| 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).
At the time, the site was referred to as "Power Plant USTs Site" USTs Numbers 1 and 2 located approximately 70 feet northwest of the power plant and adjacent to the municipal building. Both are currently in operation, constructed of steel, and have a 4,000 gallon capacity. One was installed in 1962, and the other was installed in the early 70s. These USTs were originally the terminus of a pipeline from the diesel tank farm. Because the pipeline was suspected to be leaking, the USTs are filled by tanker truck. Stained soil was noted at the fill and vent pipes of both USTs and registered 5 ppm on the PID. Tanks are more than 15 years old and do not meet ADEC or U.S. EPA requirements for leak detection, corrosion protection, and spill/overfill protection. It has been recommended that these tanks be replaced (Buckel 1990). Recommendation: determine nature and extent of POL contamination.
Recommendation: determine if POL and CERCLA contamination exist. |
Jennifer Roberts |
| 8/11/1994 |
Site Visit |
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 |
| 3/30/1995 |
Update or Other Action |
Woodward Clyde Phase 1B Environmental Assessment a.k.a. Expanded site (inspection) investigation received which was to identify the nature and extent of soil and groundwater contamination. Woodward-Clyde observed that soil staining was not limited to the
fill and vent piping, but was widespread around both USTs and the power plant building. Eight test pits were excavated across the site to determine the extent of the contamination in soil. Fractured basalt bedrock was encountered at approximately 4 to 5 feet below ground surface (bgs) in all excavated test pit locations, and groundwater was not encountered during excavation activities. A total of four surface and eight subsurface samples were collected from the site.
All samples were submitted to an onsite laboratory for total petroleum hydrocarbon (TPH), gasoline-range organics (GRO), diesel-range organics (DRO), volatile organic compounds (VOC), polychlorinated biphenyls (PCB), and metals. Two surface soil and two subsurface soil samples were sent to an offsite laboratory for confirmation analyses.
The data obtained from the site inspection were used to determine which areas have contaminated media and need further investigation. TPH was detected in all of the samples from 33 to 2,100 mg/kg. DRO was detected in 4 of the samples ranging from 220 to 3,700 mg/kg. TP-4 had the highest DRO levels and was located next to the underground supply line from the power plant to the diesel USTs and near the rear doorway to the power plant where waste oil drums were stored.
The only other analyte detected in the offsite laboratory samples was tetrachloroethene, which
was detected in the subsurface from test pits 4 and 7 at concentrations of 0.023 mg/kg and 1.9 mg/kg, respectively. NOTE TO FILE (Cleanup level for tetrachloroethane as of 2009 is 0.024 mg/kg for migration to groundwater).
Based on sample results, DRO at TP-1, TP-4 and TP-7 require remedial action. Pending removal of the USTs and related fuel lines and subsequent assessment a corrective action plan needs to be developed and submitted for ADEC review. Woodward-Clyde subcontracted Alaska Storage Tank Testing to conduct a UST integrity test on the active UST. The tightness test indicated that the UST and piping met ADEC requirements; leaking from the tank or associated piping was not apparent during the integrity test. |
Louis Howard |
| 6/1/1995 |
Site Added to Database |
Site added to database. |
Ray Dronenburg |
| 5/3/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson |
S&W |
| 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. Hart Crowser excavated two additional test pits south and southwest of Woodward-Clyde’s test pit 4 . Samples were collected from the surface, 4 feet bgs, and at the bottom of the excavated test pits, about 9 feet bgs. Six samples were collected and submitted to the field laboratory for diesel, gasoline, and oil analysis. Additionally, one sample from each test pit was submitted to the project laboratory for DRO analysis. Diesel, gasoline, and oil were not detected in soil samples collected from the test pits.
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. TP-4 had DRO at 3,700 mg/kg from 4' below ground surface. Oil (RRO) was detected in TP-4 at 4' below ground surface was a maximum of 3,800 mg/kg. Volume estimated requiring excavation or remediation is 225 cubic yards. Remedial action at the site should be completed in conjunction with the planned removal of the USTs. |
Louis Howard |
| 11/12/1998 |
Update or Other Action |
Status of Two Party Agreement for Site Number 7 OU 4. 2 regulated diesel USTs 4,000 gallons each were removed, underground supply and return piping from USTs to Power Plant removed, 1,128 cubic yards of petroleum contaminated soil (PCS) excavated and stockpiled on NOAA property on the north side of Zapadni Road, excavation backfilled with clean fill.
Excavation was stopped due to impracticability from the risk of undermining buildings or inability to penetrate fractured basalt.
Reported underground fuel distribution network to Port Fuel cargo lines to be investigated. 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 analyses, site assessment and site restoration. Monthly progress reports 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 |
| 5/15/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation. Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard. |
Louis Howard |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
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 2/15/2000. Contractor to mobilize in field in July 2000. |
Louis Howard |
| 4/11/2001 |
Document, Report, or Work plan Review - other |
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 |
| 8/31/2001 |
Long Term Monitoring Established |
Wells TPA-MW-1 through TPA80-MW-9 were installed in the vicinity of the site. |
Louis Howard |
| 4/19/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed the groundwater contaminant plume characterization report for TPA 8. The Department concurs with the recommendations below:
1. Potential sources for the release resulting in the floating product measured in TPA8-MW-1, TPA8-MW-3, and TPA1-MW-1. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
2. Historical data for the area northeast of the site should be reviewed for indications of potential petroleum product and tetrachloroethene (PERC) sources. Additional wells would be placed to further verify the source, extent, and character of the release(s).
