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Site Report: Manley Hot Springs Gravel Pit

Site Name: Manley Hot Springs Gravel Pit
Address: Steese Highway, 3/4 Mile East of Manley, Manley Hot Spgs, AK 99756
File Number: 180.38.008, 180.23.001
Hazard ID: 290
Status: Active
Staff: Stacee Henderson, 9072628202 stacee.henderson@alaska.gov
Latitude: 65.006653
Longitude: -150.597152
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

In September 1989 ADEC staff sampled three drums abandoned in a brushy area above the perimeter of the Manley Hot Springs gravel pit, a then-active pit located on the Elliot Highway approximately 1.3 miles east of the Manley Hot Springs town center. The drums were located on the eastern perimeter of the pit and approximately 40 ft above the floor of the pit. The drums and surrounding soil were found to contain residues of the herbicide 2,4-D and the banned herbicide 2,4,5-T. 2,4,5-T was banned in the U.S. in the 1970s because the manufacturing process produces the trace contaminant 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) the most potent and persistent dioxin. The drum liquids were sampled for 2,3,7,8-TCDD with a maximum concentration of 48,000 ug/L in a mostly filled drum labeled as originally containing a combination of 2,4,5-T and 2,4-D; the other two drums were unmarked. Soil samples from soil near the labeled drum contained 670 mg/kg 2,4,5-T and 150 mg/kg 2,4-D. In August 1990 an approximately 0.5-foot-thick layer of soil in the vicinity of the drums was removed and backfilled with clean fill. The contaminated soils and former herbicide-containing drums were shipped to a hazardous waste treatment facility in Kansas. Additional site characterization in summer 1993 included advancing 11 soil borings, with the highest 2,4,5-T and 2,4-D herbicide concentrations found in soil were just beyond the limits of the 1990 excavation at depths of up to 4.5 ft below the ground surface (bgs). A total of five samples from two of the 11 soil borings were analyzed for 2,3,7,8-TCDD and 2,3,7,8-tetrachlorodibenzofuran (2,3,7,8-TCDF). Four of the five samples contained detectable levels of 2,3,7,8-TCDD ranging from 418 to 24,600 picograms per gram dry soil(pg/g) compared to the EPA action level of 39 pg/g set for 2,3,7,8-TCDD ("dioxin") at that time, and the current applicable human health cleanup level of 60 pg/g. The fifth dioxin-analysis sample, collected from 6 to 6.5 feet bgs, did not contain dioxin or furan analytes above the laboratory practical quantitation limit (PQL) of 72 pg/g. Following sampling the spill area was covered with a 20-foot by 10-foot sheet of 20-mil high-density polyethylene liner. In 1994 the ADEC had a chain-link fence installed around the perimeter of the spill. In May 2006 five soil borings were drilled within the fenced area and four samples were collected from surface soil outside the fenced area. Ten samples exceeded the dioxin action level of 39 pg/g including three of the four surface samples collected outside the fenced area. Each of the five soil borings (B-1 through B-5) also yielded samples above the dioxin action level; the dioxin TEQ (toxicity equivalent) was above the limit in each of the samples collected to a depth of 0.5 foot bgs, and the sample from 2.5 to 3.0 feet bgs in Boring B-3 also exceeded the maximum allowable dioxin TEQ. Boring B-3 also yielded the sample with the highest dioxin TEQ measured to date (29,200 pg/g); this location was coincident with the highest concentration detected during the 1993 characterization work. Based on these sample results we recommended Additional sampling to determine the extent of the dioxin contamination was determined to be warranted prior to developing a corrective action plan. In March 2007, S&W completed a report evaluating the remedial alternatives for the site and recommended capping the soil in place after delineating the full extent of the soil contamination. CS project file # 180.38.008 was combined with the RCRA file #180.23.001.

