[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






                                     property of Csc I.Lbr&3:Y


                                    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





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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


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                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

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                (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

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              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.




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                       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.



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                       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

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             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.












































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










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










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










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                                   Estuary
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                                 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

                                                              40

                                                            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


                                                                                      80


                                                                                       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


                                                                         80


                                                                         60


                                                                         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


                                                                             80


                                                                             60

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



                                   0        10 XM

                                   C4010urs im Motors






                                                            jS

                             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

                                                                                                                                           90


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

                                        100              1044 samples                                    +                                 50

                                                                                                                                           40


                                                                                                                                           30
                                                50
                                                                                                                                           20


                                                                                                                                           10

                                                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,_


                                          0.

                                    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



                                       20



                                       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-












                                                                      0



                                                          .....                 . .....



                                                                                                                     85'
                                        Menominee
                                                                                                                        45'







                                                                                       Frankfort


                              Green Bay


                                 lei
                               0+                                                            0   10    20   30 rni

                                                                                               1. 20 311 401m























                               Mil.a.kee                                      :X-.

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


                                                                                                   piver


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

                                     N



                                                                                    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

                                                      z



                   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,


                                                                                W:






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










                    CL






                                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



                                                                             0


                                                                                                       ... ... ....

                                                                                                                                 ...........
                                                                                                      ..............             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-







                                3

                             28

                             53


                             78

                         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





                                                        z




                                                            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

                                                W

                                                     '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-



                               70



                               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-

                         z


                         C3
                         C)






                         Cr

                         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

                                               18

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

                                                                                           s:v'

                                                                                                 g
                                                   6

                                                                                          Q.,
                                                                                                 R,
                                                   4

                                                   2

                                                   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).


                                                                                                 H

                                                                   4        0


                                                                 Co2                                  M
                                                                 U
                                                                 CL

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



                                                                                                           Michigan

                                                    12-





                                                    10-
                                                   0
                                                   2
                                                   I--




                                                                          22















                                                                      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

                         Co

                         0.


                            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


                                                  2-

                                                                   7.3     106




                                                      1965               1970                1975                 1980               1985
                                                                                      YEAR







                                                                                                                      9



                                                                                                                    -8


                                                                                                                        c


                                                    c
                                                    12
                                                                                                                      9 Z:
                                                                                                                       c
                                                                                                                       a





                                                                                                                      4

                                                    .j

                                                      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-





                          80





                          70-





                          60
                     (n



                     0    50-


                     0


                     z
                     LU
                     U    40-




                          30



                                                                      LP
                          20





                          10





                            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):

                    ï¿½        Pollution comprises contamination resulting in exposures that cause effects.

                    ï¿½        Determining the presence and significance of pollution is not always easy.

                    ï¿½        Targets and measures of the five individual assessment components were discussed
                             (see Table 2-7).

                    ï¿½        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).

                                                       N





                              LAKE ERIE


                                                       S














                              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 -



                                             20




                                              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).






                                                                   -66-












                                                          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





































                                                                -67-









                                                 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


































                                                     -68-










                                               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]

































                                                    -69-










                                                    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




































                                                      -70-














                                                            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




















                                                                 -71-












                                                                 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

























                                                                   -72-








                      ï¿½       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.

                      ï¿½       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.

                      ï¿½       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.




                                                               -73-












                             INTESTINE r 2  0.699
                     0.15-




                     0.15-



                E    0.15-

                E

                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

                           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).







                                                    -74-







                       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



                                                              -75-







               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



                                                               -76-







               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.



                                                               -77-







                       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.








                                                                  -78-








                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.



                                                          -79-








             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




                                                                -81-









                 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


                                                                     -82-










              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.





                                                               -83-









                         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.



                                                                 -84-










              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.



                                                               -85-









                         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



                                                                     -86-









               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.



                                                                 -87-









               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


                                                                -88-









                              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

                      ï¿½       EPA should clearly define what contaminated sediments are, prior to release of the
                              Strategy.

