Division of Spill Prevention and Response

Breadcrumbs

Site Report: St. Paul TPA 05 Landfill Cells A, B, C


Site Name: St. Paul TPA 05 Landfill Cells A, B, C
Address: Tract 42, Saint Paul, AK 99660
File Number: 2644.38.017.02
Hazard ID: 2164
Status: Cleanup Complete - Institutional Controls
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 57.149033
Longitude: -170.232953
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

The St. Paul Island Landfill consists of cells A, B, C, an active cell,and an area used for the disposal of sewage solids. These cells consisted primarily of municipal solid waste (refuse) such as paper goods, clothing, building materials, and organic material. Cells A, B, C, have been closed out and capped. No further remedial action is necessary at the site since NOAA has remove petroleum contaminated soils to the maximum extent practicable. Long-term monitoring of the groundwater will be part of NOAA's operations and maintenance requirements. CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. Located in the Ataqan Subdivision 1.5 miles northeast of City of St. Paul and 0.25 miles south of the St. Paul Airport. For purposes associated with the environmental restoration project, NOAA arbitrarily distinguished three areas within the Tract 42 landfill and the Ataqan Subdivision: (1) Cell A (Site 6/TPA Site 5b); (2) Cell B (Site 7/TPA Site 5c [Drum Dump] and Site 8/TPA Site 5d [Solid Waste]); and (3) Cell C (Site 5/TPA Site 5a). Cell A, located north of Tract 42, contained construction debris and barrels, some with waste oil. Cell A was capped with sand and scoria during the 2000 and 2003 field seasons. Cell B, located north and west of Tract 42, was associated with historical disposal activities on St. Paul Island and contained primarily MSW and drums, some with waste oil. Cell B was closed during the 2003 field season when the MSW was relocated to within Cell C; the drums were removed and disposed off-island. Cell C, located within the boundaries of Tract 42, primarily contained MSW. All the MSW in Cell C that was near the property boundary was relocated to the central portion of Tract 42, inside a line set back 50 feet (ft) from the property boundary (“50 ft setback line”). Covered by 1996 Pribilof Islands Environmental Restoration Agreement a.k.a. Two Party Agreement between State of Alaska and NOAA. NOAA owns 5.78 acres (Cell C). City of St. Paul owns Cells B (drum dump/solid waste) and A with The Aleut Corporation. Former ADEC project Manager was Ray Dronenburg up to April 5, 1999.



Action Information

Action Date Action Description DEC Staff
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. Ray Dronenburg
12/30/1984 Update or Other Action According to the "Transfer of Property Agreement" signed in 1984, the United States agrees to convey the certain real properties on St. Paul Island, Alaska to the local and state entitites. These entities agree to accept all right, title, and interest to the real property. Table 1 Conveyance of Real Property on St. Paul Island, Alaska According to the 1984 Transfer of Property Agreement:Sanitary Landfil, Accepting Entity-City of St. Paul, Conditions-none. Louis Howard
12/22/1986 Update or Other Action Covered by the Memorandum of Understanding among: TDX, TANAQ, and 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 ANSCA 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 ANSCA. Joint Use Areas: 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 1(b)). *Not Withdrawn, subject to Joint Use Agreement, that is, land and any improvements thereon to be available for selection by the Village Corporation, but subject to joint management by the Pribilof Islands Joint Management Board pursuant to the agreement creating said Board. 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. 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). The sanitary landfill is located about 3.75 miles northeast of the city and used by all residents. NOAA reportedly disposed of drums along the east west oriented road at the north end of the landfill. The city reportedly collected NOAA drums from the Power Plant and the Machine Shop (TPA 9 Tract 46 subsites) and transported them to the landfill. Approximately 650 drums are concentrated in six areas along this road. Markings vary from: Lube Oil, Chevron motor oil DELO 30 SAE, Shell Rotella Oil 30W. Oil was present besides several drums. Petroleum odor was present, no OV were detected using the PID. 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 PCB contamination. Ray Dronenburg
5/13/1993 Meeting or Teleconference Held Meeting minutes from Pribilof Island conference in Anchorage. Landfill regulations. Discussion at the conference about the 10/09/1993 deadline to comply with stricter federal landfill requirements imposed by EPA in 40 CFR Parts 57 and 258. Appears the landfills on Saint Paul and Saint George are likely to be exempt from the more onerous provisions D and E: design criteria, including liners, and groundwater monitoring. This is due to the Island landfills meeting the exemption criteria less than 20 tons per day of refuse, no practicable waste management alternative, and less than the stipulated average annual rainfall. The other subparts apply, which means that new operating practices must be put in place: site control, control of hazardous waste, cessation of open burning, and application of daily covering of soil. The date by which these operating practices must be in place has been extended to April 9, 1994 from October 9, 1993 deadline. NOAA is developing plans for closure of both landfills, subject to funding being made available (possibly in FY95). Prior to that time, NOAA will provide technical assistance upon request to the Cities operating the landfills. Major action items from the conference: 1) obtain the determination from EPA on which process is going to apply to the Islands, CERCLA or RCRA. 2) Work to expeditiously respond to the various action items that have been mentioned in this conference. 3) Review the various activities planned for this summer-construction activities and health issues that will be addressed. 4) provide an overview of the various methods for reaching out to local entities such as grants, 8a program, and trusts. 5) NOAA desires and needs to obtain information about additional sites not listed in the Preliminary Assessment. 6) Get copies of the research from the University of Connecticut which had found the highest level of mercury contamination in human hair from people living on the Pribilof Islands and the Penn State research completed by David Kertz studying seal livers and found no elevated mercury levels. 7) Distribute copies of the Preliminary Assessment to interested parties. 8) Invite members from the Small Business Administration and Bureau of Indian Affairs to the next meeting. Elary Gromoff stated that the Saint Paul landfill must be closed immediately and the Saint George landfill is nearing capacity. Neither meets regulatory requirements. FAA is also encouraging Saint Paul to close the landfill due to the bird problem it creates and the threat it poses to aircraft using the airport. Mr. Gromoff was asked about the time frame to get a new landfill designed and constructed. He said he felt it would take one summer to do both landfill design and construction. Larry Merculieff mentioned that the cost to complete the landfill would be 300,000 to 700,000 dollars. John Leffel recommended the Indian Health Service be contacted as a potential source of funds for the landfill construction. He suggested that Jim Crum, the Director of the Anchorage Area for Sanitation Facility be contacted and this issue be pursued. The IHS has in the past constructed landfills for native entities and the Saint Paul and Saint George would be ideal candidates for this. In terms of immediate needs to address the landfill problems on Saint George, they need about 30,000 of engineering and permitting funds for this summer for their landfill. Landfills are a very high priority. Local staff and resources could be used to do cleanup work and then operate the landfill. NOAA will look into the landfill issue and report back by the next check-in meeting in June 1994. 4/13/1993 update from 5/13/1993 Pribilof Island conference. 650 drums concentrated in six areas along the road (unknown, waste oil, motor oil). Scheduled to be removed in bulking and sampling operation. Transformers formerly located at site were removed by U.S. Coast Guard. Ray Dronenburg
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
9/21/1994 Update or Other Action Woodward Clyde CERCLA Site Inspection Report performed for three sites on Saint Paul Island. They were the: Oil Drum Dump Site, the Sanitary Landfill Site, and the Power Plant Site. 22 soil samples, 14 sediment samples and 4 surface water samples total were taken from the landfill and drum site. Analyses were for PCBs, VOCs, Semi-VOCs, and Target analyte list metals. Individual organic compounds were not detected or estimated in any media exceeding conservative EPA human health, risk based screening criteria. Only 3 TAL metals: arsenic, beryllium, and manganese were detected in the soil and sediment samples greater then the EPA screening criteria. Comparing the metals in soil samples to those from background showed that the results are comparable and not above an action level. The surface water samples for total or dissolved metals did not exceed EPA maximum contaminant secondary MCL or the freshwater chronic value. Surface and subsurface soils at the Sanitary Landfill and the Drum Dumpsite have been significantly impacted by petroleum hydrocarbons limited to the less environmentally mobile heavier fuel and lubricating oil fractions. Prevalent staining at the Sanitary Landfill and Drum Dump sites indicates that liquids most likely to be used as motor oils have affected the sites. The black oily liquids visible in some of the drums at both sites have an appearance and odor of used motor oils. Lab data and field evidence strongly indicate that soils have been contaminated by diesel fuel and waste motor oils. Jennifer Roberts
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 schoolyard 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 DRo and RRO. Ray Dronenburg
8/2/1995 Preliminary Assessment Approved (Old R:Base Action Code = SA2R - Phase II SA Review (CS)). Approved an Environmental Site Assessment. Ray Dronenburg
3/4/1996 Update or Other Action Hart Crowser Memorandum received which attempted to address concerns regarding use of the petroleum-contaminated soils from the Blubber Dump which is stockpiled near Telegraph Hill in the closure of the Saint Paul Landfill. A leaching assessment was done by the synthetic precipitation leaching potential predicted resultant groundwater concentration of TPH in the groundwater at the edge of the cover was to be less than 0.8 mg/L. 9,000 cubic yards is half the necessary soil cover needed at the dump and it would have been placed in lifts with nutrients mixed in thereby lowering the contaminant levels through mixing. Potential cost benefit would have approached 1,000,000 dollars. Ray Dronenburg
