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Site Report: St. George TPA 06 Open Pits Site

Site Name: St. George TPA 06 Open Pits Site
Address: St. George, Saint George, AK 99591
File Number: 2643.38.012
Hazard ID: 2178
Status: Cleanup Complete - Institutional Controls
Staff: Louis Howard, 9072697552
Latitude: 56.601944
Longitude: -169.537974
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.


Originally the pits were constructed as a single pit for a precautionary spill containment area for possible spills from the Inactive/Abandoned Diesel Tank Farm (TPA-23). Served as a historical and recent disposal site for vehicles, building materials, tanks and drums. NOAA removed contaminated soil to the maximum extent practicable and no further remedial action is necessary. Covered by 1996 Pribilof Islands Environmental Restoration Agreement a.k.a. Two Party Agreement between State of Alaska and NOAA. 2 acres in size. City of St. George and The Aleut Corporation owners. ANSCA Selected property. Former ADEC project Manager was Ray Dronenburg up to April 5, 1999.

Action Information

Action Date Action Description DEC Staff
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 *Not Withdrawn, subject to Joint Use Agreement, that is, land and any improvements thereon to be available for selection by the Village Corporation, but subject to joint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. Identified as "Vehicle Boneyard" (Truck Dump) - St. George. Possible that the site may be Boneyard B TPA 15 or Boneyard C TPA 16. Sanitary Landfills and "Vehicle Boneyards" (truck dumps) which are subject to joint management may be used free of charge for their intended purposes by the non-owning party. Louis Howard
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). Pits are located south of the ocean dump site. The pit on the west side of the road occupies an approximately 200 feet by 200 feet area. The western pit contains a power shovel, dumpster, concrete, building materials, vehicles, battery, and 55 gallon drums. Eastern pit contains piping, tanks, vehicles, drums and coal. The coal is reportedly burned by some residents to heat their homes. Reportedly the pits were originally constructed as an overflow catchment for a fuel spill containment and subsequently it was used as a landfill and vehicle disposal site (NOAA 1993). Recommendation: determine if POL and CERCLA contamination exists at the site. Jennifer Roberts
11/28/1993 Update or Other Action In 1993, an inventory and bulking operation was conducted by Woodward Clyde to remove government owned drums, propane cylinders, and batteries from various locations on the island. Forty drums and six automotive batteries were inventoried and removed from the Open Pits Site. One vehicle and one abandoned crane were inspected and determined to be free of fluids. Four drums containing waste material were sampled and characterized. Chlorinated solvents and polychlorinated biphenyls (PCBs) were not detected in drum samples collected from the site and analyzed in an off site laboratory. Louis Howard
8/11/1994 Update or Other Action ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former NMFS facilities on Saint George Island. ADEC traveled with NOAA, their consultant, Tanaq Corp. and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol. NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills. NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island, the site of an underground thermonuclear detonation in the 1970s. Our law are also clear about responsibility for these materials. That responsibility remains with the Federal Government. One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability. Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable. The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. Simon Mawson
8/19/1994 Update or Other Action Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service Facility, Saint George Island response to July 20, 1994 NOV Letter. 1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS). 2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records. Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in these reports. 3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas. Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet. During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. Janice Adair
12/22/1994 Update or Other Action Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy regarding outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes. NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island. These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump. 18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. Simon Mawson
6/1/1995 Site Added to Database Dump-disposal site for vehicles, building materials, tanks and drums. Ray Dronenburg
5/3/1996 Site Ranked Using the AHRM Ranked by Shannon and Wilson. S&W
