J.5_Revised Final Addendum_1 EMMP.pdf

Revised Final

Addendum 1

Environmental Media Management Plan

National Oceanic and Atmospheric Administration National Marine Fisheries Service

Manchester Research Station Seawater System Replacement and Campus Addition Project

Manchester, Washington

February 2025

1.0 INTRODUCTION

The Environmental Media Management Plan (EMMP) prepared for the Seawater System Replacement and Campus Addition Project was approved by the United State Environmental Protection Agency (EPA) on April 17, 2024. Since that time, construction of the Seawater System Replacement project has been ongoing. The purpose of this addendum is to present the clarifications and adjustments needed as a result of site conditions that have now become known and the decisions that have been made to address these site conditions. This addendum also documents the soil and water disposal methods that have been selected as of August 2024. The previous version of the addendum was submitted to the EPA in October of 2024.

Comments received in November and December of 2024 have been incorporated in this revised final addendum.

2.0 SOIL MANAGEMENT

Table 3 of the EMMP described the general approach to soil disposal methods and provided a range of available disposal methods. Subsequent to the approval of the EMMP, the Construction Contractor has worked to identify waste disposal facilities and their acceptance criteria. Table 3 of the EMMP has been modified by adding a column (in RED) to present the disposal method actually being implemented by the Seawater System Replacement project (see Table A1-1 below).

As noted in Table A1-1, unanticipated contaminated soil (SUN) discovered through the month of July 2024 include visibly contaminated soils encountered during potholing activities in SMC3 and during roadway excavations in SMC1/SMC2. These areas are annotated on Figure A1-1.

Table 1A1-1 – Soil Management Classifications Soil Managem ent Class1

Preconstruct ion Sampling Results2

General Approach to Soil Reuse

General Approach to Soil Disposal (if required)

Selected Disposal Method

SMC1 No contaminants detected above laboratory LOQs

Stockpiled3 directly adjacent to excavation or in pre-approved stockpile location or roll-off bin.

May be reused on site without further sampling, no restriction on location.

May be disposed of, subject to receiving facility acceptance criteria, at a clean fill site such as a quarry (subject to NOAA COR approval), or at a municipal solid waste facility, or Subtitle D landfill.

Reuse on site to the maximum extent possible.

Dispose excess soil at a Subtitle D landfill.

Note: Disposal at clean fill sites excluded from consideration due to lack of controls on the end use of soils.

SMC2 One or more contaminants detected at levels above laboratory LOQs but below RSLs

Stockpiled3 directly adjacent to excavation or in pre-approved stockpile location or roll-off bin.8

May be reused on site within SMC2 or

Must be disposed of at Subtitle D landfill (subject to receiving facility & NOAA COR approval of waste profile) or

Disposal of SMC2 soils at a Subtitle C landfill would

Dispose excess soil at a Subtitle D landfill7.

Reuse onsite within SMC2 area.

Soil Managem ent Class1

Preconstruct ion Sampling Results2

General Approach to Soil Reuse

General Approach to Soil Disposal (if required)

Selected Disposal Method

SMC3 areas without further sampling.

Must not be reused in SMC1 areas unless stockpile sampling4 confirms PFAS and PCBs are below LOQs.

also be permissible, if desired.

SMC3 One or more contaminants detected at levels above RSLs

Placed directly into lined roll-off bin or equivalent lined storage area3.

Must not be reused on site unless stockpile -excavation sampling4 confirms PFAS and PCBs are below RSLs.

If PFAS are below RSLs and PCBs are below 50 mg/kg, soil may be disposed of at a Subtitle D landfill (subject to receiving facility and NOAA COR approval of waste profile).

If PFAS are above RSLs or PCBs are above 50 mg/kg, soil must be disposed of at Subtitle C landfill (subject to receiving facility & EPA approval of waste profile) unless sampling4 of stockpile/roll-off bin confirms PFAS and PCBs are below RSLs.

If PCBs are detected above 50 mg/kg in soils, moveable equipment/ sampling supplies will be double washed/rinsed as discussed in 40 CFR 761.360, Subpart S and referenced in 40 CFR

761.79 (c)(2)(ii).

Dispose all excavated soil at a Subtitle D landfill7.

Note: Available sample results are considered as representative of the soils to be disposed. Results indicate PFAS concentrations are below RSLs and PCBs are below 50 ppm. Waste characterization data showed soils meet Subtitle D landfill disposal criteria.

Therefore, all of the soil is to be disposed at a Subtitle D landfill.

Unanticipa ted Contamin ated Soils

(SUN)

Any soil showing visible, olfactory, or other indications of contamination (e.g., discoloration, staining or odors).

Soil must be segregated, stockpiled3, and tested in accordance with Sampling and Analysis Plan.

Must not be reused on site if free product5,9 encountered or if sampling results indicate any contaminants above RSLs (or MTCA

If free product is present, soil must be disposed of off-site in accordance with

ICP5,9.

If no free product and if sampling results indicate no other contaminants (other than PCBs or PFAS) are present above RSLs or MTCA thresholds, stockpile shall be classified as SMC1 (below LOQs), SMC2 (below RSLs), or SMC3 (above RSLs) and reused

SUN to be tested and analyzed in accordance with Appendix A Waste Characterization Sampling and Analysis Plan. Soil will be classified and managed in accordance with the identified criteria and procedures specified in the

EMMP.

Note: SUN discovered through the month of July 2024 includes soils encountered during

Soil Managem ent Class1

Preconstruct ion Sampling Results2

General Approach to Soil Reuse

General Approach to Soil Disposal (if required)

Selected Disposal Method

Method A thresholds for petroleum).

and/or disposed of accordingly, per above.

