4
Evaluation of Dredging Effectiveness: What Has Experience Taught Us?

INTRODUCTION

Over the last 20 years, various contaminated sediment sites have been remediated in whole or in part through dredging. The committee examined 26 dredging projects to evaluate whether dredging was able to meet short-term and long-term goals. Short-term goals are defined as cleanup levels that can be measured during or immediately post-dredging to verify the effective implementation of the remediation. The ability to maintain cleanup levels in the long term is ideally linked to the achievement of long-term risk-based goals or remedial action objectives. Appendix C presents the various sites’ cleanup levels and remedial action objectives and describes whether they were achieved at individual sites. Taken as a whole, the projects indicate what can and cannot be achieved with dredging and the conditions that favor or discourage the use of dredging.

Evidence that dredging projects led to the achievement of long-term remedial action objectives and did so within expected or projected time frames is generally lacking. It was often not possible to evaluate long-term remedy performance relative to remedial action objectives because of insufficient post-remediation data, quality, or availability or because of lack of an equivalent pre-remediation dataset. Post-remediation



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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness 4 Evaluation of Dredging Effectiveness: What Has Experience Taught Us? INTRODUCTION Over the last 20 years, various contaminated sediment sites have been remediated in whole or in part through dredging. The committee examined 26 dredging projects to evaluate whether dredging was able to meet short-term and long-term goals. Short-term goals are defined as cleanup levels that can be measured during or immediately post-dredging to verify the effective implementation of the remediation. The ability to maintain cleanup levels in the long term is ideally linked to the achievement of long-term risk-based goals or remedial action objectives. Appendix C presents the various sites’ cleanup levels and remedial action objectives and describes whether they were achieved at individual sites. Taken as a whole, the projects indicate what can and cannot be achieved with dredging and the conditions that favor or discourage the use of dredging. Evidence that dredging projects led to the achievement of long-term remedial action objectives and did so within expected or projected time frames is generally lacking. It was often not possible to evaluate long-term remedy performance relative to remedial action objectives because of insufficient post-remediation data, quality, or availability or because of lack of an equivalent pre-remediation dataset. Post-remediation

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness conditions are always influenced by long-term natural attenuation processes and ongoing sources of contaminations if they exist, so long-term monitoring—over decades—may be needed to establish effectiveness; few of the sites reviewed by the committee have reached that level of maturity. Not counting the 5 pilot studies or hot-spot removal actions, about one half of the sites apparently did not achieve remedial action objectives or had inadequate monitoring to judge performance relative to remedial action objectives. Insufficient time has elapsed to judge achievement of remedial action objectives in approximately one quarter of the sites. The remaining sites apparently met remedial action objectives although the extent to which those remedial action objectives achieve long-term risk reduction may not be known. There were often sufficient data to evaluate performance relative to cleanup levels or short-term implementation goals, but the relationship of these measures to long-term risk reduction was often not clear. An examination of Appendix C shows that many sites achieved cleanup levels; however, many were operational goals (mass removal or dredging to elevation) rather than contaminant-specific goals. Natural processes are always modifying conditions at a site; their influence can be difficult or impossible to separate from the remedial action, particularly when control or reference sites are not monitored before and after remediation. Conditions also are often influenced by the implementation of combined remedies, such as dredging and capping, which complicate the assessment of the performance of dredging alone. Thus, the committee was unable to evaluate the effectiveness of dredging alone at most sites. Experiences at the sites can nevertheless inform remedial project managers as to what may be achievable with dredging and what site and operational factors may limit dredging effectiveness or contribute to its success. Experience is especially useful in identifying factors that contribute to success or failure of dredging to meet short-term cleanup levels because monitoring has been conducted at most sites to judge performance relative to these standards. The ability to meet chemical-specific cleanup levels, however, does not in itself mean the ability to meet long-term risk-reduction targets or indicate the time frame over which any such targets might be met. This chapter discusses the lessons learned from sites where dredging was conducted and uses specific examples to

