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Site Report: Port Heiden SS006 POL Pipeline


Site Name: Port Heiden SS006 POL Pipeline
Address: Pipeline Corridor AOC05, Port Heiden, AK 99549
File Number: 2637.38.002.02
Hazard ID: 179
Status: Active
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 56.924395
Longitude: -158.662166
Horizontal Datum:NAD83

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.

Problems/Comments

Fuel releases associated with the fuel pipeline extended from the composite building to the petroleum, oil, and lubricants (POL) tanks about 4 miles southwest of the composite building. The pipeline from the POL tanks (near the old village) to the airport was transferred to Reeve Aleutian Airways The pipeline between the airport and the former composite building (former White Alice Communication System) has been dismantled Study Area called Former Pipeline Corridor (SS006) includes the POL Pipeline. Formerly known as AOC05. This Former Pipeline Corridor has subsites: above ground portion from the Marine Terminal Area to the Former Facility Area and the buried portion within the Former Facility Area. RCRA EPA ID#AK0210890091 Hazardous waste activity: generator 1. CERCLA AK8570028698; Site located about 100 miles NE of Cold Bay, on the north side of Alaska Peninsula.

Action Information

Action Date Action Description DEC Staff
8/1/1979 Update or Other Action On August 1, 1979, Air Force leased a 210,000 gallon fuel storage tank, associated pipeline and fuel pumping station to Reeve Aleutian Airways, Inc. Louis Howard
9/30/1986 Update or Other Action The Air Force notified Reeve, the lease for the 210,000 gallon fuel tank , associated pipeline, and fuel pumping station would not be renewed. The threat of an oil spill, due to beach erosion in the vicinity of the tanks and structural distress, was a major concern. Reeves was informed the storage tank and piping was scheduled for demolition/removal. The Corps of Engineers (COE) was scheduled to perform cleanup of the Fort Morrow Army Station and other Army locations in the Aleutian Islands. To save mobilization costs, the Air Force authorized the COE to include Port Heiden cleanup in their Defense Environmental Restoration Program (DERP). Louis Howard
2/11/1987 Update or Other Action Reeve Aleutian Airways, Inc. Letter to Betty Chandler, Alaska Air Command/DEPE, Elmendorf AFB, AK 99506 RE: Port Heiden Contract #DACA 85-1-86-23 Fuel Storage Tank and related. REEVE understands that the planned facilities clean-up scheduled for the fall/winter (1987) of this year includes: demolition and removal of the fuel storage tanks, pumping station, and fuel lines. Reeve agrees that the removal of the fuel storage tank is necessary; that the continued beach erosion represents a potential for pollution liability. Reeve respectfully requests that the Alaskan Air Command not remove the existing fuel line and continue our past lease arrangements for use of this line. If this is not possible, please advise what alternatives are available and what steps must be taken to arrange continued use of the fuel line. Signed David A. Jensen, Administrative Vice President. Louis Howard
3/31/1987 Update or Other Action Air Force advised Reeve they would have to acquire an interest for the POL pipeline right-of-way from BLM or the future owners of the property. The Air Force had no specific land interest for the POL pipeline. Their land interest was a notation on the public record for a road right-of-way acquired in 1957. The Air Force placed the pipeline within the road ROW. Louis Howard
1/15/1988 Update or Other Action The Air Force offers up the tanks, associated pipeline and pumping station for sale through the COE invitation bids. Reeve purchased the fuel storage tank. There were no bids on the other equipment. Louis Howard
2/19/1988 Update or Other Action USACE Real Estate Division, Management and Disposal Branch letter to Reeve Aleutian Airways, Inc Mr. David A. Jensen. On February 3, 1988, your bid offer of $500.00 for the fuel tank no. 1105A located at Port Heiden, was awarded as the high bid sold under Inivitation for Bids no. 88-1. Receipt is hereby acknowledged for your checks to cover the balance of your bid offer of $400.00 and the required performance bond deposit of $1,500.00. Take this letter and your enclosed Contract No. IFb 88-1 to Real Property Officer, Elmendorf Air Force Base, Alaska, (Bldg. 21-048 Telephone No. 552-2128) where you will be informed of the location of any possible underground utilities that may be necessary for the excavation work required. Also at this time, you will be informed of the location of the fill material available. After receiving the necessary clearances and authority to commence work, you may then proceed with removal operations. Although the fuel tank purchased is considered empty, it does contain residual amounts of fuel and sludge and the tank will require purging if attempts are made to use cutting torches to affect removal. Your attention is invited to Condition no. 7 of your contract, which requires that all disposal and restoration work be comleted on or before May 31, 1988 and that no extensions of time will be granted except for "unusual and unforseeable circumstances". Signed Dennis E. Klein, Chief, Real Estate Division. Louis Howard
4/8/1988 Update or Other Action USACE Memo for: Cdr, 21st Combat Support Group, ATTN: Real Estate (Beal), Bldg. 11-530, Elmendorf AFB, AK 99506-5000 Subj: Port Heiden Underground Fuel Pipeline (3") 33,000 LF. 1) The Alaska District, Corps of Engineers, geotechnical personnel have visited the site at Port Heiden as part of a hazardous toxic waste evaluation. No evidence of polychlorinated biphenyls or asbestos contamination of the pipeline was identified. No samples of the pipeline were taken to confirm this (statement) since there was no reason to suspect contamination. 2) This information is provided per discussions between Mr. Carey Meyer of our Project Management Branch and Mr. Leroy Marcus of our Real Estate Branch to allow for the pipeline to be purchased by interested parties. Signed Harlan E. Moore, Chief, Engineering Division. Louis Howard
4/26/1988 Update or Other Action AF Form 300 Facility Disposal, Facility 1104 (Portion), Liquid Fuel Pipeline, Port Heiden RRL, Alaska. 1) Forwarded for continuance of action is AF Form 300, for the sale, removal of a portion of the Liquid Fuel Pipeline located at Port Heiden RRL, Alaska. 2) The pipeline has not been in use since the site was deactivated in 1978; therfore, it has not been flushed and may contain residual oil. 3) It is imperative that precautionary action be taken by the successful bidder to avoid the possibility of a fuel spill while the pipeline is being removed. Any fuel that is left in the pipeline should be removed and disposed. 4) The Department of Air Force will not be held responsible for damages to the property or injuries to persons that may be involved in removal operation while in the area.. Signed Warren Page Colonel, USAF, Base Civil Engineer. Louis Howard
6/15/1988 Update or Other Action Reeve bid: Invitation No. 88-3 Port Heiden Air Force Base, Alaska dated June 15, 1988 to the District Engineer US Army Engineer District, Alaska ATTN: Real Estate Division, PO Box 898, Anchorage, AK 99506-0898. Reeve Aleutian Airways, Inc. hereby offers to purchase from the United States of America, subject to the terms and conditions and in accordance with the instructions to bidders contained in invitation for bids No. 88-3, attached hereto and made a part hereof, any or all of the items described below for which bid prices are indicated, in consideration of the price indicated for each such item. Bldg/Fac. No. 1104B Pipeline (30,830 LF) Performance Bond Deposit $1,500.00 Amount of Bid: $501.00. Note: Facility 1104B consists of a 30,830 linear-foot portion of pipeline. Enclosed is a certified check, cashier's check, traveler's check, or postal money order payable to the order of FAO, USAED, Alaska, in the amount of $100.00 U.S.). Signed by David A. Jensen, Vice President May 23, 1988. Louis Howard
6/21/1988 Update or Other Action The Air Force readvertises the pipeline and pump station for sale, Reeve purchased the 30,830 foot pipeline through COE contract sale. Certified mail from Dept. of the Army, US Army Engineer District, Alaska, PO Box 898 Anchorage, AK 99506 Real Estate Division, Management and Disposal Branch to Mr. David A. Jenson Administrative Vice President, Reeve Aleutian Airways, Inc. You have been determined to be the successful bidder under Invitation for Bids No. 88-3 for the purchase AND OFF-SITE REMOVAL of 30,830 linear feet of pipeline no. 1104B, located at the Port Heiden Radio Relay Site, Alaska. The total bid offer was $501.00, and you submitted a bid deposit of $100.00. The $401.00 balance of the bid price and performance bond in the amount of $1,500 are now due. Your attention is invited to Condition Nos. 5 and 8 of the Invitation for Bids, which requires that the purchase price balance and performance bond be submitted within seven days from receipt of this letter. Failure to comply with these terms and conditions may result in forfeiture of your bid deposit. Signed Dennis E. Klein, Chief, Real Estate Division. (Paid by check #9200 on 06/27/1988). The contract specified the pipeline was to be moved off-site. Reeve did not relocate the pipeline. Reeve acquired land interests from the land owners for the ROW. Louis Howard
1/31/1989 Update or Other Action The Air Force conducts a site inspection and sent a letter to the COE stating Reeve had complied with the terms of the sale for the fuel tank and with the terms of the sale of the pipeline, including off-site removal. Louis Howard
2/8/1989 Update or Other Action USACE Memo for: Commander, 21 CSG/DEER, Elmendorf AFB, AK 99506-5000 Subj: Submittal of AF Forms 300 for Disposal of Facilities at Port Heiden Radio Relay Site, Alaska. 1) Forwarded are signed copies of AF Forms 300 for disposal of the two fuel tanks and fuel pipeline (30,830 LF) sold under Invitation for Bids Nos. 88-1 and 88-3. 2) Also enclosed are AF Forms 300 for a pump station and 510 LF of fuel pipeline. These facilities were advertised in the aforementioned IFBs, but no offers were received. Signed Lucille E. Steelman, Acting Chief, Real Estate Division. Louis Howard
