SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
SEDIMENTS REMEDIATION ACTION TEAM
FRAMEWORK REVIEW SUBGROUP CONFERENCE CALL

2:00 p.m.-4:00 p.m.
November 22, 2004

On November 22, 2004, the following members of the Remediation Technologies Development Forum's (RTDF's) Sediments Remediation Action Team, Framework Review Subgroup, met in a conference call:

Nancy Grosso, DuPont Corporate Remediation (Action Team Co-chair)
Lyle Bruce, BP
Dana Davoli, U.S. Environmental Protection Agency (EPA), Region 10
Katherine Fogarty, Menzie-Cura and Associates, Inc.
John George, Alcoa
Greg Peterson, Limno-Tech, Inc.
Lisa Saban, Windward Environmental
Jennifer Sutter, Oregon Department of Environmental Quality
Brett Thomas, Chevron Texaco

Anita White of Eastern Research Group, Inc., (ERG) was also present.

BACKGROUND INFORMATION

The purpose of this conference call was to give members of the Framework Review Subgroup an opportunity to provide comments on the latest iteration (distributed on November 5) of a document called The Framework for Evaluating and Managing Contaminated Sediment Sites. Nancy Grosso thanked those who provided comments on the previous iteration, noting that she had incorporated as many of their comments as she could. Some of the comments, however, had to be forwarded to the document's original authors for consideration. (The original authors consist of representatives from the following organizations: the U.S. Environmental Protection Agency [EPA], the Navy, the Army Corps of Engineers, and the National Oceanic and Atmospheric Administration [NOAA].)

DISCUSSION

Conference call participants provided comments on the following issues:

• Releasing this document as an EPA-endorsed product. Dana Davoli (from EPA Region 10) said that she does not think the document (as it currently appears) should be advertised as an EPA-endorsed product because it recommends some approaches for sediments management that do not jibe with the way EPA Region 10 does things in the field. At Grosso's request, Davoli agreed to send a list of the specific conflicts to EPA's Steve Ells (one of the document's original authors). Even if the conflicts are resolved, Davoli said, the document should probably still be distributed for broader EPA review if the intention is to release it as an EPA product. (She warned that the Agency's Office of General Council might want to review the document before it is distributed.)



• Modifying the section that discusses screening risk assessment. Davoli expressed concern about the document's recommendation to perform a preliminary screening risk, noting that if such an assessment is performed too early--before enough characterization data are collected--managers might unduly eliminate important chemicals of concern. Her comment prompted a broader discussion on screening values. Davoli said that screening levels do not exist for bioaccumulators. Jennifer Sutter agreed, and advised adding a sentence to the document stating that it will be impossible to rule out a site during a preliminary screening assessment if bioaccumulators have been detected in sediments. Lisa Saban advised adding a sentence describing some of the factors that one should consider (e.g., an analysis of detection limits and back-of-the-envelope food web models) when developing screening risk numbers for specific sites.



• Clarifying who is developing the list of bioaccumulators. Section 2.5.2 of the document indicates that EPA Region 10 has prepared a list of bioaccumulative contaminants of concern. Davoli said that the list is actually being developed by the Dredged Material Management Program (DMMP). Sutter agreed to send Grosso a reference for the DMMP.



• Placing more emphasis on data quality issues. Davoli advised placing greater emphasis on the importance of developing a sampling plan and collecting high-quality data early in the assessment process.



• Emphasizing the point that contamination typically extends beyond sediments at a "sediments site." Davoli advised making this point clear at the beginning of the document.



• Expanding the discussion on Net Environmental Benefits Analysis (NEBA). Grosso said that NOAA has advised deleting the discussion about NEBA. Several call participants disagreed with NOAA's stance, noting that the NEBA approach merits discussion because it is gaining popularity with some organizations. For example, Oak Ridge National Laboratory has written a guidance document for the NEBA approach and the Texas Commission on Environmental Quality (TCEQ) has incorporated it into its ecorisk guidelines. Call participants listed some scenarios in which a NEBA might lead to ecologically beneficial effects. For example, if a contaminated wetland is likely to be destroyed in the process of remediating it, Grosso said, it might make more sense to leave the contaminants in place and invest the money that would have spent on remediation on another wetland or habitat restoration project. Saban agreed to write up a paragraph on the NEBA approach and to send it to Grosso for consideration. References will be included in the writeup. Brett Thomas said that he would send Saban the name of someone at ChevronTexaco who might be able to provide references.



• Clarifying what types of risk reduction should be evaluated when performing a comparative analysis of technologies. John George said that the document discusses the importance of comparing the "risk reduction" potential of different technologies when trying to determine which technology is most appropriate to use at a site. When it comes to evaluating risk reduction, he said, two factors should be considered: (1) Will the technology effectively reduce the risks posed by site contaminants? and (2) What types of risk are associated with implementing the technology? Expanding on the latter, George noted that some remedial technologies carry risks of their own and can cause environmental harm. He advised making it clear that one should evaluate both types of "risk" when performing a comparative analysis of technologies. Grosso agreed. George advised adding the following language to section 4.3: "remedial alternatives are evaluated not only for the degree of direct risk reduction they might be able to achieve, but also with regard to the range of risks that might arise as a result of implementing the remedy." If such clarification were made in Section 4.3, he said, then the last sentence in the third paragraph of section 3.6 could be eliminated.



• Using the term "hazardous waste sites." Sutter said that this phrase is used in the first paragraph of Section 3.3.2. She advised changing it to "contaminated sites."



• Making it clear that EPA is required to assess current and future risks. Davoli said that there are a few places in the document where the authors failed to stress the importance of assessing current and future risks. She advised making this point clear throughout the document.

PATH FORWARD

Grosso thanked the participants for their interest and said that she would incorporate their comments into the document and send out an updated version soon. If people want to comment on the next iteration they should do so via email. Grosso said that the ultimate goal is to release the document during the first quarter of 2005. Ideally, she said, it will be released at the same time EPA publishes its sediments guidance document.

ACTION ITEMS

• Davoli will generate a list of specific issues that conflict with Region 10 practices and forward the list to EPA's Steve Ells.



• Sutter will send Grosso a reference for the DMMP.



• Saban will write up a paragraph on the NEBA approach and send it to Grosso for consideration. Thomas will send Saban and Sutter the name of someone at ChevronTexaco who might be able to provide references on the NEBA approach.



• Grosso will incorporate the comments that were provided during this conference call. Once she has finished doing so, she will redistribute an updated version of the document to the Framework Review Subgroup.