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Site Report: AKARNG Kotlik FSA

Site Name: AKARNG Kotlik FSA
Address: Unnamed Road, near Post Office, Kotlik, AK 99620
File Number: 2423.38.001
Hazard ID: 2822
Status: Active
Staff: Danielle Duncan, 9074655207
Latitude: 63.032807
Longitude: -163.556473
Horizontal Datum:WGS84

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.


Petroleum contamination in soil. Site Investigation Report prepared by CH2MHill dated June 1996, received by ADEC 7/29/1997. Diesel range organics (DRO) detected at 2,050 and 2,660 mg/kg in shallow soil borings. BTEX detected in shallow soil at 21.5 mg/kg. Matrix Score Sheet indicated Level D site. Area subject to flooding. (All of Lots 1 and 2, Block 6 of Tract B, U.S. Survey 4497, being within the Kotlik Townsite.) As of December 2016, all of the petroleum contaminated soil that had concentrations greater than the approved alternative cleanup levels has been removed from the site. Surface water meets Division of Water regulations. Groundwater on site is contaminated with DRO and is undergoing 5 year long term monitoring.

Action Information

Action Date Action Description DEC Staff
9/24/1997 Site Added to Database Petroleum contamination. Scott Pexton
9/24/1997 Site Ranked Using the AHRM Site ranked by staff. Scott Pexton
8/18/1998 Site Characterization Workplan Approved Letter sent with approval of Site Sampling Plan, prepared by Hart Crowser, Inc. Scott Pexton
1/25/1999 Update or Other Action Received Draft Remedial Investigation Report. Scott Pexton
1/26/1999 Update or Other Action Letter sent with comments on draft remedial investigation report. Scott Pexton
4/30/1999 Update or Other Action Received Final Remedial Investigation Report, prepared by Hart Crowser, Inc. Scott Pexton
10/15/1999 Site Ranked Using the AHRM Site reranked based on information provided in 1999 Final Remedial Investigation report. Scott Pexton
11/5/2001 Site Characterization Report Approved Letter sent to Norm Straub of the Alaska Army National Guard with approval of April 1999 site characterization report prepared by Hart Crowser with following conditions: (1) ADEC does not approve the proposed cleanup levels presented in Section 4.4.3 of the April 1999 Final Remediation Investigation report; (2) soil cleanup levels provided under method one and method two apply at a contaminated site unless the department approves an alternative cleanup level that the responsible person has proposed under method three or method four (18 AAC 75.340 (d)); (3) ADEC concurs with the report evaluation that indicated a remedial action to excavate, treat, and properly dispose contaminated soil at the site may be effective. DEC requested that the Alaska Army National Guard submit a cleanup plan for the Kotlik Federal Scout Armory site by December 31, 2001. Scott Pexton
4/8/2004 Update or Other Action File number assigned: 2423.38.001. Sarah Cunningham
6/2/2004 Update or Other Action ADEC received Final Interim Removal Action Plan. Beatrice Egbejimba
6/2/2004 Update or Other Action ADEC received draft Alternate Cleanup level Demonstration Project. Beatrice Egbejimba
7/2/2004 Update or Other Action DEC issued a letter stating the following: DEC has completed review of the document titled: Final Interim Removal Action Plan, Federal Scout Armory, Kotlik, Alaska dated March 2004 and offers the following comments. DEC concurs with the general approach of the plan however, can not provide approval to the plan as written. The plan provides a general approach for the excavation, and handling of impacted petroleum contaminated soil but lacks site specific detail for DEC approval under 18 AAC 75. DEC understands that the AKARNG is performing this action to reduce risk to human health and the environment under 18 AAC 75.330, to provide for a partial cleanup at the site and not achieve cleanup levels. It is presumed that information gathered during this interim action will provide data to be used in determining any future actions required for site clean up. In conclusion, DEC has no objection to the interim removal approach provided and will defer any further regulatory decisions until review of the data collected from the site work. David Pikul
2/4/2005 Update or Other Action Staff reviewed the July 2004 final workplan that was recieved Oct 04 for the Alternate Cleanup Level Project. The work plan in general meets requirements. Debra Caillouet
2/18/2005 Update or Other Action A letter was sent to the AKANG providing conditional approval of the workplan. Debra Caillouet
6/2/2005 Update or Other Action Staff reviewed the Installation Action Plan and sent the following comment. I have reviewed the plan which contains a summary of the actions to date and proposed cleanup strategy. The summary of the actions fairly depicts the results of the Site Investigation (SI) in 1995 and a Remedial Investigation (RI) in 1998. The RI identified one area on the north side of the armory building as having up to 24,000 mg/kg. Diesel Range Organics (DRO) in surface soil. The Alaska Department of Environmental Conservation (DEC) approved an Interim Removal Action (IRA) Workplan in July 2004. The work is expected to occur in the spring of 2005. An Alternative Cleanup Level (ACL) Demonstration report is currently pending for the site. The Cleanup Strategy that is proposed states that the residual DRO remaining after the IRA is localized. This conclusion cannot be supported if the IRA has not occurred as stated earlier in the IAP. The rest of the strategy includes a no further action determination based on the IRA and the ACL development or if that cannot be supported long term monitoring and five year reviews. DEC cannot concur with the cleanup strategy until the results of the IRA and the ACL development are available. After these are reviewed, DEC would like to work with the Alaska Army National Guard to determine the best course of action to achieve protection of human health and the environment at the Kotlik Federal Scout Armory. Debra Caillouet
