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Site Report: HEA Kenai NWR Utility Poles

Site Name: HEA Kenai NWR Utility Poles
Address: Utility ROW in Kenai NWR; Near MP 70 Mile Sterling Hwy; ~12 Miles E of Sterling, Sterling, AK 99672
File Number: 2334.38.059
Hazard ID: 26551
Status: Non-Qualifying
Staff: No Longer Assigned, 9074655229 dec.icunit@alaska.gov
Latitude: 60.532185
Longitude: -150.419226
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

Homer Electric Association (HEA) has rights of way through the Kenai National Wildlife Refuge for utility lines. US Fish and Wildlife Service collected soil samples at the base of twelve utility poles near mile 70 of the Sterling Highway due to concern over potential leaching of contaminants from the treated wooden poles and the fact that HEA had plans to remove and replace several of the poles in early 2016. The poles had been treated with pentachlorophenol as a wood preservative. Two separate utility lines run through the right of way, a 69kV line installed during the 1950s and a 115kV line installed in the 1980's. Composite samples were collected along each of the two lines from surface soil at the base of the poles and at distances of 25 cm and 50 cm from the base of the poles. The soil sample results showed high concentrations of pentachlorophenol, dioxins and furans in surface soil at the base of all the poles where samples were collected. Contaminant concentrations decreased significantly with distance from the poles. The horizontal and vertical extent of contamination was not determined. Samples were only collected from near 12 poles in the vicinity of the current utility line project. Granite Construction collected samples from around five utility poles near the East Fork Moose River and in conflict with the Alaska Department of Transportation Sterling Highway MP 58-79 Rehabilitation project in spring of 2018. Soil samples were collected from varying distances around the poles. Data showed concentrations of PCP, polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs) above 18 AAC 75.341 cleanup levels are limited to within a radius of 1 to 10 feet of the source poles. Parties agreed that remaining pole remnants and butts would be removed from the ground with minimal disturbance, holes backfilled with clean fill, and the contaminated areas covered with geo-textile, geo-grid fabric, and a minimum of three feet of clean fill. The vertical extent of contamination was not defined for three of the five poles. ***Note - Site Status changed to "non-qualifying" on December 11, 2017 in response to HEA's position that use of penta-treated utility poles is authorized under the federal Fungicide, Insecticide and Rodenticide Act (FIFA) and any resulting contamination isn't regulated under CERCLA, RCRA or State law. DEC has not concurred, but agreed to not post this site on the internet version of the CSP database, pending further data collection and legal review.***

