Site Report: Hilcorp NS Tuboscope, Inc. Lease Tract (BPX)

Site Name:	Hilcorp NS Tuboscope, Inc. Lease Tract (BPX)
Address:	Spine Road, Prudhoe Bay, AK 99734
File Number:	300.38.094
Hazard ID:	1176
Status:	Active
Staff:	Andrea Carlson, 9074515174 andrea.carlson@alaska.gov
Latitude:	70.287500
Longitude:	-148.690400
Horizontal Datum:	WGS84

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

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

The AMF Tuboscope Company conducted their operations at the BOC pad from 1978 until February 1982 when a fire destroyed the building. The facility was used for inspection and refurbishment of tubular pipes used in oil well construction. Pipe cleaning operations using solvents occurred within the facility's shop building. A preliminary investigation in 1982 showed evidence of TCA contamination in the surface water surrounding the pad, as well as lead contamination in soil. Further investigations performed by BPXA from 1983 to 1986, discovered diesel contamination which originated from the nearby mud plant or diesel heating fuel from the Tuboscope facility. Numerous investigations have been conducted at the former Tuboscope site since the facility fire in 1982. Standard Oil Company's R&D Group performed numerous environmental assessments in Sept. 1982 to July 1983, August 1984, Oct. 1985, August 1986, and August 1987. In 1990, the EPA designated the former Tuboscope Site as a solid waste management unit (SWMU). US EPA Administrative Order by Consent (Order), Docket No. RCRA 10-99-0179 was signed in August 1999. BPXA has been operating a treatment system for this site under this Order.

