| Action Date |
Action |
Description |
DEC Staff |
| 2/15/1945 |
Update or Other Action |
This LORAN-A Station [Unit#60 Code Name "Peter" (XP1-023)] was located approximately 2.5 miles from the City of St. Paul on St. Paul island, which is part of the Pribilof Islands in the Bering Sea NNW of Dutch Harbor, 750 miles SW of Anchorage. This site was first developed after February 1945 as part of the war program when a radio direction finder station and accessory facilities (LORAN-A station) were established on this island for national defense purposes. The Coast Guard (CG) obtained a permit from the Department of the Interior for the development of LORAN-A on 150 acres of land on 15 February 1945.
At that time, the island's" ... very small pre-war population [was] concentrated at Village Cove, a natural harbor at the south end of the island. The site selected for the Loran station was on the most westerly point of the island. From Village Cove to this site a route 16 miles in length, had been selected by the original siting party. However, a more direct route was surveyed, cutting the distance to 7 miles. A road existed for 2 miles of this latter route, but the balance of the distance was over rugged terrain, consisting of tundra heavily covered with volcanic boulders." When completed, this LORAN-A station covered an area of approximately 1200' by 1800'.
That LORAN-A Station was disestablished and disassembled, the CG's permit terminated, and the property transferred to the U.S. Fish & Wildlife Service (FWS) in 1950. By 1957 the CG neither owned nor operated any buildings on the site and the LORAN-A Station had "deteriorated beyond possible repair." The CG did, however, continue to operate a radio beacon from FWS-owned space. |
Louis Howard |
| 6/3/1965 |
Update or Other Action |
1965 Memorandum of Agreement between the U.S. Coast Guard - Bureau of Commercial Fisheries (now the National Marine Fisheries Service). Whereas, the USCG continues to operate a LORAN station on Saint Paul Island in accordance with a DOD requirement, and further in accordance with the agreement previously entered into between the USCG and the Bureau of Commercial Fisheries (BCF). *NOTE: Date of previous agreement is not known.
It is hereby agreed as follows: this agreement abrogates and supersedes the previous agreement above noted; this document represents the entire agreement between the parties.
The USCG shall continue to occupy the Telegraph Hill site for operation of a LORAN Station until such time as the station becomes no longer essential to the Defense Program; pre-existing metes and bounds description, boundaries, and Petroleum Oils and Lubricants (POL) pipeline continue as specified on USCG headquarters drawing number 107250, which drawing is incorporated herein by reference.
That USCG personnel shall have access to such other areas on the island for operational and recreational use as is not inconsistent with the DOI regulations relating to the administration of the Pribilof Islands and protection of the seal herds, and such other rules and regulations of like regard lawfully promulgated by the Island Manager.
That facilities and equipment of both the USCG and the BCF shall be used for the mutual advantage and benefit of both to an extent practicable and agreed upon by Commanding Officer, LORAN Station, Saint Paul and the Island Manager.
The USCG shall operate and maintain the Saint Paul radio beacon.
The USCG shall provide power for the operation of the airstrip and apron lights and beacon as necessary.
The USCG shall provide portable emergency fire fighting equipment for the landing and take off of aircraft.
Agreement shall be effective when executed by the Commandant USCG and the Director BCF or their duly authorized representatives. Signed May 13, 1965 P.E. Trimble Rear Admiral USCG Chief of Staff and June 3, 1965 Acting Director Bureau of Commercial Fisheries. |
Louis Howard |
| 2/10/1970 |
Update or Other Action |
1970 Amendment to the Memorandum of Agreement USCG - Bureau of Commercial Fisheries. MOA is amended as follows: The USCG is authorized to locate and operate a remote retransmitting device near Halfway Point, Saint Paul Island, Alaska, at a point midway between Polovina Hill and Halfway Point (geographic position approximately Latitude 57 degrees 10.2 minutes North, Longitude 170 Degrees 10.5 minutes West). The remote retransmitting device will have a self-contained power supply and will be housed in a structure of a size of about ten feet by ten by eight feet with a ground system consisting of 36 fifty foot radials of copper wire and ground rods, and a receiving and a transmitting antenna mounted on the roof. Signed USCG G.M. Loboudger, Captain USCG Comptroller and Bureau of Commercial Fisheries Director. |
Louis Howard |
| 5/17/1971 |
Update or Other Action |
1971 Amendment Number 2 to Interservice Agreement (1A-FB5000-0051-0 and DOT-CG17-1655) between Alaskan Air Command and Seventeenth Coast Guard District. Par. 10a(6). Add: a new Par. 10a(8) Arrange commercial airlift service for subsistence items (1200 to 1500 pounds every two weeks) to Coast Guard Loran Station Saint Paul Island Alaska. Signed Alaskan Air Command Neal A Bird Colonel, USAF, Chief of Staff May 17, 1971 and M. McPherson Contracting Officer May 7, 1971. |
Louis Howard |
| 8/6/1979 |
Update or Other Action |
U.S. Coast Guard Loran Station Well AK No. 80194 (finished in basalt) latitude 57 degrees, 09' 08" longitude -170 degrees, 14', 41" reconnaissance conducted on 8/06/1979. Only three wells were identified as being used in 1979, two by the community of St. Paul and one by the Coast Guard Loran facility. All wells are in the southeastern part of the island. On the basis of present well yields, amount of fresh water inferred to be present below the water table, and potential recharge from precipitation, it is concluded that it would be possible to design a well field in the southeastern part of the island that could yield more than a million gallons per day without danger of inducing saline water into the well field. |
Jennifer Roberts |
| 10/1/1980 |
Update or Other Action |
Diesel fuel UST Tank 3 installed in 1970 with 550 gallon capacity. UST was removed in October 1980 from the Flow-through incinerator day tank. NO record of contamination found during removal; however, area included in release investigation. |
Jennifer Roberts |
| 8/1/1986 |
Update or Other Action |
Multiple overfills occurred in 1986 when the UST located by the southwest entrance to the
Administration/Barracks Building was replaced by an aboveground storage tank (AST). The former
1,000 gallon underground storage tank 1, containing diesel fuel,was installed in 1975 at the Administration/Barracks building. It was removed in 1986. The heating oil UST was to provide fuel for the boiler. No record of contamination found during the removal in August 1986, however, area included in release investigation. Tank 2 was installed in 1960, 1,000 gallon capacity for heating oil for the Boiler Room UST (Signal & Power Building). No record of contamination found during removal in August 1986, however area included in release investigation. |
Jennifer Roberts |
| 8/16/1987 |
Interim Removal Action Approved |
(Old R:Base Action Code = SC - Site Control (Emergency Response)). Plumber's plug used to cover leak. It was crimped on to pipe and sealed with hose clamp. Later line was cut then a wooden plug was used to seal pipe then covered as before. 19,000 gallons of fuel oil estimated to have been released from two tanks. |
Former Staff |
| 8/17/1987 |
Site Added to Database |
Diesel contaminant. |
Former Staff |
| 8/18/1987 |
Interim Removal Action Approved |
Spill response plan to deal with spill immediately, more detailed plan to follow.
Phase 1: delineate the zone of contamination horizontally and vertically, Phase 2: Remove gross contamination and free product, Phase 3: Contain Spill horizontally and vertically, Phase 4: Long term cleanup and monitoring. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
Phase 2 has begun at this time (8/18/87) and the contractor is recovering free product dug nearby on an impervious layer. Phases 1 and 3 will begin field operations on Thursday August 20, 1987. Equipment mobilization is taking place at this time. |
Mike Lewis |
| 8/19/1987 |
Update or Other Action |
Bruce Erickson status report on spill. Mike Lewis will be on Saint Paul as ADEC on scene coordinator and will be keeping the City of Saint Paul city manager informed of the progress of the spill. There is a dispute as to the actual size of the spill. Some have put it at 16,000, 19,000 or 14, 000 gallons in size. Mike Lewis will ascertain the amount when he is on site.
There also appears to be many old spills and some slow pipe leaks in the area, and the method proposed for plume delineation should be able to differentiate between the new and old oil. NOTE: Spill # 87-261-229-1 assigned on 8/18/87 is incorrect. New corrected spill # is 87-221-229-1. |
Bruce Erickson |
| 9/2/1987 |
Update or Other Action |
Letter to Commander H.E. Walter USCG regarding Saint Paul LORAN Station subsurface soil contamination. Per our initial investigation of a fuel spill at the station on August 15, 1987, ADEC has found evidence of further soil contamination from other existing spills. The areas in question can be found in several locations throughout the facility site.
1. Located on the NE end of the generator/maintenance building , visual and olfactory observations along a parallel running trench next to the building, soil was found to be darkly stained with a highly pungent odor.
2. South of the new spill area, heaviest concentrations were found to be around the existing fuel storage day tank located in front of the office and living quarters building. Testing through a gas chromatograph showed evidence of a much older degrading spill than as compared to the new fuel contamination.
3. Found within the excavated material from foundation work on new fuel tank construction. Visual and olfactory observations showed clear evidence that soil was contaminated.
ADEC requests the USCG conduct remedial actions and investigation on the contaminated areas as soon as possible.
1. Setup an initial investigation team to test and probe areas of contamination to determine the size, constituents and impacts.
2. Implement an initial recovery system.
3. Determine the most suitable final cleanup procedures and coordinate function with ADEC.
4. Exercise care to maintain any natural impervious zones separating contaminated areas from unaffected zones. |
Bill Lamoreaux |
| 9/3/1987 |
Update or Other Action |
(Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). AMI submits written report on spill cleanup. Investigation revealed several previous spills have occurred at the site. Spill was well contained vertically by the stratigraphy and by the prompt installation of sump areas which limited horizontal spread of the spill. Two sumps were installed initially but there is only one large sump currently installed.