5/2/1996 Site Ranked Using the AHRM Ranked by Shannon and Wilson. S&W
7/15/1996 Update or Other Action Hart Crowser July 11, 1996 Saint Paul Landfill Closure Request for Waiver received. Proposal is to use the petroleum-contaminated soils in the cover construction from a storage cell at the Blubber Dump Site. NOAA requested a waiver from 18 AAC 60.025 Polluted Soil. Contaminated soils observed around the perimeter of Cell B of the landfill are proposed to be left in place. Synthetic leaching procedure showed that less than 1 mg/L of petroleum hydrocarbons would leach. Additionally the placement of a membrane cover over the contaminated soils would further reduce the leaching potential at the site to zero. Above the liner would be two feet of material with the uppermost six inches capable of supporting vegetation. Ray Dronenburg
10/17/1996 Update or Other Action Hart Crowser October 1996 Groundwater Monitoring Well Installation and sampling/analysis report received. Original planned monitoring well locations were not placed in their locations due to site conditions. The wells will provide coverage for landfill except for areas north of Cell A. Nine soil borings were drilled to depths from 11 to 22.5 feet below ground surface. Soil borings SPL-6, SPL-5, SPL-4, SPL-9, and SPL-8 were completed as monitoring wells. Concentrations of the organic and inorganic analytes were below marine surface water and drinking water screening levels. Toluene at concentrations of 1.4 ppb in MW-1 and 1.2 ppb in MW-4 were the only volatile organics detected. Lead was the only detected metal at 1.5 ppb in MW-1, 2, and MW-5. 15 ppb is the MCL for Lead and 1000 ppb is the cleanup level for toluene (Table C 18 AAC 75). Ray Dronenburg
12/9/1996 Meeting or Teleconference Held Restoration advisory board meeting held at Regal Alaskan Hotel. One topic that held great interest and which was not resolved was the Saint Paul Landfill. Saint Paul has presented most of the information necessary to obtain a solid waste permit, however they have not requested that this permit be issued. They list as a rationale, the fact that they would have extreme difficulty maintaining the road to the new landfill and that sufficient land to establish the land is not available to them. TDX Corporation (landowners) is reluctant to give the City more land. Consequently progress on the new landfill has stopped. NOAA has requested and been given permission to close the old landfill and that will probably occur sometime in summer of 1997. City of Saint Paul has sued the Department of Commerce for 50,000,000 dollars and consequently it was not possible to get the city manager to discuss the landfill. Dronenburg proposed to get all parties to agree to a third party contractor, funded by NOAA, to work on behalf of all parties involved and get the landfill issue resolved. Ray Dronenburg
4/15/1997 Meeting or Teleconference Held Pribilof Environmental Restoration Advisory meeting held in Anchorage. Saint Paul Landfill Closure project is currently postponed due to NOAA/State negotiations on the Closure Plan. Specifically, NOAA's desire to incorporate petroleum contaminated soil from the Blubber Dump Site into landfill cover material for the landfill. Concern was expressed by the Saint Paul Island entities regarding NOAA's unresponsiveness to requests made to include "opening landfills" in NOAA's area of responsibility. Dan Strandy indicated that at this point it is not NOAA's responsibility to open landfills. He also indicated that NOAA had previously attempted to initiate and facilitate a meeting for TDX and the City of Saint Paul to discuss the unresolved issues of opening a new landfill. NOAA received correspondence from J. R. Merculief Saint Paul City Manager, stating that the City was not interested in participating in such a meeting. Ray Dronenburg
10/16/1997 Update or Other Action Final landfill closure plan received for permanently closing the Saint Paul Island Landfill. It described the final appearance of the facility, anticipated post closure use of the property, and the location of any permanent survey monuments. The plan also includes information regarding site access restrictions, site improvements, and post closure monitoring. 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 SAs include: Documentation at SAs 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 Saint Paul Landfill Cell B site 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, PCBs and collect groundwater samples 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
8/20/1999 Site Characterization Workplan Approved Comments sent to be incorporated into TPA 5's final site characterization plan. For purposes associated with the environmental restoration project, NOAA arbitrarily distinguished three areas within the Tract 42 landfill and the Ataqan Subdivision: (1) Cell A (Site 6/TPA Site 5b); (2) Cell B (Site 7/TPA Site 5c [Drum Dump] and Site 8/TPA Site 5d [Solid Waste]); and (3) Cell C. Cell A, located north of Tract 42, contained construction debris and barrels, some with waste oil. Cell B, located north and west of Tract 42, was associated with historical disposal activities on St. Paul Island and contained primarily MSW and drums, some with waste oil. Cell C, located within the boundaries of Tract 42, primarily contained MSW. 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. Louis Howard
1/6/2000 Update or Other Action Staff commented on revised schedules for Saint Paul Island. Staff requested NOAA provide some action item in the cover sheet of the schedule (i.e. modeling, revise closure plans). Louis Howard
5/25/2000 Update or Other Action 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. Cell B of the landfill was the document's emphasis. Staff concurred with the debris removal as presented but noted that NOAA must eventually delineate the nature and extent of the contamination at the site and comply with Solid Waste regulations (18 AAC 60) with regards to monitoring and eventual closure requirements. Louis Howard
8/10/2000 Update or Other Action Staff reviewed and commented on a removal action workplan for drums at the landfill. Main comments were that NOAA must follow, at a minimum, 18 AAC 75.330 Interim Removal Action. The interim removal action may not be used to delay or supplant the cleanup process. The interim removal action must be followed by additional cleanup actions at the site unless ADEC determines that the interim removal action has met the requirements of the site cleanup rules. Louis Howard
8/17/2000 Update or Other Action Staff sent comment letter to NOAA regarding debris sampling plan TPA site # 5 Drum disposal site Saint Paul Landfill Version 1.1 August 2000. ADEC requests NOAA screen the drums in the field for hazardous waste characterization (ignitability, reactivity, corrosivity, and halogen presence) in addition to the Petroflag or PID methods. Ignitability testing is usually performed using a TAG Closed Cup Flash Tester by Koehler Instrument Company, Inc. or its equivalent. Reactivity tests for cyanide and sulfide should be performed on both liquid and solid drum content samples. Solid drum contents should also be tested for reactivity with water. Cyanide and sulfide reactivity testing is usually performed with an EM Quant test kit or its equivalent. Halogen tests for chlorine halogens are typically performed with Chlor-D-Tect test kit by Dexsil Corporation or its equivalent. Corrosivity testing of liquids and solids are typically done with a pH meter and sample material mixed with deionized water if a solid or directly with the meter if a liquid. The text states that gasoline range organics, diesel range organics/residual range organics, volatile organic compounds, semi-volatile organic compounds and metals will be analyzed from two samples taken from the area of greatest contamination determined by screening results. In addition to these analyses, ADEC requests NOAA analyze all soil samples taken at the site for polynuclear aromatic hydrocarbons (if not already analyzed under SVOCs) pesticides and polychlorinated biphenyls since the contents of the drums disposed of at the landfill is not known. Additionally, the metals analyses must be for the following (at a minimum): arsenic, barium, cadmium, chromium, lead, nickel, and vanadium. It cannot be demonstrated that all of the drums held only petroleum products when placed in the landfill and therefore all are suspected to contain hazardous constituents. The identity of a released refined petroleum product must be assumed to be unknown unless a responsible person demonstrates that the product is only gasoline or only refined non-gasoline products (see 18 AAC 75.341). PAH analysis for soils would be required for all petroleum releases at the site, unless the sum of the applicable soil cleanup concentrations based on laboratory results for individual petroleum hydrocarbon fractions or ranges determined for the site by applying the corresponding Method 2 – 4 referenced in 18 AAC 75.340 is equal or less than 500 mg/kg. PAH analysis would not be required for cleanup using Method 1 referenced in 18 AAC 75.340. Louis Howard
9/21/2000 Update or Other Action Staff reviewed and approved an interim removal action for the contaminated soils at the landfill. Treatment will be at the ETC system for treatment no later than the 2001 field season. Interim action cannot supplant requirement to do a final cleanup action at the site. Louis Howard
9/21/2000 Update or Other Action Site was reranked based on updated site information for the site. Louis Howard
10/24/2000 Update or Other Action Heather Stockard, SW Program Manager, sent letter to NOAA regarding clarification on landfills at the Pribilof Islands. The Alaska Department of Environmental Conservation (DEC) has met with you on October 23, 2000. Based on the discussion with you this is what we believe to be NOAA’s responsibilities for new solid waste landfills being developed adjacent to or on existing landfills on either island. 1. The old landfill on NOAA property is properly closed out with a liner material and soil cap. NOAA is responsible for any subsequent monitoring and potential remedial action, if necessary, associated with the old landfill. 2. A new landfill is developed on top of the old capped and now closed landfill by the landowner and/or operator of the new landfill. NOAA is not responsible for any release associated with the new solid waste associated with the new landfill. The landowner and/or operator of the new landfill would be responsible for addressing releases derived from the new waste at the new landfill. A new landfill is placed on land NOAA does not own, either adjacent to or situated away from the closed out old landfill. NOAA is not responsible for any release associated with the new landfill. The landowner and operator of the new landfill would be responsible for addressing releases from their landfill. Louis Howard
