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Site Report: Tesoro Alaska Refinery

Site Name: Tesoro Alaska Refinery
Address: 54741 Tesoro Road, Mile 21.5 N. Kenai Road, Nikiski, AK 99635
File Number: 2323.38.057
Hazard ID: 312
Status: Active
Staff: Peter Campbell, 9072623412 peter.campbell@alaska.gov
Latitude: 60.684167
Longitude: -151.367222
Horizontal Datum:NAD83

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

Oil contamination of groundwater. Approximately 17,000 cubic yards of contaminated soil was stockpiled on site. All contaminated soil in the stockpile was thermally remediated in 1994. Facility is under The Resource Conservation and Recovery Act (RCRA) Corrective Action and governed by RCRA Permit. Soil and groundwater still contaminated with levels exceeding ADEC & Environmental Protection Agency (EPA) cleanup levels. Trichloroethylene (TCE) contamination is present under a Solid Waste Management unit (SWMU) being regulated under EPA's Hazardous Waste Program regulations.

Action Information

Action Date Action Description DEC Staff
8/9/1974 Notice of Violation ADEC informed Tesoro that they are in violation of the State Waste Discharge Permit 70-2. Former Staff
11/22/1976 Interim Removal Action Approved (Old R:Base Action Code = SC - Site Control (Emergency Response)). Letter informing ADEC of completion of protective fencing and covers over the two oily sludge pits. Two oiled ducks had been found behind the Tesoro refinery in May of 1976. Former Staff
3/13/1987 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). Tesoro informed ADEC's Paul Horwath of benzene concentration in refinery water system detected at up to 340 ppb. Paul Horwath
4/2/1987 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies prepared a Remedial Investigation Work Plan. Former Staff
5/6/1987 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies submitted Remedial Investigation of Well Contamination and Phase II Field Investigation Work Plan. Former Staff
7/20/1987 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies submitted Phase II Field Investigation Report and Phase II Field Investigation Work Plan. Former Staff
8/1/1987 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). Receipt of lab results in August 1987 showing 48 ppb toluene in groundwater at a site next to Tesoro refinery. Party performing sampling unknown. Former Staff
8/3/1987 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). Several reports transmitted to ADEC. A hydrocarbon layer in the groundwater is likely leaking from tanks at Tesoro. Former Staff
1/16/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies submitted Field Investigation Results for the September 6, 1986 Hot Oil Leakage Near Tanks 12 and 23. Former Staff
2/15/1988 Update or Other Action (Old R:Base Action Code = F - Site Treatment, Soil/H2O). Recovery well #1 is removing 15 bbls/day of 100% product. Former Staff
3/1/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Phase IV Field Investigation Report with Appendices Volumes I and II. Former Staff
3/14/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Phase V Remedial Investigation Work Report. Former Staff
3/21/1988 Update or Other Action (Old R:Base Action Code = F - Site Treatment, Soil/H2O). To date, 2,000 to 2,500 ppbls of product have been recovered. Former Staff
3/30/1988 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). EPA "Technical Enforcement Support at the Hazardous Waste Site Report" and a draft review of the "Revised RCRA Closure/Post Closure Plan" for the Tesoro refinery. Former Staff
7/6/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Phase V.1 Wetland Recovery Well Installation and Field Investigation Report, Preliminary Field Investigation Report, and Field Investigation Work Plan Continuation. Former Staff
7/15/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Phase VI Wetland Recovery Well Installation and Phase V.2 Preliminary Field Investigation Report and Field Investigation Work Plan Continuation. Former Staff
8/2/1988 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Remedial Investigation Work Plan. Former Staff
8/2/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Preliminary Phase III Field Investigation Report and Phase IV Field Investigation Work Plan. Former Staff
8/2/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Phase I Remedial Investigation of Well Contamination and Phase II Field Investigation Work Plan. Former Staff
9/15/1988 Interim Removal Action Approved (Old R:Base Action Code = REM - Removal / Excavation). Site visits by ADEC personnel recording jet fuel spill at the lower tank farm, vicinity Tank #40. A liner was laid down and excavation has begun. All pits were backfilled and liners (caps) put in place. Former Staff
9/19/1988 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). KDO visited site. Soils excavated to a depth of 14'. Former Staff
9/21/1988 Update or Other Action (Old R:Base Action Code = F - Site Treatment, Soil/H2O). 5 recovery wells operating. Working on 4 additional wells. Former Staff
9/26/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Report/Remediation Plan regarding the September 14, 1988 JP-4 Fuel Spill near tank 40. About 6,700 gallons of JP-4 were spilled. Cleanup consisted of 500 cubic yards of soil being removed. Soil borings were drilled and floating product discovered, apparently from a different spill. Additional ground excavation is proposed, with a vapor removal system along the northern perimeter of tank #40. Soils proposed to be stockpiled on site and treated. Former Staff
10/28/1988 Interim Removal Action Approved (Old R:Base Action Code = REM - Removal / Excavation). Tesoro excavating soils contaminated by 10/21 spill. Former Staff
11/11/1988 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Sampling Plan, Tesoro Alaska Refinery, November 14 - 18, 1988. Former Staff
11/15/1988 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Site Specific Quality Assurance Project Plan Draft for the Tesoro refinery. Party that drafted plan is unknown. Former Staff
11/17/1988 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Tesoro File Search Final Report, Summary Information submitted by B. Savage. Thirty seven spills recorded. The estimated total spillage is approximately 49,186 gallons (mainly diesel and crude products). Overall recovery was 39%. Former Staff
4/14/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Tesoro Refinery Benzene Problem Report written by ADEC. The report details current remediation steps under way at the refinery. About two feet of product remains above the aquifer at the contamination site. Former Staff
5/16/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Evaluation of the Hydrology and the Impact of Industrial Pumping Wells on the Contaminant Movement at the Tesoro Refinery and Adjacent Properties (dated May 1, 1989), and Evaluation of the Effectiveness of the Wetland Recovery System and Recovery Well E-36 and Workplan for Evaluating the Enhancement of Oil Recovery at the Tesoro Refinery. Former Staff
5/16/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Drinking water survey. Former Staff
5/19/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Field Investigation Workplan. Former Staff
8/11/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Report of Proposed Injection Well Program. Former Staff
8/15/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Conceptual Workplan for Additional Remedial Measures. Former Staff
8/17/1989 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Water sample obtained. No 503.1 parameters detected. Former Staff
8/21/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Preliminary Engineering Information on the Injection Well System. Former Staff
9/29/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Interim Measure #3, Workplan for Delineation of Contaminant Plumes. Former Staff
10/2/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Interim Measure #1, Workplan for Additional Petroleum Product Recovery Wells. Former Staff
10/2/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Interim Measure #2, Workplan for Groundwater Pumping. Former Staff
10/17/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Closure/Post Closure Plan for Surface Impoundments at the Tesoro Refinery. Former Staff
11/2/1989 Notice of Violation Issued by B. Lamoreaux based on findings from an investigation of the refinery on 8/9/89. Requests a report stating corrective measures within 30 days. Bill Lamoreaux
11/3/1989 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Scope of Work: Exploratory Boring/Well Installation on the S.W. Portion of the Phillips Petroleum Company Property. Former Staff
11/6/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Radian Corp., RCRA Facility Investigation, Task #1: Description of Current Conditions. Former Staff
11/7/1989 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Results from sampling of well #4 at the refinery. Former Staff
12/15/1989 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Results from water sample from Tesoro refinery. Former Staff
12/19/1989 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, RCRA Investigation Task III, Initial Assessment of Corrective Measure Tech. Former Staff
1/1/1990 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Project Management Plan RCRA Facility Investigation; RCRA Facility Investigation Work Plan; Health and Safety Plan RCRA Facility Investigation; and Data Collection Quality Assurance Plan/Data Management Plan RCRA Facility Investigation. Former Staff
1/1/1990 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Environmental Strategies, Interim Measure #4 Workplan for Groundwater Flow and Contaminant Transport Models. Former Staff
1/19/1990 Update or Other Action (Old R:Base Action Code = PER - Permit Action at Site). Application for wastewater disposal permit for Tesoro's surface impoundment groundwater remediation system. Former Staff
1/25/1990 Update or Other Action (Old R:Base Action Code = PER - Permit Action at Site). Air permit application. Former Staff
1/29/1990 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Water analyses from Tesoro refinery did not detect any of the parameters tested. Former Staff
3/7/1990 Update or Other Action (Old R:Base Action Code = PER - Permit Action at Site). Application for wastewater disposal permit for groundwater remediation system. Former Staff
3/13/1990 Update or Other Action (Old R:Base Action Code = F - Site Treatment, Soil/H2O). Approval to construct a surface impoundment for the groundwater remediation project given by R. Nicklas. Former Staff
4/1/1990 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Radian Corp., RCRA Groundwater Assessment Monitoring Comprehensive Project Report, Volumes 1, 2 and 3. Former Staff
4/30/1990 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Results of water analyses. No detected contamination. Former Staff
5/1/1990 Site Characterization Workplan Approved (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Final RCRA Facility Investigation Workplan; Interim Measure #4 Workplan for Groundwater Flow and Contaminant Transport Models; Final Data Collection Quality Assurance Plan/Data Management Plan RCRA Facility Investigation; and Addendum to Interim Measure #1 Workplan, Additional Petroleum Product Recovery Wells. Former Staff
6/14/1990 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Environmental Strategies, Interim Measure #3 Delineation of Containment Plumes. Former Staff
9/24/1990 Update or Other Action (Old R:Base Action Code = MS - Monitoring/Sampling). Water sample from Crude Control Tap at Tesoro refinery did not show contamination. Former Staff
10/1/1990 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). Geophysical Investigation Report from EBA Engineering, Inc., reporting possible buried metallic wastes at the Tesoro refinery. Date of report and party contracting study unknown. Former Staff
1/11/1991 Site Ranked Using the AHRM Initial ranking. Former Staff
5/2/1991 Site Number Identifier Changed Old Reckey 19872X0103501. Kenai Special Project code eliminated. Former Staff
3/3/1992 Site Ranked Using the AHRM Site reranked. Former Staff
1/1/1993 Site Added to Database Oil contamination of groundwater. Former Staff
6/9/1993 Site Ranked Using the AHRM Site re-ranked. Population Density Value changed from 8 to 5. Former Staff
10/8/1993 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Review and comment on draft sampling/disposal plan for some of the contaminated soils in the storage cell. Numerous technical assistance calls with consultant ENSR. Former Staff
10/19/1993 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed sampling and disposal plan for oversized material at the Tesoro refinery. Sent letter requesting additional information on 10/23/93 Former Staff
10/20/1993 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). FI of treatment cell cover liner. Former Staff
10/27/1993 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed revised ENSR draft sampling plan for top 12 inches of soil in the Tesoro Refinery contaminated soil containment cell. Sent letter requesting additional information and plan revision on 10/27/93. Former Staff
11/2/1993 Update or Other Action (Old R:Base Action Code = TECH - Technical Assistance). Met with Tesoro staff to discuss remediation plans for contaminated soils in the refinery's contaminated soil containment cell. Former Staff
11/4/1993 Update or Other Action (Old R:Base Action Code = TECH - Technical Assistance). Provided information on State cleanup guidelines, regulations, procedures to EPA/R10 in relation to the Tesoro contaminated soil containment cell cleanup and closeout. Former Staff
11/9/1993 Update or Other Action (Old R:Base Action Code = CORR - Correspondence (General)). Sent letter to Tesoro concerning guidance for regulation and closure of the contaminated soils containment cell at the refinery. The letter and regulation was coordinated with EPA/R10 RCRA permitting staff. Former Staff
11/16/1993 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed data and issued no further action letter for oversized material stockpiled at refinery. Former Staff
11/29/1993 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Review 1993 soil remediation plan; contaminated soils containment area at the Tesoro Refinery. Former Staff
2/16/1994 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed Tesoro Focused Corrective Measures Study and provided EPA/R10 RCRA permitting section comments and local background on contamination. Former Staff
7/1/1994 Update or Other Action (Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed and approved confirmation sampling plan for thermal remediation of contaminated soils in the contaminated soil containment area. Former Staff
8/12/1994 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). Joint inspection with air program to check on progress of thermal treatment of stockpiled soils in the contaminated soil containment cell. Former Staff
10/13/1994 Update or Other Action (Old R:Base Action Code = FI - Field Inspection (General)). Site inspection to check on progress of thermal remediation project and discuss interim report. Former Staff
11/21/1994 Interim Removal Action Approved Review bi-monthly monitoring and progress report. Donald Seagren
1/9/1997 Notice of Violation In a letter dated November 27, 1996 from Tesoro Alaska to Gary Folley of PERP, Tesoro estimated 389,575 gallons of wastewater from their Oily Water Sewer System (OWSS) leaked into the ground in 1996 at their Kenai refinery. The leakage was detected during an annual hydrostatic testing of the OWSS. Tesoro Refinery is under a RCRA permit which was issued to the facility on December 9, 1995 and was jointly signed by EPA and ADEC. The ADEC permit coordinator is Geoff Kany of CSRP. The information in the November 27, 1996 letter is currently being evaluated by Kany and he will make recommendations for possible State enforcement action. The subject letter was also forwarded to EPA. Based upon the subject letter, EPA issued Tesoro a NOV on January 9, 1997 and requested analytical results from Tesoro regarding the OWSS. In a letter dated January 16, 1997, Tesoro provided Folley laboratory analysis for petroleum constituents of a sample collected from the API inlet stream of the OWSS. The report showed that the sample contained various levels of petroleum constituents and levels including benzene at 13.5 mg/l, which would indicate that the sample would be considered hazardous waste as it exhibited the characteristic of toxicity for benzene. The benzene threshold level for the toxicity characteristic leaching procedure (TCLP) is 0.5 mg/l. The sample report was forwarded to EPA. Donald Seagren
