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7.0 REMEDY SELECTION CONSIDERATIONS 

TABLE OF CONTENTS 

7.0 REMEDY SELECTION CONSIDERATIONS ......................................... 7-1

7.1 NCP REMEDY SELECTION FRAMEWORK ................................ 7-2

7.2 CONSIDERING CLEANUP METHODS ..................................... 7-2

7.3 CONSIDERING INSTITUTIONAL CONTROLS ............................ 7-12

7.4 CONSIDERING NO-ACTION ............................................ 7-13

7.5 CONCLUSIONS ....................................................... 7-14

HIGHLIGHTS 

Highlight 7-1: NCP Remedy Expectations and Their Application to Contaminated Sediment ........ 7-3

Highlight 7-2: Site Conditions Generally Consistent with Selection of Common Sediment Cleanup

Methods .................................................................... 7-4

Highlight 7-3: Examples of Some Key Differences Between Sediment Cleanup Methods .......... 7-6
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Chapter 7: Remedy Selection Considerations 

7.0 REMEDY SELECTION CONSIDERATIONS 

“No two sites are identical and therefore the risk-management strategy will vary from site 

to site...The strategy selected should be one that actually reduces overall risk, not merely 

transfers the risk to another site or another affected population. The decision process 

necessary to arrive at an optimal management strategy is complex and likely to involve 

numerous site-specific considerations.” 

“Management decisions must be made, even when information is imperfect. There are 

uncertainties associated with every decision that need to be weighed, evaluated, and 

communicated to affected parties. Imperfect knowledge must not become an excuse for 

not making a decision.” 

In these two statements from the National Research Council’s (NRC’s) A Risk Management 

Strategy for PCB-Contaminated Sediments report (NRC 2001), the NRC identifies some of the key 

challenges faced by project managers of many sites at the remedy selection stage. The goal of the 

Superfund remedy selection process is to select remedies that are protective of human health and the 

environment, that maintain protection over time, and that minimize untreated waste (NCP 

§300.430(a)(1)). However, the best route to overall risk reduction depends on a large number of sitespecific considerations, some of which may be subject to significant uncertainty. This guidance has 

attempted to address many of those considerations and uncertainties, in the context of the Superfund 

program’s implementing regulation, the National Oil and Hazardous Substances Pollution Contingency 

Plan (NCP). 

Each of the risk management principles in the U.S. Environmental Protection Agency’s (EPA’s) 

Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites [included in this 

guidance as Appendix A, (U.S. EPA 2002a)] is important to consider for achieving a successful sediment 

cleanup. Several of the principles apply more directly to the remedy selection stage, especially Principle 

7: “Select site-specific, project-specific, and sediment-specific risk management approaches that will 

achieve risk-based goals.” Any decision regarding the specific choice of a risk management strategy for 

contaminated sediment should be based on careful consideration of the advantages and disadvantages of 

available options and a balancing of tradeoffs among alternatives. This and other risk management 

principles which apply at the remedy selection stage are discussed further in section 7.5, Conclusions. 

EPA’s Rules of Thumb for Superfund Remedy Selection (U.S. EPA 1997d) is another helpful 

guidance for project managers to review when selecting remedies at sediment sites. The Rules of Thumb 

guidance describes key principles and expectations, interspersed with “best practices” based on program 

experience and policies. This guidance also discusses how remedy selection may also be applicable to the 

Resource Conservation and Recovery Act (RCRA) Corrective Action Program. For more information the 

project manager should see OSWER Directive 9200.0-25 Coordination Between RCRA Corrective Action 

and Closure and CERCLA Site Activities (U.S. EPA 1996g). 

Documenting and communicating how and why remedy decisions are made are very important at 

sediment sites. For guidance on documenting remedy decisions under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) project managers should refer to EPA’s A Guide 

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Chapter 7: Remedy Selection Considerations 

to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection Documents, 

also referred to as the “ROD Guidance” (U.S. EPA 1999a). 

7.1 NCP REMEDY SELECTION FRAMEWORK 

In the NCP, EPA establishes a series of expectations (see Highlight 7-1) to reflect the principal 

requirements of CERCLA §121 and to help focus the remedial investigation/feasibility study (RI/FS) on 

appropriate cleanup options. EPA also developed nine criteria for evaluating remedial alternatives to 

ensure that all important considerations are factored into remedy selection decisions. Chapter 3, 

Feasibility Study Considerations, outlines the NCP’s nine remedy selection criteria in section 3.2. These 

criteria are derived from the statutory requirements of Section 121, as well as technical and policy 

considerations that have proven to be important for selecting among remedial alternatives. The nine 

criteria analysis comprises two steps: 1) an evaluation of each alternative with respect to each criterion; 

and 2) a comparison among the alternatives to determine the relative performance of the alternatives and 

identify major trade-offs among them (i.e., relative advantages and disadvantages). Ultimately, the 

remedy selected must be protective of human health and the environment, attain (or waive) applicable or 

relevant and appropriate requirements (ARARs), be cost effective, utilize permanent solutions and 

alternative treatment technologies or resource recovery technologies to the maximum extent practicable, 

and satisfy a preference for treatment or provide an explanation as to why this preference was not met. 

Cost effectiveness is determined by comparing an alternative’s cost to its effectiveness as 

determined by the following: 1) its long-term effectiveness and permanence; 2) its ability to reduce 

toxicity, mobility, or volume of hazardous substances, pollutants or contaminants through treatment; and 

3) its short-term effectiveness (U.S. EPA 1999a). A remedy is considered cost effective when its cost is 

proportional to its overall effectiveness as demonstrated though a comparison among alternatives. It is 

important to note that more than one alternative can be cost effective, and that the Superfund program 

does not mandate the selection of the most cost-effective alternative, or the least-costly alternative that is 

also cost effective. The evaluation of an alternative’s cost effectiveness is concerned only with the 

reasonableness of the relationship between the effectiveness afforded by each alternative and its costs 

when compared to other available options. 

Highlight 7-1 discusses how the six NCP remedy selection expectations (NCP 

§300.430(a)(1)(iii)) may be relevant for sites with contaminated sediments. Generally, the expectations 

are addressed by selecting the alternative that provides the best balance of trade-offs among the 

alternatives evaluated. 

7.2 CONSIDERING CLEANUP METHODS 

If the baseline risk assessment indicates that contaminated sediment threatens (or may threaten) 

human health or the environment, remedial alternatives should be developed to eliminate, reduce, or 

manage those threats. In considering the range of alternatives to develop during the FS, the project 

manager should explore the most promising or likely cleanup methods given site-specific characteristics 

or conditions. As discussed in Chapter 3, section 3.1, Developing Sediment Alternatives, due to the 

limited number of cleanup methods available for contaminated sediment, generally, project managers 

should evaluate each of the three major cleanup methods: monitored natural recovery (MNR), in-situ 

capping, and removal through dredging or excavation, at every sediment site at 

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Chapter 7: Remedy Selection Considerations 

Highlight 7-1: NCP Remedy Expectations and Their Application to Contaminated Sediment 

The EPA expects to use treatment to address the principal threats posed by a site, wherever practicable: 

• Contaminated sediment is frequently a source material and subject to this expectation regarding principal 

threat waste. definition of principal threat waste. 

should evaluate an alternative which includes treatment where toxicity and mobility combine to pose a 

potential human health risk of 10-3 or greater for carcinogens (U.S. EPA 1991e). ever, the 

practicability of treatment, and whether a treatment alternative should be selected, should be evaluated 

against the NCP nine remedy selection criteria 

The EPA expects to use engineering controls, such as containment, for waste that poses a relatively low long-term 

threat or where treatment is impracticable: 

• Containment options for sediment generally focus on in-situ capping. Where possible, a project manager 

should evaluate in-situ capping, or other engineering controls, for every sediment site that includes lowlevel threat waste. here an in-situ capping alternative is clearly not appropriate, project managers 

should consider ex-situ containment. here monitored natural recovery is expected to be achieved 

through burial with clean sediment, it may also be considered a containment option 

See EPA (1991e) for In general, project managers 

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The EPA expects to use a combination of methods, as appropriate, to achieve protection of human health and the 

environment: 

• Large or complex contaminated sediment sites or operable units frequently require development of 

alternatives which combine various cleanup methods for different parts of the site. For a broader 

discussion on this topic, refer to Chapter 3, section 3.1.1, Alternatives That Combine Cleanup Methods 

The EPA expects to use institutional controls such as water use and deed restrictions to supplement engineering 

controls as appropriate for short- and long-term management to prevent or limit exposure to hazardous 

substances, pollutants, or contaminants: 

• Institutional controls such as fish consumption advisories, fishing bans, ship draft/anchoring/ wake 

controls, or structural maintenance requirements are frequently necessary as part of sediment 

alternatives, especially where contaminated sediment is left in place, or where remedial objectives in fish 

tissue cannot be met for some time. See Chapter 3, section 3.5, Institutional Controls, for additional 

discussion 

The EPA expects to consider using innovative technology when such technology offers the potential for 

comparable or superior treatment performance or implementability, fewer or lesser adverse impacts than other 

available approaches, or lower costs for similar levels of performance than demonstrated technologies: 

• Innovative technologies are technologies whose limited number of applications result in a lack of cost and 

performance data, frequently due to limited field application. onal cost and performance data are 

needed for many sediment remedies and field demonstrations of new techniques and approaches are 

especially welcome, including both innovative in-situ and ex-situ treatment technologies and innovative 

technologies applied to in-situ capping or enhancements to natural recovery 

The EPA expects to return reusable ground waters to their beneficial uses wherever practicable, within a time 

frame that is reasonable given the circumstances for the site. hen restoration of ground water to beneficial uses 

is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated 

ground water, and evaluate further risk reduction: 

• Ground water may be a continuing source of sediment and water contamination. here this is the case, 

ground water restoration and migration prevention may be very important to a successful sediment 

cleanup 

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Chapter 7: Remedy Selection Considerations 

which they may be appropriate. Depending on site-specific conditions, contaminant characteristics, 

and/or health or environmental risks at issue, certain methods or combinations of methods may prove 

more promising than others. In reality, each site and the various sediment areas within it presents a 

unique combination of circumstances that should be considered carefully in selecting a comprehensive 

site-wide cleanup strategy. At large or complex sediment sites, the remedy decision frequently involves 

not a simple choice between cleanup methods but a choice between what areas of the site are best suited 

to a particular method. 

To assist project managers in evaluating cleanup options two highlights are presented below. 

Highlight 7-2 provides general site, risk and contaminant characteristics that are generally consistent with 

each of the three common sediment cleanup methods. Highlight 7-3 lists key differences between the 

cleanup methods. 

The site characteristics in Highlight 7-2 are intended as a general tool to suggest that project 

managers look more closely at particular methods when these characteristics are present. They are not 

requirements or expectations for the use of the three cleanup methods. It is important to remain flexible 

when evaluating sediment alternatives and consider cleanup methods which may not at first appear ideal 

for a given environment. When a cleanup method is selected for which some site characteristic is not 

ideal, additional engineering or institutional controls may be available to enhance the remedy. Some of 

these situations are discussed in the remedy-specific chapters (Chapters 4, 5, and 6). 

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Highlight 7-2: Site Conditions Generally Consistent with Selection of Common Sediment 

Cleanup Methods 

Characteristics Monitored Natural 

Recovery 

In-situ Capping Dredging/Excavation 

General Site 

Characteristics 

Low rates of fish/shellfish 

consumption. 

Critical resources not 

likely to be impacted if 

some contaminants 

released if sediment bed 

disturbed. 

Stable land uses in 

watershed; no plans for 

upstream structures which 

would trap sediment. 

Source control achieved 

or well underway. 

Nearby source of suitable 

cap material, of sufficient 

quantity for area of 

contamination. 

High rates of fish/shellfish 

consumption, such as 

subsistence fishing 

community. 

Critical resources not 

likely to be impacted if 

some contaminants 

released if cap disturbed. 

Source control achieved 

or well underway. 

Nearby disposal site for 

dredged material. 

Available area for staging and 

handling of dredged material. 

High rates of fish/shellfish 

consumption, such as 

subsistence fishing 

community. 

Navigational dredging 

required. 

Source control achieved or 

well underway. 

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Characteristics Monitored Natural 

Recovery 

In-situ Capping Dredging/Excavation 

General 

Physical/Chemical 

Environment 

Consistent sediment 

deposition with high rate 

of burial. 

Low probability of 

contaminant dispersal to 

sensitive environment 

without active remedy. 

Reducing environment for 

metals contamination. 

Low rates of ground water 

influx that may increase 

contaminant migration 

through clean sediment. 

Shallow slopes and 

relatively level bottom 

topography. 

