| Action Date |
Action |
Description |
DEC Staff |
| 12/22/1976 |
Update or Other Action |
Memorandum of Understanding Pribilof Land Selections. Future Transfers. NMFS agrees to effect in the future to the Tanadgusix Corporation of such houses or other buildings on St. Paul Island as may become unnecessary to the carrying out of NMFS responsibilities under the Fur Seal Act of 1966, 16 U.S.C. 1151, or its successor statute. Such transfers will be carried out by applicable law and regulations.
Joint Use Areas. Areas not shown on Exhibits. Further areas not shown on the attached exhibits which are available for selection by the appropriate Village Corporation, but subject to joint management (category 3 of paragraph 1b above) are as follows: 1) Polovina/Big Lake "Vehicle Boneyard" (Truck Dump)-St. Paul, Scoria Pits. The Telegraph Hill, Polovina and Lake Hills Borrow (scoria) pits on St. Paul are being retained by NMFS subject to joint management, namely TDX Corp. may use scoria from these pits free of charge, subject to priority use by NMFS, for so long as these pits are under control of NMFS. Sanitary Landfills and "Vehicle Boneyards" (truck dumps) which are subject to joint management may be used free of charge for their intended purposes by the nonowning party. |
Louis Howard |
| 12/30/1984 |
Update or Other Action |
According to the "Transfer of Property Agreement" signed in 1984, the United States agrees to convey the certain real properties on St. Paul Island, Alaska to the local and state entitites. These entities agree to accept all right, title, and interest to the real property.
Table 1 Conveyance of Real Property on St. Paul Island, Alaska According to the 1984 Transfer of Property Agreement: Polovina Borrow Pit (Parcel 5), Accepting entitiy-TDX, Conditions-City shall have free and unrestricted access and use of materials for purpose of road and airport maintenance. |
Louis Howard |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV).
Residents reported a buried vehicle boneyard existed at the base of Little Polovina Hill. One vehicle and one tire was found on the ground adjacent to the road on the east side of the hill. Potential sources of contamination are any oils or fuels associated with the visible vehicle and the potentially buried vehicles. No surface contamination was evident during the site visit. Recommended actions were to conduct a geophysical survey prior to sampling to determine the potential location of vehicles. |
Jennifer Roberts |
| 9/30/1993 |
Update or Other Action |
U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report.
Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. |
Ray Dronenburg |
| 10/1/1993 |
Update or Other Action |
City of Saint Paul Public Notice to: Contractors/Regulatory Agencies. The City of Saint Paul hereby notifies you of the potential presence of hazardous materials on the island. The attached maps should be used as a general reference for identification of potential hazardous materials in planning your project. For the proposed utility projects within the Harbor Area planned for construction during the summer of 1993, the City does not believe that any hazardous materials are present. However, landowners and contractors are responsible for assuring compliance with federal and state regulations and should not rely on information provided herein.
If contractors on City Projects (and/or City Property) or on projects which are to become property of the City, believes that hazardous materials may or have been encountered, they must immediately cease any and all construction activity, immediately notify the Public Works Director and City Manager orally and in writing and comply with the attached guidelines. No further construction work can be done unless explicitly authorized in writing by the Public Works Director and City Engineer.
City of Saint Paul Hazardous Materials Procedures-
1) Review attached maps. If project includes construction within areas noted as potentially contaminated or if you encounter potential environmental contamination during construction, the following procedures must be followed:
2) Notify NOAA and the City of the potential problem;
3) conduct standard ADEC screening tests and provide in writing at a minimum-to NOAA and the City: a) exact location of area and land ownership; b) Quantity of material; c) Characteristics of material and contamination; d) documentation the contractor has certified persons to 1) conduct screening tests and 2) handling and disposal of hazardous wastes; e) Provide a detailed cost estimate for the initial screening, stockpiling, and testing of the material including labor, materials, equipment, testing, etc.; f) provide a schedule for the final removal of any stockpiled materials; g) identify the location and specifications for stockpiling the materials.
4) If the material does not appear to require remediation according to ADEC and EPA regulations, the City Engineer and City Public Works Director will authorize the construction to proceed.
