Appdx_B_-_MCB_Pendleton_Launch_Ramp_2015_SAR.pdf

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Appendix B. 2016 Camp Pendleton Loading Ramp Sampling and Analysis Report. 114 pages

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SAMPLING AND ANALYSIS REPORT

Marine Corps Base Camp Pendleton Loading Ramp Dredge Material Sampling and Testing for Beach Nourishment Suitability

Task Order No. 0008 USACE Contract No. W912PL-11-D-0015

Prepared for:

U.S. Army Corps of Engineers

Los Angeles District Los Angeles, California

Prepared by:

Diaz•Yourman – GeoPentech – Kinnetic Laboratories/ Joint Venture

1616 E. 17th Street Santa Ana, CA 92705

February 2016

GeoPentech i

DISTRIBUTION LIST

Mr. Jeffrey Devine, Technical Manager U. S. Army Corps of Engineers, Los Angeles District Jeffrey.D.Devine@usace.army.mil

Ms. Kelly Shaw Field Geotechnical Leader Diaz-Yourman kelly@diazyourman.com

Mr. Scott John, Project Manager U. S. Army Corps of Engineers, Los Angeles District Scott.M.John@usace.army.mil

Mr. Christopher Diaz Geotechnical Manager Diaz-Yourman & Associates chris@diazyourman.com

Mr. Robert Directo, Project Leader Public Works Department MCB Camp Pendleton robert.directo@usmc.mil

Mr. Allen Yourman Joint Venture Project Manager Diaz-Yourman Associates, GeoPentech, and Kinnetic Laboratories Joint Venture Allen@diazyourman.com

Mr. Larry Smith U. S. Army Corps of Engineers, Los Angeles District lawrence.J.Smith@usace.army.mil

Mr. Ken Kronschnabl KLI Project Manager Kinnetic Laboratories, Inc.

kkronsch@kinneticlabs.com

Ms. Christina Arias San Diego Regional Water Quality Control Board carias@waterboards.ca.gov

Mr. Spencer Johnson Field Operations Manager Kinnetic Laboratories, Inc.

sjohnson@kinneticlabs.com

Ms. Melisa Scianni United States Environmental Protection Agency- Region 9 scianni.melissa@epa.gov

Ms. Amy Howk KLI QA/QC Management Kinnetic Laboratories, Inc.

ahowk@kinneticlabs.net

Mr. Allan Ota United States Environmental Protection Agency- Region 9 ota.allan@epa.gov

Mr. Jon Toal Health and Safety Management Kinnetic Laboratories, Inc.

jtoal@kinneticlabs.com

Mr. Robert Smith U.S. Army Corps of Engineers Regulatory Division rober.r.smith@usace.army.mil

Ms. Danielle Gonsman Client Services Director Eurofins Calscience DanielleGonsman@eurofinsus.com

Mr. Larry Simon Federal Consistency Coordinator Energy, Ocean Resources and Federal California Coastal Commission lsimon@coastal.ca.gov ii

THIS PAGE WAS LEFT INTENTIONALLY BLANK

iii

Task Order No.0008, USACE, Contract No. W912PL-11-D-0015

TABLE OF CONTENTS

Page No.

EXECUTIVE SUMMARY ...................................................................................................................... vii

1.0 INTRODUCTION

1.1 Project Summary

1.2 Site Location and Description

1.3 Roles and Responsibilities

2.0 HISTORICAL DREDGING AND DATA REVIEW

3.0 METHODS

3.1 Dredge Design

3.2 Study Design

3.2.1 Sediment Collection and Chemical Testing

3.2.2 Geotechnical Samples and Testing

3.2.3 Summary of Testing and Evaluation Sequence

3.2.4 Evaluation Guidelines

3.3 Field Sampling Protocols

3.3.1 Positioning and Depth Measurements

3.3.2 Vibracore Sampling Methods

3.3.3 Vibracore Decontamination

3.3.4 Core Processing

3.3.5 Detailed Soils Log

3.3.6 Documentation and Sample Custody

3.4 Laboratory Testing Methods

3.4.1 Geotechnical Testing

3.4.2 Bulk Sediment Chemical Analyses

4.0 RESULTS

4.1 Sediment Physical Results

4.2 Sediment Chemical Results

5.0 DISCUSSION

5.1 Sediment Observations

5.2 Sediment Grain Size

5.3 Bulk Sediment Chemistry

5.4 Conclusions

6.0 QUALITY CONTROL SUMMARY

6.1 Field Sampling Quality Management

6.2 Analytical Chemistry QA/QC

7.0 REFERENCES CITED

iv

APPENDICES

APPENDIX A – BEACH PHYSICAL COMPATIBILITY ANALYSIS (USACE, Los Angeles

District, 2015)

APPENDIX B – CORE PHOTOGRAPHS

APPENDIX C – SOILS LOGS OF SEDIMENT PHYSICAL CHARACTERISTICS

APPENDIX D – ANALYTICAL LABORATORY REPORT

APPENDIX E – FIELD DATA LOGS

APPENDIX F – GRAIN SIZE DISTRIBUTION CURVES AND OTHER PHYSICAL DATA

APPENDIX G – ANALYTICAL QUALITY ASSURANCE/QUALITY CONTROL REPORT

LIST OF TABLES

Table 1. Project Team and Responsibilities Table 2. Key Project Contacts Table 3. Actual Sampling Locations, Core Depths, Mudline Elevations, and Sampling

Elevations, MCBCP Loading Ramp Table 4. MCBCP Loading Ramp Sediment Screening Values for Selected Analytes Table 5. Sediment Analytical Methods and Quantitation Limits Table 6. 2015 MCBCP Loading Ramp Sieve Analysis Data for Individual Cores Table 7. Surface Physical Data for Oceanside City Beaches Collected in 2012 Table 8. 2015 MCBCP Loading Ramp Composite Bulk Sediment Chemistry Results Table 9. Quality Control Summary for Field Sediment Sampling Table 10. Counts of QC records per Chemical Category

LIST OF FIGURES

Figure 1. Location of the Oceanside Harbor Figure 2. Location of the Oceanside Harbor MCBCP Loading Ramp Area and 2016 Oceanside

City Beach Nourishment Areas Figure 3. Oceanside Harbor Del Mar Boat Basin Loading Ramp Area Dredge Prism, June 2015

