OSWER Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites (Feb. 12, 2002), established the CSTAG as a technical advisory group to "monitor the progress of and provide advice regarding a small number of large, complex, or controversial contaminated sediment Superfund sites."

On this page:

• Purpose of the CSTAG
• Membership
• Meetings
• Stakeholder participation
• CSTAG recommendations
• Coordination with the National Remedy Review Board (NRRB)

Purpose of the CSTAG

• To help RPMs and OSCs of a select number of large, complex, or controversial sediment sites appropriately investigate and manage their sites in accordance with the risk management principles.
• To encourage national consistency in the management of sediment sites by providing a forum for exchange of technical and policy information.
• To provide a mechanism for monitoring and evaluating the progress at a number of the largest or most complex contaminated sediment sites.

Membership

CSTAG membership has changed periodically over time; it currently includes one representative from each EPA Region, two representatives each from EPA-ORD and EPA-OSRTI, and two representatives from the U.S. Army Corps of Engineers’ ERDC. Members participate in monthly conference calls and in two to four meetings per year. Many of these meetings include site visits, which may involve extra travel time. The representative for the Region where the site visit is taking place is expected to make arrangements for hotel rooms and meeting space. Each EPA member's Region or Office is expected to pay all travel costs, which should be charged to site-specific accounts. Membership entails a significant time commitment, especially when a member is preparing for a meeting to be held in their Region.

• CSTAG Members

Top of Page

Meetings

The RPM or OSC will be notified of a planned CSTAG meeting by the regional member about three months beforehand. The date will be set after consultation with the lead state or Department of Defense (DOD) RPM if the site is not an EPA-lead site. The initial meeting will be held near the site. An overview by the lead RPM will include a presentation of site data and how the RPM is considering risk management principles. This part of the meeting normally lasts four to eight hours, depending on the amount of data available and the complexity of the site. Attendees should include other EPA staff and contractors. State staff and DOD staff should attend at sites where the sediment operable unit is state-lead or federal facility-lead. The meeting will also include a site visit, a half-day session where stakeholders may make presentations, and at least a half-day CSTAG-only session where CSTAG members begins drafting their recommendations.

Members of the site team should be available during CSTAG deliberations to answer questions. In addition to CSTAG members and regional, state and DOD staff, the appropriate OSRTI regional coordinator will also be invited to attend. The RPM should submit a written summary (i.e., a Consideration Memo) to the CSTAG Chair at least two weeks prior to the meeting. The summary should discuss how they addressed each of the risk management principles and include a site background information package. Sections of technical documents may be appended to add additional details if needed.

Initial meetings will focus on one site; subsequent update meetings will usually focus on a couple of sites already visited. Subsequent meetings will usually occur before the RI//FS Report has been finalized, before the Proposed Plan has been sent out for public review and before the first FYR or Site Completion Report has been completed. The CSTAG plans to monitor the progress of each site until all RAOs have been met.

Top of Page

Stakeholder Participation

Although CSTAG meetings are not public meetings, key stakeholder groups with significant site involvement will have an opportunity to give a short presentation to the CSTAG during the first site meeting. These stakeholder groups usually include the lead state agency, the lead potentially responsible party (PRP), the lead trustee, tribe(s) and recognized community groups. To allow adequate time for presentations and questions from the CSTAG members, no more than six presentations should typically be scheduled.

The key stakeholders should be invited at least six weeks before the meeting. Their presentations should focus on how EPA is or should be addressing risk management principles at the site. Each presentation should take no more than 20 minutes, with an additional 10 minutes available for discussion with CSTAG members. If the invited stakeholders decide not to make a presentation, they may submit written materials instead. Other stakeholders not invited to the meeting may also submit written comments to the CSTAG. All written submittals, including a summary of each presentation, should be sent to the EPA RPM at least one week before the meeting. Submittals should not exceed 15 pages.

Top of Page

CSTAG Recommendations

After the initial meeting and any subsequent update meetings, the CSTAG will send the RPM its recommendations on how risk management principles could be best addressed as part of ongoing and planned site work. The CSTAG will provide the RPM with its recommendations within six weeks of the final meeting. The appropriate OSRTI Regional Branch Chief, Division Director, and Office Director and the Regional Branch Chief will be copied; a copy will also be placed on the Contaminated Sediments in Superfund Web page. The RPM will provide the CSTAG Chair with a brief written response to all recommendations within two months of receiving them. The RPM will also send a copy of the response, along with the CSTAG recommendations, to all stakeholders who attended the meeting. OSRTI will also place the regional response on its Web page.

Top of Page

Coordination with the National Remedy Review Board (NRRB)

The proposed remedy for most of the large sites reviewed by the CSTAG will also meet NRRB review requirements. When an RPM prepares the site package for the NRRB, the RPM should also prepare a draft Consideration Memo and submit it to the NRRB and the CSTAG Chair. The memo should document how all risk management principles were considered during remedy selection for the site. The memo should usually be less than 20 pages long. The CSTAG Chair will distribute the memo to CSTAG members for review. To avoid sending two sets of recommendations to the RPM, any CSTAG comments will be relayed to the NRRB Chair. At least two CSTAG members will attend the NRRB meeting (this can include NRRB members who are also CSTAG members) to offer advice on site issues related to the principles.

The CSTAG may modify these operating procedures over time.

Top of Page