Sufficient post-capping 

water depth to maintain 

flow capacity during floods 

or necessary navigational 

depths. 

Low rates of ground water 

influx that may increase 

contaminant migration 

through cap. 

Insufficient or inconsistent 

rates of natural burial. 

Contaminated sediment 

underlain by clean soft 

sediment rather than hardpan 

or bedrock (to facilitate overdredging). 

Few piers, pilings, or other 

structures to impede 

maneuverability. 

High probability of 

contaminant dispersal to 

sensitive environment without 

removal. 

General Ecological 

Environment 

Sensitive, unique 

environment which should 

not be disturbed by an 

active cleanup. 

Ecological community 

recolonizes cap or 

relocates to neighboring 

areas. 

Ecological community 

recolonizes dredged area or 

relocates to neighboring 

areas. 

Hydrodynamic 

Conditions 

Consistently stable 

sediment bed over long 

periods, including low 

incidence of natural 

sediment disruptive 

events and sedimentdisruptive human activity. 

Low enough incidence of 

natural disruptive events 

for practical design and 

maintenance of cap. 

Low or controllable 

incidence of capdisruptive human 

behavior, such as large 

boat anchoring. 

Water diversion practical, or 

current velocity low or can be 

minimized to reduce 

resuspension and downstream 

transport during dredging. 

Where near-water disposal is 

used, low enough incidence of 

natural disruptive events for 

practical design and 

maintenance of disposal site. 

Sediment 

Characteristics 

Highly cohesive or wellarmored sediment. Sufficient shear strength 

to support cap. 

High density/low water 

content sediment. 

Low incidence of debris, logs, 

or boulders, or effective 

removal prior to dredging or 

excavation. 

Contaminant 

Characteristics 

High rates of 

biodegradation or 

transformation to lower 

toxicity forms. 

Low contaminant 

concentrations covering 

diffuse areas. 

Low ability to 

bioaccumulate. 

Contaminants with low 

rates of flux through cap. 

Contamination covers 

contiguous areas. 

High contaminant 

concentrations covering 

discrete areas. 

Contaminants highly 

correlated with sediment grain 

size (to facilitate separation 

and minimize treatment costs). 

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Chapter 7: Remedy Selection Considerations 

Some of the key differences between cleanup methods are presented in Highlight 7-3. For 

convenience these comparisons are organized around the NCP’s nine remedy selection criteria. This 

highlight is intended to only identify some of the general differences between these three remedy types, 

not as an example of an actual comparative alternatives analysis for a site. An actual site alternatives 

analysis would typically include more complex alternatives and many site-specific details, as described in 

A Guide to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection 

Decision Documents, also referred to as the “ROD Guidance,” (U.S. EPA 1999a) and Guidance for 

Conducting Remedial Investigations and Feasibility Studies under CERCLA, also referred to as the 

“RI/FS Guidance” (U.S. EPA 1988a). The example criterion components used in Highlight 7-3 below are 

taken from the RI/FS Guidance and are intended as only examples of some of the components that may be 

considered when evaluating that remedy selection criterion. 

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Highlight 7-3: Examples of Some Key Differences Between Sediment Cleanup Methods 

NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Overall 

Protectiveness 

Relies upon natural 

processes for protection. 

Low level of short-term 

protection, but 

potentially adequate 

long-term protection. 

Relies upon adequate 

cap placement and 

maintenance for 

protection. 

Moderate to high level of 

protection, depending 

upon areal extent of cap. 

Relies upon effective 

removal and low residual 

levels for protection. 

Moderate to high level of 

protection, depending on 

residual. not be as 

protective in the short term 

as capping (due to 

residuals) but potentially 

high long-term protection. 

Compliance 

with 

Applicable 

or Relevant 

and 

Appropriate 

Requirements

(ARARs)

Generally, only

chemical-specific

ARARs apply (these

would also apply to other

cleanup methods).

Generally, the Clean

Water Act (CWA) §404

(regulates discharge of

dredged or fill materials

into waters of the U.S.)

and the Rivers and

Harbors Act (prohibits

obstruction or alteration

of a navigable waterway)

are ARARs.

Generally, CWA §404 and

the Rivers and Harbors Act

are ARARs.

Generally, treatment

facilities and in-water

disposal sites should meet

substantive requirements of

the CWA §§404 and 401 for

discharge of effluents into

waters of the U.S. 

Generally, RCRA is an

ARAR for disposal in solid

or hazardous waste

landfills.

For polychlorinated biphenyl

(PCB) sites, the Toxic

Substances Control Act

(TSCA) may be an ARAR.

May

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Chapter 7: Remedy Selection Considerations 

NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Long-Term 

Effectiveness and 

Permanence 

Long-Term 

Effectiveness 

and 

Magnitude of 

Residual 

Risks 

Low to high long-term 

effectiveness and 

residual risk, depending 

on processes being 

relied upon (e.g., burial 

or degradation). 

Moderate to high longterm effectiveness and 

generally low to moderate 

residual risk, depending 

on cap design, 

placement, construction, 

and maintenance to 

address site 

characteristics that might 

otherwise prevent longterm isolation of 

contaminants. 

Moderate to high long-term 

effectiveness and low to 

moderate residual risk, 

depending on amount of 

residual contamination. 

Low (upland) to moderate 

(in-water) residual risk for 

sediments and treatment 

residuals contained at 

controlled disposal sites. 

Permanence 

and 

Adequacy 

and 

Reliability of 

Controls for 

Residual Risk 

Low (except in case of 

degradation or dilution), 

but potentially adequate, 

permanence. 

ability to control physical 

disturbance due to 

human activity via 

institutional controls 

(ICs); little ability to 

control physical 

disturbance due to 

natural forces. 

Little to no ability to 

control advection and 

diffusion of 

contaminants through 

overlying cleaner 

sediment, where this is 

of concern. 

Moderate 

Moderate to high 

permanence, depending 

on cap stability and 

contaminant migration 

through cap. 

Low to moderate ability to 

control physical 

disturbance due to 

human and natural forces 

through cap design and 

moderate ability to control 

disruption through 

institutional controls. 

Some ability to control 

effects of advective flow 

and diffusion rates 

through cap design. 

Need for FiveYear Reviews 

Perpetual review 

required for most sites 

due to waste left in place 

and possible continuing 

need for use restrictions. 

Perpetual review required 

for most sites due to 

waste left in place and 

possible continuing need 

for use restrictions. 

Highly permanent due to 

removal of contaminants. 

Control of residual risk from 

contaminants remaining in 

place is similar to MNR. 

Residual risks at upland 

disposal sites easily 

controlled; at in-water sites 

control can be more 

complex. 

Review generally required 

for dredged site until 

cleanup levels and remedial 

action objectives are met 

and site is available for 

unrestricted use. 

Perpetual review generally 

required for on-site disposal 

facilities. 

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Chapter 7: Remedy Selection Considerations 

NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Reduction of 

Toxicity, 

Mobility, and 

Volume 

(TMV) 

Through 

Treatment 

No treatment is involved. Presently no treatment is 

involved. 

Future potential for 

combining innovative 

treatment components 

within an in-situ cap. 

Sediment can be treated if 

cost-effective; stabilization 

is most common form. 

Future potential for 

innovative treatment and reuse of dredged materials. 

Water treatment can reduce 

TMV of contaminants where 

significant quantities of 

toxics are removed from the 

water. 

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Environmental 

Impacts 

During 

Remedy 

Implementation 

Impacts to environment 

continue but gradually 

decline until protection is 

achieved. 

Bottom-dwelling 

ecological community 

left intact, although may 

be impaired. 

Time Until 

Protection is 

Achieved 

Generally, longest time 

to achieve protection, 

depending on rates of 

natural processes and 

bio-availability of the 

contaminants. 

Time to achieve 

protection is frequently 

highly uncertain. 

NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Short-Term 

Effectiveness 

Community 

and Worker 

Protection 

During 

Remedy 

Implementation 

Impacts to community 

continue but gradually 

decline until protection is 

achieved. 

Moderate ability to 

control impacts from 

fish/shellfish ingestion 

and, where applicable, 

direct contact with 

contaminated sediment, 

through ICs. 

Minimal impacts on 

workers from monitoring 

activities. 

Low potential for impacts 

to community and 

workers from contaminant 

releases during cap 

placement; engineering 

controls may minimize 

these releases; worker 

protection generally 

available. 

Increased truck or rail 

traffic for transport of cap 

material may impact 

workers and the 

community. 

Low to moderate potential 

for impacts to community 

and workers from 

contaminant release during 

dredging, transport, and 

disposal; engineering 

controls may minimize 

these releases; worker 

protection generally 

available. 

Increased truck or rail traffic 

for transport of dredged 

material may impact 

workers and the community. 

Low potential for impacts 

from releases to the 

environment during cap 

placement and initial 

consolidation; impact of 

aquatic releases partially 

controllable through 

equipment selection and 

placement techniques. 

Majority of bottomdwelling ecological 

community smothered; 

potential for recolonization variable. 

Cap design can facilitate 

re-colonization in some 

cases. 

Generally, shortest time 

to achieve protection, 

although biota recovery 

may still take several 

years. 

Low to moderate potential 

impacts to environment 

during dredging; releases 

partially controllable by 

physical barriers and by 

selection and operation of 

dredging equipment. 

Majority of bottom-dwelling 

ecological community 

removed; potential for recolonization variable. 

Backfill design can facilitate 

re-colonization in some 

cases. 

Time to achieve protection 

varies significantly 

depending on the size and 

complexity of the project. 

Time frame generally more 

uncertain than for capping 

due to unknown extent of 

residual contamination. 

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NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Implementability Technical 

Feasibility 

Generally, no 

construction is required. 

Reliability can be 

uncertain in some 

environments due to 

uncertain rates of 

natural processes and 

uncertainties concerning 

sediment stability. 

Relatively easy to 

implement a different 

remedy in case of 

remedy failure. 

Methods for monitoring 

sediment cleanup levels 

are relatively wellestablished, although 

certain natural 

processes themselves 

can be difficult to 

monitor directly. 

Cap placement methods 

are generally wellestablished; 

constructability depends 

mainly on water depth 

and currents, slope and 

geotechnical stability of 

underlying materials, and 

stability of the cap itself 

during and after 

construction. 

Reliability generally high, 

depending on 

environment and degree 

of monitoring and 

maintenance 

Relatively easy to repair 

cap in case of remedy 

failure, but relatively 

difficult to implement a 

different remedy. 

Methods for monitoring 

cap itself are relatively 

well-established, although 

certain processes, such 

as through-cap advective 

flow, can be difficult to 

monitor directly. 

Dredging and excavation 

methods are generally wellestablished; technical 

feasibility of dredging 

depends mainly on 

accessibility, extent of 

obstructions, and the ability 

to over-dredge. 

Disposal in upland landfills 

is well-established; in-water 

disposal methods are less 

well-established and require 

greater monitoring; 

technical feasibility 

generally depends on slope 

and geotechnical stability of 

disposal site, distance to 

the disposal site, and ease 

of dewatering. 

Reliability higher for 

excavation than dredging; 

reliability of dredging 

depends on environment 

and skill of equipment 

operators. 

Transport of sediment to 

disposal site may present 

costly technical/and or 

administrative challenges. 

Relatively easy to re-dredge 

or implement a different 

remedy in case of remedy 

failure. 

Monitoring methods for 

sediment cleanup levels 

and short-term releases 

from dredging are relatively 

well-established. 

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NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

Administrative 

Feasibility 

State-regulated ICs, 

including fish 

consumption advisories, 

are frequently needed 

for a longer period than 

for other remedies. 

Containment in public 

waters can require longterm coordination with 

state and local regulators 

due to potential need for 

permanent controls on 

waterway use. 

Dredging and excavation 

plan should be coordinated 

with other agencies to 

ensure compatibility with 

other waterway uses and 

habitat concerns during the 

removal operation. 

Disposal siting often 

requires intensive 

coordination with several 

government agencies and 

the public. 

Availability of 

Services, 

Materials, 

Capacities, 

and 

Equipment 

Monitoring and analytical 

services are generally 

readily available. 

Location and suitability of 

capping material source 

is critical and can be 

problematic. 

Specialized cap 

placement equipment 

may be needed in some 

environments, but are 

generally available. 

Environmental dredging and 

excavation equipment is 

generally available, 

although availability may be 

a problem for large projects 

and specialized equipment 

may need to be constructed 

for special situations. 

Availability of a suitable 

disposal facility with 

adequate capacity is critical 

and can be problematic. 

Cost Generally, no capital 

cost. 

Operation and 

maintenance (O&M) 

costs (e.g., monitoring) 

generally continue in 

perpetuity. 

