| Action Date |
Action |
Description |
DEC Staff |
| 3/2/1992 |
Update or Other Action |
Letter from Tanadgusix (TDX) Native Village Corporation (created under the Alaska Native Claims Settlement Act (ANCSA) of 1971) regarding Summary of background on past and present ownership and operation of the underground storage tanks systems (USTs), statement of reservation of rights by TDX, request for extension on performance of a tank tightness test (TTT) or site assessment (SA) on USTs currently in use and applications for financial assistance for performance of a TTT or SA on each such UST.
At some point prior to 1970, the NOAA/NMFS installed at least six USTs on St. Paul Island. The St. Paul USTs were primarily used for storage of petroleum products. Among the real properties to be transferred by the Federal Government to TDX was a parcel identified as the Plant Site and Industrial Buildings Area ("Parcel 1"). The St. Paul USTs appear all to be located on Parcel 1. The agreement also required TDX to lease the existing gas station facility on Parcel 1 to the IRA and to lease the Power Plant and Machine Shop/Equipment Shed to the City.
TDX has made several attempts to contact the City and the IRA to discuss UST compliance obligations. However, despite having significant financial resources, the City takes the unreasonable position that all USTs are TDX' problem, even though TDX has never operated any of the USTs and has not accepted title to the land. The City sends all ADEC notices it receives about the USTs to TDX. The City sends all ADEC notices it receives about the USTs to TDX. The City has operated, and is currently operating three USTs on premises leased from TDX.
Tank no. 5 is thought to be located between the gas station and the Power Plant (NOTE: a.k.a. TPA 09C), the exact location is uncertain. It may have been taken out of use by the Federal Government before the TOPA. The contents, if any, are unknown, but it may have contained diesel fuel. The federal government has not registered the tank with the ADEC.
Finally, TDX is willing to meet with ADEC, the City, IRA, NOAA, and NMFS to develop a long-term plan to bring the St. Paul USTs into compliance with State and Federal law. If the other parties will not cooperate, TDX will litigate the matter of its rights and duties with regard to such tanks before the Board of Storage Tank Assistance or in State or Federal Court.
If TDX is found to be responsible for any of the St. Paul USTs currently in use, it intends to permanently close such tanks and will so notify ADEC and comply with closure procedures. TDX does not intend to wait until it is faced with a compliance order and penalties before it takes responsible action with regard to the St. Paul USTs. |
Ray Dronenburg |
| 9/30/1993 |
Update or Other Action |
U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report.
Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. |
Ray Dronenburg |
| 10/1/1993 |
Update or Other Action |
City of Saint Paul Public Notice to: Contractors/Regulatory Agencies. The City of Saint Paul hereby notifies you of the potential presence of hazardous materials on the island. The attached maps should be used as a general reference for identification of potential hazardous materials in planning your project. For the proposed utility projects within the Harbor Area planned for construction during the summer of 1993, the City does not believe that any hazardous materials are present. However, landowners and contractors are responsible for assuring compliance with federal and state regulations and should not rely on information provided herein.
If contractors on City Projects (and/or City Property) or on projects which are to become property of the City, believes that hazardous materials may or have been encountered, they must immediately cease any and all construction activity, immediately notify the Public Works Director and City Manager orally and in writing and comply with the attached guidelines. No further construction work can be done unless explicitly authorized in writing by the Public Works Director and City Engineer.
City of Saint Paul Hazardous Materials Procedures-
1) Review attached maps. If project includes construction within areas noted as potentially contaminated or if you encounter potential environmental contamination during construction, the following procedures must be followed:
2) Notify NOAA and the City of the potential problem;
3) conduct standard ADEC screening tests and provide in writing at a minimum-to NOAA and the City: a) exact location of area and land ownership, b) Quantity of material, c) Characteristics of material and contamination, d) documentation the contractor has certified persons to 1) conduct screening tests and 2) handling and disposal of hazardous wastes, e)Provide a detailed cost estimate for the initial screening, stockpiling, and testing of the material including labor, materials, equipment, testing, etc., f) provide a schedule for the final removal of any stockpiled materials, g) identify the location and specifications for stockpiling the materials.