2000 gallons of Number 2 diesel have been recovered from the sumps and an estimated 1450 gallons contained in soil that was excavated in the process of installing the sumps. The excavated soil has been temporarily stored on a plastic liner. Ultimate disposal of the soil can be accomplished by spreading and devolatilization and then either backfilling soil into the sump excavation or incorporating the soil into road building material. |
Mike Lewis |
| 9/24/1987 |
Document, Report, or Work plan Review - other |
ADEC letter to AMI regarding report from Woodward Clyde Consultants. ADEC has found WCC's report adequately addressing the investigative and cleanup efforts. Expansion of recovery effort as recommended needs to be implemented as soon as possible. Details for expansion work may be followed as addressed in the report. Recovery efforts must be maintained until there is little to no collection being made. Determination for final cessation of recovery operations may be made by the department upon submission of test sampling results.
WCC's recommendations for treatment of recovered contaminated soils are acceptable. In either case, you will need a permit from our office for final disposal. Long term sampling as recommended by WCC is acceptable. Additional probe sampling in the summer of 1988 will provide assurity to the department of the effectiveness of the cleanup operations. Final deposition of the fuel recovered from cleanup operations is left to your discretion. Whatever way is chosen to dispose of the fuel, further contamination to the environment must not be allowed. We request you submit a report on your final cleanup procedures. Your report should also include a schedule showing all start up and completion times of cleanup operation efforts. This report should be submitted to our office no later than October 12, 1987. |
Mike Lewis |
| 10/28/1987 |
Interim Removal Action Approved |
(Old R:Base Action Code = REM - Removal / Excavation). Fuel oil recovered supplies oil in camp heaters after treatment in decanting tank. Soil spread-2"lifts or less and compacted minimum less of 90% over roads and parking lots.
Letter to AMI regarding final spill cleanup report on subject facility. In overview of report we have generally found the proposed recovery and disposal procedures satisfactory for cleanup work.
1. Expansion of oil recovery: no objections.
2. Treatment of recovered oil: Potential problems with long term degradation of liner, request all contaminated soil be mixed with clean, coarser material and spread as road oil seal. Attached is a surface oiling permit application.
3. Recovered oil disposal: Decanting operations must be closely monitored to insure the quality of water is maintained.
4. Long term sampling-no comment.
ADEC requests as each item is implemented, a brief report be submitted outlining the methods and procedures used in the work. The report should include photographic evidence, chronological accounts on the progression of work. |
Mike Lewis |
| 12/21/1987 |
Document, Report, or Work plan Review - other |
ADEC letter to AMI regarding 12/15/1987 letter on the subject application. ADEC has found the documentation provided adequate with exception to the testing of lead and PCBs within oil. Upon receiving satisfactory test results of these constituents, we may then approve the surface spreading request. |
Mike Lewis |
| 1/4/1988 |
Update or Other Action |
Chlorine residual violation. Chlorinator is down and the system is expected to be online 2/88. 3/9/88 report is still not available. 7/14/88 Chlorinator is still down so the Loran station is getting water from the City of Saint Paul. PWSID 261436 Source ID 002. |
Mike Lewis |
| 2/2/1988 |
Update or Other Action |
Letter from AMI to Mike Lewis Fuel Spill# 87-211-229-1 Loran Station Status of cleanup effort for fuel oil spill given. Installation of French drain and sump recovery system was started on 11/2/87 and completed 11/5/87. Recovery was initially 130-150 gallons/week but has dropped off to 40-50 gallons/week of fuel oil/water mix. To date they have recovered 2,793.35 gallons of fuel oil.
Little progress has been made towards the disposal of oil contaminated soil that was removed from the spill area. Currently soil is stored in piles resting on plastic. AMI has applied for a road oil permit so soil may be disposed of by spreading it on roads. Pending receipt of the permit, soil will be used in the spring time for road oil purposes. |
Mike Lewis |
| 2/10/1988 |
Update or Other Action |
Letter to Alaska Mechanical Inc. (AMI) Mr. Robert Kuczek re:2/2/88 letter on status update. Your efforts for recovery and disposal of the fuel have been found to be more than acceptable. Reference to road oil permit: ADEC is not able to issue a disposal permit due to changes in federal law. ADEC offers the following courses of action for disposal:
1. All contaminated material may be containerized and shipped off to a permitted hazardous waste disposal site.
2. All contaminated material may be devolatized by running it through either an asphalt plant or sand drying plant dryer. After devolatizing, material may be disposed of in a manner such that would not further degrade the surrounding environment.
3. All contaminated material may be landfarmed to devolatized soil and disposed in the following manner:
a. A site to be selected which is not in a depressed area and is at least 200 feet or more and nor direct drainage to any water body. Sites with grades greater than 5% should not be used.
b. An impermeable plastic liner visquene (4 mil. or greater) or equivalent, is required to be placed on top of the site area in a rectangular shape with the longer side set parallel to the land contour.
c. After placing the liner, contaminated soil can then be spread out loosely in a lift not exceeding 4 inches. A minimum of 3 foot boundary should be left around the perimeter of the plastic sheet to contain sloughing.
d. After placing the contaminated soil, it should then be allowed to sit for a minimum of 4 to 6 months to devolatize. During this time, the soil should be left undisturbed and be posted to prohibit any vehicular or pedestrian traffic.
e. Upon completion of devolatization, the soil may be finally disposed in a manner which would not further degrade the surrounding environment.
Upon AMI's decision of which method it feels would be the most suitable for material disposal, we request a letter addressing your decision and what specific disposal procedures will be implemented. |
Mike Lewis |
| 2/23/1988 |
Update or Other Action |
Letter to Oakley B. Ulsrud Sr. Project Manager AMI regarding 2/10/88 letter to AMI. ADEC has an additional alternative course of action for disposal. All contaminated material may be spread in an 2 inch lift or less over any road or parking area which does not have any direct runoff to a watershed. In addition, any potential runoff into sensitive areas such as water bodies or breeding grounds, must be avoided. Layed material will be required to be rolled to a minimum of 90% compaction. Other material may be added to provide a tighter binding course. If this alternative is the preferred method of disposal, please inform ADEC of the methods of disposal and areas where material will be placed. |
Mike Lewis |
| 4/13/1988 |
Update or Other Action |
USCG letter to Bill Lamoreaux SCRO regarding ADEC letter September 2, 1987 USCG Loran Station Saint Paul subsurface contamination. Several points and recommendations are brought out:
1. All contaminated soil in the area around the station appears to be well contained vertically by soil stratigraphy (clayey/sand/silt barrier). In response to Mr. Lewis's request, in the Spring after the ground has thawed we will take a soil sample from below this layer for analysis to ensure vertical containment. The sample will be cored through a larger casing which will be filled with grout to preserve the natural barrier.
2. Relatively small area contaminated by the recent spill combined with the dry performance of our recovery well and construction trenches in the same area, indicate that our contaminated soil is also well contained horizontally. Field investigation and maps of the contaminated area combined with the clean well water sample taken from the station's main well help to substantiate this conclusion.
3. Due to the age of the contamination, the relatively effective containment properties of the local soil, the substantial # of LORAN signal cables/high voltage lines located in and around the station, it was decided that the contaminated soil could remain in place.
Further investigation into the cause of the older soil contamination revealed cause to be repeated overfilling of the station's diesel oil day tanks. The major station renovation project being completed this summer (1988) incorporates several fuel spill prevention measures. |
Bill Lamoreaux |
| 5/31/1988 |
Update or Other Action |
Letter to USCG Shore Maintenance Detachment ATTN: L.H. Howell Juneau regarding USCG LORAN Station subsurface soil contamination. Clarification of the department's position on this matter:
1. Assessment of vertical migration of contaminants has been well addressed but the horizontal extent of contamination is still not clear. Additional test probing should be done to better define the boundary limits of the contamination. A boundary limit can be defined as the division line between where average background contaminant levels exist and concentration of contaminants increases above background levels.
2. ADEC agrees that USCG should not subject cleanup personnel to a greater risk that what may be incurred by leaving the contaminants in place. However, alternative cleanup methods could be used: A. Soil gas venting or B. Water injection. Please evaluate the methods described on their potential use as a recovery and cleanup system for the spill. Provide a plan on how further monitoring and testing may be employed to further evaluate the extent and concentrations of contaminants within the spill area. |
Bill Lamoreaux |
| 10/19/1988 |
Update or Other Action |
AMI letter to Mike Lewis regarding Fuel oil spill # 87-2-1-1-229-1 ADEC letter dated 2/23/1988. AMI will utilize the method described in the letter to dispose of the contaminated materials. Material will be spread over the roads and parking lots in 2 inch lifts or less and compacted to a minimum of 90%. A site plan of the surfacing area is attached.
As discussed with you this date (10/14/88), a sample of the liquid collecting in the sump will be sent to Montgomery Engineer's of Pasadena, CA to be tested per EPA method 502.2 If the test results are favorable, we will upon your advisement cover all existing sumps and close out the subject spill. |
Mike Lewis |
| 11/9/1988 |
Update or Other Action |
AMI letter and sampling results received by Mike Lewis. Please review results using EPA test procedure 502.2 and advise as soon as possible. |
Mike Lewis |
| 11/17/1988 |
Update or Other Action |
(Old R:Base Action Code = RARR - Remedial Action Report Review (CS)). ADEC letter to AMI, 8540 Dimond "D" Circle, P.O. Box 203649, Anchorage, AK 99520 for final acceptance of cleanup project signed M.P. Lewis EE.
