| Action Date |
Action |
Description |
DEC Staff |
| 10/31/1983 |
Update or Other Action |
Disposal of Federal property on Pribilof Islands (the Pribilofs)- (a) Submission to Congress of property transfer document - Any provision of law relating to the transfer & disposal of Federal property to the contrary notwithstanding, the Secretary, after consultation with the Secretary of the department in which the Coast Guard is operating, is authorized to bargain, grant, sell or otherwise convey, on such terms as he deems to be in the best interests of the United States (U.S.) & in furtherance of the purposes of this chapter, any & all right, title, & interest of the U.S. in & to the property, both real & personal, held by the Secretary on the Pribilofs: Provided, That such property is specified in a document entitled "Transfer of Property on the Pribilof Islands: Descriptions, Terms & Conditions," which is submitted to the Congress on or before October 31, 1983.
(b) Contents of property transfer document - shall include, but need not be limited to: (1) a description of each conveyance; (2) the terms to be imposed on each conveyance; (3) designation of the recipient of each conveyance; (4) a statement noting acceptance of each conveyance, including the terms, if any, under which it is accepted; & (5) an identification of all Federal property to be retained by the Federal Government on the Pribilofs to meet its responsibilities as described in this chapter & under the Convention.
(c) Report to Congress of fair market value of transferred property - Within 60 days of the transfer of real or personal property specified in the document described in subsection (a) of this section, the Committee on Merchant Marine & Fisheries of the House of Representatives & the Committee on Commerce, Science, & Transportation of the Senate shall be given a report prepared by the Secretary stating the fair market value at the time of the transfer of all real & personal property conveyed.
(d) Memorandum of Understanding (MOU)- A MOU shall be entered into by the Secretary, a representative of the local governmental authority on each Island, the trustee or trustees, & the appropriate officer of the State of Alaska (the State) setting forth the respective responsibilities of the Federal Government, the Trust, & the State regarding - (1) application of Federal retirement benefits, severance pay, & insurance benefits with respect to Natives of the Pribilofs; (2) funding to be allocated by the State for the construction of boat harbors on St. Paul & St. George Islands; (3) assumption of the State of traditional State responsibilities for facilities & services on such islands in accordance with applicable laws & regulations; (4) preservation of wildlife resources within the Secretary's jurisdiction; (5) continued activities relating to the implementation of the Convention; (6) oversight of the operation of the Trust established by section 1166(a) of this title to further progress toward creation of a stable, diversified, & enduring economy not dependent up commercial fur sealing; (7) the cooperation of government agencies, rendered through existing programs, in assisting with an orderly transition from Federal management & the creation of a private enterprise economy on the Pribilofs as described in this chapter; & (8) such other matters as may be necessary & appropriate for carrying out the purposes of the chapter, including the assumption of responsibilities to ensure an orderly transition from Federal management of the Pribilofs. |
Louis Howard |
| 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.
6) When test results are available, the contractor must provide the following: a) test results, b) ADEC and EPA regulatory requirements for disposal, c) Proposed detailed plan for disposal of materials, d) Documentation that the contractor has certified personnel to handle and dispose of hazardous waste, 3) Provide a detailed cost estimate for the disposal of the material and any additional remediation required including labor, materials, equipment, testing, etc., f) provide a schedule for the final removal of any stockpiled materials.
7) The City and NOAA must approve the proposed plan and costs for disposal of the materials which were stockpiled prior to any construction activity. (Issued 10/01/1993). |
Ray Dronenburg |
| 10/19/1993 |
Update or Other Action |
Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation.
Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it.
The current construction season has passed, to allow us the necessary time to schedule the equipment; NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. |
Ray Dronenburg |
| 11/2/1994 |
Update or Other Action |
CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP.
Environmental Protection Agency (EPA) Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. Department of Commerce (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.
NOTE To file: SEC. 120. FEDERAL FACILITIES.(a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.—
(1) IN GENERAL.—Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act.
Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107.
(2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.—
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located,
applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities
shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines,
rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act.
(3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility
which is owned or operated by any department, agency, or instrumentality of the United States.
