| 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).
Tank farm has been in operation since the 60s consisting of 3 10,000 gallon and 2 20,000 gallon tanks. The 10,000-gallon tanks sit on a concrete foundation and appear to have been abandoned. The 20,000-gallon tanks appear to be in use and are connected to each other by an aboveground piping system. Stained soil was evident near the tanks, valves, and piping. No secondary containment features are associated with the gas tank farm except an earthen berm around one tank that is currently being used. PID readings taken from around the pipes and below the gas nozzle were 1 and 2 ppm respectively. Water ponded in the berm did not have sheen. Recommendation: determine the nature and extent of POL and possibly lead 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 staffs 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 is 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 |
Update or Other Action |
(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). Expanded site investigation. |
Ray Dronenburg |
| 6/1/1995 |
Site Added to Database |
DRO and GRO. |
Ray Dronenburg |
| 1/30/1997 |
Update or Other Action |
Hart Crowser January 1997 Expanded Site Inspection 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 up to 2,300 mg/kg and recommendation was to stockpile overburden for reuse as backfill and excavate and remove contaminated soil. Volume is estimated to be 55 to 130 cubic yards. The recommendations are based on the assumption that the existing tanks and saddles will be removed first to facilitate excavation in the area. The tank removals may reveal that other contaminated soils exist adjacent to and below the tanks. |
Ray Dronenburg |
| 11/12/1998 |
Update or Other Action |
Status update for TPA Site Number 24 OU 5. Site assessed during 1996/97 Expanded Site Investigation (ESI). Residual liquids, seven aboveground storage tanks (ASTs), piping, concrete footings, and bulk debris removed. Petroleum Contaminated Soil (PCS) excavated, stockpiled and additional site assessment conducted during the FY97 Phase I Cooperative Agreement (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, and 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 ($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 |
| 4/7/1999 |
Meeting or Teleconference Held |
Restoration Advisory Board Meeting held at the Captain Cook Hotel. Risk based cleanup under Alaska cleanup rules: 18 AAC 75 Methods 1, 2, 3, 4 presented. Public Law 104-91 as it pertains to community issues and concerns related to cleanup and local hire, NOAA organizational chart, accounting of budget for all funds received, uses of the funds requested again by ADEC as was presented in 1/6/999 letter to NOAA was discussed at the RAB meeting. Finally discussed projects planned for the future at the Pribilofs, how clean is clean and whether or not community buy in is required to assign a no further remedial action required or closure of sites for either island. Ray Dronenburg announced that as of April 5, 1999 he is no longer the project manager for the site, Louis Howard is the new project manager for ADEC. |
Ray Dronenburg |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation. Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard. |
Larry Dietrick |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 2/15/2000. Contractor to mobilize in field in July 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 |
| 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 |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 4/11/2002 |
Update or Other Action |
Staff reviewed and commented on the Draft Corrective Action Plan Revision Number 4 Inactive Gas Tank Farm, TPA Site 24 Remedial Corrective Action Project St. George Island March 26, 2002. The table shows site cleanup levels for most of the petroleum contamination that is applicable for the site. However, ADEC wishes to inform NOAA that it must also analyze and address any other contamination associated with ethylbenzene, toluene, and total xylenes for a Method 1 Alaska Cleanup Matrix approach for this site. If NOAA were to use any other method or contemplate any other method besides Method 1, then ADEC will require analyses for polynuclear aromatic hydrocarbons (PAHs). The cleanup levels for these 3 additional contaminants are as follows: 5.5 mg/kg Ethylbenzene, 5.4 mg/kg Toluene, and 78 mg/kg for total xylenes.
The text states the photo ionization detector (PID) will be used to evaluate soil on-site in an effort to estimate if the material exceeds the site cleanup level. A PID can never take the place of laboratory analyses nor can it be used to determine parts per million of a particular fuel range (DRO, GRO, or RRO) in a soil matrix. Only laboratory analysis can determine if a deflection of a PID device is related to a contaminant level in the soil.
The biggest limitation of a PID meter is that it measures total concentration of many organic compounds and is generally not able to separate and identify individual compounds, which is a problem when mixtures of compounds are present. Another limitation is that selection of lamps is critical to measuring the compounds of interest. One advantage to PID meters is that they do not detect methane. This fact is particularly important if the site being examined is a marsh or bog area or possibly a landfill area where methane gas may be generated and the methane would interfere with measuring other compounds of interest. Operator knowledge of the operating principles and limitations is critical. The PID is considered a portable instrument for field use. The instrument is affected by high humidity.
