United States Science Advisory EPA-SAB-EC-03-008 Environmental Board (1400A) May 2003 Protection Agency Washington, DC wwiv.epa.gov/sab oEPA CONTAMINATED SEDIMENTS SCIENCE PLAN: AN SAB REPORT A REPORT BY THE CONTAMINATED SEDIMENTS SCIENCE PLAN REVIEW PANEL OF THE EPA SCIENCE ADVISORY BOARD (SAB) ------- May 30, 2003 EPA-SAB-EC-03-008 Honorable Christine Todd Whitman Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Subject: Review of the Contaminated Sediments Science Plan: A Science Advisory Board Report Dear Governor Whitman: The Contaminated Sediments Science Plan Review Panel (Panel) constituted under the auspices of the Executive Committee of EPA's Science Advisory Board conducted two public teleconferences and drafted preliminary responses to the Agency charge questions prior to a two- day public face-to-face meeting with Agency personnel on October 30-31, 2002 at which the June 13, 2002 draft Agency document, Contaminated Sediments Science Plan (CSSP) was reviewed. The review was conducted at the request of the Office of Solid Waste and Emergency Response. The Panel was charged with evaluating the adequacy of the CSSP in addressing a range of contaminated sediments issues, as well as considering the methods exemplified by the CSSP for cross-Agency science planning. Following the October 2002 meeting, the Panel was engaged in extensive internal discussions focused on refining its draft responses to Agency charge questions. Resolution of outstanding technical issues was achieved through the scheduling of two additional public conference calls that ultimately led to the Panel's unanimous approval of the CSSP review document. The purpose of the attached report is to advise you and the appropriate management at EPA, particularly the Agency's Science Policy Council, of the Panel's findings and recommendations. The overarching goal of the CSSP is to provide a mechanism by which Agency science activities that support contaminated sediments risk management decisions can be more effectively prioritized, managed and coordinated. The Panel acknowledges that development of the CSSP represents a major step in cataloguing contaminated sediment work at the EPA, and that this alone will foster improved coordination within the Agency. However, the Agency's goals for cross-Agency science planning set a performance standard for the CSSP that revealed critical weaknesses in the plan's design complicating the task of review. ------- Consequently, the Panel sought clarification of the purpose of cross-Agency science planning from EPA representatives. The Agency informed the Panel that cross-Agency science planning was conceived as a necessary tool to inform and coordinate science and research activities across various Agency programs. Cross-Agency science planning would function to both characterize Agency science needs as well as to select and prioritize those science activities required to support specific EPA environmental goals. Members of the Panel were in full agreement that these functions were desirable, and if addressed systematically, could significantly improve the Agency's effectiveness in managing the risks associated with complex, multi-jurisdictional environmental issues. The selection of contaminated sediments as the first multi-jurisdictional environmental issue on which to apply the cross-Agency science planning process was a courageous choice, as the area is multifaceted and broadly affects a number of Agency program offices. The Panel acknowledged the significant level of effort expended by the CSSP work group in compiling the information contained in the CSSP draft. This effort will substantially contribute to building awareness of important contaminated sediment work across the Agency. However, in the absence of information on the research being conducted on sediments in other Federal, State and regional governments, the utility of the CSSP as a foundation for coordinating current and future contaminated sediments science activities at EPA is of limited value. The Panel asserts that a broader review of pertinent science is necessary for the Agency to establish defensible research priorities. The Panel identified other substantive deficiencies in the draft document that also limited its value as a basis for science planning including insufficient or otherwise inadequate scientific justification for supporting a range of specific research activities (Section 4). The Panel was particularly concerned with the absence of a coherent framework governing plan development, implementation and assessment, and the lack of relationship to other Agency planning activity. In the absence of this framework and identifiable criteria for science priority setting, the material presented in the draft document is most reasonably viewed as an "inventory" or "synthesis" of the Agency's current contaminated sediment science related activities. The need for the development of a defensible science planning framework is so fundamental to addressing complex and multi-jurisdictional environmental problems, that the Panel does not recommend extensive revision of the CSSP work group's document, although numerous technical comments and suggestions for improvement are provided in this review. Instead, the Panel suggests that the development of a model science plan, undertaken with sufficient resources and a coherent vision, should be the focus of the Agency's efforts to refine the process for science planning. The Panel proposes that an alternative technical area be selected, one that is less complicated, more easily assembled, and offering a fresh approach to development of a defensible cross-Agency science plan. The need to revise the CSSP, and the process to produce an unassailable contaminated sediments science plan, should be evaluated by the Agency once a satisfactory model science plan has been developed. ------- The Panel repeatedly returned to questions of science planning design in the discussion of the CSSP Agency charge questions. The CSSP suffered primarily from the absence of such a defined process for the development of a science plan. The CSSP did clarify the need for a systematic and transparent planning framework as necessary to establish credibility for the recommendations. However, a strong consensus emerged among the Panel members that before an Agency science plan undergoes review, there should be clear evidence that it was developed through application of an approved process for science planning. In constructing the required framework, the Panel recommends that the Agency include the following elements. a) An explicit statement of the rationale and process used to support both the identification of cross-Agency science gaps and the associated science activity recommendations designed to fill those gaps. b) A full and explicit description of the criteria used to prioritize the science needs as well as recommendations. c) A description of the cross-Agency science plan's implementation framework that clearly identifies the roles and responsibilities of those Agency offices accountable to senior management for successful execution of the plan. Selection criteria and a transparent planning framework are necessary for the Panel to make unqualified statements on the adequacy of the range of scientific disciplines or science questions in the CSSP. For example, Charge Question Two asked if the major areas of contaminated sediment science identified in Chapters Two and Three are addressed adequately. Panel members with expertise in the areas of human health and risk communication identified serious deficiencies in the Agency's description of science activities that ostensibly support these specific technical areas. The establishment of technically defensible criteria for the selection of appropriate scientific activities would enable an objective evaluation of the CSSP's "adequacy" in addressing contaminated sediments science issues. To summarize, the Panel supports the intent of cross-Agency science planning as described in the draft CSSP Section 1.0 Goals and Objectives. In particular, Figure 1-1 on Page 2, "expected results: Improved environmental decision-making which is more informed and has a sound science basis" reflects the Panel's unanimous opinion of what science planning should accomplish. However, the Panel finds that the CSSP as submitted lacks the framework required of a science plan for defensible science activity selection, prioritization and evaluation. The present document provides a valuable inventory of current and ongoing Agency research efforts dealing with contaminated sediments. The Panel recommends that the current version of the CSSP be renamed to more accurately reflect its content. ------- We hope the recommendations contained in the attached report offer a constructive contribution to the development of science planning at EPA, and the safe, effective management of contaminated sediments. We would be pleased to answer any questions you or your staff may have. Sincerely, /S/ /S/ Dr. William Glaze, Chair Dr. Michael McFarland, Chair EPA Science Advisory Board Contaminated Sediments Science EPA Science Advisory Board Plan Review Panel ------- NOTICE This report has been written as part of the activities of the EPA Science Advisory Board, a public advisory group providing extramural scientific information and advice to the Administrator and other officials of the Environmental Protection Agency. The Board is structured to provide balanced, expert assessment of scientific matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention of trade names or commercial products constitute a recommendation for use. Distribution and Availability: This EPA Science Advisory Board report is provided to the EPA Administrator, senior Agency management, appropriate program staff, interested members of the public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is also provided in the SAB's monthly newsletter (Happenings at the Science Advisory Board). Additional copies and further information are available from the SAB Staff [US EPA Science Advisory Board (1400A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460-0001; 202- 564-4533. U.S. Environmental Protection Agency ------- Science Advisory Board Contaminated Sediments Science Plan Review Panel CHAIR Dr. Michael McFarland, Utah State University PANEL MEMBERS Mr. Steve Bay, Southern California Coastal Water Research Project Dr. Frank Bohlen, University of Connecticut Dr. Caron Chess, Rutgers University Dr. Deborah Cory-Slechta, University of Rochester Dr. Richard Di Giulio, Duke University Dr. Fred Pfaender, University of North Carolina Mr. Douglas Splitstone, Splitstone and Associates Dr. Thomas Theis, University of Illinois Dr. Herbert Windom, Skidaway Oceanographic Institute FEDERAL EXPERT Mr. L. Jay Field, U.S. National Oceanographic & Atmospheric Administration SCIENCE ADVISORY BOARD STAFF Mr. Lawrence Martin, Designated Federal Officer Ms. Mary Winston, Management Assistant 11 ------- TABLE OF CONTENTS 1. EXECUTIVE SUMMARY 1 1.1 Background 1 1.2 Charge to the Panel 1 1.3 Summary 5 2. INTRODUCTION 7 2.1 Background 7 2.2 Summary of Process Used by the Panel 8 2.3 U.S. EPA Charge to the SAB CSSP Review Panel 10 3. RESPONSE TO THE EPA CHARGE BY THE REVIEW PANEL 12 3.1 Charge Question 1 12 3.2 Charge Question 2 13 3.3 Charge Question 3A 13 3.3.1 Goal 1 14 3.3.2 Goal 2 14 3.3.3 Goal 3 15 3.4 Charge Question 3B 15 3.5 Charge Question 3C 16 4. ADDITIONAL COMMENTS AND SUGGESTIONS FROM PANEL MEMBERS 20 4.1 Sediment Site Characterization 20 4.2 Exposure Assessment 22 4.3 Human Health Risk Assessment 23 4.4 Ecological Risk Assessment 25 4.5 Sediment Remediation And Monitoring 26 4.6 Risk Communication And Community Involvement 26 4.7 Information Management And Exchange Activities 27 4.8 CSSP Report Organization 28 5. RECOMMENDATIONS FOR SCIENCE PLANNING AT EPA 30 REFERENCES R-l APPENDIX A - Contaminated Sediments Science Plan Review Panel Biosketches A-l in ------- 1. EXECUTIVE SUMMARY 1.1 Background The US Environmental Protection Agency (EPA) Science Advisory Board (SAB) established a panel to review the Agency's Contaminated Sediments Science Plan (CSSP). This expert panel (Panel) conducted two public teleconferences and drafted preliminary responses to the Agency charge questions prior to a two-day face to face meeting with Agency personnel on October 30-31, 2002 at which the June 13, 2002 draft document, Contaminated Sediments Science Plan (CSSP) was reviewed. The review was conducted at the request of the Office of Solid Waste and Emergency Response. The Panel was charged with evaluating the adequacy of the CSSP in addressing a range of contaminated sediments issues, as well as considering the methods exemplified by the CSSP for cross-Agency science planning. The overarching goal of the CSSP communicated by EPA to the Panel is to provide a mechanism by which Agency science activities that support contaminated sediments risk management decisions can be more effectively prioritized, managed and coordinated. The Panel learned from the Agency briefing that an impetus for this planning effort arose from the Agency's Corrective Action Strategy response to Government Accounting Office (GAO) recommendations in 1994. It was learned that the U.S. EPA's Science Policy Council (SPC) established the Agency-wide "science plan" as a mechanism to facilitate the coordination of Agency-wide science activities that support crosscutting, multi-jurisdictional environmental issues. In 2000, the SPC identified the management of contaminated sediments as an important cross-Agency environmental issue, the coordination of which could benefit significantly from the implementation of a science plan. The Contaminated Sediments Science Plan (CSSP) is the first Agency science plan to be developed, according to background included in the Agency's CSSP briefing to the Panel. 