2011 SEDIMENT IMPLEMENTATION WORK PLAN

Gateway Pacific Terminal

Whatcom County, Washington

Prepared for:

Pacific International Terminals, Inc.

1131 SW Klickitat Way

Seattle, Washington 98134

Prepared by:

AMEC Earth & Environmental, Inc.

11810 North Creek Parkway North

Bothell, Washington 98011

June 2011

Project No. 0-915-15338-C.06.01

TABLE OF CONTENTS

1.0Introduction

1.1Site Description and Background

1.1.1Location

1.1.2Background

1.1.3Historical and Current Use

2.0Objective and Design of Investigation

2.1Sampling Design

2.2Statistical Design

2.3Analysis Schedule

3.0FIELD SAMPLING METHODS

3.1Station Positioning

3.2Sediment Samples

3.3Decontamination Procedures

3.4Sample Compositing

3.5Waste Sediment

4.0Sample Handling Procedures

4.1Sample Containers

4.2Sample Storage

4.3Chain of Custody

5.0Laboratory Analytical Methods

5.1Biological Analyses

5.1.1Amphipod Sediment Bioassay

5.1.2Microtox® (Marine Pore Water) Toxicity Assessment

5.1.3Sediment Larval Bioassay

5.1.4Photoactivation of Polycyclic Aromatic Hydrocarbons

5.2Chemical Analysis and Target Detection Limits

6.0Quality Objectives and Criteria

6.1Quality Objectives and Criteria for Biological Data

6.2Quality Objectives and Criteria for Analytical Data

6.2.1Precision

6.2.2Accuracy

6.2.3Representativeness

6.2.4Comparability

6.2.5Completeness

6.3Field Quality Assurance

6.4Documentation and Records

6.4.1Field

6.4.2Bioassay Laboratory

6.4.3Analytical Laboratory

6.5Instrument/Equipment Testing, Inspection, Maintenance, and Calibration

6.5.1Field Equipment

6.5.2Analytical Laboratory

6.6Data Management

6.7Assessment and Response Actions

6.7.1Field

6.7.2Biological Laboratory

6.7.3Analytical Laboratory

7.0Data Validity and Usability

7.1Data Review, Verification, and Validation

7.2Verification and Validation Methods

7.3Reconciliation with User Requirements

8.0Data Analysis and Reporting Requirements

8.1Analysis of Biological Data

8.2Analysis of Sediment Chemical Data

8.3Reports to Management

9.0Health and Safety

10.0Schedule

11.0Project Management

11.1Prime Consultant

11.2Consultant Team Project Manager

11.3Quality Assurance Manager

11.4Field Manager

11.5Analytical Laboratory Coordinator

11.6Biological Laboratory Coordinator

11.7Data Management

11.8Data Validation

11.9Analytical Laboratory Project Manager

11.10Bioassay Laboratory Project Manager

12.0References

TABLES

Table 1Tiered Analysis Schedule

Table 2AProposed Sample Locations in Permitted Configuration

Table 2BProposed Sample Locations in Alternative Configuration

Table 3Data Quality Objectives for the Constituents of Concern, Practical Quantitation Requirements

Table 4Analytical Methodologies and Reporting Limits

Table 5Summary of Method Quality Objectives for Method 8082—PCBs

Table 6Summary of Method Quality Objectives for Method 6010—ICP Metals

Table 7Summary of Method Quality Objectives for Method 7000 Series—Metals via GFAA/CVAA

Table 8Summary of Method Quality Objectives for Method 8270D—SVOCs

Table 9Summary of Method Quality Objectives for Sediment Conventionals

Table 10Summary of Method Quality Objectives for Method 8260C—Sediment VOCs

Table 11Summary of Method Quality Objectives for Method 8081—Pesticides

Table 12Sediment Management Standards Biological Testing Control Limits, Performance Standards, and Effects Criteria

Table 13Data Qualifiers

FIGURES

Figure 1Project Vicinity Map

Figure 2Sediment Sampling Design

Abbreviations and Acronyms

AMEC Earth & Environmental, Inc.

Project No. 0-915-15338-C1

\\Sea-fs1\departments\15338-C GPT3\06-Water and Sediment Quality\2011 Sed Implementation Plan\2011_GPT Sediment_Implementation_Plan_062111.docx

AMECAMEC Geomatrix, Inc.

