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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 Background and Rationale 1-1
1.2 Objectives 1-1
1.3 Summary of Approach 1-2
2.0 REVIEW AND SUMMARY OF RELEVANT STUDIES 2-1
3.0 BURDEN/EFFECT LEVELS AND STANDARD METHODS 3-1
4.0 DECISION SCHEME FOR REGULATORY USE OF SEDIMENT CRITERIA . 4-1
5.0 RECOMMENDATIONS 5-1
6.0 REFERENCES 6-1
APPENDIX A - Management and Technical Needs In Sediment
Criteria Development A-l
APPENDIX B - Interactive Activity and Information Flow
Diagrams for Studies Relevant to Criteria
Development in Puget Sound B-l
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1.0 INTRODUCTION
1.1 BACKGROUND AND RATIONALE
Upon completion of the initial evaluation of alternatives for the
development of sediment criteria (Pavlou and Weston 1983; Pavlou and
Weston 1984), a series of activities were identified as the logical
sequence to the initial study. These were separated Into management
and technical needs which reflected both regional and national
programatic priorities as expressed by the EPA Criteria and Standards
Branch and the EPA Region X project staff. These activities are
summarized in Appendix A. Regionally, EPA intends to develop a
coherent approach in the management of contaminanted sediments and in
the control of toxic discharges in Puget Sound. Nationally, EPA
intends to develop a methodology for establishing sediment criteria in
a variety of marine sites throughout the country to define toxic levels
of contaminants in sediments and determine what should be considered a
safe level. Control, compliance, and enforcement decisions would be
based on these numerical values.
1.2 OBJECTIVES
In response to these needs, and as a first step to performing the tasks
presented in Appendix A, it was deemed appropriate to: (1) review all
current investigations being performed in Puget Sound which address
sediment quality aspects of relevance to sediment criteria development,
and (2) to develop an interactive Information-use framework which would
eventually lead to the development of defensible numerical criteria.
The main focus of this short term effort was to stimulate common
interest among the various agencies and to develop an Informational
feedback on methods, procedures, and Interpretive techniques for
deriving defensible and enforceable regulatory sediment criteria.
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1.3 SUMMARY OF APPROACH
To achieve these objectives, the following tasks were performed:
o Current studies underway in Puget Sound which would contribute to
the refinement of the "first cut" sediment criteria were identified
through interviews with key agency staff and contractors.
o The general approach of each of these studies was clarified and
verified by the parties performing the work.
o The specific work components for each study were detailed in an
interactive information flow diagram. The projected results of
each of these investigations were defined, together with an
expected completion date. The Interrelationships among components
of the different studies and the comparative progress of each were
also shown.
o A decision process chart was generated showing how the data
developed by the different investigations could be incorporated
into the regulatory process.
The studies evaluated were:
o EPA/NERC/R. Swartz - Dose/Response Studies
o WDOE/Tetra Tech - Burden-Effect Study, Commencement Bay
o NOAA/E. Long - Triad Evaluations in Puget Sound (Sediment
Chemlstry /Toxicology/Bioeffects)
o EPA/Battelle Northwest - Recruitment Studies in Puget Sound
Embayments
o EPA/Envirosphere/S. Pavlou - Equilibrium Partitioning Analyses
o Miscellaneous Regional Efforts
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In addition to the above tasks, an attempt was made to obtain an
estimate of burden/effect levels from the principal investigators of
those studies in which bioassay and residue level measurements were
taken.
The ensuing sections of this report present the results of this short
project, together with recommendations for follow-up activities.
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2.0 REVIEW AND SUMMARY OF RELEVANT STUDIES
The studies identified in Section 1.0 of this report were reviewed and
outlined in terms of an interactive activity and information flow
scheme. These schematic diagrams are Included in Appendix B as Figures
B-l through B-5. In addition to the flow schematics, the Figures
include descriptive information consisting of: (1) the entity
performing the study, (2) the approach, (3) the objectives of the
study, (4) location, (5) expected results, (6) implementation and use
of results, and (7) an outline of the advantages and disadvantages of
the study. Provided below is a summary of the contents of each figure
in Appendix B.
Figure B-l EPA/NERC, Rick Swartz - Dose/Response Studies
This diagram was developed exclusively from two phone interviews with
Dr. Swartz. The right half of the schematic represents an iterative
process that is repeated for each contaminant of concern. A report
describing the applicability of this bioassay to sediment quality
determinations should be available in October 1984. Subsequent reports
will follow containing data on additional contaminants as they are
evaluated, such as the cadmium toxicity study which was completed this
summer.
This approach shows promise for developing burden/effect relationships
that could be used to generate threshold limits or be incorporated Into
the equilibrium partitioning approach for verifying the "first cut"
criteria values.
Figure B-2 WDOE/Tetra Tech - Burden/Effect Study, Commencement Bay
The diagram was developed from Tetra Tech's draft report R-3752, May
1984 "A Decision-Making Approach" and then modified with Information
from the "Sampling and Analysis Plan Task 3 Report" February 1984, and
two interviews with the project manager, Mr. Tom Ginn.
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This investigation incorporates most of the bioassays and field
biological surveys developed or used by NOAA/NWAFC, but modified to
obtain specific results (a "no effect" level) required for remedial
action decision making. Together with EPA's dose/response studies this
project should provide the most coherent data base for establishing
burden/effect relationships 1n Commencement Bay as well as a test case
for the whole Puget Sound.
Figure B-3 NOAA/Edward Long - Triad Evaluations 1n Puget Sound
(Sediment Chemistry/Tox1c1ty/B1oeffects)
The diagram was developed from "A Multidisciplinary Approach to
Assessing Pollution In Coastal Waters" (Long 1983), NOAA OMPA-2 (Maiins
et al. 1980), NOAA OMPA-19 (Maiins, et al. 1982), the correspondence
between NOAA and EPA concerning sediment criteria development, and two
Interviews with Mr. Long. Due to the complexity of the NOAA approach
which is relatively broad topically and multidisciplinary, this diagram
was greatly simplified to allow Incorporation of the major study
components which constitute the basic framework of these
investigations. Other components such as oceanographlc field studies,
transport modeling, sedimentation studies and water chemistry studies
were not included.
The box "Interim Reports on Results and Co-Occurrence" represents a
series of annual update reports by several different subcontractors for
NOAA. These documents have been published since 1980 and several more
will be available in 1984 and 1985.
