| Action Date |
Action |
Description |
DEC Staff |
| 8/11/1994 |
Update or Other Action |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former NMFS facilities on Saint George Island. ADEC traveled with NOAA, their consultant, Tanaq Corp. and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol. NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills.
NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island, the site of an underground thermonuclear detonation in the 1970s. Our law are also clear about responsibility for these materials. That responsibility remains with the Federal Government.
One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability. Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable.
The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. |
Simon Mawson |
| 8/19/1994 |
Update or Other Action |
Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service Facility, Saint George Island response to July 20, 1994 NOV Letter.
1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS).
2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records.
Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in these reports.
3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas.
Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet.
During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. |
Janice Adair |
| 6/1/1995 |
Site Added to Database |
Petroleum contamination. |
Ray Dronenburg |
| 6/1/1995 |
Update or Other Action |
(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). Expanded site investigation. |
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. 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 up to 10,000 mg/kg with recommendations to excavate and remove accessible soil. 16 surface soil samples taken and 7 test pits installed and 29 subsurface samples taken. Field laboratory reported results from sample T-4/S-1 at 120 mg/kg and the project lab confirmation result for same sample reported 11,000 mg/kg for TPH analysis. Approximately 1,330 to 2,850 cubic yards are estimated to require remediation. Soil would not be removed from the roadway because of a number of active underground utilities present (volume estimated to be about 130 cubic yards). |
Ray Dronenburg |
| 11/12/1998 |
Update or Other Action |
Status of TPA Site Number 18 OU 1. Preliminary site assessments completed during 1996/97 ESI. Renegotiated. Phase II Draft work plan due March 29, 1999. Final work plan due April 26, 1999. Phase II site work will require determination of petroleum contamination extent, remediation of any PCS, confirmation sampling and analysis, site assessment, and site restoration. Monthly progress report to be submitted to ADEC after project award until site closure.
Flow chart attached for confirmation sampling and applicable to all TPA sites. Definition of a site assessment attached also and is applicable to all TPA sites. Site restoration is defined as one or more of the following actions dependent on each TPA site, existing site use, intended post restoration use: Recontouring, regrading, soil or scoria addition or removal, wind/water erosion control, and revegetation. |
Ray Dronenburg |
| 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 |
| 4/11/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 12/31/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft site characterization report for TPA 18.
8.0 Recommendations Page 44: The Department concurs, for the most part, with the recommendations made in this document. However, NOAA must be aware that there are implications regarding treatment of the lead and mercury on-site or off-site. The Department requests NOAA to conduct a toxic characteristic leaching procedure (TCLP) on the mercury and lead contaminated soils to determine whether or not it is dealing with a hazardous waste regulated under the Resource Conservation Recovery Act (RCRA) as amended by the Hazardous and Solid Waste Amendments Act of 1984 (HSWA). There is no longer a RCRA program within the Department so if the TCLP tests show that NOAA has a hazardous waste, then it must coordinate with the U.S. EPA Region 10 Seattle, WA, RCRA office to properly handle, treat and dispose of the hazardous waste.
If and when NOAA determines that the soils are not regulated under RCRA, then there are other issues to be considered if solidification or fixation is identified as a remedial option. Solidification and fixation usually refers to the use of cementing agents that transform contaminated soil into freestanding, relatively impermeable blocks. It is important that the reuse of the treated material be for a beneficial purpose.
If not, the treated material must be disposed of in accordance with 18 AAC 60 Solid Waste regulations. Examples of beneficial reuse include: aggregate for concrete, road base course, building foundation fill, and parking lot base course. Beneficial reuse must occur in an area that is at least six feet above the seasonal high water table. Examples of non-beneficial use include nonstructural fill, stockpiles, and wetlands fill.
The Department will require the following be provided by NOAA for remedial options involving solidification and fixation.
1. Workplan with detailed specifications for the solidification or fixation project.
2. Design plan that will provide prevention of contamination migration to previously unaffected areas unless otherwise approved by the department in a corrective action plan.
3. Workplan schedule for conducting field work, monitoring, corrective action performance, and submittal of interim and final corrective action reports.
