Division of Spill Prevention and Response

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Site Report: Skagway (Nahku) Ore Terminal


Site Name: Skagway (Nahku) Ore Terminal
Address: State Street South at Skagway Harbor, West Nakhu Bay, Skagway, AK 99840
File Number: 1526.38.004
Hazard ID: 401
Status: Active
Staff: Kara Kusche, 9072697530 kara.kusche@alaska.gov
Latitude: 59.450734
Longitude: -135.327611
Horizontal Datum:NAD83


We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.


Problems/Comments

The release of lead and zinc ore concentrate fugitive dust to upland properties and to harbor sediments of the marine environment from historical ore transfer operations (1970s, 1980s) is confirmed by site investigation. Complete human exposure route pathways include inhalation, ingestion and dermal contact. Site cleanup in Skagway by responsible party Pacific and Arctic Railway and Navigation Company and other responsible parties has reduced the risk of human exposure on the upland properties, however, contaminated sediments in the Ore Basin of the Skagway Harbor remain a major concern to DEC for the remaining complete exposure pathways to public health. DEC has requested a thorough seafood risk assessment be conducted if a planned sediment dredge removal action cleanup remedy is not implemented in the near future. Environmental Protection Agency (EPA) ID AKD981767148; EPA site name Nahku Ore Facility.



Action Information

Action Date Action Description DEC Staff
8/26/1988 Update or Other Action EPA issued Compliance Order 1088-08-18-309 to Bowhead Equipment Company to immediately cease the discharge of ore into the waters of Skagway Harbor (as fugitive dust) and to present EPA with a detailed engineered site control design solution within thirty days. The EPA Order is based primarily on an inspection by EPA on June 17th and 18th, 1988, and on a 1983-84 study by the U.S. Fish and Wildlife Service. In the study, F&W documented high levels of metals, particularly lead, in marine sediments and marine organism tissues. Bruce Wanstall
12/2/1988 Report or Workplan Review - Other Preliminary Assessment (PA) Report prepared by Ecology and Environment Inc.(E&E) was delivered by regular mail to Tom Healy City Manager for the Municipality of Skagway. DEC sponsored the E&E PA under a cooperative agreement with U.S. Environmental Protection Agency Comprehensive Environmental Response, Compensation, Environmental Response, Compensation, and Liability Act (CERCLA) Preliminary Assessment and Site Investigation (PA/SI) Program. The E&E PA concludes that human and environmental risks may exist as a result of contaminated marine sediments and particulate emissions caused by operations of the Nahku Ore Terminal. Additional investigation of spilled ore, potential food-chain effects, and human health risks posed by inhalation of contaminated dust is needed. These concerns would be appropriately addressed under an investigation using EPA's Revised Hazard Ranking System. Bruce Wanstall
4/20/1989 Cleanup Plan Approved DEC hand-delivered a letter to White Pass & Yukon Route (White Pass) approving the proposed removal action of all soils having lead concentrations greater than 1,000 milligrams per kilogram on the east side of the ore terminal facility and within five feet of the center line of the railroad right of way from their southernmost limits to the Gold Rush Cemetery north of Skagway. Confirmation analytical sampling at the limits of excavation must indicate the cleanup level is met in remaining soil before backfilling and no areas are to be covered or filled without DEC authorization. Excavations will be backfilled with clean fill. Excavated contaminated material from each of those areas will be transported to and stockpiled separately between liners on a concrete pad at the White Pass Rail Yard northeast of town. The burden of prohibiting releases of contaminates during the removal action belongs to White Pass. The letter stated that cleanup of the west side of the ore terminal property remains unresolved but each owner and operator involved are potentially liable for the cost of site investigation, cleanup, and maintenance of site controls at the ore terminal site, now and in the future. Bruce Wanstall
8/7/1989 Enforcement Agreement or Order Without DEC authorization, White Pass & Yukon Route (White Pass) filled an area of concern for lead contamination prior to soil confirmation analytical sampling and analysis to meet the lead in soil cleanup level of 1,000 milligrams per kilogram. Alaska Department of Law notified White Pass by letter this date of intent to issue a compliance order covering site investigation and testing throughout the remainder of the site investigation and cleanup project. Bruce Wanstall
8/26/1993 Site Added to Database Metals. No Longer Assigned
11/10/1994 Site Ranked Using the AHRM Initial ranking. No Longer Assigned
10/15/1999 Update or Other Action A cleanup of the uplands was conducted 1988-90. Biota sampling and a seafood risk assessment were conducted in 1989-90. This file needs to be reviewed for potential future action. Bill Janes
8/7/2001 Site Ranked Using the AHRM Site re-ranked to show documented release, Air Exposure index from 0.1 to 1.0 Bill Janes
