Ocean Discharge Criteria Evaluation
for the Issuance of a National Pollutant Discharge
Elimination System Permit for the
United States Navy Arctic Ice Camp
in Federal Waters of the Beaufort Sea, Alaska

(NPDES Permit No.: AK-005378-3)

IPk	United States

Environmental Protection
Wmmm M m Agency

December, 2015

Prepared by:

U.S. Environmental Protection Agency

Region 10

Seattle, Washington


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TABLE OF CONTENTS

1.	INTRODUCTION	1-4

1.1.	Area of Coverage	1-4

1.2.	Description of Proposed Discharges	1-5

1.2.1.	Graywater	1-5

1.2.2.	Desalination/Reverse Osmosis Reject Water	1-6

1.3.	Estimated Discharge Volumes	1-6

1.4.	Proposed Permit Requirements	1-6

1.4.1.	Graywater (Outfall 001)	1-7

1.4.2.	Reverse Osmosis Reject Water (Outfall 002)	1-7

2.	Scope of Analysis	2-8

3.	Description of the Existing Physical Environment	3-1

3.1.	Weather	3-1

3.1.1.	Air Temperature	3-1

3.1.2.	Winds	3-1

3.1.3.	Circulation and Currents	3-1

3.1.4.	Water Temperature and Salinity	3-2

3.2.	Ice	3-2

3.2.1. Pack Ice Zone	3-2

4.	DETERMINATION OF UNREASONABLE DEGRADATION	4-1

4.1.	Criterion 1	4-1

4.2.	Criterion 2	4-1

4.3.	Criterion 3	4-2

4.4.	Criterion 4	4-2

4.5.	Criterion 5	4-3

4.6.	Criterion 6	4-3

4.7.	Criterion 7	4-3

4.8.	Criterion 8	4-3

4.9.	Criterion 9	4-3

4.10.	Criterion 10	4-4

5.	BIBLIOGRAPHY	4-5

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LIST OF FIGURES

Figure 1: Area of Coverage for the U.S. Navy Arctic Ice Camp NPDES Permit.	1-5

Figure 2: Major water-mass flows in the Chukchi and Beaufort Seas (Source: IMS, 2010)	3-2

LIST OF TABLES

Table 1: Estimated discharge volumes provided by the U. S. Na vy in its NPDES Permit Application (US Na vy,

2015A AND 2015b)	1-6

Table 2: Graywater Effluent Limitations and Monitoring Requirements (Outfall 001)	1-7

Table 3: Reverse Osmosis Reject Water Effluent Limitations and Monitoring Requirements (0 utfall 002).
	1-8

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ABBREVIATIONS AND ACRONYMS

BMP

Best Management Practices

BOD

Biochemical Oxygen Demand

BE

Biological Evaluation

BOEM

Bureau of Ocean Energy Management

CFR

Code of Federal Regulations

CZMA

Coastal Zone Management Act

CWA

Clean Water Act

ELG

effluent limitation guidelines

EPA

U.S. Environmental Protection Agency

ESA

Endangered Species Act

MMS

Minerals Management Service

NAIC

Navy Arctic Ice Camp

NMFS

National Marine Fisheries Service

NPDES

National Pollutant Discharge Elimination System

OCS

Outer Continental Shelf

ODCE

Ocean Discharge Criteria Evaluation

RO

Reverse Osmosis

TSS

total suspended solids

USFWS

U.S. Fish and Wildlife Service

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UNITS

jj.g/g	micrograms per gram

(ig/L	micrograms per liter

°C	degrees Celsius

°F	degrees Fahrenheit

cm	centimeters

cm/s	centimeters per second

ft	feet

ft/sec	feet per second

g	grams

gal	gallons

gal/day	gallons per day

h	hour

in	inches

km	kilometers

m	meters

mg/kg	milligrams per kilogram

mg/L	milligrams per liter

mi	miles

mm	millimeter

m/s	meters per second

nmi	nautical miles

ppm	parts per million

ppt	parts per thousand

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1. INTRODUCTION

The U.S. Environmental Protection Agency (EPA), Region 10, proposes to issue a National Pollutant
Discharge Elimination System (NPDES) permit for discharges of graywater and reverse osmosis (RO)
reject water associated with a temporary Arctic Ice Camp ("the facility") operated by the United States
Navy ("U.S. Navy") in federal waters of the Beaufort Sea (see Figure 1). The U.S. Navy will operate the
facility approximately every other year, beginning in the winter of 2016.