11/15/1989 Update or Other Action In late 1989, the COE awarded the cleanup contract to Underwater Construction and Associates, Inc. (UC&AI), of Anchorage. Before field work, UC&AI) submitted a quality assurance project plan, health and safety plan, hazardous waste handling plan and revegetation plan. Louis Howard
4/30/1990 Site Visit Representatives of the COE, ADEC and contractors visited the site. They observed that the City of Port Heiden had removed the 20,000 gallon fuel tanks from the northeast side of the composite building for the city's use. The remaining hole in the ground contained standing water that had a fuel sheen. A 30,000 gallon fuel tank shown on the bid documents was not located in 1990. John Halverson
5/1/1991 Update or Other Action During site restoration by the COE, the COE claimed there were sections of the pipeline between the runway and White Alice sites which had been cut. These sections showed that residual fuel had leaked on the ground. The section of pipeline was a portion of the 30,830 foot pipeline purchased by Reeve. Reeve had reported the spill to the Alaska Department of Environmental Conservation. At the time, Reeve stated they were not aware of this section of the pipeline was included in the sale by the COE. They used the pipeline from the beach unloading area to the runway. Reeve accepted responsibility for any cleanup needed in the pipeline right-of-way. They will either contract with the COE contractor on the site to do the cleanup, or they will find another contractor if the COE contractor is unable to undertake the job. COE claimed Reeve violated the terms of the sale agreement by not removing the pipeline from the Air Force road ROW. The COE reported the alleged violation to the OSI to investigate possible contract fraud. Louis Howard
9/10/1991 Update or Other Action USACE memo for: Commander, 21 CSG/DEER, 22040 Maple Street, Elmendorf Air Force Base, Alaska, 99506-3240 SUBJ: Sale of Fuel Pipeline under Invitation for Bids (IFB) No. 88-3 to Reeve Aleutian Airways, Inc. Port Heiden Radio Relay Station, Alaska. The above contract required the successful bidder to remove the pipeline from Air Force property and restore the site satisfactorily. Upon receipt of notice dated 19, January 1989 from your office that the terms and conditions of the contract. Louis Howard
9/24/1991 Update or Other Action Dept. Of The Army, US Army Engineer District, Alaska, PO Box 898, Anchorage, AK 99506 Office of Counsel letter to David A. Jensen Administrative Vice President Reeve Aleutian Airways, Inc. RE: Two-inch Petroleum, Oil, Lubricant (POL) Pipeline at Port Heiden, Alaska. In our meeting with you, it was indicated by you that your company's intent from the outset was to buy the pipeline and to continue using most of it in place. You also alluded to certain related lease arrangements you have made with the current owners of the underlying land reaching from the Meshik townsite to the beach. You mentioned you were aware of the reported leaks in that system and that you are working closely with the Alaska Dept. Of Environmental Conservation to correct those problems. The portion of the pipeline which runs from the airport to the former site of the radio relay station is not being used by your company. You indicated this segment, approximately 1.7 miles of the pipeline was inadvertantly left in place. The notes from the meeting reflect you now intend to correct this oversight by removing all segments of pipe you are not using and performing any required cleanup. This letter is intended to accurately reflect representations you made on behalf of Reeve Aleutian Airways Inc. If you disagree with my account, please respond with your objections, comments or addtions. Signed M. Susan Fink, Assistant District Counsel. Louis Howard
9/27/1991 Update or Other Action Reeve letter to M. Susan Fink, Dept. of Army, US Army Engineer District, Alaska, PO Box 898, Anchorage, AK 99506. I have reviewed your letter dated 24, September 1991 and find that you accurately state my representations. Since our meeting, I have instructed our environmental engineers, Hart Crowser, to define and develop a scope of work for removing the approximately 1.7 miles of pipeline. They will submit the project plans to the State of Alaska Department of Environmental Conservation for project approval. After receiving DEC cleanup approval, I will contact Underwater Construction and hopefully negotiate a contract to clean up the referenced pipeline segment in accordance with the DEC approved plan. I also will, as represented to you, not cause any adverse impact on the time sensitive nature of your contract with Underwater Construction. With regard to expressions of contract interpretations raised in our meeting, please direct any further concerns to my attention. Signed David A. Jensen, Vice President of Administration. Louis Howard
4/9/1992 Update or Other Action EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses. I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region 10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion. Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992. Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92 JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92. Screening Values for Water RBCs based on Ingestion, Residential Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000 JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700 JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000 Screening Values for Soils- RBCs Based on Soil Ingestion Residential Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000 JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000 JP-4 Risk 10-6 10-4 NA, HQ = 20,000 USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X. This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). Jennifer Roberts
9/30/1992 Update or Other Action From 1990 to 1992, COE contractors demolished the site, and removed hazardous wastes and PCB- and petroleum-impacted materials. Because the bulk of the debris and hazardous materials at Port Heiden was of DOD origin, and "ownership" could not be clearly distinguished among periods of use-World War II, WACS site, and the FAA-the COE combined all areas into a DERP cleanup from 1990 to 1992. Louis Howard
6/1/1993 Update or Other Action Hart Crowser report for Mr. Robert Hanson of Frosty Fuel Company for three areas: Site 1, Site 2 and Site 3. Site 1 is the pipeline located approximately 20 ft. from the main road underneath a driveway. Site 1(near SS05 POL Tank Farm formerly AOC06) lies along the active portion of the line. Site 2 lies along the inactive portion of the pipeline. At this site, a 75ft. segment of the pipeline was removed by an unknown person sometime prior to September 1991. When the pipeline was cut, an unknown amount of Jet-A 50 spilled out of the south side of the pipeline break. Site 3 lies along the active portion of the pipeline. At this site, an unknown, but probably small quantity of Jet-A 50 leaked from the pipeline. First report of the spill was on April 12, 1992. This site is situated in a muskeg swamp. Pipeline abandonment-The inactive portion of the fuel pipeline, extending from the airport north to the former White Alice Site, was closed between August 25 and 28, 1992. Aboveground pipeline segments were cut into pieces and sorbent pads were used to collect any spillage. Underground segments were abandoned in place by capping each segment where they emerged from the subsurface. Louis Howard
1/31/1994 Update or Other Action CH2MHILL Preliminary Assessment (PA) Contract No. DACA85-92-D-0007 Delivery Order 0007 completed. This document is the first step in the investigative process under the National Contingency Plan (NCP). It involves a review of existing information and an offsite reconnaissance, if appropriate, to determine whether a release requires additional investigation or action under CERCLA. A fuel pipeline ran along the road system from two aboveground fuel tanks (whose size varies in descriptions as 250,000 or 100,000 gallons) at Meshik to the airport and then to the WACS site. The pipeline (3 inches and 33,000 linear feet) was alternately buried and laid on top of the ground. According to the COE project manager, the two large tanks (assumed capacity of 250,000 gallons each) were filled twice each year. No information is available about how much fuel was transported by pipeline or truck to the WACS site. At the time of the demolition of the WACS site, Reeve Aleutian Airways had reconnected the pipeline to new tanks and was using the segment of pipeline from Meshik to the airfield. Pipeline ownership of that segment was changed from DOD to Reeve Aleutian Airways. Louis Howard
4/12/1994 Update or Other Action EPA Region 10 sent letter to USAF Lt. Colonel Rodney L. Hunt 11th CEOS. The letter was to inform the Air Force that EPA Region 10 has completed the review of the Preliminary Assessment (PA) report for the Port Heiden White Alice Communication site located near Port Heiden, Alaska. The PA and supplemental information have been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the facility does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information to be proposed for the NPL, EPA must reevaluate your facility accordingly. EPA's NFRAP designation does not relieve your facility from complying with appropriate Alaska state regulations. The Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 120(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. Mark Adar Federal Facilities, Site Assessment Manager. Louis Howard
