J.5_REVISED FINAL_EMMP (February 2025).pdf

REVISED FINAL

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

Prepared for:

National Oceanic and Atmospheric Administration National Marine Fisheries Service Northwest Fisheries Science Center

Prepared by:

AECOM Technical Services Inc

February 2025

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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose

2.0 BACKGROUND

2.1 Site Description

2.2 Geological Information

2.3 Operational History

2.4 Previous Environmental Investigations

2.5 Previous Remedial Actions

2.6 Former Landfill (northeast of MRS Property)

2.7 Former Fire Training Area (east side of MRS Property)

2.8 Institutional Controls

3.0 SUMMARY OF CONTAMINANTS AND AREAS OF POTENTIAL CONCERN

3.1 Former Fire Training Area

3.2 West Portion of MRS Property

4.0 CONTRACTOR HEALTH AND SAFETY

4.1 Health and Safety Plan

5.0 SOIL MANAGEMENT

5.1 Responsible Personnel

5.2 Soil Management Classification and Methods of Classification

5.3 Soil Excavation Observation and Monitoring

5.4 Exclusion Zone and Decontamination

5.5 Soil Excavation and Loading

5.6 Control of Excess Project Site Soil

5.7 On-Site Reuse of Excavated Soil

5.8 Temporary Soil Storage

5.9 Off-Site Disposal of Excess Soil

5.10 Off-Site Transportation of Soil and Other Wastes

5.11 Known, Unanticipated and Unknown Contaminated Soil Management

5.12 Soil Management during Potholing Activities

6.0 WATER MANAGEMENT

6.1 Introduction

6.2 Water Management Classification

6.3 Dewatering Process

6.4 Known, Unanticipated and Unknown Contaminated Water Management

7.0 STORMWATER MANAGEMENT

8.0 CONTINGENCY WORK PLANS

8.1 Contingency UST Removal Plan

8.2 Contingency Asbestos Handling Plan

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9.0 KEY CONTACT DETAILS

10.0 PROJECT SCHEDULE

11.0 CLOSURE REPORTING

12.0 REFERENCES

FIGURES

APPENDICES

TABLES

Table 1 – Maximum Detected Concentrations in Former Fire Training Area Soil

Table 2 – Maximum Detected Concentrations in Former Fire Training Area Groundwater

Table 3 – Soil Management Classifications

Table 4 – Limits of Quantification and Regional Screening Levels – Soil

Table 5 – Water Management Classifications

Table 6 – Limits of Quantification and Screening Criteria – Groundwater

Table 7 – Key Contacts

FIGURES

Figure 1 – Site Location and Project Area

Figure 2 – Site Vicinity Map

Figure 3 – Site Plan Previous Remediation and Sampling Locations

Figure 4 – Concentrations of Total PCBs in Inland Soil Samples Collected by USACE

Figure 5 - Soil Management Classification Areas

Figure 6 - Groundwater Management Classification Areas

Figure 7 – PFAS Distribution in Soil at the Former Fire Training Area

Figure 8 - PFAS Distribution in Groundwater at the Former Fire Training Area

APPENDICES

Appendix A Waste Characterization Sampling and Analysis Plan

Appendix B Contingency Underground Storage Tank Removal Plan

Appendix C Contingency Asbestos Handling Plan

Appendix D PFAS Treatment System Monitoring Sampling and Analysis Plan iii

ACRONYMS AND ABBREVIATIONS

µg/kg micrograms per kilogram AECOM AECOM Technical Services, Inc.

ASD Assistant Secretary of Defense bgs below ground surface BMPs best management practices CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC contaminants of concern COR Contracting Officer’s Representative Ecology Washington State Department of Ecology EMMP Environmental Media Management Plan EPA United States Environmental Protection Agency EZ exclusion zone HASP health and safety plan HAZWOPER Hazardous Waste Operation & Emergency Response ICP Institutional Control Plan ID Identification mil one thousandth of an inch MRS Manchester Research Station NAVD88 North American Vertical Datum of 1988 Navy U.S. Navy NOAA National Oceanic and Atmospheric Administration NWFSC Northwest Fisheries Science Center PCBs polychlorinated biphenyls PFAS per- and polyfluorinated alkyl substances PFHxS perfluorohexane sulfonate PFNA perfluorononanoic acid PFOA perfluorooctanoic acid PFOS perfluorooctane sulfonate PID photoionization detector ppm parts per million project Manchester Research Station Seawater System and Campus Addition Project RCRA Resource Conservation and Recovery Act RI/FS remedial investigation/feasibility study ROD Record of Decision RPM Remedial Project Manager SMC Soil Management Classification Superfund Comprehensive Environmental Response, Compensation, and Liability Act SWPPP Stormwater Pollution Prevention Plan TPH Total petroleum hydrocarbon iv

USACE United States Army Corps of Engineers UST underground storage tanks WDEC Potentially Contaminated Decontamination Water WMC Water Management Classification WUN Potentially Contaminated Water

1.0 INTRODUCTION

This Environmental Media Management Plan (EMMP) has been prepared by AECOM Technical Services, Inc. (AECOM) on behalf of the National Oceanic and Atmospheric Administration (NOAA) for the Northwest Fisheries Science Center (NWFSC) Manchester Research Station (MRS) located at 7305 Beach Drive East in Port Orchard, Kitsap County, Washington (the MRS Property, Figure 1 and Figure 2. NOAA plans to construct a replacement seawater system and up to four new buildings on the MRS Property as part of the MRS Seawater System and Campus Addition Project (project). A preliminary design site plan for the proposed MRS Property improvements is provided on Figure 3.