1/30/1997 Update or Other Action Hart Crowser January 1997 Expanded Site Inspection received. Surface and subsurface soil samples were taken to assess potential contamination from past practices. Based on field lab analytical results indicate exceedances of ADEC NON-UST matrix cleanup levels at this site. Recommendations were to excavate and remove soils. Contamination detected is as follows: DRO at 5,000 mg/kg at 8' and 6,800 mg/kg from a sample at 4', oil (RRO) to 2,100 mg/kg from a surface sample attributed to coal in the vicinity. Total estimated cubic yards to be excavated was 430 to 930 cubic yards. Louis Howard
5/20/1998 Update or Other Action Laura Ogar Solid Waste Program re: Expectations for Remaining Work and Regulatory Compliance for Solid Waste Projects Pribilof Islands. Of primary importance to the Department will be NOAA's assessments of the source areas (SA) to identify the extent of solid waste and any solid waste impacts at each site. Specific expectations for the SA's include: Documentation at SA's containing buried waste must include and estimation of the footprint area and depth of the waste material and include the site longitude and latitude to accurately identify the waste disposal area. Information on groundwater (depth to, gradient, etc,) must also be provided. Information must be provided on the depth to groundwater as a potential receptor for contamination if buried waste is present and/or suspected surface contamination is sufficient to warrant concerns for leaching. Where surface debris has been removed, the Site Investigation will be required to include evidence to support a conclusion that surface contamination does not exist. Any surface debris removal must be fully documented to include a description of the volumes and types of wastes removed, and identify the approved final disposal location of any wastes removed from a SA through tipping fees, shipping records, etc. Locations where buried waste will remain in the ground, solid waste landfill closure standards of 18 AAC 60 must be met. Typical landfill closure standards include the placement of final cover over the buried waste footprint to minimize infiltration and erosion. The applicable closure standards for the individual sites should be discussed with the SW Program staff prior to the development of a closure plan being developed. A closure plan must be submitted to the SW Program for review and approval prior to work being performed. Permanent markers or survey monuments must be established from which the exact location of a facility can be determined. A notation must be recorded on the deed of the property containing the waste disposal site stating that the land has been used as a landfill and future use of the land may be restricted in order to protect and maintain the final cover and any monitoring devices in place. Post closure monitoring for a period of five (5) years following the placement of final cover and landfill closure. Post closure monitoring will include but may not be limited to annual visual monitoring of the sites and required looking for signs of damage settlement or erosion. Surface and or ground water monitoring may be required if the department finds that pollution from the facility is likely to endanger public health or cause a violation of the water quality standards in 18 AAC 70. Ray Dronenburg
11/12/1998 Update or Other Action Status of Two Party Agreement Site Number 6 OU 6. Apparent recent deposits of asbestos containing building material (ACBM) found during June 3-5, 1998 site visit. Renegotiated. Phase I Final Debris Removal report due February 1999. Phase II draft work plan due March 29, 1999. Final work plan due April 26, 1999. Phase II site work will require determination of petroleum contamination extent, remediation of any PCS, confirmation sampling, analysis, site assessment and site restoration. Monthly progress report to be submitted to ADEC after project award until site closure. Flow chart attached for confirmation sampling and applicable to all TPA sites. Definition of a site assessment attached also and is applicable to all TPA sites. Site restoration is defined as one or more of the following actions dependent on each TPA site, existing site use, intended post restoration use: Recontouring, regrading, soil or scoria addition or removal, wind/water erosion control, and revegetation. Ray Dronenburg
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. Action entered by L. Howard. Jennifer Roberts
12/10/1999 Update or Other Action Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 2/15/2000. Contractor to mobilize in field in July 2000. Louis Howard
4/11/2001 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
3/3/2002 Long Term Monitoring Established NOAA will be monitoring the site for groundwater contamination. Louis Howard
8/26/2002 Cleanup Plan Approved Staff reviewed and approved the draft corrective action plan for TPA 6 as submitted. The Department’s review and concurrence on the corrective action plan for the Open Pits TPA Site no. 6 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 corrective action plan does not relieve the National Oceanic Atmospheric Administration (NOAA) or its consultants, contractors, or other personnel from the need to comply with other applicable laws and regulations. Louis Howard