If PCBs or PFAS are not above RSLs, then soil may be reused on-site in accordance with Ecology’s reuse criteria6 or disposed of based on landfill acceptance criteria.

If any contaminant exceeds the applicable threshold for CERCLA waste, RCRA Hazardous Waste, or WA State Dangerous Waste, disposal at a Subtitle C hazardous waste landfill is required. EPA approval of disposal facility is required for CERCLA waste.

potholing activities within SMC-3 and Roadway Excavations within SMC1/SMC2 (see Figure A1-1). Soils were sampled and analyzed in accordance Appendix A Waste Characterization Sampling and Analysis Plan.

Results indicate PFAS concentrations are below RSLs and PCBs are below 50 ppm. Waste characterization data showed soils meet Subtitle D landfill disposal criteria.

Therefore, all of the soil is to be disposed at a Subtitle D landfill.

Acronyms: EPA = U.S. Environmental Protection Agency. LOQ = limits of quantification (see EMMP Table 4). ICP = Institutional Control Plan. MTCA – Model Toxics Control Act. PCBs = polychlorinated biphenyls. PFAS = polyfluoroalkyl substances. RSLs = EPA Regional Screening Levels (see EMMP Table 4). SMC = soil management classification. SUN = Unanticipated Contaminated Soils.

Notes:

1 See Figure A1-1 for map of project site showing where each SMC applies.

2 Laboratory LOQs and RSLs for PFAS and PCBs are detailed in EMMP Table 4. MTCA Method A thresholds for petroleum hydrocarbons refer to the Washington Department of Ecology August 2023 MTCA Method A thresholds (unrestricted land use) (https:/ecology.wa.gov/Regulations-Permits/Guidance-technical-assistance/Contamination-clean-up-tools/CLARC) of 2,000 mg/kg for diesel and heavy oil range petroleum hydrocarbons. Screening levels for other contaminants should be obtained from the latest available RSLs from EPA at the time of construction (or established in conjunction with the EPA RPM if no applicable RSL exists).

3 Soils from each SMC area must be stockpiled separately (or in separate roll-off bins) and managed in accordance with Section 5.8 of this EMMP to prevent stormwater runoff/run-on or any additional construction SWPPP requirements. If soils from two different SMCs are combined, all soil must be treated and disposed of in accordance with the more stringent SMC.

4 Stockpile sampling must be undertaken in accordance with procedures set forth in the Waste Characterization Sampling and Analysis Plan (Appendix A to this EMMP).

5 ICP states if free product is encountered, excavated soils shall be disposed of in an appropriate off-site landfill. If free product is not encountered, the soils may be returned to the original excavation, or very close to the original excavation in a substantially similar environment.

6 See EMMP Section 12 and Tables 12.1 and 12.2 of Ecology’s 2016 Guidance for Remediation of Petroleum Contaminated Sites, Toxics Cleanup Program Publication No. 10-09-057. https://apps.ecology.wa.gov/publications/documents/1009057.pdf 7 The selected Subtitle D landfill must have appropriate environmental controls such as bottom liner, leachate collection system, and gas collection and control system (see July 11, 2023, Memorandum for Assistant Secretaries of the Army, Navy, Air Force, and Defense Logistics Agency, and EPA’s Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances—Version 2 [April, 2024]).

8 Liners will be employed, after consultation with EPA, if and when a situation requires their usage.

9 Per October 1, 2024 EPA comments on the September 6, 2024 Revised Draft Addendum 1 EMMP, EPA views any wet, discolored, and/or stained soil with a light to strong odor of petroleum is viewed as having “free product”. See https://www.epa.gov/ust/ust-technical-compendium-release-investigation-confirmation-and-corrective-action

3.0 WATER MANAGEMENT

Table 5 of the EMMP describes the general approach to water disposal methods and provides a range of available disposal methods. However, the disposal methods identified in the table were either not viable or not fully viable as described below:

https://apps.ecology.wa.gov/publications/documents/1009057.pdf

(1) Release for on-site infiltration – this disposal method is of limited utility, particularly within WMC 3 area due to lack of permeable surface that would allow water to infiltrate at an acceptable rate. In addition, there is concern that surface infiltration in upgradient WMC1 area could have the effect of mobilizing existing contaminants in the downgradient area.

(2) Release to sanitary sewer – not viable at this time because the local utility district indicated that they did not have the capacity to receive the water.

(3) Disposed of offsite at a licensed wastewater treatment/disposal facility – not viable at this time due to cost.

Table 5 of the EMMP has been modified by adding a column (in RED) to identify the selected disposal method which includes a new option: discharge through the existing seawater outfall to surface water after treatment using an activated carbon filtration system to remove PFAS and petroleum hydrocarbons (see Table A1-2 below). Activated carbon filtration system is a proven technology in removing PFAS, petroleum hydrocarbons and other organic compounds.

NOAA requested and received approval from the USEPA to use the existing seawater outfall to discharge the treated water to Clam Bay without a National Pollutant Discharge Elimination System (NPDES) permit per Section 9621(e)(1) of CERCA where “No Federal, State, or local permit shall be required for the portion of any removal or remedial action conducted entirely onsite, where such remedial action is selected and carried out in compliance with this section”.

The location of the existing seawater outfall is annotated on Figure A1-2.

