| Action Date |
Action |
Description |
DEC Staff |
| 10/31/1983 |
Update or Other Action |
Disposal of Federal property on Pribilof Islands (the Pribilofs)- (a) Submission to Congress of property transfer document - Any provision of law relating to the transfer & disposal of Federal property to the contrary notwithstanding, the Secretary, after consultation with the Secretary of the department in which the Coast Guard is operating, is authorized to bargain, grant, sell or otherwise convey, on such terms as he deems to be in the best interests of the United States (U.S.) & in furtherance of the purposes of this chapter, any & all right, title, & interest of the U.S. in & to the property, both real & personal, held by the Secretary on the Pribilofs: Provided, That such property is specified in a document entitled "Transfer of Property on the Pribilof Islands: Descriptions, Terms & Conditions," which is submitted to the Congress on or before October 31, 1983.
(b) Contents of property transfer document - shall include, but need not be limited to: (1) a description of each conveyance; (2) the terms to be imposed on each conveyance; (3) designation of the recipient of each conveyance; (4) a statement noting acceptance of each conveyance, including the terms, if any, under which it is accepted; & (5) an identification of all Federal property to be retained by the Federal Government on the Pribilofs to meet its responsibilities as described in this chapter & under the Convention.
(c) Report to Congress of fair market value of transferred property - Within 60 days of the transfer of real or personal property specified in the document described in subsection (a) of this section, the Committee on Merchant Marine & Fisheries of the House of Representatives & the Committee on Commerce, Science, & Transportation of the Senate shall be given a report prepared by the Secretary stating the fair market value at the time of the transfer of all real & personal property conveyed.
(d) Memorandum of Understanding (MOU)- A MOU shall be entered into by the Secretary, a representative of the local governmental authority on each Island, the trustee or trustees, & the appropriate officer of the State of Alaska (the State) setting forth the respective responsibilities of the Federal Government, the Trust, & the State regarding -
(1) application of Federal retirement benefits, severance pay, & insurance benefits with respect to Natives of the Pribilofs;
(2) funding to be allocated by the State for the construction of boat harbors on St. Paul & St. George Islands;
(3) assumption of the State of traditional State responsibilities for facilities & services on such islands in accordance with applicable laws & regulations;
(4) preservation of wildlife resources within the Secretary's jurisdiction;
(5) continued activities relating to the implementation of the Convention;
(6) oversight of the operation of the Trust established by section 1166(a) of this title to further progress toward creation of a stable, diversified, & enduring economy not dependent up commercial fur sealing;
(7) the cooperation of government agencies, rendered through existing programs, in assisting with an orderly transition from Federal management & the creation of a private enterprise economy on the Pribilofs as described in this chapter; &
(8) such other matters as may be necessary & appropriate for carrying out the purposes of the chapter, including the assumption of responsibilities to ensure an orderly transition from Federal management of the Pribilofs. |
Louis Howard |
| 6/15/1990 |
Update or Other Action |
In 1990 NOAA identified two (2) 10,000 gallon underground storage tanks at the now Decommissioned Power Plant (DPP). One (1) UST was determined to be empty and the other serviced the then-active power plant. |
Louis Howard |
| 3/5/1992 |
Update or Other Action |
Letter from TDX regarding Summary of background on past and present ownership and operation of the USTs, statement of reservation of rights by TDX, request for extension on performance of a tank tightness test or site assessment on USTs currently in use3 and applications for financial assistance for performance of a TTT or SA on each such UST. At some point prior to 1970, the NOAA/NMFS installed at least six USTs on St. Paul Island. The St. Paul USTs were primarily used for storage of petroleum products. Among the real properties to be transferred by the Federal Government to TDX was a parcel identified as the Plant Site and Industrial Buildings Area ("Parcel 1"). The St. Paul USTs appear all to be located on Parcel 1. The agreement also required TDX to lease the existing gas station facility on Parcel 1 to the IRA and to lease the Power Plant and Machine Shop/Equipment Shed to the City.
TDX has made several attempts to contact the City and the IRA to discuss UST compliance obligations. However, despite having significant financial resources, the City takes the unreasonable position that all USTs are TDX' problem, even though TDX has never operated any of the USTs and has not accepted title to the land. The City sends all ADEC notices it receives about the USTs to TDX. The City sends all ADEC notices it receives about the USTs to TDX. The City has operated, and is currently operating three USTs on premises leased from TDX. The IRA has few financial resources but was operating one UST at the gas station and has recently abandoned it.
Tanks No. 4 and 6 are located near and possibly under the Power Plant leased by the City from TDX. Tank no. 4 appears to contain diesel fuel and is operated by the City to fuel its equipment; and has been so operated for the past several years. Tank no. 6 appears to be empty and not in use. TDX has no information on tank capacity, structural composition, the type of piping, or the installation date of these tanks. The City has apparently registered both tanks with ADEC in TDX' name. TDX has no information on whether any spill or overflow, corrosion protection, or leak detection equipment exist on these tanks.
Finally, TDX is willing to meet with ADEC, the City, IRA, NOAA, and NMFS to develop a long-term plan to bring the St. Paul USTs into compliance with State and Federal law. If the other parties will not cooperate, TDX will litigate the matter of its rights and duties with regard to such tanks before the Board of Storage Tank Assistance or in State or Federal Court. If TDX is found to be responsible for any of the St. Paul USTs currently in use, it intends to permanently close such tanks and will so notify ADEC and comply with closure procedures. TDX does not intend to wait until it is faced with a compliance order and penalties before it takes responsible action with regard to the St. Paul USTs. |
Louis Howard |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment (PA) 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).
Contaminated drain line site: 14-inch diameter drain line runs from a floor drain in the power plant building 200 feet into the harbor area. Drain line had not been in use for several years when a nearby septic tank overflowed. Water began to seep into the drain line, carrying some oil product to the outfall. City of Saint Paul stopped the septic tank overflow and plugged the inlet with concrete. Boom was placed around the outfall (Buckel 1990). No oil was observed during the E and E site visit nor was any absorbent boom present as previously reported. Recommendation: To determine if any POL contamination remains in the surface soil.
This assessment identified two (2) 10,000 gallon UST tanks: UST No. 3 and UST No. 4, in the area of the southeast corner of the DPP building. This assessment also noted that 13 gallons of diesel fuel/water mix had recently been removed from UST No. 3 while UST No. 4 was still in use. |
Jennifer Roberts |
| 9/30/1993 |
Update or Other Action |
U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report.
Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. |
Ray Dronenburg |
| 10/1/1993 |
Update or Other Action |
City of Saint Paul Public Notice to: Contractors/Regulatory Agencies. The City of Saint Paul hereby notifies you of the potential presence of hazardous materials on the island. The attached maps should be used as a general reference for identification of potential hazardous materials in planning your project. For the proposed utility projects within the Harbor Area planned for construction during the summer of 1993, the City does not believe that any hazardous materials are present. However, landowners and contractors are responsible for assuring compliance with federal and state regulations and should not rely on information provided herein.
If contractors on City Projects (and/or City Property) or on projects which are to become property of the City, believes that hazardous materials may or have been encountered, they must immediately cease any and all construction activity, immediately notify the Public Works Director and City Manager orally and in writing and comply with the attached guidelines. No further construction work can be done unless explicitly authorized in writing by the Public Works Director and City Engineer.
City of Saint Paul Hazardous Materials Procedures-
1) Review attached maps. If project includes construction within areas noted as potentially contaminated or if you encounter potential environmental contamination during construction, the following procedures must be followed:
2) Notify NOAA and the City of the potential problem;
3) conduct standard ADEC screening tests and provide in writing at a minimum-to NOAA and the City: a) exact location of area and land ownership, b) Quantity of material, c) Characteristics of material and contamination, d) documentation the contractor has certified persons to 1) conduct screening tests and 2) handling and disposal of hazardous wastes, e)Provide a detailed cost estimate for the initial screening, stockpiling, and testing of the material including labor, materials, equipment, testing, etc, f) provide a schedule for the final removal of any stockpiled materials, g) identify the location and specifications for stockpiling the materials.