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness illustrate them. It also provides recommendations regarding implementation of successful remediation with dredging. DATA AVAILABILITY AND ACCESSIBILITY The potential utility of a review of remedial effectiveness is governed by the availability of pre-remediation and post-remediation monitoring data. That issue has three components: whether data were acquired at a site, whether the data are available for review, and whether the data are sufficient to support conclusions about effectiveness. The goal of acquiring data for this type of analysis appears relatively simple: collect and evaluate pre-remediation and post-remediation monitoring data on concentrations and effects from Superfund sites. However, obtaining this information is surprisingly difficult.1,2 1 For example, the post-dredging sediment concentrations at the Waukegan Harbor, IL, Superfund site were of interest. In response to the committee’s request for these data, the U.S. Environmental Protection Agency (EPA) stated only “Post-Cleanup: 1/1/2005, Ave. 2.5 ppm (Source: RPM),” with no supporting data (EPA 2006a [OMC Waukegan Harbor Site, May 15, 2006]). To pursue sediment data further, the committee reviewed the site’s 5-year reviews (EPA 1997a, 2002). The 1997 5-year review states that “confirmation sampling was taken at the base of dredge to verify that contaminants levels required for this cleanup were met.” However, the sampling did not include chemical analyses of contaminant levels in the sediment (Canonie Environmental 1996). The 2002 5-year review does not indicate that any post-remediation monitoring of the harbor sediments had been conducted. However, another literature search indicated that EPA contaminants studied in harbor sediments collected in 1996, a few years after dredging (EPA 1999) and again in 2003 (ILDPH/ATSDR 2004). 2 For example, the post-dredging sediment concentrations at the Bayou Bonfouca, LA, Superfund site were of interest. In EPA’s summary to the committee (EPA 2006a [Bayou Bonfouca Superfund site, May 12, 2006]), they indicate that COC concentration data in sediment and biota are unavailable. The “monitoring” section in EPA’s summary refers only to a study by the Hazardous Substance Research Center S&SW which contains an analysis of remedy performance but not the raw monitoring data. However, the conclusion contains an excerpted paragraph from a 2003 report on the site (EPA 2003a) that indicates that post-dredging sediment samples were collected (a portion of the 2003 report [without sample locations or relation to the dredging site] was provided). The locations were later received from EPA. To pursue obtaining sediment data further, the

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness The amount, frequency, and type of data collected at dredging sites are highly variable. Some of the earlier sites had very little post-dredging monitoring. For example, Bayou Bonfouca, LA, and Outboard Marine Corporation, IL, did not sample sediment concentrations immediately after dredging (see footnotes 1 and 2). Marathon Battery, NY, is an exception in that sediment and biota concentrations were collected and bioaccumulation was tested, but obtaining monitoring data proved difficult, requiring several iterations, and ultimately the committee could not access the full range of reports. At some more recent sites, dredging is supported and guided by chemical confirmation sampling, and the resulting data are accessible. For example, the U.S. Environmental Protection Agency (EPA) provided the committee concentration and location data on the recently completed dredging in the Grasse River, NY, and Hylebos Waterway in Commencement Bay, WA, including date, location coordinates, and chemical concentration information. Information on the operations and sampling and the monitoring results at pilot projects (such as conducted at the Grasse River, NY; Fox River, WI; and Lavaca Bay, TX, sites) are often well documented, as would be expected from studies specifically intended to document remedial effectiveness on a smaller scale. Data and reports from remediation sites are often held by various entities (including EPA, consultants, states, and responsible parties), and site’s 5-year reviews (EPA 1996a, 2006b; CH2M Hill 2001) were examined. The 2001 5-year review (the first to address the dredging activity) states that “no monitoring of the water level or quality conditions in the bayou are currently conducted—and no water quality data has been collected in the bayou adjacent to the site since the end of the source removal remedial action in 1995.” However, it also states that “the swimming and sediment contact advisory remains in effect based on the sediment samples collected [by the State of Louisiana] in 1997.” The 5-year review (CH2M Hill 2001) does not provide these sampling data or indicate locations or average concentrations of the samples. Later efforts to obtain the data through EPA were not successful. The 2006 5-year review indicates that sediment samples were taken after Hurricane Katrina in 2005. The post-hurricane sampling report was not provided to the committee, but the data (without sample locations) were provided in the 2006 5-year review. The post-hurricane report (CH2MHILL 2006), with sample locations, was later requested and acquired from EPA.

