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
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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).
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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
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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).
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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,
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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
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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
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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:
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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.
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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.
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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.
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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?)
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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
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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.
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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.
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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.
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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
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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 -
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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
-------
ASSESSMENT
Figure 4. Basic decision-making framework for dredged material disposal.
(Reference: Lee et al. 198S)
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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Pavlou, S.P. 1987. The use of the equilibrium partitioning approach in determining
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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
A-8
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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
A-9
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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
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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.
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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.
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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.
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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
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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.
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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.
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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:
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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
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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.
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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.
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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
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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:
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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
C-7
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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.
C-8
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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.
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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.
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