4) If the material does not appear to require remediation according to ADEC and EPA regulations, the City Engineer and City Public Works Director will authorize the construction to proceed.
5) If the initial screening per ADEC and EPA regulations indicates that the material must be stockpiled for further testing (NOTE to file states should not be removed until an approved plan is submitted), then the contractor must comply with the protocol approved by NOAA and the City. At a minimum, this protocol would include the stockpiling of excavated materials, the placement of an impermeable liner in the construction utility corridor, the installation of utility lines covered with non-contaminated materials, and the testing of stockpiled materials for analysis and disposal per ADEC and EPA regulations.
6) When test results are available, the contractor must provide the following: a) test results, b) ADEC and EPA regulatory requirements for disposal, c) Proposed detailed plan for disposal of materials, d) Documentation that the contractor has certified personnel to handle and dispose of hazardous waste, 3) Provide a detailed cost estimate for the disposal of the material and any additional remediation required including labor, materials, equipment, testing, etc., f) provide a schedule for the final removal of any stockpiled materials.
7) The City and NOAA must approve the proposed plan and costs for disposal of the materials which were stockpiled prior to any construction activity. (Issued 10/01/1993). |
Ray Dronenburg |
| 10/19/1993 |
Update or Other Action |
Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation.
Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it.
The current construction season has passed, to allow us the necessary time to schedule the equipment; NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. |
Ray Dronenburg |
| 11/2/1994 |
Update or Other Action |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL). From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. |
Jennifer Roberts |
| 11/15/1994 |
Update or Other Action |
Woodward Clyde Consultants performed a site inspection at the DPP in 1993. A trench was dug on the west side of the power plant and up to the northeast corner of the annex to locate a drain line. No drain line was encountered nor was any indication of petroleum contamination found. No analytical samples were collected in the trench. Two (2) hand auger borings were dug near the large plant doors and a valve box on the west and east sides of the building.
Numerous petroleum product analytes, as well as pesticides (lindane and heptachlor) were detected in the east side boring at the five (5) foot interval. WCC determined that all analytes were well below human health risk based concentrations. The PCB Arochlor 1260, was detected at a concentration of 30 mg/kg (PPM) in a sample at the 0.5 feet below ground surface (bgs). This was the only detection of PCBs at the DPP site. |
Ray Dronenburg |
| 8/2/1995 |
Update or Other Action |
(Old R:Base Action Code = RECN - Site Reconnaissance (CS)). Extensive investigation. 9000 cubic yards of contaminated soil stockpiled from diesel seep. |
Ray Dronenburg |
| 8/2/1995 |
Update or Other Action |
(Old R:Base Action Code = TAS - Treatment Alternative Study (CS)). Extensive investigation. |
Ray Dronenburg |
| 9/15/1995 |
Update or Other Action |
Hart Crowser Final management plan for Expanded Site Inspections received. Plan covered Tract 41 (a.k.a. Tract 46) which is composed of 5 subareas: active power plant, former power plant, former gasoline/diesel drum storage area, former AST location (saddles), former kerosene AST location, Demolished Diesel Tank Farm, Lukanin Bay Debris Site, NMFS Landfill site. Field laboratory will run Petroleum hydrocarbons (Method 8015 modified), PCB (Method 8080), BTEX using a PhotoVac , PAHs using a immunoassay kit. Confirmation sampling and analysis to support the field lab results submitted to the project lab on the rate of 1 per test pit, approximately 25% or more of the surface soil samples (site specific). |
Ray Dronenburg |
| 5/2/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson. |
S&W |
| 8/12/1996 |
Update or Other Action |
Ben Thomas letter to NOAA re: Facility ID# 2394 Tank ID# 1 requirement to close an UST that has been temporarily out of service for more than 12 months. This letter is to thank you for replying to the Notice of Violation (NOV) that you recently received. The NOV dated June 28, 1996, outlines requirements necessary to properly decommission an UST which has been temporarily out of service for more than 12 months.Based on the information you provided, the Alaska Department of Environmental Conservation (ADEC) has determined that the subject tank(s) is hereby: Still in Ground, Awaiting Closure Plan. Please submit the Site Assessment and Post-Closure Notice no later than October 31, 1996 to the address listed on this letterhead. |
Cindy Thomas |
| 8/26/1996 |
Update or Other Action |
NOAA letter re: NOV June 28, 1996-NOAA is very appreciative of your department's verbal acceptance of our (NOAA/ADEC) joint two party agreement (action/remediation plan) that was put in place to address this issue. Second: An update. The grant/cooperative agreement between NOAA and a local island remediation contractor is in the review process and should be approved by the end of this month. If all goes according to plan, the UST in question and five others will be out of the ground shortly. |
Cindy Thomas |
| 1/30/1997 |
Update or Other Action |
Hart Crowser Draft Expanded site investigation conducted in 1996. One test pit and 4 hand auger borings were dug, and 12 soil samples were collected from the various sample depths in the holes. Samples were collected at between 0 and 10 feet bgs. The maximum sample depth was limited by refusal. Samples displayed DRO levels from ND (20 mg/kg) to 4,100 mg/kg in 4 of the 12 samples.
RRO ranged from 50 mg/kg to 3,100 mg/kg. No GRO, BTEX, metals, PCBs or pesticides were detected in any samples collected at the site. The investigation did, however, detect the presence of several polycyclic aromatic hydrocarbons (PAHs). One PAH compound, benzo(a)pyrene, was detected at a level of 0.16 mg/kg, thus exceeding the EPA risk based criteria of 0.088 mg/kg. However, under current ADEC cleanup criteria, PAHs detected at the site exist in levels below ADEC cleanup level of 3.0 mg/kg. |
Ray Dronenburg |
| 12/6/1997 |
Update or Other Action |
Tract 41 (St Paul) is inclusive of several sites to include Fire station gas pump and former power plant. |
Ray Dronenburg |
| 12/10/1997 |
Site Number Identifier Changed |
Incorporated data from Reckey 1994250135427 into Reckey 1994250135426 because this Reckey (26) is being treated as a group of spills. However, 11/4/99 broken back out for tracking purposes. |
Ray Dronenburg |
| 12/31/1997 |
Update or Other Action |
The electrical power plant operated from 1960 until its decommissioning in November 1998. The building measured 90 ft. along its east/west axis and 40 ft. along its north/south axis. Three ASTs and two 10,000 gallon USTs originally serviced the facility. In 1997, NOAA arranged to remove one UST and closed the other in place. |
Ray Dronenburg |
| 2/27/1998 |
Document, Report, or Work plan Review - other |
Lynne Bush letter to Minh Trinh re: UST Closure Site Assessment reports. Old Power Plant Area Facility ID #3048 Tank 4. Diesel contamination remains in the soil in the area near this former UST, closed in place with Department approval on June 23, 1997. Levels of diesel contamination of 7,400 mg/kg remain in place in that location. It is the understanding of the Department that this tank will be removed from the ground and a closure site assessment performed when the overlying structure is demolished. As with the other UST systems reviewed in this letter, further release investigation and corrective action will be necessary. |
Ray Dronenburg |
| 9/30/1998 |
Update or Other Action |
Jacobs Engineering Group Inc. Investigation Workplan received. Data quality objectives: Initial sampling round will try to determine if Tract 41 can be closed. Plan is to collect soil samples from up to 3 borings per site, install monitoring wells, and collect groundwater samples from each well. Comments in document: sampling is limited to one soil sample from the most contaminated interval and one groundwater sample at each boring/well, PCB analysis at only one well. Analyses: GRO, BTEX, DRO, RRO, PAH, RCRA metals, for all 3 wells, PCBs for 1 well. |
Ray Dronenburg |
| 10/7/1998 |
Update or Other Action |
Dave Allen sent NOAA courtesy reminder of the December 22, 1998 deadline to upgrade USTs. We wish to remind you that our records indicate that the UST at Facility ID# 0-002394 City Power Plant Tank ID# 002, 10,000 gallon capacity diesel does not meet the December 22, 1998 upgrade standards. Owners of UST systems that are not closed or upgraded by the deadline will be subject to enforcement actions including monetary penalities by the State of Alaska or the U.S. EPA or both. Your distributor may not be willing to deliver product to your tank if the tank is not upgraded. Letter repeated on 13-November 1998. |
David Allen |
| 10/29/1998 |
Update or Other Action |
ADEC Letter to Minh Trinh NOAA re: request to close UST sites in Tract 41 Area. August 27, 1998 letter from NOAA requested closure of UST sites in Tract 41 area. None of the seven (7) USTs identified on St. Paul Island qualifies for No Further Action and may require additional investigation or corrective action. Per 18 AAC 78, “closure” of an underground storage tank is defined thus: 18 AAC 78.995(19) “close” has the meaning given that term in AS 46.03.375(g)(1); AS 46.03.375(g)(1) “close” means to remove petroleum and sludges from the tanks in the tank system and either fill the tanks with inert solid material or remove, dismantle, and dispose of the tanks”;
18 AAC 78.085(c) To permanently close a tank, the owner or operator shall empty and clean it by removing all liquids and accumulated sludge. A UST that is to be closed must be removed from the ground, along with all associated piping, or filled with an inert solid material. A UST with a known or past release must be removed from the ground unless the department, in its discretion, allows the tank to remain in place because removal of the tank would endanger existing structures. The resulting excavation must be investigated and cleaned up as required by 18 AAC 78.230 – 18 AAC 78.350. The owner or operator shall document the name of the disposal method, and the disposal location for all liquids, sludges, and UST components, including tanks, piping, and equipment.” 18 AAC 78.090(a) When performing permanent closure or a change-in-service, the owner or operator shall complete a site characterization and, depending on the results of the site characterization, perform a site assessment or release investigation.”