The locations and numbers of laboratory samples to be taken depend on the requirements of 18 AAC 78 for the specific type of sampling activity. The results of field screening must be used to determine the location from which to obtain samples. Samples must be obtained from locations that field screening and observations indicate are most heavily contaminated. A positive field screening result is one in which any deflection in the meter reading occurs at locations where samples are required. ADEC requests clarification on what PID reading will be used in the field to determine if a soil sample is clean or requires treatment (e.g. 5 units/ppm or less). Samples analyzed with field screening devices may not be substituted for required laboratory samples.
The text states RRO (residual range organics) will be analyzed for this project. If NOAA demonstrates that #3 to #6 fuel oils were never used in any of the above ground storage tanks (ASTs), pipeline or pumping equipment, then RRO would not be required (UST Procedure Manual Table 2 Determination of Sampling and Laboratory Analysis). |
Louis Howard |
| 5/22/2002 |
Cleanup Plan Approved |
Staff reviewed and approved the revised corrective action plan for the Inactive gas tank farm. The Department’s review and concurrence on the corrective action plan for the Inactive Gas Tank Farm TPA Site # 24 is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the corrective action plan does not relieve the National Oceanic Atmospheric Administration (NOAA) or its consultants, contractors, or personnel from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 6/22/2003 |
Update or Other Action |
Staff reviewed and commented on the draft corrective action report for the inactive gas tank farm TPA site 24. The Department concurs with the recommendations in the report and concurs with NOAA’s statement regarding collecting soil samples beneath the site, estimate volume of contaminated soil and its proximity to groundwater. Monitoring of the groundwater downgradient of the site will be required since soil contamination remains at the site above migration to groundwater cleanup levels specified in 18 AAC 75 Table B1 and B2.
The soil cleanup levels provided under method two apply unless the Department approves an alternative cleanup level that NOAA has proposed under method three or method four (this includes the petition for a 10X Rule determination). To obtain approval for an alternative cleanup level, NOAA must demonstrate that an alternative cleanup level proposed under method three or method four is protective of human health, safety, and welfare, and of the environment, and must demonstrate compliance with the applicable institutional control requirements under 18 AAC 75.375. |
Louis Howard |
| 11/24/2004 |
Update or Other Action |
Formal request for Conditional Closure at the Inactive Gasoline Tank Farm TPA Site no. 24 NOAA Site no. 28. 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, north of the Abandoned Diesel Tank Farm (TPA Site 23) and immediately south of the Bering Sea (56°36’9.85’’ North Latitude, 169°32’30.15’’ West Longitude).
Legal Property Description: The area of excavation is Tract 45 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. 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 of gasoline fuel in seven aboveground fuel storage tanks (ASTs) and their appurtenances; and 2) leaks associated with gasoline and diesel fuel transfers within the pipeline that crossed the site.
Corrective actions related to PCS removal were performed in 2002 and 2003. The corrective action objectives called for removing and transporting contaminated soil to the NOAA long-term PCS stockpile and confirming the removal of all soil exceeding the ADEC Method Two cleanup levels, consistent with an ADEC-approved corrective action plan. NOAA pursued these objectives until all petroleum contamination at or above the cleanup levels was removed, the excavation encroached into another TPA site (i.e. TPA Site 25-2), refusal (i.e. more competent pyroclastic material) was experienced, the excavation reached depths greater than 15 ft bgs, or continued excavation threatened to destabilize the adjacent road to TPA Site 6 (Open Pits Site) and the East Rookery.
Corrective action activities involved the removal and transport of 1,731 cubic yards of contaminated soil to the PCS Stockpile for remediation. Recovery of contaminated scoria and welded tuff was discontinued in some areas due to refusal. The maximum depth of excavation at the site was approximately 16 ft bgs. The minimum vertical distance from contaminated soil at the bottom of the excavation to the regional aquifer below was estimated as 30 ft.
Additional PCS was removed from the northwest portion of the site in 2003 during the corrective action for the adjacent TPA Site 25-2. The soil found contaminated in 2002 samples SG-24-015D and SG-24-065 was removed. This PCS was added to NOAA’s PCS stockpile and currently awaits beneficial industrial use as soil berm construction material for the City of St. George’s new landfill.
