| Action Date |
Action |
Description |
DEC Staff |
| 7/9/1944 |
Update or Other Action |
ST. GEORGE ISLAND BECOMES MONITOR (Unit 25 Monitor Site XP1-022)- The monitor station at Cape Sarichef, having proven unsatisfactory from an electronic point of view, surveys were ordered to determine a more suitable location. On 8 and 9 July, 1944, a party which, included several radio technicians, and a group from the Cutter CLOVER, set up a temporary monitor station on St. George Island, one of the Pribilof group (St. Paul - Unit 60 Double Slave), with which they observed the signals of the Loran rates one and two. The location of this temporary installation was on a knoll to the southeast of St. George Village.
Not only were the electronics results satisfactory at this location, but the surroundings were such as to make the establishment of a permanent station quite feasible. At the village of St. George, there was a landing with a small derrick for handling supplies, roads leadings toward the proposed Loran site, a water supply, and electric power which would be available in an emergency. The other sites visited by this survey party were less desirable in one way or another. Headquarters, on receipt of the recommendations of the District Coast Guard Officer, authorized the establishment of this new station, which was to be constructed by a district engineering force.
A party for this purpose left Ketchikan on 21 August, and construction began immediately upon their arrival. The station was commissioned on 4 December, 1944, becoming Unit 95. The Cape Sarichef station, Unit 25, relinquished the monitoring duty
The Coast Guard disestablished this site before 1979. The Coast Guard has been unable to locate additional information on the status of the structures, though it assumes that the structures were dismantled as per the terms of the Coast Guard's permit to occupy the property. |
Louis Howard |
| 10/31/1983 |
Update or Other Action |
Disposal of Federal property on Pribilof Islands (the Pribilofs)- (a) Submission to Congress of property transfer document - Any provision of law relating to the transfer & disposal of Federal property to the contrary notwithstanding, the Secretary, after consultation with the Secretary of the department in which the Coast Guard is operating, is authorized to bargain, grant, sell or otherwise convey, on such terms as he deems to be in the best interests of the United States (U.S.) & in furtherance of the purposes of this chapter, any & all right, title, & interest of the U.S. in & to the property, both real & personal, held by the Secretary on the Pribilofs: Provided, That such property is specified in a document entitled "Transfer of Property on the Pribilof Islands: Descriptions, Terms & Conditions," which is submitted to the Congress on or before October 31, 1983.
(b) Contents of property transfer document - shall include, but need not be limited to: (1) a description of each conveyance; (2) the terms to be imposed on each conveyance; (3) designation of the recipient of each conveyance; (4) a statement noting acceptance of each conveyance, including the terms, if any, under which it is accepted; & (5) an identification of all Federal property to be retained by the Federal Government on the Pribilofs to meet its responsibilities as described in this chapter & under the Convention.
(c) Report to Congress of fair market value of transferred property - Within 60 days of the transfer of real or personal property specified in the document described in subsection (a) of this section, the Committee on Merchant Marine & Fisheries of the House of Representatives & the Committee on Commerce, Science, & Transportation of the Senate shall be given a report prepared by the Secretary stating the fair market value at the time of the transfer of all real & personal property conveyed.
(d) Memorandum of Understanding (MOU)- A MOU shall be entered into by the Secretary, a representative of the local governmental authority on each Island, the trustee or trustees, & the appropriate officer of the State of Alaska (the State) setting forth the respective responsibilities of the Federal Government, the Trust, & the State regarding - (1) application of Federal retirement benefits, severance pay, & insurance benefits with respect to Natives of the Pribilofs; (2) funding to be allocated by the State for the construction of boat harbors on St. Paul & St. George Islands; (3) assumption of the State of traditional State responsibilities for facilities & services on such islands in accordance with applicable laws & regulations; (4) preservation of wildlife resources within the Secretary's jurisdiction; (5) continued activities relating to the implementation of the Convention; (6) oversight of the operation of the Trust established by section 1166(a) of this title to further progress toward creation of a stable, diversified, & enduring economy not dependent up commercial fur sealing; (7) the cooperation of government agencies, rendered through existing programs, in assisting with an orderly transition from Federal management & the creation of a private enterprise economy on the Pribilofs as described in this chapter; & (8) such other matters as may be necessary & appropriate for carrying out the purposes of the chapter, including the assumption of responsibilities to ensure an orderly transition from Federal management of the Pribilofs. |
Louis Howard |
| 12/22/1986 |
Update or Other Action |
Memorandum of Understanding among: TDX (St. Paul Island Village Corporation), TANAQ (St. George Island Village Corporation), and United States Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service (USDOC NOAA NMFS) regarding Pribilof Islands Land Selections. Negotiations undertaken by the parties to resolve potential conflicts between village corporation and federal land selections on the Pribilof Islands under the Alaska Native Claims Settlement Act (ANCSA) were successfully concluded during a third meeting held on St. George Island in June 1974. The Parties desired to record the items agreed upon during this meeting and during the two previous negotiating sessions held on St. Paul Island in April 1974 and in Seattle WA in February 1974.
The parties intend that this record of agreed items serve as a permanent background against which to compare and construe the land selection requests made by the parties to the BLM, Dept. of Interior, pursuant to the ANCSA.
Water Survey: NMFS agrees to conduct a geological study of the availability of other water sources on St. George Island. If such study determines that a water source proximate to the village is feasible for use, NMFS agrees to install a fresh water system, contingent upon the availability of funds. |
Louis Howard |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 9/25/1992 |
Update or Other Action |
Joe Sautner ADEC, SCRO, Regional Oil Program Coordinator sent letter to Frank Hong, Delta Western Seattle, WA RE: Delta Western's proposed St. George Island Tank Farm. ADEC received notice that you intend to submit a contingency plan for an oil terminal facility that is to be built on St. George Island. Construction has already begun and target date for start up is November 1, 1992. ADEC understands Delta Western has enterend into an agreement with the Village of St. George regarding the supply of fuel to the village from the proposed facility. You indicated the present tank farm serving the village will run out of fuel on November 1, 1992 and is not environmentally safe for storing product.
Your consultant has requested, on your behalf, a waiver of the 60-day pre-application notice for the plan for this proposed facility. ADEC will consider waiving some or all of this pre-application period if it is considered to be in the best interest of the village. ADEC must point out that you are requesting a waiver for a plan for a facility that has not been built and for which a plan still has not been developed.
ADEC does not wish to cause undue hardship to the citizens of St. George because of regulatory review requirements. However, ADEC must question why it was not notified by Delta Western until now that this project was in the planning. We also understand that a plan will not be submitted until the projected start up date of the facility. Please be advised it is a violation of state law to operate a facility without an approved contingency plan.
ADEC requests that Delta Western and/or the Village of St. George submit a letter explaining why proper notification was not given to the appropriate agencies (ADEC, ADNR, ADF&G, coastal districts), and explaining the current situation in detail, including a chronology of events leading up to the present situation. With this information, ADEC will be better able to explore other alternatives to address this issue. ADEC also requests you clearly indicate that if the facility isn't operational by November 1, 1992, what are the alternatives for fuel storage for the Village of St. George. You are also reminded of the more stringent oil pollution requirements for new installations. These requirements are detailed in 18 AAC 75 Article 1 - Oil Pollution Prevention Requirements. |
Ray Dronenburg |
| 10/7/1992 |
Update or Other Action |
Draft Master Plan Pribilof Island Cleanup-WASC April 1993. Liability issues: Craig O'Connor 10/07/1992 memo states "The United States is liable under CERCLA for the costs of removing hazardous wastes from the Islands as the current owner and/or the owner at the time of disposal of the wastes. In addition, it is liable for natural resources damages occurring after December 11, 1980, as a result of releases of hazardous waste. In addition, the United States is liable under CERCLA as a current and/or past operator of a facility at which hazardous substances have been disposed of, with respect to the dumpsites and landfills operated by federal agencies or with the government's acquiescence.
The United States' liability under CERCLA will survive any transfers of title to the Pribilovians, and includes an affirmative obligation to perform all remedial action on lands conveyed to the Pribilovians deemed necessary after conveyance. In addition, CERCLA imposes certain hazardous waste disclosure requirements on any agreements for the sale of federally owned contaminated property and deeds conveying same. Finally, the United States' liability as a previous owner or operator also survives conveyance.
The United States may be liable under RCRA if it has obtained neither the requisite permit nor an executive exemption with respect to its landfill and disposal site activities on the Islands. In addition, the United States is likely liable under section 7003 of RCRA with respect to disposal sites which pose an imminent threat to human health or the environment, even where it has not undertaken active supervision or management of the site." |
Ray Dronenburg |
| 1/31/1993 |
Update or Other Action |
Estimated Cleanup Schedule and costs for Pribilof Islands Cleanup (In Jan. 1993 dollars -- Out years not adjusted for inflation). Activities include: Preliminary Assessment, Site Investigation, Remedial Investigation/Feasibility Study scoping, Site Characterization, Develop and Screen Alternatives, Treatability Investigation, Detailed Analysis of Alternatives, Selection of Remedy, Remedial Design, Remedial Action Capital Costs, Post Project Activities O&M Costs (5 Years), and Administrative Costs (10% of all costs FY92-FY09). Estimated time: 17 years (2010) and $190,000,000. |
Ray Dronenburg |
| 2/28/1993 |
CERCLA PA |
CERCLA Preliminary Assessment* (PA) 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).
Former diesel tank farm was located along the waterfront north of the village gas station. Twenty (20) 10,000 gallon steel tanks were used from the 50s to the 70s. Thirteen (13) of the twenty (20) abandoned diesel tanks were relocated approximately 300 feet east of the former tank farm when they were decommissioned in the 70s. Thirteen (13) of the abandoned diesel tanks are located near the former diesel tank farm and six (6) of the tanks have been disposed of in the Oil Drum Dump A. Village elders reported they had released two (2) of the abandoned diesel tanks into the ocean. If the information is true, then a disparity exists between the total number of tanks reported abandoned and the total number of tanks disposed of.
Recommendation: determine if POL (petroleum, oil and lubricants) contamination exists. Residents rely on groundwater from a sole source aquifer, soils on the island is highly permeable and contamination that may have migrated from the sources may impact the drinking water supply. However, on Saint George Island, drinking water wells are located on a slope above the city and are upgradient of a majority of the sources. Other items brought to E and E's attention during site visits and interviews with local officials include NOAA housing built with asbestos containing floor tiles on Saint George. The tiles have been reportedly deteriorating and residents believe the tiles have been releasing friable asbestos.
EPA uses a structured program to determine appropriate response for Superfund sites:
The site assessment phase identifies sites for the NPL. The remedial phase determines the extent of contamination and implements cleanup remedies.
The primary objective of the site assessment phase is to obtain the data necessary to identify the highest priority sites posing threats to human health and the environment. The site assessment phase begins with site discovery, or notification to EPA of possible releases of hazardous substances. Sites are discovered by Regional EPA offices, State agencies, and citizens who file a PA petition. Section 105(d) of SARA established the PA petition as a formal mechanism for citizens to report potential hazardous waste sites.
Publication 9200.5-301FS, “Preliminary Assessment Petition,” by EPA’s Office of Emergency and Remedial Response describes the process. Once discovered, sites are entered into the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS), EPA’s computerized inventory of potential hazardous waste sites. EPA then evaluates the potential for a release of hazardous substances from a site during two investigative steps:
Preliminary Assessment: A PA is a limited-scope investigation performed by States and/or
EPA on every CERCLIS site. PA investigators collect readily available information and
conduct a site and environs reconnaissance. The PA is designed to distinguish between
sites that pose little or no threat to human health and the environment and sites that require
further investigation. The PA also identifies sites requiring assessment for possible
emergency response actions.
Site Inspection (SI): If the PA recommends further investigation, an SI is performed. SI
investigators typically collect waste and environmental samples to determine the
substances present at a site and whether they are being released to the environment. The
objective of the SI is to identify which sites have a high probability of qualifying for the
NPL. A second objective is to identify sites posing immediate health or environmental
threats which require emergency response.
At the end of both the PA and SI, EPA applies the HRS to derive a site score and determine either that further investigation is necessary or that the site should receive a “no further remedial action planied” (NFRAP) recommendation. A NFRAP recommendation means that further action under the Federal Super-fund program is not planned; however, such sites may be reexamined later if warranted. File information for NFRAP sites is provided to the State, or other regulatory authorities, which may also take action on their own. |
Jennifer Roberts |
| 9/30/1993 |
Document, Report, or Work plan Review - other |
FYI entry: U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities & Logistics Div. 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 George 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 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 National Priorities Listing (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 & subsurface) should be collected from the source areas to characterize the type of contamination present & delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands & bays located near sources. Soil & 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) & 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 & 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.
NOTE TO FILE:
The objective of an SI is to gather information to support a site decision regarding the need for further Superfund action. The SI is not a study of the full extent of contamination at a site or a risk assessment. The appropriate level of information gathered & analyzed to meet this objective can only be achieved through strategic planning to determine what data are essential to the decision. The SI phase of the Superfund program is a dynamic, flexible process that should be tailored to the specific circumstances of individual sites it is not a standardized process to be repeated at every site.
The SI investigator, in coordination with EPA Regional & State officials, is responsible for the design & execution of the SI, & should determine how best to use the flexibility of this process. As conditions are tested & hypotheses are either confirmed or rejected, The investigation should be adjusted. These adjustments, like the site decision itself, involve balancing a wide variety of factors & exercising professional judgment.
After the focused SI, one of three recommendations may be made:
Site evaluation accomplished (SEA);
Further action (e.g., expanded SI) recommended;
or
Preparation of an HRS package scheduled if all necessary data are available.
The objective of the expanded SI is to provide documentation for the HRS package to support NPL rulemaking. Remaining HRS information requirements are addressed & site hypotheses not completely supported during previous investigations are evaluated. ESI sampling is designed to satisfy HRS data requirements by documenting observed releases, observed contamination, & levels of actual contamination at targets. In addition, investigators collect remaining non-sampling information.
Sampling during the expanded SI includes background & QA/QC samples to fully document releases & attribute them to the site. Following the expanded SI, EPA site assessment managers assign the site a priority for HRS package preparation & proposal to the NPL.
In some cases, it may be possible to conduct a single SI instead of the focused & ESI. The single SI presumes that a site would not be screened by a focused SI & fulfills the functions of the ESI to collect analytical data & nonsampling information to complete an HRS package. The single SI is similar in scope to the expanded SI & may be appropriate for certain high priority sites that are highly likely to be placed on the NPL. |
Ray Dronenburg |
| 10/11/1993 |
Update or Other Action |
Water sampling results from a "preliminary health assessment" by NOAA which basically sampled drinking water and conducted radon sampling. Saint George Public Water System Pumphouse-All results for volatile organic compounds at 0.0010 mg/L (detection limit) per EPA Method 502.2/524.2, Saint George Health Clinic, Cottage C-Lead at 0.005 mg/L EPA Method 239.2 GF action level is 0.015 mg/L copper/lead standard. No water sample results were above detection levels for volatile organic compounds or lead on either island. Radon is not an issue on either island. |
Ray Dronenburg |
| 5/25/1994 |
Update or Other Action |
Preston Gates and Ellis Attorneys for the City of Saint George regarding the investigation and cleanup of contaminated sites on the Island of Saint George. Letter was sent to NOAA on why they believe that the federal government is responsible for addressing this contamination. NOAA has pursued a Preliminary Assessment of the contaminated sites on both Pribilof Islands and implementing limited cleanup actions, NOAA has taken the position that it does not have the authority to pursue remediaiton on the Saint George sites because they are no longer federally owned and have not been listed on the National Priorities List (NPL) by EPA. CERCLA liability: Because NOAA disposed of substances on Saint George that are hazardous under CERCLA, it is liable under that Act. It is clear from the Preliminary Assessment, the Harding Lawson Associates (HLA) Final Report for the Phase I Environmental Assessment, and other available information, that hazardous substances were widely disposed of on Saint George. NOAA appears to be under the mistaken impression that removing those drums identified as containing hazardous waste is sufficient to relieve the agency of CERCLA liability. Removal of the drums does not address the issue of soil and groundwater contamination.