4. A list of additives and additive effects.
5. Site control plan.
6. Wastewater discharge permit for discharge of regulated wastewater (18 AAC 72).
7. Project complies with air quality standards and requirements (18 AAC 50).
8. Soil placed on liner meeting long-term storage requirements.
9. Non-domestic wastewater system plan approval for the construction, alteration, installation, modification, or operation of a non-domestic wastewater treatment works or disposal system under 18 AAC 72.600.
10. Information submitted that addresses containment and handling of leachate.
11. Project maintains appropriate separation distance from surface water, water supply wells, and groundwater.
12. If solidification or fixation project is offsite, department approval before moving contaminated soil to the treatment site.
13. If solidification or fixation is off-site, compliance with the treatment facility requirements.
Rather than treat on-site and have to go through the permitting processes which may be required, the Department encourages NOAA to strongly consider excavating and treating/disposing of the soil at an approved treatment, storage and disposal facility. |
Louis Howard |
| 7/12/2004 |
Institutional Control Record Established |
Institutional controls will be required for the site regarding the contaminated soils present at the site. In the event that the remaining contaminated soil becomes accessible by the removal of the soil at TPA 25-2 for any reason, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i). |
Louis Howard |
| 7/12/2004 |
Cleanup Complete Determination Issued |
Based on our review of the document, the Department finds the site conditions, (refusal during excavation due to competent pyroclastic materials) combined with adjacent roads or utilities which limit further practicable excavation at TPA Site No. 18, do not pose a significant threat to human health or safety, or the environment. The Department has, therefore, determined that no further investigation or soil sampling is required for this site. Upon submission of written proof that disposal of the petroleum and mercury contaminated soil and concrete asbestos pipe, the Department will then grant a “no further remedial action required” determination for Two-Party Agreement (TPA) Site Number 18 Former Fuel Storage Area.
Metals contamination in the soil (with the exception of mercury) may be considered background concentrations and no action is needed for the arsenic, chromium, and selenium. However, continued groundwater monitoring will be required since levels in the down gradient monitoring wells TPA18-MW-1 and 2 (although the report did not state what the levels of petroleum were) until it is below Table C criteria in 18 AAC 75.34. Monitoring for total dissolved solids and salinity will not be required since they are secondary maximum contaminant levels (MCLs) expected to be present due to the proximity of the Bering Sea.
This pending determination for TPA 18 will be equivalent to certification by the Department that corrective action is complete under TPA section 59 Closure of Sites of Operable Units.
Section 59 states: “… NOAA may request from ADEC written confirmation that all corrective action has been completed at a site(s) or operable unit(s) in accordance with this Agreement. Within thirty (30) Days of its receipt of such request, ADEC shall: (1) provide written confirmation that no further corrective action is required at the subject site(s) or operable unit(s). ADEC shall not deny certification that corrective action is complete at any site(s) or operable unit(s) solely on the basis that post-remedial measures, such as monitoring, shall remain in place for a period of months or years.”
In the event that the remaining contaminated soil becomes accessible by the removal of the soil at TPA 18 for any reason, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i).
The Department reserves all of its rights, under A.S. 46.03 and 18 AAC 75 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions at TPA 18 if information becomes available that contamination is found at this site which is poses a risk to human health or safety, welfare, or the environment.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required: 1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1; 2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and 4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
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. |
Louis Howard |
| 4/14/2005 |
Update or Other Action |
Formal Request for Conditional Closure Former Fuel Storage Area TPA Site no. 18 NOAA Site 18. Location: St. George Island, Alaska is approximately 800 miles southwest of Anchorage in the Bering Sea. On the island, the site is located within the City of St. George, approximately 50 feet southeast of the village store and 260 feet southeast of the Bering Sea (56° 36’ 7.22” N latitude, 169° 32’ 55.60” W longitude.
The site is also directly south of the Old Power Plant, TPA Site 9, southwest of the St. George Russian Orthodox Church, and west of the Aikow Hotel.
Legal Property Description: The Former Fuel Storage Area is located in Tract 52, Township 41 South, Range 129 West, Section 29 of the Seward Meridian, Alaska, as shown on the plat of rectangular net survey, officially filed February 15, 1985 (Figure 2). The City of St. George owns the surface estate.
Type of Release: Petroleum products released from drums or pipes during past operations at the site and mercury from unknown sources and activities.
