oversight

Dredging America's Waterways and Harbors: More Information on Environmental and Economic Issues

Published by the Government Accountability Office on 1977-06-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

               REPORT TO THE CONGRESS

               BY THE COMPTROLLER GENERAL
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               OF THE UNITED STATES
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                                                                                                 -


               Dredging America’s Waterways
               And Harbors--More lnfor
               Needed On Environmental
               And Economic Issues
                                                                                           3/
               Corps of Engineers     (Civil Functions)       1104
               Department    of the Army                 ~1°C
                                                               a4
               Environmental    Protection   Agency
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               The effects that dredging and disposing of
               dredged material    will have on the environ-
               ment have come into sharper focus within the
               last decade; and, the Corps of Engineers has
               been required by legislation,       litigation,    and
               regulations   to modify      its practices.     In re-
               sponse, the Corps has undertaken            a research
               program, and changed its dredging practices at
               certain locations,  but at much higher costs.
               To date their research has been incomplete.          In
               fact, the long-term     effects of contaminated
               dredged material on the environment           have not
               been determined.

               Additional information    should be included in
               the Corps’ budget justifications  submitted  to
               the Congress on the costs and environmental
               effects of alternative   disoosal oractices for




               CED-77-74
                   COMPTROLLER     GENERAL     OF     THE       UNITED   STATES
                                 WASHINGTON,    DC.         20948




B-166506




To the President of the Senate and the
Speaker of the House of Representatives
        This report        describes    several   aspects    of the Corps of
Engineers'        dredging     and dredged-material       disposal     practices,
including       costs and environmental         effects,     the impact of
recent     legislation,        problems    in developing     criteria,     and
research      being performed         on the topic.
      This review was made to identify   and report    to the
Congress on the environmental   and economic    issues   involved
in maintaining   the Nation's waterway  system.
     We made our review pursuant to the Budget and Accounting
Act, 1921 (31 U.S.C. 53), and the Accounting  and Auditing
Act of 1950 (31 U.S.C. 67).
       Copies of this  report    are being                           sent to the Director,
Office   of Management and Budget;       the                         Secretaries  of Defense
and the Army; the Chief of Engineers,                                 Corps of Engineers;
and the Administrator,     Environmental                             Protection  Agency.




                                               -Comptroller   General
                                                of the United   States
    COMPTROLLER GENERAL'S                                    DREDGING AMERICA'S WATERWAYS
    REPORT TO THE CONGRESS                                   AND HARBORS-- MORE INFORMATION
                                                             NEEDED ON ENVIRONMENTAL AND
                                                             ECONOMIC ISSUES
                                                             Corps of Engineers
                                                             Environmental  Protection Agency
    DIGEST
    ------
            Keeping the Nation's        navigable     waterway   system
            fully   functioning      is vital    to the Nation's
            commerce.       To do so requires       channel maintenance
            or dredging       to remove large      quantities   of
            sediment.       (See p. 1.)
            until    the mid-1960s,       the Army Corps of Engineers
            generally    disposed      of sediment    near the dredging
            site,    in open water,      or on wetlands--usually
            the most economical         method.    Since then, concern
            over possible       environmental     damage associated
            with this disposal         has increased.     Unmanaged
I
            disposal    practices

I
            --can disrupt              or harm fish         and other    aquatic
               life,
I

            --may allow absorption      of contaminants                     in the
               dredged material    into the biological                      food
               chain,  and
            --under    uncontrolled               conditions,       can directly
               destroy   wetlands,              which play an important
               part in the life                cycles     of wildlife.
                (See p. 5.)
            Controversy       developed      over whether        the Corps was
            doing enough to counter              known or suspected
            effects      on the environment          from dredging        and
I
            disposing      of dredged material.             Legislation
            and related       litigation      within     the last decade
I
            have required          the Corps to take additional
            precautions       in dredging        and disposing        of
            dredged material.            For example,       the Corps has
            been required          to determine      how its dredging
            will    affect    the environment,          consider      the
            views of others           in making its decisions,            and
            comply with Federal           guidelines.         (See p. 10.)
            Alternatives             to traditional     disposal  sites--such
            as confined            disposal      areas, deep ocean water,
            and upland            areas-- may reduce or eliminate         the

    Jear Sheet    Upon removal,   the report
    cover date ‘should be noted   hereon.               i                            CED-77-74
     suspected  environmental        risks    of traditional
     disposal  practices.       But, these alternatives
    'generally   increase     Federal     costs,   often     increase
     costs and responsibilities           of local     sponsors,
     and may affect     the economic feasibility             of some
     waterway projects.
    As a result     of the confined      disposal    program
    on the Great Lakes, for example,            dredging    costs
    are approximately       3-l/2  times more than they
    would be if open lake disposal           methods were
    used. In other locations,         the Corps estimates
    that alternative      disposal    methods may cost
    from 1 to 15 times more than traditional               methods.
     (See p. 19.)
    Because of potential    harm to the environment,
    the levels   at which concentrations  of various
    contaminants   become too high need to be
    identified.
    With this   knowledge,     appropriate       practices       for
    disposing   of dredged material          can be selected.
    The Corps and the Environmental             Protection
    Agency continue      to refine     disposal     regulations,
    but cause-and-effect       relationships        between
    materials   considered      contaminated       and signifi-
    cant damage, especially         long-term     damage,
    have not been determined.            (See pp. 13 and 23.)
    Because possible          risks     of traditional         disposal
    practices      were not well-defined,              the River and
    Harbor Act of 1970 directed                 the Corps to re-
    search the effects            of, and alternatives            to,
    traditional        disposal      practices.        Although       not
    completed,       preliminary        results     of the $30
    million     research      program indicate           that open
    water disposal          is not as environmentally               harmful
    as first      believed.        The long-term         effects,
    however,      are still       unknown.        (See p. 23.)
    Since a follow-on       program may be necessary,      the
    Corps should‘now       advise   the Congress how a
    follow-on   program can be expedited        to develop
,   and obtain    information      not provided   by the
    original   program.       (See p. 33.)
    The Government's      lead agency in environmental
    protection--     the Environmental      Protection Agency--
    has played only a limited          role in the Corps'
    research     program.    Even though the current

                                         ii
        program is almost complete,              the Agency should
        participate        in the final     stages of the program
        by assigning         staff  to work full       time with the
        Corps'      researchers     in interpreting         research
        results       and developing     final     conclusions       for
        the program.
        If a follow-on       research     program is conducted,
        the Agency should participate              fully,      from the
        beginning.       The Agency's      participation          in the
I
        current      and proposed     research     programs       is
        particularly       important     because it is responsible
I       for guidelines       on disposal       of dredged material
        and criteria       to which the research          will      apply.
        (See p- 32.)
        Until     research     confirms      or dispels     suspected
        environmental        risks    or identifies        realistic
        alternatives       to traditional         dredgin,g     and dis-
        posall      the Government       will   be faced with
        basically      three choices,         or a combination        of
        them, in maintaining            each dredging       project:
        --Increasing         costs by using dredging   and
            disposal      techniques   which may be less
            damaging      to the environment.
        --Keeping    costs down by reducing                        or eliminating
           maintenance    of the less vital                       portions   of
           the waterway     system.
        --Accepting       the potential                 environmental         risks
           of traditional      dredging                 and disposal         practices.
        Before appropriating         funds for channel   maintenance
        projects,   the Congress        needs adequate information
        on the tradeoffs       between economic and environmental
        values.   Additional       information   which could help
    I   the Congress     includes
        --the      cost   of changing        from         current        practices,
        --a      qescription      of    current          and proposed
              disposal      methods,
        --the      reasons     for     changing          disposal        methods,
        --the    environmental           benefits             expected      from      the
            changing    methods,         and



                                                  iii


                                                          .    .. .
--continued    economic feasibility  of affected
   navigation   projects  if proposed changes are
  'made.    (See p. 33.)
The Corps, in coordination           with the Environmental
Protection    Agency, should prepare and provide.
such information        to the Congress when the Agency
objects to the method or location            of the Corps'
disposal    activities.       (See p. 33.)     The Army
believes    that only those cases should be
highlighted     where major cost increases occur
due to environmental         conditions.     This, however,
would not bring to the Congress' attention            those
cases where the Agency objected to or questioned
the Corps' practices         and where changes were'not
made and additional        funds were not requested.
Army and Environmental     Protection Agency officials
agreed in principle    with GAO's recommendations,     but
questioned how they would be.implemented.      (See pp.
33 to 35.)




                           iv
                          Contents

                                                              -Page
DIGEST                                                           i
CHAPTER
    1        PERSPECTIVE                                        1
                 Scope of   review                               3

    2        ENVIRONMENTAL EFFECTS AND RISKS                    5
                 Open water disposal                            5
                 Wetlands  disposal                             7

    3        IMPACT OF ENVIRONMENTAL LEGISLATION
               AND LITIGATION ON CHANNEL AND
               HARBOR MAINTENANCE                              10
                 Environmental    legislation                  10
                 Litigation    on State regulations            11
    4        PROBLEMS IN DEVELOPING CRITERIA
               FOR DISPOSAL OF DREDGED MATERIAL
               INTO NAVIGABLE AND OCEAN WATERS                 13     .
                 Development of predictive  criteria           13

    5        EFFECTS OF ALTERNATIVE DISPOSAL METHODS           17
                 Alternative    disposal    methods            17
                 Potential   effects     of alternative
                    methods                                    19
    6        RESEARCH ON DREDGED MATERIAL DISPOSAL             23
                 Objectives   and status  of the
                   DMRP                                        23
                 Other research   studies                      29

    7        CONCLUSIONS AND RECOMMENDATIONS                   31
                 Recommendations to the Secretary
                   of the Army and the Administrator,
                   Environmental Protection   Agency           33
                 Agency comments and our evaluation            33
APPENDIX'
         I   Case study --Great   Lakes   confined
               disposal   program                              36

    II       Case study-- dredged material      disposal
               in the New York Bight                           40
  III        Case study-- disposal  of material     dredged
               from the Upper Mississippi     River            43
                                                                                           Page

APPENDIX
      IV    Case study --dredged   material   disposal
              in the San Francisco     Bay area                                             46
        V   Case study--disposal                  of dredged material
              at selected     Gulf              of Mexico harbors                           51
    VI      Letter    dated February                28, 1977, from the
               Assistant    Secretary               of the Army to GAO                      53
  VII       Letter    dated March 24, 1977, from                           the
               Environmental    Protection Agency                          to GAO           55
 VIII       Principal          officials       responsible               for
               activities            discussed     in this             report               64
                                 ABBREVIATIONS
DMRP        Dredged         Material       Research           Program
EPA         Environmental              Protection        Agency
GAO         General         Accounting          Office
GREAT       Great      River      Environmental               Action      Team
NOAA        National         Oceanic          and Atmospheric             Administration
USFWS       United      States         Fish     and Wildlife            Service
WES         Waterways          Experiment           Station
                                     -CHAPTER 1
                                    PERSPECTIVE
                                    ---
        The Nation's     aquatic     environment--rivers,         streams,
shorelines,     wetlands,      and lakes--     is   an  important    economic
and natural      resource    providing      such benefits       as transporta-
tion,    food, water supplies,          and recreation.         An important
segment of the aquatic           environment      is the Nation's       navigable
waterways     system consisting         of over 25,000 miles of channels,
107 commercial       harbors     and ports,      and 400 small boat harbors.
This system plays an important              role in the Nation's         trade at
home and abroad.
        Waterborne     commerce, foreign     and domestic,      totals   about
1.7 billion      tons a year.       About one-third      of the total
originates      or terminates     in foreign    countries.      Barges and
shallow-draft       vessels   using the inland      waterways     system move
almost 16 percent        of the Nation's     domestic      commerce.    (See
photograph      on p. 2.)
        Water transportation      is relatively     fuel-efficient,
compared to other transportation            modes, as shown in the
following    table   based on information       developed       by the American
Waterways Operators,         Inc.
           Mode of                               Energy    consumption
       transportation                               per    ton-mile
                                                               -I_
                                              (British     thermal     units)
             Water                                           500
             Rail                                            750
             Truck                                        2,400
             Air                                          6,300
       Since 1824, the Corps of Engineers                has been responsible
for planning,       constructing,      operating,      and maintaining         the
inland    waterways     and harbors.        Constructing        a navigable
waterway     involves     the removal of sediments            from the bottom
of the waterway        (dredging)     to form a channel          of sufficient
depth and width to accommodate barges in inland                     waters and
ships in harbor       areas,      and constructing       locks and dams to
regulate    the flow and depth ,of the water,               as necessary,        for
navigation.
     Reaccumulations       of sediment   must be periodically       removed
to keep channels     at navigable    depths.     In fiscal    year 1976,
the Corps dredged about 287 million          cubic yards of material
from the waterways       at a cost of about $240 million.          This
is enough material       to cover the entire     District   of Columbia
(67 square miles)      to a depth of 49 inches each year.
                                         1
2
        Most of the dredged materials         have been deposited          in
the water or near the water close to the dredging                  operation
to minimize     disposal    costs.     Moving large      volumes of the
material    from one area of the aguatic           environment     to
another    can adversely     affect    the potential      of that environ-
ment to serve important          uses, such as food, recreation,             water
supply,    and  wildlife    habitat.      The danger     may  be increased
when the material        is contaminated.
       With the increasing       public                  and congressional   concern
for   environmental   preservation                     since the mid-1960's,     attention
has   been    focused         on    the    suspected         damaging      aspects       of   dredging,
particularly   the disposal       of dredged material          into the aquatic
environment.     Legislation      reflecting       this   concern   requires the
Corps and other Federal         agencies      concerned    with the aquatic
environment  to give greater          attention      to the environmental
impact of maintaining        the waterway channels.
        Controversy        developed       over whether            the Corps was doing
enough to counter           known or suspected                environmental         effects
from dredging         and dredged-material               disposal.          The Environmental
Protection       Agency (EPA) and other agencies                       whose missions          are
related     to environmental           protection,            have questioned           the Corps'
continued       use of dredging          and disposal            practices       which may
involve     unacceptable         environmental           risks.        The extent         of these
risks,     however,      has not been fully               identified        or quantified.
Alternative        practices,      while overcoming                some of the environ-
mental objections,            can present          additional         problems      such as
greatly     increased       costs,     difficulty           in obtaining         suitable
disposal      sites,      and increased          responsibilities             for local
sponsors      of the projects.
SCOPE OF REVIEW
       We examined files      on operation   and maintenance     of selected
dredging    projects,    as well as laws, regulations,       procedures,
and practices       used by the Corps in its dredged-material         research
program and its dredging        and disposal   activities.
        Our review           was made at the               following      Corps      locations:
        --Office        of    the      Chief     of Engineers,          Washington,           D.C.,
        --Waterways           Experiment          Station        (WES),    Vicksburg,
           Mississippi,
        --Buffalo          District,           New York,
        --New       York     District,          New York,
        --Mobile        District,          Alabama,

                                                       3
        --San     Francisco           District,          California,   and

        --St.     Paul    District,               Minnesota.