4) If the material does not appear to require remediation according to ADEC and EPA regulations, the City Engineer and City Public Works Director will authorize the construction to proceed.
5) If the initial screening per ADEC and EPA regulations indicates that the material must be stockpiled for further testing (NOTE to file states Should not be removed until an approved plan is submitted), then the contractor must comply with the protocol approved by NOAA and the City. At a minimum, this protocol would include the stockpiling of excavated materials, the placement of an impermeable liner in the construction utility corridor, the installation of utility lines covered with non-contaminated materials, and the testing of stockpiled materials for analysis and disposal per ADEC and EPA regulations.
For additional information see site file. |
Ray Dronenburg |
| 11/2/1994 |
Document, Report, or Work plan Review - other |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action.
Section 120 Federal Facilities(a) Application of Act to Federal Government(4)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. |
Jennifer Roberts |
| 12/20/1994 |
Update or Other Action |
Duplicate site name was "Municipal Garage UST Header Pipes" - NOAA site on St Paul Island. |
Ray Dronenburg |
| 12/15/1995 |
Update or Other Action |
Hart Crowser collected soil samples in 1995 at the Municipal Garage/Machine Shop site from several hand auger borings and one test pit. Arctic diesel, diesel, heavy oil, and benzo(a)pyrene were detected in the samples, though the heavy oil was not found at elevated levels. Arctic diesel was found at up to 2,700 mg/kg in surface soils and at up to 5,900 at 10 feet bgs. Note that arctic diesel is essentially diesel mixed with gasoline-range organics (e.g., benzene) to prevent the mixture from freezing during cold weather, and that tetraethyl lead was not added to arctic diesel. As a result, the arctic diesel results would be indicative of both GRO and DRO contamination. Heavy oil is indicative of residual-range organics (RRO) contamination. Benzo(a)pyrene is a semi-volatile organic compound (SVOC) sometimes found with petroleum hydrocarbons. |
Ray Dronenburg |
| 2/27/1997 |
Document, Report, or Work plan Review - other |
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.
Two 8,000 gallon diesel USTs, located south of the old machine shop, were removed on June 18, 1997. Both tanks and the piping corridor show evidence of remaining PCS above cleanup levels.
All benzene samples were non-detect, BTEX ranged from 5.0 to 27.7 mg/kg, DRO from 4,600 to 18,000 mg/kg. It should be noted that a cancelled cargo flight made it impossible to use a field screening instrument to segragate soils during removal. Therefore, it is possible that locations along the piping run and elsewhere have not been adequately screened and sampled.
Two 1,000 gallon USTs containing gasoline and diesel fuel were removed and assessed during July and August 1997. Contamination remains in the soils at levels exceeding the target cleanup levels. GRO was detected up to 768 mg/kg, benzene up to 3.2 mg/kg, total BTEX to 193 mg/kg and DRO to 2,430 mg/kg. |
Lynne Bush |
| 12/15/1997 |
Update or Other Action |
In 1997, the ASTs and most of the USTs along the west side of the Municipal Garage were removed by Aleutian Enterprises. |
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. |
Louis Howard |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation.
Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard.
|
Louis Howard |
| 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. Action entered by L. Howard. |
Jennifer Roberts |
| 9/29/1999 |
Site Added to Database |
DRO Contaminant. |
Louis Howard |
| 10/11/1999 |
Site Ranked Using the AHRM |
Initial ranking by staff. |
Louis Howard |
| 3/28/2001 |
Document, Report, or Work plan Review - other |
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 |
| 6/4/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed a draft site cleanout report for the Machine Shop TPA 09 Tract 46 St. Paul Island on May 11, 2001. The text states only one report is available regarding this property: St. Paul Island Building Inspection Report, July 19-21, 2000. ADEC disagrees. 1997 UST removal and closure report (Bristol Environmental Services Corporation-BESC 1997 project # 7029FG-00 Sept. 24, 1997) show a release has occurred at the site. Please refer to ADEC comment letter dated February 27, 1998 subject: Review of UST Closure Site Assessment Reports (see attached).
