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could not be dredged because or failure to meet the criteria. 



This circumstance was particularly perplexing, considering that almost every 

 harbor and different type of waterbody in the United States had contaminated 

 sediments 29 , that NOAA had found toxic sediment, fish and shellfish 

 contamination to be of national proportions and that NOAA's National Status 

 and Trends Program had found the highest concentrations of organic chemicals, 

 heavy metals and pesticide residues in those areas closest in proximity to cities 

 and ports. 31 How was it that dredged materials from around the country 

 consistently appeared to be considered clean enough for ocean disposal at the 

 same time that contaminated sediments appeared to be widespread in the same 

 waterways that were being dredged. Obviously, how sediments were tested 

 played a major role in their characterization. 



The 1977 tests were problematic for a number of reasons. They include: 1) 

 the use of species in acute bioassays that were particularly hardy and tolerant of 

 pollutants; 2) the absence of important sensitive species used in tests: 3) the 

 unrepresentativeness of sediments to be dredged due to the small number of 

 samples taken; 4) the need to show statistical significant differences in mortality 

 and bioaccumulation between proposed dredged material sediments and "reference 

 sediments" with small number of data: 5) the short duration time for 

 bioaccumulation test, and 6) the lack of assessment for long-term sublethal, or 

 community effects. 



Other examples specific to the New York Bight region include the 

 following. Up until recently, the only contaminant for which a "bioaccumulation 

 criteria" existed was for total PCBs. Therefore, if there was bioaccumulation of 

 any contaminant other than PCBs in test organisms over a 10-day period of time 

 and the bioaccumulation levels was statistically significantly higher than the 

 bioaccumulation level in organisms exposed to reference sediments, no decision 



:, A.D. Little. 1987. Overview of Sediment Quality in the United States. 

 Prepared for the U.S. Environmental Protection Agency. NTTS # PB88-251384. 



"Ehler. Charles N. 1989. Prepared Statement of Charles N. Ehler. Director. 

 Office of Oceanography and Marine Assessment, NOAA before the Subcommittee 

 on Superfund. Ocean and Water Protection and the Subcommittee on 

 Environmental Protection. Committee on Environment and Public Works. 



''National Ocean Service. 1987. National Status and Trends Program for 

 Marine Environmental Quaiitv Progress Report. NOAA Technical Memorandum 

 NOS OMA 38. 



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