| 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).
The tank farm consists of 12 20,000-gallon tanks with earthen berm. No evidence of an impervious liner was present for secondary containment requirements. Currently only six of the tanks are being used since the 70s when the former diesel tank farm was decommissioned. In 1987 or 1988, an additional 20,000-gallon tank was placed on the ground north of the tank farm outside of the earthen berm and is currently being used. Stained soil beneath the tank valve indicated a reading of 2 ppm on the PID. Areas of stained soil were also noted below the tank valve in the bermed area of the current diesel tank farm. The PID reading taken from the stained soil was 3 ppm (Buckel 1990; E&E 1992). The current diesel tank farm was originally designed to supply fuel through a pipeline to two USTs at the power plant. The city took over operation of the pipeline in 1983 and due to a discrepancy in volume of diesel being delivered (read: a leak in the system somewhere) through the pipeline, the city stopped using the pipeline in late 1983 or 1984. Because the city suspects the pipeline to be leaking, it currently uses tanker trucks to transport fuel from the tank farm to the USTs (E&E 1992, Malavansky 1993). Recommendation: determine the extent of POL contamination. |
Jennifer Roberts |
| 8/11/1994 |
Update or Other Action |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former NMFS facilities on Saint George Island. ADEC traveled with NOAA, their consultant, Tanaq Corp. and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol. NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills.
NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island, the site of an underground thermonuclear detonation in the 1970s. Our law are also clear about responsibility for these materials. That responsibility remains with the Federal Government.
One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability. Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable.
The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. |
Simon Mawson |
| 8/19/1994 |
Update or Other Action |
Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service Facility, Saint George Island response to July 20, 1994 NOV Letter. 1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS).
2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records.
Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in these reports.
3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas.
Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet.
During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. |
Janice Adair |
| 6/1/1995 |
Site Added to Database |
DRO and GRO. |
Ray Dronenburg |
| 5/3/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson. |
S&W |
| 10/31/1996 |
Cleanup Plan Approved |
Ray Dronenburg sent Polarconsult Inc. Dave Ausman, a contractor working on behalf of NOAA, an approval letter for containment cell design. Fax was received on 10/30/1996 for approval for a contaminated material storage cell. Unfortunately the fax copy was not clear enough to determine exact specifications, however, it is assumed (by ADEC) that ADEC guidance documents regarding contaminated material storage were considered in the design. (Plan states: "Since the containment cell will incorporate a water treatment system and regular maintenance program to process accumulating precipitation, Tanaq requests that the department waive the requirement for a top cover for the soil. The main reason for this request is that the top cover is expected to be problematic given the island's high winds and the need to uncover the piles on a daily basis."
ADEC's primary concern for the storage facility will be the protection of any surface water or groundwater sources. Having been to St. George on several occasions it would appear that the site selection would be near or on the old runway and not in the vicinity of any surface water sources, however, because of our discussion regarding cover for the stockpile and with a potential for leachate from the pile as well as rinsate from the UST activities, it might be prudent to develop at some point, a schedule for monitoring for excessive water accumulation.
The cell design and location are approved as submitted.
NOTE to file: Petroleum contaminated soils were from UST and Non-UST related sources encountered during FY97 Phase I Cooperative Agreement a.k.a. "Part I of the cleanup operations" on St. George Island. These include, but are not limited to, TPA 02 STG Former Drum Storage Area and TPA 03 Inactive Gas Station (oceanfront) (1624 cubic yards removed), TPA 10 STG Former Kerosene Drum/AST Storage Area, TPA 11 STG Cottage C UST (98 cubic yards removed), TPA 12 STG Former Hangar Building (195 cubic yards removed), TPA 21 Abandoned City Diesel Tank Disposal Site (1500 cubic yards removed), and TPA 23 Inactive/Abandoned Diesel Tank Farm (4,146 cubic yards removed.). |
Ray Dronenburg |
| 1/30/1997 |
Update or Other Action |
Hart Crowser January 1997 Expanded Site Inspection (ESI) received. Surface and subsurface soil samples were taken to assess potential contamination from past practices. Based on field lab analytical results indicate exceedances of ADEC NON-UST matrix cleanup levels at this site. Recommendations were to excavate and remove soils.
