Site Report: Nikolski RRS SS006 Former Drum Storage Area

Site Name:	Nikolski RRS SS006 Former Drum Storage Area
Address:	Between Runway and Beach, Umnak Island, Nikolski, AK 99638
File Number:	2621.38.004
Hazard ID:	135
Status:	Cleanup Complete - Institutional Controls
Staff:	Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude:	52.943229
Longitude:	-168.858546
Horizontal Datum:	WGS84

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

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

This is the former Drum Storage Area at the west end of the gravel runway, about 200 feet from the beach. All the drums (181) were removed and disposed in 1997. Diesel range organics and residual range organics are have been detected in the soil. Formerly known as AOC No. 6 a drum storage area. RRS operated from 1958 to 1977. All buildings and antennas demolished. Above ground POL storage tanks and POL pipeline still in place. Drum storage area and lighting vault are adjacent to airstrip. POL pipeline runs along sea coast and crosses Sheep Creek. A removal of soil took place in 2015 with diesel range organics remaining in the soil that inaccessible below the access road. Groundwater has met all Table C cleanup levels during the 2014, 2015, 2016 monitoring events. Site is assigned cleanup complete with institutional controls. While not listed on the NPL, investigations at Nikolski 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].

Action Information

Action Date	Action	Description	DEC Staff
1/1/1994	CERCLA PA	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. 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.].	Debra Caillouet
11/1/1995	CERCLA PA	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. During the 1995 PAJSI, about 200 drums were counted, most lying on their sides, directly on the ground in and near the drum storage area. Some of the drums were full; some had leaked onto the soil and surface water. Some of the drums still had unbroken seals on the bungs. This area was not sampled in 1995.	Debra Caillouet
6/17/1996	CERCLA SI	DRO concentrations in samples 96NIK024SO, -025SO, & -026SO ranged from 14,000 mg/kg to 21,000 mg/kg Although DRO was detected in the soil samples, the analytical report stated that the results were a quantification of a heavier petroleum product & that the samples did not contain diesel fuel. No VOCs or GRO were detected in the three soil samples. PCBs & pesticides also were not detected in the three samples RCRA metals were detected at the following concentration ranges: arsenic - 7 mg/kg to 9 mg/kg (2015 18 AAC 75 Table B1 MTGW 3.9 mg/kg, direct contact 4.5 mg/kg), barium - 276 mg/kg to 532 mg/kg, cadmium - not detected (ND), chromium - 12 mg/kg to 18 mg/kg; lead - 11 mg/kg to 13 mg/kg; selenium - ND to 1 mg/kg, & silver – ND Based on a factor of 20 times the toxicity characteristic leaching procedure (TCLP) maximum concentration limits for the RCKA metals, the total metals concentrations in the soil samples are within these limits & the soils are not considered to be a toxicity characteristic hazardous waste. (Or, if the total concentration of a chemical is less than 20 times the TCLP regulatory limit, then the sample cannot leach enough of that constituent to fail the TCLP limit, even if all the chemical dissolved into the extraction fluid. This works because the total analysis represents the total amount of chemical present in the sample and if the total concentration is less than 20 times the TCLP regulatory limit of that constituent, then the sample could not possibly “leach” enough of the chemical under TCLP conditions to fail the TCLP limit even if all the chemical dissolved into the extraction fluid.) Analysis of the surface water sample from the pond located within the AOC06 site area (sample 96NIK027WS) detected the presence of VOCs. Benzene, trichloroethylene (TCE), toluene, & xylenes were detected at 11 micrograms per liter (ug/L, equivalent to parts per billion), 6 ug/L, 13 ug/L, & 3 ug/L, respectively. (NOTE TO FILE: 18 AAC 70 TAH cleanup level is 10 ug/L which is exceeded by summing VOCs = 33 ug/L) Benzene & TCE were detected in surface water at concentrations above the drinking water maximum contaminant level (MCL) of 5 lag/1.. The installation of well points between AOC06 & the shoreline is recommended to determine if migration of the contaminants observed at AOC06 is occurring toward the shoreline. Removal of the drums & impacted soil is recommended to eliminate the sources of contamination. The contents of the drums should be sampled to determine appropriate disposal methods. Additional soil sampling will also be necessary to further characterize the soil contaminants & determine appropriate remediation methods. See site file for additional information.	Louis Howard
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
8/12/1997	Document, Report, or Work plan Review - other	Staff provided comment on the WP, FSP & QAPP. QAPP 4.4.2 Discuss what corrective action will be taken to address erratic meter response due to elevated headspace moisture and/or high organic vapor concentrations. 4.5.2 Verify whether soil samples will be collected from each test pit for off-site lab analysis. 4.10.2 Jars used for samples that will methanol preserved are pretared. Affixing labels in the field would invalidate the tare weight. WP 3.2.7.1 Notify & provide results of the lab analysis on the rinsewater to ADEC prior to discharging rinsewater onto surface of the ground. FSP 3.1.3 Text does not state whether additional soil samples will be collected based on the results of field screening for off-site lab analysis. FSP does not tie the field screening to the actual locations of the soil samples. 3.1.3.1 Please ensure that soil samples will be taken at locations of visually observable contamination. See site file for additional information.	Katarina Rutkowski
10/14/1997	Document, Report, or Work plan Review - other	Staff provided comments on the Draft MAP. Table 3-1 IRP Sites and Areas of Concern Summary Please include ADEC, 18 AAC 75 in the column entitled "Regulatory Mechanism" for all areas of concern (AOCs) and IRP sites. For those areas with aboveground or underground storage tanks, the appropriate administrative code is 18 AAC 75 unless the tank(s) are regulated tanks. Section 3.2 Restoration Sites and Areas of Concern Fifth paragraph The Department has requested that additional investigation be conducted at AOC02 to delineate the extent of subsurface sod, sediment and surface water contamination. Please modify text accordingly. Section 4.3 Ongoing and Planned Removal Actions Please modify text to accurately reflect planned activities. For example, the work at the Drum Storage Area took place this year; however, the text indicates that the work will be done in FY99. Also, please add text to reflect that additional investigation will be done at AOC02, AOC07, and AOC08. Please modify text in Section 5.2 to ensure consistency with the changes to this section.	Katarina Rutkowski
12/15/1997	Update or Other Action	Post Action Report received for the AOC-06 Drum Storage Area at Beach Drum Characterization, Removal, Transportation & Disposal. After the contents of the drums were bulked into new drums and the removal action was complete, the contents of Drums 20, 21, 22, and 24 were sampled by the 611 CES/CEVR field personnel on 1 and 2 October 1997. These samples were shipped to QES's Anchorage laboratory for analysis. These samples were collected to evaluate transportation and disposal options. Because the COC record was lost during transportation from Nikolski to Anchorage, the field sampler repackaged and recreated the COC at the Jacobs Anchorage facility prior to relinquishing samples to the laboratory. Ice was not added to the coolers after samples were repackaged. The COC and sample container labels for samples collected 1 and 2 October were completed by the Jacobs project chemist at the QES Anchorage facility on 6 October 1997.	Katarina Rutkowski
