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Site Report: Trading Bay Facility

Site Name: Trading Bay Facility
Address: West Foreland, Cook Inlet; SW of Tyonek, Tyonek, AK 99682
File Number: 2337.38.007
Hazard ID: 1263
Status: Active
Staff: Peter Campbell, 9072623412 peter.campbell@alaska.gov
Latitude: 60.816399
Longitude: -151.788337
Horizontal Datum:NAD83

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

Problems/Comments

This is a site that has contamination extending from the ground surface to the water table in most areas in the facility due to past work practices. Petroleum contamination has migrated via the groundwater to the adjacent beach. Trading Bay Production Facility (TBPF) is an onshore crude oil and natural gas processing facility on the west side of Cook Inlet. Crude oil and natural gas is transported to TBPF via pipelines from off shore platforms in Cook Inlet. Crude oil is processed at TBPF then piped to the Drift River facility about 20 miles away. Marathon and Unocal has conducted several site assessments to determine the vertical and horizontal extent of contamination. FY 92 actions: Marathon conducted two extensive site assessments to further determine the extent of contamination at the facility. They also underwent extensive pipe and tank testing to eliminate all sources of contamination. Several tanks were cleaned out and repaired. A Compliance Order by Consent (COBC) was signed in 1996 between Unocal, Marathon and ADEC which required Unocal and Marathon to perform further monitoring/assessment/cleanup of the site. Later in 1996, Forcenergy bought Marathon's interest in TBPF. Cleanup and monitoring is on-going. LC listed is 14884660. The site includes a number of spills that were reported to DEC in 1991. The site also includes a petroleum spill under Tank #5 that was reported to the Prevention and Emergency Response Program (PERP) in 7/5/2003; PERP as Spill Number 03239918601.

Action Information

Action Date Action Description DEC Staff
2/22/1991 Update or Other Action Marathon reports multiple spills of various types of contaminants have occurred at the TBPF since it started that has contaminated the soil and groundwater. Bryson Twidwell
6/20/1991 Update or Other Action ADEC receives a fax from Marathon attaching a QA plan for sampling of groundwater in the six 8 inch recovery wells. Bryson Twidwell
7/2/1991 Update or Other Action On 7/2/1991, KDO received a report "Trading Bay Production Facility Environmental Assessment Report" dated June 1991 by Marathon Oil. Bryson Twidwell
7/17/1991 Update or Other Action ADEC received a letter from Marathon regarding Corrective Action Plans for TBPF Spills. Bryson Twidwell
7/19/1991 Update or Other Action Svend Brant-Ericksen issues a letter to Marathon thanking them for their June 14 and July 8, 1991 schedule and briefing to perform proposed assessment and cleanup at TBPF. The ADEC letter also informed Marathon of the oil spill regulations and prefers to enter into a COBC to address the cleanup. The letter also informed Marathon of DEC's obligations to recover its expenses. Bryson Twidwell
7/19/1991 Update or Other Action ADEC received a letter from Marathon regarding monitoring well installations. Included are reports: "Site Specific Quality Assurance Program Plan," "Work Plan, Monitoring Well Installation," and "Work Plan, Gluteraldehyde Contamination Monitoring." Bryson Twidwell
7/19/1991 Update or Other Action On 7/19/91, KDO received a plan "Site-Specific Quality Assurance Program Plan Trading Bay Production Facility Alaska" by James Montgomery on behalf of Marathon dated July 1991. Bryson Twidwell
7/25/1991 Update or Other Action ADEC informed Marathon that its POC for COBC issues would be Ron Klein. Bryson Twidwell
8/9/1991 Update or Other Action ADEC provides comments to Marathon on the following Marathon documents: "Proposal, Risk Assessment for Petrolite XC-107 Spill TBPF" dated July 16, 1991; "Work Plan, Underground Storage Tank Site Assessment TBPF" dated 8/1/1991; "Work Plan, gluteraldehyde Contamination Monitoring TBPF" dated 7/17/1991; "Work Plan Monitoring Well Installation TBPF" dated 7/17/1991; and, "Site-Specific QA Program Plan TBPF" dated 7/17/1991. Bryson Twidwell
11/6/1991 Update or Other Action Marathon provided its report "Trading Bay Production Facility Monitoring Well Installation and Sampling Volume 1 and 2: Soil Analytical Data" dated 11/6/91 to DEC. Bryson Twidwell
11/7/1991 Update or Other Action Marathon submitted to DEC a risk assessment report dated 11/7/91 by Dames and Moore titled "Risk Assessment for Petrolite XC-107 Spill 11/7/91 Report and 6/7/91 Proposal (for the risk assessment)." Included in the report were the following Harding Lawson reports: Nalco 970 Inhibitor Site Soil Sampling/Analytical Results 11/7/91; Corrective Action Plan Inhibitor Tank Spill dated 7/31/91; and Solar Building Spill Soil Sampling/Analytical Results dated 11/7/91; and Solar Building Spill Corrective Action Plan dated 7/12/91. Bryson Twidwell
3/6/1992 Update or Other Action On 3/6/92, KDO received a report by James Montgomery titled "Work Plan for Remedial Investigation at the Trading Bay Production Facility Final" on behalf of Marathon Oil dated February 1992. Bryson Twidwell
6/2/1992 Update or Other Action In response to Marathon's document "Product Recovery Planning, Status Report" dated 1/9/1992, ADEC approves of Marathon's request to defer the design or construction work for a total fluids treatment system until the remedial investigations planned for 1992 and 1993 at TBPF is completed. The deferral was granted because of lack of knowledge of the vertical and horizontal extent of contamination. Bryson Twidwell
6/2/1992 Update or Other Action ADEC provided comments on Marathon's work plan "Work Plan for Remedial Investigation" prepared by James Montgomery dated February 1992, which was received by ADEC on 3/6/1992. Bryson Twidwell
1/13/1993 Site Added to Database Extensive petroleum contamination. Former Staff
6/9/1993 Site Ranked Using the AHRM Site re-ranked. SW Exposure Index Value changed to 0. Former Staff
6/15/1993 Update or Other Action On 6/15/1993, ADEC provided comments to Marathon regarding their work plan "Phase I Data Summary Report and Work Plan Addendum Number 2 TBPF" dated 4/2/1993. Bryson Twidwell
7/14/1993 Update or Other Action On 7/14/93, KDO received the report "Marathon Oil Company Trading Bay Production Facility Phase I Data Summary Report and Work Plan Addendum No. 2" dated 3/12/93 with its cover letter from Bruce Cox to Dan Brewster dated 7/8/93. The cover letter noted that the work plan addendum for the 1992 work performed by James Montgomery and the report of that work at the request of Twidwell. The cover letter also noted that Montgomery completed their 1993 work in June and expected a report no later than 4/1/94. Bryson Twidwell