3/13/1996 Update or Other Action PA/SI received. AOC05 (fuel pipeline) The fuel pipeline extended from the composite building to the petroleum, oil, and lubricants (POL) tanks about 4 miles southwest of the composite building The pipeline from the POL tanks to the airport was transferred to Reeve Aleutian Airways The pipeline between the airport and the former composite building has been dismantled. The pipeline corridor has not been evaluated for potentially impacted areas. A site inspection and soil sampling are recommended along the pipeline corridor. John Halverson
12/29/1997 Update or Other Action Management Action Plan DACA85-95-D-0010, D.O. No. 16 is intended to be a strategic document integrating the Environmental Restoration Program {ERP) into a series of response actions necessary to protect human health and the environment. Due to the dynamics inherent in the strategic planning process, the MAP represents a "snapshot" in time, requiring periodic updating to remain useful. This MAP does the following: • Describes the environmental response objectives, the MAP purpose, and a brief history of the installation (Chapter 1), Identifies all known contaminated sites; environmental condition of property; real property, off-base facilities and properties; and non-Air Force tenants (Chapter 2); Summarizes the status of the Installation Restoration Program (IRP) and regulatory agreements (if applicable); IRP Sites; Areas of Concern (AOCs); and community relations program Chapter 3); Describes the installation-wide strategy for environmental restoration through the definition of zones (including current scope of removal and remedial activities associated with, or to be completed for, each), and contracting and hiring strategy (Chapter 4), and • Provides a Master Schedule of planned and anticipated activities to be performed throughout the duration of the ERP(Chapter 5). All areas at the Port Heiden RRS have been assigned to one of seven environmental condition of property categories based on site characterization and remediation efforts to date. AOC05 (SS006): Category 7. Areas that are unevaluated or require add)tional evaluation. Areas at the Port Heiden RRS installation in this category are the Fuel Pipeline (AOC05) and the Septic Tank And Outfall Area (AOC04). Installation areas and individual sites were categorized for mcluslon in one of the above seven categones by: • Review of real property records, land use maps, and aerial photographs to identify histoncal land uses; • Review of IRP studies and field investigations to identify areas where the presence (or absence) of contamination had been confirmed; • Revlew of recorded chain-of-title documents to assess whether any prior uses could reasonably contnbute to existing environmental concerns; Review of installation areas where industrial operations occurred; solid and hazardous wastes were stored, disposed, or released; and hazardous material storage sites; and • Review of records from industrial shops, supply stores, and fire departments. Louis Howard
11/2/1999 Site Added to Database Petroleum releases associated with the pipeline. Gretchen Pikul
1/30/2001 Update or Other Action Final Site Investigation, Port Heiden RRS, Alaska (dated July 2000) – no draft version was received for ADEC review prior to the final version being submitted – this investigation was performed to update the relative risk evaluation for select sites at Port Heiden and Driftwood Bay RRS, however, a rock slide blocked access to 2 of the sites at Driftwood Bay and therefore the investigation was not conducted at 2 of the selected sites – pending funding, the samples may be collected this field season Gretchen Pikul
6/13/2002 Update or Other Action DEC received a fax and letter from the Lake and Pennisula Borough and the City of Port Heiden about a phone call from an annonymous worked who reported dumping drums of hazardous material into a trench on the northwest side of the former White Alice site and that the chemicals could cause health problems for the villlagers. The letters requested DEC assistance in following up on the call and ensuring the former military sites are cleaned up properly. John Halverson
6/19/2002 Update or Other Action DEC sent letter to the Corps of Engineers and the 611 CES (Air Force) informing them on the community concerns and asking for cooperation in compling the site records, conducting a site inspection and community meeting, and ensuring the sites are adequately characterized and cleaned up. John Halverson
9/5/2002 Meeting or Teleconference Held DEC staff conducted a site inspection and particpated in a public meeting with the Corps of Engineers and the 611 CES (Air Force). Many residents expressed concern over health problems and their thoughts that there may be a link between past military activities and health problems. Scott Anderson, Tribal Environmental Coordinator and Lynn Carlson helped coordinate the meeting and site inspections. The surface cleanup work appears to have been very thorough and the landfills are adequately covered. Subsurface characterization is needed. Residents want their water wells sampled and had applied for a grant from TASWER to conduct the sampling. DEC, the Corps and Air Force staff said they would work together to help get wells sampled. One resident had an unexploded ordnance (UXO) item (appeared to be a 20MM projectile) in their house. John Halverson
9/9/2002 Update or Other Action Staff contacted the Army Explosive Ordnance Disposal (EOD) team at Fort Richardson regarding the ordnance item in a residence at Port Heiden. The EOD representative (Sgt. Bryant 384-7603) said they were willing to go out and destroy the item, if the home owner wanted. DEC staff coordinated with the village and EOD to dispose of the item. John Halverson
9/18/2002 Update or Other Action After conducting the site visit earlier this month, staff researched options for groundwater characterization at Port Heiden and found out the the City of Port Heiden is on the Village Safe Water program's list for a Water and Wastewater Feasibility Study in FY03. The scope calls for evaluating the current systems, the aquifers, water use and estimated future needs. It may include some limited testing, but not sampling 30 wells; it is a civil works project rather than environmental. Staff is working with the Corps of Engineers to sample existing wells under the Native American Lands Environmental Mitigation Program (NALEMP). John Halverson
4/30/2003 Meeting or Teleconference Held DEC and the Air Force participated in a public meeting at Port Heiden to update the community on Air Force plans for conducting remedial investigation work in 2004 and completing a proposed plan, record of decision and implementing a remedy by 2007. The Corps does not have work planned for Fort Morrow until 2011, but will re-evaluate the schedule based on any new information (water well sample results). John Halverson
6/5/2003 Update or Other Action Keres Environmental is sampling all water wells in Port Heiden under the Native American Lands Environmental Mitigation Program (NALEMP). Sampling plans were reviewed by DEC and the Corps and each well will be tested for VOC, PAHs, PCBs, and metals. Sampling will be conducted during the first week of June and results are anticipated by early August. John Halverson
4/27/2005 Meeting or Teleconference Held WESTON Meeting Summary of April 27 2005 RE: Port Heiden Remedial Action Objectives. The Air Force held a meeting at the office of Weston Solutions on 27 April 2005 to discuss upcoming cleanup activities at the former Port Heiden Radio Relay Station (RRS). The discussion provided a summary of the contamination found during the 2004 Remedial Investigation (RI) and presented some of the alternatives that were being considered for cleanup of the site. The meeting was held to initiate discussion with stakeholders not present at the community meetings in Port Heiden but with property ownership or interests on or near the RRS. These included representatives of the State of Alaska Department of Transportation (AKDOT), the Alaska Peninsula Corporation, and the Bristol Bay Native Corporation (BBNC). One of the goals of the meeting was to determine what Remedial Action Objectives (RAGS) would be acceptable to the stakeholders. In attendance were Larry Underbakke (61lth CES/CEVR), James Kiasen (l1th Air Force JAV), Mark Goodwin (AFCEE), Ralph Angasen Sr. (Alaska Peninsula Corporation), Sam Fortier (Attorney for Alaska Peninsula Corporation), Tiel Smith (BBNC), Jack Moore (BBNC), Jacques Gusmano (United States Environmental Protection Agency [USEPA]), John Halverson (Alaska Department of Environmental Conservation [ADEC], Bob Thomas (AKDOT), Ron Stroman (AKDOT), Scott Blount (Weston Solutions), Leslie Boughton (Weston Solutions), and Russ Beck (Weston Solutions). A copy of the participant record is attached to this meeting summary. The meeting began with discussion of property ownership and a review of property maps. It was confirmed that the majority of the Former Facility Area (former location of the antennas and composite building) is located on AKDOT property. Some portions (such as the RRS landfill and septic outfall) are located on Native Corporation land (surface rights belong to Alaska Peninsula Corporation and subsurface rights belong to BBNC). It was discussed whether the Air Force had the option of buying the property from the AKDOT. The AKDOT indicated that the State would be willing to convey the property to the Air Force and it should be considered and option in the Feasibility Study (FS). Mr. Underbakke and Mr. Blount then provided a summary of the contamination found during the 2004 RI. They indicated that all of the information being presented would be provided in the Final RI/FS, which would be published within a year. The discussion included a summary of the contamination found at the Marine Terminal Area, along the Former Pipeline Corridor, and at the Former Facility Area. Mr. Underbakke then provided a summary of the alternatives that were under consideration in the FS. At the Marine Terminal Area, very little contamination was found and the likely alternative would be no action because the entire area is being rapidly eroded by heavy waves during storms. Along the Former