3/27/1998	Update or Other Action	IRA Drum Removal & Soil Investigation at AOC06, Drum Storage Area at Beach Sept-Oct 1997 report received. The data in Table 1 indicates that at Nikolski, there is no correlation between TVA readings & DRO contents. A duplicate set of water samples taken from MW8 at the northeastern corner of the fenced area was located close to the half full solvent drum, & yielded exceptionally high levels (10 4 & 14 5 ppm) These two samples also show good data replication for other 8240 compounds, such as 1, 1-Dichloroethene & others, which presumably exist either as weather or manufacturing daughter products. The surface of the drum storage area at Nikolski has been returned to a state of suitable cleanliness The drums & entrained materials have been properly disposed, & two rusted vehicle hulks were also removed to present a clean, empty field Nonetheless, this field is spotted with oily patches, & even more ominously, there are excesses of chlorinated solvents m the groundwater at the south end of the fenced area, taken at MW 8 Even though the area is now physically cleaned, there are further concerns to be addressed as to cleanup requirements for halogenated solvents. See site file for additional information.	Katarina Rutkowski
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 Added to Database	TCE, DRO and RRO.	Former Staff
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	DRO and RRO were detected at concentrations above site regulatory limits in two areas within the fenced area of the site. It is recommended that approximately 80 cubic yards of this POL contaminated soil be removed from the site or other alternatives be further evaluated in the feasibility study. Concentrations of TCE were detected in approximately 400 cubic yards of soil located in the southern portion of the fenced area. It is recommended that this soil be removed from the site or other alternatives be evaluated in the feasibility study. TCE was detected in surface water, a pond on the other side of the road. This will have to be addressed in the feasibility study.	Debra Caillouet
1/11/2002	Site Ranked Using the AHRM	Initial ranking.	Debra Caillouet
1/14/2002	Site Ranked Using the AHRM	Changed the Toxicity Value from 2 for petroleum to 4 for TCE.	Former Staff
1/17/2002	Site Ranked Using the AHRM	Changed Observed Environmental Impacts value from 3 to 0 and changed Surface Water Environments value from 2 to 3.	Former Staff
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.	Debra Caillouet
3/3/2003	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
12/16/2004	Document, Report, or Work plan Review - other	Staff provided comments on the draft PP for AOC-01 dam and pump house foundation, SS-002 former water supply house and aboveground storage tank, SS-005 runway lighting vault building and underground storage tank, SS-006 former drum storage area, AOC-07 construction camp septic tank, AOC-08 composite building septic tank and outfall, AOC-09 two 20,000 gallon underground storage tanks, OT-010 former transfer building and White Alice Arrays. Page 1: The aerial photograph showing the locations of the sites should be modified to show the property boundaries or another graphic showing the property boundaries should be included in the Proposed Plan. This comment is based on past confusion over land ownership around the site. Additionally, a legend should be added to clarify that the sites shown in black text are addressed in the plan and sites shown in white text will be addressed in a subsequent plan. Page 3, under Site Background: The paragraph titled Remedial Investigation summarizes all the sampling conducted at the facility during 2001 and implies it was for these eight sites, whereas, the summary includes sampling at the five other sites that are not included in this proposed plan. The summary should be limited to sampling at the sites included in this Proposed Plan. Page 7, Summary of Site Risks and Cleanup Levels: The first paragraph should be revised to include more detail on the groundwater use determination. The regulations at 18 AAC 75.345(b)(2) provide that a groundwater cleanup level equal to 10 times the cleanup levels in Table C can be approved in consultation with the landowner, the public and appropriate government officials. The Proposed Plan should be used as the vehicle to initiate this consultation. Therefore, this section should explain the criteria in 75.350, how it applies to the site, and that public input is sought prior to approval of the proposed cleanup level. The second sentence should read something like "The Air Force has proposed a groundwater use determination under 18 AAC 75.350 for the former drum disposal area (SS-006) and that cleanup levels ten times the values listed in 18 AAC 75.345, Table C, be applied to the site (see pages 11-12 for details).” Page 11, SS-006 - Former Drum Storage Area: • Please revise the first sentence in the Groundwater Use Determination section to state, "Groundwater beneath the site is not a current, nor does it appear to be a reasonably expected future, source of drinking water.” • The second paragraph states groundwater samples collected showed some evidence of saltwater intrusion. However, the salinity levels were well below those typically used to determine the suitability of groundwater as a drinking water source, thus that statement should be removed unless there is other supporting data. • In the third paragraph please revise the first sentence to read, "In accordance with 18 AAC 75.345(b)(2), the Air Force and DEC are seeking public input on the proposal that groundwater at the site is not a likely future source of drinking water. If approved, then the applicable groundwater cleanup levels beneath the site will be ten times the groundwater cleanup levels listed in Table C." Page 12, SS-006 – Summary of Cleanup Alternatives: • The title for this section is confusing and would be clarified by revising it to “Summary of Cleanup Alternatives Considered (these alternatives were also considered for AOC-09 and OT-010).” • Please note, if alternative cleanup levels are approved based on the "ten times rule", then institutional controls (18 AAC 75.375(a)) need to be implemented to prevent installation of a drinking water wells and to document that soil and water from the site should not be moved off-site without prior DEC approval. The specific Institutional Controls that will be used should be explained in the Preferred Alternative description. Page 13, SS-006 – Preferred Alternative: The first sentence should state "…migration to groundwater of contaminants in soil including diesel range organics…". Also, in the second sentence of the second paragraph, it should state that DEC was notified in 2001, rather than in 1991, of the additional drums being placed on-site.	Louis Howard
1/18/2005	Update or Other Action	File number issued 2621.38.004	Aggie Blandford
5/29/2006	Document, Report, or Work plan Review - other	Staff provided comments regarding State of AK requirements for Proposed Plans and site specific comments. SS-006 Former Drum Storage Area – The remedy proposed is to remove the soil contaminated with DRO above 2300 mg/kg and TCE above 0.2 mg/kg based on 18 AAC 75.345(2) ten times the migration to groundwater pathway, and RRO above 8300 mg/kg 18 AAC 75.341 Table B2, ingestion pathway and applicable institutional controls as required by 18 AAC 75.375 (a) will be implemented. Soil will be thermally treated off-site unless on-site thermal treatment is more cost effective.	Louis Howard
11/8/2007	Exposure Tracking Model Ranking		Debra Caillouet
7/23/2012	Document, Report, or Work plan Review - other	Comment sent to the AF on the Tech Memo: Evaluation of Remediation Alternatives for Sites SS003, SS004 and SS006 at Nikolski Radio Relay Station (Final) 19 July 2012	Debra Caillouet
11/15/2012	Document, Report, or Work plan Review - other	Evaluation of Remedial Alternatives for Sites SS003, SS004, and SS006 at Nikolski Radio Relay Station, Revised Final, November 2012	Debra Caillouet