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness this complicated the compilation of information. Committee requests for data on sites were sent to Superfund Headquarters, which did not have them and forwarded the requests to project managers in the EPA region who were responsible for a particular site (although these managers may or may not have been in that position during the remediation). The data might not be held by the EPA region, but instead may reside with the contractors that performed the work or the responsible parties that funded the work. Some data at sites where remedial actions had been completed are archived or not readily retrievable. Thus, even when information was available to EPA it might have been inaccessible. In some cases, reports containing monitoring data and interpretations were held by the responsible parties but EPA wished not to have them released because sensitive negotiations were under way. When reports and data were available, they may have been reproduced only on paper although they were originally produced electronically. Such conditions severely limit distribution and faithful replication of information, because many site documents rely on large-scale maps in color. The ability to access reports and data via public Web sites was generally extremely limited, but there were exceptions. The mid-Atlantic EPA Region 3 has each site’s administrative records on line, and this permits the public and researchers to access site files electronically (although typically these files are in a scanned, nonnative format).3 Public information is available on all Superfund sites via the CERCLIS database, which frequently contains a site’s record of decision and 5-year reviews, if available. It was presumed that a site’s 5-year review would contain explicit statements of the sampling that had been conducted and provide, at a minimum, concentration and location data on sampling, but the committee was surprised to see that that was not necessarily the case.1,2 Comments regarding the ready public accessibility of electronic data may seem trivial. However, pre-remediation and post-remediation information is the end result of massive planning, implementation, and 3 The administrative records contain much information that is ancillary to understanding site conditions (for example, e-mails, records of phone discussions, submitted comments, and written communications among states, agencies, and responsible parties). Those materials are important for maintaining a transparent decision-making process, but the primary data reports and summaries are most important for reviewing remedial effectiveness.

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness data collection efforts that typically have involved large expenditures of public resources (whether the expenditures result from remediation itself or from the establishment of agreements with responsible parties who conduct it). Provision of pre-remediation and post-remediation data on chemicals of concern in an accessible, intuitive manner that defines collection efforts and results is a prerequisite to reviewing and understanding the results of remedial projects. An issue related to the availability (or lack) of complete sampling data is the need to rely on data summaries and various site reports to evaluate pre- and post-remediation results. At times the committee relied on reports and summaries that did not convey the necessary raw data to confirm summary statistics. That is because the committee did not have access to the primary sources or the resources to complete an ad-hoc reassembly and evaluation of all the information. A note of caution relevant to this and other studies that summarize site information is that data on concentrations and effects should be collected consistently over time (for example, from the same locations, media, depth interval, and developed with similar techniques and protocols) to be most useful. Summary statistics may not be derived from similar datasets and reports may have incomplete annotation on sample location (for example, the relation of the samples to the dredging footprint), sampling protocols, and chemical analyses. Over time, analytical methods, contractors, sampling locations, and sampling methods can change. These changes complicate pre- and post-remediation comparisons. When possible, the committee provides information on these issues. DREDGING EFFECTIVENESS Dredging to Remove Contaminant Mass The direct effect of dredging is the removal of sediment and its associated contaminant mass. Experience at a variety of sites has shown that dredging is effective at removing contaminant mass. Where sediments are subject to scour by storm or other high-flow events, buried contaminated sediment may be the source of future exposure and risk. In such cases, mass removal may result in risk reduction because the future

