| 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).
Cottage C is located within a row of cottages southwest of the hotel. Currently used for housing for visiting NOAA scientists. An AST is located east of the cottage, and a UST is located to the south of the cottage. UST was reportedly used to store heating oil and recently started leaking. Evidence of the leaking tank was noted the time of the site visit. Since the time of the visit, the leak has reportedly been repaired and contaminated soil is scheduled to be removed and disposed of (NOAA 1993). The removal and disposal of contaminated soil should be in accordance with 18 AAC 78.315. Recommendation: determine nature and extent of POL contamination. Refer to 18 AAC 78.315 for disposal and treatment options. |
Jennifer Roberts |
| 7/20/1994 |
Enforcement Action |
Notice of Violation (NOV) issued this date by Janice Adair to NOAA Ms. Sharon L. Lundin regarding Former National Marine Fisheries Service Facilities, Saint George Island. ADEC has reviewed the March 31, 1994 Phase 1B Environmental Assessment Report prepared for NOAA. ADEC has determined that NOAA, on behalf of the National Marine Fisheries Service, which owned, operated, and managed Saint George Island until 1984 is liable for environmental pollution resulting from past practices and is responsible for taking action to contain and cleanup all spills and releases as well as solid waste which are or were the result of federal activities and operations on Saint George Island. These pollution incidents are in violation of numerous provisions of Alaska Statutes including AS 46.04.020, AS 46.09.020, AS 46.03.100.
Alaska Statute 46.03.822 establishes who is liable in a pollution incident. Records available to ADEC indicate that NOAA meets the criteria.
1) owned or controlled the hazardous substance at the time of its release;
2) owned or operated the property from which the release occurred;
3) owned or operated property at which the hazardous substances came to be located.
The State is authorized, under Alaska Statute Title 46, to respond to this pollution incident if response actions are not satisfactory to the Department. In the event that State response actions are necessary, the responsible parties may be held financially liable for any response actions taken by the State. Recoverable costs include salaries of personnel, travel, contracts, legal fees, indirect costs and interest and other costs associated with the response.
Please respond in writing within thirty (30) days from the date of this letter addressing your intended actions with respect to the environmental pollution due to federal activities on Saint George Island. Please submit two (2) copies of information requested in this letter. |
Janice Adair |
| 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 |
Site added to database. |
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 |
| 1/26/1996 |
Enforcement Agreement or Order |
Pribilof Islands Environmental Restoration Agreement between the National Oceanic and Atmospheric Administration (NOAA) and the State of Alaska signed. The agreement is identify, assess, and remedy environmental contamination due to former NOAA operations on the Pribilof Islands, active and abandoned landfills, scrap disposal areas, and other solid waste management units have not been properly closed.
Owned by NOAA. |
Ray Dronenburg |
| 5/6/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson |
S&W |
| 10/31/1996 |
Cleanup Plan Approved |
Ray Dronenburg sent Polarconsult Inc. Dave Ausman, a contractor working on behalf of NOAA, an approval letter for containment cell design. Fax was received on 10/30/1996 for approval for a contaminated material storage cell. Unfortunately the fax copy was not clear enough to determine exact specifications, however, it is assumed (by ADEC) that ADEC guidance documents regarding contaminated material storage were considered in the design. (Plan states: "Since the containment cell will incorporate a water treatment system and regular maintenance program to process accumulating precipitation, Tanaq requests that the department waive the requirement for a top cover for the soil. The main reason for this request is that the top cover is expected to be problematic given the island's high winds and the need to uncover the piles on a daily basis."
ADEC's primary concern for the storage facility will be the protection of any surface water or groundwater sources. Having been to St. George on several occasions it would appear that the site selection would be near or on the old runway and not in the vicinity of any surface water sources, however, because of our discussion regarding cover for the stockpile and with a potential for leachate from the pile as well as rinsate from the UST activities, it might be prudent to develop at some point, a schedule for monitoring for excessive water accumulation.
The cell design and location are approved as submitted.
