| Action Date |
Action |
Description |
DEC Staff |
| 10/2/1950 |
Update or Other Action |
The first documented use of the site occurred in October 1950, when it was leased by a construction company for maintenance and storage equipment. |
Jennifer Roberts |
| 10/1/1953 |
Update or Other Action |
Aerial photographs show that considerable excavation occurred in the southern half of the site between 1950 and 1953. A haul road is visible up the bluff to the north leading to Elmendorf Air Force Base, and it is likely that gravel from the site was mined for use in base construction. |
Jennifer Roberts |
| 6/1/1955 |
Update or Other Action |
Beginning in 1955, various metal recycling and salvage businesses operated at the site. During recycling and salvage activities, electrical transformers and batteries were handled. Releases of hazardous substances occurred from these activities and inappropriate burial or burning of transformer oil. |
Jennifer Roberts |
| 9/21/1982 |
Site Visit |
On September 21, 1982, Jim Hayden responded to an anonymous complaint regarding transformers at the subject site near Ship Creek. There were indeed over one hundred (100) transformers scattered about the salvage yard. With the owner's permission, Jim sampled oil from ninety-seven (97) transformers. None were leaking. Jim could not sample every transformer as they were stored in a jumbled heap, many of which were inaccessible. Results of those samples indicated 7 transformers to be slightly contaminated, i.e., between 50 & 500 ppm PCBs. |
Jim Hayden |
| 9/30/1982 |
Site Added to Database |
Polychlorinated biphenyls, lead, dioxins. |
Jim Hayden |
| 1/4/1983 |
Document, Report, or Work plan Review - other |
Certified Mail sent to Gerald Poirier Standard Steel and Metals. RE: PCB Contaminated Transformer Fluid.
As you may recall from this past September [1982], I tested many of the transformers stored at your facility for the presence of polychlorinated biphenyls (PCBs) . PCBs are stable, long-lasting organic chemicals used primarily as transformer fluids. Unfortunately, these fluids were found to be harmful to human health only after many thousands of tons HAD BEEN PRODUCED. Approximately thirty percent of the transformers in use nationwide have detectable concentrations of PCBs.
Transformer oils from ninety-seven transformers were tested at your facility. Of these seven were found to be contaminated with PCBs. Transformer Types: i. PCB Transformer. A transformer containing greater than 500 parts per million PCB. 2. PCB Contaminated Transformer. A transformer containing between 50 and 500 parts per million PCB. 3. Non-PCB Transformer. A transformer containing less than 50 parts per million PCB.
The transformers at your facility are of types two and three. All may be scrapped on-site but the fluids from the seven transformers identified as type-two must first be drained and later shipped in a proper container to a federally approved disposal site. I have identified the contaminated transformers at your facility by number.
When the weather improves, a sorting process should begin - thereby separating contaminated from non-contaminated transformers. Due to inaccessibility, not all transformers at your facility were tested. However, during t he sorting process t he remaining transformers will be checked.
Roughly fifty transformers remain unsampled. At a contamination rate near 10 percent, one can expect four or five more contaminated transformers to be identified. Added to those previously identified, a total of twelve contaminated transformers seems a reasonable expectation. Tile transformers have been averaging fifty gallons each so it is likely that upwards of six-hundred gallons of PCB contaminated fluid will need to be shipped to a certified disposal site. Disposal costs at certified sites, excluding transfer cost, run $2.35 per gallon.
Please contact this office so that meetings may be scheduled to discuss items such as previous ownership and responsible parties after which a disposal plan may be prepared
See site file for additional information. |
Jim Hayden |
| 1/5/1985 |
Update or Other Action |
The site (Standard Steel), as well as all lands west of Reeve Avenue, south of Post Road, east of Wrangell Street and north of Ship Creek, is currently managed and controlled by the Alaska Railroad Corporation (ARRC) pursuant to an exclusive license issued by the United States under the authority of an act of Congress, the Alaska Railroad Transfer Act of 1983. ARRC assumed control of these propertyies from the United States government on January 5, 1985. The underlying property owner of the site is the United States, pending eventual transfer to ARRC as contemplated by the Act. The ARRC is a public corporation owned by the State of Alaska. ARRC has publicly taken the position that zoning of the site and surrounding areas should remain industrial. |
Jim Hayden |
| 8/2/1985 |
Update or Other Action |
The issue resurfaced on August 2, 1985 when I received another anonymous call concerning the same Jumbled mass of transformers. While investigating the August 2, 1985 complaint, Jim noticed the aromatic scent of PCB's emanating from the ground beneath an obsolete car crusher. With utmost caution, Jim sampled the suspected soil & sent it in protected containers to Douglas for rush analysis.
Jim Hayden of Southcentral Regional Office (SCRO) Alaska Department of Environmental Conservation (ADEC) in coordination with USEPA staff, conducted sampling at site found elevated Polychlorinated biphenyls (PCB) soil contamination. 110,000 mg/kg maximum concentration. |
Jim Hayden |
| 8/23/1985 |
Update or Other Action |
EPA Situation Report from Lynn Tomich Environmental Protection Specialist to Steven Torok Air & Hazardous Waste Coordinator. Sitrep 1 - Standard Steel, Anchorage. EPA Alaska Operations office received information from Jim Hayden of the Alaska Department of Environmental Conservation regarding a potential PCB problem at Standard Steel and Metals in Anchorage.
Mr. Hayden stated that verbal lab analysis reports from soil samples taken at Standard Steel showed approximately 100,000 ppm PCBs. - EPA conducted an initial PCB inspection at Standard Steel on September 10, 1982. A Letter of Advisement was sent to Standard Steel stating a
lab result of a soil sample taken as 64 ppn. The letter requests Standard Steel to "test your equipment for PCBs" .
Standard Steel did not take any action to test transformers onsite, however, Jim Hayden has sampled many transformers over the past two years and marked (with his own system) those transformers containing PCBs. Mr. Hayden asked Gerry Poirer, site operator, to separate out the
transformers that he has determined contain PCBs. Mr. Poirer has not done this.
- The property is owned by the Alaska Railroad (State government) and leased to Norman Thompson of Ben Lomand, Inc.
EPA conducted a follow up PCB inspection on 8/20/85 and collected samples on 8/ 22/85.
- Inspection revealed: - approximately 100 transformers onsite - some open - the majority
of the transformers onsite are in a locked , fenced area, however, this area has been broken into and transformer fluid stolen (information from site operator, Gerry Poirer)
- apparent labeling violations - a large hydraulic baler (no longer in service) which the yardman stated used to be serviced with fluid from transformers stored onsite.
- an incinerator which was used to burn oil off the coils from transformers to clean the copper prior to recycling
-bulk transformer fluid storage - approximately 1,800 gal. - no records available for additions or removals from the tank
- open transformers stored within 10 yards of Ship Creek
Future Actions :
· - EPA action pending lab result s fr001 samples collected 8/22/85
See site file for additional information. |
Jim Hayden |
| 10/25/1985 |
Update or Other Action |
Anch. Daily News 10/25/1985 Article "Yard to Be Checked for PCBs". Investigators for the Environmental Protection Agency plan to dig up an Anchorage junkyard in a search for hazardous
wastes, an official of the Alaska Department of Environmental Conservation said this week.
Environmental Conservation Field Officer Jim Hayden said federal investigators want to determine whether significant quantities of PCB-laden oil has been spilled at the Standard Steel and Metal Co. Inc., 2400 Railroad Ave. While making a summer inspection at the junkyard
near Ship Creek, Hayden said he noticed the distinctive smell of PCB oil and took some soil samples.
Those samples revealed PCBs were spilled in the area at some time in the past, but a full-scale investigation is needed to determine the extent of the pollution, Hayden said. Hayden expected the EPA to spend about a week at the junkyard conducting its tests. He said it would take some time after that before the results were known.
Poirer, who purchased Standard Steel in 1981, said no transformers have been dismantled at the junkyard since he assumed ownership, but it appears that for many years before that they were dismantled in a search for copper. The transformers have copper cores that are valuable on the, scrap metal market. "They were probably taken apart down there · for 20 years," Poirier said.
Poirier said environmental officials have told him the soil in that acre of ground will probably have to be cleaned of PCBs, but they have offered no suggestions on who would pay for the clean-up. The land under the junkyard is owned by the Alaska Railroad, but the junkyard is operated on lease by Poirier, who bought it from Stanley Osland.
It is hard to estimate how much PCB-laden oil may have been spilled, he said. More than 100 transformers may have been disposed of at the junkyard, but nationally - on the average - only about 6 percent of old transformers have been found to contain PCBs, he said.
See site file for additional information. |
Jim Hayden |
| 10/28/1985 |
CERCLA PA |
Lynn Tomich of EPA Emergency Response Team (ERT), Alaska Ops Office, and Region X technical assistance team (TAT) conducted a two week investigation to inventory the materials on site and to collect samples from surface soils, transformer storage areas, drainage pathways and incinerators on site. Composite surface soil samples from all exposed areas indicated widespread contamination from PCBs (up to 120,000 ppm), carrier solvents and heavy metals.
Significant levels of chlorinated dioxins and furans were detected in an onsite incinerator. Ash samples from the on-site incinerator contained dioxin with Toxic Equivalent Factor (TEF) values as high as 5.71 parts per billion (ppb). Other contaminants of concern found in soil samples indicated high levels of lead, significant levels of cyanide and trichlorobenzene. Off site migration of PCBs was documented in stream sediment sampling conducted along Ship Creek, which indicated 2.5 mg/kg PCBs downstream of the Site. |
Lynn Kent |
| 11/6/1985 |
Update or Other Action |
Results Of Analyses Of Duplicate Sample Sets Analyzed At Different Laboratories, Standard Steel And Metals Salvage Yard , Anchorage, Alaska.
Laucks Laboratory (portable GC): TSA2-02 Soil, Transformer storage area #2 - 500 mg/kg (36,000), Lead 3,900 mg/kg, SSS-16 Soil, roadway - 6.1 mg/kg (no result), SSS-33 Soil Office Parking lot - 10 mg/kg (6), SSS-38 Soil roadway 220 mg/kg, SSS-45 120,000 mg/kg (19,023). Lead 1,400 ppm, Transformer Oil: T-18 590 ppm (410), T-34 220 ppm (210), T-84 730 ppm (1,000), T-139 100 ppm (6.9), T-142 38 ppm (390), T-169 160 ppm (140). |
Jim Hayden |
| 12/9/1985 |
Update or Other Action |
DEC Memo from J. Hayden thru B. Erickson to Keith Kelton, Director Environmental Quality. RE: PCB Contamination Standard Steel Yard. On September 21, 1982, 1 responded to an anonymous complaint regarding transformers at the subject site near Ship Creek. There were indeed over 100 transformers scattered about the salvage yard. With the owner's permission, I sampled oil from 97 transformers. None were leaking. I could not sample every transformer as they were stored in a jumbled heap, many of which were inaccessible.
Results of those samples indicated 7 transformers to be slightly contaminated, i.e., between 50 & 500 ppm PCB. I sent the operator Mr. Gerald Poirier a letter of general explanation on January 4, 1983. I asked Mr. Poirier to contact the office about sorting the transformers & planning for disposal. Mr. Poirier was cooperative in allowing me access to the property but he did not respond to the letter nor did he offer to sort the transformers.
I did not feel pressed to notify the EPA about the trace PCB's because the transformers were intact, not leaking, & EPA had conducted their own same-site investigation September 10, 1982. My work shifted to water & sewer issues in 1983 so the priority for follow-up was low.
The issue resurfaced on August 2, 1985 when I received another anonymous call concerning the same Jumbled mass of transformers: Please note that during the intervening years my wonderfully large nose had become sensitized to the odor of PCB's due to some pure PCB samples taken at the special request of ADOT (Tudor Facility).
While investigating the August 2, 1985 complaint, I noticed the aromatic scent of PCB's emanating from the ground beneath an obsolete car crusher. With utmost caution, I sampled the suspected soil & sent it in protected containers to Douglas for rush analysis. On August 16th, I was notified of positive results averaging nearly 100,000 ppm.
Subsequent discussions with Mr. Poirier revealed that previous transformer saivage operations during the 1960's & 1970's resulted in transformer oil being used to replenish the ·1eaking hydraulic cylinder of the car crusher. Due to these comments, & the high concentrations of PCBs in the samples, I notified EPA to set TSCA in motion.
Also, due to the shortage of staff at A/WDO, I suggested to EPA site be added to the Tetra Tech list in hopes that the aside for that program could be used for the PCB assessment. EPA conducted some preliminary tests on August 22, 1985 which in turn warranted a team of special investigators flown in from Seattle. The special team assessment was conducted during the last week of October, 1985. The final report is pending.
This site will be expensive to clean because it is cluttered with a vast assortment of heavy salvage items. Heavy equipment will be needed to lift, sort, & wash the cluttered masses of salvage yard debris. Large amounts of soil will probably need to be removed.
In conclusion, the operator is in bankruptcy & the site is leased from Alaska Railroad. The railroad people have, of course, expressed a desire to be included in discussions concerning clean-up. The land in question has not yet been transferred to the State (it is still federal land). |
Jim Hayden |
| 12/12/1985 |
Update or Other Action |
Gerald Poirier operating business as Standard Steel and Metals. EPA issues letter with seven violations spelled out regarding Disposal of PCBs 40 CFR 761.60(a), Storage of PCBs 40 CFR 761.65(c)(6)(8), 761.65(c)(7)(iii).
1. VIOLATION ONE - Dirt and ash from in front of the incinerator contained PCBs at 75 parts per million and had not been properly cleaned up and disposed of.
2. VIOLATION TWO - Soil near the base of the bulk oil storage tank contained PCBs at 75 parts per million and had not been properly cleaned up and disposed of.
3. VIOLATION THREE - Soil by the door to the hydraulic baler contained PCBs at 407 parts per million and had not been properly cleaned up and disposed of.
4. VIOLATION FOUR - There were no batch records for the large tank in the yard area used for bulk storage of transformer oil. The PCB content of the oil was unknown and it must be assumed to have been PCB-contaminated (i.e., containing 50-499 parts per million PCB) until or unless chemical analysis indicates otherwise. [Reference: Federal Register, Vol. 44, No. 106, May 31, 1979, page 31517.J In addition, there was no SPCC Plan for the bulk tank.
5. VIOLATION FIVE - There were approximately 100 transformers stored throughout the
facility. There was no documentation available of PCB content of these transformers. Mineral oil transformers must be assumed to be PCB-contaminated, and liquid-filled t ransformers whose
dielectric flu id is unknown must be assumed to be PCB Transformers, unless chemical analysis indicates otherwise.
6. VIOLATION SIX - The following were not marked with the required PCB label: a. The large tank in the yard area used for bulk storage of transformer oil; b. The Dempster Balester, KILKOM hydraulic baler, serial no . 78111; and c. The area where (a) and (b) were stored.
7. VIOLATION SEVEN - There was no PCB Annual Report for 1984.
See site file for additional information. |
Jim Hayden |
| 12/12/1985 |
Update or Other Action |
Gerald Poirier operating business as Standard Steel and Metals. EPA issues letter with seven violations spelled out regarding Disposal of PCBs 40 CFR 761.60(a), Storage of PCBs 40 CFR 761.65(c)(6)(8), 761.65(c)(7)(iii).
1. VIOLATION ONE - Dirt and ash from in front of the incinerator contained PCBs at 75 parts per million and had not been properly cleaned up and disposed of.
2. VIOLATION TWO - Soil near the base of the bulk oil storage tank contained PCBs at 75 parts per million and had not been properly cleaned up and disposed of.
3. VIOLATION THREE - Soil by the door to the hydraulic baler contained PCBs at 407 parts per million and had not been properly cleaned up and disposed of.
4. VIOLATION FOUR - There were no batch records for the large tank in the yard area used for bulk storage of transformer oil. The PCB content of the oil was unknown and it must be assumed to have been PCB-contaminated (i.e., containing 50-499 parts per million PCB) until or unless chemical analysis indicates otherwise. [Reference: Federal Register, Vol. 44, No. 106, May 31, 1979, page 31517.J In addition, there was no SPCC Plan for the bulk tank.
5. VIOLATION FIVE - There were approximately 100 transformers stored throughout the
facility. There was no documentation available of PCB content of these transformers. Mineral oil transformers must be assumed to be PCB-contaminated, and liquid-filled t ransformers whose
dielectric flu id is unknown must be assumed to be PCB Transformers, unless chemical analysis indicates otherwise.
6. VIOLATION SIX - The following were not marked with the required PCB label: a. The large tank in the yard area used for bulk storage of transformer oil; b. The Dempster Balester, KILKOM hydraulic baler, serial no . 78111; and c. The area where (a) and (b) were stored.
7. VIOLATION SEVEN - There was no PCB Annual Report for 1984.
See site file for additional information. |
Jim Hayden |
| 3/1/1986 |
Update or Other Action |
EPA TAT Activities Report-Preliminary Site Assessment Standard Steel and Metals Salvage Yard 10/28/1985-11/08/1985 by Region X Technical Assistance Team TDD #10-8510-07. The health and environmental hazards presented by high levels of PCBs (samples from the main transformer storage area were as high as 165,000 ppm EPA Laboratory), PCDDs, PCDFs (up to 180 ppb), organic solvents, and heavy metals present in the soil at the Standard Steel site must be reduced as soon as possible.
PCB sediment sample taken 50 yards downstream of the west border detected 2.5 ppm PCBs. These results indicate that PCB contamination is migrating from the Standard Steel site. This is especially significant as the sample was taken at a point approximately 1/4-mile from the nearest transformer storage area.
The final TEF for soot generated from PCB fires was calculated to be equivalent to 45 ppm 2, 3, 7 ,8-TCDD. Presumably the transformer oil burned in this study was pure PCB. The 2,3,7,8-TCDD toxicity equivalence for the Standard Steel samples are as follows: DXOl 0.17 ppb, DX02 4.76 ppb, DX03 5.71 ppb, DX04 1.61 ppb and DX05 2.48 ppb.
Further determination of the extent of contamination of surface and subsurface soil on the site for PCBs, PCDDs, PDCFs, organic solvents, cyanide, and heavy metals.
o Proper containment and disposal of hazardous materials present in the 55-gallon drums or other containers on the site.
o Proper containment and segregation of PCDD and PCDF contaminated materials.
o Removal and proper disposal or treatment of all PCB-contaminated soils,liquids, and debris in full compliance with 40 CFR Part 761.
o Determination of the extent of contamination in groundwater by installation of onsite monitoring wells, and if required, treat groundwater to reduce contamination to acceptable levels.
o Properly contain or dispose of the large battery piles on the site.
o construct a security fence around the site.
In the interim, Standard Steel customers and employees should be prevented from coming in contact with contaminated materials. The Standard Steel Company has filed for bankruptcy and current property ownership is being researched. Should the property owner decline to stabilize the site, it is reasonable to assume that the Standard Steel site would become a primary candidate for a Superfund Removal Action.
See site file for additional information. |
Jim Hayden |
| 4/14/1986 |
Update or Other Action |
EPA Letter to Ben Lomand Inc. c/o Norman Thompson RE: Discovery of Hazardous Substances and Superfund Removal Action. The Environmental Protection Agency ("EPA") baa determined that the release and threat of release of hazardous substances at the Standard Steel and Metals Salvage Yard in Anchorage Alaska presents an endangerment and threat to the public health or welfare or the environment. The Notice which accompanies which accompanies this letter outlines the factual basis for that determination and describes minimum removal activitie1 which are necessary and appropriate to stabilize the site and prevent future release at the site.
However, you may ex1rci1e thi1 opportunity only if you meet certain requirements within a specified time frame. Those requirements are:
1. Provide a written commitment to EPA of your intent to perform the work, and post a $500,000 performance bond in support of that commitment by April 23, 1986;
2. Sign a Administrative Order on Consent, pursuant to 42 U.S.C, 9606, with EPA by May 15, 1986:
3. Commence removal activities by June 1, 1986, and complete all removal activities within the time specified in the Notice.
If you choose to refrain from these activities, or it any of these requirements are not met within the time periods specified, EPA will exercise its authority pursuant to 42 U.S.C. 9604 and 40 CFR 300.65. and perform the necessary and appropriate removal activity.
See site file for additional information. |
Jim Hayden |
| 4/14/1986 |
Interim Removal Action Approved |
EPA issues a CERCLA 106 Order against potentially responsible parties to begin stabilization & cleanup of the site. A letter for Discovery of Hazardous Substances & Superfund Removal Action for Site to Norman Thompson DBA Ben Lomand Inc.
From at least 1972 to the present, the site has been & is used as a metal salvage & recycling center. Activities at the site have included the reclamation of electrical transformers including polychlorinated biphenyl (PCB) contaminated transformers. Incineration of copper wire, transformer casings, & other debris is done at the site. Old batteries, filled & empty 55-gallon drums, & bulk tanks containing liquids are stored on site. Used equipment & barrelled debris from military sources, po11ibly including live ordnance are· also stored on the site.
Over 175 used tran1formers are stored on site. Of those tested, at least eleven transformers stored on the site were found to contain PCBs in excess of 50 part per million (ppm). Four transformers contained over 500 ppm of PCB. Some tran1formers showed signs of vandalism, causing leakage of liquids from the transformers. Soil samples from beneath transformer storage areas showed significant & uniform PCB contamination, ranging from 87 ppm to 165,000 ppm. Ash samples from known incineration areas showed contamination of dioxins & furans, ranging from 2.1 parts per billion (ppb) to 180 ppb. Sediment samples from Ship Creek, taken from approximately 50 yards downstream from the site, revealed PCB contamination of 2.5 ppm. Water samples from the same area revealed low levels of PCB contamination. Samples from road areas on site also showed low levels of PCB contamination.
So11 & eub1tance samples from debris storage areas on site revealed the presence of heavy metals & carrier solvents. Notice served to outline factual basis for the determination that the Site has a release & threat of release of hazardous substances which present an endangerment & threat to the public health or welfare or the environment. Standard Steel & Metals Co. Inc. & USDOT Federal Railroad Administration-AK Railroad served with notice too.
No parties came forward to implement the cleanup. Actual cleanup & site stabilization work by EPA began on June 2, 1986.
See site file for additional information. |
Jim Hayden |
| 4/16/1986 |
Update or Other Action |
EPA Factsheet #1 Standard Steel and Metals Salvage Yard. Investigations conducted by the Environmental Protection Agency (EPA) and the Alaska Department of Environmental Conservation· (ADEC) indicate that high levels of PCBs,solvents, and heavy metals are present in the transformer fluids and in soils on-site. In addition, lower levels of PCBs have been detected in the sediment of Ship Creek. The investigation also revealed the presence of low levels
of chlorinated dioxin and furan contamination in the ash near the onsite incinerator.
Because of the number of transformers and other contaminated materials on site, clean-up of the site will probably span two summer seasons: fencing of the site to prevent people from being exposed to the soils and transformer liquids on site, making sure employees and customers do not have access to the site, staging salvage materials and debris away from the site borders and creek bank, determining the extent of contamination on the site and in the creek by taking additional soil and water samples, berming around the site to prevent run-off problems,
sampling, analyzing, and packaging all transformer liquids containing PCBs, segregating and containing all ash from the incinerator, and sampling existing groundwater wells in the immediate area.
Future activities that may be necessary at the site include:
installing and sampling of groundwater wells, and treating of the ground water, if necessary,
and treatment of contaminated materials and soils.
See site file for additional information. |
Jim Hayden |
| 4/17/1986 |
Update or Other Action |
Anc. Daily News article "PCBs found in creek. EPA Reports Ship Creek Pollution from junkyard."
Toxic PCBs have leached from a grossly contaminated Anchorage junkyard into lower Ship Creek, according to federal Environmental Protection Agency tests released Wednesday. The tests also found traces of dioxins - some of the most toxic chemicals created by man - in the ash of a junkyard furnace.
"We believe the site does represent a hazard to those (five) people who work on the site and those people who might have access to the site," said Bill Longston, an EPA official who will lead an emergency cleanup. "The site also represents a potential hazard to those people in surrounding areas."
Gerald Poirier operates the junkyard on land leased from the federal Department of Transportation and managed by the state-owned Alaska Railroad. He could not be reached for comment Wednesday. In an earlier interview, Poirier said he bought the junkyard four years ago from Stanley Osland. He said he's tried for years to get state officials to check the site for
PCBs. Outside the trailer, Roger Millsap, another junkyard employee, climbed off a piece
of heavy equipment to talk with a reporter. Millsap said he's lived in a trailer inside the junkyard for the past six years.
According to Millsap, transformer oil hasn't been burned in the furnace during the four years Poirier has managed the junkyard. Before that, oil routinely was burned in the furnace, he
said. Junkyard workers tried to get the furnace hot enough to burn the oil cleanly but didn't
always succeed, he said. "There was a lot of real black smoke ... The soot went all over the place."
See site file for additional information. |
Jim Hayden |
| 4/23/1986 |
Update or Other Action |
EPA Letter to Tony Knowles MOA Mayor. The Environmental Protection Agency conducted a preliminary site assessment at Standard Steel and Metals in Anchorage this past fall. Test
results indicate several hazardous or toxic materials onsite. EPA issued notices to three potentially responsible parties on April 14, 1986. The notices require the parties to advise EPA, by April 23, 1986, whether or not they will take action to stabilize and clean-up the site. In the event that none of the parties are willing or able to take action, EPA intends to
use Superfund monies to stabilize the site. If warranted, EPA work is scheduled to begin the last week in May.
On April 16, 1986 the EPA held a meeting with Municipality of Anchorage and State of Alaska. representatives to discuss the results of the· preliminary site assessnent and EPA's plans.
During the briefing, EPA solicited assistance fran the Municipality. Specifically, EPA requested:
1) That warning signs previously posted at Standard Steel by the Municipality be m::>dified to reflect the increased hazard level now known to be present.
2) That police patrols of the area be increased to minimize trespassing at the site and thus reduce public exposure to the hazard. (0ne of EPA's first actions will be to fence the site to prevent public access).
3) That Municipality, with assistance from the Alaska Department of Law, assist in relocating a Standard Steel employee currently living on the site.