9/30/2002 Update or Other Action Polarconsult removed a total of 2,149 cubic yards of petroleum contaminated soil. Recovery of contaminated soil was limited to refusal or the limits of the excavator at about 21 feet bgs. Louis Howard
2/28/2004 Update or Other Action Groundwater monitoring for gasoline range organics, diesel range organics, and volatile organic carbons at the site in 2002, 2003, and 2004 at two monitoring wells. A third monitoring well was installed at the Inactive/Abandoned Diesel Tank Farm TPA site 23. No contaminants have been detected in these wells with analyses that have achieved detection limits below the 18 AAC 75.345 Table C cleanup levels. Louis Howard
3/3/2004 Cleanup Complete Determination Issued The Alaska Department of Environmental Conservation (the Department) received the above document on February 24, 2004. Because further excavation of contaminated soil is not feasible, (e.g. due to difficulty excavating the more competent pyroclastic materials or refusal) and groundwater has not been impacted from contaminants at the site (wells TPA6-MW-1 & TPA6-MW-2), the Department concurs with the statements in the document that no further remedial action (NFRA) is necessary. Monitoring of groundwater may be required (see comments under 3.1.3 Hydrogeology). This determination by the Department is in accordance with Paragraph 59 of the Pribilof Islands Environmental Restoration Two Party Agreement at the site known as the Open Pits TPA Site 6 (contaminated sites database site name: TPA 06 STG Open Pits Site reckey no. 1994250135434). The removal of 2,149 cubic yards of petroleum contaminated soil to prevent it acting as a potential source of groundwater contamination, combined with the depth to groundwater at the site (varies from 72 to 82 feet below ground surface) and the location of the closest active city drinking water well approximately 2,473 feet from the site supports this NFRA decision. The Department is basing its decision on the most current and complete data provided by NOAA. The Department reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require NOAA to perform additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. Even though NOAA has data showing that soil remains contaminated above migration to groundwater standards, the document states that petroleum compounds have not been found in downgradient wells TPA6-MW-1 and TPA6-MW-2. However no data was presented in the document to substantiate this statement. The Department requests NOAA present at least two years of groundwater data sampling at the frequency of at least twice yearly from these wells to show that groundwater impacts have not occurred from the Open Pits site. The data may exist already in other reports, but it was not included in the document. If the data does exist, please submit it to the Department for its review or identify which document it exists in that so the Department may review it. If the data does not exist, then NOAA will be required to monitor the groundwater for a period of at least two years at the frequency of no less than twice a year. If the monitoring indicates that the contaminants were present in the groundwater above Table C values listed in 18 AAC 75.345, the Department will require additional follow-up monitoring. However, if the groundwater results show that Table C values were not exceeded, the Department will allow NOAA to discontinue the monitoring since it is not necessary to ensure protection of human health, safety, and welfare, and of the environment. 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. For additional information see site file. Louis Howard
3/3/2004 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 Open Pits Site TPA 6, 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
2/7/2005 Update or Other Action Letter Report and Conditional Closure Request Public Health Service Project Soil Pile/non-TPA Site 34 St. George Island, Alaska sent by NOAA to ADEC. This letter report provides a summary of confirmation sampling and analysis of soils excavated during an upgrade to the City of St. George, Alaska sewer system (ca. 1986). These soils were presumably piled at a location currently referred to as National Oceanic and Atmospheric Administration (NOAA) non-Two Party Agreement (TPA) Site 34 or Site 34 (56° 36’ 6.01” N, 169° 32’ 18.76” W). Included herein are a summary of sampling activities, maps and photographs of the sampling location, and fixed-laboratory sample results. Based on the data and information presented, NOAA is requesting a conditional closure determination from the Alaska Department of Environmental Conservation (ADEC) for this site. The U.S. Department of Health and Human Services, Public Health Service (PHS) and the City of St. George, under a work order with the PHS, conducted the City of St. George sewer upgrade. The City and the