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness exposure and transport of sediment have been thwarted (see Chapter 2 for additional discussion). For example, a demonstration dredging project was conducted to remove a deposit (Deposit N) contaminated with polychlorinated biphenyls (PCBs) in a high-velocity reach of the Lower Fox River, WI, in 1998 and 1999. PCB contamination in sediments of the river is the result of historical wastewater discharge from the manufacture and recycling of carbonless copy paper incorporating Aroclor 1242. The objective of the Deposit N demonstration was to remove contaminated sediment and leave no more than 3-6 in. of residual material in place while minimizing resuspension and offsite loss of sediment. Dredging to target elevations in 1998 and 1999 resulted in the removal of 112 kg of PCBs, or 78% of the pre-dredging inventory (Foth and Van Dyke 2000). Mass removal may have been an appropriate cleanup objective if there was the potential for future mobilization and transport of the PCBs. Simple mass removal, however, may not reduce risk. For example, the non-time-critical removal action conducted in 1995 in the Grasse River in Massena, NY, had the objective of removing much of the PCB mass that was in the vicinity of an outfall. PCBs had been in use at the adjacent Alcoa facility and were introduced into the river through the outfall and from other sources. It was estimated that this localized removal of about 2,500 cy removed 27% of the PCB mass from the entire study area, consisting of several miles of river (BBL 1995). Despite removal of as much as 98% of the targeted contaminant mass (Thibodeaux and Duckworth 1999), no measurable reduction in water-column or fish concentrations of PCBs was noted. Site characterization and assessment efforts have led to the conclusion that water-column PCB concentrations are related, at least during low-flow periods, to surficial sediment concentrations of PCBs throughout the river and that removal of buried mass does not have a major influence on water-column concentrations (Ortiz et al. 2004). The removal may still have been warranted to avoid potential scouring during high-flow conditions, but risk reduction was not achieved during base flow conditions. Dredging to Reduce Risk A more complete assessment of dredging effectiveness would include evaluation of long-term risk reduction in addition to mass removal

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness or performance relative to cleanup levels. Although few sites have sufficiently complete datasets, dredging has apparently resulted in risk reduction in some cases, including at some sites with long-term datasets. Lake Jarnsjon, Sweden The Lake Jarnsjon site was remediated in 1993 and 1994. The pre-dredging surface sediment (0-40 cm) PCB concentrations had a geometric mean of 5.0 mg/kg (n=12; range 0.4 to 30.7 mg/kg) in 1990. Following remediation, the surface sediment (0-20 cm) concentrations in 1994 were significantly reduced and had a geometric mean of 0.060 mg/kg (n=54; range 0.01 to 0.85 mg/kg) (Bremle et al 1998a). Out of 54 defined subareas, one exceeded 0.5 mg/kg dry weight (set as the highest acceptable level to be left in the sediment); 20% of the sediment areas had PCB levels higher than 0.2 mg/kg dry weight, the remediation objective was set at 25% (Bremle et al 1998b). Fish-tissue PCB concentrations declined after remediation although post-dredging monitoring did not take place until 2 years after dredging. Concentrations did not, however, decrease to those upstream of the contaminated area. In their report, Bremle and Larsson (1998) compare fish concentrations in the remediated lake to fish in upstream areas and conclude that “fish from all the locations in 1996 had lower PCB concentration than in 1991 [dredging occurred in the summers of 1993 and 1994]. The most pronounced decrease was observed in the remediated lake, where levels in fish were halved. The main reason for the reduced levels was the remediation.” However, the authors also state that “the reason for the decline of PCB in fish could be decreased atmospheric deposition and thus lowered loadings of PCB to the freshwater.” The comparisons in the study benefited from the use of a reference site that indicated background declines in fish-tissue concentrations; these declines have been seen elsewhere as well (Stow et al. 1995). In that regard, Bremle and Larsson (1998) state that …the results show that if a remedial action is to be evaluated and the process is extended over several years, changes in background contamination must be taken into account. After a remedial action, the results need to be followed over several years to show if it has

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness been successful, which has not yet been the case in the present study. It also stresses the importance of using reference sites, to compare the results from the remedial area. A decrease in overall background contamination could otherwise well be interpreted as a result of the remedial action only. Black River, Ohio At the Black River, in Lorain, OH, sediment was contaminated with polycyclic aromatic hydrocarbons (PAHs) as a result of effluent from a steel-plant coking facility. In 1983, the coking facility closed. Dredging occurred from late 1989 to early 1990 below the Kobe Steel outfalls at river miles 2.83-3.55 (EPA 2007a). In the early 1980s, PAH compounds were detected in sediments at high concentrations, and the brown bullhead population had high rates of liver cancer and pre-cancerous lesions. Since closure of the facility and dredging, PAH concentrations in surface sediments, fish PAH residues, and neoplasm frequencies in fish have declined (Baumann 2000). As shown in Figure 4-1, a decrease in cancer at the site was noted immediately after the plant closure. An increase in cancer was also noted immediately after dredging and was probably due to the exposure of fish and their prey to higher concentrations of PAHs in sediment and water during dredging. Later sampling, however, showed decreases in cancer, suggesting that the increase during dredging was a short-term phenomena. Within 5 years after remediation, the cancer incidence was lower than the pre-dredging data, presumably as a result of the dredging. However, it is unclear to what extent continued natural attenuation, as evidenced by the reduction in observed cancer after plant closure but before dredging, could have reduced cancer incidence in the same time frame. Marathon Battery, New York The ability to achieve remedial action objectives and long-term risk reduction with dredging was demonstrated at Foundry Cove of the Marathon Battery, NY, site. Foundry Cove is a small body of water adjacent to the Hudson River about 85 km north of New York City. The