3. The Active Power Plant site may or may not be the source of the floating product based on historical information gathered on the type of fuel that was delivered to the island and used at the site in the past. Fuel identification showed the product from the wells as diesel #1 or fuel oil #1 and from the fuel source was typical of diesel #2 or heating fuel #2.
The text states that all existing monitoring wells should be sampled for diesel range organics (DRO) and PERC using AK 102 and EPA Method 8260B respectively.
Contaminated sites with soil or groundwater contaminated with Diesel #1/Arctic Diesel requires analysis for GRO, DRO, BTEX, and PAHs (refer to Table 2 Determination of Sampling and Laboratory Analysis for Soils and Groundwater UST Procedure Manual). The Department requests NOAA include AK 101 for GRO and EPA Method 8270 or an alternate lab method with prior approval. |
Louis Howard |
| 5/1/2003 |
Update or Other Action |
Free product was observed in wells TPA8-MW-1, 3, 5, 7, 8, 10, and 12. Dissolved phase DRO above Table C values were found in wells TPA8-MW-2, 4, 6 (which was dry 4 out of the 6 sampling events), and TPA8-MW-11. All analytes were below ADEC criteria in wells TPA8-MW-9 and TPA8-MW-13. |
Louis Howard |
| 5/31/2003 |
Update or Other Action |
Monitoring wells TPA8-MW-10 through TPA-MW-13 were installed in the vicinity of the site. |
Louis Howard |
| 6/2/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft field investigation report. Free product must be addressed as required by 18 AAC 75.325(f) NOAA shall
(1) to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that
(i) minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions;
(ii) avoids additional discharge; and
(iii) disposes of the recovered free product in compliance with applicable local, state, and federal requirements.
With incorporation of the above comments or addressing issues concerning free product recovery at a later date in a corrective action plan, staff will approve the plan as submitted.
Staff's review and concurrence on the document is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While staff may comment on other state and federal laws and regulations, our concurrence on the document 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 |
| 7/20/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Feasibility Study-Product Removal Testing, Two-Party Agreement Sites 1 and 8, St. George Island, Alaska June 2005. The text states that ADEC will have to issue a permit (2003-DB-0096) for reinjecting groundwater back into the aquifer upgradient from each location. This is incorrect since ADEC no longer issues general permits for this type of activity. As part of an approved workplan for the site, ADEC can issue an approval for this activity, provided the byproduct groundwater is NOT a RCRA waste or hazardous waste that would be regulated and subject to approval by the U.S. Environmental Protection Agency (see http://www.epa.gov/safewater/uic/index.html) Groundwater Protection Unit (OCE-082) 1200 Sixth Avenue, Seattle WA, 98101 (206) 553-1224 FAX (206) 553-0151.
An oil water separator cannot be used to treat chlorinated solvent contamination, for cases such as this; ADEC has approved granulated activated carbon (GAC) filter units for “polishing” the groundwater prior to reinjection. NOAA would be required to test prior to reinjection for baseline contaminant levels, at some pre-approved frequency of monitoring during treatment and at the end of the project or before the useful life of the GAC unit(s) has been reached.
Please be aware that Section 3020 of RCRA addresses the underground injection of hazardous waste in the context of RCRA and CERCLA cleanups. RCRA section 3020(a) bans hazardous waste disposal by underground injection into a formation which contains an underground source of drinking water (within one-quarter mile of the well), or above such a formation.
However, RCRA section 3020(b) exempts from the ban reinjection of treated contaminated ground water withdrawn from an aquifer, if the following criteria are met:
(1) the reinjection is a CERCLA section 104 or 106 response action or part of a RCRA corrective action intended to clean up the contamination,
(2) the contaminated ground water is treated to substantially reduce hazardous constituents prior to such reinjection, and
(3) the response action or corrective action is sufficient to protect human health and the environment upon completion.
Please be aware that ADEC’s review and comment on the document is to ensure the compliance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our review and comments on the document does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, sub-contractors, or personnel from complying with other applicable laws and regulations.
The text states that the pneumatic bladder pump removal system is best suited at TPA 1 and 8. ADEC requests clarification from NOAA on how it intends to improve operational time of the system based on the information provided on Section 5.1.2 Page 29. It states the test at TPA1-MW1 operated discontinuously for 67 hrs. and 33 minutes. The motor on the air compressor was worn and required excessive current to operate. ADEC requests additional information on whether the compressor was worn due to unfavorable site conditions or the contractor was using a compressor that was already worn out and should not have been used in the first place. |
Louis Howard |
| 8/12/2005 |
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 Active Power Plant TPA 8, 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 |
| 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 |
| 8/31/2005 |
Update or Other Action |
Formal Request for Conditional Closure. At the Active Power Plant Site in 1997, Polarconsult removed the two 4,000-gallon USTs and their associated piping, excavated contaminated soil, and collected and analyzed confirmation samples (Polarconsult 1997a and 1997b). Excavation revealed that the tanks were set in sand, which was discolored and had a strong fuel odor.