The letter clearly states at Facility ID 3048, diesel Tanks 5 & 6 had substantial diesel range organics (DRO) contamination remaining in place after removal. The closure report lists sample 8KnF had 16,000 mg/kg DRO & 27.47 mg/kg total BTEX. Two 8,000-gallon single walled USTs and 30' of piping were removed.
Apparently the limits of backhoe were reached in the excavation with soils still observed with high petroleum contamination (BESC 1997 Page 4 Discussion). Sample 8KNC had 20.01 total BTEX and 15,000 mg/kg DRO. Both 8KNC and 8KNF were from the Northern Tank closest to the old machine shop. Line between USTs and old machine shop sample "Line A" had 18,000 mg/kg DRO (BESC 1997 Table 1). This particular sample was from a pipeline stubout to supply a former boiler in the machine shop. No groundwater was encountered from surface to bedrock at 18'. Stockpiled soil was moved to seven miles north near quarry site on Polovina Hill.
ADEC cannot grant a no further action determination until NOAA provides further information which shows the site was adequately characterized to determine the horizontal and vertical extent of contamination, the contamination was successfully remediated and no additional contamination remains at the site above Category “B” criteria (see BESC report appendix D). |
Louis Howard |
| 12/31/2001 |
Update or Other Action |
In 2000, a UST at the southeast corner of the Municipal Garage was removed by CESI during site characterization activities. CESI also conducted additional sampling at the Municipal Garage. Analytical data for soil samples collected during this investigation indicated the presence of diesel-range organic compounds (DRO) up to 13,000 mg/kg, gasoline-range organic compounds (GRO) up to 470 mg/kg, toluene up to 20 mg/kg, and ethylbenzene up to 12 mg/kg.
Groundwater samples were collected from monitoring wells at and near the Municipal Garage in 2000 by CESI and in 2001 by IT Alaska Corporation Analytical data for these samples indicated the presence of DRO, GRO, residual-range organic compounds (RRO), benzene, and toluene at concentrations exceeding regulatory limits established by ADEC. |
Louis Howard |
| 5/30/2002 |
Update or Other Action |
NOAA has elected to proceed with corrective actions at the Municipal Garage/Machine Shop under the guidelines afforded by 18 AAC 75.345 and 18 AAC 75.350 (ADEC 2000), commonly referred to as the Ten Times Rule. NOAA has determined that the groundwater in St. Paul Village is non-potable (Mitretek 2002) as defined under 18 AAC 75.350, and based on this determination, applied to ADEC to use the Ten Times Rule. NOAA’s application received conditional approval (May 30, 2002). |
Louis Howard |
| 5/30/2002 |
350 Determination |
18 AAC 75.350 determination granted by ADEC. TPA Site 9, also known as Tract 46, has 16 distinct soil-contaminated sites identified by investigations subsequent to the signing of the TPA. TPA 9 sites & TPA 12 are covered by the determination.
The groundwater in the Tract 46 area is impacted by saltwater intrusion from the nearby Bering Sea, which makes it unfit for drinking water consumption. This is demonstrated with the high levels of total dissolved solids, chloride, & electrical conductivity NOAA has measured in the Tract 46 area. The groundwater is not currently used for drinking water & there is no anticipated future use of groundwater in the study area.
All residents obtain their drinking water from the public water supply system two miles northeast from the city. There is no current or future need for the groundwater within the study area to be used as a potential drinking water source. The existing water supply located two miles away from Tract 46 is adequate to meet all anticipated needs for drinking water. See site file for additional information. |
Jennifer Roberts |
| 3/10/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Preliminary Soil Gas Survey for Assessment of Hydrocarbons Contamination at St. Paul Island Dated October 31, 2002.
The Alaska Department of Environmental Conservation (the Department) received the above document on February 24, 2003. The Department wishes to state that the use of soil gas surveys regardless of sample collection technique is regarded as a screening device. Samples analyzed with field screening devices may not be substituted for required laboratory samples (UST Procedure Manual November 2002). Soil gas surveys will allow for more focused site investigations by indicating the area where the contamination is likely to be present.
