| Action Date |
Action |
Description |
DEC Staff |
| 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 |
| 8/11/1994 |
Update or Other Action |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former national marine fisheries service (NMFS) facilities on Saint George Island. ADEC traveled 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, 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 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 these 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 |
Update or Other Action |
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. |
Jennifer Roberts |
| 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. Four test pits were completed (TP-8, TP-11, TP-12, TP-13). Subsurface water was found at TP-8 at approximately 8' below ground surface. A well point was installed and water sample collected. This was the only time a water sample was collected during this investigation and only from TP-8.
A sheen was observed on the water surface. Lab results showed that the petroleum hydrocarbons are above ADEC water quality standards. Surface soil sample TP-11 had detected: xylenes-1,200 mg/kg, toluene-190 mg/kg, ethylbenzene-12 mg/kg, DRO-4,500 mg/kg and GRO-8,600 mg/kg. TP-12 had DRO at 4,100 mg/kg and TP-13 had DRO at 6,500 mg/kg. Water sample collected showed DRO, GRO and TPH at 4.4 mg/l, 0.27 mg/l and 7.5 mg/l respectively. The general area of elevated levels of target constituents appear to be confined to the surface and likely the result from surface spills. |
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. |
Ray Dronenburg |
| 8/11/1995 |
Site Ranked Using the AHRM |
Site ranked. |
Ray Dronenburg |
| 10/31/1996 |
Cleanup Plan Approved |
Ray Dronenburg sent Polarconsult Inc. Dave Ausman, a contractor working on behalf of NOAA, an approval letter for containment cell design. Fax was received on 10/30/1996 for approval for a contaminated material storage cell. Unfortunately the fax copy was not clear enough to determine exact specifications, however, it is assumed (by ADEC) that ADEC guidance documents regarding contaminated material storage were considered in the design. (Plan states: "Since the containment cell will incorporate a water treatment system and regular maintenance program to process accumulating precipitation, Tanaq requests that the department waive the requirement for a top cover for the soil. The main reason for this request is that the top cover is expected to be problematic given the island's high winds and the need to uncover the piles on a daily basis."
ADEC's primary concern for the storage facility will be the protection of any surface water or groundwater sources. Having been to St. George on several occasions it would appear that the site selection would be near or on the old runway and not in the vicinity of any surface water sources, however, because of our discussion regarding cover for the stockpile and with a potential for leachate from the pile as well as rinsate from the UST activities, it might be prudent to develop at some point, a schedule for monitoring for excessive water accumulation.
The cell design and location are approved as submitted.
NOTE to file: Petroleum contaminated soils were from UST and Non-UST related sources encountered during FY97 Phase I Cooperative Agreement a.k.a. "Part I of the cleanup operations" on St. George Island. These include, but are not limited to, TPA 02 STG Former Drum Storage Area and TPA 03 Inactive Gas Station (oceanfront) (1624 cubic yards removed), TPA 10 STG Former Kerosene Drum/AST Storage Area, TPA 11 STG Cottage C UST (98 cubic yards removed), TPA 12 STG Former Hangar Building (195 cubic yards removed), TPA 21 Abandoned City Diesel Tank Disposal Site (1500 cubic yards removed), and TPA 23 Inactive/Abandoned Diesel Tank Farm (4,146 cubic yards removed.) *approximately 7,563 cubic yards.
NOTE: Although not called out for in the original design drawings, a double liner system with a minimum of six inches and an estimated twenty-four inches of interbed sand was found during the liner removal in 2006. The drainage system was designed to capture precipitation that perculated through the stockpile. Approximately 11,000 cubic yards of PCS were excavated from several island TPA sites, and stockpiled on the protective sand layer above the liner. |
Ray Dronenburg |
| 2/7/1997 |
Update or Other Action |
Polarconsult letter-Dave Ausman with data sent to St. George Tanaq Corp. Bret Coburn regarding containment cell baseline analysis. December 5, 1996 four (4) soil samples were taken from 1.5 feet below grade and shown to be below ADEC "Level A" cleanup standards for diesel and gasoline range organics. Based on the low concentrations found, and since the liner material is being installed, the collection of more samples may not be warranted or feasible immediately from under the containment cell. |
Ray Dronenburg |
| 2/21/1997 |
Update or Other Action |
Ray Dronenburg sent Dave Ausman Polarconsult Inc. letter regarding St. George Work plan for site assessment and contaminated soil removal. It is recommended that all field analysis conform to UST requirements for sampling by method and location. It is recommended that text be clarified to correctly state the intent for contaminated water draining away from the temporary stockpiling locations. In order that work can proceed and because the aforementioned remarks were personally discussed with Polarconsult, this work plan is approved having received the assurance from Polarconsult that appropriate changes will be made to the work plan to satisfy ADEC requirements. |
Ray Dronenburg |
| 7/17/1997 |
Update or Other Action |
Memorandum to M. Goetz Project Mgr. NOAA. RE: Permits for water discharge. 7/16/1997 Robert Dolan who handles permit system for discharge of wastewater suggested that rather than issue a specific permit for the discharge of waters from the stockpile site on St. George, he would approve Contaminated Sites staff handling the situation. Dave Ausman will add couple of pages to his monthly report to include: on a monthly basis, report the gallons of water collected from the stockpile berm and placed into the 20,000 gallon tank. Prior to any discharge, Polarconsult will then take batch samples to ensure that maximum contaminant levels (MCLs) for wastewater are not exceeded and then using the St. George sewage truck, move the water to the sewage outfall.