The entirety of the MRS Property is located within the southern part of the US Environmental Protection Agency (EPA) Old Navy Dump/Manchester Superfund Site (EPA Identification [ID] Number WA 8680030931). The media management activities outlined in this EMMP are consistent with the requirements stipulated in the Record of Decision (ROD) issued by the EPA and the US Army Corps of Engineers (USACE), with concurrence from the Washington State Department of Ecology (Ecology) in 1997 (Hart Crowser 1997) and the Institutional Control Plan (ICP), created jointly by the USACE, EPA, and NOAA in 2012 (USACE et al 2012). In addition, NOAA held a series of meetings with the EPA and USACE between October 2023 and March 2024 to develop this plan. The EMMP received final approval from EPA on April 17, 2024 (AECOM 2024a). Subsequent to its approval, NOAA received additional comments from EPA in November of 2024 on the Final EMMP as well as comments on the appendix material (e.g., Appendix A Waste Characterization Sampling and Analysis Plan) that were pertinent to the EMMP. These additional comments have been addressed in this Revised Final EMMP.

1.1 Purpose

The purpose of this EMMP is to provide site-specific procedures to be employed by NOAA and its construction contractor(s) to manage potential contaminated soils, water (including groundwater, contaminated stormwater, and decontamination water), and remnant site features that may be encountered during excavation activities performed for the proposed seawater system and campus addition project on the MRS Property. This EMMP has been designed to facilitate the proper management of contaminated media in a manner that is protective of human health and the environment and does not exacerbate existing environmental conditions.

Per Section 1.5 of 01 57 19 Temporary Environmental Controls of the Technical Specification, 100% Construction Documents, the Contractor must comply with the requirements specified in this document.

The EMMP includes:

A description of the type and magnitude of contaminants of concern (COC) detected in soil and groundwater samples previously collected at MRS Property;

Procedures for the management of known contaminated soil and water that may be encountered during construction activities (Sections 5 and 6);

Waste characterization sampling procedures and proposed analytical program (Appendix A);

Procedures for the management of unanticipated and/or unknown: soil contamination, underground storage tanks (UST [Appendix B]), and asbestos-clad piping (Appendix C), should any be encountered during construction activities;

PFAS Treatment System Monitoring Sampling and Analysis Plan (Appendix D) for sampling of treated effluent prior to discharge; and

Measures to control the off-site migration of contaminated soil via erosion and/or track-off project site during construction and media handling activities (with references to the Stormwater Pollution Prevention Plan [SWPPP] that will be prepared by the contractor and approved by the EPA Region 10 as part of the Construction General Permit for the project, prior to the start of construction).

The scope of this EMMP is applicable to the construction activities performed during the seawater system and campus addition project on the MRS Property (Figure 3). This EMMP does not cover other ground disturbing activities that may be conducted for environmental investigations or remedial activities on the MRS Property or the adjacent properties. This EMMP assumes that NOAA’s construction contractor will only excavate and remove soil from the MRS Property to the extent necessary to complete the seawater system and campus addition project and that no additional excavation would be performed by the construction contractor for the purpose of delineating or removing any contamination identified during the construction, unless authorized by NOAA.

There is no warranty by AECOM or NOAA, expressed or implied, that the information or data obtained from any source referenced in this EMMP is indicative of all subsurface conditions that may be encountered during the seawater system and campus addition project on the MRS Property.

If construction activities encounter chemical contamination significantly different than that identified in the EMMP or any other materials suspected of posing a threat to human health and the environment, the construction contractor should take the following actions:

Immediately cease all work activities in and around any area of the project where contamination has been encountered or discovered, notify NOAA’s Contracting Officer’s Representative (COR) and/or their designee, and take appropriate measures in compliance with all applicable environmental laws to stop or minimize the immediate spread or release of any contamination.

Immediately implement appropriate control measures in the affected area to prevent rain or stormwater runoff from contacting the suspected contamination, in a manner that does not spread or mobilize the suspected contamination in conformance with the project’s approved

SWPPP.

Addendums to the EMMP may be prepared to document the clarifications, updates, and adjustments needed as a result of newly discovered or changed site conditions. The addendums are to be submitted to EPA for review and concurrence. The addendums must be consulted in conjunction with the EMMP during construction.

2.0 BACKGROUND

2.1 Site Description

The MRS Property is the southern 22.5-acre portion of the 31-acre Manchester Annex on the western shore of Clam Bay in Puget Sound in unincorporated Kitsap County at 7305 Beach Drive East, Manchester, Washington, 98353 (Figure 1). The Annex is within Section 16, Township 24 North, Range 02 East, Willamette Principal Meridian, Washington. The Annex is owned by the US federal government, with EPA and the US Department of Commerce NOAA as holding agencies. The northern portion of the Annex (adjacent to the northeast of the MRS Property) is currently occupied by EPA and Ecology’s Manchester Environmental Laboratory campus (Figure 2).

The southeastern portion of the MRS Property is developed with various buildings, laboratories, parking and hardscaping areas and landscaping (Figure 3). The northwestern portion of the MRS property is heavily vegetated with limited structures. The adjacent property to the south is owned by the U.S. Navy (Navy), which leases two buildings (Buildings 4 and 5) to the MRS.

