| Action Date |
Action |
Description |
DEC Staff |
| 12/2/1946 |
Update or Other Action |
NWS and its predecessor agencies, including the Weather Bureau, have operated portions of the current station since at least 1946, when the Weather Bureau accepted the property from the U.S. Coast Guard, the former site operator. Additional portions of the facility were transferred from the U.S. Coast Guard to the Weather Bureau in 1949, 1950, and 1960. The station heating boilers have been fueled with arctic diesel fuel stored in USTs and ASTs since before NWS received the property from the U.S. Coast Guard. The AST was supplied by a fuel tank farm at the current U.S. Coast Guard facility located north of and across Airport Road from the NWS station.
The AST in turn supplied the USTs with fuel. The pipelines between the storage tanks and the U.S. Coast Guard facility were reportedly removed, although dates and observations made during the pipeline removal could not be obtained. The AST and USTs were removed from the site concurrent with waste trench investigative activities, and the removal is documented in a separate report. The station and adjacent buildings currently are heated with arctic diesel stored in skid-mounted, concrete, vaulted ASTs that were installed in 1994. These ASTs are located next to the buildings they serve.
The 10,000-gallon AST was reportedly taken out of service in 1994. Dates of service of the three USTs are not known. The station and adjacent buildings currently are heated with arctic diesel stored in skid-mounted, concrete, vaulted ASTs that were installed in 1994. These ASTs are located next to the buildings they serve. |
Louis Howard |
| 12/30/1966 |
Update or Other Action |
Weather Bureau Master Plan, Weather Bureau Pipeline shows 2 above-ground storge tanks (ASTs) and 1 underground storage tank (UST) on Subject Property. Tank locations are southwest of Quarters. Pipe connects tanks to 7 fuel storage tanks at the US Coast Guard facility, approximately 6,900 feet to the northwest. |
Louis Howard |
| 12/31/1970 |
Update or Other Action |
Weather Bureau Housing Site Plan shows three 9000 gal. underground storage tanks (USTs) closed-in-place, and one 10,000 gal. above-ground storage tank (AST). The AST is connected to the two houses by an oil line. Three septic tanks are shown, one for each of the two houses and one for the Quarters.
All are drawn connected to leach fields. No City water connection is shown. The well is shown connected to the various buildings by a series of water lines. An abandoned 2" water supply line leads south from the Quarters (toward Pumphouse Lake). Transite (an asbestos-containing material) is shown as a construction material. A transformer is present west of the Quarters. |
Louis Howard |
| 12/28/1973 |
Update or Other Action |
Weather Bureau documents suggest connection of the City water supply to the facility. |
Louis Howard |
| 12/31/1975 |
Update or Other Action |
Weather Bureau Layout Diagram shows fuel transfer line and one fuel storage tank at previous location. Fuel oil lines also shown running from tank to House #1, House #2, and Quarters. Two septic tanks are shown; one southeast of Quarters, and one southeast of House #1. The latter also appears to be connected to House #2. City water is shown connected to the Warehouse, which contains a water storage tank.
A water line runs from the tank to the NWS well south of the Quarters. Water lines connect the NWS well to the Quarters, and the Quarters to Houses #1 and
#2. A transformer is present west of the Quarters. |
Louis Howard |
| 1/3/1983 |
Update or Other Action |
National Weather Service Site Plan shows the addition of a spill dike around the 10,000 gal. aboveground storage tank (AST). The AST is connected to the two houses by a fuel transfer line. Three septic tanks and leach fields are shown; one for each of the two houses and one for the Quarters. All are connected to leach fields.
The site is connected to City water. The well is shown, together with a water line extending south from the Quarters past the houses. Transite (an asbestos-containing material) is shown as a construction material. A transformer is present west of the Quarters. |
Louis Howard |
| 8/30/1985 |
Update or Other Action |
Department of Defense Report notes Site F: "Quonset Ruins Near Airport.” Old pumps and other nearby debris were apparently part of the St. Paul water supply and are not DOD material. |
Louis Howard |
| 12/1/1992 |
Update or Other Action |
National Weather Service Project initiated to replace underground fuel lines and remove an existing line. File photos show details of AST and piping, and transformer. A photo of the
south wall of the Quarters building shows a UST vent pipe that is not correlated with any of the UST positions or pipings on any of the site plans. |
Louis Howard |
| 12/31/1992 |
Update or Other Action |
Weather Bureau Layout Diagram shows one fuel storage tank at previous location. The Coast Guard transfer pipe is not shown. Fuel oil lines also shown running from tank to House #1 House #2, and Quarters. The same septic tanks are shown as in the 1975 diagram. The septic tank near the quarters is now shown with a leach field. City water is connected to the Warehouse, which contains two water storage tanks. A water line runs from the tank to the NWS well south of the Quarters. Water lines connect the NWS well to the Quarters, and the Quarters to Houses #1 and #2. A transformer is present west of the Quarters. |
Louis Howard |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment (PA) conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterizaton, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV).
An approximate 6 feet deep open cesspool is located west of the NOAA building. A trench extended from the building approximately 10 feet west and then turned north for approximately 10 feet. Cesspool is located at the end of the trench. The cesspool was subsequently covered in late October/early November 1992 with soil over a plywood cover. This is a temporary measure with plans to convert this septic system and connect it to the City's sewer system sometime in summer of 1993. Recommendation: determine the extent of potential biological contamination. |
Jennifer Roberts |
| 11/2/1994 |
CERCLA PA |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
RCRA ID AK0131490021 CESQG CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate accordingly.
EPA's NFRAP designation will NOT relieve NOAA from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket.
NOTE To file: SEC. 120. FEDERAL FACILITIES.(a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.—
(1) IN GENERAL.—Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act.
Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107.
(2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.—
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act.
(3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility
which is owned or operated by any department, agency, or instrumentality of the United States.
(4) STATE LAWS.—State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) when such facilities are not included
on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. |
Jennifer Roberts |
| 9/15/1997 |
Site Visit |
National Oceanic & Atmospheric Administration Site inspection reveals a leaking oil drum and a debris trench on the Subject Property. Heavily stained soil is present around the leaking drum. |
Louis Howard |
| 9/30/1999 |
Update or Other Action |
Draft Work Plan Solid Waste Trench Investigation and Fuel Tank Closure National Weather Service Station, St. Paul Island, Alaska Contract No. 50WCNA906018, Modification No. 56WCNA901101 Tetra Tech Task Order No. 27 submitted by TetraTech to NOAA (T. M. Trinh). Activities include several objectives have been identified for the project, including: Remove waste and petroleum-contaminated soil (PCS) (if encountered) from the solid waste trench located east of the NWS office. Remove one, 10-000-gallon, AST that formerly stored arctic diesel fuel used for residential heating purposes. Remove three 1,000-gallon (estimated) USTs that formerly stored arctic diesel fuel used for residential heating purposes. Collect soil and groundwater (if encountered) samples using a Geoprobe®, hand augers, or other means to determine whether waste management or fuel storage activities at the above areas of potential concern have impacted underlying soils. Collect groundwater samples from the former water supply well (if it can be located) and permanently abandon the well.
See site file for additional information. |
Louis Howard |
| 10/15/1999 |
Site Added to Database |
Diesel fuel (home heating fuel). Overfills apparent at three 3,000 gallon underground storage tanks removed in 1999. One 500 gallon UST on site. Staining present on ground and an unpermitted solid waste disposal site. |
Louis Howard |
| 10/25/1999 |
Site Ranked Using the AHRM |
Site Ranked. Drinking water well smelled of diesel fuel so residents stopped using it. Alternative water supply piped in to building from another source. |
Louis Howard |
| 3/24/2000 |
Update or Other Action |
Final FUEL STORAGE TANK REMOVAL REPORT received for the National Weather Service Station.