Step 6 consists of Iterative components, as was the case with Figure
B-l, 1n order to identify the specific effects of a contaminant or
group of contaminants at the concentrations previously found 1n Puget
Sound.
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Step 7 is a proposed effort for incorporating all the data and previous
reports generated up to 1986 into an overall program report. Through
this step areas which are adversely affected by contaminants determined
to be toxic at the concentrations currently found in the sound could be
delineated. Several reports will probably be published in 1986 with
different areas of emphasis and from different subcontractors.
Figure B-4 EPA/BatteHe Northwest - Recruitment Studies in Puqet
Sound Embayments
This diagram was developed from two phone interviews with Dr. Eric
Crecelius. The amphipod bioassays are being performed by EPA's
Manchester Laboratory. The oyster larvae deformation bioassays are
performed in Seguim along with the recruitment Phase 2 study. Phase 3
has yet to be funded by EPA/DOE but is considered a critical component
by Battelle in verifying the validity of recruitment approach and
expanding the usefulness of the data collected in Phase 2.
These Battelle studies will provide another useful data base of
chemical, benthic infaunal and toxicological information for
identifying possible correlations between combined contaminant levels
and adverse biological effects, and ranking contaminated sediments.
However, the results of their unique recruitment study will probably
not be directly applicable in identifying burden/effect threshold
limits for specific contaminants that can be compared with the "first
cut" criteria derived from the equilibrium partitioning approach.
A standard method for the current recruitment experiments has yet to be
published. The Initial experiments demonstrating the proof of
principle for contaminated sediment were conducted by J.W. Anderson of
Battelle (Anderson et al. 1978). Subsequently, J.R. Vanderhorst
further developed the techniques. The results of Vanderhorst's work
are available (Vanderhorst et al. 1978, 1980, 1981). The procedures
applied 1n the current EPA-sponsored recruitment experiment are
extensions of a line of research conducted at Battelle's Marine
Research Laboratory over the last eight years.
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Two additional advantages of the Battelle approach not included in
Figure B-4 are 1) the time course for recovery can be assessed
experimentally, and 2) through evaluations of the variances, statements
concerning statistical sensitivity are possible. Given such statements
the cost to detect a given level of change can be determined.
Figure B-5 EPA/Envirosphere/S. Pavlou - Equilibrium Partitioning
Approach
This method has been discussed 1n detail in previous reports (Pavlou
and Weston, 1983; Pavlou and Weston, 1984). The diagram is a
simplified representation of the method. The activities identified
past April 1984 are projections pending further funding. Field
verification, and comparison of refined criteria values with threshold
limits determined from the burden/effect studies described above are
considered high priority prior to adoption of this approach as the
optimum method for sediment criteria development.
MISCELLANEOUS REGIONAL EFFORTS
In addition to the above studies, two activities addressing aspects
related to sediment quality but of no direct applicability to sediment
criteria were evaluated. These were: EPA/Versar Endangerment
Assessment in Commencement Bay and the Seattle District Corps of
Engineers dredge/disposal related studies. A brief summary of these
two efforts is provided below.
EPA/Versar - Endangerment Assessment, Commencement Bay
This short project was an attempt to provide an assessment of the
aquatic fate of contaminants, their toxicity to aquatic life and the
risk to human health in Commencement Bay. The evaluations were focused
on seven contaminants of toxic significance for which Toxic
Significance Factors (TSF) were estimated. This study was of limited
utility due to the lack of supporting data necessary to verify the TSF
calculations. Although this study was primarily a generic assessment,
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the methods provided in estimating bioavailability, population exposure
and human health effects could be incorporated into WDOE/Tetra Tech's
Commencement Bay assessment to supplement the burden/effect evaluations.
Seattle District Corps of Engineers Studies
The summary presented below reflects Envirosphere's interview
discussions with Keith Phillips and Pat Storm of the Seattle District
Corps of Engineers, June 28, 1984.
The Corps currently does not have any research projects underway that
would provide information or data for direct use in sediment criteria
development for Puget Sound. However, the following projects, reports
and data generated in a variety of projects may be useful as indirect
references, especially in clarifying the future use of sediment
criteria for dredged material disposal.
o Since 1975, the Corps dredging office has kept records of the basic
sediment chemistry analyses required for dredged material
disposal. However, the data is inconsistent and is not research
oriented. Sediment quality data exists for Everett, Bellingham,
Duwamish, and Commencement Bay.
o Grays Harbor, Evaluation of Sediments for Ocean Disposal. The
research report on field studies and bioassays being performed by
NOAA will be available in August 1984. Data will Include:
Suspended and solid phase bioassays for worms, clams, amphipods,
and salmon; newly developed procedures for testing sediments; and
bioaccumulation analyses of tissues for contaminants.
o Commencement Bay, Final Report on Disposal Options for DOE, being
prepared by Waterways Experiment Station. The Report will Include
summary tables of worldwide sediment chemistry data and disposal
"criteria"; suites of tests to determine biological effects;
prediction of problems with leaching and runoff from upland
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disposal; and decision making guidelines. A workshop between WES
and DOE scheduled in September 1984 will discuss the draft report.
The final report should be available in November 1984.
o The capping project in Duwamish, scheduled in September 1984, will
provide information on the percentage loss of contaminated
sediments and percentage loss of contaminants through the cap layer.
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3.0 BURDEN-EFFECT LEVELS AND STANDARD METHODS
As mentioned earlier (Section 1.0), in addition to the review of the
studies addressing sediment quality impacts, available documentation
for each study was reviewed for information on possible ranges of
burden-effect threshold limits and for specific references to the
standard methods that were used. In areas where studies were completed
or interim results were available, the data was usually presented in
charts and tables with discussions on comparisons among regions sampled
and statistical correlations between bioeffects and contaminant
concentrations in the sediments. Unfortunately, no conclusions or
determinations of threshold limits were presented.
The only study that addresses this aspect explicitly is the superfund
investigation in Commencement Bay performed by WDOE/Tetra Tech. In
this case, it is anticipated that "no effect" levels for several
categories of bioeffects will be determined and used to formulate
remedial action plans; this information will not be available until
November 1984.
Since it became apparent that available documentation could not provide
Immediate estimates of burden-effect limits without a coherent analysis
of the data, the key scientists involved 1n the studies discussed in
section 2.0 were asked if they could provide a "first cut" estimate of
ranges (low, medium, high) of burden-effect levels, together with the
latest reference for the standard methods used 1n their study.
