Action Date |
Action |
Description |
DEC Staff |
9/1/1983 |
Update or Other Action |
1983 PCB Removal Action
In 1983, the USAF 5099 Civil Engineering Operation Squadron conducted an environmental investigation and contamination removal action. PCB-contaminated soil was excavated from
the northeast entrance/exit of the transformer building at OT-001 [AKA Composite Building & White Alice Arrays] and in the vicinity of three transformers found in the old disposal area north of the contractor's camp (now LF001). The limits of these excavations are unknown. |
Louis Howard |
9/3/1984 |
Update or Other Action |
1984 PCB Removal Action
USAF records indicate that 36 drums of PCB-contaminated soil and six drums of transformer material were removed from Nikolski RRS in 1984 and shipped to Elmendorf Air Force Base. No analytical data are available, and there are no records further indicating the final disposition of the contaminated soil or transformer materials. |
Louis Howard |
1/1/1994 |
Preliminary Assessment Approved |
CH2MHill was contracted by the USACE to conduct a PA for the Nikolski White Alice Communication System Site. In 1984, the USAF removed PCB soil and transformers. In 1988 the facility was demolished and the debris and asbestos buried in an on-site landfill. |
Debra Caillouet |
4/13/1994 |
CERCLA PA |
Letter from Mark Ader (EPA) to Lt. Colonel Hunt (AF)
This letter is to inform you that EPA Region 10 has completed the review of the Preliminary Assessment (PA) report for the Nikolski White Alice Communications site. The PA has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation does not relieve your facility from complying with appropriate Alaska state regulations. The Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 120(a) (4) requires federal facilities to comply with State [of Alaska-DEC] cleanup requirements and standards when not listed on the NPL.
This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. |
Louis Howard |
10/3/1994 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Work plan, White Alice Communications Sites, Nikolski, Alaska; Prepared by EMCON Alaska, September 1994.
If the Air Force intends to me the results of this investigation to support a NFA Decision for the site, additional investigation appears necessary prior to the State concurring. Areas around the fuel storage-distribution system & the land fill should be assessed in more detail than is proposed. A gravel runway is shown on figure 2, the vicinity map. It is not clear If the Air Force owned or operated a fueling system at the runway', If it did, Investigation of the fueling system should be included.
No fuel tanks, other than the above ground tank (ASTs) at the beach area, are identified on the site maps. Based on other White Alice sites, it is very likely USTs or ASTs were present at the site. Use of geophysical Investigation would help in defining whether USTs are, or have, been present. Geophysical survey would also help In defining disposal area boundaries & determining whether buried debris is present in areas of disturbed soil.
Section 4.1 - This section states a PID will be used for field screening. ADEC recommends use of additional field screening methods to help assess areas with contaminants other than VOCs. PCBs are a potential contaminant of concern. Various PC8 screening methods are available which would help in selecting sample collection points & providing a higher degree of confidence in the site investigation (SI) results. FIDs, Infrared spectrometry, immunoassay & other methods are available to assess petroleum contamination that contains little to no VOCs. Due to the high cost & difficulty in planning work at remote sites, ADEC recommends collection of as much field data as possible while crews are on-site. If contamination is evident during the field work sufficient screening should be conducted to aid in planning future investigation or corrective action.
Section 4.1 - it states calibration for the PID will be shipped out to the site "if practical'.
PIDs should be calibrated daily (& more frequently if necessary) while in the field. Every effort should be made to ship calibration gas to the site. If it is impossible then alternative screening methods must be utilized.
See site file for additional information. |
John Halverson |
11/1/1995 |
CERCLA SI |
EMCON was contracted by the USAF 611th to perform a PA/SI. The site was divided into two Installation Restoration Program (IRP) sites and ten areas of concern (AOC). This site-OT01 consists of the former composite building, former transformer building, four former White Alice arrays.
OT001 Former Transformer Bldg.
PCB field screening was conducted on soil samples from four locations at each former feedhom (SCR-31 through SCR-34 at the south feedhom, and SCR-35 through SCR-38 at the north feedhorn). Field screening results did not conclusively detect PCBs in any of the field screening locations. Soil samples were collected from field screening locations exhibiting the greatest possibility of impact. Soil samples 95NIK010SO, 95NIK011SO (split sample), and 95NIK012SO (duplicate sample) were collected from field screening location SCR-32 at the south feedhorn. Sample 95NIK013SO was collected at field screening location SCR-38 at the north feedhorn.
The PCB analytical results for these samples were ND to 4.5 ppm [NOTE: soil sample 95NIK013SO collected from the north feedhorn exceeds the soil cleanup level in 18 AAC 75 (2015) Table B1 cleanup level for PCBs is 1 ppm]. Another soil sample was collected from the former transformer building area in the approximate vicinity where the 5099th removed PCB-impacted soil. The PCB laboratory analytical result for this sample (95NIK014SO) is 0.5 ppm (Table 4).
Conclusions
Analytical results from samples in this vicinity do not indicate the presence of PCB-impacted soil above the standard 10 ppm cleanup level. In addition, the 5099th removed PCB-impacted soil at the front of the building in 1983. There is no indication of other potential sources of impact. No further investigation is warranted in this area. Table 4 summarizes the analytical results and recommendations for this site.