11/21/2002 Update or Other Action Michael Kenzie Skagway Tribe checking on risks associated with harbor sediments and subsistence foods. I went through file and put together a briefing email for project manager Palmieri. Stored in Outllook site folder. Anne Marie Palmieri
12/27/2002 Update or Other Action John Wood (AIDEA) informs staff that AIDEA has decided to remove the ore concentrate building as it is a physical safety concern. AIDEA wants DEC to tell them what needs to be done to close out the site. File review will begin in 1/03. Anne Marie Palmieri
1/6/2004 Update or Other Action Skagway Terminal Co. wants to dredge sediments at the Broadway Dock. It is unknown if sediments contain elevated levels of metals. Staff is requesting sampling prior to dredging. Anne Marie Palmieri
3/4/2004 Update or Other Action PRP notification letter and request for additional work sent to AIDEA. Anne Marie Palmieri
6/4/2004 Update or Other Action Project manager transition site visit - obtained GPS reading Bill Janes
11/22/2004 Meeting or Teleconference Held A teleconference to discuss marine sediment contamination issues was held. Attending were representatives from DEC, AIDEA, Dept. of Law, White Pass, and Bowhead. Parties agreed in concept to hiring a consulting firm specializing in marine sediments to review the six prior studies between 1982 and 1995, identify data gaps, and make recommendations. Bill Janes
11/1/2006 Update or Other Action Project Manager change from Janes to Wanstall Bruce Wanstall
5/25/2007 Update or Other Action ADEC received payment of $4,538.18. The funds were recovered from the responsible party/ facility operator for cleanup oversight management of the Skagway (Nakhu) Ore Terminal, Rail Yard and Bulk Fuel Tank Farm sites. Bruce Wanstall
6/27/2007 Exposure Tracking Model Ranking Intitial Ranking Complete for Source Area: 71380 (Autogenerated Action)
7/4/2007 Update or Other Action This contaminated site is listed on CERCLIS database as AKD981767148 Nakhi Ore Facility - Nakhu Harbor - Skagway Bruce Wanstall
7/6/2007 Exposure Tracking Model Ranking Updated Ranking Complete for Source Area: 71380 (Autogenerated Action)
7/17/2007 Update or Other Action The ADEC sent an environmental status letter to the Borough Manager of Skagway concerning Borough property that was part of the White Pass & Yukon cleanup of lead from soil on commercial and residential property along the mining ore transport route through Skagway. The Borough plans to build a bus barn on commercial property at the south end of town. The Borough was advised that the industrial cleanup level that was approved in 1990 carries a restriction that the excavation of soil and/or transport off-site must be coordinated with the ADEC. Bruce Wanstall
12/27/2007 Update or Other Action ADEC received payment of $4,858.91. The funds were recovered from the responsible party/ facility former operator for oversight of residual environmental impact long term monitoring of the Skagway (Nakhu) Ore Terminal, Rail Yard and Bulk Fuel Tank Farm sites. Bruce Wanstall
2/13/2008 GIS Position Updated ArcMap was used to fine-tune the location of the shore-to-ship conveyor at the facility where the release of contaminants occurred and the bulk of residual contamination is of concern to the ADEC. Property Legal Description data was added to the record. Bruce Wanstall
4/18/2008 Update or Other Action An ADEC letter replied to Minto Explorations concerning the 2007 Skagway Harbor Baseline Study by Access Consulting and Dr. Chad Gubala. The study combined bathymetric and tidal pattern data to indicate that a net loss of sediment occurs naturally from the SOT basin. The re-suspenion of metals contaminated sediments into these currents may have spread them into deeper benthic substrate in Lynn Canal. The report did not include laboratory reports or spatial sample location data necessary for a quality assurance evaluation. Bruce Wanstall
8/10/2009 Report or Workplan Review - Other ADEC received laboratory data for the draft Tetra Tech TMDL study on the Skagway Harbor and Pullen Creek for quality assurance review of toxicity data on metals RfD benchmarks for ecological exposure risk in sediment, pore, and ambient waters. Methodology, statistical confidence and species/number tested establish reliability of the conclusions in the report. Bruce Wanstall
3/4/2010 Meeting or Teleconference Held ADEC met with the Skagway Borough Manager to discuss the Skagway (Nahku) Ore Terminal contaminated site in Skagway. Several studies of harbor waters in 2007 indicate that sediments contaminated with mining ore metals at the SOT basin have been scattered outward by erosional forces leaving a reduced risk of exposure to aquatic life in the harbor. Both studies are currently under quality assurance review. Bruce Wanstall
3/5/2010 Update or Other Action DEC requested AIDEA submit a laboratory analysis report for baseline SOT basin sediment samples, soil samples and ground water samples that were collected by URS in 2006 and requested by letter that Sherwood/Minto Mining submit laboratory analysis report for sediment samples collected by Access Consulting in 2007 (copy of DEC 4.13.2008 letter requesting the additional data from Access was attached). Bruce Wanstall