The facility will be constructed on an ice floe located approximately 100-200 nautical miles (115-230
statute miles) north of Deadhorse, Alaska, and will be operated for a six-week period from late February
to early April. The ice camp provides support for a variety of submarine training and testing operations,
and research activities. Once constructed, the ice camp typically consists of approximately 15 to 20
buildings (housing/sleeping quarters, dining facility, a power house, command hut), a runway, and a
heliport. The completed ice camp, including the runway, is approximately one mile in diameter. The
estimated camp population will be an average of 48 people with a maximum population of 65 people over
two separate two-day periods. During facility build-up and demobilization the population will consist of
15 people. At the end of the six-week period, the entire facility is demobilized and removed from the ice
floe, including all construction materials, solid waste, hazardous waste, and sanitary waste.

Section 403(c) of the Clean Water Act (CWA) requires that NPDES permits for discharges into marine
waters of the territorial seas, the contiguous zone and the oceans comply with EPA's Ocean Discharge
Criteria. The purpose of this Ocean Discharge Criteria Evaluation (ODCE) is to evaluate the discharges
proposed to be authorized by EPA under the U.S. Navy Arctic Ice Camp NPDES permit (Permit No. AK-
005378-3) and assess the potential for the discharges to cause unreasonable degradation of the marine
environment.

l.l. Area of Coverage

The Area of Coverage for the U.S. Navy Arctic Ice Camp NPDES permit includes federal waters of the
Beaufort Sea located approximately 100-200 nautical miles north of Deadhorse, Alaska. The exact
location of the ice camp cannot be predicted in advance as it will depend upon ice conditions at the start
of the season. The location will also change over the course of the season as the ice floe, on which the
camp is built, drifts. As such, based on the quadrant data provided by the U.S. Navy, EPA calculated the
extent of the Area of Coverage to be approximately 18,000 acres in size, which also accommodates for
drifting of the ice camp (see Figure 1).

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Navy Military Readiness Activities Area

	Territorial Sea

	U.S. Exclusive Economic Zone

I I ICEX16 Study Area

1:10.000,000
Nautical Miles

Date: 20 April 2015

0 50 100 150 200

Coordinate System: WGS 1984 North Pole LAEAAIaska Data Sources: ESRI, US Navy

FIGURE 1: Area of Coverage for the U.S. Nmy Arctic Ice Camp NPDESPermit.

1.2, Description of Proposed Discharges

1.2.1. Gravwater

Dining facility operations include food preparation and dishwashing. Prior to use, dishwashing water will
be heated using an on-demand propane water heater. Water made available to camp personnel for
consumption will be imbibed as is or used with powdered drink mixes, coffee, oatmeal, and other food
products. Dishwashing will involve the use of a biodegradable, chlorine and phosphate-free detergents.

Wastewater generated during food preparation and dishwashing will be discharged to the Beaufort Sea via
a single drain in the camp's dining facility. The drain consists of a corrugated pipe wrapped in electric
heat tape to prevent the pipe from freezing. The drain will utilize a removable metal screen to capture
solid debris in the wastewater prior to discharge. The metal screen will have a mesh size of no greater
than 1/16 inch. Solids captured in the screen will be disposed of via the camp's solid waste containers

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and brought back to Deadhorse for disposal. The facility's best management policy is to reduce
wastewater solids, therefore camp personnel will be directed to scrape dishes clean of any solids prior to
turning them in for washing.

1.2.2. Desalination/Reverse Osmosis Reject Water

Freshwater will be generated at the facility via ice mining of multi-year sea ice that has naturally become
free of salt, and through the desalination of first-year sea ice and/or of seawater using a portable reverse
osmosis system. Ice mining and melting of multi-year ice will be the primary means of generating fresh
water at the ice camp. Freshwater will be used for food preparation, dishwashing, and for human
consumption.