System inspections during tank removal indicated that underground tank piping connections were made improperly, thereby leading to chronic leakage during tank filling operations. Excavation around the USTs continued until diesel fuel concentrations subsided or further excavation was impracticable due to the risk of undermining buildings or the inability to penetrate fractured basalt. About 1,128 cubic yards of soil were removed from the site. Excavated soil was placed in an ADEC-approved petroleum-contaminated soil stockpile located on NOAA property on the north side of Zapadni Road, about 1 mile west of the City of St. George (Polarconsult 1996 and 1997a). Samples were collected from the excavation sidewalls, bottom, and intermediate locations around the site to establish contamination levels.
Results of confirmation sample analyses are summarized in Table 1. Polarconsult collected confirmation samples for DRO analysis from 31 locations. Of these, samples from 15 locations exceeded the site cleanup level. Analysis of BTEX was conducted on two samples. Results were below the site cleanup levels for benzene and total BTEX. One sample was analyzed for GRO, and results were below the GRO cleanup level. Polarconsult identified a large volume of darkly discolored soil just south of the southern UST. A sample collected from this location (SS060) was analyzed for waste oil constituents (arsenic, cadmium, chromium, lead, and halogenated volatile organic compounds). Only chromium was detected (17 mg/kg), and its concentration was below the cleanup level in 18 AAC 75.341 (ADEC 2003).
Following soil removal and sampling, the excavation was backfilled with material from the local scoria a pit. An impermeable plastic sheet was placed over the excavation and covered with scoria to reduce water infiltration (Polarconsult 1997a and 1997b).
Recommended Action:
Because NOAA has removed contaminated soil from the Active Power Plant Site, TPA Site 8/NOAA Site 8, to the extent practicable, and NOAA intends to address contaminated groundwater beneath the site under a separate corrective action plan, NOAA requests in accordance with paragraph 59 of the Two Party Agreement (NOAA 1996) written confirmation that it completed all appropriate corrective actions, to the maximum extent practicable, for contaminated soil at the site 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 |
| 8/31/2005 |
GIS Position Updated |
Taken from legal property description Latitude/Longitude data listed in a 2005 report. |
Louis Howard |
| 9/1/2005 |
Update or Other Action |
St. George Island Two Party Agreement (TPA) Sites 1 and 8 Product Removal Testing Final Feasibility Study Report dated October 2005 received. SLR Alaska (SLR) was retained by St. George Chadux Corporation (St. George Chadux) to conduct pilot testing of product removal technologies proposed at two historical contaminated sites within the City of St. George, located on St. George Island, Alaska. This work was conducted between September 2004 and December 2004 under Task Order 5 between St. George Chadux and National Oceanic and Atmospheric
Administration (NOAA) Pribilof Project Office (PPO).
The two areas that were the focus of the pilot testing were Two Party Agreement (TPA) Site
1 and TPA Site 8, hereafter referred to as TPA 1 and TPA 8. Both sites had experienced
historical releases of free petroleum product to soils and ground water.
Key objectives of the project included:
• Evaluating the effectiveness of belt skimmers and pneumatic bladder pumps to remove product.
• Evaluating the physical parameters to estimate the effectiveness of multi phase extraction systems
• Determining if vacuum applied to the wells is beneficial for increasing product removal.
• Evaluating the radius of influence of vacuum extraction in the subsurface to provide design criteria for the placement of extraction wells.
• Estimating the hydraulic characteristics of the subsurface materials at the two Sites
using methods that extend beyond the immediate area of the well bore. These data will be used to refine the product volume estimate, and for future design purposes for fluid withdrawal or infiltration well design.
• Collecting water chemistry and biological activity samples to determine the appropriate measures to be taken to avoid equipment and well fouling caused by precipitates or biological activity during product removal.
• Evaluating the infrastructure in the area of the two sites, particularly surface access,
electrical service, telephone service, and the presence of existing structures suitable
for locating remediation system equipment.
The following specific conclusions are drawn:
• Pneumatic bladder pumps are more appropriate for use at this site than belt skimmers due to the following advantages:
• ease of installation, as the system can easily be installed in flushmounted wells without the need for either above grade equipment at the well, or a sub-grade vault
• installation of pneumatic pumps below grade (without requiring vaults to be constructed) will limit exposure of treatment system equipment to inclement weather
• the pumps are intrinsically safe for use in explosive atmospheres
• separate transfer pumps will not be required to pump the recovered LNAPL and water to a central location
• when properly placed, the pneumatic pumps produced very little water compared to LNAPL recovery
• The product removal pilot test, in combination with the prior baildown tests , demonstrated that the maximum actual product thickness is likely approximately 0.42 feet at TPA 1 and 0.51 feet at TPA 8
• The vacuum-enhanced product recovery testing, while successful in increasing the product recovery rate, did not result in significant additional volumes of LNAPL recovery.
• The air discharge sampling results demonstrated that the exhausted air did not exceed NIOSH TWA RELs.
• The biological activity response testing and the ground water geochemical analyses indicated that both biological fouling and chemical precipitation may occur within wells, pumps and the treatment equipment. These factors will need to be considered when selecting and designing a treatment system.
The review of remedial alternatives completed shows that Alternative 3, the pneumatic bladder pump removal system, appears to be best suited for use at TPA 1 and TPA 8. Following review of these recommendations, SLR recommends that NOAA and St. George Chadux provide SLR with approval to prepare design documents and detailed cost estimates for the selected remedial alternatives. |
Louis Howard |
| 9/4/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on NOAA's submission of a letter dated September 28, 2005 stating that it has selected Alternative 3-Pneumatic Bladder Pump Recovery System as its alternative for the free phase product removal. ADEC concurs with this alternative for free product removal.