5/24/2010 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71380 Ore Transfer Shed & Conveyor. Subsurface soil lead concentration exceeds the 400 mg/kg action level: Boring SB-2 lead concentration is 1,999 mg/kg. Construction operations to rebuild the facility are completed which returns control to the direct contact to subsurface soil exposure route. Bruce Wanstall
7/13/2010 Update or Other Action On request, ADEC combined conclusions of the Total Maximum Daily Load (pollution) Study of Skagway Harbor waters with a timeline for conclusions of the investigation and how it will affect developments of the Skagway (Nahku) Ore Terminal Contaminated Site; sent by email to John Walsh, a consultant for the Borough of Skagway. Bruce Wanstall
4/4/2011 Meeting or Teleconference Held DEC (CS & Non-Point Source Water Programs) met with the city manager and legislative aide for the Municipality of Skagway to discuss the Ore Terminal contaminated sediments. Skagway plans to coordinate with a contractor to evaluate the existing data reports available in the site record to determine the status of the contamination to assist in planning development in the White Pass Basin. Bruce Wanstall
3/30/2012 Site Characterization Report Approved A contractor for the City of Skagway and Port Commission recently reassessed and provided a report on the contaminated sediments at the marine facility. The report included the observation that existing contamination may be being displaced by erosion into deeper harbor waters. This statement has elevated DEC's concern for the site. DEC letter sent to the Borough of Skagway provided approval of laboratory data from recent site activity with regard to contaminated sediments in the Ore Terminal Basin, comments on and conclusions of all recent data for the site, and requests for a timely cleanup remedy that includes dredge of contaminated sediments from the Ore Terminal Basin and disposal upland in an engineered structure that will meet regulatory monofill requirements. Bruce Wanstall
4/2/2012 Report or Workplan Review - Other DEC reviewed and by letter approves the 2011 Skagway Harbor Baseline Study (Report), dated November 2011. The revised version of the Report by Chad Gubala documents 2011 site activities for the Municipality of Skagway. The site activity met the objectives of the project and an acceptable number of representative samples were collected. The precision, accuracy and completeness of the resulting analytical data is sufficient to be used to support the decision making process. In accordance with Title 18 Alaska Administrative Code (AAC) 75.360, qualified person(s) used data collection and field methods consistent with DEC methodology. The laboratory data meet Contaminated Sites Program quality assurance criteria therefore the Report is approved in accordance with 18 AAC 75.335(d). Bruce Wanstall
5/15/2012 Update or Other Action DEC determined that dredge and upland disposal is the necessary contaminated sediment cleanup remedy. By letter to the DEC, the Borough of Skagway and Port Commission accept the conclusions reached by DEC and its request for mitigation of the risks posed by contaminated sediments. They agreed to: 1) within 2-4 months notify port users and partners (i.e. AIDEA, White Pass) that the Borough accepts cleanup responsibility and will perform additional sediment monitoring and characterization of the SOT basin in parallel with the mitigation planning process; 2) ASAP establish a technical dialogue to seek comments and to organize a lead or team to design and submit a practical and feasible plan for contaminated sediment removal, upland disposal, isolation and monitoring for completion within 2 years. Bruce Wanstall
8/22/2012 Update or Other Action DEC held a discussion with an environmental representative of Skagway Borough (Gubala) the cleanup remedy for contaminated sediments at the White Pass & Yukon Ore Terminal Dock harbor basin. DEC provided regulatory and industry specifications for the solid waste monofill liner to contain the contaminated sediments in an engineered structure at an upland location. Bruce Wanstall
9/6/2012 Update or Other Action Prepare site information and travel from Juneau to Skagway to attend meetings with White Pass and Golder Associates to discuss how to improve communication and coordination of future site activities at sites in Skagway. While aspects of the proposed dredge project at the Ore Terminal Basin were discussed, a site visit was not performed by the attendees. Bruce Wanstall
11/26/2012 Meeting or Teleconference Held DEC met with Skagway City Manager Tom Healy and consultant John Walsh to discuss the schedule and scope of a project that will dredge contaminated sediments from the basin of the Skagway Harbor at the Ore Terminal ship loading dock. Additional assessment borings will be advanced into subsurface sediments of the basin in 2013. The site activity will provide essential geotechnical data for the project and will better define the volume of contaminated material that is planned to be encapsulated into a confined on-site monofill in conjunction with reconstruction of the ore dock. Bruce Wanstall