The U.S. Navy intends to test the portable reverse osmosis system to determine if it can function in the
Arctic environment. If the reverse osmosis system is operationally successful, the process may serve to
supplement the freshwater produced from mining of multi-year sea ice. The discharge of reject water
from the camp's portable reverse osmosis system will occur during a four week period during the camp's
six weeks of operation. Treatment chemicals will not be used in the desalination process and the reject
water is expected to have a salt concentration approximately three times that of the feed seawater.

1,3, Estimated Discharge Volumes

The estimated volumes of graywater and RO reject water to be discharged, including average and
maximum daily volumes, maximum per season, and during the five-year permit term are developed by
EPA based on information provided by the U.S. Navy in its NPDES Permit Application. The estimated
volumes are summarized below in Table 1.

TABLE 1: Estimated discharge volumes provided by the U.S. Navy in its NPDES Permit Application (US Navy,

2015a and 2015b).

Discharge

Average Daily
Discharge
Volume

(gpd1)

Maximum Daily
Discharge
Volume

(gpd1)

Total Maximum
Discharge
Volume2 Per
Season
(gal1)

Total Maximum
Discharge during 5
Year Permit Term3

(gal1)

Graywater

100

300

6,300

18,900

RO Reject Water

144

288

8,064

24,192

NOTES: 1 Units: gpd means gallons per day; gal means gallons.

2	Based on a six-week operating season.

3	Arctic ice camp activities are anticipated to occur three times between 2016 and 2021.

The maximum RO reject water volumes shown in Table 1 reflect the system being operated 24 hours/day
for four weeks. Discharge volumes are approximated due to uncertainty regarding parameters such as
temperature and conductivity and how they will effect system performance. The estimated average reject
water production of 144 gallons/day (50% of the maximum) is based on the RO unit not being operated
continuously for 24 hours/day due to downtime associated with system maintenance and adjustments. In
addition, the RO system will not be used during the camp build-up and demobilization periods.

1.4. Proposed Permit Requirements

The proposed permit includes effluent limitations and monitoring requirements for the two proposed
discharges, graywater and RO reject water, and are summarized below in Tables 2 and 3, respectively.

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The permit also includes other requirements, such as reporting requirements and best management
practices, to (1) prevent or minimize the generation and the potential for the release of pollutants from the
facility to waters of the United States through normal operation and ancillary activities; and (2) ensure
that methods of pollution prevention, control, and treatment will be applied to all wastes.

1.4.1. Graywater (Outfall 001)

The permit requires use of phosphate-free and minimally-toxic soaps and detergents for any purpose if
graywater is discharged. Soaps and detergents must be free from toxic or bioacummulative compounds.
Additionally, the permit prohibits the discharging of kitchen oils through Outfall 001

Table 2: Graywater Effluent Limitations and Monitoring Requirements (Outfall 001).

Parameter

Effluent
Limitations

Sampling
Frequency1

Sample Type

Reported Values6

Flow

--

Daily

Estimate5 or Meter

Average Weekly and
Maximum Daily; gpd

pH

--

Weekly

Grab

Minimum and
Maximum Values; s.u.

Total Suspended
Solids (TSS)

--

Twice per year 2'3

Grab

mg/L

Biological Oxygen
Demand (BOD5)

--

Twice per year 2'4

Grab

mg/L

Oil and Grease

No Discharge

Daily

Observation

Report1

When visual sheen
observed

Grab

Average Monthly and
Maximum Daily; mg/L

Floating Solids

No Discharge

Daily

Observation

Report1

Foam

No Discharge

Daily

Observation

Report1

Garbage

No Discharge

Daily

Observation

Report1

Oily Sheen

No Discharge

Daily

Observation

Report1

Notes: 1 Required during periods of discharge.

2	The Permittee must monitor TSS and BOD5 no less than twice (2) per year and may cease monitoring if
a total of five (5) samples do not exceed numeric monitoring triggers for the respective parameters. The
Permittee may collect and analyze all five samples during one operation season. All samples must be
collected during maximum occupancy at the facility and during periods of maximum discharge. See
Footnotes 3 and 4.