Pipeline Corridor, five small areas of soil and groundwater contamination were found and the option that appears to make the most sense is source removal with groundwater monitoring. This could include enhanced bioremediation or chemical treatment. At the Former Facility Area, several options are being considered for the various media found to be contaminated. For PCBs in surface soil; they include excavation and off-site disposal and/or off-site remediation, excavation and on-site remediation; and in-situ remediation. For subsurface soil (primarily fuel contamination), options similar to those considered for the Former Pipeline Corridor are being explored. And for groundwater at the Former Facility Area (primarily TCE contaminated), in-situ treatment (enhanced natural attenuation)-with long-term groundwater monitoring appears to be the most promising. It was stressed that options for cleanup of all media are somewhat limited due to the remoteness of the site and the lack of infrastructure (primarily electricity) to run treatment systems. Some of the details of how various options could be implemented were also discussed. Mr. Halverson and Mr. Gusmano indicated that the ADEC and USEPA support enhanced natural attenuation and indicated that the Record of Decision should be written with some flexibility. RAOs were discussed. The AKDOT indicated that if the property were not conveyed to the Air Force, the State would like the site to be cleaned up to residential standards to allow for possible future development. The State would also like access to be unrestricted (no institutional controls). If the property is conveyed to the Air Force, a possible risk-based concentration for PCBs may be considered for a subsistence-use scenario. John Halverson
5/3/2005 Update or Other Action File number issued 2637.38.002.02 Aggie Blandford
5/20/2005 Update or Other Action It should be noted that the only locations where media contained concentrations of analytes in excess of screening criteria along the Pipeline Corridor were between the Marine Terminal Area and the Airport. In addition, GRO concentrations at several of these fuel-contaminated Pipeline Corridor locations were higher than at any other source area studied during the 2004 RI. This includes one spill that is known to have occurred in 1985 after the Air Force had left the site. FPC-029 Spill Site This was the location of a spill that occurred in 1985 when a snow plow hit the pipeline. During this event, an unknown quantity of fuel spilled from the pipeline and into a resident’s driveway. The release took place in winter and much of the fuel mixed with snow and ponded. As temperatures warmed, the fuel became more mobile and spread westward toward the resident’s house. In the spring, the ponded fuel reportedly infiltrated the soil. Although this spill is not associated with the Air Force, it was investigated to provide the community with limited data regarding the nature and extent of any remaining contamination. One analytical surface soil sample was collected on either side of the driveway and two soil borings (FPC-SB-13 and FPC-SB-14) were drilled in the driveway at the location of the spill. Groundwater grab samples were collected from each boring and sent for laboratory analysis. Analytical results indicate that both DRO and GRO are present in soil above screening criteria. DRO and GRO were detected at 19,000 mg/Kg and 760 mg/Kg, respectively, in the sample collected from 1 to 2 feet bgs in soil boring FPC-SB-13. Screening criteria for these compounds are 250 mg/Kg and 300 mg/Kg, respectively. There were no other analytes detected above screening criteria in soil. A soil sample collected from this boring at 9 to 11 feet bgs in smear zone soil did not contain either compound above screening criteria. A groundwater grab sample from this boring was also free of analytes above screening criteria. However, it should be noted that a groundwater grab sample collected from soil boring FPC-SB-14 did contain DRO slightly below the screening criteria of 1.5 mg/L at a concentration of 1.3 mg/L. NOTE to File:Regulatory speaking, this water sample result obtained from soil boring will be considered by ADEC to be qualitative and not quantitative. Water sampled directly from an excavation, or in this case, a soil boring, is not necessarily representative of normal groundwater conditions and will not be evaluated as a representative groundwater sample. Only those groundwater samples from properly installed and developed groundwater wells will be considered acceptable groundwater monitoring samples. Based on analytical results, it appears that fuel contamination is present in soil at this site and may have impacted groundwater. Louis Howard
5/21/2005 Update or Other Action FPC-066 Spill Site This station is across the road from the school and is the location of a spill that occurred in late 1980s to early 1990s. Although this spill is not associated with the Air Force, it was investigated to provide the community with limited data regarding the nature and extent of remaining contamination. At this site, one analytical surface soil sample was collected using hand digging techniques, five soil borings were drilled and analytical samples of surface soil, subsurface soil, and groundwater collected. One monitoring well was installed and sampled for laboratory analysis, and two downgradient peizometers were installed and sampled. In all, ten soil samples and six groundwater samples were collected and submitted for laboratory analysis from this site. Analytical results showed a small area of surface and subsurface soil contained DRO in excess of the screening criteria of 250 mg/Kg. The highest result was 8,400 mg/Kg in a sample collected from 0 to 2 feet bgs in soil boring FPC-SB-05. DRO was also detected slightly above the screening criteria in a subsurface soil sample collected in the smear zone at 4 to 6 feet bgs. There were no other analytes detected above screening criteria in soil samples from this boring. DRO was also detected above the screening criteria in the surface soil sample collected at this station. There were no analytes detected above screening criteria in any other soil sample at this site. DRO and RRO were both detected above the screening criteria of 1.5 mg/L and 1.1 mg/L, respectively, in groundwater samples collected at this site. The highest DRO result was 8.1 mg/L in a groundwater sample collected from FPC-MW-01. RRO was detected above the screening criteria in two groundwater grab samples. However, as established at other locations investigated during the 2004 RI, the RRO detected in these samples is likely due to naturally occurring organics in the subsurface rather than anthropogenic contamination. This is supported by the fact that RRO was not detected in the groundwater sample collected from FPC-MW-01, which was the sample with the highest DRO result. It should be noted that, although not in excess of the screening criteria of 1.3 mg/L, GRO was detected at 0.9 mg/L in this sample. Based on analytical data, it appears that DRO contaminated soil covers an area of approximately 400 to 900 square feet. The size of the DRO plume in groundwater appears to be approximately 400 to 900 square feet in extent. Louis Howard
5/22/2005 Update or Other Action FPC-074 This station is located north of the school in a low-lying wet area. At this location, a small circular area of stressed vegetation approximately five feet in diameter was noted. A sheen was identified on surface water at this location. The root mass of the stressed wetland vegetation was agitated to expose a fresh surface prior to sampling. A strong fuel odor was detected upon doing so. One analytical sample was collected of surface water in the center of the contaminated area and three step-out analytical surface water samples were collected. Each was collected 10 feet from the center of the stressed vegetation. Analytical results in excess of surface water screening criteria are found in this location. Both TAH and TAqH were detected above screening criteria of 0.010 mg/L and 0.015 mg/L, respectively, in the sample collected in the center of the stressed vegetation (FPC-074-W01-0). TAH and TAqH were not detected above the screening criteria in any of the three step-out samples collected at this location and no sheen was observed in step-out samples. It should be noted that the surface water was also evaluated for DRO and RRO at this location. DRO and RRO were detected at 170 mg/L and 2.4 mg/L in sample FPC-074-W01-0. This is the highest concentration of DRO detected in a water sample during the 2004 RI. Although there is no surface water screening criteria for DRO and RRO, these results are provided as additional data to define the nature of contamination at this site. Although there is no surface water screening criterion for GRO, it should also be noted that GRO was detected at 0.82 mg/L in sample FPC-074-W01-0. This may be an indication of a relatively recent leak rather than a leak that occurred during Air Force operation of this portion of the pipeline. Based on analytical data, it appears that a plume of TAH and TAqH contaminated surface water of less than 20 feet in diameter is present at FPC-074. FPC-086 At this station, a small area of stressed vegetation was noted during reconnaissance of the Former Pipeline Corridor (activity locations are depicted on Figure 6.2-59). Sections of the pipeline were found in-place sporadically overgrown with vegetation. A small hole (approximately 1.25 feet deep) was hand-dug in the center of the stressed vegetation to expose a fresh surface for sampling. A strong fuel odor was detected upon doing so. During the initial investigation of this location, two surface soil analytical samples were collected and split samples were field tested for TPH. One sample (BGS-CN-01) was collected at 1.5 feet bgs and the other sample (BGS-CN-02) collected at 2.5 feet bgs. Both samples were of highly organic saturated soil. DRO was detected in the shallow sample at 630 mg/Kg, exceeding the soil screening criteria of 250 mg/Kg. DRO was detected in the deeper sample at 4 mg/Kg. Field testing of these samples did not correlate well to analytical results due to the very high organic and water content. Due to these results (and other initial field test results compared to analytical results along the Pipeline Corridor), it was determined that the proper media to investigate at wet areas along the Pipeline Corridor would be surface water rather than soil or sediment. Louis Howard
