PTI
ENVIRONMENTAL SERVICES
WORKSHOP PROCEEDINGS

TOXIC SEDIMENTS-
APPROACHES  TO  MANAGEMENT
June 15 - 17, 1988
Prepared for
Sally Valdes-Cogliano
Science-Policy Integration Branch
Office of Policy Analysis
U.S. Environmental Protection Agency
EPA Contract 68-01-7489 to AMS, Inc.
September 1988

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PTI  Environmental Services
3625 - 132nd Avenue S.E.
Suite 301
Bellevue, WA 98006
WORKSHOP PROCEEDINGS:

TOXIC SEDIMENTS—APPROACHES TO MANAGEMENT
JUNE 15 - 17, 1988
For
Sally Valdes-Cogliano
Science-Policy Integration Branch
Office of Policy Analysis
U.S. Environmental Protection Agency
401 M Street, SW (PM-220)
Washington, DC 20460
under EPA Contract No. 68-01-7489 to AMS, Inc.
PTI Contract No. C713-01
September 1988

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                                       PREFACE
     The Toxic  Sediments—Approaches to Management Workshop  focused on  issues that
need  to  be  addressed when  managing  toxic  sediments.    Richard Morgenstern,  Director
of the Office  of Policy  Analysis,  directed the  participants  to  better define  the  problem,
provide examples of  the  questions that need  to be  asked for informed decision-making,
demonstrate approaches that work,  and offer recommendations for improving  the  manage-
ment  process.  A series of case studies was  presented  that described the nature  and extent
of sediment problems and  the possible management options.

     On the  second day  of the workshop,  each  participant was  placed in one  of three
workgroups:     setting  priorities,  selecting  management   options,   and  implementation.
Some  general results of these workgroups include:

     •     The  importance of  recognizing  that  the management  of  toxic  sediments
           means  management   of  a   variety  of  activities,  including  issuance  of
           disposal  and  discharge  permits, selection  of disposal  methods  and  sites,
           site monitoring, enforcement, and cleanup

     •     The need for guidance on assessment methods

     •     The  need for   best  management alternatives  to  consider  a  combination of
           institutional  controls,   source   controls,   navigational   dredging   where
           possible,  and, where  necessary, remedial action

     •     The need for  waste  management decision-making  to, ideally, be integrated
           across  possible  disposal environments  (land, water, air)  to  provide  the
           least risk to human health and the environment

     •     The  importance of communication at all steps  of the management  process
           with  various  involved  parties  [within  the  U.S.  Environmental  Protection
           Agency (EPA);  among federal, state, and  local agencies; with  responsible
           parties; and with the affected public]

     •     The  need  to   establish  institutional   mechanisms  to facilitate  interagency
           coordination.
                                                               Sally Valdes-Cogliano
                                                               Workshop Coordinator
                                                               Office of Policy Analysis
                                           11

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                                CONTENTS

                                                                      Page

PREFACE                                                                ii

LIST OF FIGURES                                                        vi

LIST OF TABLES                                                         vii

ACKNOWLEDGMENTS                                                   viii

WORKSHOP ORGANIZATION AND OBJECTIVES                                1

KEYNOTE ADDRESS -
Richard D. Morgenstern, Director, EPA Office of Policy Analysis                     3

OVERVIEW OF CASE STUDY PRESENTATIONS                                 8

    PCB CONTAMINATION IN THE UPPER HUDSON RIVER                    8

    NEW BEDFORD HARBOR SUPERFUND SITE                               9

    WAUKEGAN HARBOR SUPERFUND SITE                                11

    DREDGED MATERIAL DISPOSAL FOR THE PORTS OF NEW YORK AND
    NEW JERSEY                                                        12

    DEVELOPMENT OF SEDIMENT MANAGEMENT PLANS IN PUGET SOUND    14

    SULLIVAN'S LEDGE SUPERFUND SITE                                  16

MANAGEMENT PERSPECTIVES ON CONTAMINATED MARINE SEDIMENTS -
Kenneth S. Kamlet, Chairman, Marine Board, National Research Council               18

WORKGROUP CONCLUSIONS AND RECOMMENDATIONS                       23

    WORKGROUP I - SETTING PRIORITIES FOR TOXIC SEDIMENT
    MANAGEMENT                                                      23

         Options for Setting Priorities                                        24
         How Clean is Clean?                                              32
         Comparison of Sites and Problems                                    35
         Communication Channels                                           36
         Information Needs                                                37

    WORKGROUP II - SELECTING THE BEST MANAGEMENT
    ALTERNATIVE(S)                                                   37

         Regulatory and Cross-Program Constraints                              38
         No-Action Alternative                                             40
         Sediment Remedial Action Alternatives                                42
         Disposal Alternatives                                              44
         Best Management Alternative                                        45
                                    in

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                                                                        Pace

     WORKGROUP III - IMPLEMENTING THE SELECTED ALTERNATIVE(S)       48

         Constraints to Implementation                                        49
         Relationships Between Agencies and Potentially Responsible Parties           52
         Regulatory Implementation                                           S3
         Communication with Local Interests                                   53
         Implementation Time and Integration of Source Control                    55
         Monitoring the Success of Remedial Actions                             57
         Remedial Action Contingencies Plans                                   58
         Additional Implementation Approaches                                 59
         Institutional Arrangements                                           60

CONSIDERATIONS FOR INTEGRATING TOXIC SEDIMENT MANAGEMENT
STRATEGIES                                                              61

     SETTING PRIORITIES FOR MANAGEMENT                               61

         Unresolved Issues                                                  61
         Overview                                                         63

     SELECTING THE BEST MANAGEMENT ALTERNATIVE(S)                  65

         Unresolved Issues                                                  68
         Overview                                                         69

     IMPLEMENTING THE SELECTED ALTERNATIVE                          82

         Unresolved Issues                                                  82
         Overview                                                         82

SELECTED BIBLIOGRAPHY                                                 84

GLOSSARY OF ABBREVIATIONS                                             91

APPENDIX A - LIST OF INVITED PARTICIPANTS                             A-l

APPENDIX B - CASE STUDY SUMMARIES

     UPPER HUDSON RIVER PCB SITE                                      B-l

     NEW BEDFORD HARBOR SUPERFUND SITE                             B-5

     WAUKEGAN HARBOR SUPERFUND SITE                                B-9

     DREDGED MATERIAL DISPOSAL MANAGEMENT PLAN FOR THE PORTS
     OF NEW YORK AND NEW JERSEY                                     B-l3

     SEDIMENT  MANAGEMENT PLANS IN PUGET SOUND                    B-l8
                                     IV

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                                                                  Page

    SULLIVAN'S LEDGE SUPERFUND SITE                              B-24

   * COMMENCEMENT BAY NEARSHORE/TIDEFLATS SUPERFUND SITE      B-28

   * EVERETT HARBOR DREDGING PROJECT                           B-33

   * PORT OF OAKLAND DREDGING PROJECT                           B-37

APPENDIX C -  OVERVIEW OF MAJOR LAWS AND REGULATIONS
             CONCERNING THE MANAGEMENT OF CONTAMINATED
             SEDIMENTS                                            C-1

APPENDIX D -  OVERVIEW OF NATIONAL ACADEMY MARINE BOARD
             WORKSHOP ON CONTAMINATED SEDIMENTS
             (TAMPA, FLORIDA, MAY 30 - JUNE 3, 1988)                  D-l
* These  three  summaries  were prepared as  written case  studies  only and were not
presented orally at the workshop.

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                                       FIGURES


Number                                                                              Page

   1     Generalized strategy for tiering chemical and biological tests                    64

   2     Generalized strategy for assigning priorities for remedial action                  66

   3     Simplified decision process for sediment remedial action/source control          67

   4     Basic decision-making framework for dredged material disposal                  71

   5     Example sediment remedial technologies and process options                    77

   6     Comparative display of composite cost and technical criteria                    81

 C-1     Facilitating and constraining aspects of selected environmental laws and
         regulations relating to sediment remedial action                                C-S
                                           VI

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                                       TABLES


Number                                                                            Page

   1     Comparison of Marine Board and OPA workshops                             19

   2     Summary of the dredged material alternative selection strategy
         (DMASS) process                                                            72

   3     General categories of sediment remedial action alternatives                      74

   4     National Contingency  Plan evaluation of alternatives                           75

   5     CERCLA/SARA evaluation criteria to determine applicable remedial
         technologies                                                                76

   6     Status of application of control/treatment  technologies                          78

 C-1     Examples of major environmental laws and regulations relevant to sediment
         remedial actions                                                           C-2
                                          Vll

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                                ACKNOWLEDGMENTS
    These  proceedings  were  prepared  by  PTI  Environmental  Services  for  the  U.S.
Environmental  Protection Agency  (EPA)  in  partial  fulfillment  of Contract  No.  68-01-
7489 to American Management  Systems,  Inc (AMS).  Dr. Dexter  Hinckley, Science-Policy
Branch  of the Office  of  Policy  Analysis  (OPA),  originally  conceived  of the  workshop.
Dr. Sally  Valdes-Cogliano served as project manager  for  EPA/OPA.   Mr.  Jeff  Sabol was
project  manager  for  AMS  and had  primary  responsibility  for  providing  facilities and
logistical support for  the  workshop  with  assistance  from Ms.  Karen  Peterson-Hellmann.
Mr. Robert C. Barrick was project manager at PTI.

    This  report  and  background  materials  in  the  appendices  were  prepared by Mr.
Barrick, Dr. Thomas Ginn,  Mr. Pieter Booth, Dr. Lucinda Jacobs, and Dr.  Chip Hogue  of
PTI.  Workgroup and  plenary sessions  were attended and  recorded by Mr.  Barrick and Dr.
Ginn  of  PTI,  and  Mr. Sabol  and Ms.  Cordelia Shea of  AMS.   Special  recognition  is
deserved for the planning  efforts  and review  of materials  before,  during,  and after the
June workshop by  the workgroup  leaders, Dr. Kim  Devonald  (Workgroup I), Mr.  Keith
Phillips  (Workgroup II), and Mr. Howard Zar (Workgroup III).
                                          Vlll

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                   WORKSHOP ORGANIZATION AND OBJECTIVES
     The Science-Policy Integration  Branch of the Office of Policy Analysis (OPA) sponsored
a two  and  one-half  day  workshop focusing on  regional, state, and  other  federal  agency
experience  in  managing  toxic  sediments.   These  management  activities  have  occurred
under a variety of legislative and regulatory mandates related to sediments (see Appendix C).
OPA's  interest  in  toxic sediment  management  and  an overview  of  expected  workshop
products  are addressed in the following keynote  presentation  by Mr. Richard D. Morgenstern,
Director of OPA.

     Nine  case  studies  summarized  in  Appendix  B   provided  the  framework for  the
workshop on  the  first  day.   The  six studies selected  for  oral presentation  (see Overview
of Case  Study  Presentations)  represent a range  of toxic sediment  problems in different
environments.    The  studies  illustrate  how the  problem   became  a  priority  issue,  the
management  options  considered and   those  selected,  and   the  progress  in  implementing
plans.  Management of Superfund sites, regulation by permitting of dredging and disposal,
and  state management  activities were  highlighted in  the  presentations.  The goal  of  the
presentations  was  to  provide  a  context  within  which  recommendations  on  the  best
approaches to toxic sediment management could be  developed.

     On   the  second  day of  the  workshop, the participants  divided  into  three   smaller
workgroups. Their discussion focused on the following specific areas:

     •    Setting  priorities  for toxic  sediment  problems   (facilitated  by  Dr.   Kim
          Devonald,  U.S. Environmental  Protection Agency (EPA)  Office  of Marine
          and Estuarine Protection)

     •    Deciding  on  the -best management  alternatives  (facilitated  by Mr.  Keith
          Phillips,  State of Washington Department of Ecology, Sediment Management
          Unit)

     •    Implementing  the  chosen  alternative  (facilitated by  Mr.  Howard   Zar,
          EPA Region  5).

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     On the  final day of the  workshop, each  workgroup's  results  were  summarized and
presented in  a plenary  session of  the participants, focusing  on what could  be  learned
from  current  practice  and  how  the  process  of  managing  toxic  sediments  might  be
improved.   The purpose  of  this  report is  to  document the  case  studies  and workgroup
conclusions  and recommendations.   The proceedings conclude  with an  integrated synthesis
of the  workshop  perspectives  for  managing  toxic  sediments.   Lists of invited  workshop
participants  and additional interested parties are provided in Appendix A.

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                                  KEYNOTE ADDRESS

                            Richard D. Morgenstern, Director
                              EPA Office of Policy Analysis
     I  would  like to  welcome  you  to  the OPA-sponsored  Toxic  Sediments--Approaches
to Management Workshop.   We  have  brought you here  today  because  we  hope to  tap
your  experience  and  expertise to  put together an  examination of the  "state-of-the-art"
for the management of toxic sediments within the current regulatory environment.

     In  my  remarks  today I'd  like to discuss both  the  importance  of toxic sediments
and  what we hope  to  accomplish over the next  two and  one-half days.   Before turning
to the  issue, however,  I'd  like  to  take  this  opportunity  to  introduce  ourselves in  the
OPA and explain why we are interested in toxic sediments.

     An important  role of  OPA  is  to identify emerging  issues.    We  view  contaminated
sediments as  falling  into  that category.    Contaminated sediments  have  the potential  to
become a significant regulatory  issue with important  science  implications.   The  agency's
Unfinished Business Study,  released  last  year,  found in-place toxics  to pose a high risk
to the  environment on both  a  local  and  regional  scale.   The Science-Policy Integration
Branch  of  OPA—a  mixture  of  ecologists  and  health  scientists—decided   to  bring  the
issue of toxic sediment contamination to the  forefront for a closer examination.

     The overall  goals of the  Science-Policy  Integration  Branch  in  the  OPA are  to
improve the  credibility and  consistency  of  risk  analysis,  to  provide  regulatory  support
to the  Office of  Policy,  Planning  and  Evaluation (OPPE),  and   to  coordinate  science-
policy issues.

     We view toxic  sediments as  a  potentially serious and  costly  environmental  problem
whose   management  may  require  participation  and  coordination   of  a wide range   of
players.  We  hope to assist in this process by providing a  forum  for  discussion  of  toxic
sediment management issues.

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      In  a  larger sense,  why should  anyone  be concerned  about  toxic  sediments?   Most
simply, we are  concerned that  they  may  not stay  put and  will  continue  to be  a source
of  contamination to surface waters.   As  ecologists  we  are  concerned  about the  risks to
aquatic communities.   As  government  managers  we  are concerned about the  costs  of
cleanup,  the  risks  of  no  action,  and  the  potential for  toxics  in  sediments to  undercut
the effectiveness of other programs.

      Authority  for   management of toxic  sediments  can be  found  in a number  of  laws.
Much of  the current activity in  the  toxic sediments area  is  under the authority  of  three
mandates:   Superfund,   the  Marine  Protection Research  and Sanctuaries  Act  (MPRSA),
and  the  Clean  Water  Act  (CWA).    Most of the case studies we will talk about  today
are in a Superfund  or dredge disposal context.  Looking to the future it  will be interesting
to see  if  the  in-place  pollutants  being identified under various provisions of the  CWA
(e.g.,   nonpoint   sources,   surface  water  toxics, Great   Lakes, clean  lakes,  and  estuaries
programs) will result  in additional cleanup activities  in toxic sediments.

      How  extensive  and  severe  is  toxic  sediment  contamination?    It  is difficult  to
quantify  its extent  and  severity  both  because of large data  gaps  and  because criteria
for distinguishing between  "clean" and  "contaminated"  sediments  are  still in the  develop-
mental stage.   Still,  considering the historical use of surface waters  as dumping  grounds,
there  may be hundreds of sites in the  U.S.  with toxic sediments of concern to environmental
scientists  and managers.    Harbor  areas, both freshwater  and marine, generally have the
most  contaminated  sediments due  to  wastes  received from  local  urban  and industrial
sources, boat traffic, and rivers that feed  into the harbors and drop their sediment load.

      Although no comprehensive assessment of sediment contamination  has been  undertaken,
there   have  been  limited  efforts   to  define  the  extent  of  toxic  contamination.    For
example,  a recent literature review and  interviews  with regional EPA  offices identified
and  characterized  184  toxic  hot  spots.   These  sites   included  lakes,  streams,  estuaries,
and  ocean  sites  from  every  region  of the  country.    Other  relatively  recent  efforts  to
characterize the  extent  of  contamination include  the  National Oceanic  and  Atmospheric
Administration's  (NOAA) national  program  to monitor  toxic  chemicals  in bottom-feeding
fish  and  sediments  in  50 coastal  sites and a U.S. Fish and  Wildlife  Service (FWS) report
which cited contamination concerns in 85 refuges.

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      In  summary,  although  the extent  of contamination  is  not  well-defined  at  present,
it is likely to include a large number of hot spots.

      When we do  establish  the presence  of toxics  in sediments, the  next  question may
be:   So what?   What risks do they pose to the environment and human health?

      Toxic  sediments  can   adversely   affect  aquatic  organisms   and  their   predators.
Sediments  can  be directly toxic.   In  addition,  long-term  exposure  to toxics  may  result
in  reproductive  failure,  cancer, fin rot, or  other  diseases.   It  is  easy  to  imagine that
biomagnification of  toxics may adversely affect  fish-eating birds  and  mammals.   A good
example  of  this  was when  mink,  fed  Great  Lakes  fish,  failed   to  reproduce.    PCBs
appeared to be the culprit.

      How could  toxics in the sediments affect  us?   A  prime possibility is through  the
food  chain--fish  and shellfish  could  be contaminated.  Many  fisheries  have  been contami-
nated although the  relative  contributions  from  current pollution and sediments  can  be
difficult  to  sort  out.   When  recognized  as  contaminated, use  restrictions  (i.e.,  fishing
bans) are a common risk reduction strategy.

      The  public  health  advisories  that  have been  issued  warning  against eating  fish  or
shellfish  harvested  within certain  areas can be  used  as  one  measure of  contamination
of  coastal  waters.    NOAA  has  been  trying  to centralize  this  information—preliminary
results show  that  at least 40  public  health advisories  involving  toxics have been issued
by  coastal states.   Examples of waters  with  restrictions  on  harvesting include Baltimore
Harbor,  Maryland;  the Inner  New  York  Bight  and  mort of  Long  Island  Sound,  New
York; parts  of San  Francisco  Bay and Santa  Monica Bay,  California; and the  Hudson
River.  The  health  advisories  are  based on such contaminants as PCBs, mercury, DDT,
chlordane,  and dioxin.   Advisories can  reduce  the  human risks   associated  with  toxic
sediments.  However, we may  be writing off important  fisheries in the process.

      An advisory  with  no other action is  an example of a management option.  In what
situations   is  this  our  best  option?    Is  it  our only option  in areas  that  have  been
grossly  contaminated over a number  of years?   Knowing that  the  costs  of  individual
cleanup  efforts are  high, how  do we  set  our  priorities   so  we  can  make the  greatest
impact on improving water quality?

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     These  are only a  few of  the  questions  we  hope to address in the  next  few  days.
They are, as you know, difficult questions—which is why we need  your help.

     We  hope  that the  case  studies  presented  today  will  provide  the  subjects  and
framework for  tomorrow's workgroup  sessions.   You will  hear  about  several  Superfund
toxic  sediment  sites,  dredged   disposal  management  and  regulation,  and  some  state
activities in toxic sediment  management.

     Tomorrow  we  can  take  what  we've  learned  through   this examination  of  case
studies and apply it to the three workgroups:

     •    Establishing priorities

     •    Selecting a management option

     •    Implementation.

By the end of these two days we hope to have:

     •    Better defined what  the problems are

     •    Provided good   examples  of the  questions  that  need  to  be asked  for
          informed decision-making

     •    Demonstrated approaches that work

     •    Offered recommendations for improving the managerial  process.

     In preparing for this workshop, we at OPA  were struck  by the need for greater com-
munication and coordination- on  this issue.   This  sharing of experiences between  offices
in EPA,  between  regions  and headquarters,  between states and the  federal  governments,
and  among federal  agencies is an important part  of any  effort  to improve toxic sediment
management.    We  are  pleased  to  note that steps have  already  been taken  to facilitate
this  need.  A Sediment  Oversight Committee has recently been  organized by the Office
of Water  which includes  members from several offices  in EPA headquarters,  regions, and
laboratories.   The committee  will be  meeting again  at  the  end  of  June  at  the Duluth,

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Minnesota laboratory.    Included  on  the  agenda  is  the  development of  a  near-term  as
well as a  Waukegan 3-  to  5-year operating  plan to guide and coordinate  sediment  policy
and  activities  agency-wide.   This  operating plan  is  expected to  address issues  such  as
overlapping  authorities,   regulatory  authority,   regulatory  mechanisms,   special   regional
concerns,  and  prioritizing  sediment  issues.  It  will also address  technical issues  such  as
EPA  Office  of  Research  and   Development  (ORD)  priorities,  methods   for  calculating
sediment  criteria,   standardized  and  predictive  bioassays,  matching  sediment  evaluation
method to a site, and the  fate of contaminated  sediments.

     In addition, key  activities will be  identified  that are to  be reported to the  admin-
istrator on  a   regular  basis.   As  efforts  to   address  contaminated  sediments  progress,
other federal and stage agencies should be  informed and involved.

     I  will  be  very  interested in  looking  at the  results of  your  efforts over  the  next
few  days.    We have  brought together  a  very  able  group of participants for  this  OPA
workshop  and  expect  its results will be beneficial to those in the regions and  headquarters
who make  decisions on toxic sediment  management.   We appreciate the  time  you have
taken to devote to this task.  Thank you  and good luck.

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                    OVERVIEW OF CASE STUDY PRESENTATIONS
     A brief  summary is provided in this  section of  the  major points made during  the
presentations  of  case  studies  on the  first  day  of  the workshop.    Formal  papers  were
not submitted  for these six  presentations,   but  case  study  summaries  are  presented  in
Appendix B.   Summaries  are  also  provided  in Appendix  B  for  the  Commencement  Bay
Nearshore/Tideflats Superfund  project (the  largest  marine  Superfund  site),  the  Everett
Harbor  Navy  Homeport dredging project in Washington  (the  deepest  proposed disposal/-
capping  project  in  the  U.S.),  and  the  Oakland  Harbor  dredging  project  in  northern
California (the largest proposed  dredging project to  date in the U.S.).
PCB CONTAMINATION IN THE UPPER HUDSON RIVER
Presenter.   Clifford Rice, U.S. Fish and Wildlife Service
            and PCB Settlement Advisory Committee

     A  detailed  case  study for  this site  has been  prepared and  given to the  National
Academy of Science Marine  Board (Sanders  1988).  Discharges of polychlorinated  biphenyls
(PCBs)  from capacitor  manufacturing plants  operated  by General  Electric Company  (GE)
started  in  1947 at Fort Edwards and  in 1952 at Hudson  Falls along the Upper  Hudson
River.    Removal  of a dam at Fort Edwards  in 1973 resulted  in  downstream  release of
additional contaminated  sediment  as  well as logging  debris.   Elevated  levels of  PCBs in
Hudson River fish were first detected in 1969.  By 1975, various fisheries were closed and
administrative proceedings  were begun  to seek cessation of PCB  discharges,  penalties, and
rehabilitation of the Upper Hudson River.  A ban on  the  commercial striped bass fishery
was  later extended  to  include  striped  bass  from Long  Island Sound and the  New  York
Bight (consumption  of  PCB-contaminated fish  is the primary exposure  route of  concern).
     An estimated 500,COO  io  i,000,000  cubic yards of  contaminated  material  has  been
released; approximately 80  percent of  the  total derives from one  pipe.   As the result  of
a settlement at which it  was concluded  that  no laws had  been  broken, PCB discharges
were  ceased  in  July  1977,  wastewater  treatment  facilities  were  constructed  at   the
plants,  and studies  were undertaken  to  evaluate  environmental  effects and  rehabilitation.

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A PCB Settlement Advisory Committee oversees many of these studies  under a $6  million
fund.   The  committee  is  a  panel  of  scientist, engineers, environmental  activists,  and
public  representatives  working  in  cooperation  with  the  New  York  State  Department of
Environmental Conservation.

      Dredging-secured encapsulation  is one alternative that  is  favored  based on  selection
criteria  emphasizing   demonstrated  technologies  for  which  costs  are   not   excessive.
Alternatives  for  PCB removal  and/or destruction  from dredged sediments  are  still  under
evaluation.   A  continuing  issue is the need to forestall  further spread of PCBs into the
lower  reaches  of the  Hudson  River.   The  more  erodible  sediments  (PCB concentration
approximately  20 ppm)  are  being  addressed  first  rather than the  highest concentration
sediments (>50 ppm in some areas).   To date, several cleanup actions have been  undertaken
at Fort Edwards; rock riprap  has  been built  along  a  portion of the Hudson River to
prevent further scour, and monitoring of fish, river water, and  sediments has continued.

      Approximately 360,000 cubic  yards of sediment  has been  removed  and treated at  a
total  unit  cost  of $110/cubic  yard  [dredging  costs  are  estimated  to  be  <10  percent of
the  total  cost;  the  remainder  is   primarily because  of  the need  for  containment in  a
Resource  Conservation  and  Recovery  Act  (RCRA)-type   facility].    Approximately  10
percent of the total  PCB  in  sediments will  be  dredged (i.e., approximately 51,000  pounds
of PCBs).    It was  estimated  that the dredging  will  produce  a 20  percent  reduction in
fish  tissue burden and the downstream  transport of  PCBs.   Total requested  budget for
the project is $40 million (half federal funding; half state matching funds).

      During  the question period,  the merits and  rationale  of the  planned  PCB reduction
were  debated.   In addition, opportunities for removal  of  PCBs  during  navigation  dredging
were  also  discussed  but site  availability for  the disposal  of  the  dredged  material  is  a
key  constraint.   A  number of additional responses  during  the  question period  have  been
integrated into the above summary.
NEW BEDFORD HARBOR SUPERFUND SITE
Presenter  Frank Ciavattieri, EPA Region 1

      A  detailed  case study  for this  site  has  been  prepared and  given to  the National
Academy of  Science  Marine  Board  (Ikalainen and Allen  1988).   PCB  contamination is

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the major concern  although there  is  also some  metals  contamination (especially  copper).
The contamination has resulted in the closure of  fisheries to varying degrees (approximately
5,000 acres are affected) and  the idling  of  200-300  fishing  vessels.   It  is estimated  that
approximately  4-8 pounds/day  of PCBs  leave  the  upper  estuary  and  enter  the  bay;  80
percent of the  PCBs  lie in two hot spots.   The  final study  will rely on  a  hydrodynamic
and  sediment  transport model,  which  is  now  being  calibrated.   The feasibility study is
scheduled for  completion at the end  of 1988  and a  Record  of  Decision  is  scheduled for
the summer of 1989.

     A  risk  assessment  was  conducted  to  quantify  the  potential  risk to  human  health,
to determine if remedial action  will mitigate risks, and to serve as a baseline  for evaluating
effectiveness (and  identify  the  need  for  cleanup).   Direct contact,  ingestion of sediment
and  biota, and air inhalation  account  for  99 percent  of  the potential  exposure.   Three
distinct study  areas  and remedies have  been  established;  the  cleanup level  will probably
be limited  by  available technology.   The primary  alternative  is  removal  of  PCBs  but
treatment alternatives  are  not  as  promising  as originally  hoped.   Potentially   1.5 million
cubic yards of sediment could be removed at the site.

     A pilot  study has been  scheduled to begin  this fall  in  which dredging  and  disposal
techniques studied in  the   laboratory  will be  demonstrated  in the  field.   Tests  will  be
conducted  with  three  dredges  (cutterhead, mudcat,  and  match  box) and two  kinds  of
disposal,  including confined (diked  on  shoreline; treated  effluent)  and  confined aquatic
disposal  (CAD) (burying of contaminated sediments below  clean  sediments that  have  been
excavated).    Special  concerns   for  the pilot  study  include  the   wide variation  in  depth
that  will  require  modification  of  dredging  techniques.   Funds for demonstration  projects
are not  limited to Superfund  or even  EPA-led sites but  preference  is  given  to  sites  on
the EPA National Priorities  List (NPL).

     The overriding  regulatory  concern is  attainment of  Food  and  Drug Administration
(FDA)  limits  for  fish tissue  concentrations  of  PCBs  (5  ppm  wet  weight)  and federal
water  quality  criteria.   Approximately  $15-18  million  has  been  spent  to  date.   It  is
estimated that  containment  of  sediments  in  the upper   harbor  could cost  $20  million;
dredging, removal,  and  treatment could cost  up to  $1  billion.    A  conservative  estimate
by  NOAA  of  the cost  of the  fisheries  closure  is  approximately  $10-12 million for  an
estimated  closure  period  of  50-100  years;  the  absolute catch  value  is  approximately
                                            10

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$1 million/year.  Development of the harbor has also been limited because no maintenance
dredging has been permitted.

     During questions, it was  asked how  priority  funding was obtained for the  project.
New  Bedford  received funds because  it is on  the NPL  (the  Hudson  River  site  in  the
previous case  study is  not)  and  the  state  declared  the site  a  Number  1  priority  for
action  (automatically elevating  the  site  to  the NPL).   There was  also  discussion  of  the
proposed revised Hazard  Ranking System (HRS)  in which food  chain  contamination will
play a  stronger  role  relative to  human health concerns.   It  was  noted  that  based on
the original  HRS,  New Bedford  did not make the  initial ranking  of NPL  sites  although
there  were  identified  problems.   The  increased emphasis  on these environmental  risks is
expected to  ease funding for marine sites.   Responses to additional  questions  have been
integrated into the above summary.
WAUKEGAN HARBOR SUPERFUND SITE
Presenter Howard Zar, EPA Region 5

     Waukegan  Harbor is a federal  Superfund site  located in Illinois.   PCB  contamination
at Slip  3 of the site  spans a concentration  range of 500  to  10,000 ppm;  cleanup at this
site  is  expected to  abate  most of  the  problem  in the harbor  and  Lake  Michigan.   In
one  localized  area,  PCB  concentrations exceed   10,000  ppm.    There is  approximately
300,000 pounds of PCBs in 11,000 cubic yards of  sediment  in  the  harbor.   An estimated
20-40  pounds/year  of PCBs  is discharged  to  Lake  Michigan.    This  local discharge of
PCBs from  Waukegan  Harbor  is  significant,  although atmospheric  deposition  of  PCBs
from various  sources  is  the  largest  lakewide contribution  to Lake Michigan.   Mr. Zar
was  only able  to discuss  a  previous proposal  embodied in  a  1984  Record  of Decision.
The  issue  has  been in  litigation  and  negotiation  since then, although  current  prospects
for settlement are very good.

     The alternatives  previously selected for implementation  include removal  and disposal
of highly contaminated  sediment  in  Slip  No. 3  and  the  Upper Harbor  ($3.IS  million);
dredging, dewatering,  and  disposal of  material in  an adjacent  parking  lot  ($10  million);
removal and disposal  of highly contaminated material  in an adjacent  ditch  area  ($0.74
million); containment  and  capping of  the   remaining  material  in  the  ditch  area  ($4.21
million); and containment  and capping  of  material  in  the  parking   lot   ($3.2  million).
                                           11

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The  total  cost of $23.3 million (most recently estimated  at >$27 million) for the five  cleanup
actions  has  been evaluated  in  a  feasibility  study  that  considered   14  different   cleanup
processes.    Treatment  options  evaluated  incineration  according   to  Toxic   Substances
Control Act  (TSCA) requirements for landfill  disposal.  A  problem in implementation is
that  the placement  of dredged  material behind  a cofferdam  will landlock  a private  ship
operation, resulting in adverse public reaction.

     Overall  objectives  of the 1984  plan were  to:   sequester or destroy  >90  percent  of
PCBs in the  harbor and remove >99  percent of PCBs when U.S.  Army Corps of Engineers
(Corps) navigation dredging is included; reduce the discharge of PCBs to a small percentage
of the  20-40 pounds/year;  and  reduce  the  PCB level in  fish  to  below  the FDA action
level.   Based on transport  and  fish  contaminant modelling, the product is expected  to
attain these level.

     The site's  legal  history began  in  1978  when  EPA filed suit  against  the  potentially
responsible party [prior  to   the  signing  of the  Comprehensive  Environmental Response,
Compensation and Liability  Act of   1980  (CERCLA)  in  December  1980].    After  EPA
planned  a federal  cleanup  action  in  January  1983,  the   1978  suit was expanded.    A
record of decision was  signed  in May  1984 by Lee Thomas and EPA moved  to  dismiss
the 1978  suit in June  1984.   After  dismissal of the suit in  February 1985, EPA obtained
a design access  warrant which was  blocked in March  1985  by a stay of  warrant.   Since
April  1985,  protracted  legal  proceedings were  expected  over  the  issue  of site  access;
passage of the Superfund  Amendments and Reauthorization Act (SARA)  in 1986 provided
authority for  access.  The issue is now  under negotiation.

     Questions  asked  in  this session related  to  details of  the  remedial  plan, especially
concerning the significance of  the PCB  contribution relative to  the  overall Lake Michigan
PCB  budget  and the  no action  alternative,  treatment  alternatives, and  the  food  chain
modeling predictions. Responses have been integrated into the above discussion.
DREDGED MATERIAL DISPOSAL FOR THE PORTS OF NEW YORK AND NEW JERSEY
Presenter Carol Coch, U.S. Army Corps of Engineers, New York District

     A variety  of operations and  planning  issues were  discussed,  including ocean dumping
test  criteria,  types  of  dredged  material   to   be   disposed,  the  need  for  alternatives,
                                           12

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navigation  dredging,  testing and  siting criteria,  and the overall  decision  process [including
an  interagency  steering  committee   and  SOO-member  Public  Involvement  Coordination
Group (PICG); see the  case study  summary in Appendix B for  additional details].   Major
decisions follow  the  Corps/EPA  management  guidelines  for dredged  material.   New York
District  has  developed  a  regional  manual that  includes  guidance  based  on  indigenous
organisms.

     Most  of  the  dredging is  conducted  by clam  shell  dredge;  6  million cubic  yards  are
disposed annually  (the  equivalent  of  three World Trade  Center  towers).   Approximately
90-95  percent  meets  unrestricted  ocean  dumping  criteria  and  is  disposed  in  two  ocean
sites located  6 miles east (Sandy  Hook)  and  12  miles south (Rockaway  Inlet of the New
York Harbor Transect).  Primary laws concerning disposal include  the National Environmental
Protection  Act (NEPA),  CWA  Sections 401 and  404, and  Section  103 of the MPRSA  of
1972  (as amended).   Federal  jurisdiction  extends beyond  the  3-mile limit;  both  federal
and state agencies have jurisdiction within  the 3-mile limit.

     Three categories of material are designated:

       I.   Meets criteria for unrestricted disposal

                Excluded from further testing (e.g., sand)

                Fine-grained material (requires bioassay/bioaccumulation testing).

      II.   Meets  criteria   for  restricted   disposal  (e.g.,  is remediated   by  capping with
           Category I material)

     III.   Does  not meet  criteria  (not  ocean  disposed,  but  may  meet upland disposal
           criteria).

The  cost for  the  feasibility studies  has  been approximately $0.5  million/year  over a  7-
year period.  The unit cost of oceun disposal is approximately  $5/cubic yard.

     The Mud Dump  site  was designated by  EPA in June  1984  with  a capacity  of  100
million cubic  yards (a  new  site  will  be needed by  the  mid-1990s).   Alternative disposal
options  for  large  volumes  of  dredged  material  include  upland disposal, use of dredged
                                            13

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material  as sanitary  landfill cover, containment,  subaqueous  borrow  pits, and continued
ocean  disposal.    In  special  cases,  beach  nourishment,  in-channel  sand  mining,  and
wetlands stabilization  could  be  used  for  uncontaminated  material, and  containment  areas
could be used  for small volumes of contaminated material.

     During questions,  it  was  noted  that  most  of  the problems  in deciding  appropriate
disposal  options occurred with  Category II  material.   In response to a question concerning
the  sensitivity of  the  bioassay  tests  that  were  used,  it was  noted  that the  bioassays
were  refined  for  use  in  New  York  Harbor.   The  testing is constantly being revised to
reflect environmental  changes.
DEVELOPMENT OF SEDIMENT MANAGEMENT PLANS IN PUGET SOUND
Presenter Catherine Krueger, EPA Region 10

     Sediment planning efforts in Puget  Sound involve multiple  federal and  state agencies,
including the  Washington  Departments of Ecology  (Ecology)  and  Natural  Resources, the
Corps (Seattle District), and EPA (Region  10).  A  large amount of sediment is deposited in
deep  basins  that  extend  to  900  feet; it is  estimated that approximately  80  percent  of
the contaminants  discharged  to  Puget Sound remain within  the  main  basin as  a result
of recirculation and deposition.   Contaminants  eventually  bind  to sediment  particles  and
settle  to  the  bottom  of  the  sound.    Little  is  known concerning  specific  cause/effect
relationships,  but concerns over  toxics contamination  and  observed  biological  effects  in
the late  1970s  and  the  1980s  eventually  led  to  the  establishment of  a  sound-wide
management  plan  by the  Puget Sound Water Quality Authority  (Authority) in  1987.  The
plan balances  long-term  solutions  with near-term  needs for  environmental  controls.   As
a  matter of policy,  association  of   biological  effects and chemical contamination  have
been  accepted as  a means of identifying problem  sources of  chemicals.   The  presence
of contaminants is not the critical aspect; biological effects are.

     At the industrialized Commencement Bay Superfund site,  25  major sources  and  400
potential sources have  been evaluated.  Cleanup levels  that  are  considered environmentally
protective  for  sediments  have  been proposed for the  Superfund  site based  on biological
effects  relationships  established  for  71  chemicals.   Estimated  cleanup  costs range  from
$24  million  to  $64  million,   and result from a  remedial  investigation/feasibility study
(RI/FS) that  cost  approximately  $3 million.
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     In  assessing   procedures   for  evaluating  navigation   dredging  projects,  the  Puget
Sound  Dredged  Disposal  Analysis (PSDDA)  accomplished   the  following  three objectives:
(1)  determine  "how clean  is clean" for open-water,  unconfined  disposal sites; (2) develop
test procedures; and (3) evaluate costs of different  alternatives for disposal site management
relative to  the impact  of  different volumes of  dredged  material.   It  was  decided  that
minor  adverse  effects (i.e.,  sublethal effects  onsite; no effects offsite) was  an  unacceptable
goal for disposal  sites,  in part because  physical impacts  routinely  occur  during  operation
of these sites.

