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Site Report: St. George TPA 04 Former Active Landfill


Site Name: St. George TPA 04 Former Active Landfill
Address: Saint George, Saint George, AK 99591
File Number: 2643.38.010
Hazard ID: 2187
Status: Cleanup Complete - Institutional Controls
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 56.589151
Longitude: -169.595426
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

Approximately 120 drums were found above ground leaking and soil staining is evident. Old landfill has been closed out and subsequently has been transferred from NOAA to the City of St. George. Covered by 1996 Pribilof Islands Environmental Restoration Agreement a.k.a. Two Party Agreement between State of Alaska and NOAA. City of St. George land owner. Formerly the Active landfill which is now the Old Landfill. New landfill constructed to replace old landfill. City of St. George Active Landfill Permit 0325-BA002 received 4/22/2003 issued 11/15/2004 expires 11/15/2009 NOAA Landfill expired (1/30/1988) permit# 8521-BA020 received 9/18/85 issued on 1/26/86 SITEID 6654 Class 3 (village) landfill. 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 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. 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: "Vehicle Boneyard" (Truck Dump)-St. George Sanitary Landfills and "Vehicle Boneyards" (truck dumps) which are subject to joint management may be used free of charge for their intended purposes by the nonowning party. * Land and any improvements thereon to be retained in fee simple by the Federal Government as in **subparagraph (b)(1) above, but subject to joint management by the Pribilof Islands Joint Management Board pursuant to the agreement creating said Board. **Section (b)(1) "Government Withdrawal" states: land and any improvements thereon to be retained in fee simple by the Federal Government as the smallest practicable tract enclosing land actually used in connection with the administration of a Federal installation, within the meaning of 3(e)(1) of the Alaska Native Claims Settlement Act, 43 USC 1602(e)(1); such property not presently considered by the parties to be subject to joint management by the Pribilof Islands Joint Management Board. Louis Howard
9/13/1985 Update or Other Action Contract for disposal by Chase Construction. Section 5 PROPOSED DISPOSAL SITE FOR 5T. GEORGE ISLAND: The location recommended for a debris disposal site on St. George Island is at the existing landfill. The site is on a gentle slope within 1/2 mile of the DOD barrel dump and is controlled by the federal government (NOAA). The site is expected to be conveyed to the City of St. George by late 1985. The Tanaq Corporation, owner of most of the St. George Island lands, is not interested in development of an additional disposal site in addition to the one already in use on the island. The site is located about 1/4 mile east of the midpoint of the road connecting St. George village with Zapadni Bay. Drainage is generally to the north. The soil type appears to be principally pyroclastic volcanic deposits overlying basalt bedrock at unknown depth. Mineral soil is covered by a 6" thick organic mat supporting typical tundra plant types. The lack of evidence of surface runoff suggests that the area has good drainage. Adequate fill to cover cleaned-up debris sites and the landfill area appears to be readily obtainable from active borrow sites adjacent to the landfill, provided owner permission is obtained, proper permits are secured, and approval by the Contracting Officer is obtained. 6. SUMMARY OF WORK AND BASIC PROJECT INTENT: The intent of this project is to remove and dispose of all materials from the sites in an environmentally sound manner, thereby avoiding damage to the tundra, and to restore the area to a close approximation of its natural condition. This includes revegetation of areas disturbed by contract activities and cleanup of spills from the existing drums. 6.1 As evidenced from previous site inspection, most of the drums have rusted through and spilled their contents onto the tundra.. The Contractor is to assume that they are not suitable for transport of the petroleum, oils and lubricants (POL• materials). Most of the drums are either empty or partially filled with water which has entered through holes created by rust, damage, or absence of a bung. A small percentage of the barrels may have residual POL materials or other fluids. Use of an O/W separator is encouraged to reduce the volume of material to be disposed of since the POL is in some barrels may have been diluted by precipitation entering through holes. Therefore, the POL materials shall be bulked in Federal Dept. of Transportation (DOT) approved containers prior to transport in order to assure that the contents do not spill or leak. The Contractor shall have a hazardous-waste disposal person who is certified by EPA for on-site bulking operations. This person shall be on site during bulking operations. He shall identify the contents of non-empty barrels prior to handling by the work. crew and sample and analyze fluids and soils as necessary to determine proper handling procedures. He shall ascertain the degree of tundra and soil contamination of barrel cleanup sites. It is anticipated that the Contractor will crush the emptied drums prior to transport to a local disposal site; however, prior to crushing he will be required to assure that there is no significant POL residue in the drums. A drum is considered empty if there is less than 1 in. of material at the bottom of the drum (EPA definition). The methods of residuals removal shall not in any way create an environmental hazard or problem. POL materials must be positively identified prior to consolidation for recycling or burning, pending ADEC burn permit. If the Contractor opts not to crush the drums, he will be responsible for removal of drums from the Pribilof Islands for disposal in approved disposal site. The Contractor shall be aware that there is a potential hazard of some products other than POL, such as solvents, and shall be prepared to handle these products with appropriate equipment and protective devices and clothing for all personnel. Suspect fluids should not be mixed or burned. The Contractor will set up a barrel content identification station adjacent to barrel crushing operations for the purpose of identifying and emptying the contents of barrels prior to crushing. The station must have an impermeable base and sides to prevent leakage of barrel contents into the surrounding environment. Material recovered from these barrels must be disposed of in accordance with procedures set forth in Section 02050, DEMOLITION, Pg. DG-l. 6.2 Most of the barrels have ruptured, and may have leaked onto the tundra or underlying soil. The Contractor will be responsible for cleanup of only hazardous spills and for disposing of wasted oil in a manner that is acceptable. to the Environmental Protection Agency (EPA), the ADEC and the Contracting Officer. The Contractor is cautioned that this project is an "Environmental Cleanup Operation" and will receive thorough scrutiny from regulatory agencies. (Ref. 01060-7.1) For additional information see site file. Louis Howard
1/10/1986 Update or Other Action Receipt of Serial Letter CLO1, dated December 6, 1985 is acknowledged. It is agreed that the general intent or the contract is to dispose of DOD wastes. However, there may be be some non-DOD waste in the sites designated. This material should also bo disposed of. Major items, or large quantities of non-DOD waste near the designated cleanup sites are not to be disposed of as part of the requirements of this contract.· The tractor and barrels on St. George Island, belonging to the U.S. Department of Commerce, which you reference in your letter, are not within the limits of a designated cleanup site, and are not to be removed. John R. Nelson Cpt. COE, Alternate Resident Contracting Officer. Louis Howard
4/3/1986 Update or Other Action Letter to CHASE Construction from CORPS. SUBJECT: Operation And Testing Plan, Contract DACA85-86-C-0003, Debris Cleanup and Site Restoration, St. Paul/St. George Island, Alaska. Your: Operation Plan with the Testing and Samping Addendum has been reviewed by this office. The following items need to be addressed before your plan can be accepted. Operation Plan 1. a. You still need to provide supportive data to show that Mr. Benson is qualified to be appointed as the hazardous waste disposal person, asstated in Serial Letter RRO/lO. 1. b. You ehould include what types of POL products you expect to find, state which ones will be batched and which ones will not. Also a diagram or explanation describing the steps that will be taken to determine that wastes are compatible should be included. General. You must include a description of how you plan to remove residue from the barrels prior to crushing. If you plan to use some of the recovered POL products for flaring, the requirements of Technical Speclfication 02050, Paragraph 1.2 must be complied with. Site B-1 You need to address the proposed cleanup method for the sludge pond. Testing and Sampling Addendum Except for the cover letter from Pittsburgh Testing Laboratory, your submitted plan is basically a guide explaining how a testing plan should be created. Page 1-7 outlines the type of items that need to be included in your testing plan. Special emphasis should be given comments three through seven. You are required to provide the sampling procedure and test for ALL materials which are regulated under the Resource Conservation and Recovery Act (RCRA), Toxic Substance Control Act (TSCA), and any other applicable state and federal regulations that deal with hazardous and/or toxic wastes) unless adequate rational is provided for restricting the testing parameters. Your composite environmental sampling methodology is acceptable, but you must address how you will deal with possible concentrated, highly contaminated areas within the large contaminated soil area. For your "hazardous or concentrated" samples you must provide the list of items that you will test for and the specific analytical method that will be used for each item. Use of a caliwasa is not recommended because of the difficulty and time required to decontaminate the apparatus after each sampling. Your Operation and Testing Plan must be resubmitted. Until it is approved, you may not begln any bulking operations on St. Paul Island. A1so, you are reminded, you must provide an acceptable disposal plan for the contaminated materials as part of your Operation Plan. This may be provided once all testing and bulking is completed, but must be prior to disposal of any of the material. If there are any questions concerning these requirements, please contact 1LT Woodard at 863-3101. Jack A. Vellinga Resident Contracting Officer. Bill Lamoreaux
