Site Report: Togiak Fisheries

Site Name:	Togiak Fisheries
Address:	Togiak Bay, Togiak, AK 99678
File Number:	2658.38.001
Hazard ID:	322
Status:	Cleanup Complete - Institutional Controls
Staff:	IC Unit, 9074655229 dec.icunit@alaska.gov
Latitude:	59.054589
Longitude:	-160.334888
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.

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

Surface and subsurface gasoline and diesel releases in excess of 35,000 gallons took place during the 1980’s at the Togiak Fisheries site and continued until late 1987, when ADEC and the U.S. Coast Guard investigated and confirmed complaints of ongoing releases. Togiak Fisheries signed a Compliance Order by Consent with the State of Alaska on 1/20/1988 that outlined ADEC requirements for site cleanup, monitoring, and reporting. Contaminant sources included releases from subsurface gasoline and diesel pipelines; drums of waste oil; and mixtures of water and petroleum products stored at the site. The fuel spills contaminated the groundwater and to an unknown extent, the shoreline and waters of Togiak Bay, with a sheen observed on the waters of adjacent Togiak Bay and the Togiak River estuary and 300 feet of shoreline visibly impacted by fuel. Site investigation during late 1987 and early 1988 documented the presence of a large amount of fuel on the water table at the site. After signing the compliance order Togiak Fisheries contracted with RZA Inc. to evaluate the extent of the contamination and begin spill remediation. Criminal charges were filed against the plant manager and the corporation for knowingly not reporting petroleum spills. In the fall of 1988 an out-of-court settlement was made on civil and criminal penalty for $185,000. The total volume of product collected from recovery wells at the site was approximately 8,300 gallons during the year the recovery system operated. In 1996 Togiak Fisheries, Inc. merged to become North Pacific Processors, Inc., and in 2005 changed its name to North Pacific Seafood, Inc.(NPSI). 1996 Togiak Fisheries, Inc. merged to become North Pacific Processors, Inc., and in 2005 changed its name to North Pacific Seafood, Inc.(NPSI).