(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 or facilities that are the subject of a deferral under subsection (h)(3)(C) 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 |
| 5/2/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson. |
S&W |
| 12/15/1996 |
Update or Other Action |
In 1996, an expanded site investigation detected the presence of total petroleum hydrocarbons (TPH) in the vicinity of the Fuel Transfer Facility. No GRO or kerosene was detected in any samples near the Fuel Transfer Facility. |
Ray Dronenburg |
| 12/10/1997 |
Site Number Identifier Changed |
Incorporated data from Reckey 1994250135427 into Reckey 1994250135426 because this Reckey (26) is being treated as a group of spills. However, 11/4/99 broken back out for tracking purposes. |
Ray Dronenburg |
| 9/30/1998 |
Update or Other Action |
Jacobs Engineering Group Inc. Investigation Workplan received. Data quality objectives: Initial sampling round will try to determine if Tract 41 can be closed. Plan is to collect soil samples from up to 3 borings per site, install monitoring wells, and collect groundwater samples from each well. Comments in document: sampling is limited to one soil sample from the most contaminated interval and one groundwater sample at each boring/well, PCB analysis at only one well. Analyses: GRO, BTEX, DRO, RRO, PAH, RCRA metals, for all 3 wells, PCBs for 1 well. |
Ray Dronenburg |
| 10/29/1998 |
Update or Other Action |
ADEC letter to Minh Trinh NOAA re: request to close UST sites in Tract 41 Area. August 27, 1998 letter from NOAA requested closure of UST sites in Tract 41 area. None of the seven (7) USTs identified on St. Paul Island qualifies for No Further Action and may require additional investigation or corrective action. Per 18 AAC 78, “closure” of an underground storage tank is defined thus: 18 AAC 78.995(19) “close” has the meaning given that term in AS 46.03.375(g)(1); AS 46.03.375(g)(1) “close” means to remove petroleum and sludges from the tanks in the tank system and either fill the tanks with inert solid material or remove, dismantle, and dispose of the tanks”;
18 AAC 78.085(c) To permanently close a tank, the owner or operator shall empty and clean it by removing all liquids and accumulated sludge. A UST that is to be closed must be removed from the ground, along with all associated piping, or filled with an inert solid material. A UST with a known or past release must be removed from the ground unless the department, in its discretion, allows the tank to remain in place because removal of the tank would endanger existing structures. The resulting excavation must be investigated and cleaned up as required by 18 AAC 78.230 – 18 AAC 78.350. The owner or operator shall document the name of the disposal method, and the disposal location for all liquids, sludges, and UST components, including tanks, piping, and equipment.” 18 AAC 78.090(a) When performing permanent closure or a change-in-service, the owner or operator shall complete a site characterization and, depending on the results of the site characterization, perform a site assessment or release investigation.”
Under these definitions, not all the tanks within Tract 41 meet the definition of “closed”. Rather than reiterate the contents, I enclose a copy of the February 27, 1998 letter to re-familiarize you with the specific data gaps. NOAA is obliged to continue investigating the release and to perform corrective actions, as deemed necessary by the Department. Per regulations, site characterizations and assessments were performed during tank removal activities and the releases were reported in a timely manner.
However, the required release investigations for these sites have not taken place. 18 AAC 78.235(g) requires submittal of a release investigation report within 45 days of the date the confirmed release was reported to the Department. This has not occurred. 18 AAC 78.240 requires an interim corrective action report informing the department of the status of the cleanup actions within 60 days after the date of release confirmation. This has not occurred. Your agency is seriously behind schedule.
Due to the nature and scope of the work to be performed on both St. George and St. Paul Islands, the Department has thus far chosen to be lenient when enforcing deadlines, including those set forth in regulation and the Two-Party Agreement. We recognize the need to prioritize work and to set reasonable milestones and it is our intention to work in conjunction with NOAA and representatives of both islands to achieve acceptable levels of cleanup and to do so within schedules that consider the needs of all parties. Unfortunately, NOAA has missed an entire field season in which they might have accomplished these goals.
For additional information see site file. |
Lynne Bush |
| 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 |
| 4/7/1999 |
Meeting or Teleconference Held |
Restoration Advisory Board Meeting held at the Captain Cook Hotel. Risk based cleanup under Alaska cleanup rules: 18 AAC 75 Methods 1, 2, 3, 4 presented. Public Law 104-91 as it pertains to community issues and concerns related to cleanup and local hire, NOAA organizational chart, accounting of budget for all funds received, uses of the funds requested again by ADEC as was presented in 1/6/999 letter to NOAA was discussed at the RAB meeting. Finally discussed projects planned for the future at the Pribilofs, how clean is clean and whether or not community buy in is required to assign a no further remedial action required or closure of sites for either island. Ray Dronenburg announced that as of April 5, 1999 he is no longer the project manager for the site, Louis Howard is the new project manager for ADEC.