1.2 Charge to the Panel The CSSP identified three goals: a) Development and dissemination of tools and science necessary to address the management of contaminated sediments; b) Enhancement of the level of coordination and communication of science activities dealing with contaminated sediments across the Agency; and c) Development of an effective, cost-efficient strategy to promote these scientific activities, including research. In preparing its draft responses to the Agency's charge questions, the Panel first sought to clarify the intent of cross-Agency science planning at the EPA. Based on the face to face discussions with Agency personnel, the Panel's understanding is that cross-Agency science planning, of which the CSSP was the Agency's first effort, should be designed such that the scientific criteria established for environmental issue resolution are well defined and transparent ------- to the reader. Furthermore, cross-Agency science plans must be scientifically defensible and supported by a systematic process for identifying and prioritizing scientific needs. The development of the CSSP was not supported by the use of a systematic decision-making process. Particularly with respect to science activity "prioritization" an explicit goal or objective must be specified. As part of the prioritization process, cataloging of different activities and documentation of their anticipated benefits, in qualitative or physical terms, is necessary, but not sufficient. A plan that calls for prioritization of activities, with respect to any reasonable objective function, is not possible without corresponding information concerning the resource requirements of these competing activities. These costs are not addressed. Thus, the CSSP cannot achieve its nominal objective of providing such a prioritization. Consequently, the Panel unanimously concluded that the CSSP does not successfully meet the basic requirements of a technically defensible science plan. The Panel's conclusion, in this regard, severely complicated its ability to fully address the Agency's charge questions, each of which presumed that the CSSP was developed using a sound scientific approach. The Panel members agreed that addressing the charge questions was the necessary mission of the Panel. Therefore, every effort was made to respond to the specifics of the charge questions. Where the absence of a scientifically defensible planning framework limited the Panel's ability to provide a full and direct response to charge questions, the Panel reiterates the importance of this attribute in science planning. The Panel stresses that, while significant time was spent discussing technical comments and suggestions for improvement to the CSSP, which are detailed in Section 4 of the Panel's report, the absence of a defensible planning framework precludes the Panel from recommending significant additional resources be dedicated to revising the CSSP in its current form. Instead, the Panel suggests that the development of a model science plan, undertaken with sufficient resources and a coherent vision, should be the focus of the Agency's efforts to refine the process for science planning. The Panel proposes that an alternative technical area be selected, one that is less complicated, more easily assembled, and offering a fresh approach to development of a defensible cross-Agency science plan. The need to revise the CSSP, and the process to produce an unassailable contaminated sediments science plan, should be evaluated by the Agency once a satisfactory model science plan has been developed. A summary of the Panel's responses to the Agency's charge questions follow. Charge Question 1: Are the goals and objectives of the plan understandable and appropriate to the subject and does the CSSP adequately convey the need for such a planning document? The CSSP was an ambitious undertaking that documents current Agency science activities and needs associated with contaminated sediments including research, management, implementation and communication. Its breadth and description of the technical complexities and scientific unknowns reflect a clear sense of the need for systematic and careful planning if effective risk management decisions are to be developed for contaminated sediment sites. While the Panel commends the Agency's formulated goals, which are clear, the Panel concluded that the CSSP does not identify science gaps or propose recommendations to fill those gaps utilizing a process that is scientifically defensible or transparent. The Panel concurs that ------- the CSSP reflects, in general terms, a need for science planning, but in its present form, constitutes an inadequate response to that need. Charge Question 2: Are the major areas of contaminated sediments science identified in Chapters Two and Three (sediment site characterization, exposure assessment, human health effects and risk assessment, ecological effects and risk assessment, sediment remediation, baseline and post-remediation monitoring, risk communication, and information management and exchange activities) addressed adequately? Are any major areas missing? Selection criteria and a transparent planning framework are necessary for the Panel to make unqualified statements on the adequacy of the range of scientific disciplines or science questions in the CSSP. Although Panel members agreed among themselves that the range of science areas identified within the CSSP seemed appropriate, Panel members with expertise in the areas of human health and risk communication identified serious deficiencies in the Agency's description of science activities that ostensibly support these specific technical areas. The establishment of technically defensible criteria for the selection of appropriate scientific activities would enable an objective evaluation of the CSSP's "adequacy" in addressing contaminated sediments science issues. Charge Question 3A: Do the CSSP recommendations meet the CSSP's goals and objectives? In support of the three stated CSSP goals, the Agency puts forward thirty-three recommendations. Although there is some degree of overlap, twenty-five of the recommendations are mainly in support of Goal 1, and eight of Goal 2. No direct recommendations in support of Goal 3 were provided by the Agency. Goal 1. Development and dissemination of tools and science necessary to address the management of contaminated sediments. The Panel commends the Agency for applying the risk assessment/risk management paradigm1 in identifying and categorizing the relevant science activities, an approach that is consistent with Agency policy and supported by the Science Advisory Board (Toward Integrated Environmental Decision-Making - EPA-SAB-EC-00-011). The report articulates many important scientific questions concerning the management of contaminated sediments. However, in the absence of an articulated and transparent framework for decision-making the Panel could only rely on its own judgment to determine if these are the most appropriate set of questions. While the Panel expressed a reasonable level of comfort with the effort described to develop "tools and science necessary to address the management of contaminated sediments," it was the unanimous opinion of Panel members that the criteria for success should be clearly reasoned and articulated in a science plan, and not left to the judgment of the reader. The CSSP would benefit from the application of a systematic process designed to identify and prioritize Agency science activities based on scientifically defensible criteria. 1 National Research Council (NRC), Managing Risk in the Federal Government, National Academy Press, 1983 3 ------- Goal 2. Enhancement of the level of coordination and communication of science activities dealing with contaminated sediments across the Agency. If a clear plan cannot be articulated now, at minimum, the science should be better coordinated so the plan can be effectively developed. The CSSP seems particularly deficient in this area and could benefit from a more systematic approach to planning that incorporates the needs and values of stakeholders from both within and outside the Agency. Goal 3. Development of an effective, cost-efficient strategy to promote these scientific activities including research. As noted above, the Panel identified no specific recommendations in support of Goal 3. The report does specify several activities aimed at promoting Agency wide contaminated sediment related scientific activities including: 1) convening scientific workshops and meetings, 2) conducting surveys of Agency activities related to contaminated sediments, 3) identification of unfunded activities related to contaminated sediments, 4) continual updating and improvement of the CSSP plan to reflect advancements in scientific knowledge and 5) coordination of CSSP implementation through the efforts of the Contaminated Sediment Management Committee (CSMC). Taken together, the Panel acknowledges that these activities are elements of an implementation plan. However, without the benefit of a systematic planning approach, the elements constitute a list of important activities rather than a coherent and defensible science plan implementation strategy. Charge Question 3B: Are the key recommendations clearly defined and appropriate to address the identified CSSP science needs and are the priorities identified appropriate? The Panel noted that most of the recommendations described in CSSP Chapters Three and Four address important scientific or program needs within the Agency and are, therefore, appropriate for inclusion in the CSSP. However, in some cases, the specific recommendations are not consistent with the identified science needs. This inconsistency appears to be the result of the absence of a systematic and scientifically defensible planning process that can be applied to identify science needs and prioritize associated cross-Agency recommendations. Given that the CSSP has failed to demonstrate that it was developed using a systematic process or framework, the Panel finds it difficult to discern the relevance of the proposed implementation time frames for the recommendations. Charge Question 3C: Are the CSSP's recommendations responsive to the identified need for coordination, particularly intra-agency. By its very nature, the Panel sees that the CSSP is responsive to the goal of improved intra and inter-Agency coordination. The Panel questioned the absence of a more thorough description of the role of other Federal agencies, states and tribes in its research description, and science information management and exchange activities. Active and continuing collaboration with these and other outside agencies, and greater attention to how the Plan is responsive to the concerns of stakeholders is considered by the Panel to be essential to the ultimate success of any EPA contaminated sediment science planning effort. The Panel, without reservation, strongly encourages the Agency to fully acknowledge that work and evaluate whether specific Agency science needs or recommendations are currently being addressed by other agencies in any further ------- development of the CSSP. The key recommendations provided by the CSSP provide a clear indication of Agency offices and programs that should be involved in a coordinated effort. Most of the key recommendations list other federal agencies as suggested partners, but the level of information provided is insufficient to clearly understand the types and range of interactions supported by the CSSP. Without the establishment of a transparent and systematic framework for CSSP implementation including management accountability, the role of the CSMC may fall subject to parochial interests. A number of panel members expressed support for the development of a cross-Agency science plan implementation strategy that would offer greater detail than provided in the CSSP. The CSSP did not provide any description of how other planning efforts within the Agency, including the overall EPA strategic plan, were considered in its development. Effective cross-Agency science planning should ensure that science activity needs are appropriately considered within the science budgetary discussions. The CSMC (or its designated representative) must effectively coordinate and be held accountable for communicating and championing those critical contaminated sediment science needs within the Agency's Research Coordination Team (RCT) deliberations. The Panel recommends that the Agency clearly describe how the goals and objectives outlined in the CSSP are integrated with other Agency planning efforts. In addition to responding to the specific Agency charge questions, individual Panel members also identified a number of scientific activity and planning concerns for consideration by the Agency as part of any future science plan effort targeting contaminated sediments. The Panel did not engage in extensive discussion on these suggestions, and consequently they do not represent a panel consensus, but rather highlight a set of professional opinions based upon panel member's relevant experience and scientific expertise. The suggestions and supporting rationale are provided within the text of the report. 1.3 Summary In general, the Panel considered the CSSP to provide a valuable synopsis of the contaminated sediment related science activities in which the Agency is currently engaged. The CSSP provided both a clear and concise portrayal of the regulatory framework within which contaminated sediment environmental issues must be addressed. It also provides a detailed list of recommendations formulated to reduce uncertainties in scientific knowledge critical for supporting Agency risk-based decision-making. Although development of the CSSP clearly represents a considerable effort by the Agency, the Panel unanimously agreed that, in its current form, the CSSP serves only as a first step in creating a defensible science plan. The Panel encourages the Agency to change the name of the CSSP, insofar as the Panel found that the document does not adequately meet the purpose for which a science plan is purportedly intended. Rather than a science plan, the panel suggests "inventory" or "synthesis document." Extensive revision of the process for developing the CSSP would be necessary to achieve the systematic and scientifically defensible product understood by the Panel to be the function of an cross-Agency science plan. The Panel does not recommend ------- comprehensive modification of the CSSP, rather advises the Agency to first revisit the fundamental issue of cross-Agency science planning. Cross-Agency science planning, the Panel acknowledges, is a relatively new process whose success depends upon the application of a systematic, scientifically defensible framework to facilitate plan implementation, incorporate accountability and provide a clear methodology for maintaining continuous improvement. The Panel asserts that the cross-Agency science planning process must be unassailable if it is to enhance the credibility of Agency environmental science planning and programs. Consequently, the Panel identified the following three components as necessary and integral to a defensible cross-Agency science plan. a) An explicit statement of the rationale and process used to support both the identification of cross-Agency science gaps and associated science activity recommendations designed to fill those gaps. b) A full and explicit description of the criteria used to prioritize the science needs as well as recommendations. c) A description of the cross-Agency science plan's implementation framework that clearly identifies the roles and responsibilities of those Agency offices that are accountable to senior management for successful execution of the plan. It is the Panel's contention that science planning that proceeds in the absence of addressing these essential components is unlikely to generate a defensible cross-Agency science plan. The Panel agreed that, since the CSSP was not developed through the application of a transparent and systematic planning process, its value was limited in terms of providing a technically defensible blueprint for coordinating Agency-wide contaminated sediment science activities. The Panel suggests improvements to the Agency's science planning process, and recommends that the Agency develop and implement a transparent process to identify, prioritize and manage