Contour Bathymetry and Sampling Locations Figure 4. Oceanside Harbor Del Mar Boat Basin Loading Ramp Area Dredge Prism, June 2015

Point Bathymetry Data and Sampling Locations Figure 5. Location of the 2012 Sampling Transects at Oceanside City Beaches v

LIST OF ACRONYMS

ASTM American Society for Testing and Materials MS Matrix Spike BLK Method or Procedural Blank MSD Matrix Spike Duplicate BMP Best Management Practice ND Not Detected BS Blank Spike NOAA National Oceanic and Atmospheric Administration BSD Blank Spike Duplicate OEHA Office if Environmental Hazard Assessment Cal/EPA California Environmental Protection Agency PAH Polyaromatic Hydrocarbon CD Compact Disc PCB Polychlorinated Biphenyl CDFG California Department of Fish and Game PDS Post Digestion Spike CESPD Corps of Engineers South Pacific Division PDSD Post Digestion Spike Duplicate CHHSL California Human Health screening Level PPB Parts Per Billion COC Chain of Custody PPM Parts Per Million CSLC California State Lands Commission PRG Preliminary Remediation Goals CV Coefficient of Variation PVC Polyvinyl Chloride cy Cubic Yards RBC Risk-Based Concentration DDD Dichlorodiphenyldichloroethane RL Reporting Limit DDE Dichlorodiphenyldichloroethylene RPD Relative Percent Difference

DDT Dichlorodiphenyltrichloroethane RSLs Regional Screening Levels for Cleanup of Superfund Sites

DGPS Differential Global Positioning Satellite SC- DMMT Southern California Dredge Material Management Team

DTSC Department of Toxic Substances Control SOPs Standard Operating Procedures DUP Laboratory Replicates STLC Title 22 Soluble Threshold Limit Concentration ERL NOAA Effects Range Low SURR Surrogate Analysis ERM NOAA Effects Range Medium SWQCB State Water Resources Control Board GPS Global Positioning Satellite TOC Total Organic Carbon

HHMSSL Human Health Medium – Specific Screening Levels TRPH Total Recoverable Hydrocarbons

HDPE High-density Polyethylene TTLC Title 22 Total Threshold Limit Concentration ITM Inland Testing Manual UCL Upper Control Limit LCL Lower Control Limit USACE U.S. Army Corps of Engineers LCS Laboratory Control Spike USEPA U.S. Environmental Protection Agency LDPE Low-density Polyethylene QA Quality Assurance LSD Least Significant Difference QC Quality Control MCBC Marine Corps Base Camp Pendleton QUAL Qualifier MDL Method Detection Limit USCS Unified Soil Classification System MLLW Mean Lower Low Water vi vii

EXECUTIVE SUMMARY

The United States Army Corps of Engineers (USACE) would like to conduct maintenance dredging of the loading ramp facility for Marine Corps Base Camp Pendleton (MCBCP) adjacent to the Del Mar Boat Basin of Oceanside Harbor, California in order to restore the area in front of the loading ramp to its design depth of -13 feet Mean Lower Low Water (MLLW). Based on a June 2015 bathymetric survey, up to 21,000 cubic yards (cy) of sediment would need to be removed with a two-foot overdredge allowance. This dredging would be conducted during routine O&M dredging of the Del Mar Federal Channel of Oceanside Harbor.

This study was undertaken to evaluate the physical and chemical properties of the sediments within the dredge footprint in order to support planning and permitting for dredging and reuse. It is desired to reuse all of the loading ramp sediments for beach replenishment on Oceanside City Beaches.

Vibracore sampling was carried out off a pontoon barge to collect subsurface sediment samples at eleven (11) locations during the 26th and 27th of August, 2015. Subsamples from each location were combined with like subsamples to form a single composite sample. This composite sample was analyzed for total and volatile solids, pH, total organic carbon, oil & grease, petroleum hydrocarbons, ammonia, sulfides, metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver and zinc), butyltins, pyrethroid pesticides, chlorinated pesticides, PCB congeners, phenols, phthalates, and PAH compounds. In addition, samples for grain size analyses and for archiving were collected from each individual core prior to compositing. These grain size and archive samples represented the entire core length from the mudline to the two foot overdredge elevation or to the depth of refusal. Additional grain size samples were collected of any vertical grain size stratification.

Los Angeles District USACE used all geotechnical data gathered to do physical beach compatibility analyses between the proposed dredged sediments and the receiving beaches. To assist in evaluating beach suitability, receiving beach data used by the Corps was data obtained from Oceanside City Beach transect samples obtained during the 2012 dredge material evaluation of the Oceanside Harbor federal channels. These grain size gradation data were compared with grain size gradation data from the loading ramp samples to determine if the launch sediments are physically compatible with the receiving areas. The USACE report (Appendix A) concluded that all of the loading ramp sediments are compatible with the placement sites based on the weighted average of both the individual and composite sediment grain size curves for all core samples collected. USACE did note that a coarser gravely sand was encountered below elevations of approximately -10.5 feet to -15 feet MLLW. This coarser sediment is apparently an extensive layer of sediment that is distinct from the finer grained sand above it and can be anticipated to become part of the sediment that will be dredged and placed at the three potential receiving beach areas. This coarser material can be a problem for hydraulic mechanical dredging methods (hopper or cutter-head dredges) as it may cause the dredge production to slow down and could damage the pumping equipment.

Bulk sediment chemistry results were evaluated against National Oceanic and Atmospheric Administration (NOAA) toxicity effects-based screening levels and human health objectives.

There were no chemical constituents elevated above NOAA’s lower effects-based screening values viii and only arsenic was elevated above human health objectives. However, the arsenic exceedance was lower than typically found background concentrations and the position of the California Department of Toxic Substances Control (Dr. William Bosan, personnel communication) is that the risk to human health is minimal for arsenic concentrations below 12.0 mg/kg. The arsenic concentration in the loading ramp composite sample was 1.26 mg/kg. Therefore, the arsenic excursion above human health objectives appears to be minor and the overall dataset indicates that there is little chance of increased adverse biological or human health effects from the placement of the MCBCP loading ramp sediments at the Oceanside City Beach nourishment areas.

Task Order No. 0008, USACE Contract No. W912PL-11-D-0015

1.0 INTRODUCTION

Substantial shoaling has occurred in front of the Marine Corps Base Camp Pendleton (MCBCP) small boat launch adjacent to the Del Mar Boat Basin of Oceanside Harbor, California (Figures 1 and 2). Dredging is required in order to restore the MCBCP Loading Ramp area, shown on Figure 3, to its design depth. Sediments to be dredged require an environmental and physical evaluation of sediment quality in order to support planning and permitting for dredging and reuse.

