Division of Spill Prevention and Response

Breadcrumbs

Site Report: St. Paul TPA 13A/B Lagoon Diesel Seep


Site Name: St. Paul TPA 13A/B Lagoon Diesel Seep
Address: 0.65 Miles N. of City St., Paul & Polovina Turnpike, Saint Paul, AK 99660
File Number: 2644.38.027
Hazard ID: 681
Status: Cleanup Complete - Institutional Controls
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 57.129129
Longitude: -170.275436
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

Diesel seepage into salt lagoon reported in June 1989. Source was most likely a seal processing plant built in 1918 and demolished in 1988 when the commercial seal harvesting ended. Diesel contamination is thought to have occurred from spillage during fuel handling. The fueling operation involved manually pouring 55 gallon drums into a larger tank which fed an on-site boiler. An area, approximately 120 feet by 120 feet showed evidence of diesel contamination. Contamination was encountered from the surface to groundwater which occurred at 3 to 5 feet. 2004 removal action of over 9,000 cubic yards of petroleum contaminated soil and placement of 100,000 pounds of granulated activated carbon in two trenches addressed the contamination at the site. Sheen is no longer visible in the lagoon and further remedial action is not required. CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. Covered by 1996 Pribilof Islands Environmental Restoration Agreement a.k.a. Two Party Agreement between State of Alaska and NOAA. LC could have been 14876060. TDX Corporation owns the land. TAC owns the subsurface. ANSCA Selected Property. Master Title Plat SUPPL SEC 25 current to July 7, 1997 delineates 5.72 acres NOAA is the landowner. Contamination has been identified as migrating offsite to the North Lot 1 Tract 25 which is TDX property (Tract 50 previously a.k.a. tract 44 and Parcel 6j). ANSCA selected property. Former file number CS74.01.



Action Information

Action Date Action Description DEC Staff
12/22/1986 Update or Other Action Memorandum of Understanding among: TDX, TANAQ, and USDOC NOAA NMFS regarding Pribilof Islands Land Selections. Byproducts Plant. NMFS agrees to release for selection by the Tanadgusix Corporation the fur seal byproducts processing plant, subject, however, (1) To contractual agreements between NMFS and Lee Paola (Oregon Alaska Marine Products Company) which presently exist or may exist for a period of five (5) years from the date hereof; and (2) To continued use by NMFS of the byproducts plan for biological sampling. Louis Howard
2/28/1988 Update or Other Action Corps of Engineers Environmental Assessment submitted as required under NEPA "Finding of No Significant Impact" for the Saint Paul Island Harbor Project. the proposed action is the construction of a 1,000 foot detached breakwater to assure harbor safety. The main purpose of constructing the main and secondary breakwaters is to reduce the wave climate within the proposed boat harbor. The shoreline at the proposed project location does not allow a design which would minimize impacts to harbor flushing and circulation. Because of the presence of the Salt Lagoon and the small tidal range, the proposed design is the most damaging platform for harbor flushing and circulation. The breakwater design was modified with a 200 foot break at the shoreline to permit some flushing and circulation. It appears that a good flushing action would occur only with storms which produce waves of about 10 feet or more. This change could cause adverse effects to Salt Lagoon if quantities of pollutants are introduced into the system through boat refueling, leaking underground storage tank systems, or other contaminant sources. Ray Dronenburg
6/14/1989 Interim Removal Action Approved (Old R:Base Action Code = SC - Site Control (Emergency Response)). City of Saint Paul was solicited by NMFS to construct a trench to mitigate contaminant migration. Louis Howard
6/20/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). NMFS engineering representative concluded an UST, because of site conditions, was unlikely to exist and contamination was probably due to fuel spillage. Louis Howard
6/1/1990 Update or Other Action February 1990 Site investigation Army Corps of Engineers Former rendering plant investigated. Soil in the study area immediately to the west of the plant site was contaminated with #2 diesel. Document theorizes that the area of TP-14 and immediately east is the source area. Salt marsh to the north and northwest has not yet been contaminated, but is vulnerable. Remediation to involve removal of contaminated soils. Land farming is a disposal option. The fueling operation involved manually pouring 55 gallon drums into a larger tank which fed an on-site boiler. In 1988 the plant was demolished after commercial harvesting of seals ended. An area approximately 120' by 120' showed evidence of diesel contamination. Contamination was encountered from the surface to groundwater which occurred at 3 to 5 feet. The soil TPH ranged from non detectable to 50,000 ppm. Groundwater in the contaminated area ranged from 200 to 250 ppm TPH. Groundwater movement from the contaminated area threatens uncontaminated wetlands to the west and NW. Soil removal and possible land farming of excavated soils was proposed. February 1990 Final Report received January 31, 1992 by Western District Office. Ray Dronenburg
9/26/1990 Update or Other Action INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990 Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee. Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels. Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1. Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants. For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans. If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL. Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1. Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information. The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II. General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. Louis Howard
2/13/1991 Site Number Identifier Changed Old Reckey 1989210615201. Changed to reflect correct work plan. Ray Dronenburg
8/9/1991 Site Number Identifier Changed Old # 89210115201, new # 89250115201. Western district now. Louis Howard
1/1/1992 Site Added to Database Diesel fuel contaminant. Louis Howard
6/30/1992 Update or Other Action Oil Spill Consultants report Diesel Fuel Spill Remediation received. May 1992 OSC initiated site remediation for a diesel fuel spill near the former seal carcass rendering plant near the Salt Lagoon. Oil containment boom was installed along the bank of the Salt Lagoon inlet channel where sheens are observed, 3 oil interception trenches equipped with perforated PVC pipe and collection sumps were constructed to capture and contain oil seeping from the contaminated soil, soil from a 10' X 10' contaminated area (recommended for cleanup by the U.S. Army COE) was excavated and placed in plastic fish totes. TPH ranged from 10 to 53,000 mg/kg. In the excavation the TPH ranged from 1,080 mg/kg to 16,600 mg/kg and for beach soil where sheen is seeping into the salt lagoon inlet channel the TPH ranged from 23,900 mg/kg to 38,200 mg/kg. In the area to the south of the former seal carcass rendering plant immediately behind the Saint Paul Island Public Works Department contained approximately 200 drums. Based on the condition of the drums, they appeared to have been there for many years. The drums were eventually removed and taken to the City tank farm for storage inside a bermed area. Although the site report prepared by the COE states that the sheens in the lagoon are from a diesel fuel spill, both the ground color and odor (based on OSC's experience) reveal that the contamination includes lubricating oils. Personnel interviews of TDX personnel that used to work at the plant and the Public Works Department revealed that the grounds around the former rendering plant were previously used as a staging area for drums containing fuel oil and lubricating fluids. Ray Dronenburg
1/31/1993 Update or Other Action Estimated Cleanup Schedule and costs for Pribilof Islands Cleanup (In Jan. 1993 dollars -- Out years not adjusted for inflation). Activities include: Preliminary Assessment, Site Investigation, Remedial Investigation/Feasibility Study scoping, Site Characterization, Develop and Screen Alternatives, Treatability Investigation, Detailed Analysis of Alternatives, Selection of Remedy, Remedial Design, Remedial Action Capital Costs, Post Project Activities O&M Costs (5 Years), and Administrative Costs (10% of all costs FY92-FY09). Estimated time: 17 years (2010) and $190,000,000. Ray Dronenburg