6/11/2013 Meeting or Teleconference Held Telephone meeting held with Chad Gubala (consultant for the Skagway Borough) for a final discussion of the sampling plan analyte intervals and methodology for collecting sediment cores in the Ore Terminal Basin. A vibracore device will be used in combination with a dredge stand-in barge to advance borings. After sampling the remainder of the cores will be used to perform a test of the geomembrane planned to envelope contaminated sediments in an on-site upland containment. The exposure response experiment will include exposing the membrane to the core material at varying temperatures monitoring permeability and structural continuity over time. Bruce Wanstall
6/14/2013 Site Characterization Workplan Approved DEC evaluated the 2013 Gateway Pre-Engineering Assessment Sediment Coring Sampling and Analysis Plan (Plan) and held a telephone discussion of the Plan with Gubala Consulting Inc this morning. DEC requested that in addition to the seven other cores scattered throughout the basin Gubala advance a core to collect samples to characterize sediments between the Ore Dock and the shoreline of the transfer facility. The southernmost boring in the basin will be moved to this new location. The analyte list for samples from this boring will remain the same as the other sediment samples. Also, DEC requested Gubala collect a sample and field duplicate of pore water from one of the borings and analyze for total metals only. Plan approval was sent by email to Gubala and copied to the George Edes, Skagway City Manager. Bruce Wanstall
8/12/2013 Meeting or Teleconference Held DEC traveled to Skagway to attend meetings with representatives of the City and Borough of Skagway (City Manager and members of the Assembly and Port Commission), the general public, White Pass and Yukon Route, Pacific Contract Company and Gubala Consulting to assist with the planning and coordination of site activity by the Gateway Initiative to dredge the Ore Terminal Basin that has contaminated sediments. Bruce Wanstall
4/24/2014 Report or Workplan Review - Other DEC reviewed and approves the 2013 Skagway Harbor Gateway Pre-Engineering Assessment Report. The Report documents benthic core sampling and laboratory analysis in 2013 to characterize sediments in the Skagway Harbor for contamination from legacy and contemporary sources. The site activity is consistent with a work plan approved by DEC in June, 2013, to collect samples from sediment cores advanced deeper below the surface than has been carried out in previous characterization investigations. The data meet field and laboratory report meet Contaminated Sites Program quality assurance criteria therefore the Report is approved in accordance with 18 AAC 75.335(d). The spatial distribution of selected metals and polyaromatic hydrocarbons (PAHs), combined with the relatively consistent depth to refusal (clean sand at ~1.0 to 1.5 meters below surface) for each sediment core illustrates that the base layer of the historically affected sediment zone in the SOT harbor represents the highest degree of contamination. The contamination is highest in proximity to the ore dock, especially near and to the southwest of the loader, and sediment contamination falls rapidly off with depth in the sediment once the sand boundary layer is encountered (~1.0 to 1.5 meters below surface). Bruce Wanstall
6/11/2014 Site Visit DEC site visit to inspect the vegetative cover at the upland undeveloped area Bruce Wanstall
8/11/2014 Meeting or Teleconference Held DEC attended a meeting at the federal building in Juneau sponsored by USACE and EPA for DEC, KPFF, Anchor QEA to discuss permit and work plan requirements involved with the site cleanup dredging of legacy contaminated sediments in the Ore Transfer Harbor that resulted from historical White Pass & Yukon Route ore transfer operations in Skagway. The site cleanup coincides with ore terminal facility remodeling under the Skagway Municipality Gateway Initiative. Municipality representative Dr. Chad Gubala attended the meeting by teleconference from Skagway. Bruce Wanstall
10/2/2014 Meeting or Teleconference Held DEC attended a meeting at the federal building in Juneau sponsored by USACE and EPA for DEC, KPFF, Anchor QEA to discuss a draft Sampling and Analysis Plan for dredging the Small Boat Harbor and Skagway Harbor sediments for beneficial use in the Skagway Intermodal Reconstruction and Legacy Contamination Cleanup for the Municipality of Skagway Gateway Initiative. Bruce Wanstall
10/15/2014 Meeting or Teleconference Held A meeting by teleconference, sponsored by Sampling and Analysis Plan (SAP) authors Anchor QEA, on October 15, 2014 was attended by KPFF Consulting Engineers and regulatory representatives from US Army Corps of Engineers, Environmental Protection Agency, and DEC (Water and Contaminated Sites Programs) to discuss modifications to the SAP suggested by the same attendees in an October 2, 2014 meeting held in Juneau. Attendees of this meeting acknowledged that requested clarifications and changes are included in the updated version of the SAP. For example, to accommodate the yet to be determined depth of the Z layer in the deepest Dredged Material Management Units (DMMUs) (itself a variance from the DMMP User Manual), the SAP selects smaller DMMU volumes than the DMMP ranking would normally require and increased the number of sampling locations in the Small Boat and Ore Terminal