Summaries of their comments follow and their standard methods are
referenced 1n Table 3-1 with the complete citation appearing 1n Section
6.0, References.
Rick Swartz - EPA/NERC Newport
The amphlpod bioassay, which he developed and 1s being widely used by
NOAA, WDOE/Tetra Tech, and EPA/BatteHe Northwest, 1s used as an
Indication of lethality or acute toxicity with the results usually
being presented as percent survival. A toxic effect 1s Indicated 1f
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TABLE 3-1
FIELD BIOLOGICAL SURVEYS
Category/Specific Analysis
Parameter Quantified
Standard Method
FIELD BIOLOGICAL SURVEYS:
NQAA
Fish Pathology
Type and number of parasitic infections
Type and number of all lesions
Hematology and blood chemistry
Invertebrate Pathology
Type and nurtber of parasitic infections
Type and number of all lesions
Fish Ecology
Seasonal and annual catch rates
Species richness
Species diversity
Sex, age and size
Invertebrate Ecology
Community structure
Total abundance
Taxon richness
Number of infections
Number of lesions
Concentrations of contaminant
Number of infections
Number of lesions
(CPUE) Catch per unit effort
(S) number of species
(H) Shannon-Weaver Diversity Index
Comparative percentages
(IBD) Index of benthic degradation
(ITI) infaunal trophic index
(TA) number of organisms
(S) number of taxon
Mai ins et al. 1980; 1982
Mai ins et al. 1980; 1982
Mai ins et al. 1980; 1982
0'Conner and Swanson 1982
Word 1978
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Category/Specific Analysis
Bioaccumulation
Fish livers
Invertebrate edible tissues
Limited edible tissue analyses of fish
Harbor seal blubber
Marine bird muscle and organs
Effect Studies
Invertebrate exposure
Recolonization
Tetra-Tech
Bioaccumulation
Crab and fish edible tissue and fish livers
Fish Pathology
Type and number of liver lesions
Mai ins et al. 1982
Benthic Community Structure
Total abundance
Amphipod abundance
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TABLE 3-1 (Continued)
Parameter Quantified
Standard Method
ug contaminant/g dry weight
ug contaminant/g dry weight
ug contaminant/g dry weight
ug contaminant/g dry weight
ug contaminant/g dry weight
Mai ins et al. 1980; 1982
Calambokidis 1984
Riley 1983
Comparative survival
Comparative abundance and richness
Mai ins et al. 1982
Concentration (ppb) and
Bli = Cs1-/Cr1-
h = contaminant group)
Malins et al. 1982
Percent prevalance and Plj = pSi/pRi
(i = type of lesion)
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Category/Spedfie Analysis
NOAA (Continued)
Benthic Community Structure (Continued)
Molluscan abundance
Total taxa
Amphipod taxa
Molluscan taxa
Species richness
Species dominance
Battel!e
Effect Studies
Recruitment
BIOASSAYS:
NOAA
Oyster Larvae
Abnormal development
Mortality
Surf Smelt Eggs and Larvae
Abnormal development
Hatching success
Larval survival
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TABLE 3-1 (Continued)
Parameter Quantified
Standard Method
BCI = BCR1/BCSl-
(i = structure variable)
Swartz 1978
Number of species
Number of organisms
Number of species in a taxon
Number of species in a trophic level
Vanderhorst et al
1978
Comparative percent sublethal
Comparative percent survival
Comparative percent sublethal
Comparative percent survival
Comparative percent survival
Chapman and Morgan 1983
Chapman, et al. 1983
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Category/Specific Analysis
NOAA (Continued)
Polychaete Life Cycles
Survival at all stages
Growth rate
Timing to reproduction
Cell Reproduction
Inhibition of cell proliferati
Cytotoxicity
Anaphase aberration
Amphipod Toxicity
Lethality
Oligochaete Response
Respiration rate
Tetra-Tech
Acute/Lethal
Amphipod survival
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TABLE 3-1 (Continued)
Parameter Quantified
Standard Method
Comparative percent survival
mm/day
Number of days
Chapman and Fink 1984
No. of cells/96 hours
ug/ml
Comparative percent occurrence
Chapman et al. 1983
Chapman et al. 1982
Landolt and Kocan 1984
Comparative percent survival
Swartz et al. 1984
Comparative ul O2
Chapman 1984
Percent mortality and TI^ = Mj/Mr
Swartz et al. 1984
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TABLE 3-1 (Continued)
Category/Specific Analysis Parameter Quantified Standard Method
Tetra-Tech (Continued)
Sublethal
Oyster larvae deformation Percent abnormality and TI^Aj/Ap Chapman and Morgan 1983
Definitions of Tetra-Tech Symbols
Cj.j = tissue concentration of contaminant group i at a study area.
CRl- = tissue concentration of contaminant group i at reference areas(s).
Pjf = percent of fish with liver lesion i at a study area.
PRi = percent of fish with liver lesion i at reference area(s).
Ri = va^ue a selected benthic community structure variable at reference area(s).
BCSl- = the value of the same benthic community structure variable at the study area.
M$ = mortality rate at a study area.
Mr = mortality rate of reference area(s).
A$ = abnormality rate at a study area.
AR = abnormality rate at reference area(s).
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mean survival is less than 85 percent (less than 17 out of 20
individuals surviving). This method has been used by EPA to evaluate
the toxicity of sediments in the interim dredged material disposal
decision process. It represents the point at which one can reliably
detect a significant difference from background based on statistical
analyses of numerous bioassay tests. The interpretive use of this
method is summarized below.
In the control bioassays the number of surviving amphipods can range
from 20/20 down to approximately 17/20 or 85 percent survival.
Therefore, in the bioassays of contaminated sediments, if the mean
survival rate is less than 85 percent then one could reasonably assume
that a causative agent in the sediment induces a toxic effect on the
amphipods. Dr. Swartz has not analyzed data from these amphipod
bioassays to the extent required to develop burden-effect ranges.
However, he suggested that 0 to 8 survival/20 might be considered
highly toxic, 9 to 17 survival/20 moderately toxic and 17 to 20/20
normal background. He emphasized that the results of these bioassays
are very site specific in that the survival of the amphipod also varies
with sediment characteristics (i.e., grain size and organic content).
He believes that a better understanding by researchers of how these
burden-effect levels would be used by regulatory agencies is necessary
in order to improve the utility of this method. Right now, all that
can be reliably determined is a yes or no answer regarding the
occurrence of an effect.