Action Information

Action Date	Action	Description	DEC Staff
11/23/1987	Site Added to Database	Gasoline and diesel spills impacted soil, groundwater and adjacent beach and marine environment.	Mike Lewis
12/2/1987	Update or Other Action	Site visit - ADEC staff visited site to collect samples and identify spill areas.	Mike Lewis
1/5/1988	Update or Other Action	Fuel saturated soils identified on-site. ADEC investigations indicate a large amount of gasoline/diesel fuel on the groundwater.	Mike Lewis
1/12/1988	Site Visit	Site visit by ADEC - staff collected two soil samples and two water samples. One water sample was taken below ice by the dock and the second was from the winter watchman's house well--a hand-dug pit well-- where the depth to water was approximately 12 feet. No petroleum odor was observed in either water sample. Both soil samples appeared to be maximally saturated by fuel.	Mike Lewis
1/20/1988	Update or Other Action	Compliance Order by Consent (COBC) between Togiak Fisheries and the State of Alaska signed. The COBC outlines speficic tasks which Togiak Fisheries must perform and a schedule of deadlines which must be met to avoid penalties. Actions required included remedial action to contain fuel spills and to prevent aditional contamination of land or continued migration of fuel contamination into water. (Mike Lewis was project manager at time of COBC issuance).	Mike Lewis
1/29/1988	Update or Other Action	ADEC amended the deadlines in the compliance order (see 1/20/1988 entry)in a letter of this date.	Mike Lewis
3/4/1988	Update or Other Action	Report "Subsurface Exploration and Groundwater Monitoring Petroleum Recovery Operations, Togiak, Alaska, February 1988" submitted by consultant RZA with cover letter to Togiak Fisheries dated 3/4/1988. Date stamp on document is July 22, 1988. The report documents the following: 11 borings that were completed as four 2-inch diam. monitoring wells and seven 5-inch diam. recovery wells; installation and operation of a free product recovery system; free-product was encountered in 4 wells during periods of low tide; initiation of free product recovery began on Feb. 13, 1988;subsurface soils generally consist of gravelly fine- to coarse-grained sand, or mixed sand and gravels, all of fairly high permeability; depth to groundwater ranged from 4-10 feet below ground surface; and by March 4,1988 over 200 gallons of fuel had been recovered. (Input to db 2008).	Closed
3/17/1988	Document, Report, or Work plan Review - other	ADEC review letter of consultant RZA's report "Subsurface Exploration and Groundwater Monitoring Petroleum Recovery Operations, Togiak, Alaska, February 1988." Recovery operations were found to be marginally adequate, and comments by ADEC included the need for further investigation of the site; the need to increase product recovery from the groundwater as soon as weather permits; insufficient processing of water separated from floating product that has been discharged on the ground, and requirements for testing the water or reinjecting it into the ground; and a request for details on actions to be taken to check fuel system components and whether components of the entire system will be replaced. The letter also reiterates the need for a response regarding items requested in ADEC's Feb. 2, 1988 letter that were not addressed.	S&W
3/28/1988	Update or Other Action	Received plan. Cover letter from RZA to Togiak Fisheries dated March 28, 1988 accompanies "Site Remediation Plan: Remedial Action Plans for Fuel Recovery Operations at Togiak Fisheries, Inc." The plan proposes installing 8 6-inch diameter recovery wells, with 4 wells to be placed in the area of the main processing complex (northern end of spit) and 4 wells to surround the waste oil drum storage area approximately 1000 feet south of the main complex. The plan also includes a combination free product recovery system using a scavenger floating oil skimmer, a trench system, groundwater reinjection gallery, and venting system, and sampling and appropriately disposing of or handling all drums in the drum storage area. (Action Input 2008)	S&W
5/1/1988	Interim Removal Action Approved	Crowley Environmental and RZA retained by TFI; Crowley to direct petroleum recovery; RZA documents subsurface and groundwater monitoring.	Mike Lewis
6/1/1988	Update or Other Action	Additional product recovery wells installed; operated in 1988 winter with difficulty. Site Treatment, Soil/H2O	Mike Lewis
6/2/1988	Update or Other Action	Soil venting system installed; operated year round. Site Treatment, Soil/H2O.	Mike Lewis
7/14/1988	Update or Other Action	Incinerator installed for disposing of waste fuel; some recovered gasoline was mixed with new gasoline and burned in engines.	Mike Lewis
7/15/1988	Update or Other Action	Permit Action at Site: Incinerator ash disposal; permit #8821-BA011.	Mike Lewis
4/24/1989	Update or Other Action	Chempro, formerly Crowley Environmental, completed on-site evaluation and repair of facility after first winter of operation	Mike Lewis
6/20/1989	Update or Other Action	Recovery wells restarted for season. Site Treatment, Soil/H2O.	Mike Lewis
6/20/1989	Update or Other Action	Recovery wells restarted for season. Site Treatment, Soil/H2O.	Mike Lewis
9/27/1989	Update or Other Action	Field Inspection. RZA updated review of petroleum recovery efforts; equipment damage from saline groundwater and winter conditions; portion of VE system flooded or frozen. Winter operation of recovery wells not recommended. VE system recovery increased when area beneath dock thawed.	Mike Lewis
12/5/1989	Update or Other Action	TFI has shut down and winterized recovery wells. Product recovered to date is 8,307 gallons. VE system reported at 35 to 40% LEL during first year of operation. Decreased to 15% LEL during second summer of operation; decreased to 2% LEL during the following winter. Site Treatment, Soil/H2O.	Mike Lewis
2/1/1990	Update or Other Action	Letter from Fryer/Pressley Engineering, Inc., contracted to ADEC, reporting on deficiencies of Togiak Fisheries fuel storage and piping system based on a review of a video of the system provided by ADEC.	S&W
3/2/1990	Site Number Identifier Changed	Also includes old Reckey 1988210901901.	Mike Lewis
5/22/1990	Update or Other Action	Recovery wells reactivated; trace amount of product recovered; VE system increased to 3% LEL from winter 2% LEL.	Mike Lewis
8/14/1990	Update or Other Action	Follow-up work is being done to conform with the ADEC Compliance Order. On site fuel system being brought up to code. Further site investigation planned by RZA to delineate boundary of "zero" contamination. VE system continues to run at 2 to 4% LEL.	Mike Lewis
10/8/1990	Document, Report, or Work plan Review - other	ADEC letter approving plan to replace fuel tank farm in accordance with the COBC (see 1/20/1988 entry). Letter responds to Togiak Fisheries letter providing status of product recovery system and notification that fire marshall approved plan for new tank farm.	S&W
12/4/1990	Site Ranked Using the AHRM	Initial ranking.	Mike Lewis
6/4/1991	Update or Other Action	Progress report sent in on cleanup and monitoring as required by compliance order 88-2-1-1-019-1. Monitoring wells show no accumulation of product. Vapor extraction system continues to operate, but lower explosive level is very minimal. Last of 6 diked tanks installed and in process of hooking up piping.	Mike Lewis
8/9/1991	Site Number Identifier Changed	Changed workplan from 21 to 25.	Mike Lewis
9/3/1991	Update or Other Action	Date of "Field Report and Sampling Results" report by PTI Environmental--stamped rec'd April 19, 2001 by ADEC. Report contents are referenced in August 2000 consultant Brady Environmental report with note that the report was not in the file so Brady did not review it). PTI concluded that the extent of subsurface contamination was similar to what was found in 1988, with the exception of the free-floating hydrocarbons,with the number of wells with occurrences of floating hydrocarbons on the water table decreasing from five in June 1989 to one in June 1991. PTI and RZA concluded that there was one large plume that covered most of the site.	S&W-Miner
12/28/1994	Update or Other Action	COBC (see 1/20/1988 entry re COBC) required inspection every two months but last report was February 1990. Vapor extraction at 2%.	Ray Dronenburg
4/20/2000	Meeting or Teleconference Held	Met with Pat Brady of Brownsfield Development, LLC at ADEC offices in Anchorage to review file and discuss site characterization and cleanup issues.	Scott Pexton
2/5/2001	Meeting or Teleconference Held	Teleconference held with Jim Kudwa and Jeff Backlund of North Pacific Processors, Inc., Pat Brady of Brady Environmental, LLC, and Chuck Blumenfeld of Perkins, Coie to discuss site characterization and cleanup issues. North Pacific Processors, Inc. indicate interest in having Brady Environmental, LLC oversee interim removal actions and additional site characterization activities during spring/summer of 2001.	Scott Pexton
2/7/2001	Update or Other Action	Report received: "Togiak Fisheries Soil and Groundwater Investigation report, August 2000" prepared by Brady Environmental, LLC.	Scott Pexton
2/26/2001	Document, Report, or Work plan Review - other	Letter sent to Pat Brady with comments on investigation report.	Scott Pexton
3/13/2001	Update or Other Action	Received and reviewed liner specification sheet faxed to CSRP by Pat Brady. Telephoned Pat Brady and verbally approved the proposed woven HDPE polyolefin fabrix with LDPE coatings for use as a short-term liner for petroleum-contaminated soil.	Scott Pexton
3/14/2001	Update or Other Action	Received Togiak Fisheries Interim Remedial Action Measure Plan, prepared by Brady Environmental, LLC for North Pacific Processors, Inc.	Scott Pexton
3/30/2001	Cleanup Level(s) Approved	ADEC approved Method 1 Category B cleanup levels of 100 mg/kg, 200 mg/kg, and 2000 mg/kg for GRO, DRO, and RRO respectively that were proposed in the interim removal action work plan by Brady Environmental, LLC.	Scott Pexton
3/30/2001	Interim Removal Action Approved	Letter sent to Pat Brady of Brady Environmental, LLC with conditional approval of the interim removal work plan. The letter also provided ADEC approval of a site-specific operations plan for a portable thermal treatment facility.	Scott Pexton
4/19/2001	Update or Other Action	Received plan "Togiak Fisheries Supplemental Site Characterization Work Plan, Togiak, Alaska . . . April 11, 2001" prepared by Brady Environmental, LLC.	Scott Pexton
4/30/2001	Site Characterization Workplan Approved	Letter sent to Pat Brady with approval of Site Characterization work plan received 4/19/2001.	Scott Pexton
7/19/2001	Update or Other Action	Received copy of letter from Brady Environmental, LLC to the ADEC Solid Waste program regarding application for a general permit for a one-time disposal of construction and demolition waste.	Scott Pexton
7/25/2001	Update or Other Action	Letter signed by acting CSRP Program Manager and sent to Jim Kudwa of North Pacific Processors, Inc. that effectively terminates compliance order by consent 88-2-1-1-019-1.	S&W
8/3/2001	Update or Other Action	Received two reports prepared by GANCO Environmental Construction, Inc. titled "Togiak Fisheries Third Party Sampling Report for Sampling Conducted on June 19, 2001" and "Togiak Fisheries Third Party Sampling Report for Sampling Conducted on July 16, 2001." Results indicated concentrations of GRO/DRO/RRO in all confirmation samples were non-detect.	Scott Pexton
8/6/2001	Site Visit	Site visit to Togiak Fisheries on Monday and Tuesday to view progress with interim removal action and site characterization.	Scott Pexton
8/14/2001	Update or Other Action	Received copy of General Permit Number 9940-BA003 for the operation and maintenance of a monofill for the one-time disposal of construction/demolition debris at the Togiak Fisheries site.	Scott Pexton
8/27/2001	Update or Other Action	Received fax copies of confirmation sample analytical results for samples collected by Platt Environmental. Two batches of samples were collected by Platt Environmental, one on 8/3/2001 and another on 8/18/2001. Results indicate that all samples collected met Category B, Method 1 cleanup levels for GRO/BTEX and RRO. However, ten samples collected 8/3/2001 did not meet the Category B, Method 1 cleanup level for DRO of 200 mg/kg (sample concentrations ranged from 237 to 348 mg/kg with Method AK102). Therefore, the treated soil was processed through the treatment system again; results of confirmation samples collected by Platt Environmental 8/18/2001 indicated that all confirmation samples met Category B, Method 1 cleanup levels for GRO/BTEX and DRO/RRO.	Scott Pexton
1/29/2002	Update or Other Action	ADEC received "Togiak Fisheries Supplemental Site Characterization Report" and "Togiak Fisheries Interim Remedial Actions Measures, Summer 2001 Status Report" both prepared by Brady Environmental, LLC.	Scott Pexton
2/13/2002	Meeting or Teleconference Held	Meeting held at ADEC offices in Anchorage with Scott Pexton and Markus Niebanck, an agent representing Firemans Fund Insurance to discuss site history and status of site cleanup.	Scott Pexton
3/7/2002	Update or Other Action	ADEC received a Togiak Fisheries Offsite Soil Treatment Facility Operations Plan, prepared by Brady Environmental, LLC. The plan outlines plans to modify the existing soil treatment facility to meet requirements for an offsite soil treatment facility. Also accompanying the plan was a letter report with figures dated March 1, 2002 with subject line "Review Statement, Togiak Fisheries Offsite Soil Treatment Facility Operations Plan."	Scott Pexton
3/27/2002	Site Characterization Report Approved	ADEC letter to Pat Brady (copy to Jim Kudwa of North Pacific Processors) with approval of site characterization report in accordance with 18 AAC 75.335 (d). Requested submittal of an additional set of figures (similar to Figure 2) as an addendum to the Supplemental Site Characterization Report. The figures should depict: all monitoring or recovery wells found during 2001, including the wells that were sampled; the extent of groundwater contamination by delineating GRO, DRO, and BTEX compound concentration isopleths based on 2001 groundwater sampling results; and the groundwater flow direction(s) based on the measured water elevations levels in wells.	Scott Pexton
3/28/2002	Update or Other Action	ADEC letter to consultant Brady (copy to RP representative Jim Kudwa) that (1) approved interim removal action report; (2) requested submittal of an additional figure as an addendum to the Interim Removal Action Measures Status Report showing much additional information including the locations where the 2001 excavation confirmation sample results exceeded the approved method one soil cleanup levels; (3) noted that while the report included the fact that DEC approved the use of method one Category B soil cleanup levels for GRO, DRO, and RRO at the site, many of the excavation confirmation soil samples exceeded the target method one cleanup levels for GRO or DRO and this was not addressed; and (4) requested a cleanup plan by May 15, 2002. ADEC stated that the cleanup plan is to include a soil confirmation sampling and analysis plan; a groundwater monitoring proposal to evaluate concentration trends; a schedule for conducting fieldwork, monitoring; and submittal of a final cleanup report.	Scott Pexton
4/8/2002	Update or Other Action	Email message with letter attachment sent from Paul Horwath to Pat Brady with comments on Operations Plan for offsite soil treatment facility.	Scott Pexton
4/22/2002	Update or Other Action	Received 2 letter reports, both dated April 16, 2002 from Brady Environmental LLC with responses to ADEC requests for addition information pertaining to the interim removal action report (see information request described in 3/27/2002 ADEC letter entry) and the site characterization report (see information request described in 3/28/2002 ADEC letter entry). The letter report with subject line "Request for Additional Information, Site Characterization Report . . ." includes GRO, benzene and DRO groundwater contaminant distribution shown as isopleths. The letter report with subject line "Request for Additional Information, Interim Removal Action Report" provides figures showing the location of soil samples that exceeded approved cleanuplevels and shows proposed excavation areas, with hatched areas showing areas believed to exceed applicable cleanup levels.	Scott Pexton
5/13/2002	Update or Other Action	"Revised Togiak Fisheries Off-Site Soil Treatment Facility Operations Plan" with cover letter addressed to Paul Horwath, PE, ADEC Soldotna Office, dated May 10, 2002, was received by the Soldotna Office on 5/13/2002.	Eileen Olson
5/13/2002	Meeting or Teleconference Held	Met at ADEC offices with Pat Brady and Elizabeth Stergiou. Pat submitted the offsite soil treatment facility Operations Plan and indicated it had been revised to address ADEC comments provided by Paul Horwath. Pat indicated that he had prepared a draft cleanup plan but wanted to submit it later in the week. He indicated that Pacific Processors, Inc. was negotiating some cleanup issues with an insurer and wanted to delay submittal of the cleanup plan. It was suggested that the draft plan be submitted with a request to delay for ADEC review of the draft plan until a later date.	Scott Pexton
5/17/2002	Meeting or Teleconference Held	Meeting at ADEC offices in Anchorage with Pat Brady and Charles Blumenfeld of Perkins Coie LLP, an attorney representing Pacific Processors, Inc. Cleanup issues were discussed and Mr. Blumenfeld indicated that alternative cleanup level proposals may be submitted at a later date and that additional site-specific information would be gathered this field season to support an ACL proposal. He also indicated that they would submit an interim removal action plan (18 AAC 75.330) instead of a cleanup plan under 18 AAC 75.360. He indicated that a letter would be sent to ADEC within a week which would describe their plans more fully.	Scott Pexton
5/28/2002	Update or Other Action	Received faxed letter from Charles Blumenfeld of Perkins Coie LLP, an attorney representing North Pacific Processors, Inc., indicating that Togiak Fisheries, Inc. would submit an interim action plan for summer 2002 work instead of a Cleanup Plan. The letter indicated that Togiak Fisheries believes the interim measures would allow continued progress and provide additional data needed to propose a final cleanup plan.	Scott Pexton
6/7/2002	Update or Other Action	Letter sent to Chuck Blumenfeld of Perkins Coie LLP, an attorney representing North Pacific Processors, Inc., with a request for an interim removal action plan. The request was for submittal of a plan to describe work to be performed during the summer of 2002 that would focus on removing contaminated material that comes in contact with surface water and to provide further characterization data needed to prepare a cleanup plan.	Scott Pexton
6/10/2002	Update or Other Action	Received 2 plans: "Togiak Fisheries Interim Remedial Actions Measures Plan Summer 2002" prepared by Brady Environmental, LLC. Also, received "Togiak FIsheries Evaporative Disorption Remediation Sampling and Analysis Plan . . . June 7, 2002" for post treatment sampling at the Togiak Fisheries Soil Treatment Facility. The plan was prepared by Platt Environmental for Brady Environmental LLC.	Scott Pexton