4) That the Municipality assist EPA in locating and gaining access to wells in the vicinity of the Standard Steel site.
5) That an information repository contain information pertaining to Standard Steel be maintained by the Municipality for public review. (EPA would provide information for the repository.)
Municipality assistance with these tasks (sane of which has already begun) will be greatly appreciated.
See site file for additional information. |
Jim Hayden |
| 5/9/1986 |
Update or Other Action |
Surface Water and Groundwater Survey Near the Standard Steel And Metals Salvage Yard, Anchorage, Alaska 5-9 May 1986 Prepared By Technical Assistance Team TDD #10-8604-12.
The hydrogeology of the area includes a shallow unconfined aquifer located 5 to 40 feet below the surface. The base of the confined aquifer is marked by a clay unit approximately 150 to
200 feet thick. A confined aquifer is found beneath the clay layer. More than half of the water used in the Anchorage area is taken from the deep confined aquifer. Several shallow wells exist in the area of the standard Steel facility. A list of 14 wells was developed for potential sampling. TAT and EPA chose eight of the wells that were closest to the· standard steel site in both upgradient and downgradient locations.
A summary of the results indicates that none of the well samples revealed the presence of PCB contamination. Analyses of the volatile organics, base/neutral extractible and metals portions of the EPA Priority Pollutant scans revealed only one high value. The shallow well at the Steel Fabricators facility, downgradient and adjacent to Standard Steel revealed a zinc value of
14 milligrams per liter (mg/l). This result would be significant considering that the National Secondary Drinking Water Standard for zinc is listed as 5 mg/l; however, since the well water is only used for washing construction vehicles, it should not pose a threat to the public health. Results from the water and sediment samples taken from Ship Creek revealed no PCB _ contamination upstream of the site. The PCB contamination found in the downstream sediment locations dropped from the 2.5 ppm level discovered during the initial TAT assessment to 0.04 and 0.06 ppm. It cannot be determined if this decrease is due to a reduction of the contaminant migration rate or other factors such as seasonal variations in the stream sediment.
See site file for additional information. |
Jim Hayden |
| 5/9/1986 |
Update or Other Action |
Weston Consultants, widespread PCB contamination and dioxins detected at on site incinerator |
Bill Lamoreaux |
| 5/19/1986 |
Update or Other Action |
EPA Factsheet #2. The EPA's sampling team also followed up on several reports of transformer fluid which may have left the site. Samples were collected at one of these sites, a rural area near Palmer. The Alaska Department of Labor, OSHA, has taken measures to protect employees of Standard Steel from contact with the PCBs and dioxins found to be on site.
Activities at the site are tentatively scheduled to begin the first week in June and will include: staging salvage materials and debris away from the site borders and bank of Ship Creek,
fencing the site to prevent people from being exposed to the soils and transformer liquids on site, staging salvage materials and debris away from the site borders and creek bank, additional sampling to determine the extent of contamination on the site and in the creek,
berming or other measures to prevent surface run off from the site, sampling, analyzing , and packaging all transformer liquids containing PCBs and segregating and containing all ash from the incinerator.
See site file for additional information. |
Jim Hayden |
| 6/11/1986 |
Update or Other Action |
EPA Factsheet #3. The EPA began cleanup and site stabilization activities at Standard Steel on June 2, 1986. The Superfund Emergency Response Cleanup Services contractor is onsite along with EPA, USCG personnel, and the Technical Assistance Team, contractors to EPA. EPA took control of the site on 6/3/ 86 and has a security guard present during all times EPA is not onsite.
Access to the Standard Steel/Ben Lomand Inc. property has been made through a fence on the west border. All project support facilities (trailers, job office, equipment storage, etc.) are currently on property adjacent to the site per approval of the owners. A decontamination line for personnel has been set up and all site entry will be through this point.
A temporary road has been built, using crushed rock, on the site property to facilitate equipment movement along with temporary staging area which is to be used for the storage hazardous materials being collected on the site.
A survey has been completed to establish the boundaries of existing property owners on the site. Ship Creek, directly south of the property has al so been surveyed and EPA is presently
working with the Corps of Engineers to develop plans for bank stabilization. Prevention of bank erosion is necessary to prevent further PCB contamination to Ship Creek and to prevent
the loss of a streamside roadway used for clean-up equipment movement.
See site file for additional information. |
Jim Hayden |
| 6/16/1986 |
Update or Other Action |
US Army Engineer District - Alaska sent letter to Alvin Ewing Assistant Regional Administrator Alaska Ops Office. Your letter of June 5, 1986 requested the Corps of Engineers to assist in designing a method of bank stabilization for a portion of Ship Creek threatened by PCB contamination. Mr. William H. Longston's letter of June 9, 1986 also stipulated that sheetpiling be used as the method of stabilization.
Because of the emergency nature of this situation it was indicated that design sketches would be acceptable. The enclosed material contains our recommended design for these erosion control
measures.
See site file for additional information. |
Jim Hayden |
| 6/19/1986 |
Update or Other Action |
EPA letter to ADEC Bill Lamoreaux RE: Standard Steel Superfund Clean-up Site. To date, all
hazardous materials adjacent to Standard Steel on the public street, Yakutat Avenue, have been removed onto the Standard Steel property and Dioxin containing ash from the incinerator area has been containerized. The PCB contaminated oil is being pumped from transformers to bulk storage tanks. The southern portion of the property borders on Ship Creek, and there is the possibility of material from the yard actually eroding into the creek. It will therefore be necessary to prevent stream erosion by Ship Creek along this boundary to prevent additional PCB contamination to Ship Creek, to maintain an existing roadway, and to provide a more permanent anchor for security fence construction.
As discussed with you, enclosed is a copy of the bank stabilization plans developed for EPA by the Corps of Engineers. Under the National Contingency Plan, during Superfund actions, EPA is exempt from obtaining Federal, State and local permits for activities related to clean-up operations. We are anxious, however, to meet the intent of any ADEC regulations which may apply to stream bank stabilization activities.
Since EPA is not actually applying for permits, unsigned permit applications and copies of the design plans have been submitted to other interested agencies for their information and comments. If ADEC feels there are major revisions that should be incorporated, or you have questions regarding the enclosed plans, please call Lynn Tomich of EPA at the Standard Steel site at 272-0530
See site file for additional information. |
Bill Lamoreaux |
| 7/10/1986 |
Update or Other Action |
EPA Factsheet #4. Incinerator - All dioxin contaminated ash has been containerized. The
stack from the incinerator has been taken down in sections which have been sealed in visqueen. Stack, incinerator, and drums have been enclosed in a wooden structure within the shed on the Standard Steel property. At present, there is no legal method of dioxin disposal and this material will remain onsite indefinitely.
- Security Fence Construction - Boundaries are being cleared and fence construction has begun with an estimated completion date of 7/18/86.
Transformers - Oil from all transformers to date has been pumped into bulk storage tanks based on PCB concentration (more than 50 ppm, 50-500 ppm, less than 500 ppm). Empty PCB transformers have been rinsed and staged.
- Drums - 357 drums have been sampled, field analyzed and staged according to hazard category, i.e. flammable liquids, oxidizers, acids, bases and water reactives.
- Standard Steel resident has been relocated. EPA sampled, then removed Roger Milsap's trailer to his private lot near Palmer on June 13-14.
- Rip rap installation began along bank of Ship Creek on 7/2/86. The scheduled completion date is 7/12/86.
- Chinook and Silver Smolts, Dolly Varden, and Rainbow fish samples have been collected from Ship Creek and will be analyzed for PCBs.
PLANNED ACTIVITIES
- Estimate an additional 250 drums to be sampled, field analyzed and staged according to sample results.
- EPA will conduct an overflight to take aerial photos at close of this field season.
- Plans are to containerize highly contaminated soil in drums and segregate other contaminated soil onto visqueen and cover with visqueen for storage through the winter.
See site file for additional information. |
Jim Hayden |
| 7/18/1986 |
Update or Other Action |
Memo from Burgh to Lamoreaux, Flint, and Lucky. RE: Hazardous waste transportation pre-notification. The wastes originate from the Standard Steel and Metals yard in Anchorage; this waste is a result of the clean-up efforts underway presently by EPA and their ERCS contractor Riedel.
From the clean-up so far, EPA will be sending out of Anchorage next Wednesday, July 23, four (4) 40-foot containers (trailers) : one with ignitable wastes, one with corrosive wastes, one with oxidizers, and one with PCB oils, solids, and transformer shells. The wastes are packed in 55-gallon drums in these containers, The container of oxidizers only will have a few drums. A separate container is necessary to keep the required separation distance between different classes of hazardous materials for marine transport.
The shipment is expected to leave Anchorage July 23, travel to Seward via the Seward Highway, and then depart Seward July 25 enroute to Seattle. Transporter for this shipment will be Ocean Terminals, a permitted RCRA transporter out of Washington state. The containers will travel on SeaWays barge from Seward.
See site file for additional information.
See site file for additional information. |
Colleen Burgh |
| 7/23/1986 |
Update or Other Action |
EPA Letter to David Nyman ARRC re: Monitor Water Well Easement Requests for Standard Steel Site. The EPA contracted Technical Assistance Team requests permission to drill four to seven shallow monitoring wells on and adjacent to the Standard Steel Metal and Salvage site (fig. 1) located on land within the railroad terminal reserve (southwest 1/4 Sec. 9, Tl3N, R3W). The purpose of the wells will be to determine any level of groundwater contamination that may exist in the local shallow unconfined aquifer. Sediment samples will also be collected to test for the migration of contaminants at selected depths. Depth of the wells will range from fifteen to thirty feet, constructed with PVC tubing and protected by steel surface casings with locking caps. A driller specification sheet is attached.
Locations proposed are within or immediately adjacent to the defined site. A background well is desired at a site along the north side of the tracks paralleling Railroad avenue.
See site file for additional information. |
Jim Hayden |
| 7/31/1986 |
Update or Other Action |
Phase I of the response action commenced by EPA. Site security was undertaken, removal of 1,000 gallons of PCB contaminated oils, removal of eighty-five 55 gallon drums of RCRA hazardous waste, installation of four groundwater monitoring wells, isolation of dioxin/furan wastes, construction of an erosion control wall along Ship Creek, fish bioassay of resident fish in Ship Creek, initial PCB soil sampling. |
Jim Hayden |
| 8/4/1986 |
Update or Other Action |
EPA Factsheet #5. There were enough funds to c001plete all activities planned for the
1986 field season. Remaining funds were used for shipping and disposal of the following materials:
- 17 drums of PCB liquids, 5 PCB transformers, and 45 drums of highly contaminated PCB soil,3 drums of oxidizers, 24 drums of caustics and acids and 55 drums of flammables.
All shipping containers were inspected by EPA and USCG prior to leaving the site. These materials were shipped the week of 7/21/86 to Seward via truck, then barged to Seattle where they will be trucked to disposal facilities.
- The remaining drums of waste oil and non-hazardous materials have been staged on pallets within the security fence and covered for storage through the winter.
Riprap installation along Ship Creek was c001pleted on 7/12/86
- Security fence construction was completed on 7/25/86. Keys to the gate will be maintained at the Anchorage EPA office.
Four (4) monitoring wells have been installed. Soil samples were collected at different depths during the drilling process.
- Completion of the monitoring wells terminated activities at the site for the 1986 field season.
PLANNED ACTIVITIES
- Water samples will be collected throughout the winter, as weather and scheduling permit, to help establish the extent of contamination at the site and to help formulate clean-up strategy for the summer of 1987.
- Examine, decontaminate or dispose of all above surface contamination on the site. Determine subsurface contamination and either clean or remove soil.
See site file for additional information. |
Jim Hayden |
| 1/1/1987 |
Interim Removal Action Approved |
Interim 2 June-31 July 1986 Federal On Scene Coordinator's Report for the contaminants shipped from site included 17 drums of PCB liquid, 5 PCB transformers, 45 drums of highly contaminated PCB soil, 24 drums of oxidizers, 55 drums of flammables, 250 tons of batteries. The following are contaminants identified at the site: PCB; Furans; Dioxin; Aroclor; Lead; Copper; Chromium; Zinc.
Dioxin was found in ash generated by an on-site incinerator burning PCBs. Preliminary assessment of the site showed low level PCB concentrations throughout the site with several areas of high contamination. PCBs found in sediments downstream, but not upstream of the site indicated this contamination may have migrated to Ship Creek. Four monitoring wells installed 24 July 1986. 1st groundwater sampling results revealed presence of PCBs and carrier solvents.
The removal action at the Standard steel site is scheduled for completion during the summer of 1987 following reauthorization of CERCLA funding. Activities that are planned for the second phase of the removal include the stabilization or disposal of the electrical storage batteries and additional soil removal in highly contaminated areas of the site. In the interim period between summer seasons, a monitor well sampling program has been scheduled to collect and analyze well water on a quarterly basis from the four wells installed during the removal action
See site file for additional information. |
Bill Lamoreaux |
| 5/29/1987 |
Update or Other Action |
EPA Factsheet #6. The overall goal for this summer's activities is to contain all contaminated materials and soils on-site. This will involve the following activities:
Identify, delineate and remove all PCB contaminated soils. [Cleanup level inside the fence = 25 mg/kg. Outside the fence = 10 mg/kg with fill material and cap on top.]
Containerized soils will be secured on-site for ultimate disposal using an "alternate technology", next year .
Systematically sample non-hazardous debris to ensure materials aren't contaminated by PCB laden dust.
Selectively remove contaminated items for disposal or recycling as EPA' s off-site disposal policies permit . (i.e. used batteries)
Identify and neutralize any acid contaminated soils.
Ensure no other, previously obscurred, hazardous wastes are presently on-site.
Address the contamination of the shallow ground water table; define the extent of contamination and ensure off-site migration is minimized.
See site file for additional information. |
Jim Hayden |
| 5/29/1987 |
Update or Other Action |
EPA Emergency Response Team and EPA Contractors conducted additional site assessment including installing seven temporary monitoring wells, shallow surface soil borings, off-site sampling along Ship Creek. |
Jim Hayden |
| 6/1/1987 |
Update or Other Action |
June-October 1987: EPA conducted phase II of removal action. Approximately 781,000 pounds of batteries and 10,450 gallons of waste oils were recycled, 1,600 cubic yards of PCB contaminated soils were stockpiled and sprayed with temporary concrete fiber cap. Contaminants remaining on site have been secured. Contaminated soils stored on site are coated with a cement/fiber mixture to immobilize. Dioxin contaminated ash/soil is secured on-site in steel connex boxes. |
Bill Lamoreaux |
| 8/15/1987 |
Update or Other Action |
EPA Factsheet #7. Completed Activities- Batteries: All of the used vehicle and miscellaneous batteries, (approximately 500,000 pounds) have been containerized and shipped offsite. Non-leaking batteries were palletized and shipped out for processing as hazardous materials according to DOT regulations. The remaining batteries which made up the majority, were damaged and leaking to the point that they had to be handled as hazardous waste and shipped accordingly. These batteries were placed in plastic tote bins and shipped to an out of state RCRA permitted, treatment-disposal facility.
Drums: A pile of over 700, mostly empty, fifty-five gallon drums were removed to clear room for soil excavations. These drums, along with 500 others which were left empty onsite at the completion of last year's activities, were deheaded, steam-c leaned and removed from the site. Non-hazardous Drummed Materials: Several hundred drums containing
non-hazardous materials left after last year's activities have been properly disposed of.
Planned Activities: Excavation of PCB and lead contaminated soils will begin shortly. Field
testing will aid in delineation of 11 hot 11 and clean zones. Soils within the fence will be cleaned down to established levels which will pose no threat to human health or the environment. Contaminated material will be staged onsite until next year when it is anticipated that it will be treated onsite. |
Jim Hayden |
| 10/13/1987 |
Update or Other Action |
EPA Factsheet #8. Completed Activities:
Excavations of PCB contaminated soils above 10 ppm immediately adjacent to the site, outside the fence line is complete. Areas on Yakutat Street, the Alaska Rep./Standard Steel & Metals Salvage Yard parking lot, and Johnny Jackson's auto salvage yard have been scraped and back filled with clean gravel. Contaminated soils have been staged onsite.
Dioxin contaminated material, previously boxed up in the Standard Steel warehouse have been placed in a steel connex box and secured onsite within the fenced-off area.
A building which housed a hydraulic bailer/crusher contaminated with PCBs was decontaminated and torn down to facilitate excavation of underlying contaminated soils.
Contaminated soils stored onsite were coated with gunnite, (a cement and fiber mixture) to prevent the possibility of fugitive dust pollution in the area.
Areas targeted for soil excavations within the fence line have been cleared of debris and scrap.
The 1987 removal activities were terminated October l. In addition to the above mentioned activities, over half a million pounds of used batteries, 700 decontaminated drums and several hundred containers of non-hazardous materials were cleared from the site to facilitate access to contaminated soils and prevent further pollution.
Planned Activities:
The entire site will remain fenced-off and secured throughout the winter. Water samples will be collected from ten monitoring wells installed on and around the site on a quarterly basis. Soil excavations are anticipated to continue next year during the 1988 field season
See site file for additional information. |
Jim Hayden |
| 1/1/1988 |
Update or Other Action |
(Old R:Base Action Code = REM - Removal / Excavation). June 1988: EPA conducted final phase of removal action. These activities were primarily focused on securing the site until further remedial actions could be undertaken. During 1988 no wastes were generated or transported under this CERCLA removal action. |
Jennifer Roberts |
| 12/30/1988 |
Update or Other Action |
EPA Factsheet: SS&MSY (USDOT). Work during tl1e 1988 season completed the removal action by securing the site in preparation for long-term cleanup. EPA's 1988 activities included sealing the soil surface in the most highly contaminated areas, removing the remaining containers of hazardous materials , and reworking and strengthening the security fence.EPA plans to negotiate for further cleanup with parties potentially responsible for wastes associated with the site. |
Bill Lamoreaux |
| 7/14/1989 |
Update or Other Action |
July 14, 1989 US EPA proposed the Site for inclusion on the National Priority List (NPL). 54 Fed. Register 29820 (July 14, 1989). Sixty day comment period initiated. |
Jim Hayden |
| 7/20/1989 |
Update or Other Action |
US DOT FRA Memorandum to EPA Kathy Hutson Office of Federal Activities. RE: Narrative summaries for federal facilities NPL Updates EPA Memorandum of June 9, 1986. We would like to point out that the United States, through the authority delegated by the Congress to the Secretary of Transportation in Section 604(a) of the Alaska Railroad Transfer Act of 1982 ("ATRA"), 45 U.S.C. Section 1203(a), sold the land in question to the Alaska Railroad Corporation ("ARRC") on January 5, 1985 (the "Transfer Date"). Because of the peculiarities of land ownership in Alaska stemming from the of myriad types of claims (i.e., mining claims, Native claims, and State Selection claims with their origin in Alaska Statehood), in order to expedite the sale and
transfer process, the Congress legislatively determined that perfection of the title to the real estate conveyed could take place subsequent to the Transfer Date. In fact, that technical
process is still ongoing under the supervision of the Bureau of Land Management, U. S. Department of the Interior.
Hence, the Congress determined in its enactment of Section 604(b)(l)(C) of ARTA that certain lands should be transferred simultaneously to the state as an integral part of the January 5th Transfer, including all beneficial and equitable interest in those lands and all rights to use them and enjoy their profits and rents; the United States was left only interim bare legal title in certain of the lands to facilitate the ministerial completion of that process. 2 That
is precisely the case with the Standard Steel Site (as shown the attached Exclusive License on file in the Anchorage Recording District, recorded in Book 1212, pages 0297-0352.) sum, the ARRC holds, pursuant to the statutorily created exclusive license, all beneficial and equitable interests in the Standard Steel Site.
See site file for additional information. |
Jim Hayden |
| 8/10/1989 |
Update or Other Action |
USEPA AK Ops Office letter ot ADEC Dennis Kelso Commissioner RE: Federal Facility National Priority List Sites. On July 14, 1989, the Environmental Protection Agency (EPA) proposed listing
the following Alaska Federal Facilities on the Superfund National Priorities List (NPL): Eielson Air Force Base, Elmendorf Air Force Base, Fort Wainwright, and Standard Steel Metals and Salvage Yard.
The next step in the NPL process is to develope three party Inter-Agency Agreements (IAG's) including each facility the State of Alaska Department of Environmental Conservation (ADEC) and EPA. The Alaska Operations Office is committed to effecting signed agreements according to the following schedule 1st Quarter FY 90: Eielson Air Force Base, Elmendorf Air Force Base,
Fort Wainwright, and Standard Steel
In order to initiate the IAG process, we request ADEC identify a policy negotiating team consisting of an attorney and staff members of the Central Office Oil and Hazardous Substance Spill Response Branch and Hazardous and Solid Waste Management Branch. In addition, a senior management person who has the authority to speak for the State and participate in the negotiations
and dispute resolution needs to be identified. We would appreciate receiving this list by August 20, 1989.
As you know, EPA and ADEC staff members have begun informal discussions pertaining to ADEC's oversight and document review for the proposed NPL sites. These oversight and review tasks are to be provided through an EPA grant to ADEC. Furthermore, as a part of the negotiations with each Federal Facility, these tasks and funds are to be incorporated into a follow up grant from each facility to ADEC.
Signed Alvin L. Ewing, Assistant Regional Administrator. |
Lynn Kent |
| 1/2/1990 |
Update or Other Action |
ARRC Letter to EPA Hazardous Site Evaluation Division OSWER RE: NPL Proposed Update #9 Comments on the Standard Steel Site. This letter is submitted to clarify certain title issues raised by the FRA and assist in your consideration of the Standard Steel & Metal Salvage Yard site.
The FRA suggests that ARRC holds full equitable title to the Standard Steel site and that only technical. ministerial acts remain to divest FRA of any interest in the property. They thus argue that the site does not qualify for listing on the NPL as a "federal facility". With all due respect, FRA's characterization of its status as holder of "bare legal title" for a limited amount of property overlooks the primary reason for the admittedly unique conveyance process. Examination of the Alaska Railroad Transfer Act ("ARTA") and its legislative history reveals a complex conveyance process necessitated ·not only by the sheer dimensions of the transfer. but, more importantly, by questions regarding the status of the United States' title.
The ARRC has only an "exclusive license" for the Standard Steel site. with legal title remaining in the United States government. On January s. 1985. the ARRC received a patent or interim conveyance for those properties whose title was clearly vested in the federal government. However. an "exclusive license" (such as the one appended to FRA's comment) was issued where title ~as not clearly vested in the federal government for lands subject to claims of valid existing rights of third parties. see 45 U.S.C. 1203(b)(l)(B) & (C). For these latter properties. an adjudication of any such existing claims must be made by the Department of the Interior's Bureau of Land Management prior to any further conveyance. This overall
process is hardly ministerial.
We believe your original treatment of the Standard Steel site as a federal facility is correct. Indeed. EPA must rely on title records since it has neither the authority nor expertise
to resolve conflicting 'title issues. If the site is to be added to the NPL. it is most appropriately described as a federal facility.
See site file for additional information. |
Jim Hayden |
| 8/30/1990 |
Update or Other Action |
August 30 1990 EPA placed the site on its National Priorities Listing (NPL) of hazardous waste sites requiring cleanup. 55 Fed. Register 35502 (August 30, 1990). |
Jennifer Roberts |
| 11/20/1990 |
Site Ranked Using the AHRM |
Initial ranking. |
Jennifer Roberts |
| 10/8/1991 |
Update or Other Action |
USDOT FRA letter to USEPA Assist. Reg. Counsel Lori Houck. Obviously, a threshold question of paramount importance is whether it is appropriate for an agency to enter into a "Federal Facility Agreement" with respect to property or facilities which are no longer in the federal domain.
January 5, 1985 the [Federal] railroad was conveyed out of the Federal government to State ownership [Alaska Railroad]. Hence, we did not have, and do not have on our staff now,
a technical person of the type whom you requested that we include on an FRA negotiating team. Nevertheless, we have had discussions with the Corps of Engineers about the prospects of entering ·into an interagency agreement commencing in fiscal year 1992 for their provision of technical assistance, and advising in negotiations with you. The Corps may also be able to help in our mutual determination as to which third parties may be responsible, so as to minimize uncalled for adverse impacts on the Federal government's budget by allotting cleanup costs at the outset to those actually responsible for causing any contamination.
Further, as I am certain you can appreciate in light of our telephone conversations, it will be necessary for us to have finalized our understanding with the Alaska Railroad Corporation (ARRC), and to have secured their active participation (as they must be a signatory to any agreement with EPA) prior to our negotiation sessions.
We are still awaiting our appropriations: we have asked the Congress, to be expended on these matters, for $1 million for fiscal year 1992; and have estimated to the Congress future needs at $2 million for fiscal year 1993; and $3 million for fiscal year 1994.
See site file for additional information. |
Bill Lamoreaux |
| 12/6/1991 |
Enforcement Action |
On December 6, 1991, the United States filed a lawsuit under Section 107 of CERCLA, 42 USC 9607, against eight parties for recover of EPA's costs incurred in performing the removal action and determination of liability for future costs. The eight parties sued were the Alaska Railroad Corporation, Ben Lomand Inc., Chugach Electric Association, Inc., Westinghouse Electric Corporation (Now CBS Corp.), Sears, Roebuck and Co., Montgomery Ward and Co., Inc., J.C. Penny Company, Inc., and Bridgestone/Firestone Inc.
Certain other Federal entities are considered to be within the class of persons who may be liable under CERCLA. Those entities are the Federal Railroad Administration, Department of Transportation, Defense Reutilization and Marketing Service, Department of Defense, and The Army/Air Force Exchange Service. |
Jennifer Roberts |
| 12/12/1991 |
Enforcement Action |
AK Dept. Of Law letter to Federal Railroad Administration (FRA) USDOT, Acting Administrator for USDOT, and Administrator USEPA regarding Notice of intent to bring citizen's suit under 42 U.S.C. 9659 (CERCLA 310). Pursuant to 42 U.S.C. §9659( d), the State of Alaska gives notice of its intent to bring a citizens suit action against the United States Department of Transportation (USDOT) and the Federal Railroad Administration (FRA) to compel their performance of hazardous waste investigation and cleanup responsibilities at the Standard Steel & Metal Salvage Yard site owned by the federal government.