2/28/1993 Update or Other Action Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV). 1989, a diesel seep was discovered along the shoreline of the Salt Lagoon near the former seal carcass rendering plant. During the E and E visit, petroleum contaminants still appeared to be seeping into the Salt Lagoon. A sheen was visible on the water, but the boom appears to be supplying proper containment (E and E 1992). The 200 drums Oil Spill consultants found in 1992 adjacent to the former seal carcass rendering plant were removed by the City of Saint Paul in 1992 and staged in a containment area in the City's current tank farm. Drums allegedly belong to NMFS. The drums were rusted and located on wooden pallets on top of a plastic liner. Diesel appears to be directly seeping into the Lagoon due to tidal fluctuations influencing the GW/surface water interaction at the shore of the Lagoon. Recommendation: define the extent of POL contamination. Jennifer Roberts
5/13/1993 Meeting or Teleconference Held Pribilof Island Conference meeting minutes. Saint Paul Diesel seep: Sampling throughout the diesel seep area was done late this spring. The contractor has not yet submitted his report of sample analysis, which will guide us on the next steps. Ray Dronenburg
9/30/1993 Update or Other Action U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report. Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. Ray Dronenburg
10/1/1993 Update or Other Action City of Saint Paul Public Notice to: Contractors/Regulatory Agencies. The City of Saint Paul hereby notifies you of the potential presence of hazardous materials on the island. The attached maps should be used as a general reference for identification of potential hazardous materials in planning your project. For the proposed utility projects within the Harbor Area planned for construction during the summer of 1993, the City does not believe that any hazardous materials are present. However, landowners and contractors are responsible for assuring compliance with federal and state regulations and should not rely on information provided herein. If contractors on City Projects (and/or City Property) or on projects which are to become property of the City, believes that hazardous materials may or have been encountered, they must immediately cease any and all construction activity, immediately notify the Public Works Director and City Manager orally and in writing and comply with the attached guidelines. No further construction work can be done unless explicitly authorized in writing by the Public Works Director and City Engineer. City of Saint Paul Hazardous Materials Procedures- 1) Review attached maps. If project includes construction within areas noted as potentially contaminated or if you encounter potential environmental contamination during construction, the following procedures must be followed: 2) Notify NOAA and the City of the potential problem; 3) conduct standard ADEC screening tests and provide in writing at a minimum-to NOAA and the City: a) exact location of area and land ownership, b) Quantity of material, c) Characteristics of material and contamination, d) documentation the contractor has certified persons to 1) conduct screening tests and 2) handling and disposal of hazardous wastes, e) Provide a detailed cost estimate for the initial screening, stockpiling, and testing of the material including labor, materials, equipment, testing, etc, f) provide a schedule for the final removal of any stockpiled materials, g) identify the location and specifications for stockpiling the materials. 4) If the material does not appear to require remediation according to ADEC and EPA regulations, the City Engineer and City Public Works Director will authorize the construction to proceed. 5) If the initial screening per ADEC and EPA regulations indicates that the material must be stockpiled for further testing (NOTE to file states Should not be removed until an approved plan is submitted), then the contractor must comply with the protocol approved by NOAA and the City. At a minimum, this protocol would include the stockpiling of excavated materials, the placement of an impermeable liner in the construction utility corridor, the installation of utility lines covered with non-contaminated materials, and the testing of stockpiled materials for analysis and disposal per ADEC and EPA regulations. For additional information see site file. Ray Dronenburg
10/19/1993 Update or Other Action Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation. Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it. The current construction season has passed, to allow us the necessary time to schedule the equipment, NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May, 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. Ray Dronenburg
7/5/1994 Update or Other Action Woodward Clyde Consultants June 1994 plan received for the "Corrective Action Plan for the Salt Lagoon Diesel Seep Site." Recommendations include a phased approach for the option of excavating the contaminated soil to remove the source and stockpile contaminated material for a season prior to initiating soil treatment process. Long-term stockpiling will be necessary and NOAA proposes to stockpile it at the Blubber Dump site which is property owned by NOAA. The Blubber Dump once received seal carcass wastes, and has since been covered with scoria. Document recommended on-island bioremediation with a prior bench scale or pilot test to show that it is feasible before full implementation. Finally, two potential alternatives were identified; use remediated soil as landfill cover at the existing or proposed new city landfill OR use the remediated soil in conjunction with the proposed airport upgrade project. The soil may be suitable for subgrade material or base course material under the proposed A-C pavement to cover the runway and taxiway areas. Ray Dronenburg
9/1/1994 Update or Other Action Woodward Clyde Technical Scope of Work for Contaminated Soil Excavation and Stockpiling received for the Salt Lagoon Diesel Seep. Contractor to excavate and stockpile petroleum contaminated Salt Lagoon Seep site on Saint Paul Island. 6,650 cubic yards are estimated to be excavated, transported to a designated stockpiling area, stockpiled in accordance with ADEC guidance for long-term stockpiling. Plan called for verification that all contaminated diesel range organic soil above 200 mg/kg to be excavated and one sample per 600 lineal feet of excavation bank be taken (or 1 per 240 square feet of exposed bank) or approximately 18 lab samples from the sidewalls, at just above the water table. Ray Dronenburg
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. NOTE To file: SEC. 120. FEDERAL FACILITIES.(a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.— (1) IN GENERAL.—Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act. Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107. (2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.— All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act. (3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States. (4) STATE LAWS.—State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. Jennifer Roberts
4/24/1995 Update or Other Action Final Report for the "Contaminated Soil Excavation and Stockpile" by Oil Spill Consultants dated April 17, 1995 received. Excavated area was extended to the maximum boundaries cited in the Corrective Action Plan dated August 1994. 9,000 cubic yards of soil removed and stockpiled. Lab results confirmed that the DRO level at all sample points along the north (wetland) and south (concrete ramp) boundaries was less than the 200 mg/kg threshold. DRO levels in the 5 foot buffer strip exceed 200 mg/kg. Sample point B collected on 11/9/1994 4' 6" depth closest to the buffer strip had 13,700 mg/kg DRO (extractable petroleum hydrocarbons) and TPH at 12,200 mg/kg. Confirmatory lab samples taken for the east project boundary (275' from the Salt Lagoon tidal channel shoreline) showed sample point EW Zone 10-3 had 22,900 mg/kg DRO which is several orders of magnitude above 200 mg/kg threshold. CAP allowed for the contaminated soil to be left in place to prevent the collapse of the 5' buffer strip from the salt lagoon. Tidal fluctuation is part of the remedial design to "eventually" reduce the DRO level in the buffer zone. NOTE that the COE environmental assessment showed that the breakwater design reduces the flushing action of the tidal influence for the Salt Lagoon to lower levels thus negating the effects of tidal fluctuation on the DRO contaminants in the buffer zone. NOAA Letter dated April 20 1995 from Thanh Minh Trinh Pribilof Project Manager to Ray Dronenburg stated that two hundred feet of harbor and absorbent booms were installed to capture all the diesel/hydrocarbon products which might be released from the project area. NOTE diesel sheen is being released to the project area despite the booms and absorbents. These booms will remain in place until the release of diesel/hydrocarbon products has permanently stopped. Ray Dronenburg