3	The numeric monitoring trigger for TSS is 298 mg/L. If there is no exceedance of this value for a total
of five (5) samples, then the Permittee may cease TSS monitoring for the duration of the permit term.

4	The numeric monitoring trigger for BOD5 is 914 mg/L. If there is no exceedance of this value for a total
of five (5) samples, then the Permittee may cease BOD 5 monitoring for the duration of the permit term.

5	Any estimation of effluent flow must include a narrative discussion of how the estimate is derived and a
description of the procedures in the QAP (Permit Part II.B.).

6	Refer to Permit Part I.B.2.

7	The daily observations must occur during periods of maximum discharge.

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1.4.2. Reverse Osmosis Reject Water (Outfall 002)

The permit requires monitoring of the RO reject water discharges from Outfall 002 as specified in Table
3.

TABLE 3: Reverse Osmosis Reject Water Effluent Limitations and Monitoring Requirements (Outfall 002).

Parameter

Sampling
Method

Frequency1

Reported Values3

Flow

Estimate2 or Meter

Daily

Average Weekly and
Maximum Daily; gpd

pH

Meter

Weekly

Maximum and Minimum;

s.u.

NOTE: 1 Required during periods of discharge.

2	Any estimation of effluent flow must include a narrative discussion of how the estimate is

derived and a description of the procedures in the QAP (Permit Part II.B.).

3	See Permit Part I.B.2.

2. SCOPE OF ANALYSIS

This ODCE evaluates two waste streams EPA proposes to authorize under the U.S. Navy Arctic Ice Camp
NPDES permit. EPA's Ocean Discharge Criteria (Title 40 of the Code of Federal Regulations (CFR)

Part 125, Subpart M) set forth specific determinations that must be made before permit issuance to ensure
that the discharges would not cause an unreasonable degradation of the marine environment.

Unreasonable degradation of the marine environment is defined (40 CFR 125.121 [e]) as follows:

•	Significant adverse changes in ecosystem diversity, productivity, and stability of the biological
community within the area of discharge and surrounding biological communities;

•	Threat to human health through direct exposure to pollutants or through consumption of exposed
aquatic organisms; or

•	Loss of aesthetic, recreational, scientific, or economic values, which are unreasonable in relation to
the benefit derived from the discharge.

This ODCE is based on 10 criteria (40 CFR 125.122):

•	Quantities, composition, and potential for bioaccumulation or persistence of the pollutants to be
discharged;

•	Potential transport of such pollutants by biological, physical, or chemical processes;

•	Composition and vulnerability of the biological communities which may be exposed to such
pollutants, including the presence of unique species or communities of species, the presence of
species identified as endangered or threatened pursuant to the Endangered Species Act, or the
presence of those species critical to the structure or function of the ecosystem, such as those
important for the food chain;

•	Importance of the receiving water area to the surrounding biological community, including the
presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for other
functions or critical stages in the life cycle of an organism;

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•	Existence of special aquatic sites including, but not limited to, marine sanctuaries and refuges,
parks, national and historic monuments, national seashores, wilderness areas, and coral reefs;

•	Potential impacts on human health through direct and indirect pathways;

•	Existing or potential recreational and commercial fishing, including finfishing and shellfishing;

•	Any applicable requirements of an approved Coastal Zone Management Plan;

•	Other factors relating to the effects of the discharge as may be appropriate; and

•	Marine water quality criteria developed pursuant to CWA section 304(a)(1).

If the Regional Administrator determines that the discharge will not cause unreasonable degradation of
the marine environment, a NPDES permit may be issued. If the Regional Administrator determines that
the discharge will cause unreasonable degradation of the marine environment, a NPDES permit may not
be issued.