The benthic community structure indices (Swartz 1978) which WDOE/Tetra
Tech is using in Commencement Bay are indicators of a "real world"
change in a portion of the marine environment. These indices are used
to detect a change in the structure of the community (i.e., change in
number of species, taxon abundance, or disappearance of sensitive
species). This change could be due not only to changes in contaminant
concentrations, but also to variations in organic enrichment, sediment
characteristics, and/or other covariates. Dr. Swartz believes that
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these indices can only be used to compare similar communities in
similar environments or follow the community behavior over a period of
time. Therefore, benthic community indices by themselves are not
conclusive enough to be used as a single "criterion" or grouped into
ranges of burden-effect levels.
Peter Chapman - EVS Consultants
Dr. Chapman has developed and/or modified four bioassays which are
being used in studies of Puget Sound sediment contamination. The
oyster larvae bioassay is used to detect sublethal effects by recording
abnormal larvae development and lethal effects by egg survival. The
fish cell reproduction bioassay is used to determine lethal effects,
cytotoxicity, by measuring the inhibition of cell proliferation and
sublethal effects by calculating the percent occurrence of anaphase
aberrations. The polychaete life-cycle bioassays also measure both
levels of effects, lethal - survival at all stages, and sublethal -
changes in growth rate and timing of reproduction. Sublethal effects
of sediment contamination can also be detected with the oligochaete
response bioassay which compares changes in respiration rates. Dr.
Chapman indicated that with further research and statistical analyses,
some components of these bioassays could be used to develop a
"criterion" but cautioned that they would have to be applied very
carefully due to the Inherent site specific limitations and the
difficulty in obtaining enough reliable data to perform adequate
statistical analyses. He felt that there was not enough data yet to
begin a meaningful evaluation of burden-effect levels and cautioned the
regulatory agencies not to hurry into the sediment criteria development
process.
Eric Crecelius and Walt Pearson - Battelle Northwest
The benthic community recruitment studies on sediments from eight
embayments in Puget Sound are based on methods developed over the last
eight years at Battelle's Marine Research Laboratory by Dr. J.V.
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Anderson and J.R. Vanderhorst to predict the effects of oil spills on
intertidal populations. Data obtained from these studies will include
the number of species, number of individuals, number of species in a
taxon and number of species in a trophic level. The data will be used
to rank the eight embayments according to the comparative bioeffects on
recruitment. Because these studies were designed to test the
integrated effect of all the contaminants in a series of sediment
samples and experimentally assess the impact of the whole sediment
rather than individual components, both Drs. Crecelius and Pearson
believe that the data will not be suitable for developing specific
numerical sediment criteria. Limiting factors, such as the effects of
grain size on species preference and the bioavailability of
contaminants may preclude this benthic community structure test from
being used in the development of sediment criteria for specific
contaminants or groups of contaminants. These current studies can only
show indications of contamination and to what relative degree they
occur. Specific burden-effect relationships or ranges cannot be
estimated. This technique, though, is not inherently incapable of
determining such relationships. Experimental manipulation of
oil-contaminated sediments have yielded quantitative relationships
between the level of oil contamination and the rate of benthic recovery.
Jack Word - University of Washington
The infaunal trophic index (ITI) was developed by Jack Word to improve
the reliability of comparing other benthic community structure
indices. The ITI essentially is used to describe the community; it
characterizes the community structure by taking into account the
interrelationships between the four major trophic groups, food
availability, and key sediment characteristics. Therefore, when
benthic samples from different embayments with similar ITI values are
compared, the effects of natural variables affecting the structure
indices are minimized and the effects of contamination can more
reliably be assessed.
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From his experience, Dr. Word felt that a change in the number of
species was a more sensitive indicator of contamination than the number
of individuals because the sensitive and marginal species would
disappear first due to toxic contaminants. Dr. Word said that a 30
percent change in the number of species versus background would be
indicative of contamination, while a 50 percent change in the number of
individuals would be required to conclude that the area was
contaminated. However, the use of the ITI method in evaluating
toxicant effects is still a controversial issue and is not being
supported by other quantitative benthic biologists.
His opinion on the use of benthic community structure indices for
sediment criteria concurs with those of Dr. Swartz and Dr. Pearson; the
data and indices developed for purposes of comparison are not
appropriate for establishing burden-effect relationships for specific
contaminants.
Don Mai ins - NOAA/NWAFC
Numerous field biological survey techniques have been developed and/or
modified by NWAFC for assessments of Puget Sound sediments. These
surveys fall into the following five categories: fish pathology,
invertebrate pathology, fish ecology, invertebrate ecology, and
bioaccumulation. According to Dr. Mai ins, of all these surveys, only
the incidence of liver lesions has been correlated with the presence of
contaminants in the sediments. In a nonurban or pristine environment,
the incidence of liver lesions is essentially zero in the five species
of fish usually surveyed. Therefore, even a 1 to 2 percent incidence
of liver lesions is an indication of contamination. No attempt has
been made to group the percent incidence data into low, medium, or high
levels of effect. All other types of lesions and parasitic infections
commonly occur in fish and Invertebrates even in pristine environments;
to-date no correlations between their percent incidence and contaminant
levels have been documented.
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Similarly, statistical correlations required to establish burden-effect
relationships have not yet been found in the data from fish ecology and
invertebrate ecology surveys. Bioaccumulation studies are as yet
inconclusive, as they are still in the developmental stages and much
data has to be gathered and analyzed to first improve the scientists'
understanding of bioaccumulation before attempts at identifying
burden-effect relationships can be initiated.
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4.0 DECISION SCHEME FOR REGULATORY USE OF SEDIMENT CRITERIA
Based on the evaluation of the most relevent ongoing studies in Puget
Sound and discussions with EPA Region X staff, a decision process chart
was generated showing how the data developed by the different
investigations (approaches) could be incorporated into the regulatory
process. The process scheme is shown 1n Figure 4-1. At this stage of
the sediment criteria development program, this interactive chart is
intended only as an example of the type of decision considerations that
may have to be incorporated in the regulatory process for implementing
an effective control/compliance/enforcement plan for toxic
contaminants. This decision scheme is designed for a chemical-by-
chemical assessment. It utilizes the criteria graph concept developed
in the preliminary evaluation study in conjunction with supplemental
information anticipated to be obtained from the burden-effect analyses
and bioassay testing. The authors recognize the preliminary nature of
this decision scheme and intend to refine and/or modify it as more
evaluations are performed and additional feedback from the regulatory
and scientific community is acquired.