|
Ray Dronenburg |
| 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 |
| 7/21/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into final site characterization plan for Tract 46 and data gap analysis/conceptual site model. |
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. |
Jennifer Roberts |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plant to be reviewed and commented on by ADEC on 1/14/2000. Contractor to mobilize in field on May 2000. |
Louis Howard |
| 12/11/1999 |
Update or Other Action |
In 1999, DRO soil concentrations (1,100 mg/kg) 2 feet bgs exceeded the ADEC Method Two cleanup criterion of 250 mg/kg at sampling location DPASB-1 on the West Dock. This location is just below the pump house (Figure 10); RRO at this same location recorded at 8,600 mg/kg or below the ADEC Method Two cleanup criterion of 10,000 mg/kg. |
Louis Howard |
| 2/18/2000 |
Update or Other Action |
Staff commented on the draft final site characterization plan for Tract 46 and adjoining properties. Staff clarified sampling depth for surface soil is from 0-2' not 0-2cm for analyzing exposure from inhalation of particulates, ingestion, dermal contact and inhalation from contaminants other than particulates. Sampling depth for subsurface as stated in the risk assessment procedure manual is ten feet. |
Louis Howard |
| 5/5/2000 |
Update or Other Action |
Staff sent comment letter to NOAA on draft final site characterization plan for tract 46 and adjoining properties. The text in paragraph 3 also states that the sampling depth will be no greater than 2 centimeters (cm), in accordance with ADEC guidance (Risk Assessment Procedures Manual). This statement would be correct if NOAA and ADEC were only concerned with particulates (liquid or solid particles such as dust, smoke, mist, or smog found in air emissions). Since the work for this site is not limited to particulates, ADEC requests NOAA sample beyond the first 2 cm for surface soil sampling. This sampling effort would ideally be from the 12-18” interval, but no deeper than 2’. Surface soils are defined in regulations as “...soil that extends no more than 2’ below the surface.”
Furthermore, the ADEC Risk Assessment Procedures Manual for Section 3.2.2.5 defines what depths are generally considered when sampling surface and subsurface. It states that for all land uses, ADEC will generally use a default value of two feet to define surface soil and ten feet to define subsurface soil to which residents will have a reasonable potential to be exposed (ingestion, dermal contact, and inhalation).
There appears to be a discrepancy between 18 AAC 75(j)(2) which states that cleanup must be achieved in the subsurface soil to a depth of at least fifteen (15) feet and section 3.2.2.5 of the Risk Assessment Procedures Manual. Section 3.2.2.5 states that for all land uses, ADEC will generally use a default value 10 feet to define subsurface soil to which residents will have a reasonable potential to be exposed (ingestion, dermal contact, and inhalation).
Until the issue can be corrected in the Risk Assessment Procedures Manual at a later date, ADEC will require NOAA to meet cleanup levels which prevent human exposure from ingestion or inhalation of a volatile hazardous substance in the surface soil and the subsurface soil to a depth of at least fifteen feet. Fifteen feet is the minimum depth which ADEC considers it reasonably likely for affected soils to be excavated and brought to the surface during the installation of septic systems, utilities, construction of basements, etc.
Upon incorporation of the above comments, ADEC will consider it a "final" document. |
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 |
| 3/28/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter.
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.”
With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows:
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.
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. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. |
Louis Howard |
| 5/25/2001 |
Long Term Monitoring Established |
Staff reviewed and commented on the groundwater monitoring plan which covered TPA 2, 5, 9, 11, 15. Comment was on the lack of current lab certification listed in table 10 for two labs. Staff requested proof of current certification and corrected table in the document with latest expiration date. |
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 |
| 4/17/2002 |
Update or Other Action |
Staff reviewed and commented on the Draft Annual Groundwater Monitoring Report 2001 St. Paul Island March 2002 Project 823255.01030000. 2.3 Village Hill Plume Pages 2-5 and 2-6.
The text states that chromium was detected in samples collected from all four wells up to 5,200 ug/L. NOAA used a Hach kit to perform hexavalent chromium analyses (Diphenyl-carbazide method) screening. The kit uses a Diphenyl-carbohydrazide (DPC) to form an intensely colored complex with Cr(VI). The complex is measured quantitatively by its visible absorption at 520 nm.
However, as in any colorimetric analysis, this test is subject to positive interferences from other colored materials in the sample as well as from other elements that form colored complexes with DPC. The Department views the Hach kit testing as a field screening method and data gathered by field screening never is substituted for laboratory analyses. The only acceptable determination on whether the Cr(VI) is present in a water sample is through laboratory analyses. For example, there are methods available such as:
EPA method 218.6, or SW-846 Methods 7000 series method 7195 (coprecipitation) is used to determine Cr(VI) in EP extracts and groundwater, or method 7198 differential pulse polarography used to determine Cr(VI) in natural and wastewaters and in EP extracts, or method 7199 often used for determination of Cr(VI) in drinking water, groundwater and industrial wastewater effluents by ion chromatography.