This Sampling and Analysis Report (SAR) has been prepared on behalf of the U.S. Army Corps of Engineers, Los Angeles District to detail procedures and results including quality assurance/quality control (QA/QC) results from the sampling and testing of sediments from the boat launch area identified for placement at a potential beach nourishment site. This work is being performed under Task Order No. 0008, USACE Contract No. W912PL-11-D-0015. All work described in this report was done in accordance to the approved SAP (Diaz-Yourman and Associates, GeoPentech and Kinnetic Laboratories Joint Venture, 2015).

1.1 Project Summary

The purpose of this project was to sample and test sediments from within the MCBCP Loading Ramp dredge foot print area to provide sediment quality data for evaluation of dredging and the beneficial reuse of the dredge material for beach nourishment at nearby Oceanside City Beaches The 2016 beach nourishment areas are identified on Figure 2. This report is to fulfill requirements of the Corps of Engineers South Pacific Division Regulation No. 1110-1-8 (CESPD, 2000), the Inland Testing Manual (ITM) (USACE and USEPA, 1998), the Clean Water Act (CWA), and Southern California Dredge Material Management Team (SC-DMMT) draft guidelines.

Design depth of the MCBCP Loading Ramp area is -13 feet Mean Lower Low Water (MLLW).

Based on a June 2015 bathymetric survey, the estimated volume of sediments to be dredged from the loading ramp area to the design depth is 17,500 cubic yards (cy). With a two foot overdepth allowance, the total amount of material to be dredged could reach 21,000 cy. Bathymetric data from the June 2015 survey are shown on Figures 3 and 4.

Figure 1. Location of the Oceanside Harbor.

Figure 2. Location of the MCBCP Loading Ramp Area and 2016 Oceanside City Beach Nourishment Areas.

Figure 3. MCBCP Loading Ramp Area Dredge Prism, June 2015 Contour Bathymetry and Sampling Locations.

MCBCPBRVC15- 1

MCBCPBRVC15- 2

MCBCPBRVC15- 5

MCBCPBRVC15- 6

MCBCPBRVC15- 9

MCBCPBRVC15- 3

MCBCPBRVC15- 4

MCBCPBRVC15- 7

MCBCPBRVC15- 10

MCBCPBRVC15- 11

Proposed SAP Locations

Actual Sampling Locations Dredge Area Boundary

MCBCPBRVC15- 8

Figure 4. MCBCP Loading Ramp Area Dredge Prism, June 2015 Point Bathymetry Data and Sampling Locations.

Proposed SAP Locations

Actual Sampling Locations

Dredge Area Boundary

MCBCPBRVC15- 1

MCBCPBRVC15- 2

MCBCPBRVC15- 3

MCBCPBRVC15- 4

MCBCPBRVC15- 6

MCBCPBRVC15- 5

MCBCPBRVC15- 8

MCBCPBRVC15- 7

MCBCPBRVC15- 11

MCBCPBRVC15- 9

MCBCPBRVC15- 10

1.2 Site Location and Description

Oceanside Harbor is located 37 miles north of the City of San Diego and just to the north of the City of Oceanside and the mouth of the San Luis Rey River. The Harbor was built in two sections.

The southern wing houses a small fishing fleet and the northern wing is for recreational boaters.

There are more than 900 permanent slips.

The Del Mar Boat Basin is located north of the main Harbor and is connected to the entrance by the Del Mar Channel. It was first developed in 1942 shortly after Camp Pendleton was commissioned to support US Marine amphibious training missions. The Basin is also home to a recreational boating marina along with other recreational facilities.

The MCBCP Loading Ramp was constructed next to the Del Mar Channel just before it enters the Del Mar Basin towards the end of the 20th century. Geographic coordinates (NAD 83) for the Loading Ramp are 33° 12.81' N and 117° 24.15' W. There are no records of maintenance dredging of the loading ramp area. There are no fuel docks or sanitary pump out stations in the vicinity of the loading ramp, and according to Navy records, the loading ramp facility has never been used for fueling operations or sanitary pump out operations.

The proposed beach placement areas are along a 1.3-mile stretch of beach that runs from the mouth of the San Luis Rey River (33° 12.07' N and 117° 23.46' W) to Wisconsin Avenue (33° 12.07' N and 117° 23.46' W) in the City of Oceanside. This stretch of beach has previously received dredged material from the main channels of Oceanside Harbor.

1.3 Roles and Responsibilities

Project responsibilities and key contacts for this sediment characterization program are listed in Tables 1 and 2. Kinnetic Laboratories Inc. provided sampling and reporting services. Diaz- Yourman and Associates provided core logging and geotechnical testing. Analytical chemical testing of sediments this project was primarily carried out by Eurofins Calscience (NELAP No.

03220CA; Cal-ELAP No. 2803).

Table 1. Project Team and Responsibilities Responsibility Name Affiliation

Project Planning and Coordination

Jeffrey Devine Scott John

Christopher Diaz Ken Kronschnabl

USACE

USACE

Diaz-Yourman Kinnetic Laboratories

Sampling and Analysis Plan (SAP) Preparation Ken Kronschnabl Christopher Diaz

Kinnetic Laboratories Diaz-Yourman

Field Sample Collection and Transport Spencer Johnson Dale Parent

Kinnetic Laboratories Kinnetic Laboratories

Geotechnical Investigation Chris Diaz Kelly Shaw

Diaz-Yourman Diaz-Yourman

Health and Safety Officer and Site Safety Plan Jon Toal Kinnetic Laboratories

Laboratory Chemical Analyses Danielle Gonsman Katie Scott

Calscience Kinnetic Laboratories

QA/QC Management Analytical Laboratory QA/QC

Amy Howk Danielle Gonsman

Kinnetic Laboratories Calscience

Technical Review

Pat Kinney Jeffrey Devine

Christopher Diaz Larry Smith

Kinnetic Laboratories

USACE

Diaz-Yourman

USACE

Final Report Ken Kronschnabl Christopher Diaz

Kinnetic Laboratories Diaz-Yourman

Agency Coordination

Jeffrey Devine Larry Smith Scott John Joe Ryan

USACE

USCAE

USACE

USACE

USACE = United States Army Corps of Engineers

Table 2. Key Project Contacts Scott John USACE Project Manager Navigation Section U. S. Army Corps of Engineers, Los Angeles

District 915 Wilshire Blvd., Ste. 980 Los Angeles, Ca. 90017 Tel. (213) 452-3388.

