U.S. Environmental Protection Agency Galveston District
Region 6 New Orleans District
OCEAN DREDGED MATERIAL DISPOSAL PROGRAM
REGIONAL IMPLEMENTATION
AGREEMENT
FOR
TESTING AND REPORTING REQUIREMENTS
FOR OCEAN DISPOSAL OF DREDGED MATERIAL
OFF THE LOUISIANA AND TEXAS COASTS
UNDER SECTION 103 OF
THE MARINE PROTECTION, RESEARCH AND SANCTUARIES ACT
July, 2003
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PREFACE
This Regional Implementation Agreement (RIA) was prepared cooperatively by the U.S. Army
Corps of Engineers (USAGE), New Orleans District and Galveston District, and the U.S.
Environmental Protection Agency, Region 6 (EPA). The RIA provides guidance for applicants,
permittees, and USAGE and EPA staff working on ocean dredged material disposal projects in
Louisiana and Texas. The RIA is necessary to adapt the national procedures, contained in the
1991 Evaluation of Dredged Material Proposed for Ocean Disposal - Testing Manual, to
Regional situations and ensure compliance with the ocean dumping regulations.
This RIA is designed to specify sampling, testing, and reporting procedures for dredged materials
proposed for ocean disposal in the Gulf of Mexico off the Louisiana and Texas coasts. In
addition, this RIA establishes administrative, coordination, and documentation procedures that
will be followed by the USAGE, New Orleans District and Galveston District, and EPA Region 6.
This RIA revises and combines the existing RIAs for the Ocean Dumping Program in Louisiana
and Texas, finalized in 1992. This RIA will supercede the 1992 RIAs upon finalization.
This RIA has undergone review by the USAGE Engineer Research and Development Center,
EPA National Health & Environmental Effects Research Laboratory, EPA Office of Wetlands,
Oceans and Watersheds, U.S. National Marine Fisheries Service, U.S. Fish and Wildlife Service,
National Oceanic and Atmospheric Administration, Louisiana Department of Environmental
Quality, Louisiana Department of Natural Resources, Louisiana Department of Wildlife and
Fisheries, Texas Natural Resource Conservation Commission, Texas General Land Office, and
the Texas Parks and Wildlife Department. Comment letters received are included in Appendix F.
In addition, the following individuals have reviewed this document through a formal peer review
process: Mr. Martin Arhelger, PBS&J; Dr. Barry A. Vittor, Barry A. Vittor and Associates, Inc.;
Mr. James Reese, USAGE, Northwestern Division; and Mr. Walter Berry, USEPA Environmental
Effects Research Laboratory.
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This RIA has been approved by the following officials of U.S. Environmental Protection Agency
and the U.S. Army Corps of Engineers, and goes into effect upon the date of the last signature.
Miguel I. Flores
Director, Water Qu^ity Protection Division
Region 6
U.S. Environmental Protection Agency
DATE
Leonard D. Waterworth
Colonel, Corps of Engineers
District Engmeer
jj Iveston District
Peter KiOwin
Colonel, C >rps of Engineers
[ineer
New Orleans District
DATE
ATE
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GLOSSARY OF TERMS
Acute Toxicity:
Short-term toxicity to organism(s) that have been affected by the properties of one or more chemical
substances contained in water or sediment. The acute toxicity of contaminated sediment is generally
determined by quantifying the mortality of appropriately sensitive organisms that are put into contact with
the sediment, under either field or laboratory conditions, for a specified period.
Bioaccumulation:
The accumulation of contaminants in the tissue of organisms through any route, including respiration,
ingestion, or direct contact with contaminated water, sediment, or pore water.
Bioassay:
A bioassay is a test using a biological system. It involves exposing an organism to a test material and
determining a response. There are two major types of bioassays differentiated by response: toxicity tests
which measure an effect (e.g. acute toxicity, sublethal/chronic toxicity) and bioaccumulation tests which
measure a phenomenon (e.g. the uptake of contaminants into tissues).
Contaminant of Concern (COC):
A contaminant present in a given sediment thought to have the potential for unacceptable adverse
environmental impact due to a proposed discharge. A contaminant is defined as a chemical substance in a
form that can be toxic to or bioaccumulate in aquatic organisms, consumers of aquatic organisms, or users of
the aquatic environment, and includes but is not limited to the substances listed on the 307(a)(l) list of toxic
pollutants promulgated on January 31, 1978 (43 FR 4109).
Data Quality Objectives (DQO):
Qualitative and quantitative statements that clarify study objectives, define appropriate types of data and
specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality
and quantity of data needed to support decisions. DQOs provide the framework for planning environmental
data operations consistent with the data user's needs.
Dissolved Fraction or Liquid Phase:
The dissolved fraction of the elutriate process is that portion of the elutriate supernatant that has been filtered
through a 0.45 Om filter (or centrifuged and then filtered).
Dredged Material Elutriate:
The dredged material elutriate preparation (see Section 10.1.2 of the Green Book) involves mixing the
dredged material with dredging site water in a sediment-to-water ratio of 1:4 and allowing the mixture to
settle. The suspended paniculate phase is the supernatant from the dredged material elutriate preparation
and is used for water column bioassays. The liquid phase is the supernatant from the dredged material
elutriate preparation that has been centrifuged and/or filtered and is used for EPA WQC/state WQS
screening.
EPA Risk Levels
Levels of co:
a 1 in 100,000 incremental incidence of cancer over a 70 year period) and/or noncancer hazard (i.e. exceeds
Levels of contaminant concentrations in an exposure medium that pose a potential carcinogenic risk (10~5 or
ill
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a reference dose). Screening levels for contaminants are used in this RIA to estimate human health risk
associated with the consumption of chemically contaminated fish.
Equilibrium Partitioning (EqP) Approach:
Approach used to relate the dry-weight sediment concentration of a particular chemical that causes an
adverse biological effect to the equivalent free chemical concentration in pore water and to that
concentration sorbed to sediment organic carbon or bound to sulfide. Based on the theory that the
partitioning of a nonionic organic chemical between organic carbon and pore water and the partitioning of a
divalent metal between the solid and solution phases are at equilibrium.
Exclusionary Criteria:
Should the dredged material meet at least one of the criteria listed in Section 227. 13(a) of the ocean dumping
regulations, no additional testing is required of the sediment and the material is considered to be compliant
with the regulations.
Green Book:
Evaluation of Dredged Material Proposed for Ocean Disposal - Testing Manual (EPA-503/8-9 1/001), or the
"Green Book" is the technical guidance manual for determining suitability of dredged material for ocean
disposal through chemical, physical, and biological evaluations. The Green Book is intended for use in
evaluating dredged-material compliance with the EPA ocean dumping regulations.
Initial Mixing:
That dispersion or diffusion of liquid, suspended paniculate, and solid phases of dredged material that
occurs within 4 hours after dumping. The limiting permissible concentration (LPC) shall not be exceeded
beyond the boundaries of the disposal site during initial mixing and shall not be exceeded at any point in the
marine environment after initial mixing.
Inland Testing Manual (ITM):
Evaluation of Dredged Material Proposed for Discharge in Waters of the U.S. - Testing Manual (EPA-823-
B-98-004), or the Inland Testing Manual, is the technical guidance manual for determining the potential for
contaminant-related impacts associated with the discharge of dredged material in waters regulated under
Section 404 of the Clean Water Act (inland waters, near coastal waters, and surrounding environs - all
waters other than the ocean and territorial sea regulated pursuant to Section 404 of CWA) through chemical,
physical, and biological evaluations.
Log octanol/water partition coefficient, the ratio of the chemical concentration in octanol divided by the
concentration in water. The octanol/water partition coefficient has been shown to correlate with
bioconcentration factors in aquatic organisms and adsorption to soil and sediment.
The median lethal concentration. The concentration of a substance that kills 50% of the organisms tested in
a laboratory toxicity test of specified duration.
Limiting Permissible Concentration (LPC):
The liquid phase LPC [40 CFR 227.27(a)] is the concentration of the constituent that, after allowing for
initial mixing, does not exceed the acute marine water quality criteria (WQC) for that constituent and/or a
IV
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toxicity threshold of 0.01 of the acutely toxic concentration of the dredged material. The LPC of the
suspended paniculate phase and solid phases is the concentration which will not cause unreasonable toxicity
and which will not cause bioaccumulation of contaminants of concern in the human food chain (SPP
bioaccumulation testing is not required) [40 CFR 227.27(b)].
Liquid Phase or Dissolved Fraction (LP):
For dredged material, the liquid phase is considered to be the centrifuged and/or 0.45 Om filtered
supernatant from the dredged material elutriate preparation [See also 40 CFR 227.32(b)(l)].
Marine Protection Research and Sanctuaries Act (MPRSA):
Enacted by Congress in 1972, MPRSA regulates the transportation for the purpose of dumping and dumping
of all materials into the ocean. It establishes a system for permitting the disposal of materials and prohibits
the dumping of particular materials. It implements the Convention on the Prevention of Marine Pollution by
Dumping of Wastes and Other Matter, or the London Convention of 1972. Also known as the Ocean
Dumping Act.
Minimum Quantification Level (MQL):
The lowest concentration that can be reliably quantified with specified limits of precision and accuracy
during routine laboratory operating conditions.
Ocean Waters:
Those waters of the open seas lying seaward of the baseline from which the territorial sea is measured (see
also paragraph 220.2(c) of the ocean dumping regulations).
Ocean Dredged Material Disposal Site (ODMDS):
A precise geographical area within which ocean disposal of dredged material is permitted under conditions
specified in permits issued under § 103 of the MPRSA. Such sites are identified by boundaries established
by (1) coordinates of latitude and longitude for each corner or by (2) coordinates of latitude and longitude
for the center point and a radius in nautical miles from that point.
Ocean Dumping Regulations:
Procedures and concepts published in 40 CFR 220-228 for evaluating proposals for dumping dredged
material in the ocean.
Reference Sediment:
A sediment, substantially free of contaminants, that is as similar as practicable to the grain size of the
dredged material and the sediment at the disposal site. In addition, the reference sediment reflects
conditions that would exist in the vicinity of the disposal site had no dredged material disposal ever taken
place, but had all other influences on sediment condition taken place. The reference sediment serves as a
point of comparison to identify potential effects of contaminants in the dredged material.
Solid Phase (SP):
According to the regulation, the solid phase is considered to be all the material settling to the bottom after
one hour settling of the dredged material elutriate [See also 40 CFR 227.32(b)(l)]. Forthe purposes of this
RIA, solid phase refers to the whole sediment as defined in the Green Book, which includes the sediment
that would settle in one hour.
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Suspended Particulate Phase (SPP):
The SPP is the supernatant as obtained from the dredged material elutriate preparation. [See also 40 CFR
227.32(b)(l)].
Target Detection Limit (TDL):
A performance goal set between the lowest, technically feasible, detection limit for routine analytical
methods and available regulatory criteria or guidelines for evaluating dredged material. The target detection
limit is, therefore, equal to or greater than the lowest amount of a chemical that can be reliably detected
based on the variability of the blank response of routine analytical methods. However, the reliability of a
chemical measurement generally increases as the concentration increases. Analytical costs may also be
lower at higher detection limits. For these reasons, a target detection limit is typically set at not less than 10
times lower than available sediment guidelines.
Tiered Testing:
A structured, hierarchical procedure for determining data needs relative to decision-making, which involves
a series of tiers or levels of intensity of investigation. Typically, tiered testing involves decreased
uncertainty and increased available information with increasing tiers. This approach is intended to ensure
the maintenance and protection of environmental quality, as well as the optimal use of resources.
Specifically, least effort is required in situations where clear determinations can be made of whether (or not)
unacceptable adverse impacts are likely to occur based on available information. Most effort is required
where clear determinations cannot be made with available information.
Toxicity Test:
A bioassay which measures an effect (e.g. acute toxicity, sublethal/chronic toxicity). Not a bioaccumulation
test.
Water Quality Criteria (WQC):
Nationally recommended water quality levels by EPA for the protection of aquatic organisms and their uses.
The criteria are developed under Section 304(a) of the Clean Water Act and are based solely on data and
scientific judgements on the relationship between pollutant concentrations and environmental and human
health effects. They provide guidance to the States in adopting water quality standards that ultimately
provide a basis for controlling discharges or releases of pollutants.
Water Quality Standard:
A law or regulation that consists of the beneficial designated use or uses of a water body, the numeric and
narrative water quality criteria that are necessary to protect the use or uses of that particular water body, and
an anti-degradation statement. Nationally recommended water quality criteria provide guidance for the
States in adopting water quality standards.
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LIST OF ACRONYMS
ASTM - American Society for Testing and Materials
CFR - Code of Federal Regulations
COC - Contaminant(s) of Concern
CWA - Clean Water Act
DQO - Data Quality Objectives
EIS - Environmental Impact Statement
EPA - Environmental Protection Agency
FR - Federal Register
GC/MS - Gas Chromatograph/Mass Spectrometry
GIS - Geographic information system
ITM - Inland Testing Manual
LPC - Limiting Permissible Concentration
MPRSA - Marine, Protection, Research and Sanctuaries Act
MQL - Minimum Quantification Level
ODMDS - Ocean Dredged Material Disposal Site
PAH - Polynuclear Aromatic Hydrocarbons
PCB - Polychlorinated Biphenyl
QA - Quality Assurance
QAP - Quality Assurance Plan
QC - Quality Control
RIA - Regional Implementation Agreement
SAP - Sampling and Analysis Plan
SPP - Suspended Paniculate Phase
SP - Solid Phase
TDL - Target Detection Limit
USAGE - U.S. Army Corps of Engineers
U.S.C.-United States Code
WQC - Water Quality Criteria
WQS - Water Quality Standards
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TABLE OF CONTENTS
Preface _i
Signatures _ii
Glossary of Terms _iii
Acronyms vii
Table of Contents viii
1. Introduction 1
1 1 Background 1
1 2 Purpose 1
1.3 Modifications 1
1.4 Issue Resolution 2
1.5 Contacts 2
2. Applicability 2
3. Administrative Process .2
3.1 MPRSA Section 103 Permit 3
3.2 Navigational Projects Constructed and/or
Maintained by the USACE 3
3.3 USAGE Review 3
3.4 Information submitted to EPA 5
3 5 EPA Review 5
4. Tiered Testing Approach 6
4.1 Overview 6
4.2 Limiting Permissible Concentration 6
4.3 Tier I-Existing Information 6
4.4 Tier I-Exclusionary Criteria 8
4.5 Tier I-Compliance Decisions 9
4.6 Tiers II & Ill-New Data Evaluation 9
4.7 Tiers II & Ill-Compliance Decisions 11
4.8 Tier IV-Case-by-case Analyses 11
5. Sampling and Analysis Plan 11
5.1 Sampling and Analysis Plan 11
5.2 Sampling Design 13
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5.3 Sampling Approach 14
5.4 Sample Collection 14
5.5 Reference and Control Sediments 15
6. Quality Assurance/Quality Control 17
7. Dredged Material Evaluation 18
8. Physical and Chemical Evaluations 19
8.1 Physical Analysis 19
8.2 Chemical Analysis 19
9. Water Column Evaluations .20
9.1 Dredged Material Elutriate Preparation 20
9.2 Water Quality Criteria/Standards Evaluation
Using the Liquid Phase-Tier II 22
9.3 Water Column Bioassay
Using the Suspended Particulate Phase-Tier III 23
9.3.1 Suspended Particulate Phase Toxicity Test 23
9.3.2 Test Organisms 24
9.3.3 Data Analysis 24
10. Benthic Evaluations .26
10.1 Benthic Bioassay-Tier III 27
10.1.1 Solid Phase Toxicity Test .27
10.1.2 Test Organisms 27
10.1.3 Data Analysis .28
10.2 Bioaccumulation Testing-Tier III 29
10.2.1 Test Organisms .29
10.2.2 Chemical Analysis of Tissues 30
10.2.3 Bioaccumulation Evaluations 31
11. Risk-Based Evaluative Tools 33
12. Emergency Procedures 35
13. References 37
Tables
Table 1 Sample Collection Requirements 16
Table 2 Contaminants of Concern and Conventional Parameters 21
IX
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Figures
Figure 1
Figure 2
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Overview of Review Process...
Overview of Tiered Approach
.4
7
Required Information & Documentation for Evaluation of Dredged
Material Proposed for Ocean Disposal Al
Sample Collection, Preservation and Storage Bl
Target Detection Limits for Sediment, Tissue and Water Cl
Reference Area Locations _D1
EPA Evaluator Worksheets for Testing and Evaluation of Dredged Material
Proposed for Ocean Disposal El
Comment Letters Fl
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1. INTRODUCTION
1.1 Background. Section 103 of the Marine Protection, Research and Sanctuaries Act
(MPRSA) (33 U.S.C. §1401 et. seq.), specifies that all proposed operations involving the
transportation and disposal of dredged material into ocean waters must be evaluated to determine
the potential environmental impact of such activities. Environmental evaluations must be in
accordance with the ocean dumping regulations in 40 CFR 220-228, and with permitting and
dredging regulations in 33 CFR 320-330 and 335-338. National implementation guidance was
developed jointly by the U.S. Army Corps of Engineers (USAGE) and the Environmental
Protection Agency (EPA) to define technical procedures for testing dredged material. The
national guidance manual was first issued in 1977 and an updated version entitled, Evaluation Of
Dredged Material Proposed for Ocean Disposal - Testing Manual, (the Green Book) was issued
in February 1991 (EPA/USACE, 1991).
1.2 Purpose. Regional guidance is necessary to adapt the national procedures to regional
situations and to adhere to ocean dumping regulations at 40 CFR 220-228. This Regional
Implementation Agreement (RIA) is designed to specify sampling, testing, and reporting
procedures for dredged materials proposed for ocean disposal in the Gulf of Mexico off the
Louisiana and Texas coasts. In addition, this RIA establishes administrative, coordination, and
documentation procedures that will be followed by the USAGE, New Orleans District and
Galveston District and EPA, Region 6. This RIA revises and combines the existing RIAs for the
Ocean Dumping Program in Louisiana and Texas, finalized in 1992 (EPA/USACE 1992a &
1992b). This RIA will supercede the 1992 RIAs upon fmalization.
In 1998, EPA and the USAGE jointly issued national guidance defining technical procedures
under Section 404 of the Clean Water Act (CWA) for evaluating proposed discharges of dredged
material into waters of the U.S associated with navigational dredging projects. It is intended that
the document, Evaluation of Dredged Material Proposed for Discharge in Waters of the U.S. -
Testing Manual, (EPA/USACE, 1998), the Inland Testing Manual or ITM, serve as a counterpart
to the Green Book, and in many technical aspects is more up-to-date. Thus for the purposes of
this RIA, references are made to relevant technical sections of the ITM as well as the Green
Book.
1.3 Modifications. New and more advanced testing procedures are continually being
developed and refined by the research and development laboratories of the EPA and USAGE, as
well as by the academic community. Monitoring of the designated Ocean Dredged Material
Disposal Sites (ODMDS) off the Louisiana and Texas coasts will provide effects-based feedback
that will enable EPA Region 6 and the USAGE, New Orleans District and Galveston District to
make more refined and environmentally sensitive decisions concerning the ocean disposal of
dredged materials. For these reasons, this RIA will be reviewed periodically and revised as
necessary to incorporate modifications to the testing and reporting requirements. Modifications
will be made only upon mutual agreement by the USAGE, New Orleans District and Galveston
District and EPA Region 6 and will be subject to public review.
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1.4 Issue Resolution. Early coordination and communication is essential for avoiding
disagreements. Disagreements between the USAGE, New Orleans District or the Galveston
District and EPA Region 6 regarding the characterization of dredged material proposed for ocean
disposal will be discussed and, when possible, resolved at the staff level. If, however, the issue
cannot be resolved at the staff level, then the issue will be elevated to District and Regional
Managers. If necessary, consultation with the USAGE Engineer Research and Development
Center and USAGE Headquarters and with the EPA Environmental Research Laboratories and
EPA Headquarters will be the responsibility of the respective agency.
1.5 Contacts. Questions regarding any aspects of this RIA should be directed to:
U.S. Army Corps of Engineers
New Orleans District
Operations Division, Technical Support Branch CEMVN-OD-T
P.O. Box 60267
New Orleans, LA 70160-0267
U.S. Army Corps of Engineers
Galveston District
Environmental Section CESWG-PE-PR
P.O. Box 1229
Galveston, TX 77553-1229
U.S. Environmental Protection Agency
Region 6
Water Quality Protection Division
Marine & Wetlands Section 6WQ-EM
1445 Ross Avenue, Suite 12000
Dallas, TX 75202-2733
2. APPLICABILITY
This document applies to all activities involving the transportation of dredged material for the
purpose of disposing it in ocean waters and is applicable to dredging activities permitted by the
USAGE and navigational projects constructed and maintained by the USAGE.
3. ADMINISTRATIVE PROCESS
The Ocean Dumping Program is jointly administered by EPA, Region 6 and the USAGE, New
Orleans District and Galveston District. In accordance with Section 103 of MPRSA, the USAGE
is the permitting authority for dredged material disposal, subject to EPA review and concurrence.
Navigational projects constructed and maintained by the USAGE are subject to the same Federal
environmental laws and regulations as the general public even though the USAGE does not issue
a permit document to authorize its own activities. Prior to disposal of dredged material at any
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designated ODMDS, both EPA and the USAGE are charged with making independent
evaluations of all proposed dredged material disposal actions (40 CFR 225). Figure 1 shows a
flowchart overview of the review process.
3.1 MPRSA Section 103 Permits. Applications for MPRSA Section 103 permits must be
submitted to the USAGE, New Orleans District or Galveston District. Section 103 applications
must comply with USAGE permitting regulations at 33 CFR Parts 320-330. In addition, Clean
Water Act Section 401 water quality certification will be required. Applicants are strongly
encouraged to arrange pre-application meetings with the USAGE, New Orleans District or
Galveston District and EPA, Region 6 in order to determine the need for testing and for
additional information on the permitting process.
Once the USAGE, New Orleans District or Galveston District receives a completed permit
application, the information will be published for review in a public notice. The information
required for the public notice is specified in 33 CFR 325.3. The information provided in the
public notice and other information requested by the USAGE Districts or EPA, Region 6 shall be
used in making evaluations and determining suitability of dredged material for ocean disposal
and compliance with 40 CFR 220-228. The types of information necessary to conduct
evaluations are listed in Appendix A. In addition, the "evaluator worksheets" (Appendix E),
used by EPA in evaluating the proposed dredged material, also provide a listing of information
needed for adequate evaluations.
3.2 Navigational Projects Constructed and/or Maintained by the USACE. The USAGE, New
Orleans District and Galveston District must provide the same information as required for a
Section 103 permit and are subject to the same review process (33 CFR Parts 335-338). The
types of information necessary to conduct evaluations are listed in Appendix A. In addition, the
"evaluator worksheets" (Appendix E), used by EPA in evaluating the proposed dredged material,
also provide a listing of information needed for adequate evaluations.
To date, the USACE, New Orleans District and Galveston District, respectively, are the only
users of the eight (8) MPRSA 102(c) Ocean Dredged Material Disposal Sites (ODMDS) off the
coast of Louisiana and the ten (10) MPRSA 102(c) ODMDS off the coast of Texas.
Advance notice and coordination for USACE navigational projects occurs during the New
Orleans District's annual Environmental Dredging Conference and the Galveston District's
annual Dredging Conference where the USACE Districts present the proposed maintenance
dredging projects for the upcoming fiscal year.