6/10/1986 Update or Other Action Letter to CHASE Construction from John R. Nelson Cpt. COE Alternate Resident Contracting Officer. Reference your Seria1 Letter CL-13 dated May 27, 1986. Laucks Testing Lab is hereby accepted for use on this contract, contingent upon successful performance in the field. The use of Rocky Mountain Analytical lab as your Quality Assurance Lab is Acknowledged. 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. Louis Howard
9/9/1987 Update or Other Action Letter to Chase Construction from Roy S. Carlson Jr. Lt. Col COE Contracting Officer. I have been advised by the Richardson Resident Engineer that your firm completed all work required under contract DACA85-86-C-0003, Debris Cleanup & Site Restoration. St. Paul & St. George Islands. Alaska on June 24, 1987 and it is hereby accepted. This acceptance does not relieve you of other contractual requirements, which include the Warranty of Construction. Your compliance with the safety regulations of this contract has been satisfactory, and your cooperation with the Corps of Engineers in the Accident Prevention Program is appreciated. Your final pay hai-been processed. Louis Howard
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 meet 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. Ray Dronenburg
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
11/2/1994 Update or Other Action CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. Environmental Protection Agency (EPA) Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. Department of Commerce (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
11/15/1994 Update or Other Action (Old R:Base Action Code = RECN - Site Reconnaissance (CS)). Ray Dronenburg
12/19/1994 Update or Other Action Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy-Re: outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes. NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island. These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump. 18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. Simon Mawson
3/15/1995 Update or Other Action Letter from City of Saint George to R. Dronenburg regarding Saint George Landfill Permit. Request assistance from Ray in preparing applications for permits to bring Saint George Landfill to current standards. New Refuse Tariff became effective on February 1, 1995 to gain control of the operations. Terminated haul your own option and replaced it with the City collection only because past practices resulted in poor management and lack of monitoring. New policy allows City to separate types of wastes and assure proper disposal thus reducing potential health hazards to drinking water and heading off potential infestation. Ray Dronenburg
3/30/1995 Update or Other Action Woodward-Clyde Phase 1B Environmental Assessment a.k.a. Expanded site (inspection) investigation received which was to identify the nature and extent of soil and groundwater contamination. The data obtained from the site inspection were used to determine which areas have contaminated media and need further investigation. TPH was detected in concentrations ranging from 690 to 3,100 mg/kg and DRO up to 1,700 mg/kg. Sample SGD94S013L at 2' below ground surface had DRO at 3,700 mg/kg. The sample results indicate that a localized surface spill occurred and there are many oil surface stains that have been noted during previous inspections at this landfill. The stains have the appearance of discarded used waste oil. Recommendations include a NFA request with the possibility of installing groundwater monitoring wells as required by a closure of the landfill (18 AAC 60.410) to measure any existing or future impact from contaminated leachate from the landfill. One sample of sediment from sample SGD94D001L detected PCBs at 0.31 mg/kg. Ray Dronenburg
4/1/1995 Update or Other Action City of Saint George letter to Commissioner Gene Burden regarding Saint George Landfill Funding. Currently NOAA's general counsel's office opinion states closure of the Saint George landfill is no way their responsibility. City disagrees. 1. NOAA created the landfill without a State permit and operated it without a State permit. Under the terms of the Fur Seal Act amendments of 1983 and the Transfer of Property Agreement of 1984, the City was told by NOAA it had to accept title to the property. The City acquiesced, knowing that the facility was no different than any other NOAA facility transferred to the City in that it failed to comply with federal and state safety and health and environmental regulations. The City had no alternative: Congress shutdown fur sealing and did not ask the residents their opinion on how transfer to a new economy was to be accomplished. The City took title to the landfill under duress and performed its public responsibility to operate the landfill since the 1980s. The landfill is out of compliance with State regulations. (Note: the City has made every effort to move toward full compliance, in spite of City budgetary limitations). 2. NOAA is proposing to avoid using the Landfill altogether. Currently, NOAA is requesting bids for removal of PCB filled transformers on the School Yard site and previously collected drums which have been stored since the summer of 1994. Due to its legal stance, the agency requires these items be removed, NOAA personnel have continued to use the landfill to the present day. 4. Yet NOAA indicates it must remove all NOAA waste from the environmental cleanup project from the Island via expensive off-Island disposal methods. Why? NOAA claims it is prohibited from contributing to a non-complying landfill. Then why do they continue to use the landfill for operations? Is this consistent? As you review the things that must go into the Compliance Agreement (between the State and NOAA), the City requests you consider these questions: Is NOAA going to be forced or convinced to participate in closure of its former landfill? If not, the City will be forced to rely on the State of Alaska to pay for it. The City simply doesn't have the money. B. Will NOAA be allowed to use precious federal cleanup funds to pay a surcharge for removing waste to a distant disposal location in Seattle? C. Would it be more appropriate under the spirit of the regulations (State and Federal) to use the NOAA waste export funds to achieve a permanent solution which NOAA itself can use for its Island operations in the future? D. Why is Saint George different than Saint Paul? NOAA is paying the entire closure bill for the current city of Saint Paul Landfill. E. Why did NOAA request 10,000,000 dollars for the Pribilof Island environmental cleanup if the agency intends to continue to refuse to take responsibility for its present and former facilities? There are differences of opinion with NOAA on the agency's General Counsel's position. It is clear that NOAA is posturing itself to be free from internal criticism and awaiting the Department of Environmental Conservation insistence on taking these responsibilities. Signed Richard Wilson City Administrator. Ray Dronenburg
6/1/1995 Site Added to Database Leaking drums and soil staining. Ray Dronenburg
6/8/1995 Update or Other Action City of Saint George letter to Dronenburg regarding transformer removal. June 6, 1995 employees of Philip Environmental completed removal of the abandoned transformers from the Saint George Elementary Schoolyard. Samples of the transformer contents were taken from each transformer for lab analysis before they were placed in over-pack containers for shipment. Although samples were taken from each transformer, and a "complimentary" field soil sample test was performed, Alvin Merculief Public works director, feels that a few soil samples should have been collected from the affected site, and sent to a lab for in depth analysis. The second soil sample test revealed PCBs were present in the soil directly beneath the wooden foundation. Furthermore, the wooden enclosure that the transformers were in should be considered contaminated, and properly disposed of at a hazardous waste disposal facility. NOAA officials are aware of the wooden foundation, as Richard Wilson and I brought that to their attention several months ago in one of our many teleconferences with them. We even discussed methods of how the wooden foundation would be destroyed and placed in over-pack drums for proper disposal. I hope this doesn't result in another "NFA required" statistic under NOAA and the contaminated transformer enclosure improperly disposed of at our unpermitted landfill. Ray Dronenburg
6/9/1995 Update or Other Action Letter from NOAA to clarify that the Dexsil Chlor-in-Soil tests came up negative for PCB levels over 50 ppm. Indicators are purple negative (less than 50 ppm) and yellow positive (over 50 ppm). Shades of purple do not indicate there is anything other than less than 50 ppm of PCBs could be present. More testing is needed of the soils for confirmation by laboratory analysis vs. screening kit. Ray Dronenburg