3/18/2013	Document, Report, or Work plan Review - other	Comment was sent to the AF on the draft ROD for SS006. 1.4 The remedy should not specify the wells to be sampled and it should include monitoring for the TCE breakdown products. It should also state the groundwater plume will continue until it is at a steady state or decreasing and the contaminant concentrations are decreasing for three consecutive events. 2.9 The inclusion of the groundwater monitoring to assure the plume is steady state or decreasing is needed. 2.12.1 The last paragraph should read: The selected remedial alternative of Excavation and Offsite Disposal with ICs and groundwater monitoring is the most readily implementable approach to reduce the risk posed by contaminated soils, and therefore, provides the best balance of tradeoffs with respect to balancing and modifying criteria. Given the remote location of the site, excavation and offsite transport for disposal at a permitted facility provides superior flexibility, feasibility, and short-term effectiveness relative to in-situ treatment. The No Action alternative was rejected because it failed to meet the threshold criteria of protection of human health and the environment, and compliance with ARARs. Due to the length of time associated with I Cs as a stand-alone remedy, the costs would be higher than Excavation and Offsite Disposal activities. Excavation and Offsite Disposal has a better than average rating for long-term effectiveness and permanence, and implementability (Table 2-1 ). See site file for additional information.	Debra Caillouet
5/15/2013	CERCLA ROD Approved	Record of Decision signed by John Halverson (ADEC). By signing this declaration, ADEC concurs that proper implementation of the selected remedy for SS006 will comply with state environmental laws. This decision will be reviewed and may be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk the human health or the environment. The chemicals of concern (COCs) are diesel range organics (DRO) and residual range organics (RRO), commingled with trichloroethylene (TCE), which have been detected at this site above 18 AAC 75 soil cleanup levels. Pursuant to 18 AAC 75.350, ADEC determined during the 2001 Remedial Investigation (RI) that groundwater is not considered a drinking water source at SS006. Residual COCs in groundwater following the excavation of contaminated soil and during post remediation monitoring will require land use controls through the establishment of institutional controls (ICs) to limit the use of the site. The CERCLA-selected remedy for SS006 is Excavation and Offsite Disposal of contaminated soil in a permitted disposal facility. As part of this remedy, post remediation monitoring of monitoring wells would continue once a year until the concentration of TCE and its breakdown products in the groundwater plume is at a steady state, or decreasing, and the contaminant concentrations are decreasing for three consecutive monitoring events. See site file for additional information.	Debra Caillouet
5/15/2013	Update or Other Action	Upon completion of the selected remedy, Nikolski RRS ERP Site SS006 will be in compliance with CERCLA and the State of Alaska environmental statutes. No contamination above ADEC Method Two soil cleanup levels identified in 18 AAC 75.341 will remain onsite. Contamination above ADEC Table C groundwater cleanup levels will remain onsite. Refer to Tables 1-1 and 1-2 for COCs and concentrations. However, the ICs will limit human exposure to contaminants onsite and promote the safety of human health and the environment. The ICs will become effective immediately upon implementation of the ICs. The location of the ICs will be documented according to surveys already completed and will be recorded in the Anchorage Recorder’s office under the Aleutian Islands Recording District. ICs will be used to prevent residential use and restrict surface excavation activities in Tract 39A, which covers approximately 2.44 acres. The Air Force will require all surface excavation or digging activities within Tract 39A to be subject to ADEC approval, per State of Alaska regulations (18 AAC 75.325(i), 2008). The Air Force will conduct 5-year reviews as required by CERCLA Section 121(c) since hazardous substances may remain onsite at levels above the ADEC maximum contaminant levels (MCLs) for drinking water (AAC, Title 18, Part 80.300(b)(2)(B) and ADEC Method Two soil cleanup levels (18 AAC 75)). These 5-year reviews will include a report on the effectiveness of the ICs. The ICs will remain in effect indefinitely or until such time as the COCs are below applicable ADEC cleanup levels. COCs for SS006 are TCE, DRO, and RRO. The Air Force, as the responsible entity, will implement, monitor, and maintain the ICs in accordance with CERCLA and NCP regulations. The Air Force will also provide annual monitoring reports to ADEC. If the site remedy is found to be deficient during an inspection, ADEC will be contacted and 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 and activity restrictions subject to ICs. There are currently no tenants, contractors, or occupants within the property subjected to ICs.	John Halverson
5/15/2013	350 Determination	Record of Decision (ROD) memorialized ADEC determination for groundwater not to be considered a drinking water source per 18 AAC 75.350. A groundwater use determination has been made for SS006, per 18 AAC 75.350 (Appendix B of the ROD). The major permanent surface water feature in the vicinity of SS006 is Nikolski Bay. Data collected in the 2001 Remedial Investigation indicates that Nikolski Bay is not impacted by site contaminants and the groundwater use determination concluded that the site contamination poses no threat to current or reasonably expected future sources of drinking water. Since the final determination of the proposed action specified in the 2012 Proposed Plan for SS006, requirements for institutional controls for groundwater and CERCLA 5-year reviews have been added to the site remedy of Excavation and Offsite Disposal. See site file for additional information.	John Halverson
12/11/2014	Document, Report, or Work plan Review - other	Draft Remedial Action Work Plan for Remedy Implementation at the Former Nikolski Radio Relay Station, Alaska December 2014, The plan is deficient in many details and requires significant revision. A complete revised DRAFT document is required.	Debra Caillouet
5/4/2015	Document, Report, or Work plan Review - other	Staff commented on the Draft-Final RA WP for Remedy Implementation at SS003, SS004, SS006 and OT010. Page 3-6 Table 3-1 Review and correct. Holding time for VOCs is not 180 days. There are six methods in EPA 540-R-09-03 Jan 2011, Appendix B for low level VOCs in soil, the method you have chosen has this caveat This option is NOT a Preferred Option for the CLP because: NaHS0-1 preservation creates low pH conditions that will cause the destruction of certain CLP target analytes (e.g., vinyl chloride, trichloroethene, trichlorofluoromethane, cis- and trans-1,3-dichloropropene). As vinyl chloride and trichloroethene are two of the COCs please chose one of the three recommended methods. VOC water samples are not collected in 1 liter bottles nor are TLC caps used. This also has to be corrected in the UFP-QAPP. Provide method for RRO in water. Table 4-2 The sub-sites/areas that are shown in this table are not identified in the figures. The RODs do not include sub-sites. Provide figures with the sub-sites identified, once that occurs ADEC may or may not concur with the analytes for each area. Duplicates are to be collected at a rate of 10% minimum. 24 is less than 10% of 245. Verify all and correct, as there are others also shown at less than 10%. At SS004 confirmation sampling is to include PAH. Long-Term monitoring at SS006 is to include GRO and DRO. Page 4-1 4.3 The volumes in this section, 39 cy TCE and 186 cy DRO are not in the ROD. The ROD states "estimated volume of soil to be excavated at SS006 is approximately 200 cubic yards". See comment 7, sub-sites are not shown on Figure 4-4. Also note that sample SS6-HA31 has TCE at 0.484 mg/kg which is above the cleanup level but the value is not bolded on Figure 4-4. UFP-QAPP Page 11 Worksheet 6 should be Communications Pathways. Worksheet 10 is the Conceptual Site Model. The information in the table does not apply to either. Please review and fix. The rest of this UFP-QAPP, is not being reviewed. Please do an internal review of this document to assure that the contents of each worksheet is what is explained in the Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans Optimized UFP-QAPP Worksheets March 2012. Please note that the Executive Summary of said document includes this: ... "the information contained in the worksheets continues to capture the elements that would comprise related project-planning documents, such as a Sampling and Analysis Plan (SAP), Work Plan (WP), and Field Sampling Plan (FSP)" and" ... the final, approved QAPP is designed to be a stand-alone document containing all specifications and procedures necessary for project personnel to carry out their assigned responsibilities. For example, the field team should be able to rely on the QAPP for complete sampling instructions, including how to sample, where to sample, how many samples to collect, the types of bottles, preservatives, related QC, etc. If the approved QAPP provides insufficient procedures to carry out all tasks, then SOP's must be attached to the QAPP. If required elements are contained in other documents, those documents may be referenced; however the documents must be available to all personnel responsible for reviewing and implementing the QAPP" ADEC can review this document with the separate Work Plan and Waste Management Plan Quality Control Plan Page 5-2 5.7 The UFP-QAPP has many obvious omissions/errors. Please explain what type of review occurred and why future QA/QC on the actual performance of the work should be trusted. See site file for additional information.	Debra Caillouet