The existing MRS facilities are located on a relatively flat section of land ranging in elevation from 13 to 18 feet North American Vertical Datum of 1988 (NAVD88). The forested upland areas to the north and west of the developed portions of the site range in elevation from approximately 20 to 68 feet NAVD88. The western property boundary is bordered by Clam Bay and a small creek (Beaver Creek) is situated south of the MRS Property (Figure 2).

2.2 Geological Information

Published geological information indicates that the NOAA property is underlain by Quaternary aged glacial deposits and Holocene marine terrace deposits and Tertiary volcanic and marine sedimentary deposits (Yount et al 1993). Site-specific geotechnical investigations for a previous construction project at the MRS facility (Krazan and Associates 2011) identified 3 to 7 feet of topsoil underlain by loose silty sand with gravel fill. The fill is underlain by 14 to 18 feet of clayey silt glaciolacustrine deposits. Groundwater was not encountered during the 2011 geotechnical investigation, except perched groundwater that was noted at 3 to 4 feet below ground surface in one boring. Groundwater was encountered in the borings at depths of between 2 to 9 feet below ground surface during the 2021 USACE per- and polyfluorinated alkyl substances (PFAS) investigation, and as shallow as 0 feet below ground surface during the 2024 preconstruction sampling (AECOM 2024b). Groundwater is inferred to flow east toward Clam Bay.

2.3 Operational History

The Manchester Annex was formerly owned and operated by the Navy for submarine net maintenance, fire training, and waste disposal activities. The Former Fire Training Area, which comprises the easternmost portion of the NOAA property was reportedly used by the Navy from the 1940s to the early 1970s to train personnel to extinguish Naval vessel fires. Large concrete structures known as "simulators" were used to simulate ship compartments (USACE 2009), in which fires were started and then extinguished for training. Associated subsurface equipment included USTs for gasoline, diesel, and waste oil; vaults (e.g., valve boxes); fuel lines; and water lines. The fire training activities resulted in releases of hazardous materials and petroleum products. Constituents of concern associated with these operations include polychlorinated dioxins and furans (hereafter called dioxins/furans) and petroleum hydrocarbons (USACE 2019). The Navy fire fighting training area has been the focus of various hazardous materials investigations and remedial actions and is subject to Institutional Controls (described in more detail in Section 2.3 below). There is no documented history of Navy activities on the western portion of the NOAA site (i.e., outside of the Former Fire Training Area).

NOAA acquired the southernmost 22 acres of the Manchester Annex, which includes the Former Fire Training Area, in the early 1970s (Hart Crowser 1997). NWFSC has operated the MRS since the 1970s, which is the largest marine research station within NOAA. Science undertaken at the MRS facility supports NMFS’ efforts to conserve at-risk and endangered Pacific salmon, develop ecologically sustainable aquaculture, advance marine fish and shellfish biology, and restore marine habitat.

2.4 Previous Environmental Investigations

Beginning in 1987, several environmental investigations were performed on the Manchester Annex. Based on the findings of the investigations, the site was listed on the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA aka Superfund) National Priorities List of Hazardous Sites in 1994 as single operable unit, the Old Navy Dump/Manchester Laboratory (USEPA/NOAA) Superfund Site (Comprehensive Environmental Response, Compensation, and Liability Information System ID Number WA 8680030931) which was also referred to as the Old Navy Dump/Manchester Superfund Site (and is referred to within this report as the Old Navy Dump/Manchester Superfund Site - Figure 2).

An approximately 6-acre capped landfill associated with the Old Navy Dump/Manchester Superfund Site (referred to as the Former Landfill) is present on the EPA-owned property located to the northeast of the MRS Property (Figure 1 and Figure 2). The southeastern edge of the Former Landfill was formerly exposed along Clam Bay and allowed waste materials to erode into the adjacent intertidal area.

A 1996 remedial investigation/feasibility study (RI/FS) identified potential current and future risk to human health and the environment, primarily associated with potential skin contact and incidental ingestion of waste materials containing elevated concentrations of metals and polychlorinated dioxins and furans (Hart Crowser 1996). Elevated concentrations of these constituents were detected in the Former Landfill waste materials, FFTA debris, and soils. The RI/FS also identified a threat of metals and polychlorinated biphenyls (PCBs) migrating from the Former Landfill area into Clam Bay, where sediments and marine organisms may accumulate contaminants.

PCB concentrations in tidal sediments and clam tissue within Clam Bay have been monitored by USACE for several years following implementation of the remedial actions required by the ROD.

In 2020, USACE also sampled soils from the coastal embankment close to the NOAA outfalls and undertook additional sampling in October 2023 to further assess the distribution and lateral extent of PCBs in the area of the NOAA outfalls and erosional embankment, and the impact of these areas on the remainder of Clam Bay (USACE 2021; USACE 2023b). As shown on Figure 4, total PCB concentrations above the screening level of 40 micrograms per kilogram (µg/kg) are observed in the bluff face adjacent to PCB-contaminated sediments in Clam Bay and upland soils adjacent to the bluff. Inland soil PCB concentrations were mostly below screening levels with only a few samples on the eastern side of the Former Fire Training Area exceeding screening levels.