On August 30, 1990, the Standard Steel site located along Ship Creek in Anchorage, Alaska was formally listed on the National Priorities List (NPL) by the United States Environmental Protection Agency (EPA) as a Federal Facility. 55 F.R. 35502, 35509 (August 30, 1990). The United States Department of Transportation was designated as the federal agency responsible for investigation and remediation of the site. Id. Section 120 of CERCLA mandates that "[n]ot later than 6 months after the inclusion of any facility on the National Priorities List, the department, agency, or instrumentality which owns ... such facility shall, in consultation with the Administrator and appropriate State authorities, commence a remedial investigation and feasibility study [Rl/FS] for such facility." 42 U.S.C. § 9620( e) (emphasis added).
More than 15 months have passed and USDOT /FRA have not commenced the required RI/FS. On July 29, 1991, the United States Environmental Protection Agency requested that USDOT/FRA enter into a pre-RI/FS Interagency Agreement (hereinafter Federal Facility Agreement) with EPA and the State of Alaska to establish a framework for the investigation and cleanup of the site. The USDOT/FRA has refused to enter into a Federal Facility Agreement with EPA and the State of Alaska.
Since the United States Department of Justice refuses to bring suit on behalf of EPA to bring federally owned facilities into compliance with federal environmental laws, it falls to the states and the citizens of those states to ensure that these laws enacted to protect human health and the environment are enforced. To ensure that the State of Alaska's statutorily mandated role in cleanup of these federal NPL sites is protected and that the hazardous wastes at the Standard Steel site are cleaned up, the State of Alaska, on behalf of its Department of Environmental Conservation gives notice that it will file a Section 310 citizen suit.
See site file for additional information. |
Jennifer Roberts |
| 2/10/1992 |
Update or Other Action |
DEC Letter to Environmental Investigative Services Deerfield Illinois. Enclosed find the OSC Report for SSMS Yard. DEC has two supplementary files consisting of sample results, EPA correspondence, the federal on-scene coordinator's report and the preliminary site assessment
prepared by Region X. These files contain approximately 204 pages. The cost per
copy is twenty-five cents; if you would like copies, please let us know.
See Site File for additional information. |
Jennifer Roberts |
| 4/21/1992 |
Update or Other Action |
USDOT FRA Letter to EPA Director HW Mgt. Division.
We understand that you have requested an advance commitment from the Federal· Railroad Administration (FRA) to reimburse the Hazardous Substance Superfund for monies committed or to
be expended by EPA Region 10 1n connection with conduct of the remedial investigation and ·feasibility study (RI/FS) at the standard steel·Site in Anchorage, Alaska. FRA will accede to the Department of Justice's urging in this respect in order to facilitate and expedite the commencement of the RI/FS.
As you know, several of the non-federal potentia1ly responsible parties (PRPs) will be conducting the RI/FS at the site pursuant to an administrative order on consent (AOC), which is currently being negotiated with EPA Region 10. The AOC will also provide for payment of EPA response costs incurred in connection with the RI/FS. By separate ·agreement with the non-federal parties, FRA and other federal agency PRPs will pay only a defined share of these RI/FS costs.
In accordance with and subject to the terms of the AOC and the federal agencies agreement with the private PRPs, FRA will reimburse Superfund costs incurred by EPA at the Site in connection with the RI/FS. If negotiations over either of these agreements are unsuccessful, this letter shall have no effect, however.
In providing this commitment, FRA makes no admission as to current ownership of the site, and reserves its rights to challenge designation of the ·site as a "federa1 facility."
See site file for additional information. |
Jennifer Roberts |
| 6/5/1992 |
Document, Report, or Work plan Review - other |
ADEC comments on the management plan. The plan does not address off-site soil or groundwater contamination. Previous groundwater analysis of this site has shown that contamination is present in the groundwater. Off-site groundwater must ultimately be addressed. These issues, field sampling, the off-site extent of soil and groundwater contamination, should be addressed within the management plan and submitted within the draft Remedial Investigation.
The report states that monitoring wells will be installed with screens which will extend
across the entire area of the unconfined aquifer. The Department recommends the use of nested wells. The nested wells would determine the presence of light none aqueous phase liquids (LNAPL's), and dissolved phase contaminants, dense none aqueous phase liquids (DNAPL's) .
The nested wells should be include at the minimum the following components: one well screened at the water table level, which can be used to monitor the presence and thickness of floating product (LNAPLs), one well screened at a relatively shallow depth below the water table, which can be used to sample shallow groundwater without possibly entraining floating product, and one well should be screened at the bottom of the shallow aquifer in order to detect dense nonaqueous phase liquids (DNAPLs).
A .02-inch slot size screen is proposed for monitoring well construction. Due to problems with sediments in the area, the screen size and the annular pack should be selected based on sieve analysis.
See site file for additional information. |
Jennifer Roberts |
| 6/25/1992 |
Update or Other Action |
EPA Letter to M Siroky SPAR Notification of Federal Natural Resource Trustees SS&MS Yard.
In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 ("CERCLA"), as amended by Superfund Amendments and Reauthorization Act ("SARA"} of 1986, Sections 104 (b) (2) and 122(j), 42 U.S.C. §§ 9604(b) (2) and 9622(j ), the United States Environmental Protection Agency ("EPA") hereby notifies your Agency of negotiations with potentially responsible parties {"PRPs") for conducting a Remedial Investigation/Feasibility Study ("RI/FS") and of potential damages to natural resources resulting from releases under investigation at the Standard Steel and Metals Salvage Yard in Anchorage, Alaska.
In January of 1991 NOAA prepared a Preliminary Natural Resource Survey for the site. EPA encourages NOAA to provide any additional concerns which may need to be addressed in the Remedial Investigation.
See site file for additional information. |
Jennifer Roberts |
| 6/29/1992 |
Update or Other Action |
EPA Letter to ADEC Notification of Federal Natural Resource Trustees SSMS Yard. In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 ("CERCLA"), as amended by Superfund Amendments and Reauthorization Act ("SARA") of 1986, Sections 104 (b) (2) and 122(j), 42 U.S.C. §§ 9604(b) (2) and 9622(j), the United States Environmental Protection Agency ("EPA") hereby notifies your Agency of negotiations with potentially responsible parties ("PRP") for conducting a Remedial Investigation/Feasibility Study ("RI/FS") and of potential damages to natural resources resulting from releases under investigation at the Standard Steel and Metals Salvage Yard in Anchorage, Alaska.
In January of 1991 National Oceanographic and Atmospheric Administration ("NOAA") prepared a Preliminary Natural Resource Survey for the site. EPA encourages NOAA to provide any
additional concerns which may need to be addressed in the Remedial Investigation.
See site file for additional information. |
Jennifer Roberts |
| 7/2/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: Specific comments on the Standard Steel and Metals Salvage Yard RI/FS WP. These comments constitute the United States Environmental Protection Agency ("EPA") concerns on sampling needs for conducting an ecological risk assessment, air monitoring at the Site and general editorial changes. Specific comments on groundwater and soil sampling have been included for inclusion in the revised Draft Workplan submittal. These comments are in addition to EPA's June 18, 1992 transmittal of comments concerning groundwater and surface sampling.
These comments were verbally presented to you during our June 25, 1992 meeting at your office. At that meeting we agreed that Woodward-Clyde Consultants would address these concerns in a draft final submittal of the RI workplan in the next couple of weeks.
An in-depth or refined air pathway analysis method, such as air monitoring, should not be implemented without first assessing the impacts of the Site using screening techniques or evaluating a conceptual site model. It should be determined whether contaminants present at the Site may be presenting a threat via an air pathway to the environment and human populations.
The need for determining whether deposition of dioxin contaminated ash is posing an unacceptable risk must be evaluated. This may be done by determining the predominant
wind direction, review of local meteorological information should be sufficient, estimating emission characteristics of the furnace and taking a representative number of samples in
the appropriate areas.
The sampling regime proposed in the workplan is not adequate for fully determining the spatial extent of contamination. In particular, surface soil and sediments outside the fenced area that could be affected by contaminant migration from the Site should be sampled. Data summarized in the On-scene Coordinators Report ("OSC"), (E&E 1988, Appendix B) indicate that polychlorinated biphenyls ("PCBs") were detected east of the fence line on Yakutat Street and outside the fence
line on the north and south side of the property (vicinity of Repertory Theater Bldg., Johnny Jackson Auto Yard, and personnel carriers area). The OSC report does not state that samples were taken from the unfenced area between the fence and Ship Creek, where a variety of debris is currently stored. Areas between the fence and Ship Creek may be important habitats for ecological receptors of concern at the Site. Additional sampling of surface soils and
sediments should be undertaken in these areas to determine the extent of a contaminant plume and ecological exposure point concentrations.
Elevated levels of PCBs, lead, and volatile organic compounds ("VOC") have been detected in surface, subsurface and groundwater samples at the Site. Based on significant driving forces (rain and snowmelt) and high groundwater flow velocities in the Site area, contaminants could be migrating into adjacent Ship Creek via the groundwater and should be characterized.
See site file for additional information. |
Jennifer Roberts |
| 7/8/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: Preliminary Remediation Goals for SS&MS Yard. Pursuant to Section 300.430(e) of the National Contingency Plan ("NCP") and Section 121 of the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA") I have developed a list of Preliminary Remediation Goals ("PRGs") for determining initial long term targets to use during analysis and selection of remedial alternatives at the standard steel and Metals Salvage Yard in Anchorage, Alaska ("Site"). These PRGs have been developed from readily available information and past sampling activities at the Site. A list of potentially Applicable or Relevant and Appropriate Regulations ("ARARs") has been included in order to facilitate early screening of ARARs.
These goals will be modified, as necessary, as more information becomes available during the remedial investigation/feasibility study ("RI/FS") at the Site. It is important to remember that PRGs do not establish that cleanup to meet these goals is warranted or, PRGs are considered final remediation levels. Final remediation levels will be determined from information gathered in the RI/FS, and presented in the Site Record of Decision.
These PRGs are chemical/media specific and are based on protectiveness of human health, they are not applicable for ecological sampling. I have included a list of references which
will provide you with information for determining ecological sampling detection limits and preliminary criteria screening levels . If you require additional EPA input for ecological
sampling please contact Bruce Duncan at (206) 553-8086.
Potential ARARs
STATE of ALASKA ARARs
18 Alaska Administrative Code ("AAC") Chapter 50, Air Quality Control Regulations, July 21, 1991
18 AAC Chapter 60 (1987); Solid Waste Management Regulations
18 AAC Chapter 70 (Dec. 1989); Water Quality Standards
18 AAC Chapter 72 (1990); Waste Water Disposal Regulations
18 AAC Chapter 75 (May 1992); Oil and Hazardous Substances Pollution Control Regulations
18 AAC Chapter 80 (1991); Alaska Drinking Water Regulations
See site file for additional information. |
Jennifer Roberts |
| 7/22/1992 |
Update or Other Action |
EPA Factsheet Superfund Community Relations Plan. This Community Relations Plan describes ways the U.S. Environmental Protection Agency (EPA) plans to keep you informed about and involved in the cleanup activities at the Standard Steel site in Anchorage. The plan summarizes the community concerns we learned about during our May 1992 telephone interviews. It also describes the communication tools we will use to keep the community informed and involved throughout the cleanup.
EPA encourages your interest and involvement in the activities we are conducting at the site. If you have any comments or suggestions, please call or write one of the following EPA representatives:
Grechen F. Schmidt, Community Relations Coordinator, (206) 553-1283 or Christopher Cora, Project Manager, (206) 553-1148 or call toll free, Monday through Friday 8:00 a.m. to 4:30 p.m. 1-800-424-4372 U.S. Environmental Protection Agency 1200 Sixth Ave. Seattle, WA 98101
See site file for additional information. |
Jennifer Roberts |
| 7/31/1992 |
Update or Other Action |
RIFS Scope of work received by ADEC from EPA. The purpose of this Remedial Investigation/Feasibility study (RI/FS) is to investigate the nature and extent of contamination
at the Standard steel Metals and Salvage Yard ("Site") located in Anchorage, Alaska and develop and evaluate remedial alternatives. The RI and FS are interactive and may be conducted concurrently so that the data. collected in the RI influences the development of remedial alternatives in the FS, which in turn affects the data needs and the scope of treatability studies. The Respondents will conduct this RI/FS (except for the baseline risk assessment component) in accordance with the Administrative order on consent ("AOC") to which this Statement of Work is attached. Respondents will produce draft RI and FS reports that are in accordance with this SOW, the Guidance for Conducting Remedial Investigations and Feasibility studies under CERCLA (U.S. EPA, Office of Emergency and Remedial Response, October 1988, OSWER Directive No. 9355.3-01) (the "RI/FS Guidance"), and other guidances that the U.S. Environmental Protection Agency {"U.S. EPA") uses in conducting a RI./FS (a list of primary guidance is attached). The RI/FS Guidance describes the report format and the required report content. The Respondents will furnish all necessary personnel, materials, and services needed, or incidental to performing the RI/FS, except as otherwise specified .in the AOC.
At the completion of the RI/FS, U.S. EPA will be responsible for the selection of a site remedy, which it will document in a Record of Decision ("ROD"). The final RJ./FS report, as adopted by U.S. EPA, and U.S. EPA's baseline risk assessment, together with the administrative record, wi11 form the basis for the selection of the remedy at the site and will provide the information necessary for preparation of the ROD.
The remedial action alternative selected by U.S. EPA will meet the cleanup standards specified in Section 121 of the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), as amended by the Superfund Amendments and Reauthorization Act of 1986 ("SARA"), 42 U.S.C. §1621. That is, the selected remedial action will be protective of human health
and the environment, will be in compliance with, or include a waiver of, applicable or relevant and appropriate requirements of other laws, will be cost-effective, will utilize permanent
solutions and alternative treatment technologies or resource recovery technologies, to the maximum extent practicable, and will address the statutory preference tor treatment as a
principal element.
See site file for additional information. |
Jennifer Roberts |
| 8/10/1992 |
Document, Report, or Work plan Review - other |
DEC Letter to EPA RE: SOW SS&MS Yard. The SOW as drafted by the EPA does not adequately involve (DEC) in the overall plan for the Standard Steel site. The SOW document in particular overlooks the Department's interest in providing and assisting EPA in the oversight of assessment and ultimately remediation of contamination at the Standard Steel site. As stated previously, DEC requests that a mechanism be negotiated between DEC and EPA which will allow the state a cooperative and significant role in decision making processes related to this site.
The Department overall does not disagree with the technical points brought out in the SOW with
the exception of the scrap removal issue. Scrap removal as a facet of the plan was not delineated in the SOW nor was there any indication that it would be detailed in a later phase.
The Department is looking forward to negotiating a mutually agreeable and beneficial settlement to our differences.
|
Jennifer Roberts |
| 8/31/1992 |
Update or Other Action |
Agency for Toxic Substances and Disease Registry (ATSDR) health consultation report received. USEPA requested agency to determine if levels of dioxin and furans at the Site warrant further action. Report recommends that dioxin and furan contamination of surface soil may pose a health risk and additional sampling should be conducted. EPA requests dioxin and furan sampling regime be implemented during the remedial investigation. |
Jennifer Roberts |
| 9/14/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: Comments on the Sept. 1, 1992 SS&MS Yard Work Plan Sections 4.1-4.4. EPA has expedited its review of the Workplan in order to allow field work to be conducted during the 1992 field season. These comments do not constituent all of EPA's concerns for the Workplan and are dependent upon receiving the signed Administrative Order on Consent, which is required prior to conducting any field work at the Site. The Alaska Department of Environmental Conservation ("ADEC") has conducted an initial review of the Workplan and their
comments are incorporated in this submittal.
Specific discussions and details of anticipated phase II activities are not provided in the work plan. Criteria for determining RI/FS data gaps after phase I are not provided. Phase II sampling requirements, particularly in areas that are currently inaccessible due to scrap materials, are not specifically identified. The development of a phase II work plan is recommended. Due to time constraints for the ~992 field season, EPA will consider approving specific phase I activities and tasks, but defer on providing overall approval of the RI/FS management plan.
Rationale are not provided for the methods proposed in the work plan for selecting site-specific target analytes. EPA. recommends that the method be ·equivalent to EPA Region 10's risk assessment guidance for determining chemicals of concern (EPA 1991). This method requires that maximum detected contaminant concentrations be compared to risk-based concentrations. If a sample exceeds the risk based concentration, as presented in the Preliminary Remediation Goals that contaminant will be considered a site-specific target analyte.
Analytical methods should to the extent practicable be capable of providing detection limits at or below EPA maximum contaminant levels (MCLs) and risk-based concentrations equivalent to cancer risks of 1 x 10-6. The methods proposed in Table 4-1 do not provide detection limits below 10-6 risk-based concentrations for the analysis of groundwater for all volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and polychlorinated biphenyl compounds (PCBs). Moreover, the proposed method for SVOC analysis of soils has not provided
sufficiently low detection limits for all target compounds
See site file for additional information. |
Jennifer Roberts |
| 9/16/1992 |
Update or Other Action |
EPA Letter to DEC. RE: Aerial Photos SS&MS Yard. I have received a set of interpreted aerial photographs for the Standard Steel and Metals Salvage Yard ("Site") in Anchorage ,
Alaska from our Environmental Photographic Interpretation Center ("EPIC"). The photographs extend significantly beyond the property lines of the Site and date back to 1939. I thought
these photos would assist Alaska Department of Environmental Conservation ("ADEC") both in investigations in the area of lower Ship Creek and at the Site. I am also sending a set to the
parties entering into the Administrative Order on Consent for the Site and anticipate they will utilize them for refining sampling locations at the Site. |
Jennifer Roberts |
| 9/23/1992 |
Document, Report, or Work plan Review - other |
DEC letter to EPA RE: Comments on the 9/1/1992 SS&MS Yard Work Plan. The report is not clear what will identify the beginning and ending points of the different phases proposed for the project, nor is it clear on how will the different phases will feed into each other.
It is the Department's understanding that a revised field sampling plan will be submitted at a future date. The Department will not comment on the current field and sampling plan. A conditional approval of this workplan will be granted based on the submittal and final approval of the field sampling plan. The presence of paleo-channels must be further investigated. This information can be investigated by inspection of the available geologic, hydrogeologic and areal photos of the area by a qualified sedimentologist. Field method may include continuous loggers and ground penetrating radars (GPA).
Section 2.6.2.2, page 2-14
The report states that "potentially significant exceeds only for trichloroethene, trichloroethylene and trichlorobenzene." It was also concluded in the report that only
trichlorobenzene may effect cleanup decisions. The report fails to mention that there are other contaminants that exceed the risk based criteria or the maximum contaminant level on site. Any contaminant that exceeds the maximum cleanup level or the risk based criteria is significant and may effect the cleanup level. The rational for basing the cleanup only on trichlorobenzene is unclear.
Section 4.1.1, Page 4-3
The comprehensive analytical test that are outlined in table 4-1 describes the use of methods 8240, 8270, and 8080 which do not supply sufficiently low enough detection limits. Alternative analytical methods with reporting limits that meet or exceed the Maximum Contaminant Levels (MCLs) or the 10"6 risk based concentrations should be used at the time of the initial remedial investigation sampling.
Section 4.1.2, Page 4-4
The report states that for ground water, the method in which a chemical will be placed on the target analyte list is if the chemical is measured at a concentration equal to or greater than the PRG in two or more wells, or if it exceeds double the concentration of the PRG in one well. The Department does not agree nor does it understand the rationale behind this selection criteria. The Department requests that every sample that exceeds the maximum contaminant level (MCL) or the risk based concentration, whichever is more stringent even if found only once will be placed on the target analyte list.
See site file for additional information. |
Jennifer Roberts |
| 9/25/1992 |
Update or Other Action |
WCC Letter to EPA RE: MW Locations and Installation Procedures. The maximum screen length for a single screen well installation will be 10 feet. Where the saturated thickness appears to exceed 8 feet, two clustered wells will be used. Clustered wells will be installed within 5 feet of each other and will utilize 5 foot screen sections (one shallow and one deep). The
exception to this, as discussed in our phone conversation of September 25, 1992, will be the three background wells (K, L, and Mon the attached figure) for which IO foot screens will be used, bottomed on the aquitard.
• Screen slot size and sand pack grain size will be reduced, as appropriate, if actual soil conditions at the actual screen location are observed to be finer grained than as anticipated in the Work Plan (eg.: 0.010 inch slots and I0-20 sand).
• Two soil samples from each monitoring well location will be analyzed for PCBs and lead. Samples submitted will be from the ground surface and from just above the groundwater table as estimated in the field. Analyses will be high resolution/Level 3, with an estimated detection limit for PCBs of 0.1 mg/kg (PCBs will be quantitated by aroclor).
See site file for additional information. |
Jennifer Roberts |
| 9/25/1992 |
Enforcement Agreement or Order |
EPA Region 10 issues a final Administrative Order on Consent for Remedial Investigation/Feasibility Study, proceeding under Sections 104, 106, 120(e)(6), 122(a) and 122(d)(3) of CERCLA as amended 42 USC 9604, 9606, 9620(e)(6), 9622(a), and 9622(d)(3). US EPA Docket Nos. 1091-07-02-107 and 1091-07-01-120. Effective date for all deliverables is established as 9/25/92. Respondent Chugach Electric Association entered voluntarily into order with EPA.
The U.S. through Federal Railroad Administration (agency within USDOT) owned site for many years, early 60s site leased through Alaska Railroad to various metal salvage recycling businesses. Current lessee of Site is Ben Lomand Inc. which subleased a large portion of the Site to Standard Steel and Metals (owned by Gerald Poirier).
PCB contamination as high as 165,000 mg/kg was found in soils on-site, soil samples for PCBs from roads on and off-site ranged from traces to 220 mg/kg. Soil samples on-site also indicated high levels of lead and significant levels of cyanide and trichlorobenzene. Ash samples from the on-site incinerator contained dioxin with Toxic Equivelant Factor ("TEF") values as high as 5.71 parts per billion ("ppb"). Off-site migration of PCBs was documented in stream sediment sampling conducted along Ship Creek, which indicated 2.5 mg/kg PCBs downstream of the site.
Pursuant to the Consent Order, the Respondent, Chugach Electrical Association, is required to complete a remedial investigation and feasibility study, as provided under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA).
The first deliverable under the Order will be a draft final workplan due within 30 days of the effective date of the Order. Woodward Clyde Consultants will be on site October 5, 1992 to install groundwater monitoring wells and begin surface soil sampling.
Not all persons identified as potentially responsible parties for this Site are Respondents in this Consent Order. Certain federal agencies, including the US Department of Transportation, (including the Federal Railroad Adminstration) and US DOD (including the Defense Logistics Agency, and the Defense Reutiliztion and Marketing Service) are paying a portion of the costs of the RI/FS pursuant to a separate Funding Agreement with the Respondent. Other potentially responsible parties identified for the Site are not partcipating in this Order.
Project Coordinators: Formerly EPA Christopher Cora Federal Facility Branch (HW-124) US EPA Region 10 1200 Sixth Avenue Seattle WA 98101, as of March 6, 2003 Kevin Oates EPA Alaska Operations Office Anchorage, AK was the project Coordinator, June 1, 2005 Jacques Gusmano AK Ops Office and for Respondent: Alex Tula Woodward Clyde Consultants 3440 Bank of California Center 900 Fourth Avenue Seattle WA 98164. Alex Tula now works for Alta Geosciences 22833 Botthell-Everett Hwy. Suite 102 #1168, Bothell, WA 9802-8282
(current as of March 6, 2005). |
Jennifer Roberts |
| 9/30/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: 1992 Field work at SS&MS Yard. The letter. adequately addresses EPA concerns, with the following clarifications:
If clustered wells are installed the well screens should not overlap. This will enable collection of groundwater samples from discrete portions of the aquifer. Wells must be installed without the use of binding agents like glue or epoxy. Wells screened at the Bootlegger Cove Aquic lude must be designed to collect dense non-aqueous phase liquids at the
top interface between the shallow aquifer and the Bootlegger Cove formation. This letter is i ntended to allow Woodward-Clyde to install monitoring wells within the 1992 field season. It is not an approval letter for the Management Plans submitted on September 1, 1992.
See site file for additional information. |
Jennifer Roberts |
| 10/2/1992 |
Update or Other Action |
EPA Factsheet. Last month, Chugach Electric Association, one of the potentially responsible parties (PRPs) for the contamination at the Standard Steel site, signed a legal document with EPA called an administrative order on consent. The consent order requires the PRP to characterize the nature and extent of contamination at the site and analyze possible cleanup alternatives. The consent order also requires the results of this work to be submitted to EPA, as a Remedial Investigation/Feasibility Study Report, within twenty-eight months.
Chugach Electric Association has reached a tentative agreement with two federal agencies, which are also PRPs for the site, for partial funding of the Remedial Investigation/Feasibility Study.
With EPA oversight and technical support from the Alaska Department of Environmental Conservation, the electric association is initiating the investigation of the Standard Steel site this month. During the month thirteen groundwater monitoring wells will be installed and the surface and subsurface soil will be sampled. In the winter of 1992 the groundwater monitoring wells will be sampled for PCBs, toxic metals, and other hazardous compounds often found at Superfund sites.
Field investigations will resume at the site during the spring and summer of 1993. Additional samples will be taken of groundwater and soil. Water and sediment samples will also be taken from Ship Creek to determine whether contaminants from the site are impacting the creek.
While the investigation under the consent order proceeds, EPA will conduct a risk assessment to evaluate potential risks to human health and the environment from the contamination at the site.
See site file for additional information. |
Jennifer Roberts |
| 10/2/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: Final comments on the 9/1/1992 WP. The workplan should identify that the purpose of the remedial investigation/feasibility study is to supply additional information which the previous investigations did not obtain. Specifically that the investigation is looking for additional areas of contamination and contaminants not previously identified or sampled. Although information currently available is sufficient to establish the need for conducting remedial actions at the site, additional sampling is required for conducting a baseline risk assessment.