Scott.M.John@usace.army.mil

Jeffrey Devine USACE Project Technical Manager Geology and Investigations Section U. S. Army Corps of Engineers, Los Angeles District 915 Wilshire Blvd. Ste. 980 Los Angeles, Ca. 90017 Tel. (213) 452-3579 Jeffrey.D.Devine@usace.army.mil

Larry Smith U. S. Army Corps of Engineers, Los Angeles

District 915 Wilshire Blvd., Ste. 980 Los Angeles, Ca. 90017 Tel. (213) 452-3846 lawrence.J.Smith@usace.army.mil

Robert Directo, P.E.

Project Leader, (Civil), O&T Team AC/S G-F, Public Works Dept.

Architecture & Engineering Box 555013, Building 220101T MCB Camp Pendleton, CA 92055-5013 Tel. (760) 763-8151 robert.directo@usmc.mil

Chris Diaz Project Manager - Geotechnical Investigations Diaz-Yourman & Associates 1616 East 17th Street Santa Ana, CA 92705-8509 Tel. (714) 245-2920 chris@diazyourman.com

Ken Kronschnabl Project Manager - Sampling/Testing Kinnetic Laboratories, Inc. (KLI) 307 Washington St.

Santa Cruz, CA 95060 Tel. (831) 457-3950 kkronsch@kinneticlabs.com

Spencer Johnson Field Operations Mgr.

Kinnetic Laboratories, Inc. (KLI) 307 Washington St.

Santa Cruz, CA 95060 Tel. (831) 457-3950 sjohnson@kinneticlabs.com

Danielle Gonsman Client Services Director – Analytical Testing Eurofins Calscience 7440 Lincoln Way Garden Grove, CA 92841-1427 Tel.: (714) 895-5494 DanielleGonsman@eurofinsUS.com

Marty Stevenson KLI QA/QC Management Kinnetic Laboratories, Inc.

55-1 Puapake Pl.

Lahaina, HI 96761 Tel. (808) 661-1110 mstevens@kinneticlabs.com

Allen Yourman Joint Venture Project Manager Diaz-Yourman Associates, GeoPentech, and Kinnetic Laboratories Joint Venture 1616 East 17th Street Santa Ana, CA 92705-8509 Tel. (714) 245-2920 Allen@diazyourman.com mailto:Allen@diazyourman.com

2.0 HISTORICAL DREDGING AND DATA REVIEW

There are no known or available sediment quality data from Camp Pendleton loading ramp area since its construction occurred in 1998. There is, however, some recent historical data available for the adjacent Del Mar Channel. This channel is maintained by the Los Angeles District Corps of Engineers and the area within 1,000 feet of the loading ramp area is dredged approximately every six years. The channel was last tested for maintenance dredging and beach nourishment back in 2012 (Diaz-Yourman, GeoPentech and Kinnetic Laboratories JV, 2012). Sediments from all maintenance dredging activities have been reused for beach nourishment since 2004.

A total of fourteen (14) cores were collected for the 2012 study for the Del Mar Channel. Each core was assessed individually for grain size distribution and a single composite sample was formed from the fourteen cores for chemical testing. All cores consisted of poorly graded sand (SP-SM) with silt with occasional layers of silty sand (SM). The overall fines content for the entire channel was 6%. All sediment chemical concentrations in the channel composite sample were either non-detect or below NOAA effects-based screening levels (Long et al., 1995). The only contaminant in the channel sediments that was above human health criteria for residential settings was arsenic.

3.0 METHODS

This section describes the dredging design, study design and field and analytical methods for this testing program.

3.1 Dredge Design

Contoured bathymetric data from June of 2015 are shown on Figure 3 and point bathymetric data are shown on Figure 4. These figures also identify the limits of dredging. The design depth for the entire area is -13 ft MLLW. Dredging will most likely occur with a cutterhead suction dredge.

3.2 Study Design

The study design for this project covers data collection tasks for the MCBCP Loading Ramp area.

Evaluation guidelines are also discussed.

The main approach used was to sample dredge sediments to dredge depth plus allowable overdepth, composite the sediments from individual locations into a single sample, and subject the composite sample to chemical testing to determine if the loading ramp sediments are environmentally suitable for beach nourishment. The approach used was to also determine the physical properties of the sediments at each location and at different depths to determine if the physical properties are compatible with the physical properties of the receiving beach. Testing followed requirements and procedures detailed in the ITM (USEPA/USACE, 1998) with further guidance from Los Angeles District USACE guidelines (CESPL, undated) and from SC-DMMT draft guidelines. Acceptability guidelines published in these documents were used to evaluate the suitability of the loading ramp maintenance-dredging sediments for beach nourishment.

3.2.1 Sediment Collection and Chemical Testing

Vibracore sampling, as described in Section 3.3.2 (Vibracore Sampling Methods), was carried out to collect subsurface sediment data at eleven (11) locations adjacent to the MCBCP Loading Ramp.

The prefix for all locations used was “MCBCPBRVC-15-##.” Final sampling locations as well as the proposed locations are shown on Figures 3 and 4. All cores were advanced past the design elevation plus two feet for overdepth allowance (-15 ft MLLW) unless core rejection was encountered. Core rejection occurred for 6 out of the 11 locations after dense fine sand and/or gravel was encountered. Final coordinates, seafloor elevations, and sample elevations for the sample locations are listed in Table 3.

As mentioned, one composite sample was created from the sediments collected from the 11 core locations and analyzed for bulk sediment chemistry. Continuous samples from the mudline to the project depth plus two feet for overdepth (-15 ft MLLW) or to the depth of refusal were collected from all locations. These primary core intervals were homogenized and then combined with primary core intervals from all locations to form the composite sample. Any sediments collected below the overdepth elevation were not included in the sediment composite sample.

Table 3. Actual Sampling Locations, Core Depths, Mudline Elevations, and Sampling Elevations, MCBCP Loading Ramp.

Core Designation Date Sampled

Time Sampled

California Lambert Zone 6 (NAD 83)

Geographic Coordinates (NAD 83) Mudline

Elevation (ft., MLLW)

Design Depth + Overdepth (ft., MLLW)

Core Recovery

(ft.)