Under these definitions, not all the tanks within Tract 41 meet the definition of “closed”. Rather than reiterate the contents, I enclose a copy of the February 27, 1998 letter to re-familiarize you with the specific data gaps. NOAA is obliged to continue investigating the release and to perform corrective actions, as deemed necessary by the Department. Per regulations, site characterizations and assessments were performed during tank removal activities and the releases were reported in a timely manner.
However, the required release investigations for these sites have not taken place. 18 AAC 78.235(g) requires submittal of a release investigation report within 45 days of the date the confirmed release was reported to the Department. This has not occurred. 18 AAC 78.240 requires an interim corrective action report informing the department of the status of the cleanup actions within 60 days after the date of release confirmation. This has not occurred. Your agency is seriously behind schedule.
Due to the nature and scope of the work to be performed on both St. George and St. Paul Islands, the Department has thus far chosen to be lenient when enforcing deadlines, including those set forth in regulation and the Two-Party Agreement. We recognize the need to prioritize work and to set reasonable milestones and it is our intention to work in conjunction with NOAA and representatives of both islands to achieve acceptable levels of cleanup and to do so within schedules that consider the needs of all parties. Unfortunately, NOAA has missed an entire field season in which they might have accomplished these goals.
For additional information see site file. |
Lynne Bush |
| 12/24/1998 |
Update or Other Action |
Bristol Environmental Services Corporation conducted an evaluation at the site in 1997. One of the 10,000 gallon USTs (UST No. 3 Fac. ID No. 3048) was removed, while the second UST (UST No. 4 Fac. ID No. 3048) was closed in place. During the UST No. 3 removal, 40 cubic yards of contaminated soil was removed and stockpiled at Big Polovina Hill. The excavation measured 15 feet by 20 feet to a depth of 13 feet DRO and BTEX levels measured from 3 soil samples below the UST at approximately 14 feet bgs ranged from non-detect to 120 mg/kg for DRO and ND to 0.10 mg/kg for BTEX. DRO levels in the stockpiled soils was recorded at 260 mg/kg DRO and BTEX was not detected (ND).
Groundwater was not encountered at 14 feet bgs. At UST No. 4 (closed in place) a soil sample was taken at six (6) feet bgs adjacent to the fill/vent pipe alongside the UST. BESC found this sample to contain DRO at 7,400 mg/kg and 0.98 BTEX. |
Ray Dronenburg |
| 2/22/1999 |
Update or Other Action |
This is the first week that stipulated penalties against NOAA are invoked by ADEC. Pribilof Islands Environmental Restoration Agreement: Paragraph 70 page 17 Stipulated penalties states: If determined by ADEC to be appropriate, NOAA shall pay to ADEC a stipulated penalty of two thousand dollars ($2,000) for the first week (or portion thereof) and three thousand dollars ($3,000) for each additional week (or portion thereof) in the event NOAA fails to meet any deadline related to a regulated UST or solid waste unit owned by NOAA and included in Attachment A. Interpretation remains whether or not the penalties are for each site in Attachment A per deliverable not received by ADEC or per week for both islands. |
Ray Dronenburg |
| 7/21/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into final site characterization plan for Tract 46 and data gap analysis/conceptual site model. |
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. |
Jennifer Roberts |
| 12/2/1999 |
Update or Other Action |
CESI performed site investigation activities in the vicinity of the DPP January 25 through February 4, 1999. One emphasis of the investigation was obtaining water quality data from saltwater wells installed during the commercial fur-sealing days for process water. Free product was found in the west DPP well, the east DPP well, the west Old Sealing Plant (WOS) well, and the East Old Sealing Plant well. 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.
The east DPP contained the most product, a viscous, paint-like light non-aqueous phase liquid (LNAPL). A sample of the product contained 59,000 mg/L DRO and 510,000 mg/L RRO. Gasoline and diesel range organics cleanup level were exceeded in all wells except for east DPP well since no groundwater sample was collected. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization plant to be reviewed and commented on by ADEC on 1/14/2000. Contractor to mobilize in field on May 2000. |
Louis Howard |
| 2/18/2000 |
Update or Other Action |
Staff commented on the draft final site characterization plan for Tract 46 and adjoining properties. Staff clarified sampling depth for surface soil is from 0-2' not 0-2cm for analyzing exposure from inhalation of particulates, ingestion, dermal contact and inhalation from contaminants other than particulates. Sampling depth for subsurface as stated in the risk assessment procedure manual is ten feet. |
Louis Howard |
| 2/28/2000 |
Update or Other Action |
Staff received Geophysical Survey Report dated August 5, 1999 on February 28, 2000. Machine shop, Municipal Garage and East Side gas line were investigated. Site history indicated an underground gasoline line, which supported a former gas station and UST in this area. An EM61 survey was performed of the area and a metallic anomaly with the characteristics of a pipe was detected. There appears to be a magnetic anomaly with the characteristics of a pipeline present in this location, however, no anomalies with the characteristic of a UST were located at this site. Site history for the municipal garage North End Pipeline indicated a pipeline may have existed on the north end of the municipal garage. An EM61 survey was performed of the area and no metallic anomalies with the characteristics of pipelines were detected. Demolished seal processing plant history indicated USTs and underground pipelines may have been present at this location. EM61 survey detected no metallic anomalies with the characteristics of USTs or pipelines. Finally, at a demolished building foundation site history indicated that there may have been USTs associated with the site. A Magna-Trak handheld magnetometer was used and an anomaly was detected having the characteristics of a UST on the Southwest end of the building foundation. |
Louis Howard |
| 5/5/2000 |
Update or Other Action |
Staff sent comment letter to NOAA on draft final site characterization plan for tract 46 and adjoining properties. The text in paragraph 3 also states that the sampling depth will be no greater than 2 centimeters (cm), in accordance with ADEC guidance (Risk Assessment Procedures Manual). This statement would be correct if NOAA and ADEC were only concerned with particulates (liquid or solid particles such as dust, smoke, mist, or smog found in air emissions). Since the work for this site is not limited to particulates, ADEC requests NOAA sample beyond the first 2 cm for surface soil sampling. This sampling effort would ideally be from the 12-18” interval, but no deeper than 2’. Surface soils are defined in regulations as “...soil that extends no more than 2’ below the surface.”