Diesel range organics (DRO) detected in the surface sample from TP-6 was 11,000 mg/kg and at 4' below ground surface was 9,400 mg/kg. Recommendations are to excavate and remove soil except in the vicinity of TP-3. Volume of contaminated soil to be removed is estimated at 1,110 to 2,370 cubic yards. TP-3 did not have sample results which indicated that it was impacted from petroleum hydrocarbons above action criteria. |
Ray Dronenburg |
| 7/7/1997 |
Update or Other Action |
Faxed letter received from Polarconsult to Ray Dronenburg and NOAA, City of Saint George dated February 7, 1997 regarding placement of concrete supports in open pits site (TPA 6). Faxed letter states: Please take a moment to formalize our verbal agreement to place the concrete tank supports in the Open Pit Site (tpa 6). Currently, the Saint George Tanaq Corp. is in the process of removing 25,000-gallon above ground fuel tanks from the inactive/abandoned diesel tank farm (tpa 23). As you are aware, these tanks are supported by large concrete "saddles". In Tanaq's application to NOAA it was proposed that these saddles be placed in the City's landfill (tpa 4). Recently, however, due to the plans to close the City's landfill and benefits to filling the adjacent Open Pits site (tpa 6), it was agreed that this concrete should be placed in the Pit.
Tanaq proposes to place the concrete in the vicinity of sample location TP-1 as defined in the June 1996 Expanded Site investigation prepared by Hart Crowser. Based on Hart Crowser's findings this location appears to be out of the contaminated zone and probably won't affect future remediation efforts. Tanaq proposes to cover the concrete with soil from the adjacent banks of the pit. The cover soil will not be from the known contaminated areas.
For your convenience, a signature blank has been provided below indicating your approval of these actions. Signed by Ray Dronenburg 2/12/1997. |
Ray Dronenburg |
| 7/17/1997 |
Update or Other Action |
Memorandum to M. Goetz Project Mgr. NOAA. RE: Permits for water discharge. 7/16/1997 Robert Dolan who handles permit system for discharge of wastewater suggested that rather than issue a specific permit for the discharge of waters from the stockpile site on St. George, he would approve Contaminated Sites staff handling the situation. Dave Ausman will add couple of pages to his monthly report to include: on a monthly basis, report the gallons of water collected from the stockpile berm and placed into the 20,000 gallon tank. Prior to any discharge, Polarconsult will then take batch samples to ensure that maximum contaminant levels (MCLs) for wastewater are not exceeded and then using the St. George sewage truck, move the water to the sewage outfall.
Lastly, Polarconsult will post a lookout to ensure that "sheen" does not occur. The only other alternative would be additional paper work (permitting process) to achieve the same results. Mr. Ausman is faxing Ray Dronenburg in a memorandum of understanding for the procedure and when the Department receives it will provide NOAA with a copy. The Department does not see any reason not to do the same thing on St. Paul.
7/17/1997 FAX Polarconsult to R. Dronenburg: Discharge of water from the soil containment cell. Water will be collected in the 20,000 gallon tank adjacent to the cell, batch analyzed, and transferred to the City of St. George's sewer system. The system is connected to an outfall line which discharges to the Bering Sea. The sample collection, analysis, record keeping, effluent limitations, and noncompliance notification will be performed in accordance with the procedures outlined in the ADEC waste water general permit #9240-DB005. In consideration of the mixing zone allowance, the effluent limitation will be 1 mg/L for Total Aromatic Hydrocarbons (EPA 602) and 1.5 mg/L for Total Aqueous Hydrocarbons (EPA 602+610) as allowed in appendix 1.B of the permit. The city of St. George has agreed to the discharge of water through the local sewer system provided ADEC indicates approval.
Signed and approved by Ray Dronenburg July 17, 1997. |
Ray Dronenburg |
| 11/11/1997 |
Update or Other Action |
St. George Tanaq Corporation (Tanaq), under a grant to NOAA, removed the fourteen ASTs and their appurtenances, and disposed of them off island as scrap metal, in 1997. Tanaq also performed a major PCS removal in 1997. Tanaq's objectives were the removal of the PCS identified by Hart Crowser and removal of additional PCS identified by fixed lab analyses, field screening with a PID, visual observations, and olfactory observations. Tanaq pursued these objectives until all petroleum contamination at or above the cleanup levels was removed or refusal was experienced. Refusal was encountered throughout much of the excavation. Tanaq removed and transported an estimated 4,150 cubic yards of contaminated soil to the PCS stockpile in 1997. Maximum depth of excavation was approximately 15 feet bgs. 40 final confirmation samples were collected and a maximum concentration of DRO was detected at 7,240 mg/kg. |
Ray Dronenburg |
| 6/24/1998 |
Update or Other Action |
R. Dronenburg letter w/L. Bush letter attached to Mr. Minh Trinh Pribilof Project Manager re: Contaminated Sites (LUST) stockpile St. George Island. On several occasions the Department has requested NOAA provide some sort of contractual assurance that leachate from the stockpile would be handled consistent with an earlier agreement. This assurance has never been achieved. Additionally and since the original agreement, extensive community concerns have been expressed for contamination spreading as caused by blowing material from the exposed stockpile, a concern the Department supports.
