Coralations - Appendix B - Analysis - CZ-2022-1109-029

CORALations, Inc.
APPENDIX B ANALYSIS CZ-2022-1109-029

B-1
The Report entitled MPRSA Section 103 Sediment Characterization Testing and Analysis of
San Juan Harbor, PR, May 2021, was not available online at the Coastal Zone Consistency
Webpage for public review. This to my knowledge is the first opportunity for public review.
When solicited from the Corps they initially released a report of the same title with DRAFT
written over the front and sent by email Feb 24th, 2022 (APPENDIX C, pg 93) Pertinent
analytical information is found in the appendices of this report, which had to be solicited and
as of this date has not yet been completely released. (Appendix C )
The May 2021 103 report summary indicates: pg. ES-1P-1
This link indicates that 103 MPRSA allows the Corps to collaborate with EPA to select alternate dump
site, when something prevents dredge from going into designated (ODMDS), aka, the Puerto Rico
trench. The link says ocean dumping is regulated by EPA through 102 MPRSA. The ODMDS is good for
10 years and last one was done in 2011. The 103 report summary indicates “new” work. However the
new work is not the 15 acre “borrow area" near Cut 6, and in fact nothing near Cut 6 was even
sampled. The Corps ran later physical analysis on bottom sediment in April or May of 2021, and no
report from lab was issued. Corps indicates fundings were summarized in the 2021SEA (APPENDIX
C-33). The samples taken in the 15 acre borrow site to dump into Condado Lagoon were analyzed
only for particle size and composition - there was no toxicology or chemical analysis.
Also this was done after this report entitled 103 compliance (but possibly only pertaining to 102
compliance analysis).
This confusion was why it’s important to get one email from the Corps that clarifies this.
Only new site considered in the May 2021

analysis and indicated in gray
Cut 6 and borrow area are west

and north of the closest sample site:
M-A-S-1/D-AC-C1
PO Box 750 Culebra, PR. 00775 coralations@gmail.com

CORALations, Inc. APPENDIX B ANALYSIS CZ-2022-1109-029
B-2
On Friday February 25th, Paul Demarco sent the following geotechnical information for the
new borrow area via email:
File Name: vibracore-map.pdf - A map (screen shot below) of most recent sampling sites
File Name: borrow-VC-1-3a-logs.pdf - drilling logs (6 pages)
File Name: borrow-VC-1-3a-graphs.pdf - graphs of the particle analysis limited to particle size
and composition (16 pages)
After follow up question by email, requesting complete report with lab certs and COC’s, Mr.
Demarco responded with this email and the attached chain of custody file: COC file: 22
According to the map and the graphic analysis documents sent in Feb, there were three
sampling sites in the borrow area, cut 6 - However there is also an area inside the Anegado
Channel inside cut 6 and also marked for disposal in the Condado Lagoon. (Graphic below)
Samples from different depths were taken at these three sites.
Sampling was done on 4-28-2021
and analysis was done at 6-29-2021
Boring log date screen shot and chain of

custody 5/28?

B-3
The three sample sites from

the last data sent in the email
from Demarco, show graphic
analysis, maps and logs mesh,
and indicate the following
three sample sites:
VB-SJH20-01
VB-SJH20-02
VB-SJH20-03A
However, the chain of custody

indicates sample transfer on
5-28-2021, instead of
sampling date, 4-28. 2-21, with
more sample sites than shown
in Plate No 2 (right) and no site
03A:
VB-SJH20-01
VB-SJH20-02
VB-SJH20-03
VB-SJH20-04
VB-SJH20-05
The discrepancy indicates that

the analysis of all samples
taken was not made available.
There was geotechnical

analysis of particle size and
composition only - and found
was another study that did
geophysical analysis in an
earlier study.
SEA DRAFT 2021 shows borrow

area for lagoon
also inside the channel

B-4
Figure 3-1 found on

Page 18 of the 2021 SEA
shows a graphic that
indicates geotechnical
(meaning no chemical or
toxicological analysis
was done) in and around
the "borrow" area. The
2021 VB-SJH20
sampling sites are
shown and in this figure
include VB-SJH20-04,
and VB-SJH20-05, for
which no corresponding
analysis was sent in the
Feb 25th
communication. These
are located to the south
of the borrow site.
Figure 3-1 also shows

reference numbers for
core samples taken with
the prefix CB:
CB-SJH20-41
CB-SJH20-01
CB-SJH20-42
CB-SJ90-21
CB-SJH20-02, 03 and
04
A search for these

sample reference numbers in the May, 2021 Final 103 compliance report, and Appendix A of
the 2018 IFR/EA revealed only one hit in appendix A, and this was for
CB-SJ90-21.
According to the bore log found, the CB sample designation prefix indicates samples taken in
1991, 31 years ago with no additional information found regarding the analysis.