See site file for additional information. |
Debra Caillouet |
2/12/1997 |
Update or Other Action |
(Old R:Base Action Code = SI - Site Investigation). SI action added by Shannon and Wilson, Inc., based on Air Force Relative Risk Evaluation Worksheet dated 9/14/95. No other information available. |
S&W-Miner |
2/12/1997 |
Site Added to Database |
Site added by Shannon and Wilson, Inc. |
S&W-Miner |
12/1/2000 |
Update or Other Action |
A site survey was conducted with the 611th, Jacobs Engineering and Jeff Brownlee (ADEC). |
Debra Caillouet |
12/21/2000 |
Meeting or Teleconference Held |
Scoping meeting for the remedial investigation at this former White Alice site. The site operated on Umnak Island in the Aleutian Islands from 1957 to 1977. All the facilities except a tank farm and pipeline were demolished and buried on site in 1986. A Preliminary Assessment/Site Investigation was done in 1995. A drum removal was performed in 1997. Ten Areas of Concern and two IRP sites were identified during the PA/SI. Contaminants of concern include PCBs, petroleum, metals and TCE at one AOC. |
Jeff Brownlee |
2/22/2001 |
Meeting or Teleconference Held |
Meeting was to get to know the team and goals/plans for summer 2001 work. |
Debra Caillouet |
4/11/2001 |
Site Number Identifier Changed |
Changed Reckey from 199725X104309 to reflect better spill date and Workplan. |
Debra Caillouet |
5/17/2001 |
Meeting or Teleconference Held |
A public meeting was held in Nikolski on May 14. The Air Force, Jacobs Engineering and ADEC presented information on the cleanup process and the RI work scheduled for 6/2001. The meeting was well attended and well received by the community. |
Debra Caillouet |
6/25/2001 |
Update or Other Action |
Staff traveled to Nikolski to review the characterization work being done. Work was proceeding well. |
Debra Caillouet |
11/29/2001 |
Site Characterization Report Approved |
Benzo(a)pyrene was detected above site regulatory limits in two soil samples collected at the former composite building. It is recommended that this compound be further addressed in the feasibility study. DRO was also detected at the composite building at concentrations exceeding site regulatory limits. It is recommended that approximately 250 cubic yards of impacted soil be removed from the site or other alternatives be further evaluated in the feasibility study.
Soils beneath the former transformer building site and at the northern White Alice array contained polychlorinated biphenyls (PCBs) at concentrations above regulatory limits. It is recommended that approximately 140 cubic yards of PCB contaminated soil from the transformer building site be removed or remediated. The slope at the northern feedhorn tower will prevent safe removal of soil from this location; therefore, it is recommended that this soil be left in place. Additionally, a septic tank was found at the former transformer building site. It is recommended that this tank be abandoned in place in accordance with Alaska Department of Environmental Conservation (ADEC) guidance.
TU019
Water remaining in the tanks contains DRO and RRO at concentrations above site regulatory limits for groundwater. Therefore, it is recommended that this water be pre-treated with an oil-water separator and treated on site and that the tanks be abandoned in place in accordance with ADEC regulations. Approximately eight cubic yards of soil within the concrete vault on top of the northeast tank contained DRO and RRO concentrations exceeding site regulatory limits. Therefore, it is recommended that this soil be remediated or removed from the site. Four polynuclear aromatic hydrocarbons (PAHs) were detected at concentrations above site regulatory limits in soils at AOC-09: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene and dibenzo(a,h)anthracene. This contamination also extends beneath the former composite building site (OT-001) and includes approximately 12,900 to 19,000 cubic yards of contaminated soil. It is recommended that alternatives for addressing these elevated concentrations in soil be evaluated in the feasibility study. |
Debra Caillouet |
5/15/2002 |
Meeting or Teleconference Held |
Staff attended a public meeting in Nikolski |
Debra Caillouet |
10/14/2002 |
Update or Other Action |
Staff submitted comments on the draft feasibility study. |
Debra Caillouet |
12/11/2002 |
Meeting or Teleconference Held |
Staff participated in the Air Force peer review of the proposed plan for Nikolski.
In December 2002, the Air Force conducted a peer review of the draft feasibility study. The peer review team concluded that a risk assessment should be conducted at the composite building and associated White Alice arrays (OT-001), the fuel pipeline (SS-003), and the POL tank area (SS-004). Based on the conclusions of the peer review team, a preferred alternative will not be selected for OT-001, SS-003, SS-004, or the POL outfall area (WP-007) until the risk assessment is completed. Because this change significantly impacted the alternatives developed to address POL contamination, a separate alternative to address the remaining sites with POL contamination has been included in this document in order to implement the peer review team's recommendations.
See site file for additional information. |
Debra Caillouet |
3/4/2003 |
Document, Report, or Work plan Review - other |
Staff commented on the Nikolski Radio Relay Station, Approval of Feasibility Study for Sites, LF-001, AOC-01, SS-002, SS-005, SS-006, AOC-08, AOC-09, and OT-010
The Alaska Department of Environmental Conservation (DEC) received your response to our comments of October 14, 2002 on February 21, 2003. The response to comments has met the requirements of 18 AAC 75.335(c)(5) for the above listed nine of the thirteen sites investigated.