Soil, sediment, and surface water sampling of the off-site migration pathways between the site boundary and Ship Creek is not planned. Some runoff, along with sediments from the site, may be captured and deposited in small depressions or low-lying areas in the riparian zone between the site and Ship Creek. The workplan and field sampling plan should include a rationale and sampling and analytical procedures for off-site surface soil, sediment, and surface water sampling. Samples should be collected from areas between the site and Ship Creek that may be affected by site-related contaminant migration. For example, shallow water-filled depressions were seen between the site and Ship Creek in the Spring of 1992. These depressions may collect surface runoff from the site, or may be an expression of the water table downgradient of the site.
Sediment sampling in the creek is proposed in areas adjacent to the site and in areas potentially affected by storm water runoff from the site. Additional sediment sampling is
recommended to evaluate the impacts of contaminated sediment loads along the reach of Ship Creek adjacent to and downstream of the site. Also, collection of surface water samples from Ship Creek is not planned and should be. Ship Creek water samples should also be collected during storms to evaluate the impact of runoff and sediment loads from the site on water quality. The scope and location of Ship Creek water samples can be determined after field observations of runoff.
Previous EPA comments (July 2, 1992} recommended that a site screening program, using air modeling, be designed and implemented before air quality is monitored. These comments were
not addressed in the revised workplan and should be considered. A screening approach using the Cowherd model (Cowherd 1985) or other applicable models is recommended in the specific comments
that follow. The screening approach could be used to predict potential ambient dust concentrations and historical deposition of contaminants in the site area.
See site file for additional information. |
Jennifer Roberts |
| 10/28/1992 |
Update or Other Action |
PRC Environmental Mgt. Inc. Trip Report for oversight and split sampling at Standard Steel Site. Acceptable drilling, sampling, and well installation procedures were used by the field
investigation team at the site, including appropriate responses to technical difficulties and
variances from anticipated site conditions. Field evidence of contamination was observed at
locations F, A, and D. Observations made during drilling indicate that nonaqueous phase liquids
are still present in the area of locations A and D, as reported in previous investigations of the site.
The top of the Bootlegger Cove formation was detected at a greater depth along the southern site
boundary, occurring at a depth below 37 feet at location C (Figure 2). The greater depth to the
Bootlegger Cove may be the resulting of grading and alteration of the flow of Ship Creek at the
southern part of the site, as observed on the aerial photographs of the facility. The depth of the contact with the Bootlegger Cove below a depth of 35 feet may also reflect the presence of a
paleochannel eroded into the top of the unit, with a thicker alluvial section present in the vicinity of the current course of Ship Creek. (A preliminary geologic cross-section is included as Figure 2.)
Wells at location I should be installed, and an additional boring should be drilled using casing to seal the upper aquifer while drilling, in order to determine the depth of the contact with the Bootlegger Cove formation at the southern boundary of the site. Additional information on the nature and extent of contamination will be provided when subsurface soil sample results are obtained and subsequent sampling tasks are implemented.
Because little information is present on the type of contamination present at location F,
groundwater monitoring for all of the contaminants potentially present at the site should be
conducted and carefully evaluated to determine additional characterization activities needed for
this area of contamination. The observations at locations A and D indicate that nonaqueo us phase liquids are still present in the subsurface in this area. In addition to groundwater monitoring planned for this location, monitoring for nonaqueous phase liquids in the monitoring wells should be conducted, and additional monitoring wells should be installed in subsequent fi eld efforts for the remedial investigation at the site.
See site file for additional information. |
Jennifer Roberts |
| 11/3/1992 |
Update or Other Action |
WCC Letter to EPA RE: Analytical Methods and Preliminary Remediation Goals. In our opinion, the analytical methods proposed are appropriate and were selected to achieve, to the extent practicable, the detection limits called for in the Preliminary Remediation Goals defined by EPA, while maintaining the high quality of analytical data required under CERCLA guidance.
As discussed below, the SW-846 methods as proposed achieve all soil PRGs, and nearly all groundwater PRGs. In a few cases, conservative risk based PRGs are slightly exceeded.
• The reporting limits for these methods are far below any Records of Decision of which we are aware.
• There are no analytical methods for soils equivalent to the SDW A methods for water. As a result, it would be extremely difficult to correlate water concentrations with soil concentrations, or to draw relational conclusions from the two sets of data.
• The SDWA methods, while providing ostensibly lower reporting limits, do not provide the level of precision, accuracy, and reproducibility allowed with the SW-846 methods. Even through the use of special analytical services, compliance with all of the CERCLA data quality requirements cannot be assured, hence potentially casting doubt on data validity.
EPA did not establish soil PRGs for the following compounds for which groundwater PRGs were provided: cadmium, chromium, mercury, and 1,3 dichlorobenzene. However, the reporting limits shown are well below any established cleanup values that we are aware of and should be adequate for the intended purpose. As will be seen, PRGs are slightly exceeded for PCBs, dioxin/furans, vinyl chloride, and 1,2,4-trichlorobenzene. Each of these compounds is discussed separately below. Note that the value shown for chromium is for total chromium. It should not be necessary to speciate chromium unless detections in groundwater for total chromium exceed the PRGs for either species (100 ug/L). Previous analyses by EPA reported no detections of chromium in groundwater.
The reporting limit for PCBs in water by Method 8080 modified is 0.02 ug/L. This is more
than an order of magnitude lower than the drinking water Maximum Contaminant Level
(MCL), but slightly exceeds EPA's 10~ risk criteria of 0.01 ug/L. The analytical laboratory
proposed for this project (Analytical Technologies, Inc., of Renton, Washington) recently
completed an extensive study of achievable detection limits for PCBs in conjunction with
EPAs Manchester Laboratory. The results of that study showed that the lowest achievable
reporting limit which still met EPA 's data quality requirements was 0.05 ug/L. Therefore,
the method proposed appears to represent the lowest level practically achievable for this
project.
See site file for additional information. |
Jennifer Roberts |
| 11/4/1992 |
Document, Report, or Work plan Review - other |
EPA letter to WCC RE: Analytical Methods and PRGs. Your November 2, 1992 letter concerning analytical methods and associated reporting limits for use at Standard Steel and Metals (Site) addresses my concerns for sampling at the Site. I have not had the opportunity to review your submittal of the Quality Assurance Project Plan (QAPP), which arrived on the same day. If the QAPP reflects what was presented in the November 2, 1992 letter I do not anticipate submitting any comments.
It is my understanding that you are planning to install the remaining groundwater monitoring wells and conduct surface samples early in December. When you have firm dates for this
event please notify me so I can coordinate with you for collecting split samples. |
Jennifer Roberts |
| 11/9/1992 |
Update or Other Action |
EPA Letter to WCC RE: Standard Steel Superfund Site Late Submittal of Deliverable. I am writing to notify you, as Chugach Electric Association's Project Coordinator for the Standard Steel and
Metals Site (Site), that Chugach Electric Association is in violation of the Administrative Order on Consent (Order) for Remedial Investigation/Feasibility Studies (RI/FSs) at the Site.
This violation is pursuant to Appendix 1, Task l(a), which requires the Respondent, Chugach Electric Association, to submit a Draft Final RI Work Plan within thirty (30) days of the
effective date of the Order. Thirty days from the effective date was October 26, 1992.
The United States Environmental Protection Agency (EPA) was not notified that the above referenced deliverable would be late. It was not until I called you on October 29, 1992, that EPA was informed, by the Project Coordinator for the Respondent, that the deliverable would be late. It was during this phone conversation that you informed me that the document would be delayed. You indicated that your project team had been concentrating on installing the groundwater monitoring wells and clarifying sampling methodology with EPA for the Site and was unable to address EPA's comments prior to the submittal date.
Our October 2, 1992 letter, transmitting final comments on the Management plans to you, clearly identified a Draft Final Work Plan submittal, as required in the Order, to be submitted
thirty (30) days after the effective date of the Order. We expect that the Draft Final Work Plan will be a complete set of all management plans incorporating our comments. The schedule in Appendix 1 of the Order are enforceable deadlines which have associated financial penalties. The
assessment of these penalties is at the discretion of EPA (§ 19.1 of the Order) and may be invoked when deadlines are missed or EPA is not satisfied with the quality of a submittal without notice to the Respondent.
To avoid potentially unnecessary enforcement actions against your client, I recommend you communicate any potential delay in submitting primary or secondary documents, as defined in the Order, to me, as the EPA Project Coordinator as soon as you know a delivery date will be missed.
|
Jennifer Roberts |
| 11/23/1992 |
Update or Other Action |
EPA letter to Chugach Electric's Lawyer. You requested that EPA retract its November 5, 1992 notice of violation based on your conclusion that there was a miscommunication between EPA, Chugach and Woodward Clyde.
EPA agrees the r e was a miscommunication. EPA believes that the miscommunication could have been avoided and would like to reduce the likelihood that future miscommunications occur in the
course of implementing the RI/FS under the Administrative Order on Consent (AOC) . EPA believes that one approach to furthering good communications would be the assignment of a project manager
by Chugach who would be responsible for communications between EPA , Chugach and its contractor, Woodward Clyde.
Our experience has shown that when the project manager for a PRP is the contractor conducting the RI/FS, a misunderstanding can quickly escalate any issue into the legal realm. Whereas, if the project manager works directly for the PRP, misunderstandings most often will be resolved at the project manager level . Consequently, EPA strongly encourages Chugach to consider assigning a project manager who is not the attorney for the project nor the contractor conducting the work. EPA would be happy to discuss the benefits of such an arrangement with Chugach.
With respect to the specific miscommunication that has precipitated these correspondences, EPA does not agree that the May 18th submission from Woodward Clyde was the Draft Final Work
Plan, nor that Woodward Clyde's October 9 letter put EPA on notice that it was confused about the deliverable due date or that it was requesting an extension of time to submit the
deliverable. However, EPA sees no purpose in debating this issue back and forth in letters.
EPA received the Draft Final Work Plan on November 12, 1992. EPA acknowledges that no other deliverable, report or work required under the Order was delayed due to the late submission
of the Draft Final Work Plan. Chugach is not now in violation of the Order.
The deliverable deadlines contained in the Order ensure that the remedial investigation is completed in a timely fashion. If circumstances arise that make it impossible to meet a deadline, please notify EPA in writing and expressly request an extension. We trust that Chugach understands our concerns both with respect to the specifics of this miscommunication and with respect to the larger, longer-term communications issues, and will take steps to
ensure that similar miscommunications will not occur in the future. |
Jennifer Roberts |
| 12/4/1992 |
Document, Report, or Work plan Review - other |
DEC letter to EPA RE: Surface Soil Sampling. The report states that all of the samples will be analyzed for the comprehensive list of analytes including PCB, lead and dioxins. Figure 4-4 shows different PCB sample locations than the target analytes samples. Please explain this discrepancy. The Department is concerned about surface sample collection during the month of December. The ground is usually frozen during this month. The frozen ground condition has also been worsened this year by recent freeze and thaw which has saturated the soil and created a frozen solid condition that may be impossible to penetrate. The Department is concerned that representative sampling cannot be attained and that the integrity of the sample will be violated. The Department's recommendations that sampling be postponed until the spring when more favorable sampling conditions will exist. |
Jennifer Roberts |
| 12/8/1992 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: Surface soil sampling. Section 4.3, Field Sampling Plan: In order to insure the samples are representative of past activity at the site I propose sampling at depths from two inches to one foot below ground surface. This is being proposed to account for potential infiltration of contaminants over time, disturbance of surface soil associated with the type of facility, and the period of time since contaminants have been released on the surface of the Site.
I realize that sampling to one foot may be a problem at this time of year in Anchorage, however I am sure you share my concern for ensuring this sampling round is representative of contaminants present at the site. Although certain guidance documents define surface sampling as 0-6", sampling should always be designed specifically for a site. EPA' s baseline risk assessments utilize a surface soil definition Of 0-2'.
Section 4 . 3 Step 1
The work plan references Fall of 1992 for collecting surface soil samples. This should be altered to Winter of 1992, if surface sampling will be conducted at that time. The selection of site target analytes is of vital importance for the subsequent sampling rounds. EPA, as well as Alaska Department of Environmental Conservation (ADEC), are concerned with sampling during the winter months. We feel it will be very difficult to obtain samples that are representative of the site at this time of year .
See site file for additional information. |
Jennifer Roberts |
| 12/13/1992 |
CERCLA RI Plan Approved |
(Old R:Base Action Code = MPA - Management Plan Approval). USEPA provides comments on 11/12/1992 draft final management plan for Site. Upon incorporation of comments and the submittal of 3 copies of the complete set of management plans the USEPA will consider the MP final and approved. The approval was for Phase 1 of the field work and the rationale presented in the MP. An addendum for Phase 2 sampling will require review and approval by EPA. |
Jennifer Roberts |
| 12/15/1992 |
Document, Report, or Work plan Review - other |
EPA letter to WCC RE: Final comments on the draft final Mgt. Plans. The specific scope of Phase II sampling, particularly soil sampling and hydrologic characterization, should be presented in an addendum to the Management Plans once Phase I sample results have been reviewed. The site conceptual model should be revised to consider ingestion and dermal contact with soil outside the site fence. The future residential receptor scenario should also be assessed. As stated in earlier comments this will enable us to assess the Site utilizing a conservative, but reasonable future land use scenario. Utilizing this scenario is not a predetermination of future land use at the Site.
Section 3.3 describes potential receptors, and Figure 3.2 presents the conceptual site model. Previous EPA comments requested that potential ingestion and direct contact of soil by
area workers or residents be considered, since contaminants have been detected outside the site fence. EPA comments also specified ·that the future residential scenario be mentioned.
These receptors and pathways were neither described in Section 3.3 nor specified in Figure 3.2, and should be added to the final work plan.
The EPA is not convinced that the principle concern from dioxin and furan is from their generation during PCB transformer oil combustion and subsequent deposition as ash. Please refer to a August 28, 1992 transmittal from EPA which I forwarded Woodward Clyde Consultants a Health Consultation .Report from the Agency for Toxic Substances and Disease Registry. In this report ATSDR states "According to the Hazardous Substances Data Bank (HSDB), PCBs contain, almost without exception, various levels of polychlorinated dibenzofurans (PCDF) as contaminants. Tri- to heptachlorodibenzofurans have been found in Aroclor, with total PCDF concentrations as high as 10 ppm. Please address this concern in your rational for selection of sampling compounds.
Previous EPA comments recommended that air modeling be initially considered in the evaluation of the air pathway. Section 4.6 outlines such an approach, using the Cowherd model to predict
off-site particulate emissions and contaminant air concentrations. This section and Figure 4-9 should specify that on-site risks will also be assessed. Section 4.6 should also describe a specific methodology for assessing releases of volatile emissions or for documenting that such emissions could not contribute significantly to health risks. In addition, this section should specify the air monitoring method to be used if the modeling predicts unacceptable risk, (for example, method used to determine gradients and sample locations).
See site file for additional information. |
Jennifer Roberts |
| 4/30/1993 |
Site Characterization Report Approved |
(Old R:Base Action Code = PSE - Preliminary Source Evaluation). Preliminary Site Data Summary Report Phase I by Woodward Clyde consultants received. Key points of report: GW flow directions generally parallel Ship Creek, with no indicated tendency to "short circuit" into the creek near the Site, a thin LNAPL layer, composed principally of PCBs and non-priority pollutant compounds is present in only one well MW-17, DNAPLS have not been detected, both PCBs and lead exceed EPA's RBC for soils in many samples, PCBs, lead and 6 other inorganic compounds exceed RBC in unfiltered GW samples. |
Jennifer Roberts |
| 5/26/1993 |
Update or Other Action |
EPA Factsheet received. PCBs were found in concentrations as high as 380 parts per million (ppm) and lead as high as 4,300 ppm. These levels are significantly above cleanup levels established for these chemicals at other Superfund sites across the country. Cleanup levels at other sites have ranged from 1 ppm to 25 ppm for PCBs and 500 ppm to 1,000 ppm for lead, depending on the current or future use of the property. Dioxin, which is associated with the PCBs, was also found on site. However, the levels found on site are below those of other Superfund sites where EPA has determined no action is necessary. Solvents and petroleum based chemicals, known as polyaromatic hydrocarbons, were also found in the surface soil. Cleanup levels for this site will be established after the studies are complete.
A six-inch layer of oil containing PCBs and other contaminants was found floating on the groundwater under a portion of the site. This layer was found in the same location during previous investigations and does not appear to be moving. Future sampling will determine the size of the floating oil layer and how to remove this contamination.
Additional sampling of groundwater, surface and subsurface soils, and sediments in Ship Creek is scheduled for this summer. This sampling is intended to help define the extent of soil contamination and groundwater conditions. In addition , a survey of wildlife in and around Ship Creek will be conducted.
Chugach Electric will also be developing a list of possible cleanup alternatives. These alternatives will focus on addressing the PCB and ad contamination at the site, and other potential risks at the site. As part of the development of possible cleanup alternatives, an evaluation of the current and future risks from exposure to the site will also be done. This information will be used to analyze the alternatives to determine which are most appropriate for the site and most protective of human health and the environment.
See site file for additional information. |
Jennifer Roberts |
| 6/9/1993 |
Site Ranked Using the AHRM |
Site re-ranked. Site Access Value changed to 1 and GW Usage Value changed to 1. |
Jennifer Roberts |
| 9/13/1993 |
Update or Other Action |
Received USEPA Decision Document Supporting Unilateral Administrative Order for Access and Removal Activities to Alaska Railroad Corp. regarding the Standard Steel and Metals Salvage Yard Superfund Site. Because access has been denied to the southern portion of the site and an imminent and substantial endangerment exists at the site, it is recommended that the Alaska Railroad be ordered to remove the armored personal carriers in accordance with the July 1993 Scrap Metal and Debris Work Plan. Restricted access to all portions of the site should be maintained until the completion of the Remedial Actions at the site. |
Jennifer Roberts |
| 7/12/1994 |
Update or Other Action |
EPA Factsheet. Public Comment period announced for Consent Decree July 7 - August 7, 1994. You are invited to comment on a proposed Consent Decree that would collect a portion of what EPA spent conducting a removal action and other activities at the Standard Steel & Metals Salvage Yard site through 1991. It would also divide the costs of the Remedial Investigation and Feasibility Study (RI/FS), which is now being conducted by Chugach Electric Association with EPA oversight.
The proposed Consent Decree is between the United States. on behalf of the U.S. EPA, and the Alaska Railroad Corporation, Chugach Electric Association, Westinghouse Electric Corporation, J.C. Penney Company, Bridgestone/Firestone, Inc., and Montgomery Ward & Co., Inc. The settling federal entities include the Federal Railroad Administration in the Department of Transportation, the Defense Reutilization and Marketing Service, the Defense Logistics Agency in the DoD, and the Army Air Force Exchange Service.
The United States filed a federal lawsuit on December 6, 1991 against the settling defendants to recover past EPA costs at the site. The proposed Consent Decree is a partial settlement because it does not include all parties in the lawsuit, and it does not recover all of EPA's costs. DOJ and EPA will seek to recover costs that are not recovered under the Partial Consent Decree from Sears Roebuck and Co., the only non-settling party.
The parties to the proposed Consent Decree have agreed to pay approximately 71 % of EPA's past costs. The settlement also contains an agreement for the settling parties to reimburse the Chugach Electric Association and the federal agencies for money spent so far on the RI/FS, based on an allocated share of each party's responsibility. When the RI/FS is completed, if Chugach and the federal agencies spend more than their allocated share, then that will be credited toward what they owe on past costs.
The Consent Decree does not include the settling parties' liability for future cleanup of the Standard Steel site or for costs that may be spent by EPA in the future. When the final cleanup plan for the Site is selected and the costs of the cleanup are known, EPA will seek to negotiate an agreement for the work and reimbursement of any future costs.
See site file for additional information.
|
Jennifer Roberts |
| 8/24/1994 |
CERCLA RI Report Approved |
Pursuant to the AOC, Chugach Electric Association Inc. completed a Remedial Investigation Report in August of 1994. EPA accepted draft final copy of RI report as final on 8/24/96. Primary contaminants of concern (COCs) are lead and polychlorinated biphenyls (PCBs). For almost all samples where PCBs were detected, Aroclor 1260 was the only PCB congener which was found, so that the total PCB concentration is represented by Aroclor 1260. Lead was detected in 128 of 132 samples analyzed during the RI.
Maximum concentrations measured during the RI sampling 4,300 mg/kg. The maximum detected during EPA's removal actions investigations was 44,500 mg/kg. Background soil concentrations for lead is 13.3 mg/kg as determined by studies conducted during the Elmendorf Air Force Base remedial investigations. Lead concentrations greater than 500 mg/kg do not extend below the first two feet of soil.
PCBs were detected in 89 of 132 soil samples analyzed during the RI. Maximum concentration measured was 380 mg/kg. Stockpiled soils from the Removal Action had maximum PCB concentrations of 10,600 mg/kg. During sample collection for treatability testing samples were obtained from the stockpiled soils which had up to 3,500 mg/kg. Subsurface PCB contamination extends to groundwater in three locations on site.
Maximum concentrations of up to 519 mg/kg PCBs were detected in subsurface soils assocated with LNAPL. The LNAPL had PCB concentrations of 4,500 mg/kg. The concentrations of dioxins and furans are expressed as 2,3,7,8-tetrachlorodibenzo-p-dioxin equivelant (2,3,7,8-TCDD equivelant). Dioxions and furans were detected at 9 of 10 surface sample locations. The maximum concentration was 0.0017 mg/kg and all 9 samples exceeded the screening value of 0.0000004 mg/kg.
LNAPL was present at monitoring wells 17 and 19 but not evaluated separately as a medium of concern. The LNAPL is very viscous, tarry material that cannot be effectively separated from the soil. Consequently the LNAPL is considered as teh same media of concern as subsurface soil. DNAPL was not detected in any well. LNAPL was detected in MW-17A and MW-19A. A layer of LNAPL was detected in MW-17A (0.23 to 0.44 feet thick) and MW-19A (0.05 to 0.89 feet thick). An LNAPL sheen was detected in well MW-17 for three events and in MW-19 for the first event only. It appears the LNAPL plume is confined to the central part of the site in the vicinity of MW-17A and MW-19A bounded by the temporary well locations of 25, 26, 27, 28, and 29, where a free product layer was not detected.
The MW-17A product sample had PCB 1260 at 4,500 mg/kg, lead at 4.3 mg/kg, methylene chloride at 9,300 mg/kg, tetrachloroethane at 3,600 mg/kg, and various other VOCs, semi-VOCs. Approximately 1,600 cubic yards are covered with Shotcrete along the eastern boundary of the site. These soils have the highest concentration of PCBs at the site, with a maximum of 10,600 mg/kg.
Lead was detected in 3 of 9 down gradient groundwater monitoring locations in Round 2 from 0.0016 to 0.0031 mg/L. Lead concentrations in Rounds 2 and 3 are low relative to the EPA promulgated action level of 0.015 mg/L, and relative to background at Elmendorf AFB (0.047 mg/L). Considering the low frequency of detection and low concentrations detected relative to the guideline, lead was not retained as a COC for groundwater.
PCBs were detected in none of the 12 well locations during Round 2. During Round 3, PCBs were detected at 2 of 9 well locations ranging from 0.000023 mg/L to 0.000032 mg/L. The concentrations are about 20 times lower than MCL (0.0005 mg/L). Considering the low frequency of detection and low concentrations detected relative to the MCL, PCBs were not retained as a COC for groundwater. |
Jennifer Roberts |
| 1/5/1995 |
Update or Other Action |
Letter to EPA from Chugach RE: Standard Steel Superfund Site--Stabilization and Solidification. Chugach believes that stabilization/solidification (S/S) of all soil over cleanup levels should be the remedy selected for the Standard Steel Site. As demonstrated in the Standard Steel Soil Treatability Study, S/S will effectively decrease the mobility of lead and PCBs in soils at the Site. S/S is the only treatment process that will effectively treat both PCBs and lead, thereby negating the need for multiple treatment processes. The treatment process will ensure that the contaminants remain locked up in the soil matrix and continue to cause no impact to groundwater. The residual human health risks assocated with the S/S alternative are a cancer risk of 4 x 10 -4 and a hazard index for systemic toxicants of 0.03, well within Superfund risk goals.
Unlike many other remedies discussed in the FS, S/S can be implemented using equipment and contractors locally available in Anchorage. The treatment can be completed in one Anchorage construction season and requires no transport of contaminated materials to the lower 48 states. There is adequate space available on-site to conduct the treatment. There are no treatment residuals that require special handling, off-site disposal, or cause undue risk to the community during remediation. The remedy is moderately cost effective. The treatment results in an increase in soil volume which is actually a benefit as the raised elevations will help ensure that areas of treated soil remain above the flood plain of Ship Creek. The process produces excellent foundation conditions for future construction and continued industrial development of the area. |
Jennifer Roberts |
| 12/19/1995 |
Document, Report, or Work plan Review - other |
EPA letter to Alex Tula received RE: EPA comments on revised draft final feasibility study for Standard Stell and Metals Salvage Yard. This document was submitted to reflect changes requested by EPA in a April 26, 1995 comment letter and additional information obtained by conducting a Soil Washing Pilot Study at the Site. EPA approves the FS with the resolution of the attached comments. Your interpretations regarding applicability or relevance and appropriate regulations (ARARs) are sufficient for the evaluation of alternatives. Final determination of ARARs will be made in the Record of Decision.
Treatment of the Proposed PCB Mega Rule as "policy" is inappropriate. When discussing the implications and the "applicability" of the Proposed Rule it should be referenced as a To Be Considered. Compliance of ARARs is not applicable to the No Action Alternative. The No Action alternative should be dropped for its failure to be protective of Human Health and the Environment.
Stabilization/Solidification (S/S) has not demonstrated that it will comply with TSCA, without waiving all subtantive requirements. This issue was raised in our April 24, 1995 comment letter and has not been adequately addressed. Considering the concentrations of PCBs which would be placed in the containment cell and EPA's PCB Guidance on NPL Sites with PCBs, it is inappropriate to eliminate standard containment features of Chemical Waste Landfills prior to design of a stabilized mass.
