| Action Date |
Action |
Description |
DEC Staff |
| 12/22/1976 |
Update or Other Action |
Memorandum of Understanding Pribilof Land Selections. Future Transfers. 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 nonowning party. |
Louis Howard |
| 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).
Several abandoned vehicles are located within the dunes on the north side of the island directly north of the Little Polovina Hill. Two sites are separated by a ridge. The first site contains 3 vehicles and the second dune vehicle boneyard is located on the north side of the ridge adjacent to the first site containing 8 dump trucks. No apparent stressed vegetation or visibly stained soils are present at the first site. PID readings at the 2nd site ranged from 0.6 ppm to 2 ppm at the piston area of the southern-most dump truck.
Recommended actions were to sample the surface soils to determine the nature and extent of petroleum, oils, and lubricants (POL) contamination. |
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 |
| 11/2/1994 |
Update or Other Action |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. |
Jennifer Roberts |
| 12/19/1994 |
Update or Other Action |
Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy-Re: outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes.
NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island.
These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump.
18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. |
Simon Mawson |
| 6/1/1995 |
Site Added to Database |
Abandoned vehicles. |
Ray Dronenburg |
| 5/2/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson. |
S&W |
| 1/17/1997 |
Document, Report, or Work plan Review - other |
Letter to Minh Trinh NOAA Pribilof Project Office (PPO) Project Manager (PM), UST comments to be covered under separate comment letter relating to any and all activities relating to removal of USTs. Comments mainly for portion of the plan that deals with debris removal and stockpiling of contaminated soils.
a) The stockpile plan identified in section seven (7) is approved as written.
Debris Removal (vehicles). The Department does not assume nor will the contractor "assume" that vehicles identified as debris under the two-party agreement (TPA) are free from hydrocarbons. In fact, the Department will require that all vehicles be checked for fluids before being compacted and stockpiles for shipment off island.
Open Burning. The department has promulgated new regulations regarding open burning. The document dated January 18, 1997 has been provided by the contractor.
18 AAC 60.355. OPEN BURNING. Notwithstanding any rule of 18 AAC 50 that permits open burning, open burning is prohibited at a Class I or Class II MSWLF. (Eff. 1/28/96, Register 137)
Authority:AS 44.46.020, AS 46.03.100
AS 46.03.010, AS 46.03.110
AS 46.03.020, AS 46.03.810 |
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 |
| 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 Dune Vehicle Boneyard 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 |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Ray Dronenburg |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation. Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard. |
Larry Dietrick |
| 8/23/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into TPA 4's closure confirmation sampling plan. |
Louis Howard |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization report to reviewed and commented on by ADEC on 2/29/2000. |
Louis Howard |
| 5/25/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft sampling and analysis plan for 6 TPA and 5 Non-TPA sites including this one. General comments included discussion on field screening protocols and the need to use devices in addition to olfactory and visual observations for identifying sampling locations. Staff also provided information on soil sampling procedures from the UST procedures manual to clarify the document's QCP/QAP. |
Louis Howard |
| 2/20/2001 |
Site Closure Approved |
Documented in the NFA report was the November 2000 effort by TetraTech EM Inc. who collected 2 soil samples from the most heavily stained soils. The results were below ADEC cleanup level for DRO (1,000 mg/kg) at 26 mg/kg.
Based on a review of the data presented in the report, ADEC concurs with the conclusion that no further action is required at TPA 4 Dune Vehicle Boneyard. However, if in the future, additional contamination is discovered at this site, further investigation and/or remedial actions will be requested of NOAA by ADEC. ADEC reserves its rights, under 18 AAC 75 Oil and Hazardous Substances Pollution Control and AS 46.03 to require NOAA to conduct additional assessment and/or corrective actions in the future, if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or to the environment. |
Louis Howard |