The cleanup methods proposed in the document have been reviewed by DEC but will need to be presented for public review and comment before they can be approved. The Risk Assessment that is proposed for sites OT-001, SS-003, SS-004 and WP-007 should follow the guidance found in the Risk Assessment Procedures Manual, June 2002 and User's Guide for Selection and Application of Default Assessment Endpoints and Indicator Species in Alaskan Ecoregions, June 1999.
|
Debra Caillouet |
10/13/2003 |
Risk Assessment Workplan Approved |
Staff provided comments on the RA WP.
The Alaska Department of Environmental Conservation (ADEC) received the above mentioned report on August 21, 2003. We concur that the work plan meets the requirements of ADEC’s Risk Assessment Procedures Manual, dated June 8, 2000.
Thank you for providing a copy of the Final Nikolski RRS Risk Assessment Work Plan. |
Debra Caillouet |
8/6/2004 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Nikolski Radio Relay Station, Nikolski, Alaska, Baseline Risk Assessment, Final, June 2004.
Composite Building and Associated White Alice Arrays
The risk assessment for the composite building and associated White Alice arrays indicates that people visit the site only infrequently. Due to extreme weather, lack of water supply, and the badly eroded access road, residential development of the site is considered highly unlikely. In addition, the proposed groundwater use determination (18 AAC 75.350) previously developed for this site indicates that groundwater is not a current or reasonably expected future source of drinking water. Public review and comment, which can be done through the pending proposed plan, are needed prior to the DEC formally making the groundwater use determination. The human health hazard index (HI) and estimate of excess lifetime cancer risk developed based on these assumptions are both less than target risk values in 18 AAC 75.325(h). The final remedy will need to include institutional controls or land use controls to ensure assumptions used in developing cleanup levels remain valid in the future.
A variety of polynuclear aromatic hydrocarbons (PAHs) at the composite building site resulted in ecological hazard quotients (HQs) greater than 1.0. Ecological HQs for these compounds ranged from to 2 to 10,000. The significance of the calculated ecological HQs is assessed in light of a number of site-specific factors and concludes that the contaminants will not reach higher trophic level organisms. Additionally, as described in the uncertainty analysis and conclusions sections, the natural site setting and conditions do not provide quality habitat for lower trophic level species for which the higher HQs were calculated. Thus, the DEC concurs with the risk assessment conclusions for this area.
See site file for additional information. |
Debra Caillouet |
1/18/2005 |
Update or Other Action |
File number issued 2621.38.004 |
Aggie Blandford |
2/16/2007 |
Exposure Tracking Model Ranking |
|
Debra Caillouet |
3/9/2007 |
Update or Other Action |
DEC submitted formal comment on the published Proposed Plan for Site OT001 Former Composite Building and White Alice Arrays
1.DEC does not concur with the proposed no action required for this site.
a.Establishing and enforcing institutional controls and conducting Five Year reviews are actions that are required to prevent exposure to contamination.
i.The EPA, in A Guide to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection Decision Documents (EPA 540-R-98-031), Section 8.1 Documenting No Action Decisions starts out, "The lead agency may determine that no action (i.e., no treatment, engineering controls, or institutional controls) is warranted….
ii.The Department of Defense has also supported this in the Memorandum Interim Guidance on Environmental Restoration Record of Decision (June 4, 2002). In the second paragraph, "When a remedial action is taken, it must be documented in a ROD as required by CERCLA and its implementing regulation, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This requirement fully applies to remedies that have a use restriction component."
2.The Proposed Plan does not present the remedial alternatives that were analyzed for the site. (40 CFR 300.430 (f) (2))
|
Debra Caillouet |
5/14/2007 |
Document, Report, or Work plan Review - other |
Lawyers on behalf of the Chaluka Corp. submitted comments on the Proposed Plans for Nikolski, Alaska.
Of the six Proposed Plans (PPs) issued by the Air Force (AF), four involve land to be conveyed to Chaluka pursuant to special legislation enacted by the United States Congress in 2003 (hereinafter "Airport Legislation"). In three of those four PPs, the AF proposes to place restrictions on the use of the land. The bulk of Chaluka' s comments are directed to these three PPs (Site SSO1O, Site WP007, & Site OTOO1).
Chaluka would submit further that not only is there no authority for such restrictions, but that ANCSA, in fact, prohibits such restrictions. In sum, placing restrictions on the use of the land is antithetical to ANCSA's requirement that land be conveyed in "fee simple." As a justification for its intent to place use restrictions on the Phase II lands, the AF apparently relies on the language in Section 190(c)(l)(B) of the Airport Legislation. As stated above, that section provides that the Phase II lands shall be conveyed to Chaluka "upon completion of environmental restoration ... in accordance with applicable law."