       We held discussions          with     officials          of EPA, the United
States     Fish    and Wildlife     Service         (USFWS) of the Department
of the Interior,          and the Corps.           We also        contacted       local
sponsors      and officials      of selected           port     authorities         and
the States       of Alabama,     California,           Florida,        Minnesota,       and
Wisconsin.

         The remainder            of this     report      describes         several      aspects
of dredging            and dredged-material             disposal         including       environ-
mental      effects         and risks,       applicable        legislation          and liti-
gation,       criteria         for disposal         of dredged        material,        effects
of alternative              disposal      methods,      and research            on dredging       and
dredged-material               disposal.      Our conclusions              and recommendations
are contained             in a separate         chapter      because         they generally
relate      to the entire            topic    of dredging          rather       than any
specific        chapter.
                                     CHAPTER 2
                     ENVIRONMENTAL EFFECTS AND RISKS
        When dredged material      is disposed     of in open water    (see
photograph      on p. 6) or on wetlands        it may (1) harm or kill
bottom-dwelling      organisms,     (2) cause aesthetic     problems
(turbidity),      and (3) destroy      wetlands,   which play an important
role in the life      cycles    of wildlife.
         In those cases where the material             is contaminated,     the
effects     can be more serious.          The Corps is studying         the extent
of these effects         and alternatives     to these dredged-material
disposal      practices,    but conclusive      results    have not yet been
identified       (see chapter     6).
       Dredging    is required      because material    which enters
streams    and is deposited       as sediment    in navigation    channels
must be removed to maintain           required  depths.      As a result
of urban development          and industrial   and agricultural       activity,
the sediment      has become increasingly       contaminated,     further
increasing     the potential      for environmental     damage from dredging
and disposal      activities.
        The dredging       process    involves       the removal of sediment
from channels        by hydraulic       or mechanical       means and can directly
damage bottom-dwelling            organisms      in the channel.          But the
question     which causes most of the environmental                    concern    in the
dredging     process     is how and where to dispose               of the dredged
material.        The range of choices          includes     disposal      in open
water,     wetlands,     ocean waters,       confined      areas,    or upland areas.
Open water disposal           has been most widely          used by the Corps,
and it has drawn considerable               environmental        objections,     parti-
cularly     when the dredged material              is contaminated,         or when it
physically      destroys      or adversely       alters    aquatic     systems.
        Contaminants       enter the water from various              sources,
including      waste discharged         by industry       and municipalities         and
uncontrolled       runoffs      of agricultural       fertilizers        and wastes.
Toxicants,      such as heavy metals and pesticides,                  may enter
the food chain and can affect                the health       of aquatic     organisms
and eventually        affect      humans who eat fish which were exposed
to and accumulated           the toxicants.        Dredging       and disposal      of
the dredged material            resuspend      or expose the contaminants             in
the water and may make them available                   to aquatic       organisms.
This exposure       may or may not have a significant                  impact on
aquatic     organisms      in any given case.
OPEN WATER DISPOSAL
       When dredged       material     is dumped into        open water,    the
bulk   of it settles       rapidly     to the bottom,        often trapping     and
                                           5
    LL
    0




6
smothering        aquatic     organisms     and damaging or destroying
their     habitat     and the plants        on which they depend for food.
The Corps'        researchers       said that such impact has been found
through     field     studies     to be of short duration      and generally
of little       regional      ecosystem     consequence  because of the
resiliency        of many aquatic        organisms.
        Finer particles         which do not settle         remain suspended
and concentrated           for some time in the water at the disposal
area until        dispersed      by the flow of water or aggregated               into
larger     particles.         This condition,      called     turbidity     (see
photograph        on p. 8), may screen out sunlight                needed by
aquatic     plants      and create     aesthetic     problems.         Open water
disposal      can also cause the formation              of mounds of dredged
material      which can alter         water circulation.
       The concerns       become more severe when the dredged material
is contaminated.         Aquatic      organisms       in the area may die or
store   the contaminants         in their       tissues    and pass them through
the biological      food chain.          Human health        could be affected        by
having body contact         with water containing              toxic     levels    of
contaminants,      or by consuming          fish or wildlife           which have
been exposed to the contaminants.                    WES officials         said that
recent    research    results      indicate       that uptake        (body absorption
through     food consumption)         of toxicants       by aquatic         organisms
has been minimal        in marine and esturine             sediments.
WETLANDS DISPOSAL
       The use of wetlands          as dredged-material        disposal    sites
has been practiced          by the Corps"for        many years.      Because of
proximity     to the dredging         operations,     it is usually      one of
the least     expensive      disposal     methods.      In recent    years there
has been increased          awareness     of the functions       coastal   and
inland    wetlands     serve,    including      food chain production,
general    habitat     and nesting       areas for wildlife,       spawning
and rearing      areas for aquatic          and land species,      and flood
and erosion      protection.
        In a 1969 report,        the Commission       on Marine Science,
Engineering,       and Resources       concluded    that coastal         estuarine
waters and marshlands          were vital      to the life       support       of
much of our marine fisheries'              harvest.      Seven of the ten
most valuable        species   for the Nation's        commercial         fisheries
spend all or important           portions     of their    life     cycles      in
estuarine      waters.      The report     pointed    out that in the pre-
ceeding     20-year    period,     569,000 acres--7       percent       of about
8 million      acres considered        to be important         habitat--were
lost    through    dredging    and filling.
      In its September  1975 guidelines       on the discharge    of
dredged material,   EPA described    disposal    operations    in wetlands
                                            7
8
as being     most severe,      and stated          that destruction          of highly
productive     wetlands     may represent            an irreversible         loss of a
valuable     aquatic    resource.
          In November 1976 the Corps estimated          that 7,000 acres
of land are needed annually          for new dredged-material             disposal
facilities.         This figure represents    total     land requirements,
including       both upland areas and wetlands.           Individual        acreage
records      for each, however,    are not maintained          by the Corps.
The Corps told us that wetlands           are still     used because these
are sometimes the closest         and cheapest      disposal      alternative,
and because in some cases there are no economically                     viable
alternatives        available.
      EPA officials          told us that a major concern of conservation
and environmental          interests       is the long-term           cumulative      effects
of dredging     activities.            This concern       is recognized         by the
Corps, and is reflected              in one of its dredging             regulations
which states     that,       although      individual       alteration       of wetlands
may constitute       a minor change,            the cumulative         effects     of
numerous piecemeal           changes often         result     in a major impairment
of the wetland       resources.
         EPA officials    said that an illustration           of such long-term
effects     is contained     in the Corps'     April    1976 Environmental
Impact Statement       for the Lower Mississippi          River and Tributaries.
The impact statement         points    out that riverine       habitat  loss over
the last 100 years has been significant,                and acknowledges      that
continued     maintenance     dredging    will  further     reduce wetland
habitat.
       EPA officials       believe   that such long-term        effects     should
be fully    considered      in making decisions      involving        economic and
environmental       values    in selecting  disposal      sites     for dredged
material.
                                         CHAPTER 3

                    --IMPACT OF ENVIRONMENTAL
                                      ------  LEGISLATION
         AND LITIGATION --- ON CHANNEL AND HARBOR MAINTENANCE
                                                   ----
         During the past decade,            new legislation         and related          legal
actions      have affected         the Corps'      mission    to maintain         the Nation's
waterway       system.      As a result,        the Corps has been required                 to
assess the environmental               impact of its dredging             and disposal
activities;        consider      the views of other Federal,                State,      and
local      agencies    in making its decisions;              and comply with EPA
dredged-material          disposal      guidelines.        In addition,         the Corps
has been required           to use confined         disposal     facilities         for
dredged material          classified       by EPA as contaminated              on the
Great Lakes, and to conduct                a research      program on the effects
of, and alternatives             to, its dredged-material              disposal       practices.
ENVIRONMENTAL LEGISLATION
----
        Section  102 of the National      Environmental         Policy     Act of
1969 (Public     Law 91-190,     January  1, 1970) requires            all agencies
of the Federal      Government    to prepare    detailed     environmental
impact statements        on major Federal    actions     significantly        af-
fecting     the quality    of the human environment.            These statements
include     such factors    as
        --the     environmental         impact      of   the proposed        action,
        --any adverse environmental    effects   which cannot be                               .
           avoided should the proposal    be implemented,   and
        --alternatives          to the     proposed       action.
         Whether the Corps would prepare                  environmental            impact
statements       for maintenance            dredging    projects        was initially
questioned       since these were continuing                  activities.           Corps
officials      told us that emphasis was given to environmental
assessment       and Environmental             Impact Statement           preparation
for new construction             activities        since the Corps felt                that
maintenance        dredging     projects        caused less environmental
impact.       The Corps decided             to prepare      statements         for main-
tenance dredging          projects        based on (1) a Council               on Environ-
mental Quality         interpretation           of its guidelines            and (2) a
1974 court decision.              This process         permits       appropriate          Federal,
State,     and local      governments,          as well as interested                individuals
and groups,        to comment on the Corps'               dredging        activities.
        The Corps has established     an internal  policy,    effective
January    1, 1976, not to perform     maintenance   dredging    on any
project    for which an environmental      impact statement     or
assessment     has not been prepared.
                                               10
         Section     123 of the River and Harbor Act of 1970 (Public
Law 91-611,        December 31, 1970) authorized                   the Corps to build,
operate,       and maintain       confined        disposal      facilities      for con-
taminated       dredged material           on the Great Lakes and their                 con-
necting      channels.       Under the Great Lakes Confined                    Disposal
Program,       which was authorized              by this law, the Corps places
dredged material          determined        to be contaminated             by EPA behind
retaining       dikes,    thereby      reducing         the threat       of potential
environmental          damage.     The Corps plans to construct                    46a/ such
facilities        at a cost of about $263 million.                       The Corps told
us that confined          disposal       facilities'        use on the Great Lakes
costs 3-l/2        times more than open lake disposal                      methods.      This
program is discussed            in greater           detail   in appendix       I.
      Section   123 also authorized          the Corps to conduct       a
comprehensive     research   program on the effects         of, and alterna-
tives   to, dredged-material        disposal    practices.      The program,
which is a $30 million       effort     planned    for completion     in 1978,
is discussed    in greater    detail      in chapter     6.
        Section     404 of the Federal     Water Pollution       Control      Act
Amendments of 1972 (Public          Law 92-500,      October    18, 1972) and
section     103 of the Marine Protection,           Research,    and Sanctuaries
Act of 1972 (Public         Law 92-532,    October    23, 1972) (Ocean Dumping
Act) required        that EPA, in conjunction        with the Secretary          of
the Army, establish         and apply guidelines        and criteria       for the
discharge       of dredged material     into inland      and ocean waters.
The Ocean dumping criteria          were published       in the Federal
Register      in October    1973 and were revised        in January      1977.
The inland       guidelines   were published      in September       1975.
        These two acts have not had a significant            overall       impact
on the performance      or costs of channel        maintenance.         Poten-
tially,     the impact from these acts could be substantial                 because
they give EPA, rather         than the Corps, the final         authority      as
to where dredged material          can be dumped.       EPA officials       told
us that to minimize       these potential      impacts,    EPA and the Corps
have established      a joint     committee  to work on the continued
refinement     of these criteria      and guidelines.
LITIGATION        ON STATE REGULATIONS
      The State of Minnesota      brought     suit against    the Corps
in the united   States  District     Court,    District    of Minnesota,
in March 1975.     The State claimed       that the Corps had violated
State laws and regulations       which


a/Includes        five   land   facilities        requiring     very    limited
    construction.

                                             11
       --require       secondary        treatment     of dredged       spoil,
       i-forbid    discharges  into           navigable       waters     in violation
           of State water quality             standards,       and
       --require       all   dredgers       to obtain      a State     disposal
           permit.
       The issue was mainly             one of decisionmaking                 responsibility--
whether    the State or the Corps was responsible                          under the Federal
Water Pollution        Control     Act Amendments of 1972 for regulating
dredged or fill        material       discharge         into navigable           waters.
Section    402 of the act authorizes                  States     to establish          permit
programs     to regulate       discharges         of all pollutants              into the
navigable      waters.     If the State's             program is approved by EPA
as meeting      applicable       Federal       standards,        State permits           issued
to those proposing         discharges          into the waters replace                 Federal
permits,     which otherwise           are required.           Section        404 of the act,
however,     gives the Corps permit-granting                     authority         over the
discharge      of dredged or fill             material      at specified           disposal
sites.     The Corps contended              that this latter           authority          (section
404) was controlling           over its own dredging                activities         as opposed
to State control.          The District           Court held otherwise,                however,
in an October        9, 1975, decision,             that section         404 is applicable
only if there was no approved                  State permit         program under sec-
tion 402 of the act,           or   if    the    approved      State     program did not
try to regulate        dredging,        neither       of   which    was     the case in
Minnesota.
        The Corps also contended              that to compel it to obey State
requirements        would impair        its authority         to maintain        navigation
and would violate          an express        provision       under section          511 of
the act which protected              that authority.            The Court's        ruling
on this question         was also against             the Corps, stating            that
the Corps'       compliance     with State permit             requirements         would not
affect    the Corps'       authority        to maintain       navigation,        but would
merely require         maintenance        in compliance         with effluent           limita-
tions    established       pursuant       to the act.         The Corps appealed
this decision         in January       1976, and an October            1976 decision
on the appeal by the U.S. Circuit                     Court of Appeals         for the 8th
Circuit     reversed     the District          Court decision,         stating        that the
Congress had not intended               to waive the immunity             of the Federal
Government       from State regulations.                 As a result,       the Corps does
not have to comply with individual                      State standards        relating         to
discharges       into navigable         waters      in its dredging         activities.
Both EPA and the Corps told us EPA guidelines                          and criteria
are now the only mechanisms governing                       Corps'   dredging         and
disposal      operations      in State waters.
       On January        26, 1977, the         State of Minnesota    appealed  the
decision   to the        Supreme Court         which, on April    25, 1977, decided
not to hear the          case.
                                              12
                                       CHAPTER 4
          PROBLEMS IN DEVELOPING CRITERIA                  FOR DISPOSAL OF
          DREDGED MATERIAL INTO NAVIGABLE AND OCEAN WATERS
        Because contaminated        dredged-material          disposal     may
potentially     have adverse       environmental      effects,       there    is a
need to identify        the levels     at which concentrations             of various
contaminants      become unacceptable         for disposal         in the aquatic
environment.        However, cause and effect            relationships       between
materials     considered    to be contaminated           and significant        en-
vironmental     damage are often difficult             to verify       with current
analytical     procedures.       Furthermore,       Corps'      researchers     be-
lieve     it may not be possible         to establish       such relationships.
       Knowledge of these effects          is critical   to future dredged-
material      disposal  practices.      The Corps uses water disposal
sites     for about 65 percent       of the material   it dredges,   and
based on criteria       existing     in 1973, the Corps estimated     that
a high percentage       of the material      contained   chemicals in
potentially       toxic concentrations.
        Guidelines     to determine      the polluted        nature    of dredged
material     were first     developed      by EPA in January         1971.     Since
then EPA, in conjunction           with the Corps, has published               three
additional       sets of regulations--one           for inland      waters    and
two for ocean waters.            But until    more scientific          evidence
is developed        on cause and effect       relationships,         decisions
regarding      the acceptability       of dredged material           for disposal
in open water will         often   be subjective,        and will      be based
on case-by-case        analyses.
DEVELOPMENT OF PREDICTIVE              CRITERIA
        A Corps'     study stated         that the criteria            for determining
the acceptability         of disposing          of dredged material              into the
water should address the question:                        does the dredging          and
disposal    of sediment         known to contain            various      contaminants
cause them to be released               to the water column (dissolved),                  or
in any other way to become more available                         to the biological
food chain?        Currently,        there    is no single          test which answers
that question.          Neither      the Jensen criteria              nor the elutriate
test fully     predicts       the long-term           behavior      of contaminated
dredged material         after     it enters       the water.          Bioassay      test
procedures      (discussed       below),      adopted in January 1977 as part
of the revised        ocean disposal          criteria,        however,      were developed
to predict     the effects        of proposed           disposal      operations       on
aquatic    organisms      on a short-term            basis.



