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Site Report: St. Paul Oil Drum Dump Site FUDS Former TPA 01


Site Name: St. Paul Oil Drum Dump Site FUDS Former TPA 01
Address: 1000 Feet South of, Airport Road, Saint Paul, AK 99660
File Number: 2644.38.012
Hazard ID: 2159
Status: Active
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 57.158844
Longitude: -170.202354
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

Site is within a Formerly Used Defense Site (FUDS). Approximately 350 rusted drums located on central mound stained soils present on southern slope. The 1986 Formerly Used Defense Sites (FUDS) cleanup project report included work on nine separate sites on the island. Based on all the information provided to date, the Corps has not demonstrated that the Oil Drum Dump Two Party Agreement Site #1 (a.k.a. site B-2 and B-4) was adequately characterized, cleaned up or closed during the FUDS 1985-86 cleanup. At Drum Dump sites B-2 and an estimated 650+ drums were reportedly removed. The contracting documents state that most of the drums had rusted through and spilled their contents. The documents called for cleaning up hazardous spills and sampling to verify the level of cleanup. Site logs produced by the contractor show that some contaminated soil was excavated and transported to the FUDS landfill for disposal. It is unclear what types and what concentrations of contaminants were present in the soil that was placed in the landfill. Depth to groundwater ranges from 27 feet to 79 feet below ground surface across the Island of Saint Paul. The fact that some of the FUDS Program sites on the Pribilof Islands are contiguous with NOAA TPA sites complicates cleanup issues. Under current legislation, Public Law 106-562 Section 107, NOAA is prohibited from further expending Pribilof Project funds for cleanup or remediation of FUDS. Formerly referred to as Oil Drum Dump Site No. 1, OUC No. 6 (Two-party agreement site no. 1). This is a Formerly Used Defense Site (FUDS), as of Jan. 2000, under Public Law 106-562 (H.R. 1653), it is not eligible for further funding by NOAA for any cleanup work. Former ADEC project Manager was Ray Dronenburg up to 6/99. Also known as: East Airport Barrel Dump Site A under FUDS program. St. Paul Island Post (1869 - 1870, 1942 - 1945), St. Paul Island An Army post on a remote island in the Bering Sea. The island was again in use by the military in WWII. Also called St. Paul Post. Property owners are the TDX –Tanadgusix Corporation; and TAC – The Aleut Corporation (subsurface estate).

Action Information

Action Date Action Description DEC Staff
9/19/1942 Update or Other Action A preliminary reconnaissance landings on Adak on 26 and 27 August [1942] had failed to discover any enemy forces on the island, and three days later an Army force of about 4,500 began to come ashore. The fortuitous discovery that a tidal basin near the landing area could be used as an airfield site solved anticipated construction problems on that score. Army engineers installed an ingenious drainage system which with fills provided a usable airfield in less than two weeks, instead of the two or three months that had been forecast. The Army planned to increase the Adak garrison to more than 10,000 men by mid-October, and thus to make it the strongest as well as the most advanced of the Alaskan bases.51 A few days after the Adak landing General DeWitt ordered the Alaska Defense Command to send an Army detachment to St. Paul and St. George Islands in the Pribilofs, from which the native population had been evacuated in June. A Joint Chiefs directive of 6 September confirmed this move, which in transmission crossed a vigorous message of protest from Admiral Theobald. At his insistence the operation was briefly deferred, an Army force of 800 finally landing on St. Paul on 19 September, where it was housed in the abandoned civilian dwellings and where it built a fighter strip that was ready for use by the end of October. Louis Howard
12/22/1976 Update or Other Action Memorandum of Understanding Pribilof Land Selections. Future Transfers. National Marine Fisheries Service (NMFS) agrees to effect in the future to the Tanadgusix Corporation of such houses or other buildings on St. Paul Island as may become unnecessary to the carrying out of NMFS responsibilities under the Fur Seal Act of 1966, 16 U.S.C. 1151, or its successor statute. Such transfers will be carried out by applicable law and regulations. Joint Use Areas. Areas not shown on Exhibits. Further areas not shown on the attached exhibits which are available for selection by the appropriate Village Corporation, but subject to joint management (category 3 of paragraph 1b above) are as follows: 1) Polovina/Big Lake "Vehicle Boneyard" (Truck Dump)-St. Paul, Scoria Pits. The Telegraph Hill, Polovina and Lake Hills Borrow (scoria) pits on St. Paul are being retained by NMFS subject to joint management, namely TDX Corp. may use scoria from these pits free of charge, subject to priority use by NMFS, for so long as these pits are under control of NMFS. Sanitary Landfills and "Vehicle Boneyards" (truck dumps) which are subject to joint management may be used free of charge for their intended purposes by the non-owning party. Louis Howard
10/30/1983 Site Reopened ADEC conducted a site inspection of St. Paul Island in October 1983 that included the Oil Drum Dump Site (Harmon 1983). Refer to "Field And Project Report State of Alaska Department of Environmental Conservation Conducted October 1 Through 8, 1993 "Waste Disposal St. Paul Island" Prepared by: Carl H. Harmon Title: Environmental Engineer Region: Southcentral Date: March 21, 1984 File No: 10-1-1983." The site was listed as a suspected contaminated site in a survey of waste disposal practices on St. Paul Island. Thousands of drums were estimated to be present, some with leaking contents. Ray Dronenburg
10/31/1983 Update or Other Action Disposal of Federal property on Pribilof Islands (the Pribilofs)- (a) Submission to Congress of property transfer document - Any provision of law relating to the transfer & disposal of Federal property to the contrary notwithstanding, the Secretary, after consultation with the Secretary of the department in which the Coast Guard is operating, is authorized to bargain, grant, sell or otherwise convey, on such terms as he deems to be in the best interests of the United States (U.S.) & in furtherance of the purposes of this chapter, any & all right, title, & interest of the U.S. in & to the property, both real & personal, held by the Secretary on the Pribilofs: Provided, That such property is specified in a document entitled "Transfer of Property on the Pribilof Islands: Descriptions, Terms & Conditions," which is submitted to the Congress on or before October 31, 1983. (b) Contents of property transfer document - shall include, but need not be limited to: (1) a description of each conveyance; (2) the terms to be imposed on each conveyance; (3) designation of the recipient of each conveyance; (4) a statement noting acceptance of each conveyance, including the terms, if any, under which it is accepted; & (5) an identification of all Federal property to be retained by the Federal Government on the Pribilofs to meet its responsibilities as described in this chapter & under the Convention. (c) Report to Congress of fair market value of transferred property - Within 60 days of the transfer of real or personal property specified in the document described in subsection (a) of this section, the Committee on Merchant Marine & Fisheries of the House of Representatives & the Committee on Commerce, Science, & Transportation of the Senate shall be given a report prepared by the Secretary stating the fair market value at the time of the transfer of all real & personal property conveyed. (d) Memorandum of Understanding (MOU)- A MOU shall be entered into by the Secretary, a representative of the local governmental authority on each Island, the trustee or trustees, & the appropriate officer of the State of Alaska (the State) setting forth the respective responsibilities of the Federal Government, the Trust, & the State regarding - (1) application of Federal retirement benefits, severance pay, & insurance benefits with respect to Natives of the Pribilofs; (2) funding to be allocated by the State for the construction of boat harbors on St. Paul & St. George Islands; (3) assumption of the State of traditional State responsibilities for facilities & services on such islands in accordance with applicable laws & regulations; (4) preservation of wildlife resources within the Secretary's jurisdiction; (5) continued activities relating to the implementation of the Convention; (6) oversight of the operation of the Trust established by section 1166(a) of this title to further progress toward creation of a stable, diversified, & enduring economy not dependent up commercial fur sealing; (7) the cooperation of government agencies, rendered through existing programs, in assisting with an orderly transition from Federal management & the creation of a private enterprise economy on the Pribilofs as described in this chapter; & (8) such other matters as may be necessary & appropriate for carrying out the purposes of the chapter, including the assumption of responsibilities to ensure an orderly transition from Federal management of the Pribilofs. Louis Howard
9/30/1986 Update or Other Action The 1986 formerly used defense sites (FUDS) cleanup project included work on nine (9) separate sites on the island. Based on all the information provided to date, the Corps has not demonstrated that the following areas were adequately characterized, cleaned up or closed: the LORAN Station at Southwest Point - FUDS site A in the 1985-86 cleanup, the Oil Drum Dump Site #1 - site B-1 in the FUDS cleanup, the Barrel Dumps north and east of Big Lake - sites B-2 and B-4 in the FUDS cleanup, and the FUDS Landfill created near the Big Polovina Hill Vehicle boneyard. The documents called for cleaning up hazardous spills and sampling to verify the level of cleanup. Site logs produced by the contractor show that some contaminated soil was excavated and transported to the solid waste disposal area a.k.a. FUDS landfill for disposal. It is unclear what types and concentrations of contaminants were present in the soil that was placed in the FUDS landfill. Chase Construction, Inc., under contract to the U.S. Army Corps of Engineers (USACE), removed debris and drums from FUDS on St. Paul Island (Chase Construction, Inc. 1986). Approximately 4,000 rusted drums with petroleum product and antifreeze markings were removed from FUDS B-1. The empty drums were crushed and placed in a burial trench near the Vehicle Boneyard (TPA Site 2). Drums judged to be non-military in origin, approximately 350 drums, were placed atop the central pad and left in place without further action being taken. Louis Howard
12/22/1986 Update or Other Action Memorandum of Understanding among: TDX (St. Paul Island Village Corporation), TANAQ (St. George Island Village Corporation), and United States Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service (USDOC NOAA NMFS) regarding Pribilof Islands Land Selections. Negotiations undertaken by the parties to resolve potential conflicts between village corporation and federal land selections on the Pribilof Islands under the Alaska Native Claims Settlement Act (ANCSA) were successfully concluded during a third meeting held on St. George Island in June 1974. The Parties desired to record the items agreed upon during this meeting and during the two previous negotiating sessions held on St. Paul Island in April 1974 and in Seattle WA in February 1974. The parties intend that this record of agreed items serve as a permanent background against which to compare and construe the land selection requests made by the parties to the BLM, Dept. of Interior, pursuant to the ANCSA. Ray Dronenburg
9/30/1991 Update or Other Action Discovery action entered in CERCLIS No Further Remedial Action Planned (NFRAP) Sites for Saint Paul Island EPA ID AKD983066127 on 11/01/1988. A preliminary assessment was entered in on 9/30/1991 for a no further remedial action planned determination under CERCLA. EPA's NFRAP designation will NOT relieve the facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120*(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. NOTE TO FILES: SEC. 120 [42 U.S.C. 9620] Federal Facilities [§120 added by PL 99-499] (a) Application of Act to Federal Government.- 1) In general. -- Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act. Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107. (2) Application of requirements to federal facilities. -- All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act. (3) Exceptions. -- This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States. (4) State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. Jennifer Roberts