7/15/1993 Update or Other Action (Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). The report was a summary of several previous assessments which were conducted yearly since July 1991. The site assessment disclosed several additional problem areas. I sent a reply letter on July 15, 1993 requesting additional site assessment in several areas and remediation of area A which is an old burial site on the south-west side of the facility. Former Staff
8/13/1993 Update or Other Action On 8/13/1993, ADEC provided comments regarding Marathon's 8/11/1993 proposal to place excavated contaminated soil back into the excavation in lieu of stockpiling the contaminated soil and placing clean fill into the excavation. Bryson Twidwell
12/24/1993 Site Ranked Using the AHRM Surface Water Environments and Recreation Area values changed from site managers submitted form. Former Staff
6/1/1994 Update or Other Action Marathon submitted to DEC its report "Trading Bay Production Facility Remedial Investigation Volume I Final Report and Volume II Appendices." Bryson Twidwell
8/18/1994 Meeting or Teleconference Held DEC staff, Daniel Brewster of the AGs office met with Marathon and Unocal and their consultants to discuss remedial investigations at Trading Bay Production Facility and future actions. At the meeting, Marathon provided copies of their report "Project Update: Trading Bay Production Facility 1992 - 1993 Remedial Investigations and Future Long-term Remediation Efforts. Confidential Settlement Document" dated 8/18/94. Bryson Twidwell
10/3/1994 Preliminary Assessment Approved (Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). On 10/3/1994, ADEC provided comments and concerns to Marathon regarding their "Trading Bay Production Facility Remedial Investigation Report" prepared by Montgomery Watson dated June 1994, which was received by ADEC on 7/5/1994. Additional information and additional site assessment information was requested. Former Staff
10/20/1994 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Contaminated soils will be shipped to Anchorage CleanSoils and remediated during the upcoming month. Former Staff
10/28/1994 Update or Other Action On 10/28/94, KDO received a plan "Operations Plan Product Recovery System Installation and Remediation Testing Trading Bay Production Facility" and its accompanying health safety plan by Bristol Environmental Services on behalf of Marathon dated October 1994. Bryson Twidwell
11/22/1994 Update or Other Action On 11/22/1994, ADEC provided comments to the Marathon document "Human Health and Ecological Risk Assessment for TBPF" prepared by Tetra Tech Inc. dated 10/21/1994, which was received by ADEC on 10/25/1994. The letter also included comments by DEC's term contractor E&E who reviewed the document. Bryson Twidwell
11/23/1994 Meeting or Teleconference Held On 11/23/1994, ADEC staff met with representatives of Marathon to discuss the risk assessment report that was submitted by Marathon. Bryson Twidwell
11/28/1994 Update or Other Action On 11/28/1994, ADEC issued a letter to Marathon on issues raised at the 11/23/1994 meeting regarding the risk assessment. Bryson Twidwell
12/1/1994 Update or Other Action On 12/1/1994, ADEC approved of Marathon's plan "Product Recovery Installation and Remediation Testing Work Plan Review" prepared by Bristol Environmental Services Corp. dated 10/24/1994, which was received by ADEC on 10/28/1994. Bryson Twidwell
4/4/1995 Update or Other Action On 4/4/1995, ADEC approved of the 10/15/1994 "TBPF Human Health and Ecological Risk Assessment: Description of Methods and Approach" with the understanding that revisions will be made to the plan as identified in Unocal's 12/18/1994 letter (Beitia to Twidwell). Paul Horwath
8/25/1995 Update or Other Action On 8/25/1995, ADEC issued a letter of non-objection to Unocal's plan for trenching to install piping for a new water treatment system as described in the document "Trading Bay Production Facility Construction Project." Bob Krogseng
1/31/1996 Update or Other Action On 1/31/1996, DOL provided Unocal's legal counsel a copy of a draft COBC for review. Bob Krogseng
2/15/1996 Risk Assessment Report Approved On 2/15/1996, ADEC approved of Unocal's "Trading Bay Production Facility Human Health and Ecological Risk Assessment (and its Appendices)" that was prepared by Tetra Tech dated 7/10/1995 and received at ADEC on 7/17/1995. The letter noted that the risk assessment was approved provided that modification would be made to the risk assessment that revised or addressed several areas. ADEC noted that this could be addressed in an addendum to the report. On 3/5/1996, Unocal provided a response to DEC's comments. Bob Krogseng
3/21/1996 Update or Other Action On 3/21/1996, ADEC notified Unocal that it was beginning cost recovery proceedings for its time regarding TBPF. Bob Krogseng
3/22/1996 Update or Other Action On 3/22/1996, DOL responded to Susan Reeves' letter (legal counsel for Unocal) on that date regarding past history of the site and her comments on the draft COBC. Bob Krogseng
4/9/1996 Update or Other Action On 4/9/1996, DOL provided Reeves with a redlined draft of the COBC changes. Bob Krogseng
4/12/1996 Update or Other Action On 4/12/1996, DOL thanked Reeves for her submittal of 4/10 (Unocal letter dated 4/10/1996) that outlined past spills at TBPF. Bob Krogseng
6/14/1996 Update or Other Action On 6/14/1996, DOL responded to Unocal's letter and draft COBC of 6/11/1996, which Unocal had provided comments. Bob Krogseng
6/18/1996 Update or Other Action On 6/18/1996, DOL informed and included a printout of costs to be reimbursed under Paragraph 55 of the proposed COBC. Costs included for DOL and most of DEC's costs for a total of $91,383.36. Bob Krogseng
6/21/1996 Update or Other Action On 6/21/1996, the COBC (version 6/21/1996) was signed by ADEC and submitted to Marathon and Unocal for signatures. On 7/12 and 7/18/1996, representatives of Union Oil Co. of Calif. and Marathon Oil Co. signed the COBC, respectively. Bob Krogseng
7/17/1996 Cleanup Plan Approved (Old R:Base Action Code = RAPA - Remedial Action Plan Approval). Remedial Action Workplan (Phase 1, Air Sparging) reviewed and approved. Bob Krogseng
7/17/1996 Update or Other Action On 7/17/1996, ADEC approved of Unocal's plan "Phase I Air Sparging and Monitoring Work Plan" that was prepared by Geosphere Inc. and received by ADEC on 7/1/1996. The plan called for installing two Phase I air sparging systems at TBPF. Bob Krogseng
8/8/1996 Update or Other Action On 8/8/1996, ADEC issued a letter of non-objection to Unocal's 8/6/1996 letter that outlined revisions to its "Phase I Air Sparging and Monitoring Work Plan." ADEC requested that an operations plan be submitted by 10/1/1996 along with an as-built. The ADEC also notified Unocal that it expected that additional Phase I groundwater cleanup at the source areas and the bluff be addressed when the Facility Groundwater Monitoring Plan is submitted on 10/1/1996. Bob Krogseng