5) If the initial screening per ADEC and EPA regulations indicates that the material must be stockpiled for further testing (NOTE to file states should not be removed until an approved plan is submitted), then the contractor must comply with the protocol approved by NOAA and the City. At a minimum, this protocol would include the stockpiling of excavated materials, the placement of an impermeable liner in the construction utility corridor, the installation of utility lines covered with non-contaminated materials, and the testing of stockpiled materials for analysis and disposal per ADEC and EPA regulations.
For additional information see site file. |
Ray Dronenburg |
| 10/19/1993 |
Update or Other Action |
Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation.
Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it.
The current construction season has passed, to allow us the necessary time to schedule the equipment, NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May, 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. |
Ray Dronenburg |
| 8/26/1994 |
Update or Other Action |
Received the Oil Spill Consultants Chemical Data Acquisition and Quality Control Plan for Hazardous and Toxic Waste Removal and Disposal August 15, 1994 document. This document covered TPA -3, TPA-5, TPA-1. It was for a removal action to start in August 1994 of drums containing waste products at these sites. Screening will be for volatile organic compounds, corrosive liquids, combustible compounds, hazardous waste liquids/solids, waste oxidizing substances, and chlorinated hydrocarbons. Eventual disposal will be to Seattle WA for proper disposal by Basin Oil. |
Ray Dronenburg |
| 11/2/1994 |
Update or Other Action |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. |
Jennifer Roberts |
| 12/19/1994 |
Update or Other Action |
Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy-Re: outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes.
NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island.
These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump.
18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. |
Simon Mawson |
| 6/1/1995 |
Site Added to Database |
Reported buried vehicle boneyard. |
Ray Dronenburg |
| 5/2/1996 |
Site Ranked Using the AHRM |
Initial ranking by Shannon and Wilson. |
S&W |
| 1/17/1997 |
Update or Other Action |
Letter to Minh Trinh NOAA PPO PM, UST comments to be covered under separate comment letter relating to any and all activities relating to removal of USTs. Comments mainly for portion of the plan that deals with debris removal and stockpiling of contaminated soils.
a) The stockpile plan identified in section seven (7) is approved as written.
Debris Removal (vehicles). The Department does not assume nor will the contractor "assume" that vehicles identified as debris under the TPA are free from hydrocarbons. In fact, the Department will require that all vehicles be checked for fluids before being compacted and stockpiles for shipment off island.
Open Burning. The department has promulgated new regulations regarding open burning. The document dated January 18, 1997 has been provided by the contractor. |
Ray Dronenburg |
| 8/29/1997 |
Update or Other Action |
The National Oceanic and Atmospheric Administration (NOAA) refers to this site as the Polovina Hill stockpile and has designated it as non-Two Party Agreement (NTPA; NOAA 1996) site 47. The site is located seven miles northeast of the Village of St. Paul
on St. Paul Island, Alaska (Figures 1 and 2). PCS from excavations conducted in the village in 1997 was brought to this site for long-term storage. NOAA placed the petroleum contaminated soils (PCS) on impervious liner and covered the stockpile with a liner.
NOAA selected the Polovina Hill stockpile site in 1997 to store contaminated soils removed from the following USTs sites on St. Paul Island:
1. Former Gas Station (TPA 09N). The former gas station was adjacent to the entrance of the Cascade Building. Two 3,000-gallon (estimated) USTs were removed, cleaned, and recycled. An estimated 350 cubic yards (CY) of PCS were transported to the stockpile at Polovina Hill.
2. Decommissioned Power Plant (DPP) (TPA 09C). A 10,000-gallon UST was removed, cleaned, and recycled. A second UST of the same size was closed in place. Approximately 40 CY of PCS were hauled from the DPP to the stockpile. [Note: NOAA removed the second UST at the DPP on November 2002. PCS excavated
during this removal was transported to the stockpile at the Blubber Dump and was subsequently treated and disposed.]
3. Municipal Garage (a.k.a. equipment shed) (TPA 09E). Two 8,000-gallon USTs were removed, cleaned, and recycled. An estimated 375 CY of PCS were transported to the stockpile at Polovina Hill.