Furthermore, the ADEC Risk Assessment Procedures Manual for Section 3.2.2.5 defines what depths are generally considered when sampling surface and subsurface. It states that for all land uses, ADEC will generally use a default value of two feet to define surface soil and ten feet to define subsurface soil to which residents will have a reasonable potential to be exposed (ingestion, dermal contact, and inhalation).
There appears to be a discrepancy between 18 AAC 75(j)(2) which states that cleanup must be achieved in the subsurface soil to a depth of at least fifteen (15) feet and section 3.2.2.5 of the Risk Assessment Procedures Manual. Section 3.2.2.5 states that for all land uses, ADEC will generally use a default value 10 feet to define subsurface soil to which residents will have a reasonable potential to be exposed (ingestion, dermal contact, and inhalation).
Until the issue can be corrected in the Risk Assessment Procedures Manual at a later date, ADEC will require NOAA to meet cleanup levels which prevent human exposure from ingestion or inhalation of a volatile hazardous substance in the surface soil and the subsurface soil to a depth of at least fifteen feet. Fifteen feet is the minimum depth which ADEC considers it reasonably likely for affected soils to be excavated and brought to the surface during the installation of septic systems, utilities, construction of basements, etc.
Upon incorporation of the above comments, ADEC will consider it a "final" document. |
Louis Howard |
| 12/14/2000 |
Update or Other Action |
Staff sent letter to NOAA regarding Notification of possible Force Majeure (per the TPA). The Alaska Department of Environmental Conservation (ADEC) has received the above document via facsimile from NOAA on December 5, 2000. The document states that in accordance with Paragraph 67 of the Two Party Agreement, the potential exists for a Force Majeure situation. It further states that unless further Pribilofs Cleanup Funds are appropriated to NOAA for FY01, the project budget will be exhausted this fiscal year. We very much appreciate your providing this information and analysis of NOAA’s anticipated plans in FY 01 given the existing funding situation. ADEC realizes that funding is uncertain due to Congress not yet finalizing a budget for this FY01. We anticipate a meeting with NOAA to discuss potential impacts to the Pribilof Islands Environmental Restoration Agreement when Congress finalizes a budget. |
Louis Howard |
| 3/2/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force Majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act).
In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While
ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 3/28/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter.
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.”
With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows:
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.
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. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. |
Louis Howard |
| 5/25/2001 |
Long Term Monitoring Established |
Staff reviewed and commented on the groundwater monitoring plan which covered TPA 2, 5, 9, 11, 15. Comment was on the lack of current lab certification listed in table 10 for two labs. Staff requested proof of current certification and corrected table in the document with latest expiration date. |
Louis Howard |
| 6/4/2001 |
Update or Other Action |
Staff commented on the draft cleanout report for the machine shop. The text states only one report is available regarding this property: Saint Paul Island Building Inspection Report, July 19-21, 2000. ADEC disagrees. 1997 UST removal and closure report (Bristol Environmental Services Corporation-BESC 1997 project # 7029FG-00 September 24, 1997) show a release has occurred at the site. Please refer to ADEC comment letter dated February 27, 1998 subject: Review of UST Closure Site Assessment Reports (see attached). The letter clearly states at Facility ID 3048, diesel Tanks 5 and 6 had substantial diesel range organics (DRO) contamination remaining in place after removal. The closure report lists sample 8KnF had 16,000 mg/kg DRO and 27.47 mg/kg total BTEX. Two 8,000-gallon single walled USTs and 30' of piping were removed.
Apparently the limits of backhoe were reached in the excavation with soils still observed with high petroleum contamination (BESC 1997 Page 4 Discussion). Sample 8KNC had 20.01 total BTEX and 15,000 mg/kg DRO. Both 8KNC and 8KNF were from the Northern Tank closest to the old machine shop. Line between USTs and old machine shop sample "Line A" had 18,000 mg/kg DRO (BESC 1997 Table 1). This particular sample was from a pipeline stubout to supply a former boiler in the machine shop. No groundwater encountered from surface to bedrock at 18'. Stockpiled soil was moved to seven miles north near quarry site on Polovina Hill.
ADEC cannot grant a no further action determination until NOAA provides further information which shows the site was adequately characterized to determine the horizontal and vertical extent of contamination, the contamination was successfully remediated and no additional contamination remains at the site above Category “B” criteria (see BESC report appendix D). |
Louis Howard |
| 6/12/2001 |
Update or Other Action |
In 2000 and continuing into 2001, Columbia Environmental Services Inc. (CESI) conducted a site characterization on behalf of NOAA. CESI installed a group of monitoring wells (MW46-5, MW-46-6, MW46-9, MW-23, and MW-28) at and around the DPP site. Five wells were sampled near the DPP. Two wells (WDPP and EDPP) located in the southwest corner of the building, and three wells (PH2, WOSP and EOSP) located approximately 75 feet east of the DPP were sampled. The depth to groundwater at these nearby easterly wells is 20 feet bgs.
CESI detected DRO and ROO in a single soil sample from the DPP site. Only DRO exceeded the Method Two soil cleanup level of 250 mg/kg at 2,300 mg/kg in the 11 to 12 feet bgs sample (DPPSB-1) taken near the former location of UST No. 3. RRO in the soils did not exceed the most stringent RRO criteria of 10,000 mg/kg. |
Louis Howard |
| 6/13/2001 |
Update or Other Action |
CESI installed groundwater wells in the vicinity of the DPP site. Five (5) pre-existing saltwater wells associated with the former commercial fur sealing operation remained in close proximity to the DPP. The first two rounds of sampling was performed in 2000. Beginning in 2001 IT Alaska Corporation (IT) continued groundwater monitoring at the wells. The newly installed wells were sampled a total of five times over a one year period. The five pre-existing wells were sampled only during a single event in October 2000.
Groundwater analyses revealed the presence of DRO and RRO in two wells, MW46-9 and MW46-23. DRO levels at these two wells exceeded Method Two Table C level of 1.5 mg/L on one occasion, displaying an elevated DRO value of 1.6 mg/. At MW46-9 tetrachloroethene also known industrially as perchloroethylene (PCE) exceeded the cleanup level of 0.005 mg/L (PPB) during two sampling events. The source of the PCE is unknown. MW46-5 and MW46-6 were sampled only once in September 2000. GRO was detected in MW46-6 at 4.5 mg/L and DRO at both wells was found to be 6.7 mg/L and 11.0 mg/L respectively. MW26-28 during all five sampling events found GRO to be 24 mg/L for the highest sampling result and DRO at 18 mg/L. RRO was found to be 1.3 mg/L during one event.
DRO was sampled at five pre-existing wells and the highest level was 13 mg/L at WOSP. GRO was detected in all five wells but exceeded cleanup level at EOSP (3.5 mg/L) and WOSP (1.6 mg/L). |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 4/17/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Annual Groundwater Monitoring Report 2001 St. Paul Island March 2002 Project 823255.01030000. 2.3 Village Hill Plume Pages 2-5 and 2-6.
The text states that chromium was detected in samples collected from all four wells up to 5,200 ug/L. NOAA used a Hach kit to perform hexavalent chromium analyses (Diphenyl-carbazide method) screening. The kit uses a Diphenyl-carbohydrazide (DPC) to form an intensely colored complex with Cr(VI). The complex is measured quantitatively by its visible absorption at 520 nm.
However, as in any colorimetric analysis, this test is subject to positive interferences from other colored materials in the sample as well as from other elements that form colored complexes with DPC. The Department views the Hach kit testing as a field screening method and data gathered by field screening never is substituted for laboratory analyses. The only acceptable determination on whether the Cr(VI) is present in a water sample is through laboratory analyses. For example, there are methods available such as:
EPA method 218.6, or SW-846 Methods 7000 series method 7195 (coprecipitation) is used to determine Cr(VI) in EP extracts and groundwater, or method 7198 differential pulse polarography used to determine Cr(VI) in natural and wastewaters and in EP extracts, or method 7199 often used for determination of Cr(VI) in drinking water, groundwater and industrial wastewater effluents by ion chromatography.