6/15/1995 Update or Other Action (Old R:Base Action Code = RARR - Remedial Action Report Review (CS)). Reviewed closure plan. Ray Dronenburg
6/26/1995 Update or Other Action Ray Dronenburg received letter from the City of Saint George City Administrator-re: Solid Waste Landfill Permit. The city is applying for a solid waste landfill permit to dispose of the clean and crushed drums which will be removed from the School Yard site restoration program as documented in Hart Crowser's Final Work Plan (1995). The letter is submitted in accordance with Ray Dronenburg's request and was prepared as a result of Dronenburg's conversation with Hal Marlow (Hart Crowser). The drums will be excavated, handled, cleaned, and crushed in accordance with the work plan. The City proposes to dispose of the drums on city property located on Tract 38B (Section 36, T41S, R13 W, Seward Meridian) adjacent to the municipal landfill (figure 1). The area available for disposal is approximately 14,400 square feet. The city proposes to haul the drums to the disposal location for staging and temporary storage. After the school yard restoration is complete, or nearly so, they will obtain an accurate estimate of the volume of material to be disposed of. A trench will be excavated in the proposed solid waste disposal area. Clean and crushed drums will be placed in the trench and compacted with the bulldozer. After all of the drums have been placed and compacted, a three foot cover of soil will be placed over the solid waste in the excavation and the surface will be graded for drainage. Ray Dronenburg
6/28/1995 Update or Other Action Letter from City of Saint George to NOAA for release and indemnity agreement. NOAA provided the funds for the removal of the drums. NOAA hereby authorizes the City of Saint George to dispose of the drums removed from the School Yard removal to be buried in the City's Landfill upon the approval by the ADEC of such disposal. In consideration of the approval by NOAA set out in paragraph 1, the City hereby waives any right it may have now or in the future to indemnity, defense or payment by NOAA of any demand, suit, or other claim arising out of the burial, presence or contents of said drums in the City's Landfill. Furthermore, the City hereby agrees to save, hold harmless, defend and indemnify NOAA for and from any demands, suits or other claims arising out of the burial, presence or contents of said drums in the City's landfill. Signed by the City of Saint George City Administrator Richard Wilson for the Mayor of Saint George. Ray Dronenburg
7/12/1995 Update or Other Action Letter from Ray Dronenburg to City Administrator Richard Wilson regarding Solid Waste Permit and Disposal of Crushed drums. Permitting process will take time and effort and must have certain documentation from the City of Saint George regarding boundaries, soils type, etc. Additionally, your permit request will need to be posted to allow for public comment. Ray thought that they should also consider that probably, because of the permeability of soils found in the landfill, the potential for liner or materials to create an impermeable barrier will be required. Serious consideration should also be given to incineration, given the serious consequences, should contamination reach Saint George's aquifer. As for the drums, Ray has visited the landfill many times, and is familiar with the drums that are to be buried and aware that Hart Crowser will be certifying the drums as "clean" for burial. Recognizing that this effort will pose no health risk, ADEC approves the plan for permanent burial of the drums. It is ADEC's understanding that the drums, as removed, are the property of NOAA, it is requested that the City of Saint George provide this office with a document which transfers liability for the drums from NOAA to the City of Saint George and which certifies to hold NOAA harmless for their burial on Island. Also, please provide the exact location of burial, as accurate as possible and the number of drums buried, upon completion of the project. Ray Dronenburg
8/15/1995 Update or Other Action Saint George Landfill leachate determined by sampling, however, data not yet provided. Louis Howard
8/30/1995 Update or Other Action Letter from Simon Mawson to Rich Wilson regarding development of a new landfill for Saint George with the opening of the borrow pit by the BIA contractor doing road work on the island. Simon stressed that the landfill is part of a system for solid waste management. Need to identify the waste streams, how much is being produced, who produces it, evaluate the alternatives for reducing, reusing and recycling wastes and then disposing of what's left. Next figure out the capital costs and the operation and maintenance costs of the solid waste management system and who is going to pay for them. Lastly, need some ordinances that regulate and charge producers of solid waste. Simon Mawson
5/6/1996 Site Ranked Using the AHRM Ranked by Shannon and Wilson. S&W
4/15/1997 Meeting or Teleconference Held Pribilof Restoration Advisory Board Meeting held in Anchorage. Saint George Landfill Closure Project (city of Saint George). It was noted that the proposal is currently being negotiated. NOAA is currently awaiting response to comments and/or a revised application package. Max Malavansky noted that a resubmission of the proposal would be received by the end of April 1997. Due to the concerns regarding groundwater contamination a recommendation was made for the inclusion of monitoring wells for this project. Ray Dronenburg
5/8/1997 Update or Other Action ADEC Laura Ogar Solid Waste Program provided a memorandum letter to Saint George Mayor Max Malavansky, John Alder city administrator, Chuck Eggener City Engineer, Mary Goetz NOAA, Ray Dronenburg ADEC and Lynne Balogh ADEC regarding response to faxed discussion items for teleconference on 5/9/97 regarding Saint George Landfills. Laura concurs that several months ago Chuck Eggener provided her with conceptual drawings of the capping scenario for closure and site plan for the landfill. In several conversations since then, she has stated to Max and Chuck that from a conceptual basis the plans look fine. Departmental approval is only given after a review of permit applications or closure plans not on draft plans or conceptual drawings. Site selection is a local decision which ADEC does not approve or disapprove. The City is awaiting ADEC approval on several of the basic issues which is affecting continued work on the projects. ADEC does not understand this statement, but encourages the City to submit a final closure plan and permit application for review and approval if you wish to keep the projects moving forward. Dump Closure: ADEC has provided Mr. Eggener with regulatory citation which references the specific requirements for closure, 18 AAC 60.390 and Laura has provided copies of the Solid Waste Regulations 18 AAC 60 on at least two different occasions. The final cover at a rural community landfill must be soil at least 24 inches thick, graded to promote drainage without erosion, and must be revegetated or otherwise treated in a manner appropriate for the long-term use of the facility. Mr. Eggener has asked several times if the scoria material native to the community is sufficient as cover since it is porous. Please not that no specification is made as to the classification or permeability of the soil cover. Certainly the purpose of the cover material is to reduce infiltration and percolation through the waste, so the more impermeable the final cover the better. The regulations provide the regulatory minimums and if the City Engineer does not believe they are sufficient for the community or the City wishes to do an alternative closure design, they are not prohibited from doing this. (Appears that Laura is also stating that the scoria material is sufficient to be used for cover material if the City Engineer believes it sufficient for the community). If fact, the regulations allow the department to approve alternatives if you present them for ADEC review. Chuck Eggener asked Laura several times if monitoring wells are required. Laura Ogar has stated for the closure of this landfill it is not required. Mr. Eggener has said that the site cannot be revegetated. ADEC only asks for the best practical attempt at revegetating the site similarly to the undisturbed areas adjacent to it. Laura suggests crushing the scoria for a more silty type material if possible before seeding, or land applying lime treated sludge, or perhaps burlap matting with grass seed, etc. If the site is to be used as a vehicle storage area as Mayor Max Malavansky has suggested in the past, then revegetation may not be necessary or required for this specific type of future use as a parking site. For additional information see site file. Louis Howard
6/19/1997 Update or Other Action Application for Cooperative agreement, bid/offer/application initial filing sent by City of Saint George to NOAA by Max Malavansky. Saint George Landfill closure estimated to cost $1, 738,358.00 Costs include: 1) purchase and mobilization of good used construction equipment (D-6 dozer, Cat 966 loader, 3 10/12 cubic yard end dump trucks) ($566,200) 2) Consolidation, shaping, compacting, contouring of the refuse in the dump ($53,880). 3) placement of 40,000 cubic yards of locally available cover material for minimum of two feet of cover over a seven acre dump site at 1.50/cubic yard. Cover to be graded to drain ($524,800). 4) Establishment of vegetative cover on closed out dump ($92,000). 5) Installing four monitoring wells ($56,250 ea.) 6) Staking, layout, inspection and construction engineering ($46,650). Access Control 1) Fencing $34,250 (includes gates for monitoring well access roads) 2) Signs and Traffic Channelization devices ($9,250) 3) Powerline Extension ($24,650) 4) Construction Engineering ($15,000) (Procure building, stake and layout fence and utility trenches, document construction) for subtotal of $83,150 Reporting Final Close-out 1) Collect one sample from 4 monitoring wells and forward to lab for analyses ($5,850) 2) Lab analyses (assumes $3,000 per sample) $12,000 3) Complete and file report $4,650 4) Prepare "Final" close-out report $6,200 subtotal $28,700 Ray Dronenburg