scientific information clearly in support of risk management decision-making. The Panel encourages the Agency to formulate a cross-Agency science planning framework based upon existing peer-reviewed planning models, citing recent SAB advice to the Agency strongly endorsing a more systematic approach to identifying and prioritizing the science activities that support risk based Agency decisions (EPA-SAB-EC-00-011 - Toward Integrated Environmental Deci si on-Making). The complexity of contaminated sediment science requires a broad based interdisciplinary approach involving social scientists, economists, engineers, legal scholars and the full range of life and earth scientists. Given this complexity the Panel recommends that the Agency consider selecting a simpler subject as the focus for its initial science planning effort. This approach would allow timely development of the required planning framework and its implementation from research priority setting to the evaluation of plan effectiveness. Following Agency testing and acceptance, the resulting planning process could be applied to the subject of contaminated sediment science. ------- 2. INTRODUCTION 2.1 Background The Science Advisory Board Executive Committee convened an expert panel (Panel) to review the June 13, 2002 draft document, Contaminated Sediments Science Plan (CSSP). The review was conducted at the request of the Office of Solid Waste and Emergency Response (OSWER). The Panel was charged with reviewing the adequacy of the CSSP in addressing a range of contaminated sediments issues, as well as considering the methods exemplified by the CSSP for cross-Agency science planning. The CSSP states its intended functions are the development and coordination of cross- Agency science activities in the contaminated sediments area. These functions are performed by providing an analysis of the current Agency science activities in this area, identifying and evaluating the science gaps, and providing recommendations for filling these gaps. The CSSP reports that sediment contamination is an issue that cuts across offices and jurisdictions throughout the Agency, other federal agencies, state agencies, and tribes; and that significant resources are spent by a number of Agency offices to address contaminated sediment problems. U.S. EPA offices identified by the CSSP that are addressing this problem include: the Superfund Program, Office of Water, Office of Solid Waste, Great Lakes National Program Office, Office of Pollution Prevention and Toxic Substances, Office of Research and Development, and U.S. EPA Regional Offices. These offices operate under the mandate of many statutory provisions including the Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), the Oil Pollution Act (OPA), the Toxic Substances Control Act (TSCA), and the Marine Protection, Research, and Sanctuaries Act (MPRSA). OSWER provided the SAB Panel a briefing at which the Agency indicated that, in response to the crosscutting and multi-faceted dimensions of the Agency's contaminated sediment program, EPA's Science Policy Council (SPC) initiated the development of the Contaminated Sediments Science Plan (CSSP) in 2000. The impetus for this planning effort arose in part, the Panel learned, as an element of the Agency's Corrective Action Strategy response to Government Accounting Office (GAO) recommendations in 1994. Science planning is intended to improve multi-media integration of the research planning process. Therefore, a principal function of the Agency-wide science plan is to provide a systematic means to portray and fully integrate the Agency's science needs associated with cross-cutting environmental issues into the established strategic planning, and research prioritizing and budgeting framework. In effect, the Panel observes, an Agency-wide science plan must transparently inform research- planning deliberations so that the final list of Agency supported research activities clearly and appropriately reflect Agency environmental science priorities. The CSSP states that it does not constrain recommendations to fit prescribed resources. Instead, the recommendations are a comprehensive list that U.S. EPA organizations can consider when balancing resource allocations across competing high-priority needs. ------- The CSSP reports itself to be the first formal example of an Agency science plan on a specific cross-Agency office- and region-wide activity. The expectation was communicated to the Panel by the Agency charge that additional science plans, addressing other cross-cutting issues, will be formulated to improve EPA's environmental decision-making, and conserve both human and financial resources. Three goals are stated in the CSSP to promote a strong scientific basis for addressing contaminated sediments: a) Development and dissemination of tools and science necessary to address the management of contaminated sediments. b) Enhancement of the level of coordination and communication of science activities dealing with contaminated sediments across the Agency. c) Development of an effective, cost-efficient strategy to promote these scientific activities, including research. 2.2 Summary of Process Used by the Panel The SAB Panel's overall evaluation and assessment of the CSSP included the following activities: a) A public meeting in Washington, D.C. October 30 and 31, 2002, preceded and followed by multiple telephone conferences. b) Team drafting of written responses to specific Agency's charge questions, including recommendations to improve the CSSP for Agency consideration; c) Evaluation of the general intent of the cross-Agency science planning process; and d) Development of recommendations to improve the current Agency science planning structure. In reviewing the CSSP, the Panel's deliberation gradually differentiated into the following categories of comments, which form the structure of the Panel's report: a) Responses to the Agency's charge questions; b) Recommendations that speak more generally to the overall process of cross- Agency science planning, including scientific defensibility and management; and c) A list of science activity recommendations specifically tailored to fill important gaps in the Agency's current contaminated sediment science knowledge base. ------- The Panel's initial efforts were focused on addressing the specific Agency charge questions. However, in formulating its responses to the charge questions, the Panel was challenged to understand the purpose of cross-Agency science planning, including how the design of the CSSP as a model science plan could be improved to serve the Agency's mission. The need for adopting a systematic science-planning framework, transparency of criteria used for prioritization of science plan recommendations, coordination of stakeholder participation, and management accountability for science plan implementation were issues that clearly went beyond the Agency charge; but became critical in the Panel's response to the charge. The Panel felt compelled to address these critical and far reaching concerns, given the role of the CSSP in establishing a defensible model for future cross-Agency science plans. Following Agency briefings to the Panel on October 30, 2002 describing the role of the CSSP in coordinating Agency supported science activities, the Panel found it necessary to modify its prior understanding of the organizational focus and intent of the CSSP. The following bullets, which were presented to and received concurrence from Agency staff at the October 30 & 31st Panel meeting, summarize the Panel's current understanding of the function of the CSSP in managing contaminated sediment related science activities. a) Identify and compile those contaminated sediment science activities and needs from across the Agency that are determined to be critical in establishing defensible risked based environmental decision-making. b) Use the compilation and synthesis of Agency-wide contaminated science activities and needs to promote more effective coordination and communication of science activities across Agency program offices and regions. c) Establish science priorities across the Agency by determining the extent to which science needs are being addressed by current Agency science activities. d) Encourage the Agency-wide adoption of a science plan paradigm as a cost- effective approach for establishing science priorities and associated allocation of resources when addressing cross-cutting, multi-faceted, multi-jurisdictional environmental issues. The Agency's clarification of the CSSP's anticipated function in coordinating science activities was welcomed, and aided the Panel in formulating its responses to the specific Agency charge questions. In preparing its draft responses to the Agency's charge questions, the Panel first sought to clarify the intent of cross-Agency science planning at the EPA. Based on the face to face discussions with Agency personnel, the Panel's understanding is that cross-Agency science planning, of which the CSSP was the Agency's first effort, should be designed such that the scientific criteria established for environmental issue resolution are well defined and transparent to the reader. Furthermore, cross-Agency science plans must be scientifically defensible and supported by a systematic process for identifying and prioritizing scientific needs. The ------- development of the CSSP was not supported by the use of a systematic decision-making process. Particularly with respect to science activity "prioritization" an explicit goal or objective must be specified. As part of the prioritization process, cataloging of different activities and documentation of their anticipated benefits, in qualitative or physical terms, is necessary, but not sufficient. A plan that calls for prioritization of activities, with respect to any reasonable objective function, is not possible without corresponding information concerning the resource requirements of these competing activities. These costs are not addressed. Thus, the CSSP cannot achieve its nominal objective of providing such a prioritization. Consequently, the Panel unanimously concluded that the CSSP does not successfully meet the basic requirements of a technically defensible science plan. The Panel's conclusion, in this regard, severely complicated its ability to fully address the Agency's charge questions, each of which presumed that the CSSP was developed using a sound scientific approach. The Panel members agreed that addressing the charge questions was the necessary mission of the Panel. Therefore, every effort was made to respond to the specifics of the charge questions. Where the absence of a scientifically defensible planning framework presents a problem in responding directly to charge questions, the Panel reiterates the importance of this attribute in science planning. The Panel stresses that, while significant time was spent discussing technical comments and suggestions for improvement to the CSSP, which are detailed in Section 4 of the Panel's report, the absence of a defensible planning framework precludes the Panel from recommending significant additional resources be dedicated to revising the CSSP in its current form. Instead, the Panel suggests that the development of a model science plan, undertaken with sufficient resources and a coherent vision, should be the focus of the Agency's efforts to refine the process for science planning. The Panel proposes that an alternative technical area be selected, one that is less complicated, more easily assembled, and offering a fresh approach to development of a defensible cross-Agency science plan. The need to revise the CSSP, and the process to produce an unassailable contaminated sediments science plan, should be evaluated by the Agency once a satisfactory model science plan has been developed. 2.3 U.S. EPA Charge to the SAB CSSP Review Panel The charge questions, which were formulated by an intra-Agency contaminated sediments task group, were presented to the Panel as follows: 1) The Contaminated Sediments Science Plan (CSSP) is the first official Agency science plan of its kind designed to address a significant cross-agency environmental issue in a systematic and integrated fashion. Chapter One of the CSSP discusses the goals, objectives, and how the CSSP relates to the Agency's mandate. Are the goals and objectives of the plan understandable and appropriate to the subject, and does the CSSP adequately convey the need for such a planning document? 2) Chapter Two of the CSSP provides an overview of the contaminated sediment problems and issues across the Agency. The brief description of issues in Chapter Two is meant to provide the overall context for the more detailed discussion of 10 ------- specific science needs given in Chapter Three. Are the major areas of contaminated sediments science identified in Chapters Two and Three (sediment site characterization, exposure assessment, human health effects and risk assessment, ecological effects and risk assessment, sediment remediation, baseline and post-remediation monitoring, risk communication, and information management and exchange activities) addressed adequately? Are any major areas missing? 3a) Chapter Four provides the key recommendations for future Agency priority science activities, including research, from the identified research needs and discussion in Chapter Three. For each recommendation, critical U.S. EPA partners and the immediate or long-term nature of the science activity are proposed. Do the CSSP recommendations meet the CSSP's goals and objectives? 3b) Are the key recommendations clearly defined and appropriate to address the identified CSSP science needs, and are the priorities identified appropriate? 3c) Are the CSSP's recommendations responsive to the identified need for coordination, particularly intra-agency? The Panel's responses to the Agency's charge questions (sections 3-7) are targeted narrowly to address only the question as posed. Section eight offers more detailed suggestions by Panel members arising from their discussion of the charge questions; and section nine makes recommendations for the development of future science plans. None of these responses should be construed by the Agency as an endorsement to substantially revise or otherwise modify the CSSP but, rather, should be recognized as strategic and technical guidance that the Agency may wish to consider as it addresses the issue of contaminated sediments, and in the development of future science plans. 