The Department requests NOAA confirm the validity of Hach kit test results through a strict laboratory analyses using an approved Cr(VI) analytical method for groundwater results where chromium was detected in the groundwater. After determining through laboratory analysis that hexavalent chromium is not present above the Table C Groundwater Cleanup level of 100 ug/L, then NOAA may discontinue analysis for this particular parameter.
2.6 Recommendations for Central Tract 46 Page 2.8
See comments above regarding laboratory analysis of water for hexavalent chromium Cr(VI) to validate the field screening with Hach kits. The Department concurs with semi-annual monitoring of contaminants of concern (COCs) at Tracts 43 and 46. The Department will require monitoring for the following COCs : gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, lead, selenium, hexavalent chromium, and tetrachloroethylene.
The Department requests groundwater monitoring of tetrachloroethylene not be limited to MW46-9, but also include MW46-23. MW46-23 will act as a sentinel well to ensure that tetrachloroethylene is not spreading beyond MW46-9. The Department requests that groundwater flow direction be described in the text and shown on the figures for the sites. |
Louis Howard |
| 5/30/2002 |
Cleanup Level(s) Approved |
The Alaska Department of Environmental Conservation (the Department) has received the draft final groundwater use and classification in the vicinity of Tract 46 TPA 9 on May 6, 2002. Department staff also attended and participated in a briefing given by NOAA regarding the 18 AAC 75.350 10X Table C groundwater cleanup levels in the Tract 46 (TPA 9) area on May 9, 2002. Below are the Department’s general comments regarding NOAA’s request for a 10X rule determination for groundwater at Tract 46. Specific comments regarding the document referenced above will be addressed in another letter to NOAA.
General Comments
After reviewing the data and hearing NOAA’s briefing, the Department will approve the use of a 10X rule for groundwater cleanup levels in Tract 46. This approval does not modify the Water Quality Standards found in 18 AAC 70, which NOAA must comply with where applicable. The rationale for the Department’s approval is based on these site-specific conditions listed below:
-The groundwater in the Tract 46 area is impacted by saltwater intrusion from the nearby Bering Sea, which makes it unfit for drinking water consumption. This is demonstrated with the high levels of total dissolved solids, chloride, and electrical conductivity NOAA has measured in the Tract 46 area.
-The groundwater is not currently used for drinking water and there is no anticipated future use of groundwater in the study area.
-All residents obtain their drinking water from the public water supply system two miles northeast from the city.
-There is no current or future need for the groundwater within the study area to be used as a potential drinking water source. The existing water supply located two miles away from Tract 46 is adequate to meet all anticipated needs for drinking water.
The Tract 46 area includes sixteen (16) distinct soil contaminated sites-e.g. Tract 43, Parcel 6f and Tract A north of Bartlett Ave. and west of Airport Rd. encompassing 45 acres. Department approval is contingent upon NOAA resolving the following issues.
1. NOAA shall consult with the current and future landholders of the property it has transferred and will transfer regarding: a) the 10X rule for groundwater cleanup levels and corresponding migration to groundwater cleanup levels for soil, b) proper handling and disposal of contaminated soils excavated in the Tract 46 area in accordance with 18 AAC 75.325(i) and 18 AAC 75.370 and, c) prohibition of installation of groundwater wells and restrictions on groundwater use for drinking water or other uses.
2. NOAA shall conduct, with DEC participation, a public meeting to discuss the 10X rule for cleanup levels in groundwater, institutional controls on current and future landowners, restriction on groundwater use, proper soil handling and disposal requirements when excavating soil, which is contaminated.
For additional information see site file. |
Louis Howard |
| 5/30/2002 |
350 Determination |
18 AAC 75.350 determination granted by ADEC. TPA Site 9, also known as Tract 46, has 16 distinct soil-contaminated sites identified by investigations subsequent to the signing of the TPA. TPA 9 sites & TPA 12 are covered by the determination.
The groundwater in the Tract 46 area is impacted by saltwater intrusion from the nearby Bering Sea, which makes it unfit for drinking water consumption. This is demonstrated with the high levels of total dissolved solids, chloride, & electrical conductivity NOAA has measured in the Tract 46 area. The groundwater is not currently used for drinking water & there is no anticipated future use of groundwater in the study area.
All residents obtain their drinking water from the public water supply system two miles northeast from the city. There is no current or future need for the groundwater within the study area to be used as a potential drinking water source. The existing water supply located two miles away from Tract 46 is adequate to meet all anticipated needs for drinking water. See site file for additional information. |
Jennifer Roberts |
| 8/29/2002 |
Update or Other Action |
ADEC Staff sent response to TDX attorney letter regarding use of 10 times (10X) rule in Tract 46 area.
The Alaska Department of Environmental Conservation (the Department) received your letter of August 1, 2002 on behalf of Ron Philemonoff, CEO of the Tanadgusix Corporation (TDX). Your letter inquired about the impact of the 18 AAC 75.350 ten times (10X) groundwater cleanup levels to the Two-Party Agreement (TPA) site 9 commonly referred to as Tract 46 (the study area) on St. Paul Island.
The 18 AAC 75 Contaminated Sites regulations defines “cleanup” and “cleanup levels” as follows: “cleanup” means efforts to mitigate environmental damage or a threat to human health, safety, or welfare resulting from a hazardous substance , and includes removal of a hazardous substance from the environment, restoration, and other measures that are necessary to mitigate or avoid further threat to human health, safety, or welfare, or to the environment; and “cleanup level” means the concentration of a hazardous substance that may be present within a specified medium and under specified exposure conditions without posing a threat to human health, safety, or welfare, or to the environment.
The higher cleanup levels NOAA is requesting for the study area is literally ten times (10X) those found in 18 AAC 75.345 Groundwater Cleanup Levels Table C and in most cases, those levels found in 18 AAC 75.341 Table B1 Method Two. For example, if diesel contamination were detected in the groundwater above Table C cleanup levels, then the cleanup level for diesel in soils would be 10X the migration to groundwater level.
If diesel contamination were detected at or below the Table C cleanup levels in groundwater, then soil cleanup levels for diesel contamination would have to meet the more restrictive migration to groundwater level and would not be eligible for the 10X rule application. These higher soil cleanup levels would only apply to the migration to groundwater cleanup level and, in no case, will not exceed the ingestion, inhalation, or maximum allowable soil cleanup levels (whichever value is less).
After reviewing NOAA’s data, the Department has determined that applying the 10X rule for groundwater cleanup levels in the study area is appropriate. This approval does not modify the Water Quality Standards found in 18 AAC 70, which NOAA must comply with whether or not a 10X rule determination is made. For example, where groundwater is closely hydrologically connected to surface water, water quality standards in 18 AAC 70 must be met for surface water and sediment.
The rationale for the Department’s approval is based on the site-specific conditions listed below:
The groundwater in the study area is impacted by saltwater intrusion from the nearby Bering Sea, which makes it unfit for drinking water consumption. This is demonstrated with the high levels of total dissolved solids, chloride, and electrical conductivity NOAA has measured in the study area. The groundwater is not currently used for drinking water and there is no reasonable expectation of a future use of groundwater as a drinking water source in the study area. All residents obtain their drinking water from the public water supply system located two miles northeast from the city.
There is no current or future need for the groundwater within the study area to be used as a potential drinking water source. The existing water supply located two miles away from the study area is adequate to meet all anticipated future needs for drinking water.
For additional information see site file. |
Louis Howard |
| 11/5/2002 |
Update or Other Action |
Letter from Breck Tostevin Attorney General's Office
Re: NOAA Environment Cleanup on Pribilof Islands.
AGO File No. 661-95-0126: Draft City of St. Paul Ordinance Concerning Water Wells
The Alaska Department of Environmental Conservation (DEC) has asked that I provided comments on a draft City Ordinance No. 02-05 addressing groundwater use on St. Paul Island, received by DEC on November 1. I have some general comments on the subject of institutional controls under DEC’s cleanup regulations and some more specific comments on the proposed ordinance itself.