5/23/2005 Update or Other Action FPC-215 (Reeve Pipeline Junction) As stated above, Reeve Aleutian Airways used the southern two thirds of the pipeline to transport fuel from the Marine Terminal Area to the Airport starting sometime after the Air Force left the site in 1978 until the early 1990s. Reeve installed a junction in the pipeline on the west side of the road, at the approximate location of FPC-215, that extended the pipeline east under the road and to two large ASTs located at the Airport ramp. The portion of the pipeline that was buried under the road remains in-place. Although not operated by the Air Force, investigation of this junction and branch of the pipeline were investigated to provide the community with limited data regarding the nature and extent of contamination remaining at this location. Four soil borings were drilled at this location; three on the west side of the road to investigate the pipeline junction, and one on the east side of the road to investigate the pipeline branch toward the Airport. Two of these borings were converted to monitoring wells. Soil boring FPC-SB-15 was drilled in a low area on the shoulder of the road approximately 10 feet west of the west end of the section of pipeline found buried under the road. In this boring, several absorbent pads were found buried approximately one foot bgs. The pads appear to have been placed under the pipeline junction during a release and then covered with soil. Two surface soil analytical samples, three subsurface soil analytical samples, and four groundwater analytical samples were collected during the investigation of this site. Both DRO and GRO were detected above the screening criteria of 250 mg/Kg and 300 mg/Kg, respectively, in a subsurface soil sample collected at 9 to 11 feet bgs in soil boring FPC-SB-15. Groundwater at this location was encountered at approximately 15 feet bgs. There were no other analytes detected above screening criteria in this sample and no analytes detected above screening criteria in any other soil samples from this site. Soil analytical results from investigation of the FPC-215 pipeline junction area in excess of screening criteria are found here (DRO 8,200 mg/kg and GRO 1,000 mg/kg). It should be noted that the GRO detected in this sample was the highest concentration detected in soil during the 2004 RI. The second highest concentration was detected in soil boring FPC-SB-13 south of the school at the FPC-029 Spill Site. In addition, the compounds 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, 4-isopropyltoluene, and total xylenes were also detected in sample FPC-SB-15-S02-0 at the highest concentrations recorded during the 2004 RI. DRO was detected in excess of the screening criteria of 1.5 mg/L in two of the four groundwater samples collected at this site. The maximum DRO concentration was 49 mg/L in the groundwater grab sample collected from soil boring FPC-SB-15. A sheen was also noted on the water collected from this boring. In addition, GRO was detected above the screening criteria of 1.3 mg/L in the groundwater grab sample collected from soil boring FPCSB-15. GRO was detected at 3.25 mg/L in this sample. All groundwater analytical results in excess of screening criteria at this site. It should be noted that the GRO detected in this sample was the highest concentration detected in water during the 2004 RI. The next highest concentration was detected in a groundwater sample from FPC-MW-01 at 0.9 mg/L. The DRO detected in this sample was the third highest concentration detected in water during the 2004 RI. The highest concentration in water was detected in a surface water sample collected at FPC-074. Based on analytical data collected at FPC-215, it appears that a significant release occurred at the pipeline junction. The presence of absorbent pads and a high concentration of GRO in soil and groundwater indicate that the spill did not occur during the time the Air Force operated the pipeline but was instead a more recent event. Louis Howard
7/22/2005 Site Characterization Report Approved DEC approved the final RI report dated May 2005. The Former Pipeline Corridor was the location of a two-inch pipeline used to transport fuel approximately six miles from the Marine Terminal Area north to the Former Facility Area. The pipeline was also buried from the eastern margin of the Former Facility Area pad to the former USTs northeast of the Former Composite Building. 127 soil samples and 37 water samples (19 surface water 18 groundwater) were collected and submitted for lab analysis. FPC-029 Spill Site was the location of a spill that occurred in 1985 when a snow plow hit the pipeline. One surface soil sample was collected on either side of a resident's driveway and tow soil borings were drilled in the driveway at the location of the spill. Groundwater grab samples were collected from each boring and sent for lab analysis. *NOTE:This "water sample" result obtained from soil boring will be considered by ADEC to be qualitative and not quantitative. Water sampled directly from an excavation, or in this case, a soil boring, is not necessarily representative of normal groundwater conditions and will not be evaluated as a representative groundwater sample. Only those groundwater samples from properly installed and developed groundwater wells will be considered acceptable groundwater monitoring samples. John Halverson
2/8/2008 Update or Other Action Draft 2008 Proposed Plan Port Heiden RRS January 2008 Contract Number: FA8903-04-D-8681, TO 305 Air Force Project Number: TNYH20077201 received and staff provided comments. Site Characteristics: The text states “Levels of contaminants were compared to screening criteria which are based on State (ADEC) and EPA risk and cleanup levels. The screening criteria used for surface soil and groundwater is ADEC Method 2 cleanup levels (18 AAC 75 Tables B and C), which is protective of human health and the environment and allows unrestricted land use and access.” ADEC requests deleting “screening criteria” and inserting cleanup levels. Additionally, cleanup levels for soil specified in Table B at 18 AAC 75.341 apply to both surface and subsurface soil. For the majority of contaminants, the migration to groundwater cleanup levels in Table B are those that allow for unrestricted use and not inhalation or ingestion cleanup levels that are typically higher and require land use controls. However, certain contaminants have higher migration to groundwater cleanup levels than ingestion/inhalation levels. For these contaminants, use the most stringent level as the “unrestricted use” level. For example, the contaminant: Benzo (a) pyrene has a cleanup level of 1 mg/kg for ingestion and 3 mg/kg for migration to groundwater. In this case the more stringent cleanup level for ingestion would be the level that allows for “unrestricted use”. Cleanup Objectives: The text states “…contaminants in concentrations greater than screening criteria are:….” ADEC requests the text be changed to read “…contaminants in concentrations greater than cleanup levels are….” ADEC requests the section be renamed Remedial Action Objectives and change objective 1 to read as follows: 1) to protect the current and future residents of Port Heiden by reducing the contaminant concentrations to meet cleanup levels. Preferred Cleanup Options: ADEC requests the section be renamed “Preferred Cleanup Alternative” and throughout the text change “option” to “alternative”. Add text to Groundwater Option 3 section: “Institutional controls would be implemented for groundwater and would remain in-place until groundwater cleanup levels were achieved through natural attenuation.” The text in the document does not specifically mention groundwater use restrictions: “As under Surface Soil Option 4, property owners would be notified of the contamination on site and restrictive covenants would be employed. Property use restrictions and covenants would be removed after long-term monitoring results show that the concentrations had dropped below cleanup levels.” Surface Soil Option 6 – Soil Excavation (> 1 ppm): ADEC does not agree to the use of 1 ppm as an appropriate or applicable cleanup level for all contaminants of concern at the site (i.e. pesticides and PAHs with cleanup levels less than 1 mg/kg). Please refer reader to contaminant specific listing for the Former Facility Area and appropriate cleanup levels. ADEC requests text be added to this section: “Because this remedy will result in hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted every five years after initiation of the remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment. These reviews will be conducted until cleanup levels are achieved at the site.” Louis Howard
2/19/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Louis Howard