Action Information

Action Date Action Description DEC Staff
5/2/2016 Site Added to Database A new site has been added to the database Mitzi Read
5/3/2016 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 79910 name: HEA Kenai NWR Utility Poles Mitzi Read
5/6/2016 Potentially Responsible Party/State Interest Letter DEC sent Homer Electric Association (HEA) a Potentially Responsible Party letter and a letter requesting submittal of a site characterization workplan by not later than June 22, 2016. John Halverson
6/14/2016 Update or Other Action DEC received a letter from HEA stating it does not believe additional site characterization is necessary and requesting that DEC rescind the Potentially Responsible Party letter and request for site characterization. John Halverson
8/22/2016 Meeting or Teleconference Held DEC met with staff and contractors working for ADOT, USWFS and HEA regarding a Sterling Highway Improvement Project scheduled for construction in 2017 that will impact contaminated soil at the base of PCP treated utility poles near the East Fork of Moose Creek. DOT will include contract provisions requiring an environmental consultant to develop and implement plans to conduct sampling and analysis around utility poles that will need to be removed and to properly manage contaminated media during the construction project. The plans will be developed in coordination with USFWS, HEA and DEC. Decisions on whether contaminated soil/sediment can be managed in place or will need to be removed will be based on the sample results, design and construction plans, the feasibility of removal and evaluation of potential risks posed. A goal is to conduct the soil sampling this winter so data are available for review in the spring in time to plan any necessary removal and waste management activities for the construction to proceed. John Halverson
7/12/2017 Meeting or Teleconference Held DEC met with representatives from ADOT, Western Wood Preservers Institute, Tellus (QEP for DOT), Integral Consulting Inc. to answer questions and discuss ADOT Sterling Highway Improvement project schedule. Western Wood Preservers Institute and Consultant (Integral Consulting, Inc.) requested to review the ADOT project Sampling and Analysis Plan being written. The ADOT project has begun, but the schedule for sampling was not clear. Wendy Hansen
8/15/2017 Update or Other Action DEC corresponded with the Project Engineer who reported that two of the HEA poles planned for sampling (QK-255 and QK-256) fell over during electrical transmission line decommissioning activities at the East Fork Bridge. The length and buried depths were measured and documented. The poles were taken to the HEA yard in Kenai and the areas surrounding QK-254 through QK-257 were secured to mitigate potential disturbance. Photos and communications indicated that the surface area around poles QK-255 and QK-256 had been disturbed, to include the planned surface sample location(s) at QK-255. Wendy Hansen
8/29/2017 Meeting or Teleconference Held DEC staff attended a teleconference with ADOT, USFWS, Tellus (QEP), and Granite Construction representatives to discuss the status of the site near the East Fork Moose River near MP 71.5 with regard to potentially compromised sample locations around utility poles, water management, path forward, and status of the Sampling & Analysis and Soil Management Plans that were scoped in ADOT contract specifications for the project. Wendy Hansen
8/30/2017 Update or Other Action DEC Contaminated Sites requested a dewatering permit for management of storm water that had accumulated on site, prior to pumping. The collection of surface soil sample(s) from the water accumulation area prior to the placement of fill material was also requested. Wendy Hansen
9/14/2017 Document, Report, or Work plan Review - other DEC staff provided comments on surface water and sediment/soil sampling plans. The plans provided details for sampling activities planned in an area of standing water that collected in a low spot adjacent to a power pole where dioxins and pentachlorophenol were detected in previous sampling efforts. Wendy Hansen
9/22/2017 Document, Report, or Work plan Review - other DEC staff provided comments to Granite Construction on a revised sediment sampling plan, for collection of samples in the ponded water accumulation area. Wendy Hansen
9/25/2017 Document, Report, or Work plan Review - other DEC staff provided comments to Granite Construction on a revised surface water sampling plan, for collection of samples in the ponded water accumulation area. Wendy Hansen
10/6/2017 Enforcement Action DEC staff issued an NOV to Granite Construction Company and ADOT, Enforcement Tracking No. 2017-R0871 for conducting regulated activities within an active contaminated site without a work plan. Wendy Hansen
10/16/2017 Update or Other Action Granite Construction Company issued letter dated October 13, 2017 to the DEC requesting that NOV 2017-R0871 be reversed to a Compliance Letter. Wendy Hansen
10/17/2017 Document, Report, or Work plan Review - other DEC staff provided comments to Granite Construction on a second revision to each surface water and sediment/soil sampling plans, for collection of soil samples in the ponded water accumulation area and water samples from a lined containment basin. The revised plans were submitted to the DEC on October 9, 2017. Wendy Hansen
