Proceedings of the EPA's contaminated sediment management strategy forums

[From the U.S. Government Printing Office, www.gpo.gov]

United States Office of Water EPA 823-R-92-00T,
Environmental Protection (WH - 556) September 1992
Agency
4`01, EPA Proceedings of the
EPA's Contaminated
Sediment Management
Strategy Forums

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PROCEEDINGS OF EPAqS
CONTAMINATED SEDIMENT MANAGEMENT STRATEGY FORUMS

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U - S - DEPARTMENT OF COMMERCE NOAA
COASTAL SERVICES CENTER
2234 SOUTH HOBSON AVENUE
CHARLESTON , SC 29405-2413

19927
THE YEAR OF
CLEAN WATER Office of Water
Office of Science and Technology
Standards and Applied Science Division
U.S. Environmental Protection Agency
Washington, DC 20460

k-1 September 1992

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This document is based entirely on presentations at three public forums sponsored by
the U.S. Environmental Protection Agency (EPA) to solicit input on its proposed Contaminated
Sediment Management Strategy. The views expressed by individual presenters are their own
and do not necessarily reflect those of EPA. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ................................................ 1

CHAPTER ONE INTRODUCTION ..................................... 9

1.1 Sediment Contamination in the United States ...................... 9
1.2 Development of a Strategy for Managing Contaminated
Sediments ................................................ 9
1.3 Public Review of EPA's Contaminated Sediment
Management Strategy ....................................... 14
1.4 References ............................................... 15

CHAPTER TWO THE EXTENT AND SEVERITY OF CONTAMINATED
SEDIMENTS ........................................ 17

2.1 Introduction .............................................. 17
2.1.1 Welcome ........................................ 17
2.2.2 EPA's Understanding of the Extent and
Severity of Contaminated Sediments .................... 18
2.2 Presentation Summaries ..................................... 19
2.2.1 Extent of Sediment Contamination ..................... 19
2.2.2 Severity of Contaminated Sediments
Human Health Effects .............................. 38
2.2.3 Severity of Contaminated Sediments
Ecological Effects .................................. 63
2.3 Summary of Comments and Discussions ......................... 75
2.3.1 Comments on Draft Outline of EPA's Contaminated
Sediment Management Strategy ....................... 75
2.3.2 Definition of Contaminated Sediment ................... 76
2.3.3 Extent of Contamination ............................ 76
2.3.4 Severity of Contamination ........................... 77
2.3.5 Sediment Criteria .................................. 78
2.3.6 Research Needs ................................... 78
2.4 References ............................................... 79

CHAPTER THREE BUILDING ALLIANCES AMONG FEDERAL, STATE AND
LOCAL AGENCIES TO ADDRESS THE NATIONAL PROBLEM
OF CONTAMINATED SEDIMENTS ...................... 81

3.1 Introduction .............................................. 81
3.2 Assessment .............................................. 82
3.2.1 EPXs Proposed Assessment Strategy ................... 82
3.2.2 Federal and State Agency Assessment Programs ........... 83

TABLE OF CONTENTS (cont.)

Page

3.2.3 Formal Public Comment: Randall Ransom,
Chemical Manufacturers Association (CMA) ............. 88
3.2.4 Open Discussion .................................. 89
3.3 Preventing Sediment Contamination ............................ 91
3.3.1 EPA's Proposed Prevention Strategy .................... 91
3.3.2 Federal and State Agency Prevention Programs ........... 93
3.3.3 Open Discussion .................................. 97
3.4 Remediation of Contaminated Sediments ........................ 99
3.4.1 EPA!s Proposed Remediation Strategy .................. 99
3.4.2 Federal and State Agency Remediation Programs .......... 101
3.4.3 Formal Public Comment: Ellen Fisher,
Wisconsin Department of Transportation ................ 105
3.4.4 Open Discussion .................................. 106
3.5 EPA Response to Forum Recommendations ...................... 107
3.5.1 Assessment ...................................... 107
3.5.2 Prevention ....................................... 108
3.5.3 Remediation ..................................... 108

CHAPTER FOUR OUTREACH AND PUBLIC AWARENESS .................. 109

4.1 Introduction .............................................. 109
4.1.1 Welcome ........................................ 109
4.1.2 Forum Overview .................................. 110
4.1.3 EPA!s Proposed Outreach Activities to
Support Implementation of EPA's Contaminated
Sediment Management Strategy ....................... 110
4.1.4 Questions on EPA!s Proposed Outreach Activities ......... 111
4.2 Presentation Summaries ....................... I ............... 112
4.2.1 State Government ................................. 112
4.2.2 Regulated Community .............................. 117
4.2.3 Environmental Advocacy Groups ...................... 121
4.2.4 Public Awareness Group ............................ 125
4.2.5 National Environmental Education Act .................. 128
4.3 EPA Summary of Comments and Discussions on Outreach
and Public Awareness Themes ................................ 129
4.3.1 Citizen's Advisory Group ............................ 129
4.3.2 Types of Outreach Materials ......................... 130
4.3.3 Content of Outreach Information ...................... 130
4.3.4 Information Dissemination ........................... 130
4.3.5 Risk Communication ............................... 130

TABLE OF CONTENTS (cont.)

Page

APPENDIX A EPA'S CONTAMINATED SEDIMENT STRATEGY
STRATEGY DRAFT OUTLINE ............................... 131

APPENDIX B PROPOSED ACTIVITIES TO SUPPORT
IMPLEMENTATION OF EPAS CONTAMINATED
SEDIMENT MANAGEMENT STRATEGY ....................... 163

APPENDIX C AGENDAS OF THREE FORUMS ON EPAIS
CONTAMINATED SEDIMENT MANAGEMENT STRATEGY ........ 175

APPENDIX D FORUM SPEAKERS ....................................... 187

APPENDIX E FORUM ATTENDEES ...................................... 195

EXECUTIVE SUMMARY

INTRODUCTION

On March 5, 1992, the U.S. Environmental Protection Agency (EPA) distributed a draft
outline of EPA's Contaminated Sediment Management Strategy to government agencies, industry,
consulting firms, law firms, environmental groups, and academia as a proposal for discussion. With
the transmittal of the draft discussion document, EPA solicited written public comment and issued
an invitation to attend three public forums to discuss the draft.

This document summarizes the proceedings of these EPA-sponsored forums. Each forum
addressed a particular issue related to development of the Contaminated Sediment Management
Strategy. The three forums were:

0 The Extent and Severity of Contaminated Sediments, held April 21-22, 1992, in
Chicago, IL

0 Building Alliances Among Federal, State, and Local Agencies to Address the
Problem of Contaminated Sediments, held May 27-28, 1992, in Washington, DC

E Outreach and Public Awareness, held June 16, 1992, in Washington, DC

FORUM 1: THE EXTENT AND SEVERITY OF CONTAMINATED SEDIMENTS

This forum consisted of panel discussions on three topics of concern: (1) the extent of
sediment contamination, (2) the severity of contamination with respect to human health effects, and
(3) the severity of contamination with respect to ecological effects. Forum participants concluded
that (1) contaminated sediments are a national problem, and (2) human health problems and
ecological harm have been documented at a number of contaminated sediment sites.

Extent of Sediment Contamination

Representatives of several federal agencies involved in tracking the condition of sediments
in the United States presented evidence of sediment contamination in particular geographic regions.
The presentations suggest that sediment contamination is a widespread problem with toxic hot spots
occurring in many areas across the United States.

Thomas O'Connor, of the National Oceanographic and Atmospheric Administration
(NOAA), summarized the results of sampling at 280 sites nationwide; these samples indicate that
contamination is most severe near densely populated urban areas. Richard Latimer, of EPA's
Monitoring and Assessment Program, reported elevated concentrations of metals and organic
chemicals in several areas along the mid-Atlantic coast. In his presentation, Steve Garbaciak, of
the Great Lakes National Program Office, described results of that office's research which identified
42 areas in the Great Lakes where sediments contain elevated levels of cadmium, copper, mercury,
PAHs, and PCBs. Charles R. Lee reported findings of the U.S. Army Corps of Engineers (COE),
estimating that 12 million of the 400 million cubic yards of sediments dredged each year from the

nation's waterways were contaminated. According to data presented by Frank Manheim, of the
U.S. Geological Survey (USGS), 50 percent of 1,300 sediment samples drawn from Boston Harbor
from 1962 to 1990 contained levels of copper, zinc, lead, chromium, nickel, and mercury above
those commonly associated with adverse biological effects. In his presentation, Richard Cahill, of
the Illinois State Geological Survey, explained how cesium-137 could be used to determine when
sediment contamination has occurred.

Panelists agreed that existing data on the extent of sediment contamination are
decentralized. They supported the development of a national inventory of contaminated sites based
on site chemistry, health effects, and intended uses. For this purpose, existing data from diverse
sources must be compiled and subjected to rigorous quality assurance procedures.

Severity of Contamination-Human Health Effects

Evidence presented by this panel suggests that direct or indirect exposure to contaminants
in sediments can adversely affect human health. Since human exposur 'e to sediment contamination
is typically too low to result in acute or observable toxicity, the severity of human health effects is
often expressed as estimates of increased cancer incidence, reproductive or developmental toxicity,
or neurotoxicity.

The consumption of seafood contaminated through bioaccumulation from sediments is a
major concern, but the effects of chronic exposure to contaminants from seafood have been poorly
documented. Gerald Pollock, of the California EPA, reported that estimated excess lifetime cancer
risks from consumption of seafood in areas of high contamination range from below 1 in 100,000
to as high as 2 to 5 per 1,000. Nancy Ridley, of the Massachusetts Department of Public Health,
noted that the greatest human health risks come from consumption of large quantities of raw
shellfish; consumption of typical amounts of seafood may not pose a significant threat to human
health. Wayland Swain, of Eco Logic International, Inc., presented studies correlating consumption
of contaminated seafood with higher body burdens of PCBs in both male and female adults and
increased levels of PCBs in the whole serum and breast milk of highly exposed mothers. Mr. Swain
also noted that infants born to highly exposed mothers have had lower birth weights, reduced
gestational ages, and smaller head circumferences, and have exhibited neuro-motor effects.

Little research has been done on the health risks associated with dermal contact and
incidental ingestion of contaminants from sediment. William Alsop, of ENSR Consulting and
Engineering, presented case studies from seven Superfund sites which suggest that health risks from
these forms of exposure are minimal compared to risks from consumption of contaminated seafood.

Severity of Contamination-Ecological Effects

Panelists presented studies associating elevated concentrations of metals and organic
chemicals in sediment with elevated tissue burdens of these pollutants in aquatic organisms. Such
burdens can produce a variety of effects.

Robert C. Hale, of the Virginia Institute of Marine Science, presented studies conducted
in the Elizabeth River, a subestuary of the Chesapeake Bay, linking sediment contamination to
increased frequency and intensity of neoplasms, cataracts, enzyme induction, "finrot", and other
lesions in fish populations. According to Paul Baumann, of the U.S. Fish and Wildlife Service

(FWS), over the last 15 years, concentrations of PAHs in sediments have correlated with elevated
tumor frequencies in six species of fish at 16 locations across the country. Barry Vittor, of Vittor
& Associates, Inc., reported documented decreases in the abundance and variety of benthic species
as a result of sediment contamination and sedimentation in the Gulf of Mexico.

Assessing ecological effects is more difficult than delineating the extent of sediment
contamination, because important effects manifest themselves in ways that are often difficult to
detect. Peter Chapman, of EVS Environment Consultants, suggested that integrated
assessments--encompassing toxicity tests, sediment chemical analyses, tissue chemical analyses,
pathological studies, and community structure studies-are necessary to appraise an ecosystem's
status.

FORUM 2: BUILDING ALLIANCES AMONG FEDERAL, STATE, AND LOCAL AGENCIES TO
ADDRESS THE PROBLEM OF CONTAMINATED SEDIMENTS

This forum was conducted in three parts corresponding to three elements of the
Contaminated Sediment Management Strategy: (1) assessment, (2) prevention, and (3) remediation.
Forum participants concluded that (1) EPA should expedite implementation of the Strategy; (2)
development of a contaminated sediment inventory is a high priority need for which all agencies
want to provide data; (3) more attention should be paid to nonpoint sources in the Strategy; (4)
the addition of sediment toxicity and bioaccumulation tests to chemical registration under the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Toxic Substances Control Act
(TSCA) is a high priority need to prevent point and nonpoint source contamination of sediments;
and (5) consideration should be given to developing an integrated federal agency strategy on
contaminated sediments.

Assessment

Panelists from several state and federal agencies involved in assessing sediment
contamination described their activities and made recommendations for EPA's assessment strategy.
In addition, an industry representative expressed a perspective from the private sector.

Betsy Southerland, of EPA, summarized the proposed assessment strategy, which calls for
the development of a national inventory of contaminated sediment sites and sources, the use of
consistent biological and chemical tests for evaluating sediments, and increased monitoring of
sediment conditions. Gail Mallard outlined several USGS programs currently studying physical
properties of sediments, fate and transport mechanisms, rates of sedimentation, sediment grain size,
and fish uptake of sediment contaminants. She suggested that USGS and EPA coordinate their
efforts to develop a national inventory of contaminated sites. Representatives of COE, David
Moore and Joseph Wilson, described COE's dredging activities and recommended a biological
effects-based, tiered testing approach to sediment assessment. Andrew Robertson, of NOAA,
described his program's "mussel watch" and "benthic surveillance" assessment measures as well as
historical core sampling assessment measures. Donald Steffeck described FWS's joint efforts with
COE and EPA to manage contaminated sediments and FWS's new techniques for evaluating
bioaccumulation. Fred Calder, of the Florida Department of Environmental Regulation,
recommended Florida's "weight-of-evidence" approach to sediment assessment, involving a large
data base of biological effects from 25 priority contaminants. In a formal public comment, Randall
Ransom, of the Chemical Manufacturer's Association (CMA), expressed CMA's belief that

sediment contamination is a local hot spot problem, not a national problem, and that contamination
should be assessed in terms of human health risks, not numerical chemical criteria.

Panelists identified assessment of contaminated sites as an area in which EPXs Strategy
needs clearer direction. The Strategy must define contaminated sediments more precisely, focus
more attention on nonpoint source contamination, identify and promulgate consistent QA/QC
protocols for sediment sampling and bioeffects testing, actively encourage coordination with state
agencies, and propose mechanisms for effective use of assessment data to support sediment
management programs. Panelists were divided on two issues: (1) whether the Strategy should
encourage an effects-based assessment approach or the development of numerical sediment quality
criteria, and (2) whether the Strategy should specify uniform effects-based testing methods or call
for different but comparable effects-based testing methods.

Prevention

Representatives of several state and federal agencies responsible for the prevention of
sediment contamination discussed their activities and made recommendations for EPA's prevention
strategy.

Judith Nelson, Stuart Tuller, and James Pendergast outlined EPA's efforts to control point
and nonpoint sources of sediment contamination. David Farrell, of the U.S. Department of
Agriculture (USDA), described USDA's program to monitor the distribution, accumulation, and
dissipation of agricultural chemicals over time. The Forest Service's attempts to minimize the
impact of land management practices on water and sediment quality in the National Forests were
described by Warren Harper, also of USDA. In his presentation, James Burgess described NOAA
and EPA's Coastal Zone Management Program, the only program that has enforcement authority
to control nonpoint source pollution. Duane Schuettpelz, of the Wisconsin Department of Natural
Resources, presented Wisconsin's Sediment Assessment and Remediation Techniques program,
which is currently conducting a statewide inventory of contaminated sediments. This program
applies sediment quality criteria developed by the state to clean up some Superfund sites, and has
an active pollution prevention component. Craig Wilson, of the California State Water Resources
Control Board, pointed to similarities between California's Bay Protection and Toxic Cleanup
Program and EPA's Strategy, and commended EPA for developing a strong, coherent approach to
prevention of sediment contamination.

Echoing many of the concerns expressed by the panel on assessment, the panel on
prevention urged EPA to clarify several aspects of the Strategy. Panelists called for the Strategy
to state clearly how sediment quality criteria will be used, include stronger provisions for prevention
of nonpoint source contamination, and identify ways to improve coordination between state and
federal agencies. In addition, panelists urged EPA to avoid overreliance on models and recognize
the value of case study approaches to understanding contaminated sediments. Some panelists
pointed out that sediments may act as a natural sink for trapping contaminants and rendering them
unavailable to other environmental media over time. However, recycling of contaminants from
sediment biota, surface water, and ground water can occur at varying rates depending on chemical
and biological processes.

Remediation

Panelists representing several state and federal organizations currently managing
contaminated sediments described their remediation activities and provided recommendations for
EPA's remediation strategy.

Richard Nagle, Lawrence Zaragoza, Denise Keehner, and Tony Baney outlined EPA's
authority to remediate contaminated sediments under the Clean Water Act; the Clean Air Act; the
Comprehesive Environmental Response, Compensation, and Recovery Act; the Resource
Conservation and Recovery Act; the Toxic Substances Control Act; the Rivers and Harbors Act;
and the Oil Pollution Act. Bruce Kimmel spoke about the Department of Energy's (DOE's)
"federal facility agreements" with several states and with EPA to coordinate remedial actions at
DOE facilities nationwide. Joe Wilson and Norman Francingues outlined several COE research
projects aimed at gamering a better understanding of dredging, disposal, and treatment technologies
for contaminated sediments. The State of Washington's sediment management strategy, which has
established narrative, chemical, and biological criteria for use in remedial actions, was described by
Keith Phillips, Washington Department of Ecology. Ellen Fisher, of the Wisconsin Department of
Transportation, indicated that sediment contamination currently threatens the viability of
Wisconsin's harbors and that disposal capacity is dwindling.

Participants recommended that contaminated sediment remediation must be linked to
human health protection and ecological risk reduction. Some cautioned, however, that risk
assessment analyses that are too conservative can paralyze remedial actions programs, and lead to
high costs with little marginal benefit. Therefore, the Strategy should support the use of more
liberal risk assessments.

Panelists also pointed out that liability issues have prevented cleanup at a number of sites.
The Strategy should address liability issues to facilitate more timely remedial actions. In addition,
the Strategy should provide guidance on specific issues related to managing contaminated
sediments. These include remediation of oil spills, disposal of contaminated dredged material,
aquatic construction and maintenance activities, management of sediments contaminated by
stormwater discharges and other nonpoint sources, and the use of natural recovery options.

FORUM 3: OUTREACH AND PUBLIC AWARENESS

This forum provided recommendations for effective public outreach from four perspectives:
(1) state government, (2) the regulated community, (3) environmental advocacy groups, and (4) a
public awareness group. There was a consensus among the groups participating in the forum that
EPA should get the public involved as early as possible, clearly indicate how long cleanup will take,
convey complete information without skimping on details, and communicate the health risks
associated with sediment contamination in terms analogous to comparable risks that the public can
understand. Whenever possible, EPA should link the contaminated sediment issue to visible effects,
such as beach closings and seafood consumption advisories. Since cleanup will probably take a long
time, EPA must articulate and remain accountable to short-term goals and celebrate interim
successes while working toward long-term restoration. Above all, EPA must engage in active
dialogue with the public and be responsive to public concerns.

State Government

David O'Malley, of the Wisconsin Department of Natural Resources, outlined how
Wisconsin's Remedial Action Plans (RAPs) successfully foster public involvement. Based on his
experience with RAPs, Mr. O'Malley recommended that EPA utilize existing state networks for
public involvement and information dissemination, and allow states flexibility in adapting the
strategy to local situations.

The Regulated Community

Dick Schwer, of E.I. DuPont Company, and Donna Tomlinson, of Eastman Chemical
Company, represented the Chemical Manufacturers Association (CMA) in this presentation. Ms.
Tomlinson described CMA's Responsible Care Program, an industry outreach initiative to improve
performance, health and safety, and environmental quality. Mr. Schwer reiterated CMA's belief
that sediment contamination is a local hot spot problem, not a national problem. He critiqued the
proposed Strategy, strongly urging EPA to subject all data and conclusions about sediment
contamination to rigorous review and to define contaminated sediments with respect to human
health and ecological risk, not numerical chemical criteria.

Environmental Advocacy Groups

Glenda Daniel, of the Lake Michigan Federation, suggested that current public outreach
efforts are inadequate. Beth Milleman, of the Coast Alliance, indicated that the public lacks
confidence that EPA has a rational, defensible program to manage contaminated sediments. Both
panelists recommended that EPA take advantage of existing communication networks, such as
conventions of environmental groups or labor unions, to present information on contaminated
sediments; establish face-to-face contact whenever possible through meetings, workshops, or
conferences; and develop more engaging written and graphic information, particularly when
introducing the subject of contaminated sediments to nontechnical audiences.

Public Awareness Group

Frances Flanigan, of the Alliance for the Chesapeake Bay, described her organization's
successful campaign to raise public consciousness of pollution in Chesapeake Bay. Based on this
experience, Ms. Flanigan advised EPA to make sure outreach efforts address the specific needs of
various target audiences, to design materials to foster participation in effective policy making, to
build consensus among conflicting interests, and to develop a framework of institutions that will be
self-sustaining and carry the work of sediment management into the future.

PROCEEDINGS FORMAT

This proceedings document summarizes the presentations at the three forums and captures
the highlights of comments, questions, and input from the participants. Chapter One describes the
development of EPA's Contaminated Sediment Management Strategy; Chapter Two summarizes
Forum 1; Chapter Three summarizes Forum 2; and Chapter Four summarizes Forum 3. The
document concludes with a series of appendices containing the draft outline of the Contaminated
Sediment Management Strategy (Appendix A), Proposed Outreach Activities to Support
Implementation of EPA's Contaminated Sediment Management Strategy (Appendix B), agendas

of the three forums (Appendix C), and address lists for forum participants (Appendix D) and forum
speakers (Appendix E).

As the written record of the public forums, this document will be reviewed extensively by
EPA senior management during revision and implementation of the Contaminated Sediment
Management Strategy.

CHAPTER ONE

INTRODUCTION

1.1 SEDIMENT CONTAMINATION IN THE UNITED STATES

The contamination of sediments in water bodies of the United States has emerged in recent
years as an ecological and human health issue of national proportions. In surveys performed in
1985 and 1987, the Office of Water (OW) of the U.S. Environmental Protection Agency (EPA) first
began to document the extent and severity of sediment contamination in the United States (see
Figures 1-1 through 1-4). In 1989, a study by the National Academy of Sciences, "Contaminated
Marine Sediments-Assessment and Remediation," identified the potential for far-reaching health
and ecological effects of contaminated sediments.

Sediments are often the depository for a myriad of chemicals and other pollutants
discharged into surface waters from both point and nonpoint sources. These sources include
industries, agricultural operations, publicly owned treatment works (POTWs), combined sewer
overflows (CSOs), stormwater, hazardous waste disposal sites, and atmospheric deposition. Heavy
metals, dioxins, polychlorinated biphenyls (PCBs), polyaromatic hydrocarbons (PAHs), and other
contaminants in sediment can harm aquatic environments and pose a significant threat to human
health. Benthic organisms, fish, wildlife, and humans come into contact with sediment either directly
or through the food chain and face the risk of exposure to elevated concentrations of harmful
contaminants and their associated health impacts. In many cases, contaminated sediment has led
to elevated tissue burdens of certain pollutants, "fin rot," reduced reproductive capacity, and
decreased biodiversity and abundance in benthic communities. Elevated carcinogenic and other
health risks have been predicted in affected human populations at many sites nationwide. To date,
contamination has been identified in the sediments of water bodies at hundreds of locations at
levels high enough to harm human health and wildlife.

1.2 DEVELOPMENT OF A STRATEGY FOR MANAGING CONTAMINATED SEDIMENTS

In 1989, EPA Administrator William Reilly formed an Agency-Wide Sediment Steering
Committee to address the problem of contaminated sediments on a national scale. This committee,
chaired by OW's Deputy Assistant Administrator, was composed of senior managers from all the
major program offices in the Agency. In January 1990, the Steering Committee decided to prepare
a Strategy for managing contaminated sediments with an aim to:

0 Prevent ongoing contamination of sediments that may cause unacceptable risks to
human health and the environment.

0 Clean up existing sediment contamination where practical.

0 Ensure that sediment dredging and disposal of dredged materials are managed in
an environmentally sound manner.

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n River
v Lake
* Marine
* Estuary
LAKE
* Wetland ONIARIO

Vr
JAL

PA NI

wV DE
OT RI

Figure 1-1. Documented contaminated sediment sites in U.S. EPA Regions 1, 11, an
(adapted from U.S. EPA, 1987).

M River
v Lake
A Marine
* Estuary KY
0 Wetland

MS AL
HM OK An GA

i A
YX
V V

Figure 1-2. Documented contaminated sediment sites in U.S. EPA Regions IV and
(adapted from U.S. EPA, 1987).

V (AKE
SUPERIOR
v v MN

ND
wr T
wl iA L(f'
MKIIIGAN

L40

Figure 1-3. Documented contaminated sediment sites in U.S. EPA Regions V, VII, and V
(adapted from U.S. EPA, 1987).

m River
v Lake
Marine WA
Estuary
0 Wetland

AZ
"V

Figure 1-4. Documented contaminated sediment sites in U.S. EPA Regions IX and X
(adapted from U.S. EPA, 1987).

EPA has authority to assess, remediate, and prevent sediment contamination under 10
different statutes, including the Clean Water Act (CWA); the Marine Protection, Research and
Sanctuaries Act (MPRSA); the Federal *Insecticide, Fungicide, and Rodenticide Act (FIFRA); the
Toxic Substances Control Act (TSCA); the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA); the Resource Conservation and Recovery Act
(RCRA); the National Environmental Policy Act (NEPA); the Coastal Zone Management Act
(CZMA); the Great Lakes Water Quality Agreement (GLWQA); and the Clean Air Act (CAA).
No less than 16 EPA program offices and 10 EPA regional offices currently implement programs
that, in some manner, manage contaminated sediment. The Contaminated Sediment Management
Strategy would aid in the coordination of EPA program offices and regions, as well as other federal,
state, and local entities to promote:

0 Consistent consideration of sediment risks.

0 Consistent decision-making at federal, state, and local levels in managing these risks.

0 Wise use of scarce resources for research, technical, and field activities.

0 Consistent sediment assessment practices.

In addition, the Strategy will facilitate EPA's response to legislative proposals currently being
considered as part of CWA reauthorization, which might require development of a national
inventory of sites with contaminated sediments, national sediment criteria and standards,
accelerated point and nonpoint source control and cleanup in designated areas, and a consistent
protocol for collecting and analyzing sediment samples.

EPA's Strategy represents a plan of action for assessing, preventing, and remediating
sediment contamination and for managing disposal of dredged materials. The success of this
Strategy, however, depends on the involvement and cooperation of a large number of federal
agencies and other groups, including the regulated community, state and local governments,
environmental groups, industry, scientists, and the general public.

1.3 PUBLIC REVIEW OF EPAIS CONTAMINATED SEDIMENT MANAGEMENT STRATEGY

In February 1992, Administrator Reilly met with the Sediment Steering Committee and
recommended that EPA distribute the draft Strategy outline to the public to acquire a better
understanding of the basic issues involved and to learn about alternative approaches. To further this
effort, EPA's OW, Risk Assessment and Management Branch, sponsored a series of three public
forums to present the Strategy and solicit feedback from the many audiences that will be affected
by its implementation.

The first forum on the Extent and Severity of Sediment Contamination was held April 21
and 22, 1992, in Chicago, IL; the second on Building Alliances Among Federal, State, and Local
Agencies was held May' 27 and 28, 1992, in Washington, DC; and the third on Outreach and Public
Awareness was held in Washington on June 16, 1992. The first two forums were attended by over
100 people each, and the third forum had approximately 35 attendees. Government agencies,
industry, environmental consulting and law firms, environmental groups, and academia were all
represented. The goal of all three forums was to allow key constituency groups to provide EPA

-14-

with additional information about the sediment problem, and to provide feedback about their
concerns and information needs, which could then be incorporated into the final Strategy.

To date, EPA has distributed at least 2,000 copies of the draft Strategy outline issued March
5, 1992. EPA accepted written comments on the draft outline through July 15, 1992, and now plans
to revise the draft Strategy, taking into consideration comments and criticisms voiced during the
three national forums as well as in the formal written comments. Following the intra-agency "red
border" review process, EPA intends to send a proposed Strategy to the Office of Management and
Budget (OMB) so that it can be published in the Federal Register during 1993.

1.4 REFERENCES

U.S. EPA. 1987. U.S. Environmental Protection Agency. An overview of sediment quality in the
United States. EPA No. EPA-905/9-88-002. Fig. IV-2a-2h. pp. 25-39.

-15-

CHAPTER TWO

THE EXTENT AND SEVERITY OF CONTAMINATED SEDIMENTS

2.1 INTRODUCTION

The forum on the extent and severity of contaminated sediments was the first in a series of
three forums sponsored by EPA's Office of Water, Risk Assessment and Management Branch. This
forum was held April 21 and 22, 1992. Section 2.2 of this report summarizes the key points in the
forum presentations. Section 2.3 summarizes the key points from the open discussions and formal
comments as well as subjects discussed during overall dialogue. Section 2.4 is a list of references
used by the speakers in their presentations.

2.1.1 Welcome, presented by Tudor Davies, U.S. EPA, Office of Science and Technology

The Director of EPA's Office of Science and Technology, Tudor Davies, welcomed
attendees and gave an overview of EPA's Contaminated Sediment Management Strategy. Dr.
Davies noted that EPA regards sediment contamination as a serious national problem. He stated
that, although progress has been made toward controlling sources of sediment contamination, some
contaminants are persistent and bioaccumulative. These contaminants are recycling in the
environment. Studies have identified sites with sediment contaminant levels that are harmful to
aquatic life and pose a threat to people ingesting fish. Of the approximately 1,400 fish consumption
advisories in the United States, 1,000 are in the Great Lakes region. Only six states do not have
fishing bans or fishing advisories.

Approximately 10 statutes deal with the management of contaminated sediments. EPA
believes that a comprehensive plan coordinating all federal activities to address sediment problems
is necessary. In various provisions of the Clean Water Act reauthorization proposals and other
legislative proposals, Congress has demonstrated an interest in addressing potential sediment
contamination problems.

The purpose of EPA's Contaminated Sediment Management Strategy is to protect beneficial
uses of surface water from the impacts of contaminated sediment. The Strategy proposes
implementation of pollution prevention and source control measures and, where possible and
appropriate, natural recovery processes to restore sediment quality. EPA must therefore improve
the understanding of natural recovery processes for in-place contaminants. The Strategy calls for
remediation. only where there are potentially high human health or ecological risks and where the
natural recovery process would be too lengthy and the short-term risks unacceptable.

EPA believes there is a need for a national inventory to assess the contaminated sediment
problem. Pilot projects to inventory the sources of contaminants in sediment are currently being
undertaken. EPA's Region IV (Southeastern United States) and V (Midwestern United States)
have completed inventories of sediment contaminant sources and are now working to gather data
needed for inventories of contaminated sediment sites.

-17-

The Strategy also outlines a number of areas for further research. EPA needs to develop
sediment criteria and common assessment methods for determining the ecological effects of
sediment contaminants and for refining fate and transport assessment techniques. The costs and
availability of technologies for sediment remediation need further investigation as well. EPA
intends to manage the National Pollutant Discharge Elimination System (NPDES) permitting
process and improve the pesticide registration and reregistration process to more effectively address
sediment concerns. EPA will seek corporate agreements for contaminant source reduction and
recycling. The Agency also will work with the U.S. Army Corps of Engineers (COE) to develop
testing methodologies for ocean and freshwater disposal of dredged material. EPA supports
applying COE's tiered testing approach, developed for ocean dumping, nationwide for freshwater.

Further research also is needed to assist EPA in understanding the risks associated with
sediment contamination, and outreach is needed to communicate those risks to the public.

2.1.2 EPA's Understanding of the Extent and Severity of Contaminated Sediments,
presented by Tim Kasten, U.S. EPA, Office of Water

Tim Kasten, of EPA's Contaminated Sediments Section, spoke about the Agency's
understanding of the extent and severity of sediment contamination. In 1985, EPA examined data
in the STORET data base to begin compiling data on a national scale regarding sediment. Since
this data source was limited for sediment, EPA conducted a study in 1987 in which people in state
and federal agencies and academia were interviewed and new surveys were conducted. From these
studies, EPA concluded that potentially hundreds of sites in all types of water bodies were
contaminated with pollutants such as polychlorinated biphenyls (PCBs), pesticides, polynuclear
aromatic hydrocarbons (PAHs), and metals. In 1989, the National Academy of Sciences (NAS)
conducted a study on contaminated marine sediments and reviewed EPA's studies. The NAS
concurred with EPA's conclusion that the national extent of sediment contamination might be large
and the effects severe. Sources of sediment contamination were found to be varied; some are
historical, and some continue to contribute to the problem.

In a 1986 EPA study that ranked environmental problems, sediment contamination as a
category of nonpoint source pollution was given a medium score for noncancer risks and a low score
for cancer risk, but was ranked as the highest surface water risk for carcinogens. On a regionally
comparative basis, in EPA Regions 1, 11, 111, and V, sediment contamination was given a medium-
high score for cancer risk. There have been numerous fishing bans in the United States due to
sediment contamination, although in some areas of the country the problems have been resolved.
Cage studies of human health effects in Quincy Bay, Massachusetts; Puget Sound, Washington; Los
Angeles, California; and Long Beach Harbor, California, showed moderate to high health risks to
people who consume certain species of fish.

The 1986 EPA study ranked nonpoint sources of sediment and sediment contamination
high as local and regional factors affecting ecological risks. EPA comparative risk studies in the
Agency's regional offices produced a high score for contaminated sediment affecting ecosystems.
Ecological effects case studies have documented effects in fish, birds, and mammals.

-18-

2.2 PRESENTATION SUMMARIES

This forum on the extent and severity of contaminated sediments was structured around
three panels: (1) extent of sediment contamination, (2) severity of contamination with respect to
human health effects, and (3) severity of contamination with respect to ecological effects. For each
of the three panels, a group of panelists presented study results. These presentations were followed
by a formal public comment period and an open discussion period (facilitated by Charles Menzie
of Menzie-Cura and Associates, Inc.).

This section summarizes the main points of the panelists' presentations as well as important
issues or comments related directly to the presentations. This section also summarizes the
presentation of any formal comments related to each panel topic.

2.2.1 Extent of Sediment Contamination

2.2.1.1 The F-lt*nt and Severity of Sediment Contamination in the Estuaries of the Mid-Adanfic
Region, presented by Richard W. Latimer, EPA's Environmental Monitoring and
Assessment Program (EMAP)

EPA's Office of Research and Development (ORD) initiated the Environmental Monitoring
and Assessment Program (EMAP) to monitor status and trends in the condition of the nation's
ecological resources. The near coastal component of EMAP consists of estuaries, coastal waters,
and the Great Lakes. A demonstration project was conducted in 1990 in estuaries of the mid-
Atlantic region called the Virginian Province (Cape Cod to Chesapeake Bay) (see Figure 2-1). The
EMAP sampling design is probability based on a well-defined grid to provide unbiased estimates
of rzsource condition. Indicators measured include habitat and exposure characteristics as well as
biological responses. Of particular interest are organic and inorganic sediment contaminants,
sediment toxicity, and macrobenthic community composition and abundance.

Results from the 1990 demonstration project (see Figures 2-2 through 2-8) suggest that
about 11 percent of the region had elevated concentrations of metals in the sediments. About 12
percent of the region had elevated concentrations of organic chemicals in the sediments. A 10-day
solid-phase toxicity test using indigenous biota was conducted to examine the condition of estuarine
sediments. Nine percent of the sediments were toxic. Elevated concentrations above background
were found in 12 percent of the areas for both PCBs and PAHs, and in 15 percent of the areas for
pesticides. Small estuarine systems, including harbors and bays, had the highest proportion of toxic
sediments and elevated metal and organic concentrations.

The biotic integrity of the estuaries was assessed by measuring the condition of bottom-
dwelling animals. Twenty percent of the region had degraded benthic resources. The largest
portion of the sites with degraded benthos also had low dissolved oxygen conditions. Other sites
showing degradation had low dissolved oxygen, toxic sediments, or other stressors.

_19-

100

Figure 2-1. EM" near coastal Virginian Province-19
(Weisberg, 1992).

100

80
160
36%
40

CL
20
2% 1%
Toxic Sediments (9%)
0
finiall
Estuaries Rivers Estuaries

Nontoxic Sediments (91 %) 100

80
Virginian Province $60
15

al
20 8% 1% 4%
0
C esapeak-e----iferaware----Uc-ng sand-
Bay Estuary Sound

Figure 2-2. Percentage of area containing to3de sediment (from Weisberg, 1992).

100

60
0
4-
C 37%
0040
27%

a-
20
ackground (88%) 4%

.............
.......... 0 I-Arge iIdal- -S-M" -al I
Estuaries Rivers Estuaries
Elevated (12%)

100-

80
Cd
Virginian Province 2!
< 60
0

2140
17% 15%
20
3%

.... .. . .....
0
Chesapeake Dela@ware Long Island
Estuary Sound
Bay
Figure 2-3. Percentage of area containing elevated concentrations of PCBs in sediment (from
Weisberg, 1992).

100

80
Cd
@ 60 66%

40
21%
Nm*
Background (88%) 20
0%
0-
Urge a ma
Estuaries Rivers
Elevated (12%) Estuaries

100

80
Virginian Province
60
0
.4-4
C
@ 40
(D
IL 19%
20
2% 5%
Chesapeake Lono Island-
Bay Estuary Sound
Figure 2-4. Percentage of area containing elevated concentrations of PAHs in sediment
(from Weisberg, 1992).

100

80
CO
CD
6 0 49%

a) 40
29%

a_
20 9%
Background (85%)

0
Urge Mal .. al
Estuaries Rivers Estuaries
Elevated (15%)

100

80
Virginian Province 2!
-<* 60
0
39%
a) 40

a.
14% 15%
20

0
Chesapeake Delaware Long I@Ia-nd---
Bay Estuary Sound
Figure 2-5. Percentage of area containing elevated concentrations of pesticides in sediment
(from Weisberg, 1992).

100

40
24%
20
s% 8%
Enriched
Conc. %)
rge
0
Estuaries Rivers Estuaries
Y, Natural Cone. (89%)
100

Virginian Province 080
60

840
20 18% 15%
3%
0 110"Mv -- -- -
Chesapeake Delaware Long Island
Bay Estuary Sound
Figure 2-6. Percentage of area containing elevated concentrations of metals in sediment
(from Weisberg, 1992).

100

37%
40
27%
n- 16%
20
Degraded Benthos (20%)

0
Estuaries Rivers Estuaries

Undegraded Benthos (80%) 100

Cd
Virginian Province 60

40 29%
a_ 16%
17%
20

0
Chesapeake Da ware Long Island
Bay Estuary Sound
71 F71

71 71

Figure 2-7. Percentage of area containing degraded benthos (from Weisberg, 1992).

UNKNOWN

B
IOXIC SEDIMENTS
OTH
VIONDEGIRADED- -DEGRADED
80% 20%
-LOW DISSOLVED OXYGEN

BEN-11-10S IN SITES WITH
THE PROVINCE DLGRADED HENTHOS

Figure 2-8. Exposure conditions at sites having degraded biological assemblages (Weisberg,
1992).

2.2.1.2 National Distribulion ofSediment Contamination, presented by Thomas P. O'Connor,
NOAA National Status and Trends Program (NS&T)

The NOAA National Status and Trends (NS&T) Program has determined concentrations
of trace metals and organic compounds in sediment samples collected at about 280 sites around the
coastal and estuarine United States. The intent has been to describe the national distribution of
chemical contamination. To ensure that data would be representative of rather large areas, samples
were not taken at "hot spots" (such as at the ends of discharge pipes or small poorly flushed
industrial waterways).

The data reveal a general connection between chemical concentrations and numbers of
people residing near sites, and the highest concentrations were found at sites in urban areas. Even
the high concentrations, however, are usually below levels often associated with biological effects.
Direct measures of biological effects are not made at all NS&T sites, but most toxicity tests of
sediments from some of the more contaminated sites have been negative. Liver tumors among
bottom-feeding fish, one effect of chemical contamination on indigenous organisms, are found
infrequently, although such effects might not be evident if the fish sampled were not old enough
to exhibit effects.

The NS&T results imply that sediments over a large portion of the estuarine and coastal
United States do not generally carry chemical contaminants at high enough concentrations to harm
marine life. As noted above, however, these data were taken from 280 sites, and do not reflect
contaminant concentrations at hot spots. Extremely contaminated sediments do occur over spatial
scales that are too small to be found by a national program sampling representative sites. The
NOAA program now conducts bioeffects surveys that examine selected estuaries more intensively,
with the express purpose of determining the spatial scales of sediments sufficiently contaminated
to induce biological effects.

2.2.1.3 Compiling Sediment and Pollutant Data Bases ftom the Historical Record, Results of
Pilot Studies Jrom the Boston Harbor-Massachusetts Bay Program, presented by F. T.
Manheim, J. C. Hathaway, and A B. ten Brink, U.S. Geological Survey, Woods
Hole, MA

The U.S. Geological Survey (USGS) is conducting multidisciplinary studies of the transport
and accumulation of contaminated sediments in selected regions of the U.S. coastal and marine
environment. These studies are designed to answer fundamental questions such as:

How are water and material transported through the system?

Where do sediments and associated contaminants accumulate and at what rate?

What are present levels of contaminants in sediments and how will they change?