1/8/1992 CERCLA PA EPA CERCLA (conducted by ADEC staff Jennifer Roberts July 29 and 30, August 1, 1991 under contract to U.S. EPA) Preliminary Site Assessment Report December 1991 received by ADEC staff. The PA was conducted to identify potential public health and/or environmental hazards related to the site and, if present, identify the need for further investigative action. The PA is based on information derived from available files and literature pertaining to the site and a site visit. Sites covered by this PA: Site A-East Airport Barrel Dump, Site B-Tonki Point Dump Site, Site C-Telegraph Hill (NOAA TPA 15 Scoria Pits), Site D-Southwest Point-WWII LORAN Station, Site E-Ridge Wall Pit (NOAA TPA 15 Scoria Pits), Site F-DERA description said this site was located on the Roadside between Middle Hill and Southwest Point-Not located during PA and locals had no knowledge of site, Site G: Landing Craft in Saint Paul, Site H-Miscellaneous Debris in town, and WWII bunker located Polovina Road below the new housing S/D where NMFS reportedly stored old dynamite caps, Site I-Bone Yard (NOAA TPA 2 Vehicle Boneyard) Site A: East Airport Barrel Dump had 200-300 55 gallon drums with most appearing to be at least partially full. Bungs are missing and tops are bulging with soil staining evident and a strong benzene odor was noted. Recommendations: No further action is warranted under CERCLA program. Nature of contamination and the low density population precludes further action under the CERCLA program. Recommendations by CERCLA PA for the Island: 1) the remaining drums be located and removed, 2) the reports of the bunker containing dynamite capes be verified, and 3) all explosives discovered be either removed by trained professionals or stored in accordance with current safety standards and codes (i.e. Standard Number: 1910.109 Standard Title: Explosives and blasting agents. SubPart Number: H SubPart Title: Hazardous Materials). Jennifer Roberts
10/30/1992 Update or Other Action In October 1992, Ecology & Environment, Inc. (E&E) performed a preliminary assessment of the Oil Drum Dump Site (E&E 1993). Approximately 350 rusted drums were observed on the central pad. The drums reportedly contained petroleum products. Ponded water was observed on the north side of the pad, and drums were scattered in a depression on the south side of the pad. In some areas at the site, the soil appeared to be saturated with oil. Jennifer Roberts
12/31/1992 Update or Other Action Harding and Lawson Associates (HLA), under contract to US Army Corps of Engineers (USACE), inventoried and removed drums at the Oil Drum Dump Site (TPA 01) in 1992 following the preliminary assessment. The contents of 310 drums were inventoried. Seven of the inventoried drums were empty or contained solid material. The other drums were field categorized for waste material compatibility. The content of 203 drums was nonflammable oil or nonflammable fuel/oil mixed with water. Fifty-one drums contained flammable fuel, flammable oil, or flammable fuel/oil mixed with water. Chlorinated compounds were identified in eight of the drums. The remaining drums contained water or other waste types. Contents from 201 of the 310 drums were bulked into 154 new drums. The newly bulked drums and the 201 emptied drums were transferred to a lined containment area (staging area) located west of the Vehicle Boneyard (TPA Site 2) where bulked drums were sampled for waste management profile and energy recovery testing. The remaining inventoried drums, including those found empty, were left at the site. Ray Dronenburg
2/28/1993 Update or Other Action Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV). Oil Drum Dump Site located 1.5 mi. east of the airport and 4 mi. northeast of the city of Saint Paul. 350 rusted drums are located in a mound in the middle of the site. Drums are scattered in a depression on the south side of the mound and the southern slope of the mound was visibly stained. In some areas within the dump area, the soil appeared to be saturated with oil. No OV was detected using the PID during ambient air monitoring, but a strong petroleum odor was present downwind of the site. Recommended actions were to sample the surface and subsurface of the soils to determine the nature and extent of petroleum, oils, and lubricants (POL) and possible CERCLA contamination. Other items brought to E and E's attention during site visits include heating oil USTs associated with housed built by NOAA on Saint Paul. On Saint Paul, 300 gallon heating oil USTs are associated with the older homes in the city. Residents of these homes are concerned with their liability associated with the leaks in the tanks. 4/23/1993 update-Scheduled to be bulked, sampled and moved (Minutes from 5/15/1993 Pribilof Island conference). Jennifer Roberts
9/30/1993 Update or Other Action U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report. Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. Ray Dronenburg
10/19/1993 Update or Other Action Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation. Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it. The current construction season has passed, to allow us the necessary time to schedule the equipment, NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May, 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. Ray Dronenburg
11/18/1993 Update or Other Action Memorandum from Dronenburg to Bruce Erickson Western District Manager regarding the November 16-18 1993 Pribilof Island Conference. NMFS has done a considerable amount of environmental damage over the years, but because they have no funding source to cleanup the contamination, NOAA is the project leader. Unfortunately, NOAA has never been involved in a project similar to this and are stuttering. Dronenburg was aware that in September 1993 they (NOAA) actually went to Saint Paul Island and cleaned up some 140 drums of contaminated waste (TPA 01). NOAA did not keep any records on the waste, they simply put it on a vessel and took some to Dutch Harbor, Delta Western and some to Seattle WA. NOAA told Dronenburg that these fuels were contaminated with water, but could not state to what extent. ADEC has suspicions as to the reliability of Delta Western when decanting water from fuels. It appears NOAA has been doing a lot of "in house" sampling and thought the work would satisfy ADEC requirements for site assessment, etc. There is no one on NOAA's staff with Quality Assurance training. There are considerable amounts of soils to be removed and stockpiled for remediation. Dronenburg was able to convince NOAA that a sampling plan would be required and a plan for stockpiling would be required. There is discussion that some contamination exists when a pipe that ran between an old above ground storage tank and a generator was cut by accident and capped. This site will require excavation (TPA 10 or 11?). Additionally, there are considerable issues that are not clear; (i.e. the seep at the salt marsh (TPA 13-1) and at the school playground (STG TPA 7)-are they related to NMFS and how to fund them. Ray Dronenburg
9/21/1994 CERCLA SI Woodward Clyde CERCLA Site Inspection Report performed for U.S. EPA on three sites on Saint Paul Island. They were the: 1) Oil Drum Dump Site (later to be known as TPA 01 STP Oil Drum Dump Site), 2) the Sanitary Landfill Site, and the Power Plant Site. Twenty-two (22) soil samples, fourteen (14) sediment samples and four (4) surface water samples total were taken from the landfill and drum site. In June 1994, Woodward-Clyde conducted a site inspection at the Oil Drum Dump Site (Woodward-Clyde 1994). Woodward-Clyde found about 100 drums in a group on top of a mound in the middle of the site (i.e., the central pad) at the time of inspection. They observed stained soils and leaking drums. Six soil samples, six sediment sediment samples, and one surface water sample were analyzed for pesticides and polychlorinated biphenyls, volatile organic compounds (VOCs), semivolatile organic compounds, and target analyte list metals. Results were compared to human health, risk-based concentrations (RBCs) developed by U.S. Environmental Protection Agency (USEPA) Region III. Organic compounds were not detected in any media at concentrations exceeding the USEPA screening criteria. Arsenic (As), beryllium (Be), and manganese (Mn) were detected in soil and sediment samples at concentrations exceeding USEPA screening criteria. Individual organic compounds were not detected or estimated in any media exceeding conservative EPA human health, risk based screening criteria. Only three (3) TAL metals: arsenic, beryllium, and manganese were detected in the soil and sediment samples greater then the EPA screening criteria. Chromium (Cr) and nickel (Ni) concentrations exceeded their Method Two soil cleanup levels of 26 mg/kg and 87 mg/kg, respectively. No analytes other than those metals exceeded the ADEC Method Two cleanup levels. Comparing the metals in soil samples to those from background showed that the results are comparable and not above an action level. The samples were not analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO) or benzene, toluene, ethylbenzene, and total xylenes (BTEX). However, Woodward-Clyde identified these compounds as contaminants of potential concern (COPCs) due to their expected presence at the site. Archive EPA records show NFRAP for USDOC NOAA NAT Marine Fisheries Service EPA ID AK0131490021. No further remedial action required under CERCLA entered on 11/02/1994 for the site inspection action. Site Inspection: identifies sites that enter the NPL Site Listing Process and provides the data needed for Hazard Ranking System (HRS) scoring and documentation. SI investigators typically collect environmental and waste samples to determine what hazardous substances are present at a site. They determine if these substances are being released to the environment and assess if they have reached nearby targets. The SI can be conducted in one stage or two. The first stage, or focused SI, tests hypotheses developed during the PA and can yield information sufficient to prepare an HRS scoring package. If further information is necessary to document an HRS score, an expanded SI is conducted. The EPA publication Guidance for Performing Site Inspections Under CERCLA; Interim Final, September 1992, (NTIS PB92-963375, EPA 9345.1-05) provides more information on conducting SIs. Ray Dronenburg
11/2/1994 Update or Other Action EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin Chief U.S. DOC Western Administration Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700 Seattle WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly. EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. Jennifer Roberts
1/27/1995 Update or Other Action January 27, 1995 Attorney General (AG) letter to NOAA General Counsel regarding environmental restoration agreement AGO file # 661--95-0126. January 13, 1997 NOAA letter does not address NOAA's obligation under federal environmental statutes. In particular, NOAA has not addressed its obligations under CERCLA, RCRA, TSCA and the open dump provisions of RCRA 40 CFR Part 257. Delegation of a federal program allows a state to enforce its program "in lieu of the federal program" See e.g. 42 USC 6926 (b). If a state program is not delegated EPA retains its right to enforce the federal program. The fact that the state has not received authorization to implement the federal program does not deprive state law of effect. To construe the federal statutes otherwise, is to render the state authority savings clauses and waivers themselves without meaning. Since the Pribilof sites are not on the NPL, section 113(h) of CERCLA does not apply at all to the case at hand. With or without RCRA delegation, the State of Alaska can enforce its solid and hazardous waste laws. Should CERCLA removal or remedial actions be pursued to address hazardous substances at any of the Pribilof Island sites, those actions would have to comply with Alaska laws under the ARARs provisions of CERCLA. See 42 USC 9621 40 CFR 300.430. The second legal misconception NOAA has is that Alaska's statutes and regulations lack sufficient specificity to waive sovereign immunity. 18 AAC 70 and 60 demonstrate these provisions set forth concise, objective, standards, including numerical pollutant concentrations. Rather than debate NOAA's interpretation of the federal sovereign immunity statutes, we would prefer to delineate which sites NOAA is prepared to address under the terms of proposed remediation agreement. If NOAA is serious in this legal position that it has no responsibility and is unwilling to move forward then it would behoove the parties to seek resolution through judicial or other means rather than fruitless debate. We hope however, that your recent letter is more of a "pro forma" denial of liability before NOAA does the "right thing" by addressing the contamination left on the islands by the federal activities. As Chairman Don Young's letter of December 14, 1994 indicated, it is time to address this continuing problem of federal contamination on native lands and to stop federal land managers flight from responsibility for cleaning up those lands. Ray Dronenburg