Please be aware that ADEC’s review and approval is to ensure the compliance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our review and approval does not relieve the National Oceanic and Atmospheric Administration (NOAA) or its consultants, contractors, sub-contractors, or personnel from complying with other applicable laws and regulations. |
Louis Howard |
| 9/28/2005 |
Update or Other Action |
NOAA (J. Lindsay) letter sent to ADEC (L. Howard) Subject: NOAA Selection of Free Phase Product Removal Alternative. NOAA previously submitted for your review SLR Alaska's draft feasibility study report for product removal testing at Two Party Agreement (TPA) Sites I and 8 on St. George Island. NOAA has selected Alternative 3 - Pneumatic Bladder Pump Recovery System as its alternative for the free phase product removal. Please respond in writing as to ADEC's acceptance for this selection. If ADEC determines that this alternative is unacceptable, please submit in writing the basis for this decision. |
Louis Howard |
| 3/25/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Final Groundwater Monitoring Technical Memorandum-St. George Island, Alaska Dated February 20, 2008. The report documents the sampling of eleven (11) groundwater monitoring wells in November 2007 on St. George Island. The main contaminants of concern in the groundwater are: diesel range organics, gasoline range organics, benzene, and perchloroethylene (PCE). The contamination is associated with Two-Party Agreement (TPA) Sites: no. 1 Former Diesel Tank Area, no. 2 Drum Storage Area, no. 8 Active Power Plant, no. 22-1 School underground storage tank (UST) and the village monitoring wells.
General Comments-In the future, ADEC requests NOAA include as part of the laboratory data reports: the CS Lab Approval Number (e.g. UST-030), lab approval expiration date, and the name of the person authorizing release of laboratory data (normally a cover page containing this information).
Note: The “raw” analytical data (Appendix C-Data Deliverables Package starting on page 88 of 490 pages), e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals to ADEC, however, must be retained on file by the laboratory for at least ten (10) years after the analysis date (i.e. 2017). The hard copy report/technical memorandum sent to ADEC need not include the “raw” analytical data, but NOAA may choose to include it on CD-ROM.
Finally, ADEC requests NOAA provide some qualitative statements in subsequent reports/technical memorandum regarding groundwater contamination at each site stating if the groundwater monitoring indicates a contamination trend and if the concentration trend
(1) is increasing or
(2) is stable or decreasing, and that hazardous substance migration is not occurring.
2.1 Groundwater Sampling Page 8-The text states several hinges were broken and rusted, unbroken hinges made access to the PVC inner casings difficult. Several steel monument caps could not be closed and locked, thus access no longer is restricted. ADEC requests NOAA to replace all broken and rusted hinges to allow the monument caps to be closed and locked, preventing unauthorized access to the monitoring wells.
2.3 Analytical Procedures Page 9- Attached you will find an updated Table 1 part A and part B, from the UST Procedures Manual. Please use this as a desk reference until the UST Procedures Manual is revised, sometime in the future. SW846 was revised in 2007 and many of the corresponding changes have been captured on the new table. ADEC has added new information for pesticides, herbicides, and mercury and ADEC has updated the determinative methods and preservation requirements.
|
Louis Howard |
| 4/22/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Free Product Removal Operational Status Report on St. George Island, Alaska Dated April 11, 2008. The document describes the first three and half months of operation of the free product removal system at Two-Party Agreement (TPA) site 8 CS database reckey no. 1994250135439.
The recommendations listed in Phase I and Phase II are reasonable approaches to optimizing recovery of free product at the site. |
Louis Howard |
| 8/11/2008 |
Update or Other Action |
Notice of Environmental Cleanup and Residual Soil Contamination at Two Party Agreement Site 8. Pursuant to 18 AAC 75.375, the City of St. George (the City) as the owner, and the U.S. Department of CommercelNational Oceanic and Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice that the property west of the City's power plant and on the south side of the City's municipal building on St. George Island, Alaska 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Lot 14, Tract 43
Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska.
56 degrees 36' 10.19" North Latitude, 169 degrees 32' 47.33" West Longitude
This property, hereafter referred to as Site 8 has been subject to petroleum contaminated soil and groundwater 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.
ADEC determined, in accordance with 18 AAC 75.325(t)(1), that Site 8 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:St. George Tanaq Corporation
4141 B Street, Suite 301
Anchorage, AK 99503
Grantee:
City of St. George
PO Box 929
St. George, AK 99591
Recording District: Aleutian Islands
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 7S.32S-.390 and 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil or water from the site or use of the groundwater at or near the contaminated area requires notification to and approval from the Department in accordance with 18 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 |
| 9/17/2008 |
Update or Other Action |
NOAA letter regarding TPA Site 8 NOAA Site 3. NOAA asserts it has complied with ADEC's policy to operate a groundwater recovery system for one year at the St. George Island Active Power Plant, Free Phase Product Site, TPA Site 8, and NOAA Site 35. NOAA further asserts in accordance with the definition of "*practicable" under 18 ACC 75.990 (93) that further recovery of free phase fuel product at TPA Site 8b NOAA Site 35 is not practicable for reasons provided
below (*Note to file: “practicable” means capable of being designed, constructed, and implemented in a reliable and cost-effective manner, taking into consideration existing technology, site location, and logistics in light of overall project purposes; “practicable” does not include an alternative if the incremental cost of the alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative;).