In accordance with paragraph 59 of the Two Party Agreement (NOAA 1996), NOAA requests written confirmation that NOAA completed all appropriate and practicable corrective and closure actions at the Inactive Gasoline Tank Farm, TPA Site 24/NOAA Site 28 in accordance with the Agreement and that ADEC grant a conditional closure that will not require further remedial action from NOAA. |
Louis Howard |
| 12/14/2004 |
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 Inactive Gasoline Tank Farm TPA 24, 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 |
| 12/14/2004 |
Long Term Monitoring Established |
Groundwater monitoring will be required and is ongoing at the site due to the presence of soil contamination above cleanup levels remaining at the site. |
Louis Howard |
| 12/14/2004 |
Cleanup Complete Determination Issued |
NOAA removed soil the maximum extent practicable. Groundwater monitoring shows no contamination above cleanup levels present in the groundwater at this time.
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 |
| 8/29/2005 |
Update or Other Action |
NOAA submits the final long-term groundwater monitoring plan which addresses 47 wells installed on St. George Island to gather information critical to environmental investigations and remediation planning pursuant to a Two Party Agreement (TPA) between National Oceanic and Atmospheric Administration (NOAA) and the State of Alaska Department of Environmental
Conservation (ADEC). Groundwater studies utilizing these wells provide data on contaminant concentration, fate, and transport at island locations where past government operations contributed to the contamination of the site. In the future, a select number of these wells will be needed for gauging the long-term effectiveness of remedial actions, to monitor for contaminant plume migration, and for utilization during free-phase petroleum product (free product) removal activities. However, monitoring wells also pose a liability by providing a potential conduit for introducing contaminants to groundwater, and by impeding use of the land around them.
Therefore, wells that are not needed by NOAA for long-term groundwater monitoring or free product removal will be decommissioned in accordance with applicable ADEC requirements.
Monitoring wells addressed by this plan are located in the vicinity of the City of St. George (the City). Twenty-five of the 47 wells will be retained, and 22 will be decommissioned. Ten of the retained wells will be used to monitor for the migration of free product plumes located in the industrial and waterfront areas of the City. The remaining 15 retained wells will be used, as needed, for free product removal or process water injection during remediation of the plumes; they may also be used for monitoring of contaminant trends once remedial efforts have
been completed. As future remedial actions progress, NOAA may decommission a number of these retained wells if it is determined that they are not required for free product removal or long-term monitoring. Wells used for monitoring for free product plume migration (sentinel wells) will be sampled semiannually for five years beginning in Fiscal Year 2006 (subject to funding availability); thereafter NOAA will evaluate the data and submit a recommendation to ADEC for further sampling or closure. Water samples will be analyzed for contaminants known to be present in the City area groundwater aquifer.
This plan addresses 47 groundwater-monitoring wells located in the vicinity of the City of St. George (the City) that NOAA installed to evaluate the nature and extent of groundwater contamination at 13 TPA sites (Figure 1-2).
These sites are:
• TPA Site 1 (Former Diesel Tank Farm)
• TPA Site 2 (Former Drum Storage Area)
• TPA Site 3 (Inactive Gas Station)
• TPA Site 6 (Open Pits Site)
• TPA Site 7 (Ballfield/Former Landfill)
• TPA Site 8 (Active Power Plant)
• TPA Site 9 (Old Power Plant)
• TPA Site 11 (Cottage C UST)
Appendix II 991
• TPA Site 18 (Former Fuel Storage Area)
• TPA Site 22-1 (School UST)
• TPA Site 22-3 (Shop/Store UST)
• TPA Site 23 (Abandoned Diesel Tank Farm)
• TPA Site 24 (Inactive Gas Tank Farm)
NOAA has completed soil remediation activities at all the above sites except TPA Site 1 and TPA Site 2 (Figure 1-3). NOAA conducted groundwater sampling in September/October 2001, October 2002, August 2003, November 2003, January 2004, and May 2004 at wells shown in Figures 2-1 and 2-2. Groundwater samples were analyzed for diesel range organics (DRO), gasoline range organics (GRO), volatile organics (VOC), semi-volatile organics (SVOC) and metals. NOAA anticipates excavating petroleum-contaminated soil (PCS) at TPA Sites 1 and 2 during the 2006 field season, subject to funding availability. In 2006, NOAA will also begin remediation of free-phase petroleum product plumes (free product), located in the vicinities of TPA Site 1 and TPA Site 8, subject to funding availability. Detailed information on island geology, hydrogeology, and groundwater sampling results for these sites can be found in Tetra Tech EM Inc.’s (Tetra Tech) Final Field Investigation Report, Pribilof Islands Environmental Restoration Project, St. George Island, Alaska. |
Louis Howard |
| 8/11/2008 |
Update or Other Action |
Notice of Environmental Cleanup and Residual Soil Contamination at TPA Sites 24 and 25-2. Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation as the owner, 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 northeast edge of the City of St. George, St George [sland, Alaska 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Lot 5 of the East Landing Subdivision
Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska.
