5
Monitoring for Effectiveness: Current Practices and Proposed Improvements

MONITORING FOR EFFECTIVENESS

The effectiveness of environmental dredging in reducing risk, as predicted when the remedy was selected, can be verified only through monitoring. Monitoring includes

  • Monitoring of potential short-term risks due to dredging.

  • Verification that dredging has achieved its immediate target cleanup levels.

  • Long-term monitoring to determine whether remedial objectives have been or are likely to be achieved in the expected time frame.

Monitoring of effectiveness is an essential part of the remedy and should be proportional to the size of the project. Through careful monitoring it is possible to demonstrate whether environmental dredging minimizes risks to human and ecologic receptors during active operations and to judge the success of contaminant cleanup in decreasing risk after the cessation of active remedial operations. Monitoring is the only way to determine short-term and long-term compliance with remedialaction objectives and evaluate net risk reduction of the remediation, and it forms the basis of the 5-year performance reviews after cleanup. Be-



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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness 5 Monitoring for Effectiveness: Current Practices and Proposed Improvements MONITORING FOR EFFECTIVENESS The effectiveness of environmental dredging in reducing risk, as predicted when the remedy was selected, can be verified only through monitoring. Monitoring includes Monitoring of potential short-term risks due to dredging. Verification that dredging has achieved its immediate target cleanup levels. Long-term monitoring to determine whether remedial objectives have been or are likely to be achieved in the expected time frame. Monitoring of effectiveness is an essential part of the remedy and should be proportional to the size of the project. Through careful monitoring it is possible to demonstrate whether environmental dredging minimizes risks to human and ecologic receptors during active operations and to judge the success of contaminant cleanup in decreasing risk after the cessation of active remedial operations. Monitoring is the only way to determine short-term and long-term compliance with remedialaction objectives and evaluate net risk reduction of the remediation, and it forms the basis of the 5-year performance reviews after cleanup. Be-

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness cause sediments typically pose long-term risks, monitoring often must span decades to assess risk reduction. The ultimate goal of monitoring is protection—that is, ensuring that short-term and long-term risks are minimized, by providing sufficient information to judge that the remedy is effective, or to adapt site management to optimize the remedy’s performance to achieve risk-based objectives. Management adaptation may entail modification of dredging procedures—for example, if short-term exposures exceed expected magnitudes—or modification of the remedy itself by amendment or modification of the record of decision (ROD) if long-term risk reduction proceeds more slowly or more rapidly than expected. An effective sediment-monitoring plan takes into account the successive stages of sediment cleanup: site characterization; selection, planning, and implementation of the remedial action; effectiveness assessment; and adaptive management.1 Monitoring should build on the studies previously performed for the remedial investigation and feasibility study (RI/FS), which should have Determined the nature and extent of contamination and any trends in time (for example, due to natural recovery). Supported or developed a conceptual site model. Provided information to assess risks to the environment and people. Evaluated remedial alternatives, including a quantitative comparison of risks associated with implementation of each one. Once the remedy is selected and implementation begins, monitoring extends the record of site conditions into the future. MONITORING PRINCIPLES Monitoring should be based on and inform the conceptual site model. 1 In general, adaptive management is the testing of hypotheses and conclusions and re-evaluation of site assumptions and decisions as new information is gathered (see Chapter 6 for further discussion). It is an important component of the updating of the conceptual site model (EPA 2005a).

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness Appropriate metrics need to be chosen, measuring success against expectations based on the conceptual site model. Monitoring is an essential verification step, not an addon activity or a second remedial investigation. Effective monitoring of the remedy requires characterization of pre-remedial trends and reference conditions, in addition to post-remedial trends. Sufficient pre- and post-remedial sample sizes are needed, to allow for natural heterogeneity. The time span of pre- and post-remedial sampling needs to be sufficient to capture the time scale of recovery processes. Proper reference sites and conditions must be specified and monitored. Monitoring and the Conceptual Site Model Links between contamination, exposure, and risk can be highly complex, involving multiple physical, chemical, and biologic processes. A particular combination of these is present at each site. Monitoring protocols and media to be monitored will vary accordingly, and should be closely linked to site conceptual models that link site conditions with biologic exposures and effects (EPA 1998). The expectations of the Superfund ROD are a natural yardstick against which to judge effectiveness. Those expectations of short-term exposures and long-term risk reduction due to dredging should be based on the conceptual site model and its mathematical counterpart. Where site conceptual models are insufficiently developed, it is difficult to develop an understanding of the factors driving trends in sitemonitoring data. On major dredging sites, short-term and long-term expectations based on site models will have been developed as part of the feasibility study supporting remedy selection. Collecting data to test whether expectations have been fulfilled is part of the process of conceptual-model development, testing, and refinement that was begun with the initial site characterization. If the important cause-effect relationships between contaminant sources, transport mechanisms, exposure path-