If the Regional Administrator has insufficient information to determine, prior to permit issuance, that
there will be no unreasonable degradation of the marine environment, an NPDES permit may not be
issued unless the Regional Administrator, on the basis of best available information, determines that:
(1) such discharge will not cause irreparable harm to the marine environment during the period in which
monitoring will take place; (2) there are no reasonable alternatives to the on-site disposal of these
materials; and (3) the discharge will be in compliance with certain specified permit conditions (40 CFR
125.122). "Irreparable harm" is defined as "significant undesirable effects occurring after the date of
permit issuance which will not be reversed after cessation or modification of the discharge" (40 CFR
125.122[a]).

EPA's evaluation of each of the 10 criteria is presented in Section 4.

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3.

DESCRIPTION OF THE EXISTING PHYSICAL ENVIRONMENT

3.1. Weather

The Area of Coverage is in the Arctic climate zone. The Arctic climate is characterized by high spatial
variability and affected by the extreme solar radiation conditions of high latitudes. Important weather
conditions that could affect the discharges proposed to be authorized by the permit include air
temperature as well as wind speed and direction. Wind speed and direction in turn can affect ice floe drift
rate and direction. The following sections describe the physical setting within the Area of Coverage.

3.1.1.	Air Temperature

In the Beaufort Sea, the air temperatures are below freezing the majority of the year. Average minimum
temperatures are lowest in February at -25 °F (NMFS 2011). Temperature data collected by the Applied
Physics Laboratory (APL) during its operations of the winter ice camps in 1988 and 1990 indicated
ranges from - 36 °F to 32 °F (APL 1989a and 1990b).

3.1.2.	Winds

Observed wind directions over the area are seasonally variable and range from an average summer flow
of 8.0 to 11.4 miles per hour (mph) from the south and southwest to a winter flow, which averages 8.0 to
17.3 mph from the east and southeast (Weingartner et al. 2009).

Wind speed and direction data from APL ice camps during the 1986, 1988, and 1990 seasons indicate
they are highly correlated, suggesting that floe drift is mainly wind driven (APL 1987, 1989a, 1990b).

3.1.3.	Circulation and Currents

Circulation in the Beaufort Sea offshore waters are primarily influenced by the large-scale Arctic
circulation known as the Beaufort Gyre, which is driven by large atmospheric pressure fields. In the
Beaufort Gyre, water moves to the west in a clockwise motion at a mean rate of 5-10 cm per second. The
Beaufort Gyre expands and contracts, depending on the state of the Arctic Oscillation (Steele et al. 2004
as cited in MMS 2008). Below the surface flow of the Beaufort Gyre, the mean flow of the Atlantic layer
(centered at 500 m) is counterclockwise in the Canada Basin. Below the polar mixed layer, currents
appear to be driven primarily by ocean circulation rather than the winds (Aagaard, Pease, and Salo 1988
as cited in MMS 2008).

Pickart (2004) documents the presence of the Beaufort shelfbreak, a narrow eastward current that carries
much of the outflowing water from the Chukchi Sea toward the eastern Canada Basin. Depending on the
season, the Beaufort shelfbreak is associated with advection of summer-time Bering water, winter-
transformed Bering water or upwelled Atlantic water. Figure 2, below, illustrates the major watermass
flows in the Chukchi and Beaufort Seas.

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Figure 2: Major water-mass flows in the Chukchi and Beaufort Seas (Source: IMS, 2010).
3.1.4. Water Temperature and Salinity

Offshore waters are colder and more saline than the coastal waters. Water temperatures are near 32 °F
and have salinities of 32.2 to 33 parts perthousand (ppt) (Lewbel and Gallaway 1984). Similar water
temperatures and salinity ranges were also observed during APL field measurements conducted during
the ice camps activities in 1986, 1988, and 1990. During the 1986 and 1988 ice camps, salinity
measurements ranged from 29.069 ppt to 34.727 ppt, collected at depths ranging from 16 m to 243 m
(APL 1987, 1989a). Salinity measurements from the 1990 ice camp ranged from 29.00 ppt near the
surface to 34.00 at 700 m (1990b).