Action Information

Action Date Action Description DEC Staff
4/25/1986 Update or Other Action On 4/26/1986 ADEC received initial complaint from Manley Hot Springs resident Liza Vernet, who said local residents have found three drums of potential hazardous substances near former ADOT gravel pit. One drum is marked as Hayward Thompson Herbicide that contains 2,4-D and 2,4,5-T and is 2/3-3/4 full of liquid. One drum shot with bullet holes. Gravel pit is now property of the Alaska Native regional corporation Doyon Limited. Local residents recall DOT herbicide use from the 1950s. Staff advised Vernet that we will schedule a visit to the site and advise her prior to it. Former Staff
4/16/1987 Update or Other Action On 4/16/1987 ADEC received a second complaint from Manley Hot Springs resident Liza Vernet, who called in a complaint a year previously. Vernet reported that there are three drums of pesticide on a low hill above the gravel pit located just out of the town of Manley Hot Springs. Vernet stated that two drums are empty and one is nearly full. Her concern is that a lot of gravel is being removed from the pit, and the drums may come down off the slope as a result. Former Staff
4/29/1987 Site Visit 4/29/1987 site visit by Carol Linkswiler of ADEC, accompanied by complainant Liza Vernet, who lives in Manley Hot Springs. Observed and photographed drums; one is clearly labeled Thompson-Hayward "Ded-Weed 2,4D and/or 2,4,5-T weed and brush killers" in brush at the top of the east side of the pit. Vernet stated that the 'old-timers' say the drums are from ADOT spraying of roadsides in the late 1950s. Photographs taken during the site visit show the "Ded-Weed"-labeled drum is upright and within an approximately 8-inch deep pool of surface water (appears to be melt-water; there is snow in surrounding brushy and grassy area). Former Staff
9/13/1989 Site Visit On 9/13/1989 ADEC staff Cormack, Simmons and Jodwalis visited the site to sample drums and soil in the area. Two drums were within 10 ft of each other and a third drum was located approximately 30 ft away in an area that was not accessible to any vehicular traffic due to brush. Photos taken on this date show all three drums on dry ground; the "Ded-Weed"-labeled drum is in the same place as when photographed in April 1987 but there is no standing water and the area is dry, apparently devegatated but possibly lacking vegetation because it is a surface water ponding area at other times of the year. The "Ded-Weed"-labeled drum was sampled with a glass tube and found to be 1/3 full. It was placed in an overpack drum, labeled as hazardous waste, and left at the site until the regulatory status of the drums and a plan for disposing of them could be made. The liquid from the Ded-Weed-labeled drum was analyzed and found to contain 520 mg/L 2,4,5-T and 1600 mg/L 2,4-D. (1990 analysis of the liquid showed it to contain 48 mg/L of the dioxin TCDD, equivalent to 9.2% of 2,4,5-T concentration). Two other drums each contained less than one inch of rusty water. The contents of these drums were not analyzed but composite samples of the surrounding soil were analyzed. Soil from the devegatated area associated with the Ded-Weed-labeled drum contained 670 mg/kg 2,4,5-T and 150 mg/kg 2,4-D. A composite sample from soil around the drum closest to the Ded-Weed drum detected low levels of 2,4,5-T, 2,4-D and other herbicides. Rich Cormack
8/19/1990 Interim Removal Action Approved VRCA was contracted by the state to test contaminated soil and the two unmarked drums; to excavate and containerize contaminated soil; and to store the excavated soil and drums in a Conex (steel cargo container) within the gravel pit. Post-cleanup samples were found to contain 2,3,7,8-TCDD (a dioxin), indicating the need for further excavation. EPA requires weekly inspection of the Conex. Former Staff
10/19/1990 Site Added to Database Dioxin contamination. Former Staff
11/28/1990 Site Ranked Using the AHRM Initial ranking. Former Staff
9/18/1992 Meeting or Teleconference Held On 9/18/1992 met with attorney and 470 office to discuss cleanup strategies. Cindy Thomas
9/20/1992 Update or Other Action Potentially responsible party search: reviewed and researched potential RPs. Located four and will notify each prior to submitting 470 fund (state lead) request. Cindy Thomas
