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REGULATORY APPLICATIONS OF SEDIMENT CRITERIA
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FINAL REPORT
on
REGULATORY APPLICATIONS
OP
SEDIMENT QUALITY CRITERIA
to:
U.S. Environmental Protection Agency
Contract No. 68016986
Work Assignment No. 2-77
December 1987
Christina A. Cowan, Work Assignment Leader
Christopher S. Zarba, Work Assignment Manager
BATTELLE
Washington Environmental Program Office
2030 M Street, N.W.
Washington, D.C. 20036
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ABSTRACT
This report briefly describes the approach being used to develop
sediment quality criteria, discusses their utility and
appropriate regulatory applications, and recommends steps to
enhance the acceptance of sediment criteria by the regulatory and
regulated communities. The report is based on the collective
input from chemists, biologists, ar>d aquatic toxicologists
working on sediment criteria development for EPA, and the results
of a survey of individuals in the regulatory and regulated
communities who are interested in and could potentially use
sediment criteria.
The first criteria values developed will be useful in identifying
potential problem areas and, in some cases, in identifying areas
where additional studies are needed to determine the likelihood
of adverse impacts. Sediment criteria will be useful in
implementing a number of laws, primarily those involving siting,
permitting, or monitoring of waste disposal; identifying or
cleaning up contaminated areas; and preparing environmental
impact statements. The development of sediment criteria is a new
effort and the exact role of these criteria in environmental
protection is in the earliest stages of formulation. As our
understanding of the impacts of contaminated sediments improves
and the role of sediment criteria in regulatory applications
becomes better defined, it is important that this progress be
communicated to all individuals and organizations who are
interested in and/or may be affected by sediment criteria.
Continuing scientific review of the criteria development effort
is essential.
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TABLE OF CONTENTS
Pase
ABSTRACT i
1.0 INTRODUCTION 1
2.0 BACKGROUND 1
3.0 OBJECTIVES AND APPROACH 3
4.0 OVERVIEW OF DEVELOPMENT OF SEDIMENT QUALITY
CRITERIA 4
5.0 SUMMARY OF THE MAJOR REGULATORY PROGRAMS OF EPA
WITHIN WHICH SEDIMENT QUALITY CRITERIA COULD BE
HELPFUL 6
6.0 APPLICATIONS OF SEDIMENT QUALITY CRITERIA 11
6.1 General Considerations 11
6.2 Examples of Specific Applications 13
6.2.1 Disposal Site Designation.. 13
6.2.2 Permit Evaluation for Dumping
and Discharges 14
6.2.3 Disposal Site Monitoring 16
6.2.4 Site Cleanup and Restoration 17
6.2.5 Environmental Impact Statements (EISs).. 18
7.0 RECOMMENDATIONS 18
8.0 SUMMARY 20
9.0 REFERENCES 21
APPENDIX A Discussion of a Survey of Needs and Uses
for Sediment Criteria A-l
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TABLE OF CONTENTS
(Continued)
Page
LIST OF TABLES
Table 1. Some of the Major Laws and the Sections
Within These Laws to Which Sediment
Criteria May Be Relevant 7
Table 2. Summary of Applications of Sediment Criteria
in Implementing Key Sections of Some Major
Environmental Laws 15
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1.0 INTRODUCTION
Sediment quality has been of interest to scientists for years
because many contaminants in the aquatic environment accumulate
to higher concentrations in sediments than in the overlying
water. Contaminated sediments may, in turn, act as a source from
which these contaminants can be released into the overlying
waters. To better accomplish'their environmental protection
missions, regulatory agencies have continually sought a scien-
tific basis for regulating contaminants in sediments. Because
sediments play a key role in contaminant interactions with the
aquatic environment, they are of great interest in a large and
growing number of regulatory programs. The differing objectives
and priorities of these programs result in a variety of potential
applications for sediment criteria. This report summarizes these
potential applications, recommends uses for sediment criteria,
and discusses limitations of sediment criteria. in this document
the term "sediment quality criteria" is. used in a general•sense
to refer to numerical values, however they are derived,
indicating environmental effects of contaminants associated with
sediments.
2.0 BACKGROUND
The development of water quality criteria (EPA, 1980) has been
one of the major continuing efforts in protection of the aquatic
environment. These criteria address the potential impacts of
dissolved contaminants in the water column. It has long been
recognized that dissolved chemicals become associated with, and
accumulate in, sediments. Although this accumulation has
resulted in significant environmental effects, techniques were
not available for developing sediment criteria applicable on a
national level to sediments covering a wide range of
1
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characteristics. Impact assessment guidance based on the
presence of elevated concentrations of chemicals in the sediment
was developed in some areas (Engler, 1980). However, sediment
criteria based on a relationship between contaminant
concentrations on the sediments and biological effects were not
developed. This was a result of inadequate scientific
understanding of the complex ways that mineral and organic
constituents in sediments interact to influence the
biogeochemical behavior, and thus the biological effects, of
contaminants.
In the absence of biological effects-based sediment criteria, a
variety of approaches emphasizing the presence of contaminants in
sediments have been used to evaluate potential environmental
effects of contaminated sediments. Examples of such approaches
(reviewed by Engler, 1980) include physical characterizations,
sanitary engineering measurements (e.g., biological oxygen
demand), and bulk or total sediment chemistry. A more
effects-oriented approach compared the concentration in sediment
elutriates to effects-based water quality criteria (EPA, 1975).
Only recently have bioassays and bioaccumulation tests been
widely used to directly evaluate the potential environmental
effects of contaminated sediments (EPA/CE, 1977).
All the approaches mentioned above, as well as many variations on
these approaches, had specific characteristics that made them
more suitable for some applications than for others, and almost
as many sediment evaluation techniques were developed as there
were programs dealing with sediment contamination problems.
These approaches were of little use on a national basis because
the results from one sediment could not be extrapolated to other
sediments. Thus, the evaluation had to be repeated for every
site or sediment of concern. Over the past dozen years,
scientific advances in a number of fields have combined to
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improve our understanding of the environmental behavior of
several classes of contaminants in sediments enough to allow
development of effects-based sediment criteria that are
applicable to a range of sediments.
3.0 OBJECTIVES AND APPROACH
The objectives of this report are to
o Identify the regulatory programs of EPA in which
sediment criteria could be most useful,
o Recommend current and potential uses of sediment
criteria by EPA,
o Evaluate the utility, including both appropriate
applications and limitations, of sediment criteria
to major regulatory programs.