6/1/1995 Site Added to Database Site added to database. Ray Dronenburg
8/2/1995 Update or Other Action In September 1994, Oil Spill Consultants inspected the Oil Drum Dump Site and found 174 drums and heavy soil staining. The tops and sides of the drums were covered with oil. Each drum contained a 6- to 8-inch layer of water, which likely resulted from precipitation that entered the drums through punctures. Drums were sampled for onsite field screening. Based on field screening results, drum contents were consolidated and shipped to Basin Oil Company in Seattle, Washington Ray Dronenburg
1/6/1996 Update or Other Action Congress passed Public Law 104-91 which was also known as H.R. 1358. Section 3 Pribilof Islands (a) In General. The Secretary of Commerce shall, subject to the availability of appropriations provided for the purposes of this section, clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants, including petroleum products and their derivatives, left by the National Oceanic and Atmospheric Administration on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred or are obligated to transfer, to local entities or residents on the Pribilof Islands, Alaska, pursuant to the Fur Seal Act of 1966 (16 U.S.C. 1151 et seq.), as amended, or other applicable law. (b) Obligations of Secretary. In carrying out cleanup activities under subsection (a), the Secretary of Commerce shall—(1) to the maximum extent practicable, execute agreements with the State of Alaska, and affected local governments, entities, and residents eligible to receive conveyance of lands under the Fur Seal Act of 1966 (16 U.S.C. 1161 et seq.) or other applicable law; (2) manage such activities with the minimum possible overhead, delay, and duplication of State and local planning and design work; (3) receive approval from the State of Alaska for agreements described in paragraph (1) where such activities are required by State law; (4) receive approval from affected local entities or residents before conducting such activities on their property; and (5) not seek or require financial contributions by or from local entities or landowners. (c) Resolution of Federal Responsibilities. (1) Within 9 months after the date of enactment of this section, and after consultation with the Secretary of the Interior, the State of Alaska, and local entities and residents of the Pribilof Islands, the Secretary of Commerce shall submit to the Committee on Commerce, Science, and Transportation of the Senate, and the Committee on Resources of the House of Representatives, a report proposing necessary actions by the Secretary of Commerce and Congress to resolve all claims with respect to, and permit the final implementation, fulfillment and completion of (A) title II of the Fur Seal Act Amendments of 1983 (16 U.S.C. 1161 et seq.); (B) the land conveyance entitlements of local entities and residents of the Pribilof Islands under the Alaska Native Claims Settlement Act (43 U.S.C. 1601 et seq.);(C) the provisions of this section; and (D) any other matters which the Secretary deems appropriate. (2) The report required under paragraph (1) shall include the estimated costs of all actions, and shall contain the statements of the Secretary of Commerce, the Secretary of the Interior, any statement submitted by the State of Alaska, and any statements of claims or recommendations submitted by local entities and residents of the Pribilof Islands. (d) Use of Local Entities. Notwithstanding any other law to the contrary, the Secretary of Commerce shall, to the maximum extent practicable, carry out activities under subsection (a) and fulfill other obligations under Federal and State law relating to the Pribilof Islands, through grants or other agreements with local entities and residents of the Pribilof Islands, unless specialized skills are needed for an activity, and the Secretary specifies in writing that such skills are not available through local entities and residents of the Pribilof Islands. (e) Definition. For the purposes of this section, the term ``clean up'' means the planning and execution of remediation actions for lands described in subsection (a) and the redevelopment of landfills to meet statutory requirements. (f) Authorization of Appropriations. There are authorized to be appropriated not to exceed $10,000,000 in each of fiscal years 1996, 1997, and 1998 for the purposes of carrying out this section. Ray Dronenburg
2/1/1996 Update or Other Action Breck Tostevin letter to NOAA Office of General Counsel Kathleen Chorostecki. AGO File Number 661-95-0126. The January 3, 1995 NOAA letter in response to AG's letter of December 7, 1994 to NOAA. NOAA letter does not address NOAA's obligations under federal environmental statutes (CERCLA, RCRA, TSCA, and the open dump provisions of RCRA. 40 C.F.R. Part 257). NOAA's analysis of the waivers of federal sovereign immunity in the federal statutes is premised on two (2) fundamental legal misconceptions. The first is that a state must have a "delegated federal program" in order for its laws to be considered "requirements" within the meaning of the waivers in the Clean Water Act or the Solid Waste Disposal Act. This conclusion is contrary to the plain terms of the two acts. The waiver sections speak of state and local "requirements" respecting "water pollution" and "solid and hazardous wastes". 33 U.S.C. 1323, 42 U.S.C. 6961. Nothing in the waiver sections limit these state and local requirements to those that are part of a federal program delegation. Rather, delegation of a federal program allows a state to enforce its program "in lieu of the federal program". See e.g. 42 U.S.C. 6926(b). If a state program is not delegated, EPA retains the right to enforce the federal program. The fact that a state has not received authorization to implement the federal program does not deprive state law of effect. NOAA's reliance on U.S. v. State of Colorado, 990 F.2d 1565, 1569 (10th Cir. 1993) is misplaced in that it does not stand for the proposition that "only under an EPA-authorized program may a state impose upon a federal agency state law requirements concerning activities "under RCRA." The site at issue in Colorado was Basin F of the Rocky Mountain Arsenal which EPA in 1989 placed on the Superfund National Priorities List (NPL). The U.S. Army sought to block Colorado's enforcement of its delegated hazardous waste program at the site on the grounds that CERCLA barred inconsistent state remedies. The 10th Circuit held that Colorado's administrative order under its delegated hazardous waste laws was not a "challenge" to CERCLA response action within the meaning of 113(h) of CERCLA. Since the Pribilofs are NOT on the NPL, section 113(h) of CERCLA does NOT apply at all to the case at hand. With or without RCRA delegation, the State of Alaska can enforce its solid and hazardous waste laws. Rather than restricting the rights of states to enforce their environmental laws, the Colorado case was important in its recognition of the important role states have in ensuring federal compliance with our nation's laws. Should CERCLA removal or remedial actions be pursued to address hazardous substances at any of the Pribilof Island sites, those actions would have to comply with Alaska laws under the ARARs provisions of CERCLA. See 42 U.S.C. 9621, 40 CFR 300.430. The second legal misconception is that Alaska's statutes and regulations "lack sufficient specificity" to waive sovereign immunity. A careful examination of Alaska's water quality regulations (18 AAC 70) and its solid waste regulations (18 AAC 60) demonstrate that these provisions set for the concise, objective standards, including numerical pollutant concentrations. Even with respect to narrative standards, the United States Supreme Court has concluded that such provisions are enforceable as "requirements" Washington Department of Ecology, 114 S. CT. 1900, 1910-11 (1994) (recognizing that criteria "are often expressed in broad, narrative terms, such as 'there shall be no discharge of toxic pollutants in toxic amounts.'"). Similarly, in a CERCLA ARARs case, the Sixth Circuit Court of Appeals concluded that "general requirements containing no specific numerical standards, or any implementing regulations, can be enforceable ARARs" U.S. v. Akzo Coating, 946 F.2d 1409 142 (6th Cir. 1991). Ray Dronenburg
5/2/1996 Site Ranked Using the AHRM Ranked by Shannon and Wilson S&W
12/31/1996 Update or Other Action NOAA collected two composite surface soil samples in October 1996 from stained areas of the central pad (i.e., TPA Site No. 1) at the Oil Drum Dump Site. Samples were analyzed for DRO, RRO, and total recoverable petroleum hydrocarbons (TRPH). SPCOMP 1, a sample composited from the southwest half of the pad, contained 4,400 mg/kg DRO, 38,000 mg/kg RRO, and 51,000 mg/kg TRPH. SPCOMP-2, a sample composited from the northeast half of the pad, contained 7,300 mg/kg DRO, 43,000 mg/kg RRO, and 50,000 mg/kg TRPH. ADEC Method Two soil cleanup levels for DRO and RRO are 250 mg/kg and 10,000 mg/kg, respectively. Ray Dronenburg
5/28/1997 Update or Other Action Michelle Brown ADEC Commissioner letter to NOAA Deputy Undersecretary Josephson regarding "Secretary's Report on the Pribilof Islands as required by Public Law 104-91." ADEC has concerns with the report, in particular Section H of the report entitled "Environmental Cleanup." ADEC does not agree with page 33 that "to date, no testing has revealed contamination posing a threat to human health or the environment." During summer of 1989, ADEC has issued a notice of violation ( NOV) to NOAA for contamination caused by a visible oil sheening to a sensitive bird nesting area on Saint Paul Island known as the salt lagoon. After a long delay and an unsuccessful attempt by NOAA to mitigate this problem, a second NOV was issued on March 3, 1994. Based on NOAA's test reports submitted to ADEC staff, it is estimated that over 30,000 cubic yards of contaminated soil remain on Saint Paul Island, which, along with other hazardous material, presents an ongoing threat to the Island's water supply and a direct threat to human health and the environment. The report's assertions appear to conflict with the spirit and intent of the Two-Party Agreement negotiated in January 1996 between NOAA and ADEC, which is to address the sites contained in the agreement based upon ADEC's review of the technical merits. To date, NOAA has committed in excess of 12,000,000 dollars for restoration work on the islands for fiscal year 1997. However, the balance of the funds authorized by Congress for the restoration work was not included by NOAA as a line item appropriation in the President's FY 1998 budget submitted to Congress. NOAA has indicated it intends to fund an additional 10,000,000 dollars of work necessary to complete its work on the islands from its general budget. Ray Dronenburg
12/31/1997 Update or Other Action In 1997, Bering Sea Eccotech removed the majority of the remaining bulk surface debris, as part of Phase I cooperative agreement with NOAA (Aleutian Enterprises 1997). Soil samples were not collected during the debris removal. Ray Dronenburg