The following discussion summarizes the scheme and provides a brief
description of the elements shown.
o A sample is obtained in the active sediment layer of a marine site
under regulatory consideration. The statistical criteria for the
number of samples obtained, the spatial configuration of the
sampling grid, and sampling techniques are not discussed in this
report.
o The sediment sample undergoes a range of analyses to quantify
various parameters including:
(1) Conventional parameters (e.g., nutrients, sulfides, oil
and grease, total solids, BOD, COD, and other variables);
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EXAMPLE OF REGULATORY DECISION PROCESS
FOR USE OF SEDIMENT CRITERIA
Figure 4-1
USE CONC. AS A
WATER QUALITY
CRITERIA VALUE
f REVIEW EXISTING^
( LITERATURE AND )—
\ APPLICABLE DATA J
LOWEST CONCENTRATION OF
CONTAMINANT X IN MARINE
WATER WHERE EFFECTS HAVE
BEEN OBSERVED
TOXICITY OF CONTAMINANT X
IN SIMILAR ENVIRONMENT
AND SEDIMENT CHARACTERISTICS
MOLECULAR STRUCTURE/REACTIVITY
ANALYSES; EXTRAPOLATE TOXICITY
FROM SIMILAR COMPOUNDS
SEDIMENT
SAMPLE
CHEMICAL ANALYSES (1)
- CONVENTIONAL
. ANCILLARY VARIABLES
¦ HEAVY METALS
- PRIORITY POLLUTANTS
NO
DOES CONTAMINANT X
HAVE A MARINE WATER
QUALITY CRITERION?
OTHER CONSIDERATIONS
NO ACTION
REQUIRED
CONFIRM FINDINGS
WITH SELECTIVE
CONTAMINANT
BIOASSAY RESULTS
CHAPMAN OR SWARTZ
METHODS
NO
DETERMINE
THRESHOLD
VALUE AT
SITE
DOES CONTAMINANT X
EXCEED THRESHOLD
VALUE?
1
1
(2)
USE THRESHOLD VALUE
FOR MULTIPLE SITES TO
DEVELOP SEDIMENT
CRITERIA CHART FOR
FUTURE USE
NO ACTION
REQUIRED
NO EFFECT
NO ACTION
REQUIRED
NO EFFECT
YES
COMPUTE SEDIMENT
CRITERION FROM
EQUILIBRIUM PARTITIONING
APPROACH
PAVLOU METHOD
WHERE DOES THE CONC.
OF CONTAMINANT X FALL
ON ITS SEDIMENT
CRITERIA CHART? (2)
NOTICEABLE
EFFECTS
RANGE
.1),
1 EXTENT OF CHEMICAL ANALYSES
| WOULD VARY DEPENDING ON THE LOCATION
(2) SEDIMENT CRITERIA CHART
FOR CONTAMINANT X
PERFORM SELECTIVE
CONTAMINANT
BIOASSAYS
SWARTZ METHOD
HZI '
OF THE SEDIMENT, i.e., LOW AREA OF
CONCERN - HIGH AREA OF CONCERN
I
J
VIOLATION
VIOLATION
EFFECT
EVALUATE PUBLIC
HEALTH RISK
CONSIDER WATER
USE DESIGNATIONS
DEVELOP CONTROL/COMPLIANCE/
ENFORCEMENT ACTION PLAN
IMPLEMENT
CONC. IN SEblMENT
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(2) Ancillary variables which are important in determining
bioavailability and burden-effect relationships. These,
for example may include: grain size, percent organic
carbon, oxidation and reduction potential, and
interstitial water chemistry (salinity, DOM);
(3) heavy metals of ecological significance (priority list);
and
(4) priority organic components Including any other
anthropogenic chemicals of known ecological significance
and/or specific to the site of interest originating from
land based sources.
o Each contaminant found in the sediment sample will be assessed on
an individual basis. If a marine water quality criterion has been
established by EPA for that contaminant, then the decision can
follow the lower pathway involving use of the equilibrium
partitioning approach. If no criterion are available a literature
review and use of relevant Information could be pursued as shown in
the upper pathway.
Lower Pathway
o From the water quality criteria a range of sediment criteria can be
computed from a predicted partition coefficient as described by
Pavlou and Weston (1984).
o The next step on the path Is determined by where the measured
contaminant concentration falls on Its sediment criteria chart. If
the coordinates of the contaminant concentration and percent
organic carbon fall within the "no effect" portion of the chart, no
regulatory action Is required. If the measured concentration falls
within the "violation" portion, this sediment sample exceeds
criterion for that specific contaminant and regulatory action 1s
required.
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o Instead of just having a line of values separating the "no effects"
and "violation" portions, there is a range which encompasses the
uncertainty associated with the derivation of the criterion value.
If a concentration falls within this "not1cable effects" range,
additional evaluations of possible biological effects are
required. Selective contaminant bioassays such as those developed
by EPA (Swartz et al. 1984) could be used to determine the toxicity
of a specific contaminant concentration associated with a given
percent organic carbon.
o The results of these bioassays could be further evaluated in light
of possible public health risks and actual water usage. Can this
contaminant be bioconcentrated in edible tissues and would
organisms that come in contact with this contaminated sediment or
intermediate trophic levels be consumed by humans? Is the location
of contaminated sediments used extensively by the public for
recreation or fishing, or 1s 1t a critical habitat? Appropriate
regulatory action could then be developed based on this evaluation.
Upper Pathway
o The first step Involves a review of existing literature and
applicable data to find possible correlations between
concentrations of the contaminant (or chemically similar compounds)
with biological effects.
o If detrimental biological effects have been observed for that
contaminant in marine waters, the lowest concentration associated
with effects could be used to develop a water quality criterion
(Stephan et al. 1983). This derived criterion could then be used
1n the lower portion of the decision process just as those criteria
which have been established.
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o If only indirect information 1s available, then selective
contaminant bloassays such as those developed by Swartz or Chapman
as presented 1n Table 3-1 could be used to confirm the toxicity of
this contaminant. From these results, tentative contaminant
threshold values can be determined for these sediment
characteristics.
o If the measured contaminant concentration exceeds this determined
threshold value, then regulatory action is required. If there is
no exceedence, no action would be necessary.
o The threshold values determined from these selective contaminant
bioassays for multiple sites can be used to develop a sediment
criteria chart for future applications.