8/2/1995 Update or Other Action (Old R:Base Action Code = TBIO - Treatment, Bio-remediation). Hart Crowser doing sampling plan to determine characterization of stockpile prior to moving to remediation site from temp stockpile. Ray Dronenburg
8/11/1995 Site Ranked Using the AHRM Site reranked. Values changed: Quantity from 2 to 4; Site Access Value from 2 to 3; GW Exposure Index Value from 1 to 0.4; SW Usage Value from 0.5 to 0.2; SW Exposure Index Value from 0.4 to 0; and, SW Environments from 2 to 5. New score = 78. Ray Dronenburg
11/2/1995 Update or Other Action No Further Action Required Letter sent stating site has been remediated to DEC's satisfaction. Excavation of 9,000 cubic yards was possible by leaving a buffer strip to prevent saltwater intrusion from lagoon. Any continued sheen will be addressed between a contract in place between City of Saint Paul and NOAA to maintain floating boom until sheen no longer exists. NFAR letter rescinded since boom and sorbent is no longer effective at containing the diesel sheen from impacting the surface water quality of the Salt Lagoon on 11/01/1999. Ray Dronenburg
11/15/1995 Update or Other Action (Old R:Base Action Code = RARR - Remedial Action Report Review (CS)). No further action required for cleanup of this site letter sent to RP by ADEC. 9,000 cubic yards of contaminated soils still stockpiled. Site not to be closed until fate of stockpile addressed. Ray Dronenburg
3/1/1996 Update or Other Action 9,000 cubic yards contaminated soil stockpile still to be dealt with before the site will be closed. Ray Dronenburg
3/29/1996 Site Number Identifier Changed Reckey 1994250135401 was duplicate of this site. Combined data from this Reckey into 1989 Reckey. Ray Dronenburg
3/29/1996 Update or Other Action Site has also been referred to as Reckey 1991250127503 by Bruce Erickson. Ray Dronenburg
5/28/1997 Update or Other Action The Department sent letter to Diana M. Josephson Deputy Under Secretary NOAA regarding the Dept. Of Commerce's Report to Congress entitled: "Secretary's Report on the Pribilof Islands as required by Public Law 104-91" dated March 17, 1997. The Department did not receive a draft of the report until after April 7, 1997, well after its presentation to Congress. The Department has concerns with the report, in particular, section H of the report, entitled "Environmental Cleanup". The Department does not agree with the report's statement on page 33 that "...to date, no ongoing sampling has revealed contamination posing a threat to human health, or the environment." Summer 1989 NOV issued for contamination caused by visible oil "sheening" to a sensitive sea bird nesting area known as the "Salt Lagoon". After long delay and an unsuccessful attempt by NOAA to mitigate the problem, a 2nd NOV was issued on March 3, 1994. This second notice was for a continued release of petroleum contamination to the lagoon and for spills of oil products from approximately 400 stockpiled fifty-five gallon drums. Soils that are contaminated with diesel range organics up to 93,000 parts per million have been excavated and stockpiled for future remediation. More than 9,000 cubic yards of soil were removed from the diesel seep salt lagoon site and the site is boomed with a slight sheen appearing on the water continues to violate water quality standards. It is estimated that more than 30,000 cubic yards of contaminated soil remain on St. Paul and 10,000 cubic yards on St. George remain which need excavation and treatment. The report's assertions appear to conflict with the spirit and intent of the "Two-Party Agreement" signed by ADEC and NOAA after lengthy negotiations by both sides. To date, NOAA has committed more than twelve (12) million dollars for restoration work on the islands for fiscal year 1997. However, the balance of funds authorized by Congress for the restoration work was not included by NOAA as a line item appropriation in the President's FY 1998 budget submitted to Congress. Ray Dronenburg
7/18/1997 Update or Other Action NOAA letter to Commissioner Michele Brown Re: letter regarding the Secretary's Report to Congress on the Pribilof Islands. NOAA states: the TPA addresses all applicable state and federal environmental laws and regulations. To date, NOAA is in compliance with all requirements of that agreement, and we know of no disagreement regarding the nature and extent of contamination related to cleanup under its terms. The language in the Report regarding the finding of "no contamination posing a threat to human health and the environment" relates to HAZARDOUS SUBSTANCES under the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). In this context, the statement regarding contamination in the Report is correct. As directed by Public Law 104-91, the Report was directed to include the statements of the State of Alaska. At the direction of the Governor's Office, State review and comment was coordinated through Mr. Tim Towarek of the Office of Rural and Community Development. A draft was distributed to Mr. Towarek on February 2, 1997. The official response, through Commissioner Mr. Cotten of the Governor's Office was received on March 14, 1997. The Report was delivered to Congress on March 18, 1997. NOTE TO FILE: 18 AAC 75 Contaminated Sites regulations and A.S. 46.03 defines “hazardous substance” has the meaning given in AS 46.03.826 which defines a "hazardous substance" as (A) An element or compound which, when it enters into the atmosphere or in or upon the water or surface or subsurface land of the state, presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, animals, vegetation, or any part of the natural habitat in which they are found; (B) Oil (“oil” has the meaning given in AS 46.04.900);) "oil" means oil of any kind and in any form, whether crude, refined, or a petroleum by-product, including but not limited to petroleum, fuel oil, gasoline, lubricating oils, oily sludge, oil refuse, oil mixed with other wastes, crude oils, liquefied natural gas, propane, butane, or other liquid hydrocarbons regardless of specific gravity; or (C) A substance defined as a hazardous substance under 42 U.S.C. 9601(14); “hazardous waste” means waste within the scope of 18 AAC 62.020. Ray Dronenburg
7/22/1997 Update or Other Action TDX Letter to NOAA regarding the Report to Congress on the Pribilof Islands required by public law 104-91. 1) The NOAA report characterizes the Salt Lagoon Diesel Seep (TPA 13-1 STP) as a "small oil spill". This spill required months of work to excavate and cleanup, with NOAA stockpiling over six thousand cubic yards of highly contaminated soil for future remediation. Even after the removal of soils and replacing with clean backfill, the site continues to seep oil into the environmentally sensitive Salt Lagoon. ADEC requires NOAA to continually maintain an absorbent boom around the site to prevent the spread of contamination into the Salt Lagoon. Therefore, it is likely that the Salt Lagoon Diesel seep will require continuous monitoring for many years due to ongoing leaching from the buffer area remaining at the site. 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
4/1/1998 Update or Other Action Corps of Engineers Environmental Assessment and Finding of No Significant Impact April 1998 received. Dredging of existing entrance channel to the Salt Lagoon to a depth of 3 feet mean lower low water and a width of 40 feet at the invert of the channel. Approximately 24,000 cubic yards of material will be dredged from the entrance channel and sediment basin. City of Saint Paul has indicated that they will use the material for road grading and has provided an upland storage site near their maintenance shop and tank farm. Ray Dronenburg
2/22/1999 Update or Other Action This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. Ray Dronenburg
5/11/1999 Update or Other Action ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation. Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard. Louis Howard
9/10/1999 Update or Other Action Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. Jennifer Roberts
9/28/1999 Site Ranked Using the AHRM Site reranked. New score=70.4. Louis Howard
9/30/1999 Update or Other Action Name changed to match names used in the Two Party Agreement site names. Louis Howard
11/1/1999 Update or Other Action Letter sent reopening site for additional investigation and corrective action to deal with seep entering into salt lagoon. Surface water continues to be impacted and boom/sorbent is not dealing with sheen adequately. Louis Howard
7/10/2000 Report or Workplan Review - Other Staff sent concurrence letter to NOAA regarding NOAA facsimile sent on June 15, 2000. ADEC agrees with the approach of reevaluating the effectiveness of the oil boom at the Two-Party Agreement Site Number 13-1 Salt Lagoon Diesel Seep. ADEC looks forward to reviewing and providing comments on the draft site characterization plan and corrective action plan once they are developed by NOAA. Louis Howard