Please note that Ms. Bush has requested a thirty (30) day time frame be allowed for this action. The Department is aware that negotiations for the planned Phase II portion of this cleanup action has suffered considerable delay and therefore considers immediate cover as essential.
While the work plan detailing the construction of the stockpile was originally approved without a cover, it became apparent that a cover would be necessary to protect human health and the environment. After discussion of site conditions during a visit by Bush in March 1997, Mary Goetz, then Program Manager for this project, agreed to Bush's request to cover the stockpile. As of today, the stockpile has yet to be properly covered. On June 17, 1998, Department staff observed the stockpiled soil from the site not covered and has reportedly not been covered since the stockpile was created. Photos are enclosed of the stockpile not being covered.
The Department requests NOAA: cover the entire stockpile in accordance with 18 AAC 78.311 within thirty (30) days of receipt of this letter and provide written statement tot he Department within thirty (30) days of receipt of this letter documenting the stockpile has been covered. Please be aware that the Department may request sampling for secondary contamination in the areas under and around the improperly contained stockpile. Further, the Department may require calculations of air emissions and evaluation of the potential impact to human health and the environment. Evaluation of the potential impact to the seal haul-out located in close proximity to the stockpile may be required, as well.
The leachate collection system, designed and installed prior to the Department's request that the stockpile be covered, also does not appear to be in good working order. Please revise the existing workplan or submit a new workplan to the Department for review and approval, to include any needed repairs, replacement, long term maintenance, or decommissioning of the system, whichever is more appropriate to your long term plans for the stockpile. Include a schedule with your statement of proper containment that details the timetable for remediation and disposal of the soil contained in the stockpile.
*June 28, 1998 NOAA sent Photos to R. Dronenburg with letter stating stockpile has been properly covered and contained. |
Ray Dronenburg |
| 7/10/1998 |
Update or Other Action |
Saint George Tanaq Corporation letter to NOAA Tony Mercadante Federal Program Officer U.S. Department of Commerce WASC NOAA. Regarding letter of June 23, 1998 regarding the observations during your field trip to Saint George Island on June 1, 1998.
1. Access Barriers at Former Diesel Tank Farm TPA 23. Access barrier was down and requested that Tanaq repair the barrier and post a warning sign. |
Ray Dronenburg |
| 10/29/1998 |
Update or Other Action |
Letter to Minh Trinh NOAA Project Manager re: contaminated stockpile located at St. George Island requirement to cover and maintain the PCS stockpile. The Department has received and reviewed NOAA's response to the Department's September 1, 1998 letter. Due to the considerable length of time since the Department expected NOAA to take action to remediate the stockpile, and the continued lack of a work plan to do so, a cover is required. The leachate collection system should be inspected and maintained as well.
NOAA's points about the wind and weather in the Pribilofs have validity, however, the Department continues to require you to cover and maintain the stockpile in accordance with 18 AAC 78.311. Continual vigilance of the cover is necessary and the Department recommends that both it and the stockpile be inspected at least once per week and step to maintain the cover be taken as needed.
As Ray Dronenburg stated in the October 22, 1998 session of the Restoration Advisory Board, the contaminated stockpiles should be covered. In his October 27, 1998 letter to Nancy Briscoe, Breck Tostevin also indicated that the Department expects the stockpile to be covered. |
Lynne Bush |
| 11/12/1998 |
Update or Other Action |
Status update for TPA Site Number 23 OU 5. Site assessed during 1996/97 ESI. Residual liquids, 12 ASTs, piping, concrete footings, and bulk debris removed. 4,146 cubic yards of PCS and rock excavated, stockpiled and additional site assessment conducted during the FY97 Phase I CA. Renegotiated. Phase I Final Debris Removal report due February 1999. Phase II Draft work plan due March 29, 1999. Final work plan due April 26, 1999. Phase II site work will require determination of petroleum contamination extent, remediation of any PCS, confirmation sampling and analysis, site assessment, and site restoration. Monthly progress report to be submitted to ADEC after project award until site closure.
Flow chart attached for confirmation sampling and applicable to all TPA sites. Definition of a site assessment attached also and is applicable to all TPA sites. Site restoration is defined as one or more of the following actions dependent on each TPA site, existing site use, intended post restoration use: Recontouring, regrading, soil or scoria addition or removal, wind/water erosion control, and revegetation. |
Ray Dronenburg |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Ray Dronenburg |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 11/15/1999 |
Update or Other Action |
NOAA John Lindsay Pribilof Project Office (PPO) sent letter to Louis Howard. Subject: Inability to Install St. George Petroleum Stockpile Cover This letter is a follow-up to a mutual decision between NOAA and ADEC made on St. George Island on 28 October 1999 to forego further attempts to install the petroleum contaminated soils stockpile cover. This decision was made during discussions between you, Ms. Laura Ogar of the Solid Waste Program and myself. The following chronology represents the sequence of events leading to the timing of the installation with the subsequent encounter with the foul weather season, the primary basis for this decision.