     The Urban  Bay  Toxics  Action  Program, a  major  component  of the  Puget  Sound
Estuary  Program  (PSEP),  was  initiated  in  1984   by EPA's  Office of  Puget  Sound  and
Ecology.  Substantial participation has  also been provided  by  the Authority  and other state
agencies,  and  local government.    Action  programs for  individual  bays  consist  of  the
identification of  problem  areas in  urban  bays (problem   definition  predominantly based
on  sediment  contamination),   identification  of  potential  sources,  development  of  an
Action  Plan for source control, and formation  of an  Action Team for  plan  implementa-
tion (including  permitting,  inspections,  and  enforcement  activities).    Actions  to  date
have  focused  on Elliott  Bay,   Everett Harbor,  and  Budd   Inlet  adjacent to  the  cities of
Seattle, Everett, and  Olympia, respectively.   Source  control actions  are  well  underway
as the  focus of the action  programs.   Sediment  remediation has  not been undertaken at
any of the sites.

     In response to the Authority's 1987 management plan,  Ecology is currently developing
state  sediment  quality  standards  for  use  in  preventing  sediment  contamination  and
identifying  and  designating sediments  that  have  adverse   effects   on  biological  resources
or  correspond  to  significant health risks  to  humans.   The standards  shall  be  used by
Ecology  to  identify  sites   with  sediment   contamination,  and  as  a  basis   for  limiting
industrial and  municipal  discharges that cause sediment contamination  in  excess  of  the
standards.    Separate  regulations  and  guidelines   are  also  being   developed  for  limiting
point  and   nonpoint sources, prioritizing and conducting  sediment  remedial  actions,  and
identifying sediments that are acceptable for disposal in water  or on land.

     During  questions,  a  representative  of  the  Corps  commented  that  the  empirical
sediment  quality  values  approach  applied   in  Puget  Sound  was  good   for  identifying
problem sites  for  remediation,  but that there were  questions concerning the applicability
                                            15

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of  chemical  predictions  of  biological  effects  at  disposal  sites  based  on  analyses   of
material  to  be  dredged (i.e.,  because  a cause-effect link  had  not  been  established  for
disposal  site effects).    In  addition,  state  testing  requirements   that  might   be  more
rigorous  than federal  guidelines could  result in  the State paying  the differential testing
cost for  federal  dredging projects.   Finally, the representative  felt that some of  the tests
recommended in  Puget  Sound were unacceptable  (e.g.,  oyster  larvae  bioassay)  for  the
Corps1 Section 404 assessment  under the  CWA because  they  were applications  of water
column tests  to  sediments.   From  a federal viewpoint,  the  participant believed  that  the
standard  bioassays (e.g., using adult organisms) met the intent of Section 404.

      In  response,  it  was noted that specific  cause-effect links  were  not needed to  use
biological  predictions  in  risk  management  of  disposal  sites;  that the  decision on testing
requirements  was delegated  to  the states; and that  the Corps Seattle  District  had  accepted
the  bioassay  tests  as modified for  sediments  (the  concern  was  at  the  national  Corps
level).   It was  also  noted  that some of the tests  typically used  by  the  Corps had  been
determined  to be  insensitive,   and  that  although  some  of  the  more sensitive  bioassays
may  be  considered  experimental  elsewhere,  they  are  routinely  applied  in  Puget  Sound
and are  generally accepted.   It  was  agreed that  the  standard  Corps bioassays   met  the
intent of  Section 404,  but  that Section 401 certification  under the  CWA  was a  separate
issue to be decided by the State  with concurrence  by EPA.
SULLIVAN'S LEDGE SUPERFUND SITE
Presenter  Jane Downing, EPA Region 1

     Sullivan's  Ledge in New Bedford, Massachusetts, is an  active golf course  in  a  wetlands
environment.    PCB  contamination  is  the  primary  concern, and  concentrations  in soil
samples  range from undetected to  over  2,000 ppm.   Two  areas  contain concentrations  in
excess of  100 ppm.  Other soil contaminants include lead  (>4,600 ppm  in one area) and
polynuclear  aromatic   hydrocarbons.     Chief  risks   related  to  soil   contamination  are
associated  with  accidental  ingestion  of  the  surface  soils,  and  erosion,  which  results  in
the  deposition  of PCB-contaminated  sediments  in  adjacent water  bodies.   There appear
to  be  minimal  risks  to public  health  associated  with  this  sediment  contamination  but
there are potential risks  to terrestrial and aquatic life.
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     Site-specific sediment quality  criteria have  been  applied at Sullivan's  Ledge  based
on  guidance provided  by  EPA's  Office  of Criteria  and  Standards  (the  criteria  are  based
on   water  quality  assessments  for  freshwater  organisms   integrated  with  equilibrium
partitioning  theory  for  nonpolar  organic  compounds   in  sediment).    Bioaccumulation
results have  been evaluated  relative  to  FDA  action  levels.   An evaluation of remediation
vs.   no-action  alternatives  considered  NOAA  concerns  about  possible  impacts to   the
Paskamansett  River,  the  magnitude  of  sediment  contaminant  levels,   compliance  with
federal  and  state applicable  or relevant  and  appropriate  requirements  (ARAR),  disruption
of  golf   course  activities,  significant adverse  impacts  to  wetlands,  and a  cost/benefit
analysis.     Remedial  alternatives  included  containment;  in  situ   biological  treatment;
removal   and  disposal  of  sediments;  removal,  solidification,  and  disposal  of  sediments;
and  onsite  incineration.   The  cost  of remediation is estimated at $4  million  for capping
sediments; $10-20  million  for pumping  and  treating  groundwater;  and  <$1  million  for
excavating and solidifying selected sediments (there are additional costs of site restoration).

     The  final  alternative  will  follow  CERCLA/SARA  guidance,   which  requires   the
selection  of a   remedy  that   ensures the protection of  public  health  and  environment,
complies  with  federal  and  state  ARARs,  applies  cost  effectiveness as  one of  several
selection  criteria,  focuses  on  treatment  to  attain a permanent  remedy  if possible,  and
provides  the  best  balance  across  all evaluation  criteria.   Some  of  the  alternatives  will.
provide complete remediation, while others mitigate the problem.

     During the question  period, there  was some  concern as to  why  there was public
usage  of  the  site  prior to remediation.   There was additional clarification concerning
the  application  of  sediment  criteria  based on   freshwater   quality   standards.    It  was
noted  that  the   use of  the criteria at  the site was  intended  as  a yardstick  for problem
identification; not necessarily for deciding  remedial actions.  Because the  PCB  bioaccumula-
tion criteria were  linked  to  an  FDA  action level  (set  in part  by  economic  factors) it
was also questioned  whether  an  environmentally protective  decision  for  wetlands  could
be  made.  An  alternative  criterion  related  to  magnitude  of  potential  chronic  effects  of
PCBs may be used.
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                         MANAGEMENT PERSPECTIVES ON
                        CONTAMINATED MARINE SEDIMENTS

                             Kenneth S. Kamlet, Chairman
                   Marine Board Committee on Contaminated Sediments
                               National Research Council
     On the second day of the workshop,  a plenary session  was held to hear comments
from  Dr.  Kenneth Kamlet,  who  presided  over  the  National  Research Council's   1988
workshop on  "Strategies and  Technologies for Cleaning  Up  and  Managing  Contaminated
Marine  Sediments."  The charge of the Marine Board, scope of  the Board's contaminated
sediment project,  and Board  membership  as  summarized  by Dr.  Kamlet  are  presented  in
Appendix D.   Dr.  Kamlet also presented a  comparison of  the  Marine  Board and  OPA
workshops  (Table  1); the  former  focused  primarily on  technical  issues and the  latter
focused on  policy  and  management issues.  The following  comments were presented  as  a
summary of  issues and  observations concerning the  three areas of  emphasis  at  the  OPA
workshop:   setting priorities  for management,  selecting  the  best  management  alternatives,
and implementing the preferred alternative.

     Observations for setting priorities for management included:

     1.   Estimation of human health and  ecological  risks  is  a matter which,  in  the
          Superfund context, will theoretically occur under an improved MRS.

     2.   From  a remediation  standpoint,  the most important  factors  are   likely  to be
          technical  and  cost   feasibility,  natural   recovery   estimates,  and  ability   to
          distinguish and/or control sources.

     3.   A "how clean is clean"  standard  is clearly  needed,  if  not for  setting priorities,
          at least for defining cleanup targets.

     4.   A  unique  attribute  of  underwater  sites  is  that  the  need  for   navigational
          dredging may  become a  major  driving  force  for sediment excavation.  In such
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         TABLE 1. COMPARISON OF MARINE BOARD (5/31 - 6/3)
                   AND OPA (6/15 - 6/17) WORKSHOPS
                             Parallel Elements
    Marine Board Workshop

Extent of Contamination
 (EPA & NOAA programs)

Classification of Contam-
 inated Sediments

Significance of Contami-
 nation (benthic biota,
 human  health)

Mobilization and Resus-
 pension

Assessment and  Selection
 of Remedial Technologies
Case Studies
  New Bedford Harbor, MA
  Hudson River, NY
  James River, VA
  Commencement Bay, WA
  Everett Harbor Dredging
   Project
          OPA Workshop
Setting Priorities (Workgroup I)


Setting Priorities
Workgroups
Selecting the Best Management
 Alternative(s)

Implementing the Selected
 Alternative(s)

Case Studies
  New Bedford Harbor, Ma
  Hudson River, NY

  Commencement Bay Nearshore/
   Tideflats
  Puget Sound Sediment Management
  Everett Harbor Dredging Project

  New York Harbor Dredged
   Material Mgmt. Plan
  Waukegan Harbor Superfund Site
  Sullivan's Ledge Superfund Site
  Port of Oakland Dredging Project

Workgroups
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     cases, there could  be  advantages  to utilizing CWA  Section  115  authorities  (if
     funded),  in conjunction with Section 10/404 dredging authorities, in preference
     to CERCLA/SARA authorities.

Observations on selecting alternatives included:

1.    Short-term risks  associated  with  sediment  removal  can  be  minimized by use
     of  specially  designed  dredges,  which  are  readily  available  overseas.    There
     are  a  variety  of  institutional   issues (e.g.,  Jones Act   restrictions  on use  of
     foreign-hulled  vessels  for  dredging) which  may complicate  but   should  not
     totally  prevent availability of  this  equipment in  the  U.S.   U.S.  suppliers  of
     dredging  equipment could  provide such  equipment in the U.S.,  if  there  were
     confidence that a  sufficient market  exists here for this equipment.

2.    Among the factors  which  make "no action"  the alternative of choice,  "adverse
     impacts  of remediation"  and  "institutional  constraints"  should  not  be  major
     constraints  [except  where   intervention   would   cause    unacceptable   habitat
     damage  (e.g.,  to  wetlands)  wholly apart  from  any  potential  for  sediment
     resuspension].    Important  considerations  include  not only  "high   remediation
     costs" and "low mobility of toxics", but also "rapid covering" over of contaminated
     sediments   (by  natural  deposition),   and  very  "high  mobility  of  toxics" (or
     contaminated sediments).

3.    In-place  containment  or treatment   a  potentially significant  legal  and  policy
     issue  is  whether  capping  with  clean sediments is to be  deemed  a  preferred
     "treatment" approach under  SARA Section 121(b).   On  the  one   hand, capping
     can  be performed  onsite  (which  is  favored  over  offsite transport)  and it can
     "permanently and significantly reduce the  ... mobility of the hazardous substances,
     pollutants,  and contaminants" present.  On  the  other hand,  it is not  treatment
     in the usual chemical, biological,  or physical sense.

4.    The  most obvious difference  in  risks  associated  with  upland  and aquatic
     disposal of contaminated  sediments  is  the greater significance  of  food  chain
     contamination as  an exposure pathway with aquatic  disposal, and greater concerns
     regarding   leaching  of  contaminants  into  groundwater  and/or  volatilization
     into the air with upland disposal.
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     Observations on selecting alternatives included:

      1.    Legislative  or  regulatory constraints:   lack  of  HRS  coverage  of  food  chain
           pathway  (being  rectified);  lack  of  "how  clean  is  clean"  standards  (sediment
           quality  criteria will  partially  fill this  void); status  of capping  as  preferred
           remedial  technology; lack of funding  for CWA Section  115  "in  place"  pollutants
           authority;  need   for  more  explicit  consideration   of  when  rapid  "removal"
           action is  required to address contaminated sediment problems.

     2.    Public  perception  of  risks  has,  in  at  least  several  cases,  blocked  or delayed
           implementation of remedial action involving  excavation  and  upland  disposal  or
           treatment of contaminated  sediments.   While a shift  from underwater to upland
           may be  lexicologically and  physico-chemically inappropriate where  the primary
           sediment  contaminants  are  heavy  metals   (the  mobility of  which  could  be
           increased  by  the  shift  in  redox  potential  associated with  exposure to  air),  it
           probably  makes   sense  in  many  cases  where  the  primary contaminants are
           toxic organics (provided precautions are taken to limit volatilization).

     3.    Remedial  action projects  involving  contaminated  bottom sediments often  consume
           inordinate time and money in seeking to characterize and prioritize the problems
           and  in  evaluating  potential  alternatives.   While  this  may  be acceptable  and
           justifiable   for  sites  involving  large   aerial extents  of   contamination   (e.g.,
           Commencement Bay, New Bedford Harbor, Upper Hudson  PCBs),  it clearly cannot
           be sustained on a routine basis or for smaller-scale sites (e.g., Waukegan Harbor,
           Sullivan's  Ledge).   Completion  of HRS  revisions and  sediment  quality  criteria
           (and/or other "how clean is clean"  standards)  should help matters considerably.

     4.    Opportunities  to  piggyback  navigational projects  may  not   be  widespread but
           are  certainly  significant.   Navigational maintenance  dredging,  by  definition,
           occurs  in areas of significant  net sediment  deposition.   These  areas  therefore
           often coincide with hot spots or sediment contamination.

     In  summary,  Dr.  Kamlet  concluded  that  although  the OPA  and  Marine  Board
projects  have  much  in common, they  differ in  primary orientation.   The  Marine  Board
project  is  principally  geared  to   enabling  decisionmakers  to  better  select   appropriate
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remedial  technologies.   The  OPA  project  seems  primarily  designed  to  identify  policy
issues and to provide broader management recommendations.

     Each study  would doubtless benefit from contributions from  the other.   It is  suggested
that  each group  be afforded  the  opportunity to  review and  comment on  a draft version
of the  report  generated by  the  other.   (The  Marine  Board Committee  has met  again
August 3-5, with  a final report to be issued by the end of the calender year).
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               WORKGROUP CONCLUSIONS AND RECOMMENDATIONS
     Three  workgroups  met  on  the  second  day  of the  workshop to  discuss  specific
issues  related  to toxic sediment  management.   The  following  sections describe the focus
of  each  workgroup  and  present  workgroup  summaries.   The  discussion  of  conclusions
and  recommendations is organized  according  to a  list  of  questions addressed  by  each
group.  Comments  directed to workgroup leaders by  participants during summary  presenta-
tions  at  the  final  plenary  session  of  the  workshop  have  been  integrated  into  each
section.  A  list  of major  unresolved issues  is presented in a following section (Considera-
tions for Integrating Toxic Sediment Management Strategies).

     Prior to  the workshop, the workgroup  leaders met and agreed  that, where appropriate,
navigation dredging issues should be distinguished from sediment  cleanup  issues.   Although
navigation dredging may involve removal of  contaminated sediments,  the  procedures  used
to determine  priorities,  best  management  alternatives,  and  implementation  strategies  in
navigation  projects differ from  those  for  projects focused  on  remedial  actions.    In
navigation dredging,  the primary objective is  to  make a  channel  possible  while minimizing
adverse environmental  impacts.   Consideration  of  any  ancillary  ecological improvements
due  to  removal  of contaminated  sediments is  not  appropriate under  the  law  in  setting
priorities  for  federal dredging  projects.   Potential ecological impacts  of  dredged material
disposal  must be  assessed  under the CWA and MPRSA.   By contrast,  the objective  of
cleanup projects  (e.g.,  Superfund) is  control  of  ecological  and health risks, and  dredging
is one  alternative that may  be  used  to accomplish this objective.  To the extent appropriate,
the  workgroup leaders agreed to separate these types of projects during discussion.
WORKGROUP I - SETTING PRIORITIES FOR TOXIC SEDIMENT MANAGEMENT

     Management  of toxic sediments requires  government  agencies to perform or oversee
a variety of activities, including:

     •     Issuing disposal and  discharge permits

     •     Selecting disposal sites for dredged materials
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      •    Monitoring disposal sites

      •    Cleaning up contaminated sites where navigational dredging is not required

      •    Enforcing applicable regulations and permit conditions.

Priorities must be  established for each of  these  activities.    Participants in Workgroup I
discussed the  management  options available for performing  these activities  and  identified
ways  to establish  management  priorities.     The  workgroup  discussions  addressed  four
groups  of questions,  and  a  summary  of  each is presented  below.   For  each question,
participants described  their experiences  with previous projects and  highlighted  unresolved
issues.    When  appropriate,  decision-making  processes  pertinent  to  navigation dredging
projects  and   those  for   cleanup  projects  not  involving   navigational  dredging  needs  are
summarized  separately.    Workgroup I   also  explored issues  associated  with determining
"how clean  is  clean",  how  to  compare sites  and  problems, and  the  need to facilitate-
communication  channels.    Discussion of these topics is   summarized  in separate sections
following options for setting priorities.


Options for Setting Priorities

      What  options  are   there  for  establishing   sediment   management  priorities?
      How are  priorities  established  for such management  activities  as  permitting,
      disposal site selection, monitoring, enforcement, and cleanup?
     Permits—Two  basic  types  of  permits  are issued relevant to  sediment  management:
permits  for  disposal of  dredged  material,  and National  Pollutant  Discharge  Elimination
System (NPDES) permits for protection of surface water quality.

     The  Corps  is  responsible  for  navigation dredging  permits  under  the  CWA  and
MPRSA.   CWA authority  applies  to  dredged material disposal  in inland  waters,  including
estuaries.   MPRSA  authority applies  to disposal  in the ocean.   Permits are  issued  on a
case-by-case basis.   Decision-making depends on sediment toxicity,  the physical composition
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of  the  material,  and  available  disposal  options.   Nationally,  EPA  and  the Corps have
historically  interpreted  laws to  mean  disposal  can occur  if  environmental  conditions  are
not further degraded by  the action.   A  contaminated site  does not  require  improvement,
only maintenance of the status quo.  Material deemed  toxic cannot be disposed of in open
waters  but  must  be  disposed  of  in  a containment area or  secure  upland  disposal area.
Disposal sites for nontoxic  material must  correspond sufficiently in physical characteristics
(e.g.,  grain size)  to the  material  to  be  disposed  that ecological  damage  will not  occur.
The Corps employs a cost/benefit  analysis to determine  when  a permit should  be granted.
For  Corps dredging projects,  projects  are  ranked  according  to their tonnage  of dredged
material.   On non-federal  dredging projects,  the  benefit  to  the  public  must  be assessed
and factored  into the permit decision.

     Several  problem areas  were mentioned in  relation  to  navigation dredge permits. and
differences  among  laws  and the implementation of  those  laws.   EPA  Regions and Corps
Districts  often  use  different   procedures   and  priorities  in  processing  and   reviewing
permit applications.   [That is, EPA  Regions may differ  from  one another and Corps Districts
from  one  another.    Typically,  an EPA  Region  uses  methods  consistent  with  its  Corps
District.]   Workgroup participants felt  there  is a major need to establish more consistency,
and  noted  recent  efforts  to  accomplish  this.    Problems  also occur  when  states enact
more  strict  regulations  or  guidelines  than  their  federal  counterparts.    The   additional
costs  required to maintain  more than  just federal nondegradation standards  will  typically
be  decided by states during negotiations  with  responsible  parties.   The  Corps  expressed
concern  with  continuing  federally  sponsored dredging projects  where  state  laws are too
rigorous  and  dredged   material  testing  costs  too  high.     Greater  consistency   among
regulations (e.g.,  MPRSA Section   103 and  CWA  Section  404) was  also  desired  by  the
workgroup.

     Currently, NPDES permits focus on  water  column impacts  and do not usually consider
sediment  quality.   EPA  Region  10 is in  the   process of  revising its NPDES  permitting
process  to incorporate sediment  quality objectives.   Priority has been given to dischargers
that release  specific  chemicals  of concern.    Region  10  is  incorporating  more effects-
based  measures  (e.g.,  empirically  derived,  toxicity-based  sediment  quality  values,  fish
pathology, and  other  biomonitoring)  into  the permit  process.    Statistically  significant
differences  between  disposal  sites  and  nonurban  reference  environments  removed  from
the  direct  influence  of  contaminant  discharges   (i.e.,  relatively  pristine   environments)
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will be  used  as  part  of  the  process  to  determine  permit  compliance.   Region  10  is
trying to place the burden of demonstrating no-effects on dischargers.

     Puget Sound  agencies are  still  considering  "impact zone permitting" where  higher
levels  of  contamination  would  be  permitted  in   distinct  and concentric  concentration
zones  around   an  outfall.    Management  or  enforcement  actions  are  triggered  when
sediment  contaminant  concentrations  exceed specified  zone  limits.   Problems encountered
with  this  approach  have  included  uncertainty  as  to  who  pays  for  cleanup  activities
involving these sediments (for example, the  discharger  or  a navigation dredging  proponent),
and the lack of monitoring and cleanup technologies.

     Region  10  and  the state  of  Washington are  also  working  in  concert  to  establish
particle-based  standards  for effluents.   Problems encountered  during  this process  include
the establishment of "concern"  limits  and the  linkage of such limits to control/management
measures  in  cases  of single   discharges,   and  in   cases  of  multiple  dischargers.    The
composition  of  chemicals  in  sediments  and  discharged  paniculate  material  provides  a.
means  to trace  pollutants to the responsible discharger.

     One  concern  mentioned   by  workgroup   participants  was  the  issue  of  permits  in
areas  of  multiple dischargers.   The  waste  load allocation  process  is  especially  difficult
to design when  sediments are the  contaminant sink.  In  these  situations, it  is  frequently
difficult  to  identify  the discharges  primarily  responsible for  creating  a problem.   The
Superfund  approach  to  this  problem in some  Regions  has been  the  payment  by each
discharger  for  a  portion  of cleanup/management  costs.   Effluent monitoring  may  also be
used  to   prove  that  individual  dischargers  are  not  responsible  for  impacts  associated
with specific   known  chemicals.   However, in  general it  was agreed  that  better  methods
of  identifying  the "footprints"  of individual dischargers  (by  analyzing  suites  of individual
chemicals)  would  contribute  to  the  ability  to  control  toxic  impacts  through  discharge
permits.    During related  discussion  by Workgroup  II  in  the final  plenary   session,  a
participant from  one of  the state sediment management  programs  noted  that the  ultimate
ability to link  sediment  contamination and discharge  controls  is subject  to  the following
assumptions, limitations, and concerns:

     •     It is  assumed  that sediment criteria eventually can  be related to effluent
           particulate limits (that  is,  the  scientific  understanding  of  transport  and
           fate processes can be adequately developed)
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     •     Notwithstanding  effluent   limits,  the  best  source  control   available  at
           present  will  probably  continue  to  result  in deposition  of  contaminated
           sediments

     •     Given  continued deposition of  contaminated material,  a dilution  zone  or
           bottom  impact  zone for  sediments  near  discharges  might  be  needed  to
           address sediment quality in permits

     •     Given  the possibility  that  impact zones  may be defined, some  form  of
           "closure plan" to be implemented  when  a discharge ceases (e.g.,  analogous
           to  RCRA  closure  plans  for contaminated  facilities) might be  needed  as
           part  of sediment maintenance;  a difficulty arises  in  applying  such a  plan
           in  multiuser  environments  (the alternative  is to  phase liability  or phase
           cleanup such  that discharges can be continued at a determined price)

     •     Dredging  in  port  maintenance  areas  has  the  important  associated  issue
           of  whether the  port  has  to  pay the  increased  cost of,  for  example, a
           municipal  storm   water   discharge   that   is  permitted;  procedures   for
           recovering these costs may be needed  to resolve this concern.

     In  addition  to  concerns about  multiple  dischargers,  Workgroup  I  also noted that
assessments by  the  EPA  Office  of  Toxic  Substances (and  others) sometimes  do  not
address the potential for  sediment contamination  posed by new chemicals.
     Disposal Site Selection--The  New York  District  of the  Corps, which  is a cooperative
agency  with  Region  2,  is using  a geographic  information  system  (GIS)  in  conjunction
with a  modified zone  of siting feasibility  (ZSF) approach  to select contaminated  sediment
disposal sites.  The following factors are used to evaluate sites:

     •     Site   physical   descriptions   (e.g.,   bathymetry,   topography,    prevailing
           currents and channels, temperature and chemical regime)

     •     Location of  biota  (both pelagic and  benthic)  relative to  proposed dump
           site
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     •     Economic cost and impact on port activities

     •     Site  surveys  for  potentially  impacted   human  activities  (e.g.,  mining,
           fishing, archaeologic sites)

     •     Sediment contaminants present

     •     Legal requirements (Section  404 of the CWA and Section  103 of the MPRSA)

     •     International treaties (in open ocean disposal).

     Some  states  have  questioned   whether  contaminated  dredged   material  should  be
considered hazardous  and be handled  under  the  provisions of  RCRA.   The Corps concurs
that  dredged  material should  be  handled  according  to  case-by-case  decisions  made  at
the  state  level.    States  require  toxicity  testing   because  they  have  jurisdiction  over.
upland  disposal, but  there  is  no  agreemer.:  at  the  federal level  that  RCRA should  be
involved.   Some  participants  felt  that  it is  not technically justifiable  and  cost-effective
to always  take  all  steps required  under  RCRA  (e.g, why  put a  landfill  liner in a  non-
permeable sediment disposal site?).
     Post-Disposal  Monitoring—Workshop  participants  agreed that  post-disposal monitoring
is  important  in  determining  the  effect  of disposal and  discharge activities.   The  Corps
noted  that  the majority  of disposal  sites where problems  arise  are those  that  have  not
been  monitored.   Monitoring is  expensive,  and cost  is  clearly   the  reason  that optimal
amounts of monitoring are not conducted.

     Decisions  whether  to  monitor after disposal  in  open  water  depend  on  costs,  the
dispersive  nature of the  site,  water  depth,  and  type of  contamination  present  in  the
sediments.   In  making  monitoring decisions,  EPA Region  1 also  evaluates the number  of
facilities  discharging to  an  area,  the  size  of  the  receiving  body,  and  flushing   rates.
Screening  Level  Concentrations,   which  are  effects-based,  chemical-specific  thresholds
developed from historical data sets by  EPA headquarters, are used  as screening for concern
levels.   As  a  regulatory tool, CWA  Section  308  letters have also  been sent to dischargers

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when there are many dischargers  or when flushing  rates are too low  (Section 308  governs
inspections, monitoring, and entry at  permitted facilities and dischargers).

     The type and frequency of  monitoring depend on various management and technical
factors:

     •     Disposal management technique (e.g, capping)
     •     Management mission
     •     The contaminant of concern (e.g., PCBs)
     •     Biota present
     •     Physical characteristics of  the site
     •     Expected rate of contaminant change or site degradation
     •     Potential for human impacts
     •     Costs.

Monitoring  benthic infauna, although  desirable  at  almost  every site,  is difficult  because
of  the  associated  high  cost.    Tiered monitoring  programs can  be  used,  however,  to
incorporate  benthic monitoring when other  less costly analyses  indicate  that the additional
analyses  and  costs  are justified.    Regional Superfund programs  are  interested in  using
bioassay  methods  as  the  second  tier  of  a tiered  approach.   Many  workgroup members
expressed  a desire for  the development  of  general  guidance  on  the types  of  testing
possible  and  protocols  for   tests, including  benthic  and  bioassay  analyses.    Participants
concluded,  however,  that such  guidance  should  not  limit  available management  options.
Resource managers  want to be told what they  can use and not what they must use.

     Funding  for  monitoring comes  from  various  sources.   Initial costs  may  be borne
by  the  project  proponent   and/or   federal  or  state agencies.    States  often  choose  to
continue monitoring programs after  federal  cutoff of funds.  The Corps may incorporate
monitoring costs as  part of its cost-benefit analysis.
     Enforcement--Most  enforcement  of  dredging  permits  is  triggered  by  inspections
conducted  by  the  Corps,  U.S.  Coast  Guard,  or  EPA.    Enforcement  actions  may  be
caused by  three types of violation:   disposal of nonpermitted material, disposal of permitted
material  in the wrong  locations,  and disposal without  a  permit.    Enforcement may also
be  triggered  by  reports  from  the  public  or   environmental groups.    In  establishing
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priorities  for enforcement actions,  the Corps  considers  the volume of  the material and
level  of contamination, if any.   Decisions regarding court  action are generally dependent
on the willingness of the dredger to comply with permit requirements.

      Under  NPDES permits  for  discharges  to  Puget Sound, sediment  contaminant  levels
trigger  intensive  inspection in areas of potential  discharges.  Sometimes permit  violations
are identified  during these inspections.  Although monetary penalties can  be assessed  for
these  violations,  they  are  used only  as  a last  resort.   Most frequently,  a special  action
team  of enforcement and  compliance  personnel from EPA  and  Washington state  agencies
advises  the discharger in an effort to  bring the discharge into permit compliance.
     Cleanup--Remedial  actions  may  include  dredging,  capping,  ceasing  discharge or
disposal  and allowing natural  recovery (no  sediment  action), and onsite chemical treatment.
Priorities for cleanup actions can  be  established  in  a  variety  of  ways.    The  federal
HRS, for example,  is used  by the Superfund program  to  establish priorities  for  placing
sites on  the  NPL.    Studies  to  determine  the  precise  extent  of the  problem  and to
develop  cleanup  options  are  then  conducted  under  a  remedial  action/feasibility  study
for each site.   Each  state  may  nominate  one site  to the  NPL  without reference to  the
HRS (e.g.,  the  New Bedford  Superfund site was a  state nomination that  did  not  score
sufficiently  high  on  HRS).    The  HRS system  currently  used  is  heavily  influenced by
potential  adverse  human  health  effects  (e.g.,   through  drinking   water  or  food chain
contamination).    The  system  is  currently   under  revision  and  will  ultimately  weigh
ecological effects more  heavily than in the past.

     High levels of contaminants  in  fish or  groundwater aquifers have also triggered  cleanup
programs.   In the  Hudson River, for  example, high levels of PCBs in fish  and  sediments
caused concern  that led  to  further  actions.   High  levels of volatile organic compounds
in groundwater  adjacent  to  one  Commencement  Bay site,  followed by additional  studies
in  the   waterway,   triggered  a decision to  recommend  cleanup  in  conjunction  with a
groundwater pump and treat plan.

     Routine  monitoring may  indicate  that cleanup  actions are appropriate.   For example,
the  wastewater   treatment  plant  operated  by the  Municipality  of  Metropolitan  Seattle
(Metro)  in  Puget  Sound  is  required  to   monitor  effluents  of  selected combined sewer
overflows as  part  of  the  NPDES  permit.    In   general, the  municipality would  pay  for
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monitoring, and when  a problem  is  found,  would  pay for  capping of  sediments.   This
program  is  a  continuation  of periodic  monitoring conducted on  a  voluntary  basis  by
Metro  in  the  past.    At  one  major  combined  sewer overflow  (CSO)  location,  Metro
initiated  a plan  for  capping  sediments  to  mitigate   contamination resulting  from  past
discharges and to discriminate effects of ongoing discharges.

      Cleanup may  also be  an objective  of  a  special  study or  local program.    In  the
Puget  Sound  Estuary  Program (PSEP),  sediment  cleanup,  either through  source  control
and  natural  recovery  or  direct remedial  action,  is  one  of  the program  objectives  for
individual urban bay toxics  action plans.  Storm  drain  cleanup efforts have been  initiated
because  of high  levels of  contaminants  of  concern  in sediments next  to storm  drain
discharges.   Funding  is  provided  in  part  by  the CWA.    This  assistance, coupled with
general public  interest and  state  and  local  government participation,  has  proved  to  be
key in implementation of the  Puget Sound program.

      Legal mandates and funding  set aside  specifically for  sediment management  have
also  triggered  cleanups.   CWA Section  115  set aside   money and  provided the  authority
to perform  hot spot  cleanup  demonstrations.   Under  the  Rivers  and  Harbors  Act  of
1970,  the Corps  also  built confined  disposal  facilities in the  Great Lakes  as  10-year
demonstration  projects.    The initial  $8-15  million   for  this  demonstration  was  used
quickly, but  the  legal  authority for  cleanup still  exists under  CWA  Section  115.   This
authority  may provide justification for future cleanup operations.

      The  priority  for cleanup  actions  may also  be  influenced  by  the  availability  of
disposal  sites.   If  suitable  sites  are  not  available,   then  alternatives  to removal  will
have  a high priority.   A  separate  issue  for prioritizing  cleanup actions involves  economic
feasibility, which  the  workgroup  identified  as  an  important  issue to consider  early in
the analysis  of a site.   Currently  under  Superfund, risk assessment and  risk management
are  separate  exercises.     Sites  are   identified  for  the   NPL  without   cost  estimates.
Remedial  measures,  alternatives, and  associated costs   are  then  identified.   Cost/benefit
analysis  is  performed last.   There  was  concern  by  some  participants  that the  cost  of
funding projects may jeopardize Superfund  itself. Some  people recommended that Superfund
not  pay  for  cleanup  until enforcement  efforts  have  been  exhausted.    However,  this
concern was beyond the scope of the workgroup and  was  not discussed in depth.
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How Clean is Clean?

     What  factors  should  be  considered  when  setting  priorities  and  determining
     "how clean is clean"?

     A  fundamental  question in  the  management  of sediments  is  what constitutes  an
acceptable level  of  contamination, i.e., how clean should  sediments be?   In  the  case of
navigational  dredging,  effects-based  measures  of sediment  contamination  (e.g.,  bioassays)
are required under  the CWA.  At  state request in two states,  the Corps uses an  extraction
procedure  toxicity  test  to compare  contamination  to  various  standards  for  land  disposal
evaluations under RCRA.  Under ocean dumping regulations, bioassays and bioaccumulation
testing are needed if there is reason  to believe sediments may be contaminated.

     The workgroup  expressed  concern  as  to  whether  current  dredged  material bioassays
from  the EPA/Corps "implementation manual" for  ocean  disposal  are  protective  enough.
The  sensitivity  of some  of  the  bioassays selected  from the list of  permissable  tests  may
be insufficient.   It was  noted  that  the  methods are  currently  under revision to address
this concern.

     It  was  observed   that  current  state-of-the-art   detection  levels  may  be  driving
concern  levels for certain chemicals,  since  no other criteria exist.   Scientific  justification
rather  than  instrument   limitations should drive concern levels.   In  some  cases routine
detection levels  of  chemicals are higher than  the actual  concern  levels;  concentrations
at which some  substances become dangerous  can be  well  below current  routine  detection
limits.

     Many  chemical data  are currently collected but are not used  in  regulatory  decisions
because  no  criteria  exist to  evaluate them.   Some  participants  noted  that data collection
by  itself is  perceived by the  public as indicating  that  some  beneficial  action  is  being
taken.    The  workgroup  agreed  that  this is not an appropriate way to  show the  public
that agencies are actively  working to correct environmental problems.

     Workshop  participants agreed that information  on  sediment chemistry is an important
factor  in setting remedial  action  cleanup  levels.    It  was  noted that  documentation  of
human  and  ecological   impacts  or  risks  is  also  important  before  cleanup  options  are
considered.    Advantages  associated with  the  use of  sediment  chemistry  data  include the
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utility of  these  numbers  in  setting  target  cleanup  values  and  the wide availability of
chemistry  data  from  studies  defining  the areal extent of  contaminated  areas.   Sediment
chemistry  can also be  used  to  link  the presence  of toxic chemicals  with their sources.
In addition, the use of chemical  data has  historically been legally defensible.  Disadvantages
of chemical  criteria  for  cleanup include  uncertainties in  the  science  underlying  criteria
development  (i.e.,  prediction of  biological effects).   Another disadvantage  is that chemical
criteria  developed  specifically   for   individual  chemicals  do  not   consider   mixtures.
Further,  no criteria exist for some chemicals, and other chemicals  may be unmeasured.

      There was no  clear  consensus  as  to  the  most  effective  way  to  collect chemical
data   (i.e.,  analyze  samples  for  only specific chemicals of  concern,  or  by "wide sweeps"
to look  for  all  chemicals present,  for example priority  pollutant scans  or even broader
scans).   The  Puget Sound  program  in Region 10  measures concentrations of at  least 61
chemicals  of  concern  that  have  been  historically  associated  with  sediment  toxicity,
bioaccumulation, human   health  effects,  or  degradation products.   The  EPA  Office  of
Water is  also  developing  sediment  qua'itv  criteria  that  are  based  on  existing  water
quality  criteria,  and   that  include   a  correction  factor  for  modifying  factors such  as
sediment organic content.   Such sediment quality criteria can be  used  to  trigger  management
action once   criteria  are  exceeded.   It  was  noted  that  EPA/ORD  is  evaluating  the
additional  question of  whether   such  standards  might  be  applicable  to  organisms  that
ingest sediments.    There was   also concern expressed  during  the  final  plenary  session
that  guidelines for  remedial action  or  dredging  be disseminated in  such  a way  that they
do not automatically become ARARs  that constrain options at CERCLA/SARA sites.

      The  workgroup  participants  recommended  that  chemical  measures  be  used  for
comparing  and prioritizing sites,  but that for  cleanup determinations, effects-based measures
should also be  included.   It  was suggested  that "triad" approaches  incorporating sediment
chemistry,  bioassays,   and  in situ   biological   measurements  (e.g.,   fish  disease,  benthic
community measures,   bioaccumulation,  and  other  observations) (see Long and  Chapman
198S)  were  useful  in  evaluating  the  extent  of  contamination  or  degree  of  cleanup
required.   Analyses  of  ben'hic  infauna  were  recommended when  adequate  funding  was
available,  but  it   was also noted  that  observed effects  could be  due  to factors other
than toxic sediments (hence the need  for appropriate reference conditions).

      The  precise  determination  of  "how clean  is clean" should in part be determined  by
the  target  and goals  of  individual projects.    The  use  of  tiered  testing strategies  was

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recommended by  the  workgroup as a  desirable way to approach  this  determination.   The
first tier  would be individual chemical criteria, and the second tier would be a  relatively
simple biological measure(s) such as a  bioassay and/or a measure of food chain contamina-
tion.   The second tier is not always needed if chemical criteria are exceeded, but  it  may
be  necessary if  no  chemical  criteria are  exceeded  to  adequately   protect  against  the
potential  effects   of  chemical  mixtures  or  unmeasured  chemicals.     There  was some
discussion  of the   possible  use of  a  third  tier of  more complex  ecological measures such
as fish disease  incidence  or community  structure, which some  workgroup  members  felt
would  be  appropriate for  large   projects   with  adequate  funding.    The value  of  such
measures  is  that  they provide  a  true  demonstration  of in situ  impact  and may  identify
subtle but important ecological effects.