11/30/2015	Meeting or Teleconference Held	Meeting with MWH scoping 5 year review for Nikolski sites. 5YR under CERCLA will not include this site as remedy was implemented in 2015 and cleanup report is not final.	Fred Vreeman
4/1/2016	Update or Other Action	Draft-Final Long-term Groundwater Monitoring Report received. Well point installation, development, and groundwater monitoring activities at Site SS006 were conducted from 26 through 28 June 2015. Groundwater samples were collected from well points WP04R and WP05R (corresponding to the former locations of SS6-MW04 and SS6-MW05, respectively). All activities were conducted in accordance with the Final 2015 Remedial Action Work Plan. The June 2015 monitoring event is the first which resulted in all contaminants of concern being found in concentrations below groundwater cleanup levels for the Site SS006. Annual groundwater monitoring will continue until concentrations of all contaminants of concern are shown to be steady state, or shrinking and contaminant concentrations are decreasing, for three consecutive monitoring events in accordance with the Nikolski RRS Record of Decision for Site SS006.	Louis Howard
12/7/2016	Document, Report, or Work plan Review - other	Comments provided for on the LTM GW report for SS006. SS004 was not able to be sampled since removal actions were taking place. Main comments were regarding the possibility of drafting an explanation of significant differences to take advantage of the less stringent cleanup level in 18 AAC 75 for TCE set at 3.5 mg/kg instead of the 0.42 mg/kg cleanup level set in the Record of Decision in 2013. See site file for additional information.	Louis Howard
2/6/2017	Update or Other Action	2016 Long-term GW Monitoring report received for review and comment. The purpose of this Long-term Groundwater Monitoring Report is to summarize analytical results for groundwater samples collected during the July/August 2016 Monitoring Event at Nikolski Radio Relay Station (RRS). No groundwater cleanup level (November 6, 2016) exceedances and no ROD exceedances. See site file for additional information.	Louis Howard
2/6/2017	Update or Other Action	ICs control report received for review and comment. ICs at Site SS004 (Petroleum, Oil, and Lubricants [POL]Tank Area) and Site SS006 (Former Drum Storage Area) are part of the selected remedy for the Nikolski RRS Record of Decision (ROD) for each of the respective sites (USAF, 2013a,b). As a result of the findings of the 2015 Remedy Implementation, Site SS003 (POL Pipeline) was added to the 2016 IC inspection. ICs at SS004, SS006, and SS003 consist of the following: 1. Land Use Controls for each site will be incorporated into the 611th Civil Engineering Squadron Land Use Control Management Plan. 2. A Notice of Environmental Contamination will be placed in the Alaska Department of Natural Resources’ (ADNR’s) land records. 3. Warning signs placed at the boundary of each site will provide contact information for Land Use Control Management. See site file for additional information.	Louis Howard
1/31/2018	Update or Other Action	Draft RAO/LTM report received for review and comment. Site observations at SS006 indicated the presence of occasional recreational land users, cattle, and wildlife. Several items were staged at the site for storage including a locked 20-ft storage container (connex), several fuel storage tanks, multiple 55-gallon drums, and leftover supersacks from the 2015 remedial activities. The fuel storage tanks appear to be in decent conditions with some rusting occurring. The tanks appear to be mostly empty with signs of residual fuel remaining. The steel 55-gallon drums are starting to degrade and are rusted and pitted on the tops where they have been holding water. The majority of the drums appear empty with residual gasoline or oil products remaining. However, a few of the drums were partially full of product. The field staff picked up the empty drums that were blown around the site and staged them next to the other drums by the storage container. It is unknown what is located within the storage container staged at the site. Three LUC warning signs that were installed in 2015 remained visible at the site and in decent condition, although leaning slightly. Revegetation efforts have been successful at the site. No other signs of erosion, or standing water were observed. A review of the analytical results from the past three monitoring events indicates that the selected remedy of excavation and offsite disposal and periodic groundwater monitoring was effective in reducing the risk posed by contaminated soils. Due to the fact that groundwater contaminant concentrations have been documented to be below groundwater cleanup levels for three consecutive events, it is recommended that the ERP site SS006 be considered compliant with CERCLA and State of Alaska environmental statutes. A statutory review is planned to be conducted in 2018 to ensure the remedy selected continues to be protective of human health and the environment. See site file for additional information.	Louis Howard
3/7/2018	Document, Report, or Work plan Review - other	Draft Remedial Action – Operations/LTM Report for Nikolski RRS reviewed. Staff requested the removal of the following items from the site or securing them so they do not “blow around” the site as observed by the field team: several fuel storage tanks, multiple 55 gallon drums, and leftover supersacks. See site file for additional information.	Louis Howard
5/23/2018	Cleanup Complete Determination Issued	Based on the information provided to date, it has been determined by ADEC, in accordance with 18 AAC 75.325 – 390 site cleanup rules, that the contaminant concentrations remaining at SS006 does not pose an unacceptable risk to human health or the environment. No further remedial action will be required by ADEC at the Former Drum Storage Area as long as the institutional controls are maintained, effective and no new information becomes available that indicates residual contamination poses an unacceptable risk to human health, safety, welfare, or the environment. DRO and RRO were detected in soil at SS006 above the ingestion cleanup level for DRO and RRO (Table B2 Method Two, Over 40 Inch Zone 18 AAC 75, as amended November 7, 2017). The Record of Decision documented that a groundwater use determination has been made for SS006, per 18 AAC 75.350. Land use controls have been established by the USAF in 2016 to limit potential future exposure and risk to human health or the environment at SS006 See site file for additional information.	Louis Howard
5/23/2018	Institutional Control Record Established	Institutional Controls established and entered into the database.	Louis Howard
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
11/10/2021	Update or Other Action	DEC reviewed overdue tasks and determined that the 2020 Remedial Action Operations, Institutional Control/Land Use Control Report, August 2021 provided adequate information regarding the maintenance of ICs at Site SS006.	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