On 31 July, NOAA received a letter dated 26 July from ADEC requesting that the PCS stockpiles on St. Paul and St. George be covered according to Alaska regulations. NOAA notified the Navy Engineering Facilities Activity (EFA) and Navy Supervisor of Shipbuilding (SupShip), Environmental Detachment (DET) to begin planning for cover installation on the Pribilofs.
On 9 August, NOAA received a stockpile cover design and estimated cost of installation from Supship. The PPO had requested the NOAA to authorize Supship funds to implement the cleanup actions on 20 May 1999. Internal approval was received on 7 June. But because the fund transfer exceeded $1 million, additional approval was required at the Department of Commerce level. This approval did not come until 8 September. However on 18 August, the SupShip Contracts Administrator refused to allow the DET to accept any additional work as DET was privatizing in mid-September 1999 as part of the Navy’s downsizing. However, with residuals from an initial $50,000 fund transfer to DET in June, DET proceeded with the procurement of the cover material for use by whomever could complete the installation. On 23 August, ADEC provided me a copy of its comments on the St. George stockpile cover design with tacit approval to proceed. On 25 August, ADEC gave final approval on the cover design.
The PPO attempted to utilize the services of EFA for placement of stockpile covers on both St. George and St. Paul, but the PPO was limited to transferring funds not to exceed $100,000 without MOU signoff. The $100,000 transfer to EFA was authorized but it was sufficient to allow for the covering of only the St. Paul Blubber Dump stockpile.
Consequently, the PPO had to seek an alternative contractor.
On 8 September, the PPO inquired about other contractor avenues available to it for the stockpile cover installation, and began preparations on a Scope of Work and Independent Government Estimate. On 16 September, NOAA requested a technical and cost proposal from Tetra Tech EMI to cover the St. George stockpile. On 14 October, NOAA contracting gives Tetra Tech EMI verbal authorization to proceed with the St. George stockpile cover installation. On 15 October, a barge delivers the cover material purchased by DET to St. George. TTEMI concludes negotiations with its subcontractor Tanaq Corporation, and on 26 October, TTEMI arrives on St. George to install the cover. During the night of 27 October, an unforecasted snowstorm covers the stockpile and high winds make it impractical and unsafe to attempt to install the cover. Seasonably adverse weather has set in and NOAA and ADEC jointly agree that it is not pragmatic to expect to cover the stockpile this season. Not only do strong winds compromise safety to workers laying down the cover, trenching for the berm around the perimeter threatened to damage the stockpile liner which was snow covered. NOAA intends to treat the stockpile at the commencement of the next field season. On 16 November, NOAA, some of its contractors and Tanaq Corporation are visiting with a vendor of a heat treatment system to discuss the technical and cost effectiveness of its application at the beginning of the next field season. NOAA believes the above information and efforts should be sufficient to satisfy pertinent requirements ADEC has identified for halting the accrual of stipulated penalties under the Two Party Agreement. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 12/14/2000. Contractor to mobilize in field in June 2000. |
Louis Howard |
| 1/6/2000 |
Update or Other Action |
Staff commented on revised schedules for site. Staff requested NOAA provide action items or descriptions (e.g. site characterization) in the "Action" section of the cover sheet for sites 21-25, which do show up in the MS Project 98 charts for the sites. |
Louis Howard |
| 9/20/2000 |
Update or Other Action |
Staff sent letter on Waiver Request for Stockpile Cover Installation on Stockpiles associated with the Enhanced Thermal Conduction System on the Pribilof Islands dated September 19, 2000. The Department is aware of the problems and unforeseen circumstances NOAA has had to deal with remediation the soil stockpiles on the Pribilofs. Based on a review of the information presented by NOAA, the Department will grant a one-time waiver for stockpile cover installation at both islands for stockpiles associated with this specific remediation effort.