The text states a more complete soil gas survey in the area of the Community Garage and Cascade building would help clarify the degree and extent of contamination. These two sites benefit more by NOAA conducting a focused site investigation using traditional soil sampling/screening in areas indicated as being contaminated by the soil gas survey. |
Louis Howard |
| 7/14/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Proposed Sampling and Analysis Frequency and Corrective action Plan for TPA Site No. 9E Municipal Garage/Machine Shop, St. Paul Island dated July 2, 2003.
The Alaska Department of Environmental Conservation (the Department) received the above document on July 8, 2003. The Department will approve the document as written with regards to the sampling numbers and frequency of field screening for petroleum contaminated soil at this specific site. Additionally, approval is granted for the corrective action plan submitted at the same time.
Please be aware that the Department’s review and concurrence on the document is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the document does not relieve the National Oceanic and Atmospheric Administration (NOAA), its consultants, contractors, sub-contractors, or personnel from complying with other applicable laws and regulations. |
Louis Howard |
| 12/15/2003 |
Update or Other Action |
During the corrective action performed in 2003 field season, approximately 2,805 cubic yards of PCS were removed from the excavation at the Municipal Garage. This corrective action was performed to address the environmental impacts resulting from past operations conducted at the site. Although analytical results for confirmation samples collected from the excavation at the Municipal Garage revealed that concentrations of BTEX, DRO, and GRO remain above cleanup levels, excavation in this area has been conducted to the maximum extent practicable, based upon equipment limitations and the presence of obstructions including buildings, the steep slope of Village Hill, and a live electric line along the north side of the building. Further excavation with available equipment is not technically feasible in this area. Although contamination remains, the cumulative risk assessment demonstrates that the cumulative cancer risk and non-carcinogenic hazard index for contaminants remaining in soil are below the required limits.
Primary sources of contamination have been removed and because the excavation of PCS has been conducted to the maximum extent practicable at the Municipal Garage.
In 2002, NOAA contracted with Mitretek Systems Inc. (Mitretek) to evaluate the groundwater data gathered by CESI and IT in the St. Paul Village area in accordance with 18 AAC 75.345 and 18 AAC 75.350 (Mitretek 2002). The Mitretek report reflects the general groundwater contaminant levels in the areas of the Municipal Garage/Machine Shop. NOAA will not address groundwater under this corrective action report. Additional groundwater assessment will be performed as necessary, but under a separate groundwater monitoring plan and corrective action plan, if necessary. The groundwater contamination details for this site are provided as information concerning the potential for soil contamination to extend to groundwater at each site.
The Mitretek report demonstrated that groundwater in the vicinity of St. Paul Village is tidally influenced and brackish. Mitretek concluded that the groundwater is not used for drinking water. The evaluation in part provided a rationale for using alternative groundwater cleanup levels that are protective of human health and the environment where the groundwater is not potable. Mitretek concluded in accordance with 18 AAC 75.350 that groundwater in the Village area is not currently used and did not afford any potential future use as a drinking water source.
Future activities should include periodic groundwater sampling of monitoring wells in the vicinity of the Municipal Garage. Two wells have been identified: MW46-6, located near the northwest corner of the building, and MW46-28 located along the north edge of the building. |
Louis Howard |
| 1/23/2004 |
Update or Other Action |
On January 23, 2004 the National Oceanic and Atmospheric Administration (NOAA) requested that the Department of Natural Resources (DNR) establish a critical water management (CWMA) under 11 AAC 93.500. The CWMA would cover only the groundwater aquifer under a portion of the town site of the City of St. Paul. In cooperation with the Department of Environmental Conservation, NOAA has conducted extensive studies of the area groundwater and found significant petroleum contamination making the water unsuitable as drinking water or for other beneficial uses.
The creation of the CWMA will facilitate the transfer of lands from the federal government to private parties on the island. DEC consulted with the public and agreed with NOAA that a non-drinking water, groundwater use determination is appropriate for this area. This determination allows for an adjustment to the groundwater cleanup levels. The CWMA is necessary to establish institutional controls to limit inadvertent future use of the contaminated groundwater in order to protect public health, and the environment. |
Louis Howard |
| 10/7/2004 |
Long Term Monitoring Established |
The Department is requesting NOAA begin, if it has not already, periodic groundwater sampling of the monitoring wells in the vicinity of the Municipal Garage. Two wells have been identified: MW46-6 and MW46-8.
