Tiered Ocean Disposal Monitoring will Minimize Data Requirements

EPA has developed guidance for a tiered approach to ocean disposal monitoring that includes the following major elements: [1] A heirarchy of monitoring tiers including compliance, nearfield, farfield, marine resources, and ocean processes, [2] Regulatory and environmental endpoints and related null hypotheses for each tier, [3] An iterative process of predicting and field testing disposed waste transport, fate, and effects, [4] A quality assurance plan, and [5] A data management and reporting plan


INTROWCTION
EPA is responsible under the Clean Water Act (a, PL 95-217) and the Marine Protection, Research, and Sanctuaries Act (MPRSA, PL 92-532) for ensuring that man's activities, specifically Ocean disposal, do not unreasonably degrade coastal or open ocean waters. This responsibility includes monitoring environmental and human health effects of Ocean discharges, Ocean dumping of municipal and industrial (M&I) wastes, Ocean dumping of dredged material, and Ocean incineration. The purpose of this paper is to describe EPA's strategy for developing and implementing cost-effective ocean disposal monitoring plans.
issuance and staidards -for Ocean d&psite management which allow only limited environmental effects during individual operations as well as limited accmulative effects from multiple or continuing dumping activities. For example, EPA's Ocean dumping regulations and permits require that limiting permissable concentrations (LPC) of toxic constituents must be met at ocean dumpsite boundaries at all times, also, that the LPCs must be met everywhere four hours after ocean dumping (40 CFR 227.29). In addition, EPA's regulations (40 CFR 228.10) list several Ocean dunping effects (standards) which must be considered when determining whether a designated dmpsite is being unreasonably degraded.
EPA presumes that mpliance with these kinds of permit requirements and dmpsite management standards will protect the marine environment from unreasonable degradation as mandated by the MPFSA.
The goal of EPA's Ocean monitoring program is to provide program managers with reliable information, in a cost-effective manner, on Ocean disposal effects on the marine environment. Such information is needed for decisions on permit reissuance and dumpsite designation modifications, also, in response to public concerns about h m n health and environmental protection. Consistent with this goal, the Agency's first monitoring priority is to provide reliable, low-cost information on ccmpliance with permit requirements and dmpsite management standards. Our second priority is to verify the above-stated presumption that mpliance with permit requirements and dumpsite management standards does, in fact, protect the marine environment fran unreasonable degradation. EPA's ocean monitoring stratery is directly responsive to the above-stated g o d and priorities. None of the several major elements of EPA's ocean monitoring strategy, as described below, is new. What is new is the way we have packaged the several elements into a cohesive, logical strategy.
EPA's Ocean disposal monitoring strategy applies directly to Ocean dmping of M&I wastes, Ocean dmping of dredged materials, and ocean incineration. The strategy also applies in principle to Ocean discharges under 99301(h) and 403(c), C W A .

TIERED
Because EPA fully supports the need to impose time and resource constraints on major activities, our Ocean monitoring strategy is intended to generate only that infomation which is needed by program management for decisionmaking. With this in mind and from our review of traditional monitoring activities and existing concepts, we have decided to apply a tiered approach as the logic f rarnework for our strategy. (Please note that, as shown on Figure  1, the so-called "higher tiers" on the monitoring pyramid are the lower nlrmbered tiers and vice versa.) Within this framemrk, all EPA Ocean disposal monitoring plans should have the following major elements: 1) regulatory and/or environmental objectives, endpoints, and null hypotheses ( H , ) in each tier, 2) an iterative process of predicting and field-testing discharged waste transport, fate, and effects, 3) a hierarchy of monitoring tiers (as shown, for example, on Figure 11, 4 ) a quality assurance plan, and 5) a data management and reporting plan.
Each of these major elements is discussed briefly below.

HYP(YIHESFS
Although a hierarchy (pyramid) of tiers provides the logic framework for EPA's Ocean monitoring strategy, explicitly stated m itoring objectives, endpints, and null h y ptheses ( H , ) are the real substance of the strategy. This is because, once we have achieved the monitoring objectives of a tier, requirements for additional data in that tier may be substantially reduced.
merefore, it is essential that all analyses and field or laboratory studies of each tier be responsive to one or more, explicitly stated regulatory or environmental protection objectives. Short-term (or nearfield) Ocean dunping monitoring activities, for example, muld likely focus on assessment of campliance with LpC requirements within the dmpsite and at the dumpsite boundary. Such a regulatory objective is directly responsive to EPA's monitoring goal. Nearfield monitoring activities may also focus on assessment of sediment deposition and cmposition within the dumpsite (40 CFR 228.10( b) ( 4 ) as a dmpsite management (or environmental protection) objective.
More specifically, the stated objective(s) of each tier should focus on regulatory or environmental protection endpoints against which predicted and measured effects can be cmpared. Such endpoints may be either quantitative or qualitative.
LPC requirements, for example, are quantitative endpoints against which predicted and measured pollutant concentrations may be compared. A qualitative endpoint, on the other hand, could be that waste pollutants must not accmulate within a dunpsite to such an extent that major uses of the site and adjacent areas are significantly impaired. Definitive endpoints such as these will help to minimize data requirements if a l l field and laboratory studies of each tier in an individual monitoring plan are responsive to the regulatory OK enviromental protection endpoints of that tier.

