Summary
Response
to
Comments
on
the
Contaminated
Sediments
Science
Plan
prepared
by
The
Contaminated
Sediments
Science
Plan
Workgroup
of
the
Science
Policy
Council
U.
S.
Environmental
Protection
Agency
Washington,
D.
C.
May
18,
2004
Summary
Response
to
Comments
Draft
Document
­
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May
18,
2004
Page
1
Section
1.0
Introduction
A.
Background
In
2000,
the
United
States
Protection
Agency's
(
EPA's)
Science
Policy
Council
(
SPC)
initiated
the
development
of
a
Draft
Contaminated
Sediments
Science
Plan
(
Science
Plan)
because
contamination
of
sediments
is
a
multi­
faceted,
cross­
Agency
issue
which
can
benefit
from
a
more
comprehensive
and
higher
level
of
coordination
across
EPA
Program
and
Regional
offices.
Extensive
resources
to
address
contaminated
sediment
problems
are
spent
by
a
number
of
Agency
program
offices,
including
the
Superfund
Program,
Office
of
Water
(
OW),
Office
of
Solid
Waste
(
OSW),
Great
Lakes
National
Program
Office
(
GLNPO),
Office
of
Pollution
Prevention
and
Toxic
Substances
(
OPPTS),
Office
of
Research
and
Development
(
ORD),
and
EPA
Regional
offices.
As
a
complement
to
EPA's
Science
Inventory,
(
which
was
not
complete
at
the
writing
of
the
Science
Plan),
the
Contaminated
Sediments
Science
Priorities
document
(
CSSP)
 
renamed
to
better
reflect
its
purpose
and
scope
 
is
a
mechanism
for
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
EPA)
to
develop
and
coordinate
Agency
office­
and
region­
wide
science
activities
that
affect
contaminated
sediments.
The
CSSP
provides
an
analysis
of
the
Agency's
contaminated
sediment
scientific
activities,
identifies
and
evaluates
science
needs,
and
provides
key
recommendations
for
filling
those
needs.

B.
EPA's
Science
Advisory
Board
(
SAB)
Peer
Review
and
Public
Comment
An
expert
panel
(
Expert
Panel)
under
the
Executive
Committee
of
EPA's
Science
Advisory
Board,
met
on
October
30­
31,
2002
to
review
the
June
13,
2002
Science
Plan.
The
review
was
conducted
at
the
request
of
the
Office
of
Solid
Waste
and
Emergency
Response
in
Washington,
D.
C.
at
a
public
meeting.
The
Panel
was
charged
with
reviewing
the
adequacy
of
the
Science
Plan
in
addressing
a
range
of
contaminated
sediments
issues,
as
well
as
considering
the
methods
exemplified
by
the
Science
Plan
for
agency­
wide
science
planning.

On
July
22,
2002,
the
US
Environmental
Protection
Agency
(
EPA),
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER),
issued
in
the
Federal
Register
a
Notice
of
Availability
and
Request
for
Comment
on
the
Science
Plan.
Twelve
commenters,
including
individual
corporations,
state
agencies,
environmental
and
public
interest
groups,
and
trade
associations,
submitted
over
260
individual
comments
regarding
the
science
policy
issues
(
submitted
under
Docket
SFUND­
2002­
0004).
The
comments
ranged
in
specificity.
Some
commenters
addressed
the
general
approach
and
its
rationale,
while
other
reviewers
provided
detailed
comments
only
on
certain
aspects
of
the
proposed
approach.
A
listing
of
the
names
and
affiliations
of
the
parties
submitting
comments
appears
in
Appendix
A.

Upon
receiving
all
comments,
the
CSSP
Workgroup
(
CSSP
WG),
a
cross­
Agency
Workgroup
comprising
staff
from
multiple
EPA
Program
Offices
and
Regions,
summarized
and
organized
all
comments
by
topic.
The
CSSP
WG
then
reviewed
all
comments
and
decided
upon
the
appropriate
revisions
to
the
document.
EPA
greatly
appreciates
the
time
and
thoroughness
of
the
reviewers
and
commenters
and
has
strived
to
improve
the
Science
Plan
based
on
their
comments.
Summary
Response
to
Comments
Draft
Document
­
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copy
May
18,
2004
Page
2
C.
Organization
of
this
Document
This
document
contains
a
summary
of
EPA's
responses
to
the
SAB
and
public
comments
received
on
its
Science
Plan.
It
is
not
meant
to
describe
EPA's
response
to
each
individual
comment
but
rather,
summarizes
how
EPA
is
addressing
major
recommendations
and
criticisms
in
its
revisions
to
the
Science
Plan.
Although
the
Agency
solicited
comments
on
all
aspects
of
the
Science
Plan,
comments
and
information
were
specifically
sought
on
the
following
four
questions:

1.
Does
the
Science
Plan
adequately
convey
the
needs
for
such
a
strategic
planning
document,
i.
e.,
are
the
goals
and
objectives
of
the
plan
understandable
and
appropriate
to
the
subject?

2.
Are
the
major
areas
of
contaminated
sediments
science
(
sediment
site
characterization,
exposure
assessment,
human
health
effects
and
risk
assessment,
ecological
effects
and
risk
assessment,
sediment
remediation,
baseline
and
postremediation
monitoring,
risk
communication,
and
information
management
and
exchange
activities)
appropriately
addressed?
Are
any
major
areas
missing?