State Law Liability: NOAA is also liable for cleanup costs under Alaska law (AS 46.03.822(a)(3)).
RCRA Liability: NOAA has indicated that it is not responsible for cleanup under RCRA because it falls to present ownership. This appears to be based on a misreading of the law since RCRA clearly extends to past owners and operators of facilities and to past generators of waste (see 42 USC 6972(a)(1)(B). The facts in NOAA's Preliminary Assessment of the sites are adequate to establish that site conditions "may present an imminent and substantial endangerment" to groundwater, public health and the environment. A majority of the sites are located within one mile of a residence or school. Samples taken by HLA indicate that abandoned transformers contain PCBs. HLA also concluded that waste in some of the drums abandoned by NOAA contain hazardous levels of lead, elevated levels of benzene, and is hazardous based on toxicity, reactivity, or ignitability.
All the refuse left by NOAA at various sites on the island, including auto carcasses, drums, equipment, and petroleum liquids, would fall within the RCRA definition of solid waste and most of the sites identified in the Preliminary Assessment contain materials that would constitute hazardous waste. The Preliminary Assessment clearly identifies NOAA as the source of most of the waste that was deposited (disposal under RCRA) at the identified sites. NOAA is also liable as the "owner" of any underground tanks that have not been used since the property transfer (February 1984) of federal lands to Saint George. The Preliminary Assessment documents a number of tanks that fall into this category. NOAA was responsible for notifying EPA of all tanks and for implementing corrective action for leaks.
NOAA is also liable under Toxic Substances Control Act (TSCA) for any PCB transformers abandoned on the island (see 40 CFR 761). At a minimum, NOAA should commit to implement the detailed Site Investigation recommended in the Preliminary Assessment, including the installation of test wells in and around the dump to identify suspected leaching into the industrial water supply. Attached to letter was also a listing of twenty sites in table format compiling a site description, proposed action from 1993 Ecology and Environment Preliminary Assessment and the 1994 Woodward Clyde Phase 1B Environmental Assessment and an added column which describes the community's main issues of concern with each site. |
Ray Dronenburg |
| 8/11/1994 |
Site Visit |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former National Marine Fisheries Service (NMFS) facilities on Saint George Island. ADEC traveled (on a site visit) with NOAA, their consultant, Tanaq Corp. and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol.
NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills.
NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island (See CS DB Hazard ID 1331 and 1332), the site of an underground thermonuclear detonation in the 1970s. Our law are also clear about responsibility for these materials. That responsibility remains with the Federal Government.
One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability.
Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable.
The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. |
Simon Mawson |
| 8/19/1994 |
Update or Other Action |
Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service (NMFS) Facility Saint George Island response to July 20, 1994 NOV Letter. 1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS).
2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records.
Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in theses reports.
3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas.
Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet.
During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. |
Janice Adair |
| 11/2/1994 |
Document, Report, or Work plan Review - other |
CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP.
Environmental Protection Agency (EPA) Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. Department of Commerce (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.
NOTE To file: SEC. 120. FEDERAL FACILITIES.(a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.—
(1) IN GENERAL.—Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act.
Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107.
(2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.—
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located,
applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities
shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines,
rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act.
(3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility
which is owned or operated by any department, agency, or instrumentality of the United States.
(4) STATE LAWS.—State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) when such facilities are not included
on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than
the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.
|
Jennifer Roberts |
| 12/8/1994 |
Update or Other Action |
NOAA has taken the position that it is not responsible for the proper disposal of debris abandoned by the federal government on the Island, including vehicles, construction equipment, transformers, old fuel storage tanks and other debris. "Solid Waste" is defined in federal and state law as: Any "discarded material" including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agriculture activities and from community activities. 42 U.S. C. 6903(27).
Abandoned vessels, vehicles, construction equipment, scrap, transformers, old tank systems and other debris fall within this definition. Under 40 CFR Part 257, a waste disposal facility may not cause surface water (257.3-3) or groundwater contamination (257-3-4) or pose a safety hazard (257-8). Municipal Solid Waste Landfills are subject to more stringent criteria in 40 CFR Part 258.
Asbestos in non-school buildings: Federal and state law do not require that asbestos be removed from buildings other than schools. See e.g. AS 18.31. CERCLA does not cover liability for asbestos within usable structures. As you know, asbestos lagging and similar materials that are not damaged (friable) do not pose an immediate health threat. Friable asbestos in the workplace would be subject to state and federal Occupational Safety and Health Administration (OSHA) exposure limits (see e.g. 8 AAC 04).
Lead solder in Service Lines of City of St. George's Public Water System: DEC has reviewed past water samples results for the City's water system. DEC has not identified any recurring lead contaminant problems in the water system. Should future testing identify service line problems, then DEC would ask the City of St. George to address the problem (not NOAA) as set forth in 18 AAC 80.840. |
Jennifer Roberts |
| 12/14/1994 |
Update or Other Action |
Don Young U.S. House of Representative Committee on Natural Resources sent letter to D. James Baker Under Secretary of Commerce to ask for Baker's personal involvement to ensure that cleanup of the schoolyard becomes a priority. Meetings between the parties over the extent of NOAA's liabilities has been ongoing for two years, NOAA has refused to concede anything on paper.
Acting upon the assumption that you had the necessary authority to fund these cleanups, the Conference Committee in FY 1995 budget earmarked funds for this cleanup. The Natural Resources Committee in the 103rd Congress carefully changed the Indian Lands Open Dump Act of 1994 to ensure that NOAA would abide by its responsibilities for the cleanup of wastes it left on the Pribilof Islands.
Finally, the State of Alaska and a member of my staff were involved in meetings and negotiations with the Deputy Under Secretary Josephson and your staff. In October, NOAA decided that is has authority in the Fur Seal Act Amendments of 1983 to make grants for cleanup of the Saint George schoolyard. As author of that law, I can tell you that it was NOT our intention to have NOAA convey property on the Pribilofs burdened with costly tort liabilities from wastes which may have been improperly disposed of by NOAA.
There is a paralysis by NOAA based upon fear of admitting liability or setting national precedent. I believe you have the authority to grant funds to the Island landowners to conduct the schoolyard and other solid waste site cleanups. I am concerned about a continuing problem regarding Alaska Native lands. These were conveyed in fulfillment of governmental obligations extinguishing aboriginal claims. I do not think it equitable that environmental problems occurring prior to conveyance of these lands are now being disowned by the land management agencies of the federal government. |
Ray Dronenburg |
| 3/30/1995 |
Update or Other Action |
Woodward Clyde Phase 1B Environmental Assessment a.k.a. Expanded site (inspection) investigation received which was to identify the nature and extent of soil and groundwater contamination. The data obtained from the site inspection were used to determine which areas have contaminated media and need further investigation. Test pit sample TP-6 at 5' below ground surface had 2,600 mg/kg diesel range organics (DRO) and gasoline range organics (GRO) at 790 mg/kg. The western and southeastern portions of the Former Diesel Tank Farm area (Area A) are above the level B cleanup criteria and require remedial action and the total volume of soil is dependent on the selected treatment method. |
Ray Dronenburg |
| 6/1/1995 |
Site Added to Database |
Site added to database. |
Ray Dronenburg |
| 8/2/1995 |
Document, Report, or Work plan Review - other |
(Old R:Base Action Code = SA2R - Phase II SA Review (CS)). Approved an Environmental Site Assessment (Inspection). |
Ray Dronenburg |
| 8/11/1995 |
Site Ranked Using the AHRM |
Site ranked. |
Ray Dronenburg |
| 1/6/1996 |
Update or Other Action |
Congress passed Public Law 104-91 which was also known as H.R. 1358. Section 3 Pribilof Islands
(a) In General. The Secretary of Commerce shall, subject to the availability of appropriations provided for the purposes of this section, clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants, including petroleum products and their derivatives, left by the National Oceanic and Atmospheric Administration on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred or are obligated to transfer, to local entities or residents on the Pribilof Islands, Alaska, pursuant to the Fur Seal Act of 1966 (16 U.S.C. 1151 et seq.), as amended, or other applicable law.
(b) Obligations of Secretary. In carrying out cleanup activities under subsection (a), the Secretary of Commerce shall—(1) to the maximum extent practicable, execute agreements with the State of Alaska, and affected local governments, entities, and residents eligible to receive conveyance of lands under the Fur Seal Act of 1966 (16 U.S.C. 1161 et seq.) or other applicable law; (2) manage such activities with the minimum possible overhead, delay, and duplication of State and local planning and design work; (3) receive approval from the State of Alaska for agreements described in paragraph (1) where such activities are required by State law; (4) receive approval from affected local entities or residents before conducting such activities on their property; and (5) not seek or require financial contributions by or from local entities or landowners.
(c) Resolution of Federal Responsibilities. (1) Within 9 months after the date of enactment of this section, and after consultation with the Secretary of the Interior, the State of Alaska, and local entities and residents of the Pribilof Islands, the Secretary of Commerce shall submit to the Committee on Commerce, Science, and Transportation of the Senate, and the Committee on Resources of the House of Representatives, a report proposing necessary actions by the Secretary of Commerce and Congress to resolve all claims with respect to, and permit the final implementation, fulfillment and completion of (A) title II of the Fur Seal Act Amendments of 1983 (16 U.S.C. 1161 et seq.); (B) the land conveyance entitlements of local entities and residents of the Pribilof Islands under the Alaska Native Claims Settlement Act (43 U.S.C. 1601 et seq.);(C) the provisions of this section; and (D) any other matters which the Secretary deems appropriate.
(2) The report required under paragraph (1) shall include the estimated costs of all actions, and shall contain the statements of the Secretary of Commerce, the Secretary of the Interior, any statement submitted by the State of Alaska, and any statements of claims or recommendations submitted by local entities and residents of the Pribilof Islands.
(d) Use of Local Entities. Notwithstanding any other law to the contrary, the Secretary of Commerce shall, to the maximum extent practicable, carry out activities under subsection (a) and fulfill other obligations under Federal and State law relating to the Pribilof Islands, through grants or other agreements with local entities and residents of the Pribilof Islands, unless specialized skills are needed for an activity, and the Secretary specifies in writing that such skills are not available through local entities and residents of the Pribilof Islands. (e) Definition. For the purposes of this section, the term ``clean
up'' means the planning and execution of remediation actions for lands described in subsection (a) and the redevelopment of landfills to meet statutory requirements. (f) Authorization of Appropriations. There are authorized to be appropriated not to exceed $10,000,000 in each of fiscal years 1996, 1997, and 1998 for the purposes of carrying out this section. |
Louis Howard |
| 8/30/1996 |
Update or Other Action |
Executive Order 13016 of August 28, 1996 Amendment to Executive Order No. 12580
By the authority vested in me as President by the Constitution & the laws of the United States of America, including SEC. 115 of the Comprehensive Environmental Response, Compensation, & Liability Act of 1980, as amended (42 U.S.C. 9601 et seq.) (the ‘‘Act’’), & SEC. 301 of title 3, United States Code, I hereby order that Executive Order No. 12580 of January 23, 1987, be amended by adding to SEC. 4 the following new subsections:
SEC. 1. A new subsection (c)(3) is added to read as follows: ‘‘(3) Subject to subsections (a) & (b)(1) of this SEC., the functions vested in the President by SEC 106(a) & 122 (except subsection (b)(1)) of the Act are delegated to the Secretary of the Interior, the Secretary of Commerce, the Secretary of Agriculture, the Secretary of Defense, & the Secretary of Energy, to be exercised only with the concurrence of the CoastGuard, with respect to any release or threatened release in the coastal zone, Great Lakes waters, ports, & harbors, affecting (1) natural resources under their trusteeship, or (2) a vessel or facility subject to their custody, jurisdiction, or control. Such authority shall not be exercised at any vessel or facility at which the Coast Guard is the lead Federal agency for the conduct or oversight of a response action. Such authority shall not be construed to authorize or permit use of the Hazardous Substance Superfund to implement SEC. 106 or to fund performance of any response action in lieu of the payment by a person who receives but does not comply with an order pursuant to SEC. 106(a), where such order has been issued by the Secretary of the Interior, the Secretary of Commerce, the Secretary of Agriculture, the Secretary of Defense, or the Secretary of Energy. This subsection shall not be construed to limit any authority delegated by any other SEC. of this order. Authority granted under this subsection shall be exercised in a manner to ensure interagency coordination that enhances efficiency & effectiveness.’’
Sec. 2. A new subsection (d)(3) is added to SEC. 4 to read as follows:
‘‘(3) Subject to subsections (a), (b)(1), & (c)(1) of this SEC., the functions vested in the President by sections 106(a) & 122 (except subsection (b)(1)) of the Act are delegated to the Secretary of the Interior, the Secretary of Commerce, the Secretary of Agriculture, the Secretary of Defense, & the Department of Energy, to be exercised only with the concurrence of the Administrator, with respect to any release or threatened release affecting (1) natural resources under their trusteeship, or (2) a vessel or facility subject to their custody, jurisdiction, or control. Such authority shall not be exercised at any vessel or facility at which the Administrator is the lead Federal official for the conduct or oversight of a response action. Such authority shall not be construed to authorize or permit use of the Hazardous Substance Superfund to implement SEC. 106 or to fund performance of any response action in lieu of the payment by a person who receives but does not comply with an order pursuant to SEC. 106(a), where such order has been issued by the Secretary of the Interior, the Secretary of Commerce, the Secretary of Agriculture, the Secretary of Defense, or the Secretary of Energy. This subsection shall not be construed to limit any authority delegated by any other SEC. of this order. Authority granted under this subsection shall be exercised in a manner to ensure interagency coordination that enhances efficiency & effectiveness.’’ |
Louis Howard |
| 7/22/1997 |
Update or Other Action |
NOAA letter to Commissioner Brown concerning the letter regarding the Secretary's report to Congress on the Pribilof Islands. Work under the agreement addresses the issue of oil sheening discovered in 1989 which Ms. Brown referenced in her letter, as well as the sites containing evidence of petroleum contamination. Clarification on the Report stating: " no contamination posing a threat to human health and the environment" relates to hazardous substances under RCRA and CERCLA. In this context (according to NOAA) the statement is correct. Draft copy of the report was sent to Tim Towarek of the Office of Rural and community development on 2/2/1997. Official response from the State Commissioner Mr. Cotten of the Governor's Office was received by NOAA on 3/14/1997. |
Ray Dronenburg |
| 2/17/1998 |
Update or Other Action |
ADEC letter to PolarConsult Alaska Inc. regarding Saint George Contaminated Sites cleanup. Thank you for your correspondence of February 12, 1998 regarding a meeting to propose a solution for a remediation contract for Saint George Island. ADEC agreed to host a meeting between NOAA, Tanaq and Polarconsult to begin a dialogue which could lead to the submittal of a proposal for the Phase II work which is to commence during the summer of 1998.
With reference to the rejection of drilling equipment, the following information is provided:
1) A phase II proposal submitted by Polarconsult was deemed non-responsive with a proposed drilling investigation that exceeded 1.5 million dollars. ADEC has not reviewed that proposal and this information is not verified.