7/25/2000 Update or Other Action Staff requested all of NOAA's budget requests made to congress since the agreement was signed in 1996 by both ADEC and NOAA for the environmental cleanup at the Pribilofs. It has come to DEC's attention that NOAA did not make a formal request for funding to Department of Commerce for FY 01 and possibly FY02 (federal fiscal years). This is not in compliance with the TPA which requires NOAA to request adequate funding to meet its obligations under the TPA. NOAA was counting on the U.S. congressional delegation to fund 12 million dollars as a special appropriation for the Pribilofs. The appropriation was much less-3 million dollars for October 2000 to September 2001. Deadline for NOAA to provide a written response was no later than August 18th. Louis Howard
7/27/2000 Update or Other Action NOAA sent in an electronic copy of the site characterization plan for the diesel seep. Hard copy to follow in the mail. Purpose of the SCP is to outline the strategy, rationale, and procedures that will be used to characterize the conditions at the Diesel Seep area. Staff commented on the SCP. Louis Howard
8/17/2000 Update or Other Action Staff sent comment letter to NOAA regarding draft site characterization plan TPA 13-1 Diesel Seep Site July 2000. The text states that the site characterization plan (SCP) has been developed and implemented in accordance with applicable ADEC regulations 18 AAC 75.335, Site Characterization. This may be true with regards to site characterization at the site, however other sections of 18 AAC 75 Oil and Other Hazardous Substances Pollution Control, 18 AAC 70 Water Quality Standards and 18 AAC 80 Drinking Water Standards are also applicable, relevant and appropriate. ADEC will also require NOAA to determine the extent to which groundwater contamination exceeds the Table C values in 18 AAC 75.345 at the site. The text states the SCP will determine cleanup levels to prevent continued significant, on-going sheening. NOAA shall also ensure that the cleanup at the site will not cause violations of the standards found in 18 AAC 70 “Alaska Water Quality Criteria” in the surface water at the site and the surface water and groundwater cleanup levels found in 18 AAC 75.345 Table C for surface water and groundwater at the site. Preventing a sheen, discoloration, or film from occurring on the surface or floor of the water body or adjoining shorelines is just one of the Alaska Water Quality Standards NOAA must meet. Target cleanup levels have already been established in ADEC regulations besides the sheening criteria mentioned throughout the SCP. Namely, 18 AAC 70.020(b) Protected Water Use Classes and Subclasses; Water Quality Criteria: Water Quality Standards Table identifies criteria that must be met in marine waters. The text states that soil concentrations will be compared to target cleanup levels designed to eliminate sheening. For the contaminated soils found at the site, NOAA shall meet cleanup levels established in 18 AAC 75.340 and 18 AAC 75.341. Specifically, NOAA shall meet cleanup levels for DRO, GRO, RRO found in Table A1 if NOAA is pursuing cleanup under Method One. If NOAA chooses to use cleanup Method Two or Method Three, the applicable petroleum hydrocarbon cleanup levels must be met in addition to the applicable chemical-specific cleanup levels for benzene, toluene, ethylbenzene, and total xylenes (BTEX); the chemical-specific cleanup levels for the polynuclear aromatic hydrocarbons (PAHs) acenaphthene, anthracene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, chrysene, dibenzo(a,h)anthracene, fluorene, indeno(1,2,3-c,d)pyrene, naphthalene, and pyrene must also be met unless ADEC determines that those cleanup levels need not be met to protect human health, safety, and welfare, and the environment. For additional information see site file. Louis Howard
9/20/2000 Update or Other Action Staff sent letter on Waiver Request for Stockpile Cover Installation on Stockpiles associated with the Enhanced Thermal Conduction System on the Pribilof Islands dated September 19, 2000. ADEC is aware of the problems and unforeseen circumstances NOAA has had to deal with remediation the soil stockpiles on the Pribilofs. Based on a review of the information presented by NOAA, ADEC will grant a one-time waiver for stockpile cover installation at both islands for stockpiles associated with this specific remediation effort. This waiver is contingent upon NOAA treating all the remaining stockpiles to level “A” cleanup criteria and the most stringent cleanup criteria for: benzene, ethylbenzene, toluene, and total xylenes listed in 18 AAC 75.341. If NOAA fails to remediate all the soils in the 2001 field season, then ADEC will require NOAA to cover its remaining stockpiles with a synthetic membrane material designed to withstand the extreme weather conditions on the Pribilofs. Stockpiles generated during future investigation, removals, or cleanup work by NOAA (including NOAA’s Compliance program) shall not be eligible for this waiver and be required to meet the requirements for stockpiles listed in 18 AAC 78.274. Louis Howard
12/12/2000 Update or Other Action Site information update by staff from files. Louis Howard
12/14/2000 Update or Other Action Staff sent letter to NOAA regarding Notification of possible Force Majeure (per the TPA). The Alaska Department of Environmental Conservation (ADEC) has received the above document via facsimile from NOAA on December 5, 2000. The document states that in accordance with Paragraph 67 of the Two Party Agreement, the potential exists for a Force Majeure situation. It further states that unless further Pribilofs Cleanup Funds are appropriated to NOAA for FY01, the project budget will be exhausted this fiscal year. We very much appreciate your providing this information and analysis of NOAA’s anticipated plans in FY 01 given the existing funding situation. ADEC realizes that funding is uncertain due to Congress not yet finalizing a budget for this FY01. We anticipate a meeting with NOAA to discuss potential impacts to the Pribilof Islands Environmental Restoration Agreement when Congress finalizes a budget. Louis Howard
3/28/2001 Update or Other Action Staff sent NOAA comment letter on TPA revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter. 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.” With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows: 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. 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. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. Louis Howard
5/29/2001 Update or Other Action NOAA tasked CESI with removing the UST and its appurtenances from the site, as well as any PCS. CESI removed the UST and appurtenances on August 24, 2000. CESI observed the tank in good condition, with minimal corrosion and no holes. CESI observed visual and olfactory evidence of releases in shallow soils around the fill pipe, but did not observe evidence of releases in the deeper excavation soils (i.e., to 6 ft bgs). Available documentation does not indicate the size of the UST, however, other NOAA sites on St. Paul Island normally used 1,000-gallon capacity USTs for heating oil storage. CESI collected five confirmation samples from the excavation: one sample from the bottom of the excavation and one sample from each of the four excavation sidewalls. All five confirmation samples were below their closure standards. One should note that CESI did not survey the locations of each confirmation sample location, so their locations are approximate and are based on CESI’s report text. One should also note the sample from the west sidewall, which is closest to the Combine Shop building, contained DRO at 340 mg/kg. This value is below the site cleanup level of 1,000 mg/kg, though it is above the ADEC Method Two DRO cleanup level of 250 mg/kg. Louis Howard
2/11/2002 Update or Other Action ADEC Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002. The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “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. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season. *Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year. The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment. With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the 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) Sec. 107(f)(2). For additional information see site file. Louis Howard
