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EPA, in consultation with the Corps, last year completed the "Evaluation of Dredged 

 Material Proposed for Ocean Disposal-Testing Manual," better known as the "Green Book". 

 The Green Book is structured for easy interpretation and representative marine organism 

 for exposure to potential contaminants in dredged material. The Green Book uses a "loose- 

 leaf' approach which will allow new procedures and methods to be added as they are 

 developed. The revised protocols will result in more stringent analysis of dredged material. 

 Congress needs to give the Green Book's long-awaited guidelines a chance to work and 

 avoid uprooting an effort that has taken years of study and millions of dollars to develop. 



The development of numerical sediment quality criteria continues to be a 

 controversial issue. EPA is in the process of working to develop numerical criteria for about 

 a half dozen pollutants. AAPA encourages EPA to convene the National Contaminated 

 Sediment Task Force mandated by WRDA '92, as soon as possible so that it can assist the 

 federal government to determine the need and a schedule for the development of numeric 

 sediment standards. AAPA will work with EPA and the Corps as they continue their work 

 on developing suitable criteria. For dredged material disposal decision-making purposes it 

 would be inappropriate at this juncture to use numeric criteria as "pass-fail" numbers, 

 replacing detailed site-specific analysis currently in use. Reliance on strict pollutant specific 

 numerical standards may lead to categorical elimination of the aquatic disposal option even 

 when it is the most environmentally preferable and cost effective option. 



A list of constituents in the sediment does not give an accurate picture of their 

 environmental significance, which is a function of a variety of complex factors. There are 

 natural variations in "background" levels of the various chemical constituents which appear 

 in sediments. The existence of the constituent is not alone enough to reach a conclusion 

 that it is causing a problem in the environment. Chemical and physical properties such as 

 temperature and sediment grain size interact to vary the bioavailability of a contaminant and 

 the impact that a specific constituent concentration may have on the environment. 



The manner in which sediment criteria are implemented is of critical importance to 

 the port industry. In their revision of the Green Book, EPA and the Corps deliberately 

 created a niche in the process for incorporation of numerical criteria as they are adopted. 

 The Green Book would use numerical criteria as a "screen," or a flashing yellow light, which 

 would indicate the need for biological testing, rather than as a "pass-fail" standard. AAPA 

 believes that this structure represents responsible use of criteria, and provides for 

 verification of the criteria validity through supplementary effects-based, biological testing. 



The Effectiveness of the Federal Ocean Disposal Program 



While the current laws and regulations are adequate to manage contaminated 

 sediments safely, implementation is lacking in two principal areas. The first, and the most 

 frustrating, is the regulatory delay and lack of strong leadership at the federal level to make 

 permit decisions. Our scientific ability to identify potential environmental problems has 