                                           13
Jensen      criteria
       The Jensen criteria             consider      sediment       from an area to
be polluted         and unsuited       for open-water         disposal,        in all cases,
if any one of seven pollution                   parameters      are exceeded,          based
on test results           of sediment        analyses.       The parameters          purport
to predict        the effect       disposal      would have on the short-term
oxygen supply          in the water and on the water's                   contamination
through     exposure        to oil,    grease,      mercury,      lead,     and zinc.        The
test   itself,       however,       is not conclusive,          since those making the
tests    are permitted         to use discretion           in deciding         whether     the
material       is too polluted          for water disposal            after    considering
other factors          such as the sources           of contamination,            the condi-
tion of the proposed             disposal       area, certain         biological       and
chemical       indicators,       and    field    observations.            Corps'    researchers
said that the mere presence                   of a contaminant          in a sediment
 is not an indication            of its potential          to create        environmental
damage.
        The Jensen criteria      were adopted by the newly created
EPA in January      1971 for use by its regional         offices    in deciding
whether    to oppose Corps'      practices  of dumping material         dredged
from a given area into the water.            Subsequently,       EPA rescinded
its requirement      that the Corps use the Jensen criteria,              and
instead    endorsed    the use of the elutriate      test for inland
disposal,    and required     its use for ocean disposal.
Elutriate         test
        The elutriate        test was designed         to predict     the increase
in the concentration            of contaminants         in the water at the pro-
posed disposal        site.       It involves    a laboratory       simulation      of
the disposal       process      and compares the concentration              of con-
taminants     in the water at the disposal                site before     and after
disposal.       In the ocean disposal           criteria,      if the test showed
that the concentration              of any one of the designated            contaminants
would not be increased              by more than 1.5 times,         the sediment       was
considered      suitable       for open water disposal.           The 1.5 factor         is
not used in the elutriate              test procedures        when applied      to
 inland   disposal      situations.
        The elutriate   test overcame one of the principal        objections
to the Jensen criteria,        that they did not fully    reflect    the
knowledge     that some contaminants      did not remain suspended      in
the water and affect       water quality     and aquatic organisms,     but
settled    with the main particles       of sediment.
        The elutriate     test, on the other hand, did not resolve
two areas vital       to the development   of valid   criteria  for pre-
dicting    effects    of the contaminated    sediment  on water quality
and aquatic      organisms.


                                             14
         --Evidence     gathered    thus far has not proven whether
            an increase     of pollutants    in the water at the dis-
            posal site by a factor        of 1.5, which was subjectively
            derived,    is too lenient     or too strict.
         --The test does not measure the potential                   effects     which
            contaminants       settling      at the disposal     site may sub-
            sequently      have on bottom-dwelling         fish and shellfish,
            nor does it consider           the possibility     that,      through
            chemical     actions,       the contaminants     may in time be
            released     into the water.
Inland     disposal      guidelines
        The EPA publication             of guidelines        for selecting          disposal
sites     in inland       waters,     as required       by the Federal          Water
Pollution       Control       Act Amendments of 1972, was delayed                     until
September 1975, about 3 years after                     the act was passed,              because
of lengthy       negotiations         over the guidelines             between the Corps
and EPA. The published                guidelines      do not prescribe            any single
test which would dictate                disposal    site     selection,          The Corps,
in consultation           with EPA, chooses one or more tests                     from
several      contained        in a comprehensive          testing,       evaluation,          and
review procedure            to evaluate       any given case.            Disposal      deci-
sions,      however,      are subject       to EPA's review and it may deny
the Corps use of a site               if it finds      that the planned disposal
would have an unacceptable                 adverse effect          on municipal        water
supplies,       shellfish        beds and fishery         areas,      wildlife,       or re-
creational       areas.         Because the guidelines             were not specific
in terms of what material                 would be considered            unsuitable         for
aquatic      disposal,        the impact on the Corps'              disposal      practices
cannot be assessed.
Ocean disposal         criteria
         Ocean disposal      criteria     issued by EPA in October        1973
pursuant      to the Ocean Dumping Act required             the Corps to apply
the elutriate        test in selecting         sites   at which contaminated
dredged material         may be dumped.          In perhaps the most important
conflict     between the Corps and EPA over the validity                of the
test as criteria,         EPA challenged         the Corps'   use of the dis-
posal site off the coast of New Jersey--the                   New York Bight--
where most of the material             dredged from the New York Harbor
area is dumped.          This conflict       is discussed     in more detail
in Appendix      II.
         In a complaint     filed     in the U.S. District    Court for the
District     of Columbia       in November 1975, the National        Wildlife
Federation     challenged        the legal   sufficiency   of EPA's ocean
dumping criteria.          To overcome the shortcomings         of the pre-
vious testing       procedures      and the,objections     of the National

                                             15
Wildlife   Federation,      EPA revised    its ocean dumping criteria
in January    1977.     These new criteria      (1) eliminated    the
arbitrary    1.5 factor     discussed    on pages 14 and 15 and (2)
now consider     the effects      of ocean disposal    on bottom-dwelling
(benthic)    aquatic    organisms.
         Under the revised        ocean disposal       criteria,     the first    step
is to determine         the source and nature          of the dredged material.
The dredged material            may be considered       acceptable      for ocean
disposal      without     further    testing    if (1) the dredged material
is made up of sand, rock,              and/or   gravel     and there    is no known
source of pollution            in the material's       area of origin       or (2) the
disposal      operation      will   not exceed applicable         water quality
criteria      for ocean waters.
        When the dredged material              does not meet the above
conditions,         further     testing     of liquid,    suspended particulate,
and solid       phases of the dredged material               is required.     During
this    testing,        aquatic    organisms      (either  those native   to the
proposed      disposal       area or other appropriate          sensitive   marine
organisms)       are subjected          under test conditions       to the three
phases mentioned            above.      This procedure     is known as the
bioassay      test.
      If these bioassay   tests  show no unreasonable       toxic   or
other adverse    effects on the tested   organisms   within      a 96-hour
test period,   the dredged material    is considered    acceptable
for ocean disposal.
        Although    the above procedure          is applicable       to almost all
dredged material        disposal     operations      in ocean waters,        each
operation      is still    evaluated      on a case-by-case        basis.      An
EPA official      told us that in some instances               where special
circumstances       are present      (for example,'the         potential     for
contaminants      being released        from the settled        dredged material
over an extended        time period),       additional     testing       may be
necessary.
        To refine    the existing     criteria,     EPA and the Corps
established       in October    1975 a joint     committee   to coordinate
research     and work on the technical          aspects   of regulatory    cri-
teria    for the discharge       of dredged and fill       material.     Based
on the information        developed     by this committee,       the Corps and
EPA plan to prepare         implementation      manuals in 1978 to supple-
ment both the inland         and ocean dumping regulations           for
dredged material.




                                         16
                                            CHAPTER 5
                                            -----
                                  EFFECTS OF ALTERNATIVE
                                  ----            P-
                                      DISPOSAL METHODS
                                               ----
        There are several              alternatives         to the Corps'  traditional
practice     of disposing             of dredged        material   in open water or
on wetlands,      including
       --deep        ocean       waters'    use,
       --land        disposal,        and
       --selective           placement       in open water.
          These alternatives        are considered       by some to be more
environmentally          acceptable     than traditional       methods,    but can
increase       Federal    costs,    as well as local       sponsors'    responsi-
bilities,       and may affect       the economic viability          of some
waterway       projects.
ALTERNATIVE DISPOSAL METHODS
        Long-term    environmental       effects     of deep ocean disposal
have not yet been thoroughly             studied     and so are not well
known.       Some scientists,       however,     consider  deep ocean areas
to be an acceptable           place to dispose       of many types of waste,
including      dredged material,       because of the low biological
productivity       in these areas.
         Land disposal      is considered         by some to be more
environmentally         acceptable       than open-water          or wetland      disposal,
particularly         when the material          is contaminated,         because it
removes the material            from the aquatic         environment.           Corps'
officials       told us that under certain              situations       land disposal
may pose a greater          risk    of long-term       adverse       ecological       impact
than open water disposal              because of geochemical             changes in the
sediment       and the possibility           of leaching       (leaking     of soluble
substances        from solid      material).        Land disposal        areas can
either      be diked areas (see photograph                on page 18) along the
shoreline       (confined     disposal)        or upland areas away from the
shore and wetlands.             Confined      disposal      has been used fre-
quently      by the Corps, but because of higher                   transportation
costs,      upland areas have not.
      In selective      placement,     dredged material    is disposed       in
the aquatic    environment,      but the number of disposal        locations                   is
reduced.    For example,      selective     placement   of dredged material
would limit    disposal     to a selected      number of locations      in the
open water,    instead     of in the entire      iength  of the waterway.

                                                   17
18
POTENTIAL EFFECTS OF
ALTERNATIVE METHODS
Increased         costs
        The use of alternative      disposal methods                          will  generally
cost more than present        methods because these                           methods will
require
          --more transportation              (deep    ocean,      land        disposal,       and
             selective  placement),
          --the     construction       of containment            facilities          (land
              disposal),
          --the    purchase        of land    (land    disposal),             and
          --additional        equipment       (deep     ocean,      land       disposal,           and
             selective      placement).
        In the past,        availability          and    economy were the                  Corps'
principal      criteria      for selecting          a    disposal   site.                 Since the
passage of environmental                legislation          in the last    5             years,
other factors,          such as potentially              adverse   effects                on water
supplies     and on fish and shellfish                   consumed by man,                  have been
given added weight           in the selection              of dredged-material
disposal     sites.
        Estimated    cost          increases  for alternative                  methods       for
projects     we reviewed             are shown in the following                  table.
                                        Estimated   cost
Location                             increases    (percent)              Method
Great Lakes                                    356                       confined
New York Harbor                                220                       deep ocean
San Francisco     Bay                  a/988 to 1088                     land,    deep ocean
Upper Mississippi     River                 b/390                        selective     placement
Gulfport   Harbor                        1224 to 1519                    upland,    ocean
Mobile Harbor                            c/65 to 147                     confined
a/Mare       Island    Strait     Project.
E/Head       of navigation        to Guttenberg,          Iowa.
E/River        channel    portion     of project.




                                              19
      Details       on the cost increases     for each of the                 locations
are discussed        in appendices   I through   V.
        The Corps      has not prepared    information    on the              nationwide
costs    of using      alternative  disposal     methods.
        EPA officials          said that they believed             that although
alternative        disposal       methods often      result      in increased         costs,
these costs are often               offset   by environmental          and economic
benefits      resulting        from the use of the alternative                methods.
For example,         they said that traditional              disposal      practices
sometimes       include       dumping material       near the dredging            site
where material           often    returns    to the channel          or harbor,
necessitating          the extra       expense and associated           potential
environmental          damage of redredging.             They also told us that
they believed          dredged material         can be used productively,                such
as for beach nourishment                 or wetland    creation.
       EPA told us that they believe            that an investment     in more
modern dredging         technology   can reduce costs and, at the same
time,    better    protect     the environment.      They said that most
dredging      equipment     now used in the United       States  is not de-
signed for cost-effective           dredged-material      removal and
transportation        (see app. VII).
        Corps officials          told us that both the private                  industry
and the Corps dredging               fleets       consist    of rather      old equipment,
and that they generally                agreed with the basic points                expressed
by EPA. Corps'          officials         pointed       out, however,       that over the
last    8 to 10 years,         funding        for new equipment         development       and
modernization        of existing          equipment        has been very limited.
Corps officials         told us that uncertainty                 about whether        the
Corps or private          industry        will     play the lead role in future
dredging     operations        has been a key to the lack of new dredging
equipment     development.             They told us, however,             that the latest
available     technology         will     be considered        in the development
of future     dredging        equipment         in the Corps'      fleet.
Increased    responsibilities            of
local   sponsors
         The responsibility           for acquiring         land for disposal         sites
is assigned        to either       the Corps or the local            sponsor    in the
legislation       authorizing         particular       projects.      With an increas-
ing trend toward land disposal                   and the generally        higher      costs
of acquiring         land,     responsibilities         of local     sponsors     will     in-
crease.        Because of increased             costs,    many local     sponsors      may
be reluctant         to fulfill       their     sponsorship      agreements,      making
it difficult         for the Corps to carry out its mission                   to
provide      for navigation.


