NCS000290_11_Camp Lejeune Approved Monitoring Plan_20130509

BcAl'i AH Euvtt onme itl EnPimaim. Pt
TO: Steven Whited
Environmental Management Division
Marine Corps Installations East - Marine Corps Base Camp Lejeune
Camp Lejuene, NC 28542
CC: David Cotnoir, PE
Naval Facilities Engineering Command
Mid -Atlantic Division
Norfolk, VA 23511
FROM: Brandon C. Ashton, PE
David H. Lee, PE
AH Environmental Engineering, PC
DATE: April 18, 2013
RE: Technical Memorandum
2013 Stormwater Outfall Monitoring Plan (SWOMP) Update
Note: This document refers to Marine Corps Installations East (MCIEAST) - Marine Corps Base
(MCB) Camp Lejeune and Marine Corps Air Station (MCAS) New River collectively as Camp
Lejeune.
The purpose of this memorandum is to inform the North Carolina Department of Environmental
and Natural Resources (NCDENR), Division of Water Quality (DWQ) of updates to the Camp
Lejeune SWOMP (2013) — specifically, proposed revisions to analytical and qualitative
monitoring locations and analytical sampling parameters.
National Pollutant Discharge Elimination System (NPDES) permit number NCS000290 issued
by NCDENR DWQ on April 1, 2011 requires that Camp Lejeune implement a stormwater outfall
monitoring program to assess the effectiveness of its stormwater management programs and
practices. The NPDES permit calls for qualitative monitoring of all stormwater outfalls that
receive runoff from facilities engaging in regulated industrial activities as defined by Title 40 of
the US Code of Federal Regulations (CFR) 122.26 (b)(14). In addition, the permit requires
analytical monitoring at representative stormwater outfalls with characteristics that typify
industrialized outfalls at Camp Lejeune. The SWOMP, a supporting document to Camp
Lejeune's Stormwater Pollution Prevention Plan (SWPPP), was developed to help Camp
Lejeune fulfill the monitoring requirements defined by their NPDES permit. The SWPPP
identifies facilities engaging in regulated industrial activity and the outfalls receiving stormwater
runoff from such facilities (i.e. the outfalls which require monitoring).
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Technical Memorandum
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The March 2013 update to the SWPPP identified 173 facilities currently engaging in regulated
industrial activity and 74 stormwater outfalls receiving runoff from these facilities. The previous
SWPPP (2002) identified 65 such outfalls. This technical memorandum summarizes the
proposed revisions to both analytical and qualitative stormwater monitoring locations found in
the 2013 update to Camp Lejeune's SWOMP, including:
• Designation of different outfalls for analytical sampling for enhanced monitoring
• Removal of existing visual observation points (VOPs) due to reclassification of outfalls
from "industrial" to "non -industrial"
• Relocation or modification of existing VOPs for enhanced monitoring or due to physical
changes at the monitoring location
• Creation of new VOPs as a result of new industrial activity.
Representative Analytical Sampling
Analytical sampling is required at representative outfalls with water quality characteristics that
typify industrialized outfalls at Camp Lejeune. These outfalls should receive stormwater runoff
from drainage basins that encompass typical industrial activity occurring at Camp Lejeune.
Table 1 specifies which representative industrialized outfalls currently serve as the analytical
sampling points (from NPDES permit). Table 2 contains the representative industrialized outfalls
for analytical sampling that Camp Lejeune proposes for approval, which are based on the
results of the 2012 SWPPP field assessments and the 2013 SWOMP update.
Table 1 Existing Representative Outfalls for Analytical Monitoring'
Base Area
Air Station
Representative
Outfall (Analytical
Sampling Point
OAS-004
Air Station
OAS-018
Camp Geiger
OTC-001
Camp Geiger
OTC-003
Hadnot Point
OHP-020
Hadnot Point
�WallaceCreek
OHP-022
OWF-001
Industrial Activities
Represented
Ground transportation operations; bulk fuel
storage and transfer
Air transportation operations
N/A2
Warehousing and storage; bulk fuel storage
and transfer
Printing and publishing
Hazardous material treatment, storage, or
disposal: warehousina and storaae
Hazardous material treatment, storage, or
disposal
Note:
1) Outfalls designated as analytical sampling points must also be visually monitored.