2/21/2008 Update or Other Action Staff reviewed and commented on the Draft Work Plan Port Heiden 2008 Pipeline Corridor Removal Action. Section 1.2 Scope of Work Page 1-4 : The text states as one of the tasks for this project includes: backfill excavation areas with treated soil. Per 18 AAC 75.325(i), department approval is required before disposal of treated soil. Table 4-1 Site Specific PRGs Page 4-1: The maximum concentration observed of gasoline range organics(GRO) was 1,000 mg/kg at FPC-215 (Reeve Pipeline Junction) sample ID FPC-SB-15-S02-0 from 9-11 ft. below ground surface (bgs). Please correct table. Table 4-2 Project Data Quality Objectives Pages 4-4 and 4-5: ADEC requests clarification on whether the baseline sampling of the treatment area be through discrete or multi-increment (MI) sampling. ADEC recommends clarification as to type, number, location, etc. for pre- and post-treatment sampling. ADEC requests the addition of AK103/Residual Range Organics (RRO) to sample analysis. RRO was indentified in previous water samples and it is unclear if previous soil samples were analyzed. Assumption of biogenic contribution is not supported. Additionally, post-treatment samples should be analyzed for volatile organic compounds (VOCs) by method 8260B, due to the remediation mechanism of the pentanonic solution which breaks down large hydrocarbon molecules into smaller (possibly volatile) fragments besides BTEX. 5.4 Petroleum-contaminated Soil Removal Page 5-5: The text states treated soil that meet ADEC’s migration-to-groundwater cleanup levels may be spread anywhere on site. Per 18 AAC 75.325(i): A responsible person shall obtain approval (from the department) before disposing of soil or groundwater from a site (1) that is subject to the site cleanup rules; or (2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1). ADEC requests the addition of AK103/RRO to sample analysis. RRO was indentified in previous water samples and it is unclear if previous soil samples were analyzed. Assumption of biogenic contribution is not supported. Additionally, post-treatment samples should be analyzed for VOCs by method 8260B, due to the remediation mechanism of the pentanonic solution which breaks down large hydrocarbon molecules into smaller (possibly volatile) fragments besides BTEX. If all of the excavated soil is mixed together prior to stockpile construction, then one decision unit of approximately 900 cubic yards is appropriate with correct duplicate/triplicate sampling. If the soil stockpile is being constructed as the excavation is occurring at each area and some areas were significantly more contaminated than others (370 mg/kg versus 19,000 mg/kg), the soil stockpile will have distinct separation and a separate decision unit would be more appropriate for each area (i.e. five stockpiles). 5.4.1 Field Screening Page 5-5: ADEC requests analytical confirmation of soil samples with less than 10 ppm PID field screening results (identified as “clean”) , prior to approval and use as backfill. 5.5 Transportation and Stockpiling and Biochemical Treatment Page 5-6: ADEC requests clarification on sampling, analytical testing and disposal requirements for any accumulated water. 5.6.2 Treatment Process Page 5-7: Department approval for the use of pentanonic is contingent upon receipt and review of information by the department in regards to the chemical constituents and structure. 5.6.3 Post-Treatment Sampling Page 5-10 and 2.4.3 FSP Page A-8 Please provide to the department, the approximate proposed dimensions of the treatment stockpile, assuming the 1,000 cy. In order to ensure adequate coverage of the treatment stockpile, ADEC recommends clarification to state that the 30 increments will be comprised of 3 randomly chosen locations of different depths from each of the 10 primary sections. Duplicate and triplicate samples must be collected from separate random locations. Please revise the work plan and sampling plan to specify that the duplicate and triplicate increments will be collected from independent quadrants and depths. Increment locations should be selected in the same manner, e.g. random number generator, as the primary sample. Duplicate/triplicate samples are to assess primarily matrix variability and field sampling precision. As such, increments must be collected from independent locations. For non-volatile (DRO/RRO) the MI guidance recommends 30-60 grams per increment be collected and additional mass if oversized material is encountered (page 9). Approximately 500-1000 g of material following sieving should be available for sub-sampling (page 10). Additionally, please specify the mass to be collected per volatile increment, to the extent possible without disturbance collection of 2-5 grams of 2mm soil is recommended. Recommend adding this clarification to ensure adequate, representative mass is collected. Louis Howard
5/28/2008 Update or Other Action Additional ADEC comments: Section 5.6.3 Page 5-11: The RSD limit for MI samples should be 30% as per ADEC "Guidance on Multi-Increment Soil Sampling" effective March 30, 2007. DEC requires a RSD of 30% or less. 35% is not acceptable and we erred in including that number in our comments on the plan. At RSDs of greater than 35%, the data distribution becomes nonnormal and confidence in the representativeness of the MI sample results diminishes. To ensure an RSD of 30% or less it is imperative to control sampling error as described in this guidance. FSP Section 2.4.3 Page A-9: Change RSD to 30% for MI sampling acceptance criteria. FSP Section 7 Page A-20: IDW Handling-ADEC will require testing all water that accumulates in soil containment cells (effluent) for pH in addition to the GRO, DRO, VOCs listed in this section. pH must be near normal (7) or typical of pH in this area (2005 RIFS states the ph for soil samples was 6.8 which is considered neutral). SWPPP Section 6.0 Page E-7: The pumps will discharge either into a water truck or existing storm water features. WHAT Features? Testing prior to discharge to land or waters of the state will be required which includes pH testing in addition to the GRO, DRO, VOCs. GENERAL: Stormwater staff at ADEC advise that if the location of any treated/untreated discharge associated with the proposed treatment facility footprint is on a "contaminated site" then it does not need a stormwater permit or plan review by Stormwater ADEC staff and can be handled by CS Program. IF it is not a contaminated area (the site) where the "potential" discharge is being contemplated from the treatment facility, then a Stormwater permit is required as well as a fees associated with the SWPPP review by SW ADEC staff. Louis Howard
5/29/2008 Update or Other Action The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites (CS) Program has reviewed the information provided on the chemical pentanonic dated April 30, 2008 and received in our office on May 1, 2008. Additional review and discussion occurred during the requested meeting on May 8, 2008, between Ms. Teresa O'Carroll of Iliaska Environmental LLC, Mr. Earl Crapps of ADEC, and yourself. All of the technical information provided on the chemical pentanonic, including but not limited to, its chemical composition and toxicity data has been evaluated and the CS program has determined that it is acceptable for use as a remediation technique for petroleum contaminated sites within the State of Alaska. The following conditions apply to the use of pentanonic for all CS projects (NOTE TO FILE: which includes the PBC POL Pipeline project-SS006). Alternative additives fiom the standards discussed must be proposed and approved by the department on a site specific basis. The standard additives are Magnesium oxide (builder), Sodium 1-butanesulfonate (anionic surfactant) and Sodium stearate (nonionic surfactant). Additives should be identified in a work plan submitted to the department for approval. The minimum dilution ration of pentanonic prior to application is seven parts water to one part pentanonic (7:l). Additional dilution of the chemical pentanonic may be required on a site specific basis, e.g. applications on or near environmentally sensitive areas (*NOTE to File:18 AAC 75.990(35) “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including (A) an area of unique, scarce, fragile, or vulnerable natural habitat; (B) an area of high natural productivity or essential habitat for living organisms; (C) an area of unique geologic or topographic significance that is susceptible to a discharge;(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits; (E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and (F) an area that merits special attention as defined at 6 AAC 80.170;). NOTE: 6 AAC 80.170 repealed see AS 46.40.210(1) "area which merits special attention". The dilution ratio should be identified in a work plan submitted to the department for approval. Monitoring for pentanonic breakdown, as well as contaminants of concern (COCs), should occur. Pentanonic breakdown will be demonstrated through pH monitoring, with a basic pH indicating the presence of the chemical and a neutral pH indicating pentanonic breakdown. COCs should always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels. All other applicable regulations and guidance for the characterization, remediation and/or cleanup of petroleum contaminated sites must be adhered to. Please note that site specific workplans must be submitted and approved by the department prior to implementing cleanup work at contaminated sites or leaking underground storage tank sites. This letter should not be considered an endorsement, nor approval, of the chemical pentanonic or its effectiveness. It may be considered a determination, based on a review of the provided information, that its use under department approved conditions on a site specific basis will not pose an unacceptable risk to human health, safety, or the environment. Thank you for providing requested information on the chemical pentanonic for department review. If you have any questions regarding this letter, please contact me at (907) 269-7545 or john.halverson@alaska.gov. Signed by John Halverson Environmental Program Manager. John Halverson
10/23/2008 Site Visit At the request of the project manager, Louis Howard, the quality assurance officer traveled to Port Heiden with the project manager and contractors for the Air Force to oversee multi incrment sampling activities. Upon arrival the sampling contractor informed ADEC representativies that MI sampling had been canceled for the day in order to attend a community meeting with Air Force representatives on site cleanup activities. However, the quality assurance officer was able to observe the placement of sampling grids on the soil stockpile. Brenton Porter