During the previous year, NOAA installed a petroleum product recovery system which involved extraction from four wells. NOAA evaluated the system's initial operations after three months. NOAA asserts that the system functioned as designed and it had recovered over its operational life approximately thirty-five gallons of product. On April 1 1,2008, NOAA submitted an operational status report to ADEC. The report included a proposal to upgrade the system to optimize the recovery of free product. On April 22, ADEC responded (File No. 2643.38.014) favorably to NOAA's proposal.
Subsequently, NOAA tasked its contractor to install the system upgrades described in the
proposal, and to continue observing the system's operational effectiveness. However, the
product recovery rate has not significantly improved over the previous design. NOAA is
of the opinion that the rate of recovery cannot be improved upon unless an indefinite
number of wells are installed in the fractured basaltic bedrock that harbors the product,
but this approach is impracticable and would not result in any significant reduction in
risk. NOAA further asserts that further attempt at recovery is not cost effective and is
disproportionate to the degree of environmental protection potentially afforded by further
recovery. The cost of recovery of an estimated forty (40) gallons of product per year is
approximately $38,000 or $950 per gallon or $3.8 million to recover the estimated
volume.
Currently, the product poses no known risk to potable water or any surface water body, such as the Bering Sea. Further, access to the site is logistically difficult as it lies nearly 800 miles from Anchorage and scheduled flights; both passenger and freight are fairly routinely
canceled due to inclement weather, and during the past two winters phone service was
interrupted for several weeks. Phone service is required to remotely monitor the recover systems
functions.
NOAA's contractor, ChemTrack LLC, is preparing a summary report on the installation and operations during the one-year time frame. However, the report will not be available until
mid-October 2008. NOAA submits that it has operated the recovery system for approximately
one year, and it requests confirmation given the aforementioned arguments, that NOAA can move to decommission TPA Site 8bINOAA Site 35. NOAA shall continue to monitor groundwater in the vicinity ofTPASite 8 in accordance with it long-term groundwater monitoring plan. Long-term monitoring is being performed by NOAA's Safety and Environmental Compliance Office.
Enclosed are two copies of a signature page attesting that no further remedial action is
planned for TPA Site 8b and NOAA Site 35. I have signed both copies as NOAA's project
manager pursuant to TPA paragraph 42. If you concur, please sign both copies on behalf of ADEC, returning one signed copy to me and retaining the other copy for ADEC's records. |
Louis Howard |
| 9/18/2008 |
Cleanup Complete Determination Issued |
NOAA letter to ADEC. NOAA submits that it has operated the recovery system for
approximately one year, and it requests confirmation given the aforementioned argunients, that NOAA can move to decommission TPA Site 8bNOAA Site 35. NOAA shall continue to monitor groundwater in the vicinity of TPA Site 8 in accordance with it long-term groundwater monitoring plan. Long-term monitoring is being performed by NOAA's Safety and Environmental Compliance Office.
ADEC concurred. In accordance with Paragraph 59 of the Two Party Agreement (TPA), this is to confirm that all corrective action has been completed to the maximum extent practicable at TPA Site 8b and NOAA's Site 35 on St. George Island, and in accordance with the Agreement that no further remedial action is required as a part of this conditional closure granted by ADEC. |
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.
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.
During 2006, NOAA initiated a long-term groundwater monitoring plan at St. George Island to monitor the migration and attenuation of groundwater contamination at NOAA Sites 35 and 36 and to gauge the effectiveness of soil remediation actions at NOAA Sites 1, 2, 3, 8 and 29. Other than acknowledging the presence of groundwater contamination at a site, groundwater is not addressed within the context of this report.
Site 8 serves as the City of St. George’s power generation facility. In the early 1960s, a 4,000-gallon diesel fuel UST was installed to supply the power plant generators. A second 4,000-gallon UST was installed in the early 1970s, adjacent to the first. In 1997, both USTs were decommissioned and removed along with approximately 1,128 yd3 of DRO contaminated soil. PolarConsult noted that improper tank/piping connections had likely resulted in diesel fuel leaking from the storage system every time the tanks were filled to the top. The power plant currently uses an aboveground storage tank (AST) for its diesel fuel.
DRO contaminated soil was removed to the extent practicable; however, contaminated soil remains adjacent to and beneath the City Municipal Building and at equipment refusal depth to the south of the building. Confirmation sample analytical results indicated DRO concentrations of up to 8,180 mg/kg, which is greater than the Method Two criterion for migration to groundwater, but less than the criteria for protection against inhalation and ingestion. No other contaminants of concern have been identified at this site.
Due to chronic fuel leakage from the UST system, the groundwater beneath Site 8 is highly contaminated with DRO, with a free-product plume on the water table. The groundwater contamination in this area has been designated as NOAA Site 35; TPA Site 8b. A long-term groundwater sampling plan has been negotiated between NOAA and ADEC as part of NOAA’s long-term operations and maintenance responsibility. Additionally, a product recovery system was installed at Site 8 in the fall of 2007. The recovery system is currently undergoing testing and optimization and will be operated until NOAA and ADEC agree that further product recovery efforts are not warranted at the site.