Action Information

Action Date	Action	Description	DEC Staff
2/2/1992	Site Added to Database		Former Staff
12/29/1992	Update or Other Action	All conditions of the COBC were met.	Mehrdad Nadem
7/1/1996	Update or Other Action	CH2M Hill prepared a remedial work plan titled Liquid-Phase Carbon Treatment at the Tuboscope Site. The treatment system was installed spring 1996. This report documents system installation and operational history.	Rich Sundet
9/19/2001	Update or Other Action	Lease Tract Landowner changed to ADNR Fairbanks. Staff conveyed status information to R.Daley of Firemans Fund (925-944-2856X313).	Bruce Wanstall
10/8/2003	Site Characterization Report Approved	Surface soil sampling conducted at the former footprint of the Tuboscope building found lead up to 14,900 mg/kg in surface soil	Bill O'Connell
10/7/2004	Update or Other Action	DEC received a copy of the work plan (Nanoscale Iron Treatment Pre-Test Assessment WP) for EPA approval which will facilitate selection of site environmental media for future potential nanoscale iron treatment bench-scale and pilot tests. This WP describes activities to be performed under BPXA's AOC.	Linda Nuechterlein
10/12/2004	Proposed Plan	EPA issued conditional approval for the Nanoscale Iron Treatment Pre-Test Assessment WP to be conducted under BPXA's AOC.	Linda Nuechterlein
10/14/2004	Update or Other Action	DEC received BPXA's 2004 Progress Report for the former Tuboscope site which was submitted to fulfill requirements of AOC, RCRA-10-99-0179.	Linda Nuechterlein
10/15/2005	Update or Other Action	Water Treatment System report dated 10/15/05 was received. BPXA is operating a treatment system as an interim measure to contain contamination related to this gravel pad. This report describes sampling, summary of system operations, and disposal activities associated with the treatment system.	Linda Nuechterlein
4/6/2006	Update or Other Action	Received Tuboscope Bimetallic Nanoscale Particle Technology Pilot Test Work Plan dated April 6, 2006. Two bimetallic nanoparticle reagent delivery methods will be evaluated for remedial effectiveness.	Linda Nuechterlein
8/27/2007	Update or Other Action	Received 2007 System Evaluation Site Assessment Work Plan dated August 27, 2007. This work plan will allow BPXA to evaluate the effectiveness of the remediation system operating at the site. Field work associated with this work plan is tentatively scheduled for the middle of September, 2007.	Linda Nuechterlein
10/16/2007	Site Characterization Report Approved	Received Tuboscope Water Treatment System Progress Report for 2007 Field Season. Six sampling events were conducted: the first to verify the treatment system was operating properly, the next five to verify that the treatment criteria were achieved prior to reinjection of treated water at Pad 3. All samples of treated water met the treatment criteria, resulting in the collection, treatment, and reinjection of over 90,000 gallons of water at the site. Surface water samples were collected from the drainage channel on three occasions, with one sample containing TCA above the treatment criteria at 0.128 mg/l.	Bill O'Connell
11/21/2007	Site Characterization Report Approved	Received the Preliminary Soil and Water Sampling Results, 1,4-dioxane Analysis for Tuboscope. 1,4-dioxane was found in soil at the shallow test plot up to 0.42 mg/kg and in pad pore water up to 0.566 mg/l. Surface water samples collected from the tundra northeast of the site also contained detectable concentrations of 1,4-dioxane. The extent of 1,4-dioxane in pad pore water was not delineated during this investigation. Additional investigation is anticipated for 2008.	Bill O'Connell
11/30/2007	Exposure Tracking Model Ranking	Initial ranking	Bill O'Connell
4/7/2008	Update or Other Action	Received 2007 System Evaluation Site Assessment Report. The system evaluation is conducted every 5 years to evaluate the effectiveness of the treatment system at reducing the areal extent of contamination at the site. Nine soil borings were drilled at the site and completed as monitoring wells. Soil, pore water, surface water and sediment samples were collected from the site. The highest concentrations of TCA were found within the footprint of the former building. 1,4-dioxane was also detected in soil and pore water. DRO and BTEX concentrations are also greatest within the footprint of the former building. Comparison of 2007 data to 2002 data shows a general decrease of TCA in soil and pore water at the site. The water treatment system as well as natural degradation have been effective at reducing the extent of chlorinated solvent impacts.	Bill O'Connell
11/21/2008	Document, Report, or Work plan Review - other	Received 2008 Tuboscope Water Treatment System Progress Report. Due to high water levels in the drainage channel, 63,000 gallons of melt water was pumped out and sent to Pad 3 for injection without sampling in May 2008. Afterwards, nine sampling events were conducted throughout the summer to verify the efficacy of the treatment system and to measure contaminant concentrations in the drainage channel. Of the four sampling events conducted in the drainage channel, 1,1,1-TCA was detected above the treatment criteria on 8/25/08 only. Lead, chloroethane, 1,1-DCA, and BTEX were each detected during at least one sampling event, but at concentrations below the treatment criteria. During the 8 sampling events at the system outlet, lead was detected during two events, and 1,1-DCA and 1,1,1-TCA were each detected during one event. During the treatment season approximately 132,000 gallons of water were treated and disposed of in the Pad 3 injection well.	Bill O'Connell
2/10/2009	Site Characterization Workplan Approved	ADEC has reviewed the RCRA Facility Investigation work plan for the former Tuboscope Site. The plan was prepared to meet the requirements of the EPA Administrative Order on Consent in place at the site. The objectives of the investigation are to evaluate the impacts of hydrogeology and human activities on contaminant migration and to delineate the on-pad and off-pad extent of impacts to soil, surface water and pore water. This plan contains details on Phase II sampling that will address data gaps from the Phase I sampling. Planned activities include: an inspection of the curtain liner surrounding the site that was installed in 1988, installation of soil borings and monitoring wells and the collection of surface water, sediment, pore water, surface soil, and subsurface soil samples. Off pad sampling will be conducted in winter 2009-10 due to tundra access restrictions.	Bill O'Connell
4/16/2009	Update or Other Action	Reviewed Interim Measures Work Plan Former Tuboscope Site. The objective of the interim measures is to "stabilize or otherwise control or minimize the subsurface movement of historically released chemicals to the off pad environment" Measures currently in place include the curtain liner around the site and the seasonal removal and treatment of potentially impacted surface water, however these measures did not target 1,4-dioxane, an emerging contaminant of concern that was found in soil and porewater at the site during recent investigations.. The interim measure workplan includes three phases, Evaluation and optimization of current measures, Data collection and treatability studies, and Implementation of the interim measures.	Bill O'Connell
11/5/2009	Document, Report, or Work plan Review - other	Reviewed Tuboscope Site Water Treatment System Progress Report for the 2009 Season. Pre-treatment activities included the removal and sampling of meltwater that had collected in the drainage channel so that the drainage channel would not overflow. Meltwater removal occurred on two occasions in May, with over 12,000 gallons removed during the first event and over 185,000 gallons removed during the second event. After sampling of the containerized water indicated contaminant concentrations were below treatment standards, the water was injected at the Pad 3 injection well. Seven sampling events were conducted at the site with various objectives. The objective of Event #1 was to verify the treatment system was working effectively before the water was transferred to the holding tank. Sample results indicated all contaminants were below treatment standards. Sampling events 2-7 were conducted to make sure treated water met standards as it exited the GAC system and to determine when the GAC needed to be changed. Sample results from these events indicated the GAC system was effective at removing contaminants, as no samples exceeded treatment standards. During sampling events 1 and 4, untreated water was sampled directly from the channel, and for the first time since 2002 when the sampling began, contaminants were not detected above treatment standards. Total volume of water treated in 2009 was over 112,000 gallons.	Bill O'Connell
3/16/2010	Document, Report, or Work plan Review - other	Reviewed work plan to investigate soils north of Tuboscope site prior to expansion of a secondary containment at the chemical storage area. Up to 9 boreholes will be sampled to 4 feet bgs to characterize soils for disposal or reuse.	Bill O'Connell
9/2/2010	Update or Other Action	Comments submitted by EPA to BPXA regarding the RCRA Facility Investigation Work Plan dated January 30th, 2009 (See Action dated 2/10/09).	Bill O'Connell
9/22/2010	Update or Other Action	Response to EPA comments on RCRA Facility Investigation work plan received from BPXA.	Bill O'Connell
10/27/2010	Document, Report, or Work plan Review - other	Reviewed Tuboscope Site Water Treatment System Progress Report. Approximately 119,784 gallons of water were treated with the GAC filter system and disposed on at the Pad 3 Class I UIC injection well. One pre-treatment sampling event was conducted in May 2010 followed by eight post treatment sampling events to gauge the effectiveness of the treatment system. Shortly after the May 2010 sample was collected from melt water in the drainage channel, high water levels necessitated the dewatering of the channel before analytical results were received. Approximately 121,800 gallon of melt water were collected followed by an additional 17,220 gallons of water collected after a rainfall event. This water was disposed of at the Pad 3 injection well with EPA approval, and the sample results indicated contaminant concentrations in the drainage channel water were below treatment standards. Sampling event #1 was conducted to verify the treatment system was operating before water was routed from the GAC system to the holding tank and sampling event #2-8 were conducted to insure the water had been treated prior to injection. Additional sampling was conducted in the drainage channel itself and also between GAC canisters to determine when the first canister needed replacing. Sampling indicated the GAC system was effective at removing contaminants, as no performance samples contained contaminants above treatment standards. Samples collected from the drainage channel on 4 occasions during the 2010 treatment season contained 1,1-DCA and 1,1,1-TCA up to 66.7 ug/l and 166 ug/l, respectively, above the respective treatment standards of 59 ug/l and 54 ug/l.	Bill O'Connell
10/24/2011	Document, Report, or Work plan Review - other	Reviewed 2011 Water Treatment System Progress Report for Tuboscope. Eight sampling events were conducted, one before the treatment system was activated for the season and seven during system operation. The pre-treatment sampling event did not indicate the presence of contaminants in water that had collected in the drainage channel, so the water (~25,000 gallons) was collected and disposed of at the Pad 3 injection well without treatment. Performance sampling conducted throughout the treatment season including the collection of samples from the drainage channel, system outlet, and between the two GAC canisters to monitor for breakthrough. Performance sampling indicated concentrations of 1,1,1-TCA had increased to a concentration above the treatment standard towards the end of the treatment season, but that the system was effective in removing chlorinated compounds from impacted surface water.	Bill O'Connell