The Department reserves all of its rights, under AS 46.03 and 18 AAC 75 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions at TPA 9e if information becomes available that contamination is found at this site which poses a risk to human health or safety, welfare, or the environment. |
Louis Howard |
| 10/7/2004 |
Conditional Closure Approved |
ADEC sent letter to NOAA regarding Site 20/TPA Site 9e.
Based on our review of the document and the data provided by NOAA, the Department finds the residual contamination remaining at Site 20/Two-Party Agreement (TPA) Site 9e, does not pose a significant threat to human health or safety, or the environment. NOAA has removed 2,805 cubic yards of contaminated soil which served as the primary source of contamination for this site to the maximum extent practicable. Excavation was limited by: concerns over worker safety and the integrity of the building, a steep slope along the base of Village Hill, a live electric line, active fuel pipelines, a concrete pad, and monitoring wells MW46-28, and MW46-6.
The Department has, therefore, determined that a no further remedial action planned (NFRAP) designation is appropriate for the soil at TPA Site 9e. This determination is equivalent to certification by the Department that corrective action is complete as stated by TPA section 59 Closure of Sites of Operable Units.
In the event that the remaining contaminated soil becomes accessible, or other information becomes available which indicates that TPA Site 9e may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from TPA Site 9e requires prior approval from the Department in accordance with 18 AAC 75.325(i).
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required:
1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1;
2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
Louis Howard |
| 10/7/2004 |
Institutional Control Record Established |
In the event that the remaining contaminated soil becomes accessible by the removal of the soil located in the vicinity of the Machine Shop/Municipal Garage TPA 9e, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site outside of the “Village Area a.k.a. Critical Water Management Area” requires approval from the Department in accordance with 18 AAC 75.325(i).
|
Louis Howard |
| 10/11/2004 |
Update or Other Action |
NOAA sent a request for no further remedial action planned (NFRAP) designation at the site sent to ADEC. Although confirmation samples indicate that contamination remains in some areas of the excavation, no further excavation could be conducted in these areas because of concerns regarding worker safety and threats to the building’s structural integrity.
Obstructions encountered during excavation included the Municipal Garage building to the east, a steep slope to the west along the base of Village Hill, a live electric line, active fuel pipelines, a concrete pad, and monitoring well MW46-28 along the north side of the building, and monitoring well MW46-6 located near the northwest corner of the building. Near the northwest corner of the Municipal Garage, the integrity of the building foundation and wall was impacted because of efforts to remove as much PCS as possible, which resulted in the foundation being undercut and some settlement of the foundation.
ADEC concurred with NOAA's request for NFRAP designation. In accordance with Paragraph 59 of the Two Party Agreement, this is to confirm that all corrective action has been completed in 2003, at the Municipal Garage/Machine Shop, TPA Site 9e/Site 20 in accordance with the Agreement and that no plan for further remedial action is warranted.
ADEC reserves all of its rights under 18 AAC 75, 18 AAC 60, and AS 46 to require NOAA to conduct further investigation and/or remedial action if information indicates conditions at the Municipal Garage/Machine Shop, TPA Site 9e/Site 20 pose a risk to human health, safety and welfare, and of the environment. |
Louis Howard |
| 4/17/2006 |
Update or Other Action |
The Critical Water Management Area (CWMA) precludes the use of groundwater from the aquifer within the boundary of the CWMA. The City of St. Paul provides an abundant and clean source of water to the homes and businesses within this area. The monitoring of the water quality in the CWMA will continue into the future, when and if the water quality improves to the point where it can be used, the designated CWMA can be revoked or amended to allow for full or limited use.
The extensive public notice and hearing process required to establish a CWMA resulted in no adverse comments to DNR’s designating the proposed area a CWMA. The establishment of the CWMA will keep current and future landowners with the CWMA from drilling, digging a well or otherwise removing groundwater from the CWMA.