Lastly, Polarconsult will post a lookout to ensure that "sheen" does not occur. The only other alternative would be additional paper work (permitting process) to achieve the same results. Mr. Ausman is faxing Ray Dronenburg in a memorandum of understanding for the procedure and when the Department receives it will provide NOAA with a copy. The Department does not see any reason not to do the same thing on St. Paul.
7/17/1997 FAX Polarconsult to R. Dronenburg: Discharge of water from the soil containment cell. Water will be collected in the 20,000 gallon tank adjacent to the cell, batch analyzed, and transferred to the City of St. George's sewer system. The system is connected to an outfall line which discharges to the Bering Sea. The sample collection, analysis, record keeping, effluent limitations, and noncompliance notification will be performed in accordance with the procedures outlined in the ADEC waste water general permit #9240-DB005. In consideration of the mixing zone allowance, the effluent limitation will be 1 mg/L for Total Aromatic Hydrocarbons (EPA 602) and 1.5 mg/L for Total Aqueous Hydrocarbons (EPA 602+610) as allowed in appendix 1.B of the permit. The city of St. George has agreed to the discharge of water through the local sewer system provided ADEC indicates approval.
Signed and approved by Ray Dronenburg July 17, 1997. |
Ray Dronenburg |
| 9/24/1997 |
Update or Other Action |
D. Ausman Polarconsult re: St. George NOAA cleanup, maintenance of containment cell. ADEC inquired about the continued maintenance of the contaminated stockpile containment cell and Polarconsult discussed the matter with Bret Coburn and Andy Kashervarof. Although there are no additional funds available under Tanaq's current award to maintain the cell, Tanaq intends to perform basic maintenance to the cell for the next several months in the interim between now and the next phase of the project. On a daily basis the cell is visited and water in the sump is pumped into the 25,000 gallon tank and that Andy reports the water being pumped into the tank is clear and no longer exhibits any sheen, nor can he detect any odor from the stockpile which used to have a detectable odor.
Andy informed Polarconsult that 40 knot winds had been stripping the sand that covers the edges of the bottom liner at places around the cell and as a result the liner is lifting. Andy intends to use the loader to recover the liner in these areas. Although the wind is displacing the sand, Andy stated that no migration of the more cohesive contaminated soil is occurring.
This situation may be a harbinger of problems to come with the top cover to this cell. Even with the proposed 200 sand bags and 1,000 feet of polypropylene rope, Andy is very skeptical of whether the top cover will remain in place without being completely covered with soil. As the Department is probably aware, this was one of the reasons Polarconsult made proposals early in the project to avoid use of the top cover. |
Ray Dronenburg |
| 6/24/1998 |
Update or Other Action |
R. Dronenburg letter w/L. Bush letter attached to Mr. Minh Trinh Pribilof Project Manager re: Contaminated Sites (LUST) stockpile St. George Island. On several occasions the Department has requested NOAA provide some sort of contractual assurance that leachate from the stockpile would be handled consistent with an earlier agreement. This assurance has never been achieved. Additionally and since the original agreement, extensive community concerns have been expressed for contamination spreading as caused by blowing material from the exposed stockpile, a concern the Department supports.
Please note that Ms. Bush has requested a thirty (30) day time frame be allowed for this action. The Department is aware that negotiations for the planned Phase II portion of this cleanup action has suffered considerable delay and therefore considers immediate cover as essential.