11 ------- 3. RESPONSE TO THE EPA CHARGE BY THE REVIEW PANEL 3.1 Charge Question 1: Are the goals and objectives of the plan understandable and appropriate to the subject and does the CSSP adequately convey the need for such a planning document? The Panel learned that the CSSP represents the result of nearly two years of effort by a multidisciplinary group of Agency staff familiar with and working in the area of contaminated sediments. The CSSP was an ambitious undertaking that documents current Agency science activities and needs associated with contaminated sediments including research, management, implementation and communication. It considers both short-term science gaps and long-term risk reduction strategies. Its breadth and description of the technical complexities and scientific unknowns reflect a clear sense of the need for systematic and careful planning if effective risk management decisions are to be developed for contaminated sediment sites. While the Panel commends the Agency's formulated goals, which are clear, the Panel concluded that the CSSP does not identify science gaps or propose recommendations utilizing a process that is scientifically defensible or transparent. The Panel concurs that the CSSP reflects a need for careful science planning, but in its present form constitutes an inadequate response to that need. A defensible science plan should fully describe the planning process used to systematically identify and prioritize science gaps and the recommendations intended to fill those gaps. Without a transparent and systematically developed framework to support science planning, Agency risk management decisions are vulnerable to claims of inconsistency and/or bias. In structuring this framework, the Panel strongly recommends science coordination within the Agency as well as with external organizations (federal, state and regional) that are currently addressing contaminated sediment issues. The Panel applauds the Agency's recognition of the need for careful planning of science activities for crosscutting, multifaceted and multi-jurisdictional environmental issues. However, the Panel was unable to assess whether the CSSP development process adequately considered fundamental questions related to defensible science planning e.g., was the CSSP development based on cross-agency communication, how are the annual science priorities established by the Agency, how do the science priorities affect the call for proposals from external organizations and/or the annual science plans by EPA region, laboratories, hazardous substance research centers, etc.? A clearer description of the process employed by the Agency in developing the CSSP would provide a basis for evaluating its need and importance within the larger Agency planning framework. Finally, with respect to the appropriateness of its stated goals, the Panel suggests that the Agency consider explicitly highlighting the adaptive nature of the CSSP. Because the Agency reportedly intends for the CSSP to be continuously updated to reflect both current Agency science needs, as well as the latest scientific information relevant to contaminated sediment management, this characteristic of the CSSP should be emphasized. 12 ------- 3.2 Charge Question 2: Are the major areas of contaminated sediments science identified in Chapters Two and Three (sediment site characterization, exposure assessment, human health effects and risk assessment, ecological effects and risk assessment, sediment remediation, baseline and post-remediation monitoring, risk communication, and information management and exchange activities) addressed adequately? Are any major areas missing? Panel members agreed among themselves that the range of science areas identified within the CSSP seemed appropriate. Panel members with expertise in the areas of human health and risk communication identified serious deficiencies in the Agency's description of science activities that ostensibly support these specific technical areas. The establishment of technically defensible criteria for the selection of appropriate scientific activities would enable an objective evaluation of the CSSP's "adequacy" in addressing contaminated sediments science issues. Beyond the Panel's concerns regarding the absence of science activity selection criteria, several panel members expressed disappointment with the limited depth of technical transfer and capacity building activities described in the CSSP. Project managers and regional technical support staff would benefit from direct access to research laboratory scientists and the ability to develop studies designed to reduce major uncertainties in the information and models utilized for scientifically defensible decision-making. The primary means to achieve effective technology transfer identified in the CSSP consisted of conducting workshops and developing guidance documents. While these are important elements, greater benefit would be achieved by the Agency from placing additional emphasis on incorporating information of new technologies and approaches applicable to contaminated sediment management within existing regional training programs. For those technologies developed within the private sector, one panel member suggested that the Agency explore the potential of utilizing the Environmental Technology Verification (ETV) program for systematically capturing stakeholder needs and values in the development of appropriate testing protocols as well as for the diffusion of technology performance data. Additional suggestions provided by individual panel members addressing a range of scientific uncertainties associated with contaminated sediment management are contained in Section 4. Finally, several panel members noted that the development of innovative technologies that support defensible contaminated sediment decision-making will be of marginal value to stakeholders if their costs and/or required user skill level is prohibitive. To reduce costs and promote greater utilization of new technologies, a number of panel members expressed strong support for the explicit consideration of technical training needs in all cross-Agency science plans. 3.3 Charge Question 3A: Do the CSSP recommendations meet the CSSP's goals and objectives? In support of the three stated CSSP goals, the Agency puts forward thirty-three (33) recommendations, divided across eight categories, and classified according to long versus short- term priorities. Although there is some degree of overlap, twenty-five of the recommendations are mainly in support of Goal 1 (A.2 through A.4, B.I through B4, C.I through C.4, D.I through 13 ------- D.7, E.I through E.5, F.I, and G.I), and eight of Goal 2 (A.I, F.2, and H.I through H.6). No direct recommendations in support of Goal 3 were provided by the Agency. For each recommendation, the Agency program offices (and, in some cases, other federal agencies) that are principally involved in its implementation are identified. In addition, there is a Section 4.3, which is entitled Recommended Approaches to Implement Strategy. The following Panel responses address the adequacy of CSSP recommendations in satisfying each of the three specific goals. 3.3.1 Goal 1. Development and dissemination of tools and science necessary to address the management of contaminated sediments. The Panel commends the Agency for applying the risk assessment/risk management paradigm2 in identifying and categorizing the relevant science activities, an approach that is consistent with Agency policy and supported by the Science Advisory Board (Toward Integrated Environmental Decision-Making - EPA-SAB-EC-00-011). The report articulates many important scientific questions concerning the management of contaminated sediments. However, in the absence of a clearly articulated and systematic framework for decision-making, the Panel could only rely on its own judgment to determine if these are the most appropriate set of questions. Moreover, to ensure that science planning will result in effective coordination of cross-Agency science activities, it was the unanimous opinion of Panel members that the set of metrics utilized for verifying successful science plan implementation be fully described in the CSSP. In its current format, it is unclear how the CSSP ensures that critical technical issues related to contaminated sediment management have not been overlooked. For example, issues specifically addressing sediment sampling regimes, and statistically defining adverse risk in terms of analyte measurements should be discussed in the context of reducing uncertainty. And although recommendation A.4 focuses on the need to obtain more information about endocrine disrupter compounds, arguably, the larger issue relates to the development of a framework for identifying worrisome substances before they are released into the environment. The Panel strongly recommends that the Agency clearly identify the process that has been applied in establishing research needs, the degree to which external input has been included, and the methodology for capturing and utilizing feedback from scientific outcomes to continuously improve the function of the CSSP. 3.3.2 Goal 2. Enhancement of the level of coordination and communication of science activities dealing with contaminated sediments across the Agency. Coordination and communication across the Agency are critically important areas that must be addressed. If a clear plan cannot be articulated now, at minimum, the science should be better coordinated so the plan can be effectively developed. The CSSP seems particularly deficient in this area and could benefit from a more systematic approach to planning that incorporates the needs and values of stakeholders from both within and outside the Agency. The major mechanisms that are put forward in the CSSP for achieving more effective coordination of stakeholder needs and ' NRC. op.cit. 14 ------- interests are primarily workshops and conferences that target Agency managers and perhaps others from related government agencies. These are important activities, but are only a first step in addressing a technically complex and multi-jurisdictional issue such as contaminated sediment management. The Panel encourages the Agency to allocate sufficient financial and personnel resources to develop a systematic planning process with a clear aim to improve science coordination across the Agency and to facilitate communication with other governmental and non-governmental agencies dealing with contaminated sediment issues. One approach supported by several panel members includes recognizing the work of Agency scientists and managers who proactively facilitate interdisciplinary science coordination and cooperation. 3.3.3 Goal 3. Development of an effective, cost-efficient strategy to promote these scientific activities including research. As noted above, the Panel identified no specific recommendations in support of Goal 3. The report does specify several activities aimed at promoting Agency wide contaminated sediment related scientific activities including: 1) convening scientific workshops and meetings, 2) conducting surveys of Agency activities related to contaminated sediments, 3) identification of unfunded activities related to contaminated sediments, 4) continual updating and improvement of the CSSP plan to reflect advancements in scientific knowledge and 5) coordination of CSSP implementation through the activities of the Contaminated Sediment Management Committee (CSMC). Taken together, the Panel acknowledges that these activities could be viewed as elements of an implementation plan. However, since these activities are not systematically integrated, they do not constitute a defensible science plan implementation strategy. For example, the "cost-effective" need (which is assumed to be inclusive of financial and personnel allocations) articulated in Goal 3 is not addressed. Moreover, the plan admits to recommending priorities without consideration of actual resource constraints. The most important suggestion listed in CSSP Section 4.3 is probably the last one, namely to view the CSSP plan as an adaptive document that will require continual updating and revision as new scientific information becomes available, and the Agency's scientific needs and/or priorities change. The Panel supports the development of a science plan that is readily adaptable to the advancements in both Agency policy and scientific knowledge. A number of panel members suggested that the Agency explicitly describe the process through which new scientific information will be evaluated and incorporated into future versions of the CSSP. 3.4 Charge Question 3B: Are the key recommendations clearly defined and appropriate to address the identified CSSP science needs and are the priorities identified appropriate? The Panel noted that most of the recommendations described in CSSP Chapters Three and Four address important scientific or program needs within the Agency and are, therefore, appropriate for inclusion in the CSSP. However, in some cases, the specific recommendations are not consistent with the identified science needs. This inconsistency appears to be the result of the absence of a systematic and scientifically defensible planning process that can be applied to identify science needs and prioritize associated cross-Agency recommendations. Systematic planning requires a framework that ties together the recommended implementation activities, and thus provides a blueprint for moving forward on the 15 ------- recommendations and future revisions of the plan. The framework should be accompanied by realistic priorities and describe how research within the different subject areas (key scientific questions) will be coordinated and integrated across the different topic areas. Without such a framework, the CSSP will serve as little more than programmatic justification for each office's own science/research interests, rather than achieve the goal of a pragmatic, systematic and defensible approach to moving the science of environmental protection forward. Given that the CSSP has failed to demonstrate that it was developed using a systematic process or framework, the Panel finds it difficult to discern the relevance of the proposed implementation time frames for the recommendations. Moreover, several panel members expressed discomfort with the Agency's intent to implement a relatively large number of science recommendations within the immediate time frame and questions whether this schedule is realistic given the practical limitations on financial and personnel resources. Notwithstanding the CSSP work group's disclaimer concerning resource constraints, a number of panel members questioned the utility of future science activity prioritization efforts that do not acknowledge and consider resource limitations. 