3.
Are
the
key
recommendations
clearly
defined
and
appropriate
to
resolve
the
science
needs
discussed
in
Chapter
3?

4.
Are
there
other
issues
or
key
recommendations
which
should
be
considered
in
this
Science
Plan?

The
SAB
peer
review
and
public
responses
to
the
questions
above
could
generally
be
divided
into
two
general
categories:
programmatic
or
scientific.
For
the
purposes
of
this
Summary
Response
to
Comments
document,
the
comments
have
been
grouped
into
the
following
four
broad
topics:

1.
The
scope/
purpose
of
the
Science
Plan
(
including
the
process
and
criteria
used
to
determine
and
prioritize
science
needs
and
the
prioritization/
implementation
of
Science
Plan
recommendations);

2.
The
role/
science
of
sediment
quality
guidelines;

3.
Data
collection
needs;
and,

4.
Method
development
needs.

Section
2.0
Response
to
Comments
Section
2.0
is
divided
into
the
four
broad
comment
topics
listed
above.
Following
each
topic
are
the
issues
raised
by
the
SAB
or
public
commenters.
The
issues
presented
represent
the
range
of
comments
received
and
particularly,
those
requiring
revisions
to
the
Science
Plan.
EPA's
response
is
presented
after
each
issue
and
discusses
the
revisions
to
the
Science
Plan
or
the
Agency's
rationale
for
why
no
changes
were
required.
Summary
Response
to
Comments
Draft
Document
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May
18,
2004
Page
3
Topic
1:
The
Scope/
Purpose
of
the
Science
Plan
The
Draft
Contaminated
Sediments
Science
Plan
stated
three
goals:
1)
to
develop
and
disseminate
tools
and
science
necessary
to
address
the
management
of
contaminated
sediments;
2)
to
enhance
the
level
of
coordination
and
communication
of
science
activities
across
the
Agency;
and,
3)
to
develop
an
effective,
cost­
efficient
strategy
to
promote
these
scientific
activities
and
research.
These
goals
are
revised
in
the
Contaminated
Sediments
Science
Priorities
document
(
renamed
to
better
reflect
its
purpose
and
scope)
as
follows:
1)
identify
the
science
necessary
to
address
the
assessment
and
management
of
contaminated
sediments;
2)
identify
the
science
gaps
and
tools
that
are
important
in
reducing
uncertainty
in
contaminated
sediment
risk
management
decision­
making;
3)
recommend
approaches
to
promote
necessary
scientific
activities
and
research;
and,
4)
enhance
the
level
of
coordination
and
communication
of
contaminated
sediment
science
activities
across
Agency
program
and
regional
offices.
By
meeting
these
goals,
the
Agency
will
have
developed
a
scientifically
sound
and
effective
plan
for
addressing
contaminated
sediments,
leading
to
improved
environmental
decision­
making
and
the
conservation
of
human
and
financial
resources.

Given
the
extensive
range
of
comments
received
on
the
scope
of
the
Science
Plan,
several
broad
issues
are
discussed
and
commented
on
below.

Issue
1A:
Based
on
the
goals
of
the
Science
Plan
above,
most
public
commenters
and
the
Science
Advisory
Board
(
SAB)
expressed
an
overarching
concern
regarding
the
value
of
the
Science
Plan
as
a
basis
for
science
planning.
Generally,
neither
the
SAB
nor
public
commenters
found
the
Science
Plan
an
adequate
strategic
planning
document.
The
SAB
explicitly
stated:

While
this
effort
will
substantially
contribute
to
building
awareness
of
important
contaminated
sediment
work
across
the
Agency,
its
value
as
a
foundation
for
coordinating
current
and
future
contaminated
sediments
science
activities
is
compromised
in
the
absence
of
knowledge
regarding
the
research
being
done
in
other
Federal,
State
and
regional
governments.
.
.
.
[
A]
broader
review
of
pertinent
science
is
necessary
for
the
Agency
to
ascertain
research
priorities.
.
.
.
In
the
absence
of
[
a
coherent]
framework
[
governing
plan
development,
implementation,
and
assessment]
and
identifiable
criteria
for
science
priority
setting,
the
material
presented
in
the
draft
document
is
most
reasonably
viewed
as
an
inventory
or
synthesis
of
the
Agency's
current
contaminated
sediment
science
related
activities.

The
framework
should
be
accompanied
by
realistic
priorities
and
describe
how
research
within
the
different
subject
areas
(
key
scientific
questions)
will
be
coordinated
and
integrated
across
the
different
topic
areas.

The
SAB
further
noted:

The
need
for
the
development
of
a
defensible
science
planning
framework
is
so
fundamental
to
addressing
complex
and
multi­
jurisdictional
environmental
problems,
that
the
Panel
does
not
recommend
extensive
revision
of
the
CSSP
work
group's
document
 
Instead,
the
Panel
suggests
that
the
development
of
a
model
science
plan,
undertaken
with
sufficient
resources
and
a
coherent
vision,
should
proceed
on
a
separate
track
targeting
an
alternative
technical
area,
one
that
is
less
complicated,
more
easily
assembled,
and
offering
a
fresh
approach
to
development
of
a
defensible
cross­
Agency
science
plan.
Summary
Response
to
Comments
Draft
Document
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May
18,
2004
Page
4
Several
commenters
expressed
their
belief
that
the
Science
Plan
did
not
provide
sufficient
detail
with
regard
to
implementation
and
that
many
of
the
plan's
recommendations
are
place
holders
that
sketch
out
only
general
ideas
for
research.