While the work plan detailing the construction of the stockpile was originally approved without a cover, it became apparent that a cover would be necessary to protect human health and the environment. After discussion of site conditions during a visit by Bush in March 1997, Mary Goetz, then Program Manager for this project, agreed to Bush's request to cover the stockpile. As of today, the stockpile has yet to be properly covered. On June 17, 1998, Department staff observed the stockpiled soil from the site not covered and has reportedly not been covered since the stockpile was created. Photos are enclosed of the stockpile not being covered.
The Department requests NOAA: cover the entire stockpile in accordance with 18 AAC 78.311 within thirty (30) days of receipt of this letter and provide written statement tot he Department within thirty (30) days of receipt of this letter documenting the stockpile has been covered. Please be aware that the Department may request sampling for secondary contamination in the areas under and around the improperly contained stockpile. Further, the Department may require calculations of air emissions and evaluation of the potential impact to human health and the environment. Evaluation of the potential impact to the seal haul-out located in close proximity to the stockpile may be required, as well.
The leachate collection system, designed and installed prior to the Department's request that the stockpile be covered, also does not appear to be in good working order. Please revise the existing workplan or submit a new workplan to the Department for review and approval, to include any needed repairs, replacement, long term maintenance, or decommissioning of the system, whichever is more appropriate to your long term plans for the stockpile. Include a schedule with your statement of proper containment that details the timetable for remediation and disposal of the soil contained in the stockpile.
*June 28, 1998 NOAA sent Photos to R. Dronenburg with letter stating stockpile has been properly covered and contained. |
Ray Dronenburg |
| 9/3/1998 |
Update or Other Action |
Another letter to NOAA re: Request to properly contain excavated petroleum contaminated soil. August 31, 1998, the Department received a citizen's complaint that the petroleum contaminated stockpile on St. George is no longer properly covered or maintained. Due to winds and rain, the cover has apparently torn open and exposed the stockpile. The stockpile should be covered immediately. A written statement should be made to the Department, by no later than thirty (30) days after the receipt of the letter, that details the steps taken to recover the pile and investigate the leachate collection system. Failure to comply with soil storage and disposal regulations may result in civil and/or criminal action as described in AS 46.03.760 and AS 46.03.790.
To assure all parties that the pile is properly maintained, the Department strongly recommends that NOAA assign a person or entity to inspect the stockpile and correct any deficiencies on no LESS than a weekly basis. |
Ray Dronenburg |
| 10/26/1998 |
Update or Other Action |
Letter to Minh Trinh NOAA project manager. The Department has spent some time attempting to resolve the contention that debris remaining on St. Paul and St. George Islands are the property of military versus NOAA versus National Marine Fisheries Service. Records that are available in the National Archives Facilities in Anchorage, Alaska reveal that ALL goods (both permanent and renewable) came on the island at the direction of NOAA and for the purpose of NOAA. All supplies came by "Cool Barge". Cool Barge was a military operation originating in Oakland California (Navy Supply Depot) and which carried supplies, all of which were marked with Federal Stock Numbers.
The exception to this was under the exclusive use of the Army during the period by 1942 to 1946. However, records again available in the National Archives, indicate that materials abandoned on the Pribilofs by the military and after occupation were utilized by the NOAA for the purpose of NOAA. ADEC strongly suggests that NOAA retain the services of a person or persons to review this historical data which ADEC believes will provide information to support the contention that debris left on the Islands is the responsibility of the Federal Government. |
Ray Dronenburg |
| 10/29/1998 |
Update or Other Action |
Letter to Minh Trinh NOAA Project Manager re: contaminated stockpile located at St. George Island requirement to cover and maintain the PCS stockpile. The Department has received and reviewed NOAA's response to the Department's September 1, 1998 letter. Due to the considerable length of time since the Department expected NOAA to take action to remediate the stockpile, and the continued lack of a work plan to do so, a cover is required. The leachate collection system should be inspected and maintained as well.
NOAA's points about the wind and weather in the Pribilofs have validity, however, the Department continues to require you to cover and maintain the stockpile in accordance with 18 AAC 78.311. Continual vigilance of the cover is necessary and the Department recommends that both it and the stockpile be inspected at least once per week and step to maintain the cover be taken as needed.
As Ray Dronenburg stated in the October 22, 1998 session of the Restoration Advisory Board, the contaminated stockpiles should be covered. In his October 27, 1998 letter to Nancy Briscoe, Breck Tostevin also indicated that the Department expects the stockpile to be covered. |
Lynne Bush |
| 11/12/1998 |
Update or Other Action |
Site update for Site Number 2 OU 6. Drums and bulk debris removed in 1997. Soil remediation to be included in upcoming FY99 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.