9/6/1996 Update or Other Action On August 23, 1996, ADEC received the document "Trading Bay Production Facility Application for Wastewater Disposal Permit" to dispose of landfill leachate and monitoring well purge water. On September 6, 1996, ADEC notified Unocal that it did not object to the proposal under General Permit 9440-DB006 onsite, which permit is valid until 1999. ADEC requested Unocal to notify ADEC each year prior to operating, and provide at the end of each year a short summary of the amounts disposed of and the results of the testing. Bob Krogseng
9/6/1996 Update or Other Action On 9/6/1996, ADEC issued a letter of non-objection to Unocal's plan to dispose of treated landfill leachate and monitoring well purge water per the proposal "Trading Bay Production Facility Application for Wastewater Disposal Permit" that was received on 8/23/1996. ADEC informed Unocal that the General Permit was valid until 1999. ADEC also requested it be informed each year prior to operation and a summary report at the end of the year(s). Bob Krogseng
10/26/1996 Meeting or Teleconference Held Unocal reported to SPAR staff regarding a spill that is not where the COBC addresses which is along a pipeline within the facility owned by CIPL. Spill handled by PERP. Rich Sundet
12/11/1996 Meeting or Teleconference Held On 12/11/96, Krogseng and Sundet attended a meeting at Unocal for their semi-annual meeting regarding the cleanup at TBPF. Also attending were Todd McGovern of Unocal, and representatives from Marathon, Geosphere and OilRisk Consultants. At the meeting, Unocal requested a waiver be given or the COBC be revised to delete the top bluff compliance line and 1.3 mg/l compliance level at the bluff top for benzene. Bob Krogseng
12/17/1996 Update or Other Action In follow-up to the 12/11/96 meeting, Unocal requested the elimination of the bluff top compliance line referred to in Section 15 of the COBC based upon the assessment and remediation work conducted after the COBC was signed. The letter noted that recent information had been submitted to ADEC in Unocal's "Phase I Air Sparging System Startup and Initial Monitoring Report, November 1996" by Geosphere and that the current monitoring program is defined in Unocal's "Groundwater Monitoring Plan, September 1996." Bob Krogseng
12/30/1996 Update or Other Action On 12/30/1996, ADEC informed Marathon that while it sold its interest in the TBPF, that Marathon's obligations under the COBC are not extinguished by the transfer, but Marathon's successor becomes an additional obligor under Paragraph 38 of the COBC. Marathon had sold its interest to Forcenergy. Bob Krogseng
1/22/1997 Update or Other Action On 1/22/97, CSRP informed Unocal that it owed ADEC $686.09 for oversight costs for the time period 10/1/96 - 12/15/96, and requested payment by 3/7/97. Bob Krogseng
2/5/1997 Meeting or Teleconference Held On 2/5/97, Sundet and Krogseng attended a meeting at Unocal regarding the concept of a work plan to be submitted by 4/1/97 to further address the contamination at TBPF. Also attending was Todd McGovern of Unocal and Marcus Allen of Marathon and Unocal's consultant David Brailey. Bob Krogseng
2/5/1997 Update or Other Action The COBC was modified to remove the east property boundary bluff top groundwater cleanup level. The beach seep cleanup level is to remain the same. Bob Krogseng
3/4/1997 Update or Other Action On 3/4/97, ADEC approved of Unocal's request to modify the COBC based upon its review of the "Phase I..." report by Geosphere, information presented by Unocal in the 12/11/01 meeting, and past information. ADEC agreed to make the following modification to the COBC that the top bluff groundwater cleanup level, e.g., 1.3 ug/l benzene, defined for the east property boundary sentry wells be eliminated from Section 15 of the COBC, but that the beach seep cleanup levels at the east property boundary remain the same. ADEC requested Marathon, Unocal and Forcenery sign and return to ADEC the letter that would bind them to this modification. The returned letter was signed by Union Oil Company on 3/10/97 and by Forcenergy on 4/2/97. Marathon later in a letter dated 6/3/97, signed (along with Forcenergy) that both companies agree that Forcenergy will work with the operator Unocal to carry out the agreements in the COBC. Therefore, Marathon's signature to the modification was not required. Bob Krogseng
4/10/1997 Update or Other Action On 4/10/97, ADEC followed up to its 3/4//97 letter that requested the three parties to sign the modification to the COBC. The 4/10 response was also in response to Marathon's 3/25/97 facsimile that informed ADEC that Marathon sold its interest in TBPF to Forcenergy and questioned the appropriateness of Marathon to sign the modification. The 4/10/97 letter informed Marathon that while Marathon is no longer the primary obligator, it was still obligated under the COBC and Marathon is in the position of a guarantor. The 4/10 letter informed Marathon that it could either sign off on the changes to the COBC or provide written delegation that authorizes the new owner (Forcenergy) to modify the COBC on Marathon's behalf and bind Marathon to any changes. Bob Krogseng
5/7/1997 Update or Other Action On 5/7/97, CSRP informed Unocal that it owed ADEC $834.75 for oversight costs for the time period 12/16/96 - 3/15/97, and requested payment by 6/24/97. Bob Krogseng
5/30/1997 Cleanup Plan Approved On 5/30/97, ADEC approved of Unocal's "Phase II Environmental Work Plan" that was prepared by Oil Risk Consultants dated 4/1/97. ADEC noted that the recoverable oil is only a small fraction of the total oil in the subsurface and removal of this fraction will not appreciably reduce dissolved benzene concentrations. However, ADEC requested that Unocal continue to monitor the free product levels in the recovery wells and after 6 months, ADEC will reevaluate the requirement to continue free product recovery. The 5/30th letter also approved to the substitution of additional work to confirm that the NAPL layer is not migrating and to long term monitoring to be performed to measure the rates of benzene and total hydrocarbon degradation in the NAPL layer, and concurred with the proposed beach sand prism monitoring. Bob Krogseng
6/3/1997 Update or Other Action In a letter dated 6/3/97, Marathon provided ADEC a letter signed by Marathon (6/3/97) and Forcenergy (6/4/97) that both companies agree that Forcenergy will work with the operator Unocal to carry out the agreements in the COBC. Bob Krogseng
9/4/1997 Update or Other Action ADEC approved of Unocal's August 1997 request to dispose of treated leachate and monitoring well purge water from Kustatan Ridge and TBPF landfills onto TBPF property under General Permit 9440-DB006. Bob Krogseng