One component of these studies is the development of data bases for sediment texture and
contaminants, both inorganic and organic. The cooperation and active participation of multiple
agencies and organizations is an integral part of generating comprehensive data bases that will
provide inventories of contaminants in sediments in U.S. waterways.

-28-

In the past, the scattered and heterogeneous nature of older data made compilation, quality
control, and use difficult. Often, researchers launched new field surveys rather than attempt to use
any but the most accessible older data. Over time, much of the "new" information also took its place
among the little-used historical archives.

In late 1990, the USGS Office at Woods Hole, Massachusetts, began efforts to compile a
detailed data base of chemical, geological, physical, and environmental parameters on estuarine and
coastal sediments from all sources. The pilot study was undertaken in Boston Harbor and
Massachusetts Bay.

USGS and EPA Region I (Boston) recovered data from about 1,300 sediment samples,
taken and analyzed from 1962 to 1990 (see Figures 2-9 through 2-13). Utilizing new batch screening
methods, the USGS achieved increased effectiveness in processing and validating data. Examples
in Figure 2-11 show data before and after the "VALIDS" procedure. The validated set (b) also
added data beyond the earlier set (a), which was limited to the "Boston Harbor Data Management
File" (BHDMF). The augmented validated data set yielded a somewhat lower geometric mean
(black dot) and median, but the general distribution and central tendency of values were confirmed.
The large number of data points provides three-dimensional geographic distributions of key
contaminant parameters, more robust dispersion estimates, and measures of changes in sediment
composition with time. The amount of data also reduces the risk that a few erroneous or poorly
located data points will adversely affect statistical or management evaluations.

Applying the effects-based toxicity screening guidelines of Long and Morgan (NOAA Tech.
Mern. NOS OMA 51, 1990) to the Boston Harbor data, more than 50 percent of analyzed samples
for each of at least six metals (copper, zinc, lead, chromium, nickel, and mercury) fell above the
lowest screening threshold (ER-L or 10 percentile) among samples showing adverse biological
effects (Figure 2-12, dotted vertical line). Some of these elements had not been previously cited
as having significant toxic potential in the area.

Studies by the USGS and the Massachusetts Water Resources Authority found that metal
and Clostridium per0ingens (a bacterium spore used to trace sewage) concentrations are highest in
"depositional" (rather than erosional or other) areas defined in bottom sediment maps. Bottom
substrate mapping from more comprehensive data thus enhances the ability to extrapolate
environmental conditions on the coastal sea floor and aids the design of scientific efforts toward
answering critical management questions.

The USGS would be pleased to share data bases and techniques and work cooperatively
with agencies and institutions toward a national contaminated sediments inventory for the marine
environment.

2.2.1.4 U.S. Army Corps of Engineers National Dredging Program, presented by Charles R.
Lee, Environmental Laboratory of the U.S. Army Engineer Waterways Experiment
Station

The COE is mandated by Congress to maintain navigable waterways throughout the United
States. This area includes roughly 400 harbors and 25,000 miles of waterways. Each year COE is
responsible for dredging approximately 400 million cubic yards of material. Sixty million cubic yards
are placed in the ocean under the Ocean Dumping Act, and the remaining 340 million cubic yards
are regulated under Section 404 of the Clean Water Act (see Figure 2-14).

-29-

,Vf slic
River Chelsea I MILE
,firer

0 Waste Discharge
Location
0 Sludge Discharge
Location
Combined Sewer
outlets
OS
C/I arl
0 Storm Water
Rirer /,7,70r Overf low
bar DEER
0 ISLAND Oiller Marbor
014 0
1@7 P7, @
Chafl,74-1
Reserved Chalw7el

'or d:;'
Varchest

8
80
Y

011MC7 89

NUT M-AND

OPSO/ RYer

wey'MOVI '0---Weymoulh
lore River BoO Riyer
1

Figure 2-9. Location of waste'discharge locations in Boston Harbor (from NMLA., 1990).

-30-

Mercury in Sediments
Hg (ug/g)
100: No. of Samples 0 0.5U 1.0
I
ER-L ER-M 0

10-
80 C@
0
Cn
20-
QL_
M 607
0
30- 0
CL
Uj
w 40-- CD 0
co Below
z Q L
acute toxicity
D
z levels

20-
5oL

0
0.001 0.01 0.1 1 10 100
CONCENTRATION OF MERCURY (ug/g)
(a)

0 10 XM

C4010urs im Motors

Bosi

7.1
<D

SEDIMENT
ISAMPLE LOCATIONS 0
(b)
Figure 2-10. (a) Mercury in sediments from Boston Harbor and surrounding areas of
Massachusetts Bay from the USGS (BHDMF) data base and EPA Region 1
sediment samples (Manheim et al., 1992). Black columns refer to samples having
concentrations greater than ER-M or the 50 percentile of concentration levels in
populations showing adverse biological and mortality behaviors according to the
Long and Morgan review (1990). Shaded columns refer to ER-L or 10 percentile
of the affected population range, whereas empty histograms refer to levels below
acute toxicity levels. The same designations are applied to mercury values in the
sediment core. Note the very low mercury values in presumed uncontaminated
pre-anthropogenic sediment layers. (b) Distribution of USGS data base and EPA
Region 1 sediment samples (Manheim et al., 1992).

-31-

A Copper

No. of Samples Cumulative %
120 100

Percent of -90
100 Toxic effects samples
ranges (ppm) above this -80

ER-L 70 61.7
70
80
OAET 300 9.3
-60
Median
60 -50
Mean

-40
528 samples
40
-30

-20
20

10
.......................................
01 1 1 1 1 1 [111 1 rTmm-r 0
0.001 0.01 0.1 1 10 100 1000 10000
ug/g

B Copper

No. of Samples Cumulative %
200 100

80
150
70 ug/g ER-L value
70
300 ug/g ER-M value
60

100 1044 samples + 50

30
50
20

0 0
0.001 0.01 0.1 1 10 100 1000 10000
Concentration of Copper (ug/g)
Figure 2-11. (a) Frequency plot for copper values in raw data from Boston Harbor sediments
(all depths) before batch validation procedures (from Manheim and Hathaway,
1991). Note outlier at low and high concentration tails. N=528. (b) Frequency
plot for copper values with additional data set (total N =1044) and after
validation procedures (from Hathaway and Manheim, 1992). Low-concentration
tail in (a) was found to represent mostly elutriation, interstitial water, and other
values not properly attributable to bulk sediments. Some high values were
likewise found to be due to errors in original sources. However, note similarity in
the general distributions of values, which extend over more than three orders of
magnitude in concentration.

-32-

Boston Harbor Sediments
No. of SampleS (USGS & EPA Region Sources
400
1 Zinc
200

01 mill
0.001 0.01 0.1 1 ug/g 10 100 1000 10000
300 1 Lead
200 -

f
0 i I,Iii, l I I I I Jill
300 1
I Chromium
200

Juu.-

0
300
1copper
200

100,_

tluu
Nickel

400
1 Cadmium
200
,.I, Jill I Ibmir.0

Mercury Effects- Based Toxicity Thresholds (Long & Morgan, 1990)
100 MEDIUM
LOW
ELOW acute toxicity levels
0 FT TrrTr

I L
0.001 0.01 0.1 1 10 0 1 ...1000 10000
u9/9
Concentration in Dty Sediment

Figure 2-12. Metal distributions for seven elements from Greater Boston Harbor sediments
(from Manheim et al., 1992). Dashed vertical line refers to ER-M apparent
d: @.1111 I

effects-based toxicity screening level (from Long and Morgan, 1990); dotted
vertical line refers to ER-L toxicity screening level.

-33-

Pesticides and Other Organic Compounds

No. of Samples
160
PCB

140

100

so DDT

so DDE ALDR DIEL
HEPTE @NDR/ HEPTA
40
LA
.. ... ... . .. ... PARA

ENDO
... ... . LOR
ENDS CH
ENDI BBHC
20 .. @BHC ToXA
... HYDRC
CLW
... .. MMMIME-7, mn
0 RRIM
DDD CIND DIRK 68HC ENDRA '0cBU I
AROHY

PCB's
70 No. of Samples ...........I......... Cumulative % 100

percerd of - 90
60 Toxic effects samples
ranq9s (pprn) above this - 80
So - ER-L 0.05 85.6 - 70
OAET o.37 53.2
- 60
40 -
Median
- so
Mean
30
40

30
20

20
10 ........................
10

o F:F9.... 0
0.001 0.01 0.1 1 10 100 1000 10000
ppm
Figure 2-13. Distribution of pesticides and other organic compounds in the BHDMT data set,
and frequency plot of PCB values (total) from the BHDMT set (from Manheim
and Hathaway, 1991). Note the irregular distribution, unlike smooth lognormal
distributions for metals.

-34-

Alaska District - Open Water = 0.2 million cu yd
Sea le Pecific Ocean Division - Open Water 0.3 million cu yd
0.5

Portia
Walls*wdua

%
0.1
........................... ......
................................
2.40
....... 0 @t. Paul

............ 2.6
. .... . .. .... .....
...........................
....... . .........I Detroit
1 0.6: U Ohl ......
2 &........... Omilha
0.1 ........ ........... 1.0 E)
ck Islan
Sacramdrito
...... ......
NZ-0i Sa Franci ............ ... 25
0
4.5 Kansa it
St. Louis 8.3
. .............. ':... 'U;u1sville
; .......... 0
0.3 . ............ .
0.3 ......... ....................................... .... ............

.............. 0 Nashville
LosAngel 00 Tulsa 0
2.3
0 1.00 26.1 .....................
Albuquerque
Little. 3
Note: Districts With .0.
Quantities Less .3
Than 0.1 million Fort Worth 0 13.6
...................
cu yd Not Shown 13.7
Vic sburg
Total Quantities
Total Dredging by CE District, cu yd (All Districts)
50 to 60 million Confined 67.1 ew Or ans 0 1
25 to 50 million Unconf Ined 4.9 G esion
15 to 25 million Open Water 182.1
10 to 15 million Undifferentiated 44.3 18-2 20.3
5 to 10 million Total 298.4 millJoh cu yd 21.0 40.5
1 to 5 million
0 to I million Undifferentiated EM Confined (C)
E3 Open Water (0) E3 Unconfined (U)
Figure 2-14. Average annual quantities (cubic yards) disposed by area by district (Boyd e
1992).

A small percentage of the dredged material, approximately 3 to 12 million cubic yards, is
contaminated and requires special handling and/or treatment. COE established the Environmental
Laboratory in 1972 to develop test procedures to predict potential impacts of COE activities in
aquatic, wetland, and upland disposal environments. For the past 20 years, these test procedures
have been developed and applied to numerous dredging projects and currently are incorporated in
COE's nationwide management strategy for dredged material disposal (33 CFR Part 336, April 26,
1988). The COE process for managing dredged material involves a tiered approach that begins with
an initial screening of the sediment to be dredged. If the initial screening indicates a cause for
concern, a detailed assessment of the sediment is conducted. If the results of the assessment show
evidence of a potential problem, the COE management strategy is applied, which includes
evaluations and tests of the available disposal options (see Figure 2-15).

COE has worked closely with EPA in jointly preparing testing manuals and other guidance
for the dredging and disposal of sediments from waterways. More recently, COE has assisted EPA
in applying its expertise to the dredging and management of contaminated sediments at Superfund
sites.

2.2.1.5 Sediment Contamination in the Great Lakes, presented by Steve Garbaciak, EPA!s
Great Lakes National Program Office

The United States, and Canadian governments have identified 43 "toxic hot spots" in the
Great Lakes and designated them as Areas of Concern (AOCs). Of these 43 areas, 42 have been
identified as having contaminated sediments. EPA and local Remedial Action Plan (RAP) teams
have cited contaminated sediments as a problem in all of the 31 U.S. and joint U.S./Canadian
AOCs. In addition, the recently released National Water Quality Inventory cited contaminated
sediments as a leading source of impairments in the Great Lakes. Half of the 4 million cubic yards
of sediment dredged annually for navigation in the Great Lakes is contaminated.

A principal problem posed by contaminated sediments is that pollutants are consumed by
bottom-dwelling organisms and are transferred up the food chain. Thus, sediments can act as a
major source of contaminants to fish and wildlife and can subsequently pose a risk to human health.
Contaminated sediments also have a significant economic impact associated with closed commercial
fisheries, sport fish consumption advisories, and restrictions on navigational dredging.

Sediment contamination is widespread in the urban and industrialized harbors and rivers
of the Great Lakes. Pollutants such as cadmium, copper, mercury, PAHs, and PCBs have been
found at elevated levels. Whole sediment toxicity tests from Indiana Harbor have shown 100
percent mortality for some species. In 1988, the Assessment and Remediation of Contaminated
Sediments (ARCS) Program was convened to focus on specific problem areas. In addition, an
inventory of contaminated sediment sites in EPA!s Region V is under way.

2.2.1.6 Advantages ofIncluding Cesium-137 in Sediment Contamination Studies: Examplesfrom
Lake Michigan and the Grand Calumet River, presented by Richard A. Cahill, Illinois
State Geological Survey

Programs were undertaken to sample sediment in Lake Nlichigan and in the Grand Calumet
River. The Lake Mchigan results, published in 1981, included the chemical analysis of 286 surficial

-36-

1. INITIAL EVALUATION CLEANUP
AUTHORITY
Nb

11. DETAILED SEDIMENT ASSESSMENT
NO YES*@@
NOT CONTAMINATED CONTAMINATED

Ill. NAVIGATION
I DREDGING
CONVENTIONAL MANAGEMENT STRATEGY IV. CLEANUP
DISPOSAL I CLEANUP
APPLY ASSESSMENT
FEDERAL STANDARD I
I CLEANUP
-MANAGEMENT DECISION DECISION

YES NO YES NO

Figure 2-15. U.S. Army Corps of Engineers process for evaluation of the disposal of dredged
material.

sediment samples, collected on a 12 x 12 km lake-wide grid (Figures 2-16 to 2-18). These samples
reveal that arsenic and lead contamination is concentrated in fine grain deposits of deep basin
areas. In these areas, arsenic concentrations typically range from 10 to 20 ppm, rising to 40 ppm
in isolated hot spots. Lead concentrations are higher but similarly distributed, falling between 50
and 100 ppm in most areas, with some hot spots of over 100 ppm.

The inclusion of cesium-137 results (Figure 2-19) provides a better understanding of the
deposition patterns of the sediment and clues as to the source of contamination. In Green Bay,
for example, core samples reveal high concentrations of arsenic, but cesium-137 results indicate little
recent deposition. These findings suggest that arsenic contamination in Green Bay is probably not
anthropogenic. By contrast, cesium-137 results show recent deposition near the Menominee River,
where arsenic contamination is known to have human sources.

Results also are shown for the west branch of the Grand Calumet River (Figure 2-20),
where 10 cores were subsampled every 30 cm for chemical analysis (Figures 2-21 through 2-23).
These samples indicate that zinc and organic carbon are most heavily concentrated in the upper
sedimentary layers of the Grand Calumet River near the outfall of the Hammond Sanitary District.
Cesium-137 profiles (Figure 2-24) combined with chemical analysis (Figure 2-25) provide
information on when contaminants entered the sediment. This information allows researchers to
construct what Mr. Cahill calls "the industrial history" of the region.

Mr. Cahill concluded by emphasizing the importance of four aspects of a sampling program
to ensure the integrity of the analytical results:

0 Use a well-designed sampling grid

N Use uniform sampling techniques

N Subsample cores in discrete intervals

0 Include sedimentation rate estimates

Mr. Cahill indicated, during questions, that bioturbation can mix sediments and blur the
record of sedimentation constructed from cesium-137. He added that cesium-137 and lead-210
provide complementary results on sedimentation rates, although cesium-137 is somewhat less
expensive, and fewer samples are required for the cesium-137 determination.

2.2.2 Severity of Contaminated Sediments - Human Health Effects

2.2.2.1 Estimating the Sevetity of Human Health Effects Caused by ChemicaUy Contaminated
Sediments in California, presented by Gerald A. Pollock, Pesticide and
Environmental Toxicology Section, Office of Environmental Health Hazard
Assessment, California Environmental Protection Agency

Intense concerns have been raised regarding human health effects caused by consumption
of seafood contaminated via bioaccumulation from sediments. This situation has led to the issuance
of health advisories for contaminated species and passage of legislation to address hot spots of
contaminated sediments in the bays and estuaries of California.

_38-

A B C E I H I K L M 0 P 0 S T U V W X

50
49- T,

48-

47-

46 -
45- 0 0 0 0 0 0
44 - 0

43- 0
42 - 0 10 0
41 - 0
40- 0 85'
39- Menominee 0 0 45'
38- '0 +
37 - 0

36 - 0

35-
34 - Frankfort
33- Green Bay
32 - 0

31-
04.
30 - 04. 0 0 0 0 0 10 20 m I
29- 0 0 0 0 0 10 20 30 40km

28- 0 0 0 0

27 - 0 a 0 0

26- 0 0 0 0

25- 0 0 0 0
24- 0 0 0
23 - 0 0 0
22 - 0 0 0

21 - 0 0 0 0 0

20 - 0 0 0 0
19 - 0 0 0 0 0 0 .4@

18 - 0 41 0

17 - 0 0 0 0 0
16 - Milwaukee 0 0 0 0 0
15 - 0 0 0 0 0

14 - 0 0 0
13- 0 0 0 0 - q('qef
0
12 - 0 0

10 - ILLINOIS 0 0 0
9 Waukegan 0 9 0 0 0 0
8 - 0 0

7 -
6- 88' 0 Bent-n Harbor
5- 42' 0
4--
3- Chimago MICHIGAN St. Joseph River
2- TIN DTZA

No sample recovery
Sample recovered
z
z 5 ISGS 1980

Figure 2-16. Sample location grid for the 1975 cruise of the CSS LIMNOS in Lake Michigan
(Cahill, 1981).

-39-

....................
Menominee .. ....
45'

Frankfort

Green Bay

....... ...... 0 10 20 30mi

...... 0 10 20 30 40krn

Mil.aukee

Fliler
Kalil "a'00

ILLINOTE@
....................
Waukegan

88, Benton Harbor
42' Greater than 40 ppm
20-40 Ppm
Chicago St. Joseph River
10-20 ppm
lyjjCFLI@N
INDIANA
Less than 10 ppm

MEAN 9 pprn

3
R MIN. 1 pprn
z
Z < MAX. 150 ppm
:J@a
z

Figure 2-17. Arsenic distribution in the upper 3 cm of Lake Nfichigan sediments (Cahill,
1981).

-40-

..... . .....

85'
Menominee
45'

Frankfort

Green Bay

lei
0+ 0 10 20 30 rni

1. 20 311 401m

Mil.a.kee :X-.

.............

piver

... .. . . ...
WISCONSIN
ILLINOIS-

Benton Harbor
Greater than 100 Ppm
42'-4-
50-100 pprn
St. Joseph River
.................
Chicago MICHIGAN 20-50 PPM
NDI @4 Less than 20 ppm
MEAN 40 pprn
MIN. 1 pprn
a z MAX. 153 pprn

Figure 2-18. Lead distribution in the upper 3 cm of Lake Nfichigan sediments (Cahill, 1981).

- -41-

41N,

Menominee +4e

Frankfort

Green BaY

1 0 10 20 30mi
0
0 10 20 30 40km

XY,

. . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . ... ... .
. . . . . . . . . . . . . . . . . . . . .....
. . . . . . . . . . . . . . . . . . . . ..... .
Milwaukee ;'0"

00
. . ..... ... ......
Kalafna
X.
W1 . . . . . . . . .
@ONSIN
. . . . . . . ..........
ILLINOIS
. . . . . ....................

Waukegan . . ....
NY

j ....
Benton Harbor
8
. . . . . . . . . . .
42
. . . . . . . . . . . . . . .
. . . . . . . . . . St. Joseph River
Chicago
ICHIGAN
. . . . . . . . . . . . -- - -- - -- -
. . . . . . . . . . .
INDIANA >0.25 Bqg-'
0.05-0.25 13qg-I
<0.05 Bqg-I
a1z deep basin;
z 5
fine-grained deposits

Figure 2-19. Cesiuni-137 distribution in the upper 3 cni of Lake Michigan (Cahill and Steele,
1986).

-42-

THOMAS J. O'BRIEN U) <
0 Z
LOCK AND DAM Z <

z
UH-17 POWDER HORN
LAKE

UH-16 POWDER
HORN
LAKE

UH-14

UG-10
H-9.4 L

UH-11

Figure 2-20. Location of sediment coring samples in the Grand Calumet River (Cahill e
1992).

Sampling Density

4 IL

10 9 7
IL IND
River Mile

Figure 2-21. Sample density used in the Grand Calumet River (from Cahill et al., 1992).

-44-

Organic Carbon

... ... ....

...........
.............. I - I - .. I - I - - - .. - - - - - - - - - -.: -: -: -: -I
.............
...........
............. ....
.......................
.... ..................
. ...........
................ .
. .............

. . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . .. . . . . . . .
. . . . . . . . . .
. . . . . . . . . . . .
. . . . . . . . . . .

. . . . . . . . . .

030
2
027
...........

... ...... . . . . .
...............
024
......................
....................
CL
................................
...................
E 21
3
IN 18
..........
...... 19 15
..........
.................
...........
0 12
.. ..............

..............
4 El 9

El 3
5 Do
10 9 8 7 5
IL IND
River Mile

Figure 2-22. Organic carbon concentrations (percent) in sediments of the Grand Calumet
River (from Cahill et al., 1992).

_45-

Zinc, EDX

0 .......
. . ..... . . . . . . ..............
..........

........ ..

. . . ..... E 5000
. . ..... ...
2
E
04500
M 4000
CL
03500
0 3000
3

0 2500
12 2000
El 1500
El 1000
El 500
0 0

10 9 8 7 6 5
IL IND
River Mile

Figure 2-23. Zinc concentrations (ppm) in sediments of the Grand Calumet River (from
Cahill et at., 1992).

-46-

103-

128

153
1791
0 0.05 0.1 0.15 0.2 0.25
Cesium-137 (Bq/g)

Figure 2-24. Cesium-137 profile in core UH-9.2 from Grand Calumet River (from Cahill et
al., 1992).

1962

1924-

1886--

1848-.:

CIO --A

i fi
10 100 1000 10000
Zinc (ppm)
Assumes a Constant Rate of Sedimentation of 2.1 cm/y
Based on Cesium-137 Results M XES AA

Figure 2-25. Zinc distribution in core UH-9.4 from the Grand Calumet River, including the
approximate year deposited based on cesium-137 (from Cahill et al., 1992).

Public health attention has focused on local populations that might fish near contaminated
sites. Highly contaminated sediments have been identified in San Diego Bay, Santa Monica Bay
and the Los Angeles Bight, San Francisco Bay, and the Sacramento/San Joaquin River.

The severity of human effects usually is described based on estimates of excess cancer
incidence or other toxicity (e.g., reproductive/devclopmental, neurotoxicity), since the exposures
frequently are not high enough to result in acute or observable toxicity. Estimated excess lifetime
cancer risks from consumption of seafood in areas of high contamination range from below I in
100,000 to as high as 2 to 5 per 1,000. Also, significant exposures for mercury levels in inland lakes
have been calculated.

Better estimates of actual human health impacts are limited due to the unceriainty
associated with the risk assessment process. Uncertainty in estimating the consumption rate of
contaminated seafood and the lack of adequate epidemiological data pose problems in conducting
human health risk assessments. Recent studies on populations exposed to PCBs, DDTs, and methyl
mercury may greatly aid in our ability to evaluate the severity of human exposure to toxic chemicals
due to contaminated sediments.

Fish samples were taken and chemical analyses were conducted at 25 sites in the vicinity of
the sewage outfall in southern California. About 15 fish species were sampled, and 1,000 chemical
analyses were conducted. The chemicals of most concern were the DDT-composites found at levels
up to 3,000 ppb and PCBs found at levels up to several hundred ppb. Contamination was found
to be highest around the sewage outfall. Species- and site-specific fishing advisories were issued.

A case study of the Upper Sacramento River in the vicinity of a pulp mill outfall showed
elevated levels of dioxins and furans. A risk assessment found high health risks. Estimated
maximum excess cancer risk from consumption of fish from the Sacramento River ranged from
2 x 10' to 5 x 10' (Pollock et al., 1989).

Dr. Pollock expressed concern over the uncertainties inherent in currently used risk
assessment methodologies, and emphasized a need for further research to refine the assumptions
and methodologies used. Assumed seafood consumption rates, projection of human health effects
based on laboratory data on animals, and expansion of the list of the chemicals of concern are three
of the areas needing further research.

2.2.2.2 77m Impacts of Contaminated Sediments on Human Heafth: A Case Study from the
Great Lakes, presented by Wayland R. Swain, Eco Logic International, Inc.

Residue-forming organic contaminants of anthropogenic origin have become ubiquitously
distributed throughout the global environment. In large aquatic systems, the sediments serve as a
sink for many of these compounds. Unfortunately, the sediments also serve as a large reservoir of
these materials, which under conditions of resuspension, equilibrium partitioning, bioturbation, and
advection can become a long-term source of toxic substances. Food chain transfer of these
mobilized sedimentary contaminants frequently contributes to elevated concentrations of toxic
organic substances in fish, exceeding recommended guidelines for human consumption.

-49-

Although often surrounded by considerable controversy, the effects of acute human exposure
to many toxic organic substances are reasonably well documented, chiefly as a result of occupational
exposure or catastrophic accident. Less well understood are the human health effects of small,
repeated, or chronic exposures to these materials, particularly with respect to the role of sediments
in this process. Sources of PCBs in sediments of the Great Lakes, and their contribution through
the biota can be linked to effects on human health. Human exposure to PCBs can be analyzed in
the light of data from extensive epidemiological studies of two matched cohorts of exposed
individuals consisting of (1) sports anglers and (2) mothers and their newborn infants. These
groups were chronically exposed to significant quantities of PCBs from consumption of
contaminated freshwater fish from Lake Michigan.

In 1974, a Lake Michigan angler study of 178 adults showed that the longer they had
consumed fish, the higher their PCB body burden. Another study of 1,091 adults in 1982 showed
that persons consuming fish from Lake Michigan had higher PCB body burdens compared to non-
fish eating individuals (see Figures 2-26 through 2-28).

A study of mothers and their newborn infants showed that, as th e period of time over which
fish from the lake were consumed increased, so did the body burden of PCBs. In addition, the
higher the PCB body burden, the more intense the effects exhibited by the infants. Exposed
mothers were found to have increased levels of PCBs in whole serum and breast milk. Infants of
highly exposed mothers were born at reduced birth weights and reduced gestational ages, had
smaller head circumferences, and exhibited neuro-motor effects (see Figures 2-29 through 2-31).
The effects of PCBs are subtle and become apparent in specific psychological tests. With low level
chronic exposures to PCBs, a mother may exhibit no effects; however, her children may experience
neurobehavioral deficits.

The exposure of fish to PCBs in Lake Michigan was probably the result of a single massive
source at Waukegan Harbor (see Figures 2-32 through 2-36). Based on calculations, the majority
of the PCB releases from the source to Lake Michigan probably occurred before 1970.

2.2.2.3 Risks Associated with Seafood Consumption: Perception vs. Reality - the Quincy Bay Case
Study, presented by Nancy Ridley, Bureau of Environmental Monitoring,
Massachusetts Department of Public Health

The problems of chemical and microbiological contamination of fish and shellfish have
historically presented a challenge to public health, environmental, and natural resource officials at
the federal, state, and local levels. While the vast majority of fishery products are wholesome and
not likely to cause illness, there are areas of risk. According to the 1991 report on Seafood Safety
from the National Academy of Sciences, the greatest risks are for consumers of raw shellfish. Next
highest are the risks associated with naturally occurring toxins. Less well defined are the acute and
chronic risks associated with chemical contaminants.

In June 1988, EPA released a report, completed at the request of Congress, entitled
Assessment of Quincy Bay Contamination. The study investigated the types and concentrations of
pollutants in Quincy Bay, Massachusetts, the incidence of abnormalities in marine life, and the
potential public health implications of consumption of seafood exposed to contaminated sediments.
Study results indicated that levels of PCBs and PAHs were elevated in sediments and in the marine
species studied (see Tables 2-1 and 2-2). Elevated levels of trace metals such as copper, chromium,

-50-

LEGEND
M CONTROLS N=419
W FISH EATERS N=572

0j-
AV* "IV
R 43
Q Ix CL a Ur' a J WT 41ir CUT JU
'x -Z 0. x CL CL k CL a 0 CL AL
Q CIL

PCB 1016 rcB t 260

Figure 2-26. Median PCB levels for elution peaks found in human serum of fish caters and
nonfish eaters (from Humphrey, 1987).

900

wo-

700-
LEGEND
soo - a LAKE TROU
W
V) a CHINOOK

0 500

'too.

Cr
QUI
1
z
W
700..

100

0 to 20 30 @n @0 @0 7r) So q0 100 110 120 130 140 150 160 170 180
TIME IN I IOUnS

Figure 2-27. Percent change through time in baseline serum PCB levels following a meal of
contaminated fish (from Humphrey, 1987).

-51-

100-

90-
0

80-

60-

0-
50-

:D
40-

LIJ
Cn
30-
z
<
LU 20-

..............
10-

01j
Ze ro 1 to3 4 to 6 7 to 9 >10

Y E A R S OF FISH CONSUMPTION

Figure 2-28. Relationship between fish consumption and PCB body burden (from Swain,
1988a).

-52-

8482 wonien interviewed

4% ate sufficient quantities of contaminated
fish to qualify (1.2 - 41.7 kglyr)

313 mothers and infants studied

10-

z 8-

C3
C)

u) 4-

. . . . . . . . . . .
<
z
Ir
W

W.
AX

0
NONE 6-11 12-23 24-51 52-183
E
N U M 8 R 0 F FISH MEALS-YEAR-1

Figure 2-29. Relationship between number of fish meals per year and PCB concentrations in
maternal serum (from Swain, 1988a).

-53-

3.7 w.W (kg) 35.5 CIeWfWW46 (era)

3.6
35
3.3
3.4 34.5
3.3
12 None tAw Modlwm High 34 Low MMMUM High
EXPOSURE LEVEL D"SURE LEVEL

40 saWlenal Age (weeks) 20 14euron"acuior Waturily (relative units)

38
men* LOW M"Ur" High m6ne LOW MedIUM High
EXPOSURE LEVEL EXPOSURE LEVEL

Figure 2-30. PCB dose-response relationships for birth weight, gestational age (Ballard
Examination), head circumference, and neuromuscular activity by overall
contaminated fish consumption (from Jacobsen et al., 1985; and Fein et al.,
1984).

Go-

4
W
>
0

0
.... .....

z
-'-'.@* ...........
0

50-

LL
zxj-

..........
5.

-N:

0.2-1.1 1.2-2.2 2.3-3.5 3.6-7.9
CORD SEnUM PC[3 (NG-ML:I)
Figure 2-31 Visual recognition memory as a function of fixation to novelty compared with
PCB level in umbilical cord serum (from Swain, 1988a).

-54-

24
22 Minfinum
20 Maximum

'16
E
CL 14
CL
.5
Co 12
Q
CL 10

s:v'

g
6

Q.,
R,
4

0
Superior Humn Michigan Erie* Ontario

Coho Salmon In Lake Erie; Lake Trout riot present
Figure 2-32. Representative range of PCB levels in Great Lakes fish: mid-1970s (Swain, 1992).

4 0

Co2 M
U
CL

C 0
.01 .03 05 or 09 .11
14

Michigan

12-

10-
0
2
I--

Erie
Superior
Mulon

01 .03 05 or .09 if
V
l
tO -V-A !-otpos"'.
g@

Figure 2-33. Range of reported values of PCB levels in lake trout (Salvelinus nam"cush) in
the North American Great Lakes, and their associated arithmetic means
compared with the relative depth (D) of each lake. Relative depth is calculated
as a function of the maximum depth (Dj of a lake over the square root of its
area (A) (Swain, 1988b).
-55-

10.000-

1000- 10% of 5.3 V 10 3 Tons
_@_U_ f-c he s-e d-
E
V
10
In too-
.S

to-

I- Low "Best High
Estimates Of Mass 01
PC13 in the Sediments
Waukegan Harbor
ED Harbor and North Ditch

Figure 2-34. Estimates of total PCBS in the Waukegan Harbor-North Ditch complex relative
to the 10 percent level of PCBs purchased by the manufacturer between 1955 and
1970 (from, Swain, 1988b).
10007

North Ditch;
Fathead Minnows

a) 1007
Je

North Ditch Water-15-546.8 ng/I

Ila-rbo r;
0 Perch

liarbor-,
Bluegill
Co
0
CL

tiarbor Water 4.2ti.2 ijg/I

0.1 0 1'0 i's 210 25 3T0

Exr)o,.;ure in Days
Figure 2-35. Effects of exposure to PCBs from Waukegan Harbor-North Ditch complex
demonstrated by caged-fish study (Swain, 1988b).

-56-

7.3 ios

0
tL 7- 1.0 - 106

z
0

6
1.25 1 10

z 1.57 , 10
W

0
2.2 10
3-
M

7.3 106

1965 1970 1975 1980 1985
YEAR

-8

c
12
9 Z:
c
a

2 - -3

c f
c

1970 1980 1980 1910 1980 -0
Estimated PCs Input Est. of Estimated nange of
In Lake Michigan nange: rce Concentration in
M-Inpul from Almos. Lake Michigan Water
Waukegan Ilarbor & I"Pul M-Minimum
North 01tch =-LOW

Figure 2-36. Comparison of estimated Lake Michigan PCB parameters for 1970 and 1980
(Swain, 1988b).

-57-

TABLE 2-1

SUMMARY OF ASSUMED LIFETIME CONSUMPTION LEVELS'

Maximally Exposed Individual Typical Local Consumer
Mixed Diet Flounder Only Mixed Diet' Mixed Diee

Quincy Bay
Clams 16 g/day
(26 meals/yr)

Quincy Bay
Flounder 113 g/day 165 g/day 1 g/day 1 g/day
(about 182 (about 265 (1-2 meals/yr) (1-2 meals/yr)
meals/yr) meals/yr)

Quincy Bay
Lobsterb

Tissue 30 g/day 2.1 g/day 1.7 g/day
(about 115 (6-7 meals/yr) (6-7 meals/yr)
meals/yr)
Tomalley 6 Wday 0.4 g/day
(about 115 (6-7 meals/yr)
meals/yr)

'Assumes V2 lb. (227 g) serving per meal of clams or flounder and Y4 lb. (113.5 g) serving of edible parts per meal of lobster.
'Breakdown of tornalley versus other edible lobster tissue based on MDMF, unpublished data.
'Typical diet of flounder and lobster without tomalley.
dTypical diet of flounder and lobster with tornalley.

TABLE 2-2

MAXIMUM UPPER BOUND ESTIMATED LIFETIME CANCER RISKS FROM
CONSUMPTION OF QUINCY BAY SEAFOOD

Maximally Exposed Individual Typical Local Consumer
Mixed Diet Flounder Only Mixed Diee Mixed Diet'

Clams 2.lxlO-"
(<1%)

Flounder 3.2x10-3 4.7x10-3 2.8xlO-' 2.8xlO-'
(13.9%) (100%) (33%) (2.2%)
t!A
1P Lobster Meat 8 OX10-4 5.6x10-5 4.5x10-5
(3.5%) (67%) (3.5%)

Tomalley 1.9X10-2 1.2xlO-'
(82.6%) (92.3%)

TOTAL RISK 2.3X10-2 4.7x10-3 8.4xlO-' 1.3x10'

'Typical diet of flounder and lobster without tomalley.
'Typical diet of flounder and lobster with tomalley.
Note: Percentages may not add to 100% because of rounding and the need to display no more than two significant digits.

and lead also were found. Flounder and soft-shelled clams were found to exhibit an extremely high
incidence of conditions believed to be associated with environmental stress and poor health.
Significant histopathologic findings included cancerous lesions; liver, intestinal, and pancreatic
pathology; and neoplasms.

The risk assessment concluded that the risks of regular consumption of lobster tomalley
(hepatopancreas) from Quincy Bay lobsters were high and were comparable to those associated with
advisories and/or fishery closures in Upper New York Harbor of Uke Michigan. Consumption of
very large amounts (100 to 200 meals per year) of flounder and/or lobster muscle potentially posed
risks higher than those for other generally accepted risks associated with eating, such as
consumption of high cholesterol foods. Consumption of "typical" amounts of lobster (not tomalley)
and/or flounder (less than 10 meals per year) posed risks similar to those of other eating or drinking
activities.

The U.S. Food and Drug Administration (FDA) also conducted a risk assessment of Quincy
Bay contamination and arrived at different findings. FDA concluded that PCBs were of little
toxicological importance in Quincy Bay and that consumption of tomalley from lobsters taken from
Quincy Bay posed a negligible threat to human health. Nancy Ridley stressed that these studies
are indicative of the need for interagency coordination and consistency in approaches to conducting
risk assessments.

2.2.2.4 Human Health Risks at Superfund Sites Associated with Dermal Contact and Incidental
Ingestion of Contaminated Sediments, presented by William R. Alsop, ENSR
Consulting and Engineering

Case studies of human health risk assessments performed at seven Superfund sites were used
to illustrate the presence and severity of risks associated with contaminated sediments. The range
of sediment concentrations were reported for each of the sites. Potential human health risks, both
carcinogenic and nonearcinogenic, were derived for each of the sites based on observed sediment
concentrations. Human health risks associated with dermal contact and incidental ingestion of
contaminated sediments were compared with the overall risks calculated for each of the sites to
determine the contribution of these pathways. The assumptions used to derive these risks include
the amount of sediment in contact with skin, skin surface area exposed, sediment ingestion rate,
body weight, and other parameters based on exposure frequency and duration. Preliminary results
indicate that the carcinogenic and noncarcinogenic risks associated with exposure to contaminated
sediments via dermal contact and incidental ingestion do not significantly contribute to the
calculated total risk. Risks associated with fish consumption often constitute the greatest proportion
of the total risk, and sometimes drive the human health risk assessment (see Figures 2-37 and 2-38).
This information suggests that even when conservative assumptions about direct human exposure
are used, risks associated with dermal contact and incidental ingestion of contaminated sediments
are minimal, and contribute less to the calculation of total risk than other pathways, such as fish
consumption.

-60-

100-
V) 00
Cli
00 00
00
90-

80-

70-

60-

50 -
U-
0

z
LU
U 40-

30-

20-

10
0,
C@

0
North Carolina Connecticut New York

CASE STUDY

Figure 2-37. Percentage of total risk due to fish ingestion.

-61-

100-

go-

70-

60
(n

0 50-

z
LU
U 40-

LP
20

0
North Carolina Connecticut Texas

CASE STUDY

Figure 2-38. Percentage of total risk due to sediment exposure.

-62-

2.2.3 Severity of Contaminated Sediments - Ecological Effects

2.2.3.1 PAHs in Sediment Cause of Liver Tumors and Reduced Lifespan in Brown BuUhead,
presented by Paul C. Baumann, U.S. Fish and Wildlife Service

Over the last 15 years, concentrations of PAHs in sediment have been associated with
elevated tumor frequencies in six species of fish at 16 locations (Harshbarger and Clark, 1990).
One such location is the Black River in Ohio, where brown bullheads three years old or older were
found to have a high incidence of liver tumors in a study done from 1980 to 1982 (see Figures 2-39
through 2-43 and Tables 2-3 through 2-6). These same fish had elevated PAH concentrations with
a profile matching that found in sediment. There were three orders of magnitude difference
between PAH levels in sediment in the Black River and sediment in reference sites. The Black
River bullhead population in 1980 and 1981 had a truncated age structure with a Iifespan about 70
percent that of builhead from nearby Old Woman Creek (Baumann et al., 1990). The steel and
coke industry underwent a decline in 1982. Residues of such PAHs as phenanthrene, fluoranthene,
and the carcinogen benzo(a)pyrene were approximately 10 times higher in bullhead sampled in 1980
and 1981 than in those sampled in 1982. In October 1983, the USX coking plant ceased operation;
it has not been reopened. The frequency of liver neoplasms in bullheads over the age of 3 (N = 125)
was 60 percent in 1982, and the frequency of advanced lesions (cancer) was 39 percent. By 1987
the neoplasm frequency for this same age group (N=80) had declined to almost one-half (32
percent), and the incidence of cancer had been reduced to about one-quarter of the 1982 level (10
percent). Using criteria established for human epidemiology studies, the evidence supports a cause-
effect relationship for sediment PAH carcinogens and liver cancer in native fish populations.

2.2.3.2 Integrative SedimentAssessments, presented by Peter A Chapman, EVS Environment
Consultants

Integrative sediment assessments are defined as investigations involving attempts to integrate
measures of environmental quality to make an overall assessment of the ecosystem's status. Such
assessments include two or more of the following components: sediment toxicity tests, sediment
chemical analyses, tissue chemical analyses, pathological studies, and community structure studies.
As such, integrative assessments are more than the sum of their parts; the total amount of
information about. a system extracted by an integrative assessment (through a preponderance of
evidence approach) is of much greater utility than the information provided by individual
components. The following points were covered (see Tables 2-7 and 2-8):

� Pollution comprises contamination resulting in exposures that cause effects.

� Determining the presence and significance of pollution is not always easy.

� Targets and measures of the five individual assessment components were discussed
(see Table 2-7).

� Information provided by each of the five assessment components presents a total
picture of the situation. If used in isolation, individual components can be
misleading (see Table 2-8).

-63-

ONTARIO

MICHIGAN

Oat=

Wridsor

PO'eveiand
Lorain

CHIC

Figure 2-39. Map showing the location of the Black River (Johnston, 1989).

