On July 26, 2002, the following members of the Remediation Technologies Development Forum's (RTDF's) Sediments Remediation Action Team, Sediment Decision Subgroup, met in a conference call:
Nancy Grosso, DuPont Corporate Remediation (Action Team Co-chair)
Dennis Timberlake, U.S. Environmental Protection Agency (EPA) (Action Team Co-chair)
Gary Hinshaw, Environmental Assurance Monitoring, LLC
Michael Kravitz, U.S. Environmental Protection Agency (EPA)
Mike Palermo, U.S. Army Corps of Engineers
Cornell Rosiu, EPA
Dick Schwer, DuPont Engineering
Bill Schew, Environmental Standards
Jennifer Sutter, Oregon Department of Environmental Quality
Brett Thomas, Chevron Texaco
John Wolfe, Limno-Tech, Inc.
Christine Hartnett of Eastern Research Group, Inc., (ERG) was also present.
A sediments management decision framework is being developed by a team of federal stakeholders (i.e., EPA, the Navy, the Army Corp of Engineers, and the National Oceanic and Atmospheric Administration). Mike Palermo, who is leading the team, participated in this conference call. He said that the framework will serve as a road map; it is not intended to duplicate existing guidance documents or to restate documents that have already been written. Instead, it is intended to lead users through the sediments assessment process. Reference will be made to more detailed guidance where applicable. Palermo said that the framework will be released as a joint agency document but that it will probably be published by EPA and posted on EPA's Web site. The Web-version, which will link directly to applicable guidance materials, will be a living document.
The sediments management decision framework will consist of two components: (1) a flow diagram, and (2) seven chapters of supporting text. A draft version of the flowchart has been completed. The seven chapters have not been written yet but an annotated outline has been created to show what concepts will be highlighted. This conference call was held to allow RTDF Sediment Subgroup members an opportunity to comment on the flowchart and annotated outline. They discussed the following:
The Contaminated Sediments Technical Advisory Group (CSTAG). CSTAG has been formed to provide advice on large and complex contaminated sediment sites. Nancy Grosso advised mentioning CSTAG and indicating how it fits into the sediment management decision framework.
Program coordination. Call participants noted that watersheds are subject to several different activities and programs. They recommended including a discussion on mechanisms that can be used to coordinate the programs. (One call participant noted that EPA is trying to develop a way to streamline and integrate programs.) Grosso also recommended discussing the importance of coordinating activities to ensure that cleanup activities are not pursued in areas downstream of ongoing contaminant sources.
Reliance on the Superfund Process. Grosso said that the framework's language and structure borrow heavily from the Superfund program. Call participants said the language should be altered to make the flowchart more applicable to contaminated sediment sites. Palermo asked for suggestions on how to do this. Suggestions should be directed to Palermo, Grosso, or Dennis Timberlake.
Iteration and the site characterization process. Call participants agreed that iteration is important; in many cases, they said, it is not wise to adhere to a linear site assessment approach. Instead, it is better to go back to earlier steps and collect additional information if this will assist stakeholders in making sound decisions. John Wolfe identified two steps in the framework's flowchart that do not currently support an iterative approach: (1) section 3.2 which indicates that iterative characterization should be minimal, and (2) section 3.6 which fails to list "additional characterization" as an option to consider after risk assessment is completed. Palermo agreed that the framework should be designed to promote a flexible and iterative approach to sediments management. Thus, the sections in question will be revisited and text will be modified to make it clear that it is unwise to make decisions in the absence of robust data sets. Palermo said that he does think it is important, however, to make it clear that the need for iteration can be lessened if site managers develop well-designed site characterization studies upfront. If given some forethought, he noted, it is even possible to design site characterization sampling plans to collect information that will prove useful during the remedial selection phase. (The latter idea is captured in Section 2.4 of the annotated outline, which suggests designing data collection plans with future remedial actions in mind.)
Discussion of assessment goals. Call participants said that the decision framework should address the following questions upfront: What do site stakeholders hope to achieve? Are the goals realistic? What benchmarks (e.g., background concentrations) should be used to screen a site? If stakeholders have a clear vision upfront, call participants noted, the entire assessment process will be tailored to collect the most relevant information. They recommended inserting goal-setting activities higher up in the framework's flowchart.
Multidisciplinary input. Grosso advised stating that multidisciplinary expertise is needed upfront to determine what type of physical, hydrogeological, or chemical data should be collected.
Examples. Call participants suggested presenting examples to help illustrate options that exist along different stages of the sediment management decision process.
Grosso agreed to consolidate all the comments she has received from Subgroup members and forward them to Palermo. This includes comments presented during the conference call and comments e-mailed to Grosso prior to the close of business on July, 26, 2002. Palermo will forward the comments to the people working on the framework's seven chapters. Palermo said that he expects to have a first draft of the framework's text by the end of August 2002. This will be circulated among the federal stakeholder team for comment. The text will be sent to a wider audience, including the Sediment Decision Subgroup, by the end of September 2002.