3.5 Charge Question 3C: Are the CSSP's recommendations responsive to the identified need for coordination, particularly intra-agency? The Panel finds that the CSSP represents a considerable effort by the Agency to organize its science activities associated with contaminated sediments so that coordination of those efforts is better achieved. By its very nature, the CSSP is responsive to the goal of improved intra and inter-Agency coordination. The Panel questioned the absence of a more thorough description of the role of other Federal agencies, States and Tribes in its research description, and science information management and exchange activities. Many states (e.g., California, Florida, Washington) have invested considerable resources in contaminated sediment science and have developed a number of useful tools for assessing problems (some of which are mentioned in the CSSP). Moreover, NOAA, USGS and the US Department of Defense (DoD) have ongoing contaminated sediment science programs that directly address many of the key recommendations. Active and continuing collaboration with these and other outside agencies is considered by the Panel to be essential to the ultimate success of any EPA contaminated sediment science planning effort. The Panel, without reservation, strongly encourages the Agency to fully acknowledge that work and evaluate whether specific Agency science needs or recommendations are currently being addressed by other agencies in any further development of the CSSP. The Panel commends the excellent compilation of Agency research summarized in Appendix A of the CSSP. The compilation of relevant science is useful in communicating current scientific activity. With an updating of this compilation and a more detailed cataloging of Agency research, this information may be used to identify science gaps, redundancies, research of low priority and opportunities to partner with other agencies/groups. Suggested improvements to Appendix A include the addition of complete contact information, addition of uniform resource locators (i.e., URLs) containing program documents/summaries, and the 16 ------- inclusion of relevant projects conducted by other federal agencies and organizations. Finally, adopting a transparent and more systematic approach to planning that appropriately balances stakeholder values and concerns with available resources is critical for ensuring the credibility of future Agency science plans. A defensible science-planning framework must specifically address how the interests and concerns of stakeholder groups are considered throughout the decision- making process. The key recommendations provided by the CSSP provide a clear indication of Agency offices and programs that should be involved in a coordinated effort. Most of the key recommendations list other federal agencies as suggested partners, but the level of information provided is insufficient to clearly understand the types and range of interactions supported by the CSSP. In some cases, the list of partners is too numerous to provide much specificity and no contact information is provided to assist in locating interested partners within each office. Furthermore, it is unclear as to whether this list is merely a suggestion of potential future partners or, alternatively, if this list has been strategically developed through systematically evaluating Agency needs with respect to the science and technical strengths of other agencies and organizations. Some standardization in the presentation of this information would be an improvement. The Panel understands that the CSSP is meant to be a living document that is adaptive to changing Agency focus as well as flexible in embracing new scientific information. Effective coordination must be part of a systematic program whose aim is continuous improvement. As such, science activity coordination should be a continual process applied throughout the year. As proposed in the CSSP, a once a year effort to rapidly compile information from disparate Agency groups may not be optimal. It may be more effective to form smaller and more focused intra-Agency task groups to review the status of specific science areas, plan implementation of recommendations, and improve coordination within the Agency. To provide greater confidence that implementation of cross-Agency science plans will be successful, the Agency is encouraged to establish a clear process and set of metrics that are appropriate to assess the effectiveness of science plan implementation. The recommended implementation strategy for the CSSP lists various activities (e.g., conferences, workshops, etc.) that should improve coordination of science activities within the Agency. However, these actions are not sufficiently described to permit an assessment as to how successful they are likely to be. The process and level of authorization by which the Contaminated Sediments Management Committee (CSMC) functions to implement the CSSP should be clearly described and not left to interpretation or speculation. Without the establishment of a transparent and systematic framework for CSSP implementation including management accountability, the role of the CSMC may fall subject to parochial interests. A number of panel members expressed support for the development of a cross-Agency science plan implementation strategy that would offer greater detail than provided in the CSSP. Effective cross-Agency science planning should ensure that science activity needs are appropriately considered within the science budgetary discussions. With regard to fully integrating the contaminated sediment science priorities into the appropriate Agency budgetary 17 ------- deliberations, one panel member acknowledged that the CSMC (or its designated representative) must effectively coordinate and be held accountable for communicating and championing those critical contaminated sediment science needs within the Agency's Research Coordination Team (RCT) deliberations. Without an effective mechanism to establish a meaningful dialogue with RCT representatives, cross-Agency science priorities may not find resonance with the RCT when competing against other science activities. Several panel members recommended that the CSMC should be held responsible for annually documenting both the prioritized list of science activity recommendations and its supporting technical justification for each RCT addressing science issues relevant to contaminated sediment management. This activity would, in effect, be a de facto order to each Program Office RCT representative to provide a full description of the ranking of science activities within the context of the RCT deliberations. The CSSP did not provide any description of how other planning efforts within the Agency, including the overall EPA strategic plan, were considered in its development. The CSSP makes a commendable effort in clarifying how contaminated sediments science activities supports Agency GPRA goals, but it fails to provide sufficient description of how it is to be integrated with other cross- Agency planning exercises and priority setting. For example, how will the goals and objectives specified in the CSSP be coordinated with the Agency's multi-year plan for mercury, endocrine disrupters or the Metals Action Plan? The Panel recommends that the Agency clearly describe how the goals and objectives outlined in the CSSP are integrated with other Agency planning efforts. A number of panel members expressed discomfort with the CSSP recommendation that the CSMC be tasked with the responsibility of identifying science areas where inter-Agency and/or intra-Agency partnerships are needed. From a technical standpoint, summarizing those science activities that would benefit from establishing partnerships is as important as establishing a defensible process for identifying science needs, and therefore should be identified in the CSSP itself. The role of the CSMC should be to facilitate the implementation of these partnerships, not to define them. The Panel supports continuous improvement in intra and inter-Agency science coordination as contaminated sediment science activities move forward. For example, within the contaminated site remedial process, affected sites (e.g., CERCLA and RCRA sites) provide important field laboratories for evaluation of technical approaches for measuring and assessing the ecological effects of contaminated sediments. Promoting more meaningful integration between research activities and site assessment has several important benefits to the Agency including: 1) the participation of research scientists in site assessment provides direct technical transfer to project managers and regional technical support staff; 2) researchers gain insight into the relevant questions and issues confronting decision-makers and the public in the application of science; 3) the establishment of a database that can be used to manage innovative technology performance information; and 4) development of pilot projects that can serve as effective teaching tools. Finally, remedial action decision-makers are often required to select risk reduction options despite significant uncertainty associated with the results of risk assessments and/or the 18 ------- effectiveness of the risk reduction option selected. The Agency is encouraged to consider application of quantitative uncertainty analysis to enable risk managers to more fully comprehend the level of statistical confidence associated with their remedial action decisions. 19 ------- 4. ADDITIONAL COMMENTS AND SUGGESTIONS FROM PANEL MEMBERS The Panel represented a diverse group of scientists and engineers whose breadth of technical expertise and experience offered insights the Agency management may chose to consider in addressing contaminated sediments science priorities. Although the Panel does not endorse comprehensive revision of the CSSP, in discussion of the charge questions the Panel identified technical issues, scientific needs and organizing strategies useful for any future science planning effort focusing on contaminated sediments. The suggestions are for the most part organized by the technical areas identified by the Agency as necessary for the SAB's review of the CSSP, with the exception of suggestions on the Plan's organization. In large degree they address those specific science gaps that the Panel members collectively or individually recognized as important in reducing uncertainty in contaminated sediment risk management decision-making. The Panel did not engage in extensive discussion or consensus building on these points, and consequently the listing is not represented as being unanimous, comprehensive or complete. While the recommendations are primarily focused on improvements to the CSSP, some are broad in scope and have applicability to the general activity of defensible science planning. The Panel strongly encourages the Agency to clarify that, in its current form, the CSSP serves primarily as a first step in the development of a defensible science plan. Although the CSSP did not appear to result from any systematic and transparent approach to science planning, the document does provide a compilation of cross-Agency science initiatives, which is a necessary and important first step in the establishment of a defensible science-planning framework for contaminated sediments. To distinguish the CSSP from future Agency science plans, the Panel recommends that the title of the CSSP should be modified to more accurately reflect what the document offers: The Contaminated Sediment Science Activity and Needs Inventory or Synthesis. The Agency should make explicit what role the CSSP will serve in its current form, clearly differentiating that role from one that would be supported by a systematically developed cross-Agency science plan. 4.1 Sediment Site Characterization • The CSSP makes several references to the importance of capturing the effects of sediment stability in the development of effective contaminant fate and transport models (e.g., Recommendations Al and B4). Several panel members expressed support for the Agency's claim that evaluation of sediment stability is important for developing defensible risk management decisions. However, these same panel members indicated that the broader and more fundamental question for site characterization (and ultimately risk assessment) is whether those processes that significantly impact contaminant mobility can be adequately characterized. For example, biological processes may significantly influence both sediment stability and contaminant mobility. Unfortunately, existing fate and transport models at best consider the effects of biological activity on contaminant mobility and sediment stability in a limited way. Understanding the effects of biological 20 ------- activity including the role and significance of aquatic vegetation on contaminant fate and transport processes is critical for estimating human health and ecological risk. Moreover, adequate characterization of these effects represents an important opportunity for effectively targeting Agency resources to reduce model uncertainty. The Agency is encouraged to evaluate the need for establishing a scientific research program with a focus on understanding biologically mediated contaminant transport mechanisms and to organize technical workshops that will serve as an effective forum for addressing other contaminant fate and transport mechanisms that significantly reduce the level of uncertainty. One panel member identified the need for developing Agency guidance that specifically addresses the advantages, limitations and reliability of current sediment dating methods (e.g., Pb 210, Csl37, Be7). The CSSP should explicitly describe the role of floodplains in exacerbating the human health and ecological risks associated with contaminated sediments in riverine ecosystems as well as their impact on terrestrial food chains. Floodplains should be considered during sediment characterization, ecological and human exposure assessment, remediation, monitoring, and risk communication. The development of Agency guidance that describes effective approaches for characterizing and assessing the human health and ecological risks associated with floodplain contamination was supported by a number of panel members. Several panel members commented on the technical challenges associated with the characterization of non-aqueous phase liquids (NAPL) contamination in sediments. To effectively characterize the risks associated with contaminated sediments impacted by NAPL as well as identification of suitable risk reduction options, a more comprehensive evaluation of these types of sites is warranted. At a minimum, the Agency should consider addressing the following specific questions within a CSSP: 1) how many sediment sites are affected by sub-aquatic NAPL discharges, 2) how can NAPL impacted sites be remediated, 3) what can be done to prevent future discharges of NAPL, particularly dense non-aqueous phase liquids (DNAPL), into waterways? Given the significant volume of scientific literature available that describes the presence of endocrine disrupters in the environment, one panel member expressed surprise that no analytical technique for quantifying alkylphenol ethoxylates (APEs) was identified within the list of CSSP priorities. Beyond APEs, the Agency is encouraged to consider whether or not the types and amounts of pharmaceutical compounds typically found in sediments currently pose an unacceptable risk to human health and the environment. The Agency's acknowledgment of the need to collect toxicity data on new contaminants of concern is commendable. Of particular importance are those contaminants that would be anticipated to be present at environmentally 21 ------- significant concentrations at contaminated sediment sites but which are not now routinely measured and/or characterized due to limited toxicological information (e.g., alkylated polycyclic aromatic hydrocarbons - PAHs). In the absence of this information, the results of risk modeling of contaminated sediment sites will be characterized by significant uncertainty. The majority of the Panel expressed support for a comprehensive multimedia approach to understanding the fate and transport of contaminants associated with contaminated sediments. To support risk based decision-making, the Agency must be able to scientifically document whether the rates of contaminant transfer between physical compartments e.g., transport from sediment to pore water, transport from pore water to the water column, transport from the water column to the atmosphere (and in the reverse direction) are sufficient to cause significant risk. Most fate and transport models assume equilibrium and/or steady state contaminant behavior, thereby ignoring the dynamic movement of contaminants within sediments. Although these modeling simplifications may be necessary for facilitating quantitative risk analysis, the conclusions drawn by decision-makers using these model results may be scientifically unsupportable. Since the formulation and structure of the fate and transport models significantly impact risk results, the Agency is encouraged to establish a scientifically defensible methodology for systematically evaluating and reducing model uncertainty. The Agency should include a more comprehensive discussion of the recent technological advancements in the areas of contaminant analytical detection methods, real time contaminant monitoring, remote sensing, continuous monitors with telemetry, bioassays on chips or arrays, new molecular methods for bioassays etc. all of which have the potential to significantly improve the Agency's ability to characterize sediments. Explicit discussion of these innovative technologies is important since such sensors/systems have the potential to increase our abilities to assess the temporal and spatial variability in contaminant concentrations and may reduce the overall cost of sampling. 