3.3 US ACE Review. All Section 103 permit applications and USACE navigational project
authorizations for ocean disposal of dredged material are evaluated by the USACE, New Orleans
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FIGURE 1. Overview of Review Process
CORPS DETERMINES NEED TO DREDGE AND
USE OCEAN DREDGED MATERIAL DISPOSAL
TIER I EVALUATION
Exclusionary Criteria not met, or
New Data Needed
Corps/Applicant Develops Sampling Plan
Exclusionary Criteria met, or
Existing Data Sufficient to Show
Compliance With LPC
EPA Reviews/Comments on Sampling
Corps /Applicant
Revises Plan
i
k
+
EPA Does
Not Concur
EPA
Concurs
Corps/Applicant Conducts
Sampling and Analysis
CORPS REVIEWS DATA AND SUBMITS
EVALUATION TO EPA 3 MONTHS PRIOR TO
ADVERTISEMENT DATE
(unless alternative schedule determined)
EPA REVIEWS DATA AND CORPS EVALUATION 15 DAYS AFTER RECEIPT
CORPS SUBMITS
REQUESTED
INFORMATION
EPA REQUESTS
ADDITIONAL
INFORMATION
1
EPA CONCURS WITH CORPS
DFTFR MTN A TTON
1
r
MATERIAL
SUITABLE FOR
OCEAN
l
r
MATERIAL NOT
SUITABLE FOR
OCEAN
EPA DOES NOT CONCUR WITH CORPS
DETERMINATION
1
1
r
MATERIAL
SUITABLE FOR
OCEAN
l
r
MATERIAL NOT
SUITABLE FOR
OCEAN
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District or Galveston District in accordance with applicable ocean dumping criteria in 40 CFR
220-228. The evaluation consists of characterization of the dredged material and determination
of compliance with the applicable regulations. The types of information necessary to complete
the review and required to be submitted to EPA, Region 6 by the USAGE, New Orleans District
and Galveston District are listed in Appendix A.
A Tier I evaluation must be conducted, at a minimum, for all dredged material disposal
projects, both those requiring 103 permits and all USACE navigational projects as part of the
dredged material characterization. The purpose of the Tier I evaluation is to determine whether
a decision on environmental acceptability can be made on the basis of existing information (See
Section 4 of this RIA). If it is determined by the USACE, New Orleans District or Galveston
District and/or EPA, Region 6 that the existing information is inadequate, it will be necessary to
collect new sediment samples and conduct appropriate analyses to characterize the dredged
material and determine environmental acceptability.
3.4 Information submitted to EPA. The following information, required for evaluation of
dredged materials proposed for ocean disposal, shall be provided to EPA, Region 6, by the
USACE, New Orleans District and Galveston District in written format for each dredging
project: 1) dredging project information; 2) dredged material characterization/evaluation; and 3)
regulatory compliance evaluation. Appendix A offers a more detailed listing of the required
information to be submitted.
For USACE navigational projects, the USACE, New Orleans District or Galveston District shall
submit its evaluation to EPA, Region 6 at least 3 months before the advertisement date for any
dredging work. This should allow adequate time to acquire additional information (e.g. perform
sampling and analysis of the dredged material) that EPA may request. In some cases this time
frame may not be achievable, specifically for those USACE navigational projects that are
maintained on an annual or more frequent basis. For these special cases, a schedule shall be
created for the submittal of the dredged material evaluation to ensure that all data will be
available for review with adequate time to make a determination.
3.5 EPA Review. The intent of the EPA review is to evaluate the environmental effects of
dredged material disposal and to ensure that compliance with the ocean dumping criteria at 40
CFR 220-228 has been demonstrated. EPA, Region 6 will utilize "evaluator worksheets" or
checklists to assist in the review of the dredged material characterization of proposed ocean
dumping projects. These worksheets, as provided in the EPA document, Guidance Manual for
the Review of Permitted and Civil Works Projects for the Ocean Disposal of Dredged Material
(EPA, 1992c), summarize the relevant information necessary to accurately assess the adequacy
of a project's sediment and water sampling; physical, chemical, and biological test procedures;
modeling (if applicable); technical and statistical analysis; and quality assurance considerations.
This will also ensure that all relevant documentation is contained in the project's administrative
record. These checklists, provided in Appendix E, are currently under revision by EPA and will
be replaced when finalized.
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Within 15 days of receipt of the USAGE dredged material evaluation, EPA may request
additional information deemed appropriate or necessary to evaluate the proposed disposal [40
CFR 225.2(b)]. After receiving all information, EPA, Region 6 will make an independent review
of the data to determine whether the proposed dredged material is suitable for ocean disposal [40
CFR 225.2(c)]. After EPA, Region 6 receives all information, an evaluation will be made within
15 working days. Partial approval based on incomplete or draft information will not be given
except in unusual circumstances (e.g., emergencies).
EPA, Region 6 will inform the USAGE, New Orleans District or Galveston District in writing
whether the material complies with the ocean dumping criteria and regulatory requirements and
explain why it does or does not. If EPA, Region 6 determines that the material does not comply
with the criteria, then the ocean disposal of that material is prohibited. The USAGE, New
Orleans District or Galveston District and EPA, Region 6 shall then evaluate management
actions outside the scope of this RIA. In these cases, procedures for invoking economic impact
[40 CFR 225.3] may be followed and the District Engineer may request that the Regional
Administrator of the EPA, Region 6 grant a waiver of the criteria pursuant to 40 CFR 225.4.
4. TIERED TESTING APPROACH
4.1 Overview. The EPA and the USAGE implement a "tiered" testing approach to evaluate
benthic and water column impacts of dredged material proposed for ocean disposal. This
approach is designed to aid in generating only enough information to characterize the dredged
material and make a regulatory compliance decision. This allows optimal use of resources by
focusing the least effort on dredging operations where impacts are clear, and expending the most
effort on operations requiring more extensive investigations to determine the potential for
impacts. It is necessary to proceed through the tiers only until information sufficient to
demonstrate compliance with or noncompliance with 40 CFR 227.6 and 227.13 has been
obtained. Figure 2 presents a flowchart overview of the "tiered" approach to dredged material
evaluation described in this RIA.
4.2 Limiting Permissible Concentration. Compliance with the ocean dumping regulations is
determined by demonstrating that the Limiting Permissible Concentration (LPC) has been met
for each of the three phases which dredged material may impact through disposal into ocean
waters. The LPC for the liquid phase [40 CFR 227.27(a)] is the concentration of the constituent
that, after allowing for initial mixing, does not exceed the acute marine water quality criteria
(WQC) for that constituent and/or a toxicity threshold of 0.01 of the acutely toxic concentration
of the dredged material. The LPC of the suspended particulate phase and solid phases is the
concentration which will not cause unreasonable toxicity and which will not cause
bioaccumulation of contaminants of concern in the human food chain (SPP bioaccumulation
testing is not required) [40 CFR 227.27(b)].
4.3 Tier I-Existing Information. At a minimum, a Tier I evaluation shall be conducted for
each proposed dredging project. Tier I is a comprehensive analysis of all existing and readily
available, assembled, and interpreted information on the proposed dredging project. This may
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FIGURE 2. Overview of Tiered Testing Approach
IS INFORMATION
SUFFICIENT TO MAKE j
A DECISION? I
''•-.... YES
DOES DM MEET
EXCLUSIONARY
CRITERIA?
YES
TIERI
EXISTING
INFORMATION
•••*"" ''"'••. i
< NO >i
< NO
DM SAMPLE COLLECTION
EVALUATE PHYSICAL &
CHEMICAL CHARACTERISTICS
EVALUATE POTENTIAL BENTHIC
IMPACT
TIERS II, III, IV
NEW DATA
EVALUATION
EVALUATE POTENTIAL
WATER-COLUMN IMPACT
EVALUATE
BENTHIC TOXICITY
EVALUATE BENTHIC
BIOACCUMULATION
COMPLIANCE
WITH WQC
EVALUATE WATER -
COLUMN TOXICITY
DM Dredged Material
LPC Limiting Permissible Concentration
as defined in 40 CFR 227.27
WQC Applicable Marine Water Quality Criteria
< NO
DOES DM MEET
ALL ASPECTS OF
LPC?
EVALUATE MANAGEMENT
ACTIONS AS APPROPRIATE
EVALUATE REMAINING
REGULATORY REQUIREMENTS
-------
include, but is not limited to all previously collected physical, chemical and bioassay data; new
and existing activities within the area (e.g. industry, navigation, significant sources of point
source and non-point source pollution, etc.); and available data on spills that may have occurred
after the last sediment characterization, discharges, and existing sediment quality. If no bioassay
data exists for a proposed dredging project, which does not meet the exclusionary criteria, Tier
III bioassay tests will be conducted. Data used to make a decision in Tier I must meet the
current testing requirements as discussed in this document (i.e. species used, target detection
limits). For existing data, quality assurance/quality control information should be verifiable.
Tier I evaluations are described in detail in Section 4.0 of the Green Book.
The EPA, Region 6 and the USAGE, New Orleans District and Galveston District have
determined that biological and chemical data greater than 5 years old may not be adequate to
conduct evaluations. Best professional judgment will be exercised by the USAGE, New Orleans
District and Galveston District and EPA, Region 6 in deciding when new chemical and
biological data are needed more frequently than every 5 years. Factors that will be considered
will include frequency of dredging, proximity to existing and historical pollution sources, and
age of historical data results.
4.4 Tier I-Exclusionary Criteria. Based on acceptable existing information, the dredged
materials may be excluded from further testing if they meet one of the exclusionary criteria at 40
CFR 227.13(b). Information on the proposed dredging site, sediment grain size, sediment
chemistry and potential for contamination may be needed in determining exclusion from further
testing. A conclusive written evaluation must be presented to show that the proposed dredged
material meets the exclusionary criteria. Appendix A lists the information that shall be used by
the USAGE, New Orleans District and Galveston District and EPA, Region 6 in determining if
the material meets the exclusionary criteria.
The exclusionary criteria are as follows:
1) Dredged material is composed predominantly of sand, gravel, rock or any other
naturally occurring bottom material with particle sizes larger than silt, AND the
material is found in areas of high current or wave energy such as streams with large
bed loads or coastal areas with shifting bars and channels; OR
2) Dredged material is for beach nourishment or restoration AND is composed
predominantly of sand, gravel or shell with particle sizes compatible with material on
the receiving beaches; OR
3) i) When the material proposed for dumping is substantially the same as the substrate
at the proposed disposal site, AND ii) the site from which the material proposed for
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dumping is far removed from known existing and historical sources of pollution so as
to provide reasonable assurance that such material has not been contaminated by such
pollution.
4.5. Tier I-Compliance Decisions. Once the existing information has been collected and
analyzed as part of the Tier I evaluation, one of the following decisions can be made on the
proposed project (See also Figure 2):
1) The dredged material meets the exclusionary criteria at 40 CFR 227.13(b). No further
testing is required and the material meets the limiting permissible concentration (LPC)
for the liquid, suspended particulate and solid phases (40 CFR 227.27). The analyses
required by other applicable provisions of the regulations including (40 CFR Part 227
Subparts B, C, D, E, and G and section 228.4(e)) must be performed.
2) The existing information is sufficient to make a decision on environmental
acceptability of the dredged material AND the dredged material does not meet the
exclusionary criteria at 40 CFR 227.13(b). The dredged material is then evaluated using
existing information to determine compliance with the LPC for the liquid, suspended
particulate and solid phases (40 CFR 227.27).
• If it is determined from the existing information that the dredged material meets the
LPC for all phases, no further testing is required and the material is compliant with 40
CFR 227.6 and 227.13(c). The analyses required by other applicable provisions of
the regulations including (40 CFR Part 227 Subparts B, C, D, E, and G and section
228.4(e)) must be performed.
• If it is determined from the existing information that the dredged material does not
meet the LPC for all phases, it is not compliant with 40 CFR 227.6 and 227.13.
Disposal of the material at a designated ODMDS is not supported. The USAGE, New
Orleans District or Galveston District and EPA, Region 6 shall then evaluate
management actions outside the scope of this RIA.
3) The existing information is inadequate to make a compliance decision (e.g. no
biological effects-based tests, age of data, new known sources of contamination, etc.). It
will be necessary to collect new sediment samples and conduct appropriate analyses to
characterize the dredged material and determine compliance with the 40 CFR 227.6 and
227.13. This requires development of a sampling plan (see Section 5 of this RIA) and
analysis of the dredged material at a higher tier.
4.6 Tiers II & Ill-New Data Evaluation. Dredged material evaluations at Tier II and Tier III
involve sampling and physical, chemical and biological testing of the proposed dredged material
to determine environmental acceptability.
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Sediment from the proposed dredging project and from the reference area shall be collected
according to an approved sampling and analysis plan or according to the terms and conditions of
the USAGE, New Orleans District or Galveston District scope of services and/or delivery orders
for their contract laboratory. The sequence of analyses and the sampling approach taken for the
project depend largely on time and resources. Section 5 of this RIA provides additional guidance
on sample design and approach.
Physical and chemical evaluations of the dredged material shall be conducted to characterize the
sediment. Physical analysis of the sediment provides general information on the physical
characteristics of the dredged material and can assist in assessing the impact of disposal on the
benthic environment and the water column at the disposal site. Chemical analysis of the
sediment shall be conducted to identify the constituents present in the dredged material and
contaminants of concern (COC). Contaminants of concern (COC) include compounds known or
suspected of contaminating the dredging site and the list of compounds identified as COC (See
Table 2 in Section 8). Physical and chemical analyses are described further in Section 8 of this
RIA, and can also be found in Section 9 of the Green Book.
Water column evaluations include determination of compliance of the liquid phase of the
dredged material elutriate with applicable Federal Marine Water Quality Criteria (WQC) and/or
state Water Quality Standards (WQS) [40 CFR 227.6(c)(l), 227.13(c)(2)(i-ii)] (Tier II). If WQC
or WQS have not been established for all COC detected in the sediments or if synergistic effects
are possible, further biological testing is required. Suspended-particulate phase bioassay (Tier
III) [40 CFR 227.6(c)(2), 227.13(c)(3)] considers the effects, after allowance for initial mixing,
of dissolved contaminants plus those associated with suspended particulates on water-column
organisms. Section 9 of this RIA and Sections 5, 6, 10 and 11 of the Green Book provide
additional information on water column evaluations.
Benthic evaluations include solid phase bioassays [40 CFR 227.6(c)(3), 227.13(c)(3)] that
provide an assessment of toxicity of the dredged material to appropriate sensitive benthic marine
organisms and an evaluation of the bioaccumulation potential of the COC in the proposed
dredged material (Tier III). An initial screen of the dredged material may be performed for
estimating the potential of non-polar organics to bioaccumulate using a theoretical
bioaccumulation potential calculation (Tier II). The initial screen will not be used to make
regulatory decisions in absence of bioassay tests, however, it may be used to aid in re-evaluating
the need for ocean disposal in an effort to avoid Tier III bioassay costs. Section 10 of this RIA
and Sections 5, 6, 10 and 11 of the Green Book provide additional information on benthic
evaluations.
10
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4.7 Tiers II & Ill-Compliance Decisions. After Tier II and/or Tier III analyses are completed,
one of three specific decisions can be made:
(1) The information is sufficient to determine that the dredged material meets the LPC
for any one or more of the phases (40 CFR 227.27) and is compliant with 40 CFR 227.6
and 227.13. The analyses required by other applicable provisions of the regulations
including (40 CFR Part 227 Subparts B, C, D, E, and G and section 228.4(e)) must be
performed;
(2) The information is sufficient to determine that dredged material does not meet the
LPC for the liquid, suspended particulate and/or solid phases (40 CFR 22121) and thus is
not compliant with 40 CFR 227.6 and 227.13. Disposal of the material at a designated
ODMDS is not supported. The USAGE, New Orleans District or Galveston District and
EPA, Region 6 shall then evaluate management actions outside the scope of this RIA; or
3) The information is insufficient to make a compliance determination and further
analyses are required at a higher tier.
4.7 Tier IV-Case-by-Case Analyses. When a decision regarding toxicity or bioaccumulation
cannot be reached at earlier tiers or when circumstances warrant, case-by-case evaluations shall
be used to determine compliance with the ocean dumping regulations. Tests at this level should
be selected to address specific project issues for a specific dredging operation that could not be
fully evaluated in the earlier tiers. If the information is insufficient to determine compliance
after completing Tier I, II, or III, further testing is not required if noncompliance with the LPC is
assumed. This level of testing is intended for exceptional circumstances only; it should not be
routinely applied. Section 7.0 of the Green Book provides additional information on Tier IV
evaluations.
5. SAMPLING AND ANALYSIS PLAN
5.1 Sampling and Analysis Plan. The development of a project-specific sampling and analysis
plan (SAP) is the next step in the project evaluation process for those projects found to have
inadequate information to make a regulatory decision on suitability of dredged material disposal
following a Tier I evaluation. The SAP is the main source of information about the proposed
dredging project's sampling design/approach and quality assurance/quality control (QA/QC)
measures associated with sample collection and dredged material analyses. This RIA
recommends including all project-specific sampling, testing and QA/QC components in the
project SAP.
Sampling and testing must be coordinated far enough in advance of dredging to allow time for
testing and data review. The guidance document, QA/QC Guidance for Sampling and Analysis
11
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of Sediments, Water, an d Tissues for Dredged Material Evaluations (EPA/US ACE, 1995), and
Appendix G of the ITM should be used when preparing a project SAP. Section 8 of both the
Green Book and the ITM also address sample collection, however, the guidance provided in the
ITM is more technically advanced and should be used as reference for preparing a SAP.
The USAGE, New Orleans District and Galveston District, and EPA, Region 6 plan to prepare a
Dredged Material Evaluation Quality Assurance Plan (QAP), which will address basic QA/QC
issues associated with dredged material sampling and evaluations. The QAP will include all
general QA/QC information and requirements that apply across all dredging projects including
field sampling and clean techniques, laboratory testing, data validation and reporting, and other
QA/QC procedures. While basic/general sampling and analysis protocols will be addressed in
the QAP, the individual project sampling design and project-specific QA/QC issues should be
addressed in the project SAP. Once the QAP is finalized it will be included as an appendix to
this RIA. Section 6 of this RIA contains additional information on QA/QC.
The USACE, New Orleans District and Galveston District shall provide EPA, Region 6 the
opportunity to review all project SAPs submitted by apermiteefor individual projects or to be
submitted to the contractor for USACE navigational projects before work is initiated.
Applicants are strongly encouraged to arrange pre-application meetings with the USACE, New
Orleans District or Galveston District and EPA, Region 6 to prepare appropriate sampling and
analysis plans, if necessary. Advance coordination for USACE navigational projects occurs
during the New Orleans District's annual Environmental Dredging Conference and the
Galveston District's annual Dredging Conference where the USACE Districts present the
proposed maintenance dredging projects for the upcoming fiscal year.
The SAP should contain, at a minimum, the following general categories of information in as
much detail as possible.
1) Summary Information: Tier I information, including dredging site history and
location, identification of potential sources of contamination, and proposed list of
contaminants of concern.
2) Project Description: a plan view of the site (if available), the estimated type and
volume of sediment to be dredged, the depth and physical nature of the sediments,
practicable widths and depths of dredging, and dredging methods and equipment.
3) Sampling Design and Approach: number of samples, distribution/location of
samples, reference area location, number of replicates, sample compositing, sample
depth, sample volume, tests to be conducted for each sample station (e.g. sediment
chemistry or bioassays).
12
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4) Personnel Responsibilities: individual roles and responsibilities, project planning and
coordination, field sampling, chemical and biological testing, QA/QC management, and
final report preparation.
5) QA/QC Requirements: project-specific testing and/or sampling QA/QC issues (may
include laboratory specific standard operating procedures, equipment decontamination,
sample handling protocols including clean techniques, sample transport and chain of
custody). Certain QA/QC requirements may be addressed in contract laboratory quality
management plans/documents and should be referenced or included in the SAP.
5.2 Sampling Design. An appropriate and defensible sampling design should be used as the
basis for data collection for use in compliance decisions. The choice of a sampling design
depends on several factors including but not limited to, the decision to be made with the data,
frequency of dredging, historical or known location of shoaling, historical or known volumes of
materials dredged, and cost of sampling and analysis. Chapter 8 of both the Green Book and
ITM, should be used for detailed guidance for developing the sampling strategy, however, the
guidance provided in the ITM is more technically advanced and should be used as reference for
preparing a sampling strategy. Plumb (1981) provides additional guidance on sample design.
When possible, a survey of the proposed dredging project should be conducted prior to initiation
of the contracting process to obtain pertinent information on shoaling volumes and locations.
When it is not possible to conduct a survey in adequate time, the best option will be to design a
sampling approach based on estimated volumes and to collect a range of samples from areas of
historical shoaling.
Through design optimization, the sampling effort can be distributed spatially in such a way as to
maximize the amount of information obtained within the area to be sampled. Many dredging
projects can be subdivided into project segments (horizontal and/or vertical) which can be treated
as separate management units or dredged material management units. Each project segment is
an area expected to have relatively consistent characteristics that differ substantially from the
characteristics of adjacent segments. It is recommended that this approach be used whenever
possible in developing a sampling design for a specific project. Section 8 of both the Green
Book and ITM provide additional guidance on the subdivision of the dredging area, however, the
guidance provided in the ITM is more technically advanced and should be used as reference for
subdivision of the dredging area.
The method of dredging, volume of material to be dredged, areal extent of the dredging project,
the horizontal and vertical heterogeneity of the sediment, and proximity to known sources of
contamination are key to determining station locations and the number of samples to be collected
for the total dredging operation and for each project segment or dredged material management
unit. Section 8 of both the Green Book and ITM provide additional guidance on selection of
13
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sampling locations and number of samples, however, the guidance provided in the ITM is more
technically advanced and should be used as reference for determining sample location and
number.
Samples may be composited, when appropriate, prior to analysis. The number of samples and
proper use of compositing should be determined for each proposed project on a case-by-case
basis. Each dredged material sampling station should be sampled as a composite of several
samples at an area proposed for dredging within the channel. Section 8 of both the Green Book
and ITM provide additional guidance on sample compositing, however, the guidance provided in
the ITM is more technically advanced and should be used as reference for sample compositing.
5.3 Sampling Approach. Once a sampling design is developed, the sampling approach should
be determined in order to ensure that enough sediment is collected for the appropriate tests to be
conducted. Sufficient sediment and water should be collected to conduct all physical, chemical
and biological tests to ensure that all sediments are collected at the same time in order to
meaningfully compare the biological and chemical data. Sediments to be used for biological
testing may be archived pending results of the chemical analyses. However, given the relatively
short holding times for archived sediments to be used to conduct biological testing, unless quick
turn-around on chemical analyses of sediments is assured, it is recommended that the chemical
and biological tests be run concurrently. Appendix B of this RIA provides a summary of
recommended procedures for sample collection, preservation and storage. Table 1 provides
guidance on the types of samples that may be required to be collected in the field to conduct
dredged material evaluation tests.
5.4 Sample Collection. An accurate assessment of the physical, chemical and biological
characteristics of sediment proposed for dredging is dependent upon the collection of
representative samples. Steps must be taken during the sampling process to ensure that samples
accurately represent the area to be dredged (see above discussion on sample design and
approach). In general, the sampling areas should be located within areas of proposed dredging
where the largest amounts of sediments are planned for removal or in areas of known or
suspected contamination. Sampling should generally be to the project depth (including advance
maintenance and allowable over-depth) unless the sediments are known to be vertically
homogeneous. Homogeneous sediments are sediments that appear the same in physical
characteristics throughout the depth of the area to be dredged, and lack obvious color striations,
layering, or sorting of grain size. For areas which are dredged frequently or new projects which
involve the dredging of native material, the entire dredging prism may be considered
homogeneous.
Appendix B (reproduced from the ITM) of this RIA presents recommended sampling methods
and volumes. Any deviation from the recommendations in Appendix B shall be submitted to
EPA, Region 6 and the USAGE, New Orleans District and Galveston District for review and
approval prior to the sampling effort. If the recommendations in Appendix B are not followed,
14
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analytical results may be rejected as being unacceptable. Table 1 provides guidance on the types
of samples that may be required to be collected in the field to conduct dredged material
evaluation tests. EPA recommends that clean techniques (EPA 1600 series methods) be used
for collection and analysis of metals in water.
Most of the navigational projects constructed and maintained by the USAGE New Orleans
District and Galveston District are in areas that have frequent ship traffic and from which
sediments are dredged at short intervals. In these cases, grab samples can be representative of
the mixed sediment column, and corers should only be necessary if excavation of infrequently
disturbed sediments below the mixed layer is planned.
Accurate positioning of sampling stations is essential in investigations of sediment
characteristics. All samples should be obtained as close as possible to the target locations
provided in the project sampling plan. All sediment sampling locations should be recorded to a
horizontal accuracy of ±2 meters (or as approved in the sampling and analysis plan). Such
accuracy can be obtained by survey landmarks and a variety of positioning hardware. If
sampling locations are referenced to a local coordinate grid, the local grid should be tied to the
North American Datum (NAD 1983) to allow conversion to latitudes and longitudes. The use of
a standard horizontal datum will allow dredging data to be accurately mapped, including display
and analysis using geographic information system (GIS) software.