Capital costs generally 

higher than MNR and 

lower than dredging or 

excavation. 

O&M costs generally 

higher than MNR and 

dredging/excavation and 

generally continue in 

perpetuity. 

Capital costs generally 

higher than MNR or 

capping. 

O&M costs generally higher 

than MNR and less than 

capping; O&M period 

limited unless on-site 

disposal is used. 

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7 7.3 CONSIDERING INSTITUTIONAL CONTROLS 

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9 Institutional controls such as fish consumption advisories, fishing bans, ship

10 draft/anchoring/wake controls, or structural maintenance requirements, are common parts of sediment

11 remedies (see Chapter 3, section 3.5, Institutional Controls). NCP §300.430(a)(1)(iii)(D) contains the

12 following general EPA expectations with respect to ICs. These expectations generally apply to all

13 Superfund sites, including sediment sites:

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15 • EPA expects to use institutional controls such as water use and deed restrictions

16 to supplement engineering controls as appropriate for short- and long-term

17 management to prevent or limit exposure to hazardous substances, pollutants, or

18 contaminants;

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20 • Institutional controls may be used during the conduct of the RI/FS and

21 implementation of the remedial action and, where necessary, as a component of

22 the completed remedy; and

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24 • The use of institutional controls shall not be substituted for active response

25 measures (e.g., treatment and/or containment of source material, restoration of

NCP 

Remedy 

Selection 

Criteria 

Example 

Criterion 

Components 

Monitored Natural 

Recovery In-Situ Capping Dredging/Excavation 

State 

Acceptance 

and 

Community 

Acceptance 

Commonly identified 

benefits include lack of 

disruption to local 

residents, lack of 

disruption to aquatic and 

terrestrial animal and 

plant life, and low cost. 

Commonly identified 

concerns include leaving 

contamination in place, 

possible spread of 

contaminants during 

flooding or other 

disruption; uncertainties 

of predicting burial rates; 

and a potentially lengthy 

period of fishing bans or 

fish consumption 

advisories. 

Commonly identified 

benefits include use of an 

active remedy with no 

disposal issues, generally 

moderate cost, and 

potentially faster biota 

recovery due to relatively 

rapid placement of 

exposure barrier. 

Commonly identified 

concerns include leaving 

contamination in place, 

disruption to local 

residents and 

businesses, increased 

truck, rail or barge traffic, 

recreational and 

navigational waterway 

access, access to buried 

utilities, possible longterm anchoring or other 

waterway use restrictions, 

and a period of fishing 

bans or fish consumption 

advisories. 

Commonly identified 

benefits include removing 

contaminants from 

waterway, possible 

treatment of contaminants, 

potentially faster biota 

recovery, and 

increased/restored 

navigational depth, 

decreased flooding, and 

lack of use limitations 

completion. 

Commonly identified 

concerns include disruption 

to local residents and 

businesses, releases during 

dredging, recreational and 

navigational waterway 

access during dredging, 

siting of and risks from local 

disposal facilities, increased 

truck, rail, or barge traffic, 

and a period of fishing bans 

or fish consumption 

advisories. 

after 

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ground waters to their beneficial uses) as the sole remedy unless such active 

measures are determined not to be practicable, based on the balancing of tradeoffs among alternatives that is conducted during the selection of remedy. 

EPA policies concerning ICs are explained in Institutional Controls: A Site Manager’s Guide to 

Identifying, Evaluating, and Selecting Institutional Controls at Superfund and RCRA Corrective Action 

Cleanups (U.S. EPA 2000c). In addition to considering the NCP expectations concerning ICs, the project 

manager should determine what entities possess the legal authority, capability and willingness to 

implement, and where applicable, monitor, enforce, and report on the status of the IC. An evaluation 

should also be made of the durability and effectiveness of any proposed IC. The objectives of any ICs 

contained in the selected alternative should be clearly stated in the ROD or other decision document 

together with any relevant performance standards. While the specific IC mechanism need not be 

identified, the types of ICs envisioned should be discussed in sufficient detail to support a conclusion that 

effective implementation of the ICs can reasonably be expected. 

Reliability and effectiveness of ICs are of particular concern with sediment alternatives, whether 

they are used alone or in combination with monitored natural recovery, in-situ capping, or sediment 

removal. Project managers should recognize that ICs generally cannot protect ecological receptors, or 

prevent disruption of an in-situ cap by bottom-dwelling organisms. In addition, in many cases ICs have 

been only partially effective in modifying human behavior, especially in the case of voluntary or advisory 

controls. Although fish consumption advisories can be an important component of a sediment remedy, it 

should be recognized that they may not be entirely effective in eliminating exposures. Where advisories 

or bans are relied upon to reduce human health risk for long periods, public education, and where 

applicable, enforcement by the appropriate agency, are critical. This point is emphasized in Principle 9 of 

EPA’s risk management principles for sediment: “Maximize the effectiveness of institutional controls and 

recognize their limitations” (U.S. EPA 2002a). 

Implementing and overseeing ICs can often be more difficult at sediment sites where control of 

the waterbody may involve multiple entities and a single landowner is not present to provide oversight 

and enforcement. If a waterbody is privately owned, the landowner may not be in a position to prevent 

disruptions, such as grounding of vessels or anchor drag, even if ICs are in place. Where a waterbody is 

owned or controlled by local, state, or federal government entities, their regulations and guidance should 

be consulted to determine what governmental controls can be used to restrict the use of the waterbody, 

and the regulatory or administrative process to enforce such a restriction. In complex situations it may be 

useful to layer a number of different ICs as discussed in Institutional Controls: A Site Manager’s Guide to 

Identifying, Evaluating, and Selecting Institutional Controls at Superfund and RCRA Corrective Action 

Cleanups (U.S. EPA 2000c). 

7.4 CONSIDERING NO-ACTION 

Selecting a “no-action” remedy is appropriate when no engineering controls (e.g., in-situ cap, 

dredging or excavation), ICs, or treatment are warranted at a site or a portion of a site. The ROD 

Guidance indicates that a no-action remedy may be appropriate in the following situations: 

• When the site or operable unit poses no current or potential threat to human health or the 

environment; 

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• When CERCLA does not provide the authority to take remedial action; or 

• When a previous response(s) has eliminated the need for further remedial response [often 

called a “no-further action” alternative]. 

Generally, if ICs are necessary to control risks caused by a contaminant of concern at a site, a noaction remedy is not appropriate. For example, if fish consumption advisories or fishing bans are 

necessary to control risks from contaminants of concern at a site, a no-action remedy for sediment is not 

appropriate, even if the advisories or bans are already in place. Instead, a remedy should be considered 

that includes at least the institutional control (e.g., advisories or bans), and, if appropriate, other actions 

for sediment or other media. 

A no-action ROD may however include monitoring. For example, sediment may pose no current 

or potential threat to human health or the environment; however, uncertainties concerning that evaluation 

make it wise to continue some level of monitoring. In this case, a no-action ROD that includes 

monitoring may be an appropriate remedy. It is important to note that this is different from a MNR 

remedy where current or expected future risk is unacceptable and natural processes are being relied upon 

to reduce that risk to an acceptable level within a reasonable time frame. Although a no-action remedy 

may require long-term monitoring, a MNR remedy generally needs more intensive monitoring to show 

that contaminant concentrations are being reduced by anticipated mechanisms at the predicted rates. 

7.5 CONCLUSIONS 

The focus of remedy selection should be on selecting the alternative which represents the best 

overall risk reduction strategy for the site according to the NCP nine remedy selection criteria. As 

discussed in the OSWER Directive 9285.6-08 Principles for Managing Contaminated Sediment Risks at 

Hazardous Waste Sites (U.S. EPA 2002a), the EPA’s policy has been and continues to be that there is no 

presumptive remedy for any contaminated sediment site, regardless of the contaminant or level of risk. 

Generally, as discussed in Chapter 3, Feasibility Study Considerations, project managers should consider 

each of the three major cleanup methods (i.e., monitored natural recovery, in-situ capping, and removal 

through dredging or excavation) at every sediment site where they may be appropriate. 

Controlling any continuing sources of contaminants is an important component of any sediment 

remedy (U.S. EPA 2002a). Where source control is uncertain or cannot be achieved, project managers 

should consider the potential for re-contamination and factor that potential into the remedy selection 

process. However, project managers should note that delaying an action to complete source control may 

not always be wise. Early actions in some areas may be appropriate as part of a phased approach to 

address site-wide contamination even if sources are not fully controlled initially. 

At many sites, but especially at large sites, the project manager should consider a combination of 

sediment cleanup methods as the most effective way to manage the risk. This is because the 

characteristics of the contaminated sediment and the settings in which it exists, are not usually 

homogeneous throughout a waterbody (NRC 2001). As discussed in the remedy-specific chapters of this 

guidance, when evaluating alternatives, project managers should include realistic assumptions concerning 

residuals and contaminant releases from in-situ and ex-situ remedies, the potential effects of those 

residuals and releases, and the length of time a risk may persist. In addition to considering the impacts of 

each alternative on human health and ecological risks, the project manager should assess the societal and 

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cultural impacts of each alternative on the community and the opportunities for site reuse and 

redevelopment. 

The project manager should include a scientific analysis of sediment stability in the remedy 

selection process for all sites where sediment disturbance is a potential concern. Typically, it is not 

sufficient to assume that a site as a whole is stable or unstable. Generally, as discussed in Chapter 2, 

Remedial Investigation Considerations, project managers should make use of available empirical methods 

for evaluating sediment stability, especially when there are significant differences between alternatives. 

At large or complex sites, and sites with limited historical data, project managers may also consider using 

a numerical model for evaluating events where no field records are available and for predicting future 

stability. 

The project manager should include in the remedy selection process a clear understanding of the 

uncertainties involved, including uncertainties concerning the predicted effectiveness of various 

alternatives and the time frames for achieving remedial goals in the remedy selection process. Project 

managers should quantify, as far as possible, the uncertainty of important factors in the remedy decision. 

Where it is not possible to quantify uncertainty, the project manager should use a sensitivity analysis to 

determine which apparent differences between alternatives are most likely to be significant. 

The project manager should monitor all sediment remedies during and after implementation to 

determine if the actions are effective and if all remedial goals are met. Sediment remedies should not 

only include monitoring of surficial sediment immediately following implementation of the action, but 

also include long-term monitoring of sediment to assess movement of residuals and possible recontamination, and monitoring of fish or other relevant biota recovery. Without these data, an assessment 

of the long-term effectiveness of the remedy is difficult. Additional monitoring data helps not only to 

assess the site, but also helps project managers determine the future conditions and practices that lead to 

the least impacts in the short term and most effective sediment remedies in the long term. Chapter 8, 

Remedial Action and Long-Term Monitoring, discusses these and other general monitoring 

considerations for sediment sites. 

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1 8.0 REMEDIAL ACTION AND LONG-TERM MONITORING 

2

3 TABLE OF CONTENTS

4

5 8.0 REMEDIAL ACTION AND LONG-TERM MONITORING ........................... 8-1

6 8.1 INTRODUCTION ....................................................... 8-1

7 8.2 KEY ELEMENTS FOR SEDIMENT SITE MONITORING ...................... 8-3

8 8.3 POTENTIAL MONITORING TECHNIQUES ................................. 8-8

9 8.3.1 Physical Measurements ........................................... 8-9

10 8.3.2 Chemical Measurements ......................................... 8-10

11 8.3.3 Biological Measurements ......................................... 8-11

12 8.4 REMEDY-SPECIFIC MONITORING APPROACHES ......................... 8-11

13 8.4.1 Monitoring Natural Recovery ..................................... 8-11

14 8.4.2 Monitoring In-Situ Capping ....................................... 8-13

15 8.4.3 Monitoring Dredging or Excavation ................................ 8-16

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17 HIGHLIGHTS

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19 Highlight 8-1: Outline of Key Elements for Sediment Site Monitoring ......................... 8-7

20 Highlight 8-2: Example Cap Monitoring Phases and Elements ............................... 8-14

21 Highlight 8-3: Points to Remember About Monitoring Sediment Sites ........................ 8-19

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Chapter 8: Remedial Action and Long-Term Monitoring 

8.0 REMEDIAL ACTION AND LONG-TERM MONITORING 

This chapter provides an approach to developing an effective monitoring program at 

contaminated sediment sites. A monitoring program is recommended for all types of sediment remedies, 

both during the remedial action phase and over the long term [i.e., during the operation and maintenance 

(O&M) phase] to ensure that all sediment risk and exposure pathways at a site have been and continue to 

be adequately managed by the remedy. The goals of this chapter are the following: 

• To provide a consistent definition of monitoring for this guidance and identify some of 

the complexities associated with monitoring at contaminated sediment sites; 

• To present the key elements of a contaminated sediment site monitoring program; 

• To introduce some of the monitoring techniques available for physical, chemical, and 

biological measurements; and 

• To present some of the factors to consider when monitoring cleanups using monitored 

natural recovery (MNR), in-situ capping, or dredging/excavation. 