1/16/1997 Update or Other Action In a letter dated January 16, 1997, Tesoro provided Folley laboratory analysis for petroleum constituents of a sample collected from the API inlet stream of the OWSS. The report showed that the sample contained various levels of petroleum constituents and levels including benzene at 13.5 mg/l, which would indicate that the sample would be considered hazardous waste as it exhibited the characteristic of toxicity for benzene. The benzene threshold level for the toxicity characteristic leaching procedure (TCLP) is 0.5 mg/l. The sample report was forwarded to EPA. Donald Seagren
8/4/1997 Update or Other Action Coordinated with PERP on reviewing and approving a cold asphalt proposal for utilizing petroleum contaminated soils at the Kenai Refinery. Met with Tesoro representatives to discuss plan requirements. PERP has lead position in review and approval of proposal. Donald Seagren
9/18/1997 Update or Other Action Traveled to Anchorage to meet with Tesoro and EPA Region X to obtain an update on GW plume bluff seepage, site investigation plans, containment effort and changes to RCRA permit. The meeting was followed by a site inspection of the bluff seepage area. Donald Seagren
11/11/1997 Update or Other Action Discuss PIRM report with Jan Palumbo (EPA/Region X) and Tesoro meeting concerning permit modifications. Met with Peter Ribbens and Tim Roy of Tesoro to discuss permit modifications and proposed schedule. Donald Seagren
12/10/1997 Site Characterization Report Approved (Old R:Base Action Code = SA1A - Phase I Site Assessment Approval). Review PIRM Extension Area Characterization Report. Donald Seagren
5/7/1998 Update or Other Action Met with Tim Roy and Peter Ribbens to discuss status of Tesoro Plume and plans for 1998 remedial work. Donald Seagren
5/13/1998 Update or Other Action Responded to questions from Marsha Sisal, A.G., State of Washington, regarding Tesoro operations and regulatory compliance. Donald Seagren
5/29/1998 Update or Other Action Reviewed addendum to Tesoro PIRM Characterization report. Donald Seagren
11/4/1998 Update or Other Action Reviewed and commented on Feasibility Study Workplan, E-150 Lobe Plume Area. Donald Seagren
8/6/1999 Cleanup Plan Approved Reviewed, approved and provided EPA comments on RCRA Corrective Measure Plan E-150 Lobe, E-150 Lobe Plume Injection Pilot Test and Constant Rate Injection and Recovery Test Workplan. Donald Seagren
8/19/1999 Site Characterization Workplan Approved Reviewed E-150 Lobe Plume test Workplan and E-150 ICM plan; provided EPA comments. Donald Seagren
9/20/1999 Update or Other Action Review Quarterly progress Report # 15; Discuss needed data for closure of CSCA with Peter Ribbens. Donald Seagren
10/1/1999 Cleanup Plan Approved Reviewed and approved Supplemental Corrective Measure Implementation Plan / Tank 65 SVE System; Provide EPA/R10 with comments and approval. Donald Seagren
12/1/1999 Update or Other Action Reviewed Quarterly Progress Report #16, RCRA Post-Closure Permit # AKD 04867 9682. Donald Seagren
2/2/2000 Meeting or Teleconference Held Met with Peter Ribbens to discuss CSC data/report submission; termination of COBC; and signing and review of Permit Mod; public meeting on Permit Mod on 14 March 00. Donald Seagren
2/2/2000 Update or Other Action Reviewed UCA/CMIP comments. This report is part of the Permit Mod package undergoing review by the State and EPA/R10. Donald Seagren
2/8/2000 Update or Other Action Reviewed the final year's analytical data for thermal remediation of contaminated soil in former contaminated soil containment area. Met Level A standards. Approved disposal of remediated soils. Issued NFRAP for this site only, not the entire refinery. Donald Seagren
2/24/2000 Update or Other Action Review and provide EPA comments on proposed RCRA permit Mod. Coordinate comments and review with EPA project manager. Donald Seagren
4/25/2000 Update or Other Action Reviewed Injection Pilot Test Report, E-150 Plume Lobe, Tesoro Alaska Refinery, 14 April 00. Donald Seagren
7/31/2000 Update or Other Action Reviewed Biocurtain Pilot Test workplan and provided EPA - RCRA comments. Donald Seagren
8/22/2000 Update or Other Action Reviewed and commented on proposed RCRA Permit Mod request, set up public review file. Donald Seagren
9/11/2000 Update or Other Action Reviewed post-remediation analytical results for thermally treated soil from construction and well drilling activities. Donald Seagren
10/6/2000 Update or Other Action Discussed public comment period on RCRA Permit Mod with Peter Ribbens. Due to a glitch, the Mod has to go out for a further public comment period. Donald Seagren
10/13/2000 Update or Other Action Reviewed and approved request to transport petroleum hydrocarbon contaminated drill cutting from PM/PIRM area to Alaska Soil Recycling in Anchorage for thermal remediation and disposal. Donald Seagren
10/23/2000 Update or Other Action Reviewed post thermal remediation analytical report for petroleum contaminated soils. Donald Seagren
11/20/2000 Update or Other Action Reviewed Tesoro comments to EPA regarding Draft RCRA part B permit; Compare with Permit; Provide EPA R10 comments. Donald Seagren
12/1/2000 Update or Other Action Begin review of ICM Plan B Aquifer Plume Donald Seagren
12/4/2000 Update or Other Action Review Progress Report #20 Donald Seagren
1/17/2001 Update or Other Action Approved wastewater general permit for injection of treated wastewater as part of RCRA corrective action Donald Seagren
1/24/2001 Update or Other Action Combined the Surface Impoundments-Tesoro Refinery site, Reckey 1987230903502, into this site as it is being addressed collectively under this site. Donald Seagren
4/10/2001 Update or Other Action Review RCRA Permit Mod Donald Seagren
6/12/2001 Update or Other Action Review Quarterly Progress Report #22 Donald Seagren
6/13/2001 Update or Other Action Review 15 Day Release Report - Reformer Sewer Cup Release Donald Seagren
8/20/2001 Update or Other Action Reviewed Monthly Monitoring Report - B-Aquifer System, General Permit # 9640-DB001 Donald Seagren
9/5/2001 Update or Other Action Reviewed Quarterly Progress Report #23. E-mail to Jan Palumbo, EPA/R10 concerning the Department's non-objection to the proposed changes to the UCA monitoring program in Permit Attachment KK. Donald Seagren
9/20/2001 Update or Other Action Reviewed and approved the Groundwater Metals Assessment Work Plan dated 17 September 01. Donald Seagren
10/4/2001 Update or Other Action Reviewed 15 day report on 2000hp Pump Release. Donald Seagren
10/15/2001 Update or Other Action Reviewed Monthly Monitoring Report B-Aquifer(Calgon) System Donald Seagren
11/26/2001 Update or Other Action Reviewed Monthly Monitoring Report B-Aquifer (Calgon) System. Sent e-mail to Frechione regarding how to deal with expiring general non-domestic wastewater disposal permits. Donald Seagren
11/26/2001 Update or Other Action After discussing Non-domestic wastewater permit issues with Oren Wolley (EH), contacted Robert Napier. Requested permit renewal request to be re-sent, since original has been lost. Also said that general permit was being re-written and would be re-issued for Tesoro. they could continue operating under current permit until the new one was issued. Donald Seagren
12/6/2001 Update or Other Action Reviewed Quarterly Progress Report #24. Donald Seagren
1/2/2002 Update or Other Action Sent revised General wastewater disposal permit # 0240-DB002 to Tesoro. Revised permit replaces expired general wastewater disposal permit #9640-DB001 Donald Seagren
1/23/2002 Update or Other Action Reviewed Monthly Monitoring Report B-Aquifer (Calgon) System. Donald Seagren
3/4/2002 Update or Other Action Reviewed Quarterly Progress Report #25. Donald Seagren
6/25/2002 Update or Other Action Reviewed quarterly progress report #26 Donald Seagren
12/2/2002 Update or Other Action Review Quarterly Progress Report #28. Discuss LTF soil vapor extraction proposed work with Peter Ribbens. Donald Seagren
2/27/2003 Update or Other Action Reviewed Quarterly Progress Report #29. Donald Seagren
5/22/2003 Update or Other Action Reviewed R-23 Recovered Groundwater Release 15-Day Report, dated 14 May 03. No PERP involvement required. Donald Seagren
6/2/2003 Update or Other Action Reviewed RCRA Quarterly Progress Report #30. Donald Seagren
8/19/2003 Update or Other Action Completed review of Request for Permit Modification RCRA Post Closure Permit No. AKD 04867 9682, dated 8 August 03. Donald Seagren
10/22/2003 Cleanup Plan Approved Approved 70 cubic yards of petroleum contaminated soils from various historic spills & other projects, to be transported to ASR - Anchorage for thermal remediation. Donald Seagren
11/19/2003 Update or Other Action Reviewed RCRA Quarterly Progress Report#32. Donald Seagren
5/6/2004 Update or Other Action File number assigned and entered into the Fileroom DB and CS DB. Alyce Hughey
6/18/2004 Update or Other Action Reviewed RCRA Progress Report #34. Remediation and monitoring on-going. Plume appears to be stabilizing. LNAPL areas limited to a few areas rather than over the entire contaminant plume area. Donald Seagren
8/10/2004 Update or Other Action Reviewed B-Aquifer, PM and SI monitoring reports. No anomalies. Requested copies of No-purge GW Sampling Evaluation and Plan and GW Metals Assessment Report. Only received cover letter. Donald Seagren
8/11/2004 Update or Other Action Reviewed GW Metals Assessment Report and No-Purge GW Sampling Evaluation and Plan. Both done in support of RCRA permit modification application. Donald Seagren
8/24/2004 Update or Other Action Telephone call with Tesoro, Kent & Sullivan & EPA/R10 to address ADEC water program non-issuance of non-domestic WW discharge permits. Tesoro will develop corrective action plan following 18 AAC 75 to address GW treatment systems discharges. Donald Seagren
8/25/2004 Update or Other Action Reviewed analytical data and request for landspreading 10 cubic yards of sandblast sands on the KPL facility. One sample exceeded Table B for DRO. Request approved. Confirmation sampling will be required in the future to ensure remediation is complete. Donald Seagren
10/8/2004 Update or Other Action Approved Treated GW Injection Plan. This plan is for all 3 treatment systems. It replaces the former non-domestic WW discharge permits, which the WW program said they will not be reissuing. Donald Seagren
10/20/2004 Update or Other Action Approved transport of approximately 5 tons of petroleum contaminated soil to ASR Anchorage for thermal remediation. Donald Seagren
11/16/2004 Update or Other Action Reviewed post treatment analytical report for soil from ASR. Soil meets Table B cleanup standards and will be utilized in the construction industry. Donald Seagren
11/18/2004 Update or Other Action Reviewed Quarterly Progress Report #36. No significant changes in impacts to human health and the environment have been identified. The corrective measures are performing satisfactorily and meet the requirements of the RCAR Post-Closure Permit. Donald Seagren
11/19/2004 Update or Other Action Reviewed treated GW injection permit monitoring report. Due to a mix up during change over from WW discharge permit to CS corrective action plan approval, analysis was conducted for WW permit parameters. this will be corrected for future quarterly sampling events. Donald Seagren
2/28/2005 Update or Other Action Reviewed Quarterly Progress Report # 37. No significant changes to risk to human health or the environment. Donald Seagren
5/3/2005 Update or Other Action Tesoro submits request to EPA for Permit reapplication submittal extensions request. Tesoro will more fully evaluate replacing the SI groundwater treatment system with an air sparing system. Donald Seagren
6/2/2005 Update or Other Action Reviewed 15-day fire release report, shared information with PERP staff. Donald Seagren
6/7/2005 Update or Other Action Reviewed In-Situ Chemical Oxidation Pilot Test Work Plan. No comments. Approval to proceed. Donald Seagren
6/16/2005 Update or Other Action Reviewed report #38. No significant change to risk to human health or the environment. Reviewed and approved air the addition of air sparging system to the SI remediation plan. Donald Seagren
9/2/2005 Update or Other Action Reviewed Quarterly Progress Report #39. No significant changes in impacts to human health and the environment have been identified since the last progress report. Update on the In-Situ Chemical Oxidation Pilot Test Work Plan will be presented in Quarterly Progress Report #40. Tesoro plans to begin constructing a pipeline next quarter for routing water from the Wharf collection system to the B-aquifer injection system as an additional water source. The water meets drinking water standards and will help improve the performance of the PIRM and BUA corrective measures. Donald Seagren
10/11/2005 GIS Position Updated Using Figure 1 from a Quarterly Progress Report No. 39, from Tesoro Alaska Company, dated August 31, 2005, in conjunction with TopoZone Pro and the KPB Parcel Lookup, entered the coordinates for this site. Metadata includes No Topo Basemap, TopoZone Pro Street Maps, Black and White Aerial Photo, on a Medium Size Map, View Scale 1:24,000, Coordinate Datum NAD83. High degree of confidence in accuracy of location. Alyce Hughey
12/2/2005 Update or Other Action Reviewed RCRA Quarterly Progress Reports #40. The GW treatment/monitoring system continues to be evaluated to improve the process. With minor exceptions that are being corrected and evaluated further, the groundwater contaminant concentrations are within or below the historical values. Migration pathways are similar to historical directions. No significant changes to impacts to human health and the environment have been identified. The corrective measures are performing satisfactorily and meet the requirements of the Permit. Tesoro will be submitting a RCRA Part B Permit renewal application on or before 9 December 05. Donald Seagren
12/19/2005 Update or Other Action Reviewed the Oily Water Sewer System Leak discoveries 15-Day Release Report. During leak testing of the OWSS three of the ten components failed. The maximum period of non-compliance is approximately 2 years, since the last leak testing in 2003. Intermediate measures have been taken to isolate the leak areas. OW fluids have been rerouted around the leaks until full repairs can be made. Some repairs, such as to the corroded pipe have been completed. Repairs to the OWSS hubs will be completed in 06, with re-coating the hubs. Donald Seagren
12/22/2005 Update or Other Action Reviewed GW metals assessment report. This GW metals assessmet evaluates the potential for Tesoro Refinery to have released one or more metals to GW. Background GW concentrations of 17 metals were compared with concentrations in source area GW using non-parametric statistical models to determine if metal concentrations in source areas are significantly greater than background levels. The report recommended that arsenic and lead be listed as chemicals of potential concern because both are present in source area GW at concentrations that routinely exceed 1/10th the drinking water criteria. In addition, arsenic concentrations are elevated relative to background in part of the PM plume. No other metals are recommended as COPCs based on the absence of observed GW impacts. No metals are recommended for listing as COCs. Donald Seagren
1/12/2006 Update or Other Action Tesoro has requested temporary authorization under 40 CFR 270.42(e)(2)(i)(A) for a Class 2 modification that meets temporary authorization criteria under paragraphs 40 CFR 270.42(e)(3)(i) from U.S. EPA. Tesoro proposes to bypass the SI groundwater tray stripper and re-inject recovered SI groundwater directly to the unconfined aquifer because groundwater contaminant concentrations at the inlet to the SI tray stripper are well below the Target Groundwater Protection Standards. Groundwater will continue to be pumped to ensure that hydraulic control of the SI plume is maintained and contaminated groundwater flows through the new air sparge system. This request is currently under review. Donald Seagren
