| Action Date |
Action |
Description |
DEC Staff |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV).
Reportedly this site is made of 3 separate areas. One is located on the Lukanin Bay northeast of the current tank farm. Debris is scattered within some of the dune areas adjacent to the road (radiators, drums, engines, rusted metal fragments). No visibly stained soil or stressed vegetation was observed during the E and E site visit. 2nd and 3rd areas are reportedly along the left and right sides of the road that leads away from Lukanin Bay and up to Diamond Hill. Debris is reported to be buried at these locations including drums, government surplus equipment, jeeps, and other industrial waste. The debris has been covered and the areas vegetated (Philemonoff and Krukoff 1993). E and E learned of these 2 additional areas after the site visit and therefore did not visit them. A geophysical study is recommended to locate and determine the extent of debris disposal. Recommendations: To determine if POL or CERCLA contamination is present in the soils. Geophysical survey should be conducted prior to sampling to determine location of the debris. |
Jennifer Roberts |
| 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 |
| 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 |
CERCLA SI |
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).
RCRA ID AK0131490021 CESQG CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. 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 accordingly.
EPA's NFRAP designation will NOT relieve NOAA 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.
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 |
| 12/19/1994 |
Update or Other Action |
Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy-Re: outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes.
NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island.
These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump.
18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. |
Simon Mawson |
| 6/1/1995 |
Site Added to Database |
Site added to database. |
Ray Dronenburg |
| 8/2/1995 |
Preliminary Assessment Approved |
(Old R:Base Action Code = SA2R - Phase II SA Review (CS)). Approved an Environmental Site Assessment. |
Ray Dronenburg |
| 5/2/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson |
S&W |
| 6/30/1996 |
Update or Other Action |
Hart Crowser Expanded site investigation received. HA-2 8' deep had 2,200 mg/kg RRO contamination. Refusal was met at 9' for HA-2 and TP-6 so depth of elevated oil concentrations could not be determined. Total volume of contaminated soils above level B criteria range from 630 to 1,350 cubic yards. Subsurface debris was found to be throughout the site and volume of debris was estimated to be between 2,000 and 6,000 cubic yards. Consultant recommended no further action for oil impacted soils at the site even though Category B criteria was exceeded. No exposure routes exist and severe environmental damage would occur to the fragile dune environment if excavation and removal took place. Subsurface debris should be addressed in accordance with Public Law 104-91 as appropriate. Consultant again recommended NFA for debris due to dune environment being damaged from removal actions. |
Ray Dronenburg |
| 1/17/1997 |
Update or Other Action |
Letter to Minh Trinh NOAA PPO PM, UST comments to be covered under separate comment letter relating to any and all activities relating to removal of USTs. Comments mainly for portion of the plan that deals with debris removal and stockpiling of contaminated soils.
a) The stockpile plan identified in section seven (7) is approved as written.
Debris Removal (vehicles). The Department does not assume nor will the contractor "assume" that vehicles identified as debris under the TPA are free from hydrocarbons. In fact, the Department will require that all vehicles be checked for fluids before being compacted and stockpiles for shipment off island.
Open Burning. The department has promulgated new regulations regarding open burning. The document dated January 18, 1997 has been provided by the contractor. |
Ray Dronenburg |
| 7/9/1997 |
Update or Other Action |
Signed by ADEC on 7/9/1997 and NOAA on 7/14/1997. Status update for TPA sites St. Paul island. Although ESI recommends no further action, ADEC suggested surface debris removal is required. Surface debris removal is included as an option in the FY97 Cooperative Agreement. Renegotiated. Draft Management Plan due 7/17/1997, Final Debris Management plan due 9/6/1997. Draft Debris removal report due 12/22/1997. Final debris removal report due 3/16/1998. |
Ray Dronenburg |
| 3/9/1998 |
Update or Other Action |
May 1997 Aleutian Enterprises Workplan for environmental sampling during removal action at the site received. Soil samples for VOCs, SVOCs, Organic PCBs, Pesticides, Metals, TPH, GRO/BTEX, DRO, RRO, were included in the plan. However, in the NOAA scope there were no provisions for laboratory analysis, or site characterization since it mainly focused on debris removal. |
Ray Dronenburg |
| 3/19/1998 |
Update or Other Action |
1997 Aleutian Enterprises JV Close Out report received. Surface metallic debris was removed from the site. No attempts were made to field screen for contaminated soils nor were any soil samples taken to confirm the presence or absence of contamination. Not in scope of work given to contractor. |
Ray Dronenburg |
| 5/20/1998 |
Update or Other Action |
Laura Ogar Solid Waste Program re: Expectations for Remaining Work and Regulatory Compliance for Solid Waste Projects Pribilof Islands. Of primary importance to the Department will be NOAA's assessments of the source areas (SA) to identify the extent of solid waste and any solid waste impacts at each site. Specific expectations for the SA's include:
Documentation at SA's containing buried waste must include and estimation of the footprint area and depth of the waste material and include the site longitude and latitude to accurately identify the waste disposal area. Information on groundwater (depth to, gradient, etc,) must also be provided.