The NWS station at St. Paul, Alaska, currently consists of two large operational buildings containing office space, a garage, a warehouse, & staff quarters. NWS uses three small houses located south of the NWS office as additional staff quarters. Other small outbuildings include a hydrogen generator building & a formerly used weather balloon inflation building.
Under Contract No. 50WCNA906018, Tetra Tech EM, Inc. (Tetra Tech), received Contract Modification No. 56WCNA901101 (Tetra Tech Task Order No. 27) from the National Oceanic & Atmospheric Administration (NOAA). This task order calls for Tetra Tech to oversee the removal of one aboveground storage tank (AST) & three underground storage tanks (UST) from the National Weather Service (NWS) station in St. Paul, Alaska. Specific Activities described by the statement of work (SOW) dated September 13, 1999, include removing one inactive, 10,000-gallon, arctic diesel fuel AST & three inactive, arctic diesel fuel USTs. All four of these tanks are considered by the Alaska Department of Environmental Conservation (ADEC) to be unregulated.
Tetra Tech subcontractor Bering Sea Eccotech, Inc. (BSE), performed the heavy equipment-related field activities, including tank excavation, demolition, soil stockpile cell construction, & site restoration. Field activities commenced on October 6 & were completed on October 21, 1999. This removal report is part of the documentation required by the SOW & substantively meets reporting requirements outlined at 18 AAC 75 & 78 pertaining to releases of oil & hazardous substances. Because site closure cannot be sought at this time, this report may not meet all requirements of those regulations.
File reviews conducted at NOAA & NWS did not reveal any environmental investigations previously conducted at the site. However, when the AST was taken out of service in 1994, the fuel pipelines between the AST & the buildings were removed. Where pipeline removal was not feasible because of the presence of building foundations or other structural features, the lines reportedly were drained, cut, & plugged near the building foundations. No documentation of these activities was available during this report’s preparation.
Groundwater was encountered in one borehole at 10 feet bgs about 50 feet east of the AST. However, it could not be sampled because of limited recovery. An abandoned facility water well, located east of the UST excavation, could not be located. Therefore, assessment activities were insufficient to determine whether or not petroleum releases associated with the UST & AST have affected groundwater quality at the site.
Based on current site information, PCS remains in the area between the UST excavation & the AST trench. The depth of the PCS is not known. However, assuming that PCS is continuous to a depth of 8 feet bgs, the remaining volume under the AST is about 430 yd3. This volume estimate was based on the dimensions of the AST containment area of 35 by 50 feet & the calculated volume of PCS removed from the trench (89 yd3).
In addition, the extent of soil contamination north of the USTs has not been characterized. Because electrical lines & a transformer are located immediately north of the UST excavation, Tetra Tech did not install Geoprobe® boreholes in this area. The extent of contamination around the former AST also has not been delineated. Tetra Tech initially planned to install up to four boreholes at the NWS site, three as part of a separate project & one as part of the groundwater sampling effort. After Tetra Tech identified evidence of a release at the site, NOAA requested that Tetra Tech install additional boreholes to delineate the horizontal & vertical extent of contamination. With the available Geoprobe® consumable sampling tools, Tetra Tech was able to install a total of 13 boreholes, but was unable to delineate the extent of contamination.
Tetra Tech was unable to characterize the horizontal & vertical extent of contamination within the scope of the task order. NOAA should therefore expand the scope of the site investigation to evaluate the extent of DRO contamination above cleanup levels. With ADEC approval, NOAA should consider conducting a limited trenching investigation around the contaminated areas in an attempt to reach the bounds of contamination. To reduce analytical costs, ADEC-approved field screening techniques should be proposed.
For additional information see site file. |
Louis Howard |
| 4/21/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on a draft Fuel Tank Removal Report for NWS AST/USTs removal.
This report is not a site characterization report as defined by 18 AAC 75.335 Site Characterization. The document is more equivalent to a site assessment report, which determines the presence or absence of contamination and not necessarily the vertical and horizontal extent of contamination. Please refer to the following requirements under 18 AAC 75.335, which requires NOAA to submit a workplan for site characterization.
18 AAC 75.335. SITE CHARACTERIZATION. (a) Before proceeding with site cleanup under the site cleanup rules, a responsible person (NOAA) shall characterize the extent of hazardous substance contamination at the site.
After completing site characterization work, the responsible person (NOAA) shall submit to the DEC for approval a site characterization report that
(1) is prepared by a qualified person;
(2) sets out the information obtained from activities performed in accordance with a site characterization workplan;
(3) sets out the results of sampling and analysis;
(4) demonstrates that the inspections, sampling, and analysis performed adequately characterize the extent of hazardous substance contamination; and
(5) proposes cleanup techniques for the site.
(d) DEC will approve the report submitted under (c) of this section if DEC determines that the work described in the report and the cleanup techniques proposed are protective of human health, safety, and welfare, and of the environment. DEC will, as part of its approval, modify proposed cleanup techniques or require additional cleanup techniques for the site as DEC determines to be necessary to protect human health, safety, and welfare, and the environment.
1.2 Applicable Regulations Page 2
The text states that above-ground storage tanks (ASTs) are not regulated by DEC if less than 420,000 gallons. This statement is not entirely true, please refer to the following applicable regulations:
18 AAC 75.300 DISCHARGE OR RELEASE NOTIFICATION; REPORTING REQUIREMENTS. (a) Subject to (b) of this section, a person in charge of a facility or operation (NOAA) shall notify DEC by telephone, and immediately afterwards send DEC written notice by facsimile, hand delivery, or first class mail, informing DEC about a discharge or release of a hazardous substance at or from the facility or operation ("hazardous substance" means (A) an element or compound which, when it enters into the atmosphere or in or upon the water or surface or subsurface land of the state, presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, animals, vegetation, or any part of the natural habitat in which they are found; (B) oil; or (C) a substance defined as a hazardous substance under 42 U.S.C. 9601(14);
"oil" means oil of any kind and in any form, whether crude, refined, or a petroleum by-product, including but not limited to petroleum, fuel oil, gasoline, lubricating oils, oily sludge, oil refuse, oil mixed with other wastes, crude oils, liquefied natural gas, propane, butane, or other liquid hydrocarbons regardless of specific gravity;)
Groundwater was detected in a ten foot boring but did not develop enough water to collect a sample. It is unknown whether or not groundwater has been impacted by releases at the site.
9.0 Recommendations Page 16
The text states that NOAA should consider implementing an in-situ remedy such as monitored natural attenuation, bioaugmentation, soil vapor extraction, or bioventing. Prior to considering such remedies, NOAA must delineate the horizontal and vertical extent of contamination at the site as well as determining the extent of groundwater contamination. DEC is requesting NOAA submit a site investigation workplan be submitted for its review and comment prior to fieldwork commencing at the site. The workplan will need to be submitted to allow for a 60 day review period (30 days draft-DEC, 15 days-NOAA rewrite draft-final, and 15 days-DEC review of draft final and subsequent approval). Please respond in writing no later than 30 days after receipt of this letter as to what specific actions NOAA plans to take to address the issues raised in this letter. |
Louis Howard |
| 6/15/2000 |
Update or Other Action |
NOAA proposed to conduct three activities at the NWS Site to prepare for site characterization.
1) Remove the pump and clear the well shaft in the abandoned drinking water well,
2) reconstruct the wellhead of the abandoned drinking water well with a permanent completion at current ground level, and
3) inspect and open piping around the suspected underground storage tank (UST) to determine presence/absence and current contents. NOAA also proposed to remove a potential tripping hazard associated with the abandoned drinking water well. The excavation was apparently constructed last summer in an attempt to locate the well. |
Louis Howard |
| 7/10/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft site characterization plan. 3.3 Potential Source Characterization Page 9
The text states that any pipe runs encountered during this investigation will be located by conductive tracing & limited h& excavation may be required to document details of the piping. Please be aware that 18 AAC 78.085(c) requires all piping be removed that is associated with an underground storage tank (UST).