Core Intervals Sampled Northing

(feet) Easting

(feet) Latitude

North Longitude

West

MCBCPBRVC15- 1 08/27/15

11:15 2,023,301 6,209,039 33° 12.817' 117° 24.178' -11.0 -15 10.75 -11.0 to -15.0

MCBCPBRVC15- 2 08/27/15 10:15 2,023,277 6,209,028 33° 12.813' 117° 24.180' -9.0 -15 11.0 -9.0 to -15.0 MCBCPBRVC15- 3 08/26/15 13:00 2,023,246 6,209,091 33° 12.808' 117° 24.170' -3.0 -15 11.75 -3.0 to -14.75 MCBCPBRVC15- 4 08/27/15 09:02 2,023,229 6,208,967 33° 12.805' 117° 24.192' -7.0 -15 10.75 -7.0 to -15.0 MCBCPBRVC15- 5 08/26/15 17:45 2,013,187 6,208,991 33° 12.798' 117° 24.187' -1.2 -15 9.2 -1.2 to -10.4

MCBCPBRVC15- 6 08/26/15

14:08 2,023,174 6,209,073 33° 12.796' 117° 24.171' -0.6 -15 10.5 -0.6 to -11.1

MCBCPBRVC15- 7 08/26/15 17:00 2,023,163 6,208,956 33° 12.794' 117° 24.194' -1.1 -15 9.8 -1.1 to -10.9 MCBCPBRVC15- 8 08/26/15 15:08 2,023,144 6,209,007 33° 12.791' 117° 24.184' -1.1 -15 9.75 -1.1 to -10.85 MCBCPBRVC15- 9 08/27/15 08:15 2,023,139 6,208,879 33° 12.790' 117° 24.209' -6.5 -15 9.5 -6.5 to -15.0 MCBCPBRVC15- 10 08/26/15 16:10 2,023,127 6,208,930 33° 12.788' 117° 24.199' -2.0 -15 9.6 -2.0 to -11.6 MCBCPBRVC15- 11 08/27/15 07:30 2,023,104 6,208,827 33°12.784' 117° 24.219' -9.5 -15 11.25 -9.5 to -15.0

In addition to the composite sample, one archive bulk sediment chemistry sample was collected from each core location. One archive sample from each location represented the entire primary core interval (mudline to overdepth elevation). No additional chemical archive samples were formed since no potentially contaminated layers were suspected and there was no significant change in the stratigraphy greater than two feet. All chemical archive samples are being stored frozen and are of sufficient volume to allow for full chemical analyses as described below.

Core subsamples for geotechnical testing were formed from any geo-physically different layer of material not already being analyzed for grain size distribution as described below in Section 3.2.2.

3.2.2 Geotechnical Samples and Testing

A sufficient quantity of sediment was collected from each location within the dredge prism so that a representative amount of sediment was included in each geotechnical sample. A minimum of one primary grain size sample was formed and analyzed from most cores. This sample represents the material from the mudline to the project overdepth elevation (-15 ft MLLW) or the elevation of refusal.

Additional grain size samples representing layers of physically different material greater than six inches thick were selected amongst all the cores and also tested as needed or archived (set aside). Some of the finer-grained samples also underwent hydrometer analyses. Decisions on which samples to be analyze were made with input from the USACE Project Technical Manager.

All grain size analyses were run mechanically according to ASTM D 422 (1963). In addition to the mechanical grain size samples, three (3) hydrometer tests were run according to ASTM D 422 and one

(1) Atterberg Limits test was run according to ASTM D 4318 (2005). The hydrometer tests were run on three samples with greater than 10% fine grained material. The lone Atterberg Limits test was run on a clayey sample taken around -20 MLLW. Since this sample is for informational purposes only and was taken below the allowable overdepth elevation, it is not part of the dredge material evaluation. The Atterberg Limits data for this sample are only shown in Appendix E.

All geotechnical data gathered were used to do physical beach compatibility analyses between the dredged sediments and the receiving beach. This task was accomplished by USACE-Los Angeles District and is included as Appendix A to this report. Receiving beach data used by the Corps was data from Oceanside City Beach and Pier View Way Beach transect obtained during the 2012 dredge material evaluation of the Oceanside Harbor federal channels (Diaz-Yourman, GeoPentech and Kinnetic Laboratories JV, 2012). For this study, grain size samples were collected along four transects perpendicular to the receiving beaches at elevations approximately +12, +6, 0, -6, -12, -18, -24 and -30 feet MLLW. Approximate locations of these transects are depicted on Figure 5.

3.2.3 Summary of Testing and Evaluation Sequence

The testing and evaluation sequence for the MCBCP Loading Ramp samples is described in detail in the next subsection and is outlined as follows:

1) Bulk sediment chemical analyses was conducted on a single composite sample.

2) Grain size physical compatibility analyses was conducted by the Los Angeles District U.S. Army

Corps of Engineers Geotechnical Branch.

3) Analytical results were evaluated using the sediment quality guidelines consisting of Effects Range Low (ERL) and Effects Range Medium (ERM) values developed by Long, et al. (1995) that correlates concentrations of selected contaminants with likelihood of adverse biological effects. Table 4 lists available ERL and ERM values. Please note that ERLs and ERMs have not been developed for all analytes.

4) Analytical results were also evaluated using the USEPA’s RSL (Regional Screening Levels) and the State of California’s CHHSL (California Human Health Screening Levels) for potential effects to humans (Cal/EPA, 2005). Table 4 lists the available RSL and CHHSL values.

If grain size characteristics are compatible with the receiving beaches and contaminant levels are low compared to lower effects based screening levels and human health screening levels, then the sediments should be suitable for beach nourishment and no further testing is required.

3.2.4 Evaluation Guidelines

Grain size is the primary variable in determining whether the MCBCP Loading Ramp sediments are suitable for beach nourishment. Grain size suitability determination was conducted by the LA District Corps according to Los Angeles District USACE guidelines (CESPL, undated). These guidelines are the same as the SCOUP (Sand Compatibility and Opportunistic Use Program). Specifically, the following criteria were used in determining whether sediments from the composite area was suitable for placement at the receiving beach:

• Mean gradation curves of the loading ramp dredge material must not be strikingly dissimilar to the mean gradation curve of the receiving beach. Furthermore, the composite curves of the loading ramp dredge material should, for the most part, fall within the beach compatibility envelope as defined by the fine and coarse limits.