PHS encountered suspected petroleum-contaminated soils (PCS) while upgrading the sewer system. Workers subsequently removed these soils, placing them in a pile at Site 34. This site is located in Tract 52 of Township 41 south, Range 129 west, Section 29 of the Seward Meridian, Alaska, as shown on the plat of rectangular net survey, officially filed February 15, 1985, adjacent to TPA Site 6, also known as Site 6 and the Open Pit Site. The Tanaq Corporation owns the surface estate and The Aleut Corporation owns the subsurface estate of Site 34. NOAA applied ADEC Method Two cleanup criteria, discussed at 18 AAC 75.341(c) (ADEC 2003). For benzene, under the TPA (NOAA 19965), NOAA had the option to cleanup to the less stringent State of Alaska cleanup level of 0.5 mg/kg in effect in 1991 (ADEC 1991). Validated fixed-laboratory results indicated that no analytes exceeded their site cleanup levels. Accordingly, NOAA does not plan to conduct a remedial action at this site. In accordance with paragraph 59 of the TPA, NOAA requests written confirmation that NOAA completed all appropriate action at the PHS project soil pile, NOAA non-TPA Site 34/Site 34 in accordance with the Agreement and that ADEC grant a conditional closure not requiring further action from NOAA. NOAA understands ADEC will/may require additional containment, investigation, or cleanup if subsequent information indicates a level of contamination at the site that does not protect human health, safety, or welfare, or the environment. Louis Howard
2/11/2005 Update or Other Action Letter from ADEC to NOAA RE: Public Health Service Project Site 34, St. George Island, Alaska February 2005. The Alaska Department of Environmental Conservation (the Department) received the above document for review and comment. The Department has reviewed the data and concurs that no additional investigation is needed at the Public Health Service Project Soil Pilefnon-TPA Site 34. The Department reserves all of its rights, under A.S. 46.03 and 18 AAC 75 to require NOAA to conduct additional site assessment, monitoring, remediation, and/or other necessary actions at Site 34 if information becomes available that contamination is found at this site which is poses an unacceptable risk to human health or safety, welfare, or the environment. Louis Howard
8/8/2005 Update or Other Action Formal Request for conditional closure. Open Pits Site, also known as Two-Party Agreement (TPA) Site 6/National Oceanic and Atmospheric Administration (NOAA) Site 6. TPA Site 6 is located within Tract 52, in Section 29, Township 41 South, Range 129 West of the Seward Meridian, Alaska, from a Bureau of Land Management land survey filed February 15, 1985 (Figure 2). It is centered at Latitude 56° 36’ 065” North, Longitude 169° 32’ 18” West. The Aleut Corporation owns the subsurface estate. The surface estate is owned by the City of St. George. Southeast Subsite: Polarconsult’s excavation in the vicinity of TP-6 identified visibly contaminated soil exhibiting a strong diesel odor (Figure 5). Polarconsult evaluated soil on-site with a photoionization detector (PID) in an effort to estimate if the soil exceeded the site cleanup levels. Recovery of contaminated soil continued downward and outward until soil exceeding the cleanup levels was no longer evident, as determined by field screening. A total volume of 22 yd3 of PCS was removed. Crane Subsite: Polarconsults’s excavation in the former area of the wrecked crane identified visibly contaminated soil with a strong diesel odor (Figure 6). Polarconsult continued recovery of PCS downward and outward until soil exceeding the cleanup levels was no longer evident, as determined by field screening, or until refusal occurred in competent red scoria at a depth of 5 feet bgs. Polarconsult observed that contamination continued vertically downward into the competent red scoria, but it could not be removed with the available equipment. After completing the removal of PCS, one confirmation sample exceeded the current Method Two cleanup level for Diesel, and one exceeded the current Method Two cleanup level for benzene, but this second sample did not exceed the 1991 Method Two benzene cleanup level used for the site. A total volume of 132 yd3 of contaminated soil was removed. Coal Subsite: Polarconsult’s initial recovery activities at the Coal Subsite involved the removal and segregation of loose anthracitic coal. The coal was transported to the Longterm PCS Stockpile and placed in a separate location from petroleum-contaminated soil. Polarconsult began excavating in the area around TP-8 suspected to be contaminated with petroleum as reported by Hart Crowser, 1997 (Figure 7). However, Polarconsult did not find elevated levels of contamination, and refusal was encountered at 2 feet bgs instead of 8 feet bgs as expected. These discrepancies probably resulted from difficulties in relocating the TP-8 site. In an effort to find the known contaminated soil, Polarconsult excavated a new series of test pits. Polarconsult encountered