This waiver is contingent upon NOAA treating all the remaining stockpiles to level “A” cleanup criteria and the most stringent cleanup criteria for: benzene, ethylbenzene, toluene, and total xylenes listed in 18 AAC 75.341. If NOAA fails to remediate all the soils in the 2001 field season, then the Department will require NOAA to cover its remaining stockpiles with a synthetic membrane material designed to withstand the extreme weather conditions on the Pribilofs. Stockpiles generated during future investigation, removals, or cleanup work by NOAA (including NOAA’s Compliance program) shall not be eligible for this waiver and be required to meet the requirements for stockpiles listed in 18 AAC 78.274. |
Louis Howard |
| 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 |
| 12/30/2001 |
Update or Other Action |
In 2001, Tetra Tech EM Inc. (TTEMI) performed a site characterization to identify potential contaminant sources and to characterize existing contaminant sources and to characterize existing contamination in soil and groundwater at the site. TTEMI performed this characterization because confirmation samples collected during a 1997 PCS removal action indicated contamination remained above site cleanup levels. TTEMI advanced six borings at locations adjacent to the 1997 confirmation sample locations where elevated levels of DRO were encountered. The maximum boring depth was 5.9 feet bgs due to refusal (that is, competent pyroclastic material). Eleven samples from six borings were screened using Petroflag colorimetric test kit. Based on screening results, seven of the eleven samples were sent off for analysis.
GRO, DRO, RRO, VOCs (including BTEX), SVOCs, and heavy metals excepting arsenic and chromium, were not detected above their ADEC Method Two cleanup levels. TTEMI found arsenic and chromium above their cleanup levels; however, the levels detected are within the range measured in background soil samples on St. George Island.
In 2001, TTEMI also installed three groundwater monitoring wells at the site to address potential impacts to groundwater caused by PCS. Groundwater at the site begins at 90 feet bgs. |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 2/28/2002 |
Update or Other Action |
St. George Chadux Corporation (Chadux), a Tanaq subsidiary, remediated the PCS hauled to NOAA's stockpile in 1997 using NOAA's enhanced thermal conduction (ETC) thermal desorption system in 2001 and 2002. NOAA directed Chadux to backfill the open excavation in 2002 using the remediated soil from the ETC system operation. |
Louis Howard |
| 3/6/2002 |
Update or Other Action |
ADEC Staff reviewed and commented on the draft site characterization report and analytical data sets. The text stated that the groundwater elevations in all three wells were measured at different times on consecutive days it is not possible to determine the groundwater flow direction without applying a correction for tidal effects. However in the same paragraph, the text states the groundwater flow direction is most likely to the north.
No basis or reason for making this conclusion was given, the Department requests clarification on how the flow direction was determined. If the direction of groundwater flow is unable to be determined with the three wells, the department requests NOAA reconsider whether additional wells at TPA 23 will be sufficient to characterize the groundwater flow direction.
The department also wishes to inform NOAA of the well log recording requirements by the Alaska Department of Natural Resources Division of Mining, Land and Water. Alaska statutes: 38.05.020, 38.05.035, 41.08.020, 46.15.020 and regulations 11 AAC 93.140 require a log of the well must be submitted to the Alaska Department of Natural Resources (ADNR) within 45 days after installing a well. Well logs must be submitted, in writing, to ADNR/Division of Mining, Land & Water, 550 West 7th Avenue, Suite 900A, Anchorage, AK 99501-3577; (907) 269-8503 or via FAX at (907) 269-8947.
The detailed official well log reporting form is available from the ADNR/Alaska Hydrologic Survey at the above address or it may be completed online at http://www.dnr.state.ak.us/mlw/forms/welllog.pdf. Enclosed with this letter is a hard copy of the well log form for your information.
The Department wishes to inform NOAA of the requirement found in the TPA at section 50 which states: “The Parties shall make available to each other quality-assured results of sampling, tests or other data generated by or on behalf of any Party under this Agreement within sixty (60) Days of the submittal of samples to the laboratory. If quality assurance is not completed within sixty (60) days, preliminary data or results shall be made available within the sixty (60) day period and quality assured data or results shall be submitted as they become available but in no event later than one hundred and twenty (120) days after the submittal of samples to the laboratory.
These periods can be extended upon mutual agreement among the Project Managers.” The Department requests a written request or notification from NOAA, should the occasion arise in the future, in which this 120 day deadline cannot be met for the Department’s files. The Department’s preference is to have the quality assured results of sampling be incorporated or submitted with the site assessment and remedial action draft reports.
Section 6 of the TPA also has a 120 day deadline listed in it: “Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 days after completion of field work.” The Department also requests NOAA notify the Department in writing if it cannot submit Site Assessment and Remedial Action draft reports in the future within the 120 day time frame.