USACE’s sample locations and associated PCB concentrations in soil are shown on Figure 4 (USACE 2025). Total PCB concentrations exceeded the 40 µg/kg screening levels at three locations on the east side of the Former Fire Training Area near the bluff. The exceedances were at 1 to 2 feet below ground surface and ranged from 73 to 4,500 µg/kg.

In June 2021, USACE collected soil and groundwater samples in the Former Fire Training Area to assess for the presence of PFAS in soil and groundwater related to the use of aqueous film forming foam which may have contained PFAS (Aerostar Environmental and Construction LLC.

2022, USACE 2022a). The Final Site Investigation Report (USACE 2022a) compared sample results to screening levels from a September 2021 Office of the Assistant Secretary of Defense (ASD) memorandum (ASD 2022). An Addendum to the Site Investigation Report (USACE

2022b) revised the analytical results discussion to include updated screening levels from a 2022 ASD memorandum which was issued following the EPA’s release of updated regional screening levels for perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), perfluorononanoic acid (PFNA), and hexafluoropropylene oxide dimer acid.

PFAS constituents were detected in soil and groundwater in the Former Fire Training Area(Figure 5 and 6). PFAS compounds were detected in subsurface soils at concentrations below the 2022 ASD human health screening levels for residential and site worker direct soil contact (USACE 2022b; ASD 2022). PFAS constituents were detected in groundwater at concentrations exceeding ASD tap water screening levels and the 2016 EPA drinking water health advisory (USACE 2022b; ASD 2022; EPA 2016). The sample locations are shown on Figure 3.

In October 2023, USACE collected additional samples for PFAS analysis within the Former Fire Training Area (USACE 2024). PFAS distribution in soil and groundwater from the 2021 and 2023 events are shown in Figures 7 and 8 [Figures 7 and 8 from Draft Final PFAS Report, August 2024] (USACE 2024). No soil or groundwater contamination is known to exist in the western half of the MRS Property (Hart Crowser 1996, 1997). The USACE’s Draft Final PFAS Report for the 2023 sampling event concluded the following:

“PFAS compounds are present at subsurface soil and groundwater at the Former Fire Training Area. In subsurface soil, PFAS compounds are present at limited locations at concentrations below project screening levels. PFAS is present in groundwater throughout the Former Fire Training Area, including areas upgradient, adjacent to, and/or downgradient of the Northern Simulator Foundation, Other Fire Training Infrastructure, the Main Simulator Foundation, and at the Former Fire Training Area site boundaries. The highest concentrations of PFAS are generally in the areas adjacent to the former simulator foundations; however, select PFAS compounds, especially PFOA, also exceeded project screening levels along the eastern and northern boundaries of the FFTA.”

It should be noted that historical sampling in the western portion of the property was limited, as no historical features of concern were identified in this portion of the Property, therefore the potential for contamination cannot be discounted.

In January 2024, NOAA/AECOM undertook additional PCB and PFAS sampling within the proposed excavation areas for the Seawater System Replacement and Campus Addition Project, to better delineate the extent of PCB and PFAS in soil and groundwater (per the Pre- Construction Sampling and Analysis Plan, AECOM 2023). The results of that sampling effort were used to create maps of the project site (Figures 5 and 6) showing the soil and water classification (as described in Sections 5 and 6 of the EMMP) that is applicable to each area of the proposed construction footprint. Sampling results are presented in the Pre-Construction Sampling and Analysis Results Report (AECOM 2024).

Addendums to the EMMP, if prepared, must be consulted for updates to soil and water classification areas and management practices based on newly discovered or changed site conditions.

2.5 Previous Remedial Actions

Based on the findings of the 1996 RI/FS, the 1997 ROD stipulated the following remedial components for the Old Navy Dump/Manchester Superfund Site (Hart Crowser 1997):

• Former Landfill (northeast of MRS Property): removal of landfill debris along shoreline and placement of the removed debris within the upland landfill area. Capping of the upland area of the landfill and the adjacent intertidal depression with clean fill and installation of a shoreline protection system. Installation of a hydraulic cutoff system along the upgradient edge of the landfill cap. The Former Landfill is located on the EPA property, adjacent to the north of the MRS Property (Figure 2).

• Former Fire Training Area (east side of MRS Property): excavation and off-site disposal of dioxin-contaminated soil and debris located in and around the simulators.

Closure in-place of the fire simulator USTs, in accordance with following state UST closure requirements, including removal of the associated UST piping and petroleum-impacted soil along the piping, to the extent practicable. Pipe sections that were impractical to remove were abandoned in place. The Former Fire Training Area is located on the east side of the MRS Property (Figure 3).

2.6 Former Landfill (northeast of MRS Property)

Previous environmental investigations identified elevated concentrations of metals, PCBs, dioxins/furans, volatile organic compounds, and asbestos in the Former Landfill area.

Concentrations of these constituents were considerably lower outside the landfill area (Hart Crowser 1997). The landfill remedial components stipulated in the ROD were completed between 1999 and 2001 (EPA 2002).

The planned seawater system and campus addition project planned on the MRS Property does not require ground disturbance or earthwork within the Former Landfill cap, its associated hydraulic cutoff and shoreline protection systems, or the adjacent Clam Bay intertidal areas (Figure 3). Existing contamination associated with the Former Landfill is not expected to be encountered during the seawater system and campus addition project and is not further addressed in this EMMP.