On September 4, 2003, excavation of petroleum-contaminated soil (PCS) was initiated following receipt of analytical data indicating the successful recovery of mercury-contaminated soil. Recovery of PCS continued vertically downward and horizontally outward until soil exceeding the cleanup levels was no longer evident (as determined by field screening or interim confirmation sampling) or until the excavator encountered refusal, roads, or utilities. Thin layer chromatography (TLC) was the primary field screening method. PCS was transported directly
to NOAA’s long-term PCS stockpile (Figure 1). At the conclusion of the excavation process on October 3, 2003, a total volume of 2,426 yd3 of contaminated soil had been removed from the site. Final excavation depth at refusal varied between 5 and 11 feet bgs.
Along the eastern wall, the presence of a road and associated stability concerns limited excavation. Along the northwestern wall, the presence of a power line inhibited further excavation. On the excavation bottom, refusal was encountered using available equipment. After consultation with the City of St. George, the site was restored to grade, stabilized, and revegetated following excavation and confirmation sampling activities. Additionally, basalt boulders were placed along the north side of the site. At the request of island residents, a clean scoria footpath was emplaced across the site.
The FIBCs of mercury-contaminated soil and asbestos-concrete pipe were respectively shipped off St. George Island to Chemical Waste Management of the Northwest (Arlington, OR) and Waste Management Inc. (Arlington, OR) for disposal in August 2004 with final disposition occurring in November 2004 (CWMNW 2004a, CWMNW 2004b, WM 2005). The PCS removed from the site remains at NOAA’s long-term PCS stockpile, awaiting final disposition.
In accordance with paragraph 59 of the Two Party Agreement (NOAA 1996), NOAA requests written confirmation that NOAA completed all appropriate corrective action, to the maximum extent practicable, at the Former Fuel Storage Area Site, TPA Site 18/Site 18 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 |
| 4/18/2005 |
Update or Other Action |
Written confirmation of the mercury contaminated soil and asbestos-concrete pipe is present in the closure document submitted by NOAA for the site. The material and soil were shipped to Chemical Waste Management of the Northwest (Arlington OR) and Waste Management Inc. (Arlington OR) for disposal in August 2004 with final disposition occurring in November 2004 (CWMNW 2004 Certificate of Disposal 119526, Macroencapsulation followed by landfill, mercury contaminated soil. Landfill 14, November 10, 2004 Arlington Oregon December 8, 2004). Chemical Waste Management of the Northwest Inc. (CWMNW). Certificate of Disposal 119286 Stabilization followed by landfill, mercury contaminated soil Landfill 14, November 12, 2004 Arlington Oregon November 30, 2004. |
Louis Howard |
| 4/27/2005 |
GIS Position Updated |
GIS update based on report information submitted by NOAA. |
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 |
| 7/15/2008 |
Update or Other Action |
Notice of Environmental Cleanup & Residual Soil Contamination. Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation & The Aleut Corporation as the owners, & the U.S. Department of Commerce National Oceanic & Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice the property located on the hillside north of Cottage C, southeast of the Tanaq Building, & west of Aikow Hotel, in the City of St. George, St George Island, Alaska 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Lot 42, Tract 52
Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska.
56 degrees 36' 7.22" North Latitude, 169 degrees 32' 55.71" West Longitude
This property, hereafter referred to as Site 18, has been subject to petroleum contaminated soil from a discharge, or release & subsequent cleanup of oil or other hazardous substances, 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.
Site 18 Former Fuel Storage Area is covered by the Pribilof Islands Environmental Restoration Two Party Agreement (TPA) between the State of Alaska & NOAA (NOAA 1996). NOAA addressed the property as TPA Site 18 & NOAA Site 18. Following corrective action, NOAA submitted a request for conditional closure for Site 18 to ADEC. ADEC determined, in accordance with 18 AAC 75.325(f)(1), that Site 18 cleanup has been performed to the maximum extent practicable even though residual diesel range organics (DRO) contaminated soils remained on the property. ADEC granted a conditional closure, in part subject to this institutional control (deed notice), & 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.
