UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   '                          WASHINGTON, O.C, aQ<46G
                                  January 15, 1987
Honorable Lee M. Thomas                •                  SAB-EEG-87-Q14
Administrator
U.S. Environmental Protection Agency
401 M St., SW                          '                               o
Washington, DC  20460                           '                  rH

Dear Mr* Thomas;

     The Science Advisory Board's Environmental Engineering Committee has recently
completed its review of a document written by the Office of Marine and Estuarine
Protection (OMEP) to justify the separate treatment of sewage sludges and dredged
materials under the EPA ocean' dumping regulations.  At the request of OMEP, the
subject of this review was originally a draft technical support document developed
by the U.S. Amy Corps of Engineers.  In response to a number of issues raised by
the Committee, however, QMEP decided to develop a justification document of its
own, which is the actual subject of this review.  Hfe are pleased to forward to you
the Committee's report for your consideration.

     Although the Committee, agrees with -the Agency that thene are significant
differences in the properties of most sewage sludges and dredged materials,
significant exceptions exist.  It is crucial that clearly defined, consistent,
rigorous, and peer-reviewed procedures exist to identify these exceptions.  CMEP
maintains that existing procedures for evaluating dredged materials (under Part
227,13) are adequate? however, based on the documents provided to the Committee,
a rigorous protocol for identifying exceptions does not appear to exist.  The
Committee believes that a technical basis for identifying dredged materials that
require special handling and disposal could be developed.

     The Committee wishes to note the cooperation it received from the Corps of
Engineers on this review, and particularly £rcm the three members of the Corps'
Environmental Advisory Board who participated in the Committee's reviews of ocean
dumping and sewage sludge issues.   Such cooperative interagency review efforts
have considerable benefits.

     The Committee appreciates the opportunity to conduct this scientific review.
Pfe request that the Agency formally respond to the^attached report.

                                        Sincerely,
                                        Raymond C. Loehr, Chairman
                                        Environmental Engineering Committee
                                        Science Advisory Board
                                        Norton Nelson, Chairman
                                        Executive Committee
                                        Science Advisory Board
Attachment

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                                  NOTICE
     Thts report has been written by the Science Advlsorv Board,  a
public advisory group providing extramural scientific information and
advice to the Administrator and other -officials of the Environmental
Protection Agency,  The Board is structured to provide a. balanced,
expert assessment of scientific matters related to problems facing the
Agency.  This report bas not been reviewed for approval by the Agency,
and hence, the contents of this report do not necessarily represent
the views and policies of the Enyirormental Protection Agency. Nor
does mention of trade names or commercial products represent endorsement
or recommendation for use.

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                                                     -R7-014
     OF TECHNICAL DOCUMENTS SUPPORTING REVISIONS

              to the portion of

EPA OCFAN DUMPING RFOTAltfNS RELATING TO THE
     OCEAN DISPOSAL OF PPFJ3GF.D MATERIALS
                  REPORT r>F

   THE ENVIWVMFMEAL ENRINKEPING CCMMITTKK
     H.S. Environmencal Protection Agencv
            Science Advisory Board
               Washington, D.C.
                January, 19R?

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                            Table  of Contents
   I.     BXBCUTIVE SUMMARY ........ ....... ---- ................... ..... .   1

  II.     IWTRDDUCriON  ............. ---- ................. ....... *..,.,.,   2

 III.     REPORT Cm THE DREDGED MATERIAL TECHNICAL RATIONALE
         A, General Garments  ... ...... ....... ..... ....... — ...........   4
         B, Specific Garments . ......... ............ ..... ..............   5
         C. Corrections  ......... ......... ........ .............. .......   9
'iv. '• !
        A.  Boster of Committee Menbers  Conducting  the  Review ........  10
        B.  Charge to the Conmittee  ...... ...... ............. ...... ...  13
        C.  References  ..... ..... ... ..... * , ....... * ...... .............  14

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i.
     In late 1985, the Environmental Engineering Comittee of the Science
Advisory Board was asked by the Office of Marine and Estuarine Protection
(OMEP) to review technical documents supporting revisions to the Agency's
ocean-dumping regulations.  The two main issues were:  1)' technical justification
for the separate regulatory treatment of the disposal of dredged naterials
and 2) the consideration, in the ocean disposal of sewage sludges, of both
the need for ocean dutnping and the avallahility and impacts of land-based
alternatives,  this report deals with the first issue onlv.