ARIAnalytical Resources, Inc.

cmcentimeter

CSLcleanup screening level

DGPSDifferential Global Positioning System

DQIdata-quality indicator

DQOdata-quality objectives

EcologyWashington State Department of Ecology

EDDelectronic data deliverable

EIMEnvironmental Information Management

EPAU.S. Environmental Protection Agency

GFAA/CVAAgraphite furnace atomic absorption/cold vapor atomic adsorption

HPAHhigh-molecular-weight polycyclic aromatic hydrocarbon

ICPinductively coupled plasma

LCSlaboratory control sample

LPAHlow-molecular-weight polycyclic aromatic hydrocarbon

mmeter

m²square meter

mLmilliliters

MLLWmean lower low water

PAHpolycyclic aromatic hydrocarbon

PARCCprecision, accuracy, representativeness, comparability, and completeness

PCBpolychlorinated biphenyl

pptparts per thousand

PSEPPuget Sound Estuary Program

QAquality assurance

QCquality control

RRMregional reference material

SAPASediment Sampling and Analysis Plan Appendix

SMSSediment Management Standards

SOPstandard operating procedure

SQSSediment Quality Standards

TerminalGateway Pacific Terminal

SVOCsemivolatile organic compound

TOCtotal organic carbon

µmmicrometer

UVultraviolet

WACWashington Administrative Code

WDNRWashington Department of Natural Resources

AMEC Earth & Environmental, Inc.

Project No. 0-915-15338-C1

\\Sea-fs1\departments\15338-C GPT3\06-Water and Sediment Quality\2011 Sed Implementation Plan\2011_GPT Sediment_Implementation_Plan_062111.docx

AMEC Earth & Environmental, Inc.

Project No. 0-915-15338-C1

\\Sea-fs1\departments\15338-C GPT3\06-Water and Sediment Quality\2011 Sed Implementation Plan\2011_GPT Sediment_Implementation_Plan_062111.docx

2011 Sediment Implementation Work Plan

Gateway Pacific Terminal

Whatcom County, Washington

1.0Introduction

This Work Plan describes the 2011 sediment investigation to be conducted in the location of the proposed Gateway Pacific Terminal in the Strait of Georgia, Washington.This investigation has been designed to provide a baseline characterization of sediment quality.

This Work Plan has been prepared by AMEC Geomatrix, Inc. (AMEC), on behalf of Pacific International Terminals, Inc. (Pacific International Terminals).This Work Plan conforms to the substantive requirements of the Washington State Department of Ecology (Ecology) Sediment Sampling and Analysis Plan Appendix (SAPA; Ecology, 2008), the Puget Sound Estuary Program 1996 Protocols and the Settlement Agreement Pacific International Terminals, Shoreline Substantial Permit SHS 92-0020 and SHB Appeals Numbers 97-22 and 97-23 filed with the Shoreline Hearings Board on August 31,1999.

1.1Site Description and Background

This section presents a brief description of the study location, project background, and the historical and current use of the site.

1.1.1Location

Pacific International Terminals proposes to construct the Gateway Pacific Terminal (Terminal) project, a bulk commodities terminal and storage facility in Whatcom County, Washington (Figure 1).The facility would be located on heavy-impact industrial zoned land located between BP’s Cherry Point pier and refinery to the north and the ALCOA – Intalco Works pier and aluminum smelter to the south.

The proposed overwater portion of the terminal consists of an approximately 50-foot wide trestle extending to the south over the Salish Sea.The trestle connects to a wharf that will be used for vessel docking and product loading and unloading.Two different wharf configurations are being considered for the project and are referred to as the Permitted and Alternative configurations (Figure 2).The areas covered by both configurations will be sampled as part of the baseline sediment characterization.

The sediment investigation within the area covered by the trestle and both wharf configurations cover a 76acre area extending from the ordinary high water mark to a maximum depth of approximately 125feet mean lower low water (MLLW) (Figure 2).Approximately 5.3 acres of the Washington Department of Natural Resources (WDNR) lease area occurs in waters less than -12 feet MLLW (Figure 2).

1.1.2Background

Pacific International Terminals is proposing to develop the Gateway Pacific Terminal, a deep-sea cargo shipping facility. The Gateway Pacific Terminal will service transoceanic ships entering the Strait of Georgia through the Strait of Juan de Fuca.The upland portion of the Terminal will include material storage facilities, conveyors to move materials to and from ships, and railroad track to provide inland rail access. The marine development will include a three-berth deep-water wharf and a trestle accessing from the shore.

The vicinity has been identified by Whatcom County and the State of Washington for marine- dependent industry because of its proximity to shipping lanes; the bathymetry of nearshore waters that would accommodate cargo vessels; and close proximity to existing railways and Interstate 5 for inlandtransportation to this location.