Action Date

Action

Description

DEC Staff

1/1/1994

CERCLA PA

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. 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.].

Debra Caillouet

11/1/1995

CERCLA PA

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. During the 1995 PAJSI, about 200 drums were counted, most lying on their sides, directly on the ground in and near the drum storage area. Some of the drums were full; some had leaked onto the soil and surface water. Some of the drums still had unbroken seals on the bungs. This area was not sampled in 1995.

Debra Caillouet

6/17/1996

CERCLA SI

DRO concentrations in samples 96NIK024SO, -025SO, & -026SO ranged from 14,000 mg/kg to 21,000 mg/kg Although DRO was detected in the soil samples, the analytical report stated that the results were a quantification of a heavier petroleum product & that the samples did not contain diesel fuel. No VOCs or GRO were detected in the three soil samples. PCBs & pesticides also were not detected in the three samples RCRA metals were detected at the following concentration ranges: arsenic - 7 mg/kg to 9 mg/kg (2015 18 AAC 75 Table B1 MTGW 3.9 mg/kg, direct contact 4.5 mg/kg), barium - 276 mg/kg to 532 mg/kg, cadmium - not detected (ND), chromium - 12 mg/kg to 18 mg/kg; lead - 11 mg/kg to 13 mg/kg; selenium - ND to 1 mg/kg, & silver – ND Based on a factor of 20 times the toxicity characteristic leaching procedure (TCLP) maximum concentration limits for the RCKA metals, the total metals concentrations in the soil samples are within these limits & the soils are not considered to be a toxicity characteristic hazardous waste. (Or, if the total concentration of a chemical is less than 20 times the TCLP regulatory limit, then the sample cannot leach enough of that constituent to fail the TCLP limit, even if all the chemical dissolved into the extraction fluid. This works because the total analysis represents the total amount of chemical present in the sample and if the total concentration is less than 20 times the TCLP regulatory limit of that constituent, then the sample could not possibly “leach” enough of the chemical under TCLP conditions to fail the TCLP limit even if all the chemical dissolved into the extraction fluid.) Analysis of the surface water sample from the pond located within the AOC06 site area (sample 96NIK027WS) detected the presence of VOCs. Benzene, trichloroethylene (TCE), toluene, & xylenes were detected at 11 micrograms per liter (ug/L, equivalent to parts per billion), 6 ug/L, 13 ug/L, & 3 ug/L, respectively. (NOTE TO FILE: 18 AAC 70 TAH cleanup level is 10 ug/L which is exceeded by summing VOCs = 33 ug/L) Benzene & TCE were detected in surface water at concentrations above the drinking water maximum contaminant level (MCL) of 5 lag/1.. The installation of well points between AOC06 & the shoreline is recommended to determine if migration of the contaminants observed at AOC06 is occurring toward the shoreline. Removal of the drums & impacted soil is recommended to eliminate the sources of contamination. The contents of the drums should be sampled to determine appropriate disposal methods. Additional soil sampling will also be necessary to further characterize the soil contaminants & determine appropriate remediation methods. See site file for additional information.

Louis Howard

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

8/12/1997

Document, Report, or Work plan Review - other

Staff provided comment on the WP, FSP & QAPP. QAPP 4.4.2 Discuss what corrective action will be taken to address erratic meter response due to elevated headspace moisture and/or high organic vapor concentrations. 4.5.2 Verify whether soil samples will be collected from each test pit for off-site lab analysis. 4.10.2 Jars used for samples that will methanol preserved are pretared. Affixing labels in the field would invalidate the tare weight. WP 3.2.7.1 Notify & provide results of the lab analysis on the rinsewater to ADEC prior to discharging rinsewater onto surface of the ground. FSP 3.1.3 Text does not state whether additional soil samples will be collected based on the results of field screening for off-site lab analysis. FSP does not tie the field screening to the actual locations of the soil samples. 3.1.3.1 Please ensure that soil samples will be taken at locations of visually observable contamination. See site file for additional information.

Katarina Rutkowski

10/14/1997

Document, Report, or Work plan Review - other

Staff provided comments on the Draft MAP. Table 3-1 IRP Sites and Areas of Concern Summary Please include ADEC, 18 AAC 75 in the column entitled "Regulatory Mechanism" for all areas of concern (AOCs) and IRP sites. For those areas with aboveground or underground storage tanks, the appropriate administrative code is 18 AAC 75 unless the tank(s) are regulated tanks. Section 3.2 Restoration Sites and Areas of Concern Fifth paragraph The Department has requested that additional investigation be conducted at AOC02 to delineate the extent of subsurface sod, sediment and surface water contamination. Please modify text accordingly. Section 4.3 Ongoing and Planned Removal Actions Please modify text to accurately reflect planned activities. For example, the work at the Drum Storage Area took place this year; however, the text indicates that the work will be done in FY99. Also, please add text to reflect that additional investigation will be done at AOC02, AOC07, and AOC08. Please modify text in Section 5.2 to ensure consistency with the changes to this section.

Katarina Rutkowski

12/15/1997

Update or Other Action

Post Action Report received for the AOC-06 Drum Storage Area at Beach Drum Characterization, Removal, Transportation & Disposal. After the contents of the drums were bulked into new drums and the removal action was complete, the contents of Drums 20, 21, 22, and 24 were sampled by the 611 CES/CEVR field personnel on 1 and 2 October 1997. These samples were shipped to QES's Anchorage laboratory for analysis. These samples were collected to evaluate transportation and disposal options. Because the COC record was lost during transportation from Nikolski to Anchorage, the field sampler repackaged and recreated the COC at the Jacobs Anchorage facility prior to relinquishing samples to the laboratory. Ice was not added to the coolers after samples were repackaged. The COC and sample container labels for samples collected 1 and 2 October were completed by the Jacobs project chemist at the QES Anchorage facility on 6 October 1997.

Katarina Rutkowski

3/27/1998

Update or Other Action

IRA Drum Removal & Soil Investigation at AOC06, Drum Storage Area at Beach Sept-Oct 1997 report received. The data in Table 1 indicates that at Nikolski, there is no correlation between TVA readings & DRO contents. A duplicate set of water samples taken from MW8 at the northeastern corner of the fenced area was located close to the half full solvent drum, & yielded exceptionally high levels (10 4 & 14 5 ppm) These two samples also show good data replication for other 8240 compounds, such as 1, 1-Dichloroethene & others, which presumably exist either as weather or manufacturing daughter products. The surface of the drum storage area at Nikolski has been returned to a state of suitable cleanliness The drums & entrained materials have been properly disposed, & two rusted vehicle hulks were also removed to present a clean, empty field Nonetheless, this field is spotted with oily patches, & even more ominously, there are excesses of chlorinated solvents m the groundwater at the south end of the fenced area, taken at MW 8 Even though the area is now physically cleaned, there are further concerns to be addressed as to cleanup requirements for halogenated solvents. See site file for additional information.

