| Action Date |
Action |
Description |
DEC Staff |
| 7/20/1994 |
Notice of Violation |
Notice of Violation (NOV) issued this date by Janice Adair to NOAA Ms. Sharon L. Lundin regarding Former National Marine Fisheries Service Facilities, Saint George Island. ADEC has reviewed the March 31, 1994 Phase 1B Environmental Assessment Report prepared for NOAA. ADEC has determined that NOAA, on behalf of the National Marine Fisheries Service, which owned, operated, and managed Saint George Island until 1984 is liable for environmental pollution resulting from past practices and is responsible for taking action to contain and cleanup all spills and releases as well as solid waste which are or were the result of federal activities and operations on Saint George Island. These pollution incidents are in violation of numerous provisions of Alaska Statutes including AS 46.04.020, AS 46.09.020, AS 46.03.100.
Alaska Statute 46.03.822 establishes who is liable in a pollution incident. Records available to ADEC indicate that NOAA meets the criteria.
1) owned or controlled the hazardous substance at the time of its release;
2) owned or operated the property from which the release occurred;
3) owned or operated property at which the hazardous substances came to be located.
The State is authorized, under Alaska Statute Title 46, to respond to this pollution incident if response actions are not satisfactory to the Department. In the event that State response actions are necessary, the responsible parties may be held financially liable for any response actions taken by the State. Recoverable costs include salaries of personnel, travel, contracts, legal fees, indirect costs and interest and other costs associated with the response.
Please respond in writing within thirty (30) days from the date of this letter addressing your intended actions with respect to the environmental pollution due to federal activities on Saint George Island. Please submit two (2) copies of information requested in this letter. |
Janice Adair |
| 8/11/1994 |
Update or Other Action |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former NMFS facilities on Saint George Island. ADEC traveled with NOAA, their consultant, Tanaq Corporation and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol. NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills.
NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island, the site of an underground thermonuclear detonation in the 1970s. Our law are also clear about responsibility for these materials. That responsibility remains with the Federal Government.
One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability. Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable.
The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. |
Simon Mawson |
| 8/19/1994 |
Update or Other Action |
Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service Facility, Saint George Island response to July 20, 1994 NOV Letter. 1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS).
2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records.
Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in these reports.
3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas.
Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet.
During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. |
Janice Adair |
| 12/9/1994 |
Update or Other Action |
AG Letter dated to 12/7/1994 to NOAA re: legal issues raised in 11/17/1994 meeting with NOAA. NOAA has noted its position that 1) the solid waste debris areas on Saint George Island are not NOAA's responsibility and 2) that state regulations should not guide cleanup of these sites. The federal government is liable under a number of federal and state laws for resolving solid waste, hazardous waste and other environmental contamination on the Pribilof Islands that resulted from federal operations.
Petroleum Contamination from unregulated above and below ground tank systems. Pursuant to Alaska's Mini-CERCLA Law, AS 45.03.822, and the Clean Water Act and RCRA waivers of sovereign immunity, NOAA is liable for the remediation of petroleum releases that occurred during the time of federal ownership and operation of these systems. See AS 46.04.020; 18 AAC 75. Petroleum contamination for regulated underground storage tank systems: Pursuant to AS 46.03.822, the Clean Water Act and RCRA, NOAA is liable for remediation of past contamination from these tanks. Necessary upgrading and maintenance of these systems is the responsibility of the current owner/operators. See AS 46.04.020; 18 AAC 78. Regulated tank systems still owned by NOAA are subject to regulation under 18 AAC 78. |
Ray Dronenburg |
| 2/27/1997 |
Update or Other Action |
Review of UST Closure Site Assessment Reports. In certain cases, contamination related to UST system integrity or UST usage was identified. In those cases where contamination was identified, but corrective action to remove the petroleum contaminated soil (PCS) was unsuccessful, State regulations require a release investigation to determine the extent of contamination, followed by corrective action to remediate the affected area. It should be noted that very little investigation was performed during the UST system removal actions to determine if groundwater was impacted by the releases. A groundwater investigation will be necessary as part of the release investigation to determine if it has been impacted and if so, to what extent. In cases where contaminated soil was stockpiled, NOAA should include a stockpile treatment and disposal plan for inclusion in the release investigation and corrective action work plans. Until disposal, the stockpiles should remain covered and access should be limited as much as possible to avoid accidental spills.
