| Action Date |
Action |
Description |
DEC Staff |
| 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 |
| 11/2/1994 |
Update or Other Action |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. |
Jennifer Roberts |
| 6/1/1995 |
Site Added to Database |
Diesel/kerosene contamination present. |
Ray Dronenburg |
| 5/3/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson. |
S&W |
| 6/30/1996 |
Update or Other Action |
Hart Crowser Draft Expanded site investigation received. According to Hart Crowser, 55-gallon drums of gasoline and diesel fuels were reportedly stored at this site prior to the 1960’s. Based upon an interview with a former island employee, Hart Crowser stated that a funnel fabricated from a 55-gallon drum allowed for the emptying of fuel drums. An archived photo from the 1950’s suggests that a large tank with a ramp leading onto it was used to dump the fuels. Regardless, gravity transported diesel fuel through above ground pipelines running easterly and downslope to a former above ground storage tank (AST) complex currently known as the AST Saddles. Other than a schematic depicting “Existing Barrel Storage Area” prepared in 1959, the PPO has not yet found any historical aerial or ground view photodocumentation demonstrating activities at the Drum Storage Site. The PCS found at the site by Hart Crowser (1997) is thought to result from spillage or leakage during storage and transfer operations.
Diesel range organics detected up to 15,000 mg/kg from test pits TP-8, TP-9, TP-14, and TP-16. TP-8/S-2 had 10,600 mg/kg DRO and TP-14/S-2 had 9,400 mg/kg DRO both at 4.5' depth where basalt refusal. Estimated volume of contaminated soils to be approximately 1,300 cubic yards. Recommendations were to excavate and remove accessible hilltop soils above Category C criteria down to basalt. No removal actions were recommended for the steep eastern slope between elevations of 80 and 60 feet. |
Louis Howard |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Louis Howard |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation.
Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard.
|
Louis Howard |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. Action entered by L. Howard. |
Jennifer Roberts |
| 12/15/2000 |
Update or Other Action |
In 2000, Columbia Environmental Sciences, Inc (CESI) installed groundwater monitoring well MWA-1 near the former Hart Crowser test pit as part of site characterization activities. Analytical data for soil samples collected during the well installation indicated DRO levels of 2,500 mg/kg from six to seven ft. bgs and 4,800 mg/kg from 38 to 40 ft. bgs. Additionally a soil boring near another test pit revealed DRO levels of 13, 000 mg/kg. MWA-1 had DRO at 1.5 mg/L Two wells located downgradient of the Former Drum Storage Area indicated the presence of DRO above cleanup levels however, these two monitoring wells are situated downgradient of other potential sources of contamination: TPA 9e Muni. Gar./Mach. Shop and TPA 9f Old Cascade Shed/Cascade Bldg. |
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 |
| 5/30/2002 |
Cleanup Level(s) Approved |
The Alaska Department of Environmental Conservation (the Department) has received the draft final GW use & classification in the vicinity of Tract 46 TPA 9 on May 6, 2002. Department staff also attended & participated in a briefing given by NOAA regarding the 18 AAC 75.350 10X Table C GW 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 GW at Tract 46. Specific comments regarding the document referenced above will be addressed in another letter to NOAA.
General Comments: After reviewing the data & hearing NOAA’s briefing, the Department will approve the use of a 10X rule for GW 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 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. 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 |
| 6/3/2003 |
Long Term Monitoring Established |
The Department will require long-term groundwater monitoring at the site. Groundwater contamination exists in MWA-1 above the Table C DRO 1.5 mg/L cleanup level. Groundwater depth is 80 feet bgs in an unconfined aquifer and generally flows to the north and east. Groundwater is not used for drinking water, and it is not expected that groundwater in this area will ever be used for drinking water. Based on analyses of existing data, groundwater beneath the City of St. Paul is considered brackish and is therefore not potable. |
Louis Howard |
| 6/16/2003 |
Cleanup Plan Approved |
Staff reviewed and commented on the Draft Corrective Action Plan for TPA Site 9O – Former Gasoline/Diesel Drum Storage Site, St. Paul Island dated June 3, 2003.
The Alaska Department of Environmental Conservation (the Department) received the above document on June 6, 2003. The Department has reviewed the document and approves it as submitted as a final document. |
Louis Howard |
| 12/21/2003 |
Update or Other Action |
Excavation at the former drum storage area removed a total of 1,160 cubic yards of petroleum contaminated soils. Depth of excavation ranged from 2 feet bgs on the east side to 6 feet bgs on the west side. The excavation was limited because of refusal caused by the presence of large boulders and to the east concerns regarding safety were an issue with the steep slopes of Village Hill.
Upon completion of the new stockpile location in Tract 42, contaminated soil was transported to this location. Soil which was staged at the Blubber Dump was moved to Tract 42 in October 2003. |
Louis Howard |
| 5/19/2004 |
Conditional Closure Approved |
Staff received a draft Corrective Action Report for TPA Site No. 9O Former Gasoline/Diesel Storage Area. Based on our review of the document, the Department finds the site conditions (refusal during excavation due to large boulders, slope stability of Village Hill, and bedrock) at TPA Site No. 9O do not pose a significant threat to human health or safety, or the environment. The Department has, therefore, determined that no further remedial action or soil sampling is required for this site. However, continued groundwater monitoring will be required since contaminated soil remains at the site at levels above those found in 18 AAC 75.341(b) Table B1 Method Two Soil Cleanup Levels. This determination is equivalent to certification by the Department that corrective action is complete under TPA section 59 Closure of Sites of Operable Units.