LAKE ERIE

LORAIN
COUNTY COKE
PLANT

Figure 2-40. Map showing the location of the USX coke facility and outfall on the Black
River (Baumann et al., 1987).

_64-

6.0
PAM IN SEDIMENT

4.0 Buffalo River

pprn

3.0 -
2.0 - @B,,[email protected],
1.0 -

ppb
f I
Ph FI Py BoA Bap
(3) (4) (4) (4)
o-@\
10" @l

Figure 2-41. PAH residues in sediment of the Black River, Buffalo River, and Buckeye Lake.

A. Block River Bullheod z 3 yr.

B. Black River Sediment (below ourfall)

R t BenzWonthracene
Nocihtholene Fluorene PhenonLne I Pyrene Chrysene Lzoto)pyrene

0 10 110 30 40 so

Minutes
R@wer

1,1AP;

Figure 2-42. Correlation between PAH profile in tissue of brown bullheads and PAH profile
in Black River sediment (Baumann, 1989).

-65-

Grossly observable liver tumor frequencies
were very high -4-- Black River builhead
from 1980-1982 and increased
with increasing age.

60 - LIVER TUMOR RATES WITHIN
AGE GROUPS BY YEAR
50 - Brown Bullhead - Block River

40 - 1980
1981
0
1982
30 -

0- 5
A
Age

Figure 2-43. Grossly observable liver tumor frequencies in Black River bullhead from 1980 to
1982 and increase with increasing age (Baumann et al., 1987).

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TABLE 2-3

PAH RESIDUES IN AGE 3 BROWN BULLHEAD FROM THE BLACK RIVER

PAH 1980 1981 1982

Dibenzothiophene 509 832 45.8

Phenanthrene 3,930 7,570 161.0

Fluoranthene 1,260 4,040 129.0

Pyrene 756 1,570 83.9

Chrysene 60.5 42 13.2

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TABLE 2-4

DECLINE IN LIVER CANCER IN AGE 3 AND OLDER
BROWN BULLHEAD FROM THE BLACK RIVER

Liver Year Collected
Condition 1982 (N=124) 1987 (N=80) Sig.

Normal 20.2% 42.5%

Cellular Alteration 19.4% 25.0%

Noncancer Neoplasm 21.8% 22.5%

Cancer 38.7% 10.0%

* 0.01 < [email protected]
**p<0.01

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TABLE 2-5

DECLINE IN LIVER CANCER IN AGE 3 BROWN BULLHEAD FROM THE BLACK RIVER

Liver Year Collected
Condition 1982 (N=48) 1987 (N=42) Sig.

Normal 22.9% 45.2%

Cellular Alteration 20.8% 33.3%

Noncancer Neoplasm 25.0% 14.3%

Cancer 31.2% 7.1%

* 0.01<p.:!:-j..05
**p.!!:[email protected]

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TABLE 2-6

DECLINE IN LIVER CANCER IN AGE 4 BROWN BULLHEAD, FROM THE BLACK RIVER

Liver Year Collected
Condition 1982 (N=73) 1987 (N=29) Sig.

Normal 19.2% 41.1%

Cellular Alteration 19.2% 17.2%

Noncancer Neoplasm 20.5% 34.5%

Cancer 41.1% 6.5%

0.01<p<.05

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TABLE 2-7

TARGETS AND MEASURES OF INDIVIDUAL ASSESSMENT COMPONENTS

Component Target(s) Measure(s)
Sediment Toxicology Benthos Survival
Indicator organisms Sublethal effects
Commercially and/or Chronic effects
ecologically sensitive Mutagenic effects
species Cytotoxic effects
Genotoxic effects

Sediment Chemistry Sediments Individual contaminants
Sediment features (e-g-,
grain size)
Ancillary analyses (e.g.,
AVS, TOC)

Tissue Chemistry Bottom-fish Individual contaminants
Benthic epifauna Ancillary analyses (e.g.,
Benthic infauna size, weight, age)
Pathology Bottom-fish Individual pathological
conditions
Ancillary analyses (e.g.,
size, weight, age, lipid
content)
Community Structure Benthic infauna Taxa presence/abundance
Dominance
Diversity

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TABLE 2-8

INFORMATION FROM INDIVIDUAL ASSESSMENT COMPONENTS

Information

Component Provided Lacking

Sediment Toxicity Laboratory responses(s) Field responses
by organisms to test Responses to test not
conditions conducted and organisms
not exposed
Sediment Chemistry Presence and levels of (Bio)availability
measured chemicals Presence and levels of
chemicals not measured

Tissue Chemistry Presence/levels of Effects
chemicals in Presence of transformed
organisms/tissues chemicals
Bioavailability Presence/levels of
chemicals not measured

Pathology Presence/levels of Effects
measured responses in Presence/levels of
organisms and tissues responses not measured
Community Structure Presence/numbers of Causality
taxa/individuals Ecosystem level relevance

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� Two case study examples (the Gulf of Mexico and the North Sea) showed that
pollution was associated with populated areas, and hot spots were restricted rather
than widespread.

� Use of a preponderance of evidence approach includes drawing conclusions from
individual components considered relative to each other and considering different
viewpoints when determining possible mechanisms.

� The objective of integrative assessments is to use the best professional judgment for
decision-making based on data, facts, intuition, background knowledge,
characteristics of the site, and experience.

2.2.3.3 Ecological Effects of Contaminated Sediments in the Elizabeth River, presented by
Robert C. Hale, Division of Chemistry and Toxicology, Virginia Institute of Marine
Science, College of William and Mary

Assessing ecological effects is a more difficult task than delineating the extent of sediment
contamination. Important effects can be expressed in a number of ways, some of which are difficult
to detect. To examine the relationship between ecological effects and sediment contamination, a
severely polluted area has been chosen for study.

The Elizabeth River is a subestuary of the Chesapeake Bay and is heavily contaminated with
a variety of pollutants, particularly aromatic hydrocarbons. Sediment gradients of these latter
compounds have been established. Examination of benthic communities in the Elizabeth River
suggests impacts from exposure to contaminated sediments. Uptake of organic compounds in fish
has been observed by assaying bile from exposed fish. Bioaccumulation of aromatic hydrocarbons
in commercially fished, resident crabs has also been documented. In addition, the frequency and
intensity of neoplasms, cataracts, enzyme induction, finrot, and other lesions observed in fish
populations is correlated with the extent of sediment contamination (see Figure 2-44). Laboratory
studies have been conducted in an attempt to elucidate whether these sediments are responsible
for the observed effects. Fish maintained in the laboratory in contact with sediments taken from
the Elizabeth River exhibited several of the symptoms observed among fish populations in the field.
Additional laboratory studies have implicated contaminants from sediments as causal agents for
other effects, such as immune system dysfunction.

21.3.4 Case Studies of the Ecological Effects of Contaminated Sediments in the Northeastern
Gulf of Mexico, presented by Barry A. Vittor, Barry A. Vittor & Associates, Inc.

Four case studies of typical northeastern Gulf of Mexico estuaries provide information on
the ecological effects of contaminated sediments, through benthic macroinfauna, acute toxicity, and
bioaccumulation investigations.

Upper Mobile Harbor (Alabama) sediments contain high concentrations of lead (64 to 477
mg/kg), copper (16 to 72 mg/kg), zinc (150 to 543 mg/kg), and PCBs (up to 1,267 ppb). No
biological studies have been conducted in the most contaminated area (Industrial Canal), but
benthic communities in the adjoining Mobile River contain less than half the number of species and
individuals found in the upper estuary just outside the harbor.

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INTESTINE r 2 0.699
0.15-

0.15-

E 0.15-

W 0
F-
Z
LU 0 10 20 30 40 50 60 70 80 90 100

> 2
0.3- LIVER r 0.963
LU 0-
LU
C@
W)
IT
& 0.2-

0.1-

0 10 20 30 40 50 60 70 80 90 100

SEDIMENT PAH (MG/KG)

Figure 2-44. Sediment contamination and correlation with enzyme induction in spot
(Leiostomes xanthurus) (Van Veld et al., 1990).

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Lower Mobile Bay and an area southwest of the bay entrance are known to be sinks for
fine-grained sediments and contain unusually high levels of arsenic (up to 80.8 mg/kg), lead (160
mg/kg), nickel (34.6 mg/kg), and zinc (187 mg/kg). Benthic species abundances in the bay sink (20
taxa) and offshore sink (35 taxa) were lower than in other areas of the lower estuary. Individual
abundances (990/m' in the bay and 2,667/M2 offshore) were also lower than in uncontaminated
areas. Bioassay results indicated no acute toxicity.

Expansion of Pensacola Harbor, Florida, involved disposal of 4.1 million cubic yards of
sediment in an offshore disposal site. Sediments contained moderate quantities of chromium (up
to 91.7 mg/kg) and total organic carbon (9.8 percent). Benthic communities in the disposal site
exhibited a 24 percent decrease in species abundance and a 29 percent decrease in individual
abundance. Acute toxicity bioassays showed no effects on test species, and no bioaccumulation was
observed.

St. Andrew Bay, Florida, is a relatively deep estuary (up to 13 m) in which limited flushing
has resulted in organic material accumulation mostly from paper mill and municipal waste treatment
facilities, as well as from nonpoint sources. Volatile organics comprise up to 34.7 percent of
sediments in areas deeper than 8 m. Other contaminants (metals, hydrocarbons) occur in only
moderate to low concentrations. Benthic communities in the deep sink areas exhibit only 30
percent of the species and 42 percent of the individuals present in shallower, less-contaminated
areas.

Acute toxicity and bioaccumulation testing of sediments from each of these four areas has
not indicated ecological effects of contaminants, despite apparent and sometimes severe ecosystem
impacts shown by benthic macroinfauna studies.

2.3 SUMMARY OF COMMENTS AND DISCUSSIONS

The comments and discussions centered on several topics, including the draft outline of
EPA's Contaminated Sediment Management Strategy, the definition of contaminated sediment, the
extent and severity of contamination in the nation's sedimert, the need and uses for national
sediment quality criteria, and future research needs. The following comments were made by various
forum participants during the discussion.

2.3.1 Comments on Draft Outline of EPA's Contaminated Sediment Management Strategy

A representative from the U.'. Army Corps of Engineers suggested that the tiered approach
used by COE to manage dredged material disposal could be applied by EPA to identify areas with
contaminated sediment.

Donald Hughes, representing the Atlantic States Legal Foundation, presented formal
comments on the draft outline of EPA's Contaminated Sediment Management Strategy. He stated
the Foundation's concern over their interpretation that the Strategy would call for remediation of
sites only where the cleanup is practical. Under some circumstances, sediments might pose
significant risks and should be remediated regardless of practicality. The Foundation believes that
sediment standards and pollution prevention requirements should be applied universally, not just
in areas with identified problems. The Foundation is concerned about the plausibility of natural
biodegradation improving sediment quality in a reasonable time frame and about the capacity in

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some geographical areas to accommodate enough natural deposition of clean sediment to
adequately cover contaminated sediment. The Foundation recommended that EPA have numerical
guidelines for all NPDES permits for protecting sediment and better controls for nonpoint sources.
Hughes suggested that EPA develop a Technical Assistance Grant Program for addressing areas
with contaminated sediment. Hughes applauded the inclusion of sediment considerations in the
Superfund Hazard Ranking System and EPA's emphasis on pollution prevention as a means of
reducing future contamination.

Richard Schwer, representing the Chemical Manufacturers Association (CMA), presented
comments on the draft outline of EPA's Contaminated Sediment Management Strategy. The CMA
generally supports an EPA assessment of the sediment contamination problem. The CMA does
not, however, believe that EPA's existing data reveal a problem of national scope warranting a
comprehensive management strategy. The CMA does not believe there is a correlation between
sediment contamination and biological effects. The CMA believes that the study conducted by EPA
in 1985, entitled National Perspective on Sediment Quality, showed only a small number of hot
spots and that quality of the data in the study was unknown since detailed information on sample
collection methods, sediment characteristics, and quality assurance/quality control procedures were
not included in the data base. The CNLA, feels that only severely contaminated sites should be
addressed by the Strategy. In addition, the Strategy calls for identifying a list of chemicals of
concern for sediment. The CMA is concerned that the Strategy does not assure the list wrill be
compiled in a way that will include only chemicals actually concentrating in sediment at levels
adversely affecting human health and the environment.

Participants recommended that EPA add Federal Drug Administration, Centers for Disease
Control, and Agency for Toxic Substances and Disease Registry to the list of cooperating agencies
in the draft outline of the Strategy.

2.3.2 Definition of Contaminated Sediment

Discussions suggested that contamination could be defined as the presence of pollutants
above levels expected in the absence of human influence. The EPA Contaminated Sediment
Management Strategy has not defined contaminated sediment. There was a consensus that the
Agency should focus its efforts on developing assessment methods that can identify areas where
sediment contamination is a problem.

2.3.3 Extent of Contamination

National monitoring programs such as the Environmental Monitoring and Assessment
Program and NOAA have collected data indicating that, although areas containing contaminated
sediments may be numerous, the geographic extent of each individual contaminated area may be
relatively small. Sediment contaminants are often found in areas subject to human influence. They
are frequently near urban areas where contaminants are concentrated by hydrodynamic factors. In
the United States, these contaminated areas are widespread and numerous.

The participants generally supported a national inventory of contaminated sediment sites,
but noted that the primary purposes and benefits of mounting such an effort must be identified.
A set of criteria for determining the sites to be included in the inventory must be developed and
should probably be based on sediment chemistry, effects, and intended uses of the area. The

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participants seemed to agree that, in the absence of observed effects, a site should probably not be
a candidate for the inventory. When conducting a national inventory, data on major point source
locations and physical features of the receiving water bodies that influence hydrodynamics can assist
in predicting where problem areas might occur.

Many sets of decentralized historical data are available; these sets have been compiled for
various permit-related environmental reports or site studies. These data have generally been
compiled for state and federal authorities, the majority by contractors. The COE regional offices
also have considerable data related to the dredging program. The Federal Energy Regulatory
Commission is probably another source of data on sediment near hydroelectric facilities. If existing
data could be compiled and run through proper quality assurance/quality control procedures, it
could be useful in providing information on the extent of contamination, particularly if mapping
techniques were applied.

Consistency in testing methods is important in determining contaminant levels in sediment.
Test results from different laboratories using different test methods, detection limits, and
technicians with various levels of experience and qualifications can yield very different results on
the same sample. Historical data were often generated using higher detection limits than used
recently. Thus, historical data can lead to false impressions about the presence of a pollutant over
time.

2.3.4 Severity of Contamination

Determining the severity of sediment contamination is a complex undertaking. Standardized
approaches are needed to measure and assess effects of contamination. Interpretation of both
technical results and societal values are components of the definition of severity. When determining
the severity of contamination, the potentially exposed population and the current uses of
contaminated areas should be considered. Hydrodynamic factors and residence time will influence
the severity of contamination.

Criteria must be developed for determining when sediment contamination brings about
effects and is therefore a problem that warrants remediation. The simple presence of elevated
levels of metals, for instance, does not necessarily imply significant ecological effects. Sediment is
a complex mixture, and site-specific factors influence the bioavailability and potential exposure of
contaminants to aquatic life and humans. In addition to toxic chemical contamination, effects from
microbial contamination should be considered. Other pollutants not currently being studied might
be responsible for significant effects as well.

There is an urgent need for determining which effects are important and how to measure
them (i.e., VMat bioassays are most appropriate? Are field studies most appropriate?). Laboratory
tests might not reflect true field conditions. EPA should focus attention on how to interpret
laboratory tests in terms of effects that can be expected in the field. It is difficult to standardize
an approach to assessing effects, and a large amount of data is needed to complete a proper
evaluation.

Best professional judgment (BPJ) should be used when making decisions regarding the
severity of contamination at a particular site. BPJ should be based on data from an integrated
assessment, coupled with information on the characteristics of a site and the decision-maker's
experience.

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Although contaminated in-place sediment may not show effects, one has to assess the risk
of exposure from future events, such as storms or future dredging activities, that can mobilize
contaminants. Assurance that contaminants will remain immobile is needed if the management
strategy for a particular site is to allow natural recovery to take place. Also, the risks of disturbing
sediment for remediation purposes should be weighed against the risks of leaving it in place.

Site-specific evaluations are usually necessary in determining the need for fish advisories.
Sports anglers usually have high fish consumption rates and may continue to consume fish taken
from contaminated sites for lengthy periods of time. When considering fish advisories, the risks of
consuming contaminated fish should be weighed against the benefits of consuming fish versus other
sources of protein such as beef.

There are many uncertainties associated with the risk assessment process. Additional work
must be completed to develop a better understanding of fish consumption rates, other exposure
assumptions, and the potency factors. Potency factors express the degree to which specific
chemicals have been linked to certain diseases, such as cancer. (Cancer potency factors are
common measures of human health effects of chemical exposures.) Currently, human health risk
assessments add cancer potency factors for individual chemicals present in sediment samples. This
method does not account for the synergistic effects of complex mixtures of pollutants in sediment.
Furthermore, for some compounds there may be endpoints other than cancer that should be
investigated and considered in the risk assessment process. Refinement of risk assessment
procedures will be needed to more accurately predict potential effects.

The specific PCB cogeners, types of PAH, or metal species must be measured to give a
more accurate prediction of the possible effects from contamination.

2.3.5 Sediment Criteria

Concern was expressed over how sediment criteria will be used and what role they will play
in managing contaminated sediment. Site-specific conditions of the sediment, such as the presence
of iron sulfide or organic material, influence the bioavailability and toxicity of certain pollutants.
Sediment criteria will be a useful screening tool in determining when and how contaminated
sediment should be managed. Criteria may be modified by site-specific factors to be used
effectively in decision-making processes.

23.6 Research Needs

More research is needed on the sediment conditions that affect the toxicity of pollutants
such as PAHs. In addition, research is needed to determine how aquatic organisms metabolize
PAHs and what the effects of the metabolites are.

Research is needed to develop mechanisms for quantitative ecological assessments of
sediment contamination effects and to refine the human health risk assessment techniques currently
used.

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2.4 REFERENCES

Baumann, P.C. 1989. PAHs, metabolites, and neoplasia in feral fish populations. In: Varansi,
U., ed. Metabolism of Polycyclic Aromatic Hydrocarbons in the Aquatic Environment.
Boca Raton, FL: CRC Press, Inc., pp. 268-289.

Baumann, P.C., J.C. Harshbarger, and K.J. Hartman. 1990. Relationship between liver tumors
and age in brown bullhead populations from two Lake Erie tributaries. Science of Total
Environment. 94:71-87.

Baumann, P.C., W.D. Smith, and WX Parland. 1987. Tumor frequencies and contaminant
concentrations in brown bullheads from an industrialized river and a recreational lake.
Transactions of the American Fisheries Society. 116:79-80.

Boyd, M.B., R.T. Saucier, J.W. Keeley, R.L Montgomery, R.D. Brown, D.B. Mathis, and C.J.
Guice. 1992. Disposal of dredged spoil: problem identification and assessment and
research program development. U.S. Army Engineers Waterway Experiment Station
Technical Report, H-72-8.

Cahill, R.A. 1981. Geochemistry of recent Lake Michigan sediments. Illinois State Geological
Survey Circular 517.

Cahill, R.A. and J.D. Steele. 1986. Cesium-137 as a tracer of recent sedimentary processes in
Lake Michigan. Hydrobiologia. 143:29-35.

Cahill, R.A., M. Unger, and M. Hickey. 1992. Average sedimentation rates in west branch of
Grand Calumet River determined by cesium-137. Paper submitted for publication in
Journal of Great Lakes Research.

Fein, G.G., J.L. Jacobsen, S.W. Jacobsen, P.W. Schwartz, and J.K. Dowler. 1984. Prenatal
exposure to polychlorinated biphenyls: effects on birth size and gestational age.
Pediatrics. 105:315-320.

Harshbarger and Clark. 1990. Science of Total Environment. 94:1-32.

Hathaway, J.C. and F.T. Manheim. 1992. Report in preparation.

Humphrey, H.E.B. 1987. The human population-an ultimate receptor for aquatic
contaminants. Hydrobiologi:@. 149:75-80.

Jacobson, J.L. and G.G. Fein. 1985. Clusters for the Brazelton Scale: an investigation of the
dimensions of neonatal behavior. Developmental Psychology. 20:339-353.

Johnston, E.P. and P.C. Baumann. 1989. Analysis of fish bile with HPLC-fluorescence to
determine environmental exposure to benzo(a)pyrene. Hydrobiologia. 188/189:561-566.

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 Technical
Memorandum NOS OMA52. Office of Oceanographic and Marine Assessment,
National Oceanic and Atmospheric Administration. Rockville, MD.

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Manheim, F.T. and J.C. Hathaway. 1991. Polluted sediments in Boston Harbor-Massachusetts
Bay: progress report on Boston Harbor data management file. USGS Open File Report
91-331. U.S. Geological Survey. Woods Hole, MA.

Manheim, F.T., J.C. Hathaway, and M.B. ten Brink. 1992a. In: Butman, B., M.H. Bothner, J.C.
Hathaway, H.L. Jenter, H.J. Knebel, F.T. Manheim, and R.P. Signell, eds. Contaminant
transport and accumulation in Massachusetts Bay and Boston Harbor: a summary of
U.S. Geological Survey studies. USGS Open File Report 92-202. U.S. Geological
Survey. Woods Hole, MA.

Manheim, F.T., J.C. Hathaway, and M.B. ten Brink. 1992b. Boston Harbor-Massachusetts Bay:
a case study for distribution of metals in contaminated sediments. Volume 3, abstracts.
29th International Geological Congress. Kyoto, Japan.

MWRA. 1990. The State of Boston Harbor: 1990. Massachusetts Water Resources Authority.
Boston, MA.

Pollock G.A., Y.A. Weider, I.J. Uhaa, A.M. Fan, and R.R. Cook. 1989. Risk assessment of
dioxin contamination of fish. California Department of Health Services. Berkeley, CA.

Swain, W.R. Eco Logic International, Inc. Unpublished data. 1992.

Swain, W.R. 1988a. Human health consequences of consumption of fish contaminated with
organochlorine compounds. Aquatic Toxicology. 11:357-377.

Swain, W.R. 1988b. Lakewide impacts of long-term sources of xenobiotic contaminants: Lake
Managua (Nicaragua) and Lake Michigan (United States). In: Schmidtke, N.W., ed.
Toxic Contamination in Large Lakes, Volume 3: Sources, Fate and Controls of Toxic
Contaminants. Chelsea, MI: Lewis Publishers, pp. 389-427.

U.S. EPA. 1988. U.S. Environmental Protection Agency Region 1. Assessment of Quincy Bay:
summary report. Narragansett, RI: U.S. EPA Research Laboratory.

Van Veld, P.A., D.J. Westbrook, B.R. Woodin, R.C. Hale, C.L. Smith, R.J. Huggett, and J.J.
Stegman. 1990. Induced cytochrome P-450 in intestine and liver of spot (Leiostomus
xa thurus) from a polycyclic aromatic contaminated environment. Aquatic Toxicology.
17:119-132.

Weisberg, S.B. 1992. EMAP-Estuaries Virginian Province 1990 Demonstration Project Report.
EPA/600/R-92/100/June 1992.

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CHAPTER THREE

BUILDING ALLIANCES AMONG FEDERAL, STATE, AND LOCAL
AGENCIES TO ADDRESS THE NATIONAL PROBLEM OF
CONTAMINATED SEDIMENTS

3.1 INTRODUCTION

As part of the development of the Agency-wide Contaminated Sediment Management
Strategy, EPA's Office of Water (OW) sponsored the second of three forums to present and discuss
federal, state, and local perspectives on contaminated sediment management. This forum took
place in Washington, DC, on May 27 and 28, 1992, bringing together contaminated sediment
management experts and policy makers from numerous EPA program offices and regions, the U.S.
Army Corps of Engineers (COE), the U.S. Geological Survey (USGS), the National Oceanic and
Atmospheric Administration (NOAA), the U.S. Fish and Wildlife Service (FWS), the U.S.
Department of Agriculture (USDA), the U.S. Department of Energy (DOE), and the States of
California, Florida, Washington, and Wisconsin. The forum commenced with opening remarks by
Elizabeth Southerland, Chief of EPA's Risk Assessment and Management Branch, OW, who
emphasized the importance of public participation and interagency coordination in the development
of the Strategy.

The forum was conducted in three parts corresponding to the three principal elements of
EPA's Contaminated Sediment Management Strategy: contaminated sediment assessment,
prevention, and remediation. Each part of the forum consisted of presentations by representatives
of federal and state agencies followed by a period of formal public comment and open discussion
(facilitated by Virginia Tippie of the Council on Environmental Quality [CEQ]). EPA requested
that forum participants representing each agency focus their presentations on four points:

0 What the agency/organization is doing to assess, prevent, or remediate sediment
contamination.

E How the agency/organization's contaminated sediment management program
coincides with EPA activities outlined in the Strategy.

0 How two or more agencies can work together to effectively manage contaminated
sediments.

0 The strengths and weaknesses of EPA's Strategy.

The following sections summarize EPA staff presentations describing the three principal
parts of the Agency's Contaminated Sediment Management Strategy (Section 3.2 - assessment,
Section 3.3 - prevention, and Section 3.4 - remediation). These sections also include remarks made
by the various federal and state agencies regarding their contaminated sediment management efforts
and the EPA Strategy. Each section includes summaries of panel presentations and questions

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addressed to the panels during open discussion. Section 3.5 summarizes EPA's response to
recommendations made by forum participants.

3.2 ASSESSMENT

3.2.1 EPA's Proposed Assessment Strategy, presented by Elizabeth Southerland, Risk
Assessment and Management Branch, Office of Water, U.S. EPA

The assessment component of EPA's Strategy calls for a national inventory of contaminated
sediments and sources of contaminated sediments; the development of a consistent, minimum set
of chemical and biological tests for evaluating sediments, and increased monitoring of sediment
conditions. A national inventory of sites with contaminated sediments would allow EPA to
complete the best possible near-term assessment of the national extent and severity of the
contaminated sediment problem, identify areas that need further assessment, and target those areas
and contaminants causing high human health and ecological risks for appropriate remedial actions.
The national inventory would rely in part on existing data. Additional data would be needed,
however, in areas where sediment quality data have not been collected; acute toxicity tests were
used inappropriately; or crucial data characterizing sediment, such as grain size, organic content,
or the presence of acid volatile sulfides, have not been documented. Pilot inventories using existing
data are near completion in Regions IV, V, and VI.

EPA also will conduct a pilot inventory of sources of sediment contamination using Toxics
Release Inventory (TRI) data, effluent guidelines data, and other sources of data. The inventory
will be closely coordinated with the Office of Prevention, Pesticides, and Toxic Substances (OPPTS).
It will be used to target pollution prevention and source control activities, including the selection
of industries for the development of new or revised effluent guidelines, permitting, and enforcement
actions.

EPA is committed to promulgating a minimum set of chemical criteria and biological tests
for evaluating sediments and the risks they pose to aquatic and terrestrial environments. This effort
includes the selection of acute and chronic toxicity bioassay techniques for use across all EPA
programs, the development of sediment quality criteria based on the equilibrium partitioning
method, and selection of bioaccumulation bioassays. An Agency-wide workgroup will recommend
a minimum set of acute and chronic bioassay methods for review and approval by EPA!s Sediment
Steering Committee. Sediment quality criteria for nonpolar hydrophobic organic contaminants have
undergone three reviews by EPA's Science Advisory Board (SAB). The SAB plans to issue its
report in Fall of 1992. EPA hopes to publish the proposed criteria in the Federal Register, announce
a formal public comment period, and finalize the criteria following public review. The biological
test protocols will not 90 through such a lengthy regulatory approval process.

A key aspect of the assessment strategy involves improving the monitoring of sediment
quality. Data from ongoing monitoring programs could enhance EPA's ability to predict the
effectiveness of natural recovery processes and identify the contribution of particular sources of
contaminants to ongoing sediment contamination. EPA's Office of Research and Development
(ORD) will monitor sediment quality, water column quality, and fish tissue contaminant
concentrations in its extensive Environmental Monitoring and Assessment Program (EMAP). In
addition, EPA has joined forces with USGS to form the Water-Quality Monitoring

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Intergovernmental Task Force (ITF) with federal, state, and local representation. The task force
will formulate national monitoring protocols, quality assurance/quality control (QA/QC) procedures,
and data transfer systems. EPA!s water quality data systems (STORET, BIOS, and ODES) are in
the midst of a 7-year modernization effort that will include special provisions for archiving and
accessing sediment quality data.

ORD's FY92 budget includes $2 million for researching acute and chronic bioassay
techniques, sediment quality criteria, fate and transport modeling, and remediation technologies.
Current EPA research activities also include field validation of bioassay and sediment quality
criteria developed under laboratory conditions; the Assessment and Remediation of Contaminated
Sediments (ARCS) demonstration program in the Great Lakes; and a technology transfer program
for rapid dissemination of information on remedial technologies, monitoring and sampling
techniques, and other data of interest in managing sediment contamination. EPA hopes to have
a sediment management technology transfer center available within the next year.

3.2.2 Federal and State Agency Assessment Programs

3.2.2.1 Gail Mallard, Toxics Substances Hydrology Branch, Water Resources Division, U.S.
Geological Survey (USGS)

USGS, along with a number of other federal agencies (COE, Bureau of Land Management
[BLM], U.S. Forest Service, Tennessee Valley Authority [TVA], and USDA), plays an important
role in the implementation of the Federal Interagency Sedimentation Project. Mandated by OMB,
the Federal Interagency Sedimentation Project focuses on the study of physical properties of
sediments, fate and transport mechanisms, rates of sedimentation, and sediment grain size. These
physical characteristics and mechanisms often determine the degree to which existing sediments trap
contaminants and the time period over which natural recovery will occur. Research is also
conducted under the project to properly calibrate instruments to measure the movement of
suspended sediment in rivers.

USGS cochairs the Interagency Task Force on Monitoring Water Quality (IT'FM) with EPA.
The task force was created to heighten information sharing among federal and state agencies and
research issues of data comparability. The ITFM will recommend a list of "best" water and
sediment quality indicators to be used in assessing regional water quality and sediment quality, and
directing resources toward sites with the most severe levels of contamination.

Other important areas of USGS research include developing models of sediment transport,
deposition, and resuspension; modeling fish uptake of sediment contaminants; and looking at issues
of bioavailability of sediment contaminants. Because data on sediment texture (i.e., grain size) are
readily available in most cases, USGS has studied the correlation between sediment texture and the
potential for sediment contamination and bioavailability. Study results could be extremely useful
to infer contaminant levels in areas where contaminant observations are sparse. As part of its
research on Boston Harbor and Massachusetts Bay, USGS is developing techniques for archiving
data, exercising quality control, and displaying historical data. The arehived data will be available
on CD-ROM for retrieval on PCs.

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In another major sediment research effort, USGS's National Water Quality Assessment
Program will examine the occurrence of 45 trace metals and over 100 synthetic organics in the water
column, sediment, and biota at some 60 sites nationwide. The 60 sites constitute more than 60
percent of the nation's public water use. This effort is coordinated with EPA, USDA, and FWS
with the goal of measuring baseline conditions and also monitoring conditions over time to define
trends. Each site will have an advisory board made up of representatives from these federal
agencies as well as state and local agencies and organizations. The program plans to relate water
and sediment contamination to human activities where appropriate. The effort began in 1991 and
will continue over the next decade.

Dr. Mallard noted that USGS and EPA can coordinate efforts to develop information about
contaminated sediments. The data available through the National Water Quality Assessment
Program would certainly be of use in a national inventory. The greatest strength. of the EPA
assessment strategy, according to Dr. Mallard, is its emphasis on federal, state, and local agency
cooperation and its coherent and integrated plan for bringing together the many program offices
within EPA that currently address sediment assessment. Dr. Mallard looks forward to seeing the
outline transformed to a complete document with greater detail. Conducting a national inventory
may prove to be difficult and USGS would be happy to lend EPA its considerable expertise in that
area.

3.2.2.2 David Moore and Joseph Wilson, U.S. Army Corps of Engineers (COE)

COE, in fulfilling its mission to maintain, improve, and extend the nation's waterways, is
responsible for managing large volumes of dredged material each year. COE's Dredged Materials
Research Program has been in place since 1973, and has collected a wealth of information pertinent
to the assessment and modeling of sediment contamination, fate, transport, and disposal.

Dr. Moore and Mr. Wilson focused their presentation on the relative merits of what was
termed effects-based testing versus chemical criteria derived by means of equilibrium partitioning
(EP). COE employs a tiered testing approach to evaluate the potential toxicity of sediments and
the effect of their disposal on benthic communities and water column concentrations. The tiered
approach consists of four tiers of effects-based testing with each tier increasing in complexity,
certainty of assessment, and cost. The first tier involves the evaluation of historical data, the second
examines physical and chemical sampling to develop predictive models, and the third tier employs
acute toxicity tests and evaluates bioaccumulation potential. The fourth tier requires advanced
biological effects testing, possibly including chronic sublethal effects tests, field assessments, and
environmental risk assessment.' COE may initiate sediment evaluation at any tier and proceeds
through tiers only until sufficient information has been obtained to make an informed decision.
COE maintains that this approach provides cost-effective sediment assessment that is sensitive to
particular site conditions.

COE prefers the tiered testing approach to the use of numerical sediment quality criteria
for a number of reasons. The tiered testing approach accounts for the complexity of the

'COE has yet to develop the sublethal, chronic effects-based test required in tier four. COE
expects to have such a test within 2 to 3 years.

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relationship between sediment contamination and biological effects, and allows for site-specific
evaluations of sediment toxicity that may not be incorporated in chemical-specific sediment criteria.
COE fears that the chemical-specific criteria currently under development at EPA ignore
complicated factors that determine the bioavailability of sediment contaminants, as well as the
potential for interactive effects of multiple contaminants. COE also stated that tiered testing has
been a regulatory requirement for more than 20 years and its application is agreed upon, whereas
the applicability and regulatory status of chemical sediment criteria are not clear. Mr. Wilson stated
that he believes there should be one regulatory system for assessing sediment contamination, and
he warned against relying on theoretically derived chemical criteria that may "give easy answers to
what are often viewed as complex questions." Dr. Southerland of EPA commented that EPA does
not agree with the above criticisms of chemical sediment criteria.

Overall, COE wholeheartedly supports the EPA Strategy, and believes it will eventually help
to reduce the cost of dredged material disposal by reducing the point and nonpoint sources of
sediment contamination. COE applauds EPA's intention to develop a national inventory of
sediment contamination sites and sources and EPA!s continuing efforts in developing consistent
effects-based testing protocols.

3.2.2.3 Andrew Robertson, Coastal Monitoring and Bioeffects Assessment Division, National
Oceanic and Atmospheric Administration (NOAA)

NOAA's National Status and Trends (NS&T) program monitors long-term trends in
environmental quality of U.S. coastal and estuarine waters. The "mussel watch" component of the
program measures sediment contamination at 220 sites nationwide, and the "benthic surveillance"
component measures sediment contamination at about 70 sites nationwide. Over 70 contaminants
and other sediment characteristics are measured at these sites on a bi-annual basis. NOAA selects
sampling sites that it believes to be representative of larger aquatic ecosystems. Hence, sampling
does not generally take place near known sources of contamination since this might result in biased
sampling data. Other components of the NS&T program include historical assessments of sediment
contamination through core sampling and bioeffects studies in areas of elevated contamination
using acute and chronic effects-based testing methods.'

Dr. Robertson noted that EPA has developed a coherent Contaminated Sediment
Management Strategy and coordinated the sediment-related activities of the many program offices
within EPA. He voiced several concerns with the Strategy, however. Dr. Robertson cautioned EPA
that many federal and state agencies collect sediment quality data, and, to avoid duplication of
effort, EPA should review these data closely prior to embarking on a major data-gathering effort
for the national inventory of contaminated sediment sites. EMAP and NS&T data could provide
the framework for a national inventory. In Dr. Robertson's opinion, NOAA and EPA should
participate in cooperative QA/QC protocol development for data gathering, assuring compatible
data management, and other areas of common interest.

'NOAA is currently conducting bioeffects surveys in Boston Harbor, Long Island Sound,
Hudson-Raritan Estuary, Southern California Bight, Chesapeake Bay, San Francisco Bay, the
Savannah River, and Tampa Bay.

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Dr. Robertson also was concerned that the Strategy does not sufficiently address the study
of contaminated sediments and bioeffects. In recent years, NOAA's program has turned toward
the study of bioeffects, and Dr. Robertson suggested that the Strategy provide for further bioeffects
assessments. He offered NOAA's assistance in developing a national inventory of contaminated
sediment sites and sources of sediment contamination.

3.2.2.4 Donald Steffeck, Division ofEnvironmental Contaminants, U.S. Fish and Wildlife Service
(FWS)

Proposed for full implementation in 1996-97, FWS's Biomonitoring; of Environmental Status
and Trends (BEST) program will monitor trust resource health at selected sites nationwide.
Resources to be monitored will include migratory birds, endangered species, certain anadromous
fish and marine mammals, and the 91 million acres of National Wildlife Refuges. The program will
identify environmental contaminants and sources on public trust lands, and develop methods for
predicting the bioeffects of environmental contaminants. FWS will collect data on tissue burdens
of contaminants and bioeffects, and conduct full community bioassessments. Part of the effort
includes the development of a system of "biomarkers" or indicators of organism health, so that
future evaluations will be able to identify signals of deteriorating ecological conditions. A strong
component of the program involves developing consistent QA/QC protocols and cataloguing the
data in a manner accessible to other agencies. Mr. Steffeck noted that these data would be useful
in developing the national inventory of contaminated sediment sites.

FWS's special studies in its 50 operational field offices often address issues related to
contaminated sediment management. FWS works with COE on dredging projects, assists USDA's
Soil Conservation Service by providing technical assistance on stream alteration projects, and
provides technical assistance to EPA in projects falling under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and
Recovery Act (RCRA). Recently, FWS has developed new techniques for evaluating
bioaccumulation and new acute and chronic bioassay methods.

Mr. Steffeck joined with other panelists in praising EPA's emphasis on intra- and
interagency coordination in developing a national Contaminated Sediment Management Strategy,
and looks forward to working with EPA in providing solutions for the contaminated sediments
problem. Mr. Steffeck sees the development of a single national inventory as a crucial element of
the assessment strategy. Mr. Steffeck also agreed with EPA!s identification of air pollution as an
important sediment contaminant source.

Mr. Steffeck was concerned, however, that the Strategy might force federal and state
agencies to adopt a single set of bioeffects testing protocols. In Mr. Steffeck's opinion, EPA should
work with other agencies in developing comparable methods for bioeffects assessment and should
not demand conformity to a single bioeffects assessment method. The Strategy should recognize
that individual assessment methods are designed to meet individual program needs. Mr. Steffeck
believes that a single method would become obsolete over time, thus hampering future bioeffects
studies.

In addition, Mr. Steffeck suggested that the inventory of contaminated sediment sources
should evaluate nonpoint as well as point sources. Mr. Steffeek also recommended that the Strategy

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include a mechanism to ensure that assessment data are used efficiently in other components of the
Strategy. Mr. Steffeck feels that all too often assessment data do not play a central role in decisions
regarding the remediation of sediments.

3.2.2.5 Fred Cakler, Florida Department of Environmental Regulation

A collaborative effort between the State of Florida and NOAA has resulted in a
comprehensive survey of sediment and biological conditions along Florida's 11,000 miles of
shoreline. The survey effort has sampled sediments for metals contamination at over 700 sites and
organic contaminants at over 245 sites. The majority of these sites are located in estuaries adjacent
to cities and industrial areas. Florida also has issued guidelines for interpreting sediment chemical
data, and is in the process of developing preliminary sediment quality assessment guidelines for its
coastal waters.

Florida's sediment quality guidelines follow NOAXs "weight-of-evidence" approach to
deriving assessment guidelines, which is based on a variety of studies documenting biological effects
associated with sediment contamination.' Florida used the NOAA approach and augmented
NOAA's bioeffects data base with additional North American coastal biological effects data. Data
derived from a wide variety of methods and approaches were assembled and evaluated to derive
preliminary sediment quality guidelines for 25 priority contaminants in Florida coastal waters. The
numerical sediment quality guidelines were used to define three ranges of concentrations for each
of the 25 contaminants: a probable effects range, a possible effects range, and a no effects range.
A subjective assessment of the credibility of these guidelines indicated that a high level of
confidence could be placed on the guidelines derived for 11 substances and a moderate or low level
of confidence could be placed on the guidelines for the remaining 14 substances. The preliminary
guidelines will be fully evaluated and refined using the results of investigations conducted in Florida
and elsewhere.

The strengths of Florida's approach, according to Mr. Calder, are (1) the large data base
of biological effects from which the guidelines are derived and (2) the practicality of using
guidelines that define ranges of contaminant concentrations for screening a large number of sites
often having little biological data. The guidelines, however, are meant only as a measure of the
potential for biological effects; actual biological effects should not be directly inferred from the
comparison of site-specific sediment sampling data with the numerical criteria set forth in the
guidelines. Similarly, EPA should, in Mr. Calder's opinion, avoid drawing strong conclusions
regarding the bioeffects of contaminated sediment relying on chemical sediment criteria developed
using the EP approach.

Mr. Calder agreed with EPA that developing a national inventory is a critical step in the
overall Strategy but criticized EPA for not soliciting sufficient state input to the development of
criteria by which inventory data might be assessed. Mr. Calder worries about the inventory's
reliance on existing data. He asserts that existing data were collected for different reasons using

'NOAA. 1990. National Oceanic and Atmospheric Administration. Potential for Biological
Effects of Sediment-Sorbed Contaminants Tested in the National Status and Trends Program.
Technical Memorandum NOS OMA 52. Seattle, WA: NOAA.