2) Not Applicable - No regulated industrial activities were observed within outfall OTC-001 during the 2012 SWPPP
field assessments. The VOP associated with this outfall will also be removed as a result of the 2013 SWPPP and
SWOMP updates.
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2013 SWOMP Update Page 3 of 9
Table 2 Proposed Representative Outfalls for Analytical Monitoring'
Representative
Industrial Activities
Base Area
Outfall (Analytical
Represented
Sampling Point
Air transportation operations; ground
transportation operations; hazardous material
Air Station
OAS-005
treatment, storage, or disposal; bulk fuel
storage and transfer; warehousing and
storage; recycling and scraps/salvage; wood
products manufacturing
Air transportation operations
Air Station
OAS-018
Camp Geiger
OTC-003
Warehousing and storage; bulk fuel storage
and transfer
Frenchs Creek
OFC-003
Ground transportation operations
Hadnot Point
OHP-004
Ground transportation operations
Ground transportation operations;
Hadnot Point
OHP-008
warehousing and storage; recycling and
scraps/salvage; wood product manufacturing
Wallace Creek
OWC-001
Ground transportation operations
Note:
1) Outfalls designated as analytical sampling points must also be visually monitored.
Analytical sampling points associated with the industrialized outfalls OAS-018 and OTC-003
were identified in the November 2005 SWOMP and are not proposed for modification in the
2013 SWOMP update.
The November 2005 SWOMP identified an analytical sampling point associated with the outfall
OAS-004. This outfall receives stormwater runoff from a drainage basin that is typical of MCAS;
however, the outfall's physical characteristics (wide channel lined with large rip -rap) are not
conducive to water quality sampling. The first flush of stormwater runoff cannot be captured;
therefore, the 2013 SWOMP update proposes OAS-004 be removed from the analytical
sampling points.
The November 2005 SWOMP identified an analytical sampling point associated with the outfall
OHP-020; however, the only industrial activity within the drainage basin of OHP-020 is a small
printing and publishing shop. This activity does not typify industrial activity occurring at Hadnot
Point; therefore, the 2013 SWOMP update proposes OHP-020 be removed from the analytical
sampling points.
The November 2005 SWOMP identified an analytical sampling point associated with the outfall
OHP-022. This outfall receives stormwater runoff from a drainage basin that is typical of Hadnot
Point; however, the outfall's physical characteristics (rip -rap lined channel with vegetative lining)
are not conducive to water quality sampling. The first flush of stormwater runoff cannot be
captured effectively; therefore, the 2013 SWOMP update proposes OHP-022 be removed from
the analytical sampling points.
The November 2005 SWOMP identified an analytical sampling point associated with the outfall
OTC-001. This outfall no longer receives stormwater runoff from any facilities engaging in
regulated industrial activity; therefore, the 2013 SWOMP update proposes OTC-001 be
removed from the analytical sampling points.
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The November 2005 SWOMP identified an analytical sampling point associated with the outfall
OWF-001. This outfall's physical characteristics (wide, shallow vegetated swale receiving flow
from a small rain garden) are not conducive to water quality sampling. Furthermore, the facility
contributing runoff to this outfall, while still engaging in regulated industrial activity, has modified
its activity from Defense Logistics Agency Disposition Services to pesticides storage. The
current industrial activity does not represent typical industrial activity occurring within the
Wallace Creek drainage basin; therefore, the 2013 SWOMP update proposes OWF-001 be
removed from the analytical sampling points.
Refer to Section 4.1 of the 2013 SWOMP update for maps and photos of each proposed
analytical sampling point. Refer to Section 4.2 for maps and photos of the analytical sampling
points proposed for removal at OAS-004, OHP-020, OHP-022, OTC-001, and OWF-001.
Visual Observation Points
VOPs are required for each outfall that receives stormwater runoff from a facility engaging in
regulated industrial activity. Table 3 contains the updated VOPs (identified in the 2013 SWOMP
update) associated with industrialized outfalls that were identified in the March 2013 update to
the SWPPP.