6/20/2002	Interim Removal Action Approved	Letter sent to Brady Environmental LLC with conditional approval of Interim Removal Action Work Plan.	Elizabeth Stergiou
7/8/2002	Update or Other Action	Received letter from North Pacific Processors, Inc. stating that North Pacific Processors, Inc. will be unable to perform the Interim Remedial Action Measures this summer. The letter indicated they will not be able to fund response actions at the Togiak site until either an insurance company is forced by the court to make good on its obligations or until the end of the current fishing season when they hope to have revenues in excess of expenses.	Scott Pexton
8/12/2002	Update or Other Action	Letter sent to Jim Kudwa of North Pacific Processors, Inc. requesting additional information to describe the schedule for implementing the ADEC approved interim removal action plan. The letter also provided notification of a change in ADEC project manager from Scott Pexton to Elizabeth Stergiou.	Scott Pexton
11/7/2002	Meeting or Teleconference Held	Met with NPP representatives Rusty Roessler, Plant Manager and Jeff Backlund, Corporate Quality Control Manager, and NPP's attorney Chuck Blumenfeld. Scott Pexton and Elizabeth Stergiou represented ADEC at the meeting. NPP submitted the requested sampling documentation from the sampling event conducted by Fireman's Insurance and a report Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc Site. NPP proposed going to a risk assessment approach prior to further removal actions. ADEC encouraged NPP to continue with the previously approved interim removal action due to the presence of free product and contamination along Togiak Bay. ADEC will review the submitted report and offer comments. ADEC and NPP is planning to schedule a risk assessment scoping meeting for early 2003. NPP would like to conduct the risk assessment during 2003.	Elizabeth Stergiou
11/21/2002	Update or Other Action	Report received during meeting of same date: "Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc Site . . . November 1, 2002."	Elizabeth Stergiou
11/22/2002	Update or Other Action	ADEC received qualifications information re MCS Environmental from attorney for NPPI.	Elizabeth Stergiou
12/19/2002	Update or Other Action	Staff reviewed the October 30, 2002 report entitled Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc (NPPI) Site. The report recommends pursuing a risk assessment, in lieu of additional contaminated soil removal, due to the shallow depth to groundwater, the strong tidal influences and the fluctuating direction of groundwater flow. The Department does not agree with the report’s suggestion that the subject site is at the stage in the ADEC cleanup process where a risk assessment is appropriate and requests NPPI conducts additional soil removal and treatment in accordance with the conditionally approved Interim Removal Action Work Plan . NPPI has demonstrated that they can excavate the contaminated soil and successfully treat it at the Togiak Fisheries site. Additional site characterization is recommended. The subject report states that sampling to date has not established whether the depth of contamination (3-6 feet) is fully delineated. The depth of contamination (especially under the dock area) has not been fully characterized. The Department requests the remaining stockpiled soil on site be treated during field season 2003. Approximately 2,500 cubic yards of petroleum contaminated soil is stockpiled on site in a long-term storage cell. The cell was completed and filled in 2000 and the contaminated soils with in it will need to be treated during this upcoming field season. It is recommended NPPI explore the 18 AAC 75.341(e) for guidance on using site specific parameters to propose an alternative cleanup level under method three at that time.	Elizabeth Stergiou
1/28/2003	Meeting or Teleconference Held	The attendees were Rusty Roessler – NPPI Plant Manager, Jeff Backlund - NPPI Corporate Quality Control Manager, Robert Torres – NPPI General Manager, Pat Brady - Brady Environmental and Chuck Blumenfeld – Perkins Coie LLP. Togiak Fisheries will conduct the previously approved interim removal action during field season 2003, treat the remaining soil from the 2001 excavation, and conduct sampling for possible alternative cleanup levels. We discussed the surface water quality issue, as there is documented impact to the surface water of Togiak Bay. 2002 water sample results were 9.10 mg/L GRO, 3.71 mg/L DRO and 0.0399 mg/L benzene. Also discussed was the need for future surface water and groundwater monitoring, points of compliance for surface water contamination and the cleanup process from the point of the interim cleanup action. Mr. Brady proposed excavating the soils and sediments from the area most likely impacting surface water and treating it to a to be determined Method Three level, and depositing it in the area to be covered by the alternative cleanup level. Mr. Brady also proposed evaluating the site for a possible groundwater use determination under 18AAC75.350 given the tidal influence on the present monitoring wells on site. Mr. Blumenfeld voiced concern for an end point. ADEC presented the cleanup process and that the interim cleanup action may be counted as the cleanup action depending on the extent of contamination present after the action, remaining threat to surface water, and the alternative cleanup levels established. Also presented was the need for long term monitoring for surface and groundwater. If a NFRAP was granted the long term monitoring would be a component of the NFRAP and the site status may change at any time dependent on the threat to surface water.	Elizabeth Stergiou
2/18/2003	Update or Other Action	Rec'd "Togiak Fisheries Offsite Soil Treatment Facility - Soil containment Structure Construction Report and As-Built Documentation, September 2002". Report was submitted to Soldotna ADEC for engineering review.	Eileen Olson
3/3/2003	Update or Other Action	Soldotna office received "Togiak Fisheries Offsite Soil Treatment Facility Operations Plan" with cover letter by consultant to ADEC dated 2/18/2003.	Eileen Olson
3/14/2003	Update or Other Action	Rec'd "Addendum to 2002 Interim Remedial Action Measure Plan" dated March 12, 2003	Eileen Olson
3/25/2003	Update or Other Action	Reviewed the Addendum to the 2002 Interim Remedial Action Measure Plan. The original plan proposed excavation of contaminated soil in areas most likely to impact the adjacent surface water, was approved by ADEC on June 20, 2002. The addendum proposes background soil sampling and analysis for metals and total organic carbon (TOC). All groundwater monitoring wells will be replaced, developed and sampled. Samples will be analyzed for petroleum constituents and salinity. The subject addendum is approved with the following conditions: Soil samples analyzed for TOC should also be analyzed for gasoline range organics (GRO), diesel range organics (DRO) and benzene, toluene, ethylbenzene and xylenes (BTEX). Groundwater samples should also be analyzed for GRO and DRO. Additional background soil samples may be required.	Elizabeth Stergiou
4/2/2003	Update or Other Action	Changed longitude and latitude based on TopoZone interactive mapping website. Changed priority by selecting the multiple sources field to reflect site characterization information	Elizabeth Stergiou
4/21/2003	Update or Other Action	Letter by Paul Horwath, DEC engineer: Approval of the June 2002 Togiak Fisheries Evaporative Desorption Remediation Sampling and Analysis Plan.	Eileen Olson
4/29/2003	Update or Other Action	Letter from Brady Environmental to NOAA regarding NOAA recommendation to use sediment curtain for work ajdacent to the marine environment (re Togiak Fisheries Nationwide Permit #3).	Eileen Olson
6/17/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #1, May 22, 2003"	Eileen Olson
6/17/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #2, May 29, 2003"	Eileen Olson
7/2/2003	Update or Other Action	Rec'd June 5, 2003 "Togiak Fisheries Evaporative Disorption Remediation, Sampling Event #3"	Eileen Olson
7/2/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #4, June 12, 2003"	Eileen Olson
7/25/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #5, June 19, 2003"	Eileen Olson
8/8/2003	Update or Other Action	Rec'd "Third Party Sampling Report for Sampling Conducted on July 16, 2001" by Remtech Inc. (Same as Ganco).	Eileen Olson
8/15/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #8, July 24, 2003"	Eileen Olson
8/15/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #9, July 30, 2003"	Eileen Olson
8/18/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #6, July 3, 2003"	Eileen Olson
8/18/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #7, July 9, 2003"	Eileen Olson
9/4/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #10, August 7, 2003"	Eileen Olson
9/4/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #11, August 14, 2003"	Eileen Olson
9/4/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #12, August 20, 2003"	Eileen Olson
10/21/2003	Update or Other Action	Rec'd "Togiak Fisheries...Sampling Event #13, Sept. 21, 2003"	Eileen Olson
2/7/2004	Update or Other Action	Received Report Brady Environmental's "DRAFT Togiak Fisheries Remedial Action and Supplemental Site Characterization, Summer 2002/2003 Report...February 7, 2004" that documents 2002 and 2003 field season work. .	Eileen Olson
3/24/2004	Update or Other Action	DEC rec'd Brady Environmental's "Togiak Fisheries Final Remedial Action and Supplemental Site Characterization Report...March 17, 2004" that documents 2002 and 2003 field season work and was accompanied by a cover letter from NPSI dated March 22, 2004.	Eileen Olson
4/14/2004	Update or Other Action	Granted conditional approval for treatment and off-site disposal of soils, and requested a groundwater monitoring plan in response to NPSI's March 22, 2004 cover letter with attached report by Brady Environmental (see March 24, 2004 entry). The RP plans to treat by evaporative desorption approximately 7000 cubic yards of soil that are stockpiled at the site.	Eileen Olson
5/10/2004	Meeting or Teleconference Held	Staff met with Pat Brady, env. consultant, regarding plans for thermal treatment of excavated soil.	Eileen Olson
6/9/2004	Update or Other Action	Received "Togiak Fisheries Groundwater and Sediment Monitoring Plan...June 7, 2004" prepared by Brady Environmental, LLC with cover letter by RP dated June 9, 2004 indicating desire to begin work in late June.	Eileen Olson
6/10/2004	Update or Other Action	Rec'd July 2, 2004 "Togiak Fisheries Evaporative Disorption Remediation 2004 Sampling Event #1"	Eileen Olson
7/22/2004	Update or Other Action	Rec'd July 2, 2004 "Togiak Fisheries Evaporative Disorption Remediation 2004 Sampling Event #2"	Eileen Olson
9/9/2004	Update or Other Action	Rec'd "Togiak Fisheries Evaporative Disorption Remediation 2004, Sampling Event No. 3, August 6, 2004"	Eileen Olson
10/27/2004	Update or Other Action	Rec'd "Togiak Fisheries Evaporative Disorption Remediation, 2004 Sampling Events #4, #5 & #6 . . . October 2004."	Eileen Olson
1/14/2005	Meeting or Teleconference Held	Met with Jeff Backlund and attorney for Togiak Fisheries to discuss remaining work. RP requested and received a copy of the entire DEC file for the site.	Eileen Olson
1/18/2005	Update or Other Action	DEC letter sent to North Pacific Processors owner): approved Groundwater and Sediment Monitoring Plan and acknowledged change of consultants; new consultant to complete report for past consultant	Eileen Olson
3/27/2005	Update or Other Action	Received report "Togiak Fisheries Environmental Cleanup Project, 2004 Summary Report . . . April 2005." The purpose of the report was to document to the extent possible 2004 field activities by the former consultant, to summarize confirmation samples from 2004 evaporative desorption activiteis, and outline the remaining soil treatment and monitoring activities to be conducted at the site in 2005 and 2006.	Eileen Olson
5/25/2005	Update or Other Action	Sent invoice to NPSI for copying files pursuant to Public Records Act request	Eileen Olson
5/31/2005	Update or Other Action	Rec'd cover letter by NPSI with attached Technical Memo by consultant SLR outlining work for this season. Reviewed memo and discussed with consultant SLR. Work to include soil treatment using the on-site permitted thermal treatment system, groundwater monitoring and, if there is a break in the seawall, for example if erosion allows contaminated sediment to move into the intertidal environment, sediment samplling. The seawall is in good condition so far.	Eileen Olson
6/3/2005	Update or Other Action	Received on June 10, 2005 Thermal Remediation Facility Operations Plan form filled out by NPSI, dated 6/3/2005.	Eileen Olson
6/8/2005	Update or Other Action	Received on June 15, 2005 letter from NPSI dated 6/8/2005 clarifying issues related to the operation of an on-site remediation facility. That is, NPSI believes another contractor other than former contractor Brady Environmental may operate the remediation facility in accordance with the February 2003 Togiak Fisheries Offsite Treatment Facility Operations Plan subject to modifications outlined in the SLR memorandum of 5/31/2005.	Eileen Olson
6/10/2005	Update or Other Action	Rec'd faxed letter on 6/11/2005 from former environmental consultant Brady Environmental alleging that NPSI did not report a hazardous substance release and transported soil from an offsite facility to Togiak for remediation without notification to or approval by DEC.	Eileen Olson
6/13/2005	Update or Other Action	Faxed NPSI's "Thermal Operations Facility Operations Plan Applicant's Statement & Signature" (see 6/10/2005 entry) completed 1-pg form to Pat Brady of Brady Environmental upon request.	Eileen Olson
6/14/2005	Update or Other Action	DEC letter to NPSI recounting allegations in June 10, 2005 letter from former environmental consultant and requesting information regarding operations at Togiak. Attavched June 10, 2005 letter from former consultant.	Eileen Olson
6/28/2005	Update or Other Action	Ltr. to NPSI approving extension of time to provide information requested in ADEC letter dated June 14, 2005 (see June 14, 2005 entry). Letter followed up earlier emailed request by NPSI and DEC approval. New deadline set at August 15, 2005.	Eileen Olson
8/3/2005	Update or Other Action	Files sent out for copying for Roux Inc., representing insurance company.	Eileen Olson
8/8/2005	Update or Other Action	Rec'd email from consultant informing Dept. that treatment is continuing at Togiak, and NPSI is close to calling out the 3rd party sampler from Platt Environmental for the first confirmation sampling event. Request granted to store post-treated soil on a cement pad referred to as the basketball court, as it has been in the past.	Eileen Olson
8/16/2005	Update or Other Action	Rec'd detailed response from NPSI including sworn affidavits, a copy of a current lawsuit between NPSI and its former environmental consultant, barge operation logs and other documentation regarding Togiak operations intended to refute allegations by the former environmental consultant.	Eileen Olson
8/30/2005	Update or Other Action	DEC review letter sent to NPSI; Based on information received from NPSI on 8/16/2005 DEC accepts explanation regarding disparate estimates of soil processed at Togiak Fisheries and will not further investigate allegations set forth in June 10, 2005 letter from former environmental consultant.	Eileen Olson
9/13/2005	Update or Other Action	Rec'd letter from RP, NPSI, informing DEC that lawsuit is settled and NPSI intends to complete work.	Eileen Olson
9/13/2005	Update or Other Action	DEC letter sent acknowledging 9/13/05 letter from NPSI.	Eileen Olson
9/15/2005	Update or Other Action	Rec'd letter from consultant SLR and report for Sampling Event #1 for 2005 by consultant Platt Environmental. Letter advises DEC that a final report for the 2005 season will be forthcoming, and that an updated operations plan addendum for the 2006 field season will be submitted prior to reopening the facility in 2006.	Eileen Olson
2/23/2006	Update or Other Action	Received report "Togiak Fisheries, 2005 Incinerator Release, Site Assessment and Interim Corrective Action Report" dated January 2006 by environmental consultant SLR.	Eileen Olson
3/2/2006	Update or Other Action	Received Public Records Request (PRA) accompanied by DEC-required "Certificate of Nonlitigation Affiliation" from a Seattle law firm requesting an update to an earlier PRA request.	Eileen Olson
3/9/2006	Update or Other Action	Met with NPSI's Jeff Backlund, Corporate QA & Regulatory Affairs Manager and SLR representative to discuss 2005 remedial operations, planned work for 2006 and risk assessment plan to be submitted for site.	Eileen Olson
4/21/2006	Update or Other Action	DEC sent a letter with subject line "Review of "Togiak Fisheries 2005 Incinerator Release Site Assessment and Interim Corrective Action Report". The subject of the report was an approximately 260-gallon diesel release from valve on a line between a supply tank and incinerator discovered on August 1, 2005. Interim spill cleanup took place from September 23-26, 2005 and entailed the excavation of 700 cubic yards of soil, of which approximately 350 cublc yards were impacted and stockpiled pending future onsite thermal remediation. During excavation, groundwater was observed to be impacted. The impact to groundwater will be assessed pursuant to a work plan to be submitted. Soil cleanup above the water table is complete and soils meet the method 2 migration to groundwater level.	Eileen Olson
4/24/2006	Meeting or Teleconference Held	Teleconference between NPSI's consultant, SLR, and Department staff Earl Crapps, Marty Brewer and Eileen Olson regarding SLR's proposal to conduct a risk assessment for the approximately 5-acre Togiak Fisheries facility. Earl and Marty expect to review the risk assessment in-house. A tentative target date of the end of May was set to complete comment resolution for the risk assessment workplan, assuming the work plan is submitted promptly as indicated by SLR.	Eileen Olson
5/12/2006	Update or Other Action	Received Risk Assessment Work Plan "DRAFT WORK PLAN FOR A METHOD 4 HUMAN HEALTH AND SCREENING ECOLOGICAL RISK ASSESSMENT" dated May 2006.	Eileen Olson
5/26/2006	Update or Other Action	Risk assessment work plan review comments by Marty Brewer of DEC forwarded to NPSI and consultant SLR. Release of review comments followed request for additional clarification from consultant regarding the goals of the risk assessment and adequacy of data that supports the consultant's proposal that the shallow water at the site is non-potable by virtue of salinity.	Eileen Olson
6/1/2006	Update or Other Action	Received draft responses to DEC Risk Assessment work plan review comments from NPSI's consultant. Comment resolution meeting is expected to be held within a few days.	Eileen Olson
6/7/2006	Meeting or Teleconference Held	A comment resolution meeting and teleconference was held to discuss risk assessment work plan review comments and responses. DEC staff and representatives for NPSI and the environmental consulting firm SLR participated.	Eileen Olson
6/12/2006	Update or Other Action	ADEC transmitted draft record of comment resolution meeting and risk assessment workplan review comments to NPSI.	Eileen Olson