In a letter dated July 10, 2024, EPA documented this decision and provided the requirements for discharge of the treated water to Clam Bay (see Attachment A1). Per the letter, NOAA is required to sample and analyze the treatment effluent for PFAS on a monthly basis and to prepare a sampling and analysis plan that includes quality assurance/quality control requirements consistent with 40 CFR 136.7. To fulfill this requirement, NOAA prepared Appendix D PFAS Treatment Monitoring Sampling and Analysis Plan which is attached to the EMMP. Information about Clean Harbors’ PFAS treatment system referenced in EPA’s letter has since been updated. The most current information about the PFAS treatment system can be found in Attachment C-1 of the Appendix D.

Other substantive changes to the water management method are as follows:

(1) Dewatering water from the WMC1 area surrounding the pipeline segment between Building 9 and the east end of Building 6 (see Figure A1-2) are treated in the PFAS Treatment System because of the potential for groundwater contaminated with PFAS from the former simulator area to the south to be drawn into the finger area (see Figure A1-2). Treated water will be discharged through the existing Seawater Outfall.

(2) Dewater water from WMC1 area outside of the FFTA can be either (a) treated in the PFAS Treatment System before discharge through the existing Seawater Outfall, or (b) captured in a weir tank and tested to confirm surface water quality criteria is met before release through the existing Seawater Outfall. In addition, on a case–by-case basis, water can be released for on-site surface infiltration with prior approval from EPA.

(3) Unanticipated contaminated water (WUN) and decontaminated water (DECON) will be treated in the PFAS treatment system without testing as it is expected that the carbon filtration system will be effective in removing the contaminants that could be present in the water. As part of the PFAS treatment system monitoring program (Appendix D to the EMMP), the treated effluent will be tested on a monthly basis to evaluate the effectiveness of the treatment process.

(4) Due to its proximity to area with PFAS exceedance, dewater water from the pipeline segment at the northeast corner of the site north of B-15 will be treated in the PFAS treatment system even though the area is mapped as WMC2 (see Figure A1-2).

(5) The distribution pipelines between the Boring S18 and B-15 and south of Building 27 have been removed from the scope of the Seawater System Replacement project. No dewatering water will be generated in this area (see Figure A1-2).

Table A1-2 – Water Management Classifications Water Management Class1

Preconstruction Sampling Results

General Approach to Dewatering

General Approach to Disposal of Dewatering Water

Selected Disposal Method

WMC1 No contaminants detected above laboratory LOQs

Capture all dewatering water in a weir tank2.

May be either:

- treated in PFAS Treatment System before release through the existing Seawater Outfall;

- tested to confirm surface water quality criteria is met before release through the existing Seawater Outfall;

- with prior approval by EPA on a case-by-case basis, released for on-site infiltration through water treatment system set up for stormwater management in accordance with an EPA-approved construction SWPPP; or

- released to sanitary sewer (subject to discharge permit).

- Treated in PFAS Treatment System before release through the existing Seawater Outfall; or

- tested to confirm surface water quality criteria is met before release through the existing Seawater Outfall

Water from the “finger area” (pipeline segment east of Building 9) will be treated in the PFAS Treatment System because of the potential for groundwater contaminated with PFAS from area to the south to be drawn into the finger area (see Figure A1-2). Treated water discharged through the existing Seawater Outfall.

Water from Tie into Existing Raw Water Pipelines (around B-18) will also be treated due to SUN and WUN discovered in the area.

WMC2 One or more contaminants detected at levels above laboratory LOQs but below MCLs3

Capture all dewatering water in a weir tank2.

Must be either:

- treated in PFAS Treatment System before release through the existing Seawater Outfall; or

Treat in PFAS Treatment System before discharge to Clam Bay through the existing Seawater Outfall.

Water Management Class1

Preconstruction Sampling Results

General Approach to Dewatering

General Approach to Disposal of Dewatering Water

Selected Disposal Method

- with prior approval by EPA on a case-by-case basis, released for on-site infiltration in accordance with an EPA-approved construction SWPPP, within WMC2 areas as close as feasibly possible to the extraction location; or

- released to sanitary sewer (subject to discharge permit); or

- disposed of offsite at licensed wastewater treatment/disposal facility (subject to receiving facility & NOAA COR approval of waste profile).

WMC3 One or more contaminants at levels above MCLs3

Capture all dewatering water in a weir tank2.

Must be either:

- treated on-site to below MCLs3, then disposed of in same manner as WMC2; or

- disposed of offsite at a licensed wastewater treatment/disposal facility (subject to receiving facility & NOAA COR approval of waste profile).

Treat in PFAS Treatment System before discharge to Clam Bay through the existing Seawater Outfall

Unanticipated Contaminated Water (WUN)

Any dewatering water showing visible, olfactory, or other indications of contamination (e.g., petroleum/chemical sheen or odor).

Capture all dewatering water in a separate weir tank.

Based on sampling results, if PFAS are the only constituents of concern, may be reclassified as WMC1 (below LOQs), WMC2 (below MCLs3), or WMC3 (above MCLs3) and treated and/or disposed of accordingly, per above.

If other contaminants are present above RSLs or MTCA Method A cleanup levels or other applicable regulatory criteria, water shall be disposed of at an appropriate offsite

Capture in weir tank and treat in PFAS Treatment System before discharge to Clam Bay through the existing Seawater Outfall.

Water Management Class1

Preconstruction Sampling Results

General Approach to Dewatering

General Approach to Disposal of Dewatering Water

Selected Disposal Method facility (subject to NOAA COR approval).

EPA approval of disposal facility is required for any CERCLA wastes.

Decontamination Water (DECON)

Water or other liquid wastes used for cleaning and decontamination of equipment that has contacted SMC3 or SUN soils or WMC3 or WUN waters and resulting slurries.