To permanently close a UST, NOAA shall empty & clean it by removing all liquids & accumulated sludge. A UST that is to be closed must be removed from the ground, along with all associated piping, or must be filled with an inert solid material. A UST associated with a known release must be removed from the ground unless DEC allows the tank to remain in place because removal of the tank would endanger existing structures. The resulting excavation must be investigated & corrective action completed as required by 18 AAC 78.230 - 18 AAC 78.280 & 18 AAC 78.600 - 18 AAC 78.625. NOAA shall document the name of the disposal firm, the disposal method, & the disposal location for all liquids, sludges, & UST components, including tanks, piping, & equip¬ment.
In addition to the above requirements, NOAA must conduct a site characterization in accordance with 18 AAC 78.090 Site Characterization & Assessment. The site assessment must include the collection of soil samples; the number & location of samples collected is determined as follows:
(A) for an in-place assessment
(i) of an individual tank that occupies a surface area less than 250 square feet, at least two borings or test pits must be placed within five feet of the tank, each at the midpoint along two sides of an imaginary rectangle drawn around the tank, with one of the borings or pits located on the side parallel to the end of the tank that has the fill point & the second boring or pit located on the side parallel to the length of the tank where contamination is most likely to be present, as determined by field screening conducted as required by the UST Procedures Manual (eff. Dec. 1, 1999);
(ii) of an individual tank that occupies a surface area equal to or greater than 250 square feet, at least two borings or test pits must be placed within five feet of the tank, as required under (i) of this subparagraph; one additional sample must be collected for each additional 250 square feet of surface area, or portion thereof over the initial 250 square feet, at points where contamination is most likely to be present, as determined by field screening conducted as required by the UST Procedures Manual; for example, if the total surface area is 1,270 square feet, five additional samples are required;
(iii) of multiple tanks, the borings or test pits for each tank must be placed according to (i) or (ii) of this subparagraph, as applicable; the same boring or test pit may be used to satisfy the requirements applicable to more than one tank, if that boring or test pit meets the requirements for each tank separately;
(iv) of dispensing areas, at least one boring or test pit must be placed adjacent to any UST dispensing equip¬ment; if multiple dispensers exist on a common dispensing isl&, then one boring or test pit may be placed at the midpoint between the dispensers; if multiple dispensing isl&s exist, then additional borings or test pits are required at each isl&; if a canopy exists in a configuration that prevents excavating or boring equipment from operating adjacent to the dispensers or dispenser isl&s, samples may be collected as close as possible to the dispenser isl&s;
(v) of in-place piping, at least one boring or test pit must be placed adjacent to the piping at points where contamination is most likely to be present, as determined by field screening conducted as required by the UST Procedures Manual;
(vi) soil samples for assessments under this subparagraph must be collected from each boring or test pit at an elevation that is below, & within two feet of, the tank bottom & that is within two feet below the lowest point of the piping for the UST dispensing equipment; &
(vii) in this subparagraph, “surface area” is the sum of the tank length plus five feet multiplied by the sum of the tank diameter, or width for square tanks, plus five feet.
For assessment of a closure by removal, NOAA must perform the following in accordance with 18 AAC 78.090:
For additional information see site file.
|
Louis Howard |
| 10/25/2000 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Solid Waste Trench and Fuel tank workplan for the NWS Station, Saint Paul Island dated October 18, 2000. Staff stated that the tank will be considered regulated for investigation and cleanup under 18 AAC 75 if there is any release (past or present) of petroleum from the tank due to leaks, overfills, or spills to lands or waters of the State. Staff requested the Master Quality Plan (att. 2) serve as the primary sampling plan for this investigation.
Alternatively, NOAA may modify its Att. 1 SOP to mirror Att. 2 with regards to: data quality objectives, sampling objectives, and locations, sampling procedures and equipment, field quality control and analytical procedures. ADEC's Solid Waste Program will have to approve the disposal of the estimated 170 cubic yards of waste removed from the NWS solid waste trench into the current city dump. |
Louis Howard |
| 11/2/2000 |
Document, Report, or Work plan Review - other |
Letter to NOAA regarding NWS solid waste disposal to Saint Paul landfill. After further discussions with the solid waste staff, ADEC has no objection to NOAA disposing of the estimated 170 cubic yards of solid waste from this site into the City of Saint Paul's Landfill.
Of course prior concurrence and payment of any tipping fee that is required by the City would be necessary before NOAA may dispose of their debris into the Landfill. ADEC requests NOAA provide written documentation on the amount of debris that was excavated and disposed of into the landfill in the subsequent report generated for this site. |
Louis Howard |
| 11/16/2000 |
Update or Other Action |
Charles Hostetler (contractor for NOAA) reported on NOAA Regional Environmental Compliance program that the last UST has released diesel fuel to the lands of the State. Suspect that release from 500 gallon UST has been due to chronic and historic overfills. Tank had no holes or corrosion or visible staining on it, piping was tight and all connections had no releases associated with them. 50 gallons of oil water mix recovered and awaits further analysis prior to disposal at the enhanced thermal conduction system (ETC). Soil stockpiled and segregated at the ETC area prior to disposal since lab results are not back yet. Cannot dig any further north since the foundation of the NWS quarters would be impacted severely if excavation were to continue. Also excavation depth was reached due to basalt stopping excavation. |
Louis Howard |
| 1/31/2002 |
Update or Other Action |
Site Characterization Report (Draft) received. The four known source areas were: three 3,000-gal. USTs removed by Tetra Tech EM, Inc. in 1999 & one 10,000-gal. AST removed by Tetra Tech EM, Inc. in 1999.
The suspected potential source area identified in the SCP was confirmed during the NWS 2000 field reconnaissance. The suspected source area was identified as a 500-gal. heating oil UST located adjacent to the south side of the NWS staff quarters building. The UST was excavated & removed.
Free-product was observed in the excavation. Free Product Release from the North Wall of the UST Excavation. The free product began to flow shortly after BSE removed the UST, & continued for approximately half an hour.
Of the 44 observations of the PQL, 96% of the data met or exceeded the ADEC requirements. The 4% of the data that did not meet the requirements are the result of sample dilutions required to analyze highly contaminated samples. Diluting concentrated samples for analysis is required by the analytical methods & raises the PQL by the same dilution factor. Dilution was the result of very high concentrations of DRO in the samples.
Approximately 87% of the analyses met or exceeded the ADEC standards for accuracy. The 13% of the data that did not meet the accuracy DQO was caused by the occasional low recoveries of surrogate analytes.
DRO & RRO were detected above the PQL & are COPCs in soil. GRO was detected in soil 15% of the time over a range of 2 to 40 mg/kg. DRO was detected in 71% of the soil samples including those collected from the decommissioning of the 500-gal. UST & Tetra Tech EM, Inc.’s samples from 1999.
DRO concentrations ranged from 13 to 25,000 mg/kg [Note MAC is 12,500 mg/kg).
2-Methylnaphthalene was detected up to 43 mg/kg (cleanup level is 6.1 mg/kg migr-GW) & Naphthalene was found up to 23 mg/kg (cleanup level is 20 mg/kg migr-GW).
RRO levels ranged from 53 to 970 mg/kg.
DRO was detected at 9700 µg/L [note this is above the solubility limit for DRO]. The lateral extent of contamination is unknown at this time.
Distribution of DRO in subarea A: The estimated area impacted by DRO levels exceeding the ADEC screening level (250 mg/kg) is 14,000 ft2. Distribution of DRO in subarea B-The area in which DRO levels exceeded the ADEC screening level includes the bottom, north, west, & south walls of the UST excavation. The highest DRO exists along the north wall where field personnel noted heavily contaminated soils beneath the NWS Staff Quarters building foundation. The estimated area impacted by DRO levels exceeding the ADEC screening level is 90 ft2.