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different methods and that this discrepancy in data sources may compromise the degree to which
sediment quality can be meaningfully compared between sites.

Mr. Calder also questioned the effectiveness of the Strategy in dealing with nonpoint
sources. According to Mr. Calder, nonpoint sources tend to lead to chronic rather than acute
bioeffects. Currently, science is ill-equipped to assess and predict the chronic bioeffects that might
result from long-term nonpoint source contamination. Also, Mr. Calder feels that the Strategy
should address the protection of areas with surface water resources that are fully viable today, but
that over time may deteriorate due to the accumulation of contaminants from nonpoint sources.
EPA may want to include in the Strategy a component emphasizing the importance of further
research on the chronic effects of sediment contamination.

Mr. Calder stated that EPA should look toward Florida's collaboration with NOAA as a
successful model of how state and federal agencies can work together in performing cost-effective
sediment assessments.

3.2.3 Formal Public Comment: Randall Ransom, Chemical Manufacturers Association
(CMA)

Randall Ransom, Chemical Manufacturers Association (CMA), expressed CMA's agreement
with the following elements of the draft Strategy:

0 Ranking contaminated sediment sites in priority so that scarce resources can be
allocated to sites with the greatest potential to cause adverse effects.

0 The commitment to improved human health and ecological risk assessment
methodologies.

0 The commitment to sound science and cost-effective assessment, prevention, and
remediation methods.

E The preference for natural remediation where such an option is consistent with
human health and environmental standards.

Mr. Ransom expressed CMA criticisms of the draft Strategy:

0 EPA must develop a scientifically sound definition of contaminated sediment before
finalizing the Strategy.

E The Strategy focuses on chemical criteria and inadequately addresses the
relationship between sediment contamination and bioeffects. National standards
must be able to account for site-specific conditions.

N The Strategy does not recognize the critical role of the states. Sediment
contamination is a water quality issue, and states have traditionally taken a lead role
in developing water quality related programs. CMA believes the Strategy should

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allow states to address sediment contamination issues as part of their normal waste
load allocation process during watershed permitting.

M The Strategy must address nonpoint sources in addition to already regulated point
sources.

a The development of a "hit list" of problem chemicals and sediment contamination
sources is a source of concern. CMA believes each site should be evaluated
separately, and not according to a predefined list of "problem" sources.

N CNIA believes that sediment contamination is a local hot spot problem, not a
national problem.

3.2.4 Open Discussion

3.2.4.1 Summary of Assessment Panel Concerns and Recommendation4

� EPA should clearly define what contaminated sediments are, prior to release of the
Strategy.

� The Strategy should focus more attention on the problem of nonpoint source
contamination.

� The Strategy should propose mechanisms for effective use of sediment assessment
data.

N The EPA should actively solicit state input and encourage greater coordination with
state agencies in Strategy development

� EPA should identify and promulgate consistent QA/QC protocols for sediment
sampling and bioeffects testing as part of the Strategy.

� Panelists were divided on the issue of a whole sediment testing approach versus a
numerical chemical criteria assessment approach.

� Panelists were also divided on the issue of whether the strategy should encourage
the adoption of uniform effects-based testing methods, or allow the development of
different but comparable effects-based testing methods.

'Not all panelists necessarily support the following concerns and recommendations.

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3.2.4.2 Questions Addressed to the Assessment Panel

Will other agencies be involved in developing standardized effects-based tests?

Dr. Southerland (U.S. EPA) responded that EPA will actively solicit federal and state
agency input throughout the development of effects-based testing protocols and numerical sediment
quality criteria. EPA has formed an Agency-wide workgroup to determine what types of effects-
based tests should be adopted for Agency-wide use. EPA will hold national workshops in
September 1992 and the first quarter of 1993 to discuss effects-based testing and the overall tiered
testing structure. Once the Agency has determined the most appropriate effects-based test
protocols, EPA's Science Advisory Board (SAB) will review the tests and make further
recommendations. The SAB review meetings will be open to the public. Unlike the sediment
quality criteria, the Agency does not need to publish its effects-based testing protocols in the
Federal Register for formal public comment.

Are EP-based chemical criteria in fact effects based?

Dr. Southerland said that because the criteria are derived from ambient water quality
criteria, they are, in essence, effects based. Ambient water quality criteria are based on acute and
chronic toxicity data. The EP approach assumes that benthic organisms in sediments are exposed
to contaminants via the interstitial water in sediments. The criteria EP methodology is used to
calculate threshold concentrations of contaminants in sediments that lead to interstitial water
contaminant concentrations equal to the ambient water quality criteria.

Can the EP-derived sediment quality criteria adjust to site-specific conditions?

Dr. Southerland answered that the EP approach incorporates site-specific data on crucial
determinants of bioavailability, such as organic content for nonpolar hydrophobic organic
contaminants and the presence of acid volatile sulfides for metals.

Is research being conducted on the effects of sediment contamination on larger organisms higher
in the food chain?

Dr. Mallard (USGS) replied that COE, FWS, and USGS are currently conducting such
research at a number of sites nationwide.

How will sediment quality criteria and effects-based test protocols be used in the Strategy?

Dr. Southerland noted first that the development and promulgation of criteria and biological
test protocols are on separate paths. Numerical criteria go through a lengthy regulatory approval
process; effects-based tests do not. Numerical criteria are developed under Section 304 of CWA
and thus must receive OMB approval and be published in the Federal Register for formal public
comment. Depending upon the EPA program, biological testing may not be subject to statutory
provisions and hence may not need to go through a formal approval process. The test protocols

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developed pursuant to EPA!s Sediment Strategy will not, in many cases, be legally binding. EPA
hopes, however, to procure federal and state agency agreements to use these protocols and
eliminate the current situation in which different EPA program offices and federal and state
agencies use different organisms to test for acute and chronic effects and bioaccumulation.

The application of the sediment quality criteria will depend on the particular statute under
which a given sediment contamination problem is being addressed (see response to similar question
in Section 3.3). Dr. Southerland also pointed out that states could adopt different numerical
criteria as long as they are "scientifically defensible."

3.3 PREVENTING SEDIMENT CONTAMINATION

3.3.1 EPA's Proposed Prevention Strategy

3.3.1.1 Judith A. Nelson, Office of Prevention, Pesticides, and Toxic Substances (OPPTS), U.S.
EPA

OPPTS administers the Office of Pesticide Programs (OPP) and the Office of Pollution
Prevention and Toxics (OPPT) which in turn administer the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and the Toxic Substances Control Act (TSCA). FIFRA and TSCA
provide EPA with the authority to review new chemicals and regulate existing chemicals. Only
recently has OPPTS begun to consider the potential for chemicals to accumulate and persist in
sediments. OPP is currently developing a strategy for evaluating sediment toxicity and its potential
ecological effects when processing pesticide registration, reregistration, and special reviews. If a
pesticide has the potential to bioaccumulate or persist in sediments, OPP may require additional
aquatic fate testing. OPP plans to revise pesticide test requirements in 40 CFR Part 158 and
protocols in the Subdivisions of the Pesticide Assessment Guidelines. OPP will use the national
inventory of sediment quality and incident reports to select certain pesticides, if warranted, for
special review. In addition, OPP will continue work on reducing pesticide use in general by
disseminating information on alternative pest management practices, providing technical support,
and conducting pest management research.

In a few cases, OPPT, under the authority of TSCA, has required manufacturers to submit
data on a chemical's propensity to accumulate and persist in sediment. A recent test rule for
brominated fire retardants (June, 1991) included sediment toxicity testing. Like OPP, OPPT plans
to use the national inventory as well as data from TRI to select chemicals for review. If OPPT
determines that a particular chemical contributes to sediment contamination and poses
unreasonable risks, OPPT can ban or regulate the use of that chemical. Through its New Chemicals
Review Program, OPPT encourapns manufacturers to design chemicals with molecular weights
greater than 1,000 to prevent absorption through molecular membranes, and with K. values either
greater than 8 for no effects at saturation or less than 3.5 to avoid partitioning to sediments.
OPPT's exposure-based review (EBR) policy for the New Chemicals Review Program requires
environmental effects and fate testing if certain criteria are met upon initial review.

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3.3.1.2 Stuart TuVer, Nonpoint Source Control Section, Office of Water, U.S. EPA

EPA!s nonpoint source control program has five main elements: CWA Section 319 grants
to states, the Clean Lakes Program, the Coastal Zone Act Reauthorization Amendments (CZARA),
and an agricultural pollution prevention initiative. States with EPA-approved nonpoint source
management programs can apply for Section 319 grants to fund implementation of projects
designed to address nonpoint source contamination of sediments. Section 319 grants have totaled
approximately $50 million in recent years, and EPA has set aside $800,000 in 1992 for nonpoint
source programs that deal specifically with sediments. Through the Clean Lakes Program, Section
314 of CWA provides grants to states that could be used to develop methods for controlling
nonpoint source contamination of sediments.

In 1990, EPA and NOAA issued proposed national guidance for nonpoint source controls
under CZARA. Farmers, land owners, and manufacturers located within the coastal zone (as
defined by CZARA) must implement best management practices (BMPs) to control nonpoint
source contamination of sediments and other media. BMPs will be determined on a best available
technology basis and are legally enforceable.

A memorandum of agreement signed in April 1992 between EPA and USDA commits the
two agencies to work together to draft a strategy for reducing agricultural nonpoint source
contamination. EPA and USDA will issue a detailed plan for program development and
implementation by October 1, 1992. Key components of the program will include nutrient, animal
waste, and pesticide management plans, and plans to protect critical habitats. The program will rely
on voluntary, educational, incentive, and enforcement tools to implement the various program
elements.

3.3.1.3 James Pendergast, Water Quality and Industrial Permits Branch, Office of Water, U.S.
EPA

EPA's point source control program has issued effluent guidelines for almost 20 years. To
date, effluent guidelines have not considered sediment quality, in part because of a lack of guidance
on how to derive acceptable effluent concentrations based on sediment quality. For the same
reasons, there are currently very few National Pollutant Discharge Elimination System (NPDES)
permits that contain effluent limits specifically tailored to achieve a high level of sediment quality.
With new guidance from EPA, states, and other federal agencies, the Office of Water hopes to
begin issuing NPDES permits based on sediment quality where effluent contaminants are likely to
accumulate and persist in sediments. EPA is developing guidance for relating effluent
concentrations to sediment quality and applying this guidance to field studies in Louisiana and Lake
Mchigan. The Office of Water hopes to use the national inventory of contaminated sediment sites
and other screening devices to determine which industrial sources to target for sediment quality-
based NPDES permits. The Office of Water also is actively engaged in researching BMPs to reduce
effluent discharges and control storrawater discharges.

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3.3.1.4 James Edward, Strategic Planning and Prevention, U.S. EPA

With the enactment of the Pollution Prevention Act of 1990, pollution prevention has
become the apex of the environmental protection hierarchy. The act directs EPA to incorporate
pollution prevention strategies in all of its regulatory programs. The Agency has identified 16 broad
regulatory categories (pesticides formulation; pulp and paper; degreasing operations; paints, coating,
and adhesives; rubber and chemicals; and others) in which to incorporate pollution prevention
approaches over the next 5 to 6 years. The act also requires EPA to develop a federal government
pollution prevention strategy for federal facilities. EPA's 33/50 program aims at achieving a 33
percent reduction in 17 high-priority toxic chemicals by the end of 1992 and a 50 percent reduction
by 1995. Currently, 236 companies participate in the 33/50 program.

Two policies recently drafted by the Office of Enforcement allow settlements to include
enforceable pollution prevention elements. Enforcement settlements will emphasize source
reduction and recycling actions that enhance the prospect for long-term compliance with applicable
regulations wherever possible. Over 100 settlements to date have included significant pollution
prevention elements. EPA hopes that all of these efforts will reduce pollutant loadings that result
in contaminated sediments.

3.3.2 Federal and State Agency Prevention Programs

3.3.2.1 David Farrelt, Ag7icultural Research Service (ARS), U.S. Department of AgTiculture
(USDA)

The Agricultural Research Service (ARS) has actively conducted research in the areas of
soil erosion control, pest control, and fate and transport of agricultural chemicals since 1953. More
recently, ARS has modeled aquatic systems to monitor the distribution, accumulation, and
dissipation of agricultural chemicals over time. During the 1980s, ARS worked with COE to assess
the availability and plant uptake of heavy metals from contaminated dredged materials placed in
flooded and upland environments. Also during the last decade, ARS undertook a number of
research projects to evaluate approaches for reducing contaminants in industrial food processing
effluents.

Research funded in fiscal year 1992 applicable to contaminated sediment prevention
includes:

M Revision of the Universal Soil Loss Equation (USLE), the Water Erosion Prediction
Project (WEPP), and the Wind Erosion Prediction System (WEPS) for predicting
the effects of tillage and residue management practices on soil erosion by water and
wind.

0 Development and evaluation of techniques to control soil erosion.

0 Development of livestock and crop management practices that reduce surface
loadings of contaminants.

M Research on the fate and transport of agricultural chemicals.

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� Field evaluations of no-tiflage and post-emergent herbicides which could reduce
runoff of agricultural chemicals.

� Development of methods for evaluating sources and extent of ecosystem
contamination.

� Evaluation of integrated pest management and biological pest controls as substitutes
for more traditional pesticides, fungicides, and herbicides.

E Evaluation of the ion exchange potential of a variety of agricultural residues, and the
utilization of hulls and hull components from oil seed and cereal crops to treat
industrial wastewater.

ARS's current research program coincides with many elements of EPXs prevention strategy.
In particular, ARS's emphasis on reducing the volume and mobility of agricultural chemicals in the
environment is consistent with EPA's prevention strategy. The previously mentioned memorandum
of agreement between USDA and EPA should facilitate interagency cooperation in preventing
sediment contamination from point and nonpoint agricultural sources. Dr. Farrell nonetheless feels
that a major weakness of the EPA Strategy is the absence of a well-defined plan for accommodating
USDA research, education, and technical assistance. Those aspects of the Strategy that deal
specifically with nonpoint source control could be strengthened by a closer working relationship with
the agricultural sector.

According to Dr. Farrell, there are many ways in which agencies such as the Soil
Conservation Extension Service, ARS, and EPA can work together on problems associated with
sediment contamination. Dr. Farrell listed options including interagency task forces and work
groups; collaborative research; and educational and technical assistance programs. ARS's strength
and experience in all the major disciplines associated with the production and processing of
agricultural products should be invaluable to EPA by ensuring that cost-effective alternatives to
regulation are developed and made available to producers and processors. Many of the scientific
questions raised by the Contaminated Sediment Management Strategy might be best answered by
ARS, in Dr. Farrell's opinion, using long-term controlled experiments performed collaboratively
with or under contract to EPA.

Dr. Farrell also emphasized that the EPA Strategy should not rely on simplistic analyses of
agricultural chemicals (such as amount used and concentrations found in sediments) to target
certain chemicals for regulation. Concentrations found to be harmful in some aquatic environments
may be acceptable in others. EPA should consider the potential benefits sediments may provide
in binding potentially harmful compounds until they degrade into harmless components. EPA also
should not underestimate the potential for no-tillage and post-emergent herbicides to reduce
nonpoint sources of sediment contamination. Dr. Farrell pointed out that a reduction in the total
amount of pesticides used will not necessarily result in better protection for people and the
environment since not all pesticides pose the same human health and environmental risks. Dr.
Farrell stated that a better measure of risk might be the "toxic!'Ioad of a given pesticide as opposed
to shear volume of active ingredient.

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3.3.2.2 Warren Harper, Watershed and Air Management, Forest Service, U.S. Department of
Agriculture

The Forest Service regularly monitors sediments produced as a result of land management
activities. It also devises prevention strategies for the National Forest on Forest Service lands.
Recent research by this agency has focused on physical characteristics of stream systems.
Understanding the relationship of geomorphology to stream flow and sediment loads may help in
assessing the impact of sedimentation on the aquatic environment and the ecological impacts of
anthropomorphic sediment contamination.

Mr. Harper warned against overreliance on modeling in the Contaminated Sediment
Management Strategy because of the large modeling errors associated with predicting natural events
and the spurious correlation errors that may result from a poor understanding of cause/effect
relationships. Typically, the Forest Service has relied on a case study approach to assessing the
impacts of land management practices (e.g., logging, grazing, mineral extraction, recreation, etc.)
on water and sediment quality on National Forests. Mr. Harper suggested that the Strategy provide
for this type of analysis as well.

According to Mr. Harper, nonpoint source pollution from land management activities may
result in increased sediment loading to aquatic systems from the National Forests. Land
management practices can be designed to reduce these sediment load increases to a level
compatible with water quality requirements. Hence, the Forest Service's strategy has centered on
prevention through use of BMPs. The agency's greatest difficulty has been in implementing
proposed BMPs to achieve water and sediment quality objectives. Monitoring and subsequent
feedback on BMP effectiveness is an essential component of successful BMP implementation. The
Forest Service coordinates its efforts with individual states that have the responsibility for
monitoring and adjusting defined BMPs. Mr. Harper believes that EPA!s greatest challenge in
managing sediments may be in devising effective monitoring programs and models capable of
accurate predictions.

3.3.2.3 James Burgess, Office of Ocean and Coastal Resource Managemen4 Coastal Programs
Division, National Oceanic and Atmospheric Administration (NOAA)

NOAA and EPA's Coastal Zone Management (CZM) program authorized by the Coastal
Zone Management Act is the only program that can legally enforce nonpoint source controls. The
CZM program requires states to devise and implement BMPs to control nonpoint sources in coastal
zones. Failure to implement these programs by the 1995 statutory deadline will result in financial
penalties to violating states. NOAA and EPA will issue a guidance document on BMPs including
specific recommendations for each state's coastal zones. The guidance will cover BMPs for
agricultural, urban, hydromodification, and marina nonpoint sources. Preliminary guidance was
issued in 1991.

Mr. Burgess stated that the CZM program has struggled with a number of important issues
that might be pertinent to the nonpoint source prevention aspects of EPA!s Contaminated Sediment
Management Strategy:

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The flexibility states should have in devising and implementing BMPs.

The appropriate time frame for implementation.

Enforcement of BMP implementation by the CZM program.

The sources of pollutants BMPs should target.

The appropriate boundary for a "coastal zone".

Mr. Burgess advised EPA to coordinate the Strategy with federal and state nonpoint source
pollution programs, including the new coastal nonpoint pollution control program.

3.3.2.4 Duane Schuettpelz, Wisconsin Department of Natural Resources

Wisconsin's Sediment Assessment and Remediation Techniques (SMART) program parallels
the EPA!s Contaminated Sediment Management Strategy in many respects. The SMART program
is presently conducting an inventory of contaminated sediment sites, uses sediment quality criteria
at some Superfund sites, and has an active pollution prevention component. Wisconsin employs
water quality standards, stormwater permitting, and hazardous air substances controls to aid in the
prevention of sediment contamination. The state also issues grants to local organizations for
devising innovative approaches to nonpoint source control.

Mr. Schuettpelz thinks the prevention component of EPA's Strategy is a strong proposal,
and he particularly approves of the information transfer and education elements. Mr. Schuettpelz
is encouraged that EPA plans to characterize the contribution of pesticides and other chemicals to
nonpoint source sediment contamination. EPA should make certain the potential ecological and
human health effects of these contaminants are characterized as well.

Mr. Schuettpelz had a number of suggestions for the EPA prevention strategy. Under the
NPDES program, Mr. Schuettpelz recommended that EPA reevaluate the priority pollutant list with
sediment contamination in mind. Mr. Schuettpelz claimed that EPA has been too restrictive in
reviewing NPDES permits and that states need greater flexibility so that they can implement
innovative solutions to water and sediment quality problems. CERCLA and RCRA remedial
investigations should evaluate the effects of sediment contamination on entire aquatic ecosystems
including terrestrial animals. Mr. Schuettpelz generally agrees with EPA's strategy for managing
nonpoint sources, but he would like to see more attention paid to the impacts of atmospheric
deposition on contaminated sediments and a more coherent results-oriented approach to
stormwater management. Mr. Schuettpelz feels that the nonpoint source program needs to be
better integrated with the stormwater program, and that the term stormwater needs to be more
clearly defined. He questioned whether stormwater was a nonpoint source or strictly permittable
point source.

Wisconsin supports EPA!s prevention strategy. Mr. Schuettpelz stressed, however, that the
Strategy should allow for quick and efficient solutions and accommodate "public policy risk taking."
Sediment contamination threatens delicate ecosystems across the country that, in many cases,
cannot wait for the completion of long and detailed studies. Mr. Schuettpelz strongly believes that

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the states are prepared to take the initiative with contaminated sediment management and should
have an important role within the EPA Strategy.

3.3.2.5 Craig Wilson, Bay Protection and Toxic Cleanup Program (BPTCP), California State
Water Resources Control Board

The Bay Protection and Toxic Cleanup Program (BPTCP) gave the State Water Resources
Control Board (the Board) a mandate to develop a data base of all available information on
sediment contamination in California. Recognizing the large number of sites in California, the
BPTCP also directed the Board to develop qualitative and quantitative sediment quality criteria by
which to rank sediment sites. The BPTCP will expand the Board's monitoring and surveillance
program for sediments. The Board will integrate information from its inventory of contaminated
sediment sites, sediment criteria development effort, and monitoring program to develop plans for
establishing cleanup levels and remediating targeted sites, preventing further point and nonpoint
contamination, and identifying responsible parties. Parties responsible for point and nonpoint
sediment contamination will help pay for the BPTCP through a fee system.

Mr. Wilson believes that the BPTCP mirrors the EPA Strategy in many respects, and
commended EPA for developing a strong, coherent approach to the sediment contamination
problem. Mr. Wilson feels that the ideas expressed in the Strategy for incorporating pollution
prevention into new chemical testing and enforcement are particularly commendable. The greatest
weakness of the Strategy lies in its preoccupation with point sources. Mr. Wilson doubts that
additional point source controls will make a large difference in the overall contaminated sediments
problem without an aggressive program to reduce nonpoint source contaminants. EPA's nonpoint
source control strategy should encourage implementation of BMPs though education, regulatory
incentives, and command and control permitting. Mr. Wilson feels that although the Strategy
advocates intra- and interagency coordination, it does not provide any guidance concerning this
coordination. Finally, Mr. Wilson echoed earlier speakers in stating that the Strategy should clearly
define the potential role of sediment quality criteria in managing contaminated sediments under
different environmental statutes.

3.3.3 Open Discussion

3.3.3.1 Summary of Prevention Panel Concerns and Recommendations'

0 EPA should not underestimate the ability of sediments to act as a natural
mechanism for trapping contaminants and rendering them harmless to other
environmental media over time,

E The Strategy should recognize the danger inherent in overreliance on models and
recognize the value of case study approaches in understanding contaminated
sediment problems.

Not all panelists necessarily support the following concerns and recommendations.

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0 The Strategy should include stronger provisions addressing nonpoint sources.

0 The Strategy should state clearly how EPA intends to use sediment quality criteria
in its programs.

M EPA should expedite approval and implementation of the Strategy and balance the
need for further research with the need for quick policy actions.

E The Strategy should identify ways in which federal and state agencies can work
together, avoid duplication of efforts, and provide prompt and efficient solutions to
contaminated sediment problems.

3.3.3.2 Questions Addressed to the Prevention Panel

How will numerical sediment quality criteria affect current assessment, prevention, and
remediation efforts?

Dr. Southerland (U.S. EPA) stated that the criteria will have different functions under
different statutes. For example, CERCLA requires that remediation plans include all applicable
rules and regulations (ARARs). Sediment quality criteria would become another ARAR governing
sediment remediation. They would not, however, necessarily determine cleanup levels at a given
site. Remediation plans under RCRA and CERCLA must incorporate cost, technical feasibility,
and other considerations as well. Preventive actions taken under the CWA, however, cannot take
into consideration economic factors. NPDES pen-nits issued under the CWA must meet ambient
water quality standards and other applicable criteria designed to protect human health and the
environment. EPA's Strategy includes provisions to issue NPDES permits based on sediment
quality criteria when necessary.

Mr. Wilson (State of California) pointed out that California has used its "narrative" and
quantitative sediment quality criteria to prevent pollution. California also will have a separate
ranking system that includes both sediment criteria and cleanup levels. Mr. Wilson felt that, while
in some circumstances it is useful to have stringent numerical criteria, cost and feasibility issues also
must play a role in determining prevention and remediation actions.

Dr. Farrell (USDA) reiterated that numerical criteria should account for site-specific
conditions such as the potential bioavailability of contaminants, salinity, and other relevant
ecosystem variables. Dr. Southerland responded that the criteria can be adjusted to account for
organic content and the presence of acid volatile sulfides, and reiterated that sediment quality
criteria alone will not always drive preventive and remedial actions at a given site.

41hy doesn't the Strategy propose a more stringent regulatory approach for the control of
nonpoint sources?

Mr. Tuller (U.S. EPA) remarked that EPA does not currently have the statutory authority
(with the exception of the Coastal Zone Management Act [CZMAJ) to regulate nonpoint sources.
Given statutory limitations, EPA's nonpoint source control programs have relied on educational,
voluntary, and economic incentives rather than on the more traditional "command and control"

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approach. Even with statutory authority, Mr. Tuller believes that the very nature of nonpoint
sources makes the command and control approach difficult to implement. Mr. Tuller argues that
one of the principal reasons why CWA reauthorization was initially vetoed in 1987 was controversy
over nonpoint source control provisions. Mr. Tuller, however, is optimistic that Congress will adopt
approaches to nonpoint source control like those in the CZMA during upcoming CWA
reauthorization.

Mr. Schuettpelz (State of Wisconsin) commented that little actual improvement in sediment
quality will be accomplished in issuing more restrictive NPDES permits for point sources. Mr.
Schuettpelz thinks that given existing analytical technology, the current ambient water quality
criteria are sufficiently stringent to protect sediments from further point source contamination. The
greatest threat to sediment quality is from nonpoint sources; hence, the greatest gains in sediment
quality could be made by implementing an aggressive nonpoint source control strategy. Dr.
Southerland stated that although nonpoint source control will result in major improvements in
sediment quality, significant improvements in sediment quality could be achieved by revising
NPDES permits based on sediment quality criteria for some industrie:s, stormwater sewers, and
combined sewer overflows.

3.4 REMEDIATION OF CONTAMINATED SEDIMENTS

3.4.1 EPA's Proposed Remediation Strategy

3.4.1.1 Richard Nagle, U.S. EPA Region V

Mr. Nagle stressed that no single environmental statute was designed to address
contaminated sediments in particular; thus, the EPA cannot rely on a single "silver bullet" to
enforce remediation by responsible parties. Nonetheless CWA, CERCIA RCRA TSCA, the
Rivers and Harbors Act, and the Oil Pollution Act all contain provisions that, under the appropriate
circumstances, can compel responsible parties to contribute to the cleanup of contaminated
sediments.

Because contaminated sediments occur in such diverse circumstances, enforcement agencies
must have a detailed understanding of the many enforcement statutes at their disposal in order to
recover all or part of the significant costs of remediation. The case of Sheboygan Harbor, for
example, is relatively simple, with only a couple of potentially responsible parties (PRPs) and one
or two major contaminants of concern. Indiana Harbor and Ship Canal, on the other hand, have
a "veritable soup of contaminants" and hundreds of PRPs. Region V's enforcement strategy must
be highly flexible and innovative to deal with such diverse circumstances. Region V recently
instituted a Geographic Enforctinent Initiative that targets large areas for remediation and
prevention actions, prioritizes sites for remediation, and ensures timely solutions to contaminated
sediment problems. In closing, Mr. Nagle asserted that any remediation and prevention effort must
be backed up with a credible enforcement threat, regardless of the complexity of the site and
cooperation of PRPs.

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3.4.1.2 Lawrence J. Zaragoza, Office of Emergency and Remedial Response, U.S. EPA

Because of the expense associated with contaminated sediment site cleanup, Dr. Zaragoza
emphasized that most contaminated sediment cleanup will occur at sites that are on. the National
Priorities List (NPL). Once a site is placed on the NPI, it is eligible for remedial funding, which
is typically associated with long-term cleanup.

Sites are typically placed on the NPL following an evaluation with the Hazard Ranking
System (HRS), which assigns points to nominated sites based upon the severity of contamination.
The revised HRS (promulgated in 1990) provides for explicit consideration of sediment
contamination at sites. Dr. Zaragoza stated that an inventory of sites with contaminated sediments
may be evaluated with the HRS to determine if these sites warrant placement on the NPL.

An Agency-wide workgroup is developing a consistent tiered testing method for the
evaluation of contaminated sediments. Following completion of this methodology, the Superfund
program will probably develop some additional guidance that would be applicable to Superfund
sites. The Superfund process generally includes comparisons to background levels, human health
risk ranges, and various ARARs (used as Maximum Contaminant Levels [MCLs]) to determine
cleanup levels.

3.4.1.3 Denise Keehner, Office of Solid Waste, U.S. EPA

Ms. Keelmer stated that while many are aware of EPA's Superfund program, few are aware
of EPA's cleanup program under RCRA. Owners and operators of RCRA waste management
treatment, storage, and disposal facilities are responsible for cleaning up current as well as historical
coniamination at their facilities. Once EPA conducts an initial investigation of a RCRA facility and
determines that a release is occurring or has occurred at the site, the owner/operator of the site is
responsible for conducting a more detailed investigation and taking necessary remedial actions. Of
the 4,500 facilities covered by the RCRA program, EPA expects an estimated 3,600 will require
some level of remediation at a cost of approximately $200 billion over the next several decades.
Contaminated sediment is not uncommon at these RCRA sites and will no doubt account for a
significant proportion of remedial costs. Ms. Keelmer stated that the RCRA program intends to
use the national inventory of sediment quality to help prioritize RCRA facilities for remedial
actions.

Where appropriate, EPA currently requires owner/operator investigations to evaluate
sediment quality. If tiered testing protocols are adopted by the Agency, the RCRA program would
probably include them as guidance to owner/operators for evaluating the nature and extent of
sediment contamination. The RCRA program also would consider adopting any numerical
chemical criteria that the Agency proposes.

3.4.1.4 Tony Baney, Chemical Regulations Branch, U.S. EPA

The PCB Program under TSCA controls the manufacture, processing, distribution, use, and
disposal of polychlorinated biphenyls (PCBs). This program administers the broadest control over
a single contaminant exercised by any federal government agency. Although the PCB program has

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a great deal of authority to manage PCBs, a number of other statutes (CWA, CAA, RCRA
CERCLA, etc.) have authority to control the disposal of PCBs and remediate PCB contamination.
Mr. Baney spends much of his time coordinating PCB regulatory efforts between TSCA and other
statutes, including state statutes.

Formerly, under TSCA's PCB disposal rule, sediment was the only medium that could be
remediated based on site-specific risks. Other PCB-contaminated media were subject to disposal
criteria specific to the medium in which the contamination occurred, regardless of risks specific to
the site. For example, PCB contamination of ground water would be subject to one set of criteria;
soil contamination to another. Modifications to the PCB disposal rule will allow EPA to combine
all media into one remediation category, so that management decisions can be made on a site-by-
site basis.

The Agency hopes to propose a unified strategy for PCB management by the end of 1992.
This strategy would contain provisions addressing PCB contamination of sediments. A recent
investigation found that 244 of 1,218 Superfund sites have PCB contamination, much of which is
found in sediments.

3.4.2 Federal and State Agency Remediation Programs

3.4.2.1 Bnwe Kimmel, Oak Ridge National Laboratory, Department of Energy (DOE)

DOE has entered into "federal facility agreements" with several states and EPA to
coordinate the implementation of remedial actions at DOE facilities nationwide. The overall goal
of the DOE Environmental Restoration Program is protection of human health and ecological risk
reduction. The DOE Oak Ridge Reservation in Tennessee has slated three large facilities (the Oak
Ridge National Laboratory, Y-12 Plant [weapons manufacturing], and K-25 Plant [gaseous diffusion
plant]) for remediation. Some contaminants have migrated from waste sites at these facilities and
into stream, river, pond, and reservoir sediments both on and off site. The primary contaminants
of concern are PCBs, metals, and radionuclides. The presence of radioactive and mixed wastes
(hazardous and radioactive) poses a particular challenge at many DOE sites, including Oak Ridge.

In September 1990, an ongoing remedial investigation of the Clinch River revealed higher-
than-expected levels of cesium-137 in the near-surface sediments of the White Oak Creek
Embayment (WOCE) located on the DOE Oak Ridge Reservation. This discovery raised concern,
because the WOCE surface sediments could be eroded and transported downstream into public
waters. Therefore, the DOE initiated a "time-critical" CERCLA action to prevent further migration
of these contaminated sediments. With the cooperation of the Tennessee Valley Authority (TVA),
COE, EPA Region IV, and the State of Tennessee, a sediment-retention dam was constructed to
gain control of these sediments. Dr. Kimmel touts this "time-critical" action as an excellent example
of the benefits of interagency cooperation and a model of how agencies can work together to
provide immediate solutions.

A second example of such cooperation involved the organization of an interagency working
group for Watts Bar Reservoir, which has received some contaminants from Oak Ridge. When
investigations determined that contaminants from the Oak Ridge Reservation were present in the
Watts Bar sediments, DOE, COE, EPA, TVA, and the State of Tennessee formed a working group

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to screen permit applications for reservoir-use activities that had any potential for disturbing
contaminated sediments. DOE has since worked closely with TVA in the remedial investigation
of Watts Bar Reservoir to effectively utilize the expertise of the two agencies.

Dr. Kimmel was pleased to see an emphasis in the proposed Strategy on evaluation of risks
and, in particular, the comparison of baseline risks to the risks associated with remediation. Dr.
Kimmel feels that recognition of the importance of natural recovery processes and the inclusion of
national sediment quality criteria are also strong points of the Strategy.

Dr. Kimmel made the following recommendations for the remediation strategy:

0 Employ the best science possible with a solid measure of common sense and realism
in developing solutions to contaminated sediment problems.

0 Resolve the discrepancy between regulation-driven and risk-based remediation
decision-making. Dr. Kimmel defined regulation-based decision-making as that
which relies solely on statutory guidelines and criteria. Risk-based decision-making,
on the other hand, uses the outcome of risk and cost-effectiveness analyses to make
remedial decisions. Dr. Kimmel would like to see a greater emphasis on risk-based
decision-making in the Strategy.

0 Avoid the tendency to be overly conservative in conducting health and ecological
risk analyses. Multiple layers of conservatism are inherent in the risk assessment
assumptions and methodologies.

0 Employ risk screening methods and the observational approach to focus
investigations and expedite remediation processes.

3.4.2.2 Norman Francingues and Joe Wilson, U.S. Army Corps of Engineers (COE)

Mr. Francingues began his presentation by outlining COE's major research projects aimed
at garnering a better understanding of dredging, disposal, and treatment technologies for
contaminated sediments:

0 The Great Lakes Confined Disposal Facility (CDF) program has constructed CDFs
in the Great Lakes region.

E The Disposal Area Monitoring System (DAMOS) program in New England has
examined the impacts of dredged material disposal in coastal waters. The program
led to advances in capping technologies.

0 The Puget Sound Dredged Disposal Analysis (PSDDA) program provides Puget
Sound with a model for predicting impacts of unconfined dredged material disposal.

0 COE assisted in developing the New York-New Jersey Comprehensive Dredged
Material Management Plan, which provides alternatives to open ocean disposal.

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� The Field Verification Program (FVP) with EPA has produced invaluable
information on the effectiveness of open water, upland confinement, and wetland
creation disposal alternatives for highly contaminated sediments.

� The Dredged Material Research Program investigated numerous topics of interest
to identify, assess, and manage contaminated sediments associated with navigation
dredging projects. The program resulted in first-generation procedures for
evaluating the physical, chemical, and biological impacts of a variety of disposal
alternatives on water, land, and wetland areas. The program demonstrated the
viability and limits of new disposal alternatives, including the use of dredged
material as a natural resource.

� The Long-Term Effects of Dredging Operations (LEDO) program provides the
state-of-the-art technology for predicting long-term environmental impacts of
dredging and management of contaminated sediments and developing methods for
minimizing impacts associated with dredging activities.

� The Improvement of Operations and Maintenance Techniques (IOMT) program has
resulted in general guidance for selection of equipment and techniques for dredging
contaminated sediments to achieve a high level of precision and minimal
resuspension.

Mr. Francingues discussed COE's research at New Bedford Harbor and extensive
involvement in the dredging and dredged material disposal pilot project there. Dredging and
disposal of contaminated sediments had never been conducted on such a scale before, and Mi.
Francingues called the pilot project "a pioneering effort." COE concluded from the pilot project
that readily available dredging equipment and management techniques were sufficient to control
resuspension of contaminated sediment during dredging and to isolate contaminated sediment in
onsite disposal facilities. The New Bedford Harbor Superfund project was a venture between EPA
Region I, the Commonwealth of Massachusetts, and COE. COE plans to remain highly involved
in demonstration and full-scale remediation projects of this type.

Mr. Wilson began his part of the presentation by explaining that, until quite recently, COE
did not have the authority to remediate contaminated sediments on its own initiative. Throughout
the 1980s, however, COE was involved in many cleanup efforts under interagency agreement with
EPA (New Bedford Harbor, Commencement Bay, Waukegan Harbor, Sheboygan Harbor,
Marathon Battery Site, Upper Hudson River, and others). In 1987, Congress created the
Assessment and Remediation of Contaminated Sediments (ARCS) program to assess the extent of
sediment contamination in the Great Lakes and demonstrate bench-scale treatment technologies.
COE has taken the lead in designing and implementing engineering and treatment technologies for
the ARCS program.

The 1990 Water Resources Development Act (WRDA) expanded COE's. authority to dredge
and remediate contaminated sediments and directed COE to include environmental protection as
a primary mission in planning, designing, constructing, operating, and maintaining water resource
projects. WRDA also authorizes COE to actively contribute to the restoration and maintenance
of the chemical, physical, and biological integrity of the nation's waters. COE can now initiate
"clean up" dredging adjacent to and outside authorized federal navigation channels. Prior to 1990,

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COE could only initiate dredging activities within the bounds of a federal navigation channel. This
restriction prevented COE from remediating contaminated sediments outside the navigation channel
that acted as a continuing source of contamination to the channel. Mr. Wilson believes that this
authorization will allow COE to implement more permanent and less piecemeal solutions to
contaminated sediment problems in harbors and estuaries.

COE has had some difficulty in implementing this new authority because of questions of
liability. COE does not want to dredge contaminated sediments outside of navigational boundaries
without having identified responsible parties for cost recovery. Finding responsible parties can be
extremely difficult at many sites. In Mr. Wilson's opinion, EPA should examine liability issues in
sediment remediation so that COE and COE subcontractors can implement remedial actions
outside of navigational channels without assuming total liability for the cleanup.

3.4.2.3 Keith Phillips, Sediment Management Unit, Washington Department ofEcology (Ecology)

In 1991, the Washington Department of Ecology (Ecology) adopted a sediment management
strategy to deal with contaminated sediments in Puget Sound and other areas of Washington State.
In addition to assessment and prevention provisions, the strategy promulgated sediment quality
criteria known as Sediment Management Standards. The rule established narrative, chemical, and
biological criteria for use in existing source control programs and remedial actions. Recognizing
the need for regulatory flexibility in addressing contaminated sediment problems, Ecology proposed
two sets of sediment quality standards: a "no effects" level and a "minor adverse effects" level. The
former standard establishes a sediment quality goal below which contaminants in sediment should
have no adverse effects on aquatic life and human health. The "minor adverse effects" level
considers engineering feasibility and cost factors and acts as an upper bound for regulatory
decisions. Ecology will mandate cleanup levels and source control actions that fall between these
two standards based on net environmental effects and cost/feasibility tradeoffs.' Because the
standards apply to discharges and dredged material disposal as well, Ecology has ensured that
permitted discharges and dredged material disposal sites will not become cleanup sites in the future.

The Washington standard provides allowances for both ongoing contamination and natural
recovery. For ongoing discharges, the state can authorize an area outside the discharge outfall
known as a "sediment impact zone" within which the discharge can exceed the lower "no effects"
standard but not the higher "minor adverse effects" standard. The standard also allows the state
to use natural recovery as an acceptable remediation technique providing it reduces sediment
contamination to below the "minor adverse effects" level within 10 years.

Ecology has yet to resolve some critical liability and nonpoint source issues. For example,
should landowners be able to dictate the terms of discharge permits when such permits allow for
continuing sediment contamination on their land? Landowner approval of discharge permits could
result in the landowner holding the discharger hostage. Ecology also has not determined how to

"Ecology also has established five standard biological "interpretive guides" which can either
override or confirm the chemical criteria. Mr. Phillips stated that 3 times out of 10 chemical
criteria predicted adverse effects when biological tests did not.

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establish sediment impact zones for nonpoint source runoff from cities and highways and how to
assign liability for future cleanup of such areas. The issue of managing stormwater discharges and
future cleanup of sediment impact zones also has not been resolved.

In commenting upon EPA's Contaminated Sediment Management Strategy, Mr. Phillips
noted that the overall remediation strategy is quite strong, and he supported the emphasis on
prevention, risk-based analysis, natural recovery, and cost and feasibility considerations. He feels,
however, that the Strategy fails to address some critical issues, such as how to deal with oil spills,
persistent ongoing discharges (e.g., stormwater), and lack of disposal capacity.' The Strategy also
should address the impact of designating contaminated sediment sites for remediation on routine
construction and maintenance activities at the site. Mr. Phillips believes that construction and
maintenance of docks, piers, and other aquatic structures will be deterred at sites with contaminated
sediments because of liability concerns. That is, landowners may resist making improvements to
aquatic structures for fear of being assigned full or partial liability for sediment remediation costs.