10/19/2017 Meeting or Teleconference Held DEC staff met with representatives from ADOT, Granite Construction, and contractor/QEP Corvid, LLC. to resolve outstanding comments on the soil and surface water sampling plans. Revised plans are anticipated the week of October 23, 2017. The original sampling plan for the ten (10) utility poles is anticipated by December 1, 2017. Wendy Hansen
10/19/2017 Update or Other Action DEC staff issued a letter to Granite Construction Company denying the reversal of NOV 2017-R0871. Wendy Hansen
11/2/2017 Document, Report, or Work plan Review - other DEC staff provided comments to Granite Construction on a third revision (Rev.4) to the soil (formerly sediment) sampling plan, for collection of soil samples in the ponded water accumulation area. The revised plan was submitted to the DEC on October 25, 2017. Wendy Hansen
11/3/2017 Site Characterization Workplan Approved DEC staff approved Rev.5 to the soil (formerly sediment) sampling plan, for collection of soil samples in the ponded water accumulation area. The revised plan was submitted to the DEC on November 3, 2017. Wendy Hansen
3/27/2018 Site Characterization Workplan Approved Staff approved Work Plan titled Five Pole Site Characterization Work Plan Sterling Highway Rehabilitation Sterling, Highway, Alaska Final, and dated March 23, 2018. The plan was written by Corvid, LLC (on behalf of Granite Construction) and submitted to the ADEC on March 25, 2018. The focus of the site characterization is to delineate the nature and extent of pentachlorophenol (PCP) and polychlorinated dibenzo-p-dioxins (PCDD) and polychlorinated dibenzofurans (PCDF) around five utility poles near the East Fork Moose River in conflict with the Alaska Department of Transportation Sterling Highway Rehabilitation project. The data will be used to support decisions regarding management of soil around the poles. Wendy Hansen
3/27/2018 Enforcement Action Closed NOV 2017-R0871 was closed. All terms and conditions have been completed to the satisfaction of DEC. Wendy Hansen
4/4/2018 Update or Other Action DEC staff issued a closure letter to Granite and ADOT for NOV 2017-R0871. Wendy Hansen
5/17/2018 Document, Report, or Work plan Review - other DEC approved Granite's Final Storm Water Runoff Characterization Sampling work plan submitted May 15, 2018. The focus of the plan is to collect water samples from a constructed and lined containment cell at the construction site to inform decisions regarding discharge or disposal. Wendy Hansen
6/26/2018 Update or Other Action DEC received surface water sample results from Granite's lined containment cell. One sample and a duplicate were collected. No pentachlorophenol was detected. The Toxic Equivalent Quotient for polychlorinated dibenzo-p-dioxins and dibenzofurans was below Alaska Water Quality Standards. Wendy Hansen
6/29/2018 Update or Other Action The Department of Water issued Excavation Dewatering Authorization AKG002102 to Granite Construction for the discharge of water in the lined containment cell. The water will be used for dust suppression at Granite's material site at MP 77 of the Sterling Highway. Wendy Hansen
8/1/2018 Document, Report, or Work plan Review - other DEC received letter report providing summary of data from DOT/Granite 5-pole site characterization. Wendy Hansen
8/6/2018 Meeting or Teleconference Held DEC staff met with DOT, FWS, HEA, Granite, and Consultant Corvid to discuss data from 5-pole site characterization and path forward for management of utility poles in conflict with DOT/Granite construction project. Soil samples were collected from varying distances around the poles in March of 2018. Data show concentrations of PCP, polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs) above 18 AAC 75.341 cleanup levels are primarily limited to within a radius of 1 to 10 feet of the source poles. The vertical extent of contamination was not determined for three of the five poles. Wendy Hansen
8/8/2018 Update or Other Action DOT, FWS, and DEC agreed that remaining pole remnants and butts associated with poles in conflict with the DOT/Granite construction project at MP 58-79 will be removed from the ground with minimal disturbance, holes will be backfilled with clean fill, and the contaminated areas will be covered with geo-textile, geo-grid fabric, and a minimum of three feet of clean fill. Wendy Hansen
8/24/2018 Update or Other Action DEC received draft site characterization report written by Corvid,LLC., and dated August 24, 2018. The report was prepared for Granite Construction under contract to the Alaska DOT. It documented site activities conducted in 2018 to characterize the nature and extent of contamination (pentachlorophenol, polychlorinated dibenzo-p-dioxins, and polychlorinated dibenzofurans) in soil around five utility poles in conflict with a Sterling Highway Rehabilitation project. Wendy Hansen
4/19/2019 Site Characterization Report Approved DEC approved the final report titled Five Pole Site Characterization and Background Study Report; Sterling Highway Rehabilitation; Sterling, Alaska; Final Revision 1, dated April 1, 2019. A draft report was submitted on August 28, 2018. The draft report was revised to address stakeholder comments. Wendy Hansen

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