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complies with applicable state water quality standards, the enforcement of 

 which, are in most cases, delegated from EPA to the state. 



Last year, the EPA and the Corps released a new testing manual, commonly 

 referred to as the "Green Book", that provides guidance and more stringent 

 testing guidelines for to the regions to use to determine whether proposed 

 ocean dumping meets EPA criteria. Uniform application of the Green Book 

 testing protocols should result in more consistent application of ocean 

 dumping criteria and standards around the country. The EPA and the Corps 

 are currently at work updating the "Gold Book" testing manual for coastal 

 waters which is also being designed to assure more consistency both among 

 the various coastal regions and between coastal and ocean waters. 



4. In your opinion, are sediments for ocean disposal required to meet a higher 



standard than land-based counterparts? Are the testing and standards for land- 

 based disposal comparable to that required for ocean disposal? Should the 

 standards be higher for ocean disposal? Why or why not? 



Answer: It is very difficult to compare the standards for ocean and land based disposal 



of sediments for two principal reasons: first, the sediment contaminants will 

 react differently depending on their disposal conditions (e.g. contaminants that 

 will bind to sediments in a water environment, may be oxidized and released 

 into the air when disposed on land); and, second because the governing 

 statutes which regulate different disposal media (e.g. Superfund, RCRA, ODA 

 and CWA) have different requirements, goals and objectives. It is clear, 

 however, that toxicity testing protocols designed under RCRA and Superfund 

 are not appropriate for dredged material. 



EPA has developed an internal Contaminated Sediments Task Force which 

 brings together representatives from the various program offices to develop, 

 as much as possible, a consistent approach to handling contaminated 

 sediments. AAPA strongly supports this EPA initiative. Legislative changes 

 may be necessary to clarify that the handling and disposal of marine sediments 

 should be regulated by EPA's Office of Water, in consultation with the Corps, 

 to ensure consistency in the management of dredged material. In addition, 

 EPA and the Corps should expand efforts to assess and compare the 

 environmental risks posed by disposal of dredged material on land, in water, 

 and in confined near-shore facilities. AAPA favors a regulatory regime which 

 requires the consideration of aU disposal alternatives with full consideration 

 of the relative risk they pose to the environment, as well as their cost. 