This report is based on the contributions of persons with
knowledge of the biological, chemical, and legislative issues
relevant to sediment contamination and sediment criteria
development. In addition, a survey of the regulating and
regulated communities was conducted to verify the needs and
potential uses of sediment criteria in specific environmental
programs. Based on their involvement with sediment-related
environmental regulations, a total of 29 individuals were
selected to participate in the survey. The survey used a
questionnaire designed to direct the respondents through a
discussion of three major topics (1) the need for sediment
criteria, (2) the characteristics that would make the criteria
suitable for their applications (including legislative
applicability), and (3) the specific chemicals for which sediment
3
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criteria are needed. Detailed questions on each topic encouraged
each respondent to consider each subject in depth. Interviews
were conducted with individuals from eight EPA Regional Offices,
three EPA Environmental Research Laboratories, five EPA
Headquarters Offices, two offices of the National Oceanic and
Atmospheric Administration (NOAA), five offices of the Army Corps
of Engineers, three state regulatory offices, two academic
institutions, and one public utility environmental affairs
office. A complete description of the survey and a discussion of
the results are presented in Appendix A.
4.0 OVERVIEW OF DEVELOPMENT OF SEDIMENT QUALITY CRITERIA
In November 1984 and February 1985, workshops of experts in
environmental chemistry, environmental toxicology and related
areas were held to review available data and recommend an
approach for estimating sediment criteria for contaminants.
These workshops (Neff, 1985) agreed that the equilibrium
partitioning approach was a useful basis for developing
numerical, chemical-specific sediment criteria for non-polar
organic contaminants and metals. The approach for developing
sediment criteria is consistent with EPA's general approach of
developing numerical criteria for individual chemicals. Since
May 1985, EPA has been involved in verification of the approach
and in development of the necessary database for estimating
sediment criteria. Because polar organic contaminants were found
to be only a very small percentage of contaminants of concern in
sediments and a method for modifying the equilibrium partitioning
approach for polar contaminants was not evident from the
available data, no effort was initiated for that class of
contaminants.
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The equilibrium partitioning approach relates the biological
effects of contaminants on sediments to the partitioning of the
contaminant to the interstitial water. This approach has two
basic assumptions. First, the interstitial water concentration
of the contaminant can be calculated from the concentration of
the sorbent phases on the sediment, the partition coefficients,
and the concentration of the contaminant on the sediment.
Second, the toxicity of the contaminant to benthic organisms can
be related to the concentration of the contaminant in the
interstitial water. Thus, toxicity data for a contaminant in
water exposure can be used to calculate the concentration of
contaminant on the sediment that will result in a certain
toxicity.
Current research at Battelle, EPA laboratories, and several
universities is generating data that support the key assumptions
of the equilibrium partitioning approach. Within the next few
years, these development efforts will provide sediment quality
criteria for non-polar organic contaminants. These criteria will
be based on chronic water quality criteria or on appropriate
water quality advisories. The water quality criteria and
advisories will be used to establish "no-effect" or
"specific-effect" concentrations in the interstitial water. The
concentrations of contaminants on the sediment that at
equilibrium will result in these interstitial water
concentrations will be calculated based on partitioning
coefficients. In the absence of chronic water quality criteria
or appropriate advisories, other toxicological points (e.g.,
lowest observed effects levels) might be used to calculate the
sediment values, if appropriate, for specific regulatory
applications. There will, of course, be less confidence in the
protection afforded by these sediment values than for sediment
values based on chronic criteria and advisories. The
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desirability of using lowest observable effects level or other
bases for estimating sediment quality values will need to be
carefully evaluated in the context of the specific application.
Because the partitioning coefficients for many of the non-polar
organic contaminants are known only within some confidence
interval, a statistical uncertainty analysis was performed to
provide confidence limits for the sediment criteria values
(Pavlou et al., 1987). These confidence intervals could be
appropriate for determining the relative probability that a
particular sediment concentration exceeds or meets the sediment,
criteria. This "grey area" of sediment quality is referred to in
the application sections of this document. Specific
interpretation of the relative quality of a sediment based on
this "grey area" will need to be determined by each regulatory
program in light of the program's mandate.
Just as procedures for development of water quality criteria are
constantly being reviewed and improved, methods used" in the
development of sediment criteria can be expected to undergo
similar review and improvement. These efforts will result in a
progressively broader range of applications and greater
confidence in the criteria values.
5.0 SUMMARY OF THE MAJOR REGULATORY PROGRAMS WITH
SEDIMENT QUALITY CRITERIA COULD BE APPLIED
The Clean Water Acts of 1977 and 1987 give the U.S. Environmental
Protection Agency (EPA) regulatory authority to develop sediment
criteria, as does other legislation (Table 1). Under the Clean
Water Act, EPA has the responsibility for protecting the
chemical, physical, and biological integrity of the Nation's
waters. Section 104 of the 1977 Act for example, authorizes EPA
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TABLE 1. SOME OF THE MAJOR LAWS AND THE SECTIONS WITHIN THESE LAWS
TO WHICH SEDIMENT CRITERIA MAY BE RELEVANT.
LAW
PURPOSE
Clean Water Act
of 1977
Section 115
Section 301
301(b)
301(h)
Section 402
Section 404
Establishes authority to restore and
maintain the chemical, physical, and
biological integrity of the Nation's
waters.
Provides authority to identify the location
of in-place pollutants with emphasis on
toxic pollutants in harbors and navigable
waterways.
Establishes effluent limitations.
Provides for effluent limitations for
priority pollutants from point sources,
other than publicly owned treatment works.
Modifies discharge permits for discharge
from publicly owned treatment works.
Authorizes the National Pollution Discharge
Elimination System (NPDES) for regulating
the discharge of pollutants from point
sources.
Establishes permits for discharge of
dredged or fill material into navigable
waters of the U.S.
Clean Water Act
of 1987
Section 104
Establishes authority to protect the
chemical, physical, and biological
integrity of the Nation's waters.
Establishes national programs for the
prevention, reduction, and elimination of
pollution through research, experiments,
and demonstrations.
Section 118
Requires annual reports on the status of
pollutants in sediments of the Great Lakes,
and removal of sediments with toxic
pollutants.
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TABLE 1. (Continued)
LAW
PURPOSE
Section 304(a)
Authorizes development and publication of
criteria reflecting the scientific
knowledge on the environmental effects of
pollutants.
Marine Protection,
Research, and
Sanctuaries Act
of 1972
Provides authority to regulate the
transportation for dumping and the dumping
of material into ocean waters.
Section 102
Section 103
Authorizes dumping permits for sewage
sludge and industrial wastes.
Authorizes permits for transportation of
dredged material for the purpose of dumping
into ocean waters.
Resource Conservation
and Recovery Act
of 1976
Authorizes efforts to promote the
protection of health and environment and to
conserve valuable material and energy
resources by regulating the treatment,
storage, and transportation of hazardous
wastes that have adverse effects on health
and the environment.
Section 301
Establishes criteria for identification and
listing of hazardous waste.
Toxic Substances
Control Act
Authorizes regulation of chemical
substances and mixtures that present an
unreasonable risk of injury to health or
the environment.
Section 4(a)
Authorizes development of testing methods
including toxicity testing.
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TABLE 1. (Continued)
LAW
PURPOSE
Section 4(e)
Authorizes development of priority list for
promulgation of procedures under Section
4(a) .
The Federal
Insecticide,
Fungicide, and
Rodenticide Act
Gives authority to protect health and
environment against unreasonable adverse
effects from application of insecticides,
fungicides, and rodenticides.