     The Committee's original charge was to review a draft technical support
document for revision of the 1977 ocean-dii^plng regulations and criteria,
dated Fehruarv 15, l^ftfi, prepared hy the Waterways Experiment Station of the
U. S. Arrny Corps of Engineers (1) and to advise CMEP on its technical adequacy,
This document was determined hy the Coranittee to be inadequate to support the
different treatment of dredeed materials.  As a result, CMFP subsequently
prepared a technical support document of its own (2) , which is the subject
of this review.

     The following summary outlines the Ooramittee's principal findings and
recommendations.  Section III of this .report presents details on each of
these areas.          • . .  •    .       -      .                 ,

     A.  Al though the general conclusions in the OTCP docment appear adequate
and accurate, they were not adequately supported by the data in the document*
Without this documentation,  the Cotmittee was not able to evaluate or agree
with all the indicated conclusions.

     B.  The Ccffnritttee does not agree that separate testing of dredged
materials is justified in all cases.  While niost dredged materials could
well he sufficiently different from sewage sludge co justify separate testing
procedures,  significant exceptions exist, particularly whet? dredged material?
have been, or are suspected to be, highly contaminated hy toxic materials,
It is therefore crucial that clearly defined, consistent, rigorous, peer-reviewed
procedures he developed to identify these exceptions.  A clear, technically
sound, and unarnbigvous protocol should be available to detemine, for each
dredging site, whether or not the dredged material is sufficiently different
from sewage sludge and should he disposed differently than sewage sludge.
This protocol should include consideration of the nature of the planned
dredging and dumping operations themselves, since they can influence the
amount of toxicants available for exposure to humans or marine organisms.
Based on the documents provided to the Committee, such a protocol does not
appear to he available.  It should he developed.

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                                      -2-

ii.  iFTffnCTifTTirM

     In late  1985, EPA's Office of Marine and Estuarine Protection (OHEP) requested
that the Science Advisor? Board (BAB) review technical documents supporting revisions
to the Agency's ocean-dumping regulations, which implement the Marine Protection,
Research, and Sanctuaries Act (MPRRA'i.  f^e documents were to he divided into
two categories addressing, respectively, ocean disposal of sewage (POTV) sludge
and ocean disposal of dredged material.

     At the same tine, the Science Advisory Board was also asked by the office
of Water Regulations and Standards (CWRS) to review technical dociinents support-
ins the development of regulations (under Section 4("6(d) of the Clean Water
Act) for the  disposal/reuse of POTtf sludges.  Both of these reviews were assigned
to the Environmental Engineering Committee, which, decided to conduct both
reviews siraultanewislv, since ebe subject material was very similar and since, in
fact, the same methodology was being used in some cases to support both regula-
tory efforts.

     The Environmental Engineering (Tom it tee accepted the task, aid augmented
its existing  membership with a number of consultants, including three raanbers
of the Environmental Advisorv Board of the IT. 8, Armv Corps of l^gineers;
three members of the SAP's Environmental Effects, Transport and Fate Committee;
one member of the SAB's Environmental Health Conmittee; and others.  The Cotmittee
organized itself for the reviews by creating a member of subgroups, each
dealing with one or more opt ions /documents.  A listing of the Committee membership,
which includes the, subgroup breakdc&m, i§ provided, in Appendix A.  The _ Cotmittee
decided that, rather than isstie one large report covering all reviews,'it
would isstie separate reports on the disposal of dredged materials and on the
disposal/reuse of sewage sludges,

     This report, then, is confined to a review of technical material supporting
revisions to  that portion of the ocean-dumping regulations relating to the
disposal of dredged materials.  The specific charge to the SAB appears in
Appendix B.  The Committee recognises that there could well be beneficial uses
of dredge materials, hut it has omitted any discussion of this issne, as it was
not within the charse of this review,