NOTE to file: Petroleum contaminated soils were from UST and Non-UST related sources encountered during FY97 Phase I Cooperative Agreement a.k.a. "Part I of the cleanup operations" on St. George Island. These include, but are not limited to, TPA 02 STG Former Drum Storage Area and TPA 03 Inactive Gas Station (oceanfront) (1624 cubic yards removed), TPA 10 STG Former Kerosene Drum/AST Storage Area, TPA 11 STG Cottage C UST (98 cubic yards removed), TPA 12 STG Former Hangar Building (195 cubic yards removed), TPA 21 Abandoned City Diesel Tank Disposal Site (1500 cubic yards removed), and TPA 23 Inactive/Abandoned Diesel Tank Farm (4,146 cubic yards removed.). |
Ray Dronenburg |
| 7/17/1997 |
Update or Other Action |
Memorandum to M. Goetz Project Mgr. NOAA. RE: Permits for water discharge. 7/16/1997 Robert Dolan who handles permit system for discharge of wastewater suggested that rather than issue a specific permit for the discharge of waters from the stockpile site on St. George, he would approve Contaminated Sites staff handling the situation. Dave Ausman will add couple of pages to his monthly report to include: on a monthly basis, report the gallons of water collected from the stockpile berm and placed into the 20,000 gallon tank. Prior to any discharge, Polarconsult will then take batch samples to ensure that maximum contaminant levels (MCLs) for wastewater are not exceeded and then using the St. George sewage truck, move the water to the sewage outfall.
Lastly, Polarconsult will post a lookout to ensure that "sheen" does not occur. The only other alternative would be additional paper work (permitting process) to achieve the same results. Mr. Ausman is faxing Ray Dronenburg in a memorandum of understanding for the procedure and when the Department receives it will provide NOAA with a copy. The Department does not see any reason not to do the same thing on St. Paul.
7/17/1997 FAX Polarconsult to R. Dronenburg: Discharge of water from the soil containment cell. Water will be collected in the 20,000 gallon tank adjacent to the cell, batch analyzed, and transferred to the City of St. George's sewer system. The system is connected to an outfall line which discharges to the Bering Sea. The sample collection, analysis, record keeping, effluent limitations, and noncompliance notification will be performed in accordance with the procedures outlined in the ADEC waste water general permit #9240-DB005. In consideration of the mixing zone allowance, the effluent limitation will be 1 mg/L for Total Aromatic Hydrocarbons (EPA 602) and 1.5 mg/L for Total Aqueous Hydrocarbons (EPA 602+610) as allowed in appendix 1.B of the permit. The city of St. George has agreed to the discharge of water through the local sewer system provided ADEC indicates approval.
Signed and approved by Ray Dronenburg July 17, 1997. |
Ray Dronenburg |
| 6/24/1998 |
Document, Report, or Work plan Review - other |
R. Dronenburg letter w/L. Bush letter attached to Mr. Minh Trinh Pribilof Project Manager re: Contaminated Sites (LUST) stockpile St. George Island. On several occasions the Department has requested NOAA provide some sort of contractual assurance that leachate from the stockpile would be handled consistent with an earlier agreement. This assurance has never been achieved. Additionally and since the original agreement, extensive community concerns have been expressed for contamination spreading as caused by blowing material from the exposed stockpile, a concern the Department supports.
Please note that Ms. Bush has requested a thirty (30) day time frame be allowed for this action. The Department is aware that negotiations for the planned Phase II portion of this cleanup action has suffered considerable delay and therefore considers immediate cover as essential.
While the work plan detailing the construction of the stockpile was originally approved without a cover, it became apparent that a cover would be necessary to protect human health and the environment. After discussion of site conditions during a visit by Bush in March 1997, Mary Goetz, then Program Manager for this project, agreed to Bush's request to cover the stockpile. As of today, the stockpile has yet to be properly covered. On June 17, 1998, Department staff observed the stockpiled soil from the site not covered and has reportedly not been covered since the stockpile was created. Photos are enclosed of the stockpile not being covered.
The Department requests NOAA: cover the entire stockpile in accordance with 18 AAC 78.311 within thirty (30) days of receipt of this letter and provide written statement tot he Department within thirty (30) days of receipt of this letter documenting the stockpile has been covered. Please be aware that the Department may request sampling for secondary contamination in the areas under and around the improperly contained stockpile. Further, the Department may require calculations of air emissions and evaluation of the potential impact to human health and the environment. Evaluation of the potential impact to the seal haul-out located in close proximity to the stockpile may be required, as well.
The leachate collection system, designed and installed prior to the Department's request that the stockpile be covered, also does not appear to be in good working order. Please revise the existing workplan or submit a new workplan to the Department for review and approval, to include any needed repairs, replacement, long term maintenance, or decommissioning of the system, whichever is more appropriate to your long term plans for the stockpile. Include a schedule with your statement of proper containment that details the timetable for remediation and disposal of the soil contained in the stockpile.