2/21/2012	Document, Report, or Work plan Review - other	Reviewed the Work Plan Addendum-RCRA Facility Investigation for the former Tuboscope Site. The objective of the addendum is to outline the additional phases of work necessary to characterize the environmental conditions at the site and evaluate the nature and extent of all COPCs in all media to support development of corrective measures. This work includes expanding the investigation area both vertically and horizontally, expanding the hydrologic study area, evaluating background concentrations of metals in site media, performing habitat mapping, and investigating the impacts from the former mud plant at the site, the location of which may have been in error in the original RFI work plan. Samples collected during this phase will be analyzed only for the primary COPCs at each source area including 1,4-dioxane, 1,1,1-trichloroethane, and its breakdown products, DRO, barium, and select other compounds.	Bill O'Connell
5/4/2012	Document, Report, or Work plan Review - other	Reviewed Corrosion Inspection & Chemical Storage Facility Tanker Truck loading Area Pre Construction Site Investigation work plan for the Former Tuboscope Site. The work plan details activities to be conducted in an area north of the Former Tuboscope site to investigate the presence of contamination at an area where a secondary containment liner is planned for installation at a tanker truck loading area (TTLA). The investigation area is part of the planned RCRA Facility Investigation for this site, however due to the construction of the containment liner at the TTLA, the investigation at this area will be conducted sooner than the other RFI activities. 12 boreholes are planned with depths ranging from 3-7 feet bgs. Soil samples will be collected every foot from 1-3 feet bgs, then every other foot for deeper boreholes. Soil cores will be screened with a PID and where solvent contamination is suspected, soil will be screened using Color-Tec. Surface samples will be analyzed for VOCs, SVOCs, PAHs, and metals, deeper samples will be analyzed for metals and VOCs only. Soil samples will be submitted for TCLP analysis where appropriate. The objective of the investigation is to determine how much material is present that would be considered RCRA Hazardous Waste due to concentrations of a listed spent solvent to allow for better planning of the project	Bill O'Connell
6/22/2012	Document, Report, or Work plan Review - other	Date of Phase 2 RCRA Facility Investigation Work Plan Addendum.	Keather McLoone
8/21/2012	Document, Report, or Work plan Review - other	Reviewed Work Plan Addendum for TTLA. The design of the TTLA was reconfigured to minimize the generation of listed waste during construction, so additional investigation is necessary. 8 soil borings will be advanced and sampled in accordance with the May 2011 work plan to characterize areas in the new footprint of the TTLA.	Bill O'Connell
8/21/2012	Document, Report, or Work plan Review - other	Reviewed Phase II RFI Work Plan Addendum. The objectives if this investigation are to further characterize the environmental conditions at the site that may affect the fate and transport of contaminants and determine the nature and extent of contaminants associated with the former mud plant to support the development of potential corrective measures. Activities planned for 2012 include the placement of one additional thermistor string in a borehole within the drainage ditch adjacent to the site, replacement of one damaged thermistor string, installation of surface water elevation monitoring points and the deployment of transducers into off pad wells to monitor surface water elevations.	Bill O'Connell
8/21/2012	Document, Report, or Work plan Review - other	Reviewed Phase III RFI Work Plan. This work plan outlines the approach to evaluating existing data, filling data gaps, sampling water from wells and surface water sampling locations, and preparing the final RFI Report.	Bill O'Connell
8/30/2012	Update or Other Action	Date stamped on certified letter from EPA to BP regarding Contained-In Determination Request at Tanker Truck Loading Area.	Keather McLoone
9/11/2012	Document, Report, or Work plan Review - other	Reviewed RCRA Facility Investigation Interim Summary Report for Tuboscope. From 2008 to 2011 the following activities were conducted: advancement and sampling of 51 soil borings, thermistor installation in 11 borings, construction and sampling of 42 pore water monitoring wells, construction of 39 horizontal supra-permafrost GW monitoring wells, collection and analysis of pad gravel, tundra peat, and mineral soil samples, surface water sampling, vegetation survey, plant tissue sample collection and analysis, and an evaluation of the uptake of contaminants by plants through off-gas sampling. Contaminants of concern at the site include 1,1,1-TCA, 1,4-dioxane, DRO, lead, and contaminants associated with drilling mud. The results of the investigation indicate 1,4-dioxane is not present in soil at the site above proposed Tier I screening levels (SLs) or proposed Tier II action levels (ALs). SLs and ALs have not yet been finalized and a final comparison of the data to these levels will be conducting following their approval. TCA was not detected in soil above proposed SLs or ALs, except in one sample from the drainage ditch which had TCA above the SL but below the AL. Of the tundra and mineral soil samples analyzed for metals; arsenic, barium, cadmium, trivalent chromium, copper, nickel, selenium, and zinc were detected above SLs and ALs in numerous samples, but below the 90th percentile of proposed background concentrations. Additional site specific background study is recommended. 1,4-dioxane was detected in pore water above the AL at two sample locations and above the SL but below the AL in numerous off pad water samples. TCA and breakdown products are present in pad pore water above the ALs within the known contaminant plume. Of the water samples analyzed for metals, several samples contained lead above the SL but below the AL. Arsenic is also present in pore water above the AL, but this includes samples intended to represent background concentrations. Barium is present above the SL but below the Al in several samples. Background surface water samples contained arsenic and manganese above the SLs and ALs and background pore water samples contained arsenic, barium, and copper above the SLs and ALs. Additional evaluation of background concentrations is recommended. Data gaps identified for the RFI include the establishment of site specific background concentrations for several metals. Additional sample collection is planned for 2012 and an evaluation of the completeness of the RFI will be conducted once SLs and ALs are approved by EPA.	Bill O'Connell
9/19/2012	Update or Other Action	Date stamped on certified mail from EPA to BP regarding Tanker Truck Loading Area Project stating that EPA had no objection to the preconstruction investigation or construction activities as described in documents listed in this letter.	Keather McLoone
9/19/2012	Update or Other Action	Date stamped on letter from EPA to BP regarding hexavalent chromium aqueous sample preservation and holding time study.	Keather McLoone
9/20/2012	Update or Other Action	Date of letter from BP to EPA requesting a contained-out determination for water from TTLA construction activities with analytical data attached.	Keather McLoone
9/20/2012	Update or Other Action	Date of letter from BP to EPA requesting a reporting extension for 2012 Annual Interim Measure Water Treatment Progress Report.	Keather McLoone
9/21/2012	Update or Other Action	Date stamped on letter from EPA to BP regarding Contained-In Determination Request.	Keather McLoone
11/16/2012	Document, Report, or Work plan Review - other	Reviewed 2012 Field Season Water Treatment System Progress Report for Tuboscope. In addition to treating water removed from the drainage channel adjacent to the site, the treatment system also treated water removed during excavation activities at the newly constructed corrosion inspection and chemical storage facility tanker truck loading area. Modifications were made to the treatment system in 2012 to address issues identified during a hazard identification and risk review including automation of the shut down system, improvements in sediment filtration, and modification to the GAC adsorption unit. Water was sampled on 10 occasions during the treatment season including pre-treatment sampling of the water in the channel. Pretreatment samples did not contain concentrations of contaminants above treatment standards, therefore the melt water present in the channel was disposed of at the Pad 3 injection well. Sampling event 1 was conducted to verify the system was operating properly and events 2-9 were performed to verify treatment standards were met prior to disposal at the Pad 3 injection well. Contaminants of concern include lead, chloroethane, 1,1-dichloroethane, 1,1,1-trichloroethane and BTEX. Treatment standards were only exceeded in the drainage channel prior to treatment, only during the last sampling event, and only for 1,1,1-TCA. As in previous years the concentrations of contaminants increased in the channel throughout the summer. A total of 150,780 gallon of drainage channel water were treated by the system in 2012 and an additional 924 gallons were treated from the construction dewatering activities. All treated water was disposed of at the Pad 3 injection well.	Bill O'Connell
4/22/2013	Update or Other Action	Reviewed Final Former Tuboscope Site Interim Measures Water Treatment System Operations and Maintenance Manual. The treatment system was upgraded in 2012 to meet BP requirements and improve operational safety and efficiency. The general design of the system was not altered with a pump intake in the drainage channel that receives contaminated water, sediment filtration, three granular activated carbon vessels that operate in series, and temporary storage tanks to store treated water until disposal at the Pad 3 injection well.	Bill O'Connell
5/10/2013	Update or Other Action	Receipt of 7-day notification for 2013 calendar year field activities which will include the operation of the water treatment system. A workplan was to be submitted in late May or early June according to this letter.	Keather McLoone
5/10/2013	Update or Other Action	Date of letter from BP to EPA regarding Interim Measures during the 2013 field season - pre-treatment ditch de-watering.	Keather McLoone
7/11/2013	Update or Other Action	Date of Transmittal Letter from BP for three documents regarding TTLA.	Keather McLoone
7/29/2013	Document, Report, or Work plan Review - other	Date of receipt of the Materials Management and Excavation Report - Contruction Activities at the Tanker Truck Loading Area South of the Corrosion Inspection and Chemical Storage Facility. This area is in close proximity to the former Tuboscope building and borings were located within about 100 feet. The stockpile was field screened using a PID and determined to be suitable for reuse. Fuel impacts were noted near the bottom of a sump located in an area formerly occupied by a generator.	Keather McLoone
7/29/2013	Document, Report, or Work plan Review - other	Date of receipt of the Materials Management and Excavation Plan - Contruction Activities at the Tanker Truck Loading Area South of the Corrosion Inspection and Chemical Storage Facility. This plan states that a waste characterization sample may be collected from the stockpile, based on field screening results and gave a PID cutoff of 10 ppm using a 11.7 electron volt lamp.	Keather McLoone
7/29/2013	Document, Report, or Work plan Review - other	Date of receipt of Former Tuboscope Site Corrosion Inpsection and Chemical Storage Facility Tanker Truck Loading Area Pre-Construction Site Investigation Report dated October 22, 2012 covering work conducted in May and July 2012. The originally missing table section of this document was emailed and attached to the report.	Keather McLoone
9/5/2013	Document, Report, or Work plan Review - other	Date of receipt of Revised RCRA Facility Work Plan Addendum Amendment, Continuation of Hydrology Study Data Collection in 2013. Activities planned include maintenance of data loggers collecting temperature data as well as monitoring water levels and frost line elevations.	Keather McLoone
11/13/2013	Document, Report, or Work plan Review - other	Date of receipt of Water Treatment Progress Report for the 2013 Field Season. About 190,890 gallons of water were recovered and treated from the drainage channel adjacent to the former Tuboscope site. The treated water met criteria established by EPA for land disposal and was disposed of, early in the season, at the Pad 3 UIC Class I well and then later at the DS 4 G&I facility. GAC drums used in treatment were diposed of as haz waste. The untreated water from the drainage channel did not exceed criteria until the very end of July. This is similar to past years since 2007. Before 2007, treatment criteria were exceeded starting early June.	Keather McLoone