12/23/2000 Update or Other Action U.S. Congress passed Public Law 106-562 (H.R. 1653) which states in Section 206 Financial Assistance (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 Saint George and the City of Saint 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 Saint Paul and Saint 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. This means by June 21, 2001 the Cities must identify and locate the property it intends to use as the new landfill and enter into an agreement with the State. Also 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
1/22/2001 Update or Other Action NOAA sent letter regarding landfill redevelopment and contribution for cleanup under PL 106-562. Emphasis is on the deadline in the legislation which affects availability of federal financial assistance for landfill development. The amended Fur Seal Act in section 206(b)(3) Limitation- states: " 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 Saint Paul and Saint 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." Since the act was enacted on December 23, 2000, that means the State must enter into a written agreement with the cites of Saint Paul and Saint George by June 21, 2001. The Act does not provide for any extension or waiver of this deadline. NOAA also pointed out in the letter where once NOAA has fulfilled a number of requirements, section 3 of PL 104-91 is replaced with language which does not block NOAA from seeking contribution for cleanup costs. "(B) Subparagraph (A) shall not limit the authority of the Secretary of Commerce to seek or require financial contribution 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." Louis Howard
2/20/2001 Update or Other Action Staff reviewed and commented on the corrective action plan for TPA 5-1 Cell B Saint Paul Landfill. ADEC requests NOAA perform hazardous waste characterization (ignitability, reactivity, corrosivity, and halogen presence) on any drums discovered during excavation. The identity of a released refined petroleum product must be assumed to be unknown unless NOAA demonstrates the product in the drums (container) is only gasoline or only refined non-gasoline products (see 18 AAC 75.341). It cannot be assumed that all of the drums held only petroleum products when placed in the landfill and therefore all are suspected to contain hazardous constituents until proven otherwise. This hazardous waste characterization would be in addition to sampling for: diesel range organics, residual range organics, and benzene, toluene, ethylbenzene, and total xylenes, as listed in Table 2 Page 9. Finally, ADEC requests when NOAA determines that hazardous wastes are present in the drums, confirmation sampling be conducted in the area where the drum was removed to determine the levels present or absent in the soil. Louis Howard
3/2/2001 Update or Other Action Staff sent NOAA comment letter on TPA 2001 proposed schedules. 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.” ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond. 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. 2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. 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. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. Louis Howard
5/24/2001 Update or Other Action Staff reviewed and commented on Drum Dump Cell A interim removal action report and Tar spill site. Based on a review of the data presented in the report, ADEC concurs that the interim removal action was successful and no additional remedial action is required for the Saint Paul Landfill Tar Spill. This no further remedial action determination is only for the Saint Paul Landfill Tar Spill. Based on a review of the data presented in the report, ADEC concurs that the interim removal action was successful and no additional remedial action is required for the Cell A drum dump area. This no further remedial action determination is only for the Cell A drum dump area and it does not apply to any other site mentioned in the document, or any additional closure requirements necessary under 18 AAC 60 Solid Waste Regulations. However, if in the future, additional contamination is discovered at these 2 sites, further investigation and/or remedial actions will be requested of NOAA by ADEC. ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require NOAA to conduct additional assessment and/or corrective actions, if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or to the environment. Section 5.0 Evaluation of Interim Removal Action Page 14: The text states that site characterization, development and implementation of a corrective action plan and landfill closure can proceed without interference from the drum disposal area in Cell A. ADEC concurs. However, NOAA should be aware that for landfill closures or disruptions to closed landfills under 18 AAC 60, ADEC seeks to: (1) eliminate movement of landfill contents - e.g., through wind, water, gravity, vectors; (2) stabilize landfill contents and cover soils; (3) keep water off, out and away; and, (4) minimize erosion. Now that the drums are gone, ADEC requests information in writing from NOAA, within 45 days of receipt of this letter, on its plan to regrade, stabilize, recover, and revegetate the area of the former drum dump area. Louis Howard
5/25/2001 Update or Other Action Staff reviewed and commented on the groundwater monitoring plan which covered TPA 2, 5, 9, 11, 15. Comment was on the lack of current lab certification listed in table 10 for two labs. Staff requested proof of current certification and corrected table in the document with latest expiration date. Louis Howard
12/21/2001 Update or Other Action Letter to Governor Tony Knowles office in Washington D.C. from Congressman Don Young and Senator Ted Stevens originally dated on December 13, 2001. The NOAA of Dept. of Commerce, has been engaged for several years in an extensive environmental remediation effort on the Pribilof Islands, pursuant to Public Laws 104-91 and 106-562, and an agreement (*Legally binding Two-Party Agreement signed in 1996 by ADEC and US DOC/NOAA) with the State of Alaska. The agreement between NOAA and the State calls for NOAA to close the existing landfills on St. Paul and St. George Islands, and to perform various cleanup tasks at other sites. The Alaska Department of Environmental Conservation (ADEC) has advised NOAA that it will not give final approval for closure of the existing landfills until new solid waste management facilities have been completed. To address State's concerns, Public Law 106-562 authorizes appropriation to the Department of Commerce during Fiscal Years (FY) 2001-2005 of up to $10 million in federal funds, to be transferred by grant to the State of Alaska to build new solid waste facilities on the islands. In Fiscal Year 2002, Congress appropriated $2 million toward development of these landfills. However, it will be difficult for Congress to appropriate any further funds until the Alaska Department of Environmental Conservation (ADEC) has developed specific and detailed plans for the new facilities, and generated cost estimates to carry out those plans. NOAA has been in discussions with ADEC and the communities of St. Paul and St. George for approximately three years, seeking to determine the costs for new solid wastes facilities. ADEC has yet to provide anything more than a very broad general estimate of those costs. To enable Congress to consider new solid waste facilities as it develops appropriations legislation for FY 2003, and to enable NOAA to process these grants expeditiously, it is imperative that ADEC provide reliable cost projections and timetables for construction of new solid waste management facilities on St. Paul and St. George (Islands) at the earliest possible time, but certainly no later than the spring of 2002. Louis Howard
2/22/2002 Update or Other Action Letter to Senator Ted Stevens and Representative Don Young. Michele Brown ADEC Commissioner writes: I am writing to clear up some misconceptions in your letter to Governor Knowles regarding the NOAA cleanup efforts on the Pribilof Islands and to respond to your request for detailed plans and cost estimates for new landfills to serve the communities. The Alaska Department of Environmental Conservation (DEC) and NOAA have a legal agreement regarding the cleanup and closure of federally contaminated sites on the Pribilofs. This agreement includes the closure of two landfills (STP TPA 5 and STG TPA 4) that NOAA owned, operated and maintained for over half a century, which have also been traditionally used by the communities of St. George and St. Paul. As you know, to close these landfills, new permitted landfills must be redeveloped as provided in Public Law 104-91 (Section 3 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.) Early discussions between NOAA and the Pribilof communities on how to redevelop new landfills were unsuccessful. In an attempt to move the effort ahead, ADEC stepped in and offered to use Village Safe Water program staff and processes to work with the communities to plan and construct the new landfills. The Village Safe Water program has successfully worked with communities across Alaska to build sanitation infrastructure. We have explained repeatedly to NOAA that landfill construction costs will vary dramatically with the options selected by the communities. Construction costs depend on where the facilities are located, their size, the physical characteristics of the sites, etc. The specificity needed for detailed cost estimates is a product of a planning process, which will occur in the communities themselves. Despite repeated requests, no funding has been available for landfill planning. Fortunately, the situation changed this year due to funding designated in the FY 02 Commerce, Justice, State appropriation bill. Thanks to your support and the FFY 02 appropriation of $2 million for the development of landfills as authorized by Public Law 106-562, we expect to be able to initiate the community planning processes early this spring 2002. This process will yield the detailed cost estimates that Congress needs, along with the other decisions and products that necessarily precede construction. We will move ahead with these processes as quickly as possible. NOAA's earlier inability to provide funding for starting the planning process, however, may make it difficult to provide estimates by the spring of 2002 as requested in your letter. However, we hope to have such detailed estimates available to be considered in the FY 03 appropriations process. Louis Howard