visibly contaminated soil exhibiting a strong diesel odor northwest of the location originally believed to be TP-8. Observation indicated that the petroleum contamination continued downward into the competent basalt where it could not be removed with the available equipment. In the softer scoria, excavation was continued beyond the planned stopping depth of 15 feet bgs in an effort to reach the deepest extent of contamination. Recovery of contaminated soil continued vertically and horizontally until soil exceeding the cleanup levels was no longer evident as determined by field screening, until refusal occurred, or until the excavation extended beyond the limit of the excavator at about 21 feet bgs (Figure 7). Refusal occurred in competent basalt at several locations. A total volume of 1,995 yd3of contaminated soil was removed. In accordance with paragraph 59 of the TPA (NOAA 1996), NOAA requests written confirmation that NOAA completed all appropriate corrective action to the maximum extent practicable at the Open Pits Site, TPA Site 6, NOAA Site 6, St. George Island, Alaska. NOAA requests ADEC grant a conditional closure that will not require further remedial action from NOAA. NOAA understands ADEC will require additional containment, investigation, or cleanup if subsequent information indicates that the level of residual contamination does not protect human health, safety, or welfare, or the environment. Louis Howard
8/11/2008 Update or Other Action Notice of residual soil contamination at Two Party Agreement site no. 6. Pursuant to 18 AAC 75.375, the City of St. George (the City) as the owner, and the U.S. Department of Commerce National Oceanic and Atmospheric Administration (NOAA), as the operator, hereby provide public notice that property located east of the City on St. George Island, Alaska, 99591 is contaminated with petroleum products. More specifically, the property is described as follows: Lot 42, Tract 52 Section 29, Township 41 South, Range 129 West, ofthe Seward Meridian, Alaska. 56 degrees 36' 6.94" North Latitude, 169 degrees 32' 16.14" West Longitude This property, hereafter referred to as Site 6 (Figures 1 and 2), has been subject to debris and petroleum contaminated soil from a discharge, or release and subsequent cleanup of oil or other hazardous substances, regulated under 18 AAC 75, Article 3 as amended December 2006 and solid waste disposal, which is regulated under 18 AAC 60 as amended August 2003. Adequate soil cover needs to be maintained over the residual petroleum contaminated soil. If contaminated soil is exposed in the future, it must be managed in accordance with laws applicable at that time. ADEC determined, in accordance with 18 AAC 75.325(f)(1), that site cleanup has been perfonned to the maximum extent practicable even though residual petroleum contaminated soil remained on the property (NOAA 2005a). ADEC granted a conditional closure, in part subject to this institutional control (deed notice), and confirmed that no further corrective action was required at the site unless new infonnation becomes available that indicates to ADEC that the site may pose an unacceptable risk to human health, safety, welfare or the environment (NOAA 2005a). Grantor:St. George Tanaq Corporation 4141 B Street, Suite 301 Anchorage, AK 99503 Grantee: City of St. George PO Box 929 St. George, AK 99591 Recording District: Aleutian Islands In the event that information becomes available which indicates that Site 6 may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator is required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations. Further site characterization and cleanup may be necessary under 18 AAC 75.32S-.390 and 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil from the site requires notification to and approval from the Department in accordance with AAC 7S.370(b) and 18 AAC 78.600(h). This notice remains in effect until a written determination from ADEC is recorded that states that soil at the site has been shown to meet the most stringent soil cleanup levels in Method Two of 18 AAC 75 .341 (c) and that off-site transportation of soil is not a concern. Louis Howard
9/20/2008 Update or Other Action The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Pribilof Project Office is responsible for site characterization and restoration on St. George Island, Alaska. Although NOAA has attempted to meet State of Alaska soil cleanup levels and has removed contaminated soil to the maximum extent practicable, residual contamination remains at some St. George Island sites. This report documents the nature of known or potential residual soil and groundwater contamination at NOAA-remediated sites and presents the rationale for leaving the contamination in place. Of thirty-six (36) sites investigated and/or restored by NOAA at St. George Island, the following contaminants are known to remain or potentially may be present in soil and/or groundwater above applicable site cleanup levels: • DRO at 20 sites. • GRO at 5 sites. • RRO at 3 sites. • Benzene