1/26/2006 Update or Other Action Telehone call from Peter Ribbens. Discussed changing quarterly reporting dates for groundwater discharge. Change of dates approved. Donald Seagren
2/28/2006 Update or Other Action Reviewed quarterly progress report #41. In the SI sytem a supplemental air sparge system has been installed. Contaminant concentrations downgradient of the AS system have shown decreases. Several MWs were not sampled this quarter due to freezing or othe damage. They will be repaired prior to sampling in the next quarter. Contaminant concentrations are generally within or below the range of historical values. Migration pathways are similar to historical directions. No significant changes in impacts to human health and the environment have been identified. Tesoro plans on requesting a natural attenuation corrective action in the wharf area. They are compiling existing data that demonstrates natural attenuation processes are currently active in the plume and are able to prevent unacceptable risk to human health and the environment. Donald Seagren
3/10/2006 Update or Other Action Reviewed Re-evaluation of Pipeline Valve Control Box Solid Waste Management Unit report. Tesoro is requesting removal of this Solid Waste Management Unit (SWMU) during the on-going permit mod. ADEC has no objection to removing this as a SWMU. This area of the refinery is not listed as a separate site. Soil & GW contamination exists under and around the valve box exceeding ADEC cleanup levels. Tesoro has demonstrated that most likely, a major release has not occured at this location. The contamination at this site is probably a mix of numerous small releases from the valve box and a larger upgradient release migrating on site. EPA will be consulted prior to providing a written response to Tesoro on their request. Donald Seagren
9/14/2006 Update or Other Action Reviewed Quarterly Progress Report 43. No significant changes in impacts to human health and the environment. 15 new air sparging wells were installed in the PIRM system area. The 15 AS wells are intended to form a north - south air sparge treatment zone ~225' long perdendicular to the groundwater flow direction immediately upgradient of the E-150 hydraulic barrier. Installation of the piping runs, blower system and testing of the system will be done next quarter. A start up plan will be submitted to EPA and upon their approval, begin operating the system and monitoring. Donald Seagren
10/25/2006 Update or Other Action Approved transposrt of approximately 100 tons of petroleum contaminated soil obtained from routins maintenance excavation encountering historic spill and 2006 refinery releases cleanup actions to ASR in Anchorage for thermal remediation and disposal. Paul Horwath
2/13/2007 Exposure Tracking Model Ranking Donald Seagren
3/6/2007 Update or Other Action Tesoro Alaska Company Final Resource Conservation and Recovery Act Permit Renewal , EPA ID#: AKD 04867 9682: EPA approved and renewed the Permit effective 1 April 07 Donald Seagren
3/6/2007 Update or Other Action Reviewed RCRA progress report 45. In general contamiant concentrations are within or below the range of historical values. No significant change to the risk to human health and the environment. Normal winter operations problems are being addressed as they occur. Longer term evaluations and system improvements are being planned for after breakup. In the PM area well E122 continues to be erratic. It is unsure if the fluctuating benzene concentrations (ND - 980 ug/l over the past 2 years) reflects actual changes in the plume conditions or are an artifact of the no-purge sampling. No-purge sampling will be discontinued at this well for the next several quarters to assess this concern further. Donald Seagren
3/6/2007 Exposure Tracking Model Ranking Donald Seagren
7/10/2007 Update or Other Action Reviewed 15 Day Release Report for a release from a seal box in the OWSS (Reformer seal Box 1). The leak was possibly a result of the spray on liner material failing. A steel liner will be placed in the seal box. The box in in the refinery where excavation of contaminated soil is difficult due to refinery infrastructure. Contaminated soil & GW will be addressed by the RCRA Corrective action plan and the facility RCRA permit. Donald Seagren
7/10/2007 Update or Other Action Reviewed RCRA progress report #46. No significant changes to risk to human health or the environment. Report demonstrates that progress is being made and that the remediation systems are performing adequately. Problems encounterd during this quarter are those normaly encountered in the switch from winter to summer, i.e. inability to sample due to frozen wells. Donald Seagren
12/6/2007 Update or Other Action Reviewed RCRA Quarterly Progress Report # 48. Progress continues on controlling and cleaning up the contaminated GW plumes. Tesoro is proposing a Monitored Natural Attenuation plan for the Wharf Lobe. LNAPL accumulations and dissolved phase hydrocarbon concentrations in the Wharf Lobe have attenuated rapidly compared to other parts of the plume. This has occurred independently of the recovery system, which is a passive collection system at the downgradient edge of the plume lobe. Tesoro proposes to turn off the Wharf Lobe GW recovery system and rely on the ongoing nautral attenuation processes to continue to control the contaminant levels. GW now captured in the recovery system will be allowed to migrate beneath and around the sheet pile wall and discharge into Cook Inlet. The recovery system and sheet pile wall will be maintained so that it can be turned on if needed. Tha apparent reason for the enhanced natural attenuation in this area is due to the complex GW flow patterns created by the south fault and relief on the 60-foot clay and main aquitards result in commingling of the Wharf hydrocarbon plume with a nitrate, sulfate and ammonia plume emanating from the Agrium fertilizer plant. It is assumed that denitrification and sulfate reduction are the primary biodegradation processes in the Wharf Lobe. Donald Seagren
6/11/2008 Update or Other Action Site transferred from Don Seagren to Paul Horwath per Linda Nuechterlein. Alyce Hughey
9/29/2009 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 54, dated June 15, 2009, from Kent and Sullivan for Paul Horwath. The site conditions are remaining stable. The SI Area had no significant changes. The groundwater procedures will be reviewed in this area to assure that the dissolved oxygen measurements are obtained and a repair of the damaged air sparge well located up-gradient of well SMW-21A will occur during quarter 55. The flow paths through the PM Area are well within the air sparge capture zone. In order to help reduce the Benzene concentrations in well E-122 the replacement of recovery well R-21 with a line of air sparge wells will occur once receiving approval from EPA. The Benzene concentrations did reduce significantly in this quarter in the northern part of the Lower Tank Farm. No significant changes were noted in the PIRM Area. The Wharf Area meets the closure requirement for the first round of sampling per the Permit condition III.F. During quarters 55, 56, and 57 indicator parameter analyses will be performed on all wells and in quarter 58 contaminants of concern analyses will be performed on all wells located in the Wharf Area. In the B Aquifer, the B Unconfined Aquifer Corrective Action Modification Plan has effectively cut off Benzene migration beyond the B Unconfined Aquifer injection system. A small residual plume remains along the bluff area and it is expected to continue decreasing in size as clean injection water migrates into the area. Also within the B Aquifer monitoring well E-179 to the south of the refinery has had quite an increase in Benzene concentrations. Additional sampling in this area is planned to further evaluate the groundwater conditions in this area. Monitoring wells E-163 and E-187B are not being captured by the recovery system. The 2008 B Unconfined Aquifer Corrective Action Modification Plan is being implemented to meet the requirements. None of the beach seep samples have contained detectable Benzene that suggests that the B Aquifer is reaching the Cook Inlet: therefore, beach samples will now be collected quarterly. The Upper Confined Aquifer monitoring well E-198 had the highest Benzene concentrations historically. The cause is not known and due to the increase the E-198 Corrective Action Modification Plan will be implemented quarter 55. Alyce Hughey
1/8/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 55, May, June, and July 2009, dated August 31, 2009, from Kent & Sullivan for Paul Horwath. The site conditions are remaining stable. The SI Area groundwater samples are remaining stable. On July 1, 2009 RS-2 located in the SI Area was shut down due to iron buildup that had significantly reduced the wells pumping rate. The 2009 SI Corrective Action Modification and Monitored Natural Attenuation Validation Plan is planned to be implemented where RS-2 will be turned off and substitute the on-going natural attenuation process for groundwater pumping. The PM Area groundwater samples are remaining stable other than E-179 has shown an increase in Benzene concentrations. A supplemental sample was taken from E-77 to update the current conditions in that area and data shows that concentrations have decreased. Also, the work to install supplemental monitoring and air sparge wells in the R-21 Area has begun. A report will be submitted once the work has been completed. The PIRM Area groundwater samples are remaining consistent with previous sampling events. The 2009 PIRM Air Sparge Transition Plan is planned on being implemented once EPA approval is obtained. The Wharf Area meets the closure requirement for the second round of sampling during this quarter. Sampling will continue Quarters 56, 57, and 58. The B Aquifer groundwater concentrations are remaining stable other than an increase in Benzene in E-205, and Benzene was detected in the Beach Seep sample collected in May of 2009. The increase in Benzene in E-205 is believed to be caused by changes in the recovery well pumping rates. The Beach Seep sample collected in May is believed to be related to summer beach traffic because the sample taken in July didn’t contain detectable concentrations. Monthly Beach Seep samples are planned until winter freeze up. The Upper Confined Aquifer groundwater samples are consistent with Quarter 54 concentrations. E-198 still has a high Benzene concentration. With the implementation of the E198 Upper Confined Aquifer Corrective Measure the reason for the increase in Benzene concentrations will be determined. Alyce Hughey
1/27/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 56, August, September, and October 2009, dated November 30, 2009, from Kent & Sullivan for Paul Horwath. The site conditions are remaining stable. Approval for the 2009 SI Corrective Action Modification Plan and Monitored Natural Attenuation Validation Plan was obtained by EPA and implementing of the plan has begun with the injection lines and other hardware were installed and the gauging and monitoring of proposed wells has begun. Data showed that a localized LNAPL is present in SMW-33. The overall SI corrective measure is performing satisfactorily other than TCE concentrations in well SMW-I-1. No CAMP is being proposed at this time. The installation of supplemental monitoring and air sparge wells in the R-21 Area were completed. Monitoring wells E-234A&B, E-235A&B, E-236 and air sparge wells HAS-01 through HAS-17 were installed. The data presented from the new wells shows that the A-Aquifer plume extends approximately 80 feet further north than previously estimated, and consists mostly of Benzene. The 2009 PIRM Air Sparge Transition Plan data shows that wells E-143 and E-144 are to be watched and monitored. They have shown some increases, and the possible need of vapor extraction systems in conjunction with air sparge systems may need to be used. The Wharf area meets the Wharf area closure requirements for the third round of sampling. Sampling will continue quarters 57 and 58 to meet the closure requirements. The beach seep samples collected in September and October were all undetected. Beach seep samples will be collected after spring thaw and if Benzene is not present, the beach seep samples will be discontinued. The B-Aquifer is stable and the 2008 BUA CAMP is being implemented to meet the BUA corrective measure requirements. The Upper Confined Aquifer shows no significant changes. The E-198 CAMP data indicates that the unconfined conditions in the UCA pocket covers a relative large area. Supplemental samples were taken and data indicated that well E-127 may be affected from the E-198 plume. Another sample will be taken from E-127 to confirm the results. Alyce Hughey
2/3/2010 Document, Report, or Work plan Review - other Reviewed the Groundwater Injection Permit Quarterly Report, dated January 15, 2010 for Paul Horwath. The Surface Impoundment Unit pump and treat remediation system is no longer operating in this area. The Phillips-Marathon Unit is operating within normal limits, and the Calgon Unit exceeded the monthly effluent limits for Benzene for the months of October, November and December of 2009. Tesoro plans on replacing the carbon in the Calgon Unit in February. Alyce Hughey
3/2/2010 Document, Report, or Work plan Review - other Reviewed the 2009 PIRM Air Sparge Media Transfer Evaluation report, dated February 4, 2009, from Kent and Sullivan for Paul Horwath. The findings of the 2009 PIRM Air Sparge Media Transfer Evaluation indicates that the PIRM Air Sparge system currently transfers less than 3.5 percent of the benzene that enters the sparge treatment zone to the atmosphere, which are orders of magnitude below the outdoor air Regional Screening Level for industrial workers. The effect on mass transfer to the atmosphere that will be caused by stopping the PIRM groundwater pumping is not known. Monitoring will be performed to see if the current Air Sparge system provides adequate control of the groundwater plume, and if the testing indicates that the current Air Sparge system does not provide adequate control of the groundwater plume, additional air sparge wells will be installed and other changes will be implemented as needed to achieve adequate control of the groundwater plume. In the event that benzene transfer to the atmosphere exceeds 20 percent of the estimated benzene flux into the sparge treatment zone, a soil vapor extraction system will be installed. Alyce Hughey
4/15/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 57, dated February 26, 2010, from Kent & Sullivan for Paul Horwath. The site conditions are remaining stable. The approved 2009 SI Corrective Action Modification Plan and Monitored Natural Attenuation Validation Plan was placed on hold until after spring thaw. The SI sampled wells contained contaminant concentrations within or below the range of historical values, except for well SMW-32 contained 5.4 ug/L benzene. Tesoro plans on reviewing the performance of SAS-11 and SAS-13 after spring break up and take corrective actions to repair the wells if need be. Well SMW-I-1 continues to show TCE concentration above the groundwater cleanup levels. No corrective action measures has been proposed at this time, however, the in-situ chemical oxidation of the TCE using potassium permanganate is being considered in 2010. No significant changes were observed in the PM Area that impacts human health and the environment, with the review of evaluation options for replacing the pump-and-treat system in the R-21 area. The PIRM Area data showed that Monitoring well B-1 detected 8,300 ug/L benzene. Well E-144 contained 91 ug/L for benzene, which is an increase in historical values possibly due to the decrease in pumping rates in the area. The sample results in the Wharf Area were non-detected in five of the samples and the other two had detections, but were below the closure requirements per the Permit condition III.F, with the Wharf Area meeting the closure requirements for the fourth round of sampling. Beach seep samples were not collected during this quarter. Beach seep samples will be conducted after spring thaw, and if benzene is not detected the beach seep samples will be discontinued. The data to date indicates that the 2008 BUA CAMP corrective measure shows that the plume has been completely captured and a continual decreasing trend in concentrations. The Upper Confined Aquifer shows no significant changes. The sample taken from E-127 this sampling event did not detect benzene, indicating that the arrival of the benzene plume may not be apparent in this well from the E-198 plume. Alyce Hughey