     Revisions to the MPRSA relate to two separate and distinct issues.  First,
the Agencv must make revisions to the portion of the regulations dealing with
the disposal  of POTW sludges,  these revisions, mandated by a lawsuit brought
by the City of Hew York, will require that consideration 'be given to the need
for ocean dumping and to the availability and impacts of land-based alterna-
tives (whereas the current regulation considers only marine inpacts).  This
issue will be dealt with in conjunction with the totaaittee1 s review of materials
supporting revisions to the 4n5(d) regulations, and will be the subject of a
separate SAB  report.  Second, the Agencv must, as a result of a second lawsuit
brought bv the National Wildlife Federation, provide adequate technical justi-
fication for  current regulations permittinE different regulatory treatment for
the disposal of dredged materials.

     Documents for review began to arrive in April, 1986, and on May 1-2, 198fi
the Committee held its first meeting, at which it was briefed bv personnel from
CIJRS,  flKEP, and the Corps of Engineers on the technical rationale for the
disposal of dredged materials (1), which was to form the technical underpinning
for proposed  revisions to the ocean-dumping regulations.  A second meeting of
the Conmittee was >>eid on June 10-11 f at which it was briefed in more detail
abotit the dredged material technical rationale.

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                                      -3-
     Subsequent meetings of the full Coproittee were held on July 23-24, August
13-20, September 29-30, October 27-28, and December 15-1 ft.  The, purpose of
these meetings was primari.lv for ftonriittee discussions and drafting of the
Committee report..  At west of these meetings, EPA and Corps of fhgtneers staff
were present to either brief the Ooramittee or to answer questions and clarify
points that were not clear.  (The Committee "notes the assistance of Mr. Bavid
Ifethis, Mr. Robert Engler, Dr. Dick Peddicord, and Cpt. Glen Lozier of the
      of Engineers; and of Mr. Al Vastier of EPA.)
     In late June, 19S6, OMEP decided that it would > in response to a number
of questions raised about the adequacy of the dredged nateria.1 technical rationale
drafted by the Corps of Engineers, draft a technical support document of its
own.  This document (2) was furnished to the Committee on July 31 , 19B6, with
an explanation that it, rather than the Corps of Engineers document, was to
be the basis for regulation development.  This OHEP docurent is the subject,
of the Comnittee's report.                —                .         •    —

     This report, while largelv drafted by the subgroup chaired by Dr. Robert
Huggett, has been contributed to, reviewed, roodified as necessarv, and approved
by the fall Conmtttee.

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                                      -4-
III,  RFPORT ON THE DREDGED MATERIAL TECHNICAL RATIONALE


     A, General Cotments

     The Committee agrees with the Agency's contention that there are significant,
basic differences in the physical, chemical, and biological characteristics of
some, possihly even most, dredged materials and sewage sludges which can warrant
different toxicological, chemical, and physical testing.  The higher water
content and lower particle density of some typical sewage sludges indicate that
the material will often remain in suspension wore so than some tvpical dredged
materials with lower water content and higher particle density.  Therefore, it
is logical to assume that, in general, each of the two general classes will
have a different potential to affect a given segment of the marine ecosystem,

     The CormjLttee Hoes not agree that separate testing of dredged materials
is _justified'~in~all cases^The Apency should distinguish between different"
Motogical impact potentials, whether they are between sludpes and dredge
materials or between different sludges and different dredge materials themselves,
and the testing mandated should be hased on these potentials.

     It is important to note that dredged materials and sewage sludges vary
considerably among themselves depending on the sources and anthropogenic inputs
of toxic materials and pathogens.  Because of this variability, there nay be
situations in which dredged materials are transported like and have a fate
similar to sewage sludge.  For example, most of the toxic organics, if present,
will h*» preferentially partitioned to the organic fraction of the naterials
being disposed of in the ocean.  The solid material in sewage sludge is (usually)
ipostlv organic, while cormonly encountered dredged materials typicallv contain
onlv 2-8T, organics.  The concentrations of toxicants would be rmch higher in the
organic fraction of the dredged materials if the bulk, drv-weight concentrations
were similar to those in sewage sludge which, in fact, sometimes occurs.