Decontamination fluids must be captured in a weir tank.

May be either:

- treated in PFAS Treatment System before release through the existing Seawater Outfall; or

- tested to confirm surface water quality criteria is met before release through the existing Seawater Outfall.

Capture in weir tank and treat in PFAS Treatment System before discharge to Clam Bay through the existing Seawater Outfall.

Acronyms: CERCLA = Comprehensive Environmental Response, Compensation and Liability Act. EPA = U.S. Environmental Protection Agency. LOQ = limits of quantification (see EMMP Table 6). MCLs = Maximum Contaminant Levels (see EMMP Table 6).

NOAA COR = National Oceanic and Atmospheric Administration Contracting Officer Representative. PCBs = polychlorinated biphenyls. PFAS = polyfluoroalkyl substances. RSLs = EPA Regional Screening Levels (see EMMP Table 6). SWPPP = Stormwater Pollution Prevention Plan. WMC = water management classification. WUN = unanticipated contaminated water. DECON = decontamination water Notes:

1 See Figure A1-2 of this EMMP for map showing WMC areas within the project site.

2 Separate weir tanks must be used for each WMC. If water from two different WMCs is combined, all water must be treated and disposed of in accordance with the more stringent WMC.

3 For PFAS compounds where no MCL has been established, the RSL shall be used instead (see EMMP Table 6).

The Flowchart for Water Management included in the EMMP has been updated to be consistent with Table A1-2 and is presented below. The disposal methods considered as non-viable at this time (e.g., discharge to sanitary sewer or offsite disposal at licensed wastewater treatment/disposal facility) have been retained in the flowchart since they may become viable in the future depending on specific site conditions/circumstances.

Flow Chart for Water Management

STEP 1: Notify NOAA of groundwater intrusion/intent to dewater.

STEP 2: Observe water for signs of contamination.

Are there signs of contamination? Or is water from B-18 area?

NO

YES

STEP 3: Contain water and label based on WMC classification (Figure 5).

WMC1 (below LOQs) #

WMC3

(above MCLs*)

WUN

(unanticipated conditions)

WMC2

(below MCLs*)

Notes:

* For PFAS compounds without an established MCL, the 2023 EPA RSL shall be used, per EMMP Table 6.

# For WMC1 water from the “finger area” (pipeline segment east of Building 9), treatment in PFAS System and release via existing Seawater Outfall is required.

Acronyms:

LOQ = Limits of Quantification MCL = Maximum Contaminant Level MTCA = Model Toxics Control Act Method A Clean Up Levels PFAS = per- and polyfluorinated alkyl substances.

RSL = Regional Screening Level WMC = water management classification WUN = Unknown, Known, and Unanticipated Contamination.

DECON

(decontamination water)

Treat in PFAS Treatment System and released via existing Seawater Outfall

Or

Test to confirm surface water quality criteria are met before release via existing Seawater Outfall

Or

Release to Sanitary Sewer (subject to discharge permit)

Or

Release for on-site infiltration (only with EPA approval on case-by-case basis)

Treat in PFAS Treatment System and released via existing Seawater Outfall

Or

Test to confirm surface water quality criteria are met before release via existing Seawater Outfall

Or

Release to Sanitary Sewer (subject to discharge permit)

Or

Release for on-site infiltration within WMC 2 area (only with EPA approval on case-by-case basis)

Or

Create waste profile & transport to Offsite Treatment or Disposal Facility (subject to NOAA & EPA approval)

Treat in PFAS Treatment System and released via existing Seawater Outfall

Or

Create waste profile & transport to Offsite Treatment or Disposal Facility (subject to NOAA & EPA approval).

Or

Test to confirm PFAS is below MCLs and re-classified as

WMC2

Test to confirm COCs. If only PFAS, reclassify as WMC1, WMC2 or WMC3

If non-PFAS COCs are present above RSLs or MTCA Method A cleanup levels or other applicable regulatory criteria, create waste profile and transport to appropriate offsite facility (subject to

NOAA COR

approval)

Treat in PFAS Treatment System and released via existing Seawater Outfall

Or

Test to confirm surface water quality criteria are met before release via existing Seawater Outfall

Or

Test to confirm PFAS is below MCLs and re-classified as

WMC2

STEP 3: Contain water and label as

WUN

Clam Bay

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG 6

FORMER

LANDFILL

AREA

DISTRIBUTION

VALVE MANIFOLD

Beaver Creek

Tributary

T o B e a c h D r iv e E a s t

T

O

E

P

A

M a n c h e s t e r

E n v i r o n m e n t l

L b o r a t o r y

MANCHESTER

STATE PARK

FILTER/UV

SYSTEM

TIE INTO EXISTING RAW

WATER PIPELINES

TREATED WATER

PIPELINES AND

UTILITY LINES

RAW WATER

PIPELINES

EXISTING OUTFALL

TO BE RETAINED

TIE INTO EXISTING

OUTFALL

2-1

2-2

2-3

2-4

2-5

2-6

2-7

2-8

2-9

NT-02

NT-01

NT-03

NT-04

NT-05

NT-06

NT-07

NT-08

NT-09

NT-10

S16 S17

S19

S18

S22

S24

S21

S20

S25

S26

S28

S29

S27

S30

B-5f

B-4c

B-4d

B-4e

B-4g

B-6

B-15

B-18

B-19

B-13

B-14

B-7

B-10

B-1b

B-1c

B-1d

B-1e

B-1f

B-1g

B-2a

B-2e

B-2f

B-2g

B-3a

B-3c

B-3e B-3f

B-3g

B-4f

B-4a

B-4b

B-5a

B-5b

B-5c

B-5d

B-5e

B-5g

B-1a

B-2b

B-2c

B-2d

B-3b

B-3d

B-17

B-12

B-11

B-16

B-8

B-9

S23

S14

S13

S15

S8

S10

S12

S9

S7

S11

S3

S1

S4

S6

S2

S5

LEGEND

NOAA PRE-CONSTRUCTION COMPOSITE

BORING LOCATION (Jan 2024)