6/23/1997 Update or Other Action ADEC Laura Ogar comments on the Solid Waste Permit application-ADEC determination of incomplete application. 1. Information on the cover letter on waste volumes is incomplete. Population numbers presented identify year round residents only and do no reflect high seasonal population, commercial processing industry from both on and off shore activities, or any other seasonal influences such as tourism or MARPOL and associated additional waste volumes. 2. Estimates of waste volumes do not add up. Application shows 60% of the waste to be household, 40% to be commercial refuse and then additional waste streams are indicated to include construction and demolition wastes, animal wastes, inert wastes, municipal ash, junk vehicles, etc, but no percentage estimate values are indicated. The application shows lead acid batteries, infectious/medical wastes, used oil to be received at the site, but it does not provide information on how these will be containerized and shipped off island. These items are prohibited from landfill disposal so your effort to collect and store them for further shipment or processing must be described. 3. Demonstration is required by 18 AAC 60.305 showing the landfill is designed and operated so that it does not pose a bird safety hazard since it is in the FAA safety radius. The City is required to notify the FAA of this new landfill location at the time of application for disposal permit. Please submit a copy of the FAA's comments or their findings on this proposed landfill location to ADEC's office. 4. ADEC records show it to be in a coastal zone management area, application does not. Please clarify for our records and public notice needs. 5. Site plan is incomplete. Scale indicated does not appear to be consistently applied to the features of the site. Plan must show an accurate view of the site as it is to be accessed and operated, and the location of important operational features. Any use of the former adjacent landfill property must be described. Currently, the access road is labeled but not shown (is it located over the closed landfill?) as required by 18 AAC 60.210(b)(5), the location of stockpiled cover material must be shown, (18 AAC 60.210(6)(b)), a drainage ditch is labeled outside of the facility, but the drainage within the facility and the on site leachate collection system must also be shown and described. For additional information see site file. Louis Howard
7/18/1997 Update or Other Action Letter sent to NOAA Mary Goetz P.E. Discussion between the proposed contractor for the City of Saint George, this office, and NOAA regarding the landfill closure and the appropriateness of the old SW regulations and new SW regulations. It is noted that activity number one, closure of the existing dump, refers to closure compliance under 18 AAC 60 dated January 26, 1996. After consulting the Attorney General's office, ADEC concurs with NOAA that the cleanup and closure standards referenced in the NOAA-ADEC agreement and in effect at the time of the signature govern these closure activities (date January 18, 1996). Consequently, the 1996 amendments to 18 AAC 60 do not apply to these closure activities. However, any construction of a new landfill on Saint George would be governed by the January 28, 1996 amendments to 18 AAC 60 since that activity is not subject to the NOAA-ADEC agreement. Ray Dronenburg
8/20/1997 Meeting or Teleconference Held Proposed language to be added to the RAB Minutes from April 15, 16, 1997 specifically Item B on the Agenda on the status of NOAA's report to Congress under PL 104-91 (NOAA Report). The following entities made comments on the NOAA Report to Congress under PL 104-91: Saint George Tanaq Corp., Tanadgusix Corp., Aleut Community of Saint George and Saint Paul Island, City of Saint George and Saint Paul, Aleutian/Pribilof Islands Association. The comments uniformly expressed the communities' outrage at the one-sided, self-serving, nature of the NOAA Report to Congress and condemned the way NOAA blamed the Aleut People for NOAA's failure to meet its trust obligations to assist the Aleut people to establish a viable alternative economy on the Pribilof Islands, not based on the fur seal industry. Specifically, the community objected to the way the NOAA Report minimized: a) the extent of the environmental pollution left on the islands by the federal government, b) the ongoing threat to human health and the environment by such pollution, c) the cost to cleanup such pollution. The community found it inexcusable that the NOAA Report failed to provide Congress with a summary of the claims filed by Aleut individuals and entities under the process published by NOAA in the Federal Register. The State of Alaska Department of Environmental Conservation also commented on the NOAA Report, objecting to the many misstatements in the Report on the status of environmental pollution on the Pribilof Islands. Specifically, ADEC objected to NOAA's failure to inform Congress that over 9,000 cubic yards of contaminated soil remain from the Salt Lagoon Diesel Seep site; and NOAA's failure to disclose to Congress the numerous site investigation reports, performed by NOAA's environmental contractors, showing the extensive petroleum contamination, waste and debris remaining on the Pribilof Islands which NOAA must remediate under the Two Party Agreement. Ray Dronenburg
10/1/1997 Update or Other Action Update to NOAA/ADEC TPA site activities status Site 4 Active Landfill. Background: Landfill closure being performed within FY97 Cooperative Agreement with the City of Saint George. Activities/Status: Awaiting project work schedule. Remaining Activities: 1) Draft Landfill Closure plan due 7/97 2) Final Landfill closure plan due 9/97 3) Draft Landfill Closure Management Plan due 11/97 4) Final Landfill Closure Management Plan due 1/98 5) Draft landfill closure report due 11/98 6) Final Landfill Closure Report due 4/99 Ray Dronenburg
2/10/1998 Update or Other Action Laura Ogar Solid Waste Program provided comments on the Closure Plan and drawings dated December 19, 1997 for the Saint George Landfill. Existing Site Plan drawing C-1 indicates a general area where waste has been placed at the site. Proposed Grading Plan on C-1 indicates an approximate limit of liner installation. The liner must completely cover all waste buried at the site, and this statement must be shown on the plans. It is not clear where the actual boundary of the waste is at the site and if the indicated liner placement will sufficiently cover this area. Please define the actual footprint of waste within the landfill on these drawings. Please show on the Proposed Grading Plan the locations and alignments of all anchor trenches and toe trenches. Final cover detail Note#7, states any section of the GCL that is hydrated without the design depth of cover material on top of it shall be removed and replaced. Please clarify how this will be accomplished. Construction work and installation of the liner must be performed in accordance with the engineer's design specifications and must be verified in writing. ADEC requests the installation be inspected by the designer or representative throughout all phases of construction. Please inform ADEC on who will be responsible for verification and how it will be documented. Closure plan states that the closed site will be inspected annually by the City and any deficiencies will be repaired. The inspections must be for a minimum five year period. Post closure period begins officially on the completion of all closure work and notification to ADEC that such work has been completed. After five years, the City will need to submit photos of the facility, a description of any problems detected during the visual monitoring and record an appropriate notation on the deed to the landfill property. Request the City provide ADEC with a copy of the revised Closure Plan and drawings for further review and approval. Also include a proposed schedule for this closure activity. Although we may approve this closure plan on its technical merit, we will need to further review its implementation schedule. An alternative waste handling system must be in place BEFORE we allow final closure of this community landfill serving Saint George. Louis Howard
4/27/1998 Update or Other Action Draft Site Assessment Report for the Pribilof Islands Villages of Saint George and Saint Paul dated March 31, 1998 from the Office of the Deputy Secretary of Defense (Environmental Security) received by ADEC. Cover letter is from EG&G Services; John R. Garland; 8809 Sudley Rd.; Manassas, VA 20110-4788 (703) 330-4106. The assessment was conducted by Portage Environmental Inc. through EG&GS under contract to the Naval Surface Warfare Center IH Division. Purpose of the assessment was to gather additional information regarding impacts listed in the 1996 DOD report to congress on the Environmental impacts to Native American Lands. U.S. Army operations began in 1947 at the Pribilofs. A LORAN station and several small lookout posts were established on the islands. Thousands of drums, debris, and dilapidated structures were left behind at the end of WWII. Appendix D Research Documents: Saint Paul and Saint George Islands - Summary of Work for Corps of Engineers 1985 Cleanup Project under Defense Environmental Restoration Program for Formerly Used Defense Sites. 3.10 Site G Barrel Dump: Saint George Island Debris at the site consists of entirely of 55 gallon drums, most of which are closely stacked in ten 100 feet long rows that are 4 tiers high. There about 2,000 drums stacked in an area about 40 x 100 feet. An additional 200 barrels are scattered in a 300 x 300 feet area. Most of these are within 50 feet of the main stack. Most of the barrels are badly deteriorated due to rust and many are partially filled with rainwater which has entered through the holes. One very old barrel was marked "DOW CARBON TETRACHLORIDE, X-GRADE". Other barrels were too rusted to tell but faint odors of diesel and gasoline were detectable. Site G is across the road, slightly NW of the existing landfill and proposed disposal site (for the old barrels). 5. PROPOSED DISPOSAL SITE FOR Saint George ISLAND: The location recommended for a debris disposal site on Saint George Island is at the existing landfill. The site is on a gentle slope within one-half mile of the DOD barrel dump and is controlled by the federal government (NOAA). The site is expected to be conveyed to the City of Saint George by late 1985. For additional information see site file. 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