• The percentage of fine grain material (<0.074 mm) shall not exceed that of the finest beach sample from the receiving beach by more than ten percentage points.

As mentioned above, to aid in the evaluation of sediment test data, chemical concentrations of contaminants found within the sediments were compared to sediment quality guidelines (Long et. al., 1995) developed by NOAA (Table 4). These guidelines were used to screen sediments for contaminant concentrations that might cause biological effects. For any given contaminant, ERL guidelines represent the 10th percentile concentration value in the NOAA database that might be expected to cause adverse biological effects and ERM guidelines reflect the 50th percentile value in the database. Note that ERLs and ERMs were only used as a screening tool. They were not used to determine suitability.

Figure 5. Location of the 2012 Sampling Transects at Oceanside City Beaches.

2102 Trans. A 2012 Trans. B 2012 Trans. C 2012 Trans. D

O ceanside C ity B each

N ourishm ent A rea

Pier V iew

W ay B each N ourishm ent A rea

Table 4. MCBCP Loading Ramp Sediment Screening Values for Selected Analytes.

Analyte Name Units NOAA Screening1 Human RSLs2 Human CHHSLs3

Salt

ERL

Salt ERM Residential Industrial Residential Commercial/

Industrial Arsenic mg/kg 8.2 70 0.68 3.0 0.07 0.24 Cadmium mg/kg 1.2 9.6 70 800 1.7 7.5 Chromium mg/kg 81 370 100,000 1,000,000 Copper mg/kg 34 270 3,100 47,000 3,000 38,000 Lead mg/kg 46.7 218 400 800 18 180 Mercury mg/kg 0.15 0.71 9.4 40 1,600 16,000 Nickel mg/kg 20.9 51.6 1,500 22,000 1,600 16,000 Selenium mg/kg 390 5,800 380 4,800 Silver mg/kg 1 3.7 390 5,800 380 4,800 Zinc mg/kg 150 410 23,000 350,000 23,000 100,000 Di- Tri-butyltin µg/kg 19,000 250,000 1-Methylnaphthalene µg/kg 18,000 73,000 2-Methylnaphthalene µg/kg 70 670 240,000 3,000,000 Acenaphthene µg/kg 16 500 3,600,000 45,000,000 Acenaphthylene µg/kg 44 640 Anthracene µg/kg 85.3 1100 18,000,000 23,000,000 Benzo (a) Anthracene µg/kg 261 1600 160 2,900 Benzo (a) Pyrene µg/kg 430 1600 16 290 38 130 Benzo (b) Fluoranthene µg/kg 160 2900 Benzo (k) Fluoranthene µg/kg 1,600 29,000 Biphenyl µg/kg Chrysene µg/kg 384 2800 16,000 290,000 Dibenz (a,h) Anthracene µg/kg 63.4 260 16 290 Fluoranthene µg/kg 600 5100 2,400,000 30,000,000 Fluorene µg/kg 19 540 2,400,000 30,000,000 Indeno (1,2,3-c,d) Pyrene µg/kg 160 2,900 Naphthalene µg/kg 160 2100 3,800 17,000 Phenanthrene µg/kg 240 1500 Pyrene µg/kg 665 2600 1,800,000 23,000,000 Total Low Weight PAHs µg/kg 552 3160 Total High Weight PAHs µg/kg 1700 9600 Total PAHs4 µg/kg 4022 44792 Benzyl butyl phthalate µg/kg 63,000,000 820,000,000 bis-(2-Ethylhexyl)phthalate µg/kg 39,000 160,000 Diethyl phthalate µg/kg 51,000,000 660,000,000 Di-n-butyl phthalate µg/kg 6,300,000 82,000,000 2,4,6-Trichlorophenol µg/kg 49,000 210,000 2,4-Dichlorophenol µg/kg 190,000 2,500,000 2,4-Dimethylphenol µg/kg 1,300,000 16,000,000 2,4-Dinitrophenol µg/kg 130,000 1,600,000 2-Chlorophenol µg/kg 390,000 5,800,000 Bisphenol A µg/kg 3,200,000 41,000,000 Pentachlorophenol µg/kg 1,000 4,000 4,400 13,000 Phenol µg/kg 19,000,000 250,000,000 4,4'-DDD µg/kg 2 20 2,300 9,600 2,300 9,000 4,4'-DDE µg/kg 2.2 27 2,000 9,300 1,600 6,300 4,4'-DDT µg/kg 1 7 1,900 8,500 1,600 6,300 Total DDT µg/kg 1.58 46.1 Aldrin µg/kg 39 180 33 130

Table 4. MCBCP Loading Ramp Sediment Screening Values for Selected Analytes.

Analyte Name Units NOAA Screening1 Human RSLs2 Human CHHSLs3

Salt

ERL

Salt ERM Residential Industrial Residential Commercial/

Industrial Chlordane µg/kg 1,700 7,500 430 1,700 Cis-nonachlor µg/kg DCPA (Dacthal) µg/kg 0.02 8 630,000 8,200,000 Dieldrin µg/kg 34 140 35 130 Endosulfan I µg/kg 470,000 7,000,000 Endrin µg/kg 19,000 250,000 21,000 230,000 Heptachlor µg/kg 130 630 130 520 Heptachlor Epoxide µg/kg 14 70 BHC-gamma (Lindane) µg/kg 570 2,500 Methoxychlor µg/kg 320,000 4,100,000 340,000 3,800,000 Mirex µg/kg 36 170 31 120 Toxaphene µg/kg 490 2,100 460 1,800 Biphenthrin µg/kg 950,000 12,000,000 cis-/trans-Permethrin µg/kg 3,2000,000 41,000,000 Cypermethrin µg/kg 630,000 8,200,000 Fenpropathrin µg/kg 1,600,000 21,000,000 Fluvalinate µg/kg 630,000 8,200,000 PCB077 µg/kg 38 160 PCB081 µg/kg 12 49 PCB105 µg/kg 120 500 PCB114 µg/kg 120 500 PCB118 µg/kg 120 500 PCB123 µg/kg 120 500 PCB126 µg/kg 0.037 0.15 PCB156 µg/kg 120 510 PCB157 µg/kg 120 510 PCB167 µg/kg 120 510 PCB169 µg/kg 0.12 0.51 PCB189 µg/kg 120 510 Total PCB Congeners µg/kg 22.7 180 89 300