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness FIGURE 4-1 Prevalence of cancer and pre-cancerous lesions in Black River bullheads before and after dredging. The primary source of contamination was shut down in 1983, and dredging occurred in 1989-1990. Source: Adapted from Baumann 2000. Marathon Battery Company discharged cadmium, nickel, and cobalt during the manufacture of batteries through the plant’s outfalls, located beneath the Cold Spring pier and in the East Foundry Cove Marsh. About 50 metric tons of nickel-cadmium waste is estimated to have been discharged from 1953 to 1971 (Levinton et al. 2006). The site comprises six separate regions. West Foundry Cove borders the eastern shore of the Hudson River and is connected to East Foundry Cove via an opening in a railroad trestle. The most contaminated sites are East Foundry Cove Marsh (13 acres), East Foundry Cove (36 acres), East Foundry Pond (3 ac), and the Cold Spring Pier area (~5 acres) that borders the Hudson River to the north. Constitution Marsh (281 acres) is to the south and is less contaminated (see Figure 4-2). As summarized in the record of decision and summary to the committee, core sediment samples collected from East Foundry Cove during the remedial investigation ranged from 0.29 to 2700 mg/kg cadmium and had

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness FIGURE 4-2 Map showing the Marathon Battery Superfund site on the Hudson River, NY adjacent to Cold Spring, NY. Dredging was conducted in the Cold Spring Pier area, East Foundry Cove, and East Foundry Pond. East Foundry Cove Marsh was excavated and capped; Constitution Marsh was not remediated. Source: EPA 2006a (Marathon Battery Superfund Site, May 10, 2006). a mean of 179.3 mg/kg (median = 5.6 mg/kg).4 Samples collected in the Pier area (a much larger area than what was actually dredged) ranged from 1.2 to 1,030 mg/kg for cadmium and had a mean of 12.6 mg/kg 4 These data are for all depths. The mean for each sampled depth is 439.4 mg/kg (0-10 cm), 50.5 mg/kg (10-25 cm), and 2.1 mg/kg (25-50 cm). This sampling was apparently conducted in 1984 by Acres in support of the remedial investigation (EPA 1989b). These summary statistics from EPA do not include other sampling data collected in 1989 (USACE 1992).