2) ADEC has agreed that NOAA will conduct a separate study to determine the potential for groundwater contamination in the area where most Saint George contaminated soils exist. NOAA and ADEC believe that the existing data will indicate that groundwater in the vicinity of the City of Saint George (within 30 yards of the Bering Sea) will be saline and that NO POTABLE water exists (Note to file: *therefore the groundwater need not be considered a drinking water source in this area).
It is agreed that potentially extremely dense basalt layers exist between contaminated soils and any groundwater. Existing wells on Saint George in the vicinity of the contamination have been abandoned (NOTE to file for the purposes of drinking water) because of salinity. It is agreed that, as part of NOAA's investigation, a groundwater flow direction will be determined, the potential for drawdown by the City's potable water system to affect a reversal of flow will be investigate and to the greatest extent possible, the degree of salinity that exists and the extent laterally inland.
3) NOAA then directed Polarconsult to develop a work plan that would assume that those data collected by NOAA would indicate no potential for groundwater contamination and would then remediate those soils above bedrock or that dense basalt layer. ADEC required that Polarconsult develop their work plan to include two separate issues of soils from leaking underground storage tanks (USTs) and soils generated from contaminated sites (NON-USTs). NOAA then indicated that , at some point, they would seek relief from ADEC for soils contaminated under buildings and for contamination existing in dense basalt rocks again assuming that contamination was not a threat to human health, the ecological system, and specifically potable groundwater.
4) Polarconsult's requested information on soil gas survey techniques. ADEC suggested soil gas survey techniques, PIDs, PetroFlag, and of course (required) confirmation sampling could all be techniques approved by the Department.
NOAA and ADEC have agreed that matrix scores will NOT be used to determine cleanup standards and instead agreed to use proposed 18 AAC 75 Contaminated Sites Regulations (Table B) as cleanup standards. As expressed in the last sentence of your letter, this meeting was to help expedite and coordinate a startup for a project that needs to go forward this calendar year. |
Ray Dronenburg |
| 2/19/1998 |
Update or Other Action |
Polarconsult letter to Dronenburg responding back to February 17, 1998 letter from ADEC to them.
RE: Saint George Cleanup Project Phase II. Still not clear on ADEC's position on key issues.
1) As confirmed in ADEC letter, NOAA recommended that Saint George Tanaq Corporation propose a remediation program similar to that proposed by Bering Sea Ecotech for Tanagdusix corporation (TDX). NOAA has indicated to Tanaq in previous discussions that this recommendation is based on performance claims promised through the use of a liquid bio-remediation product. During our meeting with you on February 11, 1998, you stated your familiarity and positive experiences with products of this type. Further, you explicitly stated that the Department would permit use of this type of product for in-situ remediation of the contaminated sites presented in the Two-Party Agreement. Will you approve the use of a liquid injection bio-remediation product for in-situ remediation of the contaminated sites on Saint George?
2) There are several contaminated sites on Saint George where Tanaq performed excavation and was not able to completely remove the contaminated soils. For example, Site 23 (inactive/abandoned diesel tank farm) approximately 600 feet from the Bering sea and also is the closest site to the City's active wells. It was apparent that fuel seeped into the vesicular and fractured basalt and had continued traveling downward, filling the pore spaces in the rock.
As a result of these conditions, we explained the use of a drilling rig is necessary if ADEC is to require the collection of soil samples from the subsurface at the Diesel Tank Farm. During our meeting, you (Dronenburg) indicated that,
a) provided a hydrological study finds that the groundwater gradient slopes away from the drinking water wells and;
b) provided it is shown that the influence of the active wells does not cause reversal of the gradient under contaminated sites;
it is NOT necessary to define the vertical extent of contamination (as required by regulations). Under these conditions you (R. Dronenburg) reasoned that the water, potable or not, would not be drawn into the community drinking water system and as a result, would not present a risk of exposure to the community.
You (R. Dronenburg) added, therefore, that it was of little relevance whether or not free product or groundwater contamination was present (Comment to file: in any amount?) and the delineation of the vertical extent of contamination and groundwater quality in these areas was not necessary (NOTE to file: as required by 18 AAC 75 and 18 AAC 78/A.S. 46.03?).
The rationale expressed at the meeting has the potential to significantly reduce Tanaq's scope of work by eliminating the need to define the vertical and horizontal extent of contamination, not only at the Diesel tank farm site, but also at the other sites on the island. Provided the hydrological study finds that the groundwater gradient slopes away from the drinking water wells, and provided it is shown that the influence of the active wells does not cause reversal of the gradient under the contaminated sites, will you (ADEC) waive the regulatory requirement to define the vertical extent of contamination?
3) During our meeting, you (R. Dronenburg) indicated that you would approve the use of soil gas survey techniques to define the extent of contamination at the contaminated sites on Saint George. It is our understanding that the Department requires the collection of actual soil samples to verify and correlate findings of field screening tools. At the diesel tank farm and many other sites on Saint George this will involve the use of a drilling rig. Will you waive the regulatory requirement to collect confirmation samples associated with the use of a soil gas survey to define the extent of contamination?
4) Although there may be potentially extremely dense basalt layers you mention in the letter existing between the contaminated soil and groundwater, there is no evidence of this and without the use of a drilling rig, it cannot be verified. USCG LORAN station investigation by Dames and Moore concluded the dense basalt layers did NOT act as a barrier to fuel spilled due to discontinuities and internal fractures in the basalt unit. |
Ray Dronenburg |
| 11/12/1998 |
Update or Other Action |
Site update for TPA Site Number 1 OU 5. Thirteen 10,000 gallon Above ground storage tanks and bulk debris were removed during the FY97 Phase I Cooperative Agreement. Soil remediation is to be included in the upcoming FY99 Phase II Contaminated Soil (PCS) with residual debris removal and confirmation sampling project, Saint George Island (Phase II). Renegotiated. Phase I final debris removal report due February 1999. Phase II draft work plan due March 29, 1999. Final work plan due April 26, 1999. Phase II will require residual debris removal, PCS remediation, confirmation sampling and analyses, site assessment, and site restoration. Monthly progress reports to ADEC after project award until site closure. Buried piping remains at the site.
Flow chart attached for confirmation sampling and applicable to all TPA sites. Definition of a site assessment attached also and is applicable to all TPA sites. Site restoration is defined as one or more of the following actions dependent on each TPA site, existing site use, intended post restoration use: Recontouring, regrading, soil or scoria addition or removal, wind/water erosion control, and revegetation. |
Ray Dronenburg |
| 1/26/1999 |
Document, Report, or Work plan Review - other |
Letter to Bret Coburn Vice President of Finance St. George Tanaq Corporation. ADEC believes that the workplan as outlined in the proposed Hydrology, Geology, and Contaminant Transport Study for St. George Island and which is similar to a workplan for St. Paul Island is an attempt to identify certain criteria which will be required in any modeling study for risk characterization.
The Department does not believe that the intent of the study is to adequately characterize the horizontal and vertical distribution of the release(s) in the groundwater, but rather to determine certain facets of the groundwater, which are not known at this time. At the Same time, NOAA is attempting to determine, in certain locations, the extent of contamination as a basis for further requirements.
The St. George Tanaq Corporation should recognize that the proposed study does not call for looking specifically at sites where known contamination was found and left in place with the conclusion of Phase I. Buried absorbent cartridges do address questions regarding the concentrations of petroleum products in soils at depth determined by the cartridge. Given this information, it then becomes reasonable to determine the potential for contamination migration to groundwater. The use of buried absorbent cartridges, as a closure methodology would not be approved without sufficient confirmation samples. |
Ray Dronenburg |
| 3/25/1999 |
Update or Other Action |
Letter to Minh Trinh Project manager NOAA re: DEC's request to discuss Alaska's recently promulgated cleanup rules at the 4/7/99-4/8/99 RAB meeting. Concerns are based on NOAA's position that the TPA Section 21 provides that earlier guidance will be used as a basis for establishing petroleum cleanup levels. The department does not dispute NOAA's interpretation of Section 21. The exception is releases from regulated USTs which according to Section 22 of the TPA, are remediated pursuant to 18 AAC 78. They (the newly promulgated cleanup standards) are therefore applicable to areas such as Tract 41, where regulated UST releases have occurred.
The Department's intent in discussing the new cleanup rules is to assure the stakeholders that cleanups conducted according to the guidance in effect prior to promulgation of the new regulations are protective of human health and the environment. The soil cleanup matrix provides the most conservative cleanup levels and are now known as Method 1 cleanup. Risk assessments mentioned in Section 25 of the TPA are now termed as Method 4 cleanups.
The Department urges NOAA to take the time to review the new regulations and consider the advantage afforded by the new cleanup rules. The cleanup levels were carefully designed to provide for cost effective cleanups that are protective of public health and the environment. If NOAA decides not to take advantage of these regulations, the consequence will be higher assessment and cleanup costs. |
Ray Dronenburg |
| 4/1/1999 |
Update or Other Action |
MOA between Office of Finance Paul F. Roberts, Chief Financial Officer/Chief Administrative Officer and Administration and National Ocean Service Nancy Foster Assistant Administrator, National Ocean Service. The purpose of the agreement is to describe tasks to be performed by the NOS and OFA in support of the Pribilof Two Party Agreement cleanup which was signed on January 26, 1996 by NOAA and ADEC. PL 104-91, also enacted in January 1996, impacted the Pribilof cleanup by requiring the use, as much as practicable, of local labor through grants or cooperative agreements. 43 sites are listed in the agreement from both islands for evaluation and/or cleanup.
Resource management and financial management: Historically, funding for the island cleanup has been provided through the Environmental Compliance and The Pribilof Islands Cleanup line items in the NOAA appropriations. The sole source of funding for activities under this agreement will be those funds remaining from those line items, provided in the form of carryover. |
Louis Howard |
| 4/5/1999 |
Document, Report, or Work plan Review - other |
Letter from R. Dronenburg to Minh Trinh NOAA project manager. Draft Statement of Work (SOW)-Performance Specifications submitted under letter of transmittal dated March 22, 1999 was received March 22, 1999. The Department has completed a careful review of the documents and the Draft SOW is unacceptable to the Department and is considered non-responsive. The Department has determined that a violation of paragraph 70 for the Two Party Agreement exists and stipulated penalties will accrue until NOAA submits acceptable work plans. The Two Party Agreement paragraph 18, requires the submittal of plans for sites per schedule of Attachment A. As you are aware, NOAA and ADEC extended time lines for Attachment A with regards to work plans (Phase II) for investigation and remediation of contaminated soils on St. Paul and St. George Islands to February 22 1999. At NOAA's request that deadline was extended (by the Department) for thirty (30) days due to some confusion on NOAA's part as to remediation regulation. Paragraph 18 of the Two Party Agreement states in part that each plan shall outline the course of the site investigation to properly delineate the nature and extent of contamination in soil and groundwater at each source area(s).
A violation of paragraph 70 of the Two Party Agreement exists with stipulated penalties pursuant to paragraph 70 of the TPA. The penalties were invoked effective February 22, 1999 and accrue weekly until those requirements as previously identified are met. NOAA is reminded that stipulated penalties are for two thousand dollars ($2000) for the first week (or portion thereof) and three thousand dollars ($3000) for each additional week (or portion thereof). |
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 |
| 6/4/1999 |
Meeting or Teleconference Held |
Staff met with NOAA in Seattle on May 17 and 18, 1999 to discuss and scope out various requirements and objectives necessary to develop work plans for properly characterize NOAA sites on the Pribilof Islands. Other than the stockpile sampling work plan no other work plans have been submitted by NOAA for site characterization work. Expedited review comments on the stockpile plan as previously agreed to were provided to NOAA. Please note that this expedited review is an EXCEPTION rather than the rule for review and comment on draft comments, scopes of works, work plans and decision documents.
TWO-PARTY AGREEMENT - Review and Comment on Documents:6. Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B, Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year. NOAA shall submit to ADEC a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to ADEC within 120 Days after completion of field work.
7. Unless the Parties mutually agree to another time period, all draft documents shall be subject to a thirty (30) Day period for ADEC review and comment. Review of any document by ADEC may concern all aspects of the document (including completeness) and should include, but is not limited to, technical evaluation of any aspect of the document, and consistency with the state and federal laws set forth in Paragraphs 21-25. Comments by ADEC shall be provided with adequate specificity so that NOAA can respond to the comments and incorporate changes as a result of the comments, if appropriate, into the final document. Comments shall refer to any pertinent sources of authority or references upon which the comments are based, and upon request of NOAA, ADEC shall provide a copy of the cited legal authority or reference, if not already been provided. ADEC may extend the thirty (30) Day comment period for an additional twenty (20) Days by written notice to NOAA prior to the end of the 30 Day period. On or before the close of the comment period, ADEC shall transmit written comments to NOAA. |
Louis Howard |
| 6/21/1999 |
Meeting or Teleconference Held |
Letter to Robert Taylor and John Lindsay regarding a meeting on the Pribilofs TPA Schedules.
Thank you for meeting with us to discuss the Two Party Restoration Agreement priorities for
action items with us on June 17, 1999. It was a positive meeting in which we were able to meet
and discuss with you the issues facing your agency on setting priorities for site characterization and remedial action during the current and future field seasons. From DEC's perspective, a major reason and goal for the meeting is development of schedules.
The conceptual schedules (attached) developed at the meeting set a framework which NOAA
can use to create detailed schedules for setting achievable goals to bring the projects to closure and address DEC's concerns. It is DEC's expectation that NOAA will develop an outline of a plan of action which will include a gantt chart or a similar scheduling tool detailing this year's and next year's work and a list of assumptions to go along with the schedules.
An area that will need special attention in planning and schedule development is the petroleum
contaminated soil (PCS) stockpiles on both St. Paul and St. George. From our discussions, the
evaluation process for PCS treatment is now underway and an option for PCS treatment will be
forthcoming shortly, but the contracting challenges and mobilization issues remain a major
hurtle. The concept we· discussed of separating the PCS work into two phases appears
reasonable. Phase 1, to be completed this year will include evaluation of treatment options and
treatment selection, community involvement activities, permit applciation and contract award. Phase 2, occurring in year 2000, will be mobilization and actual treatment of the PCS.
An advantage of the phased approach for PCS, is the Tetra Tech field work and reports will be
finalized and any PCS discovered from that work can be treated in year 2000.
While we made excellent progress in our meeting, we did not have time to complete our list of
items to be discussed: Lukanin Bay Debris, Ridge Wall Hill, Lake Hill, groundwater investigations at the Vehicle Boneyard, Telegraph Hill, and the existing landfill at Cell "B".
Additionally, NOAA will need to develop the plan for the phased closeout of the landfills at St.
Paul and St. George, to include post-closure monitoring. DEC sees the need for another meeting with all staff involved in the June 17 meeting as a follow-up to address these outstanding issues. Please notify us of your availability so we may schedule another meeting with all the essential staff.
In order to halt the accrual of stipulated penalties, NO~A needs to complete the following
items:
-detailed schedules as noted above for the contaminated sites listed in the two party
agreement,
-PCS details on Phase 1 and Phase 2 including detailed schedules,
-A plan to address landfill closure of St. Paul and St. George open dumps using a phased
closure approach,
-submittal of the budget documents DEC requested in its January 1999 letter to NOAA.
DEC considers the June 17, 1999 meeting a positive step in the right direction in resolving the
accrual of stipulated penalties and we look forward to a rapid resolution of this matter. |
Jennifer Roberts |
| 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. August 27, 1999 ADEC letter identified contingencies and guidance for NOAA.