Stockpiled soils were segregated according to type of contamination (i.e., diesel or gasoline). NOAA constructed the stockpiles in accordance with ADEC standards for long-term stockpiling (Guidance for Storage, Remediation, and Disposal of NON-UST Petroleum Contamianted Soils, ADEC July 29, 1991). The stockpile soil quantity was initially estimated at 777 CY but later determined to be only about 400 CY. The stockpile footprint was approximately 5,050 square feet. |
Ray Dronenburg |
| 5/20/1998 |
Update or Other Action |
Laura Ogar Solid Waste Program re: Expectations for Remaining Work and Regulatory Compliance for Solid Waste Projects Pribilof Islands. Of primary importance to the Department will be NOAA's assessments of the source areas (SA) to identify the extent of solid waste and any solid waste impacts at each site. Specific expectations for the SA's include:
Documentation at SA's containing buried waste must include and estimation of the footprint area and depth of the waste material and include the site longitude and latitude to accurately identify the waste disposal area. Information on groundwater (depth to, gradient, etc.) must also be provided.
Information must be provided on the depth to groundwater as a potential receptor for contamination if buried waste is present and/or suspected surface contamination is sufficient to warrant concerns for leaching. Where surface debris has been removed, the Site Investigation will be required to include evidence to support a conclusion that surface contamination does not exist.
Any surface debris removal must be fully documented to include a description of the volumes and types of wastes removed, and identify the approved final disposal location of any wastes removed from a SA through tipping fees, shipping records, etc.
Locations where buried waste will remain in the ground, solid waste landfill closure standards of 18 AAC 60 must be met. Typical landfill closure standards include the placement of final cover over the buried waste footprint to minimize infiltration and erosion. The applicable closure standards for the individual sites should be discussed with the SW Program staff prior to the development of a closure plan being developed. A closure plan must be submitted to the SW Program for review and approval prior to work being performed.
Permanent markers or survey monuments must be established from which the exact location of a facility can be determined. A notation must be recorded on the deed of the property containing the waste disposal site stating that the land has been used as a landfill and future use of the land may be restricted in order to protect and maintain the final cover and any monitoring devices in place.
Post closure monitoring for a period of five (5) years following the placement of final cover and landfill closure. Post closure monitoring will include but may not be limited to annual visual monitoring of the sites and required looking for signs of damage settlement or erosion. Surface and or ground water monitoring may be required if the department finds that pollution from the facility is likely to endanger public health or cause a violation of the water quality standards in 18 AAC 70. |
Ray Dronenburg |
| 4/7/1999 |
Meeting or Teleconference Held |
Restoration Advisory Board Meeting held at the Captain Cook Hotel. Risk based cleanup under Alaska cleanup rules: 18 AAC 75 Methods 1, 2, 3, 4 presented. Public Law 104-91 as it pertains to community issues and concerns related to cleanup and local hire, NOAA organizational chart, accounting of budget for all funds received, uses of the funds requested again by ADEC as was presented in 1/6/999 letter to NOAA was discussed at the RAB meeting. Finally discussed projects planned for the future at the Pribilofs, how clean is clean and whether or not community buy in is required to assign a no further remedial action required or closure of sites for either island. Ray Dronenburg announced that as of April 5, 1999 he is no longer the project manager for the site, Louis Howard is the new project manager for ADEC.
|
Ray Dronenburg |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation.
Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard.
|
Louis Howard |
| 8/23/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into TPA 3's closure confirmation sampling plan. |
Louis Howard |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 3/3/2000 |
Site Closure Approved |
Staff reviewed and approved the Draft Closure Confirmation Report for TPA Site No. 3, Little Polovina Hill Vehicle Boneyard. Based on a review of the data, DEC concurs that no further action is warranted at the site and can be considered closed. The following project objectives appeared to have been met:
1) no releases of petroleum hydrocarbons or other hazardous substances have occurred;
2) the boundaries of the site have been adequately mapped;
3) surface debris appears to have been removed from the site;
4) no erosion, seepage or other settlement is occurring; and
5) no buried debris is located at the site based on the geophysical survey.
DEC will not require NOAA to conduct further investigation or remedial action at this site. However, please note that DEC reserves all of its rights under 18 AAC 75, 18 AAC 60, and AS 46 to require NOAA to conduct further investigation and/or remedial action if information indicates the site conditions pose a risk to human health, safety and welfare, and of the environment. |
Louis Howard |