NOAA PRE-CONSTRUCTION DISCRETE SOIL

BORING LOCATION (Jan 2024)

USACE PFAS & PCB SAMPLING LOCATION

(Oct 2023)

USACE PFAS SAMPLING LOCATION (2022)

USACE PCB SAMPLE LOCATIONS (Oct 2023)

USACE PCB SAMPLE LOCATION (2020)

PROPERTY BOUNDARY

PROPOSED ACTION COMPONENTS

FORMER FIRE TRAINING AREA

STREAM/CREEK

SOIL MANAGEMENT CLASSIFICATION AREAS

NOAA NWFSC MANCHESTER RESEARCH STATION SEAWATER SYSTEM REPLACEMENT AND

CAMPUS ADDITION PROJECT - ENVIRONMENTAL MEDIA MANAGEMENT PLAN

MANCHESTER, WASHINGTON

FIGURE A1-1

APRIL 2024

60703568

EXISTING BUILDINGS KEY

1 - MAIN BUILDING

2 - MAIN BUILDING

3 - MAIN BUILDING

4 - NAVY ANNEX I

5 - NAVY ANNEX II

6 - PATHOLOGY LAB

8 - WAREHOUSE

9 - EMERGENCY POWER GENERATOR

11 - FISH REARING

12 - SALTWATER MARINE LAB

13 - BPA

14 - FISH BEHAVIOR LAB

21 - KENNETH CHEW CENTER

22 - NOOKSACK

24 - STORAGE & KELP LAB

25 - BEHAVIOR ECOLOGY - COVERED TANKS

27 - ALBALONE AND SEA CUCUMBER NURSERY

B-1a

B-6

PCB AND PFAS SOIL SAMPLING RESULTS

ONE OR MORE PCB COMPOUNDS DETECTED

ABOVE APPLICABLE RSL

ONE OR MORE PCB COMPOUNDS DETECTED

ABOVE LOQ BUT BELOW RSL

ONE OR MORE PFAS COMPOUNDS DETECTED

ABOVE LOQ BUT BELOW RSL

NO PCB OR PFAS COMPOUNDS DETECTED

ABOVE TARGET LOQ

NO PFAS COMPOUNDS DETECTED ABOVE

TARGET LOQ (PCBs NOT ANALYZED)

SOIL SAMPLE NOT COLLECTED

S22

NT-01

2-1

SOIL MANAGEMENT CLASSIFICATIONS (SMCs)

SMC1 - NO PCBs OR PFAS ABOVE TARGET

LOQs

SMC2 - ONE OR MORE PCBs OR PFAS ABOVE

TARGET LOQs BUT BELOW RSLs

SMC3 - ONE OR MORE PCBs OR PFAS AT

LEVELS ABOVE RSLs

SEE ENVIRONMENTAL MEDIA MANAGEMENT PLAN FOR SOIL

HANDLING AND DISPOSAL REQUIREMENTS FOR EACH SMC

S1

DRAWING SOURCE: HDR.

IMAGERY SOURCE: ESRI, DIGITALGLOBE, GEOEYE, EARTHSTAR GEOGRAPHICS, CNES/AIRBUS DS, USGS, AEROGRID, IGN, AND THE GIS USER COMMUNITY.

Rachel.Chang Polygon

Rachel.Chang Callout Campus Addition Office/Lab Building Footprint

Rachel.Chang Polygon Due to potential for drawing contaminated water from adjacent WMC3 area into the excavation trench during construction activities, water from this area will be treated in the PFAS Treatment System prior to release.

Rachel.Chang Callout Petroleum impacted soil encountered during Roadway Excavation.

Rachel.Chang Callout Former Northern Simulator Foundation

RKoonce Oval

RKoonce Oval

RKoonce Oval

RKoonce Oval

RKoonce Oval

Rachel.Chang Typewritten Text Potholing Locations with Petroleum Impacted Soil

Rachel.Chang Rectangle

Rachel.Chang Rectangle

Clam Bay

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG

BLDG 6

BLDG B

FORMER

LANDFILL

AREA

DISTRIBUTION

VALVE MANIFOLD

Beaver Creek

Tributary

To Beach Drive East

TO EPA M

anch este r

Envir onmental L aboratory

MANCHESTER

STATE PARK

FILTER/UV

SYSTEM

TIE INTO EXISTING RAW

WATER PIPELINES

TREATED WATER

PIPELINES AND

UTILITY LINES

RAW WATER

PIPELINES

EXISTING OUTFALL

TO BE RETAINED

TIE INTO EXISTING

OUTFALL

S16 S17

S19

S18

S22

S24 S21

S20

S25

S26

S28S29

S27

S30

B-5f

B-4c B-4d

B-4e

B-4g

B-6

B-15 B-18

B-19

B-13

B-14

B-7 B-10

B-1b

B-1c

B-1d

B-1e

B-1f

B-1g

B-2a

B-2e

B-2f

B-2g

B-3a B-3c

B-3e B-3f B-3g

B-4f

B-4aB-4b

B-5a

B-5b B-5c

B-5d

B-5e B-5g

B-1a B-2b

B-2c B-2d

B-3b B-3d

B-17

B-12

B-11

B-16

B-8 B-9

S23

S14

S13

S15

S8

S10

S12

S9 S7

S11

S3S1

S4

S6

S2

S5

LEGEND

NOAA PRE-CONSTRUCTION COMPOSITE

BORING LOCATION (Jan 2024)