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness ways, and receptors have been well characterized by the time a remedy is selected, including bioavailability and food-web relationships as applicable, and there has been sufficient pilot testing or other means of anticipating site-specific field conditions and implementation challenges, well-designed monitoring should indicate the remedy has performed as expected. If not, monitoring can help to identify important elements that are missing from the conceptual site model so that its predictions can be made more accurate and site management can be adapted accordingly, as recommended in EPA’s Contaminated Sediment Remediation Guidance (2005a). In monitoring of the effectiveness of a remedy, important transport mechanisms and exposure pathways to be monitored include not only the ones that control exposures and risks under normal conditions, but also the ones that may be triggered by dredging, such as releases that may occur during normal dredging operations or when debris or bedrock is encountered. Therefore, before selection and implementation of a remedy, the site investigation should thoroughly examine factors that would complicate dredging and include them in the conceptual model. Complicating site conditions and operational limitations can also be identified through pilot studies to verify the performance of the selected technology under site-specific conditions. Data collection is one of the more expensive aspects of site management (Box 5-1).2 Judicious use of the conceptual site model in designing the monitoring plan focuses data collection where it can best ensure protectiveness while conserving monitoring resources. Monitoring should target the key pathways and receptors necessary to determine whether remedial objectives have been met. If dredging is intended to reduce ecologic or human health risks, the conceptual site model can be used to focus sampling on locations and receptors that directly indicate risk related to the targeted sediments and contaminants and minimize spurious effects, such as increased body burdens in migratory species 2 In addition to the example provided in Box 5-1, see the breakdown of costs of the Hylebos Waterway and 2004 dredging at New Bedford Harbor presented in Chapter 2 (Figures 2-4 and 2-5). However, it should be noted that these costs may not be directly comparable; it is not clear, for example, whether the costs include design costs and long-term monitoring.

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness BOX 5-1 Estimated Monitoring Costs for Lower Fox River and Green Bay, Wisconsin, ROD Remedy The costs of construction monitoring (including verification sampling) and long-term monitoring (including an initial pre-dredging baseline survey of affected media and surveys of the same media continuing for decades after the remedy) for the ROD remedy for Operable Units 2-5 of the Lower Fox River and Green Bay, WI, have been estimated at $6 and $8 million, respectively (Shaw 2006). Together those costs exceed the estimated cost of engineering and construction support for the remedy, including development of design documentation, plans, and specifications. and species with wide home ranges that are due to unrelated exposures at remote locations. If dredging is intended to minimize water-column contaminant transport, the site model can be used to control for the effects of flow, temperature, seasonality, non-sediment-related stressors (such as point and nonpoint sources), and other ambient conditions to inform sampling plans and assist in interpreting the results. Monitoring decisions may be influenced by financial, jurisdictional, or political interests, even though they should be guided solely by the need to verify conceptual site models, inform remedy implementation, and to document when remedial objectives have been achieved. Cleanup negotiations between regulators and responsible parties can be contentious, and agreements on the scope of cleanups are often the results of a long and difficult process. The scope of post-remedial monitoring can also be established during those negotiations. The parties have few incentives to seek actively to establish whether a chosen remedial action had its intended effect. This paradigm, wherein both regulators and responsible parties may perceive that they have something to lose and nothing to gain in a robust post-remediation monitoring program, may be a reason for the lack of post-remediation confirmation sampling seen at some sites. Public-sector and private-sector designers of a monitoring plan may face strong pressures to demonstrate early success while controlling costs and may also feel pressure to divert remedial funding to support broader long-term natural-resource monitoring efforts. Those ancillary goals may be attractive to parties involved in designing a monitoring program, but the fundamental objectives of monitoring are to per-