Pacific International Terminals’ proposal to construct Gateway Pacific Terminal was evaluated in a final Environmental Impact Statement (Whatcom County, 1996).Whatcom County subsequently issued a Shoreline Substantial Development Permit (SHS92-0020) and a Major Development Permit (MDP92-0020) for the project in 1997.The Washington Environmental Council, Washington Department of Fish and Wildlife, and Ecology along with 5 other appellants appealed the permit.In 1999, Pacific International Terminalsand the appellants entered into a Settlement Agreement on issues which were raised during the permit appeal (SHB Appeals Numbers 97-22 and 97-23) that incorporates a number of conditions which Whatcom County and Pacific International Terminals must meet prior, during, and after construction of the facility.

Section 2.5 of the Settlement Agreement calls for “…annual sampling of sediments, marine water, and shellfish and/or other identified indicator species in the vicinity of the project site in accordance with the State Sediment Management Standards/Sediment Sampling and Analysis Plan Appendix and the Puget Sound Estuary Program 1996 Protocols.”

Section 2.5 of the Settlement Agreement furtherstates that the requirements for sediment sampling are:

  • “…providea scientifically sound basis for establishing existing pollutant levels[i.e., baseline conditions] and related biological conditions in the proposed Department of Natural Resources lease area…”, and
  • conduct annual sampling of sediments and compare the results to baseline conditions in order to detect changes or trends in sediment quality.

This Work Plan addresses the Settlement Agreement requirement to evaluate sediment quality following the guidelines for recommended sampling presented by Ecology’sSediment Sampling and Analysis Plan Appendix (SAPA; Ecology 2008), the Puget Sound Estuary Program 1996 Protocols and the Settlement Agreement Pacific International Terminals, Shoreline Substantial Permit SHS 92-0020 and SHB Appeals Numbers 97-22 and 97-23 filed with the Shoreline Hearings Board on August 31, 1999.As well, this Work Plan addresses the objectives of standard sediment investigations conducted under the Sediment Source Control Program as established by Washington Administrative Code (WAC) 173-204-100.

1.1.3Historical and Current Use

Drainage from the upland currently flows mainly through roadside ditches and empties to the Strait of Georgia via an unnamed stream adjacent to the sediment study area. There are no engineered stormwater discharges on the site and no known history of wastewater or stormwater discharge to the sediment in the study area.

2.0Objective and Design of Investigation

The objective of this investigation is twofold. This investigation will fulfill Pacific International Terminals’ obligations provided in the Settlement Agreement, Pacific International Terminals; Shoreline Substantial Permit SHS 92-0020 and SHB Appeals Numbers 97-22 and 97-23.Specifically, the objective is to comply with Section 2.5 of the Settlement Agreement providing for annual sampling of sediments in the vicinity of the Terminal. As stated earlier, Section 2.5 requires the monitoring program to be developed in accordance with Ecology’sSediment Sampling and Analysis Plan Appendix (SAPA; Ecology 2008) and the Puget Sound Estuary Program 1996 Protocols.

The second objective of this investigation is to provide an analysis of baseline conditions in the potential WDNR lease area prior to entering into a lease agreement with WDNR. In addition, this Work Plan addresses the objectives of sediment investigations conducted under the Sediment Source Control Program as established by WAC 173-204-100.

The objectives of this investigation are to:

  • Conduct a baseline characterization of the concentration of metals and organic chemicals in sediment within the WDNR lease No. 20-013265 area;
  • determine if sediments within the WDNR lease area meet the Washington Marine Sediment Quality Standards (SQS) chemical criteria (WAC 173-204-320);
  • conduct sediment bioassays to assess toxicity for locations where the SQS chemical criteria are exceeded; and
  • use the chemical data collected to determine the statistical variance of SQS chemicals within the lease area.

This information will be used to develop a robust statistical design for the annual monitoring program to detect future changes from baseline conditions.The annual monitoring program will be developed based on specific areas where chemicals may be detected during baseline monitoring.

The data gathered during this monitoring program will meet the objectivesof the Settlement Agreement to develop a scientifically sound basis for establishing existing pollutant conditions and related biological conditions in the proposed WDNR lease area. The annual sampling design will provide a scientifically sound basis for comparison of the background data to the annual results in order to detect changes or trends in samples over the long-term.

2.1Sampling Design

This project will use a tiered testing approach.For the Tier I analysis, surficial sediment samples (upper 10 centimeter [cm]) will be collected and split into two samples.One sample will be analyzed for the metals and organic chemicals that have Washington Marine SQS.The second sample will be archived for potential Tier II analysis.

Sediment concentrations measured at each sampling location will be compared to the SQS.If any of the SQS are exceeded, a Tier II analysis will be conducted on the archived sample to evaluate compliance with the Washington sediment management standards for Biological Effects Criteria [WAC 173-204-320 (3)].

