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emissions from dredged material in CDFs are not regulated under the Clean Air
Act (CAA), since the CAA regulates point and mobile sources. CDFs are neither.
In most cases, air quality is regulated under the CAA only for gaseous emissions
that could be sampled from a waste stream, not for volatilization from an areal
source. Air quality from areal sources is more typically regulated, considering the
resulting quality at a point of compliance or at the nearest receptor. Moreover,
there have been no documented CAA concerns with any CDF anywhere in the
nation. However, the Occupational Safety and Health Administration (OSHA) air
quality standards apply when workers are exposed to inhalation or dermal contact
with vapors while handling and managing dredged material containing certain
volatile organic compounds in CDFs. In the UTM, when volatile emissions are of
concern, evaluations are performed and predicted emission concentrations are
compared to OSHA standards to determine compliance.
Plant and Animal Uptake. The direct uptake or bioaccumulation of
contaminants by wetland and terrestrial plants and animals is not directly
governed by any specific regulations. The plant and animal uptake pathways for
CDFs receiving dredged material are unique in that dredged material is not
sewage sludge, solid waste, or an industrial byproduct. Essentially, dredged
material placed in a CDF is a wet soil, usually from an adjacent waterway,
possibly containing a mixture of low levels of contaminants from various
anthropogenic sources. As explained in the RCRA discussion, none of the current
statutory or regulatory regimes used for land application of sludges or industrial
waste products are appropriate for CDF disposal of dredged material.  However,
the general mandate under NEPA requires evaluations of the uptake pathways,
since uptake and subsequent movement of contaminants into food webs may
result in impacts outside the CDF. In the UTM, the potential uptake of
contaminants into plant and animal tissue is compared to that for a reference
material representative of soils in the vicinity of the CDF had no dredged material
disposal ever occurred there, and if the dredged material uptake exceeds that for
the reference, the potential environmental impact of the uptake pathways is
evaluated in the context of a risk assessment.
1.7 References
Engler, R. M., Wright, T. D., Lee, C. R., and Dillon, T. M. (1988). "Corps of
Engineers' procedures and policies on dredging and dredged material disposal
(the Federal Standard)," EEDP-04-8. U.S. Army Engineer Waterways
Experiment Station (USAEWES), Vicksburg, MS.
Environmental Protection Agency/U.S. Army Corps of Engineers. (1991).
"Evaluation of dredged material proposed for ocean disposal Testing
manual," EPA 503/8-91/001, Office of Water, Washington, DC.
__________. (1998). "Evaluation of dredged material proposed for discharge in
waters of the U.S. Testing manual," EPA-823-B-98-004, Office of Water,
Washington, DC.
1-12
Chapter 1
Introduction

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