Site 22-4 Aviation gasoline UST Facility ID 3047 Tank 5: One 4,000 gallon avgas UST was removed from the ground prior to the onset of site assessment activities. Photographs and interviews with local residents were used to establish the location of the UST, piping and dispensers. Also additional screening and sampling were performed to take into acount possible discrepancies in information. No contamination was encountered and ADEC will not require further action for this UST system (TPA 22-4).
Site 22-5 Gas station #1-Facility ID 3047 Tank 6: Discovered during other site activities, this previously unknown 1,000 gallon UST was added to the site assessment activities. Excavation of the PCS continued until the OVM indicated no organic vapors were present. Sample results indicate no contamination remains in the soil. ADEC requires no further action for this UST system, however, until proper disposal of the excavated PCS is accomplished, it will not be considered formally closed. |
Lynne Bush |
| 2/27/1998 |
Update or Other Action |
Letter to Minh Trinh re: UST Site closure report.
Site 22-5 Gas Station #1 Fac. ID 3047 Tank 6. Discovered during other site activities, this previously unknown 1,000 gallon UST was added to the site assessment activities. Excavation of the PCS continued until OVM screening indicated that no organic vapors were present. Sample results indicate no contamination remains in the soil. The Department will not require further remedial action for the UST system. Until proper disposal of the excavated petroleum contaminated soils (PCS) is accomplished, the site will not formally be closed out until documentation is received showing soil was properly remediated. |
Lynne Bush |
| 11/12/1998 |
Update or Other Action |
Status of TPA Site Number 22-1 Saint George school. One unregulated UST removed 10 cubic yards of PCS excavated and stockpiled, excavation backfilled with clean fill and preliminary site assessments completed, during the FY97 Phase I CA. PCS determination and remediation included in FY 99 Phase II project.
22-2 UST Closure Carpenter shop 1-500 gallon UST diesel One unregulated UST remove, 341 cubic yards of PCS excavated, stockpiled, excavation backfilled with clean fill and preliminary site assessment completed during FY 97 Phase I CA. PCS determination and remediation included in FY 99 project.
22-3 UST Closure Tanaq store 1-1,000 gallon UST diesel, one unregulated UST removed, 402 cubic yards of PCS excavated, stockpiled, excavation backfilled with clean fill and preliminary site assessment completed during FY 97 Phase I CA. PCS determination and remediation included in FY 99 project. This site is located adjacent to the Former Kerosene drum/AST storage area TPA Site Number 10, OU 6.
22-4 UST closure Aviation gas near old Airport Hangar Building 1 each 4,000 gallon avgas Site Number 22-4 OU 5. Unearthed UST placed in City Storage Yard during 1996. UST scrapped and site confirmation sampling conducted during FY 97 Phase I CA.
**NOAA to submit a No Further Action Required (NFAR) request letter to ADEC.
22-5 UST closure Second inactive gasoline station 1 each 1,000 gallon gasoline site 22-5, OU 4. One regulated UST removed, attached underground gasoline supply pipeline removed but not investigated, 756 cubic yards of PCS excavated, stockpiled and excavation backfilled with clean fill, and preliminary site assessment completed during FY97 Phase I CA. PCS determination and remediation included in FY 99 Phase II Project.