In review of 11/8/1988 letter, ADEC has found your most recent test results from the collection sump satisfactory for meeting our cleanup compliance requirements.
No further cleanup action will be required from the department. However, final closeout of the cleanup site must be completed prior to leaving the area. All excavations and cleanup equipment must be adequately removed to restore the site as best as possible to original conditions. Please submit a written statement with photos (if available) showing that appropriate site restoration has been made. Upon receipt of the written statement, ADEC may then issue a final acceptance letter. |
Mike Lewis |
| 11/23/1988 |
Meeting or Teleconference Held |
AMI Letter regarding ADEC letter dated 11/17/88. Per teleconference direction on 11/14/88 and the subject letter, the site excavations have been filled in and the area fine graded. Our personnel have left the site, so photographs are not available to use. We await your letter of final acceptance. |
Mike Lewis |
| 11/30/1988 |
Update or Other Action |
Letter to AMI regarding USCG LORAN Station Saint Paul Fuel Oil Spill # 87-2-1-1-229-1. Upon receipt of your November 18, 1988 letter in reference to the final close out of the subject spill, we hereby give final acceptance of the cleanup project. Signed Mike P. Lewis P.E. Environmental Engineer. |
Mike Lewis |
| 8/9/1991 |
Site Number Identifier Changed |
Old# 87210122901. New# 87250122901. Western district now. |
Former Staff |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 5/5/1993 |
Update or Other Action |
Dennis Lundine took a spill report from the USCG Frank Madison Chief of Environmental Branch out of Civil Engineering Unit in Juneau regarding release from older oil spill discovered 5/4/1993. Old release uncovered by maintenance people starting to dig an excavation to replace pipe. Encountered a "wet" spot which grew into a large spot (not sounding like an old release). Madison stated that the USCG is in the process of determining the extent of the release. Turned over to Contaminated sites staff Eileen Olson in the western district. |
Dennis Lundine |
| 8/23/1993 |
Update or Other Action |
Closure notice received from Facility # 1767 USCG LORAN Station Saint Paul Island. Scheduled date for closure is August 16 and 17, 1993 Terrasat Inc. Worker License #AA1 Removal of Tank #4 a 5,000 gallon gasoline tank. |
Kent Patrick-Riley |
| 9/29/1993 |
Update or Other Action |
In 1993, ASCG Incorporated (ASCG) was contracted to conduct a Release Investigation. Phase I of the investigation was conducted in late 1993 and consisted of a geological survey and sampling effort. Sixty-three soil samples and four groundwater samples were collected as part of this investigation. Four broad areas of extractable petroleum hydrocarbons (EPH) contamination were identified:
• Group 1: West of the Administrative/Barracks Building
• Group 2: East of the tank farm
• Group 3: Northeast of the Power Signal Building
• Group 4: North of the Power Signal Building
Concentrations of EPH ranged from non-detect to 58,000 parts per million (ppm) with the
highest concentrations located within Group 1. Groundwater EPH concentrations ranged from nondetect to 73 ppm. While the horizontal extent of Groups 1 and 2 were assumed to be well delineated, the LORAN net and a layer of subsurface boulders interfered with the delineation of Groups 3 and 4. The total volume of contaminated soil was estimated at 3,000 cubic yards. |
Kent Patrick-Riley |
| 10/1/1993 |
Update or Other Action |
In 1993, a pipeline that extended from the beach (off of LORSTA property) to the tank farm
was drained and removed at the request of the City of St. Paul to prevent future
contamination. The pipeline was dismantled and shipped off site as scrap metal. Soil samples
were not collected in the vicinity of the pipeline as there were no indications of fuel
contamination. |
Jennifer Roberts |
| 12/9/1993 |
Update or Other Action |
USEPA Preliminary Assessment received prepared by SAIC Reston, VA for Volpe National Transport. Systems Center Cambridge MA and USCG HQ CE Division (G-ECV-1) Washington D.C. Facility assigned EPA CERCLIS ID AK3690360315. Based on a site inspection, 4 sources of potential contamination were found: 1) The tank farm (source 1), 2) outside of the Power/Signal Building (source 2) and of these 2, the tank farm is most significant. 3) An above ground pipeline, and 4) a fuel spill occurring in 1977, could not be determined. All releases and potential releases associated with this facility are petroleum related. Petroleum related releases are exempt from CERCLA response action under CERCLA 101(14). |
Jennifer Roberts |
| 2/18/1994 |
Update or Other Action |
CERCLA No Further Action Required (NFA) granted for the purposes of ranking under the Hazard Ranking System used to evaluate federal facilities for inclusion on the National Priorities List (NPL). Review of the documents indicate the site (facility) does not score high enough to be proposed for inclusion on the NPL.
NOTE: Preliminary Assessment is defined as: a limited-scope investigation performed on every CERCLIS site. PA investigations collect readily available information about a site and its surrounding area. The PA is designed to distinguish, based on limited data, between sites that pose little or no threat to human health and the environment and sites that may pose a threat and require further investigation. The PA also identifies sites requiring assessment for possible emergency response actions. If the PA results in a recommendation for further investigation, a Site Inspection is performed.
Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in the federal agency hazardous waste compliance docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA will reevaluate the facility accordingly.
The Facility is not relieved from complying with appropriate Alaska state regulations and SARA 1986(a) (4) requires *federal facilities to comply with state cleanup requirements and standards when not listed on the NPL.
CERCLA - Sec. 9620. Federal Facilities
(a) Application of chapter 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 chapter in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 9607 (CERCLA - Sec. 9607. Liability) of this title. Nothing in this section shall be construed to affect the liability of any person or entity under sections 9606 (CERCLA - Sec. 9606. Abatement Actions) and 9607 of this title.
(2) Application of requirements to Federal facilities
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this chapter 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 chapter.
(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 chapter shall be construed to require a State to comply with section 9604 (c)(3) (CERCLA - Sec. 9604. Response Authorities) of this title 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) of this section when such facilities are NOT included on the National Priorities List [NPL]. The preceding sentence SHALL NOT 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 |
| 5/2/1994 |
Update or Other Action |
UST Tank 4 with a 5,000 gallon capacity storing gasoline was installed in 1960. The UST was removed in August 1993. Site Assessment prepared by Terrasat Inc. and submitted to ADEC (Kent Patrick-Riley) May 2, 1994. NO gasoline contamination was found, only diesel contamination which was attributed to the nearby pipeline spill. |
Kent Patrick-Riley |
| 5/24/1994 |
Update or Other Action |
May 2, 1994 fax from Larry King regarding phone conversation on 5/2/94. Faxing the USCG's proposed sampling plan for the STP LORAN station stockpile of soil estimated to be 250 cubic yards. The pile was generated during construction project installation and removal of diesel fuel lines and the removal of a 5,000 gallon underground gasoline storage tank. 3 samples were taken from the former tank site and the consultant indicated that the contamination is not from the former 5,000 gallon gasoline tank.
USCG's position is that the source of the contamination in the stockpile is from previous diesel releases associated with former installations or operational procedures. Request ADEC review of proposed sampling plan, numbers and types of analyses. |
Kent Patrick-Riley |
| 5/15/1995 |
Update or Other Action |
In 1995, ASCG completed Phase II of the Release Investigation. As part of this investigation,
32 soil samples were collected from 20 test pits along with two drinking water samples. Extractable petroleum hydrocarbons (EPH) concentrations in soil ranged from nondetect to 7,380 ppm. Total benzene, toluene, ethylbenzene, and xylene (BTEX) concentrations were nondetect for all samples with the exception of five samples which ranged from 0.05 to 7.7 ppm.
Soil samples indicated that contamination in Group 2 appeared primarily limited to depths of 5 feet bgs or less. Contamination in Groups 1, 3, and 4, however, appeared to be more highly concentrated at depths greater than 5 feet bgs. BTEX concentrations in the drinking water were nondetect; total petroleum hydrocarbon concentrations ranged from nondetect to 1 ppm |
Kent Patrick-Riley |
| 10/27/1995 |
Document, Report, or Work plan Review - other |
ADEC letter to USCG Robert Deering regarding Release Investigation Final Report dated May 1995 prepared by ASCG submission date unknown. Summary of Findings: shallow soils (less than five feet) contaminated with diesel range organics up to 15, 000 mg/kg and below 5 feet as high as 40,000 mg/kg DRO. Drinking water well for Loran station is 100 foot NE of northernmost area of near surface soil contamination.
Consultant believes contamination is migrating in a direction away from the water well. However, groundwater was not sampled during this investigation (thus a determination of groundwater gradient or direction is premature). Groundwater sample collected closest to the well in a previous investigation showed 1 ppm total petroleum hydrocarbons (TPH). A water sample collected during this investigation from the well system (before treatment) showed 1 ppm TPH and non-detectable (ND) for BTEX. A water sample from the tap showed ND for TPH and BTEX.
Comments: ADEC has 3 concerns regarding defining the extent of contamination; depth of contamination; extent of groundwater contamination; and appropriate drinking water analyses.
1. Depth of contamination: Deepest pit was 9 feet with high petroleum contamination being reported (Test pit 76 at 7,800 mg/kg DRO terminated due to a water line). Because deeper borings were not made, the depth of contamination is unknown.
2. Extent and levels of groundwater contamination: The report makes a professional judgement that the groundwater contamination is moving away from the drinking water well. This determination is inconsistent with an ongoing study for the Saint Paul Landfill Closure being conducted by Hart Crowser for NOAA, which indicates that groundwater flow may be in the opposite direction. It also may be contradicted by the observation of 1 ppm TPH in a water sample collected from the drinking water system. However, given that part of the water line appears to lie in heavily contaminated soil (as indicated by Test Pit 76), the observed TPH contamination in that sample may also be due to contamination infiltrating the water lines.