AND
Active Power Plant Free-Phase, Site 35; TPA Site 8b-Chronic fuel leakage from USTs associated with the power plant (Site 8) resulted in the groundwater beneath Site 8 becoming highly contaminated with non-aqueous phase diesel fuel (free-product). The groundwater contamination in this area has been designated as NOAA Site 35; TPA Site 8b. A long-term groundwater monitoring plan has been negotiated between NOAA and ADEC as part of NOAA’s long-term operations and maintenance responsibility. Additionally, a product recovery system was installed at Site 8 in the fall of 2007. ADEC agreed with NOAA that recovery of the free-phase product is impracticable. The recovery system will be decommissioned sometime in 2009. |
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. 8/TPA Site No. 8, Active Power Plant Site: contaminated soil, UST/AST/Pipeline. Site Conditions as of August 6, 2008: DRO contaminated soil remains adjacent to and beneath the City Municipal Building and at refusal to the south of the building; deed notice; groundwater at the site is contaminated with DRO; see Site 35 [TPA 8b Active Power Plant Free Phase] below for information. Deed Notice.
Site status as of September 26, 2008: NFRAP 08/31/2005 Propery Owners: City of St. George.
Also includes NOAA Site No. 35/TPA Site No. 8b, Active Power Plant Free Phase: contaminated groundwater. Site Conditions as of August 6, 2008: Groundwater is contaminated with free-phase and dissolved-phase DRO. Long-term groundwater monitoring is in progress, and a free-phase extraction system started removing product in September 2007. Deed Notice.
Site status as of September 26, 2008: NFRAP 09/18/2008. Propery Owners: City of St. George. |
Louis Howard |
| 10/20/2009 |
Update or Other Action |
ADEC Spill# 09259929302, Spill Name- St. George Power Plant, Primary Responsible Party: Sourdough Fuel/Petro Star and Potential Responsible Party-City of St. George. Reported by Alvin Merculief to Gay Harpole. Facility relay switch failed causing discharge of approximately 325 gallons of diesel fuel to trough inside of building. Approximately 50 gallons overflowed trough and flowed outside of building to soil.
Contained most of fuel in containment trough and inside bldg. Absorbent pads and cleaning area outside. Excavation of area done. Disposal Method: ASR. Area affected size: 522 square feet. |
Louis Howard |
| 12/21/2009 |
Update or Other Action |
Groundwater Monitoring Mid-Year Report for St. George Island received. Presented in this report are the results of the June 2009 St. George monitoring well sampling event and statistical analysis of trends in contaminant concentrations for groundwater samples collected from October 2006 to June 2009 at the subject monitoring wells. Five of the eleven wells sampled; TPA1-MW-2, TPA1-MW-3, TPA2-MW-2, TPA8-MW-4, and TPA8-MW-9 were reported to contain contaminant concentrations above ADEC cleanup levels.
DRO concentrations at all five wells were above cleanup levels as were GRO and benzene
concentrations at TPA1-MW-3. Though TPA1-MW-2 and TPA1-MW-3 have historically had
high DRO concentrations this event marks the first time since May 2007 that monitoring wells
TPA2-MW-2 and TPA8-MW-4 have been reported to contain contaminants above the cleanup
level and the first time that any contaminant has been found at concentrations above ADEC
cleanup levels at monitoring well TPA8-MW-9.
RRO was not found to be a contaminant of concern by site characterization sampling performed
at TPA Sites 1 and 2 in 2001 (Tetra Tech, 2003); therefore, this contaminant has not been
specifically requested for analysis in past groundwater sampling events. During review of
analytical data from the November 2008 sampling event, it was found that RRO concentrations
had been reported by the laboratory.
Review of past analytical data packages revealed that RRO had also been reported for the November 2007 sampling event. Though RRO concentrations were reported above the cleanup level at monitoring wells TPA1-MW-2 and TPA1-MW-3 in November 2008, RRO was reported either as "not detected" or detected in very low concentrations below cleanup standards in all other wells sampled in November 2007 and 2008. No RRO concentrations were reported above the cleanup level in June 2009. It should be noted that laboratories routinely analyze for DRO and RRO concurrently. NOAA will continue to monitor RRO concentrations as part of its long-term groundwater monitoring program. RRO concentration trends will provide an indication as to whether the RRO contamination is historical or contemporary.
Monitoring wells TPA1-MW-2, TPA1-MW-3, and TPA1-MW-5 were installed to monitor the potential migration of diesel and gasoline in the groundwater beneath the former AST tank farm and fuel transfer lines at TPA Site 1. During the June 2009 sampling event all three wells were
sampled for GRO, DRO, benzene, PCE, and RRO. Duplicate samples were taken for all analytes
at wells TPA1-MW-2 and TPA1-MW-3. DRO concentrations at monitoring wells TPA1-MW-2 and TPA1-MW-3 exceeded ADEC cleanup levels as did the GRO and benzene concentrations at monitoring well TPA1-MW-3. No analytes were found above the method reporting limit at TPA1-MW-5.