Information must be provided on the depth to groundwater as a potential receptor for contamination if buried waste is present and/or suspected surface contamination is sufficient to warrant concerns for leaching. Where surface debris has been removed, the Site Investigation will be required to include evidence to support a conclusion that surface contamination does not exist.
Any surface debris removal must be fully documented to include a description of the volumes and types of wastes removed, and identify the approved final disposal location of any wastes removed from a SA through tipping fees, shipping records, etc.
Locations where buried waste will remain in the ground, solid waste landfill closure standards of 18 AAC 60 must be met. Typical landfill closure standards include the placement of final cover over the buried waste footprint to minimize infiltration and erosion. The applicable closure standards for the individual sites should be discussed with the SW Program staff prior to the development of a closure plan being developed. A closure plan must be submitted to the SW Program for review and approval prior to work being performed.
Permanent markers or survey monuments must be established from which the exact location of a facility can be determined. A notation must be recorded on the deed of the property containing the waste disposal site stating that the land has been used as a landfill and future use of the land may be restricted in order to protect and maintain the final cover and any monitoring devices in place.
Post closure monitoring for a period of five (5) years following the placement of final cover and landfill closure. Post closure monitoring will include but may not be limited to annual visual monitoring of the sites and required looking for signs of damage settlement or erosion. Surface and or ground water monitoring may be required if the department finds that pollution from the facility is likely to endanger public health or cause a violation of the water quality standards in 18 AAC 70. |
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 ($2000) for the first week (or portion thereof) and three thousand dollars ($3000) 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 |
| 8/20/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into TPA 12's final site characterization plan. |
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. |
Louis Howard |
| 9/30/1999 |
Update or Other Action |
Naming nomenclature from Two Party Agreement adopted, site information updated in database to reflect this. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received. ADEC to receive draft site characterization report on 2/29/2000 from NOAA. Corrective action plan to ADEC for review and comment on 5/13/2000 and field work to mobilize in August 2000. |
Louis Howard |
| 5/25/2000 |
Update or Other Action |
Staff reviewed and commented on the draft sampling and analysis plan for 6 TPA and 5 Non-TPA sites including this one. General comments included discussion on field screening protocols and the need to use devices in addition to olfactory and visual observations for identifying sampling locations. Staff also provided information on soil sampling procedures from the UST procedures manual to clarify the document's QCP/QAP. |
Louis Howard |
| 3/28/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force Majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff reviewed and commented on a draft site closure report for Lukanin Bay Debris site.
Pending NOAA’s formal request for closure and based on the ADEC’s review of the data presented in the report, the ADEC concurs the site does not require any further remedial action and can be considered closed. This closure is only for the site known as NOAA TPA Site 12 Lukanin Bay Debris. The ADEC is basing this determination on the most current and complete information provided by NOAA. The ADEC reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require NOAA to address the site by either performing additional containment, investigation or cleanup if subsequent information indicates that:
(1) additional contamination is discovered at this site, which poses an unacceptable risk to human health, safety, or welfare, or to the environment (which includes, but is not limited to: areas of public concern, ecological receptors, environmentally sensitive areas and marine waters); or
(2) the information that the ADEC relied upon (to make its decision) was invalid, incomplete, or fraudulent.