4/17/2002 Update or Other Action Staff reviewed and commented on the Draft Annual Groundwater Monitoring Report 2001 St. Paul Island March 2002 Project 823255.01030000. 2.3 Village Hill Plume Pages 2-5 and 2-6. The text states that chromium was detected in samples collected from all four wells up to 5,200 ug/L. NOAA used a Hach kit to perform hexavalent chromium analyses (Diphenyl-carbazide method) screening. The kit uses a Diphenyl-carbohydrazide (DPC) to form an intensely colored complex with Cr(VI). The complex is measured quantitatively by its visible absorption at 520 nm. However, as in any colorimetric analysis, this test is subject to positive interferences from other colored materials in the sample as well as from other elements that form colored complexes with DPC. The Department views the Hach kit testing as a field screening method and data gathered by field screening never is substituted for laboratory analyses. The only acceptable determination on whether the Cr(VI) is present in a water sample is through laboratory analyses. For example, there are methods available such as: EPA method 218.6, or SW-846 Methods 7000 series method 7195 (coprecipitation) is used to determne Cr(VI) in EP extracts and groundwater, or method 7198 differential pulse polarography used to determine Cr(VI) in natural and wastewaters, and in EP extracts, or method 7199 often used for determination of Cr(VI) in drinking water, groundwater and industrial wastewater effluents by ion chromatography. The Department requests NOAA confirm the validity of Hach kit test results through a strict laboratory analyses using an approved Cr(VI) analytical method for groundwater results where chromium was detected in the groundwater. After determining through laboratory analysis that hexavalent chromium is not present above the Table C Groundwater Cleanup level of 100 ug/L, then NOAA may discontinue analysis for this particular parameter. 2.6 Recommendations Page 2.8 See comments above regarding laboratory analysis of water for hexavalent chromium Cr(VI) to validate the field screening with Hach kits. The Department concurs with semi-annual monitoring of contaminants of concern (COCs) at Tracts 43 and 46. The Department will require monitoring for the following COCs: gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, lead, selenium, hexavalent chromium, and tetrachloroethylene. The Department requests groundwater monitoring of tetrachloroethylene not be limited to MW46-9, but also include MW46-23. MW46-23 will act as a sentinel well to ensure that tetrachloroethylene is not spreading beyond MW46-9. The Department requests that groundwater flow direction be described in the text and shown on the figures for the sites. 4.2 Recommendations Page 4-3 The Department concurs with the recommendations in general with regards to monitoring at this Class III landfill. However, be aware that there may be additional monitoring requirements imposed by the Solid Waste staff within ADEC to comply with 18 AAC 60 Solid Waste regulations. 18 AAC 60.396 Post Closure Care Requirements for a Class III MSWLF states: (a) For at least 60 consecutive months immediately following the closure of a Class III MSWLF, the owner or operator shall conduct visual inspections of the facility at least once every 12 months as described in 18 AAC 60.800. If surface water or groundwater monitoring was required by the department during the active life of the MSWLF, those activities must continue during the post-closure period for visual inspections required under this section. Louis Howard
8/8/2002 Update or Other Action In 2002, the village native corporation, the Tanadgusix Corporation, deeded approximately nineteen acres of land adjacent to and contiguous with Tract 42 to the City of St. Paul for use as a community MSW facility. The regional native corporation, The Aleut Corporation, retained ownership of the subsurface estate. The City of St. Paul identifies this property as the Ataqan Subdivision. Louis Howard
5/1/2003 Update or Other Action Staff received and commented on the draft project report for petroleum contaminated soil remediation. The document will be treated as final since the Department has one comment to be addressed in the future remediation work by NOAA. The Department recommends NOAA apply different procedures to address the situation raised by section 9.2 where incomplete lab data caused 33 cubic yards to be disposed of at the St. Paul Landfill. The Department wishes to commend NOAA and its staff for its efforts to remediate petroleum contaminated soils during the 2002 field season. Louis Howard
6/25/2003 Update or Other Action Staff reviewed and approved the new petroleum contaminated soil stockpile location on Tract 42 at the St. Paul landfill. The Department has reviewed and will approve your request to construct a temporary petroleum-contaminated soil (PCS) stockpile on Tract 42, which is federal government-owned land at the St. Paul Landfill (known as Two-Party Agreement Site 05). Upon placement of the first cubic yard of contaminated soil at the storage area within Tract 42, the one-hundred eighty (180) day time limit starts for your agency to properly address the soil in accordance with Contaminated Sites Regulations (18 AAC 75). For example, if placement of the contaminated soil begins on July 7, 2003, then the Department will require NOAA to submit a work plan for applying for a long-term stockpile (no more than 2 years) approval prior to January 3, 2004. Alternatively, your agency may propose to remediate or properly dispose of the soil in accordance with 18 AAC 75, if a monofill permit is not granted by the Department under 18 AAC 60 Solid Waste regulations to address the petroleum-contaminated soil. Your agency will notify the Department when this short-term stockpile clock has begun by fax 907-269-7649, directly calling 907-269-7552 or electronic mail to louis_howard@dec.state.ak.us. Please be aware that the Department’s review and concurrence on the proposed work is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the proposal does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, or personnel from complying with other applicable laws and regulations. Louis Howard
10/15/2003 Update or Other Action During the 2003 field season, NOAA relocated an estimated 14,736 cubic yards (CY) of MSW from Cell A, Cell B, and from portions of Cell C where MSW existed inside Tract 42 within 50-ft of the Tract 42 boundary. The MSW was incorporated within the southern and western portions of Tract 42, inside the 50 ft setback line, where it was leveled and compacted. NOAA placed on Tract 42 approximately 23,397 CY of PCS that had been excavated from St. Paul Island corrective action sites. Louis Howard
1/13/2004 Update or Other Action Staff reviewed and approved the request to extend the expiration date of the short term stockpile for petroleum contaminated soils currently being stored on Tract 42 at the St. Paul Landfill. The Department has originally approved the extension in an email on December 22, 2003 to NOAA. The initial short term stockpile approval has expired on January 7, 2004 and this extension will grant NOAA an additional one-hundred and eighty (180) days from that date. Louis Howard
6/10/2004 Update or Other Action The Alaska Department of Environmental Conservation has conducted a risk evaluation of landspreading-contaminated soil on the National Weather Service (NWS) property and potential effects to human or ecological receptors (see enclosure) Human Health The housing scenario is protective of all exposure scenarios that are likely to occur at this site. An occasional worker would be protected by the estimate for residential exposure. Given the low cumulative risk estimate and the low risk estimates for individual petroleum fractions, it is highly unlikely that the land farming operation would have any negative impact on the NWS residents. Ecological Receptors It is unlikely that soil contamination will result in adverse effects to terrestrial or avian receptors on the island. Generally inhalation is not an exposure route evaluated for animals because it is usually dwarfed by ingestion when animals reside on a contaminated site. As seals will not be entering the land farm area, and as there is no reason to suspect large scale deposition of fugitive dust at the seal rookery, ingestion is not a pathway of concern. It is unlikely that the land farm would endanger the seal population or any population dependent upon seals. Louis Howard
7/7/2004 Update or Other Action Staff reviewed and approved the Operations Work Plan for Petroleum contaminated soil remediation for soils at the landfill being placed at the National Weather Service using landspreading as a remediation method. After reviewing the document, the Department will approve the plan as a final version. The favorable, yet conservative, fate and transport modeling the National Oceanic and Atmospheric Administration (NOAA) conducted for the contaminated soil combined with our own independent risk evaluation has contributed to this approval. NOAA is responsible for the actions of contractors, agents, or other persons who perform work to accomplish the approved plan. For any activity that significantly deviates from the approved plan, it shall notify the Department to obtain written approval in the form of a work plan amendment before beginning the activity. Any action taken by NOAA or its agent that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The Department will give the final determination as to the significance of any deviation or the need for an amendment. Louis Howard
8/2/2004 Update or Other Action Staff reviewed and commented on NOAA's request sent via email on 8/1/04 for extension of the short-term permit for the petroleum-contaminated soils in tract 42 at the St. Paul Landfill. The Department has previously approved an extension for the placement of a short-term stockpile of petroleum-contaminated soils on Tract 42 at the St. Paul Landfill. The original time period for the extension was from January 7, 2004 to approximately July 7, 2004. The Department’s approval has expired for that extension. Upon review of NOAA’s latest request, the Department has decided to renew the previous extension and it will remain in effect from July 7, 2004 to January 7, 2005. Louis Howard
8/23/2004 Update or Other Action Letter to RAB St. Paul from NOAA: Joint Management Board Consultation requirement or not for NOAA use of NWS land for landspreading operations. The June 18, 2004 RAB meeting was held on St. Paul and NOAA noted several areas were being discussed for implementing landspreading operations. Tract 42, National Weather Service land (Tract 41, T35S, R131W, Seward Meridian), and the Vehicle Boneyard. A question was raised on whether or not the Joint Management Board would review the proposed use of the NWS land. NOAA has reviewed the 1976 Cooperative Agreement, relevant provisions of Alaska Native Claims Settlement Act, and other Federal laws and has determined the since the NOAA Weather Service property is a "Government Withdrawal" under the 1976 Memorandum of Understanding among TDS, Tanaq, and Dept. of Commerce, neither the property nor NOAA's use of the property, is subject to oversight by the Pribilof Islands JMB. Further, as determined by the State Department of Environmental Conservation risk assessment, NOAA's proposed land spreading activities at the NOAA WS property is protective of human health, welfare, safety and the environment including groundwater, fur seals and adjacent lands. Louis Howard
8/26/2004 Update or Other Action Letter from NOAA re: Addendum 2 to Closure plan. NOAA has abandoned the proposal to construct a PCS monofill and proposed to use an estimated 12,000-15,000 cubic yards of PCS to construct the cap cover over the Tract 42 municipal solid waste. Louis Howard