3/26/2002 Update or Other Action ADEC Staff reviewed and commented on the Draft Site Characterization Report Salt Lagoon Diesel Seep TPA Site 13 St. Paul Island February 2002 Project 823255.05030000. The text states surface water samples were analyzed by Alaska Methods 101, 102, 103, EPA Methods 8260B and 8270C. In addition to these methods, future analyses at this site must include, at a minimum, methods for total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) listed in Alaska Water Quality Criteria (AWQC) 18 AAC 70. Samples to determine concentrations of TAH and TAqH must be collected in marine and fresh waters below the surface and away from any observable sheen. Concentrations of TAqH must be determined and summed using a combination of: (A) EPA Method 602 (plus Xylenes) to quantify monoaromatic hydrocarbons and to measure TAH; and (B) EPA Method 610 to quantify polynuclear aromatic hydrocarbons. Use of an alternative method requires ADEC prior approval. The EPA methods may be found in 40 C.F.R. 136, Appendix A, as amended as of February 14, 1996, adopted by reference. They may be reviewed at the ADEC or are available from the Office of Monitoring Systems and Quality Assurance, Office of Research and Development, United States Environmental Protection Agency, Washington, D.C. 20460. The AWQC that are applicable at the site are found in 18 AAC 70.020(b) Protected Water Use Classes and Subclasses; Water Quality Criteria: Water Quality Standards Table. For petroleum hydrocarbons, oils and grease in marine waters where the “growth and propagation of fish, shellfish, other aquatic life and wildlife” occurs, the water quality standards state: “Total aqueous hydrocarbons (TAqH) in the water column may not exceed 15 ug/L. Total aromatic hydrocarbons (TAH) in the water column may not exceed 10 ug/L. There may be no concentrations of petroleum hydrocarbons, animal fats, or vegetable oils in shoreline or bottom sediments that cause deleterious effects to aquatic life. Surface waters and adjoining shorelines must be virtually free from floating oil, film, sheen or discoloration.” The ADEC requests including AWQC in all future documents for this site. At a minimum, they must include: TAH, TAqH and indication of whether or not a sheen was present in the surface water, shoreline or floor of the waterbody (i.e. sediment surface whether exposed or not at low tide). The text states DB02 and DB11 had a sheen present or when disturbed caused a sheen to appear in the surface water. It must be noted this sheen observed in the surface water is a violation of 18 AAC 70 Alaska Water Quality Criteria. The text indicates one well MWDS-3 has DRO contamination above Table C cleanup level of 1,500 micrograms per liter (ug/L). The ADEC wishes to inform NOAA that it must compare monitoring well results to surface water quality criteria as well (e.g. TAH and TAqH). 18 AAC 75.345 (f) states: Groundwater that is closely connected hydrologically to nearby surface water may not cause a violation of the water quality standards in 18 AAC 70 for surface water or sediment. ADEC contends that groundwater at TPA 13 is closely connected hydrologically to surface water (Salt Lagoon). See section 1.1, 1st paragraph and section 5, 3rd paragraph of the document for discussion on groundwater elevation being dependent on the tide. The ADEC requests future documents and monitoring efforts include AWQC (e.g. TAH and TAqH). For additional information see site file. Louis Howard
8/13/2002 Update or Other Action Staff reviewed and commented on the work plan for sampling and disposal of contaminated sediment under the Corps of Engineers Project for harbor improvements. The Department requests clarification regarding whether or not the project will store the dredged material for 180 days or more. Liner specifications are listed below for the short term storage (less than 180 days) or long term storage (180 days to not more than two years). Staff stated that Testing Option 1 will also require that analytical testing be conducted at an ADEC certified laboratory for gasoline range organics, diesel range organics and residual range organics will be with AK methods 101, 102, and 103, respectively. Louis Howard
3/10/2003 Update or Other Action Staff reviewed and commented on the Soil Gas Survey report for St. Paul Island which included this site (other sites in the survey were: Cascade Building, Community Garage and ATCO Building). The Department wishes to state that the use of soil gas surveys regardless of sample collection technique is regarded as a screening device. Samples analyzed with field screening devices may not be substituted for required laboratory samples (UST Procedure Manual November 2002). Soil gas surveys will allow for more focused site investigations by indicating the area where the contamination is likely to be present. Additional Work Page 49 The text states a more complete soil gas survey in the area of the Community Garage and Cascade building would help clarify the degree and extent of contamination. These two sites benefit more by NOAA conducting a focused site investigation using traditional soil sampling/screening in areas indicated as being contaminated by the soil gas survey. Louis Howard
3/30/2004 Update or Other Action Staff received and reviewed NOAA's request to discharge of treated water generated during excavation of St. Paul Island Diesel Seep (Sites 34 and 35, Two-Party Agreement Sites 13a and 13b). After reviewing the information presented in the request, the Department will approve the request to discharge the oil-water separator treated water back into the open excavation at the Diesel Seep site from which the water originated. This approval is a one-time approval and specifically applies to this site. The Department concurs that any water removed from the excavation or removed from the excavated soil will be treated in the oil-water separator, which will make it cleaner than the water remaining in the excavation, and will reduce the overall contamination remaining at the site. Louis Howard
4/29/2004 Update or Other Action The Department has reviewed NOAA's proposed sampling frequency deviation from guidance for TPA 13-1 (A and B) Uplands and Channel of the Diesel Seep Salt Lagoon site (CS Database reckey# 1989250115201). The Department concurs with all of the proposed changes and this is a one-time approval for this particular site. Any future exceptions would be reviewed on a site by site basis and have to be submitted by NOAA to the Department for its review and comment. Louis Howard
5/19/2004 Update or Other Action Staff reviewed and approved the draft corrective action plan. The Department has reviewed the plan and will approve it as a final version. The National Oceanic and Atmospheric Administration (NOAA) is responsible for the actions of contractors, agents, or other persons who perform work to accomplish the approved plan. For any activity that significantly deviates from the approved plan, NOAA shall notify the Department to obtain written approval in the form of a work plan amendment before beginning the activity. Any action taken by NOAA or its agent that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for an amendment is the responsibility of the Department. The Department’s review and comments are to ensure the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our comments do not relieve NOAA employees, contractors, or subcontractors from the need to comply with other applicable laws and regulations. Louis Howard
6/23/2004 Update or Other Action In June 2004, Kelly-Ryan Inc. (KRI), as part of the Corps of Engineers Phase II Harbor Improvements Project, collected a total of five near-surface soil samples within Tract 50 to represent site conditions prior to their use of Tract 50 for the Harbor Improvement Project staging and sediments dewatering. One of KRI’s soil samples, located within the footprint of the former drum platform foundation, contained DRO above its ADEC Method Two cleanup level. Samples exceeding the ADEC Method Two DRO cleanup level were collected from the bottom of the excavation, near the groundwater interface. Hence, further excavation in these areas was not practicable. Groundwater data for the adjacent Diesel Seep Site (Sites 34 and 35/TPA Sites 13a and 13b) indicates that groundwater flow is from the east to the west (CESI 2001). Groundwater throughout the Diesel Seep Site is found at approximately +3.0 feet mean lower low water. Louis Howard
7/7/2004 Update or Other Action Staff approved alternative protective measures provided by NOAA to ensure that the contaminated soils would not leave the dump truck beds during transport from the Salt Lagoon to the stockpile site. Louis Howard
7/25/2005 Update or Other Action Tract 50 Drum Platform (NOAA site 58) is the former location of a seal carcass byproducts plant dating back to 1918. The byproducts plant ceased operation once government management of commercial fur sealing ended in the early 1980s. The Tract 50 Drum Platform Foundation Site is located just east of the Salt Lagoon Channel and north of the Tract 50 National Oceanic and Atmospheric Administration (NOAA) administrative structures. In 2004 NOAA removed 575 cubic yards of above grade petroleum contaminated soil from the site and the demolition of the drum platform foundation. During excavation of below grade, groundwater was consistently found at 3-4 ft. bgs. Excavation stopped at the water table. NOAA removed an estimated 752 cubic yards of below grade PCS. PCS was removed to the maximum extent practicable. In addition to PCS, roofing tar was removed from the site in 55 gallon drums and Supersacks. Six drums of tar was disposed of with Waste Mgt. Inc. (Columbia Ridge landfill) in Arlington OR. Tar-soil in Supersacks were disposed of with Rabanco in Seattle WA. PCS was sent to Tract 42 PCS stockpile or to NOAA/NMFS land spreading area. Louis Howard