National Ocean Confers authority to coordinate pollution
Program Act programs amongst the federal agencies
involved in marine research, monitoring,
and regulations.
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to establish national programs for prevention, reduction, and
elimination of pollution through research, experiments, and
demonstrations. Section 304(a)(1) directs EPA to develop and
publish criteria for water quality that reflect the latest
scientific knowledge on the environmental effects of pollutants,
including factors affecting organic and inorganic sedimentation,
in various types of receiving waters. Section 404 authorizes the
development from approaches to prevent unacceptable adverse
impacts from discharges of dredged or fill material into waters
of the United States. Section 103 of the Marine Protection,
Research and Sanctuaries Act of 1972 (MPRSA or Ocean Dumping Act)
also provides for the development of approaches to evaluate and
regulate the environmental effects of discharges, including
dredged material, into the ocean. Table 1 summarizes the major
legislation that provides explicit or implicit authority for EPA
to develop and implement sediment criteria.
Seventy-six percent of those interviewed in our survey cited the
Ocean Dumping Act and the Clean Water Act as mandates for
regulating contaminated sediments. Other respondents cited
mandates under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and the Toxic Substances Control Act
(TSCA), which establish regulations for chemicals being
registered or re-registered. Also cited were Superfund, Great
Lakes Sediment Quality Guidelines, and the NPDES Program. in
addition, other Federal agencies will probably use EPA's sediment
criteria in their own environmental regulations. States are also
likely to use any sediment criteria developed by EPA as a basis
for State standards. The potential impact of sediment criteria
on other agencies and states, as well as EPA, must be recognized
and considered when these criteria are developed and implemented.
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6.0 APPLICATIONS OF SEDIMENT QUALITY CRITERIA
Sediment quality criteria will be applicable in many different
ways to the regulatory programs described in Section 5.0. In
this section, application of the criteria to these programs and
specific regulatory concerns within these programs are discussed.
6.1 GENERAL CONSIDERATIONS
The various offices and programs concerned with contaminated
sediment have different regulatory mandates and thus, have
different needs and areas for potential application of sediment
quality criteria. Because each regulatory need is different,
sediment quality criteria developed specifically to meet the
needs of one office or program may have to be implemented in
different ways to meet the needs of another office or program.
Therefore, when the criteria are promulgated, several of the
survey respondents requested that guidance documents be prepared
that describe appropriate applications of the criteria and any
modifications in the assessment procedures that may be required
to meet the various regulatory mandates. This guidance document
will indicate the degree of environmental protection associated
with the criteria values, the confidence to be placed in these
criteria values, and the specific effects covered by the
criteria. In addition, the limits beyond which sediment criteria
would not be technically valid should be addressed in the
guidance document. These limitations might include the types of
compounds, and characteristics of the environment of interest.
For example, sediment quality criteria would not be applicable to
evaluating the impact of upland disposal of dredged material
because of changes in the geochemical conditions of the dredged
sediments that would alter the availability of the contaminants.
Several respondents questioned whether the criteria will be
applicable to highly contaminated areas or to areas where high
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concentrations occur naturally. The information contained in
these guidance documents will minimize the potential for
misapplication of the criteria.
The most likely mode of application of numerical sediment quality
criteria is as a key step in a tiered or stepwise evaluation
approach and this was confirmed by the survey respondents. In
such an application, sediments in which contaminants exceed the
sediment quality criteria would be considered to result in
adverse environmental impact. Further testing would not be
required to label the sediments as "impacted." Any further
testing in other tiers of the evaluation approach would most
likely be directed toward the need for and applicability of
remediation technologies. Contaminants in a sediment at
concentrations less than the sediment criteria would not be of
concern; however, the sediments could not be considered "safe"
because they may contain other contaminants above safe levels but
for which no criteria exist. Additional testing in other tiers
of the evaluation approach, such as bioassays, could be required
to determine if the sediments are "safe" or if other contaminants
are present at concentrations that would result in impacts.
Contaminant concentrations near the criteria values (i.e., in the
"grey area") would also indicate the need for more detailed
testing to determine if impacts are indeed evidenced in this
sediment. Such detailed testing may include incorporation of site
specific information into the evaluation process. Several of the
survey respondents emphasized the need to incorporate
site-specific information into the criteria and evaluation
process when appropriate. As more sediment criteria values
become available and experience with these values in the
regulatory programs increases, the need for additional testing
and the types of additional testing could be significantly
modified.
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The specific applications described in the following section are
directed toward the tier where sediment quality criteria would be
used and makes no judgment on the need for or form of the testing
in other tiers.
6.2 EXAMPLE OF SPECIFIC APPLICATIONS
Potential applications of sediment criteria can be found in a
number of laws. The specific applications under these laws
differ, but fall into several distinct categories. The primary
categories are summarized in Table 2, which is intended to be
illustrative rather than exhaustive. The utility and limitations
of sediment criteria would be very similar within each category
of application, regardless of the law involved. That is,
sediment criteria would be used for site designation in much the
same way under any law involving site designation.
6.2.1 Disposal Site Designation
Dumpsites. Sediment criteria could be useful for designating
dumpsites under several laws (Table 2). For example, in dumpsite
designation under Section 102 of the Ocean Dumping Act, sediment
transport patterns predicted for the site by field studies or
model calculations should be evaluated to determine their impli-
cations for environmental impact. This evaluation could be
accomplished by combining transport predictions with sediment
contamination data and comparing the resulting profiles with
sediment criteria. The sediment criteria would help in
evaluating the potential impact to the surrounding area resulting
from the transport of sediment-associated contaminants from the
site. Sediment criteria could also assist in evaluating the
potential impact of contaminants transported from the site in
dissolved or microparticulate form and deposited in sediments
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away from the disposal site. Such information is important in
evaluating the acceptability of candidate dumpsites under a
number of laws (Table 2).
An advantage of sediment criteria is that they would add
objectivity and consistency to the evaluation of the potential
impact of sediment-associated contaminants. They would also
assist in distinguishing potential problem sites from those for
which there is little cause for concern. However, to be most
useful sediment criteria would have to be available for all the
major contaminants of concern, and would have to have undergone-
sufficient scientific and public review to ensure that they are
acceptable to the regulating and regulated communities.
Discharge Sites. The application of sediment criteria to the
siting of outfalls or discharges (Table 2) would be similar to
the application of criteria in the dumpsite designation process.
For example, in outfall siting under Section 301 of the Clean
Water Act, models or field data could be used to predict the
accumulation of dissolved and particulate-bound contaminants in
the sediment. Sediment criteria could then be used to help
determine whether those accumulations would constitute an
unacceptable adverse impact. Discharge siting under several
other laws (Table 2) could apply sediment criteria in a similar
way. Advantages and limitations of sediment criteria for
discharge siting would be similar to those mentioned previously
in relation to dumpsite designation.
