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Communication and outreach with the community and other stakeholders can pose unique challenges at sediment sites, especially at large sites on publicly used water bodies. Community involvement coordinators often have a critical role as part of the project team at these sites. Sediment sites that span large areas may present barriers to communicating effectively with different communities, local governments, and the private sector along the water body. People who live, work, and play adjacent to water bodies that contain contaminated sediment should receive accurate information about the safety of their activities, and be provided opportunities for involvement in the EPA’s decision-making process for sediment cleanup. Community members may have a wide variety of needs and wishes for current and future uses of the water body. Highlights 1-8 and 1-9 list some of the common community concerns about contaminated sediment and risk reduction methods for sediment. These lists are compiled from information provided by Superfund project managers and by the NRC (2001). Project managers should be aware of these potential concerns and others specific to their sites.
Highlight 1-8: Common Community Concerns about Contaminated Sediment • Human health impacts from eating fish/shellfish, wading, and swimming • Ecological impacts on wildlife and aquatic species • Loss of recreational and subsistence fishing opportunities • Loss of recreational swimming and boating opportunities • Loss of traditional cultural practices by Indian tribes and others • Economic effects of loss of fisheries • Economic effects on development, reduction in property values, or property transferability
• Concern whether all contamination sources have been identified • Increased costs of drinking water treatment, other effects on drinking water, and other water uses • Loss or increased cost of commercial navigation
1-12 Chapter 1: Introduction Existing community involvement and sediment guidance from EPA and the NRC offer some guidelines for involving the community in meeting these and other concerns, as identified in Highlight 1-10.
Highlight 1-10: Community Involvement Guidance and Advice EPA Office of Solid Waste and Emergency Response on Community Involvement (most available at
• Contaminated Sediments: Impacts and Solutions Video and Presenters Manual (U.S. EPA 2005b) • Early and Meaningful Community Involvement (U.S. EPA 2001b) • Superfund Community Involvement Toolkit (U.S. EPA 2003a) • Community Advisory Group Toolkit for EPA Staff (U.S. EPA 1997b) • The Model Plan for Public Participation, National Environmental Justice Advisory Council (U.S. EPA 1996b) • Incorporating Citizen Concerns into Superfund Decision Making (U.S. EPA 2001c) RCRA Community Involvement Guidance (available at http://www.epa.gov/epaoswer/hazwaste/ca/guidance.htm;
see list under “Public Involvement/Communication”):
• RCRA Public Participation Manual • RCRA Expanded Public Participation Rule (60 FR 63417-34) • RCRA Corrective Action Workshop Communication Tools Office of Water on Communication of Fish Consumption Risks and Surveys (available at
• Guidance for Conducting Fish and Wildlife Consumption Surveys (U.S. EPA 1998c) • National Risk Communication Conference Held in Conjunction with the Annual National Forum on Contaminants in Fish (May 6-8, 2001, conference proceedings available at http://www.epa.gov/waterscience/fish/proceedings.html)
National Research Council:
• A Risk-Management Strategy for PCB-Contaminated Sediments, Chapter 4, Community Involvement (NRC 2001) Considering existing EPA guidance, and advice from the NRC and others, the three points below highlight some of the most critical aspects of community involvement at sediment sites.
Point 1. Involve the Community and Other Stakeholders Early and Often In addition to the provisions addressing stakeholder involvement in CERCLA §117 and the NCP, one of EPA’s eleven principles for managing risk of contaminated sediment is to involve the community early and often.
This is an important principle in relation to other stakeholders as well, including local 1-13 Chapter 1: Introduction governments, port authorities, and PRPs. The mission of the Superfund and RCRA community involvement programs is to advocate and strengthen early and meaningful community participation during Superfund cleanups. Planning for community involvement at contaminated sediment sites should begin as early as the site discovery and site assessment phase and continue throughout the entire Superfund process. As noted by the NRC (2001), community involvement will be more effective and more satisfactory to the community if the community is able to participate in or directly contribute to the decision-making process. Passive feedback about decisions already made by others is not what is referred to as community or stakeholder involvement. Early involvement allows necessary input from communities and other stakeholders and facilitates more comprehensive identification of issues and concerns early in the site management process.