As you may know, DEC has had discussions with NOAA, the City of St. Paul, the Tanadgusix Corporation (TDX) and other stakeholders concerning cleanup issues associated with the downtown site commonly referred to as Tract 46 (the study area) on St. Paul Island.
One of the issues under discussion is selection of cleanup levels and the establishment of “institutional control” measures designed to ensure that the cleanup measures remain protective of human health and the environment. See attached letter from DEC to Ron Terry Turner, counsel to TDX.
The establishment of legal mechanisms to ensure that cleanup levels are protective is described in DEC’s regulations at 18 AAC 75.375. Institutional controls include a variety of measures including
“(1) the requirement for and maintenance of physical measures, such as fences and signs, to limit an activity that might interfere with cleanup or result in exposure to a hazardous substance at the site;
(2) the requirement for and maintenance of engineering measures, such as liners and caps, to limit exposure to a hazardous substance;
(3) restrictive covenants, easements, deed restrictions, or other measures that would be examined during a routine title search, and that limit site use or site conditions over time or provide notice of any residual contamination; and
(4) a zoning restriction or land use plan by a local government with land use authority.”
Under 18 AAC 75.375(c), the “use of institutional controls must, to the maximum extent practicable, be
(1) appurtenant to and run with the land so that the control is binding on each future owner of the site; and
(2) maintained by each responsible person or owner of the site."
For additional information see site file. |
Louis Howard |
| 12/31/2002 |
Update or Other Action |
Corrective action activities were conducted in two phases in 2002. Phase I included excavation of petroleum contaminated soils from two areas of concern. Area 1 was associated with the previously decommissioned-in-place 10,000 gallon UST (UST no. 4). Area 2 was associated with previous soil sample HA-3/S-1 containing DRO at 2600 mg/kg. 260 cubic yards were removed from Area 1. 8 cubic yards were removed from Area 2.
Phase II involved removal of UST No. 4 and any additional contaminated soil encountered during the removal. 160 cubic yards of soil was removed along the south side of the DPP up to the concrete slab of the remaining structure. Further excavation was not feasible due to refusal, existing utility lines near the valve vault, and the DPP footings. |
Louis Howard |
| 5/13/2003 |
Institutional Control Record Established |
It is the Department’s understanding that NOAA will conduct additional site investigation work to deal with the diesel and gasoline contaminated soil at the southeastern-most limits of this project area near the valve pit under a separate contract because it borders a separate investigation area that was established by NOAA. In the event that the remaining contaminated soil becomes accessible by the removal of the soil beneath the roadway located to the east of the site, 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, 18 AAC 75, and 18 AAC 78 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions deemed appropriate by the Department at TPA 9C if information becomes available that contamination present at this site poses an unacceptable risk to human health or safety, welfare, or the environment. Please provide the Department with a description and map of the location of any monitoring wells located near the site which may be used to monitor any potential migration of contaminants attributed to the site.
Groundwater use will be prohibited for any purpose until cleanup levels are achieve. A critical groundwater management area (CWMA) determination will be made by the Alaska Department of Natural Resource Water Management which will show up on deed searches and serve as an additional institutional control. |
Louis Howard |
| 5/13/2003 |
Conditional Closure Approved |
ADEC Staff received the above closure document, for Decommissioned Power Plant TPA Site No. 9C, on April 21, 2003. Based on our review of the document, the Department finds the residual contamination contained within the fractured rock, soil between the boulders and soil beneath the remaining building structure does not pose a significant threat to human health or safety, or the environment. NOAA has already removed and treated 390 cubic yards of contaminated soil associated with the 10,000 gallon underground storage tank. This fact combined with the remaining site conditions, the Department has determined that no further remedial action is required for TPA Site No. 9C, which is equivalent to certification by the Department that corrective action is complete under TPA section 59. Closure of Sites of Operable Units.
It 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.”
It is the Department’s understanding that NOAA will conduct additional site investigation work to deal with the diesel and gasoline contaminated soil at the southeastern-most limits of this project area near the valve pit under a separate contract because it borders a separate investigation area that was established by NOAA. In the event that the remaining contaminated soil becomes accessible by the removal of the soil beneath the roadway located to the east of the site, 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, 18 AAC 75, and 18 AAC 78 to require NOAA to conduct additional site assessment, remediation, and/or other necessary actions deemed appropriate by the Department at TPA 9C if information becomes available that contamination present at this site poses an unacceptable risk to human health or safety, welfare, or the environment. Please provide the Department with a description and map of the location of any monitoring wells located near the site which may be used to monitor any potential migration of contaminants attributed to the site.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required:
1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1;
2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
For additional information see site file. |
Louis Howard |
| 11/29/2004 |
Update or Other Action |
Tetra Tech EMI conducted groundwater monitoring in the vicinity of the DPP quarterly from October 2003 to July 2004. DRO was detected above the Table C Groundwater Cleanup level in four up-gradient wells: MW46-30, MW46-6, MW46-5, and MW46-28. GRO benzene, and toluene were also detected above Table C cleanup levels in some of these up-gradient wells. In down-gradient well MW46-9, the DRO concentration had decreased since 2000/2001 monitoring to a level below the Table C cleanup level. |
Louis Howard |
| 11/30/2004 |
Site Added to Database |
Site duplicated from TPA 09D STP Decomm Power Plant Annx, Reckey 1994250135426. |
Louis Howard |
| 2/11/2005 |
Update or Other Action |
Request for conditional closure document sent by NOAA. ADEC concurred. In accordance with Paragraph 59 of the Two Party Agreement, this is to confirm that all corrective action has been completed to the maximum extent practicable at the Decommissioned Power Plant, TPA Site 9c/Site 18 in accordance with the Agreement and that no further remedial action is required as a part of this conditional closure.
However, please note that DEC reserves all of its rights under 18 AAC 75, 18 AAC 78, and AS 46 to require NOAA to conduct further investigation and/or remedial action if information indicates conditions at the Decommissioned Power Plant TPA Site 9c/Site 18 pose a risk to human health, safety and welfare, and of the environment. |
Louis Howard |
| 4/17/2006 |
Update or Other Action |
PUBLIC NOTICE
State of Alaska,
Department of Natural Resources,
Division of Mining, Land, and Water
550 W. 7th Ave. Suite 1020
Anchorage, Alaska 99501
Notice of Critical Water Management Area
St. Paul, Alaska
Pursuant to AS 46.15 and rules and regulations promulgated thereunder, notice is hereby given that the Commissioner of the Department of Natural Resources has establish a Critical Water Management Area (CWMA) with respect to the groundwater aquifer in the area generally described as the town site of the City of St. Paul, Alaska. As a result of hydrologic studies and water quality work performed, the groundwater aquifer under the town site of St. Paul is contaminated with fuel oil and other hydrocarbons rendering the water unusable for human consumption. In addition, the construction of water wells and pumping of water from wells in the area has the potential of causing the contaminates to move into areas that are not currently contaminated.
Pursuant to AS 46.15 and 11 AAC 93 the Commissioner has issue an order establishing a Critical Water Management Area that include the following:
1. The CWMA applies only to the use of subsurface (groundwater) water within the specific area.
2. Prohibits the acceptance of any Application to Appropriate Water for groundwater or application for temporary use of groundwater and deny the construction of any new water wells in the CWMA after May 23, 2005 until such time as the designation is vacated by the Department.
3. Establishes within the boundary of the CWMA that no person shall divert, impound, withdraw or use without a valid permit of certificate of appropriation for any amount of groundwater. The use of less than a significant amount of water is no longer exempt from use without a permit or certificate of appropriation.
4. Notifies anyone using groundwater within the boundary of the CWMA without a valid permit, certificate or authorization that they shall be prosecuted under AS 46.15.180 and immediately served with a cease and desist order pursuant to 11 AAC 93.290(a)(4). If necessary to prevent further violations, a court order will be obtained pursuant to 11 AAC 93.290(b) authorizing seizure or removal of structures or works of appropriation.