10/11/2005 Update or Other Action Staff prepared a comment letter on the draft ACL demonstration report. Debra Caillouet
3/18/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Debra Caillouet
5/5/2008 Interim Removal Action Approved The final report for the Interim Removal Action at Kotlik documents the removal and off-site treatment of 11 cubic yards of petroleum contaminated soil from two areas at the site. Confirmation sampling from the limits of the excavations showed diesel range organics (DRO) remaining in Area 1 up to 1120 mg/kg adjacent to the fuel tank. Area 2 is associated with the former day tank on the north side of the building. Confirmation sampling at the limits of the excavation showed DRO remaining up to 7560 mg/kg. The contamination remaining exists next to the building or AST and could not be removed without endangering the structural integrity of the structures. The report demonstrates that the action meets the requirements of 18 AAC 75.330, Interim Removal Actions. Debra Caillouet
1/23/2009 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73798 name: Spills/Leaks Debra Caillouet
9/18/2009 Report or Workplan Review - Other Staff reviewed a letter report on one sample and prepared a letter to the Guard discussing how to proceed with the cleanup. Debra Caillouet
2/3/2010 Meeting or Teleconference Held Meeting or teleconference, by me, 2/3/10 Staff participated in the Installation Action Plan meeting. Debra Caillouet
11/30/2010 Report or Workplan Review - Other Staff reviewed and sent comment to the Alaska Army National Guard on the Draft Work Plan for Site Characterization at 21 Alaska Federal Scout Readiness Centers, November 2010, including the Site Specific Plans for Akiak, St. Mary’s and Tuntutuliak. Debra Caillouet
5/23/2011 Site Characterization Workplan Approved Final Work Plan for Site Characterization at 21 Alaska Federal Scout Readiness Centers, April 2011 approved. Debra Caillouet
9/10/2013 Site Characterization Report Approved Kotlik Federal Scout Readiness Center Data Gap Investigation Report, Fina lAugust 2013. The report recommends cleanup levels of 1,221 mg/kg for GRO,11,793 mg/kg for DRO, and 0.165 mg/kg for benzene based on the default aromatic and aliphatic cleanup levels from 18 AAC 75.341 Table B2 for the ingestion and inhalation pathways. ADEC has no objection to the use of these cleanup levels. Confirmation sampling will be necessary to show all levels, (total DRO by AK102, DRO Aromatic, DRO Aliphatic, total GRO by AK101, GRO Aromatic, GRO Aliphatic and benzene) are met. Debra Caillouet
12/19/2014 Cleanup Level(s) Approved Record of Decision signed today. Debra Caillouet
12/17/2015 Update or Other Action Staff changed to Danielle Duncan and hard file transferred to the Juneau office. Kristin Thompson
12/23/2015 Update or Other Action The site is being remediated this summer including groundwater monitoring- work plan is coming. Danielle Duncan
3/1/2016 Report or Workplan Review - Other Rec'd the draft remedial action plan and long-term monitoring for the site this date. Danielle Duncan
5/17/2016 Report or Workplan Review - Other Rec'd the Final Kotlik Remedial Action Plan this date. Danielle Duncan
6/6/2016 Update or Other Action Approved the Final Kotlik Remedial Action Plan this date. The responses to my comments were acceptable. The final remedial action plan and long-term monitoring plan (RAP) describes the excavation of petroleum contaminated soil, installation of 4 groundwater monitoring wells, and surface water sampling. The groundwater and surface water will be sampled over a period of 5 years. Danielle Duncan
12/19/2016 Update or Other Action Reviewed the Draft Remedial Action and Long Term Monitoring Report this date and sent grammatical comments - no other issues were found with the draft report and I anticipate reviewing a final report soon. The groundwater monitoring wells will have to be re-drilled yearly due to permafrost. Danielle Duncan
12/19/2016 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 73798 Spills/Leaks. Danielle Duncan
2/13/2017 Report or Workplan Review - Other Approved the remedial action and long-term monitoring report this date. Four excavations occurred on site and now soil on site meets the cleanup levels approved in the Record of Decision. Groundwater on site is affected by petroleum, but surface water appears not to be. Long-term water monitoring will continue for 4 more years. Danielle Duncan
12/28/2017 Report or Workplan Review - Other Approved the long-term monitoring report this date. Four temporary groundwater monitoring wells were installed and sampled in September 2017: MW1, MW2, MW3, MW4. The samples were analyzed for DRO and benzene. Benzene concentrations were below detection limits for all four wells. MW1 had a DRO concentration (0.26 mg/L) below the cleanup level. MW2 also had a DRO concentration (0.20 mg/L) below the cleanup level; it had a DRO concentration of 4.1 mg/L last year. MW3 was non-detect for DRO while last year it had a DRO concentration of 0.49 mg/L. MW4 had a DRO concentration greater than the cleanup level at 4.6 mg/L. Two surface water samples were collected and analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX) and polycyclic aromatic hydrocarbons (PAHs) to calculate TAH and TAqH; the results were below the cleanup levels. Danielle Duncan

Contaminant Information

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