The subsurface of the study area is characterized by:
• unconsolidated sands & mud overlying flow basalt.
• GW occurs in perched conditions at a elevation of 10 to 15 ft above MLLW & in an unconfined aquifer at a elevation of 3 to 6 ft above MLLW.
• GW flow in the unconfined aquifer is to the north, & is influenced by recharge from the large fresh water lake located to the south.
• chloride levels (estimated from measured electrical conductivity values) in GW are just below the drinking water standards & taste thresholds.
The nature of contamination in the study area is characterized by:
• sources of contamination are the USTs, ASTs, & fuel-transfer piping; all storage tanks which contributed to the contamination have been removed.
• the primary COC in soil & GW in both subareas is DRO.
The extent of contamination is characterized by:
• DRO soil contamination is present above the ADEC Method 3 cleanup level for subarea A over an estimated area of 14,000 ft2 at an estimated volume of 9200 yd3.
• DRO soil contamination is present above the ADEC Method 1 cleanup level for subarea B over an estimated area of 90 ft2 at an estimated volume of 27 yd3.
• The primary contaminants for GW (DRO & benzene) are below the ADEC 10X rule cleanup levels, therefore no GW cleanup action is required. (NOTE Current 18 AAC 75 regulations (as of 2009) no longer includes a 10X rule cleanup level)
The following recommendations were made for remedial alternatives for contaminated soils in the study area: No further action (natural attenuation) is the recommended approach for contaminated soils associated with subareas A & B. |
Louis Howard |
| 7/30/2004 |
Update or Other Action |
In 2004 (Tetra Tech EM, Inc. Boring Log for Borehole ID/Well ID: NWS-2), monitoring well MWNWS-2 was installed by NOAA approximately 150 feet north of the NWS Composite Building. This well was intended as a clean sentinel well downgradient of the NWS Site source area; however, 6 inches of NAPL was measured in the well (as noted on the boring log after installation and no water samples were collected. Soil samples were not collected during the 2004 installation of monitoring well MWNWS-2. |
Louis Howard |
| 9/21/2007 |
Enforcement Action |
Staff sent letter to NOAA informing NOAA of failing to adequately address the discharge or release of petroleum product associated with the National Weather Service Building on St. Paul Island. NOAA has not followed through with the recommendations to delineate the extent of contamination present at the site (see Fuel Storage Tank Removal Report dated March, 24, 2000 under contract# 50WCNA906018 Modification# 56WCNA901101).
Subsequent to the 2000 investigation, NOAA staff involved with the “Two-Party Agreement” cleanup on the Pribilof Islands had a contractor install a groundwater monitoring well on National Weather Service property. It was at this time that free product was encountered and to date, NOAA has not addressed the free product at the site.
This letter is to formally notify NOAA it is not complying with AS 46.03.710 (Pollution of the Air, Land, Subsurface Land or Water of the State Prohibited), and AS 46.03.740 (Discharge of Petroleum or Petroleum Products without a Permit Prohibited) and associated regulations. According to AS 46.04.020 (a) (removal of Oil Discharges), a person causing or permitting the discharge of oil shall immediately contain and cleanup the discharge.
According to AS 46.04.020 (b) the containment and cleanup activities must be carried out in a manner approved by ADEC. All work plans must be approved by ADEC prior to any further sampling, clean-up or disposal activities. ADEC requests NOAA submit a site characterization work plan prepared by a qualified person , to properly characterize the horizontal and vertical extent of contamination and address the free product present at the Weather Service Building on St. Paul for ADEC review and comment.
ADEC specifically reserves the right to require additional assessment or cleanup activities as information is developed during the course of the site evaluation and cleanup. ADEC specifically reserves the right to take further action as provided for in Title 46 of the Alaska Statutes. Additionally, ADEC reserves all its rights to pursue any and all other responsible parties involved in this incident.
18 AAC 75.325(f) states: A responsible person shall
(1) to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that
(i) minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions;
(ii) avoids additional discharge; and
(iii) disposes of the recovered free product in compliance with applicable local, state, and federal requirements;
(C) complete cleanup in a period of time that the ADEC determines to be protective of human health, safety, and welfare, and of the environment;
(D) prevent, eliminate, or minimize potential adverse impacts to human health, safety, and welfare, and to the environment, onsite and offsite, from any hazardous substance remaining at the site; and
(E) evaluate and perform a cleanup of surface soil staining attributable to a hazardous substance;
(2) meet the applicable cleanup levels determined under 18 AAC 75.340 -18 AAC 75.350; and
(3) provide for long-term care and management of a site as required under the site cleanup rules, including proper operation and maintenance of
(A) cleanup techniques and equipment;
(B) monitoring wells and equipment, if required; and
(C) institutional controls, if required under 18 AAC 75.375
The responsibility for the investigation and cleanup of hazardous substance contamination is established by state law. State law requires ADEC to recover the costs associated with our oversight work from the responsible party/parties (AS 46.03.010 and AS 46.08.070).
ADEC staff already have a cost recovery code for previous NOAA compliance program oversight on the Pribilof Islands which will be used for cost recovery purposes (CC 18526001 and LC 14906270) unless otherwise indicated by NOAA. Expenses for which ADEC may seek reimbursement include: staff time associated with general or technical assistance; work plan review; project oversight; general project management; legal services; interest; travel; equipment and supplies; and any contracting costs.
Please respond in writing within thirty (30) days from receipt of this letter as to what NOAA’s intentions are to adequately characterize the site and recovery of any free product. Please use the file number and contaminated sites database record key number associated with this site in all correspondence to the department. |
Louis Howard |
| 10/25/2007 |
Update or Other Action |
October 25, 2007 ADEC receives the NOAA (SECO ECD) sent a response letter regarding ADEC's letter Dated September 21,2007 (File: 2644.38.004, CS Database Reckey #1999250128001.
The referenced letter requested that NOAA provide its intentions to adequately characterize the St. Paul Island NWS property, herein referenced as 'site', with regard to the release of petroleum product and to address the recovery of any discovered free product.
For site characterization, NOAA has completed a Statement of Work (SOW) which includes the repair andlor development of two existing groundwater monitoring wells, and the installation and development of six (6) additional monitoring wells in the area of the former release of petroleum product. The SOW also requires that the contractor strategically position the wells and prepare a site characterization work plan, to be reviewed and approved in writing by NOAA and ADEC, prior to beginning any field activities.
To characterize the migration pathways and extent of petroleum contamination of soil and groundwater, the site characterization will include the collection and laboratory analyses of soil and groundwater samples. A groundwater sample will be collected and analyzed from each well. Soil samples will be collected at various locations and depths while advancing monitoring well boreholes. The samples will then be field screened, and those with the greatest potential for petroleum contamination will undergo further laboratory analyses.
After the field work is complete, the SOW requires that the contractor prepare a site investigation report which will provide discussions on the collected field data, observations, and analytical results from the site characterization study. The report will include a summary of findings and conclusions, and recommend remedial actions for recovery of free petroleum product. Based on the report recommendations, NOAA will make a detennination as to the next appropriate course of action, and notify ADEC of its intent.
On October 1, like most Government agencies, NOAA entered into a new fiscal year and is presently operating under a continuing resolution (CR). During a CR, money is scarce, and new project proposals will not be funded until Congress passes a budget to operate the Department of Commerce (DOC) and its agencies, NOAA included. Upper management within the NOAA Office of the Chief Administrative Officer (OCAO) is aware ofthe need to move forward with the project to further characterize the St. Paul Island NWS property, with regard to the release of petroleum product, and plans to fund this effort this FY contingent upon Congress passing DOC's budget. For reimbursable ADEC expenses, use the existing NOAA supplied cost recovery code for this project until further notice.