Institutional controls-The information that is presented is acceptable, such as it is. For EPA to make a decision, however, that includes to some part the use of institutional controls, there should be some information about the enforceability of private land restrictions in the State of Alaska, specifically, deed notices, and covenants and/or restrictions placed on property. Does Chugach know whether Alaska allows the type of deed notices they are proposing to be placed on titles?
We will explore the possibility of having land use restrictions placed in the final transfer of the property from the Federal Railroad Administration to the State. It is questionable whether a deed notice can restrict or impose legal restrictions on use of the property. It can notify prospective purchasers of the remedial action to be taken or that has been taken on the property, but it may be an overstatement that the deed notice itself can limit land uses, or subject a purchaser to the Record of Decision. Additionally, it is questionable whether deed notices or land use restrictions can impose effective legal obligations related to worker health and safety. |
Jennifer Roberts |
| 1/31/1996 |
CERCLA FS |
The feasibility study (FS) for the site is completed. Supplemental sampling during the FS had detections of lead up to 7,200 mg/kg in the surface soil. Surface soil is defined as the ground surface to 12 inches deep. Subsurface is defined as below 12 inches deep. During the FS, numerous additional samples were collected to conduct treatability tests. These samples focused on acquiring representative soils representing low, average, and high lead levels. Low levels were around 500 mg/kg, average levels were around 1,700 mg/kg and high levels were around 5,200 mg/kg. The highest lead concentrations detected 24,000 mg/kg. PCB low levels were around 50 mg/kg, average levels were around 150 mg/kg, and high levels were around 700 mg/kg. The maximum high level for PCBs was 2,700 mg/kg.
Based on the information gathered and evaluated in the RI/FS, EPA concludes that contaminated soil on the site presents an unacceptable risk to human health, welfare, and the environment. All other contaminants of concern detected at the site above risk based levels were contained within soils with greater than 10 mg/kg PCBs and 1,000 mg/kg lead. Therefore, actions taken for PCBs and lead will address all remaining unacceptable risks at the site.
EPA altered the subsurface cleanup level contained in the FS for PCBs from 50 mg/kg to 10 mg/kg to consolidate all soils which would pose an unacceptable risk if these soils were exposed in the future by site activities or erosion. This consolidation will ensure that all surface soils contain less than 10 mg/kg PCBs even after remedial actions are complete without monitoring soil concentrations or maintaining a clean soil layer (when applicable). The cost of this alteration is not considered significant because treatment of soils between 10 mg/kg and 50 mg/kg is not required and there is a reduction in monitoring and maintenance costs by consolidating contaminated soils. |
Jennifer Roberts |
| 2/2/1996 |
Document, Report, or Work plan Review - other |
Chugach Electric Association Inc. letter to EPA Charles Clarke Region 10 Administrator RE: Standards Steel Superfund Site, Anchorage Alaska. You may not be aware that Chugach is concerned about the direction EPA appears to be taking in selecting a remedy. Chugach believes that the most appropriate remedy would be stabilization/solidification (S/S) of soils contaminated with lead and PCBs.
S/S is a commonly implemented remedy that will effectively decrease the mobility of lead and PCBs to orders of magnitude below current and proposed regulatory levels, thereby protecting groundwater, negating the need for multiple complicated treatment processes, and reducing risidual risks to well within EPA goals. It will cost 4.7 to 5.7 million dollars, which may be a relatively small sum by Superfund standards, but it represents a substantial expenditure for the PRPs.
From our perspective, EPA staff has recognized the merit in S/S remedy, but appears to be leaning toward a soil washing rmeedy instead. Soil washing will cost 6.8 to 9.1 million dollars or more-- 50% more than the remedy Chugach believes is appropriate and consistent with federal law-- but with no additional reduction in risk. Not only is this remedy more costly and complicated, Chugach's technical consultants have serious concerns as to whether soil washing will work and meet cleanup goals. If it does not work, the cleanup will cost even more.
We have provided additional informaiton to address EPA's concerns regarding the long-term permanence of S/S. Indeed, other EPA regions commonly implement S/S remedies in similar circumstances. |
Jennifer Roberts |
| 3/13/1996 |
CERCLA Proposed Plan |
The proposed plan describes the United States Environmental Protection Agency's recommendation for cleaning up the lead & polychlorinated biphenyls (PCBs) contaminated soil at the Standard Steel & Metals Salvage Yard.
EPA is proposing to solidify/stabilize all wastes on-site. Recommended remedy: Solidification/stabilization (alternative 6) which is estimated to cost less than 6 million dollars to implement. Soils will be excavated when PCBs exceed a concentration of 10 parts per million (ppm).Soils between 10 ppm & 50 ppm will be consolidated within the containment cell or treated. Soils contaminated with greater than 50 ppm PCBs & soils with greater than 1000 ppm lead will be treated. The excavated soils would be treated by stabilization/solidification, which is similar to Alternative 6 in the Feasibility Study, where it is explained in more detail. EPA has altered this Alternative 6 from the feasibility study to ensure that all treated soils are managed in the same manner & that future site activities would not release PCBs or lead.
The contaminated soil would be combined with one or more binding agents, such as cement, but not removed from the site or destroyed. The solidified soil would be replaced on site in a containment cell designed to prevent leaching of the contaminants & releases by erosion. The remedy would maximize future use of the site as an industrial property. Institutional controls, such as a deed notice & land use limitations, would prevent exposure to the solidified soils & ensure that the property would only be used for industrial use. Although the RI determined the groundwater was not impacted, monitoring of groundwater & the containment cell would be conducted to ensure the cell was functioning as designed.
Treatability tests determined that stabilization/solidification was capable of creating a solid rock like structure which would be modified from the treatability tests to enhance certain characteristics, i.e. resistance to freeze/thaw processes.
Public input on the alternatives & information that supports these alternatives is an important contribution to the cleanup remedy selection process. Based on new information or public comment, EPA may modify the recommended alternative or select another alternative presented in this plan. The public is encouraged to review & comment on all technologies & alternatives considered for the Standard Steel & Metals Salvage Yard. for EPA invites written comments on the Proposed Plan during the public comment period from March 18, to April 17, 1996.
See site file for additional information. |
Jennifer Roberts |
| 4/8/1996 |
Document, Report, or Work plan Review - other |
ADEC letter to Chris Cora EPA. ADEC has reviewed the alternatives for Standard Steel and Metals Salvage Yard Superfund Site Proposed Plan. While the department has concerns regarding the preferred alternative, solidification, these concerns can be addressed in the Record of Decision. You have indicated in a phone conversation that EPA is willing to address the department's issues in the Record of Decision as technical performance standards and institutional controls. |
Jennifer Roberts |
| 4/10/1996 |
Meeting or Teleconference Held |
USEPA held a public meeting for the preferred alternative in the proposed plan for the Site. Topics: Introduction by Jean Baker EPA Community relations coordinator, Superfund process-Where we are now by Chris Cora, Site information by Alex Tula Chugach representative, and EPA's recommended cleanup alternative-Alternative 6 Chris Cora.
EPA selected the site’s long-term remedy in 1996. It included recycling/disposal of solid wastes, solidifying some of the soils; building an on-site Toxic Substances Control Act disposal cell to contain contaminated material; maintaining the landfill; conducting operation and maintenance activities; and putting institutional controls in place.
See site file for additional information. |
Jennifer Roberts |
| 4/16/1996 |
Update or Other Action |
Letter from MOA Dept. of Public Works Watershed coordinator T. R. Bacon. Municipality of Anchorage does not oppose the proposed alternative in concept, but it is concerned with possible future erosion into the site by Ship Creek. Based on its past experience, the creek has significant bank erosion potential at high water flows. The instability of the channel alignment is consistent with the area geology. The final site design should include adequate provision for stream bank stabilization to minimize the potential for future release of contaminated materials. |
Jennifer Roberts |
| 4/17/1996 |
Update or Other Action |
Landau Associates Inc. on behalf of Sears Roebuck Co. and their counsel Perkins Coie has reviewed the plan for remediation of the Site. They believe the approach of treating all soils with lead concentrations greater than 1000 ppm by stabilization/solidification is excessively conservative.
They recommend use of the recognized biokenetic slope factor (BKSF) model developed by Bowers et al. Using the equations and parameters from Bowers et al (1994) and other relevant studies, a lead cleanup level of 7,850 ppm can be derived for long-term workers exposed to soil and dust via incidental ingestion at the Standard Steel Site. |
Jennifer Roberts |
| 4/22/1996 |
Update or Other Action |
Letter from Greenpeace re: proposed plan for the Standard Steel and Metals Salvage Yard Superfund Site. The life expectancy of the monolith is approximately 30 years, however it is not long enough to ensure protection from PCBs with a life expectancy of 100s of years and lead. The technology has only been tested in a couple of sites and EPA has failed to test this technology under subarctic conditions-freeze/thaw, or consider the potential for seismic activity and flooding to facilitate the degradation of the structure.
A ADEC site summary for the Standard Steel site stated that on-site groundwater was contaminated with PCBs, lead, and tetrachloroethylene (not addressed in the current proposed plan); and that sediments in Ship Creek are contaminated with PCBs. EPA's discussion and the proposed remedy minimize the severity of the pollution problems ensuing from this site. The sampling program has been too limited in scope to assess the potential for impacts to offsite drinking water sources and bioaccumulation of persistent organochlorine contaminants downstream from the site.
Given the serious uncertainties and lack of proven technology regarding the proposed remedy, the best solution to the problem is Alternative 9--Offsite Disposal in an approved hazardous waste facility that is both secured and retrievable. |
Jennifer Roberts |
| 6/10/1996 |
Update or Other Action |
EPA letter to Alex Tula re: request to remove damaged drums. EPA has reviewed a June 4, 1996 letter regarding the condition of drums stored at the Site. EPA is satisfied with the temporary stabilization efforts for the drums which were leaking. However, it is clear by your description, EPA's observations of the drums, that the integrity of many of the drums has been compromised. Many of these drums have been stored at the site since the EPA Removal Actions in 1986 and 1987.
Pursuant to Sections 10.2 and 10.4 of the AOC, EPA requests that Chugach Electric Association, Inc. provide a workplan to accomplish this activity for our review and approval. EPA also requests, pursuant to Section 10.2 of the AOC, that Chugach repair the existing fence to prevent access to any unauthorized personnel. |
Jennifer Roberts |
| 7/16/1996 |
Cleanup Level(s) Approved |
Based upon future industrial land use on the site, cleanup standards for the soil on-site are required for 2 contaminants: PCBs and lead. Two sets of cleanup levels will apply to the site. One set for the area of the site which will have engineering and/or institutional controls applied to it. In general, the controlled area will be inside the existing fence. Another set of cleanup standards for lead and PCBs will be for areas on the site that will have unrestricted access and which pose more ecological concerns. In general, those areas will be outside of the existing fence. PCBs have been detected at levels which would pose a risk to ecological receptors beyond the fence line and pose an estimated 1E-4 risk to long term workers in AOC3.
There are not federal or Alaska regulatory cleanup standards for PCBs or lead in soil (at the time the ROD was signed this was true-however both have cleanup levels for PCBs and lead). The cleanup standards (in the ROD) applied at the site soil are derived from two main sources: EPA guidance on soil cleanup levels (for PCBs and lead); Risk-based concentrations when guidance is not available.
ROD established cleanup levels for soil mg/kg: PCB <1 mg/kg and Lead < 500 mg/kg: No Action (*Groundwater fluctuation zone will be backfilled with soils containing less than 1 mg/kg PCBs. All other excavated areas to be backfilled with soils containing less than 10 mg/kg PCBs. Soils may not be stockpiled and subsequently backfilled in a manner which reduces the concentrations below 10 mg/kg or to avoid treatment.
Soil with PCBs 1 mg/kg to 9.9 mg/kg and Lead with 500 mg/kg to-999 mg/kg : flood plain soils only, excavate and consolidate elsewhere on-site.
Soil with PCBs 10 mg/kg to 49 mg/kg and Lead N/A: Excavate and consolidate soils in on-site TSCA landfill below 1 foot of landfill surface.
Soil with PCBs 50 mg/kg or greater and Lead 1000 mg/kg or greater: Excavate soils and treat by solidificaiton/stabilization, then dispose in an on-site TSCA landfill. Treated soils cannot be placed in top foot of landfill unless concentration is less than 10 mg/kg PCBs or within the groundwater fluctuation zone*.
NOTE* Groundwater fluctuation zone will be backfilled with soils containing less than 1 mg/kg PCBs. All other excavated areas will be backfilled with soils containing less than 10 mg/kg PCBs. Soils may not be stockpiled and subsequently backfilled in a manner which reduces the concentrations below 10 mg/kg, or to avoid treatment.
Groundwater monitoring for PCBs and metals will be conducted and the groundwater standards are the MCL and action level for PCBs and lead 0.5 ug/l and 15 ug/l respectively. Monitoring of groundwater downgradient of the landfill for PCBs (EPA method 8080), lead (EPA method 6000/7000), pH, specific conductance, chlorinated organics (40 CFR 761.75(b)(6)((iii)), or methods with equivelant detection limits and accuracy will be conducted to ensure the landfill is not contributign contamination to groundwater nor altering groundwater conditions.
NOTE: The remedial investigation determined that groundwater is not a media of concern requiring treatment. Although there is Free Product or Light Non-Aqueous Phase Liquid (LNAPL) present in the center of the site, no dissolved contaminants were identified at the boundary of the site. The LNAPL was found to be present in monitoring wells 17 and 19 locations as a very viscous, tarry material that cannot be effectively separated from the soil, therefore the LNAPL is considered as the same media of concern as subsurface soil.
The physical properties of the LNAPL are conducive to excavation with contaminated soils. The LNAPL will be remediated by the same treatment as the soils, unless it is determined during remedial design testing that the LNAPL requires off-site disposal because it is considered a liquid as determined by Method 9095 (paint filter liquids test) contained in 40 CFR 268.32(i). |
Jennifer Roberts |
| 7/16/1996 |
CERCLA ROD Approved |
Record of Decision signed by USEPA for Final Remedial Action at the Site. The remedial action objectives of the selected remedy are to: prevent exposure by inhalation, ingestion, and dermal contact with contaminated soils that would result in an excess lifetime carcinogenic risk above 1E-4 for industrial use and off-site non-industrial use; prevent exposure by inhalation, ingestion, and dermal contact with contaminated soils that would result in noncarcinogenic health effects as indicated by an HI greater than 1.0; Prevent off-site migration of contaminants caused by mechanical transport, surface water runoff, flood events, and wind erosion; Prevent leaching or migration of soil contaminants into groundwater that would result in groundwater contamination in excess of regulatory standards. These RAOs will protect surface water and sediment media of concern.
Selected remedy involves:
1) Removal of regulated material stockpiled on-site and investigation derived wastes with disposal at a RCRA subtitle C or D landfill or recycling of materials; 2) Off-site disposal of remaining scrap debris by recycling or disposal at RCRA subtitle D landfill, or if debris is a characteristic hazardous waste or contains greater than 50 mg/kg PCBs or 10ug/100 cm2 by standard wipe tests, treatment and disposal in a RCRA Subtitle C or TSCA landfill. 3) Excavation and consolidation of all soils exceeding cleanup levels.
4) Treatment of all soils at or greater than 1000 mg/kg lead and 50 mg/kg PCB by stabilization/solidification. 5) On-site disposal of stabilized/solidified soils and excavated soils between 10 mg/kg and 50 mg/kg in a TSCA landfill. 6) Excavation of soils impacted above 1 mg/kg PCBs and 500 mg/kg lead from the flood plain and consolidation of these soils elsewhere on the site. 7) Maintenance and repair of erosion control structure on bank of Ship Creek. 8) Maintenance of solidified/stabilized soils and the landfill. 9) Institutional Controls to limit land uses of the site and if appropriate, access. 10) Monitoring of groundwater at the site to ensure the effectiveness of the remedial action. |
Jennifer Roberts |
| 7/16/1996 |
Institutional Control Record Established |
ROD established institutional controls (ICs).
Deed Notice and Land Use Restrictions: A deed notice will be recorded on title records for the site, if possible, and will notify any subsequent purchaser and/or successor in interest that the property is subject to a CERCLA Record of Decision. The selected cleanup levels for the COCs are based on a future industrial land use scenario. Consequently, land use restrictions must be implemented at the site to assure that no residential land uses, or commercial uses with potential chronic exposures of children (i.e. day care center) are allowed. To assure long-term protectiveness, the land use restrictions shall run with the land, bind all successors in interest, and be recorded in the property records. The objectives of the land use restrictions are:
Ensure that site use continues to be industrial or commercial and prevent use of the site for commercial developments that involve potential chronic exposures of children to soil (e.g. use of the site for a day care center);
Restrict activities at the site that could potentially impact the integrity of the TSCA Landfill;
Prevent movement of soil containing greater than 1000 mg/kg lead or 10 mg/kg PCBs to the surface or within the top foot of soil where chronic long-term worker exposure could occur.
Groundwater use restriction are necessary to prevent the installation of groundwater supply wells at the site. The property interest implemented to assure acceptable future land use shall include provisions for restricting use of groundwater underlying the site for any purpose. In addiition, to the recorded restrictions, all available regulatory controls shall be undertaken by providing written notification of restrictions and site conditions to local, regional, and state agencies, departments, and utilities. The property owner(s) will be responsible for providing these restrictions.
Access to all areas impacted by soil contamination shall be limited during the construction of the remedial action. Access to the landfill should be prohibited to the general public and limited to long or short-term workers in compliance with 40 CFR 761.75(b)(9)(i), which requires a six foot woven mesh fence, wall or similar device. However, if the solidified soil mass is designed and used as a building foundation or parking lot, this requirement may be waived. Long term public access will be limited to those areas of the site other than where surface contamination of greater than 1 mg/kg PCBs remains after all excavation, treatment and disposal is complete. Public access will be limited by installing and maintaining a six foot fence or similar structure. |
Jennifer Roberts |
| 7/16/1996 |
Long Term Monitoring Established |
ROD established that long-term monitoring of the groundwater will occur until remedial action objectives are achieved for all contaminants of concern at the site (lead, PCBs, VOCs, Cadmium).
Groundwater monitoring for PCBs and metals shall be conducted twice a year for the first two years of operation and may be reduced to annually thereafter with approval of EPA in consultation with Alaska Department of Environmental Conservation for a minimum of ten years. After ten years an assessment of the groundwater data will be conducted to determine whether groundwater monitoring is still required or whether the frequency will be altered.
Groundwater monitoring will be conducted to assess the effectiveness of the remedy for protecting groundwater. The groundwater standards that are to be achieved are the MCL and action levels for PCBs and lead, 0.5 ug/l and 15 ug/l respectively. Monitoring of groundwater downgradient of the landfill for PCBs (EPA method 8080), lead (EPA method 6000/7000), pH, specific conductance, and chlorinated organics (40 CFR 761.75(b)(6)((iii)), or methods with equivelant detection limits and accuracy will be conducted to ensure the landfill is not contributing contamination to groundwater nor altering groundwater conditions. |
Jennifer Roberts |
| 7/16/1996 |
Conditional Closure Approved |
Record of Decision memoriliazed decision that no further remedial action is required. SEE actions under Record of Decision or the actual ROD for further information. |
Jennifer Roberts |
| 7/26/1996 |
Update or Other Action |
EPA letter to Alex Tula re: Record of Decision (ROD) Signature, Treatability Testing, and interim controls for Standard Steel and Metals Salvage Yard Site. The ROD was signed on July 16, 1996. The selected remedy was solidification/stabilization of soils. Two critical pieces of work should occur this work season: repair of the erosion control wall along the north shore of Ship Creek; and inititiation of the treatability tests for the solidification of the mixture. |
Jennifer Roberts |
| 9/20/1996 |
Update or Other Action |
EPA letter to Alex Tula re: additional work and removal actions at the Standard Steel and Metals Salvage Yard. Three tasks are required to eliminate immediate threats to the environment and ensure remedial actions are undertaken within the 15 month statutory deadline (42 U.S.C. 9620(e)(2).
The rip rap wall along the bank of Ship Creek, adjacent to the Site must be repaired because the bank is in danger of severely eroding and releasing contaminants from the Site. The shotcrete cap must be repaired so that highly contaminated soils under it are no longer exposed. Additionally, cold weather will soon make gathering soil samples for the treatability study until Spring of 1997. EPA considers it essential that the treatability study proceed this winter, thus soil samples must be gathered this fall. |
Jennifer Roberts |
| 9/26/1996 |
Offsite Soil or Groundwater Disposal Approved |
EPA letter to Ted Wall Woodward Clyde Inc. re: off-site disposal/treatment of wastes from Standard Steel and Metals Salvage Yard (Site). The (off-site) disposal of hazardous wastes identified in the September 12, 1996 facsimile at the proposed disposal facilities are acceptable to EPA. Alaska Pollution Control's Chemron/Springer facility is acceptable for recyling the wastes identified in the September 12, 1996 facsimile.
Trans-Tech and GNB Metals are also acceptable for the recyling of the transformer carcass and batteries respectively. EPA would also like to clarify that the acceptability of these facilities is not a guarantee that the facilities are currently in compliance with all the relevant permits and conditions of their operations. These facilities were inspected over the past year and were deemed acceptable by EPA and had no outstanding violations with their respective state regulators that EPA has been notified of. |
Jennifer Roberts |
| 9/30/1996 |
Update or Other Action |
EPA letter to Alex Tula RE: erosion control wall repair. EPA has reviewed the September 24, 1996 proposal for repairing the erosion control wall adjacent to the Site. The proposal is acceptable and Alta Geosciences is authorized to proceed with the repair work at your earliest convenience. As long as the existing "footprint" is not expanded for the erosion control structure and no equipment is used in the stream bed, or the stream bed is disturbed, the actions are considered (by EPA) a repair action of an existing structure. This action is considered an emergency action and future more permanent, actions may be requireed to ensure the structure is sufficient to withstand anticipated flood events.
RE: Shot-crete Repair letter dated same date. EPA has comments on two items in letter proposing repair of the Shot-crete cover at the Site. First, the proposed materials are unacceptable. The proposed cover material, Amoco 4551, is designed to function as a drainage and erosion control material, not as an infiltration barrier. Task 2, of the Supplemental Statement of Work, identified preventing infiltration as one of two requirements for repairing the Shot-crete. There are many products such as HDPE and standard rain tarps, which are inexpensive, readily available and effective at preventing infiltration, which could be used to accomplish this task. The second item, EPA approves, regards removal of vegetation. At this time, vegetation removal is not required to accomplish Task 2. However, EPA is not opposed to the removal of all vegetation from the Shot-crete. |
Jennifer Roberts |
| 11/12/1996 |
Update or Other Action |
EPA letter to Jennifer Roberts ADEC dated 11/06/1996 RE: Standard Steel and Metals Salvage yard Notification of Negotiations for Remedial Design and Remedial Action. In accordance with Section 120(f) of the Comprehensive Environmental, Compensation and Liability Act (CERCLA), 42 USC 9621(f), the Alaska Dept. of Environmental Conservation (ADEC) is encouraged to participate in these negotiations which will determine how the Record of Decision (ROD) will be implemented. If you would like to participate in any negotiations relating to this site, please respond in writing within the next fifteen (15) days. Please indicate the extent of State involvement, and whether or not, the State anticipates being a party to any settlement.
ADEC has been involved in the investigation of the site and development of the ROD. Regardless of your future involvement in negotiations, EPA prefers to continue with ADEC review and input into the remedial cleanup process at the site. EPA is particularly interested in whether the State will be willing to undertake the oversight of Operation and Maintenance of the remedy. |
Jennifer Roberts |
| 11/21/1996 |
Update or Other Action |
ADEC letter to EPA dated 11/21/1996. The Department is interested in working with the Environmental Protection Agency (EPA) on the negotiations for determining implementation of the Record of Decision (ROD) for the Standard Steel Site. The State does not plan on being a party to any settlement agreement, but would like to participate in negotiations to enhance our understanding of the ROD implementation procedures that will be negotiated for the Site. Our past involvement with the EPA during the investigation and development of the ROD has been positive, and EPA has done an excellent job of including the Department and addressing our concerns and comments. At this time we do not anticipate our role changing, but are willing to discuss with EPA the potential for the Department to assume a more active leadership role, and wht the role would entail. |
Jennifer Roberts |
| 12/12/1996 |
Update or Other Action |
Under terms of the Partial Consent Decree approved in December 1996, EPA recovered past cleanup costs; the Potentially Responsible Parties (PRPs) agreed to share cost of the RI/FS; and the federal PRPs and the Alaska Railroad Corporation agreed to pay 64% of all future cleanup costs at the site. A Consent Decree, approved in January 1998, includes an agreement with the PRPs to perform the cleanup of more than six acres of contaminated soil, and the owner of the property, Alaska Railroad Corporation, agreed to implement the specific institutional controls contained in the Record of Decision. |
Jennifer Roberts |
| 12/16/1996 |
Update or Other Action |
Statement of Work for Remedial Design and Remedial Action at Standard Steel and Metals Salvage Yard received. All soil contaminated with greater than or equal to 50 mg/kg PCBs and/or greater than or equal to 1000 mg/kg lead shall be treated by stabilization/solidification (S/S) and pretreated to screen out material that is oversized and/or may interfere with the S/S treatment process. Potential material to be screened out includes: wood, cardboard, wire, cobbles, and scrap debris.
The S/S design must: minimize volume increases, reduce freeze-thaw effects, and maximize the solidified soil's long-term durability and potential as a building platform. A preliminary treatability study determined a mixture of 16% cement and 8% fly ash to be a possible S/S mix ratio. Expanded treatability study will be conducted to demonstrate the predicted effectiveness of the S/S process. The testing will include: ANS 16.1 "American Nuclear Society Measurement of the Leachability of Solidified Low-Level Radioactive Waste by a Short Term Test Procedure", TCLP analysis on the solidified material, Additional leaching test(s) on solidified samples subjected to test procedures to simulate long term weathering (freeze-thaw, etc.), compression, etc.; and, An evaluation of chemical/physical properties such as temperature and pH on the solidification process.