Early community involvement enables EPA to learn what stakeholders, especially community members, think are important exposure pathways of the contamination and of potential response options.
Available materials about community involvement in the risk assessment process include A Community Guide to Superfund Risk Assessment – What’s it All about and How Can You Help? (U.S. EPA 1999c).
Although the regulators have the responsibility to make the final cleanup decision at CERCLA and RCRA sites, early and frequent community involvement helps the regulators understand differing views and allows the regulators to factor these views into their decisions.
Point 2. Build an Effective Working Relationship with the Community and Other Stakeholders In addition to the provisions addressing public outreach in CERCLA §117 and the NCP, building partnerships with key community groups, the private sector, and other interested parties is critical to implementing a successful outreach program.
Involving communities by fostering and maintaining relationships can lead to better site decisions and faster cleanups. Referring specifically to PCBcontaminated sites, but with application to all sediment sites, the NRC (2001) report recommended that community involvement at PCB-contaminated sediment sites should include representatives of all those who are potentially at risk due to contamination, although special attention should be given to those most at risk.
Participants at EPA’s 2001 Forum on Managing Contaminated Sediments at Hazardous Waste Sites (U.S. EPA 2001d) offered the following ideas, among others, for building effective working
relationships with communities and other stakeholders at sediment sites:
• Create realistic expectations up front for both public involvement and sediment cleanup;
• Minimize jargon when speaking and writing for the public;
• Use independent facilitators for public meetings when needed;
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A complete list of forum presentation materials is available through EPA’s Superfund Web site at http://www.epa.gov/superfund/resources/sediment/meetings.htm.
Point 3. Provide the Community with the Resources They Need to Participate Effectively in the Decision-Making Process In addition to the provisions addressing public outreach in CERCLA §117 and the NCP, project managers should ensure that community members have access to the tools and information they need to participate throughout the cleanup process.
Educational materials should be accessible, culturally sensitive, relevant, timely, and translated when necessary. One potential resource is a video prepared by EPA’s Superfund office, which explains to communities the general remedial options for sediment (U.S.
Contaminated sediment sites often involve difficult technical issues. It is especially important to give community members opportunities to gain the technical knowledge necessary to become informed participants. Project managers should provide technical information to communities in formats that are accessible and understandable. The EPA has a number of resources available to help make large volumes of complex data more easily understandable. These resources are often valuable communication tools not only with the community, but also within the EPA and between cooperating agencies. An example includes the graphics and scenario analysis capabilities of Region 5 Fully Integrated Environmental Location Decision Support (FIELDS). FIELDS began as an effort to solve contaminated sediment problems more effectively in and around the Great Lakes and is applied in other regions as well.
Information about FIELDS is available at http://www.epa.gov/region5fields.
Information about Superfund community services is available through EPA’s Superfund Web site at http://www.epa.gov/superfund/action/community/index.htm. This Web site provides information on community advisory groups (CAGs), EPA’s Technical Assistance Grant (TAG) program, and the Technical Outreach Services for Communities (TOSC) program. The TOSC program uses university educational and technical resources to help community groups understand the technical issues involving hazardous waste sites in their communities. The Superfund statute provides for only one TAG per site.
At very large sites with diverse community interests, communities may choose to form a coalition and apply for grant funding as one entity. The coalition would need to function as a nonprofit corporation for the purpose of participating in decision making at the site. Individual organizations may choose to appoint representatives to a steering committee that decides how TAG funds should be allocated, and defines the statement of work for the grant. The coalition group may hire a grant administrator to process reimbursement requests to the EPA and to ensure consistent management of the grant. In some cases, EPA regional office award officials may waive a group’s $50,000 limit if site characteristics indicate additional funds are necessary due to the nature or volume of site-related information.