7/28/2006	Update or Other Action	Received "2006 Sampling and Analysis Plan, Togiak Fisheries, July 2006" that proposes stockpile sampling, monitoring well installation, etc.	Eileen Olson
7/31/2006	Update or Other Action	ADEC letter dated 7/31/2006 conditionally approved work plan received 7/28/2007.	Eileen Olson
8/3/2006	Update or Other Action	Received plan clarification letter in response to conditional approval letter of August 1, 2006 with subject line "2006 Sampling and Analysis Plan Conditional Approval and Clarifications".	Eileen Olson
8/4/2006	Update or Other Action	ADEC review letter sent this date approving revisions to SAP. The proposed revisions and information requested by the Department (DQOs etc) were received via email on 8/2/2006.	Eileen Olson
8/5/2006	Update or Other Action	Received revised plan: "2006 Sampling and Analysis Plan . . . August 2006" prepared by SLR. The plan objectives were to sample the ground water monitoring wells at the site as required in the current site monitoring plan; install and sample new monitoring/potential product recovery wells in the vicinity of the 2005 Incinerator heating oil release; sample the existing soil stockpiles for hydrocarbon constituents to support data for a quantitative risk assessment; sample surface water and sediment at the site boundary to support data collection for the 2005 risk assessment; and document site work and the findings in a summary report.	Eileen Olson
1/8/2007	Update or Other Action	Received draft risk assessment document (Title: "Method 4 Human Health and Screening Ecological Risk Assessment, North Pacific Seafoods, Inc., Togiak, Alaska." )	Eileen Olson
5/29/2007	Meeting or Teleconference Held	Risk assessment comment resolution meeting and teleconference held. Major topic of discussion was applicability of ProUCL versus bootstrap method.	Eileen Olson
8/10/2007	Update or Other Action	Received "2007 Sampling and Analysis Plan . . . August 2007".	Eileen Olson
8/14/2007	Update or Other Action	Received final risk assessment report "Method 4 Human Health and Screening Ecological Risk Assessment, North Pacific Seafoods, Inc., Togiak, Alaska . . . August 2007"	Eileen Olson
8/15/2007	Update or Other Action	Approved "2007 Sampling and Analysis Plan" rec'd 8/10.	Eileen Olson
9/17/2007	Exposure Tracking Model Ranking	Initial ranking with ETM completed for source area id: 71301 name: Surface spills - petroleum products	Pam Clemens
9/17/2007	Exposure Tracking Model Ranking	Intitial Ranking Complete for Source Area: 71301 (Autogenerated Action)
11/9/2007	Update or Other Action	ADEC letter approving risk assessment and discussing pendency of Conditional Site Closure for the Togiak Fisheries site. The letter advises North Pacific Seafood International (NPSI) that the risk assessment is approved and will be subject to institutional controls and other conditions to be set forth in Conditional Closure and Record of Decision documents that will be completed following ADEC receipt and review of the groundwater monitoring report and proposed groundwater sampling schedule.	Eileen Olson
12/13/2007	Update or Other Action	Received "2007 Soil and Ground Water Characterization Report, Togiak Fisheries, Inc., Togiak, Alaska, November 2007".	Eileen Olson
12/10/2008	Update or Other Action	ADEC staff met with consultant SLR and RP NPSI representatives to review draft closure documents and discuss conditions of site closure with institutional controls site status.	Eileen Olson
2/2/2009	Update or Other Action	ADEC received "Addendum to Method 4 Human Health and Screening Ecological Risk Assessment" dated February 2, 2009 that responded to ADEC's request that available environmental analytical data from all past site investigations be included in the risk assessment dataset.	Eileen Olson
2/4/2009	Update or Other Action	ADEC received a copy of consultant SLR's letter report to NPSI titled "Findings from ADEC Inquiry Regarding Remaining Contamination Togiak Fisheries Site, Togiak, Alaska" dated 2/4/2009. The report describes the changes made in the risk assessment addendum submitted on February 2, 2009 and the effect of those changes. SLR concluded that additional cleanup of the site is not warranted; the current contaminant site concentrations in the soil are below levels that may be expected to impact human health or ecological community health at the site; the target cleanup levels (TCLs) of 2,800 mg/kg benzene, 244,000 mg/kg gasoline range organics (GRO), 179,000 mg/kg diesel range organics (DRO) and 70,000 mg/kg residual range organics (RRO)presented in the risk assessment addendum are protective of human health and ecological community health; and all onsite soil concentrations are below these TCLs.	Eileen Olson
4/22/2009	Update or Other Action	ADEC received figures showing the estimated plume boundaries and previous excavation depths based on sample analytical results.	Eileen Olson
5/5/2009	Meeting or Teleconference Held	Staff met with two representatives of consulting firm SLR to discuss status of record of decision and site conditions including effect of changed risk assessment dataset and status of the three wells located along the boundary between the tidelands and Togiak Fisheries property that comprise the site. SLR will submit a report that includes the results for the August 2008 groundwater monitoring event within the next two weeks.	Eileen Olson
5/11/2009	Update or Other Action	Report received by hand-delivery “2008 Ground Water Characterization Report . . . May 2008” for Togiak Fisheries.	Eileen Olson
8/14/2009	Meeting or Teleconference Held	Meeting held to discuss terms of the Record of Decision (ROD) for the site. Attended by ADEC staff and NPSI and SLR representatives in person and via teleconference. Following the meeting SLR submitted by email a soil stockpile decommissioning plan proposing work in September 2009, with the comment that the ROD to be signed later would then refer to this in the past tense as a completed activity.	Eileen Olson
8/14/2009	Update or Other Action	Received plan for a placing a total of approximately 1,100 cubic yards of soil containing hydrocarbons in the 2005 incinerator release excavation, with additional soil to be spread elsewhere on the site.	Eileen Olson
8/28/2009	Document, Report, or Work plan Review - other	ADEC letter issued reviewing "Draft Togiak Fisheries Soil Stockpile Decommissioning Plan...August 2009." The letter notes that plan approval will be granted following receipt of a landspreading plan and if other conditions are met, including excavating below the groundwater table at the 2005 incinerator surface fuel release site to determine whether a sheen or free product are present on the groundwater surface, and whether a petroleum hydrocarbon smear zone is present below the high water level within the excavated area. ADEC also requested that the southern boundary of the property and locations of monitoring wells be surveyed if this has not been done.	Eileen Olson
1/6/2010	Update or Other Action	ADEC received a letter and two plans, submitted in advance of meeting planned for 1/11/2010: The letter dated January 6, 2010 has subject line "Response to ADEC Review, Draft Togiak Soil Stockpile Decommissioning Plan, August 2009". The plans are the "Togiak Fisheries Soil Stockpile Decommissioning Plan...January 2010" and "Togiak Fisheries Sampling and Analysis Plan, 2010 through 2012."	Eileen Olson
1/11/2010	Meeting or Teleconference Held	Staff met with consultant SLR and NPSI representative to review recent (Jan. 6) submittals and discuss schedule for proposed work to commence in June. ADEC and NPSI agreed that the Record of Decision will be completed following rather than prior to June 2010 work.	Eileen Olson
3/8/2010	Document, Report, or Work plan Review - other	Conditional approval granted for the "Togiak Fisheries Soil Stockpile Decommissioning Plan" received on January 6, 2010. The plan is a revision of the "Draft Togiak Fisheries Soil Stockpile Decommissioning Plan ... August 2009" in response to ADEC's review letter dated August 28,2009. The plan proposes removing clean fill from the 2005 spill excavation so that two feet of clean fill remains above the top of the zone of groundwater fluctuation; placing the contaminated soil from the 2005 spill into the excavation, and placing a minimum two-foot thickness of clean fill at the surface of the filled-excavation. Soil that is not placed in the excavation will be spread on the surface of the ground.	Eileen Olson
5/7/2010	Document, Report, or Work plan Review - other	DEC plan approval letter sent with subject line "Conditional approval of Togiak Fisheries Sample and Analysis Plan,Togiak, Alaska, 2010 - 2012" for the plan dated January 2010. The plan proposes sampling groundwater from nine monitoring wells at the site; collecting six pore water samples from intertidal sediment; rehabilitating two monitoring wells located beneath the dock that were installed in 2003 (RW-3R and RW-4R); and decommissioning 11 monitoring wells that do not include the nine to be sampled. The pore water samples will be collected during a low tide cycle.	Eileen Olson
6/2/2010	Update or Other Action	NPSI notified DEC that work would be done in accordance with the plans approved 3/8/2010 and 5/7/2010 from June 16 - 18, 2010. DEC staff had previously requested advance notice so that staff could travel to the site to observe field work. Work was delayed due to the airline losing equipment and was instead begun on June 20th. DEC staff was not on site during the June work.	Eileen Olson
6/24/2010	Update or Other Action	SLR provided DEC with updated status for site work completed by 6/23/2010 including (1) All wells scheduled for monitoring, with the exception of MW-B that was not accessible, were sampled; (2) Two wells (RW 3R and RW 4R) that were damaged or silted in were rehabilitated and sampled; (3) All Pore Water devices (PW-1 through PW-6) were installed and sampled. (4) A container barge is now anchored north of the dock starting at the northeast corner, so that the locations of two of the six pore water devices were modified.	Eileen Olson
7/30/2010	Update or Other Action	Consultant SLR submitted the "June 2010 Field Event – Letter Report, Togiak Fisheries, Togiak, Alaska" dated July 15, 2010. Field activities reported included pore water sampling, rehabilitation of two ground water monitoring wells, and ground water sampling from select monitoring wells. Activities were completed in accordance with the Sampling and Analysis Plan approved 5/10/2010. SLR personnel were on site between June 20, 2010 and June 23, 2010. Two of the six pore water sample results had detectable petroleum hydrocarbons: toluene at 0.117 milligrams per liter (mg/L) in sample location PW-4; and diesel range organics (DRO) in PW-4 at 1.11 mg/L.	Eileen Olson
8/12/2010	Update or Other Action	NPSI notified DEC that the remaining work proposed in the plan approved on May 7, 2010 would take place on September 7, 2010. DEC Quality Assurance Officer Brent Porter made arrangements to be on-site during the field work.	Eileen Olson
9/7/2010	Site Visit	ADEC's quality assurance officer made a site inspection at the Togiak fisheries site on September 7th, per the request of Eileen Olson and Rich Sundet. The quality assurance officer was accompanied by Jeff Backlund from North Pacific Seafoods and Andy Dimitriou and Aaron Nash from SLR consulting. While onsite we inspected the areas where known contamination had been present, replacement monitoring wells, pore water sampling locations, areas of recent excavation, and we observed monitoring well purging using a low flow technique. At the request of the project manager many site photos were taken and have been submitted to her on CD to be included in the project file that is in her posession.	Brenton Porter
9/21/2010	Update or Other Action	NPSI's consultant SLR notified DEC that the report for work done during the 2010 field season including the September 7, 2010 work, is in progress and that NSPI hopes to finalize the ROD for the site as soon as possible following submittal of the report.	Eileen Olson
12/22/2010	Update or Other Action	Received two reports; the "September 2010 Ground Water Monitoring Event - Summary Report" and the "September 2010 Stockpile Decommissioning - Summary Report" both dated December 22, 2010.	Eileen Olson
3/10/2011	Meeting or Teleconference Held	Staff met with NPSI and consultant SLR representatives to discuss remaining requirements in completing decision document proposed for Cleanup Complete/Institutional Controls status. Outstanding issues include how to depict historic contamination beneath the northern end of the spit. Staff and SLR agreed to work on modifying figure showing remaining contamination.	Eileen Olson
2/14/2012	Meeting or Teleconference Held	On 2/14/2012, Sundet met with Jeff Backund of North Pacific Fisheries and provided him with a hard copy of a revised draft closure document with institutional controls. Later on 2/14, Sundet emailed Jeff and Andy Demitriou of SLR with the draft document.	Rich Sundet
2/14/2012	Exposure Tracking Model Ranking	A new updated ranking with ETM has been completed for source area 71301 Surface spills - petroleum products.	Eileen Olson
3/22/2012	Spill Transferred from Prevention Preparedness and Response Program	Spill transferred by PERP staff Robert Carlson. Spill no. 05269915201; spill date = 6/1/2005; substance = diesel; quantity = unknown; description: Cannery staff left tank valve partially open after it was filled causing a slow leak for approximately 2 months. Note by project manager Eileen Olson: Site cleanup was handled under CS oversight in 2005 and results of cleanup were incorporated into subsequent documents regarding site status.	Mitzi Read
6/25/2012	Document, Report, or Work plan Review - other	ADEC letter issued "Conditional approval of Draft Togiak Fisheries Sampling and Analysis Plan, 2012 through 2013".	Eileen Olson
6/28/2012	Update or Other Action	Following receipt of comments on a previous draft decision document from the responsible party, NPSI, ADEC updated the draft decision document for Cleanup Complete with Institutional Controls (CC/IC) status and on 6/28/2012 provided NPSI with a draft deed notice (NEC - Notice of Environmental Contamination) and all figures referenced in the decision document.	Eileen Olson
8/7/2012	Cleanup Complete Determination Issued	In granting cleanup complete with institutional controls status, ADEC considered site specific conditions including the lack of accessibility to contamination remaining from major fuel releases in the 1980s, much of which is located beneath structures constructed on pilings; the fact that extensive so urce removal of approximately 7,650 cubic yards of petroleum hydrocarbon contaminated soil took place from 2001 to 2005; and the status of health and ecological exposure pathways following cleanup activities that included 'exposure controlled', 'de minimis' exposure, and 'low potential' ecological exposure. Although a contaminant smear zone is present in soil and sediment beneath and adjacent to cannery facility structures, pore water sampling and groundwater monitoring indicate that contaminant migration is not occurring.ADEC did not approve alternative cleanup levels for the site. The site cleanup levels for hazardous substances in site soil are set by 18 AAC 75.341, Method Two, Tables B1 and B2, Migration to Groundwater for the over 40-inch (precipitation) zone. ADEC cleanup levels for groundwater are set by 18 AAC 75.345, Groundwater and surface water cleanup levels, Table C.	Eileen Olson
8/24/2012	Document, Report, or Work plan Review - other	ADEC review letter declining to approve plan dated August 23, 2012 for soil disposal of small quantity (<1 cy) of contaminated soil in an area of the site not designated for disposal. Suggested alternatives including the possbility of remediating the soil in a biopile.	Eileen Olson
9/6/2012	Institutional Control Update	Received signed "Attachment A: Cleanup Complete - ICs Agreement Signature Page" dated 9/6/2012 from Togiak Fisheries.	Eileen Olson
9/10/2012	Institutional Control Record Established	Institutional Controls established and entered into the database.	Eileen Olson
10/10/2012	Update or Other Action	Received report for monitoring done according to decision document conditions: "Togiak Fisheries 2012 Groundwater Sampling Report, Twin Hills, Alaska...October 2012" prepared by SLR for work done on August 15-16, 2012. Work documented in the report includes decommissioning of monitoring well MW-B; installation of one replacement monitoring well in the vicinity of MW-B; collection of groundwater samples from specified monitoring wells; and documenting groundwater sampling activities and the findings in a summary report. Groundwater samples were collected from eight monitoring wells with analyses for BTEX and for specific wells, either DRO or GRO. Monitoring well RW-4R contained insufficient water and was purged dry prior to parameter stabilization.	Eileen Olson
6/17/2014	Document, Report, or Work plan Review - other	ADEC review letter issued in response to fall 2013 request by NPSI to cease monitoring and decommission the 9 monitoring wells at the site that are subject to the long-term monitoring requirements of the decision document dated August 7, 2012. The review letter approves decommissioning of 4 of the 9 monitoring wells and requires that by July 31, 2015, NPSI replace a monitoring well that could not be sampled due to an obstruction for the two monitoring events since the decision was issued, and sample that replacement well and the other four wells after and within three hours of low tide.	Eileen Olson
1/5/2015	Meeting or Teleconference Held	Staff met with NPSI and consultant representatives to discuss requirements of ADEC 6/17/2014 letter; consultant will provide a brief work plan before installation of one replacement groundwater monitoring well and groundwater monitoring event to take place in 2015.	Eileen Olson
4/3/2015	Document, Report, or Work plan Review - other	ADEC conditionally approved the "2015 Togiak Fisheries Sampling and Analysis Plan, Twin Hills, Alaska" dated March 20, 2015.	Eileen Olson
9/22/2015	Update or Other Action	ADEC received SLR report dated 9/21/15 "2015 Groundwater Monitoring and Decommissioning Report" with cover letter and appendices (via email).	Eileen Olson
1/15/2016	Meeting or Teleconference Held	ADEC staff met with representatives of NPSI and consultant SLR representative to discuss project status including ADEC preparation of an addendum to the 2012 decision document that makes a record of the conditions of the decision document that have now been met. Following the meeting ADEC determined that a Notice of Environmental Contamination has not yet been filed. ADEC will update the NEC and file it at the same time the addendum is completed.	Eileen Olson
11/14/2017	Institutional Control Update	ADEC received letter dated November 6, 2017 that fulfills IC condition of August 7, 2012 Decision Document regarding periodic reporting of land use and ownership status: Letter states there have been no changes in ownership or land use of the site.	Eileen Olson
6/14/2018	Institutional Control Compliance Review	IC compliance review conducted. Staff changed from Eileen Olson to IC Unit. Closure/IC Details added to reflect the institutional controls outlined in the 2012 Decision Document.	Kristin Thompson