6.2.2 Permit Evaluation for Dumping and Discharges
Once a disposal or discharge site is designated, sediment
criteria could be used in the permitting process. For example,
in evaluating a discharge permit under Section 402 of the CJ.ean
Water Act, sediment criteria could be used to help evaluate the
potential impact of contaminants that would be expected to
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TABLE 2.
SLMiARy OP HNtNEXAL APPUCATHNS OP SEDIMENT OttTHttA IN SffU
M
C KEY SBCTKWS OF SOHE HAJCR ENVDUMCNEAL LAWS.
Duopsite Discharge Beimt
Clean-to
Area
Site
EES
. _ „ Dumsite Discharge Clean Area
Designation Siting Decisions Honitorirg Monitoring Identification Selection Setting Restoration Preparation
Clean-Ub
Goal
Clean Uater Act (1977)
Section 104
Section 301
Section 303, 304
Section 311
Section 402
Section 404
1967 Clean Uater Act
Amendments
Section 118
Section 404
Section 405
Section 509
Ocean Dumping Act
Section 102
Section 103
Section 301
Resource Conservation
and Recover/ Act
(RCRA)
Section 10)6
Section lOffl
Section 20) >4
Section 3G04G
Section 3005
Section 5019
Section 7U)3
Section 0003
Super fund Amendment
aid Reauthorization
Act (SARA)
and
Comprehensive Environmental
Response and Liability Act
(CIRCLA)
Section 102/103
Section 105
Section 106
Section 107
Section 121
Sectiai 205
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
X
X
X
X
X
X
X
X
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accumulate in the sediments. These contaminants might be
dissolved or associated with micro-particulates in the discharge,
and could accumulate in sediments at some distance from the site,
or contaminants might occur in the discharged material in solid
forms that would settle rapidly to the bottom near the discharge.
In either case, sediment criteria could be used in permit
evaluations under several laws (Table 2) to help evaluate the
potential impact of such contaminants.
Sediment criteria would help in permit evaluation by increasing
the objectivity and consistency of the evaluation process. Many
survey respondents stated that for the criteria to be useful in
permit evaluations, sediment criteria for a wide range of
chemicals are needed. Many respondents also thought that use of
sediment criteria in permit evaluations, even for screening
purposes, would require extensive review of the process used to
derive the sediment criteria, and of the resulting criteria
values by the scientific community and public.
6,2.3 Disposal Site Monitoring
Disposal site monitoring implies that some action will be taken
if the data exceed some level indicating a problem is imminent.
Several laws include sections related to monitoring disposal
sites and dumpsites (Table 2). Sediment criteria could be the
basis for determining whether contaminants were accumulating in
sediment to the extent that a potential effects threshold was
being approached or had been exceeded. For example, in
monitoring a discharge under Section 301 of the Clean Water Act,
contaminants would be analyzed in the sediments around the
discharge. The concentrations could be compared to sediment
criteria to help determine the likelihood of impact.
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Sediment criteria would be particularly valuable in site monitor-
ing applications, where sediment contaminant concentrations might
gradually approach the criteria over time. Comparison to
sediment criteria could be a reliable method for providing early
warning of potential problems. Such an early warning would
provide an opportunity to take corrective action before adverse
impacts occurred. Sediment criteria would have to be available
for a large number of chemicals to be most useful in site
monitoring.
6.2.4 Site Cleanup and Restoration
Because many contaminants sorb to sediments, sediment criteria
could be helpful in evaluating the potential environmental risk
posed by in-place pollutants. For example, under Section 303 of
the Clean Water Act, sediment criteria could be used to help
determine whether an area might benefit from cleanup activities.
Under this and other laws (Table 2) sediment criteria could be
used to help (1) determine the need for cleanup, (2) set a goal
for cleanup, thereby helping to determine the size of the area to
be addressed and, thus, the cost of the cleanup effort, and (3)
assess the degree of benefit to be realized by cleaning up an
area to meet the criteria.
Evaluation of in-place pollutants in aquatic sediments could be
one of the most appropriate and immediate applications of
sediment criteria. The administrative ease of having established
numbers for comparison could, however, encourage over-reliance on
the criteria. Because identification of candidate areas for
cleanup is likely to be viewed as a less precise process than
issuing or denying a permit, there would be less incentive to
adhere rigidly to a fixed number. The utility of sediment
criteria in evaluating candidate areas for cleanup would increase
if criteria were available for a large number of chemicals.
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6.2.5 Environmental Impact Statements (EISs)
Sediment criteria could be helpful in evaluating alternatives in
the preparation of EISs (Table 2) under the National Environ-
mental Policy Act. In this context, sediment criteria could
provide one part of the quantitative basis for comparing the
environmental benefits or consequences of various alternatives,
including the no-action alternative, to the proposed action. The
use of sediment criteria in this context would require field or
model data to predict the accumulation of contaminants in sedi-
ments as a result of the proposed action and each of the
alternatives. Sediment criteria could then be used to help
evaluate the potential for unacceptable adverse impacts
associated with each of the alternatives.
7.0 RECOMMENDATIONS
o Both the regulatory and regulated communities need to continue
to have access to all information and documentation developed
in support of this effort. As progress is made on sediment
criteria development, the dissemination of information becomes
more critical to minimize unnecessary concerns and misdirec-
tions. Readily available information on the status, progress,
and direction of sediment criteria development is the key to
ensuring unnecessary uneasiness or concerns are kept to a
minimum. It has been the practice in the past to ensure that
any person with an interest in sediment criteria development
will be able to obtain copies of all documents and work plans
generated in support of this effort. This practice should
continue and become more pro-active to make people aware of
the existence of key documents.
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o The scientific and administrative review underway and planned
for the sediment criteria now being developed should be widely-
publicized. All those concerned with sediment criteria
development should be made aware of the scientific oversight
of the developmental work by the Sediment Criteria Technical
Steering Committee, past and future presentations of work at
national scientific meetings such as the Society for
Environmental Toxicology and Chemistry (SETAC), and the
planned review of the developmental process and the criteria
by the EPA Science Advisory Board (SAB).
o A technical workshop to allow the scientific community to
critique the sediment criteria development process should be
scheduled before the process is finalized. This should be a
much larger and more diverse group than the Technical Steering
Committee. The group should be provided with the physical/
chemical model for sediment-contaminant-water interactions,
and the protocols for chemical and biological te'sts, to be
used in developing sediment criteria. The workshop should be
followed by a Technical Steering Committee meeting to review
and revise the criteria development process as appropriate in
consideration of the results of the workshop.
o Sediment criteria should be developed for as many chemicals as
possible. Sediment criteria will be needed for as many of the
metals and organic compounds commonly of concern in sediments
as possible. Ongoing research should provide a method for
developing sediment criteria for metals. Coordination between
the water quality criteria and advisory program and sediment
criteria program to increase the number of nonpolar organic
compounds for which chronic or advisory water quality criteria
are being developed would result in a one-foc-one increase in
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the number of sediment criteria available. In addition, the
use of toxicological end points other than chronic water
quality criteria should be pursued.
