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)
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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.
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• 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.
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• 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
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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
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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.
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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
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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.
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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.
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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
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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.
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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
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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
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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
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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.
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