The AF apparently holds that "applicable law" allows it to take into consideration the "current & future land use" in determining the necessary level of "environmental restoration." This argument elevates the general & ambiguous reference to "applicable law" over the specific & plain statement that conveyance under the Airport Legislation "shall be considered to be conveyances under the Alaska Native Claims Settlement Act .... "
The AF PP suffer from the additional problem that Chaluka has already carried out the obligations required of it by the statute. Chaluka has already relinquished the Exchange Lands & has received patent to the Phase I lands under the Airport Legislation. These acts cannot be undone without running further afoul of the Airport Legislation. In effect, Chaluka has carried out its side of the bargain, it should not now be forced to accept something less than was originally promised it.
For all of the above reasons, Chaluka objects to the AF PP regarding Site SSO1O, Site WP007, & Site OTOO1. Chaluka submits that those lands should be restored to a condition in which they can be conveyed without restriction pursuant to "applicable law." Anything less is contrary to Congress's clear mandate as expressed in the Airport Legislation.
In addition to the above comments, Chaluka concurs with & incorporates by reference the Alaska Department of Environmental Conservation's objections to the PPs regarding Site SSO1O, Site WP007, & Site OTOO1. As for the PPs for ST018 & SS005, based on the AF's assurance that no use restrictions will be placed on those sites & based on its proposed actions for Site STO18, Chaluka offers no additional comment on those plans.
See site file for additional information. |
Debra Caillouet |
6/18/2008 |
Document, Report, or Work plan Review - other |
Site Investigation Report for TU019: Two 20,000-Gallon USTs (ADEC Facility ID #3512), Pre-draft June 2008 The Alaska Department of Environmental Conservation received the above referenced report on June 5, 2008. Due to the large number of comments and the absence of some supporting documentation, I am requesting that a draft final version of this report be submitted for review by July 18, 2008 |
Debra Caillouet |
6/30/2008 |
Enforcement Agreement or Order |
TU019
The Alaska Department of Environmental Conservation received the above referenced report on June 5, 2008. I am writing to you because I understand that due to staffing changes there is not currently an Air Force (AF) project manager assigned to the Nikolski Environmental Restoration projects.
The report documents the release of petroleum products to the soil & GW at TU019 & failure to comply with the Underground Storage Tank (UST) regulations. Specifically, a certified worker was not used to close the USTs as required by 18 AAC 78.400; the USTs were not removed from the ground during closure as required by 18 AAC 78.085(c), even though a release was observed; the release was not reported in a timely manner as required by 18 AAC 78.220; release investigation & corrective action have not been implemented as required by 18 AAC 78.235 & 18 AAC 78.240.
When contamination was first discovered the AF did not report it as required in 18 AAC 78.220, which states:
(c) If a leak, overfill, or other petroleum release from a UST is identified, & soil or water contamination is discovered by direct observation, through site characterization or assessment under 18 AAC 78.090, or through some other means, the owner or operator shall perform the following initial response actions within 24 hours after the owner or operator first discovers that a release has occurred: (1) notify the department's Anchorage, Fairbanks, Juneau, or Soldotna office of (A) a belowground release from the UST in any amount; (B) an aboveground release to land from the UST if the release exceeds 10 gallons; or (C) an aboveground release to water of the state if the release causes a sheen or discoloration of the water surface;
DEC considers this pre-draft report as notification of the release.
The UST regulations require submittal of Release Investigation Report within forty-five (45) days after the date a release has been confirmed (18 AAC 78.325(g)) & an Interim Corrective Action Report within sixty (60) days after a release has been confirmed (18 AAC 78.240(c).) Neither has been submitted, nor has an extension been requested, however, the report referenced above contains some information required in a release investigation report.
The Air Force is requested to begin corrective action by submitting a Corrective Action Plan in accordance with 18 AAC 78.220 (e) to address contamination remaining at TU019 & to remove the remaining portions of the two tanks as required by 18 AAC 78.085(c). The Underground Storage Tank regulations in Chapter 78 & the UST Procedures Manual provide the detailed requirements for the Corrective Action Plan. Please submit this plan for DEC approval (18 AAC 78.260) by August 1, 2008 & complete the corrective action by December 31, 2008.
|
Louis Howard |
7/31/2008 |
Document, Report, or Work plan Review - other |
Staff sent comments to the Air Force on three draft final cleanup reports for the Nikolski Radio Relay Station. These reports cover actions done under a performance based contract last year and document several violations of the UST regulations. The reports do acknowledge the violations of the regulations and state that corrective action work plans will be provided to DEC. The reports are still missing documentation of waste disposal that was requested in comments on the Pre-draft versions. A meeting was held with DEC, AF and DOL staff to discuss the violations and plans for transferring land to the local native corporation. |
Debra Caillouet |
8/19/2008 |
Document, Report, or Work plan Review - other |
The Corrective Action Plan for TU019: Two 20,000-Gallon USTs, Draft August 2008 was rejected. The Alaska Department of Environmental Conservation in a letter dated June 10, 2008 requested the Air Force provide a corrective action plan by August 1, 2008 to address contamination remaining at TU019 and to remove the remaining portions of the two tanks as required by 18 AAC 78.085(c). The document titled Corrective Action Plan for TU019: Two 20,000-Gallon USTs, Draft August 2008 was received on August 1, 2008. The document does not comply with the UST regulations and does not provide a plan for compliance with the regulations. Please provide a Corrective Action plan that meets the requirements of 18 AAC 78. |
Debra Caillouet |
10/15/2008 |
Meeting or Teleconference Held |
TU019
the following deficiencies occurred in the fieldwork conducted at TU019 in 2007:
?? The tanks should have been closed in accordance with the Alaska Administrative Code, Title 18, Chapter 78, USTs (18 AAC 78),
?? The tanks were not removed from the ground,
?? No certified person was on site to observe and certify the activities, and
?? The appropriate documents (site assessment form and post-closure notification) were not completed and submitted in a timely manner.