The minimum performance standards shall be demonstrated in the laboratory and in the field during construction: The Toxicity Characteristics Leaching Procedure (TCLP) test for PCBs shall be 0.5 ug/L or less. For lead, the values shall be 5 mg/L or less. 28 Day unconfined compressive strength shall be greater than 50 PSI (ASTM Method D2166 or equivelant). The triaxial permability of the cured S/S monolith shall be less than 1 x 10 -7 cm/sec (USACE Method 1110-2-1906 or equivelant). ANS 16.1 "American Nuclear Society Measurement of the Leachability of Solidified Low-Level Radioactive Waste by a Short Term Test Procedure" The test shall demonstrate that the S/S monolith does not leach lead above 15 ug/L under natural pH leaching conditions. This is a change of a specific test mentioned in the ROD (PSA Mod. MCC-1 Static Leach Test [U.S. DOE-5820]) made necessary because the original test method is no longer an approved procedure.
The test shall be conducted after freeze-thaw testing (passing freeze-thaw tests shall be indicated by less than or equal to 30% loss after 15 test cycles) and shall be modified to allow long-term analysis of leachate and for the use of a test method designed for radioactive materials with soils that are non-radioactive in nature. A life expentancy of 1,000 years shall be a design goal. Life expectancy is defined as the time before contaminants are released above design criteria from the TSCA landfill. |
Jennifer Roberts |
| 2/4/1997 |
Update or Other Action |
EPA letter to Alex Tula AltaGeosciences Inc. RE: EPA Comments on Draft Final Design Level Treatability Study Work Plan. Our concern is regarding your response to comment #6, specifically regarding the nuimber of analysis of the SBLT data. Your response that only three samples will be analyzed to develop the elution curve does not adequately address our concerns for insuring the data will provide valuable information.
The purpose of conducting the Sequential Batch Leaching Test (SBLT) is to be able to extrapolate potential leachate concentrations if there is a major failure of the monolith. There is the potential that three data points will not provide enough data to complete this evaluation and without additional data points the SBLT procedure will not be of value. Our comment recommended analyzing more than three samples for this reason. In cases where the U.S. Army Corps of Engineers has utilized SBLT for evaluation of potential leachate generation, they have analyzed a minimum of seven (7) samples, usually more. Please provide a rationale for how you intend to interpret the data if the three data points do not result in a classic elution curve. |
Jennifer Roberts |
| 3/24/1997 |
Update or Other Action |
Revised community relations plan for Standard Steel and Metals Salvage Yard. Update for the USEPA July 1992 CRP. It describes ways for public involvement during the new phase, remedial actions, at the site. Soil contaminated with more than 50 parts per million (ppm) PCBs and 1000 ppm lead will be treated by solidification/stabilizaiton. The contaminated soil will be combined with binding agents, and the solidified soil will be placed in an on-site landfill. Soil with PCB concentrations between 10 and 50 ppm will also be placed in the landfill but will not require treatment. This will effectively eliminate migration of both contaminants and prevent exposure to the environment. Land use controls, access restrictions, and deed notices will be used to protect the landfill, prevent exposure to the solidified soil and ensure that the property will only be used for industrial purposes. |
Jennifer Roberts |
| 10/6/1997 |
Update or Other Action |
Preliminary Design Report and Project Implementation plans received. The report presents the data and a discussion of the basis of the Remedial Action Design for the Site. The purpose of the report is to present the status of the RA Design as it stands in the September 1997 (30% level), and to assure that members of the PRP Group and the EPA are advised of the underlying justification for design features. Estimates of in-situ (pre-excavation) total volumes: S/S Treatment soil 15,300 cubic yards and Consolidation soil 9,400 cubic yards. |
Jennifer Roberts |
| 11/3/1997 |
Update or Other Action |
Superfund Fact Sheet: An agreement has been reached to settle a U.S. Environmental Protection Agency complaint against some of the potential responsible parties (PRPs) for contamination at the Standard Steel and Metals Salvage Yard site. Details of the agreement, which will expedite the cleanup of the site are contained in a Consent Decree lodged on October 9, 1997 in U.S. District Court in Anchorage by the U.S. Department of Justice.
The proposed Consent Decree was published in the October 30, 1997, Federal Register which triggered a 30-day public comment period. Written comments should be sent by November 29, 1997 to: Assitstant Attorney General, Office of Environment and Natural Resources Division, Department of Justice, Washington D.C. 20530 Comments should refer to D.J. No. 90-11-3-810.
PRPs can be individuals, companies, or government agencies, including owners, operators, transporters, or generators, potentially responsible for contamination problems at a superfund site. The PRPs that have agreed to the terms of theis Consent Decree are: Alaska Railroad Corporation; Chugach Electric Association Inc.; Westinghouse Electric Corporation (Now CBS Corp.); Sears, Roebuck and Company; J.C. Penny Company Inc.; and Bridgestone/Firestone Inc.. The settlement does not include one other defendant in the complaint, Montgomery Ward and Company, Inc., which filed for bankruptcy in June 1997.
This proposed Consent Decree includes an agreement with the owner of the property, Alaska Railroad Corporation, to implement specific institutional controls. Institutional controls may involve restrictions such as access to, or future use of, the property. The remaining settling defendants will implement the cleanup of the property of more than six (6) acres of soil contaminated with primarily lead and polychlorinated biphenyls (PCBs).
The cleanup will be done in accordance with the Record of Decision (ROD), a document published in July 1996 that explains the final cleanup plan for contaminated soil at the site. The cleanp plan calls for contaminated soil to be contained on-site in soldidified form that will eliminate the risks of exposure, and will ensure that contaminants do not migrate beyond the site boundaries. |
Jennifer Roberts |
| 1/26/1998 |
Enforcement Agreement or Order |
A group of companies named by U.S. EPA as Potentially Responsible Parties formed the Standard Steel RD/RA PRP Group signed a Consent Decree for Remedial Design/Remedial Action agreeing to the ROD and the PRP group was considered as the "Settling Defendants" in the case.
Signatories included: Alaska Railroad Corporation. Chugach Electric Association, Inc., Westinghouse Electric Corporation. Sears, Roebuck and Company. J. C. Penney Company, Inc., and Bridgestone/Firestone, Inc. The Consent Decree was entered on January 26, 1998. Among other requirements, the CD required the respondents to design and implement the selected remedy in the ROD. |
Louis Howard |
| 1/29/1998 |
Document, Report, or Work plan Review - other |
EPA letter dated January 26, 1998 received on January 29, 1998 RE: resolution of January 12, 1998 response to comments on 95% Remedial Design documents Standard Steel and Metals Salvage Yard Site. Five topics were discussed during the meeting: ordnance related scrap metal, response to comments 10, 11, 15 and the delivery of the revised air monitoring plan.
EPA provided Alta Geosciences documents for review and potential inclusion into the workplans: ETL 385-1, Safety Concepts and Basic Considerations for Unexploded Ordnance (UXO) Operations, dated 16 February 1996, Copies of artillery ammunition descriptions, specifically for 75mm, 105mm and recoilless rifle ammunition, U.S. Army Engineering and Support Center Ordnance and Explosives Center of Expertise (CX), Personnel and Work standards for Ordnance Response 30 July 1996, and a list of UXO contractors.
It was agreed that the response to comment#1 was acceptable with the addition that the proposed UXO "technician" would notify both the Project Engineer and the EOD unit at Fort Richardson. EPA and the USACE will contact the Fort Richardson EOD Unit to discuss the situation at the site. |
Louis Howard |
| 4/23/1998 |
CERCLA Remedial Design/Remedial Action Plan Approved |
EPA letter to Alex Tula re: notice of authorization to proceed with the Remedial Action. EPA has received the final Remedial Action Construction Work Plan dated April 1998 for the Site. The document addresses comments and concerns which were submitted to Alta Geosciences Inc. during the review phase, and is considered "approved". EPA requests specific conductance and pH be added to the groundwater sampling and analysis plan as required by the Record of Decision.
Also the Consent Decree for this action requires the Settling Defendants to establish and maintain financial security in the amount of $3, 234,000. Please provide the information to demonstrate this has been done pursuant to Section XIII, paragraph 46 of the Consent Decree. The Settling Defendants are also required to provide proof of insurance, pursuant to Section XVII, paragraph 58. This information has been verbally assured to EPA, but written proof is necessary to satisfy the requirements of the Consent Decree. Please provide it within seven (7) days upon receipt of this letter. |
Louis Howard |
| 4/24/1998 |
Institutional Control Record Established |
DECLARATION OF RESTRICTIVE COVENANTS & NOTICE OF REMEDIAL ACTION. Signed by William J. Sheffield ARRC President & Chief Executive Officer Notarized by Julie A. Black.
This Declaration of Restrictive Covenants & Notice of Remedial Action ("Deed Restrictions") is made this 23rd day of April, 1998 pursuant to, & in consideration for, the terms of the prior consent agreements & the Record Of Decision ("ROD") pertaining to the Standard Steel Superfund Site ("site") issued by the U.S. Environmental Protection Agency ("EPA") on July 16, 1996.
1. Grantor. These Deed Restrictions are granted by the Alaska Railroad Corporation & are binding upon its successors & assigns (collectively "Grantor") with respect to a parcel of land located in Anchorage, Alaska, more particularly described on Attachment "A" attached to & for all purposes made a part of these Deed Restrictions (the "Property").
2. Purpose, it is the purpose of these Deed Restrictions to implement the Institutional Controls (ICs) required by the ROD to notify all successors-in-interest or other persons of the land & water use & access restrictions that apply to the Property to assure the Property will be used only for purposes which are compatible with the Remedial Action & the RD/RA Consent Decree entered into by Grantor, the United States, & other parties, & entered by
the U.S. District Court of the District of Alaska on January 26, 1998, in the matter of U.S. v. Alaska Railroad Corporation, et al., A91-0589-CV (JWS), & CO ensure that the Property will not be used in a manner that will pope a threat to human health or the environment.
3. Servitude in Perpetuity. The covenants, terms, conditions & restrictions of these Deed Restrictions shall be binding upon & inure to the benefit of the Alaska Railroad Corporation, its successors & assigns, any grantee, & their succeasors & assigns, & shall continue as a legal & equitable servitude running in perpetuity with the Property.
4. Notice of Remedial Action. THIS PROPERTY IS PART OP THE STANDARD STEEL & METALS SALVAGE YARD SUPERFUND SITE, WHICH THE EPA, PURSUANT TO SECTION 105 OF THE COMPREHENSIVE ENVIRONMENTAL
RESPONSE, COMPENSATION, & LIABILITY ACT ("CERCLA") , 42 U.S.C. 9605, PLACED ON THE NATIONAL PRIORITIES LIST, SET FORTH AT 40 C.F.R. PART 300, APPENDIX B, BY PUBLICATION IN THB FEDERAL REGISTER ON AUGUST 30, 1990. 55 FED,. REG. 35502. IN THE RECORD OF DECISION POR THE SITE DATED JULY 16, 1996, THE EPA REGION 10 REGIONAL ADMINISTRATOR SELECTED A "REMEDIAL ACTION" FOR THE SITE, WHICH PROVIDES, IN PART, FOR IMPLEMENTATION OF INSTITUTIONAL CONTROLS LIMITING FUTURE LAND USES OF THE SITE, PREVENTING GW USE & LIMITING SITE ACCESS. AMY INTEREST IN THE PROPERTY CONVEYED OR ACQUIRED IS SUBJECT TO THE RESTRICTIVE COVENANTS CONTAINED IN THIS
DECLARATION).
Restriction on, Use. The following restrictions apply to the use of the Property/ run with the land & are binding upon any grantee.
(i) no residential use or activity shall be permitted on the Property, & no commercial use or activity shall be permitted if it involves potential chronic exposures of children to soil (e.g. . use of the Property for a day care center);
(ii) no use or activity on the Property shall be permitted that will disturb any of the remedial measures that have been implemented pursuant to the Consent Decree referred to in Paragraph 2 above or that could potentially impair the integrity of the landfill in which contaminated soils & solidified soils have been disposed; &
(iii) except as necessary to perform the Remedial Action, no use or activity on the Property shall disturb the surface or subsurface of the land by filling, drilling, excavation, or removal of topsoil, rock or minerals which could move soil containing greater than 1,000 mg/kg lead or 10 mg/kg polychlorinated biphenyl ("PCBs") to the surface or within the top foot of soil where chronic long-term worker exposures could occur;
(iv) GW underlying the Property shall not be consumed or used in any way except for the limited purpose of monitoring GW contamination levels. GW wells & facilities installed for such purpose shall only be installed pursuant to a plan approved by EPA;
For additional information see site file. |
Louis Howard |
| 4/26/1998 |
Update or Other Action |
LEGAL DESCRIPTION STANDARD STEEL SITE
A parcel of land located within the Alaska Railroad Anchorage Terminal Reserve, situated
in the Anchorage Recording District, Ihird Judicial District, State of Alaska, including Lots
53 through 58-A of the Alaska Railroad Corporation Post Road Industrial Lease Lots and
more particularly described as follows;
Beginning at the northwesterly corner of Lot 53; thence S 32° 30' 30"" E a distance of 510.00 feet; thence along Ship Creek Meanders as follows:
S 41° 15' 25"" W, 54,09'; S 19° 09' 22"" W, 57,22 feet; S 4° 01'
53"" E, 96.37 feet; S 45° 50' 52"" E, 32.76 feet; S 4° 05' 54"" W,
34.49 feet, S 23° 05' 08"" W, 85.10 feet; S 49"" 36' 47"" W.
246.17'; S 71° 18' 37"" W, 203.76';
thence N 34° 46' 19"" W a distance of 277.99 feet; thence N 32° 32' 30"" W a distance of
459.88 feet, thence N 57° 27' 30"" E a distance of 678.95 feet to the point of beginning,
Containing an area of 484.428 square feet or 11.12 acres more or less, as shown on the
attached drawing. In the event of any inconsistency between the attached drawing and
the foregoing legal description, the latter shall govern for purposes of this Declaration of
Restrictive Covenants and Notice of Remedial Action. |
Jennifer Roberts |
| 5/1/1998 |
Update or Other Action |
Pre-Mobilization Site Investigation Report received for Remedial Design/Remedial Action dated April 1998. Objectives of these pre-mobilization site investigation is to: Delineate the lateral extent of the smear zone, determine which quadrants around the perimeter of the Site meet the remedial action cleanup standards without excavation. Evaluate the required depth of soils removal in numerous quadrants throughout the Site.
The scope of work completed for this evaluation of the smear zone included: Clear snow from affected portions of the Site. Drill four borings approximately 30 feet deep. Drill seven borings approximately 12 feet deep. Test 45 soil samples for PCBs and write a summary report.
Based on the boring data the smear zone boundary was interpreted as halfway between two adjacent borings, the inner of which exceeded the Removal Action Criteria in samples from the approximate depth of the Smear Zone. This interpreted Smear Zone boundary is located primarily within the limits of the consolidation cell excavation and it does not appear to impinge on the erosion control wall excavation. This should make the soils removal and erosion control wall excavations somewhat less complicated. |
Jennifer Roberts |
| 5/4/1998 |
Update or Other Action |
Work Plan Remedial Acton Construction dated April 1998 received. During the design of the selected remedy, certain enhancements have been added which were not included in the description of the remedy included in the Record of Decision. These enhancements are designed to improve the freeze thaw resistance of the solidified soil, provide additional flood protection to the consolidated soil, and reduce or eliminate the areas for which land use controls and Site access restrictions are needed.
These include: Addition of a geomembrane cover system covering the solidified soils. Construction of a completely new erosion control structure located inland from the existing stream bank. Excavation and consolidation of all upland surface soils outside the limits of the of the TSCA landfill which exceed 1.0 mg/kg PCBs or 500 mg/kg lead. Placing three (3) feet of clean cover over the geomembrane cover system and all contaminated soils within the TSCA landfill. |
Jennifer Roberts |
| 5/12/1998 |
Update or Other Action |
Standard Steel site update emailed to Jennifer Roberts. Both the UXO team and the MAECTITE team have been uncovering unexpected ordnance. Three distinct UXO areas exist: the burn pit horizon, the landfill cap north of the burn pit horizon and the 20 mm site. Subsurface screening continues, the contractor has found two sites, one contained about 100 spent 40mm, 75mm and 105mm casings and the other site contained about 75 M100 bomb fuses.
These two sites are separated by about 50 feet of what looks like landfill cap. Clearwater is concerned that this may be an ordnance landfill and there could be just about anything in there. Subsurface screening to continue through til Thursday or Friday.
The MAECTITE application was just getting started on the mid-western portion of the site when the excavator uncovered a concentration of 20 mm rounds. 300 were estimated to be in place, in the soil pile and in a cemented ball about 1 foot in diameter. The MAECTITE application was halted, and a large area of the site secured and flagged off until the 20mm ordnance issue was resolved. These rounds were encountered about 1 foot below ground surface, and the operator believes that they were in a 55 gallon drum that he ripped the lid off of.
Clearwater feels that Huntsville CTE for Ordnance will need to send someone up to help develop, review, and approve revisions to the UXO plan so that the remaining UXO can be removed and cleared from the site. The UXO issue is putting a real crimp on the MAECTITE production. The location that the MAECTITE can be applied is being limited by the UXO t the south and to the west. It was estimated that about half the site is awaiting UXO clearance and is not available for treatment. |
Jennifer Roberts |
| 5/21/1998 |
Update or Other Action |
EPA Letter to Ron Goughnour Municipality of Anchorage re: Yakutat Street Culvert Replacement. USEPA is overseeing remedial work at the Standard Steel and Metals Salvage Yard Superfund Site in Anchorage Alaska. The site is located near the intersection of Railroad Avenue and Yakutat Street, adjacent to Ship Creek. The Settling Defendants conducting the cleanup have hired Wilder Construction Co. for the remedial action. As part of the (remedial) work, a storm water culvert running below Yakutat street adjacent to the Site, needs to be rerouted to allow for the construction of the containment cell and associated structures.
It is EPA's understanding that Wilder Construction Co. contacted your office earlier this year to request a permit for the re-routing of the culvert. EPA is writing to clarify that pursuant to Section 121(e) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended, no Federal, State, or local permit is required for remedial work conducted entirely onsite. Wilder is required to satisfy the substantive requirements of city stormwater design, i.e. codified material specifications.
EPA in another letter to Alex Tula dated 5/21/1998 RE: Yakutat Street culvert rerouting has noted that they spoke to the Municipality of Anchorage (Ron Goughnour) regarding the re-routing of the Yakutat Street culvert adjacent to the Standard Steel and Metals Salvage Yard (Site). EPA has explained the permit exemption of Section 121(e) in CERCLA and how it applies at the Site. After providing the Municipality with the specifications for the proposed culvert, they will identify whether there are any codified substantive requirements which may not be in the current specifications. |
Louis Howard |
| 5/22/1998 |
Update or Other Action |
EPA letter to Alex Tula RE: notice of potential force majeure event. EPA is writing to address the Settling Defendants potential invocation of Force Majeure due to the identification of a potential ordnance burn pit at the Site. A May 11, 1998 letter cites the discovery of the "burn pit" and the inability to work in the area as the reason why a force majeure event may exist. Since that date, EPA has been notified of additional ordnace related materials at the Site. EPA appreciates your diligence in notifying EPA of possible delays in the cleanup schedule. EPA cannot at this time determine whether or not a Force Majeure event exists.
The RD/RA Consent Decree requires within 5 days of notifying EPA of the potential for a Force Majeure event the Settling Defendants provide, in writing to EPA the following information to substantiate the Force Majeure event:
1) An explanation and description of the reasons for the delay;
2) The anticipated duration of the delay;
3) A schedule for implementation of any measures to be taken to prevent or mitigate the delay or the effect of the delay;
4) The Settling Defendants' rationale for attributing such delay to a Force Majeure event if they intend to assert such a claim;
5) And a statement as to whether, in the opinion of the Settling Defendants, such event may cause or contribute to an endangerment to public health, welfare, or the environment.
Subsequent discussions have resulted in the following actions to be taken:
1) Settling Defendants contractors will proceed with site activities in the area of the 20 mm projectiles, following the existing work plan and utilizing appropriate equipment and oversight to protect workers and the community of projectiles which have the potential of containing high explosive. Surface debris and soils above the "burn pit" will be removed to within 1 foot of the burn layer. Upon approval of a revised UXO intrusive investigation workplan for scrap, geophysics will be conducted on the burn layer to estimate its extent. 2) EPA will direct its oversight contractor to sample the burn layer for ordnance, metals, and semi-volatile compounds to determine whether additional contaminants of concern are present at the site which would require amending Health and Safety Plans and determining potential treatment and/or disposal options for impacted soils.
The material discovered is still considered "scrap" and therefore does not alter the definition of "Work" in the RD/RA Consent Decree for the Site. Based on the information provided to EPA, and discussions with all involved parties, it appears the basis for a possible Force Majeure event, i.e. needing to stop work at the Site, does not exist.
EPA will consider a schedule extension to address potential delays caused by the need for a revised work plan and procedures to address the increased amount and unanticipated types of ordnance related scrap metal. However, we need to receive and approve a proposed extended schedule for the remedial action work at the Site. EPA anticipates receiving this shortly. |
Louis Howard |
| 6/3/1998 |
Update or Other Action |
USEPA Letter to Alex Tula RE: Site Egress Procedures Standard Steel and Metals Salvage Yard Site. On June 2, 1998, the US EPA representative at the Site observed activities which deviated from the approved Remedial Action Work Plans. It was observed that contractors were egressing the Site from a gate which had no decontamination facility or procedures to prevent the transport of contamination from contaminated areas of the site to clean areas. The EPA representative identified this un-approved activitity to the contractor but the activity continued. The activity and response were unacceptable.
The Corps of Engineers are on site to observe (on behalf of the EPA) the Settling Defendants work and to provide guidance. Part of this guidance is to identify when activities are being done inconsistent with the approved workplans. If the Corps identifies activities which are not in compliance with the approved work plans, or which threatens a release of contamination which could pose an imminent and substantial risk to human health or the environment, the activity should be stopped, or altered to comply with approved work plans. |
Louis Howard |
| 6/4/1998 |
Update or Other Action |
USEPA letter to Alex Tula RE: disposal of steel rails. In response to a June 2, 1998 letter regarding the disposition of steel rails at the Standard Steel and Metals Salvage Yard Superfund Site. The letter requests EPA's position on giving the steel rails to an adjacent lease holder in their existing conditions to be used "in another railroad siding". EPA assumes authorization has been given by the owner (ARRC) of the rails to give the rails away, EPA takes no responsibility for the legality of such transfer.
Existing condition of the rails based on the sampling of four of them, shows PCB levels in excess of the 10ug/100cm2 criteria identified in the July 16, 1996 Record of Decision (ROD). The ROD requires the following: 1) Off-site disposal of remaining scrap debris by recycling or disposal in a RCRA Subtitle D landfill or, if the debris is a characteristic hazardous waste or contains greater than 50 mg/kg PCBs or 10 ug/100cm2 by standard wipe tests, treatment and disposal in a RCRA subtitle C or TSCA landfill.
The ROD was anticipating off-site disposal of scrap debris. The proposal technically may not be disposal because the rails are to be used for their intended purpose, i.e. as rail road tracks. However, the rails will be taken off-site and could potentially pose a risk to off-site receptors. Therefore, promulgated procedures for decontaminating PCB contaminated material (for movable equipment) found at 40 C.F.R. Section 761.79(b) would be applicable. |
Louis Howard |
| 6/17/1998 |
Document, Report, or Work plan Review - other |
USEPA letter to Alex Tula re: Perimeter Air Monitoring Samples Standard Steel and Metals Salvage Yard Site. US COE has forwarded a memorandum requesting altering the collection of perimeter air monitoring samples for the Standard Steel and Metals Salvage Yard Site. This memorandum was sent by Rick Quine on June 11, 1998. The memorandum requests a temporary relaxation in the number of sample sets per week that have to be collected.
This request is based primarily on the fact that Site air monitoring criteria have not been exceeded, that dust supression has been very effective and it has been a wet spring. EPA approves the alteration reduction in the collection of sample sets to one, or more, sets per week. Dust suppression must continue and be strictly enforced throughout the project. When drier weather arrives the number of collection days shall increase apprpriately. |
Louis Howard |
| 6/30/1998 |
Update or Other Action |
USEPA letter to Alex Tula re: Geophysical Investigation of "Burn Layer" Standard Steel and Metals Salvage Yard Site. EPA has reviewed the June 10, 1998 letter regarding the investigation of the "burn layer" at the Standard Steel and Metals Salvage Yard Site. The letter requests to eliminate the anticipated geophysical investigation task discussed during conferences between the RD/RA PRP Group, US Army COE, and EPA on May 21, 1998 and referenced in your May 24, 1998 letter. EPA concurs with the elimination of the geophysical investigation task for the "burn layer". Observation by a qualified UXO specialist during excavation is required, as proposed in your letter. |
Louis Howard |
| 8/3/1998 |
Update or Other Action |
Letter from USEPA to Alex Tula Alta Geosciences Inc. RE: revised wastewater pre-treatment criteria. EPA has reviewed the July 29, 1998 transmittal requesting a revision in the pretreatment criteria for wastewaters at the Standard Steel and Metals Salvage Yard Site. EPA has reviewed the Anchorage Water and Wastewater Utility letter of July 31, 1998 stating they will accept the wastewater stream from the Site in compliance with their NPDES permit. EPA approves the revision of the pretreatment criteria for PCBs from 0.001 mg/L to 0.02 mg/L in wastewaters to be discharged into the AWWU. |
Louis Howard |
| 8/6/1998 |
Update or Other Action |
Letter from USEPA to Alex Tula Alta Geosciences Inc. RE: perimeter air monitoring. EPA has reviewed an August 3, 1998 transmittal regarding terminating air monitoring for PCBs and lead and removing the weather stations at the Standard Steel and Metals Salvage Yard site. EPA approves the request to terminate air monitoring and remove the weather station. Approval is based on the results of the eleven weeks of air monitoring data which showed no exceedance of PCBs, lead or dust. Dust suppression must continue on an as needed basis. |
Louis Howard |
| 9/1/1998 |
Update or Other Action |
USEPA letter to Alex Tula Alta Geosciences re: off-site disposal/treatment of wastes. EPA has reviewed the acceptability of the treatment and disposal facility, SafetyKleen Inc., located in Aragonite Utah. This facility is acceptable for the treatment of PCB oil from the Standard Steel and Metals Salvage Yard Site. EPA would like to clarify that the acceptability of this facilty is not a guarantee that the facility is currently in compliance with all the relevant permits and conditions for their operations. This facility is acceptable by EPA and has had no outstanding violations with their respective state regulators that EPA has been notified of.