5/26/1998 Update or Other Action NOAA Office of General Counsel letter to Max Malavansky with an opinion with respect to 3 legal issues at a recent RAB meeting. 1) whether or not PL 104-91 requires NOAA to open new landfills at Saint Paul and Saint George Islands. NOAA states PL 104-91 does not require NOAA to open new landfills on Saint Paul or Saint George Islands. PL 104-91 only requires NOAA to cleanup existing landfills. Cleanup is defined by statute as "the planing and execution of remediation actions for lands...and the redevelopment of landfills to meet statutory requirements." NOAA is unaware of any such state or federal "statutory requirements" which would impose upon NOAA an obligation to open new landfills on Saint Paul or Saint George Islands. Complete text under Sec. 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. Finally, appropriations for the PL 104-91 cleanup process included no funding for new landfills. Thus, NOAA lacks both the legal authority as well as the appropriations necessary to build new landfills for Saint George and Saint Paul. 2) As to the second issue, PL 104-91 speaks only to NOAA's obligations to cleanup "lands" transferred to local entities, which definition does not include buildings which may contain friable asbestos. Thus, on its face, PL 104-91 does not require NOAA to investigate or remediate friable asbestos in the buildings at issue. Similarly, the Two Party Agreement does not require NOAA investigate or remediate friable asbestos as a part of PL 104-91 cleanup. Finally, under applicable federal law, removal or remediation of asbestos is not required if the release or threatened release emanates from products which are part of the structure of, and result in exposure within, residential buildings or business or community structures. See 42 USC 9604(a)(3). Thus, NOAA has no legal responsibility to remediate friable asbestos if it discovered in any of the buildings conveyed or about to be conveyed to local entities. 3) Your question, whether PL 104-91 requires NOAA to remove USTs on properties which it formerly owned and replace them with ASTs, also must be answered in the negative. Where required by the TPA or applicable federal law, NOAA has removed regulated USTs on its properties and replaced them with ASTs. Because Home heating USTs are not regulated by the TPA nor by applicable federal law, see 42 USC 6991(1)(A), NOAA will not remove home heating USTs nor replace them with ASTs. Ray Dronenburg
11/12/1998 Update or Other Action Status of Two Party Agreement Site Number 4 OU 2. Vehicles, equipment, and bulk debris removed in 1997, during FY97 Phase I CA. Landfill closure CA awarded September 1997, to City of Saint George. ADEC conditional approval received March 1998. Progress is delayed due to NOAA and State contention over definition of redevelopment as well as reported City financial inability to open new landfill, as the ADEC approval condition. Renegotiated. Phase I Final Debris Removal report due February 1999. Final landfill closure plan due May 2000. Draft landfill closure report due September 2001. Final Landfill Closure report due February 2002. Monthly progress report to be submitted to ADEC after City meets ADEC approval condition until site closure. Ray Dronenburg
1/14/1999 Meeting or Teleconference Held Meeting with EPA and ADEC staff. Laura Ogar is concerned with the solid waste issues in St. Paul and St. George, agreed with Ray Dronenburg. She said boats are using unpermitted landfills developed by NOAA. These landfills are identified to be closed under two-party agreement (NOAA doesn’t want the responsibility), and Laura feels they shouldn’t be closed until an alternative solid waste management system is in place. NOAA agrees. The cities are at a loss and overwhelmed with sanitation issues. She said DEC is working with NOAA, i.e., how the landfills can be closed out. The increase in ecotourism, fisheries, MARPO, seafood waste, etc., will be generating even more waste. Communities are encouraged to be self-sustaining and provide facilities for solid waste, bilge, etc., for vessels. Keven Kleweno (Drinking Water) was shocked that a permit has been issued for domestic wastewater. He said the plans are not approved and there are large gaps in info on written approval of drinking water (DW) systems. Coast Guard DW system is not approved. Someone in Seattle said the permit was approved. Kevin was adamant that of 3 water systems no permits have been approved by DEC and no one is trying to get everything together. Kevin went on to say that no geological data was used to develop or protect the two wells in St. Paul or one in St. George. There is no overall picture for geology of islands or other background information. No information on the airport water source. The NOAA well will be closed this month. In a sanitary survey, DEC was told of two wells that are on record, but found that 13 wells were being used for drinking water. NOAA owned all and then some of the Native Claim Settlement Act wells. The wells may be on NOAA property. NOAA still has Telegraph Hill. St. Paul is now monitoring highly elevated levels of nitrates on a monthly basis. Kevin said there has been no mining by the Aleuts, the source of the nitrates, for the last 3-4 months. Ray asked why the Aleuts thought they could just go out and mine in this critical area. Ray said the mine is huge and affecting the primary drinking water system. Laura asked if they had sorting equipment and was it dusty. Ray responded with “yes” to both questions. He added that they are working with no permits and that they are going to Sand Pointe to set up another quarry. St. Paul is monitoring on a monthly basis and found that nitrates (caused by explosives) have accelerated from a .4 to .7, a 3 percent increase over time. Ammonia nitrogens and fuel oils combine to make nitrates flow so many feet per second into the drinking water supply. The city doesn’t have money to do more sampling. 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 ($2000) for the first week (or portion thereof) and three thousand dollars ($3000) 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
9/10/1999 Update or Other Action Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. Jennifer Roberts
12/10/1999 Update or Other Action Revised schedules received to avoid reactivating stipulated penalties against NOAA. Landfill closure activities ongoing. Closure activities to start June 2000. Louis Howard
12/28/1999 Update or Other Action Letter from John Halverson to Pat Roth USACE CEPO-PM-E-F regarding Saint George Island Formerly Used Defense sites. December 1, 1999 ADEC received a no further action report for FUDS work on the island. It provides a general summary of work done in 1985-86 under the FUDS program. Based on the information to date, ADEC cannot concur with the proposed NOFA decision by the Corps. The draft NOFA report refers tot he plans/specs under the contract with Chase Construction and TDX Native Corporation. The specs for the project indicate that the drums most likely leaked and caused soil contamination. The landfill permit included a stipulation for collecting soil samples from the drum cleanup sites and analyzing them for petroleum hydrocarbons and RCRA regulated hazardous wastes. The report does not contain any information on investigation or cleanup of hazardous substances. It refers to cleanup and disposal of about 2,200 drums in a local landfill and other debris cleanup. It is unclear whether testing for contaminants of potential concern was done during the FUDS cleanup on Saint George Island. The draft report refers to a report on DOD impacts to native lands in the Pribilof Islands (March 31, 1998 delivery order 0018, contract N00174-96-D-0001 SAR CDRL E003 Deliverable number 18). Please note, that the report was written as a draft. ADEC and the Aleutian/Pribilof Island Association provided comments on the draft report and did not agree with the information and conclusions contained in it. It is ADEC's understanding that the Portage report was never finalized and that there is no plans to finalize it. The draft report also refers to a Landfill Closure Report Permit #8521-BA20 February 20 1996. No record of receiving a final report dated February 1996. ADEC requested copies of the remainder of the plans, specifications, landfill closure report and other supporting documentation (i.e. daily logs or reports from the contractors, etc.) for ADEC review and records. This information will help ADEC in evaluating whether the sites have been adequately characterized and cleaned up to protective levels for human health, safety, welfare and the environment. John Halverson