In a 9/9/99 letter: NOAA agrees to the following for halting penalties is based on NOAA performing field work on Saint Paul Island during the 1999 season for the following TPA Sites:
TPA (1) Oil Drum Dump Site-Site Characterization,
TPA (2) Vehicle Boneyard Site-remove residual debris, site walk over and EM survey for buried vehicles. If vehicles found report to ADEC of findings and intended actions
TPA (3) Little Polovina Hill buried vehicle boneyard-remove debris, site walkover and EM survey,
TPA (4) Dune Vehicle boneyard-remove fluid from vehicles and perform minimum steps needed to obtain NFA,
TPA (8) NOAA Cliffside landfill-identify relationship to NMFS landfill per TPA maps, review prior records for photos, site descriptions, actions completed, reports and as appropriate submit NFA request, finally TPA
TPA (12) Lukanin Bay remove debris, stage debris at Tract 38, Fill depression, cover and stabilize cover, install snow fence. In addition, NOAA is to properly contain and maintain the PCS stockpiles on both islands until treatment is completed.
Renegotiate by 12/15/99 a schedule for completing the cleanup work required under the TPA.
Development of an acceptable plan and schedule for the partial closure of the Saint George Landfill. Finally, submittal of cleanup budget information. This was satisfied by the budget information in NOAA's 7/29/1999 congressional testimony. |
Jennifer Roberts |
| 11/15/1999 |
Update or Other Action |
NOAA John Lindsay Pribilof Project Office (PPO) sent letter to Louis Howard. Subject: Inability to Install St. George Petroleum Stockpile Cover This letter is a follow-up to a mutual decision between NOAA and ADEC made on St. George Island on 28 October 1999 to forego further attempts to install the petroleum contaminated soils stockpile cover. This decision was made during discussions between you, Ms. Laura Ogar of the Solid Waste Program and myself. The following chronology represents the sequence of events leading to the timing of the installation with the subsequent encounter with the foul weather season, the primary basis for this decision.
On 31 July, NOAA received a letter dated 26 July from ADEC requesting that the PCS stockpiles on St. Paul and St. George be covered according to Alaska regulations. NOAA notified the Navy Engineering Facilities Activity (EFA) and Navy Supervisor of Shipbuilding (SupShip), Environmental Detachment (DET) to begin planning for cover installation on the Pribilofs.
On 9 August, NOAA received a stockpile cover design and estimated cost of installation from Supship. The PPO had requested the NOAA to authorize Supship funds to implement the cleanup actions on 20 May 1999. Internal approval was received on 7 June. But because the fund transfer exceeded $1 million, additional approval was required at the Department of Commerce level. This approval did not come until 8 September. However on 18 August, the SupShip Contracts Administrator refused to allow the DET to accept any additional work as DET was privatizing in mid-September 1999 as part of the Navy’s downsizing. However, with residuals from an initial $50,000 fund transfer to DET in June, DET proceeded with the procurement of the cover material for use by whomever could complete the installation. On 23 August, ADEC provided me a copy of its comments on the St. George stockpile cover design with tacit approval to proceed. On 25 August, ADEC gave final approval on the cover design.
The PPO attempted to utilize the services of EFA for placement of stockpile covers on both St. George and St. Paul, but the PPO was limited to transferring funds not to exceed $100,000 without MOU signoff. The $100,000 transfer to EFA was authorized but it was sufficient to allow for the covering of only the St. Paul Blubber Dump stockpile.
Consequently, the PPO had to seek an alternative contractor.
On 8 September, the PPO inquired about other contractor avenues available to it for the stockpile cover installation, and began preparations on a Scope of Work and Independent Government Estimate. On 16 September, NOAA requested a technical and cost proposal from Tetra Tech EMI to cover the St. George stockpile. On 14 October, NOAA contracting gives Tetra Tech EMI verbal authorization to proceed with the St. George stockpile cover installation. On 15 October, a barge delivers the cover material purchased by DET to St. George. TTEMI concludes negotiations with its subcontractor Tanaq Corporation, and on 26 October, TTEMI arrives on St. George to install the cover. During the night of 27 October, an unforecasted snowstorm covers the stockpile and high winds make it impractical and unsafe to attempt to install the cover. Seasonably adverse weather has set in and NOAA and ADEC jointly agree that it is not pragmatic to expect to cover the stockpile this season. Not only do strong winds compromise safety to workers laying down the cover, trenching for the berm around the perimeter threatened to damage the stockpile liner which was snow covered. NOAA intends to treat the stockpile at the commencement of the next field season. On 16 November, NOAA, some of its contractors and Tanaq Corporation are visiting with a vendor of a heat treatment system to discuss the technical and cost effectiveness of its application at the beginning of the next field season. NOAA believes the above information and efforts should be sufficient to satisfy pertinent requirements ADEC has identified for halting the accrual of stipulated penalties under the Two Party Agreement. |
Louis Howard |
| 1/24/2000 |
Update or Other Action |
Congress passed Public Law 106-562 (H.R. 1653) a.k.a. 'Pribilof Islands Transition Act'. SEC. 206. FINANCIAL ASSISTANCE.`(a) GRANT AUTHORITY- (1) IN GENERAL Subject to the availability of appropriations, the Secretary shall provide financial assistance to any city government, village corporation, or tribal council of St. George, Alaska, or St. Paul, Alaska. (2) USE FOR MATCHING Notwithstanding any other provision of law relating to matching funds, funds provided by the Secretary as assistance under this subsection may be used by the entity as non-Federal matching funds under any Federal program that requires such matching funds. (3) RESTRICTION ON USE The Secretary may not use financial assistance authorized by this Act (A) to settle any debt owed to the United States; (B) for administrative or overhead expenses; or (C) for contributions sought or required from any person for costs or fees to clean up any matter that was caused or contributed to by such person on or after March 15, 2000. (4) FUNDING INSTRUMENTS AND PROCEDURES In providing assistance under this subsection the Secretary shall transfer any funds appropriated to carry out this section to the Secretary of the Interior, who shall obligate such funds through instruments and procedures that are equivalent to the instruments and procedures required to be used by the Bureau of Indian Affairs pursuant to title IV of the Indian Self-Determination and Education Assistance Act (25 U.S.C. 450 et seq.). (5) PRO RATA DISTRIBUTION OF ASSISTANCE In any fiscal year for which less than all of the funds authorized under subsection (c)(1) are appropriated, such funds shall be distributed under this subsection on a pro rata basis among the entities referred to in subsection (c)(1) in the same proportions in which amounts are authorized by that subsection for grants to those entities.
(b) SOLID WASTE ASSISTANCE (1) IN GENERAL- Subject to the availability of appropriations, the Secretary shall provide assistance to the State of Alaska for designing, locating, constructing, redeveloping, permitting, or certifying solid waste management facilities on the Pribilof Islands to be operated under permits issued to the City of St. George and the City of St. Paul, Alaska, by the State of Alaska under section 46.03.100 of the Alaska Statutes. (2) TRANSFER The Secretary shall transfer any appropriations received under paragraph (1) to the State of Alaska for the benefit of rural and Native villages in Alaska for obligation under section 303 of Public Law 104-182, except that subsection (b) of that section shall not apply to those funds. (3) LIMITATION In order to be eligible to receive financial assistance under this subsection, not later than 180 days after the date of the enactment of this paragraph, each of the Cities of St. Paul and St. George shall enter into a written agreement with the State of Alaska under which such City shall identify by its legal boundaries the tract or tracts of land that such City has selected as the site for its solid waste management facility and any supporting infrastructure. |
Louis Howard |
| 3/7/2000 |
Meeting or Teleconference Held |
Staff attended a restoration advisory board meeting on island. Main concerns were for the drinking water wells a few miles away from the active landfill. Members of the RAB were doubtful on how correct the modeling results were at predicting whether or not groundwater would be protected and not impacted. Budget for closing the landfill and opening a new one was another topic that was discussed very extensively. NOAA stated that there are no dollars available for work on Saint George beyond what they could get for the landfill closure and design of the new one. 2001 is the year that investigative work can proceed at the rest of the sites. |
Louis Howard |
| 5/10/2000 |
Meeting or Teleconference Held |
Staff attended a restoration advisory board meeting in Saint Paul Island. Main points discussed during the meeting: closure of the existing landfill due to its capacity being reached, alternatives to the landfill and a new cell adjacent to it, burning of waste in an incinerator as a short term fix, funding for the new landfill not a sure thing and that the community must come together and present a unified front with a site for the new landfill and a solid waste management plan or else D.C. will not give them funding for a new landfill. |
Louis Howard |
| 6/7/2000 |
Cleanup Plan Approved |
Staff reviewed and commented on a revised draft plan to remediate petroleum contaminated soils at Saint George Island using enhanced thermal conduction. Plan was approved as submitted. |
Louis Howard |
| 7/25/2000 |
Update or Other Action |
Staff requested all of NOAA's budget requests made to congress since the agreement was signed in 1996 by both ADEC and NOAA for the environmental cleanup at the Pribilofs. It has come to DEC's attention that NOAA did not make a formal request for funding to Department of Commerce for FY 01 and possibly FY02 (federal fiscal years). This is not in compliance with the TPA which requires NOAA to request adequate funding to meet its obligations under the TPA. NOAA was counting on the U.S. congressional delegation to fund 12 million dollars as a special appropriation for the Pribilofs. The appropriation was much less-3 million dollars for October 2000 to September 2001. Deadline for NOAA to provide a written response was no later than August 18th. |
Louis Howard |
| 12/14/2000 |
Update or Other Action |
Staff sent letter to NOAA regarding Notification of possible Force Majeure (per the TPA). The Alaska Department of Environmental Conservation (ADEC) has received the above document via facsimile from NOAA on December 5, 2000. The document states that in accordance with Paragraph 67 of the Two Party Agreement(TPA), the potential exists for a Force Majeure situation. It further states that unless further Pribilofs Cleanup Funds are appropriated to NOAA for FY01, the project budget will be exhausted this fiscal year. We very much appreciate your providing this information and analysis of NOAA’s anticipated plans in FY 01 given the existing funding situation. ADEC realizes that funding is uncertain due to Congress not yet finalizing a budget for this FY01. We anticipate a meeting with NOAA to discuss potential impacts to the Pribilof Islands Environmental Restoration Agreement when Congress finalizes a budget. |
Louis Howard |
| 4/11/2001 |
Document, Report, or Work plan Review - other |
Staff sent NOAA comment letter on Two Party Agreement (TPA) revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter.
These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows:
1) FUDS. With respect to the sites that NOAA has identified as Formerly Used Defense Sites (FUDS) sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. |
Louis Howard |
| 2/11/2002 |
Document, Report, or Work plan Review - other |
ADEC Staff reviewed and commented on the Pribilof Islands Environmental Restoration Agreement Revised Schedule Submittals February 5, 2002 for Attachment B. The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers.
Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.”
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.”
For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment. With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
For additional information see site file. |
Louis Howard |
| 10/7/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the letter regarding “Establishing Petroleum Contaminated Soil Cleanup Levels for Treated Soils St. George and St. Paul Islands.” Staff generally agreed with the three approaches regarding soils treated by the enhanced thermal conduction (ETC) system. However, under each option, staff requested some text changes be made regarding cleanup levels. Staff requested NOAA substitute the words “equal to or less than” for the words “less than” in all options (1, 2, 3).
For each option, soils at or below the levels identified by NOAA are not considered “contaminated” by the Department. With regards to revising the ETC cleanup criterion for diesel range organics (DRO) from 100 mg/kg to a higher level (230/250 mg/kg), the Department concurs. The Department will require NOAA to seek the prior approval of disposal of any treated soils at an “environmentally sensitive area” as defined in 18 AAC 75.990. 230 mg/kg DRO, 260 mg/kg GRO, and 9,700 mg/kg RRO will be acceptable for all soils used as cover for solid waste sites such as landfills and 250 mg/kg of DRO, 300 mg/kg GRO and 10,000 mg/kg RRO will be acceptable for use in all other areas not involving solid waste cover material. |
Louis Howard |
| 3/10/2003 |
Update or Other Action |
Staff received and commented on the Draft Site Characterization Report for TPA Sites 1, 2, and 3 for St. George Island on March 14, 2003.
4.3.2.7 Comparison of Metals with Background Levels TPA Site 1 Pages 38 and 39 Site 2 Pages 43 and 44 and Site 3 Pages 48 and 49
The Department agrees that arsenic and chromium have met the applicable cleanup standards.
6.2 Evaluation of Corrective Action for Groundwater Pages 68 and 69
At Two Party Agreement (TPA) site no. 1, the diesel range organics (DRO) concentrations at 4,800 ug/L in groundwater would not exceed 15,000 ug/L ten times (10X) rule concentration, should NOAA successfully apply for and be granted this alternate cleanup level.
8.0 Recommendations Pages 70 and 71
The Department concurs with the recommendations presented in this section. However, if NOAA applies for and obtains a 10X rule determination, it need only consider implementing the option of a pump and treat system using an oil-water separator for benzene at TPA 1. |
Louis Howard |
| 6/2/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft Field Investigation Report for St. George Island. Staff concurred with the recommendations in the report specifically in Section 7. |
Louis Howard |
| 6/17/2003 |
Long Term Monitoring Established |
St. George Groundwater Investigation Update from NOAA to ADEC. Though this is a preliminary finding, a number of the old wells scheduled for closure this spring will not be closed yet as we may use them for product recovery. These wells will be closed when they no longer serve a purpose to NOAA. In addition, the proposed sentinel well TPA2-MW-2 will not be installed and NOAA proposes to use the existing TPA2-MW-1 as the sentinel well between TPA1-MW-2 and TPA2-MW-3. Note that revised groundwater level contours will be prepared for the addendum Field Investigation Report, which will summarize the drilling, water level logging, and sampling and analysis work we're doing right now. Since TPA1-MW-2 had soil cuttings from the saturated zone that smelled of petroleum hydrocarbons, NOAA will drill another well (TPA1-MW-4) to the west to "bracket" the plume with a potentially clean well. |
Louis Howard |
| 2/11/2004 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft corrective action plan and proposed sampling and analysis frequency for TPA 1, 2 and 25-1 on St. George Island. In general, soil samples, sufficient in number and location to represent the conditions of the soil, must be taken to adequately characterize the horizontal and vertical distribution of the release in the soil and to identify soil properties that are likely to influence the type and rate of migration of the released petroleum.
1 Field Screening PPO Alternative: The text states 45 samples for excavated soil and 67 samples for final excavated bottom would be sampled for field screening vs. the 1,118 samples excavated soil or 308 samples for final excavated bottom required by regulation. Instead the Department requests NOAA collect 1 field screening sample for every 125 cubic yards (yd3) or roughly 90 samples from approximately 11,180 yd3.
The text states that 1 sample would be collected for every 250 sq. ft., the Department concurs. The Department disagrees with the proposed sampling alternatives after the first 2,500 sq. ft. have been addressed. The Department requests NOAA collect field screening samples for every 350 square feet of final excavation bottom greater than 2,500 sq. ft. or approximately 80 samples (in addition to the 10 samples required for the first 2,500 sq. ft. for final excavated bottom from an estimated 30,783 sq. ft.. Therefore, 90 samples for final excavated bottom would be collected by NOAA for 30,783 sq. ft. of final excavated bottom. This alternative field screening sampling strategy would still save NOAA money on costs of sampling and remain protective of human health, safety, welfare, and the environment.