11/15/2004 Update or Other Action Staff reviewed and commented on the request for closure on St. Paul Landfill Cell "A" TPA Site 5b NOAA Site 6. Staff concurred that all petroleum associated with releases from drums found at the Cell "A" Site has been addressed and no further remedial action is required. Legal description for Cell "A" is Township 35 South, Range 131 West, Section 17 of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 1986. The City of St. Paul is the surface estate owner of Cell "A" and the grater Ataqan Subdivision. The Aleut Corporation is the subsurface estate owner. In accordance with Paragraph 59 of the Two-Party Agreement, this is to confirm that all corrective action has been completed to the maximum extent practicable at the St. Paul Landfill Cell A, TPA Site 5b, NOAA Site 6, in accordance with the Agreement and that no further remedial action is required as part of this conditional closure granted by ADEC. ADEC is basing this determination on the most current and complete information provided by NOAA to the department. ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations, 18 AAC 60 Solid Waste regulations, and AS 46.03 to require NOAA to perform additional containment or cleanup if subsequent information indicates that: (1) the level of contamination that remains does not protect human health, safety, or welfare, or the environment (which includes, but is not limited to: area of public concern, ecological receptors, environmentally sensitive areas and marine waters); or (2) the information ADEC relied upon (to make its decision) was invalid, incomplete, or fraudulent. Louis Howard
2/11/2005 Update or Other Action Request for conditional closure approved for TPA Site 5d NOAA Site 8 St. Paul Landfill Cell B (Solid Waste). The St. Paul municipal solid waste (MSW) landfill was arbitrarily divided into three areas or cells by NOAA in 2000, for discussion and closure planning purposes. Cells A and B are currently located on property known as the Ataqan Subdivision, owned by the City of St. Paul. Cell B occupies approximately 3.949 acres. Cell C is located within Tract 42, a 5.78 acre parcel owned by NOAA. Legal description of Cell B is Township 35 South, Range 131 West, Section 17, of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 1986. The City of St. Paul is the surface estate owner of Cell B and the greater Ataqan Subdivision. The Aleut Corporation is the subsurface estate owner. The objective for Cell B was simply to remove the deposits of municipal solid waste, relocating it to Tract 42 for proper landfilling. Cleanup of contaminated soil was not an objective for Site 8, so there are no applicable cleanup levels. During closure activities, NOAA removed a total of approximately 13, 560 cubic yards of MSW from Cell B and relocated it to within the 50 foot setback area at Tract 42. Louis Howard
2/28/2005 Update or Other Action NOAA provided a list of wells it decommissioned on St. Paul Island. At the Landfill nine wells were decommissioned-MWSNPLF-2 through MWSNPLF-8, HC-2, and HC-3. Louis Howard
4/11/2005 Long Term Monitoring Established Groundwater monitoring will be required at the site due to the present at the site (RRO contamination present above the migration to groundwater levels for Method 2). Up to eight monitoring wells will be sampled as a part of NOAA's long-term operations and maintenance responsibility. Louis Howard
4/11/2005 Conditional Closure Approved Staff reviewed and approved NOAA's submittal for conditional closure at TPA 05c Landfill Cell B (Drum Dump) at the St. Paul Landfill. NOAA has, to the maximum extent practicable, removed drums and petroleum contaminated soil from the site. Approximately 1,400 cubic yards of petroleum-contaminated soil was removed from the site and 76 drums. No further remedial action is necessary at the site. The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required: 1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1; 2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone; 3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and 4.The written approval from the landowner of the off-site location is required. The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager. Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including: (A) an area of unique, scarce, fragile, or vulnerable natural habitat; (B) an area of high natural productivity or essential habitat for living organisms; (C) an area of unique geologic or topographic significance that is susceptible to a discharge; (D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits; (E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and (F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1)) “area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include: (A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance; (B) areas of high natural productivity or essential habitat for living resources; (C) areas of substantial recreational value or opportunity; (D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water; (E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development; (F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and (G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. Louis Howard
4/11/2005 Institutional Control Record Established In the event that the remaining contaminated soil becomes accessible by the removal of the soil located in the vicinity of the Landfill Cell C TPA 5, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i). Louis Howard
9/19/2005 Update or Other Action NOAA Letter to ADEC Solid Waste Program RE: Review and Approval of Closure Report, Site 5/TPA Site 5a – St. Paul Landfill Cell C (Tract 42), St. Paul Island, Alaska, dated September 19, 2005 NOAA requests your review at the earliest possible time. NOAA will consider this the final version only pending the receipt of any substantive comments that would otherwise alter the conclusions and recommendations reached in the document. Additionally, NOAA requests that Solid Waste Program accept Cell C’s closure consistent with 18 Alaska Administrative Code Chapter 60 (Solid Waste Management) and approve NOAA’s revised Post-Closure Monitoring Plan. The Plan is included as Appendix E of the Closure Report. If ADEC considers this landfill closed, consistent with the applicable laws and regulations, please sign the attached pages and return one of them to NOAA. NOAA has sent a similar letter and request to the ADEC Contaminated Sites Program, requesting conditional closure of Cell C consistent with the Two Party Agreement between ADEC and NOAA. Leslie Simmons
10/4/2005 Update or Other Action Post-closure monitoring at the site will include groundwater sampling in the vicinity of the St. Paul Landfill and periodic inspections of the landfill cap over a five-year period. NOAA also proposes recording a deed notice regarding the closed MSW landfill and prohibited excavation at the closed cell and the use of PCS for its cap. Louis Howard
10/4/2005 Update or Other Action Because closure of Cell C has been completed in accordance with regulatory requirements, staff concurred with NOAA's request for acceptance of the Cell C closure consistent with 18 AAC 60 and with the 1996 Two-Party Agreement signed by NOAA and the State of Alaska. NOAA will conduct post-closure monitoring to include groundwater sampling in the vicinity of the St. Paul Landfill and periodic inspections of the landfill cap over a five-year period. NOAA also proposes recording a deed notice regarding the closed MSW landfill and the use of PCS for its cap. ADEC signed request for Conditional Closure of St. Paul Landfill Cell C, TPA Site 5a, NOAA Site 5, St. Paul Island, Alaska. Approvals: In accordance with Paragraph 59* of the Two-Party Agreement, this is to confirm that all corrective action has been completed to the maximum extent practicable at the St. Paul Landfill Cell C, TPA Site 5a, NOAA Site 5, in accordance with the Agreement and that no further remedial action is required as part of this conditional closure granted by ADEC. ADEC is basing this determination on the most current and complete information provided by NOAA to the department. ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations, 18 AAC 60 Solid Waste regulations, and AS 46.03 to require NOAA to perform additional containment or cleanup if subsequent information indicates that: (1) the level of contamination that remains does not protect human health, safety, or welfare, or the environment (which includes, but is not limited to: area of public concern, ecological receptors, environmentally sensitive areas and marine waters); or (2) the information ADEC relied upon (to make its decision) was invalid, incomplete, or fraudulent. *NOTE: Paragraph 59- Closure of Sites of Operable Units 59. At any time while this Agreement is in effect, NOAA may request from ADEC written confirmation that all corrective action has been completed at a site(s) or operable unit(s) in accordance with this Agreement. Within thirty (30) Days of its receipt of such request. ADEC shall: (1) provide written confirmation that no further corrective action is required at the subject site(s) or operable unit(s): or (2) deny such request and provide a written explanation of the technical bases on which the request is denied. ADEC shall not deny certification that corrective action is complete at any site(s) or operable unit(s) solely on the basis that post-remedial measures, such as monitoring, shall remain in place for a period of months or years. Louis Howard
10/4/2005 GIS Position Updated Data were collected in World Geodetic System of 1984 (WGS 84) datum, Universal Transverse Mercator Zone 2 coordinate system in meters (NOAA 2005 Report) Louis Howard
10/27/2005 Update or Other Action In accordance with Paragraph 59 of the Two-Party Agreement, this is to confirm that all landfill closure activities have been completed at the St. Paul Landfill Cell C, TPA Site 5a, NOAA Site 5, in accordance with 18 Alaska Administrative Code Chapter 60, and that ADEC approves NOAA's proposed revised post-closure monitoring plan dated September 19, 2005. ADEC is basing this determination on the most current and complete information provided by NOAA to ADEC. ADEC reserves its rights, under 18 AAC 60 Solid Waste regulations and AS 46.03 to require NOAA to perform additional containment or cleanup if subsequent information indicates that: (1) the level of contamination that remains does not protect human health, safety, or welfare, or the environment (which includes, but is not limited to: area of public concern, ecological receptors, environmentally sensitive areas and marine waters); or (2) the information ADEC relied upon (to make its decision) was invalid, incomplete, or fraudulent. Leslie Simmons
11/7/2005 Update or Other Action ADEC Solid Waste Program sent letter to NOAA-RE: Closure Report for Site 5a, St. Paul Landfill Cell C, Tract 42. The Alaska Department of Environmental Conservation has completed its review of the closure report for Site 5a, St. Paul Landfill Cell C, Tract 42, dated September 19, 2005 and approves the closure of the landfill. If you have any questions about closure and post-closure requirments, please contact ADEC SW Program staff.