3. Drinking water analyses: Two water samples were obtained from the cistern in the water system and the second from the tap. The methods for analyses (418.1 and 602) were inappropriate for drinking water testing. Analyses of water taken from drinking water supplies should be those in the EPA 500 method series. For volatiles, the appropriate method is 502.2; for semivolatiles, the appropriate method is 525.1.
In addition, the discussion of drinking water samples did not indicate how the samples were obtained (e.g. was the tap turned on for a period of time before collection) or preserved (were samples properly acidified, was any headspace observed upon arrival at the laboratory). Proper preservation is particularly critical with water samples containing volatiles. Part I of II |
Kent Patrick-Riley |
| 11/21/1995 |
Site Ranked Using the AHRM |
Initial ranking. |
Kent Patrick-Riley |
| 11/28/1995 |
Update or Other Action |
Site is still open despite Mike Lewis sending final acceptance of cleanup letter to RP, 11/18/88. |
Kent Patrick-Riley |
| 2/14/1996 |
Update or Other Action |
USCG letter to Richard Sundet regarding 10/27/1995 Kent Patrick-Riley's letter. USCG has provided the results requested for drinking water analysis at LORAN Station Saint Paul. EPA Method 502.2/524.2 and 525.1 were used and all analytes were below the method detection limits. |
Rich Sundet |
| 6/3/1996 |
Update or Other Action |
In 1996, a soil vapor extraction (SVE) system was installed to remediate soils in the four areas
of contamination delineated during the Release Investigations. The SVE system consisted of
5 blowers and 19 wells and was calculated to have an average extraction rate of 22 gallons of
product per day. During installation, contamination was discovered extending into the
groundwater aquifer.
An estimated 11 inches of free product were observed on the surface of the aquifer and diesel-range organics (DRO) were found in all six monitoring wells. Work was immediately implemented to remediate the water to protect the city water wells less than a half mile away from the LORSTA. |
Kent Patrick-Riley |
| 7/24/1996 |
Update or Other Action |
Tessa Muehllehner sent Draft Corrective Action Plan, Installation and Monitoring Plan to Richard Sundet for the USCG Saint Paul Loran Station dated July 1995. Included in the fax was a memorandum from Polarconsult David Ausman to USCG Jerry Woloszynski dated 7/18/1996 regarding Environmental Cleanup Operations at Saint Paul Coast Guard Station. As they discussed, the CG station is over the community's designated water shed and the City is concerned about potential contamination of the drinking water supply. Specifically the City is concerned the drilling operations may penetrate confining layers and provide a pathway for fuel and contaminated surface water to reach the aquifer. The fax memorandum goes on to state the City ordinances require all construction projects in the municipality to be reviewed by the Planning and Zoning. Conversations with the City Engineer indicates that these regulations apply to installation of environmental equipment and does not exempt federal facilities (*Note-executive order 12580 exempts federal agencies from local control, i.e. permits or construction reviews). All future construction operations require coordination through the City. |
Rich Sundet |
| 11/13/1996 |
Document, Report, or Work plan Review - other |
Letter from Ray Dronenburg to the USCG Jerald L. Woloszynski regarding Corrective Action Plan Loran Station Saint Paul dated 7/28/1996. Comments are as follows:
a. As previously noted in ADEC Kent Patrick-Riley 10/27/1995 letter to Rob Deering of the USCG- ADEC is very concerned with the contamination at Saint Paul and especially considering that a single source aquifer is the total drinking water and process water source for the entire island. The site is a high priority site within ADEC's ranking system.
b. ADEC is extremely concerned that vapor extraction for diesel contaminated soils (and especially old weathered diesel) is not a viable method for extraction and decontamination of soils.
c. ADEC is also working with NOAA and the TDX Corp. for spills and cleanup actions that are also occurring with a half mile radius of the Coast Guard site. Those sites are being held to a more stringent action level that what the Coast Guard has proposed and is performing.
d. The Coast Guard has performed no water quality sampling of the aquifer directly beneath the site. Conversations with Lieutenant Muehllehner indicates that water samples were taken from the cistern only and would not be representative, in the Department's opinion, for the aquifer (that is directly below the site).
ADEC is concerned that a soil vapor extraction system may not be the best method to remediate spilled diesel fuel. SVE systems work best for gasoline and other lighter end fuel spills and have limited success with treating diesel contamination. Additionally, the USCG's draft July 1995 plan states the site geology consists of sandy clay and broken basalt which may not be conducive to a SVE system. As noted in the workplan, the USCG does not expect the site to be remediated for about five years using the SVE system. This time schedule is not acceptable to the Department.
Alaska Statutes (AS 46.04.020(b) "The containment and cleanup of discharged oil shall be carried out in a manner approved by the department. Wastes generated as a result of containment or cleanup activities shall be disposed of in a manner approved by the department. The requirement of this subsection for approval of containment and cleanup activities does not apply to the United States Coast Guard or United States Environmental Protection Agency acting under the authority of Sec. 311(c) or (d) of the Clean Water Act." requires that the containment and cleanup activities for an oil spill must be carried out in a manner approved by the Department.
In this case, the department has not approved the plan presently being implemented. It is suggested that , at your earliest convenience, a meeting between this department, the U.S. Coast Guard and members of the restoration advisory board for Saint Paul Island be scheduled whereby the coast Guard can present information and data regarding the actual facts of the spill(s) and cleanup actions being accomplished and planned. Richard Sundet is no longer the project manager-please direct all future correspondence to Ray Dronenburg. |
Ray Dronenburg |
| 11/27/1996 |
Update or Other Action |
USCG letter to ADEC regarding Remedial Action Phase I Soil Vapor Extraction Startup report. Hollow stem auger was unable to bore through subsurface boulder field encountered at the site. An alternate drill rig will be brought on site. A workplan with specific details will be developed for approval before the 1997 field season. Most recent (November 6, 1996) drinking water analyses showed all petroleum constituents below method detection limits. Results are consistent with previous two sampling events conducted this year. As documented in the report, they are currently extracting 9 gallons per day from the entire site. SVE was intended as an interim phase I action until funding and further ADEC direction was available to fully address issues at the site. 700 gallons have been recovered since November 3. They further estimate an extraction of 2,400 gallons of contamination during the first entire year of operation.
It is the USCG's intention to work with ADEC to select other remedial techniques that will bring this site within ADEC standards. The UISCG would like to discuss those current standards with ADEC so a common understanding of what is expected can be reached to accomplish site closure. |
Ray Dronenburg |
| 12/17/1996 |
Update or Other Action |
USCG letter to Ray Dronenburg regarding meeting with Lieutenant Jerry Woloszynski on 12/9/1996 to discuss our progress on the LORAN Station Saint Paul, Alaska site. Based on the meeting here are the action items the USCG will perform:
1. Conduct a hydrologic study at the LORAN station to determine direction of the groundwater flow and if petroleum contamination has reached the water table. USCG expects to have a work plan developed by their consultant to ADEC by end of February 1997. Upon ADEC approval, expect to conduct this study in May or June of 1997.
2. Determine the vertical extent of petroleum contamination in the soil during the hydrologic study. USCG will also conduct a soil gas survey to establish the radius of influence for the SVE system. Using that information, the total volume of soil being treated will be calculated, as well as the total volume of soil that remains untreated.
3. Develop and submit a remedial workplan Phase II utilizing the results of the hydrologic study. Any assistance ADEC may provide in identifying a viable remedial method for the in situ petroleum contaminated soil would be appreciated. |
Ray Dronenburg |
| 1/13/1997 |
Document, Report, or Work plan Review - other |
Memorandum letter from ADEC Ray Dronenburg to Jerry Woloszynski Lieutenant USCG regarding Hydrologic Monitoring Investigation Saint Paul Loran site.
Comments for consideration:
A. How is lower low water (MLLW) defined? It is never specified.
B. Does the "perched" aquifers feed the main aquifer during recharge?
C. Are there valid background samples to quantify background organic levels?
D. The word "impermeable" should be modified when discussing the basalt levels since Dames and Moore indicates they are discontinuous.
E. Regional aquifers are discussed, but they do not clearly indicate what/where these regional aquifers are located. Are there many of them? Or do they mean the one aquifer where the city wells are. A map of these regional aquifers would be nice. They could discuss transmissivity between them also.
F. Dames and Moore indicate they used preservatives in their sample bottles, but did not use the Alaska methods. That should be clarified.
G. They discharged purge water to the ground? Not an ADEC recommended or accepted procedure.
H. The purge water drum went off island for treatment. Travel and destination needs to be documented.
I. Section 5.2.2 Just because the Eureka well was non-detectable (ND) in November does not automatically lead to the assumption that naturally occurring organics are present.
J. Where is the USCG drinking water well screened? It is probably not appropriately screened for a monitoring well.
Dames and Moore noted in the study that a mounding of groundwater beneath the CG site and a slight reversal of groundwater flow (0.00009) by actual measurement occurs. This report is the first numbers that have indicated a groundwater flow direction, however it is a single measured event. Because the recharge is so dependent on rain, Ray suggests a request for a month long measurement where measurements are made daily with monitoring of weather conditions made concurrently. |
Ray Dronenburg |
| 3/3/1997 |
Update or Other Action |
In 1997, as part of a Hydrological Study and Release Investigation, Dames and Moore developed 11 groundwater wells and three soil vapor monitoring wells to define the vertical extent of contamination and to evaluate the potential for groundwater contamination. Samples were also collected from the City of St. Paul drinking water wells, and from four ponds near the LORSTA. Soil cuttings from 6 of the 11 well borings contained DRO concentrations above background levels, with concentrations appearing to be greater at depth than at the surface.