12/18/2013	Document, Report, or Work plan Review - other	Date of receipt of revised workplan based on EPA comment entitled RCRA Facility Investigation Work Plan Addendum Amendment - Continuation of Hydrology Study Data Collection in 2013 Version 4.	Keather McLoone
1/7/2014	Update or Other Action	Date of letter from BP regarding material excavated at the Tanker Truck Loading area.	Keather McLoone
3/27/2014	Update or Other Action	Date of letter regarding BPXA Tanker Truck Loading Area Construction Materials Management in response to ADEC letter dated 2/20/2014.	Keather McLoone
4/18/2014	Document, Report, or Work plan Review - other	Date of receipt of April 2014 revision of the document originally dated February 2013 entitled Materials Management and Excavation Report. The report was revised based on ADEC comment regarding section 4.1. More specifically, the report was revised to indicated that all excavated material that was not disposed of at the G&I facility was used as material for construction of the secondary containment.	Keather McLoone
5/7/2014	Update or Other Action	Date of receipt of 7-day notification prior to 2014 Field Activity. Field activities will include the operation of the water treatment system at the site. Additional activities are planned but are not finalized yet. A workplan will be submitted in late May or early June.	Keather McLoone
9/4/2014	Site Visit		Keather McLoone
9/19/2014	Update or Other Action	Date of receipt at EPA of letter requesting an extension for submittal of the 2014 Annual Interim Measure Water Treatment Progress Report.	Keather McLoone
10/24/2014	Document, Report, or Work plan Review - other	Date of report entitled 2013 Tuboscope RCRA Facility Investigation Interim Summary Report. The work described in this document was primarily related to the hydrology study. Activities included maintenance of temperature data loggers, manual gauging of water elevation and water column depth, and an inspection of all monitoring locations in order to either repair or note needed repair.	Keather McLoone
11/4/2014	Document, Report, or Work plan Review - other	Date of document entitled 2014 Interim Measures Water Treatment System Progress Report.	Keather McLoone
11/11/2014	Document, Report, or Work plan Review - other	Date of receipt of 2012 Interim Measuring System Evaluation Site Assessment and RCRA Facility Investigation Interim Summary Report Former Tuboscope Site.	Keather McLoone
11/17/2014	Document, Report, or Work plan Review - other	Date of receipt of 2012 Interim Measures System Evaluation Site Assessment and RCRA Facility Investigation Former Tuboscope Site. This document includes details about the Conceptual Site Model and Screening Evaluation for this site as well as a description of the 2012 Field Program which included both the System Evaluation Site Assessment (SESA) and the RCRA Facility Investigation (RFI). The RFI work included primarily data collected as part of the ongoing hydrology study and additional sampling to further delineate both soil and water impacts at the site. The focus of the discussion is often limited to select organic constituents although there are some additional organic and inorganic (metal) constituent that may warrant additional effort.	Keather McLoone
4/3/2015	Document, Report, or Work plan Review - other	Date of receipt of March 2015 version of Interim Measures Work Plan. ADEC previously received a February 2015 version as well as other earlier versions.	Keather McLoone
4/24/2015	Update or Other Action	Date of receipt of Request for Revised Contained-In Determination Criteria. The basis for the requested revisions to the CID criteria can be found in the attached Contained-In Determination Evaluation Report and Recommendation for Revisions.	Keather McLoone
5/19/2015	Document, Report, or Work plan Review - other	Date of receipt of May 2015 version of the Interim Measures Workplan	Keather McLoone
8/6/2015	Document, Report, or Work plan Review - other	Date of receipt of July version of Interim Measures Work Plan, Former Tuboscope Site.	Keather McLoone
10/6/2015	Document, Report, or Work plan Review - other	Date of receipt of Former Tuboscope Site, 2015 Interim Measures Operations Annual Progress Report.	Keather McLoone
3/25/2016	Document, Report, or Work plan Review - other	Date of receipt of draft 2015 Interim Measures Termination Pilot Study Report, dated July 2016. Site conditions were evaluated using a simulated termination scenario to determine if, or under what conditions, the water extraction and treatment system IM can be terminated. Activities mainly consisted of: monitoring thaw depth and elevation data; collecting water samples; surface water observations, and assessment of the geochemical conditions in the vicinity of the drainage ditch. ADEC submitted comments pertaining to the report on April 27, 2016 via letter.	Joshua Barsis
6/28/2016	Document, Report, or Work plan Review - other	Reviewed the Former Tuboscope Site 2016 Roadmap Report, dated June 2016. The report was intended to summarize the goals and expectations of the United States Environmental Protection Agency (USEPA), the Alaska Department of Environmental Conservation (ADEC), and BP Exploration (Alaska) Inc. (BPXA), and to facilitate the Resource Conservation and Recovery Act (RCRA) Corrective Action process.	Joshua Barsis
8/1/2016	Document, Report, or Work plan Review - other	Reviewed the Former Tuboscope Site 2016 Roadmap Report, dated June 2016, for the BPX Tuboscope, Inc. Lease Tract site. Submitted comments via letter back to RP on August 1, 2016.	Joshua Barsis
8/26/2016	Document, Report, or Work plan Review - other	Reviewed the 2016 Interim Measures Termination Pilot Study Work Plan, dated July 2016, for the BPX Tuboscope, Inc. Lease Tract site.	Joshua Barsis
9/7/2016	Document, Report, or Work plan Review - other	Date of ADEC approval of Final 2015 Interim Measures Termination Pilot Study Report, dated July 2016. See March 25, 2016 associated comment.	Joshua Barsis
11/14/2016	Document, Report, or Work plan Review - other	Reviewed the Former Tuboscope Site 2016 Interim Measures (IM) Operation Annual Progress Report, dated November 2016. Activities consisted of maintaining the water level within the drainage ditch at approximately the level of the surrounding pad pore-water to evaluate the potential rebound of chlorinated compounds if termination of the IM were to occur. Four sampling events were performed during the 2016 field season; the first was performed in May prior to dewatering, the second was performed in June in anticipation of extracting more snowmelt water from the drainage ditch, the third event was performed in July so water could be removed from the drainage ditch to keep the water level within the desired Pilot Study range, and the fourth was performed in September so the drainage ditch could be de-watered in preparation for freeze-up. All sample results were below the Contained-In Determination criteria for 1,1,1-TCA, 1,1-DCA, chloroethane, and 1,4-dioxane; and below the Toxicity Characteristic Concentrations listed for benzene and lead.	Joshua Barsis
1/9/2017	Update or Other Action	Date of document received from BPXA addressing ADEC's comment pertaining to CID criteria. A revised report is not expected.	Joshua Barsis
4/3/2017	Document, Report, or Work plan Review - other	Reviewed the Interim Measures Drainage Ditch Decommissioning Work Plan (2017-2018), dated March 2017. Proposed activities mainly consist of removing water from the drainage ditch, installing infiltration piping in the ditch, backfill the ditch, and performing post-backfilling groundwater and surface water monitoring. DEC requested minor edits and clarification in a final version of this work plan by June 1, 2017.	Joshua Barsis
4/26/2017	Document, Report, or Work plan Review - other	Reviewed the 2016 Interim Measures Termination Pilot Study Report, dated March 2017. The pilot study was completed to further evaluate whether the water extraction and treatment system IM could be terminated under current site conditions. Activities were completed between June and August and mainly consisted of maintaining a consistent water level in the drainage ditch, collecting elevation data, and collecting water samples from three monitoring wells (MW-19, MW-22, and MW-202) and six surface water locations (ST-42, ST-49, ST-50, ST-52, ST-53, and ST-73). The 2016 pilot study indicates that extraction and treatment of the drainage ditch water is no longer necessary.	Joshua Barsis
11/28/2017	Document, Report, or Work plan Review - other	Reviewed the final 2016 Interim Measures Termination Pilot Study Report, dated October 2017. This report was submitted in response to DECs comments on the draft report, dated March 2017. ADEC does not have additional comments on the report and concurs with the recommendation to backfill the drainage ditch.	Joshua Barsis
12/27/2017	Document, Report, or Work plan Review - other	Received final version of the Interim Measures Drainage Ditch Decommissioning Work Plan, dated December 14, 2017.	Joshua Barsis
12/28/2017	Document, Report, or Work plan Review - other	Reviewed the 2017 Interim Measures Annual Operations Progress Report, dated November 2017. This report details the interim measures (IM) activities completed during the 2017 field season. Activities generally consisted of drainage ditch water extraction and surface water sampling. All surface water sample results were below the specified criteria.	Joshua Barsis
9/18/2018	Update or Other Action	Sent letter on this day requesting evaluation of PFAS at this site. See file for more info.	Joshua Barsis
4/16/2019	Document, Report, or Work plan Review - other	Reviewed the 2018 Interim Measures Annual Operations and Drainage Ditch Decommissioning Report, dated March 15 2019. This report details the final ditch dewatering activities, as well as the backfilling and sampling effort completed during the 2018 field season. The drainage ditch water was dewatered 20 times between May and July 2018, and before backfilling activities begun. Four surface water sampling events were completed during this time; on May 13th, June 4th, July 15th, and on July 28th. A second surface water sample was collected on July 28th from water that was infiltrating a small excavation on the northeastern end of the drainage ditch completed form conveyance piping. Diesel impacts were noted in the infiltration water, which is what prompted the sampling. All results for all five surface water sampling events were below 2015 contained-in determination (CID) levels, as well as other applicable criteria. All extracted water was disposed of at the Pad 3 injection well. The drainage ditch was backfilled over the course of July and September 2018. Soil samples were collected from the base of the drainage ditch (between 0 and 2 feet bgs) as well from just below the base of the drainage ditch (2 to 3 feet bgs). All samples were submitted for analysis of 1,4-dioxane, VOCs, SVOCs, PAHs, metals, mercury, chromium IV, and DRO. Unfortunately, the sample container used to collect VOCs were inadequate and allowed them to thaw prior to arriving at the laboratory. For this reason, three soil borings were advanced after the drainage ditch was backfilled in order to collect the VOC samples again. Monitoring well MW-22 and Thermistor String T-63R were decommissioned during backfill activities. Additional water was extracted from the ditch as need to prevent overflowing. Following completion of backfilling activities, Well MW-22 was reinstalled. Thermistor T-63R is planned to be replaced in 2019. Analytical results revealed various contaminants remain in the subsurface soils at or below the base of the drainage ditch; up to 3 mg/kg 1,4-dioxane, 6.4 mg/kg naphthalene, 15.4 mg/kg ethylbenzene, 90.7 mg/kg xylenes, 254 mg/kg lead, and 472 mg/kg barium. ADEC sent a letter on this day requesting some additional information/changes in a revised report.	Joshua Barsis
6/28/2022	Site Characterization Report Approved	A comprehensive report for activities between 2008 and 2018 was approved. There were 72 surface water samples and 41 suprapermafrost monitoring wells samples collected. Over 90 soil samples were collected from the mineral soil, 33 samples from the pad, and 106 samples from the tundra.	Lisa Krebs-Barsis