     The document areues that sewage sludge reoains in suspenion.  Organic
solids suspended in the water column should act similarly, whether from sewage
sludge or dredged materials*  Since the toxicants could conceivably be an
order of magnitude (or more) concentrated in the dredged material otganics,
the potential clearly exists for transport and resultant biological impacts
outside the dump site.  In such a case, not likely to be an especially rare
case, it is logical that similar toxicological and chemical testing be required
for both dredged waterials and sewage sludges.

     Another situation in which similar testing may be required concerns the
actual dredging/disposal operation.  The dredged material in a transporting
barge or vessel is not homogeneous.  The upper section (the last to enter the
water) usually consists of a very fine grained, unconsolidated, low-solids
mixture.  The bottom is more consolidated with a lower water content.  In
harbor dredging or deepening, operations, the uppermost material may be very
highly contaminated with metals and organics.  This material would not be
expected to deposit rapidly on the ocean floor and could well be transported
by ocean currents off- the designated disposal site.  While a very high percentage
of the "dumped" material may rapidly deposit, tjbat remains in suspension can
contain a higher percentage of any toxicants.

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                                      -5-
     The Agency maintains  that field experiments to validate model predictions
 of particle  transport  and  deposition during and after ocean disposal of drecfeed
 materials have been performed, but we were not supplied with the documentation.
 For ocean disposal  of  sewage sludges, however, adequate validation data do not
 exist.   Therefore,  predictions of transport, persistence, dilution, and biological
 impact  of these sludges are rmieh more uncertain.

     There are components  of sewage sludge which mav not remain in sitspension
 and may thus be more appropriately dealt with using the testing procedures
 Which would  normally be considered raore appropriate for 'dredged materials.
 This aspect  should  be  given serious consideration in the Agency's deeisionmaking
 on testing requirements for sewage sludge and dredged materials, as well as the
 Agency's research efforts*

     Although  tbe Corpittee agrees that ttost dredged materials are substantially
 different from sewage  sludge, it is clear that exceptions do exist.  These
 exceptions could result in off-site impacts which could be significant.
 Therefore, it  is crucial that clearly defined, consistent:. rigorous (peer-reviewed)
 testing procedures  for ide^tj^tr^these^ exceptions should be available _b_e_fore~ .....
 anychanges  to .the  oc^ean^l.np~regulatior>srare             "
     It concerns  the ftoutnittee that there is a lack of information in the
document on the procedures to be used to evaluate the toxieity of dredged
'materials.. It is  important  to provider comparision of . the dredged material
toxicity procedures with those for sewage sludge, with particular emphasis on the
relative rigor of the  two methods.  The Coranittee questions how effective the
evaluation procedure is for  identifying dredged materials which contain toxic
substances.  A diagram of the decision trees used for these evaluations (that
is,  identifying dredged materials not excluded from testing under Part 227.13)
should be incorporated.  It  should be consistent with other environmental
risk assessment evaluations  in the Agency.  A testing procedure is needed to
classify material  from any source to determine which disposal procedures are
appropriate.  A simple, but  adequate, set of tests raav be sufficient to permit
a  relatively large fraction  of dredged material to be treated separately .from
sewage sludge, but the burden is on the Asencv to taake such a case conclusively,

     Finally, the  Corwittee  finds a lack of supporting data and primary references
in the document.   The  conclusions are not adequately supported by the data
presented in the doctnent.   The Committee believes that a technical basis for
identifying which  dredged materials require special handline and disposal may
well exist, or could be developed.  The (VEP document , however, does not present
a  convincing argment  to justify separate testing in all cases.