1. Effects Range Low (ERL) and Effects Range Median (ERM) sediment quality objectives from Long et al. (1995).

2. Regional Screening Levels for Chemical Contaminants at Superfund Sites" (USEPA Region 9, 2010, updated 2015).

3. California Human Health Screening Levels for Soil (Cal/EPA, 2005, updated 2010).

As an additional measure of potential toxicity, the mean ERM quotient (ERMq) for the composite sample was calculated according to Long et al. (1998a) and Hyland et al. (1999). ERMq is calculated by dividing each contaminant concentration by its respective ERM value and then summing the results and dividing through by the number of contaminants as shown in the following equation:

∑= ERM

entrationSampleConc

1tERMQuotien

In cases where concentrations of measured contaminants are below the method detection limit (MDL), a value of ½ the MDL was used for the ERMq calculations. For a general overall indication of toxicity, a quotient less than 0.1 is indicative of a low probability (<12%) of a highly toxic response to marine amphipods (Long and MacDonald, 1998b). If there are no ERL exceedances in a sample, there is less than a 10% probability of a highly toxic response to marine amphipods. The probability of a highly toxic response increases to 71% for quotients greater than 1.0.

The dredge material was also assessed to whether or not it is suitable for human contact. To do so, the chemical results were compared to “Regional Screening Levels for Chemical Contaminants at Superfund Sites" (USEPA Region 9, 2010, updated 2015), formerly known as Preliminary Remediation Goals (PRGs). These screening levels (RSLs) were developed for Superfund/RCRA programs and are a consortium of USEPA Region 9 PRGs, USEPA Region 3 RBCs and EPA Region 6 Human Health Medium – Specific Screening Levels (HHMSSLs). RSLs are risk-based concentrations derived from standardized equations combining exposure information assumptions with EPA toxicity data. RSLs are considered by the USEPA to be protective for humans (including sensitive groups) over a lifetime. However, RSLs are not always applicable to a particular site and do not address non-human health endpoints, such as ecological impacts. The RSLs in Table 4 have been calculated without site-specific information. They are used for site "screening" and as initial cleanup goals. RSLs are not cleanup standards and were not applied as such. The RSL's primary role in site "screening" is to help identify areas, contaminants, and conditions that require further federal attention at a particular site, and is also useful in determining risks to human exposure at non-superfund sites. RSLs may be lower than the California Title 22 Total Threshold Limit Concentration (TTLC) values, but often are much higher. Material with excessive RSL exceedances should be re-used as buried fill instead of topsoil provided it can be shown that the material will not leach contaminants at detrimental concentrations into groundwater and receiving waters.

Human health risks were also evaluated using California Human Health screening Levels (CHHSLs). CHHSLs (Cal/EPA, 2005) are concentrations of 54 hazardous chemicals in soil or soil gas that are considered to be protective of human health. The CHHSLs were developed by the Office of Environmental Health Hazard Assessment (OEHHA) on behalf of Cal/EPA.

CHHSLs were developed using standard exposure assumptions and chemical toxicity values published by the USEPA and Cal/EPA. CHHSLs listed in Table 4 were developed separately for industrial/commercial settings and for residential settings. The Table 4 CHHSLs were updated in September 2010.

3.3 Field Sampling Protocols

Vibracore sampling, decontamination, sample processing and documentation procedures are discussed in this section.

3.3.1 Positioning and Depth Measurements

Positioning at sampling locations was accomplished using a differential GPS (DGPS) navigation system referenced to a local geodetic benchmark with positioning accuracies of 3 to 10 feet. The locations were recorded in both Geographic coordinates (NAD 83) and State Plane Coordinates (CA Zone VI, NAD 83). Water depths were measured with a graduated lead line and corrected to mean lower low water (MLLW). Tidal stage was determined using NOAA predicted tide tables within the DGPS unit. These tables were used to calculate the seafloor elevation/mudline for each site.

3.3.2 Vibracore Sampling Methods

All MCBCP Loading Ramp dredge footprint sediment samples were collected using an electric vibracore. The cores were taken to the target sampling elevation (project elevation plus two feet for overdepth allowance plus three feet for geotechnical purposes) or to refusal. The depth of refusal was defined as the depth at which penetration stopped for a two (2) minute period. Based on the composition of the tip material leading to core refusal, it seemed very unlikely that additional attempts would lead to longer cores and thus no additional attempts were made. At the conclusion of a successful vibracore, the core liner was removed and split open for inspection and sampling. Extrusion of the cores was not be allowed. Processing took place onshore.

Vibracore sampling at the MCBCP Loading Ramp was carried out from a Kinnetic Laboratories portable barge. This 14-foot X 10-foot vessel is equipped with a quadrapod frame and winch suitable for handling coring equipment. A 17-foot Boston Whaler was used to position the barge and transport sediment core samples to the onshore processing area. The barge was secured for coring at each location using retractable spuds.

Kinnetic Laboratories’ vibracore consists of a 4-inch diameter aluminum coring tube, a stainless steel cutting tip, and a stainless-steel core catcher. Inserted into the core tubes was food-grade clean polyethylene liners. The vibrating unit has two counter-rotating motors encased in waterproof aluminum housing. A three-phase, 240-volt generator powered the motors. The vibracore head and tube were lowered overboard with the quadrapod through a moon pool. The unit was then vibrated until it reached target sampling elevation or until the depth of refusal was reached.

When penetration of the vibracore was complete, power was shut off to the vibra-head, and the vibracore was brought aboard the vessel. A check valve located on top of the core tube reduced or prevented sediment loss during pull-out. The core tube was then detached from the vibra-head, and the core cutting tip and catcher were removed. Afterwards, the core liners were removed and sealed on both ends and transported to the onshore processing area.

3.3.3 Vibracore Decontamination

All sample contact surfaces were stainless steel, polyethylene or Teflon® coated. Compositing tools were stainless steel or Teflon® coated stainless steel. Except for the core liners, all contact surfaces of the sampling devices and the coring tubes were cleaned for each sampling location.

The cleaning protocol consisted of a site water rinse, a Micro-90 laboratory soap wash, and then finished with deionized water rinses. The polyethylene core liners were new and of food grade quality. All rinseate was collected in containers and disposed of properly.