8.0 SUMMARY
The greatest utility of sediment criteria in the near term is
likely to be in a variety of applications to identify existing
and potential problem areas. The first sediment criteria that
are developed may most appropriately be applied to identify
and confirm the potential impact of highly contaminated
sediments. With contaminated sediments near or less than the
criteria values, the criteria may be used as one tier in a
tiered approach to sediment quality assessment.
Implementation of many laws and regulations can be improved or
made easier with sediment criteria. These laws and regula-
tions are mainly concerned with siting, 'permitting, and
monitoring of discharges and dump sites; identifying and
cleaning contaminated areas; and preparing environmental
impact statements.
20
-------
9.0 REFERENCES
Engler, R.M. 1980. Prediction of Pollution Potential Through
Geochemical and Biological Procedures: Development of
Regulatory Guidelines and Criteria for the Discharge of
Dredged and Fill Material. R.A. Baker (ed.)
Contaminants and Sediments. Ann Arbor Science, Ann
Arbor, Mich.
EPA, 1975. Navigable Waters: Discharge of Dredged or Fill
Material. Federal Register 40 (173), September 5,
1975.
EPA. 1980. Water Quality Criteria Documents; Availability.
Federal Register 45(231), November 28, 1980.
EPA/CE. 1977. Ecological Evaluation of Proposed Discharge of
Dredged Material into Ocean Waters; Implementation
Manual for Section 103 of Public Law 92-532 (Marine
Protection, Research, and Sanctuaries Act of 1972).
July, 1977 (second printing April 1978), Waterways
Experiment Station, vicksburg, Miss.
Neff, J.M. 1985. Sediment Criteria Integrated Work Plan.
Report to U.S. EPA Criteria and Standards Division
under Contract 68-01-6986, WA 13. 12 pp.
Pavlou, S., R. Kadeg, A. Turner, and M. Marchlik. 1987.
Sediment Quality Criteria Methodology Evaluation:
Uncertainty Analysis of Sediment Narmalyation Theory
for Nonpolar Organic Contaminants. Prepared by
Envirosphere Corporation for EPA Criteria and Standards
Division. Submitted by Battelle Washington
Environmental Programs Office.
21
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APPENDIX A
DISCUSSION OF A SURVEY OF NEEDS
AND USES FOR SEDIMENT CRITERIA
A-l
-------
APPENDIX A
DISCUSSION OP A SURVEY OP NEEDS AND USES FOR SEDIMENT
CRITERIA
A. 1.0 INTRODUCTION
To supplement the technical expertise and regulatory knowledge of
the sediment criteria development team and review group, it was
desirable to contact the regulatory and regulated communities to
confirm the characteristics and potential uses of sediment
criteria for a variety of applications. Therefore, discussions
were held with key personnel in EPA offices and programs as well
others that have potential uses for sediment criteria. This
appendix reports the results of these discussions.
A.2.0 METHODS
A.2.1 IDENTIFICATION OF KEY PERSONNEL
The original list of interview candidates was compiled by Drs.
Richard Peddicord, James Fava, Christina Cowan, and H. Suzanne
Bolton. An attempt was made to contact representative epa
offices in each coastal or Great Lakes region that has expressed
an interest in sediment criteria. Additional contacts were
solicited at the conclusion of each interview. Ultimately, the
list of interview candidates increased to over 100, reflecting
the wide interest which exists in sediment criteria.
A-2
-------
A.2.2 THE INTERVIEW PROCESS
A questionnaire was designed for use during telephone discussions
which directed participants through a three-tiered examination of
their need for sediment criteria, the characteristics which would
make the criteria suitable for their applications, and the
specific chemicals for which sediment criteria are needed. The
questionnaire was carefully planned to minimize the possibility
of influencing the responses by the phrasing or context of the
questions. The questionnaire (Table A-l) was approved by the
Work Assignment Leader and the program office prior to the
interview process. The interview format began with a descriptive
introduction of the purpose of the survey, explaining that
Battelle was conducting the study for EPA Criteria and Standards
Division. The stated purpose of the interview was to assess the
need, the potential applications, and the desired scientific
characteristics of sediment criteria. The interview was
conducted in a conversational tone using follow-up questions to
clearly identify the candidate's position on each topic. Because
responses were not biased by limits imposed by a particular
question, an accurate characterization could be made in the final
evaluation of the survey results.
A.3.0 RESULTS AND DISCUSSION
A total of 29 interviews were conducted between March 4 and May
8, 1987. The scope of contacts included eight,EPA Regional
Offices, three EPA Environmental Research Laboratories, five EPA
Headquarters offices, two National Oceanic and Atmospheric
Administration (NOAA) offices, five Army Corps of Engineers
offices, three state regulatory offices, two members of the
academic community, and a public utility (Figure A-l). The
discussion that follows is based on the results of these
A-3
-------
TABLE A-l- 'Jig^T1 ""1TW USUI ODBXBB TEUnOHE OOHVEBSAXIOtB UJIfmUIJOTG SEDXM3TT QtZTEBZA OETtXOPnBHT AMD USE.
Data: has: ____________ Organization: _______________________ Phooa: ______________
DO ton HAVE A HEED FOR jjKUUUUW QONUTX CRITERIA?
Is your office concerned (involved) with environmental effects of contaminated sediment? __ Soil? _____
In your opinion, what is the regulatory mandate of your office for sediment protection? Under what existing laws or
regulations would you use sediment criteria?
I ] Clean Water Act [ 1 Ocean Dumping [ ] NEPA { ] EIS Other:
In your opinion, are new, enabling regulations needed in order for your office to regulate sediment contamination
using sediment criteria (SC)?
What approaches are you now using to determine whether or not sediment may be considered a problem (contaminated)?
In your opinion, how would the development of SC improve the way your office presently deals with contaminated
sediments? (Compared to whatever guidelines you working with now?)
Would you envision SC as possibly becoming the basis of state regulatory requirements?
wbmt mraaaxsm do too seed to regulate potehtial uivuiuiimskm. impacts op cdstamihated sediments?
Two conceptual approaches have been identified for using SC. One approach would present a single value or a single
value with uncertainty to be used as a pass-fail regulation, the second approach would present the SC as the first-cut
in sequence of tiered steps. Which type of approach would be most useful to you in regulating sediments: Pass-fail
Sequence of tiered steps
If pass—fail, which would probably be most useful Co your office:
A single value or a single value with uncertainty ? Discussion.
If a sequence at tiered steps, which would be most useful to your office?
A technique such as bioassay which could be used as a first-cut flag or as base for litigation?
or a sequence of tiered steps similar to that presently used in developing water quality criteria? Discussion.
What level at scientific strength do you feel you need for SC compared, for instance, with water quality criteria?
In your opinion, does the derivation procedure need to go through formal rule-making like water quality criteria?
mn MB TBI MAJOR CHEMICALS OP C-Uwmui HI SEDmntS?
Tor what classes of chemicals would SC be useful to you?