Signed Mark George P.E. Environmental Engineer. |
Louis Howard |
| 10/29/2007 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Program has received NOAA’s letter notifying ADEC of its intentions to conduct a site characterization at the National Weather Service property on St. Paul Island (referred as the “site”). This action is contingent upon a budget being passed for the Department of Commerce. The approach outlined in your agency’s letter of October 18, 2007 is acceptable to ADEC. |
Louis Howard |
| 2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
| 8/28/2009 |
Update or Other Action |
NWS Site Evaluation. A data review and assessment of past activities, as well as recommendations for future site activities at the National Weather Service (NWS) Site, Saint Paul Island, Alaska are addressed in this report. A comprehensive assessment of site investigation data, past remedial actions and facility historical uses has been completed. The results of these assessments have identified the following:
Contamination at the NWS Site is the result of releases of arctic diesel from both
aboveground and underground storage tanks (ASTs and USTs), as well as associated fuel pipmg.
The soil source area is defined in two areas: one near the former 10,000 gallon AST and three 5,000 gallon USTs (Subarea A) and the second near the former 500-gallon UST (Subarea B) just south of the NWS Building.
Approximately 221 cubic yards of impacted soil were removed from Subarea A (Tetra Tech, 2000) and approximately 35 cubic yards of impacted soil were removed from Subarea B during tank closure activities (BSE, 2001).
Diesel-range organic (DRO) compounds are the primary contaminant of concern (COC), with soil and groundwater concentrations exceeding Alaska Department of Environmental Conservation (ADEC) cleanup levels.
Current site data collected to date does not fully delineate the extent of soil and dissolved-phase groundwater contamination at the site, or the extent of non-aqueous phase liquid (NAPL) on the groundwater beneath the site.
Based on the evaluation of existing site data and conditions, and complying with current ADEC cleanup criteria, the following site investigation activities are recommended:
Installation of approximately nine monitoring wells and eight soil borings to improve the understanding of contaminant distribution in soil and groundwater at the site
Perform NAPL (product) drawdown tests to determine the formation thickness and potential recoverability of NAPL at the site.
This additional field data, along with past data collected from the NWS Site, will allow NOAA to more accurately depict current site conditions and pursue closure options with the ADEC.
Site data collected to date has been used to evaluate the extent and magnitude of soil and groundwater contamination at the site. The existing site data is believed to reasonably delineate the horizontal extent of soil contamination in the vicinity of the former AST and three USTs, which comprised the central fuel storage and distribution location at the site, and at the UST adjacent to the south side of the NWS Building. The existing site data does not delineate the vertical extent of soil contamination due to the limited depths (10 to 15 feet bgs) of the borings or the extent of groundwater impact due to the presence of only two monitoring wells at the site, both of which contained measurable thicknesses of NAPL.
While releases from the fuel storage tanks are likely the primary source of contamination at the site, secondary sources include the fuel distribution piping that conveyed fuel from the Coast Guard base to the centrally located 10,000-gallon AST and USTs and the fuel distribution piping that conveyed fuel from the centrally located tanks to the fuel storage tanks at the NWS Building and the two Quarters Buildings to the south.
The data sources reviewed for this report do not fully assess the presence or extent of potential soil contamination associated with this fuel distribution piping. As previously mentioned in this report, portions of these pipelines were reportedly removed in 1994, but no documentation of this work is available. Subsequent pipeline removal activities in 1999 and 2000 (Tetra Tech, 2000 and CESI, 2002) are not well documented and were not supported by field screening and/or analytical testing along the pipeline routes. It was noted in the Tetra Tech and CESI reports that the presence of buried utilities limited any investigation along the pipeline route near the NWS site.
New data collected since the CESI report include the installation of monitoring well MWNWS-2, the measurement of free product in wells MWNWS-1 and MWNWS-2 by Bethel Services in October 2008, and fuel analysis from these two wells by Bethel Services in November 2008. The new data indicates that site conditions are different than interpreted by CESI. As discussed in Section 2.3, there are eight general criteria that have to be met in order to achieve closure at a site. Based on the review of existing field activities and data collected at the NWS Site, the following was determined for each of the criteria:
1. Free product must be adequately addressed - Free product has been observed and measured in two of the wells installed at the site. The extent of free product at the site or the practicability of pumping out the free product has not been determined.
For additional information see site file. |
Louis Howard |
| 11/22/2010 |
Update or Other Action |
Site Characterization WP received. Approximately 18 soil borings (with about 9 to be completed as MWs) will be advanced/installed in an attempt to delineate the soil & GW contamination plume. The locations of MWs will be described in the following section. The remaining borings will be located along the former fuel distribution pipeline that lead from the USCG station to the former AST & USTs, then to each structure at the site.
The westernmost of these borings will be advanced approximately 40’ SW of the Inflation Bldg. The easternmost boring will be advanced approximately between, but slightly N of the Quarters bldngs. The remaining borings will trace the line that linked these 2 locations, approximately equally spaced from one another. Exact locations of boreholes will be determined during the site characterization based on field-screening, site observations, & access. The collection & interpretation of field data may alter boring/well locations.
Boreholes not intended to be completed as monitoring wells will be advanced until GW is encountered, to observe either the presence or absence of NAPL on the GW interface. The boreholes intended to be completed as MWs will extend to a depth of approximately 5’ below the GW interface. Headspace field-screening samples & analytical samples will be collected at 2.5-foot intervals until GW is reached, however, only selected samples will be submitted for chemical analysis based on field-screening & visual/olfactory observations of the soil.
Approximately 2 analytical soil samples will be submitted from each borehole. If field-screening indicates that all samples obtained from a borehole are negative for contamination, then at a minimum, 1 sample will be collected from the smear zone to be submitted for analysis. If contamination is observed, the sample with the highest headspace field-screening result & the sample from the smear zone will be submitted to the laboratory. Attempts will be made to recover samples from the weathered basalt layer, but equipment limitations & lack of material of appropriate grain size may prevent capturing discrete undisturbed "soil" samples. If this occurs, & if possible, headspace field-screening will continue in order to obtain data for qualitative assessment.
One of the MWs will be advanced at the location of the former UST on the south side of the NWS Office to assess GW contamination directly beneath this potential source. One well will be positioned approximately between & equidistant from existing Wells MWNWS-1 & MWNWS-2 to ascertain whether the NAPL observed in these wells is contiguous, or isolated from one another. The optimal location of downgradient MWs (approximately 4 wells) will be near the perimeter of the GW contamination plume, defined as the current DRO cleanup level of 1.5 mg/L. These wells will also be located approximately equidistant from one another in order to sufficiently characterize the site.
In 2008 approximately 1' of free product was measured in the 2 site wells. If feasible, recovering product floating on the site’s water table may significantly reduce the secondary source impacts that the product has on the site’s GW. In turn, concentrations of DRO in the site’s GW would likely decrease more rapidly after NAPL has been recovered from the site. Product recoverability will be assessed by estimating the volume of NAPL at the site, conducting product drawdown tests in multiple wells, & measuring changes in water table elevations using a pressure transducer & data logger. Measurements will be recorded in a field log book.
The NWS Composite building is occupied by a year-round, full-time staff, & is outfitted with living quarters on its 2nd fl. The Inflation building/warehouse complex is periodically occupied, but not staffed on a daily basis. Since the CSM indicates site workers are potential receptors of indoor vapors emitted from NWS Site contamination sources, a vapor intrusion sampling program will be implemented during the site characterization effort. Samples will be collected from “near-slab” soil gas probes installed adjacent to the NWS composite building. Approximate sample locations will be determined during the field effort based on observations of building layout/design & site conditions.