The Department requests NOAA confirm the validity of Hach kit test results through a strict laboratory analyses using an approved Cr(VI) analytical method for groundwater results where chromium was detected in the groundwater. After determining through laboratory analysis that hexavalent chromium is not present above the Table C Groundwater Cleanup level of 100 ug/L, then NOAA may discontinue analysis for this particular parameter.
2.6 Recommendations for Central Tract 46 Page 2.8
See comments above regarding laboratory analysis of water for hexavalent chromium Cr(VI) to validate the field screening with Hach kits. The Department concurs with semi-annual monitoring of contaminants of concern (COCs) at Tracts 43 and 46. The Department will require monitoring for the following COCs : gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, lead, selenium, hexavalent chromium, and tetrachloroethylene.
The Department requests groundwater monitoring of tetrachloroethylene not be limited to MW46-9, but also include MW46-23. MW46-23 will act as a sentinel well to ensure that tetrachloroethylene is not spreading beyond MW46-9. The Department requests that groundwater flow direction be described in the text and shown on the figures for the sites. |
Louis Howard |
| 5/30/2002 |
Cleanup Level(s) Approved |
The Alaska Department of Environmental Conservation (the Department) has received the draft final groundwater use and classification in the vicinity of Tract 46 TPA 9 on May 6, 2002. Department staff also attended and participated in a briefing given by NOAA regarding the 18 AAC 75.350 10X Table C groundwater cleanup levels in the Tract 46 (TPA 9) area on May 9, 2002. Below are the Department’s general comments regarding NOAA’s request for a 10X rule determination for groundwater at Tract 46. Specific comments regarding the document referenced above will be addressed in another letter to NOAA.
General Comments
After reviewing the data and hearing NOAA’s briefing, the Department will approve the use of a 10X rule for groundwater cleanup levels in Tract 46. This approval does not modify the Water Quality Standards found in 18 AAC 70, which NOAA must comply with where applicable. The rationale for the Department’s approval is based on these site-specific conditions listed below:
-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, and electrical conductivity NOAA has measured in the Tract 46 area.
-The groundwater is not currently used for drinking water and 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.
For additional information see site file. |
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 GW 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 GW is not currently used for drinking water & there is no anticipated future use of GW 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 GW 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 |
| 8/29/2002 |
Update or Other Action |
Staff sent response to TDX attorney letter regarding use of 10 times (10X) rule in Tract 46 area.
The Alaska Department of Environmental Conservation (the Department) received your letter of August 1, 2002 on behalf of Ron Philemonoff, CEO of the Tanadgusix Corporation (TDX). Your letter inquired about the impact of the 18 AAC 75.350 ten times (10X) groundwater cleanup levels to the Two-Party Agreement (TPA) site 9 commonly referred to as Tract 46 (the study area) on St. Paul Island.
The 18 AAC 75 Contaminated Sites regulations defines “cleanup” and “cleanup levels” as follows: “cleanup” means efforts to mitigate environmental damage or a threat to human health, safety, or welfare resulting from a hazardous substance , and includes removal of a hazardous substance from the environment, restoration, and other measures that are necessary to mitigate or avoid further threat to human health, safety, or welfare, or to the environment; and “cleanup level” means the concentration of a hazardous substance that may be present within a specified medium and under specified exposure conditions without posing a threat to human health, safety, or welfare, or to the environment.
The higher cleanup levels NOAA is requesting for the study area is literally ten times (10X) those found in 18 AAC 75.345 Groundwater Cleanup Levels Table C and in most cases, those levels found in 18 AAC 75.341 Table B1 Method Two. For example, if diesel contamination were detected in the groundwater above Table C cleanup levels, then the cleanup level for diesel in soils would be 10X the migration to groundwater level.
If diesel contamination were detected at or below the Table C cleanup levels in groundwater, then soil cleanup levels for diesel contamination would have to meet the more restrictive migration to groundwater level and would not be eligible for the 10X rule application. These higher soil cleanup levels would only apply to the migration to groundwater cleanup level and, in no case, will not exceed the ingestion, inhalation, or maximum allowable soil cleanup levels (whichever value is less).
After reviewing NOAA’s data, the Department has determined that applying the 10X rule for groundwater cleanup levels in the study area is appropriate. This approval does not modify the Water Quality Standards found in 18 AAC 70, which NOAA must comply with whether or not a 10X rule determination is made. For example, where groundwater is closely hydrologically connected to surface water, water quality standards in 18 AAC 70 must be met for surface water and sediment.