5.5 Reference and Control Sediments. It is important to distinguish clearly between reference
and control sediments in the context of benthic impact. Test procedures are conducted on the
control and reference sediments in the same way as on the dredged material proposed for ocean
dumping.
Reference Sediment
Reference sediment is defined in the Green Book as a sediment, "substantially free of
contaminants, that is as similar as practicable to the grain size of the dredged material and the
sediment at the disposal site, and that reflects the conditions that would exist in the vicinity of the
disposal site had no dredged material disposal ever taken place, but had all other influences on
sediment condition taken place." The reference sediment serves as a point of comparison to
identify potential effects of contaminants in the dredged material.
This RIA requires that the reference area approach be used rather than the reference point
approach. In the reference area approach, the reference location is viewed not as a single station
or point, but as the entire area in the environs of the disposal site, excluding the disposal site
itself. Rather than characterize the reference area by sampling at a single point, it is
characterized by a number of samples taken throughout the reference area and composited
according to methods described in the Green Book.
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Table 1. Sample Collection Requirements
This table contains general guidance on the type of samples that may be required to be collected in the field to
conduct dredged material evaluation tests.
Tests
Tier II
Water Column
Screen
Elutriate
Tier II
Benthic
Tier III
Water Column
SPP Toxicity
Test
Tier III
Benthic
Solid Phase
Toxicity Test
and
Bioaccumulation
Test
Water Samples
Disposal
Site
•
•
•
•
Dredging
Site
•
•
Control
•
Sediment Samples
Dredging
Site
•
•
•
•
•
Reference
Site
•
•
Control
•
Purpose
Chemical analyses of disposal site
water and dredging site sediments are
required for model inputs.
Dredging site water and sediments are
used for elutriate preparation.
Chemical analysis of the liquid phase
of the dredged material elutriate is used
to determine compliance with
WQC/WQS. Chemical analysis of
disposal site water and liquid phase of
the elutriate is required for model
inputs.
Chemical and physical analyses of
dredging site sediment samples and
reference site sediment samples are
required for TBP calculations.
Organisms are exposed to dilution
water, control water and the dredged
material dilution series. Dredging site
water and sediments are used for
elutriate preparation. Disposal site
water or artificial sea water may be
used for dilutions. Control water is
required for bioassay test acceptance.
Organisms are exposed to dredging site
sediments, reference sediment and
control sediment for toxicity and
bioaccumulation bioassays. Control
sediment is required for bioassay test
acceptance. Chemical analyses of
organism tissues are required for
bioaccumulation tests. Disposal site
water, clean sea water or artificial sea
water may be used to conduct
bioassays.
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The reference areas are located within 2-5 nautical miles of the ODMDS and at a location
opposite the direction of net transport. The reference area sediment sample for a given project
must be a composite comprised of a minimum of three samples. See Appendix D for reference
area locations for ODMDS in Texas and Louisiana. Reference areas for Section 103 permit
applicants will be determined on a case-by-case basis.
Control Sediment
Control sediment is distinguished from the reference sediment because it is collected from the
site where the test species were collected or an area known to be free of contaminants, or it is the
sediment that the organisms are cultured in the laboratory. The control sediment is used to
confirm the health of the test organism during bioassay tests, and to validate the test protocol as
part of the laboratory QA/QC program. The control sediment should have previously been
demonstrated to result in good survival and growth of test organisms.
Excessive mortality in the control sediment indicates a problem with testing conditions or
organisms and can invalidate the corresponding test results. It may also indicate that test species
are overly sensitive to the different grain sizes. This RIA recommends that if mortality is greater
than 10% in the control treatment for a particular test species (30% mortality/abnormality for
zooplankton in the water column bioassay), the causes of the failure should be identified (e.g.
grain size sensitivity, pH, ammonia, etc.) and the bioassay repeated.
6. QUALITY ASSURANCE/QUALITY CONTROL
An effective quality control program must be an integral part of the dredging evaluation from the
initiation of field collection. The importance of a quality assurance (QA) program is to ensure
that the data collected in order to make regulatory decisions is of known and documented quality,
as well as to ensure that quality control (QC) procedures have been implemented and
documented. QA programs set standards for personnel qualifications, facilities, equipment,
services, data generation, record-keeping, and data-quality assessments. QC procedures for the
general characterization of sediments are necessary to ensure that the data meet acceptable
criteria for precision and accuracy.
The USAGE, New Orleans District and Galveston District, and EPA, Region 6 plan to prepare a
Dredged Material Evaluation Quality Assurance Plan (QAP), which will address basic QA/QC
issues associated with dredged material sampling and evaluations. The QAP will include all
general QA/QC information and requirements that apply across all dredging projects including
field sampling and clean techniques, laboratory testing, data validation and reporting, and other
QA/QC procedures.
17
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While basic/general sampling and analysis protocols will be addressed in the QAP, the
individual project sampling design and project-specific QA/QC issues should be addressed in
the project SAP Certain QA/QC requirements may be addressed in contract laboratory quality
management plans/documents and should be referenced or included in the SAP. Once the QAP
is finalized it will be included as an appendix to this RIA.
The Dredged Material Evaluation QAP will be prepared using the following guidance
documents: QA/QC Guidance for Sampling and Analysis of Sediments, Water, and Tissues for
Dredged Material Evaluations (EPA/US ACE, 1995), and EPA Requirements for a QA Project
Plan - QA/R-5 (EPA, 2001a; www.epa.gov/qualityl). Additional guidance may also be obtained
from the Green Book and the ITM, however the guidance provided in the ITM (Appendix G) is
more technically advanced and should be used as reference for general QA/QC considerations.
Until the Dredged Material Evaluation QAP is prepared, the guidance provided in the
EPA/US ACE (1995) QA/QC guidance document and in Appendix G of the ITM will be utilized.
The USAGE, New Orleans and Galveston District will consult the Dredged Material Evaluation
QAP, when finalized, when negotiating contracts for dredged material evaluations to assure all
QA/QC measures are addressed. EPA will also assist in QC oversight activities including inter-
laboratory comparisons and routine inspections. QA/QC requirements may be addressed in
contract laboratory quality management plans/documents and should be reviewed to ensure that
the requirements of the QAP, once finalized, are met.
7. DREDGED MATERIAL EVALUATION
Under 40 CFR 227.13(c), evaluation of dredged material to determine environmental
acceptability focuses on biological effects rather than the presence/absence of contaminants. The
Green Book and the ocean dumping regulations stress the use of effects-based bioassays as
evaluative tools necessary to determine the potential impact of the dredged material on both the
benthic environment and water column. Bioassays are used to predict environmental effects
because they are regarded as the best methods available for integrating the effects of multiple
contaminants and for comparing the relative impacts of different dredged materials. Test
organisms integrate and quantify the effects of chemical and physical constituents of a dredged
material. Contaminant-based effects of the sediment can then be assessed in a holistic manner.
The biological effect of the dredged material is evaluated using new or historical data. If no
acceptable biological effects-based data exist for a proposed dredging project and it does not
meet the exclusionary criteria then biological effects-based bioassays will be conducted to
determine regulatory compliance. For most projects, the impact of the solid phase on the benthic
environment deserves the most rigorous evaluation, because the dredged material that is
deposited on the sea floor usually causes greater long-term impact than the fraction of the
dredged material that is temporarily suspended in the water column.
18
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The ocean dumping regulations [40 CFR 227.27(b)] require that both acute and chronic toxicity
effects of dredged material placement should be measured. Chronic methods are important for
assessing long-term effects, including reproduction and growth of benthic organisms. EPA has
developed a standard method for assessing chronic toxicity to the amphipod Leptocheirus
plumulosus (EPA, 2001b) which can be accessed online at www.epa.gov/waterscience.
8. PHYSICAL AND CHEMICAL EVALUATIONS
8.1 Physical Analysis. Physical analysis of the dredged material provides general information
on the physical characteristics of the dredged material and can assist in assessing the impact of
disposal on the benthic environment and the water column at the disposal site. Physical analysis
of the reference sediment is required for Tier II TBP calculations, if conducted. The
conventional parameters to be analyzed for physical characterization of sediment include the
following, at a minimum: grain size distribution, total organic carbon (TOC), total petroleum
hydrocarbons (TPH), ammonia, and percent solids. A comprehensive listing of appropriate
analytical methods for the conventional parameter analyses of sediments is provided in Table 3
of the QA/QC Guidance for Sampling and Analysis of Sediments, Water and Tissues for Dredged
Material Evaluations (EPA/US ACE, 1995). Target Detection Limits (TDLs) for conventional
parameter analyses in sediment, tissue and water (where applicable) are provided in Appendix C.
Table 1 provides guidance on the types of analyses required to conduct dredged material
evaluation tests for various field collected samples. Additional QA/QC guidance is provided in
Appendix G of the ITM and in QA/QC Guidance for Sampling and Analysis of Sediments, Water
and Tissues for Dredged Material Evaluations (EPA/USACE, 1995).
8.2 Chemical Analysis. Chemical analysis of the dredged material provides information about
the contaminants present in the dredged material that, if biologically available, could cause
toxicity and/or be accumulated in tissues. Chemical analysis of disposal site water is required for
Tier II water column effects modeling. Chemical analysis of the reference sediment is required
for Tier II TBP calculations, if conducted. Sediment-chemistry data alone should not be directly
used to make decisions regarding the acceptability of dredged material for ocean disposal.
Section 9 of the Green Book also addresses chemical analyses. A comprehensive listing of
appropriate analytical methods for determining contaminants in sediments is provided in Table 3
of the QA/QC Guidance for Sampling and Analysis of Sediments, Water and Tissues for Dredged
Material Evaluations (EPA/USACE, 1995). Table 1 provides guidance on the types of analyses
required to conduct dredged material evaluation tests for various field collected samples.
Additional QA/QC guidance is provided in Appendix G of the ITM and in QA/QC Guidance for
Sampling and Analysis of Sediments, Water and Tissues for Dredged Material Evaluations
(EPA/USACE, 1995).
Contaminants of Concern
Table 2 lists potential contaminants of concern (COCs) and additional optional contaminants for
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dredged material evaluation. The COCs listed in Table 2 are EPA priority pollutants and have
been published in the Federal Register, "National Recommended Water Quality Criteria;
Republican"on" (EPA, 1998). Target Detection Limits (TDLs) for the parameters listed in Table
2 plus other potential contaminants for sediment, tissue and water analyses are provided in
Appendix C. Generally, if one or more COCs are detected in the sediments, synergistic effects
are possible and Tier III level bioassays shall be conducted for evaluation of benthic and water
column impacts.
If no sediment chemistry data exist for a dredging project, analysis for the complete list of COCs
in Table 2 will be performed. Where sediment chemistry data exist and contaminants of concern
are known for a specific project, the basic COC list for that project may be reduced or
supplemented by mutual agreement of the USAGE, New Orleans District or Galveston District
and EPA, Region 6.
For example, if a pulp and paper mill or organic chemical plant discharges to a channel proposed
for dredging, dioxin may be added to the list of contaminants of concern. Similarly, if a ship
maintenance dock or boat marina is proposed to be dredged, tributyltin may be included.
Conversely, if a particular COC has not historically been detected in the sediments from a
specific project and no new sources of the COC in question are identified, that COC may be
removed from the list of COCs for that specific project. Contaminants detected on gas
chromatograms or reconstructed ion chromatograms that are not listed in Table 2 should be noted
in the final project evaluation.
9. WATER COLUMN EVALUATIONS
Water column evaluations are required to determine compliance with the LPC of both the liquid
(40 CFR 227.27(a)) and suspended particulate phases (40 CFR 227.27(b)) of the dredged
material. These evaluations include determination of compliance with applicable EPA marine
Water Quality Criteria (WQC) and/or state Water Quality Standards (WQS) and potential
impacts of the suspended parti culate phase of the dredged material elutriate on appropriate
sensitive marine organisms.
9.1 Dredged Material Elutriate Preparation. The dredged material elutriate preparation
(Section 10.1.2 of the Green Book) involves mixing the dredged material with dredging site
water in a sediment-to-water ratio of 1:4 and allowing the mixture to settle for one hour. The
portion of the dredged material that is considered to have the potential to impact the water
column is the supernatant remaining after undisturbed settling. The suspendedparticulatephase
is the supernatant from the dredged material elutriate preparation and is used for water column
bioassays. The liquid phase is the supernatant from the dredged material elutriate preparation
that has been centrifuged or filtered and is used for EPA WQC/state WQS screening. When
analyzing for metals, filtration of the supernatant through a 0.45 |j,m filter is required
(centrifugation optional). EPA recommends that clean techniques (EPA 1600 series methods)
be used for collection and analysis of metals in water/liquid phase. When analyzing for
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TABLE 2
Contaminants of Concern (COC) and Conventional Parameters
METALS AND CYANIDE
Antimony (Total)
Arsenic (Total)
Beryllium (Total)
Cadmium (Total)
Chromium (Total)
Chromium (+3)
Chromium (+6)
Copper (Total)
Lead (Total)
Mercury (Total)
Nickel (Total)
Selenium (Total)
Silver (Total)
Thallium (Total)
Zinc (Total)
Cyanide (Total)
CONVENTIONAL PARAMETERS
Grain Size
TOC
TPH
Ammonia
Percent Solids/Total Solids
ORGANIC COMPOUNDS
Phenols/Substituted Phenols
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-o-Cresol [2 methyl 4,6-
dinitrophenol
2,4-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
p-Chloro-m-Cresol [4 chloro-3-
methylphenol]
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
MISCELLANEOUS
Isophorone
LPAH Compounds
Acenaphthene
Acenaphthylene
Anthracene
Fluorene
Naphthalene
Phenanthrene
HP AH Compounds
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(ghi)perylene
Benzo(b & k)fluoranthene
Chrysene
Dibenzo (a,h) anthracene
Fluoranthene
Indeno (1,2,3-cd) pyrene [2,3-o-
phenylene pyrene]
Pyrene
Chlorinated Hydrocarbons
1,2-Dichlorobenzene
1,3 -Dichlorobenzene
1,4-Dichlorobenzene
2-Chloronapthalene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
1,2,4-Trichlorobenzene
Phthalate Esters
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Diethyl Phthalate
Dimethyl Phthalate
Di-n-Butyl Phthalate
Di-n-octyl Phthalate
Halogenated Ethers
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-chloroisopropyl) ether
4-Bromophenyl phenyl ether
4-Chlorophenyl phenyl ether
PESTICIDES
Aldrin
Alpha-BHC
Beta-BHC
Gamma-BHC (Lindane)
Delta-BHC
Chlordane
4,4'-DDT
4,4'-DDE
4,4'-ODD
Dieldrin
Alpha-endosulfan
Beta-endosulfan
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide (BHC-
hexachlorocyclohexane)
Toxaphene
PCBs
Total PCBs
PCB Congeners*
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-1260
PCB-1016
Organonitrogen Compounds
Benzidine
3,3' -Dichlorobenzidine
2,4-Dinitrotoluene
2,6-Dinitrotoluene
1,2-Diphenylhydrazine
Nitrobenzene
N-nitrosodimethylamine
N-nitrosodi-n-propylamine
N-nitrosodiphenylamine
*Optional to analyze
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organics, the supernatant should only be centrifuged.
9.2 Water Quality Criteria/Standards Evaluation Using the Liquid Phase-Tier II. To
determine compliance or noncompliance with applicable EPA WQC or state WQS, the potential
release of dissolved contaminants from the dredged material shall be analyzed using the liquid
phase of the dredged material elutriate. Chemical analysis of liquid phase allows a direct
comparison to applicable EPA marine WQC and state WQS. A comprehensive listing of
appropriate analytical methods for evaluating the liquid phase of the dredged material elutriate is
provided in Table 3 of the QA/QC Guidance for Sampling and Analysis of Sediments, Water and
Tissues for Dredged Material Evaluations (EPA/US ACE, 1995). EPA recommends that clean
techniques (EPA 1600 series methods) be used for collection and analysis of metals in
water/liquid phase. Additional QA/QC guidance is provided in Appendix G of the ITM and in
QA/QC Guidance for Sampling and Analysis of Sediments, Water and Tissues for Dredged
Material Evaluations (EPA/US ACE, 1995).
The EPA WQC for priority pollutants and nonpriority pollutants have been published in the
Federal Register, "National Recommended Water Quality Criteria; Republican"on" (EPA, 1998),
and all subsequent updates should be utilized. Louisiana Numerical Criteria for Specific Toxic
Substances and Texas Surface Water Quality Standards may also be applied in those instances
where the state's criteria are more stringent or where no EPA marine WQC exist.
The following points shall be considered when making comparisons of the liquid phase COC
concentration with the WQC/WQS:
* If WQC and/or WQS have not been established for all COC detected in the sediments or if
synergistic effects are possible due to detection of one or more contaminants, further
biological testing of the suspended particulate phase is required (40 CFR 227.13(c)(2)(i)), see
Section 9.3 below. The water column analyses alone are not sufficient for determining
suitability of the dredged material for ocean disposal; evaluation of the benthic impacts (solid
phase bioassay and bioaccumulation potential) must also be conducted. In addition, the
analyses required by other applicable provisions of the regulations including (40 CFR Part
227 Subparts B, C, D, E, and G and section 228.4(e)) must be performed.
* If WQC and/or WQS have been established for all COC detected in the liquid phase and they
are not exceeded, the LPC for the liquid phase is met. If one or more contaminants are
detected in the sediments, synergistic effects are possible and further biological testing of the
suspended particulate phase is required (40 CFR 227.13(c)(2)(i)), see Section 9.3 below. The
water column analyses alone are not sufficient for determining suitability of the dredged
material for ocean disposal; evaluation of the benthic impacts (solid phase bioassay and
bioaccumulation potential) must also be conducted. In addition, the analyses required by
other applicable provisions of the regulations including (40 CFR Part 227 Subparts B, C, D,
E, and G and section 228.4(e)) must be performed.
* If applicable WQC and/or WQS are exceeded in the liquid phase, the models as described in
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* the Green Book may be used for further analysis. Chemical analyses of the liquid phase and
disposal site water are required for model inputs. Appendix B of the Green Book provides
guidance on which numerical computer model should be applied.
• If the model predicts the WQC and/or WQS are not exceeded after allowance for
initial mixing, the LPC for the liquid phase is met. If multiple contaminants are
detected in the sediments, synergistic effects are possible and further biological
testing of the suspended particulate phase is required (40 CFR 227.13(c)(2)(i)), see
Section 9.3 below. The water column analyses alone are not sufficient for
determining suitability of the dredged material for ocean disposal; evaluation of the
benthic impacts (solid phase bioassay and bioaccumulation potential) must also be
conducted. In addition, the analyses required by other applicable provisions of the
regulations including (40 CFR Part 227 Subparts B, C, D, E, and G and section
228.4(e)) must be performed.
• If the model predicts that WQC and/or WQS will be exceeded after allowance for
initial mixing, the LPC for the liquid phase is not met and disposal of the dredged
material without appropriate management is not supported. The USAGE, New
Orleans District or Galveston District and EPA, Region 6 shall then evaluate
management actions outside the scope of this RIA.
9.3 Water Column Bioassay Using the Suspended Particulate Phase-Tier III.
9.3.1 Suspended Particulate Phase Toxicity Test. The suspended particulate phase (SPP)
bioassay considers the effects, after allowance for initial mixing, of dissolved contaminants plus
those associated with suspended particulates on water-column organisms. This bioassay
involves exposing test organisms to a dilution series consisting of at least three concentrations
(100%, 50% and 10% are recommended) of the suspended particulate phase of the dredged-
material elutriate. The dredged material elutriate preparation for this bioassay (Section 11.1.4 of
the Green Book) involves mixing the dredged material with dredging site water in a sediment-to-
water ratio of 1:4 and allowing the mixture to settle for one hour.
Disposal site water or artificial seawater should be used for dilutions. In addition, a control
treatment should be run using water of the type in which the animals were held prior to testing,
typically conditioned artificial seawater or natural seawater. Toxicity of the dilution water
should also be determined by conducting 100% dilution water treatment. Section 11.1 of the
Green Book contains further guidance on the suspended particulate phase toxicity test procedure.
Table 1 provides guidance on the types of samples that may be required to be collected in the
field to conduct the suspended phase toxicity test.
As described in Appendix G.2.10.5.2 of the ITM, reference toxicant tests should be performed
on all organisms used in dredged material testing to determine the health and sensitivity of the
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organisms. Additional QA/QC guidance is provided in Appendix G of the ITM and in QA/QC
Guidance for Sampling and Analysis of Sediments, Water and Tissues for Dredged Material
Evaluations (EPA/USACE, 1995).
9.3.2 Test Organisms. Bioassay tests shall be conducted on appropriately sensitive marine
water-column organisms exposed to dilution water, control water, and dredged material dilution
series according to EPA methods (EPA, 1991) and American Society for Testing and Materials
protocols (ASTM, 1994a, or most recent editions thereof). Appendix E of the ITM provides
summaries of test conditions and test acceptability criteria for conducting water column
bioassays for the organisms listed below. Any proposed variation to the methodologies must be
technically valid and mutually agreed upon by EPA, Region 6 and the USAGE, New Orleans
District and Galveston District before the bioassay tests are started.
Paragraph 227.27(c) of the ocean dumping regulations defines appropriate sensitive water-
column marine organism to mean at least one species each representative of phytoplankton or
zooplankton; crustacean or mollusc; and fish. Water-column bioassays must be conducted using
at least three organisms selected from the following list of test species:
Water column toxicity bioassay organisms
(* indicates recommended species)
Zooplankton
Copepod, Acartia sp.
Postlarval mysid shrimp, Americamysis bahia*
Crustacean
Mysid shrimp, Americamysis bahia*
Grass shrimp, Paleomonetes sp.
Fish
Inland or Atlantic Silversides, Menidia sp. *
Sheepshead minnow, Cyprinodon variegatus
9.3.3 Data Analysis
* If mortality is greater than 10% in the control treatment or in the dilution water treatment for
a particular test species (30% mortality/abnormality for zooplankton), the test should be
rejected and the bioassay repeated. If mortality is greater than 10% in the dilution water
treatment using disposal site water, the bioassay should be repeated using artificial seawater.
* If survival in all of the dredged material treatments is greater than, or equal to, survival in the
dilution water treatment, the LPC for water column toxicity/suspended particulate phase has
been met. The water column analyses alone are not sufficient for determining suitability of
the dredged material for ocean disposal; evaluation of the benthic impacts (solid phase
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* bioassay and bioaccumulation potential) must also be conducted. In addition, the analyses
required by other applicable provisions of the regulations including (40 CFRPart 227
Subparts B, C, D, E, and G and section 228.4(e)) must be performed.
* If survival in the dredged material treatments is less than survival in the dilution water
treatment, but the difference does not exceed 10%, the LPC for water column
toxicity/suspended paniculate phase has been met. The water column analyses alone are not
sufficient for determining suitability of the dredged material for ocean disposal; evaluation of
the benthic impacts (solid phase bioassay and bioaccumulation potential) must also be
conducted. In addition, the analyses required by other applicable provisions of the
regulations including (40 CFR Part 227 Subparts B, C, D, E, and G and section 228.4(e))
must be performed.
* If survival in the 100% dredged material elutriate treatment is less than survival in the
dilution water treatment, and the difference is greater than 10%, statistical analyses are
required to determine if the dredged material suspension is significantly more toxic than the
dilution water (i.e. the difference is statistically significant). Statistical procedures
recommended for analyzing test data are described in detail in Section 13 of the Green Book
and Appendix D of the ITM, however, the guidance provided in the ITM is more technically
advanced and should be used as reference for appropriate statistical methods.
• If the 100% dredged material elutriate treatment is not statistically different from the
dilution water, the dredged material is not predicted to be acutely toxic to water
column organisms and the LPC for water column toxicity/suspended particulate phase
has been met. The water column analyses alone are not sufficient for determining
suitability of the dredged material for ocean disposal; evaluation of the benthic
impacts (solid phase bioassay and bioaccumulation potential) must also be conducted.
In addition, the analyses required by other applicable provisions of the regulations
including (40 CFR Part 227 Subparts B, C, D, E, and G and section 228.4(e)) must be
performed.