Additionally, concentrations of GW contaminants will be used to support vapor sample results using the Johnson & Ettinger (E&J) Heuristic model for predicting the intrusion rate of contaminant vapors into buildings (Johnson & Ettinger, 1991) in determining potential risks. ADEC anticipates publishing a Hydrocarbon Risk Calculator (HRC) that will be similar to E&J model, but also will be capable of evaluating several compounds simultaneously & base risks on contaminant concentrations in soil. If available when the site characterization is reported, the HRC will be used to evaluate risks instead of the J&E model. |
Louis Howard |
| 12/14/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Site Characterization Work Plan St. Paul National Weather Service Station, St. Paul Island, Pribilof Islands.
1.3 Scope of Work Page 2
ADEC will require NOAA to change the text to: “…and collect heated headspace field-screening and analytical soil samples from various depths.”
ADEC’s draft Field Sampling Guidance (May 2010) states in section 1. Petroleum Hydrocarbon Field Screening Methods for A. PID and FID:
“Heated headspace organic vapor monitoring involves the measurement of volatile organics emitted from soil samples in a sealed container. The container is typically warmed and then tested for volatile organic vapors using photo- or flame-ionization techniques. The results generated by this method are qualitative to semi-quantitative and are limited to compounds that readily volatilize.” Also, temperatures of the headspace must be warmed to at least 40° F (approximately 5° C).
ADEC requests clarification on why NOAA is considering “low-flow” sampling methods. Low flow purging and sampling are particularly useful for wells that purge dry or take one hour or longer to recover. If a well is low yield and purged dry, do not collect a sample until it has recharged to approximately 80% of its pre-purge volume, when practical. ADEC is unaware of these conditions at the NWS site.
No purge sampling can employ various sampling methods and is suitable for routine sampling. However, it is not recommended for use in making critical site decisions; such as initial sampling, for making the conceptual site model, risk characterization, no further action, or site closure
Peristaltic pumps and bailers are not the preferred method for the collection of volatiles or other air sensitive parameters. Rather the use of bladder pumps, positive pressure submersible pumps, gear pump section, passive diffusion bag samplers (section D6), or samplers like HydraSleeve or Snap Samplers are preferred to reduce the loss of volatiles during sampling. Teflon® sampling equipment (e.g. tubing, bailers) is preferred.
The use of HDPE equipment should be minimized to the extent practical. Studies have indicated that Teflon® shows the least absorption and leaching biases and should be the material of choice for detailed organic sampling purposes. (ADEC draft Field Sampling Guidance May 2010).
ADEC requests NOAA follow the ADEC draft Field Sampling Guidance (May 2010) requirements for soil and groundwater sampling which do require analysis for PAHs (EPA Methods 8260C , 8270D, 8310). For each source area, PAH analysis must be performed on a sufficient percentage of the samples with the highest GRO, DRO and/or RRO concentrations to determine if PAHs are contaminants of concern. In general, 10% is recommended for site characterization. If PAH concentrations are less than applicable cleanup levels, further PAH analysis is generally not required. PAHs should be sampled in groundwater if soil samples concentrations are above applicable cleanup levels and groundwater sampling is required. Groundwater sampling is required at the NWS site.
ADEC requests NOAA add additional text: “Analyze soil gas and indoor air samples for VOCs and total petroleum hydrocarbons (TPH) in accordance with ADEC’s Draft Vapor Intrusion Guidance for Contaminated Sites (July 2009).”
1.4 Schedule Page 2
The fieldwork will take more than a month. ADEC will require two seasons (e.g. winter and summer) to identify any seasonal trends in soil gas. Seasonal environmental conditions (e.g., changes in soil temperature, soil moisture, snow cover, and frozen ground) and seasonal heating and ventilation of a building can affect volatilization and migration of contaminants in soil gas. If a vapor intrusion potential exists at a site, soil gas sampling should occur in at least two seasons to identify seasonal trends. In some cases, DEC may require soil gas data from more than two seasons (ADEC Draft VI Guidance July, 2009).
2.1 Key Personnel Page 5
ADEC requests NOAA provide the names of all personnel that have yet to be determined and ensure that they meet the definition of a “Qualified Person” as specified in 18 AAC 75.990 (100).
For additional information see site file. |
Louis Howard |
| 3/24/2011 |
Update or Other Action |
NOAA submits proposed changes to groundwater monitoring for St. George and St. Paul Island.
National Weather Service Landspreading Area/Oil Drum Dump – The revised St. Paul plan will reflect that monitoring at these wells was discontinued after three years of monitoring indicated no contaminant issues, but will be retained for future use if needed as a result of NWS Site cleanup. |
Louis Howard |
| 8/11/2011 |
Update or Other Action |
Staff received the draft LTM plan for review and comment. This long-term groundwater monitoring plan completely replaces and combines National Oceanic and Atmospheric Administration (NOAA) Long-Term Groundwater Monitoring Plan, St. Paul Island, Alaska dated August 29, 2005 and NOAA Long-Term Groundwater Monitoring Plan, St. George Island, Alaska also dated August 29, 2005.
This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island and 10 wells on St. George Island. Some wells are utilized as sentinels to monitor for contaminant plume migration while the rest are used to monitor contaminant concentration trends to evaluate the effectiveness of past remedial actions and natural attenuation of contaminants. The requirements specified in this plan will remain in effect until evaluation of contaminant concentration trends indicate a revision is warranted. All revisions to this plan shall be reviewed and concurred with by ADEC prior to becoming final.
The National Weather Service (NWS) Landspreading Area is located about 3.5 miles northeast of the City of St. Paul, about 1.5 miles east of the St. Paul airport, and is separated from the Bering Sea by several sand dune ridges (Figure 2-4). This area is federal property managed by the NWS.
NOAA chose landspreading as a practicable means of achieving remediation of petroleum-contaminated soil (PCS) excavated from various locations on St. Paul Island. PCS was spread in 18-inch deep layers across this area in 2004 and 2007 (NOAA 2008a). The PCS layers were periodically tilled to allow organics to volatize and seeded with local varieties of grass to help prevent wind and water erosion during natural biodegradation of petroleum contaminants in the soil.
ADEC did not require NOAA to monitor groundwater at the NWS landspreading area. However, NOAA chose to conduct monitoring in order to verify the contaminant transport modeling results used to demonstrate the suitability of landspreading for soil remediation. NOAA installed wells MWLS-1, MWLS-2, and MWLS-3 and utilized well MWODDS-4 (installed in 2000) to monitor for contaminant migration from the PCS layer to the water table.
Samples collected in 2006, 2007 and 2008 were analyzed for DRO, GRO and BTEX. In 2006, ethylbenzene and total xylenes were detected in very low concentrations in samples collected from MWLS-2 and MWLS-3; all other results were non-detect. In 2007 and 2008, all analytical results were non-detect (NOAA 2009). Based on these results, NOAA discontinued monitoring the NWS Landspread Area in 2009.
Future remediation of diesel-contaminated soils at the NWS Station, St. Paul may necessitate additional landspreading at this site. Monitoring wells MWLS-1, MWLS-2, MWLS-3 and MWODDS-4 will be retained until this decision is made. |
Louis Howard |
| 9/29/2011 |
Update or Other Action |
Staff received the draft Long Term Groundwater Monitoring Plan St. Paul and St. George Islands, Alaska, September 2011. This plan specifies the monitoring requirements for the remaining 28 wells on St. Paul Island.
The National Weather Service (NWS) Landspreading Area is located about 3.5 miles northeast of the City of St. Paul, about 1.5 miles east of the St. Paul airport, and is separated from the Bering Sea by several sand dune ridges (Figure 2-4). This area is federal property managed by the NWS.
NOAA chose landspreading as a practicable means of achieving remediation of petroleum-contaminated soil (PCS) excavated from various locations on St. Paul Island. PCS was spread in 18-inch deep layers across this area in 2004 and 2007 (NOAA 2008a). The PCS layers were periodically tilled to allow organics to volatize and seeded with local varieties of grass to help prevent wind and water erosion during natural biodegradation of petroleum contaminants in the soil.