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 |
| 6/2/1999 |
Update or Other Action |
Staff received and reviewed the work plan for sampling and analysis of stockpiles for St. Paul and St. George Islands. If NOAA is seriously considering using thermal desorption for the soils as a remedial technology instead of proposing use of soils as a cover material, then the number of samples is acceptable as originally proposed in the plan. Post-treatment samples must meet or be lower than Level "A" criteria if thermally treated.
If the ultimate disposal of the soils is for use as cover on a solid waste unit or some other type of use, the Department proposes that the contractor characterize the stockpiled soil as necessary to determine whether treatment or disposal of the soil is needed, to assist with selection of treatment or disposal methods, and to establish baseline data for use in evaluating the effectiveness of the treatment. The Department requests the contractor use ten (10) times the maximum contaminant levels to analyze for leaching via TCLP vs. the proposed methodology to analyze a particular sample for TCLP if the concentration exceeds twenty (20) times the maximum contaminant levels for a particular contaminant. |
Louis Howard |
| 8/17/1999 |
Update or Other Action |
Staff sent letter re: St. George Petroleum Contaminated Soils Stockpile Cover Design August 16, 1999. The text states that the TUFF WEAVE liner material can be ordered in widths up to 330 feet wide. Since the stockpile is less than 100 feet wide, the Department suggests NOAA use liner material to cover the stockpile with one sheet rather than several sheets joined together. This approach will eliminate sealing seams of liner material together in the field. If NOAA chooses to use several sheets of liner material and seal the seams in the field, then the Department requests that NOAA follow all manufacturer's requirements for sealing seams. The Department requests clarification on whether the liner material will be 12 mil in thickness as described on page 1 or 10 mil in thickness as described on figures 2 and 3. After addressing the above issues satisfactorily, the Department will consider the plan final. |
Louis Howard |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 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 |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 2/15/2000. Contractor to mobilize in field in July 2000. |
Louis Howard |
| 4/13/2000 |
Update or Other Action |
Jeanette Brena Construction Permit Engineer Division of Air and Water Quality, Air Permits Program Juneau office sent letter to Dennis Hall Re: Permit Applicability of the NOAA Enhanced Thermal Conduction Systems On the Pribilof Islands. According to the technical information received the four 2.2MMBtu/hr per unit diesel burners total heat input would not exceed the 9.3 MMBtu per hour limit. The ETC system is located in a special protection area identified under 18 AAC 50.900(25), but is not a source rated capacity of 10 MMBtu per hour or more. Therefore, no permit is required to operate the ETC system under existing State Air Quality Control Regulations.
However, the ETC system will need to meet the following State Air Quality Control Standards for industrial and fuel burning equipment:
1) Visible emissions excluding condensed water vapor, may not exceed twenty percent opacity for greater than three minutes in any one hour (18 AAC 50.055(a)(1));
2) Particulate matter emissions may not exceed 0.05 grains per cubic feet of exhaust gas, as corrected to standard conditions (18 AAC 50.055(b)(1));
3) Sulfur compound emissions, expressed as sulfur dioxide may not exceed 500 parts per million averaged over a period of three hours (18 AAC 50.055(c));
4) No person may emit any emission which is injurious to human health, welfare, animal or plant life, or property, or which would unreasonably interfere with the enjoyment of life or property (18 AAC 50.110). |
Louis Howard |
| 5/30/2000 |
Update or Other Action |
Staff commented on the Draft Facilities Operations and Process Description for Remediation of Petroleum Contaminated Soil May 22, 2000. A separate workplan for review and comment will need to be submitted for remediation of soils on St. Paul Island.
The Department requests clarification from NOAA on how the cells will be constructed in greater detail than what is presented in figure 2 of the document. The Department assumes NOAA will treat all petroleum contaminated soil including oversized material without screening out the oversized material. If NOAA proposes to screen out the oversized material (i.e. greater than two inches in size), then NOAA must demonstrate the material is indeed impervious to petroleum constituents in accordance with DEC guidance document "Petroleum Hydrocarbon Cleanup Goals For Oversized Materials" (SPAR\Director\8-93\003). DEC requests NOAA use liner material with the minimum specifications found in the UST Procedure manual Table D Bottom Liner specifications for Short Term storage of petroleum contaminated soil (less than 180 days).