B-5
Page 4 of Appendix 1: Sample 404b compliance 2018
3.2 Sediment Characteristics
Cut-6: Boring logs indicate primarily sandy deposits, with possible lenses of gravel or layers of
hard brown calcareous quartz sandstone, intermixed with soft clay or soft silt. Sand (SM) with
gravel fragments are described to -44.3 in boring CB-SJ90-21. Rock was found at the end of the
boring.
—————————————————————————————
In the middle of cultural resources discussion in the 2018 IFR/EA appears this in red:
======================================================================
There was no analysis beyond geophysical for the borrow area which is the area of particular
concern for the Condado Lagoon Estuarine Reserve. Analysis missing include sediment
chemistry, tissue chemistry and toxicology as was done in other areas of the
channel in 2020 to comply with MPRSA Section 102 requirements, not MPRSA Section 103, so
it is misleading to call the chemical and tox analysis done a 103 report. 102 governs dumping
in the trench and 102 governs dumping in different location.
The closest sampling site from 2020 to cut 6 area that enjoyed complete analysis was
Site Number M-A-S-1/ D-AC-C1 with information in the 103 report that indicated upon consult
with EPA no D-AC-C1 was performed because it was all nasty - no clay layer.

B-6
The composite sample analysis found in the report entitled section 103 compliance
which again involves no samples or analysis from the proposed borrow site either
inside the navigation channel or in the 15 acre area, raises serious concerns
recognized by 404(b) guidance, as it reflects the suitability of materials from the borrow
site as a nearby location. The TEL is the Threshold Effect Level , and the ERL is the
Effects Range Low.
From EPA’s hazardous substance site:

B-7

B-8
So the Corps has presented analysis of borrow only, nothing inside the Channel of Cut 6.
This analysis was limited to particle size and composition of the fill material for Condado
lagoon, and comments on the graphs sent from the tree sampling sites, that analyses different
core depths at each site all indicated concerns with the color of the samples, which according
to 404 (b) 1 indicates that chemical and toxicology analysis is needed before the suitability of
the fill material can be determined.
======================================================================
US ACE and EPA Guidance Document entitled: "Identifying, Planning, and Financing Beneficial
Use Projects Using Dredged Material Beneficial Use Planning Manual" October 2007 / EPA842-
B-07-001, states on page 9:
Material dredged in some of our major harbors is more likely to be contaminated because
this material is generally silt and clay particles to which contaminants can easily bind.
2.3 Beneficial use planning page 10
Prior to consideration of any dredged material placement option subject to CWA Section 404, the
material should be tested and evaluated under the procedures described in the CWA Section
404(b)(1) guidelines for compliance.
====================================================================
CWA 404 (b) (1): § 230.1 Subpart A—General Purpose and policy.
(c) Fundamental to these Guidelines is the precept that dredged or fill material should not be
discharged into the aquatic ecosystem, unless it can be demonstrated that such a discharge will not
have an unacceptable adverse impact either individually or in combination with known and/or
probable impacts of other activities affecting the ecosystems of concern.
(d) From a national perspective, the degradation or destruction of special aquatic sites, such as filling
operations in wetlands, is considered to be among the most severe environmental impacts covered
by these Guidelines. The guiding principle should be that degradation or destruction of special sites
may represent an irreversible loss of valuable aquatic resources.
§230.5 General procedures to be followed.
(c) Examine practicable alternatives to the proposed discharge, that is, not discharging into the waters
of the U.S. or discharging into an alternative aquatic site with potentially less dam- aging
consequences (§ 230.10(a)).
(i) If there is a reasonable probability of chemical contamination, conduct the appropriate tests
according to the section on Evaluation and Testing (§ 230.61).