10/6/1992 Potentially Responsible Party/State Interest Letter Sent "PRP" letters dated 10/6/1992 to BLM, ADOT/PF, Bean Ridge Corp. and Doyon, notifying parties of Response Fund pending. Gave 14 days to respond as to whether each party will undertake tasks without state funding. Cindy Thomas
12/11/1992 Meeting or Teleconference Held Thomas/DuBois: Met with ADOT staff, reviewed blow up aerial photo of gravel pit, no evidence of drums in the 1982 photo, but nothing conclusive. Discussed various agency approaches. Ben Thomas
5/4/1993 Potentially Responsible Party/State Interest Letter ADEC "Determination of Potential Responsible Party Status" letters dated 5/4/1993 sent to same parties as in October 1992 including Bean Ridge Corporation, US BLM, Doyon Ltd., and the Alaska Dept. of Transportation. Each letter states that as a responsible party recipients are required to perform response or removal actions including fully characterizing the contamination, containerizing any sampling wastes, contracting with a hazardous waste transporter to ship the hazardous wastes currently stored at the site, etc. Former Staff
7/1/1993 Site Characterization Report Approved Reviewed "Site Characterization Letter Report", summarizing E&E sampling efforts to determine residual dioxin concentrations. All samples below detection limits except one. Site was covered with 20 mil liner after sampling. Ecology and Environment performed work under Term Contract. Recommended Risk Assessment to determine site-specific dioxon cleanup levels. Cindy Thomas
7/9/1993 Meeting or Teleconference Held Staff Thomas/Dubois met with Northwest Enviroservices on 7/9/1993 to discuss sampling plan for Manley. Northwest will sample, containerize and ship for disposal all dioxin wastes this July. Meeting was primarily to met with contractors and answer general site questions. Ben Thomas
7/15/1993 Site Visit Met with two term contractors - Northwest Enviroservices and Ecology and Environment on-site to inspect the gravel pit, Conex trailer and contents and denuded area. Discussed coordination of projects between two contractors. Also met with Village Tribal Council and Bean Ridge. Site sampling to occur next. Cindy Thomas
8/2/1993 Site Visit On 8/2/1993 inspected drum sampling and reconnaissance efforts by Northwest Enviroservices to sample and verify contents of drums in Conex. Sampling went without incident, but total drum count may vary from count noted by VRCA during storage operation. NWest will submit count shortly. Samples sent to APTUS today for confirmation. Cindy Thomas
7/25/1994 Document, Report, or Work plan Review - other Oversaw and reviewed final report on Shannon and Wilson's installation of a permanent chain-link fence around spill area. Cindy Thomas
8/1/1994 Document, Report, or Work plan Review - other Oversaw the sampling, removal, transport and incineration of all waste drums from the Conex to Coffeeville, Kansas. All stored wastes are now gone from site. Work completed under Term Contract with Northwest EnviroServices. Certificate of Destruction in file. Cindy Thomas
9/25/1994 Cleanup Assumed by ADEC Sent summary letter to 4 PRPs notifying them of summer cleanup activities at the site, including waste removal, site assessment, liner installation and fencing. Told PRPs that ADEC decided No Additional Action with State Funds, but encouraged private cleanup. Cindy Thomas
10/24/1994 Site Ranked Using the AHRM Reranked after cleanup action occurred at site. Former Staff
1/17/1995 Document, Report, or Work plan Review - other Site summary reviewed. Drums of waste and soil removed and destroyed. Assessment completed around drums. Spill area permanently fenced. ADEC has completed 470 work and requested that future assessment/cleanup efforts be completed by landowners. Based on available data and funding, not enough contamination for State to justify cleanup. One sample result was above the cleanup level. Cindy Thomas
4/26/2006 Update or Other Action ADEC drafted an RFP for a consultant to perform additional site characterization at the site. They propose to install five soil borings within the fenced area and collect soil samples at the surface, at 3 feet bgs, and at 5 feet bgs. In addition, four surface samples from outside the perimeter fence will be collected. These samples will be analyzed for dioxin/furans by EPA Method 8290 and for herbicides by EPA Method 8151A. Deborah Williams