     There was  also  some support (but  no agreement) among workshop  participants  for
lowering  the  significance  level  for  statistical  tests  from 95  percent to 80-85  percent.
Such  a shift  would be  environmentally protective  but would also increase the  probability
for false  positive  tests.    This  shift  may  be  appropriate for  screening-level  analyses in
which the quantity of data does not  support a more rigorous  level of analysis.

     Threats  to beneficial uses  of a site may influence demand  for  cleanup or  the level
of cleanup.  Examples  of such threats include:

     •     Loss  of fishery  or other living resource (e.g.,  New Bedford, Massachusetts;
           Hudson River  and its  estuary, New York/New Jersey)

     •     Loss of swimming (e.g., Puget Sound, Washington; Union  Lake, New Jersey)

     •     Loss of commercial development potential (e.g., Elizabeth  River,  Virginia).

The  loss   of  development  potential  in  the  third  case  includes   1)   decline  in  property
values as  a  function  of  proximity  to  the site,  and  2) exclusion of  certain  industries
(e.g., marinas) if dredging is not allowed.

     A number  of  technical questions  were  apparent in this session  on "how clean  is
clean."  These questions were summarized as follows:

      1.    What  is the  availability  of  nonchemical  (e.g.,  biological)  test methods?
           Several  participants  requested  guidance  on   this  subject.    There   was

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           disagreement  as  to  whether  the   database  is  sufficiently  developed  to
           support nonchemistry-based analysis.  A database of bioassay and bioaccumu-
           lation  results  for many chemical  constituents is needed.   There  is  also a
           need   to  define  the  role  of  biological  testing  in   verifying  sediment
           chemistry predictions of biological effects.

     2.    How  should appropriate reference  sites  be  selected to ensure  meaningful
           comparison?  Where can comparison data be  found?

     3.    What  other measures  of  ecological  risk (besides bioassay/bioaccumulation
           results) should   be  used  or  developed,  and  what  are  the  uncertainties
           associated with these other measures?

     4.    How  should chemical  data be  collected  to  be efficient  but  still  ensure
           measurement of all detrimental chemicals or  degradation products?

     5.    For Superfund  sites,  are chemical data alone  sufficient  to  establish the
           responsibility  of sources or to further require  cleanup?   Should biological
           effects  information be used  to  prove harm?    It  was observed  by  one
           region that only 1 of 60 sites  (not all Superfund)  had  enough data on
           ecological  impacts to  facilitate  cleanup requirements,  although  chemical
           monitoring data were abundant for almost all of the sites.

     6.    What   statistical  confidence  level  should  be   used  for  tests  in  various
           applications?   Currently,  a  95 percent confidence level is typically  used,
           but use  of a   lower   (e.g.,  80-85  percent)  confidence  level  for   some
           purposes was discussed.
Comparison of Sites and Problems

     To what  extent can  different sites  or problems be  compared?   What  unique site
     priorities might be given special case-by-case consideration?

     The  site-specific nature  of sediment  contamination complicates attempts  to perform
cross-site  comparisons or  to rank  the  severity of  contamination  at  a number of  sites.
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Although  some  approaches are  appropriate  to  perform  these comparisons,  tiered methods
were recommended when making comparisons for regulatory purposes.

     The  group  was at issue with  the  utility  and appropriateness  of a national sediment
standard against  which all sites could be  evaluated.   While consistency  and comparability
are desirable  outcomes  of such  a  standard, sediment  contamination is  often a localized
problem that requires flexible  regulatory criteria.
Communication Channels

     What communication  channels are  necessary among  and  within  agencies  setting
     priorities?  Also, how can regional/headquarters communications be facilitated?

     Workgroup  members  stated  that  efforts  should  be  made to  -reduce  jurisdictional
friction  among  regulatory agencies.    Key  federal  and  state  agencies,  along with  the
public,  should  be  included  early in  the  problem  scoping  and decision process  for  a
given  site  to  ensure  that   all  interested  parties  have  an  opportunity  to  communicate
their needs, responsibilities,  and abilities  to  contribute to  the  project.   Steering  committees
may be  necessary  for  federal and state  agencies to  oversee  the management  of projects.
These  oversight groups  could also look at  problems  on  a  regional basis  and  ensure that
environmental standards are  being met.   New York has  such  an organization, which may
form  a model  for other states.   The  organization includes  the  Corps, NOAA, EPA, FWS,
and the states of New York and New Jersey.  A 500-member  Public Involvement Coordination
Group  also provides  input  for  the   decision-making  process.    Region  3 has  formed  a
bioassessment  workgroup  to review  sediment   management   work   plans,  evaluate  data
collection  needs,   and   recommend  appropriate   ecological  concerns.     Members  of  this
group  include  representatives from  NOAA, the FWS,  and  EPA wetlands  and  technical
support  offices.    Also,  a  national  sediment  oversight  group has been  created  with
representatives   from the  EPA  Office  of  Water,  Superfund,  various  EPA  regions, and
EPA/ORD and laboratories (e.g., Duluth, Narragansett, and  Newport).

     Concern was  also expressed that  more coordination in both  research and implementation
phases  of projects  is needed.   Because  agencies have different missions, this integration
may be  the only way that  necessary  research  is ultimately  accomplished  given  limited
resources.    It  was encouraged,  for  example,  that  the  cooperative  research  between
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EPA/ORD and the Corps Waterways  Experiment Station  (WES) continue,  with an emphasis
on toxic sediment contamination issues.
Information Needs

     To  facilitate   understanding  of  contaminated  sediment  issues,  many  members  of
Workgroup I requested additional information on the following topics:

     •     List  of  official  contacts,  groups,  and  individuals  involved in  sediment
           management  (e.g.,  specific  program  offices  at EPA,  specific  responsi-
           bility  offices at  other  state  and  federal  agencies,  lists  of  other  agencies
           associated with sediment management)

     •     Guidance  on  types  of  testing  possible  and  on  developing  consistent
           protocols (so tests are comparable among investigators)

     •     Available information in Superfund programs  relevant to optional  bioassay
           methods  (i.e., for  use  in a second  tier  of  testing;  participants desired
           information on what can be used rather than what must be used).
WORKGROUP II - SELECTING THE BEST MANAGEMENT ALTERNATIVE(S)

     After  establishing  management priorities  for different  sites,  a range of alternatives
must  still   be  considered  for  addressing   contaminant  problems  at  a   particular  site.
Participants  in Workgroup II focused on  methods to select the best  management alternative,
after making the following assumptions at  the start of the session:

     •    The workgroup is selecting the  best  management  alternative  for sediment
          that  is  contaminated  and  has  been  identified for  priority action  (i.e.,
          fixing a known problem)

     •    A  cleanup goal has  been  established and  accepted (i.e.,  "how clean  is
          clean" has  been decided)
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      •    For  discussion  of  navigation  management  objectives,  the sediment  will
           be dredged (i.e., the focus is on disposal issues).

      Workgroup discussion was organized  in  response  to  the general  questions  outlined
in the  following sections,  which summarize the  workgroup's conclusions  and  recommenda-
tions.    For  each  question,   the  workgroup  addressed  useful  approaches  in   the  case
studies (Appendix  B),  recommendations,  needs, or additional work to answer the question.
In  addition,  it  was   recognized  that the  response  to each   question  may  differentiate
between navigation and cleanup  management  objectives.   The proceedings  are  organized
according to the differing responses (when applicable) for these two objectives.


Regulatory and Cross-Program Constraints

      What  regulations   and  cross-program  constraints  should   be factored  into  the
      selection of management alternatives?

      The  workgroup  found   little  distinction  between navigation  and  cleanup  issues
relevant to regulatory  and cross-program constraints.   In  particular,  it  was  noted  that
a "contagious"  liability exists  for  materials  that  are  designated under SARA  or  CERCLA
(i.e.,  material  transferred  from Superfund  sites  tends   to  retain  an actual  or  perceived
liability  that  can  implicate  new sites).    This  liability, or  perception   of  liability,  can
impede navigation  projects as  well  as  limit alternatives for  sediment  cleanup.    It  was
concluded  that   there  is  a  need  for a procedure  to  waive  this  liability  to   facilitate
cleanup  and encourage cleanup contribution  from navigation   actions.    Public  education
and   integration  of sediment  contamination   considerations  into NPDES   permits  were
identified as two ways to facilitate the resolution of liability issues.

      Routine  navigation  dredging is  frequently complicated  by  sediment  contamination
issues  because  the Corps (one of  the   major  dredgers)  has  no  specific  authority  for
cleanup  of sediments.    Expenditure  of  maintenance  dredging  funds for  cleanup is  also
limited by the  "federal  standard",  barring  specific congressional  action  (e.g.,  projects
authorized under CWA  Section 115).

      The  coordination  of navigation  dredging  or cleanup  projects  requires  consideration
of  a  wide range  of  laws and regulations.    It was  concluded  that the  relationship of
RCRA, TSCA, CERCLA, SARA,  CWA, and  MPRSA (see Appendix C) merits development

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of  a policy that integrates  waste  management  practices  across all media.   With  specific
regard  to  RCRA, it was noted  that  there  are difficulties  in applying  RCRA  technical
procedures  to  classifying aquatic  sediments.    The  extraction  procedure  (EP)  toxicity
test, which is used  in  the RCRA  program  to  classify solid waste, does  not  characterize
the  true or full  toxicity  potential  of sediments or soils.   The  proposed replacement  of
EP toxicity with  the Toxicity Characteristic  Leaching  Procedure  (TCLP)  is  still  deficient
because  organic  compounds  are  not  considered.    It  was  concluded  that  RCRA  is  not
designed  to  address  large  volumes   of  low-concentration  waste,  which  is  often  the
problem at marine sites.

     The workgroup  noted that the preference to  rely on accepted engineering  practices
is  in conflict with  the  need  expressed  under SARA and  CERCLA to consider innovative
technologies  for  sediment remedial  actions.   Funding  of  demonstration  projects  for new
technologies applicable to  large sediment  volumes is  one mechanism for  providing incentives
to   use   innovative  technologies.   These  technologies   are  often  relevant  to   "permanent
remedies,"  which are  generally  defined  as  those   that permanently  reduce  the  toxicity,
mobility,  or  volume of  contamination.    Draft guidelines  for considering reduction  in
contamination as  an  evaluation  criterion have  been  recently issued by EPA (1988).   The
workgroup  recommended  that permanent remedies   for  sediment remedial action be  better
defined  to  acknowledge  what can and  cannot  be  done with sediments.    For  example,  a
clear definition of  "acceptable  permanence"  is  important  to  distinguish sediment  capping,
CAD, and specialized treatment followed by  aquatic disposal  (unconfined or confined).

     Related  to  this issue and  the earlier  issue of  "contagious  liability",  it was recognized
that potentially  responsible  parties  (PRPs)  may be reluctant   to  remove,  transport, and
dispose  of  contaminated  sediments at a  different site  (even a  more  secure site)  because
of  potential  new  liabilities that  are created.   This  perception  of  added  liability  increases
pressure for  the  selection  of onsite  alternatives,  which  may   not always  be  permanent.
Also, clear  definitions are needed  to  define  or limit the  liability  associated with residues
from treatment  processes  to provide  incentive for selection  of  permanent solutions  in
both the technical and legal sense.

     The general Superfund  policy to  conduct remedial  action  onsite was  considered  an
impractical  constraint for sediment  remedial  actions.   Workgroup  participants  noted that
onsite  solutions  may be  precluded by  navigation,  high  energy  environments, or  public
perceptions.    Also,  given  the   present  constraints  on practical  technology,  selection  of
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permanent remedies  often involves disposal  at a  RCRA facility.   Finally, since cleanup
is  required to meet  substantive regulatory requirements, the workgroup  recommended that
mitigation  policies be considered when selecting management alternatives.
No-Action Alternative

     What  site  conditions  or  other  factors  make  no-action  the  alternative  of
     choice?  How  is "no action" defined?

     Navigation  Issues--Workgroup  recommendations  are  based  on  a  definition  of no-
action  for navigation as meaning no  dredging.   The no-action assessment  should consider
the impacts  of the material if left in  place  compared with  the  benefits if removed, and
the impacts  at the  disposal  environment.   The  net  effects of  these impacts  should  be
considered in deciding among alternatives.

     The  following  key  reasons for  selecting  the  no-action  alternative for  dredging
projects were identified:

     1.    Disposal sites are unavailable

     2.    Superfund liability overshadows navigation benefits

     3.    Solutions cannot be afforded.

In the case of Superfund  liability with respect  to  a  navigation  dredging project,  additional
considerations  will be  required  if  cleanup  is  being considered as  part  of  a sediment
remedial action assessment.  These  requirements are discussed in the  following section.
      Cleanup  Issues--The   following  two   levels  of   no-action  were  identified  by  the
workgroup as applicable to remedial actions associated with sediment cleanup:

      1.    No action  with  respect  to  either  source   control  or sediment  remedial
           action,  including  any institutional controls (i.e.,  no  action  as  generally
           defined by NEPA)
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      2.    No  action  with  respect  to  sediment   remedial  action,  including  any
           institutional controls  regarding  direct  exposure  to  sediments or  to other
           media   contaminated   by  association  with   sediments  (although  source
           control activities may occur).

The workgroup recommended that these alternative definitions  of  no-action  be standardized
and  used  in  Superfund  programs  to  avoid confusion  on  how to assess costs of  the no-
action alternative.

      The  no-action  alternative  for sediments was evaluated by  the workgroup relative  to
potential  short-term  and long-term impacts.    It  was  concluded  that  short-term  impacts
are generally  manageable relative to long-term in situ  risks  of no action.  This  conclusion
was  reached because in  contaminated  sediment projects  there has been  a consistent pattern
of  initial  concern  regarding dredging  resuspension,  studies  to determine  degree  of resus-
pension,  and   ultimately   acceptance of  dredging  as a  remedial  tool.    However,  short-
term losses of habitat can be critical at some sites and should be considered.

      In  assessing  the merits of  no action, the workgroup identified two major controlling
factors:

      •     What are the effects of contamination if left undisturbed? Are contaminants
           in   a  biologically  active  zone  or are they   isolated?    The  biologically
           active zone  often extends  to  only 10-20  cm in  marine sediments; except
           in   high-energy  nearshore  zone, particulate-bound  contaminants  that  are
           buried  below   this zone can  be considered  effectively  isolated  (although
           not necessarily "permanent" over geologic time).

      •     What  is  the  ability   of  sediments to  naturally  recover as  the  result  of
           sediment  deposition,   source  control,  and  effects  of  biological,  chemical
           and  physical  mixing   in  the  surface  layer  of  sediment?    The   factors
           controlling recovery  time  can  be  modeled   to  estimate  the  potential  for
           reduction  in  sediment  contamination  over   time.   For example,   in  the
           Commencement  Bay Superfund project (Region 10), no sediment  remedial
           action  is  proposed  in  cases  where  sediment  contamination  is  projected
           to   meet  cleanup goals  in  10  years  solely  through  source control and
           natural deposition of cleaner sediment.
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      Natural  resource  damage  assessments (NRDA)  were also considered by the  workgroup
as a  useful  tool  to assess  the  no-action alternative.   Participants preferred  cost-effective
preliminary  NRDA over   complete  assessments  [i.e.,  either  the  standardized  Type  A
procedure  (53  FR  9769)   requiring  minimal  field  observation  or  the  site-specific  and
more complex Type B  procedure (51 FR 27674) codified in 43 CFR Part II and authorized
under CERCLA Section 301(c)].   It  was recommended that  results of preliminary NRDA
be  used  to  provide some  preponderance  of  evidence of ecological  harm  and that the
analysis  indicate  the  number  of  users of  the resource  (or associated  resources).   The
latter factor  is important for  demonstrating relevance for  priority  assignment of  funding.
Limited  ecological  damage  or  low numbers  of users  of  the  resource  were  considered
major reasons  for  preferring  the no-action  alternative.    Some participants  noted  that
ecological  damage  was  often  ignored  relative to  human  health  considerations,  although
there is limited information on the ultimate effect of ecological changes on humans.

      The  ability  to  clearly identify  the  relationship  between ultimate  users and the
directly impacted resource  is the  major  technical  issue  in  using  NRDA.  It  was suggested
that   demonstration  NRDA  at  a  limited  number of sites  would  be  useful  in providing
basic  information that could  be extrapolated to other sites.

      In  addition  to technical  factors,  costs and  institutional constraints  can lead to the
no-action  alternative.   Cost  constraints may  include  a negative  cost/benefit  analysis  in
a dredging project  or high  costs  required  to implement  cleanup goals  based solely on
technical  factors  for remedial  action  projects.   Institutional constraints  may include the
inability to identify appropriate disposal sites.
Sediment Remedial Action Alternatives

      What  site  conditions  or  other  factors  favor selection  of  specific  alternatives
      (e.g.,  "in-place"  containment  or  treatment;  dredging  and  disposal:  dredging,
      treatment, and disposal)?

      Navigation  and  Cleanup  Issues--Issues  unique  to either  navigation or  cleanup  are
discussed in  the  following  sections; however,  there  were  several  issues  identified  that
pertained to  both areas.   In  particular,  it was considered  inefficient  for all  projects  to
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reconsider  every technology.   The  following  guidelines were  summarized by the workgroup
for recognition of appropriate technologies:

      1.    Many dredging/disposal  technologies are worth  considering only  for  smaller
           volumes or when highly mobile contaminants are  present

      2.    In  most  cases, modifications  to  conventionally available  equipment  will
           suffice to conduct  remedial action

      3.    Specialty  dredges  may   be   necessary  as  dictated  by  site  factors (e.g..
           dredging around structures).

      With  respect  to aquatic  confinement  for  navigation or cleanup  projects,  the potential
for episodic  events,  bioturbation, and diffusion of contaminants are the major factors  that
must be recognized in the design of  caps.
     Navigation  Issues--The  two  major alternatives  relevant  to  navigation  projects  are
1) dredging  and disposal,  and 2) dredging,  treatment, and  disposal.   Treatment feasibility
is  primarily  constrained by the volume of material (i.e., only small sediment volumes  may
be  treated).    To  address  water quality issues in  upland  disposal,  treatment  has  often
involved the addition of  flocculants  as a relatively inexpensive process.   Other  techniques
for small  sediment  volumes  include  portable  sand/carbon  filtration  units  (e.g.,  used  to
remove kepone in James  River sediment on  the east  coast and PCBs in Duwamish River
sediment on the west coast) or solidification of homogeneous materials.
      Cleanup Issues--In the absence  of a need  to  perform  maintenance dredging, cleanup
alternatives  for  sediments  may   include  institutional  controls   or   in  situ   containment.
Primary  institutional  controls  include  use  restrictions,  access   restrictions,   monitoring,
and  education  programs.    The  workgroup concluded that such  controls  are  a  necessary
component  to  sediment remedial  action  but are  not  sufficient in  themselves, because
once  implemented  the unresolved  problem  is  often ignored, and  the  controls do not
effectively discourage the already frequent user.
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     In  situ  containment  of  contaminated  sediments  is  an  important  alternative  for
consideration  in  remedial  action  programs  because of  its  relative  simplicity and  lower
cost compared  to  removal,  treatment,  and  disposal  alternatives.    This  alternative  is
inappropriate  for navigation  channels,  and there may also  be a  public  perception  problem
for material that is  contained and left at a  site.   In addition, more than  a simple sand
cap is necessary  when  there  is  groundwater  recharge  or  infiltration, mobile  contaminants,
or  a  high-energy environment.    A  relatively impermeable  layer  of  clay  or  alternative
geotextile/geomembrane  (e.g.,  polypropylene  sheeting) may  be required  to  retard  the
mobility  of contaminants.    Thick caps  (e.g.,  >6  feet) or  the  rejection of containment
alternatives  may be required in dispersive environments.
Disposal Alternatives

     How  should  risks  associated  with open-water,  near shore,  and  upland  disposal
     be compared?

     The following  range of  options  were  considered  by  the workgroup  for  disposal  of
contaminated sediments:

     •     Onsite CAD  (i.e.,  by removal  of  the  contaminated  layer,  excavation  of
           underlying  clean  material,   disposal  of  the   contaminated  layer  in  the
           excavated area, and capping with the previously underlying clean material)

     •     Offsite CAD (i.e., at a defined aquatic disposal site)

     •     Nearshore   disposal   (typically  in  diked  areas   in  which  the  disposal
           material is mounded above the water line)

     •     Land  disposal  of  dredged  material  or dredged material  mixed  with other
           materials

     •     Dispersive ocean disposal (subject to international concerns).
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     The workgroup recommended that  dispersive ocean disposal, although often discounted,
be  considered  as  an  alternative.    Key  factors  include  advantages  of  reduced  human
health   exposure  and  reduced  concentrations  through dispersion,  and  disadvantages  of
uncertain  accountability  and  public  perception.   The  official  U.S.  position in  ocean
disposal  is  to  accept  only  total  containment  of  contaminants,   which  discourages   the
alternative.   A  general issue raised  during the  final plenary session  was  whether beneficial
uses of  the  assimilative  capacity  of   the  environment (e.g.,  ocean  disposal) should  be
considered when  adverse  effects  are  not  produced.   The  resolution  of  this  issue  would
require a  public  education program because  of  the  strong  public  perception  against  the
concept.    A  second concern  is  the lack  of a  good  technique for monitoring effects in
deep ocean vs. nearshore environments, which raises accountability issues.

     Strategies  for  comparing  disposal  alternatives were  considered  by  the  workgroup.
It   was  concluded  that  there  are available  tools  for  quantitatively  comparing  human
health  and  ecological  risks of disposal alternatives.   An example conceptual application
of  comparative  risk analysis  was  presented  (see Pastorok et  al.  1986)  for a comparison
of  1} deepwater, unconfined disposal, 2) nearshore confined disposal, and 3)  upland sanitary
landfill  disposal.    The  workgroup  was  divided  as  to  whether  there   was  a sufficient
technical  basis  for  quantifying these  estimates  at  this  time.   Quantitative  estimates  are
complicated  by  the substantial  information  and  uncertainties  in  comparing  different
environments.    Several  participants  concluded  that   the  process  of  risk  quantification
can  be  a useful  tool  for  evaluating  assumptions  but  that  the  resulting  numbers  are
often not a good way of expressing these risks to the public at large.
Best Management Alternative

     How should one identify the best management alternative for a site?

     Several approaches  to  selecting the best alternative were  presented to the workgroup
for discussion,  including the  1988 CERCLA  guidance  for  cleanup (EPA  1988)  and the
Dredged Material  Alternative  Selection  Strategy  (DMASS)  developed   by  the  Corps/WES
(Cullinane et al. 1986).  Examples of evaluation criteria used at most CERCLA sites include:

     •     Institutional  compliance  [e.g.,  conformance  to  ARARS,  other   criteria,
           advisories,   guidance;  Note:    guidance  on  ARARs  has  recently  been

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           released  by  the  Office  of  Solid Waste and Emergency  Response  (EPA
           1988; CERCLA  Compliance with Other Laws)].

     •     Reduction   in   contamination  (e.g.,  reduction   in   toxicity,  mobility,  or
           volume of contaminants)

     •     Protectiveness  (e.g.,  public  health/safety  and  timeliness  as  measures  of
           short-term effectiveness;  permanence as  a measure  of long-term  effective-
           ness)

     •     Implementability (technical feasibility and availability)

     •     Cost  (e.g.,  design and  specifications,  capital  construction, operations  and
           maintenance, monitoring).

In addition,  under the  National Contingency  Plan (NCP), the  evaluation  of  aJternatives-
for CERCLA sites is usually conducted in two phases:

     •     Phase  I  -  an  initial  screening  of alternatives  by  consideration  of  cost
           (order-of-magnitude  only),  effects  of  alternatives  (i.e.,  a  consideration
           of the effective protection of public health,  welfare, or  the  environment),
           and  acceptability  of engineering practices  (i.e.,  feasibility,  applicability,
           and reliability).

     •     Phase  II  - a  detailed  analysis  of  alternatives  (with  preference given to
           established  technologies),  including  detailed  cost estimation, consideration
           of  engineering   requirements,  implementability,   and constructability,  and
           an  evaluation of the extent  of  protection  afforded, adverse impacts,  and
           costs of mitigation.

     Under  the  NCP,  the  selected  alternative  should  be  "the   lowest  cost  alternative
that  is  technologically feasible  and reliable  and which effectively  mitigates and minimizes
damage to and provides adequate protection of public health, welfare, or the environment."


     Navigation and  Cleanup  Issues--No  particular distinction  was  made for  navigation
and  cleanup issues,  but  based  on  the review  of available  approaches,  several  "needs"

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were  identified.   Participants  concluded  that  details  of the  assessment  procedure  need
to be  documented to substantiate  project  findings.   A need was  also  identified for  some
"standard"  for  decision-making,  although  going  through  the  selection  procedure   itself
was  considered  to be of  value  even without  a  clear  standard  for  making a final decision.
Finally,  participants  expressed  the  need  for  a  common  mode of presentation  of results,
because the decision documents may serve as a basis for subsequent legal actions.

     To  be  effective,  the  decision  guidance   for   selecting  the  best alternative  should
clearly define when, where,  and  how  costs should be considered.   For example, following
problem  definition and an assessment  of intangible  factors that may be  important, it was
recommended  that   a   preliminary   analysis  be  conducted  to  estimate   if  the  probable
remedial costs  were  excessive.   This  analysis would not  consider the  financial  ability of
PRPs or  a detailed  cost-benefit  analysis but could   be  used to assess  relative  impacts of
alternatives (CERCLA  guidance calls  for  a  preliminary  order-of-magnitude  consideration
of costs  when  screening alternatives).   It  was  noted that EPA  had a responsibility to
advocate cleanup but that  this responsibility had to be balanced against overregulation.

     Timing  issues were  also  raised with  respect to sediment  remedial action.   Complete
(100  percent)   source  control  is  unlikely  to be feasible.   Natural   recovery  times  and
kinetics  of contaminant  dispersion  are also  uncertain  or unknown.   Therefore,  initiation
of  sediment  remedial  action   may  be  desirable or necessary  before  source  control  is
fully implemented.  As  part of the final solution,  it may be appropriate  to consider sediment
maintenance   as  an   extension  of   the   source   treatment  process  (i.e.,  combine  partial
source control and intermittent dredging as the  best alternative).

     To   improve  the   ability  to  select  among  alternatives,   the   workgroup   strongly
recommended  near-term  demonstration  projects  on  the  most  contaminated  material  that
is now known.   The  results of  these projects  are  needed  to  prove that remedial  actions
are  feasible,  to  accelerate  cleanup  projects, and to  enhance  public relations.    During
the  final  plenary session,  it  was  also  noted  that  there  is  a  need  to involve  special
interest  groups  in  the  demonstration  projects  so that  public  education  efforts are
enhanced.    Early  involvement  by  agencies  and special interest groups  is  desirable so
that there  is a clear understanding of  the project context when  results become available.

      For  the  actual  selection process,  the  workgroup  was  divided  as  to  whether the
evaluation matrix should be  solely  narrative  or  quantitative  with supporting narrative.
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If factors  are quantified,  the  workgroup  recommended  that numbers  in  the  evaluation
matrix  of  alternatives  be  expressed  as  relative  indices  rather  than as  absolute  criteria.
As  appropriate, some  form of sensitivity analysis should  be conducted  to enable reporting
of quantitative results as a range (e.g., costs).
     Recommended  Alternative--The  best management alternative  should  consider combina-
tions  of  institutional  controls,  source  controls, navigation dredging  where possible,  and
where  necessary,  sediment  remedial  action.    A  policy is needed  that  integrates  waste
management  practices and requirements  in  all  environments  to  resolve inconsistencies in
standards  and  practices  across programs  and  to enable  consistent application  of  technical
principles.

     A  suggestion  was   made  to consider  different  classes  of  sediment  quality  (i.e.,
different  standards  for  different  areas  or  uses) in  assessing  alternatives.   No consensus
was  formed,   but  a  simple  two-class  system  for  relatively  uncontaminated areas  and-
more  heavily  contaminated  areas  might oe  necessary  to form  guidelines for  what is the
best alternative for remedial action.

     The  workgroup  concluded  that the  alternatives  evaluation  is  not  a "bottom  line"
solution  to  be followed  blindly, but rather a process  for  identifying the  implications of
key assumptions  and  developing an  informed decision.   Related to  this decision  process,
there  is  a need within the  cleanup program  for improved  information  transfer procedures
and possibly coordination requirements.  Expert systems may  be an appropriate  tool for
this field.
WORKGROUP ID - IMPLEMENTING THE SELECTED ALTERNATIVE(S)

     The  final  phase  of  the  overall  management   process  for  contaminated  sediments
involves  implementation  of  the selected  remedial alternative(s).   Participants  in Work-
group III addressed  several  questions that  are  outlined  in the following  sections.    The
workgroup  focused  primarily  on  procedures  or  approaches  that  could  streamline   the
implementation  process,  resulting  in  more  efficient  and  timely remediation  of sediment
contamination  problems.    Recommendations  are  limited  by  the  fact  that  few  toxic
sediment projects have actually reached the  point of implementation.
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Constraints to Implementation

     What  major  legislative or  regulatory  constraints  are  being  encountered during
     implementation of alternatives?

     Several  factors  were  identified   by  the  workgroup   that  constrain   or   have  the
potential to constrain the implementation of remedial alternatives.
     Changing  Rules and Regulations--One  of the  most important  factors  involves  the
potential  for  regulatory  change  to  occur  during the  implementation process.   Examples
of projects  where  such  regulatory change has impeded the implementation process  include
the  upper  Hudson  River PCB  cleanup  and  the  Everett  Harbor  dredging  project  (see
Appendix B).   An  additional  example  discussed during  the final plenary session  related
to potential  >1 part per  trillion dioxin standards  for RCRA land disposal, which could force
problems  with disposal of dredged material.   Dialogue between agencies was  recommended
to ensure defensible  cleanup (i.e.,  regulations  within one agency should  be  coordinated
with overlapping regulations in another).

     In   cases  where  regulatory   change  has  constrained   implementation,  the   major
contributory  factor  seems to  be  the  excessive  time required  for  the   assessment  and
identification  of remedial  alternatives.   During  these periods  of up to  several years, it
must  be  expected  that  the  regulatory  environment  will  change.    In  other  cases,  the
program may  be   constrained by the  incompatible  changes  in  various  federal regulatory
programs  (e.g.,  RCRA and CERCLA/SARA) or federal and state programs.   Regardless  of
the source  of the  regulatory change, it  is  apparent  that  such changes  will  occur  during
any  normal  period of implementation.   Therefore,  the solution  to this  problem  involves
a  recognition  that such  changes  will  occur  in  addition to  the following  strategy  for
adapting to  change:

     1.   Keep the  project moving  as  rapidly  as  possible.    By  shortening the
          overall  assessment and  implementation  process,  the  potential  for  major
          legislative or regulatory changes affecting the project is reduced.
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     2.    Maintain flexibility.  It should be recognized that the regulatory environment
           may change.   Therefore,  the  implementation plan  should be  sufficiently
           flexible  to adapt  to  either  anticipated  or  unexpected  changes.    It  is
           important  is  such cases  to maintain  the  basic  logic  of  the  plan  while
           adapting to changing  regulatory circumstances.

     3.    Maintain  information flow on  changes.    An implementation  project will
           be  more adaptable to  regulatory  change  if all involved  parties are  aware
           of  the  anticipated  or existing changes.    Therefore,  it is important  for
           the  primary  regulatory  agency  to  disperse   such  information  to   PRPs,
           cooperating agencies,  contractors,  and the  public  so  that  these  groups
           can also maintain flexibility.
     State and County Rules and Regulations—A problem frequently encountered in sediment
remediation  is   that  the  selected  alternative(s)  is  incompatible  with  state  or  county
rules  and  regulations.   This  situation has  resulted in  a state  or county  objecting to  the
selected  alternative  relatively  late  in  the implementation  process,  resulting  in  wasted
effort, last-minute delays, or frustration of the implementation process.

     This  kind  of regulatory  incompatibility  has  been  a  major problem for  the Corps.
In  many cases,  state  rulings  have  resulted in  loss  of disposal  alternatives  or  additional
required studies.

     A  partial  solution  to   this   problem  is  to  communicate  early  and often  with  all
relevant  state and local government  agencies.    This  communication  should have the goal
of  advising  state and  local  governments on the  project status  and  actions  at  the  initial
planning  stages   and  periodically  during  the   implementation  process.    Such   enhanced
communication  will  enable  each  agency  to understand the  other's  role in  the  process
and their  regulations.   It will also enable  federal  agencies to  anticipate local  or  state
government  interests  by  not  prematurely   dismissing  any  reasonable  alternative,  or  by
early dismissal of alternatives that are clearly in conflict with state or local regulations.

     The  formation  of interagency  workgroups  (IA)  is  one useful mechanism to facilitate
communication  and  cooperation among  agencies during  the  implementation  process.    An
example of  the   successful use of an  IA  is PSDDA in Washington  state.   In  this  case,
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the federal regulatory  agencies  (EPA and Corps), the  state regulatory  agency  (Ecology),
and  the  state  resource  agency  (Department  of  Natural  Resources)   all  cooperated  to
define dredging  and disposal  standards  for  Puget Sound.   There  is a  need to  investigate
the feasibility  of  IA in other areas.

     An   additional  potential  problem  is   inconsistency  between  states   for  projects
crossing  state boundaries.   For example, in  many  cases  there  are inconsistencies among
the states  in policies   regarding  disposal of  dredged  material,  hindering  the  nationally
standardized  approaches.    In  cases  of  potential inconsistencies  among  states,  technical
panels  such  as   bioassessment groups  (BAG)  have been  useful  in  promoting  consistency
and interagency  cooperation.  The  New York/New  Jersey BAG provides an  example of such
cooperation among states.
     Complex  Pollutant Sources  or Unregulated Sources--In  many coastal  urban environ-
ments, sediment  contamination may result  from .numerous  point and  nonpoint sources of
pollution.   These  situations  are  characteristic of  many  of the  major  harbor  areas  on
the  east  and  west  coasts  and  Great  Lakes  (e.g.,  New  York Harbor,  Indiana  Harbor
Canal, Elizabeth River,  Los  Angeles  Harbor, San  Francisco Bay,  Commencement Bay).
Many  of sources of  pollution in  these  areas  are  unknown  or are currently unregulated
(e.g., urban nonpoint sources).   The  problem  is  most  severe at non-NPL  sites  that  have
complex   sediment  contamination  problems  (i.e.,  multiple  contaminants  of  concern  and
multiple  sources).  There is presently no  good regulatory program to enforce thoroughgoing
source control and sediment remediation at such sites.

     Assessment  and  remediation  of  these  situations  requires an  integrated  study  of
contamination  and  pollutant  sources  from  an area-wide  perspective.   Because  of  the
complexity  of  contamination  and  potential  sources,  it  is not  prudent   to   implement
cleanup  at  a  specific  site  without an  evaluation of the interaction  of adjacent  sources
and  the  potential  for  recontamination  of the  site.   This problem is  being  addressed  in
Puget  Sound by the Urban  Bay Action  Teams as  part of PSEP, implemented  under  the
EPA   National  Estuary  Program.    The  application  of such  multiagency  enforcement
groups should be evaluated for other areas.


     Jones  Act  Restriction  on  Foreign  Hulls--The  Jones  Act  restriction  on the  use  of
foreign-hull  vessels  was  identified as  a potential constraint  to the use  of some  modern

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dredging equipment in the U.S.   However, it was concluded  that  this potential constraint
may be overcome by mounting the required equipment on a U.S. vessel.
     Early  Assessment of NRDA Issues--The  possibility of an  NRDA suit  by a  resource
agency  may be  an impediment  to  negotiations  between  a PRP  and  regulatory  agencies.
The potential  problem  arises  from  NRDA  issues not  being  raised  early  enough in  the
assessment and  implementation process,  thereby  leaving  open  the  potential  for a suit  at
a  later  date.   In  this situation,  the  PRP may be  hesitant to settle on  a remedy before
the NRDA issues are resolved.

     The recommended  solution  to  this potential  problem  is  to  have  early  notice  and
involvement  of  the  resource  agencies  in  the process.    This  early  involvement  would
facilitate  the  identification  of any  NRDA  issues  prior  to the  implementation  phases of
the project.   It  would  also facilitate  the development of  a  covenant not to sue  between
the  regulatory  and  resource  agencies.   The  important   objective  is that  the   resource
agencies  should be  on  the  same  time frame as the  regulatory  agencies, and not become
involved only  in  the  later  stages of  the project.   Preliminary  Natural  Resource Surveys
(PNRS),  which are agreements between  EPA and NOAA,  are one  mechanism of  ensuring
timely  involvement of resource agencies.  These interagency agreements,  which are  currently
implemented in EPA Regions 1  and 10, are being negotiated  for other  areas.

     It  may also  be helpful to further  develop the Type  A and Type B NRDA  methods
(see  discussion above  by Workgroup  II under No Action Alternative:  Cleanup  Issues), so
they can  be used  as  an early screening of NRDA  issues.  A  simplified model  is being
developed  for  the Type  A  assessments   to  provide  a  screening  of  potential  natural
resource damages.
Relationships Between Agencies and Potentially Responsible Parties

     Can  relationships   between  agencies  and  potentially  responsible   parties  be
     improved?

     The  consensus  of  the  workgroup  was   that  the  relationships  between  regulatory
agencies  and  PRPs  should be  improved.   The adversary  relationships  that  may  develop
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between  agencies and  PRPs  can be  a  major  impediment to  timely  implementation  of
remedial alternatives.

     To overcome  these   potential  adversary  relationships,  the objective  should  be  to
open  up the  process  and  reduce potential  delays  due to  litigation.   One  solution  is  to
involve  the  PRP early during  the  discussion  of  problems  and remedial  actions.   This
involvement  will  enable the  regulatory  agency  to understand  the PRP's  concerns  with
various alternatives at  an  early  phase of  the project.   In  addition, the  PRP will develop
an  understanding  of  the agency's direction  on the  project.  During this  phase it  is also
important  that  contact with the  PRP  be  developed  in  tandem with  all   cooperating
agencies  so that the PRP is not receiving contradictory signals from the various agencies.
Regulatory Implementation

     What  regulations,  sources  of funding,  and  payment  methods  by  potentially
     responsible parties are most useful in pursuing action?

     The  workgroup  identified CERCLA/SARA and  CWA as  useful  for  remediation of
contaminated  sediments.   CWA Section  115 is potentially useful in implementing  cleanup
actions if funding becomes available for  this program.   The major needs are for coordination
of  enforcement  activities  among  agencies  (state  and  federal) for  source  controls  and
sediment  remediation.  For example, there is  a need  for source control activities  directed
at  urban  nonpoint  sources of pollution  that  contribute  to  sediment  contamination.    It
was noted by the workgroup  that  the  Urban  Bay Toxics Action  Teams in  EPA Region
10  have  made  progress  in this  area.    These  teams  result  from  a  cooperative  effort
between  state  and  federal  personnel  as part  of the  National   Estuary  Program  in  Puget
Sound.
Communication with Local Interests

      What  mechanisms  have been  most effective  in  communication  and  coordination
      with local interests and with the public?