NOAA needs to be aware of 18 AAC 75.396 Local Control. It states: “Subject to AS 29.35.020, AS 46.04.110, and AS 46.09.060, the requirements of 18 AAC 75.300 - 18 AAC 75.390 do not preempt local control that is as stringent as, or more stringent than, those requirements, and that is consistent with a regional master plan prepared under AS 46.04.210." |
Louis Howard |
| 4/5/2002 |
Update or Other Action |
Staff reviewed and commented on the Draft Site Characterization Report Lukanin Bay TPA Site #12, St. Paul Island February 2002 Project 823255.03020000. The ADEC’s February 11, 2002 letter indicating concurrence with NOAA’s closure report is hereby withdrawn for Two Party Agreement (TPA) 12 also known as Lukanin Bay. A no-further-action determination will not be granted until all of the contamination discovered during IT Corporation’s site characterization is properly addressed in accordance with cleanup regulations.
The ADEC concurs with the majority of the recommendations for further work at this site as discussed in this section. Groundwater monitoring will only need to be conducted at MWLB-2 if migration to groundwater cleanup levels are to be used at the site. If NOAA chooses to implement Method 3 cleanup levels, then additional groundwater monitoring and wells will be required. In addition to the recommendations in this section, the ADEC requests that NOAA further delineate the extent of pesticide contamination associated with SP12-SB2-6-8.
The cleanup level for gamma-BHC (Lindane) is 3 ug/kg and NOAA detected 8.5 ug/kg. This particular contaminant does not lend itself to being treated through the Enhanced Thermal Conduction (ETC) system that NOAA is currently operating on the island. After NOAA has removed the Lindane contamination from the site, it would be more appropriate to ship Lindane contaminated soil/debris off island to a permitted treatment-storage-disposal facility.
The ADEC requests further clarification on whether the ETC system can successfully treat polynuclear aromatic hydrocarbons such as Benzo(a)pyrene found at the site. The cleanup level for Benzo(a)pyrene is 1,000 ug/kg for ingestion and 3,000 for migration to groundwater. NOAA detected 5,600 ug/kg in the 2 to 4 feet sampling interval. |
Louis Howard |
| 9/17/2003 |
Update or Other Action |
The Department has reviewed and will approve the Draft Remedial Design Investigation for TPA Site 12 – Lukanin Bay Debris Site, St. Paul Island dated August 29, 2003 as final. 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 approval does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, subcontractors from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 4/6/2004 |
Update or Other Action |
Staff reviewed and approved the draft remedial design investigation for pesticide characterization. The Department has reviewed and will approve the document as final. 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 approval does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, subcontractors from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 3/16/2005 |
Update or Other Action |
Staff reviewed the draft corrective action report for site 33 a.k.a. TPA 12c Lukanin Bay PCS site. Based on our review data provided by NOAA, ADEC concurs that no contamination, above applicable cleanup levels, remains at Site 33/Two-Party Agreement (TPA) Site 12c, CS Database Reckey no. 1994250135416. The site is located on the west side of Diamond Hill 1 mile northeast of the City of St. Paul and 200-300 ft. west of Lukanin Bay. ADEC 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 Site 12c if information becomes available that contamination is found which poses a risk to human health or safety, welfare, or the environment. |
Louis Howard |
| 5/5/2005 |
Site Closure Approved |
NOAA sent a request for NFRAP designation at the site to ADEC. ADEC concurred. In accordance with Paragraph 59 of the Two Party Agreement, this is to confirm that all corrective action has been completed at the Lukanin Bay Site, TPA Sites 12a, 12b, 12c/NOAA Sites 31, 31, 33 in accordance with the Agreement and that no plan for further remedial action is warranted.
However, please note that DEC reserves all of its rights under 18 AAC 75 and AS 46 to require NOAA to conduct further investigation and/or remedial action if information indicates conditions at the Lukanin Bay Site, TPA Sites 12a, 12b, 12c/NOAA Sites 31, 31, 33 pose a risk to human health, safety and welfare, and 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 Lukanin Bay petroleum contaminated soil TPA Site 12c has solid waste and contaminated soil. Site conditions as follows: Vegetated soil cap over excavation.
Property Owner as of November 6, 2007 is the Tanadgusix (TDX) for the surface estate and The Aleut Corporation (TAC) for the subsurface estate. |
Jennifer Roberts |
