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Site Report: IHS Kanakanak Hospital - Area 2

Site Name: IHS Kanakanak Hospital - Area 2
Address: 6000 Kanakanak Road, Dillingham, AK 99576
File Number: 2540.38.005
Hazard ID: 25464
Status: Cleanup Complete - Institutional Controls
Staff: Tim Sharp, 9074512131 tim.sharp@alaska.gov
Latitude: 59.000670
Longitude: -158.540150
Horizontal Datum:WGS84

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

The site is in the quarters area, encompassing buildings 315, 316, 317, & 318 which serve as staff housing. A former fuel distribution line delivered heating oil to the underground fuel storage tanks associated with the buildings. In 1990 or 1991, the tanks were removed and replaced with new underground storage tanks. If contaminated soil was encountered during tank removal, it was excavated and replaced with clean soil. Soil samples were not collected, and records were not kept to indicate which individual tanks were associated with contaminated soil. Footing drains from the buildings discharged via an outfall line to the soil north of building 318. The footing drains would occasionally become plugged and residents would complain that oily water would backup into the basement of the buildings. In 1990, the hospital sanitarian unplugged the footing drain to building 318, and a discharge of oily water poured out of the drain. The fuel distribution line has been decommissioned, and is tracked as a separate area of concern. The facility is served by two Class A wells located approximately 500 feet up gradient of Area 2. Shallow groundwater at the site is 12 to 15 feet below ground surface, but drinking water is obtained from a deeper, confined aquifer. The drinking water wells are thought to be screened at approximately 85 feet below ground surface, and the State Drinking Water Program verified that these wells have not been impacted by petroleum contamination.

Action Information

Action Date Action Description DEC Staff
11/5/2009 Site Added to Database A new site has been added to the database Deborah Williams
11/6/2009 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 78826 name: Area 2 heating oil tanks, fuel distribution line and outfall Kim DeRuyter
12/11/2009 Update or Other Action A draft request for closure report was submitted on 11/6/09. Area 2 was defined as an outfall north or a duplex, Building 318 where footing drains had discharged contaminated water. The source of the contamination was one or more fuel oil tanks removed in 1991. The tanks were removed without soil sampling, but oily water was said to backup into the basements of the residences when the footing drains were clogged. Staff responded 11/19/09, that Area 2 should incorporate the potential sources of the contamination (4 former USTs), and that site characterization efforts were inadequate to make a closure decision. A Final closure request for area 2 was submitted on 12/11/09. This report incorporated the former USTs into area 2, but did not provide any additional evidence to support site closure. Kim DeRuyter
11/28/2012 Document, Report, or Work plan Review - other The Final Work Plan to address Areas 2, 5, and 7 was approved. 10 soil borings will be advanced at area two and one monitoring well will be installed. Meghan Dooley
2/19/2014 Cleanup Plan Approved Reviewed site files, current investigations, and monitoring from adjacent sites. Site is appropriate for a cleanup complete determination with required institutional controls. Landowner concurrence is required, including concurrence by entities to whom land will be transferred. Sent letter dated 2/19/14 to IHS with copies to Alaska Area Native Health Service. Fred Vreeman
4/2/2014 Update or Other Action Received a concurrence letter from Alaska Area Native Health Service for a cleanup complete with institutional controls decision. Site is now suitable for closure with contamination left in place and land use restrictions agreed to by owners. IC compliance reviews are required. Fred Vreeman
5/13/2014 Institutional Control Record Established Institutional Controls established and entered into the database. Monte Garroutte
5/13/2014 Cleanup Complete Determination Issued Petroleum contamination does not remain in the surface soil, sub-surface soil or groundwater above the ADEC approved alternate cleanup levels on this site. ADEC has determined there is no unacceptable risk to human health or the environment as long as the contamination is properly managed. A cleanup complete with institutional controls determination has been made for this site. The responsible party is required to report every five years to ensure that the institutional controls have been maintained. Monte Garroutte
8/7/2015 Update or Other Action Transfer to Fairbanks Susan Carberry
5/8/2020 Update or Other Action DEC conducted a teleconference with IHS, BBAHC, and ERM representatives for the site. Discussed summary of site. Additionally, clarified that the Alternative Cleanup Levels (ACLs) from 1998 would no longer apply as regulations have been introduced that are more stringent than these values. DEC will send a formal letter explaining the decision to rescind old cleanup levels and clarifying applications of newer levels as detailed in 18 AAC 75.340 and 345. Tim Sharp
7/21/2020 Update or Other Action Due to numerous regulatory changes, updated toxicological information, and groundwater impacts at the site, the 1998 ACLs previously accepted by DEC have been rescinded. The contaminated sites at Kanakanak Hospital are subject to the “site cleanup rules”, 18 AAC 75.325 – 18 AAC 75.390. Thus, in lieu of the 1998 ACLs, the currently promulgated cleanup levels in 18 AAC 75 apply. For contaminants in soil, the Human Health, Maximum Allowable, and Migration to Groundwater cleanup levels apply, as listed in Tables B1 and B2 of 18 AAC 75.341. For contaminants in groundwater, the Groundwater Cleanup Levels in Table C of 18 AAC 74.345 apply. Sites that were previously categorized as 'Cleanup Complete' or 'Cleanup Complete with Institutional Controls' may be subject to further review. DEC has sent a formal letter to IHS and BBAHC representatives explaining this change. Tim Sharp
8/17/2020 Document, Report, or Work plan Review - other DEC supplied comments for the Site Wide IC Management Plan. The IC MP details the history of each area of concern at the site and the specific ICs in place for each of the closed sites with ICs. Due to the rescission of the 1998 ACLs, DEC requested each AOC be analyzed by IHS to determine if the ICs are still protective of human health and the environment. Other comments call attention to potentially complete pathways to consider, and further monitoring of groundwater at landfarms. Tim Sharp
9/21/2020 Update or Other Action DEC received the Draft Plan to Develop ACLs at Kanakanak Hospital Memo. The RP has chosen to use the hydrocarbon risk calculator to develop new ACLs. The methods listed include using previous data for Toc values, while collecting new samples for EPH/VPH analysis. Conservative values will be used for bulk density, aquifer thickness, and porosity. A list of data gaps involving drill rig mobilization is also included. Tim Sharp
10/23/2020 Document, Report, or Work plan Review - other DEC provided comments for the Draft Plan to Develop ACLs Memo. Comments regarded including figures for sampling locations, methodology clarification, and bringing attention to data gaps that would require a drill rig to close (Area 3 and 7 MAC exceedances). Tim Sharp
7/19/2022 Site Visit DEC performed a site visit for all areas of concern on the Kanakanak Hospital campus. As part of the site visit, IHS, BBAHC, ERM and DEC held a meeting to discuss the proposed next steps at the site to evaluate remaining contamination and potential transfer of property from IHS to BBAHC. Tim Sharp
1/3/2023 Document, Report, or Work plan Review - other DEC reviewed and submitted comments for the Proposed Alternative Cleanup Levels Memo for Kanakanak Hospital. The Memo proposes new alternative cleanup levels (ACLs) intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. ACLs were developed using the Hydrocarbon Risk Calculator (HRC) as allowed under 18 AAC 75.340 (d) – (f). The ACLs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed ACLs given the three- and four-phase calculations conducted using new and historical site-specific data. Tim Sharp
3/24/2023 Document, Report, or Work plan Review - other DEC approved the Proposed Preliminary Remediation Goals (PRGs) based on Hydrocarbon Risk Calculator (HRC) Calculations Tech Memo for Kanakanak Hospital in Dillingham. The tech memo proposes new PRGs intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. PRGs were developed using the HRC. The PRGs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed PRGs given the three- and four-phase calculations conducted using new and historical site-specific data. The technical memorandum asserts that the results of the HRC require validation. Upon attaining PRGs in soil at a given area of concern, model validation will be considered complete when measured concentrations in groundwater fall below 18 AAC 75.345(b), Table C groundwater cleanup values in at least two successive sampling events, accounting for seasonal variability. If these values cannot be attained, reassessment of the PRGs may be appropriate to adjust them downwards. Tim Sharp
8/25/2023 Document, Report, or Work plan Review - other DEC completed a review of the Draft Supplemental Site Investigation Report. The SI Report details soil and groundwater sampling at eight areas of concern (AOCs) at the Indian Health Service (IHS) Kanakanak Hospital Site. These samples are being used to assist in characterizing contamination at the site, and are being evaluated in tandem with the recent preliminary remediation goals (PRGs) identified in the Proposed Preliminary Remediation Goals based on Hydrocarbon Risk Calculator Calculations memorandum, approved by DEC. Future review of previously closed sites is recommended, and a feasibility study will be prepared for evaluation of remediation options. Tim Sharp