• If the 100% dredged material elutriate treatment is statistically different from the
dilution water, it is necessary to run a numerical model to determine compliance with
the LPC.
Appendix B of the Green Book provides guidance on the appropriate numerical computer model
that should be applied. The key parameters derived from the model for evaluating water-column
toxicity are: 1) the maximum concentration of dredged material in the water column outside the
boundary of the disposal site during the 4-hour initial mixing period, and 2) the maximum
concentration in the water column in the marine environment after the 4-hour mixing period.
The modeled concentrations of the dredged material are compared with the LPC, as determined
by 0.01 of the 48- or 96-hour LCso, to determine compliance.
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The following points shall be considered when making modeled concentrations comparisons
with the LPC:
• The LCso is the concentration of the suspended paniculate phase that is lethal to 50%
of the organisms.
• If greater than 50% mortality occurs in at least one of the serial dilutions of the
dredged material treatments, it may be possible to calculate an LCso value.
• If less than 50% mortality occurs in all of the dredged material treatments, it is not
possible to calculate an LCso. In such cases, the LCso is assumed to be >100%.
• If the conditions are highly toxic, such that the 10% dredged material treatment has
greater than 50% mortality, further dilution must be made (new treatments of less
than 10% dredged material) to attain a survival of greater than 50% and determine the
LCso by interpolation.
• If both modeled concentrations are less than the 0.01 of the LCso, the LPC for water
column toxicity/suspended particulate phase is met. The water column analyses alone
are not sufficient for determining suitability of the dredged material for ocean
disposal; evaluation of the benthic impacts (solid phase bioassay and bioaccumulation
potential) must also be conducted. In addition, the analyses required by other
applicable provisions of the regulations including (40 CFR Part 227 Subparts B, C, D,
E, and G and section 228.4(e)) must be performed.
• If either of the modeled concentrations exceeds 0.01 of the LCso, the discharge does
not meet the LPC for water column toxicity/suspended particulate phase and disposal
of the dredged material without appropriate management is not supported. The
USAGE, New Orleans District or Galveston District and EPA, Region 6 shall
evaluate management actions outside the scope of this RIA.
10. BENTHIC EVALUATIONS
Benthic evaluations are required to determine compliance with the LPC of the solid phase (40
CFR 227.27(b)) of the dredged material. These evaluations include assessment of toxicity of the
dredged material to appropriate sensitive benthic marine organisms and an evaluation of the
bioaccumulation potential of the COC in the proposed dredged material. An initial screen of the
dredged material is included in Tier II of the Green Book and may be performed for estimating
the potential of non-polar organics to bioaccumulate using a theoretical bioaccumulation
potential calculation. However, compliance with LPC of the solid phase will be based on
benthic bioassays, including solid phase toxicity and bioaccumulation tests. The initial screen
will not be used to make regulatory decisions in absence of bioassay tests, however, it may be
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used to aid in re-evaluating the need for ocean disposal in an effort to avoid Tier III bioassay
costs.
10.1 Benthic Bioassay—Tier III.
10.1.1 Solid Phase Toxicity Test. Solid phase bioassays are conducted to evaluate potential
impacts to benthic marine organisms. Solid phase bioassay treatments should be comprised of
exposure to sediment from the dredging site, reference sediment, and control sediment. Disposal
site water, clean seawater or artificial seawater may be used to conduct the bioassay. Table 1
provides guidance on the types of samples that may be required to be collected in the field to
conduct the solid phase toxicity test.
Section 11.2 of the Green Book contains guidance on experimental procedures. As described in
Appendix G.2.10.5.2 of the ITM, reference toxicant tests should be performed on all organisms
used in dredged material testing to determine the relative health of the organisms. Reference
toxicant tests will be conducted for 96 hours. Additional QA/QC guidance is provided in
Appendix G of the ITM and in QA/QC Guidance for Sampling and Analysis of Sediments, Water
and Tissues for Dredged Material Evaluations (EPA/USACE, 1995).
10.1.2 Test Organisms. Bioassay tests shall be conducted on appropriately sensitive benthic
marine organisms [40 CFR 227.27(d)] exposed to reference area, control site, and proposed
dredging site sediment samples according to EPA methods (EPA, 1994; EPA, 1995a) and ASTM
protocols (ASTM, 1994b, c, d, or most recent editions thereof). Appendix E of the ITM provides
summaries of test conditions and test acceptability criteria for conducting solid phase bioassays
for the organisms listed below. Any proposed variation to the methodologies must be technically
valid and mutually agreed upon by EPA, Region 6 and the USAGE, New Orleans District and
Galveston District before the bioassay tests are started.
The benthic species should represent filter-feeding, deposit-feeding, and burrowing species.
These categories of species are broad and overlapping. At least two different species listed
below that together cover the three feeding strategies identified in the regulations should be used
to evaluate a disposal project. Both the Green Book and the ITM recommend that a sensitive
infaunal amphipod be used in solid phase toxicity evaluations. This RIA recommends using
either the amphipods Ampelisca abdita or Leptocheirusplumulosus in benthic toxicity
evaluations, however, alternative amphipod species may be substituted at the approval of EPA
and the USAGE. Guidance on available testing procedures provided by EPA (1994) and ASTM
(1994b, c) may be followed and modified to conduct a 10-day mysid test.
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Solid Phase Toxicity Bioassay Organisms
(* indicates recommended species)
Filter-feeding
Mysid shrimp, Americamysis bahia*
Juvenile Bivalves (clams), dwarf surf clam, Mulinia later alls
Deposit-feeding
Infaunal amphipod, Ampelisca abdita*
Amphipod, Leptocheirus plumulosus *
Polychaete, Neanthes succinea, Nereis virens
Grass shrimp, Paleomonetes sp.
Burrowing
Infaunal amphipod, Ampelisca abdita*
Amphipod, Leptocheirus plumulosus
Polychaete, Neanthes succinea, Nereis virens
10.1.3 Data Analysis.
* If greater than 10% mean mortality occurs in the control sediment, the test should be
repeated.
* If survival in the dredged material treatments is greater than, or equal to, survival in the
reference sediment treatments, the LPC for benthic toxicity has been met. The benthic
toxicity analyses alone are not sufficient for determining suitability of the dredged material
for ocean disposal; evaluation of the water column impacts and the bioaccumulation potential
of the solid phase must also be conducted. In addition, the analyses required by other
applicable provisions of the regulations including (40 CFR Part 227 Subparts B, C, D, E, and
G and section 228.4(e)) must be performed.
* If survival in the dredged material treatments is less than survival in the reference sediment
treatments, but the difference does not exceed 10% (20% for amphipods), the LPC for
benthic toxicity has been met. The benthic toxicity analyses alone are not sufficient for
determining suitability of the dredged material for ocean disposal; evaluation of the water
column impacts and the bioaccumulation potential of the solid phase must also be conducted.
In addition, the analyses required by other applicable provisions of the regulations including
(40 CFR Part 227 Subparts B, C, D, E, and G and section 228.4(e)) must be performed.
* If survival in the dredged material treatments is less than survival in the reference sediment
treatments, and the difference is greater than 10% (20% for amphipods), then statistical
analyses are required to determine if the dredged material is significantly more toxic than the
reference sediment. Statistical procedures recommended for analyzing test data are described
in detail in Section 13 of the Green Book and Appendix D of the ITM, however, the guidance
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provided in the ITM is more technically advanced and should be used as reference for
appropriate statistical methods.
• If mortality of organisms exposed to sediment from the dredging is not
statistically greater than the mortality of organisms exposed to the reference
sediment, then the LPC for the solid phase is met. The benthic toxicity analyses
alone are not sufficient for determining suitability of the dredged material for
ocean disposal; evaluation of the water column impacts and the bioaccumulation
potential of the solid phase must also be conducted. In addition, the analyses
required by other applicable provisions of the regulations including (40 CFRPart
227 Subparts B, C, D, E, and G and section 228.4(e)) must be performed.
• If bioassay organism mortality is statistically greater than in the reference
sediment, then the dredged material does not meet the LPC for the solid phase
and disposal of the dredged material without appropriate management is not
supported. The USAGE, New Orleans District or Galveston District and EPA,
Region 6 shall then evaluate management actions outside the scope of this RIA.
10.2 Bioaccumulation Testing-Tier III. Bioaccumulation tests are conducted to determine the
bioavailability of contaminants through 28-day exposure tests. The tests are designed to evaluate
the potential of benthic organisms to bioaccumulate COC from the dredged material. Section 12
of the Green Book contains guidance on bioaccumulation testing protocols. Bioaccumulation
treatments should include exposure to sediment from the dredging site, reference sediment and
control sediment. Disposal site water, clean natural seawater or artificial seawater may be used
to conduct the bioassay. Table 1 provides guidance on the types of samples that may be required
to be collected in the field to conduct the bioaccumulation test.
Section 12 of the Green Book contains guidance on experimental procedures. Additional
QA/QC guidance is provided in Appendix G of the ITM and in QA/QC Guidance for Sampling
and Analysis of Sediments, Water and Tissues for Dredged Material Evaluations (EPA/US ACE,
1995).
10.2.1 Test Organisms. Bioassay tests shall be conducted on appropriately sensitive benthic
marine organisms [40 CFR 227.27(d)] exposed to reference area, control site, and proposed
dredging site sediments according to EPA methods (EPA, 1994). Appendix E of the ITM
provides summaries of test conditions and test acceptability criteria for conducting
bioaccumulation tests for the organisms listed below. Any proposed variation to the
methodologies must be technically valid and mutually agreed upon by EPA, Region 6 and the
USAGE, New Orleans District and Galveston District before the bioassay tests are started.
Only organisms in a given replicate chamber may be composited for chemical analysis;
therefore, sufficient biomass must be obtained from each repliate to run analyses on the tissue.
The benthic species should represent filter-feeding, deposit-feeding, and burrowing species.
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These categories of species are broad and overlapping. At least two different species listed
below that together cover the three feeding strategies identified in the regulations should be used
to evaluate a disposal project.
Bioaccumulation Test Organisms
(* indicates recommended species)
Filter-feeding
Mollusk, Macoma nasuta
Quahog, Mercenaria sp. *
Deposit-feeding
Polychaete, Neanthes succinea, Nereis virens
Commercial shrimp, Penaeus aztecus*
Burrowing
Polychaete, Neanthes succinea, Nereis virens*
Other
Blue crab, Callinectes sapidus
Red Drum, Sciaenops ocellatus
10.2.2 Chemical Analysis of Tissues. Tissues of appropriate benthic organisms exposed to the
dredged material shall be analyzed for classes of COCs detected in the sediments. Ordinarily,
only those compounds detected in the sediment need be analyzed for in the tissue. In some
cases, however, it may be desirable to analyze tissues for compounds not detected in the
sediments. The detection limits listed in Appendix B will be used when conducting evaluations
of tissues from bioaccumulation tests. A comprehensive listing of appropriate analytical
methods for evaluating tissues is provided in Table 3 of the QA/QC Guidance for Sampling and
Analysis of Sediments, Water and Tissues for Dredged Material Evaluations (EPA/US ACE,
1995). Additional QA/QC guidance is provided in Appendix G of the ITM and in QA/QC
Guidance for Sampling and Analysis of Sediments, Water and Tissues for Dredged Material
Evaluations (EPA/USACE, 1995).
The basic strategy for selecting contaminants for tissue analysis should include three
considerations:
• The target analyte is a COC and is present in the sediment as determined by sediment
chemical analyses.
• The target analyte has a high potential to accumulate and persist in tissues.
• The target analyte is of toxicological concern
Generally, the relative potential for bioaccumulation of organic compounds can be estimated
from the Kow of the compounds. As stated in the Green Book and ITM, EPA recommends that
compounds for which the log Kow is greater than 3.5 be considered for further evaluation of
bioaccumulation potential. The bioaccumulation potential of inorganic compounds can be based
on calculated bioconcentration factors (BCF). Contaminants with BCFs greater than 1000 (log
30
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BCF>3) should be further evaluated for bioaccumulation potential. Appropriate application of
these values along with consideration of the factors above will assist in selecting COC for
bioaccumulation analysis by providing a general indication of the relative potential for various
chemicals to accumulate in tissues. Section 9.5.1 in both the Green Book and ITM provide
additional guidance on identifying organic and inorganic COC for bioaccumulation analyses and
should be consulted when conducting this evaluation.
Both wet weight and dry weight tissue concentrations should be determined and reported. Wet
weight tissue concentrations should be used in comparison to action level values or advisories
reported as wet weight concentrations, such as Food and Drug Administration (FDA) Action
Levels, or for use in risk modeling that makes assumptions of dose coming from consumption of
"fresh" material, not dried matter. Dry weight tissue concentrations should be used to
statistically evaluate bioaccumulation potential of COC detected in the tissues of organisms
exposed to sediment from the dredging site. This provides a more accurate assessment of
statistical significance by removing any variability in the data associated with moisture or water
contents in tissues, which can be influenced by how tissues were prepared in the laboratory or
other factors. Using dry weight data for statistical comparisons removes this variable. Statistical
procedures recommended for analyzing test data are described in detail in Section 13 of the
Green Book and Appendix D of the ITM however, the guidance provided in the ITM is more
technically advanced and should be used as reference for appropriate statistical methods.
Tissue concentrations of test organisms should be measured prior to exposure to the sediment
from the dredging site, reference sediment and control sediment. This will add perspective to the
magnitude of uptake during the exposure period, and in some cases may show elevated body
burdens were not due to exposure to dredged material or reference sediment but were already
present in the organisms at the start of the test. If tissue concentrations are not measured prior to
the initiation of the tests, some of the organisms must be archived (frozen). If test results are
suspect, then the archived organisms should be analyzed.
10.2.3 Bioaccumulation Evaluations. Concentrations of contaminants of concern in tissues of
benthic organisms exposed to the test sediments/dredged material are compared initially against
applicable FDA Action Levels when such levels have been set. These levels are based on human
health and economic considerations and do not include the potential for impact on the ecosystem.
FDA Action Levels are presented in table format in Appendix D of EPA's sediment quality
survey, The Incidence and Severity of Sediment Contamination in Surface Waters of the U.S.,
Volume I: National Sediment Quality Survey (EPA, 1997b), and subsequent updates. The
appendix can be accessed on-line at www.epa.gov/OST/cs/vol 17appdx_d.pdf
* If the concentrations of one or more contaminants of concern in tissues exposed to sediment
from the dredging site are statistically greater than the FDA levels, then the dredged material
does not meet the LPC for the solid phase and disposal of the dredged material without
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appropriate management is not supported. The USAGE, New Orleans District or Galveston
District and EPA, Region 6 shall then evaluate management actions outside the scope of this
RIA.
If the tissue concentrations of all COCs are not statistically greater than FDA levels or there
are no FDA levels for the COCs, then the concentrations of COCs in tissues exposed to
sediment from the dredging site are compared to the contaminant concentrations in the
tissues exposed to the reference sediment.
If the contaminant concentrations in tissues exposed to sediment from the dredging site do
not statistically exceed the contaminant concentrations in tissues exposed to the reference
sediment, the bioaccumulation LPC for the solid phase is met. No adverse effects are likely
if the concentration in the dredged material-exposed tissue is less than the reference material-
exposed tissue. The bioaccumulation analyses alone are not sufficient for determining
suitability of the dredged material for ocean disposal; evaluation of the water column impacts
and the toxicity of the solid phase must also be conducted. In addition, the analyses required
by other applicable provisions of the regulations including (40 CFR Part 227 Subparts B, C,
D, E, and G and section 228.4(e)) must be performed.
A statistically greater tissue residue in organisms exposed to sediment from the dredging site
than in organisms exposed to the reference sediment does not necessarily indicate increased
environmental hazard or human health risk. Conversely, the lack of statistically greater
tissue residues in sediment from the dredging site compared to reference sediment would be
strong evidence that the sediment from the dredging site would not result in increased
environmental hazard or human health risk for the pollutants tested. Therefore, the following
factors will be assessed to evaluate LPC compliance when the contaminant concentration in
tissues exposed to the sediment from the dredging site statistically exceeds the contaminant
concentrations in tissues exposed to the reference sediment. The factors and their order of
evaluation are as follows:
1. Statistical significance of the results from tests on sediment from the dredging
site when compared to reference sediment results.
2. Magnitude by which bioaccumulation in organisms exposed to sediment from
the dredging site exceeds bioaccumulation in organisms exposed to the reference
sediment.
3. Number of contaminants for which bioaccumulation in organisms exposed to
sediment from the dredging site is statistically greater than bioaccumulation in
organisms exposed to the reference sediment.
4. Number of species in which bioaccumulation in organisms exposed to
sediment from the dredging site is statistically greater than bioaccumulation in
organisms exposed to the reference sediment.
32
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5. Toxicological importance of the contaminants whose bioaccumulation in organisms
exposed to sediment from the dredging site statistically exceeds that from the reference
sediment.
6. Phylogenetic diversity of the species in which bioaccumulation in organisms
exposed to sediment from the dredging site statistically exceeds bioaccumulation
in organisms exposed to the reference sediment.
7. Propensity for the contaminants with statistically significant bioaccumulation
to biomagnify within aquatic food webs.
8. Magnitude of toxicity and number and phylogenetic diversity of species
exhibiting greater mortality in the sediment from the dredging site than in the
reference sediment.
If a compliance decision still cannot be reached, a sampling plan will be developed and agreed
upon by both the EPA and the USAGE to evaluate factor 9.
9. Magnitude by which contaminants whose bioaccumulation in organisms
exposed to sediment from the dredging site exceeds that of organisms exposed to
the reference sediment also exceed the concentrations found in comparable
species living in the vicinity of the proposed disposal site.
11. RISK-BASED EVALUATIVE TOOLS
In addition to the above analytical evaluations, risk-based evaluations may also be applied to
assess the potential ecological and human health effects of the tissue concentrations. Examples
of guidance documents, databases, and evaluative tools that may be used to aid EPA and the
USAGE in interpretation of bioaccumulation data are presented in this section.
The USAGE has developed guidance for conducting human health and ecological risk
assessments to evaluate the potential impacts associated with aquatic placement of dredged
material, Ecological and Human Health Risk Assessment Guidance for Aquatic Environments
(USAGE, 1999). The guidance includes an overview of ecological and human health risk
assessment and recommendations on proper application of risk assessment within the dredging
program. Sources of additional information on risk assessment applications, toxicity profiles,
and other tools used in risk assessment are provided. The report can be accessed at
www.wes.army.mil/el/dots.
EPA has developed a status and needs summary document that describes the existing knowledge
on the use of bioaccumulation data as part of sediment quality assessments, Bioaccumulation
Testing and Interpretation for the Purpose of Sediment Quality Assurance-Status and Needs
33
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(EPA, 2000). The document provides a summary of existing knowledge on bioaccumulation,
including a compilation of exposure and effects data for persistent, bioaccumulative chemicals;
factors that affect the bioavailability of sediment-associated sediments; and issues and research
needs for interpreting bioaccumulation data. The document contains appendix tables that
summarize information on chemical characteristics; human health concerns; wildlife and aquatic
organism partitioning factors; and food chain multipliers. The document can be accessed online
at www.epa.gov/OST.
Human Health Risk-Based Evaluations. Human health risk-based evaluations focus on
carcinogenic and non-carcinogenic risk to humans from potential exposure. For example, EPA
human health risk-based screening levels can be used to determine levels of contamination in
tissue that might result in a 10"5 cancer risk (1 x 10"5 or 1 in 100,000 incidence of cancer over a
70 year period) or noncancer hazard in humans. The contaminant concentrations in the tissue of
the organisms exposed to the test sediment/dredged material are compared with EPA fish tissue
screening levels which are available for numerous priority pollutants. The procedures for
estimating human health risks are based on EPA guidance document, Guidance for Assessing
Chemical Contaminant Data for use in Fish Advisories, Volume I, 2nd Edition, Fish Sampling
and Analysis (EPA, 1995b). These screening levels, along with FDA Action Levels, are
presented in table format in Appendix D of EPA's sediment quality survey, The Incidence and
Severity of Sediment Contamination in Surface Waters of the U.S., Volume I: National Sediment
Quality Survey (EPA, 1997b), and subsequent updates. The appendix can be accessed on-line at
www.epa.gov/OST/cs/vol 17appdx_d.pdf.
Ecological Risk-Based Evaluations. Ecological risk-based evaluations focus on potential risk to
non-human biota likely to occur at the disposal site. For example, an evaluation of potential
ecological effects of the bioaccumulation of PAHs can be made by direct comparison of total
PAH tissue residues with the Critical Body Residue (CBR) as described by McCarty, et al.
(1992) and Billion and Gibson (1992). The CBR is the value above which an adverse effect
would be expected and is represented as the ratio of the mass of the chemical/toxicant to the
mass of the organism (i.e. Omol/g). The acknowledged mode of toxicity for PAHs is narcosis,
e.g. lethargy, unconsciousness and death in extreme narcosis. According to McCarty et al.
(1992), CBRs of PAHs ranging from 2 to 8 Omol/g can produce acute narcotic response and
CBRs of PAHs ranging from 0.2 to 0.8 Omol/g can produce chronic narcotic response.
Environmental Residue Effects Database. The USAGE Engineer Research and Development
Center and EPA have developed a database, the Environmental Residue Effects Database
(ERED), that contains over 2000 records/references including information on more than 200
contaminants and 100 aquatic species. The database is a compilation of data, taken from the
literature, where biological effects (e.g., reduced survival, growth, etc.) and tissue contaminant
concentrations were simultaneously measured in the same organism. Currently, the database is
limited to those instances where biological effects observed in an organism are linked to a
specific contaminant within its tissues. The USAGE Engineer Research and Development
Center have published a Dredging Research Technical Note, EEDP-04-30, Interpreting
Bioaccumulation Data with the Environmental Residue-Effects Database (Bridges et al., 1999),
which provides information on the use of the ERED to interpret bioaccumulation data collected
during environmental assessment of dredged material. The Technical Note can be found online
34
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at www.wes.army.mil/el/dots/eedptn.html. The database can be found online at
www.wes.army.mil/el/ered.
Integrated Risk Information System (IRIS). EPA prepared and maintains the IRIS, an electronic
database containing information on human health effects that may result from exposure to
various chemicals in the environment. The database files on individual chemicals contain
descriptive and quantitative information. A basic discussion on risk assessment is included in
the introduction, www.epa.gov/ngispgm3/iris.
12. EMERGENCY PROCEDURES
In some instances, the USAGE, New Orleans District or Galveston District may deem it
necessary to utilize the existing 102(c) ODMDSs for emergency disposal of dredged materials
from other than the reach for which the ODMDSs are designated by invoking the emergency
procedures as provided in the USAGE Regulations at 33 CFR 337.7. In these cases, early and
timely coordination between the District and EPA Region 6 is essential. To better assist with the
coordination effort, the USAGE and EPA have developed the following procedures to address
emergency situations.
* The District shall notify EPA within 24 hours of the emergency and the proposed use of the
ODMDS.
* A complete Tier I evaluation of the activity shall be submitted to EPA as soon as possible.
The information included in the evaluation shall include a description of the emergency
project, any maintenance disposal activity at ODMDS at the time of the emergency (if
applicable), dredged material characterization/evaluation, and the remaining regulatory
evaluation of relevant subparts of 40 CFR 227.
* If no bioassay evaluations of the dredged material to be removed during the emergency event
and placed at the ODMDS have been done within the last 5 years according to the procedures
and protocols outlined in this RIA and the Green Book, then the dredged material shall be
sampled prior to removal and analyzed to determine potential environmental impacts. The
sampling plan shall be provided to EPA for review and comment prior to sampling.
* Adequate records shall be maintained and be provided to EPA of all disposal activities,
including precise location of disposal, volumes disposed, dates and number of trips.
* EPA and the USAGE will determine what actions are appropriate to address any concerns
raised by the dredging and disposal activity. This may include any remediation or mitigation
prompted by analysis of the dredged material test results, additional site specific monitoring
at the ODMDS, as well as any actions necessary to address concerns related to impacts of
future hurricanes and any other issues identified by EPA, the USAGE and/or the public.
* In order to ensure that all potential impacts as a result of the emergency disposal event at the
ODMDS have been adequately addressed in the NEPA documentation, EPA recommends
35
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that the ocean dumping evaluation as required by the regulations under 40 CFR 227 be
included as an appendix to the EA/EIS for emergency action.