In addition to the guidance presented in this chapter, the project manager should consider 

applicable or relevant and appropriate requirements (ARARs), such as the Clean Water Act (CWA), 

Resource Conservation and Recovery Act (RCRA), Toxic Substances Control Act (TSCA), state/tribal 

laws, and to be considered (TBC) criteria, in developing a site-specific monitoring program. 

8.1 INTRODUCTION 

For the purposes of this guidance, monitoring is the collection of field data (i.e., chemical, 

physical, and/or biological) over a sufficient period of time and frequency to determine the status and/or 

trend in a particular environmental parameter or characteristic. Environmental monitoring should not 

produce only a “snapshot in time” of the parameter of interest. Rather it should involve repeated 

sampling over time to define the trends in the parameter(s) of interest relative to clearly defined 

management objectives and goals. 

Environmental sampling and analysis is typically conducted during all phases of the Superfund 

process to address various questions. By the time a project manager is implementing a remedial action or 

writing a monitoring plan, a considerable amount of site data should have been collected during the 

remedial investigation or site characterization phase and during remedial design. In the site 

characterization phase, sampling is performed to determine the nature and extent of contamination, to 

develop the information necessary to assess risks to human health and the environment, and to assess the 

feasibility of remedial alternatives. During site characterization, the project manager should consider 

expected monitoring needs during and after the remedial action to ensure that data are collected 

describing baseline conditions for comparison to future data sets. It is important to note that data 

collection is a dynamic process. 

The project manager should review the existing site characterization data in the remedial design 

phase to determine whether adequate data have been collected to provide a baseline for remedial action 

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and/or long-term monitoring. It may be necessary to collect additional data in the design phase to serve 

this purpose. At sediment sites it is also frequently necessary to continue collecting data from upstream 

or other reference areas away from the direct influence of the site, for comparison to site monitoring data. 

This can be especially important where there is uncertainty or potentially changing conditions in 

background areas, for example, where upstream urban storm water runoff or other continuing sources of 

contamination could impact a remedy. 

Although sediment sites vary widely in size and intricacy, monitoring may be especially complex 

at sediment sites for the following reasons: 

• Sediment sites often involve more than one affected medium (e.g., sediment, surface 

water, air, ground water, and continuing contaminant sources, such as wastewater 

effluents) and may have more than one contaminant of concern; 

• Sediment sites may require monitoring over very large areas; 

• Sediment sites may occur in a large variety of environmental settings (e.g., marine, 

estuarine, riverine, lacustrine, etc.), each of which may require different monitoring 

strategies; 

• Sediment sites often include multiple human health exposure pathways (e.g., recreational 

use, commercial and subsistence fishing, drinking water); 

• Sediment sites may include complex ecosystems involving multiple ecological receptors 

(e.g., benthic, aquatic, terrestrial, and avian biota) and hence require multiple monitoring 

measurement endpoints; and 

• The spatial and temporal variabilities of both physical and chemical sediment 

characteristics can be great. In particular, the spatial and temporal variabilities of both 

sediment and contaminant transport are often greater than for less mobile media such as 

contaminated soil, for example, located on the flood plains. 

These potential complexities make it especially important at sediment sites to systematically plan 

for monitoring. Key general elements for monitoring sediment sites, some potential monitoring 

techniques and approaches for sediment remedies are discussed in the remainder of this chapter. More 

specific guidance is under development by the U.S. Environmental Protection Agency (EPA) to assist 

project managers with the following aspects of sediment site monitoring: 

• Using sediment toxicity tests and chemical analyses when assessing baseline ecological 

risks and when monitoring remedy effectiveness; 

• Using benthic assessment field studies when assessing baseline ecological risks and when 

monitoring remedy effectiveness; 

• Using biota tissue data, biota sediment accumulation factors (BSAFs), and simple food 

chain models when assessing baseline ecological risks and when monitoring remedy 

effectiveness; and 

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Chapter 8: Remedial Action and Long-Term Monitoring 

• Monitoring for resuspension, contaminant transport, and residuals during and after 

dredging. 

8.2 KEY ELEMENTS FOR SEDIMENT SITE MONITORING 

Monitoring can be conducted at contaminated sediment sites for a variety of reasons, but primary 

among them are the following: 1) to assess operational effectiveness (e.g., monitoring sediment 

resuspension rates during dredging, measuring cap thickness during and after installation); and/or 2) to 

evaluate remedy effectiveness and document long-term human health and environmental benefits. No allinclusive monitoring blueprint exists because sediment sites can be quite different, both with respect to 

types of contaminants [e.g., polychlorinated biphenyls (PCBs), metals] and physical characteristics (e.g., 

lakes, rivers, estuaries). However, certain key elements are important for a well-designed monitoring 

program, independent of the site or the remedial stage. These key elements are presented below in text 

and outline form. Following each element, a brief hypothetical example is provided to illustrate how the 

project manager might apply each element to a cleanup scenario. 

When creating a monitoring program following the key elements below, it is important to review 

the record of decision (ROD) for the site. The ROD generally should contain cleanup levels for sediment, 

remediation goals for biota, and narrative remedial action objectives (RAOs) which can then be applied to 

the monitoring program, especially Elements 1 through 3 below. If the cleanup levels and remediation 

goals are very specific, some of the work in Elements 1 through 3 will already be completed. 

Element 1: Monitoring Objective Identification 

The most important element in developing an effective monitoring program is for the project 

manager to identify clear and specific monitoring objectives. These objectives generally will support the 

remediation goals, remedial action objectives for the site which are often risk-based (e.g., reduce fish 

tissue concentrations) and should be in the ROD. Inadequate or vague monitoring objectives can lead to 

criticism about what was monitored and why. Furthermore, funding for monitoring is often limited. 

Specifying objectives help to focus the experimental design and ensure that the most useful information is 

collected. 

When identifying monitoring objectives other than those established in the ROD, the project 

manager should involve participants from all concerned groups [e.g., public, natural resource trustees, 

state agencies, potentially responsible parties (PRP)]. This participation does not necessarily imply the 

continuous involvement of the stakeholders; rather, it provides an opportunity for their input into 

developing the monitoring objectives. In some instances, more direct involvement is warranted by certain 

groups (e.g., natural resource trustees) to ensure that all needs/concerns are incorporated into the overall 

monitoring objectives. Whether involvement is direct or indirect, the purpose is for the project manager 

to bring all stakeholder viewpoints to the decision making process. In general, the focus of any specific 

monitoring program should be to determine the status and/or trend in those environmental parameters or 

characteristics of interest relative to clearly defined management objectives and goals. 

Example: In River X, fish were found to have very high concentrations of PCBs in their 

tissue. These concentrations were determined to pose both human health and ecological 

risks. A remediation goal of reducing PCB concentrations in fish tissue to 0.05 parts per 

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million (ppm), was documented in the ROD. The subsequent monitoring program would 

monitor PCB concentrations in fish tissue along River X until this goal is reached. 

Element 2: Decision/Evaluation Criteria 

Once monitoring objectives are agreed upon and stated explicitly, the next step for the project 

manager is to identify specific decision criteria to assess whether the objectives are met. Criteria can be 

based on physical, chemical, and/or human health or environmental goals. Examples could include a 

physical criterion to limit contaminant net transport, a chemical criterion to limit contaminant 

concentrations in the water column, and/or a biological criterion to lower fish tissue concentrations to a 

specific value. Furthermore, additional criteria may relate to engineering and/or construction (e.g., cap 

stability or thickness). 

Another factor the project manager should consider when developing decision criteria is the time 

frame for assessing those criteria. If the potential risks are high, the time frame for assessing decision 

criteria may need to be short. For example, when dredging severely contaminated sediment, a real-time 

monitoring program could be established to analyze water samples on a time frequency basis before 

proceeding with the next day’s dredging. In contrast, the time frame required to assess a long-term 

monitoring objective (e.g., to lower fish tissue concentrations) would be longer. In either case, it is 

essential that the time frame be explicitly stated and understood by all the participants. 

Example: With the remediation goal to reduce PCB concentrations in fish tissue to 0.05 

ppm, the explicit monitoring decision criterion is to meet and interim goal of 2 ppm in 

fish tissue. Furthermore, this goal is expected to be met within a five year period, after 

which monitoring frequency may be revisited. 

Element 3: Endpoint identification 

Once the decision criteria have been identified, the next key element in this framework is to 

determine the information required to evaluate those criteria. Again, the more clearly the goals and 

criteria are stated initially, the easier it is to identify the appropriate endpoints. In general, physical (e.g., 

transport) and chemical (e.g., water quality criteria) endpoints are easier to interpret than biological 

endpoints (e.g., benthic community diversity). However, the ability of physical and chemical endpoints 

to quantify ecological risk is usually less direct than biological measurements. For example, 

contaminated sediment usually contains a suite of chemicals, and it is virtually impossible to analyze for 

all of them. Also, chemicals can act additively, thus increasing the ecological risks beyond those 

indicated by single chemical measurements. Biological endpoints (e.g., toxicity tests) provide an 

integrated measurement of the cumulative effects of all contaminants and, therefore, can be a better 

assessment of ecological risks. 

When identifying appropriate endpoints, it is important for the project manager to ensure that the 

measure employed matches the time frame established for the criteria. For example, acute toxicity tests 

quantify short-term effects on an organism; therefore, this type of test may be appropriate for operational 

monitoring (e.g., monitoring during remedial dredging), where it can be performed in a short period of 

time. Other biological endpoints, such as changes in community species diversity, occur over long 

periods of time and may be more appropriate for use in a long-term monitoring program designed to look 

at ecological recovery. While no single endpoint can quantify all possible risks, a combination of 

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physical, chemical, and biological endpoints usually provides the best overall approach for measuring 

risks. 

Example: Given that the decision criterion is 2 ppm in fish tissue, PCB concentrations in 

fish species A will be measured every X months to evaluate whether the interim goal has 

been met. 

Element 4: Monitoring Program Design and Data Collection 

At this point monitoring objectives, criteria, and endpoints have been identified. The fourth key 

element for the project manager is to identify the monitoring design for collecting endpoint data (e.g., 

determining where and how often to collect those data). Design considerations include quality assurance, 

spatial and temporal factors, statistical design, and cost. The time spent initially to develop an effective 

and efficient monitoring design is often the best way to maximize the utility of the information collected 

(i.e., it is more effective to collect less of the “right” data than it is to collect more of the “wrong” data). 

EPA requires a systematic planning approach to develop acceptance or performance criteria for 

all environmental data collection. The Agency’s data quality objective (DQO) process is a planning 

approach appropriate for sediment sites (U.S. EPA 2000e). Quality assurance project plans (QAPPs) are 

also required. The formation and documentation of a rigorous quality assurance/quality control (QA/QC) 

program ensures the validity of the results for EPA and others and reenforces subsequent conclusions. 

The spatial and temporal aspects of a monitoring program define where and when to collect 

samples. In general, sampling locations should be based on the areal extent and magnitude of the 

contaminated sediment and the propensity for the contaminants to move, either through transport (e.g., 

remediation, natural events) or through the food chain. Sampling station locations are site-specific and 

depend on the endpoints and decision criteria selected. It is also important for the project manager to 

consider how frequently to collect samples. Generally, the more dynamic the conditions, the more 

frequently sampling should occur. 

Selecting a statistical approach to use is another important aspect of the monitoring program 

design. Data are sometimes collected in a manner that is incompatible with the statistical tests used to 

analyze the data. Project managers should identify factors such as data representativeness, sample 

replication, biased versus unbiased sampling designs, etc., when designing the monitoring program. The 

DQO process can be particularly helpful in this regard. Failure to take this step can result in the need to 

resample or modify decisions, all of which might be avoided through effective statistical considerations 

early in the design phase. 

Finally, in reality, cost often drives data collection. For example, frequently the question asked 

is, “How many chemistry samples can I collect with my $50,000 budget?" The more correct philosophy 

should be, “Given that I have a $50,000 budget, what are the most appropriate samples to collect?” To 

reiterate, it is more cost-effective to collect less of the “right” data than it is to collect more of the 

“wrong” data. The monitoring program design will determine what the “right” data are. 