5/25/2006 Update or Other Action Corrective action plan for removal of lead contaminated soil St. Paul Island-approval letter sent to NOAA by Leslie Simmons. Solid Waste Program reviewed the May 15, 2006 Corrective Action Plan for removal of lead contaminated soil at Teacher Houses 101 and 103 and the Duplex (NOAA Site 60 Non-TPA). The plan proposes disposal of Resource Conservation Recovery Act (RCRA) Subtitle C lead contaminated hazardous waste at a federally permitted hazardous waste facility and proposes disposal of Subtitle D lead-contaminated solid waste at the Tract 42 landfill or an alternative location approved by ADEC. The solid waste program approves the plan, because it is consistent with Title 18, Chapter 60 of the Alaska Administrative Code. Leslie Simmons
10/31/2006 Update or Other Action NOAA conducted in-situ amendment of lead contaminated soil at the Lead Contaminated Soil site in October 2006 using a phosphate based additive, testing the amended soil via the TCLP, and verifying prior to excavation that it did not exceed the leachability characteristic for lead. Once this was verfied, the soil was excavated, becoming a solid waste that was non-hazardous in nature at that time. The amended non-hazardous waste soil was then disposed of in the Tract 42 Cell C landfill. NOTE: the Lead Contaminated Soil site consists of the lead contaminated soil around the: teacher houses 101 and 103, and duplex 108/109 which exceeded the 5.0 milligram per liter (mg/L) RCRA limit for leachable lead. Louis Howard
10/15/2007 Update or Other Action Demolition work on the Municipal Garage, Decommissioned Power Plant, and pump house until 2007. NOAA and the City of St. Paul reached an agreement in 2007 to allow the inert demolition wastes to be disposed of in the City's landfill. While lead contaminated soil around the Municipal Garage exceeded the commercial and industrial cleanup level of 1,000 mg/kg, it did not fail TCLP. This soil was disposed of ina trench excavated in the Tract 42 Cell C landfill in August 2007, along with the teach house 102 radiators coated with lead-based paint. This last remaining trench in Tract 42 Cell C was backfilled on October 15, 2007 with the petroleum contaminated soil (PCS) that had been excavated during trench excavation. PCS covered all wastes in the trench to a thickness of at least 2 feet. The cap soil disturbed by the 2007 disposal activities will be seeded with native grasses and fertilized in the spring of 2008. Louis Howard
12/14/2007 Update or Other Action Technical Memorandum Request for Re-Closure of Site 5a/TPA Site 5 - St. Paul Landfill Cell C (Tract 42) St. Paul Island, AK. Following completion of landfill closure Tract 42, which contains Cell C, also known as TPA Site 5, is scheduled for transfer to the City of St. Paul under the Transfer of Property Agreement (TOPA, NOAA 1984). Tract 42 lies in Section 17, Township 35 South, Range 131 West of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 196 (57 degrees, 8 minutes, 54.10 seconds North Latitude, 170 degrees 13 minutes 57.76 seconds West Longitude). tract 42 is a 5.78 acre tract owned and managed by NOAA, and is surrounded by the City of St. Paul owned property known as the Ataqan Subdivision. The landfill is a former municipal solid waste disposal site owned by the National Oceanic and Atmospheric Administration (NOAA). NOAA closed the landfill with concurrence in 2005 by the ADEC Contaminated Sites Program, and the ADEC Solid Waste Program. NOAA then reopened it in 2006, with ADEC Solid Waste Program concurrence, for additional disposal of inert waste (i.e. non-hazardous waste as defined by RCRA and non-Regulated Asbestos Containing Material-RACM). The inert wastes included: materials from lead-based paint and asbestos abatement, building renovation, building and well head demolition debris, and lead contaminated soil above ADEC Contaminated Sites Program's cleanup standards of 400 milligrams per kilogram (mg/kg) for residential areas and 1,000 mg/kg for commercial and industrial areas. NOAA recapped the area used for inert waste disposal in 2006 and 2007, consistent with the ADEC Solid Waste Program approved landfill re-open request. Conclusions (from the St. Paul Tract 42 Re-Closure Technical Memorandum): The Tract 42 Cell C, TPA Site 5, landfill reopened by NOAA in 2006 with the approval of ADEC's Solid Waste Program. Subsequently, NOAA disposed of a total of 271 cubic yards of lead contaminated soil, demolition debris, and other miscellaneous items removed from several NOAA excavation, renovation, and demolition projects in several small trenches on the top of the existing Tract 42 Cell C cap during 2006 and 2007. These trenches were then capped in compliance with State of Alaska regulations in the fall of 2006 and 2007. NOAA will continue to conduct groundwater monitoring at the landfill under the ADEC approved 2005 Long-Term Groundwater Monitoring Plan, and will perform annual visual inspections of the landfill cap as specified in the 2005 Closure Report, with repairs as needed, for at least 5 years from the ADEC approved closure date. NOAA performed its first visual inspection in 2005, but the 5 year period will be restarted at the date when ADEC signs the attached closure approval form. After 5 years, NOAA understands that ADEC may grant a reduced frequency or cessation of inspections and groundwater monitoring if requesting by NOAA and supported by data. Louis Howard
1/24/2008 Update or Other Action DEH SW Program Bob Blankenburg SW Program Coordinator sent John Lindsay PPO Manger of the NOAA Pribilof Project Office a letter. Subject: Approval of Re-closure of Site 5a/TPA Site 5 St. Paul Landfill Cell C (Tract 42) St. Paul Island, Alaska. The Alaska Dept. of Environmental Conservation Solid Waste Program (ADEC) received a letter, dated December 14, 2007, with an attached technical memorandum, requesting ADEC approval of re-closure of the Site 5a/TPA Site 5 - St. Paul Island Landfill Tract 42 Cell C (landfill) in St. Paul, Alaska. ADEC originally approved closure of this landfill in 2005. The National Oceanic and Atmospheric Administration (NOAA) reopened the landfill in 2006, with ADEC cocurrence, to disposed of inert wastes (described in detail in the December 14, 2007 technical memorandum). NOAA capped the area used for disposal of the inert waste in 2006 and 2007, as described in the technical memorandum. ADEC Solid Waste Program hereby approves the re-closure of this landfill. Post-closure monitoring is required for at least five (5) years from the date of this approved letter. No further investigation or remedial action is required at this site, unless new information regarding conditions at the site indicate that further action is required to protect human health or the environment. Louis Howard
4/28/2008 Report or Workplan Review - Other Staff reviewed and commented on the Annual Groundwater Monitoring Report for St. Paul Island. The report documents sampling of groundwater from thirty-six (36) wells at five (5) areas on St. Paul Island. These areas are City of St. Paul Old Village (a.k.a. Tract 46), Diesel Seep (Salt Lagoon Diesel Seep a.k.a. TPA Site 13), Icehouse Lake (a.k.a. TPA Site 14), St. Paul Municipal Landfill Area (a.k.a. TPA Site 5) and the National Weather Service Landspreading Area Site. ADEC requests NOAA add an approximate indicator of groundwater direction to all figures with groundwater monitoring wells in future report submittals. There is also new ADEC monitoring well guidance out “Monitoring Well Design and Construction for Contaminated Sites” (February 2008) which can be found at http://www.dec.state.ak.us/spar/guidance.htm The text indicates one of the monitoring wells was covered with soil. ADEC requests NOAA identify procedures it has put in place to prevent this from happening in the future and/or notification to local entities regarding the importance of not burying existing monitoring wells with fill material. Louis Howard
6/4/2008 Update or Other Action 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). As of June 4, 2007, the St. Paul Landfill (Active Cell "C" and Cell "A") has buried drums, solid waste and contaminated soil. Cell "B" drum dump has drums and contaminated sol. Cell "C" site conditions: Municipal solid waste (MSW), lead-based paint abatement waste (including building renovation waste), demolition debris, and lead soil from other sites consolidated at this location; vegetated cap; cap consists of petroleum-contaminated soil; post-closure cap monitoring until January 24, 2013; groundwater monitoring (potential DRO and lead contamination) until spring 2013 pending regulatory review; deed notice. Cell "A" site conditions: Residual soil DRO or RRO contamination remains in at least one limited area among construction and demolition debris. All buried debris and MSW has been capped with a minimum of two feet of clean scoria; the cap side walls are vegetated; post-closure cap monitoring until November 2010 pending regulatory review; deed notice. Cell "B" drum dump site conditions: Residual soil contaminated with DRO and RRO remains beneath City of St. Paul working pad circa 25 ft bgs; long-term groundwater monitoring at least until spring 2013 as part of the Cell C monitoring effort; deed notice. Cell "C" Property Owner as of November 6, 2007 is NOAA. Cell "A" and Cell "B" owners are City of St. Paul and The Aleut Corporation (TAC) for the subsurface estate. Jennifer Roberts
12/21/2009 Update or Other Action The National Oceanic and Atmospheric Administration has performed site characterization and restoration on St. Paul Island, Pribilof Islands, Alaska and monitored groundwater for diesel range organics, gasoline range organics, volatile organic compounds, semivolatile organic compounds, metals, and total dissolved solids at monitoring wells located at multiple sites. Contaminants of concern and representative wells were chosen for long-term monitoring at five sites, which include the City of St. Paul, Icehouse Lake, the Diesel Seep near Salt Lagoon, the St. Paul Municipal Landfill, and the National Weather Service Station Landspreading Area/Oil Drum Dump Site. Starting in June 2006, the National Oceanic and Atmospheric Administration Office began long-term groundwater monitoring on a semi-annual basis and contracted Bethel Services, Inc. to continue groundwater monitoring beginning in May 2008. Sampling scheduled for May 2009 did not take place until June 2009 due to fuel shortages on the island. After obtaining concurrence from Alaska Department of Environmental Conservation (ADEC), NOAA directed that six of the 36 monitoring wells be dropped from the program beginning in the spring of 2009; therefore, 30 groundwater monitoring wells located at four sites (City of St. Paul, Icehouse Lake, the Diesel Seep near Salt Lagoon, and the St. Paul Municipal Landfill) were sampled in June 2009. BSI completed groundwater monitoring of the subject monitoring wells between June 9 and June 15, 2009. Presented in this report are the results of the June 2009 St. Paul monitoring well sampling event. Nine wells sampled in June 2009 were found to have contaminants in concentrations exceeding ADEC cleanup levels. Mann-Kendall statistical methods were used to evaluate contaminant trends at 22 of the 30 wells sampled for a total of 45 calculated trends. The analyses incorporated available data from October 2003 to Jun 2009. Of the 45 contaminant concentration trends analyzed, nine met data quality requirements and are useable for the purposes of this report. All other trends had less than a 95% level of confidence, and therefore did not meet the data quality objective (DQO) of a 95% confidence level or greater. The nine trends meeting DQO criteria showed DRO concentrations trending upward at monitoring wells MW46-6 and MWA-3 and downward at monitoring wells MW46-14 and MWIHL-4. The trends showed benzene concentrations trending downward at MW46-5, MW46-6, and MW46-28; total lead concentrations trending downward at MWSNPLF-1; and ethylbenzene concentrations trending downward at monitoring well MW46-5. Additional sampling and analysis will further verify the contaminant trends presented in this report. Factors influencing groundwater contaminant concentrations such as water table variations as related to seasonal changes and sampling location relative to the water table were neglected in the statistical analysis owing to lack of data availability. Though some wells had contaminant concentrations above ADEC cleanup levels these particular wells have historically been contaminated above the cleanup levels. Louis Howard