      All  workgroup  members  agreed  that  effective  communication  techniques  are  the
key to maintaining public  involvement  and public support for the remedial project.   The

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adequacy of  communication  with  the  public  and other  local  interests  can  affect  all
other aspects  of the  project.   Effective communication  is  too  important to be  conducted
exclusively  by  the  agency  public  relations staff.   Therefore, it  is  important for  project
personnel  to  be  involved  in  the  planning  and  implementation  of  public  information
activities.   This is  important  for  the  public to  understand  the  issues  and to  develop a
sense that the  agencies are competent to implement the project.

      An  important  requisite to adequate communication  is  to involve  all relevant agencies
early in the  process.    Public  understanding can  be accomplished  only if there  is  agency
cooperation.    Alternatively, the  public  can be  easily  confused  by  a lack  of  agency
cooperation or  by different policies  being advocated  by different  agencies.   As  part  of
this  early involvement,  it is also important to reach the  key decision-makers in  the  public
and   all   affected  agencies.    Academic   personnel  and  technical  personnel  from   other
agencies  should  also be  involved  early.  Subsequent  activities can be effective only if  these
critical individuals are identified and involved in the planning  and  implementation process.

      Risk communication  is an  increasingly  important issue  for  toxic sediment  problems
during the  implementation  process.   Adequate  and clear communication of  risks  is also
one  of  the most  difficult  aspects of public education.   In  discussing  risk  communication,
the workgroup identified three areas that may be overlooked:

      •     When conducting risk communications, all presenters  should  be thoroughly
           briefed and prepared to cover all aspects of the situation.

      •     All  risk  evaluations  should  be  presented   in  light of  associated  costs
           (i.e.,  what are  the  costs  of risk reductions from  various  remedial alter-
           natives?).

      •     Evaluations of  risks  should not be  limited  to  cancer  risks  but should
           also  include  non-cancer and environmental  risks  in the overall assessment
           of  alternatives.

      The  workgroup  identified  one  aspect of  risk communication as  especially difficult
to communicate to  the  public.  This problem  is  associated with  the  differences between
the  FDA  and  EPA  approaches  to   determining  human  health risks  from  contaminated
seafood.   The FDA  approach  is frequently used  for some  chemicals  because it  results  in
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specific  numerical  criteria in the form  of Action Levels or Tolerance Limits.   Alternatively,
the  EPA  method  provides  for  the  calculation  of risk as  a  probability  of cancer  at a
given tissue concentration.

      EPA's Office of Water has  recently produced  a report, Guidance Manual for Assessing
Human  Health  Risks from  Chemically Contaminated Fish  and Shellfish (Pastorok 1988),
describing the  relationships  between  the EPA  and  FDA  risk  assessment methods.    The
document  also  describes  the  steps  of a  recommended approach  for conducting  a health
risk assessment for  fish  and  shellfish, provides guidance  on presentation of results,  and
summarizes uncertainties in the risk assessment methods.

      A  final  area  of communication identified  by the workgroup as needing improvement
involves  cost  balancing.  The  major need in this area is for agencies to  be  open regarding
cost balancing as  an important  part of  the process of evaluating  alternatives.   It  is  also
important  to  describe  the role  of  cost balancing  in  a straightforward  manner  that  can
be understood by the public.  The following items were identified as key issues:

      •     Be  honest  that  Superfund  (or  other  programs)  cannot  clean  up  all
           contaminated sediments

      •     Admit   that  funds  are not  available  for  total cleanup; therefore  it  is
           important to  direct funds  to  problem  areas  with the greatest hazard  to
           the environment or to public health

      •     Clearly  describe   the   cost  balancing  approach  used,  including  a  clear
           description of the decision-making approach and the criteria used.
Implementation Time and Integration of Source Control

     How  long  is  it taking  to implement  the  chosen  alternative(s)?   Has  there
     been adequate consideration of source control and natural recovery processes?

     The consensus  of  the  workgroup  was  that  it  takes  much  too  long  to  implement
remedial alternatives  once they are selected.   The  implementation process  needs to  be
streamlined  to affect  timely  implementation  of  the  selected  alternative.    Many of  the
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impediments  to  timely  implementation  that  result  from  PRP  litigation  or  last-minute
intervention  by local  groups can  be avoided  by the  previously discussed recommendations
on planning, communication, and open  involvement.   A key aspect of timely implementation
is  early  involvement  of  the PRP,  in which the  PRP  participates  in  the  selection  and
design  of remedial  alternatives.    It  was  also  noted by the  workgroup  that  successful
cleanups must  be  conducted and documented for  the  agencies to be perceived  as responsible
by the public and  PRPs.

     There  is also a  critical  need  to have  flexibility  in  the implementation process  to
respond  to  immediate  threats  from  sediment  contamination,   especially  involving  public
health  effects  from contaminated  seafood,  water  supplies,  and  direct  sediment  contact.
In many  cases, a  large, complex  area  of contaminated  sediments may have  localized hot
spots that are highly  contaminated but  spatially restricted  near  a  point source discharge
or spill  site.   If  these areas pose  a more  immediate  threat  to the environment  or to
public  health,  they  should  be put  on  a  more  rapid  implementation schedule than the
overall study area.

     The  solution to  this  situation  is  to maintain  the  flexibility  to implement remedial
actions  in phases  in  separate  operable units.   Given  this flexibility,  rapid responses can
be  directed  toward  restricted,  highly  contaminated  areas.   Identification  of these  areas
should  be accomplished  early  in the  assessment  or  site characterization  phases  of the
project.   Rapid cleanup of such  sites  may then be  facilitated by their small  size  because
of the relatively straightforward evaluation of cleanup options  when compared with very
large areas of contaminated sediments.

     The  workgroup  also  identified  a  critical  need  for  coordination of source  control
and  sediment  remedial actions during the implementation  process.    In  situations  where
ongoing  sources  are contributing  to sediment  contamination,  it is generally  not advisable
to implement  expensive sediment  cleanup alternatives if there is a  possibility  for near-
term recontamination  of  the  sediments.   Therefore,  prior to  implementation  of  sediment
cleanup,   it  is  important  to  characterize  the sediment  contamination as  resulting  from
either  historical or ongoing sources.   If the contamination  results  from  ongoing  sources,
major ongoing  sources should be identified and controlled prior to sediment cleanup.

     Following source  identification,   the  next important  step  is to  evaluate the  effects
of source  control  on  the  future  sediment  contaminant  levels.   These evaluations  include
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assessment  of the  natural  recovery  of  sediments following  partial  or complete source
control.   The workgroup  identified a key need for analytical tools to gauge  the  influence
of  source  controls  on  the  magnitude   and  extent  of  sediment  contamination  and  to
determine  whether  sediment contamination  will recur  if  a sediment alternative is imple-
mented.    One   such  tool,  the  Sediment  Contamination  Assessment Model  (SEDCAM),
developed  as  part of  the  Commencement Bay Feasibility Study,  and may have  potential
for application in other areas.
Monitoring the Success of Remedial Actions

     What  criteria  are  being  used  to  measure  the  success  of remediation?    Are
     contingency  plans  in  place  to  respond  to  monitoring  results?    Is there  an
     institutional  framework  for  insurance,  bonds,  disposal  site  repair,  and  other
     necessary post-project concerns?

     Monitoring was identified  as an  important  component of  any  sediment remediation
program.   As  part of  the  monitoring  program,  criteria should  be  established to  evaluate
effectiveness of  the  remedial actions  and  determine if there is  a release  of contaminants
from any sediment disposal  sites.   It  was concluded that these criteria  should  be established
on a site-specific basis.

     The degree and kinds of monitoring  data are dependent on a variety of site-specific
factors,  including   contaminants  present  (e.g.,  metals  vs.  organics),   spatial  extent  of
contamination,  involvement  of  food  web  organisms,  relationship to  transport  mechanism
(e.g.,  groundwater), and the kind  of  sediment remedial alternative (e.g., in situ  treatment,
capping,  removal and offsite disposal).   The  workgroup  concluded  that,  in general, the
collection of  only chemistry  data may  be appropriate to  monitor smaller  sites,  whereas
biological data  will  be  desirable for larger  sites, especially if  there  is contamination of
fish and shellfish resources.

     An  important use  of  monitoring  data  is  to determine  whether  the  remedial  action
results  in an  elimination  of the  contaminant  threat  to  the  environment  and  to public
health.   If  the post-remediation  response  is not  as expected  (i.e.,  the  remedy  fails), the
following evaluations are recommended:
                                            57

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     •     Check the  remedy  (e.g.,  Was  it  properly  executed  according  to  design
           specifications?  Was there a structural failure?)

     •     Evaluate  fundamental  assumptions  and  predictive  relationships (i.e.,  Was
           the failure due to improper design of the remedial alternative?)

     •     Finally,  the  regulatory  agencies   should check  for  a  re-opener  in  the
           consent judgement  for the project.

  The   final  part  of  this  topic  dealing  with  insurance,  bonds,  and  other  post-project
liability  concerns was  not  addressed  by  the workgroup  because  of a  lack  of  expertise
and experience by the workgroup members in these areas.
Remedial Action Contingencies Plans

     Are  the   selected  alternatives  solving  the  sediment  contamination   problems?
     What  action  should  occur   if  a   selected  alternative  encounters  significant
     opposition or is found to  be technically flawed?

     In  general  there  has  been  insufficient  experience at  contaminated  sediment sites
to  develop  overall  conclusions  on  the  effectiveness  of  various  remedial  alternatives.
Because  of this  lack of  direct  application  and  because of  new  interest in  contaminated
sediments,  some  of  the  alternatives being evaluated  or  selected  are  untested  in  the
field  or are highly  innovative in  nature.   Many  of the  alternatives  that  are potentially
applicable  to  sediments  have  only been  applied in  pilot or  bench-scale studies  or have
been previously tested only on soils.

     The  innovative  and  untested characteristics  of many  sediment  remedial alternatives
pose special problems for  the agency  project  managers [e.g., Regional Project  Managers
(RPMs)]  or other  individuals  involved  in  implementation  activities.    These  individuals
have  limited  experience  with assessment  and  implementation of  remedial  alternatives for
situations  involving  sediment  contamination.    Because  of the  limited  experience  and the
lack of "off   the shelf"  solutions, these  individuals  may  potentially  select  inappropriate
options.
                                            58

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     Support and  training  are  two  important  factors  in  preventing  this  situation and
ensuring that selections  of remedial alternatives are based  on sound  technical considerations.
First,  it  is  important  that  the  person  in  charge  of  the  implementation  project  be
supported  by  other  parts  of the  agency  with  needed   technical  expertise.    A  critical
need  is  for expert  assistance  in the  areas of toxicology  and  human  health  effects.
Links  should be  established  with other  parts of the agency  to ensure prompt advisory
service  on  relevant issues.   Second,  the site  managers  should  receive specific training
in the  availability and applicability of sediment remedial  alternatives to various contaminant
problems.    This  is  important  because  the  characteristics  of  sediments  result  in   very
different remedial design considerations than those used for contaminated soils.
Additional Implementation Approaches

     What  additional  approaches  should  be  explored to  accomplish  remediation of
     toxic sediment problems?

     The  workgroup  concluded  that  there  are substantial  opportunities  to  "piggyback"
toxic sediment removal projects onto maintenance dredging projects  by the Corps  and other
entities involved  in maintenance dredging  (e.g., ports).   This  potential  results  from  the
co-occurrence  of  many sediment  contamination  problems  in the  inner  harbor  areas of
major  ports that are subject to siltation and require periodic channel deepening.

     The  opportunity  to integrate  toxic  sediment remediation  with  maintenance dredging
operations  provides  the  possibility  of  relatively low  marginal costs and  less  complex
planning  than  is  involved in  a Superfund  site  effort.  Some  additional  external funding
may be  required,  however.   The use of CWA  Section  115  funds  (see  Appendix C and
previous discussion  by  Workgroup I)  should  be evaluated  for this purpose.   This cooperative
effort  offers cost  saving  benefits  to EPA  and state regulatory agencies as  well as  to
the Corps  in  that  contaminant levels would be lowered for  future navigation projects.
Therefore, future consideration of disposal alternatives would be simplified.
                                            59

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Institutional Arrangements

     7s there a need to improve institutional arrangements for sediment remediation?

     The consensus of  the  workgroup  was that there is  a definite  need to increase  the
coordination  among ail  agencies  involved  in  sediment remediation projects  (see  previous
section  on  lAs,  for  example).    Several  examples  of  successful  integration of  various
agency  programs  were  identified:   the  New  York-New  Jersey  steering committee  for
dredged  material disposal,  PSDDA  and  PSEP  in  Region  10,  the  Region  5   Inter-Agency
Workgroup on  confined disposal  facilities  (CDF), and the Hudson River  PCB Settlement
Advisory Committee.

     As discussed above, the interagency agreement between EPA and NOAA for Preliminary
Natural Resource Surveys  has  been successfully implemented  in  Regions  1 and 10.  It is
recommended that extension of the interagency agreement be considered for other regions.
                                          60

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                        CONSIDERATIONS FOR INTEGRATING
                   TOXIC SEDIMENT MANAGEMENT STRATEGIES
     In  this  section,  key  elements  of the  three  components  of  sediment management
(i.e., prioritization  of  problems,  selection of management  alternatives, and  implementation
of  alternatives)  are   synthesized  in  an  integrated  framework  to  form  the   basis  for
planning  activities  and  future  development  of  sediment management  strategies.    This
synthesis  is  not intended  to be a  comprehensive  summary  of  all workgroup  recom-
mendations.    Instead, interrelationships among   the  three  management  components  are
highlighted, consistent  with the conclusions and  recommendations of individual workgroups
summarized in greater detail in  the  previous sections.  This  section was  developed after
the workshop by EPA/OPA and its contractor.

     Specific  management strategies  for each area of  interest  were  not always  addressed
or concluded by  the workgroups.  Hence, major unresolved  issues that affect development
of consensus on these strategies are also re-emphasized in  this section.
SETTING PRIORITIES FOR MANAGEMENT

     Prior to  assessing  potential actions  or implementing  a specific  action,  the  relative
priority of different  sites  or areas  within  a site must be assessed  to  ensure that  cleanup
or  dredged  material  management  resources  are  appropriately  focused.    Workgroup  I
evaluated  a wide  range  of issues concerning  the  setting of priorities, which are strongly
influenced by  the goal of  the  particular  management program.   In  particular, differences
between  the  goals  of  programs for  dredged  material  disposal  and  sediment  remedial
action may well lead to different priorities for action.
Unresolved Issues

     The  largest  number of  unresolved  issues  were  identified  in  this  portion  of  the
workshop, including the following major issues:
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Permitting:   Liability  issues on  who cleans up  and  who  pays are clearly
unresolved.  This issue was noted in each of the three workgroups.

How Clean Is Clean:

     There were several requests for  guidance  on  appropriate  biological
     test methods (ecological and lexicological)  and  observations by  some
     that the database is not sufficiently  developed to support toxicological
     analyses for effects  of specific chemicals.

     A  lack  of availability or  understanding  of  methods  for selecting
     reference  areas was cited  as an obstacle to acceptance  of  assessment
     methods that use a reference  area approach.

     In  Superfund  projects,  it  was  undecided  as to  the  extent  to which
     data  besides chemistry (e.g., biological) should  be  used to  determine
     PRP  responsibility.   Chemistry  alone was  considered insufficient  by
     some for requiring cleanup.

     Currently   95  percent confidence  (i.e.,   alpha=0.05)   is  typically
     assigned in statistical  tests.   There  was some  discussion of lowering
     the confidence level to 80-85 percent for some purposes.

Navigational Dredging:

     The  assumption  in  navigation  dredging   has   generally  been  that
     protecting  living   resources   is  adequate  to  protect  human  health.
     Whether this is a protective assumption was questioned.

     For  dredged   materials  classified  as  contaminated,   the  technical
     justification   and   cost-efficiency  of   sometimes   requiring  steps
     required  under  RCRA  for  sediment  disposal  were  questioned  (e.g.,
     why put a landfill liner in a nonpermeable sediment disposal site?)
                                 62

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                There  was  concern  as  to  whether  current  dredged  material  tests
                from  the  EPA/Corps  "implementation  manual"  for  ocean  disposal
                are  protective enough.   It was  noted that these  methods  are  often
                applied for disposal in  inland  waters as  well  as the ocean.   Because
                the  sensitivity  of  the  bioassays  may  be  insufficient,  it  was  noted
                that  the  methods  are  currently   under  revision   (including,  for
                example,  publication  of regional  manuals).  Work  is  also  underway
                to  develop  compatibility  of  methods  for  assessing  contamination
                under  CWA  Section 404 and the Ocean Dumping Regulations  under
                MPRSA.

                There   was   concern   that   although  data collection  by  itself  is
                perceived  by the public as  indicating  that some  beneficial action is
                being  taken,  more  appropriate ways are  needed  to show  the public
                that agencies are actively working  to correct environmental problems.

           Sediment Cleanup  and Standards:

                It  was  unclear  at what point  costs  should be  taken  into account  in
                setting cleanup targets (a recurring question in other workgroups).

                The workgroup was at issue  over the utility  and appropriateness of
                national  sediment  standards.    While consistency  is a  very desirable
                outcome of such  a standard, sediment  contamination is  often  a very
                localized problem  that requires flexible regulatory criteria.
Overview

     A  definitive strategy for  setting  priorities  was  not  formulated  by  Workgroup  I,
although a number of recommendations  were made.   In particular, the  workgroup  generally
recommended that tiered testing  strategies  be used  to assess  priorities.   An  example of
a  simplified  strategy  for  tiering  tests  based  on  chemical  and  biological  assessments,
developed  by OP A and  its  contractor  after  the  workshop,  is  shown  in Figure  1.    The
specific  need for testing will  depend  on the  availability of existing  information, as well
                                           63

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     ASSESS EXISTING INFORMATION
            CONDUCT TIER I
           CHEMICAL TESTS
           AS APPROPRIATE
            CONDUCT TIER II
           BIOLOGICAL TESTS
            AS APPROPRIATE
           CONDUCT TIER III
     ADDITIONAL ECOLOGICAL TESTS
           AS APPROPRIATE
       PRIORITIZE SITES BASED ON
   PREDICTED OR OBSERVED EFFECTS
Figure 1. Generalized strategy for tiering chemical and biological tests.
                   64

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as  the  degree  of  acceptance of  predictive  relationships  embodied  in  sediment  quality
standards  that   relate  chemical  contamination  and  biological  effects.     For  dredging
projects,  criteria based  on   both  chemical  and  biological  data  may  be  used  to  rank
different  sites.   Beneficial uses of  dredging are also  key considerations  in deciding  the
final priorities for a particular project as well as for ranking potential disposal sites.

     A  generalized  strategy  for  ranking  sites for  remedial  action, developed  after  the
workshop, is shown  in  Figure 2.   Chemical  or biological sediment  quality values are used
to  interpret  site-specific  data  on   contamination   and  biological  effects.    From  this
assessment,  problem  areas  and chemicals  can be  identified and prioritized  for subsequent
source identification  efforts.   A  final priority for  potential  action could then  be based
on  a final assessment of environmental and human health hazard posed  by  the contaminated
sediments  and  a determination of  the adequacy of source  identification.   A simplified
decision   process  for  prioritizing  sediment   remedial  action   relative  to  source  control
actions  is  shown in  Figure  3 (presented  during  the workshop  as  part of Workgroup  II).
In  general, sediment remedial action  should  be  undertaken only  when major sources  of
contamination  have  been  identified  and  controlled.    Because  100  percent  source  control
may not  be possible, a  combination  of source control and  sediment remedial  action may
be  necessary as part of the selection  of a best  management alternative.   The determination
of  the  best management  alternative  for  each  site may  also  affect priorities among  sites,
as discussed in the following section.
SELECTING THE BEST MANAGEMENT ALTERNATIVE(S)

     After  establishing  the need for  action  at a  particular  site,  selection  of the  best
management alternative (either  for  remedial action  or for an  appropriate  disposal site  for
dredged  material) can  involve  a wide range  of technical and cost considerations.   The
particular action  selected  for  a  site  may,  therefore,  modify  the initial  priority  assigned
to the site  during  problem  identification.   Workgroup II  examined  a  variety of selection
strategies, which have been used to develop a generalized strategy in this section.
                                            65

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 ASSEMBLE DATA ON
CONTAMINATION AND
BIOLOGICAL EFFECTS
APPLY ACTION-LEVEL
    GUIDELINES
      IDENTIFY
  PROBLEM AREAS
      PRIORITIZE
   PROBLEM AREAS
  IDENTIFY PROBLEM
      CHEMICALS
                        SEDIMENT QUALITY
                             VALUES
I
 PRIORITIZE PROBLEM
      CHEMICALS
                             SOURCE
                          IDENTIFICATION
J
  FINAL PRIORITY FOR
   REMEDIAL ACTION
 Figure 2. Generalized strategy for assigning priorities for remedial action.
                     66

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                              SIMPLIFIED DECISION PROCESS
                 FOR SEDIMENT REMEDIAL ACTION /  SOURCE CONTROL
o>
-J
                                Identify Problem Areas,
                                  Chemicals, Sources
                                Major Ongoing Sources?
                                          I	
                       Yea

               Estimate Maximum
               % Source Control
Recovery Predicted
   in Acceptable
    Timeframe?
                       No
                                   Yes
                                        1
                                    Evaluate Only
                                   Source Control
               Evaluate Combination
             Sediment Remedial Action
                and Source Control
                                              No
Recovery Predicted  Yes
   in Acceptable
   Timeframe?
                                              No
                                          Evaluate
                                         Sediment
                                      Remedial Action

                                                       No Sediment
                                                      Remedial Action
                   Figure 3.  Simplified decision process for sediment remedial action/source control.

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Unresolved Issues

     Major unresolved issues identified by Workgroup II included the following:

     •     Cross-Program Constraints:

                PRPs are reluctant  to dredge and dispose because they  gain liability
                at the new disposal  site.   These  concerns lead to pressure  for  onsite
                disposal, which should be recognized in the selection process.

                It is not always evident when  after  treatment a residue  no  longer
                retains Superfund liability.   There should  be  clear definitions so  that
                at some  point  wastes or  residues  from  treatment processes can  be
                deregulated.

     •     No-Action Alternative:

                The   definition   of  "no  action"  is  ambiguous  among  programs  and
                should  be made  consistent  (at  least by clearly defining assumptions
                concerning whether institutional controls  imply  "action")

                It was  noted that better definition  is  required  for  determining how
                to  weigh  ecological/environmental  concerns   in  rejecting  the  no-
                action alternative.    It  was  generally  observed  that  some  prepon-
                derance-of-evidence  requirement  should  be  used to  make  the case
                for ecological harm before rejecting the no-action alternative.

     •     Sediment  Remedial Alternatives:

                Although  controversial,  the   beneficial   use   of  the   assimilative
                capacity  of  the environment was raised  as  a possible  consideration
                when choosing disposal options.

                The  use of  quantitative risk assessment  is  an  issue  based on  the
                discrepant views of the workgroup  on  how  to report results  to the
                public.   The release  of numbers should  be controlled in some way,
                but  at the same time there was  a need expressed to identify decision

                                            68

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                 rules  using risk assessment.    Issues revolve  around  clearly  defining
                 what  is to be  protected  and  for  how  long (both at the  disposal site
                 and the dredged site).  There was  a concern by one participant that
                 there  was  too  much information  for  different  environments  to  be
                 able to come  to an effective conclusion.

           Selection of the  Best Alternative:

                 There was  discussion as to how much of an advocate for environmental
                 protection  EPA  should  be.    If  EPA  acts  as  a  constant  advocate
                 there  is  the  danger  of  losing  credibility,  although credibility can
                 also be lost if an advocacy position  is  not taken.   There also  appeared
                 to  some  to  be a  double  standard regarding  funding; public  funds
                 may  be  rationed,  but PRP   funds  are  readily  attached  with  much
                 less regard  for cost effectiveness.

                 When  costs  should  be  considered was  not  fully  resolved.    One
                 suggested  approach  for  early  consideration  of costs  was  to  first ask
                 "What is  the problem?",  then  "What  are  the  intangibles  that may
                 require  protection?",  and  finally  "Is  the  cost  excessive?    It  was
                 suggested  that  such a preliminary  cost analysis definitely should not
                 consider  whether   the PRP   can   afford  it  and  should  not  be  a
                 detailed  cost/benefit analysis,  but  should  provide some  sense  as to
                 whether the project was cost effective.

                 The  quantification  of guidance  for  selecting  alternatives   was  not
                 fully   resolved,   but  some felt that the  guidance should  be cast  as
                 relative  indices, not "criteria".   With relative  indices the  bottom line
                 was judged to  be  more  easily defined, although  the need  for  some
                 kind  of sensitivity  analysis was  also  expressed (i.e., presentation  of
                 results as a range for each alternative).
Overview

     Selection strategies for  dredged  material  disposal options  have been refined  by  the
Corps  for  general  use.   The  basic approach is  incorporated  into  a  decision-making  frame -

                                            69

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work, which is  shown  in simplified  form  in  Figure  4.   Using this  framework,  a phased
process  for  selecting  a  dredged material  alternative  has been formulated,  as  shown  in
Table 2.  The DMASS process  is  used to  identify important contaminants  and pathways;
to  rank the  importance  of  pathways  according  to  site-specific   factors;  to   develop,
screen,  evaluate,  and  rank disposal  alternatives; and  to provide a final  selection using  a
variety  of  technical and cost criteria.    The  DMASS process  coupled  with  the  decision-
making  framework developed by the Corps provides an  integrated  approach  to disposal
site  prioritization  and  selection  of  management alternatives.   However, DMASS  does not
explicitly include  some  items  relevant  to toxic sediments,  for example,  an assessment  of
human health risk.

      At contaminated  sites,  managers are faced with a  wide  range  of alternatives,  shown
in  Table 3.   Only some  of these  alternatives  involve  dredging  and disposal  activities.
It should be noted that  the  no-action  alternative  can  be defined in  a manner consistent
with  NEPA  (i.e.,  no sediment or source  control  action  of any  type) if control of discharges,
which might proceed  in the  absence of sediment remedial  action,  is considered  as one
of several possible institutional controls.

      A  phased approach to screening and  evaluating these remedial  alternatives  has been
recommended  in  the  National  Oil  and  Hazardous  Substances  Pollution Contingency Plan
(NCP) (Table  4).   The NCP  establishes  the process  for determining  appropriate  removal
and/or remedial  actions  at  Superfund sites  (Federal Register  Vol.  50,  No. 224, p. 47946).
This  approach  has several parallels  to  the DMASS  approach for  disposal site  selection
(Table 2).   Evaluation  criteria  recommended  under  CERCLA/SARA guidance  (Table   5)
also   share  characteristics  of  several of those  used  in DMASS  (Table  2).    However,
remedial  alternatives  address  a  much  wider  range  of remedial technologies  and process
options (e.g., Figure 5) than is required for  navigation  dredging  projects.   At  least one
detailed  alternative for  each  of  the  general categories of  alternatives  shown  in Table  3
is recommended  for analysis to  facilitate a  balanced remedy.  Not all  of the  potential
technologies  are  equally implementable,  even  for more routine   dredging  and  disposal
alternatives  (e.g.,  see Table 6).   The  initial  and final  detailed screening of  alternatives
will  eliminate  many proposed  remedial  technologies  because   of the lack  of  information
regarding their applicability to marine sediments.

      A  useful technique for comparing  cost  and technical criteria for different alternatives
is shown in Figure  6.    All  three  workgroups  were  divided  as to when  costs should  be
                                           70

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                                  ASSESSMENT
Figure 4.  Basic decision-making framework for dredged material disposal.
                      (Reference:  Lee et al. 198S)

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         TABLE 2.  SUMMARY OF THE DREDGED MATERIAL ALTERNATIVE
                     SELECTION STRATEGY (DMASS) PROCESS
                           (Reference:  Cullinane et al. 1986)
      Phase
      Step
    Purpose
   Criteria Used
I.    Presumption of
     contamination
     pathway
II.   Confirmation
     of contamination
     pathway
     (site-specific)
III.  Alternative
     development and
     initial screening
I.  Select potential
   sites
                        2.  Assess site
                           characteristics

                        3.  Identify pathways
                           of concern
                        4.  Select dredge/
                           transport
                           technique
                        5.  Site constraints
                           Check compatibility
1.  Select potential
   technologies
                        2. Develop alterna-
                           tives

                        3. Screen alternatives
Apply decision-making
framework to identify
contaminant type,
level, and pathway

Eliminate poor or
inferior sites
Determine attributes
of sites

Is pathway identified
in Phase I as
concern at site?

For potential  sites
and pathways,
eliminate poor
transport combinations

Are remaining
site-dredge/transport
options compatible?

Identify suitable
combinations  of
technologies
                       Combine technologies
                       and sites

                       Eliminate poor or
                       inferior alternatives
Decision-making
framework    and
related    regional
administrative decisions

1.  Availability
2.  Distance
3.  Capacity
4.  Cost
5.  Impact
                                              1.
                                              2.
                                              3.
   Impact
   Cost
   Compatibility
1. Impact
2. Cost
3. Accepted
   engineering practice
                                          72

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TABLE 2. (Continued)
      Phase
      Step
    Purpose
   Criteria Used
IV.  Detailed
     evaluation and
     ranking
1.  Evaluation of
   alternatives
Extensive evaluation
of remaining
alternatives
                         2.  Ranking of
                            alternatives
                       Arraying of
                       alternatives for easy
                       comparison
V.   Alternative
     selection
1.  Cost
2.  Operation &
   Maintenance
3.  Reliability
4.  Safety
5.  Regulatory
   requirements
6.  Implementability
   and availability
7.  Public acceptance
8.  Environmental
   impact
9.  Technical
   effectiveness

Same as above
                                            73

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  TABLE 3. GENERAL CATEGORIES OF SEDIMENT
        REMEDIAL ACTION ALTERNATIVES
No Sediment Remedial Action (i.e., Natural Recovery Only)

Institutional Controls (Including Source Control)

In Situ Containment (Capping)

Removal and Disposal

Removal, Treatment, and Disposal
                        74

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                    TABLE 4.  NATIONAL CONTINGENCY PLAN
                         EVALUATION OF ALTERNATIVES
PHASE I:  INITIAL SCREENING OF ALTERNATIVES

     Cost

          Initial
          O&M
          (order-of-magnitude cost/benefit analysis)

     Effects of Alternative

          Adverse environmental effects
          Effectiveness of source control
          (Effective protection of public health, welfare, or environment)

     Acceptable Engineering Practices

          Feasible
          Applicable
          Reliable


PHASE II:  DETAILED ANALYSIS OF ALTERNATIVES

     Emphasis on Established Technology

     Detailed Cost Estimation

     Engineering, Implementation, or Constructability

     Extent of Protection

     Adverse Impacts and Costs of Mitigation
THE SELECTED ALTERNATIVE SHOULD BE:

          "the  lowest cost alternative that is technologically feasible and reliable
          and which effectively mitigates and minimizes  damage to and provides
          adequate* protection of public health, welfare, or the environment."
                                         75

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        TABLE 5.  CERCLA/SARA EVALUATION CRITERIA
    TO DETERMINE APPLICABLE REMEDIAL TECHNOLOGIES
Institutional Compliance

          Applicable or Relevant and Appropriate Regulations (ARAR)
          Other Criteria, Advisories, Guidance

Reduction in Contamination

          Toxicity
          Mobility
          Volume

Protectiveness

          Short-term Effectiveness:

               Public Health/Safety
               Timeliness

          Long-term Effectiveness:

               Permanence

Implementability

          Technical Feasibility:

               Constructability
               Demonstrated Technologies
               Available Contingencies
               Operation and Maintenance
               Monitor Effectiveness

          Availability:

               Equipment in Region
               Materials/Specialists in United States
               Local Treatment/Storage/Disposal Facilities
Cost
          Design and Specifications
          Capital Construction (Direct and Indirect Costs)
          Operations and Maintenance
          Monitoring
                                 76

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RESPONSE REMEDIAL ACTION
ACTION OR TECHNOLOGY

NO ACTION 	

INSTITUTIONAL
CONTROLS

IN srru
CONTAINMENT

RFUSWal _


IN srru
TREATMENT

POST-REMOVAL
TREATMENT

DISPOSAL —

— | None |


PROCESS OPTION



~~| Ute Restriction j
— ( Aoeatt Restriction")
— { MonltoringJ
1— | Haiard Education Pregramt |




^Sermt and Dike* |

— {Mechanical
Overcappfno | Sediment | Qay/Sand/G/auel
Synthetic Man

Vnrlninnl

— j HydraUie Dredging | 	
— | Specialty Dredging | 	
1— | Excavation

r—| Solidification




— jCnarnicalTranttormation | 	
1— | BJotoQiea) Treatment |

,— | SolidHicallon




— \ Chemical Trt
— | Biological Tn
— | Thermal Trea













qUnconflnad




J


| Sorbonls
nbrana | SdidiflcatiorVSlabilizatlon


damthrtl) Draojme| Bucket Ladder | Dipper |
Cuttarnead | BucketMheel |SucSon |Dutpan[H
bppaf |
Mud Cat | Cleanup | ReHsher JDREXJ WaMauf
Backhoat floai

El


GrtXtt | Gate [vWfcafen |
Thamiopiatttc Procawat | Pozzolanic ProonaM [SealanB J
Oxidation | Denatogenafenl
BJorectamaUon j



Sorbana | Grouti | Gala | VartteaUon


1 n_ • f^

OxidatervRaMtuctlon | D*)haJooenatton JHydroty
NvuVifiZaUkin | Ozonsten | ton Exdvngv |
Comptialng
AcSvmtBd SJudga
| Lirttarrw^g
TraatnantLagoont
i JSealana
tit | Photolysis
PiQuuitalion

RparyWh | HTFWfleadpr | WMAirOiadatton | MollBnSalt


idBed | Pyrolyw*
Ptoma Are Torch | Vertical Tuba Raaeer Advanead Etoctrte Reactor
Dawatanng | Sol Wtahlng | Sohwit Extnadion
Carbon Adaorpdort |Rltr«tlon| Sofld* Separation

Opan Waterf
Shallow-water

Figure 5. Example sediment remedial technologies
(Reference: Tetra Tech 1987)

Naarahore [Upland |

Volaflbaten
Sedimentation

and process options.
77

-------
TABLE 6.  STATUS OF APPLICATION OF CONTROL/TREATMENT TECHNOLOGIES
                     (Reference: Cullinane et al. 1986)
Technology
Controls Durine Dredsina
Dredge selection
Barriers
Operational controls
Controls During Transport
Hopper dredges
Specialized barges
Pipeline controls
Pump controls
Route/navigation controls
Loading/unloading controls
Truck transport
Rail transport
Restricted Open-Water Disposal
Submerged diffuser
Gravity-fed downpipe
Hopper dredge pump down
Solidification/stabilization
Capping
Lateral confinement
Restricted Upland Disposal
Covers
Surface sediment stabilization
Liners (synthetic)
Liners (soil)
Slurry walls
Surface-water controls
Subsurface drainage
Groundwater pumping
Sheet piling
Site security
Settling basins
Stationary screens and sieves
Moving screens
Hydraulic classifiers
Spiral classifiers
Cyclones and hydrocyclones
Solidification/stabilization
n
Proven Demonstrated

X X
X X
X X

X X
X
X
X
X
X
X
X

X
X


X


X
X
X
X
X
X
X X
X
X
X
X X
X
X
X
X
X
X
Demonstrable






X
X
X
X
X
X
X

X
X


X
X

X
X
X
X
X
X

X
X
X





X
X
Conceptual
















X
X

X












X
X
X
X


                               78

-------
TABLE 6. (Continued)

Technology
Rotary- kiln incineration
Multiple-hearth incineration
Fluidized-bed incineration
Extraction
Immobilization
Degradation
Attenuation
Chemically-assisted
clarification
Filtration
Chemical precipitation
Carbon adsorption (metals)
Chemical reduction
Chemical oxidation
Ion exchange
Carbon adsorption (organics)
Biological treatment
Stripping
Chlorination
Ozonation
Distillation
Electrodialysis
Reverse osmosis
Proven Demonstrated Demonstrable
X
X
X
X
X
X
X

X X
X X
X X
X



X X







Conceptual
X
X
X
X
X
X
X




X
X
X
X

X
X
X
X
X
X
X
Restricted Nearshore Disposal

Covers                               X                                 X
Surface-sediment stabilization         X                                 X
Liners (synthetic)                     X                                 X
Liners (soil)                          X                                 X
Slurry walls                          X                                 X
Surface-water controls                X              X
Subsurface drainage                                                                      X
Groundwater pumping                                                                    X

Sheet piling                          X                                 X
Site security                          X                                 X

Settling basins                        X              X
Stationary screens  and sieves          X                                                   X
Moving screens                       X                                                   X
                                                 79

-------
TABLE 6.  (Continued)
     Technology                 Proven*      Demonstrated       Demonstrable      Conceptual


Hydraulic classifiers                 X                                                   X
Spiral classifiers
Cyclones and Hydrocyclones          X                                X
Solidification/stabilization            X                                X

Rotary-kiln incineration             X                                                   X
Multiple-hearth incineration          X                                                   X
Fluidized-bed incineration           X                                                   X

Extraction                           X                                                   X
Immobilization                      X                                                   X
Degradation                         X                                                   X
Attenuation                         X                                                   X
Chemically-assisted
clarification
Filtration
Chemical precipitation
Carbon adsorption (metals)
Chemical reduction
Chemical oxidation
Ion exchange
Carbon adsorption (organics)
Biological treatment
Stripping
Chlorination
Ozonation
Distillation
Electrodialysis
Reverse osmosis

X X
X X
X
X
X
X
X
X
X
X
X
X
X
X
X



X
X
X
X
X
X
X
X
X
X
X
X
X

a   Proven  in  concept  which  may also  have  been demonstrated or  is  demonstrable;  unproven
technologies are by definition only conceptual although the concept may be demonstrable.
                                                 80

-------
        INCREASING
        COMPOSITE
           COST
          SCORE

             $
(adapted from CullinaiM et al. 1986)
                               11
                 Remedial
               Alternatives
                                  12
8
                10
      13
                                                   14
                          INCREASING COMPOSITE TECHNICAL SCORE
                Figure 6. Comparative display or composite cost and technical criteria.
                       (adapted from Cullinane et at. 1986)

-------
incorporated  into   a  management  strategy   for  contaminated  sediments,  although  in
general,  some  early  consideration  of the magnitude of costs  was  recommended.   Analysis
of  Figure  6 indicates  that  the  best alternatives  are  those  shown  on  the  dotted envelope
of  the  cost-technical  criteria  graph.    For  example, any  alternative  not  on  the dotted
line can always  be  replaced  by a  less expensive  and technically superior alternative  on
the  dotted  line  (e.g.,  Alternative  8  of the  14  alternatives  is  less  favored  than  either
Alternative  3  or  10, which  have  higher  composite  technical  scores  and lower composite
cost scores).   Differentiation of  alternatives  along  the  dotted  line  results from a  final
weighing of cost vs.  technical  factors.
IMPLEMENTING THE SELECTED ALTERNATIVE

     Workgroup  III noted that there is considerably  less experience  in actually  implementing
management  alternatives  in  response  to  sediment  contamination concerns  than in  either
prioritizing problems or  in selecting management alternatives.  A number of  recommenda-
tions were developed  for increasing communication,  better defining project  implementation
needs,  and outlining implementation steps based on  a common-sense approach to sediment
management.
Unresolved Issues

     No major unresolved issues  were noted  by Workgroup II.   A  concern was observed
over the appropriate  way  to  evaluate  the  need  for  bonding,  insurance,  and  other  issues
related  to  cleanup  liability.   Resolution of this  issue is important for successfully moving
projects  into  an implementation  phase  but  was  considered  beyond  the specific  expertise
of the group.
Overview

     Regulatory  change  is often  a  primary  issue  of  concern because  many  sediment
management  projects  continue  over several  years  and  often  include  a number  of phases
that require different approaches  to  management.    In  the  face  of  regulatory  change,
the following strategy for adapting to change was recommended:
                                           82

-------
      •    Keep the project moving as rapidly  as  possible.   By shortening the overall
           assessment and  implementation  process, the  potential for major legislative
           or regulatory changes affecting the project is reduced.