1/24/2000 Update or Other Action Public Law 106-562 H.R. 1653 passed which has special significance to solid waste assistance on the island. SOLID WASTE ASSISTANCE- `(1) IN GENERAL- Subject to the availability of appropriations, the Secretary shall provide assistance to the State of Alaska for designing, locating, constructing, redeveloping, permitting, or certifying solid waste management facilities on the Pribilof Islands to be operated under permits issued to the City of St. George and the City of St. Paul, Alaska, by the State of Alaska under section 46.03.100 of the Alaska Statutes. `(2) TRANSFER- The Secretary shall transfer any appropriations received under paragraph (1) to the State of Alaska for the benefit of rural and Native villages in Alaska for obligation under section 303 of Public Law 104-182, except that subsection (b) of that section shall not apply to those funds. `(3) LIMITATION- In order to be eligible to receive financial assistance under this subsection, not later than 180 days after the date of the enactment of this paragraph, each of the Cities of St. Paul and St. George shall enter into a written agreement with the State of Alaska under which such City shall identify by its legal boundaries the tract or tracts of land that such City has selected as the site for its solid waste management facility and any supporting infrastructure. Louis Howard
7/17/2000 Update or Other Action DEH SW Program (L. Ogar) sent St. George's engineer (C. Eggener) an approval letter. RE: ADEC Approval of City of St. George, 2000 Interim Municipal Solid Waste Dump Closure Plan. The Alaska Department of Environmental Conservation (ADEC) has reviewed the 2000 Interim Municipal Solid Waste Dump Closure Plan, submitted by CE2 Engineers on June 30, 2000. The closure plan for the existing landfill is shown to include grading and compaction of the existing waste, possible removal of perimeter metal debris and vehicles, placement of bedding material suitable for installation of the geosynthetic clay (GCL) top cap, and soil cover on top of the GCL of adequate thickness in order to protect the liner. ADEC approves the plan with the following comments: 1.) The treated, petroleum contaminated soils from the NOAA project would be suitable for use as bedding material (with cover) within the cap once pcs treatment limits have been shown to be met. 2.) The cover over the GCL must be of adequate thickness in order to protect the GCL. The cap designer shall determine the thickness based on manufacturer recommendations. 3.) The surface of the landfill cap must be constructed in a manner appropriate for proposed future activities. The cap must be revegetated or otherwise appropriately completed. If future vehicle storage is proposed at the site then the surface of the landfill cap must provide a wearing surface suitable for driving and vehicle storage/transportation. 4.) The GCL was not a requirement of the Department, however if it is to be placed, it should be constructed in accordance with all manufacturers recommendations, including a statement certifying the suitable preparation of the bedding material prior to placement of the GCL liner. 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
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
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 Congressman 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
1/3/2003 Institutional Control Record Established As a landfill, controls will be placed at the site restricting any excavation or removal of soils placed as cover material or debris placed at the site. Louis Howard
1/13/2003 Cleanup Complete Determination Issued The Department has reviewed NOAA's request for confirmation of completion of corrective action and, in accordance with Paragraph 59 of the Pribilof Islands Environmental Restoration Two Party Agreement, confirms that no further corrective action is required at TPA Site 4 Active landfill (Site 4). 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, 18 AAC 60 Solid Waste 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, which presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the infomlation provided was invalid, incomplete, or fraudulent. Louis Howard
3/31/2003 Update or Other Action Final Report for St. George landfill closure (NOAA Award Number NA77AB052) for interim closure of a community dump on St. George Island. This project involved the partial closure of a 50 year old, open burning dump located on Tract 38B, a 5.78 acre parcel within Section 36, Township 41 South, Range 130 West, Seward Meridian, Alaska. The closure design and construction were performed by the City of St. George under a Cooperative Agreement with the National Oceanographic and Atmospheric Administration (NOAA) pursuant to Public Law 104-91. The work was performed in accordance with State of Alaska solid waste regulations and was completed in the fall of 2001. In May 2001 crews resumed ripping and stockpiling scoria and grading and shaping the refuse in preparation for installation of the impermeable top cap. The barge arrived from Seattle and the geotextile padding and geosynthetic clay liner were unloaded and staged near the dump. Scoria was spread and compacted over the shaped refuse. Mining and stockpiling of beach sand also continued. Late in May 2001 crews began installing geotextile fabric to pad the bottom side of the GCL. During June 2001 crews continued placing geotextile padding and began installing GCL under the direction of a factory trained installer. The GCL was covered with 8 inches of screened beach sand and ballasted with 10-inches of scoria. Monuments were set on the perimeter of the closed dump. During July 2001 crews placed boulders to channel traffic to the “temporary landfill” which was established in the southeast corner of the partially closed dump. A fence was erected on the north, south, and west sides of the temporary landfill. A sign was erected on the west side of the site to document the relative positions of the perimeter markers and to identify the site as a closed dump. In August 2001 crews completed dump closeout construction activities, cleaned up the staging areas, smoothed and graded the red scoria pit, and demobilized. In December 2001 a post-construction survey of the red scoria pit was performed to determine final extraction quantities for royalty payment to the Aleut Corporation. As-built drawings were also completed and the project was closed out. Louis Howard
12/12/2003 Update or Other Action NOAA sent ADEC a letter-Subject: Request for Confirmation of Completion of Corrective Actions for Two Party Agreement Site 4, Active Landfill, St. George, Alaska. Pursuant to Paragraph 59 of the PribilofIslands Environmental Restoration Two Party Agreement (TPA), National Oceanic and Atmospheric Administration (NOAA) requests Alaska Department of Environmental Conservation (ADEC) confirm that all corrective actions have been completed for Saint George Island TPA Site 4, identified in the agreement as the Active Landfill. TPA Site 4, located on Tract 38B within Section 36, Township 41 South, Range 130 West, Seward Meridian, Alaska, is owned by the City of Saint George. The 5.78 acre landfill site had been in operation for approximately 50 years at the time of the TPA signing in 1996. In August 1997, NOAA awarded the City of St. George a Cooperative Agreement Grant of $1,738,358 to assist the City in closing the landfill. The City and its contractor, CE2 Engineers, Inc., developed a closure plan approved by ADEC in July 2000. Closure included identifying the extents of the existing buried municipal waste; removal of vehicle hulks and large metallic scrap; grading and reshaping the municipal waste; installation of geotextile pad, geosynthetic clay cap and cover material in a manner that ensured all solid waste was covered; installation of perimeter drainage ditches, perimeter markers, and warning signage. Construction started September 2000 and was completed August 2001. As-built plan documents were certified by CE2 Engineers, Inc. in December 2001. Included in the final plan documents approved by ADEC is the requirement for the City of Saint George to perform postclosure care and monitoring activities in accordance with State of Alaska Solid Waste Regulations 18 AAC 60.390. The closure of the active landfill in existence at the time of the TPA enactment, financed by NOAA and accomplished by the City of Saint George, fulfills NOAA's obligations under the TPA. Currently, the City is operating an interim solid waste disposal area within Tract 38B until a new municipal landfill (under construction) is operational. NOAA considers closure of this interim site the municipality's responsibility, not a TPA action. Attached is a copy of the ADEC letter approving the City's closure plan, reduced size certified as-built closure plan documents, and site photographs. Louis Howard
1/13/2004 Update or Other Action Staff commented on the completion of corrective action at TPA 4. The Department has reviewed the information and in accordance with Paragraph 59 of the Pribilof Islands Environmental Restoration Two Party Agreement confirms that no further corrective action is required at this specific site known as the Active Landfill (site 4). 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, 18 AAC 60 Solid Waste 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, which presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. Louis Howard
6/14/2004 Update or Other Action The Alaska Department of Environmental Conservation has conducted a risk evaluation of land farming petroleum contaminated soil on St. George Island and potential effects to human health. It is assumed that a worker at the land farm site would work for 250 days per year for 25 years. In all likelihood, this overestimates the amount of a time a worker would be at the site during a week as well as the number of years that contamination would persist at the same level. All of the risks presented in document are well below all risk management standards. Given the low estimates of risk associated with a worker being at the land farm site and the conservative nature of those estimates, there is minimal risk associated with performing labor on this site. Louis Howard