ADEC did not require NOAA to monitor groundwater at the NWS landspreading area. However, NOAA
chose to conduct monitoring in order to verify the contaminant transport modeling results used to demonstrate the suitability of landspreading for soil remediation. NOAA installed wells MWLS-1, MWLS-2, and MWLS-3 and utilized well MWODDS-4 (installed in 2000) to monitor for contaminant
migration from the PCS layer to the water table. Samples collected in 2006, 2007 and 2008 were
analyzed for DRO, GRO and BTEX. In 2006, ethylbenzene and total xylenes were detected in very low concentrations in samples collected from MWLS-2 and MWLS-3; all other results were non-detect.
In 2007 and 2008, all analytical results were non-detect (NOAA 2009). Based on these results, NOAA discontinued monitoring the NWS Landspread Area in 2009. Future remediation of diesel-contaminated soils at the NWS Station, St. Paul may necessitate additional landspreading at this site. Monitoring wells MWLS-1, MWLS-2, MWLS-3 and MWODDS-4 will be retained until this decision is made. |
Louis Howard |
| 2/2/2012 |
Update or Other Action |
Staff received the Site Characterization Work Plan for review & comment.
The purpose of this Work Plan is to describe the approach & methodology for characterizing the NWS Site’s soil & GW as a means to determining appropriate remedial action alternatives for the site. In addition, potential vapor intrusion of subsurface petroleum hydrocarbons into the site’s structures & non-aqueous phase liquid (NAPL) product recoverability from the water table will be investigated.
An estimated 17 soil boring (with about 9 to be completed as monitoring wells) will be advanced/installed in an attempt to delineate the soil & GW contamination plume. The locations of monitoring wells will be described in the following section. The remaining borings will be located along the former fuel distribution pipeline that leads from the USCG station to the former AST & USTs, then to each structure at the site. The westernmost of these borings will be advanced approximately 40 feet southwest of the inflation building.
The easternmost boring will be advanced approximately between, but slightly north of the Quarters buildings. The remaining borings will trace the line that linked these two locations, approximately equally spaced from one another. Exact locations of boreholes will be determined during the site characterization based on field-screening, site observations, & access.
Boreholes not intended to be completed as monitoring wells will be advanced until GW is encountered, to observe either the presence or absence of NAPL on the GW interface. The boreholes intended to be completed as monitoring wells will extend to a depth of approximately 5’ below the GW interface. Headspace field-screening samples & analytical samples will be collected at 2.5-foot intervals until GW is reached, however, only selected samples will be submitted for chemical analysis based on field-screening & visual/olfactory observations of the soil.
Approximately two analytical soil samples will be submitted from each borehole. If field-screening indicates that all samples obtained from a borehole are negative for contamination, then, at a minimum, two samples will be collected from the smear zone to be submitted for analysis. If contamination is observed, the sample with the highest headspace field-screening result & the sample from the smear zone will be submitted to the lab. Attempts will be made to recover samples from the weathered basalt layer, but equipment limitations & lack of material of appropriate grain size may prevent capturing discrete undisturbed soil samples. If this occurs, & if possible, headspace field-screening will continue in order to obtain data for qualitative assessment.
Approximately 9 of the soil borings described above will be completed as monitoring wells, primarily downgradient of the spill area. 2 initial monitoring wells will be installed north of the Warehouse Building & east of the NWS Composite building, respectively, to establish the triangulation necessary to estimate GW flow direction. GW flow direction will be established by triangulations using the two newly installed & two existing wells. This will allow generation of up to four approximate GW flow directions representing four partially-overlapping areas.
After the GW in the newly installed wells has been allowed to equilibrate (at least overnight), closed looped & depth-to-GW surveys will be conducted for the four aforementioned wells. If necessary, calculations for determining GW elevations & flow direction will factor in the presence of floating NAPL. The remaining wells will be positioned based on the refined discernment of site GW flow direction.
The NWS Composite building is occupied by a year-round, full-time staff, & is outfitted with living quarters on its second floor. The inflation building/warehouse complex is periodically occupied, but not staffed on a daily basis. Since the CSM indicates that site workers are potential receptors of indoor vapors emitted from NWS Site contamination sources, a VI sampling program will be implemented during the site characterization effort. Vapor samples will be collected from locations within the crawlspace & first floor indoor living spaces of the NWS composite building.
Indoor air samples will not be collected from the recreation room/garage addition to the NWS composite building or inflation building due to the likelihood that vapor sources other than the soil & GW contamination at the site would be detected in vapor samples. Exact locations will be determined during the field effort based on observations of building layout/design & site conditions.
A Building Inventory & Indoor Air Sampling Questionnaire Part 1 for NWS Composite building has been completed & added as Appendix D that identifies building characteristics & possible vapor-entry points that may influence the VI pathways. |
Louis Howard |
| 6/27/2012 |
Meeting or Teleconference Held |
Call with NOAA PM regarding change in work plan approach. NOAA is currently conducting a contaminated site characterization at National Weather Service (NWS), St. Paul in accordance with a work plan ADEC approved in April 2012. Figure 4-1 of the plan indicates tentative locations where NOAA planned to install 9 monitoring wells and 8 bores for soils sampling. Upon our arrival at the site last week, utility locates were conducted with the assistance of the City of St. Paul and an NWS electrician. The results of the locates indicate that there are quite a few underground utilities (fiber optics, ASOS power, water, high voltage supply, septic tanks and drain fields, etc.) and that the exact locations of these utilities are not well documented and not readily traceable from the surface.
The number of underground utilities and the zones of safety around their "expected" routes limits where NOAA can place wells and bores. Therefore, it will not be possible to install some wells and bores at some of the locations indicated in the plan.
Here's how NOAA plans to proceed, as limited by underground utilities. The contract allows for 3 additional wells and bores for a total of 12 wells and 11 bores. Of the 12 wells, 3 will be installed as 4" wells for future use as product recovery wells in areas where LNAPL is suspected or known; 9 wells will be installed as 2" monitoring wells in areas we believe free of LNAPL.
The eleven sample bores will be used to search for contaminant source areas along fuel distribution pipeline routes as identified in old documents and other areas such as north of the NWS Composite Building where LNAPL is known to exist, but no source has been identified. Bores/sampling will also be used to confirm (at least to refusal) whether an area is contaminated or not prior installing wells.
The Site Characterization Report, to be provided to ADEC for review, will contain a figure indicating where the underground utilities are suspected or know to exist and will also have a figure indicating where wells and bores ultimately were installed |
Louis Howard |
| 2/11/2014 |
Update or Other Action |
Draft Site Characterization Report received for review and comment.
The National Oceanic and Atmospheric Administration (NOAA) retained Bethel Environmental
Solutions LLC (Bethel) to conduct a site characterization at the National Weather Service
(NWS) St. Paul Station in St. Paul, Alaska. The purpose of the work was to collect site data to
sufficiently characterize the approximately 5-acre site and evaluate future remediation options
related to diesel-impacted soil and groundwater.
The site characterization revealed the following findings:
Mobile non-aqueous phase liquid or free product is present at three wells at the site and ranges in thickness from 0.35 feet to 1.63 feet.
Contaminated soil remains in the unconsolidated soil in the vicinity of the former 500-gallon
underground storage tank south of the Composite Building, at concentrations up to 2,150 milligrams per kilogram.
Fuel-impacted soil is also found in the zone of groundwater fluctuation (smear zone) near the locations of the former tanks in weathered/fractured basalt bedrock.
Nine soil borings advanced along the site’s former fuel distribution lines did not encounter
contamination, indicating that the lines did not contribute to the known contamination source.
One vapor sample collected in July in the Composite Building’s crawlspace had concentrations of chloroform and naphthalene that exceeded Alaska Department of Environmental Conservation (ADEC) indoor air target levels for residential use. Vapor samples collected in November from the same locations did not have exceedances of target levels.