      •    Maintain flexibility.  It should be recognized that  the regulatory environment
           may change.   Therefore,  the  implementation  plan should  be  sufficiently
           flexible  to  adapt  to  either  anticipated  or  unexpected  changes.    It  is
           important is  such cases  to maintain  the basic  logic  of the  plan  while
           adapting to changing regulatory circumstances.

      •    Maintain  information  flow  on  changes.   An  implementation  project will
           be  more adaptable to  regulatory change  if all  involved parties  are aware
           of the anticipated  or  existing changes.  Therefore,  it is important  for  the
           primary regulatory agency to disperse such information to PRPs, cooperating
           agencies, and contractors so that these groups can also maintain flexibility.

If the post-remediation  response  is not as  expected  (i.e., the  remedy  fails),  the following
evaluations were recommended:

      •    Check  the  remedy (e.g.,  Was  it  properly executed  according  to design
           specifications? Was there a structural  failure?)

      •    Evaluate fundamental  assumptions and predictive relationships  (i.e., Was
           the failure due to improper design of the remedial  alternative?)

      •    Finally,  the   regulatory  agencies  should  check  for  a  re-opener  in  the
           consent judgment for the  project.
                                            83

-------
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U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS.
                                          87

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Pastorok, R.A., P.N. Booth, L.G. Williams,  and J. Shields.  1986.  Framework for comparative
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Pastorok, R.A.  1988.  Guidance  manual  for  assessing  human health risks from chemically
contaminated fish  and shellfish.  Final Report.  Prepared  for U.S. Environmental Protection
Agency, Office of Water, Washington, DC.  PTI Environmental Services, Bellevue, WA.

Pavlou, S.P.    1987.   The  use  of the equilibrium partitioning  approach  in  determining
safe  levels  of contaminants in  marine sediments.  In:   Fate and Effects of Sediment-
Bound  Chemicals  in  Aquatic Systems.   K.L.  Dickson,  A.W. Maki,  and W.A.  Brungs (eds).
Pergamon Press, Toronto,  pp. 388-412.

Phillips, K...  D.  Jamison,  J.  Malek,  B. Ross,  C.  Krueger,  J. Thornton,  and J.  Krull.  1988.
Evaluation   procedures  technical  appendix.    Public   Review  Draft.    Prepared  by  the
Evaluation  Procedures Work Group  with  assistance of Resource  Planning  Associates,  PTI
Environmental  Services,  Shapiro  &   Associates,  and  Tetra  Tech,  Inc.   for  the  Puget
Sound  Dredged Disposal Analysis.

PTI.    1987.   Policy  implications  of effects-based  marine sediment criteria.   Prepared for
U.S.  Environmental  Protection Agency,  Office of Policy  Analysis.   EPA Contract  No.
68-01-7002.    PTI  Environmental   Services, Bellevue,  WA  for  American   Management
Systems. 57 pp. + appendices.

Puget Sound Water Quality Authority.   1987.  1987 Puget Sound  water quality management
plan.  Puget Sound Water Quality Authority, Seattle, WA.  212 pp.

Puget Sound Water Quality Authority.   1988.  1989 Puget Sound  water quality management
plan.  Puget Sound Water Quality Authority, Seattle, WA.  270 pp.

Sanders, J.   1988.   The Hudson River  a case  study,  summary of PCB  pollution  problem.
For presentation at the National Research Council Marine Board Symposium on  Contaminated
Sediment, Tampa, FL,  30 May-3 June  1988.   Barnard College, Columbia University, New
York, NY.   12 pp.

Simmers,  J.W.,  R.G.  Rhett, and C.R. Lee.    1983.    Application  of  a  terrestrial  animal
bioassay for determining  toxic  metal uptake  from dredged material.   In:   Proceedings,
International Conference on Heavy Metals in the Environment, Heidelberg, Germany.

Swartz, R.C.   (In press).    Guide for conducting static acute sediment  toxicity  tests with
marine and  estuarine infaunal amphipods.    American Society  for Testing and  Materials,
Philadelphia, PA.

Swartz, R.C., W.A.  DeBen,  J.K.. Phillips,  J.O. Lamberson, and F.A.  Cole.   1985a.   Phoxo-
cephalid amphipod  bioarsay for  marine  sediment toxicity.  pp.  284-307.    In:   Aquatic
Toxicology and  Hazard Assessment  Proceedings of the Seventh Annual  Symposium.  R.D.
Cardwell, R. Purdy,  and  R. Bahner  (eds).   ASTM STP 854.  American Society  for  Testing
and Materials, Philadelphia, PA.
                                           88

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Swartz,  R.C., D.W.  Schults,  G.R. Ditsworth, W.A. DeBen, and F.A.  Cole.   19855.  Sediment
toxicity,  contamination,  and macrobenthic  communities near  a  large  sewage outfall,   pp.
152-175.   In:    Validation and Predictability  of Laboratory  Methods for  Assessing  the
Fate and Effects of  Contaminated Aquatic  Ecosystems.    T.P.  Boyle (ed).    ASTM  STP
865. American Society for Testing and  Materials, Philadelphia, PA.

Swartz,  R.C.,  W.A.  DeBen,  K.A.  Sercu, and J.O.  Lamberson.   1982.   Sediment toxicity
and  the distribution  of amphipods   in  Commencement Bay, Washington,  U.S.A.   Mar.
Pollut. Bull.  13:359-364.

Tagatz,  M.E.    1987.   Some methods for measuring  effects of toxicants on  laboratory-
and  field-colonized  estuarine  benthic  communities,   pp. 18-29.   In:   Community  Toxicity
Testing.   J. Cairns  (ed).   ASTM  Special Publication 920.   American  Society  for Testing
and Materials,  Philadelphia, PA.

U.S. Army  Corps  of  Engineers Environmental  Laboratory.   1987.   Disposal  alternatives
for  PCB-contaminated sediments  from  Indiana Harbor,  Indiana.    Miscellaneous  Paper
EL-87-9, Volumes I and II.  U.S. Army Engineer Waterways  Experiment Station, Vicksburg,
MS.

U.S. Army  Corps  of  Engineers.   1983.    Preliminary  guidelines  for  selection  and  design
of  remedial  systems  for  uncontrolled  hazardous  waste  sites.    Draft  Engineer  Manual
1110-2-600. U.S. Army Corps, Washington, DC.

U.S. Army  Corps   of  Engineers.     1987.   Testing  requirements for  dredged  material
evaluation.  Regulatory Guidance Letter RGL-87-8. U.S. Army Corps, Washington, DC.

U.S. Army Corps of Engineers.  No  Date.   Introduction to  dredged material management:
an  illustrated  guide.   U.S.  Army  Engineer Waterways  Experiment Station, Vicksburg,  MS
and U.S. Army Corps Seattle District, Seattle, WA.

U.S. Environmental Protection  Agency.   1980.    Guidelines  for specification  of disposal
sites for dredged or  filled material.   Federal  Register, Vol. 45,  No.  249,  24 December
1980. pp. 85336-85358.

U.S. Environmental  Protection   Agency.    1984.    Initial  evaluation  of  alternatives  for
development of sediment related  criteria  for toxic  contaminants  in  marine  waters  (Puget
Sound).   Phase IL   Development and  testing  of  the sediment-water equilibrium  partitioning
approach. EPA 910/8-83/117. 90pp.

U.S. Environmental Protection  Agency.    1987.   Nonpoint  source guidance.   U.S.  EPA
Office  of Water, Office of Water  Regulations and Standards, Washington, DC.   33 pp. +
appendices.

U.S. Environmental  Protection Agency.  1988. Guidance for conducting remedial investiga-
tions and feasibility studies under CERCLA.  Volumes I  and II.   August  8,  1988 draft.
OSWER  Directive  9355.3-01.   U.S.  EPA  Office of Emergency  and  Remedial Response,
Washington, DC.

U.S. Environmental  Protection  Agency  and  U.S.  Army   Corps   of   Engineers.     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).   U.S.  Army  Engineer  Waterways  Experiment  Station,
Vicksburg, MS.
                                          89

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Varanasi, V., W.L. Reichert, J.E. Stein, D.W. Brown, and H.R. Sanborn.  1985.  Bioavailability
and biotransformation  of aromatic  hydrocarbons in benthic  organisms  exposed to sediments
from an urban estuary.  Environ. Sci. & Technol. 19:836-841.

Williams,  L.G.,  P.M.  Chapman, and T.C.  Ginn.   1986.   A  comparative  evaluation of
sediment  toxicity  using  bacterial  luminescence,  oyster  embryo,  and  amphipod  sediment
bioassays.  Mar. Environ. Res.  19:225-249.

Word,  J.Q.,  and  A.J.  Mearns.   1979.   60-meter  control survey off  southern  California.
Tech. Memo. TM 229.   Southern  California Coastal Water  Research  Project, El  Segundo,
CA.  58 pp.
                                          90

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                         GLOSSARY OF ABBREVIATIONS
ARAR         Applicable or Relevant and Appropriate Requirements under CERCLA/SARA
Authority       Puget Sound Water Quality Authority

BAG           BioAssessment Groups

CAD           Confined Aquatic Disposal
CDF           Confined Disposal Facility
CECW-D       Corps Chief of Engineers Civil Works - Dredging
CERCLA       Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS       Comprehensive  Environmental   Response,   Compensation  and   Liability
               Information System
Corps          U.S. Army Corps of Engineers
CSO           Combined Sewer Overflow
CWA           Clean Water Act
CZMA         Coastal Zone Management Act

DEQE          Massachusetts Department of Environmental Quality Engineering
DMASS        Dredged Material Alternative Selection Strategy

Ecology        Washington State Department of Ecology
EIS            Environmental Impact Statement
EP toxicity      Extraction Procedure (toxicity test)
EPA           U.S. Environmental Protection Agency

FDA           Food and Drug Administration
FWS           U.S. Fish and Wildlife Service

GE            General Electric  Co.
GIS            Geographic Information System

HRS           EPA Hazard Ranking System

IA             InterAgency workgroups

MCL           Maximum Contaminant Level
Metro          Municipality of Metropolitan Seattle
MPRSA        Marine Protection Research and Sanctuaries Act

NCP           National Contingency Plan
NDAA         National Defense Authorization Act
NEPA          National Environmental Policy Act
NJDEP         New Jersey Department of Environmental Protection
NOAA         National Oceanic and Atmospheric Administration
NOPA          National Ocean Program Act
NPDES         National Pollutant Discharge  Elimination System
NPL           EPA National Priorities List
NRDA         Natural Resource Damage Assessments
NYSDEC       New York State  Department of Environmental Conservation
                                        91

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OERR         EPA Office of Emergency and Remedial Response
OMEP         EPA Office of Marine and Estuarine Protection
OPA           EPA Office of Policy Analysis
OPPE          EPA Office of Policy, Planning and Evaluation
ORD           EPA Office of Research and Development
OSHA          Occupational Safety and Health Act
OWRS         EPA Office of Water Regulations and Standards

PAH           Polynuclear Aromatic Hydrocarbons
PICG          New York/New Jersey Public Involvement Coordination Group
PCB           PolyChlorinated Biphenyl
PNRS          Preliminary Natural Resource Surveys
POTW         Publicly-Owned Treatment Works
PRP           Potentially Responsible Party
PSDDA         Puget Sound Dredged Disposal Analysis
PSEP          Puget Sound Estuary Program

RCRA         Resource Conservation and Recovery Act
RfD           Reference Dose (previously called Acceptable Daily Intake)
RI/FS          Remedial Investigation/Feasibility Study
ROD           Record Of Decision
RPM           EPA Regional Project Manager

SARA         Superfund Amendments and Reauthorization Act
SEDCAM       SEDiment Contamination Assessment Model
SMP           Shoreline Management Plan

TCLP          Toxicity Characteristic Leaching Procedure
TSCA          Toxic Substances Control Act

WES           Corps Waterways Experiment Station

ZSF           Zone of Siting Feasibility
                                         92

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        APPENDIX A




LIST OF INVITED PARTICIPANTS

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                      WORKSHOP INVITED PARTICIPANT LIST

               TOXIC SEDIMENTS - APPROACHES TO MANAGEMENT
 Coordinator:

 Dr. Sally Valdes-Cogliano
 EPA/OPPE/OPA
 PM 220
 U.S. EPA
 401 M Street, SW
 Washington, DC  20460
 (202) 382-5871
Invited Participants:
(includes attendees)

Mr. Dennis Athayde
Participant
EPA/OW/OWRS (C&SD)
WH 585
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202)382-7112

Mr. Richard Batiuk
Participant
U.S. EPA
Chesapeake Bay Liaison  Office
410 Severn Avenue
Annapolis, MD 21403
(301) 266-6873

Ms. Melissa Bernstein
Participant
U.S. EPA, Region II
Marine and Wetlands Protection
26 Federal Plaza
New York, NY 10278
(212) 264-1570

Mr. Darrell Brown
Participant
EPA/OW/OMEP
WH-556M
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 475-8448
 Mr. Mark Brown
 Invited Speaker
 Dept. of Environmental Conservation
 Room 301
 50 Wolf Road
 Albany, NY 12233
 (518) 457-7470

 Mr. Fred Calder
 Participant
 Florida Dept. of Env. Regulation
 2600 Blair Stone Road
 Tallahasse, FL  32399-2400
 (904) 488-4805

 Mr. Paul  Campanella
 Participant
 EPA/OPPE/OMSE (MSD/ERB)
 PM 222A
 U.S. EPA
 401 M Street, SW
 Washington,  DC 20460
 (202) 382-4906

 Ms. Ruth Chemerys
 Participant
 EPA/OPPE/OMSE (MSD/ERB)
 PM 222A
 U.S. EPA
 401 M Street, SW
 Washington, DC 20460
 (202) 475-8214

 Mr. Frank Ciavattieri
 Speaker
 U.S. EPA, Region I
 HAN-CAN2
 Waste Management Division
 JFK. Federal  Building
 Boston, MA  02203
 (617) 573-5710

 Ms. Carol Coch
 Speaker
 Army Corps of Engineers
 26 Federal Plaza
 New York, NY 10278-0090
Attn:  CENAN-OP-W
(212) 264-5621
                                      A-l

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Mr. Mike Cox
Participant
EPA/OPPE/OPA
PM 220
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-2770

Ms. Shannon Cunniff
Participant
EPA/OEA/OFA
A-104
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-7072

Mr. Sherwood Cutler
Participant
NOAA
26 Federal Plaza
Room 734
New York, NY  10278
(212) 264-6325

Mr. Art Day
Participant
EPA/OSWER/OPMS (WMD/LDB)
WH 565E
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-4680

Mr. Charles Delos
Participant
EPA/OW/OWRS (MDSD)
WH 553
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-7039

Dr. Kim Devonald
Workgroup Leader
EPA/OW/OMEP
WH 556F
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 475-8484
Ms. Jane Downing
Speaker
U.S. EPA, Region I
HRSCA-2
JFK Federal Building
Boston, MA  02203-2211
(617) 573-5708

Dr. Robert Engler
Participant
Army Corps of Engineers
MC CE WES EP-D
Waterways Experiment Station
P.O. Box 631
Vicksburg, MS 39180
(601) 634-3624

Mr. Thomas Ferdette
Participant
Army Corps of Engineers
424 Trapelo Road
Waltham, MA 02254
(617) 647-8057

Mr. Will Garvey
Participant
EPA/OW/OWP
A  104F
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 475-7799

Mr. Frank Hammond
Participant
Maryland  Port  Authority,  Harbor
Development
World Trade Center, 19th Floor
401 E. Pratt Street
Baltimore, MD 21202-3041
(301) 333-4795

Mr. William Hanson
Participant
EPA/OSWER/OERR (HSCD/SPGB)
WH-548E
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-2345
                                       A-2

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Mr. Delbert Hicks
Participant
U.S. EPA, Region IV
C/O Mr. Reginald Rogers
345 Cortland Street, NE
Atlanta, GA 30365
(404) 347-2297

Mr. Dexter Hinckley
Participant
EPA/OPPE/OPA
PM 220
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-2781

Mr. William Ives
Participant
EPA/OW/OWP
A-104F
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-5047

Mr. Gary Jackson
U.S. Fish and Wildlife
1000 North Glebe Road, Rm. 601
Arlington, VA  22201
(703) 235-1904

Ms. Meg Kerr
Participant
EPA/OW/OWRS (MDSD)
WH 553
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-7056

Mr. Bob Koroncai
Participant
U.S. EPA, Region III
3WM12
841 Chestnut Street
Philadelphia, PA  19107
(215) 597-0133
Mr. Stephen Kroner
Participant
EPA/OW/OWRS (MDSD)
WH 553
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-7051

Ms. Catherine Krueger
Speaker
U.S. EPA, Region X
WD-139
1200 6th Avenue
Seattle, WA  98101
(206)442-1287

Ms. Jan Kurtz
Participant
EPA/SAB
A101F
Fairchild Building
U.S. EPA
499 S. Capitol St., SW
Washington, DC  20460
(202) 382-2552

Mr. John  Malek
Participant
U.S. EPA, Region X
WD-138
1200 6th Avenue
Seattle, WA  98101
(206)442-1286

Ms. Gayle Mallard
Participant
USGS
412 National Center
12201 Sunrise Valley Dr.
Reston, VA  22092
(703) 648-6861

Ms. Deborah Martin
Participant
EPA/OPPE/OPA
PM-221
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-7069
                                        A-3

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Mr. David Mathis
Participant
Army Corps of Engineers
Office of the Chief of Engineers
ATTN:  CECW-D
Washington, DC 20314
(202) 272-0397

Ms. Ossi Meyn
Participant
EPA/OSWER/OPMS (CAD)
WH-562B
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-4781

Mr. Jan  Miller
Participant
Army Corps of Engineers
219 S. Dearborn St.
Chicago, IL 60604-1797
(312) 353-6518

Ms. Pat Mundy
Participant
EPA/OSWER/OERR (HSED)
WH 548A
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 475-9495

Ms. Sue  Norton
Participant
EPA/ORD/OHEA
RD-689
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-2588

Mr. Edmund Notzon
Participant
EPA/OW/OWRS (MDSD)
WH 553
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 475-7301
Mr. Tom O'Connor
Participant
NOAA/OAD
 N/OMA 32
Rockwall Building
Room 652
Rockville, MD 20852
(301) 443-8698

Mr. Bill Painter
Participant
EPA/OPPE/OPA  (ERAD/WEB)
PM221
U.S. EPA
401 M Street,  SW
Washington, DC  20460
(202) 382-5484

Mr. Jon Perry
Participant
EPA/OSWER/OPMS
WH 565
U.S. EPA
401 M Street,  SW
Washington, DC  20460
(202) 382-4663

Mr. Loren Philips
Participant
Commander
U.S. Army
Environmental Hygiene Agency
Aberdeen  Proving  Ground,  MD
21010-5422
ATTN: HSHB-ME-WM

Mr. Keith Phillips
Workgroup Leader
Washington State  Dept. of Ecology
Mail Stop PV-11
Olympia, WA  98504
(206) 459-6143

Mr. Ron Preston
Participant
U.S. EPA, Region III
303 Methodist Bldg.
11 th and Chapline
Wheeling, WV  26003
(304) 922-2285
                                       A-4

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Mr. William Rabert
Participant
EPA/OPTS/OTS (HERD)
TS-796
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-4266

Dr. Clifford Rice
Pautuxet Wildlife Research Station
U.S. Fish and Wildlife Service
Laurel, MD 20708
(301) 498-0278

Mr. Reginald Rogers
Participant
U.S. EPA, Region  IV
345 Cortland Street, NE
Atlanta, GA  3036S
(404) 347-2126

Mr. Phil Ross
Participant
EPA/OEA/OFA
A  104
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 382-2407

Dr. Phil E. Ross
Participant
U.S. EPA, Region  V
230 S. Dearborn St. (5GL)
Chicago, IL 60604
(312) 353-0123

Ms. Moira Schoen
Participant
U.S. EPA/OPPE/OPA
PM 221
401 M Street, SW
Washington, DC 20460
(202) 382-5484

Ms. Elizabeth SoutherlancI
Participant
U.S. EPA/OW/OWRS (C&SD)
WH 585
401 M Street, NW
Washington, DC 20460
(202) 382-7049
Mr. Jim Thorton
Participant
WA Dept. of Ecology
Olympia, WA 98504
(206) 459-6016

Ms. Krystyna Wolniakowski
Participant
Near Coastal Waters Program Manager
OR Dept. of Environmental Quality
Water Quality Division
811 SW, 6th Avenue
Portland, OR  97204
(503) 229-6019

Mr. Thomas Wright
Participant
Army Corps of Engineers
MC CE WES EP-D
Waterways Experiment Station
P.O. Box 631
Vicksburg,  MS  39180
(601) 634-3708

Mr. Chieh Wu
Participant
EPA/ORD/OEPER
RD682
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-5977

Mr. Howard Zar
Speaker/Workgroup Leader
U.S. EPA, Region V
230 S. Dearborn St. (5W)
Chicago, IL 60604-1797
(312) 886-1491

Mr. Chris Zarba
Participant
EPA/OW/OWRS (C&SD)
WH 548E
U.S. EPA
401 M Street, SW
Washington, DC  20460
(202) 382-2339
                                        A-5

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               TOXIC SEDIMENTS - APPROACHES TO MANAGEMENT

                                     GUESTS
Mr. Rory Bens
Charles Menzie Associates
1 Courthouse Lane
Unit 2
Chelmsford, MA 01854

Mr. Harry Bridges
FHWA (HEV-20)
Washington, DC 20590

Ms. Marlene Berg
EPA/OERR
WH-548A
U.S. EPA
401 M Street, SW
Washington, DC 20460

Mr. Charles Bering
U.S. EPA, Region I, ORC
JFK Federal Building
Boston, MA 02203

Mr. Chris Carlson
EPA/OPPE/OPA/SPIB
U.S. EPA
401 M Street, SW
Washington, DC 20460

Mr. Bob Falkenstein
Federal Highway Administration
HEV-20
400 7th Street, SW
Washington, DC 20590

Mr. Seong Hwang
U.S. EPA
401 M Street, SW
Washington, DC 20460

Dr. Kenneth Kamlet
A.T. Kearney, Inc.
225 Reinkers Lane
Alexandria, VA  22314
(703) 739-4731
Ms. Diane Leber
CIBA-GEIGY Corporation
444 Saw Mill River Road
Ardsley, NY 10502
(914) 478-3131

Mr. Bill McFarland
General Motors
EAS Building
GM Tech Center
Warren, MI 48090

Ms. Stephanie Meadows
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005

Dr. Frank Prince
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005

Ms. Christine Reiter
SOLMA
1330 Connecticut Avenue
Suite 300
Washington, DC 20036

Mr. Mark D. Sickles
American   Association  of   Port
Authorities
1010 Duke Street
Alexandria, VA  22314
(703) 684-5700

Mr. Larry D. Weimer
RCC
3630 Cornus Lane
Ellicot City, MD 21043

Ms. Ruth Vender
EPA/OW/WQAB
U.S. EPA
401 M Street, SW
Washington, DC 20460
                                       A-6

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                             ADDITONAL MAILING LIST

               TOXIC SEDIMENTS - APPROACHES TO MANAGEMENT
Ms. Loretta Barsamian
Wetlands, Oceans, and Estuaries
U.S. EPA, Region IX
P-l
U.S. EPA
215 Fremont Street
San Francisco, CA 94105
(415) 974-8188

Mr. John Bascietto
EPA/OWPE
WH-527
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202)475-9811

Bendix Environmental Research
1390 Market Street
Suite 418
San Francisco, CA  94102
ATTN:  Selina Bendix

Rory Bens
401 Baldwin  Road
Carlisle, MA  01741

Mr. Charles Bering
Office of Regional Counsel
JFK Building
Boston, MA 02203
(617) 565-3715

Ms. Marlene  Berg
EPA
WH-548A
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 475-9493

BFI
1150 Connecticut Ave, NW
Suite 500
Washington, DC  20036
(202)223-8157
Mr. Julian Blomley
MSV
Systems Inc.
P.O. Box 6100
New Orleans, LA 70161
(504) 569-4641

Ms. Kathy Brandhager
Keller and Eluman
2400 Fourth & Blanchard Bldg.
Seattle, Washington  98121

Mr. John Catena
Oceanic Society
1536 16th Street, NW
Washington, DC 20036
(202) 328-0098

Ms. Denise  Ceduc
General Motors
Environmental Activities Staff
GM Technical Center
30400 Mound Road
Warren, MI 48090-9015
(313) 947-1854

Ms. Celia Chem
Marine Board
National Research Council
2101 Constitutional Ave, NW
Washington,  DC  20418
(202)334-3119

Ms. Diana Clemens
Surface Water Quality
MI Dept. of Natural Resources
Stephens T. Mason Bldg.
P.O. Box 30028
Lansing, MI 48909
(517) 373-2758

Mr. Pat Cotter
Wetlands, Oceans, and Estuaries Office
U.S. EPA, Region 9
215 Fremont St.
San Francisco, CA  94105
(415) 974-0257
                                        A-7

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Mr. Rodger Crawford
Outboard Marine Corp.
100 Seahorse Drive
Waukegan, IL  60085

Mr. Peter Cumbie
Duke Power Company
P.O. Box 33189
Charlotte, NC 28242

Mr. Nick Gillen
ATEC Environmental Consultants
8989 Herrmann Drive
Columbia, MD 21045-4780

Mr. Jerry Gless
Montana Power Company
40 E. Broadway
Butte, MT 59701
(406) 723-5421 x3336

Ms. Rhea Graham
Ponderosa Product, Inc.
P.O. Box 25506
Alburqurque, NM  87215

Mr. Pete Hudelson
CMA
2501 M  Street, NW
Washington, DC 20037

Mr. Anthony Kizaluskas
Great Lakes National Program Office
U.S. EPA, Region 5
230 South Dearborn St.
Chicago, IL  60604
(312) 353-3576

Mr. Michael Kravitz
Battelle
2030 M  Street, NW
Washington, DC 20036
(202) 728-7107

Mr. Steve Landau
Cotter Corp.
12596 West  Bayard  Ave.
Suite 350
Lakewood, CO 80228
Ms. Diane Lauer
Hunton and Williams
P.O. Box 1823
Washington, DC  20036
382-4012

Mr. Howard Levenson
Oceans and Environment Program
Office of Technology Assessment
U.S. Congress
Washington, DC  20510-8025
(202) 228-6856

Mr. Dave Levy
U.S. EPA
(202) 475-9829

Mr. Steven Maylan
Lake County Health Department
3010 Grand Ave
Waukeegan, WI  60085
(312) 360-6748

Mr. Bill McFarland
GM Corporation
Environmental Activities Staff
GM Technical Center
30400 Mound Road
Warren, MI 48090-9015

Ms. Stephanie Meadows
American Petroleum Institute
H.E.A.D.
1220 L Street, NW
Washington, DC 20005

Charles Menjie & Assoc.
1 Court House Lane
Unit 2
Chelmsford, MA  01824

Ms. Beth Millemann
Coastal Alliance
1536 16th Street,  NW
Washington, DC

Mr. William Muir
U.S. EPA, Region 3
841 Chestnut Street
Philadelphia, PA  19107
FTS 597-2541
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Mr. Robert Pavia
NOAA/OAD/N/OMA 34
7600 Sand Point Way, NE
Seattle, WA98115
(206) 526-6319

Dr. Richard Peddicord
Battelle Ocean Sciences
397 Washington Street
Duxbury, MA 02332
(617) 934-0571

Mr. Mark Sickles
American Port Authority Association
(APAA)
1010 Duke Street
Alexandria, VA 22314
(703) 684-5700

Ms. Maria Sileno
Pepper, Hamilton & Scheetz
1300 19th St.  N.W.
8th Floor
Washington, DC  20036
828-1512

Mr. Craig Simmonson
Outboard Marine Corp.
100 Seahorse Drive
Waukegon, IL  60085

Mr. Mike Stoner
U.S. EPA, Region X
HW-113
1200 6th Avenue
Seattle, WA 98101
(206) 442-2710
Mr. Nelson Thomas
U.S. EPA
Environmental Research Lab
6201 Congdon Blvd.
Duluth, MN 55804
FTS 780-5702

Ms. Charlotte White
EPA
WH-527
U.S. EPA
401 M Street, SW 20460
Washington, DC
(202) 382-4846

Ms. Ruth Vender
EPA/OW
WH-553 (Rm. 835E)
U.S. EPA
401 M Street. SW
Washington, DC 20460
(202) 382-7062
Dr. G. M. Zemanski
Water Quality Division
Maryland   Department
Environment
201 W Preston Street
Baltimore, MD  21201
of   the
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     APPENDIX B




CASE STUDY SUMMARIES

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                              CASE STUDY - MAY 1988
                           UPPER HUDSON RIVER PCB SITE
                       Mark Brown, New York State Department of
                        Environmental Conservation, Albany, N.Y.
                                    (518) 457-7470
SITE BACKGROUND
1.    Where  is the site  located, how large is  the  site,  and what are the major  environ-
      mental  problems and sources of contamination?

Approximately 200  miles  of the  Hudson River  were  contaminated  by polychlorinated
biphenyls  (PCBs) discharged  by  two  capacitor  factories  in  the  Upper  Hudson  River
Basin.  The  Upper  Hudson River Superfund  site is a 40-mile stretch  of river composed
of a series of pools formed by low-level dams that are part of the Champlain Canal System.


2.    Under what authority is this project being pursued?

The  project  is  currently  being  pursued  under  direct approval  of  cleanup funds  by
Congress (under  the  federal  Clean Water  Act) and  the New York State Legislature for
the  cleanup   of   contaminated   river  sediment,  and  Superfund   remedial  planning  and
cleanup for contaminated soil on the river banks.


3.    What federal, state, and local agencies have either prime responsibility for the project
      or  provide  review  and oversight?   Did  this involvement change  over  the course of
      the project?

Agencies  with primary  responsibility  for  site  investigations,  planning,  and  cleanup  are
the  New York  State Department  of  Environmental  Conservation (NYSDEC), the  New
York Hazardous Waste Siting Facility Board,  and the EPA.


4.    What is the time-frame,  current status, and approximate cost of the project?

Problems with gross contamination of  Hudson  River fish first came to light  in the  early
1970s. Health advisories for consumption of fish from the lower river,  a ban on commercial
striped  bass  fishing,  and  a complete  ban on fishing  in the upper  river  have  been in
effect since  the   mid-1970s.   In  1975, NYSDEC  and  the General  Electric  Corporation
began a  series of  actions  to  reduce  the discharge  of PCBs.    PCB  discharges  were
eliminated  in  1977.    In  1978,  the  exposed  contaminated  riverbank  sediment  deposits
were  stabilized, and  one deposit was  excavated.   During  1977  and  1978,  200,000 cubic
yards of  contaminated  sediment  was  dredged  from  the  Hudson  River  near the  PCB
discharge  point and placed in a clay-lined landfill.   Remediation  of  seven  contaminated
landfill sites is almost complete.

The  original  remedial  plan called  for  dredging  1.5  million  cubic  yards of sediment from
a 40-mile segment of the upper river,  removal of  contaminated  river bank  deposits,  and
transfer  of  previously  dredged  sediment  to  a  secure  landfill  with  a  capacity   of  2.3


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The  original remedial plan called  for dredging  l.S million  cubic yards of  sediment  from
a 40-mile  segment of the  upper river, removal of contaminated  river bank deposits, and
transfer  of  previously  dredged sediment to  a  secure  landfill   with  a  capacity  of  2.3
million  cubic yards.   The cost of  this  plan  was estimated to  be  $40  million.   Due  to
increased  costs  of dredging and disposal  [e.g.,  Resource Conservation and  Recovery Act
(RCRA)-approved  landfill  is  now  required] and the lack  of  additional  funding sources,
the original  remedial  plan  has  been pared down.  There is  a  proposed  project  awaiting
approval  by the  New  York  Hazardous  Waste  Siting  Facility   Board  to dredge  380,000
cubic yards  of the  most  highly  contaminated  sediment from  a 5-mile  segment  of  the
river  and  place  it  in  a landfill.    Dredging  under  the  proposed project is  expected  to
start in  1990, and closure of the landfill is expected in 1991.
SETTING PRIORITIES

1.   What factor prompted the  initial focus on the site?  Why  was this  site given  priority
     over other potential sites in the region?

From the  discovery  of PCB  contamination  problems  in  the early 1970s  to  the  time  of
this  writing,  the  major  factor  of  concern about  the  site  is fisheries contamination  and
related  public health risks.   Both  the  early  discovery  of this  site  and  the extent  of
contamination contributed to its high priority for remediation.


2.   How  were the magnitude and extent of the problem quantified (i.e.,  what factor drove
     the analysis of the problem)?

Large-scale surveying and monitoring  of PCBs in fish and  sediment  began  in  1976 with
funds from a settlement between  the State of New York and General Electric.
3.   What factor drove the selection and implementation of remedial action?

The high PCB concentrations in fish  and the high (flow-dependent) rates of PCB transport
to  the  Lower Hudson River  drove  the  selection and  implementation of  remedial  action
for the river sediment.
4.   Were specific  ranking methods applied  to  different phases  of  this  project?   Which
     methods were used?

The discovery of PCBs in the  Hudson  River during the early 1970s  predates widespread
discovery  and  action  on  problems  of  hazardous  substance  contamination  both  in  the
State of New York  and nationwide.   Through the  1970s  there  was virtually no competition
with other sites,  as the State  of New  York  charted  its own course  toward remediation.
No ranking methods were applied to different phases of this project.


CHOOSING  ALTERNATIVES

1.   Who has formal responsibility for the scoping and final selection of the alternative?

NYSDEC  and the  PCB  Settlement  Advisory  Committee, a  panel of scientists,  engineers.
environmental  activists,  and  public  representatives,  shared  the  responsibility  for  the
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assessment of  remedial options  and the  final  selection  of  dredging and landfilling for
sediment remediation.
2.   What major alternatives were considered?

After completion  of initial  remediation  in 1977  and  1978,  dredging with upland disposal
in a landfill  (with  and  without  treatment)  was  the  major  category  of  action  considered.
Within  this framework,  several  alternatives  were considered,  ranging from  no action to
bank-to-bank  dredging of the Upper Hudson River.
3.   What  procedure was used  to evaluate  the  alternatives  (e.g.,  cost benefit analysis,
     evaluation criteria matrix)?

Mathematical  models  of contaminated  sediment transport  and  PCB bioaccumulation  were
used  in  combination  with technical feasibility  analyses  and  economic  analyses  to  assess
alternatives of sediment removal.
4.   What  alternative  was chosen?  Was there an  overriding regulatory or  programmatic
     requirement that drove the choice of the alternative?

The  current alternative allows only for  the removal of 380,000 cubic yards of contaminated
river  sediment.   This  alternative  was  derived  from  the original  remedial  plan.   Due  to
funding  constraints  and  litigation, this alternative  is  less  comprehensive   than  original
alternatives proposed for the site.
IMPLEMENTING THE ALTERNATIVE

1.   What major legislative  or regulatory constraints were encountered  during the implemen-
     tation of the chosen alternative?

In 1979, Congress  authorized  $27 million for the Hudson River  PCB Reclamation  Project
under  the  federal  Clean   Water Act.    The  project  received  all  necessary  state  and
federal  permits  in  1982.   EPA  endorsed the project in the  Final  Environmental  Impact
Statement but denied the release  of  Clean Water Act  funds, citing the potential availability
of Superfund  remediation   moneys.    New  York  and several environmental  groups  sued
EPA  for  the release  of Clean  Water  Act  funds.   During  this  period,  state permits for
the proposed landfill were overturned in court based  on pressure from  project opponents.
In 1984, a consent order was signed resolving the  suit  brought  against  EPA.   However,
by this time, the project was  faced with 1) new regulations  (i.e.,  RCRA) that  drastically
increased  the cost  of  landfill construction,  2)  the  task of  finding  a  new  disposal site,
and  3) a  decision  by  EPA that Superfund would  only  address remediation of  exposed
river sediment (i.e., river banks).


2.   What regulations were most useful In pursuing action?  How were funds obtained?

Initially, the Clean Water  Act  was  most useful  for securing funds  for site  remediation.
Funds  were obtained via congressional and New York legislative appropriations.
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3.   What  mechanisms were  established  for  communicating with  local  Interests  and  the
     public?  Did public perception of risks affect Implementation of the project?

Local  interests  and the  public  were  directly involved  in  activities  through a  variety  of
mechanisms,  including  the  PCB  Settlement  Advisory  Committee.    Public  perception  of
risks associated with  the  proposed  project were  manifested  in  a successful  legal challenge
to an  earlier  version  of the Project.    Several  methods  of coping with  risk  perception
and conflict of interest on  the part of NYSDEC have been tried.
4.   How long did it take, or is It expected to take, to Implement the alternative?

Dredging  under  the proposed  project  is  expected  to  start in  1990, and  closure  of  the
landfill is expected in 1991.
5.   What criteria were or will be used to measure the success of remediation?

The  goal  for  the  current  project is to achieve a 20  percent reduction in fish  contamination
in the  Upper Hudson River and a  20 percent reduction  in contaminated sediment transport
to the  Lower Hudson River.  These  goals will be compared to empirical  data to  determine
the success of the  project.