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness form a fair and conclusive evaluation of remedy effectiveness and risk reduction, and resources and energy should be focused on this objective. Information developed from the monitoring program should be used to guide future decision-making in a manner which balances a realistic assessment of the projected environmental benefit relative to anticipated costs. Developing a body of well-designed site evaluations of dredging effectiveness will meet the broader programmatic objective of providing EPA and other lead agencies with invaluable information on strengths and weaknesses of dredging as a remedy—information that they can use in future remedial decision-making. Comparisons to Baseline Conditions To assess the effectiveness of the remedy, post-remedial monitoring should be compared with data trends and model forecasts developed before remedy selection. This requires that there be comparable datasets before (a “baseline”) and after dredging. As stated by EPA (2005a, page 8-2), During site characterization, the project manager should anticipate expected post-remedy monitoring needs to ensure that adequate baseline data are collected to allow comparison of future datasets. Monitoring plans should also be designed to allow comparison of results with model predictions that supported remedy selection. It is often difficult in practice for an effective monitoring plan to meet the above objectives. One important issue at Superfund megasites is that the time from initial site investigation to implementation of remedial measures can be 10 years or more; it is extremely difficult to ensure temporal and spatial consistency of baseline and post-remedial monitoring data, including data- quality assurance and control. Data collections that span many years can greatly complicate the selection of appropriate statistical tests for evaluating them. Those concerns are often manifested after the fact rather than being evident during the planning of the baseline and long-term monitoring programs.

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness Consistent with its role in supporting hypothesis-testing, the monitoring protocol should be rigorous enough to allow managers to evaluate critically the potential adverse effects of dredging on human and ecologic receptors and potential risk reductions due to removal of contaminated sediment. For example, proper reference sites or reference conditions should be established to allow comparison of affected media with pre-dredging or nondredged controls. Appropriate sample sizes should be determined from estimates of variability derived from pilot studies or other sources of data. In particular, the natural heterogeneity of biologic systems can be substantial and should be explicitly accounted for in defining sample sizes. CURRENT MONITORING PRACTICES According to Elzinga et al. (1998, as referenced in EPA 2004), monitoring is “the collection and analysis of repeated observations or measurements to evaluate changes in condition and progress toward meeting a management objective.” Monitoring at Superfund sites is typically directed toward evaluation of the performance of a remedy and whatever environmental protections are in place during implementation of the remedy. Monitoring may include the collection of samples or real-time metered data During implementation of the remedy to assess immediate human health or environmental effects. Soon after implementation to determine compliance with cleanup levels or other short-term objectives. Over time to evaluate the achievement of the long-term remedial-action objectives, the need for maintenance or repair, and the continued effectiveness of the remedy and associated source control. Ideally, the monitoring parameters measured are linked to site-specific risk factors so that success (or lack of success) of the remedy is evident and directly informs management of the site. There are no absolute requirements for monitoring elements or techniques, but a number of guidance documents have been published (Fredette et al. 1990; EPA/USACE 1998; EPA 2001a, 2004, 2005a) to identify relevant meas-

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness urements and techniques and to guide the design of monitoring programs for a contaminated sediment site undergoing remediation. Monitoring Parameters and Techniques Monitoring involves combinations of physical, chemical, and biologic methods. Three critical lines of evidence that increasingly define successful sediment remediation include sediment physical stability, sediment chemical stability (lack of movement of contaminants from the sediment to the water column), and biologic-ecologic integrity. These three concepts are integral components of remedy evaluation, and monitoring should use techniques sufficient to measure progress toward these end points. A variety of techniques and measurement parameters exist for the characterization of the nature, extent, and potential effects of sediments. These techniques range from relatively simple and quick to elaborate and time consuming (e.g., EPA 2001a; Wenning et al. 2005). Several of the techniques are described below and summarized in Box 5-2. Physical Techniques Available physical techniques include direct sampling of sediment for laboratory analysis of geophysical properties, core sampling to identify sediment layering or the presence of debris, side scan sonar to develop high resolution maps of bottom contours, acoustic sub-bottom profilers or magnetometers to map sub-bottom characteristics, remote sensing to document vegetative cover or other characteristics, videography or photography to document bottom features or shallow sediment profile characteristics, and instrumentation to measure environmental conditions (such as temperature and turbidity) or flow characteristics that may affect sediment and suspended solids transport. For example, sediment-profile imaging (a photographic technique) of surface (10-20 cm) characteristics can be conducted to establish various parameters including the depth of bioturbation, the depth of an oxygenated layer, general benthic community type and degree of recovery, or hydrogen sulfide gas production (see Figure 5-1 for an example). Other remote