5/20/1998 Update or Other Action Laura Ogar Solid Waste Program re: Expectations for Remaining Work and Regulatory Compliance for Solid Waste Projects Pribilof Islands. Of primary importance to the Department will be NOAA's assessments of the source areas (SA) to identify the extent of solid waste and any solid waste impacts at each site. Specific expectations for the SA's include: Documentation at SA's containing buried waste must include and estimation of the footprint area and depth of the waste material and include the site longitude and latitude to accurately identify the waste disposal area. Information on groundwater (depth to, gradient, etc,) must also be provided. Information must be provided on the depth to groundwater as a potential receptor for contamination if buried waste is present and/or suspected surface contamination is sufficient to warrant concerns for leaching. Where surface debris has been removed, the Site Investigation will be required to include evidence to support a conclusion that surface contamination does not exist. Any surface debris removal must be fully documented to include a description of the volumes and types of wastes removed, and identify the approved final disposal location of any wastes removed from a SA through tipping fees, shipping records, etc. Locations where buried waste will remain in the ground, solid waste landfill closure standards of 18 AAC 60 must be met. Typical landfill closure standards include the placement of final cover over the buried waste footprint to minimize infiltration and erosion. The applicable closure standards for the individual sites should be discussed with the SW Program staff prior to the development of a closure plan being developed. A closure plan must be submitted to the SW Program for review and approval prior to work being performed. Permanent markers or survey monuments must be established from which the exact location of a facility can be determined. A notation must be recorded on the deed of the property containing the waste disposal site stating that the land has been used as a landfill and future use of the land may be restricted in order to protect and maintain the final cover and any monitoring devices in place. Post closure monitoring for a period of five (5) years following the placement of final cover and landfill closure. Post closure monitoring will include but may not be limited to annual visual monitoring of the sites and required looking for signs of damage settlement or erosion. Surface and or ground water monitoring may be required if the department finds that pollution from the facility is likely to endanger public health or cause a violation of the water quality standards in 18 AAC 70. Ray Dronenburg
6/28/1998 Site Visit 28 June 1998, Rev. 0,SITES SUMMARY, TRIP REPORT, 01-06 JUNE 1998, PRIBILOF ISLANDS ORIENTATION TRIP, by DAVID B. WINANDY. Item 16 Description: Former Drum Storage Site - East of NWS, Two Party Agreement-Oil Drum Dump Site, No. 1, OUC No. 6. NOTES: 1) Site cleared. 2) Surface PCS weathering and vegetation encroaching. 3) No visible oil sheen on either upper or lower perched lakes/marsh areas. 3) On dune hillside opposite, areas of steel metal fragments on surface. 4) On lower perched lake/marsh area immediately below former drum site, low water levels exposed bed. Drum sections, fragments and bed springs atop and protruding from marsh bed. Possible 401 Permit for wetlands. General Overall Impression. 1. Typical remote site and seasonal weather logistic challenges and difficulties for any project. 2. Although not completed, a great deal of debris has been removed from St. Paul Island and the landscape improved by the Phase I Debris Removal. 3. Project management will be subject to the City, TDX, TDX Subsidiary and Subcontractors, Aleut Corporation, Traditional Council, NOAA HQ, NOAA WASC, NOAA NMFS, NOAA NWS, USF&W, USACE, State of Alaska, and NOAA Contractors interactions. This is coupled with distance and time zone differences. Ray Dronenburg
7/16/1998 Update or Other Action CORPS Robert Chivvis 7/14/1998 letter to John Halverson regarding 5/8/98 letter requesting information on Corps cleanup work on Saint Paul and Saint George Islands. With regards to the 3 monitoring wells and monitoring requirements for 3 years, the Corps suggests ADEC address its concerns to the CORPS' contractor Chase Construction. They constructed the landfill and obtained the Permit to dispose of not only the CORPS' non-hazardous debris, but also other debris located on the island as directed by the local Native leaders. Information on all FUDS cleanup work done on the islands was compiled and made available to Ray Dronenburg who visited the Corps office last month (June 1998). He was satisfied with the information provided in order to address the subject at the next Pribilof Islands RAB meeting. John Halverson
8/5/1998 Potentially Responsible Party/State Interest Letter John Halverson sent a potential responsible party notification letter to NOAA Mr. Minh Trinh. The letter is to advise NOAA that a pollution incident potentially exists for which NOAA may be a liable party. Potentially five (5) sites have been identified which are associated with the Army Corps of Engineers actions during a project which occurred in the 1980s. These sites are on NOAA property or property that were conveyed by NOAA to other parties. (Public Law 104-91 states, in part "The Secretary of Commerce shall clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants, including petroleum products and their derivatives, left by the National Oceanic and Atmospheric Administration (NOAA) on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred or are obligated to transfer, to local entities or residents on the Pribilof Islands, Alaska..." Consistent with the Two Party Agreement, the Department is requesting that all sites as determined by those data available be added to the agreement and investigation be conducted as appropriate to determine (a) the level of contamination, and (b) appropriate clean up action if required. Site description and location maps are attached for NOAA's information and no action dates have been established at this time. However, please respond in writing within 30 days from the date of this letter addressing your responsible party status and intended actions with respect to these pollution incidents. John Halverson
9/1/1998 Update or Other Action NOAA letter dated 8/27/1998 from Thanh Minh Trinh regarding 8/5/1998 PRP letter notification. While NOAA appreciate ADEC's need to remediate the sites, it is troubling to NOAA that a failure to follow through by the Corps on the pre-existing agreement with the Corps could result in this type of action against NOAA. During the negotiation of the TPA, it was NOAA's understanding that ADEC would pursue an independent course of action on the FUDS sites. It is still NOAA's position that this is the appropriate course of action. The financial resources to address cleanup have come as special Congressional appropriations (NOTE: Not in the Department of Commerce Budget submitted by NOAA for the Pribilof Islands Agreement). NOAA does not have a congressionally supported and funded formal program for cleanup like the Corps and FUDS program. NOAA's position is that the TPA addresses all the requirements under Section (3) of PL 104-91. NOAA's position is that PL 104-91, as a federal law, does not give rise to any new authority for the State to compel remediation of another agency's former contamination. It is doubtful that any additional funding will be made available for subsequent remedial actions when a Congressionally funded program already exists to address this issue (i.e. DOD/FUDS). In light of the foregoing, please be advised that NOAA will not entertain reopening the TPA to address these sites. With regard to Alaska's separate action of pursuing NOAA as an owner/operator PRP under Alaska Statute, this matter has been referred to legal counsel for an analysis of sovereign immunity and potential referral to the Department of Justice. Initial reactions are that the State does not have authority to bring action against the Federal Government. This position is consistent with the underpinnings of negotiations undertaken with Breck Tostevin at the time of the TPA negotiation in 1995. Ray Dronenburg
9/30/1998 Update or Other Action Jacobs Engineering Group Inc. Investigation Workplan received. Data quality objectives: Initial sampling round will try to determine if Oil Drum Dump can be closed. Plan is to collect soil samples from up to 3 borings per site, install monitoring wells, and collect groundwater samples from each well. Comments in document: sampling is limited to one soil sample from the most contaminated interval and one groundwater sample at each boring/well. Analyses: GRO, BTEX, DRO, RRO, PAH, RCRA metals, for all 3 wells. Ray Dronenburg
10/23/1998 Update or Other Action October 23, 1998, the Corps Office of Counsel letter sent to Ray Dronenburg regarding Saint Paul Request for Information and Position on PRP Status. In our meeting on September 17, 1998, we agreed to research our records and provide information relative to contract performance and closeout with reference to soil and groundwater results. Canvassing District Personnel was unsuccessful for locating soil or groundwater results. Ray Dronenburg
10/26/1998 Update or Other Action Letter to Minh Trinh NOAA project manager. The Department has spent some time attempting to resolve the contention that debris remaining on St. Paul and St. George Islands are the property of military versus NOAA versus National Marine Fisheries Service. Records that are available in the National Archives Facilities in Anchorage, Alaska reveal that ALL goods (both permanent and renewable) came on the island at the direction of NOAA and for the purpose of NOAA. All supplies came by "Cool Barge". Cool Barge was a military operation originating in Oakland California (Navy Supply Depot) and which carried supplies, all of which were marked with Federal Stock Numbers. The exception to this was under the exclusive use of the Army during the period by 1942 to 1946. However, records again available in the National Archives, indicate that materials abandoned on the Pribilofs by the military and after occupation were utilized by the NOAA for the purpose of NOAA. ADEC strongly suggests that NOAA retain the services of a person or persons to review this historical data which ADEC believes will provide information to support the contention that debris left on the Islands is the responsibility of the Federal Government. Ray Dronenburg
11/2/1998 Update or Other Action ADEC's Responses to "relevant facts" the AK District raised in its October 23, 1998 letter. The Corps letter refers to recent DOD Site Assessment report as support of its position that no further assessment or cleanup is necessary and that the landowner concurs. The Pribilof Islands Site Assessment Report, prepared for the Office of the Deputy Under Secretary of Defense March 31, 1998 is a draft report. DEC and the Aleutian Pribilof Island Association both provided comments on the draft stating that concerns over DOD impacts to the Islands have not been adequately addressed. The assessment did not include any sampling or even a trip to the site, but was done through phone calls, letters, and review of historical records (which are incomplete and do not document adequate cleanup). NOAA as a landowner/manager has clearly state its position that DOD has further obligations to investigate and cleanup these FUDS. Item number five on page two of the Corps letter states: ""Chase Construction was responsible for and did, in fact, arrange for disposal, not the Corps of Engineers. Therefore ADEC has failed to show that the Corps is subject to AS 46.03.822."" However, on the contrary, it is very clear that the Corps contracted with Chase Construction to dispose of DOD waste. Therefore the Corps is liable under AS 46.03.822(a)(4) which provides that ""any person who by contract, agreement, or otherwise arranged for disposal... of hazardous substances..."" is strictly liable. The Corps is also liable as a person who arranged for disposal under 42 U.S.C. 9607(a)(3) and 42 U.S.C. 6973. Item number ten refers to a 1987 letter from DEC which indicated that submitall of photographs or as-built drawings showing the location of the landfill would allow for closing the file on the landfill. However, the photographs or as-built drawings are required under condition ""H"" (Reporting). Groundwater monitoring is required under permit condition ""G"" (Monitoring). They are separate and distinct requirements that cannot be modified without a written permit amendment (see permit Appendix A at A). The letter states that a St. Paul Landfill Closure Report dated February 1996 and photographs were submitted to DEC to meet closure requirements. However, DEC has received a draft report, dated December 1, 1995, but has no record of receiving a final closure report or the photographs that are referenced. Nor has DEC received groundwater monitoring data that was required under the permit. Therefore, the landfill is not in compliance with permit requirements and has not been properly closed. Item number eleven states that DEC has not provided any documentation of releases by DOD subsequent to 1986. However, the Corps has failed to demonstrate that it adequately cleaned up releases that were documented before 1986. In fact, several people have documented that crushed, rusted drums and soil contamination remain at Telegraph Hill. No documentation has been provided on the types or concentrations of contaminants that were in soil buried in the landfill. The required groundwater monitoring has not been conducted, thus it is unclear whether contaminants are leaching from the waste, impacting groundwater and posing a risk to human health, safety or welfare or to the environment. Item number twelve states, "Any contamination left at the disposal site was permitted by ADEC and cannot be grounds for further action." Again, to the contrary, the solid waste disposal permit specifically stipulates, in condition "I" "Pollution, as defined in AS 46.03.900, resulting from the operation of this permitted facility, constitutes a violation of this permit... and/or criminal penalties. Additionally, the Permittee may be required to monitor, evaluate impacts, and provide restoration...". Since the permit was obtained for, and work was performed and generated during a FUDS cleanup, responsibility for resolving these issues extends to the United States Army Corps of Engineers and ultimately the Federal Government. John Halverson