2.7 Former Fire Training Area (east side of MRS Property)

Previous environmental investigations and remedial actions identified and cleaned up contamination associated with the Former Fire Training Area on the eastern portion of the MRS Property (Figure 3). There is no known or suspected significant contamination located in the western portion of the MRS Property, outside of the Former Fire Training Area (Hart Crowser 1996, 1997).

The Former Fire Training Area is approximately 4.7 acres of the easternmost portion of the NOAA MRS property (Figure 3). Large concrete structures known as “simulators” were used to simulate ship compartments (USACE 2009), in which fires were started and then extinguished for Naval fire training. This area had USTs containing various fuels including gasoline, diesel, and waste oil. Fire training activities resulted in releases of hazardous materials and petroleum products. Constituents of concern associated with these operations include dioxins/furans, petroleum hydrocarbons, and PFAS (USACE 2019; Aerostar Environmental and Construction 2022; USACE 2022a, 2022b).

A 1998 removal action was performed to remove diesel fuel distribution piping and petroleum-contaminated soils from the area currently occupied by the main MRS parking lot (Kleinfelder and REMTECH 1999; USACE 2009, 2019). The fire training simulator structures and associated debris were removed, along with excavation of petroleum contaminated soils to depths between 6 and 8 feet below ground surface and backfilled with clean fill (Kleinfelder and REMTECH 1999). The brick flooring and lower portions of the simulators and excavated soils were disposed of at the Rabanco Regional Landfill (now known as Republic Services Roosevelt Regional Landfill) in Klickitat County, Washington. Other clean brick and concrete debris was transported off-site to Woodworth & Company Lakeview Concrete Recycling Pit in Tacoma, Washington (Kleinfelder and REMTECH 1999).

In 2000, a second removal action was performed to close the remaining USTs and vaults and associated piping in the Former Fire Training Area and characterize and remove stockpiled dioxin-impacted soil and debris located in the vicinity of the Northern Simulator area (Figure 3).

Dioxin impacted soils were removed from around the Northern Simulator foundation to 6 inches below ground surface to levels below the ROD cleanup levels of 270 nanograms per kilogram for 2,3,7,8-TCDD Equivalent (Kleinfelder and REMTECH 2001 and Hart Crowser 2005). In addition, approximately 100 feet of asbestos-clad piping was discovered, abated, and removed near UST 13 and lead-contaminated soil removed from UST 11 was disposed off-site (at the Rabanco Regional Landfill) as hazardous waste. Soil sampling confirmed that concentrations of petroleum and dioxins/furans, lower than project action levels, remained in soils after the removal action was completed (Kleinfelder and REMTECH 2001).

Between 1994 and 2000, a total of thirteen USTs formerly containing petroleum products were decommissioned in-place in accordance with Washington UST regulations and the associated piping systems were reportedly removed or plugged. Four other underground concrete structures (referred to as USTs but which appear to have been used for water storage - not for petroleum products or other hazardous materials), remained present on site as of 2009 (USACE 2009). The UST locations, remedial excavation areas, and areas suspected of having residual petroleum contamination are depicted on Figure 3. A site-specific risk assessment and leachability testing indicated a low risk to groundwater from residual petroleum hydrocarbons (USACE et al. 2012; USACE 2019). A summary of the USTs in the Former Fire Training Area, (based on information from USACE et al. 2012, Appendix G) is presented below.

• Tanks 1 through 4 and Tank 9: decommissioned in 1998

• Tank 5: Steel, decommissioned in 1994

• Tank 5A: Concrete, Intact

• Tank 6: Concrete Vault, Intact

• Tank 7: Steel, decommissioned in 1994

• Tank 8: Concrete, decommissioned in 2001

• Tank 10: Steel, decommissioned in 1994

• Tanks 11 through 16: decommissioned in 2000

• Tank 17: Concrete, Intact

• Tank 18: Concrete, Intact

2.8 Institutional Controls

The ICP for the Old Navy Dump/Manchester Superfund Site includes the following institutional controls to address residual petroleum hydrocarbons remaining in the Former Fire Training Area on the MRS Property (USACE et al 2012):

• The property on which the Former Fire Training Area was located shall not be used in the future as a residential property or a day care facility.

• Future storm water runoff systems shall be designed to divert runoff away from the UST areas (Figure 3).

• During subsurface excavations in the restricted areas where residual petroleum exists:

o Contractors and employees working in subsurface excavations shall be notified of the need to utilize health and safety precautions normally applicable to UST removals.

o Excavations shall be observed by a qualified environmental professional to determine if exposed soils contain free product.1 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 close to the original excavation in a substantially similar environment.

o Temporary stormwater controls and other best management practices (BMPs), such as temporary soil covers and subsurface liners, shall be used to minimize infiltration and runoff of soil materials.

1 The ICP defines a “qualified environmental professional” as “a professional biologist, physical scientist, or engineer with a minimum of two years’ experience in responsible activities at the site, or a technician with a minimum of three years’ experience in responsible activities at the site” (USACE et al. 2012). The ICP further states “Responsible activities are those that involve environmental management decisions and implementation and/or a program of health and safety protection” and that “24-or 40-hour HAZWOPER training is not a requirement due to the nature of the materials possibly contacted.”