22-6 PCS Stockpile site 22-6, OU 6. Stockpile consists of an estimated 8,700 cubic yards of PCS excavated during phase I CA. Renegotiated. PCS will either be used as landfill cover, or included in the Phase II for remediation. AST and debris removal required. |
Ray Dronenburg |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Ray Dronenburg |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 9/29/1999 |
Site Added to Database |
Contaminant: DRO. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 2/15/2000. Contractor to mobilize in field in July 2000. |
Louis Howard |
| 1/6/2000 |
Update or Other Action |
Staff commented on revised schedules for site. Staff requested NOAA provide action items or descriptions (e.g. site characterization) in the "Action" section of the cover sheet for sites 21-25, which do show up in the MS Project 98 charts for the sites. |
Louis Howard |
| 5/30/2000 |
Update or Other Action |
Staff sent comment letter on Draft Corrective Action Work Plan for Remediation of Petroleum Contaminated Soil, Pribilof Islands Restoration Project, Saint Paul Island RAC II/Delivery Order Number 0077 dated May 26, 2000. ADEC request clarification from NOAA on how the cells will be constructed in greater detail than what is presented in the document.
DEC requests NOAA treat all of the petroleum-contaminated soil, which includes the oversized material in the existing stockpiles without screening out the oversized material such as scoria. If NOAA proposes to screen out the oversized material (i.e. greater than two inches in size), then NOAA must demonstrate that the material is indeed impervious to petroleum constituents.
DEC guidance document (SPAR\Director\8-93\003) "Petroleum Hydrocarbon Cleanup Goals For Oversize Materials" states that for rock material greater than two inches will need to be treated or tested if it has the potential to hold excess amounts of contamination (e.g. greater than matrix level "A") or contains visible petroleum product on the surface.
Materials that may hold excessive contamination could include: shales, schists, limestone, pumice, or other porous types of rocks. Soil clumps greater than two inches, including silt/clay compounds or frozen tundra and peat material must also be treated. ADEC believes that the bulk of the oversized material is scoria and therefore has the potential to contain contamination above Level "A" criteria. Absent any scientific evidence that the oversized material is truly impermeable, ADEC will require NOAA treat all soil and oversized material contained in the stockpile.
DEC requests that for final corrective action verification samples NOAA obtain them from the location and depth of areas showing the highest levels of contamination during field screening. Unless otherwise approved by DEC, all laboratory soil samples must be grab samples and may not be composited before analysis, except soil samples for total arsenic, cadmium, chromium, and lead that are for screening purposes which may be composited in the field or in the laboratory before analysis. ADEC requests NOAA collect no less than twenty-eight soil samples for field screening purposes on a 600 cubic yard treatment cell. ADEC is requesting field screening samples be collected and additional confirmation samples be obtained from the perimeter of the original stockpiles. This is to characterize any petroleum contaminants that have leached out to the surrounding soils while awaiting remediation. |
Louis Howard |
| 7/25/2000 |
Update or Other Action |
Staff requested all of NOAA's budget requests made to congress since the agreement was signed in 1996 by both ADEC and NOAA for the environmental cleanup at the Pribilofs. It has come to DEC's attention that NOAA did not make a formal request for funding to Department of Commerce for FY 01 and possibly FY02 (federal fiscal years). This is not in compliance with the TPA which requires NOAA to request adequate funding to meet its obligations under the TPA. NOAA was counting on the U.S. congressional delegation to fund 12 million dollars as a special appropriation for the Pribilofs. The appropriation was much less-3 million dollars for October 2000 to September 2001. Deadline for NOAA to provide a written response was no later than August 18th. |
Louis Howard |
| 9/20/2000 |
Update or Other Action |
Staff sent a letter to NOAA on Waiver Request for Stockpile Cover Installation on Stockpiles associated with the Enhanced Thermal Conduction System on the Pribilof Islands dated September 19, 2000. ADEC is aware of the problems and unforeseen circumstances NOAA has had to deal with remediation the soil stockpiles on the Pribilofs. Based on a review of the information presented by NOAA, ADEC will grant a one-time waiver for stockpile cover installation at both islands for stockpiles associated with this specific remediation effort.