8/6/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 58, dated June 15, 2010, from Kent & Sullvan for Paul Horwath. The Surface Impoundment (SI) area TCE plume continues to remain centered in the area of well SMW-I-1. The implementation of the SI 2010 TCE CAMP will be performed to address this concern. The SI 2010 TCE CAMP will consist of the drilling of one injection well and one monitoring well with potassium permanganate injections for 60 consecutive days. The benzene plume in the SI area has migrated past the AS system, and a performance review is planned and repairs performed as needed. The Phillips-Marathon (PM) area showed an increase in benzene within well E-122. The PM 2010 Highway AS/SVE Interim Measure Plan is proposed to replace the groundwater extraction in the area of recovery well R-21. The plan will increase the treatment area in an effort to reduce the benzene plume migration. The Phillips interim remedial measure (PIRM) area showed similar results to previous quarter samplings other than the southern supplemental samples taken showed an increase in benzene concentrations. The new air sparge wells included in the PIRM AS/SVE Pilot Test Plan will extend the capture zone further south to address the concern for the increase in benzene concentrations. The work will include installing a soil vapor extraction system, expanding the air sparge well network, installing two groundwater monitoring wells, and conducting a pilot test to ensure its effectiveness. The Wharf area successfully completed the closure demonstration period and the Wharf 2010 Standby Plan will be implemented to ensure that the corrective measures can be immediately resumed in case the need for additional remediation and demonstrate the adequacy of the groundwater remediation. The B-Aquifer plume is completely captured with only a small area of elevated benzene concentrations remaining beyond the injection system, and only a small residual plume remains along the bluff. The Upper Confined Aquifer data shows that it is performing satisfactorily other than the benzene concentrations in well E-198 have shown an increasing trend and the E-198 Corrective Action Modification Plan is being implemented to address this concern. Alyce Hughey
8/10/2010 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report for January, February, March of 2010, dated April 15, 2010 from Tesoro Alaska Company for Paul Horwath. The Surface Impoundment Unit is no longer in operation, the Phillips-Marathon Unit was operating within normal limits, and the Calgon Unit exceeded the discharge limits for this reporting period. Corrective actions performed was Tesoro replaced the carbon in March. Alyce Hughey
8/10/2010 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report, dated July 15, 2010, from Tesoro Alaska Company for Paul Horwath. For quarters April, May, and June of 2010 the Surface Impoundment Unit is no longer operating, the Phillips-Marathon Unit was operating within normal limits, and the Calgon Unit was operating within normal limits. Alyce Hughey
10/1/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 59, dated August 31, 2010, from Kent and Sullivan for Paul Horwath. The SI area continues to show TCE concentrations above the groundwater cleanup levels within well SMW-I-1. One injection well and one monitoring well was installed in this area of the TCE plume to perform potassium permanganate injections. Air sparge wells SAS-11 and SAS-13 were also redeveloped this quarter to re-establish adequate air flow. The PM area showed similar contaminant concentrations this quarter. Six soil vapor extraction wells and three vapor monitoring points in the area of R-21 were installed to replace the groundwater extraction in this area to help reduce the benzene plume migration. In the PIRM area within well E-143 continues to show an increase in benzene concentrations. Two monitoring wells, one soil vapor extraction well and five air sparge wells were installed to increase the capture zone to better address the benzene concentrations in well E-143. The Wharf area met the Wharf 2010 Standby Performance Standards with the sample taken not detecting any of the analytes tested for. The B-Aquifer continues to show decreasing concentrations after the implementation of the 2008 BUA Camp, and in the Upper Confined Aquifer well E-198 is showing decrease benzene concentrations since quarter 54 after implementing the CAMP for UCA Well E-198. Alyce Hughey
12/8/2010 Document, Report, or Work plan Review - other Reviewed the Groundwater Injection Permit Quarterly Report, dated October 8, 2010 for Paul Horwath. The Surface Impoundment Unit pump and treat remediation system is no longer operating in this area. The Phillips-Marathon Unit and the Calgon Unit is operating within normal limits. Alyce Hughey
12/29/2010 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 60, dated November 2010, from Kent & Sullivan. The SI area continues to show TCE concentrations above the groundwater cleanup levels within well SMW-I-1; with a continual decrease in concentrations being seen. The injection of potassium permanganate into well IW-5 began on August 31, 2010 to help reduce the TCE concentrations within well SMW-I-1. Tesoro began implementing the PM 2010 Highway AS/SVE Interim Measure Plan after installing six Soil Vapor Extraction wells and three Vapor Monitoring points in the R-21 area. The PIRM area well E-187A detected benzene for the first time, and the well will be sampled next quarter to confirm the benzene concentrations. On September 20, 2010 Tesoro began implementing the Revised PIRM 2010 AS/SVE Pilot Test by starting the five new AS wells (PAS-16 through PAS-20). Water injection wells I-4 and I-5 were stopped at the same time. The AS system was reprogrammed to account for the new AS wells and the changes in water levels resulting from stopping the water injection in wells I-4 and I-5 were accounted for. The SVE system was started and after testing and monitoring the SVE blower capacity was found to not be large enough to capture the sparge air. The pilot test was stopped until a larger blower is obtained and installed. The Wharf area continues to meet the Wharf 2010 Standby Performance Standards. The B-Aquifer continues to show decreasing concentrations after the implementation of the 2008 BUA Camp, and in the Upper Confined Aquifer well E-198 is showing decrease benzene concentrations since implementing the CAMP for UCA Well E-198. Also, monitoring well E-145 tested below the target groundwater protection standard for the first time. Alyce Hughey
3/15/2011 Document, Report, or Work plan Review - other Reviewed the Groundwater Injection Permit Quarterly Report, dated January 13, 2011 for Paul Horwath. No anomalies were found during the October, November, and December groundwater remediation systems within the Phillips-Marathon Unit and the Calgon Unit, they were operating within normal limits. The Surface Impoundment Unit pump and treat remediation system is no longer in operation. Alyce Hughey
4/19/2011 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report #61, dated February 28, 2011, from Kent & Sullivan. The potassium permanganate injections in the SI area were completed in November of 2010. The findings concluded that the solution preparation and injection system functions well and could be used in future In-Situ Chemical Oxidation projects at the Tesoro Refinery; however, the potassium permanganate injection did not reduce the TCE concentration in the down-gradient well SMW-34 and an increase in benzene concentration did occur. Tesoro began implementing the PM 2010 Highway AS/SVE Interim Measure Plan, and after receiving EPA approval they are planning on finishing installing the AS/SVE systems and begin the operation of the treatment systems. The PIRM area well E-143 contained an anomalously high benzene concentration 22 ug/L, and well E-187A contained 15 ug/L benzene, subsequently additional samples were taken and well PI-2 contained elevated benzene levels of 36.5 ug/L. The air sparge system was adjusted and follow-up sampling showed that benzene was non-detect within well PI-2 within two weeks. The SVE blower within the PIRM 2010 AS/SVE Pilot test was found to not be large enough last quarter; therefore, a larger blower was purchased and installed in January of 2011. The system is remaining in operation pending the analysis of the influent and effluent samples collected from January 17 to February 1. Recovery wells R-47 and R-48 accumulated a large amount of LNAPL; therefore, in January of 2011 the recovery of the LNAPL was started using a portable pump system. The Wharf area continues to meet the Wharf 2010 Standby Performance Standards. The B-Aquifer continues to show decreasing concentrations after the implementation of the 2008 BUA Camp, and in the Upper Confined Aquifer well E-198 is showing decrease benzene concentrations since implementing the CAMP for UCA Well E-198. Alyce Hughey
5/13/2011 Document, Report, or Work plan Review - other Reviewed the Groundwater Injection Permit Quarterly Report, dated April 15, 2011 and April 20, 2011 for Paul Horwath. The Surface Impoundment Unit pump and treat remediation system is no longer operating in this area. The Phillips-Marathon Unit and the Calgon Unit is operating within normal limits. Alyce Hughey
7/20/2011 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report, dated July 11, 2011, from Tesoro Alaska Company. The Phillips-Marathon Unit and the Calgon Unit operated within normal limits for April, May, and June of 2011. The Surface Impoundment Unit pump-and-treat remediation system is no longer in operation. Alyce Hughey
8/10/2011 Update or Other Action Received notification that the Environmental Protection Agency has approved the Final PM 2011 Highway Area AS/SVE System Installation and Operation Work Plan - Phase 1 (Work Plan) dated July 26, 2011. Alyce Hughey
1/18/2012 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report, dated January 16, 2012, from Tesoro Alaska Company. The Phillips-Marathon Unit and the Calgon Unit operated within normal limits for October, November, and December of 2011. The Surface Impoundment Unit pump-and-treat remediation system is no longer in operation. Alyce Hughey
1/24/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report Number 62, dated June 15, 2011, from Kent & Sullivan for Paul Horwath. The Potassium Permanganate In-Situ Chemical Oxidation Treatment conducted in the SI Area was evaluated and the injection well IWS-5 did not detect BTEX or TCE and the purple potassium permanganate was still present within the well. TCE concentrations was found in well SMW-11 at concentrations of 30 ug/L, where in quarter 40 it had 3.6 ug/L and quarter 18 had 1.7 ug/L. TCE was also found in well SMW-34 with concentrations during quarter 61 at 13 ug/L, 18.5 ug/L, 14.9 ug/L, 18.1 ug/L and 27 ug/L respectively, where in quarter 62 it had 31 ug/L. The increase may be due to the plume expanding during the potassium injection. Monitoring well SMW I-1 is showing a decrease in TCE from quarter 61 at 54 ug/L, to quarter 62 at 40 ug/L. The PM Area contaminant concentrations are within or below the range of historical values. The corrective measures are performing satisfactorily and it meets the performance requirements of the permit. The treated water equilibration lagoon was cleaned out in February to remove accumulated iron precipitates, and the pond was put back into service on February 25, 2011. The PIRM AS/SVE System was started up during quarter 62. Samples collected from E-187A located on the western side of the hydraulic barrier, and well PI-2 located just up-gradient of the hydraulic barrier contained elevated benzene levels. Immediate steps were taken to adjust the air sparge systems. The adjustments took almost immediate effect and benzene levels were almost non-detect in well PI-2 within two weeks, however, the elevated benzene in well E-187A, down-gradient of the Air Sparge system has not been totally resolved and additional supplemental samples will be collected to confirm adequate plume control. Monitoring well E-91 detected benzene for the last two quarters, where it has not been detected before. A supplemental sample will be collected in quarter 63 to confirm the presence of benzene, and if confirmed, Tesoro will investigate the source. One sample was taken from the WHARF Area, and the groundwater quality meets the Wharf 2010 Standby Performance Standards. With the implementation of the 2008 BUA Camp the plume is continuing to show decreasing benzene concentrations. For the first time since the implementation of the 2008 BUA Camp the elevated levels of benzene that were in the wells beyond the BUA injection system are no longer present. The Upper Confined Aquifer groundwater flow direction is not consistent with previous quarters because the plant supply well TW-2A was not operating at the time of gauging. A new supply well was installed in the lower aquifer and will be operating as a water supply well. With this groundwater flow direction change, the plume has also shown an expansion toward well E-127. This is the first time since quarter 26 that well E-127 contained detectable benzene. This well is planned to be sampled next quarter to confirm the presence of benzene. Alyce Hughey
1/26/2012 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report, dated October 17, 2011. The Phillips-Marathon Unit and the Calgon Unit were operating within normal limits during July, August and September of 2011. The Surface Impoundment Unit pump-and-treat remediation system is no longer in operation. Alyce Hughey
1/30/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 63, May, June, and July 2011, dated August 31, 2011, from Kent & Sullivan. The SI monitoring wells SMW-27 and SMW-32 contained elevated concentrations were they historically have not. Well SMW-27 contained 6.5 ug/L TCE where it historically has not detected TCE, and well SMW-32 contained 100 ug/L benzene where it historically has been below the target groundwater protection standard. It is thought that the increases are a result of inadequate air flow to even-numbered air sparge wells, due to a broken air line to sparge well SAS-24. The PM Area contaminant concentrations are within or below the range of historical values. The corrective measures are performing satisfactorily and it meets the performance requirements of the permit. The PM 2011 Highway AS/SVE System will be installed and started during Quarter 64 after EPA approved on July 28, 2011. The PIRM benzene concentrations in well PI-03 have continued to increase from 5.51 ug/L quarter 62, and 66 ug/L, 102 ug/L, 110 ug/L, and 126 ug/L respectively during quarter 63. Also, the benzene concentrations in well E-187A have shown an increase from 15 ug/L in quarter 62, and 23.8 ug/L, 19.5 ug/L and 12 ug/L respectively during quarter 63. The increase in benzene has not been determined; and additional air sparge wells and an additional monitoring well is planned to be installed in quarter 64. Monitoring well E-91 continues to detect benzene for the third quarter now, where historically have not. This well is planned to be continued to be monitored to see if any changes occur in the groundwater quality. The Wharf Area continues to meet the Wharf 2010 Standby Performance Standards. The B Unconfined Aquifer contaminant concentrations are within or below the range of historical values. The Upper Confined Aquifer monitoring well E-127, had an increase in benzene concentrations at 5.7 ug/L in Quarter 62, and 10 ug/L in Quarter 63. A supplemental sample was also collected from well E-198, and it is thought that the benzene is migrating from well E-198 to well E-127. Well E-127 will continue to be monitored to see if any changes are made. Alyce Hughey