8/17/2005 Long Term Monitoring Established Staff reviewed and commented on the Draft Corrective Action Report Sites 34 and 35/Two-Party Agreement Sites 13a and 13b Salt Lagoon Diesel Seep. ADEC concurs with monitoring for sheen in surface water during the same time as groundwater monitoring, however, ADEC recommends that NOAA inspect for sheen whenever its staff are present on St. Paul Island and not just at the time of groundwater sampling. Written documentation of these additional inspections of surface water over time (e.g. three years) for sheen at the Salt Lagoon site will help in the removal of this waterbody from the State’s "impaired water body” list (eff. February 13, 2004). Currently, the Saint Paul Island Lagoon (AK ID Number 30104-601) is a Category 5 Waterbody-Impaired by pollutant(s) for one or more designated uses and it is placed on the 2003 Section 303(d) list for the Petroleum Hydrocarbons, Oil & Grease standard for petroleum products (sheen). ADEC reserves all of its rights, under A.S. 46.03, 18 AAC 75, and 18 AAC 78 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions deemed appropriate by the Department at TPA sites 13a and 13b (Salt Lagoon Diesel Seep) if information becomes available that contamination is present which poses an unacceptable risk to human health or safety, welfare, or the environment or a violation of water quality criteria is detected at the site (e.g. sheen). It is ADEC’s understanding a separate request for no further remedial action will be forthcoming from NOAA shortly. Louis Howard
8/17/2005 Institutional Control Record Established Institutional controls on site placed for excavation restrictions in area where granulated active carbon barriers were placed since these barriers are required for treatment of groundwater prior to discharge to the salt lagoon. Louis Howard
2/13/2006 Conditional Closure Approved 2004 9,234 cubic yards of contaminated soil removed from site, two granulated activated carbon barriers placed to address petroleum contaminated groundwater before it reaches surface water, salt lagoon channel bank rebuilt using rock, sand, filter fabric, topsoil, vegetation and erosion control matting. NOAA has removed the maximum amount of soil practicable and could not excavate any further due to groundwater and sloughing of excavation sidewalls. Monitoring of groundwater and surface water is ongoing and in-situ treatment of the groundwater is occurring by the GAC barriers. No further remedial action is warranted at the site. ADEC reserves the right to require NOAA to perform additional containment, investigation, or cleanup if subsequent information indicates that the level of contamination that remains does not protect human health, safety, or welfare, or the environment. Louis Howard
2/13/2006 Update or Other Action NOAA sent a request for NFRAP designation at the site to ADEC. ADEC concurred. In accordance with Paragraph 59* of the Two Party Agreement, this is to confirm that all corrective action has been completed at the Salt Lagoon Diesel Seep, NOAA Sites 34 and 35/TPA Sites 13a and 13b in accordance with the Agreement and that no plan for further remedial action is warranted. However, please note that DEC reserves all of its rights under 18 AAC 75 and AS 46 to require NOAA to conduct further investigation and/or remedial action if information indicates conditions at the Decommissioned Power Plant Annex TPA Site 9d/Site 19 pose a risk to human health, safety and welfare, and the environment. *NOTE: Paragraph 59- Closure of Sites of Operable Units 59. At any time while this Agreement is in effect, NOAA may request from ADEC written confirmation that all corrective action has been completed at a site(s) or operable unit(s) in accordance with this Agreement. Within thirty (30) Days of its receipt of such request. ADEC shall: (1) provide written confirmation that no further corrective action is required at the subject site(s) or operable unit(s): or (2) deny such request and provide a written explanation of the technical bases on which the request is denied. ADEC shall not deny certification that corrective action is complete at any site(s) or operable unit(s) solely on the basis that post-remedial measures, such as monitoring, shall remain in place for a period of months or years. Louis Howard
4/28/2008 Update or Other Action Staff reviewed and commented on the Annual Groundwater Monitoring Report for St. Paul Island. The report documents sampling of groundwater from thirty-six (36) wells at five (5) areas on St. Paul Island. These areas are City of St. Paul Old Village (a.k.a. Tract 46), Diesel Seep (Salt Lagoon Diesel Seep a.k.a. TPA Site 13), Icehouse Lake (a.k.a. TPA Site 14), St. Paul Municipal Landfill Area (a.k.a. TPA Site 5) and the National Weather Service Landspreading Area Site. ADEC requests NOAA add an approximate indicator of groundwater direction to all figures with groundwater monitoring wells in future report submittals. There is also new ADEC monitoring well guidance out “Monitoring Well Design and Construction for Contaminated Sites” (February 2008) which can be found at http://www.dec.state.ak.us/spar/guidance.htm The text indicates one of the monitoring wells was covered with soil. ADEC requests NOAA identify procedures it has put in place to prevent this from happening in the future and/or notification to local entities regarding the importance of not burying existing monitoring wells with fill material. Louis Howard
4/28/2008 Update or Other Action Staff reviewed and commented on the Annual Groundwater Monitoring Report for St. Paul Island. The report documents sampling of groundwater from thirty-six (36) wells at five (5) areas on St. Paul Island. These areas are City of St. Paul Old Village (a.k.a. Tract 46), Diesel Seep (Salt Lagoon Diesel Seep a.k.a. TPA Site 13), Icehouse Lake (a.k.a. TPA Site 14), St. Paul Municipal Landfill Area (a.k.a. TPA Site 5) and the National Weather Service Landspreading Area Site. ADEC requests NOAA add an approximate indicator of groundwater direction to all figures with groundwater monitoring wells in future report submittals. There is also new ADEC monitoring well guidance out “Monitoring Well Design and Construction for Contaminated Sites” (February 2008) which can be found at http://www.dec.state.ak.us/spar/guidance.htm The text indicates one of the monitoring wells was covered with soil. ADEC requests NOAA identify procedures it has put in place to prevent this from happening in the future and/or notification to local entities regarding the importance of not burying existing monitoring wells with fill material. Louis Howard
5/1/2008 Update or Other Action NOAA files with the Alaska Dept. of Natural Resources a notice to deed # 2008-000209-0 Recording District:305-Aleutian Islands 5/1/2008 7 pages. Notice of Environmental Cleanup and Groundwater Contamination at TPA 3, Salt Lagoon Diesel Seep, St. Paul Island, Alaska. Pursuant to 18 AAC 75.375, Tanadgusix Corporation as the owner, and the U.S. Department of Commerce/National Oceanic and Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice that the property located 0.65 miles N. of the City of St. Paul on the west side of Polovina Turnpike and on the east shore of the Salt Lagoon Channel, St. Paul Island, Alaska 99660 is contaminated with petroleum products. More specifcally, the site described as follows: Township 35 South, Range 132 West, Lot 1, Section 25 of the Seward Meridian, Alaska; Patent No. 50-90-0669 Tanadgusix Corporation, 57 degrees, 7 minutes, 44.90 seconds North Latitude; 170 degrees, 16 minutes, 31.95 seconds West Longitude (Figures 1 and 2) has been subjected to petroleum contaminated soil and groundwater contamination, as a result of a discharge, or release and subsequent cleanup of oil or other hazardous susbstances, regulated under 18 AAC 75, Article 3 as amended October 2005. If contaminated soil or solid wastes are exposed in the future, they must be managed in accordance with laws applicable at that time. These releases and cleanup are documented in the Alaska Department of Environmental Conservation (ADEC) contaminated sites database under the site number CS Reckey # 1989250115201; File ID 2644.38.027. Following corrective action , NOAA submitted a request for conditional closure to ADEC. NOAA's request stated further cleanup was impracticable because contaminated soils remained within the saturated zone or within areas with buried demolition debris associated with diesel range organics (and potentially animal fats) on the property (NOAA 2006). ADEC granted a conditional closure, in part subject to this institutional control (deed notice), and confirmed that no further remedial action was required at the site unless new information becomes available that indicates to ADEC that the site may pose an unacceptable risk to human health, safety, welfare or to the environment (NOAA 2006). Grantor, the U.S. Bureau of Land Management Grantees: the Tanadgusix Corporation (grantee of the surface estate), 4300 B Street, Suite 402, Anchorage, AK 99503-5946 The Aleut Corporation (grantee of the subsurface estate), 4000 Old Seward Highway, SUite 300 Anchorage, AK 99503 Recording District: Aleutian Islands This notice remains in effect until a written determination from ADEC is recorded that states that soil and/or groundwater at the site has been shown to meet the most stringent soil cleanup level n Method Two of 18 AAC 75.341(c) and/or groundwater meets the cleanup levels in Table C in 18 AAC 75.345, and that off-site transportation of soil and/or groundwater is not a concern. Louis Howard