Table 3 Updated Visual Observation Points
Base Area
Visual Observation Points'
Amphibious Base AB
OAB-001. OAB-002, OAB-003, OAB-006, OAB-007
OAS-001, OAS-002, OAS-003, OAS-004, OAS-005,
Air Station (AS)
OAS-006, OAS-014A, OAS-014B, OAS-018, OAS-021,
OAS-030, OAS-032
Camp Geiger (TC)
OTC-003, OTC-004, OTC-005, OTC-008
Camp Johnson CJ
OCJ-001, OCJ-004A, OCJ-004B
Courthouse Bay CB
OCB-001, OCB-013, OCB-014
OFC-001, OFC-002, OFC-003, OFC-004, OFC-005,
Frenchs Creek (FC)
OFC-006A, OFC-00613, OFC-006C, OFC-008,
OFC-009, OFC-012, OFC-013, OFC-026, OFC-027
OHP-001, OHP-002A, OHP-002B, OHP-003, 0HP-0041
OHP-005, OHP-006A, OHP-006B, OHP-006C,
OHP-008, OHP-010, OHP-011, OHP-012, OHP-013A,
Hadnot Point (HP)
OHP-013B, OHP-015, OHP-017, OHP-018A,
OHP-018B, OHP-019A, OHP-019B, OHP-019C,
OHP-019D, OHP-020, OHP-021A, OHP-021B,
OHP-022, OHP-024, OHP-035, OHP-038
Landfill LF
OLF-001, OLF-002
Naval Hospital NH
ONH-001, ONH-002
Old Hospital (OH)
OOH-001
Rifle Range RR
ORR-001, ORR-003, ORR-012, ORR-013, ORR-014
Sandy Run (SR)
OSR-001
Wallace Creek (WC)
OWC-001, OWC-002, OWC-003, OWF-001, OWF-002
Note:
1) VOPs associated with industrialized outfalls that were not identified in the November 2005 SWOMP (i.e., new
VOPs) are shown in bold. VOPs already identified in the November 2005 SWOMP are not bolded.
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Table 4 lists the VOPs that have not been modified as a result of the 2013 updates to the
SWPPP and SWOMP.
Table 4 2005 VOPs (unmodified in 2013)
Base Area
Visual Observation Points
Amphibious Base (AP)
OAB-001. OAB-002, OAB-003, OAB-006
OAS-001, OAS-002, OAS-003, OAS-004, OAS-005,
Air Station (AS)
OAS-014A, OAS-014B, OAS-0181, OAS-021, OAS-030,
OAS-032
Camp Geiger TC
OTC-003
OCJ-001, OCJ-004A, OCJ-004B
Camp Johnson CJ
Courthouse Bay CB
None
Frenchs Creek (FC)
OFC-001, OFC-002, OFC-003, OFC-004, OFC-005,
OFC-006A, OFC-006B, OFC-012
OHP-001, OHP-002, OHP-003, OHP-004, OHP-005,
Hadnot Point (HP)
OHP-008, OHP-010, OHP-011, OHP-013A, OHP-013B,
OHP-015, OHP-019A, OHP-019B, OHP-019C, OHP-019D,
OHP-020, OHP-021A, OHP-021B, OHP-022, OHP-024
Landfill LF
OLF-001
Naval Hospital NH
ONH-001
Old Hospital OH
OOH-001
Rifle Range RR
ORR-001
Sandy Run SR
None
OWF-001
Wallace Creek (WC)
Note:
1) There are two VOP markers for ONH-001 in different locations. One of these markers will be removed.
The following are VOPs identified in the 2005 SWOMP whose associated outfalls no longer
receive stormwater runoff from facilities engaging in regulated industrial activities and will be
removed as a result of the 2013 updates to the SWPPP and SWOMP:
• OAB-005
• OCJ-002
• OCJ-003
• OFC-007
• OHE-001
• OHP-007
• OHP-014
• OHP-016
• OOH-002
• OPP-001
Table 5 contains VOPs associated with industrialized outfalls that were identified in the
November 2005 SWOMP that will be modified as a result of the 2013 updates to the SWPPP
and SWOMP, including descriptions of the modifications.
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Table 5 Modifications to Existing Visual Observation Points
2005 VOPs Modification
OCB-001 VOP for OCB-001 was relocated further downstream to
capture more of the drainage basin.
Stormwater runoff at this location consists of runoff from the
OFC-008
drainage basins of OFC-008 & OFC-009. VOPs for these two
outfalls were relocated further upstream to differentiate.
OFC-009
VOP for OFC-009 was relocated further upstream to
differentiate from OFC-008.
Two additional VOPs were added to OHP-006 for enhanced
OHP-006
monitoring.