                                              20
         The Corps'    policy     is to continue     open water disposal
on projects       where it is now used unless local           interests
provide     suitable    alternate      confined   areas at no cost to the
Government.         When the Corps does not have the authority               and
the local      sponsor does not have the means to provide               land
facilities,       the alternatives        are to suspend dredging,        or to
continue     to use the existing         disposal    method.
      Some of the difficulties             experienced      by the Corps with
local  sponsorship agreements             are illustrated      in the following
examples.
         In 1971 four Florida           counties    notified         the Corps of their
inability       to provide       land disposal       sites      for the placement
of material        dredged from the Apalachicola                  River as required
by agreements         they had signed with the Corps.                     The Corps
estimated       that it would require            $600,000       to acquire      upland
sites      for disposal       of the material.           Several       Federal   and
State agencies          objected     to the Corps'        initial       plan to obtain
disposal       easements without         charge from property              owners whose
land adjoined         the 104-mile       length    of the river           because of
possible       environmental        degradation.
       The Redwood City Harbor in California                  was not dredged
in 1974 as scheduled,          or in 1975 as rescheduled,             because
the local   project       sponsor,     the Port of Redwood City,            had
not found an acceptable            land disposal      site.     When the harbor
was dredged     in 1970, the dredged material                was dumped at a
nearby aguatic      site.      However,    environmental        regulations
precluded   further       dumping at this       site,    and the nearest
acceptable    aquatic      site was located         24 miles    from the harbor.
Because use of that site would increase                   the cost of dredging
the harbor    over 2-l/2       times the cost of using land disposal,
the Corps required         that the sponsor provide            a land disposal
site.
Prospective      abandonment        of channels
        Federal     policy   for the construction         of new channels
requires      showing that the project          will   return    benefits
greater     than the cost of construction             and later    maintenance.
After     a project      is constructed,      however,    the Corps does not
routinely      weigh the benefits          and costs of maintaining
waterways      and harbors.        Factors    which enter     into decisions
for continued        maintenance      include
       --prospective       future     increases     in benefits      (increased
          traffic),
       --the    effect    on the     local economy and on business   firms
           induced     to locate     on the waterway by the presence    of
           the channel,      and

                                          21
           --national    defense      needs.
Increases  in dredging             costs due to environmental    concerns
could adversely   affect            the economic viability    of some projects.
        The Corps'    Mobile District       analyzed  the effect                   of proposed
alternative     disposal     practices     on the benefit-cost                   ratio   for
the Gulfport,      Mississippi,       harbor project.
        USFWS had suggested             that the Corps abandon the use of
dredged-material            disposal      sites    along the Gulfport             harbor
and ship channels             for more environmentally               acceptable         sites.
USFWS predicated            its suggestion         on the belief          that disposal
of dredged material               in open water areas is often                 environment-
ally    undesirable.            USFWS specifically          noted that marine
grass beds (used for fish and wildlife                        habitat)        could be
damaged as a result               of using the existing            sites.       The Corps'
Mobile District            estimated      that the cost of dredging                 the
channels       would be increased             from $680 thousand            to $9.0 million
annually       for land disposal            or to $11.0 million             annually        if the
material       is taken to deep ocean waters                  for disposal.             Either
alternative         would cause the channels'               maintenance         costs to
greatly       exceed the calculated              economic benefits            which the
harbor      returns      (about $2 million           annually),        reducing       the
benefit-cost         ratio      from 2.98 to 1, to 0.2 to 1.
        Since the Corps does not routinely             compute benefits        and
costs for existing        projects,     the impact of higher         dredging
costs on the economic viability              of any given project        is
generally      not fully   assessed.       It is reasonable        to assume,
however,     that smaller      waterways     with limited    traffic     which
require     alternative    disposal     methods would be the most
severely     affected.




       ,

                                               22
                                      CHAPTER 6
                  RESEARCH ON DREDGED MATERIAL DISPOSAL
        For several      years,      the Corps has been studying                 the effects
of, and alternatives           to,     traditional        dredged-material          disposal
practices.      Progress       has been made in identifying                   the effects
of dredging,     the alternatives               to traditional        practices,       and
the effects     of implementing             the alternatives.            Research to date,
however,    has not fully          identified        or quantified        the long-term
environmental       risks    of dredged-material               disposal     operations.
       Most of the research     on the environmental         effects     of
dredged-material    disposal    has been performed        since 1966, when
the Corps began studying      the effects      on water quality         and
water organisms    of open-water     disposal     of contaminated        dredged
material    from Great Lakes harbors.         The results     of this      study--
which was completed      in 1969--were     inconclusive.        These results,
and increasing    concern over the effects          of dredging      operations
in other parts of the Nation,        led to the development           of the
Dredged Material     Research Program (DMRP).
      LJSFWShas played an active  role in the                    DMRP, but EPA had
not directly  participated in the DMRP until                     an EPA/Corps
Committee was established  in October  1975.                     (See p. 28.)
         The DMRP, to be completed              in 1978, should add to the
body of knowledge           on the effects         of, and alternatives          to, tradi-
tional     dredging      practices,       but it is questionable           whether     the
program will        answer all questions             on the effects       of, and
alternatives        to, traditional          practices.       According      to DMRP
officials,       additional       work will       need to be done under the
general      categories      of (1) conducting          follow-on      research,
(2) promoting         technology      transfer,       and (3) conducting         new
research.        DMRP officials         told us that this         additional       work
could be started          before    the DMRP is completed            if additional
personnel       and funding       were available.
OBJECTIVES AND STATUS OF THE---DMRP
      The DMRP was authorized        by section  123 of the River and
Harbor Act of 1970 which called         for the Corps to conduct   a
comprehensive    research    program on the characteristics     of
dredged material     and alternative     methods for its disposal.
The Corps assigned      this   task to WES.
       In 1971 WES started   a study to identify                   and assess the
problems,   and to develop   a proposed     research               plan.    This work
was completed    in November 1972, and in 1973                   the Office     of
Dredged Material    Research was established         to            conduct   a 5-year,
$30-million   study designed   to identify:

                                          23
       --The effect      on water quality            and aquatic            organisms         of
          dredged-material      disposal           in water.
       --Potential          uses of dredged        material       for      creating       wild-
          life     habitat.
       --Better       ways of managing          material      placed            in confined
          land     facilities.
       --The      potential   for   productive         uses of dredged                material.
As of January   1, 1977, 148 research units had been completed,
88 were in active   status, and 24 more were planned.
       WES' guidelines        for   the    study      provided          that:
       --The research    would avoid             problems        restricted           to one
          area or a single    dredging             project.
       --A majority       of the research       (a goal of 70 percent        was
          established)       would be done under contracts           with
          private     industry,    universities     and institutes,       other
          Federal     agencies,    Corps district      offices,     and other
          Corps laboratories.
       --Independent     technical          consultants    and a technical
           advisory  board would          direct    and guide the program.
According      to WES officials,      the research               is expected            to be
completed      on schedule     in March 1978, but                additional           research
and/or    follow-on    evaluation     studies  will              be desirable             after
that date.
Effects  of open water disposal
on water quality  and aquatic   organisms
        When the DMRP was initiated             in 1973, research            centered
on the effects         of open water disposal          on the water column
(the water area between the surface                  and bottom of the dis-
posal area).          As a result,    much of DMRP's research                was focused
on measuring        the effect     on water uuality          and aquatic       organisms
of the release         of chemicals     contained       in dredged material.
Previous      research    had established         that some of the chemicals
disturbed       in the dredging      and disposal        process      were dissolved
in the water and thereby            became more readily            available       for
entry     into the food chain.          The remaining         portion      remained
attached      to other    sediment    particles       (soils     and other non-
chemical      solids)    and settled     in an undissolved            state.
       Corps officials    told us that DMRP laboratory   studies
revealed    that chemical    effects on the water column at a

                                           24
disposal    site were insignificant      to nonexistent.         A contract
study performed       for the DMRP concluded    that only ammonium,
iron,    and manganese were shown to be released            in significant
quantities,     but none of these constituents         were considered
to be highly     toxic    and all are required    nutrients      for
organisms.
       The Corps said        that DMRP field      studies    at      two sites
produced   preliminary         results indicating       that
       --water     quality  effects   of open water            disposal     of
          both contaminated       and uncontaminated             dredged
          material     were minimal,
       --ammonia      and manganese       were the only constituents
          released     to the water       column in significant     con-
          centration,     and
       --heavy    metals   and nutrients        were found to either
          show no significant       release,      or to decrease   in
          concentration     during    disposal.
        Corps officials      said that other        results      of field
investigations       have shown that bottom-dwelling                organisms
have migrated       upward through      coverings      of various       depths
of dredged material.          Another     study showed little           uptake
of heavy metals        from heavily     contaminated         sediments.
According      to the Corps, the long-term            effects     of dredged
material      on aquatic   organisms     after    the material         has settled
have not been fully        or satisfactorily          established.
       Because WES' concerns    about the effects      of contamination
in the water column have decreased,        emphasis has been shifted
to examining    the longer-term   effects     of dredged-material
disposal    on bottom-dwelling   communities.
Use of dredged        material    for
creafing-wilalife         habitat
        The overall     objectives       of the habitat        development       project
were to evaluate        the feasibility        of establishing         productive
biological     habitats     on dredged material,            and to identify         the
environmental       impacts     associated     with the disposal          of dredged
material     on wetlands.        The project       consists     of five     inter-
related    tasks:      (1) the effects        of marsh and terrestrial
disposal,     (2) marsh development,            (3) terrestrial        habitat
development,      (4) aquatic       habitat    development,        and (5) island
habitat    development.         As of April      1977, some preliminary
results    had been obtained,          but a final       report    on this     segment
of the research        had not been published.


                                          25
                                                                                   J




Other    productive    uses
       WES has completed         a marketing    survey which showed that
there    is potential      for using dredged material           to serve land-
fill   and construction         needs.    The survey showed that potential
future     uses of dredged material          as sanitary     landfill     cover,
fill   for strip-mined        areas and abandoned quarries,            park
development,      industrial      parks,   beach nourishment,         and airfield
and highway construction,            would substantially        exceed the avail-
able volume of dredged material.               The location       and timing     of
the uses, however,         often do not coincide         with the availability
of the dredged material.
        WES concluded     that it would be practical            to stockpile
the material      at locations        strategic      to needs and that it could
be sold to recover        transportation         costs after    it had been
cleaned    and dewatered.        A WES contractor         also recommended
use of the material         for creating        new land either     by extending
shorelines    or creating       artificial       islands.     The land could
be sold to recover        the costs of its creation.
      The actual economic feasibility             of these     approaches,
however,  had not been demonstrated.
Results   obtained    from
completed    research
       As of January 1, 1977, 87 reports           had been published
or were being reviewed       for publication.          DMRP officials      said
that although       they are incomplete,      research    results     were
confirming    that:
        --Water    column impact during      disposal   appeared  to be
           minimal    to nonexistent,    and the effect    was pre-
           dominately    aesthetic    in nature.
        --Leaching  of toxic  heavy metals          from disposal     mounds
           into the water column appeared           no greater    than from
           natural sediments.
        --The major bottom impact found at disposal       sites              was
           the physical   mounding of the material;  benthic
           recolonization   of the mounds appears relatively
           rapid.
        --Toxic   heavy metal uptake studies          suggest minimal         to
           no impact in marine and estuarine           sediments.
        --Petroleum   and chlorinated   hydrocarbon          uptake studies
           suggest minimal   uptake from the solid           phase of
           sediments.

                                        26
       --Creation    of marshlands       and artificial         habitat
          might be viable    cost-effective          alternatives       for
          dredged-material     disposal.
       --Equipment        was available      which better       controlled    the
          adverse      effects  of the      physical  act     of dredging.
       --Productive       uses could be made of dredged material,
          e.g.,    strip    mine reclamation,      development      of addi-
          tional    recreational,      and industrial      land-use    sites.
Limitations
         -       of    the   DMRP
        The DMRP has not concentrated          much attention         on river
disposal    areas (such as the Upper Mississippi                River)     and
ocean waters outside        the 3-mile   limit,      even though these
areas are used as dredged-material             disposal     sites.        The
director    of the DMRP told us that much of the research                     done
in coastal     areas is applicable     to river       dredging.         He ac-
knowledged     that research    in deeper ocean waters             is needed,
but told us that because of the high costs of such research
in comparison       with the amount of material          disposed       of in
these areas,      it was not included      in the research           program.
Post-DMRP
--            study
       After    the DMRP is completed    in 1978, several      environmental
questions     regarding    dredging  and disposal   operations     will
remain,     and additional     work will be needed.
       A post-DMRP study is proposed            by WES to begin in 1978
when the DMRP is completed.           According       to WES, preliminary
cost estimates      range from $9 million         to $15 million      and the
post-DMRP could be completed           in 3-l/2     to 5 years depending      on
which of several       options    is chosen.      A DMRP official      told us
that,   given additional        manpower and funds now, the project
could start    within     9 months,   thereby     shortening    the time
period    for completion       of the follow-on       work by about 6 months.
The additional      research     needs identified       for the post-DMRP
study include:
       --Continued     monitoring      of      selected  field sites     to
          asse'ss long-term      effects        of marsh and terrestrial
          development.
       --Continued       monitoring     of open water disposal     to
          evaluate      ecological     impact and develop   procedural
          guidelines       for routine    operations.
       --Study     of ecological  problems    associated      with       confined
          disposal    areas and comparison     of the effects            of dis-
          posal alternatives     and dredging     techniques.
                                          27
       --Evaluation    of concepts     and assessment    methodologies
          for disposal    area re-use,    disposal   area sizing,      and
          material   dewatering.
       --Establishment     of a WES advisory          group   to provide
          assistance   to Corps' districts           in application      of
          DMRP technology.
       --Identification          of new issues   and needs      relating     to
           a combination        of dredged material   with      solid    and
           liquid     wastes.
       --Developing   and refining     techniques    for evaluating
          existing  aquatic   ecosystems,     and predicting     the
          impact dredged-material      disposal   has on them.
Federal    agencies'
involvement     In the      DMRP
       To encourage      their    involvement     in the research       program,
WES invited     other    interested      Federal    agencies    to contribute
researchers     to work on the program.             Arrangements     were made
for a scientist       from the USFWS to be assigned             full  time    to
assist    with research       planning,    development,      and management
as a member of the technical             advisory    board.    The USFWS
representative      told us that he has coordinated               USFWS objec-
tives   with DMRP objectives           and he believes      his input has
been a benefit      to the research        program.
         Section     123 of the River and Harbor Act of 1970 called
for the facilities           and personnel     of EPA to be utilized    for
that part of the research            which involved     water quality.
Through December 31, 1976, EPA was conducting                 three research
segments at its labs for the DMRP, but EPA has not been
directly       involved    in the overall      management of the DMRP, or
in the evaluation         of research      results.
       The director    of the DMRP and the USFWS representative
to the DMRP told us that they believed       a full-time      EPA
representative      on the DMRP would be valuable      to both EPA
and the research      program.
        An EPA official     told us that he believed             a joint   EPA/
Corps committee       on the technical        aspects    of regulatory       cri-
teria    for the discharge       of dredged and fill          material    was
an adequate mechanism for EPA coordination                  with the DMRP.
This committee,       which meets       at least   three times a year,
was established        in October      1975 to insure      technically
sound and implementable          criteria     for disposal       of dredged
material     in inland    and ocean waters        by (1) research        coor-
dination     and planning,      (2) providing      interim     guidance     for

                                         28
existing    evaluation     procedures,        (3) preparing an in-depth
implementation       manual,   and (4) recommending.technical
revisions    based on research         results.
        It seems to us that EPA should have played                     an active
part in the DMRP as it was being conducted.                       We recognize
that since the research          program is nearing             completion,      the
value of EPA's direct         participation        in the program is reduced.
Nonetheless,       we believe    that it would be valuable                for EPA to
participate      in the final      stages of the DMRP when final                con-
clusions      of the 5-year    research     effort       will    be developed.
If a follow-on       program to the DMRP is to be conducted,                    we
believe     that EPA should participate            fully      in the initiation
and conduct of the program by assigning                   staff    to work directly
on the program.
        We believe       that EPA's participation      in the final       stages
of the DMRP, and more importantly,               in any follow-on     program
is particularly          important      because EPA is responsible      for
establishing       criteria       and guidelines   for dredged-material
disposal     operations         to which the DMRP and follow-on       program
research     results       will   apply.