3.0 SUMMARY OF CONTAMINANTS AND AREAS OF POTENTIAL CONCERN

This section describes the known and potential environmental conditions that may be encountered during excavation and earthwork activities for the seawater system replacement and campus addition construction project on the MRS Property.

3.1 Former Fire Training Area

Previous environmental investigations and remedial actions identified soil and groundwater contamination, USTs, and asbestos-clad piping associated within the Former Fire Training Area on the eastern portion of the MRS Property.

3.1.1 Soils

Petroleum constituents (primarily diesel- and oil-range total petroleum hydrocarbon [TPH]) and dioxin/furan-contaminated soil (Table 1) have been previously identified and removed from the Former Fire Training Area and from around the former simulator (Hart Crowser 1996;

Kleinfelder and REMTECH 1999, 2001). Residual petroleum and dioxin/furan contamination may remain in soil under the former Northern Simulator foundation (Figure 3). Metals (arsenic, barium, lead, and mercury) were detected in soil at concentrations below the Resource Conservation and Recovery Act (RCRA) Toxicity Leaching Characteristic Procedure hazardous waste criteria (Kleinfelder and REMTECH 1999, 2001).

No PFAS compounds have been detected in site soils above the applicable regional screening levels or project screening levels (AECOM 2024, USACE 2024). Low levels (below applicable screening levels) of PFAS in soils were detected at several locations within the Former Fire Training Area. PFAS has not been detected above laboratory limits of quantification outside of the Former Fire Training Area (AECOM 2024b).

Total PCB concentrations were observed at concentrations above screening levels in soils collected from the bluff face adjacent to PCB-contaminated sediments in Clam Bay. Upland soils adjacent to the bluff also had PCB concentrations above the screening levels. Inland soil PCB concentrations were mostly below screening levels with only a few samples on the eastern side of the FFTA exceeding screening levels (USACE 2025). PCBs have not been detected above laboratory limits of quantification outside of the Former Fire Training Area (AECOM 2024b). Maximum detected concentrations in the Former Fire Training Area are provided below in Table 1.

Table 1 – Maximum Detected Concentrations in Former Fire Training Area Soil

Constituent of Concern

Pre-Remediation Maximum Detected

Concentration 1

Post-Remediation Maximum Detected

Concentration 2

ROD Cleanup Level/ Clean Up

Goal 3 Project Screening

Level4

TPH (as Gasoline) 1,100 mg/kg Not Detected N/A N/A TPH (as Diesel) 16,000 mg/kg 29 mg/kg NA / 200 mg/kg N/A TPH (as Oil) 7,700 mg/kg 180 mg/kg N/A N/A Dioxins/Furans 2,3,7,8-TCDD Equivalent

26,000 ng/kg 259 ng/kg 270 ng/kg/ NA N/A

PCBs (total) 0.58 mg/kg 4.5 mg/kg5 0.13 mg/kg /

0.04 mg/kg

0.13 mg/kg

PFOS N/A 2.19 ng/g6 N/A 13 µg/kg PFOA N/A 0.229 J ng/g6 N/A 19 µg/kg

Constituent of Concern

Pre-Remediation Maximum Detected

Concentration 1

Post-Remediation Maximum Detected

Concentration 2

ROD Cleanup Level/ Clean Up

Goal 3 Project Screening

Level4

PFBS NA ND6 NA 1,900 µg/kg

PFBA NA ND6 NA 7,800 µg/kg

PFNA NA ND6 NA 19 µg/kg

PFHxA NA ND6 NA 3,160 µg/kg

PFHxS NA ND6 NA 126 µg/kg

HFPO-DA NA ND6 NA 23 µg/kg bis(trifluoromethylsulfonyl)amine

(TFSI) 8

NA NA NA 2,300 µg/kg perfluoropropanoic acid (PFPrA) 8

NA NA NA 3,900 µg/kg

Notes:

1 Maximum detected concentration reported in the 1996 RI/FS (Hart Crowser 1996) or 2022 PFAS Site Inspection and Addendum

(USACE 2022a, 2022b).

2 Maximum detected concentrations reported after completion of the soil and debris removal and UST closure activities in 2000

(Kleinfelder and REMTECH 1999, 2001) 3 Old Navy Dump/Manchester Superfund Site Record of Decision, Table 15 (Hart Crowser 1997) 4 See Table 4 (PCBs) and Table 5 (PFAS) for more detailed information regarding project screening levels.

5 From Table 3 Concentrations of Total PCBs in Inland Soils from Draft Final Data Summary and Analysis Report (USACE 2025)

6 From Table 4 Former Fire Training Area Subsurface Soil Analytical Results, Addendum to the Final Site Inspection Report, (USACE 2022)

7These analytes do not currently have EPA- approved analytical methods, but this may change in the future.

8Analytes added for future reference. These analytes do not currently have EPA- approved analytical methods, but this may change in the future.

J = estimated concentration mg/kg = milligrams per kilogram NA = not applicable or not available ND = non-detect ng/g = nanograms per gram ng/kg = nanograms per kilogram PCBs = polychlorinated biphenyls PFOA = perfluorooctanoic acid PFOS = perfluorooctane sulfonate ROD = record of decision TCDD = tetrachlorodibenzo-p-dioxin TPH = total petroleum hydrocarbons

Sampling activities undertaken by NOAA in January 2024 also encountered areas of petroleum odors and/or sheen in several locations along and near the roadway along the coastal portion of the site (boring locations B-12 through B-16 on Figure 3) (AECOM 2024b).