This waiver is contingent upon NOAA treating all the remaining stockpiles to level “A” cleanup criteria and the most stringent cleanup criteria for: benzene, ethylbenzene, toluene, and total xylenes listed in 18 AAC 75.341. If NOAA fails to remediate all the soils in the 2001 field season, then ADEC will require NOAA to cover its remaining stockpiles with a synthetic membrane material designed to withstand the extreme weather conditions on the Pribilofs. Stockpiles generated during future investigation, removals, or cleanup work by NOAA (including NOAA’s Compliance program) shall not be eligible for this waiver and be required to meet the requirements for stockpiles listed in 18 AAC 78.274. |
Louis Howard |
| 12/14/2000 |
Update or Other Action |
Staff sent letter to NOAA regarding Notification of possible Force Majeure (per the TPA). The Alaska Department of Environmental Conservation (ADEC) has received the above document via facsimile from NOAA on December 5, 2000. The document states that in accordance with Paragraph 67 of the Two Party Agreement, the potential exists for a Force Majeure situation. It further states that unless further Pribilofs Cleanup Funds are appropriated to NOAA for FY01, the project budget will be exhausted this fiscal year. We very much appreciate your providing this information and analysis of NOAA’s anticipated plans in FY 01 given the existing funding situation. ADEC realizes that funding is uncertain due to Congress not yet finalizing a budget for this FY01. We anticipate a meeting with NOAA to discuss potential impacts to the Pribilof Islands Environmental Restoration Agreement when Congress finalizes a budget. |
Louis Howard |
| 3/2/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 2/24/2003 |
Update or Other Action |
Formal Request for No Further Action Gas Station #1 UST Site TPA Site no. 22-5. Location: St. George Island, Alaska, approximately 800 miles southwest of Anchorage in the Bering Sea. The
site is a former underground storage tank (UST) for a gasoline distribution station located east of the current St. George Tanaq Corporation Carpenter Shop (TPA Site 22-2) in the City of St. George.
Type of Release: Petroleum fuel hydrocarbons from a UST and its appurtenances.
History: A gas station operated at this site from 1973 to the mid-1980s. The UST was installed in 1973 or 1974 and was used until the mid-1980s for gasoline storage. The Alaska Department of Environmental Conservation facility ID for this tank is 3047.
Summary of Site Investigations: No site investigations were performed for the site. The UST was discovered in 1997 during activities supporting clean up actions on nearby sites. Once NOAA discovered the UST, NOAA’s contractor was tasked to close the UST and remediate associated petroleum contaminated soil.
Summary of Clean up Actions: A UST closure was performed in accordance with a May 1997 work plan. Clean overburden soil was excavated from above the UST and placed temporarily in two on-site stockpiles. During the closure, the soil immediately below the tank appeared highly contaminated with fuel based on field instrument readings, as well as visual and olfactory observations. Several small, pencil-sized holes were observed in the tank bottom during tank cleaning. The tank was removed from the site, cleaned, and cut into pieces. The tank was transported to Alaska Metal Recycling in Seward, Alaska in June 1997 for disposal as metallic scrap.
A total of 756 cubic yards of petroleum contaminated soil (PCS) was removed from beneath and near the tank. The excavated PCS was hauled to NOAA’s PCS stockpile, approximately one mile west of the City of St. George. The PCS stockpile was treated using NOAA’s enhanced thermal conduction system in 2000 and 2001 (Polarconsult 2001). Confirmation samples were collected from the excavation. Stockpile characterization samples were collected from the two clean overburden stockpiles on-site. The samples were analyzed for gasoline-range organics (GRO) and were found to be at non-detectable levels and below the GRO cleanup level of 100 mg/kg. The samples were not analyzed for benzene, toluene, ethylbenzene, xylenes or lead due to non-detectable levels of GRO. A summary of analytical data is shown in Table 1. The site was backfilled with clean soil, compacted and graded.