Several
commenters
also
stated
that
the
Science
Plan
is
too
ambitious
in
its
inclusion
of
33
specific
recommendations
and
that
the
recommendations
should
be
prioritized
and
streamlined
so
that
a
realistic
number
of
action
items
can
be
accomplished
within
an
appropriate
time
frame.
Another
commenter
stated
that
the
Science
Plan
should
capitalize
on
the
experience
and
resources
of
other
public
and
private
stakeholders.

EPA
Response:
The
Agency
agrees
that
further
discussion
of
prioritization
and
coordination
is
appropriate
and
necessary.
The
Agency
developed
the
Science
Plan
as
a
first
step
in
coordinating
the
numerous
science
activities
that
were
occurring
in
the
various
Offices,
and
Regions.
Science
planning
and
coordination
occurs
across
various
Offices
within
EPA.
However,
each
Office
has
its
own
budget
that
funds
all
activities
for
that
office.
Science
activities
for
contaminated
sediments
may
therefore
compete
with
other
funding
requirements.
As
such,
the
Science
Plan
proposed
that
a
broad
oversight
committee
,
such
as
the
SPC,
would
be
an
appropriate
group
to
oversee
prioritizing
and
funding
contaminated
sediment
issues.

Prioritization
of
Science
Plan
recommendations
into
"
immediate
time
frame"
and
"
longer
time
frame"
categories
was
used
to
provide
general
guidance
regarding
the
importance
of
the
science
needs
discussed.
Once
these
needs
had
been
discussed
and
further
prioritized
within
EPA
Offices,
with
regard
to
their
regulatory
and
budget
constraints,
a
more
complete
examination
and
planning
of
the
topic
would
be
undertaken.
The
Science
Plan
attempted
to
present
the
needs
and
recommendations
of
highest
concern
for
the
Agency,
with
greater
detail
provided
by
the
individual
Offices
undertaking
the
work.

To
address
SAB
and
public
reviewer
concerns
regarding
the
process
and
criteria
used
to
develop
key
science
recommendations,
the
Agency
significantly
revised
the
Science
Plan
to
more
clearly
explain
the
process
and
criteria
used
by
the
CSSP
WG.
The
rationale
for
the
selection
of
the
key
recommendations
is
also
more
explicitly
described
and
linked
with
the
overall
discussion
of
the
science
needs
in
Section
3
of
the
document.

The
Agency
also
recognizes
the
utility
of
public
and
private
stakeholders
in
assisting
the
Agency
in
establishing
science
priorities.
Sections
2.5.1
and
2.5.2
of
the
Science
Plan
discuss
the
collaborative
efforts
of
the
Agency.
EPA
has
sought
the
expertise
of
public
and
private
stakeholders
by
hosting
several
joint
stakeholder
meetings
on
various
contaminated
sediment
science
topics
such
as
an
EPA
Forum
on
Managing
Contaminated
Sediments
at
Hazardous
Waste
Sites
(
June
2001),
an
intensive
three
day
workshop
on
Sediment
Stability
(
January
2002),
and
a
workshop
on
the
Environmental
Stability
of
Chemicals
in
Sediments
(
April
2003).
The
information
garnered
from
these
meetings
was
also
incorporated
into
the
CSSP.
The
summaries
for
these
meetings
can
be
found
at:
the
following
website:
<
http://
www.
epa.
gov/
superfund/
resources/
sediment/
meetings.
htm>
Summary
Response
to
Comments
Draft
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May
18,
2004
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5
Issue
1B:
EPA's
SAB
was
strongly
supportive
of
EPA's
inclusion
of
the
risk
communication,
community
involvement,
information
management
topics.
However,
several
commenters
expressed
concern
that
these
topics
have
little
or
nothing
to
do
with
science
and
therefore
should
not
be
included.

Response:
The
Agency
believes
an
important
goal
of
the
CSSP
is
to
identify
the
science
gaps
and
tools
that
are
important
in
reducing
uncertainty
in,
and
improving
the
consistency
of,
contaminated
sediment
decision­
making.
Risk
communication
and
information
management
are
fundamental
to
meeting
this
goal.
The
National
Research
Council
in
their
Risk
Management
Strategy
for
PCB­
Contaminated
Sediments
stressed
the
importance
of
community
involvement
in
their
risk
management
framework
(
NRC,
2001).
EPA
believes
that
the
community
should
be
involved
early
and
often
when
addressing
a
contaminated
sediment
hazardous
waste
site.
Given
the
importance
of
these
topics
to
contaminated
sediment
science,
these
sections
were
not
removed
from
the
CSSP.

Issue
1C:
Several
commenters
expressed
their
belief
that
characterizing
PCB
risk
on
congener
basis
and
evaluating
toxicity
of
endocrine
disruptors
(
and
alkylphenol
ethoxylates
in
particular)
are
not
sediment
specific
and
therefore
should
not
be
in
the
CSSP.