OTHER RESEARCH STUDIES
        Research in individual        Corps'   districts      has for the
most part been independent           of the DMRP. In the districts
 included    in our review,       the research    has tended to be in-
conclusive.         It especially    has not,dispelled        concerns  about
long-term      effects   of dredged-material         disposal   on the aquatic
environment.
       Research studies       have been, or are being,        conducted     in
the San Francisco        Bay area, Mobile Harbor,        New York Harbor,
and the Upper Mississippi         River.       These studies   were concerned
with the effects        on the local     environment    of dredging     and
disposal    activities.
       Other Federal    agencies--such      as EPA, NOAA, and USFWS--
perform    research  related    to the marine environment.       For
example,     NOAA is conducting      a study of water pollution     in
the New York Metropolitan         area which includes    a study of
dredged-material     disposal     in the New York Bight.
       EPA is conducting        research        on
       --bioassay    procedures     to estimate the ecological
           impact on the marine and estuarine      environment              of
          dredged-material      disposal,
       --procedures    and guidelines            for assessing    the   biological
          effects   of ocean disposal,             and
                                           29
       --the    magnitude    and distribution        of settled    and
           suspended material      resulting     from dredged-material
           disposal    and the effects       of pollutants      on freshwater
           ecosystems.
       Corps'   officials    told us that       the   EPA research     is being
coordinated     with the    DMRP.




                                        30
                                       CHAPTER 7
                                       ---
                       CONCLUSIONS
                               --  AND RECOMMENDATIONS
       Waterborne      commerce plays an important              part    in the
national     transportation       system.       To create      and maintain      the
harbors     and channels    for this commerce, dredging                 is required
which entails       the removal      of large       quantities     of sediment.
The discharge       of municipal,       industrial,         and agricultural
wastes into the Nation's           streams has caused this sediment
to become increasingly         polluted,        particularly       near large
metropolitan       areas.
         In less than a decade,            the creation        and maintenance           of
our navigable           waterways     has changed from an activity                that
occurred       relatively       unnoticed      to one that has created              sub-
stantial       controversy.         On the grounds         that the activity           may
seriously        damage the environment,             threaten    human health,           or
reduce benefits            of alternative        uses of water resources;              the
policies,        criteria,      and assumptions         inherent    in earlier
dredging       practices      have been challenged            and in some cases
changed.         Corps' officials         believe,      however,    that in many
cases insufficient            evidence     of these hazards         exists      to
warrant      the economic consequences               of adopting      alternative
measures that have been proposed.
         To confirm     or dispel     the need for substantial                  changes
in dredging       and disposal       methods,        the Corps is conducting
a research      program on the effects              of, and alternatives              to,
its traditional         dredging     and disposal         practices.           Although
incomplete,       preliminary      results       of the research           indicate
that the effects          of open water disposal              on the water
column (the area above the disposed                     material)       are less
severe than had been originally                  thought.         The long-term
effects,     however,      are still      relatively        unknown.         It is
questionable        whether    the present         research       program will
conclusively        answer all the questions              about the environmental
effects     of, and alternatives            to, traditional           dredging       and
disposal     practices.
        The current       research    program is planned              for completion
in early      1978, but program officials              have told         us that a
follow-on       program is desirable          to continue          monitoring    on-
going research         to determine      long-term        effects,       do new work,
and facilitate         the transfer      of information            learned    in the
program to a form usable by Corps'                  districts.           They told us
this    follow-on      program could be started               now if additional
personnel       and funding       were available.           Information       on the
extent      to which the follow-on           program could be expedited
with more funding           and personnel       could be of use to the Congress
in considering         appropriation       requests       for the program.

                                             31
         EPA has worked with the Corps in the development                        and
refinement      of dredged-material           disposal       criteria,      has
coordinated      with the Corps on various               aspects       of the DMRP,
and is conducting          its own research         relative        to dredging.
EPA's direct      participation          in the DMRP, however,            has been
limited.       USFWS has assigned          a scientist        to the DMRP to
assist     with research       planning,      development,          and management.
       Because EPA is the Federal               Government's     lead agency in
environmental        protection,       we believe     that EPA should assign
a senior     level       individual    to work on the final          stages of the
DMRP to assist          in the interpretation         of research       results      and
the development            of final   conclusions     for the 5-year        research
program.       More importantly,          we believe      that if a follow-on
program to the DMRP is developed,                 EPA should participate
fully    from the beginning           by assigning      staff  to work full          time
on the initiation             and conduct    of the follow-on        program.        EPA's
involvement       in both the ongoing and proposed               follow-on        programs
is particularly            important   because EPA is responsible             for
dredged-material            disposal   guidelines     and criteria        to which
the research        will      apply.
        Until      the ongoing       or follow-on            research      programs       confirm
or dispel        the environmental            risks      of traditional           disposal
practices        or develop        new disposal          alternatives,          decisions
will    continue       to be made on how to dispose                     of the material
based on the best available                   scientific          technology        (oftentimes
incomplete)          and subjective         evaluation.             The choices        of what
to do in the meantime on any given project                              range from modi-
fying     existing       practices       to better         protect      against      environ-
mental damage to accepting                  the potential            environmental          risks
of traditional           dredging     and disposal             practices.         Judgments
between these choices               depend on (1) quantifying                   the environ-
mental     risks      and (2) knowing what the alternatives                          will     cost.
The DMRP should provide                information           which can be used in
better     quantifying          the risks       but the research             has not been
completed,         and overall       conclusions           have not yet been drawn.
The cost of alternatives                 (ranging        from an estimated             100 to
1500 percent          more than current            costs for the projects                 we
reviewed)        have not been calculated                  on a nationwide           basis.
       Additional    information,      which could be of value in
deciding     among dredging       and disposal      alternatives,       includes
the range of methods for disposing              of dredged material            for
each project,     the environmental         benefits      or disbenefits         of
each method where known and identification                    of disagreements
as to such benefits        or disbenefits,        and the estimated          dis-
posal costs associated         with each method.            Such information
could be of value in future           decisions       regarding     tradeoffs
between environmental         and economic values.


                                                32
RECOMMENDATIONS TO THE SECRETARY OF
THE ARMY AND THE ADMINISTRATOR,
ENVIRONMENTAL PROTECTION AGENCY
        We      recommend that for those           dredging     projects   where EPA
objects         to the method or location            of the Corps' dredged-material
disposal          practices, the Corps,in          coordination       with EPA, should
include         in its budget justifications             for those projects
         --the   estimated     cost    of proposed       alternatives         as compared
             to current    costs,
         --a      description      of the Corps'     current      and EPA's      proposed
               disposal      method or location,
         --reasons      for EPA's suggested       change in disposal    method
             or location    including    environmental     benefits   expected
             to be achieved      or adverse    effects  expected    to be avoided
             by the change,      and
         --the     effect    of the proposed        change     on the     economic
             feasibility      of the project.
         We also recommend that EPA take               a more active          role    in      the
Corps'     dredging  research by assigning              staff to
         --work     full    time on the final    stages of the DMRP in inter-
            preting      research  results    and developing  final conclusions
            for the program and
         --participate   fully,  from the            beginning,      on the      initiation
            and conduct  of the proposed             follow-on      program      to the
            DMRP if it is conducted.
       In addition,   we recommend that the Corps                       advise     the
Congress of the extent      to which the anticipated                       follow-on    re-
search program to the DMRP could be expedited                           with additional
personnel   and funding.
AGENCY COMMENTS AND OUR EVALUATION
      Regarding    the recommendation          on additional       information
in the Corps'     budget justifications,            the Department       of the
Army told us (see app. VI) that it believes                  that only those
cases should be highlighted          where significant          cost increases
occur due to environmental          conditions.        This approach,        however,
would not bring      to the Congress'        attention     those cases where
EPA objected    to or questioned         the Corps'     practices,       and changes
were not made and additional           funds were not requested.



                                           33
        We believe        that the Congress         should have the opportunity
to participate          in selecting      between environmental           and economic
considerations          in appropriating         funds for controversial
dredging      projects.        The information        called   for in our recom-
mendation      would provide        the Congress a valuable            tool for such
participation         and, consequently,           we believe    the additional
information        should be included          in the Corps'       budget justifica-
tions     for each dredging         project      where EPA individually         questions
or objects       to the Corps'        practices.        EPA did not specifically
comment on this recommendation                 (see app. VII).
        Concerning    the recommendation        relating     to EPA's
participation       in the Corps'      DMRP, the Department          of the Army
said that it agreed in principle            with the recommendation             but
believed      that the EPA/Corps Committee           on Criteria      Development
was functioning       effectively      and was achieving         coordination      of
research      beyond the degree which any single             person could achieve
at this late stage of the research              program.     EPA did not speci-
fically      comment on this      recommendation,       but did note the
EPA/Corps Committee          has greatly   improved      coordination        of EPA
and Corps research         over the past year.
        We recognize    that the Corps'     research     program is nearing
completion     (planned    for March 1978),     and coordination        between
the agencies      has improved.     Our recommendation,         however,    is
made primarily       to encourage   EPA's participation         in the research
program as opposed to EPA's coordination              with the program.         We
believe    that EPA's participation       in the final       stages of the
program would be valuable         because
       --interpretation          of research        results    and development           of
           final     conclusions    for the       program     will occur during
           this    time period,
       --EPA is responsible         for        dredged-material       disposal
          guidelines     and criteria            to which the     research     results
          will    apply,
       --the     universal      acceptability      and application    of final
           research     conclusions       would be enhanced if the Federal
           Government's       agency responsible       for environmental
           protection      participated       in their   preparation,    and
      --EPA'S   participation   in the final stages of the                      existing
         program would give it a head start     toward full                     partici-
         pation  in the proposed   follow-on to the current                      research
         program if it is conducted.
       We believe     that the EPA/Corps joint     Committee   on Criteria
Development,      which meets only three time yearly,        could be
valuable,    but is not an adequate     substitute    for EPA's direct,


                                          34
full-time    participation         in the current     and proposed   follow-on
research    programs.       It seems to us that the potential            benefits
of EPA's participation           in both the current      and proposed      follow-
on research     programs      far outweigh     the costs to EPA of assigning
personnel    to participate          in the programs.
       Neither   the Corps nor EPA commented specifically             on our
recommendations      that (1) EPA take a more active         role in the
Corps'   proposed    follow-on  research    program and (2) the Corps
advise   Congress of the extent       to which the proposed       follow-on
program can be expedited       with additional     personnel     and funding.




                                       35
APPENDIX I                                                                    APPENDIX I

                                      CASE STUDY
                                      ---
                 GREAT
                 -we-  LAKES CONFINED -- DISPOSAL --
                                                  PROGRAM
        The Great Lakes Confined         Disposal    Program,   established      in
1970, calls     for placing       behind retaining      dikes any material
dredged from the Great Lakes area which is determined                    by EPA
to be polluted.         This program is particularly          important     because
it was the first        major overall     program dealing      with the sus-
pected environmental         effects    of dredged-material       disposal.
As a result,      lessons    learned    in this program may be applicable
in other locations         where dredging      and disposal    changes are
anticipated.        The program to date has been characterized               by
substantial     delays     and cost increases.
BACKGROUND
         In 1966 the Corps began a study of the effects               of, and
alternatives        to, dumping dredged material         from the Great Lakes
harbors      into the lakes.        The study was initiated       because of
concerns       that increased     population    and industrial     development
on the Great Lakes were causing              the sediments     in channels   to
become increasingly         polluted.
         In 1969, the Corps'       Buffalo      District        issued a report             on
this     study which stated      that no harmful            effects       attributable
to open water disposal         had been identified,                but that the
possibility       of environmental       damage existed.               The report
concluded      that in-lake    disposal       of heavily          polluted       dredged
material      must be considered        presumptively          undesirable,            and
that it might be desirable            to construct          diked areas to confine
materials      to be dredged over a lo-year               period       from 35 Great
Lakes harbors        which were considered           highly       polluted.          The
assumption       was that after     a lo-year        period,       sufficient          pro-
gress would have been made under regulatory                        programs        for
controlling       the entry   of pollutants          to permit         a resumption
of open water dumping without              serious       environmental           risks.
         The Congress responded      to this recommendation       by enacting
section     123 of the River and Harbor Act of 1970.            It authorized
the Corps to build,        operate,    and maintain   confined    disposal
facilities     for polluted     dredged material     on the Great Lakes.
The act also authorized         EPA to advise     the Corps as to which
localities     were in the greatest       need of these facilities.
        The legislation         stated     that local      sponsors    were to
provide    all necessary          lands,     easements,     and rights-of-way       for
the proposed       facilities,         and were to contribute          25 percent     of
the construction           costs of the facilities.              The sponsors,     however,
could receive        waivers     of the local       contribution       if EPA found
that the State or local              interests     were in compliance         with an

                                             36
APPENDIX      I                                                              APPENDIX     I



approved       plan for the general     geographic    area of the dredging
activity       for construction,     modification,    expansion,    or reha-
bilitation        of waste treatment     facilities,   and the Administrator
of EPA found that applicable           water quality     standards   were not
being violated.          As of February     1977, 46a/ facilities     were
planned      for the program and 32 have received           waivers  of the
local      contribution.
PROGRAM DELAYS
        When the program was authorized        in 1970, the Corps
developed     two plans for construction       of the facilities--com-
pletion     of the facilities     in two construction       seasons,    or in
four seasons.        The Corps selected   the latter      plan because of
anticipated      lower costs.     As of February     1977, 9 facilities
had been completed,         5 were under construction,       and 32a/ had
not been started.
        The delays        in program implementation              have been primarily
due to the involvement              of other organizations,                both public
and private,         in the site       selection       process.         After     a study
of alternative          locations      for a confined         facility,         opinions
are obtained         from Federal,         State,   and local         groups on the
potential       sites.       Concurrence       on the site       finally        chosen has
to be obtained          from the local         government.          An environmental
impact statement            must be prepared        which entails            contacts
with many different             organizations        interested         in the environ-
mental     implications         of the project.           In addition,          before
construction         can begin,      an agreement         has to be consummated
with the local          sponsor on its responsibilities                    relative      to
the project.
      For two harbors       we reviewed--Conneaut       and Huron, Ohio--
45 and 36 months,       respectively,     were required    from the date
the confined     disposal    program was authorized       by the Congress
until  the final     preconstruction      activities    had been completed.
COSTS
        When the program was authorized              in 1970, the Corps
estimated     that it would cost between $80 million                and $110
million    to build     the facilities        depending     on whether   they
would be completed         in 4 or 2 years,        respectively.       As of
February     1977, the total        estimated     cost of the program
had increased        to about $263 million,          as shown on the
following     chart.

a/Includes        five   land   disposal      sites    requiring      very    limited
    construction.