Mr. Phillips also was concerned that remediation strategies employing natural recovery
might be thwarted because of the natural resource damages provisions in various environmental
statutes. Natural resource damages provisions often make immediate cleanup a more attractive
alternative than natural remediation, since natural remediation in many cases may require several
decades. This potentially lengthy process increases the number of years over which damage to
natural resources can occur. Responsible parties may wish to solve the problem immediately rather
than be liable for additional years of resource damages.

Finally, Mr. Phillips suggested that the Strategy explore the potential for state regulatory
agencies to integrate authorities to achieve additional cleanup through state lease renewal actions
for docks, piers, and other aquatic structures. Washington has been very successful in collecting
additional cleanup resources during real estate transactions involving a site with contaminated
sediments.

3.4.3 Formal Public Comment: Ellen Fisher, Wisconsin Department of Transportation

Wisconsin maintains 14 commercial harbors, which receive and discharge more than $7
billion in cargo each year. Dredging activities in these harbors have been paralyzed by "bureaucratic
gridlock" over the management of contaminated sediments. An additional inch of sediment in
shipping channels forces reduction of the average shipping load by approximately 200 tons. Ms.
Fisher was pleased that EPA's Contaminated Sediment Management Strategy promises to
encourage greater cooperation and integration of the many agencies that manage contaminated
sediments, but she would like to see these promises acted upon. The key to finding suitable
contaminated dredged material disposal sites in a timely manner is cooperation among the
regulatory agencies and early and continuous involvement of the local project sponsor. This effort
also requires a willingness of regulators to coordinate their efforts and to engage in a problem-
solving partnership with the local project sponsor.

'Mr. Phillips estimated that between 30 and 70 million cubic yards of sediment will require
remediation. The State of Washington currently has about 2 to 3 million cubic yards of disposal
capacity for contaminated sediments.

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Ms. Fisher stressed that sediment contamination threatens the viability of Wisconsin's
harbors now, and these harbors are running out of disposal capacity. A partnership among
Wisconsin, EPA, and local harbor authorities should be formed immediately to find suitable
disposal sites.

Ms. Fisher stated that Wisconsin and the Port of Milwaukee would like to serve as a Great
Lakes demonstration project to test the proposed Strategy. The International Joint Commission
has designated Milwaukee's harbor as an area of concern. The city has engaged in the development
of a remediation plan to identify disposal options for the harbor's contaminated sediments. The
Port Authority of Milwaukee would welcome EPA's assistance in solving the contaminated sediment
problem and fending off the disastrous consequences of port closure.

3A.4 Open Discussion

3.4.4.1 Summary of Remediation Panel Concerns and Recommendations'

N The Strategy should clearly state that the bottom line of contaminated sediment
remediation should be human health protection and ecological risk reduction.

0 Risk assessment analyses that are too conservative can paralyze remediation actions
and lead to high costs with little marginal benefit. The Strategy should condone the
use of more liberal risk assessments.

0 Liability issues have prevented cleanups at a number of sites. The Strategy should
address liability issues and explore ways in which liability laws can be altered to
facilitate more timely remedial actions.

M EPA should provide a more detailed account in the Strategy of how it plans to
implement the remediation of contaminated sediment.

0 The Strategy should address oil spills, contaminated dredged material disposal
capacity, and liability issues regarding construction and maintenance of docks, piers,
and other aquatic structures at contaminated sediment sites.

M The Strategy should include guidance on managing sediment contaminants in storm-
water discharges and implementing cleanup of sediment contaminated by nonpoint
source pollution.

M The Strategy should examine the effect of natural resource damage settlements on
the natural recovery alternative.

'Not all panelists necessarily support the following concerns and recommendations.

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3.4.4.2 Questions Addressed to the Remediation Panel

Who is responsible for planning for adequate contaminated sediment disposal capacity?

Dr. Zaragoza (U.S. EPA) responded that disposal capacity must be addiessed by states.
States are required to develop plans that show how the hazardous wastes generated within their
borders can be managed. While capacity assurance plans only address hazardous wastes (all
sediments are not expected to fall into this category), Dr. Zaragoza suggested that by examining
the generation of waste and disposal capacity, states could better identify shortfalls in capacity for
the treatment and disposal of contaminated sediments. Mr. Phillips (State of Washington) agreed
with Dr. Zaragoza on this point, although he feels that there should be some level of federal cost
sharing for disposal capacity planning. The State of Washington is currently examining the liability,
contingency, and indemnification issues of contaminated sediment disposal. Mr. Wilson (COE)
added that EPA!s Strategy should call for more research on remediation alternatives that do not
require confined disposal (i.e., capping, in situ chemical treatment, solidification, open disposal,
ete.)_

"at elements of the StrateAy provide for risk assessments that may be too conservative?

Dr. Kimmel (DOE) feels that the EPA risk assessment guidance requiring remediation to
yield incremental cancer risks of 10' for the maximally exposed individual are too conservative.
Dr. Kimmel stated that, in the case of radionuclides, natural background levels in most areas of the
world yield incremental cancer risks in the 10' range. Investigators at Oak Ridge National
Laboratory are using an approach similar to that of the State of Washington, in which lower-bound
risk estimates using conservative assumptions and upper-bound estimates using more realistic
assumptions are established. Dr. Kimmel undorstands that conservative risk assessments diminish
the potential for underestimating risks due to uncertainties, but noted that the upper-bound risk
estimates are both more realistic and appropriately conservative. Unfortunately, multiple layers of
conservatism can paralyze efforts at efficient and timely remedial actions. Dr. Zaragoza commented
that the Superfund target risk range of 10' to 10' is sufficiently flexible to provide for public health
protection. He stated that higher risk levels may not be protective of public health.

3.5 EPA RESPONSE TO FORUM RECOMMENDATIONS

Dr. Southerland (U.S. EPA) reiterated EPA!s intention to incorporate oral and written
comments into the Strategy and offered the following responses to forum recommendations:

3.5.1 Assessment

� EPA fully intends to use all existing data on sediment contamination in developing
the national inventory of contaminated sediment sites and sources.

� EPA recognizes the importance of identifying methods that the Agency will use in
I
consistent tiered testing of contaminated sediments and sharing those methods and

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associated QA/QC data with other federal and state agencies. EPA will sponsor two
workshops in the next 6 months on standardizing biological-effects testing methods.

3.5.2 Prevention

0 EPA will ensure that Section 319 (nonpoint source program) grants to states will
continue to promote nonpoint source controls for sediment contamination. EPA
will specifically target $800,000 of the 319 grant funds in 1992 to states interested
in developing BMPs that prevent nonpoint source contamination of sediments.

0 EPA will address nonpoint source contamination of sediments through its agreement
with USDA to implement an interagency agricultural pollution prevention strategy
and througA the regulatory provisions of the Coastal Zone Management Act.

3.5.3 Remediation

0 EPA will carefully examine the risks of remediation versus the risks of natural
recovery at all sites.

0 EPA will look into solving liability issues that currently hamper remediation efforts
at many sites nationwide.

0 EPA will examine the disposal capacity issue and try to find innovative solutions to
that problem.

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CHAPTER FOUR

OUTREACH AND PUBLIC AWARENESS

4.1 INTRODUCTION

The forum on outreach and public awareness was the third and final forum sponsored by
EPA!s Office of Water for the purpose of gathering information and soliciting feedback on the
Agency's Contaminated Sediment Management Strategy. This forum was held June 16, 1992, in
Washington, DC, and attendees included representatives from industry, states, municipalities, EPA
program offices, environmental organizations, public interest groups, and consulting and legal firms.

Section 4.1 summarizes opening presentations that set forth the forum's goals and objectives,
and provides an overview of EPA!s proposed outreach and public awareness activities related to the
Strategy. Section 4.2 presents summaries of presentations made by representatives of state
government (4.2.1), the regulated community (4.2.2), environmental advocacy groups (4.2.3), and
a public awareness group (4.2.4), and concludes with a presentation from a representative from
EPA headquarters on the National Environmental Education Act (4.2.5). This section summarizes
key points made by the presenters and in the question and answer sessions following each group.
Section 4.3 concludes with broad impressions of the overall dialogue.

4.1.1 Welcome, presented by Elizabeth Southerland, Risk Assessment and Management
Branch, Office of Water, U.S. EPA

Elizabeth Southerland, Chief of EPA!s Risk Assessment andManagement Branch, Office
of Water (OW), began the forum with welcoming remarks and an overview of the Agency's
Contaminated Sediment Management Strategy. She briefly described EPA's goals for and
conclusions from the first two forums and expressed the Agency's pleasure at the attendance of
approximately 120 people at each one. The two major conclusions from the first forum were (1)
contaminated sediments are a national problem, and (2) case studies have documented harm to
human health and the environment. Conclusions from the second forum included the following:

E EPA should expedite implementation of the Strategy.

N The development of a national inventory of contaminated sediment sites is a high
priority, and a number of federal and state agencies have quality data to contribute.

0 More attention should be paid to nonpoint sources; many participants felt the
Strategy places too much emphasis on point sources.

N Sediment toxicity and bioaccumulation are high priorities to be addressed under the
Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA).

_109-

The Strategy should be integrated among all federal agencies, either through a
federal task force or through memoranda of agreement or understanding.

Dr. Southerland also informed participants that the proceedings containing summaries of
all three forums would be available in late Fall 1992. She emphasized that this report would serve
as the public record for comments concerning the Strategy from these meetings.

4.1.2 Forum Overview, presented by Charles Menzie, Menzie-Cura & Associates

Charles Menzie, Menzie-Cura & Associates, served as the forum moderator, and opened
by presenting the forum goals and introducing its key participants. Dr. Menzie commented on the
diversity of the audience in attendance, which included members of the regulated community, states,
municipalities, environmental groups, and the general public. He stressed that the forum's most
important goal was hearing comments from the Strategy's key audiences on the information they
would need to implement and comply with the Strategy. In addition to the speakers on the agenda,
Dr. Menzie appealed to other members of the audience to comment on how EPA could assist them
in communicating the Strategy's key messages to their constituents. He also emphasized that the
Strategy does not exist in isolation and that one of the most important issues to consider is how to
integrate the Strategy's components into a larger message on management of water bodies.

4.1.3 EPA's Proposed Outreach Activities to Support Implementation of EPA's
Contaminated Sediment Management Strategy, presented by Tom Armitage, Risk
Assessment and Management Branch, Office of Water, U.S. EPA

Tom Armitage, of EPA!s Office of Water, presented an overview of EPA!s proposed plan
for the outreach component of the Strategy. (The proposed outreach activities are included in this
document as Appendix B.) Dr. Armitage stressed that outreach is a critical component of the
Strategy, because of the importance of public understanding and support in . Strategy
implementation. He reiterated EPA!s desire to obtain feedback from all speakers and participants
at this meeting, so that the Agency could craft an outreach plan that would be most useful to its
audiences. He noted that in implementing the Contaminated Sediment Management Strategy, EPA
intends to build on existing successful outreach programs in which the government has worked with
public and private interests, such as the Chesapeake Bay Citizen's Advisory Committee (described
in more detail in Frances Flanigan's presentation, Section 4.2.4.1), the National Estuary Program,
EPA public-private partnership programs, and the RCRA public outreach program.

The primary goal of EPA's contaminated sediment outreach program is to educate key
audiences about the risks, extent, and severity of contaminated sediments; the role of the Strategy
in solving the contaminated sediments problem; and how stakeholders will be involved in Strategy
implementation. The proposed outreach plan has four key elements: (1) defining key Strategy
themes and messages; (2) identifying target audiences and needs; (3) developing appropriate
materials such as guidance documents, brochures, and videos; and (4) providing channels to
facilitate two-way communication on Strategy issues. Targeted audiences include environmental
and public interest groups, the scientific community, congressional representatives and committees,
federal agencies, states and municipalities, EPA program offices and regions, the regulated

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community, and the news media. Outreach materials will be developed for broad audiences and
specific subgroups within those audiences.

Dr. Armitage outlined four messages for the outreach program to convey, which are closely
linked to the goals of the Strategy itself-

E Sediment contamination poses threats to human health and the environment.

0 Sediment contamination comes from many sources, both point and nonpoint.

0 An effective program to address sediment contamination will focus upon assessment,
prevention, and remediation activities.

E EPA!s Strategy relies on intra-agency coordination to consistently and efficiently
make decisions, characterize risks, and employ resources. It also will be necessary
for EPA to work closely with other federal and state agencies.

Dr. Armitage mentioned that EPA is already working with other federal and state agencies,
including the National Oceanic and Atmospheric Administration (NOAA) and the United States
Geological Survey (USGS) in monitoring efforts, and the United States Department of Agriculture
(USDA), Department of Defense (DOD), and Department of Transportation (DOT) in promoting
remediation and prevention activities consistent with the Strategy.

Dr. Armitage also presented some of the specific outreach activities, guidance, and
publications being planned by EPA as part of the Contaminated Sediment Management Strategy.
EPA is planning to form task forces and to develop guidance for regulatory actions, testing
guidelines, informational publications, and multimedia materials.- The Agency is particularly
interested in the role task forces and advisory groups can play in informing key audiences about
contaminated sediment issues and generating input to the Strategy. Currently, there are EPA work
groups developing the national inventory of contaminated sediment sites and tiered testing methods
for sediment, and an interagency work group on consistency in monitoring methods. Proposed
legislation would establish a national task force on contaminated sediments in order to facilitate
interagency cooperation. EPA is considering establishment of a Citizen's Advisory Council, similar
to those supporting the National Estuary and Chesapeake Bay Programs, which would consist of
representatives from all stakeholders in the Strategy including the regulated community. The
committee would provide input to EPA in support of Strategy development and implementation.

4.1.4 Questions on EPA-'3 Proposed Outreach Activities

Man stakeholders, such as farmers, municipalities, and public works departments, are missing
Y
from the fonan audience. fAy were they not included?

Dr. Armitage responded that EPA had invited a broad range of participants and would be
interested in receiving written comments from groups that could not attend the forum. The end
of the public comment period was July 15, 1992. Nicole Veilleux, Office of Wetlands, Oceans, and
Watersheds (OWOW) emphasized that the news media is an important audience, which also must
be kept informed and educated.

How will the National Environmental Education Act (NEF,4) be employed in the Strategy's
outreach efforts?

Dr. Armitage replied that the NEEA targets students in earth science and environmental
education classes. He added that Michael Baker of EPA's Office of Environmental Education
would be speaking on the NEEA later in the program (see Section 4.2.5.1).

On whatparticular aspects of the outreach program would EPA most likefeedback- from forum
attendees?

Dr. Armitage responded that he was most interested in hearing what types of technical
guidance the regulated community needs, and what types of nontechnical guidance and outreach
approaches would be most effective in reaching the public with critical information.

4.2 PRESENTATION SUMMARIES

4.2.1 State Government

4.2.1.1 David O'Mafley, Planning Analyst, Wisconsin Department of Natural Resources

In Wisconsin, the public has reacted most strongly to water quality problems that result in
visible effects, such as beach closings, restrictions on water consumption, contaminated fish and
wildlife, and eutrophication. Mr. O'Malley felt that the public must be educated about the link
between contaminated sediments and fish and wildlife advisories, which are in effect in many places
in Wisconsin. Although fish advisories are probably the number one concern noted by local
citizens, other issues often raised include the duration and costs of cleaning up contaminated sites,
the equitable distribution of funds for remediation among different regions, and the level of
commitment from the government to implement Remedial Action Plans (RAPs). Affected citizens
need information on remedial technologies, especially innovative technologies such as
bioremediation. They also need technical support for development of sediment cleanup guidelines
for metals, PAHs, and PCBs. Information on increased funding to carry out remedial activities
from sources outside the state government must also be made available. Mr. O'Malley also thought
it would be useful to have more information available about the scope of sediment cleanup activities
nationwide.

Mr. O'Malley focused on the RAP process as an example of successful public involvement
in Wisconsin. RAPs stress a multimedia approach to addressing contamination that includes both
point and nonpoint sources of pollution. In the Great Lakes Region, 42 of the 43 areas of concern
(see Figure 4-1) have contaminated sediments as a common denominator. Five of these
contaminated sediment areas are in Wisconsin. Mr. O'Malley outlined the three stages in the RAP
development process: stage 1 describes the water quality problems and establishes goals; stage 2
develops a blueprint for action which describes what is going to be done by whom and in what time
frame; and stage 3 involves surveillance and monitoring to confirm that the area is restored.

The Citizen's Advisory Committee is the backbone of the RAP process. The committee's
representation is diverse, including industry, sporting clubs, and the general public. Mr. O'Malley
stressed the importance of the committee's role in educating local decision-makers about the extent

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Lake Superior

1 Peninsula Harbour
2 Jacklish Bay
3 Niplgon Bay
4 Thunder Bay 3
5 St. Louis Bay I River
6 Torch Lake
7 Deer Lake -
Carp Creek River

Lake Michigan 540 te
76 39
8 Manlstlque River 21
9 Menominee River
8
10 Fox River /Southern Green Bay
11 Sheboygan River
9
12 Milwaukee Estuary
13 Waukegan Harbor 2
14 Grand Calumet River/. 10 A__
35
Indiana Harbor Canal 36
15 Kalamazoo River -0
16 Muskegon Lake 37A,-'
17 While Lake 11@ @17 18
16 38 4111132 33
12
40
22
Lake Huron 13
15 41
0 -J
23
18 Saginaw River Saginaw Bay 24 29
19 Collingwood Harbour 25
20 Severn Sound 14
26 .27
21 Spanish River Mouth

Figure 4-1. Forty-three areas of concern identified in the Great Lakes Basin.

of the problem and educating state agency personnel about the stakeholders' perceptions and
concerns. He also emphasized that because RAPs can be years in completion, committee members
can experience burnout and need to identify achievable short-term milestones, such as getting
funding from a particular source, to instill a sense of accomplishment.

Specific outreach efforts in Wisconsin have included the development of a program to
explain the fish consumption advisory to the Huomong population in Sheboygan. A specially
designed advisory poster relies on symbols rather than words to convey fish consumption risks (see
Figure 4-2). Wisconsin also developed a RAP newsletter and a magazine supplement stressing
partnerships in RAP implementation by profiling local contributors such as sports fishers and local
chambers of commerce. The supplement, which had a circulation of 80,000, was produced under
a grant from the Coastal Zone Program.

Mr. O'Malley reminded EPA to be responsive to comments from advisory groups and
members of target audiences when planning Agency outreach efforts. He also advised EPA to use
existing state networks, such as the RAP process in Wisconsin, to implement the goals of the
Contaminated Sediment Management Strategy, and to allow states flexibility in their own efforts.
He thought it was important to emphasize from the outset of sediment management programs how
long cleanup could be expected to take, and to inform the public about the risks and costs
associated with different remedial options, including natural recovery. Fact sheets that summarize
key information and describe specific technologies would be very useful in disseminating this type
of information. Mr. O'Malley commended EPA for organizing the forum series as a way to get
input, generate ideas, and establish a network for communicating with important audiences. He
reinforced the idea of the Strategy as a partnership effort, expressing the view that the more the
public and the regulated community were involved in decision-making, the more likely they were
to support the Strategy's implementation.

4.2.1.2 Summary of State Government Recommendations

E EPA should involve people as early as possible in the Strategy planning process.
The Agency should involve the private sector as well as the general public, and
emphasize community participation.

E EPA should clearly state its expectations for sediment cleanup efforts at the outset.
Issues such as costs, time frame for cleanup, and how the local situation compares
to the sediment efforts nationwide all should be addressed in the initial planning
stages of a cleanup effort.

E EPA should focus on keeping the momentum going with respect to citizen
involvement. The Agency should create short-term goals and highlight
accomplishments.

N Whenever possible, EPA should tie the issue of in-place sediments to tangible
effects such as fish consumption advisories.

N EPA should demonstrate its commitment to sediment management efforts through
consistent involvement and its accountability by providing status reports.

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Figure 4-2. Fish consumption advisory for the Huomong population in

EPA should utilize existing state networks and mechanisms for public involvement
and information dissemination.

N EPA should provide broad information and support, but allow the states flexibility
in making decisions and adapting the Strategy to local situations.

0 Fact sheets and clear, consistent guidance are useful methods for getting technical
information across to the largest audience. Workshops and face-to-face contact,
however, are important for demonstrating commitment and allowing a two-way flow
of information.

4.2.1.3 Questions Addressed to the State Government Representative

How much do your Wisconsin constituents know about the link between fish advisories and
contaminated sediments?

Mr. O'Malley replied that the RAP committee members understand this link, but that the
general public must be educated further.

How did Wisconsin originally determine that sediment contamination was a problem in the five
areas of concem?

Mr. O'Malley said state officials used EPA and U.S. Army Corps of Engineers (COE)
guidelines for determining moderately and heavily polluted areas. Data from routine sampling and
sampling for fish consumption advisories were also used. He further noted that sediment
contamination was determined on the basis of concentrations rather than effects. Glenda Daniel,
Lake Michigan Federation, added that caged fish studies had been used to determine
concentrations in fish in the Detroit River. Mr. O'Malley said that Wisconsin was initiating this
type of study and finding some chronic effects from bioassays.

4*at form of information would be most useful to your constituents?

Mr. O'Malley replied that short, abbreviated, and clearly summarized guidance was most
important in getting across basic concepts. Workshops and forums such as this one are also very
helpful in disseminating information and receiving input. One of the worst frustrations, he said,
was being asked to comment on documents within a time frame that did not allow a thorough
review.

"at are the most useji4l ways to communicate with the public in terms of nontechnical
guidance?

Mr. O'Malley emphasized the need for consistent guidance nationwide, and for information
about a range of remedial options. He also stressed the importance of using programs that are
already in place and communicating through existing state channels.

-116-

"at methods does Wisconsin use to distribute guidance?

Mr. O'Malley replied that face-to-face contact has been most effective in the past, such as
in RAP committee meetings and when local RAP coordinators and committee members appear in
booths on local information days or distribute materials in a workshop setting. He also mentioned
a Wisconsin group called the Green Bay Backers, who have sponsored citizen involvement activities
in communities.

R*at roles do the private sector and the farming community play in RAP implementation?

Mr. O'Malley said that these groups were active in committee meetings and drafting
recommendations, and often contributed money for the development and distribution of
publications. He felt that members of industry and agriculture, in addition to carrying clout with
the community, could share valuable technical knowledge not obtainable elsewhere.

4*at is the relationship between the state and municipal governments, where municipalities
enact their own regulations?

Mr. O'Malley replied that county or city governments do not have to follow the
recommendations of the RAP, because these documents do not have the force of law. Often,
however, in light of community pressures and public opinion, municipalities enact even more
stringent regulations than the state, for example, with regard to protective zoning for wetlands.

What are your techniques for dealing with minority opinion in the advisory groups, and how
would you protect against a citizen's action suit?

Mr. O'Malley answered that, although it is not always possible to obtain a 100 percent
consensus, minority opinion may be incorporated into the RAP as an alternative. Sometimes,
however, the Department of Natural Resources (DNR) finds it necessary to make a decision that
may not be popular with everyone on the committee. This is because the DNR is ultimately
responsible for the RAPs implementation. There is always the possibility that a citizen may take
legal action if he or she disagrees with the committee's decisions. The use of the natural recovery
option for sediment remediation might be an issue associated with some controversy and
disagreement. Mr. O'Malley said that even 1 percent of a group could force a legal decision on an
issue over which there was 99 percent consensus.

4.2.2 Regulated Community

4.2.2.1 Richard Schwer, E.L DuPont Company

As a representative of the Chemical Manufacturers Association (CMA), Mr. Schwer
expressed CMA!s eagerness to contribute to developing the Strategy and to provide feedback on
the proposed outreach activities. CNLk which represents more than 90 percent of the productive
capacity for manufacturing basic industrial chemicals in the United States, believes the Strategy may

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have far-reaching implications for the industry. Mr. Schwer's comments reflected his concern for
what he perceived to be a lack of adequate information on the extent and severity of the
contaminated sediment problem. He stated that the data from the 1985 Office of Water's
contaminated sediments study were limited, lacked consistency and quality controls, and did not
relate contaminant chemistry to biological effects. He further stated that the Office of 'Water's 1987
study and the 1989 study by the National Academy of Sciences used the same data base. According
to Mr. Schwer, more recent and comprehensive data are needed to assess the problem. He believes
that available data suggest "hot spot," rather than widespread, contamination. Mr. Schwer feels that
EPA must present the regulated community with an environmentally relevant and consistent
definition for the term "contaminated sediment." He is concerned that sediment contamination will
be judged on the basis of chemical concentration rather than bioavailability, and he recommended
a tiered site-specific approach to assessment. Mr. Schwer cited risk communication as another need.
The regulated community and the public require balanced factual information on. assessment,
methodologies, and management alternatives. This information must be conveyed in a clear and
understandable manner so that stakeholders in the Strategy become informed decision-makers.

In his critique of EPA!s proposed outreach plan, Mr. Schwer supported EPA!s intention to
have the Science Advisory Board review all aspects of the Strategy for sound science. He strongly
endorses EPA!s willingness to form a Citizen's Advisory Council that would serve as an information
resource and periodically review the Strategy. He is pleased with EPA's involvement of industry
in the process. He would like to see the formation of a task force that would include the private
sector and would bring together federal agencies and affected parties to facilitate Strategy
implementation. Some of his concerns are that EPA continues to emphasize point over nonpoint
sources in the Strategy and that the consultation center mentioned in the proposed outreach
activities appears to be limited to EPA rather than allowing access by the private sector as well.

Mr. Schwer felt that EPA could improve upon its outreach efforts by providing information
expressed in terms of the public's values and concerns. Information on issues such as the
relationship between sediment contamination and fish consumption advisories must be
communicated to the public. EPA needs access to technically knowledgeable people, and the
regulated community can provide some of that expertise. Mr. Schwer emphasized the need for all
groups to work together, including both the regulators and the regulated community, and cautioned
that conflict can create mistrust. Mr. Schwer stated that guidance should be available for nonpoint
as well as industrial point sources of contamination, and that it is critical to link these sources to
contaminated sites with demonstrated cause-and-effect data. EPA technical assistance also should
be available to the public, for example, through a hotline staffed by knowledgeable people. Mr.
Schwer also recommended that the information obtained and conclusions reached at this forum
series should be widely published.

4.2.2.2 Donna Tomlinson, Eastman Chemical Company

Ms. Tomlinson's presentation focused on CMA!s Responsible Care Program, an industry
outreach initiative to improve performance, health and safety, and environmental quality.
Participation in Responsible Care is a requirement for participation in CMA. Responsible Care
was founded to foster two-way communication with the public, and to establish the chemical
industry's commitment to improved performance in response to public concerns. Public perception
of the chemical industry has traditionally been lower than that of the oil industry or the nuclear

industry. CMA believes that public understanding and support will increase if the public has a way
of participating in the decision-making process.

CMA achieves public involvement in Responsible Care through a National Public Advisory
Council and a broad public outreach program supported by member companies. The Public
Advisory Council, assembled and managed by an outside group, includes local government officials,
emergency responders, environmental and consumer activists, and representatives from agriculture
and industry who review and evaluate codes of management practices. The panel's membership
represents two key constituencies: citizens living in areas with high industrial concentrations and
those on the leading edge of public opinion.

Performance improvement is accomplished through implementing codes of management
practices that address community awareness and emergency response, pollution prevention, process
safety, employee health and safety, and product stewardship. Each code has a self-evaluation form
to help companies identify areas that need improvement and to track improvement of each member
company for the purpose of informing the public. In addition, executive leadership groups
composed of senior industrial executives meet regularly to discuss progress, share experiences with
Responsible Care implementation, and offer help to member companies.

The code most relevant to this forum is the Community Awareness and Emergency
Response (CAER) code. The CAER code requires facilities to initiate an outreach program to
communicate useful information responsive to the public's concerns about health, safety, and the
environment. It is based on performance objectives rather than standards, thus allowing member
companies flexibility in how to achieve the code's goals. The CAER code emphasizes interaction
with many audiences, including employees, emergency responders, government officials, and the
general public. Outreach efforts have included establishing community advisory panels and toll-free
information numbers; providing information about waste minimization, emissions reduction, health
effects of chemicals, and efforts to ensure safe transport; and distributing summary publications,
press releases, and progress reports.

Ms. Tomlinson closed by reiterating CMA's support of EPA's Strategy development process
and CMA!s willingness to continue to offer constructive criticism toward the development of a
balanced, environmentally sound, and effective Strategy.

4.2.2.3 Summary of Regulated Communi& Recommendations

0 EPA should communicate the importance of the sediment management issue with
reference to salient public concerns, such as fish consumption advisories.

M EPA should evaluate carefully what data are needed to draw relevant conclusions
about sediment contamination and subject all data and conclusions to rigorous
review.

0 EPA must develop and consistently apply a definition of "contaminated sediments"
that incorporates environmental and human health effects.

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0 EPA should provide the public with a balanced risk framework that is
understandable and includes information about comparative risks. The Agency must
also determine what the public values, and express risk analyses results in those
terms.

N EPA should efficiently utilize the National Consultation Center and a sediment
hotline to provide the public with accurate information. EPA also should publish
widely the information and conclusions from the three sediment forums.

0 EPA should seek input and participation from the public and the private sector
through the formation of a Citizen's Advisory Council on Sediment Management.

0 Industry initiatives such as CMA!s Responsible Care Program can help foster the
goals of EPA!s Contaminated Sediment Management Strategy.

4.2.2.4 Questions Addressed to the ReguWM Community Representatives

Aren't the terms "better data" and "sound science" often used by industry as buzzwords for
delaying implementation of environmental action?

Mr. Schwer responded that data collection and analysis methods had improved little in 5
years, and that much of the data in the STORET data base predates 1985. Considering the costs
and implications of decisions that would be made based on these data, he felt that updating the
data was critical. He recognized, however, that data collection as an end in itself could become a
trap which must be avoided. One issue that particularly interests Mr. Schwer is whether the
contamination problem is nationwide or whether effects from contamination are limited to selected
areas. He feels strongly that more data would contribute to deciding whether a "shotgun" or
"scalpel" approach to management was necessary.

How active is the Responsible Care Program, and how might EPA's Strateff be incorporated
into Responsible Care?

Ms. Tomlinson replied that the program has received a number of calls in response to the
toll-free numbers published in popular magazines such as Time and Newsweek. Questions are
answered by CMA staffers or by the environmental management departments of individual member
companies. The program is expecting the number of calls to increase as the toll-free number is
more widely publicized. Ms. Tomlinson said that EPA!s Strategy would add another responsibility
to the Responsible Care initiative.

In what form would CMA's member companies prefer to receive information related to the
Strategy and its implementation?

Mr. Schwer responded that information should be targeted to specific audiences within a
company. For example, company management would be interested in information concerning
public relations, the bottom line, and the future of the company's operations; whereas project

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managers would most need to know what they are required to do for compliance and what tools
are available to help them. Scientists and consultants within a company would be most interested
in the scientific and technical basis for decisions. Mr. Schwer further explained that CMA would
be able to advise EPA on how material should be structured but would not be able to develop the
materials themselves.

nat should an environmentally relevant deftnition of contaminated sediments include?

Mr. Schwer replied that such a definition would need to combine a number of endpoints,
such as information on bioacc'umulation and toxicity as they relate to the aquatic environment in
a particular location.

Is CAM responsiblefor leading the chemical industry effort in pollution prevention methods and
technoWes?

Mr. Schwer responded that such an effort would need to be developed on a company-by-
company or even a process-by-process basis. Mr. Schwer was not aware of any centralized authority
for such information.

Are there any examples or case studies of effective models of risk communication from an
industry point of view?

Mr. Schwer responded that CMA would need more time to identify and prepare such
examples. Dr. Southerland said that she would be very interested in leaming about successful
examples.

4.2.3 Environmental Advocacy Groups

4.2.3.1 Glenda Daniel, Executive Director, Lake Michigan Federation

Ms. Daniel's Lake Mchigan constituency is well acquainted with issues related to
contaminated sediments. Many of their concerns are technically specific: how EPA!s sediment
criteria will be used, what it means to have numerical sediment criteria, how acute differs from
chronic toxicity, whether bioaccumulation is being taken into account, and how EPA determines
and evaluates exposure and risk. Other concerns relate to the decision-making process, including
such issues as why sediment contamination wasn't publicized earlier, why the public was excluded
from Strategy discussions, where cleanup money will come from, how priorities for cleanup will be
selected, and where cleanup will take place.

NIs. Daniel urged EPA to address public interests, both to assuage irrational fears and to
foster justifiable concerns. For example, citizens perceive that dredging will stir up dangerous
sediments. They need to be informed that contaminated sediments are being constantly stirred up
by winds, currents, ships, and wildlife and assured that measures will be taken to control sediment
dispersal during dredging. Similarly, citizens need more information on noncancer risks, because

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the potential dangers from contaminated sediments appear to be as much neurological and
behavioral as carcinogenic.

Commenting on EPXs proposed activities, Ms. Daniel suggested that current modes of
public outreach are inadequate. Public meetings tend to be rigid and formulaic; citizens feel as if
they are being "talked down to." Written and visual information tends to be unengaging, in need
of a fresher, more attractive presentation. Ms. Daniel cited the professional advertising campaign
to increase public awareness of radon as a successful model. Whenever possible, the sediment
problem should be linked to current events like the Spring 1992 flood in Chicago, which threatened
to bring contaminated sediments into people's basements. Most importantly, EPA must convey a
willingness to remain flexible and to engage in two-way dialogue with the public. Such dialogue not
only increases public trust but may produce critical information for EPA. Ms. Daniel mentioned
specifically a meeting that provided valuable information for EPA. At the meeting, parents
indicated that their children swam in a river where EPA had assumed that there was little human
exposure.

Given the wide geographic area and diverse interests of her region, Ms. Daniel noted the
importance of assembling interested parties on a regular basis to identify disagreements and lay out
parameters for discussion. Constant effort is required to identify and include missing groups in the
discussion. She felt that one model for public involvement, the Assessment and Remediation of
Contaminated Sediments (ARCS) Program, while clumsy in scale, proved to be effective. Under
this program, people from NOAA, the U.S. Fish and Wildlife Service (FWS), COE, EPA, Bureau
of Mines, environmental groups, fisheries, and industry formed three committees to address specific
needs. The Toxicity Chemistry Committee assessed the extent of contamination, the Risk
Assessment Committee used computer modeling to determine associated health risks, and the
Technology Project Committee generated and tested potential cleanup strategies. This task-specific.
structure successfully avoided isolating nongovernmental and nontechnical people from the decision-
making process. The ARCS Program plans a number of outreach methods to publicize its work
at five demonstration sites established to evaluate various remedial approaches. Data from these
sites will be presented in technical and nontechnical guidance documents, and at technology transfer
workshops, to infonn workers at other sites of the progress that has been made. To keep the public
informed, ARCS also is developing newsletters, slideshows, and videos to display their progress at
each site.

Commenting on EPNs draft outline for the Contaminated Sediment Management Strategy,
Ms. Daniel called for stronger language. She pushed EPA to define more precisely what constitutes
an unacceptable risk to human health (Goal A). She questioned whether EPA!s commitment to
clean up contamination when practical (Goal B) meant, in effect, when convenient or when
unopposed. She requested assurance that EPA!s commitment to continue sediment disposal (Goal
C) included a commitment to explore innovative technologies. She questioned the efficacy of
natural cleanup processes (Principle J), suggesting that nearly every site requires intervention to
facilitate biodegradation. Finally, she urged EPA to set higher goals (Principle K) and to strive
always for "fishable, swimmable, and drinkable" waters.

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4.2.3.2 Beth MiUemanr4 Coast Aftiance

Ms. Millemarm built a strong case for implementation of a program to inform the public
on issues related to contaminated sediments and to involve them in the formation of the
Contaminated Sediment Management Strategy. Levels of public involvement in the Strategy thus
far have been low, in marked contrast to the levels of involvement among industry, scientists,
lawmakers, and public officials. Affected industries are already deeply involved in tracking this
issue. COE and port authorities are collecting information and passing it on to lawmakers,
journalists, and trade organizations. Congress is presently considering bills that could result in
action on disposal of contaminated sediments. The international community is studying
contaminated sediments as they pertain to the London Dumping Convention. In essence, the public
is the last to become involved. Historically, prolonged public ignorance of environmental issues has
led to litigation, long-term arbitration, and disenchantment with state and federal agencies.

There is a clear need for better outreach so that the public can make informed decisions
about contaminated sediments as the issue affects their lives. In coastal areas, the public is already
beginning to face questions that require knowledge of issues related to contaminated sediment
management. For example, there is a proposal to dredge contaminated channels in Oakland
Harbor, but commercial fishing organizations and environmental groups are opposing it. In Boston,
plans are being made for a third harbor tunnel, and citizens want to know where the dredged
material will be disposed of. There is little public confidence that EPA has a rational, defensible
program to deal with contaminated sediments. Public distrust can be dangerous: bans on ocean
dumping of sludge and industrial waste exemplify the public's tendency to support stiff regulation
rather than compromise.

Ms. Millemann urged EPA to use existing avenues of communication to introduce the topic
of contaminated sediments to the public. She suggested several forums for public involvement in
coastal areas. Annual conventions of environmental groups such as the National Audubon Society
are well advertised, well attended, and offer opportunities for EPA staff to discuss contaminated
sediment issues. Labor unions such as the Teamsters, responsible for handling contaminated
sediments, host environmental panels at their national conventions. Organizations such as the
Coastal Society and the Coastal States Organization offe-- similar opportunities to publicize
contaminated sediment issues. Citizens advisory committees such as those active in the National
Estuary Program offer existing networks for public outreach at both the state and federal level.
Watershed organizations like Great Lakes United and the Conservation Law Foundation of New
England offer opportunities to reach their large and diverse constituencies. In addition, many states
have coastal zone management programs that come under review every 2 years, with citizen advisory
committees already in place.

4.2.3.3 Summary of Environmental Advocacy Group Recommendations

0 EPA should get the public involved as early as possible in Strategy planning.

0 EPA should provide information at a level of detail that allows the public to
formulate decisions. People want to hear the "meat" of the message and to be
treated as a sophisticated audience.

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E Data collection and analysis should be thorough and scientifically sound.

N EPA should take advantage of existing communications systems, such as newsletters
and annual meetings of environmental groups or union groups, to disseminate
information.

0 EPA publications and presentations should employ interesting visuals and engaging
formats.

0 Face-to-face interaction through meetings, workshops, or conferences is the most
effective way to communicate EPA!s messages.

4.2.3.4 Questions Addressed to Environmental Advocacy Grvup Representatives

How ftequently should citizen adviso?y groups meet and how are such meetings typically funded?

Ms. Daniel responded that advisory groups work cheaply. To her knowledge, participants
have been reimbursed only for travel and lodging, never on a per dipm basis. She sug ested that
99
meetings be scheduled frequently enough to keep citizens involved in the depision-making process.
Ms. Millemann suggested using conference calls to minimize expenses. Mr. Schwer said that the
regulated community would provide time for members to participq@e in citizen advisory groups and
noted that meeting only once a year would probably not provide EPA with sufficient input. He
suggested quarterly meetings during the first year to foster working relationships between citizens
and Agency staff. After 1 or 2 years, meetings could be scheduled every 6 months with quarterly
consultations if necessary.

How would you suggest that EPA strike a balance between technical and nontechnical
information when addressing the public?

Ms. Daniel pointed to problems experienced at the recent "all-hands" annual meeting for
ARCS. The meeting was divided into very technical presentations and presentations for RAP
advisory groups. The technical presentations were too technical and were presented out of context;
advisory group presentations consisted merely of "headlines." The meeting suffered as a
consequence. Ms. Daniel emphasized the importance of interpreting the research being done and
illustrating those interpretations with well-chosen examples.

Randall Ransom, Dow Coming, warned against the assumption that all news is bad news.
Mr. Ransom pointed to the NOAA National Status and Trends Program, which indicates that most
sediments are not contaminated.

Is there a compendium of public groups with names to contact and information on annual
meetings?

Ms. Millemann suggested the Conservation Directory, available from the National Wildlife
Federation Office in Washington, DC.

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fflat are some other examples that could help EPA use existing mechanisms for public
outreach?

Suzanne Bolton, NOAA urged EPA not to neglect mechanisms within other federal
agencies, such as agriculture extension services within the U.S. Department of Agriculture and Sea
Grant within NOAA, that deal with individual localities. In addition, Ms. Bolton pointed to
successful use of teleconferencing by the Economic Development Administration, U.S. Travel and
Tourism Administration, and the U.S. Information Agency during a recent conference on rural
tourism.

Ruddie Clarkson, J.M. Consulting Engineers, indicated that industries, community groups,
and local governments are calling for basic, yet sufficiently detailed, information on the health and
ecological effects of contaminated sediments. She added the U.S. Public Health Service and Public
Health Department to the list of existing networks that EPA should use for public outreach; these
organizations can disseminate basic information on sediment toxicity issues via hospitals and private
physicians.

fMat kinds of results can EPA show citizens to demonstrate that the public i's having an impact
on sediment cleanup?

Ms. Daniel recognized the need to wam citizens that cleanup may be slow, but she stressed
the importance of celebrating interim successes. Such successes, however slow in coming, put the
overall plan for cleanup into a more comprehensible and manageable perspective and allow goals
to be more clearly articulated.