4/29/2010 Update or Other Action Annual groundwater monitoring report received. St. Paul Municipal Landfill, located approximately 3 miles north of the City of St. Paul, is an active landfill and accepts municipal wastes generated on the island. A closed portion of the landfill was capped by petroleum contaminated soil. Eight wells have been selected for long-term monitoring of DRO, GRO, BTEX, and lead contaminants. NOAA has retained eight monitoring wells at the St. Paul Municipal Landfill, MWSNPLF-1, MWSNPLF-10, HC-4, MWSNPLF-9, HC-5, MWSNPLF-11, MWSNPLF-12, and MWSNPLF-13. All eight wells have been designated as sentinel wells to monitor potential contaminant migration associated with former disposal activities in and around the area. The following sections present trend analyses for all sentinel wells at the St. Paul Municipal Landfill where data is available and meet the previously described criteria. Only one well, MWSNPLF-1, had sufficient data to perform a trend analysis on any of the analytes collected. A trend analysis was performed on the concentrations of DRO and total lead. The concentration of DRO was trending up and the total lead concentration was trending down. The contaminant concentration trend for total lead had a significance level of a < .05 meeting the data quality requirements to be considered statistically valid for the purposes of this report. Only one well, MWSNPLF-1, at the St. Paul Municipal Landfill had sufficient data to calculate a statistical trend. A trend analysis was performed on the concentrations of DRO and total lead. The lead trend met data quality requirements and is useable for the purposes of this report. The trend showed lead concentrations trending downward. Louis Howard
2/10/2011 Update or Other Action Staff received the St. Paul Mid-Year Monitoring Report. The purpose of continued groundwater monitoring on St. Paul is to monitor petroleum hydrocarbon constituents at designated monitoring wells within the City of St. Paul, near Icehouse Lake north of the city, the Diesel Seep near Salt Lagoon, and within the St. Paul Municipal Landfill (NOAA, 2005) and report sampling results. COC include DRO, GRO, and BTEX. Total and dissolved lead are also monitored at Icehouse Lake and the St. Paul Municipal Landfill. In 2000 and 2001, site characterizations were conducted at eight two-party agreement (TPA) sites on St. Paul Island. This project focuses on GW sampling at four of these sites: the City of St. Paul Old Village, Icehouse Lake, Diesel Seep, & the St. Paul Municipal Landfill. In each of these areas, GW wells have been designated for long-term monitoring of hydrocarbon contaminants & lead to establish contaminant trends. NOAA has retained eight monitoring wells at the St. Paul Municipal Landfill, MWSNPLF-1, MWSNPLF-10, HC-4, MWSNPLF-9, HC-5, MWSNPLF-11, MWSNPLF-12, and MWSNPLF-13. All eight wells have been designated as sentinel wells to monitor potential contaminant migration associated with former disposal activities in and around the area. The following sections present trend analyses for all sentinel wells at the St. Paul Municipal Landfill where data is available and meet the previously described criteria. Only wells, MWSNPLF-1 and MWSNPLF-11 had sufficient data to perform a trend analysis on any of the analytes collected. A trend analysis was performed on the concentrations of DRO and total lead at MWSNPLF-1 and total lead only at monitoring well MWSNPLF-11, the results of which are presented in Table 5-2. At monitoring well MWSNPLF-1 DRO concentrations are trending upward and total lead concentrations are trending downward. Total lead concentrations at monitoring well MWSPLF-11 are trending upward. No contaminant concentration trends for wells at the St. Paul Municipal Landfill had a significance level of a < .05 therefore do not meet the data quality requirements to be considered statistically valid for the purposes of this report Louis Howard
3/24/2011 Update or Other Action NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island. Municipal Landfill - Continue monitoring all eight wells annually (MWSNPLF-1, MWSNPLF-9, MWSNPLF-10, MWSNPLF-11, MWSNPLF-12, MWSNPLF-13, HC-4, and HC-5) through spring 2013 sampling round. If current contaminant concentration trends continue, decommission all wells after the spring 2013 round except potentially MWSNPLF-1 and MWSNPLF-11; then consider going to semi-annual monitoring for DRO, total and dissolved lead at these wells to facilitate better trend analysis. Reason: ADEC Solid Waste Program requirements stipulate annual monitoring of the eight wells around Landfill Cell C for a minimum of 5 years after final cap closure, i.e. until at least January 24, 2013. Analytes to be monitored for are DRO, GRO, BTEX, total lead and dissolved lead. Since June 2006, all analytes at wells MWSNPLF-9, MWSNPLF-10, MWSNPLF-12, MWSNPLF-13, HC-4, and HC-5 have had concentrations reported below MRL. Contaminant concentration trend analysis at these wells is not practicable due to a lack of sample results above MRL. If sampling continues with similar results through spring 2013, decommissioning these six wells will remove potential pathways for introduction of contaminants to the groundwater. MWSNPLF-1 – DRO was detected above the cleanup criteria during the June 2007 and May 2010 sampling rounds; there is an upward DRO concentration trend analysis at < 90% confidence level. There is a downward total lead concentration trend analysis at < 90% confidence level. All other analytes have been reported as ND or below MRL. Analytical results and trend analysis will be evaluated after the spring 2013 sampling round; at that time a decision will be made to decommission the well, continue annual sampling for just DRO (if all other analytes remain below MRL), or increase DRO sampling to semiannual for improved trend analysis. MWSNPLF-11 - total lead was detected at 6.26 and 14.5 ppb during the May 2008 and May 2010 sampling rounds respectively at this well. Although these hits are below the cleanup criteria of 15 ppb, they produce an upward total lead concentration trend analysis at < 90% confidence level. On the other hand, dissolved lead was undetected during these sampling rounds indicating low bio availability. Analytical results and trend analysis will be evaluated after the spring 2013 sampling round; at that time a decision will be made to decommission the well, continue annual sampling for just total/dissolved lead (if all other analytes remain below MRL), or increase lead sampling to semiannual for improved trend analysis. Louis Howard
4/4/2011 Update or Other Action Annual GW monitoring report received. The purpose of this report is to present the results of the November 2010 sampling event and to analyze available data from all the monitoring wells currently included in the St. Paul Island long-term groundwater monitoring project for the presence of increasing or decreasing trends in the concentration of analytes. Groundwater sample analytes included DRO, GRO, benzene, toluene, ethylbenzene, total xylenes (BTEX), and lead. Groundwater sampling procedures and protocols used for this project followed the NOAA Master Quality Assurance Plan (NOAA, 2006), the Final Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska (NOAA, 2005), and the Groundwater Monitoring Work Plan, St. Paul Island, Pribilof Islands, Alaska updated and prepared by BSI in May 2009. St. Paul Municipal Landfill (TPA Site 5) St. Paul Municipal Landfill, located approximately 3 miles north of the City of St. Paul, is an active landfill and accepts municipal wastes generated on the island (Figure 1-4). A closed portion of the landfill was capped by petroleum contaminated soil. Eight wells have been selected for long-term monitoring of DRO, GRO, BTEX, and lead contaminants. Two wells, MWSNPLF-1 and MWSNPLF-11, at the St. Paul Municipal Landfill had sufficient data to calculate statistical trends. Trend analyses were performed on the concentrations of DRO and total lead at MWSNPLF-1. A trend analysis was performed only for total lead at monitoring well MWSNPLF-11. No trends at the St. Paul Municipal Landfill met data quality requirements for this project, are not considered scientifically defensible, and should not be used to make decisions or draw conclusions. MWSNPLF-1 had 2.27 mg/L DRO (compared to 1.14 mg/L May 2010, 1.71 mg/L May 2008, and 2.34 mg/L June 2007). Louis Howard
8/11/2011 Update or Other Action Staff received the draft LTM plan for review and comment. This long-term groundwater monitoring plan completely replaces and combines National Oceanic and Atmospheric Administration (NOAA) Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska dated August 29, 2005 and NOAA Long-Term Groundwater Monitoring Plan, St. George Island, Alaska also dated August 29, 2005. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island and 10 wells on St. George Island. Some wells are utilized as sentinels to monitor for contaminant plume migration while the rest are used to monitor contaminant concentration trends to evaluate the effectiveness of past remedial actions and natural attenuation of contaminants. The requirements specified in this plan will remain in effect until evaluation of contaminant concentration trends indicate a revision is warranted. All revisions to this plan shall be reviewed and concurred with by ADEC prior to becoming final. The former St. Paul Municipal Landfill Cell C, TPA Site 5a, is located about 3 miles north of St. Paul Village and is contained within Tract 42 (Figure 2-3). NOAA and its predecessor agency (Bureau of Commercial Fisheries), along with the City of St. Paul, managed municipal landfill operations at or near Tract 42 from the 1940s to 2004 (NOAA 2008a). After 2004, NOAA utilized Cell C for disposal of inert debris until final closure in 2007 (NOAA 2008a). ADEC solid waste regulations require post-closure monitoring of landfill sites. NOAA retained the following eight wells to monitor for groundwater contamination in the vicinity of Tract 42: HC-4, HC-5, MWSNPLF-1, MWSNPLF-9, MWSNPLF-10, MWSNPLF-11, MWSNPLF-12 and MWSNPLF-13 (Figure 2-3). These monitoring wells will be sampled annually for at least five years after ADEC acceptance of final closure, which occurred on January 24, 2008 (NOAA 2008a). Therefore, NOAA and ADEC will evaluate contaminant concentration trends in 2013 to determine the requirements, if any, for further monitoring at this site. COCs monitored by these wells are DRO, GRO, BTEX, and lead (total and dissolved). To-date, analyses of collected samples have indicated all analytes at all wells to be non-detect or detected at very low concentrations with the exception of DRO at MWSNPLF-1 and total lead at MWSNPLF-11. Statistical analyses of the DRO and lead concentrations indicate upward trends with low confidences levels. Additional monitoring of contaminant concentration trends at these wells is required to increase statistical confidence levels that the indicated trends are factual and not random. NOAA will sample HC-4, HC-5, MWSNPLF-1, MWSNPLF-9, MWSNPLF-10, MWSNPLF-11, MWSNPLF-12 and MWSNPLF-13 annually; analytes are DRO, GRO, BTEX and lead (total and dissolved). Louis Howard