Action Date

Action

Description

DEC Staff

11/23/1987

Site Added to Database

Gasoline and diesel spills impacted soil, groundwater and adjacent beach and marine environment.

Mike Lewis

12/2/1987

Update or Other Action

Site visit - ADEC staff visited site to collect samples and identify spill areas.

Mike Lewis

1/5/1988

Update or Other Action

Fuel saturated soils identified on-site. ADEC investigations indicate a large amount of gasoline/diesel fuel on the groundwater.

Mike Lewis

1/12/1988

Site Visit

Site visit by ADEC - staff collected two soil samples and two water samples. One water sample was taken below ice by the dock and the second was from the winter watchman's house well--a hand-dug pit well-- where the depth to water was approximately 12 feet. No petroleum odor was observed in either water sample. Both soil samples appeared to be maximally saturated by fuel.

Mike Lewis

1/20/1988

Update or Other Action

Compliance Order by Consent (COBC) between Togiak Fisheries and the State of Alaska signed. The COBC outlines speficic tasks which Togiak Fisheries must perform and a schedule of deadlines which must be met to avoid penalties. Actions required included remedial action to contain fuel spills and to prevent aditional contamination of land or continued migration of fuel contamination into water. (Mike Lewis was project manager at time of COBC issuance).

Mike Lewis

1/29/1988

Update or Other Action

ADEC amended the deadlines in the compliance order (see 1/20/1988 entry)in a letter of this date.

Mike Lewis

3/4/1988

Update or Other Action

Report "Subsurface Exploration and Groundwater Monitoring Petroleum Recovery Operations, Togiak, Alaska, February 1988" submitted by consultant RZA with cover letter to Togiak Fisheries dated 3/4/1988. Date stamp on document is July 22, 1988. The report documents the following: 11 borings that were completed as four 2-inch diam. monitoring wells and seven 5-inch diam. recovery wells; installation and operation of a free product recovery system; free-product was encountered in 4 wells during periods of low tide; initiation of free product recovery began on Feb. 13, 1988;subsurface soils generally consist of gravelly fine- to coarse-grained sand, or mixed sand and gravels, all of fairly high permeability; depth to groundwater ranged from 4-10 feet below ground surface; and by March 4,1988 over 200 gallons of fuel had been recovered. (Input to db 2008).

Closed

3/17/1988

Document, Report, or Work plan Review - other

ADEC review letter of consultant RZA's report "Subsurface Exploration and Groundwater Monitoring Petroleum Recovery Operations, Togiak, Alaska, February 1988." Recovery operations were found to be marginally adequate, and comments by ADEC included the need for further investigation of the site; the need to increase product recovery from the groundwater as soon as weather permits; insufficient processing of water separated from floating product that has been discharged on the ground, and requirements for testing the water or reinjecting it into the ground; and a request for details on actions to be taken to check fuel system components and whether components of the entire system will be replaced. The letter also reiterates the need for a response regarding items requested in ADEC's Feb. 2, 1988 letter that were not addressed.

S&W

3/28/1988

Update or Other Action

Received plan. Cover letter from RZA to Togiak Fisheries dated March 28, 1988 accompanies "Site Remediation Plan: Remedial Action Plans for Fuel Recovery Operations at Togiak Fisheries, Inc." The plan proposes installing 8 6-inch diameter recovery wells, with 4 wells to be placed in the area of the main processing complex (northern end of spit) and 4 wells to surround the waste oil drum storage area approximately 1000 feet south of the main complex. The plan also includes a combination free product recovery system using a scavenger floating oil skimmer, a trench system, groundwater reinjection gallery, and venting system, and sampling and appropriately disposing of or handling all drums in the drum storage area. (Action Input 2008)

S&W

5/1/1988

Interim Removal Action Approved

Crowley Environmental and RZA retained by TFI; Crowley to direct petroleum recovery; RZA documents subsurface and groundwater monitoring.

Mike Lewis

6/1/1988

Update or Other Action

Additional product recovery wells installed; operated in 1988 winter with difficulty. Site Treatment, Soil/H2O

Mike Lewis

6/2/1988

Update or Other Action

Soil venting system installed; operated year round. Site Treatment, Soil/H2O.

Mike Lewis

7/14/1988

Update or Other Action

Incinerator installed for disposing of waste fuel; some recovered gasoline was mixed with new gasoline and burned in engines.

Mike Lewis

7/15/1988

Update or Other Action

Permit Action at Site: Incinerator ash disposal; permit #8821-BA011.

Mike Lewis

4/24/1989

Update or Other Action

Chempro, formerly Crowley Environmental, completed on-site evaluation and repair of facility after first winter of operation

Mike Lewis

6/20/1989

Update or Other Action

Recovery wells restarted for season. Site Treatment, Soil/H2O.

Mike Lewis

6/20/1989

Update or Other Action

Recovery wells restarted for season. Site Treatment, Soil/H2O.

Mike Lewis

9/27/1989

Update or Other Action

Field Inspection. RZA updated review of petroleum recovery efforts; equipment damage from saline groundwater and winter conditions; portion of VE system flooded or frozen. Winter operation of recovery wells not recommended. VE system recovery increased when area beneath dock thawed.

Mike Lewis

12/5/1989

Update or Other Action

TFI has shut down and winterized recovery wells. Product recovered to date is 8,307 gallons. VE system reported at 35 to 40% LEL during first year of operation. Decreased to 15% LEL during second summer of operation; decreased to 2% LEL during the following winter. Site Treatment, Soil/H2O.

Mike Lewis

2/1/1990

Update or Other Action

Letter from Fryer/Pressley Engineering, Inc., contracted to ADEC, reporting on deficiencies of Togiak Fisheries fuel storage and piping system based on a review of a video of the system provided by ADEC.

S&W

3/2/1990

Site Number Identifier Changed

Also includes old Reckey 1988210901901.

Mike Lewis

5/22/1990

Update or Other Action

Recovery wells reactivated; trace amount of product recovered; VE system increased to 3% LEL from winter 2% LEL.

Mike Lewis

8/14/1990

Update or Other Action

Follow-up work is being done to conform with the ADEC Compliance Order. On site fuel system being brought up to code. Further site investigation planned by RZA to delineate boundary of "zero" contamination. VE system continues to run at 2 to 4% LEL.

Mike Lewis

10/8/1990

Document, Report, or Work plan Review - other

ADEC letter approving plan to replace fuel tank farm in accordance with the COBC (see 1/20/1988 entry). Letter responds to Togiak Fisheries letter providing status of product recovery system and notification that fire marshall approved plan for new tank farm.

S&W

12/4/1990

Site Ranked Using the AHRM

Initial ranking.

Mike Lewis

6/4/1991

Update or Other Action

Progress report sent in on cleanup and monitoring as required by compliance order 88-2-1-1-019-1. Monitoring wells show no accumulation of product. Vapor extraction system continues to operate, but lower explosive level is very minimal. Last of 6 diked tanks installed and in process of hooking up piping.

Mike Lewis

8/9/1991

Site Number Identifier Changed

Changed workplan from 21 to 25.

Mike Lewis

9/3/1991

Update or Other Action

Date of "Field Report and Sampling Results" report by PTI Environmental--stamped rec'd April 19, 2001 by ADEC. Report contents are referenced in August 2000 consultant Brady Environmental report with note that the report was not in the file so Brady did not review it). PTI concluded that the extent of subsurface contamination was similar to what was found in 1988, with the exception of the free-floating hydrocarbons,with the number of wells with occurrences of floating hydrocarbons on the water table decreasing from five in June 1989 to one in June 1991. PTI and RZA concluded that there was one large plume that covered most of the site.

S&W-Miner

12/28/1994

Update or Other Action

COBC (see 1/20/1988 entry re COBC) required inspection every two months but last report was February 1990. Vapor extraction at 2%.

Ray Dronenburg

4/20/2000

Meeting or Teleconference Held

Met with Pat Brady of Brownsfield Development, LLC at ADEC offices in Anchorage to review file and discuss site characterization and cleanup issues.

Scott Pexton

2/5/2001

Meeting or Teleconference Held

Teleconference held with Jim Kudwa and Jeff Backlund of North Pacific Processors, Inc., Pat Brady of Brady Environmental, LLC, and Chuck Blumenfeld of Perkins, Coie to discuss site characterization and cleanup issues. North Pacific Processors, Inc. indicate interest in having Brady Environmental, LLC oversee interim removal actions and additional site characterization activities during spring/summer of 2001.

Scott Pexton

2/7/2001

Update or Other Action

Report received: "Togiak Fisheries Soil and Groundwater Investigation report, August 2000" prepared by Brady Environmental, LLC.

Scott Pexton

2/26/2001

Document, Report, or Work plan Review - other

Letter sent to Pat Brady with comments on investigation report.

Scott Pexton

3/13/2001

Update or Other Action

Received and reviewed liner specification sheet faxed to CSRP by Pat Brady. Telephoned Pat Brady and verbally approved the proposed woven HDPE polyolefin fabrix with LDPE coatings for use as a short-term liner for petroleum-contaminated soil.

Scott Pexton

3/14/2001

Update or Other Action

Received Togiak Fisheries Interim Remedial Action Measure Plan, prepared by Brady Environmental, LLC for North Pacific Processors, Inc.

Scott Pexton

3/30/2001

Cleanup Level(s) Approved

ADEC approved Method 1 Category B cleanup levels of 100 mg/kg, 200 mg/kg, and 2000 mg/kg for GRO, DRO, and RRO respectively that were proposed in the interim removal action work plan by Brady Environmental, LLC.

Scott Pexton

3/30/2001

Interim Removal Action Approved

Letter sent to Pat Brady of Brady Environmental, LLC with conditional approval of the interim removal work plan. The letter also provided ADEC approval of a site-specific operations plan for a portable thermal treatment facility.

Scott Pexton

4/19/2001

Update or Other Action

Received plan "Togiak Fisheries Supplemental Site Characterization Work Plan, Togiak, Alaska . . . April 11, 2001" prepared by Brady Environmental, LLC.

Scott Pexton

4/30/2001

Site Characterization Workplan Approved

Letter sent to Pat Brady with approval of Site Characterization work plan received 4/19/2001.

Scott Pexton

7/19/2001

Update or Other Action

Received copy of letter from Brady Environmental, LLC to the ADEC Solid Waste program regarding application for a general permit for a one-time disposal of construction and demolition waste.

Scott Pexton

7/25/2001

Update or Other Action

Letter signed by acting CSRP Program Manager and sent to Jim Kudwa of North Pacific Processors, Inc. that effectively terminates compliance order by consent 88-2-1-1-019-1.

S&W

8/3/2001

Update or Other Action

Received two reports prepared by GANCO Environmental Construction, Inc. titled "Togiak Fisheries Third Party Sampling Report for Sampling Conducted on June 19, 2001" and "Togiak Fisheries Third Party Sampling Report for Sampling Conducted on July 16, 2001." Results indicated concentrations of GRO/DRO/RRO in all confirmation samples were non-detect.

Scott Pexton

8/6/2001

Site Visit

Site visit to Togiak Fisheries on Monday and Tuesday to view progress with interim removal action and site characterization.

Scott Pexton

8/14/2001

Update or Other Action

Received copy of General Permit Number 9940-BA003 for the operation and maintenance of a monofill for the one-time disposal of construction/demolition debris at the Togiak Fisheries site.

Scott Pexton

8/27/2001

Update or Other Action

Received fax copies of confirmation sample analytical results for samples collected by Platt Environmental. Two batches of samples were collected by Platt Environmental, one on 8/3/2001 and another on 8/18/2001. Results indicate that all samples collected met Category B, Method 1 cleanup levels for GRO/BTEX and RRO. However, ten samples collected 8/3/2001 did not meet the Category B, Method 1 cleanup level for DRO of 200 mg/kg (sample concentrations ranged from 237 to 348 mg/kg with Method AK102). Therefore, the treated soil was processed through the treatment system again; results of confirmation samples collected by Platt Environmental 8/18/2001 indicated that all confirmation samples met Category B, Method 1 cleanup levels for GRO/BTEX and DRO/RRO.

Scott Pexton

1/29/2002

Update or Other Action

ADEC received "Togiak Fisheries Supplemental Site Characterization Report" and "Togiak Fisheries Interim Remedial Actions Measures, Summer 2001 Status Report" both prepared by Brady Environmental, LLC.

Scott Pexton

2/13/2002

Meeting or Teleconference Held

Meeting held at ADEC offices in Anchorage with Scott Pexton and Markus Niebanck, an agent representing Firemans Fund Insurance to discuss site history and status of site cleanup.

Scott Pexton

3/7/2002

Update or Other Action

ADEC received a Togiak Fisheries Offsite Soil Treatment Facility Operations Plan, prepared by Brady Environmental, LLC. The plan outlines plans to modify the existing soil treatment facility to meet requirements for an offsite soil treatment facility. Also accompanying the plan was a letter report with figures dated March 1, 2002 with subject line "Review Statement, Togiak Fisheries Offsite Soil Treatment Facility Operations Plan."

Scott Pexton

3/27/2002

Site Characterization Report Approved

ADEC letter to Pat Brady (copy to Jim Kudwa of North Pacific Processors) with approval of site characterization report in accordance with 18 AAC 75.335 (d). Requested submittal of an additional set of figures (similar to Figure 2) as an addendum to the Supplemental Site Characterization Report. The figures should depict: all monitoring or recovery wells found during 2001, including the wells that were sampled; the extent of groundwater contamination by delineating GRO, DRO, and BTEX compound concentration isopleths based on 2001 groundwater sampling results; and the groundwater flow direction(s) based on the measured water elevations levels in wells.

Scott Pexton

3/28/2002

Update or Other Action

ADEC letter to consultant Brady (copy to RP representative Jim Kudwa) that (1) approved interim removal action report; (2) requested submittal of an additional figure as an addendum to the Interim Removal Action Measures Status Report showing much additional information including the locations where the 2001 excavation confirmation sample results exceeded the approved method one soil cleanup levels; (3) noted that while the report included the fact that DEC approved the use of method one Category B soil cleanup levels for GRO, DRO, and RRO at the site, many of the excavation confirmation soil samples exceeded the target method one cleanup levels for GRO or DRO and this was not addressed; and (4) requested a cleanup plan by May 15, 2002. ADEC stated that the cleanup plan is to include a soil confirmation sampling and analysis plan; a groundwater monitoring proposal to evaluate concentration trends; a schedule for conducting fieldwork, monitoring; and submittal of a final cleanup report.

Scott Pexton

4/8/2002

Update or Other Action

Email message with letter attachment sent from Paul Horwath to Pat Brady with comments on Operations Plan for offsite soil treatment facility.