10/29/2004 Update or Other Action The Alaska Department of Environmental Conservation (the Department) has received and reviewed the Final Summary Report for St. George landspreading and fate and transport modeling documents on October 28, 2004 via email. This proposal is considered an alternative cleanup level (method three) allowed by 18 AAC 75.340. Below are the Department's comments. The modeling summary report proposes petroleum contaminated soil (PCS) excavated from sites on St. George Island under the Two Party Agreement (NOAA 1996) be disposed at the new St. George landfill site through land spreading. This would be accomplished either by using the PCS to construct the berm surrounding the municipal solid waste disposal cell, or by spreading the PCS inside the disposal cell, and using it over time as cover material during the operation of the landfill. After reviewing the data submitted, the Department concurs with the conclusions of the model that use of the PCS to construct a berm or spreading PCS at the landfill will not cause an exceedence of Table C Groundwater cleanup levels. The Department further concludes that this proposed activity is protective of human health, safety, and welfare, and the environment and does not pose an unacceptable risk to human health or the environment. Any transport or disposal of PCS excavated from the landfill requires approval from the Department in accordance with 18 AAC 75.325(i). Institutional controls will be required at the landfill which will restrict removal of the PCS from the landfill and provide notice that PCS is present at the landfill. 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, 18 AAC 78 Underground Storage Tank Regulations, 18 AAC 60 Solid Waste Regulations, and AS 46.03 to require NOAA to perform additional investigation, cleanup, or containment if subsequent information indicates that: 1) PCS which was placed at the site by NOAA presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided to the Department was invalid, incomplete, or fraudulent. Louis Howard
11/15/2004 Update or Other Action DEH-Solid Waste Program (Kim Strickland signature SW & Pest. Prog. Mgr. POC Lori Aldrich 269-7642) grants permit# 0325-BA002 for a Class III Landfill to the City of St. George. The landfill is located approximately 3 miles southwest of the City within Section 36, Township 41 South, Range 130 West, Seward Meridian. If the City wishes to burn municipal wastes prior to disposal, burning must be done in a burn box/cage or incinerator designed to allow for adequate air to flow through the wastes to ensure a hot, clean burn with little black smoke. The City proposed open burning at the face of the landfill in its design. Federal and State air regulations prohibit the open burning at the face of the landfill in this manner. A design for a burn box and plan changes must be submitted to the Department for approval within thirty (30) days of permit issuance. Any open burning at the face of the landfill is a violation of State and Federal laws and the owner and operator may be subject to legal action. Louis Howard
3/4/2005 Update or Other Action Staff received and approved NOAA's request for "Approval for Continued Storage, Petroleum Contaminated Soil (PCS) Long-term Stockpile, St. George Island Alaska, Non Two-Party Agreement Site No. 32 (NTPA Site 32) via electronic mail on March 3, 2005. This extension is granted with the understanding that NOAA will have relocated the stockpile to the City of St. George’s New Landfill berm for beneficial use by September 30, 2005. Louis Howard
7/6/2005 Update or Other Action Staff reviewed and approved the Draft Site Closure Plan for the NOAA long-term Petroleum Contaminated Soil Stockpile Site. The site closure work will follow the below listed general approach. The use of the words “site soil” means soils other than stockpiled PCS and sand bedding material, and includes the original naturally occurring in-situ soils and the scoria used to build the site in 1997. •Removal of the 15,000 gallon steel AST and miscellaneous surface debris. •Culling of debris, liner fragments and boulders from the PCS stockpile. •Relocation of PCS and the coal pile from the stockpile to the new St. George landfill. •Relocation of sand bedding material from the site to the new St. George landfill. •Characterization sampling and analysis of the sand bedding material stockpile at the new St. George landfill. •Removal of the metal sump and buried drainage culvert. •Removal of the liner from the site. •Excavation of site soils and relocation to the new St. George landfill. •TLC field screening and confirmation soil sampling following excavation under the footprints of the PCS stockpile liner, ETC Operations area, and in the general area about the footprints. •Confirmation sampling at both the vehicular ingress and egress points for the site. •Site restoration. •Survey and location by DGPS of all sample points, excavations, final disposal areas, characterized stockpile(s) and site restoration features. •Preparation of debris and IDW for final disposition. Louis Howard
7/29/2005 Update or Other Action An environmental assessment (EA) has been prepared for the NOAA Office of Response and Restoration Pribilof Environmental Restoration Project Office to disclose potentially significant impacts to the human environment associated with the treatment and/or disposal of petroleum-contaminated soils (PCS) excavated from the Pribilof Islands under a Two-Party Agreement with the State of Alaska. The preferred alternatives consist of the beneficial reuse of the PCS in the construction and operations of the City of St. George landfill (Alternative 2) and on-island bioremediation by landspreading (Alternative 3). The preferred siting location is the landfill for Alternative 2 and land leased from the St. George Tanaq Corp. for Alternative 3. Based upon an environmental review and evaluation of this project, NOAA has made a finding of no significant impact (FONSI) determination. The proposed treatment/disposal of petroleum-contaminated soil on St. George Island, Alaska does not constitute a major federal action significantly affecting the quality of the human environment within the meaning of section 102(2)(c) of the NEPA, as amended. Accordingly, an environmental impact statement is not required for this project, and further, NOAA considers this document to meet its functional equivalency standards. Louis Howard
4/7/2006 Meeting or Teleconference Held On April 7, 2006, NOAA and ADEC held a public meeting on St. George Island that was attended by concerned island residents and representatives from the City Council and St. George Tribal Office. The purpose of the public meeting was to explain the modeling and associated parameters that led to the Environmental Assessment conclusion that landspreading at the City landfill sites was the preferable alternative for PCS disposal. NOAA and ADEC presented the data, and answered all questions to the satisfaction of those present. NOAA negotiated a purchase order with the City for moving the remaining PCS and sand bedding material from the stockpile site to the City's Old landfill. Louis Howard
7/5/2006 Spill Transferred from Prevention Preparedness and Response Program PERP Staff sent letter to Pribilof School district informing them of the transfer of the Birdhouse #1 AST release to CS Program staff: Louis Howard for oversight. Characterization of contamination and subsequent cleanup of the site will be conducted by NOAA since they are the property owners and they want to facilitate transfer of the property from NOAA to local entities on island. NOAA has monitoring wells in the immediate vicinity for monitoring groundwater associated with other sites. Eric Henry
7/11/2006 Update or Other Action The Alaska Department of Environmental Conservation (ADEC) has received the corrective action plan for the removal of petroleum contaminated soil at the Pribilof School District Birdhouse #1 on St. George Island. The release was from a 300 gallon heating oil leaking above ground storage tank that was formerly located at the residence (Birdhouse #1). Birdhouse#1 is located in the eastern portion of St. George Village on Lot of Tract 41, East Landing Subdivision, Seward Meridian, Alaska, as shown on the plat of rectangular net survey, officially filed February 15, 1985; Tract 41 Lot 1; 1976 MOU; Parcel 13h; TOPA: Site 35 (Figure 1). Coordinates are latitude 56 degrees, 36 minutes, 8.87 seconds North and longitude 169 degrees, 32 minutes, 38.98 seconds West. Tract 41 was subdivided into Lots 1 and 2 in the 1980s; Birdhouse#1 occupies Lot 1, while Lot 2 includes the St. George School and associated schoolyard. ADEC has reviewed the document and will approve the document as submitted to conduct the removal, to the maximum extent practicable, and subsequent transport/disposal of petroleum contaminated soil at the City of St. George's old landfill for beneficial reuse as closure soil or additional cover material. Louis Howard
10/31/2006 Update or Other Action In October 2006, the remaining PCS, the upper portions of the protective sand layer over the stockpile liner, and temporary excavator access ramp material were removed from NOAA Site 32 and used as capping material at the City's old landfill site. A total of 6,500 cubic yards of material was moved. The stockpile liner was removed and buried at the new City landfill. The stockpile containment area was backfilled with approximately 2 feet of clean material to restore the area to grade. Large rocks were placed at the site access points to deter vehicle trespass. During the stockpile removal, it was found that a double liner system had apparently been installed in 1997, with approximately six to twenty four inches of sand placed between the liners. Louis Howard