NOTE: the EPA is referring to in their letter the "Off-Site rule" (OSR) an it is defined as follows: Section 121(d)(3) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) applies to any CERCLA response action involving the off-site transfer of any hazardous substance, pollutant or contaminant (CERCLA wastes).
That section requires that CERCLA wastes may only be placed in a facility operating in compliance with the Resource Conservation and Recovery Act (RCRA) or other applicable Federal or State requirements. That section further prohibits the transfer of CERCLA wastes to a land disposal facility that is releasing contaminants into the environment, and requires that any releases from other waste management units must be controlled. These principles are interpreted in the Off-Site Rule (OSR), set forth in the National Contingency Plan (NCP), at 40 CFR 300.440. The purpose of the OSR is to avoid having CERCLA wastes from response actions authorized or funded under CERCLA contribute to present or future environmental problems by directing these wastes to management units determined to be environmentally sound (preamble to final OSR, 58 FR 49200, 49201, Septemeber 22, 1993). |
Louis Howard |
| 9/2/1998 |
Update or Other Action |
Notification to Tim Stevens UST program from the Alaska Railroad Corporation re: tank removals at Standard Steel. Closure notice for two tanks the ARRC was informed about them a few days ago by the on-site contractor, who is doing remedial work (soil solidification). September 17/18 estimated date of closure by CH2M Hill. Tanks are of unknown age, product, date of last use and 2,000 gallon and 500 gallon capacities. |
Tim Stevens |
| 10/10/1998 |
Update or Other Action |
Factsheet for site is available. The former erosion control wall adjacent to Ship Creek is no longer needed to protect the site and will be removed in the future. The containment cell incorporates a much stronger erosion wall, which is recessed from Ship Creek. This design will allow Ship Creek to reestablish a more natural channel adjacent to the site and allow for more natural stream conditions.
Soil contaminated with lead and polychlorinated biphenyls (PCBs) has been excavated. Higher-level contaminated soil above 50 parts per million (ppm) of PCBs and 1000 ppm of lead, were mixed with a solidifying agent and placed in the on-site containment cell. Soil with PCB concentrations between 1 and 50 ppm were also placed in the containment cell, but without solidification. The entire containment cell has been capped with a liner, which prevents water from entering the containment cell and three feet of clean soil. The flood plain and slopes of the containment cell will be planted with native plants in the spring. The surface of the containment cell may be used for non-residential purposes which will not damage the cover system. |
Louis Howard |
| 10/29/1998 |
Update or Other Action |
Letter from USEPA to Alex Tula Alta Geosciences Inc. re: Pre-Final Construction Completion Inspection. The Pre-Final Construction Completion Inspection held on October 13, 1998 demonstrated that the Standard Steel and Metals Salvage Yard is substantially complete. However, there are a limited number of tasks required by the Record of Decision and Remedial Action workplan which have not been completed.
1) Flood Plain revegetation, 2) Surface Drainage Ditches (this has been completed since the pre-final construction completion inspection), 3) Side Slope hydro seeding, 4) Removal of original Rip Rap erosion control wall, and 5) Performance standard verification plan.
The uncompleted tasks are required tasks are required elements of the Remedial Action selected in the Record of Decision. However, the inspection and confirmational sampling show that there are no uncontrolled hazardous substances at the site and therefore the site may be utilized for commercial/industrial purposes consistent with the institutional controls selected in the ROD. EPA is evaluating the request to waive 40 C.F.R. Section 761(b)(9)(i) at the Site. |
Louis Howard |
| 11/9/1998 |
Update or Other Action |
USEPA letter to ADEC received. RE: Explanation of Significant Difference (ESD) letter dated November 4, 1998. Regarding the waiver of the 40 CFR 761.75(b)(9)(i) to erect a a six foot fence at the site. This waiver of the requirement was anticipated in the Record of Decision if the site was designed as a building foundation or parking lot. EPA proposes to waive 40 CFR 761.75(b)(9)(i) at the site because the remedial action meets, and exceeds, the requirements identified in the June 1996 ROD. Pursuant to the National Oil and Hazardous Substance Contingency Plan (NCP) section 300.435(c)(2).
PCB concentrations at the site varied from non-detect to 10,500 mg/kg and lead varied from 30 mg/kg to 24,000 mg/kg. All lead concentrations above 500 mg/kg were located in the surface soils. The ROD selected industrial cleanup levels of 10 mg/kg PCBs and 1,000 mg/kg lead for surface soils at the site. The approved design was enhanced by excavating and consoldating all upland surface soils outside the limits of the TSCA landfill which exceed 1.0 mg/kg PCBs or 500 mg/kg lead and add a geomembrane cover system, consisting of a four inch foam layer, 40 mil geomembrane impermeable liner, geonet drainage layer, geonet filter fabric and three feet of clean soil.
The addition of the geomembrane cover system and three feet of soil exceeds the design requirements of the ROD and satisfies 40 CFR 761.75(b)(9)(i). Institutional controls in the ROD provide notice of the TSCA landfill to the landowner, lessees, and local utilities, and will prevent excavation, construction or other incompatible uses at the site.
The ROD cost for Alternative 6, the selected remedy was $4.7 to $5.8 million dollars. The reported RA cost in the August 1999 Completion Report is $5.25 million dollars. |
Louis Howard |
| 11/16/1998 |
Update or Other Action |
Letter from USEPA to ADF&G regarding the action on the original erosion control wall along Ship Creek. Due to a different approach in scheduling the remedial action, the erosion control wall was not addressed this year. They plan on addressing it early next year, before salmon runs restrict construction along stream banks.
EPA requests ADF&G to identify design parameters for the extent of the removal of the original erosion control wall. The parties who conducted the remedy have constructed an erosion control structure away from the creek and are willing to remove the original erosion control if consensus is reached between the ARRC, EPA and the State of Alaska on the extent of the removal. |
Louis Howard |
| 11/17/1998 |
Update or Other Action |
Letter to C. Cora USEPA re: ESD letter dated November 4, 1998. After reviewing the letter received on November 4, 1998 regarding the waiver of the 40 CFR 761.75(b)(9)(i). After reviewing the information provided, ADEC concurs with the EPA in its decision to waive the requirement of a six foot fence at the site. It is ADEC's understanding that the institutional controls in the ROD will be enforced to ensure the cover system at the site is maintained and use of the site is consistent with the remedy (i.e. parking lot). |
Louis Howard |
| 11/18/1998 |
Update or Other Action |
Notification letter to Alex Tula Alta Geosciences Inc. re: Waiver of 40 CFR Section 761.75(b)(9)(i). The U.S. EPA has evaluated the remedial action at the Standard Steel and Metals Salvage Yard relative to the requirements of the July 16, 1996 Record of Decision (ROD). The approved design and remedial action exceed the requirments of the ROD and justify (the US EPA) waiving the requirements to construct and maintain a fence around the TSCA Landfill pursuant to 40 CFR 761.75(b)(9)(i). All other conditions required in the ROD apply, in particular, the institutional controls must be diligently monitored and enforced. Enclosed is the Explanation of Significant Difference (ESD) for the waiver. Signed Chris Cora Remedial project manager.
Description of the Significant Differences and the Basis for those differences: This ESD was determined necessary to document the waiver of 40 CFR 761.75(b)(9)(i), fence or barrier controls at TSCA landfills, for the on-site TSCA landfill. The intent of 40 CFR 761.75(b)(9)(i) is to prevent unauthorized persons or animals from entering the landfill and being exposed to PCBs.
The ROD provided for a vaiver of a 6 foot high woven mesh fence, wall or similar device, if the site was constructed as either abutting foundation or parking lot. The ROD required that the treated contaminated soils in the containment cell be covered with clean soil to support a vegetative cover or paved over to prevent erosion of surface soil. the ROD selected cleanup levels of 10 mg/kg PCBs and 1000 mg/kg lead for surface soils at the site and therefore required access restrictions to prevent exposure to individuals, except short or long-term workers.
The approved design was enhanced by excavating and consolidating all upland surface soils outside the limits of the TSCA landfill which exceed 1.0 mg/Kg PCBs or 500 mg/Kg Lead and adding a geomembrane cover system, consisting of a four (4) inch foam layer, 40 mil geomembrane impermeable liner, geonet drainage layer, geonet filter fabric, and three (3) feet of clean soil. The addition of the geomembrane cover system and three feet of soil exceeds the design requirements of the ROD and satisfies the intent of 40 CFR 761.75(b)(9)(i). Institutional controls in the ROD and agreed to by the Alaska Railroad Corporation in the January 26, 1998 Consent Decree provide notice of the TSCA Landfill to the landowner, lessees, and local utilities, and will prevent excavation, construction, or other incompatible uses at the Site.
The modified remedy continues to satisfy the requirements of CERCLA section 121.
Considering the new information and results of the Pre-Final Completion inspection, EPA believes that the remedy:
1) remains protective of human health and the environment,
2) complies with Federal and State requirements that were identified in the ROD signed by the US EPA on July 16, 1996 as applicable or relevant and appropriate to this remedial action at the time the ROD was signed, and
3) is also cost effective with regard to the risk posed.
Signed by Michael F. Gearhard Associate Director of Environmental Cleanup Office 11/18/1998. |
Louis Howard |
| 4/30/1999 |
Update or Other Action |
April 1999 groundwater monitoring report received for sampling that was completed in May 1998. No PCBs, Lead and halogenated volatile organics were detected in any monitoring wells (MW 13, 14, 15 and 22).
Non-detect for all analytes at the practical quantitation limit (PCBs 0.1 ug/l; lead 5.6 ug/l; HVOCs 1.0 to 8.0 ug/l). |
Louis Howard |
| 5/31/1999 |
Update or Other Action |
US EPA fact sheet: Returning Sites to Productive Use. In Anchorage, Superfund sites are less common than seeing a moose in town. One of those sites, Standard Steel and Metals Salvage Yard, recently had a make-over. Tucked away in an industrialized part of the city along the north side of lower Ship Creek, the site has been used by metal recyclers and salvage operators for the past 30 years. These businesses left the soil and groundwater contaminated with PCBs and lead. In 1990, EPA added the site to its list of hazardous waste sites needing cleanup. Once the site was listed, EPA and those responsible for the contamination cleaned it up by removing some of the surface waste, and treating, solidifying and covering the remainder with a cap. Now the site is ready for new occupants, and part of it is already being leased to the owner of a local trucking company, who uses it to store equipment and as a parking lot for trucks. |
Louis Howard |
| 7/25/1999 |
Update or Other Action |
July 1999 Completion Report: Remedial Action Construction documents action taken at site. Remedial action construction undertaken by PRP starting in April 1998 and substantially completed by November 1998. Landscaping and streambank restoration work on Ship Creek was finished in June 1999. Elements of the construction included:
construction of an onsite TSCA compliant landfill (consolidation cell) for isolation of PCB impacted soils including a geomembrane cover system and up to 3 feet of soil cover.
Excavation of 32,700 tons of moderately impacted soils and placement without treatment into onsite TSCA landfill. Excavation, stabilization/solidification treatment and consolidation of 22,272 tons of more heavily impacted soils, including lead stabilization with Maectite of 9,700 tons of soil.
Following completion of all soils removal, treatment, and consolidation, the consolidation cell was capped using a layer of foam insulation, 40 mil XR-5 geomembrane, a geocomposite drainage layer and 3 feet of cover soil. Sideslopes on the cell were covered with a shallow layer of topsoil, a layer of jute matting and hydroseeded for erosion protection.
Screening, classification and disposal of ordnance related scrap and potential UXO materials.
Construction of an erosion control wall to protect the consolidation cell from floodwaters involving 13,700 tons of riprap and bedding materials.
Final inspection of the remedial action construction was held with contractor and U.S. EPA on June 25, 1999. No significant deficiencies were observed.
Enhancements added to the description of the remedy of the ROD to improve freeze thaw resistance of the solidified soil, provide additional flood protection to the consolidated soil, and reduce or eliminate the areas for which land use controls and Site access restrictions were needed.
1) Addition of a geomembrane cover system covering the solidified soils.
2) Construction of a completely new erosion control structure located inland from the existing stream bank.
3) Excavation and consolidation of all upland surface soils outside the limits of the landfill which exceed 1.0 mg/kg PCBs or 500 mg/kg lead.
4) Placing three feet of clean cover over the geomembrane cover system and all contaminated soils within the landfill.
Soil Stabilization: approximately 22,300 tons of soil determined to have 50 mg/kg PCBs or greater and/or 1,000 mg/kg lead or greater was treated by mixing with Portland cement and flyash in a pugmill prior to placement in the TSCA landfill.
With respect to soils removal, the following was required:
Excavation and consolidation of all soils exceeding 10 mg/kg PCBs or exceeding 1000 mg/kg lead cleanup level;
stabilization/solidification (S/S) treatment of all soils having contamination levels equal to or greater than 1000 mg/kg lead or equal to or greater than 50 mg/kg PCBs;
on site disposal of S/S treated soils and of excavated soils contaminated between 10 mg/kg and 50 mg/kg PCBs in the consolidation cell;
Excavation of soils contaminated above 1.0 mg/kg PCBs and 500 mg/kg lead from Ship Creek flood plain and consolidation of these soils on the portions of the Site where use and access restrictions will be implemented.
During the Design phase it was decided to remove soils outside the boundary of the landfill containing 1.0 to 10 mg/kg PCBs and less than 500 mg/kg lead in locations less than 3 feet from the finished surface. NOTE: This was done to mitigate restrictions requiring fencing and/or institutional controls of the remediated Site, if such soils remained in the top 3 feet of Site soils. |
Louis Howard |
| 9/15/1999 |
Update or Other Action |
May 1999 groundwater monitoring report received for May 1999 monitoring events. No COCs were detected in monitoring wells 13, 14, 15, 22. All samples analyzed by EPA Method 3031 for PCBs, 7421 for Lead and 8260B for halogenated volatile organics. |
Louis Howard |
| 9/16/1999 |
Update or Other Action |
USEPA signed a preliminary close out report on September 16, 1999 documenting the completion of remedial construction activities (i.e. construction complete). |
Louis Howard |
| 12/6/1999 |
Update or Other Action |
USEPA letter to Alex Tula re: EPA approval of the Remedial Action Construction Completion report September 13, 1999. EPA has reviewed and approves the Final Remedial Action Construction Completion Report. The Standard Steel and Metals Salvage Yard Site is now in an "operation and maintenance" mode, including monitoring. Upon determination by Settling Defendants that the remedial action is operational and functional and that Performance Standards identified in the July 1996 Record of Decision have been met, but not less than two years following the Final Construction Completion Inspection Settling Defendants should notify EPA and the State that the Remedial Action is complete. The Final Inspection was conducted on June 25, 1999.
In regards to the October 7, 1999 letter requesting that EPA eliminate the requirement to submit monthly progress reports for the Site, EPA has reviewed the relevant sections of the Consent Decree (Sections X, XII, XXXI). The requirement to submit monthly status reports is contained in the body of the Consent Decree. In order to "materially modify" the Consent Decree we would have to obtain the approval of all parties, and the Court. Due to the level of effort required to revise the Consent Decree, EPA believes it is unjustified for the reasons presented in the letter. If the Settling Defendants provide additional significant reason to undertake this course of action, EPA will consider it. |
Louis Howard |
| 12/29/1999 |
Update or Other Action |
11/99 second semiannual groundwater monitoring report received. No detectable levels of PCBs were found with a PQL of 0.099 ug/L. Lead levels were all below 15 ug/L, Methylene chloride were all below 5 ug/L even though they were considered lab contaminants. Methylene chloride was detected in one sample at 2.6 ug/l but was also found in the lab blank at 1.7 ug/l. This is likely a lab contaminant. |
Louis Howard |
| 7/1/2000 |
CERCLA Remedial Design/Remedial Action Plan Approved |
Operations and Maintenance plan (revised) Remedial Design/Remedial Action(RD/RA). Overall goal of the RA design and construction for the Site is to provide an effective mechanism for protecting human health and the environment from contaminated Site soils, while allowing future industrial and commercial use of the property. The Operations and Maintenance (O&M) plan presents a discussion of the features constructed during the RA and the maintenance, inspection, and monitoring requirements which apply to the Site in the post RA Construction area.
Operating Limitations: Restrict any activities that would cause environmental or human exposure to consolidated or treated soils in the TSCA cell (the Remedial Design incorporated provisions which were more protectective than strictly required by the ROD. Geomembrane cover system constructed on top of the stabilized portion of the consolidation cell followed by 3 feet of clean soil fill. Excavation and consolidation with the consolidation cell of all soils containing greater than 1 mg/kg PCBs from all affected areas to at least 3 feet. in depth). Also restricted are activities which might penetrate, expose, or either chemically or physically damage the geomembrane cover system. Placement or storage of heavy objects (> 2,000 pounds) over the geomembrane system is prohibited. Open fires on the ground surface is prohibited. Sides of the cell cannot be paved or covered in such a way as to inhibit drainage discharge system.
Building Sites with Minimal Limitations: Light industrial and commercial structures located on specific portions of the Site are compatible with the RA design and construction. Utilities crossing the consolidation to buildings or beneath buildings should not penetrate the geomembrane cover system and must remain at least 1 foot above the top of this system unless specific engineering and health and safety provisions are adopted. Footings placed at least one foot above the geomembrane liner may be constructed without special construction techniques or considerations.
The entire site should be suitable for parking or storage, and loading or unloading of vehicles, provided suitable modifications are made for the intended use. Safe use by heavy vehicles or repeated traffic may require the placement of additional surface materials such as crushed rock road base, and/or asphalt concrete paving.
Future developments and operations on or around the consolidation cell must not create ponded water on the cell or interfere with surface water drainage. Snow must not be plowed into the drainage ditches, since this will intefere with their functioning during spring breakup.
Maintenance requirements: Erosion protection wall must be maintained, inspection should be required following any major flood event, with timely repair of any damage. The top surface and sides of the consolidation cell must be maintained free of deep-rooted plant species and any erosion or man made excavations must be immediately backfilled with engineered fill. Side slopes of the consolidation cell should be inspected for slope failures or slumping following major earthquakes in the Anchorage area, and repairs should be initiated if damage is identified.
Inspections of the consolidation cell needs to be made at least twice yearly during the first three years(1999-2001) following remedial construction; Once in April or May and once in August or September. After that time, annual inspections in the Spring should be sufficient. Inspections should also be made following major flood events, wildfires, earthquakes, or other events with the potential to damage the cell. Monitoring of ground water will continue for a minimum of 5 yrs., twice yearly for minimum of 2 yrs., w/EPA concurrence, may be reduced to yearly monitoring. Analyses will be for PCBs, Lead and Halogenated volatile organic compounds. |
Louis Howard |
| 1/18/2001 |
Update or Other Action |
Semiannual Groundwater monitoring report received dated October 2000. Event was in September 2000 and groundwater samples were taken from 4 wells on 9/28 and 9/29/2000. No detectable values for PCB aroclors (PQL of 0.5 ug/L). No detectable values for lead were reported. Detection levels for lead were at 13.9 to 14.2 ug/L which is slightly higher than the target reporting limit of 5 ug/L. Error due to laboratory changes in analytical procedures. Methylene chloride was detected in two samples at 1.2 ug/l and 1.5 ug/l and chloromethane was detected in one sample at 1.2 ug/l. These are considered to be lab contaminants.
May 2000 samples were all non-detect for all analytes at the PQL (PCBs 0.5 ug/l, lead 5.6 ug/l, hvocs 1.0 ug/l). |
Louis Howard |
| 1/19/2001 |
Update or Other Action |
Inspection on 9/27and 9/28/2000 by ALTA Geosciences in accordance with the Operations and Maintenance plan. 2 items were observed needing attention: 1) erosion on the Yakutat Street drainage ditch; and 2) trash accumulation in the drainage ditches. ARRC representatives agreed to work with its tenants to resolve these items. |
Louis Howard |
| 1/30/2001 |
Update or Other Action |
Alta Geosciences Inc letter to USEPA RE: modification to the groundwater monitoring plan SS&MSY Site. In two years of monitoring semiannually at the Site following completion of the Remedial Action Construction, there have been no significant detections of chemicals of concern at the site. NOTE:The ROD did not retain groundwater as a medium of concern for development of RAOs. LNAPL is present at the center of the site, no dissolved contaminants were identified at the boundary of the site. Prevention of future migration of contaminants into groundwater was addressed by the selected remedy in the ROD.
A request is being made to reduce the groundwater monitoring frequency to once per year. The difference of groundwater elevation from spring to fall in site monitoring wells is less than 0.3 foot. Because this difference is inconsequential, it is also requested that the allowable timeframe for the sampling be extended to the period May 1st through September 30th. |
Louis Howard |
| 5/3/2001 |
Update or Other Action |
USEPA letter to Alex Tula RE: Groundwater monitoring modification and November 2000 Semi-Annual Inspection Report SS&MSY. EPA has reviewed the January 25, 2001 request to modify groundwater monitoring at the Site. EPA approves the request to conduct groundwater sampling annually. Justification is based on the data submitted during the past two years of monitoring. EPA has concerns with how the remedy for the Site is being implemented and maintained.
On September 28, 2000 a semiannual site inspection occurred. During that inspection 3 items were identified which indicate to EPA that due diligence in implementing the institutional controls are not occurring.
1) Drainage Channels and Pipes: Recent paving on Yakutat St. has resulted in soil erosion which is impacting a drainage structure for the Site. This erosion is placing sediment and dirty water into Ship Creek. Trash and debris is also accumulating in side ditches.
2) Cell Side Slopes: It is alleged the current tenant is dumping/plowing large amounts of snow over the back of the cell each year. In only two years this has resulted in excessive gravel/soil and wood debris being deposited on the Erosion Control wall.
3) Monitoring Wells: Upgradient Monitoring well 22 has allegedly been destroyed by construction/paving.
Although none of these items has resulted in a failure of the containment cell, they reveal by those responsible for maintaining the Site. In particular, it appears the institutional controls are not being fully implemented. EPA's concern is compounded because only two years have passed since the remedy was implemented. EPA considers the site a TSCA landfill, and as such, requires diligent management. EPA denies the request for not replacing monitoring well 22 and will expect all drainage channels and erosion control structures be repaired by the next inspection. |
Louis Howard |
| 5/31/2001 |
Update or Other Action |
Alta Geosciences Inc letter to EPA re: Erosion Control Measures SS&MSY Site. Paving of Yakutat Street has resulted in changes in the runoff patterns and some erosion has developed on the Yakutat St. side of the drainage ditch along the east side of the Site. After careful evaluation, it was concluded that the installation of a protective gravel blanket in the effected areas was the best long term solution to this problem. |
Louis Howard |
| 8/27/2001 |
Update or Other Action |
EPA conducted a Final Inspection on August 27, 2001 of the Remedial Action. The inspection determined that:
-the Settling Defendants had constructed the remedy in accordance with EPA approved remedial design plans and specifications;
-all remedial construction activities were complete;
-the remedy was operational and functional and met the remedial action goals and objectives;
-the required two years of groundwater monitoring was performed and all groundwater remedial action goals have been met;
-all the institutional controls required by the Record of Decision have been implemented. |
Louis Howard |
| 9/17/2001 |
Update or Other Action |
Unexploded Ordnance (UXO) workplan and groundwater sampling results received. Excavation of 20mm projectiles and the expected UXO burn pit site is planned. If during the course of the excavation geophysical or physical data indicates that UXO other than 20mm projectiles is present at the job site, all work will cease pending further notification. During excavation of contaminated soils containing PCBs and lead, multiple UXO scrap items were located, identified and certified as inert.
Here is a list of what was previously found at the site during excavation:
Shell casings: 75mm, 105mm, 106mm, 90mm, 60mm, and 40mm. Projectiles: 20mm and 40mm. 2.36" Rocket, Rifle grenades, 100mm fuzes, 3.5" bazooka, anti-tank mines, 2.75" rocket warhead. NOTE: all casings appeared to have been burnt with no primer burster tubes or have been fired and empty of propellant). Bazooka rocket 2.36" were for the most part without nose caps, propellants but had safety pins in place. All warheads were empty of any filler. One rocket was found that had its nose cap and motor in place and could not be identified to be an inert practice round. EOD staff from Fort Richardson provided disposal onsite by detonation. Anti-tank rifle grenades had safety pin in place, no live rounds were found and no explosive filler was found. 40mm projectile: anti-tank projectile with the tracer burned out, smooth rotating band indicating it had been disposed of by burning rather than fired from a gun.
Several inert fused 3.5" bazooka rockets were found within the 20mm area with blue warheads, blue anodized fuses, and were empty of any propellant. 20mm projectiles: Shell casings were missing and external features indicated they could be one of three types (incendiary, high explosive incendiary, or practice). Safety precautions will be followed for all projectiles using the procedures for the most hazardous: high explosive incendiary (M97). AN M100 series bomb tail fuses: mechanical impact tail fuses found to be without the primer detonator and the condition was consistent with burning by disposal. All fuses were found with safety pin in place. 2.75" rocket warheads: warheads are inert plaster filled with no fused warheads found to date.
