10 CDF Contaminant Management Actions

10 CDF Contaminant

Management Actions

If the evaluations for one or more of the contaminant pathways indicate

impacts for the proposed CDF design and placement option under consideration,

management actions may be considered (USACE/EPA 1992). Management

actions may include managing or modifying the proposed placement operation,

modification of the CDF design or geometry, treatment of effluent, runoff, or

leachate discharges, and physical management such as covers, liners, or barrier

systems. Several studies have described these management actions and the degree

to which they have been applied to CDFs (Averett, Perry, and Torrey 1990;

USEPA 1994; National Research Council 1997; Permanent International

Navigation Association (PIANC) 1996; Palermo and Averett 2000).

Since CDFs are a containment option, necessary management actions can be

designed, constructed, and operated to meet requirements for even the most highly

contaminated dredged sediments. For this reason, use of the CDF option per se

would rarely be found technically infeasible.

In considering appropriate management actions, the influence of a given

action on multiple pathways should be considered. For example, incorporating a

surface cover of clean material as a final layer in the CDF may serve to reduce

potential impacts of surface runoff, leachate and bioaccumulation pathways.

Table 10-1 summarizes the applicability of various types of control measures

management actions to each CDF pathway.

Once a management action is considered, the pathways influenced by that

action should be reevaluated. The reevaluation would necessarily be an iterative

process, as the reduction of the various pathway releases is considered.

10-1

Chapter 10

CDF Contaminant Management Actions