Removal of the tanks under the observation of a UST-certified person and completion and submittal of the site assessment form and post-closure notification form will satisfy the ADEC UST Program under 18 AAC 78.
The Air Force will revise the Corrective Action Plan (CAP) to resolve the deficiencies and close the tanks in accordance with 18 AAC 78. The revised CAP will include excavation and removal of the tanks in the presence of a UST-Certified Decommissioner, field screening and confirmation laboratory sampling of the excavated material that was used as backfill, proposal of cleanup levels for the site and an evaluation of the Remedial Investigation (RI) data to see if the soil samples collected at the pipeline were adequate for the site investigation sampling. ADEC UST Division agreed with the conclusion that the eight soil samples collected around the tanks were adequate for the site investigation. The Revised CAP will be submitted for ADEC approval prior to implementation of field activities in Summer 2009.
The site assessment form and post-closure notification will be submitted to the ADEC UST Division within the regulated timeframe after completion of fieldwork.
The Air Force will evaluate Method Three Cleanup Levels for soil at TU019 prior to evaluation of Method Four Cleanup Levels. If Method Four Cleanup Levels are proposed, the Air Force would have to go through the risk assessment process in the ADEC Risk Assessment Procedures Manual. Additionally, ADEC UST Division provided clarification that the Risk Evaluation form at the end of the UST Procedures Manual is not used.
Ms. Paige confirmed that submittal of the correct documentation for the USTs at TU019 will eliminate the potential for a Notice of Violation (NOV).
In response to the Draft Final Site Investigation Report for TU019, ADEC Contaminated Sites will review and evaluate any additional information provided by BEM’s subcontractor. ADEC Contaminated Sites specifically requested documentation for the volume and disposal of fuel and sludge removed from the USTs. |
Louis Howard |
10/31/2008 |
Document, Report, or Work plan Review - other |
ADEC response to meeting minutes dated 10/15/2008 for meeting held on 9/24/2008 for TU019, SS005, SS004.
TU019
3rd paragraph. The eight samples obtained during the 2007 activities were sufficient to determine that a release had occurred under the UST regulations. For site characterization, sampling and analysis for PAHs, along with the petroleum hydrocarbon fractions will be necessary.
7th paragraph. During the meeting BEM stated they were meeting with their subcontractor that afternoon and would provide documentation of the disposal of the fuel and sludge the next day. DEC has not received this documentation. Please provide this by November 15, 2008.
|
Louis Howard |
6/15/2009 |
Update or Other Action |
Corrective Action Plan for TU019 received.
The USAF will implement the following corrective actions:
The remnants of the two USTs will be excavated and removed from the site for off-site
disposal/recycling as required by 18 AAC 78.085(c).
The field activities will be completed under the observation of a UST-Certified decomissioner.
Additional sample collection will be performed to comply with the UST regulations. After the UST removal has been conducted, a Closure Report including the appropriate UST forms will be submitted to ADEC within the timeframes specified in 18 AAC 78.
The results of the tank removal and sample collection will be documented in a UST Closure Report. The UST Closure Report will be submitted for review and approval by the ADEC UST Program. |
Debra Caillouet |
7/2/2009 |
Site Characterization Workplan Approved |
SS005 and TU019 Final Release Investigation Work Plan for SS005: Runway Lighting Vault and UST, June 2009, Final Corrective Action Plan for TU019: Two 20,000-Gallon USTs, June 2009 The Alaska Department of Environmental received the above referenced work plans on July 6, 2009 via e-mail. The work plans incorporated acceptable responses to previously supplied comment and are approved for implementation |
Debra Caillouet |
9/1/2009 |
Update or Other Action |
Also in 2009, Site TU019 was incorporated into Site OT001 because the PAH compounds identified in soil at the two sites likely came from the same source, believed to be an historical diesel spill. This determination was based on the uniformity of the relative PAH concentrations at Sites OT001 and TU019. Soil contamination at Site TU019 was administratively transferred to Site OT001, and all PAH contamination in the area is considered part of Site OT001. |
Louis Howard |
9/29/2011 |
Cleanup Complete Determination Issued |
Signing of the ROD demonstrates concurrence with the selected remedy: Institutional controls for the soil contamination present at OT-001.