Action Date

Action

Description

DEC Staff

2/2/1992

Site Added to Database

Former Staff

12/29/1992

Update or Other Action

All conditions of the COBC were met.

Mehrdad Nadem

7/1/1996

Update or Other Action

CH2M Hill prepared a remedial work plan titled Liquid-Phase Carbon Treatment at the Tuboscope Site. The treatment system was installed spring 1996. This report documents system installation and operational history.

Rich Sundet

9/19/2001

Update or Other Action

Lease Tract Landowner changed to ADNR Fairbanks. Staff conveyed status information to R.Daley of Firemans Fund (925-944-2856X313).

Bruce Wanstall

10/8/2003

Site Characterization Report Approved

Surface soil sampling conducted at the former footprint of the Tuboscope building found lead up to 14,900 mg/kg in surface soil

Bill O'Connell

10/7/2004

Update or Other Action

DEC received a copy of the work plan (Nanoscale Iron Treatment Pre-Test Assessment WP) for EPA approval which will facilitate selection of site environmental media for future potential nanoscale iron treatment bench-scale and pilot tests. This WP describes activities to be performed under BPXA's AOC.

Linda Nuechterlein

10/12/2004

Proposed Plan

EPA issued conditional approval for the Nanoscale Iron Treatment Pre-Test Assessment WP to be conducted under BPXA's AOC.

Linda Nuechterlein

10/14/2004

Update or Other Action

DEC received BPXA's 2004 Progress Report for the former Tuboscope site which was submitted to fulfill requirements of AOC, RCRA-10-99-0179.

Linda Nuechterlein

10/15/2005

Update or Other Action

Water Treatment System report dated 10/15/05 was received. BPXA is operating a treatment system as an interim measure to contain contamination related to this gravel pad. This report describes sampling, summary of system operations, and disposal activities associated with the treatment system.

Linda Nuechterlein

4/6/2006

Update or Other Action

Received Tuboscope Bimetallic Nanoscale Particle Technology Pilot Test Work Plan dated April 6, 2006. Two bimetallic nanoparticle reagent delivery methods will be evaluated for remedial effectiveness.

Linda Nuechterlein

8/27/2007

Update or Other Action

Received 2007 System Evaluation Site Assessment Work Plan dated August 27, 2007. This work plan will allow BPXA to evaluate the effectiveness of the remediation system operating at the site. Field work associated with this work plan is tentatively scheduled for the middle of September, 2007.

Linda Nuechterlein

10/16/2007

Site Characterization Report Approved

Received Tuboscope Water Treatment System Progress Report for 2007 Field Season. Six sampling events were conducted: the first to verify the treatment system was operating properly, the next five to verify that the treatment criteria were achieved prior to reinjection of treated water at Pad 3. All samples of treated water met the treatment criteria, resulting in the collection, treatment, and reinjection of over 90,000 gallons of water at the site. Surface water samples were collected from the drainage channel on three occasions, with one sample containing TCA above the treatment criteria at 0.128 mg/l.

Bill O'Connell

11/21/2007

Site Characterization Report Approved

Received the Preliminary Soil and Water Sampling Results, 1,4-dioxane Analysis for Tuboscope. 1,4-dioxane was found in soil at the shallow test plot up to 0.42 mg/kg and in pad pore water up to 0.566 mg/l. Surface water samples collected from the tundra northeast of the site also contained detectable concentrations of 1,4-dioxane. The extent of 1,4-dioxane in pad pore water was not delineated during this investigation. Additional investigation is anticipated for 2008.

Bill O'Connell

11/30/2007

Exposure Tracking Model Ranking

Initial ranking

Bill O'Connell

4/7/2008

Update or Other Action

Received 2007 System Evaluation Site Assessment Report. The system evaluation is conducted every 5 years to evaluate the effectiveness of the treatment system at reducing the areal extent of contamination at the site. Nine soil borings were drilled at the site and completed as monitoring wells. Soil, pore water, surface water and sediment samples were collected from the site. The highest concentrations of TCA were found within the footprint of the former building. 1,4-dioxane was also detected in soil and pore water. DRO and BTEX concentrations are also greatest within the footprint of the former building. Comparison of 2007 data to 2002 data shows a general decrease of TCA in soil and pore water at the site. The water treatment system as well as natural degradation have been effective at reducing the extent of chlorinated solvent impacts.

Bill O'Connell

11/21/2008

Document, Report, or Work plan Review - other

Received 2008 Tuboscope Water Treatment System Progress Report. Due to high water levels in the drainage channel, 63,000 gallons of melt water was pumped out and sent to Pad 3 for injection without sampling in May 2008. Afterwards, nine sampling events were conducted throughout the summer to verify the efficacy of the treatment system and to measure contaminant concentrations in the drainage channel. Of the four sampling events conducted in the drainage channel, 1,1,1-TCA was detected above the treatment criteria on 8/25/08 only. Lead, chloroethane, 1,1-DCA, and BTEX were each detected during at least one sampling event, but at concentrations below the treatment criteria. During the 8 sampling events at the system outlet, lead was detected during two events, and 1,1-DCA and 1,1,1-TCA were each detected during one event. During the treatment season approximately 132,000 gallons of water were treated and disposed of in the Pad 3 injection well.

Bill O'Connell

2/10/2009

Site Characterization Workplan Approved

ADEC has reviewed the RCRA Facility Investigation work plan for the former Tuboscope Site. The plan was prepared to meet the requirements of the EPA Administrative Order on Consent in place at the site. The objectives of the investigation are to evaluate the impacts of hydrogeology and human activities on contaminant migration and to delineate the on-pad and off-pad extent of impacts to soil, surface water and pore water. This plan contains details on Phase II sampling that will address data gaps from the Phase I sampling. Planned activities include: an inspection of the curtain liner surrounding the site that was installed in 1988, installation of soil borings and monitoring wells and the collection of surface water, sediment, pore water, surface soil, and subsurface soil samples. Off pad sampling will be conducted in winter 2009-10 due to tundra access restrictions.

Bill O'Connell

4/16/2009

Update or Other Action

Reviewed Interim Measures Work Plan Former Tuboscope Site. The objective of the interim measures is to "stabilize or otherwise control or minimize the subsurface movement of historically released chemicals to the off pad environment" Measures currently in place include the curtain liner around the site and the seasonal removal and treatment of potentially impacted surface water, however these measures did not target 1,4-dioxane, an emerging contaminant of concern that was found in soil and porewater at the site during recent investigations.. The interim measure workplan includes three phases, Evaluation and optimization of current measures, Data collection and treatability studies, and Implementation of the interim measures.

Bill O'Connell

11/5/2009

Document, Report, or Work plan Review - other

Reviewed Tuboscope Site Water Treatment System Progress Report for the 2009 Season. Pre-treatment activities included the removal and sampling of meltwater that had collected in the drainage channel so that the drainage channel would not overflow. Meltwater removal occurred on two occasions in May, with over 12,000 gallons removed during the first event and over 185,000 gallons removed during the second event. After sampling of the containerized water indicated contaminant concentrations were below treatment standards, the water was injected at the Pad 3 injection well. Seven sampling events were conducted at the site with various objectives. The objective of Event #1 was to verify the treatment system was working effectively before the water was transferred to the holding tank. Sample results indicated all contaminants were below treatment standards. Sampling events 2-7 were conducted to make sure treated water met standards as it exited the GAC system and to determine when the GAC needed to be changed. Sample results from these events indicated the GAC system was effective at removing contaminants, as no samples exceeded treatment standards. During sampling events 1 and 4, untreated water was sampled directly from the channel, and for the first time since 2002 when the sampling began, contaminants were not detected above treatment standards. Total volume of water treated in 2009 was over 112,000 gallons.

Bill O'Connell

3/16/2010

Document, Report, or Work plan Review - other

Reviewed work plan to investigate soils north of Tuboscope site prior to expansion of a secondary containment at the chemical storage area. Up to 9 boreholes will be sampled to 4 feet bgs to characterize soils for disposal or reuse.