Response:
Although
neither
PCBs
nor
endocrine
disruptors
are
unique
to
sediments,
they
are
often
found
in
contaminated
sediments.
In
addition,
EPA
is
concerned
about
the
interaction
between
PCBs/
endocrine
disruptors
and
sediments
characteristics
(
e.
g.,
organic
content,
grain
size,
and
mixing)
that
affect
bioavailability
and
exposure.
Thus
the
Agency
has
included
the
study
of
these
substances
as
a
vehicle
for
understanding
the
risks
associated
with
contaminated
sediments.
The
NRC
also
suggests
the
use
of
PCB
congeners
as
total
PCB
concentrations
may
not
accurately
capture
exposure
and
toxicity
effects
(
NRC,
2001).
Given
the
importance
of
these
topics
to
contaminated
sediment
science,
these
sections
were
not
removed
from
the
CSSP.

Issue
1D:
A
commenter
questioned
the
absence
of
a
more
thorough
description
of
the
role
of
other
federal
agencies,
states,
and
tribes
in
the
Science
Plan.
The
commenter
noted
further
that
many
Federal
Agencies
and
states
have
invested
considerable
resources
in
contaminated
sediment
science
and
have
developed
a
number
of
useful
tools
for
assessing
problems.

Response:
The
Agency
has
listed
other
Federal
Agencies
as
suggested
partners
for
key
recommendations
and
currently
coordinates
contaminated
sediment
science
issues
with
numerous
federal
agencies,
states,
and
tribes.
Such
collaborations
are
the
subject
of
many
Memorandums
of
Understanding
(
MOUs)
between
the
Agency
and
its
partners.
In
addition,
EPA
staff
regularly
participate
on
many
multi­
stakeholder
workgroups
and
committees.

EPA
agrees
that
many
federal
agencies
and
states
(
e.
g.,
California,
Florida,
Washington)
have
invested
considerable
resources
in
contaminated
sediment
science
and
have
developed
a
number
of
useful
tools
for
assessing
problems.
EPA's
recommendations
are
Summary
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consistent
with
the
science
needs
or
recommendations
that
are
currently
being
addressed
by
other
agencies
and
States
and
the
CSSP
encourages
continued
coordination
with
these
groups
(
See
response
to
Issue
1A).

Additional
Issues
Regarding
the
Scope
of
the
CSSP
Many
commenters
suggested
that
the
scope
of
the
CSSP
be
expanded
and
suggested
the
inclusion
of
several
topics
to
the
document.
EPA
responds
to
several
of
the
more
commonly
suggested
topic
inclusions
below.

Bioavailability:
Several
commenters
expressed
concern
that
the
issue
of
contaminant
bioavailability
was
not
adequately
addressed
by
the
Science
Plan.
Commenters
noted
that
while
the
shortcomings
of
available
methods
are
acknowledged,
no
appropriate
science
is
suggested.
Another
commenter
noted
that
the
Agency
did
not
address
specific
types
of
organic
carbon
in
its
recommendations.

Response:
The
CSSP
is
intended
to
broadly
lay
out
science
activities
to
be
conducted
by
EPA.
The
Agency
addresses
contaminant
bioavailability
when
it
suggests
research
and
model
validation
in
support
of
a
tiered
framework
to
assess
food
web
exposures
which
includes
bioaccumulation.

The
Agency
agrees
that
the
various
forms
of
carbon
in
sediments
can
affect
sorption
mechanisms
and
bioavailability.
The
document
has
been
revised
to
acknowledge
that
the
type
of
organic
carbon
is
an
important
consideration
in
contaminant
binding
phases
and
bioavailability.

Direct
Toxicity:
Several
commenters
suggested
that
direct
toxicity
(
e.
g.,
dermal
exposure)
from
contaminated
sediments
should
be
included
within
the
list
of
human
health
effects.

Response:
The
Agency
agrees
that
there
is
a
science
need
to
better
understand
the
exposure
that
results
from
direct
skin
contact
with
contaminated
sediments.
The
CSSP
identifies
two
specific
science
needs
regarding
direct
toxicity
from
contaminated
sediments:
1)
to
determine
the
amount
of
sediment
that
might
come
into
contact
with
the
skin
from
various
activities;
and
2)
to
develop
a
model
that
accurately
predicts
how
much
of
the
sediment­
borne
contaminants
cross
the
dermal
barrier
(
and
available
to
effect
toxicity).
In
addition,
the
topic
of
direct
toxicity
is
being
addressed
by
other
groups
within
EPA.
The
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
has
recently
released
a
draft
Risk
Assessment
Guidance
for
Superfund,
Part
E,
Supplemental
Guidance
for
Dermal
Risk
Assessment
(
U.
S.
EPA,
2001b)
for
public
review.
It
promotes
a
consistent
methodology
for
assessing
the
exposures
from
the
dermal
pathway
and
focuses
on
dermal
contact
with
soil
and
water;
it
does
not
provide
guidance
on
quantifying
dermal
absorption
of
chemicals
resulting
from
exposure
to
vapors.
Additional
information
for
procedural
guidance
towards
evaluating
exposure
to
contaminated
sediments
can
be
found
in
the
OSWER
Supplemental
Guidance
for
Developing
Soil
Screening
Levels
at
Superfund
Sites
(
U.
S.
EPA,
2002a)
and
the
Soil
Screening
Guidance
(
U.
S.
EPA,
1996b).
Summary
Response
to
Comments
Draft
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May
18,
2004
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As
this
issue
is
not
limited
to
contaminated
sediments
and
because
other
EPA
Offices
are
addressing
the
topic,
additional
information
was
not
included
in
the
CSSP.