Example: From the remedial investigation (RI) data we know that Fish A overwinters in 

the contaminated area. The proposed sampling plan would consist of overlying an 

unbiased sampling grid onto a map of the contaminated area of River X as well as in the 

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areas upstream and downstream of the site. Based on available funding, it is decided that 

30 fish will be collected in the Spring in each of these areas. However, given cost 

considerations, only 10 samples will be analyzed immediately and the other 20 archived 

for further analyses pending the results. The DQO process is used and a QA/QC plan is 

developed, as well as a health and safety plan (HASP). 

Element 5: Data Analysis and Management 

The last key element of a monitoring program is data analysis and dissemination. At this point, 

the project manager evaluates the data relative to the status and trends of multiple endpoints as well as 

comparing it to the decision criteria to determine if the interim goal and remediation goals are met. In 

addition, the project manager should communicate data, results, and conclusions to the appropriate 

audience. Frequently, the importance of communicating the results is underestimated. Because 

information is often provided to individuals with various levels of technical expertise, it should be 

comprehensible at multiple levels. Complex scientific data are not often easily understood by those 

without a technical background and ineffective data communication often leads to skepticism about the 

conclusions. Therefore, it is important that the project manager consider the audience and present results 

in multiple formats. To those less familiar with the technical presentation of data, information can be 

presented in easily understood visual formats [e.g., geographic information system (GIS)]. This approach 

maximizes the effective dissemination of information to the greatest number of individuals, thus 

increasing the probability that the conclusions will be understood and believed. 

A final consideration is the physical location of data storage, that is, who will maintain the data 

and who will have access to it. Data stored electronically are much easier to manipulate graphically 

and/or reevaluate than data filed on handwritten sheets; however, data securing should also be considered. 

Example: At this point, three years of fish tissue data have been collected, analyzed, and 

have passed the QA/QC evaluation. The decisions criterion for this monitoring objective 

was to reduce the PCB concentrations in fish tissue to 2 ppm. The data show that the 

after the third year, fish tissue concentrations are still above 2 ppm; however, the highest 

levels are restricted to a relatively small area. The results are summarized and presented 

to the original participating agencies. Due to the high fish tissue concentrations in certain 

areas, the project manager decides to analyze the additional 20 samples to better 

characterize the contamination. After examining the additional data, the decision is made 

that the monitoring objective has not been met and continued monitoring at the current 

frequency is necessary. 

An outline of the five key elements and suggested subparts is shown in Highlight 8-1. It should 

be noted that the following outline essentially follows EPA’s DQO process, with modification, for ease of 

application to a contaminated sediment site. Project managers should refer to the DQO process to 

supplement this outline when preparing a sediment site monitoring program. 

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Highlight 8-1: Outline of Key Elements for Sediment Site Monitoring 

1. Monitoring Objective Identification (Ex: Reduce fish PCB concentrations to remediation goal of 0.05 

ppm) 

a. Site summary 

i. Background information 

b. Participants 

i. Federal 

ii. State 

iii. Trustees 

iv. Public 

v. PRPs 

c. Human risks 

i. Exposure 

(1) Air 

(2) Water 

(3) Sediment 

(4) Biota 

d. Ecological risks 

i. Transport 

ii. Exposure 

iii. Bioaccumulation 

2. Decision/Evaluation Criteria (Ex: Reduce fish PCBs to interim goal of 2 ppm in 5 years)

a. Existing criteria 

i. ARARs 

b. Site-specific criteria

i. Risk-based criteria

ii. Technology-based criteria (e.g., cap thickness)

c. Milestones (Time frame for assessing criteria)

i. Real time

ii. Annual

iii. Post remediation

3. Endpoint Identification (Ex: PCB tissue residues in fish species A) 

a. Measures and methods 

i. Physical 

(1) Resuspension 

(2) Transport 

ii. Chemical 

(1) Bioavailable sediment concentrations 

(2) Biota tissue concentration 

iii. Biological 

(1) Chronic toxic effects 

(2) Food chain effects 

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4. Monitoring Program Design and Data Collection (Ex: 30 fish collected in the Spring at multiple locations 

and times) 

a. Temporal considerations 

i. Meteorological factors 

ii. Time frame for data collection 

b. Spatial considerations 

i. Strategic locations relative to transport, exposure, health, etc. 

c. Statistical considerations 

i. Replication 

ii. Representativeness 

iii. Biased vs. Unbiased sampling 

d. Cost 

i. Number of samples 

(1) Tiered approach 

1. Worst areas first with most intensive monitoring 

2. Scale back in less contaminated areas 

e. Feedback loop 

i. Ability to modify the experimental design based on new information 

f. DQO process and QA/QC plan 

g. HASP 

5. Data Analysis and Management (Ex: Fish residues are greater than 2 ppm after 3 years, requiring 

continued long-term monitoring at current frequency) 

a. Data analysis 

i. QA/QC evaluation 

ii. Statistical evaluation to compare data with decision criteria to evaluate if goals met 

b. Data dissemination 

i. Audience 

(1) Managers 

(2) State and local governments 

(3) Public 

(4) Scientific literature 

ii. Type 

(1) Electronic (e.g., web site) 

(2) Hard copy (e.g., fact sheets) 

(3) Public meetings 

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37 8.3 POTENTIAL MONITORING TECHNIQUES

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39 This section provides a brief overview of the types of monitoring techniques and endpoints that

40 the project manager should consider during and following implementation of a sediment cleanup. The

41 exact measurements depend on the cleanup methods selected and the phase of the operation as discussed

42 in previous sections. In general, a combination of physical, chemical, and biological methods and a tiered

43 monitoring protocol/sampling plan, as described above, is the best approach to determine whether a

44 sediment remedy meets remedial objectives and associated performance criteria both during remedial

45 action and in the long term.

46

47 Generally, physical (e.g., transport) and chemical (e.g., sediment concentrations) endpoints are

48 easier to measure and interpret than biological (e.g., species abundance) endpoints. In the case of human

49 health risk, chemical measurements are most often used to assess risk (e.g., mercury in fish tissue). In

50 contrast, measurement of the biological community is a direct but often complex measurement for

51 monitoring response to changed ecological risk. Caged organisms (e.g., Macoma, or mussels) at the site

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over a defined time frame can identify changes in bioavailable concentrations of many contaminants. 

Collection of fish and tissue analysis can address both human health and ecological response of the 

system, if both needs are considered during design of the sampling and analysis plan. The project 

manager should refer to Office of Water’s Methods for Collection, Storage, and Manipulation of 

Sediments for Chemical and Toxicological Analyses (U.S. EPA 2001j) and Managing and Sampling and 

Analyzing Contaminants in Fish and Shellfish (U.S. EPA 2000f) for more detailed information. 

Biological endpoints (e.g., toxicity tests) provide an integrated measurement of the cumulative 

effects of all contaminants. When using biological endpoints, it is important for the project manager to 

ensure that the biological test employed fits the intended criteria. For example, acute toxicity tests 

quantify short-term effects on an organism; therefore, this type of test may be appropriate when 

monitoring for short-term impacts of a remedy. Other biological endpoints, such as changes in 

community species diversity, occur over long periods of time and are more appropriate for use in a longterm monitoring program designed to look at ecological recovery. While no single endpoint can quantify 

all possible risks, project managers should consider a combination of physical, chemical, and biological 

endpoints to provide the best overall approach for assessing the short- and long-term success of a 

remedial action. 

8.3.1 Physical Measurements 

Physical testing at a site may include measurements of erosion and/or deposition of sediment, 

pore water analysis, ground water advective flow analysis, particle size analysis, surface water flow rates, 

and sediment homogeneity/heterogeneity. Potential types of physical monitoring data and their uses also 

include the following: 

• Sediment Geophysical Properties: Uses include fate and transport modeling, 

determination of contaminant bioavailability, and habitat characteristics of post-cleanup 

sediment surface; 

• Water Column Physical Measurements (e.g., turbidity, total suspended solids): Uses 

include monitoring the amount of sediment resuspension during dredging and during 

placement of in-situ caps; 

• Global Positioning Systems (GPS) Data: Uses include maintaining accuracy of 

navigation for repetitive sampling; 

• Bathymetry Data: Uses include evaluation of post-capping or post-dredging bottom 

elevations for comparison to design specifications and evaluation of sediment stability 

during natural recovery; 

• Side Scan Sonar Data: Uses include remote sensing to monitor the distribution of 

sediment types and bedforms; 

• Settlement Plate Data: Uses include monitoring changes in cap thickness over time and 

measurement of cap consolidation; 

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• Sediment Profile Camera Data: Uses include monitoring of changes in thin layering 

within sediment profiles, sediment grain sizes, bioturbation and oxidation depths, and the 

presence of gas bubbles; and 

• Subbottom Profiler Data: Uses include remote sensing measurement of changes in 

sediment surface and subsurface layers, bioturbation and oxidation depths, and presence 

of gas bubbles. 

8.3.2 Chemical Measurements 

Chemical testing may include sediment chemistry (both the upper biological zone and/or deeper 

sediment), evaluating biodegradation, contaminant partitioning to the pore water, and concentrations of 

total organic carbon. Potential environmental monitoring methods used in support of chemical 

measurements include the following: 

• Sediment Grab Samplers: Uses include measurement of surface sediment chemistry; 

• Coring Devices (e.g., vibracore, gravity piston, or drop tube samplers): Uses include 

obtaining a vertical profile of sediment chemistry, or detection of contaminant movement 

through a cap or through a layer of naturally deposited clean sediment; 

• Direct Water Column Measurements (probes): Uses include measurement of parameters 

such as pH and dissolved oxygen in the water column; 

• Surface Water Samplers: Uses include measurement of chemical concentrations 

(dissolved and particulate) in water or contaminant releases to the water column during 

construction; and 

• Semi-Permeable Membrane Devices: Uses include measurement of dissolved 

contaminants at the sediment-water interface. 

For sediment sites contaminated with PCBs, the National Research Council (NRC) recommends 

that PCB sites be characterized and remedies for PCBs be monitored on the basis of specific PCB 

congeners and the total mixture of congeners that exist at each site, rather than on the basis of total PCBs 

or Aroclors [(i.e., commercial PCB mixtures) NRC 2001]. EPA’s Office of Water, in Guidance for 

Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume 1, Fish Sampling and 

Analysis, Third Edition (U.S. EPA 2000g) indicates that analyses for PCBs as Aroclors can result in 

significant error in determining total PCB concentrations and that the distribution of PCB congeners in 

Aroclors is altered considerably by physical, chemical, and biological processes after release into the 

environment. Characterizing PCB risk and monitoring PCB remedies on a congener-specific basis allows 

for an accounting of the differences in physicochemical, biochemical, and toxicological behavior of the 

different congeners in type and magnitude of effects and, therefore, in risk calculations. 

However, deciding how best to characterize and monitor a PCB site is a complex issue due in part 

to issues related to dioxin-like PCBs, the lack of congener-specific toxicological data, the need for 

comparing present and previously-collected data, and the cost of congener-specific analyses. As of July 

2002, OERR has non-routine analytical service contracts in place for PCB congener analyses. As of 

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September 2003, EPA will provide this service through the contract laboratory program to meet more 

extensive quality assurance requirements. 

8.3.3 Biological Measurements 

Biological testing can include toxicity bioassays, examining changes in the biological 

assemblages at sites, either to document problems or evaluate restoration efforts, and/or determining 

toxicant bioaccumulation and food chain effects. Potential types of biological monitoring data and their 

uses also include the following: 

• Benthic Community Analysis: Uses include evaluations of population size and diversity, 

and monitoring of recovery following remediation; 

• Toxicity Testing: Uses include measurement of lethal or sublethal effects of contaminants 

on organisms in order to help establish protective range of remediation goals; 

• Tissue Sampling: Uses include measurement of bioaccumulation, modeling trophic 

transfer potential, and estimating food web effects; 

• Caged Fish/Invertebrate Studies: Uses include monitoring change in uptake of 

contaminants by biota from the sediment or water column to measure the effect of the 

remedy on bioaccumulation rates; and 

• Sediment Profile Camera: Uses include indirect measurement of macroinvertebrate 

recolonization, for example, measuring population density of polychaetes by counting the 

number of burrow tubes per linear centimeter along the sediment-water interface. 

8.4 REMEDY-SPECIFIC MONITORING APPROACHES 

The following sections discuss monitoring issues particular to natural recovery, in-situ capping, 

and dredging or excavation. Many sediment remedies involve a combination of cleanup methods, and for 

these remedies, the monitoring program will likely include a combination of techniques to measure shortand long-term success. In general, the project manager should consider monitoring which takes place 

during construction or at any time before construction specifications, cleanup levels, and remedial action 

objectives are met, to be part of remedial action and the long-term operation and maintenance phase of the 

remedy. 