B-9
Subpart B—Compliance With the Guidelines § 230.10 Restrictions on discharge.
Although all requirements in §230.10 must be met, the compliance evaluation procedures will
vary to reflect the seriousness of the potential for adverse impacts on the aquatic ecosystems
posed by specific dredged or fill material discharge activities.
(a) Except as provided under section 404(b)(2), no discharge of dredged or fill material shall be
permitted if there is a practicable alternative to the proposed discharge which would have
less adverse impact on the aquatic ecosystem, so long as the alternative does not have
other significant adverse environmental consequences.
(5) To the extent that practicable alternatives have been identified and evaluated under a Coastal Zone
Management program, a section 208 program, or other planning process, such evaluation shall be
considered by the permitting authority as part of the consideration of alternatives under the Guidelines.
Where such evaluation is less complete than that contemplated under this subsection, it must be sup-
plemented accordingly.
(b) No discharge of dredged or fill material shall be permitted if it:
(1) Causes or contributes, after consideration of disposal site dilution and dispersion, to
violations of any applica-ble State water quality standard;
(2) Violates any applicable toxic effluent standard or prohibition under section 307 of the Act;
(3) Jeopardizes the continued existence of species listed as endangered or threatened under the
Endangered Species Act of 1973, as amended, or results in likelihood of the destruction or ad-
verse modification of a habitat which is determined by the Secretary of Interior or Commerce, as
appropriate, to be a critical habitat under the Endangered Species Act of 1973, as amended. If an
exemption has been granted by the Endangered Species Committee, the terms of such exemption
shall apply in lieu of this subparagraph;
(4) Violates any requirement imposed by the Secretary of Commerce to pro- tect any marine
sanctuary designated under title III of the Marine Protection, Research, and Sanctuaries Act of
1972.
(c) Except as provided under section 404(b)(2), no discharge of dredged or fill material shall be
permitted which will cause or contribute to significant degradation of the waters of the United
States. Findings of significant degradation related to the proposed discharge shall be based upon
appropriate factual determinations, evaluations, and tests required by subparts B and G, after
consideration of subparts C through F, with special emphasis on the persistence and permanence of
the effects outlined in those subparts. Under these Guidelines, effects contributing to significant
degradation considered individually or collectively, include:
(1) Significantly adverse effects of the discharge of pollutants on human health or welfare,
including but not limited to effects on municipal water supplies, plankton, fish, shellfish, wildlife,
and special aquatic sites.
(2) Significantly adverse effects of the discharge of pollutants on life stages of aquatic life and
other wildlife dependent on aquatic ecosystems, including the transfer, concentration, and spread of

B-10
pollutants or their by- products outside of the disposal site through biological, physical, and
chemical processes;
(3) Significantly adverse effects of the discharge of pollutants on aquatic ecosystem diversity,
productivity, and stability. Such effects may include, but are not limited to, loss of fish and wild-
life habitat or loss of the capacity of a wetland to assimilate nutrients, purify water, or reduce wave
energy; or
(4) Significantly adverse effects of discharge of pollutants on recreational, aesthetic, and economic
values.
(d) Except as provided under section 404(b)(2), no discharge of dredged or fill material shall be
permitted unless appropriate and practicable steps have been taken which will minimize potential
adverse impacts of the discharge on the aquatic ecosystem. Subpart H identifies such possible
steps.
§230.21 Suspended particulates/turbidity.
The extent and persistence of these adverse impacts caused by discharges depend upon the relative
increase in suspended particulates above the amount occurring naturally, the duration of the higher levels,
the current patterns, water level, and fluctuations present when such discharges occur, the vol- ume, rate, and
duration of the discharge, particulate deposition, and the seasonal timing of the discharge.
§ 230.22 Water.
(b) Possible loss of environmental characteristics and values: The discharge of dredged or fill material can
change the chemistry and the physical characteristics of the receiving water at a disposal site through the
introduc- tion of chemical constituents in suspended or dissolved form. Changes in the clarity, color, odor,
and taste of water and the addition of contaminants can reduce or eliminate the suitability of water bodies
for populations of aquatic organisms, and for human consumption, recreation, and aes- thetics.
Subpart E—Potential Impacts on Special Aquatic Sites

NOTE: The impacts described in this subpart should be considered in making the factual determinations and the findings of
compliance or non-compliance in subpart B. The definition of special aquatic sites is found in § 230.3(q–1).
§ 230.43 Vegetated shallows.
(a) Vegetated shallows are perma- nently inundated areas that under nor- mal circumstances support commu-
nities of rooted aquatic vegetation, such as turtle grass and eelgrass in estuarine or marine systems as well
as a number of freshwater species in rivers and lakes.
(b) Possible loss of values: The discharge of dredged or fill material can smother vegetation and benthic
organisms. It may also create unsuitable conditions for their continued vigor by: (1) Changing water
circulation patterns; (2) releasing nutrients that increase undesirable algal populations; (3) releasing
chemicals that adversely affect plants and animals; (4) increasing turbidity levels, thereby reducing light
penetration and hence photosyn- thesis; and (5) changing the capacity of a vegetated shallow to stabilize
bottom materials and decrease channel shoaling. The discharge of dredged or fill material may reduce the
value of vegetated shallows as nesting, spawning, nursery, cover, and forage areas, as well as their value in