harbors. Analytical composites are collected from similar depth intervals across borings and from each boring to characterize each DMMU. Section 4.3 of the SAP states: “The final extent of dredging in the Harbor will be determined based on results of the sampling and additional pending details regarding structural requirements. Preliminary volume calculations indicate that dredging in the vicinity of the Ore Dock may include up to a total maximum volume of approximately 205,000 cubic yards (CY) of material. This dredge volume is a rough estimate and was developed solely for this document to provide a theoretical maximum extent of dredging and subsequently establish the Dredged Material Management Units (DMMUs) for the SAP.” Section 8.3 of the referenced SAP states: “Results of chemical, physical, and leachability testing (if necessary) will inform sediment management options for the Project including dredge prism design for both the Ore Dock and SBH. Recommendations will also be made for the management of dredge material for beneficial reuse as fill in the Gateway Intermodal Dock sheetpile retaining wall structure.” Bruce Wanstall
10/31/2014 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71380 Ore Transfer Shed & Conveyor. Bruce Wanstall
12/9/2014 Institutional Control Record Established Institutional Controls (ICs) are established and entered into the database per Compliance Order By Consent (COBC)* executed between White Pass and DEC in 1989 for properties where removal action cleanup was completed to a soil cleanup level of 1,000 milligrams per kilogram. For these properties future land use is restricted to industrial only and any plans to excavate soil on the Ore Terminal Property must obtain written authorization from DEC prior to any such activity begins. Requirement of periodic reporting for compliance with ICs in a signed agreement is requested of the landowner, Municipality of Skagway. *COBC No. 88-11-09-299-02 (September 1, 1989) Bruce Wanstall
1/7/2015 Institutional Control Update DEC provided Chad Gubala PhD, representing the Municipality of Skagway, with Notice of Institutional Controls (ICs) placed on the property in a Compliance Order by Consent agreement dated 1989, are now established on the DEC database of contaminated sites. When site cleanup is complete, DEC will issue a closure determination letter describing any remaining contamination at the site subject to the ICs. A Deed Notice with the closure with ICs determination information will be recorded, and a representative of the Municipality of Skagway will sign an agreement to abide by the terms of the ICs in future management of the property. The ICs may be removed in the future if documentation can be provided that shows cleanup levels for unrestricted land use have been established and all hazardous materials are removed from the site. DEC has approved a Sampling and Analysis Plan for the harbor sediments and anticipates reviewing for approval, a sampling plan for the upland property that will adequately characterize contamination associated with site activity that will disturb the surface soils, and perform any necessary cleanup in a timely manner. Bruce Wanstall
1/8/2015 Report or Workplan Review - Other DEC approved by letter with requests and additions: SOT Uplands Sampling and Analysis Plan for Coordinated Gateway Programming ‘23 (Plan). The Plan represents an add-on to the DEC-approved Gateway Sampling and Analysis Plan (SAP) to allow the Municipality of Skagway (MOS) and Alaska Industrial Development and Export Authority (AIDEA) to acquire geotechnical and environmental data from the upland property at the Skagway Ore Terminal (Site) concurrent with execution of the Gateway SAP to characterize harbor sediments for contamination and remedial treatment on-site. Gubala Consulting Inc. prepared and submitted the Plan as an impartial third party qualified person, proposed data collection and field screening methods that are consistent with DEC methodology. The Plan meets field and laboratory report quality assurance criteria in Contaminated Sites Program guidance documents, therefore the Plan is approved in accordance with 18 AAC 75.335(b). Bruce Wanstall
2/10/2015 Meeting or Teleconference Held A meeting held at the federal building in Juneau, today (February 10, 2015), was attended by the Sampling and Analysis Plan (SAP) authors Anchor QEA, regulatory representatives of US Army Corps of Engineers, Environmental Protection Agency, and DEC Contaminated Sites Program and, attending in teleconference, was KPFF Consulting Engineers and the Municipality of Skagway. The agenda began with news that the Sonicore technology was successful in reaching a depth of fifteen feet below the mudline to obtain the sediment cores in the difficult terrain of ore terminal harbor and in the small boat harbor in Skagway. Soil core sampling was also completed on the upland Municipality-owned and managed ore terminal operations property. The data objectives included critical geotechnical for structural design and chemical characterization for remedial design. In accordance with the SAP, Anchor QEA collected the first round of analytical samples and submitted them to respective laboratories and have archived the remainder of the cores in frozen, secure storage. The group discussed a basis for how the data will inform sediment management options for the dredge prism design, beneficial reuse of sediment as fill in the Gateway Intermodal Dock sheetpile retaining wall structure, and the coordination of timelines for draft/final characterization reporting, agency and municipal review, permit public comment and final approval processes. Bruce Wanstall