For additional information see site file. |
Louis Howard |
| 11/28/2003 |
Update or Other Action |
During a 2003 remedial action for the adjacent North-South Cargo Fuel Pipeline (TPA 25-2) Site, Chadux performed an additional remedial action at the western portion of the 1997 excavation footprint. Chadux removed an estimated 900 cubic yards of clean 1997 backfill, then removed an estimated 1,450 cubic yards of PCS associated with 1997 confirmation samples SS186, SS204, SS207, SS210, SS211, SS214, SS215. Chadux removed the PCS t NOAA's direction since it was contiguous with PCS from TPA 25-2. The PCS was added to NOAA's PCS stockpile and currently awaits beneficial reuse as soil berm construction material for the City of St. George's new landfill. |
Louis Howard |
| 9/30/2004 |
Update or Other Action |
Sampling was conducted in October 2001and October 2002, August and November 2003, January 2004 and April 2004. During the sampling events, none of the wells at the site had contamination above the Table C groundwater cleanup levels. |
Louis Howard |
| 1/28/2005 |
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 Inactive Diesel Tank Farm TPA 23, 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).
|
Louis Howard |
| 2/22/2005 |
Update or Other Action |
Formal Request for Conditional Closure at Abandoned Diesel Tank Farm TPA Site no. 23 NOAA Site no. 27. Location: St. George Island, Alaska is approximately 800 miles southwest of Anchorage in the Bering Sea. On the island, the site is situated east of St. George Village, south of the Inactive Gasoline Tank Farm (TPA Site 24) and the Bering Sea (56°36’5.22’’ North Latitude, 169°32’27.08’’ West Longitude).
Legal Property Description: The area of excavation is located at Tract 49 in Section 29, Township 41 South,Range 129 West of the Seward Meridian, Alaska, as shown on the plat of rectangular net survey, officially filed February 15, 1985 (Black-Smith & Richards 1985. The City of St. George owns the property within the area of excavation. [Note: TPA site boundaries are not defined in the TPA. At its discretion, NOAA established a boundary for this TPA site based on site characterization data and historic information.]
Type of Release: Potential release mechanisms include: 1) leaks associated with the storage and dispensation of diesel fuel in fourteen aboveground fuel storage tanks (ASTs) and their appurtenances; and 2) leaks associated with diesel fuel transfers utilizing the pipeline that enters the site from the north.
History and Background: Reportedly, the use of the site use began in the 1970s when the Former Diesel Tank Farm (TPA Site 1) was decommissioned (WCFS 1995). TPA Site 1 is located along the St. George Village waterfront, approximately 1,500 feet (ft) northwest of the site. The diesel tank farm at the site was originally designed to fuel the Active Power Plant (TPA Site 8) underground storage tanks (USTs) via the Port Fuel Supply Line. Twelve of the tanks were 20,000-gallon capacity, adjacent to each other in an east-west oriented row, supported by individual concrete saddles, and situated within an earthen berm. Another 20,000-gallon capacity tank was situated north of the twelve tanks, and was reportedly used from the late-1980s to 1992. A 2,500-gallon tank was located south of the twelve tanks.
The City of St. George took over responsibility for the fuel storage and power generation needs of the community in 1983, and subsequently ceased use of the Port Fuel Supply Line due to suspicions of leakage based on AST fuel volume discrepancies. The City used tanker trucks to transport fuel from the ASTs to the power plant USTs until 1993, when the City abandoned the site after the Delta Western fuel depot at St. George Harbor became operational. The site is currently unused, and the nearest residence is approximately 200 ft northwest of the site.
Conclusions and Recommended Action:NOAA removed an estimated 5,600 cubic yards of PCS from the site, backfilling the site with clean soil. NOAA permanently remediated an estimated 4,150 cubic yards of this PCS with its ETC system. An estimated 1,450 cubic yards of this PCS is stockpiled at NOAA’s short-term PCS stockpile and awaits final disposal. Soil DRO contamination remains in some locations along the eastern portions of the 1997 excavation sidewall above the ADEC Method Two cleanup level for protection of groundwater (250 mg/kg), including above the refusal depth along the eastern part of the 1997 excavation.
However, no soil contamination remains at the site above the ADEC Method Two cleanup levels for the ingestion and inhalation exposure pathways (10,250 mg/kg and 12,500 mg/kg, respectively). Groundwater monitoring results from six monitoring events over a 30-month period indicate that soil DRO contamination at the site has not impacted groundwater. Additionally, site groundwater flows toward the Bering Sea and away from the municipal drinking water supply.
