Submitted to California Central Valley Regional Water Quality Control Board,

In late July 2004 the California Department of Water Resources (DWR) purchased Deep Water Ship Channel sediments that were in a dredged material disposal area owned by the Port of Stockton to enhance the Trapper Slough levee in the Delta. When questions were raised about the potential for these dredged sediments to lead to surface water pollution associated with runoff from the levee where they were placed, DWR conducted some hazardous waste leaching tests to “characterize ” the pollution potential of these dredged sediments. DWR, working with the Port of Stockton, issued a report and a press release stating that the dredged sediments were not hazardous waste. The characterization of wastes and the impact of dredged sediments on water quality are areas in which I have been active for over 30 years. Presented herein is a discussion of the inappropriate approach that DWR used to characterize the pollution potential of the dredged sediments that were placed on the Trapper Slough levee. Also, guidance is provided on the type of studies that need to be conducted to properly evaluate the potential for the dredged sediments to lead to water pollution in Trapper Slough by chemical constituents in the dredged sediments