*June 28, 1998 NOAA sent Photos to R. Dronenburg with letter stating stockpile has been properly covered and contained. |
Ray Dronenburg |
| 11/12/1998 |
Update or Other Action |
Status Update for TPA Site Number 11 OU 5. Unregulated UST 1 each, 1,000 gallon diesel, was removed, underground supply and return piping from USTs to Cottage C removed, 98 cubic yards of PCS excavated, stockpiled, and excavation was backfilled with clean fill. 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 |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2000) for the first week (or portion thereof) and three thousand dollars ($3000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Ray Dronenburg |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 11/15/1999 |
Update or Other Action |
NOAA John Lindsay Pribilof Project Office (PPO) sent letter to Louis Howard. Subject: Inability to Install St. George Petroleum Stockpile Cover This letter is a follow-up to a mutual decision between NOAA and ADEC made on St. George Island on 28 October 1999 to forego further attempts to install the petroleum contaminated soils stockpile cover. This decision was made during discussions between you, Ms. Laura Ogar of the Solid Waste Program and myself. The following chronology represents the sequence of events leading to the timing of the installation with the subsequent encounter with the foul weather season, the primary basis for this decision.
On 31 July, NOAA received a letter dated 26 July from ADEC requesting that the PCS stockpiles on St. Paul and St. George be covered according to Alaska regulations. NOAA notified the Navy Engineering Facilities Activity (EFA) and Navy Supervisor of Shipbuilding (SupShip), Environmental Detachment (DET) to begin planning for cover installation on the Pribilofs.
On 9 August, NOAA received a stockpile cover design and estimated cost of installation from Supship. The PPO had requested the NOAA to authorize Supship funds to implement the cleanup actions on 20 May 1999. Internal approval was received on 7 June. But because the fund transfer exceeded $1 million, additional approval was required at the Department of Commerce level. This approval did not come until 8 September. However on 18 August, the SupShip Contracts Administrator refused to allow the DET to accept any additional work as DET was privatizing in mid-September 1999 as part of the Navy’s downsizing. However, with residuals from an initial $50,000 fund transfer to DET in June, DET proceeded with the procurement of the cover material for use by whomever could complete the installation. On 23 August, ADEC provided me a copy of its comments on the St. George stockpile cover design with tacit approval to proceed. On 25 August, ADEC gave final approval on the cover design.
The PPO attempted to utilize the services of EFA for placement of stockpile covers on both St. George and St. Paul, but the PPO was limited to transferring funds not to exceed $100,000 without MOU signoff. The $100,000 transfer to EFA was authorized but it was sufficient to allow for the covering of only the St. Paul Blubber Dump stockpile.
Consequently, the PPO had to seek an alternative contractor.
On 8 September, the PPO inquired about other contractor avenues available to it for the stockpile cover installation, and began preparations on a Scope of Work and Independent Government Estimate. On 16 September, NOAA requested a technical and cost proposal from Tetra Tech EMI to cover the St. George stockpile. On 14 October, NOAA contracting gives Tetra Tech EMI verbal authorization to proceed with the St. George stockpile cover installation. On 15 October, a barge delivers the cover material purchased by DET to St. George. TTEMI concludes negotiations with its subcontractor Tanaq Corporation, and on 26 October, TTEMI arrives on St. George to install the cover. During the night of 27 October, an unforecasted snowstorm covers the stockpile and high winds make it impractical and unsafe to attempt to install the cover. Seasonably adverse weather has set in and NOAA and ADEC jointly agree that it is not pragmatic to expect to cover the stockpile this season. Not only do strong winds compromise safety to workers laying down the cover, trenching for the berm around the perimeter threatened to damage the stockpile liner which was snow covered. NOAA intends to treat the stockpile at the commencement of the next field season. On 16 November, NOAA, some of its contractors and Tanaq Corporation are visiting with a vendor of a heat treatment system to discuss the technical and cost effectiveness of its application at the beginning of the next field season. NOAA believes the above information and efforts should be sufficient to satisfy pertinent requirements ADEC has identified for halting the accrual of stipulated penalties under the Two Party Agreement. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plan to be reviewed and commented on by ADEC on 2/15/2000. Contractor to mobilize in field on June 2000. |
Louis Howard |
| 9/20/2000 |
Document, Report, or Work plan Review - other |
Staff sent letter on Waiver Request for Stockpile Cover Installation on Stockpiles associated with the Enhanced Thermal Conduction System on the Pribilof Islands dated September 19, 2000. The Department is aware of the problems and unforeseen circumstances NOAA has had to deal with remediation the soil stockpiles on the Pribilofs. Based on a review of the information presented by NOAA, the Department will grant a one-time waiver for stockpile cover installation at both islands for stockpiles associated with this specific remediation effort.