2/1/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 64, dated November 30, 2011, from Kent & Sullivan. The SI monitoring wells SMW-27, SMW-31 and SMW-32 were re-sampled this quarter to evaluate the benzene and TCE concentrations. The benzene concentrations in SMW-32 went from 110 ug/L to 2.7 ug/L and TCE went from 3.7 ug/L to undetected. The benzene concentrations in SMW-27 went from undetected to 5.2 ug/L, and TCE went from 6.4 ug/L to 4.3 ug/L. The benzene concentrations in SMW-31 went from 1.8 ug/L to 1.9 ug/L and the TCE concentrations went from 3.5 ug/L to 77 ug/L. The benzene and TCE fluctuations are thought to be a result from remnant portions of the plume that are now cut off by the sparge system. The TCE concentrations in well SMW-I-1 went from 44 ug/L in Quarter 63 to 65 ug/L in Quarter 64. Monitoring well SMW-I-1 will continue to be monitored on a quarterly basis until adequate progress can be demonstrated. Monitoring well SMW-13 was abandoned on August 16, 2011 to allow construction of the containment dike around a new aboveground storage tank. The PM Area contaminant concentrations are within or below the range of historical values. The Highway AS/SVE System equipment connex was fabricated and shipped to the refinery this quarter and Vapor Monitoring Points HVMP-4 through HVMP-9 where installed. The completion of the installation of the Highway AS/SVE System will be conducted in November of 2011. The PIRM Area investigation and sampling in well PI-03 and E-187A showed that the benzene is passing through the bottom of the A-Aquifer beneath the original line of air sparge wells. An additional monitoring well was installed down-gradient of PI-03 with benzene being detected at 32 ug/L and 42.7 ug/L. Three additional air sparge wells were installed (PAS-21 to PAS-23) to the base of the A-Aquifer to intercept the deep benzene plume. The benzene concentrations in well PI-03 showed a decrease in benzene from 100 ug/L to 17 ug/L due to the initial operation of new air sparge wells. Additional deep air sparge wells are planned to be installed in November to continue to address the benzene concentrations within wells E-187A, PI-03 and E-239. Monitoring well E-91 will continue to be sampled to monitor the benzene concentrations. The Wharf Area continues to meet the Wharf 2010 Standby Performance Standards. The B Unconfined Aquifer contaminant concentrations are within or below the range of historical values. The Upper Confined Aquifer well E-127 had concentrations at 5.7 ug/L in Quarter 62, 10 ug/L in Quarter 63, and 15 ug/L in Quarter 64. It is thought that the benzene in well E-198 is migrating to well E-127. Monitoring well E-127 will continue to be monitored to see if any changes are made. Alyce Hughey
3/15/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 65, dated February 29,2012, prepared by Kent & Sullivan. The SI Area TCE concentration in well SMW-I-1 continues to increase in concentrations, with 88 ug/L, and monitoring well SMW-32 continues to have elevated benzene concentration above the groundwater cleanup levels, at 26 ug/L. It is thought that the elevated TCE and Benzene concentrations in the SI Area are due to low air flow to the SI air sparge system from a faulty pressure relief valve. The faulty pressure relief valve was corrected in mid-December, and continual monitoring is being conducted to ensure that the air sparge system is working properly. The PM Area Highway AS/SVE System and Monitoring began on January 16, 2012, after the system was finished being installed and initial testing was performed in November and December of 2011. The R-21 Shut-Off Pilot Test was submitted to EPA and will be initiated upon approval. Within the PIRM Area, six additional deep air sparge wells were installed this quarter and three new monitoring wells, E-239 to E-241. The new monitoring wells were installed to provide additional down-gradient, up-gradient and side-gradient monitoring locations for the deep benzene plume. Monitoring well PI-03 continues to detect elevated benzene concentrations for the fourth quarter. Tesoro is continuing to troubleshoot this problem and make corrections to the PIRM AS/SVE as needed. The Benzene concentrations in down-gradient wells E-187A went from 23.8, 19.5, and 12 ug/L to 3.4 ug/L, and well E-239 went from 32 and 42.7 ug/L to 4.9 ug/L. The concentrations within these two down-gradient monitoring wells are showing an improvement since the additional deep air sparge wells were installed and initiated. The WHARF Area continues to meet the Wharf 2010 Standby Performance Standards. The B-Aquifer concentrations are within or below the historical ranges, and the migration pathways are similar to previous events. No significant changes were observed. The Upper Confined Aquifer contaminant concentrations are within or below the range of historical values, and the migration pathway is similar to previous quarters, other than within well E-127, with concentrations at 5.7 ug/L in Quarter 62, 10 ug/L in Quarter 63, 15 ug/L in Quarter 64, and 20 ug/L in Quarter 65. It is thought that the benzene in well E-198 (showing a decreasing trend) is migrating to well E-127. Monitoring well E-127 will continue to be monitored to see if any changes are made. Alyce Hughey
6/18/2012 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report for January, February and March of 2012 for Paul Horwath. The Calgon Unit was diverted to the Phillips-Marathon Unit after benzene was detected exceeding the effluent limits in January. The carbon filter was changed on February 21, 2012 and remained diverted to the Phillips-Marathon Unit due to a frozen pipe. The Phillips-Marathon Unit operated within normal limits, and the Surface Impoundment Unit is no longer operated in this unit. Alyce Hughey
8/2/2012 Document, Report, or Work plan Review - other Reviewed the Treated Groundwater Injection Permit Quarterly Report for April, May and June of 2012 for Paul Horwath. The Calgon Unit pipe thawed out and water was started back to the unit on May 25, 2012, and operated within normal limits. The Phillips-Marathon Unit operated within normal limits, and the Surface Impoundment Unit is no longer operating. Alyce Hughey
10/1/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 66, February, March, and April 2012, dated June15, 2012, prepared by Kent & Sullivan. The SI area well SMW-I-1 showed a decrease after a series of increases this quarter. Elevated benzene and TCE concentrations have been observed in SMW-32 and SMW-31 respectively. It is thought that the elevated TCE and benzene concentrations was due to a low air flow to the SI air sparge system from a faulty pressure relief valve. The system was repaired and a decrease in benzene was seen in SMW-32 and in TCE in SMW-31. Tesoro plans to redevelop several of the wells next quarter to improve the system performance. The PM Highway AS/SVE System and Monitoring began on January 16, 2012. The plume continues to remain within the extraction and air-sparge system capture zone, even with R-21 pumping at a reduced rated due to heavy iron fouling. The initial startup report shows that benzene concentrations immediately down-gradient of Highway AS/SVE system decreased significantly from Quarter 64 to Quarter 66 with reductions of 97 to 99% in wells sampled. The PIRM Area AS system was changed last quarter to address the benzene migration past the AS line. Nine new deep AS wells were installed and has cut off most of the plume; however, the plume has migrated north past the AS line with an increase seen in well E-241. In addition one of the new AS wells failed and the benzene plume is migrating past this well seen with the increase in well PI-03. Tesoro plans to replace the failed new AS well and expand the AS line to the north. The source of the down-gradient benzene concentration past the PIRM AS system was identified as being from a deep benzene plume migrating at the base of the A-aquifer. Also an increase was seen in E-143. This well and the down-gradient well E-237 will be sampled next quarter to evaluate the extent of the plume migration in this area. The WHARF Area continues to meet the Wharf 2010 Standby Performance Standards. The B-Aquifer plume capture could not be defined due to the low pumping and injection rates and the difficult winter operating conditions. The wells will be re-gauged next quarter to evaluate the capture zone. The Upper Confined Aquifer elevated benzene concentrations remains within only wells E-127 and E-198. Well E-198, showing a decreasing trend and well E-127, showing an increasing trend. It is though that benzene is migrating from well E-198 to E-127. These wells will continue to be monitored to see if any changes are made. Alyce Hughey
11/23/2012 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 67, May, June, & July 2012, dated August 31, 2012, prepared by Kent & Sullivan. The SI area well SMW-I-1 showed another decrease in TCE after a series of increases this quarter, where SMW-31 showed another increase in concentrations. Benzene concentrations increased in SMW-32 after a decrease was reported last quarter. The flux in benzene and TCE concentrations within the SI area has been associated with various air system problems that were addressed by replacing faulty equipment, and Tesoro plans to continue to address the problem next quarter by re-developing some of the sparge wells. After the startup of the PM Highway AS/SVE System down-gradient wells are starting to show decrease benzene concentrations. Wells showing decreases are E-53 from 17 ug/L to non-detect, E-122 from 1,500 ug/L to 800 ug/L, E-234A from 150 ug/L to 42 ug/L, E-235A from 34 ug/L to non-detect, E-236 from 31 ug/L to 12 ug/L. R-21 pump was replaced; however, on July 30th the heat trace on R-21 return line failed and now requires replacement. Tesoro would like to first implement the Phase 2 testing of the PM Highway AS/SVE pilot system, pending EPA approval before replacing the line, due to the expense. The PIRM AS system was expanded this quarter by converting well E-241 to AS well PAS-30, installing two new AS wells north of PAS-30 (PAS-31 and PAS-32) and replacing PAS-21 with a new well designated as PAS-21R. Also a new sentinel well (E-242) was installed at the north end of the lengthened sparge line and a new up-gradient well (E-243) installed east of the air sparge system, with additional legs to serve the wells. Benzene concentrations decreased slightly in PI-03 from 66 ug/L to 54 ug/L, E-239 from 2.5 ug/L to non-detect and wells E-172 and E-185 north of PI-03 contained low benzene concentrations where previous samples did not. Well E-143 continues to increase in high concentrations, with benzene now at 49 ug/L. WHARF Area continues to meet the Wharf 2010 Standby Performance Standards. High benzene concentrations were detected in wells E-205, E-219, and E-225 due to low pumping rates last winter, resulting in inadequate down-gradient capture. Pumping rates were adjusted and by early June the wells were within the capture zone. The Upper Confined Aquifer elevated benzene concentrations remains within only wells E-127 and E-198. Well E-198, showing a decreasing trend and well E-127, showing an increasing trend. It is though that benzene is migrating from well E-198 to E-127. These wells will continue to be monitored to see if any changes are made. Alyce Hughey
12/28/2012 Update or Other Action ADEC received a letter of response from EPA on November 9, 2012, to Tesoro's Memorandum: PIRM Area Deep Benzene Plume Update, dated October 9, 2012. EPA approved starting Phase 2 of the Highway Air Sparge/Soil Vapor Extraction system pilot test, but did not approve ceasing operation of recovery well R-21 at this time. Phase 2 of the pilot must operate for at least six months and the results evaluated by EPA before EPA will consider ceasing operation of R-2. A Class 3 permit modification will be required to cease operation of R-21. Alyce Hughey
1/15/2013 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report Number 68, dated November 30, 2012, from Kent and Sullivan. The SI area wells SMW-31 and SMW-I-1 showed an increase in benzene concentrations this quarter along with an increase in TCE. The flux in benzene and TCE concentrations has been associated with various air system problems one addressed last quarter by replacing faulty equipment, and one from the constructed buried well heads preventing routine maintenance of the AS wells and air pipelines, resulting in a gradual decrease in AS treatment effectiveness from low air flow rates. The SI AS system was shut down temporarily near the end of the quarter because both sparge blowers failed. One blower was repaired and one was replaced and re-started. Fourteen SI air sparge wells were upgraded by extending their well casings to ground surface for easier maintenance and re-development except for one with a misaligned casing. Next quarter Tesoro plans to blow out the AS lines. The PM Highway AS/SVE System were showing improvement last quarter; however, concentrations did show an increase from last quarter as a result of shut-downs caused by a fault in the SVE system’s catalytic oxidizer. It is expected to be corrected next quarter. EPA approved for the start of the Phase 2 of the Highway Air Sparge/Soil Vapor Extraction system pilot test, but did not approve ceasing operation of recovery well R-21. The heat trace on the return line for R-21 was replaced and returned to its usual pumping rates. The PIRM migration pathways are similar other than an increase in benzene in well E-151 on the north side of the plume contained 26 ug/L benzene, and confirmation sample collected contained 121 ug/L benzene. Tesoro plans to investigate the increase next quarter. The sparge system operation changes completed this quarter decreased benzene at monitoring wells E-172, E-185 and PI-3 located between the sparge well line and the hydraulic barrier, with concentrations remaining above the groundwater cleanup levels in wells E-185 and PI-3 located past the AS line. However wells down-gradient of E-185 and PI-3 located on the western side of the hydraulic barrier (E-189 and E-239) did not contain detectable benzene. WHARF Area continues to meet the Wharf Standby Performance Standards. The B-Aquifer wells E-205 increased, E-219 remained the same and E-225 increased in benzene. The high benzene concentrations detected within these wells is thought to be from low pumping rates during winter months. The pumping rates have returned to normal, and it is expected that benzene concentrations will return to historical levels slowly. The Upper Confined Aquifer monitoring well E-127 is continuing to show an increasing trend and E-198 is continuing to show a decreasing trend. These wells will continue to be monitored to see if any changes are made. Alyce Hughey
4/1/2013 Update or Other Action TCE was added to this database as a contaminant of concern. TCE contamination in soil and groundwater is present under a Solid Waste Management unit (SWMU) being regulated under EPA's Hazardous Waste Program regulations. Paul Horwath
4/5/2013 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 69, dated February 28, 2013, prepared by Kent & Sullivan. The SI area concentration of TCE in SMW-31 was 11 ug/L; the highest reported concentration for this well, and SMW-32 contained 28 ug/L benzene, the highest concentration since quarter 40. These sample results suggest that the actions taken prior to quarter 69 to improve the air sparge system were not adequate to fully capture TCE and Benzene. Changes were made in January of 2013 and further work is planned next quarter to address problems with wells SAS-10, SAS-13 and SAS-14. Monitoring well E-122 contained 300 ug/L benzene which is the lowest concentration reported since Quarter 53. This well is located down-gradient of the PM Highway AS/SVE System and it appears that the system is helping decrease the benzene concentrations down-gradient. Wells down-gradient of the PIRM air sparge system and west of the hydraulic barrier (E-186, E-187A, E-189, E-190A and E-239) were below the benzene target groundwater protection standard for 1.5 years. These long-term results indicate that the revamped air sparge system is adequately controlling the A-aquifer and the more recent deep benzene plume present at the bottom of the A-aquifer. Wells E-185 and PI-3 continue to exceed the benzene target groundwater protection standard. Well E-185 went from 11 ug/L to 12 ug/L Benzene and PI-3 went from 29.3 to 11 ug/L from quarters 68 to 69. Well E-242, the northern sentinel well of the PIRM air sparge system contained 2.8 ug/L Benzene compared to previous quarters, where it was not detected. This detection to the north may indicate that the deep benzene plume is continuing to expand to the north. Tesoro plans to further investigate the northern extent of the deep Benzene plume next quarter. WHARF Area continues to meet the Wharf Standby Performance Standards. Of the three wells sampled in the B-Aquifer, all three were non-detect. The Upper Confined Aquifer well E-127 contained 140 ug/L benzene, the highest concentration yet, and well E-198 showed an increase from last quarter but not as high as historical concentrations. Tesoro plans to install an industrial water supply well TW-2B next quarter. This well will be located about 30 feet north of the existing TW-2A and will be pumped at similar rates. Switching to the new well will not have significant impacts on the upper confined aquifer. Alyce Hughey