     B.  Specific  Cgtnments


         1.  Pages 1 and ?.t  Executive Summary (and Paee 42) —  The technique
used to determine  particle size distribution (PSD) should be clearly identified.
Were inaterial samples  for PSD determination dispersed or not?  uependtag on
whetber dispersed  or non-dispersed samples are used, the PSH can be quite
different.  Dispersed, PSBs yield data on primary particles, whereas non-dispersed
PSDs Indicate bow the  material actually behaves in' the environment.  If the
dredged materials  consist of cohesive Tuaterials, organic material, or small
and  large acHregates,  chemically oxidizing and chemically dispersing the sartple

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                                      -6-


produces substantial changes in the sample as compared to the actual material
as encountered In the real vrorld environment.  For example, if there is a high
clay content and high enough electrolyte concentrations»  there may be enough
flocculation in a nondispersed sample to create zone settling,  A PSD determination
hased on this behavior indicates no particles smaller than, say, approximately
20 to 30 microns.  If the same sample is chemically dispersed using common
engineering property soil testing procedures, results way indicate, say> 20%
clav-size (diameters less than or equal to four microns)  primary particles.
These differences are important because they indicate whether the fines will
remain in suspension to he transported off site in the "water column or settle
to the bottom in the dump area,

       2.  Page 3, line 5 (and Page 43, Table VI)  — References to "silt."
Are these primary particles in the 4-62 micron range or aggregates? Are these
data from dispersed or nondispersed PPDs?

       3.  Page 3, middle (and Page 4Q) — Reference to dredged material rapidly
affecting the sea floor.  The fate of material depends on how the material is
introduced.  This discussion should cite options such as pimping overboard,
bottom dumping, discharge from a pipeline, and in-chaonel spoiling.  There are
various ways a material can be released into the tracer column, and this makes
a big difference in the amount of water entrained in the plufflef concentrations,
and sedimentation characteristics.  This should be acknowledged, instead of
giving'the impression that dredged material simply drops to the bottom inside
the designated disposal area just because it is "dredged "material."

       4.  Page 4 (and Paees 14-18) — The discussion does not acknowledge
that there are different types of sewage sludges with different characteristics,
e.s. raw primary sludge and digested sludge.

       5,  Page 4, bottom 2 lines -- "Sludge behaves as a liquid." If it is  95-
Q8% water and released so as to provide or facilitate mixing, densitv could be
close to that of seawater.  This could also be true for many dredged materials
if a high-mixing release is used.  Op the other hand, if sludge is jetted down
or pumped down in a way to minimize entrainment or dilution, it is not likely
that sludge would behave like seawater — nor wauld the fines in dredged material,
if similarly letted or pumped.  Dredged material and sewage sludge do not
necessarily behave totally differently sitnplv hecause one is labeled as "sewage
sludge" and one is called "dredged material."

       6*  Page 7, Overview —  The discussior should explicitly state what "act"
is being referred to.

       7,  Pages 11 and 12 ~ We recommend that detailed" explanation of what is
entailed in each box be presented, with particular attention given to the
criteria on which the decisions are made.

       P.  Page 13, last part of top paragraph — The argument concerning
procedures for a "buoyant water-soluble liquid waste" and a "weighted
containerized waste" was not clear.  Were the last two sentences in this top
paragraph intended to provide a comparison to illustrate sewage sludge versus
dredged material?

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                                      -7-


       9.  Page 14, reference and first paragraph — There seem to be considerable
references to the NRC 1977 report.  There are more recent works (such as the EPA
"40 City Study" 13]) which may be more pertinent with respect to anthropogenic
chemicals.

      10.  Page 14, paragraph 2, first sentence — Seme of the particulate solids
that could result from a typical wastewater treatment plant could well consist
of grit chamber solids.  These would probably contain a great deal of inorganic
material and aggregate part iciest-containing organic material—which could
settle rapidly.

      11.  Page 19, paragraph 1 — The particle size range of 5-50 microns would
likely include particles well up into the coarse silt range,  while those in the
lower particle size range wculd tend to settle rather slowly, those at the upper
end could settle reasonably well.  This a too large a range to make general
conclusions about settling characteristics.

      12.  Page 20, first sentence of first full paragraph — The statement "The
results of these studies indicate that ,,," is not compelling to the Committee,

      13,  Page 2QJ Paragraph 2 — The bottom sediments near a sewage outfall
sometimes contain a very high organic load, presumably from sewage particulate
matter.  These solids are similar, if not identical, to sewage sludge, and they
certainly have deposited.  Therefore, they should deposit in the ocean disposal
environment.