11/15/1998 Update or Other Action General comments on NOAA remediation work plan for St. Paul Island submitted by Bering Sea Eccotech (BSE). this preliminary work plan is not acceptable due to lack of information on groundwater and the unknown extent of contaminated soil. The extent of petroleum contaminated soil, as described in the plan, may not be accurate. I am concerned that the estimate is not high enough. Without the proper release investigation having been done at all the sites to determine the horizontal and vertical extent of contamination prior to application of in-situ remediation, NOAA is running the risk of having to return to the sites in the future to continue work. Another distinct area lacking information is the manner, method of application, and contents of the bio-augmentation material. Monitoring of the product, both in soil and in groundwater, will be required. Finally, without information on depth to groundwater and information on water quality, use of alternative cleanup levels is not acceptable. NOAA will need to obtain Department approval for the HAVE facility, in accordance with standard Department policy and it is consistent with other such facilities throughout the State. Clarification is needed on how BSE arrives at the estimates of contaminated soil to be remediated. It should explain, in detail for each site, how they determined the estimates and on what data was used. Maps of the remaining petroleum contaminated soil (PCS) with depth and area should be provided to assist NOAA in taking confirmation samples after remediation activities. However, providing this may be difficult, since investigation in prior phases of work was so limited. For all sites, the screening and sampling regime should be outlined in detail. This includes visual and olfactory inspection, the manner in which field instruments like a PID or FID will be used, the planned depth and location of both screening and sampling locations, and exactly what sampling will be done. This last is presented somewhat in the appendices, but needs to be further outlined. Revegetation details should be discussed, e.g. plant materials, how will the windblown areas be stabilized while the work is underway, etc. Marsh restoration requires a Wetlands Permit and a storm water plan. Bioaugmentation: Will need to know what is in the nutrient brew and other additives. Will need to know specifics of application. If, as it appears, the method of application is through water, then there will need to be a lot more discussion on how they plan to monitor the product. Frankly, unless they can show that there is no impact to groundwater, it’ll need to include monitoring wells, etc. The nutrients themselves may pose a hazard and will require monitoring. Any debris should be inspected for contamination prior to disposal. Perhaps a line item concerning the potential problems associated with disposal of contaminated material would be appropriate, e.g. the concrete saddles and other solid waste. Need more information on how the excavations remaining open will be kept off-limits to the general public until backfilled, e.g. fences. The plan discusses ‘negotiated’ cleanup levels. There may not be enough information exists at present for the Department to be completely comfortable defaulting to Method Two. The Two Party agreement states that Cleanup Level A is the target, and specifies use of the current UST and former SW regulations, and Interim Guidance for CS. Stockpile locations need to be located and, possibly, screened/sampled, prior to deposition. And after they are removed, additional screening/sampling may be needed. A general work plan for stockpile construction should be prepared Lynne Bush
11/18/1998 Potentially Responsible Party/State Interest Letter Don Young, Chairman Committee on Resources sent Joseph W. Westphal, Secretary (Civil Works), Department of the Army, The Pentagon, Washington, D.C. a letter. I am writing you to advise you that the Department of Defense (DOD) through the Corps of Engineers appears to be responsible for environmental cleanup at one or more formerly used defense sites on the Pribilof Islands (St. Paul and St. George), Alaska, and to ask for your personal attention to these sites to ensure their prompt and complete cleanup and remediation. The National Oceanic and Atmospheric Administration (NOAA) is in the midst of a multi-year $25 million environmental restoration and cleanup project on the lands that are or were under its jurisdiction. This is part of a larger effort to transfer control on the Islands from Federal to local control. That effort results from the demise of the Federal fur seal harvest on the Islands. The Coast Guard is also undertaking a cleanup of property that it controlled. The Corps of Engineers has previously acknowledged responsibility for a site known as Telegraph Hill on St. Paul Island. Unfortunately, the Corps has not scheduled the cleanup of this site. The use of St. Paul and St. George by DOD for defense purposes over a number of years suggests that there may be other sites on the Islands for which DOD should accept responsibility and undertake cleanup and remediation actions. The State of Alaska and the residents of the Pribilof Islands are anxious to complete the cleanup of Federal sites. To enhance the Islands' private sector economy, cleanup of all Federal sites is needed. Please advise me at your earliest opportunity of the cleanup and remediation schedule for Telegraph Hill; the evaluation of DOD's potential responsibility for other sites on the Pribilofs; and the plan for resolving environmental problems at those sites. Sincerely, Don Young. Ray Dronenburg
1/18/1999 Update or Other Action Dept. of Army US Army Corps of Engineers, Military Programs sent letter to Don Young. This is in response to your Novcmber 18, 1998, letter regarding the Department of Defense's (DoD) responsibility for environmental clean up at the Pribi1of Islands, Alaska, specifically Telegraph Hill on St. Paul Island. As you know, the U.S. Army Corps of Engineers managed the Formerly Used Defense Site program for DoD. In this regard, the Corps has evaluated all known areas of former DoD usage within the pribilofs and concluded there is no further DoD responsibility. In 1986 the Corps successfully removed all DoD contamination from Te1sgrapb Hill and ten other sites on the ilands to the satisfaction of the community (tribal government and native villages). Any pol1ution remaining, was determined as non-DoD. In a 1998 letter from the Alaska Department of Environmental Conservation (ADEC) to tbe Nationsal Oceanic and Atmospheric Administration, the ADEC corroborated our evaluation regarding Telegraph Hill, stating that the site was not the responsibility of DoD. If you have further questions or desire further details regarding our actions in the Pribilofs please contact our project manager, Mr. Ronald Pflum, at (907) 753-5185. Louis Howard
2/19/1999 Update or Other Action Dronenburg received an unsolicited proposal from Bering Sea Eccotech (BSE) Inc. for remediation of Saint Paul contaminated soils for ex-situ stockpiled soils via the HAVE (hot air vapor extraction) system. For in-situ soils it was proposed to use bio-augmentation with bioventing. NOAA has declined to review or accept/reject the proposal from Bering Sea Ecotech Inc. since it has not solicited it in the first place. Ray Dronenburg
4/5/1999 Update or Other Action Letter from R. Dronenburg to Minh Trinh NOAA project manager. Draft Statement of Work-Performance Specifications submitted under letter of transmittal dated March 22, 1999 was received March 22, 1999. The Department has completed a careful review of the documents and the Draft SOW is unacceptable to the Department and is considered non-responsive. The Department has determined that a violation of paragraph 70 for the Two Party Agreement exists and stipulated penalties will accrue until NOAA submits acceptable work plans. The Two Party Agreement paragraph 18, requires the submittal of plans for sites per schedule of Attachment A. As you are aware, NOAA and ADEC extended time lines for Attachment A with regards to work plans (Phase II) for investigation and remediation of contaminated soils on St. Paul and St. George Islands to February 22 1999. At NOAA's request that deadline was extended (by the Department) for thirty (30) days due to some confusion on NOAA's part as to remediation regulation. Paragraph 18 of the Two Party Agreement states in part that each plan shall outline the course of the site investigation to properly delineate the nature and extent of contamination in soil and groundwater at each source area(s). A violation of paragraph 70 of the Two Party Agreement exists with stipulated penalties pursuant to paragraph 70 of the TPA. The penalties were invoked effective February 22, 1999 and accrue weekly until those requirements as previously identified are met. NOAA is reminded that stipulated penalties are for two thousand dollars ($2000) for the first week (or portion thereof) and three thousand dollars ($3000) for each additional week (or portion thereof). Ray Dronenburg
4/7/1999 Meeting or Teleconference Held Restoration Advisory Board Meeting held at the Captain Cook Hotel. Risk based cleanup under Alaska cleanup rules: 18 AAC 75 Methods 1, 2, 3, 4 presented. Public Law 104-91 as it pertains to community issues and concerns related to cleanup and local hire, NOAA organizational chart, accounting of budget for all funds received, uses of the funds requested again by ADEC as was presented in 1/6/999 letter to NOAA was discussed at the RAB meeting. Finally discussed projects planned for the future at the Pribilofs, how clean is clean and whether or not community buy in is required to assign a no further remedial action required or closure of sites for either island. Ray Dronenburg
8/20/1999 Site Characterization Workplan Approved Comments sent to be incorporated into TPA 1's final site characterization plan. Louis Howard