Scott Pexton

4/22/2002

Update or Other Action

Received 2 letter reports, both dated April 16, 2002 from Brady Environmental LLC with responses to ADEC requests for addition information pertaining to the interim removal action report (see information request described in 3/27/2002 ADEC letter entry) and the site characterization report (see information request described in 3/28/2002 ADEC letter entry). The letter report with subject line "Request for Additional Information, Site Characterization Report . . ." includes GRO, benzene and DRO groundwater contaminant distribution shown as isopleths. The letter report with subject line "Request for Additional Information, Interim Removal Action Report" provides figures showing the location of soil samples that exceeded approved cleanuplevels and shows proposed excavation areas, with hatched areas showing areas believed to exceed applicable cleanup levels.

Scott Pexton

5/13/2002

Update or Other Action

"Revised Togiak Fisheries Off-Site Soil Treatment Facility Operations Plan" with cover letter addressed to Paul Horwath, PE, ADEC Soldotna Office, dated May 10, 2002, was received by the Soldotna Office on 5/13/2002.

Eileen Olson

5/13/2002

Meeting or Teleconference Held

Met at ADEC offices with Pat Brady and Elizabeth Stergiou. Pat submitted the offsite soil treatment facility Operations Plan and indicated it had been revised to address ADEC comments provided by Paul Horwath. Pat indicated that he had prepared a draft cleanup plan but wanted to submit it later in the week. He indicated that Pacific Processors, Inc. was negotiating some cleanup issues with an insurer and wanted to delay submittal of the cleanup plan. It was suggested that the draft plan be submitted with a request to delay for ADEC review of the draft plan until a later date.

Scott Pexton

5/17/2002

Meeting or Teleconference Held

Meeting at ADEC offices in Anchorage with Pat Brady and Charles Blumenfeld of Perkins Coie LLP, an attorney representing Pacific Processors, Inc. Cleanup issues were discussed and Mr. Blumenfeld indicated that alternative cleanup level proposals may be submitted at a later date and that additional site-specific information would be gathered this field season to support an ACL proposal. He also indicated that they would submit an interim removal action plan (18 AAC 75.330) instead of a cleanup plan under 18 AAC 75.360. He indicated that a letter would be sent to ADEC within a week which would describe their plans more fully.

Scott Pexton

5/28/2002

Update or Other Action

Received faxed letter from Charles Blumenfeld of Perkins Coie LLP, an attorney representing North Pacific Processors, Inc., indicating that Togiak Fisheries, Inc. would submit an interim action plan for summer 2002 work instead of a Cleanup Plan. The letter indicated that Togiak Fisheries believes the interim measures would allow continued progress and provide additional data needed to propose a final cleanup plan.

Scott Pexton

6/7/2002

Update or Other Action

Letter sent to Chuck Blumenfeld of Perkins Coie LLP, an attorney representing North Pacific Processors, Inc., with a request for an interim removal action plan. The request was for submittal of a plan to describe work to be performed during the summer of 2002 that would focus on removing contaminated material that comes in contact with surface water and to provide further characterization data needed to prepare a cleanup plan.

Scott Pexton

6/10/2002

Update or Other Action

Received 2 plans: "Togiak Fisheries Interim Remedial Actions Measures Plan Summer 2002" prepared by Brady Environmental, LLC. Also, received "Togiak FIsheries Evaporative Disorption Remediation Sampling and Analysis Plan . . . June 7, 2002" for post treatment sampling at the Togiak Fisheries Soil Treatment Facility. The plan was prepared by Platt Environmental for Brady Environmental LLC.

Scott Pexton

6/20/2002

Interim Removal Action Approved

Letter sent to Brady Environmental LLC with conditional approval of Interim Removal Action Work Plan.

Elizabeth Stergiou

7/8/2002

Update or Other Action

Received letter from North Pacific Processors, Inc. stating that North Pacific Processors, Inc. will be unable to perform the Interim Remedial Action Measures this summer. The letter indicated they will not be able to fund response actions at the Togiak site until either an insurance company is forced by the court to make good on its obligations or until the end of the current fishing season when they hope to have revenues in excess of expenses.

Scott Pexton

8/12/2002

Update or Other Action

Letter sent to Jim Kudwa of North Pacific Processors, Inc. requesting additional information to describe the schedule for implementing the ADEC approved interim removal action plan. The letter also provided notification of a change in ADEC project manager from Scott Pexton to Elizabeth Stergiou.

Scott Pexton

11/7/2002

Meeting or Teleconference Held

Met with NPP representatives Rusty Roessler, Plant Manager and Jeff Backlund, Corporate Quality Control Manager, and NPP's attorney Chuck Blumenfeld. Scott Pexton and Elizabeth Stergiou represented ADEC at the meeting. NPP submitted the requested sampling documentation from the sampling event conducted by Fireman's Insurance and a report Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc Site. NPP proposed going to a risk assessment approach prior to further removal actions. ADEC encouraged NPP to continue with the previously approved interim removal action due to the presence of free product and contamination along Togiak Bay. ADEC will review the submitted report and offer comments. ADEC and NPP is planning to schedule a risk assessment scoping meeting for early 2003. NPP would like to conduct the risk assessment during 2003.

Elizabeth Stergiou

11/21/2002

Update or Other Action

Report received during meeting of same date: "Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc Site . . . November 1, 2002."

Elizabeth Stergiou

11/22/2002

Update or Other Action

ADEC received qualifications information re MCS Environmental from attorney for NPPI.

Elizabeth Stergiou

12/19/2002

Update or Other Action

Staff reviewed the October 30, 2002 report entitled Evaluation of Remedial Activities and Suggested Next Steps for the North Pacific Processors, Inc (NPPI) Site. The report recommends pursuing a risk assessment, in lieu of additional contaminated soil removal, due to the shallow depth to groundwater, the strong tidal influences and the fluctuating direction of groundwater flow. The Department does not agree with the report’s suggestion that the subject site is at the stage in the ADEC cleanup process where a risk assessment is appropriate and requests NPPI conducts additional soil removal and treatment in accordance with the conditionally approved Interim Removal Action Work Plan . NPPI has demonstrated that they can excavate the contaminated soil and successfully treat it at the Togiak Fisheries site. Additional site characterization is recommended. The subject report states that sampling to date has not established whether the depth of contamination (3-6 feet) is fully delineated. The depth of contamination (especially under the dock area) has not been fully characterized. The Department requests the remaining stockpiled soil on site be treated during field season 2003. Approximately 2,500 cubic yards of petroleum contaminated soil is stockpiled on site in a long-term storage cell. The cell was completed and filled in 2000 and the contaminated soils with in it will need to be treated during this upcoming field season. It is recommended NPPI explore the 18 AAC 75.341(e) for guidance on using site specific parameters to propose an alternative cleanup level under method three at that time.

Elizabeth Stergiou

1/28/2003

Meeting or Teleconference Held

The attendees were Rusty Roessler – NPPI Plant Manager, Jeff Backlund - NPPI Corporate Quality Control Manager, Robert Torres – NPPI General Manager, Pat Brady - Brady Environmental and Chuck Blumenfeld – Perkins Coie LLP. Togiak Fisheries will conduct the previously approved interim removal action during field season 2003, treat the remaining soil from the 2001 excavation, and conduct sampling for possible alternative cleanup levels. We discussed the surface water quality issue, as there is documented impact to the surface water of Togiak Bay. 2002 water sample results were 9.10 mg/L GRO, 3.71 mg/L DRO and 0.0399 mg/L benzene. Also discussed was the need for future surface water and groundwater monitoring, points of compliance for surface water contamination and the cleanup process from the point of the interim cleanup action. Mr. Brady proposed excavating the soils and sediments from the area most likely impacting surface water and treating it to a to be determined Method Three level, and depositing it in the area to be covered by the alternative cleanup level. Mr. Brady also proposed evaluating the site for a possible groundwater use determination under 18AAC75.350 given the tidal influence on the present monitoring wells on site. Mr. Blumenfeld voiced concern for an end point. ADEC presented the cleanup process and that the interim cleanup action may be counted as the cleanup action depending on the extent of contamination present after the action, remaining threat to surface water, and the alternative cleanup levels established. Also presented was the need for long term monitoring for surface and groundwater. If a NFRAP was granted the long term monitoring would be a component of the NFRAP and the site status may change at any time dependent on the threat to surface water.

Elizabeth Stergiou

2/18/2003

Update or Other Action

Rec'd "Togiak Fisheries Offsite Soil Treatment Facility - Soil containment Structure Construction Report and As-Built Documentation, September 2002". Report was submitted to Soldotna ADEC for engineering review.

Eileen Olson

3/3/2003

Update or Other Action

Soldotna office received "Togiak Fisheries Offsite Soil Treatment Facility Operations Plan" with cover letter by consultant to ADEC dated 2/18/2003.

Eileen Olson

3/14/2003

Update or Other Action

Rec'd "Addendum to 2002 Interim Remedial Action Measure Plan" dated March 12, 2003

Eileen Olson

3/25/2003

Update or Other Action

Reviewed the Addendum to the 2002 Interim Remedial Action Measure Plan. The original plan proposed excavation of contaminated soil in areas most likely to impact the adjacent surface water, was approved by ADEC on June 20, 2002. The addendum proposes background soil sampling and analysis for metals and total organic carbon (TOC). All groundwater monitoring wells will be replaced, developed and sampled. Samples will be analyzed for petroleum constituents and salinity. The subject addendum is approved with the following conditions: Soil samples analyzed for TOC should also be analyzed for gasoline range organics (GRO), diesel range organics (DRO) and benzene, toluene, ethylbenzene and xylenes (BTEX). Groundwater samples should also be analyzed for GRO and DRO. Additional background soil samples may be required.

Elizabeth Stergiou

4/2/2003

Update or Other Action

Changed longitude and latitude based on TopoZone interactive mapping website. Changed priority by selecting the multiple sources field to reflect site characterization information

Elizabeth Stergiou

4/21/2003

Update or Other Action

Letter by Paul Horwath, DEC engineer: Approval of the June 2002 Togiak Fisheries Evaporative Desorption Remediation Sampling and Analysis Plan.

Eileen Olson

4/29/2003

Update or Other Action

Letter from Brady Environmental to NOAA regarding NOAA recommendation to use sediment curtain for work ajdacent to the marine environment (re Togiak Fisheries Nationwide Permit #3).

Eileen Olson

6/17/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #1, May 22, 2003"

Eileen Olson

6/17/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #2, May 29, 2003"

Eileen Olson

7/2/2003

Update or Other Action

Rec'd June 5, 2003 "Togiak Fisheries Evaporative Disorption Remediation, Sampling Event #3"

Eileen Olson

7/2/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #4, June 12, 2003"

Eileen Olson

7/25/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #5, June 19, 2003"

Eileen Olson

8/8/2003

Update or Other Action

Rec'd "Third Party Sampling Report for Sampling Conducted on July 16, 2001" by Remtech Inc. (Same as Ganco).

Eileen Olson

8/15/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #8, July 24, 2003"

Eileen Olson

8/15/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #9, July 30, 2003"

Eileen Olson

8/18/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #6, July 3, 2003"

Eileen Olson

8/18/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #7, July 9, 2003"

Eileen Olson

9/4/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #10, August 7, 2003"

Eileen Olson

9/4/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #11, August 14, 2003"

Eileen Olson

9/4/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #12, August 20, 2003"

Eileen Olson

10/21/2003

Update or Other Action

Rec'd "Togiak Fisheries...Sampling Event #13, Sept. 21, 2003"

Eileen Olson

2/7/2004

Update or Other Action

Received Report Brady Environmental's "DRAFT Togiak Fisheries Remedial Action and Supplemental Site Characterization, Summer 2002/2003 Report...February 7, 2004" that documents 2002 and 2003 field season work. .

Eileen Olson

3/24/2004

Update or Other Action

DEC rec'd Brady Environmental's "Togiak Fisheries Final Remedial Action and Supplemental Site Characterization Report...March 17, 2004" that documents 2002 and 2003 field season work and was accompanied by a cover letter from NPSI dated March 22, 2004.

Eileen Olson

4/14/2004

Update or Other Action

Granted conditional approval for treatment and off-site disposal of soils, and requested a groundwater monitoring plan in response to NPSI's March 22, 2004 cover letter with attached report by Brady Environmental (see March 24, 2004 entry). The RP plans to treat by evaporative desorption approximately 7000 cubic yards of soil that are stockpiled at the site.

Eileen Olson

5/10/2004

Meeting or Teleconference Held

Staff met with Pat Brady, env. consultant, regarding plans for thermal treatment of excavated soil.

Eileen Olson

6/9/2004

Update or Other Action

Received "Togiak Fisheries Groundwater and Sediment Monitoring Plan...June 7, 2004" prepared by Brady Environmental, LLC with cover letter by RP dated June 9, 2004 indicating desire to begin work in late June.

Eileen Olson

6/10/2004

Update or Other Action

Rec'd July 2, 2004 "Togiak Fisheries Evaporative Disorption Remediation 2004 Sampling Event #1"

Eileen Olson

7/22/2004

Update or Other Action

Rec'd July 2, 2004 "Togiak Fisheries Evaporative Disorption Remediation 2004 Sampling Event #2"

Eileen Olson

9/9/2004

Update or Other Action

Rec'd "Togiak Fisheries Evaporative Disorption Remediation 2004, Sampling Event No. 3, August 6, 2004"

Eileen Olson

10/27/2004

Update or Other Action

Rec'd "Togiak Fisheries Evaporative Disorption Remediation, 2004 Sampling Events #4, #5 & #6 . . . October 2004."

Eileen Olson

1/14/2005

Meeting or Teleconference Held

Met with Jeff Backlund and attorney for Togiak Fisheries to discuss remaining work. RP requested and received a copy of the entire DEC file for the site.

Eileen Olson

1/18/2005

Update or Other Action

DEC letter sent to North Pacific Processors owner): approved Groundwater and Sediment Monitoring Plan and acknowledged change of consultants; new consultant to complete report for past consultant

Eileen Olson

3/27/2005

Update or Other Action

Received report "Togiak Fisheries Environmental Cleanup Project, 2004 Summary Report . . . April 2005." The purpose of the report was to document to the extent possible 2004 field activities by the former consultant, to summarize confirmation samples from 2004 evaporative desorption activiteis, and outline the remaining soil treatment and monitoring activities to be conducted at the site in 2005 and 2006.