                      ï¿½       The Strategy should focus more attention on the problem of nonpoint source
                              contamination.


                      ï¿½       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

                      ï¿½       EPA should identify and promulgate consistent QA/QC protocols for sediment
                              sampling and bioeffects testing as part of the Strategy.

                      ï¿½       Panelists were divided on the issue of a whole sediment testing approach versus a
                              numerical chemical criteria assessment approach.

                      ï¿½       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.


                                                                 -89-










                         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


                                                                  _90-










             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.



                                                                   -93-










                        ï¿½       Field evaluations of no-tiflage and post-emergent herbicides which could reduce
                                runoff of agricultural chemicals.

                        ï¿½       Development of methods for evaluating sources and extent of ecosystem
                                contamination.


                        ï¿½       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:




                                                             -95-









                               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



                                                               -96-









              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.


                                                              -97-









                        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"



                                                                  -98-










              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.







                                                              -99-









                         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



                                                                   _100-










              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


                                                              _101-










                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.



                                                               -102-









                      ï¿½      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.

                      ï¿½      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.


                      ï¿½      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.

                      ï¿½      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,


                                                             -103-









               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.


                                                               -104-









              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.


                                                              -105-









                         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.


                                                                 -106-










                        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


                        ï¿½        EPA fully intends to use all existing data on sediment contamination in developing
                                 the national inventory of contaminated sediment sites and sources.

                        ï¿½        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



                                                                   -107-










                                 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.




























                                                                   -108-











                                                     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



                                                               -110-










             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



                                                               -112-













                        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.


                                                               -114-





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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


                                                              -117-










                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


                                                            -120-










              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


                                                              -121-










                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.








                                                               -122-










                      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.



                                                              -123-










                        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.


                                                                -124-











                      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


                                                               -125-










                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



                                                               -126-









              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

                      ï¿½       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.

                      ï¿½       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.

                      ï¿½       EPA must work toward building consensus among all of its audiences.

                      ï¿½       EPA must demonstrate accountability by achieving interim goals and providing
                              information on the status of activities.


                      ï¿½       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


                                                              -127-









               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


                                                               -128-










              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.



                                                                -129-











                      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.












                                                              -130-



































                               APPENDIX A



           EPA'S CONTAMINATED SEDIMENT MANAGEMENT STRATEGY
                             DRAFT OUTLINE
































                                   -131-





                                                                                 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.



                                                   DRAFT





                                                    -132-








                                                    2

                  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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                                                    4

                  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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                                                     5

                                      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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                                                      7

                    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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                                                       8

                          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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                                                     9

                                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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                                                 10

                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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                                                         13

                                   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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                                                     14

                         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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                                                        15

                           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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                                                   16

                              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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                                                       17

                           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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                                                      18

                                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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                                                       19

                                 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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                                                        20

                                  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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                                                    21

                               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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                                                 22

                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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                                                       23

              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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                                                    24

                         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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                                                          25

                                   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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                                                   26

                              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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                                                      27

                                 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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                                                    28

            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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                                                   29


                  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.






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                                                   30

                        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.

















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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




                                                     -165-









                                  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



                             ï¿½    industrial effluent and emissions


                             ï¿½    Agricultural, industrial, and urban nonpoint source controls

                             ï¿½    Publicly owned treatment works

                             ï¿½    Combined sewer overflows


                             ï¿½    Stormwater


                             ï¿½    Runoff and leachate from hazardous waste disposal sites

                             ï¿½    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


                                                       -166-











                                 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.



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                            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



                                                         -170-










                         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






















                                                       -174-




































                              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





                                                       -176-













               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











                                                            -177-










               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





                                                            -178-










             11:10 AM            Open Discussion

             12:00 PM            Recommendations for the Sediment Steering Committee and Strategy -
                                        Summary of Forum

             12:30 PM            Adjourn




















































                                                     -179-










                                        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)