6.   How successful was the  alternative in  solving  the  problem  identified during  the
     setting of priorities?

Remediation  has not yet been implemented.
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                               CASE STUDY - MAY 1988
                     NEW BEDFORD HARBOR SUPERFUND SITE
                                    Frank Ciavattierl
                                  U.S. EPA Region 1
                                      Boston, MA
                                    (617) 573-5710
SITE BACKGROUND

1.   Where Is the site located, how large  is the site, and what are the  major environmental
     problems and sources of contamination?

The  New  Bedford Harbor  site  is  located in  southeast Massachusetts.   The site  consists
of over  18,000  acres  of sediments  and  includes the  Acushnet River  estuary  and  the
harbor of  the  city of  New  Bedford.   The  sediment  is  contaminated with  PCBs and
heavy  metals.   Primary  sources  are allegedly  two capacitor manufacturers  in  the area.
There  are  also  wastewater discharges in  the  vicinity.    Since  1979,  the  area  has been
closed  to all  fishing and shellfishing.   Development  of  the  area  has also been  limited.
The site was designated as the top priority site  in the state  of Massachusetts in 1982.


2.   Under what authority Is this project being pursued?

The project has been performed under the authority of the EPA Superfund program.


3.   What federal, state, and local  agencies have either  prime responsibility  for the project
     or  provide review and  oversight?   Did this  involvement change  over the course  of
     the project?

EPA has primary  responsibility for the site.   A number of other state and local  agencies
and  organizations  are  involved  in  review  and  oversight,  including  the  Massachusetts
Department of  Environmental Quality  Engineering (DEQE),  NOAA,  the  Department  of
Fish  and  Wildlife, the  Massachusetts Office  of  Coastal  Zone  Management,  and  the
Massachusetts Department of Health.
4.   What Is th« time-frame, current status, and approximate cost of the project?

The  remedial  investigation  has  been completed.   The feasibility  study  is  in  progress.   It
is expected that the Record of Decision will be finalized in June 1989.

     Cost of RI/FS Study:       $15-18 million (includes pilot study)
     Cost of cleanup:           $20-800 million
                                          B-5

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SETTING PRIORITIES

1.   What factor prompted the initial focus on  the site?  Why was this site  given  priority
     over other potential sites  in the region?

Numerous  studies in the  early  1970s  raised concerns  about  the  site.  The state  requested
EPA to  include  the site on the first Superfund list because of concern  over human  heath
effects associated with seafood  consumption and loss of the area's fisheries resources.
2.   How were  the  magnitude  and extent of problem quantified  (i.e.,  what factor drove
     the analysis of the problem)?

The  magnitude  and  extent  of  the  problem  were  quantified by  chemical  analysis  of
sediments  and  fish  tissues.    No  comprehensive  human  health  effects  study  has  been
conducted.    A  preliminary  survey   of  blood  serum levels   indicated  that  levels  were
elevated in only a few cases. The results of this study are the subject of debate.


3.   What factor drove the selection and Implementation of remedial action?

The  original  concern over the  site was  related  to human  health  effects.   However,  the
loss of the harbor as a resource may  be an equally  important factor driving  future remedial
action.
4.   Were specific  ranking methods applied to different  phases of this project?  Which
     methods were used?

The  site  did not score  high  enough to be  included on  the  NPL  using  the initial  NPL
scoring  criteria.    The  site  was  included  on  the  NPL  using the  state's  discretionary
choice selection.
CHOOSING ALTERNATIVES

1.   Who has formal responsibility for the scoping and final selection of the alternative?

EPA  has primary responsibility  for  the scoping  and  final selection  of  the  alternative.
DEQE has key involvement.


2.   What major alternatives are being considered?

The following types of alternatives  have been reviewed  for possible application to the site:

     -  In situ capping (selected areas)
     -  Dredging-Disposal
     -  Dredging-Treatment-Disposal

Hydraulic  dredging  techniques   that  limit  resuspension  are   considered  the   preferred
removal  technology.    Potential disposal  sites  include  confined  upland,  near shore  (lined
and unlined),  and open-water disposal  sites.    Potential  treatment technologies include
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biodegradation,   solvent   extraction,   supercritical   fluid   treatment,   solidification,   and
dechlorination processes.


3.   What  procedure  was used  to  evaluate  the alternatives  (e.g.,  cost  benefit  analysis,
     evaluation criteria matrix)?

An evaluation criteria matrix  was used  to  evaluate  alternatives  and identify a  preferred
alternative.    Criteria were  based on EPA  interim  guidance  contained  in  the  Draft  of
Guidance  for Conducting  Remedial  Investigations  and  Feasibility   Studies  under  the
Comprehensive  Environmental   Response, Compensation,  and  Liability  Act  (CERCLA)
(March 1988).  Evaluation criteria include the following:

     -  Short-term Effectiveness
     -  Long-term Effectiveness and Permanence
     -  Reduction of Toxicity, Mobility, and Volume
     -  Implementability
     -  Cost
     -  Compliance with applicable or  relevant and appropriate requirements  (ARARs)
     -  Protection of Public Health and the Environment
4.   What  alternative  was  choseo?  Was there an overriding  regulatory or  programmatic
     requirement that drove the choice of the alternative?

A remedial alternative  has not yet been  selected.   Identification of a  preferred alternative
will be based on CERCLA guidance.
IMPLEMENTING THE ALTERNATIVE

1.    What major legislative or regulatory constraints were encountered during  the implemen-
      tation of the chosen alternative?

It  is  anticipated  that  two  conflicting  program  goals  will complicate  selection  of  the
preferred alternative.    CERCLA  guidance  emphasizes  alternatives  that  are  conducted  on
site and  that are  permanent.   Wetland  legislation, RCRA,  and  water quality  concerns
emphasize solutions that do  not impact wetlands.


2.    What regulations were most useful in pursuing action?  How were funds obtained?

The study and related actions are driven and funded by Superfund.


3.    What  mechanisms were established  for  communicating with  local  interests  and  the
      public?  Did public perception of  risks affect implementation of  the project?

A  Community  Workgroup  meets monthly.    Participants  represent  business, fishermen,
the health  community, and  potentially responsible  parties (PRPs)  from  the  city  of New
Bedford and  three other local  communities.  Public perception of risk was more important
at  the beginning of  the  project.    Concerns  were somewhat  allayed   by  the  equivocal
result of the  health effects study.   It  is  not  anticipated that  public perception  of  risk
will affect implementation of the project.
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4.   How long did It take, or is it expected to take, to implement the alternative?

It is anticipated that  it  will take  2-10 years to implement  the  alternative, depending on
the scope of the alternative selected.
5.   What criteria were or will be used to measure the success of remediation?

Criteria  that  will be  used  to measure  success  have  not been established.   A  three-
dimensional hydrodynamic and food  chain model  will be  used to predict compliance  with
ARARs.   Water Quality Standards and FDA  limits on  the concentration of PCB  in  fish
will probably be elements of the criteria.
6.   How successful  was  the  alternative  in  solving  the  problem identified  during  the
     setting of priorities?

The alternative has not yet been implemented.
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                              CASE STUDY - MAY 1988
                       WAUKEGAN HARBOR SUPERFUND SITE
                            Howard Zar, U.S. EPA Region 5
                                    (312) 886-1491
SITE BACKGROUND
1.   Where is the site  located, how large  is  the  site,  and what are the major environ-
     mental problems and sources of contamination?

The  site  occupies approximately  10  acres  of  Waukegan  Harbor  and  portions  of  the
Outboard  Marine  Corporation  (OMC)  property  in  Waukegan (Lake Michigan),  Illinois.
Sediments  of  the  harbor  are extensively  contaminated  with  polychlorinated  biphenyls
(PCBs,  at  concentrations  exceeding  10,000  rag/kg  dry  weight  in  some  places)  from
chronic releases from OMC.
2.   Under what authority is this project being pursued?

The Waukegan Harbor site is a federal Superfund site under EPA lead.


3.   What federal, state, and local  agencies have either  prime responsibility for  the project
     or  provide  review  and oversight?   Did  this  involvement  change over  the course  of
     the project?

EPA has had  prime responsibility for activities at the  site since discovery of contamination
in the  early  1970s.    Other  key  participants  include  the  Corps,  FWS,  NOAA,  Illinois
EPA, Illinois Department of Conservation, and Illinois Department of Transportation.


4.   What is the time-frame, current status, and approximate  cost of the project?

Contamination  of the site  was  first  observed in  the early   1970s.   Several  investigations
have been completed  since  site discovery [including  completion  of  the remedial  investi-
gation/feasibility study (RI/FS)  process].   The  total cost  to  date  of studies, negotiations,
and  remedial  design  is  approximately  $1.5  million.  A Record  of  Decision  (ROD) was
signed  in  May  1984  for cleanup costs  of  $21  million.    The case  has  been in litigation
since  the signing  of  the ROD.   EPA  is currently  negotiating  a  settlement with the  PRP
to initiate remediation.   In  March 1985, EPA  revised  cleanup  estimates  to  $27 million
based on  preliminary remedial  design.    In  OMCs 1986 annual  report to  taxpayers, the
company  listed  $15  million in  environmental liability,  suggesting  that  estimated  cleanup
costs range from $15 to $27 million.


SETTING PRIORITIES

1.   What factor prompted the  initial focus on the site?  Why was this site given priority
     over other potential sites in the region?

This site  was  given  high  priority  for  action  primarily for  two  reasons:   1) very  high
concentrations  of  PCBs  were   present   in  harbor  sediments  (in   some places  exceeding
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10,000 mg/kg), and  2) there was a  city of  Waukegan emergency  drinking water  intake
in the harbor.
2.   How  were the magnitude and  extent of the problem quantified (i.e., what factor drove
     the analysis of the problem)?

PCB  contamination of  sediments  in  the  harbor drove  problem  area  definition.    Data
from   several  sediment  surveys  (surface  sediments  and   sediment  cores)  defined   the
volume  of  contaminated  material  in  the  harbor.    In   addition  to  sediment  surveys,
surface water  and fish  have  been  sampled in  the  harbor,  and  soils  and  groundwater  at
the OMC facility have been sampled.
3.   What factor drove the selection and Implementation of remedial action?

The  preferred  alternative was  selected  primarily because  of cost considerations  for  fund
balancing.   The alternative  selected for  maximum protection  of  human health  and  the
environment  had  an  estimated  cost  of  $75  million.   The  preferred  alternative  is a
modification of this alternative.
4.   Were specific  ranking methods applied to different  phases of this project?   Which
     methods were used?

No  ranking  methods  were  used during  the  course  of  this  project.    Hot  spots  were
identified as areas with sediment PCB concentrations in excess of 10,000 mg/kg dry weight.
CHOOSING ALTERNATIVES

1.   Who has formal responsibility for the scoping and final selection of the alternative?

EPA and its contractor,  FWS,  and  the  Illinois EPA had prime  responsibility for selecting
the preferred alternative.


2.   What major alternatives were considered?

Approximately   75  alternatives  were  considered  for   remediation  in  Waukegan  Harbor.
Alternatives  were  evaluated  for  in  situ remediation,  incineration,  confinement  in  vaults,
and various treatment technologies.


3.   What  procedure was used  to  evaluate  the  alternatives  (e.g.,  cost benefit analysis,
     evaluation criteria matrix)?

Cost/benefit  analysis (including consideration of human  health and  environmental impacts)
was  used  to select  the  preferred  alternative,  with the  final  decision  being  driven  by
fund balancing.  The  area targeted  for remediation was determined based on a combination
of  cost  and  environmental  modeling.    Modeling  indicated  that   natural  resources  and
human health would be acceptably protected with the removal  of all  sediment contaminated
at levels at  or above  100  mg/kg  PCBs.   Participating agencies applied  a  safety  factor
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of 2  to this  estimate, thus  deciding  to  remediate all  sediment contaminated  with  PCBs
at concentrations at or above SO nig/kg dry  weight.
4.   What alternative was chosen?   Was  there  an overriding  regulatory or  programmatic
     requirement that drove the choice of the alternative?

In situ  remediation  was  ruled infeasible early  in the  remedial  evaluation  process.   The
preferred  alternative involves  removal   of  sediment  from  hot  spots,  solidification,  and
disposal at a  facility approved by TSCA; and removal of all  other  contaminated sediment
(i.e,  with  PCBs >50  mg/kg)  and confined disposal on OMC property.   Disposal  on OMC
property  will  consist of  construction  of  1) slurry  walls  to  the  depth  of  glacial  till
hardpan,  and 2) an impermeable cap  over  the  disposal  areas.   Dredging  undertaken as
part  of this  project  will  be  coordinated with dredging in  the  federal navigation channel
by the  Corps, with  the  net   effect  that all  contaminated  sediments (i.e.,  including  those
with <50  mg/kg PCBs) will   be  removed  from  the  harbor.  It is  estimated that  at the
conclusion of  remediation,  more than  99  percent   of  the  PCBs  present  in  Waukegan
Harbor will have been removed.
IMPLEMENTING THE ALTERNATIVE

1.   What  major   legislative  or   regulatory  constraints  were  encountered  during  the
     implementation of the chosen alternative?

Remediation  has not yet  begun in Waukegan Harbor.  The major constraint  to remediation
was  posed by  CERCLA,  which allowed  site access only for  the  purpose of engineering
and  investigation.   CERCLA  amendments  under SARA removed this constraint by allowing
for site access  during remediation.   There have been no constraints to the implementation
of the dredging portion of site remediation.
2.   What regulations were most useful in pursuing action?  How were funds obtained?

Action was first pursued at this site under the federal CWA.   Authority under the CWA
was  ill suited for addressing problems associated with Waukegan Harbor (i.e., contaminated
sediment  and the  type  of source  and contaminant).   Funding  and  the  mechanisms  for
investigating  and  eventually remediating  contamination at this  site  was  offered  through
Superfund (especially SARA for the onsite portion of remediation) and TSCA.


3.   What mechanisms  were  established  for  communicating  with  local  interests  and the
     public?  Did public perception of risks affect implementation of  the project?

Public  involvement during  the  ROD  process  included  distribution  of  fact  sheets  and
several  public  meetings attended  by area residents  and  citizen  groups, the Sierra  Club,
and  Lake  Michigan  environmental  groups.   Public  perception  of  risk  has not  affected
the  project  to  date.    Human  health  risks  from  this  site  were   quantified  during  the
course of study and were generally acceptable to public users.
                                         B-ll

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4.   How long did it take, or is It expected to take, to implement the alternative?

The  alternative  has not yet  been  implemented.   Once  implemented,  it is expected to  be
complete in 2 years.
S.   What criteria were or will be used to measure the success of remediation?

Specifications  for the removal  of sediment  were  determined  based  on the  knowledge  of
the volume (areal extent  and depth)  of contaminated  material.  Performance specifications
will  be  strictly  adhered  to  during   dredging.   Soundings  and  some  additional sediment
sampling  will  be  conducted  after   dredging  is complete  to  ensure  that  the specified
grade lines were achieved.
6.   How  successful  was  the alternative  in  solving  the  problem  identified  during  the
     setting of priorities?

Remediation of contamination in Waukegan Harbor has not yet begun.
                                         B-12

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                              CASE STUDY - MAY 1988
                DREDGED MATERIAL DISPOSAL MANAGEMENT PLAN
                 FOR THE PORTS OF NEW YORK AND NEW JERSEY
              Carol Coch, U.S. Army Corps of Engineers,  New York District
                                    (212) 264-5621
THE SCOPE OF THE PLAN

1.   Define the planning area, and describe  the major environmental problems and sources
     of contamination.

The  planning  area  includes the New York/New  Jersey  Harbor area and  inner New  York
Bight.   The  planning  area  does not  generally  include upstate  New  York  waters  (e.g.,
upper Hudson  River  except  for  those sediments  which  are  ocean-disposed).   Sediment in
the  harbor  areas   are  contaminated  to  varying  degrees  with a  variety  of  chemicals,
including mercury,  cadmium,  DDT, PCBs, and petroleum hydrocarbons.   Major sources of
contamination  include  permitted  discharges,  municipal  wastewater  including a significant
volume  of   untreated  sewage, agricultural runoff,  PCBs from  extensive contamination in
the Upper Hudson River, urban runoff, and atmospheric deposition.


2.   Under  what authority is this project being pursued?

The  project is being pursued under  principal authority of the dredging program  of the
Corps.   The  project  was initiated in  part  by a  lawsuit  filed by  the National  Wildlife
Federation  against   the Corps  to  require  the Corps  to find  alternatives to ocean disposal.
Alternative   analyses  are  also required  under Section  103  of the   Marine  Protection,
Research, and Sanctuaries Act of 1972 (as amended).
3.   What federal, state, and local agencies have either prime responsibility for the project
     or provide review and  oversight?  Did  this  involvement change  over  the course of
     the project?

A steering  committee  provides  guidance  on  technical  and  institutional  issues  and  is
composed  of representatives from the Corps, EPA, FWS, NOAA, New York  State Department
of Environmental Conservation (NYSDEC),  New  York State Department of  State (responsible
for  Coastal  Zone  Management),   and  the  New   Jersey  Department  of  Environmental
Protection (NJDEP).   The Public  Involvement  Coordination Group  (PICG)  also provides
input  to  the  plan and  consists  of  environmental  groups,   community  boards,  labor,
industry, elected officials, and state and local government agencies.


4.   What is the time-frame, current status, and approximate cost of the project?

Development  of the plan has  been underway for  7  years (it  was originally expected to
take  5 years  to  complete)  and  some of  the alternatives  are currently   in  the early
stages  of  implementation.   The  Corps  has spent  approximately $500,000  a year during
plan  development.  A summary report is expected this year.
                                        B-13

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SETTING PRIORITIES

1.   How were key toxic sediment management problems identified?

There  was  knowledge of  sediment  contamination in  the  planning  area  long  before the
program was  initiated.   Sediment management problems  were  identified primarily because
of  two management  needs:   1)  the need  to satisfy  ocean disposal criteria,  and  2) the
need to investigate alternatives to ocean disposal.
2.   How were  the  magnitude  and extent of problems quantified  (i.e., what factor drove
     the analysis of the problem)?

The magnitude and extent of contamination have been identified by a variety of mechanisms:

     •     Many historical studies  by  the  Corps  and others have  surveyed  sediment
           contamination and biological conditions in the study area

     •     Sediment  chemistry  and  biological  testing  take place  on  a  project-by-
           project basis to characterize the material requiring disposal

     •     Under  the  current   planning   effort.  Corps   has  investigated   physical,
           chemical,   and  biological characteristics  of  alternative  aquatic  disposal
           sites and site  economics.

Problem  quantification  and  planning  were  driven  by  the need  to  find  cost-effective,
environmentally  acceptable  disposal strategies  for   dredged  material  (both  contaminated
and uncontaminated).  The principal contaminants of  concern  (Hg,  Cd, petroleum  hydro-
carbons,  PCBs,  and  DDT)  were selected  by consensus  by  the  steering  committee  based
on  their   possible  occurrence  in   the  planning  area  and  potential  adverse  effects  on
marine biota.
3.    What factors would affect the selection and Implementation of remedial actions?

A combination of technical, cost, and institutional factors  continue  to  affect the implemen-
tation of alternative disposal options.  These are addressed by several questions below.
4.    Were  specific ranking  methods  applied  to  different phases  of this  project?   Which
      methods?

Criteria  were  developed  for  each  alternative  studied.    These   criteria  were  used  to
screen the number of sites available for each option  and to define the chemical and physical
characteristics  of  acceptable,  dredged  material.   The primary ranking  method used for
disposal  alternative decision-making consists  of a  combination of chemical  analyses  and
biological  testing.   In  general,  dredged  material is  judged unsuitable  for confined  (i.e.,
capped) ocean disposal if:

      •    Bioaccumulation  of  many  to most  of the  key  contaminants  listed  above
           exceed   "matrix   values"  and   show   statistically   significant   differences
           from reference sediment values (usually  in more  than  one test organism).
           Matrix  values are  derived  as  concentrations of contaminants  typical  of
           a  relatively  clean  (reference)  area  of  the  New  York  Bight  or  of  the
                                           B-14

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           New York/New Jersey Harbor.

     •     Mortality  from  bioassay   tests  exceed  10  percent  difference  between
           reference mortality values.

     •     The  combination  of  bioassay (toxicity)  and  bioaccumulation  testing  as
           compared  with  a  reference  sediment  is  based  on  the  concept of  no
           further degradation.

Ranking  was  also  used  for  evaluating the  alternative  disposal  environments.    Primary
criteria  used  for  these  evaluations  were  cost,  environmental  protection, and ability  to
meet  volume  requirements of the  program.    For example,  500 upland  disposal sites  were
identified at the beginning of  the  planning  process.   This  number has since  been  reduced
to  2  based  on a  number  of  factors, including  transport  costs  and  site   size.    Also,
potential  sites  for containment islands  were  identified  throughout  the planning  area.
Sites  were ranked  based predominantly on  habitat  utilization (another major  consideration
was 20-foot minimum depth).


CHOOSING ALTERNATIVES

1.   Who had formal responsibility for the scoping and final selection of the alternatives?

The responsibility  for  scoping  and selector of  alternatives was  shared by the  Corps  and
all agencies in the steering committee.


2.   What major alternatives were considered?

The major  alternatives  considered  were continued  ocean  disposal  and  monitoring  (at  the
Mud Dump site); ocean  disposal with capping;  small  containment islands near or containment
areas  attached  to land;  large containment islands in the Lower and  Upper  Harbors;  several
upland  disposal alternatives,  including  use of  dredged  material  as  cover   material  for
sanitary  landfills;  subaqueous  borrow  pits  in  which  former  sand  mining pits would  be
filled with contaminated  dredged  material  and  capped with clean material  (digging  new
pits  was  also  considered); wetlands  stabilization;  beach nourishment;  and  other  beneficial
uses.
3.   What  procedure  was  used to  evaluate  the  alternatives (e.g.,  cost  benefit  analysis,
     evaluation criteria matrix)?

Several criteria were  used  to  evaluate  disposal alternatives.   In  general,  decision-making
was  achieved by consensus  building  among  members of the steering  committee.  Technical
feasibility,  potential  environmental  impact criteria,  and  cost  were used in the evaluation
process.


4.   What  alternatives were  chosen?   Were there overriding regulatory  or programmatic
     requirements that drove the choice of alternatives?

The dredged  material  management  plan  consists  of  a  mix of  disposal  scenarios.   In
general,  ocean  disposal  is  the  only alternative  for  large volumes  of dredged  material.
Capping can  also be utilized when  there is concern over  potential environmental  impacts.


                                          B-15

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Disposal and  capping  in  subaqueous  borrow  pits, and construction  of  large  (500  acres)
containment  islands  also  shows promise  for long-term disposal  of contaminated  dredged
material.    The  other  options (upland  disposal,  use  of  dredged  material   as  sanitary
landfill cover, containment  areas  and  islands,  wetland stabilization  areas)  will  be imple-
mented when  institutional and financial  arrangements can  be made.   Finally,  as  a result
of the  plan  studies,  the  New  York  Department  of Sanitation is conducting a  pilot study
for potential  use  of  dredged  material  as cover  for the Fresh Kills landfill.   Section  404
of  the Clean Water  Act  and  Section  103  of the  Marine  Protection,  Research,  and
Sanctuaries  Act of 1972  (as  amended) were  the overriding  programmatic  and  regulatory
requirements  driving  selection  of  alternatives.    Other  regulatory   and  programmatic
requirements  influenced  the planning  process  to  a  lesser degree.   For example,  initial
planning  involved  consideration  of   very  large  (e.g.,  over   1,000  acres)  containment
islands  for  the disposal of  all dredged material.   Some agencies opposed  this  alternative
because it  would  adversely impact  a correspondingly large area  of  habitat  utilized  by
marine  resources.    The  present   version  of  the  containment  island  alternative  (500
acres)  is  designed to  accommodate  the  disposal  of  contaminated  sediment only, for  up
to 20 years.
IMPLEMENTING ALTERNATIVES

1.   What major alternative or regulatory constraints  were encountered during implement-
     ation of alternatives?

The  major  regulatory  constraints  encountered  are  generally  those  imposed   by  state
regulatory agencies for non-ocean alternatives.


2.   What regulations were the most useful in pursuing action?  How were funds obtained?

Section  404 of  the  Clean  Water Act and Section 103  of the Marine  Protection,  Research,
and  Sanctuaries  Act of  1972  (as amended)  enable the  Corps and EPA  to  regulate  and
plan for  dredging and  dredged material disposal  in the New  York/New  Jersey  planning
area.  Funding was appropriated for studies from the Corps Dredging  Program.


3.   What mechanisms were  established for  communicating with  local interests and  the
     public?  Is public perception of  risks affecting implementation of the plan?

A 500-member  PICG provides input to the decision-making process  by representing  local
government,  environmental groups,  community boards,  labor,  and  industry.    Seven vice-
chairpersons  of   the  group  attend  the Steering  Committee  meetings  (held every  six
weeks)  to  provide  input  and  report back  to  members  at the PICG  meetings (also  held
every six weeks).   A  newsletter,  distributed to all  interested  parties before  each meeting
of  the  Steering  Committee, contains general  information  about  progress  with   the  plan
and  related  harbor  activities.   Public   input  has  shaped  decision-making  throughout  the
planning process.   For  example,  some   members  of the public were strongly opposed (to
the point of suing  the State  of  New  York)  to  the use of the  borrow  pits  for dredged
material  disposal  on the grounds  that  this  action  would  result  in the loss  of productive
sport  fishing grounds.   A  compromise  may be  reached whereby  the  creation of  a new
pit is agreed to by the former opponents of this option.
                                          B-16

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4.   How long did it take, or is It expected to take, to implement the plan?

Planning  has  been  underway  since  1981.   Capping  was  implemented as  a management
tool  almost  immediately  with  concurrent  studies  being  performed  on  cap stability  at  the
Mud  Dump site.   Implementation  of certain  aspects of  the  plan is  now beginning.   For
example,  disposal  in  borrow  pits may  begin  soon,  and  sites  have  been   identified  for
containment  islands.    Full  or  partial  plan  implementation  rests  on   identifying local
cooperating  agencies who will  work  towards  obtaining institutional and financial  arrange-
ments  (e.g., for  construction of  containment  islands, subaqueous borrow  pits, containment
areas/wetlands  stabilization areas, beach  nourishment,  and  upland disposal/use  of dredged
materials as  sanitary landfill cover).
5.   What criteria were or will be used to measure the success of the plan?

The  primary  goal  of  the plan was  to  identify  feasible alternatives to ocean disposal  of
dredged  material and  to monitor and  manage  any of the disposal  alternatives  implemented;
this  goal has been met.  This included a  mud dump-site capping  demonstration project
by the  Corps that  proved that contaminated  sediment  could  be disposed of  in  an  ocean
environment  in  an environmentally safe way  (i.e., capping).   This project  involved  the
disposal  of  contaminated dredged material, capping  of  the contaminated  material  with
clean sediment, and  long-term monitoring  for contaminant  migration  and  cap  integrity.
Monitoring over a  period of  several  years  indicated  that  the cap  was structurally  intact
(even after  exposure  to  turbulence  generated  by  a severe  hurricane), and  contaminants"
had not migrated into the surrounding environment.


6.   How  successful  were the alternatives  in  solving  the  problems  identified during  the
     setting of priorities?

Technically   feasible,  cost effective   alternatives  were  developed  for  large  volumes  of
dredged  material disposal in  the  New York/New Jersey Harbor area.   Small containment
islands,  upland  disposal sites,  and wetlands stabilization  were determined  to  be  infeasible
for  regional  dredged  material disposal  because  they  are  unable  to  accommodate  the
large  volumes of  dredged material that  require disposal.   However,  they  may be possible
in special cases or on a project-specific basis.
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                               CASE STUDY - MAY 1988
                 SEDIMENT MANAGEMENT PLANS IN PUGET SOUND
                         Catherine Krueger, U.S. EPA Region 10
                                      Seattle, WA
                                    (206) 442-1287
THE SCOPE OF THE PLAN

1.   Define  the planning area,  and describe the major  environmental problems  and sources
     of contamination.

The  Washington   Department  of  Ecology  (Ecology),   the  Puget  Sound  Water  Quality
Authority (Authority),  and  EPA  Region  10  have undertaken  a comprehensive  effort  to
establish sediment  quality  standards  for  use  in  Puget Sound.    These  standards,  which
will  be  promulgated  through  the Washington Administrative  Code,  will  serve  as  the
basis  for regulatory  decisions concerning  the management, disposal,  and  remediation  of
contaminated sediments.  The planning area  currently  encompasses  Puget Sound, a  large
estuary  in the state  of  Washington.    Following  development  of sediment  standards  for
the sound,  marine and freshwater  sediment  quality  standards  will  be developed for  the
rest of the state.

Puget  Sound sediments  contain   a   variety   of  chemical  contaminants  including  heavy
metals,  PCBs,  and several  other  organic  chemicals.   Contamination  has resulted from  a
variety  of  point  and  nonpoint  sources,   including  municipal  and  industrial discharges,
combined sewer overflows and storm drains, and agricultural runoff.


2.   Under what authority is this project being pursued?

This project is  being  pursued  under the  authority of  the  federal Water Quality  Act  of
1987, the  Washington  Water Pollution  Control Act  (Section 90.48  of the Revised  Code
of Washington), and the Authority (Section 90.70 of the Revised Code of Washington).


3.   What federal, state, and local agencies have either  prime  responsibility  for the project
     or  provide review  and oversight?   Did  this  involvement change over the  course  of
     the project?

Ecology, the Authority, and  EPA Region  10  have prime  responsibility  for the program.
Other  major participants  include  the  Seattle District Corps,   NOAA,  and  Washington
Department of Natural Resources.
4.   What Is the time-frame, current status, and approximate cost of the project?

Efforts  to develop sediment  standards  for use in Puget Sound were  initiated  in earnest
2 years ago.  The first year was  spent evaluating potential  methods for setting  standards,
and  the second  year was  spent  refining  and  validating the  method  selected.   Ecology
intends  to promulgate final standards by the following dates:
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          General Sediment Standards           Interim by 31 December  1988
                                               Final by 30 June  1989

          Effluent Paniculate Limits            Interim by 30 June 1988
                                               Final by 30 June  1989

          Standard for Unconfined Disposal     Interim by Summer 1988
          of Dredged Material                  Final by Summer  1989

          Standard for Confined Disposal        Interim by September 1989
          of Dredged Material                  Final by September 1990

          Remedial Action Guidelines           Final by January  1991.
SETTING PRIORITIES

1.   How were key toxic sediment management problems identified?

Combinations of  the  following four major approaches have been considered for identifying
sediment management problems  in  Puget Sound:   1) a  program  focused on  implementing
best  available   technology   to   control  environmental  risks,   2)   a  sediment  evaluation
system  based  on  controlling risks  to human  health, 3)  an  evaluation  system  based  on-
comparison  of  chemistry  values   with   reference  areas   values,   and  4)  an  evaluation
system based on the occurrence of biological effects.

For  most programs  (e.g.,  urban bays  toxics action plans,  dredged  material disposal  sites,
and  Superfund sites), management  problems have  been  identified based  on an  evaluation
of  sediment  contamination,  observed  and predicted  biological effects, and human  health
risks  associated  with consumption  of contaminated  seafood.   The  significance of  these
evaluations  has  been determined  relative to conditions  at Puget  Sound reference  areas!
Prioritization  of   problems   has  been  reviewed  by  work  groups  or  technical  oversight
committees  composed of agency personnel, citizens  and   scientists  from the community,
and industrial representatives.
2.   How  were  the magnitude  and  extent  of the problem quantified  (i.e.,  what  factor
     drove the analysis of the problem)?

Surveys of Puget Sound by NOAA, EPA, and other agencies in the early 1980s documented
the presence of abnormal benthic communities  and high abundances of tumors  in  flatfish
harvested in  areas  of  high  sediment contamination.    Subsequent  work  has shown  that
sediment contamination in  potentially toxic concentrations  is  widespread  in  many  urban
and industrial areas of the sound.
3.   What factors would affect the selection and Implementation of remedial actions?

Management options are  always influenced  by consideration  of  technological  feasibility
and  cost prior to implementation.   A  variety of other factors  may also influence selection
and  implementation  of remedial  actions,  depending on the  combination  of approaches
used  for  problem  identification, and  the  particular  goals of  the subject  program.   For
remedial actions,  these factors include:
                                          B-19

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     •     The  choice  of  action  levels  based  on  a  range  of  available  sediment
           quality  values  that  can  be  used  to  predict  volumes  of  contaminated
           sediments (lower action levels are protective of a  wide range  of potential
           biological effects;  higher  action  levels  focus attention  on  sites at  which
           a preponderance of evidence  predicts  adverse  biological effects)

     •     Optional  or  required  site-specific  biological testing   to  refine estimates
           based on these predictions

     •     The degree of contamination  by ongoing vs. historical sources

     •     Consideration of  the  potential  for  natural  recovery  over an  acceptable
           time period, and the status of source control actions.

A combination of chemical and biological guidelines has also  been proposed  for determining
the  suitability of  open-water disposal for  dredged material  in Puget  Sound.    Dredged
material  containing  chemicals  at  concentrations  below a  low  chemical  screening  level
would  be  suitable  for open-water unconfined  disposal  without  further  testing.   Biological
testing  would  always  be  required  to  determine  the  suitability  of  material  contaminated
at  concentrations  between  the  screening   level  and  a  much  higher  maximum   level.
Contaminated  material  exceeding  the  maximum  level  would  be  assumed unsuitable  for
open-water unconfined  disposal,  although  a battery of  optional  biological tests could be
conducted  to demonstrate that such material was  suitable.


4.   Were  specific  ranking methods applied to  different phases  of this project?   Which
     methods?

Ranking methods differ based on project  goals,  and methods  used for problem identification.
In  general,  problems  and remedial  alternatives  have  been  ranked  using  a   matrix of
independent indices.   For example,  problem  areas are ranked in urban bay  toxics programs
based on  an  action  assessment matrix.  The  matrix enables comparison of  the elevation
of chemical contamination  and biological effects  among problem  areas relative to reference
conditions.    Biological  indices  include  sediment  toxicity  (e.g.,  amphipod  mortality  and
oyster  larvae  abnormality),  and  observed  biological  effects  in  the  field  (e.g.,  benthic
infauna impacts, fish histopathological disorders,  and bioaccumulation).

Following  problem  area ranking,  additional methods  are  applied  to focus  resources  on
high priority actions.   For  example,  at the  Commencement  Bay  Superfund  site, source
control  remedial alternatives  have been  ranked  into three  categories (high, medium,  and
low  priority) by  assigning a  relative  numerical  value  to  three  criteria for each source
within a problem  area, and  to each  problem area.    The  criteria  include environmental
significance  (e.g.,  spatial  extent  and  magnitude  of  sediment  contamination  attributable
to  each  source),  feasibility  of source  control  (problem  area-wide,  and  for  individual
sources), and status of ongoing source  control efforts.

In combination with  the proposed sediment standards, a  ranking system will be recommended
for application  to  a  sound-wide  inventory  of contaminated sediments.   The system  will
incorporate both  environmental  and   human  health concerns.    Procedures  will  also  be
recommended  for  relating  results  of  this  ranking system   to  existing  hazardous  waste
ranking  systems that  are  primarily focused  on  land-based contamination  and potential
effects on human health.
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CHOOSING ALTERNATIVES

1.   Who had formal responsibility for the scoping and final selection of the alternatives?

Although EPA  was  responsible  for  much  of the  work  that  went  into the  development
and  validation  of  approaches  for   identifying   sediment  contamination  problems  and
evaluating alternative remedial  measures, Ecology  and  the Authority  are responsible for
the scoping and final  selection of state  sediment  quality standards.   EPA will  participate
in a review capacity.   The Washington Department of  Natural Resources  and  the  Corps
were  also partners in  the  development of  strategies  and  standards  for use  in  dredged
material  management.


2.   What major alternatives were considered?

The  four alternative  "conditions" for  site  management  evaluated  for  open-water  dredged
material  disposal sites  are representative of  those  considered  for  Puget  Sound in  general.
These  alternatives  represent  the relative  severity of  potential  biological  effects  to  be
allowed  at  a  site.   Condition  I  would allow  "no adverse  effects"  (i.e.,  no  significant
sublethal, chronic  toxicity  of  any  kind)  at  the   site.    Site  Condition II  would   allow
"minor adverse effects" (i.e.,  some  chronic  but  no significant  acute  toxicity)  at  the  site.
Site  Condition  III  would allow  "moderate  adverse  effects"  (but no  severe  acute  toxicity)
at the site.    Site  Condition  IV  would  allow "major  adverse  effects"  (but  no  dangerous.
waste  defined  by  state  regulations)  at  the  site.   Sediment  management alternatives for
other  Puget Sound  projects all involve establishing  criteria that  define the  alternatives
based on observed or potential biological effects and  human health considerations.
3.   What  procedure  was  used to  evaluate  the alternatives (e.g.,  cost benefit analysis,
     evaluation criteria matrix)?

The methods for problem  identification,  remedial alternative evaluation, and  selection of
sediment  management  alternatives were evaluated based  on one  or more of the  following
procedures:

           Evaluation  of  the  reliability of  sediment  quality  values  used  to  relate
           chemical concentrations and biological effects

           Review of  evaluation  criteria  matrices of  technical  and  cost factors for
           specific remedial actions

           Comparative  analysis  of  environmental   impacts   associated   with  the
           sediment management alternatives
           Comparative cost analysis for implementing the different  sediment  management
           alternatives  for specific programs.
4.    What  alternatives were  chosen?   Were there overriding regulatory or  programmatic
      requirements that drove the choice of the alternatives?

Different sediment  management alternatives  have been or  will  be selected to  meet  the
needs of different programs in Puget Sound, including the following:

      •    Dredged  Material  Disposal  Guidelines:  Guidelines  have  been proposed to
           establish  "minor  adverse effects"  as  the appropriate  sediment management


                                           B-21

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           alternative  for  open-water  disposal sites.   Guidelines are  being  developed
           to  establish  appropriate alternatives  for other  disposal  scenarios  (e.g.,
           open-water confined, nearshore, upland).

           Sound-wide  Sediment   Standards:    Criteria   are   being   proposed   that
           support the "no  adverse effects"  alternative  for  designation  of  a  sound-
           wide sediment inventory  to be managed.

           Remedial Action  Guidelines:  The  specific sediment  management alternative
           for  sound-wide  remedial  action  is  currently  undecided.   The  thrust of
           this developing effort is to establish guidelines  that  will  aid  in decision-
           making,  with  possible  use   of   a  trigger-level  criterion  for  requiring
           particular  remedial actions  such as in  situ capping  or removal and  upland
           disposal  or  treatment.     It  is   anticipated  that  the   trigger-level   will
           reflect  effects-based  sediment  criteria  that  have  been   "cost-modified"
           for technical and  economic feasibility.