Eileen Olson

5/25/2005

Update or Other Action

Sent invoice to NPSI for copying files pursuant to Public Records Act request

Eileen Olson

5/31/2005

Update or Other Action

Rec'd cover letter by NPSI with attached Technical Memo by consultant SLR outlining work for this season. Reviewed memo and discussed with consultant SLR. Work to include soil treatment using the on-site permitted thermal treatment system, groundwater monitoring and, if there is a break in the seawall, for example if erosion allows contaminated sediment to move into the intertidal environment, sediment samplling. The seawall is in good condition so far.

Eileen Olson

6/3/2005

Update or Other Action

Received on June 10, 2005 Thermal Remediation Facility Operations Plan form filled out by NPSI, dated 6/3/2005.

Eileen Olson

6/8/2005

Update or Other Action

Received on June 15, 2005 letter from NPSI dated 6/8/2005 clarifying issues related to the operation of an on-site remediation facility. That is, NPSI believes another contractor other than former contractor Brady Environmental may operate the remediation facility in accordance with the February 2003 Togiak Fisheries Offsite Treatment Facility Operations Plan subject to modifications outlined in the SLR memorandum of 5/31/2005.

Eileen Olson

6/10/2005

Update or Other Action

Rec'd faxed letter on 6/11/2005 from former environmental consultant Brady Environmental alleging that NPSI did not report a hazardous substance release and transported soil from an offsite facility to Togiak for remediation without notification to or approval by DEC.

Eileen Olson

6/13/2005

Update or Other Action

Faxed NPSI's "Thermal Operations Facility Operations Plan Applicant's Statement & Signature" (see 6/10/2005 entry) completed 1-pg form to Pat Brady of Brady Environmental upon request.

Eileen Olson

6/14/2005

Update or Other Action

DEC letter to NPSI recounting allegations in June 10, 2005 letter from former environmental consultant and requesting information regarding operations at Togiak. Attavched June 10, 2005 letter from former consultant.

Eileen Olson

6/28/2005

Update or Other Action

Ltr. to NPSI approving extension of time to provide information requested in ADEC letter dated June 14, 2005 (see June 14, 2005 entry). Letter followed up earlier emailed request by NPSI and DEC approval. New deadline set at August 15, 2005.

Eileen Olson

8/3/2005

Update or Other Action

Files sent out for copying for Roux Inc., representing insurance company.

Eileen Olson

8/8/2005

Update or Other Action

Rec'd email from consultant informing Dept. that treatment is continuing at Togiak, and NPSI is close to calling out the 3rd party sampler from Platt Environmental for the first confirmation sampling event. Request granted to store post-treated soil on a cement pad referred to as the basketball court, as it has been in the past.

Eileen Olson

8/16/2005

Update or Other Action

Rec'd detailed response from NPSI including sworn affidavits, a copy of a current lawsuit between NPSI and its former environmental consultant, barge operation logs and other documentation regarding Togiak operations intended to refute allegations by the former environmental consultant.

Eileen Olson

8/30/2005

Update or Other Action

DEC review letter sent to NPSI; Based on information received from NPSI on 8/16/2005 DEC accepts explanation regarding disparate estimates of soil processed at Togiak Fisheries and will not further investigate allegations set forth in June 10, 2005 letter from former environmental consultant.

Eileen Olson

9/13/2005

Update or Other Action

Rec'd letter from RP, NPSI, informing DEC that lawsuit is settled and NPSI intends to complete work.

Eileen Olson

9/13/2005

Update or Other Action

DEC letter sent acknowledging 9/13/05 letter from NPSI.

Eileen Olson

9/15/2005

Update or Other Action

Rec'd letter from consultant SLR and report for Sampling Event #1 for 2005 by consultant Platt Environmental. Letter advises DEC that a final report for the 2005 season will be forthcoming, and that an updated operations plan addendum for the 2006 field season will be submitted prior to reopening the facility in 2006.

Eileen Olson

2/23/2006

Update or Other Action

Received report "Togiak Fisheries, 2005 Incinerator Release, Site Assessment and Interim Corrective Action Report" dated January 2006 by environmental consultant SLR.

Eileen Olson

3/2/2006

Update or Other Action

Received Public Records Request (PRA) accompanied by DEC-required "Certificate of Nonlitigation Affiliation" from a Seattle law firm requesting an update to an earlier PRA request.

Eileen Olson

3/9/2006

Update or Other Action

Met with NPSI's Jeff Backlund, Corporate QA & Regulatory Affairs Manager and SLR representative to discuss 2005 remedial operations, planned work for 2006 and risk assessment plan to be submitted for site.

Eileen Olson

4/21/2006

Update or Other Action

DEC sent a letter with subject line "Review of "Togiak Fisheries 2005 Incinerator Release Site Assessment and Interim Corrective Action Report". The subject of the report was an approximately 260-gallon diesel release from valve on a line between a supply tank and incinerator discovered on August 1, 2005. Interim spill cleanup took place from September 23-26, 2005 and entailed the excavation of 700 cubic yards of soil, of which approximately 350 cublc yards were impacted and stockpiled pending future onsite thermal remediation. During excavation, groundwater was observed to be impacted. The impact to groundwater will be assessed pursuant to a work plan to be submitted. Soil cleanup above the water table is complete and soils meet the method 2 migration to groundwater level.

Eileen Olson

4/24/2006

Meeting or Teleconference Held

Teleconference between NPSI's consultant, SLR, and Department staff Earl Crapps, Marty Brewer and Eileen Olson regarding SLR's proposal to conduct a risk assessment for the approximately 5-acre Togiak Fisheries facility. Earl and Marty expect to review the risk assessment in-house. A tentative target date of the end of May was set to complete comment resolution for the risk assessment workplan, assuming the work plan is submitted promptly as indicated by SLR.

Eileen Olson

5/12/2006

Update or Other Action

Received Risk Assessment Work Plan "DRAFT WORK PLAN FOR A METHOD 4 HUMAN HEALTH AND SCREENING ECOLOGICAL RISK ASSESSMENT" dated May 2006.

Eileen Olson

5/26/2006

Update or Other Action

Risk assessment work plan review comments by Marty Brewer of DEC forwarded to NPSI and consultant SLR. Release of review comments followed request for additional clarification from consultant regarding the goals of the risk assessment and adequacy of data that supports the consultant's proposal that the shallow water at the site is non-potable by virtue of salinity.

Eileen Olson

6/1/2006

Update or Other Action

Received draft responses to DEC Risk Assessment work plan review comments from NPSI's consultant. Comment resolution meeting is expected to be held within a few days.

Eileen Olson

6/7/2006

Meeting or Teleconference Held

A comment resolution meeting and teleconference was held to discuss risk assessment work plan review comments and responses. DEC staff and representatives for NPSI and the environmental consulting firm SLR participated.

Eileen Olson

6/12/2006

Update or Other Action

ADEC transmitted draft record of comment resolution meeting and risk assessment workplan review comments to NPSI.

Eileen Olson

7/28/2006

Update or Other Action

Received "2006 Sampling and Analysis Plan, Togiak Fisheries, July 2006" that proposes stockpile sampling, monitoring well installation, etc.

Eileen Olson

7/31/2006

Update or Other Action

ADEC letter dated 7/31/2006 conditionally approved work plan received 7/28/2007.

Eileen Olson

8/3/2006

Update or Other Action

Received plan clarification letter in response to conditional approval letter of August 1, 2006 with subject line "2006 Sampling and Analysis Plan Conditional Approval and Clarifications".

Eileen Olson

8/4/2006

Update or Other Action

ADEC review letter sent this date approving revisions to SAP. The proposed revisions and information requested by the Department (DQOs etc) were received via email on 8/2/2006.

Eileen Olson

8/5/2006

Update or Other Action

Received revised plan: "2006 Sampling and Analysis Plan . . . August 2006" prepared by SLR. The plan objectives were to sample the ground water monitoring wells at the site as required in the current site monitoring plan; install and sample new monitoring/potential product recovery wells in the vicinity of the 2005 Incinerator heating oil release; sample the existing soil stockpiles for hydrocarbon constituents to support data for a quantitative risk assessment; sample surface water and sediment at the site boundary to support data collection for the 2005 risk assessment; and document site work and the findings in a summary report.

Eileen Olson

1/8/2007

Update or Other Action

Received draft risk assessment document (Title: "Method 4 Human Health and Screening Ecological Risk Assessment, North Pacific Seafoods, Inc., Togiak, Alaska." )

Eileen Olson

5/29/2007

Meeting or Teleconference Held

Risk assessment comment resolution meeting and teleconference held. Major topic of discussion was applicability of ProUCL versus bootstrap method.

Eileen Olson

8/10/2007

Update or Other Action

Received "2007 Sampling and Analysis Plan . . . August 2007".

Eileen Olson

8/14/2007

Update or Other Action

Received final risk assessment report "Method 4 Human Health and Screening Ecological Risk Assessment, North Pacific Seafoods, Inc., Togiak, Alaska . . . August 2007"

Eileen Olson

8/15/2007

Update or Other Action

Approved "2007 Sampling and Analysis Plan" rec'd 8/10.

Eileen Olson

9/17/2007

Exposure Tracking Model Ranking

Initial ranking with ETM completed for source area id: 71301 name: Surface spills - petroleum products

Pam Clemens

9/17/2007

Exposure Tracking Model Ranking

Intitial Ranking Complete for Source Area: 71301 (Autogenerated Action)

11/9/2007

Update or Other Action

ADEC letter approving risk assessment and discussing pendency of Conditional Site Closure for the Togiak Fisheries site. The letter advises North Pacific Seafood International (NPSI) that the risk assessment is approved and will be subject to institutional controls and other conditions to be set forth in Conditional Closure and Record of Decision documents that will be completed following ADEC receipt and review of the groundwater monitoring report and proposed groundwater sampling schedule.

Eileen Olson

12/13/2007

Update or Other Action

Received "2007 Soil and Ground Water Characterization Report, Togiak Fisheries, Inc., Togiak, Alaska, November 2007".

Eileen Olson

12/10/2008

Update or Other Action

ADEC staff met with consultant SLR and RP NPSI representatives to review draft closure documents and discuss conditions of site closure with institutional controls site status.

Eileen Olson

2/2/2009

Update or Other Action

ADEC received "Addendum to Method 4 Human Health and Screening Ecological Risk Assessment" dated February 2, 2009 that responded to ADEC's request that available environmental analytical data from all past site investigations be included in the risk assessment dataset.

Eileen Olson

2/4/2009

Update or Other Action

ADEC received a copy of consultant SLR's letter report to NPSI titled "Findings from ADEC Inquiry Regarding Remaining Contamination Togiak Fisheries Site, Togiak, Alaska" dated 2/4/2009. The report describes the changes made in the risk assessment addendum submitted on February 2, 2009 and the effect of those changes. SLR concluded that additional cleanup of the site is not warranted; the current contaminant site concentrations in the soil are below levels that may be expected to impact human health or ecological community health at the site; the target cleanup levels (TCLs) of 2,800 mg/kg benzene, 244,000 mg/kg gasoline range organics (GRO), 179,000 mg/kg diesel range organics (DRO) and 70,000 mg/kg residual range organics (RRO)presented in the risk assessment addendum are protective of human health and ecological community health; and all onsite soil concentrations are below these TCLs.

Eileen Olson

4/22/2009

Update or Other Action

ADEC received figures showing the estimated plume boundaries and previous excavation depths based on sample analytical results.

Eileen Olson

5/5/2009

Meeting or Teleconference Held

Staff met with two representatives of consulting firm SLR to discuss status of record of decision and site conditions including effect of changed risk assessment dataset and status of the three wells located along the boundary between the tidelands and Togiak Fisheries property that comprise the site. SLR will submit a report that includes the results for the August 2008 groundwater monitoring event within the next two weeks.

Eileen Olson

5/11/2009

Update or Other Action

Report received by hand-delivery “2008 Ground Water Characterization Report . . . May 2008” for Togiak Fisheries.

Eileen Olson

8/14/2009

Meeting or Teleconference Held

Meeting held to discuss terms of the Record of Decision (ROD) for the site. Attended by ADEC staff and NPSI and SLR representatives in person and via teleconference. Following the meeting SLR submitted by email a soil stockpile decommissioning plan proposing work in September 2009, with the comment that the ROD to be signed later would then refer to this in the past tense as a completed activity.

Eileen Olson

8/14/2009

Update or Other Action

Received plan for a placing a total of approximately 1,100 cubic yards of soil containing hydrocarbons in the 2005 incinerator release excavation, with additional soil to be spread elsewhere on the site.

Eileen Olson

8/28/2009

Document, Report, or Work plan Review - other

ADEC letter issued reviewing "Draft Togiak Fisheries Soil Stockpile Decommissioning Plan...August 2009." The letter notes that plan approval will be granted following receipt of a landspreading plan and if other conditions are met, including excavating below the groundwater table at the 2005 incinerator surface fuel release site to determine whether a sheen or free product are present on the groundwater surface, and whether a petroleum hydrocarbon smear zone is present below the high water level within the excavated area. ADEC also requested that the southern boundary of the property and locations of monitoring wells be surveyed if this has not been done.

Eileen Olson

1/6/2010

Update or Other Action

ADEC received a letter and two plans, submitted in advance of meeting planned for 1/11/2010: The letter dated January 6, 2010 has subject line "Response to ADEC Review, Draft Togiak Soil Stockpile Decommissioning Plan, August 2009". The plans are the "Togiak Fisheries Soil Stockpile Decommissioning Plan...January 2010" and "Togiak Fisheries Sampling and Analysis Plan, 2010 through 2012."

Eileen Olson

1/11/2010

Meeting or Teleconference Held

Staff met with consultant SLR and NPSI representative to review recent (Jan. 6) submittals and discuss schedule for proposed work to commence in June. ADEC and NPSI agreed that the Record of Decision will be completed following rather than prior to June 2010 work.