3/7/2007 Exposure Tracking Model Ranking Initial ranking completed. Deborah Williams
4/5/2007 Meeting or Teleconference Held Jim Frechione met with Shannon & Wilson (Mark Lockwood and David McDowell) regarding the remedial options that might be available to us at the Manley Gravel Pit site. ADEC was still interested in the excavation (and transport) of dioxin contaminated soil at first - but they relayed concerns about the transport of hazardous waste from the US to another country. They also provided some information about the Swan Lake treatment facility in Alberta, Canada and wanted ADEC to know about the facility and any issues associated with their operations. In order to explore all remedial options - including transport and disposal off site or treatment on site - ADEC will contact EPA and determine what RCRA issues may be at this site and what options ADEC may have regarding the treatment and management of the dioxin soil - if we determined not to excavate it. ADEC told S&W they should begin to prepare a sample plan to better define the dioxin contaminated areas - based on if we leave the waste material in place. They would have to step out from the last sample areas and define the outer limits of the contamination. ADEC will contact the landowner (Bean Ridge Native Corp) and request comments on the various options. Deborah Williams
7/6/2007 Document, Report, or Work plan Review - other Shannon & Wilson submit 2007 assessment report for the Manley Gravel Pit site. A May 2007 sample event included collection of 17 soil samples from outside the fenced enclosure. The sample results indicated dioxin remains above the 39 ppt action level both inside and outside the fenced enclosure. it was estimated that an area (30 feet x 40 feet) with an average depth about 1.5 foot bgs would contain 55 cubic yards of contaminated soil. Jim Frechione
9/5/2007 Update or Other Action The Manley Tribal Council was contacted (672-3177) regarding a contact for the Bean Ridge Corp. in order to discuss the remedial options at the gravel pit area. Elizabeth Woods identified herself as a contact person that could provide the information to the tribal council. She indicated the council may not meet again for a couple of months. I forwarded her the July 11, 2007 letter that outlined the various options for the site and requested a meeting to discuss them Jim Frechione
9/11/2007 Update or Other Action Dixie Dayo contacted me regarding the Manley Gravel Pit site and I requested a meeting with her and other members of the Bean Ridge Corp to discuss various options to addressing the dioxin contamination at the gravel pit site. She indicated she was busy and would get back to me in a couple of weeks. Jim Frechione
6/18/2008 Update or Other Action DEC letter to Bean Ridge Corp. requesting comments and/or meeting regarding plans to remediate the site. There is a need to conduct an interim remedial measure in order to minimize any exposure risks until the long term solution could be reached. Jim Frechione
7/9/2008 Update or Other Action Dixie Dayo (president of Bean Ridge) contacted DEC to discuss the options for short and long term remediation at the gravel pit site. Dixie requested a letter be sent to Bean Ridge; the Manley Village Council; and Doyon outlining the various options and any proposal to lease the property for the short or long term. she indicated the corporation was not in favor of selling property and - if necessary - preferred to lease it. Points of contact: Dixie Dayo, President, Bean Ridge Corp, PO Box 82062, Fairbanks 99708 Elizabeth Woods, Manley Village Council, PO Box 105, Manley Hot Spings 99756 Norm Phillips, Doyon Ltd, One Doyon Place Suite 300, Fairbanks 99701 Jim Frechione
1/14/2009 Update or Other Action DEC received a letter response from Bean Ridge to Jim Frechione's letter of July 15, 2008. The Corporation would like to contain the contamination, rather than excavate and lease the land to the State. They plan to open the gravel pit for business this summer so the limits of contamination need to be clearly identified and fenced. Ann Farris