           Effluent Permit Limits:  The  sound-wide  sediment  management alternative
           of  "no adverse  effects" will  likely be   integrated into  effluent  permit
           limits  as a  means of supporting  the  sound-wide  goal  over  time  through
           source control and natural burial of contaminated  sediments.
IMPLEMENTING ALTERNATIVES

1.   What major legislative or regulatory constraints were encountered during  implementa-
     tion of alternatives?

No  significant  legislative  or   regulatory  constraints  were  encountered  during   early
development of the sediment quality standards.


2.   What regulations were most useful in pursuing action?  How were funds obtained?

Section  90.70  of the Revised Code of  Washington,  which provided  the  legislative authority
for the creation of  the  Authority and the preparation  of a  Management  Plan for  Puget
Sound, provided  great impetus  to  Ecology for  the development of state  sediment standards.
The  1987  Management  Plan establishes  specific goals for Puget  Sound sediment  quality
and specific deadlines by which  Ecology must promulgate standards.


3.   What mechanisms  were  established  for  communicating  with  local  interests and  the
     public?   la public perception of risks affecting implementation of the plan?

Many  of the  early meetings  in which  the  methods  for developing  sediment  standards
and  consideration  of  sediment  management  alternatives  were  open   to  the  regulated
community.    Public meetings,  workshops,  etc.,  have  been and  will  continue   to be  used
to communicate  with local interests  and  the  public at  large.   An  EIS was  prepared  to
evaluate  potential  ecological  impacts  associated  with guidelines  developed   for  dredged
material  disposal.   Public  advisory committee meetings  and  a  "sediment advisory  group"
will  provide  direction  for the  development  of  state  standards.     Public  perception   of
risks  has affected  the  development  of  sediment standards  in  the  sense that  the public
is demanding that the environmental quality of the sound be maintained and  enhanced.
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4.   How long did It take, or Is It expected to take, to Implement the plan?

All standards,  limits,  and  guidelines are scheduled  to  be developed by  January  1991  (see
Question 4 under Scope of the Plan).
5.   What criteria were or will be used to measure the success of the plan?

A computerized  database is  being  developed  to  store  and  track  information  on  the
extent   and  magnitude  of  sediment   contamination  and  potentially  associated  biological
effects  (e.g., bioassay  results,  species abundances,  histopathology,  and  bioaccumulation)
in the  sound.   This  database  will be  used in combination  with sediment quality  standards,
a planned  Puget Sound Monitoring  Program, and project-related monitoring (e.g., remedial
action  monitoring at the  Commencement  Bay Superfund site)  to:  1) evaluate the success
of ongoing  source   control actions and  sediment  remedial actions,  and  2)  continue  to
reevaluate  the  reliability  of  sediment  standards  (periodic  modification  of  the  standards
is expected).

6.   How  successful were the  alternatives in solving  the  problems identified during the
     setting  of priorities?

Criteria, standards, and limits are still under development.
                                          B-23

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                              CASE STUDY - MAY 1988
                        SULLIVAN'S LEDGE SUPERFUND SITE
                                     Jane Downing
                                  U.S. EPA Region 1
                                      Boston, MA
                                    (617) 573-5708
SITE BACKGROUND
1.   Where is the site located, how large is the site, and what are the major environmental
     problems and sources of contamination?

Sullivan's  Ledge  is  located  in  New  Bedford,   Massachusetts.    The  most  contaminated
portion  of the site  is approximately  12  acres in  size and  includes a former  rock quarry
pit  that was used by  the city of New  Bedford  as an industrial disposal site.   The entire
study area is approximately 270 acres in size  and includes wetlands north of the site.

There  are  three  types of  chemical  contamination on   the site:    Contaminated  soils,
contaminated  sediments,  and contaminated  groundwater.    The  deep   bedrock  aquifer
underlying  the  pit  is  contaminated  with  volatile  organic  compounds.    Groundwater'
contamination  has also infiltrated into a stream  adjacent  to  the  site.   PCB-contaminated
soils in  the vicinity of the  disposal  site have migrated offsite via  runoff  and  contaminated
stream sediments and wetlands north of the site.
2.   Under what authority is this project being pursued?

The project has been performed under the authority of the EPA Superfund program.
3.   What federal, state, and local agencies have either prime responsibility for the project
     or  provide review  and oversight?   Did  this involvement change  over the course of
     the project?

EPA and the Massachusetts  Department of Environmental Quality  Engineering (DEQE) share
primary  responsibility  for the site, with EPA  as  the lead agency.  NOAA  is also  involved
in  review  and  oversight,  primarily  because  of concerns  over  potential  impacts to  the
Apponaganset Swamp, north of the site.


4.   What is the time-frame., current status, and approximate cost  of the project?

The Phase  1  remedial   investigation was completed  in  December  1987,  at a  cost of
approximately $700,000.   The  Phase  2  remedial  investigation  and feasibility  study  are
scheduled for completion in July  1988,  at a total cost of approximately  $900,000.   The
Record of Decision will be completed  by the end of 1988.
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SETTING PRIORITIES

1.   What factor prompted the initial focus on the site?  Why  was this site given  priority
     over other potential sites in the region?

In the  early  1980s,  the  state wanted to build a  parking lot  on  the  site.   Transformers
and  capacitors were  unearthed during  preliminary  excavations.    A  site  investigation was
conducted immediately, and elevated levels of PCBs were found.

The site was not given priority over other sites in the region.


2.   How  were  the  magnitude and  extent  of problem  quantified (i.e.,  what factor  drove
     the analysis of the problem)?

The  characterization  of   groundwater  contamination  was  complex.    The  Phase   1  RI
focused on  the  relationship   between  overburden  and  bedrock,  and  the groundwater flow
regime.  Additional  deep  bedrock wells were  added during  the  Phase  2 RI to refine  the
characterization of  groundwater contamination.  The characterization of soil was  complicated
by offsite migration  and  by  land  use in the vicinity of the  site.   Stream water and  stream
and wetland sediments were analyzed to characterize offsite runoff.
3.   What factor drove the selection and implementation of remedial action?

The  selection and  implementation of  a preferred  alternative  will  be  driven by  CERCLA
guidelines and EPA directives.
4.   Were specific  ranking methods applied  to  different phases  of  this  project?   Which
     methods were used?

The hazardous waste  site ranking system  was applied to rank the site  on the  NPL.   No
other ranking system was applied to the site.


CHOOSING  ALTERNATIVES

1.   Who has formal  responsibility for the scoping and final selection of the alternative?

EPA  and Massachusetts  DEQE have  formal   responsibility  for  the  scoping  and final
selection of the alternative.


2.   What major alternatives were considered?

The following remedial alternatives are being considered for groundwater contamination:

     -  No action
     -  Containment (capping)
     -  Pump and treatment.
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The following remedial alternatives are being considered for soil and sediment contamination:

     - No action
     - Containment
     - Treatment (i.e., solidification, dechlorination, and incineration).
3.   What  procedure  was  used  to  evaluate  the  alternatives  (e.g., cost benefit  analysis,
     evaluation criteria matrix)?

An evaluation  criteria  matrix was  used to evaluate alternatives  and  identify a  preferred
alternative.   Criteria  were  based  on  the National  Contingency  Plan  (NCP)  and  EPA
interim guidance contained in the Draft of Guidance  for  Conducting  RIs  and FSs  under
CERCLA (March 1988).  Evaluation criteria  include the following:

     - Effectiveness (compliance with ARARs)
     - Implementability
     - Cost.
4.   What alternative  was chosen?   Was there an overriding  regulatory  or  programmatic
     requirement that drove the choice of  the alternative?

The  preferred  alternative  has not yet  been selected.    It  is anticipated  that  requirements
of SARA  (i.e.,  treatment alternatives  that provide  a  permanent  solution)   will  have a"
major influence on the selection of the alternative.
IMPLEMENTING THE ALTERNATIVE

1.   What major legislative or regulatory constraints were encountered during the implemen-
     tation of the chosen alternative?

It is anticipated  that the SARA waiver of ARARs  may be  invoked regarding  groundwater
treatment.   Attainment of drinking water  standards  (MCL) using available  pumping and
treatment technologies may be technically infeasible.
2. What regulations were most useful in pursuing action?  How were funds obtained?

SARA amendments  were useful in that  they were  very specific regarding applicability of
ARARs to remedial action implementation.  The Winston Porter directives  from headquarters
helped to clarify EPA policy.


3.    What  mechanisms were  established for  communicating  with  local  interests  and  the
      public?  Did public perception of risks affect implementation of the project?

Until  recently,  there   has  not been  active  public  involvement.   Fact  sheets  have been
sent to the public, and  the  first  public meeting is scheduled for the end of  May  1988.
Public perception of risks has not affected the project thus far.
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4.   How long did it take, or is it expected to take, to implement the alternative?

The  time it  will  take  to implement the alternative  depends  on the  alternative  selected.
Groundwater pumping and treatment could take from 10 to 20 years.
5.   What criteria were or will be used to measure the success of remediation?

Performance standards  will  be  identified  for  groundwater,  and  chemical concentrations
will  be monitored over  time.  Cleanup goals for contaminated soils will be based on  human
health  risk  assessments.     Cleanup  goals  for contaminated sediments  will  be developed
by   relating  water  quality  criteria  to  sediment  concentrations  using  the   concept  of
equilibrium  partitioning.


6.   How successful  was  the  alternative  in  solving  the  problem identified  during  the
     setting of priorities?

The  preferred alternative has not yet been selected or implemented.
                                          B-27

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                              CASE STUDY - MAY 1988
         COMMENCEMENT BAY NEARSHORE/TIDEFLATS SUPERFUND SITE
                    Dave Bradley, Washington Department of Ecology
                                      Lacey, WA
                                    (206) 438-3069

         * Written case study provided as background information for participants;
                             not presented at the workshop


SITE BACKGROUND

1.   Where Is the site located, how large  is the site, and  what are the major environmental
     problems and sources of contamination?

Commencement  Bay is located  in  southern Puget Sound.   Chemical contamination of  the
marine environment  is the major problem  at the  site.   The bay and tideflats are  approxi-
mately 9  square miles  and  12  square  miles,  respectively.  However, the  areal extent of
sediments  targeted  for  remedial action  is less that  1  square  mile.   Commencement Bay
supports  important fisheries  resources, especially anadromous  salmonid  populations.   The.
site  includes contaminated  sediments  in  industrialized  waterways and along the shoreline
adjacent to a former copper smelter and upland sources of contamination.

Discharge   and  dumping  of  solid,  liquid, organic,  and inorganic waste   material  have
contaminated waters and  sediments in major portions  of the  site.   There  are  25 major
identified   sources supplying  metals (arsenic, lead,  zinc,  mercury, copper)  and  organic
contaminants (PCBs,  chlorinated hydrocarbons, PAH compounds).   Facilities  that act  as
contaminant  sources  include a copper smelter,  chemical and aluminum  companies, lumber
and  pulp   mills, petroleum  storage  facilities, ore  unloading   facilities,  shipyards, plating
facilities,  marinas, and  storm  drains.    Historically, raw sewage was  discharged to  the
waterways.  Over 400 potential sources of contaminants have been identified.
2.   Under what authority is this project being pursued?

The  investigation  phase of  the  project has been  performed  under the  authority of  the
EPA  Superfund  program.   Enforcement  and  actions  to reduce  the  ongoing  release  of
contaminants  have  been  pursued  under  a  variety  of  state  and  federal  environmental
laws  including  the Washington  State  Water Pollution  Control  Act  and  the  Hazardous
Waste Cleanup Act.


3.   What federal, state, and local agencies have either prime responsibility for the project
     or  provide review  and oversight?   Did  this  Involvement  change  over  the course  of
     the project?

Prime  responsibility for  the project is shared by EPA and the  Washington  State Department
of  Ecology (Ecology).    Ecology was  delegated the  lead  role in  the  investigation.   A
number of other federal, state, and local agencies and organizations are involved in review
and  oversight, including NOAA, the Washington  Department  of  Fish  and  Wildlife,  City
of  Tacoma,  the  Tacoma/Pierce  County Health  Department,  the  Washington  Department
                                         B-28

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of  Natural  Resources,  Washington  Department  of Fisheries,  the  U.S.  Geologic Survey,
and the Puyallup Indian  Nation.  Ecology is  the lead agency for the majority of enforcement
actions  designed to  reduce  the  amount  of  contaminants being  released  to  the  marine
environment.


4.   What is the time-frame, current status, and approximate cost of the project?

The  remedial investigation began  in  1983  and  was completed in 1985.   The  feasibility
study  will  be  completed  in mid-1988.    Source  investigation  and  characterization  has
been developed,  expanded, and  refined over this period, and source  controls have  been
implemented for some sources and  are scheduled for the near  future  for others.   It  is
anticipated that sediment remedial action will take place  in phases from 1988 to 1996.

     Total cost of the  RI/FS:  $3-53.5 million
     Costs  associated  with supplemental  source  characterization  and  source  control:
           unknown
     Estimated cost of sediment remedial action: $24-564 million.
SETTING PRIORITIES

1.   What factor prompted the initial focus on the site?  Why was this site given priority-
     over other potential sites in the region?

In 1981, Commencement  Bay was listed  on the "interim  priority  list" of  115  sites targeted
for Superfund action.    Initial  focus on  the  site was  prompted  by  concerns  over air
emissions  from  ASARCO, groundwater contamination of the  South Tacoma Channel,  and
investigations  initiated  by NOAA in  1978 that indicated  that chemical  contamination of
the sediments could  be associated with  biological  effects.   Subsequently,  the  groundwater
contamination  in  the  South  Tacoma Channel  was  addressed   under   a  separate  study!
The  Commencement  Bay  project consisted of two parts:   chemical  contamination of the
upland  environment  near  the  ASARCO  smelter, and  chemical  contamination  and  its
effects in  the marine environment.
2.   How were the  magnitude and extent of the  problem quantified (I.e., what factor drove
     the analysis of the  problem)?

The  magnitude  of sediment contamination  was characterized  using  chemical  analyses  and
biological effects  indicators.    Elevation of  chemical  concentration over  reference  area
concentrations  and  the  presence  of  measurable  biological effects  provided  an  indication
of the  magnitude of the problem.   Areal extent of sediment contamination was characterized
by collecting  surface  sediments from  a number  of locations  in  the waterways  and along
the  shoreline.   Vertical extent of   sediment  contamination   was evaluated  by  collecting
sediment cores and analyzing chemicals at various depth  horizons.


3.   What factors drove the selection and implementation of remedial actions?

The  selection  of preferred  alternatives for the nine  major problem  areas in the  study area
is based on EPA  interim guidance contained in the  Preliminary Review Draft of Guidance
for Conducting RIs and FSs  under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) (October  1987).  Evaluation criteria included the following:
                                         B-29

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          Short-term effectiveness
          Long-term effectiveness and permanence
          Reduction of toxicity, mobility, and volume
          Implementability
          Cost
          Compliance with ARARs
          Protection of public health and the environment.

The  original  concern  over  the  site  was  related  to   environmental  and   human  health
effects.   However,  the economic limitations associated  with the Superfund status  of the
site may be an equally  important factor driving remedial action.


4.   Were specific  ranking methods  applied to different  phases of this project?   Which
     methods were used?

Ranking  schemes were applied  to  the  project  at  a  number  of  points  during  problem
characterization.   In  general,  ranking schemes  assigned  a numerical  score to  different
criteria,  and  priority  ranks  were derived  from total scores.    Sediment  cleanup  goals
based  on  the empirical relationship  between biological  effects  and  chemical concentrations
[Apparent  Effects  Threshold  (AET)  values]   were   developed   and  included   in  ranking
schemes at several phases of the project.

During the RI, ranking methods were appl'.ec1 to assign priority to:

     Chemical contaminants (priority 1, 2, and 3)
     Problem areas (high, medium, low).

During the FS, ranking methods were applied to assign priority to:

     Additional source investigations
     Chemicals requiring source control
     Facilities requiring remedial  action
     Problem areas requiring  remedial action.


CHOOSING  ALTERNATIVES

1.   Who has formal  responsibility for the scoping and final selection of the alternative?

Ecology   and  EPA  have   formal responsibility  for  scoping  and  final  selection  of the
alternative.
2.    What major alternatives were considered?

Remedial action  at the  site has  two components:   source control and  sediment  remedial
action.  The following sediment remedial alternatives were evaluated:

           In situ capping
           Dredge and confined disposal (upland, nearshore, and sub-aquatic)
           Dredge,  treatment  (solidification,  incineration,  biological, solvent  extraction),
           and disposal (upland, nearshore, and  sub-aquatic).
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A  large variety of  sources exist on  the  site.    Source control  technologies  considered
for or applied to contaminated facilities include the following:

           Runoff controls (e.g., sedimentation basins)
           Soil capping
           Groundwater pump and treat
           Soil removal and/or treatment.
3.   What  procedure was used  to  evaluate  the  alternative  (e.g.,  cost  benefit analysis,
     evaluation criteria matrix)?

An evaluation  criteria matrix  was used  to  evaluate  alternatives  and  identify a  preferred
alternative  for  each problem area.  Criteria were  based on EPA interim guidance  contained
in the  Preliminary  Review Draft  of Guidance  for  Conducting RIs and FSs under  CERCLA
(October 1987).


4.   What  alternative  was chosen?  Was there an overriding  regulatory or  programmatic
     requirement that drove the choice of the alternative?

Preferred  alternatives  have  not   yet  been  selected.   Availability  of  disposal  sites  has
been  the most difficult  problem to overcome and has  limited  the  feasibility  of  several
potential disposal alternatives.
IMPLEMENTING THE ALTERNATIVE

1.   What major legislative or regulatory constraints were encountered during the  implemen-
     tation of the chosen alternative?

It is not anticipated  that any  major legislative or regulatory  constraints  will be encountered
during implementation  of the  chosen alternative.  Compliance with  ARARs is a  component
of the evaluation process.


2.   What regulations were most useful in pursuing action?  How were funds obtained?

State  and  federal  Superfund  laws and  the State  Water  Pollution  Control  Act  have been
the primary  vehicles for pursuing  action.   Funding  of remedial  action  by PRPs  is  the
preferred option.  However, state and federal Superfund monies are also available.


3.   What  mechanisms  were  established  for  communicating with  local  interests  and  the
     public?  Did public perception of  risks affect implementation of the  project?

A Citizens Advisory Committee  has  been  involved at key  points throughout  the  RI/FS
process.   Fact  sheets  have been  distributed at key project  milestones.   Similarly,  public
meetings  and  project  briefings  have  been  sponsored  by  Ecology  and EPA.    Public
perception of risk has not been a driving force to date.
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4.   How long did It take, or is it expected to take, to Implement the alternative?

It is  anticipated  that  the  preferred  alternatives  (including  source  control and sediment
remedial actions)  will  be  implemented   in  a  phased  manner between  1988  and  1996.
Problem areas  with the  highest priority ranking  will  be  implemented  first  to  ensure
that  the  worst  environmental  problems  (and  associated  threat  to  public  health)  take
precedence.
5.   What criteria were or will be used to measure the success of remediation?

Both  source  loading  and  sediment  concentrations  will  be  monitored   to  ensure  that
cleanup goals are  attained  and  maintained over  the  long term.  Cleanup  goals are based
on  AET.    AET  were  developed during the  RI to relate  biological  effects to  chemical
concentrations.
6.   How successful  was  the  alternative in  solving  the problem  identified  during  the
     setting of priorities?

Not yet known.
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                              CASE STUDY - MAY 1988
                      EVERETT HARBOR DREDGING PROJECT
                    Jim Thornton, Washington Department of Ecology
                                     Olympia, WA
                                    (206) 459-6016

         * Written case study provided as background information for participants;
                             not presented at the workshop
SITE BACKGROUND

1.   Where is the site  located, how large is  the  site,  and what are the  major environ-
     mental problems and sources of contamination?

The  proposed dredging  is  to  take  place  in support of  the  U.S.  Navy  Homeport  project
in Everett  Harbor,  Washington.   Dredging  of  approximately  100,000  cubic  yards  of
contaminated  sediments  will  occur  within  the East Waterway of  Everett Harbor,  which
occupies an  area approximately  1200  meters  long  and 250  meters  wide.   The  site  is
contaminated  with  a  variety   of  chemicals,   including  4-methylphenol,  low  molecular
weight  polycyclic aromatic  hydrocarbons,  resin  acids  (e.g.,  dehydroabietic  acid),  and  to
a  lesser extent,  several chlorinated  phenols and guaiacols  and  PCBs.   Potential  source;
of many  of these contaminants include historical  and  present discharges  from pulp  and
paper  mills.   In  addition,  ongoing  surface  runoff  from storm  drains is  suspected to be
contributing significant loadings of contaminants to the study area.


2.   Under what authority is this project being  pursued?

The  planned dredging is in support of construction of  a Navy  Homeport  for the  aircraft
carrier  Nimitz,  and is  authorized under the National Defense Authorization Act  (NDAA).


3.   What federal, state, and  local  agencies  have either prime responsibility for the project
     or provide  review  and oversight?   Did  this  involvement change over the course of
     the project?

The  U.S.  Navy  has  prime  responsibility  over the  project.   Regulatory  authority  and
oversight  (e.g.,  planning and  permitting)  are  provided  by  the following  agencies:   U.S.
Navy,  EPA, the Corps, FWS,  NOAA, Washington Department of Ecology,  and Washington
State Departments of Natural  Resources,  Wildlife,  and  Fisheries.   The city  of Everett's
role  in shoreline planning  (under  the  Federal Coastal  Zone Management  Act and  State
Shoreline  Management  Act) has increased  since the inception of  the  project.   Everett's
involvement  in  the permitting process  was  recently assured by  the  9th Circuit  Court  of
Appeals in San  Francisco,  which  ruled  that  the  U.S. Navy was  required  to  secure  a
Shoreline  Substantial Development  Permit from the  city  for (among other things) dredging
activities.


4.   What Is  the time-frame, current status, and approximate cost of the project?

It is expected that  dredging and disposal  can be completed  within  24  months.   However,
disposal site monitoring may continue for  an additional  10 years.  The  project is currently


                                          B-33

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awaiting appropriation of  funds  from  Congress.   The  project  is estimated  to cost  in
excess of $25.5  million.   Testing and analysis of  sediment in  the  East  Waterway and  at
the disposal site  is expected  to cost in excess of $1 million; design, engineering,  dredging,
and  disposal  and  capping  of  dredged  material is  expected   to  cost  $17  million;  and
long-term monitoring is estimated  to cost $7.5 million.
SETTING PRIORITIES

1.   What factor prompted the initial focus on  the site?  Why was this site given  priority
     over other potential sites  in the region?

This site  was  favored for citing  a Navy Homeport over other sites  in  Puget Sound and
the west coast of the United States for practical and strategic considerations.


2.   How  were the magnitude and extent of the  problem quantified (i.e., what factor drove
     the analysis of the problem)?

The environmental  problems  and  costs  associated with  the  management  of contaminated
sediments  prompted  the characterization  of the  areal  extent  and depth  of  contamination
and the  determination  of  criteria for  initially  evaluating  the  sediment.    The  criteria
selected  were   those  already   used at another   dredged  material  disposal  site  in  Puget.
Sound  (Four-mile Rock near Seattle).  Based  on  the results of the initial survey,  additional
chemical testing was  recommended for  the contaminated sediment, and  biological  testing
was recommended  for  the   cleaner  sediment  (i.e.,  sediment  meeting  the  acceptability
criteria for disposal  at the Four-mile Rock  site)  and nearshore and open-water disposal
sites.
3.   What factor drove the selection and implementation of remedial action?

Selection  of  a remedial  alternative  was driven by the direct  project  needs (e.g.,  moorage
for  deep-draft  vessels)  and  the evaluation of  testing  procedures for  dredged  material
and disposal sites.


4.   Were specific  ranking methods applied to different phases  of this project?   Which
     methods were used?

Sediments were   ranked  in  two  classes based  on  chemical  and  physical  characteristics.
Chemical and biological testing requirements were developed for  each class of sediment.


CHOOSING  ALTERNATIVES

1.   Who has formal responsibility for the scoping and final selection of the alternative?

Responsibility  for scoping  and  selection of an alternative was shared by  the Navy, EPA,
Corps, Washington Department of Natural Resources, Ecology,  and the city of Everett.
                                          B-34

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2.   What major alternatives were considered?

Three disposal options were considered:  upland, nearshore, and confined aquatic.
3.   What  procedure  was  used  to  evaluate  the  alternatives  (e.g., cost  benefit  analysis,
     evaluation criteria matrix)?

The  options   were  evaluated  based  on  chemical   and  biological  testing  requirements,
design  considerations,  and cost.   The EIS for the  entire  Homeport project presented  an
evaluation  matrix  for  the  three  disposal  options.   The matrix  contained several criteria
that were together considered in the overall rating of each alternative.
4.   What  alternative was  chosen?   Was there an overriding  regulatory  or programmatic
     requirement that drove the choice of  the alternative?

Confined aquatic  disposal  was  chosen  as  the  preferred  alternative.    There  were  no
overriding regulatory or programmatic requirements driving this choice.
IMPLEMENTING THE ALTERNATIVE

1.   What   major  legislative   or  regulatory  constraints   were  encountered   during  the'
     implementation of the chosen alternr.il"??

The major  constraint encountered during selection  of the  preferred  alternative  is  that
state  regulations   do  not  provide  clear  guidance  for  decision-making  involving  the
management of contaminated  sediment.    State guidance  is  much  more  clear  if  sediment
is treated  as an aquatic discharge under the federal  CWA (e.g., state  programs associated
with Section  404  for dredging and Section  401  for  water quality  certification) than  if  it
is treated  as solid  waste  (e.g.,  upland disposal).   If dredged  material  is  treated  as  solid
waste,  state  regulations  give  management authority  to local  health  departments, and  it
is unclear whether a federal facility would be required to  meet local regulations.


2.   What regulations were most useful in pursuing action?  How were funds obtained?

Section  401  of the  federal  CWA (state water  quality certification)  was the  most  useful
regulation  for  pursuing action  during  this project.    Under Section  401, state  agencies
have  the authority to  issue water quality certifications  for  federal  projects  where   there
are  potential  water  quality   impacts.     Ecology   has  the  additional  authority  to   issue
water quality  modifications  for permitting temporary  violations  of ambient  water quality
criteria   (e.g.,  during  dredging  and/or  disposal  operations).    Both  regulatory  tools are
useful  because regulatory  compliance  can be conditioned  on  a variety of  factors.    For
example,  the  water  quality  certification  issued to  the   Navy  for  this  project  included
pass/fail  performance standards  for  the  capping  operation.    These  standards  will   allow
Ecology  to  temporarily  or  permanently halt disposal activities  if  a number of circumstances
arise  (e.g.,  inaccurate placement  of  cap  material  or  excessive  migration of contaminants).
In  addition,  a  comprehensive  monitoring  program  is included  as  a  condition  of the
water quality certification  and  allows Ecology to  require a variety of actions if unacceptable
adverse impacts are detected after the disposal is complete.
                                           B-35

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3.   What  mechanisms were  established  for  communicating with  local  interests  and  the
     public?  Did public perception of risks affect implementation of the project?

Several  public  involvement  and  participation  mechanisms  have  been  used  during  the
course of  this  project, including  1)  scoping,  hearings,  and  public  information  meetings
that  were  conducted  as  part  of the  federal  and state HIS  processes;  2)  public  hearings
that  were  a  part of  the  401  Certification  process;  and 3)  public hearings  by  the state
legislature.   Public  perception  of risks  and concern over  potential environmental  impacts
primarily  affected the project  by  increasing  the emphasis  on biological  impacts  during
dredging  and  disposal and after cap  placement.   For  example,  monitoring  of  the  sea
surface  microlayer  was   incorporated   into  the  water  quality  certification  to   address
public concerns.
4.   How long did it take, or Is it expected to take,  to implement the alternative?

Dredging  and  placement  of   dredged  and  cap  material  is  expected  to  take  2  years.
Long-term monitoring may occur over an additional 10-year period.


5.   What criteria were or will  be used to measure the success of remediation?

A comprehensive,  long-term monitoring  program has  been designed  to  determine whether
contaminants  from  the  disposal  site  are  adversely  affecting  marine  biota.    Monitoring
includes  testing  for  the  migration  of contaminants, migration  of contaminated sediment,
bioaccumulation, benthic  impacts,  and  water quality impacts.   The monitoring  program
is designed to phase out some  components  over time if results indicate  a low  probability
of impacts.   Additional long-term  monitoring is required at the dredging site  to  ensure
that sediments do not become recontaminated.
6.   How successful  was the  alternative in  solving  the problem  identified  during  the
     setting of priorities?

The alternative has not been implemented.
                                          B-36

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                              CASE STUDY - MAY 1988
                      PORT OF OAKLAND DREDGING PROJECT
                             Pat Cotter, U.S. EPA Region 9
                                   San Francisco, CA
                                    (415) 974-0257

         * Written case study provided as background information for participants;
                             not presented at the workshop
SITE BACKGROUND

1.   Where is the site located, how large is the  site, and what are  the major environmental
     problems and sources of contamination?

The  Port  of Oakland  is  located  in  San Francisco Bay  adjacent  to  the city  of Oakland.
The  Port  of  Oakland  determined  that  dredging  was  needed  to  allow  access  to  larger
vessels and to expand the economic capabilities of  the port.

Heavy  metals,  PAH, and  tributyltin are  present  at elevated concentrations  in some of
the sediments designated to  be dredged.   The contamination is  attributed  to  shipyards-
and heavy industry situated near the harbor.

Dredging  is  to  be  conducted  in  two  phases.    In  Phase  1,  the inner  harbor will be
dredged from its current depth  of -35  feet to  -38  feet.   This will involve the removal
of approximately 560,000 cubic yards of sediment.   In Phase 2, the inner and outer  harbors
will  be dredged to -42 feet.   This will  involve the movement of  approximately 7,000,000
cubic yards of sediments.
2.   Under what authority is this project being pursued?

The Port of Oakland project is being pursued under Section  103 of the Ocean Dumping Act.


3.   What federal, state, and local  agencies have either prime responsibility for the project
     or  provide  review  and oversight?   Did  this involvement change  over  the course of
     the project?

Prime  responsibility for  the project is  shared  by federal  Corps  and EPA, state (California
Regional Water Quality Control Board and San Francisco Bay Conservation and  Development
Commission), and local (Port of Oakland) agencies and organizations.

Project review also  involves other  federal (Fish and Wildlife  Department, National Marine
Fisheries) and state agencies (California Fish and Game Department).

Involvement has not changed over the course of the project.
                                         B-37

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4.   What is the time-frame, current status, and approximate cost of the project?

Phase  1  dredging is expected  to  begin in May  1988 and  last approximately  1.5  months.
Phase  2 dredging  is  expected  to  begin  in  September  1988 and last  approximately  18
months.   It  was originally  thought that  all  of  the dredged  material (Phase  1 and Phase
2) could  be disposed  of at an  open-water  unconfined  site, at a  total cost of  S30-S50
million.   It has  been determined  that  the more  severely contaminated  sediments  must be
disposed of at  upland facilities.  The added costs associated with  the  option have  not been
determined.

Harbor sediments have been  sampled for physical,  biological,  and  chemical  characterization
on three separate occasions.   The cost of the  first two  studies  is not  known.   The  cost
of the  third is estimated to be between $300,000 and $400,000.
SETTING PRIORITIES

1.   What factor prompted  the initial focus on  the  site?  Why was this site given priority
     over other potential sites in the region?

The  Port  of Oakland  and the  Corps  determined  that the  port  should  be   dredged  to
expand economic capabilities and make it  more competitive with other west coast ports.


2.   How  were the magnitude  and extent of the problem quantified (i.e., what  factor drove
     the analysis of the problem)?

There  were  concerns  that  sediments   to  be  dredged  were  contaminated  and  that   the
process of dredging and disposal could threaten human health and the environment.

Physical,  chemical,  and  biological  properties  of  the  sediments  were  characterized   to
define the  extent of  sediment  contamination.    Physical  characterization  included grain
size,  density,   and  plasticity  of   the  sediments.    Chemical   characterization  included
conventional  analyses and a  reduced list  (approximately  60  chemicals)  of EPA priority
pollutants.  Biological characterization included toxicity and bioaccumulation testing.


3.   What factor drove the selection and implementation of remedial  action?

Ocean dumping regulations  do  not allow  toxic  sediments  to  be  dumped  in  the  open
ocean (40 CFR 227).
4.   Were specific  ranking methods applied to different  phases of  this project?  Which
     methods were used?

The relative  toxicity of  sediments  was  ranked on the  basis  of the  toxic  response of
biological indicators, the relative magnitude  of  chemical concentrations, and by comparison
with other sites.
                                          B-38

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CHOOSING ALTERNATIVES

1.   Who has formal responsibility for the scoping and final selection of the alternative?

The  Corps  evaluates applications  and  authorizations  for  dredged  material  permits  under
Section  103 of the Ocean  Dumping Act (40 CFR Part  225.1).  The  Regional Administrator
of EPA  receives specific  permit  information  from  the  Corps (40 CFR  Part 225.2(a)] and
makes  an independent  evaluation  of the proposed dumping  [40  CFR Part 225.2(c)].   As a
result  of  this  independent evaluation,  the  Regional  Administrator  determines  whether
the proposed  action complies with  the requirements of the  Ocean  Dumping  Act [40 CFR
Part  225.2(d)  and (e)].   If the material does not comply, the  District Engineer ma;y not
issue a  permit unless:  1)  a determination  is accepted  by  the Chief of  Engineers that  no
economically  feasible  alternatives  exist,  and  2) a waiver  of  EPA's  criteria   is  sought
from  the EPA  Administrator.   The  Administrator  has 30  days to act  on  the  Chief  of
Engineer's  request  (40  CFR Part 225.4).   If upland  disposal is chosen over other  open-
water or nearshore alternatives,  the  state of  California  is  responsible for selection  of
the disposal alternative.

2.   What major alternatives were considered?

The following removal/disposal option were considered:

           Unconfined ocean dumping (in bay, out of bay, off the continental  shelf)
           Upland disposal.

Treatment alternatives were not considered.
3.   What  procedure was  used  to  evaluate  the  alternatives (e.g., cost  benefit  analysis,
     evaluation criteria matrix)?

Neither approach was  used  to evaluate  the  alternatives.   Alternatives  were  selected  on
the basis of ocean dumping  regulations (40 CFR 220-229) and the EPA/Corps Implementation
Manual for Ocean Dumping  (1977).
4.   What  alternative  was chosen?   Was there an overriding  regulatory  or  programmatic
     requirement that drove the choice of the alternative?

Phase  1  dredged material that is  suitable for open ocean dumping will be  dumped at a
site  24 miles south  of the  bay,  near  the  Golden  Gate  ship  canal.   Neither  the upland
disposal alternative nor the open ocean dumpsite for Phase 2 material has  been selected.
IMPLEMENTING THE ALTERNATIVE

1.   What major legislative or regulatory constraints were encountered during the implemen-
     tation of the chosen alternative?

No major legislative  or regulatory  constraints  were  encountered;  however,  litigation  has
become an  issue.  Fishermen from  Half  Moon Bay have  filed a lawsuit against  the  Port
of Oakland and Corps to block dumping at the selected disposal site.
                                          B-39

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2.   What regulations were most useful In pursuing action? How were funds obtained?

Ocean  dumping regulations  and NEPA  regulations  are  the  most  pertinent to the  disposal
site.  Section  401  of  the  federal CWA and Section 307c of  the  Coastal Zone Management
Act  are  applicable at dredging  locations.   The  Port  of Oakland  will  pay for 25  percent
of the total project cost and the Corps will pay  for 75 percent.


3.   What  mechanisms were established for communicating  with local  interests and  the
     public?  Did  public perception of risks affect Implementation of the project?

A Dredged Material steering Committee includes  representatives  from  local,  federal, and
state  agencies  and  the  public.    Public  views  were  also  presented  during the  public
comment  period  and  during public hearings.   Public perception  of risks  played a major
role in the selection process.


4.   How long did It take, or is it expected to take, to implement the alternative?

Phase 1  dredging is expected  to begin in May 1988 and last approximately 1.5 months.
Phase 2 dredging is expected to begin in September 1988 and last approximately 18 months.
Monitoring of the  dump site after dumping will be conducted for 1  year.
5.   What criteria were or will be used to measure the success of remediation?

The  goal  of the project  is  not  remediation but  the environmentally protective  implemen-
tation of  dredging for economic purposes.   No formal criteria  exist; however,  monitoring
of the dump site  will be conducted and will  probably  involve  measurement of the same
parameters used to characterize the sediment before dredging.


6.   How successful  was  the  alternative  in   solving  the  problem  identified during  the
     setting of priorities?

The alternative has not yet been implemented.
                                          B-40

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             APPENDIX C

OVERVIEW OF MAJOR LAWS AND REGULATIONS
      CONCERNING THE MANAGEMENT
      OF CONTAMINATED SEDIMENTS

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       MAJOR POTENTIAL FACILITATING AND CONSTRAINING ASPECTS OF
        SELECTED ENVIRONMENTAL LAWS AND REGULATIONS RELATING
                          TO SEDIMENT REMEDIAL ACTION
     The   following  discussion  provides  a  summary  of  general   relationships  between
major  environmental  laws (and associated regulations) and  four major  sediment remedial
action/cleanup activities:

     •     Problem Identification:    Includes  activities such  as  environmental surveys
           (e.g., sediment  chemistry,  benthic  infauna  effects,  and  bioaccumulation),
           human   health  risk  assessment,   and  programs  to  determine  suitable
           action or cleanup levels (i.e., sediment criteria).

     •     Sediment   Removal:    Refers  to  activities  (nearshore   or   open-water)
           associated with dredging or excavation of contaminated sediment.

     •     Sediment Disposal:   Includes the transportation  and disposal of contaminated
           sediment in a  variety of environments and under a  number of conditions,
           for example:

                Upland,   nearshore   intertidal,   nearshore   subtidal,   or   open-water
                environments

                Unconfined (i.e., material deposited is not isolated from the surrounding
                environment)  and confined (e.g., excavation/disposal,  dikes, capping,
                or landfilling) conditions.

     •     Habitat Restoration:  Includes a variety of activities in upland, nearshore
           and  open-water environments.   Activities can  range  from  creation  of
           intertidal  habitat (e.g., salt marsh) to  restoration of  open-water  disposal
           area to natural conditions (e.g.,  matching of slope and native  material).

Brief  summaries  of  major  environmental   laws  and   regulations   relevant  to  sediment
remedial action are  presented  in  Table  C-l.    General relationships between laws  and
regulations   and major activities  of  sediment  remediation  are  illustrated  in  Figure  1.
The  remainder  of  this  paper  provides brief  explanations of the  relationships depicted in
Figure  1,   and presents   a  summary evaluation  of  the  major  constraints  of  existing
environmental laws and  regulations  (in  terms of implementing  sediment remediation)  and
potential mitigating measures.