Typically for determining whether or not the excavated material has been treated to cleanup standards at least one field screening sample would be obtained from each ten cubic yards of treated soil. Instead of the sixty soil samples required for post-treatment sampling, the Department is proposing that NOAA collect no less than twenty-eight soil samples for field screening purposes on a 600 cubic yard treatment cell vs. the fourteen proposed by NOAA in its submittal.
The Department requests NOAA obtain these samples from: the bottom of the soil treatment cell, but above the original base layer of clean material after the treatment cell has cooled down sufficiently, from the middle of the treatment cell (i.e. if cell is eight feet tall, then sample from a depth of four feet), and the furthest point from each hot air injection manifold and/or piping but no closure than 18 inches from the surface of the stockpile. Field screening must follow the procedures outlined in the UST Procedure Manual for treatment of petroleum contaminated soil and water standard sampling procedures (effective March 1, 1999). |
Louis Howard |
| 6/7/2000 |
Update or Other Action |
Staff reviewed and commented on the Revised Draft General Facilities Operations and Process Description for Remediation of Petroleum Contaminated Soil, Pribilof Islands Restoration Project, St. George Island Dated June 6, 2000.
21.0 Confirmation Soil Sampling NOAA Response to Comments from DEC
Item 3 states the design of this system would have the greatest chance for contamination after treatment being present nearer the surface of the soil cell. DEC disagrees with NOAA on this matter based on its experience with previous sites in Alaska using this type of system. However, NOAA may choose to take limited surface samples to ensure that they have met the remedial action objective of Method 1 Category “A” cleanup-criteria. These samples would be in addition to those samples being proposed in the plan and may not be substituted for any of the final confirmation samples.
DEC will approve the revised plan as submitted. If the plan is modified significantly from its current form, then NOAA must contact DEC to discuss the changes to the plan. |
Louis Howard |
| 9/20/2000 |
Update or Other Action |
Staff sent letter on Waiver Request for Stockpile Cover Installation on Stockpiles associated with the Enhanced Thermal Conduction System on the Pribilof Islands dated September 19, 2000. The Department is aware of the problems and unforeseen circumstances NOAA has had to deal with remediation the soil stockpiles on the Pribilofs. Based on a review of the information presented by NOAA, the Department will grant a one-time waiver for stockpile cover installation at both islands for stockpiles associated with this specific remediation effort.
This waiver is contingent upon NOAA treating all the remaining stockpiles to level “A” cleanup criteria and the most stringent cleanup criteria for: benzene, ethylbenzene, toluene, and total xylenes listed in 18 AAC 75.341. If NOAA fails to remediate all the soils in the 2001 field season, then the Department will require NOAA to cover its remaining stockpiles with a synthetic membrane material designed to withstand the extreme weather conditions on the Pribilofs. Stockpiles generated during future investigation, removals, or cleanup work by NOAA (including NOAA’s Compliance program) shall not be eligible for this waiver and be required to meet the requirements for stockpiles listed in 18 AAC 78.274. |
Louis Howard |
| 4/11/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. 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.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as 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.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. 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. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 10/2/2001 |
Long Term Monitoring Established |
Twenty-two (22) monitoring wells were installed at TPA Sites 1, 2, 3, 7, 8, 9, 11,18, 22.1, 22.3, 23, 24 and in village; conducted aquifer testing July through October 2001. The monitoring wells were installed in basalt bedrock after encountering layers of overlying unconsolidated pyroclastic debris of varying degrees of compaction and hardness. All of the monitoring wells were drilled using air rotary drilling methods with NOAA’s Foremost Mobile B-58 drilling rig that was equipped with an air compressor as a separate unit. The boreholes were advanced using a 4.75-inch diameter pneumatic hammer and ODEX casing advancement system that advanced 6-inch diameter steel casing and produced a nominal 6-inch diameter borehole. In some cases the steel casing was advanced such that it was seated in competent rock and the borehole completed using the downhole hammer in the open hole.
The boreholes were advanced to a target depth of approximately 8 feet below the static water level, in order to place a 15-foot long screen that would straddle the water table. The cuttings from the borehole were logged as grab samples by a geologist. Boring logs have been attached to previous reports. After the borehole was advanced to the target depth, the well was installed. The monitoring wells consisted of a 2-inch diameter Schedule 40 polyvinyl chloride (PVC) riser pipe and well screen with 0.010” slots. A filter pack consisting Colorado 10/20 silica sand was installed to a height of 2 feet above the top of the screen. A minimum 2-foot thick bentonite seal was installed above the filter pack. A bentonite cement grout was used to fill the remainder of the annulus to 10 feet bgs. The remainder of the annulus was filled with bentonite grout. The monitoring wells were completed above the ground surface using locking steel protective casings.