3/5/2015 Institutional Control Update It has been DEC’s understanding that regular operation of the ore transfer facility produced no discharge of any water to subsurface soil at the ore terminal. The reason for that is the remaining contaminated soil under the protective asphalt cap could leach pollutants (metals and PAH compounds) into subsurface waters that are hydrologically connected to the harbor. The apparent discharge from the water treatment unit and other sources to subsurface infiltration galleries and monitoring wells may conflict with terms of Institutional Controls (ICs) placed on the property by DEC following the 1989 cleanup of lead and zinc contamination of surface soils under two Compliance Orders by Consent that were completed to the satisfaction of the Department. DEC requested work plan to collect samples from the wells for laboratory analysis to monitor effluent produced by operation of the truck wash down unit and storm water runoff from the Ore Terminal Facility. Bruce Wanstall
3/31/2015 Site Visit DEC Water and Contaminated Sites staff met with Tyler Rose at the White Pass & Yukon office in Skagway to arrange a facility inspection of the ore terminal facility. DEC then contacted Capstone Mining operations engineer Martin Mann in YT CA to arrange a meeting with Mineral Services, operator of the terminal. Gene Lindfors met with DEC Water and Contaminated Sites staff to discuss facility site controls and then tour the ore transfer operations area, truck and equipment wash-down collection bays and water treatment plants and the four excess water subsurface infiltration galleries. Bruce Wanstall
4/3/2015 Update or Other Action The DEC Compliance and Enforcement Section of the Water Program issued a Notice of Violation to Mineral Services Incorporated alleging that beginning on or about March 5, 2015 (date of complaint received by ADEC) at 116 Ore Terminal Rd., Skagway, AK 99840, the Skagway Ore Terminal did unlawfully fail to comply with the conditions of the Alaska Administrative Code. Such action is in violation of 18 AAC 72.500 Failure to obtain permit coverage, 18 AAC 72.510 Sludge Disposal, 18 AAC 72.600 Application for Department Approval, and 18 AAC 72.200 Domestic Wastewater Application for Approval. An ADEC inspection on March 31, 2015 confirmed that stormwater, gray water, equipment wash water and potable water from a hose are all being routed to the four infiltration galleries onsite. There are no records of discharge permit applications on file with ADEC. The discharge of stormwater, gray water, equipment wash water and the potable water from the hose is in violation of the proper operation and maintenance of an institutional controls on the property required by the Contaminated Sites Program, as authorized in Title 18 of Alaska’s Administrative Code (AAC) of regulations, Chapter 75.375. Bruce Wanstall
4/13/2015 Meeting or Teleconference Held DEC met with Skagway Borough consultants Derek Coleman and Chad Gubala in DEC office. Discussion included a scope and schedule for dredge cleanup ex-situ and in-situ stabilization of contaminated sediments at the ore terminal, implementation strategies, structural integrity and sediment cleanup criteria. DEC project manager provided approval of the conceptual plan subject to future comment on the final draft. Bruce Wanstall
4/21/2015 Meeting or Teleconference Held DEC Water and Contaminated Sites Programs teleconferenced with representatives of AIDEA, Capstone Mining, and Mineral Services to clarify aspects of the Notice of Violation and improve understanding of how to proceed with permitting water discharges at the ore terminal facility. An Multi Sector General Permit (MSGP) permit is required for storm water and APDES industrial discharge permits may be required for each of the treated water sources. Due to uncertainty of construction and functionality, the subsurface water infiltration systems in a storm water permit became the most uncertain factor going forward with the permit applications. Bruce Wanstall
4/23/2015 Meeting or Teleconference Held DEC CS staff and managers of the Storm Water and Industrial Discharge Permit Programs and Water Quality Compliance and Enforcement teleconferenced with the Skagway Borough Mayor Mark Schafer, City Manager Scott Hahn, and consultants Chad Gubala and Bob Riley with KPFF Engineers. Discussion included a request to DEC that, as landowner, the Skagway Borough have the option to approve or reject any operator proposed permit from a facility located on the Skagway Ore Terminal peninsula. Due to the documented polluting effects of past facility operations on the Skagway Harbor, the Borough prefers no discharge of water, treated or otherwise, be directed to the subsurface on the industrial properties located on the peninsula, particularly at the ore transfer terminal. The preferred option is installation of a collection vessel, for sample monitoring and reporting in accordance with a facility-specific permit quality assurance plan, prior to the discharge of any process treated or storm water from each of the five facility operations on the peninsula. Bruce Wanstall
