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MEMORANDUM
TO:
Jesse
Pritts
and
Pat
Harrigan,
EPA
EAD
CC:
Kathy
Monk,
EPA
EAD
FROM:
Betsy
Bicknell,
ERG
DATE:
February
6,
2003
SUBJECT:
Brief:
The
National
Sediment
Contaminant
Point
Source
Inventory:
Analysis
of
Facility
Release
Data
(
9/
1997)

This
memorandum
is
a
partial
response
to
Technical
Direction
received
from
Jesse
Pritts
on
January
15,
2003.
Among
other
things,
ERG
was
directed
to
review
briefs
prepared
by
EAD.
These
briefs
evaluate
the
utility
of
data
sources
for
determining
specific
industrial
categories
or
facilities
that
may
pose
a
risk
to
human
health
and
the
environment
or
may
be
significant
dischargers
of
toxic
or
conventional
pollutants
to
waters
of
the
U.
S.
due
to
wastewater
and
stormwater
discharges.
This
memorandum
addresses
the
brief
describing
The
National
Sediment
Contaminant
Point
Source
Inventory:
Analysis
of
Facility
Release
Data
(
9/
1997).

Overview
In
1997,
EPA
Office
of
Science
and
Technology
(
OST)
conducted
a
screening
analysis
identifying
probable
point
source
contributors
of
sediment
pollutants.
This
analysis
was
based
on
1994
discharge
data
compiled
in
PCS
and
in
the
1993
TRI
database.
PCS
includes
discharges
reported
by
direct­
discharging
facilities.
OST
evaluated
both
the
direct
and
indirect
releases
reported
in
TRI,
and
developed
a
sediment
hazard
scoring
system.
They
calculated
the
annual
chemical
load
from
each
facility
represented
in
PCS
and
TRI,
then
multiplied
this
load
by
the
sediment
hazard
score
to
calculate
a
hazard­
weighted
release.
The
hazard­
weighted
releases
for
each
industrial
category
were
summed
and
the
categories
were
ranked.
TRI
data
and
PCS
data
were
analyzed
separately.

Comments
°
The
methodology
used
to
analyze
PCS
data
could
be
used
in
EAD's
ongoing
analysis
of
PCS
loads
and
trends.
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°
Several
factors
were
used
to
weight
chemical
releases
for
sediment
contamination
potential.
There
is
limited
discussion
of
these
factors
in
the
brief.

°
TRI
and
PCS
do
not
provide
a
complete
picture
of
wastewater
discharges.

°
The
majority
of
sediment
contaminants
reported
in
PCS
are
discharged
by
sewerage
systems
and
public
utilities.

°
Three
categories
(
Metal
Products
and
Finishing,
Primary
Metals,
and
Industrial
Organic
Chemicals)
were
identified
in
both
the
analysis
of
the
TRI
data
and
the
PCS
data
as
major
dischargers
of
sediment
contaminants.

Short­
term
Follow­
up
(
February
­
March,
2003)

°
Contact
staff
responsible
for
the
PCS
analysis
and
request
detailed
documentation
to
potentially
support
EAD's
analysis
of
PCS.

°
Compare
the
factors
used
to
weight
chemical
releases
for
sediment
contamination
potential
to
the
"
toxic
weighting
factors"
EAD
has
used
to
analyze
the
cost­
effectiveness
of
effluent
limitations
guidelines
and
standards
and
the
environmental
indicators
included
in
RSEI.
Also
compare
these
factors
to
the
chemical
ranking
factors
used
by
OPPT.

°
For
chemicals
with
high
sediment
contamination
weights,
use
OPPT
tools
to
obtain
information
about
the
relative
amounts
of
these
chemicals
in
commerce
in
the
U.
S.
(
and
to
identify
chemicals
no
longer
in
commerce).
Also
use
the
OPPT
tools
to
identify
industries
from
which
the
identified
sediment
contaminants
may
be
discharged.

°
Get
further
breakdown,
by
industry,
of
the
Primary
Metals
discharges
to
determine
what
proportion
originated
from
facilities
in
the
Iron
and
Steel
point
source
category.

°
Collect
profile
information
about
the
Industrial
Organic
Chemicals,
Petroleum
Refining,
and
Plastic
Materials
and
Synthetic
Fibers
categories
for
use
in
EAD
targeting.

Long­
term
Follow­
up
(
after
March
2003)

°
Because
sewerage
systems
and
public
utilities
are
major
dischargers
of
sediment
contaminants
(
especially
divalent
metals),
comprehensive
analysis
of
inputs
to
and
outputs
from
these
sources
is
warranted.

°
The
Metal
Products
and
Finishing
Category
was
identified
as
a
major
source
of
sediment
contaminants.
EAD
has
just
completed
a
lengthy
and
extensive
review
of
the
category.
If,
using
updated
discharge
information,
category
remains
a
major
source
of
sediment
contaminants,
target
it
for
non­
regulatory
programs.
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°
Consider
incorporating
sediment
hazard
weighting
factors
into
other
risk
screening
tools
(
TWFs,
RSEI)
if
they
are
not
yet
included.