3.2. ICE

Sea ice is frozen seawater with most of the salt extruded out that floats on the ocean surface; it forms and
melts with the polar seasons. In the Arctic, some sea ice persists year after year. Sea ice in the Arctic
appears to play a crucial role in regulating climate because it regulates heat, moisture, and salinity in the
polar oceans. Sea ice insulates the relatively warm ocean water from the cold polar atmosphere, except
where cracks or leads (areas of open water between large pieces of ice) in the ice allow exchange of heat
and water vapor from ocean to atmosphere in winter.

3.2.1. Pack Ice Zone

Pack ice is seaward of the stamukhi ice zone and includes first-year ice, multiyear ice, and ice islands.
First-year ice that forms in fractures, leads, and polynyas (large areas of open water) varies in thickness
from a few centimeters to more than a meter. Multiyear ice is ice that has lasted one or more melt
seasons.

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Movement in the pack ice zone in the Area of Coverage is generally small during the winter, moving
from east to west in response to the Beaufort Gyre (MMS 2008). Ridges indicate deformed pack ice. In
1986, the APL ice camp was established on 4.3 meters (14 ft) of ice. Ice camps in 1988 and 1990 were
established on ice ranging from 1.5 meters (4.9 ft) to 2.4 meters (7.8 ft) (APL 1987, 1989a, 1990b).

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4.

DETERMINATION OF UNREASONABLE DEGRADATION

The EPA has determined that due to the limited discharge quantities, the remote offshore location and
short duration of the ice camp activities, the issuance of the NPDES permit for the U.S. Navy Arctic Ice
Camp will not cause an unreasonable degradation to the marine environment. EPA's ocean discharge
criteria evaluation, related findings and determinations are discussed in this section.

4.1.	Criterion 1

The quantities, composition, and potential for bioaccumulation or persistence of the pollutants to be
discharged.

The proposed permit authorizes two discharges during a six-week period while the U.S. Navy conducts
training and testing operations, and research activities at the temporary ice camp. It is estimated that
graywater will be discharged at a rate of 100 gallons/day, with an estimated maximum daily flow of 300
gallons/day during periods of food preparation and dishwashing. The estimated total discharge volume
per season from the ice camp's dining facility is 6,300 gallons. A Vi6-inch mesh screen will be used to
strain solids from the wastewater prior to discharge. As a best management practice, camp personnel will
be directed to scrape dishes clean of any solids prior to turning them in for washing. Dishwashing will
involve the use of a biodegradable, chlorine and phosphate-free detergent.

The discharge of reject water from the camp's portable reverse osmosis system will occur for a four-week
period during the camp's six weeks of operation. Treatment chemicals will not be used in the
desalination process and the reject water is expected to have a salt concentration approximately three
times that of the feed seawater. The average flow is expected to be 144 gallons/day with a maximum
daily flow of 288 gallons/day. The maximum total discharge volume of reject water from the ice camp is
8,064 gallons.

Both discharges do not include pollutants that will bioaccumulate or persist in the environment. The
potential pollutants of concern in the graywater include pH, total suspended solids (TSS), biological
oxygen demand (BOD5), and oil and grease. These are considered conventional pollutants and are non-
toxic. The permit includes monitoring provisions to ensure they do not cause an unreasonable
degradation of the marine environment.

4.2.	Critef

The potential transport of such pollutants by biological, physical, or chemical processes.

Pollutant transfer can occur through biological, physical, or chemical processes. Due to the limited
volume of graywater and RO reject water to be discharged, the short-term nature of the activities, and the
requirements established by the permit, the transfer of pollutants are not expected to cause an
unreasonable degradation of the marine environment.

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4,3, Criterion 3

The composition and vulnerability of the biological communities which may be exposed to such
pollutants, including the presence of unique species or communities of species, the presence of
species identified as endangered or threatened pursuant to the Endangered Species Act (ESA), or
the presence of those species critical to the structure or function of the ecosystem, such as those
important for the food chain.

The Endangered Species Act (ESA) requires federal agencies to consult with the U.S. Fish and Wildlife
Service (USFWS) and the National Marine Fisheries Service (NMFS) if the federal agency's actions
could beneficially or adversely affect any threatened or endangered species or their critical habitat. Two
threatened and endangered species are expected to occur within the Area of Coverage during the winter
months: ringed seals and polar bears. These species live or spend a portion of their lives in the Area of
Coverage, and currently, there are no designations of critical habitat areas for these species. While
unlikely, the potential exists for the species to interact with the graywater and RO reject water discharges.