5/18/2009 Site Visit Staff conducted a site visit to the gravel pit to evaluate the need for further sampling and the logistics of excavating or capping the dioxins. Soil is needed on the northwest of the existing fenced area. Soil berms on the other sides would have limited the contaminant migration from surface runoff or during the spill. The area is partially in the trees and willows so they will need to cut down in order to effectively cap the soil. The existing fence and signage is in good condition. Photos are on the Fairbanks G:drive. Ann Farris
6/18/2009 Update or Other Action Funding was approved to complete the characterization sampling and update alternatives analysis. Shannon and Wilson will complete a work plan and the sampling with the next month and the alternatives analysis by early August. Hoepfully this will permit a funding request to actually complete the remediation before the end of the summer. Ann Farris
7/1/2009 Update or Other Action Sampling described in 8/17/2009 entry done in accordance with "Work Plan, Dioxin Assessment...July 2009" prepared by S&W for ADEC. Former Staff
8/17/2009 Update or Other Action Staff received dioxin sampling results from Shannon and Wilson’s July sampling event at Manley Hot Springs Gravel Pit. The site is owned by Bean Ridge Native Corporation and was used by ADOT for pesticide drum storage. These results indicated the dioxins may have spread from the drum storage area over a bluff and into the main pit. Since these results could significantly alter the chosen the remedy, CS Staff went back out to Manley to collect samples down the bluff and in the main pit area. Upon arrival at the pit, staff observed 6 to 7 children playing on the bluff and four-wheeling through the pit. They left upon my arrival. Ten soil samples were collected and submitted to Vista Analytical. These samples will be analyzed in phases to try to minimize costs. Preliminary results should be available by Sept. 8th. Ann Farris
8/18/2009 Update or Other Action Vista Analytical Laboratory letter to ADEC with copy of COC in file, acknowledging receipt of samples collected 8/17/2009. Former Staff
9/16/2009 Update or Other Action Final results received 9/14/2009 for samples collected August 17th. Contamination was confirmed over the bluff, but only in one localized area. Results have been forwarded to the consultant to finalize the alternatives analysis which will be used for the request for proposal for cleanup. The landowner will be copied on the results and informed of the situation. Ann Farris
2/17/2010 Update or Other Action Site transfered from Ann Farris to Robert Weimer. Robert Weimer
3/2/2010 Document, Report, or Work plan Review - other December 2009 report documents the July 15, 2009 soil sampling. Nine surface soil samples and one duplicate sample collected. Up to 1,130 pg/g of 2,3,7,8-TCDD (dioxin). Four of the samples exceeded site cleanup levels of 47 pg/g. Robert Weimer
3/2/2010 Document, Report, or Work plan Review - other December 2009 report also documents the August 16, 2009 soil sampling. Four surface soil samples collected. Up to 187 pg/g of 2,3,7,8-TCDD (dioxin). Only one of the samples exceeded site cleanup levels of 47 pg/g. The report recommends removing the down slope contamination, placing it in the top slope contaminated area, covering a 45x45 foot area with a geo-fabric membrane, then covering a 50x50 foot area with clean fill that will be seeded and sloped to promote runoff and minimize errosion. Robert Weimer
8/26/2010 Update or Other Action Alaska Department of Law provided a draft "consent to enrty and agreement to contain" agreement to the property owner Bean Ridge Corporation. The agreement would alow the state to perform excavation, sampling, monitoring, capping and fencing activities. Robert Weimer
10/28/2010 Update or Other Action To date the Alaska Department of Law has not received a response to the a draft "consent to enrty and agreement to contain" agreement to the property owner Bean Ridge Corporation. Robert Weimer
12/28/2010 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71269 Dioxin contamination from drums of herbicide. Robert Weimer