In accordance with paragraph 59 of the Two Party Agreement (NOAA 1996), NOAA requests written confirmation that NOAA completed all appropriate corrective action, to the maximum extent practicable, at the Abandoned Diesel Tank Farm, TPA Site 23/Site 27 in accordance with the Agreement and that ADEC grant a conditional closure not requiring further remedial action from NOAA. NOAA understands ADEC will/may require additional containment, investigation, or cleanup if subsequent information indicates that the level of contamination that remains does not protect human health, safety, or welfare, or the environment. |
Louis Howard |
| 2/28/2005 |
Cleanup Complete Determination Issued |
NOAA removed an estimated 5,600 cubic yards of PCS from the site, backfilling the site with clean soil. NOAA permanently remediated an estimated 4,150 cubic yards of this PCS with its ETC system. An estimated 1,450 cubic yards of this PCS is stockpiled at NOAA's short term PCS stockpile and awaits final disposal. Soil contamination is present above cleanup level but NOAA has excavated to the maximum extent practicable (refusal) and this fact combined with the groundwater monitoring results showing that groundwater has not been impacted, justifies no further remedial action at the site.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required: 1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1; 2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and 4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
Louis Howard |
| 2/28/2005 |
GIS Position Updated |
Geographical location was taken from NOAA 2005 report and updated by project manager. No other coordinates information available. |
Louis Howard |
| 2/28/2005 |
Long Term Monitoring Established |
Groundwater monitoring is ongoing at the site since soil remains above cleanup level for petroleum contaminants (i.e. diesel range organics-DRO). Groundwater sampling was conducted in October 2001and October 2002, August and November 2003, January 2004 and April 2004. During the sampling events, none of the wells at the site had contamination above the Table C groundwater cleanup levels. |
Louis Howard |
| 7/6/2005 |
Update or Other Action |
Staff reviewed and approved the Draft Site Closure Plan for the NOAA long-term Petroleum Contaminated Soil Stockpile Site.
The site closure work will follow the below listed general approach. The use of the words “site soil” means soils other than stockpiled PCS and sand bedding material, and includes the original naturally occurring in-situ soils and the scoria used to build the site in 1997.
•Removal of the 15,000 gallon steel AST and miscellaneous surface debris.
•Culling of debris, liner fragments and boulders from the PCS stockpile.
•Relocation of PCS and the coal pile from the stockpile to the new St. George landfill.
•Relocation of sand bedding material from the site to the new St. George landfill.
•Characterization sampling and analysis of the sand bedding material stockpile at the new St. George landfill.
•Removal of the metal sump and buried drainage culvert.
•Removal of the liner from the site.
•Excavation of site soils and relocation to the new St. George landfill.
•TLC field screening and confirmation soil sampling following excavation under the footprints of the PCS stockpile liner, ETC Operations area, and in the general area about the footprints.
•Confirmation sampling at both the vehicular ingress and egress points for the site.
•Site restoration.
•Survey and location by DGPS of all sample points, excavations, final disposal areas, characterized stockpile(s) and site restoration features.
•Preparation of debris and IDW for final disposition. |
Louis Howard |
| 7/15/2008 |
Update or Other Action |
Notice of Environmental Cleanup and Residual Soil Contamination at TPA Sites no. 23 and 25-2. Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation and The Aleut Corporation 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 property on the southeast edge of the City of St. George, St George Island, Alaska 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Tract 49 Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska.
56° 36' 11.48" North Latitude, 169° 32' 27.10" West Longitude
This property, hereafter referred to as the " Site", has been subject to petroleum contaminated soil from a discharge or release and subsequent cleanup regulated under 18 AAC 75, Article 3 as amended December 2006. Adequate soil cover needs to be maintained over the residual petroleum contaminated soil. If contaminated soil is exposed in the future, it must be managed in accordance with laws applicable at that time.
The Site was identified as Site 23 Abandoned Diesel Tank Farm and Site 25-2 Port Fuel Supply Line North-South pursuant to the Pribilof Islands Environmental Restoration Two Party Agreement (TPA) between the State of Alaska and NOAA (NOAA 1996). NOAA addressed the property as TPA Site 23 NOAA Site 27 and TPA Site 25-2 NOAA Site 30. Following corrective actions, NOAA submitted requests for conditional closures for these sites to ADEC. ADEC determined, in accordance with 18 AAC 75.325(f)(1), that the Site cleanup has been performed to the maximum extent practicable even though residual petroleum contaminated soil remained on the property. ADEC granted a conditional closure, in part subject 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 or the environment.
Grantor:U.S . Bureau of Land Management
Grantee (subsurface estate):The Aleut Corporation
4000 Old Seward Highway, Suite 300
Anchorage, AK 99503
Grantee (surface estate):St. George Tanaq Corporation
4141 B Street, Suite 301
Anchorage, AK 99503
In 2001, NOAA installed three groundwater monitoring wells at the Site. Groundwater samples collected from these wells from 2001 through 2004 had analytical results indicating all contaminants either nondetect or detected at concentrations well below ADEC cleanup standards. Based on a determination that groundwater in the vicinity of the Site had not been adversely impacted by DRO contamination, these monitoring wells were decommissioned in 2005 and removed in 2006 in accordance with an ADEC approved long-term groundwater monitoring plan.
In the event that 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 is required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations. Further site characterization and cleanup may be necessary under 18 AAC 75.325-.390 and 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil from the Site requires notification to and approval from the Department in accordance with AAC 75.370(b) and 18 AAC 78.600(h).