7/8/2015 Meeting or Teleconference Held Water and SPAR Division staff met with consultants for the Municipality of Skagway Gubala Consulting, Anchor QEA and KPFF and the EPA and US Army CORPS at the Federal Building in Juneau regarding the Skagway Municipality sponsored Sediment Characterization Report for the Gateway Project in Skagway Harbor. Bruce Wanstall
8/5/2015 Report or Workplan Review - Other DEC SPAR and Water Division technical staff met in teleconference with the Alaska Industrial and Export Authority (AIDEA) project manager to discuss DEC requests for changes to a draft quality assurance and sampling plan (QAPP/SAP) prepared by Carson Dorn Inc.(CDI) for Mineral Services Inc. (MSI) operations at the Skagway Ore Terminal (SOT). The group determined that the best means of moving forward to obtain missing discharge permits named in the April 2015 DEC Notice of Violation to MSI included the following: •proceed with the sampling of the surface water and truck/equipment wash water to characterize their waste streams (note, CDI still exploring the discharge of the graywater and blackwater), •submit a Notice of Intent (NOI) along with a Storm Water Pollution Prevention Plan (SWPPP) for stormwater coverage under the Multi-Sector General Permit (MSGP, AKR060000), and •identify a plan (timeline) of when MSI will be able to proceed with closure of the infiltration galleries and transition to an alternative discharge location – i.e., surface water discharge. AIDEA requested DEC allow an extension of the NOV deadline of August 15, 2015 to submit permit applications. Bruce Wanstall
8/26/2015 Report or Workplan Review - Other DEC approval letter for the 2015 Skagway Harbor Sediment Characterization Report by Anchor QEA submitted on behalf of the Municipality of Skagway for the Gateway Development Project was sent by regular and electronic mail today. A copy of the letter is posted to the database record and is available to the public on the department website. Bruce Wanstall
9/22/2015 Update or Other Action ADEC Division of Water, Compliance and Enforcement Program issues a Closure Letter that states the conditions of all deliverables have been satisfied for the Notice of Violation that was issued on 4/3/2015. Kara Kusche
10/20/2015 Update or Other Action Joint letter from Divisions of Water and SPAR issued to Municipality of Skagway addressing concerns related to institutional controls among other issues. Current institutional controls are deemed adequate; however, consistent with current practice, they will be memorialized in a notice of environmental contamination on the property deed and filed with the Department of Natural Resources. In addition, signed agreements to these institutional controls will be obtained from each landowner, leaseholder and operator. Letter also addresses water discharge permitting concerns and concerns about the concentrations of copper in the harbor that were previously expressed by the Municipality. ADEC finds that discharge permit requirements are either met or not required, and ADEC finds no evidence of increasing copper concentrations in the harbor. Bruce Wanstall
10/20/2015 Update or Other Action Joint letter from Divisions of Water and SPAR issued to Municipality of Skagway (MOS)addressing concerns related to institutional controls among other issues. Current institutional controls are deemed adequate; however, consistent with current practice, they will be memorialized in a notice of environmental contamination on the property deed and filed with the Department of Natural Resources. In addition, signed agreements to these institutional controls will be obtained from each landowner, leaseholder and operator. Bruce Wanstall
10/23/2015 Meeting or Teleconference Held DEC staff met in the Anchorage office with Chad Gubala (Gubala Consulting), and Anchor QEA Barbara Bundy and Derik Koellmann to discuss the Municipality of Skagway (MOS) Gateway Project. The MOS has filed a Clean Water Act Section 404 dredge and fill permit application (POA-2015-371) with the U.S. Army Corps of Engineers. The Gateway Project seeks to redevelop the Skagway Ore Terminal through the demolition of existing in- and over-water infrastructure, environmental dredging of contaminated sediments, and construction of new shoreline infrastructure to facilitate ongoing and new ore loading operations, accommodate a wider variety of vessels, and improve environmental conditions in the Skagway Harbor. Bruce Wanstall
2/3/2016 Institutional Control Update IC letter sent to parties for signature. Purpose of letter and ICs is to formalize previously established ICs with current parties. Signatures from parties requested within 60 days from receipt. Note that these ICs apply only to the uplands portion of the site. Kara Kusche
6/29/2016 Potentially Responsible Party/State Interest Letter PRP Letter sent to the Municipality of Skagway. Kara Kusche