B-11
protecting shorelines from erosion and wave ac- tions. It may also encourage the growth of nuisance
vegetation.
§ 230.44 Coral reefs.
(a) Coral reefs consist of the skeletal deposit, usually of calcareous or silicaceous materials, produced by the
vital activities of anthozoan polyps or other invertebrate organisms present in growing portions of the reef.
(b) Possible loss of values: The discharge of dredged or fill material can adversely affect colonies of reef
build- ing organisms by burying them, by releasing contaminants such as hydro- carbons into the water
column, by reducing light penetration through the water, and by increasing the level of suspended
particulates. Coral organisms are extremely sensitive to even slight reductions in light penetration or
increases in suspended particulates. These adverse effects will cause a loss of productive colonies which in
turn provide habitat for many species of highly specialized aquatic organisms.
§230.31 Fish, crustaceans, mollusks, and other aquatic organisms in the food web.
(a) Aquatic organisms in the food web include, but are not limited to, finfish, crustaceans, mollusks, insects,
annelids, planktonic organisms, and the plants and animals on which they feed and depend upon for their
needs. All forms and life stages of an organism, throughout its geographic range, are included in this
category.
(b) Possible loss of values: The discharge of dredged or fill material can variously affect populations of fish,
crustaceans, mollusks and other food web organisms through the release of contaminants which adversely
affect adults, juveniles, larvae, or eggs, or result in the establishment or prolifera- tion of an undesirable
competitive species of plant or animal at the expense of the desired resident species. Sus- pended
particulates settling on attached or buried eggs can smother the eggs by limiting or sealing off their ex-
posure to oxygenated water. Discharge of dredged and fill material may result in the debilitation or death of
sed- entary organisms by smothering, exposure to chemical contaminants in dissolved or suspended form,
exposure to high levels of suspended particulates, reduction in food supply, or alteration of the substrate upon
which they are dependent. Mollusks are particularly
40 CFR Ch. I (7–1–10 Edition)
sensitive to the discharge of material during periods of reproduction and growth and development due
primarily to their limited mobility. They can be rendered unfit for human consumption by tainting, by
production and accu- mulation of toxins, or by ingestion and retention of pathogenic organisms, vi- ruses,
heavy metals or persistent syn- thetic organic chemicals. The discharge of dredged or fill material can
redirect, delay, or stop the reproduc- tive and feeding movements of some species of fish and crustacea, thus
pre- venting their aggregation in accus- tomed places such as spawning or nursery grounds and potentially
leading to reduced populations. Reduction of de- trital feeding species or other rep- resentatives of lower
trophic levels can impair the flow of energy from primary consumers to higher trophic levels. The reduction
or potential elimination of food chain organism populations de- creases the overall productivity and nutrient
export capability of the ecosystem.

B-12
TESTING:
Subpart G—Evaluation and Testing

§230.60 General evaluation of dredged or fill material.
The purpose of these evaluation procedures and the chemical and biological testing sequence outlined in
§230.61 is to provide information to reach the determinations required by §230.11. Where the results of prior
evaluations, chemical and biological tests, scientific research, and experience can provide information helpful
in making a determination, these should be used. Such prior results may make new testing unnecessary. The
information used shall be documented. Where the same information applies to more than one determination,
it may be documented once and referenced in later determinations.
(a) If the evaluation under paragraph (b) indicates the dredged or fill material is not a carrier of
contaminants, then the required determinations pertaining to the presence and effects of contaminants
can be made without testing. Dredged or fill material is most likely to be free from chemical, biological,
or other pollutants where it is composed primarily of sand, gravel, or other naturally occurring inert
material. Dredged material so composed is generally found in areas of high current or wave energy such
as streams with large bed loads or coastal areas with shifting bars and channels. However, when such
material is discolored or contains other indications that contaminants may be present, further
inquiry should be made.
============================================================================
BENEFICIAL USES OF DREDGED MATERIAL EM 1110-2-5026, US ACE
PAGE 2B

