EPA Response to Comment from Clean Ocean Action on Engineering Performance Standards … Public Review

EPA Response to Comment from Clean Ocean Action onDocument Engineering Performance Standards – Public Review CopyHudson River PCBs Superfund SiteDocument Date October 10, 2003#Reviewer Comment Topic ResponseClean 1a Performance standard and action levels for dredging Resuspension USEPA believes the performance standard isOcean resuspension (i.e., Resuspension Standard) are not Not protective protective of human health and theAction adequately protective. Clean Ocean Action urges EPA to environment. Compliance with thedevelop and implement a Resuspension Standard that resuspension performance standard criteriareflects ambient loadings and concentrations in the river will ensure that the Total PCB water columnso that increases above ambient, baseline levels are concentrations meet the requirements of theunacceptable and require contingency actions. Safe Drinking Water Act. In addition,compliance with the standard is expected tonot adversely affect fish body burdens overthe long-term (there may a short-termincrease in fish body burdens during thedredging itself, but body-burdens are forecastto decline rapidly upon completion of thedredging).Further, the sensitivity analysis performed insupport of the Resuspension Standard showedthat the PCB concentration and load criteriaestablished for the Resuspension Standard andaction levels are protective of the riversystem. Total PCB concentrations at far-fieldlocations during dredging is expected to ...