Free product was encountered in five of the groundwater wells, though not in the City’s drinking water wells. Low DRO concentrations were observed in one drinking water well; however, the concentrations were thought to be a result of naturally occurring organics. Surface water also exhibited trace amounts of DRO which was also thought to be of natural origin. |
Ray Dronenburg |
| 4/1/1997 |
Update or Other Action |
Land records at BLM indicate that the CG site (85 plus acres) is owned by the NOAA and identified as tract 43. According to the Traditional Council, the Native Corporation and subsidiary organizations, this site should be added to the two party agreement between NOAA and ADEC. Then all future cost recovery could be under NOAA. Because the Coast Guard has responded in a positive manner towards cleanup and investigation, this idea has been resisted to date.
Original paperwork Door II Site Description refers to the parcel of land situated on Saint Paul Island containing 72 acres more or less and more particularly described as follows:
Beginning at a United States Coast and Geodetic triangulation sta. marked "South West Base" run South 83 degrees 53 minutes and 09 seconds West a distance of 1105.78 feet to a point designated as REF.#2 thence, N 73 degrees, 59 minutes, 40 seconds W., a distance of 465 feet more or less to a point on the shore of a fresh water lake, which is the true point of beginning of the land to be described, thence:
1-North true a distance of 810.00 feet to a point, thence;
2-North 50 degrees 00 minutes East a distance of 710.00 feet to a point, thence;
3-Due East a distance of 800.00 feet to a point, thence;
4-South 40 degrees 00 minutes East a distance of 940.00 feet to a point, thence;
5-Due South a Distance of 1190.00 feet to a point, thence;
6- South 50 degrees 00 minutes West a distance of 1090 feet to a point, thence;
7-North 40 degrees 00 minutes W., a distance of 1510 feet more or less to a point on the shore of a fresh water lake, thence; Meandering northwesterly with the shore of the lake a distance of 230 feet more or less to the true point of beginning. All is shown on a USCG drawing Number 107250 dated November 16, 1959. Together with a 20 foot wide easement for a pipeline as shown on the drawing Number 107250. |
Ray Dronenburg |
| 4/15/1997 |
Site Characterization Workplan Approved |
(Old R:Base Action Code = SA2A - Phase II SA Approval / Release Investigation). With some exceptions noted in the 4/8/1997 letter to the USDOT USCG Civil Engineering unit, Ray Dronenburg approved a work plan by Dames and Moore to install eight monitor wells and to look at the depth and lateral extent of contamination. Ground water analyses and soil analyses will be provided.
a. Page 6 (Regional Groundwater)
Given the facts as presented in the groundwater section of this report and the facts pertaining to accumulative spill data, ADEC does not concur that the SVE system presently installed and operating represents adequate protection for the water system at risk. Further, ADEC does not concur that conversion of the SVE system to a bioventing system would be adequate to provide protection of human health, safety, welfare or the environment.
Page 7 Par. 3 suggests that it is unlikely that groundwater from the USCG site would ever reach the drinking water supply wells. Par. 2 however does state that tests conducted in 1994 did result in an upcoming of salt water. ADEC feels that a catastrophic event such as drinking water tank failures, major fire or line ruptures could result in excessive drawdown which could result in potential groundwater contamination moving from the USCG site towards the drinking water wells and consequently considers the risk sufficient for concern.
b. Adequate
c. Page 9 bullet #4 ADEC does not believe that photoionization detector (PID) readings can be directly correlated to levels detected in laboratory sampling. ADEC suggests the contractor be asked to submit for lab analyses any sample (PID) that exceeds a certain level (reading) and thereby giving the data more credibility for levels of contamination from surface to bottom.
d. Page 9 bullet #5 ADEC has not been able to locate the validity for the proposed sampling for "major ions using EPA Method 300". A review of the March 1995 EPA Method Status Table does not list a Method 300.
e. ADEC does not concur with the locations for MW-8. Please provide a statement indicating why this site was chosen.
f. concur. |
Ray Dronenburg |
| 4/27/1997 |
Update or Other Action |
(Old R:Base Action Code = SA1A - Phase I Site Assessment Approval). This site is owned by NOAA Saint Paul (reference Tract 43). The Coast Guard has done little to characterize the site. This plan calls for monitor wells and to determine depth and extent laterally for contamination. |
Ray Dronenburg |
| 5/12/1997 |
Update or Other Action |
May 8, 1997 USCG letter regarding workplan for Hydrologic study and Phase IV release investigation.
Purpose of the Phase IV investigation is to evaluate the potential for the surface soil contamination at the site to impact the groundwater. The SVE system currently operating at the site is intended as an interim treatment system. Changes to this system or additional remedial measures may be performed pending results of this investigation.
Item c. The sampling program is based upon 2 factors. Previous studies have sampled to 10 feet and additional sampling in this soil column would not yield significant new information or help determine the vertical extent of contamination. Dames and Moore proposes to field screen all the samples (and if necessary the soil cuttings) every 5 feet using the PID and IR. Samples from the bottom of the contamination and the first clean sample will be analyzed by the lab.
It should be noted they intend to treat wells DM-7 and DM-8 somewhat differently than the wells installed within the contaminated areas of the site. Since these particular wells are located in presumably uncontaminated areas, we will analyze the shallowest samples (< 5 feet below ground surface) to confirm that surface releases have not occurred in these areas, as well as the deepest samples collected from the well borings.
d. Method 300 is for chloride analyses per Methods for Chemical Analyses of Water and Waste EPA document # 500/479/020.
e. Location for well DM-8 was selected to be outside the contaminated area of the site, while still being between the City's North and South wells and the USCG site. It is the CG's understanding that these wells (N and S) may no longer be in use, however they are still in place and have been used in the past as drinking water sources. The CG believes that the possibility exists that the wells could be used at a future date and should be protected from potential groundwater contamination originating from the USCG site. |
Ray Dronenburg |
| 5/14/1997 |
Update or Other Action |
TDX attorney sent letter to NOAA regarding status of Title to Tract 43 USCG Loran station Saint Paul Island. Follow-up letter to March 11, 1997 letter to Daniel Strandy Chief Facilities and Logistics on status of title to same. April 1997 RAB meeting Dan Strandy disclosed that NOAA believes itself to be the owner of record for the72 acre property that the LORAN station is situated on.
Under Section 3(e) of the Alaska Native Claims Settlement Act, the Property (LORAN station) was one of the many sites on Saint Paul Island that NOAA withdrew so that it was not available for selection by TDX as part of TDX's ANSCA land entitlements.
In 1975, TDX objected to NOAA's extensive ANSCA Section 3(e) withdrawals because they were not the "smallest practicable tract(s) enclosing land actually used in connection with the administration of a federal installment" as required by ANSCA 3(e).
To avoid litigation with TDX over TDX's ANSCA land entitlements, NOAA entered into the 1976 Memorandum of Understanding (1976 MOU) with TDX.
The Coast Guard plans to vacate the Property within the next few years; therefore, NOAA is contractually obligated under the 1976 MOU to convey the property to TDX. NOAA's contractual obligations to TDX under the 1976 MOU clearly bring the Property within the provisions of PL 104-91.
NOAA must therefore, implement both the local hire and environmental liability protection provisions of PL 104-91 with respect to the Property. TDX also urges NOAA to formally designate the Property as a cleanup site under the "two-party agreement."
TDX understands that the Coast Guard is currently under contract with Dames and Moore to perform environmental cleanup work on the Property. TDX will not demand immediate local hire on this job, BUT ONLY if NOAA immediately meets with local Aleut entities and DEC's representative Ray Dronenburg, to discuss future cleanup work on the Property which can and should be performed by the local Aleut entities.
NOTE TO FILE: 18 AAC 75.355 (b) requires a responsible person and the owner or operator of an offsite or portable treatment facility under 18 AAC 75.365 shall ensure that the collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party.
“Qualified person” means a person who actively practices environ-mental science or engineering, geology, physical science, hydrology, or a related field and who has the following minimum education and experience:
(A) a bachelor's degree or equivalent from a nationally or internationally accredited post-secondary institution in environmental science or engineering, geology, hydrology, physical science, or a related field; for purposes of this subparagraph, “equivalent” means at least 128 semester hours, 168 trimester hours, or 192 quarter hours at an accredited post-secondary institution, with at least 18 percent of those hours in a science major and at least 13 percent of those hours in upper division-level courses; and
(B) at least one year of professional experience in environ-mental science or engineering, geology, physical science, hydrology, or a related field, obtained after the degree in (A) of this paragraph was obtained. |
Ray Dronenburg |
| 5/27/1997 |
Update or Other Action |
Letter from USCG to NOAA regarding comments on workplan for hydrologic study and Phase IV investigation. The USCG can easily incorporate NOAA's comments (Mary Moloseau Goetz) in the final revision to the plan. The USCG will also survey NOAA's monitoring wells near the Saint Paul Landfill, as the information will prove beneficial to both the USCG and NOAA. Please provide the USCG with any site plans or drawings NOAA may have for these monitoring wells. |
Ray Dronenburg |
| 6/11/1997 |
Update or Other Action |
6/4/1997 NOAA response to TDX attorney's letters of March 11, 1997 and May 14, 1997.