2 Confirmation Sampling PPO Alternative: The text states that 1 sample for every 250 sq. ft. of excavation bottom of up to 2,500 sq. ft. will be collected for the first 2,500 sq. ft., the Department concurs with this approach. The text goes further to state that one sample for every 500 ft2 of excavation exceeding 2,500 sq. ft. will be collected for a minimum of 67 samples taken for an estimated 30,783 sq. ft.. The Department disagrees. The Department requests a total of 98 samples or sampling for every 350 sq. ft. of final excavated bottom exceeding 2,500 sq. ft.. Upon incorporation of these comments into the corrective action plan, the Department will consider the revised corrective action plan a final document. This alternative confirmation sampling strategy would still save NOAA money on costs of sampling and remain protective of human health, safety, welfare, and the environment. |
Louis Howard |
| 5/12/2005 |
Update or Other Action |
Staff reviewed the groundwater monitoring report for St. George Island. Main comment was regarding the absence of the chain of custody/transfer log/release forms that typically accompany samples. ADEC requests NOAA provide copies of these forms for all samples listed in the document as an appendix in the final version of the report. ADEC looks forward to reviewing a groundwater monitoring plan incorporating the recommendations found in section 7.0. |
Louis Howard |
| 7/20/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Feasibility Study-Product Removal Testing, Two-Party Agreement Sites 1 and 8, St. George Island, Alaska June 2005. The text states that ADEC will have to issue a permit (2003-DB-0096) for reinjecting groundwater back into the aquifer upgradient from each location. This is incorrect since ADEC no longer issues general permits for this type of activity. As part of an approved workplan for the site, ADEC can issue an approval for this activity, provided the byproduct groundwater is NOT a RCRA waste or hazardous waste that would be regulated and subject to approval by the U.S. Environmental Protection Agency (see http://www.epa.gov/safewater/uic/index.html) Groundwater Protection Unit (OCE-082) 1200 Sixth Avenue, Seattle WA, 98101 (206) 553-1224 FAX (206) 553-0151.
An oil water separator cannot be used to treat chlorinated solvent contamination, for cases such as this; ADEC has approved granulated activated carbon (GAC) filter units for “polishing” the groundwater prior to reinjection. NOAA would be required to test prior to reinjection for baseline contaminant levels, at some pre-approved frequency of monitoring during treatment and at the end of the project or before the useful life of the GAC unit(s) has been reached.
Please be aware that Section 3020 of RCRA addresses the underground injection of hazardous waste in the context of RCRA and CERCLA cleanups. RCRA section 3020(a) bans hazardous waste disposal by underground injection into a formation which contains an underground source of drinking water (within one-quarter mile of the well), or above such a formation.
However, RCRA section 3020(b) exempts from the ban reinjection of treated contaminated ground water withdrawn from an aquifer, if the following criteria are met:
(1) the reinjection is a CERCLA section 104 or 106 response action or part of a RCRA corrective action intended to clean up the contamination,
(2) the contaminated ground water is treated to substantially reduce hazardous constituents prior to such reinjection, and
(3) the response action or corrective action is sufficient to protect human health and the environment upon completion.
Please be aware that ADEC’s review and comment on the document is to ensure the compliance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our review and comments on the document does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, sub-contractors, or personnel from complying with other applicable laws and regulations.
The text states that the pneumatic bladder pump removal system is best suited at TPA 1 and 8. ADEC requests clarification from NOAA on how it intends to improve operational time of the system based on the information provided on Section 5.1.2 Page 29. It states the test at TPA1-MW1 operated discontinuously for 67 hrs. and 33 minutes. The motor on the air compressor was worn and required excessive current to operate. ADEC requests additional information on whether the compressor was worn due to unfavorable site conditions or the contractor was using a compressor that was already worn out and should not have been used in the first place. |
Louis Howard |
| 8/8/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the long-term groundwater monitoring plan for St. George Island. |
Louis Howard |
| 8/29/2005 |
Update or Other Action |
NOAA submits the final long-term groundwater monitoring plan which addresses 47 wells installed on St. George Island to gather information critical to environmental investigations and remediation planning pursuant to a Two Party Agreement (TPA) between National Oceanic and Atmospheric Administration (NOAA) and the State of Alaska Department of Environmental
Conservation (ADEC). Groundwater studies utilizing these wells provide data on contaminant concentration, fate, and transport at island locations where past government operations contributed to the contamination of the site. In the future, a select number of these wells will be needed for gauging the long-term effectiveness of remedial actions, to monitor for contaminant plume migration, and for utilization during free-phase petroleum product (free product) removal activities. However, monitoring wells also pose a liability by providing a potential conduit for introducing contaminants to groundwater, and by impeding use of the land around them.
Therefore, wells that are not needed by NOAA for long-term groundwater monitoring or free product removal will be decommissioned in accordance with applicable ADEC requirements.
Monitoring wells addressed by this plan are located in the vicinity of the City of St. George (the City). Twenty-five of the 47 wells will be retained, and 22 will be decommissioned. Ten of the retained wells will be used to monitor for the migration of free product plumes located in the industrial and waterfront areas of the City. The remaining 15 retained wells will be used, as needed, for free product removal or process water injection during remediation of the plumes; they may also be used for monitoring of contaminant trends once remedial efforts have
been completed. As future remedial actions progress, NOAA may decommission a number of these retained wells if it is determined that they are not required for free product removal or long-term monitoring. Wells used for monitoring for free product plume migration (sentinel wells) will be sampled semiannually for five years beginning in Fiscal Year 2006 (subject to funding availability); thereafter NOAA will evaluate the data and submit a recommendation to ADEC for further sampling or closure. Water samples will be analyzed for contaminants known to be present in the City area groundwater aquifer.
This plan addresses 47 groundwater-monitoring wells located in the vicinity of the City of St. George (the City) that NOAA installed to evaluate the nature and extent of groundwater contamination at 13 TPA sites (Figure 1-2).
These sites are:
• TPA Site 1 (Former Diesel Tank Farm)
• TPA Site 2 (Former Drum Storage Area)
• TPA Site 3 (Inactive Gas Station)
• TPA Site 6 (Open Pits Site)
• TPA Site 7 (Ballfield/Former Landfill)
• TPA Site 8 (Active Power Plant)
• TPA Site 9 (Old Power Plant)
• TPA Site 11 (Cottage C UST)
Appendix II 991
• TPA Site 18 (Former Fuel Storage Area)
• TPA Site 22-1 (School UST)
• TPA Site 22-3 (Shop/Store UST)
• TPA Site 23 (Abandoned Diesel Tank Farm)
• TPA Site 24 (Inactive Gas Tank Farm)
NOAA has completed soil remediation activities at all the above sites except TPA Site 1 and TPA Site 2 (Figure 1-3). NOAA conducted groundwater sampling in September/October 2001, October 2002, August 2003, November 2003, January 2004, and May 2004 at wells shown in Figures 2-1 and 2-2. Groundwater samples were analyzed for diesel range organics (DRO), gasoline range organics (GRO), volatile organics (VOC), semi-volatile organics (SVOC) and metals. NOAA anticipates excavating petroleum-contaminated soil (PCS) at TPA Sites 1 and 2 during the 2006 field season, subject to funding availability. In 2006, NOAA will also begin remediation of free-phase petroleum product plumes (free product), located in the vicinities of TPA Site 1 and TPA Site 8, subject to funding availability. Detailed information on island geology, hydrogeology, and groundwater sampling results for these sites can be found in Tetra Tech EM Inc.’s (Tetra Tech) Final Field Investigation Report, Pribilof Islands Environmental Restoration Project, St. George Island, Alaska.
|
Louis Howard |
| 9/1/2005 |
Update or Other Action |
St. George Island Two Party Agreement (TPA) Sites 1 and 8 Product Removal Testing Final Feasibility Study Report dated October 2005 received. SLR Alaska (SLR) was retained by St. George Chadux Corporation (St. George Chadux) to conduct pilot testing of product removal technologies proposed at two historical contaminated sites within the City of St. George, located on St. George Island, Alaska. This work was conducted between September 2004 and December 2004 under Task Order 5 between St. George Chadux and National Oceanic and Atmospheric
Administration (NOAA) Pribilof Project Office (PPO).
The two areas that were the focus of the pilot testing were Two Party Agreement (TPA) Site
1 and TPA Site 8, hereafter referred to as TPA 1 and TPA 8. Both sites had experienced
historical releases of free petroleum product to soils and ground water.
Key objectives of the project included:
• Evaluating the effectiveness of belt skimmers and pneumatic bladder pumps to remove product.
• Evaluating the physical parameters to estimate the effectiveness of multi phase extraction systems
• Determining if vacuum applied to the wells is beneficial for increasing product removal.
• Evaluating the radius of influence of vacuum extraction in the subsurface to provide design criteria for the placement of extraction wells.
• Estimating the hydraulic characteristics of the subsurface materials at the two Sites
using methods that extend beyond the immediate area of the well bore. These data will be used to refine the product volume estimate, and for future design purposes for fluid withdrawal or infiltration well design.
• Collecting water chemistry and biological activity samples to determine the appropriate measures to be taken to avoid equipment and well fouling caused by precipitates or biological activity during product removal.
• Evaluating the infrastructure in the area of the two sites, particularly surface access,
electrical service, telephone service, and the presence of existing structures suitable
for locating remediation system equipment.
The following specific conclusions are drawn:
• Pneumatic bladder pumps are more appropriate for use at this site than belt skimmers due to the following advantages:
• ease of installation, as the system can easily be installed in flushmounted wells without the need for either above grade equipment at the well, or a sub-grade vault
• installation of pneumatic pumps below grade (without requiring vaults to be constructed) will limit exposure of treatment system equipment to inclement weather
• the pumps are intrinsically safe for use in explosive atmospheres
• separate transfer pumps will not be required to pump the recovered LNAPL and water to a central location
• when properly placed, the pneumatic pumps produced very little water compared to LNAPL recovery
• The product removal pilot test, in combination with the prior baildown tests , demonstrated that the maximum actual product thickness is likely approximately 0.42 feet at TPA 1 and 0.51 feet at TPA 8
• The vacuum-enhanced product recovery testing, while successful in increasing the product recovery rate, did not result in significant additional volumes of LNAPL recovery.
• The air discharge sampling results demonstrated that the exhausted air did not exceed NIOSH TWA RELs.
• The biological activity response testing and the ground water geochemical analyses indicated that both biological fouling and chemical precipitation may occur within wells, pumps and the treatment equipment. These factors will need to be considered when selecting and designing a treatment system.
The review of remedial alternatives completed shows that Alternative 3, the pneumatic bladder pump removal system, appears to be best suited for use at TPA 1 and TPA 8. Following review of these recommendations, SLR recommends that NOAA and St. George Chadux provide SLR with approval to prepare design documents and detailed cost estimates for the selected remedial alternatives. |
Louis Howard |
| 9/28/2005 |
Update or Other Action |
NOAA (J. Lindsay) letter sent to ADEC (L. Howard) Subject: NOAA Selection of Free Phase Product Removal Alternative. NOAA previously submitted for your review SLR Alaska's draft feasibility study report for product removal testing at Two Party Agreement (TPA) Sites I and 8 on St. George Island. NOAA has selected Alternative 3 - Pneumatic Bladder Pump Recovery System as its alternative for the free phase product removal. Please respond in writing as to ADEC's acceptance for this selection. If ADEC determines that this alternative is unacceptable, please submit in writing the basis for this decision. |
Louis Howard |
| 12/29/2005 |
Update or Other Action |
STG Water System AK2260074 (PWSID)
U.S. Environmental Protection Agency (EPA) has ordered the Saint George (STG) Water System, to correct deficiencies found at the facility, complete required monitoring of the drinking water and notify users of the violations. Violation of any terms of this federal order may result in an administrative civil penalty of up to $27,500 or a civil judicial penalty of not more than $32,500 per day of violation. STG Water System is a community public water system serving approximately 200 users, located on the northeast shore of Saint George Island, the southern-most of the five islands in the Pribilof chain in the Bering Sea.
The system has a history of failure to comply with Safe Drinking Water Act requirements. It was referred to EPA for formal enforcement after state officials had exhausted all available remedies to bring the system into compliance. The system is owned by the City of Saint George, not the federally-recognized tribe, the Saint George Island Traditional Council.
According to EPA officials, the STG Water System has repeatedly failed to correct deficiencies found during a 2004 sanitary survey (similar to an inspection), conducted by the Department of Environmental Conservation (DEC). The deficiencies included; securing and decommissioning an inactive well and no approved sample siting plan. The system has also failed to test the water for total coliform bacteria on a regular monthly basis, Volatile Organic Compounds (VOCs), lead and copper and inform its customers about the quality of their water. |
Louis Howard |
| 2/15/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 10/10/2007 |
Update or Other Action |
Corrective Action Report/Conditional Closure Request for NOAA Site No. 1 TPA site no. 1 Former Diesel Tank Farm & NOAA Site no. 2 TPA site no. 2 Former Drum Storage Area. The City of St. George (the City) is the current owner of Site 1 and Site 2, having received the property from the federal government under a transfer of property agreement (NOAA 1984).
2.2 PROPERTY DESCRIPTION
Site 1 and Site 2 are located within Tract 43, Section 29, Township 41 south, Range 129 west of the Seward Meridian, Alaska, as shown on the Bureau of Land Management, File/Record No. ak2804100s12900w001, February 15, 1985, sheet 1 of 4 (Figures 1 and 2). Site 1 is centered on coordinates latitude 56º 36’ 12.67” north and longitude 169º 32’ 48.76” west; Site 2 is centered on coordinates latitude 56º 36’ 12.81” north and longitude 169º 32’ 45.83” west.
2.3 HISTORY
Site 1 – Former Diesel Tank Farm
Site 1 served as a fuel tank farm from the 1950s to the 1970s (E & E 1993). Figure 3 was developed from a 1967 aerial photo, and shows twenty 10,000 gallon above ground storage tanks (ASTs) located at the site, plus an additional AST in the adjacent Site 2. A 1964 Department of the Interior (DOI) drawing identifies two ASTs as being used for gasoline storage (DOI 1964). The DOI drawing also identifies one of the tanks as being damaged, making it a potential source of the GRO contamination found at the site. Site 1 tanks were filled from barges via 3-inch diameter transfer lines routed from the east boat launch and west landing (Figure 3). The tank farm was taken out of operation in the 1970s; the tanks were removed from the site in 1996 (Polarconsult 1997a).
Site 2 – Former Drum Storage Area
Site 2 was used for drum storage of diesel fuel and gasoline (Figure 3). DOI documents indicate that in 1964 there was a 20,000 gallon drum storage capacity for diesel fuel, and a 2,000 gallon drum storage capacity for gasoline. The drum storage area consisted of a soil platform behind a concrete-filled drum retaining wall. Most of the retaining wall was removed during 2006 cleanup activities. The drums were off-loaded full from barges and ships and/or filled from fuel barges via a 2-inch diameter manifold and hose system located on the north side of the site. In 2006, heavily contaminated soil was encountered along the north side of the site; this contamination may have been a result of leakage and spills from the drum filling operations. Site 2 was likely in use until the 1970s when it was taken out of operation along with TPA Site 1.
Petroleum-contaminated soil has been removed from NOAA Sites 1 and 2 to the extent practicable. Contaminated soil remains in a strip, starting at about 3 feet bgs, running along the north side of the community’s sewer system, and at one location just to the south of the sewer system at 10.5 feet bgs (sample location SG01-CS-053-105, Figure 10). Further excavation toward the sewer line would endanger it. Contaminated soil remains along the earthen barrier, starting at about 4 feet bgs, in the western end of Site 1 where it slopes toward the Bearing Sea
(Figures 9 and 10). This buffer was left in place between Bering Sea and the site excavation to reduce the potential for storm seas breaching the excavation and carrying fill material and contamination to sea, a scenario of concern to the community. Contaminated soil also remains at refusal, between 7.5 and 13 feet bgs, in the western end of the excavation; and from 14 feet bgs to the water table at 15 ft. bgs primarily in the western half of the excavation. Further soil removal vertically is not practicable because of the presence of either hard basalt or the water table.