NOAA PRE-CONSTRUCTION DISCRETE SOIL

BORING LOCATION (Jan 2024)

USACE PFAS & PCB SAMPLING LOCATION

(Oct 2023)

USACE PFAS SAMPLING LOCATION (2022)

PROPERTY BOUNDARY

PROPOSED ACTION COMPONENTS

FORMER FIRE TRAINING AREA

STREAM/CREEK

WATER MANAGEMENT CLASSIFICATION AREAS

NOAA NWFSC MANCHESTER RESEARCH STATION SEAWATER SYSTEM REPLACEMENT AND

CAMPUS ADDITION PROJECT - ENVIRONMENTAL MEDIA MANAGEMENT PLAN

MANCHESTER, WASHINGTON

FIGURE A1-2

APRIL 2024

60703568

B-1a

B-6

PFAS GROUNDWATER SAMPLING RESULTS

ONE OR MORE PFAS COMPOUNDS DETECTED

ABOVE APPLICABLE RSLs AND/OR MCLs

ONE OR MORE PFAS COMPOUNDS DETECTED

ABOVE APPLICABLE LOQ BUT BELOW RSLs AND/OR MCLs

NO PFAS COMPOUNDS DETECTED ABOVE TARGET

LOQ

GROUNDWATER SAMPLE NOT COLLECTED

S1

S22

EXISTING BUILDINGS KEY

1 - MAIN BUILDING

2 - MAIN BUILDING

3 - MAIN BUILDING

4 - NAVY ANNEX I

5 - NAVY ANNEX II

6 - PATHOLOGY LAB

8 - WAREHOUSE

9 - EMERGENCY POWER GENERATOR

11 - FISH REARING

12 - SALTWATER MARINE LAB

13 - BPA

14 - FISH BEHAVIOR LAB

21 - KENNETH CHEW CENTER

22 - NOOKSACK

24 - STORAGE & KELP LAB

25 - BEHAVIOR ECOLOGY - COVERED TANKS

27 - ALBALONE AND SEA CUCUMBER NURSERY

WATER MANAGEMENT CLASSIFICATIONS (WMCs)

WMC1 - NO PFAS ABOVE TARGET LOQs

WMC2 - ONE OR MORE CONTAMINANTS

ABOVE TARGET LOQs BUT BELOW RSLs AND/OR MCLs

WMC3 - ONE OR MORE PFAS ABOVE RSLs AND/OR MCLs

SEE ENVIRONMENTAL MEDIA MANAGEMENT PLAN FOR WATER

HANDLING AND DISPOSAL REQUIREMENTS FOR EACH WMC

DRAWING SOURCE: HDR.

IMAGERY SOURCE: ESRI, DIGITALGLOBE, GEOEYE, EARTHSTAR GEOGRAPHICS, CNES/AIRBUS DS, USGS, AEROGRID, IGN, AND THE GIS USER COMMUNITY.

PFAS Plum

Rachel.Chang Typewritten Text

BLDG

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Rachel.Chang Typewritten Text 15C

Rachel.Chang Typewritten Text 15A 10

Rachel.Chang Typewritten Text 15B

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Rachel.Chang Polygon Due to potential for drawing contaminated water from adjacent WMC3 area into the excavation trench during construction activities, water from this area will be treated in the PFAS Treatment System prior to release.

Rachel.Chang Callout Treat dewatering water in PFAS Treatment System

Rachel.Chang Polygon Due to potential for drawing contaminated water from adjacent WMC3 area into the excavation trench during construction activities, water from this area will be treated in the PFAS Treatment System prior to release.

Rachel.Chang Callout Petroleum impacted soil encountered during Roadway Excavation. Treat dewatering water in PFAS Treatment System

Rachel.Chang Callout Treated effluent discharge location

Rachel.Chang Callout These distribution pipelines have been removed from the scope of the project - existing pipelines to be utalized.

Rachel.Chang Polygonal Line

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Rachel.Chang Callout Treat dewatering water in PFAS Treatment System

Rachel.Chang Callout PFAS Treatment System

Rachel.Chang Line

Rachel.Chang Polygonal Line

Rachel.Chang Polygonal Line

Rachel.Chang Callout Transition to aboveground

Rachel.Chang Callout Campus Addition Office/Lab Building Footprint

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Rachel.Chang Rectangle

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Rachel.Chang Callout Former Northern Simulator Foundation

Attachment A1 EPA July 10, 2024 Letter

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suite 155

Seattle, WA 98101

SUPERFUND &

EMERGENCY

MANAGEMENT DIVISION

July 10, 2024

Rachel Chang, PE Environmental Engineer Safety and Environmental Compliance Office National Oceanic & Atmospheric Administration 7600 Sand Point Way NE Seattle, WA 98115-6349

Re: Requirements for discharge of treated PFAS-impacted groundwater/PFAS-impacted groundwater mixed surface water to Clam Bay resulting from the NOAA Seawater Expansion Project at the Manchester Marine Research Station, Manchester, WA

Ms. Chang, EPA is providing the following requirements for discharge of treated PFAS-contaminated groundwater and PFAS-contaminated groundwater with mixed surface water to Clam Bay via the Clean Harbor PTS-660 PFAS Water Treatment System as identified in Attachment 1.