7/8/2016 Report or Workplan Review - Other Laboratory Treatability Report was approved. This report summarizes the sediment treatability testing performed to support development of dredge material reuse options. The most effective amendment mixture in reducing contaminant leachability consisted of 3% ferrous sulfate, 5% bone meal, and 2% Portland cement. Kara Kusche
7/25/2016 Report or Workplan Review - Other ADEC receives amended Laboratory Treatability Report and a Memorandum re: Gateway Treatability References which provide information requested by ADEC regarding sediment treatability topics. Kara Kusche
7/28/2016 Report or Workplan Review - Other ADEC sends letter approving amendment to the Laboratory Treatability Report. Kara Kusche
2/27/2017 Report or Workplan Review - Other Study Design and Sampling & Analysis Plan received from White Pass. This plan is intended to fill data gaps in support of moving forward with a human health and ecological risk assessment. The plan proposes sediment chemistry sampling and analysis, benthic community sampling and analysis, tissue sample collection and analysis, sediment toxicity testing, and toxicity identification evaluation. Kara Kusche
3/22/2017 Report or Workplan Review - Other ADEC provided comments to White Pass on the Study Design and Sampling & Analysis Plan. Kara Kusche
4/17/2017 Report or Workplan Review - Other ADEC receives revised Study Design & Sampling and Analysis Plan, along with responses to ADEC comments from White Pass. Kara Kusche
4/26/2017 Report or Workplan Review - Other ADEC approves the Study Design & Sampling and Analysis Plan, along with White Pass's responses to ADEC's comments as a "package." Kara Kusche

Contaminant Information

Name Level Description Media Comments
DRO > Table C Groundwater monitor well MW-5
DRO Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil MTG level exceeded in surface sample in boring MW-2 and sample at 18 feet bgs in boring MW-5 in 1995 D&M Report
Lead - Total > Human Health/Ingestion/Inhalation Soil Post-cleanup sampling in 1995 has residual levels above 1,000mg/kg
Zinc - Total < Method 2 Most Stringent Soil Post-cleanup Baseline Report by D&M 1995 has detectable low levels
PAHs - Total > Site Specific Sediment Criteria Sediment - Marine Concentrations exceed NOAA Threshold and Probable Effect Levels
Lead - Total > Site Specific Sediment Criteria Sediment - Marine Concentrations exceed NOAA Threshold and Probable Effect Levels
Mercury - Total > Site Specific Sediment Criteria Sediment - Marine Concentrations exceed NOAA Threshold and Probable Effect Levels
Cadmium - Total > Site Specific Sediment Criteria Sediment - Marine Concentrations exceed NOAA Threshold and Probable Effect Levels


Control Type

Type Details
Local Ordinances, Databases, Zoning Restrictions An industrial cleanup level of 1000 mg/kg lead was approved for the Ore Terminal property in 1989 by ADEC and concurred with by the Skagway City Council via Resolution 89-18R, which restricts the property to industrial land use only, and requires a surface stabilization program that will provide the following: prevention of soil migration by wind, erosion, tracking or any other natural or mechanical means, suitable for long-term purposes, necessary and reasonable public access, if appropriate and not in conflict with principle uses. In addition, a monitoring and control program that provides maintenance of the surface stabilization program that will prevent activities at the ore terminal from re-contaminating municipal lands.
Institutional Control Management Plan Any plans to excavate soil on the Ore Terminal Property must obtain written authorization from DEC prior to any such activity begins. Future land use is limited to industrial only and maintenance of a cap over all contaminated soil is required.
Other Installation of groundwater wells requires DEC coordination for approval before any work begins. Groundwater wells present on-site should be kept locked and access should be coordinated with DEC through an approved sample monitoring plan. Groundwater monitoring wells must be decommissioned in accordance with DEC guidance and documentation must be submitted to DEC within 30 days of well closure.


Requirements

Description Details
Restricted to Industrial / Commercial Land Use DEC approved site-specific land use cleanup levels of 500 milligrams per kilogram (mg/kg) for residential and 1,000 mg/kg for industrial on the ore terminal Site property. Any future change in land use at the ore terminal property may impact assumptions used in the cleanup level and exposure pathway risk evaluation for this Site. If industrial land use and/or ownership changes, these management conditions may not be protective and ADEC may require additional remediation and revised conditions.
Excavation / Soil Movement Restrictions Any plans to excavate soil on the Ore Terminal Property must obtain written authorization from DEC prior to any such activity begins.
Other Installation of groundwater wells requires DEC coordination for approval before any work begins. If groundwater wells are present on-site for monitoring they should be locked and access coordinated with DEC through an approved sample monitoring plan. Groundwater monitoring wells must be decommissioned in accordance with DEC guidance and documentation of closure must submitted to DEC within 30 days of completion.