9/29/2011 Update or Other Action Staff received the draft Long Term Groundwater Monitoring Plan St. Paul and St. George Islands, Alaska, September 2011. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island. ADEC solid waste regulations require post-closure monitoring of landfill sites. NOAA retained the following eight wells to monitor for groundwater contamination in the vicinity of Tract 42: HC-4, HC-5, MWSNPLF-1, MWSNPLF-9, MWSNPLF-10, MWSNPLF-11, MWSNPLF-12 and MWSNPLF-13 (Figure 2-3). These monitoring wells will be sampled annually for at least five years after ADEC acceptance of final closure, which occurred on January 24, 2008 (NOAA 2008a). NOAA and ADEC will evaluate contaminant concentration trends in 2013 to determine the requirements, if any, for further monitoring at this site. COCs monitored by these wells are DRO, GRO, BTEX, and lead (total and dissolved). To-date, analyses of collected samples have indicated all analytes at all wells to be non-detect or detected at very low concentrations with the exception of DRO at MWSNPLF-1 and total lead at MWSNPLF-11. Statistical analyses of the DRO and lead concentrations indicate upward trends with low confidences levels. Additional monitoring of contaminant concentration trends at these wells is required to increase statistical confidence levels that the indicated trends are factual and not random. NOAA will sample HC-4, HC-5, MWSNPLF-1, MWSNPLF-9, MWSNPLF-10, MWSNPLF-11, MWSNPLF-12 and MWSNPLF-13 annually; analytes are DRO, GRO, BTEX and lead (total and dissolved). Louis Howard
5/9/2012 Update or Other Action NOAA sent a request for ADEC [Solid Waste Program - Lori Aldrich] Concurrence Regarding NOAA's Completion of Post-Closure Monitoring at the St. Paul Landfill Cell A on St. Paul Island. Alaska National Oceanic and Atmospheric Administration (NOAA) has completed 5 years of post-closure monitoring at the St. Paul Landfill Cell A on St. Panl Island, Alaska (Two-Party Agreement Site 5b/NOAA Site 6). This memorandum provides documentation of Cell A closure cap monitoring and requests concurrence from Alaska Department of Environmental Conservation (ADEC) Solid Waste Program that NOAA has met and completed its obligations for post-closure monitoring at this site. This site is listed in the ADEC contaminated sites database under File ID 2644.38.017.02. Post-Closure Monitoring and Maintenance NOAA currently collects groundwater samples annually from 8 monitoring wells primarily sited around Cell C which is downgradient from Cell A (Attachment 3, Figure 4). Results of this monitoring are reported to ADEC Division of Spill Prevention and Response, Contaminated Sites Program. Groundwater monitoring will continue until a determination is made that post-closure monitoring is no longer required for Cell C. Documentation of annual post-closure visual monitoring of Cell A's cap with vegetated side slopes began in October 2007 and continued through November 2011. A summary of each year's closure cap monitoring and maintenance are provided in the following paragraphs. Yearly field reports with photos are provided as Attachment 2. Year-One Monitoring NOAA inspected Cell A's closure cap on October 16, 2007. No adverse conditions were observed and it was noted on the inspection form that 350 pounds of fertilizer had been applied to the vegetated side slopes in July 2001. Maintenance was not deemed necessary. Year-Two Monitoring NOAA inspected Cell A's closure cap on June 18, 2008. No adverse conditions were observed and it was noted on the inspection form that 400 pounds of fertilizer had been applied to the vegetated side slopes during the time frame of the inspection. Maintenance was not deemed necessary. Year-Three Monitoring NOAA inspected Cell A's closure cap on December 3, 2009. Snow prevented a complete inspection; however, side slope vegetation was visible above the snow cover. Maintenance was not deemed necessary. Year-Four Monitoring NOAA inspected Cell A's closure cap on November 11, 2010. The inspection report noted that the City was cleaning up the scoria pad on top of the cell and that side slope vegetation looked healthy. Maintenance was not deemed necessary. Year-Five Monitoring NOAA inspected Cell A's closure cap on November 18, 2011. No adverse conditions were noted and maintenance was not deemed necessary. Notice to Deed In May 2008, NOAA filed a Notice to Deed with Alaska Recording District 305 describing the history and final conditions of this property. Conclusion NOAA concludes that it has met its obligation for at least five years of inspection and maintenance of the St. Paul Landfill Cell A and requests that ADEC Solid Waste Program concur with this conclusion. Louis Howard
10/22/2012 Update or Other Action Draft GW monitoring work plan received. The St. Paul Municipal Landfill is located approximately three miles north of St. Paul village and is an active landfill which accepts municipal wasted from the island. A closed portion of the landfill (Cell C) is capped by petroleum contaminated soil. Eight wells will be sampled for this effort at this site in November 2012 only. Groundwater samples will be analyzed for GRO, DRO, BTEX, EDB, 1,2-DCA, total lead, and dissolved lead. Louis Howard
10/23/2012 Update or Other Action Staff received the draft GW monitoring report for St. Paul Island. This report focuses on the results of the December 2011 and June 2012 sampling events and statistical analysis of concentrations trends for groundwater samples collected from June 2006 to June 2012 from 21 of the 28 monitoring wells sampled. Samples from seven wells monitored in December 2011 had detections of at least one contaminant with a concentration that exceeded an Alaska Department of Environmental Conservation (ADEC) groundwater cleanup level (MW46-5, MW46-6, MW46-10, MW46-28, MWA-1, MWA-3, and MWSNPLF-1). Seven wells sampled in June 2012 had detections of at least one contaminant with a concentration that exceeded an Alaska ADEC groundwater cleanup level (MW46-5, MW46-6, MW46-10, MW46-28, MW46-30, MWA-1, and MWA-3). Mann-Kendall statistical methods were used to evaluate contaminant trends at 21 of the 28 wells for a total of 45 calculated trends. The analyses incorporated available data from June 2006 to June 2012. Of the 46 contaminant concentration trends analyzed, six met the minimum confidence level requirement of 95 percent and are considered valid trends by ADEC. The six valid trends include a decreasing benzene concentration trend for MW46-6, a decreasing toluene concentration trend for MW46-10, a decreasing DRO concentration trend for MW46-28, increasing ethylbenzene and total xylenes concentration trends for MW46-28, and decreasing DRO concentration trend for MWIHL-4. Seasonal effects and sampling locations relative to the water table were not evaluated in the statistical analysis owing to data availability. Although eight wells had contaminant concentrations above ADEC cleanup levels for either the December 2011 or June 2012 sampling events, there are no new exceedances that have not been observed in the past. Four of the six wells with statistically valid concentration trends are for contaminants that are decreasing. Louis Howard
10/23/2012 Report or Workplan Review - Other SW Program Lori Aldrich sent James Malchow a letter regarding the Saint Paul Landfill Cell A on Saint Paul Island. The Alaska Department of Environmental Conservation (ADEC) received a request from the National Oceanic and Atmospheric Administration (NOAA), dated May 9,2012, to terminate post-closure obligations for the Saint Paul Landfill Cell A, on Saint Paul Island, Alaska. The Saint Paul Landfill Cell A is located within Section 17 of Township 35 South, Range 131 West, Seward Meridian. The site was capped and conditionally closed by NOAA in 2004. The Department inspected the closed site on June 22, 2012 and no deficiencies in the cap were noted. The NOAA submission included monitorin reports, inspection reports, and photos from 5 years of post closure monitoring. Monitoring reports show that NOAA has met the conditions of closure. Photos indicate that the scoria cap is appropriately maintained, and the slopes adequately revegetated. The submission also included a copy of a notification to the deed for the property, recorded on March 12,2008 in the Aleutian Islands District, that satisfies the requirements of Title 18, Chapter 60, Section 490(a) of the Alaska Administrative Code [18 AAC 60.490 (a)]. ADEC has determined that the NOAA has met their post-closure obligations for the Saint Paul landfill Cell A, and the site does not pose a threat to public health, safety, or the environment. ADEC approves your request to terminate post-closure obligations and considers the status of the landfill to be retired. ADEC reserves the right to require additional investigation, assessment, monitoring, or remediation if new information regarding conditions at the site indicates that further actions are necessary to protect human health or the environment. Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 - 18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185. Informal review requests must be delivered to the Division Director, Alaska Department of Environmental Conservation, 555 Cordova Street, Anchorage, AK 99501 within 15 days of the permit decision. Adjudicatory hearing requests must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby Avenue, Suite 303,]uneau, Alaska 99801, within 30 days of the permit decision. If a hearing is not requested within 30 days, the right to appeal is waived. More information regarding submitttng a request for an informal review or adjudicatory hearing may be found at www.dec.state.ak.us/commish/ReviewGuidance.htm. Even if an adjudicatory hearing has been requested and granted, all conditions remain in effect unless a stay has been granted. Louis Howard
6/14/2013 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73142 name: auto-generated pm edit TPA 05 STP Landfill Cell C Louis Howard

Contaminant Information

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


Control Type

Type Details
Land Use Plan / Maps / Base Master Plan Land use controls are required. As a former landfill and part of the post closure monitoring plan, a program of visual monitoring of the integrity of the cap is required.


Requirements

Description Details
Maintenance / Inspection Of Engineering Controls Municipal solid waste (MSW), lead-based paint abatement waste (including building renovation waste), demolition debris, and lead soil from other sites consolidated at this location; vegetated cap; cap consists of petroleum-contaminated soil; groundwater monitoring (potential DRO and lead contamination) until spring 2013 pending regulatory review; deed notice. post-closure cap monitoring until January 24, 2013