12/5/2008 Update or Other Action Ownership of the POL Pipeline (SS006) from the POL Tank Area to the Composite Budding Area (OT001) has been transferred to Reeve Aleutian Airways. The airline couldn't withstand the effects of increased competition, deregulation and the continued difficulties of flying to the Aleutians. Reeve Aleutian Airways stopped scheduled air service December 5, 2000, after nearly 70 years. John Halverson
2/17/2009 Report or Workplan Review - Other Staff reviewed and commented on the Draft Report 2008 Pipeline Corridor Removal Action. General Comments The report does not provide any documentation/photos of the multi-increment (MI) sample preparation for any of the MI activities. ADEC requests the Air Force (AF) provide this information if it is available. 1.4 Findings of Previous Site Investigation Page 1-15 ADEC requests the AF change the text to state there was an exceedance for benzene in GW. The 2004 site investigation results from the lab data tables (sample FPC-SB-15-W01-0 on page 190 of 247) shows benzene at 9.4 ug/L (sample date 9/2/2004). This sample was from the FPC-215 (Reeve Junction of the Pipeline). The 2004 site investigation text did not note that benzene exceeded the 5 ug/L cleanup level established in 18 AAC 75 Table C. 2.4.2 FPC-029 Spill Site Figure 2-3 FPC-029 Spill Site Excavation & Sampling Results Page 2-13 ADEC requests the AF provide clarification on whether there were analytical confirmation samples taken from the floor of the excavation. If no confirmation samples were taken from the floor of the excavation, then this appears to be a data gap & in direct conflict with comments & response to comments given on the 2008 field sampling plan (FSP) for Page A-5. Page 2-14 & 2-15 The text states that stained soil & sheen were observed in the bottom of the excavation & in the smear zone along the sidewall, however, all of the confirmation sample results (see Table 2-5 FPC-029) are non-detect. ADEC requests the AF explain the lack of contamination in sample results & the observed stained soil & presence of sheen in the bottom of the excavation/smear zone. 2.4.5 FPC-066 Spill Site Page 2-19 Figure 2-5 ADEC requests the AF provide clarification on whether there were analytical confirmation samples taken from the floor of the excavation. If no confirmation samples were taken from the floor of the excavation, then this appears to be a data gap & in direct conflict with comments & response to comments given on the 2008 FSP (Page A-5). See comment response under 2.4.2 for the 2008 FSP. 2.5.1 Pre-treatment Baseline Sampling Pages 2-28, 2-29, Figure 2-11 ADEC requests the AF provide clarification for the text & figure for the treatment facility & baseline sampling. Please add dimensions (200’ x 140’) to Figure 2-10, if the entire treatment facility was sampled. Page 2-29 The duplicate & triplicate multi-increment (MI) samples were collected incorrectly. Duplicate & triplicate sample locations should have been from independent quadrants, not approximately 18” from the primary sample location. This is in direct conflict with the comments provided on the 2008 work plan Page 5-10 & FSP Page A-8 . Table 2-12 Page 2-31 ADEC recommends the method detection limit (MDL), not ½ the MDL be used for relative standard deviation (RSD) calculation. Per the MI guidance, the 95% upper confidence limit (UCL) must be calculated for all decision units. The 95% UCL will be used to evaluate against DEC Cleanup levels. Please revise. 2.5.5 Final Treatment Sampling Page 2-37 2nd Paragraph The duplicate & triplicate MI samples were collected incorrectly. Per comments & the approved work plan, duplicate & triplicate sample locations should have been from independent quadrants & depths, not approximately 18” from the primary sample location. See comment & response to comments above from 2008 work plan regarding duplicate & triplicate sample locations. As such, the MI samples & results may not be representative of stockpile concentrations. ADEC requests the AF clarify how discrete sampling was performed. Additionally, ADEC requests the AF provide clarification on the statement that “...after the multi-incremental sample compositing & collection was complete.” Page 2-37 4th paragraph The text states the field crew was required to remobilize and recollect samples from the existing augered holes. ADEC requests the Air Force provide information on why it was necessary to remobilize and recollect MI samples and analyze for diesel range organics (DRO) and residual range organics (RRO). ADEC requests the Air Force provide the rationale on why samples were collected from existing augered holes five days later. ADEC was not consulted and did not approve of this deviation in sampling from the existing holes at a depth of six inches. This is in direct conflict with the field sampling plan which specified: “Thirty sample increments will be comprised of three randomly chosen locations of different depths from each of the ten primary sections.” Table 2-14 Post-Treatment Multi-Incremental Soil Sample Results Page 2-38 See Comment for Table 2-12 Page 2-31. Please revise and include 95% UCL. Louis Howard
6/5/2009 Update or Other Action Final Report 2008 Pipeline Corridor Removal Action received. The United States Air Force (USAF) conducted a removal action at the Former Pipeline Corridor (FPC) in 2008. The FPC removal action consisted of removing in-place pipeline, collecting previously removed pipeline from various locations around the community, consolidating all pipe & ancillary support structures for proper disposal at the Native Village of Port Heiden (NVPH) landfill, collecting & disposing of fluids in the pipeline, & removing petroleum-impacted soil from sites along the FPC. Approximately 12,000 ft. of in-place pipe & 6,000 ft. of previously abandoned pipe were removed, cleaned, & consolidated during the field effort. Minimal fluids were collected from the in-place pipe; 200 gallons of fuel with water, & 50 gallons of fuel contaminated water were collected & disposed. Contaminated soil was excavated from 6 sites along the FPC. Contamination at 4 of the sites had been documented in previous site investigations, FPC-029, FPC-036, FPC-066, & FPC-215. Two new areas of with slight impacts to site soils were identified during the pipeline removal & were designated FPC-015 & FPC-034. Confirmation sample results indicated that corrective actions for impacted soil at all six sites has been completed to the extent practical, with only residual soil contamination remaining at 2 sites in locations that are proximal to roads. Additional actions at FPC-066 & FPC-215 cannot be performed without damaging the structural integrity of the roads. Approximately 1,015 cy of soil was excavated & bio-chemically treated from the 6 sites. Treatment confirmation sampling results indicated that the soils were remediated below applicable Alaska Department of Environmental Conservation (ADEC) soil cleanup levels. Impacts to the groundwater & smear zone remain at 3 of the sites, FPC-029, FPC-66, & FPC-0215. The USAF will coordinate with ADEC & NVPH to develop a plan for assess residual impacts to groundwater. The excavation was initiated near monitoring well FPC-MW01 which was installed during the 2004 RI. A very strong odor & soil staining were observed as soon as the excavation exposed subsurface soils. The contamination was observed to have migrated vertically to the water table which was encountered at 6.5’ bgs. Excavation continued until PID results indicated that the horizontal extent of contamination in the sidewalls had been removed, with the exception of the sidewall to the east which was adjacent to the roadway. Stained soil & a strong odor were observed to remain in place along this perimeter of the excavation. Residual fuel-contaminated soil was observed in the bottom of the excavation & in the smear zone along the sidewalls. A heavy sheen & some floating product were observed on the groundwater that seeped into the floor of the excavation. Adsorbent booms were placed on the surface of the standing water to aid in removal of the sheen. After PID readings & observations of staining & odor indicated that soil contamination above the smear zone had been excavated to the extent practical (except along the eastern wall along the road), 6 field-screening samples were collected from various locations & depths within the excavation for headspace & PetroFlag® Test Kit analyses. Final confirmation samples were collected to confirm the field screening results. DRO exceeded the ADEC cleanup levels in the sample & its duplicate that was collected from the east wall of the excavation, 08PH-066-01-SO. FPC-215 The pipeline was visible at the edge of the road adjacent to FPC-215. However, once the excavation was opened up, it was discovered that it was only a small section of isolated pile (approximately 4’ long). The extent of the excavation was approximately 30’ long by 25’ wide with a total depth of 12’ bgs. Approximately 334 cy of soil were removed from this site. After the final confirmation samples were collected, the excavation was immediately backfilled due to its proximity to the road. After the soil removal was completed, several shallow test pits were advanced to the NW of the main excavation in the vicinity of former soil boring FPC-SB-24 (2004 RI). In the previous investigation DRO had been encountered in a soil sample from the 2’ bgs interval of this soil boring at a concentration of 340 mg/Kg. In the 2008 field effort no physical evidence (staining or odor) or PID readings indicated the presence of contamination in this area. A confirmation sample, FPC-215-06-SO, was collected at a depth of 2’ bgs in a test pit at this location. DRO exceeded the ADEC cleanup levels in the sample collected from the floor of the excavation from smear zone, 08PH-215-01-SO. Additionally, DRO was slightly above cleanup levels in a sample collected from the sidewall. All other sample results were below the applicable cleanup levels. Louis Howard