at 4 sites. • Toluene at 3 sites. • Ethylbenzene at 4 sites. • Total xylenes at 4 sites. • Perchloroethylene at 2 sites. • Lead at 2 sites. Contaminated soil may have been left in place at sites due to equipment limitations and/or the presence of utility lines, buildings, roads, and other structures. Additionally, NOAA was not obligated to excavate contaminated soil to address the inhalation and ingestion pathways fifteen (15) feet or greater below the ground surface, or at shallower depths when encountering the water table. Buried debris, such as municipal solid waste, also remains at some sites. In such locations, NOAA placed a soil cap over the debris according to State of Alaska requirements. During 2006, NOAA initiated a long-term groundwater monitoring plan at St. George Island to monitor the migration and attenuation of groundwater contamination at NOAA Sites 35 and 36 and to gauge the effectiveness of soil remediation actions at NOAA Sites 1, 2, 3, 8 and 29. Other than acknowledging the presence of groundwater contamination at a site, groundwater is not addressed within the context of this report. Site 6 is the location of a former quarry that was used for the disposal of solid waste which included domestic trash, coal, building material, pipe, tires, scrap metal drums, batteries, derelict equipment and fuel storage tanks. Cleanup activities in 1993 (Woodward-Clyde 1994) and in 1997 (PolarConsult 1997) resulted in the removal of the solid waste. A site assessment conducted in 1996 identified areas in Site 6 where soil was contaminated with DRO in concentrations above the Method Two criterion for migration to groundwater (Hart Crowser 1997). In 2002, approximately 2,149 yd3 of DRO contaminated soil was removed from three sub-sites within Site 6: Southeast, Crane, and Coal. Contaminated soil was removed to the extent practicable; however, DRO contaminated soil remains beyond fifteen feet bgs at the coal sub-site, and at refusal depth at the crane and coal sub-sites (PolarConsult 2004a). In 2002, NOAA installed two groundwater monitoring wells down-gradient of Site 6. Groundwater samples collected from these wells from 2002 through 2004 had analytical results indicating all contaminants were either non-detect or detected at concentrations below ADEC cleanup criteria (Tetra Tech 2005a). Based on a determination that groundwater in the vicinity of Site 6 had not been adversely impacted, these monitoring wells were decommissioned in 2005 and removed in 2006 in accordance with an ADEC approved long-term groundwater monitoring plan (NOAA 2005a). Louis Howard
9/26/2008 Update or Other Action Summary of Residual Soil Contamination and Buried Solid Wastes at NOAA Cleanup Sites on St. George Island. NOAA Site No. 6/TPA Site No. 6, Open Pits Site: drums, surface debris, solid waste, contaminated soil. Site Conditions as of August 6, 2008: DRO contaminated soil remains beyond 15 feet bgs at the coal subsite, and at refusal depth at the crane and coal subsites. Deed notice Site status as of September 26, 2008: NFRAP 08/08/2005 Propery Owners: City of St. George. ALSO includes NOAA Site No. 34/NTPA Public Health Service PCS-Open Pits Site: Contaminated soil. Clean Closure. Site status as of September 26, 2008: NFRAP 02/11/2005 Propery Owners: City of St. George/TAC. Louis Howard
6/14/2013 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73156 name: auto-generated pm edit TPA 06 STG Open Pits Site Louis Howard

Contaminant Information

Name Level Description Media Comments
DRO Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil DRO contaminated soil remains beyond 15 feet bgs at the coal subsite and at refusal depth at the crane and coal subsites.

Control Type

Type Details
Land Use Plan / Maps / Base Master Plan Location of contaminated soil is noted and mapped.
Notice of Environmental Contamination (Deed Notice) Notice of Residual Soil Contamination 2008-000389-0 Recording Dist: 305 8/11/2005. Pursuant to 18 AAC 75.375, the City of St. George (the City) as the owner, and the U.S. Department of Commerce/National Oceanic and Atmospheric Administration, as the operator, hereby provide public notice that property located east of the City on St. George Island, Alaska, 99591 is contaminated with petroleum products. More specifically, the property is described as follows: Lot 42, Tract 52 Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska. 56 degrees 36' 6.94" North Latitude, 169 degrees 32' 16.14" West Longitude


Description Details
Advance approval required to transport soil or groundwater off-site. In the event that the remaining contaminated soil becomes accessible by the removal of the soil located in the vicinity of the Open Pits Site TPA 6, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. As required when soil is proposed to be moved from site.
Excavation / Soil Movement Restrictions Any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i). As required when soil is proposed to be moved from site.

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