1/28/1998 Meeting or Teleconference Held On 1/28/98, the semi-annual meeting required under the COBC occurred at Unocal. Attending was Krogseng and Sundet for DEC, John Betia of Unocal and his consultants Larry Acomb and David Brailey (OilRisk Consultants). Discussion focused on findings from 1998 compared to past years. Bob Krogseng
4/23/1998 Update or Other Action On 4/23/98, CSRP informed Unocal that it owed ADEC $613.44 for oversight costs for the time period 9/16/97 - 3/31/98, and requested payment by 6/6/98. Bob Krogseng
12/21/1998 Update or Other Action CSRP received the annual report for the 1998 groundwater monitoring at Trading Bay. The report was dated 12/98 and the cover letter from Unocal dated 12/17/98. Rich Sundet
10/15/1999 Update or Other Action Based upon its review of the September 23, 1999 "Notice of Disposal of Discharge" of landfill leachate at the Trading Bay Production facility and supplemental analytical data received on October 8, 1999, ADEC granted Unocal permission to dispose of treated leachate from the Kustatan and TBPF landfills at TBPF. The "Notice of Disposal" was submitted in accordance with ADEC Wastewater General Permit Number 9640-DB001. The wastewater will be treated by air sparging prior to discharge and the discharge will be to the ground surface within the limits of an existing hydrocarbon plume at the facility. ADEC requested that at the end of each year to provide a summary of the amount disposed of and the results of any testing. Jeff Ginalias
9/27/2000 Update or Other Action Based upon its review of 9/26/00 OilRisk Consultant's request that included analytical data, CSRP approved of the request to dispose of about 2,000 gallons of treated landfill leachate under DEC's General Wastewater Permit Number 9640-DB001 (which would expire on 1/1/02) that was generated from the Trading Bay and Kustatan landfills, and monitoring well purge water from TBPF. The leachate was collected on 8/25 - 27/00 and treated by air sparging. The approval was based upon that Unocal perform the discharge under the General Permit conditions. ADEC also requested that at the end of each year to provide a summary of the amount disposed of and the results of any testing. Rich Sundet
1/3/2001 Update or Other Action In a letter dated 1/3/01, in accordance to paragraph 46 of the COBC, Unocal informed ADEC that its representative is John Hammelman who replaced John Beitia. Rich Sundet
5/3/2001 Update or Other Action On 5/3/01, ADEC received Unocal's report "2000 Groundwater Monitoring for TBPF - COBC" dated 4/27/01. The report showed that NAPL was still present and the cover letter noted that monitoring and the operation of the air sparging would continue. Rich Sundet
12/27/2001 Update or Other Action The A.G.'s Office informed ADEC in a letter dated 12/27/01 that it received a check for $654.03 from Unocal dated12/26/01 for costs incurred by ADEC for oversight work. Rich Sundet
5/2/2002 Meeting or Teleconference Held Sundet met with John Hammelman and his consultant Larry Acomb to discuss a proposal by Unocal to replace the existing sparge system with a sparge trench system. Unocal will be submitting a formal proposal later. The work is proposed to begin in summer 2002. Rich Sundet
7/2/2002 Update or Other Action On 7/2/02 via email, CSP approved the work plan "Air Sparging Trench Design Basis Report and Installation Work Plan Trading Bay Production Facility" dated May 2002 that was prepared by Unocal's consultant Geosphere, INC. The plan was received by CSP on May 28, 2002. The letter noted that per previous discussion between Sundet and Hammelman, this email acts as CSP's approval of the subject work plan. The approval also noted that the monitoring points and the cleanup levels remain the same as stated in the COBC, as well as the reporting schedule. Lastly, the letter requested that Unocal ensure that all necessary permits are obtained prior to performing the work. Rich Sundet
7/31/2002 Update or Other Action On 7/31/02, John Hammelman of Unocal informed CS via email that Unocal elected to postpone installing the air sparging trench until next year. Rich Sundet
9/5/2002 Update or Other Action On 9/5/02, CS received Unocal's document titled "2001 Groundwater Monitoring for Trading Bay Production Facility - COBC No. 91-23-01-053-02" dated 9/3/02. Rich Sundet
10/8/2002 Update or Other Action The A.G.'s Office informed ADEC in a letter dated 10/8/02 that it received a check for $425.28 from Unocal dated 10/01/02 for costs incurred by ADEC for oversight work at Trading Bay and the Swanson River field. Of that money, $279.99 was due to CS oversight for the Trading Bay facility between 5/1 and 6/30/02.. Rich Sundet
8/6/2003 Meeting or Teleconference Held Sundet and Ted Moore of IPP met w/Bob Shipley of Unocal to discuss the petroleum spill discovered when they removed tank #4 in their tank farm in winter 2003. PERP had assigned the spill as spill number is 03239918601. Rich Sundet
8/14/2003 Meeting or Teleconference Held Sundet and Kirsten Balland of IPP met w/Bob Shipley of Unocal and their consultant Dave Brailey to discuss the petroleum spill discovered when they removed tank #4 in their tank farm in winter 2003. PERP had assigned the spill as spill number is 03239918601. At the meeting, Unocal provided a document by OilRisk Consultants titled "Soil Analysis Results, Tank 4 & 5 Geotechnical Borings Trading Bay Production Facility" dated August 2003. Unocal proposed that they would submit a workplan to DEC stating that they would excavate the upper 2 ft. of contamination and temporarily stockpile it on site, and later in fall 03 propose to landfarm the soil at one of two proposed locations onsite. Concurrently, Unocal would propose to install a replacement tank to replace tank #4. Rich Sundet
8/21/2003 Update or Other Action On 8/21/03, CSP approved the plan titled “Workplan for Soil Excavation Beneath Tank 4” by OilRisk Consultants dated 8/15/03. This spill was assigned by PERP as Spill Number 03239918601. The approval also was in follow-up to DEC's meeting on August 14 and OilRisk Consultants subject workplan. As noted during the meeting and prior conversations, crude oil contamination was discovered by Unocal when Tanks 4 and 5 were dismantled at the Trading Bay Production Facility. The letter also noted that Unocal provided CSP the Unocal spill report that noted that oil was discovered beneath Tank 4 on July 5, 2003. The report titled “Soil Analysis Results, Tank 4 and 5 Geotechnical Borings Trading Bay Production Facility” by OilRisk Consultants dated August 2003 was submitted to the Department at the August 14th meeting. The report provides information regarding the contamination under those tanks, up to 11,000 mg/kg DRO and 9,800 mg/kg RRO. BTEX also was detected with benzene up to 29 mg/kg. During the meeting, Unocal proposed to remove some of the highly contaminated soil from the surface and temporarily stockpile it on site, and that later under