This parcel (LORAN Station) is designated on the Bureau of Land Management (BLM) Master Title Plat (MTP) for Saint Paul Island as Tract 43, consisting of 84.88 acres. As indicated on the MTP, this parcel was among NOAA's withdrawals under sect. 3(e) of ANSCA. The parcel is so identified in the 1976 MOU among TDX, and the Tanaq Corporation and the Department of Commerce, NOAA, National Marine Fisheries Service (NMFS) regarding Pribilof Islands land selection (1976 MOU), wherein it is designated by reference number 8A (which also appears on the MTP), and described as the USCG Loran Station.
The best information presently available appears to indicate that NOAA owns Tract 43, which is presently occupied by the USCG as authorized under a MOA executed in 1965 between the USCG and NMFS' predecessor agency the Bureau of Commercial Fisheries (1965 MOA) (copy enclosed).
In addition to its identification as a NOAA property in the 1965 MOA, the 1976 MOU and the MTP, Tract 43 is identified as a parcel to be retained by the US, acting by and through the Secretary of Commerce, under the 1984 agreement among the Pribilof Island entities, the State of Alaska, and NOAA regarding "Transfer of Property on the Pribilof Islands: Descriptions, Terms, and Conditions" (TOPA), which implemented a provision of the Fur Seal Act amendments of 1983 regarding disposal of federal property on the Pribilof Islands (16 USC 1165).
Site Cleanup-The USCG has assumed full responsibility for identifying and cleaning up contamination on Tract 43. NOAA is satisfied with the work conducted by the USCG to date, and will continue to defer to the USCG to take the lead on site cleanup. NOAA will monitor the progress of the USCG's efforts. If in the future it appears necessary for NOAA to assume a role in cleaning up Tract 43, additional options may be considered. At least 2 misstatements are in the May 14, 1997 letter NOAA wishes to correct. NOAA has never stated any intention to amend the "Two Party Agreement" between NOAA and ADEC to include Tract 43, nor has NOAA ever indicated that funds designated for the Saint George Sealing Plant would be allocated to pay for cleanup work on Tract 43. Signed Daniel Strandy Chief, Facilities and Logistics Division. |
Ray Dronenburg |
| 7/24/1997 |
Update or Other Action |
USCG letter to Nancy Briscoe Office of General Counsel Natural Resources Silver Spring MD. The USCG agrees with NOAA that remediation at Coast Guard LORAN Station Saint Paul Pribilof Islands is outside the scope of the two-party agreement between NOAA and ADEC. The USCG has assumed responsibility for remediating contamination at the LORAN station in accordance with State regulations. The USCG is committed to working with ADEC to obtain a certification of "no further action" at the site subject only to the availability of appropriated funding and adequate resources. The USCG is committed to keeping the NOAA Pribilof Island Project Manager apprised of remediation plans and progress and to keeping local entities and residents informed by participating in the two party agreement remedial advisory board meetings as appropriate. Enclosed is a copy of the May 2, 1997 letter from the Commanding Officer of the Coast Guard Civil Engineering Unit Juneau Alaska to NOAA Western Administrative Support Center that further details the Coast Guard's commitment. Signed Edward F. Wandelt Chief Environmental Management Division U.S. Coast Guard by Direction of the Commandant. |
Ray Dronenburg |
| 8/7/1997 |
Update or Other Action |
(Old R:Base Action Code = RI - Remedial Investigation). Phase IV investigation completed by Dames and Moore. Approximately 40,000 gallons of various petroleum products on the ground water which is hydraulically connected to the St Paul DW system less than 500 yards away. |
Ray Dronenburg |
| 8/28/1997 |
Site Ranked Using the AHRM |
Site reranked. Changed Quantity Value from 3 to 4; Site Access Value from 1 to 0; Population Density Value from 5 to 3; Environmental/Recreation Area from 2 to 0; and Multiple Sources from "n" to "y". |
Ray Dronenburg |
| 8/28/1997 |
Update or Other Action |
(Old R:Base Action Code = RDRA - Remedial Design / Remedial Action). Response letter to CG requesting additional information for GW flow direction and requiring product recovery commence prior to September 15, 1997 |
Ray Dronenburg |
| 9/11/1997 |
Update or Other Action |
9/9/97 USCG letter to Ray Dronenburg regarding draft hydrologic study and release investigation Phase IV for LORAN station Saint Paul. In response to your recommendations and 15 September 1997 deadline the USCG would like to provide an update to its intended actions and associated execution dates.
Dames and Moore of Anchorage will conduct routine monitoring of the groundwater and free product conditions at the site. Data logger monitoring devices will be used to study the groundwater fluctuations that may occur over a 30 day period due to local precipitation. Quarterly monitoring of the USCG wells and selected City of Saint Paul drinking water wells. They intend to begin the 30 day study upon ADEC acceptance of the forthcoming workplan and completed procurement of the data logger monitors. It is expected installation of the loggers will take place in October 1997. Quarterly monitoring shall commence in that month and continue every 3 months thereafter.
To address the threat from free product found below the LORAN station, the USCG is involved in the development of a customized free product removal pump. It will work with the varying oil viscosity they have found across the site and work in the monitoring wells. They are also currently developing and evaluating techniques for the complete restoration of the site. |
Ray Dronenburg |
| 10/20/1997 |
Document, Report, or Work plan Review - other |
ADEC letter to USCG regarding USCG LORAN site Hydrologic Monitoring Investigation.
Page 10 par. 4.6.1 Purge Water: The paragraph suggests an oil-water separator will be used to remediate the drummed groundwater and after separation the water may be discharged to the ground. ADEC has developed a wastewater general permit (Permit Number 9640-DB003) which outlines requirements for discharge of contaminated ground waters. Attached is a copy of the permit for your consideration.
Page 10 par. 4.6.2 Petroleum Product: Please advise ADEC regarding the ultimate fate for the oil product removed from the ground and remediated using the oil-water separator. ADEC approves the purpose and scope for the project and the work plan is approved, however ADEC suggests the completion of the wastewater permit be required prior to any discharge of generated contaminated wastewater. It is also requested that consideration be given for the use of monitoring wells installed by NOAA for their landfill closure effort. These wells are to south and east of the LORAN site and might broaden the area of concern without a great deal of additional cost to the USCG. |
Ray Dronenburg |
| 10/27/1997 |
Update or Other Action |
USCG letter 10/23/1997 sent to City of Saint Paul Public Works Manager regarding request for permission to sample several city wells on a quarterly basis. At least a two day notice will be given and with the City's permission, they will sample: Fredreka 1 and 2, Eureka Monitoring well and either the North or South well. First sampling event to be during November 3-7, 1997. Sampling results will be used to confirm (or prove) that petroleum contamination on CG property has not contaminated the City's drinking water. |
Ray Dronenburg |
| 10/30/1997 |
Update or Other Action |
USCG letter dated 10/29/1997 regarding Review comments on Hydrologic Monitoring Investigation. It is the USCG's intention to pursue a general wastewater permit concurrent with the development of the next full scale remedial phase to be developed this winter (1997-1998) for the LORAN site. In the interim, one drum of purge water will be generated each quarter and shipped to the CG facility in Kodiak for proper disposal in the Liquid oily waste system on Base.
Request modification of the existing monitoring investigation, to allow CG to conduct 30 day data logger study in the spring. Current precipitation on Saint Paul is mixture of snow and rain which could alter or retard true recharge rates and skew the test data.
Skimmer test pumping during 10/16-23/1997 on wells DM-2 and DM-5 since they had the highest measurements of free product found during the hydrologic investigation. DM-2 initially contained 2.5 inches of clear free product and was reduced to a sheen within a 24 hour period. However, product returned within a 24 hour period but subsequent pumping reduced it to 0 inches at the end of the week. 40 gallons total of free product and water were recovered and liquid will be shipped off to Kodiak. DM-5 started off with 4 inches of darker free product and could only be pumped to 0.38 inches by the end of the week. 65 gallons of free product and water were recovered. The USCG will be remeasuring the free product levels during the next quarterly monitoring at the site. |
Ray Dronenburg |
| 11/1/1997 |
Long Term Monitoring Established |
Dames and Moore conducted the first quarterly sampling event of the groundwater long term monitoring at the site. Free product had increased in all wells since June 1997 event with the exception of Well DM-2. DRO and BTEX were not detected in any of the nearby City drinking water wells or the Eureka monitoring well. |
Louis Howard |
| 11/13/1997 |
Document, Report, or Work plan Review - other |
Ray Dronenburg letter to USCG regarding USCG LORAN station contamination and cleanup.
ADEC has obtained from Reginas, the protocol for use of ORC for in-situ bioremediation. The information provided by the manufacturer indicate parameters that have not been determined in previous investigation that the placement of ORC socks might serve no purpose and in fact could be detrimental to the project.
Oregon Department of Environmental Quality has indicated that a potential exists for an overabundance of released oxygen resulting in the "cracking" of compounds which then creates exotic compounds far more lethal than the original compound of concern. ADEC has requested the CG not use the ORC socks at this time. ADEC will continue to research the method of cleanup.
Thirty day monitoring report: It may be reasonable to continue with monitoring ground water height during the low yield months for several seasons. Because groundwater demand does not "let up" during the winter, it would also be beneficial to determine groundwater levels during low recharge periods which might indicate a reversal of groundwater flow, especially given the very low gradient for flow direction of 0.0009. ADEC therefore suggests the USCG reconsider setting aside the project of monitoring and, in fact, consider additional monitoring to include the winter months or periods of low recharge.