4/16/2013 Document, Report, or Work plan Review - other The Treated Groundwater Injection Permit Quarterly Report for January, February and March of 2013 reported that the Phillips-Marathon Unit and the Calgon Unit operated within normal limits and the Surface Impoundment Unit is no longer operating. Alyce Hughey
4/18/2013 Update or Other Action On February 1, 2013, ADEC’s Prevention and Emergency Response Program responded to a release of approximately 420-gallons of fuel, southwest of tank 20 at the intersection of 5th and B (SW corner of the tank farm) from a pipeline flange at the Tesoro Alaska Refinery. Contaminated soil was excavated and transported to ASR for thermal remediation and disposal. Following excavation, soil samples were collected with elevated benzene and DRO results depicting that historic contamination remains. Attached to the Contaminated Sites database is “Figure 3 Soil Excavation Map 2013 VTBB Pipeline Release” and “Spill Summary Report Tesoro VTB Release 2-1-2013” documenting this release for future cleanup when the historical soil contamination at the refinery will be addressed following the cleanup of the groundwater according to the EPA Corrective Action Order for the refinery. Alyce Hughey
6/26/2013 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 70, dated June 15, 2013, prepared by Kent and Sullivan. The SI area benzene plume is larger at the north end of the plume this quarter, with 51 ug/L benzene in well SD-3. Well SMW-31 contained 18 ug/L TCE this quarter the highest concentration for this well, and SMW-12B contained 680 ug/L benzene; the highest concentration recorded for this well. In addition well SD-3 contained the highest benzene concentration since quarter 28, and SMW-32 contained the highest concentrations since Quarter 63, and SMW-2B contained TCE for the first time. The air pipeline to SAS-14 was broken and benzene migrated to SMW-32. The Highway AS/SVE system is showing significant improvement in the groundwater quality with significant reductions of benzene in down-gradient wells. It is estimated that the treated groundwater from the Highway AS/SVE system is advancing at approximately 1.5 to 1.7 feet per day and it is expected that the clean groundwater will reach the PIRM AS system first half of 2015. The A-aquifer plume is captured by the PIRM recovery wells with the exception of the northern edge of the deep benzene plume, and well E-187A. The northern edge of the deep benzene plume has expanded into sentinel well E-242 with an increase in benzene from 2.8 ug/L to 45 ug/L, as well as into well E-187A at a concentration of 16 ug/L, which is thought to be associated with operation problem with well PAS-25. Tesoro plans to convert well E-242 to an air sparge well, and install a new sentinel well at the north end of the sparge line. In addition Tesoro Plans to restart A-aquifer recovery well R-40 to capture a portion of the deep benzene plume and to stop further northward expansion of the plume. One sample was taken from the WHARF Area (well E-160), with groundwater sample results meeting the Wharf 2010 Standby Performance Standards. Well E-225 located near the down-gradient plume margin of the B Unconfined Aquifer was outside the capture zone. Well maintenance is planned next quarter to increase system pumping and injection capacities, and improve capture. Also well E-206 detected benzene for the first time this quarter at 2.1 ug/L and xylenes at 4.3 ug/L. The presence of xylenes is not characteristic and will be evaluated when sampled again in quarter 72. The concentrations continue to increase in well E-127 with 220 ug/L benzene, the highest concentration yet, and well E-198 showed a decrease from last quarter from 65 ug/L to 20 ug/L. It is still thought that the benzene plume is migrating from E-198 to E-127. The down-gradient well E-148 appears to be on this benzene plume flow path and is planned to be sampled next quarter. Production well TW-2A was replaced by TW-2B. This well will serve as the primary refinery water supply well. The groundwater levels across the site were at or above historical levels as a result of a large snow pack in 2012 and rain storms in the fall of 2012. Alyce Hughey
7/17/2013 Document, Report, or Work plan Review - other The Treated Groundwater Injection Permit Quarterly Report for April, May and June of 2013 reported that the Phillips-Marathon Unit and the Calgon Unit operated within normal limits and the Surface Impoundment Unit is no longer operating. Alyce Hughey
8/23/2013 Update or Other Action Reviewed EPA Comments Regarding Tesoro PIRM Deep Benzene Plume, dated August 6, 2013. EPA had the following comments after reviewing Tesoro's letter regarding the PIRM deep benzene plume, dated May 14, 2013, and from the follow-up discussion in Quarterly Progress Report Number 70, dated June 15, 2013. 1. The benzene plume in the PIRM area has been spreading laterally to the north since November 2011. While EPA agrees with Tesoro's proposed action to extend the line of AS wells further to the north and start operation of recovery well R-40, EPA also believes that it is important to understand why the plume is expanding. Potential data needs/gaps, if they exist, must be identified and further corrective measures may be required. 2. The most recent monitoring data (Quarter 70) indicate that the benzene plume also escapes the AS system in the area between wells PAS-23 through PAS-26. A comprehensive evaluation must include a determination of the reason for the non-containment of the plume in the middle section of the AS line, and what measures are necessary to contain the plume in this area. 3. Tesoro must also propose additional actions to address elevated benzene concentrations at E-187A. An evaluation must include a determination of whether this detection indicates an escape from the shallow or deep benzene plume and whether it can be addressed by adjusting AS operations or adding a new AS wells to fill gaps both horizontally and vertically. Alyce Hughey
9/12/2013 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report Number 71, dated August 30, 2013, from Kent and Sullivan. The SI area benzene plume in well SD-3 had 51 ug/L benzene last quarter, with 59 ug/L benzene being confirmed this quarter, and SMW-32 continues to show an increase in benzene. The TCE plume continues to increase in well SMW-31 and well SD-3 contained 18 ug/L this quarter where it was not detected last quarter. It is thought that the high water levels and the low or no air flow to SAS-13, SAS-14 and SAS-15 are the cause of the shift in contaminant concentrations. The broken line to SAS-14 was repaired and poorly performing wells were redeveloped. Additional supplemental samples will be collected to continue to assess the plume. Two monitoring wells were installed E-245A and E-245B in the Highway AS/SVE system. Well E-245A contained 530 ug/L benzene. This well is planned to be sampled again next quarter and if benzene concentrations are confirmed the air sparge line will be expanded to the north and a new sentinel well will be installed. In the PIRM area, well E-187A continues to detect benzene above the target groundwater protection standard with 11 ug/L benzene. Corrective measures implemented this quarter to capture the deep benzene plume included the expansion of the PIRM AS System by converting E-242 to an air sparge well, installing a new air sparge well north of E-242 and installing a new sentinel well north of the air sparge line. Air sparge well PAS-25 was tuned and modified, and recovery well R-40 was restarted to capture a portion of the deep benzene plume. One sample was taken from the WHARF Area (well E-160), with groundwater sample results meeting the Wharf 2010 Standby Performance Standards. B-Unconfined Aquifer wells E-205 and E-225 located near the down-gradient plume margin continue to be outside the capture zone, with 2,200 ug/L and 1,800 ug/L respectively. Gauging was conducted as well as R-50, R-51 and R-52 were redeveloped and it is expected that the concentrations will show a decrease in concentrations in the coming quarters. The concentrations in well E-127 remained 220 ug/L benzene, and well E-198 showed a decrease from last quarter from 20 ug/L to 17 ug/L. Supplemental samples collected down-gradient of wells E-198 and E-127 did not detect BTEX concentrations. This supports the analysis that the plume that emanates from the well E-198 area is migrating into well E-127 area where it is currently present. Tesoro plans to sample E-148 the down-gradient well from E-127, to monitor the migration of benzene in the Upper Confined Aquifer. Alyce Hughey
9/23/2013 Exposure Tracking Model Ranking A new updated ranking with ETM has been completed for source area 71291 OWSS leaks & various spills. Paul Horwath
10/11/2013 Document, Report, or Work plan Review - other The Treated Groundwater Injection Permit Quarterly Report for July, August and September of 2013 reported that the Phillips-Marathon Unit and the Calgon Unit operated within normal limits and the Surface Impoundment Unit is no longer operating. Alyce Hughey
1/6/2014 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 72, dated November 30, 2013, prepared by Kent & Sullivan. The SI area had modifications completed to the air sparge system controls between August 23 and September 20, 2013 to address the TCE and Benzene plumes. The air sparge wells were divided into three banks instead of two. This increased the average air flow but decreases the operating time by 33 percent. With an increase in air flow, the radius of air channels around operating wells will eliminate gaps in the treatment zone. Following the modifications to the air sparge system, improvement in concentrations were observed in SMW-32, with benzene decreasing from 110 ug/L to 12 ug/L. However, well SMW-31 did not show an improvement due to air sparge well SAS-9, located directly up-gradient was out of service due to being damaged by heavy equipment. This air sparge well is planned to be repaired next quarter. A lake formed over the past year in the wetlands between the northwest corner of the refinery and the Spur Highway due to historically high groundwater levels. This lake is planned to be investigated further during the next quarter. The newly installed monitoring well E-245A installed in Quarter 71, north of the Highway Air Sparge Line, detected benzene at 530 ug/L in Quarter 71. This well was sampled again in Quarter 72 with 320 ug/L benzene, confirming the presence of benzene north of the Highway Air Sparge line. Based on these sample results the Highway AS/SVE system will be expanded northward next quarter. Wells down-gradient of the PIRM air sparge system and west of the hydraulic barrier tested this quarter (E-186, E-187A, and E-239), confirms that the modifications to the PIRM AS system and the startup and operation of R-40 indicates that the deep benzene plume is now being captured, with none of the down-gradient wells detecting benzene above the groundwater cleanup levels. The benzene plume has shown a significant change since the startup of R-40. The width of the plume has decreased at the northern part of the plume, and it is hoped to continue to decrease with operation of R-40. If this occurs, well E-243 will reach concentrations below the groundwater cleanup levels and the plume width will be at least 80 feet less. One sample was taken from the WHARF Area (well E-160), with groundwater sample results meeting the Wharf 2010 Standby Performance Standards. B-Unconfined Aquifer wells E-205 and E-225 located near the down-gradient plume margin continues to be outside the capture zone, with 1,900 ug/L and 1,900 ug/L respectively. Well E-205 showed a decrease with 2,200 last quarter to 1,900 ug/L this quarter, and well E-225 showed an increase with 1,800 last quarter to 1,900 ug/L this quarter. Modifications were made with R-50, R-51 and R-52 and two additional recovery wells are planned to be installed. The Upper Confined Aquifer concentrations in well E-127 showed a decrease from 220 ug/L to 190 ug/L, and well E-198 showed an increase from last quarter from 17 ug/L to 28 ug/L. With the decrease in benzene concentrations in E-127, it is thought that the plume concentrations have peaked and concentrations may decrease steadily in future quarters. Alyce Hughey
1/28/2014 Document, Report, or Work plan Review - other The Treated Groundwater Injection Permit Quarterly Report for October, November and December of 2013 reported that the Phillips-Marathon Unit and the Calgon Unit operated within normal limits and the Surface Impoundment Unit is no longer operating. Alyce Hughey
3/12/2014 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 73, November and December 2013, January 2014, dated February 28, 2014, prepared by Kent & Sullivan. The SI monitoring wells detecting TCE this quarter above the groundwater cleanup levels include SMW-31 and SMW-I-1, with decreasing concentrations. Well SMW-31 went from 21 ug/L to 20 ug/L, and well SMW-I-1 went from 35 ug/L to 32 ug/L. None of the wells sampled detected Benzene above the groundwater cleanup levels. As planned air sparge well SAS-9 was repaired but was found to be plugged with dirt and remained out of service this quarter. SAS-9 is planned to be repaired or replaced next quarter. The lake that formed over the past year in the PM wetland area was further investigated this quarter through the collection of surface water samples, with Benzene concentrations at 4.3 to 900 ug/L. Additional corrective actions were conducted through the Highway AS/SVE system expansion northward, with the installation of four air sparge wells HAS-18 through HAS-21, one soil vapor extraction well HSVE-8, two vapor monitoring points HVMP-10 and HVMP-11 and a set of nested monitoring wells E-246A and E-246B. Based on the sample results from the investigation activities it was determined that the groundwater in the upper part of the aquifer is flowing into the swamp, and the Draft PM Swamp Corrective Action Modification Plan was developed in an effort to meet performance measures. The northern wells in the PIRM area (E-244 and E-151) did not contain detectable benzene this quarter. Down-gradient well E-187A showed a decrease in benzene concentrations with 2.8 ug/L benzene were last quarter it contained 3.9 ug/L. Well E-171 located east of the plume contained elevated BTEX concentrations and is presumed to be anomalous. Well E-171 detected Benzene at 240 ug/L, Toluene was non-detect, Ethylbenzene at 7,000 ug/L and Xylenes at 23,140 ug/L, Well E-171 will be sampled again next quarter to verify the BTEX concentrations in the well. One sample was taken from the WHARF Area (well E-160), with groundwater sample results meeting the Wharf 2010 Standby Performance Standards. The three wells sampled in the B-Unconfined Aquifer were non-detect for all analytes. The Upper Confined Aquifer concentrations in well E-127 showed an increase from 190 ug/L to 220 ug/L, and well E-198 showed an increase from last quarter from 28 ug/L to 29 ug/L. Well E-148 located down-gradient of E-127 did not detect Benzene this quarter. Alyce Hughey
5/21/2014 Document, Report, or Work plan Review - other The Treated Groundwater Injection Permit Quarterly Report for January 1 through March 31, 2014 reported that the Phillips-Marathon Unit and the Calgon Unit operated within normal limits and the Surface Impoundment Unit is no longer operating. Alyce Hughey
5/21/2014 Update or Other Action On April 14, 2014 Tesoro received an analytical report that indicated the Philips-Marathon Unit treated groundwater sampled on April 4, 2014 was 7 ug/L benzene, which exceeds the permitted limit of 5 ug/L. On April 14, 2014 Tesoro re-sampled the treated water, with results of 4 ug/L benzene. The elevated benzene concentrations is thought to be caused by the stripping unit in-service at that time. Alyce Hughey