8.4.1 Monitoring Natural Recovery 

Monitoring is an essential component of a remedy that includes MNR, as contaminants are left in 

place, generally, without physical protection from physical or biological disturbances. Remedial action 

monitoring for MNR can extend for a long period of time. It generally includes all monitoring up until 

cleanup levels and remedial action objectives are met (i.e., the recovery period). Long-term monitoring 

(i.e., during the O&M phase) generally includes all monitoring following attainment of cleanup levels and 

remedial action objectives (i.e., continued monitoring to ensure recovery is maintained). MNR remedies 

generally require more intensive monitoring early in the recovery period, which may be relaxed if 

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predicted recovery rates are being attained. An exception may be in the case of an intensive disturbance 

event. 

Remedial Action Monitoring 

Remedial action monitoring of natural recovery should test the claim that the numerous relevant 

processes are indeed operating to isolate or eliminate the contaminants of concern. Monitoring should 

focus on the natural processes which are relied upon to reduce risk. In some cases it may be possible for 

the project manager to monitor the process itself, but in most cases, monitoring involves measuring the 

process indirectly or measuring the effects of that process. As a sound strategy for monitoring natural 

recovery the project manager should consider monitoring the following: 

• Direct or indirect measures of natural processes (e.g., sediment accumulation rates, 

degradation products, sediment and contaminant transport); 

• Contaminant levels in sediment (e.g., of the bioavailable zone and, where appropriate, at 

depth); and 

• Measures of biota recovery (e.g., benthic organism population size and diversity and/or, 

for bioacumulative contaminants, contaminant levels in other trophic level indicator 

species). 

EPA’s Science Advisory Board (SAB), in its May 2001 report, Monitored Natural Attenuation: 

USEPA Research Program - An EPA Science Advisory Board Review (U.S. EPA 2001i), section 3.4, 

under “Summary of Major Research Recommendations,” indicates the need for the development of 

additional monitoring methods to quantify attenuation mechanisms, contaminated sediment transport 

processes, and bioaccumulation to support footprint documentation and analysis of permanence. EPA is 

aware of these research needs and plans to address some of these topics in ongoing and future work. 

In developing monitoring plans for MNR, project managers should also consider the likelihood of 

movement of contaminants by advective flow of water through the contaminated sediment, either into 

surface water or into surrounding ground water. In addition, movement by molecular diffusion over long 

time periods is inevitable. The project manager should consider these processes for both remedial action 

and long-term monitoring plans. 

For areas that may be subject to sediment disruption, the project manager should conduct more 

extensive monitoring when specified disruptive events (e.g., storms or flow stages of a specified 

recurrence interval or magnitude) occur in order to evaluate whether buried contaminated sediment is 

being disturbed or transported and the extent to which that disturbance is causing release of contaminants 

and increased risk. The project manager should design the monitoring plan to handle the relatively quick 

turnaround times needed to effectively monitor expected disruptive events. This disturbance-related 

monitoring may be appropriate during both remedial action and long-term monitoring. 

The project manager should include periodic comparisons of monitoring data to rates of recovery 

expected for the site in a MNR monitoring program. Where predictions were based on modeling, the 

project manager should use monitoring results to verify and/or adjust model assumptions and to rerun 

model predictions. Where contingency remedies or triggers for additional work are part of a remedy 

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decision, the project manager should design the monitoring plan to help determine whether those triggers 

are met. Examples triggers include the following: 

• Contaminant concentrations in sediment, surface water, or biota at specified locations that 

exhibit an increasing or insufficient decreasing trend; 

• Changes in land and/or surface water/ground water use may adversely affect the 

protectiveness of the remedy; 

• Insufficient sedimentation rates; and 

• Occurrence of a flood or storm that scours the sediment and exposes previously buried 

contaminants. 

Where contingencies are triggered, the project manager may need to include measures such as 

additional source control, additional institutional controls, the placement of a thin layer of clean sediment 

to enhance natural recovery, or an active cleanup such as dredging or capping. 

Long-Term Monitoring 

Following completion of the remedial action, long-term monitoring is frequently needed at MNR 

sites. The term “long-term monitoring” is somewhat confusing for MNR remedies because the remedial 

action phase generally takes a long time period by itself. Long-term monitoring (i.e., monitoring during 

the O&M phase) for MNR remedies is monitoring after cleanup levels and remedial action objectives 

have been achieved. For sites where natural recovery is based on burial with clean sediment, continued 

monitoring generally is necessary after cleanup levels and remedial action objectives have been achieved 

in order to assess whether buried contaminants remain in place and are not bioavailable. Many of the 

factors discussed above concerning disruptive event monitoring and other issues apply to this stage of 

monitoring as well. 

8.4.2 Monitoring In-Situ Capping 

Monitoring is an essential component of a remedy that includes in-situ capping. Remedial action 

monitoring for capping generally includes monitoring of construction and placement, initial cap 

performance, and monitoring of any broader remedial action objectives such as fish recovery. Long-term 

monitoring (i.e., during the O&M phase) for capping generally includes continued monitoring of cap 

performance and monitoring of maintenance activities. Long-term monitoring may also include periodic 

monitoring to ensure that broader remedial action objectives continue to be met. Monitoring of a cap is 

also used to guide cap maintenance plans and modify future monitoring schedules and activities. 

Highlight 8-2 lists example elements of cap monitoring. 

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3 4 5 6 7 

Highlight 8-2: Example Cap Monitoring Phases and Elements 

Monitoring Phase Element Component Analysis Frequ

Cap Construction Cap material quality Cap material sampling Physical properties 5% of loads 

Cap thickness and areal extent 

Bathymetry Subbottom profile 

Thickness of cap layers Areal extent of cap 

Baseline Initial placement Final surveys ove

Sediment profile camera (SPC) 

Thickness of cap layers Baseline 

Initial placement Defined grid for r

Cores Layer thickness and physical properties 

Chemical properties for baseline 

Defined grid 

Sediment resuspension 

Plume tracking Acoustic Doppler Current Profile (ADCP) Water column samples 

Suspended sediment Water column chemistry 

5% of load place

Cap Performance Recolonization SPC 

Benthic Community Analysis 

Layer thickness 

Recolonization, population size and diversity 

Defined grid - frelocal information rates 

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10 11 Physical isolation Subbottom profile 

Bathymetry Cores 

12 Chemical isolation Cores 

Peepers Seepage meters 

Layer thickness Annual checks in 

Surveys over ent

Physical properties Defined grid everSediment chemistryPore water chemistry

1314

Severe Event Response 

Cap integrity Subbottom profile 

SPC Cores 

Following major s

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As shown in Highlight 8-2, a variety of monitoring equipment and methods can be used for 

capping projects during both remedial action and long-term monitoring. Two common approaches are the 

use of bathymetric surveys to determine cap thickness and stability over time and the analysis of 

sequential cores taken through the cap to confirm physical and chemical isolation. Specialized 

equipment, such as seepage meters, diffusion samplers (e.g., peepers and semi-permeable membrane 

devices), and sediment profile cameras, can also be considered. To ensure physical isolation of 

contaminated sediment, measurements of bathymetry of the capped area, cap/component thickness, 

colonization by bottom-dwelling organisms, and sedimentation through sediment traps can be conducted. 

Elements for measuring contaminant migration may include chemical analysis of cap materials, collection 

chambers, air-filled (vapor diffusion) or solvent-filled (peepers) bags, and caged fish. Seepage meters can 

also be used to measure advective flow rates and pore water flux. 

In developing monitoring plans for caps, project managers should also consider the likelihood of 

movement of contaminants by advective flow water through the cap and the contaminated sediment, 

either into surface water or into surrounding ground water. In addition, movement by molecular diffusion 

over long time periods is inevitable. Both remedial action and long-term monitoring plans should 

consider these processes. 

Remedial Action Monitoring 

As mentioned above, remedial action monitoring for capping generally includes monitoring of 

construction, initial cap performance monitoring, and monitoring of any broader remedial action 

objectives such as recovery of the bottom-dwelling benthic community, fish/shellfish, or other higher 

trophic level biota. 

Construction monitoring for capping is designed to measure whether design plans and 

specifications are followed in the placement of the cap and to monitor the extent of any contaminant 

releases during cap placement. During construction, monitoring results can be used to identify 

modifications to design or construction techniques needed to meet unavoidable field constraints. 

Construction monitoring frequently includes interim and post-construction cap material placement 

surveys. Appropriate methods for monitoring cap placement include bathymetric surveys, sediment core 

sampling, sediment profiling camera, and chemical resuspension monitoring for contaminants. For some 

sites, visual observation in shallow waters or surface visual aids, such as viewing tube or diver 

observations, can also be useful. 

More broadly, remedial action monitoring of a cap should be designed to evaluate whether all 

remedial action objectives have been met. Biological testing may include the type and quantity of 

organisms that may recolonize the capped site and the bioturbation behavior of benthic organisms. Where 

contaminants are bioaccumulative, fish or other biota edible tissue or whole body monitoring may also be 

recommended. 

Long-Term Monitoring 

Following completion of the remedial action, long-term monitoring is important to ensure that the 

cap is not being eroded or significantly compromised (e.g., penetrated by submerged aquatic vegetation, 

ground water recharge, or bioturbation) and that chemical contaminant fluxes that ultimately do move 

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through the cap to surface water do so at the projected rate and concentration. It is also frequently 

desirable to include ongoing monitoring for recontamination of the cap surface from other sources. 

For areas that may be subject to cap disruption, more extensive monitoring should be triggered 

when specified disruptive events (e.g., storms or flow stages of a specified recurrence interval or 

magnitude) occur, in order to evaluate whether the cap was disturbed and whether any disturbance caused 

release of contaminants and increased risk. Additional monitoring for the effects of tidal and wave 

pumping and boat propeller wash is also recommended. In general, the project manager should monitor 

cap integrity both routinely and following all storm/flood events that approach the design storm 

magnitude envisioned by the cap’s engineers. As for other types of sediment remedies, the project 

manager should design the monitoring plan to handle the relatively quick turnaround times needed to 

effectively monitor expected disruptive events. 

Cap maintenance is generally limited to the repair and replenishment of the erosion protection 

layer in high erosion areas where this is necessary. Project managers should consider the ability to detect 

and quickly respond to a loss of the erosion protection layer when evaluating a capping alternative. 

Seasonal limitations, such as ice formation or closure of navigation structures (locks), can limit the ability 

to monitor in-situ caps after a significant erosion event. This can also limit the project manager’s ability 

to respond if maintenance is needed. 

Capping remedies frequently include provisions for actions to be taken in the case that one or 

more cap functions are not being met. Options for modifying the cap design may or may not be available. 

If monitoring shows that the stabilization component is being eroded by events of lesser magnitude than 

planned, or the erosive energy at the capping site was underestimated, then eroded material can be 

replaced with more erosion-resistant cap material. If monitoring indicates that bottom-dwelling 

organisms are penetrating the cap in significant numbers, then project managers should consider placing 

additional cap material on top of the cap to inhibit cap colonization. These types of management options 

are feasible where additional cap thickness, and the resulting decrease in water depths at the site, does not 

conflict with other waterway uses. Where a cap has been closely designed to a thickness that will not 

limit waterway use (i.e., recreational or commercial navigation), the options for modifying a cap design 

after construction can be limited. 

8.4.3 Monitoring Dredging or Excavation 

Like all sediment remedies, monitoring is an essential component of a remedy that includes 

dredging or excavation. Remedial action monitoring for this type of remedy generally includes 

construction and operational monitoring of the dredging or excavation, transport, dewatering, any 

treatment, transport, and any on-site disposal placement. Remedial action monitoring for dredging or 

excavation also includes monitoring of residual contamination and monitoring of all broader remedial 

action objectives such as bottom-dwelling community recovery or fish and shellfish recovery. Long-term 

monitoring (i.e., during the O&M phase) for dredging or excavation generally includes continued 

monitoring of any on-site disposal facilities and monitoring sediment and/or biota for recontamination. 

Remedial Action Monitoring 

Remedial action monitoring for dredging or excavation generally includes a comprehensive 

monitoring program for all potential routes of contaminant exposure during various phases of the 

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Chapter 8: Remedial Action and Long-Term Monitoring 

operation. Depending on the levels of contamination and the selected methods of dredging/excavation, 

transport, treatment or disposal, potential construction and operational monitoring may include the 

following: 

• Water quality monitoring at the dredging and disposal sites; 

• Monitoring of dredging residuals; 

• Effluent quality monitoring after sediment dewatering and/or treatment; 

• Air monitoring at the dredge, transport, on-site disposal, and treatment sites; and 

• Monitoring of on-site treatment residuals. 