NOAA has the intent and ability to meet the requirements required by ADEC to establishment a 10X rule for contamination clean up in the area of the CWMA . The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells.
The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells. The establishment of the CWMA will in no way effect the ability of the public to access navigable or public waters. |
Louis Howard |
| 4/8/2008 |
Update or Other Action |
NOAA sent a Corrective Action Report and Conditional Closure Request for TPA Site 9e. Contamination (i.e., lead contaminated soil and PCS) was mostly removed from the site during the 2007 field season, except for petroleum contaminated soil at the depth of groundwater (14 feet bgs) and contaminated soil near underground utilities.
Given the proximity of the site to the harbor and the direction of groundwater flow, it is possible that the contaminated groundwater could migrate to the surface water of the harbor; however, there is no indication of this occurring. NOAA is conducting long term groundwater monitoring of wells located between the site and the harbor and will be able to detect in any such migration if it should occur. Monitoring wells located in the vicinity of the site include MW46-6, MW46-28, MW46-5, MW46-9, MW46-14, MW46-10, and MW46-15.
NOAA and its contractors removed approximately 2,017 CY of PCS and 18 CY of lead contaminated soil from the Municipal Garage and Connector Building sites. Because NOAA removed the primary sources of contamination and met the objectives of the CAP addendum, NOAA seeks a conditional closure for soil contamination at the Municipal Garage site. |
Louis Howard |
| 4/9/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on NOAA's Corrective Action Report and Conditional Closure Request-Municipal Garage Demolition Soil Removal NOAA Site 20/TPA Site 9e. The Municipal Garage site is situated on St. Paul Island, close to the harbor to the northeast of Village Hill (57°07'21'' latitude, 170°16'50" longitude). Its legal description is: Tract 46, Township 35 South, Range 132 West, of the Seward Meridian, Alaska, as shown on the dependent resurvey of a portion of U.S. Survey No. 4943, Alaska, Tract "A", St Paul Townsite, officially filed June 3, 1997. Some of the western portion of this site falls within Lot 3, Section 25, Township 35 South, Range 132 West, of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 1986. NOAA currently owns the site.
ADEC has previously made a no further remedial action decision in 2004 based on the condition that the Municipal Garage building and foundation remain intact. Since that time, NOAA has elected to demolish the building and remove the foundation. Therefore, further remedial investigation activities by NOAA was necessary. Two-thousand and seventeen (2,017) cubic yards of soil was excavated by NOAA in 2007. Further excavation of contaminated soil could not be conducted because of the risk to buried utilities that parallel the north and northeast sides of the site as well as groundwater occurring at a depth of 14 feet. Additionally, eighteen (18) cubic yards of lead-contaminated soil was removed and transported to a disposal trench in Landfill Cell C.
The excavated soil has been properly treated or disposed and ADEC has determined that a conditionally closed determination is still appropriate for Two-Party Agreement (TPA) Site No. 9e Municipal Garage site, NOAA Site 20, ADEC CS database reckey# 1994250119605.
ADEC’s determination is equivalent to certification by the Department that corrective action is complete under TPA section 59. Closure of Sites of Operable Units which states: “… NOAA may request from ADEC written confirmation that all corrective action has been completed at a site(s) or operable unit(s) in accordance with this Agreement. Within thirty (30) Days of its receipt of such request. ADEC shall: (1) provide written confirmation that no further corrective action is required at the subject site(s) or operable unit(s). ADEC shall not deny certification that corrective action is complete at any site(s) or operable unit(s) solely on the basis that post-remedial measures, such as monitoring, shall remain in place for a period of months or years.”
In the event that the remaining contaminated soil becomes accessible by the removal of the soil located in the vicinity of the Municipal Garage TPA 9e Site 20, the land owner and/or operator will be required under 18 AAC 75.300 to notify ADEC. Also, any transport or disposal of contaminated soil excavated from the site outside of the “Village Area” requires approval from ADEC in accordance with 18 AAC 75.325(i).