Bill O'Connell

9/2/2010

Update or Other Action

Comments submitted by EPA to BPXA regarding the RCRA Facility Investigation Work Plan dated January 30th, 2009 (See Action dated 2/10/09).

Bill O'Connell

9/22/2010

Update or Other Action

Response to EPA comments on RCRA Facility Investigation work plan received from BPXA.

Bill O'Connell

10/27/2010

Document, Report, or Work plan Review - other

Reviewed Tuboscope Site Water Treatment System Progress Report. Approximately 119,784 gallons of water were treated with the GAC filter system and disposed on at the Pad 3 Class I UIC injection well. One pre-treatment sampling event was conducted in May 2010 followed by eight post treatment sampling events to gauge the effectiveness of the treatment system. Shortly after the May 2010 sample was collected from melt water in the drainage channel, high water levels necessitated the dewatering of the channel before analytical results were received. Approximately 121,800 gallon of melt water were collected followed by an additional 17,220 gallons of water collected after a rainfall event. This water was disposed of at the Pad 3 injection well with EPA approval, and the sample results indicated contaminant concentrations in the drainage channel water were below treatment standards. Sampling event #1 was conducted to verify the treatment system was operating before water was routed from the GAC system to the holding tank and sampling event #2-8 were conducted to insure the water had been treated prior to injection. Additional sampling was conducted in the drainage channel itself and also between GAC canisters to determine when the first canister needed replacing. Sampling indicated the GAC system was effective at removing contaminants, as no performance samples contained contaminants above treatment standards. Samples collected from the drainage channel on 4 occasions during the 2010 treatment season contained 1,1-DCA and 1,1,1-TCA up to 66.7 ug/l and 166 ug/l, respectively, above the respective treatment standards of 59 ug/l and 54 ug/l.

Bill O'Connell

10/24/2011

Document, Report, or Work plan Review - other

Reviewed 2011 Water Treatment System Progress Report for Tuboscope. Eight sampling events were conducted, one before the treatment system was activated for the season and seven during system operation. The pre-treatment sampling event did not indicate the presence of contaminants in water that had collected in the drainage channel, so the water (~25,000 gallons) was collected and disposed of at the Pad 3 injection well without treatment. Performance sampling conducted throughout the treatment season including the collection of samples from the drainage channel, system outlet, and between the two GAC canisters to monitor for breakthrough. Performance sampling indicated concentrations of 1,1,1-TCA had increased to a concentration above the treatment standard towards the end of the treatment season, but that the system was effective in removing chlorinated compounds from impacted surface water.

Bill O'Connell

2/21/2012

Document, Report, or Work plan Review - other

Reviewed the Work Plan Addendum-RCRA Facility Investigation for the former Tuboscope Site. The objective of the addendum is to outline the additional phases of work necessary to characterize the environmental conditions at the site and evaluate the nature and extent of all COPCs in all media to support development of corrective measures. This work includes expanding the investigation area both vertically and horizontally, expanding the hydrologic study area, evaluating background concentrations of metals in site media, performing habitat mapping, and investigating the impacts from the former mud plant at the site, the location of which may have been in error in the original RFI work plan. Samples collected during this phase will be analyzed only for the primary COPCs at each source area including 1,4-dioxane, 1,1,1-trichloroethane, and its breakdown products, DRO, barium, and select other compounds.

Bill O'Connell

5/4/2012

Document, Report, or Work plan Review - other

Reviewed Corrosion Inspection & Chemical Storage Facility Tanker Truck loading Area Pre Construction Site Investigation work plan for the Former Tuboscope Site. The work plan details activities to be conducted in an area north of the Former Tuboscope site to investigate the presence of contamination at an area where a secondary containment liner is planned for installation at a tanker truck loading area (TTLA). The investigation area is part of the planned RCRA Facility Investigation for this site, however due to the construction of the containment liner at the TTLA, the investigation at this area will be conducted sooner than the other RFI activities. 12 boreholes are planned with depths ranging from 3-7 feet bgs. Soil samples will be collected every foot from 1-3 feet bgs, then every other foot for deeper boreholes. Soil cores will be screened with a PID and where solvent contamination is suspected, soil will be screened using Color-Tec. Surface samples will be analyzed for VOCs, SVOCs, PAHs, and metals, deeper samples will be analyzed for metals and VOCs only. Soil samples will be submitted for TCLP analysis where appropriate. The objective of the investigation is to determine how much material is present that would be considered RCRA Hazardous Waste due to concentrations of a listed spent solvent to allow for better planning of the project

Bill O'Connell

6/22/2012

Document, Report, or Work plan Review - other

Date of Phase 2 RCRA Facility Investigation Work Plan Addendum.

Keather McLoone

8/21/2012

Document, Report, or Work plan Review - other

Reviewed Work Plan Addendum for TTLA. The design of the TTLA was reconfigured to minimize the generation of listed waste during construction, so additional investigation is necessary. 8 soil borings will be advanced and sampled in accordance with the May 2011 work plan to characterize areas in the new footprint of the TTLA.

Bill O'Connell

8/21/2012

Document, Report, or Work plan Review - other

Reviewed Phase II RFI Work Plan Addendum. The objectives if this investigation are to further characterize the environmental conditions at the site that may affect the fate and transport of contaminants and determine the nature and extent of contaminants associated with the former mud plant to support the development of potential corrective measures. Activities planned for 2012 include the placement of one additional thermistor string in a borehole within the drainage ditch adjacent to the site, replacement of one damaged thermistor string, installation of surface water elevation monitoring points and the deployment of transducers into off pad wells to monitor surface water elevations.

Bill O'Connell

8/21/2012

Document, Report, or Work plan Review - other

Reviewed Phase III RFI Work Plan. This work plan outlines the approach to evaluating existing data, filling data gaps, sampling water from wells and surface water sampling locations, and preparing the final RFI Report.

Bill O'Connell

8/30/2012

Update or Other Action

Date stamped on certified letter from EPA to BP regarding Contained-In Determination Request at Tanker Truck Loading Area.

Keather McLoone

9/11/2012

Document, Report, or Work plan Review - other

Reviewed RCRA Facility Investigation Interim Summary Report for Tuboscope. From 2008 to 2011 the following activities were conducted: advancement and sampling of 51 soil borings, thermistor installation in 11 borings, construction and sampling of 42 pore water monitoring wells, construction of 39 horizontal supra-permafrost GW monitoring wells, collection and analysis of pad gravel, tundra peat, and mineral soil samples, surface water sampling, vegetation survey, plant tissue sample collection and analysis, and an evaluation of the uptake of contaminants by plants through off-gas sampling. Contaminants of concern at the site include 1,1,1-TCA, 1,4-dioxane, DRO, lead, and contaminants associated with drilling mud. The results of the investigation indicate 1,4-dioxane is not present in soil at the site above proposed Tier I screening levels (SLs) or proposed Tier II action levels (ALs). SLs and ALs have not yet been finalized and a final comparison of the data to these levels will be conducting following their approval. TCA was not detected in soil above proposed SLs or ALs, except in one sample from the drainage ditch which had TCA above the SL but below the AL. Of the tundra and mineral soil samples analyzed for metals; arsenic, barium, cadmium, trivalent chromium, copper, nickel, selenium, and zinc were detected above SLs and ALs in numerous samples, but below the 90th percentile of proposed background concentrations. Additional site specific background study is recommended. 1,4-dioxane was detected in pore water above the AL at two sample locations and above the SL but below the AL in numerous off pad water samples. TCA and breakdown products are present in pad pore water above the ALs within the known contaminant plume. Of the water samples analyzed for metals, several samples contained lead above the SL but below the AL. Arsenic is also present in pore water above the AL, but this includes samples intended to represent background concentrations. Barium is present above the SL but below the Al in several samples. Background surface water samples contained arsenic and manganese above the SLs and ALs and background pore water samples contained arsenic, barium, and copper above the SLs and ALs. Additional evaluation of background concentrations is recommended. Data gaps identified for the RFI include the establishment of site specific background concentrations for several metals. Additional sample collection is planned for 2012 and an evaluation of the completeness of the RFI will be conducted once SLs and ALs are approved by EPA.

Bill O'Connell

9/19/2012

Update or Other Action

Date stamped on certified mail from EPA to BP regarding Tanker Truck Loading Area Project stating that EPA had no objection to the preconstruction investigation or construction activities as described in documents listed in this letter.

Keather McLoone

9/19/2012

Update or Other Action

Date stamped on letter from EPA to BP regarding hexavalent chromium aqueous sample preservation and holding time study.