submittal of a separate plan request that this soil and soil stockpiled on site from previous spills of crude oil be landfarmed on site. Unocal also proposed to install a replacement tank in the general vicinity of Tank 4. The August 15 workplan proposes to remove about 50 cubic yards of contaminated soil from the footprint of Tank 4 and stockpile it on site in accordance to 18 AAC 75.370. The plan also notes that calculations show that the oil is immobile as a liquid phase and that the contamination is part of an existing groundwater plume that is intercepted by a downgradient air sparging system along the beach. In addition, the plan notes that as long as the facility remains operational, the remaining contamination will pose no significant human health or ecological risk. As noted during our August 14th meeting, Unocal will address the remaining soil contamination when the facility begins to close operations. The approval letter also noted that a separate plan will need to be provided to the CSP for the discussed landfarming of excavated contaminated soil. Rich Sundet
9/12/2003 Update or Other Action On 9/12/03, CSP received the Groundwater Monitoring report for the Trading Bay facility for 2002. The report shows that routine groundwater monitoring and air sparging is continuing. The report also shows that NAPL thickness remains stable and that groundwater contaminant levels are below risk based cleanup levels established in the 1996 COBC. Rich Sundet
10/24/2003 Update or Other Action In a letter dated 10/21/03, UNOCAL notified Sundet of DEC and Kennedy of the A.Gs. Office that in accordance to the COBC that the new Unocal contact is Robert Shipley replacing John Hammelman and the new UNOCAL address is Unocal Alaska; 909 W. 9th Ave.; P.O. Box 196247; Anchorage, AK 99519. Rich Sundet
3/25/2004 Update or Other Action On 3/25/04, DEC received Unocal's report "2003 Groundwater Monitoring for Trading Bay Production Facility -COBC No. 91-23-01-053-02.The document reported routine groundwater monitoring findings. Rich Sundet
3/26/2004 Update or Other Action File number assigned and entered into the Fileroom DB and CS DB. Alyce Hughey
4/26/2005 Update or Other Action Reviewed 2004 Groundwater Monitoring Report; COBC # 91-23-01-053-02; little or no changes to risk to human health and the environment. Donald Seagren
8/18/2005 Update or Other Action Reviewed and commented on GW monitoring plan for the Airstrip Landfill. This site was permitted by the SW program. It is now in post-closure monitoring. Comments were provided to the SW program for their consideration. Donald Seagren
10/19/2005 GIS Position Updated Using Figure 1-2 from a Work Plan for Remedial Investigation at the Trading Bay Production Facility, from James M. Montgomery, dated February 1992, in conjunction with TopoZone Pro and the KPB Parcel Lookup, entered the coordinates for this site. Metadata includes USGS Topo Maps 1:63K, TopoZone Pro Street Maps, Black and White Aerial Photo, on a Medium Size Map, View Scale 1:24,000, Coordinate Datum NAD83. Moderate to High degree of confidence in accuracy of location. Alyce Hughey
12/22/2005 Update or Other Action reviewed Kustatan Ridge permitted SW disposal facility monitoring report. Donald Seagren
3/28/2006 Update or Other Action Reviewed 05 GW monitoring report. GW flow dierections consistant with previous interpretations. Beach seep dissolved benzene concentrations have varied betweeen ND & 0.1mg/l. A gradual decling in benzene concentrations in bluff top wells M-103 & M0105S. Benzene concentrations in source area wells and bluff-top wells have remained fairly stable. NAPL tnickness has decreased in some wells but remained unchanged in others. Data indicates tha tthe contaminant plume is stable. No change in risk to human health or the environment. Donald Seagren
1/17/2007 Update or Other Action Telephone cal with Scott Thorsell, Chevron, concerning beach sampling. They are unable to sample at this time of the year due to the beach being iced over. The important factor is to monitor seeps entering Cook Inlet to ensure no contamination from the facility is entering the inlet. The work plan and COBC will be reviewed to see if it specifically mentions sampling in the winter. If it does, a request will be made to conduct the samplng during the Spring, Summer, Fall time period when the beach seeps are accessible and not iced over. ADEC will approve this request. Donald Seagren
5/18/2007 Update or Other Action Reviewed 06 Groundwater Monitoring for Trading Bay Production Facility - COBC No. 91-23-01-053-02. Results are consistent with previous monitoring reports. No adverse risk to human health or the environment. Donald Seagren
5/18/2007 Exposure Tracking Model Ranking Donald Seagren
2/13/2008 Update or Other Action Reviewed monitoring reports for Trading Bay permitted solid waste disposal sites at Kustatan and the Airstrip Landifll. At Kustatan, the compliance wells showed statistically higher concentrations of barium, calcium and magnesi8um than the background well, but there is no consistent pattern as would be expected for a leachate plume. Two exceedances for calcium & magnesium have no Alaska Water Quality standards. The remaining exceedances can be discounted by the lack of corresponding increases in sodium, chloride and hydrocarbon concentrations, all of which are elevated in the leachate. At the Aitstrip landfil, the water table configuration beneath the landfill is consistent with prior results. All analytes were below ADEC clenaup levels.The continued decline in benzene concentrations at MW-7 is consistent with prio rinterpretation of cross-contamination from surficial soils. As was previously reported, contamianted soils were encountered in the top 7' @ MW7, some of which may have been carried downward during drilling. Donald Seagren
6/11/2008 Update or Other Action Site transferred from Don Seagren to Paul Horwath per Linda Nuechterlein. Alyce Hughey
11/18/2008 Update or Other Action File transferred from Paul Horwath to Don Fritz, per Paul Horwath. Alyce Hughey
7/20/2009 Update or Other Action Review Trading Bay COBC sent by Paul. Don Fritz
12/28/2009 Site Characterization Report Approved Review 2008 Groundwater Monitoring report from Dave Brailey. Don Fritz
4/21/2010 Meeting or Teleconference Held Phone conversation with Wendy Woolf (DNR) and then with Linda. Review information sent by Wendy with regard to DNR's needs for a site closure cost estimate regarding bankrupcy proceedings, and begin drafting an estimate. Don Fritz
4/23/2010 Update or Other Action Provide a cost estimate to Wendy Woolf for future estimated costs for cleanup actions a tthe facility. Don Fritz
4/23/2010 Update or Other Action Provide a cost estimate to Wendy Woolf for future estimated costs for cleanup actions a tthe facility. Don Fritz