Mixtures:
A
commenter
suggested
that
the
Agency
conduct
research
and
provide
guidance
on
approaches
to
assess
the
toxicity
of
mixtures
of
contaminants
in
sediment
that
account
for
interactive
effects
based
on
mechanisms
of
toxic
action.

Response:
The
Agency
agrees
that
science
and
guidance
on
approaches
to
assess
the
toxicity
of
mixtures
of
contaminants
that
account
for
interactive
effects
based
on
mechanisms
of
toxic
action
is
a
science
need.
EPA
issued
the
Supplementary
Guidance
for
Conducting
Health
Risk
Assessment
of
Chemical
Mixtures
(
U.
S.
EPA,
2000a),
which
represents
the
Agency's
policy
and
procedural
guidance
for
evaluating
data
on
the
health
risks
from
exposures
to
chemical
mixtures.
The
document's
focus
is
on
dose
response
and
risk
characterization
and
is
organized
according
to
the
type
of
data
available.
The
Agency's
Human
Health
Research
Strategy
(
U.
S.
EPA,
2003a)
and
Ecological
Research
Multi­
Year
Plan
(
U.
S.
EPA,
2003b)
also
address
the
science
needs
associated
with
assessing
the
risks
to
both
humans
and
the
environment
as
a
result
of
their
exposure
to
mixtures
of
chemicals.
As
this
issue
is
not
limited
to
contaminated
sediments
and
because
other
EPA
Offices
are
addressing
the
topic,
additional
information
was
not
included
in
the
CSSP.

Indicator
Species:
A
commenter
suggested
that
the
Agency
give
additional
consideration
to
developing
a
transparent
and
scientifically
defensible
process
for
indicator
species
selection
that
accounts
for
their
range
of
sensitivities
to
contaminants,
developing
specific
guidance
for
assessing
risk
to
endangered
and
threatened
species
from
contaminated
sediments
and
for
evaluating
the
effectiveness
of
various
risk
reduction
options
to
mitigate
risk
to
protected
species,
and
developing/
applying
ecological
risk
assessment
models
that
appropriately
address
species
variability.

Response:
The
Agency
agrees
that
a
transparent
and
scientifically
defensible
process
for
indicator
species
selection
that
accounts
for
their
range
of
sensitivities
to
contaminants
is
an
important
goal.
EPA
notes
that
these
(
and
similar)
science
needs
are
addressed
in
the
Agency's
Ecological
Research
Multi­
Year
Plan
(
U.
S.
EPA,
2003b).
As
this
issue
is
not
limited
to
contaminated
sediments
and
because
other
EPA
Offices
are
addressing
the
topic,
additional
information
was
not
included
in
the
CSSP.

Sub­
populations:
A
commenter
suggested
that
the
Agency's
failure
to
include
specific
recommendations
for
sensitive
sub­
population
studies
is
a
significant
oversight
since
such
studies
are
critical
in
establishing
the
variability
of
risk
associated
with
targeted
populations.

Response:
The
Agency
agrees
that
sensitive
sub­
population
studies
are
critical
in
establishing
the
variability
of
risk
associated
with
targeted
populations
and
notes
that
the
Office
of
Research
and
Development's
(
ORD)
Human
Health
Research
Strategy
(
U.
S.
EPA,
2003a)
proposes
research
on
susceptible
sub­
populations
that
focuses
on
developing
a
scientific
understanding
of
the
biological
basis
for
differing
responsiveness
of
subpopulations
within
the
general
population,
including
factors
associated
with
their
Summary
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differential
exposure.
As
this
issue
is
not
limited
to
contaminated
sediments
and
because
other
EPA
Offices
are
addressing
the
topic,
additional
information
was
not
included
in
the
CSSP.

Topic
2:
The
Role
of
Sediment
Quality
Guidelines
The
role
and
science
of
Sediment
Quality
Guidelines
were
a
major
topic
of
comments.
Given
the
needs
of
risk
assessors
and
decision­
makers,
the
CSSP
includes
a
discussion
of
frameworks
for
sediment
quality
assessments
(
dealing
in
particular
with
the
use/
limitations
of
SQGs
based
on
equilibrium
partitioning).

Issues:
Following
are
some
specific
issues
raised
by
the
commenters.

Equilibrium
Partitioning:
Several
commenters
expressed
numerous
concerns
regarding
sediment
quality
guidelines
(
SQGs)
in
general
and
equilibrium
partitioning
(
EqP)
guidelines
in
particular.
Comments
included:

°
EqPs
are
not
sufficiently
accurate
to
be
used
to
determine
which
contaminants
can
exert
toxic
effects;
°
EqPs
should
only
be
used
for
screening
purposes
to
determine
the
needs
for
additional
sediment
assessment;
°
EqPs
must
not
be
considered
substitutes
for
toxicity
tests;
°
The
EqP
approach's
assumption
of
steady­
state
equilibrium
dynamics
can
ignore
high
variability
in
sediment
environments;
°
The
EqP
approach
used
in
the
ESGs
does
not
account
for
important
factors
such
as
pH
that
effect
bioavailability
and
toxicity;
°
Uncertainty
in
EqP
values
has
been
greatly
underestimated.