OHP-012
VOP for OHP-012 was relocated further downstream to
capture more of the drainage basin runoff.
[OHP-018
One additional VOP was added to this outfall for enhanced
monitoring.
OTC-004
Location of existing VOP could not be verified due to
construction in the area; a new VOP was established.
Table 6 contains new VOPs associated with industrialized outfalls that were not identified in the
November 2005 SWOMP, but are included in the 2013 SWOMP update. The associated outfalls
have either been reclassified from "non -industrial" to "industrial" or are outfalls that have been
recently delineated.
Table 6 New Visual Observation Points
Base Area
Visual Observation Points
Amphibious Base AB
OAB-007
Air Station AS
OAS-006
Camp Geiger TC
OTC-005, OTC-008
Camp Johnson CJ
None
Courthouse Bay CB
OCB-013, OCB-014
Frenchs Creek FC
OFC-006C, OFC-013, OFC-026, OFC-027
Hadnot Point (HP)
OHP-00613, OHP-006C, OHP-017, OHP-01813,
OHP-035, OHP-038
Landfill LF
OLF-002
Naval Hospital NH
ONH-002
Old Hospital OH
None
Rifle Range RR
ORR-003, ORR-012, ORR-013, ORR-014
Sandy Run SR
OSR-001
Wallace Creek WC
OWC-001, OWC-002, OWC-003, OWF-002
Refer to Section 5.1 of the 2013 SWOMP update for maps and photos of the updated VOPs.
Refer to Section 5.2 for maps and photos of the VOPs that were removed or modified as a
result of the 2013 updates to the SWPPP and SWOMP.
AH Environmental Engineering, PC

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Removal of Analytical Sampling Parameter (Vinyl Chloride)
Camp Lejeune's current NPDES permit (NCS000290) requires annual analytical monitoring for
vinyl chloride at each representative outfall. Camp Lejeune proposes to remove vinyl chloride
from the required analytical parameters at the representative stormwater outfalls. Justification
for removal of vinyl chloride is discussed below.
In addition to the requirements stated in Camp Lejeune's NPDES permit, the permit also
requires compliance with the North Carolina general permits listed below. There are no
requirements for vinyl chloride monitoring in these general permits.
- NCG010000
-Construction Activities
- NCG080000
- Vehicle Maintenance Areas
- NCG110000
-Treatment Works (Wastewater)
- NCG150000
-Air Transportation Facilities.
The following pertinent passages are quoted from the Toxicology Profile for Vinyl
Chloride, written by the Toxic Substances and Disease Registry (U.S. Department of
Health and Human Services, Public Health Service Agency):
- "The major source of vinyl chloride releases to the environment is believed to be
emissions and effluents from plastic industries, primarily vinyl chloride and PVC
manufacturers."
- "Vinyl chloride has been identified in at least 622 of the 1,662 hazardous waste
sites that have been proposed for inclusion on the EPA National Priorities List
(NPL) (HazDat 2005)."
- "Vinyl chloride was detected in groundwater at 538 of the 1,662 current or former
EPA NPL hazardous waste sites, and in surface water at 110 of the 1,662 current
or former EPA hazardous waste sites (HazDat 2005).
- "In the vicinity of hazardous waste sites, a significant source of vinyl chloride may
originate from the bacterial degradation of chlorinated solvents such as
trichloroethylene, tetrachloroethylene, and 1,1,1-trichloroethane, rather than
industrial sources."
- "According to data collected from the analysis of leachates and monitoring wells
at sites where groundwater has been contaminated by municipal solid waste
landfill leachate, vinyl chloride was present in both the leachates and
groundwater samples (Sabel and Clark 1984). Vinyl chloride has been found in
groundwater at other landfills also (Agency for Toxic Substances and Disease
Registry 1995a, 1995b)."
- "In the United States, limited quantities of vinyl chloride were used as an aerosol
propellant and as an ingredient of drug and cosmetic products; however, these
practices were banned by the EPA in 1974 (HSDB 2005; IARC 1979)."
In summary, the Toxicology Profile for Vinyl Chloride considers plastic industries,
hazardous waste sites, and landfills as the current primary sources of vinyl chloride
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releases to the environment. No other industrial activities were specifically identified in
the toxicology report.
• Table 7 presents a summary of annual representative outfall analytical monitoring results
from 2008 to present (results for vinyl chloride only).