( 1 PCBs ( 1 Dioxin ( 1 Metals: ( | chlorinated Pesticides
Other Specific Cheaucals of Concern: ————————————
Other Comments: ________________________
Can you recommend other people who you think I should contact about this subject:
A-4
-------
FIGURE A-l. NUMBER AND APPILIATION1 OF INDIVIDUALS CONTACTED IN A
SURVEY ON SEDIMENT CRITERIA DEVELOPMENT AND USE.
A - Army Corps of Engineers, B - EPA Regional Offices, 0 - EPA
Environmental Research Laboratories, 0 » State Agencies, E - NOAA,
Academic Community, etc., F - EPA Headquarters Offices.
-------
interviews and is intended to be illustrative rather than a
quantitative sampling of opinions. Responses are those of the
individual interviewee, and do not represent any consensus of
views in the respondents' organization or area. The results of
the survey, summarized in Table A-2, are discussed in the
following section.
A.3.1 MANDATE FOR REGULATION OF SEDIMENT CONTAMINATION
Of the 29 individuals contacted, 97% were concerned with the
environmental effects of contaminated sediments. The Ocean
Dumping Act and the Clean Water Act are the primary regulatory
mandates cited by those involved with sediment contamination,
representing 41 and 31%, respectively, of those interviewed.
Eighteen percent of those surveyed were involved with the
registration of chemicals, including pesticides, herbicides, and
new formulations. Eighteen percent were involved in Superfund
or Resource Conservation and Recovery Act (RCRA) cleanup issues,
and 17% evaluated sediments under National Environmental Policy
Act (NEPA) regulations.
A.3.2 PRESENT APPROACHES USED IN
SEDIMENT CONTAMINATION REGULATION
In the absence of centralized guidelines, a variety of approaches
have been adopted. In many cases, no single method has been
adopted by similar offices or within regions. The approach taken
seems to be driven, at least in part, by the perceived magnitude
of the problems and the backlog of sites awaiting evaluation.
The two general approaches used to assess contaminated sediments
are case-by-case evaluations (59%) and mandatory bioassays (38%).
Where the case-by-case approach is used, historical data, bulk
chemical analyses, and bioassays are usually part of a sequence
of tiered decision-making steps. Results of bioassays are used
A-6
-------
tmle a-2. swart or a teumub sukvr omdocted between march 4 add my a, 1987 with ranivnxitts selected tor their
mULVMHT WRB UUUUT (3UTERIA DEVELOPMENT! AMD USE.
Respondent Categories1
A B C D E r Total
Number of Respondents: 5 8 3 3 5 5 29
Is your office concerned with environmental
«ffacts of contaminated sediments?
Yes
100
100
100
100
100
80
97
No
-
-
-
-
_
_
Not Yet
-
-
-
-
-
20
3
In your opinion, what is (are) tha regulatory
mandate*s) of your office for sediment protection?
(More than on* choice possible).
Ocean Dumping
60
75
33
67
-
20
41
Clean Water
60
25
33
67
20
20
31
PTFRA, TSCA
20
-
66
-
-
60
18
RCRA, Superfund
20
12
33
33
20
-
18
NEPA
20
37
-
33
-
_
17
SRPA
-
12
-
-
-
_
4
N/A
-
-
33
-
30
-
7
What approaches are you now using to determine
sediment contamination?
Case by case Tiered Approach
40
50
-
100
100
60
59
Manditory Bioassays
60
50
100
-
-
20
38
N/A
-
-
-
-
-
3
3
How would tha development of SC improve the
w«y your office presently regulates contaminated
sediments? (More than one choice).
Additional Weight in Decision-making
40
25
33
67
60
60
45
Provide Cutoff Number vs
Bast professional Judgement
40
38
-
-
40
40
34
Eliminate Manditory Bioassays
-
12
33
-
-
-
10
Ho Effect (Mould not use)
20
25
33
33
-
-
17
Mould a sequence of tiered steps or a pass-fail
•pproach be most useful to you in regulating the
Potential environmental impact of contaminated
sediments?
Tiered Steps
80
12
100
rn
100
«0
76
Pass - fail
-
12
-
-
-
-
1
Combination of Tiered Steps t Pass-Fail
-
12
-
-
>0
10
Neither
.:o
li
~
-
.:o
10
*A rn Corps of rnijin«Ti 8 - EPA Regional Offices C - EPA Environmental MMtKh Labortories, D
B » Miscellaneous, r « EPA Headquarters Offices.
Stat* Sa^ulitots,
A-7
-------
TABLE ft-2. (Continued).
Hambmi of Respondents
A
5
Respondent Categories
B
a
c
3
D
3
Total
29
How would you us* SC in decision-making?
first-cut Screening
Added Weight
TSCA Approach (cut-off affects criteria)
None of Above
Won't Use
20
40
40
38
50
12
Percent of Respondents
33
67
67
33
40
60
20
60
20
31
45
10
4
10
What level scientific strength do sediment
criteria need to be useful and enforceable
for your office? (More than one choice).
Very Strong
Legally Defensible
More Research Reeded
Advisory or Guidance
Peer Review
Need Specific Chemicals
60
60
20
20
62
25
25
50
25
67
33
67
33
67
33
67
100
20
20
40
40
20
80
20
20
40
62
14
34
31
34
10
Are new, enabling regulations needed in order
for your office to regulate sediment contamination
using sediment quality criteria?
Ye s
No
Maybe
N/A
Irrelevant
20
60
20
38
50
12
33
33
33
67
33
40
60
20
60
20
24
48
7
10
7
In your opinion, does the derivation procedure
need to go through formal rule-making like
water criteria?
Yes
No
Hope Not
Doesn't Care
Not Yet
N/A
Would you envision a Sediment Criteria becoming
the basis of state regulatory requirements?
Yes
Maybe
Hope Not
No
N/A
20
20
20
20
20
20
20
20
JO
25
12
25
25
12
50
25
12
12
33
33
33
67
33
60
33 20
33
33 20
33
33
60
JO
80
20
¦10
20
•JO
34
21
14
4
17
10
45
2$
10
1
14
See previous page.
A-8
-------
either as a basis for requiring further work (chemical analyses
or bioaccumulation tests) or are, themselves, the endpoint used
for decision-making. In cases where bioassays are mandatory,
these other parameters may or may not be. examined as part of the
decision-making process.
A.3.3 APPLICATIONS AND ADVANTAGES OF SEDIMENT CRITERIA
A. 3.3.1 Immediate Applications
In general, many respondents (76%) envisioned using sediment
criteria as part of the tiered decision process they now use.
One respondent suggested: "Sediment chemistry values would be
compared to the sediment criteria. If sediment concentrations
were well below the criteria value, no bioassays would be
required and a permit would be issued. If sediment concentra-
tions were well above the sediment criteria values, bioassays and
more specific analytical chemistry would be mandatory. If
sediment concentrations were close to the sediment criteria
values, the amount and kind of future testing and analysis would
be determined by evaluation of the available data based on best
professional judgment."