4.2 Exposure Assessment Effective characterization of contaminant exposure in support of risk based decision-making may require the acquisition of specific data elements that are not necessarily associated with the physical and/or chemical characteristics of sediments. For example, one panel member suggested that the collection of data that would support the characterization of the surface micro-layer may be important for describing the transfer of organic contaminants to surface feeding biota, including aquatic insects and the birds and fish that feed upon them. Establishing a systematic approach for characterizing such factors and their influence on exposure model uncertainty would allow the Agency to identify those mechanistic components of models that merit further scientific investigation. 22 ------- PAHs are collectively identified with PCBs as persistent and bioaccumulative toxicants, although, it is well known that the mechanisms of PAH toxicity are much different than those associated with halogenated aromatics (e.g., PAHs are much more readily metabolized and their metabolites are often of primary concern). Developing the tools to measure exposure offish to PAHs is a science activity that is complementary to the Agency's expressed need for developing better analytical methods for evaluating fish tissue. Because of its potential impact on water quality, the Agency is advised to consider the risk to human health from potable water supplies impacted by pollutants associated with contaminated sediment. The mechanisms that regulate bioavailability will have a significant impact on site characterization, exposure assessment, toxicity assessment, and selection of effective risk management options. Because its effects are far reaching, the Agency should consider development of a systematic approach for quantifying contaminant bioavailability that includes the leveraging of Agency resources to establish collaborative partnerships with other federal agencies that currently have extensive research programs in this area. 4.3 Human Health Risk Assessment Several panel members commented that the Agency's contaminated sediment science program could benefit from establishing a science activity agenda that explicitly addresses the toxicological effects of contaminant mixtures. For example, although those panel members familiar with PCB human toxicity assessment methodologies generally supported the Agency's plan to evaluate the toxicology of individual PCB congeners, they highlighted the fact that Key Recommendation C. 1 failed to explicitly describe how the Agency will utilize this information to assess the risk of PCB mixtures. The full range of science issues associated with the toxicology of contaminant mixtures to humans could be more effectively addressed if this science activity were specifically targeted by the Agency and supported by a systematically developed research plan. Since a significant body of scientific literature exists that describes the human health effects of many of the chemicals that have been found at contaminated sediment sites, the Agency should describe how this information was used in developing CSSP priorities. The Agency is encouraged to formulate and implement a scientifically defensible approach for selecting and prioritizing those chemicals of concern that require further human health effects investigation. The determination of human health risks requires the assessment of the types and levels of exposure as well as the primary routes of exposure. Since a systematic framework for evaluating contaminant exposure was not described, it is unclear 23 ------- what role human health exposure assessment played in developing and prioritizing those human health research needs and recommendations cited in the CSSP. For example, a scientifically defensible rationale should have been provided by the Agency for supporting the evaluation of the human health risks associated with dermal exposure to contaminated sediments. The Agency should apply appropriate risk assessment models to systematically differentiate those exposure routes that warrant further evaluation from those that have an insignificant impact on human health risk. Several panel members suggested that the Agency systematically determine whether the following science activities should be assigned as priorities within the CSSP: a) Characterization of chemical interactions among multiple contaminants including pesticides typically found in sediments. b) Development of scientifically defensible methodologies to relate bioaccumulation results from animal studies to doses anticipated in humans. c) Studies designed to investigate mode- and mechanism-of-action for single chemical species and mixtures in sediments. d) Development of biomarkers that indicate exposure effect and relating these to measurable human toxicity endpoints. In several sections of the CSSP (e.g., 3.2. Sediment Site Characterization, 3.5 Ecological Effects and Risk Assessment), the Agency develops relatively large lists of site-specific parameters whose value could potentially impact the level of risk to human health and environment from contaminated sediments. For each of these parameters, the Agency should provide an explicit technical justification of their importance, as well as a description of the process used to establish the data quality criteria. Although several panel members expressed their support of the Agency's list of parameters, at least one panel member noted that the Agency had failed to demonstrate why resources should be expended to quantify their values. A potential approach to developing a scientifically defensible list of measurable parameters is to apply a sensitivity analysis to the selected risk assessment model in order to identify those model inputs that have the largest impact on risk results. From the subset of model inputs generated by the sensitivity analysis, those whose magnitude of uncertainty is relatively large could be targeted by the Agency as parameters that warrant further scientific evaluation (this is also applicable to ecological risk assessment). Sensitive sub-population studies are also mentioned within the CSSP, although no recommendations on this topic appear in the final list of Agency 24 ------- recommendations. This omission is a significant oversight since such studies are critical in establishing the variability of risk associated with targeted populations. Direct toxicity from contaminated sediments should be included within the list of human health effects (CSSP Page 10, Paragraph 2). 4.4 Ecological Risk Assessment Several panel members recommended that the Agency develop specific guidance for assessing risk to endangered and threatened species from contaminated sediments and for evaluating the effectiveness of various risk reduction options to mitigate risk to protected species. Significant limitations in the Agency's proposed use of benthic community analysis to support risk based remedial decision-making were identified. Benthic community analysis can be an effective approach for characterizing the ecological impact of contaminated sediments. However, because of the impact of habitat on benthic community diversity and population size, the Agency is encouraged to develop and apply ecological risk assessment models that appropriately address species variability. One panel member suggested that the Agency focus greater effort on developing additional chronic test endpoints for benthic invertebrate and fish species. For example, biological responses beyond mortality, growth impacts and reproduction effects should be considered by the Agency in establishing relevant ecological benchmarks. Environmental responses such as an impaired immune system, altered physiological function, and behavioral effects should be considered as potential endpoints. Moreover, it was suggested by a number of panel members that the Agency consider developing test endpoints employing a greater diversity of marine and freshwater test species for assessing toxicity and the effects of bioaccumulation. The goal should be to survey many species and select surrogates that represent a wide range of life history strategies and sensitivities to contaminants. Risk management decisions based on a limited number of species and test endpoints leads to increased uncertainty. To reduce uncertainty in risk decisions, the Agency is encouraged to develop a transparent and scientifically defensible process for indicator species selection that accounts for their range of sensitivities to contaminants. The Agency is advised to evaluate the impacts of multiple-generation exposures in aquatic organisms, including adaptations, associated fitness costs, and effects on gene structure and diversity (i.e., evolutionary impacts). Traditional toxicological testing does not take such important effects into account. The elucidation of such effects requires careful integration of field and laboratory studies. 25 ------- • Developing, improving, and testing sediment quality guidelines for the protection of benthic organisms, whether empirically derived or theoretical (EqP), requires data from various contaminant gradients. Assessing risk impacts chemical-by- chemical fails to account for addititive, synergistic or antagonistic chemical effects and has the potential to significantly underestimate the true exposure response. Research and guidance on approaches to assess the toxicity of mixtures of contaminants in sediment that account for interactive effects based on mechanisms of toxic action is critical for effective risk-based decision-making • The Agency is encouraged to develop effective scientific approaches to specifically reduce uncertainty associated with the measurement of ecological indicators. These approaches should be included in a general discussion of interpretive guidance for toxicity tests and other indicators of ecological effect. • A number of panel members expressed support for the Agency's decision to target science resources to assess the chronic effects of bioaccumulative contaminants on high trophic level aquatic organisms, including fish as well as marine and freshwater mammals. 4.5 Sediment Remediation And Monitoring • The Agency's current science activities aimed at understanding the effects of sediment capping and dredging on habitat alteration are important for supporting risk based decision-making. To benefit from the research supported by outside agencies and to more effectively leverage its own resources, the Agency is encouraged to comprehensively evaluate the field data available from numerous capped and dredged sediment sites. These data could yield important and useful scientific insight into the impact of various risk management alternatives on target marine organisms and species habitat. • Panel members expressed support for greater coordination and more extensive involvement of stakeholders from both within and outside the Agency in developing scientifically defensible contaminated sediment-monitoring guidance. Development of monitoring guidance should address the values and priorities of natural resource trustees and other stakeholders. 4.6 Risk Communication And Community Involvement • The CSSP should be commended for raising issues concerning local knowledge and development of partnerships, rather than merely focusing on one-way explanation of information. However, the basis of most of the CSSP risk communication problem statements and recommendations is unclear. Agency efforts to manage contaminated sediments should establish meaningful consultation with the EPA office of community relations to determine stakeholder needs and priorities. 26 ------- • A majority of the panel acknowledged the need for incorporating social science expertise in developing effective contaminated sediment risk communication programs. The ORD request for risk communication proposals (cited in Chapter 4) solicits ideas but was deemed to be inadequate for developing a comprehensive risk communication agenda suitable to support contaminated sediment decision- making. One panel member suggested that a systematic process be established that begins by determining if the Agency has a risk communication research agenda, and, if so, the extent to which it addresses issues relevant to contaminated sediments. If the Agency does not have a risk communication research agenda that may be examined for applicability to contaminated sediments, it will be important for EPA to establish an expedient process to develop a research agenda relevant to this environmental issue. This process might involve soliciting research topics from practitioners and academics, and establishing priorities with the assistance of an advisory committee of technical experts in the field. As with the other contaminated sediments research, it will be critical to assess the extent to which other government agencies have research programs in these priority areas. Because the NRC is embarking on the study of public participation in environmental decision-making, consultation with the NRC may be a valuable first step in understanding and incorporating lessons learned from outside agencies and organizations that have addressed this identical issue. • Several panel members recommended that the Agency develop a transparent and defensible framework that specifically outlines how the interests and concerns of stakeholder groups are considered throughout the entire science planning decision-making process. Chapter Two would benefit from explicit recognition of the value of systematically integrating the input from a broad group of stakeholders early in the contaminated sediment risk management decision- making process. 