12/29/2010 Document, Report, or Work plan Review - other Reviewed the 2009 Groundwater Monitoring Report Trading Bay Production Facility, dated December 2010, from OilRisk Consultants for Don Fritz. The results of the tri-annual sampling of the beach seeps performed in June and August of 2009 and January of 2010 showed dissolved benzene concentrations below the beach seep alternate cleanup levels. The results of the annual groundwater sampling of the bluff-top and source area monitoring wells (Ten Wells Sampled) showed benzene concentrations above the COBC requirements within five of the monitoring wells sampled and above the ADEC groundwater cleanup levels within the other five monitoring wells sampled. The groundwater level and annual non-aqueous phase liquid thickness measurements showed similar results from previous measurements taken within the wells. Alyce Hughey
10/28/2011 Document, Report, or Work plan Review - other Reviewed the 2010 Groundwater Monitoring Report, Trading Bay Production Facility, dated September 2011, from OilRisk Consultants. The results of the tri-annual sampling of the beach seeps performed in June, September and December of 2010 were non-detected for BTEX. The results of the annual groundwater sampling of the bluff-top wells (Eight Wells) detected Benzene within five wells above the ADEC groundwater cleanup levels at concentrations of 0.0292 to 0.692 mg/L and within three wells above the COBC requirements at concentrations of 1.41 to 2.84 mg/L. The two source wells detected Benzene above the COBC requirements at concentrations of 2.11 and 3.16 mg/L. The groundwater level and annual non-aqueous phase liquid thickness measurements were 0.37 to 6.27 feet of product in the wells measured. Alyce Hughey
1/13/2012 Update or Other Action Site Transferred from Paul Horwath to Peter Campbell per Paul Horwath. Alyce Hughey
4/15/2013 Document, Report, or Work plan Review - other For the 2011 Groundwater Monitoring Report, Trading Bay Production Facility, dated November 2012, prepared by OilRisk Consultants, the results of the beach seeps performed in July 2011 detected benzene at 0.00653 and 0.00669 mg/L, the September of 2011 detected benzene at 0.0171 mg/L, and January of 2012 were non-detected for BTEX. The results of the annual groundwater sampling of the bluff-top wells (Eight Wells) detected Benzene within five wells above the ADEC groundwater cleanup levels at concentrations of 0.0482 to 0.67 mg/L and within three wells above the COBC requirements at concentrations of 1.45 to 2.90 mg/L. The two source wells detected Benzene above the COBC requirements at concentrations of 1.87 and 2.74 mg/L. The groundwater level and annual non-aqueous phase liquid thickness measurements were 0.16 to 3.42 feet of product in the wells measured. Alyce Hughey
4/16/2013 Document, Report, or Work plan Review - other For the 2012 Groundwater Monitoring Report, Trading Bay Production FAcility, dated February 2013, prepared by OilRisk Consultants, results of the beach seeps performed in May 8, 2012 detected benzene at 0.00118 and 0.0109 mg/L, the September of 2012 did not detect benzene, and November of 2012 detected benzene at 0.00771 and 0.061 mg/L. The results of the annual groundwater sampling of the bluff-top wells (Eight Wells) detected Benzene within five wells above the ADEC groundwater cleanup levels at concentrations of 0.0328 to 0.811 mg/L and within three wells above the COBC requirements at concentrations of 1.65 to 2.90 mg/L. The two source wells detected Benzene above the COBC requirements at concentrations of 2.03 and 2.15 mg/L. The groundwater level and annual non-aqueous phase liquid thickness measurements were 0.20 to 4.30 feet of product in the wells measured. Alyce Hughey
6/16/2015 Site Visit Site visit to the Trading Bay Facility to observe the collection of beach seep samples and the layout of the air sparging system. No hydrocarbon sheen was observed on the beach at a -2.3’ tide. There was evidence that the air sparging system was having an influence on the beach by observing air bubbles escaping at the ground surface approximately 70 feet from the bluff. Peter Campbell
6/17/2015 Document, Report, or Work plan Review - other The 2014 Groundwater Monitoring Report, Trading Bay Production Facility, dated February 2015, prepared by Weston solutions, Inc. There were detections of benzene in beach seep sample locations BH-5, BH-6, BH-8 and BH-9. None of the sample locations had concentrations that exceeded the cleanup level of 0.8 mg/l benzene. All of the detected concentrations were below 0.003 mg/l benzene. Peter Campbell
2/22/2016 Document, Report, or Work plan Review - other The 2015 Groundwater Monitoring Report for Trading Bay Production Facility, dated January 2016, prepared by Weston Solutions. Results of the beach seeps performed in June August and October detected benzene in only one seep sample at 0.0022 mg/L in October at BH-3. This result is below the cleanup level. Approximately 8.5 gallons of product was recovered from on site wells where standing product was bailed out. Benzene levels remain elevated in bluff top and source area wells. Peter Campbell
7/11/2017 Document, Report, or Work plan Review - other Reviewed the 2016 Site Investigation and Groundwater Monitoring Report dated April 10, 2017. The site investigation work was primarily focused on the beach, which is down gradient from the oil processing facility. Twenty eight soil borings and twenty five monitoring wells were installed on the beach. Twenty two of the wells were installed as nested as nested wells with two or three wells in close proximity to measure the potential for vertical distribution of contaminants. Subsurface oil contamination was discovered on the northern portion of the beach. The eastern extent of contamination has not been identified and will be the subject of a field investigation and drilling program in July of 2017. At this point it does not appear that hydrocarbon contamination is discharging to surface waters of Cook Inlet. Peter Campbell
10/9/2017 Document, Report, or Work plan Review - other Reviewed and approved the Proposed 2017 Beach Monitoring Well Decommissioning Procedure. The plan call for the removal of six beach wells that might be in danger of being destroyed by winter storms and/or ice. Four of the wells have significant free phase product within the casing. Peter Campbell
2/14/2018 Meeting or Teleconference Held Met with Chevron Environmental Management to discuss 2018 remediation goals and project status. Peter Campbell
6/20/2018 Site Characterization Report Approved Reviewed the 2017 Site Investigation and Groundwater Monitoring Report prepared by Weston. The report covered annual groundwater monitoring, operation of the air sparge plume, beech seep sampling, and the installation of 11 monitoring wells on the beach to continue the assessment of hydrocarbons discovered in the northern beach subsurface soils and groundwater. ADEC established that the newly discovered plume is not covered under the alternative cleanup levels in the 1996 Compliance Order by Consent and will be regulated under current cleanup levels. Peter Campbell