A.3.3*2 Long-Range Applications
Most respondents are eager for some type of sediment criteria and
readily suggested potential applications for sediment criteria.
In general, applications fall into three categories: prediction
and planning, baseline establishment, and expediting decision
making. In all these applications the desire for numbers based
on scientifically rigorous testing (i.e., lab and field verifi-
cation of the values) was universal. The regulation of municipal
and industrial discharges involves not only the types of
decisions required in dumping permits, but also long-range.,
planning, since discharges represent what is essentially chronic
exposure. Sediment criteria would be useful in the planning,
A-9
-------
prediction, and decision-making required in discharge permits.
A.3.3.2.1 Prediction and Planning
Dumping. There is a widespread desire for the ability to predict
both the potential short-term impact of the disposal process
itself and the long-term effects of dumping on the dumpsite
before regulating decisions are finalized. Sediment criteria
could help evaluate potential effects of contaminants
accumulating in sediments from various dumping activities.
Discharges. Sediment criteria could be used to help evaluate
trends in transport of contaminants from point and non-point
sources. They could be incorporated into software inventories
that would track present discharge levels from point sources, and
predict whether contaminant accumulation rates from all sources
would require action. Used in conjunction with effluent testing,
estimates of storm water run-off and other non-point source
contributions, and hydrologic models for specific water bodies,
sediment criteria could help evaluate the environmental
importance of dispersal, settling and accumulation of
contaminated sediments. Sediment criteria could be incorporated
into environmental fate and effects models to help assess the
potential for unacceptable adverse impact. Such predictive
models would require both lab and field testing before they could
be used with assurance.
Planning. Many states recognize the need to plan the use of
waterways and to anticipate the cumulative effects of many point
and non-point sources of pollution. Some states are in the
process of developing master plans for the use and protection of
lakes, rivers, harbors and estuaries. Sediment criteria could be
A-10
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incorporated into long-term planning as clean-up targets, or as
average maximum allowable levels.
A.3.3.2.2 Baseline Establishment
The need for baseline data is a common theme among respondents.
Most areas have no baseline or historical data which can be used
to help determine what is. clean and what is contaminated.
Sediment criteria could help provide a target number for cleanup,
a comparative baseline for dredging and dumping decisions, and a
benchmark number for examination of the cumulative effects of
outfalls. Sediment criteria could be used in sediment surveys to
create contamination maps, noting trends of contamination spread
and patchiness, which could be used as indicators of the overall
condition of water bodies.
A. 3.3.2.3 Decision-making
Sediment criteria would permit respondents to streamline the
permitting process. The crisis that many face is typified by the
respondent who said "I'm so backlogged with NPDES permits that I
don't even have time to think about sediments." While this is an
extreme case, the backlog of permits and decision making is
universal. This backload is created not only by the volume of
applicants but by the approach used by most offices in making
decisions on a case-by-case basis. In many cases the same
information is recreated with each application.
Dumping. Sediment criteria based on bioavailability could be
used to help determine whether additional testing were needed and
if so, what types of testing would be appropriate for a specific
site. One survey respondent thought "Sediment criteria might do
away with need ,for bioassays if the bulk chemistry analysis could
A-11
-------
be judged against a defensible sediment criteria number... allow-
ing evaluation of dumping impact without requiring bioassays."
Discharges. In the need for decision-making tools, most
respondents would use sediment criteria primarily as part of a
sequence of tiered steps. Sediment criteria would probably be
incorporated into state regulations as a target for sediment
loading or contamination, and could be used as part of the basis
for closing areas for shellfishing. In some cases, sediment
criteria would probably be used like the water quality criteria,
providing a fixed number for enforcement. Many respondents
feared such an over-application of sediment criteria, and this
would be beyond the intent of the criteria.
A.3.4 DESIRABLE SCIENTIFIC CHARACTERISTICS FOR
SEDIMENT CRITERIA
Regardless of the specific application, the survey supports the
contention that the decision to use sediment criteria will be
based primarily on the confidence respondents have in the
derivation process. The essential characteristic that will
ensure this confidence can be summarized in one word: data. The
recurring theme of "Good data... enough baseline data... real
data...hard data..." makes this the critical issue for acceptance
and use of sediment criteria.
Sediment criteria will be used either as stand-alone numbers for
regulatory purposes, or in conjunction with an application
factor, or as part of already existing decision-making
procedures. Those who are potentially involved in litigation
activities (62% of respondents), commonly expressed the view that
they cannot use sediment criteria as the basis for permits or
litigation if the numbers are not "scientifically defensible...
rigorous...with strong teeth... hard... real..." Almost 34% of
A-12
-------
respondents desired to see sediment criteria developed as the
water quality criteria were developed: with multispecies, round
robin testing, peer review, public scrutiny, and finally, Federal
Register publication. Some feel that both field and laboratory
testing are necessary to support the sediment criteria. Many
survey respondents recognized that this process could take 5 to
10 years, and suggested that sediment criteria advisories or
guidance documents be published in the interim. On the other
hand, sediment criteria will require much less testing and
validation for the 31% of respondents who said they will use the
values only as guidance. In these cases, the values must only be
supported by "a good database that supports the criteria
derivation process."
In either case, most respondents believed that sediment criteria
should consider the interrelationships between sediment
contamination, bioaccumulation, and toxicity.
A.3.5 LEGISLATION
A.3.5.1 Need For Formal Rulemaking
The mandate to regulate the contamination of sediments and to
remediate sediment contamination is contained explicitly or
implicitly within the framework of existing legislation. In
some cases, the decision-making criteria are contained in the
legislation itself. In order for sediment criteria to be
implemented in these cases, new legislation may be required.
Where the decision-making process is loosely defined and left to
the regulating office, it is unlikely that new legislation will
be required.
A-13
-------
Under its present mandate, the U.S. Army Corps of Engineers would
not use sediment criteria, alone, as specific cut-off numbers.
Because their mandate requires that decisions include other
considerations in addition to potential environmental impact,
sediment criteria would not, in themselves, drive the decision.
Because the Corps has no requirement to use sediment criteria
values, many Corps respondents (60%) feel that there is no need
for new regulations. In addition, sediment criteria could be
used as guidance within the context of present regulations.
Many respondents either were unsure or disagreed on whether new
legislation would be required in order for them to use sediment
criteria: 48% felt that no new regulations would be needed, but
31% thought that new legislation was possibly or definitely
required. In general, acceptance depended upon the specific
application for which sediment criteria will be used. If used as
a technical aid, sediment criteria would not require new enabling
legislation because published technical documents become articles
of practice or support documentation for many regulating offices.
In fact, as one respondent said: "Sediment criteria presented in
guidance documents will be of more use to a wider audience:
formal structure loses application." On the other hand, 34%
felt that the sediment criteria should go through the same formal
rulemaking and review as did the water quality criteria: 21%
felt that formal rulemaking is not necessary and another 17%"felt
that it is not desirable at this time. The rulemaking process
would provide the exposure to and comment from the scientific
community needed if sediment criteria are to be used in
litigation. One respondent stated, "If sediment criteria do not
go through the same rigor as the water quality criteria they will
be second-class citizens."