8/27/1999 Potentially Responsible Party/State Interest Letter ADEC John Halverson sent Potentially Responsible Party (PRP) Notification/Request for site characterization and possible remedial action for the Saint Paul Island Formerly Used Defense Sites (FUDS). We received the Alaska District's October 23,1998 letter responding to the potentially responsible party (PRP) letters ADEC sent to on August 5 and September II, 1998. The latest letter provided additional information on the cleanup work done on ST. Paul Island in 1985-86 under the FUDS program. It described the Alaska District's conclusion that all Department of Defense (DOD) impacts to the Island have been "mitigated to acceptable risk based levels and satisfy community concerns" and a decision to "not reopen our remediation". Our Department (DEC) does not agree with the AK District's position that no further work should be done under the FUDS program. Insufficient information has been provided to document that the FUDS were adequately cleaned up. Therefore, the Department of Defenses has out-standing responsibilities for investigation and possibly cleanup on the Island. DEC is requesting that the Corps, as DOD's agent for cleanup at FUDS, conduct additional work under the FUDS Program to complete site characterization and any necessary cleanup. The National Oceanic and Atmospheric Administration (NOAA), as the federal land manager for the island, is currently investigating and cleaning up areas that have impacts from past federal government activities. NOAA contends that areas in which cleanup work was done under the FUDS program, but which have not resulted in site closure under State regulations, should be brought to closure under the FUDS program. DEC requests that the Corps of Engineers work with NOAA to conduct site characterization and any necessary cleanup in these areas. Working together cooperatively will help ensure a timely and cost effective response. The 1986 FUDS cleanup project included work on nine separate sites on the island. Based on all the information provided to date, the Corps has not demonstrated that the following areas were adequately characterized, cleaned up or closed: the LORAN Station at Southwest Point – FUDS site A in the '85-86 cleanup, the Oil Drum Dump Site # I - site B-1 in the FUDS cleanup, the Barrel Dumps north and east of Big Lake - sites B-2 and B-4 in the FUDS cleanup, and the FUDS Landfill created near the Big Polovina Hill Vehicle boneyard. DEC requests that the Corps of Engineers work with NOAA to conduct site characterization and any necessary cleanup in these areas. Working together cooperatively will help ensure a timely and cost effective response. the Corps has not demonstrated that the following areas were adequately characterized, cleaned up or closed: the LORAN Station at Southwest Point - FUDS site A in the 1985-86 cleanup, the Oil Drum Dump Site #1 - site B-1 in the FUDS cleanup, the Barrel Dumps north and east of Big Lake - sites B-2 and B-4 in the FUDS cleanup, and the FUDS Landfill created near the Big Polovina Hill Vehicle boneyard. Telegraph Hill is located in the recharge area for what appears to be a surface influenced sole-source aquifer for the community of Saint Paul. The site is directly upgradient from the water supply wells. Periodic petroleum contamination has been documented in the water wells. Telegraph Hill is located in the recharge area for what appears to be a surface influenced sole source aquifer for the community of St. Paul. The site is directly upgradient from the water supply wells. Periodic petroleum contamination has been documented in the water wells. FUDS cleanup work at Telegraph Hill included removing what the Corps estimated to be 4000 abandoned drums from approximately two acres of land. At the Oil Drum Dump Site (site B-1) an estimated 4000 drums, 60 tanks and 300 cubic yards of other debris were to be removed. At Drum Dump sites B-2 and B-4 an estimated 650+ drums were reportedly removed. The contracting documents state that most of the drums had rusted through and spilled their contents. The documents called for cleaning up hazardous spills and sampling to verify the level of cleanup. Site logs produced by the contractor show that some contaminated soil was excavated and transported to the FUDS landfill for disposal. It is unclear what types and concentrations of contaminants were present in the soil that was placed in the landfill. It is unclear whether any site characterization work was done at the former LORAN Station. To date, no documentation has been provided to ADEC to demonstrate that these FUDS were adequately characterized or cleaned up. The October 23 letter from the AK District states, "I canvassed district personnel who may have some knowledge or records on this matter. Unfortunately, we were not able to locate soil or groundwater results." For additional information see site file. John Halverson
9/10/1999 Update or Other Action Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. Jennifer Roberts
11/15/1999 Update or Other Action Letter from Scott R. Marchand Assistant District Counsel Corps regarding Saint Paul Island PRP Notification request. We have received your August 27, 1999 letter to Mr. Bob Chivvis, in response to our October 23, 1998 letter regarding PRP status on Saint Paul Island. ADEC's recent letter renewed its prior request that the Alaska District conduct additional work under the FUDS program on five of the original nine sites. ADEC is of the opinion that FUDS on Saint Paul have not been adequately characterized and cleaned up because you lack certain information which you believe was required by the remediation contractor as part of its permit. However, ADEC did not provide any new information to support its contention. Rather, ADEC merely reiterated its interpretation of AS 46.03.822 and contractual documentation with which the Corps disagrees. The Corps have confirmed with Portage Environmental, the contractor doing the DOD Site Assessment, that their report is still in draft. Therefore, the Corps cannot comply with ADEC's renewed request for additional FUDS funded characterization and cleanup on Saint Paul Island. John Halverson
12/10/1999 Update or Other Action ledger code update and other minor data corrections. Louis Howard
12/15/1999 Update or Other Action Letter to Mr. Chivvis CEPOA-PM-E-F US Army Corps of Engineers District-Alaska from ADEC (J. Halverson). We received the November 10 letter from Scott Marchand responding to our August 27 potentially responsible party (PRP) notification and request for action letter. The response failed to address the legal and factual information contained in the August 27 letter. The AK District has not addressed Department of Defense liability for disposal of solid and hazardous waste under 42 U.S.C. 9607(a)(3) (CERCLA) and 42 U.S.C. 6973 (RCRA liability for past disposal presenting potential threat to human health or the environment) (see item 2, Attachment 1, in the Aug. 27, 1999 letter). The response failed to address the site conditions, the potential threat to the community drinking water wells and the fact that insufficient documentation has been provided to demonstrate that the past FUDS cleanup work is protective of human health, safety, welfare and the environment. DEC does not agree with the Alaska Districts position regarding DOD's responsibility at these sites. On December 1, we received a draft No Further Action (NOFA) Report for FUDS work on St. Paul. We were quite surprised by the submittal, especially in light of the fact that the Corps met with DEC, the Army, NOAA and Congressional staff in Washington D.C. in mid November regarding FUDS issues on St. Paul Island. Based on that meeting, it was our understanding that staff from the AK District, NOAA and DEC would be meeting in January. The objective of the agreed upon meeting is to discuss the federal government’s responsibility for ensuring areas it used on the island are adequately investigated and cleaned up so the land transfers can be completed in accordance with state and federal laws. However, the cover letter on the draft NOFA report requested that DEC provide comments on the document by January 3. It appears that there has been a significant miscommunication on this issue. DEC does not concur with the proposed NOFA. The document does not address the site information and concerns raised in DEC’s previous correspondence. Attached is another copy of our Aug. 27 letter. Until the issues in that letter are adequately addressed, DEC will continue to pursue DOD to ensure it adequately cleans up hazardous substances, pollutants and contaminants from its past activities that may pose a risk to human health, safety, welfare or the environment in Alaska. I suggest that we schedule a meeting in January, after NOAA provides its next report on work it has conducted on the island, as was agreed upon during the meeting in Washington D.C., to discuss this issue further. John Halverson
12/31/1999 Update or Other Action Tetra Tech conducted a preliminary investigation at the Oil Drum Dump Site in August and September 1999. Tetra Tech collected 77 soil samples, 36 from TPA Site No. 1 and 41 from FUDS B-1, and analyzed them for GRO, DRO, RRO, and BTEX. Some samples were also analyzed for PAHs and VOCs. In soil, GRO, BTEX, PAHs, and VOCs were sporadically detected but never above ADEC Method Two cleanup levels. DRO was detected above its Method Two cleanup level of 250 mg/kg at eight locations, with a maximum detection of 18,000 mg/kg at sample location 01SS02-020. RRO was detected above its Method Two cleanup level of 10,000 mg/kg at four locations, with a maximum detection of 110,000 mg/kg at sample location 01SS23-020. Exceedances occurred both on land considered to be part of TPA Site No. 1 and land considered part of the FUDS. Seven groundwater samples, including one duplicate, were also collected. Only one sample, 01GW18, contained fuels or other organic compounds above ADEC Table C cleanup levels. This sample, collected from beneath the central pad, contained DRO at 10,400 ug/L. The cleanup level for DRO in groundwater is 1,500 ug/L. Surface water and sediment samples were collected from two locations each in the ephemeral marsh area down slope from areas containing obvious soil staining. The maximum DRO concentrations detected in sediment and surface water were 94 mg/kg and 320 ug/L, respectively. RRO was detected in sediment, with a maximum concentration of 340 mg/kg. The state of Alaska does not have sediment quality standards; however, the DRO and RRO concentrations in the sediment are below the most stringent ADEC cleanup levels for soil, 100 mg/kg and 2000 mg/kg, respectively. The only quantitative state standards for petroleum in fresh surface water are for total aqueous hydrocarbons and total aromatic hydrocarbons for which analyses were not conducted. GRO, BTEX, PAHs, and VOCs were not detected in surface water or sediment samples above their respective practical quantitation limits (PQLs). During CESI’s 2000 site characterization efforts, 46 soil samples from 39 locations, nine groundwater samples from six wells, and three surface water samples from three locations were collected and analyzed at a fixed laboratory. In this SCR, data from CESI’s investigation were synthesized with other available analytical data, primarily from Tetra Tech, to comprehensively evaluate the condition of the Oil Drum Dump Site regarding concentrations of hazardous substances. A total of approximately 123 soil samples from 84 locations at the Oil Drum Dump Site have been collected and analyzed in a fixed laboratory for GRO, DRO, RRO, and BTEX, and in some cases SVOCs, VOCs, heavy metals, and PAHs. A total of approximately 16 groundwater samples from 12 wells and three surface water samples from three locations have also been collected and analyzed for GRO, DRO, VOCs, and in some cases SVOCs and heavy metals. Based on data from these sample analyses, the following conclusions can be made: • The primary sources of contamination (i.e., drums) have been removed from the Oil Drum Dump Site. • DRO is the most extensively found soil contaminant at the site. • DRO, RRO, As, and Cr were found in soil above ADEC Method Two cleanup levels. DRO and RRO are considered contaminants of concern. As and Cr are not considered contaminants of concern. • RRO exceedances were only found at soil sampling locations were DRO also exceeded cleanup criteria. Louis Howard
1/6/2000 Update or Other Action Staff commented on revised project schedules for Saint Paul Island. Pending ADEC review of the 1999 sampling results, ADEC may require additional action by NOAA. Also, unless the Corps of Engineers (COE) takes steps by May 1 to address the data gaps necessary for closure, ADEC will request further action by NOAA for this site and other formerly used defense sites (FUDS) sites. Soil needs to remediated and wells installed for groundwater contamination at the site. Staff referred NOAA to the August 27, 1999 Potentially Responsible Party (PRP) letter to COE and August 8, 1998 PRP letter to NOAA. Louis Howard