                                            37
APPENDIX I                                                                                         APPENDIX I


                                           Number of
                                           --                     sites                  Estimated----        cost

Completed                                                  9                              $ 79,749,ooo
Under construction                                         5                                    94,000,000
Not yet started                                   --a/32                                        89,285,OOO

   Total                                              46
                                                      S
                                                                                          $263,034,000
                                                                                           --


a/Includes        five       land      disposal            sites      requiring          very       limited
    construction.
          Several        factors       have contributed                   to the     increased             costs:
          --Inflation.
          --Initial        estimates     were based on the least    costly    sites,
              but local        interests   ultimately  selected  higher    cost
              alternatives          for many projects.
          --Initial    estimates   based on general     assumptions     about
              site conditions    and structural   requirements      were
              modified   based on engineering   studies.
          In the Corps'    Buffalo   District,   for example,                                      least     costly
sites      were rejected     for 9 of 12 planned       facilities,                                    either
because        the site  could not be acquired      or because                                     of State       or
local       opposition   to the least     costly site.
          In addition      to the costs to construct      the confined      disposal
facilities,        operating     costs for dredging     and disposal     activities
have increased         over open water disposal       techniques     because the
material      has to be transported        greater  distances     to the confined
areas.
     In April   1977 the Corps estimated   that costs per cubic
yard for confined   disposal  on the Great Lakes as compared to
open water disposal    were as follows:
                                                                                                        Percent
Area                                       Confined            disposal           Open      lake        increase-
Buffalo   Harbor                                       $5.63                        $1.10                  412
Cleveland    Harbor                                        7.39                       2.00                 270
Detroit   River                                            5.61                      1.10                  410
Milwaukee    Harbor                                        7.26                      1.65                  340

   Average for all                 sites
     using confined
     disposal                                          $6.77                        $1.49                  354


                                                       38
APPENDIX I                                                   APPENDIX I


An April  1977 Corps estimate     for dredged material    requiring
confined  disposal    on the Great Lakes showed that total        annual
costs for maintaining      these projects  were $58.6 million       using
confined  disposal    as opposed to $12.9 million    for open-water
disposal.




                                   39
APPENDIX II                                                          APPENDIX II


                                   CASE STUDY
         DREDGED-MATERIAL DISPCSAL IN THE NEW YORK BIGHT
       The Port of New York handles            more waterborne   commerce
than   any other port in the United            States--about   216 million
tons   yearly.
      Most of the dredged material           from the New York Harbor
area is disposed      of in an EPA-designated          ocean disposal   site
in the New York Bight,          about 6 miles off the New Jersey shore
 (see map on p. 41).         This site has been used for the disposal
of dredged material        for over 30 years.       Most of the material
from New York Harbor contains           high concentrations      of nickel,
lead,  chromium,     and cadmium.       The Bight    is also used as a
dumping area for other materials,            such as sewage sludge from
many municipalities        in the New York City area, excavation
and demolition      materials,      and waste acids.
      In October    1974 EPA announced its intention           to move
the dumping areas for sewage sludge further             offshore   after
July 1976, and to phase out by 1981 the dumping of all
sewage sludge and industrial            wastes in favor of environment-
ally  acceptable    land-based      alternatives.     At the same time,
EPA requested    the Corps to submit a plan for phasing            out
the use of the existing        dredged-material      dump site by 1976
in favor of one further        offshore.
        EPA said that it took the action             to counter      a threat     to
the waters of New Jersey and Long Island                 from an expected
threefold    increase      in the amount of sewage sludge generated
by upgraded     treatment     facilities       in the area.        EPA explained
its plan to move the dredged-material                site on the basis that
both sewage sludge and dredged material                 equally     contribute
to the actual      load--pounds        per year --of    pollutants      added to
the ecosystem.        As of April        1977, sewage sludge and industrial
wastes were still        being disposed       of at the same location           in
the Bight with EPA's approval.
       In July 1975 the Corps responded              to EPA by stating        that
it had no evidence         of adverse impacts        from the disposal        of
dredged material        at the present      site on municipal       water
supplies,     shellfish     beds and fisheries,         wildlife,   or recrea-
tional    areas,     and that the Corps could not increase            dredging
costs by relocating          the present    disposal     site without     first
knowing if there are adverse            impacts    from using the present
procedure.
       In a March 1975 report, NOAA reported   that there was no
evidence   of imminent hazards to beaches and that the temporary
use of a new site would likely   result   in more harm than good.
                                         40.
APPENDIX II                                                                     APPENDIX II
                                         NEW YORK BIGHT




                                                                        u
                                                                MONTAUK                 PT


                                                            ?

                                                                \


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                       I
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                                                                                i
                                                                                    i
                                                                                        ‘\




                            EXPLODED VIEW OF APEX SECTION




        SANDY   HOOK       AMBROSE
                           LIGHTHOUSE.
APPENDIX II                                                             APPENDIX II


          Because of future        uncertainties         about the Bight being
available        for dredged-material          disposal,       the Corps awarded
a contract         in April    1975 to an architect-engineering                 firm
to study alternatives            to the present          site,    such as the
utilization          of the alternative        ocean disposal         sites,    or the
creation       of an artificial         island    in lower New York Bay, a
confined       disposal     concept.        The scope of the report           required
from the firm included             the technical,         economic,       and environ-
mental      feasibility      of the alternatives.
      Preliminary   estimates    of the contract  study indicated
that moving the site 65 miles out to sea would increase
annual costs from about $25 million        ($2.67 per cubic yard)
to about $80 million      ($8.50 per cubic yard).
        The Corps'    New York District        expects       substantially
increased    costs under any plan that would ban the disposal
of dredged material          at the present      site.       The Corps'      District
solicited    estimates       from three private          dredging     firms on the
cost increases,that          could be expected         if the disposal         site
is moved to a location           65 miles away from the coast.                 The
estimated    increases       ranged from 75 percent            to 600 percent.
One firm told the Corps that its fleet                   could not be converted
to meet standards         for towing    65 miles to sea.            In view of the
uncertain    future     of disposal      in the Bight,         the company felt
that incentives       to make investments          in new or modified
equipment    would not be'pre'sent         unless Government            guarantees
or subsidies      would be available.
       As of January        1977, the Corps was still       using the same
ocean disposal        site    for dredged material     as it has for the
last   30 years,      6 miles     off the New Jersey coast.        EPA officials
told us that the impacts             of disposing  dredged material       at
this site will        be evaluated      based on the new revised       ocean
disposal   criteria        of January     1977 to determine    whether    the
use of this      site     should be continued     or terminated.




                                           42
APPENDIX III                                                             APPENDIX III



                                      CASE STUDY
                                      ----we-
                  DISPOSAL OF MATERIAL DREDGED FROM-- THE
                  -_--__-___-__--_--------
                            UPPER MISSISSIPPI
                            ----------------            RIVER
        The Corps'    Upper Mississippi         River navigation        project

extends    from st. Louis,       Missouri,      to Minneapolis,        Minnesota.
The Corps'     St. Paul District         has jurisdiction        over a 242-mile
portion    of the waterway       extending      from Guttenberg,        Iowa, to
St. Anthony Falls       near Minneapolis,           Minnesota.      The Corps
operates     and maintains     a g-foot-deep          navigation    channel        in
the project     area.     Dredging     operations        in this  area have
been the subject       of legal     actions     filed      by the States        of
Wisconsin     and Minnesota.        The Minnesota          legal action       is
discussed     on pages 11 and 12.
WISCONSIN LEGAL ACTION
-----w-P
         In June 1973, the State of Wisconsin                     initiated      legal
action      in the United       States     District       Court to obtain          an
injunction       to prevent       the Corps from disposing                 of dredged
materials      from a maintenance           dredging        project      near La Crosse,
Wisconsin.         The State charged that the Corps had failed                         to
file    an environmental          impact statement           as required        by the
National      Environmental         Policy    Act of 1969.            The Court,      after
a hearing,       granted     a preliminary          injunction        in June 1973.
This preliminary          injunction       was lifted         in July 1973, when
the Court noted that the State had not been able to show
significant        environmental         damage resulting           from dredged-
material      deposits      at specific       sites      in Wisconsin.
        In October       1973, the State,         with more evidence,           made
a motion before          the District       Court for a preliminary             in-
junction      to enjoin       and restrain      the Corps from proceeding
with its dredging           disposal    operations.         In March 1974 the
Court granted         the injunction        and ruled     that the depositing
of dredged materials            within    the State's       boundaries       was a
major Federal         action    which had a significant            effect      on the
quality      of the environment          and, therefore,        before     dredging
could begin,        the Corps was required            to prepare,       circulate,
and file      an environmental         impact statement.           In March 1975
the Corps filed          the impact statement           and the injunction          was
lifted     in April      1975.
       While the injunctions       were in effect,     the Corps was
required    to obtain    the approval   of the Wisconsin      Department
of Natural     Resources    for the selection     of disposal   sites;
however,    the Court allowed      some emergency dredging.        While
the Corps normally       dredged this   area of the Mississippi

                                            43
APPENDIX III                                                              APPENDIX III


River to a depth of 13 feet,                   it was limited   to 11 or 12
feet under the Court-imposed                   conditions.    The Corps
acknowledged     that navigation               was not impaired   because of
these constraints.
       The Corps has since established            a policy   that no new
maintenance     dredging    will    be performed      after January  1976
until   an environmental        impact statement       has been prepared.
The Corps expects        to complete    the preparation      of almost all
its environmental        impact statements       nationwide    by the end
of fiscal   year 1977.
OPTIONS FOR FUTURE DREDGING
AND DISPOSAL OPERATIONS

       The Corps'     environmental       impact statement      on the Upper
Mississippi    River presented        various     options    to the existing
maintenance    practices.         The alternative       methods of disposing
of dredged material         were:
         --Selective         placement    disposal       in selected      areas
            within     the     flood plain.
         --Remote      disposal,   similar     to selective  placement,
            except     that disposal     sites   would be larger   and
            fewer.
         --Central    disposal,     use of a single   central   disposal
            area within     a specified   section   of the river.
         --Removal      from the flood plain,             disposing      of   the
            material      in upland areas.
         The cost      estimates      for     these    methods   were:
                                      Total  average            Unit cost           Percent
Method     of disposal                 annual cost           per cubic yard         increase
Traditional       method                $      740,000            $ .50                --
Selective      placement                    3,670,OOO              2.45                390
Remote disposal                             5,260,OOO              3.50                600
Central     disposal                        8,950,OOO              5.95               1090
Removal from floodplain                     8,120,OOO              5.40                980
         Of these      options,      the Corps        chose the selective        placement
method     rather      than the      traditional         method since it       believed




                                              44
APPENDIX III                                                       APPENDIX III


selective  placement     was environmentally           acceptable
and economically     feasible;     and phased        in the selective
placement  method during       1974-76.
GREAT RIVER ENVIRONMENTAL
ACTION TEAM (GREAT)
       The Corps'   environmental      impact statement  on the Upper
Mississippi    River recommended that a comprehensive          2-year
study of the environmental        problems    associated with channel
maintenance    on the Upper Mississippi        River be undertaken.
Under the sponsorship       of the Upper Mississippi     River Basin
Commission,    a study group was formed in October        1974, which
subsequently    led to GREAT.'
        The ultimate      goal    of the study is to develop       a river
system management plan            for the Upper Mississippi       River that
would incorporate         total     river resource  requirements,      including
commercial      navigation,       fish and wildlife    resources,     and
recreation.
        Federal     agencies    represented     on GREAT are the Corps,
USFWS, EPA, and the Soil Conservation                 Service    of the Department
of Agriculture.          Representatives      from the States         of Minnesota,
Wisconsin,       and Iowa are also members of GREAT. All members
of the team participate            in work-study      groups and leadership
responsibilities         are divided      among the agencies.           Represen-
tatives      of citizen     groups are also invited           to review    study
findings       and provide     nontechnical     information.
       GREAT is also involved             in on-site    inspections      of potential
Corps dredged-disposal           sites      to minimize    environmentally
harmful   disposal     of dredged material            and better    determine
the environmental        effects      of its disposal.          Upon completion
of the Corps'      dredging      activities       for the 1975 season,        GREAT
began an analysis        of the environmental           and economic benefits
achieved    in areas where GREAT recommendations                  were considered.
       Through the uses of town meetings    and study reviews   by
broad-based    citizen  groups, GREAT is able to keep the river
community    aware of its recommendations   and activities.