The remedy for OT-001 will result in petroleum contaminants remaining onsite above State of
Alaska regulatory soil cleanup levels in 18 AAC 75 that allow for unlimited use and
unrestricted exposure. Land use restrictions are required as part of this response action and will be achieved through the establishment of ICs that limit the use of those areas of the site that have contamination remaining in place. Therefore, periodic reporting will be required at ERP Site OT-001 for submittal to ADEC to verify that the remedy is, or will be, protective of human health and the environment. |
Louis Howard |
9/29/2011 |
CERCLA ROD Approved |
The response action selected in this ROD is necessary to prevent exposure to non-CERCLA COCs remaining in place after implementation of the selected remedy. The COCs are benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, & RRO which have been detected above 18 AAC 75 soil cleanup levels. Areas within Site OT-001 cannot support unlimited use & unrestricted exposure due to the aforementioned COCs remaining in place after implementation of the selected remedy. Land use restrictions are required as part of this response action & will be achieved through the establishment of ICs that limit the use of those areas of the site that have contamination remaining in place.
The USAF is committed to implementing, monitoring, maintaining, & enforcing all components of the selected remedy to ensure that it remains protective of human health & the environment. Remedial alternatives for the Former Composite Building site (OT-001), which includes the adjacent Two 20,000-Gallon USTs site (TU-019, formerly AOC-09), were developed & evaluated during the Feasibility Study (FS) (USAF 2003a). Based on the results of the Feasibility Study, the USAF selected ICs as the preferred alternative for OT-001.
TU019's site status changed to Non-Qualifying as it has been incorporated into Site OT-01 administratively & ICs are to be implemented.
The Former Composite Building (OT-001), including the adjacent Two 20,000-Gallon USTs site (TU-019), are two of thirteen ERP sites at Nikolski RRS. The TU-019 site is in close proximity to Site OT-001. As documented in the 2004 Baseline Risk Assessment, a high degree of correlation exists between the PAH fingerprints from soil borings at OT-001 & TU-019, which indicates that the source of contamination at OT-001 was from a diesel fuel spill. In addition, the conceptual site model for OT-001 indicates that a likely source of the fuel spill that resulted in PAH contamination at OT-001 was from TU-019. Given the close proximity of the sites & similarity of PAH fingerprints, a technical memorandum discussing the administrative inclusion of TU-019 to OT-001 is included in Appendix C.
The major components of the selected remedy for OT-001 will include:
• ICs to prevent residential use and restrict surface excavation activities at the site. The ICs will be developed to encompass an area described as Tract 37C covering approximately 29.64 acres (Figure B-1 in Appendix B).
• The requirement that all surface excavation or digging activities within Tract 37C be subject to ADEC approval as may be required by State of Alaska regulations [e.g., 18 AAC 75.325(i)].
• USAF will conduct five-year reviews of the remedy since substances will remain onsite at levels above applicable State of Alaska cleanup levels specified in 18 AAC 75. These five-year reviews will also report on the effectiveness of the ICs. Reviews may become more frequent if conditions change.
See site file for additional information.
|
Debra Caillouet |
9/29/2011 |
CERCLA ROD Approved |
Signing of the ROD details the cleanup levels assigned for the site. The Former Composite Building (OT-001), including the adjacent Two 20,000-Gallon USTs site (TU-019), are two of thirteen ERP sites at Nikolski RRS. The TU-019 site is in close proximity to Site OT-001. As documented in the 2004 Baseline Risk Assessment, a high degree of correlation exists between the PAH fingerprints from soil borings at OT-001 & TU-019, which indicates that the source of contamination at OT-001 was from a diesel fuel spill. In addition, the conceptual site model for OT-001 indicates that a likely source of the fuel spill that resulted in PAH contamination at OT-001 was from TU-019.
Given the close proximity of the sites & similarity of PAH fingerprints, a technical memorandum discussing the administrative inclusion of TU-019 to OT-001 is included in Appendix C of the 2011 Record of Decision for OT-001, ST-018, & WP-007.
While not listed on the NPL, Nikolski RRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.]. |
Louis Howard |
9/30/2011 |
Institutional Control Record Established |
Institutional Controls established & entered into the database.
The response action selected in this ROD is necessary to prevent exposure to non-CERCLA COCs remaining in place after implementation of the selected remedy. The COCs are benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, & RRO which have been detected above 18 AAC 75 soil cleanup levels. Areas within Site OT-001 cannot support unlimited use & unrestricted exposure due to the aforementioned COCs remaining in place after implementation of the selected remedy. Remedial alternatives for the Former Composite Building site (OT-001), which includes the adjacent Two 20,000-Gallon USTs site (TU-019, formerly AOC-09), were developed and evaluated during the Feasibility Study (FS) (USAF 2003a). Based on the results of the Feasibility Study, the USAF selected ICs as the preferred alternative for OT-001.
Land use restrictions are required as part of this response action & will be achieved through the establishment of ICs that limit the use of those areas of the site that have contamination remaining in place. The USAF is committed to implementing, monitoring, maintaining, & enforcing all components of the selected remedy to ensure that it remains protective of human health & the environment.
The major components of the selected remedy for OT-001 will include:
• ICs to prevent residential use & restrict surface excavation activities at the site. The ICs will be developed to encompass an area described as Tract 37C covering approximately 29.64 acres (Figure B-1 in Appendix B).