Site 18 was used by the federal government to store petroleum products in drums from the 1930s until the 1960s. Fuel was transferred from the drums to storage tanks located west of the Old Power Plant, TPA Site 9, via aboveground piping. The drums, drum platform & transfer piping were removed during the 1960s. Environmental investigations performed in 1996 & 2001 found that fuel storage & transfer operations had contaminated Site 18's soil with DRO. The 2001 investigation also found mercury concentrations in the soil were above cleanup standards at 3 locations. The source of the mercury is unknown. In 2003, NOAA excavated the mercury contaminated soil from the three locations; this soil was subsequently shipped off-island for disposal. Also in 2003, after confirmation sample analytical results indicated the mercury contaminated soil had been removed, NOAA removed approximately 2,426 cubic yards of DRO contaminated soil from Site 18. Contaminated soil removal continued until field screening indicated DRO cleanup requirements had been met or further excavation was not practicable due to reaching equipment refusal, endangering road beds, &/or the presence of buried utilities. The excavated area was backfilled with clean material.
In 2001, NOAA installed a groundwater monitoring well up-gradient of Site 18, & two monitoring wells down-gradient. Groundwater samples collected from these wells from 2001 through 2004 had analytical results indicating all contaminants either non-detect or detected at concentrations well below ADEC cleanup standards. Based on a determination groundwater in the vicinity of Site 18 had not been adversely impacted, these monitoring wells were decommissioned in 2005 & removed in 2006 in accordance with an ADEC approved long-term groundwater monitoring plan.
In the event that information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner &/or operator is required under 18 AAC 75.300 to notify ADEC & evaluate the environmental status of the contamination in accordance with applicable laws & regulations. Further site characterization & cleanup may be necessary under 18 AAC 75.325-.390 & 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil from the site requires notification to & approval from the Department in accordance with AAC 7S.370(b) & 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) & 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.
Site 18 was used as a storage area for drums of diesel, gasoline, and lubricating oil from the 1930s to the 1960s. In 1996, Hart Crowser collected soil samples to determine the nature and extent of contamination at the site. Samples were analyzed for DRO, RRO and GRO; DRO was the only analyte found to exceed its Method Two criterion. In 2001, Tetra Tech EM, Inc. (Tetra Tech) collected additional soil samples from Site 18. Tetra Tech had the samples analyzed for DRO, RRO, GRO VOC, SVOC, and metals. As with the Hart Crowser results, DRO was the only organic contaminant found to exceed Method Two; however, mercury was found to exceed the Method Two criterion at three locations. The source of the mercury contamination was not determined.
In August 2003, the three locations where mercury contamination was found were excavated, containerized and stored for disposal off-island. Excavation confirmation samples indicated that remaining mercury concentrations were below the Method Two criterion. In 2004, the containerized mercury contaminated soil was shipped off-island and disposed of at the Chemical Waste Management of the Northwest, Inc. facility at Arlington, Oregon.
In September of 2003, after removal of the mercury contaminated soil, 2,426 yd3 of PCS was excavated from the site. PCS contaminated soil was removed to the extent practicable; however, excavation was constrained to the east-northeast by the presence of a road and to the north-northwest by a power line and roadway. Equipment refusal, due to consolidated basaltic bedrock, was encountered at depths varying between five and eleven feet bgs. Cleanup confirmation samples were collected from the excavation and analyzed for DRO, BTEX, and RRO. Analytical results indicated that only DRO remains at Site 18 in concentrations above the Method Two criterion. The highest DRO sample concentration was 21,000 mg/kg, located adjacent to a buried power line in the northwestern area of the excavation.
Two monitoring wells, TPA18-MW-1 and TPA18-MW-2, were installed down-gradient from Site 18 in 2001 to determine if contaminants had migrated from the site to the groundwater. Groundwater samples were collected from these wells from 2001 through 2004 and analyzed for DRO, GRO, VOC, SVOC, and metals. Sample analytical results indicated all contaminants were either non-detect or detected at concentrations below ADEC cleanup criteria. Based on a determination that groundwater in the vicinity of Site 18 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. 18/TPA Site No. 18, Former Fuel Storage Area Site: drums, contaminated soil. Diesel range organics (DRO) and RRO contaminated soil remains at refusal depths of 4 to 11 feet bgs. Deed notice.
Site status as of September 26, 2008: NFRAP 04/18/2005. Property Owners: St. George Tanaq Corporation (Tanaq)/TAC.
|
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73161 name: auto-generated pm edit TPA 18 STG Former Fuel Storage Area |
Louis Howard |