Confirmation sample analytical results show that the remaining soil contaminant concentrations are well below the ADEC cleanup criteria for inhalation and ingestion (see Tables 6-1 and 8-1). The cumulative cancer risk for remaining contaminants does not exceed 1 x 10-5, and the cumulative non-carcinogenic hazard index is 7.3 x 10-3, well below ADEC’s criterion of 1.0.
The depth to the water table in the vicinity of Sites 1 and 2 is approximately 15 feet bgs. Due to its shallow depth and the history of these sites, it is likely that the groundwater became contaminated with petroleum products soon after fuel storage operations began in the 1950’s.
The removal of 14,280 cubic yards of PCS from these sites, most of what was present, should largely mitigate further introduction of contaminants to the groundwater. During PCS excavation, the water table was exposed in test pits to keep track of its depth. These test pits were left open as the excavation progressed, and no more than product sheen was observed accumulated on the exposed water. Environmental investigations have shown that the groundwater in vicinity of Sites 1 and 2 is not potable due to elevated TDS concentrations as a result of sea water intrusion.
For additional information see site file. |
Louis Howard |
| 11/2/2007 |
Cleanup Complete Determination Issued |
In accordance with Paragraph 59 of the Two Party Agreement (TPA), this is to confirm that all corrective action has been completed to the maximum extent practicable at NOAA Site 1/Two Party Agreement Site 1 on St. George Island in accordance with the TPA. Diesel range organics (DRO) contaminated soil remains in the following locations: just north of and parallel to the City sewer system at depths of 5 feet below ground surface (bgs) and deeper; in an unexcavated buffer zone along the Bering Sea from the beach line inland approximately 10 to 15 feet at depths of 3 feet bgs and deeper; in the western portion of the site, at equipment refusal (due to bed rock) at depths of 7 to 14 feet bgs; and in the eastern portion of the site at the bottom of the vadose zone at 14 to 15 feet bgs. DRO, gasoline range organics (GRO), benzene, ethylbenzene and total xylene remain in one area in the western portion of the site at bed rock depth of 14 feet bgs. Groundwater is contaminated with DRO, GRO and benzene in this area. |
Louis Howard |
| 3/25/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Final Groundwater Monitoring Technical Memorandum-St. George Island, Alaska Dated February 20, 2008. The report documents the sampling of eleven (11) groundwater monitoring wells in November 2007 on St. George Island. The main contaminants of concern in the groundwater are: diesel range organics, gasoline range organics, benzene, and perchloroethylene (PCE). The contamination is associated with Two-Party Agreement (TPA) Sites: no. 1 Former Diesel Tank Area, no. 2 Drum Storage Area, no. 8 Active Power Plant, no. 22-1 School underground storage tank (UST) and the village monitoring wells.
General Comments-In the future, ADEC requests NOAA include as part of the laboratory data reports: the CS Lab Approval Number (e.g. UST-030), lab approval expiration date, and the name of the person authorizing release of laboratory data (normally a cover page containing this information).
Note: The “raw” analytical data (Appendix C-Data Deliverables Package starting on page 88 of 490 pages), e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals to ADEC, however, must be retained on file by the laboratory for at least ten (10) years after the analysis date (i.e. 2017). The hard copy report/technical memorandum sent to ADEC need not include the “raw” analytical data, but NOAA may choose to include it on CD-ROM.
Finally, ADEC requests NOAA provide some qualitative statements in subsequent reports/technical memorandum regarding groundwater contamination at each site stating if the groundwater monitoring indicates a contamination trend and if the concentration trend
(1) is increasing or
(2) is stable or decreasing, and that hazardous substance migration is not occurring.
2.1 Groundwater Sampling Page 8-The text states several hinges were broken and rusted, unbroken hinges made access to the PVC inner casings difficult. Several steel monument caps could not be closed and locked, thus access no longer is restricted. ADEC requests NOAA to replace all broken and rusted hinges to allow the monument caps to be closed and locked, preventing unauthorized access to the monitoring wells.
2.3 Analytical Procedures Page 9- Attached you will find an updated Table 1 part A and part B, from the UST Procedures Manual. Please use this as a desk reference until the UST Procedures Manual is revised, sometime in the future. SW846 was revised in 2007 and many of the corresponding changes have been captured on the new table. ADEC has added new information for pesticides, herbicides, and mercury and ADEC has updated the determinative methods and preservation requirements.
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Louis Howard |
| 9/5/2008 |
Institutional Control Record Established |
Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation as the owner, and the U.S. Department of Commerce/National Oceanic and Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice that the property on the north side of the City of St. George along the Bering Sea coastline, St George Island, Alaska, 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Lot 1 of the East Landing Subdivision Tract 43 Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska. 56 degrees 36' 12.96" North Latitude, 169 degrees 32' 47.33" West Longitude.
Adequate soil cover needs to be maintained over the residual petroleum contaminated soil. If contaminated soil is exposed in the future, it must be managed in accordance with laws applicable at that time. Groundwater in the general vicinity of the Site is known to be contaminated with DRO, GRO, and benzene due to the fuel storage and transfer operations at multiple TPA sites in the area. Groundwater in this area is monitored for contaminant concentration trends in accordance with an ADEC approved long-term groundwater monitoring plan.
In the event that information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator is required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations.
Further site characterization and cleanup may be necessary under 18 AAC 75.325-.390 and 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil or water from the site or use of the groundwater at or near the contaminated area requires notification to and approval from the ADEC in accordance with 18 AAC 75.370(b) and 18 AAC 78.600(h).
This notice remains in effect until a written determination from ADEC is recorded that states that soil at the site has been shown to meet the most stringent soil cleanup levels in Method Two of 18 AAC 75.341 (c) and that off-site transportation of soil is not a concern. |
Louis Howard |
| 9/20/2008 |
Update or Other Action |
The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Pribilof Project Office is responsible for site characterization and restoration on St. George Island, Alaska. Although NOAA has attempted to meet State of Alaska soil cleanup levels and has removed contaminated soil to the maximum extent practicable, residual contamination remains at some St. George Island sites. This report documents the nature of known or potential residual soil and groundwater contamination at NOAA-remediated sites and presents the rationale for leaving the contamination in place.
Of thirty-six (36) sites investigated and/or restored by NOAA at St. George Island, the following contaminants are known to remain or potentially may be present in soil and/or groundwater above applicable site cleanup levels:
• DRO at 20 sites.
• GRO at 5 sites.
• RRO at 3 sites.
• Benzene at 4 sites.
• Toluene at 3 sites.
• Ethylbenzene at 4 sites.
• Total xylenes at 4 sites.
• Perchloroethylene at 2 sites.
• Lead at 2 sites.
Contaminated soil may have been left in place at sites due to equipment limitations and/or the presence of utility lines, buildings, roads, and other structures. Additionally, NOAA was not obligated to excavate contaminated soil to address the inhalation and ingestion pathways fifteen (15) feet or greater below the ground surface, or at shallower depths when encountering the water table. Buried debris, such as municipal solid waste, also remains at some sites. In such locations, NOAA placed a soil cap over the debris according to State of Alaska requirements.
During 2006, NOAA initiated a long-term groundwater monitoring plan at St. George Island to monitor the migration and attenuation of groundwater contamination at NOAA Sites 35 and 36 and to gauge the effectiveness of soil remediation actions at NOAA Sites 1, 2, 3, 8 and 29. Other than acknowledging the presence of groundwater contamination at a site, groundwater is not addressed within the context of this report.
Former Diesel Tank Farm, Site 1; TPA Site 1 and Former Drum Storage Area, Site 2; TPA Site 2. Site 1 and Site 2 are located along the Bering Sea oceanfront north of the City of St. George. These sites were used as fuel (diesel and gasoline) storage areas from the 1950s to the 1970s. Site 1 is located to the west of and adjacent to Site 2. Site 1 and Site 2 investigations performed in 1994 (Woodward-Clyde 1995) and 2001 (Tetra Tech 2003a) found widespread diesel range organics (DRO) and gasoline range organics (GRO) contamination. Woodward-Clyde also found, within Site 2, soil contaminated with toluene, ethylbenzene and total xylene above ADEC cleanup criteria.
Approximately 14,300 cubic yards (yd3) of contaminated soil were excavated from Site 1 and Site 2 in 2006 (NOAA 2007a). Contaminated soil removal resulted in one large excavation that spanned both sites. Soils with contaminant concentrations above Method Two criteria were removed to the extent practicable; however, excavation efforts were constrained to the north by the Bering Sea and to the south and west by the City of St. George’s sewer system. Excavation depth was mostly limited by the area’s water table, which was encountered at about 15 bgs; however, basaltic bedrock was encountered as shallow as 7.0 feet bgs in one area.
At Site 1, soil contaminated with DRO in concentrations above the Method Two criterion for migration to groundwater remains in the following locations: just north of and parallel to the City sewer system at depths of 5 feet bgs and deeper; in an unexcavated buffer zone along the Bering Sea from the beach line inland approximately 10 to 15 feet at depths of 3 feet bgs and deeper; in the western portion of the site, at equipment refusal (due to bedrock) at depths of seven to fourteen feet bgs; and in the eastern portion of the site at the bottom of the vadose zone at fourteen to fifteen feet bgs. DRO, GRO, benzene, ethylbenzene and total xylene remain in concentrations exceeding Method Two criteria for migration to groundwater in one area in the western portion of the site at bedrock depth of fourteen feet bgs.
At Site 2, soil contaminated with DRO in concentrations above the Method Two criterion for migration to groundwater remains in the following locations: just north of and parallel to the City sewer system at depths of eight feet bgs and deeper; at equipment refusal (due to bedrock) at a depth of thirteen feet bgs; and at the bottom of the vadose zone (in areas of deeper bedrock) at fourteen to fifteen feet bgs. Remaining contaminant concentrations at both Site 1 and Site 2 are below Method Two criteria for ingestion and inhalation. |
Louis Howard |
| 9/26/2008 |
Update or Other Action |
Summary of Residual Soil Contamination and Buried Solid Wastes at NOAA Cleanup Sites on St. George Island. NOAA Site No. 1/TPA Site No. 1, Former Diesel Tank Farm: surface debris, contaminated soil, contaminated groundwater, UST/AST pipeline. Diesel range organics (DRO) contaminated soil remains in the following locations: just north of and parallel to the City sewer system at depths of 5 feet below ground surface (bgs) and deeper; in an unexcavated buffer zone along the Bering Sea from the beach line inland approximately 10 to 15 feet at depths of 3 feet bgs and deeper; in the western portion of the site, at equipment refusal (due to bed rock) at depths of 7 to 14 feet bgs; and in the eastern portion of the site at the bottom of the vadose zone at 14 to 15 feet bgs.
DRO, gasoline range organics (GRO), benzene, ethylbenzene and total xylene remain in one area in the western portion of the site at bed rock depth of 14 feet bgs. Groundwater is contaminated with DRO, GRO and benzene in this area; see Site 36 [TPA 1b & 25-1b Oceanfront Sites Free Phase] below for information. Deed notice.
Site status as of September 26, 2008: NFRAP 11/02/2007. Property Owners: City of St. George; St. George Tanaq Corporation (Tanaq).
ALSO includes NOAA Site no. 36 TPA site no. 1b & 25-1b Oceanfront Sites Free Phase: Contaminated groundwater. Site conditions as of August 6, 2008: Petroleum sheen observed on the water table surface during excavation activities in 2006. Dissolved-phase contaminants include DRO, GRO, and benzene. Long-term groundwater monitoring is in progress.
Site Status as of September 26, 2008: NFRAP 11/02/2007. Property owners: City of St. George/Tanaq. |
Louis Howard |
| 12/21/2009 |
Update or Other Action |
Groundwater Monitoring Mid-Year Report 2009 St. George Island Report. NOAA contracted Bethel Services, Inc. (BSI) in 2007 to continue long term groundwater monitoring on St. George.
BSI completed the sixth long-term groundwater monitoring event of the subject monitoring wells
on June 19, 2009. Presented in this report are the results of the June 2009 St. George monitoring well sampling event and statistical analysis of trends in contaminant concentrations for groundwater samples collected from October 2006 to June 2009 at the subject monitoring wells.
Five of the eleven wells sampled; TPA1-MW-2, TPA1-MW-3, TPA2-MW-2, TPA8-MW-4, and TPA8-MW-9 were reported to contain contaminant concentrations above ADEC cleanup levels. DRO concentrations at all five wells were above cleanup levels as were GRO and benzene concentrations at TPA1-MW-3. Though TPA1-MW-2 and TPA1-MW-3 have historically had high DRO concentrations this event marks the first time since May 2007 that monitoring wells TPA2-MW-2 and TPA8-MW-4 have been reported to contain contaminants above the cleanup level and the first time that any contaminant has been found at concentrations above ADEC cleanup levels at monitoring well TPA8-MW-9.
Mann-Kendall statistical methods were used to evaluate contaminant concentration trends at the
subject monitoring wells over the period of October 2006 to June 2009, as data was available.
Analytical results from sampling events conducted in August 2003, November 2003, January
2004 and May 2004 are included with this report for a historic perspective; however, analytical
results from 2003 and 2004 are not included in the trend analyses. Substantial contaminated soil
excavation work conducted during the fall of 2006 and spring of 2007, in and adjacent to TPA
Sites 1, 2 and 8, caused a significant change in the area's contaminant-groundwater equilibrium
state.
This equilibrium change is evident by the large upward contaminant concentration spikes
found in several wells during the October 2006 and May 2007 sampling events. Inclusion of only
analytical results from October 2006 onward will result in a more meaningful analysis of
groundwater contaminant concentration trends that are a result of the contaminated soil
remediation work conducted at these TPA sites.
Eight monitoring wells on St. George Island had the concentrations of 14 analytes statistically
analyzed for monotonic trends. Analyses showed six contaminant concentrations trending
upward and eight trending downward. DRO concentrations were found to be trending upward at
TPA2-MW-2, TPA8-MW-4, TPA8-MW-9, and VIL-MW-3 and downward at TPA1-MW-2, TPA1-MW-3, and TPA2-MW-1. GRO concentrations were found to be trending downward at TPA1-MW-3, TPA2-MW-1, and TPA8-MW-4 and upward at TPA1-MW-2 and TPA2-MW-2. The benzene concentration at TPA1-MW-3 was found to be trending downward, as well as the PCE concentration at TPA8-MW-4. Though sufficient data was available to calculate these trends, due to the small number of data points and other factors, no DRO trends on St. George meet the data quality requirements for this project to be considered statistically valid and they should not be used to draw conclusions or make decisions.
RRO was not found to be a contaminant of concern by site characterization sampling performed at TPA Sites 1 and 2 in 2001 (Tetra Tech, 2003); therefore, this contaminant has not been specifically requested for analysis in past groundwater sampling events. During review of
analytical data from the November 2008 sampling event, it was found that RRO concentrations
had been reported by the laboratory. Review of past analytical data packages revealed that RRO had also been reported for the November 2007 sampling event. Though RRO concentrations were reported above the cleanup level at monitoring wells TPA1-MW-2 and TPA1-MW-3 in November 2008, RRO was reported either as "not detected" or detected in very low concentrations below cleanup standards in all other wells sampled in November 2007 and 2008. No RRO concentrations were reported above the cleanup level in June 2009. It should be noted that laboratories routinely analyze for DRO and RRO concurrently. |
Louis Howard |
| 4/29/2010 |
Update or Other Action |
Groundwater Monitoring Annual Report 2009 received. TPA Sites 1 and 2 are former diesel tank farm and drum storage areas, respectively. The sites were used between 1950 and 1970 for bulk fuel and drum storage. Previous environmental investigations at these sites indicated petroleum contaminants in soils and groundwater included DRO, GRO and benzene, toluene, ethylbenzene, and xylenes (BTEX).