This waiver is contingent upon NOAA treating all the remaining stockpiles to level “A” cleanup criteria and the most stringent cleanup criteria for: benzene, ethylbenzene, toluene, and total xylenes listed in 18 AAC 75.341. If NOAA fails to remediate all the soils in the 2001 field season, then the Department will require NOAA to cover its remaining stockpiles with a synthetic membrane material designed to withstand the extreme weather conditions on the Pribilofs. Stockpiles generated during future investigation, removals, or cleanup work by NOAA (including NOAA’s Compliance program) shall not be eligible for this waiver and be required to meet the requirements for stockpiles listed in 18 AAC 78.274. |
Louis Howard |
| 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 |
| 1/20/2004 |
Update or Other Action |
NOAA (J. Lindsay) letter to ADEC (L. Howard) Subject: Cottage C (TP A Site 11), St. George Island.
The National Oceanic and Atmospheric Administration (NOAA) entered into the 1996 Two-Party Agreement (TPA) with the Alaska Department of En vir omental Conservation (ADEC) in furtherance of NOAA's obligations under Public Law 104-91 to clean up contaminants and debris from lands which NOAA or its predecessor agencies abandoned, quitclaimed, transferred or are obligated to transfer, to local entities or residents on the PribilofIslands. In developing the TPA, NOAA and ADEC inadvertently included in the list of sites needing cleanup on St. George Island (TPA Attachment A) the underground storage tank for Cottage C (TPA Site II , Lot 5, Tract 47). Cottage C is an active federal facility that NOAA is not obligated to transfer and has no plans to transfer to local entities. Since the site in question is not slated for transfer, and is therefore not covered by Public Law 104-91, NOAA requests that the site be removed from Attachment A.
While the site should be removed from the TPA, NOAA does intend to address any potential contamination issues that may exist at this site. The NOAA Office of Environmental Compliance, Health and Safety will undertake necessary measures, including but not limited to site investigations and corrective action, as appropriate to clean up any contamination on site. The agency currently plans to undertake the needed actions during the 2004/2005 time frame.
Through this correspondence, NOAA seeks your concurrence with this request. |
Louis Howard |
| 2/5/2004 |
Document, Report, or Work plan Review - other |
Letter from ADEC to NOAA re: Cottage C (TPA Site 11) St. George Island January 20, 2004. The Alaska Department of Environmental Conservation (the Department) received the above document on January 23,2004. The Department concurs with the request to remove the Cottage C site otherwise known as Two-Party Agreement (TPA) Site II located on Lot 5, Tract 47.
The Department's concurrence on the request does not relieve the National Oceanic and Atmospheric Administration (NOAA) from its responsibility to properly address releases of pollutants, hazardous substances, petroleum products and oil within the meaning of AS 46.03.826 , AS 46.03.740 and 18 AAC 75.990(35) which have occurred or may have occurred at the Cottage C site regardless if it is on the TPA or not.
The Department will require a workplan to be submitted for its review and comment, prior to any work being conducted, which shall outline the course of the site investigation to properly delineate the nature and extent of contamination in soil and groundwater at Cottage C. Implementation of this workplan shall comply with 18 AAC 75, 78 and the Underground Storage Tank Procedure Manual, where applicable. Field work will be conducted or directly supervised by a qualified person as defined in 18 AAC 78.995. The Department expects the workplan to incorporate existing data in the possession of NOAA or its consultants to the maximum extent practicable. |
Louis Howard |
| 2/12/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 9/20/2008 |
Update or Other Action |
Administratively removed from the Two-Party Agreement and additional action will be conducted by NOAA Compliance program.
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.
Cottage C is a federally owned government facility, operated by National Marine Fisheries Service (NMFS), with no intent of transfer of ownership in the foreseeable future. Cottage C was inadvertently included in the TPA as Site 11 due to the presence of an UST on the site. ADEC concurred that this site would be removed from the TPA, and would fall under NOAA NMFS responsibilities for complying with the State of Alaska laws and regulations.