5/21/2014 Update or Other Action On April 21, 2014 a sulfur dioxide release of 524 pounds was released from the main refinery flare (J-801) from 10:40 AM to 12:50 PM, for a total duration of 2 hours and 10 minutes. The flaring occurred during a planned maintenance shutdown of the Hydrocracker Unit. These releases are not believed to have impacted any individuals or pose any acute or chronic health risks. No emergency response actions were required for the release. Alyce Hughey
7/1/2014 Document, Report, or Work plan Review - other Reviewed the Quarterly Progress Report No. 74, dated June 15, 2014, prepared by Kent & Sullivan. The SI monitoring wells detecting TCE this quarter above the groundwater cleanup levels included SMW-31 and SMW-I-1. Well SMW-31 went from 20 ug/L to 16 ug/L, and well SMW-I-1 went from 32 ug/L to 35 ug/L. Groundwater was flowing to the west which is not consistent with previous gauging. It is unknown as to the cause for the change, but it is thought that it could be associated with the high water levels combined with the spring thaw. With the change in groundwater flow towards the west monitoring well SMW-5 contained detectable benzene at 4.7 ug/L for the first time. In addition the benzene plume migrated south of the air sparge line with well SMW-32 containing 16 ug/L benzene. Well SAS-9 was repaired (up-gradient of SMW-31) and it is expected that concentrations in SMW-31 will decline. The lake within the PM wetland was investigated further with twenty-three surface water samples collected below the ice cap of the swamp in February and March of 2014, with benzene concentrations ranging from 9.03 to 437 ug/L. Higher concentrations were found to be located in the southeastern portion of the swamp. Toluene was detected in all surface water samples, which is unusual for the site. In efforts to track the infiltration of the groundwater into the swamp area, monitoring wells up-gradient of the swamp were sampled. Monitoring well E-227 detected Toluene at 2,600 ug/L, indicating that the area of well E-227 could be the flow path of the groundwater infiltration into the swamp area. Additional corrective actions in the PM Area included the installation of paired wells E-247A, E-247B, E-248A and E-248B, installation of air sparge wells HAS-23 and HAS-24, and the abandonment of well E-072R and installation of well E-072RR. The PIRM down-gradient well E-168 detected benzene this quarter and it is thought that the concentrations present in this well is a remnant of the benzene present in well E-187A last spring. Monitoring well E-151, down-gradient of recovery well R-40, contained 94 ug/L benzene. Recovery well R-40 pumping rate was increased to help capture the plume. The follow-up sample collected in well E-171 indicated that the elevated BTEX concentrations last quarter were anomalous. One sample was taken from the WHARF Area (well E-160), with groundwater sample results meeting the Wharf 2010 Standby Performance Standards. Well E-160 contained DRO at 1,200 ug/L this quarter where last quarter it only contained 440 ug/L, and Benzene was detected at 4.8 ug/L were last quarter it was non-detect. Notable changes to the groundwater plume within the B-Unconfined Aquifer included Well E-233 contained benzene for the first time, which expanded the northern extent of the plume, and well E-162 contained benzene again this quarter, with nearby well E-179 containing 7,770 ug/L benzene. The high concentrations in well E-179 is not known. In addition well E-219 is showing increase in concentrations and Tesoro plans to address the increase in concentrations with the submittal of a CAMP for the startup and operation of the Lower Tank Farm AS/SVE system, and expand the recovery well system by installing to additional recovery wells. The Upper Confined Aquifer concentrations in well E-127 showed a decrease from 220 ug/L to 200 ug/L, and well E-198 showed a decrease from 29 ug/L to 21 ug/L. Well E-148 located down-gradient of E-127 did not detect Benzene this quarter. Production well TW-2B was installed during Quarter 70 and was sampled in quarter 72 and quarter 74 with 14 ug/L benzene in quarter 72 and 22 ug/L benzene in quarter 74. Alyce Hughey
8/28/2015 Document, Report, or Work plan Review - other Receive and preliminarily review of the TriHydro Quarterly Progress Report #79, covering activities in May - July, 2015. Paul Horwath
1/12/2016 Update or Other Action Receive and review the Treated Groundwater Injection Permit quarterly report for October - December, 2015. Water quality in compliance with permit allowed effluent limits. Paul Horwath
2/9/2016 Document, Report, or Work plan Review - other Review the Trihydro January 21, 2016 letter and Work Plan for Well Installation submitted to EPA and Cc'd to ADEC. Provide ADEC review comments to EPA's Jan Polumbo via e-mail. Paul Horwath
7/15/2016 Update or Other Action Receive and review Tesoro's treated groundwater injection quarterly monitoring report for April - June, 2016. Paul Horwath
12/7/2016 Document, Report, or Work plan Review - other Receive and log in Tesoro's Quarterly Progress Report No. 16-4, prepared by Trihydro, covering the period August-October, 2016. Paul Horwath
1/31/2017 Update or Other Action Receive Tesoro's compliance notification letter for the October 2016 exceedance of the daily wastewater flow rates associated with their treated groundwater injection system. Paul Horwath
7/3/2017 Document, Report, or Work plan Review - other Review and provide comments to Tesoro's consultant, Trihydro, concerning Tesoro's treated groundwater injection workplan. Paul Horwath
7/5/2017 Document, Report, or Work plan Review - other Receive and review Tesoro's treated groundwater injection quarterly monitoring report for April - June, 2017. Paul Horwath
7/6/2017 Document, Report, or Work plan Review - other Review and provide comments to EPA on Tesoro's SI Area GW treatment work plan. Paul Horwath
10/12/2017 Document, Report, or Work plan Review - other Received and reviewed the quarterly treated groundwater sampling and analysis report. All analytes were within their applicable discharge limitations/concentrations. Paul Horwath
10/16/2017 Document, Report, or Work plan Review - other Reviewed, and provided comments to, Tesoro in response to their revision 4 of their Treated Groundwater Injection Plan. Paul Horwath
10/31/2017 Site Characterization Workplan Approved Issue ADEC approval decision on Tesoro's October 18, 2017 Treated Groundwater Injection Plan. Paul Horwath
12/19/2017 Document, Report, or Work plan Review - other Review Tesoro's RCRA Post-Closure Permit required Quarterly Progress Report #17-4, dated November 30, 2017. Paul Horwath
1/16/2018 Document, Report, or Work plan Review - other Received and reviewed the 4th quarter treated groundwater sampling and analysis report. The PM treatment system sample collected in November 2017 exceeded the treatment limit of 1.7ug/L naphthalene, with a laboratory reported concentration of 4.49ug/L. All produced groundwater was then sent to the Calgon treatment unit for treatment and disposal. The Calgon unit treated water samples all met the established contaminant-specific treatment levels. Paul Horwath
4/13/2018 Document, Report, or Work plan Review - other Receive & review Tesoro's 1st quarter 2018 treated groundwater sampling and analysis report, prepared by TriHydro. All concentrations met the discharge permit limitations. Paul Horwath
6/1/2018 Document, Report, or Work plan Review - other Received Tesoro's RCRA Post-Closure Permit Quarterly Progress Report No. 18-2. Begin review of report. Paul Horwath
6/19/2018 Document, Report, or Work plan Review - other ADEC review of the Tesoro RCRA Post-Closure Permit, Quarterly Progress Report No. 18-2, dated May 31, 2018. Paul Horwath
7/12/2018 Document, Report, or Work plan Review - other Receive Tesoro's 2nd quarter 2018, treated groundwater sampling and analysis report, prepared by Trihydro, for the injection of treated groundwater. Benzene is only COC detected at slowing increasing concentration, but still less than 2 ug/L. No other COCs detected. Paul Horwath
12/18/2018 Document, Report, or Work plan Review - other ADEC review of the Tesoro RCRA Post-Closure Permit, Quarterly Progress Report No. 18-4, dated November 30, 2018. Paul Horwath
1/7/2019 Document, Report, or Work plan Review - other Receive and review Tesoro's 4th quarter, 2018 treated groundwater permit sampling and analysis event report, prepared by Trihydro. Benzene was the only analyted detected, and at a maximum concentration of 2.32 ug/L, below the 4.6 ug/L treatment standard. Paul Horwath
4/9/2019 Document, Report, or Work plan Review - other Receive and review Tesoro's 1st quarter, 2019 treated groundwater permit sampling and analysis event report, prepared by Trihydro. Benzene was the only analyted detected - at a maximum concentration of 0.78 ug/L, well below the 4.6 ug/L required treatment level. Paul Horwath
7/10/2019 Document, Report, or Work plan Review - other ADEC approved Trihydro's 2019 Injection Well Rehabilitation Work Plan - Revision 1, dated July 10, 2019. Paul Horwath
10/7/2019 Document, Report, or Work plan Review - other Receive and review Tesoro's 3rd quarter, 2019 treated groundwater permit sampling and analysis event report, prepared by Trihydro. Benzene was the only analyted detected - at a maximum concentration of 1.76 ug/L, well below the 4.6 ug/L required treatment level. Peter Campbell
12/3/2019 Update or Other Action There has been periodic sheen developing on the beach, emanating from the bluff adjacent to monitoring wells B-1 and B-2. It appears that this sheen may be originating from the Hot Oil Pipeline release that has been causing sheen since the early 1990's. Several investigations have been conducted at the site. The Spill Response Program has agreed to allow Marathon to conduct "Daily checks recording at minimum: • Date, time, recorder’s name • Written description of sheen visibility • Weather • Photograph During each check, the technician will evaluate whether additional mitigation will be needed that day, beyond the boom placed at the bottom of the bluff." Peter Campbell
12/23/2019 Document, Report, or Work plan Review - other ADEC review of the Tesoro RCRA Post-Closure Permit, Quarterly Progress Report No. 19-4, dated November 30, 2019. Peter Campbell
12/23/2019 Update or Other Action It appears that the intermittent beach seep on the Cook Inlet Beach is not from the Hot Oil Pipeline release as previously suspected as analytical testing indicated that the contamination is a weathered gasoline range organic material. Peter Campbell
1/9/2020 Document, Report, or Work plan Review - other Receive and review Tesoro's 4th quarter, 2019 treated groundwater permit sampling and analysis event report, prepared by Trihydro. Benzene was the only analyte detected - at a maximum concentration of 3.58 ug/L in October, dropping to 0.817 ug/L in November and not detected in December, below the 4.6 ug/L required treatment level. Peter Campbell
4/8/2020 Document, Report, or Work plan Review - other Receive and review Tesoro's 1st quarter, 2020 treated groundwater permit sampling and analysis event report, prepared by Trihydro. Benzene was the only analyted detected - at a maximum concentration of 0.729 ug/L, well below the 4.6 ug/L required treatment level. Peter Campbell
4/14/2020 Document, Report, or Work plan Review - other Review the 1st Quarter 2020 Report and the Beach Seep Investigation in particular. Tesoro’s response to the beach discharge is [Page 6, Section iii, paragraph 3] ”the toxicity of the petroleum sheen is insignificant because the composition of the LNAPL has a low BTE fraction.” The discharge, and sampling points on the tidal flats exceed Alaska Water Quality Standards for TAH and TaqH and ADEC’s maximum allowable concentrations for diesel range organics on the beach. Under the State’s guidelines, the bluff top wells would be the compliance point for groundwater migrating to surface water. Two bluff top wells, E-257B and E-129 had concentration that exceed Alaska water quality standards. Beach sediment impacts, in two locations exceeded human health exposure levels for diesel range organics and TAH TAqH. (Table 3: Analytical Sediment Results). Tesoro has agreed to study remedial alternatives. Peter Campbell
7/1/2020 Document, Report, or Work plan Review - other Review the 2020 second quarter Treated Groundwater Injection Permit report. All groundwater is being treated through the Calgon carbon unit. All analytical parameters were below detection limits except benzene, which was below 0.6 ug/L. the cleanup level for benzene is 4.6 ug/L. Peter Campbell
8/27/2020 Document, Report, or Work plan Review - other Review the 2nd Quarter 2020 Report. Beach Seep remediation alternatives due June 2020. Peter Campbell
9/1/2020 Update or Other Action Request copy of June 2020 Conceptual Site Model and Assessment of Remedial Alternatives for the Beach Seep from Marathon. Peter Campbell
9/1/2020 Update or Other Action Receive copy of the EPA's assessment of Remedial Alternatives for the Beach Seep. Peter Campbell
9/17/2020 Update or Other Action EPA Approves the use of an oil coagulating compound (S200-Oilgone) to supplement beach sheen mitigation. Peter Campbell
10/2/2020 Update or Other Action The PM system is inactive. All groundwater is diverted to the Calgon treatment system. Samples are collected monthly from the Calgon treatment system effluent and analyzed for Hydrocarbons. The Calgon effluent samples were all below criteria for benzene and non-detect for all other constituents. All Calgon system flow limits and effluent concentrations were below ADEC criteria for the quarter. The latest carbon replacement occurred on October 8, 2019. Peter Campbell
1/11/2021 Document, Report, or Work plan Review - other Review the 2020 4th quarter Treated Groundwater Injection Permit report. All groundwater is being treated through the Calgon carbon unit. All analytical parameters were below detection limits. Peter Campbell
4/8/2021 Update or Other Action All pumped groundwater continues to be diverted to the Calgon treatment system. Samples were collected monthly from the Calgon treatment system effluent and analyzed for BTEX, benzene compounds and naphthalene. The Calgon effluent samples were non-detect for all constituents. All Calgon system flow limits and effluent concentrations were below ADEC criteria for the quarter. The latest carbon replacement occurred on October 27, 2020. Peter Campbell
4/12/2021 Document, Report, or Work plan Review - other Review Quarterly Progress Report 21-1. All Permit-required corrective action system performance criteria were met this quarter, except A and B-aquifer groundwater extraction rates. A mass flux evaluation was completed for the Surface Impoundment area and to assess current plume characteristics and trichloroethylene (TCE) migration. This evaluation provides an additional line of evidence that the primary attenuation mechanisms for TCE and daughter products are physical processes like dispersion. Passive flux traps (samplers) are being planned for additional data collection in the spring of 2021 to guide the future remediation approach. The beach seep area is checked daily during the ebbing tide to identify the presence of petroleum sheen seeps and mitigate sheen migration as needed. A conceptual site model (CSM) and an assessment of remedial alternatives was submitted by Marathon to the EPA November 16, 2020. No mitigation work has been conducted. Peter Campbell
5/24/2021 Update or Other Action EPA approval of Tesoro’s Updated Conceptual Site Model and Remedial Alternatives Evaluation for the 1987 Hot Oil Pipeline Release, Revision 2,” and responses to EPA comments, dated April 22,2021. Tesoro must submit a Work Plan for design and implementation of the remediation system as proposed in the revised Report within 90 days. Peter Campbell
5/28/2021 Document, Report, or Work plan Review - other Review and approve the 2021 Recovery Well Rehabilitation Work Plan dated April 29, 2021. the work will involve removing the pumps from the wells, mechanically scrubbing the screens then cleaning the well with diluted 31% hydrochloric acid for 24 hours followed by a bio-dispersant. The well will be purged until the purge water reaches background pH. The purge water will be managed for disposal. Peter Campbell