Katarina Rutkowski

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 Added to Database

TCE, DRO and RRO.

Former Staff

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

DRO and RRO were detected at concentrations above site regulatory limits in two areas within the fenced area of the site. It is recommended that approximately 80 cubic yards of this POL contaminated soil be removed from the site or other alternatives be further evaluated in the feasibility study. Concentrations of TCE were detected in approximately 400 cubic yards of soil located in the southern portion of the fenced area. It is recommended that this soil be removed from the site or other alternatives be evaluated in the feasibility study. TCE was detected in surface water, a pond on the other side of the road. This will have to be addressed in the feasibility study.

Debra Caillouet

1/11/2002

Site Ranked Using the AHRM

Initial ranking.

Debra Caillouet

1/14/2002

Site Ranked Using the AHRM

Changed the Toxicity Value from 2 for petroleum to 4 for TCE.

Former Staff

1/17/2002

Site Ranked Using the AHRM

Changed Observed Environmental Impacts value from 3 to 0 and changed Surface Water Environments value from 2 to 3.

Former Staff

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.

Debra Caillouet

3/3/2003

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

12/16/2004

Document, Report, or Work plan Review - other

Staff provided comments on the draft PP for AOC-01 dam and pump house foundation, SS-002 former water supply house and aboveground storage tank, SS-005 runway lighting vault building and underground storage tank, SS-006 former drum storage area, AOC-07 construction camp septic tank, AOC-08 composite building septic tank and outfall, AOC-09 two 20,000 gallon underground storage tanks, OT-010 former transfer building and White Alice Arrays. Page 1: The aerial photograph showing the locations of the sites should be modified to show the property boundaries or another graphic showing the property boundaries should be included in the Proposed Plan. This comment is based on past confusion over land ownership around the site. Additionally, a legend should be added to clarify that the sites shown in black text are addressed in the plan and sites shown in white text will be addressed in a subsequent plan. Page 3, under Site Background: The paragraph titled Remedial Investigation summarizes all the sampling conducted at the facility during 2001 and implies it was for these eight sites, whereas, the summary includes sampling at the five other sites that are not included in this proposed plan. The summary should be limited to sampling at the sites included in this Proposed Plan. Page 7, Summary of Site Risks and Cleanup Levels: The first paragraph should be revised to include more detail on the groundwater use determination. The regulations at 18 AAC 75.345(b)(2) provide that a groundwater cleanup level equal to 10 times the cleanup levels in Table C can be approved in consultation with the landowner, the public and appropriate government officials. The Proposed Plan should be used as the vehicle to initiate this consultation. Therefore, this section should explain the criteria in 75.350, how it applies to the site, and that public input is sought prior to approval of the proposed cleanup level. The second sentence should read something like "The Air Force has proposed a groundwater use determination under 18 AAC 75.350 for the former drum disposal area (SS-006) and that cleanup levels ten times the values listed in 18 AAC 75.345, Table C, be applied to the site (see pages 11-12 for details).” Page 11, SS-006 - Former Drum Storage Area: • Please revise the first sentence in the Groundwater Use Determination section to state, "Groundwater beneath the site is not a current, nor does it appear to be a reasonably expected future, source of drinking water.” • The second paragraph states groundwater samples collected showed some evidence of saltwater intrusion. However, the salinity levels were well below those typically used to determine the suitability of groundwater as a drinking water source, thus that statement should be removed unless there is other supporting data. • In the third paragraph please revise the first sentence to read, "In accordance with 18 AAC 75.345(b)(2), the Air Force and DEC are seeking public input on the proposal that groundwater at the site is not a likely future source of drinking water. If approved, then the applicable groundwater cleanup levels beneath the site will be ten times the groundwater cleanup levels listed in Table C." Page 12, SS-006 – Summary of Cleanup Alternatives: • The title for this section is confusing and would be clarified by revising it to “Summary of Cleanup Alternatives Considered (these alternatives were also considered for AOC-09 and OT-010).” • Please note, if alternative cleanup levels are approved based on the "ten times rule", then institutional controls (18 AAC 75.375(a)) need to be implemented to prevent installation of a drinking water wells and to document that soil and water from the site should not be moved off-site without prior DEC approval. The specific Institutional Controls that will be used should be explained in the Preferred Alternative description. Page 13, SS-006 – Preferred Alternative: The first sentence should state "…migration to groundwater of contaminants in soil including diesel range organics…". Also, in the second sentence of the second paragraph, it should state that DEC was notified in 2001, rather than in 1991, of the additional drums being placed on-site.

Louis Howard

1/18/2005

Update or Other Action

File number issued 2621.38.004

Aggie Blandford

5/29/2006

Document, Report, or Work plan Review - other

Staff provided comments regarding State of AK requirements for Proposed Plans and site specific comments. SS-006 Former Drum Storage Area – The remedy proposed is to remove the soil contaminated with DRO above 2300 mg/kg and TCE above 0.2 mg/kg based on 18 AAC 75.345(2) ten times the migration to groundwater pathway, and RRO above 8300 mg/kg 18 AAC 75.341 Table B2, ingestion pathway and applicable institutional controls as required by 18 AAC 75.375 (a) will be implemented. Soil will be thermally treated off-site unless on-site thermal treatment is more cost effective.

Louis Howard

11/8/2007

Exposure Tracking Model Ranking

Debra Caillouet

7/23/2012

Document, Report, or Work plan Review - other

Comment sent to the AF on the Tech Memo: Evaluation of Remediation Alternatives for Sites SS003, SS004 and SS006 at Nikolski Radio Relay Station (Final) 19 July 2012

Debra Caillouet

11/15/2012

Document, Report, or Work plan Review - other

Evaluation of Remedial Alternatives for Sites SS003, SS004, and SS006 at Nikolski Radio Relay Station, Revised Final, November 2012

Debra Caillouet

3/18/2013

Document, Report, or Work plan Review - other

Comment was sent to the AF on the draft ROD for SS006. 1.4 The remedy should not specify the wells to be sampled and it should include monitoring for the TCE breakdown products. It should also state the groundwater plume will continue until it is at a steady state or decreasing and the contaminant concentrations are decreasing for three consecutive events. 2.9 The inclusion of the groundwater monitoring to assure the plume is steady state or decreasing is needed. 2.12.1 The last paragraph should read: The selected remedial alternative of Excavation and Offsite Disposal with ICs and groundwater monitoring is the most readily implementable approach to reduce the risk posed by contaminated soils, and therefore, provides the best balance of tradeoffs with respect to balancing and modifying criteria. Given the remote location of the site, excavation and offsite transport for disposal at a permitted facility provides superior flexibility, feasibility, and short-term effectiveness relative to in-situ treatment. The No Action alternative was rejected because it failed to meet the threshold criteria of protection of human health and the environment, and compliance with ARARs. Due to the length of time associated with I Cs as a stand-alone remedy, the costs would be higher than Excavation and Offsite Disposal activities. Excavation and Offsite Disposal has a better than average rating for long-term effectiveness and permanence, and implementability (Table 2-1 ). See site file for additional information.