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5.0 RECOMMENDATIONS
Upon completion of this short project, 1t Is apparent that prior to
launching a full-fledged effort In sediment criteria development, EPA
must determine whether (1) establishing sediment criteria is an
effective method to protect the marine environment from present and
future contaminant insults and (2) 1f the different approaches
currently pursued by various environmental agencies and scientific
groups will generate sufficiently reliable Information which could
render the derived numerical values defensible against scientific
scrutiny as well as in a court of law. It is also apparent that,
although there is a tacit agreement on the basic concepts currently
considered by the various approaches, there are differences of opinion
in the way these approaches are Interpreted and the way the data should
be applied 1n the development of sediment criteria.
Based on the above considerations, the following recommendations are
made as logical steps for addressing both the regulatory and technical
concerns addressed above.
o A technical workshop should be planned as soon as possible to
evaluate the methodology and interpretive procedures currently used
1n the various approaches presented 1n this report and reach a
technical concurrence on the applicability of state-of-the-art
technology in the development of sediment criteria.
Examples of State-of-the-Art Technology
Bioassays - Made-up mixtures or fractionated suites
- Spiked sediments
- Polychaete Hfecycles
Bloaccumulation in edible tissues
Recruitment in benthic communities
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Concurrent to this activity should be an attempt (based on best
current knowledge) by scientists and environmental managers to
identify alternative decision methods for establishing acceptable
levels. The workshop should include key individuals who are
actively involved in the use and testing of relevent technology. A
desirable output from the workshop should be a consensus document
delineating applicable methods, procedures, and data which can be
used to evaluate sediment criteria or related burden-effect
threshold limits.
o A regulatory workshop should be organized to perform the following
recommended tasks in order to address immediate and long term
regional decision/regulatory needs:
1. Identify estuarlne/coastal decision and regulatory needs which
may require the application of sediment criteria.
2. Identify existing criteria upon which decisions/actions,
(i.e., control, compliance, enforcement) are presently based.
3. Describe regulatory decision making processes to which
sediment criteria can be applied and/or existing water quality
criteria can be confirmed by Incorporating sediment quality
parameters.
4. Determine how sediment criteria can be incorporated in the
permitting process (I.e., 301 (h) waivers, NPDES permits,
dredge/disposal permits) by developing a conceptual
process/procedural scheme which enhances end point of
regulatory decision/need. (What do we need to protect?)
5. Determine how the sediment criteria can be converted (and the
process by which one goes about converting) from an ambient
value to a source control limit. Determine transport and fate
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process of contaminants from an input source or sources to
ambient concentration. Develop general model relating input
loading to ambient burden which can be tailored to a given
specific need.
6. Based on 4 and 5, develop and recommend the type and form of
sediment criteria needed to meet the regulatory/decision end
point, (e.g., Type—biological, chemical, integrated;
Form—criteria graph, threshold limits, index.) Look at
regulatory instruments and how we would make these permits the
most effective means for solving sediment problem by using
sediment criteria.
7. Develop conceptual framework for incorporating sediment
criteria into EPA's use-attainability analysis scheme.
Implement recommendations 1A through IE under Technical Tasks,
Task 1, as presented in Appendix A. Recommendations 1A and IB can
be performed together.
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6.0 REFERENCES
Anderson, J.W., R.G. Riley and R.M. Bean. 1978. Recruitment of
benthic animals as a function of petroleum hydrocarbon
concentrations in the sediment. J. Fish Bd. of Can. 35(5):776-790.
Calambokidis, J., J. Peard, G.H. Stelger, H.C. Cubbage, R.L De Long.
1984. Chemical contaminants in marine mammals from Washington
State. NOAA Technical Memorandum NOS OMS-6. National Ocean
Services, Rockvilie, MD. 167 pp.
Chapman, P.M. 1984. Oligochaete respiration as a measure of sediment
toxicity in Puget Sound, Washington. Water Research.
Chapman, P.M. and R. Fink. 1984. Effects of Puget Sound sediments and
their elutriate on the life cycles of Capitella capitata. Bulletin
of Environmental Contaminants and Toxicology.
Chapman, P.M. and J.D. Morgan. 1983. Sediment bloassays with oyster
larvae. Bulletin of Environmental Contaminants and Toxicology,
Vol. 31. Pages 438-444.
Chapman, P.M., R.N. Dexter, R. Fink, R.M. Kocan, M.L. Landolt,
J. Morgan, D.R. Munday. 1983. Survey of biological effects of
toxicants upon Puget Sound biota, II-Test of Reproductive
Impairment. NOAA Technical Report NOS-2, 0MS-1, Rockvllle, MD,
58 pp.
Chapman, P.M., G.A. Vlgers, M.A. Farrell, R.N. Dexter, E.A. Quinlan,
R.M. Kocan, M.L. Landolt. 1982. Survey of biological effects of
toxicants upon Puget Sound biota, I-Broad Scale Toxicity Survey.
NOAA Technical Bulletin, OMPA-25. Office of Marine Pollution
Assessment, Boulder, CO. 98 pp.
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Landolt, M.L. and R.M. Kocan. 1984. Lethal and sublethal effects of
marine sediment extracts on fish cells and chromasomes.
Helgolander Meesunters. Vol. 38.
Long, E.R. 1983. A multldlsciplinary approach to assessing pollution
in coastal waters. Jjn: Proceedings of the Third Symposium on
Coastal and Ocean Management, ASCE/San Diego, CA. June 1-4, 1983.
Pages 163-178.
Mai ins, D.C., B.B. McCain, D.W. Brown, A.K. Sparks, H.O. Hodgins, and
S. Chan. 1982. Chemical contaminants and abnormalities 1n fish
and Invertebrates from Puget Sound. NOAA Technical Memorandum
OMPA-19.
Malins, D.C., B.B. McCain, D.W. Brown, A.K. Sparks, and H.O. Hodgins.
1980. Chemical contaminants and biological abnormalities In
central and southern Puget Sound. NOAA Technical Memorandum OMPA-2.
O'Connor, J.S. and R.L. Swanson. 1982. Unreasonable degradation of
the marine environment - what 1s 1t?. ^n: Proceedings from
Oceans 82, Marine Pollution Papers, Marine Technology Society,
September 20-22, 1982, Washington, D.C. Pages 1125-1132.
Pavlou, S.P. and D.P. Weston. 1983. Initial Evaluation of
Alternatives For Development of Sediment Related Criteria for Toxic
Contaminants in Marine Waters (Puget Sound). Phase I: Development
of Conceptual Framework.