Some respondents thought that the Clean Water Act, the Ocean
Dumping Act, and Superfund may have to be modified in order to
A-14
-------
use sediment criteria for some applications. Some feel that the
mandate to use sediment criteria may exist implicitly in water
quality criteria and that if sediment criteria are as environ-
mentally protective as water quality criteria, there will be no
need for additional legislation. In freshwater applications,
some felt "it will be difficult to link discharges to elevated
contamination levels down-stream" in remediation efforts based on
sediment criteria without new legislation.
A.3.5.2 Legislation at the State Level
Based on the results of this study, 45% felt that sediment
criteria would become the basis of state regulations and another
28% saw a potential for this use. While there is a great need
for numerical guidance, 10% of the respondents at either Federal
or Regional offices expressed concern that numerical values
published by EPA would probably be written into state legislation
without full understanding of the intent and proper application
of the numbers. Therefore, legally and technically defensible
sediment criteria values are essential and would require both
public scrutiny and peer review through publication in the
refereed scientific literature.
Many states are creating and promulgating sediment criteria for
their own use. Both Washington and Wisconsin are developing
state-wide sediment criteria at present. Federal sediment
criteria and the methodology developed to derive these criteria
should augment the State efforts and provide a basis for meeting
multistate needs in interstate waterways.
A.3.6 CHEMICALS OF WIDEST CONCERN
The specific chemicals for which sediment criteria are needed are
determined by the regulations and permits implementing the
A-15
-------
environmental laws. Some permits require testing of the full
suite of priority pollutants. Others require bulk analysis of
specific classes of chemicals or target individual chemicals. At
the state level, additional specific chemical analyses may be
required.
The six major classes of chemicals for which sediment criteria
are most needed according to the respondents are the heavy metals
(72%), followed by PCBs (59%), PAHs (41%), chlorinated pesticides
(34%), dioxins (24%), and "persistent compounds" (17%). (Table
A-3 ) .
A.3.7 EXAMINATION OF MAJOR CONCERNS
Only 7% of those interviewed expressed no concern over the
present sediment criteria development strategy as they understood
it. All others voiced a variety of opinions about the need to
modify the development process. Over 50% expressed the opinion
that the present sediment criteria development is not sufficient-
ly effects-based. They felt that the criteria should include
risk assessment for a defined level of protection and should
include an assessment of the effects of bioaccumulation. Eighty
percent expressed some concern for the chemical methodology,
questioning the validity of extrapolating sediment criteria
derived from single-chemical testing to complex mixtures and a
variety of geochemical parameters, and the inadequacy of the
present state of the science to sample and measure contaminant
concentrations consistently. Forty-one percent expressed concern
about the potential for over- or under-regulating sediment
contamination, the misuse of sediment criteria values by the
states, or overly rapid development of sediment criteria. These
misunderstandings can be addressed if the long-range plans for
sediment criteria development and implementation are described.
A-16
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TABLE A-3. CHEMICALS NAMED BY SURVEY RESPONDENTS AS ONES FOR WHICH
SEDIMENT CRITERIA WOULD BE USEFUL. RESULTS ARE REPORTED AS
THE PERCENT OF RESPONDENTS IN EACH CATEGORY AND AS THE
PERCENT OF THE TOTAL NUMBER INTERVIEWED.
Percent
Respondent Category of Total
Chemical Type A B C D E F Respondents
Heavy metals
100
88
67
67
60
40
72
PCBS
100
88
33
33
40
20
59
PAH
60
38
33
100
40
-
41
Chlorinated Pesticides
40
25
-
33
40
60
34
Dioxin
80
25
-
-
-
20
24
Persistent compounds
20
-
33
33
20
20
17
Carcinogens
-
-
67
33
-
-
10
Chlorinated hydrocarbons
20
-
-
67
-
-
10
Total organics
-
25
-
-
20
-
10
Priority Pollutants
-
25
-
33
-
-
10
Oil & Grease
-
25
-
-
-
—
7
Furans
20
-
33
-
-
—
7
DDT
20
12
-
-
-
—
7
Neutral hydrophobics
-
-
-
-
-
20
4
Bioaccumulatable cmpds.
-
-
-
33
-
-
4
Charged Organics
-
-
-
-
-
20
4
Total Phosphorus
-
12
-
-
-
-
4
Volatile Organics
-
12
-
-
-
-
4
Organic Nitrogen, Carbon
-
12
-
-
-
-
4
Organophosphate
-
-
-
-
-
20
4
Incineration Products
-
-
33
-
-
-
4
Nutrients
20
-
-
-
-
-
4
Organic Distillates
20
-
-
-
-
-
4
Total Dissolved Sulfides.
-
12
-
-
-
-
4
Total Organic Carbon
-
12
-
-
-
-
4
A-17
-------
Open communication with respondents will be the crucial factor in
the recognition and acceptance of sediment criteria. A sampling
of respondent thoughts and concerns is presented in Table A-4.
A-18
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TABLE A—4. REPRESENTATIVE COMMENTS FROM RESPONDENTS TO THE TELEPHONE
INTERVIEWS.
"If sediment criteria were based on good data, they could be used as part
of the assessment for whether or not testing was necessary." Corps of
Engineers
"Walk carefully. Nontechnical people want an easy number. This usually
results in overregulating or underregulating." Corps of Engineers
"Once there's a baseline, maybe we won't have to do analysis every time."
Corps of Engineers
"I like the partitioning-based idea of sediment criteria for hydrophobic
organics combined with field testing." Corps of Engineers
"If sediment criteria are related to bioaccumulation and toxicity they
would provide numerical criteria which could be used with bioassays." EPA
Region 1
"Sediment criteria should be commensurate with water quality advisories,
not criteria." EPA Region 1
"The present analytical methods aren't good enough for a certified
document. Sediment criteria should be issued in a guidance document."
EPA Region 2
"I basically doubt that a good baseline can be developed." EPA Region 2
"Sediment criteria would legitimize the decision to forego
bioassays... sediment criteria might provide a relaxation of the bioassay
requirement, which is very costly." EPA Region 4
"Pilot them. Try them in real-life situations." epa Region 5
"Sediment criteria would be a parameter factored into the assessment of
dredging- or construction-generated sediments for disposal; a target for
sediment loading or contamination." EPA Region 9
"Strong scientific strength would be nice but right now it's seat-of-
the-pants anyway. Sediment criteria would give us a place to start." EPA
Region 9
"Sediment criteria would be a number to go by just like water quality
criteria to be used for enforcement vs best professional judgement. They
nust be site specific and compared with a reference site, and must take
into account naturally occurring high values." EPA Region 9
"Sediment criteria must have more than a theoretical base. They must
incorporate field data and biological fate information, and must be
Predictive." EPA Region 10
A-19
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