Table 7 Summary of Vinyl Chloride Monitoring Results
Representative
Outfall
OAS-004
Vinyl Chloride
Analytical Results'
2008
< 1.0 pc
< 1.0 pc
2012
< 0.5 pg/L
2011
2010
< 1.0 pg/L
2009
< 1.0 pg/L
No Results2
OAS-018
< 0.5 p /L
< 1.0 p /L
< 1.0 p /L
OHP-020
< 0.5 pg/L
< 1.0 p /L
< 1.0 p /L
< 1.0 pc
OHP-022
< 0.5 pg/L
< 1.0 pg/L
< 1.0 pg/L
< 1.0 pc
OTC-001 < 0.5 p /L
27.9 pg/L 3.2 p /L3
2.5 pgj
OTC-003
< 0.5 p /L
< 1.0 p /L
< 1.0 p /L
< 1.0 pc
OWF-001
< 0.5 ua/L
< 1.0 up/L
< 1.0 ua/L
< 1.0 u(
Notes:
1) Camp Lejeune's complete analytical monitoring results are included in Appendix J of the 2013 SWOMP
update.
2) Analytical sampling requirements waived during NPDES permit renewal year.
3) The value reported in the table corresponds to the sample taken at the OTC-001 sampling point. Samples
were also taken upstream and downstream of the sampling point. Those results were 8.2 pg/L (upstream)
and 1.8 pg/L (downstream).
• From 2008 to present, the only representative outfall with vinyl chloride results above the
detectable limits was OTC-001, located at Camp Geiger. There are currently no active
industrial activities within OTC-001 (as stated in the 2013 SWPPP); therefore, the origin
of vinyl chloride is likely not related to stormwater discharges from industrial activities. As
previously stated in this memorandum, Camp Lejeune proposes to eliminate OTC-001
from the representative analytical outfalls. The probable source of vinyl chloride at OTC-
001 is described below:
- There are two hazardous waste sites located immediately upstream of outfall
OTC-001. Both sites are included in the EPA NPL and are part of the
comprehensive environmental investigation and cleanup currently being
performed at Camp Lejeune under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) program.
- Management of these hazardous waste sites is described in the EPA Superfund
Record of Decision (ROD) issued in October 2006 for Operable Unit 16 (OU-16).
The principal contaminants of concern are tetrachloroethene (PCE) and its
breakdown products (trichloroethene [TCE], cis- 1,2-dichloroethene [DCE], vinyl
chloride [VC]) and 1,1,2,2-tetrachloroethane (PCA).
- According to the ROD, long-term groundwater monitoring of the contaminants of
concern will be conducted and land use controls will be maintained within the
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boundaries of the hazardous waste sites until the concentrations of hazardous
substances in the groundwater have been reduced to levels that allow for
unlimited exposure and unrestricted use.
- In summary, the hazardous waste sites upstream of OTC-001 are known to
contain vinyl chloride. Ongoing cleanup and monitoring of these hazardous waste
sites is performed under the CERCLA program.
As indicated in the 2013 SWPPP, there are no plastic industries at Camp Lejeune.
Camp Lejeune does have an active and closed landfill, as well as additional hazardous
waste sites that are identified in the EPA NPL. The known hazardous waste sites are
managed and monitored under the CERCLA program.
- Leachate, groundwater, and surface water monitoring is currently performed
semi-annually at the active and closed landfills at Camp Lejeune. This monitoring
includes analysis for volatile organic compounds (VOCs), including vinyl chloride.
Summary:
Based on the Toxicology Profile for Vinyl Chloride, primary sources of vinyl chloride releases to
the environment are emissions and effluents from plastics industries, hazardous waste sites,
and landfills. Camp Lejeune proposes to remove vinyl chloride from the required analytical
parameters at the representative stormwater outfalls based on the following:
• Camp Lejeune manages and monitors known hazardous waste sites under the CERCLA
program. Vinyl chloride is a monitored contaminant of concern for applicable hazardous
waste sites.
Camp Lejeune monitors the leachate, groundwater, and surface water surrounding the
active and closed landfills. This monitoring includes analysis for volatile organic
compounds (VOCs), including vinyl chloride.
• According to the 2013 SWPPP, there are no plastics industries at Camp Lejeune.
AH Environmental Engineering, PC