36
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13. REFERENCES
ASTM. 1994a. Standard Guide for Conducting Static Acute Toxicity Tests with Fishes,
Macroinvertebrates, and Amphibians. Method E 729-88. In: Annual Book of ASTM
Standards, Water and Environmental Technology, Volume 11.04. American Society for
Testing and Materials, Philadelphia, PA.
ASTM. 1994b. Standard Guide for Conducting 10-day Static Sediment Toxicity Tests with
Marine andEstuarine Amphipods. Method E1367-92. In: Annual Book of ASTM
Standards, Water and Environmental Technology, Volume 11.04. American Society for
Testing and Materials, Philadelphia, PA.
ASTM. 1994c. Standard Guide for Designing Biological Tests with Sediments. Method E1525-
94. In: Annual Book of ASTM Standards, Water and Environmental Technology,
Volume 11.04. American Society for Testing and Materials, Philadelphia, PA.
ASTM. 1994d. Standard Guide for Conducting Sediment Toxicity Tests with Marine and
Estuarine Polychaetous Annelids. Method E1611-94. In: Annual Book of ASTM
Standards, Water and Environmental Technology, Volume 11.04. American Society for
Testing and Materials, Philadelphia, PA.
Bridges, T.S. and C.H. Lutz. 1999. Interpreting Bioaccumulation Data with the Environmental
Residue-Effects Database. Dredging Research Technical Note. EEDP-04-30, USACE
Engineer Research and Development Center, Vicksburg, MS.
Dillon, T.M. and A.Gibson. 1992. Critical Body Residue (CBR) approach for interpreting the
consequences of bioaccumulation of neutral organic contaminants. Environmental Effects
of Dredging Technical Notes. EEDP-04-17, USACE Waterways Experiment Station,
Vicksburg, MS.
EPA. 1987. Quality Assurance/Quality Control (QA/QC) for 301(h) Monitoring Programs:
Guidance on Field and Laboratory Methods. EPA 430/9-86-004. Prepared by Tetra Tech,
Inc., Bellevue WA, for the U.S. Environmental Protection Agency, Office of Marine and
Estuarine Protection. NTIS Number PB87-221164.
EPA. 1990. Specifications and Guidance for Obtaining Contaminant-Free Sampling Containers.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Directive #9240.0-05, April 1990.
EPA. 1991. Methods for Measuring Acute Toxicity of Effluents and Receiving Waters to
Freshwater and Marine Organisms, 4th ed. EPA/600/4-90/027.
EPA. 1992a. Sediment Classification Methods Compendium. EPA 823-R-92-006. U.S.
Environmental Protection Agency, Office of Water, Washington, DC.
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EPA. 1992c. Guidance Manual for the Review of Permitted and Civil Works Projects of
Permitted and Civil Works Projects for the Ocean Disposal of Dredged Material. EPA
842-B-92-007. U.S. Environmental Protection Agency, Office of Water, Washington,
DC.
EPA. 1993. Technical basis for deriving sediment quality criteria for nonionic organic
contaminants for the protection ofbenthic organisms by using equilibrium partitioning.
Draft EPA 822-R-93-011. U.S. Environmental Protection Agency, Office of Science and
Technology, Health Ecological Criteria Division, Washington, DC.
EPA. 1994. Methods for Measuring the Toxicity and Bioaccumulation of Sediment-Associated
Contaminants with Marine Invertebrates. EPA 600/R-94/025. U.S. Environmental
Protection Agency, Duluth, MN.
EPA. 1995a. Draft Method for Assessing the Toxicity of Sediment-Associated Contaminants with
the Bivalve, Mulinia Later alls. Office of Research and Development, Atlantic Ecology
Division. U.S. Environmental Protection Agency, Narragansett, RI. 125pp.
EPA. 1995b. Guidance for Assessing Chemical Contamination Data for Use in Fish Advisories,
Volume I: 2nd Edition: Fish Sampling and Analysis. EPA-823-R-95-007. U.S.
Environmental Protection Agency, Office of Science and Technology, Washington, DC.
EPA. 1996. Guidance for Data Quality Assessment - Practical Methods for Data Analysis, EPA
QA/G-9. EPA/600/R-96/084. U.S. Environmental Protection Agency, Office of Research
and Development, Washington, DC.
EPA. 1997a. EPA Guidance for Quality Assurance Project Plans, EPA QA/G-5. U.S.
Environmental Protection Agency, Office of Research and Development, Washington,
DC.
EPA. 1997b. The Incidence and Severity of Sediment Contamination in Surface Waters of the
United States, Volume I: National Sediment Quality Survey. EPA 823-R-97-006. U.S.
Environmental Protection Agency, Office of Science and Technology.
EPA. 1998. "National Recommended Water Quality Criteria; Republican"on". Federal Register
1998, Vol. 63, No. 237, 68354-68363. U.S. Environmental Protection Agency, Office of
Science and Technology.
EPA. 2000. Bioaccumulation Testing and Interpretation for the Purpose of Sediment Quality
Assurance-Status and Needs. EPA 823-R-00-001, Office of Water & Office of Solid
Waste, Washington, D.C.
EPA. 2001a. EPA Requirements for a QA Project Plan (QA/R-5). EPA/240/B-01/003, Office of
Environmental Information, Washington, D.C.
38
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EPA. 200 Ib. Methods for Assessing the Chronic Toxicity of Marine and Estuarine Sediment-
associated Contaminants with the AmphipodLeptocheirusplumulosus. EPA-823-F-01-
008, Office of Water, Washington, D.C.
EPA/US ACE. 1991. Evaluation of Dredged Material Proposed for Ocean Disposal - Testing
Manual. EPA-503/8-91/001, Washington, DC.
EPA/US ACE. 1992a. Ocean Dredged Material Disposal Program; Regional Implementation
Agreement for Testing and Reporting Requirements for Ocean Disposal of Dredged
Material off the Texas Coast Under Section 103 of the Marine Protection, Research and
Sanctuaries Act. U.S. Environmental Protection Agency, Region 6 and USAGE,
Galveston District.
EPA/US ACE. 1992b. Ocean Dredged Material Disposal Program; Regional Implementation
Agreement for Testing and Reporting Requirements for Ocean Disposal of Dredged
Material off the Louisiana Coast Under Section 103 of the Marine Protection, Research
and Sanctuaries Act. U.S. Environmental Protection Agency, Region 6 and USAGE, New
Orleans District.
EPA/US ACE. 1992c. Evaluating Environmental Effects of Dredged Material Management
Alternatives-A Technical Framework. EPA 842-B-92-008, Washington, D.C.
EPA/USAGE. 1995. QA/QC Guidance for Sampling and Analysis of Sediments, Water, and
Tissues for Dredged Material Evaluations. Phase I - Chemical Evaluations. EPA-823-B-
95-001. Office of Water, Washington, DC.
EPA/USAGE. 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the
U.S. - Testing Manual. EPA-823-B-98-004, Washington, DC.
Lee, H. Ill, B.L. Boese, J. Pelletier, M. Winsor, D.T. Sprecht, and R.C. Randall. 1989. Guidance
Manual: Bedded Bioaccumulation Tests. ERL-N Contribution No. Nl 11, EPA 600/X-
89/302. Newport, OR.
Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder. 1995. Incidence of adverse
biological effects within ranges of chemical concentrations in marine and estuarine
sediments. Enviro. Man. 19(l):81-97.
Long, E.R., and L.G. Morgan. 1990. The potential for biological effects of sediment-sorbed
contaminants tested in the National Status and Trends Program. NOAA tech. mem. NOS
OMA 52. National Oceanic and Atmospheric Administration, Seattle, WA.
McCarty, L.S., D.Mackay, A.D.Smith, G.W.Ozburn andD.G.Dixon. 1992. Residue-based
interpretation of toxicity and bioconcentration QASRs from aquatic bioassays: neutral
narcotic organics. Environ. Tox. Chem., 11:917-930.
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NOAA. 1989. Standard Analytical Procedure of the NOAA National Analytical Facility. 2nd ed.,
NOAA Technical Memoranda NMFS F/NWC-92, 1986-89. NOAA National Status and
Trends Program, NOAAN/OMA32, Rockville, MD.
Plumb, R.H., Jr. 1981. Procedures for handling and chemical analysis of sediment and water
samples. Tech. Rept. EPA/CE-81-1 prepared by Great Lakes Laboratory, State University
College at Buffalo, Buffalo, NY, for the U.S. Environmental Protection Agency/U.S.
Army USAGE of Engineers Technical Committee on Criteria for Dredged and Fill
Material. Published by the U.S. Army Engineer Waterways Experiment Station,
Vicksburg, MS.
Tetra Tech. 1986a. Analytical methods for U.S. EPA priority pollutants and 301(h) pesticides in
estuarine and marine sediments. Final Report prepared by Tetra Tech, Inc., for U.S.
Environmental Protection Agency under Contract No.69-01-6938.
Tetra Tech. 1986b. Bioaccumulation monitoring guidance: 4. Analytical methods for U.S. EPA
priority pollutants and 301(h) pesticides in tissues from estuarine and marine organisms.
Final Report prepared by Tetra Tech, Inc., for U.S. Environmental Protection Agency
under Contract No. 68-01-6938.
USAGE. 1999. Ecological and Human Health Risk Assessment Guidance for Aquatic
Environments. Technical Report DOER-4, Dredging Operations and Environmental
Research Program.
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APPENDIX A
REQUIRED INFORMATION & DOCUMENTATION
FOR
EVALUATION OF DREDGED MATERIAL PROPOSED FOR OCEAN DISPOSAL
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REQUIRED INFORMATION & DOCUMENTATION FOR
EVALUATION OF DREDGED MATERIAL PROPOSED FOR OCEAN DISPOSAL
The following information is required for the USAGE and EPA to evaluate dredged materials
proposed for ocean disposal.
A. Dredging project information,
B. Characterization of material from dredging site, and
C. Regulatory compliance evaluation
A. Dredging project information
The proposed dredging project will be described to include:
• large scale map showing the location of the project
• the project plan drawing, design depth, and advance maintenance and allowable over-
depth
• estimated extent of shoaling
• interruption or changes in standard operations resulting from shoaling
• the anticipated type of dredging and disposal vessel
• anticipated start date and duration of the disposal operation
• estimated volume and area to be dredged
• estimated disposal quantities
• work details as described in the specifications of the dredging contract
• a short description of the last dredging performed (e.g. maintenance projects),
including location of placement of material at the ODMDS
B. Characterization of material from dredging site
Existing Information, Tier I (Section 4.2). At a minimum, a Tier I evaluation shall be
conducted for every proposed dredging operation. If regulatory compliance can be established
using existing information, an assessment of the existing information shall accompany the
compliance decision. For existing data, quality assurance/quality control information should be
verifiable.
If using historical information, it may not be necessary to resubmit the test results that have been
previously submitted to EPA. However, the following information should be provided and
referenced: the date of the original submittal letter, title of the report, name of the consultant,
date of the report and types of analyses performed (i.e. chemical, toxicity, bioaccumulation).
Other sources of data/information should be referenced and/or included with the Tier I
evaluation, including any spill reports, sediment quality databases, research reports, point-source
Al
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discharge permit records, etc. (see Section 4.0 of the Green Book for a detailed listing of other
sources of information).
Exclusionary Criteria, Tier I (Section 4.3). Information on the proposed dredging site,
including sediment grain size, sediment chemistry and potential for contamination may be
needed in determining exclusion from further testing.
• For this RIA, the term "predominantly sand", in 40 CFR 227.13(b)(l) and (b)(2), will be
determined on a case-by-case basis by best professional judgment of both the USAGE, New
Orleans District and Galveston District and EPA, Region 6.
• The phrase "material proposed for dumping is substantially the same as the substrate at the
proposed disposal site", in 40 CFR 227.13(b)(3)(i), is interpreted to mean the comparison of
both physical and chemical characteristics of the proposed dredged material to the disposal
site (i.e. "like on like").
• Information used in determining "areas of high current or wave energy" in 40 CFR
227.13(b)(l) may include area hydrology and available physical oceanographic data.
• Information used in determining "far removed from known existing and historical sources of
pollution" in 40 CFR 227.13(b)(3)(ii) may include area hydrology, location of dredging site
and proximity to sources of pollutants, quantities and types of pollutants discharged upstream
of the proposed dredging area, and existing chemical and physical data on the dredged
material.
If one or more of the exclusionary criteria can be satisfied using existing information, a
conclusive written evaluation must be presented to show that the proposed dredged material
meets the exclusionary criteria. An assessment of the existing information shall accompany the
compliance decision. For existing data, quality assurance/quality control information should be
verifiable.
If using historical information, it may not be necessary to resubmit the test results that have been
previously submitted to EPA. However, the following information should be provided and
referenced: the date of the original submittal letter, title of the report, name of the consultant,
date of the report and types of analyses performed (i.e. chemical, toxicity, bioaccumulation).
New Data (Section 4.5). It may be necessary to collect new sediment samples and conduct
appropriate analyses to determine compliance with the ocean dumping regulations. The
following information shall be provided with submittal of new data:
1) A copy of the site-specific sampling and analysis plan (SAP) as discussed in
Sections of this RIA.
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2) A description of the sampling survey, including the following: dates, sampling
devices used, compositing procedure, and the location of the sediment sampling stations
for each dredging area and reference site station by a) latitude and longitude determined
by Global Positioning System, and b) in general terms (e.g. by channel marker, buoy
number or significant landmarks).
3) Copies of the test results conducted according to the site-specific sampling plan in
a standard electronic format and/or report/hard-copy format. These test results include
data for all tests at all tiers (physical, chemical, and/or biological), and the laboratory(s)
performing the tests. Appendix H of QA/QC Guidance for Sampling and Analysis of
Sediments, Water, an d Tissues for Dredged Material Evaluations (EPA/US ACE, 1995)
contains a sediment testing report.
C. Regulatory compliance evaluation
The applicable subparts and sections of 40 CFR listed below must be evaluated to determine if
the proposed dredged material is suitable for ocean disposal. A written discussion must address
all the following:
1) Part 227 Subpart B - Environmental Impact
a. 227.1 Applicability
b. 227.4 Criteria for evaluating environmental impact
c. 227.5 Prohibited materials
d. 227.6 Constituents prohibited as other than trace contaminants
e. 227.9 Limitations on quantities of waste materials
f. 227.10 Hazards to fishing, navigation, shorelines or beaches
g. 227.13 Dredged materials
2) Part 227 Subpart C - Need for Ocean Dumping (all sections)
3) Part 227 Subpart D - Impact of the Proposed Dumping on Aesthetic, Recreational
and Economic Values (all sections)
4) Part 227 Subpart E - Impact of the Proposed Dumping on Other Uses of the
Ocean (all sections)
5) Part 227 Subpart G - Definitions (all sections)
6) Part 228
Section 228.4(e) - Dredged Material Permits
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APPENDIX B
SAMPLE COLLECTION, PRESERVATION AND STORAGE
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SUMMARY OF RECOMMENDED PROCEDURES FOR SAMPLE COLLECTION, PRESERVATION, AND
STORAGE51
Analyses
Collection
Methodb
Amount
Required0
Container"1
Preservation Technique
Storage
Conditions
Holding Times6
SEDIMENT
Chemical/Physical Analyses
Metals
Organic Compounds (e.g.,
PCBs, pesticides, poly cyclic
aromatic hydrocarbons
Particle Size
Total Organic Carbon
(TOC)
Total solids/specific gravity
Miscellaneous
Sediment from which
elutriate is prepared
Grab/corer
Grab/corer
Grab/corer
Grab/corer
Grab/corer
Grab/corer
Grab/corer
100 g
250 g
lOOg
50 g
50 g
350g
Depends
on tests
being
performed
Precleaned
polyethylene] a/
Solvent-rinsed
glass jar with
Teflon lidf
Whirl-pac bagf
Heat treated
glass vial with
Teflon-lined lidf
Whirl-pac bag
Whirl-pac bag
Glass with
Teflon-lined lid
Dry icef or freezer storage for
extended storages; otherwise
refrigerate
Dry icef or freezer storage for
extended storages; otherwise
refrigerate
Refrigerate
Dry icef or freezer storage for
extended storages; otherwise
refrigerate
Refrigerate
Refrigerate
Completely fill and
refrigerate
#4°C
#4°Cf/darkg
<4°C
#4°Cf
<4°C
<4°C
40C/dark/airtight
Hg - 28 days Others -
6 months8
14 days'1
Undetermined
14 days
Undetermined
Underermined
14 days
Bl
-------
Biological Tests
Dredged material
Reference sediment
Control sediment
Grab/corer
Grab/corer
Grab/corer
12-15 L
per sample
45-50 L
per test
21-25 L
per test
Plastic bag or
container1
Plastic bag or
container1
Plastic bag or
container1
Completely fill and
refrigerate; sieve
Completely fill and
refrigerate; sieve
Completely fill and
refrigerate; sieve
40C/dark/airtight
40C/dark/airtight
40C/dark/airtight
14 daysj
14 daysj
14 daysj
WATER AND ELUTRIATE
Chemical/Physical Analyses
Paniculate analysis
Metals
Total Kjeldahl nitrogen
(TKN)
Chemical oxygen demand
(COD)
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
500- 2000
mL
1L
100 - 200
mL
200 mL
Plastic or glass
Acid-rinsed
polyethylene or
glass jar1'
Plastic or glass1
Plastic or glass1
Lugols solution and
refrigerate
pH<2withHNO3k;
refrigerate
H2SO4 to pH <2; refrigerate
H2SO4 to pH <2; refrigerate
4°C
4°C 2°Ck
4°C'
4°C'
Undetermined
Hg - 14 days Others -
6 months1
24 h1
7 days1
B2
-------
Total organic carbon (TOC)
Total inorganic carbon
(TIC)
Phenolic compounds
Soluble reactive phosphates
Extractable organic
compounds (e.g.,
semivolatiles)
Volatile organic compounds
Total phosphorus
Total solids
Sulfides
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
Discrete
sampler or
pump
100 mL
100 mL
1L
.
4L
80 mL
.
200 mL
.
Plastic or glass1
Plastic or glass1
Glass1
Plastic or glass1
Amber glass
bottlek
Glass vialk
Plastic or glass1
Plastic or glass1
Plastic or glass1
H2SO4 to pH <2; refrigerate
Airtight seal; refrigerate11
0.1-1.0gCuSO4;H2SO4to
pH <2; refrigerate
Filter; refrigerate11
pH <2, 6N HCL; airtight
seal; refrigerate
pH<2 with 1:1 HCL;
refrigerate in airtight,
completely filled container1'
H2SO4 to pH <2; refrigerate
Refrigerate
pH >9 NaOH (ZnAc);
refrigerate
4°C'
4°C'
4°C'
4°C'
4°Ck
4°Ck
4°C'
4°C'
4°C'
<48h'
6 months1
24 h1
24 h1
7 days for extraction;
40 days for extract
analysisk
14 days for sample
analysis if preserved111
7 days1
7 days1
24 h1
B3
-------
Volatile solids
Discrete
sampler or
pump
200 mL
Plastic or glass1
Refrigerate
4°C'
7 days1
Biological Tests
Site water
Dilution water
Grab
Grab or
makeup
Depends
on tests
being
performed
Depends
on tests
being
performed
Plastic carboy
Plastic carboy
Refrigerate
Refrigerate
<4°C
<4°C
14 days
14 days
TISSUE
Metals
PCBs and chlorinated
pesticides
Volatile organic compounds
Trawl/Teflon-
coated grab
Trawl/Teflon-
coated grab
Trawl/Teflon-
coated grab
5-10g
10-25g
10-25g
Double Ziplocf
Hexane-rinsed
double
aluminum foil
and double
Ziplocf
Heat-cleaned
aluminum foil
and watertight
plastic bag111
Handle with nonmetallic
forceps; plastic gloves; dry
icef
Handle with hexane-rinsed
stainless steel forceps; dry
icef
Covered ice chest8
#-20°Cfor
freezer storage
#-20°Cfor
freezer storage
#-20°Ch or
freezer storage
Hg - 28 days; Others -
6 months"
14 days'1
14 days"
B4
-------
Semivolatile organic
compounds (e.g., PAH)
Lipids
Trawl/Teflon
-coated grab
Trawl/Teflon
-coated grab
10-25g
part of
organic
analyses
Hexane-rinsed
double
aluminum foil
and double
Ziplocf
Hexane-rinsed
aluminum foil
Handle with hexane-rinsed
stainless steel forceps; dry
icef
Handle with hexane-rinsed
stainless steel forceps; quick
freeze
#-20°Cfor
freezer storage
#-20°C or
freezer storage
14 days'1
14 days'1
This table contains only a summary of collection, preservation, and storage procedures for samples. The cited references should be
consulted for a more detailed description of these procedures. It was taken directly from the Inland Testing Manual, EPA-823-B-98-004.
Collection method should include appropriate liners
Amount of sample required by the laboratory to perform the analysis (wet weight or volume provided, as appropriate). Miscellaneous
sample size for sediment should be increased if auxiliary analytes that cannot be included as part of the organic or metal analyses are added
to the list. The amounts shown are not intended as firm values; more or less tissue may be required depending on the analytes, matrices,
detection limits, and particular analytical laboratory.
All containers should be certified as clean according to EPA (1990)
These holding times are for sediment, water, and tissue based on guidance that is sometimes administrative rather than technical in nature.
There are no promulgated, scientifically based holding time criteria for sediments, tissues, or elutriates. References should be consulted if
holding times for sample extracts are desired. Holding times are from the time of sample collection.
NOAA (1989)
TetraTech(1986a)
Sample may be held for up to one year if at -20°C.
Polypropylene should be used if phthalate bioaccumulation is of concern.
Two weeks is recommended; sediments must not be held for longer than 8 weeks prior to biological testing.
EPA (1987); 40 CFR Part 136, Table III
Plumb (1981)
If samples are not preserved to pH<2, then aromatic compounds must be analyzed within 7 days.
TetraTech(1986b)
B5
-------
APPENDIX C
TARGET DETECTION LIMITS
FOR ANALYSIS OF
SEDIMENT, TISSUE AND WATER
-------
Target Detection Limits" (TDLs) for analysis of sediment, tissue and water
These values equate to Minimum Quantification Levels (MQLs). TDLs utilized in the analysis of samples should be
adequate to satisfy the Data Quality Objectives (DQOs), to the extent practicable. Alternate TDLs may be proposed
as long as DQOs are satisfied (e.g., for use in assessing water quality criteria or screening levels). Proposed TDLs
should be contained in the sampling and analysis plan (SAP) for each project. Sediment values are reported as dry
weight. Tissue values are reported as wet weight. Highlighted parameters are contaminants of concern and
conventional parameters listed in Table 2.