6/20/2018 Site Characterization Workplan Approved Reviewed and approved the 2018 Monitoring and Site Investigation Work Plan drafted by Stantec for Chevron. The work plan covers groundwater sampling, further delineation of the northern beach LNAPL and dissolved phase transport to Cook Inlet. ADEC asked for an additional work plan to sample existing monitoring wells to reevaluate inland conditions. Peter Campbell
8/16/2018 Workplan Requested Require work plan for the sampling of PFAS compounds in monitoring wells around the Fire Training Facility at Trading Bay. Work plan required by December 1, 2018. Peter Campbell
8/27/2018 Document, Report, or Work plan Review - other Review the Work Plan for Recovery Well System Installation (8/12/2018) and responded to Chevron with several comments addressing concerns that bluff top recovery wells do not address ADEC's primary concern of contamination in the beach environment. ADEC requested a new work plan to address soil and groundwater contamination below the mean high water datum. Peter Campbell
9/27/2018 Document, Report, or Work plan Review - other Review and approve the Addendum to the Work Plan for Recovery Well System Installation, which was a soil management plan for the installation of recovery well piping. Impacted soils from historical contamination will be documented and placed back into the excavation trench where they originated. Impacted soils that appear to be from current a release will be addressed directly. Peter Campbell
3/13/2019 Meeting or Teleconference Held Meet with Chevron (Boyer) and Consultant (StanTec) re: 2018 results and plans for 2019. No definitive source area has been defined for product on the beach subsurface. The plan for this summer is to further delineate the extent of the dissolved and free phase plume on the beach. Peter Campbell
5/8/2019 Document, Report, or Work plan Review - other Review and approve the 2019 Monitoring and Site Investigation Work Plan. The plan calls for groundwater monitoring, delineating the extent of the confining silt lens on the beach, delineating the extent of oil and dissolved phase plume on the beach and evaluate alternative remediation technologies for beach impacts. Peter Campbell
9/16/2019 Document, Report, or Work plan Review - other Review a work plan for the additional assessment of the offshore dissolved phase plume (August 28, 2019) that extends out into Cook Inlet in the subsurface. The work plan includes the installation of a permeable reactive barrier near the bluff to intercept the crude oil plume that is the source area for the dissolved phase plume. ADEC requested additional delineation work to further assess the plume. Peter Campbell
9/18/2019 Workplan Requested Letter sent to Hilcorp requiring a groundwater sampling work plan for PFOS compounds in existing monitoring wells surrounding the former fire training area. Peter Campbell
10/3/2019 Document, Report, or Work plan Review - other Review the 2018 Site Investigation Groundwater Monitoring and Recovery Well System Report. Significant product is accumulating in new bluff top recovery wells RW-2 and RW-7. Minor accumulation is present in RW-4. Soil concentrations during the installation of RW-9 and RW-10 were notable in that elevated hydrocarbons at 53 feet indicate that the source area is probably not the lined lagoons. Peter Campbell
10/4/2019 Meeting or Teleconference Held Meeting with Chevron and consultant to discuss fall 2019 field sampling, which is ongoing. Peter Campbell
3/24/2020 Update or Other Action The consultant for site work has delayed field work due to a global health pandemic and the associated travel restrictions. Peter Campbell
4/10/2020 Document, Report, or Work plan Review - other ADEC reviewed and approved Hilcorps work plan for sampling monitoring wells around the former fire training area. Peter Campbell
4/27/2020 Document, Report, or Work plan Review - other Review Water Well #3R and #4 Sampling Report Dec. 2019 for Hilcorp by Jacobs Engineering. Water Well #3R is near the former fire training area. ADEC requested that the well be sampled for PFAS and PFOA compounds as a condition for the water use permit. Water samples collected from the well did not show any detectable PFAS compounds. Water well #4 was sampled for hydrocarbon compounds because of it's proximity to a plume of significant NAPL. This well is 127 feet deep and showed no hydrocarbons above ADEC's cleanup levels. Peter Campbell
6/24/2020 Document, Report, or Work plan Review - other Review and Approve the 2020 Groundwater Monitoring and Site Investigation Work Plan. Proposed work includes groundwater and pore water sampling, permeable reactive barrier investigation to determine effectiveness, and maintenance of recovery and air sparge wells. Peter Campbell
7/1/2020 Meeting or Teleconference Held Chevron provided a map locating two additional proposed sampling locations for the 2020 work plan that are upgradient from the permeable reactive barrier. Peter Campbell
7/8/2020 Document, Report, or Work plan Review - other Review and approve the 2019 Annual Report. Peter Campbell
12/17/2020 Meeting or Teleconference Held Meet with consultant and Chevron to discuss 2021 work plan focusing primarily on beach impact remediation. Discuss options in general and the preferred path witch is vertical extraction wells on the beach for operation in the summer only, to be removed in the fall before winter storms. Peter Campbell
12/17/2020 Update or Other Action 190 barrel release from a tank near the south east corner of the retention pond. The release was under the tank liner, directly to the subsurface. The released fluid was 80% crude oil and 20% water. 19 barrels were initially recovered. Peter Campbell
1/26/2021 Update or Other Action Report documenting PFOS and PFOA sampling at wells surrounding the former fire training area indicates that there are fire fighting foams in the groundwater in at least one monitoring well. Peter Campbell
3/8/2021 Meeting or Teleconference Held Meeting with new Chevron project manager to discuss work plans and site status. Discuss the implications of the Harvest pipeline being constructed this fall. There is not expected to be any conflict with areas of known contamination. Peter Campbell
3/15/2021 Document, Report, or Work plan Review - other Review the Trading Bay Production Facility Former Fire Training Area Per- and Polyfluoroalkyl Substances Sampling Report prepared for Hilcorp. Sampling detected regulated per- and polyfluoroalkyl substances (PFAS) firefighting foam, in the groundwater adjacent to the fire training area. ADEC is requiring an assessment be conducted to determine the extent of soil, groundwater and surface water impacts at the site. Peter Campbell