Response:
A
range
of
sediment
quality
assessment
methods,
including
Equilibrium
Partitioning
Sediment
Quality
Guidelines
(
ESGs)
are
available
for
sediment
quality
assessment.

As
is
stated
in
EPA's
Procedures
for
the
Derivation
of
Equilibrium
Partitioning
Sediment
Benchmarks
(
ESBs)
for
the
Protection
of
Benthic
Organisms:
PAH
Mixtures
(
EPA/
600/
R­
02/
013),
ESBs
do
not
consider
antagonistic,
additive
or
synergistic
effects
of
other
sediment
contaminants
in
combinations
with
other
contaminants
(
in
this
specific
case,
with
PAHs)
or
the
potential
for
bioaccumulation
and
trophic
transfer
of
contaminants
(
in
this
specific
case,
with
PAHs)
to
aquatic
life,
wildlife
or
humans.
Consistent
with
the
recommendation
of
EPA's
Science
Advisory
Board,
publication
of
these
documents
does
not
imply
the
use
of
ESBs
as
stand­
alone,
pass­
fail
criteria
for
all
applications;
rather,
ESB
exceedances
could
be
used
to
trigger
the
collection
of
additional
assessment
data.

Topic
3:
Data
Collection
Needs
Summary
Response
to
Comments
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18,
2004
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The
CSSP
identifies
and
discusses
a
variety
of
data
needs
within
the
topics
of
sediment
site
characterization;
exposure
assessment;
human
health
effects
and
risk
assessment;
ecological
effects
and
risk
assessment;
sediment
remediation,
baseline,
remediation
and
post­
remediation
monitoring;
risk
communication
and
community
involvement;
and,
information
management
and
exchange
activities.
The
CSSP
makes
a
number
of
recommendations
with
regard
to
data
collection
efforts.

Issues:
Commenters
made
numerous
suggestions
regarding
development
of
additional
data
to
improve
contaminated
sediment
management
decisions.
Three
of
the
more
common
issues
recommend
that
the
Agency:

°
Evaluate
comprehensively
the
field
data
available
from
numerous
capped
and
dredged
sediment
sites;
°
Develop
a
better
understanding
of
the
role
of
natural
attenuation
processes
in
different
environments
and
for
different
chemical
and
chemical
mixtures,
and;
°
Evaluate
the
impacts
on
habitat
and
aquatic
plants
and
animals
potentially
caused
by
capping,
dredging;

Response:
The
Agency
recognizes
the
importance
of
these
suggestions.
Specifically,
recommendations
D.
4
and
E.
2
identified
the
need
to
further
evaluate
the
impacts
and
performance
of
dredging
and
capping
technologies.
Also,
work
has
been
undertaken
in
several
of
these
areas
in
various
EPA
Offices.
For
example,
EPA's
Superfund
Program
maintains
a
contaminated
sediment
remedy
database
to
track
remedial
decisions
at
Superfund
sites.
ORD
also
evaluates
field
data,
techniques,
and
results
from
various
capped
and
dredged
sites
through
individual
investigations
and
via
its
cross­
office
Contaminated
Sediment
Focus
Groups.
The
CSSP
also
identifies
the
need
to
analyze
data
from
historical
and
ongoing
capping
remedies
and
to
evaluate
the
performance
of
innovative
and
low
resuspension
dredging
technologies.

With
respect
to
dredging
performance
evaluation
(
e.
g.,
the
rate
of
resuspension,
precision
of
dredging,
production
rates),
the
Agency
notes
that
other
studies
have
evaluated
the
range
of
commonly
used
dredging
technologies
(
e.
g.,
NRC
1997,
U.
S.
EPA
1996a,
Steuer
2000).
The
CSSP
therefore
focuses
on
gaps
in
performance
evaluation
associated
with
innovative
and
low
resuspension
dredging
equipment.

The
Agency
agrees
that
better
understanding
of
the
impacts
of
dredging
(
i.
e.,
the
destruction
and
recovery
of
submerged
vegetation)
would
improve
comparative
net
risk
reduction
calculations
for
the
sediment
management
alternatives
under
consideration
at
a
given
site.
Recommendations
D.
4
identifies
a
collaborative
approach
for
studying
the
short­
and
long­
term
impacts
from
environmental
dredging).
Recommendation
E.
2
specifically
identifies
the
need
to
further
evaluate
the
impacts
and
performance
of
dredging
and
capping
technologies.

Topic
4:
Method
Development
Needs
Summary
Response
to
Comments
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2004
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The
CSSP
identifies
and
discusses
a
variety
of
science
needs
in
the
context
of
method
development
within
the
topics
of
sediment
site
characterization;
exposure
assessment;
human
health
effects
and
risk
assessment;
ecological
effects
and
risk
assessment;
sediment
remediation,
including
baseline,
remediation
and
post­
remediation
monitoring;
risk
communication
and
community
involvement;
and,
information
management
and
exchange
activities.
The
CSSP
makes
a
number
of
recommendations
with
regard
to
method
development.