Finally, each tier must have
H O ' s directed at each of the regulatory or environmental protection endpoints.
HO's are statements or conclusions about mpliance with endpoints that may be tested in the field. The rationale for this requirement is simple. once an H, has been demonstrated to be true within an acceptable range of uncertainty, related field studies may be reduced to a level that will continue to verify that the H, is true under varied waste characteristics and disposal conditions.
A typical Ho may be: "Toxic concentrations at the dumpslte boundary do not exceed the LJ?C for the most sensitive indigenous species." &Is will nolmally serve as triggers for mving fran higher to lower tiers. Detailed studies at a lower tier will be justified, normally, only when available data demonstrate that relevant Hots at the higher tier are false or the data are ambiguous.
For exqle, with respect to the above %, if available data demonstrate that toxic concentrations at the dumpsite boundary are close to the LPC level(s), farfield studies may be justified to verify the absence of long term, large scale, biological effects or threats to hman health. Inversely, if dmpsite boundary concentrations are much less than the Lpcs, there may be no need for long tedfarfield studies on biological effects.

PREDICTION AM) VERIFICATION OF TRANSPORT, FATE, AND EFFECE
We have already indicated how important it is for analytic, field, and laboratory studies to be responsive to regulatory and environmental objectives and endpoints. As stated earlier, Ocean disposal permit issuance is based on the presmption (or prediction) that cmpliance with permit requirements and dlrmpsite management standards will protect the marine environment.
There have been significant improvements, over the past ten to fifteen years, in our capability to predict transport, fate, and effects of ocean-disposal pollutants. EPA's Ocean monitoring strategy is intended to capitalize on this improved capability. The idea here is to predict.. . through the careful use of available mathematical models... that Hots are true. Relevant field studies, then, are designed to test such predictions and, hopefully, verify that the Hots are true. However, all such predictions must be within acceptable ranges of uncertainty, ie, confidence limits. If the available field data indicate that the predictions are not reliable, the appropriate mathematical mcdel(s) needs to be refined and, subsequently verified by additional field studies. However, once program managers feel ccmfortable with the predictability of Ocean disposal effects on the marine environment, and that the relevant &,' s are true, additional field studies can be reduced to a level that will just "stay on top" of changing waste characteristics and disposal conditions. It is & s o important to note here that predicted and measured pollutant concentrations in the diluted wastefield represent the effects of pollutant increments above s m e "backgrcund" or baseline concentrations. Hence, input requirements for such predictions and neasurements must include baseline concentrations of all relevant pollutants. Figure 1 shows an example of a ccmprehensive, five-tiered monitoring pyramid that includes:

MONITORING TIERS
(1) source characterization, (2) short-term (nearfield) monitoring, (3) long-term (farfield) monitoring, ( 4 ) biological effects and/or marine resources monitoring, ( 5 ) and ocean process monitoring. &gain, note that the so-called higher tiers have lower numbers. Fs indicated on Figure 1, each of these tiers has a spatial or temporal context ranging, for example, f r m relatively instantaneous sampling of wastes from a barge for physical and chemical analysis to very long-term study and analysis of the effects of major Ocean currents and water mass movements on ocean disposal transport, fate , and effects.
Simply put, EPA's tiered monitoring strategy... and the individual ocean disposal monitoring plans that will flow f r m this strategy.. . tend to answer simple, regulatory questions first, ie, in the higher tier(s). More complex environmental or program-related questions are answered in the lower tier(s). In other words, the analyses and studies beccme more m p l e x as you m v e f r m higher to lower tiers. Also, as explained below, the detailed design of lower tier studies will depend on the results of higher tier studies and analyses. In fact, as indicated in the above discussion on %IS, the results of higher tier studies may often justify a decision not to conduct the more mplex, lower tier studies. Each of the tiers of our example monitoring pyramid on Figure 1 is described briefly below.
Source characterization in Tier 1 would include sampling and physical/ chemical analysis of wastes being disposed (eg, being dumped from a barge), also, a determination of the disposal rate. When Tier 2, short-term (nearfield) studies are being conducted, waste sampling and disposal rate determinations must be done coincident with such studies. This is because the data on waste characteristics a d disposal rates fran Tier 1 sampling and analyses will provide input to predictions of short-tend nearfield transport, fate, and effects which must be verified by field studies in Tier 2. idso, the Tier 1 source characterization data may be ccmpared with permit descriptions and permit requirements for canpliance purposes.
The Tier 2, short-term studies would include the nearfield determination of transport and fate of discharged wastes, specifically, plume tracking studies and sampling within the plume for physical and chemical analysis. -pending on waste and 8umpsite characteristics, Tier 2 studies may include short-term biological effects. Alternatively, biological effects monitoring may be paired with marine resources monitoring at a lower tier (eg , Tier 4 in Figure 1). As in Tier 2, the Tier 3, long-term (farfield) studies would include transport and fate of discharged wastes and nay include long-term biological effects. Tier 3 studies may be canplicated by difficulty in "locating" the diluted wastef ield, ie, many of the waste constituent concentrations may be close to or below chemical analysis detection limits. Hence, tracer chemicals may be required in the long-term studies to "track" the wastefield. Alternatively, drifters and/or satellite imagery data on water m a s s movements may be used at deepwater dmpsites for tracking the wastef ield. As in Tier 2, the Tier 3 field data on waste constituent fate and concentrations (also, marine organism toxic effects and body burdens, if biological effects are included) will be used to verify transport, fate (and biological effects) predictions. Unlike Tier 2 studies, which may span hours or days, the Tier 3 studies will normally span days or weeks, even months and years if biological effects are included.
The Tier 4 studies on Figure 1 would focus on long-term Ocean disposal effects on marine ccmmercial and recreational fisheries: sensitive biological cmunities, such as coral reefs and kelp beds: shorelines and swinnning beaches; and any other marine resource( s ) of social or econanic value. As indicated above, the marine resource studies m y be paired with short-term and long-term biological effects, depending on waste and dmpsite characteristics.
At Tier 5 of Figure 1, the studies would focus on very long-term relationships between discharged waste transport and fate and large scale Ocean current patterns and water mass movements. Such factors may be imprtant if concerns arise about the effects of longterm changes in Ocean currents and background water quality at the dmpsite. & you consider the example pyramid of monitoring tiers on Figure 1 and description of each tier, the statement made earlier regarding "moving from less amylex questions in the higher tiers to m r e m p l e x questions in the lower tiers" becames more clear. Source characterization and short-term studies are conceptually simpler and much less costly than long-term marine resource studies or ocean process studies.
It is important to note here that, although we will expect all Ocean disposal monitoring plans to be tiered, we will not expect all the plans to look like Figure 1. Many monitoring plans, such as for dredged material dmpsite monitoring, may only have three tiers and, possibly, only two tiers, if source characterization is combined with the short-term studies. Nominally, the n m h r of monitoring plan tiers will depend on the potential for long-term, farfield environmental effects and on the predictability of such effects.

. QUALITY ASSURANCE PLANS
Ocean disposal management decisions require good quality data: unreliable data may be wrse than no data at all. Also, the range of uncertainty associated with predictions of waste transport, fate, and effects depends on the quality of data used in the predictive models. In fact, it is often reported that the credibility of such predictions depends more on the quality of data inputs than on inherent uncertainty of the mathematical models. Consequently, laboratory and field studies must be designed and conducted to minimize uncertainty of the resulting data. In this regard, preparation and donduct of an EPA-approved quality assurance plan will be critical for minimizing data quality problems and, thereby, minimizing data collection requirements.
A l l too often, monitoring data are collected and "stored" but not used to answer relevant questions. Any data that are not used to answer regulatory, program management, or environmental protection related questions or are not available in usable form are wasted data. An efficient and practical datamanagement and reporting plan is, therefore, essential for a cost-effective Ocean disposal mnitoring program. Such a plan must include the collection and review of all available, relevant data for establishing baseline information on dmpsite characteristics and marine resources as input to predictions of Ocean disposal transport, fate, and effects. Also, an efficient data base management system must be used for storage and retrieval of all relevant data and should be accessible for response to related questions by future users. Finally, data reportirq intervals and formats should be designed that are responsive to the needs of monitoring program scientists, analysts, and management. This Ocean disposal monitoring strategy, including the five major elements described above, clearly has the potential for minimizing data collection requirements and, thereby, generating cost-effective Ocean disposal monitoring plans.
We have already applied the strategy in the following ways: 1) Developent of a monitoring plan for the 106 mile deepwater disposal site: 2) Development of the North Atlantic Incineration Site monitoring plan: and 3) Evelopent of guidance for dredged material dmpsite monitoring plans.
These three applications have adhered to the basic rule of including all five major elements in Ocean disposal mnitoring plans. The approach has also proven flexible enough to address the distinctly different circunistances of ocean dumping of M & I wastes, Ocean incineration, and ocean dunping of dredged materials.
We have not yet applied the strategy to developnt of §30l(h) or §403(c), C W A , ocean discharge monitoring plans. m e n we do, it is evident that the strategy should generally apply but may need to be carefully adapted to pipe discharge circumstances. In any case, it is certain that application of the tiered monitoring strategy will help us to achieve our ocean disposal monitoring objectives in the most cost-effective manner.