A thorough operational monitoring plan, including effective containment barriers, will help 

project managers to ensure that contamination is not spread during dredging, transport, treatment, or 

disposal to uncontaminated areas of the waterbody, sensitive habitats, or adjacent human populations. 

The project manager should consider water, air, and biological sampling in the remedial monitoring plan. 

This is dependent on the predominant contaminants of concern and the tendency for the contaminant to 

volatilize or bioaccumulate. 

Generally, project managers should design remedial action monitoring for dredging to test the 

effectiveness of silt curtains, operational controls, and any other measures used to control total suspended 

solids from sediment resuspension. In most cases the project manager should include sampling 

upgradient of the dredging operation and both inside and outside of any containment structures. 

Generally this sampling should also include dissolved compounds in the water column. Also, where 

contaminants may be volatile, project managers should include air sampling. As discussed in Chapter 6, 

section 6.8.2, Sediment Characteristics, several tests and models have been established by the EPA and 

the U.S. Army Corps of Engineers (USACE) to predict contaminant losses from dredging. At highly 

contaminated sites, it may be necessary for the project manager to conduct a pilot study on a small area to 

determine if the sediment may be removed without causing unacceptable risks to adjacent human 

populations or adjacent benthic habitat. This information can help to determine what containment 

barriers or dredging methods work best and what performance standards are achievable at the site. The 

project manager should compare monitoring results to a pre-operational baseline for contaminant 

concentrations in air and water. This ensures that effects due to dredging may be separated and evaluated 

from natural perturbations, such as tide and storm influence. The project manager should develop 

contingency plans to guide changes in operation where performance standards are exceeded. 

Following dredging, it is essential for project managers to determine whether cleanup levels in 

sediment and remediation goals for all media, including biota, are achieved through sediment monitoring. 

Initial sampling should be analyzed rapidly, so that contingency actions, such as additional dredging or 

backfilling, can be implemented quickly if cleanup levels have not been met. A post-dredging monitoring 

program should be designed by the project manager to measure whether the remedy has been successful 

in managing the risks at the site. The project manager should design the monitoring program for dredging 

sites to provide data that demonstrates that all food chain risks and other sediment exposure pathways 

have been managed or controlled and any on-site disposal facilities are operating effectively to isolate 

contaminants from the environment. 

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Chapter 8: Remedial Action and Long-Term Monitoring 

Long-Term Monitoring 

Following completion of the remedial action, it is necessary for the project manager to conduct 

long-term monitoring to ensure the dredged area is not re-contaminated by additional sources or by 

disturbance of any residuals which remain above cleanup levels. Long-term monitoring of any on-site 

disposal facilities is also necessary. 

If an in-water or upland disposal facility is constructed on-site as part of the remedy, it should be 

monitored to ensure that it remains intact and that there are no unacceptable contaminant releases in the 

long term. Monitoring is recommended to resolve whether contaminants are leaking through the bottom 

or walls of the confined disposal facility (CDF) or landfill, and that any surface cap remains intact to 

ensure protection from infiltration. Depending on the type of disposal site and the nature of the 

contamination, long-term disposal site monitoring may include the following: 

• Seepage from the CDF containment cells to surrounding surface water; 

• Ground water monitoring; 

• Surface water run-off monitoring; 

• Monitoring of disposal area cap integrity; and 

• Monitoring of revegetation or recolonization by plant and animal communities, and their 

potential uptake of contaminants. 

Highlight 8-3 lists important points to remember related to monitoring sediment sites. 

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Highlight 8-3: Points to Remember About Monitoring Sediment Sites 

• A monitoring program is important for all types of sediment remedies, both during the remedial action and 

over the long term to ensure that sediment risk and exposure pathways at a site have been adequately 

managed and remain so 

• The development of monitoring plans should follow a systematic planning process that identifies 

monitoring objectives, decision criteria, endpoints, and data collection and analysis methods 

• Before implementing a remedial action, project managers should review baseline data and collect 

additional data if needed to ensure that an adequate baseline exists for comparison to monitoring data 

• Remedial action monitoring includes both construction/operational monitoring and monitoring intended to 

measure whether cleanup levels and remedial action objectives have been met 

• Monitoring plans should be designed to evaluate whether performance standards of the remedial action 

are being met and should be flexible enough to allow revision if operating procedures are revised 

• Field methods/quick turnaround with real-time feedback are useful, especially during the remedial action 

to predict or identify potential problems 

• After completion of remedial action, long-term monitoring is important to watch for recontamination, to 

assess continued containment of buried or capped contaminants, and to monitor dredging residuals and 

on-site disposal facilities 

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Deibel, I.K., and J.W. Zwakhals. 1993. Separation from Sand out of Sludge; A Large Scale Test. 

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Hall, J.S. 1994. Physical Disturbance and Marine Benthic Communities: Life in Unconsolidated 

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Chapter 9: References 

Tabak, H.H., and R. Govind. 1997. Bioavailability and Biodegradation Kinetics Protocol for Organic 

Pollutant Compounds to Achieve Environmentally Acceptable Endpoints During Bioremediation. 

In: Bioremediation of Surface and Subsurface Contamination, Annals of New York Academy of 

Sciences. 829:36-60. 

USACE. 1992. Thin Layer Placement of Dredged Material Feasibility Analysis, Eagle Harbor, 

Washington. U.S. Army Corps of Engineers, Seattle District. 

USACE. 1983. Dredging and Dredged Material Disposal. Engineer Manual 1110-2-5025. U.S. Army 

Corps of Engineers, Washington, DC. 

USACE. 1987. Confined Disposal of Dredged Materia. Engineer Manual 1110-2-5027. U.S. Army 

Corps of Engineers, Washington, DC. 

USACE 1995. LTFATE: A Model to Investigate the Long-Term Fate and Stability of Dredged Material 

Disposal Sites; Users Guide (IR DRP-95-1). U.S. Army Corps of Engineers Waterways 

Experiment Station, Vicksburg, MS. 

USACE. 2001. Subaqueous Cap Design: Selection of Bioturbation Profiles, Depths and Process Rates. 

DOER Technical Notes Collection ( ERDC TN-DOER-C21). U.S. Army Corps of Engineers 

Waterways Experiment Station, Vicksburg, MS. Available at 

http://www.wes.army.mil/el/dots/doer/technote.html. 

USACE. 2002. Subaqueous Capping and Natural Recovery: Understanding the Hydrogeologic Setting 

of Contaminated Sediment Sites. DOER Technical Notes Collection (ERDC TN-DOER-C26). 

U.S. Army Corps of Engineers Research and Development Center, Vicksburg, MS. Available at 

http://www.wes.army.mil/el/dots/doer. 

USACE. In preparation. Evaluation of Dredged Material Proposed for Disposal at Island, Nearshore, or 

Upland Confined Disposal Facilities - Testing Manual. U.S. Army Corps of Engineers Research 

and Development Center, Waterways Experiment Station, Vicksburg, MS. Estimated release 

2003. 

USACE WES. 1998. Volatile Losses from Exposed Sediments. Dredging Research Technical Note. 

EEDP-02-24. U.S. Army Corps of Engineers, Waterways Experiment Stations, Vicksburg, MS. 

May. 

USACE and U.S. EPA. 1998. Evaluation of Dredged Material Proposed for Disposal in Inland and Near 

Coastal Waters - Testing Manual. U.S. Department of the Army and U.S. Environmental 

Protection Agency, Office of Water, Washington, DC. EPA 823-B-98-004. February. 

U.S. EPA. 1988a. Guidance for Conducting Remedial Investigations and Feasibility Studies under 

CERCLA, Interim Final. U.S. Environmental Protection Agency Office of Emergency and 

Remedial Response, Washington, DC. OSWER Directive 9355.3-01. October. 

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Chapter 9: References 

U.S. EPA. 1988b. CERCLA Compliance with other Laws Manual, Interim Final. U.S. Environmental 

Protection Agency Office of Emergency and Remedial Response, Washington, DC. OSWER 

Directive 9355.0-67FS. EPA 540-G-89-099. December. 

U.S. EPA. 1989. Risk Assessment Guidance for Superfund. U.S. Environmental Protection Agency 

Office of Emergency and Remedial Response, Washington, DC. EPA 540/1-89/002. December. 

U.S. EPA. 1990a. CF Systems Organic Extraction System - New Bedford, Massachusetts Technology 

Evaluation Report. Office of Research and Development, Cincinnati, OH. EPA 540/5-90/002. 

U.S. EPA. 1990b. Engineering Bulletin, Chemical Dehalogenation Treatment: APEG Treatment. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC, and Office of Research and Development, Cincinnati, OH. EPA 540/2-90/015. 

U.S. EPA. 1990c. Treating Chlorinated Wastes with the KPEG Process - Project Summary. U.S. 

Environmental Protection Agency Office of Research and Development, Cincinnati, OH. EPA 

600/S2-90/026. 

U.S. EPA. 19991a. Compendium of CERCLA ARARs Fact Sheets and Directives. U.S. Environmental 

Protection Agency Office of Solid Waste and Emergency Response, Washington, DC. OSWER 

Directive 9347.3-15. 

U.S. EPA. 1991b. Handbook: Remediation of Contaminated Sediments. U.S. Environmental Protection 

Agency Office of Research and Development, Cincinnati, OH. EPA 625/91/028. April. 

U.S. EPA. 1991c. Engineering Bulletin. Chemical Oxidation Treatment. Superfund. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC, and Office of Research and Development, Cincinnati, OH. EPA 540/2-91/025. 

U.S. EPA. 1991d. Engineering Bulletin: Thermal Desorption Treatment. U.S. Environmental 

Protection Agency Office of Emergency and Remedial Response, Washington, DC, and Office of 

Research and Development, Cincinnati, OH. EPA 540/2-91/008. 

U.S. EPA. 1991e. A Guide to Principal Threat and Low-level Threat Wastes. U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response, Washington, DC. OSWER 

Directive 9380.3-06FS. 

U.S. EPA. 1992a. ECO Update - The Role of Natural Resource Trustees in the Superfund Process. 

Intermittent Bulletin Vol. I, No. 3. U.S. Environmental Protection Agency Office of Emergency 

and Remedial Response, Washington, DC. OSWER Directive 9345.0-05I. March. 

U.S. EPA. 1992b. Early Action and Long-Term Action under SACM - Interim Guidance. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC. OSWER Directive 9203.1-05I. December. 

U.S. EPA. 1992c. National Study of Chemical Residues in Fish, Volumes I and II. Office of Science 

and Technology, Washington, DC. EPA 823-R-92-008a, b. September. 

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U.S. EPA. 1993a. Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA.. 

U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, 

Washington, DC. OSWER Directive 9360.0-32. EPA 540/R-93/057. August. 

U.S. EPA. 1993b. Revisions to OMB Circular A-94 on Guidelines and Discount Rates for Benefit-Cost 

Analysis. Office of Solid Waste and Remedial Response, Washington, DC. OSWER Directive 

No. 9355.3-20. 

U.S. EPA. 1993d. ARCS Risk Assessment and Modeling Overview Document. U.S. Environmental 

Protection Agency Great Lakes National Program Office, Chicago, IL. 

U.S. EPA. 1993e. Selecting Remediation Technologies for Contaminated Sediment. U.S. 

Environmental Protection Agency Office of Water, Washington, DC. EPA 823/B-93/001. 

U.S. EPA. 1993f. Toronto Harbor Commissioners (THC) Soil Recycle Treatment Train, Applications, 

and Analysis Report. Office of Research and Development, Washington, DC. EPA 540/AR93/517. 

U.S. EPA. 1993g. Pilot Scale Demonstration of Thermal Desorption for the Treatment of Buffalo River 

Sediment. EPA 905/R-93/005. December. 

U.S. EPA. 1994a. Guidance for Conducting External Peer Review of Environmental Regulatory Models. 

U.S. Environmental Protection Agency, Office of the Administrator, Agency Task Force on 

Environmental Regulatory Modeling, Washington, DC. EPA 100/B-94/001. July. 

U.S. EPA. 1994b. Assessment and Remediation of Contaminated Sediments (ARCS) Program 

Remediation Guidance Document. EPA/905/R-94/003. U.S. Environmental Protection Agency 

Great Lakes National Program Office, Chicago, IL. 

U.S. EPA. 1994c. Considering Wetlands at CERCLA Sites. U.S. Environmental Protection Agency 

Office of Solid Waste and Emergency Response. EPA 540/R-94/019. May. 

U.S. EPA. 1994d. Pilot Scale Demonstration of Solvent Extraction for the Treatment of Grand Calumet 

River Sediment. EPA 905/R-94/003. January. 

U.S. EPA. 1994e. Pilot-Scale Demonstration of Sediment Washing for the Treatment of Saginaw River 

Sediment. Assessment and Remediation of Contaminated Sediments (ARCS) Program. EPA 

905/R-4/019. July. 