Debra Caillouet

5/15/2013

CERCLA ROD Approved

Record of Decision signed by John Halverson (ADEC). By signing this declaration, ADEC concurs that proper implementation of the selected remedy for SS006 will comply with state environmental laws. This decision will be reviewed and may be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk the human health or the environment. The chemicals of concern (COCs) are diesel range organics (DRO) and residual range organics (RRO), commingled with trichloroethylene (TCE), which have been detected at this site above 18 AAC 75 soil cleanup levels. Pursuant to 18 AAC 75.350, ADEC determined during the 2001 Remedial Investigation (RI) that groundwater is not considered a drinking water source at SS006. Residual COCs in groundwater following the excavation of contaminated soil and during post remediation monitoring will require land use controls through the establishment of institutional controls (ICs) to limit the use of the site. The CERCLA-selected remedy for SS006 is Excavation and Offsite Disposal of contaminated soil in a permitted disposal facility. As part of this remedy, post remediation monitoring of monitoring wells would continue once a year until the concentration of TCE and its breakdown products in the groundwater plume is at a steady state, or decreasing, and the contaminant concentrations are decreasing for three consecutive monitoring events. See site file for additional information.

Debra Caillouet

5/15/2013

Update or Other Action

Upon completion of the selected remedy, Nikolski RRS ERP Site SS006 will be in compliance with CERCLA and the State of Alaska environmental statutes. No contamination above ADEC Method Two soil cleanup levels identified in 18 AAC 75.341 will remain onsite. Contamination above ADEC Table C groundwater cleanup levels will remain onsite. Refer to Tables 1-1 and 1-2 for COCs and concentrations. However, the ICs will limit human exposure to contaminants onsite and promote the safety of human health and the environment. The ICs will become effective immediately upon implementation of the ICs. The location of the ICs will be documented according to surveys already completed and will be recorded in the Anchorage Recorder’s office under the Aleutian Islands Recording District. ICs will be used to prevent residential use and restrict surface excavation activities in Tract 39A, which covers approximately 2.44 acres. The Air Force will require all surface excavation or digging activities within Tract 39A to be subject to ADEC approval, per State of Alaska regulations (18 AAC 75.325(i), 2008). The Air Force will conduct 5-year reviews as required by CERCLA Section 121(c) since hazardous substances may remain onsite at levels above the ADEC maximum contaminant levels (MCLs) for drinking water (AAC, Title 18, Part 80.300(b)(2)(B) and ADEC Method Two soil cleanup levels (18 AAC 75)). These 5-year reviews will include a report on the effectiveness of the ICs. The ICs will remain in effect indefinitely or until such time as the COCs are below applicable ADEC cleanup levels. COCs for SS006 are TCE, DRO, and RRO. The Air Force, as the responsible entity, will implement, monitor, and maintain the ICs in accordance with CERCLA and NCP regulations. The Air Force will also provide annual monitoring reports to ADEC. If the site remedy is found to be deficient during an inspection, ADEC will be contacted and 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 and activity restrictions subject to ICs. There are currently no tenants, contractors, or occupants within the property subjected to ICs.

John Halverson

5/15/2013

350 Determination

Record of Decision (ROD) memorialized ADEC determination for groundwater not to be considered a drinking water source per 18 AAC 75.350. A groundwater use determination has been made for SS006, per 18 AAC 75.350 (Appendix B of the ROD). The major permanent surface water feature in the vicinity of SS006 is Nikolski Bay. Data collected in the 2001 Remedial Investigation indicates that Nikolski Bay is not impacted by site contaminants and the groundwater use determination concluded that the site contamination poses no threat to current or reasonably expected future sources of drinking water. Since the final determination of the proposed action specified in the 2012 Proposed Plan for SS006, requirements for institutional controls for groundwater and CERCLA 5-year reviews have been added to the site remedy of Excavation and Offsite Disposal. See site file for additional information.

John Halverson

12/11/2014

Document, Report, or Work plan Review - other

Draft Remedial Action Work Plan for Remedy Implementation at the Former Nikolski Radio Relay Station, Alaska December 2014, The plan is deficient in many details and requires significant revision. A complete revised DRAFT document is required.

Debra Caillouet

5/4/2015

Document, Report, or Work plan Review - other

Staff commented on the Draft-Final RA WP for Remedy Implementation at SS003, SS004, SS006 and OT010. Page 3-6 Table 3-1 Review and correct. Holding time for VOCs is not 180 days. There are six methods in EPA 540-R-09-03 Jan 2011, Appendix B for low level VOCs in soil, the method you have chosen has this caveat This option is NOT a Preferred Option for the CLP because: NaHS0-1 preservation creates low pH conditions that will cause the destruction of certain CLP target analytes (e.g., vinyl chloride, trichloroethene, trichlorofluoromethane, cis- and trans-1,3-dichloropropene). As vinyl chloride and trichloroethene are two of the COCs please chose one of the three recommended methods. VOC water samples are not collected in 1 liter bottles nor are TLC caps used. This also has to be corrected in the UFP-QAPP. Provide method for RRO in water. Table 4-2 The sub-sites/areas that are shown in this table are not identified in the figures. The RODs do not include sub-sites. Provide figures with the sub-sites identified, once that occurs ADEC may or may not concur with the analytes for each area. Duplicates are to be collected at a rate of 10% minimum. 24 is less than 10% of 245. Verify all and correct, as there are others also shown at less than 10%. At SS004 confirmation sampling is to include PAH. Long-Term monitoring at SS006 is to include GRO and DRO. Page 4-1 4.3 The volumes in this section, 39 cy TCE and 186 cy DRO are not in the ROD. The ROD states "estimated volume of soil to be excavated at SS006 is approximately 200 cubic yards". See comment 7, sub-sites are not shown on Figure 4-4. Also note that sample SS6-HA31 has TCE at 0.484 mg/kg which is above the cleanup level but the value is not bolded on Figure 4-4. UFP-QAPP Page 11 Worksheet 6 should be Communications Pathways. Worksheet 10 is the Conceptual Site Model. The information in the table does not apply to either. Please review and fix. The rest of this UFP-QAPP, is not being reviewed. Please do an internal review of this document to assure that the contents of each worksheet is what is explained in the Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans Optimized UFP-QAPP Worksheets March 2012. Please note that the Executive Summary of said document includes this: ... "the information contained in the worksheets continues to capture the elements that would comprise related project-planning documents, such as a Sampling and Analysis Plan (SAP), Work Plan (WP), and Field Sampling Plan (FSP)" and" ... the final, approved QAPP is designed to be a stand-alone document containing all specifications and procedures necessary for project personnel to carry out their assigned responsibilities. For example, the field team should be able to rely on the QAPP for complete sampling instructions, including how to sample, where to sample, how many samples to collect, the types of bottles, preservatives, related QC, etc. If the approved QAPP provides insufficient procedures to carry out all tasks, then SOP's must be attached to the QAPP. If required elements are contained in other documents, those documents may be referenced; however the documents must be available to all personnel responsible for reviewing and implementing the QAPP" ADEC can review this document with the separate Work Plan and Waste Management Plan Quality Control Plan Page 5-2 5.7 The UFP-QAPP has many obvious omissions/errors. Please explain what type of review occurred and why future QA/QC on the actual performance of the work should be trusted. See site file for additional information.