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Chapter 2: Remedial Investigation Considerations
2.0 REMEDIAL INVESTIGATION CONSIDERATIONSThe main purpose of investigating contaminated sediment, as with other media, is generally to determine the nature and extent of contamination to determine if there are unacceptable risks that warrant a response and, if so, to evaluate potential remedies. Investigations may be conducted by a number of different parties under a number of different legal authorities. Most of this chapter presents general information of potential use to any investigator. However, the language and program-specific references are drawn from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) program, and at times, from the Resource Conservation and Recovery Act (RCRA) program.
This chapter is not a comprehensive guide to site characterization and risk assessment of sediment sites, but it does attempt to summarize many of the most important considerations.
Under CERCLA, the investigation process is known as a “remedial investigation” (RI). Under RCRA, the investigation process is known as a “RCRA facility investigation.” The RI process is described in the U.S. Environmental Protection Agency’s (EPA’s) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (U.S. EPA 1988a, also referred to as the “RI/FS Guidance”). The investigative process in a RCRA corrective action is best described in Office of Solid Waste and Emergency Response (OSWER) Directive 9902.3-2A, RCRA Corrective Action Plan (U.S.
EPA 1994a), and the May 1, 1996 Advanced Notice of Proposed Rulemaking [(ANPR) 61 Federal Register (FR) 19447]. This chapter supplements these existing guidances by offering brief sedimentspecific guidance about site characterization, risk assessment, and other investigation issues unique to sediment. More detailed guidance concerning site characterization is beyond the scope of this document, but may be developed as needed in the future.
2.1 SITE CHARACTERIZATION The site characterization process for a contaminated sediment site should allow the project
manager to accomplish the following general goals, at a scale and complexity appropriate to the site:
• Identify and quantify the contaminants present in sediment, surface water, biota, flood plain soils, and in some cases, ground water;
• Identify the sources of historical contamination and quantify any continuing sources;
• Understand the geomorphological setting and processes (e.g., resuspension, transport, deposition, weathering) affecting the stability of sediment;
• Understand the key chemical, and biological processes affecting the fate, transport, and bioavailability of contaminants;
• Collect data necessary to evaluate the potential effectiveness of natural recovery, in-situ capping, sediment removal, and promising innovative technologies; and • Provide a baseline of data that can be used to monitor remedy effectiveness in all appropriate media (generally sediment, water, and biota).
The project manager, in consultation with technical experts and stakeholders, should develop sitespecific investigation goals that are of an appropriate scope and complexity for the site. Systematic planning, dynamic work strategies, and, where appropriate, real-time measurement technologies may be useful at sediment sites. Combined, these three strategies are known as the “triad approach,” described on EPA’s Innovative Technologies Web site at http://www.cluin.org/triad (although the term “triad” is the same, this approach should not be confused with the approach to ecological risk assessment known by the same name). This approach attempts to summarize the best current practices in site characterization to collect the “correct” data, improve confidence in results, and save cost. The triad approach resources also include EPA (2003b), Crumbling (2001), and Lesnick and Crumbling (2001).
Data collection during the remedial investigation frequently has multiple uses, including human health and ecological risk assessment, identification of potential early actions, and remedy decisionmaking. It is important to consult as many data users as possible (e.g., risk assessors, modelers, as well as quality assurance/quality control (QA/QC) experts) early in the scoping process and throughout data collection.
Data should be of a type, quantity, and quality to meet the objectives of the project. The EPA’s data quality objective (DQO) process is one method to achieve this, as described below. Where other agencies (e.g., natural resource trustee agencies, state remediation agencies, and health departments) have an interest at the site, they should be consulted concerning decisions about DQOs so that collected data can serve multiple purposes, if possible. In addition, the community and other stakeholders [e.g., local governments and potentially responsible parties (PRPs)] should be consulted in these decision as appropriate.
2.1.1 Data Quality Objectives
The EPA’s DQO process is intended to help project managers collect data of the right type, quality, and quantity to support site decisions. As described in Guidance for the Data Quality Objective Process (U.S. EPA 2000a), seven steps generally guide the process. The initial steps help assure that only data important to the decisions that need to be made are collected. The seven DQO process steps include
the following, with an example provided in the context of a risk assessment:
2. Identify the decision. Example: Is the exposure causing an unacceptable risk?