U.S. EPA. 1995a. Land Use on the CERCLA Remedy Selection Process. U.S. Environmental Protection 

Agency, Office of Emergency and Remedial Response, Washington, DC. OSWER Directive 

9355.7-04. 

U.S. EPA. 1995b. Cleaning Up Contaminated Sediments: A Citizen’s Guide. Assessment and 

Remediation of Contaminated Sediment (ARCS) Program. U.S. Environmental Protection 

Agency Great Lakes National Program Office, Chicago, IL. EPA 905/K-95/001. July. 

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U.S. EPA. 1996a. Soil Screening Guidance. U.S. Environmental Protection Agency Office of Solid 

Waste and Emergency Response, Washington, DC. EPA 540/R-96/018. July. 

U.S. EPA 1996b. The Model Plan for Public Participation (developed by the National Environmental 

Justice Advisory Council). Office of Environmental Justice. EPA 300/K-96/003. November. 

U.S. EPA. 1996c. Superfund Removal Procedures, Response Management: Removal Action Start-up to 

Close-out. U.S. Environmental Protection Agency, Office of Emergency and Remedial 

Response, Washington, DC. OSWER Directive 9360.3-04. 

U.S. EPA. 1996d. ECO Update on Ecotox Thresholds. U.S. Environmental Protection Agency Office 

of Solid Waste and Emergency Response, Washington, DC. EPA 540/F-95/038. January. 

Available at http://www.epa.gov/superfund/resources/ecotox/index.htm. 

U.S. EPA. 1996e. The National Sediment Quality Survey: a Report to Congress on the Extent and 

Severity of Sediment Contamination in Surface Waters of the United States. Office of Science 

and Technology, Washington, DC. EPA 823-D-96-002. July. 

U.S. EPA. 1996f. Estimating Contaminant Losses from Components of Remediation Alternatives for 

Contaminated Sediments. Assessment and Remediation of Contaminated Sediment (ARCS) 

Program. U.S. Environmental Protection Agency Great Lakes National Program Office, Chicago, 

IL. EPA 905/R-96/001. March. 

U.S. EPA. 1996g. Coordination between RCRA Corrective Action and Closure and CERCLA Site 

Activities. U.S. Environmental Protection Agency Office of Solid Waste and Emergency 

Response, Washington, DC. OSWER Directive 9200.0-25. September. 

U.S. EPA. 1997a. CERCLA Coordination with Natural Resource Trustees. U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response, Washington, DC. OSWER 

Directive 9200.4-22A. 

U.S. EPA. 1997b. Community Advisory Group Toolkit for EPA Staff. U.S. Environmental Protection 

Agency, Office of Solid Waste and Emergency Response, Washington, DC. EPA 540/R-97/038. 

U.S. EPA. 1997c. Ecological Risk Assessment Guidance for Superfund: Process for Designing and 

Conducting Ecological Risk Assessment. Interim Final. U.S. Environmental Protection Agency 

Office of Solid Waste and Emergency Response, Washington, DC. EPA 540/R-97/006. June. 

U.S. EPA. 1997d. Rules of Thumb for Superfund Remedy Selection. U.S. Environmental Protection 

Agency Office of Solid Waste and Emergency Response, Washington, DC. EPA 540/R-97/013. 

U.S. EPA. 1998a. EPA’s Contaminated Sediment Management Strategy. U.S. Environmental 

Protection Agency Office of Water, Washington, DC. EPA 823/R-98/001. A fact sheet on this 

document is available on the Internet at http://www.epa.gov/OST/cs/stratefs.html. The strategy is 

available on the Internet at http://www.epa.gov/OST/cs/stratndx.html. 

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U.S. EPA. 1998b. The Plan to Enhance the Role of States and Tribes in the Superfund Program. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC. OSWER Directive 9375.3-03P. EPA 540/R-98/012. March. Available at 

http://www.epa.gov/superfund/states/strole/index.htm. 

U.S. EPA. 1998c. Guidance for Conducting Fish and Wildlife Consumption Surveys. U.S. 

Environmental Protection Agency Office of Water, Washington, DC. EPA 823/B-98/007. 

November. 

U.S. EPA. 1998d. Assessment and Remediation of Contaminated Sediments (ARCS) Program Guidance 

for In-Situ Subaqueous Capping of Contaminated Sediments. Prepared for the Great Lakes 

National Program Office, U.S. Environmental Protection Agency, Chicago, IL. EPA 905/B96/004. Available on the Internet at http://www.epa.gov/glnpo/sediment/iscmain. 

U.S. EPA. 1999a. A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other 

Remedy Selection Decision Documents. U.S. Environmental Protection Agency Office of Solid 

Waste and Emergency Response, Washington, DC. EPA 540/R-98/031. 

U.S. EPA. 1999b. Ecological Risk Assessment and Risk Management Principles for Superfund Sites. 

U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, 

Washington, DC. OSWER Directive 9285.7-28P. 

U.S. EPA. 1999c. A Community Guide to Superfund Risk Assessment – What’s it All about and How 

Can You Help? U.S. Environmental Protection Agency Office of Solid Waste and Emergency 

Response, Washington, DC. OSWER Directive 9285.7-30. EPA 540/K-99/003. December. 

U.S. EPA. 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and 

Underground Storage Tank Sites. U.S. EPA Environmental Protection Agency Office of Solid 

Waste and Emergency Response, Washington, DC. EPA 540/R-99/009. April. 

U.S. EPA. 2000a. Use of Non-Time-Critical Removal Authority in Superfund Response Actions. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC. OSWER Directive 9360.0-40P. February 14. 

U.S. EPA. 2000b. Peer Review Handbook, 2nd Edition. Science Policy Council, Washington DC 

EPA 100-B-00-001. December 

U.S. EPA. 2000c. Institutional Controls: A Site Manager’s Guide to Identifying, Evaluating, and 

Selecting Institutional Controls at Superfund and RCRA Corrective Action Cleanups. U.S. 

Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington, 

DC. OSWER Directive 9355.0-7FS-P. EPA 540-F-00-005. September. 

U.S. EPA. 2000d. Institutional Controls and Transfer of Real Property under CERCLA Section 120 

(h)(3)(A), (B), or (C). Federal Facilities Restoration and Reuse Office, Washington, DC. 

February. Available at: http://www.epa.gov/swer/ftrr/guide/htm. 

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U.S. EPA. 2000e. Guidance for the Data Quality Objectives Process. (EPA QA/G-4). Office of 

Environmental Information, Washington, DC. EPA 600/R-96/055. Also available on the Internet 

at http://www.epa.gov/quality/qa.docs.html. 

U.S. EPA. 2000f. Managing and Sampling and Analyzing Contaminants in Fish and Shellfish, Volume 

1. U.S. Environmental Protection Agency Office of Water. EPA 823/B-00/008. 

U.S. EPA. 2000g. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, 

Volume 1, Fish Sampling and Analysis, Third Edition. Office of Water. EPA 823/B-00/007. 

November. 

U.S. EPA. 2001a. Draft Report on the Incidence and Severity of Sediment Contamination in Surface 

Waters of the United States, National Sediment Quality Survey: Second Edition. U.S. 

Environmental Protection Agency Office of Water, Washington, DC. EPA 823/F-01/031. 

December. Estimated release 2003. 

U.S. EPA. 2001b. Enhancing State and Tribal Role Directive. U.S. Environmental Protection Agency 

Office of Emergency and Remedial Response, Washington, DC. OSWER Directive 9375.3-06P. 

Available at http://www.epa.gov/superfund/states/strole/index.htm. 

U.S. EPA. 2001c. Early and Meaningful Community Involvement. U.S. Environmental Protection 

Agency Office of Emergency and Remedial Response, Washington, DC. OSWER Directive 

9230.0-99. October. 

U.S. EPA. 2001d. Superfund Community Involvement Handbook and Toolkit. U.S. Environmental 

Protection Agency Office of Emergency and Remedial Response, Washington, DC. Available 

at http://www.epa.gov/superfund/resources. 

U.S. EPA. 2001e. Forum on Managing Contaminated Sediments at Hazardous Waste Sites. U.S. 

Environmental Protection Agency Office of Emergency and Remedial Response, Washington, 

DC. Proceedings available at http://www.epa.gov/superfund/new/sedforum.htm. 

U.S. EPA 2001f. Natural Recovery of Persistent Organics in Contaminated Sediments at the SangamoWeston/Twelvemile Creek/Lake Hartwell Superfund Site. Prepared by Batelle under contract to 

U.S. Environmental Protection Agency, National Risk Management Research Laboratory, 

Cincinnati, OH. 

U.S. EPA 2001g. Natural Recovery of Persistent Organics in Contaminated Sediments at the 

Wykoff/Eagle Harbor Superfund Site. Prepared by Battelle under contract to U.S. Environmental 

Protection Agency, National Risk Management Research Laboratory, Cincinnati, OH. 

U.S. EPA. 2001h. Comprehensive Five-Year Review Guidance. U.S. Environmental Protection Agency 

Office of Emergency and Remedial Response, Washington, DC. EPA 540/R-01/007. June. 

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Chapter 9: References 

U.S. EPA. 2001i. Monitored Natural Attenuation: USEPA Research program - An EPA Science 

Advisory Board Review. Environmental Engineering Committee of the EPA Science and 

Advisory Board. EPA-SAB-EEC-01-004. May. 

U.S. EPA. 2001j. Methods for Collection, Storage, and Manipulation of Sediments for Chemical and 

Toxicological Analyses: Technical Manual. U.S. Environmental Protection Agency Office of 

Water, Washington, DC. EPA 823/B-01/002. 

U.S. EPA. 2002a. Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites. 

U.S. Environmental Protection Agency Office of Emergency and Remedial Response, 

Washington, DC. OSWER Directive 9285.6-08. February. 

U.S. EPA. 2002b. Update: National Listing of Fish and Wildlife Advisories. U.S. Environmental 

Protection Agency Office of Water, Washington, DC. EPA 823/F-02/007. May. 

U.S. EPA. 2002c. Role of Background in the CERCLA Cleanup Program. U.S. Environmental 

Protection Agency Office of Solid Waste and Emergency Response, Washington, DC. OSWER 

Directive 9285.6-07P. April 26. 

U.S. EPA and USACE. 1977. Environmental Effects of Dredging. Technical Note EEDP-09-3. 

U.S. EPA and USACE. 1992. Evaluation of Dredged Material Proposed for Ocean Disposal: Testing 

Manual. U.S. Environmental Protection Agency Office of Marine and Estuarine Protection, 

Washington, DC, and U.S. Army Corps of Engineers, Washington, DC. EPA 503/8-91/001. 

February. 

U.S. EPA and USACE. 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the 

U.S. - Inland Testing Manual. U.S. Environmental Protection Agency Office of Water, 

Washington, DC, and U.S. Army Corps of Engineers, Washington, DC. EPA 823/B-98/004. 

U.S. EPA and USACE. 2000. A Guide to Developing and Documenting Cost Estimates During the 

Feasibility Study. EPA 540-R-00-002. U.S. Army Corps of Engineers Hazardous Toxic, and 

Radioactive Waste Center of Expertise, Omaha, Nebraska and U.S. Environmental Protection 

Agency Office of Emergency and Remedial Response, Washington, DC. July. Available at: 

www.epa.gov/oerrpage/superfund/resources/remedy/finaldoc.pdf. 

Van den Eede, E. 1994. Personal communication. Treatment and Disposal of Dredged Material, the 

Flemish Experience. Workshop Concerning Treatment and Disposal of Contaminated Dredged 

Material, 26-27 April 1994, Ghent, Belgium. 

Van Dillen, M., and W. Bruggeman. 1992. Development Programme Treatment Processes-Phase I 

(1989-1990). Institute for Inland Water Management and Waste Water Treatment, Lelystad, the 

Netherlands. 

Van Oostrum, R.W. 1992. Dredging of contaminated sediment between pre-dredging survey and 

treatment. In: Proc. of the International Symposium on Environmental Dredging, Buffalo, NY. 

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Chapter 9: References 

Wardlaw. 1993. Personal communication. 

Warner, G.F. 1977. On the Shapes of Passive Suspension-Feeders. In Keegan, B.F., P.O. Ceidigh, and 

P.J.S. Boaden, eds. Biology of Benthic Organisms. New York. 

Zappi, P.A., and D.F. Hayes. 1991. Innovative Technologies for Dredging Contaminated Sediments. 

Miscellaneous Paper EL-91-20. U.S. Army Corps of Engineers, Waterways Experiment Station, 

Vicksburg, MS. 

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