1/24/2000 Update or Other Action Congress passed Public Law 106-562 (H.R. 1653) a.k.a. 'Pribilof Islands Transition Act'. SEC. 104. DISPOSAL OF PROPERTY. Section 205 of the Fur Seal Act of 1966 (16 U.S.C. 1165) is amended— (1) by amending subsection (c) to read as follows: ‘‘(c) Not later than 3 months after the date of the enactment of the Pribilof Islands Transition Act, the Secretary shall submit to the Committee on Commerce, Science, and Transportation of the Senate and the Committee on Resources of the House of Representatives a report that includes— ‘‘(1) a description of all property specified in the document referred to in subsection (a) that has been conveyed under that subsection; ‘‘(2) a description of all Federal property specified in the document referred to in subsection (a) that is going to be conveyed under that subsection; and ‘‘(3) an identification of all Federal property on the Pribilof Islands that will be retained by the Federal Government to meet its responsibilities under this Act, the Convention, and any other applicable law.’’; and (2) by striking subsection (g). SEC. 206. FINANCIAL ASSISTANCE.`(a) GRANT AUTHORITY- (1) IN GENERAL Subject to the availability of appropriations, the Secretary shall provide financial assistance to any city government, village corporation, or tribal council of St. George, Alaska, or St. Paul, Alaska. (2) USE FOR MATCHING Notwithstanding any other provision of law relating to matching funds, funds provided by the Secretary as assistance under this subsection may be used by the entity as non-Federal matching funds under any Federal program that requires such matching funds. (3) RESTRICTION ON USE The Secretary may not use financial assistance authorized by this Act (A) to settle any debt owed to the United States; (B) for administrative or overhead expenses; or (C) for contributions sought or required from any person for costs or fees to clean up any matter that was caused or contributed to by such person on or after March 15, 2000. (4) FUNDING INSTRUMENTS AND PROCEDURES In providing assistance under this subsection the Secretary shall transfer any funds appropriated to carry out this section to the Secretary of the Interior, who shall obligate such funds through instruments and procedures that are equivalent to the instruments and procedures required to be used by the Bureau of Indian Affairs pursuant to title IV of the Indian Self-Determination and Education Assistance Act (25 U.S.C. 450 et seq.). (5) PRO RATA DISTRIBUTION OF ASSISTANCE In any fiscal year for which less than all of the funds authorized under subsection (c)(1) are appropriated, such funds shall be distributed under this subsection on a pro rata basis among the entities referred to in subsection (c)(1) in the same proportions in which amounts are authorized by that subsection for grants to those entities. (b) SOLID WASTE ASSISTANCE (1) IN GENERAL- Subject to the availability of appropriations, the Secretary shall provide assistance to the State of Alaska for designing, locating, constructing, redeveloping, permitting, or certifying solid waste management facilities on the Pribilof Islands to be operated under permits issued to the City of St. George and the City of St. Paul, Alaska, by the State of Alaska under section 46.03.100 of the Alaska Statutes. (2) TRANSFER The Secretary shall transfer any appropriations received under paragraph (1) to the State of Alaska for the benefit of rural and Native villages in Alaska for obligation under section 303 of Public Law 104-182, except that subsection (b) of that section shall not apply to those funds. (3) LIMITATION In order to be eligible to receive financial assistance under this subsection, not later than 180 days after the date of the enactment of this paragraph, each of the Cities of St. Paul and St. George shall enter into a written agreement with the State of Alaska under which such City shall identify by its legal boundaries the tract or tracts of land that such City has selected as the site for its solid waste management facility and any supporting infrastructure. Louis Howard
3/27/2000 Update or Other Action Staff reranked site based on additional information gathered from the Draft Site Characterization report concerning volumes of contaminated soils and contaminated groundwater. Staff also commented on draft site characterization report. Requested installation of monitoring wells for geoprobe sample contaminated with diesel range organics. Also, staff reminded NOAA that it would be responsible for cleanup at the site should the Corps of Engineers determine that the site is not eligible for funding under the FUDS cleanup program. Default value of fifteen feet would be the depth at which ADEC considers it reasonably likely that soils would be excavated and brought to the surface through installation of septic systems, building foundations or utility systems. Louis Howard
3/28/2000 Update or Other Action Staff reviewed and commented on the draft site characterization report for the Oil Drum Dump Site No. 1. There appears to be a discrepancy between regulation which states ADEC will generally use a default value of 10 feet to define subsurface soil to which residents will have a reasonable potential to be exposed and the risk assessment procedure manual which states a depth of 15 feet. ADEC will require NOAA to meet cleanup levels for ingestion or inhalation of a volatile hazardous substance in soil to a depth of at least 15 ft. To demonstrate groundwater contamination is attenuating, ADEC requests NOAA submit a workplan for review and approval to install and sample groundwater monitoring wells at the site. With regards to the FUDS issue at this site, ADEC will not require NOAA to pursue cleanup at the site at this time pending the outcome of a future joint meeting with the Corps of Engineers. If the Corps determines that this site is not eligible for funding under the FUDS cleanup program, then ADEC will be requesting NOAA address contamination at the site. Louis Howard
5/10/2000 Meeting or Teleconference Held Staff attended a restoration advisory board meeting in Saint Paul Island. Main points discussed during the meeting: closure of the existing landfill due to its capacity being reached, alternatives to the landfill and a new cell adjacent to it, burning of waste in an incinerator as a short term fix, funding for the new landfill not a sure thing and that the community must come together and present a unified front with a site for the new landfill and a solid waste management plan or else D.C. will not give them funding for a new landfill. Louis Howard
7/25/2000 Update or Other Action Staff requested all of NOAA's budget requests made to congress since the agreement was signed in 1996 by both ADEC and NOAA for the environmental cleanup at the Pribilofs. It has come to DEC's attention that NOAA did not make a formal request for funding to Department of Commerce for FY 01 and possibly FY02 (federal fiscal years). This is not in compliance with the TPA which requires NOAA to request adequate funding to meet its obligations under the TPA. NOAA was counting on the U.S. congressional delegation to fund 12 million dollars as a special appropriation for the Pribilofs. The appropriation was much less-3 million dollars for October 2000 to September 2001. Deadline for NOAA to provide a written response was no later than August 18th. Louis Howard
12/12/2000 Update or Other Action Site information update by staff from files. Louis Howard
12/14/2000 Update or Other Action Staff sent letter to NOAA regarding Notification of possible Force Majeure (per the TPA). The Alaska Department of Environmental Conservation (ADEC) has received the above document via facsimile from NOAA on December 5, 2000. The document states that in accordance with Paragraph 67 of the Two Party Agreement, the potential exists for a Force Majeure situation. It further states that unless further Pribilofs Cleanup Funds are appropriated to NOAA for FY01, the project budget will be exhausted this fiscal year. We very much appreciate your providing this information and analysis of NOAA’s anticipated plans in FY 01 given the existing funding situation. ADEC realizes that funding is uncertain due to Congress not yet finalizing a budget for this FY01. We anticipate a meeting with NOAA to discuss potential impacts to the Pribilof Islands Environmental Restoration Agreement when Congress finalizes a budget. Louis Howard
12/23/2000 Update or Other Action U.S. Congress passed Public Law 106-562 which states in section 107(f)(2) replacement language to PL 104-91 (16 USC 1165 note) is amended (1) by striking subsection (f) and inserting the following Authorization of Appropriations-(2) None of the funds authorized by this subsection may be expended for the purpose of cleaning up or remediating any landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, or contaminants, including petroleum products and their derivatives, left by the Department of Defense or any of its components on lands on the Pribilof Islands, Alaska. Louis Howard
3/28/2001 Update or Other Action Staff sent NOAA comment letter on TPA revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.” With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows: 1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force Majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. Louis Howard
1/28/2002 Site Ranked Using the AHRM Changed Observed Environmental Impacts value from 3 to 0 because an entry exists for Surface Water Environments. Changed Surface Water Environments value from 2 to 3. No Longer Assigned
2/11/2002 Update or Other Action Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002. The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season. *Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year. The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment. With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2). In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA. NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement, 1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary. NOAA has submitted the necessary revised schedules for Attachment B based on available funding. 2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. Louis Howard
5/10/2004 Update or Other Action Michael J. Walsh Colonel, Corps Of Engineers, Chief of Staff issues Engineering Regulation No. 200-3-1. It is the policy of the USACE that the policies contained in this ER are the overarching USACE policy for management & execution of the FUDS program & takes precedence over previous USACE FUDS program policy & guidance. The USACE MUST comply with the DERP statute (10 USC 2701 et seq.), CERCLA, 42 USC § 9601 et seq., Executive Orders (EOs) 12580 & 13016, NCP, & all applicable DoD (e.g., DoD Management Guidance for the DERP [28 September 2001]) & Army policies in managing & executing the FUDS program. Because of the linkages between the DERP & CERCLA & the delegation of certain Presidential authorities under CERCLA to DoD, CERCLA is DoD's preferred framework for environmental restoration. Where a regulatory agency seeks to use another framework, USACE Districts shall: Seek formal approval of the decision to follow a framework other than CERCLA. Ensure that the actions undertaken also comply with all applicable CERCLA requirements, especially in the areas of the content of decision documents & the maintenance of an Administrative Record. Consistent with the statutory program goals of the DERP, DoD has established 3 program categories to classify activities at FUDS properties & projects: installation restoration program, military munitions response program, & building demolition/debris removal program. 1) Installation Restoration (IR) Program. For the FUDS, the IR program includes the Hazardous, Toxic, & Radioactive Waste (HTRW) & Containerized HTRW (CON/HTRW) project categories. IR program category is defined as the conduct of response actions (i.e., the identification, investigation, & remedial actions, or a combination of removal & remedial actions) to address releases of: Hazardous substances or pollutants & contaminants (as defined in the CERCLA). Petroleum, oil, or lubricants (POL). Under the DoD Management Guidance for the DERP, funding appropriated to the Environmental Restoration (ER)-FUDS account may be used to remediate releases of petroleum where the release poses an imminent & substantial endangerment to the public health or welfare or to the environment [10 USC 2701(b)(2)]. DoD-unique materials. Hazardous wastes or hazardous waste constituents. Low-level radioactive materials or low-level radioactive wastes. Explosive compounds released to soil, surface water, sediments, or groundwater as a result of ammunition or explosives production or manufacturing at ammunition plants. 