Contaminated sediment sites are generally more complex than terrestrial sites. Factors that contribute to their complexity include the dynamic nature of aquatic systems, the potential for ongoing multiple sources from Department of the Navy (DON) and non-DON releases, their relatively large size, and the potential for ongoing mission critical activities. Remedial Project Managers (RPMs) maintain awareness of Navy policy and guidance for sediment sites including source identification, defensible data collection, risk management, and remedial action evaluation when appropriate. RPMs also plan early on for an acquisition strategy that ensures efficient and cost-effective implementation of sediment remediation projects.
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Contaminated sediments pose an important and complex challenge for DON, as many DON installations are located within marine or estuarine sediment basins and watersheds along the coastline. The dynamic nature of aquatic systems makes characterizing the nature and extent of sediment contamination more challenging than typical terrestrial sites. Sediments can be impacted by both DON and non-DON releases, as well as accumulate and/or release contamination over time depending on site-specific conditions. Therefore, a more robust evaluation of potential DON and non-DON sources of contamination is required to identify DON responsibility and ensure recontamination does not occur after cleanup. Many DON sediment sites are also located in areas with logistical and access restrictions due to mission critical activities. Because of the challenges that may arise, sediment sites can be very costly and challenging to remediate.
The DON Policy on Sediment Site Investigation and Response Action details how and when to implement sediment investigations and response actions. A critical component of the policy is the requirement that all sediment investigations and response actions must be directly linked to DON Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Resource Conservation and Recovery Act (RCRA) contamination. The policy also introduced the Watershed Contaminated Source Document (WCSD), a report that documents the existence of both DON and non-DON sources whose activities may have or could continue to have an impact on sediments in a water body adjacent to DON property. More details on the WCSD can be found in the WCSD Fact Sheet.
For more information, RPMs should refer to DON policy and guidance to support contaminated sediment investigations and response actions. In addition, DON and the Department of Defense (DoD) have made significant investments in resources and research for contaminated sediment site management. Contaminated sediment sites are addressed in Chapter 13.7 of the DON Environmental Restoration Program Manual.