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and for contaminated sites, to measure progress in cleaning them up -- 

 once criteria are in place. 



E. Standards for site cleanup/restoration 



For sediments that are already contaminated and need to be cleaned 

 up, a mechanism is needed to determine what triggers remediation. 

 Sediment quality standards would serve as a critical component of a set of 

 criteria that would be used to trigger the cleanup of a contaminated site. 

 Currently there exists little agreement or understanding of the extent to 

 which sediments must be cleaned up for purposes of achieving a 

 remediated site. Of course, cleanup can mean many things. It can mean 

 implementation of pollution prevention to halt further contamination and 

 allow natural processes to take their course. In some cases, it will mean 

 full-scale dredging and treatment of materials. Each site will need to be 

 evaluated individually. Used in conjunction with other factors or criteria, 

 sediment standards will serve to trigger remediation. 



Once a decision has been made, people charged with remediation 

 need to select a cleanup goal -- a level of de-contamination that will protect 

 human health and the environment. 



The debate about "how clean is clean" will occur in sediment 

 remediation, just as it has in ground water, surface water, and soil 

 remediation cases. 



Just as water quality criteria and drinking water Maximum 

 Contaminant Level Goals (MCLGs) serve as measures of cleanliness under 

 Superfund, so too should sediment quality standards (whether they are set 

 by states or by EPA). 



Concerns that these national standards, which are used to establish 

 "no adverse effects levels," will be too difficult to meet at Superfund and 

 other contamination sites are unfounded. Existing law already provides 

 mechanisms for establishing a cleanup goal when these standards are 

 unattainable. For example, under the CWA EPA has established a 

 carefully controlled set of variance provisions for water quality criteria 

 under which a State can apply a less protective criterion if it is not possible 

 or appropriate, for technical, scientific, or economic reasons, to meet the 

 State's standard at a particular site (40 CFR 131.10(g)(l)-(6)). 



Under Superfund, the President can select a cleanup action that will 

 not achieve the otherwise primary "applicable, relevant, and appropriate 

 requirements" (ARARs) of water quality criteria if, among other things, 