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Louis Howard |
| 10/31/2001 |
Update or Other Action |
In 2000 and 2001 NOAA installed and began operation of an enhanced thermal conduction (ETC) soil treatment system to the east of the PCS stockpile location. Approximately 10,000 cubic yards of the PCS stockpiled in 1997 were thermally remediated to meet ADEC soil cleanup criteria. |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
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.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 9/30/2002 |
Update or Other Action |
NOAA and its contractors continued PCS excavation at island TPA sites and ETC treatment of stockpiled soil. Approximately 1,500 cubic yards of PCS were treated, and an estimated 3,300 cubic yards of PCS remained stockpiled at the end of the field season. Due to unacceptably high operating costs, the ETC system was not operated after 2002. |
Louis Howard |
| 3/10/2003 |
Document, Report, or Work plan Review - other |
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 |
| 2/11/2004 |
Update or Other Action |
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 square feet, the Department concurs. The Department disagrees with the proposed sampling alternatives after the first 2,500 square feet have been addressed. The Department requests NOAA collect field screening samples for every 350 square feet of final excavation bottom greater than 2,500 square feet or approximately 80 samples (in addition to the 10 samples required for the first 2,500 square feet for final excavated bottom from an estimated 30,783 square feet. Therefore, 90 samples for final excavated bottom would be collected by NOAA for 30,783 square feet 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 square feet of excavation bottom of up to 2,500 square feet will be collected for the first 2,500 square feet, the Department concurs with this approach. The text goes further to state that one sample for every 500 square feet of excavation exceeding 2,500 square feet will be collected for a minimum of 67 samples taken for an estimated 30,783 square feet. The Department disagrees. The Department requests a total of 98 samples or sampling for every 350 square feet of final excavated bottom exceeding 2,500 square feet. 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 |
| 3/22/2004 |
Update or Other Action |
Staff received and reviewed NOAA's Waiver Request Regarding Chromium Concentrations, Volcanic Materials and Soils, Clean Source Material, St. George Island.
After reviewing the data, the Department concurs with the request to use volcanically derived, naturally occurring materials (e.g. scoria, tuff, basalt) and soils (e.g. beach sand, sandy loam) as clean fill material. The source material is not known nor suspected to be contaminated with external or anthropomorphic sources of chromium. The chromium levels detected in the materials may be considered “background ” concentrations. This decision is in accordance with 18 AAC 75.340(h)(1). Soil cleanup levels; general requirements: “The department will approve less stringent soil cleanup levels subject to any institutional controls required under 18 AAC 75.375, if a responsible person demonstrates that (1) background concentrations of a hazardous substance in the site area exceed the applicable cleanup level set out in 18 AAC 75.341 for the hazardous substance.” This approval is only for chromium+3 (CAS Number 16065-83-1) and does not apply to any other contaminant of concern that may be found on St. George Island. No institutional controls or special handling for the fill material with these background levels of chromium will be required. |
Louis Howard |
| 5/3/2004 |
Update or Other Action |
The Alaska Department of Environmental Conservation (the Department) concurs with NOAA’s plans to cover the stockpile at the end of the 2004 field season. Total volume of the stockpile is not to exceed ten-thousand (10,000) cubic yards as a long-term stockpile site. Be aware that NOAA’s definition of the term “long-term” storage does not meet the regulatory definition of “long-term storage”. 18 AAC 75.370 Soil Storage and Disposal Table D refers to long term storage as one-hundred eighty (180) days to two (2) years.
Those stockpiles which are used for storage longer than two (2) years without treatment may require a solid waste permit review under 18 AAC 60 Solid Waste regulations. This approval is granted with the understanding that NOAA will provide a work plan addressing the stockpile’s ultimate disposition for Department review and comment by January 31, 2005. Without a work plan being submitted by this date, the Department will require NOAA to apply for a solid waste permit for a monofill from the Solid Waste Program. |
Louis Howard |
| 4/23/2007 |
Exposure Tracking Model Ranking |
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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, this is to confirm that all corrective action has been completed to the maximum extent practicable at NOAA Site 2/Two Party Agreement Site 2 on St. George Island in accordance with the Agreement.