Recommended Action: In accordance with paragraph 59 of the Two-Party Agreement (NOAA 1996), NOAA submits written confirmation that all corrective action has been completed and that no further action is required at TPA Site Number 22-5. |
Louis Howard |
| 3/10/2003 |
Site Closure Approved |
Letter from ADEC to NOAA RE: St. George Island Request for No Further Action for Gas Station #1 UST (gasoline) TPA site no. 22-5. Based on a review of the information provided, the Department finds the Gas Station #1 underground storage tank (UST) Site listed in the Two Party Agreement (TPA) as Site No. 22-5, does not pose a significant threat to human health or safety, or the environment. For your information, Department regulations concerning sampling
at suspected releases from gasoline USTs typically requires additional sampling for benzene,
toluene. ethylbenzene, xylenes (BTEX) and lead. There are no provisions in [18 AAC 75 or 18 AAC 78] regulation to eliminate this sampling requirement based solely on analytical results obtained for gasoline range organics (GRO).
However, since confirmation soil samples did not detect any GRO in any of the samples, it is
highly unlikely that BTEX would be present above levels requiring further action. This fact
combined with the excavation and treatment of 756 cubic yards of contaminated soils, the
Department has determined that no further investigation or sampling is required.
NOTE: Unless analytical data indicates otherwise, all future investigative, assessment, and/or confirmation sampling activities for Method One cleanups on the Pribilof Islands involving gasoline sources shall include: GRO, BTEX and lead analyses.
The Department is basing its decision on the most current and complete information provided by NOAA. The Department reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations, 18 AAC 78 Underground Storage Tank regulations, and AS 46.03 to require the National Oceanic and Atmospheric Administration to perform additional investigation, cleanup, or containment if subsequent information indicates that
(1) the level of contamination that remains does not protect human health, safety, or welfare, or the environment; or
(2) the information the Department relied upon for its decision was invalid, incomplete, or fraudulent. |
Louis Howard |
| 9/20/2008 |
Update or Other Action |
The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Pribilof Project Office is responsible for site characterization and restoration on St. George Island, Alaska. Although NOAA has attempted to meet State of Alaska soil cleanup levels and has removed contaminated soil to the maximum extent practicable, residual contamination remains at some St. George Island sites. This report documents the nature of known or potential residual soil and groundwater contamination at NOAA-remediated sites and presents the rationale for leaving the contamination in place.
Of thirty-six (36) sites investigated and/or restored by NOAA at St. George Island, the following contaminants are known to remain or potentially may be present in soil and/or groundwater above applicable site cleanup levels:
• DRO at 20 sites.
• GRO at 5 sites.
• RRO at 3 sites.
• Benzene at 4 sites.
• Toluene at 3 sites.
• Ethylbenzene at 4 sites.
• Total xylenes at 4 sites.
• Perchloroethylene at 2 sites.
• Lead at 2 sites.
Contaminated soil may have been left in place at sites due to equipment limitations and/or the presence of utility lines, buildings, roads, and other structures. Additionally, NOAA was not obligated to excavate contaminated soil to address the inhalation and ingestion pathways fifteen (15) feet or greater below the ground surface, or at shallower depths when encountering the water table. Buried debris, such as municipal solid waste, also remains at some sites. In such locations, NOAA placed a soil cap over the debris according to State of Alaska requirements.
A 1,000-gallon gasoline UST was located at Site 26. The UST was in use from about 1973 until the mid 1980s. The UST was removed in 1997 along with approximately 756 yd3 of GRO contaminated
soil. Contaminated soil was removed to depths of up to 19.5 feet bgs. GRO was not detected in cleanup confirmation samples taken within the final excavation extents; no further action was required. |
Louis Howard |
| 9/26/2008 |
Update or Other Action |
Summary of Residual Soil Contamination and Buried Solid Wastes at NOAA Cleanup Sites on St. George Island. NOAA Site No. 26/TPA Site No. 22-5 Gas Station #1 UST: contaminated soil, UST/AST pipeline. Clean closure.
Site status as of September 26, 2008: NFRAP 03/10/2003. Property Owners: St. George Tanaq Corporation (Tanaq). |
Louis Howard |