B-13
==========================================================================
NOTE DESCRIPTION>>>>>>>>>
The analysis of the new 15 acre fill site was based on a recent geo technical study (no chemical
or tox analysis) where we were sent upon our request the bore logs, chain of custody, and
analysis graphs by email. These were sent loose and not consolidated or interpreted in a formal
report by certified analytical lab. The graphs raise concerns in that verbal characteristics of the
samples taken from the new fill area needed to cap the toxic fill from the channel, all indicate
either yellow to olive, or dark gray coloration. According to Subpart G—Evaluation and Testing
§230.60, the coloration of samples is also an indicator, as are uses and the fact SJH receives
urban and industrial runoff, is a very busy port, and composite samples showed hazardous
substances, all reflect the likely hood of contamination of the water body to be dredged, so
that this analysis of dredge material to be disposed of in the Condado Lagoon Estuary
Reserve, must prove itself suitable through additional investigation.
To put this differently because it is very confusing, the Corps presents a very good analysis
document for samples taken inside SJH, produced by an accredited laboratory but then
mistakingly entitles that study Final MPRSA 103 compliance, 2021. According to page ES-1-P1
of the 2021 document :
Note this does mention the Condado Lagoon fill. Samples tested actually support section 102
compliance to MPRSA. However needed for 404 (b) document is section 103 compliance of
MPRSA, which governs disposal in areas not already designated for disposal, such as disposal in
the Condado Lagoon. However, this good analysis does not involve analysis of the Cut 6 inside
channel dredge proposed for borrow, nor does it include the 15 acre new borrow site in the SJH.
This is the analysis is needed for disposal into the ODMDS (Puerto Rico trench)
The lab conducting the study provided a strong analysis that raises serious concerns about
contamination in the borrow site, however this analysis avoided including cut 6 in the Nav
channel and the borrow site in this analysis. Later a study was done of what the Corps calls
geotechnical information - to include grain size, composition and coloration. Unfortunately there
were problems with this study including no official report, analytical interpretation and access to
all relevant documents needed to determine the CWA method compliance.
The graphs sent by email by request, and not accessible to the public, raise alarms of coloration
that §230.60, indicate "need further inquiry." The Corps SEA understands Cut 6 borrow inside the
channel is likely not suitable which is why it expanded the project creating a new 15 acre site to
“cap" the toxins, with what they incorrectly interpreted from three core sample evaluations as
that material is suitable for capping. There is no discussion of the turbidity and associated toxins
that will be associated with the fill of the Cut 6 dredge materials inside the channel adjacent and

B-14
well done studies imply are seriously contaminated and clearly unsuitable for protected
water bodies, listed species and estuarine lagoon. Of course the CWA also discusses at
some length the concerns regarding source contamination related to the water body and here
the Corps does a good job describing impacts to the San Juan Bay Estuary in general as
receptical for dense urban and industrial development.
This is outside of the channel footprint and excavation in this and other areas could likely
destabilize channel integrity and result in collapses that ends up blocking current navigation.
Comments from shipping interests express similar concerns in Appendix J of the IRF/EA (2018).
Contamination effecting seas grass

U. S. STANDARD SIEVE OPENING IN INCHES U. S. STANDARD SIEVE NUMBERS HYDROMETER
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30
PERCENT COARSER BY WEIGHT

PERCENT FINER BY WEIGHT
60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAIN SIZE IN MILLIMETERS
GRAVEL SAND
COBBLES SILT OR CLAY
COARSE FINE COARSE MEDIUM FINE
Visual %
Sample No. Depth Classification Munsell Shell (est) %CO 3 GS Org % wn LL PL PI
PROJECT San Juan Harbor Improvement
1 2.0 to 2.2 Ft. SAND, clayey, mostly subrounded 2.5Y 6/8 30
fine-grained sand-sized quartz, some
clay, some fine to coarse-grained
BORING NO. VB-SJH20-01
gravel and sand-sized shell, olive
yellow (SC) BORING ELEV. -32.2 Ft., MLLW
GRADATION CURVES DATE 6/29/2021