• The requirement that all surface excavation or digging activities within Tract 37C be subject to ADEC approval as may be required by State of Alaska regulations [e.g., 18 AAC 75.325(i)].
• USAF will conduct five-year reviews of the remedy since substances will remain onsite at levels above applicable State of Alaska cleanup levels specified in 18 AAC 75. These five-year reviews will also report on the effectiveness of the ICs. Reviews may become more frequent if conditions change.
The ICs established by the State of Alaska regulations will remain in effect indefinitely or until the COCs at OT-001 are below applicable 18 AAC 75 cleanup levels, at which point the ICs can be eliminated with the approval of ADEC in accordance with 18 AAC 75.375(f). USAF, as the responsible entity, will implement, monitor, & maintain the ICs in accordance with State of Alaska regulations. USAF will also provide a monitoring report to ADEC every five years after each monitoring event. If the site remedy is found to be deficient during an inspection, ADEC will be contacted & further corrective action will be planned. ADEC will be notified if the property subject to ICs is transferred or if any significant changes are made to the use & activity restrictions of the ICs.
See site file for additional information. |
Louis Howard |
11/30/2015 |
Meeting or Teleconference Held |
5 Year Review scoping meeting held with MWH. Referred contractor to 11/23/15 entry requiring periodic reporting and recommended inclusion of this site in LUC -IC Management Plan. |
Fred Vreeman |
8/26/2016 |
Update or Other Action |
Draft 5 Year Review for LF001, OT001, ST017, TU019, WP007 received for review and comment. The site inspection identified stained soil at WP007 and protruding debris at Sites LF001, OT001,
TU019, and WP007. Recommendation and follow-up action: Soil staining and protruding debris
should be evaluated during annual site inspections to determine if sampling or repairs are required.
LF001
Warning sign at Site LF001 has blown over and is lying on the ground.
Recommendation: Repair warning signage to restore integrity of the Site LF001 LUCs
The 2013 ROD incorrectly listed excavation as a component of the Site LF001 remedy.
Recommendation: Issue a ROD Amendment to clarify that the Site LF001 remedy is LUCs and soil
excavation is not required.
There are no immediate threats from the five sites at Nikolski RRS. The remedies for Sites
OT001, TU019, ST017, and WP007 are being implemented in accordance with their respective
RODs. Long-term, the remedies are protective for the following reasons:
• ICs are in place at Sites OT001, TU019, ST017, and WP007 to limit potential exposures
to onsite contaminants; and
• LTM is performed at Site ST017 to monitor TCE concentrations in the seep area
downgradient of the site.
NOTE: ROD for OT001 (includes TU-019) states-
• Prevent ingestion of soil containing benzo(a)pyrene in excess of 0.4 mg/kg.
• Prevent human contact with underground utilities containing asbestos.
• (TU-019) Prevent ingestion of soil containing RRO in excess of 8300 mg/kg, benzo(a)anthracene in excess of 4.0 mg/kg, benzo(a)pyrene in excess of 0.4 mg/kg, benzo(b)fluoranthene in excess of 4.0 mg/kg, and dibenzo(a,h)anthracene in excess of 0.4 mg/kg.
The USAF certifies that the remedies for Sites OT001, TU019, ST017, and WP007 at Nikolski RRS are protective of human health and the environment and comply with Federal and State requirements that are legally applicable or relevant and appropriate.
The remedy for Site LF001 was selected in accordance with State laws and regulations, as no CERCLA COCs were identified as being released to the environment at the site. The results of this FYR indicate that the Site LF001 remedy is neither currently protective nor protective in the future based on documented deficiencies in the LUCs. Annual inspections are performed at Site
LF001, in accordance with the ROD. However, additional action is required to restore the
integrity of the Site LF001 LUCs.
See site file for additional information. |
Louis Howard |
10/25/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the draft five year review for LF001, OT001, ST017, TU019, WP007. Staff requested the specific public land order be cited and included as an appendix to the document. Staff requested a notice of environmental contamination be filed with DNR Land Records office and to document the last inspection and when the monitoring report was submitted to ADEC for review. Finally, staff requested that several PAHs be reviewed since their cleanup level and toxicity have changed to more stringent levels since the 2011 ROD was signed.
See site file for additional information.
Update: 2019 August-No Final Five Year Review has been submitted since 2016 comments in October 2016. |
Louis Howard |
8/23/2017 |
Document, Report, or Work plan Review - other |
Draft RAO/LTM WP addendum reviewed and commented on by staff. Main comments were to ensure that photos are taken of each source area to document compliance with ICs and site conditions in addition to filling out the land use control form. The full suite of VOCs analyzed with SW8260 shall be reported in preparation of the next five year review which will review remedy protectiveness. PCB field screening will not demonstrate compliance with 1 mg/kg cleanup level regardless of the screening kit/method used. A good correlation between lab results and field screening has not been demonstrated for PCBs in soil.