Ms. Clarkson commented that many community programs fail because goals and strategies
are not clearly articulated. The public must recognize up front that cleanup will require a long-term
commitment; this recognition makes what Ms. Daniel calls "interim celebrations" more satisfying.

"ich audiovisual techniques are most effective forpublic outreach?

Ms. Daniel indicated that computer bulletin boards and networks do not work well. Too
many small groups have only one computer, which is used primarily for word processing. Ms.
Millemarm suggested that people are more effective communicators than videotapes, but that videos
are better than written reports which simply do not get read. Oral presentations should be
accompanied by slides and short fact sheets so as to make a visual link between "dirty mud' and
health impacts on fish and birds.

4.2.4 Public Awareness Group

4.2.4.1 Frances Flanigan, Alliance for the Chesapeake Bay

Ms. Flanigan amplified a theme stressed by other speakers, stating that EPA must find ways
to involve the public in working to improve environmental quality. The public's interest in this issue

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is clear: its tax dollars, health, and well being are at stake. Ms. Flanigan believes that public
participation should be seen as a means to enact good policy, and she outlined three roles the
public can play. First, they can help to define the extent of the problem. Whether or not
Chesapeake Bay has a sediment problem is a value judgment; such judgments should be made by
more than a few people. Second, the public can define the level of risk they find acceptable,
making a distinction between voluntary risk and risk imposed externally. Third, the public can
contribute to the development of cost-effective solutions. If they have defined the problem
themselves, they will often feel a greater stake in finding solutions. EPA!s outreach should be
designed to encourage public participation in these aspects of policy-making.

Public outreach is more complicated when the public is part of the problem. Citizens often
fail to realize that pollutants from toilets and cars can cause as much damage as those from
negligent industries. The Alliance for the Chesapeake Bay has raised public consciousness of
nonpoint pollution through a peer-to-peer network. For example, farmers whose fertilizers pollute
ground water are contacted through the leadership of farm organizations. Ms. Flanigan's program
has also sought to avoid assigning blame. Farmers learn that agrichernicals are part but not all of
the problem. Whenever possible, environmental messages are delivered in terms that make
economic sense. Farmers are informed that excessive fertilizer application is simply a waste of
money. Fostering voluntary compliance greatly reduces government expense.

Ms. Flanigan urged EPA to be accountable to citizens participating in environmental
programs; citizens want to know that their input brings results. She suggested several steps to
ensure accountability to the public, including publication of an annual report, preparation of
technical documents, or soliciting annual meetings. For example, in the Chesapeake Bay Program,
an executive council, including governors and EPA Administrator Reilly, meets annually to review
accomplishments and plan future activities. Accountability becomes more important as policy
implementation begins. Since implementation is usually long term, EPA must try to remain
accountable for short-term goals established early in the development of environmental programs.
When initial implementation fails, new courses of action need to be charted. At this stage, there
is a strong temptation to exclude the public, but EPA must continue to keep the public involved.

The goal of Ms. Flanigan's public information program has been to create "an environment
of awareness." The message has been simple: "The Bay is in trouble, and we are all at fault. Here's
what others are doing and what you can do. Here's what it will cost and how long it will take." The
Alliance has conveyed the message in four formats: an inexpensive introductory brochure, fact
sheets on particular local interests, a newsletter funded by EPA, and a booklet with more detailed
information. Ms. Flanigan questioned the necessity of expensive, glossy, written materials when
targeting an audience with a vested interest in the information. Such materials are more useful
when courting audiences with no particular interest in contaminated sediments. In addition, Ms.
Flanigan has found that highly technical information is unnecessary to foster support for action.

Ms. Flanigan stressed the importance of targeting diverse audiences: chambers of commerce,
farm organizations, civic organizations, and recreational groups. EPA must develop and maintain
an up-to-date mailing list of contacts and get on these organizations' agendas. Ms. Flanigan
emphasized the feasibility of building consensus at the broad policy level, if not at the level of
regulation. Citizen advisory committees bring together diverse interests, and discussions within
these groups build consensus by narrowing the fields of disagreement. In concluding, Ms. Flanigan

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stated that the Alliance has successfully set up an institutional network among existing governmental
and nongovernmental agencies that can sustain long-term implementation.

4.2.4.2 Summary of Public Awareness Group Recommendations

� EPA should first identify ways to get people interested and concerned about the
contaminated sediment problem, and then get them involved in the process of
implementing solutions.

� EPA must recognize that public involvement is a process and a means to achieving
the Strategy goals.

N Communications tools should be developed in response to specific audiences and
specific needs. EPA should be involved in designing information pieces to close
knowledge gaps.

� EPA must work toward building consensus among all of its audiences.

� EPA must demonstrate accountability by achieving interim goals and providing
information on the status of activities.

� EPA should work toward developing a management framework of institutions that
will be self-sustaining and carry the work of sediment management on into the
future.

4.2.4.3 Questions Addressed to the Public Awareness Group Representative

How would you describe the infrastructure needed to support an effort as successful as yours in
disseminating information to the public?

Ms. Flanigan replied that the Alliance for Chesapeake Bay is fortunate to have support from
other organizations. For example, the Chesapeake Bay Foundation, an advocacy group with 80,000
members, 100 full-time staff members, and a $7 million budget, does extensive work in education,
lobbying, and litigation. The Alliance for Chesapeake Bay, with three offices, 15 full-time
professionals, and a $800,000 budget focuses on public outreach. Ms. Flanigan emphasized that
substantial work can be done relatively inexpensively by organizations committed to remaining lean
and "unbureaucratic."

Has the Affiance worked on methods to explain comparative risks?

Ms. Flanigan remarked that little work had been done overall. She added that the
Chesapeake Bay Program had a Toxics Committee, chaired by Clay Jones, doing work in this area.
Dierdre Murphy, Maryland Department of the Environment, pointed out that risk estimates
represent upper bounds. In some cases, there may be little or no risk at an. She urged EPA to put

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these risk figures into meaningful language, perhaps by comparing them to risks that are
encountered in everyday experience.

How does the Alliance get its information from EPA and which channels are most useful?

Ms. Flanigan suggested that newsletters, reports, and press releases arriving by mail are the
most common sources of information. Despite the volume of these items, she expressed concern
that she might still be missing other sources of information. In filtering through material from
EPA, Ms. Flanigan looks for pieces that are relevant and well written. She suggested that EPA
might identify audiences more carefully and make phone contact to call attention to important
documents.

With regard to the nutrient problem in Chesapeake Bay, Ms. Flanigan replied that fact
sheets from EPA tended to be too technical to be useful. As a nontechnical group, she and her
staff found it more effective to serve as translators between the technical community and the public.
People at the Alliance attend meetings and make sense of the information, then write their own
fact sheets to distribute to the public. Ms. Flanigan suggested that presentations, well delivered,
detailed, and supported with interesting graphics, are by far the most useful form of communication.
Even if the information is very technical, these presentations convey a sense of who has done
significant research and who is to be trusted.

4.2.5 National Environmental Education Act

4.2.5.1 Michael Baker, Acting Deputy Director, Office of Environmental Education

The signing of the National Environmental Education Act (NEEA) in 1990 added education
to EPA's regulatory and enforcement activities. The NEEA is authorized for 5 years, and funded
at approximately $12 million per year. In FY 1992, $6.5 million was appropriated by Congress. The
message behind the NEEA, said Mr. Baker, is the encouragement of partnership among academia,
government and nongovernmental organizations, and the private sector. Many of the grant
programs focus on ways that different sectors of society can cooperate in funding and implementing
environmental education activities.

According to Mr. Baker, the NEEA!s environmental education programs have received a
tremendous response this first year. Over 3,000 proposals requesting over $100 million dollars were
received for this year's grants programs. Proposals for less than $25,000 were evaluated by EPA
regional offices and a peer panel; proposals of more than $25,000 were evaluated by headquarters
and peer reviewers. The winners of these awards were announced by Administrator William Reilly
at the end of June. A single 3-year grant was awarded to the University of Michigan to establish
a National Training Program Center based on a train-the-trainer model. In addition to the grants
programs, NEEA is sponsoring an intern fellowship program, which places individuals in federal
agencies across the country.

Mr. Baker described the NEEA!s use of advisory boards to involve all sectors of society in
implementation activities. These groups include a 38-member internal EPA advisory board; a
federal task force consisting of EPA and 16 other federal agencies; and an 11-member national

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advisory council composed of representatives from state and local governments, nongovernmental
organizations, schools and universities, and industry.

Other outreach activities include the development of a user friendly clearinghouse on
environmental education resources; EPA's Earth Notes newsletter for educators; and an
international memorandum of agreement among the United States, Canada, and Mexico.

4.2.5.2 Questions on the National Environmental Education Act

"at is the nature of the interaction between the Office of Environmental Education and other
EPA offices?

Mr. Baker responded that representatives from the program offices provide input through
the EPA advisory board. These representatives then share information on planning and
implementation of NEEA activities with their respective offices.

Will the National Training Program Center be available for training scientists and regulators in
monitoring and testing methods for sediments?

Mr. Baker replied that would be one of its services.

Will money from the NEEA be available to customize educational programs to individual
schools?

Mr. Baker replied that such funds could be procured through the Section 6 grants program.

43 EPA SUMMARY OF COMMENTS AND DISCUSSIONS ON OUTREACH AND PUBLIC
AWARENESS THEMES

Dr. Southerland expressed her appreciation for the many valuable comments and
recommendations made by the speakers and other participants in the forum. Below is a summary
of some of the input regarding major areas of concern to EPA.

4.3.1 Citizen's Advisory Group

Every speaker commented that some form of citizen's advisory group that could monitor
the development and implementation of the Contaminated Sediment Management Strategy would
be worthwhile. Such a group should not isolate nongovernmental organizations and the private
sector from other federal agencies, but bring them together to discuss concerns. It is important to
clearly define the roles of all group members, whether involved as advisors or as participants in
decision-making. Also, it is critical to ensure that members continue to represent their constituents
throughout the process.

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43.2 Types of Outreach Materials

Forum participants agreed that the most effective forms of outreach involve face-to-face
interaction, such as through advisory groups, public meetings, or workshops. These methods allow
two-way communication. Through this kind of interaction, infon-nation can be targeted to meet the
specific needs of individual audiences. Teleconferencing was suggested as a next best alternative
to in-person contact. It was noted that videotapes are more useful than printed materials, but still
allow for only one-way communication instead of a dialogue.

433 Content of Outreach Information

Speakers stressed the importance of conveying complete information to the public, without
skimping on details. EPA should be careful to explain the significance of projects under way; the
public wants to know why certain activities are being pursued. EPA also must be clear at the outset
of its program about the time frame for remedial activities and what is expected to be
accomplished. In the ARCS Program, goals were not clearly communicated, and many people did
not realize that the success of demonstration projects did not represent ultimate cleanup.
Publicizing interim successes, however, will help the public feel a sense of accomplishment and
progress toward long-term restoration.

Participants also felt that outreach programs should be tailored to respond to geographical
issues and concerns.

43.4 Information Dissemination

Many forum participants encouraged EPA to use existing networks for outreach and public
participation, especially those in other federal agencies such as the extension services in USDA and
Sea Grant in NOAA. Other outreach mechanisms described by speakers included the RAP process
in Wisconsin, the CMA Responsible Care Program, and meetings of environmental groups,

43.5 Risk Communication

The need for effective risk communication was discussed, but participants could offer few
examples of successful programs. Risk must be communicated both in terms of voluntary and
involuntary risk and ecological and human health risks. EPA is very interested in appropriate and
useful examples of comparative risks related to contaminated sediments.

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APPENDIX A

EPA'S CONTAMINATED SEDIMENT MANAGEMENT STRATEGY
DRAFT OUTLINE

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March 4, 1992

Draft Outline

EPA's Contaminated Sediment Management Strategy:

A Proposal for Discussion

Purpose

A. Describe EPA's understanding of the extent and severity of sediment
contamination, including the uncertainties about the dimension of the
problem.

B. Describe the policy framework in which EPA intends to promote
consideration and reduction of ecological and human health risks
posed by sediment contamination.

C. Describe specific actions EPA will take to bring about consideration
and reduction of sediment risks.

Definition of Contaminant: any solid, liquid, semisolid, dissolved solid,
gaseous material or disease causing agent which upon exposure, ingestion,
inhalation, or assimilation into any organism, either directly from the
environment or indirectly by ingestion through food chains, may, on the
basis of information available to the Administrator, pose a risk of or cause
death, disease, behavioral abnormalities, cancer, genetic mutations,
physiological malfunctions (including malfunctions in reproduction), or
physical deformations, in the organism or their offspring.

Goals

A. Prevent ongoing contamination of sediments that may cause
unacceptable risks to human health or cause ecological harm, so that
beneficial uses of the nation's surface waters are maintained.

B. When practical, clean up existing sediment contamination that
adversely impacts the nation's surface waters or their uses or that
causes other significant effects on human health or the environment.

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C. Ensure that sediment dredging and the disposal of dredged materials
continue to be managed in an environmentally sound manner.

IV. Principles

General

A. EPA programs with authority to address sediment contamination
operate under the mandate of many statutory provisions. Thus,
regulatory decisions must be based on sets of considerations that are
not always consistent. EPA programs should respond to the risks of
sediment contamination as consistently as is possible, taking into
account statutory requirements and the need for programs to address
other problems that may pose similar or higher risks.

B. EPA will assign highest priority to activities with the greatest potential
for reducing unacceptable risks to human health and the environment.

C. EPA should continue to improve coordination of research and
regulatory efforts to assess and manage contaminated sediments with
other State and Federal agencies, with international organizations, and
with private parties.

AssessMent

D. EPA should continue to develop and improve methods for identifying
contaminated sediments that are causing harmful ecological effects
and/or poslr@q unacceptable risks to human health.

E. Assessment of sediment contamination, and any subsequent steps
taken by the Agency to reduce risks, should be based on sound
science.

F. To better assess the extent and severity of sediment contamination,
the Agency should conduct an inventory of sediment quality and
improve its monitoring for sediment contamination. The Agency
should identify a list of chemicals of concern based on toxicity,
persistence and propensity to bind to sediment particles and of
sources of these chemicals.

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G. The Agency should use consistent methods to assess sediment
contamination and its effects, so that data gathered by EPA programs
are comparable and to focus methods development efforts.

Prevention

H. Where sediment quality is sufficient to support, or could support, the
full beneficial uses of a waterbody, the Agency should ensure that
existing pollution prevention measures and source controls will
maintain or achieve the appropriate level of sediment quality.

1. Where sediments are contaminated to levels that cause ecological
harm or pose an unacceptable risk to human health, the Agency
should implement pollution prevention measures and source controls
to prevent further contamination and allow toxic sediments over time
to become nontoxic. This is a critical step to ensure the long-term
success of any remedial activity for the site, to minimize the costs of
navigational dredging, and to increase opportunities for beneficial
reuse of dredged materials (e.g., wetland restoration).

Remediation

J. Where short term risks and effects can be tolerated and statutes do
not require remediation or establish other preferences (e.g., preference
for treatment under the Superfund Amendments and Reauthorization
Act), the preferred remedy is to implement pollution prevention
measures and source controls and to allow natural cleanu2 wocesses
such as biodegradation and the deposition of clean sediments to
restore the site. In these cases, the Agency may still seek restitution
for damages to natural resources in coordination with other Federal
and State agencies.

K. Remediation should be prioritized to limit serious risks to human health
and the environment first, and then to restore sites to current and
reasonably expected future uses, whenever such restorations are
practicable, attainable, and cost-effective.

L. EPA will not proceed with a cleanup when technically and
economically achievable remedial techniques would cause more
environmental harm than leaving the site alone.

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M. Where pollution prevention, source control, and natural remediation
will not reduce risks and effects in'an acceptable time frame, EPA will
assign highest priority to remediating sediment contamination:

1 that is contributing to severe effects or substantial risks to
aquatic life, wildlife, and human health,

2. where continued delay would result in the spread of harmful
levels of contamination over a wider area where remediation is
no longer technically or economically feasible, or

3. where continued delay would result in the spread of harmful
levels of contamination into areas that provide important
habitat.

N. The cost of sediment remediation cannot be borne solely by Federal,
State, and local governments. Under appropriate statutes, authorities
should be used to encourage voluntary cleanups or compel responsible
parties to cleanup sediments contaminated by their activities and to
seek restitution for damages to natural resources.

V. Statement of the Problem

A. Knowledge about the Extent of Contamination

I . EPA's Office of Water Studies

a. 1985 -- National Perspective on Sediment Quality.

b. 1987 - An Overview of Sediment Quality in the United
States (EPA/905/9-88/002).

2. 1989 National Academy of Sciences report, "Contaminated
Marine Sediments -- Assessment and Remediation."

3. Conclusion

a. Based on available data, it appears that sediments in all
types of waterbodies at hundreds of locations across the
country, are contaminated at levels that harm benthic

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and other aquatic communities, and that potentially
threaten human health and wildlife.

b. The sediment contaminan.ts of greatest concern appear to
be heavy metals and persistetit, toxic, bioaccumulative
organic compounds. Some evidence suggests that short
term exposures to non-persistent compounds (e.g.,
pesticides) may be a problem in certain circumstances.

C. There are many potential sources of these contaminants -
- municipal sewage treatment plants, combined sewer
overflows from older municipal sewage systems,
stormwater-related discharges from municipal sewers and
industrial facilities, industrial discharges of process
wastewaters, runoff and leachate from hazardous waste
and solid waste disposal sites, agricultural run-off, mining
operations, run-off from industrial manufacturing and
storage sites, and atmospheric deposition of
contaminants.

d. More and better data on sediment quality are needed.
Many locations have not been adequately sampled.
Much of the available data on levels of chemical
contaminants in sediment do not include information that
is needed to determine the bioavailability of the sediment
bound chemicals. For lack of better methods, data on
sediment toxicity were obtained by performing acute
tests on species that are not sensitive to sediment
contamination. Chronic toxicity tests and other
endpoints that use or reflect the sensitivity of more
sensitive organisms are more appropriate for sediment
evaluation.

B. Human Health Risks

1 Comparative Risk Studies

a. Unfinished Business: In 1987, EPA completed a study
entitled, Unfinished Business. A Comparative
Assessment of Environmental Problems. Unfinished
Business ranked in-place toxics in sediments (as part of a

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nonpoint source category) as the eleventh most
significant environmental problem of 32 identified.

b. The EPA Science Advisory Board (SAB) is a public
advisory group that provides scientific information and
advice to the EPA. In early 1989, Administrator Reilly
asked the Science Advisory Board to review Unfinished
Business. SAS supported EPA's ranking of the human
health risks posed by in-place contaminated sediments.

C. EPA and SAS judged that contaminated sediments pose a
medium risk for non-cancer illnesses. Non-cancer
illnesses result from toxics; (e.g., mercury) in sediments
bioaccumulating up the food chain to fish and shellfish.
Consumption of contaminated fish was judged to pose a
low risk for cancer, but the SAS noted this was the
primary routs of human exposure to carcinogens in
surface waters.

d. Relative risk ranking projects by EPA Regions in the North
and mid-Atlantic and mid-West (Regions 2, 3, and 5)
scored nonpoint sources, including in-place contaminated
sediments, as a medium-high or high risk. This
evaluation is due primarily to the consumption of sport
fish containing toxic oompoundi bioaccumulated from
sediments.

2. Examples of Case Studies

a. Quincy Bay, Massachusetts: elevated cancer risk from
consuming lobster tornalley.

b. Lake Michigan: Developmental problems in children
whose mothers consumed large amounts of fish.

C. Los Angeles-Long Beach Harbor: Up to 1011 to 101
cancer risk from consuming white croaker.

d. Puget Sound: As much as 2 x 1 0-4cancer risk for
moderate seafood consumers and 4 x 10-3 cancer risk for
high-quantity consumers.

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C. Ecological Risks

1. SAB and Regional Comparative Risk Studies

a. Contaminated sediments received a high risk ranking on
the spatial extent of the problem, affecting areas on a
local, regional, and global scale.

b. High risk rankings were attributed to contaminated
sediments for the potential to cause ecological effects
and responses.

C. Recovery period for areas with sediment contamination
may be decades or longer.

2. Examples of Case Studies

a. Elizabeth River, Virginia: severe fin and-gill erosion,
tumors, mortality.

b. Ashtabula River, Ohio: fish tumors and other
abnormalities in brown bullheads.

C. Great Lakes: reproductive problems in Forster's Tern,
reproductive failures and mortality in mink.

d. Commencement Bay, Washington: mortality in
amphipods and oyster larvae.

D. Limited public or private funds are available to respond to sediment
contamination that is causing severe ecological effects or
unacceptable risks to human health.

VI. Why EPA Needs an Agency-wide Management Strategy for Contaminated
Sediments

A. Various statutes give EPA authority to address contaminated
sediments.

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1. Clean Water Act (CWA)

a. National Pollutant Dis c*harge Elimination System (NPDES)
permits for point sources, including the authority to
require monitoring and to enforce against violations of
permit conditions.

b. Grants and guidance for State programs that control
nonpoint sources.

C. Regulation of the discharge of dredged or fill materials
into inland waters of the U.S.

d. Emergency powers to bring suit to stop the discharge of
pollutants presenting an imminent and substantial
endangerment to health or welfare (livelihood) of persons.

e. Identification of locations of in-place pollutants in harbors
and navigable waterways.

2. Marine Protection Research and Sanctuaries Act (MPRSA) --
site designation, criteria development on effects, and permit
review for the disposal of dredged materials in the oceans.

3. Federal Insecticide Fungicide and Rodenticide Act (FIFRA) --
effects of a pesticide on nontarget organisms vs. benefits of its
Use.

4. Toxic Substances Control Act (TSCA)

a. Regulation of new and existing chemicals that may cause
sediment contamination.

b. Disposal of material contaminated with PCBs.

5. Comprabl.ansive Environmental Response Compensation and
Liability Act (CERCLA or "Superfund")

a. Placement of sites on the National Priorities List (NPL).

b. Emergency response.

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C. Enforcement authority for non-NPL sites.

6. Resource Conservation and Recovery Act (RCRA)

a. Corrective action to address contamination caused by
hazardous waste facilities.

b. Emergency powers to require the abatement of imminent
and substantial endangerment caused by past or present
handling of solid or hazardous waste.

7. National Environmental Policy Act (NEPA) -- preparing
environmental impact statements (EIS).

8. Great Lakes Water Quality Agreement (GLWQA)/Great Lakes
Critical Programs Act (GLCPA)

a. Remedial action plans for 31 Areas of Concern partly or
wholly in U.S. waters.

b. Assessment and Remediation of Contaminated Sediments
(ARCS) program (originally established under Section 118
(c)(3) of the CWA).

9. Coastal Zone Management Act (CZMA) -- EPA/National Oceanic
and Atmospheric Administration (NOAA) Guidance for
controlling nonpoint sources in States with approved coastal
zone management programs and degraded coastal waters.

10. Clean Air Act (CAA) -- regulation of hazardous air pollutants
that contaminate sediments via atmospheric deposition and in
Section 309, reviewing major Federal actions (i.e., EIS's of
other Federal Agencies) with the potential to significantly affect
the human environment.

11. For more information on EPA's authorities for addressing
sediment contamination, see the document "Contaminated
Sediments -- Relevant Statutes and EPA Program Activities"
(EPA 506/6-90/003).

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B. Many EPA Offices implement these statutory authorities or coordinate
their implementation in specific geographic areas:

1 . Office of Water (OW)

2. Office of Emergency and Remedial Response (OERR)

3. Office of Waste Programs Enforcement (OWPE)

4. Office of Solid Waste (OSW)

5. Office of Pesticide Programs (OPP)

6. Office of Pollution Prevention and Toxics (OPPT)

7. Office of Air Quality Planning and Standards (OAQPS)

8. Office of Radiation Programs (ORP)

9. Office of Enforcement (OE)

10. Office of Federal Activities (OFA)

11. Office of Policy, Planning, and Evaluation (OPPE)

12. Office of Research and Development (ORD)

13. Chesapeake Bay Liaison Office

14. Great Lakes National Program Office (GLNPO)

15. Gulf of Mexico Program (GOMP)

16. Office of Information Resources Management (OIRM)

17. Tan EPA Regional Offices -- Depending on statute and program
structure, Regional Offices may have wide latitude in how they
assess and manage sediment contamination.

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C. EPA needs coordination among these offices with authority to address
sediment contamination to promote:

1 consistent consideration of sediment risks,

2. consistent decision-making at Federal and State levels in
managing these risks,

3. wise use of scarce resources for research, technical and field
activities, and

4. consistent sediment assessment practices.

VII. Policy Framework

A. Administrator Thomas formed an Agency-wide Sediment Steering
Committee in 1989

1. Chaired by OW Deputy Assistant Administrator (DAA).

2. Members include DAA's and Office Directors across the
Agency.

B. In January 1990, the Steering Committee decided to prepare a
Management Strategy for Contaminated Sediments. (At a later date,
the Agency may prepare a companion strategy to improve the
assessment and management of problems caused by sedimentation
and physical/hydrological modification of habitats.)

C. The Sediment Steering Committee will be an ongoing body to oversee
development and implementation of the Strategy.

Vill. Strategy for Assessing Sediment Contamination
(Principles D-G)

A. EPA has committed to use a consistent, minimum set of chemical and
biological methods across Agency programs to determine whether
sediments are contaminated. These methods will produce data of
high quality which can be defended in regulatory and enforcement

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actions. These methods will be used for prevention, remediation, and
the management of dredged material disposal programs.

B. An Agency-wide work group is in the process of selecting the
minimum set of methods. Recommendations will be made to EPA's
Sediment Steering Committee for review and approval.

C. Each EPA program may use supplemental, program-specific
assessment methods and develop its own guidance detailing the
specific regulatory actions to be taken based on the assessment.

D. Different programs within EPA may require compliance with all
assessment methods, while another program may not. This is
because environmental statutes vary in their requirements to prevent
or eliminate all contamination. For example:

1 . CWA requires control of point source discharges as necessary
to achieve water quality standards, regardless -of cost.

2. FIFRA requires consideration of costs in deciding whether to
register or restrict the use of a pesticide.

I TSCA provides authority to address unreasonable risks posed
by new or existing chemicals.

4. RCRA decisions on corrective action cannot consider costs.

5. CERCLA remediation decisions mu*st express a preference for
treatment but must also consider cost.

D. EPA will request resources for an inventory of sites with contaminated
sediments.

1 . An EPA work group is now designing a national inventory of
sites with contaminated sediments based on existing
inforr.-,ation on sediment quality. Pilot efforts are underway in
EPA Regions in the mid-West, Southeast, and Gulf Coast
(Regions 4, 5 and 6). The purpose of this activity is:

a. to obtain the best possible, near-term assessment of the
national extent and severity of problem,

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b. to identify areas which may be contaminated and need
further assessment, and

C. to identify areas with sufficient data to be characterized
as causing high risks or severe effects, so that Agency
programs can target those areas for appropriate actions.

2. EPA will also conduct a pilot study to gather additional data on
sediment quality most efficiently. Current information is
sufficient to identify: 1) the potential for a large-scale problem
and 2) specific sites where sediments are highly contaminated.
However, additional data are needed because:

a. in many areas of the country, few data on sediment
quality have been collected.

b. much of the data on the concentrations of specific
chemicals in sediment does not include basic information
that would allow determinations to be made as to what
portion of the contaminant is available to aquatic life.

C. much of the data on sediment toxicity was developed
using acute tests on organisms that are not as sensitive
to contamination in short-term tests (e.g., clams).

E. Inventory of sources of sediment contamination

1 . EPA will develop a pilot inventory of sources of sediment
contamination using:

8. Toxics Release Inventory (TRO data,

b. effluent guideline data, and

C. other sources.

2. An inventory of sources will be useful to target sediment
sampling: 1) in the pilot effort to inventory contaminated sites
using new data (see above), and 2) in water quality monitoring
programs (see below).

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3. A source inventory will also be useful for targeting pollution
prevention activities and source control efforts, including
selection of industries for development of effluent guidelines,
permitting and enforcement actions.

4. The inventory will be closely coordinated with OPPT pollution
prevention activities including participation in the voluntary
33/50 Program which encourages industrial sources to reduce
toxic waste generation.

5. Depending on the results of the pilot effort to inventory sources
of sediment, EPA may conduct a similar effort on a larger scale.

6. A source inventory will be useful in targeting enforcement
actions.

F. EPA will work to increase sediment monitoring in water quality
monitoring programs.

1 . ORD's Environmental Monitoring and Assessment Program
(EMAP) will gather important chemical and biological data on
sediment quality.

2. OW will include sediment monitoring issues in its overall
monitoring program framework that includes EPA Headquarters,
EPA Regions, and State Agencies.

3. OW is negotiating with the United States Geological Survey
(USGS) to form the Water-Quality Monitoring Intergovernmental
Task Force (ITF) with Federal, State, and local representation.
ITF will design a national monitoring framework, information
system linkages, monitoring protocols, and QA/QC procedures
which will include sediments.

4. OW and OIRM will continue to assure that the capability to
store and use sediment data is enhanced as part of the ongoing
modernization of the Agency's water quality data systems,
STORET, BIOS, and ODES. Some of EPA's Regions are also
developing or have developed data bases for sediment
information that are (or will be) compatible with these national
databases.

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5. EPA is considering an increase in its monitoring program during
reauthorization of the CWA.

G. Under Section 11 2(m) of the CAA, EPA is undertaking a program
("Great Water Bodies Study") to assess the effects of hazardous air
pollutants on the Great Lakes, Lake Champlain (on the New
York/Vermont Border), the Chesapeake Bay, and near coastal waters.

1 . This Study (funded in the CAA) includes air deposition
monitoring, monitoring of biota, and toxic contaminant
transport modeling.

2. An initial report is due to Congress in 1993, and every two
years thereafter. Among other topics, the reports will address:
contribution of air pollutants to water pollution, sources of
pollutants, and whether they contribute to violations of water
quality standards.

H. EPA will coordinate its assessment strategy and activities with the
National Oceanic and Atmospheric Administration (NOAA), U.S.
Geologic Survey (USGS), the U.S. Army Corps of Engineers (COE),
U.S. Fish and Wildlife Service (FWS), and the States.

IX. Strategy for Preventing Sediment Contamination
(Principles H and 1)

A. FIFRA gives EPA the authority to ban or restrict the use of pesticides
that have the potential to contaminate sediments, if the risks to
nontarget organisms are judged to be unreasonable. In making
decisions on pesticides, FIFRA requires EPA to consider economic,
social and environmental costs and benefits.

1 . Sediment toxicity is not currently addressed in routine test
procedures and risk assessments for pesticide registration,
reregistration, and special review.

2. Although past registrations of pesticides did not routinely
address potential ecological effects of sediment contamination
in terms of ecological effects, OPP is currently developing a
strategy to do so. As appropriate and accepted sediment
toxicity testing and test guidelines are developed, OPP can

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accelerate its efforts accordingly. Efforts will eventually include
revision of test requirements in 40 CFR Part 158 and protocols
in Subdivisions of the Pesticide Assessment Guidelines.

3. OPP is considering the following actions:

a. Routinely require aquatic fate tests to support many
terrestrial uses of persistent or bioaccumulative
pesticides. For these tests, OPP would need to
determine the degree of persistence and bioaccumulation
potential that would trigger testing.

b. Integrate the water column monitoring ("Aquatic Field
Dissipation") test requirement with the aquatic life tissue
monitoring study ("Accumulation in Aquatic Non-Target
Organism").

C. Require analysis of benthic organism tissues in the
currently required procedures.

d. In ecological risk assessment, require special field testing
when the Agency suspects sediment problems.

e. Work to reduce pesticide use in general by providing
information on better management practices and
Integrated Pesticide Management.

4. If the national inventory of contaminated sediment sites
indicates that certain pesticides are posing risks or causing
harmful effects on a national jcale, OPP may select these
pesticides for special review. Replacements need to be
identified for these pesticides in the form of biological and
bioengineered controls, as well as other alternatives to chemical
pesticides (e.g., Integrated Pest Management).

5. OPP iim currently developing a Memorandum of Agreement with
USGS for work in the National Water-Quality Assessment
(NAWQA) Program. USGS has developed and is testing
protocols for conducting ecological surveys and for collecting
and analyzing water samples for pesticides and synthetic
organic compounds. OPP will investigate whether sediment
could be added to the analyses.

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6. OPP uses incident reports which are often voluntary reports
made by citizens, farmers, and registrants for information on
use, misuse, or other problems associated with pesticides. OPP
will investigate sediment contamination in these incident reports
on a case-by-case basis. OPP is in the midst of setting up a
special process for cataloging, sorting, processing, and using
such incident reports in EPA's regulatory framework.

7. OPP is involved in various pollution prevention efforts.
Specifically, OPP is involved in technical guidance documents
on evaluation of pesticide risks, evaluation of a chemical
pesticide for its potential to runoff or to leach, possible
pesticide grants for examining specific areas with problems, and
other related topics.

B. TSCA gives EPA the authority to regulate new or existing chemicals
that have the potential to contaminate sediments, if ecological or
human health risks are judged to be unreasonable.

1 . In assessing risk, OPPT gathers important information for
predicting whether chemicals have the potential to accumulate
in sediments. However, in only a few cases has OPPT required
the submission of data an the effects of potential sediment
contamination (e.g., in the June 1991 test rule for brominated
flame retardants).

2. OPPT will seek resources to begin incorporating Agency-wide
tests into TSCA test guidelines and modeling databases.

3. OPPT will use the national inventory of contaminated sediment
sites and the pilot inventory of sources to select chemicals for
review.

4. OPPT will analyze TRI data to see if additional sources of
sediment contamination can be identified.

5. Through the New Chemicals Program, OPPT can ban or regulate
the production of chemicals that could contribute to sediment
contamination and result in unreasonable risk to human health
or the environment. OPPT can and has prevented pollution
from occurring. By encouraging the chemical industry to re-
design chemicals (e.g., molecular weights > 1000 to prevent

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absorption through biological membranes; K.,,, values > 8 for
no effects at saturation or < 3.5 to avoid partition to
sediment), OPPT can prevent pollution to aquatic and sediment
environments.

6. OPPT is working on an assessment of a cluster of chemicals
that may be persistent bioaccumulators. Chemicals which are
persistent bioaccumulators are likely to accumulate in
sediments. To the extent that this cluster, or elements thereof,
are shown to pose an unreasonable risk to human health or the
environment, OPPT will engage industry in discussions to
mitigate this risk through voluntary pollution prevention
measures.

7. Under the New Chemicals Program, OPPT has developed an
exposure-based review (EBR) policy. In this program,
environmental fate and effects tests (i.e., sediment toxicity
tests) may be triggered if certain criteria are mi3t in initial
review. Data gathered in this way will improve the OPPT risk
evaluation and management processes, and therefore prevent
sediment contamination.

8. OPPT is also proposing a geographic initiative that is designed
to develop a closer partnership between OPPT and the Regions
that will focus OPPT, TSCA, and pollution prevention on
selected site-specific problem areas. Many of these may well
be areas that include contaminated sediments. OPPT also
continues to work with the Great Lakes National Program Office
and EPA's Regional Office in Chicago (Region 5) to explore
ways to apply TSCA authorities to problems in the Great Lakes
region.

9. OPPT is assisting EPA's Region 5 in developing a testing
strategy which will provide the data necessary to complete an
environmental risk assessment for biocides which are
potentially toxic and could potentially bind to sediment. These
biocides, are proposed for use in large volumes to control fouling
of pipes and other surfaces by Zebra mussels in power plant
cooling systems. OPPT is working with the Region, the
manufacturer of the blocide.- and other EPA program office
representatives, to construct a series of tests to determine the
biodegradability of the biocide under environmentally relevant

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conditions and the potential for the substance to inhibit
sediment communities.

10. OPPT is working with trade associations providing insight and
guidance to their member companies. For example, OPPT and
other program offices are assisting members of the Ecological
and Toxicological Association of the Dyestuffs Manufacturing
Industry (ETAD) to develop a pollution prevention program to
record their past pollution prevention achievements, further
reduce waste generation, and continue to realize the benefits of
pollution prevention in the dye industry.

C. The Office of Enforcement issued two policies related to the use of
pollution prevention conditions in Agency enforcement settlements:
Policy on the Use of Supplemental Environmental Projects in EPA
Settlements (issued February 12, 1991) and Policy on the Inclusion of
Pollution Prevention Conditions in Enforcement Settlements (issued
February 25, 1991)

1 . These policies are designed to help reduce or eliminate root
causes of noncompliance by commuting the violation (via
enforceable agreements) to undertake appropriate source
reduction or recycling activities. This policy can be applied to
settlements on sediment contamination.

2. Settlements will emphasize reductions over and above what is
required to return to compliance with the requirements of law
and projects which enhance the prospects for long term (or
continuous) compliance.

3. OE is managing a pollution prevention initiative with the
participation of OPTS, Stationary Air, NPDES, and RCRA
compliance programs over the next two years. Funds for the
initiative will be used to:

a. provide technical support to Agency negotiation teams to
identify/evaluate the feasibility of specific pollution
prevention conditions,

b. monitor the respondent's or defendant's activities and
assure compliance with all settlement conditions,

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C. evaluate the effectiveness of the pollution prevention
conditions obtained in the settlements, and

d. develop enforcement-oriented technical pollution
prevention guidance for training purposes.

X. Strategy for Abating and Controlling Sources of Sediment Contamination
(Principles H and 1)

A. Tech nology- Based Controls for Point Sources

1 . Under the CWA, EPA sets minimum technology-based effluent
limits defined as Best Available Technology Economically
Achievable (BAT) for industries discharging directly into surface
waters and Pretreatment Standards for existing and now
industries discharging into municipal sewer systems.

2. To date, the BAT program has not considered sediment
contamination in selecting industries for regulation.

3. OW will use information on sediment contamination from the
national inventory of sites, the pilot inventory of sources, or
other available reports in deciding which industries will be
regulated by now or revised effluent guidelines.

4. Pollution prevention in the form of best management practices
(BMP's) or other in-plant approaches will be considered when
developing effluent guidelines.

B. Sediment Quality-Based Controls for Point Sources and Other
Limitations in NPDES Permits that Will Improve Sediment Quality.

1 To date, no NPDES permits have been issued with chemical-
specific or whole effluent toxicity limits designed to protect
specifie-@ levels of sediment quality. However, the NPDES
program continues to make progress in establishing water
quality-based effluent limitations in permits where they are
necessary to protect state water quality standards. These
improved water quality-based permits will result in additional
reductions in the release of toxics from point sources into

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surface water and will contribute indirectly to the protection of
sediment quality.

2. In FY 92, OW will continue to conduct case studies on deriving
NPDES permit limits based on sediment quality. OW will
prepare a draft guidance manual deriving permit limits and
conditions to protect sediment quality and release the manual
for public comment. Both chemical-specific and whole
sediment toxicity approaches will be addressed. OW will also
work with ORD to develop and apply sediment toxicity
identification evaluations to determine which pollutants from
which point sources are causing sediment contamination.

3. OW will seek FY 93 resources to begin implementation of
NPDES permit limits based on sediment criteria for high priority
discharges.

4. OW will use the national inventory of sites, the pilot inventory
of sources, or other available data to target point sources for
NPDES permit limits based on sediment quality.

5. OW will continue development, validation and application of
methods for screening and regulating point sources based on
their discharge of bioconcentratable contaminants. These
contaminants are also potential sediment contaminants.

6. OW will continue to focus on preventing and controlling
industrial stormwater discharges, discharges from municipal
separate storm sewer systems, and combined sewer overflows
which are known sources of sediment contamination. Each
facility covered by a general stormwater permit will be required
to prepare a pollution prevention plan.

7. OW will continue to require use of BMP's in NPDES permits to
minimize accidental spills of pollutants that may harrn sediment
and water quality.

8. Permit limits must be based on sediment quality and on in-plant
pollution prevention techniques.

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C. Nonpoint Source Control Program

1 Section 319 of CWA gives EPA authority to award grant funds
to States as an incentive for nonpoint source control.

2. OW's FY 91 Section 319 grants designate projects that prevent
sedimentation or contamination of sediments as eligible for
funding.

3. Section 314 of the CWA provides Clean Lakes grants to States.
Grants are used to develop methods and procedures to control
sources of pollution and restore water quality.

4. In FY 92, OW will allocate a portion of the 5% "national
incentive" set-aside in the grants program under Section 319 of
the CWA for preventing sediment contarnination.

5. OW will work to include measures for prevention of
sedimentation and sediment contamination in EPA's Agricultural
Pollution Prevention Strategy.

6. In June 1990 EPA and NOAA issued proposed national
guidance for nonpoint source controls under the Coastal Zone
Management Act Reauthorization Amendments of 1990. These
controls will help prevent sediment and water quality problems
due to nonpoint sources of pollution.

D. OW will use the national inventory of contaminated sediment sites in
evaluating strategies and projects under the National Estuary and Near
Coastal Waters management programs.

E. OSW has issued technical guidance to hazardous waste generators on
how to minimize waste and offers technical assistance through EPA's
Pollution Prevention Clearinghouse.

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X1. Remediation Strategy
(Principles J-N)

A. Enforcement-based Remediation

1 The following statutory provisions may be used in appropriate
circumstances to compel viable responsible parties to cleanup
the sites they have contaminated to levels which are causing
ecological harm or unacceptable risk to human health; to
recover costs from responsible parties for EPA-performed
cleanups; and to coordinate with natural resource trustees to
seek restitution for damages to natural resources:

a. CWA Sections 309, 311, 504

b. CERCLA Sections 104, 106, 107, 122

C. RCRA Sections 3004(u), 3004(v); 3008(a),
3008(h), 3013, 3005(c)(3), 7003

d. TSCA Section 7

2. EPA will use all of its existing statutory authorities in a
consistent, coordinated manner to pursue remediation of
contaminated sediments that are causing ecological harm or
posing unacceptable risks to human health. EPA will take care
to focus on compelling cases involving substantial
environmental damage or risks to human health.