Halogenated volatile organics were detected in sample #982133005 Well 22MSD (surface, eff., ground): results ranged from: 34ppb bromoform, 38 ppb for dibromochloromethane, chlorobenzene to 41ppb for trans 1, 2-dichloroethene, 1,1-Dichloroethane, 1,1,1-trichloroethane, and trichloroethene. |
Louis Howard |
| 6/11/2002 |
Update or Other Action |
Draft Site Close Out Report received for the SS&MSY Site. The report documents that remedial activities are complete and cleanup goals have been achieved for the Standard Steel and Metals Salvage Yard site in accordance with Close Out Procedures for National Priorities List Sites (OSWER directive 9320.2-09A-P). Sampling as discussed earlier verifies that the remedy has been implemented in accordance with the ROD and that it is protective of human health and the environment. All groundwater samples since completion of the remedial construction in July 1999 had concentrations below the ROD cleanup levels (MCL’s and action level for lead).
The Settling Defendants choose to incorporate stricter cleanup criteria for soils within the top three feet of the site. Those criteria are 250 mg/Kg for lead and 1.0 mg/Kg for PCBs. This design removed surface contamination above residential cleanup levels. Stormwater controls were employed to prevent the direct discharge of contaminated sediments into Ship Creek during and after construction.
The Settling Defendants selected a cleanup level of 1mg/Kg for PCBs and 250 mg/Kg for lead in soils within 3 feet of the surface in areas outside the containment cell. In addition a three foot layer of uncontaminated soil was placed on the surface of the containment cell. This provides greater protection of all receptors exposed to the site and reduces the potential for soil migration to Ship Creek and surrounding areas.
The only required actions for the Site are groundwater monitoring for 10 years, Institutional Controls, maintenance of the containment cell, five year reviews and potential site deletion.
Hazardous substances will remain at the site above levels that allow unlimited use and unrestricted exposure after the completion of the remedial action. Pursuant to CERCLA section 121(c) and as provided in the current guidance on Five Year Reviews, EPA must conduct a statutory five-year review to ensure that the remedy continues to provide adequate protection of human health and the environment. The Five-Year Review Report will be completed prior to March 2003 (five years after RA on-site mobilization). |
Louis Howard |
| 7/24/2002 |
Update or Other Action |
After a staff briefing managment, they concurred with the EPA's Superfund Final Closeout Report for the Site. |
Louis Howard |
| 8/14/2002 |
Update or Other Action |
A "Notice of Intent to Delete" for this site was published in the Federal Register on August 14, 2002 (67 FR 52918). The closing date for comments on the Notice of Intent to Delete was September 15, 2002. A comment letter was received after the comment period closed. The commentor opposes EPA's remedy and proposes an alternative remedy using peroxidative treatment. EPA selected its remedy after holding a public comment period between March 18 and April 17, 1996. Pursuant to the National Contingency Plan, EPA selected a stabilization/solidification and containment remedy which is protective of human health and the environment. Because hazardous substances will remain at the site above levels that allow unlimited use and unrestricted exposure, the site will undergo five-year reviews.
EPA identifies sites that appear to present a significant risk to public health, welfare, or the environment and it maintains the NPL as the list of those sites. Any site deleted from the NPL remains eligible for Fund-financed remedial actions in the unlikely event that conditions at the site warrant such action. Section 300.425(e)(3) of the NCP states that Fund-financed actions may be taken at sites deleted from the NPL. Deletion of a site from the NPL does not affect responsible party liability or impede Agency efforts to recover costs associated with response efforts. |
Louis Howard |
| 9/15/2002 |
Update or Other Action |
Groundwater results Non-detect for PCBs at 0.1 ug/L PQL, Lead detected in one well at 2.28 ug/l, HVOCs not detected in 2 of 6 wells. In the other four wells, the following were reported: Well MW-14: 1,2,4-trichlorobenzene 0.53 ug/l, 1,2,3-trichlorobenzene 1.28 ug/l, well MW-15: naphthalene 1.29 ug/l, well MW-24 tetrachloroethylene 0.45 ug/l, 2,2,4, trichlorobenzene 0.33 ug/l. Well MW-18 (dup of MW-24) tetrachloroethylene 0.45 ug/l, trichloroflouromethan 0.33 ug/l. All other HVOCs were non-detect. |
Louis Howard |
| 9/30/2002 |
Update or Other Action |
61272 - 61273 Federal Register / Vol. 67, No. 189 / Monday, September 30, 2002 / Rules and Regulations. ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 300 [FRL-7384-3] National Oil and Hazardous Substances Pollution Contingency Plan; National Priorities List Update AGENCY: Environmental Protection Agency. ACTION: Notice of deletion of the Standard Steel and Metals Salvage Yard Site from the National Priorities List. SUMMARY: The U.S. Environmental Protection Agency (EPA), Region 10, announces the deletion of the Standard Steel and Metals Salvage Yard Site which is located in Anchorage, Alaska, from the National Priorities List (NPL). The NPL is appendix B of 40 CFR part 300 which is the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), which EPA promulgated pursuant to section 105 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended. EPA and the State of Alaska have determined that the Site poses no significant threat to public health or the environment and, therefore, no further remedial measures pursuant to CERCLA are appropriate. Effective date:September 30, 2002.
FOR FURTHER INFORMATION CONTACT: Beverly Gaines EPA Point of Contact U.S. Environmental Protection Agency Region 10
1200 Sixth Avenue Mail Stop ECL-110 Seattle, WA 98101 (206) 553-1066
NOTE to FILE: The NCP (40 CFR 300.425 (e)) states that a site that is deleted from the NPL is eligible for further fund-financed remedial actions should future conditions warrant such action. A Superfund site can be deleted from the NPL when one of the following criteria, as identified in the NCP (40 CFR 300.425(e)), is met. These criteria are as follows: Responsible or other parties have implemented all appropriate response actions required; all appropriate Fund-financed response under CERCLA has been implemented and no further response action by responsible parties is appropriate; or, the remedial investigation has shown that the release poses no significant threat to human health or the environment, and therefore, taking remedial measures is not appropriate. |
Louis Howard |
| 2/26/2003 |
Update or Other Action |
Site inspection for five year review conducted with EPA. Section 121 of CERCLA, as amended by SARA, requires that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site be subject to a five-year review. The NCP further provides that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure protection of human health and the environment.
The Five-Year Review requirement applies to all remedial actions selected under CERCLA §121. Therefore, sites with CERCLA remedial actions may be subject to a five-year review. Consistent with Executive Order 12580, other Federal agencies are responsible for ensuring that five-year reviews are conducted at sites where five-year reviews are required or appropriate.
It appears conditions of land use are in compliance with requirement with the record of decision to remain industrial use.
As described in § 300.425(e)(3) of the NCP, any site or portion thereof deleted from the NPL remains eligible for remedial actions in the unlikely event that conditions at the site warrant such action in the future. Deletion of a site from the NPL does not affect potentially responsible party liability or impede agency efforts to recover costs associated with response efforts. |
Louis Howard |
| 4/23/2003 |
CERCLA ROD Periodic Review |
First Five year review report received and is required pursuant to Section 121 of CERCLA triggered by remedial actions at the site which began on 4/23/1998. The remedial action left wastes in place that do not allow for unrestricted use. The immediate threats have been addressed and the remedy is expected to remain protective of human health and the environment. Groundwater monitoring at the site will continue for another five years to ensure on-site groundwater is not adversely impacted by stabilized material and that no off-site migration occures that could affect Ship Creek.
Issues: drainage was temporarily affected due to local street paving. This was corrected in 2001. Recommendations & followup actions: Continue annual operation and maintenance activities to ensure the integrity of the solidified material and cap. Protectiveness statements: Because the remedial actions at the site are protective, the site is protective of human health and the environment. 85 post cards were mailed out to inform interested parties of the review and no comments were received during the review.
Institutional controls that are in place include: restrictions to access, prevent use of groundwater, and maintain current land use on the property (industrial). The also is a prohibition of disruption of the cover on the TSCA landfill. Vehicle3 storage is allowable. Numerous trucks, trailers and some earthmoving equipment was observed parked on the capped area. No impacts to the cap were noticed at the locations of these vehicles or elsewhere on the cap.
The Alaska Railroad Corporation (ARRC) is the owner of an exclusive license to the property under the Alaska Railroad Transfer Act. ARRC executed and filed the Declaration of Restrictive Covenants per the Consent Decree Requirements with the local land recording district office in Anchorage. ARRC's lease agreements for the property notify the lessee of the institutional controls which must be complied with to meet the conditions of the Record of Decision. Additionally, notice of the remedy and the Declaration of Restrictive Covenants was provided to applicable state and local government agencies and all local utilty companies.
In summary the ICs contained in the RD/RA Consent Decree, ROD, recorded through a declaration of restrictive covenants are:
Ensure that site use continues to be industrial or commercial and prevent use of the site for commercial developments that involve potential chronic exposures of children to soil (e.g. use of the site for a day care center);
Restrict activities at the site that could potentially impari the integrity of the TSCA Landfill;
Prevent movement of soil containing greater than 1000 mg/kg lead or 10 mg/kg PCBs to the surface or within the top foot of soil where chronic long-term worker exposure could occur.
Groundwater use restriction recorded with local, regional and State agencies, departments and utilities.
No groundwater wells in the unconfined aquifer have been identified within a half mile of the site and there are no potable water wells on the site. |
Louis Howard |
| 6/10/2005 |
Update or Other Action |
File number issued 2100.38.457. |
Aggie Blandford |
| 4/11/2008 |
CERCLA ROD Periodic Review |
Second Five year review received. The remedy selected for the Standard Steel & Metals Salvage Yard Superfund Site in Anchorage, Alaska includes: removal and offsite disposal of regulated material stockpiled onsite; offsite disposal of scrap metal and debris; excavation, stabilization and capping of contaminated soils on site; maintenance of the cap and erosion control structures on Ship Creek; institutional controls; and groundwater monitoring. The site consists of one Operable Unit; therefore this five year review covers sitewide conditions.
The site achieved Construction Completion with the signing of the Final Close Out Report on June 26, 2002. The site was deleted from the National Priorities List on September 30, 2002. An initial five-year review was triggered by the actual start of construction on April 23, 1998. This second five-year review was triggered by the completion date of the first five-year review, April 23, 2003.
The remedy at Standard Steel is protective of human health and the environment, and exposure pathways that could result in unacceptable risks are being controlled. The remedy is functioning as intended in accordance with the Record of Decision signed on July 16, 1996. The immediate threats have been addressed and the remedy is expected to remain protective of human health and the environment.
As of March 31, 2008 for the Standard Steel Site: • The Human Health Environmental Indicator Status is Long Term Human Health Protected. • The Ground Water Environmental Indicator Status is Under Control. • The Cross Program Measure Status is Ready for Anticipated Use (11.12 acres). As of March 2008, nine years of groundwater monitoring has been completed and demonstrates that onsite groundwater is not adversely impacted by the stabilized material and no offsite migration is occurring that could affect Ship Creek.
Issues: The ADEC reported that new information obtained during a 2007 investigation by the Alaska Railroad shows PCBs were detected in surface soil samples collected from a former drainage ditch adjacent to southwest corner of the Standard Steel site. The ADEC requested additional sampling be conducted to characterize the drainage ditch. Two of the 5 drainage ditch samples exceeded the soil cleanup level specified by the ROD for flood plain soils of 1 mg/kg PCBs.
The concentrations ranged from 0.05 to 2.13 mg/kg. The Alaska Railroad conducted the investigation under a separate Administrative Order on Consent with the US EPA. The current EPA project manager is Jacques Gusmano in the Alaska Operations Office. A draft Feasibility Study completed by the ARRC indicates they intend to remove the PCBs above 1 mg/kg in the ditch and treat the soil by incineration. The sampled area is not an active drainage pathway for the landfill cell, site land use is still industrial, thus the remedy remains protective. The data does not suggest the remedy is failing.
Recommendations and Follow-up Actions: Continue annual operation and maintenance activities to ensure the integrity of the solidified material and cap. Continue yearly site inspections for the landfill consolidation cell, cap, and drainage system. As of March 2008, nine years of groundwater monitoring has been completed and demonstrates that onsite groundwater is not adversely impacted by the stabilized material and no offsite migration is occurring that could affect Ship Creek.
After the Fall 2008 groundwater monitoring event is completed, further evaluation of continued groundwater monitoring should be conducted. A recommendation to discontinue groundwater monitoring after the 2008 event should be considered. Next 5 year review should verify that PCBs detected in former drainage ditch adjacent to the landfill containment cell were addressed under separate regulatory action between US EPA and the Alaska Railroad. |
Louis Howard |
| 3/28/2013 |
CERCLA ROD Periodic Review |
Third Five-Year Review (FYR) Report for Standard Steel & Metals Salvage Yard (USDOT) Anchorage, Alaska March 2013 received.
The remedy selected for Site (Standard Steel) in Anchorage, AK includes: removal & offsite disposal of regulated material stockpiled onsite; offsite disposal of scrap metal & debris; excavation, stabilization & capping of contaminated soils on site; maintenance of the cap & erosion control structures on Ship Creek; ICs; & GW monitoring. The site consists of one OU; therefore this FYR covers sitewide conditions. The site achieved Construction Completion with the signing of the Final Close Out Report on June 26, 2002. The site was deleted from the NPL on September 30, 2002. An initial FYR was triggered by the actual start of construction on April 23, 1998. This third FYR was triggered by the completion date of the second FYR on April 11, 2008.
The Superfund Program tracks progress at cleanup sites using several indicators, to comply with mandates of the Government Performance & Results Act (GPRA). The sitewide human exposure environmental indicator is designed to document long-term human health protection on a sitewide basis by measuring the incremental progress achieved in controlling unacceptable human exposures at a Superfund site. The GW environmental indicator demonstrates that all information on known & reasonably expected GW contamination has been reviewed & that the migration of contaminated GW is stabilized & there is no unacceptable discharge to surface water. The Sitewide Ready for Anticipated Use (RAU) measure reports that all cleanup goals in the ROD have been achieved for media that may affect current & reasonably anticipated future land uses of the site, so that there are no unacceptable risks; & all institutional or other controls required in the ROD have been put in place.
As of March 31, 2013 for the Standard Steel Site:
• The Human Health Environmental Indicator Status is Long Term Human Health Protected.
• The GW Environmental Indicator Status is Under Control.
• The Cross Program Measure Status is Ready for Anticipated Use (11.12 acres).
There are no issues that affect the protectiveness of the remedy. The following are recommendations & follow-up actions for issues that do not affect current or future protectiveness of the remedy:
1. The ROD requires a minimum of ten years of GW monitoring to ensure there are no adverse impacts to site GW or offsite migration of contaminants. The GW monitoring program to date has demonstrated the effectiveness of the landfill containment cell; no significant detections of contaminants of concern have been observed. As of March 2013, ten GW monitoring events have been performed over the course of fourteen years. A recommendation to discontinue GW monitoring should be considered.
2. Yearly site inspections of the landfill cap, drainage swales, & runoff systems are required in accordance with the Consent Decree to ensure site activities, tenant operations, & extreme weather or other unusual events do not result in adverse impacts to the integrity of the protective remedy. Adequate funding must be provided & made available by the PRP Group to perform the O&M activities & submit reports in a timely, consistent manner to the USEPA, as required by the Consent Decree. The PRP Group should examine its current funding mechanism & address any issues to ensure proper funding & the release of funds is provided to perform O&M activities at the required frequencies & submit all documentation in a timely, consistent manner to the USEPA, including prompt site inspection after any unusual events that may compromise the protective remedy such as the 2012 September flood event.
3. The next FYR should also verify that the PCBs detected above 1 mg/kg in a former drainage ditch adjacent to & southwest of the landfill consolidation cell were addressed through a separate action between the Alaska Railroad & the US EPA.
Because the remedial actions completed at the site are protective, the site is protective of human health & the environment. All exposure pathways that could result in unacceptable risks are being controlled. All threats at the site have been addressed through stabilization & capping of contaminated soils, & the implementation of institutional controls. All monitoring data indicates the landfill containment cell is functioning as required to prevent exposure to the contaminated materials, & prevent offsite migration of contaminants.
The next FYR for the site is required by April 2018, five years from the date of this review. The integrity of the landfill cap, monitoring wells, storm drainage ditches, & erosion control measures should be evaluated to determine the remedy remains protective of human health & the environment. ICs should be reviewed to ensure the land use & GW restrictions are still in place. |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 71090 name: Salvage Yard |
Louis Howard |
| 9/22/2017 |
Document, Report, or Work plan Review - other |
EPA Letter to WCC RE: ATSDR Health Consultation for SS&MS Yard. I am sending you a health consultation report conducted by the Agency for Toxic Substances and Disease Registry {"ATSDR")
for the Standard Steel and Metals Salvage Yard in Anchorage, Alaska.
I requested the report to determine whether levels of dioxin and furans detected during EPA removal actions warrant further investigation in the scheduled remedial investigation ("RI"). ATSDR's recommendation is that dioxin and furan contamination of surface soil may pose a health risk and additional sampling should be conducted. For this reason I request that a dioxin and furan (2,3,7,8 TCDD equivalency) sampling regime be implemented during the remedial investigation.
I am aware that you anticipated conducting additional sampling for dioxin and furans in the RI and just wanted to inform you that this sampling is justified and necessary .
See site file for additional information. |
Jennifer Roberts |
| 9/22/2017 |
Document, Report, or Work plan Review - other |
DEC Letter to EPA re: Draft Administrative Order on Consent for Standard Steel and Metals Salvage Yard. The Departments of Law and Environmental Conservation (DEC) will be taking a
close look at the draft in the next two weeks to identify changes that need to be made to provide for an acceptable level of state involvement in the RI/FS and remedial action and design process.
The State of Alaska, as evidenced by the December 12, 1991 Notice of Intent to Bring Citizen Suit under 42 U.S.C. 9659 (CERCLA SS 310), has a serious interest in activities which are and will be undertaken to address the problems at the Standard Steel site. We are concerned about the potential risk posed to public health and the environment by the releases which occurred at the site owned by the federal government and troubled by the approach federal agencies are taking to address the problems.
The department expected that action would be taken by the United States Department of Transportation (DOT) in accordance with Section 120 of CERCLA upon formal listing on the National Priorities List. We expect that any alternative process as proposed in the Environmental Protection Agency's (EPA) March 4, 1992 letter (Hofer to Siroky), which is in lieu of EPA issuing a unilateral order or publishing a schedule for DOT, would respect the State's role in the RI/FS process under CERCLA 120 and 121, and the National Contingency Plan.
In our March 18, 1992 letter (Siroky to Hofer) to EPA we expressed our interest in providing oversight of Standard Steel response activities. We identified eight considerations which the department would like included in the AOC. the decision-making process for the Standard Steel Site. The AOC does little to address all eight considerations outlined in the March 18, 1992 letter. For example, absolutely no mention is made in the document, nor the draft statement of work received July 31, 1992, of the State's interest in reviewing and commenting on the various documents that make up the Rl/FS process. In addition there is no provision for early incorporation and consideration of state ARAR's and no opportunity for comment on the baseline risk assessment.
See site file for additional information. |
Jennifer Roberts |
| 11/21/2017 |
Update or Other Action |
Red Tape impedes hazardous waste removal at Ship Creek, bureaucratic tangle over land ownership is stalling cleanup at Anchorage's Standard Steel & Metals Co., one of the nation's most polluted spots. & regulators cannot look at other potential waste hazards in the city's industrial strip because of the confusion among the U.S. EPA, the U.S. Department of Transportation's Federal Railway Administration (FRA) & the Alaska Railroad, officials say. "The Ship Creek area is probably one of the most troublesome spots in the community," said Carl Lautenberger, an Anchorage-based EPA official.
If the EPA were to take a comprehensive lock, Ship Creek land is "just chock-full of stuff," said Jennifer Roberts, an ADEC hydrologist & administrator of federal Superfund cleanup money. The hazardous materials, she said, include: PCBs, a carcinogen, buried asbestos; dioxins & other solvents. "Some of the property is OK, but there are bits & pieces down there that you would look at & go 'Whoa!' "Standard Steel is still a big mess," said the DEC's Roberts. "None of the stuff has gone away. The EPA pushed all the PCBs into one place."
The DEC's Roberts said the FRA appears to be dragging its feet. "They told EPA they did not have to comply with Superfund," she said. But Roberts said all of this has prevented her from looking at another troublesome spot: Arctic Cooperage at 932 Whitney Road, a former 55-gallon-drum reconditioning business closed for about five years. The doors of the half-circle-shaped building are chained & locked, nothing but undisturbed snow & an old Renault Le Car with Louisiana license plates left in the driveway. "There are rumors that Arctic Cooperage could be as bad as Standard Steel, but all we have is rumors," Roberts said. The last lessee of the land was Bernie Saupe of Fairbanks, who operates a gasoline distributorship there.
Saupe was out of the state & could not be reached for comment, but his son, Rod, said the business operated intermittently for about eight years, using a number of solvents & paint. Roberts said the building once housed a tannery, & that barrels of caustics may be buried underground.
Roberts said she is worried about the number of homeless people who camp out & build shacks & lean-tos in the industrial area. "If (the Ship Creek area) were a military base, there would be fence-to-fence ranking & it would be a Superfund site," she said. The DEC's Roberts & the EPA's Lautenberger say Ship Creek needs more scrutiny. The water table in the industrial district is unusual & unpredictable, Roberts said. & it is strange to find PCBs in the water, since they tend to like to cling to soil & stay stable, she said. That may indicate other solvents may have carried them there.
The city's 1989 report suggests applying for state & federal funds for testing, & stated "if there is no improvement in the bacteria levels by the fall of 1989, a recommendation will be made to post the creek with warning signs." Since then, though, the city has decided state water quality standards are too strict. Even though bacteria levels have increased, the city's health department will not make the recommendation, said Mark Little, water quality program manager.
See site file for additional information. |
Jennifer Roberts |
| 11/21/2017 |
CERCLA Remedial Design/Remedial Action Plan Approved |
EPA Final Consent Decree for Remedial Design/Remedial Action. In accordance with the NCP and Section 12l(f) (1) (F} of CERCLA, 42 U.S.C. § 962l(f) (1) (F), EPA notified the State of Alaska (the 11 State") on November 6, 1996, of negotiations with potentially responsible parties regarding the implementation of the remedial design and remedial action for the Site, and EPA has provided the State with an opportunity to participate in such negotiations and be a party to this Consent Decree.
Settling Defendants shall perform the Work in accordance with this Consent Decree, the ROD, the SOW, and all Work Plans and other plans, standards, specifications, and schedules set forth herein or developed by Settling Defendants and approved by EPA pursuant to this Consent Decree. Settling Defendants shall also reimburse the United States for Future Response Costs as provided in this Consent Decree; The obligations of Settling Defendants to perform the Work under this Consent Decree are joint and several. In the event of the insolvency or other failure of any one or more Settling Defendants to implement the requirements of this Consent Decree, the remaining Settling Defendants shall complete all such requirements (without waiving any rights such remaining Settling Defendants may have against the defaulting Settling Defendant or its successors or assigns) . Nonpayment by any person, including the Federal PRPs, shall not be a defense to nonperformance of any provision of this Consent Decree that Settling Defendants or Owner Settling Defendant are required to perform.
See site file for additional information. |
Jennifer Roberts |
| 11/21/2017 |
Update or Other Action |
EPA Factsheet. The existing erosion control wall, adjacent to Ship Creek, will be removed and
replaced with a much stronger wall. The new erosion wall will not be along the bank of Ship Creek, but recessed and mostly buried from view. This design will allow Ship Creek to reestablish it’s preferred channel adjacent to the site and allow for a more natural stream corridor. The flood plain will be revegetated with native plants.
Soil contaminated primarily with lead and polychlorinated biphenyls (PCBs) will be excavated. Higher-level contaminated soil, above 50 parts per million (ppm) of PCBs and 1000 ppm of lead, will be mixed with a solidifying agent like cement and placed in the on-site containment cell. Soil with PCB concentrations between 1 and 50 ppm will also be placed in the containment cell, but without solidification. The entire containment cell will be capped with a liner, which prevents water from entering the containment cell, and three feet of clean soil.
Following the cleanup, surface soil on the site will likely have no PCB contamination greater than 1 ppm. This will allow for unrestricted access to the property. There will be monitoring of the containment cell for as long as it remains on the site and groundwater for a minimum of five years.
See site file for additional information. |
Jennifer Roberts |
| 7/7/2022 |
Institutional Control Periodic Reporting |
On 7/7/2022 DEC emailed an competed EPA questionnaire for the Fifth Five-Year Review (FYR) Report for Standard Steel & Metals Salvage Yard (USDOT) Anchorage, Alaska. The remedy selected for Site (Standard Steel) in Anchorage, AK includes: removal & offsite disposal of regulated material stockpiled onsite; offsite disposal of scrap metal & debris; excavation, stabilization & capping of contaminated soils on site; maintenance of the cap & erosion control structures on Ship Creek; ICs; & GW monitoring. |
Daniela Fawcett |
| 2/22/2023 |
Institutional Control Periodic Reporting |
DEC reviewed the Draft Fifth Five Year Review Standard Steel and Metals Salvage Yard, Dated January 2023. Review letter and comment table emailed to EPA. |
Daniela Fawcett |
| 4/10/2023 |
Meeting or Teleconference Held |
DEC received responses to comments on the Fifth Five-Year Review document. EPA called as a follow up to explain the responses to DEC and discuss the finalization of the document and the responsible parties and landowners of the Standard Steel site. |
Erica Blake |
| 6/2/2023 |
Document, Report, or Work plan Review - other |
DEC provided approval for the "Fifth Five-Year Review Report for Standard Steel & Metal Salvage Yard Superfund Site, Anchorage, Alaska" Undated. The Standard Steel site is a former 11-acre metals salvage yard located north of the downtown Anchorage area and south-southeast of Joint Base Elmendorf-Richardson (JBER). The Five-Year Review remedy protectiveness determination was for short-term protectiveness because adjacent Ship Creek (used for sport fishing) has been migrating and threatening the integrity of the containment cell of the landfill. The document was approved with the expectation that the next Five-Year Review (scheduled for 2028) will evaluate per- and polyfluoroalkyl substance (PFAS) contamination risks. |
Erica Blake |
