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Contaminated Sediment
IJC Recommendation
"Governments should immediately develop a comprehensive,
binational program to address the full scope of the contaminated sediments
problem over the long term, setting appropriate priorities and defining
the resources required for completion. As part of this comprehensive program,
governments should ensure that:
(i) programs and cost estimates are in place and made public
for fully addressing contaminated sediments in Areas of Concern,
(ii) timetables for fully implementing those programs are
established and made public,
(iii) resources are provided to fully implement the programs
in accordance with the established timetables, and
(iv) progress reports are issued at least biennially."
Response to Recommendation
The IJC, in the preamble to its recommendation on contaminated sediment,
has outlined the significance of persistent toxic substances in sediment
in restoring environmental conditions in AOCs. In addition, the IJC noted
some of the Parties' efforts as well as its own (with the Parties' support),
to respond to this issue. The Governments of Canada and Ontario fully
appreciate the needs expressed in the recommendation above and have been
working cooperatively with industrial stakeholders and other private and
public sector interests in AOCs to identify and implement the necessary
sediment remedial actions.
The IJC expressed some concern with the application of the site-specific
approaches taken by the Parties, as manifested in the apparent contradictions
in the cleanup goals to be attained. The example of polycyclic aromatic
hydrocarbons (PAHs) in the Black River (U.S.) and Hamilton Harbour (Canada)
was cited. The Randle Reef project in Hamilton Harbour is a proposed targeted
intervention at a specific hotspot of contamination, and the PAH level
specified is used to delineate the hotspot. It should not be construed
as an overall cleanup goal for Hamilton Harbour. The effort at Randle
Reef follows an overall sediment remediation strategy that has been developed
for Hamilton Harbour by a RAP Technical Team and endorsed by the RAP stakeholders
(1995 Update to the Hamilton Harbour Remedial Action Plan stage 2 Report,
December 1995, ISBN 0-7778-4897-X). The strategy designates zones for
active intervention (i.e., hotspots where sediment is acutely toxic to
benthos), supports experimentation with techniques such as capping to
evaluate potential remedial measures, and calls for monitoring and research
to evaluate results. The approach taken in this strategy is consistent
with the advice of the IJC's Sediment Priority Action Committee, which
called for an incremental approach to the management of contaminated sediments
and restoration of beneficial uses.
The IJC has also presented additional information to illustrate what
it believes to be the outstanding requirement for sediment remediation.
More specifically, it noted that in Canada only 0.2 percent of sediment
contamination has been remediated. The basis for this figure was not presented,
and Canada sought supporting information from the IJC, which was subsequently
provided to the Parties. We believe the assumptions and calculations made
by the IJC are misleading because they presuppose that evidence of contamination
must lead to some form of direct intervention with a remediation project.
While chemical criteria are often used to spatially delineate areas of
sediment contamination, decisions on intervention integrate additional
information on toxicity, field biological assessment, and environmental
benefits, including linkages to the restoration of use impairments. In
addition, sediment remediation interventions must be technically and economically
achievable. We can illustrate the point as follows. The IJC in its calculations
has identified 600,000 cubic metres in the St. Clair River as requiring
remediation. Substantial work has been undertaken to assess sediment contamination
in the St. Clair River; and analysis of potential remediation needs have
focused on projects involving substantially less than this figure. While
further assessments are being done to define remediation needs, we believe
that the IJC's figure exaggerates the requirement.
To avoid possible confusion, Canada will provide more detailed status
reports on sediment-related work in the AOCs, including projected remediation
needs.
With respect to the specific recommendation brought forward by the IJC,
Canada responds as follows:
Canada, in consultation with the United States, does not support the
development of a binational program to address contaminated sediments.
The Parties believe that the response to sediment management needs (including
program definition, resourcing, timetables, and progress reporting) legitimately
falls under the authority and responsibility of the domestic programs
in Canada and the United States. The appropriate jurisdictions and agencies
responsible for fulfilling these commitments in the AOCs are to be accountable.
As noted above, Canada will undertake, as part of its progress reporting,
to provide more detail on its sediment program and activities in order
to be more responsive to the IJC's recommendations. Canada further notes
that at the binational level, considerable scientific and technical interchange
exists to advance sediment assessment methodologies and technology development
for sediment treatment. In addition, under the Great Lakes Binational
Toxics Strategy, the Parties have initiated work to enhance progress reporting
on sediment-related activities and associated priority toxic substances
and to support joint efforts (such as the April 2001 workshop on contaminated
sediment-treatment technologies). Sediment-related matters are also discussed
by the Parties under the Lakewide Management Plans (LaMPs), the Canadian
Review Panel for Massena (St. Lawrence River) Superfund Sites, and the
Four Party Agreement for the Detroit/St. Clair and St. Marys Rivers and
Lake St. Clair. These efforts, together with others, contribute to a substantive
binational dialogue on contaminated sediment and support the commitments
under Annex 14 of the GLWQA.
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