6/3/2010 Update or Other Action Draft Hydrogeologic Study received. A hydrogeological study was performed at these three sites to characterize the extent and nature of groundwater contamination. Additionally, two spill sites located in wetland areas along the pipeline corridor were further investigated, FPC-074 and FPC-086. Releases of petroleum hydrocarbons at the pipeline spill sites did not result in widespread contamination. The impacts were limited in areal extent but extended down to the water table. Soil removal actions in 2008 appear to have addressed most soil and groundwater contamination at the site. Natural attenuation mechanisms will continue to eliminate residual contamination. It is recommended that annual groundwater monitoring be continued at FPC-029, FPC-066, and FPC-215 to collect three consecutive years of data. The groundwater samples should be analyzed for gasoline-range organics (GRO), diesel range organics (DRO), residual-range organics (RRO), and benzene, toluene, ethylbenzene, and xylenes constituents (BTEX). The absence of any significant soil or water quality impacts at FPC-074 should eliminate the necessity for further monitoring. All detected constituents in the surface water samples and wetland soil samples were below applicable ADEC Water Quality Standards (ADEC, 2009) and ADEC soil cleanup levels (ADEC, 2008). It is recommended additional investigation should be conducted at FPC-086 to further assess impacts to soil identified by this study. All detected constituents in the surface water samples were below applicable Alaska Department of Environmental Conservation (ADEC) Water Quality Standards (ADEC, 2009). DRO was detected at concentrations that exceeded ADEC soil cleanup levels. Annual surface water and soil monitoring should be continued until at least three consecutive years of data have been collected. The surface water samples will be analyzed for total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH). Soil samples will be analyzed for GRO, DRO, RRO, and BTEX. FPC-066: Soil sample results-DRO was detected at concentrations above the ADEC Method 2 migration to groundwater soil cleanup level of 250 mg/Kg in only one soil boring. Both samples from SB-15 exceeded the cleanup level for DRO. The sample collected at the water table (6- foot bgs) and the sample collected immediately above it within smear zone soil (5.5-foot bgs) and having an elevated PID of 281 ppm had DRO concentrations of 11,900 mg/Kg and 3,280 mg/Kg, respectively. SB-15 is downgradient of the former excavation. Groundwater: DRO was detected in MW-5 (2.25 mg/L) and WP-14 (37.9 mg/L) which are co-located, and the duplicate for WP-14 (6.97 mg/L). DRO as also detected in WP-11 which was installed in the center of the former excavation area. DRO was detected in WP-11 at a concentration of 5.9 mg/L. FPC-215 DRO was detected at concentrations above the ADEC Method 2 migration to groundwater soil cleanup level of 250 mg/Kg in two soil borings. The sample collected at the water table (10-foot bgs) in SB-4, which was the soil boring drilled in the center of the former excavation, had DRO concentrations of 1,190 mg/Kg. A sample collected from the 5-foot interval in SB-9 had a DRO concentration of 642 mg/Kg. SB-9 is across the road and in the direction of the airport from the former excavation. Benzene was detected in one sample, SB-4 at 10 feet bgs, at a concentration of 0.0576 mg/Kg, which exceeds the ADEC soil cleanup level of .025 mg/Kg. Groundwater: DRO was detected in MW-9 (4.18 mg/L) and its duplicate (3.99 mg/L), and WP-5 (6.44 mg/L) which are co-located. DRO was not detected in any other groundwater samples at FPC-215. Wetlands soil sampling: DRO was the only analyte in samples collected from FPC-086 that exceeded ADEC soil cleanup levels. DRO was detected in four of the five soil samples collected from this location. DRO exceeded ADEC soil cleanup levels in soil sample locations FPC86-02 and FPC86-04 (Figure 6) at concentrations of 678 mg/Kg and 436 mg/Kg, respectively. FPC-066 Sampling conducted in 2009 confirmed that smear zone soils at the location of the former excavation and immediately downgradient are impacted by DRO at concentrations that exceed ADEC’s most stringent cleanup levels (SB-15 at 5.5 and 6’ bgs). DRO was detected in both well points at concentrations exceeding the ADEC groundwater cleanup level of 1.5 mg/L. DRO was also detected above groundwater cleanup levels in the downgradient monitoring well MW-5, which is collocated with temporary well point WP-14. Louis Howard
6/23/2010 Report or Workplan Review - Other Staff reviewed and commented on the Draft Report 2009 Groundwater Investigation. 7.1 FPC-029 Spill Site Page 7-1 The text states: “It is recommended that annual groundwater monitoring be continued to collect three consecutive years of data. The groundwater samples should be analyzed for GRO, DRO, RRO, and BTEX.” ADEC disagrees. Table 1 – FPC-029 Soil Sample Analytical Results and Table 2 – FPC-029 Groundwater Sample Analytical Results shows no contaminated groundwater or contaminated soil above 18 AAC 75 Table B1/B2 and Table C cleanup levels. ADEC believes no further remedial action is necessary at FPC-029. ADEC is basing its decision on the most current and complete data provided by the Air Force. ADEC reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances, Pollution Control regulations and Alaska Statute 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. 7.1 FPC-066 Page 7-2 The text states: “It is recommended that annual groundwater monitoring be continued to collect three consecutive years of data. The groundwater samples should be analyzed for GRO, DRO, RRO, and BTEX.” ADEC disagrees. Table 3 – FPC-066 Soil Sample Analytical Results shows DRO as the only contaminant of concern above cleanup levels (3,280 mg/kg and 11,900 mg/kg). Table 4 – FPC-066 Groundwater Sample Analytical Results also shows DRO as the only contaminant of concern above cleanup levels. Unless there is previous data which shows GRO, RRO and BTEX as being contaminants of concern above the applicable cleanup levels, ADEC is recommending the Air Force analyze for DRO groundwater at FPC-066 and when groundwater is shown to have met Table C cleanup levels, then resample for DRO in soil. 7.3 FPC-215 Page 7-3 The text states: “It is recommended that annual groundwater monitoring be continued to collect three consecutive years of data. The groundwater samples should be analyzed for GRO, DRO, RRO, and BTEX.” ADEC disagrees. Table 5 – FPC-215 Soil Sample Analytical Results shows DRO and Benzene above cleanup levels (DRO 1,190 mg/kg and 642 mg/kg benzene 0.0576 mg/kg). Table 6 – FPC-215 Groundwater Sample Analytical Results shows DRO as the only contaminant of concern. Unless there is previous data which shows GRO and RRO above applicable cleanup levels, ADEC is recommending the Air Force only analyze for DRO and BTEX in groundwater at FPC-215 and when groundwater is shown to have met Table C cleanup levels, resample for DRO and benzene in soil. 7.4 FPC-074 The text states: “The absence of any significant soil or water quality impacts at FPC-074 should eliminate the necessity for further monitoring.” ADEC agrees. ADEC believes no further remedial action is necessary at FPC-074. ADEC is basing its decision on the most current and complete data provided by the Air Force. ADEC reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances, Pollution Control regulations and Alaska Statute 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. 7.5 FPC-086 Page 7-4 The text states: “It is recommended additional investigation should be conducted at FPC-086 to further assess impacts to soil identified by this study. Annual surface water and soil monitoring should be continued until at least three consecutive years of data have been collected. The surface water samples will be analyzed for TAH and TAqH. Soil samples will be analyzed for GRO, DRO, RRO, and BTEX.” ADEC disagrees. Table 7 – FPC-074 and FPC-086 Wetland Soil Analytical Results shows only DRO and possibly benzene as being above applicable cleanup levels. Table 8 - FPC-074 and FPC-086 Surface Water Sample Analytical Results shows no exceedances of TAH or TaQH. Unless there is previous data which shows GRO and RRO above applicable cleanup levels, ADEC is recommending the Air Force only analyze for DRO and BTEX in the soil at FPC-086 during its additional investigation to assess the impacts to soil identified in this document. Louis Howard
4/12/2013 Update or Other Action Draft Groundwater Monitoring Plan received for review and comment. Work Plan describes the specific tasks required to support annual groundwater monitoring at the Port Heiden RRS Former Pipeline Corridor (FPC)-215 and FPC-066 in Port Heiden, Alaska, expanding on previous environmental investigations undertaken in Port Heiden. Activities will be conducted in compliance with the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act Executive Order 12580, the Superfund Amendments and Reauthorization Act, 18 AAC 75 Oil and Other Hazardous Substances Pollution Control, and 18 AAC 78 Underground Storage Tanks. The specific project goal and objective is to conduct annual groundwater sampling for the ongoing groundwater monitoring program. A total of 27 existing monitoring wells will be sampled in September 2013 to investigate groundwater contamination. Analytical suites: GRO, DRO, RRO, VOCs, and MNA. Historical activities supporting the RRS occurred at the former facility area (referred to herein as the Former RRS), the Marine Terminal Area (a former petroleum tank farm and pump house where Airport Road reaches the Port Heiden Lagoon), and the former pipeline corridor (FPC) connecting the Marine Terminal Area to the Former RRS along Airport Road and Site Road. Both FPC-066 and FPC-215 are associated with these historical activities. Groundwater and soil within these areas have been contaminated by petroleum, oil, and lubricants (POL). Louis Howard
6/2/2016 Report or Workplan Review - Other Staff reviewed and approved the Final 2014 Groundwater Monitoring Report Port Heiden RRS dated May 2015. Louis Howard

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