Sampling will occur under the former Northern Simulator foundation prior to construction activities to determine if COCs are present. The sampling approach is described in the Manchester Event #4 – Campus Addition Site Prep and Electrical Upgrades Sampling and Analysis Work Plan (NOAA, 2025).

3.1.2 Groundwater

Contaminants previously detected in groundwater at the Former Fire Training Area include:

TPH, benzene, and PFAS (Table 2) (Hart Crowser 1996; USACE 2022a, USACE 2022b).

Pre-construction sampling efforts undertaken in early 2024 found detections of PFAS in groundwater at concentrations exceeding applicable screening levels in some parts of the Former Fire Training Area (AECOM 2024b), and at low levels (below applicable screening levels) in other areas of the Former Fire Training Area. No PFAS has been detected above laboratory limits of quantification outside of the Former Fire Training Area.

Table 2 – Maximum Detected Concentrations in Former Fire Training Area Groundwater

Constituent of Concern Maximum Detected Concentration 1 Project Screening Level 2 TPH (as Gasoline) 1,300 µg/L 800 µg/L3 TPH (as Diesel) 1,100 µg/L 500 µg/L3 TPH (as Oil) Not Detected 500 µg/L3

Benzene 22 µg/L 5 µg/L3

Dioxins/Furans Not Detected N/A PCBs Not Detected N/A PFOS 128 ng/L 4 ng/L PFOA 256 ng/L 4 ng/L PFBA 25.9 ng/L 1800 ng/L PFBS 16.3 ng/L 600 ng/L PFHxS 51 ng/L 10 ng/L PFHxA 31.1 ng/L 990 ng/L PFNA 10.4 ng/L 10 ng/L HPFO-DA 7.85 ng/L 10 ng/L Bis(trifluoromethylsulfonyl)amine

(TFSI)4

NA NA

Notes:

1 Maximum detected concentrations reported in the 1996 RI/FS (Hart Crowser 1996), Table 6 Summary of PFBS, PFOA, and PFOS

Detection and Screening Level Exceedances, Addendum to the Final Site Inspection Report (USACE 2022), or Table 5-1 Summary of PFAS Detections and Screening Level Exceedances, Draft Final Supplemental Site Inspection Report, PFAS Investigation Report (USACE 2024).

2 See Table 5 for more detailed information regarding project screening levels for PFAS related compounds.

3 Model Toxics Control Act (MTCA) Method A Cleanup Levels for Groundwater (Table 720-1, WAC 173-340-900) 4 Analytes added for future reference. These analytes do not currently have EPA- approved analytical methods, but this may change in the future.

µg/L = micrograms per liter ng/L = nanograms per liter PCBs = polychlorinated biphenyls PFOA = perfluorooctanoic acid PFOS = perfluorooctane sulfonate TPH = total petroleum hydrocarbon

3.1.3 Potential Underground Storage Tanks

The proposed construction excavation activities are not currently planned where known potentially intact or closed-in place USTs are located (Figure 3). However, if a UST or associated piping is encountered during project earthwork activities, the construction contractor will stop work in the UST discovery area and immediately notify the COR and/or their designee.

The construction contractor will not resume work in the UST discovery area until receiving authorization from the COR and/or their designee to proceed with the necessary UST mitigation measures. The construction contractor will follow the general UST removal procedures and requirements provided in the Contingency UST Removal Plan (Appendix B).

3.1.4 Potential Asbestos-Containing Materials

Subsurface asbestos-clad piping was removed and abated during previous remedial activities in the Former Fire Training Area (Kleinfelder and REMTECH 2001). It is possible that previously unknown subsurface asbestos-clad piping may be present within the project area. If any asbestos-clad piping or suspected asbestos-containing materials are encountered in construction excavations, the construction contractor will stop work in the suspected asbestos-containing material discovery area and immediately notify the COR and/or their designee. The construction contractor will not resume work in the suspected asbestos-containing material discovery area until receiving authorizatio0n from the COR and/or their designee to proceed with the necessary asbestos mitigation measures. The construction contractor will follow the procedures in the Contingency Asbestos Handling Plan (Appendix C) for avoidance and/or safe handling, removal, and disposal of remnant subsurface asbestos-clad piping and suspected asbestos-containing materials.

3.2 West Portion of MRS Property

No Navy fire training activities, and associated soil or groundwater contamination, are known to have occurred in the western half of the MRS Property (Hart Crowser 1996, 1997). However, historical sampling in the western portion of the property was limited.

This EMMP identifies a range of soil and water management strategies that should be implemented, based on the soil management classification (SMC) and water management classification (WMC) of the area where construction would occur. The classifications are based on the potential contaminant levels, with lower classifications (SMC1 and WMC1) indicating no or very low contaminant levels, and higher classifications (SMC3 and WMC3) indicating higher contaminant levels, as described in Sections 5.2 (for soil) and 6.2 (for water) of this EMMP.

The results of the additional PCB and PFAS pre-construction sampling (AECOM 2024b) were used to delineate which areas of the construction footprint are subject to the various soil and water management classifications. These SMC and WMC maps are presented in Figures 5 and 6 of this EMMP.

Addendums to the EMMP, if prepared, should be consulted for the latest versions of the SMC and WMC maps.