5. Allows the Department to establish additional conditions on diversions, withdrawals or use of groundwater to insure against the further deterioration of this public water resource.
General CWMA boundary: The proposed CWMA will include the industrial area and a portion of the residential area in the City St. Paul proper including areas along Bartlett Boulevard, Polovina Turnpike to the intersection of Haul Road; Shady Lane, Warehouse Street, Short Street, Eagan Street and lands east of Seward Street, all located in Section 25, Township 35 South, Range 132 West, Seward Meriden.
A map of the proposed boundary and properties embraced by this CWMA maybe obtained from the Department of Natural Resources by contacting Gary Prokosch, Chief, Water Resources Section at the above address, or at (907) 269-8645.
The public was invited to comment on this action during the months of April and May 2005. A hearing was held on April 22, 2005 from 9:00 am through Noon at St. Paul Island School. The hearing was attended by 11 individuals; no testimony was received at the hearing. No written comments were received during the open comment period.
The Department of Natural Resources reserves the right to waive technical defects in this publication. |
Louis Howard |
| 4/17/2006 |
Institutional Control Record Established |
The CWMA precludes the use of groundwater from the aquifer within the boundary of the CWMA. The City of St. Paul provides an abundant and clean source of water to the homes and businesses within this area. The monitoring of the water quality in the CWMA will continue into the future, when and if the water quality improves to the point where it can be used, the designated CWMA can be revoked or amended to allow for full or limited use.
The extensive public notice and hearing process required to establish a CWMA resulted in no adverse comments to DNR’s designating the proposed area a CWMA. The establishment of the CWMA will keep current and future landowners with the CWMA from drilling, digging a well or otherwise removing groundwater from the CWMA.
NOAA has the intent and ability to meet the requirements required by ADEC to establishment a 10X rule for contamination clean up in the area of the CWMA . The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells.
The CWMA establishes an institutional control over the removal of groundwater from the contaminated area, which is required under the 10X rule. This is a benefit to the applicant in that a more intensive and expensive clean up would not be required. The applicant has no need to remove water other than for water quality testing from a series of monitoring wells. The establishment of the CWMA will in no way effect the ability of the public to access navigable or public waters. |
Louis Howard |
| 4/1/2008 |
Update or Other Action |
NOAA submitted a Corrective Action Report and Conditional Closure Request for the Decommissioned Power Plant Demolition and Contaminated Soil Removal (NOAA Site 18/TPA 9c). The DPP and pump house were demolished, and the building demolition debris was placed in the City of St. Paul landfill. Minor amounts of asbestos in the DPP were removed, containerized, and
either shipped off-island, and or disposed in a permitted asbestos monofill. During the corrective action, BSE removed approximately 800 cubic yards of PCS from the site and transported it to
NOAA’s ADEC-approved landspreading area at the National Weather Service property on the island. BSE backfilled the PCS excavation to its original grade, using approximately 970 cubic
yards of clean fill material.
After completing the removal of PCS at the DPP site, confirmation samples collected from the excavation bottom and side walls indicated concentrations of DRO exceeded its site cleanup
level within the southeastern half of the excavation, on the excavation bottom. No other contaminants exceeded their site cleanup levels in confirmation samples. More PCS could not be
removed because it was located 18 feet below ground surface and beyond the reach limit of the excavator, or extended into areas with buried utilities and existing roadways where excavation is not required by ADEC.
As a result of this cleanup action, all specified contamination has been removed and no exposure routes remain for human receptors or the environment. NOAA is therefore requesting in this
Corrective Action Report/Conditional Closure Request that ADEC agree further remedial action from NOAA is no longer required at the DPP site since the primary sources of contamination
have been removed and analytical data indicate that PCS has been excavated to the maximum extent practicable. |
Louis Howard |
| 4/8/2008 |
Update or Other Action |
Staff reviewed and concurred with the conclusions and recommendations NOAA provided in the Corrective Action Report and Conditional Closure Request for NOAA Site 18/TPA Site 9c. NOAA and its contractors removed approximately 800 CY of PCS from the Decommissioned Power Plant site in 2007. Although confirmation sample data indicated that DRO concentrations
remain above the site cleanup level in some portions of the bottom of the excavation, further excavation was not practicable due to the depth of excavation relative the reach limitation of the
excavator. Also, PCS remains in areas proximate to buried utilities and roadways (18 AAC 75.325(f), 18 AAC 75.990(93)). Because of the great depth of the remaining contamination (18 ft
bgs), there is no complete exposure pathway to humans or the environment, and therefore site contaminants do not pose unacceptable risks. Groundwater in the vicinity of the site is being
monitored to ensure detection of unacceptable changes in contaminant conditions.
Because the primary sources of contamination have been removed and the objectives of the CAP addendum have been met for the Decommissioned Power Plant, NOAA is requesting with this
report that ADEC grant a conditional closure not requiring further remedial action from NOAA for soil contamination at this site. NOAA requests that ADEC concur with this request by
providing NOAA with a signed copy of the conditional closure approval letter attached at the end of the report. Based on the information and data provided in the report, ADEC signed the approval letter on April 8, 2008: Approvals-In accordance with Paragraph 59 of the Two Party Agreement, this is to confirm that all corrective action has been completed at the St. Paul Island Alaska Decommissioned Power Plant, TPA Site 9c/TPA 18, in accordance with the Agreement and that no plan for further remedial action is required. |
Louis Howard |
| 4/28/2008 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) received the above document on April 8, 2008. Based on a review of the data provided in the report for NOAA Site 18/TPA Site 9c CS DB Reckey 1994250935428, ADEC will approve this report. ADEC has previously submitted signature pages for the conditional closure request and this letter will enable NOAA to finalize the corrective action report. |
Louis Howard |
| 6/4/2008 |
Update or Other Action |
NOAA and ADEC signed the closure letter for St. Paul Island. In accordance with paragraph 59 of the Pribilof Islands Environmental Restoration Agreement (Two-Party Agreement or TPA) January 1996 by designated officials of the State of Alaska and the National Oceanic and Atmospheric Administration (NOAA), NOAA requested Alaska Department of Environmental Conservation (ADEC), as the duly authorized representative of the State of Alaska, certify NOAA’s completion of corrective action for the St. Paul Island Operable Unit (OU).
As of June 4, 2007, the Decommissioned Power Plant Site 9c has contaminated soil, building demoltion debris and contamination is associated with either a UST/AST/pipeline.
Site conditions:Residual soil contaminated with DRO and GRO remains greater than 15 feet bgs and under the roadway; long term groundwater monitoring (DRO contamination); benzene does not exceed 1991 criterion of 0.5 mg/kg, but it does exceed the current criterion of 0.02 mg/kg; deed notice.
Property Owner as of November 6, 2007 is NOAA. Site is within the Critical Water Management Area (CWMA). |
Jennifer Roberts |
| 4/29/2010 |
Update or Other Action |
Annual groundwater monitoring report received. The City of St. Paul overlooks Village Cove and St. Paul Harbor. Sources of petroleum contamination of the groundwater included former fuel storage and dispensing stations and associated piping; demolished and decommissioned power plants; fuel tank farms; and a municipal garage/machine shop (Tutka, 2007a). Nineteen wells located in the Old Village have been selected for long-term monitoring of petroleum contaminants DRO, GRO, and BTEX in groundwater.
Of the 19 monitoring wells involved in long-term groundwater monitoring in the City of St. Paul
Old Village, 18 were statistically analyzed for DRO concentration trends, five for GRO
concentration trends, five for benzene concentration trends, three for toluene concentration
trends, four for ethylbenzene concentration trends, and four for xylene concentration trends.