ADEC reserves all of its rights, under A.S. 46.03, 18 AAC 75, and 18 AAC 78 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions deemed appropriate by ADEC at TPA 9e, if information becomes available that contamination is present which poses an unacceptable risk to human health or safety, welfare, or the environment. |
Louis Howard |
| 6/4/2008 |
Update or Other Action |
NOAA and ADEC signed the closure letter for St. Paul Island. In accordance with paragraph 59 of the Pribilof Islands Environmental Restoration Agreement (Two-Party Agreement or TPA) January 1996 by designated officials of the State of Alaska and the National Oceanic and Atmospheric Administration (NOAA), NOAA requested Alaska Department of Environmental Conservation (ADEC), as the duly authorized representative of the State of Alaska, certify NOAA’s completion of corrective action for the St. Paul Island Operable Unit (OU).
As of June 4, 2007, the Municipal Garage/Machine Shop (a.k.a. Municipal Garage UST vent fill pipe TPA 9c, and Municipal Garage Drum Staging Area (Tract 41) 9d per TPA Attachment A) Site 9e has contaminated soil associated with either a UST/AST/Pipeleine and building demolition debris.
Site conditions: No contamination is known to exist under the Machine Shop. However, soil contamination at the water table remains below the former Municipal Garage which was demolished during 2007. Residual soil contaminated with DRO, GRO, benzene, toluene, and ethyl benzene, remain along utilities, beneath the roadway, and underneath a concrete pad tied to the Machine Shop; total xylenes above Method Two in soil remain in limited areas at the water table; DRO, GRO, toluene, and ethyl benzene in soils at the water table exceed the 10x Rule criteria in some areas; benzene exceeds the 1991 benzene criterion of 0.5 mg/kg in some areas; long term groundwater monitoring (DRO, GRO, toluene, and benzene contamination); deed notice.
Property Owner as of November 6, 2007 is NOAA Site is within the Critical Water Management Area (CWMA). |
Jennifer Roberts |
| 4/30/2012 |
Update or Other Action |
Staff received the Tract 46 Quit Claim Deed from NOAA for review and comment.
The National Oceanic and Atmospheric Administration (hereinafter "NOAA" or
"Grantor"), an agency of the United States Department of Commerce, pursuant to its authority
under Section 205(a) the Fur Seal Act of 1966, as amended (16 U.S.C. § 1165(a)), and in
fulfillment of Paragraph 5(a) and (b) of the Transfer of Property Agreement (TOPA), dated
February 10, 1984, does hereby convey and quitclaim all of its right, title and interest in the
below-described real property to the Tanadgusix Corporation, the village corporation on St. Paul
Island, Alaska (hereinafter the "TDX" or "Grantee"), to wit:1
Tract 46, Sec. 25, T. 35 S., R. 132 W., Seward Meridian, Alaska, as shown on
Dependent Resurvey of a Portion of Tract A, U.S. Survey No. 4943, St. Paul
Townsite and the Dependent Resurvey of Portions of and Subdivision of Tract 41
into Tracts 45 and 46 plat of survey, officially filed June 3, 1997,
a true and correct copy of which survey is attached hereto as Exhibit A, commonly known as the
“Plant Site and Industrial Building Area (formerly known as Tract 41)” and the “West Landing
Area”, together with all rights, privileges, immunities, and appurtenances thereto belonging
(hereinafter referred to as the "Property").
The TDX hereby acknowledges the conditions of the Property and, with the sole
exception of the covenants made hereunder pursuant to Section 120(h) of the Comprehensive
Environmental Response, Compensation and Liability Act, 42. U.S.C. § 9620(h) (CERCLA),
accepts the Property without warranty or representation under this quitclaim deed, and without
recourse to the NOAA or the United States pursuant to this quitclaim deed.
Ingress and egress to nineteen monitoring wells as indicated on Exhibit B, including periodic
sampling from the monitoring wells, and closure of the monitoring wells consistent with
direction from the State of Alaska Department of Environmental Conservation.
Grantor states that in accordance with the direction of the Alaska Department of
Environmental Conservation ("ADEC"), an agency of the State of Alaska, corrective action has
been taken on the Property and completion of such corrective action is further evidenced by a
certain "Closure of the St. Paul Island, Alaska Operable Unit" letter dated June 4, 2008,
concurred with by ADEC, a true and correct copy of which is attached hereto as Exhibit D.