3. EPA will coordinate its efforts with Federal and State regulatory
partners with additional authorities.

4. EPA will use additional authority for sediment remediation and
enforcement, if provided, when appropriate statutes are
reauthorized.

5. OE will seek a special FY 93 budget initiative to develop
enforcement cases in which the Agency will seek to require
that parties responsible for sediment contamination remedy the
harm and risks posed by their actions.

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6. OW will provide guidance to EPA Regional offices on successful
enforcement-based remediation cases under the CWA and urge
them to pursue cases of their own. OW will also analyze for
any correlations between dischargers with histories of permit
violations and sediment problems, as identified by the EPA's
inventories of sediment sites, sources, and other available
information.

B. Remediation under the CWA

1 . Section 115, which authorizes EPA and COE to cleanup
contaminated sediments, was funded only once in the 1970's.

2. In conjunction with OW and other interested program offices,
OFA will develop a Memorandum of Agreement (MOA) between
COE and EPA to remediate under Section 115 of the CWA,
CERCLA, Section 10 of the Rivers and Harbors Act, or other
such authority. The MOA would define the general roles and
responsibilities of COE and EPA in sediment remediation
projects.

3. EPA will use the national inventory of contaminated sediment
sites to select potential areas for remediation under Section 115
authority.

4. EPA will use the Agency-wide minimum set of testing methods
to assess sediment contamination at sites selected for potential
remediation under Section 115. Cleanup levels will be
determined on a site-specific basis, taking into account
technical and economic feasibility, and the hazards or risks that
would be posed by other technically and economically feasible
alternatives.

5. EPA will consider options for broadening the CWA sediment
remediation program as part of CWA reauthorization.

C. Remediation under CERCLA

1 . As part of the 1990 revisions to the Hazard Ranking System
(HRS), contaminated sediments received explicit consideration
in the scoring of sites. For sites scored under the new system,

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contaminated sediments now provide a basis for placement on
the NPL.

2. OERR will consider the results of a national inventory of sites
with contaminated sediments in the selection of sites for
scoring with the HRS.

3. OERR and OWPE are participating in an Agency-wide work
group to develop consistent tiered testing methods that will be
used in the Remedial Investigation/Feasibility Study stage of
Superfund remediation.

4. OERR has developed guidance for determining health-based
site-specific cleanup levels for remediation projects and is
developing guidance for determining levels to protect aquatic
life. These procedures may be revised as a result of the
Agency's effort to develop a comprehensive, consistent, risk-
based approach to managing remediation wastes in its
contaminated media cluster.

D. Remediation under RCRA Authorities

1 . OSW will use the information in the national inventory of
contaminated sediment sites or the pilot inventory of sources
for prioritizing RCRA facilities for corrective action. An
"observed release" will be scored for the surface water route
under the RCRA National Corrective Action Prioritization System
(NCAPS) for facilities which appear in the national or pilot
inventory. An observed release will pften lead to the
classification of a facility as "high priority" for corrective action.

2. If a RCRA Facility Assessment indicates that a release to
surface waters has occurred, extensive RCRA Facility
Investigations (RFI) will be required and include sediment
considerations.

3. OSW will use the Agency-wide minimum set of testing methods
in RFI by specifying these tests in the RFI Guidance.

4. OSW will develop site-specific cleanup levels using the Agency-
wide comprehensive, consistent risk-based approach to

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managing remediation wastes developed by the contaminated
media cluster.

E. Application of TSCA to remediation of PCB-contaminated sediments
under non-CERCLA authorities.

1 . In FY 92, OPPT will use the principles for remediation
developed by the Agency's contaminated media cluster to
determine the appropriate management scheme under TSCA
for sediments contaminated with PCBs.

2. TSCA already provides the EPA Regional Administrators with
flexibility in approving alternatives to the disposal methods
specified in the regulations implementing TSCA requirements
(incineration or disposal in TSCA-approved facilities).

F. EPA will coordinate its remediation strategy with NOAA (natural
resource damage claims), COE (remediation under CWA authority,
technical issues encountered in remediation projects under various
statutes) and with States.

XII. Dredged Material Management Strategy
(Principles C, D, and E)

A. EPA will work with the COE to ensure that dredged materials
continued to be managed in an environmentally sound manner. EPA
and the COE will take the following steps to improve the management
of dredged material:

1 . OW will ensure implementation of the recently revised national
testing manual ("Green Book") for evaluating dredged material
to be discharged into ocean waters under the IVIPRSA.

2. OW will continue to work with the COE to develop the first
national testing manual for evaluating discharges of dredged
material into inland waters of the U.S. under CWA authority.
This now manual will:

a. supplement the existing CWA Section 404(b)(1)
Guidelines for these evaluations,

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b. be consistent with the Green Book testing manual for
ocean waters, and

C. include physical and chemical tests, bioassay and
bioaccumulation tests, and QA plans and data -evaluation.

3. OW and OFA will work with the COE to develop a dredged
material management strategy document that identifies
alternative disposal options and relevant environmental factors
for each alternative.

4. OW will develop additional guidance on designating, monitoring,
and managing ocean sites where dredged materials are disposed
to ensure that adverse impacts will not occur.

B. RCRA and TSCA requirements for treating and disposing of
contaminated sediments are based upon testing procedures and
methodology that were not developed for the sediment media.

1 . In FY 92, OSW will use the principles for remediation
developed by the Agency's contaminated media cluster
to determine the appropriate management scheme for
dredged material under RCRA.

2. In FY 92, OPPT will use the principles for remediation
developed by the Agency's contaminated media cluster
to determine the appropriate management scheme for
dredged material contaminated with PCBs under TSCA.
TSCA already provides the EPA Regional Administrator
with flexibility in approving alternatives to the. disposal
methods specified in the regulations implementing TSCA
requirements.

C. EPA will coordinate its strategy for managing the disposal of dredged
materials with COE and with States.

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XIII. Research Strategy
(Principles C - G)

A. ORD will gather important chemical and biological data on sediment
quality in the surface water component of its EMAP program.

B. ORD will submit a sediment quality research initiative in the budgets
for FY 92 and beyond to focus resour ces on:

1 . Continued development of sediment quality criteria to protect
aquatic life.

2. Continued development of sediment quality criteria to protect
wildlife and human consumers of aquatic life.

3. Continued development of sediment physical and chemical
testing procedures for freshwater, estuarine, and marine
sediments.

4. Continued development of sediment chronic toxicity tests and
improved acute toxicity tests for sediments using freshwater,
estuarine and marine organisms.

5. Continued development of sediment bioaccumulation tests
using freshwater, estuarine and marine organisms.

6. Enhancement and validation of sediment fate and transport
models.

7. Improvement of Sediment Toxicity Evaluations.

8. Additional assessment of remedial techniques and development
of innovative methods.

C. In all of these activities, ORD will work closely with the program
offices and FDA Regions to ensure that the methods, tests, and
models it develops are useful to Agency programs. ORD will also
coordinate with COE, FWS, NOAA, USGS, and other Federal
agencies.

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D. Technology transfer

1 ORD will establish a Resource Center to provide the EPA
program offices and EPA Regional offices with technical
assistance in evaluating sediment contamination and its effects.

2. ORD will sponsor workshops and training sessions, such as the
recent workshop series on remediating contaminated sediments.

3. OW will co-sponsor workshops and training sessions with the
COE on sediment sampling and analysis.

XIV. Outreach Strategy

A. Building Alliances with Other Federal Agencies and States

1 . EPA will work toward an integrated Federal strategy versus
individual memoranda of understanding with other agencies.

2. Work with COE field offices to develop region specific
workshops to deal with regional issues.

3. Target sediment issues at the biannual meetings of the
Interagency Coordination Committee.

4. Work with the Department of Agriculture to ensure agricultural
practices are consistent with the goals of this strategy.

5. Work with the Bureau of Reclamation to consider sediment
contamination from irrigation.

6. EPA liaison to the Department of Defense will promote., the
sediment considerations outlined in the strategy.

7. Identify ways in which the Department of Transportation can
use the strategy to minimize sediment contamination from
highways.

DRAFT

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8. Work with the Department of Energy to ensure that current and
future environmental policies are considerate of sediment
contamination.

9. OFA's awards to other Federal agencies on exemplary
environmental work will consider sediment contamination
issues.

10. EPA will strive to ensure that all Federal and State agencies
share research findings and innovative technologies.

B. Public Awareness

1 . Include contaminated sediment issues in implementation of the
National Environmental Education Act.

2. Disseminate contaminated sediment information to the public in
a clear, accurate, and timely fashion.

3. As materials related to this strategy are developed, EPA will
request a review by the SAB.

4. Incorporate information from the public in EPA contaminated
sediment activities.

5. Sponsor National Conferences on Contaminated Sediments.

6. Promote and support the formation of a citizen group to track
and monitor implementation of the strategy.

DRAFT

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APPENDIX B

PROPOSED OUTREACH ACTIVITIES TO SUPPORT IMPLEMENTATION
OF EPA'S CONTAMINATED SEDIMENT MANAGEMENT STRATEGY

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June 3, 1992

PROPOSED OUTREACH ACTIVITIES TO SUPPORT IMPLEMENTATION OF
EPAIS CONTAMINATED SEDIMENT MANAGEMENT STRATEGY

1. Overview

A. Background

1 Contamination of sediments in water bodies of the United States is
an ecological and human health issue of national proportions.
Contamination has been identified in the sediments of water bodies at
levels high enough to harm human health and wildlife.

a. 1985 and 1987 Office of Water (OW) surveys found PC8s,
pesticides, PAHs, and metals at hundreds of sites.

b. A 1989 study by the National Academy of Sciences identified
the potential for far-reaching health and ecological effects of
contaminated sediments.

2. EPA's Contaminated Sediment Management Strategy

a. In 1989, EPA formed the Agency-wide Sediment Steering
Committee, chaired by OW's Deputy Assistant Administrator.

b. In January 1990, the Steering Committee prepared the
Strategy to:

0 Prevent ongoing contamination of sediments that may
cause unacceptable risks to human health and the
environment

0 Clean up existing sediment contamination where
practical

Ensure that sediment dredging and disposal of dredged
materials are managed in an environmentally sound
manner

3. 10 Statutes Deal with Management of Contaminated Sediments

a. Clean Water Act (CWA)

b. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

C. Toxic Substances Control Act (TSCA)

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d. Clean Air Act (CWA)

e. Resource Conservation and Recovery Act (RCRA)

f. Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA)

9. Marine Protection Research and Sanctuaries Act (MPRSA)

h. National Environmental Policy Act (NEPA)

i. Great Lakes Water Quality Agreement (GLWQA)/Great Lakes
Critical Programs Act (GLCPA)

j. Coastal Zone Management Act (CZMA)

4. EPA would like to build on other successful models in which
government and public and private interests have worked together to
strengthen government programs (e.g., Chesapeake Bay Program,
Public Private Partnerships, RCRA's Outreach Program, National
Estuary Program.)

5. EPA also would like to apply new legislation, such as the National
Environmental Education Act (NEEA), to implement programs in
schools and communities that will provide public education on
sediment contamination.

B. Forum Series on the Contaminated Sediment Management Strategy. Goal: to
allow key constituency groups to provide EPA with feedback about their
concerns and information needs.

1 . Forum 1. Extent and Severity of Contaminated Sediments, Chicago,
IL, April 21-22.

2. Forum 2. Coordination among Federal, State, and Local Agencies,
Washington, DC, May 27-28.

3. Forum 3. Outreach and Public Involvement, Washington, DC, June
16.

C. Goals of the Proposed Outreach Plan

1 . Primary goal is to educate key audiences about the problem of
contaminated sediments and EPA's Contaminated Sediment

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Management Strategy to solve the ecological and health problems
related to contaminated sediments.

2. EPA will focus on:

Defining key Strategy themes and messages

Identifying specific target audiences and information needs

Developing appropriate outreach materials (technical and non-
technical guidance, brochures, fact sheets, guidance
documents, videos, posters, etc.) to educate the public and
the regulated community about the problems associated with
contaminated sediments and how they should contribute to
solutions

Providing channels and forums through which interested
parties can become involved in Strategy implementation and
learn more about the issue of contaminated sediments (e.g.,
newsletters, meetings, workshops, etc.)

11. Communication Themes

A. Sediment Contamination Comes from Many Sources

� industrial effluent and emissions

� Agricultural, industrial, and urban nonpoint source controls

� Publicly owned treatment works

� Combined sewer overflows

� Stormwater

� Runoff and leachate from hazardous waste disposal sites

� Atmospheric deposition

B. Sediment Contamination Poses Threats to Human Health and the
Environment

1 . Heavy metals and toxic compounds that are persistent and
bioaccumulate are of greatest concern. Bioaccumulation is the

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process by which contaminants that persist in body tissues
accumulate in greater and greater concentrations with each animal
higher on the food chain.

2. Case Studies

a. In Ohio's Black River, where sediment contamination has been
documented, six species of fish have had frequent occurrence
of tumors.

b. In the Elizabeth River, Virginia, contaminated sediments appear
to be contributing to fish fin and gill rot as well as the growth
of tumors.

C. In the Great Lakes, contaminated sediments have been found
to affect the reproductive abilities of certain species of fish-
eating birds and mammals.

d. Significant contamination has been detected in fish in bays
and estuaries of California and Quincy Bay, just south of
Boston Harbor.

e. Fishing bans or fishing advisories are in effect in all but six
states (e.g., in the Great Lakes region, there are 1,000 fish
advisories).

3. Risk Communication. Education is needed about how to
communicate risks clearly and effectively in specific situations and
how to interpret the relative risks from sediment contamination in the
context of other relevant environmental and health risks.

C. Sediment Contamination Can Be Effectively Managed through Assessment,
Prevention, and Remediation

1 . EPA will respond to sediment contamination as consistently as
possible, assigning highest priority to activities with the greatest
potential for reducing unacceptable risks.

2. Assessment Activities

a. Create a national inventory of sites that may be used to:

0 Pinpoint geographic areas and potential sources of
sediment contamination

0 Provide data to rank sites according to level of risk

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Measure extent and severity

0 Provide data to target sites for pollution prevention and
control measures, or for remediation

b. Create an inventory of sources of point and nonpoint sediment
pollution

C. Establish a standardized set of testing and monitoring
procedures that will be:

Based on sound science

Implemented consistently throughout EPA and other
federal agencies

3. Pollution Prevention Activities

a. Evaluate the effects of pesticides and other persistent
chemicals in the environment and ban or restrict their use
where necessary to protect human health and the environment

b. Develop an agricultural pollution prevention strategy as a
critical component of the sediment strategy

C. Consider sediments when regulating industrial effluent
discharge, and setting permit limits for sediment quality,
bioaccumulation, toxic air pollutants, and high-priority
dischargers

4. Remediation Activities

a. Use the national inventory of sites to provide data for priority
sites for remediation under RCRA and CERCLA

b. As the preferred remedy, implement pollution prevention
measures and source controls, then allow natural recovery
through processes such as biodegradation and deposition of
clean sediments

C. Where pollution prevention, source control, and natural
remediation will not reduce risks in an acceptable time frame,
EPA will:

E Enforce cleanup of high-priority sites by responsible
parties

Recover costs for cleanups performed by the Agency

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Coordinate with natural resource trustees to seek
restitution

5. Dredged Materials Management Activities

a. Work with the U.S. Army Corps of Engineers (COE) to ensure
the sound management of sediment dredging and disposal of
dredged materials

b. Develop testing methods for assessing dredged material to be
disposed at sea and in fresh water

D. EPA's Strategy for Managing Contaminated Sediment Relies on Inter-Agency
Coordination and Alliances with Other Agencies, Industry, and the Public

1 . Communication and integration of efforts among all affected
audiences are necessary to promote:

Consistent characterization of risks

Consistent decision-making at the federal, state, and local
levels

Best use of financial and technical resources

Consistent assessment and testing methods

2. EPA will work with other federal agencies and states to implement an
integrated approach to managing contaminated sediments and to:

a. Coordinate assessment activities with the National Oceanic
and Atmospheric Administration (NOAA), the U.S. Geological
Survey (USGS), the U.S. Army Corps of Engineers (COE), the
U.S. Fish and Wildlife Service (FWS), and the states

b. Work with the U.S. Department of Agriculture (USDA), the
Department of Defense (DOD), the Department of
Transportation (DOT), and the Department of Energy (DOE) to
promote remediation and prevention practices consistent with
the Strategy

3. EPA intends to coordinate research and regulatory activities with
other state and federal agencies, international organizations, and
private groups.

_169-

4. EPA must work internally to coordinate, among Agency enforcement
programs, the 10 statutes that address contaminated sediments.

5. EPA will work with both private industry and the general public who
can each contribute to solutions and encourage the use of sound
practices consistent with the goals of the Strategy and implementing
voluntary actions to reduce risks posed by sediments.

6. Consideration of the development of a National Contaminated
Sediment Strategy Task Force and development of a national Federal
strategy for contaminated sediments.

111. Target Audiences

A. To Implement an Effective Outreach Plan, EPA Must:

1 . Communicate with large and highly diverse audiences

2. Educate and involve the general public in EPA's decision-making
processes

3. Target some information materials to broad audiences and others to
subgroups within these audiences

B. The Steps EPA Must Take in Designing and Targeting Its Messages Include:

1. Determining the information needs of each audience by assessing the
extent of their knowledge on the topic

2. Determining the audiences' positions and concerns about the topic

3. Determining the level of interest in the topic and develop ways to
increase interest and attention

4. Assessing how the topic fits in with the audience's agenda

5. Determining whether the primary purpose of the message is to inform
the audiences, change their attitudes, or encourage them to take
action

C. The Major Audiences EPA Intends to Target with Its Outreach Program Are:

1. General public

2. Environmental and public interest groups

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3. Scientific community including academia, laboratories, and
professional societies

4. Congressional representatives and government groups

5. Federal agencies, including the U.S. Army Corps of Engineers, the
U.S. Department of Energy, the U.S. Department of Defense, the
U.S. Department of Agriculture, and other agencies whose policies
and operations directly contribute to the sediment Strategy or affect
its goals

6. State and municipal agencies

7. Regional and Headquarter's EPA personnel

8. Regulated community including businesses and industrial trade
associations

9. News media including printed media, television, radio, and trade and
industry journals and environmental magazines

IV. Outreach Activities

A. Many EPA Offices May Contribute to the Development of Outreach Materials

As with the Contaminated Sediment Strategy itself, the outreach plan will
require the coordination and cooperation of various EPA Program Offices

B. Planned Activities Include the Following:

1 . EPA May Undertake Regulatory Actions and Prepare Major Guidance
Documents (Testing Methods, Sediment Criteria and Support
Documents, Risk Assessment Guidance, and Strategies That Focus
on Aspects of Assessment, Prevention, and Remediation)

a. Standards for minimum testing including acute and chronic
bioassays, chemical criteria, and bioaccumulation tests and
models

b. Guidance for regulatory action following assessment of
contaminated sites

C. Report to Congress on Great Water Bodies Study on the
effects of hazardous air pollutants

-171-

d. Remedial guidance and technologies on specific remedial
alternatives for contaminated sediment sites including
descriptions of technologies and remedial techniques

e. Bans or restrictions on the use of pesticides and chemicals
that may cause unreasonable risks to human beings or the
environment

f. Revision of TSCA test guidelines and modeling data bases that
address new or existing chemicals with the potential to
accumulate in sediments

9. Guidance for trade associations on pollution prevention issues,
including the contamination of sediments from point and
nonpoint source pollution

h. Agricultural Pollution Prevention Strategy that includes
methods for reducing erosion, controlling irrigation, and
minimizing runoff of pesticides and fertilizer that contribute to
nonpoint source pollution

i. Section 319 (CWA) grant programs for nonpoint source
control

j. Guidance manual for deriving permit limits and conditions to
protect sediment quality (chemical-specific and whole
sediment toxicity approaches)

k. Proposed national guidance for nonpoint source controls to
help prevent sediment and water quality problems due to
nonpoint source pollution

1. National guidance on dredged materials testing of ocean
waters

M. National guidance on dredged materials testing of inland
waters

n. qtrategy document on the environmental factors to consider
when evaluating disposal options for dredged materials

0. Additional guidance on designating, monitoring, and managing
ocean sites where dredged materials are disposed

P. Guidance for determining site-specific cleanup levels for
remediation projects

-172-

2. Public Outreach Publications and Multimedia Materials

a. EPA may prepare outreach publications and support other
agencies in developing their own technical and general
audience publications.

b. EPA may develop journal articles, pamphlets, brochures, fact
sheets, slide shows, and other multimedia materials to inform
a variety of technical and nontechnical audiences about issues
and solutions related to sediment contamination.

C. These materials could be distributed through a hotline; through
advertising in bulletins (such as the Contaminated Sediments
News quarterly bulletin); or at public meetings, workshops,
and national conferences on pollution prevention or
contaminated sediments.

3. Other (Advisory Groups, Data Bases, Clearinghouses, Workshops)

a. EPA may support the establishment of a Citizen's Advisory
Council on Sediment Management. This council could:

0 Track and monitor implementation of the Strategy

0 Be composed of members of the regulated community,
including businesses and trade associations; federal,
state, and local governments; environmental groups;
the scientific community; educators; and private
citizens

Meet on an annual or biannual basis to review Strategy
achievements and policies, provide additional
information, and make recommendations

b. National inventory of contaminated sediment sites that lists
specific geographic areas and potential sources, and provides
data to rank risk levels as high, medium, or low, or known vs.
suspected risk

C. Environmental Monitoring and Assessment Program (EMAP) to
gather and make available important chemical and biological
data on sediment quality

d. Pilot inventory of sources listing specific industries using the
Toxic Release Inventory (TRI), effluent guidelines data, and
other data

-173-

e. Water-Quality Monitoring Intergovernmental Task Force (ITF)
to design a national monitoring framework, information system
linkages, monitoring protocols, and QA/QC procedures that
include sediments

f. Pollution Prevention Clearinghouse that includes waste
minimization measures to reduce the potential for
contamination of sediments from runoff, leaching, industrial
effluent, or other sources

9. National Consultation Center to provide EPA program and
Regional offices with technical assistance in evaluating
sediment contamination and its effects

h. Interagency Coordination Committee meetings to target
sediment issues

i. Memoranda of Understanding and Agreement with other
agencies to work toward an integrated federal strategy for
managing contaminated sediments

National Task Force on Contaminated Sediment Management
to replace the memoranda of understanding and agreement
approach to agency cooperation

k. Contaminated sediments management hotline to answer
questions and respond to requests for information concerning
sediment contamination and issues related to the Strategy's
implementation

1. EPA awards to federal agencies on exemplary environmental
work to highlight projects related to sediment contamination

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APPENDIX C

AGENDAS OF THREE CONTAMINATED
SEDIMENT MANAGEMENT STRATEGY FORUMS

-175-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAIS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

THE EXTENT AND SEVERITY OF SEDIMENT CONTAMINATION

Holiday Inn - Mart Plaza
Uj Chicago, IL
April 21-22, 1992

AGENDA

TUESDAY, APRIL 21

7:30 AM Registration/Check-in

8:30 AM Welcome
Timothy J. Kasten
Contaminated Sediments Section, U.S. Environmental Protection
Agency

8:45 AM Overview of the Contaminated Sediments Management Strategy
Tudor T. Davies, Director
Office of Science and Technology, U.S. Environmental Protection
Agency

Extent and Severity of Sediment Contamination: EPA's Management
Strategy for Contaminated Sediments
Timothy J. Kasten
Contaminated Sediments Section, U.S. Environmental Protection
Agency

9:00 AM Forum Overview
Charles Menzie, Forum Moderator
Menzie - Cura & Associates, Inc.

Extent of Sediment Contamination

9:15 AM The Extent and Severity of Sediment Contamination in the Estuaries of the
Nfid-Atlantic Region
Richard W. Latimer, Acting Technical Director
EMAP Program, U.S. Environmental Protection Agency

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9:35 AM National Distribution of Sediment Contamination
Thomas P. O'Connor, Manager
National Status and Trends Program, National Oceanic and
Atmospheric Administration

9:55 AM Compiling Sediment and Pollutant Databases from the Historical Record:
Results of the Studies from the Boston Harbor - Massachusetts Bay Program
Frank T. Manheim, Senior Research Geologist
U.S. Geological Survey

10:15 AM Break

10:35 AM U.S. Army Corps of Engineers National Dredging Program
Charles R. Lee
U.S. Army Corps of Engineers

10:55 AM Sediment Contamination in the Great Lakes
Steve Garbaciak
Great Lakes National Program Office, U.S. Environmental
Protection Agency

11:15 AM Formal Comment Period

11:45 PM Open Discussion

12:45 PM Lunch

Severity of Contaminated Sediments - Human Health Effects

2:00 PM Estimating the Severity of Human Health Effects Caused by Chemically
Contaminated Sediments in California
Gerald A. Pollock, Acting Chief of Fish and Sediment
Contamination Evaluation Unit
Pesticide and Environmental Toxicology Section, California
Environmental Protection Agency

2:20 PM The Impacts of Contaminated Sediments on Human Health: A Case Study
from the Great Lakes
Wayland R. Swain, Vice-President
Eco Logic International, Inc.

2:40 PM Break

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3:00 PM Risks Associated with Seafood Consumption: Perception vs. Reality - The
Quincy Bay Case Study
Nancy Ridley, Director
Bureau of Environmental Monitoring, Massachusetts Department of
Public Health

3:20 PM Human Health Risks Associated with Dermal Contact and Incidental
Ingestion of Contaminated Sediments
William R. Alsop, Environmental Scientist
ENSR Consulting & Engineering

3:40 PM Formal Comment Period

4:10 PM Open Discussion

5:00 PM Adjourn

5:30 - 7:30 PM Cash Bar Reception

WEDNESDAY, APRIL 22

Severity of Contaminated Sediments - Ecological Effects

9:00 AM PAHs in Sediment Cause Uver Tumors and Reduced Lifespan in Brown
Bullhead
Paul C. Baumann
U.S. Fish and Wildlife Service

9:20 AM Integrative Sediment Assessments
Peter M. Chapman, Director
EVS Environment Consultants

9:40 AM Break

10:00 AM Ecological Effects of Contaminated Sediments in the Elizabeth River,
Virginia
Robert C. Hale, Division Head
Virginia Institute of Marine Science

10:20 AM Case Studies of the Ecological Effects,of Contaminated Sediments in the
Northeastern Gulf of Mexico
Barry A. Vittor, President
Barry A. Vittor and Associates, Inc.

10:40 AM Formal Comment Period

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11:10 AM Open Discussion

12:00 PM Recommendations for the Sediment Steering Committee and Strategy -
Summary of Forum

12:30 PM Adjourn

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U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAIS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

BUILDING ALLIANCES AMONG FEDERAL, STATE, AND
LOCAL AGENCIES TO ADDRESS THE NATIONAL PROBLEM
Uj OF CONTAMINATED SEDIMENTS
Holiday Inn Capitol
Washington, DC
May 27-28, 1992

AGENDA

Wednesday, May 27

8:00 AM Registration/Check-in

9:00 AM Welcome & Overview of EPA's Contaminated Sediments Management
Strategy
U.S. EPA, Office of Water
Betsy Southerland

9:30 AM Forum Overview
Virginia Tippie, Forum Moderator
Council on Environmental Quality, Executive Office of the President

ASSESSING SEDIMENT CONTAMINATION

9:40 AM EPA's Proposed Assessment Strategy
U.S. EPA, Betsy Southerland

- National Inventory of Contaminated Sediment Sites
- National Inventory of Contaminant Sources
- Use of a Standard Sediment Toxicity Test
- Monitoring

10:00 AM Federal and State Agency Discussion to Address:

- What agencies are doing to assess sediment contamination
- How it coincides with EPA's activities outlined in the strategy
- The strengths and weaknesses of the assessment approach in
EPA's Draft Strategy Outline
- How two or more agencies could work together to address
assessment of contaminated sediments

-180-

Wednesday, Ma-y 27 (continued)

10:00 AM U.S. Geological Survey
Gail Mallard

10:20 AM U.S. Army Corps of Engineers
David Moore and Joseph Wilson

10:40 AM National Oceanic and Atmospheric Administration
Andrew Robertson

11:00 AM Break

11:20 AM U.S. Fish and Wildlife Service
Donald Steffeck

11:40 AM Florida Department of Environmental Regulation
Fred Calder

12:00 PM Open Discussion and Public Comment

12:45 PM Lunch

PREVENTING SEDIMENT CONTAMINATION

2:00 PM EPA's Proposed Prevention Strategy
U.S. EPA
Judy Nelson
Pollution Prevention: Registration of Pesticides and Toxic
Substances
Stuart Tuller
Non-Point Source Controls under Section 319 of Clean Water Act,
Agricultural Pollution Prevention Strategy
James Pendergast
Point Source Controls: Effluent Guideline considerations,
NPDES permit limits based on sediment quality
James Edward
Enforcement Based Prevention

2:20 PM Federal and State Agency Discussion to Address:

- What agencies are doing to prevent sediment contamination
- How it coincides with EPA's activities outlined in the strategy
- The strengths and weaknesses of the prevention approach in
EPA's Draft Strategy Outline
- How two or more agencies could work together to address
prevention of contaminated sediments

-181-

Wednesday, May 27 (continued)

2:20 PM U.S. Department of Agriculture, Agriculture Research Service
David Farrell

2:40 PM U.S. Department of Agriculture Forest Service
Warren Harper

3:00 PM National Oceanic and Atmospheric Administration: Coastal Zone
Management Program
James Burgess

3:20 PM Break

3:40 PM Wisconsin Department of Natural Resources
Duane Schuettpelz

4:00 PM California State Water Resources Control Board
Craig Wilson

4:20 PM Open Discussion and Public Comment

5:00 PM Adjourn

Thursday, May 28

REMEDIATION OF CONTAMINATED SEDIMENTS

9:00 AM EPA's Proposed Remediation Strategy
U.S. EPA
Richard Nagel
Enforcement Based Remediation
Clean Water Act
Comprehensive Envirorunental Response Compensation
and Liability Act (Superfund)
Resource Conservation and Recovery Act (RCRA)
Toidc Substances Control Act (TSCA)
Lawrence Zaragoza
Superfund Remediation
Siting: Hazard Ranking System
Remedial Investigation/Feasibility Study
Health Based Site Specific Clean-Up Levels
Denise ieehner
RCRA Remediation
Facility Investigation
Corrective Action Prioritization
0 Dredged Material
Tony Baney
TSCA Remediation
PCB Remediation.
Dredged Material

-182-

Thursday. May 28 (continued)

9:30 AM Federal and State Agency Discussion to Address:

- What agencies are doing to remediate sediment contamination
- How it coincides with EPA's activities outlined in the strategy
- The strengths and weaknesses of the remediation approach in
EPA's Draft Strategy Outline
- How two or more agencies could work together to address
remediation of contaminated sediments

9:30 AM Department of Energy
Bruce Kimmel

9:55 AM U.S. Army Corps of Engineers
Norman Francingues and Joseph Wilson

10:20 AM Break

10:40 AM Washington State Government Representative
Keith Phillips

11:05 AM Open Discussion and Public Comment

12:00 PM Summary of Forum Recommendations

12:30 PM Adjoum

-183-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

OUTREACH AND PUBLIC AWARENESS

Holiday Inn Capitol
Uj Washington, DC
C June 16, 1992
AGENDA

Tuesday, June 16

8:00 AM Registration/Check-in

9:00 AM Welcome and Introduction
U.S. EPA Office of Water (OW)

9:15 AM Overview of EPA Contaminated Sediments Management Strategy
Betsy Southerland, U.S. EPA, Office of Science and Technology

9:30 AM Forum Overview
Charles Menzie, Forum Moderator, Menzie-Cura & Associates

9:40 AM EPA's Ideas for Outreach and Public Awareness
Tom Armitage, U.S. EPA, Office of Water

10:10 AM BREAK

10:30AM PANEL PRESENTATIONS
Panelists include representatives from various targeted audiences: 1) State
Government; 2) Regulated Community; 3) Environmental Advocacy Groups; and
4) Public Awareness Groups.

Each panelist will make a 25-minute presentation to include:

1. Discuss what the targeted audiences already know or need to ki-low about
contaminated sediments and the environmental and human health risks
that they may pose.

2. Provide feedback on EPA's outreach activities and suggestions for
activities not presented by EPA.

3. Present successful examples of outreach and public awareness activities.
Correlations will be drawn between the example presented and its
applicability to contaminated sediment issues as outlined in the Draft
Strategy. Reasons for the particular success of the program will be
discussed. Examples may include technical transfer activities, guidance
rAf

supplied to the regulated community, and programs to build public
support for and awareness of environmental protection efforts similar to
the contaminated sediments management strategy.

-184-

Agenda - Page Two

Each presentation will be followed by 20 minutes of questions, comments, and
dicussion.

PANEL PRESENTATIONS

STATF- GOVERNMENT

10:30AM Representative from State Government
David O'Malley, Wisconsin Department of Natural Resources

10:55AM Discussion Period

11:15AM Representative from the Regulated Community
Chemical Manufacturer's Association

11:40AM Discussion Period

12:OOPM LUNCH (90 minutes)

PANEL PRESENTATIONS CONTINUE

ENVIRONMENTAL ADVOCACY

1:30PM Lake Michigan Federation
Glenda Daniels

1:55PM Discussion Period

2:15PM Coast Alliance
Beth Millemann

2:40PM Discussion Period

3:OOPM BREAK

PUBLIC AWARENESS

3:15PM Alliance for the Chesapeake Bay
Frances H. Flanigan

3:40PM Discussion Period

4:OOPM Open Discussion and Comment on Outreach and Public Awareness Themes

4:30PM Summary of Panel and Discussion of EPA's Contaminated Sediment
Management Strategy

5:OOPM Adjourn

-185-

APPENDIX D

FORUM SPEAKERS

-187-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPA'S CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

THE EXTENT AND SEVERITY OF CONTAMINATED SEDIMENTS

Holiday Inn - Mart Plaza
UU Chicago, IL
C N April 21-22, 1992
r4f SPEAKER LIST

William R. Alsop Tudor T. Davies
Environmental Scientist Director
ENSR Consulting and Engineering Office of Science and Technology
35 Nagog Park U.S. Environmental Protection Agency
Acton, MA 01742 401 M Street, SW (WH-551)
508-635-9500 Washington, DC 20460
Fax: 508-635-9180 202-260-5400

Paul C. Baumann Steve Garbaciak
U.S. Fish and Wildlife Service Great Lakes National Program Office
Ohio State University U.S. Environmental Protection Agency
473 Kottman Hall 77 West Jackson Boulevard (G-9J)
2021 Coffey Street Chicago, IL 60604
Columbus, OH 43210 312-353-0117
614-469-5701 Fax: 312-353-2018
Fax: 614-292-7162
Robert C. Hale
Richard A. Cahill Division Head
Illinois State Geological Survey Virginia Institute of Marine Science
615 East Peabody Drive P.O. Box 1346
Champaign, IL 61820 Gloucester Point, VA 23062
217-244-2532 804-642-7228
Fax: 217-244-7004 Fax: 804-642-7186

Peter M. Chapman Timothy J. Kasten
Director Contaminated Sediments Section
EVS Environment Consultants U.S. Environmental Protection Agency
195 Pemberton Avenue 401 M Street, SW (WH-585)
North Vancouver, B.C. V7P 2R4 Washington, DC 20460
Canada 202-260-5994
604-986-4331 Fax: 202-260-9830
Fax: 604-662-8548

-188-

Richard W. Latimer Gerald A. Pollock
Acting Technical Director Acting Chief of Fish and Sediment
Environmental Research Laboratory Contamination Evaluation Unit
U.S. Environmental Protection Agency PETS, Office of Environmental Health
27 Tarzwell Drive Hazard
Narragansett, RI 02882 California Environmental Protection Agency
401-782-3077 P.O. Box 942732
FIFS: 401-838-6000 601 North Seventh Street
Fax: 401-782-3099 Sacramento, CA 94234-7320
916-323-9667
Charles R. Lee Fax: 916-327-1097
Waterways Experiment Station
U.S. Army Corps of Engineers Nancy Ridley
3909 Halls Ferry Road (WES-ES-R) Director
Vicksburg, MS 39180 Bureau of Environmental Monitoring
601-634-3585 Massachusetts Department of Public Health
Fax: 601-634-3120 305 South Street
Jamaica Plain, MA 02130
Frank Manheim 617-727-2670
Senior Research Geologist Fax: 617-524-8062
Office of Energy and Marine Geology
U.S. Geological Survey Wayland R. Swain
Quisette Campus Vice President
Woods Hole, MA 02543 Eco Logic International, Inc.
508-457-2235 2395 Huron Parkway
FTS: 508-837-4235 Ann Arbor, MI 48104
Fax: 508-457-2310 313-973-2780
Fax: 313-677-0055
Charles Menzie
President Barry A. Vittor
Menzie-Cura & Associates, Inc. President
1 Courthouse Lane - Suite 2 Barry A. Vittor & Associates, Inc.
Chelmsford, MA 01824 8060 Cottage Hill Road
508-453-4300 Mobile, AL 36695
Fax: 508-453-7260 205-633-6100
Fax: 205-633-6738
Thomas P. O'Connor
Manager
National Status and Trends Program
N/ORCA-21
National Oceanic and Atmospheric
Administration
6001 Executive Boulevard
Rockville, MD 20852
301-443-8655
Fax: 301-231-5764

-189-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAIS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

BUILDING ALLIANCES AMONG FEDERAL, STATE, AND
LOCAL AGENCIES TO ADDRESS THE NATIONAL PROBLEM
Uj OF CONTAMINATED SEDIMENTS
Holiday Inn Capitol
Washington, DC
May 27-28, 1992

SPEAKER LIST

Tony Baney David Farrell
Chemical Regulations Branch Buildirig 005 - Room 201
U.S. Environmental Protection Agency BARC West
401 M Street, SW (TS-798) Beltsville, MD 20705
Washington, DC 20460 301-504-6246
202-260-3933 Fax: 301-504-5467
Fax: 202-260-1724
Ellen Fisher
James Burgess Wisconsin Department of Transportation
Coastal Programs Division P.O. Box 7914
Office of Ocean & Coastal Madison, WI 53707-7914
Resource Management/CPD 608-267-9319
National Oceanic Fax: 608-267-6748
& Atmospheric Administration
1825 Connecticut Avenue, NW - Room 724 Norman Francingues
Washington, DC 20235 U.S. Army Corps of Engineers
202-606-4158 Waterways Experiment Station
Fax: 202-606-4329 3909 Halls Ferry Road (CEWES-EE-S)
Vicksburg, MS 39180-6199
Fred Calder 601-634-3703
Florida Department of Fax: 601-634-3833
Environmental Regulation
2600 Blair Stone Road Warren Harper
Tallahassee, FL 32399-2400 Watershed & Air Management
904-488-0784 U.S. Department of Agriculture
Fax: 904-487-4938 Forest Service
201 14th Street, SW - Auditors 35
James Edward Washington, DC 20250
Strategic Planning & Prevention 202-205-1475
U.S. Environmental Protection Agency Fax: 202-205-1096
401 M Street, SW (OE-2261)
I
<Amk
rm

Washington, DC 20460
202-260-8859
Fax: 202-260-9437

-190-

Denise Keehner James Pendergast
Office of Solid Waste Water Quality & Industrial Permits Branch
U.S. Environmental Protection Agency Office of Water
401 M Street, SW (OS-341) U.S. Environmental Protection Agency
Washington, DC 20460 401 M Street, SW (EN-336)
202-260-4740 Washington, DC 20460
Fax: 202-260-0096 202-260-9537
Fax: 202-260-1460
Bruce Kimmel
Martin Marietta Energy Systems, Inc.
Oak Ridge National Laboratory Keith Phillips
Building 1505 - P.O. Box 2008 (MS: 6038) Sediment Management Unit
Oak Ridge, TN 37831-6038 Washington Department of Ecology
615-574-7833 P.O. Box 47703
Fax: 615-576-8646 Olympia, WA 98502-7703
206-459-6143
Gail Mallard Fax: 206-493-2967
Water Resources Division
U.S. Geological Survey Randall Ransom
National Center (MS: 412) Dow Corning Corporation
Reston, VA 22092 3901 South Saganaw Road
703-648-6872 Midland, MI 48686-0995
Fax: 703-648-5295 517-496-5644
Fax: 517-496-5419
David Moore
Waterways Experiment Station Andrew Robertson
3909 Halls Ferry Road (CEWES-EE-S) Coastal Monitoring & Bioeffects
Vicksburg, MS 39180-6199 Assessment Division
601-634-3624 National Oceanic
Fax: 601-634-3833 & Atmospheric Administration
6001 Executive Boulevard - Room 323
Richard Nagle N/ORCA 2
U.S. Environmental Protection Agency Rockville, MD 20852
77 West Jackson Boulevard (CS-3T) 301-443-8933
Chicago, IL 60607 Fax: 301-231-5764
312-353-8222
Fax: 312-886-0747 Duane Schuettpelz
Surface Water Standards
Judy Nelson & Monitoring Section
Office of Prevention, Pesticides, Wisconsin Department of Natural Resources
& Toxic Substances 101 South Webster Street - P.O. Box 7921
U.S. Environmental Protection Agency Madison, WI 53707
401 M Street, SW (TS-788) 608-266-0156
Washington, DC 20460 Fax: 608-267-2800
202-260-2890
Fax: 202-260-0951

