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Operating Procedures for EPA's Contaminated Sediments Technical Advisory Group (CSTAG)

Updated 3/19/2008


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."

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.

CSTAG membership has changed periodically since it was created; currently it includes one representative from each EPA Region, two from EPA/ORD, two from EPA/OSRTI, and two from the Army Corps/Engineer Research and Development Center. The current list of members is presented below. Members are expected to participate in monthly conference calls and in two to four meetings per year. Many of these meetings will include site visits, which may involve extra travel time. The representative for the Region in which a site is being visited 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 his or her Region.


The RPM (or OSC) will be notified of the planned CSTAG meeting by the regional member approximately three months prior to the proposed date for the meeting. The date for the meeting will be set after consultation with the lead State or DOD RPM if the site is not an EPA-lead site. The initial meeting for each site will be near the site and will include an overview of the site by the lead RPM that focuses on how the RPM is considering the principles and a presentation of the site data. This part of the meeting normally lasts four to eight hours and is based upon the amount of data available and the complexity of the site and should include other EPA staff and contractors, and State staff and DOD staff, where the sediment OU 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 the CSTAG begins drafting it recommendations. Members of the site team should be available during the CSTAG deliberations session to answer questions. In addition to the CSTAG members and Regional/State staff, the appropriate OSRTI Regional coordinator will also be invited to attend. The RPM should submit a written summary (i.e., a Consideration Memo) stating how he or she addressed each of the principles and a site background information package to the chair at least two weeks prior to the meeting. Selected sections of technical documents may be appended to add additional details if needed.

Initial meetings will focus on only one site; while subsequent update meetings will normally focus on a couple of sites already visited. Subsequent meetings will normally occur before the RI//FS report has been finalized, before the Proposed Plan has been sent out for public review, and before the first five-year review or site completion report have been completed. The CSTAG plans to monitor the progress of each site until all remedial action objectives have been met.

Stakeholder Participation

Although these CSTAG meetings are not public meetings, the Regional CSTAG member and EPA RPM will give key stakeholder groups that have had significant involvement with the site the opportunity to give a short oral presentation to the CSTAG at the first site meeting. This will normally include the lead State agency, lead PRP, lead trustee, tribe(s), and recognized community groups such as those with a TAG. To allow time for adequate presentations and questions from the CSTAG members, no more than six presentations should normally be scheduled.

The key stakeholders should be sent invitations at least six weeks before the meeting in order to allow time to prepare a presentation if they decide to make one. The presentation should focus on how they think EPA is or should be addressing the principles at the site. Each presentation should be no more than 20 minutes with an additional 10 minutes available for discussion with the CSTAG members. If the invited stakeholders elect not to make an oral presentation, they may submit a written one instead. Other stakeholders not invited to the meeting may submit written comments to the CSTAG on how the Principles should be considered. All written submittals, including a summary of each oral presentation, should be sent to the EPA RPM at least one week prior to the meeting and should not exceed fifteen pages.

CSTAG Recommendations

After the initial meeting on a site, and after subsequent update meetings as appropriate, the CSTAG will send to the RPM, within six weeks, its new recommendations on how the RPM might better address the principles in ongoing and planned work. The appropriate OSRTI Regional Branch Chief, Division Director, and Office Director and the Regional Branch Chief will be copied, and a copy will be placed on the Contaminated Sediments in Superfund Web page at: http://www.epa.gov/superfund/health/conmedia/sediment/cstag.htm. 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 that attended the meeting. OSRTI will also place the regional response on the web page.

Coordination with the National Remedy Review Board (NRRB)

It is anticipated that the proposed remedy for most of the large sites being reviewed by the CSTAG will also meet the requirements for review by the NRRB. When an RPM prepares the site package for the NRRB, the RPM should also prepare and submit to the NRRB and the CSTAG chair a draft Consideration Memo. The memo should document how all principles were considered in selecting the proposed remedy for the site and should normally be less than 20 pages. The CSTAG chair will distribute the memo to the CSTAG members for their review. In order to avoid sending two sets of recommendations to the RPM, any CSTAG comments will be relayed to the Chair of the NRRB. At least two members of the CSTAG will attend the NRRB meeting (this can include NRRB members that are also CSTAG members) to offer advice on site issues relative to the principles.

The CSTAG may modify these operating procedures after more sites have been visited, as more experience has been gained, or as members change.

CSTAG Members

Region 1 Kymberlee Keckler 617-918-1385
Region 2 Doug Tomchuk 212-637-3956
Region 3 Randy Sturgeon 215-814-3227
Region 4 Craig Zeller 404-562-8827
Region 5 Jim Hahnenberg 312-353-4213
Region 6 Gary Baumgarten 919-541-4625
Region 7 Craig Smith 913-551-7683
Region 8 David Rathke 303-312-6016
Region 9 Sharon Lin 415-972-3446
Region 10 Allison Hiltner 206-553-2140
ORD Barbara Bergen 401-782-3059
ORD Lawrence Burkhard 218-529-5164
OSRTI Steve Ells, Chair 703-603-8822
OSRTI Marc Greenberg 732-452-6413
Corps/ERDC Earl Hayter 864-656-5942
Corps/ERDC Karl Gustavson 703-603-8753

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