6/4/2008 Update or Other Action NOAA and ADEC signed the closure letter for St. Paul Island. In accordance with paragraph 59 of the Pribilof Islands Environmental Restoration Agreement (Two-Party Agreement or TPA) January 1996 by designated officials of the State of Alaska and the National Oceanic and Atmospheric Administration (NOAA), NOAA requested Alaska Department of Environmental Conservation (ADEC), as the duly authorized representative of the State of Alaska, certify NOAA’s completion of corrective action for the St. Paul Island Operable Unit (OU). As of June 4, 2007, the Salt Lagoon Diesel Seep (uplands)TPA Site 13a has drums, contaminated soil associated with either a UST/AST/Pipeline. Site conditions as follows: Residual soil contaminated with DRO and GRO (at one location the level was 310 mg/kg) remains within the smear zone and in the east area among buried concrete rubble associated with the former By-Products Plant; two granular activated carbon reactive permeable walls installed; groundwater monitoring (DRO contamination) until at least October 2008 pending regulatory review; deed notice. Property Owner as of November 6, 2007 is the Tanadgusix (TDX) for the surface estate and The Aleut Corporation (TAC) for the subsurface estate. Jennifer Roberts
12/21/2009 Update or Other Action The National Oceanic and Atmospheric Administration has performed site characterization and restoration on St. Paul Island, Pribilof Islands, Alaska and monitored groundwater for diesel range organics, gasoline range organics, volatile organic compounds, semivolatile organic compounds, metals, and total dissolved solids at monitoring wells located at multiple sites. Contaminants of concern and representative wells were chosen for long-term monitoring at five sites, which include the City of St. Paul, Icehouse Lake, the Diesel Seep near Salt Lagoon, the St. Paul Municipal Landfill, and the National Weather Service Station Landspreading Area/Oil Drum Dump Site. Starting in June 2006, the National Oceanic and Atmospheric Administration Office began long-term groundwater monitoring on a semi-annual basis and contracted Bethel Services, Inc. to continue groundwater monitoring beginning in May 2008. Sampling scheduled for May 2009 did not take place until June 2009 due to fuel shortages on the island. After obtaining concurrence from Alaska Department of Environmental Conservation (ADEC), NOAA directed that six of the 36 monitoring wells be dropped from the program beginning in the spring of 2009; therefore, 30 groundwater monitoring wells located at four sites (City of St. Paul, Icehouse Lake, the Diesel Seep near Salt Lagoon, and the St. Paul Municipal Landfill) were sampled in June 2009. BSI completed groundwater monitoring of the subject monitoring wells between June 9 and June 15, 2009. Presented in this report are the results of the June 2009 St. Paul monitoring well sampling event. Nine wells sampled in June 2009 were found to have contaminants in concentrations exceeding ADEC cleanup levels. Mann-Kendall statistical methods were used to evaluate contaminant trends at 22 of the 30 wells sampled for a total of 45 calculated trends. The analyses incorporated available data from October 2003 to Jun 2009. Of the 45 contaminant concentration trends analyzed, nine met data quality requirements and are useable for the purposes of this report. All other trends had less than a 95% level of confidence, and therefore did not meet the data quality objective (DQO) of a 95% confidence level or greater. The nine trends meeting DQO criteria showed DRO concentrations trending upward at monitoring wells MW46-6 and MWA-3 and downward at monitoring wells MW46-14 and MWIHL-4. The trends showed benzene concentrations trending downward at MW46-5, MW46-6, and MW46-28; total lead concentrations trending downward at MWSNPLF-1; and ethylbenzene concentrations trending downward at monitoring well MW46-5. Additional sampling and analysis will further verify the contaminant trends presented in this report. Factors influencing groundwater contaminant concentrations such as water table variations as related to seasonal changes and sampling location relative to the water table were neglected in the statistical analysis owing to lack of data availability. Though some wells had contaminant concentrations above ADEC cleanup levels these particular wells have historically been contaminated above the cleanup levels. Louis Howard
4/29/2010 Update or Other Action Annual groundwater monitoring report received. The Diesel Seep, also known as the Salt Lagoon Diesel Seep, is near a former marine mammal rendering plant that was located at the southern shore of Salt Lagoon east of St. Paul Harbor. At this location, diesel fuel was released from fuel storage tanks and piping associated with a diesel-powered boiler. Additionally, soil contamination might have occurred from spillage or leakage of fuel during fueling operations. Two monitoring wells have been selected for long-term monitoring of DRO in groundwater. Both of the wells involved in long-term groundwater monitoring at the Salt Lagoon Diesel Seep were statistically analyzed for the presence of and direction in a trend of DRO concentrations. Neither trend met data quality requirements for this project and are not considered scientifically defensible. Louis Howard
11/19/2010 Site Visit NOAA staff (J. Malchow) observed the St. Paul Island Salt Lagoon Channel adjacent to the Diesel Seep Site on November 19, 2010 at approximately 6 pm. The northerly wind was mild with only a slight chop to the water that did not hinder inspection for signs of sheen. Staff observed no signs of oil sheen at the site. Louis Howard
2/10/2011 Update or Other Action Staff received the St. Paul Mid-Year Monitoring Report. The purpose of continued groundwater monitoring on St. Paul is to monitor petroleum hydrocarbon constituents at designated monitoring wells within the City of St. Paul, near Icehouse Lake north of the city, the Diesel Seep near Salt Lagoon, and within the St. Paul Municipal Landfill (NOAA, 2005) and report sampling results. COC include DRO, GRO, and BTEX. Total and dissolved lead are also monitored at Icehouse Lake and the St. Paul Municipal Landfill. In 2000 and 2001, site characterizations were conducted at eight two-party agreement (TPA) sites on St. Paul Island. This project focuses on GW sampling at four of these sites: the City of St. Paul Old Village, Icehouse Lake, Diesel Seep, & the St. Paul Municipal Landfill. In each of these areas, GW wells have been designated for long-term monitoring of hydrocarbon contaminants & lead to establish contaminant trends. NOAA has retained two monitoring wells at the Salt Lagoon Diesel Seep. One well, MWDS-3, due to its location and analytical history has been designated as a sentinel well to monitor potential DRO migration at the edge of the 2004 petroleum contaminated soil excavation. The other well at this site, MWDS-2, is a long-term monitoring well, and is in place to monitor the contamination levels in a known plume. Both wells were sampled during the May 2010 sample event. The following section presents statistical analysis of contaminant concentration trends where data is available and meets the previously described criteria. In the fall of 2004, NOAA completed a major cleanup of the Salt Lagoon Diesel Seep with the excavation/removal of contaminated soil. Because this action changed the static groundwater/contaminant conditions, only analytical results from sampling performed after 2004 were used to perform trend analyses of DRO concentrations at both monitoring wells MWDS-2 and MWDS-3, the results of which are present in Table 5-2. Both monitoring wells exhibited decreasing trends in DRO concentrations. Neither trend meets the data quality requirements for this report and are not considered scientifically defensible. Louis Howard