-191-

Betsy Southerland Lawrence Zaragoza
Office of Water Office of Solid Waste
U.S. Environmental Protection Agency U.S. Environmental Protection Agency
401 M Street, SW (WH-585) 401 M Street, SW (OS-230'
Washington, DC 20460 Washington, DC 20460
202-260-3966 202-260-2467
Fax: 202-260-9830 Fax: 202-260-0854

Donald Steffeck
Division of Environmental Contaminants
U.S. Fish & Wildlife Service
4401 North Fairfax Drive - Room 330
Arlington, VA 22203
703-358-214-8
Fax: 703-358-1800

Virginia Tippie (Forum Moderator)
Council on Environmental Quality
722 Jackson Place, NW
Washington, DC 20503
202-395-3706
Fax: 202-395-3874

Stuart Tuller
Nonpoint Source Control Section
Office of Water
U.S. Environmental Protection Agency
401 M Street, SW (WH-553)
Washington, DC 20460
202-260-7112
Fax: 202-260-7024

Craig Wilson
Bay Protection & Toxic Cleanup Program
California State Water
Resources Control Board
901 P Street
Sacramento, CA 95814
916-657-1108
Fax: 916-657-2388

Joseph Wilson
U.S. Army Corps of Engineers
CE CW-OD
20 Massachusetts Avenue, NW
Washington, DC 20314
202-272-8846
Fax: 202-272-1685

-192-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

OUTREACH AND PUBLIC AWARENESS

Holiday Inn Capitol
LU Washington, DC
June 16, 1992

SPEAKER LIST

Tom Armitage Beth Millemarm
Office Of Water (WH-585) Coast Alliance
U.S. Environmental Protection Agency 235 Pennsylvania Avenue, SE
401 M Street, SW Washington, DC 20003
Washington, DC 20460 202-546-9554
202-260-5388 Fax: 202-546-9609
Fax: 202-260-9830
David O'Malley
Michael Baker Wisconsin Department of
Office of Environmental Education Natural Resources
U.S. Environmental Protection Agency Box 7921
401 M Street, S.W. 101 South Webster Street
Washington, DC 20460 Madison, W1 53707
608-266-9275
Glenda Daniel Fax: 608-267-2800
Uke Michigan Federation
59 East Van Buren - Suite 2215 Charles Menzie (Moderator)
Chicago, IL 60605 Menzie-Cura & Associates, Inc.
312-939-0838 1 Courthouse Lane - Suite 2
Fax: 312-939-2708 Chelmsford, MA 01824
508-453-4300
Frances H. Flanigan Fax: 508-453-7260
Executive Director
Alliance for the Chesapeake Bay Betsy Southerland
6600 York Road Office of Water (ATIH-585)
Baltimore, MD 21212 U.S. Environmental Protection Agency
410-377-6270 401 M Street, SW
Fax: 410-377-7144 Washington, DC 20460
202-260-3966
Fax: 202-260-9830
I=
1bw

-193-

Richard F. Schwer
E.I. Dupont
P.O. Box 6090
Newark, DE 19714-6090
302-366-4257
Fax: 302-366-4123

Donna R. Tomlinson
Eastman Chemical Company
P.O. Box 1993
Kingsport, TN 37662
615-229-4120
Fax: 615-229-4864

Anthony Wagner (Contact)
Manager, Water Issues
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
202-887-1174
Fax: 202-887-1237

-194-

APPENDIX E

FORUM ATIPENDEES

-195-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAIS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

THE EXTENT AND SEVERITY OF CONTAMINATED SE I)IMENTS
Uj Holiday Inn - Mart Plaza
Chicago, IL
April 21-22, 1992

ATTENDEE LIST

Tom Aartila Shiv Baloo
Wisconsin Department of Natural Resources Amoco Corporation
2300 North Martin Luther King, Jr. Drive P.O. Box 3011
P.O. Box 12436 Naperville, IL 60566
Milwaukee, WI 53212 708-961-7919
414-263-8701 Fax: 708-420-3698
Fax: 414-263-8483
Gordon Bart
David Allen Texas Gas Transmission Corporation
U.S. Fish and Wildlife Service 3800 Frederica Street
U.S. Department of the Interior Owensboro, KY 42301
1015 Challenger Court 502-926-8686
Green Bay, WI 54311 Fax: 502-926-8686
414-433-3803
Fax: 414-433-3882 Robert Bergsvik
Daily Southtown Economist
Thomas Anderson 5959 South Harlem Avenue
Save the Dunes Council Chicago, IL 60638
444 Barker Road 312-229-2805
Michigan City, IN 46360 Fax: 312-229-2900
219-879-3937
Fax: 219-872-4875 Christine Bourn
ENSR Consulting & Engineering
Thomas Armitage 740 Pasquinelli Drive
Chief, Contaminated Sediment Section Westmont, IL 60559
U.S. Environmental Protection Agency 708-887-1700
401 M Street, SW (WH-585) Fax: 708-850-5307
Washington, DC 20460
202-260-5388 John Brabeck
Fax: 202-260-9830 Science Applications
International Corporation
1 East Wacker Drive - Suite 2500
Chicago, IL 60601
312-670-3600
Fax: 312-670-3604

-196-

Mary Brockmiller John Claussen
Amoco Corporation General Electric Company
200 East Randolph Drive (MC-1103) 3135 Easton Turnpike
Chicago, IL 60601 Fairfield, CT 06431
312-856-5879 203-373-2714
Fax: 312-616-0529 Fax: 203-373-3342

G. Allen Burton Mary Colwell
Biological Sciences Department Lake County Health Department
Wright State University 3010 Grand Avenue
Dayton, OH 45435 Waukegan, IL 60085
513-873-2201 708-360-6747
Fax: 513-873-3301 Fax: 708-360-3656

Thomas Buttner Glenda Daniel
Ruetgers-Nease Chemical Company Lake Michigan Federation
c/o Baker & McKenzie 59 East Van Buren - Suite 2215
130 East Randolph Drive - Suite 3200 Chicago, IL 60605
Chicago, IL 60601 312-939-0838
312-861-2868
Fax: 312-861-2899 Mick DeGraeve
Battelle Great Ukes Environmental Center
Robert Byrne 739 Hastings
Wildlife Management Institute Traverse City, MI 49684
1101 14th Street, NW - Suite 725 616-941-2230
Washington, DC 20005 Fax: 616-941-2240
202-371-1808
Fax: 202-408-5059 Valerie Denney
Grand Cal Task Force
Richard Cahill 4141 North Paulina
Illinois State Geological Survey Chicago, IL
615 East Peabody Drive 312-880-5679
Champaign, IL 61820
217-244-2532 John Distin
Fax: 217-244-7004 Squire, Sanders & Dempsey
1800 Huntington Building
Phillippa Cannon Cleveland, OH 44115
U.S. Environmental Protection Agency 216-687-8530
77 West Jackson Boulevard (Pl-195) Fax: 216-687-8793
Chicago, IL 60604
312-353-6218 John Dorkin
Water Division
Paul Carver U.S. Environmental Protection Agency
Maguire Group, Inc. 77 West Jackson Boulevard (15-J)
1 Court Street Chicago, IL 60604
New Britain, CT 06051 312-886-6873
203-224-9141
Fax: 203-224-9147

-197-

Howard Duckman William Gala
U.S. Environmental Protection Agency Chevron Research & Technology, Company
77 West Jackson Boulevard (WCC-15J) 1003 West Cutting Boulevard
Chicago, IL 60604 Richmond, CA 94804-0054
312-886-6716 510-242-4361
Fax: 312-886-0168 Fax: 510-242-1380

Wade Eakle Robert George
U.S. Army Corps of Engineers Hydraulic Engineer
211 Main Street (CESPN-CO-RI) U.S. Bureau of Reclamation
San Francisco, CA 94105 P.O. Box 25007
415-744-3325 Denver, CO 80225
Fax: 415-744-3320 303-236-3777
Fax: 303-236-0199
Bonnie Eleder
U.S. Environmental Protection Agency Howard Greenburg
77 West Jackson Boulevard (HSRW-6J) Ruetgers-Nease Chemical Company
Chicago, IL 60604 c/o Baker & McKenzie
312-886-4885 130 East Randolph Drive - Suite 3200
Chicago, IL 60601
Laura Evans 312-861-2868
Ecology & Environment, Inc. Fax: 312-861-2899
111 West Jackson Boulevard
Chicago, IL 60604 John Haggard
312-663-9415 General Electric Company
Fax: 312-663-0791 One Computer Drive, S
Albany, NY 12205
Al Fenedick 518-458-6619
U.S. Environmental Protection Agency Fax: 518-458-9247
77 West Jackson Boulevard (5MP-19J)
Chicago, IL 60606 Amy Hardwick
312-886-6872 ENSR Consulting & Engineering
Fax: 312-353-4135 740 Pasquinelli Drive
Westmont, IL 60559
William Fitzpatrick 708-887-1700
Water Resources Engineer Fax: 708-850-5307
Wisconsin Department of Natural Resources
101 South Webster Street - P.O. Box 7921 Michael Henebry
Madison, WI 53707-7921 Aquatic Toxicologist
608-266-9267 Illinois Environmental Protection Agency
Fax: 608-267-2800 2200 Churchill Road
P.O. Box 19276
Cynthia Fuller Springfield, IL 62794
Woodward-Clyde Consultants 217-782-8779
122 South Michigan Avenue - Suite 1920 Fax: 217-524-4959
Chicago, IL 60603
312-939-1000
Fax: 312-939-4198

-198-

Michael Hickey Daniel Injerd
Howard Needles Tammen Bergendoff Acting Chief
111 North Canal Street - Suite 880 Division of Water Resources
Chicago, IL 60601 Bureau of Resource Management
312-930-9119 Illinois Department of Transportation
Fax: 312-930-9063 310 South Michigan Avenue - Room 1606
Chicago, IL 60604
Pat Hill 312-793-3123
Water Quality Programs Fax: 312-793-5968
American Paper Institute
1250 Connecticut Avenue, NW Thomas Janisch
Washington, DC 20036 Environmental Specialist
202-463-2581 Water Resources Branch
Fax: 202-462-2423 Wisconsin Department of Natural Resources
101 South Webster Street - P.O. Box 7921
Linda Holst Madison, WI 53707-7921
Watershed Unit 608-266-9267
U.S. Environmental Protection Agency Fax: 608-267-2800
77 West Jackson Boulevard (WQW-16J)
Chicago, IL 60604 Stephen Johnson
312-886-0215 U.S. Environmental Protection Agency
Fax: 312-886-7804 77 West Jackson Boulevard (5SP-14J)
Chicago, IL 60604
Patricia Van Hoof 312-886-1330
Great Lakes Environmental Fax: 312-886-1515
Research Laboratory
National Oceanic & Marsha Jones
Atmospheric Administration Wisconsin Department of Natural Resources
2205 Commonwealth Boulevard 2300 North Martin Luther King, Jr. Drive
Ann Arbor, MI 48105 P.O. Box 12436
313-668-2286 Milwaukee, WI 53212
Fax: 313-668-2055 414-263-8708
Fax: 414-263-8483
Paul Horvatin
U.S. Environmental Protection Agency George Kannapel
77 West Jackson Boulevard (GLNPO) Floyd Brown Associates, Inc.
Chicago, IL 60604 181 South Main Street
312-353-3612 Marion, OH 43302
614-383-2187
Donald Hughes Fax: 614-382-1420
Atlantic States Legal Foundation
658 West Onondaga Street Phil Kaplan
Syracuse, NY 13204 Wisconsin Department of Natural Resources
315-475-1170 101 South Webster Street - P.O. Box 7921
Fax: 315-475-6719 Madison, WI 53707-7921
608-266-5486
Fax: 608-267-2800

-199-

Ali Khau Brett Lemon
Air Quality Control Maecorp
3903 Indianapolis Boulevard 155 North Wacker Drive - Suite 400
East Chicago, IN 46312 Chicago, IL 60606
219-391-8237 312-372-3300
Fax: 312-239-4050
Ken Klewin
U.S. Environmental Protection Agency Elizabeth Lewis
77 West Jackson Boulevard (W-15J) Baker & McKenzie
Chicago, IL 60604 130 East Randolph Drive - Suite 3200
312-886-4679 Chicago, IL 60601
Fax: 312-886-0957 312-861-2868
Fax: 312-861-2899
Robert Kozlowski
833 Buena - # 1008 Lauira Loverde
Chicago, IL 60613 Amoco Chemical Company
312-477-4364 200 East Randolph Street (MC-4803)
Chicago, IL 60601
Frank Kuwik 312-856-4984
Ecology & Environment, Inc. Fax: 312-616-0277
111 West Jackson Boulevard - Suite 1200
Chicago, IL Ton 'y MacDonald
312-663-9415 American Association of Port Authorities
1010 Duke Street
Joan Kwilosz Alexandria, VA 22314
Black & Veatch Waste Science 703-684-5700
& Technology Corporation Fax: 703-684-6321
101 North Wacker Drive - Suite 1100
Chicago, IL 60606 Midhael Mangahas
312-683-7841 Baker Environmental, Inc.
Fax: 312-346-4781 701 East 83rd Avenue
Merrillville, IN 46410
Olive Lee 219-736-0263
Vinson & Elkins L.L.P. Fax: 219-755-0233
1455 Pennsylvania Avenue, NW
Washington, DC 20008 Charles Maurice
202-639-6586 Ecology & Environment, Inc.
Fax: 202-639-6614 111 West Jackson Boulevard
Chicago, IL 60604
G. Fred Lee 312-663-9415
President Fax, 312-663-0791
G. Fred Lee & Associates
27298 East El Macero Drive Dartiel Mazur
El Macero, CA 95618 Great Lakes National Program Office
916-753-9630 U.S. Environmental Protection Agency
Fax: 916-753-9956 77 West Jackson Boulevard
Chicago, IL 60604
312--353-7997

-200-

Dennis McCauley David Pott
Battelle Great Lakes Environmental Center Harza Engineering Company
739 Hastings Sears Tower
Traverse City, MI 49684 233 South Wacker Drive
616-941-2230 Chicago, IL 60606-6392
Fax: 616-941-2240 312-831-3000
Fax: 312-831-3999
Kelly Moore
U.S. Environmental Protection Agency William Priore
77 West Jackson Boulevard Floyd Brown Associates, Inc.
Chicago, IL 60604 181 South Main Street
312-353-1869 Marion, OH 43302
614-383-2187
William Muellenhoff Fax: 614-382-1420
Battelle
397 Washington Street Belinda Rabano
Duxbury, MA 02332 Inside EPA's Environmental Policy Alert
617-934-0571 1225 Jefferson Davis Highway
Fax: 617-934-2124 Arlington, VA 22202
703-892-8518
Ayman Oubari Fax: 703-685-2606
Division of Engineering
Washington State Department of Randall Ransom
Natural Resources Dow Corning Corporation
P.O. Box 47030 3901 South Saganaw Road
Olympia, WA 98504 Midland, MI 48686-0995
206-664-9108 517-496-5644
Fax: 206-586-5456 Fax: 517-496-5941

Steve Peterson Joseph Rathbun
Ecology and Environment, Inc. AScI Corporation
368 Pleasantview Drive c/o U.S. Environmental Protection Agency
Lancaster, NY 14086 9311 Greh Road (LLRS)
716-684-8060 Grosse Ile, MI 48138
Fax: 716-684-0844 313-692-7634
Fax: 313-692-7603
Dave Petrovski
RCRA Section Mark Reshkin
U.S. Environmental Protection Agency Indiana University Northwest
77 West Jackson Boulevard (HRP-8J) 3400 Broadway
Chicago, IL 60604 Gary, IN 46408
312-886-0994 219-980-6966
Fax: 219-980-6890

-201-

Mike Rexrode Russell Short
Fisheries Biologist Ecology and Environment, Inc.
Office of Pesticide Programs 368 Pleasantview Drive
Ecological Effects Branch Lancaster, NY 14086
U.S. Environmental Protection Agency 716-684-8060
401 M Street, SW Fax: 716-684-0844
Washington, DC 20460
703-305-5578 Rob Sulski
Fax: 703-305-6309 Illinois Environmental Protection Agency
1701. South First Avenue - Suite 600
Alan Roberson Ma)wood, IL 60153
American Water Works Association 708-531-5900
1401 New York Avenue, NW - #604 Fax: 708-531-5930
Washington, DC 20005
202-628-8303 Karen Thomas
Fax: 202-628-2846 Uni@versity of Michigan Medical Center
300 North Ingalls - Room N14D22
Loreen Robinson Ann Arbor, MI 48107
Amoco Corporation 313-763-5588
200 East Randolph Drive (MC-4808) Fax: 313-747-2104
Chicago, IL 60601
312-856-6053 Sha:ron Thoms
Fax: 312-616-0152 Tetra Tech, Inc.
10306 Eaton Place - Suite 340
Dana Rzeznik Fairfax, VA 22030
U.S. Environmental Protection Agency 703-385-6000
77 West Jackson Boulevard Fax:: 703-385-6007
Chicago, IL 60604
312-353-6492 Williarn Tong
U.S. Environmental Protection Agency
Richard Schwer 77 West Jackson Boulevard (WCC-1SJ)
DuPont & Company Chicago, IL 60604
DuPont Company Engineering (L-3358) 312--886-9380
P.O. Box 6080 Fax: 312-886-0168
Newark, DE 19714-6090
302-366-4257 Marc Tuchman
Fax: @02-366-4123 U.S. Environmental Protection Agency
77 West Jackson Boulevard ('VIQ-16J)
Burt Shephard Chicago, IL 60604
Harza Engineering Company 312-886-0239
Sears Tower Fax: 312-886-7804
233 South Wacker Drive
Chicago, IL 60606-6392 Michael Unger
312-831-3042 Inland Steel Company
Fax: 312-831-3999 6514 Forest Avenue (MC-8-130)
Hammond, IN 46324
219-399-1702

-202-

Charles Vaughn Julia Wozniak
Dow Chemical Company Commonwealth Edison Company
1261 Building P.O. Box 767
Midland, MI 48667 Chicago, IL 60690
517-636-4336 312-294-4468
Fax: 517-638-7142 Fax: 312-294-4466

Anthony Wagner Caner Zanbak
Chemical Manufacturers Association Woodward Clyde Consultants
2501 M Street, NW 122 Sough Michigan Avenue - Suite 1920
Washington, DC 20037 Chicago, IL 60603
202-887-1174 312-939-1000
Fax: 202-887-1237 Fax: 312-939-4198

Will Wawrzyn Howard Zar
Wisconsin Department of Natural Resources Environmental Scientist
2300 North Martin Luther King, Jr. Drive U.S. Environmental Protection Agency
P.O. Box 12436 77 West Jackson Boulevard (W-16J)
Milwaukee, WI 53212 Chicago, IL 60604
414-263-8699 312-886-1491
Fax: 414-263-8483 Fax: 312-886-0957

Raymond Whittemore Barry Zuerclier
National Council for Air & Pope & Talbot
Stream Improvement 1200 Forest Street
Anderson Hall P.O. Box 330
Tufts University Eau Claire, WI 54701
Medford, MA 02155 715-834-3461
617-627-3254 Fax: 715-834-7646
Fax: 617-627-3831

Matthew Williams
Water Division
U.S. Environmental Protection Agency
77 West Jackson Boulevard (5W-15J)
Chicago, IL 60657
312-353-4934
Fax: 312-886-0957

Holiday Wirick
U.S. Environmental Protection Agency
77 West Jackson Boulevard (5MP-19J)
Chicago, IL 60606
312-353-6704
Fax: 312-353-413

-203-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPAIS CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

BUILDING ALLIANCE',;; AMONG FEDERAL, STATE, AND
LOCAL AGENCIES TO ADDRESS THE NATIONAL PROBLEM
OF CONTAMINATED SEDIMENTS
Uj Holiday Inn Capitol
Washington, DC
May 27-28, 1992

ATTENDEE LIST

Beverly Baker
Kay Anderson Office of Water
American Bottoms Regional Wastewater U.S. Environmental Protection Agency
Treatment Facility 401 M Street, SW (VVH-585)
1 American Bottoms Road Washington, DC 20460
Sauget, IL 62201 202-260-7037
618-337-1710
Fax: 618-337-8919 linda. Blankenship
Manager of Regulatory Affairs
Marianne Anderson Water Environment Federation
Kirkland & Ellis 601 Wythe Street
655 Fifteenth Street, NW Arlington, VA
Washington, DC 20005 703-684-2423
202-879-5918 Fax: 703-684-2492
Fax: 202-879-5200
Lani Boldt
Tom Armitage Division of Environmental Technology
Office of Water U.S. Bureau of Mines
U.S. Environmental Protection Agency 811) Seventh Street, NW (6205)
401 M Street, SW (VvrH-585) Washington, DC 20241
Washington, DC 20460 202-501-9273
202-260-5388 Fax: 202-501-9957

Rodger Baird Suzanne Bolton
Los Angeles County Sanitation Districts Ocean & Coastal Services
1965 South Workman Mill Road National Oceanic
Whittier, CA 90601 & Atmospheric Administration
213-699-0405 1825 Connecticut Avenue, NW (IA-22)
Fax: 213-699-3368 Washington, DC 20235
202-606-4436
Fax: 202-606-4057

-204-

Marilyn ten Brink Jeff Cherry
Geochemist Associate
Atlantic Marine Geology Branch Vinson & Elkins, L.L.P.
U.S. Geological Survey 1455 Permsylvaina Avenue, NW
Quissett Campus Washington, DC 20004-1000
Woods Hole, MA 202-639-6500
508-457-2392 Fax: 202-639-6604
Fax: 508-457-2310
David Christian
Mary Brockmiller ARINC Research Corporation
Amoco Corporation 2121 Crystal Drive - Suite 101
200 East Randolph Drive (1103) Arlington, VA 22202
Chicago, IL 60601 703-685-6109
312-856-5879 Fax: 703-685-6101
Fax: 312-616-0529
David Clarke
Wade Bryant Inside EPA Weekly Report
Ecologist/Biologist 1225 Jefferson Davis Highway - Suite 1400
U.S. Fish and Wildlife Service Arlington, VA 22202
4401 North Fairfax Drive - Room 330 703-892-1012
Arlington, VA 22203 Fax: 703-685-2606
703-358-2148
Fax: 703-358-1800 Rhea Cohen
Environmental Protection Specialist
John Butler Office of Federal Activities
Midwest Research Institute U.S. Environmental Protection Agency
51009 Leesburg Pike - Suite 414 401 M Street, SW (A-104)
Falls Church, VA 22041 Washington, DC 20460
703-671-0400 202-260-8465
Fax: 703-820-6224 Fax: 202-260-0129

Robert Byrne John Distin
Wildlife Management Institute Squire, Sanders & Dempsey
1101 14th Street, NW - Suite 725 1800 Huntington Building
Washington, DC 20005 Cleveland, OH 44115
202-371-1808 216-687-8530
Fax: 202-408-5059 Fax: 216-687-8793

Raheem Cash Philip Dom
Amoco Corporation Shell Development Company
200 East Randolph Drive (4808) P.O. Box 1380
Chicago, IL 60601 Houston, TX 77251-1380
312-856-5105 713-493-7855
Fax: 31.2-616-0152 Fax: 713-493-8727

-205-

David Eaton Laura Gabanski
Hercules, Inc. Aquatic Biologist
Hercules Plaza Science Policy Branch
Wilmington, DE 19894 Office of Policy Planning and Evaluation
302-594-7814 U.S. Environmental Protection Agency
Fax: 302-594-7097 401 M Street, SW (PM-223X)
Washington, DC 20460
Richard Eskin 202-' 260-5868
Maryland Department of the Environment Fax: 202-260-9757
2500 Broening Highway
Baltimore, MD 21224 William Gala
410-631-3699 Chevron Research & Technology Company
Fax: 410-631-3873 1003 West Cutting Boulevard
Richmond, CA 94804-0054
Kevin Fast 510-242-4361
Hunton & Williams Fax: 510-242-1380
2000 Pennsylvania Avenue, NW
Washington, DC 20006 Robin Garibay
202-955-1519 The Advent Group, Inc.
Fax: 202-778-2201 1925 North Lynn Street - 702
Rosslyn, VA 22209
Ellen Fisher 703-522-9662
Wisconsin Department of Transportation Fax: 703-522-2416
P.O. Box 7914
Madison, WI 53707-7914 Jeanette Glover Glew
608-267-9319 Food & Drug Administration
Fax: 608-267-6748 200 C Street, SW (HFF-304)
Was1iington, DC 20204
Bob Foley 202-254-9597
U.S. Fish & Wildlife Service Fax: 202-254-3986
1825 Virginia Street
Annapolis, MD 21401 Mark Graham
410-269-5448 Arlington County
Fax: 410-269-0832 2100 Clarendon Boulevard - Room 807
Arlington, VA 22201
Jeffrey Frithsen 703-358-3613
Senior Scientist Fax: 703-358-3606
Versar, Inc.
7200 Rumsey Road Alison Greene
Columbia, MD 21045 Office of Water
410-964-9200 U.S. Environmental Protection Agency
Fax: 410964-5156 401 M Street, SW (WH-585)
Washington, DC 20460
202-' 260-7053

-206-

Lloyd Guerci Rick Hoffman
Mayer, Brown & Platt Office of Water
2000 Pennsylvania Avenue, NW U.S. Environmental Protection Agency
Washington, DC 20006 401 M Street, SW (WH-585)
202-778-0637 Washington, DC 20460
Fax: 202-861-0473
Carlton Hunt
Pamela Guffain Battelle Ocean Sciences
The Fertilizer Institute 397 Washington Street
501 Second Street, NE Duxbury, MA 02332
Washington, DC 20002 617-934-0571
202-675-8250 Fax: 617-934-2124
Fax: 202-544-8123
Ann Hurley
John Haggard National Association of Attorneys General
General Electric Company 444 North Capitol Street - Suite 339
One Computer Drive, S Washington, DC 20001
Albany, NY 12205 202-434-8039
518-458-6619 Fax: 202-434-8008
Fax: 518-458-9247
Hamid Karimi
Paul Hauge Water Resources Management Division
Division of Science & Research District of Columbia Environmental
New Jersey Department of Environmental Regulation Administration
Protection & Energy 2100 Martin Luther King Avenue, SE
401 East State Street (CN-409) Suite 200
Trenton, NJ 08625 Washington, DC 20020
609-633-7475 202-404-1120
Fax: 609-292-7340 Fax: 202-404-1141

Pat Hill Tim Kasten
American Paper Institute Office of Water
1250 Connecticut Avenue, NW - Suite 210 U.S. Environmental Protection Agency
Washington, DC 20036 401 M Street, SW (WH-585)
202-463-2420 Washington, DC 20460
Fax: 202-463-2423 202-260-5994

Helen Hillman Jeff Keiser
Program Analyst C112M Hill
U.S. Department of Commerce/NOAA 310 West Wisconsin Avenue - Suite 700
c/o Commandant, USCG; Milwaukee, WI 53201
2100 2nd Street, SW 414-272-1052
Washington, DC 20593
202-267-0422 Steven Kilpatrick
Fax: 202-267-4825 The Dow Chemical Company
2050 Dow Center
Midland, 1@1[ 48674
517-636-8287
Fax: 517-638-9933

-207-

Eleanor Kinney Tony MacDonald
Coast Alliance American Association of Port Authorities
235 Pennsylvania Avenue, SE 1010 Duke Street
Washington, DC 20003 Alexandria, VA 22314
202-546-9554 703-684-570,0
Fax: 703-684-6321
James Knight
Associate Scientist Charlie MacPherson
Chem Risk Tetra Tech, Inc.
Stroudwater Crossing 10306 Eaton Place - Suite 340
1685 Congress Street Fairfax, VA 22030
Portland, ME 04102 703-385-6000
207-774-0012 Fax: 703-385-6007
Fax: 207-774-8263
Ralph Markarian
Robert Kohnke Entrix, Inc.
Northern Virginia Soil 200 Bellevue Parkway - Suite 200
& Water Conservation District Wilmington, DE 19809
8705 Parliament Drive 302-792-93,10
Springfield, VA 22151 Fax: 302-792-9329
703-591-6660
Beth McGee
Mike Kravitz Ecological Assessment Division
Office of Water Maryland Department of the Environment
U.S. Environmental Protection Agency 2500 Broening Highway
401 M Street, SW Baltimore, MD 21224
Washington, DC 20460 410-631-3782
202-260-8085 Fax: 410-631-4105

Olive Lee Donald McCaig
Vinson & Elkins L.L.P. Eastern Regional Sales Manager
1455 Pennsylvania Avenue, NW Mud Cat
Washington, DC 20004 1611 Bush Street
202-639-6586 Baltimore, MD 21230
Fax: 202-639-6614 410-837-7900

Nancy Iin Bill McFarland
Mobil Oil Corporation Manager Superfund Activities
P.O. Box 1031 General Motors
Princeton, NJ 08543 30400 Mound Road
609-737-5223 Warren, MI 48090-9015
Fax: 609-737-4197 313-947-1870
Fax: 313-947-1422
Tobin Lounsbury
DuPont Environmental Remediation
300 Bellevue Parkway - Suite 390
Wilmington, DE 19809
302-792-8996
Fax: 302-792-8995

-208-

Thomas McKinney Dan Olson
Washington Government Services Environmental Scientist
Dames & Moore U.S. Fish and Wildlife Service
7101 Wisconsin Avenue - Suite 700 4401 North Fairfax Drive - Room 330
Bethesda, MD 20814-4870 Arlington, VA 22203
301-652-2215 703-358-2148
Fax: 301-652-4122 Fax: 703-358-1800

Ossi Meyn Alan Parsons
Environmental Scientist Cambridge Environmental, Inc.
OPFT 58 Charles Street
U.S. Environmental Protection Agency Cambridge, MA 02141
401 M Street, SW 617-225-0810
Washington, DC 20460 Fax: 617-225-0813
202-260-1264
Fax: 202-260-1283 Ralph Pearce
Environmental Engineer
Barbara Mohler Ruetgers-Nease Chemical Company, Inc.
ARINC Research Corporation 201 Struble Road
2121 Crystal Drive - Suite 101 State College, PA 16801
Arlington, VA 22202 814-238-2424
703-685-6128 Fax: 814-238-1567
Fax: 703-685-6101
Richard Peddicord
Deirdre Murphy EA Enizineerine Science & Technology, Inc.
Maryland Department of the Environment 15 Lov@ton Circle
2500 Broening Highway Sparks, MD 21152
Baltimore, ItM 21224 410-771-4950
410-631-3609 Fax: 410-771-4204

Tony Neville Sam Petrocelli
Labat-Anderson, Inc. Dynamac
2200 Clarendon Boulevard - Suite 900 2275 Research Boulevard
Arlington, VA 22201 Rockville, MD 20850
703-525-9400 301-417-6038
Fax: 703-525-7975 Fax: 301-417-6075

Maynard Nichols Harriette Phelps
Virginia Institute of Marine Science Biology Department
Gloucester Point, VA 23062 University of the District of Columbia
804-642-7269 4200 Connecticut Avenue, NW
Fax: 804-642-7250 Washington, DC 20008
202-282-7364
Bridget. O'Grady Fax: 301-345-6017
National Water Resources Association
3800 North Fairfax Drive - Suite 4
Arlington, VA 22203
703-524-1544
Fax: 703-524-1548

-209-

Fred Pinkney Thomas Reed
Versar, Inc. Project Manager
9200 Rumsey Road Maryland Environmental Service
Columbia, MD 21045 912 Commerce Road
410-964-9200 Annapolis, I@M 21401
Fax: 410-964-5156 410-974-7261
Fax: 4.10-974-7236
Jay Pitkin
Department of Environmental Quality Diane Reid
Utah Division of Water Quality North Carolina Division of
288 North 1460 West - P.O. Box 144870 Environmental Management
Salt Lake City, UT 84114-4870 P.O. Box 29535
801-538-6146 Raleig]h, NC 27626
919-73.3-5083
David Pott Fax: 9,19-733-9919
Harza Engineering Company
Sears Tower Duane Roskoskey
Chicago, IL 60606 Environmental Quality Analyst
312-831-3000 Waste Management Division
Fax: 312-831-3999 Michigan Department of Natural Resources
John A. Hannah Building
Myron Price P.O. Box 30241
Regulatory Analyst Lansing, 1@ff 48909
American Petroleum Institute 517-315-4712
1220 L Street, NW
Washington, DC Williani Rue
202-682-8478 Manager Conceptual Biomonitoring
Fax: 202-682-8031 EA Engineering, Science and Technology
15 Loveton Circle
Belinda Rabano Sparks,, MD 21152
Associate Editor 301-771-4950
Environmental Policy Alert Fax: 301-771-9148
1225 Jefferson Davis Highway - Suite 1400
Arlington, VA 22202 Gerald Saalfeld
703-892-8516 Michigan Department of Natural Resources
Fax: 703-685-2606 P.O. Box 30028 (SWQB)
Lansin,g MI 48909
Randel Ranson 517-335-4201
Dow Corning Corporation Fax: 517-373-9958
3901 South Saginaw Road
Midland, MI 48686-0995 John @-acco
517-496-5644 Bureau. of Environmental Evaluation
Fax: 517-496-5941 & Risk Assessment
New Jersey Department of Environmental
Protection & Energy
401 East State Street (CN-413)
Trenton, NJ 08625
609-984-3068
Fax: 609-633-2360

-210-

Chris Schlekat Jack Sullivan
Ecological Assessment Division Deputy Executive Director
Maryland Department of the Environment AWWA
2500 Broening Highway 1401 New York Avenue, NW - Suite 640
Baltimore, MD 21224 Washington, DC 20005
410-631-3785 202-628-8303
Fax: 410-631-4105 Fax: 202-628-2846

Richard Schwer Sharon Thorns
DuPont Company Tetra Tech, Inc.
DuPont Company Engineering 10306 Eaton Place - Suite 340
P.O. Box 6080 (L-3358) Fairfax, VA 22030
Newark, DE 19714-6090 703-385-6000
302-366-4257 Fax: 703-385-6007
Fax: 302-366-4123
Boyce Thorne-Miller
Mohsin Siddique Friends of the Earth
Water Quality Control Branch 218 D Street, SE
District of Columbia Environmental Washington, DC 20003
Regulation Administration 202-543-4448
2100 Martin Luther King Avenue, SE
Suite 203 David Velinsky
Washington, DC 20020 Interstate Commission on
202-404-1120 the Potomac River Basin
Fax: 202-404-1141 6110 Executive Boulevard - Suite 300
Rockville, MD 20852
Katie Simmel 301-984-1908
Reporter Fax: 301-984-5841
Bureau of National Affairs
1231 25th Street, NW - Suite 370 Anthony Wagner
Washington, DC 20036 Chemical Manufacturers Association
202-452-4637 2501 M Street, NW
Fax: 202-452-4150 Washington, DC 20037
202-887-1174
Susan Smillie Fax: 202-887-1237
Senior Analyst
LABAT-ANDERSON, Inc. Beverly Whitehead
2200 Clarendon Boulevard - Suite 900 U.S. Department of Energy
Arlington, VA 22201 1000 Independence Avenue, SW
703-525-5300 Room GA-076 (EH-231)
Fax: 703-525-7975 Washington, DC 20585
202-586-6073
Alexis Steen Fax: 202-586-3915
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
202-682-8339
Fax: 202-682-8270

-211-

Raymond Whittemore
National Council for Air
& Stream Improvement
Tufts University
Anderson Hall
Medford, MA 02155
617-627-3254
Fax: 617-627-3831

Robert Youngman
Paralegal
Garvey Schubert & Barer
1000 Potomac Street, NW - Suite 5
Washington, DC 20007
202-965-7880
Fax: 202-965-1729

-212-

U.S. Environmental Protection Agency

PUBLIC FORUM ON EPA'S CONTAMINATED SEDIMENTS
MANAGEMENT STRATEGY

OUTREACH AND PUBLIC AWARENESS

Holiday Inn Capitol
Uj Washington, DC
C N June 16, 1992
rA0 ATTENDEE LIST
Kathy Bayne Tom Bonenberger
American Mining Congress Amomco Corporation
1920 N Street, NW - #300 1615 M Street, NW
Washington, DC 20036 Washington, DC 20036-3260
202-861-2852 202-857-5346
Fax: 202-861-7535 Fax: 202-857-5349

Jeremy Berstein Robert Byrne
Environmental Policy Alert Wildlife Management Institute
1225 Jefferson Davis Highway 1101 14th Street, NW - Suite 725
Arlington, VA 22202 Washington, DC 20005
703-892-8518 202-371-1808
Fax: 703-685-2606 Fax: 202-408-5059

Linda Blankenship Miriam Cairns
Water Environment Federation Dames & Moore, Inc.
601 Wythe Street 7101 Wisconsin Avenue - Suite 700
Alexandria ' Va 22314-1994 Bethesda, MD 20814
703-60.4-2423 301-652-2215
Fax: 703-684-2492 Fax: 301-656-8059

Suzanne Bolton Phillippa Cannon
Chief, CqmTunity Affairs Public Affairs Specialist
Ocean & Coastal Services U.S. Environmental Protection Agency
National Oceanic Atmospheric 77 West Jackson Road (PI-19J)
Administration Chicago, IL 60604
1825 Connecticut Avenue, NW (I-A-22) 312-353-6128
Washington, DC 20235 Fax: 312-353-1155
202-606-4436
Fax: 202-606-4057

-213-

Jeff Cherry Helen Hillman
Vinson & Elkins L.L.P. National Oceanic and
1455 Pennsylvania Avenue, NW Atmospheric Administration
Washington, DC 20004 c/o Cbmmondant
202-639-6586 United State Coast Guard
Fax: 202-639-6614 2100 Second Street SW
Washington, DC 20593
Jacquelyn Clarkson 202-267-0422
James M. Montgomery Consulting Engineers Fax: 202-267-4865
63501 North Caseway - Suite 300
Metaire, LA 70005 Tim Kasten
504-835-4252 Office Of Water (A111-585)
Fax: 504-835-8059 U.S. Environmental Protection Agency
401 M Street, SW
Sean Culey Washington, DC 20460
The Advent Group, Inc. 202-260-5994
1925 North Lynn Street - Suite 702 Fax: 202-260-9830
Rosslyn, VA 22209
703-522-9662 Karl Kieninger
Fax: 703-522-2416 Atlas Elektronik of America
1075 Central Avenue
Normand Goulet Clark, New Jersey 07066
Northern Virginia Planning 908-3,88-1500
District Commission Fax: 908-388-5781
7535 Little River Turnpike
Annadale, VA 22030 Jim ]Kright
703-591-0700 ChemRisk
Fax: 703-642-5077 Stroudwater Crossing
1683 Congress Street
Mark Graham Portland, ME 04102
Arlington County 207-774-0012
2100 Clarendon Boulevard - Room 801 Fax: 207-774-8263
Arlington, VA 22201
703-358-3613 Donna Lawson
Fax: 703-358-3606 Damage Assesment Center
National Oceaninc &
Brad Jennings Atmospheric Administration
Great Lakes Assistant 6001 Executive Boulevard - Room 425
Sierra Club Rockville, MD 20852
408 C Street, NE 301443-8865
Washington, DC 20002 Fax: 301-231-7488
202-675-2383
Fax: 202-547-6009 Nancy Lin
Mobil Oil Corporation
P.O. Box 1031
Princeton, NJ 08543
609-737-5223
Fax: 609-737-4197

-214-

Deirdre Murphy Beverly Whitehead
Maryland Deparment of the Environment Environmental Protection Specialist
2500 Broening Highway Department of Energy
Baltimore, MD 21224 1000 Independence Avenue, SW
410-631-3609 Room GA-076 (EH-231)
Washington, DC 20585
Myram Price 202-586-6073
American Petroleum Institute Fax: 202-586-3915
1220 C Street, NW
Washington, DC 20005 Raymond Whittemore
202-682-8478 National Council for Air
Fax: 202-682-8031 Stream Improvement
Anderson Hall - Tufts University
Loreen Robinson Medford, MA 02155
Regulatory Affairs 617-627-3254
Arnoco Corporation Fax: 617-627-3831
700 East Randolph (4808)
Chicago, IL 60601
312-856-6053
Fax: 312-616-0152

Katie Stimmel
Bureau of National Affairs
Daily Environment Report
1231 25th Street, NW
Washington, DC 20037
202-452-4637
Fax: 202-452-4150

Sam Sury
Director, Environmental Protection
Ciba-Geigy Corporation
444 Saw Mill River Road
Ardsley, NY 10502
914-479-2673
Pax: 914-479-2332

Nicole Veilleux
Office of Water
Office of Wetlands,
Oceans, & Watersheds
Oceans & Costal Protection Division
401 M Street, SW (VvH-556F)
Washington, DC 20460
202-260-1981
Fax: 202-260-6294

-215-

SPECIAL FOURTH-CLASS RATE
BOOK
Official Business POSTAGE & FEES PAID
Penalty for Private Use EPA
MWI
NVEPA $300 PERMIT NO.G-35
_/ 4t, '

United Washington DC 20460
Envirr
Agef

CY)

Burgess
tal Programs Division
00
dce of Ocean &Coastal CD
Resource Management/CPD CO
National Oceanic
& Atmospheric Administration
825 Connecticut Avenue, NW - Room 724
Washington, DC 20235

EPA Form 5180-13 (5-79)