Pavlou, S.P. and D.P. Weston. 1984. Initial Evaluation of
Alternatives For Development of Sediment Related Criteria for Toxic
Contaminants in Marine Waters (Puget Sound). Phase II:
Development and Testing of the Sediment-Water Equilibrium
Partitioning Approach. EPA Report 910/9-83-117.
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Riley, R.G., E.A. Crecelius, R.E. Fitzner, B.L. Thomas, J.M. Gurtisen,
N.S. Bloom. 1983. Organic and inorganic toxicants in sediment and
marine biota from Puget Sound. NOAA Technical Memorandum NOS
0MS-1. National Ocean Services, Rockville, MD. 125 pp.
Stephan, C.E., D.I. Mount, D.J. Hansen, J.H. Gentile, G.A. Chapman,
W.A. Brungs. 1983. Guidelines for deriving numerical National
Water Quality Criteria for the protection of aquatic life and its
uses. Draft, EPA. July 5, 1983.
Swartz, R.C., W.A. Debend, J.K.P. Jones, J.O. Lamberson, and F.A. Cole.
1984. Amphipod bioassay for marine sediment toxicity, jji:
Proceedings of the 7th Symposium of Aquatic Toxicology, ASTM.
Swartz, R.C. 1978. Techniques of sampling and analyses of the marine
benthos. EPA Ecological Research Series, EPA-600/3-78-030.
Vanderhorst, J.R., J.W. Anderson, P. Wilkinson, and D. Woodruff. 1978.
Estimation of effects from oil on intertidal populations:
experimental pertubations versus natural variation. In:
Proceedings of Conference on Assessment of Ecological Impacts of
Oil Spills, held in Keystone, Colorado on 14-17 June. Pages
807-820.
Yanderhorst, J.R., J.W. Blaylock, P. Wilkinson, M. Wilkinson and
G. Fellingham. 1980. Recovery of Strait of Juan de Fuca
intertidal habitat following experimental contamination with oil.
DOC/EPA Interagency Energy/Environment R&D Program Report
EPA-600/7-80-140, U.S. Environmental Protection Agency, Washington,
D.C. 73 pp.
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Vanderhorst, J.R., J.W. Blaylock, P. Wilkinson, M. Wilkinson and
G. Fellingham. 1981. Effects of experimental oiling on recovery
of Strait of Juan de Fuca intertidal habitats. DOC/EPA Interagency
Energy/Environment RSD Program Final Report EPA-600/7/81/088. U.S.
Environmental Protection Agency, Washington, D.C. 129 pp.
Word, J.Q. 1978. The infaunal trophic index. Coastal Water Research
Project (W. Bascom, ed.). Annual Report, 19-37.
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APPENDIX A
MANAGEMENT AND TECHNICAL NEEDS IN SEDIMENT CRITERIA DEVELOPMENT
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APPENDIX A
MANAGEMENT AND TECHNICAL NEEDS IN SEDIMENT CRITERIA DEVELOPMENT
INTRODUCTION
Based on the initial evaluation of alternatives for development of
sediment criteria for toxic contaminants in marine waters (Pavlou and
Weston, 1983; Pavlou and Weston 1984) two types of follow-up activities
were identified. One reflects the regional EPA needs and the other the
national programatic priorities as expressed by the project staff of
the EPA/Criteria and Standards Division. EPA Region X is pursuing the
development of a coherent approach in the management of contaminated
sediments and the implementation of a realistic contaminant
control/compliance/enforcement plan for Puget Sound. The EPA's
Criteria and Standards Division is interested in developing methodology
for establishing sediment criteria for a variety of marine sites
throughout the country to define toxic levels of contaminants in
sediments and determine what should be considered a safe level so that
effective regulation of contaminants can be implemented.
Envirosphere, in consultation with both management and technical staff
from the EPA Region X Office, has developed a list of activities which,
from the Agency's perspective, would strengthen the effort of
developing defensible criteria. These activities include management
and technical tasks applicable to the regional and national needs
presented above. A short summary of these tasks is presented below.
OBJECTIVES AND ASSUMPTIONS
Although the objectives of the sediment criteria development
continuation studies reflect primarily regional needs, they are
applicable to any marine region. The objectives are summarized below:
o Develop best available interim criteria for Puget Sound.
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0
Develop arid manage a coordinated and coherent approach to
upgrade criteria to legally defensible regulatory status
consistent with EPA Headquarters needs.
o Develop regional and national numerical defensible
(scientifically sound) sediment criteria.
In performing the proposed tasks the assumption is made that Puget
Sound is identified as the lead marine region where sediment criteria
will be developed and will provide a test case for the national effort.
MANAGEMENT TASKS
Task 1 Preparation of Management Framework for the Sediment Criteria
Development Program
o Compile and document interim criteria values generated by
all existing approaches and ongoing efforts by various
agencies in Puget Sound. The list to be prepared
following consensus among all concerned parties involved
and confirmation by all regulatory agencies.
o Perform comparative analyses of data generated by each
approach and determine consistency of results produced by
different approaches.
o Develop theoretical projection of each approach, i.e.,
extend evaluations and analyses to a degree of rigor
necessary to ensure that the derived criteria are
technically and scientifically defensible numerical
values.
o Develop an interactive diagram of activities and CPM
scheme to reach defensible numerical criteria values
integrating the results of various approaches.
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o Perform coherent evaluations:
Interrelate and Integrate approaches for Puget Sound;
define common elements resulting in defensible
numerical values.
Expand evaluations to include national needs and
approaches.
o Define existing/ongoing approaches and research efforts;
relate to approaches identified in the initial evaluation
reports. Define list through examination of ongoing
activities (field surveys) in Puget Sound.
Task 2 Management of Interim Sediment Criteria Use
o Project regulatory decision points (milestones) where
interim sediment criteria will be required. Relate to
interactive diagram and activities developed under Task 1
above.
o Develop sediment criteria for open water dredge disposal
of contaminated sediments. Obtain concensus by all
regulatory agencies.
o Propose field studies and laboratory research to provide
cost effective improvement of numerical values.
o Analyze projected use of interim Puget Sound numerical
criteria.
Evaluate when numbers need to be upgraded with
respect to data and regulatory decision points.
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Analyze data and recommend changes.
Revise projected data needs and apply to Interactive
diagram/CPM scheme.
Task 3 Coordination of Interagency Communications and Information
Exchange
o Document activities under Task 1 and disseminate
information to participating agencies in easily
understandable documents. Focus on visual methods, oral
presentations, and workshops.