Corrective action locations specific to the Property are listed in Exhibit D as NOAA Sites 18
(TPA Site 9c), 19 (TPA Site 9d), 20 (TPA Site 9e), 21 (TPA Site 9f), 22 (TPA Site 9g), 23 (TPA
Site 9h), 25 (TPA Site 9j), 27 (TPA Site 9l), 28 (TPA Site 9m), 29 (TPA Site 10), 49 (TPA Site
9n), and 51 (TPA Site 9p). |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73110 name: auto-generated pm edit TPA 09E STP Machn Shop/Muni. Garage |
Louis Howard |
| 5/24/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 2016 groundwater monitoring report. With the 2016 revised 18 AAC 75 regulations & subsequent amendments on March 23, 2017, there is no more 10X Rule or 10X ACLs for soil or GW as they are no longer protective. The cleanup levels for Cleanup Complete determination will be based on complying with Table C GW cleanup levels or an alternative cleanup level under Method Four (risk assessment). Methods One, Two, & Three do not modify GW cleanup levels. Current site concentrations in GW will be compared to the new cleanup levels. Human Health based soil cleanup levels should be used instead of 10X rule concentrations. Closure with institutional controls may be appropriate for those sites with GW plumes that are demonstrated to be “stable or decreasing”.
Also any contaminant which exceeds 1/10th the current (2017) cleanup level in GW will also need to be included in cumulative risk evaluation/calculations (except for DRO & GRO). The cumulative risk calculator can be found at: https://csites.ornl.gov/cgi-bin/risk_search & the instructions for the calculator can be found here http://dec.alaska.gov/spar/csp/docs/Cumulative%20Risk%20Calc%20Instructions.pdf
ADEC requests NOAA begin assessment of vapor intrusion pathway for occupied buildings within thirty feet of wells that exceed GW target levels in ADEC’s Vapor Intrusion Guidance for Contaminated Sites (January 2017) Steps 1 through 11 (as applicable). For wells that exceed target screening levels with no current occupied buildings, there still needs to be consideration for VI intrusion for future buildings that may be built.
Ethylbenzene: MW46-6, MW46-10, MW46-28 (Highest level of ethylbenzene detected in GW at 972 ug/L). The levels detected in these wells exceed residential & commercial target levels.
Xylenes: MW46-6 (exceeds residential target level), MW46-10 (exceeds residential target levels & exceeds commercial target levels in the fall – October), MW46-28 (Highest level of xylenes detected in GW at 3,982 ug/L or 3.982 mg/L. Exceeds both residential & commercial target levels).
Temperature adjustment for GW target levels: GW target levels are calculated by applying the Henry’s Law Constant to the concentration in GW in order to estimate the concentration in soil gas. ADEC uses a constant based on a temperature of 25ºC. The investigator may propose alternative GW target levels using a Henry’s Law Constant adjusted for the GW temperature documented at the site. For assistance with this calculation see http://www.epa.gov/athen.learn2mode l/part-two/onsite/esthenry.html.
A review of the GW sampling data sheets in Appendix B shows GW temperatures from 5.65oC (MW46-6) to 4.72oC (MW46-10) to 6.08oC (MW46-28) all below 25oC.
See site file for additional information. |
Louis Howard |
| 10/20/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the draft report for groundwater monitoring. Staff noted that a few wells were above the screening levels for ethylbenzene and total xylenes (e.g. 699 ug/L and 3,210 ug/L respectively for Well MW46-28). As was previously required in comments submitted to NOAA, ADEC requests NOAA begin assessment of vapor intrusion pathway for occupied buildings within thirty feet of wells that exceed groundwater target levels (during October or May) in ADEC’s Vapor Intrusion Guidance for Contaminated Sites (January 2017) Steps 1 through 11 (as applicable). For wells that exceed target screening levels (either in October or May) with no current occupied buildings, there still needs to be consideration for VI intrusion for future buildings that may be built.
See site file for additional information. |
Louis Howard |