Analytes with more than one instance of a sample being reported above the method reporting limit were statistically analyzed using a Mann-Kendall trend and Sen’s Slope analysis; in this case DRO and GRO were analyzed at TPA1-MW-2 and DRO, GRO, and benzene at TPA1-MW-3. With the exception of GRO concentrations at TPA1-MW-2 which are now trending up, all concentrations analyzed were trending downward. No trends at TPA Site 1 are significant at a < .05 and therefore do not meet the data quality requirements to be considered statistically valid for the purposes of this report. |
Louis Howard |
| 1/11/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed NOAA's Groundwater Monitoring Mid-Year Report for St. George Island. Staff reviewed the document and accepted it as a final version of the document without changes. |
Louis Howard |
| 4/29/2010 |
Update or Other Action |
Groundwater monitoring report received. TPA Site 8 is the Active Power Plant. Two former 4,000-gallon diesel fuel USTs installed between 1962 and the early 1970s were used as fuel supply for the current St. George Island electric power plant. In 1997, NOAA contracted St. George Tanaq Corporation to remove the tanks and approximately 1,128 cubic yards of DRO contaminated soil. During tank removal, system inspections discovered leaking underground fuel line connections, which were believed to have resulted in the presence of a non-aqueous phase liquid (NAPL) at the site.
Monitoring wells TPA8-MW-4, TPA8-MW-9, TPA8-MW-13, and TPA8-MW-14 were installed to monitor the potential migration of fuel in the groundwater beneath the electric power plant, designated as TPA Site 8. Fuel releases are from suspect leaking underground fuel line connections discovered during UST removal. During the December 2009 sampling event all four wells were sampled for GRO, DRO, benzene, PCE, and RRO. No contaminant concentrations were above ADEC cleanup levels.
A statistical trend analysis was calculated for DRO, GRO, and PCE concentrations at TPA8-MW-4, and for the DRO concentration at TPA8-MW-9. DRO concentrations at both wells were shown to be trending upward; at TPA8-MW-4 GRO had a zero trend and PCE concentrations were trending downward. The PCE concentration trend is significant at 95% or greater and meets the data quality requirements to be considered statistically valid for the purposes of this report. |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Staff received the Groundwater Monitoring Mid-Year Report dated January 2011. This report presents the results of the June 2010 St. George monitoring well sampling event and statistical analysis of trends in COC concentrations. Groundwater sampling procedures and protocols used for this project follow the NOAA Master Quality Assurance Plan, the Final Long-Term Groundwater Monitoring Plan, St. George Island, Alaska, and the Groundwater Monitoring Work Plan, St. George Island, Pribilof Islands, Alaska prepared by BSI. Trend analysis was performed using Mann-Kendall statistical methods which are described by Boyaciogly and Boyaciogly.
The purpose of continued groundwater monitoring on St. George is to monitor DRO, GRO, RRO, benzene, and PCE concentrations in groundwater at 11 monitoring wells, which are part of a monitoring well network. Hydrocarbon and PCE concentrations were detected in groundwater at wells installed in two locations in the village: the Former Diesel Tank Farm Two-Party Agreement (TPA) Site 1 and Active Power Plant TPA Site 8. At the Former Drum Storage Area TPA Site 2 and the School underground storage tank (UST) TPA Site 22-1 only hydrocarbon analytes were detected.
TPA Site 8 is the Active Power Plant. Two former 4,000-gallon diesel fuel USTs installed
between 1962 and the early 1970s were used as fuel supply for the current St. George Island
electric power plant. In 1997, NOAA contracted St. George Tanaq Corporation to remove the
tanks and approximately 1,128 cubic yards of DRO contaminated soil. During tank removal,
system inspections discovered leaking underground fuel line connections, which were believed
to have resulted in the presence of a non-aqueous phase liquid (NAPL) at the site.
Monitoring wells TPA8-MW-4, TPA8-MW-9, TPA8-MW-13, and TPA8-MW-14 were installed
to monitor the potential migration of fuel in the groundwater beneath the electric power plant,
designated as TPA Site 8. Fuel releases are from suspect leaking underground fuel line
connections discovered during UST removal. During the June 2010 sampling event all four wells were sampled for GRO, DRO, benzene, PCE, and RRO.
No contaminant concentrations were above ADEC cleanup levels. A statistical trend analysis was calculated for DRO, GRO, PCE, and RRO concentrations at TPA8-MW-4, and for the DRO concentration at TPA8-MW-9. DRO concentrations at both wells were shown to be trending upward; all other contaminant concentrations were trending downward. No trends at TPA Site 8 are significant at a < 0.05 and therefore do not meet the data quality requirements to be considered statistically valid for the purposes of this report.
Groundwater samples collected during June 2010 at the Former Diesel Fuel Tank Farm (TPA
Site 1), Drum Storage Area (TPA Site 2), Active Power Plant (TPA Site 8) and monitoring wells
TPA22.1-MW-1 and VIL-MW-4 indicated the presence of hydrocarbon compounds in groundwater. Four of the eleven wells sampled, TPA1-MW-2, TPA1-MW-3, TPA2-MW-1 and TPA2-MW-2 were reported to contain contaminant concentrations above ADEC cleanup levels. DRO concentrations all four wells were above cleanup levels as were benzene concentrations at TPA1-MW-3. Contaminants reported above cleanup levels have historically been high at these four wells. |
Louis Howard |
| 3/24/2011 |
Update or Other Action |
NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island.
2) Discontinue monitoring/decommission well TPA22.1-MW-1.
Justification: This well was initially installed to monitor for DRO resulting from soil contamination left under the school's foundation from UST spills, then it was designated as a sentinel well for detecting migration of the free-product plume from TPA 8. No contaminants have ever been detected in this well above applicable cleanup standards. Since long-term monitoring began in October 2006, no analytes have been detected above MRL except DRO at 120 ppb in May 2007.