2) Miltary Munitions Response Program (MMRP). The MMRP category is defined as response actions (i.e., the identification, investigation, & remedial actions, or a combination of removal & remedial actions) to address Munitions & Explosives of Concern (MEC) or Munitions Constituents (MC). This includes the removal of foreign military munitions if it is incidental to the response addressing DoD military munitions at a FUDS property. 3) Building Demolition & Debris Removal (BD/DR) Program. This program category is defined as the demolition & removal of unsafe buildings & structures at FUDS properties that were owned by, leased to, or otherwise possessed by the United States & under the jurisdiction of the Secretary of Defense & transferred to state, local governments, or Native Corporations of Alaska. FUDS Project Definition. Within this Program, USACE has defined a FUDS Project as a unique name given to an area of an eligible FUDS property containing one or more releases or threatened releases of a similar response nature, treated as a discrete entity or consolidated grouping for response purposes. This may include buildings, structures, impoundments, landfills, storage containers, or other areas where hazardous substance are or have come to be located, including FUDS eligible unsafe buildings or debris. Response actions at FUDS projects fall under the Installation Restoration (HTRW & CON/HTRW), Military Munitions Response Program (MEC & MC), or Building Demolition/Debris Removal (BD/DR) program categories. An eligible FUDS property MAY have more than one project. The DoD Goals for the DERP, established for the FUDS program in the DoD Financial Management Regulation (FMR), require USACE to develop an execution strategy that includes the following. Reducing risk to human health & the environment through implementation of effective, legally compliant, & cost-effective response actions. Having final remedies in place & completing response actions. Requiring certain percentages of FUDS projects in the program to progress to specific stages of the response process by specific dates (i.e., milestones). The objective of the BD/DR program is to protect human health & safety by demolishing & removing unsafe buildings, structures, & debris resulting from past DoD operations. Louis Howard
5/24/2004 Update or Other Action Columbia Environmental Science, Inc. (CESI), conducted a field investigation at the Oil Drum Dump Site during the 2000 field season. During the 2000 field investigation, 46 soil samples from 39 locations, nine groundwater samples from six wells, and three surface water samples from three locations were collected and analyzed at a fixed laboratory. Based on these investigations, the following conclusions can be made: -The primary sources of contamination (i.e., drums) have been removed from the Oil Drum Dump Site. -DRO is the most extensively found soil contaminant at the site. -DRO, RRO, As, and Cr were found in soil above ADEC Method Two cleanup levels. DRO and RRO are considered contaminants of concern. As and Cr are not considered contaminants of concern. -RRO exceedances were only found at soil sampling locations were DRO also exceeded cleanup criteria. -DRO and GRO were the only contaminants found in groundwater above the ADEC Table C cleanup criteria. -The estimated maximum volume of soil removal required to meet ADEC standards is 5761 cubic yards. NOAA finds and recommends the following regarding the Oil Drum Dump Site: -Approximately 5761 cubic yards of contaminated soil should be considered for removal. -The extent of groundwater contamination is limited. Future groundwater monitoring may be warranted. -NOAA is prohibited from further expending Pribilof Project funds for clean up or remediation of FUDS. (NOTE See action 12/23/2000 for language in public law 106-562 FUDS prohibition). Louis Howard
10/25/2004 Update or Other Action John Halverson letter to CORPS (S. Beauchamp) to follow up on prior discussions and correspondence regarding formerly used defense site (FUDS) program work in the Pribilof Islands. DEC has asked the Alaska District to re-evaluate the sites for FUDS program eligibility to address residual contamination. In prior responses, the District has claimed cleanup work conducted in the mid 1980s was adequate to meet applicable cleanup requirements and provide protection of human health and the environment. The National Oceanic and Atmospheric Administration (NOAA) has been conducting site characterization and cleanup on the St. Paul and St. George Islands for many years. NOAA claims contamination remains at some of the FUDS where cleanup was conducted in the ‘80s and that it should be addressed under the FUDS program. While NOAA is obligated to cleanup and transfer the land on the islands to the native corporations, it is also prohibited from cleaning up FUDS. Enclosed are electronic copies of site characterization reports NOAA’s consultants prepared for sites known as Telegraph Hill Scoria Pit and Oil Drum Dump Site. Please have your staff review these documents and then I would like to schedule a meeting, in early December, with the District, NOAA and our project managers to see if we can reach a mutually acceptable agreement on how to address residual contamination at these sites. John Halverson
11/30/2004 Update or Other Action Oil Drum Dump Site TPA Site No. 1 and Formerly Used Defense Site B-1 Site Characterization Report (SCR) received. The Oil Drum Dump Site was used as a disposal area for drums and debris during the 1940s and later decades. Cleanup of the site began in 1986 and continued through 1994. A central pad, now known as TPA Site No. 1, was created and initially used when the Department of Defense (DOD) conducted drum and debris removal and cleanup activities at Formerly Used Defense Site (FUDS) B-1. For purposes of this SCR, the Oil Drum Dump Site refers to the area encompassing both TPA Site No. 1 and FUDS B-1. A NOAA contractor, Columbia Environmental Science, Inc. (CESI), conducted a field investigation at the Oil Drum Dump Site during the 2000 field season. This SCR presents the objectives, methodologies, and results of the CESI investigation, and synthesizes the results with data from prior investigations. During the 2000 field investigation, 46 soil samples from 39 locations, nine groundwater samples from six wells, and three surface water samples from three locations were collected and analyzed at a fixed laboratory. When prior investigations are considered, a total of approximately 127 soil samples from 84 locations at the Oil Drum Dump Site have been collected and analyzed in a fixed laboratory for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes (BTEX), and in some cases semivolatile organic compounds (SVOCs), volatile organic compounds (VOCs), heavy metals, and polynuclear aromatic hydrocarbons (PAHs). A total of approximately 17 groundwater samples from 14 wells have been collected and analyzed for GRO, DRO, VOCs, and in some cases SVOCs and heavy metals. Based on these investigations, the following conclusions can be made: • The primary sources of contamination (i.e., drums) have been removed from the Oil Drum Dump Site. • DRO is the most extensively found soil contaminant at the site. • DRO, RRO, As, and Cr were found in soil above ADEC Method Two cleanup levels. DRO and RRO are considered contaminants of concern. As and Cr are not considered contaminants of concern. • RRO exceedances were only found at soil sampling locations were DRO also exceeded cleanup criteria. • DRO and GRO were the only contaminants found in groundwater above the ADEC Table C cleanup criteria. Based on data and other information presented in this site characterization, NOAA finds and recommends the following regarding the Oil Drum Dump Site: • Approximately 5,761 cubic yards of contaminated soil should be considered for removal. • The extent of groundwater contamination is limited. Future groundwater monitoring may be warranted. • Soil contamination on site is most likely the result of spills and leakage during the USACE’s staging of barrels on the site in 1986 or deterioration or damaging of barrels brought to and abandoned on the site by the USACE. • As a result of statutory restraints on NOAA’s expending appropriated funds to clean up contamination including petroleum products left by the Department of Defense on lands on the Pribilof Islands, no further remedial action should be required of NOAA for this site. Louis Howard
4/23/2007 Exposure Tracking Model Ranking Louis Howard
6/4/2008 Cleanup Complete Determination Issued NOAA and ADEC signed the closure letter for St. Paul Island. In accordance with paragraph 59 of the Pribilof Islands Environmental Restoration Agreement (Two-Party Agreement or TPA) January 1996 by designated officials of the State of Alaska and the National Oceanic and Atmospheric Administration (NOAA), NOAA requested Alaska Department of Environmental Conservation (ADEC), as the duly authorized representative of the State of Alaska, certify NOAA’s completion of corrective action for the St. Paul Island Operable Unit (OU). Site 1 listed in TPA Attachment A and Table 1(a.k.a. Oil Drum Dump), and Sites 48 and 56 (Table 1), Windmill Wells and ATCO/Radio Building Barrel Storage Area, respectively, were subsequently recognized as formerly used defense sites (FUDS) in accordance with Public Law 106-562 legislated in 2000. While NOAA had conducted soil and groundwater assessments at these sites, PL106-562 precluded NOAA from undertaking any corrective action. The site is administratively closed with regards to further NOAA action and investigation. The Oil Drum Dump has buried drums, surface debris, solid waste and contaminated soil. As of June 4, 2007, diesel range organics (DRO) and residual range organics (RRO) exceed 18 AAC 75.341 Method Two levels in an estimated 2,300 cubic yards of soil. Groundwater contaminated with DRO. Buried debris exists, but extent and quantity is unknown. Property Owner as of November 6, 2007 is the Tanadgusix Corporation (TDX) for the surface estate and The Aleut Corporation (TAC) for the subsurface estate. Before the enactment of Public Law 106-562 in December 2002, which enacted the previously mentioned spending limitation, both NOAA and the USACE had conducted efforts related to the cleanup of the Oil Drum Dump Site. Prior to 1985, FUDS B-1 was described as having approximately 4,000 rusted 55-gallon barrels with gasoline, diesel oil, antifreeze and motor oil markings; 60 steel tanks (300- to 600-gallons each); and 300 cubic yards of miscellaneous metal debris (U.S. Army 1991). Representatives from USACE examined the site debris and noted debris they judged as being non-military in origin. According to a Chase Construction Daily Quality Control Inspection Report dated May 23, 1986 (Appendix J), “Barrels containing used oil (not DOD) are being segregated. There are approximately 650 by COE [USACE] rep. and my count. About 160 contain oil, most of which are full.” Debris categorized as non-military, including the segregated ‘non-DOD’ barrels, were gathered by the USACE’s contractor and apparently assembled on a small (less than an acre) pad at the site (i.e., the central pad), which became TPA Site No. 1. With the exception of the debris judged to be non-military, Chase Construction reportedly removed the drums, steel tanks, and miscellaneous debris noted above in 1986. The USACE’s contractor consolidated the remaining debris on the central pad at the Oil Drum Dump Site. Additionally, newer barrels from FUDS C (Telegraph Hill) considered by DOD to be non-military were moved to FUDS B-1 and stockpiled. These drums contained petroleum, oil, and lubrication products (Chase Construction Daily Quality Control Inspection Report dated May 20, 1986, Appendix J). Jennifer Roberts
3/24/2011 Update or Other Action NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island. National Weather Service Landspreading Area/Oil Drum Dump – The revised St. Paul plan will reflect that monitoring at these wells was discontinued after three years of monitoring indicated no contaminant issues, but will be retained for future use if needed as a result of NWS Site cleanup. Louis Howard
6/25/2015 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73137 name: drums Louis Howard

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