560 36' 9.87" North Latitude, 1690 32' 30.21" 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 24 Inactive Gas 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 24 NOAA Site 28 and TPA Site 25-2 NOAA Site 30. Following corrective action, NOAA submitted a request for conditional closure 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:St. George Tanaq Corporation
4141 B Street, Suite 301
Anchorage, AK 99503
Recording District: Aleutian Islands
Gasoline was stored at TPA Site 24 in aboveground storage tanks (ASTs) from the late 1960s until 1993. Gasoline was transferred from Site 24 to island dispensing stations via the Port Fuel Supply Line North-South (TPA Site 25-2) which ran through the Site. The Port Fuel Supply Line North-South was also used for transferring diesel fuel from TPA Site 23 (Abandoned Diesel Tank Farm), which was located south and up-gradient of TPA Site 24. Environmental investigations performed in 1992 and 1996 found petroleum hydrocarbon contaminated soil at the Site. The contamination likely resulted from gasoline spills associated with operation of the ASTs, and supply pipeline leakage of both gasoline and diesel fuel. In 1997, the ASTs were removed from the Site. In 2002 and 2003, approximately 2,000 cubic yards of contaminated soil was removed from the Site. The excavations were backfilled with clean material. Contaminated soil was removed to the extent practicable; however, areas contaminated with diesel range organics (DRO), gasoline range organics (GRO), toluene, ethylbenzene and total xylenes remain at equipment refusal depths of between 9.5 and 16.2 feet below the ground surface (bgs).
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 7S.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.
Two 15,000-gallon, three 8,000-gallon, and two 1,100-gallon gasoline ASTs were located at Site 28. This site was in operation from the 1960s until 1993 when it was abandoned and operations moved to the Delta Western Fuel depot at St. George Harbor. Environmental investigations performed in 1992 and 1996 found the site was contaminated with DRO and GRO. Sample analytical results for BTEX and lead were below Method Two cleanup criteria. DRO contamination at Site 28 likely resulted from leaks at joints along the Port Fuel Supply Line North-South (Site 30) which was a supply line used by both Site 28 and the Abandoned Diesel Tank Farm (Site 27) for distribution of gasoline and diesel fuel.
In 1997, the seven ASTs and appurtenances were removed and scrapped. In 2002, 1,731 yd3 of contaminated soil was excavated and removed from the site. Excavation continued until field analyses indicated contaminant levels fell below Method Two criteria, further excavation was not practicable due to reaching equipment refusal between 9.6 and 16.5 feet bgs, or the excavation encroached into Site 30 (Port Fuel Supply Line North-South). In 2003, Site 30 remediation activities included removing additional contaminated soil from the north end of Site 28. The Site 28 excavation was backfilled with clean material.
Excavation confirmation samples were analyzed for DRO, RRO, GRO, BTEX and lead. Analytical results indicated that soil contaminated with DRO, GRO, toluene, ethylbenzene, and total xylenes in concentrations above Method Two criteria for migration to groundwater remain at Site 28 at equipment refusal depths between 9.6 and 16.5 feet bgs.
Three monitoring wells, TPA24-MW-1, TPA24-MW-2 and TPA24-MW-3, were installed at Site 28 in 2001 and 2002 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 28 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. 28/TPA Site No. 24, Inactive Gas Tank Farm: contaminated soil, UST/AST pipeline. Diesel range organics (DRO), GRO, toluene, ethylbenzene, and total xylenes contaminated soil remains at refusal depths varying between 9.6 feet and 16.5 feet bgs. Deed notice.
Site status as of September 26, 2008: NFRAP 12/14/2004. Property Owners: City of St. George; St. George Tanaq Corporation (Tanaq). |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73158 name: auto-generated pm edit TPA 24 STG Inactive Gas Tank Farm |
Louis Howard |