5/19/2021 Workplan Requested 2021 Groundwater Monitoring and Site Investigation Work Plan Approval and Work Plan Request. ADEC is requiring that Chevron collect a water sample from the outfall of the remediation system pumping wells and test that sample for PFAS compounds, including PFOS and PFOA. The discovery of these compounds in groundwater on the site makes it prudent to do so as this water discharges to Cook Inlet. ADEC is requesting Chevron present a work plan for this field season to address separate and dissolved phase product remediation on the seaward side of the permeable reactive barrier beach remediation system Peter Campbell
8/23/2021 Update or Other Action On August 9, 2021 Hilcorp reported a slop oil release adjacent to the sand sand drain and produced water retention basin. The Spill Response Program is managing the release. The spill report is included in attachments. Peter Campbell
9/27/2021 Document, Report, or Work plan Review - other The Prevention and Response Program has been working a release investigation at Inspection site #14. The work plan is in Report Attachments. Excavation and characterization activities on inspection dig (Dig 14) of buried pipelines adjacent the Flare Trap Building The source appears to be a 4-inch line just outside the Flare Trap Building. The line appears to have been intentionally severed and abandoned in place, but not properly cleaned or capped. The 8-inch side of the line is a dead leg on the current sand drain system, which operated at 0-30 pounds head pressure when draining the Battery 2 tanks to the sand drain. The 4-inch side of the line appears to be the primary source of the spill and runs from the excavation to the old sand drain pit. This line has been located running to the east from the Flare Trap Building and turning south between the two produced water retention ponds for approximately 90 feet. Peter Campbell
6/16/2022 Workplan Requested 2022 Work Plan for Groundwater Monitoring and Site Investigation not approved pending the addition of PFAS monitoring to the outfall of the remediation system. Discharge of PFAS compounds through the remediation system may endanger Hilcorp's NPDES permit. Peter Campbell
9/1/2022 Update or Other Action Revised Contaminated Soil and Groundwater Soil Management Plan for 2022 Integrity Inspections to include abandoned Fire Hydrant and New Accumulator Bypass Line. Peter Campbell
9/15/2022 Document, Report, or Work plan Review - other It is our understanding, based on the review of the pump test data presented in the report, that there is little communication between pumping wells at the current pumping rates. There is significant drawdown in the pumping wells, but apparently no reaction in water levels in adjacent recovery wells, implying that pumping rates are not sufficient to capture all dissolved phase liquids along the bluff. We are requesting that Chevron address this deficiency in pumping flow rates, particularly in the northern portion of the property where dissolved concentrations are greatest. Chevron will demonstrate groundwater pumping rates sufficient to capture the dissolved phase and NAPL plumes moving east off the property. Peter Campbell
1/19/2023 Workplan Requested Request a work plan from Hilcorp to investigate product accumulation at the bluff which is migrating offsite to the beach. This is a third work plan request to investigate the potential for product accumulation on the groundwater. DEC has requested work plans from the Hilcorp Trading Bay Line Release W-0534 (2337.38.054) and Hilcorp Trading Bay Piping Leak (23337.38.052). Request work plan by March 1, 2023. Peter Campbell
1/31/2023 Update or Other Action Hilcorp has requested an extension until April 14, 2023, for their Site Assessment workplan to investigate NAPL at the bluff. Peter Campbell
6/23/2023 Workplan Requested Request work plan for assessment work in the facility to determine if releases are impacting groundwater and if there is recoverable product. Notice sent to Chevron copied to Hilcorp. Peter Campbell
7/21/2023 Long Term Monitoring Workplan or Report Review Review and approve the 2023 Facility Groundwater Monitoring and Site Investigation Work Plan. The approval letter requested that Chevron develop a contingency plan for the beach and bluff areas should erosion cause a failure of the remediation system or expose contamination to the marine environment. Peter Campbell
8/3/2023 Long Term Monitoring Workplan or Report Review 2022 Annual Report ADEC Comments and Report Approval. DEC has requested contingency plans for two areas of beach remediation, the north and south beach. The beach is eroding, and a storm could cause dramatic changes to the beach environment, leading to hydrocarbons daylighting to surface water. Peter Campbell
8/24/2023 Offsite Soil or Groundwater Disposal Approved Hilcorp Soil Transport Approval - Investigation Derived Waste from of soil generated during the Trading Bay PFAS investigation from Super Sacks #5 and #8. DRO was detected above the ADEC migration to ground water levels in both super sacks. Soil to be transferred to KGF G&I Facility for disposal. Peter Campbell
3/6/2024 Spill Transferred from Prevention Preparedness and Response Program Integrity Survey Dig 14 Aug 4, 2022. Grossly contaminated with PAH, DRO and RRO. Photos do not show an area that is restrictive of excavation work. Significant amount of crude present in photos. 2022.7.26 email: “Contamination is hydrocarbon-based and is weathered; no free liquids. Appears to be historical contamination. The total volume of spilled material is undetermined at this time. Cause is unknown. No observation of infrastructure or leaking equipment in excavated area. There are no buried or above ground Hilcorp oil pipelines at this location. Excavated area is about 5’ wide on top, 3’ wide on bottom, and about 6’ long by 3 ‘deep (Photo 1371).” 2022.9.22 email: “Attached are analytical results for the Dig 5 and Dig 14 soil samples collected in early August by Susitna Environmental at the Trading Bay Production Facility in response to found contamination during facility integrity digs. Dig 14 has DRO, RRO, PAHs, and VOCs detected above cleanup levels. Dig 5 has DRO above the cleanup level (3,370 mg/kg) in the west wall and DRO and RRO above cleanup levels in the floor (5,080 mg/kg and 12,600 mg/kg respectively). Attached also is the daily report from Susitna with photos showing the sample locations. Susitna Environmental has recommended and Hilcorp is requesting ADEC concurrence to backfill these two locations with uncontaminated soil and defer cleanup to the pad end of life. Further excavation at these locations is not feasible due to existing active infrastructure including subsurface pipelines and adjacent buildings.” Peter Campbell

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