This well is distant from the TPA 8 plume, there is no indication of free product migration from TPA 8, and contaminant concentration trends cannot be established due to too few samples above MRL. Decommissioning this well will remove a potential pathway for introduction of contaminants to the groundwater. |
Louis Howard |
| 4/4/2011 |
Update or Other Action |
Annual Groundwater monitoring report received. The purpose of continued groundwater monitoring on St. George is to monitor DRO, GRO, RRO, benzene, and PCE concentrations in groundwater at 11 monitoring wells, which are part of a monitoring well network. Hydrocarbon and PCE concentrations were detected in groundwater at wells installed in two locations in the village: the Former Diesel Tank Farm Two-Party Agreement (TPA) Site 1 and Active Power Plant TPA Site
8. Only hydrocarbon analytes were detected at the Former Drum Storage Area TPA Site 2 and
the School underground storage tank (UST) TPA Site 22-1.
Monitoring wells TPA8-MW-4, TPA8-MW-9, TPA8-MW-13, and TPA8-MW-14 were installed to monitor the potential migration of fuel in the groundwater beneath the electric power plant, designated as TPA Site 8. Fuel releases are from suspect leaking underground fuel line connections discovered during UST removal. During the November 2010 sampling event all four wells were sampled for GRO, DRO, benzene, PCE, and RRO. No contaminant concentrations were above ADEC cleanup levels.
Statistical trend analyses were calculated for DRO, GRO, PCE, and RRO concentrations at TPA8-MW-4 and for the DRO concentration at TPA8-MW-9. The DRO concentration at TPA8-MW-4 was shown to be trending upward; all other contaminant concentrations were trending downward for TPA8-MW-4. The DRO concentration trend for TPA8-MW-9 had a trend of zero. No trends at TPA Site 8 are significant at a < 0.05 and therefore do not meet the data quality requirements to be considered statistically valid for the purposes of this report. |
Louis Howard |
| 9/29/2011 |
Update or Other Action |
Staff received the draft Long Term Groundwater Monitoring Plan St. Paul and St. George Islands, Alaska, September 2011. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island.
From June 2006 to November 2010, groundwater samples were collected semiannually from monitoring
wells TPA8-MW-4, TPA8-MW-9, and TPA8-MW-13; and semiannually from TPA8-MW-14 from November 2007 to November 2010 (Figure 2-5). Sample analytes were DRO, GRO, benzene, PCE and, starting in November 2008, residual-range organics (RRO) which had been detected above its ADEC cleanup criterion in two samples collected from TPA Site 1 in November 2008. Resulting analytical results for GRO, benzene, PCE and RRO were all non-detect or detected at very low concentration (NOAA 2011b).
Statistical analysis of analyte concentration trends from the two wells with analytical results above MRL, TPA8-MW-4 and TP8-MW-9, indicated increasing and zero trends for DRO respectively; both with low confidence levels (NOAA 2011b). GRO, PCE and RRO had decreasing concentration trends at monitoring well TPA8-MW-4, which was the only well with more than two analytical results above MRL for these analytes. Benzene was not detected in any of the samples collected (NOAA 2011b).
Sampling and subsequent reports to ADEC will be accomplished in accordance with Section 3.0 and as follows:
• Semiannual sampling at all wells for DRO, GRO, and RRO.
• Benzene will be sampled/analyzed for every five years to verify continued decreasing
concentration levels at TPA1-MW-3. The next sampling round will occur no later than November 2015.
• PCE will be dropped as an analyte. |
Louis Howard |
| 9/14/2012 |
Update or Other Action |
Draft GW Monitoring Annual Report received.
Monitoring wells TPA8-MW-4, TPA8-MW-9, TPA8-MW-13, and TPA8-MW-14 were installed to monitor the potential migration of fuel in the groundwater beneath the electric power plant, designated as TPA Site 8. Fuel releases are from suspect leaking underground fuel line connections discovered during UST removal. During the 2012 sampling events all four wells were sampled for GRO, DRO, and RRO. The DRO concentration at monitoring well TPA8-MW-4 exceeds ADEC cleanup level.
Statistical trend analyses were performed for DRO, GRO, and RRO data for Well TPA8-MW-4 and for the DRO data for Well TPA8-MW-9. The results of trend analyses indicate the DRO concentration at TPA8-MW-4 is trending upward; all other contaminant concentrations were trending downward for TPA8-MW-4. The DRO concentration trend for TPA8-MW-9 had a trend of zero. None of the trends at TPA Site 8 are significant at a < 0.05 and therefore do not meet the minimum confidence level to be considered statistically valid.
TPA8-MW4 1/18/2012 DRO was detected at 1.97 mg/L. TPA8-MW9, MW-13, & MW-14 were all below Table C cleanup levels for DRO, GRO, RRO.
Village Monitoring Wells
Monitoring well VIL-MW-3 was installed as part of an expanded groundwater monitoring well network. During the 2012 sampling events, groundwater from monitoring well VIL-MW-3 was sampled for GRO, DRO, and RRO. Concentrations of each analyte were below their respective ADEC groundwater cleanup level. Only one analyte at the village monitoring wells met the requirements necessary for a statistical trend analysis.
DRO concentrations at VIL-MW-3 were analyzed for a monotonic trend and the result indicates that the trend is increasing. No trends at the VIL-MW-3 are significant at a < 0.05 and therefore do not meet the minimum confidence level to be considered statistically valid |
Louis Howard |