3.3.4 Core Processing

Whole cores were processed onshore on top of tables. The tables had a plastic covering that was freshly changed for every core. Cores were placed in a PVC core rack that was cleaned between cores. After placement in the core rack, core liners were split lengthwise to expose the recovered sediment. Once exposed, sediment that came in contact with the core liner was removed by scraping with a pre-cleaned stainless steel spoon. Each core was photographed, measured, and lithologically logged in accordance with the Unified Soil Classification System (USCS) as outlined in ASTM Standards D-2488 (2006) and D-2487 (2006). Additional sediment characteristics including likely sediment origin and other observations were also recorded. A geologist from Diaz-Yourman and Associates did the lithologic logging along with collection of sample splits for geotechnical testing.

Photographs were taken of each core (each photograph covers a maximum two-foot interval).

These pictures are included as Appendix B of this report with captions describing the subject and date.

Following logging, vertical composite subsamples were then formed from each core and samples for grain size analyses were formed. The primary vertical composite subsamples were from the mudline to project depth plus two feet below project depth or depth of refusal. Primary vertical composite subsamples were used to form the area composite sample for chemical testing. An archived sample was formed from each primary vertical composite subsample. Since there were no distinct geologic stratification greater than two feet nor layers of suspected contamination in the cores, no additional archive samples were collected. Distinct geologic strata greater than eight inches in length were analyzed or archived for grain size.

Vertical composite subsamples were formed by combining and homogenizing a representative sample from each primary core interval, as described above, in a pre-cleaned stainless steel or Teflon®-coated tray. A 1-liter portion of each primary vertical composite subsample was placed in a pre-cleaned and certified glass jar with a Teflon®-lined lid for archived material (Ziploc bags for grain size samples). The remaining portion of each primary vertical composite subsample within each sampling interval identified for composite sample formation was placed in another pre-cleaned tray for area compositing with all other cores from the dredge area. All samples for grain size analyses were transferred to pre-labeled sample containers (sealed plastic bags) and stored appropriately and ultimately transferred to Diaz-Yourman and Associates for analysis.

Except for archival material for chemical analyses, containers were completely filled to minimize air bubbles being trapped in the sample container. A small amount of headspace was allowed for samples archived for potential chemical analyses to prevent container breakage during freezing.

For the preservation of the sediment composite sample for chemical analyses, the filled container was placed on ice immediately following sampling and maintained at 2 to 4°C until analyzed.

Archived samples for chemical analyses were placed on ice initially and then frozen as soon as possible. The sample containers were sealed to prevent any moisture loss and possible contamination.

3.3.5 Detailed Soils Log

A detailed soils log was prepared for each sampling location. These logs include the project name, hole number or designation, date, time, location, water depth, estimated tide, mudline elevation, type and size of sampling device used, depth of penetration, length of recovery, name of person(s) taking samples, depths below mudline of samples, and a description and condition of the sediment.

Descriptions of the sediments were conducted in accordance with ASTM D 2488 (2006), and include as a minimum: grain size, color, maximum particle size, estimation of density (sand) or consistency (silts and clays), odor (if present), and description of amount and types of organics and trash present. In cohesive soils, a pocket penetrometer and miniature vane shear device (torvane) was used to collect estimated strength/consistency data. Copies of the soils logs are included as Appendix C to this report.

3.3.6 Documentation and Sample Custody

All sample containers were physically marked as to sample location, date, time and analyses. All samples were handled under Chain of Custody (COC) protocols beginning at the time of collection.

Samples were considered to be “in custody” if they are (1) in the custodian’s possession or view,

(2) in a secured place (locked) with restricted access, or (3) in a secure container. Standard COC procedures were used for all samples collected, transferred, and analyzed as part of this project.

COC forms were used to identify the samples, custodians, and dates of transfer. Except for the shipping company, each person who has custody of the samples signed the COC form and ensured samples were stored properly and not left unattended unless properly secured.

Standard information on Chain of Custody forms includes:

• Sample Identification

• Sample Collection Date and Time

• Sample Matrices (e.g., marine sediment)

• Analyses to be Performed

• Container Types

• Preservation Method

• Sampler Identification

• Dates of Transfer

• Names of Persons with Custody

Completed COC forms (for both the composite samples and archive samples) were placed in sealable plastic bags that were placed in the cooler with the samples. Copies of the COC forms are included with the laboratory reports in Appendix D of this report. Redundant sampling data were also recorded on field data log sheets. Copies of the field data logs are included in this report as Appendix E.

As described in Sections 3.3.5, detailed soil logs were prepared from each sampling location.

These soil logs are an integral part of this report.

3.4 Laboratory Testing Methods

Analytical chemistry testing of sediments for this project was primarily carried out by Calscience Laboratories; a State certified testing laboratory (Cal-ELAP No. 03220CA) using USEPA and USACE approved methodologies. Extraction and analysis of the sediments occurred between the period of August 28 and September 12, 2015. Diaz-Yourman and Associates carried out all geotechnical analyses during the period of October 1 to October 30, 2015.

3.4.1 Geotechnical Testing

Sieve analyses and hydrometer testing were performed according to ASTM D 422 (1963), and Atterberg Limits were determined according to ASTM D 4318 (2005). Required U.S. standard sieve sizes included No. 4, 7, 10, 14, 18, 25, 35, 45, 60, 80, 120, 170, 200, and 230 sieves. All sediment samples were classified in accordance with the Unified Soil Classification System (ASTM D 2487-06 and ASTM D 2488-06). Grain size compatibility of the proposed dredge material with the receiving beach was evaluated by the Los Angeles District USACE. Note that ASTM D 422 for grain size is similar to but deviates from the method by Plumb (1981) specified in the draft SC-SMMT guidance document.

3.4.2 Bulk Sediment Chemical Analyses

The single composite sample collected from the MCBCP Loading Ramp was analyzed for the parameters and quantification limits specified in Table 5. The results are reported in dry weight unless noted otherwise. All analyses were conducted in a manner consistent with guidelines for dredge material testing methods in the USEPA/USACE Inland Testing Manual. Samples were extracted and analyzed within specified USEPA holding times, and all analyses were accomplished with appropriate quality control measures.

Discrete samples from each location were archived frozen for at least 180 days from collection.

Additional direction will be provided for analysis, if required.

There are a few method deviations from those listed in the draft SC-DMMT guidelines. These method deviations were detailed in the project SAP. One deviation is chlorinated pesticides were analyzed by use of USEPA method 8270C (SIM) rather than EPA method 8081A.

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