Debra Caillouet

11/30/2015

Meeting or Teleconference Held

Meeting with MWH scoping 5 year review for Nikolski sites. 5YR under CERCLA will not include this site as remedy was implemented in 2015 and cleanup report is not final.

Fred Vreeman

4/1/2016

Update or Other Action

Draft-Final Long-term Groundwater Monitoring Report received. Well point installation, development, and groundwater monitoring activities at Site SS006 were conducted from 26 through 28 June 2015. Groundwater samples were collected from well points WP04R and WP05R (corresponding to the former locations of SS6-MW04 and SS6-MW05, respectively). All activities were conducted in accordance with the Final 2015 Remedial Action Work Plan. The June 2015 monitoring event is the first which resulted in all contaminants of concern being found in concentrations below groundwater cleanup levels for the Site SS006. Annual groundwater monitoring will continue until concentrations of all contaminants of concern are shown to be steady state, or shrinking and contaminant concentrations are decreasing, for three consecutive monitoring events in accordance with the Nikolski RRS Record of Decision for Site SS006.

Louis Howard

12/7/2016

Document, Report, or Work plan Review - other

Comments provided for on the LTM GW report for SS006. SS004 was not able to be sampled since removal actions were taking place. Main comments were regarding the possibility of drafting an explanation of significant differences to take advantage of the less stringent cleanup level in 18 AAC 75 for TCE set at 3.5 mg/kg instead of the 0.42 mg/kg cleanup level set in the Record of Decision in 2013. See site file for additional information.

Louis Howard

2/6/2017

Update or Other Action

2016 Long-term GW Monitoring report received for review and comment. The purpose of this Long-term Groundwater Monitoring Report is to summarize analytical results for groundwater samples collected during the July/August 2016 Monitoring Event at Nikolski Radio Relay Station (RRS). No groundwater cleanup level (November 6, 2016) exceedances and no ROD exceedances. See site file for additional information.

Louis Howard

2/6/2017

Update or Other Action

ICs control report received for review and comment. ICs at Site SS004 (Petroleum, Oil, and Lubricants [POL]Tank Area) and Site SS006 (Former Drum Storage Area) are part of the selected remedy for the Nikolski RRS Record of Decision (ROD) for each of the respective sites (USAF, 2013a,b). As a result of the findings of the 2015 Remedy Implementation, Site SS003 (POL Pipeline) was added to the 2016 IC inspection. ICs at SS004, SS006, and SS003 consist of the following: 1. Land Use Controls for each site will be incorporated into the 611th Civil Engineering Squadron Land Use Control Management Plan. 2. A Notice of Environmental Contamination will be placed in the Alaska Department of Natural Resources’ (ADNR’s) land records. 3. Warning signs placed at the boundary of each site will provide contact information for Land Use Control Management. See site file for additional information.

Louis Howard

1/31/2018

Update or Other Action

Draft RAO/LTM report received for review and comment. Site observations at SS006 indicated the presence of occasional recreational land users, cattle, and wildlife. Several items were staged at the site for storage including a locked 20-ft storage container (connex), several fuel storage tanks, multiple 55-gallon drums, and leftover supersacks from the 2015 remedial activities. The fuel storage tanks appear to be in decent conditions with some rusting occurring. The tanks appear to be mostly empty with signs of residual fuel remaining. The steel 55-gallon drums are starting to degrade and are rusted and pitted on the tops where they have been holding water. The majority of the drums appear empty with residual gasoline or oil products remaining. However, a few of the drums were partially full of product. The field staff picked up the empty drums that were blown around the site and staged them next to the other drums by the storage container. It is unknown what is located within the storage container staged at the site. Three LUC warning signs that were installed in 2015 remained visible at the site and in decent condition, although leaning slightly. Revegetation efforts have been successful at the site. No other signs of erosion, or standing water were observed. A review of the analytical results from the past three monitoring events indicates that the selected remedy of excavation and offsite disposal and periodic groundwater monitoring was effective in reducing the risk posed by contaminated soils. Due to the fact that groundwater contaminant concentrations have been documented to be below groundwater cleanup levels for three consecutive events, it is recommended that the ERP site SS006 be considered compliant with CERCLA and State of Alaska environmental statutes. A statutory review is planned to be conducted in 2018 to ensure the remedy selected continues to be protective of human health and the environment. See site file for additional information.

Louis Howard

3/7/2018

Document, Report, or Work plan Review - other

Draft Remedial Action – Operations/LTM Report for Nikolski RRS reviewed. Staff requested the removal of the following items from the site or securing them so they do not “blow around” the site as observed by the field team: several fuel storage tanks, multiple 55 gallon drums, and leftover supersacks. See site file for additional information.

Louis Howard

5/23/2018

Cleanup Complete Determination Issued

Based on the information provided to date, it has been determined by ADEC, in accordance with 18 AAC 75.325 – 390 site cleanup rules, that the contaminant concentrations remaining at SS006 does not pose an unacceptable risk to human health or the environment. No further remedial action will be required by ADEC at the Former Drum Storage Area as long as the institutional controls are maintained, effective and no new information becomes available that indicates residual contamination poses an unacceptable risk to human health, safety, welfare, or the environment. DRO and RRO were detected in soil at SS006 above the ingestion cleanup level for DRO and RRO (Table B2 Method Two, Over 40 Inch Zone 18 AAC 75, as amended November 7, 2017). The Record of Decision documented that a groundwater use determination has been made for SS006, per 18 AAC 75.350. Land use controls have been established by the USAF in 2016 to limit potential future exposure and risk to human health or the environment at SS006 See site file for additional information.

Louis Howard

5/23/2018

Institutional Control Record Established

Institutional Controls established and entered into the database.

Louis Howard

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

11/10/2021

Update or Other Action

DEC reviewed overdue tasks and determined that the 2020 Remedial Action Operations, Institutional Control/Land Use Control Report, August 2021 provided adequate information regarding the maintenance of ICs at Site SS006.

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

Contaminant Information

Name	Level Description	Media	Comments
DRO	> Human Health/Ingestion/Inhalation	SoilSoil	Land use controls limit access to soil at the site.

Name

Level Description

Media

Comments

DRO

> Human Health/Ingestion/Inhalation

SoilSoil

Land use controls limit access to soil at the site.

Control Type

Type

Details

Requirements

Description	Details
Advance approval required to transport soil or groundwater off-site.
Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)

Description

Details

Advance approval required to transport soil or groundwater off-site.

Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)

Cleanup complete with ICs

Proposed Plan

Record of Decision

No associated sites were found.

Missing Location Data

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Site Report: Nikolski RRS SS006 Former Drum Storage Area

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

Cleanup complete with ICs

Proposed Plan

Record of Decision

Missing Location Data

State of Alaska Department of Environmental Conservation