8/13/2021 Document, Report, or Work plan Review - other Review 2nd quarter 2021 Progress Report. Hydrocarbon remediation systems are operating normally. Pilot test for supplemental organic carbon to remediate TCE has been completed with the conclusion that reductive dichlorination is no longer occurring. An updated remediation approach will be developed this year. An assessment of remediation alternatives has been submitted to the EPA for the beach seep. Peter Campbell
9/13/2021 Document, Report, or Work plan Review - other Review the #21-3 Quarterly Progress Report. Tesoro will use passive flux traps in four monitoring wells the surface impoundment area to supplement the mass flux evaluation. Tesoro plans to implement bio-sparging to increase oxygen content of source soils and groundwater and potentially speed natural source zone depletion rates along the bluff. The proposed bio-sparge well installation is scheduled for September 2021. Peter Campbell
10/20/2021 Update or Other Action Marathon has submitted a work plan to the EPA, "Gravity Rock Retaining Wall Work Plan." The plan is to place large rock at the base of the bluff to dissipate wave energy and slow erosion. Erosion is happening aggressively at the end of the sea wall that protects the bluff at the Kenai Liquid Natural Gas Plant. The erosion is exposing bluff contamination from the 1997 hot oil pipeline release. The release is exposing beach seeps and making sheen and hydrocarbon odor at the base of the bluff and periodically on the beach. Peter Campbell
1/4/2022 Update or Other Action Review the 4th quarter 2021 Treated Groundwater Report. The Calgon unit effluent quarterly samples were all lower that the cleanup criteria for benzene and non-detect for all other tested constituents. The latest carbon replacement occurred on September 29, 2021. The October 6, 2021 sample had a benzene detection of 4.21 ug/L, just below the cleanup criteria of 4.6 ug/L. Peter Campbell
1/4/2022 Update or Other Action Review the 4th quarter 2021 Treated Groundwater Report. The Calgon unit effluent quarterly samples were all lower that the cleanup criteria for benzene and non-detect for all other tested constituents. The latest carbon replacement occurred on September 29, 2021. The October 6, 2021 sample had a benzene detection of 4.21 ug/L, just below the cleanup criteria of 4.6 ug/L. Peter Campbell
2/16/2022 Update or Other Action The US Environmental Protection Agency (EPA) has reviewed the Bio-Sparge Pilot Study 1987 Hot Oil Pipe Release Work Plan, Revision 1 (Work Plan, Revision 1) and the Responses to Technical Review Comments (Responses to Comments) on the Bio-Sparge Pilot Study Work Plan. The Work Plan, Revision 1 and the Responses to Comments, prepared by Trihydro Corporation, Soldotna, AK for Tesoro Alaska Company, LLC (Tesoro), are dated November 9, 2021, and were transmitted to EPA by email on February 10, 2022. The Work Plan, Revision 1 and Responses to Comments have addressed all of EPA’s comments on the previous version. EPA hereby approves the Work Plan, Revision 1 and the Responses to Comments, contingent on Tesoro making the following minor correction to the Work Plan: Page 2-3, Section 2.2, third bullet from the top of page: Well B-1 should be added to this bullet for dissolved oxygen (DO) and carbon dioxide (CO2) monitoring using a downhole probe or titration kits. Table 1 has been revised including well B-1 on this monitoring; adding well B-1 to revise text in the bullet will be consistent with Table 1. Peter Campbell
4/12/2022 Update or Other Action Review the 1st quarter 2022 Treated Groundwater Report. The Calgon unit effluent quarterly samples were all lower that the cleanup criteria for benzene and non-detect for all other tested constituents. Peter Campbell
4/12/2022 Update or Other Action Review the 1st quarter 2022 Treated Groundwater Report. The Calgon unit effluent quarterly samples were all lower that the cleanup criteria for benzene and non-detect for all other tested constituents. Peter Campbell
4/12/2022 Update or Other Action Contacted by Harvest Pipeline about a repair this summer on the Swanson River Oil Line. An inspection on the line indicated that a section of the pipe adjacent to the refinery would require routine maintenance and potentially dewatering at the excavation site. Harvest was advised to contact the EPA in preparation for the work as they are the primary regulator. ADEC Contaminated Sites Program has no special precautions for the work. Peter Campbell
6/20/2022 Document, Report, or Work plan Review - other Beech sheen report received from Tesoro from May 23 to June 5. No sheen observed. Peter Campbell
7/12/2022 Meeting or Teleconference Held Meeting with consultant and Marathon about the impoundment area TCP plume remediation plan. Plan is to install a carbon wall with plume stop injection through 22 injection points. Work plan pending. EPA has been informed. Peter Campbell
7/22/2022 Update or Other Action On July 16, 2022 Marathon observers reported a barley visible sheen on the bluff that smelled of gasoline. The sheen was not visible the following day. Peter Campbell
8/19/2022 Document, Report, or Work plan Review - other Review 2022 #2 Report. Three wells (E-233, E-209 & E-245B)on the northern portion of the B Aquifer have an increasing benzene concentration. The plume map may not represent the changes accurately. The increased levels are captured by the groundwater extraction system. Peter Campbell
9/1/2022 Document, Report, or Work plan Review - other SI Area Supplemental Groundwater Remedial Action Plan ADEC Approval The plan calls for injecting liquid carbon and iron into a cross section of the TCE benzene plume emanating from the surface impoundment area. Peter Campbell
9/1/2022 Update or Other Action Beach Sheen Report 8.16-8.29-22 No beach sheen noted for this interval. Peter Campbell
9/1/2022 Update or Other Action Beach Sheen Report 8.2-8-15-22. No sheen noted for this report period. Peter Campbell
10/6/2022 Long Term Monitoring Workplan or Report Review Beach sheen report 9-13 to 9-26-2022. On 9-17 there was a minor sheen on the bluff in three locations. Peter Campbell
10/11/2022 Document, Report, or Work plan Review - other 3rd 1/4 2022 Water treatment report submitted. All sample results from discharge were below detection levels. Peter Campbell
10/13/2022 Long Term Monitoring Workplan or Report Review Beach sheen report reviewed 9-27 to 10-10-2022. No sheen reported. Peter Campbell
12/8/2022 Update or Other Action Beech sheen report submitted for October 11, 2022 to October 31, 2022. Sheen was report on the bluff on three days, October 12, 16 and 23. On the 23rd, hydrocarbon odor was noted 100 feet down the beach. Peter Campbell
1/10/2023 Long Term Monitoring Workplan or Report Review Review 4th Quarter 2022 Treated Groundwater Report. Calgon Treatment system results were all non-detect. Peter Campbell
4/11/2023 Long Term Monitoring Workplan or Report Review Review 2023 Q1 Treated Groundwater Injection Permit Quarterly Report. The Calgon effluent samples were non-detect for the regulated constituents. The Calgon system flow limits and effluent concentrations were all non-detect for the quarter. Peter Campbell
4/25/2023 Document, Report, or Work plan Review - other Beach sheen reporting resumed from winter hiatus. Report reviewed 4-23 to 4-16-2023. No sheen reported. Peter Campbell
4/25/2023 Document, Report, or Work plan Review - other Beach sheen reporting resumed from winter hiatus. Report reviewed 4-3 to 4-16-2023. No sheen reported. Peter Campbell
5/15/2023 Long Term Monitoring Workplan or Report Review Beach sheen report from 4-17 to 4-30-2023. No sheen reported. Peter Campbell
5/25/2023 Long Term Monitoring Workplan or Report Review Beach sheen report from 5-1 to 5-14-2023. No sheen reported. Peter Campbell
5/25/2023 Long Term Monitoring Workplan or Report Review Beach sheen report from 5-1 to 5-14-2023. No sheen reported. Peter Campbell
6/5/2023 Long Term Monitoring Workplan or Report Review Review EPA comments on the 4th Quarter 2022 and 1st Quarter 2023 reports submitted June 5, 2023. Peter Campbell
7/10/2023 Update or Other Action Beach Sheen Report 6.12.23 to 6.25.23 submitted and reviewed. No sheen reported from beach seeps. Iron sheening was reported and investigated. Peter Campbell
7/12/2023 Update or Other Action Review quarterly sample results from the Treated Groundwater Report. All samples for the previous quarter (April, May, June 2023) were below detection limits for water polished by activated carbon and reinjected to the ground. Peter Campbell
7/13/2023 Long Term Monitoring Workplan or Report Review Beach sheen report from 6-26 to 7-9-2023. No sheen reported. Peter Campbell
8/3/2023 Long Term Monitoring Workplan or Report Review Beach Sheen Report 7.10.23 to 7.23.23 reviewed. No sheen reported. Peter Campbell
8/16/2023 Long Term Monitoring Workplan or Report Review Beach Sheen Report 7.24.23 to 8.6.23, no sheen reported. Peter Campbell
8/17/2023 Update or Other Action EPA TECHNICAL REVIEW COMMENTS Quarterly Progress Report No. 23-2 Peter Campbell
8/23/2023 Update or Other Action Review Marathons reply to EPA Response to EPA Tech Review Comments Q 23-2 Peter Campbell
8/24/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 8.7.23 to 8.20.23. No sheen noted. Peter Campbell
9/6/2023 Meeting or Teleconference Held RCRA inspection of the site with EPA representatives Jan Palumbo, Rory O'Rourke and Tong Li. Marathon staff, Trihydro staff and DEC Haswaste staff present. During the meeting it was observed that the water table elevations were approaching unusually high levels, potentially leading to benzene again moving from the upper unconfined aquifer into the highway adjacent wetlands. Benzene has been the only parameter measured in surface water. Marathon was notified that they will be required to monitor for TAH and TAqH in surface water in the wetlands. During the inspection, firefighting foams were observed being stored on site. Discussions led to a historical fire training area on the northwest side of the facility where foams were used. Foam is also stored throughout the facility. A letter will be drafted requiring modified surface water quality monitoring and assessment work for PFAS in soil and groundwater. The EPA is to be copied on communications. Peter Campbell
9/6/2023 Long Term Monitoring Workplan or Report Review 2023 Injection Well Rehabilitation Work Plan 8/2/23 IR-29, IR-30, IR-31, and IR-32 are A-aquifer treated water injection wells installed in 1990. IR-30 stopped accepting water in December 2022, due to iron-fouling. IR-29 has had a steady reduction in flow capacity since June 2023. Decreased well function and eventual failure due to iron fouling is a common problem with recovery wells, injection wells, and air sparge wells at the Refinery. Because iron-fouling is likely occurring in IR-31 and IR-32, rehabilitation is used to extend the functional life of the well. Approve plan at meeting. Peter Campbell
9/12/2023 Workplan Requested DEC requirement for work plan to assess surface water quality and sediment in the Spur Highway wetlands where groundwater merges with surface water during times when groundwater is elevated. DEC has also requested that Marathon assess the site for PFAS contamination. Firefighting foams have been stored and used for fire training at the facility. Peter Campbell
9/13/2023 Long Term Monitoring Workplan or Report Review Beach Sheen Report 8.21 to 9.3.23 - no sheen noted. Peter Campbell
9/22/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 9.4 to 9.17.23. No sheen observed. Peter Campbell
10/2/2023 Document, Report, or Work plan Review - other Review the 2023 3rd quarter Treated Groundwater Injection Permit report. All groundwater is being treated through the Calgon carbon unit. All analytical parameters were below detection limits. Peter Campbell
10/9/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 9.18 to 10.1.23. Barely visible sheen reported on 9/24/2023. No other sheen noted during reporting period. Peter Campbell
10/27/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 10.2 to 10.15.23. No sheen observed. Peter Campbell
11/8/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 10.16 to 10.29.23. No sheen observed. Peter Campbell
11/27/2023 Long Term Monitoring Workplan or Report Review Review Beach Sheen Report 10.30.2023 to 11.8.2023. No sheen noted. This will be the last sheen check for this year as beach conditions can be hazardous. Peter Campbell
12/15/2023 Site Characterization Workplan Approved Review and approve PFAS Investigation Work Plan. Comment on the plan that the investigation derived waste must be characterized and disposed of appropriately. Peter Campbell
1/16/2024 Long Term Monitoring Workplan or Report Review Review the 2023 4th quarter Treated Groundwater Injection Permit report. All groundwater is being treated through the Calgon carbon unit. All analytical parameters were below detection limits. Peter Campbell
2/23/2024 Long Term Monitoring Workplan or Report Review Review and approve Swamp Surface Water and Sediment Sampling Work Plan dated Nov. 16, 2023. Require quarterly sampling of wetlands as discharge to surface water may vary seasonally, especially during high groundwater events. DEC's goal is to determine seasonal concentrations in the long term (4 years +) and highwater concentrations in the short term as events occur. If possible, DEC sees value in collecting samples through the ice. Peter Campbell
2/27/2024 Long Term Monitoring Workplan or Report Review Review Progress Report 23-2. Permit required corrective action system criteria for the SI Area were not met for a majority of the weeks this quarter due to the planned partial AS pilot shutdown of the eastern section (SAS-2 through SAS-10) of the AS system, which was initiated in October of 2022 following the installation of the liquid activated carbon wall. PlumeStop combined with S-Micro Zero Valent Iron (S-MZVI), was injected along a 120 ft transect within the area of highest groundwater impacts to improve the capture and reduce migration of trichloroethene (TCE), vinyl chloride (VC), and benzene contaminated groundwater. The annual plume map of indicator parameters for the SI area shows the TCE plume continues to extend past the AS system to well SMW-35, SMW-36, and SMW-37. Compliance monitoring well SMW-29 measured a TCE concentration below the Target Groundwater Protection Standard (TGPS) at 2.55 µg/L. However, SMW-29 is no longer the downgradient edge of the plume since SMW-36 is consistently above the TGPS. The measured TCE concentration in SMW-36, located downgradient of SMW-29, was above the TGPS at 4.67 µg/L. Although SMW-36 remains above cleanup criteria, concentrations have begun to decrease following the installation of the carbon wall in the fall of 2022. Newly installed monitoring wells SMW-37, cross gradient of SMW-29, displayed a TCE concentration above the TGPS at 4.88 µg/L. Continued monitoring will be performed to assess TCE concentrations at SMW-36 and SMW-37 and the effectiveness of the carbon wall. Well SMW-36, located downgradient of the SI AS treatment zone, TCE concentration remains above the TGPS (4.67 µg/L) with a statistically significant positive trend. TCE exceedances are being addressed by the carbon barrier wall installed upgradient of SMW-36 to reduce the TCE dissolved phase contaminant migration. Benzene concentrations measured in the Swamp and groundwater immediately south of the Swamp (e.g., E-247A and E-248A, Figure 3A) were elevated in Q23-2 (Figure 3A). Lack of access to water level monitoring locations due to large snowpack and cold temperatures causing thick ice in the swamp, water levels could not be measured in Q23-2. As typical in winter months, benzene concentrations increased across the swamp surface water samples due to the cold temperatures and thick ice buildup. This likely minimized physical and biological attenuation of benzene from the surface water. Elevated benzene concentrations in Q23-2 are consistent with previous observations of weaker attenuation of benzene in surface water when the Swamp is capped by ice. Despite the increase in benzene concentrations versus Q22-4, benzene concentrations are lower than previous spring historical Swamp concentrations (e.g., Q15-2). SW-06 was the only swamp location that was unable to be sampled in Q23-2 due to ice thickness. Swamp surface water sampling results for benzene are displayed in Appendix B2. Benzene concentrations in the samples were above TGPS at all Swamp sample locations. Peter Campbell

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