The rationale for the Department’s approval is based on the site-specific conditions listed below:
The groundwater in the study 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, and electrical conductivity NOAA has measured in the study area. The groundwater is not currently used for drinking water and there is no reasonable expectation of a future use of groundwater as a drinking water source in the study area. All residents obtain their drinking water from the public water supply system located 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 the study area is adequate to meet all anticipated future needs for drinking water.
For additional information see site file. |
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 |
| 1/28/2004 |
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 Fuel Transfer Station TPA 9P, 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” requires approval from the Department in accordance with 18 AAC 75.325(i).
|
Louis Howard |
| 1/28/2004 |
Conditional Closure Approved |
ADEC Staff reviewed and commented on the Draft Corrective Action Report for West Dock Fuel Transfer Facility TPA Site No. 9P and Decommissioned Power Plant Annex TPA Site No. 9D, St. Paul Island dated January 2004.
The Alaska Department of Environmental Conservation (the Department) received the above document on January 20, 2004, for the West Dock Fuel Transfer Facility (WDFTF) TPA Site No. 9P.
Based on our review of the document, the Department finds the remaining soil contaminated with diesel range organics (DRO) has been removed to the maximum extent practicable by NOAA.
In the case of the WDFTF, refusal was encountered in Area 1 and 2, a pump house located to the north, and a live electrical line, combined with an access road limited expansion of the excavation laterally in Area 2. NOAA has already removed approximately the majority of petroleum contaminated soil associated with this site. These facts, combined with the remaining site conditions, the Department has determined that no further remedial action is required for TPA Site No. 9P, which is equivalent to certification by the Department that corrective action is complete under TPA section 59. Closure of Sites of Operable Units.
It 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 SP19-CS-028-150 (10,000 mg/kg DRO), SP19-CS-034-150 (9,600 mg/kg DRO), 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 ten-times rule area requires approval from the Department in accordance with 18 AAC 75.325(i).
The Department 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 the Department at TPA 9D and TPA 9P, if information becomes available that contamination is present at these sites which pose an unacceptable risk to human health or safety, welfare, or the environment. Please provide the Department with a description and map of the location of any monitoring wells located near the sites which may be used to monitor any potential migration of contaminants from these sites. Monitoring will be required to demonstrate that DRO (and any other contaminant attributed to the sites) is at or below the ten times rule cleanup level for groundwater established for this area.
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.
For additional information see site file. |
Louis Howard |
| 12/3/2004 |
Site Added to Database |
Site duplicated from TPA 09D STP Decomm Power Plant Annx, Reckey 1994250135426. |
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 Fuel Transfer Station and Pipeline (Receiving Warehouse) Site 9p has had contaminated soil associated with either a UST/AST/Pipeleine.
Site conditions: Residual soil contaminated with DRO and benzene remain along buried utilities south of the transfer pump station; benzene does not exceed 1991 criterion of 0.5 mg/kg; DRO exceeds 10x rule criterion in limited areas; 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 |
| 7/6/2012 |
Update or Other Action |
Staff provided comments on the Draft St. Paul Tract 46 Quit Claim Deed for 9c, 9d, 9e, 9f, 9g, 9h, 9p, 9m, 10, 9n, 9j, and 9l.
5 Acceptance of Property
ADEC requests NOAA make this section broader to provide access to the general area for groundwater monitoring purpose (e.g. use the language cited in the third paragraph under “Hazardous Substance Warranty”). NOAA may need to replace wells or possibly install new wells in the general area.
Hazardous Substance Warranty
Public Law 106-562, Section 107 Authorization of Appropriations states: “Limitation- None of the funds authorized by this subsection may be expended for the purpose of cleaning up or remediating any landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, or contaminants, including petroleum products and their derivatives, left
by the Department of Defense or any of its components on lands on the Pribilof Islands, Alaska.”
Please change “waste dumps” to “wastes, dumps”.
Deed Restrictions/Groundwater Restrictions
ADEC is concerned about monitoring well replacement or installation of new monitoring wells in close proximity to the existing ones, if determined to be necessary. See comment #1 above regarding additional language and the need in the future for NOAA to replace wells or install new ones.
Deed Restrictions/Soil Removal Restrictions
The Exhibits listing has two F-4s, perhaps the second one is supposed to be F-5?
|
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73121 name: auto-generated pm edit TPA 09P STP Fuel Transfer Station |
Louis Howard |