      14,  Page 24, Table III — "Environmental Effects," third item; This may
render them unfit for human consumption.  Such an economic impact could be far
reaching and should be considered in the reports.

      15, Page 24, Table III —- The far right column corresponding to "metals"
seems to be incomplete'.

     16.  Pages 24 and 25, last two lines on page 24 and renteinder of sentence
at top of page 25 —  The Committee agrees that, where the concentrations are
quite high after dumping, coagulation can be effective and large aggregates can
form and settle.   This indicates the Importance of being very specific about the
schemes used to introduce materials—whether they be dredged materials or sewage
sludges—into the ocean environment.  This is poorly treated in the document,
and therefore the Committee is unable to determine the conditions under which
coagulation might or might not take place in typical real-world situations.

     17.  Page 25f Paragraph 2 —» Again, for low concentration wastes and/or
conditions of high initial dilution, it is not clear that coagulation will
occur.

     18. Page 27, Paragraph 2 — This argument is logical as far as it goes.
Low-level contamination over long periods of time can also have damaging
impacts.

     19. Page 29, Paragraph 1 — BAccumulation and/or biomagnif ication may
render the biota not fit for human consuisption, for example contamination
of the James River with Keporte.

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                                      -R-


     20.  Page 36, Paragraph 3, Line 9 — add "turbidity maximum in estuaries."

     21.  Page 40, Paragraph 2, Lines 5/6 — This can he very site specific,

     22.  Page 49 and Page 50, Figure IX — The document must improve its
'treatment of methods used to introduce dredged materials and sewage sludges
into the marine environment.  The statement "The discharge of materials from  a
hopper or scow...." provides inadequate information on the type of jet created
and how much entrainment of ambient water will he caused.  This makes a great
deal of difference and is inadequately treated in this report.

     23.  Page 52, Paragraph 3 - Many polar organic compounds (such as Kepone)
associate with sedtaent.  Perhaps "hydrophobic organic compounds" wwld
he hetter wording.

     24,  Page 56, Paragraph 1, Lines R-1Q — It is important to note that in the
cases where sediments are contaminated with numerous toxicants, it is often not
possihle to distinguish the independent variable(s).  This is particularly
true when only a preselected set of substances are analyzed.

     ?5.  Page 57, Paragraph 1, Lines 12-15 — The Committee agrees with
this statement.

     26,  Page !W, section VII — The Committee is very uncomfortable with the
material that leads to conclusions numbers 5 and 7.  In number 5, it is stated
that "water column impacts associated with ocean disposal of dredged material
are short-termed, and predictable."  Item 7 deals with fine-grained sediments
containing anthropogenic contaminants.  The fine-grained material can cause
problems in the water column.  Conclusion 7 aoes on to state that this "nay have
long-term adverse effects on the marine environment which, at the present, are
largely unknown," The Committee does not agree that the water column impacts,
particularly for fine-grained materials, are "short-term" and predictable.  In
addition, the Committee is troubled by the existence of "long-term" effects
which are presently acknowledged as being "largely unknown,"

     27.  Page 60 — Various items that deal with guidance on whether dredged
Tnaterial might pose an environmental or water quality problem are somewhat trouble-
some.  There is frequent reference to the composition being "predominantly" one
thine or another and "substantially" one thins or another.  Relatively small
concentrations and small masses of damaging or highly toxic materials are
potentially very significant.  The document must explicitly define the terms
"substantially," "predominantly," and "mostly,"

     28, Page 60 -- There is also a good hit of emphasis on the "history" of
the material that is being dredged.  The Committee cannot support decisionmaking
that potentially relies only on understanding the history and sources of the
material that is being dredged and considered for ocean disposal.  The Committee
recommends more rigor in evaluating the composition of a material as part of
making sound decisions on proper disposal methods.

     29, Page fifl — The remittee suggests that more specific information be
provided about how the "history" of the dredged material wuld be evaluated or
documented and how this leads to a defensible decision that no substantial
chemical or biological evaluation is warranted.  Potentially significant decisions
should not be made without clear, adequate, and scientifically sound guidance.