Eileen Olson

3/8/2010

Document, Report, or Work plan Review - other

Conditional approval granted for the "Togiak Fisheries Soil Stockpile Decommissioning Plan" received on January 6, 2010. The plan is a revision of the "Draft Togiak Fisheries Soil Stockpile Decommissioning Plan ... August 2009" in response to ADEC's review letter dated August 28,2009. The plan proposes removing clean fill from the 2005 spill excavation so that two feet of clean fill remains above the top of the zone of groundwater fluctuation; placing the contaminated soil from the 2005 spill into the excavation, and placing a minimum two-foot thickness of clean fill at the surface of the filled-excavation. Soil that is not placed in the excavation will be spread on the surface of the ground.

Eileen Olson

5/7/2010

Document, Report, or Work plan Review - other

DEC plan approval letter sent with subject line "Conditional approval of Togiak Fisheries Sample and Analysis Plan,Togiak, Alaska, 2010 - 2012" for the plan dated January 2010. The plan proposes sampling groundwater from nine monitoring wells at the site; collecting six pore water samples from intertidal sediment; rehabilitating two monitoring wells located beneath the dock that were installed in 2003 (RW-3R and RW-4R); and decommissioning 11 monitoring wells that do not include the nine to be sampled. The pore water samples will be collected during a low tide cycle.

Eileen Olson

6/2/2010

Update or Other Action

NPSI notified DEC that work would be done in accordance with the plans approved 3/8/2010 and 5/7/2010 from June 16 - 18, 2010. DEC staff had previously requested advance notice so that staff could travel to the site to observe field work. Work was delayed due to the airline losing equipment and was instead begun on June 20th. DEC staff was not on site during the June work.

Eileen Olson

6/24/2010

Update or Other Action

SLR provided DEC with updated status for site work completed by 6/23/2010 including (1) All wells scheduled for monitoring, with the exception of MW-B that was not accessible, were sampled; (2) Two wells (RW 3R and RW 4R) that were damaged or silted in were rehabilitated and sampled; (3) All Pore Water devices (PW-1 through PW-6) were installed and sampled. (4) A container barge is now anchored north of the dock starting at the northeast corner, so that the locations of two of the six pore water devices were modified.

Eileen Olson

7/30/2010

Update or Other Action

Consultant SLR submitted the "June 2010 Field Event – Letter Report, Togiak Fisheries, Togiak, Alaska" dated July 15, 2010. Field activities reported included pore water sampling, rehabilitation of two ground water monitoring wells, and ground water sampling from select monitoring wells. Activities were completed in accordance with the Sampling and Analysis Plan approved 5/10/2010. SLR personnel were on site between June 20, 2010 and June 23, 2010. Two of the six pore water sample results had detectable petroleum hydrocarbons: toluene at 0.117 milligrams per liter (mg/L) in sample location PW-4; and diesel range organics (DRO) in PW-4 at 1.11 mg/L.

Eileen Olson

8/12/2010

Update or Other Action

NPSI notified DEC that the remaining work proposed in the plan approved on May 7, 2010 would take place on September 7, 2010. DEC Quality Assurance Officer Brent Porter made arrangements to be on-site during the field work.

Eileen Olson

9/7/2010

Site Visit

ADEC's quality assurance officer made a site inspection at the Togiak fisheries site on September 7th, per the request of Eileen Olson and Rich Sundet. The quality assurance officer was accompanied by Jeff Backlund from North Pacific Seafoods and Andy Dimitriou and Aaron Nash from SLR consulting. While onsite we inspected the areas where known contamination had been present, replacement monitoring wells, pore water sampling locations, areas of recent excavation, and we observed monitoring well purging using a low flow technique. At the request of the project manager many site photos were taken and have been submitted to her on CD to be included in the project file that is in her posession.

Brenton Porter

9/21/2010

Update or Other Action

NPSI's consultant SLR notified DEC that the report for work done during the 2010 field season including the September 7, 2010 work, is in progress and that NSPI hopes to finalize the ROD for the site as soon as possible following submittal of the report.

Eileen Olson

12/22/2010

Update or Other Action

Received two reports; the "September 2010 Ground Water Monitoring Event - Summary Report" and the "September 2010 Stockpile Decommissioning - Summary Report" both dated December 22, 2010.

Eileen Olson

3/10/2011

Meeting or Teleconference Held

Staff met with NPSI and consultant SLR representatives to discuss remaining requirements in completing decision document proposed for Cleanup Complete/Institutional Controls status. Outstanding issues include how to depict historic contamination beneath the northern end of the spit. Staff and SLR agreed to work on modifying figure showing remaining contamination.

Eileen Olson

2/14/2012

Meeting or Teleconference Held

On 2/14/2012, Sundet met with Jeff Backund of North Pacific Fisheries and provided him with a hard copy of a revised draft closure document with institutional controls. Later on 2/14, Sundet emailed Jeff and Andy Demitriou of SLR with the draft document.

Rich Sundet

2/14/2012

Exposure Tracking Model Ranking

A new updated ranking with ETM has been completed for source area 71301 Surface spills - petroleum products.

Eileen Olson

3/22/2012

Spill Transferred from Prevention Preparedness and Response Program

Spill transferred by PERP staff Robert Carlson. Spill no. 05269915201; spill date = 6/1/2005; substance = diesel; quantity = unknown; description: Cannery staff left tank valve partially open after it was filled causing a slow leak for approximately 2 months. Note by project manager Eileen Olson: Site cleanup was handled under CS oversight in 2005 and results of cleanup were incorporated into subsequent documents regarding site status.

Mitzi Read

6/25/2012

Document, Report, or Work plan Review - other

ADEC letter issued "Conditional approval of Draft Togiak Fisheries Sampling and Analysis Plan, 2012 through 2013".

Eileen Olson

6/28/2012

Update or Other Action

Following receipt of comments on a previous draft decision document from the responsible party, NPSI, ADEC updated the draft decision document for Cleanup Complete with Institutional Controls (CC/IC) status and on 6/28/2012 provided NPSI with a draft deed notice (NEC - Notice of Environmental Contamination) and all figures referenced in the decision document.

Eileen Olson

8/7/2012

Cleanup Complete Determination Issued

In granting cleanup complete with institutional controls status, ADEC considered site specific conditions including the lack of accessibility to contamination remaining from major fuel releases in the 1980s, much of which is located beneath structures constructed on pilings; the fact that extensive so urce removal of approximately 7,650 cubic yards of petroleum hydrocarbon contaminated soil took place from 2001 to 2005; and the status of health and ecological exposure pathways following cleanup activities that included 'exposure controlled', 'de minimis' exposure, and 'low potential' ecological exposure. Although a contaminant smear zone is present in soil and sediment beneath and adjacent to cannery facility structures, pore water sampling and groundwater monitoring indicate that contaminant migration is not occurring.ADEC did not approve alternative cleanup levels for the site. The site cleanup levels for hazardous substances in site soil are set by 18 AAC 75.341, Method Two, Tables B1 and B2, Migration to Groundwater for the over 40-inch (precipitation) zone. ADEC cleanup levels for groundwater are set by 18 AAC 75.345, Groundwater and surface water cleanup levels, Table C.

Eileen Olson

8/24/2012

Document, Report, or Work plan Review - other

ADEC review letter declining to approve plan dated August 23, 2012 for soil disposal of small quantity (<1 cy) of contaminated soil in an area of the site not designated for disposal. Suggested alternatives including the possbility of remediating the soil in a biopile.

Eileen Olson

9/6/2012

Institutional Control Update

Received signed "Attachment A: Cleanup Complete - ICs Agreement Signature Page" dated 9/6/2012 from Togiak Fisheries.

Eileen Olson

9/10/2012

Institutional Control Record Established

Institutional Controls established and entered into the database.

Eileen Olson

10/10/2012

Update or Other Action

Received report for monitoring done according to decision document conditions: "Togiak Fisheries 2012 Groundwater Sampling Report, Twin Hills, Alaska...October 2012" prepared by SLR for work done on August 15-16, 2012. Work documented in the report includes decommissioning of monitoring well MW-B; installation of one replacement monitoring well in the vicinity of MW-B; collection of groundwater samples from specified monitoring wells; and documenting groundwater sampling activities and the findings in a summary report. Groundwater samples were collected from eight monitoring wells with analyses for BTEX and for specific wells, either DRO or GRO. Monitoring well RW-4R contained insufficient water and was purged dry prior to parameter stabilization.

Eileen Olson

6/17/2014

Document, Report, or Work plan Review - other

ADEC review letter issued in response to fall 2013 request by NPSI to cease monitoring and decommission the 9 monitoring wells at the site that are subject to the long-term monitoring requirements of the decision document dated August 7, 2012. The review letter approves decommissioning of 4 of the 9 monitoring wells and requires that by July 31, 2015, NPSI replace a monitoring well that could not be sampled due to an obstruction for the two monitoring events since the decision was issued, and sample that replacement well and the other four wells after and within three hours of low tide.

Eileen Olson

1/5/2015

Meeting or Teleconference Held

Staff met with NPSI and consultant representatives to discuss requirements of ADEC 6/17/2014 letter; consultant will provide a brief work plan before installation of one replacement groundwater monitoring well and groundwater monitoring event to take place in 2015.

Eileen Olson

4/3/2015

Document, Report, or Work plan Review - other

ADEC conditionally approved the "2015 Togiak Fisheries Sampling and Analysis Plan, Twin Hills, Alaska" dated March 20, 2015.

Eileen Olson

9/22/2015

Update or Other Action

ADEC received SLR report dated 9/21/15 "2015 Groundwater Monitoring and Decommissioning Report" with cover letter and appendices (via email).

Eileen Olson

1/15/2016

Meeting or Teleconference Held

ADEC staff met with representatives of NPSI and consultant SLR representative to discuss project status including ADEC preparation of an addendum to the 2012 decision document that makes a record of the conditions of the decision document that have now been met. Following the meeting ADEC determined that a Notice of Environmental Contamination has not yet been filed. ADEC will update the NEC and file it at the same time the addendum is completed.

Eileen Olson

11/14/2017

Institutional Control Update

ADEC received letter dated November 6, 2017 that fulfills IC condition of August 7, 2012 Decision Document regarding periodic reporting of land use and ownership status: Letter states there have been no changes in ownership or land use of the site.

Eileen Olson

6/14/2018

Institutional Control Compliance Review

IC compliance review conducted. Staff changed from Eileen Olson to IC Unit. Closure/IC Details added to reflect the institutional controls outlined in the 2012 Decision Document.

Kristin Thompson

Contaminant Information

Name	Level Description	Media	Comments
GRO	Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation	GroundwaterSoilSoilGroundwaterGroundwaterSoil

Name

Level Description

Media

Comments

GRO

Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation

GroundwaterSoilSoilGroundwaterGroundwaterSoil

Control Type

Type	Details
Notice of Environmental Contamination
Signed CS Determination

Type

Details

Notice of Environmental Contamination

Signed CS Determination

Requirements

Description	Details
Groundwater Use Restrictions	Groundwater is currently not used at the site and may not be used in the future for any purpose including drinking water or food processing without prior ADEC plan review and approval. Any use of the groundwater including placement of additional monitoring wells requires prior review and approval by ADEC.
Other	ADEC must be notified if NPSI becomes aware that groundwater use is taking place or is proposed within 600 feet of NPSI's only landward property boundary.
Other	The current owner and/or other party responsible for the site shall report to ADEC every five years to document land use, or report as soon as they become aware of any changes in land ownership and/or use.
New Construction Restrictions	Prior to construction of any structure intended for human occupancy, submit for ADEC approval an updated Conceptual Site Model and supporting documentation that potential exposure pathways have been abated or mitigated, shown to be incomplete, or otherwise determined not to pose an unacceptable risk to human health.
When Contaminated Soil is Accessible, Remediation Should Occur	ADEC may require characterization and/or cleanup of areas that become accessible through removal or alteration of structures.
Excavation / Soil Movement Restrictions	NPSI shall provide a plan to ADEC at least 30 days prior to conducting any activities at the site, including within the adjacent tidelands, that could reasonably be expected to result in disturbance of contaminated soil or sediments or that could render accessible soils previously inaccessible including earthmoving, excavating, filling, dredging, building, dock or piling demolition.
Advance approval required to transport soil or groundwater off-site.	Standard condition.
Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)	Standard condition.

Description

Details

Groundwater Use Restrictions

Groundwater is currently not used at the site and may not be used in the future for any purpose including drinking water or food processing without prior ADEC plan review and approval. Any use of the groundwater including placement of additional monitoring wells requires prior review and approval by ADEC.

Other

ADEC must be notified if NPSI becomes aware that groundwater use is taking place or is proposed within 600 feet of NPSI's only landward property boundary.

Other

The current owner and/or other party responsible for the site shall report to ADEC every five years to document land use, or report as soon as they become aware of any changes in land ownership and/or use.

New Construction Restrictions

Prior to construction of any structure intended for human occupancy, submit for ADEC approval an updated Conceptual Site Model and supporting documentation that potential exposure pathways have been abated or mitigated, shown to be incomplete, or otherwise determined not to pose an unacceptable risk to human health.

When Contaminated Soil is Accessible, Remediation Should Occur

ADEC may require characterization and/or cleanup of areas that become accessible through removal or alteration of structures.

Excavation / Soil Movement Restrictions

NPSI shall provide a plan to ADEC at least 30 days prior to conducting any activities at the site, including within the adjacent tidelands, that could reasonably be expected to result in disturbance of contaminated soil or sediments or that could render accessible soils previously inaccessible including earthmoving, excavating, filling, dredging, building, dock or piling demolition.

Advance approval required to transport soil or groundwater off-site.

Standard condition.

Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)

Standard condition.

Decision Document - Cleanup Complete with ICs

No associated sites were found.

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Alaska Department of Environmental Conservation

Site Report: Togiak Fisheries

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

Decision Document - Cleanup Complete with ICs

Missing Location Data

State of Alaska Department of Environmental Conservation