Section 59 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.” The Department requests NOAA identify the three closest wells that are located in the vicinity of TPA 9O which will be actively monitored for diesel range organics.
In the event that the remaining contaminated soil becomes accessible or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site 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 and 18 AAC 75 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions at TPA 9O if information becomes available that contamination is found at this site which is poses a risk to human health or safety, welfare, or the environment.
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. |
Louis Howard |
| 5/19/2004 |
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 Gasoline/Diesel Drum Storage TPA 9O, 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 |
| 4/17/2006 |
Update or Other Action |
The Critical Water Management Area (CWMA) precludes the use of groundwater from the aquifer within the boundary of the CWMA. The City of St. Paul provides an abundant and clean source of water to the homes and businesses within this area. The monitoring of the water quality in the CWMA will continue into the future, when and if the water quality improves to the point where it can be used, the designated CWMA can be revoked or amended to allow for full or limited use.
The extensive public notice and hearing process required to establish a CWMA resulted in no adverse comments to DNR’s designating the proposed area a CWMA. The establishment of the CWMA will keep current and future landowners with the CWMA from drilling, digging a well or otherwise removing groundwater from the CWMA.
NOAA has the intent and ability to meet the requirements required by ADEC to establishment a 10X rule for contamination clean up in the area of the CWMA . The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells.
The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells. The establishment of the CWMA will in no way effect the ability of the public to access navigable or public waters. |
Louis Howard |
| 5/1/2008 |
Update or Other Action |
NOAA files with the Alaska Dept. of Natural Resources a notice to deed # 2008-000214-0 Recording District:305-Aleutian Islands 5/1/2008 7 pages. Notice of Environmental Cleanup and Groundwater Contamination at TPA 9O, Gas/Diesel Drum Storage, St. Paul Island, Alaska. Pursuant to 18 AAC 75.375, Tanadgusix Corporation and the City of St. Paul as the owners, and the U.S. Department of Commerce/National Oceanic and Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice that the property located on Village Hill, St. Paul, St. Paul Island, Alaska 99660 is contaminated with petroleum products. More specifically, the site described as follows: Township 35 South, Range 132 West, Tract A, Lot 3, Section 25 and 35 South, Range 132 West, Tract A, undeveloped intersection of Village Street and Church Street, of the Seward Meridian, Alaska; and located at 57 degrees, 7 minutes, 21.93 seconds North Latitude; 170 degrees, 16 minutes, 57.02 seconds West Longitude (Figures 1 and 2) has been subjected to petroleum contaminated soil and groundwater contamination, as a result of a discharge, or release and subsequent cleanup of oil or other hazardous susbstances, regulated under 18 AAC 75, Article 3 as amended October 2005. If contaminated soil or solid wastes are exposed in the future, they must be managed in accordance with laws applicable at that time. These releases and cleanup are documented in the Alaska Department of Environmental Conservation (ADEC) contaminated sites database under the site number CS Reckey # 1994250135424; File ID 2644.38.023.015.
Following corrective action, NOAA submitted a request for conditional closure to the ADEC. NOAA's request stated further cleanup was impracticable because contaminated soils remained buried at the soil horizon where consolidated material (rock) impeded excavation (NOAA 2004). ADEC determined, in accordance with 18 AAC 75.325(f)(1) that site cleanup has been performed to the maximum extent practicable even though residual petroleum contaminated soils, primarily diesel range organics exist on the site property (Tetra Tech 2004). ADEC granted a conditional closure, in part to this institutional control (deed notice), and confirmed that no further remedial action was required at the site unless new information becomes available that indicates to ADEC that the site may pose an unacceptable risk to human health, safety, welfare to the environment (NOAA 2004).
Grantees: the Tanadgusix Corporation (grantee of the surface estate), 4300 B Street, Suite 402, Anchorage, AK 99503-5946
The Aleut Corporation (grantee of the surbsurface estate), 4000 Old Seward Highway, Suite 300, Anchorage, AK 99503
Recording District: Aleutian Islands.
This notice remains in effect until a written determination from ADEC is recorded that states that soil and/or groundwater at the site has been shown to meet the most stringent soil cleanup levels in Method Two of 18 AAC 75.341(c) and/or groundwater meets the cleanup levels in Table C in 18 AAC 75.345, and that off-site transportation of soil and/or groundwater is not a concern. |
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 Former Gasoline/Diesel Drum Storage Area Site 9o has had drums and contaminated soil associated with either a UST/AST/Pipeleine.
Site conditions: Residual soil contaminated with DRO and benzene remain, further removal limited by rock and/or slope grade. DRO exceeds 10x rule criterion in certain areas. Residual benzene in soils exceeded Method Two level of 0.02, but not above 1991 level of 0.5 mg/kg; long term groundwater monitoring (DRO contamination); deed notice
Property Owner as of November 6, 2007 is the Tanadgusix TDX Corporation (surface estate) Site is within the Critical Water Management Area (CWMA). |
Jennifer Roberts |