                                        45
APPENDIX IV                                                             APPENDIX IV


                                    CASE STUDY
                     DREDGED-MATERIAL -----__-__
                     --               DISPOSAL IN THE
                            SAN FRANCISCO
                                        ----BAY AREA
         The San Francisco     Bay area is a mixing       area for the
waters of the Sacramento-San           Joaquin    River systems and the
tidal     waters of the Pacific       Ocean.    It includes    San Francisco
Bay f Suisun Bay, San Pablo Bay, Central              Bay, and South Bay
(see map on p. 47).         The Bay area is the largest         port complex
on the Pacific      Coast,   including     such important     ports as
San Francisco,      Oakland,    Richmond,     and Stockton;    and strategic
military      bases at Alameda and Mare Island.
       The economy of the San Francisco                 Bay area is dependent
on the shipping          industry,      which transports       about 60 million
tons of general         cargo into and out of the Bay area annually.
Foreign     trade accounts         for about 25 percent          of this tonnage,
with petroleum         products      representing      70 percent     of all ton-
nage.      Corps officials         told us that they are responsible
for about 55 percent            or 5.7 million        cubic yards of all
material      dredged annually          from the Bay.       Approximately      75
percent     of the material          dredged by the Corps is disposed
of in the Bay area.             The remainder       is currently      disposed
of in open water,           but has been proposed          for land disposal
at sites      adjacent      to or within       a few miles of the dredge
operation.
BAY POLLUTANTS
        Pollutants       enter    the Bay system from municipal               sewage,
industrial        waste outfalls,         storm drains,      surface      runoff,
aerial     fallout,      discharge      from vessels,       agricultural        drainage
and upland erosion,            and leaching     from waste disposal             sites
adjacent       to the Bay and tributary           waters.        Although      improved
over the last         few years,      the Bay still       contains       substantial
amounts of pollutants.               About 40 percent        of the municipal
sewage entering          the Bay receives       secondary        treatment      and the
other     60 percent       receives     only primary      treatment.
        Environmental       agencies   in the Bay area,         including     USFWS,
have said that much of the dredged material                    should be disposed
of on land or at deep ocean disposal               sites     (loo-fathom      depth).
Corps officials         in the San Francisco       District       told us that
they believe       open water disposal       creates      far less water
pollution      than is created       by waste treatment         plants,    industry,
and natural       processes     such as storm runoffs,          and that it is
much more important          to treat    the causes rather          than the
effects     of pollution.


                                         46
APPENDIX IV                                APPENDIX IV




              SAN FRANCISCO BAY SYSTEM




                           MARE   ISLAND




                           BERKLEY




                      47
APPENDIX IV                                                                   APPENDIX IV


     An example        of   the   issues   being     faced      in     the    San Francisco
Bay area follows.
MARE ISLAND STRAIT PROJECT
       Two-and-a-half       million     cubic yards of material     are dredged
from the Mare Island         Strait     project  annually.    Corps officials
told us this      represents       about 43 percent     of the Corps'   annual
maintenance     dredging     in the Bay.
        The project   involves   dredging      a 30- to 45-foot-deep     channel
in San Pablo Bay, Mare Island          Strait,     and the mouth of Carquinez
Strait.     The Mare Island     channel portion       is used by nuclear
submarines     and other deep-draft       naval vessels      moving to and from
the Mare Island     Naval Shipyard.         Carquinez    Strait,   an EPA-ap-
proved disposal     site,    has been used as the disposal          site for
the dredged material.
        EPA and USFWS consider         the Mare Island          Strait    project     to
be the most environmentally            sensitive       maintenance       dredging     project
in the Bay area, and the Carquinez                Strait    disposal       site   to be
the least      environmentally      desirable.         Mare Island       and Carquinez
Straits     are corridors      for anadromous        fish    (ocean fish which
return     to fresh water to spawn).             Several     species--chinook,
steelhead,      and sturgeon--     pass through        these straits         in their
annual spawning migrations.
       The Corps performed           a tracer     study on the dispersion           of
dredged material        dumped at this site as part of its San Fran-
cisco dredged disposal            study.      The tracer     study was conducted
in North San Francisco            Bay to determine       the long-term        dispersion,
deposition,       and circulation        of   sediments    dredged   from     Mare
Island     Strait   and dumped at the Carquinez             disposal    site.       The
study showed that
       --the   dispersion of dredge             material       after        disposal   was
           very rapid and
       --dredged      material     was found       dispersed         over      100 square
          miles.
Additionally,   the Corps told us that between 10 to 15 percent
of the quantity    discharged at the disposal site returns to
the dredged channel.
       In a July 1975 letter        to the Corps'       San Francisco     District,
the Department      of the Interior        noted that concern       about the
suspected    physical,    chemical,      and biological      impacts   of dredging
and disposal     on anadromous      fish passing      through    the Carquinez
Strait   dredge spoil     disposal     site had caused State and Federal

                                           48
APPENDIX IV                                                             APPENDIX IV


biologists       to request    that the site     be used only during       the
months of       December, January,      and February      when the fish are
present    in    lower numbers.     Due to a high shoaling          rate in the
Mare Island        Strait,  the Corps has stated        that it is necessary
to dredge       on a semi-annual    basis,    from September      through
November,       and from February     through    April.
         In January        1975, USFWS suggested           the construction           of a
disposal      pipeline       to an island       located      about 20 miles from the
dredging      site or to the lOO-fathom                depth of the ocean to alle-
viate      the Bay disposal         problems.       As interim        measures,       USFWS
said that       it would prefer         the use of the Navy's              Mare Island
land disposal          site    (capable    of handling        only about 3 million
cubic yards of material)               or a new aquatic          site     several     miles
to the west of the present                Carquinez      Strait     site.      The Corps'
District      Engineer       maintained      that,     besides     being more expensive,
transferring         the dredged material            to another       aguatic     disposal
site     in the Bay could increase              shoaling      in another       location.
     The San Francisco      Bay Conservation       and Development
Commission,   a regional    planning    agency established      to protect
the Bay, had suggested      that disposal      of dredged material      should
be on dry land,     in approved    fill  projects,    in the ocean, or--
as a last alternative--     at designated      Bay disposal   sites.
       As of April 1977, Corps'    officials told us that the
Carquinez   Strait was still   being used as the disposal       site
for dredged material    from the Mare Island    Strait project.
       The Corps      estimated      that the disposal          costs for the Mare
Island   Strait      project     would increase        substantially        if it had
to change from        the Carguinez          Strait  disposal       site to more
environmentally         acceptable       sites.     The following        table   shows
Corps estimates,          prepared     in September      1974, based on the
removal   of 1.8      million     cubic yards annually            in the Mare
Island   Strait      project.
                                  Cost per             Approximate           Percentage
Disposal
_------      site              cubic
                               --      Yard
                                        --       --------a-- annual cost
                                                 total                         increase
                                                                              ----
Carquinez     Strait
   (current    site)              $ .25              $      450,000                --
Petaluma    (land)                 2.72                  4,896,OOO                 988
 100 Fathoms (ocean)               2.97                  5,346,OOO              1,088




                                          49
APPENDIX IV                                                                     APPENDIX IV


SAN FRANCISCO BAY STUDY
-7
       A dredged disposal     study for the San Francisco     Bay and
Estuary    was conducted    to complement    the Corps' DMRP (see
ch. 6).     The study was initiated      in April  1972 and the main
report   was published    in February    1977.
        The purpose of the Bay study was to provide          definitive
information       on the environmental    impact of dredging      and dredge
spoil    disposal    in the San Francisco    Bay.    The study's      scope was
divided     into the following     three categories:
      --Dredging            with      aquatic    disposal     within      the   Bay.
      --Alternative                disposal     methods.
      --Dredging            technology.
       The Corps conducted    the study in cooperation      with EPA,
USFWS, the National     Marine Fisheries  Service,     State and local
agencies,   and consultants.     The cost of the study was about
$3 million.
      Some of         the    conclusions         of the     study      were:
      --Although     large changes in water quality   were
         demonstrated,     no analogous changes in organisms                                were
         observed.
      --Release     of toxicants during     dredging  and disposal
         operations    seems to be at such low levels           and to last
         for such short durations       that their   availability      for
         uptake and accumulation      is extremely    limited.
      --Open water disposal        is not considered                       a significant
         blockage     of the channels     for migration                     of fish,
         particularly      through   Carquinez   Strait.
      --The transport   of highly  contaminated      sediments                             from the
         Bay to deep water ocean disposal      sites    has the                            potential
         for creating long-term   biological     impact.
      --Extensive   land disposal         for maintenance     dredging   projects
         does not appear to be a viable           alternative     to aquatic
         disposal  at this        time because of costs,      identified
         technical  difficulties,         and adverse environmental       effects
         which may be involved.




                                                 50
APPENDIX V                                                              APPENDIX V
                                    CASE STUDY
                       DISPOSAL OF DREDGED MATERIAL

                   AT SELECTED GULF OF MEXICO HARBORS
MOBILE HARBOR
        Mobile Harbor,     Alabama,     contains      about 42 miles of
navigable      channels.    To maintain       these channels         at the author-
ized 40-foot       depth requires     the removal of an average of 7.5
million     cubic yards of sediment         each year at an average cost
of $.21 per cubic yard.           Material      dredged from the bar channel
leading     into the Gulf of Mexico is deposited                by hopper dredge
into the open water in the Gulf.                Material     dredged     in the
Mobile Bay channel       is deposited       by hydraulic        pipeline     on
either    side of the channel.          Material      from the river        portion
of the channel       has for a number of years been confined                   by
dikes.      The Corps'   Mobile District          long-range     disposal      plan
had called      for the continued       use of these disposal            practices.
       In response    to the Corps District's       draft  environmental
impact statement      dated July 25, 1974, which described          these
plans,   EPA and the Department       of the Interior     objected    to the
planned   enlargement     of the existing     diked areas and recommended
that alternate     methods be sought for the disposal           of material
now disposed     of in the Bay.
        The project's        local   sponsor,   the Alabama State Docks
Department,      proposed       two alternate     disposal      sites:     Blakely
Island     and Pinto     Island.      These proposed       sites     were approved
by EPA but Mobile County expressed                reluctance        to use them
until     more alternatives        were considered.          The alternative       dis-
posal sites       would increase        the cost of dredging           the river
channel      from about $.81 per cubic yard for the long-range
plan to between $1.34 and $2.00 per cubic yard for the
alternatives,       increases      of from 65 to 147 percent.
        The Corps'   Mobile District      developed     three alternative
plans for disposing       of material     dredged from the Bay:           (1) a-
longside    the ship channel,      (2) on islands       constructed     in the
Gulf,    and (3) in diked islands       along the Gulf shore.           According
to EPA, the capacity       of the proposed       land sites      will be reached
in 12 years,      and as a result,    the Corps will        be faced with the
recurring     problem of selecting      suitable     land disposal      sites.
       In   its long-range     plan,   the Corps District   planned     to
continue      dumping material     dredged from the Bay channel       into
the open      waters of the Bay.       District   officials said that the
cost of     confining    the material     in dikes or of transporting      it




                                        51
APPENDIX V                                                                   APPENDIX V


to the Gulf for disposal              would     be prohibitive,           but they     had
not prepared  cost   estimates            of    the economic          implications      of
the suggested   changes.
GULFPORT HARBOR, MISSISSIPPI
       The authorized       Gulfport     project    provides      for a channel
19 miles    long, with varying         depths,    from the Gulf of Mexico
to the Gulfport        Harbor facilities.         Dredging      is usually
performed     annually.      An annual average of 2,930,OOO cubic
yards is hydraulically          dredged and 910,000 cubic yards were
hopper-dredged.         The material       is deposited      along the ship
channel    and in the Gulf.
        In its May 1973 draft             environmental         impact statement
on the Gulfport          Harbor,      the Corps stated          that,     due to the
25mile      distance      to the nearest          upland areas suitable              for
dredged spoil         disposal,       it did not consider            alternatives
and would continue            present     dredge and disposal             methods.        EPA
objected,       stating     that continued         use of the existing             sites
would eventually          restrict       or alter     circulation         patterns       with
a resultant        degradation        in water quality.            As a result,          EPA
suggested       that the Corps give consideration                     to placing       the
material      on upland areas and in Gulf water areas deeper than
the ones normally           used.
      The Corps estimated             that if the suggested     actions   were
implemented,   the effect            on the project's  benefits      and costs
would be as follows:
                             Estimated               Estimated            Benefit-to-cost
Method                   annual benefits            annual costs                  ratio

Open water                   $2,026,900              $      679,534                  2.98
Diked upland
   areas                       2,026,900                  9,000,000                     23
Ocean disposal                 2,026,900                 11,000,000                   :18

       The high costs for the alternate                plans were due to the
unavailability        of suitable     land in close proximity            to the ship
channel      and the need for additional            equipment     to dredge and
transport      the material      to the Gulf.        Unless required       to do
otherwise,       the Corps plans to continue             its traditional      method
of dredging        and disposing    in the open water since the other
methods would be economically             prohibitive.




                                           52
APPENDIX VI                                                                                   APPENDIX VI


                                 DEPARTMENT    OF THE                   ARMY
                        OFFICE     OF THE ASSISTANT                     SECRETARY
                                      WASHINGTON.        D.C.   20310




                                                                                28 FEB 1977



    Mr. Henry Eschwege
    Director,   Community and Economic
       Development Division
    General Accounting    Office
    Washington,   D.C.   20548



    Dear Mr. Eschwege:

          This is in reply to your letter      of 7 December 1976 to the Secretary
    of Defense forwarding   copies of your draft report,     "Dredging America's
    Waterways and Harbors--More    Information    Needed on Environmental and
    Economic Issues,"   OSD Case #4488.

          Representatives  of GAO and Corps of Engineers have met and dis-
    cussed a number of recommended proposed changes to the draft report.
    Most of our suggestions,    many of which were updating information, were
    agreed to by your auditors,

         As a general observation  we agree in principle                         with the recommenda-
    tion made on pages iv and 38 of assigning     an EPA                     staff member to work
    full  time on the DMRP. However, we do feel that                         the EPA/CE Committee
    on Criteria  Development is functioning   effectively                       and achieving  coordina-
    tion of research and planning   to a degree beyond                       which any single person
    could effect  by being assigned to the program at                        this late stage.

             The recommendation on pages v and 38 suggests that when EPA objects
    to the method or location           of the Corps dredged material         disposal     opera-
    tions,     the Corps should include certain          information     in its budget justi-
    fications       for those projects.      We believe     this recommendation        should be
    modified      to properly   reflect    the consultation      and coordination       responsi-
    bilities      of both EPA and the Corps to jointly           solve environmental        pro-
    blems.      We should only highlight       those cases in which significant             cost
    increases       occur due to environmental      conditions.       This suggestion       can be
    accomplished       by changing the last sentence on page v to read:                 "GAO
    recommends that the Corps, in conjunction               with EPA, prepare and provide
    such information        to Congress, on those individual          dredging projects
    where there has been a change in method or location                  of the Corps dredging




                                                    53
APPENDIX      VI                                                                    APPENDIX     VI



     and disposal    operations  for environmental     reasons resulting        in significant
     cbst increases,"     (See page 38).   Appropriate     changes should       also be made
     to the recommendations     on page 38.