2/16/2011 Report or Workplan Review - Other Staff reviewed and commented on the Groundwater Monitoring Mid-Year Report 2010, St. Paul Island, Pribilof Islands dated January 2011. The document covers groundwater monitoring for numerous TPA 9 Sites, TPA 11, TPA 14, TPA 13 and TPA 5. There were some issues with cooler temperatures not brought out in the text of the report. The checklist dated December 15, 2010 for laboratory report number 1102474 noted four sampler coolers were sent to the laboratory with temperatures 6.5, 7.1, 7.5 and 3.1 degrees Celsius. The VOA cooler at 6.5 degrees C was marginally above the maximum temperatures. Coolers at 7.1 and 7.5 degrees Celsius contained DRO samples. The report stated: “Data quality of the sample analysis was not affected by the temperature anomalies.” ADEC disagrees. The sample results associated with these three coolers will be used for qualitative purposes and for demonstrating compliance with cleanup levels. Both AK102 and SW8260B require temperatures for samples to be 4o ± 2o C. The DQA St Paul 1102474 DQA 121410, Data Quality Assessment, Sample Management section stated: “There was no ice present in the temperature blank or the samples.” The checklist dated December 15, 2010 for laboratory report number 1102523 stated Samples were preserved and less than 24 hours had passed from the time of collection. ADEC disagrees. DRO sample cooler #2 had 2 samples collected within 24 hours, but 1 sample was collected on June 2, 4 samples were collected on June 1. All were analyzed for DRO and sample receipt form SGS 1102523 noted the temperature blank at 7.8 o C. ADEC disagrees with the statement that the data quality of the semi-volatile sample analysis was not affected by the higher cooler temperature. Data from this cooler will be treated as qualitative data and not to be used for compliance with cleanup levels. *Note for future reference: The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, however, must be retained on file by the laboratory for at least ten years after the analysis date. ADEC has reviewed the document and concurs with the conclusions and recommendations that additional sampling and analysis will further verify the contaminant trends presented in this report. Louis Howard
3/24/2011 Update or Other Action NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island. 1) Diesel Seep Site - Discontinue monitoring/decommission wells MWDS-2 and MWDS-3; continue visual sheen inspection/documentation at adjacent Salt Lagoon Channel. Justification: Long-term sampling began on St. Paul Island in June 2006, since that time DRO (the COC at this site) has never been detected above MRL. Contaminant concentration trend analysis is not practicable due to a lack of sample results above MRL. Decommissioning these wells will remove potential pathways for introduction of contaminants to the groundwater. The revised Long-Term Monitoring Plan will stipulate that visual inspections for sheen in the Salt Lagoon Channel (likely cause would be GAC saturation/breakthrough) will continue whenever an OCAO rep is on-island with annual inspection/photo documentation at a minimum. Louis Howard
4/4/2011 Update or Other Action Annual groundwater monitoring report received. The purpose of this report is to present the results of the November 2010 sampling event and to analyze available data from all the monitoring wells currently included in the St. Paul Island long-term groundwater monitoring project for the presence of increasing or decreasing trends in the concentration of analytes. Groundwater sample analytes included DRO, GRO, benzene, toluene, ethylbenzene, total xylenes (BTEX), and lead. Groundwater sampling procedures and protocols used for this project followed the NOAA Master Quality Assurance Plan (NOAA, 2006), the Final Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska (NOAA, 2005), and the Groundwater Monitoring Work Plan, St. Paul Island, Pribilof Islands, Alaska updated and prepared by BSI in May 2009. The Diesel Seep, also known as the Salt Lagoon Diesel Seep, is near a former marine mammal rendering plant that was located at the southern shore of Salt Lagoon east of St. Paul Harbor. At this location, diesel fuel was released from fuel storage tanks and piping associated with a diesel-powered boiler. Additionally, soil contamination might have occurred from spillage or leakage of fuel during fueling operations. Two monitoring wells have been selected for long-term monitoring of DRO in groundwater. NOAA has retained two monitoring wells at the Salt Lagoon Diesel Seep. One well, MWDS-3, due to its location and analytical history has been designated as a sentinel well to monitor potential DRO migration at the edge of the 2004 petroleum contaminated soil excavation. The other well at this site, MWDS-2, is a long-term monitoring well, and is in place to monitor the contamination levels in a known plume. Both wells were sampled during the May 2010 sample event but were not during the November 2010 sample event. The following section presents statistical analysis of contaminant concentration trends where data is available and meets the previously described criteria. DRO concentrations at monitoring wells MWDS-2 and MWDS-3 were statistically analyzed for monotonic trends using the Mann-Kendall method. Both monitoring wells exhibited decreasing trends in DRO concentrations. Neither trend meets the data quality requirements for this report and are not considered scientifically defensible. Both of the wells involved in long-term groundwater monitoring at the Salt Lagoon Diesel Seep were statistically analyzed for the presence of and direction in a trend of DRO concentrations. Neither trend meets the data quality requirements for this project and are not considered scientifically defensible. Louis Howard
9/29/2011 Update or Other Action Staff received the draft Long Term Groundwater Monitoring Plan St. Paul and St. George Islands, Alaska, September 2011. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island. In accordance with the 2005 long-term monitoring plan (NOAA 2005a), NOAA collected samples from 2 wells retained at this site (MWDS-2 and MWDS-3) from June 2006 through May 2010. Samples were analyzed for DRO. All sample analytical results indicated DRO concentrations as either non-detect or detected at levels well below the applicable ADEC cleanup criterion (NOAA 2011a). Therefore, groundwater monitoring will be discontinued at this site and the associated monitoring wells decommissioned. Additionally, in accordance with the 2005 long-term monitoring plan (NOAA 2005a), visual inspections for petroleum sheen on the Salt Lagoon Channel were conducted between June 2006 and November 2011. These visual inspections verify the effectiveness of granular activated carbon (GAC) filled trenches that were installed to prevent residual petroleum from entering the lagoon. No petroleum sheen has been observed to-date. NOAA will continue to perform the visual inspection at the Salt Lagoon Channel coincident to the St. Paul harbor/industrial area groundwater monitoring. Each visual inspection will include photo documentation and a brief report of the inspection's findings, to be provided to ADEC via email or other suitable means as soon as practicable after the inspection. Louis Howard
6/14/2013 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 71660 name: auto-generated pm edit TPA 13A/B STP Lagoon Diesel Seep Louis Howard
9/30/2013 Report or Workplan Review - Other Staff reviewed the proposal by NOAA to continue groundwater sampling under the existing approved monitoring plans. ADEC has reviewed the information provided and approves the work as a continuation of the three existing work plans for groundwater monitoring on the Pribilof Islands. Louis Howard

Contaminant Information

Name Level Description Media Comments
DRO > Table C Groundwater


Control Type

Type Details
CS Database Notation And Letter To Landowner/RP Excavation at the site restricted due to ongoing remediation by granulated activated carbon barriers placed by NOAA to deal with contaminated groundwater prior to discharge into the salt lagoon.


Requirements

Description Details
Excavation / Soil Movement Restrictions Excavation prohibited due to GAC barriers placed in ground at site to deal with residual DRO contaminated groundwater prior to discharge into the salt lagoon. Annual report no later than April of each year.
Groundwater Monitoring Annual groundwater monitoring at the site is required for petroleum contaminated groundwater. Annual report no later than April of each year.
Surface water monitoring Surface water (salt lagoon) is inspected for sheen. Annual report no later than April of each year.