Monitoring wells TPA1-MW-2, TPA1-MW-3, and TPA1-MW-5 were installed to monitor the potential migration of diesel and gasoline in the groundwater beneath the former AST tank farm and fuel transfer lines at TPA Site 1. During the December 2009 sampling event all three wells were sampled for GRO, DRO, benzene, PCE, and RRO. Duplicate samples were taken for all analytes at wells TPA1-MW-2 and TPA1-MW-3. DRO concentrations at monitoring wells TPA1-MW-2 and TPA1-MW-3 exceeded ADEC cleanup levels as did the GRO and benzene concentrations at monitoring well TPA1-
MW-3. No analytes were found above the method reporting limit at TPA1-MW-5. Analytes with
more than one instance of a sample being reported above the method reporting limit were
statistically analyzed using a Mann-Kendall trend and Sen’s Slope analysis; in this case DRO
and GRO were analyzed at TPA1-MW-2 and DRO, GRO, and benzene at TPA1-MW-3.
With the exception of the GRO concentration at TPA1-MW-2 which is trending up, contaminant concentrations analyzed were trending downward. The benzene concentration trend at TPA1-MW-3 is significant at a < 0.05 and meets the data quality requirements to be considered statistically valid for the purposes of this report. |
Louis Howard |
| 7/23/2010 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73152 name: storage tank |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Staff received the Groundwater Monitoring Mid-Year Report dated January 2011. This report presents the results of the June 2010 St. George monitoring well sampling event and statistical analysis of trends in COC concentrations. Groundwater sampling procedures and protocols used for this project follow the NOAA Master Quality Assurance Plan, the Final Long-Term Groundwater Monitoring Plan, St. George Island, Alaska, and the Groundwater Monitoring Work Plan, St. George Island, Pribilof Islands, Alaska prepared by BSI. Trend analysis was performed using Mann-Kendall statistical methods which are described by Boyaciogly and Boyaciogly.
The purpose of continued groundwater monitoring on St. George is to monitor DRO, GRO, RRO, benzene, and PCE concentrations in groundwater at 11 monitoring wells, which are part of a monitoring well network. Hydrocarbon and PCE concentrations were detected in groundwater at wells installed in two locations in the village: the Former Diesel Tank Farm Two-Party Agreement (TPA) Site 1 and Active Power Plant TPA Site 8. At the Former Drum Storage Area TPA Site 2 and the School underground storage tank (UST) TPA Site 22-1 only hydrocarbon analytes were detected.
TPA Sites 1 and 2 are former diesel tank farm and drum storage areas, respectively. The sites were used between 1950 and 1970 for bulk fuel and drum storage. Previous environmental investigations at these sites indicated petroleum contaminants in soils and groundwater included DRO, GRO and benzene, toluene, ethylbenzene, and xylenes.
Monitoring wells TPA1-MW-2, TPA1-MW-3, and TPA1-MW-5 were installed to monitor the potential migration of diesel and gasoline in the groundwater beneath the former AST tank farm and fuel transfer lines at TPA Site 1. During the June 2010 sampling event all three wells were sampled for GRO, DRO, benzene, PCE, and RRO. Duplicate samples were taken for all analytes at wells TPA1-MW-2 and TPA1-MW-3. DRO concentrations at monitoring wells TPA1-MW-2 and TPA1-MW-3 exceeded ADEC cleanup levels as did the benzene concentration at monitoring well TPA1-MW-3. No analytes were found above the method detection limit at TPA1-MW-5.
Analytes with more than one instance of a sample being reported above the method reporting limit were statistically analyzed using a Mann-Kendall trend and Sen’s Slope analysis; in this case DRO, GRO, and RRO were analyzed at TPA1-MW-2 and DRO, GRO, RRO, and benzene at TPA1-MW-3. Statistical analyses results for TPA Site 1 are presented in Table 4-2. With the exception of the GRO concentration at TPA1-MW-2 which is trending upward, contaminant concentrations analyzed were all trending downward. The benzene concentration trend at TPA1-MW-3 is significant at a < 0.05 and meets the data quality requirements to be considered statistically valid for the purposes of this report.
The groundwater monitoring at St. George was conducted from June 20, through June 21, 2010, and was performed in accordance with approved plans. No NAPL was observed in the wells sampled in June 2010. Review and validation of the data showed that for four samples, AK101 surrogate recoveries were above the quality control criteria. GRO data for samples TPA1-MW-2, TPA1-MW-3, TPA1-MW-33, and TPA1-MW-22 are qualified to indicate the detectable concentrations are an estimate with a high bias. All other sample results are considered to be valid with no data qualifiers assigned.
Village Monitoring Wells
From 2001 to 2003, additional wells were installed as part of a monitoring well network. These wells are not associated with specific TPA sites (NOAA, 2005). The wells were sampled for GRO, DRO, VOCs, SVOCs, and metals and results indicated that there were no detectable concentrations of GRO, DRO, and VOCs. Detected SVOCs and metal concentrations were below ADEC cleanup criteria.
Monitoring well VIL-MW-3 was installed as part of an expanded groundwater monitoring well network. During the June 2010 sampling event, the groundwater at monitoring well VIL-MW-3 was sampled for GRO, DRO, benzene, PCE, and RRO. No analytes were reported to exceed ADEC cleanup levels. Only one analyte at the Village Monitoring Wells met the requirements necessary for a statistical trend analyses. DRO concentrations at VIL-MW-3 were analyzed for a monotonic trend, the results of which are presented in Table 4-2. DRO concentrations at VIL-MW-3 were shown to be increasing. No trends at the Village Monitoring Wells are significant at a < 0.05 and therefore do not meet the data quality requirements to be considered statistically valid for the purposes of this report. |
Louis Howard |
| 2/16/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Groundwater Monitoring Mid-Year Report 2010, St. George Island, Pribilof Islands dated January 2011. The document covers groundwater monitoring for TPA 1, TPA 2, TPA 8, and TPA 22-1 as well as the Village Monitoring Wells.
ADEC has reviewed the document and concurs with the conclusions and recommendations that additional sampling and analysis will further verify the contaminant trends presented in this report. |
Louis Howard |
| 3/24/2011 |
Update or Other Action |
NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island.
Current St. George Plan requirements: Semi-annual monitoring at eleven wells (TPA1-MW-2, TPA1-MW-3, TPA1-MW-5, TPA2-MW-1, TPA2-MW-2, TPA8-MW-4, TPA8-MW-9, TPA8-MW-13, TPA8-MW-14, TPA22.1-MW-1, and VIL-MW-3) for DRO, GRO, Benzene, and PCE. NOAA subsequently added RRO to the analytes after detection above cleanup levels in November 2008.
1) Drop monitoring for benzene and PCE at all wells.
Justification: Benzene and PCE have been undetected or detected at concentrations below MRL for all sampling events since October 2006 (beginning of long-term monitoring) at all wells except TPAI-MW-2 (benzene), TPA1-MW-3 (benzene), and TPA8-MW-4 (PCE).
TPA1-MW-2: one benzene detect in Nov 08 at 0.65 ppb which is above MRL but well below the 5.0 ppb cleanup criterion; all other sample results either ND or below MRL. A concentration trend cannot be established due to too few samples above MRL.
TPA1-MW-3: benzene at concentrations well above the 5.0 ppb criterion have always been found in all samples from this well; however, sources (ASTs) have been removed, contaminated soil has been removed to the extent practicable, and statistical analysis of sample results indicates a strong downward concentration trend (99.9% probability). No product sheen has ever been observed in the adjacent Bering Sea and benzene has not been detected in other area wells in amounts that would suggest migration.
Studies indicate that groundwater in this area has high TDS (above drinking water standards) likely due to saltwater intrusion (Tetra Tech 2005), and hydrogeological modeling indicates that the village's potable water supply is not threatened by groundwater contamination in this area (Tetra Tech 2005). Therefore, with benzene concentrations strongly tending down and little risk to environment or human health, benzene can safely dropped from the analytes monitored at this well. GRO concentrations at this well also show a strong downward trend (95% probability) but will continue to be monitored along with DRO/RRO.
6) General – Two reports/year for each island are currently provided to ADEC containing the same information, i.e. trend analysis of each well, figures, tables, appendices, consultant's conclusions and recommendations – full reports semi-annually. Proposed revision to the plans would specify submittal of the analytical lab's report, ADEC QA checklist, contractor's QA evaluation and forwarding letter to ADEC after the first round. The forwarding letter will report any unexpected anomalies revealed by the 1st round of sampling. ADEC will receive one full report/year after the 2nd sampling round which includes trend analysis of each well, figures, tables, appendices, consultant's conclusions and recommendations, all data from first round etc. ADEC, of course, reserves the right to ask for more information from the 1st round if deemed necessary, but routinely would only get a full report once a year.
Reason: Limited value of trend analysis twice a year and significant cost savings over producing two full reports/year.
|
Louis Howard |
| 4/4/2011 |
Update or Other Action |
Annual Groundwater monitoring report received. The purpose of continued groundwater (GW) monitoring on St. George is to monitor DRO, GRO, RRO, benzene, & PCE levels in GW at 11 monitoring wells, which are part of a monitoring well network. Hydrocarbon & PCE were detected in GW at wells installed in two locations in the village: the Former Diesel Tank Farm Two-Party Agreement (TPA) Site 1 & Active Power Plant TPA Site 8. Only hydrocarbon analytes were detected at the Former Drum Storage Area TPA Site 2 & the School underground storage tank (UST) TPA Site 22-1.
TPA Site 1 is a former diesel tank farm. It was used between 1950 & 1970 for bulk fuel storage. In May 2006, SLR Consulting, under contract with NOAA, excavated two trenches northwest of TPA Site 1. The water table was encountered approximately 15 feet below ground surface (bgs). A layer of contaminated soil was observed in both trenches from about 1 foot bgs to the bottom of the trenches at the water table. Petroleum sheen was observed on the exposed GW.
Beginning in September 2006 & continuing through early November 2006, ChemTrack LLC, under contract with NOAA, excavated approximately 14,000 cubic yards of petroleum contaminated soil from an area spanning TPA Sites 1 & 2. The excavation was limited to the north by the shoreline of the Bering Sea & to the south & west by the City’s sewer system. The depth of the excavation averaged about 14 feet bgs, & was intentionally kept roughly 1 foot above the water table, or to bedrock, which was about 7.5 feet bgs at one location.
To verify depth to GW, the excavation depth was periodically increased until the water table was encountered. Soils with contaminants above ADEC cleanup levels were removed, as practicable, & transported off-site. Some contaminated soils could not be removed owing to the location of the sewer system & the need to maintain a buffer zone between the Bering Sea & the excavation. Observations made during excavation of TPA Sites 1 & 2 indicated no evidence of free-phase product greater than sheen on the GW. The excavation was backfilled with clean material after collection of soil samples for cleanup confirmation.
TPA1-MW-3 had DRO at 5.78 mg/L & benzene at 15.9 (duplicate 17.6 ug/L) ug/L in November 2010 compared to 3.52 mg/L DRO & 18.3 ug/L in June 2010. TPA1-MW-2 had 1.47 mg/L in November 2010 compared to 1.81 mg/L DRO in June 2010. TPA1-MW-5 remained below cleanup level as it always has in previous sampling events.
With the exception of the GRO level at TPA1-MW-2, which had a trend of zero, contaminant levels analyzed were all trending downward. The GRO level at TPA1-MW-3 is significant at a < 0.05 & meets the data quality requirements to be considered statistically valid for the purposes of this report. The benzene level trend at TPA1-MW-3 is significant at a < 0.001 & also meets the data quality requirements to be considered statistically valid for the purposes of this report.
DRO
Though sufficient data was available to calculate these trends, due to the small number of data points & other factors no DRO trends on St. George meet the data quality requirements for this project to be considered statistically valid. These DRO trends should not be used to draw conclusions or make decisions.
GRO
Five of the eleven subject monitoring wells on St. George Island, TPA1-MW-2, TPA1-MW-3, TPA2-MW-1, TPA2-MW-2, & TPA8-MW-4 had GRO levels statistically analyzed for monotonic trends. Three of the wells had downward trending GRO levels; one well had an upward trending GRO level; & one well had a GRO level trend of zero. The GRO trend at TPA1-MW-3 was the first GRO trend to be calculated with a significance of 95% or greater in St. George. The GRO level is trending downward, & at 95% or greater significance, meets the data quality requirements to be considered statistically valid for this project.
Benzene & PCE
Two wells were statistically analyzed for monotonic trends of benzene & PCE; TPA1-MW-3 for benzene, & TPA8-MW-4 for PCE. Analyses showed that benzene & PCE are trending downward & that the benzene trend is significant at 95% or greater, meeting the data quality requirements to be considered statistically valid for this project.
RRO
Though sufficient data was available to calculate these trends, due to the small number of data points & other factors no RRO trends from the St. George wells meet the data quality requirements for this project to be considered statistically valid. These RRO trends should not be used to draw conclusions or make decisions. Additional sampling & analysis will further verify the contaminant trends presented in this report. Factors influencing groundwater contaminant concentrations such as water table variations as related to seasonal changes & sampling location. |
Louis Howard |
| 4/11/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Annual Report for Groundwater Monitoring on St. George Island. The document covers groundwater monitoring for TPA 1, TPA 2, TPA 8, and TPA 22-1 as well as the Village Monitoring Wells.
Table 3-1: November 2010 Sampling Event Results Page 12
The table shows benzene in well TPA1-MW-3 at 15.9 µg/L and 17.6 µg/L for the duplicate sample. However, Table 4-1: GRO, DRO, RRO, Benzene and PCE Results for All Sampling Events shows 15.9 µg/L being reported. ADEC requires the highest value between a primary and duplicate sample result be reported. Technical Memorandum 08-001 “Guidelines for Data Reporting, Data Reduction, and Treatment of Non-Detect Values” (August 12, 2008) states:
In order to ensure consistent data when making site management decisions, the department provides the following clarification on data reduction reporting requirements.
1. Reporting of multiple results for the same constituent in the same sample.
2. Reduction of field duplicates to derive one value for use.
3. Handling of non-detect results in the calculation of exposure concentrations.
DATA REPORTING:
1. Reporting of multiple results for the same constituent in the same sample
In the event that more than one contaminant result is reported due to multiple analyses by a single method, the highest detected value will be used. If more than one result is reported from alternate analytical method(s) for a single contaminant, the highest detected value OR the result from the confirmatory method shall be used. This determination is made on a compound specific basis. Any method specific reporting requirements should also be adhered to.
If results are reported as non-detect by multiple analyses or methods, the undetected result with the lowest detection limit (DL) may be selected for reporting.
2. Data reduction from field duplicate samples
ADEC regulates based on the maximum result or statistically valid 95% upper confidence limit (UCL) per 18 AAC 75.380(c)(1). Therefore, ADEC requires that the most conservative detectable sample result of the primary and duplicate results be used for management decision making purposes. Primary and duplicate results shall not be averaged.
ADEC will require NOAA to use the highest reported value regardless if it is the primary or duplicate sample. Please correct Table 4-1, figures in the report and text to show the highest sample result for benzene (17.6 µg/L). |
Louis Howard |
| 8/11/2011 |
Update or Other Action |
Staff received the draft LTM plan for review and comment. This long-term groundwater monitoring plan completely replaces and combines National Oceanic and Atmospheric Administration (NOAA) Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska dated August 29, 2005 and NOAA Long-Term Groundwater Monitoring Plan, St. George Island, Alaska also dated August 29, 2005.