          We are inclosing      several    specific   recormnended changes to the report
     to more appropriately      reflect    our views.

          We appreciate      the opportunity to review      the draft report      and for
     our representatives      to discuss in detail  its     salient  points.

                                               Sincerely,




     1 Incl                                    Charles R. Ford
     as                         Acting    Assistant    Secretary of the Army
                                                (Civil  Works)



     GAO note:     The inclusure     mentioned       above is    not included
                   in the report,     but was       considered    by us in
                   preparing    this  report.




     Note:     Page references      in    this   appendix   refer to our draft
               report   and may   not     correspond     to the pages of this
               final  report.




                                                  54
APPENDIX       VII                                                                    APPENDIX           VII


 &@ S”**
+hiy
B
0 s3?2
          !       UNITED    STATES     ENVIRONMENTAL              PROTECTION    AGENCY
        $
 %r4LpR&G~                              WASHINGTON.        D.C.   20460




                                                                                            OFFICE OF
                                                                                 PLANNING    AND MANAGEMENT



           Mr.   Henry Eschwege,     Director
           Community    and Economic      Development              Division
           United States General   Accounting     Office
           Washington,   D. C. 20548

           Dear      Mr.   Eschwege:

                   We have reviewed       the draft report    entitled   “Dredging    America’s
           Waterways      and Harbors     - More Information        Needed on Environmental
           and Economic       Issues. ‘I We appreciated      the opportunity      to work with
           the General     Accounting    Office auditors   in reviewing      the draft and are
           pleased   to find that many improvements          suggested     have been incorpo-
           rated into the report.

                    We agree with the general        premise       of the report    that more
           information    is needed on the environmental              and economic      issues
           associated    with the dredging      of America’s         waterways     and harbors.
           As was brought      out in our discussions,          the environmental        and
           economic    issues of dredging       America’s        waterways     and harbors      are
           very complex      and are extremely        difficult    to communicate       simply
           and in a brief report.      At the risk of calling          factors   to your attention
           that have already     been included      in the final version,         we think the
           following   concepts    are significant      and worth summarizing.

                     1. Adverse        physical   effects of dredged    material    disposal,
                     as differentiated       from effects   of contaminated      material,
                     are quite important.

                     2. Degradation      and destruction     of the natural    environment
                     often result   in short-   and long-term      economic     costs to
                     society  that greatly    exceed the short-term       increase     in
                     dredging   costs.




                                                      55
APPENDIX        VII                                                                     APPENDIX     VII




                                                                                               2
           3. Traditional       disposal    practices     sometimes    include   dumping
           material   near the dredging         site where material       often returns
           to the channel or harbor         necessitating     the extra expense and
           associated     potential   environmental        damage of redredging.

           4. Modern      dredging   equipment     can greatly    reduce the unit
           cost of disposing     of dredged material       and minimize     the
           environmental      and economic     consequences     mentioned      above.
           As of this time,     modern    dredging    equipment     is not widely
           available   in the United States.      (See attachment)

           5. There is a strong interrelationship                between navigation    and
           other national  interests  such as flood            plain management     and
           water quality  protection.

           6. Environmental       legislation     and legislation   authorizing    channel
           and harbor  maintenance,          its scope and date of enactment        are
           controlling factors     that should be examined        thoroughly    and
           placed in perspective.

           7. The Corps/EPA        Joint Research  Committee    has greatly
           improved   coordination     of EPA and Corps research    effort over
           the past year.

            8. Final     revisions      to the Ocean Dumping            Regulations     and
            Criteria    were published        in the Federal         Register    on January    11,
            1977, and significantly          update the criteria         for evaluating
            dredged material         proposed      for ocean disposal.           The revisions
           further    provide     procedures        for the selection       and management
            of ocean disposal        sites,   including     criteria     for evaluating     dump-
           ing impact      to determine       whether     individual      sites should be
            designated     for continuing       use or whether         use of such sites
            should be terminated.

           9. The Corps should be funded to construct,           operate,   and
           maintain   navigational  projects  in an environmentally       acceptable
           manner    and to deal with contingencies      that increase     maintenance
           costs,   such as the Kepone contamination       of the James River.




                                                      56
APPENDIX VII                                                              APPENDIX VII




            We appreciate    the opportunity     to review   this draft report prior
    to its submission     to Congress.      Please   contact us if we can be of any
    further  assistance.

                                              Sincerely   yours,


                                             d$h---4WL
                                              Richard    Redenius
                                     Acting  Assistant    Administrator
                                      for Planning     and Management

    Enclosure




                                             57
APPENDIX VII                                                                                             APPENDIX VII

                                                  ATTACHMENT                                                                         .


         Examples of the--heed+     wng                                                          Technology                      .
          In many projects   it is now recognized                                        that     if disposal
                                                                                                                                         .
          sites.     can be located                outside          the      immediate            vicj.nity            of
                    .
         the       harbor      or channel,            one or more of the                         following
         benefits           can 'be achieved:

          (1)      the amount           of dredged              material          that      returns          to      the

         channel        can be reduced,                    thereby         minimizing              the
          frequency          and cost           of maintenance                 dredging;

          (2) material           can be used to stabalize                                eroding         beaches:


          (3) destruction                or degradation                  of important               aquatic
          systems       can be avoided.                                             .


         Unfortunately,                 most equipment                  now in use in               the United
         States        is    not designed             for        cost       effective            removal          and
         transportation                 of dredged              material.


         Investment            in more modern                   dredging          technology             can reduce
         costs       and at the            same      time,        better          protect          the aquatic
         environment.              Many dredging                   systems          now operating                 in
         U&S. waters            are      extracting              only       15 to 20 percent
         solids       and the           systems       cannot            readily          concentrate              the
         fine       clayey      silts        found         in    most      harbors          and channels                   for
         efficient           transport            to suitable               disposal            areas.        Thus,
         much of        the     cost       of     transporting               material            to disposal
         sites       results       from         hauling          loads       that        contain         a   large

         percentage            of water.             For example,                 a .hopper         dredge           can
                                                                                     .
         be inefficient                 because       it        is not       pumping            sediment          while


                                                       58
                                                                                                                  APPENDIX VII
APPENDIX VII



                                                                  2
        it     is     transporting                spoil           to the disposal                    site        and because
        it     has' no means for                      concentrating               .    fine       clayey         silts.
        A conventional                    pipe        line         dredge         with        a single           charge         is
         also        inefficient            because                its     pump does not                   concentrate
         the        solids     and it            is    not         operating             while           the    single
         barge         is    transporting                   the        spoil.           Although           the

         conventional                pipeline               dredge          action         in conjunction
         with        a fleet         of barges                  would       be more efficient                      than
         the        single      barge,           it        is     still         inefficient               when handling

         the        fine     clayey         silts           because             these      materials              cannot
         be readily             concentrated.

         The basic             equipment              is        available              on the market               today             for
         dredging            and transporting                          materials              from       15 to 20 miles
         or more at a reasonable                                 cost.           Chain         bucket          dredges          which
         concentrate                the    solids               by simply              letting           the water          fall
         off        when the bucket                   is        full       have been used for                      years
         in Europe.                 A report            by Adolph                W. Mohr,            MASCE of             the
         Corps        of Engineers,                   South            Atlantic          Division              states       that
         the chain            bucket         dredge              takes          less     power           to operate
         and 4s more efficient                              than          the conventional                     pipeline
         dredge            used in this               country.


         pump,s capable               of concentrating                           clayey          silts         have

         already            been tested               by the Corps                     of Engineers,               Philadelphia

        District.              If     the suction                      head on a hydraulic                       dredge              is
APPENDIX        VII                                                                                                    APPENDIX           VII




   .       reduced             by lowering                it     into     the water                 on a dredging                  arm
           it     can be made to pump spoil                                 with         a high            concentration

           of solids.                  Pneumatic                pumps are             also         ~afl&l;            which
           can handle               spoil         with          a high         solids          content.              The
           system         designed               by the Philadelphia                           District             of the Corps
           of Engineers                   consists              of a special                  dredge          of catamaran
           design          with          its     own propulsion                      system         with          dredge      heads
           and pumps designed                            to give         high         solids          to water             ratios.
           The        system        is designed                  to operate               continuously                as it
           includes              sufficient                bottom        unloading                 barges          to insure
           continual              loading              and transport                  of spoil             to remote
           disposal              sites          without          shut      down of the pumps.                              The
           system          is     descr'ibed               in    the     "Long Range Spoil                          Disposal
           Study,          Part          IV,     Substudy           3, Development                      of New Dredging
           Equipment              and Techniques"                       U.S.        Army Corps                of Engineers,
           Philadelphia,                       Pennsylvania.                   It     has been demonstrated
           that        this       equipment                can pump fine                  clayey           silt      materials
           at a rate              of       7,000,OOO             cubic         yards          of     insitu         materials
           to 11,600,OOO                       cubic       yards        of dredged                 mixture          in 7,000
           hours          (28 cu yd/min.).                         The average                 density             of the         shoal
           material             ~1,300                 gr/l.        This            equipment           was investigated
           for        the Charleston                    Harbor          project           and was found                    to be the
           most        economical                method          of eight              (8) alternatives                     studied
       .
           by the Corps                   of Engineers.                    EPA has recommended                             this
           method          for      use at Gulfport,                      Mobile,              Pascagoula,                 Charleston,
APPENDIX VII                                                                                       APPENDIX VII




                                                         4
.      and Savannah Harbors                     and it        could       be used at most of
       our     large     harbors          because         most of them have similar
                                                                              L
       spoil      disposal            problems.


       The main problem                 seems to be the, initial                     cost      of the
       equipment,         and private              investors           are not willing               to
       invest      in the equipment                 unless         they     can be assured                  of
       a sufficient                 number of contracts                to pay for           the
       equipment         and show a profit.                       However,         where      the cost
       was prorated                 to only     one job such as at Charleston
       Harbor      the cost            was 42$ per cubic                  yard     as compared
       with     $2.64         for     hopper      dredging         the same material
       (1970 prices)                 or about      l/6       the cost       of hopper          dredging.
       If     the cost         of this         equipment          could     be prorated            to
       several         jobs         such as Gulfport,              Pascagoula,          Mobile,
       Panama City,                 and Pensacola            Harbors       on the Gulf            Coast           and
       another         system         to Charleston,              Georgetown,          Wilmington,
       Savannah,         Brunswick,             and Jacksonville                  Harbors      on the
       Atlantic         Coast,         the cost          per cubic         yard     could      be greatly
       ,reduced.         Although             the knowledge            of the advantages                    of.
       this     system         has been available                  since         1969-1970,        little               '
       progress         has been made with                    regard       to implementing
       the use of such a system.




                                                             61
APPENDIX    VII                                                                                                   APPENDIX         VII




                                                               5
     l




           There     is     also     a need for                additional             similar          equipment
                                                                                                             .
           smaller         in size         but    with         pumpout         facilities'for                      use a>ong
           the     Intracoastal             Waterways               and at      small          boat      harbors.
           Silt     and sandbars             have to be removed                         from         the waterways
           and side         channels         at frequent                  intervals            for      proper
           maintenance.              Since            the waterways             travel          through                marshes
           and valuable             shallow            water        bays and estuaries,                           suitable
           spoil      sites        are     frequently               beyond      economic              pumping
           distance.           Moreover,               since        beach erosion               problems                exist
           along     most      of the Atlantic                      and Gulf'Coast                   shores,            much
           of the         sandy shoal            material            could      be      used to good
           advantage          on the beaches.                       Where the beach                   is beyond              the
           economic         pumping -distance                      of a conventional                    pipeline
           dredge,         bottom        unloading             barges         width pumpout                  facilities
           which     can pump to the beach or the dune areas                                                     or bottom
           unload      along        the beach would                      be of exceptional                        value.         The
           Wilmington          District               of the Corps             of Engineers                      has
           experimented             with     this        approach             using      the         split         hull,
           bottom      dumping           barge,         the Currituck.                   Similar                 barges
           could     be used for             pumping               the clayey           silt         materials             to
           upland      diked        areas        or     for        disposal       at ocean              sites.




                                                                    62
APPENDIX VII                                                                 APPENDIX VII



                                                 6



   Thus,     the continued       use of out-dated         dredging    equipment
   has artificially          inflated       the cost    of economically
   sound disposal      practices          that   also   would   minimize   adverse
   effects     on the aquatic           environment.




                                                 63
APPENDIX VIII                                                  APPENDIX VIII


                 PRINCIPAL    OFFICIALS         RESPONSIBLE
                                                         -
             FOR ACTIVITIES     DISCUSSED IN THIS REPORT
                                                      Tenure    of office
                                                      From                  To

                       DEPARTMENT OF DEFENSE
                                          -
SECRETARY OF DEFENSE:
    Harold Brown                                    Jan.     1977    Present
    Donald H. Rumsfeld                              NOV.     1975    Jan.        1977
    James Schlesinger                               June     1973    Nov.        1975
    William  P. Clements,     Jr.   (acting)        May      1973    June        1973
    Elliott  L. Richardson                          Jan.     1973    Apr.        1973
    Melvin  Laird                                   Jan.     1969    Jan.        1973
                      DEPARTMENT OF THE ARMY
SECRETARY OF THE ARMY:
    Clifford   L. Alexander                         Feb.     1977    Present
    Martin   R. Hoffman                             Aug.     1975    Feb.        1977
    Howard H. Calloway                              May      1973    July        1975
    Robert F. Froehlke                              July     1971    May         1973
    Stanley   R. Resor                              July     1965    June        1971
ASSISTANT SECRETARY OF THE ARMY
  FOR CIVIL WORKS:
    Charles  R. Ford (acting)                       Feb.     1977    Present
    Victor  V. Veysey                               Mar.     1975    Jan.    1977
CHIEF OF ENGINEERS:
    Lt.   Gen. John W. Morris                       July     1976    Present
    Lt.   Gen. William   C. Gribble,      Jr.       Aug.     1973    June    1976
    Lt.   Gen. Frederick   J. Clarke                Aug.     1969    July    1973
                 ENVIRONMENTAL PROTECTION AGENCY
                                             --
ADMINISTRATOR:
    Douglas M. Costle                               Feb.     1977    Present
    Russell E. Train                                Sept.    1973    Jan.        1977
    John R. Quarles,   Jr. (acting)                 Aug.     1973    Sept.       1973
    Robert W. Fri (acting)                          Apr.     1973    Aug.        1973
    William D. Ruckelshaus                          Dec.     1970    Apr.        1973


                                    64
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