The Biological Effects Criteria include testing sediment for two of the acute and one of the chronic tests listed in the sediment management standards (SMS; WAC 173-204-315). Sediment samples that pass all of the biological tests are designated as passing the applicable SQS of WAC 173-204-320 through 173-204-340.Any sample which fails any one of the biological tests is interpreted as not complying with the SQS.The sediment bioassays proposed for the two acute tests are the 10day amphipod bioassay using Rhepoxynius abronius, and the sediment larval bioassay using a mollusk or an echinoderm species. The chronic test will be run using the cultured marine bacteria Vibrio fisheri.

The sediment investigation design considers the shallow (sampling locations in water depths less than -12 MLLW) and deeper areas of the lease area as two separate areas of investigation because benthic-dwelling organisms exposed to polycyclic aromatic hydrocarbons (PAHs) in waters less than -12 feet MLLW may experience increased toxicity due to the photoactivation of selected PAHs from ultraviolet (UV) radiation (Ecology, 2008).If Tier II analysis is required for sediments collected in the shallow area, bioassays will be performed in the presence of full spectrum laboratory lighting that includes ultraviolet wavelengths of sufficient intensity to mimic the site conditions.

2.2Statistical Design

The program,Visual Sample Plan, Version 6.0, was used to develop the sampling design included in this Work Plan.This program was specifically created to develop sampling designs based on specified statistical objectives.Current sponsors of the model include the U.S. Environmental Protection Agency (EPA), U.S. Department of Energy, U.S. Department of Defense, U.S. Department of Homeland Security, U.S. Centers for Disease Control, and the United Kingdom Atomic Weapons Establishment.

The statistical objectives specified for the sampling design are:

  • systematic triangular grid pattern within the area to be covered by the trestle and both wharf configurations; and
  • 95 percent probability of detecting a circular hot spot with a diameter of 150feet (an area of 70,686square feet).

The sampling design specifies the collection of 47 samples as shown on Figure 2.Forty-four of the sampling locations are in water depths greater than -12 feet MLLW; three locations are in waters shallower than -12 feet MLLW. Thirty-two sampling locations will be sampled within the Permitted configuration area and thirty locations will be sampled within the Alternative configuration area.Nine of the forty-seven sampling locations are within both configurations.

If Tier II testing is required at either of the locations in waters shallower than -12 feet MLLW, the bioassays will be performed in the presence of full spectrum laboratory lighting that includes ultraviolet wavelengths of sufficient intensity to mimic the conditions at the site (Ecology, 2008).

2.3Analysis Schedule

The initial round of analysis (Tier I; Table 1) is chemical testing of the sediments collected within the lease area (Figure 2).Tier II biological effects testing will be conducted on sediment samples that fail to meet the SQS chemical criteria.

3.0FIELD SAMPLING METHODS

3.1Station Positioning

The planned sampling locations are shown on Figure 2 and givenin Tables 2A and 2B.In the field, sample stations will be located with a Differential Global Positioning System (DGPS).Samples will be collected within 3 meters (m) of the proposed sampling locations.If samples cannot be collected after two attempts, the AMEC Project Manager (refer to Section 11) will be notified and an alternative location may be selected.The actual sample locations will be recorded and logged.

3.2Sediment Samples

A hand-core sediment sampler (20 cm diameter x 10 cm deep) will be used to collect the sediment samples at the shallowest water depth (Station GP-1).Sediments at all other sampling location will be collected using 0.2 m² stainless-steel Van Veen sediment grab sampler deployed from a sampling vessel.Prior to sampling, the surface of the sediment will be photographed, visually inspected, and logged.

3.3Decontamination Procedures

Sample containers, instruments, working surfaces, technician protective gear, and other items that may come into contact with sediment sample material will meet high standards of cleanliness.All sediment-handling equipment will be cleaned and decontaminated prior to arrival at the site.The hand-coresamplers will be pre-cleaned prior to arrival at the site.The hand-core samplers will be rinsed clean of any visible sediment and decontaminated between uses.All equipment and instruments used to remove sediment from the sampler or to homogenize samples will be stainless steel and will be decontaminated before and in between each use.

The AMEC standard decontamination procedure for the hand-core samplers, Van Veen grab, and other sample handling equipment is modeled after Puget Sound Estuary Program (PSEP) protocols (PSEP, 1997); however, the decontamination procedure will not use any acid or solvent rinses (the final rinse will use distilled water).

3.4Sample Compositing

During the initial round of sampling, surface sediment (top 10 cm) from a minimum of two hand cores at Station GP-1, and a single Van Veen grab at other sample locations will be collected.Sediments for pore water extraction for the Microtox® bioassay will be placed directly from the sampler into the 16-oz glass jar to minimize disturbance and possible volatilization of potential contaminants.The remaining sediments will be homogenized and bottled.A portion of the bottled sediment will be tested during the initial round of chemical testing.The remaining sediment will be archived for possible biological effects testing.