4.0 CONTRACTOR HEALTH AND SAFETY

Prior investigation identified petroleum, dioxins/furans, PCBs, and PFAS in soils, therefore contractor personnel working at the MRS Property should be made aware of the potential for encountering these contaminants. It is the responsibility of each involved entity (e.g., the Owner [NOAA], the construction contractor and its subcontractors such as an environmental consultant/qualified environmental professional) to conduct its own hazard assessment to determine appropriate health and safety measures for its workers. Also refer to Section 3.8 of 01 57 19 Temporary Environmental Controls of the Technical Specifications, 100% Construction Documents.

All entities are responsible for notifying and updating others and their employees of potential hazards that may be encountered during the project. Testing, management, handling, excavation, and transportation of contaminated soil will require persons with 40-hour Hazardous Waste Operation & Emergency Response ([HAZWOPER] 29 Code of Federal Regulations [CFR] 1910.120) training. Each party involved should assess the need for this training on the basis of current information for the project site. Changes to the level of protection will be made should additional contaminated areas be discovered.

4.1 Health and Safety Plan

The construction contractor and its subcontractor(s), if applicable, will be responsible for developing and implementing their own specific health and safety plan (HASP), which should be submitted to NOAA, USACE, and EPA prior to mobilization. Based on the currently available site data, it is assumed that all construction and environmental monitoring field work will be conducted using Level D personal protective equipment, which includes hardhats, steel-toed boots, high visibility safety vests, safety glasses, and gloves. The level of protection may be upgraded based on the field screening and sampling results.

5.0 SOIL MANAGEMENT

This section describes the proposed approach to identifying and managing contaminated soil encountered during construction related earthwork. This EMMP assumes that NOAA’s construction contractor will only excavate and remove soil from the MRS Property to the extent necessary complete the seawater system and campus addition project, unless requested and authorized by NOAA. The contractor should reuse excavated soil on-site within the same area as it was excavated from, to the maximum extent practicable based on field screening and testing results, in accordance with the conditions and limitations outlined in this EMMP.

Addendums to the EMMP, if prepared, should be consulted for the most current soil management classification areas and management and disposal practices.

5.1 Responsible Personnel

Excavation and soil handling activities at the site will be undertaken by a licensed contractor in conformance with a site-specific HASP to be developed by the contractor that meets the requirements of 29 Code of Federal Regulations 1910.120. In particular, the Health and Safety Plan shall specify those activities which must be undertaken by qualified 40-hour Occupational Safety and Health Administration HAZWOPER-trained personnel.

The contractor’s Environmental Manager will have primary responsibility for all aspects of soil management including temporary erosion control measures, stockpiling, and off-site transportation and disposal. The Environmental Manager will be responsible for ensuring that the construction contractor undertakes the tasks described within this document.

A qualified environmental professional will be on-site during grading and excavation activities to field screen soils for the presence of unanticipated contamination, collect representative soil samples for analytical testing (see Appendix A, Waste Characterization Sampling and Analysis Plan [WCSAP]) to assist the contractor with determining if the material is suitable for reuse or profiling for off-site disposal at a licensed landfill facility.

5.2 Soil Management Classification and Methods of Classification This EMMP requires that soils excavated during construction be managed in different ways, depending on the level of PCBs and/or PFAS contamination that is present within the soils.

Figure 5 of this EMMP identifies the specific areas within the project footprint to which each of the Soil Management Classes (SMCs) described in Sections 5.2.1 through 5.2.3 apply based on the criteria in Table 3. The applicable laboratory limits of quantification (LOQs) and regional screening levels (RSLs) referenced in Table 3 are presented in Table 4.

Note: If and when PFOS, PFOA, or other PFAS compounds are listed as CERCLA hazardous substances with established cleanup levels, the established cleanup levels will be used in place of RSLs. The soil management classification map will be updated to reflect any changes to zones based on the established cleanup levels.

Table 3 – Soil Management Classifications Soil Management Class1

Preconstruction Sampling Results2

General Approach to Soil Reuse

General Approach to Soil Disposal (if required)

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.

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.

May be reused on site within SMC2 or SMC3 areas without further sampling.

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

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

Disposal of SMC2 soils at a Subtitle C landfill would 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 sampling4 confirms PFAS and PCBs are below RSLs.

If PFAS are below RSLs and PCBs are below 50 parts per million, 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 parts per million, soil will 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)

Unanticipated Contaminated 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 product encountered or if sampling results indicate any contaminants above RSLs (or

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

ICP5.

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

Soil Management Class1

Preconstruction Sampling Results2

General Approach to Soil Reuse

General Approach to Soil Disposal (if required)

MTCA Method A thresholds for petroleum).

LOQs), SMC2 (below RSLs), or SMC3 (above RSLs) and reused 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, Resource Conservation Recovery Act 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.

Acronyms:

EPA = U.S. Environmental Protection Agency.

LOQ = limits of quantification (see Table 4).

ICP = Institutional Control Plan.

MTCA – Model Toxics Control Act.

PCBs = polychlorinated biphenyls.

PFAS = polyfluoroalkyl substances.

RSLs = EPA Regional Screening Levels (see Table 4).

SMC = soil management classification.

SUN = Unanticipated Contaminated Soils.

Notes:

1 See Figure 5 of this EMMP for map of project site showing where each SMC applies.

2 Laboratory LOQs and RSLs for PFAS and PCBs are detailed in Table 4 below. 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.