Keather McLoone

9/20/2012

Update or Other Action

Date of letter from BP to EPA requesting a contained-out determination for water from TTLA construction activities with analytical data attached.

Keather McLoone

9/20/2012

Update or Other Action

Date of letter from BP to EPA requesting a reporting extension for 2012 Annual Interim Measure Water Treatment Progress Report.

Keather McLoone

9/21/2012

Update or Other Action

Date stamped on letter from EPA to BP regarding Contained-In Determination Request.

Keather McLoone

11/16/2012

Document, Report, or Work plan Review - other

Reviewed 2012 Field Season Water Treatment System Progress Report for Tuboscope. In addition to treating water removed from the drainage channel adjacent to the site, the treatment system also treated water removed during excavation activities at the newly constructed corrosion inspection and chemical storage facility tanker truck loading area. Modifications were made to the treatment system in 2012 to address issues identified during a hazard identification and risk review including automation of the shut down system, improvements in sediment filtration, and modification to the GAC adsorption unit. Water was sampled on 10 occasions during the treatment season including pre-treatment sampling of the water in the channel. Pretreatment samples did not contain concentrations of contaminants above treatment standards, therefore the melt water present in the channel was disposed of at the Pad 3 injection well. Sampling event 1 was conducted to verify the system was operating properly and events 2-9 were performed to verify treatment standards were met prior to disposal at the Pad 3 injection well. Contaminants of concern include lead, chloroethane, 1,1-dichloroethane, 1,1,1-trichloroethane and BTEX. Treatment standards were only exceeded in the drainage channel prior to treatment, only during the last sampling event, and only for 1,1,1-TCA. As in previous years the concentrations of contaminants increased in the channel throughout the summer. A total of 150,780 gallon of drainage channel water were treated by the system in 2012 and an additional 924 gallons were treated from the construction dewatering activities. All treated water was disposed of at the Pad 3 injection well.

Bill O'Connell

4/22/2013

Update or Other Action

Reviewed Final Former Tuboscope Site Interim Measures Water Treatment System Operations and Maintenance Manual. The treatment system was upgraded in 2012 to meet BP requirements and improve operational safety and efficiency. The general design of the system was not altered with a pump intake in the drainage channel that receives contaminated water, sediment filtration, three granular activated carbon vessels that operate in series, and temporary storage tanks to store treated water until disposal at the Pad 3 injection well.

Bill O'Connell

5/10/2013

Update or Other Action

Receipt of 7-day notification for 2013 calendar year field activities which will include the operation of the water treatment system. A workplan was to be submitted in late May or early June according to this letter.

Keather McLoone

5/10/2013

Update or Other Action

Date of letter from BP to EPA regarding Interim Measures during the 2013 field season - pre-treatment ditch de-watering.

Keather McLoone

7/11/2013

Update or Other Action

Date of Transmittal Letter from BP for three documents regarding TTLA.

Keather McLoone

7/29/2013

Document, Report, or Work plan Review - other

Date of receipt of the Materials Management and Excavation Report - Contruction Activities at the Tanker Truck Loading Area South of the Corrosion Inspection and Chemical Storage Facility. This area is in close proximity to the former Tuboscope building and borings were located within about 100 feet. The stockpile was field screened using a PID and determined to be suitable for reuse. Fuel impacts were noted near the bottom of a sump located in an area formerly occupied by a generator.

Keather McLoone

7/29/2013

Document, Report, or Work plan Review - other

Date of receipt of the Materials Management and Excavation Plan - Contruction Activities at the Tanker Truck Loading Area South of the Corrosion Inspection and Chemical Storage Facility. This plan states that a waste characterization sample may be collected from the stockpile, based on field screening results and gave a PID cutoff of 10 ppm using a 11.7 electron volt lamp.

Keather McLoone

7/29/2013

Document, Report, or Work plan Review - other

Date of receipt of Former Tuboscope Site Corrosion Inpsection and Chemical Storage Facility Tanker Truck Loading Area Pre-Construction Site Investigation Report dated October 22, 2012 covering work conducted in May and July 2012. The originally missing table section of this document was emailed and attached to the report.

Keather McLoone

9/5/2013

Document, Report, or Work plan Review - other

Date of receipt of Revised RCRA Facility Work Plan Addendum Amendment, Continuation of Hydrology Study Data Collection in 2013. Activities planned include maintenance of data loggers collecting temperature data as well as monitoring water levels and frost line elevations.

Keather McLoone

11/13/2013

Document, Report, or Work plan Review - other

Date of receipt of Water Treatment Progress Report for the 2013 Field Season. About 190,890 gallons of water were recovered and treated from the drainage channel adjacent to the former Tuboscope site. The treated water met criteria established by EPA for land disposal and was disposed of, early in the season, at the Pad 3 UIC Class I well and then later at the DS 4 G&I facility. GAC drums used in treatment were diposed of as haz waste. The untreated water from the drainage channel did not exceed criteria until the very end of July. This is similar to past years since 2007. Before 2007, treatment criteria were exceeded starting early June.

Keather McLoone

12/18/2013

Document, Report, or Work plan Review - other

Date of receipt of revised workplan based on EPA comment entitled RCRA Facility Investigation Work Plan Addendum Amendment - Continuation of Hydrology Study Data Collection in 2013 Version 4.

Keather McLoone

1/7/2014

Update or Other Action

Date of letter from BP regarding material excavated at the Tanker Truck Loading area.

Keather McLoone

3/27/2014

Update or Other Action

Date of letter regarding BPXA Tanker Truck Loading Area Construction Materials Management in response to ADEC letter dated 2/20/2014.

Keather McLoone

4/18/2014

Document, Report, or Work plan Review - other

Date of receipt of April 2014 revision of the document originally dated February 2013 entitled Materials Management and Excavation Report. The report was revised based on ADEC comment regarding section 4.1. More specifically, the report was revised to indicated that all excavated material that was not disposed of at the G&I facility was used as material for construction of the secondary containment.

Keather McLoone

5/7/2014

Update or Other Action

Date of receipt of 7-day notification prior to 2014 Field Activity. Field activities will include the operation of the water treatment system at the site. Additional activities are planned but are not finalized yet. A workplan will be submitted in late May or early June.

Keather McLoone

9/4/2014

Site Visit

Keather McLoone

9/19/2014

Update or Other Action

Date of receipt at EPA of letter requesting an extension for submittal of the 2014 Annual Interim Measure Water Treatment Progress Report.

Keather McLoone

10/24/2014

Document, Report, or Work plan Review - other

Date of report entitled 2013 Tuboscope RCRA Facility Investigation Interim Summary Report. The work described in this document was primarily related to the hydrology study. Activities included maintenance of temperature data loggers, manual gauging of water elevation and water column depth, and an inspection of all monitoring locations in order to either repair or note needed repair.

Keather McLoone

11/4/2014

Document, Report, or Work plan Review - other

Date of document entitled 2014 Interim Measures Water Treatment System Progress Report.

Keather McLoone

11/11/2014

Document, Report, or Work plan Review - other

Date of receipt of 2012 Interim Measuring System Evaluation Site Assessment and RCRA Facility Investigation Interim Summary Report Former Tuboscope Site.

Keather McLoone

11/17/2014

Document, Report, or Work plan Review - other

Date of receipt of 2012 Interim Measures System Evaluation Site Assessment and RCRA Facility Investigation Former Tuboscope Site. This document includes details about the Conceptual Site Model and Screening Evaluation for this site as well as a description of the 2012 Field Program which included both the System Evaluation Site Assessment (SESA) and the RCRA Facility Investigation (RFI). The RFI work included primarily data collected as part of the ongoing hydrology study and additional sampling to further delineate both soil and water impacts at the site. The focus of the discussion is often limited to select organic constituents although there are some additional organic and inorganic (metal) constituent that may warrant additional effort.

Keather McLoone

4/3/2015

Document, Report, or Work plan Review - other

Date of receipt of March 2015 version of Interim Measures Work Plan. ADEC previously received a February 2015 version as well as other earlier versions.

Keather McLoone

4/24/2015

Update or Other Action

Date of receipt of Request for Revised Contained-In Determination Criteria. The basis for the requested revisions to the CID criteria can be found in the attached Contained-In Determination Evaluation Report and Recommendation for Revisions.