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
gravel and sand-sized shell, olive
yellow (SC) BORING ELEV. -32.2 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
3 6.0 to 6.2 Ft. SAND, clayey, mostly subrounded 5Y 4/1 20
fine-grained sand-sized quartz, little
clay, little medium to coarse-grained
sand-sized shell, dark gray (SC)
BORING ELEV. -32.2 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
4 8.0 to 8.2 Ft. SAND, poorly graded with clay, mostly 5Y 4/1 5
subrounded fine-grained sand
sized-quartz, few clay, trace
coarse-grained sand-sized shell, dark
gray (SP-SC) BORING ELEV. -32.2 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
1 0.5 to 0.7 Ft. SAND, silty, mostly subrounded 10YR 4/1 25
silt, little fine to coarse-grained gravel
and sand-sized shell, dark gray (SM)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
2 2.0 to 2.2 Ft. SAND, silty, mostly subrounded 10YR 4/1 20
silt, little fine to coarse-grained gravel
and sand-sized shell, dark gray (SM)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
3 4.0 to 4.2 Ft. SAND, poorly-graded with silt, mostly 10YR 4/1 20
subrounded fine-grained sand-sized
quartz, few silt, little coarse-grained
sand-sized shell, dark gray (SP-SM)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
4 5.5 to 5.7 Ft. SAND, silty,mostly subrounded 10YR 4/1 5
silt, trace medium to coarse-grained
sand-sized shell, dark gray (SM)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
gravel and sand-sized shell, dark gray
(SC) BORING ELEV. -25.6 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
6 8.5 to 8.7 Ft. SAND, silty, mostly subrounded 2.5Y 3/1 40
silt, some fine to coarse-grained
gravel and sand-sized shell, very dark
gray (SM) BORING ELEV. -25.6 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
7 11.0 to 11.2 Ft. SAND, silty, mostly subrounded 2.5Y 3/1 10
fine-grained sand-sized quartz, few
silt, few medium to coarse-grained
sand-sized shell, very dark gray (SM)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
clay, some coarse-grained
BORING NO. VB-SJH20-03A
gravel-sized shell, dark gray (SC)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
clay, little medium to coarse-grained
sand-sized shell, dark gray (SC)

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
clay,little fine to coarse-grained gravel
and sand-sized shell, very dark gray
(SC) BORING ELEV. -22.4 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
4 7.0 to 7.2 Ft. SAND, poorly-graded with silt, mostly 5Y 3/1 5
subrounded fine-grained sand-sized
quartz, few silt, trace fine-grained
gravel-sized shell, very dark gray
(SP-SM) BORING ELEV. -22.4 Ft., MLLW

SAJ FORM 2087
JUN 02
1 3 1 3
6 4 3 2 12 1 4 2 8 3 4 6 8 10 1416 20 30 40 50 70 100 140 200
100 0
90 10
80 20
70 30

60 40
50 50
40 60
30 70
20 80
10 90
0 100
500 100 50 10 5 1 0.5 0.1 0.05 0.01 0.005 0.001
GRAVEL SAND
Visual %
5 10.0 to 10.2 Ft. SAND, silty, mostly subrounded 5Y 3/1 25
silt, little medium to coarse-grained
sand-sized shell, very dark gray (SM)

SAJ FORM 2087
JUN 02
Boring Designation VB-SJH20-01
DIVISION INSTALLATION SHEET 1
DRILLING LOG South Atlantic Jacksonville District OF 2 SHEETS
1. PROJECT 9. SIZE AND TYPE OF BIT See Remarks
San Juan Harbor Improvement 10. COORDINATE SYSTEM/DATUM HORIZONTAL VERTICAL
State Plane, PR/VI (U.S. Ft.) MLLW