Of the 39 COC concentration trends analyzed, seven met data quality requirements and are useable for the purposes of this report. All other trends at the city of St. Paul Old Village were not significant at less than a = .05 and are therefore not useable. The seven useable trends show GRO concentrations trending downward at MW46-5; benzene concentrations trending downward at MW46-5, MW46-6, and MW46-28; ethylbenzene concentrations trending downward at
monitoring well MW46-5; and toluene concentrations trending downward at MW46-6 and MW46-10. |
Louis Howard |
| 8/11/2011 |
Update or Other Action |
Staff received the draft LTM plan for review and comment. This long-term groundwater monitoring plan completely replaces and combines National Oceanic and Atmospheric Administration (NOAA) Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska dated August 29, 2005 and NOAA Long-Term Groundwater Monitoring Plan, St. George Island, Alaska also dated August 29, 2005.
This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island and 10 wells on St. George Island. Some wells are utilized as sentinels to monitor for contaminant plume migration while the rest are used to monitor contaminant concentration trends to evaluate the effectiveness of past remedial actions and natural attenuation of contaminants. The requirements specified in this plan will remain in effect until evaluation of contaminant concentration trends indicate a revision is warranted. All revisions to this plan shall be reviewed and concurred with by ADEC prior to becoming final.
The St. Paul harbor/industrial area (Figure 2-1) contains many individual TPA sites that were contaminated by petroleum hydrocarbons as a result of releases from fuel storage/distribution systems. Groundwater in discrete locations within this area is contaminated with DRO, GRO, benzene, toluene and ethylbenzene (NOAA 2008a). For contaminated groundwater in the harbor/industrial area, ADEC granted NOAA an increase in groundwater contaminant concentration cleanup levels to ten times (10X Rule) the levels listed in Table C of 18 Alaska Administrative Code 75 (18 AAC 75) contingent upon institutional controls being put in place to prevent use of the groundwater for any purpose (ADEC 2002). Alaska Department of Natural Resources, pursuant to Alaska Statute (AS) 46.15.520 and 11 AAC 93, established a Critical Water Management Area (CWMA) that encompasses most of the harbor/industrial area (ADNR 2006).
The CWMA provides an institutional control by preventing the issuance of water use permits for groundwater withdrawal within the CWMA boundaries (Figure 2-1). Additionally, property deeds for this area contain deed restrictions or deed notices that inform current and future property owners of the groundwater contamination and corresponding restrictions on its use.
NOAA currently has 19 groundwater monitoring wells in the vicinity of the St. Paul harbor/industrial area (Figure 2-1). The following 10 wells function as sentinels for monitoring contaminant migration: MW46-23, MW46-9, MW46-14, MW46-15, MW46-31, MW46-24, MW46-12, MW46-4, MW46-3, and MWA-2.
The following 9 wells are used for long-term monitoring of contaminant trends within known plume areas: MW46-30, MW46-5, MW46-6, MW46-28, MW46-10, MW46-11, MW46-7, MWA-1, and MWA-3. Groundwater in the vicinity of these wells is contaminated to levels above 18 AAC 75 Table C cleanup criteria, and in the case of MW46-6 and MWA-3, above the 10X Rule cleanup criteria (NOAA 2011a).
To-date, statistical analysis of contaminant concentration trends in this area indicates some analyte concentrations trending up, others trending down, and others with no trend, depending on the well evaluated (NOAA 2011a). Additional monitoring of contaminant concentration trends is required to increase statistical confidence levels that the indicated trends are factual and not random. NOAA will sample the 19 wells within the St. Paul harbor/industrial area semiannually; analytes are DRO, GRO and benzene, toluene, ethylbenzene and total xylene (BTEX).
NOAA installed monitoring wells VIL-MW-1 in 2001 and VIL-MW-3 in 2003 for use in a hydrogeological modeling network. In 2009, VIL-MW-1 was decommissioned. From June 2006 to November 2010, groundwater samples were collected from VIL-MW-3 (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.
To-date, sample analyses have found analyte concentrations either non-detect or detected at very low levels (NOAA 2011b). Statistical analysis of contaminant concentration trends indicates an increasing trend for DRO at a low confidence level; all other analytes had less than two sample results above MRL, therefore no statistical analysis performed (NOAA 2011b). |
Louis Howard |
| 4/30/2012 |
Update or Other Action |
Staff received the Tract 46 Quit Claim Deed from NOAA for review and comment.
The National Oceanic and Atmospheric Administration (hereinafter "NOAA" or
"Grantor"), an agency of the United States Department of Commerce, pursuant to its authority
under Section 205(a) the Fur Seal Act of 1966, as amended (16 U.S.C. § 1165(a)), and in
fulfillment of Paragraph 5(a) and (b) of the Transfer of Property Agreement (TOPA), dated
February 10, 1984, does hereby convey and quitclaim all of its right, title and interest in the
below-described real property to the Tanadgusix Corporation, the village corporation on St. Paul
Island, Alaska (hereinafter the "TDX" or "Grantee"), to wit:1
Tract 46, Sec. 25, T. 35 S., R. 132 W., Seward Meridian, Alaska, as shown on
Dependent Resurvey of a Portion of Tract A, U.S. Survey No. 4943, St. Paul
Townsite and the Dependent Resurvey of Portions of and Subdivision of Tract 41
into Tracts 45 and 46 plat of survey, officially filed June 3, 1997,
a true and correct copy of which survey is attached hereto as Exhibit A, commonly known as the
“Plant Site and Industrial Building Area (formerly known as Tract 41)” and the “West Landing
Area”, together with all rights, privileges, immunities, and appurtenances thereto belonging
(hereinafter referred to as the "Property").
The TDX hereby acknowledges the conditions of the Property and, with the sole
exception of the covenants made hereunder pursuant to Section 120(h) of the Comprehensive
Environmental Response, Compensation and Liability Act, 42. U.S.C. § 9620(h) (CERCLA),
accepts the Property without warranty or representation under this quitclaim deed, and without
recourse to the NOAA or the United States pursuant to this quitclaim deed.
Ingress and egress to nineteen monitoring wells as indicated on Exhibit B, including periodic
sampling from the monitoring wells, and closure of the monitoring wells consistent with
direction from the State of Alaska Department of Environmental Conservation.
Grantor states that in accordance with the direction of the Alaska Department of
Environmental Conservation ("ADEC"), an agency of the State of Alaska, corrective action has
been taken on the Property and completion of such corrective action is further evidenced by a
certain "Closure of the St. Paul Island, Alaska Operable Unit" letter dated June 4, 2008,
concurred with by ADEC, a true and correct copy of which is attached hereto as Exhibit D.
Corrective action locations specific to the Property are listed in Exhibit D as NOAA Sites 18
(TPA Site 9c), 19 (TPA Site 9d), 20 (TPA Site 9e), 21 (TPA Site 9f), 22 (TPA Site 9g), 23 (TPA
Site 9h), 25 (TPA Site 9j), 27 (TPA Site 9l), 28 (TPA Site 9m), 29 (TPA Site 10), 49 (TPA Site
9n), and 51 (TPA Site 9p). |
Louis Howard |
| 7/6/2012 |
Document, Report, or Work plan Review - other |
Staff commented on the draft St. Paul Tract 46 Quit Claim Deed and Exhibits.
5 Acceptance of Property
ADEC requests NOAA make this section broader to provide access to the general area for groundwater monitoring purpose (e.g. use the language cited in the third paragraph under “Hazardous Substance Warranty”). NOAA may need to replace wells or possibly install new wells in the general area.
Hazardous Substance Warranty
Public Law 106-562, Section 107 Authorization of Appropriations states: “Limitation- None of the funds authorized by this subsection may be expended for the purpose of cleaning up or remediating any landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, or contaminants, including petroleum products and their derivatives, left
by the Department of Defense or any of its components on lands on the Pribilof Islands, Alaska.”
Please change “waste dumps” to “wastes, dumps”.
Deed Restrictions/Groundwater Restrictions
ADEC is concerned about monitoring well replacement or installation of new monitoring wells in close proximity to the existing ones, if determined to be necessary. See comment #1 above regarding additional language and the need in the future for NOAA to replace wells or install new ones.
Deed Restrictions/Soil Removal Restrictions
The Exhibits listing has two F-4s, perhaps the second one is supposed to be F-5? |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73180 name: auto-generated pm edit TPA 09C STP Decom. Power Plant |
Louis Howard |