Keather McLoone

5/19/2015

Document, Report, or Work plan Review - other

Date of receipt of May 2015 version of the Interim Measures Workplan

Keather McLoone

8/6/2015

Document, Report, or Work plan Review - other

Date of receipt of July version of Interim Measures Work Plan, Former Tuboscope Site.

Keather McLoone

10/6/2015

Document, Report, or Work plan Review - other

Date of receipt of Former Tuboscope Site, 2015 Interim Measures Operations Annual Progress Report.

Keather McLoone

3/25/2016

Document, Report, or Work plan Review - other

Date of receipt of draft 2015 Interim Measures Termination Pilot Study Report, dated July 2016. Site conditions were evaluated using a simulated termination scenario to determine if, or under what conditions, the water extraction and treatment system IM can be terminated. Activities mainly consisted of: monitoring thaw depth and elevation data; collecting water samples; surface water observations, and assessment of the geochemical conditions in the vicinity of the drainage ditch. ADEC submitted comments pertaining to the report on April 27, 2016 via letter.

Joshua Barsis

6/28/2016

Document, Report, or Work plan Review - other

Reviewed the Former Tuboscope Site 2016 Roadmap Report, dated June 2016. The report was intended to summarize the goals and expectations of the United States Environmental Protection Agency (USEPA), the Alaska Department of Environmental Conservation (ADEC), and BP Exploration (Alaska) Inc. (BPXA), and to facilitate the Resource Conservation and Recovery Act (RCRA) Corrective Action process.

Joshua Barsis

8/1/2016

Document, Report, or Work plan Review - other

Reviewed the Former Tuboscope Site 2016 Roadmap Report, dated June 2016, for the BPX Tuboscope, Inc. Lease Tract site. Submitted comments via letter back to RP on August 1, 2016.

Joshua Barsis

8/26/2016

Document, Report, or Work plan Review - other

Reviewed the 2016 Interim Measures Termination Pilot Study Work Plan, dated July 2016, for the BPX Tuboscope, Inc. Lease Tract site.

Joshua Barsis

9/7/2016

Document, Report, or Work plan Review - other

Date of ADEC approval of Final 2015 Interim Measures Termination Pilot Study Report, dated July 2016. See March 25, 2016 associated comment.

Joshua Barsis

11/14/2016

Document, Report, or Work plan Review - other

Reviewed the Former Tuboscope Site 2016 Interim Measures (IM) Operation Annual Progress Report, dated November 2016. Activities consisted of maintaining the water level within the drainage ditch at approximately the level of the surrounding pad pore-water to evaluate the potential rebound of chlorinated compounds if termination of the IM were to occur. Four sampling events were performed during the 2016 field season; the first was performed in May prior to dewatering, the second was performed in June in anticipation of extracting more snowmelt water from the drainage ditch, the third event was performed in July so water could be removed from the drainage ditch to keep the water level within the desired Pilot Study range, and the fourth was performed in September so the drainage ditch could be de-watered in preparation for freeze-up. All sample results were below the Contained-In Determination criteria for 1,1,1-TCA, 1,1-DCA, chloroethane, and 1,4-dioxane; and below the Toxicity Characteristic Concentrations listed for benzene and lead.

Joshua Barsis

1/9/2017

Update or Other Action

Date of document received from BPXA addressing ADEC's comment pertaining to CID criteria. A revised report is not expected.

Joshua Barsis

4/3/2017

Document, Report, or Work plan Review - other

Reviewed the Interim Measures Drainage Ditch Decommissioning Work Plan (2017-2018), dated March 2017. Proposed activities mainly consist of removing water from the drainage ditch, installing infiltration piping in the ditch, backfill the ditch, and performing post-backfilling groundwater and surface water monitoring. DEC requested minor edits and clarification in a final version of this work plan by June 1, 2017.

Joshua Barsis

4/26/2017

Document, Report, or Work plan Review - other

Reviewed the 2016 Interim Measures Termination Pilot Study Report, dated March 2017. The pilot study was completed to further evaluate whether the water extraction and treatment system IM could be terminated under current site conditions. Activities were completed between June and August and mainly consisted of maintaining a consistent water level in the drainage ditch, collecting elevation data, and collecting water samples from three monitoring wells (MW-19, MW-22, and MW-202) and six surface water locations (ST-42, ST-49, ST-50, ST-52, ST-53, and ST-73). The 2016 pilot study indicates that extraction and treatment of the drainage ditch water is no longer necessary.

Joshua Barsis

11/28/2017

Document, Report, or Work plan Review - other

Reviewed the final 2016 Interim Measures Termination Pilot Study Report, dated October 2017. This report was submitted in response to DECs comments on the draft report, dated March 2017. ADEC does not have additional comments on the report and concurs with the recommendation to backfill the drainage ditch.

Joshua Barsis

12/27/2017

Document, Report, or Work plan Review - other

Received final version of the Interim Measures Drainage Ditch Decommissioning Work Plan, dated December 14, 2017.

Joshua Barsis

12/28/2017

Document, Report, or Work plan Review - other

Reviewed the 2017 Interim Measures Annual Operations Progress Report, dated November 2017. This report details the interim measures (IM) activities completed during the 2017 field season. Activities generally consisted of drainage ditch water extraction and surface water sampling. All surface water sample results were below the specified criteria.

Joshua Barsis

9/18/2018

Update or Other Action

Sent letter on this day requesting evaluation of PFAS at this site. See file for more info.

Joshua Barsis

4/16/2019

Document, Report, or Work plan Review - other

Reviewed the 2018 Interim Measures Annual Operations and Drainage Ditch Decommissioning Report, dated March 15 2019. This report details the final ditch dewatering activities, as well as the backfilling and sampling effort completed during the 2018 field season. The drainage ditch water was dewatered 20 times between May and July 2018, and before backfilling activities begun. Four surface water sampling events were completed during this time; on May 13th, June 4th, July 15th, and on July 28th. A second surface water sample was collected on July 28th from water that was infiltrating a small excavation on the northeastern end of the drainage ditch completed form conveyance piping. Diesel impacts were noted in the infiltration water, which is what prompted the sampling. All results for all five surface water sampling events were below 2015 contained-in determination (CID) levels, as well as other applicable criteria. All extracted water was disposed of at the Pad 3 injection well. The drainage ditch was backfilled over the course of July and September 2018. Soil samples were collected from the base of the drainage ditch (between 0 and 2 feet bgs) as well from just below the base of the drainage ditch (2 to 3 feet bgs). All samples were submitted for analysis of 1,4-dioxane, VOCs, SVOCs, PAHs, metals, mercury, chromium IV, and DRO. Unfortunately, the sample container used to collect VOCs were inadequate and allowed them to thaw prior to arriving at the laboratory. For this reason, three soil borings were advanced after the drainage ditch was backfilled in order to collect the VOC samples again. Monitoring well MW-22 and Thermistor String T-63R were decommissioned during backfill activities. Additional water was extracted from the ditch as need to prevent overflowing. Following completion of backfilling activities, Well MW-22 was reinstalled. Thermistor T-63R is planned to be replaced in 2019. Analytical results revealed various contaminants remain in the subsurface soils at or below the base of the drainage ditch; up to 3 mg/kg 1,4-dioxane, 6.4 mg/kg naphthalene, 15.4 mg/kg ethylbenzene, 90.7 mg/kg xylenes, 254 mg/kg lead, and 472 mg/kg barium. ADEC sent a letter on this day requesting some additional information/changes in a revised report.

Joshua Barsis

6/28/2022

Site Characterization Report Approved

A comprehensive report for activities between 2008 and 2018 was approved. There were 72 surface water samples and 41 suprapermafrost monitoring wells samples collected. Over 90 soil samples were collected from the mineral soil, 33 samples from the pad, and 106 samples from the tundra.

Lisa Krebs-Barsis

Contaminant Information

Name

Level Description

Media

Comments

Control Type

Type

Details

Requirements

Description

Details

Investigation Report 2008-2018 Combined Tables.

Investigation Report 2008-2018 Summary Figures

Tuboscope Comprehensive Report

No associated sites were found.

Missing Location Data

Because the GIS location data for this site has not been entered, we cannot direct you to its position on the map. Click "Continue" to proceed to the Contaminated Sites Web Map or "Close" to return to the site report.

Continue Close

Site Report: Hilcorp NS Tuboscope, Inc. Lease Tract (BPX)

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

Investigation Report 2008-2018 Combined Tables.

Investigation Report 2008-2018 Summary Figures

Tuboscope Comprehensive Report

Missing Location Data

State of Alaska Department of Environmental Conservation