Chemical
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (3+)
Chromium (6+)
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Zinc
Organotin
Conventional/ Ancillary
Parameters
Ammonia
Cyanides
Total Organic Carbon
Total Petroleum Hydrocarbons
Tot. Recov. Petr. Hydrocarbons
Total Phenols
Acid Volatile Sulfides
Total Sulfides
Grain Size
Sediment
ms/ks
10b
2.5
0.3b
2b
lb
0.1
lb
1
1
0.1
lb
20b
0.3b
lb
0.2
0.5b
0.5b
0.2
0.2
0.5
2b
0.01
mg/kg
0.1
2
0.1%
5
5
1
0. 1 ^/mole/g
0.1
1%
Tissue
ms/ks
1
0.1
0.1
lb
0.1
0.1
0.05b
50
50
0.1
0.1
10
0.1
0.5
0.01
0.1
0.2
0.1
0.1
0.1
O.lb
0.01
mg/kg
-
1
-
50'
-
10
-
-
-
Water
//s/1
40
3 (0.02)c
1 (0.005)
10b
0.2
1 (0.01)
1
1
1
4
1 (0.1)
10
1 (0.02)
1
0.2 (0.0002)
1 (0.1)
2
1 (0.1)
1 (0.02)
5
1 (0.5)
0.01
mg/1
0.03
0.1"
0.1%
0.1
0.5
0.05
-
0.1
-
Cl
-------
Chemical
Conventional/ Ancillary
Parameters, Continued
Total Suspended Solids
Total Settleable Solids
Total Solids/Dry Weight
Total Volatile Solids
Specific Gravity
pH
Total Moisture Content
Total Lipid
Oil and Grease
LPAH Compounds
Napthalene
Acenapthylene
Acenapthene
Fluorene
Phenanthrene
Anthracene
Methylnapthalene
2-Methylnapthalene
HP AH Compounds
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b&k)fluoranthene
Benzo(a)pyrene
Ideno[l,2,3-c,d]pyrene
Dibenzo [a,h] anthracene
Benzo [g,h,i]perylene
Orsanonitrosen Compounds
Benzidine
3 , 3 -Dichlorobenzidine
2,4-Dinitrotoluene
2,6-Dinitrotoluene
1 ,2-Diphenylhydrazine
Nitrobenzene
N-Nitrosodimethyl amine
N-Nitrosodi-n-propylamine
N-Nitrosodiphenylamine
Sediment
mg/kg
0.1
-
0.1%
0.1
0.01
0.1 SU
0.1%
-
20'
//g/kg
20
20
20
20
20
20
20
20
//g/kg
20
20
20
20
20
20
20
20
20
//g/kg
5
300b
200b
200b
10
160b
-
150b
20
Tissue
mg/kg
-
-
-
-
-
-
0.1%
0.1%g
20'
//g/kg
20
20
20
20
20
20
20
20
//g/kg
20
20
20
20
20
20
20
20
20
//g/kg
5
-
-
-
100
-
-
-
20
Water
mg/1
1
0.05
-
-
-
-
-
-
2'
HQ]\
0.8b
1.0"
0.75b
0.6b
0.5b
0.6b
10
0.9b
HQ]\
0.9b
1.5"
0.4b
0.3b
0.6b
0.3b
1.2b
1.3"
1.2b
HQ]\
I
1*°
5
2b
2b
1
0.9b
3.1b
0.9b
2.1b
C2
-------
Chemical
Phthalate Esters
Dimethyl Phthalate
Diethyl Phthalate
Di-n-butyl Phthalate
Butyl Benzyl Phthalate
Bis[2-ethylhexyl] Phthalate
Di-n-octyl Phthalate
Phenols/Substituted Phenols
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
Pentachlorophenol
2,4,6-Trichlorophenol
4-Chloro-3 -methylphenol
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
4,6-Dinitrophenol
2-Chlorophenol
2,4-Dichlorophenol
4,6-Dinitro-o-cresol
Polychlorinated Dibenzo-p-
dioxins
2,3,7,8-TCDD
Other Tetrachlorinated Dioxins
Pentachlorinated Dioxins
Hexachlorinated Dioxins
Heptachlorinated Dioxins
Octachlorinated Dioxins
Polvchlorinated Dibenzofurans
Tetrachlorinated Furans
Pentachlorinated Furans
Hexachlorinated Furans
Hepatachlorinated Furans
Octachlorinated Furans
Dibenzo Furan
Polvchlorinated Biphenvls
PCB Congeners & Aroclors
Total PCB
Sediment
//g/kg
50
50
50
50
50
50
//g/kg
100
50
100
20
100
140b
140b
200b
500b
500b
500b
110b
120b
600
//g/kg
0.001
0.001
0.0025
0.005
0.005
0.01
//g/kg
0.001
0.0025
0.005
0.005
0.01
50
//g/kg
1
1
Tissue
//g/kg
20
20
20
20
20
20
//g/kg
20
20
20
20
100
-
-
-
-
-
-
-
-
20
//g/kg
0.001
0.001
0.0025
0.005
0.005
0.01
//g/kg
0.001
0.0025
0.005
0.005
0.01
20
//g/kg
2
2
Water
//g/1
lb
lb
lb
4b
2b
ob
J
HQ]\
10
10
10
10
50
0.9b
0.7b
2b
5b
5b
5b
0.9b
0.8b
10
HQ]\
0.00001
0.00001
0.000025
0.00005
0.00005
0.0001
//g/1
0.00001
0.000025
0.00005
0.00005
0.0001
0.7b
//g/1
0.01
0.01
C3
-------
Chemical
Pesticides
Aldrin
Chlordane and Derivatives
Dieldrin
4,4'-DDD
4,4'-DDE
4,4'-DDT
Endosulfan and Derivatives
Endrin and Derivatives
Heptachlor and Derivatives
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Toxaphene
Methoxychlor
Chlorbenside
Dacthal
Total Chlorinated Pesticides
Malathion
Parathion
Chlorinated Hydrocarbons
1 , 3 -Dichlorobenzene
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobenzene
Hexachlorobenzene
2-Chloronapthalene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorobutadiene
Volatile Organic Compounds
Benzene
Chloroform
Ethylbenzene
Toluene
Trichloroethene
Tetrachloroethene
Total Xylenes
Halosenated Ethers
Bis(2-chloroethyl)ether
4-chlorophenyl phenyl ether
4-Bromophenyl phenyl ether
Sediment
//g/kg
3b
ob
J
5b
5b
5b
5b
5b
5b
3b
ob
J
3b
ob
J
3b
50
5b
2
2
20
5
6
//g/kg
20
20
20
10
10
160b
300b
100
20
//g/kg
10
10
10
10
10
10
10
//g/kg
130b
170b
160b
Tissue
//g/kg
6b
6b
10
10
10
10
10
10
6b
6b
6b
6b
6b
50
10
2
2
20
5
6
//g/kg
20
20
20
20
20
-
-
40
40
//g/kg
10
10
10
10
10
10
10
//g/kg
-
-
-
Water
//g/1
0.03b
0.03b
0.02
0.1
0.1
0.1
0.1
0.1
0.1
0.03
0.03
0.03
0.1
0.5
0.5
0.002
0.03
0.02
0.8
0.8
//g/1
0.9b
lb
0.8b
0.9b
0.4b
0.8b
3.0b
0.9b
0.9b
HQ]\
2b
2b
5
5
2b
2b
5
//g/1
0.9b
0.6b
0.4b
C4
-------
Chemical
Halosenated Ethers, Continued
Bis(2-chloroisopropyl)ether
Bis(2-Chloroethoxy)methane
Miscellaneous
Isophorone
Benzyl Alcohol
Benzoic Acid
Methyl Ethyl Keytone
Resin Acids and Guaiacols
Sediment
//g/kg
140b
130b
//g/kg
10
50
100
20
10
Tissue
//g/kg
-
-
//g/kg
100
100
100
20
-
Water
/JK/1
0.7b
lb
/LIZ/l
1
1.5"
2.0b
50
-
aThe primary source of these TDLs was EPA 823-B-95-001, QA/QC Guidance for Sampling and Analysis of
Sediments, Water and Tissues for Dredged Material Evaluations.
bThese values are based on recommendations from the EPA Region 6 Laboratory in Houston; these values were
based on data or other technical basis.
°The values in parentheses are based on EPA "clean techniques", (EPA 1600 series methods) which are applicable in
instances where other TDLs are inadequate to assess EPA water quality criteria.
dThese values contained in Region 6 "Development of Minimum Quantification Levels" prepared by the EPA
Region 6 Permits Branch.
eThis value recommended by Houston Lab using colorimetric method.
fThis value recommended by Houston Lab using method 1664.
gLee et. al, 1989.
C5
-------
APPENDIX D
ODMDS AND REFERENCE AREA LOCATIONS
-------
LOUISIANA
Reference Sample locations determined using Area Approach
Mississippi River - Gulf Outlet ODMDS
Mississippi River - Southwest Pass ODMDS
Barataria Bay Waterway ODMDS
Atchafalaya Bar Channel ODMDS
Calcasieu River & Pass ODMDS
Houma Navigation Canal (Cat Island Pass)
ODMDS
29°22'00"N, 88°56'30"W
29°23'00"N, 88°54'30"W
29°24'30"N, 88°52'30"W
28°53'58"N, 89°25'31"W
28°53'45"N, 89°25'09"W
28°53'13"N, 89°25'28"W
28°53'11"N, 89°24'49"W
29°13'30"N, 89°53'30"W
29°13'54"N, 89°53'48"W
29°14'21"N, 89°54'06"W
29°07'00"N, 91°31'30"W
29°08'00"N, 91°29'00"W
29°09'00"N, 91°27'00"W
29°30'00"N, 93°10'18"W
29°30'51"N, 93°10'00"W
29°30'00"N, 93°09'27"W
28°58'09"N, 90°29'30"W
28°58'57"N, 90°31'30"W
28°57'57"N, 90°31'54"W
-------
1 .-•:••.} I .
'. •/.;•.•.•-•.'•••.•>'.>».
OUI SI AN A- '-.'iili
—29°28'
-29°26'
-29°24'
2 Miles
Mississippi River Gulf Outlet ODMDSX
^^^••a
^^^™^^^^ , ]
1 1 (
024 Kilometers
89°12' 89°10' 89°08'
I 1 1 1
89°06' 89°04'
1 1
89°02
I
89°00'
-------
.11 '
:•:•:,X. MISSISSIPPJ •'•;
•;.-,v.-/V . ....,•.'.i_r.tvi,i-:-oJ
29°58'—
28°56'-
28°54-
Southwest Pass - Mississippi River ODMDS
0 0.5 INauticalMile
28°52'-
89°28'
I
89°26'
I
89°24'
I
1 2 Kilometers
89°22'
-------
nBay+ **& Quatre
Dispute ^3323 -.
•«*» Ipr Bayou
v>?s^?>*. $fr^ Pass
• • ••>• *fu~* - .*>*
endican
Island
Beauregard
Island
0.5 1 Nautical Mile
Panama
Pt.
1 2 Kilometers
Barataria Bay Waterway ODMDS/
Area
Shown
-------
:••••• . LOUISIANA
Area
Shown
Atchafalaya River Bar Channel
POINT AU PER ISLAND: -.-:•,
Interim-Designated ODMDS
1 2 3 Statute Miles
I
24fi Kilometers
-------
Calcasieu River
and Pass ODMDS
Gulf
of
Mexico
3 Miles
6 Kilometers
95°
TEXAS
I J
94° ')
I
93°
•30C
HOUSTON ivj
•
\ LOUISIANA
ICAUMOHT-.J .-.-•..;..,
• t''-'ir^f-:-''<-&.'-''- '
s«^orte
Shown
Calcasieu River and
Pass ODMDS *1
93°34' 93°32' 93°30' 93°28'
Calcasieu River
Pass ODMDS *3 -^
29°48'-
.-Monkey Island. - -
' • • ' ••••••
29°44'-
29°42'-
93°26'
I
93°24'
I
93°20'i
29°40'-
29°38'-
29°36'-
29°34'-
29°32'-
29°30'-
93°18'
1
-------
Pt. Mast
Bay
3 Miles
6 Kilometers
29°12'-
29°10'-
29^8-
I
29°06'-
29°04 —
Houma Navigation Channel ODMDS
90°40' 90°38'
90°36'
90°34'
90°32'
90°30'
-------
TEXAS
Reference Area boundary locations - Reference Sample collected within area
Sabine-Neches Waterway ODMDS No. 1 & 2
Sabine-Neches Waterway ODMDS No. 3 & 4
Galveston Harbor & Channel ODMDS
Freeport Harbor ODMDS
Matagorda Ship Channel ODMDS
Corpus Christ! Ship Channel ODMDS
Port Mansfield ODMDS
Brazos Island Harbor ODMDS
29°27'30"N, 93°37'00"W
29°27'30"N, 93°36'45"W
29°26'38"N, 93°36'45"W
29°26'38"N, 93°37'00"W
29°35'52"N, 93°41'45"W
29°35'52"N, 93°41'30"W
29°35'00"N, 93°41'30"W
29°35'00"N, 93°41'45"W
29°20'22"N, 94°37'11"W
29°19'32"N, 94°36'56"W
29°19'23"N, 94°37'06"W
29°20'13"N, 94°37'21"W
28°54'28"N, 95°13'40"W
28°54'35"N, 95°13'28"W
28°55'07"N, 95°14'01"W
28°54'60"N, 95°14'13"W
28°24'27"N, 96°16'04"W
28°24'33"N, 96°15'52"W
28°25'10"N, 96°16'30"W
28°25'04"N, 96°16'42"W
27°50'10"N, 96°59'17"W
27°50'20"N, 96°59'09"W
27°50'48"N, 96°59'57"W
27°50'38"N, 97°00'05"W
26°32'11"N, 97°13'44"W
26°31'58"N, 97°13'44"W
26°31'58"N, 97°14'42"W
26°32'11"N, 97°14'42"W
26°02'18"N, 96°06'30"W
26°02'18"N, 97°07'26"W
26°02'05"N, 97°07'26"W
26°02'05"N, 96°06'30"W
-------
Sabine-Neches
ODMDS
Sabine-Neches
ODMDS
Sabine-Neches
ODMDS
TEXAS BEAUMONT_..J .>.•:..;...
Sabine-Neches ODMDS
-29"32'
-29°30'
-29°28'
-29V26'
93°54' 93°52'
I t
93°50'
I
93°48'
93°46'
I
93°44'
I
-------
Bolivar •.." •.:?•?Ł
Peninsula •• -•Ł••Ł"
—29°18'
Gulf
of
Mexico
Galveston Harbor
and Channel ODMDS
-29°16'
0.5 1 Nautical Mile
0 1 2 Kilometers
B4°44' 94°42'
96°
-30'
95° 94°
flCAUMONT- >
HOUSTOH:f/:^.^:.•/:,-^y
-2a° r.-::*;:f$jjLf AREA
SHOWN
94°40
I
-------
Freeport Harbor ODMDS
(45-Foot Project)
0.5 1 Nautical Mile
1 2 Kilometers
Freeport Harbor ODMDS
(45 Foot Project)
28°54-
28°52'—
28°50-
95°20'
95°18'
95°16'
-------
Matagorda Ship Channel ODMDS
-28°22'
-29°
97° 96C
TEXAS
'
-28°20'
0.5 1 Nautical Mile
2 Kilometers
98°20'
98j>18'
S6°18'
I
-------
San Jose
Island
•.••
^;.-:;.;.y Corpus Christi Ship Channel ODMDS
0.5 1 Nautical Mile
2 Kilometers
97°04'
I
97°00'
Gulf
of
Mexico
27°50-
27°48—
-29'
97°
-28(
-27'
I.VK I i
27°46-
96°58'
I
96°56'
i
-------
Laguna
Madre
-28°.
96°
Area
Shown
26°38'-
26°36'-
Gulf
Of
Mexico
Port Mansfield ODMDS
26°34' —
0.5 1 Nautical Mile
1 2 K ilome ters
97°14'
I
97°12'
I
-------
Brazos Island Harbor ODMDS
\
-------
APPENDIX E
EPA EVALUATOR WORKSHEETS
FOR
TESTING AND EVALUATION OF DREDGED MATERIAL
PROPOSED FOR OCEAN DISPOSAL
-------
Table 1
EPA Evaluator Worksheet for Tier I Data_
Data for Compliance with the Exclusionary Criteria in
40 CFR 227.13(b)
la. Proposed dredged material is composed
predominantly of sand, gravel, rock or any other
naturally occurring bottom material with particle
sizes larger than silt (using results of grain-size
analyses); and
Ib. Proposed dredged material is found in high current or
wave energy areas.
2a. Proposed dredged material is for beach nourishment
or restoration; and
2b. Proposed dredged material is composed
predominantly of sand, gravel or shell with particle
sizes compatible with material on the receiving beach
(using statistical comparison of grain size at dredging
site vs. disposal site).
Yes
Data Acceptable
No N/A Need
More
G
G
G G G
G G G
G G G
Comments
3a.
3b.
4.
5.
The proposed material is substantially the same as the
substrate at the proposed disposal site (using
statistical comparison of grain size at dredging site
vs. disposal site); and
The site the material is taken from is far removed
from known existing and historical sources of
pollution.
Adequacy of disposal-site sediment and/or water
sampling (as concluded from Table 6).
QA verification of analytical procedures and results
(as concluded from Table 7).
G G G G
G G G G
G G G G
G G G G
N/A: not applicable
El
-------
Table 1
EPA Evaluator Worksheet for Tier I Data (continued)
Data for LPC Determinations
6. Definition of the area to be dredged (maps, coordinates, depth
of cut, side slopes, over-depth dredge, etc.).
7. Physical and chemical characterization of the proposed
dredged material, including contaminants of concern and their
project locations.
8. Procedures and results of prior physical, chemical, and
bioassay tests of the dredged material or of tests on sediments
from the vicinity of the proposed dredging area.
- Adequacy of dredging-site sediment sampling
(as concluded from Table 6).
9. Procedures and results of monitoring studies of material
similar to the proposed dredged material.
- Adequacy of disposal-site sediment and/or
water sampling (as concluded from Table 6).
10. Data on the source of the dredged material (e.g., origin and
history of the sediment) and known or suspected contaminant
sources to the dredged material.
11. Other existing data that are pertinent to the proposed dredged
material.
12. Confirmatory analysis (physical, chemical, and biological
evaluations ~ refer to 1991 Green Book).
13. QA verification of analytical procedures and results, including
statistical analyses, if any (as concluded from Table 7).
Yes No
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Data Acceptable
N/A Need
More
G G
G G
G G
G G
G G
G G
G G
G G
Comments
N/A: not applicable
E2
-------
Table 2
EPA Evaluator Worksheet for Tier II Marine WQC Compliance and Water-Column Toxicity Data
Data Acceptable Comments
Data
1.
2.
3.
4.
for Compliance with Marine WQC
Chemical analysis of sediment and/or elutriate, including
- Laboratory methods and individual method detection limits
- Analytical results
Data on elutriate preparation, if any:
- Sample compositing
- Homogenization and sieving methods
- Storage method and duration
- Elutriate -water source/quality
List of applicable marine WQC.
Criteria for selecting appropriate dilution model (e.g.,
STFATE):
- Dilution model input parameters
- Disposal site water quality parameters
- Disposal site physical descriptions (size, depth, current
directions and velocities, etc.)
- Disposal operation descriptions (barge type, capacity,
discharge rate, speed, course, etc.)
- Dredged material descriptions (density, solid fractions,
concentrations of contaminants, etc.)
- Other project-specific data and assumptions for the model
input (type of dredging equipment, incremental rate of
discharge, etc.)
Yes
G
G
G
G
G
G
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A: not applicable
E3
-------
Table 2
EPA Evaluator Worksheet for Tier II Marine WQC Compliance and Water-Column Toxicity Data (continued)
Dilution model output (hardcopy printout, output analysis and
summary)
- Maximum predicted concentration of dredged material in
the water column outside of the boundaries of the disposal
site during and post disposal
- Maximum predicted concentration of dredged material in
the water column within disposal site bounds after the 4-h
initial-mixing period
Adequacy of the sediment sampling (as concluded from Table
6)
QA verification of analytical procedures and results, including
model input and operation (as concluded from Table 7)
Yes No
G G
G G
Data Acceptable
N/A Need
More
Comments
G
G
G
G
N/A: not applicable
E4
-------
Table 3
EPA Evaluator Worksheet for Tier III Water-Column Toxicity Data
Data Acceptable Comments
1 . Data on elutriate preparation:
- Sample compositing, if any
- Homogenization and sieving methods
- Storage method and duration
- Dilution series and dilution-water source/quality
2. Chemical analysis of the elutriate, including:
- Laboratory methods and method detection limits (MDL)
- Analytical results
3 . Data on treatments :
- Test species used and justification of selection
- Test endpoints
- Distribution of treatments
- Number of organisms in each treatment at start of test
- Observations and data recorded during the tests (observed
mortality, water-quality measurements, etc.)
- Number of organisms in each treatment recovered alive at
conclusion of test
- Additional observations (e.g., behavioral abnormalities)
- Percent survival in the control or the dilution water [mean
survival should be 90% or more (70% or more for
zooplankton) or test must be repeated]
- LC50 calculation for each sample or project segment
- Reference toxicants and reference toxicant LC50s for each
organism
Yes
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
4. Criteria for selecting appropriate dilution model
(e.g., STFATE).
N/A: not applicable
E5
-------
7.
Table 3
EPA Evaluator Worksheet for Tier III Water-Column Toxicity Data (continued)
Data Acceptable Comments
5.
6.
Dilution model input parameters:
- Disposal site water-quality parameters
- Disposal site physical descriptions (size, depth, current
directions and velocities, etc.)
- Disposal operation descriptions (barge type, capacity,
discharge rate, speed, course, etc.)
- Dredged material descriptions (density, solid fractions,
concentrations of contaminants, etc.)
- Other project-specific data and assumptions for the model
input (type of dredging equipment, incremental rate of
discharge, etc.)
Dilution model output (hardcopy printout, output analysis and
summary):
Yes
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
- Maximum predicted concentration of dredged material in
the water column outside the boundaries of the disposal
site during and post disposal
- Maximum predicted concentration of dredged material in
the water column within disposal site bounds after the 4-h
initial-mixing period
Comparison of predicted concentrations and 0.01 of the LC50
for each sample or project segment.
8. Adequacy of the sediment sampling (as concluded from
Table 6).
9. QA verification of analytical procedures and results, including
model input and operation and any statistical analyses (as
concluded from Table 7).
N/A: not applicable
E6
-------
Table 4
EPA Evaluator Worksheet for Tier III Benthic Toxicity Data
Data Acceptable Comments
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Treatment preparation procedures, including:
- Station identification
- Sediment compositing
- Homogenization
- Sieving
- Storage
Test species used in tests, and justification of selection.
Test organism data, including:
- Source of organisms
- Date of collection (if field collected)
- Laboratory holding conditions
- Organism care and feeding
Distribution of treatments within laboratory.
Test apparatus and setup.
Test endpoints.
Number of organisms in each treatment at start of tests.
Observations and data recorded during the tests (observed
mortality, water-quality measurements, etc.).
Number of organisms recovered alive at conclusion of tests.
Additional observations (e.g., behavioral abnormalities).
Yes
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A: not applicable
E7
-------
Table 4
EPA Evaluator Worksheet for Tier III Benthic Toxicity Data (continued)
Data Acceptable
Yes No N/A Need
More
11. Percent survival in control sediment (mean control survival
must be 90% or more or the test must be repeated).
12. Comparison of the dredged material and reference sediment
test survival.
13. Reference toxicants and reference toxicant LC50s for each test
organism.
Comments
14.
15.
Adequacy of the sediment sampling (as conclude from
Table 6).
QA verification of analytical procedures and results, including
any statistical analyses (as concluded from Table 7)
G
G
G
G
G
G
G
G
N/A: not applicable
E8
-------
Table 5
EPA Evaluator Worksheet for Tier III Benthic Bioaccumulation Data
Data Acceptable Comments
1.
2.
3.
4.
5.
6.
7.
8.
9.
Treatment preparation procedures, including:
- Station identification
- Sediment compositing
- Homogenization
- Sieving
- Storage
Test species used in tests and justification of selection.
Test organism data, including:
- Source of organisms
- Date of collection (if field collected)
- Laboratory holding conditions
- Organism care and feeding
Distribution of treatments within laboratory.
Test apparatus and setup.
Number of organisms in each treatment at start of tests.
Observations and data recorded during the tests (observed
mortality, water-quality measurements, etc.).
Additional observations (e.g., behavioral abnormalities).
Reference toxicants and reference toxicant LC50s for each test
organism.
Yes
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A: not applicable
E9
-------
Table 5
EPA Evaluator Worksheet for Tier III Benthic Bioaccumulation Data (continued)
Data Acceptable Comments
10.
11.
12.
13.
14.
15.
16.
Depuration procedures (if required).
Procedures and results of chemical analysis of tissues from:
- Dredged material tests
- Reference sediment tests
- Control sediment tests
Statistical comparison of contaminants in tissues from
dredged-material treatments to FDA standards.
Statistical comparison of contaminants in tissues from
dredged material and reference sediment treatments.
Comparison of contaminants in tissues from dredged material
to other appropriate values.
Adequacy of the sediment sampling (as concluded from Table
6).
QA verification of analytical procedures and results, including
any statistical analyses (as concluded from Table 7).
Yes
G
G
G
G
G
G
G
G
No
G
G
G
G
G
G
G
G
N/A
G
G
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
G
G
N/A: not applicable
E10
-------
Table 6
EPA Evaluator Worksheet for Determining Sampling and Analysis Plan Adequacy
5.
6.
Summary of project specifications, including:
- Project dimensions
- Dredging depths
- Allowable overdepth
- Side slopes
- Dredging methods
Summary of all applicable historical data including physical,
chemical, and biological analyses of sediments in the project
area, and analysis of land uses and other data on possible
contaminant loading to project area.