Pursuant to 40 C.F.R. § 122.49(c), EPA has made the determination that the proposed permit action is
Not Likely to Adversely Affect the ringed seal (Arctic species, Phoca hispida hispida). EPA's effect
determination is made based on the Informal Consultation Document developed by the Navy in close
coordination with EPA. The Informal Consultation Document evaluates the proposed ice camp activities,
including the potential effects from the wastewater discharges proposed to be authorized by EPA. The
Informal Consultation Document serves as the consultation document with the National Marine Fisheries
Service (NMFS) for both agencies under the Endangered Species Act (ESA) Section 7. EPA is
requesting concurrence from NMFS on our effect determination.

EPA has made the determination that the proposed discharges will have No Effect on the polar bear
(Ursus naritimus). EPA's analysis supporting this conclusion is included in the Administrative Record.
Polar bear dens are found near shorefast ice and pack ice. Ringed seals are polar bear's primary food
source, and areas near ice edges, leads, or polynyas where ocean depth is minimal are the most productive
hunting grounds (USFWS 2009). Polar bears are more likely to be encountered if activities were
conducted in shallow, nearshore locations in the Beaufort Sea; however, the U.S. Navy has developed a
polar bear interaction plan to ensure deterrence measures are in place in the event of an encounter with a
polar bear.

4,4, Critef

The importance of the receiving water area to the surrounding biological community, including the
presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for other
functions or critical stages in the life cycle of an organism.

Since the proposed discharges from the U.S. Navy Arctic Ice Camp occur on a temporary basis to the
Beaufort Sea, 100-200 nautical miles (115-230 statute miles) from shore, the presence of spawning sites,
nursery/forage areas, migratory pathways, or areas necessary for other functions or critical stages in the
life cycle of an organism are not expected to be a concern.

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4,5, Criterion 5

The existence of special aquatic sites including, but not limited to, marine sanctuaries and refuges,
parks, national and historic monuments, national seashores, wilderness areas, and coral reefs.

No marine sanctuaries or other special aquatic sites, as defined by 40 CFR 125.122, are in or adjacent to
the Area of Coverage.

4.6.	Critef

The potential impacts on human health through direct and indirect pathways.

Human health within the communities on the North Slope communities is directly related to the
subsistence activities in the Beaufort Sea. In addition to providing a food source, subsistence activities
serve important cultural and social functions for Alaska Natives. Individuals in the communities have
expressed concerns related to contaminant exposure through consumption of subsistence foods and other
environmental pathways. Concerns have also been expressed over animals swimming through discharge
plumes that may contain chemicals.

EPA has determined the proposed discharges will not impact subsistence harvest activities or human
health through direct and indirect pathways for the following reasons: (1) The location of the U.S. Navy
Arctic Ice Camp activities will be located 100-200 nautical miles (115-230 statute miles) offshore during
the winter months on pack ice; (2) The small volumes of graywater and RO reject water discharges will
occur on a temporary basis for a short duration; and (3) the monitoring requirements established by the
permit are protective of the marine environment.

4.7.	Criterion 7

Existing or potential recreational and commercial fishing, including finfishing and shellfishing.

There are no recreational, commercial or subsistence fishing, finfishing or shellfishing activities within
the Area of Coverage.

4.8.	Critef

Any applicable requirements of an approved Coastal Zone Management Plan.

Not applicable.

4.9.	Critef

Such other factors relating to the effects of the discharge as may be appropriate.

EPA has determined that the proposed discharges of graywater and RO reject water will not have
disproportionately high and adverse human health or environmental effects with respect to minority or
low-income populations living on the North Slope. In making this determination, EPA considered the
potential effects of the discharges on the communities, including subsistence areas, the distance from
shore, and the receiving marine environment.

ODCE for the U.S. Navy Arctic Ice Camp NPDES Permit
Final - December 2015

4-3


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4,10, Criterion 10

Marine water quality criteria developed pursuant to CWA section 304(a)(1).