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness BOX 5-2 Common Physical, Chemical, and Biologic Measurements Used To Characterize Contaminated Sediments Common physical measurements include Sediment geophysical properties, such as bulk density, particle size, and shear strength. Pre-dredging and post-dredging bottom elevations, and sediment bedforms. Sediment layering, such as depth of disturbance or bioturbation, presence of gas bubbles, redox layers, and interfaces between sediment of different textures. Debris-field mapping (location, density, and size). Conductivity, temperature, turbidity, and suspended particles under various flow conditions. Stream velocities. Common chemical measurements include Water-column parameters (such as dissolved oxygen and total and dissolved chemicals under various flow conditions). Surface- and subsurface -sediment chemistry, including magnitude, distribution, and depth of contamination. Pore water contaminant concentrations. Bioavailable fractions of contaminants in sediment, on the basis of organic-carbon normalization or acid volatile sulfide (AVS) analysis. Tissue contaminant concentrations including tissues ingested by humans (in field collected or exposed aquatic organisms or plants) or tissue surrogates. Air quality (including odor) during construction of remedy or handling of dredged material. Common biologic measurements include Benthic invertebrate community structure (including abundance, diversity, and other structural or functional indexes). Toxicity (acute and chronic effects measured in the laboratory or field). Aquatic or wetland plant community structure (including species composition and percentage of cover). Fisheries status (including size, abundance, reproductive status, and incidence of lesions or parasites).

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness FIGURE 5-1 Sediment profile imagery (SPI) equipment (two left photos) and sediment profile photograph (right) from New Bedford Harbor Superfund site (the outer harbor is the area of the site with the least contamination). This equipment is used as part of the long-term monitoring program at the site to assess benthic quality rapidly and augment traditional benthic survey techniques that entail sieving and enumeration. Source: W. Nelson, U.S. Environmental Protection Agency. sensing techniques, such as lidar (light detection and ranging) can be used to map large-scale site characteristics, including the extent of eel grass beds or other vegetative cover. Assessments of physical stability of sediments (which translates into the likelihood for sediments to be dislodged and transported by erosive events) are based on site uses, hydrology and geomorphology, sediment bed descriptions (radio dating deposits, stratigraphy, and physical characteristics), and measurement of sediment transport and sediment bed dynamics (erodability or bed elevation changes) (Bohlen and Erickson 2006). Chemical Monitoring Chemical monitoring can address multiple media—including air, sediment, water, biota, groundwater, and pore water—and can be designed to evaluate specific phases of chemicals of concern (for example, if they are dissolved or suspended in association with solids). It is impor-

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness tant to monitor those parameters that affect chemical bioavailability, such as total and dissolved organic carbon, acid volatile sulfides (AVSs), grain size, and pore water fractions because organisms are exposed only to the bioavailable fraction (NRC 2003). The relationship between chemical concentrations, the bioavailable fraction, and toxic effects is the foundation for establishing sediment quality guidelines (see next section). Chemical sampling may involve in situ instrumentation for water, single-point grab samples of water or sediment obtained with various devices, or use of samplers that integrate chemistry over time or space (such as sediment traps, composite water samplers, and peepers). Rapid chemical screening techniques that use immunoassay response (enzyme-linked immunosorbent assays [ELISA]) or chemical fluorescence to document relative exposures have also been developed, but these are generally single-contaminant or contaminant-class tests, and few rapid field screening techniques are available for measuring a broad array of contaminants. Some analytic methods for environmental samples can be time-consuming, labor-intensive, and expensive. For example, chemical measurements for persistent organic contaminants in sediments—such as polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAHs), and DDT—require extraction, cleanup, and instrument analyses with gas chromatography or mass spectrometry. None of those measurements is rapid or performed conveniently in the field. As with sediments, the chemical analysis of biologic samples requires extraction, cleanup, and instrument techniques. Replicate measurements are necessary for both sediment samples and biologic tests because of inherent variability. Newer techniques have been developed for deployment of manufactured materials in the form of passive sampling devices (such as semipermeable-membrane devices, solid-phase microextraction fibers, and Tenax) that can mimic biologic exposure to and tissue uptake of contaminants from water, pore water, or sediments. For example, semipermeable membrane devices (SPMDs) have been widely used in environmental applications since the early 1990s (Huckins et al. 1990; 1993) and applied at Superfund sites to monitor dissolved hydrophobic contaminants and estimate water column concentrations of these contaminants (e.g., Hofelt and Shea 1997; Weston 2005). Polyethylene devices (PEDs) passively sample hydrophobic organic compounds in the aqueous phase.

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