Subdivision of the project area (if applicable) and basis for
identification of project segments.
Sampling stations within each segment and method of station
selection (objective, worst-case, random, uniform, skewed-
random, skewed-uniform, exhaustive).
Navigation/positioning equipment used for sampling.
Record of sediment and water sampling, including:
- Field preparation
- Type of station (sediment samples: project, reference, or
control; water samples: project or reference)
- Date, time, tide, and station location
- Sampling depth and equipment used
- Sample identification and replicate number
- Observations made during the sampling operations
- Sample handling, preservation, and storage
procedures/requirements
- Sample custody and tracking procedures
Yes No
Data Acceptable
N/A Need
More
Comments
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Ell
-------
Table 6
EPA Evaluator Worksheet for Determining Sampling and Analysis Plan Adequacy (continued)
Data Acceptable Comments
7.
8.
Sample composite scheme.
Chemical and Biological testing:
- Detection Limits and Methods
- Testing parameters
- Tissue preparation
- Statistical methods
Yes
G
G
G
G
G
G
No
G
G
G
G
G
G
N/A
G
G
G
G
G
G
Need
More
G
G
G
G
G
G
9. QA verification of sampling and sample handling procedures
(as concluded from Table 7)
N/A: not applicable
E12
-------
Table 7
EPA Evaluator Worksheet for Verifying QA Components of Dredged-Material Evaluations
Yes No
Data Acceptable
N/A Need
More
Comments
General QA Components
1 . QA plan(s), approved and implemented prior to sampling/
analysis, including clear descriptions of:
- Evaluation/testing objectives
- Technical approach for each task
- Schedule of tasks and products (e.g., collection dates,
analysis dates, report dates)
- Data quality assessments/criteria (quality control)
- Sampling and analytical procedures
- Field and laboratory instrument calibration and
maintenance procedures
- Sample custody and tracking procedures
- Data documentation, reduction, validation, correction, and
reporting procedures
- Performance and system audits
- Responsibilities of major participants
2. Each sampling organization and testing laboratory:
- Has an established QA program
- Conducts all routine methods according to SOPs
- Participates in inter-laboratory testing/certification
program
- Has qualified personnel
- Has adequate facilities and equipment
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
N/A: not applicable
E13
-------
Table 7
EPA Evaluator Worksheet for Verifying QA Components of Dredged-Material Evaluations (continued)
Data Acceptable Comments
Yes
No
N/A
Specific QA Checks
3.
4.
5.
6.
Requirements met for:
- Sample collection
- Sample handling
- Sample preservation, if necessary
- Sample storage
- Sample tracking and custody
- Analytical methods
- Analytical objectives
Documentation of:
- Sample custody and tracking
- Equipment calibration and maintenance
- Data reduction and validation
- Sample processing and analysis
- Performance and system audits
- Corrective actions (if required)
- Quantitation levels (detection limit actually met)
Quality Control (QC) Data for Chemical Analyses:
- Replicate analyses
- Analysis of spikes
- Analysis of blanks
- Analysis of standard reference materials (SRM)
- Detection limit is achievable with confidence
QC Data for Biological Tests:
- Control survival
G
G
G
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
\J
G
Need
More
G
G
G
G
G
G
G
G
G
G
G
G
\J
G
G
G
G
G
G
G
G
G
\J
G
- LC50 determinations for SRMs
- During-test measurements and observations
- Replicate analyses
E14
-------
APPENDIX F
COMMENT LETTERS
-------
Texas Genera!
land Office
David Dewbuwt
Commissioner
i?OONc-(th
78751 -1495
May 29,2001
Mr. Sam .Becker
US, Environmental Protection Division, Region o'
1445 Ross Aye., Suite 1200
Dallas, Texas 78711-2873 I ;
Dear Mr. Becker: '- *
& '
The Toxas.General. Land O.flico fins reviewed tlic Apdl 200i drtal
Regional ImpJemontation Agrewnent: for Testing and Reporting < - •* v
Requirements for Ocean Disposal of Dredged Material off the Loii&ian^and
Texas Coasts (KM). We have no comments regarding the technicij; a&iiscts '
ofthcRIA. OT °
?!
I ask Uiat the U.S. Environmental Protection Agency and the US.
Army Corps of Engineers continue to coordinate the planning of dredged
material disposal sites with stale and federal resource agencies through the
ititeragcncy tcatn approach. The Coastal Projects Division of the Land
Office is currently evaluating offshore, sand sources for potential use for.
bench re-nourishment for some of our eroding Texas beaches. Perhaps some
the .information we obtain can be of assislnnce t:o your efforts in the future.
You may also contact my staff with Uie Resoiirce Management Program of
the Land Office regarding the consistency of proposed dredged material
management plam with the goals and policies of the Texas Coasts).
Management Act.
Jf you- need ;my additional inlonmtion regarding this matter you may
contact Mr. Ray Newby with the Coastal Projects Division of the Land
Oilioe at 512/475-3624 or by email at ray.new^y@gjo,state,lx.us,
Sincerely,
David Dewhurst
Texas Land Coinmi.ssioner
DD/rn.
The Galveston District has utilized the Interagency
Coordination Team approach successfully in the past
and will continue to do so in the future. Additional
coordination is encouraged by all resource agencies
through participation in the District's annual Dredging
Conference.
We look forward to coordinating with you in the
future.
Fl
-------
M,S,
1.
2.
State of Louisiana
- FOSTER. m
<• i
A t*3
Mr, Sam Becker, Acting Director
Water Quality. Protection Division,
United States Environmental Protection Agency
Region VI
l445:S:ossAVenac,;:Smte 1206 ""'""" '"''"' '"''''
Dallas, TX 75202-2733
KK: Regional Implementation Agreement, Final Draff, April 2001
Dea»- Mr. Becker:
We have received and reviewed the above referenced document and offer one comment.
The Preface page of the document lists the respective .agencies .requested to review the •Regional'
Implementation Agreement. Th« National Oceanic and Atmospheric Adminisiratiou (N0AA)
svas not listed as one of the reviewers. As you may be aware, NOAA has developed a set of
Sixeening Quick Reference Tables (SQuiRTs) that list screening etwcentraiions for inorganic.
and organic contaminants in various media.
Wo suggest that you consider these vahies during your evfihtation process \yhen deienaihuig if
the dmlged material is siiiEnhle for disposal.
We appreciate the opportunity to review the Regional Impleaicntation Agreetpent;
If • you or your stafl' should have any questions, please contact Mr. Percy :V.- Harris:<>)' she -Office
npRnt>iii AiopeampnniiKvirrtiiiniinta! Tecliftology Division at (235) 765-03S5.
JTDale Givens
Secretiao'
pvh
JIXMH-059
P.O.BOX S2JW BATOM ROUOE. "
T6U;W*>ME (225) 765-074! FAX (225) 765-W48
AN FJUAL OPPORTONITT EMPLOYER
70RR4-Z263
1) The National Oceanic and Atmospheric Administration
has been added to the list in the Preface.
2) The Ocean Dumping regulations require using effects-
based bioassay results for determining suitability of dredged
materials for ocean disposal and do not allow use of
sediment screening values for compliance decisions.
F2
-------
M J, "MiKŁ" FOSTKR,:JB.
GOVERNOR.
JAeKC.CALDWIiLL
SECRETARY
OEPAKTMENTQF NATURAL RKSWRpES
June:12,2:00I
Sam Becker
Acting Director
Water Quality Protection. DMson
U, S. Environmental Protection Agency, Region 6
1445 Ross Avenue, Suite 1200
O .-n
— ~t>
as «i?
ro vd
~**c
'-m
•:; ra
RE:
€20010237,, Solicitation of Views
U. S. Environmental Protection Agcriey V
Direct Federal Action § ~
Draft Regional Implementation Agreement (RIA) for testing and reporting rcquirer^itfer ocean
disposal of dredged material of the Louisiana and Texas coasts under the 103 Isctfijji of.tJKJ
Marine Protection, Research and Sanctuaries Act, Gulf Coast of Louisiana -c ~ tli
* - *.-. '. , >
Dear Mr. Becker
~, rs
r^
5 9?
..-.-•- .
-------
'
iiy questions concerning thitf matter, please comacl Jeff Harris'of the
Consistency Sectiojvat (225)342-7949,
Sincwcly,
Ącny w. Howey,
Administrator
TWMH/bgm
Jaclf Caldwell, Secretary
Fred Dunham, LDWF
Ronald J. Ventola, COE-NOD
Richard Hartraan, NMFS
Larry Wiesepape, LDEQ
F4
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE t'
646 Cajundonw Blvd.
Suite 400 ui
Lafayette, Louisiana 70506
May 29,2001
Mr, Sam Becker
U.S. Environmental Protection Agency
Acting Director
Water Quality Protection Division
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202-2733
Dear Mr. Becker. P
Please reference your May 10,2001, letter requesting our review of the final draft "Regional
Implementation Agreement for Testing and Reporting Requirements for Ocean Disposal of
Dredged Material Off the Louisiana and Texas Coasts under Section 103 of the Marine
Protection, Research and Sanctuaries Act," The following comments are submitted in
accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended;
16U.S.C.661etscq.).
Section 5.5. Reference end Control Sediments. Control Sediment. Second Paragraph, Page 17 -
It is indicated (and again in gection 9.33 Data Analysis, page 241 that a bioassay test should be
repeated if mortality/abnormality exceeds 30% in a zooplankton toxicity test. The 1990 Draft
Ecological Evaluation of Proposed Discharge of Dredged Material into Ocean Waters, the
"Green Book," in contrast, (page 10-13) states "If less than 10 percent mortality (20 percent for
zooplankton and larvae) occurs in the control treatment for a particular test species, the data for
that species may be evaluated," (i.e., those data are considered to be valid). The Inland Testing
Manual (1TM) lists similar percentages for acceptability of bioassay results. The standard for
mortality in a control is generally accepted to be 10%, except for amphipod bioassays in which
20% mortality is acceptable. Thus it appears that the 30% zooplankton mortality threshold is
excessive and fails to follow that recommended in related guidance. We recommend mat the
subject portions of the document be revised to incorporate, at a minimum, the 20% threshold for
consistency.
Table 2 Contaminants of Concern, page 20 - Several aroclors are listed under PCBs, but arc
absent from Appendix C.
10.3.3 Bioaccmnulation Evaluations - This section places substantial credence on Food and Drug
Administration (FDA) action levels (when they are available) in evaluating dredge sit& sediment
1) The Green Book was finalized in 1991, entitled Evaluation
of Dredged Material Proposed for Ocean Disposal-Testing
Manual (EPA-503/8-91/001), and recommends a 30%
threshold for mortality in zooplankton for water column
impact assessments (pg. 11-6)
2) Appendix C has been corrected to include the appropriate
detection limits.
F5
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3.
4.
contaminant .concentrations, FDA levels were prorogated to-evaluate contaminant levels in
various food items for human consumption. We recommend that this section be revised to
incorporate more appropriate criteria for evaluating ecological risk to aquatic biota, such as the
threshold effects levels (TBLs), probable effects levels (BELs), effects range low (ERLs), and
effects range median (EKMs) presented in the Notional Oceanic and Atmospheric
Administration's Screening Quick Reference Tables (SqujRTs), which can be viewed at
http'V/response.restorationjaoaa.gov/cpr/sednnent/squirt/html.
The Service-appreciates the opportunity to review the final draft RIA, and encourages the
EnvironmcntalProtection Agency Jo,utilize appropriate ecologicalTisk-based criteria when
evaluating dredged sediments for ocean disposal in the future. If any further assistance is
required, please contact-Paul Conzelmann of this office at (337)291-3126.
ell C. Watson
Acting Field Supervisor
FWS, Atlanta, GA (ES/HC)
USCQE, New Orleans^ LA
NMES, Baton Rouge; 3LA
NQAA, Dallas, TX
LDEQ,JSafon Rouge, IA
LDWF, Baton Rouge, LA
3) The Green Book recommends utilizing FDA action levels
as numerical screens for evaluating bioaccumulation potential.
The sediment screening values mentioned here (e.g.
ERL/ERM) are intended to evaluate the potential for acute
toxic effects rather than bioaccumulative impacts. In addition,
the Ocean Dumping regulations require using effects-based
bioassay results for determining suitability of dredged material
for ocean disposal and do not allow use of sediment screening
values for compliance decisions.
4) The current science of dredged material evaluations is
moving toward risk based evaluations. Some currently
available examples are outlined in Section 11 of the RIA.
F6
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S.
*•««>«•
UNITED STATES DEPARTMENT OP COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MAHINE FISHERIES SERVICE
Southeast Regional Office
9721 Executive Center Drive N,
St. Petersburg, Florida 33702
May 30,2001
Mr, Sam Becker
Acting Director
Water Quality Protection Division
US.EnvJronmentaI Protection Agency
Region 6
1445 Ross. Avenue, Suite 1200
Dallas, Texas 75202-2733
«?s
i
Ł-
Dear Mr. Becker:
As you requested in your Letter dated May 10,2001, the National Marine Fisheries Service (NMFS)
has reviewed the draft version of the revised Regional Implementation Agreement (RIA), Ocean
Dredged Material Disposal Program, dated April 2001, The RIA establishes administrative,
coordination and documentation procedures, in addition to sampling, testing, and analytical
procedures, that will be followed by the U.S. Army Corps of Engineers, New Orleans District and
Gdveston District and Environmental Protection Agency Region 6 in evaluating dredged materials
proposed for ocean disposal at any of the eighteen (18) Marine Protection Research and Sanctuaries
Act, Section 102(c) Ocean Dredged Material Disposal Sites along the Texas and Louisiana coasts.
The NMFS has no comments on this well organized and detailed testing manual. We appreciate the
opportunity to offer our comments and if you have any questions, please call Mr. William Jackson
at our Galvcston Field Office at (409) 766-3699.
Sincerely.
Andreas Mager, Jr. a
' Assistant Regional Administrator j*
Habitat Conservation Division ?*
.r-
O
F7
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PEPARTWENTT iOFTHE ARMY
Kfew 0«IJCA)ii« OlSVWCt COW* Of RtKJWSePIS
AlUJUSt 13, 2001
Operations Division
technical Support Branch
Mr. Sam Sector
Acting Director
Water Quality Protection Division
Environmental Protection Agency
1M5 Boss. Avenue
Duilas,TX 75202-2733 ? a Ł
;; u
Dear Mr. Becker;
We have reviewed the revised Regional Implementation Agreement (R! A), dated April 2001,
which complements the national guidance manual, Evaluation of Dredged Material Proposed.for
Ocean Disposal- Taxiing Manual (Green Book). Our Engineer Research and Development
Center also reviewed the document and provided comments as follows:
a. GENERAL COMMENTS
1. An advantage of a regional guidance is 'the; region specific issues -.may be; included.
Other regional guidance documents hrive been developed, such as die PSDDA Guidance aad
Great Lakes.Guidance. These documents have included regional specific issues thai have not
been included in.tae Region 6 .document An exarap Je of an issue that should be included is the
development of a regional list of Contaminants of Concern. Infusion of a list of contaminants
of concern would eliminate the need to analyze contaminants tliut are on the national list of
priority pollutants. These regional issues would be good to include, therefore we. suggest.
reviewing these other regional guidance documents to identify areas where additional regional
guidance could be included,
b. SPECIFIC COMMENTS
1. Page 4, Figure t. - The bottom two boxes should be split. Remove suitability the two
boxes and make the option for the EPA to concur or not concur with the determination
independent of its suitability Sxt ocean disposal.. In other words, make one box that indicates the
EPA concurs and one that EPA does not concur. From each of these, have
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' 3 . Page 1 2, bullet f - Include a line that indicates that COC& Should be identified.
4. Page 13-14 - Eliminate ihe four approaches and make a statement that you should
collect as much material that is necessary for the analysis. As it is Usied, it endorses an approach
that is ii tiered collection (i.e., 1*' collection is for chemistry, 21* collection is(fbr:piQassays).: This
approach should be avoided because the material can be very different at each collection lime
interpretation very difficult
5.. Page. !S-Clean:t«hriigiwsare;.cxpensiy5!.^n.c[ we v\iouid suggest they be used for
water alone! SMraiaits:wili;have:a backgrowii cpncwtTatmn of maiBls'tlial does -flirt .require
clean analysis.
6. Pags i 7, 1 " paragraph - Wfmt-is the poinJ reference? It is not cleat ;what this is! and
e. Maybe eliraiiffltc it?
7. Pago 17, Control Sediineut .-- Use wording frora the ITM-or QTM to describe control
scdirnent. \Ve rccojr;i»ei»dtJi* following wording;
" Control sediment is distinguished from the reference because it is collected from the
site where the tost species were collected or it is the material thai the organisms arc
cultured in the laboratory! The control sediment is used tQ confirm the health, of the
organisms during tbebUiassay tests and to validate die test protocol as part of the
laboratory QA/QC program. The control sediment should ..."
.8. Page 20 - identify regional contaminants of cone em. We assume there ate particular
ehctnicato that are a routine: problem for Region 6 (i.e. ,PAHs) while some may noi be a problem.
9. Page 21, last paragraph- Change "'['he liquid phase is the supernatant, , ."to "The
dissolved phase is obtained by filtering or wntrifuging the supernatant and is used . . ,"
10, ljagc 35, Laist bullet - Eliminate "and disposal of the dredged material is not
supported." '(tie placement of the material can still be done; it may:just rcquit e matiagenient as
indicated in the ne xt sentence.
1 1 , Page 26i bullet 2 - The approach of eliminiiting GOCs from the analysis during the
bioiitcumulation test; is> appropriate, progressive and will save money during tile evaJuatioi)-
12. Page 33, last pai-agraph - Move the discussion of the GBR appronch. TO the
icterpretalion of bioaccurrrulution data. Then discuss ecological risk assessment approaches Uiat
would ^^ include evaluating other ecological receptors, food webs, additional exposure pathways.
and comparative risfe analysis of other plaocnient options.
13. Page 32 and 53 - Include a descriptioii of- tlw site, physical 'characteristics of the
sedimentjund wuiwr eonditiorKi (siilinity)/ This would provide one to more easily identify the
appropriate referwiCrC for his or her project,
B3) This recommendation has been incorporated.
B4) The entire Section 5.3 Sampling Approach has been
revised.
B5) The discussion on clean techniques has been clarified
to apply to collection and analysis of metals in water
samples only.
B6) The reference point is discussed in Section 3.1.2 of the
Green Book. The RIA clarifies that this approach is not
recommended in this Region.
B7) The recommended revisions have been incorporated.
B8) We agree that for the existing Ocean Dumping
projects, certain classes of contaminants are not routinely a
problem. We are hesitant however to create site specific
lists in the event that other applicants besides the USAGE
use the sites in the future. We prefer to create project
specific COC lists.
B9) The term liquid phase, rather than dissolved fraction,
is used throughout the Green Book and the Ocean
Dumping regulations.
BIO) The sentence has been clarified.
Bll) The entire Section 10.1 has been removed.
B12) Section 11 is intended to apply to assessment of risk
in interpreting bioaccumulation data, and CBR is one of
several approaches discussed.
B13) Reference area locations have already been
determined for each ODMDS. A table of reference area
locations and maps of each area and ODMDS are included
in Appendix D.
F9
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We suggest that w& teleconference with the Gsiveston District and your office to discuss
resolution of these and any other comments received on the document
It has been a pleasure working with Ms. Monica Voungof your Kcosystems Protection
Branch on th^Amsion of this RIA. Ms. Young is extremely knowledgeable in ail aspects of
ocean disposal and in. particular in interpreting the regulations as they relate 10 dredged material
evaluation. She is to be commended for her work in the ocean disposal arena;
Sincerely
dA
Linda G. Manias, PhD.
Chief, Envitoomenta! Function
Copy ftiHiishted w&ttachraent;
Sfe NJoniea Young
EcbsyStems.Ptptectioa Brtnefe (6WQ-BM)
Siviroiunental Brotection Agency
Dallas, TX 75202-2733
•S
.:,; rrj
If
EPA has been closely coordinating all revisions with both
the Galveston District and New Orleans District.
F10
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Office of Water
Office of Wetlands, Oceans, and Watersheds
Oceans and Coastal Protection Division
AUG 2 7 2001
MEMORANDUM
SUBJECT:
FROM:
TOs
Review of Region 6 Draft Regional Implementation Agreement for the Testing
andvRepoiting Requirements for Ocean-DisposaJ of Dredged Material
Suzanne Schwartz
Director
Oceans and Coastal Pro
Divi
Sam Becker
Acting Director
Water Quality Protection Division (6WQ)
Thank you for the opportunity to review the draft version of the revised Region 6 Regional
Implementation Agreement, dated April 2001, which complements the national guidance manual,
known as the Green Book (Evaluation of Dredged Material Proposed for Ocean Disposal -
Testing Manual),
We ate very pleased with the efforts that Region 6 has put forth in establishing a consensus-based
process and close working relationship with both the New Orleans and Galveston Districts
through the development of the RIA. We have provided several specific edits for your
consideration (see attachment). In addition to the specific edits, there is a more general issue
raised in the RIA that concerns u* and may require discussion between our staffs. This issue
pertains to Inland Testing Manual (FTM) references. We recommend further consideration as to
when the ITM can be referenced because it is not the appropriate testing manual for evaluating
the suitability of dredged material proposed for ocean disposal. We do recognize that sections of
the ITM may be a helpful reference where lechniques and approaches of both the ITM and the
Oreenbook overlap, and the ITM can provide more updated, technical information. However,
references to the ITM for other reasons are not appropriate because the two dredged material
management regulatory programs have several significant differences. For example, the "reason
to believe" concept applies only to the CWA Section 404 program and the ITM. It does not
apply to ocean dumping: Therefore we recommend deleting it from the RIA.
If you have any questions, please feel free to contact me or David Lopez (202) 260-9179, who
will be the acting Chief for the Marine Pollution Control Branch until (he end of September.
Thank you again for including us in the review.
•* U.S. Environmental Protection Agency * Ariel Rios Building •*
* 1200 Pennsylvania Avc., NW.<4S04F» Washington, DC 20460 *
* (202) 260-1952 * http://www,epa.gov/owow/oc«ins/+
The RIA has been revised to clarify that only certain technical
sections of the ITM (e.g. sampling approach, quality assurance
considerations, and statistical analyses) are more technically
advanced and should be used. In the discussion of Tier I
evaluations all references to the ITM and "reason to believe"
have been removed.
Fll
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Regional Imple
Region.6
HQ Comments/Edits
*Nbtc: The following comments arc prepared in redline/strikeout.
p. ii, Glossary of Terms
Acute Toxicitv -The second sentence of this definition should read as follows: "The
acute toxiclty of contaminated sediment is ... under either field or. laboratory conditions,
for a specified project p
Bioaccumulation - "The accumulation of contaminants in the tissue of organisms ...
contaminated water, sediment, QJ pore water ui diwlgwl matwial."
Data Quality Objectives - "Qualitative and quantitative statements of the overall
uncertainty that a decision maker is willing to accept in results or decisions derives
djyjvgd, from environmental data,"
The definition for Dredged Material Elutriate should come before Effects range-low (ER-L)
and Effects range-medto medium (ER-M).
Effects range-low (ER-Lt and pffects range-median medium IER-M) - ...
p. iii, Tnland Testing Manual (TTM) - "Evaluation of Dredged Material Proposed, Cor Discharge in
Waters of the U.S. -Testing Manual ... Section 404 of the. Clean Water Act (inland
waters, near coastal waters, and surrounding environs - all;\yateriQthj6rt)ljan.th^,Qee8Ti
• aodtfaetP^TitQrjal^eas.resailated'pumiam to Sefition.4QJt.CWAl through..."
p. iv, Marine Protection Research and Sanctuaries Act CMPRSA) - "Enacted by Congress in
1972 ... or the London Dumping Convention of 1972..."
Reference Sediment - "A sediment, substantially free of contaminants, that is gs, similar
as practical..."
Solid Phase - The second sentence should read as follows: For the purposes of the RIA,
solid phase refers to the whole sediment as defined in the Green Book
9. p. v, Target Detection fcevei Limit (TDL) - """Note: Throughout the manual TDL is referred to as
the target detection level. Please make a global change throughout the document of target
detection level to target detection limit.