The U.S. Navy Arctic Ice Camp NPDES permit includes monitoring of graywater for the following
parameters: pH, TSS, and BOD5, and oil and grease if a sheen is observed. Additionally, the permit
prohibits the discharge of floating solids, garbage, debris, sludge, deposits, foam, scum or other residues
(excluding residual salt from desalination/RO reject water) of any kind. Federal criteria applicable to
these parameters include oil and grease. The criterion establishes levels of oils or petrochemicals in the
sediment which cause deleterious effects to the biota should not be allowed. In addition, surface waters
shall be virtually free from floating nonpetroleum oils of vegetable or animal origin, as well as petroleum-
derived oils.

4-4

ODCE for the U.S. Navy Arctic Ice Camp NPDES Permit

Final - December 2015


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5. BIBLIOGRAPHY

Aagaard, K., C.H. Pease, and S.A. Salo. 1988. Beaufort Sea Mesoscale Circulation Study-Preliminary
Results. NOAA Technical Memorandum ERL PMEL 82. Seattle, WA:USDOC, NOAA, PMEL,
171 pp. plus appendices.

APL. Applied Physics Laboratory. 1987. Environmental Measurements in the Beaufort Sea, Spring
1986. Technical Report APL-UW-4-86. University of Washington, Seattle, WA.

	1989a. Environmental Measurements in the Beaufort Sea, Spring 1988. Technical Report APL-

UW-TR8822. University of Washington, Seattle, WA.

	1990b. Environmental Measurements in the Beaufort Sea, Spring 1990. Technical Report APL-

UW-TR9105. University of Washington, Seattle, WA.

Lewbel, G.S., and Gallaway, B.J. 1984. Transport and fate of spilled oil. In: Proceedings of a Synthesis

Meeting: The Barrow Arch Environment and Possible Consequences of Planned Offshore Oil and
Gas Development. Girdwood, AK Oct 30-Nov 1 1983. Anchorage, AK. USDOC, NOAA
OCSEAP and USDOI, MMS. p. 7-29.

MMS (Minerals Management Service). 2008. Beaufort Sea and Chukchi Sea Planning Areas Oil and Gas
Lease Sales 209, 212, 217, and 221 Draft Environmental Impact Statement (OCS Report MMS
2008-0055). November 2008.

NMFS (National Marine Fisheries Service). December 2011. Effects of Oil and Gas Activities in the

Arctic Ocean Draft Environmental Impact Statement. U.S. Department of Commerce, National
Oceanic and Atmospheric Administration, National Marine Fisheries Service, Office of Protected
Resources. December 2011.

Pickart, R.S. 2004. Shelfbreak Circulation in the Alaskan Beaufort Sea: Mean Structure and Variability.

Journal of Geophysical Research 109:C04024.

Steele, M., J. Morrison, W. Ermold, I. Rigor, M. Ortmeyer, and K. Shimada. 2004. Circulation of
Summer Pacific Halocline Water in the Arctic Ocean. Journal of Geophysical Research
109(C02027):DOI 10.1029/2003JC002009.

USFWS (U.S. Fish and Wildlife Service). 2009. Polar Bear (Ursus maritimus) Fact Sheet. USFWS
Endangered Species Program. Arlington, VA. October 2009.

US Navy. 2015a. U.S. Navy Arctic Submarine Laboratory NPDES Permit Application, Form 1 and 2E.
Submitted April 21, 2015.

US Navy. 2015b. U.S. Navy Arctic Submarine Laboratory Revised NPDES Permit Application, Form
2E. Submitted May 19, 2015.

Weingartner, T.J., S.L. Danielson, J.L. Kasper, and S.R. Okkonen. 2009. Circulation and water property
variations in the near shore Alaskan Beaufort Sea (1999 - 2007). Prepared by the Institute of
Marine Science for the U.S. Department of the Interior Minerals Management Service, Alaska
OCS Region, Anchorage, AK.

ODCE for the U.S. Navy Arctic Ice Camp NPDES Permit	4-5

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