DRO contaminated soil remains in the westernmost portion of the site only in the following locations: just north of and parallel to the City sewer system at depths of 8 feet bgs and deeper; at equipment refusal (due to bed rock) at a depth of 13 feet bgs; and at the bottom of the vadose zone (in areas of deeper bedrock) at 14 to 15 feet bgs.. Groundwater is contaminated with DRO, GRO and benzene in this area. |
Louis Howard |
| 1/2/2008 |
Update or Other Action |
Formal conditional closure request for NOAA Site 32/Non-Two Party Agreement Petroleum-Contaminated Soil Stockpile and Enhanced Thermal Conduction Operations Area.
Site 32 was used for stockpiling and treating PCS that had been excavated from various St. George Island sites (see information below on sites). Stockpiled PCS was isolated within an area that was surrounded by a berm and protected by a double-liner and sump system. Analytical results for closure assessment confirmation sampling indicate that the PCS stockpile containment, and properly executed ETC soil treatment operations, were largely successful in preventing the spread of contaminated soil outside of controlled areas. However, one location was found during assessment sampling to be contaminated with DRO in concentrations that approached the site closure requirements established by the CAP. Based on observations made during subsequent excavation of this hot spot, it is apparent that PCS was spilled and left outside the containment area at this location during stockpiling operations. The PCS
was removed and cleanup confirmation samples collected
The long-term stockpile is from several Two-Party Agreement UST/NON-UST sources which include, but not limited to: TPA 02 STG Former Drum Storage Area and TPA 03 Inactive Gas Station (oceanfront) (1624 cubic yards removed), TPA 10 STG Former Kerosene Drum/AST Storage Area, TPA 11 STG Cottage C UST (98 cubic yards removed), TPA 12 STG Former Hangar Building (195 cubic yards removed), TPA 21 Abandoned City Diesel Tank Disposal Site (1500 cubic yards removed), and TPA 23 Inactive/Abandoned Diesel Tank Farm (4,146 cubic yards removed.).
Contaminated soil was either treated or removed from Site 32 and the site meets CAP closure requirements for soil contaminant concentrations. Analytical results from the closure assessment and cleanup confirmation samples at Site 32 indicate that contaminant levels throughout Site 32 are well within the CAP closure requirements discussed below:
Cleanup Levels for Site 32 Closure-
GRO (a): 1,000 mg/kg, DRO (a) 2,000 mg/kg, RRO (a): 2,000 mg/kg, Benzene (b): 0.5 mg/kg (c), Toluene (b): 5.4 mg/kg, Ethylbenzene (b): 5.5 mg/kg, Total Xylenes (b): 78 mg/kg,
(a) As listed in 18 AAC 75.341, Method One, Table A1, Category D.
(b) As listed in 18 AAC 75.341, Method Two, Table B1, Under 40 Inch Zone, Migration to Groundwater.
(c) 1991 cleanup level for benzene which NOAA is allowed to use per Two Party Agreement requirements.
NOAA has completed the removal of PCS from Site 32 in compliance with the requirements of its closure and assessment plan. The cumulative cancer risk at Site 32 does not exceed 1 x 10-5, and the cumulative non-carcinogenic hazard index is below ADEC’s criterion of 1.0. Site 32 has been left graded, fertilized and seeded with native grasses. No further action is required at NOAA Site 32.
RECOMMENDATION-NOAA requests written confirmation from ADEC that all appropriate closure actions have been completed at NOAA Site 32 on St. George Island, Alaska, and that ADEC grants a conditional closure not requiring further action from NOAA. NOAA understands ADEC may require additional containment, investigation, or cleanup if subsequent information indicates that the level of contamination that remains does not protect human health, safety, or welfare, or the environment. |
Louis Howard |
| 3/25/2008 |
Update or Other Action |
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 |
| 8/5/2008 |
Institutional Control Record Established |
Notice of Environmental Cleanup and Residual Soil Contamination. Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation as the owner, and the U.S. Department of CommercelNational 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
This property, hereafter referred to as the Site, has been subject to petroleum contaminated soil and groundwater from a discharge or release and subsequent cleanup regulated under 18 AAC 75, Article 3 as amended December 2006. 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.
ADEC determined, in accordance with 18 AAC 75.325(f)(1), that the Site cleanup has been performed to the maximum extent practicable even though residual petroleum contaminated soil remained on the property (NOAA 2007). ADEC granted a conditional closure, in part subject to this institutional control (deed notice), and confirmed that no further remedial action was required at the Site unless new information becomes available that indicates to ADEC that the Site may pose an unacceptable risk to human health, safety, welfare or the environment (NOAA 2007).