This notice remains in effect until a written determination from ADEC is recorded that states that soil at the Site has been shown to meet the most stringent soil cleanup levels in Method Two of 18 AAC 75.341 (c) and that off-site transportation of soil is not a concern. |
Louis Howard |
| 9/20/2008 |
Update or Other Action |
The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Pribilof Project Office is responsible for site characterization and restoration on St. George Island, Alaska. Although NOAA has attempted to meet State of Alaska soil cleanup levels and has removed contaminated soil to the maximum extent practicable, residual contamination remains at some St. George Island sites. This report documents the nature of known or potential residual soil and groundwater contamination at NOAA-remediated sites and presents the rationale for leaving the contamination in place.
Of thirty-six (36) sites investigated and/or restored by NOAA at St. George Island, the following contaminants are known to remain or potentially may be present in soil and/or groundwater above applicable site cleanup levels:
• DRO at 20 sites.
• GRO at 5 sites.
• RRO at 3 sites.
• Benzene at 4 sites.
• Toluene at 3 sites.
• Ethylbenzene at 4 sites.
• Total xylenes at 4 sites.
• Perchloroethylene at 2 sites.
• Lead at 2 sites.
Contaminated soil may have been left in place at sites due to equipment limitations and/or the presence of utility lines, buildings, roads, and other structures. Additionally, NOAA was not obligated to excavate contaminated soil to address the inhalation and ingestion pathways fifteen (15) feet or greater below the ground surface, or at shallower depths when encountering the water table. Buried debris, such as municipal solid waste, also remains at some sites. In such locations, NOAA placed a soil cap over the debris according to State of Alaska requirements.
Thirteen 20,000-gallon and one 2,500-gallon diesel fuel ASTs were located at Site 27. This site was in use from the 1970s until 1993 when it was abandoned and operations moved to the Delta Western Fuel depot at St. George Harbor. Environmental investigations performed in 1992, 1996, and 2001found the site was contaminated with DRO. Soil sample analytical results for RRO, GRO, VOC (including BTEX), SVOC, and metals indicated these analytes were below Method Two cleanup criteria, and/or at natural background levels in the case of certain metals.
In 1997, the fourteen ASTs and appurtenances were removed along with approximately 4,150 yd3 of DRO contaminated soil. In 2003, during excavation of contaminated soil from adjacent Site 30 (Port Fuel Supply Line North-South), an additional 1,450 yd3 of DRO contaminated soil was removed from Site 27. Excavations in 1997 and 2003 were backfilled with clean material.
At Site 27, soil contaminated with DRO in concentrations above the Method Two criterion for migration to groundwater remains in areas along the eastern and northern sidewalls of the 1997 excavation, at depths varying between 2.5 feet bgs and 9.1 feet bgs, with DRO concentrations of up to 7,240 mg/kg . Soil contaminated with DRO also remains in areas on the bottom of the 1997 and 2003 excavations at equipment refusal depths varying between 4.5 feet bgs and sixteen feet bgs, with DRO concentrations of up to 4,840 mg/kg. No areas within Site 27 exceed Method Two criteria for inhalation and ingestion.
Three monitoring wells, TPA23-MW-1, TPA23-MW-2 and TPA23-MW-3, were installed at Site 27 in 2001 to determine if contaminants had migrated from the site to the groundwater. Groundwater samples were collected from these wells from 2001 through 2004 and analyzed for DRO, GRO, VOC, SVOC, and metals. Sample analytical results indicated all contaminants were either non-detect or detected at concentrations below ADEC cleanup criteria. Based on a determination that groundwater in the vicinity of Site 27 had not been adversely impacted, these monitoring wells were decommissioned in 2005 and removed in 2006 in accordance with an ADEC approved long-term groundwater monitoring plan. |
Louis Howard |
| 9/26/2008 |
Update or Other Action |
Summary of Residual Soil Contamination and Buried Solid Wastes at NOAA Cleanup Sites on St. George Island. NOAA Site No. 27/TPA Site No. 23, Abandoned Diesel Tank Farm: contaminated soil, UST/AST pipeline. Diesel range organics (DRO) contaminated soil remains at concentrations
greater than ADEC’s cleanup levels for the protection of groundwater at refusal depths varying
between 4.5 and 16 feet bgs and in some locations shallower than refusal at depths varying between 2.5 and 9.1 feet bgs. Results from six groundwater monitoring events indicated groundwater was not impacted by this soil contamination. Residual PCS concentrations are less than ADEC’s cleanup levels for ingestion and inhalation. Deed notice.
Site status as of September 26, 2008: NFRAP 02/28/2005. Property Owners: St. George Tanaq Corporation (Tanaq)/TAC. |
Louis Howard |