Use of NOAA wells: NOAA has installed five wells which would, by available data, be downgradient from the CG site approximately 500 yards south/south east. ADEC feels that these wells could provide additional monitor points in the determination for groundwater flow direction and velocity. Discussion with Lieutenant Woloszynski indicated that Dames and Moore did not feel the use of the wells would be beneficial in this study. ADEC suggests the CG reconsider this position. |
Ray Dronenburg |
| 12/9/1997 |
Update or Other Action |
USCG sent Ray Dronenburg lab results of the free product from well DM-5. Used oil burn spec analysis was conducted since the USCG felt it was necessary since this area was used historically for the disposal of used oil. Free product does not exhibit any RCRA or TSCA characteristics above regulatory limits. USCG intends to obtain hydrologic data from the monitoring wells located near the landfill. The USCG will also conduct a cold weather 30 day data logger study of the groundwater in addition to the proposed study this spring (1998). Winter event will be scheduled for February 1998 and they will not install any Oxygen Releasing Compound (ORC) socks until more data regarding the byproducts associated with their usage is known. |
Ray Dronenburg |
| 1/5/1998 |
Document, Report, or Work plan Review - other |
Ray Dronenburg letter to USGS regarding final report hydrologic monitoring investigation 1st Quarter sampling event USCG LORAN station.
a) The report concludes that the slight flattening of the regional gradient (0.0006 November 1997 vs. 0.0009-June 1997) between June and November is likely the result of storm occurrence, variable water migration rates and rapid response of groundwater levels to rainfall. All of which strengthens ADEC's concern that seasonal variations could result in groundwater contamination moving "slightly northwest" or toward the Saint Paul drinking water wells.
b) Review of the August 1997 report indicate that the levels of petroleum exceed previously reported limits for DRO and for xylenes, reports new findings where xylenes were not previously reported. The practice of discharge for sump waters directly to surrounding soils is probably not a reasonable practice to continue given the information provided by the two Dames and Moore reports. ADEC requests the USCG demonstrate, with discharge logs, that water discharges from secondary containment was not contaminated and that the continued discharge of this secondary containment water will not further aggravate existing contamination problems.
c) Page 13 bullet six: indicates that the 30 day monitoring event will occur in May 1998. ADEC had suggested that an additional 30 day monitoring period be considered during periods of low or no recharge due to snow or freezing conditions. Based on these data provided by Dames and Moore, it now appears that only with additional monitoring will concerns for groundwater flow directions be answered.
The Final Report, First Quarter Sampling Event did little to answer the most important question of groundwater flow. The problem encountered during the preparation of this report with increased product thickness hampering efforts to obtain accurate groundwater elevations, strengthens the suggestion that a continuous effort is required versus a single day in a given month. It is noted that diesel range organics (DRO) concentrations, in milligrams per liter (mg/L), did decrease during the reporting incident however the significance of this fact is not clear to ADEC. |
Ray Dronenburg |
| 1/27/1998 |
Update or Other Action |
USCG letter to Ray Dronenburg regarding expected schedule of events for site restoration work for CG LORAN station Saint Paul Island. Expect to contract the design and permitting of a High Vapor Extraction (Dual Phase Recovery) system this February 1998. Final workplan for ADEC approval would be submitted by late April. Upon approval of a workplan by ADEC, the actual installation of the system could occur as early in the summer as logistics can permit (June or July). USCG expects the HVE system to be operational one month after start of construction. All ongoing sampling and maintenance would be outlined in the workplan and would continue throughout the year.
Quarterly monitoring of the City of Saint Paul's drinking water wells, the monitoring wells on the LORAN site, as well as those wells at the NOAA landfill will continue through our consultant Dames and Moore. They will also be performing 3 separate 30 day data logger studies, each associated with the upcoming quarterly monitoring events scheduled for February, May, and August of this year. |
Ray Dronenburg |
| 2/2/1998 |
Update or Other Action |
2/3/1998 TDX attorney letter to USCG regarding Tract 43 falling under the parameters of PL 104-91. TDX believes it's legal. |
Ray Dronenburg |
| 2/9/1998 |
Update or Other Action |
2/3/1998 TDX attorney letter to USCG regarding ADEC comments on the USCG Final Report Hydrologic Monitoring Investigation First Quarter Sampling Event LORAN station Saint Paul Island.
TDX is very concerned that environmental contamination appears to be migrating through the aquifer towards the fresh water drinking water wells, which constitute the only source of potable water on the Saint Paul Island. TDX is worried that the high volume of water draw down during the current crab processing season will cause such contamination to migrate far more rapidly than the USCG Report anticipates. TDX urges the USCG to adopt all of the changes set forth in the ADEC letter and to make removal of the free product from the aquifer your highest priority.
TDX is also concerned the USCG has informally taken the position that Tract 43 does not come within the parameters of PL 104-91. TDX does not agree with the CG's informal position (see TDX letter to B.J. Goettler CO dated February 2, 1998). As owner of the surrounding land, TDX fears that in addition to environmental pollution migrating through the aquifer, there is significant probability that environmental pollution from Tract 43 may also migrate on to TDX's surrounding lands through the soil, surface water runoff and other environmental pathways. Without the protections of PL 104-91, TDX could conceivably be held jointly and severally strictly liable (i.e. liable without fault) for the cost to cleanup any migrating pollution which crosses from Tract 43 on to TDX surrounding lands. In the event that ADEC or U.S. EPA elected to pursue TDX to perform such cleanup work, TDX would have no choice but to take legal action against the USCG to recover its cleanup costs or otherwise ensure the USCG cleaned up any such pollution which migrated on to TDX lands. TDX would therefore appreciate an acknowledgement from the USCG that Tract 43 comes within the environmental liability protection provisions of PL 104-91.
Finally, TDX agrees with ADEC's recommendations that a continuous effort is required to monitor the important question of groundwater flow from Tract 43 through the aquifer. TDX believes that the environmental pollution which had migrated into the aquifer from Tract 43 presents an imminent hazard to both human health and the environment on Saint Paul Island that must be corrected immediately. |
Ray Dronenburg |
| 2/9/1998 |
Update or Other Action |
Letter from Tanadgusix Corp. (TDX) attorneys (Owens & Turner) to B.J. Goettler Commanding Officer, USCG, CE Unit Juneau RE: USCG Loran Station on St. Paul Island, AK-Environmental Clean-Up Site. As you may be aware, TDX is the owner of the surface estate of all of the land surrounding Tract 43, U.S. Survey 4943, St. Paul Island, AK, also known as the U.S. Coast Guard (USCG) Loran Station ("Tract 43"). TDX has been carefully monitoring the USCG's efforts to cleanup & remediate the extensive environmental pollution on Tract 43. The purpose of this letter is to inform you of TDX' legal position that Tract 43 comes within the local hire provisions of Public Law 104-91 ("PL 104-91") with respect to the USCG's environmental cleanup program for Tract 43.
TDX has been made aware of correspondence between the USCG the National Oceanic & Atmospheric Administration ("NOAA"), to the effect neither the USCG nor NOAA agrees Tract 43 comes within the parameters of PL 104-91. However, TDX has yet to hear formally from NOAA or the USCG to such effect. It is in everyone's best interest to avoid costly & time consuming litigation over such disagreement that would divert funds away from the environmental cleanup program for Tract 43. This letter conveys TDX' request the USCG commit to enter agreements with TDX' wholly-owned subsidiary Bering Sea Eccotech, Inc. (“Eccotech") & other Aleut entities & residents of St. Paul Island, to perform significant aspects of the Tract 43 environmental cleanup program which they are qualified to perform.
In a June 4, 1997 letter ("NOAA Letter") from NOAA to TDX, NOAA is the owner of record of Tract 43. Tract 43 is also identified in the 1976 Memorandum of Understanding ("1976 MOU") between the Dept. of Commerce, NOAA & TDX, among others, where it was designated as a parcel to be retained in ownership by NOAA pursuant to the AK Native Claims Settlement Act ("ANCSA"; 43 U.S.C. § 1601 et seq.) Section 3(e) & therefore was unavailable for selection by TDX pursuant to TDX' general land entitlements under ANCSA Section 12(a). Under ANCSA § I2(a), TDX was entitled to select, & did select, all of the land on St. Paul Island except for the smallest practicable tracts of land reasonably necessary for the continued operation of federal installations. The Dept. of Commerce & NOAA entered into the 1976 MOU to clarify with TDX which lands on St. Paul Island were then necessary for ongoing government operations & would be retained in ownership by the federal government & which lands would be released for selection by TDX. Due to the shortage of land on St. Paul Island TDX was unable to fulfill its ANCSA § 12(a) land entitlements after selecting all available land on St. Paul. TDX was forced to select additional land elsewhere in the Aleut region. However, TDX remains an "under selected" ANCSA Village Corp. which, 26 years after ANCSA, has yet to receive all of its § 12(a) land entitlements from the federal government.
The parties to the 1976 MOU fully realized the high priority TDX placed on receiving every available square foot of land on St. Paul Island which might become available in the future as a result of changes in government operations. In Section 6(f) of the 1976 MOU the Department of Commerce & NOAA clearly obligated themselves to transfer any of NOAA's remaining ANCSA § 3(e) properties on St. Paul Island to TDX as soon as they were no longer necessary for carrying out federal government responsibilities.
According to the NOAA Letter, in 1965 the predecessor to the Dept. of Commerce entered into a Memorandum of Agreement ("MOA") with the USCG allowing the USCG to use & occupy Tract 43. Such agreement was later amended & extended for an indefinite term by a written agreement dated February 10, 1970. However, despite the fact that the USCG is occupying Tract 43 under the MOA, Tract 43 is still subject to the 1976 MOU & NOAA's commitment therein to convey such parcel to TDX at such time as it is no longer necessary for federal government operations. Based on all of the foregoing, TDX asserts Tract 43 comes within the express provisions of PL 104-91 § 3(a) as land which "the National Oceanic & Atmospheric Administration .... is obligated to transfer to local entities or residents of the Pribilof Islands, Alaska pursuant to .... applicable law."