Groundwater elevation fluctuates up to 0.7 feet per day at the site and 1.5 feet over the 5-month study period.
The site’s aquifer has a very low gradient that appears to shift directions on a daily basis.
This variable groundwater gradient and direction is influenced by tidal fluctuations previously noted and a complex system of basalt fractures.
Groundwater monitoring wells installed around the perimeter of the site had detections of diesel-range organics and other fuel-related compounds, but at concentrations less than ADEC Groundwater Cleanup Levels.
Based on these findings, Bethel recommendations the following actions:
Since free product is present in three wells, it should be mechanically recovered to minimize its ongoing impacts to groundwater. Bethel recommends using bailing or skimmer devices or a combination these technologies to recover free product from site wells.
Unconsolidated diesel-impacted soil along the south side of the Composite Building is
present and should be excavated until contaminated soil is removed or until bedrock is
encountered.
Vapor intrusion is occurring in the Composite Building. Further assessment would be needed to evaluate the health risks to NWS workers at the site.
Contaminated groundwater is present in the vicinity of the Composite building and at lower
concentrations around the perimeter of the site. NOAA should monitor groundwater for diesel-, gasoline-, and residual-range organics across the site for at least two additional sampling events to verify that contamination is not migrating off site. |
Louis Howard |
| 3/11/2014 |
Document, Report, or Work plan Review - other |
Comments by staff on the draft report.
Detection of naphthalene in crawl space air above ADEC vapor intrusion target levels suggests further evaluation of the vapor intrusion pathway is necessary. Recommend that indoor air as well as crawl space air be sampled during the next investigation.
Executive Summary
Last Bullet
The text states: “NOAA should monitor groundwater for diesel-, gasoline-, and residual-range organics across the site for at least two additional sampling events to verify that contamination is not migrating off site.”
The text shall state: “NOAA should monitor groundwater for diesel-, gasoline-, and residual-range organics, BTEX, PAHs across the site to verify that contamination is not migrating off site.”
Any monitoring of groundwater at the site will likely be “long-term” and extend beyond two years before it achieves Table C cleanup levels at the NWS site. One monitoring event does not equal a trend.
Sample Receipt Form 1122759, Page 841 states: Were custody seals intact? In comments/actions: “No” 1F, 1B custody seals broke by client before receipt.
Sample Receipt Form 1122759, Page 841 states: Were custody seals intact? In comments/actions: “No” “1F, 1B custody seals broke by client before receipt”. Temperature blank compliant: Condition: “No” Comments/actions:
The sample receipt form does not have any temperatures for cooler IDs 1, 2, and 3 listed on the form nor is there a therm. ID.
There appears to be some data quality issues for the water samples which will necessitate the need for NOAA to continue to groundwater monitoring for volatiles (GRO, BTEX and VOCs VOCs) as well as DRO and PAHs.
Vapor Sampling
Please note that sample VS7 may have to be redone depending on NOAA’s response to ADEC’s comment below regarding the receipt of sample VS7 by the laboratory and notes regarding positive pressure.
Sample Analyses
No mention of removal of custody seals which were noted by the receiving laboratory as being removed by the client before they received them. Sample Receipt Form 1122759, Page 841 states: Were custody seals intact? In comments/actions: “No” “1F, 1B custody seals broke by client before receipt”.
Sample Receipt Form 1122635 Page 714 states: “Client cut all custody seals (1F 1B).” The ADEC Data Review Checklists make no mention on why there were custody seals being cut on coolers before it was received by the laboratory.
Conclusions
Analytical data validity is in doubt with chain of custody being cut or broken prior to the laboratory receiving them. Vapor intrusion samples associated with VS7 are suspect if air samples were received by the laboratory with a positive pressure.
Recommendations
ADEC will require analyses for GRO, DRO, RRO, PAHs, VOCs and BTEX in groundwater due to quality control issues associated with the water samples taken at the NWS site. After a review of the data, it may be determined to reduce the chemicals of concern lists to those that are present above Table C cleanup levels.
Product Inventory Form
No indoor cleaning products where provided on ADEC building questionnaire. Recommend that the product inventory form be filled out to confirm there is no background sources of chemicals of concern.
ADEC’s Vapor Intrusion for Contaminated Sites (October 2012):
Background Interferences
Common household products stored or used in buildings can interfere with the vapor intrusion evaluation. The presampling survey in Appendix I can help identify background sources in the indoor air environment. Portable vapor monitoring equipment readings may also be useful for identifying sources in the building. When feasible, the investigator should remove these sources at least 24 hours prior to sampling. Ventilating the building may also reduce background contaminant levels. If ventilation is appropriate, it should be completed 24 hours or more before the scheduled sampling time. Where applicable, ventilation can be accomplished by operating the building’s HVAC system to maximize out-side air intake.
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Louis Howard |
| 10/13/2017 |
Update or Other Action |
St. Paul/St. George UFP QAPP Addendum. St. Paul Weather Service Office Vapor Intrusion Sampling draft copy received for review and comment. The purpose of this project is to evaluate the vapor intrusion pathway at the Composite Building. This will be accomplished by collecting air samples at the same locations as the 2012 investigation, using the current ADEC Vapor Intrusion Guidance that was update in January 2017. A total of seven samples will be collected: one outdoor ambient air sample, three crawlspace air samples, two indoor air samples, and one duplicate. Samples will be analyzed for volatile compounds associated with petroleum contamination by methods TO-15 and TO-13A. A report will be prepared comparing analytical results to ADEC target levels.
See site file for additional information. |
Louis Howard |
| 2/15/2018 |
Update or Other Action |
St. Paul Weather Service Office Indoor Air and Crawlspace Air Sampling Report received for review and comment. All air sample result concentrations were less than current ADEC residential indoor air target levels.
See site file for additional information. |
Louis Howard |
| 3/13/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the VI sampling for the NWS facility. Main comments were to get clarification on why a flow rate of 5 liters per minute was used when the ADEC VI Guidance suggests a flow rate of 200 milliliters per minutes is preferred when conducting air sampling. Staff requested a plan view of the basement be provided and the document suggested there was a marked up figure for the building survey but none was provided.
See site file for additional information. |
Louis Howard |
| 5/30/2018 |
Update or Other Action |
Final Vapor Intrusion report received. Indoor air sampling and crawlspace air sampling were completed in the WSO building in November 2017. Samples were analyzed for volatile compounds associated with petroleum contaminated sites). All results were less than ADEC target levels for residential indoor air. In general, detections were greater in indoor air samples than crawlspace samples. This suggests that there could be indoor sources causing the higher levels.
See site file for additional information. |
Louis Howard |
| 7/16/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the draft UFP-QAPP for Additional Site Characterization. Main comments were to identify what type of product was used in the 500 gallon UST removed in 2000 and to use the most current guidance and regulations when citing them in the document.
See site file for additional information. |
Louis Howard |
| 4/11/2023 |
Document, Report, or Work plan Review - other |
Draft QAPP received. 5/4/2023 Comments sent. No significant changes to previously submitted QAPP. 5/16/2023 Approval for final QAPP sent. |
Shonda Oderkirk |
| 6/14/2024 |
Document, Report, or Work plan Review - other |
Draft report received with spring 2023 sampling results. Twelve wells were supposed to be sampled; three wells contained LNAPL and were not sampled, one of the remaining nine wells had exceedances of DEC cleanup levels for DRO, RRO, and naphthalene. MNA parameters were also measured in four of the wells. Comments on the draft report sent 7/16/2024. |
Shonda Oderkirk |
| 6/14/2024 |
Document, Report, or Work plan Review - other |
Draft report for the spring 2023 sampling event. Two wells were sampled, one well continues to exceed DEC cleanup levels. The recommendation to remove the other well from the monitoring well list will be addressed after a formal request is submitted. Comments on draft report sent 7/16/2024.
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Shonda Oderkirk |