In 1997, the 1,000-gallon UST was removed along with approximately ninety-eight (98) yd3 of DRO contaminated soil. During removal, the tank was observed to be in poor condition, exhibiting holes due to corrosion. Contaminated soil excavation continued horizontally until further excavation was not practicable due to concerns for undermining the building foundation, nearby buried utilities and the adjacent road bed. Vertical excavation continued until equipment refusal was reached at about 9.5 feet bgs. DRO contaminated soil remains adjacent to and underneath the foundation and buried utilities on the south end of Cottage C. Confirmation sample analytical results indicated DRO concentrations of up to 22,800 mg/kg remains near the building foundation at about four feet bgs.
In 2001, groundwater monitoring well TPA11-MW-1 was installed down-gradient on the north side of Cottage C to investigate contaminant migration to groundwater due to the UST leakage. Groundwater samples were collected 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 Cottage C had not been adversely impacted, this monitoring well was 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. 11/TPA Site No. 11, Cottage C UST (Active Federal Facility) Site: contaminated soil, UST/AST/Pipeline. Site Conditions as of August 6, 2008: DRO contaminated soil remains adjacent to the building and buried utilities at the south end of the building; this active NOAA facility was inadvertently included on the Two-Party Agreement list of sites in 1996. ADEC concurred that this site would be removed from the TPA, and would fall under NOAA NMFS responsibilities for complying with State of Alaska laws and regulations.
Site status as of September 26, 2008: NFRAP 02/05/2004 Propery Owners: NOAA. |
Louis Howard |
| 5/24/2016 |
Meeting or Teleconference Held |
Met with NOAA Project Manager who gave an update on projects including this one. Funding is being sought to address residual contamination at this site for characterization, monitoring, VI assessment. Anticipate 2017-2018 action. |
Louis Howard |
| 7/25/2017 |
Update or Other Action |
Draft St. Paul-St. George UFP-QAPP Site Characterization received for review & comment. The objective of this project is to collect enough data to characterize the two sites fully & achieve site closure without institutional controls (ICs) if possible, however ICs will be considered, if necessary. The inhalation of outdoor or indoor air exposure pathway is considered complete. Results of soil samples collected during the 1998 UST removal were non-detect for benzene, toluene, ethylbenzene, and xylene (BTEX), however laboratory reporting limits were greater than the current ADEC Table B1 cleanup levels.
This will be achieved by performing the following tasks at each site:
• Delineation of the horizontal & vertical extent of soil contamination by advancing 6 soil borings
o Soil samples will be collected for DRO, residual range organics (RRO), GRO, VOCs, & PAHs
• Installation & sampling of a source area well & a downgradient well at the St. Paul site
o GW samples will be collected for DRO, RRO, GRO, VOCs, & PAHs
• Installation & sampling of a source area well at the STG site, if GW is encountered during the delineation
o The GW sample will be collected for DRO, RRO, GRO, VOCs, & PAHs
• Installation & sampling of three sub-slab soil gas points at each site
o Air samples will be collected for VOCs
• Collection of additional samples for potential use of the ADEC Method 3 alternative cleanup level calculator
o The source area soil sample collected at STG will be analyzed for extractable petroleum hydrocarbons (EPH) & volatile petroleum hydrocarbons (VPH)
o Eight samples will be collected for total organic carbon (TOC) at each site.
See site file for additional information. |
Louis Howard |
| 8/11/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Site Characterization work plan. Main comments were regarding TOC sample collection be conducted in accordance with the March 2017 guidance document and that there were numerous updates to referenced documents which are now obsolete. Additional comments were made regarding VI sampling procedures and COCs.
See site file for additional information. |
Louis Howard |
| 9/8/2017 |
Site Characterization Workplan Approved |
The final August 2017 UFP-QAPP for St. Paul NMFS Complex UST And St. George Cottage C Ust Site Characterization is approved by ADEC. See attached approval page from the UFP-QAPP.
ADEC’s review and approval of this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our approval on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations.
NOAA is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, NOAA shall notify the ADEC and obtain written approval in the form of a work plan amendment before beginning the activity.
|
Louis Howard |
| 9/26/2017 |
Offsite Soil or Groundwater Disposal Approved |
ADEC approved transport soil to NRC Alaska Anchorage from site. |
Louis Howard |
| 3/5/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft site characterization report. Staff agrees that cleanup complete is appropriate for the Cottage C site. |
Louis Howard |
| 1/16/2019 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73163 name: Underground tank |
Louis Howard |
| 3/20/2019 |
Cleanup Complete Determination Issued |
Cleanup complete determination made by ADEC.
See site file for additional information. |
Louis Howard |
| 3/21/2019 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