4.7 Information Management And Exchange Activities • A number of panel members commented that issues of data and information quality were not sufficiently addressed within the CSSP. It was further noted that Agency guidance requires that all data (scientific or otherwise) collected by or on behalf of the Agency be of the correct type and amount for its intended use including the support of Agency risk based decisions (EPA Order 5360.1, EPA QA/R-5). The Panel was unable to determine whether the data currently compiled in Agency databases is of the correct type and quality to support risk management decision-making. Furthermore, the Office of Management and Budget (OMB) has recently promulgated guidelines on information quality in response to the Data Quality Act (as amended to PL 106-554). These guidelines encourage, among other things, that information generated by the federal government that has a clear and substantial impact on public policy (including the analysis of risks to human health, safety and the environment) be characterized by 27 ------- objectivity, transparency and reproducibility. To ensure that the quality of information associated with the CSSP meets the intent of OMB guidance, the Agency is encouraged to recognize and fully implement the EPA quality system requirements within all science planning documents. Information management serves an important role in advancing the science associated with contaminated sediment management. Individual panel members commended the Agency for its decision to develop regional databases to compile, manage and store environmental data to support local risk management decisions. Furthermore, several panel members applauded the Agency's plan to expand the availability of relevant technical information to interested stakeholders by interfacing regional sediment databases with national databases (such as the National Sediment Inventory). However, to develop an effective blueprint for any database, the Agency was advised to first identify the intended audience(s) and the proposed uses of the data. The science questions that such databases are designed to support should provide appropriate guidance for its development. Utilizing a systematic approach that explicitly considers database requirements (e.g., type of data stored, interfaces needed, data quality requirements, roles of potential users, etc.) would enable the Agency to develop an efficient database structural design. Finally, the Agency is encouraged to conduct a comprehensive review of existing environmental databases to identify those that could provide relevant scientific information in support of the Agency's contaminated sediment data management system. One panel member reminded the Agency of the April 29, 1998 memorandum from Deputy Administrator, Mr. Fred Hansen, which addressed the need for establishing the appropriate level of data quality and included the requirement that any data quality management plan explicitly address the issue of secondary uses of data. The Agency program offices should establish meaningful coordination with the appropriate divisions within the new Office of Environmental Information to ensure that the Agency quality system requirements are appropriately incorporated early in the development process of any future science plan. 4.8 CSSP Report Organization A majority of the panel supported the inclusion of statutory and regulatory framework description provided by the CSSP. This framework establishes credible compliance criteria against which to evaluate the CSSP's identified science needs. Moreover, given the stated intent of CSSP Chapter Two, which is to provide the overall context and technical justification of the science needs discussed in CSSP Chapter Three, the Agency is encouraged to consider modifying the title of this chapter to reflect the Agency's concern, e.g., overview of major sediment regulatory issues across the Agency. A number of panel members observed that the description of regulatory requirements should not only 28 ------- support the CSSP science activity recommendations but should be used in conjunction with other Agency guidance to generate a environmental compliance context for its recommendations. The CSSP provides an expanded description of each recommendation included in CSSP Section 4, which sometimes indicates the lead Agency program office and describes future activities. Unfortunately, many of the recommendations do not include this information. The Agency is encouraged to adopt a consistent format in describing the recommendations including steps needed for their effective implementation. The Agency is encouraged to provide a set of clear and practical approaches for obtaining access to the multiple references cited in CSSP Chapter Two and all future cross-Agency science plans. Addressing this recommendation is important because documentation serves to substantiate assertions with identifiable and technically credible sources. Identification of the responsible offices within the Agency primarily responsible for addressing the contaminated sediment related regulatory compliance requirements would also enhance the value of this section. Although the risk assessment/risk management paradigm was deemed an appropriate framework for identifying important science gaps, a number of panel members recommended that the Agency extend the use of this approach in establishing science priorities. The application of the risk assessment/risk management paradigm in setting science priorities could be facilitated by considering the results of comparative risk, cumulative risk and/or comprehensive risk (i.e., human health, ecological, economics, social, etc.) assessments during the science planning process. 29 ------- 5. RECOMMENDATIONS FOR SCIENCE PLANNING AT EPA During the two-day meeting in October, 2002 the Panel shifted deliberations from addressing the strengths and weaknesses of the plan itself to the intent of science planning at the Agency. The majority of the panel members endorsed the stated purposes for which effective science planning is needed to address crosscutting and multi-jurisdictional environmental issues. However, a number of panel members identified many practical opportunities to significantly improve the Agency's current approach for developing a defensible and functional science plan. Many issues have already been discussed in the preceding sections. However, given the deficiencies associated with the approach used to develop the CSSP, the Panel has summarized its comments into the following eight recommendations to improve the overall process for science planning at the Agency: • The Agency should embrace a systematic and transparent process for developing future technically defensible science plans. In particular, the Panel recommended the integrated environmental decision-making (LED) framework contained in the SAB publication: EPA-SAB-EC-00-011 Toward Integrated Environmental Decision-Making be evaluated as a reasonable first step in formulating a defensible science planning process. The IED framework recognizes that risks often are experienced simultaneously and are cumulative; that efforts to manage one risk may have impacts on other risks; and that benefit cost scenarios may be affected by the scope of the problem definition. Key elements of the LED framework are transferable to the science planning process. • Data quality objectives (DQOs) should be established to ensure clarity on all related matters of quality assurance and quality control (QA/QC). For example, the utility of the science inventory to Agency decision-makers will be expanded by systematically incorporating technical information of known quality into the database. • The Agency must ensure that financial and personnel resources sufficient to address the task of science plan development are available. The process employed for development of the CSSP was thought to reflect inadequate resources for it to be successful in the allowed timeframe. • A systematic consideration and integration of other agency as well as external organizations' science activities will increase the efficiency of planning and leveraging of limited resources. Prioritization of cross-Agency science activity needs must consider all relevant research being conducted both within and outside the Agency. • A cross-Agency science plan whose recommended science priorities were formulated in the absence of any consideration of the resource requirements necessary for implementation is of limited practical value. At a minimum, the cross-Agency science plan should articulate the process by which the 30 ------- recommended science priorities are integrated into the Agency's science budgetary structure. • To ensure that that those scientific concerns relevant to cross-Agency environmental issues are fully considered by Agency decision-makers, effective science planning requires establishing and enforcing a system of management accountability. • The frequency at which the cross-Agency science plan should be evaluated needs to reflect different levels of review and consider "new science" timeframes as necessary. A number of panel members recommended that the Agency consider the length of the review cycle of other EPA planning activities (e.g. the ORD multi-year plan review timetable) in establishing an appropriate review frequency for the cross-Agency science plan. • A method for systematically evaluating the use of science tools by target users should be established to provide technology developers with critical information required for future tool development. Implementing an effective methodology for gauging user satisfaction with specific science tools promotes greater management accountability while encouraging responsiveness to the needs of the user communities. In summary, the Panel recommends the following three components as necessary and integral to a defensible cross-agency science plan: a) An explicit statement of the rationale and process used to support both the identification of cross-Agency science gaps and associated science activity recommendations designed to fill those gaps. b) A full and explicit description of the criteria used to prioritize the science needs as well as recommendations. c) A description of the cross-Agency science plan's implementation framework that clearly identifies the roles and responsibilities of those Agency offices accountable to senior management for successful execution of the plan. ------- REFERENCES 1. EPA-SAB-EC-00-011, Toward Integrated Environmental Decision-Making 2. EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations 3. EPA Order 5360.1 A2, Policy and Program Requirements for the Mandatory Agency-wide Quality System 4. EPA Contaminated Sediments Science Plan Work Group, Contaminated Sediments Science Plan, June 13, 2002 Draft 5. EPA FY 2001 Annual Assurance Report, Material and Agency Weaknesses, Office of Research and Development 6. Data Quality Act as appended to the 2001 Consolidated Appropriations Act PL 106-554 7. Memorandum from Mr. Fred Hansen, EPA Deputy Administrator, to Assistant Administrators on the subject of Assuring High Quality Environmental Data, April 29, 199. R-l ------- APPENDIX A - Contaminated Sediments Science Plan Review Panel Biosketches Bay, Steve - Southern California Coastal Water Research Project Steve Bay is Director of the Toxicology Department at the Southern California Coastal Water Research Project where his primary research focus is the relationship between sediment contamination and biological effects. His current research includes projects to assess and improve the performance of sediment Toxicity Identification Evaluation (TIE) methods and to use TIE methods in TMDL development in southern California bays and estuaries. Mr. Bay works closely with California environmental management agencies to develop methods for sediment quality assessment. Current activities in this area include a five-year project to develop sediment quality objectives for the California Water Resources Control Board and a multi-year effort to assist the San Diego Regional Water Quality Control Board in developing guidelines for sediment quality assessment and cleanup in San Diego Bay. As Special Studies Manager for the Los Angeles Basin Contaminated Sediments Task Force, Mr. Bay is coordinating several multi- year research projects related to the disposal and effects of contaminated dredge material and is also assisting state and federal agencies in developing a long-term strategy for the management of contaminated sediments in southern California. His research has contributed to the development and review of marine toxicity test methods for California regulatory programs, and standardization of west coast effluent test methods for the U.S. EPA. He participated in the Pellston workshops on porewater toxicity method and the use of sediment quality guidelines. Mr. Bay helped found the Southern California Toxicity Assessment Group, a professional organization dedicated to improving the use of toxicity tests. Mr. Bay's experience and training includes invertebrate taxonomy, field biology, animal culture, physiology, and radioisotope techniques. He received his M.S. in Biology from California State University in 1982. Bohlen, Frank - University of Connecticut W. Frank Bohlen is a professor with the Department of Marine Sciences at the University of Connecticut, Groton. His research has largely been applied coastal and stream processes studies examining factors such as sedimentary processes, sediment settling velocities, sediment transport systems, analysis of sediment transport systems and the relationship to PCB transfers, the effects of storms on sediment resuspension, time series observations of near-bottom suspended material concentrations, the impact of dredging on suspended material transport, and sediment capping of subaqueous dredged material disposal mounds. Dr. Bohlen was a member of the NAS/NRC Committee on Contaminated Marine Sediments, 1993-1998 and the Committee on Assessment of Risks from Remediation of PCB-Contaminated Sediments, 1999- 2001.Dr. Bohlen is a member of the American Geophysical Union, Estuarine Research Federation, The Oceanography Society, and Marine Technology Society. He received his Ph.D. in 1969 from the Massachusetts Institute of Technology and Woods Hole Oceanographic Institution. Chess, Caron - Rutgers University Caron Chess is an Associate Professor, Department of Human Ecology, Rutgers University and Director of the Center for Environmental Communication. She was previously the Founding Executive Director and later National Project Coordinator for the Delaware Valley Toxics Coalition (1981-1984). She has written extensively on topics of Risk Communication A-l ------- and Improving Public Participation in Solving Environmental Health Problems. She co-authored the publication Improving Dialogue: The Industry Risk Communication Manual, which was selected by the Society for Risk Analysis for the "Must Read" list for industry practitioners (1995). Dr. Chess was a member of the nominations committee for the Society for Risk Analysis (2001); member of the Communications Subcommittee of the Board of Scientific Counselors of the EPA, Office of Research and Development (2001); Invited participant, Workshop on Public Participation and Environmental Decision Making, National Research Council (2001); is a member of the Advisory Committee to Council of Society for Risk Analysis; was Panel Leader for Risk Communication at the World Health Organization International Seminar and Working Group Meeting on EMF, Risk Perception and Communication (1998); Chair for risk communication, Panel on Methyl Parathion, Agency for Toxic Substances and Disease Registry (1997); member, Committee on Risk Characterization, National Research Council (1994-1996); member, Governing Council, Society for Risk Analysis (1994-1996); member, EPA Science Advisory Board, Subcommittee on Valuation (1996-1997); and a member of the Editorial Boards of Human Ecology Review and Risk Analysis: An International Journal. Dr. Chess received her Ph.D. in Environmental Studies and Democratic Processes from State University of New York, College of Environmental Science and Forestry in 1997. Cory-Slechta, Deborah - University of Rochester Medical School Deborah Cory-Slechta began working as a junior staff fellow of the National Center for Toxicological Research beginning in 1979. She was appointed to the faculty of the University of Rochester Medical School in 1982 and rose through the ranks. In 1998, she was appointed Chair of the Department of Environmental Medicine and Director of the NIEHS Environmental Health Sciences Center at the University of Rochester. From July 2000- July 2002, she was appointed Dean for Research and Director of the Aab Institute for Biomedical Sciences, a newly established post at the University and as such, became the first female dean in the history of the Medical School. Dr. Cory-Slechta has served on numerous national research review and advisory panels, including committees of the National Institutes of Health, the National Institute of Environmental Health Sciences, the Food and Drug Administration, the National Center for Toxicological Research, the Environmental Protection Agency, the National Academy of Sciences, the Institute of Medicine, and the Agency for Toxic Substances and Disease Registry, Centers for Disease Control. In addition, Dr. Cory-Slechta has served on the editorial boards of several journals including Neurotoxicology, Toxicology, Toxicological Sciences, Fundamental and Applied Toxicology, Neurotoxicology and Teratology, and American Journal of Mental Retardation. She has held the elected positions of President of the Neurotoxicology Specialty Section of the Society of Toxicology, President of the Behavioral Toxicology Society, and been named a Fellow of the American Psychological Association. Her research has focused largely on environmental neurotoxicants as risk Factors for behavioral disorders and neurodegenerative disease. Specifically this has included work on the impact of lead on learning and attention and associated neurochemical mechanisms, and, more recently on the role of pesticides as risk factors for Parkinson's Disease. These research efforts have resulted in over 90 papers and book chapters to date. Dr. Cory-Slechta received her Ph.D. degree from the University of Minnesota in 1977. A-2 ------- Di Giulio, Richard - Duke University Richard Thomas Di Giulio is a Professor with the Nicholas School of the Environment & Earth Sciences at Duke University and Director of the University's Superfund Basic Research Center. Dr. Di Giulio's research is focused upon biochemical and cellular responses of aquatic animals to environmental stressors, particularly contaminants. His laboratory is concerned with both basic studies of mechanisms of contaminant metabolism, adaptation and toxicity, and with the development of sensitive, mechanistically-based indices of exposure and toxicity that can be used in biomonitoring of free-living organisms. The long-term goal of this research is to bridge the gap between fundamental toxicological research and the development of mechanism-based approaches for monitoring environmental health. He seeks to utilize the comparative biology paradigm to elucidate linkages between human and ecosystem health. He has consulted extensively, including as a contractor in the development of the Monte Carlo uncertainty analysis for the surface water component for land disposal restrictions determinations for the EPA, and as a science advisor for ecological risk assessments of Superfund sites. Dr. Di Giulio served on the Board of Directors for the Society of Environmental Toxicology and Chemistry (SET AC), and Chaired the Membership Committee. He was also a member of the SET AC 19th Annual Meeting Program Committee and Chair of the Plenary Session. He is also a member of the editorial boards of Toxicological Sciences, Human and Ecological Risk Assessment, and Chemosphere. He received his Ph.D., from Virginia Polytechnic Institute and State University in 1982. Field, L. Jay - U.S. Department of Commerce L. Jay Field Team Leader for Technical Support for Coastal Protection and Restoration Division, Office of Response and Restoration, National Oceanic and Atmospheric Administration (NOAA). Duties include providing technical support to NOAA Coastal Resource Coordinators and U.S. Environmental Protection Agency (EPA) in the evaluation of ecological risk to freshwater and coastal marine resources resulting from releases of contaminants at hazardous waste sites. Recent work has included conducting and evaluating aquatic ecological risk assessments at Superfund sites and the evaluating and developing sediment guidelines. He served on the technical advisory committees for EPA for the Remedial Investigation of the Hudson River PCBs Superfund site, the National Sediment Inventory methodology evaluation, and the Great Lakes National Program Office guidance manual to support the assessment of contaminated sediments in the Great Lakes. Recent publication titles include: Predicting amphipod toxicity from sediment chemistry using logistic regression models; Application of a sum_PAH model and logistic regression model to sediment toxicity data based on a species- specific water-only LC50 toxic unit for Hyalella azteca; Predictions of sediment toxicity using consensus-based freshwater sediment quality guidelines; Development and evaluation of consensus-based sediment effect concentrations for polychlorinated biphenyls; and Development of a framework for evaluating numerical sediment quality targets and sediment contamination in the St. Louis River Area of Concern. Mr. Field received his M.S. in Fisheries Biology from the University of Washington School of Fisheries in 1984. McFarland, Michael J. - Utah State University Dr. Michael J. McFarland received his bachelors' degree in Engineering and Applied Science from Yale University, his masters' degree in Chemical Engineering from Cornell A-3 ------- University and his Ph.D. in Agricultural Engineering from Cornell University. Dr. McFarland is currently an associate professor in the Department of Civil and Environmental Engineering at Utah State University where his research interests are focused in the areas of air quality management, industrial waste management and pollution prevention. Dr. McFarland has served on numerous federal, state and local environmental engineering and public health advisory committees for the US Dept. of Defense, US Environmental Protection Agency, US Dept. of Energy, National Science Foundation, Utah Dept. of Environmental Quality and Cache County, Utah. Dr. McFarland has authored or coauthored over fifty publications in the field of environmental engineering including engineering textbooks, workbooks, journal articles and conference proceedings. Dr. McFarland is a registered professional engineer in the State of Utah and currently holds Grade IV operator certifications for both wastewater and water treatment. Dr. McFarland is a member of the American Academy of Environmental Engineers (AAEE), the Water Environment Federation (WEF), the Society for Risk Analysis, National Biosolids Partnership and the Association of Environmental Engineering and Science Professors (AEESP). Pfaender, Fredrick - University of North Carolina at Chapel Hill Frederick K. Pfaender is a Professor of Environmental Sciences and Engineering at the University of North Carolina at Chapel Hill, with a Joint appointment as Director of Ecology for the Carolina Federation of Environmental Programs. Dr. Pfaender's research is concerned with microbially mediated transformations of xenobiotic chemicals in soil, marine and subsurface environments. The primary focus is on identification of the environmental factors that regulate microbial activities Other interests include microbial ecology, nutrient exchanges in rivers and estuaries, estuarine pollution; biodegradation of petroleum hydrocarbons by patuxent aquifer microbial communities; and biodegradation of detergent chemicals in estuarine and near-shore marine environments. Dr. Pfaender has published on his research in the areas of adaptation of aquifer microbial communities to the biodegradation of xenobiotic compounds: influence of substrate concentration and preexposure; a comparison of microbial community characteristics among petroleum-contaminated and uncontaminated subsurface soil samples; the effect of inorganic and organic supplements on the microbial degradation of phenanthrene and pyrine in soils; and polynuclear aromatic hydrocarbon metabolism in soils: relationship to soil characteristics and preexposure. Dr. Pfaender received his PhD in Microbiology from Cornell University in 1971. Splitstone, Douglas - Spiltstone and Associates Douglas E. Splitstone is Principal of Splitstone & Associates. He has designed data collection programs to investigate potential environmental impacts in air, water, and soil. Mr. Splitstone has conducted statistical analyses of data related to the extent of site contamination and remedial planning, industrial wastewater discharges, and the dispersion of airborne contaminants. Mr. Splitstone has also developed statistical decision criteria for evaluating when acceptable environmental cleanup levels have been achieved. He has successfully employed geostatistical analysis and estimation techniques for mapping the areal extent and total volume of dioxin contaminated soils at the site of a former New Jersey pesticide plant. He has also successfully employed these techniques to map the extent of contamination in the sediments of the Passaic River and design the sampling plan for the collection of data to assess the extent of A-4 ------- possible contamination by radioactive material in the environs of Department of Energy's (DOE's) Feed Materials Production Center near Fernald, Ohio. He has served as a member of the Task Group on Epidemiology and Statistical Methodology for the USEPA's Center for Environmental Epidemiology at the University of Pittsburgh's Graduate School of Public Health; and previously consulted with Science Advisory Board's Air Toxics Monitoring Subcommittee, and panels on Quality Management and Secondary Data Use. Mr. Splitstone is a member of the American Statistical Association (ASA) and is a founder and past chairman of that organization's Committee on Statistics and the Environment. He was awarded the Distinguished Achievement Medal by the ASA's Section on Statistics and the Environment in 1993. He was chairman for the Sixth Symposium on Statistics and the Environment that was held at the National Academy of Sciences Mr. Splitstone received his M.S. in Mathematical Statistics from Iowa State University in 1967. Theis, Thomas - University of Illinois at Chicago Dr. Theis is the founding director of the Institute for Environmental Science and Policy at the University of Illinois at Chicago. Formerly, Theis was the Bayard D. Clarkson Distinguished Professor and Director of the Center for Environmental Management at Clarkson University. Professor Theis' areas of expertise include the mathematical modeling and systems analysis of environmental processes, the environmental chemistry of trace organic and inorganic substances, interfacial reactions, subsurface contaminant transport, and hazardous waste management. He has been principal or co-principal investigator on over forty funded research projects totaling in excess of six million dollars, and has authored or co-authored over eighty papers in peer review research journals, books, and reports. He is a member of the USEPA Science Advisory Board (Environmental Engineering Committee), is past editor of the Journal of Environmental Engineering, and serves on the editorial boards of The Journal of Contaminant Transport, and Issues in Environmental Science and Technology. He has served on numerous professional committees including the Scientific Committee on Problems in the Environment (SCOPE), and the World Bank funded team of scholars for advising the Universidad Nacional Del Literal (Argentina) on environmental engineering education. From 1980-1985 he was the codirector of the Industrial Waste Elimination Research Center (a collaboration of Illinois Institute of Technology and University of Notre Dame), one of the first Centers of Excellence established by the USEPA, and was Principal Investigator on the NSF-Sponsored Environmental Manufacturing Management Program at Clarkson. Windom, Herbert L. - Skidaway Institute of Oceanography Herbert L. Windom is Professor/Emeritus at the Skidaway Institute of Oceanography. Research Interests include: Riverine, estuarine and continental shelf and slope geochemical processes; land-sea transport; trace metal biogeochemistry, marine, estuarine and coastal environmental quality; and estuarine and coastal marine pollution. Recent Publications include: Sediment manganese and biogenic silica as geochemical indicators in estuarine salt marshes of coastal Georgia; and General Guidelines for using the Sediment Quality Triad. He served on the Science Advisory Board Subcommittee of Sediment Quality Criteria; was a consultant to the UNEP GEMS/WATER GEF Proposal Development (Rapid Assessment of Freshwater Resources in International River Basins as a Framework for the Promotion of Environmentally Sound River Basin Management; a member of the Group of Experts on Methods, Standards, and A-5 ------- Intercalibration (GEMSI) of the Intergovernmental Oceanographic Commission (IOC) of UNESCO; and a member of NSF Advisory Panel on Biogeochemistryand Environmental Chemistry (1995); and Chairman, GEMS/Water Expert Consultation on the Assessment of Land- Based Sources of Pollution (1995). Dr. Windom received his Ph..D. in Marine Geochemistry from the University of California, San Diego, in 1968. A-6 ------- |