Task 4 Develop Interagency Information Exchange Program
These activities will focus on:
o Obtaining concurrence on the Interactive Diagram/CPM
Scheme.
o Improving the understanding of the sediment criteria
development effort by technical and management staff of
all agencies.
o Assuring effective use of management framework, i.e., how
each agency can apply ID/CPM scheme to meet their needs
and how their work would relate to other agency needs.
o Providing rapid feedback on ongoing activities as it
relates to criteria development, i.e., field surveys,
laboratory studies, data synthesis, and interpretive
evaluations.
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o Assuring effective information transfer and that
communications are maintained in formulating decisions
for future field studies and research objectives as
related to overall coordinated interagency approach to
criteria development.
TECHNICAL TASKS
Task 1 Refinement and Confirmation Studies of the Equilibrium
Partitioning Approach.
The proposed tasks comprise the follow-up activities to the
preliminary assessment of sediment criteria development
performed for Puget Sound and encompass the key aspects of the
recommendations made by Pavlou and Weston (1984).
Task 1A Compilation and Analysis of Ancillary Information.
o Compile all available organic carbon/sediment texture
data and develop master regression equation for
fine-tuning preliminary criteria values. Examine the
existence of subregional differences and adjust criteria
accordingly. Products from this effort should include a
master equation for Puget Sound sediments (estuary wide
and subregional) with associated numerical uncertainty
and computerized output (tabular and graphic).
Task IB Sediment Criteria Data Base (SCDB) Development.
o This task should be performed in two phases for cost
effectiveness. Each phase would consist of sequential
evaluations leading to a modular final product for each
phase.
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Phase I - Feasibility Assessment
Evaluate existing regional data base systems as to
their compatibility with the sediment criteria
program needs, accessibility by EPA and other users,
and ease of data processing (reduction and
statistical analyses).
Identify immediate SCDB needs for the equilibrium
partitioning approach to: (1) allow ease of
quantitative analysis of existing data, (2) inclusion
of addition contaminant residue and ancillary
parameter information, (3) refinement and fine tuning
of preliminary numerical values, and (4) expansion to
additional geographical areas nationwide.
Identify long term SCDB needs to include
incorporation of other computational methods for
generating numerical criteria. Establish interagency
consensus on unified approach.
Update progress status of ongoing regional water
quality data management efforts, estimated completion
schedules, and time of systems availability to
outside users.
Phase II - SCDB Systems Development
Develop a centralized sediment quality data
management system (SQDMS) to meet EPA's regulatory
short and long term needs.
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Task 1C Verification Studies of Equilibrium Partitioning
Approach
This task should be a field oriented activity and could
consist of two phases:
o Phase I - Develop Technical Basis of Survey and Approach
This phase is to include developing the technical
basis of survey and aprroach for site locations,
sampling frequency, chemical and ancillary variables
to be measured, and protocol development for
interstitial water sampling and analysis.
This phase could provide an updated review on the
state of knowledge in sampling and analysis of
interstitial water and recommendations for optimum
methodology to be used in a sediment criteria
development program based on equilibrium partitioning
approach.
o Phase II - Perform Survey and Analyses
Synthesize and interpret information resulting in
modification and/or refinement of preliminary
criteria values.
Task ID Biological Confirmation of the Equilibrium
Partitioning Approach.
This task should be implemented in two phases.
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o Phase I - Develop Work Plan
This work plan would be designed to determine if
sediment criteria values derived by the equilibrium
partitioning approach are below concentrations
causing adverse biological effects. Examine and
evaluate existing data. Perform preliminary analyses
afforded by the data, identify data needs for field
and/or laboratory studies, define products of the
study.
o Phase II - Perform Experimental and/or Field Survey,
Synthesize Results, and Perform Evaluations
Recommend additional field work, criteria
modifications, and/or specific protocol development
to enhance equilibrium partitioning approach by
specific bioassay tests. Refine numerical values as
appropriate. It is recommended that this task be
performed in conjunction with Task 1C to improve
coherency of evaluations and cost effectiveness by
consolidation of the sampling activities.
Task IE Chemical/Biological Comparisons from Existing Data
o This task, although specific to Puget Sound, is
applicable to any estuarine and/or coastal system where
sufficient information is available. The intent of this
task would be to perform initial evaluations based on
existing data to relate the occurrence of violations of
established "first cut" numerical criteria values to the
occurrence of biological effects. This task could be the
preliminary assessment required to better define the
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scope of the verification studies outlined in Tasks 1C
and ID above. Based on this initial assessment, develop
study scenarios that could be implemented to quantify
this relationship. Develop detailed work plan for
performing these evaluations. Recommend field and/or
laboratory studies.
Task 2 Application of Equilibrium Partitioning Approach to Other
Marine Environments
The proposed tasks are intended to test the application of the
equilibrium partitioning approach at different marine regions
and sites of the U.S. consistent with the programmatic
requirements (desires) of the EPA Criteria and Standard
Division regarding the development of acceptable methodology
nationwide for establishing sediment criteria. It is
recommended that these tasks be performed after the technical
assessments described in Task 1 are completed.
Task 2A Feasibility Testing of Derived Preliminary Criteria
in the New York Bight
o This task would apply the procedures developed by Pavlou
and Weston (1984) as verified and/or modified to the New
York Bight area. Specific activities would include:
compilation of contaminant residue data and appropriate
ancillary sediment variables (emphasis should be placed
on organic carbon/sediment texture data), the development
of criteria-graphs for New York Bight, and an evaluation
of the magnitude and spatial extent of violations.
Comparisons could be made with the results obtained in
Puget Sound and the relative magnitude, severity, and
significance of the contamination In these tests sites
could be assessed.
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Task 2B Feasibility Testing of Derived Criteria in Dredge
Disposal Sites
o This task would apply the procedures followed in Task 2A
above, to the evaluation of the magnitude, severity, and
significance of contamination at a test open water dredge
disposal site selected by EPA. This assessment should
provide EPA with: (1) an initial data base for
redesignation of disposal sites, and (2) a realistic
framework to base a coordinated effort with the Army
Corps of Engineers to develop alternative disposal
methods and site control practices.
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APPENDIX B
INTERACTIVE ACTIVITY AND INFORMATION FLOW DIAGRAMS FOR
STUDIES RELEVANT TO CRITERIA DEVELOPMENT IN PUGET SOUND
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