This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island and 10 wells on St. George Island. Some wells are utilized as sentinels to monitor for contaminant plume migration while the rest are used to monitor contaminant concentration trends to evaluate the effectiveness of past remedial actions and natural attenuation of contaminants. The requirements specified in this plan will remain in effect until evaluation of contaminant concentration trends indicate a revision is warranted. All revisions to this plan shall be reviewed and concurred with by ADEC prior to becoming final.
Based on the results of groundwater monitoring from June 2006 to November 2010, the following 10 wells will be retained for further monitoring: TPA1-MW-2, TPA1-MW-3, TPA1-MW-5, TPA2-MW-1, TPA2-MW-2, TPA8-MW-4, TPA8-MW-9, TPA8-MW-13; TPA8-MW-14, and VIL-MW-3 (Figure 2-5). Sampling and subsequent reports to ADEC will be accomplished in accordance with Section 3.0 and as follows:
-Semiannual sampling at all wells for DRO, GRO, and RRO.
-Benzene will be sampled/analyzed for every five years to verify continued decreasing concentration levels at TPA1-MW-3. The next sampling round will occur no later than November 2015.
-PCE will be dropped as an analyte.
|
Louis Howard |
| 9/29/2011 |
Update or Other Action |
Staff received the draft Long Term Groundwater Monitoring Plan St. Paul and St. George Islands, Alaska, September 2011. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island.
From June 2006 to November 2010, groundwater samples were collected semiannually from monitoring
wells TPA1-MW-2, TPA1-MW-3, TPA2-MW-1, and TPA2-MW-2; and semiannually from TPA1-MW-5
from November 2007 to November 2010. Sample analytes were DRO, GRO, benzene, PCE and, starting
in November 2008, residual-range organics (RRO) which had been detected above its ADEC cleanup
criterion in two samples collected in November 2008.
Statistical analysis of the DRO and GRO sample concentration trends indicated increasing, decreasing and zero trends; all with low confidence levels with the exception of a strong decreasing GRO concentration trend at TPA-MW-3 with a 95% confidence level (NOAA 2011b). Benzene, which exceeds its ADEC cleanup criterion only at monitoring well TPA1-MW-3, showed a strong decreasing concentration trend with a statistical confidence level of 99.9% (NOAA 2011b).
PCE was found to be either non-detect or detected below method reporting limits (MRL) in all samples collected (NOAA 2011b). RRO was found to have a decreasing concentration trends with low confidence levels at those wells with analytical results above MRL (NOAA 2011b).
NOAA installed monitoring wells VIL-MW-1 in 2001 and VIL-MW-3 in 2003 for use in a
hydrogeological modeling network. In 2009, VIL-MW-1 was decommissioned. From June 2006 to November 2010, groundwater samples were collected from VIL-MW-3 (Figure 2-5).
Sample analytes were DRO, GRO, benzene, PCE and, starting in November 2008, residual-range
organics (RRO) which had been detected above its ADEC cleanup criterion in two samples collected
from TPA Site 1 in November 2008. To-date, sample analyses have found analyte concentrations either non-detect or detected at very low levels (NOAA 2011b). Statistical analysis of contaminant concentration trends indicates an increasing trend for DRO at a low confidence level; all other analytes had less than two sample results above MRL, therefore no statistical analysis performed (NOAA 2011b).
St. George Long-Term Groundwater Monitoring Requirements
Based on the results of groundwater monitoring from June 2006 to November 2010, the following 10
wells will be retained for further monitoring: TPA1-MW-2, TPA1-MW-3, TPA1-MW-5, TPA2-MW-1,
TPA2-MW-2, TPA8-MW-4, TPA8-MW-9, TPA8-MW-13; TPA8-MW-14, and VIL-MW-3.
Sampling and subsequent reports to ADEC will be accomplished in accordance with Section 3.0 and as follows:
• Semiannual sampling at all wells for DRO, GRO, and RRO.
• Benzene will be sampled/analyzed for every five years to verify continued decreasing
concentration levels at TPA1-MW-3. The next sampling round will occur no later than November 2015.
• PCE will be dropped as an analyte. |
Louis Howard |
| 5/15/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final GW monitoring plan which includes this site. |
Louis Howard |
| 9/14/2012 |
Update or Other Action |
Draft GW Monitoring Annual Report received.
Monitoring wells TPA1-MW-2, TPA1-MW-3, and TPA1-MW-5 were installed to monitor the potential migration of diesel and gasoline in the groundwater beneath the former aboveground storage tank (AST) tank farm and fuel transfer lines at TPA Site 1. During the 2012 sampling events all three wells were sampled for GRO, DRO, and RRO. Duplicate samples were taken for all analytes at wells TPA1-MW-3 during the June 2012 sampling event.
The DRO concentrations at monitoring wells TPA1-MW-2 and TPA1-MW-3 exceed ADEC cleanup levels for both 2012 sampling events. The only detection for Well TPA1-MW-5 was in June 2012 for RRO, but at a concentration less than the LOQ and cleanup level.
Analytes with more than one instance of a sample being reported above the detection limit were
statistically analyzed using a Mann-Kendall trend and Sen’s Slope analysis; in this case DRO, GRO, and RRO were analyzed at TPA1-MW-2 and TPA1-MW-3. For these two wells the DRO, GRO, and RRO concentration trends are downward. The GRO concentration at TPA1-MW-3 is significant at a < 0.05, which indicates it is considered statistically valid.
TPA1-MW-2 2.04 mg/L DRO, TPA2-MW-3: 3.38 mg/L DRO, TPA1-MW-5: below Table C for DRO, GRO, RRO. |
Louis Howard |
| 10/22/2012 |
Update or Other Action |
Draft GW Monitoring WP received. Petroleum contamination has been detected at a number of properties currently and formerly owned and operated by NOAA and its predecessor agencies. Affected properties are described in a two party agreement (TPA) between NOAA and the Alaska Department of Environmental Conservation (ADEC) dated January 26, 1996 (NOAA 1996). Under State of Alaska regulations and in accordance with the TPA, NOAA has undertaken site characterization and restoration activities on St. George and St. Paul Islands.
The following ten wells are considered sentinel wells and will be sampled as part of this scope of work: TPA1-MW-2, TPA1-MW-3, TPA2-MW-1, and TPA2-MW-2 for plume movement north; TPA8-MW-4 and
TPA8-MW-9, for plume movement to the east and southeast; TPA8-MW-13, TPA1-MW-5, and VIL-MW-3
for plume movement to the west; and TPA8-MW-14 for plume movement to the south.
TPA Sites 1 and 2 (former Diesel Tank Farm and Drum Storage Area, respectively) were used from the 1950s to the 1970s for bulk storage of fuels. Previous environmental investigations at both the Diesel Tank Farm and the Drum Storage Area have found widespread DRO and GRO contamination in the soil. Petroleum contaminants have also been detected in the groundwater at both sites. There are five wells (TPA1-MW-2, TPA1-MW-3, TPA1-MW-5, TPA2-MW-1 and TPA2-MW-2) that will be sampled as part of this work. |
Louis Howard |
| 10/30/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft GW monitoring work plan.
2.2 Subcontractors & Service Providers
SGS-Anchorage (UST-005) approval expires on December 18, 2012. It is NOAA’s responsibility to ensure that the primary laboratory, any other “network” or sub-contracted laboratory is currently approved by ADEC. ADEC will require NOAA to have the lab supply a copy of their current ADEC approval letter in the draft and final work plan. These letters detail the methods, matrices, and dates for which the lab has approval. Labs must renew their approval and pass performance evaluation samples annually.
The text states that field activities performed by the Field Technicians as directed and coordinated by the Field Team Leader. As directed and coordinated shall have the same meaning as supervised as defined by 18 AAC 75.990(125) and 18 AAC 78.990(142) for “supervise”.
Figure 3-1
Not only will groundwater flow direction be indicated on figure, but groundwater contours (in feet) will also be required for the St. George Island Monitoring Well Locations.
4.3 Determine the Presence of Free Product (NAPL)
ADEC will require the identity and relative age (i.e. fresh fuel from a new release not likely to be related to NOAA’s activities) of the free product be determined through laboratory analyses if it is detected in an area that has not had free product historically present in the well.
4.7 Investigation derived waste
The filtered purge water may be reapplied to the ground surface within site boundaries and a minimum of 100 feet away from any drinking water wells and/or surface waters (ADEC Draft Field Sampling Guidance May 2010).
As a result of this discharge of monitoring well purge water, there will be no increase in the transport of the contaminant(s) of concern to uncontaminated areas. The discharge shall not cause contamination of surface or groundwater, and shall not cause a violation of the Alaska Water Quality Standards (18 AAC 70). The discharge shall not cause adverse effects on aquatic or terrestrial plant or animal life, their reproduction or habitat.
|
Louis Howard |
| 9/30/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed the proposal by NOAA to continue groundwater sampling under the existing approved monitoring plans. ADEC has reviewed the information provided and approves the work as a continuation of the three existing work plans for groundwater monitoring on the Pribilof Islands. |
Louis Howard |
| 10/13/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft groundwater monitoring plan. Main comments centered on the update for referencing a qualified person to meet the new definition found at 18 AAC 75.333.
See site file for additional information. |
Louis Howard |
| 5/24/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft groundwater annual report. ADEC does not concur on the removal of wells TPA1-MW-5, TPA2-MW1 and TPA2-MW-2 from future sampling efforts. These wells serve as sentinel wells and need to be monitored until all monitoring wells achieve cleanup levels for two consecutive sampling events.
See site file for additional information. |
Louis Howard |
| 5/24/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft 2014 GW monitoring report. ADEC will approve the report with one exception. ADEC does not concur on the removal of wells TPA1-MW-5, TPA2-MW1 and TPA-MW-2 from future sampling efforts. These wells serve as sentinel wells and need to be monitored until all monitoring wells achieve cleanup levels for two consecutive sampling events.
See site file for additional information. |
Louis Howard |
| 10/3/2017 |
Update or Other Action |
LTM Groundwater monitoring report received for review and comment. Analytical results for groundwater samples collected in November 2016 and May 2017 at the Former Diesel Fuel Tank Farm (TPA Site 1), Drum Storage Area (TPA Site 2), and Active Power Plant (TPA Site 8) indicated the presence of hydrocarbon compounds in groundwater. Samples from two of the ten wells (TPA1-MW-2 and TPA1-MW-3) had concentrations of DRO greater than the ADEC groundwater CL. Additional sampling and analysis will further verify the contaminant trends presented in this
report. Continued monitoring may result in additional monitoring wells showing decreasing
trends for COCs. It is recommended that semi-annual groundwater monitoring continue at St.
George wells until it can be demonstrated that TPA1-MW-2 and TPA1-MW-3 meet Table C
Groundwater CLs.
See site file for additional information. |
Louis Howard |
| 10/6/2017 |
Update or Other Action |
GW Monitoring work plan received for review and comment. The work plan will: evaluate each monitoring well location for the presence of non-aqueous phase liquid(NAPL) and, if present, measure the thickness of the NAPL; collect groundwater samples from ten monitoring wells using low flow sampling methods; submit samples to certified laboratory for analysis of gasoline-range organics (GRO), diesel-range organics (DRO), and residual-range organics (RRO); review laboratory data for accuracy, precision, representativeness, comparability, completeness, and sensitivity and prepare data quality assurance summaries documenting the results; use the analytical data acquired during the biannual monitoring events along with available and applicable historical analytical data to evaluate contaminant concentration trends and assess the statistical relevance of each trend identified using Mann-Kendall statistical methods; and produce a groundwater monitoring report after the second of two rounds of groundwater
monitoring.
See site file for additional information. |
Louis Howard |
| 10/20/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the work plan for GW monitoring. Main comments were to update or delete and revise the NOAA Master quality assurance plan from 2006 since regulations, guidance documents and policy have changed in the interim from 2006 to 2017. Lastly staff requested current (if not - then in the future) groundwater methods include petroleum VOCs and PAHs.
See site file for additional information. |
Louis Howard |
| 5/15/2018 |
Document, Report, or Work plan Review - other |
Staff approved the final version of the groundwater monitoring plan. |
Louis Howard |
| 10/30/2018 |
Document, Report, or Work plan Review - other |
Staff approved the final groundwater monitoring report for St. Paul and St. George sites.
See site file for additional information. |
Louis Howard |
| 9/6/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the draft groundwater monitoring report for St. George Island. Main comments were to require custody seals on the coolers as required by ADEC's Field Sampling Guidance (2017).
See site file for additional information. |
Louis Howard |
| 9/8/2020 |
Update or Other Action |
DEC sent a letter to the National Oceanic and Atmospheric Administration on 09/08/20 concurring with cancellation of the Spring 2020 groundwater monitoring sampling at St. Paul Island and St. George Island due to travel restrictions caused by the COVID-19 pandemic. |
Melinda Brunner |
| 10/13/2020 |
Update or Other Action |
DEC sent a letter to the National Oceanic and Atmospheric Administration on 10/13/20 concurring with cancellation of the Fall 2020 groundwater monitoring sampling at St. Paul Island and St. George Island due to travel restrictions caused by the COVID-19 pandemic |
Melinda Brunner |
| 5/26/2021 |
Update or Other Action |
DEC sent a letter to the National Oceanic and Atmospheric Administration on 10/13/20 concurring with cancellation of the Fall 2020 groundwater monitoring sampling at St. Paul Island and St. George Island due to travel restrictions caused by the COVID-19 pandemic |
Shonda Oderkirk |
| 10/12/2021 |
Document, Report, or Work plan Review - other |
Received Draft St Paul and St George Groundwater Monitoring Work Plan, October 2021. 10/13/2021: Comments sent. |
Shonda Oderkirk |
| 10/12/2021 |
Document, Report, or Work plan Review - other |
Received Draft St Paul and St George Groundwater Monitoring Work Plan, October 2021. 10/13/2021: Comments sent. |
Shonda Oderkirk |
| 10/12/2021 |
Document, Report, or Work plan Review - other |
Received Draft St Paul and St George Groundwater Monitoring Work Plan, October 2021. 10/13/2021: Comments sent.10/18/2021 RTC received. Approval for final WP sent 10/20/2021.
11/4/2021: Received email summary of sampling last week. Report will not be completed until the Spring 2022 sampling event has been conducted. |
Shonda Oderkirk |
| 10/7/2022 |
Long Term Monitoring Workplan or Report Review |
Received work plan for monitoring wells on St Paul and St George. 10/13/2022: Send comments. Field work set to start on Monday Oct 17, conditional approval given for work to start on time. Requested GAC break through calculations will be sent ASAP. 10/27/2022: Final copy of WP received. 11/1/2022: Final approval for WP sent. |
Shonda Oderkirk |
| 12/29/2022 |
Long Term Monitoring Workplan or Report Review |
Draft report received. 1/20/2023 comments sent. 1/31/2023 RTC received. 2/2/2023 Final approval sent. |
Shonda Oderkirk |
| 10/12/2023 |
Document, Report, or Work plan Review - other |
Received draft work plan. 10/13/2023 approval sent. |
Shonda Oderkirk |
| 11/9/2023 |
Document, Report, or Work plan Review - other |
The Fall 2023 field work has been canceled. Weather prevented the field team from making it out to the Pribilofs 4 times. DEC approved the cancelation. Field work will resume in the Spring of 2024. |
Shonda Oderkirk |