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     30.  Page 62, Paragraph 1, Line 11 — It is very likely that if one did
a broad spectrum tissue analysis, something would always differ by 10%*

     31.  Page 62, Paragraph 2, Lines 1-5 — This may be generally true,
but certainly with numerous exceptions, such as larval fish.

     32.  Page 63, Paragraph 1 — The Ccnmittee agrees with this statement.

     33.  Page 64, Conclusion 8 — Chemical analyses should be required for
fine-grained sediments from non-pristine environments, and decisions to dispose
of these materials should be based on logic similar to that in Conclusion 7.


     C. Corrections

          1,  Page 17f Table II — Two significant figures, at roost, are all
that ate warranted.

          2.  Page 38, Table IV — Provide units for chemical oxygen demand.

          3.  Page 43, Table VI — It appears that a radical sign has been
omitted frcra the captions.

          4.  Page 44, Figure 5— Is 10"2 correct?

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                                      -10-
                                                          APPENDIX A
                    n.s. FiwtHONMENiAL PROTECTION AGENCY
                    ENVIROW-fENTAL ENGINES ING CCWITTEE
                           SCIENCE ADVISORY BOARD

            CnWITTEE ID REVIEW REGULATIONS ON OCEAN DUMPING AND
                    REUSE ATO DISPOSAL OF SEWAGE SLUDGE
                                                Membership on Subgroup(s)
Dr. Raymond C» Ijoehr (Chairman)
Civil Engineering Department
University of Texas
Austin, TX  7ft712
Landfilling
Dr. Larry U, Canter *
Professor of Civil Engineering and
  Environmental Science
University of Oklahoma
20fi Felear Street, Roont 177
Norman., OK- 73019

Mr, Richard A. Conway
Corporate Development Fellow
Union Carbide Corporation
P. 0. -WOK «361 (770/342)
South Charleston, W  25303

Mr. Allen C"pji^ **
Consultant
1126 Arc turns lane
Alexandria, VA  2230«

Dr* Benjamin C. Dysart, III
Environmental Svstens Engineering Department
Clernson Tiniversitv
Clemson, 55C
Overall Risk Assessment
Land Application
Incineration
Incineration
Overall Risk Assessment
Dr. Pen B.
Professor of Environmental Studies
Institute for Environmental Studies
University of Illinois
40« R. Goodwin
Urbana, IL  61801

Dr. Davis I., Ford
Davis I,. Ford and Associates
7901 N. Interregional
Austin, TX  7A722
landfillins  (Chair)
Ocean Disposal
Notes;
        * - Member, Environmental Advisory Board, Corps of Engineers
       ** - Consultant to the Environmental Engineering Committee

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                                      -11-
Mr. fieorge Green                                  Incineration
Public Service Company of Colorado
Manager Production Services
1800 W Sheri I^ane
Littleton, HO  SO 120
Mr. Clair P. Aiess, Jr. *                         Dredged Material
Consultant
P.O. Box 156
Denmark, SC 29042

Dr. Rolf Harding ***                              Overall Risk Assessment-
School of Puhlic Health
iTniversity of Michigan
Ann Arbor, MI  48109

Dr. J» Will Ian Haun                               Tsndfilling
13011 Ridgedale Drive
Suite 343
Minnetonka, W  55343      .           .                    -               -

Dr. florae M. Wld?               '                 Incineration
President
Desert Research Institute
P.O. pox 60220
      1W  89506
Dr, Robert Huseett ***                            Dcedaed Material (nbair)
College of William and Mary
Chairman, Department of
  Chemical Oceanography
Virginia Institute of Marine Sciences
nloucester Point, VA  2306?,

Dr. Kenneth D. Jenkins ***                        Dredged _Haterial
Professor of Biology                              ficean Disposal
California State University at T^ona Beach
     Beach, CA
Dr. Joseph T. Ling
3M Company
3M Coroninity Service Executive Program
Build ins 521-11-01
St. Paul, W  35144