Grantor: U.S. Bureau of Land Management
Grantee: St. George Tanaq Corporation, 4141 B Street, Suite 301, Anchorage, AK 99503
Recording District: Aleutian Islands |
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. 2/TPA Site No. 2, Former Drum Storage Area: drums, surface debris, contaminated soil, contaminated groundwater, UST/AST pipeline. Diesel range organics (DRO) contaminated soil remains in the westernmost portion of the site only in the following locations: just north of and parallel to the City sewer system at depths of 8 feet bgs and deeper; at equipment refusal (due to bed rock) at a depth of 13 feet bgs; and at the bottom of the vadose zone (in areas of deeper bedrock) at 14 to 15 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). |
Louis Howard |
| 4/29/2010 |
Update or Other Action |
Groundwater Monitoring report 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 TPA2-MW-1 and TPA2-MW-2 were installed to monitor the potential migration of diesel in groundwater beneath a former drum storage area at TPA Site 2. During the December 2009 sampling event, both wells were sampled for GRO, DRO, benzene, PCE, and RRO. No analyte concentrations exceeded ADEC cleanup levels. A statistical trend analysis was performed at both wells on DRO and GRO concentrations. The results of these analyses are presented in Table 4-2. DRO is trending down at TPA2-MW-1 and up at TPA2-MW-2. GRO concentrations are trending upward at both wells. No trends at TPA Site 2 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 |
| 2/10/2011 |
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.
Monitoring wells TPA2-MW-1 and TPA2-MW-2 were installed to monitor the potential
migration of diesel in groundwater beneath a former drum storage area at TPA Site 2. During the
June 2010 sampling event, both wells were sampled for GRO, DRO, benzene, PCE, and RRO.
DRO concentrations at both wells concentrations exceeded ADEC cleanup levels.
A statistical trend analysis was performed at both wells on DRO and GRO concentrations. GRO is trending upward at TPA2-MW-1 and downward at TPA2-MW-2. DRO concentrations are trending upward at both wells. No trends at TPA Site 2 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 |
| 4/4/2011 |
Update or Other Action |
Annual Groundwater monitoring report received. 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. Only hydrocarbon analytes were detected at the Former Drum Storage Area TPA Site 2 and
the School underground storage tank (UST) TPA Site 22-1.
Monitoring wells TPA2-MW-1 and TPA2-MW-2 were installed to monitor the potential migration of diesel in groundwater beneath a former drum storage area at TPA Site 2. During the November 2010 sampling event, both wells were sampled for GRO, DRO, benzene, PCE, and RRO. The DRO concentration at TPA2-MW-1 exceeded the ADEC cleanup level and GRO was detected above the MRL. All analytes were below the MRL for monitoring well TPA2-MW-2.
A statistical trend analysis was performed at both wells for DRO and GRO concentrations. Both the GRO and DRO concentrations were trending upward at TPA2-MW-1 and both analyte concentrations were trending downward at TPA2-MW-2. Not one of the trends at TPA Site 2 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 |
| 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 TPA2-MW-1 and TPA2-MW-2 were installed to monitor the potential migration of
diesel in groundwater beneath a former drum storage area at TPA Site 2. During the 2012 sampling
events, both wells were sampled for GRO, DRO, and RRO. Contaminant concentrations were all below
ADEC cleanup levels. A statistical trend analysis was performed for both wells for DRO and GRO concentrations. The results of the trend analyses indicate that both the GRO and DRO oncentrations were trending upward at Well TPA2-MW-1 and both analyte concentrations were trending downward at Well TPA2-MW-2. None of the trends at TPA Site 2 are significant at a < 0.05 and therefore do not meet the minimum confidence level to be considered statistically valid.
|
Louis Howard |
| 6/11/2019 |
Document, Report, or Work plan Review - other |
Staff approved a Request for Decommissioning of Groundwater Monitoring Wells on St. George, AK with the exception of TPA2-MW-1, TPA 2-MW-2, TPA1-MW-2 and TPA1-MW-3. These four wells will be tested for BTEX, DRO, Petroleum VOCs and PAHs. Land use controls for groundwater may be reviewed in five years and if the groundwater data remains below applicable cleanup levels, these controls will be removed. |
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. 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 |
Document, Report, or Work plan Review - other |
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 |