Issues:
Commenters
made
numerous
suggestions
regarding
the
development
of
additional
methods/
tools
to
improve
contaminated
sediment
management
decisions.
These
issues
are
presented
and
responded
to
by
specific
issue
below.

Fate
and
Transport:
Commenters
suggested
that
EPA
explicitly
recognize
in
its
fate/
transport
models
the
differences
among
contaminant
source
material
and
apply
appropriate
risk
assessment
models
to
systematically
differentiate
those
exposure
routes
that
warrant
further
evaluation
from
those
that
have
an
insignificant
impact
on
human
health
risk.

Response:
The
Agency
also
agrees
that
the
recommendations
of
Section
3.4
deserve
expansion,
including
the
need
to
explicitly
consider
the
fate/
transport
of
the
source
material.
The
Agency
further
agrees,
in
principle,
that
different
models
are
required
for
different
contaminants
in
order
to
estimate
human
health
effects
(
e.
g.,
there
are
significant
differences
in
the
bioaccumulation
of
PCBs,
PAHs,
and
metals).

The
Agency
concurs
with
commenters
regarding
issues
they
have
identified
in
sediment
fate
and
transport
modeling
and
has
recommended
developing
improved
contaminant
fate
and
transport
models
for
site­
specific
exposures.
In
particular,
recommendation
B.
3
discusses
the
need
for
development
of
valid
fate
and
transport
models
accounting
for
bulk
sediment
movement
by
natural
hydrodynamics
and
human
intervention.

Sediment
Stability:
Commenters
suggested
that
EPA
develop
guidance
or
a
methodology
governing
the
evaluation
of
sediment
stability
at
contaminated
sediment
sites.

Response:
EPA
recognizes
that
sediment
stability
is
a
critical
area
of
contaminated
sediment
science.
As
such,
EPA
is
actively
pursuing
issues
related
to
sediment
stability
through
numerous
co­
sponsored
workshops
and
also
addresses
the
topic
in
its
Draft
Contaminated
Sediment
Remediation
Guidance
for
Hazardous
Waste
Sites.
The
scientific
issues
that
bear
on
sediment
stability
are
also
addressed
in
several
places
in
the
CSSP,
including
Sections
3.3,
3.6.1,
and
3.6.2.
Recommendation
B.
3,
for
example,
discusses
the
need
for
development
of
valid
fate
and
transport
models
accounting
for
bulk
sediment
movement
by
natural
hydrodynamics
and
human
intervention.
Recommendation
E.
1
identifies
the
need
to
collect
data
and
develop
guidance
for
assessing
the
relative
contribution
of
mass
transport
of
contaminants
by
large
storm
events
in
evaluations
of
the
suitability
of
natural
recovery
as
a
remedial
option.
The
need
for
science
to
better
understand
the
scientific
issues
that
bear
on
sediment
stability
is
embodied
in
these
recommendations.
EPA
recognizes
the
importance
of
developing
a
guidance
document
Summary
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to
discuss
sediment
stability
and
believes
the
science
activities
recommended
above
will
guide
and
assist
with
future
Agency
efforts
in
this
area.

Chemical
Prioritization:
Commenters
suggested
that
EPA
formulate
and
implement
a
scientifically
defensible
approach
for
selecting
and
prioritizing
those
chemicals
of
concern
that
require
further
human
health
effects
investigation.

Response:
Although
the
formulation
and
development
of
a
scientifically
defensible
approach
for
prioritizing
chemicals
for
evaluation
is
beyond
the
purview
of
the
CSSP,
the
Agency
notes
that
the
Office
of
Research
and
Development's
(
ORD)
Human
Health
Research
Strategy
(
U.
S.
EPA,
2003a)
proposes
research
on
establishing
principles
for
prioritization
of
chemicals
for
screening
and
testing.
In
addition,
the
Agency's
National
Center
for
Environmental
Assessment's,
Integrated
Risk
Information
System
(
IRIS)
has
an
established
process
for
selecting
chemicals
found
in
the
environment
that
affect
human
health.
IRIS
is
a
tool
that
provides
hazard
identification
and
dose­
response
assessment
information,
but
does
not
provide
situational
information
on
instances
of
exposure.
The
Agency
also
recommends
chemicals
of
concern
that
require
human
health
toxicology
research
to
the
interagency
National
Toxicology
Program
(
NTP),
which
serves
and
is
governed
by
the
National
Institutes
of
Environmental
Health
Sciences
(
NIEHS).
The
NTP
coordinates
toxicological
testing
programs;
develops
and
validates
improved
testing
protocols;
and
provides
information
about
potentially
toxic
chemicals
to
health
regulatory
and
research
agencies,
the
scientific
and
medical
communities,
and
the
public.

Section
3.
Summary
After
reviewing
and
responding
to
both
SAB
and
public
comments,
the
CSSP
WG
revised
the
Science
Plan,
now
renamed
Contaminated
Sediments
Science
Priorities,
and
presented
the
document
to
the
SPC
for
final
review.
SUMMARY
WILL
BE
COMPLETED
AFTER
SPC
REVIEW.