Contaminant Information

Name Level Description Media Comments
DRO Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil DRO concentrations of 1,700 mg/kg were detected in the soil in 2012 in sample 12-Kanak-12SB-10-1036. DRO concentrations in groundwater have not exceeded Table C cleanup values following a single sample in 1992.

Control Type

Type Details
Notice of Environmental Contamination As a condition of the 1998 alternative cleanup levels agreement between ADEC and IHS, if any contamination exists on a site above the ADEC method one calculated cleanup levels, a Notice of Environmental Contamination (deed notice) shall be recorded in the State Recorder’s Office as an institutional control (IC) that identifies the nature and extent of contamination at the property and the conditions that the owners and operators are subject to. DRO contamination at concentrations up to 1,700 mg/kg is present at this site.
Institutional Control Management Plan An IC management plan has been established for this site. The conditions laid out in the "cleanup complete with institutional controls" decision document for the IHS Kanakanak Hospital Area 2, dated February 19, 2014, serve as the management plan

Requirements

Description Details
Periodic Review Any future change in land use may impact the exposure assumptions cited in the cleanup complete with institutional controls decision document. If land use and/or ownership changes, these management conditions may not be protective and ADEC may require additional remediation and revised conditions. Therefore the Indian Health Service shall report to ADEC every five years to document land use, or report as soon as the Indian Health Service becomes aware of any change in land ownership and/or use, if earlier. The report can be sent to the local ADEC office or electronically to the current ADEC program manager.
Excavation / Soil Movement Restrictions Any ground disturbing activities or facility construction must be coordinated with and approved by the ADEC Contaminated Sites Program.
Groundwater Monitoring Groundwater monitoring wells on the site must be decommissioned in accordance with the most current ADEC Monitoring Well guidance, found at http://dec.alaska.gov/spar/guidance.htm. Coordinate well decommissioning with ADEC prior to removal.
Advance approval required to transport soil or groundwater off-site. Any proposal to transport soil or groundwater off-site requires ADEC approval in accordance with 18 AAC 78.600(h). A “site” [as defined by 18 AAC 75.990 (115)] means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership.
Excavation / Soil Movement Restrictions Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited.
Groundwater Use Restrictions Groundwater in the state of Alaska is protected for aquaculture use. In the event that an aquaculture facility uses groundwater from this site in the future, additional treatment may be required to meet aquatic life criteria under 18 AAC 70.

No associated sites were found.

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State of Alaska Department of Environmental Conservation

P.O. Box 111800
Juneau, AK 99811-1800
Phone: 907-465-5066
Fax: 907-465-5245
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