2/2/2007 Update or Other Action ADEC received and reviewed the Draft Site Closure and Assessment Plan for the NOAA Petroleum-Contaminated Soil Stockpile/Enhanced Thermal Conduction Operations Area (NOAA Site 32/Non-Two Party Agreement). ADEC will approve the document as submitted for Site 32 at longitude 169º 34’ 59.49” west and latitude 56º 36’ 2.01” north and located within an area known as: Tract 40, Section 25, Township 41 South, Range 130 West, of the Seward Meridian, Alaska. ADEC reserves its rights, under: 18 Alaska Administrative Code (AAC) 75 Oil and Other Hazardous Substances Pollution Control regulations, 18 AAC 78 Underground Storage Tank regulations, 18 AAC 60 Solid Waste regulations, and Alaska Statutes (A.S.) 46.03 Environmental Conservation, to require NOAA to perform additional investigation, cleanup, or containment if subsequent information indicates there is an unacceptable risk to human health, safety, or welfare, or the environment. NOTE TO FILE: This plan was prepared to guide field activities related to debris removal, PCS relocation, sand bedding material relocation, soil sampling, removal of soil above site cleanup levels and site restoration. These activities will facilitate: • Confirmation that petroleum hydrocarbons or other potentially hazardous substances have not been released to the environment; • Verification that all NOAA and all St. George Tanaq Corporation (Tanaq)-owned equipment has been removed from the site; • Verification that all surface debris have been removed from the site; • Verification that a metal vertical sump and a buried metal drainage culvert has been removed at the PCS stockpile; • Verification that all liner materials have been removed from the site; • Verification that any contaminated soil has been removed from the site; and • Evaluation of whether additional sampling, corrective action, or no further action is required, pursuant to applicable regulations. Louis Howard
4/28/2008 Update or Other Action In 2000, NOAA commissioned a contaminated fate and transport modeling study to evaluate contaminant migration from TPA Site 4 (Active Landfill) which is located 400 yards northwest of Site 14. Tetra Tech reported that the water table in this area is about 250 feet below the ground surface, with the public water supply wells located 2.5 miles to the northeast. Based on SESOIL modeling of the area's vadose zone, the report concluded that contaminants were not likely to reach the water table in concentrations exceeding applicable groundwater cleanup levels, and that there was little potential for impact to the island's drinking water supply. Louis Howard
8/5/2008 Update or Other Action Notice of Residual Soil Contamination and Municipal Solid Waste at Two Party Agreement Site 4. 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 about 5 miles southwest of the City and about 12 mile east of Zapadni Road in central St. George Island, Alaska, 99591 is contaminated with petroleum products and contains municipal solid waste. More specifically, the property is described as follows: Lot 1 Section 36, Township 41 South, Range 130 West, orthe Seward Meridian, Alaska. 56 degrees 35' 19.72" North Latitude, 169 degrees 35' 38.67" West Longitude This property, hereafter referred to as Site 4 (Figures I 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. Petroleum-contaminated soil (PCS) and so lid waste present on this property must be managed in accordance with current and applicable laws. ADEC determined, in accordance with 18 AAC 75.325(f)(1), that site cleanup has been performed to the maximum extent practicable even though residual petroleum contaminated soil remained on the property (ADEC 2004a). ADEC granted a conditional closure, in part subject to this institutional control ( deed notice), and confirmed that no further corrective action was required at th e site unless new information becomes avai lable that indicates to ADEC that the site may pose an unacceptable risk to human health, safety, welfare or the environment (ADEC 2004a). 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 4 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 75.325-.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 75.370(b) and 18 AAC 78.600(h). In the future, ADEC approval is required prior to moving the soil cover over the solid waste at Site 4 pursuant to 18 AAC 60. If contam inated soil and solid wastes are removed from the site, the site must be characterized and managed following regulations applicable at that time including (1) 18 AAC 75.325(i), (2) 18 AAC 75.370, and (3) 18 AAC 60 as amended. ADEC approval is required prior to moving soil or solid wastes that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.390, and 18 AAC 60 as amended. 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, and until all wastes are removed from the property. 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. Active Landfill, Site 4; TPA Site 4: Site 4 is the site of a municipal solid waste (MSW) landfill which was closed and capped in 2001 with a geosynthetic clay cover. However, the City of St. George conducted post-closure open burning of MSW in a cell on top of this cover. The post-closure open burning stopped in 2006, and the active cell was capped with petroleum contaminated soil (PCS) from NOAA Site 32/Non-Two Party Agreement - PCS Stockpile and Enhanced Thermal Conduction (ETC) Operations Area (NOAA 2007b). Site 32 PCS originated from various TPA site cleanups on St. George, and potentially contained the same contaminants that originated at these sites, i.e. DRO, RRO, GRO, benzene, toluene, ethylbenzene, and total xylene (BTEX). PCS from Site 32 was determined to be suitable for landfill cover material based on a risk analysis conducted by ADEC (ADEC 2004), contaminant fate and transport modeling by NOAA (NOAA 2004b), and an environmental assessment by NOAA (NOAA 2005b). To meet contaminant fate and transport model parameters, which included Site 32 stockpile sample analytical results, contaminant concentrations in the PCS used for capping did not exceed the following maximum averages. The City of St. George is responsible for post-closure monitoring of the landfill cap. 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. 4/TPA Site No. 4, Active Landfill: drums, surface debris, solid waste, contaminated soil. Site Conditions as of August 6, 2008: Municipal solid waste (MSW) capped with geosynthetic clay and scoria throughout most of the landfill footprint; MSW open burning was conducted post-closure in the southern portion of the footprint until 2006 when this area and much of the rest of the landfill footprint was capped with petroleum-contaminated soil (PCS) from various Two-Party Agreement sites. DRO, GRO, residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes are potential PCS cap contaminants. City of St. George is responsible for post-closure monitoring. Deed notice Site status as of September 26, 2008: NFRAP 01/13/2004 (City of St. George bears liability for long-term monitoring and Operations & Maintenance) Propery Owners: City of St. George. NOAA Site No. 32 Non-TPA Petroleum Contaminated Stockpile. Contaminated soil. Clean closure. Site Status as of September 26, 2008: NFRAP 01/08/2008. Property Owner: NOAA> Louis Howard
6/14/2013 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73165 name: auto-generated pm edit TPA 04 STG Active Landfill Louis Howard

Contaminant Information

Name Level Description Media Comments
DRO Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil Municipal solid waste (MSW) capped with geosynthetic clay and scoria throughout most of the landfill footprint; MSW open burning was conducted post-closure in the southern portion of the footprint until 2006 when this area and much of the rest of the landfill footprint was capped with petroleum-contaminated soil (PCS) from various Two-Party Agreement sites. DRO, GRO, residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes are potential PCS cap contaminants. City of St. George is responsible for post-closure monitoring.

Control Type

Type Details
CS Database Notation And Letter To Landowner/RP As a former landfill restrictions on disturbing the cap material or removal of debris placed at the site is prohibited.
Notice of Environmental Contamination (Deed Notice) 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 about 5 miles southwest of the City and about 1/2 mile east of Zapadni Road in central St. George Island, Alaska, 99591 is contaminated with petroleum products and contains municipal solid waste. More specifically, the property is described as follows: Tract 38 Section 36, Township 41 South, Range 130 West, of the Seward Meridian, Alaska. 56 degrees 35' 19.72" North Latitude, 169 degrees 35' 38.67" West Longitude

Requirements

Description Details
Excavation / Soil Movement Restrictions As a former landfill no removal of cap material or contaminated soil is allowed. Annual inspections of cover material to ensure it is intact.
Advance approval required to transport soil or groundwater off-site.
Maintenance / Inspection Of Engineering Controls In the future, ADEC approval is required prior to moving-the soil cover over the solid waste at Site 4 pursuant to 18 AAC 60. If contaminated soil and solid wastes are removed from the site, the site must be characterized and managed following regulations applicable at that time including (1) 18 AAC 75.325(i), (2) 18 AAC 75.370, and (3) 18 AAC 60 as amended. ADEC approval is required prior to moving soil or solid wastes that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.390, and 18 AAC 60 as amended.

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