Section
4.
Bibliography
Expert
Panel
2003.
Report
of
the
Science
Advisory
Board
Executive
Committee
Panel
on
the
Contaminated
Sediments
Science
Plan.
U.
S.
Environmental
Protection
Agency,
Science
Advisory
Board,
Executive
Committee,
Contaminated
Sediments
Science
Plan
Review
Panel.
February
18,
2003.

National
Research
Council.
1997.
Contaminated
Sediments
in
Ports
and
Waterways:
Cleanup
Strategies
and
Technologies.
National
Academy
Press,
Washington,
D.
C.

National
Research
Council.
2001.
A
Risk­
Management
Strategy
for
PCB­
Contaminated
Sediments.
National
Academy
Press,
Washington,
D.
C.

Steuer,
Jeffrey
J.
2000.
A
Mass­
Balance
Approach
for
Assessing
PCB
Movement
During
Remediation
of
a
PCB­
Contaminated
Deposit
on
the
Fox
River,
Wisconsin.
USGS
Report
00­
4245.
U.
S.
Geological
Survey,
Middleton,
WI.
Summary
Response
to
Comments
Draft
Document
­
Do
not
cite,
circulate,
or
copy
May
18,
2004
Page
12
U.
S.
EPA.
1996a.
ARCS
Program
­
Estimating
Contaminant
Losses
from
Components
of
Remediation
Alternatives
for
Contaminated
Sediments.
EPA­
905­
R96­
001.
U.
S.
Environmental
Protection
Agency,
Great
Lakes
National
Program
Office,
Chicago,
IL.

U.
S.
EPA.
1996b.
Soil
Screening
Guidance:
Technical
Background
Document.
United
States
Environmental
Protection
Agency,
Office
of
Solid
Waste
and
Emergency
Response,
Office
of
Emergency
and
Remedial
Response,
Washington
DC
EPA/
540/
R95/
128.

U.
S.
EPA
200a.
Supplementary
Guidance
for
Conducting
Health
Risk
Assessments
of
Chemical
Mixtures.
United
States
Environmental
Protection
Agency
Risk
Assessment
Forum,
Washington
DC
EPA/
630/
R/
00002.

U.
S.
EPA
2001a.
Office
of
Research
and
Development,
Strategic
Plan.
United
States
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Washington
DC
20460
EPA/
600/
R­
01/
003.
January
2001.

U.
S.
EPA
2001b.
Risk
Assessment
Guidance
for
Superfund,
Vol.
1:
Human
Health
Evaluation
Manual
(
Part
E),
Supplemental
Guidance
for
Dermal
Assessment.
United
States
Environmental
Protection
Agency,
Office
of
Emergency
and
Remedial
Response,
Washington
DC
EPA/
540/
R/
99005.

U.
S.
EPA
2002a.
Supplemental
Guidance
for
Developing
Soil
Screening
Levels
for
Superfund
Sites.
Office
of
Solid
Waste
and
Emergency
Response,
Office
of
Emergency
and
Remedial
Response,
Washington
DC
OSWER
9355.4­
24.

U.
S.
EPA
2003a.
Human
Health
Research
Strategy.
United
States
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Washington
DC
20460
EPA/
600/
R­
02/
050.
September
2003.

U.
S.
EPA
2003b.
Ecological
Research
Multi­
Year
Plan.
United
States
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Washington
DC
May
29,
2003.
Summary
Response
to
Comments
Draft
Document
­
Do
not
cite,
circulate,
or
copy
May
18,
2004
Page
13
Appendix
A
List
of
Commenters
American
Chemistry
Council
1300
Wilson
Boulevard
Arlington,
Virginia
22209
ASTSWMO
444
North
Capitol
Street,
NW
Suite
315
Washington,
DC
20001
Clean
Ocean
Action
18
Hartshorne
Drive
P.
O.
Box
505
Highlands,
New
Jersey
07732­
0505
DuPont
Corporate
Remediation
Group
Nancy.
R.
Grosso@
usa.
dupont.
com
Federal
Water
Quality
Coalition
2600
Chase
Plaza
10
South
LaSalle
Street
Chicago,
Illinois
60603
National
Sediments
Coalition
(
NSC)
3000
K
Street,
NW
Suite
300
Washington,
DC
20007
Sediment
Management
Work
Group
c/
o
Steven
C.
Nadeau
Coordinating
Director
2290
First
National
Building
660
Woodward
Avenue
Detroit,
Michigan
48226
Ohio
EPA,
NEDO
2110
East
Aurora
Road
Twinsburg,
Ohio
44087
Michigan
Department
of
Environmental
Quality
Constitution
Hall
525
West
Allegan
Street
P.
O.
Box
30473
Lansing,
Michigan
48909
Summary
Response
to
Comments
Draft
Document
­
Do
not
cite,
circulate,
or
copy
May
18,
2004
Page
14
Tennessee
Valley
Authority
Environmental
Policy
&
Planning
Water
Programs
jrwright@
tva.
gov
Utility
Solid
Waste
Activity
Group
c/
o
Edison
Electric
Institute
701
Pennsylvania
Avenue,
NW
Washington,
DC
20004­
2696
XCEL
Energy
414
Nicollet
Mall
Minneapolis,
Minnesota
55401­
1993
