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Development of a Regional Guidance Document for Dredged Material Evaluation

Christopher McArthur, P.E. (US Environmental Protection Agency, Region 4 - USA)

Nadia Lombardero (ANAMAR Environmental Consulting, Inc. - USA)

Doug Johnson (US Environmental Protection Agency, Region 4 - USA)

Phil Payonk (US Army Corps of Engineers, Wilmington District - USA)

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Dredged Material: Regulatory History

Marine, Research and Sanctuaries Act (MPRSA)October 23, 1972 – October 23, 2012

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Dredged Material: Regulatory History

Statute: MPRSA (Oct. 23, 1972 )

Regulation: CFR

National Guidance: Green Book

Regional Guidance: RIM

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Need: Why was revision of the RIM important?

• Old Guidance

• Difficult to Follow

• Improve Regional Consistency

• Court Decisions: Existing guidance was found to be inconsistent with the regulations

"The Green Book is merely a guidance document which cannot be given the effect of amending the regulations."

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Need: Why was revision of the RIM important?

Panama Canal

• Outdated Methods

• Improved Detection Limits

• Advances in Scientific Methodology

• More Material Going Offshore:

Post Panamax Expansion

Reduced Upland Capacity

More Applicants

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Challenges to Update

• Working with Old National Guidance

• Working with 5 Districts

• Inconsistency Between Districts

• Balancing Science with Laws, Regulations, and International Agreements

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Solutions: Opportunity to Revamp the Manual

• Drew from Other Regions’ Experiences and Expertise (R1, 2, 9, and 10)

• Sought Recommendations from Private Industry

• Developed a User-Friendly Format

• Created Templates to Help with Standardization

• Created Checklists

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2008 Southeast Regional Implementation Manual (SERIM)

• Clarification of procedures for applying for permits and coordination requirements

• Expanded use of tables, charts, and images to assist the user in following all procedures

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SERIM – SAP/QAPP

• Development of a Sampling and Analysis Plan/Quality Assurance Project Plan (SAP/QAPP) template designed to provide a consistent format for all projects in compliance with EPA’s Quality Assurance Policy. This template is based on EPA Guidance QA/G-5.

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SERIM - Sampling

• Guidance on determining sampling sites, number of samples to be collected, the composting scheme, and the depth of sampling

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SERIM - Sampling

• Guidance on determining sample collection methods, sample integrity, appropriate equipment, and compositing methods

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SERIM – Reference Sites

• Fixed locations for reference sites: Based on studies conducted by EPA Region 4, the SERIM provides recommended reference sites known to be free of sources of contamination and with physical characteristics that can be matched with the dredged material being evaluated.

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SERIM – Physical and Chemical Testing

• Incorporated new analytical technologies that were not available in 1993

• Updated analytical reporting limits

• Updated lists of contaminants of concern

• Introduced clean-up methods

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SERIM - Toxicology

• Expanded information on species and test conditions for toxicological analysis, including performance criteria for the organisms exposed to the reference sediment.

• Greater guidance on bioaccumulation interpretation: The document provides screening levels based on calculated ecological effects thresholds and background tissue concentrations as measured by EPA Region 4 in field studies of coastal waters in the southeastern U.S.

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SERIM – Reporting and Statistics

• Substantial guidance on reporting and statistical analysis, including how to deal with analytes not detected and with outliers

Water and elutriate chemistry data should be reported as µg/L. If analyte concentrations are below the LRL, they should be reported in the summary tables and flagged according to NELAC standards.

Replicate 1 Replicate 2 Replicate 3 Replicate 4 Replicate 5

90% 95% 90% 85% 25%

Normal Distribution in BlueSkewed Distribution in Red

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SERIM - Checklists

• Review checklists to assist in validating results and data quality objectives for applicant and regulators. This includes a detailed checklist for QA/QC requirements for

physical, chemical, and biological analysis.• For Regulators: SAP/QAPP

Checklist and Sediment Testing Report Checklist

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SERIM – Completed

• Beta Testing

• Document Signing

• Training

Winner of EPA’s Bronze Medal

Award!

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SERIM – Results

• Improved Coordination up Front

• Improved Quality Assurance

• More Standard Processes and Formats

• Expedited Reviews

• Improved Efficiency of Document Preparation

• Better Understanding of Program by Regulators and the Regulated Community

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SERIM – Results

• Living Document – Planned Updates:

New guidance on water quality modeling, including how to address material bulking and clumping during the dredging process

Test condition updates

Summation techniques for non-detected compounds

Appropriate digestion procedures

More QA guidance

Elutriate-phase ammonia Toxicity Identification Evaluation (TIE) procedures

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Thanks for Attending our Presentation

QUESTIONS?