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5. Do you think that there is a need to better define the word contaminated? Do you 

 think that this will better address some of the problems associated with disposal of 

 these sediments? Also, do you feel that there is a need to define what constitutes a 

 clean sediment, and how clean is clean? 



Answer: As discussed in the answers to some of the previous questions, the EPA and 



the Corps are working to ensure that there is a uniform and scientifically 

 justifiable definition of what constitutes contaminated sediments. Under 

 existing criteria and regulations, regulatory agencies have an adequate 

 definition of what constitutes contamination. However, because the definition 

 is not the same for all of EPA regulatory programs there is considerable 

 public confusion about the definition. It is not so much that a new definition 

 is required but, rather, more outreach by EPA and the Corps to educate the 

 public and to build confidence in the reliability of the existing mechanisms for 

 identifying contamination. 



Regarding a definition of "clean sediment", clearly there is a need for EPA 

 and the Corps to work together to determine appropriate cleanup levels for 

 highly contaminated sediment sites. Again, the appropriate definition will 

 depend to a large extent on what your regulatory objectives are. For example, 

 are you trying to determine the appropriate level of clean up under 

 Superfund, whether dredged material is suitable for beneficial use, or whether 

 dredged material is suitable for ocean disposal? The answer to what is "clean" 

 sediment for each of these examples may vary. 



In each case, the definition of contaminated, as well as clean sediment should 

 be effects based and flexible enough to reflect real world conditions. 



6. How much is spent annually by Port Authorities to characterize dredged sediments? 

 Based upon these costs, do you feel that there is a need to develop a long term 

 management plan to better assess these sediments and ways to dispose of them? 



Answer: We do not have any specific information on the annual cost to Port 



Authorities for characterization of dredged sediment, although in many cases 

 it can be a significant component of undertaking a project. The Port 

 Authority of New York and New Jersey estimates that they spent $1 million 

 in connection with their pending permit application. The cost of testing is 

 particularly problematic for smaller public port authorities which do not have 

 the resources or expertise to undertake the tests. 



Long term dredged material management plans and federal contribution to 

 the construction of disposal areas could significantly limit the need for 

 individualized project testing and project by project decisionmaking. AAPA 

 strongly supported provisions of the Water Resources Development Act of 



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