Dr. Hecil Ine-Hine **                             Land Application
Director for Research and Development
Metropolitan Sanitary District of
   Greater Chicago
100 East Erie Street
Chicago, IL  fiOfill
Notes;
        * - Member, Environmental Advisors Board, Corps of Engineers
       ** - Consultant to the Environmental fhgineerine Committee

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                                   -12-
Dr. Donald J» O'Connor
Professor of Environmental Engineering
Environmental Engineering Science
Manhattan College
Manhattan College Parkway
%onx, MY  10471

Dr. Charles w. O'Melia
Professor of Environmental Engineering
Department of Geography and Environmental
  Engineering
The Johns Fopkins University
Baltimore, HD  2121B

Dr. Albert Page **
Department of Soil & Environmental Sciences
University of California
Riverside, CA- 92521

Dr. Mitchell Small
Department of Civil f^ngineering
Carnegie-Mellon University
Schenley Park
Pittsburgh, PA  15213

Dr. Evan Vlachos *
Colorado State University
Department of Sociology
Fort Collins, CO  g0523

Dr. Bernard Weiss ****
Division of Toxicology
University of Rochester School of Medicine
Rochester, NY  14642
Ocean Disposal (Chair)
Dredged Material
Dredged Material
Ocean Disposal
Land Application (Chair)
Landfilline
Land Application
Overall Kisk Assessment (Chair)
Overall Risk Assessment
                           Executive Secretary
Mr. Harry C* Torno (until 9/86)
Executive Secretary, ESC
Science Advisory Board (A-101 F)
U.S. Environmental Protection Agency
Washington, D.C.  ?0460
Mr. Rric Hales (from 9/86)
Executive Secretary, EEC
Science Advisory Board (A-101 F)
U.S. Environmental T^roteetion Agencv
Washington, D.C.  20460
Notes:
        * - Member, Environmental Advisory Board, Corps of Engineers
       ** - Consultant to the Environmental Engineering Committee
     **** _ Member, Environmental Health Committee, SAB

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                                      -13-
                                                        APPENDIX B
                     Environmental Engineering Committee
                            Science advisory Boazd
                     D.S. Environmental Protection Agency
             REVIEW OF TECHNICAL MATERIAL SUPPORTING REVISIONS TO
                  PORTIONS OF EPA OCEAN DUMPING REGULATIONS
              RELATING TO THE OCEAN DISPOSAL OP DRffiXSD MITEMMS

                           Charge to the Committee
To review ard aSvige the Office of Marine and Estuarine Protection (QMEP) on
the overall technical and scientific validity of the OMSP justification for ,
separate treatnent of sewage sludge and dredged naterials under the EPA Ocean
Dumping Regulations, with particular attention to

     1. How can technically sound equal consideration and weight be given
        throughout the permitting process to potential effects of ocean,
        estuarine, and land disposal alternatives in evaluative efforts?

     2. Is it technically sound to use different tests to provide equally
        rigorous evaluation of the potential environmental impacts of dredged
        material and other material discharged to the oceans?

     3. Are there technical reasons the ocean dumping regulations should not
        have a completely separate and "stand alone*1 regulation that treats
        dredged material differently from other materials proposed for ocean
        disposal?

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 1
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                                                                             APPJPDIX C
                                           'REFERENCES
              "TYedged Material Disposal, Draft Technical Support Doctjment for
               Revision of che 1977 Ocean Bumping Regulations and Criteria,
               40 CM ,220-228," O.S. Arm? Corps of Engineers, Waterways Experiment
               Station, Vicksburg, Miss., February 15,
           2, "Sewage Sludge and Dredged Material; Justification for Separate
               Treatment under the FJPA Ocean Dumping Peculations based on Differ-
               ences in Intrinsic Properties and Behavior in the Marine Rnviron-
               raent (Draft)," U. S. Environraental Protection Agencv, Office of Marine
               and Estuarine Protection, Washington, D.C. „ July, 1986.

           3.  "Fate of Priority Pollutants in Publicly Owned Treatment Works -
                Final Report," (EPA 440/1 -8?, -303) Volumes 1,2, IT.S. Environmental
                Protection Agency, Washington, DC, September, 1982.

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