CLEAN WATER ACT (AS AMENDED BY THE WATER QUALITY ACT OF 1987)

     The   Water Quality  Act  of 1987  and  its precursors  (e.g..  Federal Water Pollution
Control Act  Amendments  of   1972-1980)  establish  a  number of  programs  designed  to
restore  and  maintain the  physical,  chemical,  and  biological  integrity  of  the  Nation's
waters.
                                         C-l

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          TABLE C-l. EXAMPLES OF MAJOR ENVIRONMENTAL LAWS AND
           REGULATIONS RELEVANT TO SEDIMENT REMEDIAL ACTIONS
          Law
                      Purpose
Clean  Water Act  as amended
by  the Water  Quality  Act of
1987 (CWA)

    Section  104
    Section  105


    Section  108


    Section  115



    Section  117


    Section  118
    Section 304(a)



    Section 314


    Section 401



    Section 404
Establishes  authority  to  restore  and  maintain  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.
Establishes  a   grant  system   for   research
development projects on contaminant sources.
and
Establishes  demonstration  projects  for  mitigating
pollution in the Great Lakes.

Provides authority  to identify  the location  of  in-
place pollutants  with emphasis  on toxic pollutants
in harbors and navigable waterways.

Provides for  continuation  of the  Chesapeake  Bay
program.

Requires annual  reports  on  the  status of pollutants
in sediments  of the Great  Lakes,  and establishment
of  a 5-year  study and  demonstration project  for
the removal of sediments with toxic pollutants.

Authorizes development  and  publication of  criteria
reflecting the scientific knowledge  on the environ-
mental effects of pollutants.

Establishes  a  Clean  Lakes  Program  and  water
quality demonstration programs.

Requires  state water  quality  certification  for  any
project  that  may  result  in  the violation  of  a state
water quality  standard.

Establishes permits  for  discharge of dredged  or
fill material into navigable waters of the U.S.
                                          C-2

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TABLE C-l. (Continued)
           Law
                      Purpose
Marine Protection,
Research, and Sanctuaries
Act (MPRSA)

    Section  102
    Section  103
Coastal Zone Management
Act (CZMA)
Superfund Amendments and
Reauthorization Act (SARA)
Resource Conservation and
Recovery Act (RCRA)
Toxic Substances
Control Act (TSCA)
National Environmental
Policy Act (NEPA)
Provides  authority  to   regulate  the   transportation
for  dumping  and  the  dumping of   material  into
ocean waters.

Authorizes dumping permits for sewage  sludge and
industrial  wastes.

Authorizes permits  for the transportation  of dredged
material  for the  purpose of  dumping  into ocean
waters.
Establishes  a  framework and   matching  grants  for
states  to  develop  and   implement  a   Coastal Zone
Management Plan. Local governments develop Shore-
line Master Programs in participating  states.

SARA  amends   the  Comprehensive  Environmental
Response  Compensation  and Liability Act (CERCLA)
on a number of programmatic and enforcement/judicial-
issues, and  establishes  new  programs  and  funding
levels.  The new provisions include the requirement
to evaluate  all  facilities  on CERCLIS (as  of  date
of enactment) with  HRS  within 4 years  of enactment;
this  provision  may have  the  effect of altering  the
present  ranking  of sites.   CERCLA  establishes  a
fund  and  comprehensive  program  for identifying,
investigating,   and  remediating  hazardous   waste
sites and recovering costs from responsible parties.

Authorizes  efforts  to  promote the  protection  of
human health  and  the 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.    Includes  provisions
and  guidance  for establishing  and  permitting solid
waste disposal facilities.

Authorizes  regulation  of  chemical  substances  and
mixtures  that   present  an  unreasonable  risk   of
injury to  health  and  the  environment (especially
PCBs  and  dioxin).    Authorizes   development  of
testing  methods  including  toxicity   testing,  and
development of priority list under Section 4(a).

Requires  the   preparation   of  an   Environmental
Impact  Statement  (EIS)  for  projects  deemed  to
cause significant adverse impacts.
                                         C-3

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TABLE C-l.  (Continued)
           Law
                      Purpose
Regulations for Hazardous
Materials Transport
Occupational Safety and
Health Act (OSHA)
National Ocean Program
Act (NOPA)
Floodplain Management
Wetlands Protection
Establishes  requirements   and  restrictions  for  the
transportation   of   hazardous   materials  on  federal
highways.

Establishes safety   requirements  for  workers  in the
workplace, including maximum  exposure times and
concentrations for numerous hazardous substances.

Confers  authority   to coordinate  pollution programs
among  the  federal  agencies  involved   in  marine
research, monitoring, and regulations.
Establishes   requirements
projects in floodplains.

Establishes   requirements
projects in wetlands.
and    procedures    for


and    procedures    for
                                          C-4

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                            FIGURE C-l.   FACILITATING AND CONSTRAINING ASPECTS OF SELECTED
                   ENVIRONMENTAL LAWS AND REGULATIONS RELATED TO SEDIMENT REMEDIAL ACTION
   Section 304(a)
CWA
   Section 104
   Section 105
   Section 108
   Section IIS
   Section 117
   Section IIS
   Section 304(a)
   Section 314
   Section 401
   Section 404
MPRSA
   Section 102
   Section 103
CZMA
SARA
RCRA
TSCA
NEPA
Regulations for
Hazardous Materials
Transportation
OSHA
OPA
Floodplain Management
Wetlands Protection
Local Land Use
Ordinances
                                           Funding support.
                                           Administrative support.
                                           Action/land use planning support.
- Chemical limits.
- Design/construction limitations.
- Site availability constraints.

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Section 104

     Section  104  establishes  national  programs of  research,  investigations,  experiments,
training,  and  information  exchange  for  the  prevention,  reduction,  and  elimination  of
pollution.   Activities  under  this  section  can  primarily  facilitate  problem  identification
and  sediment  removal and disposal  by  providing  funding  support  for  investigations that
can contribute to the state  of knowledge about fate and effects of contaminated sediment.
Section 105

     Section  105  establishes  a  grant  system  for  research  and  development  projects,
including  projects   on  advanced  waste  treatment  methods  for  contaminant   sources.
Demonstration  projects  include  investigations  of  in place  or  accumulated  sources and
methods for confining  these  sources  or otherwise preventing  the migration  of pollutants
into the  environment.   Funding support  for  facilitating  the development  of techniques
for  sediment removal  or  disposal  (e.g., confined  disposal)  is  also  potentially  provided
under this section.
Section 108

     Section  108 establishes demonstration  projects for  mitigating  pollution in  the  Great
Lakes.   Section 108(d)(2)  delegates  responsibility  to  the Corps to develop a  demonstra-"
tion waste  water  management program  for  Lake Erie.   This  program  should include
measures  to control  sources including in place  sources, bottom loads,  sludge  banks,  and
polluted harbor  dredgings.

     Significant support to  programs  in  Lake  Erie may be  provided  under  Section  108
for  the  identification  of  problem  areas,  sediment  removal  and disposal,   and  habitat
restoration.  However, the program is constrained to Lake Erie only.
Section 115

     Section 115 of the Water Quality Act of 1987 provides EPA with authority  to identify
the  location of contaminated sediments  and  (in cooperation  with the  Army  Corps  of
Engineers) take action  for sediment removal.  The emphasis of the program is on sediments
in harbors  and navigable waters that are contaminated  with toxic pollutants.   Section 115
primarily influences  sediment  remedial  actions  by  providing funding,  administrative,  and
planning support for problem identification.  As  the  program develops, it  may also provide
funding, administrative, and planing support for the removal of contaminated sediments.
Section 117

      Section  117 of  the Clean  Water Act of  1987 provides for  the  continuation  of the
Chesapeake  Bay  program.    To  the  extent  that   the  program focuses  on  contaminated
sediment,  it  can provide  support in  the  form of  funding,  program  administration,  and
planning,  primarily  relative  to  problem  identification.    Sediment  removal  and  disposal
actions may  also  be facilitated  by  the program,  but  are not specifically  called  out  in
the  Act.   Habitat  restoration  may  be  facilitated  by  the  program  to  the  extent  that
removal of contaminated  sediment takes place.
                                           C-6

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Section 118

     Section  118  of the  Water Quality Act of  1987 establishes the Great  Lakes  National
Program Office  and  assigns  it  a  variety  of  responsibilities,  including: yearly  reporting
of  environmental  conditions,  comprehensive   monitoring,  interagency  and  international
coordination,  and  establishment  of  programs  for  reducing  point  and  non-point  sources
of  contaminants   and  conducting   5-year   demonstration  projects  for  identifying  and
remediating contaminated  sediments.  Six areas are identified as priorities for demonstration
project implementation.

     Section  118  can  potentially  facilitate  problem  identification  and  sediment  removal
by providing  support  through demonstration projects in  the form of funding, administrative
support, and  planning support.   Similarly,  the  Great Lakes  program can facilitate habitat
restoration by the removal of contaminated sediment.

     By potentially  limiting  the  development  of demonstration projects  to priority  areas
identified  in  the Act,  Section 118 may constrain problem  identification,  sediment  removal,
and habitat restoration in other potentially contaminated areas.


Section 304(a)

     Section  304(a)  delegates  responsibility  to  EPA  for  developing water  quality  criteria
based  on  the  latest  scientific  knowledge  about  biological  effects of  pollutants  at  the
individual  and  community level,  and  the  environmental, concentration  and  dispersal of
pollutants.   Sections  301(a)(7)  and  301(aX8)  were  added  by   the  Water  Quality  Act of
1987  and  specify  technical  assistance  to  states  on  how  to  develop  and  measure   water
quality criteria.

     Section  304(a)  primarily facilitates problem identification through  the furthering of
knowledge about pollutant fate and effects.
Section 314

      Section  314  establishes  a Clean  Lakes  program to  identify  contamination problems
in lakes,  identify  sources of  pollution,  and investigate and implement  mitigation  measures.
Section 314(d) requires EPA  to establish and conduct a  Lake Water Quality Demonstration
Program,   including  programs  to  demonstrate   environmentally  preferred  techniques  for
the  removal  and  disposal  of contaminated sediments,  and  demonstrate  the  costs  and
benefits of using dredged material for land reclamation.

      Section  314  facilitates   the  identification  of  problem  sediments,  development   of
techniques  for  sediment  removal  and  disposal, and habitat  restoration,   by  providing
support in the form of funding, program administration, and planning.   Sediment remedial
support under Section 314  is limited to lakes.
Section 401

      Section  401  requires  State Water Quality  Certification  for  any  project  that  may
cause  the violation  of  a state water  quality  standard.    Section  401  may offer  action
planning  support  for  sediment  removal  and  disposal  activities  and  habitat  restoration


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activities  by  offering  a  degree of  predictability  to the  planning  process  (i.e.,  a priori
documentation of limitations that may be  imposed  on a  project).    Section 401  constraints
will  be  manifested  primarily  as  limitations  on  design   and  construction  (for sediment
removal  and  disposal)  and site availability  (for  sediment  disposal).    The  severity  of
these constraints  will  probably  tend  to  increase with  an  increase  in  the likelihood  that
state  water  quality  standards  may  be   violated.    Sediment  removal  and  disposal  and
habitat  restoration activities  may be precluded  if they  are deemed  to result  in significant
violations  of  state  water  quality  standards  (determined  by  the  state  on  a case-by-case
basis).
Section 404

     Section 404  of the Clean Water Act of  1977 provides authority  to  the Corps  to issue
permits  for  the  discharge  of dredged or  fill material and  designation of  disposal  sites
in  navigable  waters of the  United  States  (including  nearshore  fill  sites). EPA  provides
an  important  role  in  the  process  by assisting  the Corps  in  developing guidelines  for
disposal  and  material  testing.    In  addition,  EPA  may   prohibit the  disposal of  some
materials under  certain  conditions, and  is  responsible  for determining  areas  that  can  be
used for disposal sites.  Section 404  regulations include:

     •    Criteria for compliance with guidelines for dredged material disposal

     •    Guidelines for the evaluation and  testing of dredged  material

     •    Specifications for actions to minimize adverse effects

     •    Requirements for obtaining state  water quality certification for the disposal
           of dredged material.

     Section  404  programs  have   the potential  to  contribute  administrative  support  to
problem identification  via  requirements for testing sediment.   To  the  extent  that contami-
nated  sediment  has  been identified for removal during a dredging project (e.g., maintenance
of  navigational  channels or new construction), Section 404  may  also provide  administrative
support  to sediment removal  efforts.   For  example, at the Commencement Bay Superfund
site, planned maintenance  and  construction  dredging  will be  coordinated  with sediment
removal in order to  maximize the efficiency of remedial actions.

     Section  404  guidelines  and  regulations   may constrain  sediment disposal  options  by
precluding  the  disposal of sediment at  certain sites  or  under  certain  conditions  (e.g.,
because  of  elevated  contaminant   concentrations or  other  factors).    Wetland  protection
policies  and regulations of the  Corps can  facilitate  habitat  restoration  to  the  extent that
mitigative  measures  are incorporated  into  404 permits.   Mitigative measures  may  include
habitat creation or restoration,  or in-kind replacement (i.e.,  purchase of  wetland habitat
for placement into public trust).


MARINE PROTECTION,  RESEARCH, AND  SANCTUARIES ACT (MPRSA  OR  OCEAN
DUMPING ACT)

     The  MPRSA  provides  authority  to  regulate  the   transportation  of   material  for
ocean  dumping, ocean  dumping activities,  and  the  designation  and maintenance of  ocean
disposal sites.
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Section 102

     Section  102  establishes a  permit  system  for  the  ocean  disposal  of sewage  sludge
and  industrial  waste,  and  the  designation  and  maintenance  of  disposal  sites.    The
disposal permit regulations establish  criteria for evaluating permit applications.  Environmen-
tal  impact  criteria  include  evaluation  procedures,  prohibited constituents, and limitations
on  the  disposal of  specific wastes.   Disposal site  management  criteria include procedures
for designating sites,  evaluating  impacts,  monitoring  disposal  practices,  and  conducting
baseline  surveys.   Section  102 can facilitate sediment remediation  primarily  through  the
designation  of potential disposal  sites.   However,  requirements for  testing and  approving
materials may pose constraints on disposal in some cases.
Section 103

     Section 103  authorizes EPA  review of Corps permits for the transport and  disposal
of dredged material,  including  review of  site designation  rationale if a proposed site  is
not  a  designated  site  under  MPRSA.    Administrative  and  planning  support   for  the
removal  and  disposal  of contaminated  sediment  (e.g.,  by  providing alternative  disposal
sites) may  be  provided  under  Section  103; however  it  may  pose constraints  to  disposal
under some conditions because of limitations  on  chemical constituents and site availability.
COASTAL ZONE MANAGEMENT ACT (CZMA)

     The CZMA  establishes a national support program  for states to develop and  implement
a Coastal Zone  Management Program.   Based on the state program,  local governments  (e.g.,
counties and cities)  prepare  and  implement  Shoreline Management  Plans  (SMP).    The
jurisdiction  of  SMP  are  highly variable  but usually  encompass activities within  several
hundred feet  of  the shoreline (e.g.,  including  nearshore  dredging  and disposal),  and
sometimes  include  state  waters  (e.g.,  open-water dredging  and  disposal).   The  CZMA,
via  local  SMP,  may  facilitate  sediment  disposal by  providing  planning  support  (e.g.,
providing  guidance  on where and  under what  conditions these activities  will be allowed).
For  the same  reasons, SMP  may also  constrain sediment disposal (i.e.,  by limiting siting
possibilities).   One of  the objectives  of  the CZMA  is  to foster  habitat protection  and
may thus facilitate implementation of remediation that results in habitat restoration.


SUPERFUND AMENDMENTS AND REAUTHORIZATION  ACT (SARA)

     SARA  amends the Comprehensive Environmental Response Compensation and Liability
Act  (CERCLA).  CERCLA/SARA establishes  a fund and  comprehensive program for identify-
ing, investigating, and  remediating problems at  hazardous  waste sites.   SARA  can  have
a profound  impact  on contaminated sediment remediation at relevant designated  superfund
sites.   The  primary  objective  of CERCLA/SARA  is  to effectively  reduce  or  eliminate
risks to human  health  and  the environment from  hazardous  substances.   At  Superfund
sites,  CERCLA/SARA  outlines  a detailed process  for  characterizing   the  extent  and
nature of contamination, evaluating remedial alternatives,  and performing  remediation.

     SARA  can  potentially provide support for  all sediment  remediation activities in the
form of funding,  administrative support,  and  planning.   Problem identification  can be
facilitated   during  the   site  discovery (e.g..  Preliminary   Assessment/Site   Investigation)
and remedial  investigation phases of  the  SARA  process.    Other  facilitating   aspects of
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SARA are applicable only at sites on  the  National  Priorities List (NPL).   At these sites,
sediment  removal  can  be  facilitated during  site remediation.   Sediment that is  removed
may be  disposed  of  on- or  off-site, with  or  without treatment.   Sediment  disposal  may
be  facilitated  by   providing  alternative  disposal  sites (e.g., contaminated  sediment  may
be  confined  in-situ [capping],  disposed of in  nearshore or upland  portions  of a  site,  or
transferred  off-site  for  disposal).    Habitat   restoration  is  generally  facilitated  to  the
extent that sediment  remediation  improves  environmental   quality.   In  addition,  SARA
authorizes  federal and  state  resource  management  agencies   to  file  natural  resource
damage claims against  responsible parties at Superfund sites (43 CFR Part  11).  Pursuant
to federal  regulations  for natural resource  damage  assessments (NRDA),  moneys recovered
for damages must be used for resource (e.g., habitat) restoration or replacement.

     Problem identification under SARA is not  limited  to  Superfund sites, but would be
limited to  sites  at  which SARA hazardous  wastes are  present (or suspected  to be  present).
Sediment  removal, sediment  disposal, and  habitat restoration under  SARA  are  all  limited
to Superfund sites.


RESOURCE CONSERVATION AND  RECOVERY ACT (RCRA)

     A  major  feature  of  RCRA  is  the   establishment  of  programs  for  regulating  the
treatment,  storage, and  disposal of  hazardous  waste.   Under RCRA, a  large number  of
guidance  documents  and standards  have been  developed,  including design and  operation.
requirements for landfills and treatment facilities (e.g., land treatment and incinerators).

     RCRA  can potentially  facilitate all aspects of sediment remedial action  via  funding,
administrative, and planning support.

      As a constraint  to sediment remediation, RCRA  would only be applicable at  facilities
with  (or eligible   for)  a  RCRA  permit  where  site activities  have  contributed   to  the
contamination of  sediments.  In  addition,  RCRA  may pose some  constraints  in  the form
of remedial or construction design for sediment removal and disposal.


TOXIC SUBSTANCES CONTROL ACT (TSCA)

      TSCA provides  that EPA  establish  a committee for  developing  regulations  for  the
testing, manufacture,  processing, and distribution of toxic chemicals.  Detailed requirements
and guidelines are specified  for the handling  and disposal of  materials containing PCBs
and dioxins.   TSCA  can potentially provide support to problem  identification  and sediment
removal   and  disposal  actions   via  development  of  evaluation   and   test  methods,  and
technologies  for  handling  and  disposing  of  toxic   materials.     TSCA  requirements  for
toxic  chemical  handling  and  disposal  may  pose  constraints  to  sediment  removal  and
disposal  actions  in  certain   cases  (e.g., treatment  requirements  for materials containing
PCBs).


NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

      NEPA  generally  requires  the preparation  of   an  Environmental  Impact  Statement
for  federal  projects   for which  significant environmental  impacts  are  expected.    NEPA
poses  potential constraints  to  sediment removal and  disposal   activities insofar  as these
activities may result  in  environmental  impacts.   NEPA may  affect remedial design and
implementation  by requiring  mitigative  measures for chemical contaminant levels,  remedial


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design and  construction limitations,  and selection of a  disposal site.   Sediment remedial
actions will  generally comply  with NEPA  as  long as they  result  in  a  decrease in environ-
mental impacts.     Mitigative measures  possibly  required by NEPA  may  also  have the
effect  of facilitating  habitat  restoration  (i.e.,  in addition  to  the  restorative effects  of
sediment removal).


REGULATIONS FOR HAZARDOUS MATERIAL TRANSPORTATION

     Federal rules for the transportation of hazardous materials may pose minor constraints
to the removal and  disposal of contaminated sediment in  terms  of  chemical concentration
limitations,  and design and construction limitations.   Constraints will  most likely  involve
procedural,  equipment,  and design requirements  during  the transportation of contaminated
sediment on federal highways.


OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA)

     The primary function of OSHA  is  to  establish  safety  requirements  for  workers in
the work place,  including  maximum permissible  exposure limits for numerous  hazardous
substances.   OSHA  may pose minor constraints  to problem identification, and  sediment
removal  and disposal activities insofar as  workers may be  exposed to hazardous  substances
on  the  job.   Constraints will most likely consist  of  requirements  for  ensuring  worker
safety  (e.g.,  approved health  and safety training  and health  and safety  plan, and  use of
safety equipment).


NATIONAL OCEAN PROGRAM ACT (NOPA)

     NOPA  requires  coordination  among federal agencies  involved  in  marine research
and  monitoring and  the promulgation of  regulations.   Relatively  limited funding, admini-
strative,  and  planning  support   for  problem  identification,  and   sediment  removal  and
disposal  actions is expected under  NOPA.  The support offered under NOPA will be directly
related   to  the  benefits of   coordination that   may  accrue  to certain  programs  (e.g.,
RCRA   hazardous material  treatment  pilot  studies  may  be  applicable  to  contaminated
sediment remediation).
FLOODPLAIN MANAGEMENT

      Federal  floodplain management  regulations establish a  variety  of requirements  for
projects  in floodplains  and  are  expected  to  pose minor constraints  relative  to  project
design  and   construction.     These  regulations  may   prevent  disposal of  contaminated
sediment in a  floodplain.
WETLANDS PROTECTION

      Federal   wetlands  protection   regulations   establish   requirements  for  projects   in
wetlands  and  are  expected  to  pose  minor constraints  to  sediment  disposal relative  to
design  and  construction.    These  regulations  may  prevent  disposal  of   contaminated
sediment  in wetlands.  Wetlands protection regulations may provide planning  and administra-
tive support for projects resulting in wetland restoration.
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SUMMARY

     Federal  regulations  can   influence  sediment  remedial  activities   in  a  variety  of
ways.   In  general,  activities  may  be  constrained  in terms  of:    1) activity  type  (e.g.,
dredging,  disposal, and  treatment), 2) location  of activity (e.g.,  disposal  upland,  nearshore,
deep  water,  or  offshore),   and  3)  chemical  contamination  (e.g.,  constraints   will  vary
depending  on  nature and  extent of  contamination).   All  laws and  regulations  affecting
sediment  remedial activities  are  designed  for  the  protection of  the environment  and/or
human  health.   After a  cursory inspection, it does  not appear  that the  enforcement  of
these  regulations  (alone or in  combination)  would  prevent implementation  on any feasible
sediment remedial alternative (assuming  the  alternative results  in a  reduction or elimination
of environmental  or  human  health risk).  However,  each law emphasizes different  aspects
of environmental  or  human  health protection, and  in some  cases  the  design or  implemen-
tation  of  sediment  remedial  alternatives  may  be  significantly  affected.    For example
constraints  for  a project involving  dredging  of  severely  contaminated  sediment  (e.g.,
classifiable as RCRA hazardous  waste)  from a  wetland and  disposal  in  open  water might
include:

     •     For Dredging Activities:

                Preparation of  an EIS (if the dredging location is  not  on  a  Superfund
                site)

                Satisfaction   of Water  Quality  Act  Section  404  permit  requirements
                for  dredged  material testing  and  agency  review (e.g.,   may  include
                implementation of mitigating  measures  for  potential  impacts  to  fish
                and  wildlife)

                Compliance with local land use ordinances (e.g., pursuant to CZMA)

     •     For  Sediment  Disposal Activities   [i.e.,  assuming material   is  a  RCRA
           hazardous  waste   and  can  only  be  disposed  of (untreated)   in  a  RCRA
           approved disposal  facility]:

                Satisfaction   of requirements for  a  variety  of  treatment alternatives
                (e.g., incineration, solidification, and land treatment) under  RCRA

                Satisfaction   of  a variety  of   requirements  depending  on  location
                and  design  of disposal  site,  and  remaining  chemical contamination
                levels

                Compliance with local land use ordinances (e.g., pursuant to CZMA)

                Compliance  with specific  material  handling  requirements  of  trans-
                portation  regulations  (e.g.,  regulations   for  the   transportation of
                material on  federal  highways and water-borne  transport pursuant to
                MPRSA).

     •     For  Habitat Restoration  Activities:    Satisfaction  of  interagency  review
           and  approval (and  possible design constraints) pursuant  to Water  Quality
           Act  (WQA)  Section  404  permit,  wetland  protection  regulations, and  local
           ordinances (e.g., pursuant to CZMA).
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     Existing  environmental   laws   and  regulations  govern   virtually  all  major  aspects
(i.e.,  related  to   specific  actions,  locations,  or  chemical  concentrations)  of  sediment
remedial activities.   It  appears that most  potential  constraints are related to inefficiencies
caused  by regulatory  and  administrative duplication  of effort, or  conflicting specifications
of laws  and regulations.   In  most  cases  where  there  is a  problem  of conflicting  specifi-
cations  (e.g., different  chemical  concentration  requirements  for  different media  such  as
surface  water  and  groundwater,  or differences between state and  federal  requirements),
the conflict  can be resolved by adopting or enforcing the stricter (or strictest) requirement.
The  nature  and  severity  of  such  constraints  is likely to  vary depending  on   project-
specific characteristics.   Evaluation of  the need for new laws or  regulations for sediment
remedial activities should take  into account the  following three factors:

     1)    Potential  creation   of  additional  regulatory  overlap  or  conflict  (with
           existing  laws  and  regulations) which  may  outweigh  the  benefits   of
           increased predictability

     2)    The  likely  ongoing  need  for  project-by-project evaluation of regulatory
           constraints  (i.e., will additional laws/regulations improve predictability?)

     3)    Existing   provisions   for  inter-agency  and   inter-program   review   and
           coordination  may allow for the development of administrative  mechanisms,
           eliminating the need for new laws and regulations.

     Implementation  of sediment remedial programs  may  benefit  substantially  from  the
creation or  modification  of  administrative  mechanisms  for fostering  coordination  and
cooperation  among  key  agencies  (e.g.,   Environmental  Protection   Agency,  U.S. Army
Corps  of  Engineers,  U.S. Fish  and  Wildlife  Service,  National  Oceanic  and  Atmospheric
Administration).   It may  be  beneficial to  implement  strategies  for  enhanced coordination
and  cooperation  (e.g.,  development of   consistent  policy,  procedures  and  criteria  for
multi-agency evaluation of sediment  remedial  activities)  at  both  the national  level and
the  state-regional  level,  specially  since sediment  remedial  program  needs  will   vary
among EPA regions and among states.

     This  evaluation  was  performed based on  a cursory  review  of  major environmental
laws and  regulations,  and conclusions  should be  interpreted  only  in  very  general terms.
A more  detailed  review  of  laws, regulations  and  programs,  and interviews  with key
agency  personnel  in EPA  regions would enable: 1)  identification of  major conflicts among
existing  laws,  regulations,  and  national programs;  2)  description of  the general character-
istics of  sediment  remedial   programs  in  EPA  regions; and  3) specification  of potential
mitigating  measures for  resolving constraints.
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                 APPENDIX D

OVERVIEW OF NATIONAL ACADEMY MARINE BOARD
   WORKSHOP ON CONTAMINATED SEDIMENTS

           Strategies and Technologies
     for Cleaning Up and Managing Contaminated
               Marine Sediments
                Tampa, Florida
             May 30 - June 3, 1988

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                   SUMMARY OF COMMITTEE CHARGE
OBJECTIVE    Appraise strategies and technologies for cleaning up and managing
               contaminated marine sediments.
PRODUCT     A report,  including workshop  proceedings  and a  supplemental
               committee   analysis,  describing  technical  and   programmatic
               issues  concerning   cleanup,  and  management  of   contaminated
               marine sediments.

               The report  will provide an improved understanding of contaminated
               sediment on which to  base decisions  concerning  management
               and  technical  research  and  development.    It   will  include
               recommendations to the Corps of Engineers, the Environmental
               Protection   Agency,  states,  and  industry  regarding  further
               study and technical development.
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                     SUMMARY OF PROJECT SCOPE



               (see detailed description at end of this appendix)






PROJECT ELEMENTS:






     •    Determine extent and significance of contamination






     •    Review the state-of-the-art of technology for cleanup and remediation






     •    Identify and appraise alternative management strategies






     •    Identify R&D needs and issues for subsequent technical assessment
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                             COMMITTEE MEMBERSHIP


Kenneth S. Kamlet, Chairman, A.T. Kearney, Inc.

     •    Contaminated sediment and marine pollution law and policy


William J. Adams, Monsanto Company

     •    Aquatic toxicology, alternative biological waste treatment
          technologies


A. Karim Ahmed, Natural Resources Defense Council, Inc.

     •    Toxicology, public health risk assessment


Henry J. Bokuniewicz, State University of New York at Stony Brook

     •    Sediment transport and deposition, subaqueous capping


Thomas A. Grigaluna, University of Rhode Island

     •    Natural resource economics


John B. Herblch, Texas A&M University

     •    Dredging technology, coastal and ocean  engineering


Robert J. Huggett, Virginia Institute of Marine Science

     •    Fate and effects of toxic chemicals in aquatic systems


Howard L. Sanders, Woods  Hole Oceanographic Institution

     •    Benthic ecology


James M. Thornton, State of Washington Department of Ecology

     •    Contaminated sediment policy and planning
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                    LIAISON REPRESENTATIVES
U.S. ENVIRONMENTAL PROTECTION AGENCY

         Kim Devonald, OMEP
         Christopher H. Zarba, OWRS
         John Cunningham, OERR
         Reginald Rogers, Region IV
U.S. ARMY CORPS OF ENGINEERS

         Norman R. Francingues, WES
         David B. Mathis, CECW-D (Dredging Division)
NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

         Andrew Robertson, Ocean Assessments Div.


U.S. FISH AND WILDLIFE SERVICE

         Robert R. Bersson, Environmental R&D Coordinator


U.S. CONGRESS

         James Evans, Office of Rep. Mike Lowery
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                STRATEGIES AND TECHNOLOGIES FOR CLEANING UP

                AND MANAGING CONTAMINATED MARINE SEDIMENTS
SUMMARY
     Contamination  of  marine  sediments  poses  a potential  threat  to  marine  resources,
including the  food  chain.   Improving  the  nation's  capability  to clean  up and  manage
contaminated  sediments  is critical  to  the  health  of  the marine  environment  as  well as
to  the  utilization of  the  nation's  waterways  for  navigation and commerce.   EPA  has
identified  1,500  high-priority hazardous waste sites,  of  which  NO A A has  noted  at  least
95  that   may  threaten  marine  resources  (excluding  the  Great   Lakes).    Whereas  the
cleanup  of  hazardous  wastes  is  a  concern of  EPA,  states,  and  regulated  industries,  the
problem  of handling  contaminated  marine  sediments  in  navigation channels and  harbors
(that need to be dredged) falls primarily to the Corps.

     Contaminated marine sediments can be  left alone, removed by dredging and managed
offsite;  or  confined,  capped,  or  stabilized  in   place.    Efforts   to  address the  unique
technical and  engineering  problems  associated with "cleaning up* (or otherwise remediating)
hazardous  waste  and  contaminated  sediment  at  underwater  sites  have,  unfortunately,
received very limited attention.

     As  a result  of  discussions with  the Corps'  Dredging Division and  the EPA Offices
of  Water,  Emergency  and Remedial  Response (Superfund), and ORD, the  Marine Board
proposes  to  appraise strategies and technologies for cleaning  up and managing contaminated
marine sediments.   A committee would  be appointed  to convene a workshop that  will
examine  the  extent of  contamination and  its  significance,  review the  state of  practice
of  technology  for cleanup  and  remediation,  identify  and  appraise alternate management
strategies,  and  identify   research  and  development   needs  and  issues  for  subsequent
technical assessment.   The committee  would prepare a report that  includes the proceedings
of  the  workshop and a  summary  appraisal  that  describes  technical and   programmatic
issues concerning  cleaning up  and  managing  contaminated marine sediments and makes
recommendations to the Corps and EPA  regarding further study and technical development.


BACKGROUND

     EPA's Office of Water, several  EPA  regional offices,  and the Corps  are  interested
from  different  perspectives   in  problems  associated with contaminated  marine   sediments.
The EPA's interest  relates  to  water quality  concerns  and  its  mandate   to  remediate
uncontrolled  hazardous waste (Superfund)  sites.    The  Corps is  involved  and  concerned
because  of  its responsibility to  dredge  and  maintain navigable rivers  and  harbors.    In
addition,  under an agreement with EPA,  the Corps assists in the  design and implementation
of remedial cleanup actions under Superfund.

     The Clean  Water Act,  as  amended  by the  Water Quality Act  of 1987, gives EPA
lead responsibility for safeguarding the  quality of U.S.  coastal  and  inland  waters.  This
includes  regulating the disposal of dredged and fill  materials  (shared with the Corps under
Section 404),  and removing  in-place  toxic pollutants  in  harbors and  navigable  waterways
(under Section  115).   The  1987 amendments  added  new authorities requiring EPA  to
study and  conduct  projects  relating  to  the  removal  of toxic   pollutants from Great

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Lakes  marine  sediments  [Section  118(c)(3)]; to  identify and implement individual  control
strategies to reduce  toxic  pollutant  inputs  into  contaminated waterway segments [Section
304(1)]; and  to  formalize a National  Estuary Program aimed at  identifying  and protecting
nationally significant  estuaries  (Section 320).  The EPA  Office  of Water  is  also pursuing
initiatives  to  implement  a  broad-based   Nearshore  Coastal  Strategy  and   to  develop
sediment  quality  criteria to  address  water  quality problems attributable to contamination
of marine sediments.

     In  addition  to  the  Clean  Water Act,  which  is directed at  protecting  water quality,
CERCLA, as amended by  SARA,  is aimed at  the cleanup and remediation  of inactive or
abandoned hazardous  waste sites,  regardless of  location.   At  least two  National  Priorities
List Superfund sites  involve  cleanup of  contaminated  marine sediments:   New  Bedford
Harbor,   Massachusetts  and  Commencement  Bay,  Puget   Sound,  Washington.    Several
others  involve  submerged  freshwater sites  within the  Great Lakes  Basin.    NOAA has
identified close to  100  coastal (non-Great Lakes) Superfund sites  with  the  potential to
threaten  marine resources.

     Superfund sites  are  currently  ranked  by  EPA  based on  the hazard  they may pose
to  human health  and the  environment  via releases to  groundwater,  surface  water,  and
air.   Underwater  accumulations of hazardous waste, particularly in  marine environments,
are unlikely to threaten  human  health  except  by  way  of food-chain  exposure,  which  is
not currently  addressed  in EPA's hazard  ranking  process.   Under  the  1986  Superfund
amendments, however, EPA  was required to modify its hazard  ranking system  to  address.
"the damage to natural resources  which  may  affect  the  human food chain and  which  is
associated  with any  release  or  threatened  release  (of  a  hazardous  substance"  [Section
105(a)(2)].   It is  likely,  therefore,  once this  amendment  is implemented,  that there  will
be  a   significant  increase  in  the  number  of  underwater  Superfund  sites  in  both  coastal
and inland areas.

     To   date, contaminated  marine  sediments   have  been  managed  on an  ad hoc,  site-
specific  basis.   As   a  result,  cleanup  efforts  have  not  necessarily  employed the  most
cost-effective  or   technologically   advanced  methods  available.     Contaminated  marine
sediments can be dealt with  in one of three ways, depending  upon circumstances:

     •   They can  be  left alone (as was done  for kepone-contaminated sediments
          in the James River, Virginia)

     •   They can  be  removed  by dredging   and managed offsite  (as is  proposed
          for PCB-contaminated sediments in the upper Hudson River,  New  York)

     •   They can be confined, capped, or stabilized in place.

Dredging can  involve several  different types of equipment (i.e.,  mechanical, pneumatic,
and/or hydraulic  dredges), with  or  without  silt  curtains  to  minimize the  dispersal  of
disturbed sediment,  each  subject  to  particular depth  limitations,   precision   capabilities,
turbidity-resuspension tendencies, and sediment  consolidation capabilities.  The  appropriate-
ness of a particular  dredge type or dredging technique will also  depend on the properties
of the sediment contaminants to be  removed, particularly their  degree of water  solubility
and  their volatility.   There  are  also  many issues  associated with the  ultimate disposition
of dredged sediments.
                                          D-6

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PROPOSED PLAN OF ACTION

      A  committee of  about seven  members  will  be established under  the Marine Board
with  expertise  in state,  federal,  and  industrial  cleanup  of  hazardous  wastes;  sediment
dynamics  and  transport;   environmental  science;  dredging  technology;  natural  resource
damage  assessment; risk  assessment  and  economic  impact;  and  public  interest  in  coastal
protection. The committee will convene a workshop with invited papers in order to:

      •     Determine the extent of contamination and its significance

      •     Review the state of practice of technology for cleanup and remediation

      •     Identify and appraise  alternate  management strategies (including  removal
           of  sediments by  dredging for management  offsite; confining,  capping,  or
           stabilizing  sediments  in  place;  and  no  remedial   action  coupled  with
           regulation of activities at or near the site)

      •     Identify  research and  development  needs  and  issues  for  subsequent
           technical assessment.

(Such findings would  address classification  of sediments and the extent  of contamination;
cleanup/remediation technologies  including  dredging  technologies; and  sediment,  environ-
mental,  and waterway management strategies).

      The workshop will provide a  forum for examining and discussing current developments.
It  will  focus  on  the  special  technical  problems  and  engineering  issues  associated  with
mitigating  the environmental  impacts  of contaminant  accumulation  in  marine  sediments.
The   committee  will  solicit  participation   in  the  workshop  by individuals  from  many
backgrounds:    federal and  state  regulatory  authorities,  dredging  technology;  Superfund
cleanup  contracting,   natural  resource  damage  assessment,  environmental, and  industry
interest; and scientific research.
ANTICIPATED RESULTS

     The committee  will prepare a  report  that includes  the proceedings  of the workshop
and  a summary appraisal  by  the  committee  that  describes  technical and programmatic
issues  concerning  cleaning  up  and  managing  contaminated marine  sediments and makes
recommendations to  the Corps and EPA regarding further  study and  technical development.
The  report  will provide  an  improved  understanding  of contaminated marine sediments  on
which  to  base  decisions  concerning  management  as  well  as  technical  research  and
development to enhance  the  national capability  to  address and  resolve  the  problem  of
contaminated marine sediments.
                                          D-7

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