While an established concentration limit for treated PFAS-impacted water discharged to Clam Bay is not mandated, a detectable discharge of PFAS to surface water may necessitate the need to evaluate near shore sediments and biota for potential PFAS exposures in the future.

Given that the NOAA MRS is located on a former Navy firefighting training area (FFTA) and within the Manchester Annex Superfund Site boundaries, precautions must be taken to prevent the transport of the known site contaminants (Table 1 Manchester Annex Superfund Site Record of Decision, Table 15) within or off the site boundaries.

1. Chemicals of Concern Selected Cleanup Levels

Table 1: Manchester Annex Superfund Site Record of Decision, Table 15

Contaminant Name Anticipated Source Location Record of Decision Cleanup Level FFTA Landfill

Copper X X 10.6 µg/L Nickel X X 7.9 µg/L Zinc --- X 77 µg/L PCBs X X 0.03 µg/L

2,3,7,8- Tetrachlorodibenzo-p-Dioxin

(TCDD)

X --- *

Total Petroleum Hydrocarbons (TPH) X X *

* The cleanup levels listed in the Record Of Decision for TCDD and TPH are soil based concentrations.

2. Discharge Monitoring for PFAS

NOAA and its contractors must, upon initiating discharge of treated PFAS-impacted water to Clam Bay, sample and analyze monthly the effluent of the Clean Harbor PTS-660 PFAS Water Treatment System for PFAS on a monthly periodicity. Additional samples and analysis between vessels is encouraged as to provide advanced notification of breakthrough, should it occur.

Table 2 - PFAS Monitoring Requirements

Parameter

Monitoring Requirements

Sample Location

Sample Frequency Sample Type

Per-and Polyfluoroalkyl Substances (PFAS) (ng/L) Effluent Monthly Grab

2.1. Analytical Method

Prior to approval of analytical methods for PFAS chemicals under 40 CFR § 136, NOAA and its contractors must use the latest version of EPA Method 1633. After analytical methods for PFAS chemicals are approved under 40 CFR § 136, NOAA and its contractors may use any sufficiently sensitive approved analytical method. The PFAS chemicals that must be analyzed are listed in Table 2.1.

Table 2.1 - PFAS Chemicals to be Analyzed

Target Analyte Name Abbreviation CAS Number Perfluoroalkyl carboxylic acids

Perfluorobutanoic acid PFBA 375-22-4 Perfluoropentanoic acid PFPeA 2706-90-3 Perfluorohexanoic acid PFHxA 307-24-4 Perfluoroheptanoic acid PFHpA 375-85-9 Perfluorooctanoic acid PFOA 335-67-1 Perfluorononanoic acid PFNA 375-95-1 Perfluorodecanoic acid PFDA 335-76-2 Perfluoroundecanoic acid PFUnA 2058-94-8 Perfluorododecanoic acid PFDoA 307-55-1 Perfluorotridecanoic acid PFTrDA 72629-94-8 Perfluorotetradecanoic acid PFTeDA 376-06-7

Perfluoroalkyl sulfonic acids Acid Form

Perfluorobutanesulfonic acid PFBS 375-73-5 Perfluoropentansulfonic acid PFPeS 2706-91-4

Table 2.1 - PFAS Chemicals to be Analyzed

Target Analyte Name Abbreviation CAS Number Perfluorohexanesulfonic acid PFHxS 355-46-4 Perfluoroheptanesulfonic acid PFHpS 375-92-8 Perfluorooctanesulfonic acid PFOS 1763-23-1 Perfluorononanesulfonic acid PFNS 68259-12-1 Perfluorodecanesulfonic acid PFDS 335-77-3 Perfluorododecanesulfonic acid PFDoS 79780-39-5

Fluorotelomer sulfonic acids 1H,1H, 2H, 2H-Perfluorohexane sulfonic acid

4:2FTS 757124-72-4

1H,1H, 2H, 2H-Perfluorooctane sulfonic acid

6:2FTS 27619-97-2

1H,1H, 2H, 2H-Perfluorodecane sulfonic acid

8:2FTS 39108-34-4

Perfluorooctane sulfonamides Perfluorooctanesulfonamide PFOSA 754-91-6 N-methyl perfluorooctanesulfonamide NMeFOSA 31506-32-8 N-ethyl perfluorooctanesulfonamide NEtFOSA 4151-50-2

Perfluorooctane sulfonamidoacetic acids N-methyl perfluorooctanesulfonamidoacetic acid

NMeFOSAA 2355-31-9

N-ethyl perfluorooctanesulfonamidoacetic acid

NEtFOSAA 2991-50-6

Perfluorooctane sulfonamide ethanols N-methyl perfluorooctanesulfonamidoethanol

NMeFOSE 24448-09-7

N-ethyl perfluorooctanesulfonamidoethanol

NEtFOSE 1691-99-2

Per- and Polyfluoroether carboxylic acids Hexafluoropropylene oxide dimer acid HFPO-DA 13252-13-6 4,8-Dioxa-3H-perfluorononanoic acid ADONA 919005-14-4 Perfluoro-3-methoxypropanoic acid PFMPA 377-73-1 Perfluoro-4-methoxybutanoic acid PFMBA 863090-89-5 Nonafluoro-3,6-dioxaheptanoic acid NFDHA 151772-58-6

Ether sulfonic acids 9-Chlorohexadecafluoro-3-oxanonane-1-sulfonic acid

9Cl-PF3ONS 756426-58-1

11-Chloroeicosafluoro-3-oxaundecane-1-sulfonic acid

11Cl-PF3OUdS 763051-92-9

Perfluoro(2-ethoxyethane)sulfonic acid PFEESA 113507-82-7 Fluorotelomer carboxylic acids

3-Perfluoropropyl propanoic acid 3:3FTCA 356-02-5 2H,2H,3H,3H-Perfluorooctanoic acid 5:3FTCA 914637-49-3

Table 2.1 - PFAS Chemicals to be Analyzed

Target Analyte Name Abbreviation CAS Number 3-Perfluoroheptyl propanoic acid 7:3FTCA 812-70-4

2.2 Minimum Levels

NOAA and its contractors must achieve minimum levels no greater than those listed in Table 6 of EPA Method 1633, Acceptance Limits for EIS and NIS Compounds in All Aqueous Matrices and Associated QC Samples.