10/12/2011 Update or Other Action DEC letter to Dixie Dayo, President of Bean Ridge Native Corporation (BRNC). BRNC is the property owner of the site. The letter is a follow up to several correspondences between the AGs Office and the BRNC over the past year regarding the DEC's request for permission to perform work at the site to control exposure from known dioxin contaminated soil. The letter included a copy of a "Consent to Entry and Agreement to Contain" document for signature. The letter also mentioned that if DEC is not allowed access to do the site work then BRNC will be requested to do the work at their own expense. BRNC could also be held liable for any health related problems that may occur because they did not allow access or clean up their site. Robert Weimer
10/21/2011 Update or Other Action DEC received signed "Consent to Entry and Agreement to Contain" from Bean Ridge Native Corporation (BRNC). BRNC is the property owner of the site. The agreement gives permission to the state to perform work at the site to control exposure from known dioxin contaminated soil. Robert Weimer
3/12/2012 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71269 Dioxin contamination from drums of herbicide. Robert Weimer
9/13/2012 Cleanup Plan Approved Approved revised 2012 corrective action plan to excavate, cap, and fence remaining contaminated area. The work is to begin the the fall of 2012 and to be finished by early summer 2013. Robert Weimer
5/14/2013 Document, Report, or Work plan Review - other Approved revised 2013 corrective action plan to complete the site work that began in 2012 to excavate, cap, and fence remaining contaminated area. Robert Weimer
5/14/2013 Document, Report, or Work plan Review - other On October 23-24, 2012 ten dioxin analytical soil samples were collected around the perimeter of the area to be excavated, capped and fenced. All of the samples but one (PX-8) met site cleanup levels of 47 pg/g. Sample PX-8, located near the southern edge of the area to be capped and fenced had 201 pg/g. The other samples ranged from <0.0793 to 3.84 pg/g. Once excavation is completed they will take samples from the base of the excavation along with a soil sample to the south of PX-8 to define the extent of the remaining contamination in that area so it can be included with the cap and fenced area. Robert Weimer
8/8/2013 Document, Report, or Work plan Review - other DEC approves August 5, 2013 work plan to complete the excavation and capping of the remaining contaminated soil. Work may start as early as August 18, 2013. Later in 2013 or in 2014 the area is to be fenced, with follow up inspection in 2014 or 2015. Robert Weimer
10/8/2013 Update or Other Action On 10/8/2013 ADEC received "Corrective Action Report, Manley Hot Springs Gravel Pit." Eileen Olson
7/21/2014 Document, Report, or Work plan Review - other Reviewed the "Corrective Action Report, Manley Hot Springs Gravel Pit, October 2013"; other relevant file documents; and communicated with Bean Ridge Corporation representatives to aid in preparation of the Request for Proposal (RFP) dated July 21, 2014 to complete work at the site. Remaining work described in the RFP included securing the site with fencing; posting signs; and placing and vegetating clean fill if needed to stabilize the area surrounding the capped remaining contaminated soil. Eileen Olson
8/13/2014 Update or Other Action Modifications to RFP emailed to successful term contract bidder on this date. Subsequent to initial RFP, ADEC determined that backfill and vegetation (seeding) will not be needed. RFP tasks now include placing chain link fencing and signage. Eileen Olson
8/19/2014 Update or Other Action ADEC received revised cost proposal for modified RFP on August 28, 2014. Eileen Olson
9/4/2014 Update or Other Action Funding approved by Division Director and Notice to Proceed issued to term contractor on this date. Eileen Olson
1/2/2015 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71269 Dioxin contamination from drums of herbicide. Eileen Olson
4/22/2015 Site Visit Site visit to view status of fenced area; determine location of strong magnet corners. Eileen Olson
7/8/2019 Update or Other Action Site location was updated on this date. Coordinates for this site are used to determine the presence and position of the site on BLM’s ANCSA Conveyed Land web map. Rebekah Reams
9/4/2019 Site Visit ADEC visited site on this date. Fence and signage are still intact. Photographs of area were taken. Erin Gleason

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