1) The sentence has been corrected.
2) The sentence has been corrected.
3) The description of Data Quality Objectives has
been revised.
4) All references to Effects range-low and Effects
range-medium screening values have been removed
from the RIA.
5) This recommendation has been incorporated,
6) The sentence has been corrected.
7) The sentence has been corrected.
8) This recommendation has been incorporated.
9) This recommendation has been incorporated
throughout the document.
F12
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10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
p. vi, List of Acronyms, TDL- Target Detection fceve*
p, I, Section 1,2, Purpose, please add the following as the last sentence of the first paragraph:
"This document is intended to serve as guidance :io implement the MPRSA and its
implementing regulations at 40 GFR 220-22&.
p. 2, Section 2, Applicability, we recommend the sentence in this section to read as follows:
'This document applies to all activities involving the transportation of dredged material
for the purpose of disposing it in ocean waters and;is applicable to dredging activities
authorized pr-pej mjtted. by the USAGE and navigational
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20.
21.
22.
23.
24.
25.
p, 18, Sec^Qn',,7^pre4gcd Material Evaluation, the secondiparagraph, second sentence, should
reaVas follows;
"If no acceptable biological effects-bused dataexist fora proposed dredging project and
ihfti*. i« n-jiwHHm lidmw. rhai aantamiujiBla afe'preaftHt'ii'i the icdimcnU \t does notmeet
the-, exclusion criteria then biological effects-based bioassays most will be conducted 10
determine regulatory compliance."
The last sentence of that paragraph which continues onto p. 19 should read as follows:
"For most projects, the impact of the solid phase on the benlhic environment deserves the
most rigorous evaluation, because the dredged material that is deposited on the sea floor
usually has itraatet'pQtential to causes greater impact to a smaller area..."
Please add the following sentence as the last sentence of the first full paragraph on p.19 (the last
paragraph of the Dredged Material Evaluation section):
'
"
p. 19, Section 8.2, Chemical Analysis, subsection Contaminants of Concern, the first sentence
should read as follows:
'Table 2 lisu.pptjjjjtilil contaminants of concern ..."
p. 21 , we recommend the first full paragraph to read as follows:
"The dredged nulerial shall be. analyzed for compounds identified as COC and
compwuidi known ov -impacted of being pUMtut at the-dtcdgiug iitt: If no sediment
chemistry data exist for a dredging project and'thereis no reason te'lKJitvi that
cotUamination-cif the dredged material miglit umt. analysis for the complete list of COC
in Table. 2 is required y/jll^Rerfprjns4"
p. 26, Section 10, Benthlc Evaluations and Secion 10.1 , Theoretical Bioaccumulatlon
Potenflal (TBP) Tier H, We recommerid the following edits to these sections:
10. BENTHIC EVALUATIONS
Benthic evaluations are required to determine compliance with the LPC of the
solid phase (40- CFR;227.27(b)) of the dredged material. These evaluations
include assessment of toxicity of the dredged material to appropriate sensitive
benthic marine organisms and an evaluation of the bioaccumulation potential of
the COC in the proposed dredged material. An initial screen of the dredged
material may be perf onned for estimating the potential of non-polar organics to
bioaccumulate using a theoretical bioaccumulation potential calculation.
aQagyj^ftaJHJBtoA^^
if!the dredged rnateriaJ-is'suitabte;forOceari';djjs.j!iDS8l,
20) This recommendation has been incorporated.
21) This sentence has been revised.
22) This paragraph has been revised.
23) This recommendation has been incorporated.
24) This recommendation has been incorporated.
25) The entire Section 10.1 has been removed. Reference
to TBP is included in the introductory paragraph of Section
10 and states that TBP may not be used to make regulatory
decitions in absence of bioassay tests but may be used as a
screening tool to re-evaluate the need for ocean disposal in
an effort to avoid Tier III bioassay costs.
F14
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10.1 Thepreiacal Bioaccurnulation Potential (TBP)-TIer II. Currently, only the
potential bioaccujnulaUve impact of non-polar organic compounds in dredged
material on benthic organisms can be evaluated at Tier E The procedure
calculates the TBP for a test organism by factoring the concentration of the COC
in the test sediment and reference sediment, the total organic carbon in the
sediment, and the lipid content in the organism. Chemical analysis of the dredged
material and reference sediment is required for the Tier U TBP procedure (Table
1). Section 10.2 of the Green Book provides a detailed description of the TBP
calculation,
The following points shall be considered when calculating the TBP;
• If the TBP value calculated for the test sediment is greater than that
calculated for the reference sediment, bioaccumulation of that non-polar
organic COC is predicted and further bipaccvrmulaiion testinj? at Tier m is
necessary.
oaa csts-.'-Thc TOP
alone ii not iuffieimt for dctemiimiig suitability
of the dredged irmttnal for ocean disposal; evaluation of UK. water column
impact* ami toxidty of the aolid phase-must aho be conducted. Li
tiOH) t-lJ
plicable jsubpara of sixtiona^O CTR must-be
««dy«d (40 CFR 227 SubpatU D, C, D. E, 0 i
b6low.ll
If the. TDP value calculated for the test sediment is less than that calculated
rortlic'tefeigDMi sediment, then bioaecumulatiini U nut piediated for that
panieularnoB'p&lar organic COC. This may eliminate1 thi need for furtlwr
testiue of Uiese COC at Tier-Ill aiiU ix-ducc costs.
these CrQC._ Jurttjcnnore. if K additional COC; other than non-polar
organic compounds, such as polar organics and metals, are detected in the
sediments, the Tier III bioaccumuMon test nnist sffl|be conducted and
tissues analyzed for those compounds.
ijujflhj
citiit fa Joten:
rfte
c*i tnc
] iAi Tor 'C
aiMi aud'toxieityof-the solid plrase1 must also be
In addition, tha remaining applicable-subpaj'ts and.
:40 .CFR muat-btt anajy/atl (40 CiTR 227 Subpam D. C. D, E;-6-and
of
Iffi-.either.gase. The TOP calculation cjiajimtion
is not sufficient for determining suitability of the dredged material for ocean
F15
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26.
disposal; evaluation of the water column impacts and tpxicity of the solid phase
must also be conducted. In addition.ithe.flilalvseyareatiiicdJjav- other inMHainmc.
applicable iiibptt-ti of sections 40 CPU-must 'be ai'ialv«ic^!oyJ5itaiS-OfM
, C, D, E, gaŁG andsegipn.
27. p. 28, the footnote for Mulinia tateralis (on p.27) which is printed at the top of p. 28 should be
deleted:
•*Braft>mothod-available from-EPArfiegion 6 of EPA Nati'agunsett Laboratory; could
pessiblyTObilUute'wilh Quahofi, Meivenariasp,
p. 28, please substitute the red-lined sentence as the first sentence of the second bullet: SJif
28- jui-vi'vai in tlit dredged material treatments is greater ihanihe reference sediment
riio'inore than 10%'(20% for amphipods) lower man the reference
treatment, the LTC for bcntlik toxiuty lua b
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Response to Comments
Peer Review of Regional Implementation Agreement
August 13, 2002
Reviewer #1 Comments
The document is satisfactory overall, however, there are two things the EPA/USACE might want
to consider:
1. Section 7. Dredged Material Evaluation (in the last paragraph) notes that 40 CFR 227.27(b)
requires that both acute and chronic toxicity effects of dredged material be measured and further
comments that a chronic toxicity method based on Leptocheirus has been developed and is
currently available. Although neither the Green Book nor the ITM currently address chronic
toxicity, it seems clear that the regulations require it and that sometime in the future the programs
will have to implement chronic toxicity evaluation. It would be really "forward-thinking" if the
agencies could foresee this eventuality and elevate Leptocheirus from it's current status as an
alternate species to a recommended species. This could be the driver needed to wean the
agencies away from Ampelisca abdita (BTW, did you know the latter part of the binomial is latin
for "the devil's bug?").
Response: The RIA was revised to state that either amphipod Ampelisca or Leptocheirus is
recommended for benthic toxicity evaluations.
2. The RIA should provide guidance for dealing directly with confounding factors, such as
ammonia and/or hydrogen sulfide, when there is toxicity and evidence of >1 TU of such
constituents in the sediments. Currently, the ITM suggests that whole sediment TIE procedures
could/should be employed to answer some of these questions and I generally concur; however,
when there is strong weight-of-evidence for ammonia toxicity to an ammonia-sensitive organism
but no toxicity to an ammonia-insensitive organism in a companion test (as in the recent Bayou
Segnette project for the New Orleans District), there is no need to perfom expensive TIE tests to
prove ammonia toxicity and, as you know, there is generally no contractual basis for doing so
either. It would be very useful, and time- and money-saving everyone, if the RIA could simply
state that there is no need for TIEs if the weight-of-evidence supports a claim for a single-
causative toxicant, such as ammonia or hydrogen sulfide, whose effects would be minimal or
non-existent following open water disposal of the subject dredged material.
Response: The RIA was revised to state that causes of test failures in the control sediments
should be identified (e.g. grain size sensitivity, pH and ammonia) and addressed appropriately.
Reviewer #2 Comments
1. In general I felt the manual was well written and useful for EPA and the Corps as a condensed
summary of the national manuals. I would turn to your manual to assist a novice in
understanding the complexities of the national manuals. Several places in the manual discuss
state WQ requirements and use of the ITM. It is difficult to separate 103,404, and 401
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requirements. You never discuss distances to sites in this manual, but I am assuming that WQ
Certification is necessary for some or all of your sites. With the proposed national level effort to
combine the OTM and the ITM, I would strongly recommend that your manual also be a joint
manual for both 404 and 103 evaluations. If the states requirements could be incorporated and
agreed to, I feel you would have a true regional manual. That said I will offer up several
suggestions that I feel would make your efforts more regional and make the document more user
friendly to permit applicants and the states.
Response: Our manual is intended as guidance on implementing the ocean dumping testing
procedures recommended in the national guidance and not on the process of regulating dredged
material disposal.
2. In general it is unclear to me any advantage of this manual over using the national manuals. A
regional manual should develop COC lists for specific projects , sub-regions and/or the entire
region. Sampling and analysis requirements should be established in the manual so applicants
know what to expect and budget for. The only regionalization I saw in this manual was the
establishment of reference areas, which you are to be commended for, but this should have been
followed by a discussion of the region's dredging projects and recommendations on which sites
should be used for them under what conditions. I also recommend that state WQ Certification
requirements be included in the discussion. I believe a regional manual should act as the guide to
the process to applicants, state personnel, and new federal agency employees. Our NW
Regional Manual has served us well be making the States of Washington and Oregon signatory
to the document.
Response: As currently presented the COC list is intended to serve as a starting place for
identifying project specific contaminants. Due to the nature of the coastline in our Region, we
are hesitant to create site specific lists based solely on information from one project currently
utilizing the ODMDS in the event that other applicants besides the USAGE use the sites in the
future. In addition, we have regionalized our species lists for bioassays. Our manual is intended
as guidance on implementing the testing procedures recommended in the national guidance and
not on the process of regulating dredged material disposal.
3. Page iv: The only place LPC is defined as to what it is and how to use it is in this Glossary.
Because this value is interwoven throughout the document I would suggest that there be a more
general discussion of what it is and how it is used. Perhaps you could provide a list of the values
in the appropriate place in the report.
Response: A section has been added to the document addressing LPC and defining LPC for the
three phases.
4. Page 1: This page discusses both national manuals and reasons for needing both. If there are
reasons for not making this manual for both 404 and 103 they should be discussed here, sec 1.3:
subject to review should be discussed. Is this a public review with public notice.
Response: This document is not intended to serve as a joint CWA/MPRSA document. References
-------
to the ITM are limited to technical guidance that is more up-to-date than that provided in the
Green Book (e.g. statistical analyses, QA/QC). The review discussed is intended to be by the
public, the document has been revised to reflect this.
5. Page 2, sec 2: It should be discussed here why it is only for 103, it is unclear to me why it can
not be used for 404 evaluations and what the role of the states are, if WQ cert, is needed within
the three mile overlap of the two laws.
Response: Our manual is intended as guidance on implementing the ocean dumping testing
procedures recommended in the national guidance and not on the process of regulating dredged
material disposal.
6. Page 2 and 3 sec 3: This report should also be an applicants guide to the process. It should be
something with enough detail that they can understand what is required of them. The 103
process is more than a sediment evaluation. The process should be discussed and perhaps a case
study be included as an appendix.
sec 3.1: Our region has had difficulty agreeing on what constitutes a completed permit
application this term should be defined in your report, sec 3.2: In our region as a matter of
comity we obtain state WQ certification for 103 actions. It is confusing to me why the states role
is not discussed here.
Response: Our manual is intended as guidance on implementing the ocean dumping testing
procedures recommended in the national guidance and not on the process of regulating dredged
material disposal.
1. Page 5: Because of the general nature of the requirements in the manual and the discretion
EPA has in determining adequacy of information, it doesn't appear to me that 3 months in
sufficient time to conduct additional test that might be required by EPA. If EPA requires
additional chemical analysis or bioassays or Bioaccumulation tests 3 months is not enough time
to get additional samples collected and results back.
Response: Both EPA and the COE have agreed that the three month time frame is adequate.
8. Page 6: The states of Louisiana and Texas were ask to provide comments and their letters are
appended to the report. Their role and purpose of requesting comments from them is not
discussed in the report, this page would be a good place to discuss the states role.
Response: The States were included in a technical review of the testing requirements along with
the other resource agencies that have some responsibility for dredged material management.
Again, our manual is intended as guidance on implementing the ocean dumping testing
procedures recommended in the national guidance and not on the process of regulating dredged
material disposal.
9. Figures 1 and 2 are the first place LPC is used, other than in the Glossary. The term should
be discussed and its importance to the process pointed out before it is abbreviated on these
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figures.
Response: A section has been added to the document addressing LPC and defining LPCfor the
three phases.
10. Page 8 sec 4.3: Predominantly sand has to be defined it is critical to the assessment process.
Later in the report it is discussed it will be determined on a case by case bases. This will not be
acceptable to applicants, a regional definition is necessary as the bases for all decisions that
follow.
Response: We believe, as with determination of COC, that predominantly sand determinations
should be made on a case-by-case basis.
11. Pages 8,9, and 10: LPC is used extensively as a decision tool in this discussion. Because of
this I strongly recommend that a discussion of how, what, and why and the importance of LPCs
be discussed.
Response: A section has been added to the document addressing LPC and defining LPCfor the
three phases.
Page 9: sec 4.5: Protocols should be defined in this manual not case by case in each projects
sampling plan. The plan should reflect protocols agreed to by all the parties subject to this
manual which are full reviewed and public noticed. Also COCs can be and should be agreed to
up front for each general project area. The national list should be adjusted for chemicals known
not to be in the area or additional chemicals not on the national list. It seems to me that the
states should also play a role in making up regional/subregional COC lists.
Response: We agree. The section has been clarified to state that sediments should be collected
and analyzed according to the approved sampling and analysis plans. As currently presented the
COC list is intended to serve as a starting place for identifying project specific contaminants and
states that this list should be adjusted for the specific project. Due to the nature of the coastline
in our Region, we are hesitant to create site specific lists based solely on information from one
project currently utilizing the ODMDS in the event that other applicants besides the USACE use
the sites in the future.
12. Page 12. Requirements for a SAP can be developed for this manual. Applicants in the NW
know how many individual and composite samples will be needed based on the dredging
volumes and where the samples should be collected within the dredging prism. Recommend that
the manual be more specific into the numbers types and locations of the samples required, and
not make it a case by case decision.
Response: This approach is not appropriate for our Region due to the large nature of the
projects.
13. Page 19: The logic of adding chemicals to the National COC list should also be used to
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remove chemicals from the list. If the dredging location is in a pristine natural bay chances of
manufacturing chemicals be present a remote. They could be removed from the list. The
analysis of all National COCs is expensive and time consuming and chemical should be
eliminated when ever possible, to reduce the monetary burden to the applicant.
Response: As currently presented the COC list is intended to serve as a starting place for
identifying project specific contaminants and states that this list should be adjusted for the
specific project. Due to the nature of the coastline in our Region, we are hesitant to create site
specific lists based solely on information from one project currently utilizing the ODMDS in the
event that other applicants besides the USAGE use the sites in the future.
14. Page 20: sec 9: Here is another example of discussion of state WQ Standards, but no
discussion here or elsewhere as to why this is necessary or the role of the states. Page 22 also
specifically discussed Texas and Louisiana standards but not why they are being used.
Response: The reference to the State Standards is necessary to show compliance with the
regulatory requirement of meeting water quality criteria (the LPCfor the liquid phase). A
section has been added to the document addressing LPC and defining LPC for the three phases.
15. Page 29: The manuals discussion of the tiered testing procedures is good and appears to
fully comply with the national manuals. The statement at the bottom of page 29 is however
troubling, "in some cases, however it may be desirable to analyze tissues for compounds not
detected in the sediments" this statement if true must be supported.
Response: In our Region we have occasionally encountered project specific contaminants that
are a concern to the public but which may not have been detected in the sediments and thus are
included on the COC list for tissue analyses.
16. Appendix A If this is indeed a 103 evaluation process or part of one. it should reference that
fact. It appears that the two Corps districts should also be discussed and their role in the process.
As written this appendix puts EPA in sole control.
Response: The Appendix has been clarified to reflect that the 103 evaluative process is a joint
process between the USAGE and EPA
Reviewer #3 Comments
1. The Agreement is well-organized and covers the issues very well; I found it generally easy to
interpret, which is always helpful in a guidance document!
Response: We appreciate the comment.
2. Some areas that could be clarified:
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a. Sec. 4.6 (2); it is unclear whether dredged material must meet all three criteria to be
eligible for ocean disposal;
Response: This section has been clarified to state that the dredged material is not compliant if it
does not meet any one or more of the three phases.
b. Sec. 9.3.2; other species used successfully in past dredged material evaluations
included sea urchins and oysters, but neither is included in the list of species that are cited
as eligible for water column bioassays;
Response: These species are included on the national lists but are not included on our
regionalized listing and are not recommended.
c. Sec. 10.1.2; has Neanthes arenaceodenta been eliminated as a whole sediment bioassay
test species?
Response: This organism has not been removed from the national list, however, it is not included
on our regionalized list and is not recommended.
d. Sec. 10.2.2; this section should state clearly whether bioaccumulation test tissue
replicates can be composited for chemical analysis;
Response: The section has been clarified to state that only organisms in a given replicate
chamber my be composited for chemical analysis, therefore sufficient biomass must be obtained
from each replicate.
3. Except as noted in 2.a above, the RIA is clear with respect to decision-making and
interpretation of analytical results.
Response: We thank you for your comment.
4. Bioaccumulation potential estimates based on limited tissue data are inherently unreliable, but
represent the most practicable approach to addressing this issue. It may be appropriate to
stipulate that control sediment-exposed tissues and pre-exposure tissues be analyzed chemically,
to provide a clearer picture of bioaccumulation in test sediment exposures. The RIA addresses
bioaccumulation well, although some additional treatment of bioaccumulation factors and
ecological risk may be called for. If replicates are able to be composited for tissue chemistry,
what statistical analysis can/would be performed to compare reference and test sediments?
Response: The RIA currently recommends that tissues be analyzed prior to exposure to obtain
necessary information regarding background tissue concentrations. We do not recommend
compositing replicates. Only organisms in a given replicate chamber my be composited for
chemical analysis, therefore sufficient biomass must be obtained from each replicate. Statistical
recommendations are currently provided in the RIA.
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5. Overall, the lab analyses recommended are appropriate and based on good technical
methodologies, except that some species should be added to lists of acceptable test species (eg.,
sea urchin species, for fertilization test method). Dredged material characterization guidelines
are easy to follow; however, it should be stated clearly whether alternative test methods can be
employed, if sufficient justification is provided.
Response: The RIA currently allows for alternative test methods if sufficiently justified and
approved by the USAGE and EPA prior to use.
Reviewer #4 Comments
Page v: Should you say something about the reference Rule when you talk about reference
sediment?
Response: The reference rule is only applicable to dredged materials removed from inland
waterways and regulated under the Clean Water Act, Section 404 and not to ocean dumping of
dredged materials. Reference areas for the existing ODMDS have been selected and are
provided in the RIA.
Page 15: Do you have a minimum requirement for survival in the reference sediment? What
about test sediments that are not suitable for the test organisms because of salinity, or grain size,
or pH or some other factor that is not COC-related?
Response: There is currently no minimum survival requirement for the reference sediments. The
RIA was revised to state that causes of test failures in the control sediments should be identified
(e.g. grain size sensitivity, pH and ammonia) and addressed appropriately.
Page 19: Wouldn=t you need to do testing even if there was only one COC?
Response: Yes. The RIA has been clarified to state that testing would be required due to the
presence of one or more contaminants.
Page 21: Does Table 2 relate to Water or Seds or both?
Response: Table 2 relates to both water and sediments.
Page 22, diamond 1: What if there is only one COC that is exceeded?
Response: The RIA has been clarified to state that synergistic effects may be expected if one or
more contaminant is detected. In some cases contaminants may be undetected but still present
and causing synergistic effects.
Page 22, Diamond 2:1 would say Apossible® rather than Asuspected®.
Response: The recommended change has been incorporated throughout the document.
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Page 22, Diamond 3, point 1:1 would say Apossible® rather than Asuspected®.
Response: The recommended change has been incorporated throughout the document.
Page 22, Diamond 3, point 2: Should we get a flow chart?
Response: We do not intend to incorporate a flow chart at this time.
Page 23, 9.3.1: Should you refer back to the 1:4 dilution?
Response: The recommended change has been incorporated.
Page 24, Table: Can you use the mysids twice? Would you use different stages for different
categories?
Response: The Green Book and the RIA allow for using different stages of the Mysids for
different categories.
Page 24: Would a flow chart be helpful here?
Response: We do not intend to incorporate a flow chart at this time.
Page 24, Diamond 4: What does A100% dredged material® mean? Does it mean Afull-strength
elutriate®?
Response: The section has been clarified to say the A100% dredged material elutriate®. This
change has been made throughout.
Page 25, Square 4: Is it possible to do a cheap flunk here? Might you cahnge the dilution to get
it?
Response: The current guidance recommends a serial dilution in order to extrapolate the LCso.
The RIA also recommends this approach.
Page 26, 10.0:®The initial screen...may be used to aid in re-evaluating...® How would this work?
Are you referring to a Acheap flunk?®
Response: The intent of utilizing the TBP calculation is aid in deciding whether to spend
additional money to conduct further testing or to forgo ocean disposal for a different disposal
method. It is not intended to be used to make regulatory decisions.
Page 26, 10.1.1: Do you need to define Areference sediment® and Acontrol sediment®?
Response: The RIA currently defines and addresses reference and control sediments.
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Page 27, Paragraph 2: AAt least two species should be selected....to cover three..® Is this legal?
Response: Yes, the existing regulations allow for utilizing two species to cover the three feeding
strategies.
Page 27, 10.1.3: Will the test fail if the control survival is below 90%, but all of the test
sediments are above 90%? Are there any requirements as to minimum survival at the reference
site?
Response: If control survival is below 90% it is recommended that the test be rejected and
repeated. There is currently no minimum survival requirement for the reference sediments. The
RIA was revised to state that causes of test failures in the control sediments should be identified
(e.g. grain size sensitivity, pH and ammonia) and addressed appropriately.
Page 29: Why would you recommend Mercenaria? Is it not a biological rock?
Response: Species recommended for bioaccumulation analyses should be hardy species that
allow for accumulation of contaminants and not mortality when exposed to the dredged
materials.
Page 31: Could you just list the FDA limits in the RIA? I think that there is a lot of cross-
referencing in the document, and you might want to make it easier for the applicants where you
can, and save them a look up, maybe by putting stuff into an appendix.
Response: We prefer to reference items such as criteria and limits rather than include them in
the RIA since these items are the most likely to change.
Page 32: Are these factors modified from the original 11 factors in the Green Book? You might
mention it if they were.
Response: These nine factors are not modified from how they appear in the Green Book.
Page 32, 9.: Is there a Areference reference® that values can be compared to?
Response: Currently, background tissue concentrations of in situ organisms have not been
obtained for this region and would need to be determined on a case-by-case basis, as is
recommended in the Tier IV evaluations.
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