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness Burton, G.A., B.L. Stemmer, K.L. Winks, P.E. Ross, and L.C. Burnett. 1989. A multitrophic level evaluation of sediment toxicity in Waukegan and Indiana Harbors. Environ. Toxicol. Chem. 8(11):1057-1066. Canonie Environmental. 1996. Waukegan Harbor Remedial Action, Waukegan, IL. Construction Completion Report. Canonie Environmental. July 3, 1996. CH2M Hill. 2001. Five-Year Review Report: Second Five-Year Review Report For Bayou Bonfouca Superfund Site, Slidell, St. Tammany Parish, Louisiana. Prepared by CH2M Hill, for U.S. Environmental Protection Agency, Region 6, Dallas, TX. June 2001 [online]. Available: http://epa.gov/earth1r6/6sf/pdffiles/bayou_bonfouca_5_year.pdf [accessed Jan. 10, 2007]. CH2M Hill. 2005. Lower Fox River Operable Unit 1 Pre-design—Basis of Design. Prepared for WTM I Company, by CH2MHill, Milwaukee, WI. March 2005. CH2M Hill. 2006. Bayou Bonfouca - Hurricane Impacts Evaluation. Memorandum to Michael Herbert, EPA Region 6, from Renee Ryan and Scot McKinley, CH2M Hill. Project No. 334872.ET.02. January 25, 2006. Chemical Waste Management. 1997. Completion Report for Marine Remedial Action on the United Heckathorn Superfund Site, Richmond, CA. October 1997. Connolly, J., V. Chang, and L. McShea. 2006. Grasse River Remedial Options Pilot Study (ROPS) Findings from Dredging Activities. Presentation at the Second Meeting on Sediment Dredging at Superfund Megasites, June 7, 2006, Irvine, CA. Connolly, J., J. Quadrini, and L. McShea. 2007. Overview of the 2005 Grasse River Remedial Options Pilot Study. Presentation at the 4th International Conference on Remediation of Contaminated Sediments, January 22-25, 2007, Savannah, GA. Cressie, N.A.C. 1991. Statistics for Spatial Data. New York: Wiley. 900 pp. Dalton, Olmsted & Fuglevand, Inc. 2006. Remediation Action Construction Report, Part 1: Head of Hylebos Waterway Problem Area Commencement Bay Nearshore/Tideflats Superfund Site Tacoma, Washington, Review Draft, July 21, 2006. Prepared for Head of Hylebos Cleanup Group, Arkema, Inc, General Metals of Tacoma, Inc, by Dalton, Olmsted & Fuglevand, Inc., Kirkland, WA. July 21, 2006. Dickerson, D., and J. Brown. 2006. Case Study on New Bedford Harbor. Presentation at the First Meeting on Sediment Dredging at Superfund Megasites, March 22, 2006, Washington DC. Diggle, P.J., and P.J. Ribeiro. 2007. Model-Based Geostatistics. New York: Springer. EcoChem, Inc. 2005. Duwamish/Diagonal CSO/SD Sediment Remediation Project Closure Report. Prepared for King County Department of Natural Resources and Parks, Elliott Bay/Duwamish Restoration Program Panel, Seat

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Sediment Dredging at Superfund Megasites: Assessing the Effectiveness tle, WA. Panel Publication 39. July 2005 [online]. Available: http://dnr.metrokc.gov/WTD/duwamish/diagonal.htm [accessed Jan. 3, 2006]. EPA (U.S. Environmental Protection Agency). 1984. Record of Decision: Outboard Marine Corp. EPA ID: ILD000802827 OU 01 Waukegan, IL. EPA/ROD/R05-84/007. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/r0584007.pdf [accessed Jan. 9, 2007]. EPA (U.S. Environmental Protection Agency). 1987. EPA Superfund Record of Decision: Bayou Bonfouca, EPA ID: LAD980745632, OU 01, Slidell, LA. EPA/ROD/R06-87/019. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/r0687019.pdf [accessed Aug. 7, 2006]. EPA (U.S. Environmental Protection Agency). 1989a. Record of Decision: Marathon Battery Corp. EPA ID: NYD010959757. OU 02, Cold Springs, NY. EPA/ROD/R02-89/097. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/r0289097.pdf [accessed Jan. 9, 2007]. EPA (U.S. Environmental Protection Agency). 1989b. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual (Part A, Interim Final). EPA/540/1-89/002. Office of Emergency and Remedial Response, U.S. Environmental Protection Agency, Washington, DC. December 1989 [online]. Available: http://rais.ornl.gov/homepage/HHEMA.pdf [accessed May 9, 2007]. EPA (U.S. Environmental Protection Agency). 1989c. Record of Decision: Commencement Bay, Near Shore/Tide Flats. EPA ID: WAD980726368 OU 01, 05, Pierce County, WA. EPA/ROD/R10-89/020. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/r1089020.pdf. [accessed Jan. 9, 2007]. EPA (U.S. Environmental Protection Agency). 1990a. Record of Decision: New Bedford. EPA ID: MAD980731335, OU 02, New Bedford, MA. EPA/ROD/R01-90/045. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/r0190045.pdf [accessed Jan. 9, 2007]. EPA (U.S. Environmental Protection Agency). 1990b. EPA Superfund Explanation of Significant Differences: Bayou Bonfouca. EPA ID: LAD980745632, OU 01, Slidell, LA. EPA/ESD/R06-90/900. Superfund Information Systems, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/sites/rods/fulltext/e0690900.pdf [accessed Jan. 9, 2007]. EPA (U.S. Environmental Protection Agency). 1991. Record of Decision: General Motors (Central Foundry Division). EPA ID: NYD091972554. OU 01 Massena, NY. EPA/ROD/R02-91/131. Superfund Information Systems, U.S. En-

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