2.3 Quality Assurance

QA/QC procedures for PFAS sampling and analysis consistent with 40 CFR 136.7 must be documented in the revised Environmental Media Management Plan (EMMP) or newly created Effluent Water Monitoring Plan (EWMP) and Project Sampling and Analysis Plan (PSAP). See Section 3 (Quality Assurance Requirements).

2.4 Monitoring Schedule

NOAA and its contractors must sample at least monthly at the PTS-660 PFAS Water Treatment System effluent location. If, after 8 consecutive calendar months of monitoring, all results for the effluent are non-detect for all PFAS analytes listed in Table 1 of EPA Method 1633, NOAA and its contractors may discontinue PFAS monitoring at the effluent location for the remainder of the treatment operations. No later than 30 days after the completion of the water treatment activities and/or at the end of the calendar year, NOAA and its contractors must submit a summary monitoring report documenting all data collection to date.

3. Quality Assurance Requirements

NOAA and its contractors are required to provide, for EPA and USACE review, an EWMP and PSAP for all monitoring required in Section 2. The EWMP and PSAP will include, at a minimum, the items list below in Section 3.1 Plan Content. However, the existing EMMP may be modified to include, at a minimum, the items list below in Section 3.1 Plan Content as an alternative to developing the EWMP and PSAP. The EWMP/PSAP or revised EMMP will be hereby referred to as the Plan for the purposes of the monitoring the discharge of treated PFAS-impacted water from the NOAA project site.

3.1 Plan Content

The Plan must be designed for the collection and analysis of effluent water quality samples in support of the monitoring requirements, and in explaining data anomalies when they occur.

At a minimum, the plan must reflect the content specified in Subsection 3.1.5 Plan Procedures, and include, but not limited to, the following information:

3.1.1 Details on the number of samples, type of sample containers, preservation of samples, holding times, analytical methods, analytical detection and quantitation limits for each target compound, type and number of quality assurance field samples, precision and accuracy requirements, sample preparation requirements, sample shipping methods, and laboratory data delivery requirements;

3.1.2 Diagram(s) indicating the location(s) of the sampling point(s);

3.1.3 Qualification and training of sampling and monitoring personnel; and

3.1.4 Name(s), address(es), and telephone number(s) of the laboratories, used by or proposed to be used by NOAA and its contractors.

3.1.5 Plan Procedures: Throughout all sample collection and analysis activities, NOAA and its contractors must use EPA-approved QA/QC and chain-of-custody procedures described in the following documents:

• Quality Assurance Project Plan Standard (dated July 18, 2023, Directive No: CIO 2105-S-02.0) and Guidance for Quality Assurance Project Plans (EPA/QA/G-5).

Copies of these documents can be found at https://www.epa.gov/quality/quality-program-directives#guide, and

• Guidelines for Preparing Quality Assurance Project Plans for Environmental Studies, July 2004, Washington Department of Ecology Publication No. 04-03-030.

3.1.6 Plan Updates and Availability: NOAA must amend the Plan whenever there is a modification in sample collection, sample analysis, or other procedure addressed by the two referenced QAPP documents above.

4.0 Discharge of effluent

NOAA and its contractors must ensure that the added water volume to the existing seawater system discharge point does not exacerbate erosion of the intertidal sediments or shoreline embankments.

NOAA and its contractors will make note the condition of the existing seawater system discharge point and surrounding sediments and embankment conditions prior to initiating PFAS-impacted water treatment. While the treatment system is operational, a daily inspection must be conducted at the existing seawater system discharge point. Any noted disturbance of sediment or embankment soils in the immediate vicinity must be identified to the EPA Remedial Project Manager and USACE Site Manager immediately.

5.0 Treatment System Initiation

NOAA and its contractors must ensure that both the EPA Remedial Project Manager and USACE Site Manager are notified at least 7 days prior to the initiation of the treatment system. This will allow for the scheduling of a site visit and operational viewing of the treatment system, should the respective manager desire.

6.0 Additional Requirements

Ensure that NOAA and its contractors comply with Chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington.

The requirements listed above are the current substantive requirements for an NPDES permit associated with PFAS discharge. In the event that PFAS discharge concentration limits are developed and codified prior to the completion of the NOAA Seawater Expansion Project, this permit will require revision prior to those limits becoming enforceable.

https://www.epa.gov/quality/quality-program-directives#guide https://www.epa.gov/quality/quality-program-directives#guide

Please feel free to reach out to me at (206) 553-6295, or via email at hickey.patrick@epa.gov, if you’ve questions or concerns about the requirements listed above.

Sincerely, Patrick Hickey, EPA Remedial Project Manager

Attachment: Clean Harbor PTS-660 PFAS Water Treatment System Description

[See Attachment C-1 of Appendix D for updated Clean Harbor PTS-660 PFAS Water Treatment System Description] mailto:hickey.patrick@epa.gov