See site file for additional information., |
Louis Howard |
1/31/2018 |
Update or Other Action |
Draft RAO LTM report received for review and comment. The OT001, TU019, and WP007 sites are all located at the summit of High Hill at the terminus of the access road, and partially overlap one another. Site observations indicated the presence of occasional recreational land users. LUC
signs were installed in highly visible areas near the entrance to the site to limit resource use, excavations, and/or occupancy in the area. No other signs of erosion or deterioration was observed, and vegetation at the site is minimal.
See site file for additional information. |
Louis Howard |
5/9/2019 |
Document, Report, or Work plan Review - other |
Work plan addendum for 2019 Remedial Action Operations, Land Use/Institutional Control Former Nikolski Radio Relay Station Sites LF001, OT001, OT010, SA593, SS003, SS004, ST017, TU019, and WP007 approved by ADEC. |
Louis Howard |
7/15/2019 |
Offsite Soil or Groundwater Disposal Approved |
Staff reviewed and approved disposal of 1,100 cubic yards of PCB contaminated soil at Columbia Ridge Landfill & Chemical Waste Management Landfill in Arlington Oregon. |
Louis Howard |
4/8/2020 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft Technical Project Report for LF001, OT001, OT010, SS006, SS003, SS004, ST017, and WP007 at the Former Nikolski Radio Relay Station dated April 2020. Staff requested a replacement sign be considered for the missing one and the mounting design be redone to withstand the high winds in the area.
See site file for additional information. |
Louis Howard |
9/8/2020 |
Update or Other Action |
DEC approved the "Final Supplemental Work Plan, 2020 Remedial Action Operations, Land Use/Institutional Control, Former Nikolski Radio Relay Station, Alasak, Sites LF001, OT001, SA593, SS003, SS004, TU019, and WP007” dated September 2020. This work plan addresses inspection of the institutional controls/land use controls, as well as groundwater, surface water, pore water, soil, and sediment sampling activities associated with long term monitoring (LTM) at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, TU019, and WP007, located in Nikolski, Alaska. |
Melinda Brunner |
6/1/2021 |
Document, Report, or Work plan Review - other |
Staff provided comments on the 2021 Draft Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period. |
Axl LeVan |
6/24/2021 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments on the "2020 Remedial Action operations, Institutional Control/Land Use Control Report, Nikolski RRS, Alaska, May 2021", received on May 26, 2021. The report presented the results of the 2020 Long Term Maintenance (LTM) performed at the Former Nikolski Radio Relay Station sites LF001, OT001, SA593 (also known as SS006), SS003, SS004, TU019, and WP007. The site visit was conducted in September of 2020 and included groundwater sampling at Site SS004. |
Axl LeVan |
8/17/2021 |
Document, Report, or Work plan Review - other |
DEC approved the "Final 2020 Remedial Action operations, Institutional Control/Land Use Control Report, Nikolski RRS, Alaska, August 2021", received on August 17, 2021. The report presented the results of the 2020 Long Term Maintenance (LTM) performed at the Former Nikolski Radio Relay Station sites LF001, OT001, SA593 (also known as SS006), SS003, SS004, TU019, and WP007. The site visit was conducted in September of 2020 and included groundwater sampling at Site SS004. |
Axl LeVan |
8/20/2021 |
Document, Report, or Work plan Review - other |
Staff approved the 2021 Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, August 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period. |
Axl LeVan |
4/7/2022 |
CERCLA ROD Periodic Review |
DEC reviewed and provided comments on the "Draft Second Five-Year Review for CERCLA SITES WP007 and ST017 and Non-CERCLA Sites LF001, OT001 (incl TU019), Nikolski Radio Relay Station, Alaska, March 2022", received on March 7, 2022. This Five-Year Review (FYR) evaluated whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in the FYR report. Based on review of the report and the first five year review DEC provided comments regarding the current protectiveness statement and the need for a Notice of Activity and Use Limitations (NAULs) in accordance with Chapter 46.04, Article 3 of the Alaska Statutes Uniform Environmental Covenants Act (UECA). |
Axl LeVan |
5/17/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) reviewed and approved the "Final Second Five-Year Review for CERCLA SITES WP007 and ST017 and Non-CERCLA Sites LF001, OT001 (incl TU019), Nikolski Radio Relay Station, Alaska, April 2022" received on May 2, 2022. This Five-Year Review (FYR) evaluates whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in the FYR report.
DEC notes that a timeline for providing a ROD amendment for LF001 was not included in the document and should be completed before the next FYR. Site ST017 will no longer be included in future FYRs as the site has reach cleanup complete status. |
Axl LeVan |
7/21/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of the Draft-Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, June 2022 on June 27, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004. |
Axl LeVan |
9/7/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program approved the Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, August 2022 on August 26, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004.
|
Axl LeVan |
2/8/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "Draft-Final 2022 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, January 2024". The remaining DEC comment was addressed by the most recent update to the document. |
Axl LeVan |
5/21/2024 |
Long Term Monitoring Workplan or Report Review |
DEC reviewed and provided comments on the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, April 2024." This report presents the results of the 2023 Long-Term Management (LTM) performed at the Former Nikolski Radio Relay Station. |
Axl LeVan |
7/15/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, July 2024." based on updates addressing DEC comments on the draft. The report documents long term management at LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007.
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Axl LeVan |