2. BORING DESIGNATION LOCATION COORDINATES 11. MANUFACTURER'S DESIGNATION OF DRILL AUTO HAMMER
VB-SJH20-01 X = 762,295 Y = 885,042 MANUAL HAMMER
3. DRILLING AGENCY CONTRACTOR FILE NO. DISTURBED UNDISTURBED (UD)
12. TOTAL SAMPLES
Corps of Engineers - CESAJ 4 0
4. NAME OF DRILLER 13. TOTAL NUMBER CORE BOXES 0
14. ELEVATION GROUND WATER
5. DIRECTION OF BORING DEG. FROM BEARING
VERTICAL VERTICAL STARTED COMPLETED
15. DATE BORING
INCLINED 04-28-21 04-28-21
6. THICKNESS OF OVERBURDEN N/A 16. ELEVATION TOP OF BORING -32.2 Ft.
17. TOTAL RECOVERY FOR BORING N/A
7. DEPTH DRILLED INTO ROCK N/A
18. SIGNATURE AND TITLE OF INSPECTOR
8. TOTAL DEPTH OF BORING 9.2 Ft. ,
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
ELEV. DEPTH CLASSIFICATION OF MATERIALS % OR REMARKS
(ft) (ft) REC. UD
-32.2 0.0
SAND, clayey, mostly subrounded fine-grained 0
sand-sized quartz, some clay, some fine to
coarse-grained gravel and sand-sized shell,
2.5Y 6.5/8 (SC)
-34.2
1
From El. -34.7 to -36.7 Ft., mostly subrounded
fine-grained sand-sized quartz, some clay,
some fine to coarse-grained gravel and
sand-sized shell, 2.5Y 6.5/8
-36.2
2
fine-grained sand-sized quartz, little clay, little 5
medium to coarse-grained sand-sized shell, 5Y
4/1
-38.2
3
-39.7 7.5
SAND, poorly-graded with clay, mostly
subrounded fine-grained sand sized-quartz, few -40.2
clay, trace coarse-grained sand-sized shell, 5Y 4
4/1 (SP-SC)
-41.4 9.2 -41.4
NOTES: Abbreviations:
10
1. USACE Jacksonville is the custodian for
these original files.
2. Soils are field visually classified in

accordance with the Unified Soils Classification
System.
3. Laboratory Testing Results
SAMPLE SAMPLE LABORATORY

ID DEPTH CLASSIFICATION
------------------------------------------------------------
1 2.0/2.2 SC*
2 4.0/4.2 SC*
3 6.0/6.2 SC*
4 8.0/8.2 SP-SC*
15
SAJ FORM 1836 (Continued)
JUN 02
INSTALLATION SHEET 2
DRILLING LOG (Cont. Sheet) Jacksonville District OF 2 SHEETS
PROJECT COORDINATE SYSTEM/DATUM HORIZONTAL VERTICAL

San Juan Harbor Improvement State Plane, PR/VI (U.S. Ft.) MLLW
LOCATION COORDINATES ELEVATION TOP OF BORING
X = 762,295 Y = 885,042 -32.2 Ft.
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
(ft) (ft) REC. UD
*Lab visual classification based on gradation 15

curve
20
25
30
35
SAJ FORM 1836-A
JUN 02

VB-SJH20-02 X = 762,515 Y = 884,641 MANUAL HAMMER
12. TOTAL SAMPLES
15. DATE BORING
INCLINED 04-28-21 04-28-21
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
(ft) (ft) REC. UD
-25.6 0.0
SAND, silty, mostly subrounded fine-grained 0
sand-sized quartz, some silt, little fine to -26.1
coarse-grained gravel and sand-sized shell, 1
10YR 4/1 (SM)

fine-grained sand-sized quartz, some silt, little -27.6
fine to coarse-grained gravel and sand-sized 2
shell, 10YR 4/1
-28.6 3.0
SAND, poorly-graded with silt, mostly
subrounded fine-grained sand-sized quartz, few
silt, little coarse-grained sand-sized shell, 10YR -29.6
4/1 (SP-SM) 3
-30.6 5.0
SAND, silty, mostly subrounded fine-grained 5
sand-sized quartz, some silt, trace medium to -31.1
coarse-grained sand-sized shell, 10YR 4/1 4
(SM)
-32.1 6.5
SAND, clayey, mostly subrounded fine-grained
sand-sized quartz, little clay, some fine to -32.6
coarse-grained gravel and sand-sized shell, 5
-33.1 7.5
2.5Y 4/1 (SC)
SAND, silty, mostly subrounded fine-grained
sand-sized quartz, little silt, some fine to
coarse-grained gravel and sand-sized shell, -34.1
2.5Y 3/1 (SM) 6
fine-grained sand-sized quartz, few silt, few
medium to coarse-grained sand-sized shell,
2.5Y 3/1 10
-36.6
7
-38.4 12.8 -38.4


15
JUN 02

X = 762,515 Y = 884,641 -25.6 Ft.
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
(ft) (ft) REC. UD
accordance with the Unified Soils Classification 15

System.
3. Laboratory Testing Results

------------------------------------------------------------
1 0.5/0.7 SM*
2 2.0/2.2 SM*
3 4.0/4.2 SP-SM*
4 5.5/5.7 SM*
5 7.0/7.2 SC*
6 8.5/8.7 SM*
7 11.0/11.2 SM*
*Lab visual classification based on gradation 20

curve
25
30
35
SAJ FORM 1836-A
JUN 02
Boring Designation VB-SJH20-03A

VB-SJH20-03A X = 762,884 Y = 884,487 MANUAL HAMMER
12. TOTAL SAMPLES
15. DATE BORING
INCLINED 04-28-21 04-28-21
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
(ft) (ft) REC. UD
-22.4 0.0
SAND, clayey, mostly subrounded fine-grained 0
sand-sized quartz, little clay, some
coarse-grained gravel-sized shell, 5Y 4/1 (SC)
-23.9
1

fine-grained sand-sized quartz, some clay, little
medium to coarse-grained sand-sized shell, 5Y -26.4
4/1 2
From El. -27.4 to -28.4 Ft., mostly subrounded 5

fine-grained sand-sized quartz, little clay,little -27.9
fine to coarse-grained gravel and sand-sized 3
-28.4 6.0
shell, 5Y 3/1
SAND, poorly-graded with silt, mostly
subrounded fine-grained sand-sized quartz, few
silt, trace fine-grained gravel-sized shell, 5Y 3/1 -29.4
(SP-SM) 4
-30.4 8.0
SAND, silty, mostly subrounded fine-grained
sand-sized quartz, little silt, little medium to
coarse-grained sand-sized shell, 5Y 3/1 (SM)
-32.4
10
5
-34.2 11.8 -34.2


accordance with the Unified Soils Classification
System.
15
JUN 02
Boring Designation VB-SJH20-03A

X = 762,884 Y = 884,487 -22.4 Ft.
N-VALUE
LEGEND
SAMPLE
BOX OR
BLOWS/
RQD
1 FT.
(ft) (ft) REC. UD
3. Laboratory Testing Results 15

------------------------------------------------------------
1 1.5/1.7 SC*
2 4.0/4.2 SC*
3 5.5/5.7 SC*
4 7.0/7.2 SP-SM*
5 10.0/10.2 SM*
*Lab visual classification based on gradation

curve
20
25
30
35
SAJ FORM 1836-A
JUN 02
/
VB-SJH20-01 !
O
Cu
t-6
VB-SJH20-02 !
O AN
BO
RR VB-SJH20-03A!
O EG
O AD
CU W O
T- AR CH
6 EA AN
NE
L
Legend
O
! Vibracore Boring
Borrow Area
Channel
0 0.05 0.1 0.2 0.3 0.4

Miles
Dsn by:
GEOTECHNICAL DRAWINGS BUN
Dwn by:
PLATE NO.
NOT FOR CONSTRUCTION BUN DEPARTMENT OF THE ARMY
JACKSONVILLE DISTRICT, CORPS OF ENGINEERS
Ckd by:
SAN JUAN HARBOR BUN JACKSONVILLE, FLORIDA
2
BORING LOCATION MAP Dated:
3SEP21

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APPENDIX B ANALYSIS CZ-2022-1109-029

The May 2021 103 report summary indicates: pg. ES-1P-1

Only new site considered in the May 2021

Cut 6 and borrow area are west

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

File Name: borrow-VC-1-3a-logs.pdf - drilling logs (6 pages)

Sampling was done on 4-28-2021

and analysis was done at 6-29-2021

Boring log date screen shot and chain of

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

The three sample sites from

However, the chain of custody

The discrepancy indicates that

There was geotechnical

SEA DRAFT 2021 shows borrow

also inside the channel

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

Figure 3-1 found on

Figure 3-1 also shows

A search for these

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

Page 4 of Appendix 1: Sample 404b compliance 2018

3.2 Sediment Characteristics

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

From EPA’s hazardous substance site:

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

§230.5 General procedures to be followed.

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

(b) No discharge of dredged or fill material shall be permitted if it:

PO Box 750 Culebra, PR. 00775 coralations@gmail.com

§230.21 Suspended particulates/turbidity.

Subpart E—Potential Impacts on Special Aquatic Sites

§ 230.43 Vegetated shallows.

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§ 230.44 Coral reefs.

40 CFR Ch. I (7–1–10 Edition)

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Subpart G—Evaluation and Testing

BENEFICIAL USES OF DREDGED MATERIAL EM 1110-2-5026, US ACE

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PO Box 750 Culebra, PR. 00775 coralations@gmail.com

Contamination effecting seas grass

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PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021

PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021

PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021

PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021

PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021

PERCENT COARSER BY WEIGHT

GRADATION CURVES DATE 6/29/2021