TDX has no problem with the USCG taking the lead on the environmental clean up program for Tract 43, in light of the fact the environmental pollution thereon appears to have been caused in the course of USCG operations. However, TDX would like to point out that PL 104-91, the Fur Seal Act of 1966, including its 1983 amendments, & ANCSA are all federal laws intended for the benefit of the Aleut people of the Pribilof Islands. As such, they individually & collectively constitute Indian welfare legislation must be interpreted broadly to affect their intended remedial purpose, with all doubts resolved in favor of the Pribilof Aleuts. |
Ray Dronenburg |
| 2/25/1998 |
Update or Other Action |
Ray Dronenburg letter to USCG regarding 1/27/1998 USCG letter to ADEC. ADEC is concerned for the potential contamination to the drinking water systems of Saint Paul and is appreciative that the Coast Guard is responding quickly and efficiently to begin immediate steps to protect those systems. The HVE system appears to be a reasonable approach to this remediation given those data available to date. Careful consideration should be given to the development for an approved approach to extracted groundwater cleanup. Discharge will probably be to the marine environment and could require limits to "non-detect".
ADEC considers the monitoring program initiated by the CG for the groundwater flow direction, free product identification and potential plume delineation as extremely important to the overall cleanup effort. The schedule for events as outlined appears to be appropriate given the engineering and financial considerations for the project. |
Ray Dronenburg |
| 3/17/1998 |
Update or Other Action |
USCG letter to Erin Rose Attorney for TDX Corp. regarding USCG LORAN station Saint Paul Island. 2/2/1998 letter to USCG requested the Coast Guard commit to enter agreements with TDX's wholly owned subsidiary Bering Sea EccoTech and other Aleut entities and residents of Saint Paul Island to perform significant aspects of Tract 43 environmental cleanup which they are qualified to perform. 2/3/1998 letter requested the USCG acknowledge that the Tract 43 lands surrounding the CG LORAN station come within the environmental protection provisions of PL 104-91. It is the CG's position that PL 104-91 is inapplicable to the cleanup planned by the Coast Guard at its LORAN station on Saint Paul during 1998. Accordingly the CG cannot comply with either of these requests. However, the CG hopes the information in this letter will enable you to conclude that your client's concerns will be adequately addressed.
The CG has assumed responsibility for identifying and cleaning up the contamination at the LORAN station to ADEC standards. To this end, March 11, 1998, it issued a work order to the Alaska District USCOE for the design, permitting, installation, and operation of a High Vacuum Extraction system to be installed during the summer 1998. The CG issued this work order to the COE pursuant to the Economy Act (31 USC 1535) and FAR 48 CFR subpart 17.3 because of the CORPS's technical and contracting expertise in the fairly new and complex HVE technology. The plan will include consideration of 8(a), small business, small disadvantaged business and women owned small business firms as required by FAR 48 CFR Part 19 and the underlying statutes, as well as compliance with the Competition in Contracting Act as required by 10 USC Sec. 2304 and FAR 48 CFR Part 6.
PL 104-91 does not apply to this or future Coast Guard cleanup projects. The legal implications of both the local hire and liability protections with regard to the CG turn on the fundamental applicability of PL 104-91, Section 3. The obligations imposed on the Federal Government by Section 3 are SOLELY those of the Secretary of Commerce to be satisfied out of appropriations earmarked for that agency and are NOT the obligations of the Secretary of Transportation operating through the Coast Guard's environmental restoration program. Accordingly, neither the local hire requirements, liability contribution protections, nor any other provisions of Section 3 (PL 104-91) are applicable to the Coast Guard. |
Ray Dronenburg |
| 6/12/1998 |
Update or Other Action |
May 7, 1998 report received in June showed wells DM-1, DM-7, DM-8, DM-12, DM-13 and DM14 had diesel range organics (DRO) detected in varying amounts: 0.129 mg/L to 22.1 mg/L. Free product was found in DM-2 through DM-6 and were not sampled. DM-4 and DM-6 had free product consistent with used oil. The used oil historically at the site was dumped on the ground behind the garage bays in the vicinity of well DM-5. Thickest layer of free product was 10.0 inches at DM-6 and thinnest layer was 2.9 inches at DM-2. DRO concentrations in well: DM-1 decreased from 61.5 to 22.1 mg/L and DM-12 from 2.70 to 1.38 mg/L. 18 AAC 75 Table C groundwater criteria for DRO is 1.5 mg/L. |
Louis Howard |
| 6/23/1998 |
Update or Other Action |
Ray Dronenburg letter to the USCG regarding Hydrologic Monitoring Investigation for the LORAN Station Saint Paul Alaska. The soil vapor extraction system has been installed and operating since 1996. ADEC has requested on several occasions, data from the installed SVE system which would substantiate the success (or failure) of this system. While the system continues to be referenced as a highly successful effort no data has ever been presented to support the USCG's statements about its effectiveness. ADEC requests the data be provided from the system's start up date (to the present date). |
Ray Dronenburg |
| 6/24/1998 |
Update or Other Action |
Email communication from Lynn Bush to Ray Dronenburg: 4 regulated underground storage tanks' history. Tank 1 installed in 1975 carrying 1,000 gallons of diesel fuel removed in August 1986, Tank 2 installed in 1960 carrying 1,000 gallons of diesel and removed in August of 1986, Tank 3 installed in 1970 carrying 550 gallons of diesel and removed in 1980, and finally Tank 4 installed in 1960 carrying 5,000 gallons of gasoline and removed in August 1993. |
Lynne Bush |
| 7/13/1998 |
Update or Other Action |
USCG sent Kent Patrick-Riley a copy of the November 1993 Terrasat Inc. UST site assessment USCG NORPAC Master Loran-C station Saint Paul, Alaska. Cover letter states although petroleum contaminated soil was discovered during tank removal, the site assessment has determined that the removed tank was not the source.
Excavation was conducted on August 16, 1993 and soil samples were collected to evaluate potential contamination from the UST. Location of the USCG Loran Station is Township 35 S, Range 131 West, Pribilof Islands. The UST was used to dispense gasoline until December 4, 1991 according to Terry Philemonoff of the USCG.
3 soil samples were collected from 1 foot below the former 5,000 gallon UST (9 feet below ground surface) and analyzed using 8020 for BTEX, 8015M for gasoline range volatile petroleum hydrocarbons (VPH). Cleanup level is 15 mg/kg BTEX and 100 mg/kg gasoline range organics (VPH). Soil sample CG-3 contained 19.26 mg/kg total BTEX and 120 VPH (gasoline range organics). Laboratory chromatograms however, indicate that the contamination is diesel range hydrocarbons. GRO are integrated between 6 and 20 minutes on the gasoline chromatogram. Maximum peaks for gasoline are generally seen at about 16 minutes. Samples from this site eluted beyond the gasoline range with maximum peaks of 23 to 26 minutes. The investigation indicates the diesel investigation is migrating across the UST site from another source to the east of the former UST. |
Kent Patrick-Riley |
| 7/17/1998 |
Update or Other Action |
Ray Dronenburg sent letter to the City Manager of City Of Saint Paul. Questions: does the City maintain water usage data (by gallons) and could those numbers be correlated with dates of processing or periods of excess water usage? The purpose would be to attempt to determine a potential for drawdown of the aquifer, which could result in an increased movement of floating product from under the CG site towards the groundwater wells. Also, with the HVE system operational, a large zone of influence impacted by 29 inches of vacuum, together with a high demand for fresh water could result in an upwelling of salt water. |
Ray Dronenburg |
| 7/30/1998 |
Cleanup Plan Approved |
Workplan for construction of an HVE system at the USCG Loran station was approved by Ray Dronenburg. Work is scheduled to begin on Saint Paul 8/1/98 and startup of system on 8/31/98. |
Ray Dronenburg |
| 8/3/1998 |
Update or Other Action |
In 1998, the USCG designed, constructed, and installed an HVE system to eliminate free
product from groundwater beneath the LORSTA. |
Ray Dronenburg |
| 9/3/1998 |
Document, Report, or Work plan Review - other |
ADEC letter to the USCG regarding HVE system monitoring plan. 9/2/98 ADEC received a fax of a revised monitoring plan for the LORAN site. ADEC does not concur with the revised vapor monitoring frequency at each individual well from monthly to quarterly to coincide with quarterly groundwater and product monitoring.
However, it would be reasonable if the contractor would agree to weekly sampling for vapor discharge at the discharge stack for the first 4 weeks of the project. At that point, with 5 sampling events as background data, quarterly vapor monitoring could be acceptable (to ADEC).
Soil sampling which would occur on a 3 year basis was deleted from the project. ADEC will require soil sampling to confirm the success for the effort and before shutdown of the system. ADEC has reevaluated its position on reinjection and hereby approves the reinjection of treated groundwater based on the present monitoring plan and methods for treatment. ADEC anticipates receiving data from the HVE system in a timely manner so as to make reasonable determinations that the system is working.
Based on those data, ADEC could determine that monitoring as approved herewith, to include reinjection could not longer be acceptable. Please be advised that reinjection for treated water is a permitted function overseen by the EPA. By copy of this letter, ADEC is advising Jonathan Williams (US EPA) of the State's position and requesting their agreement. |
Ray Dronenburg |
| 9/10/1998 |
Update or Other Action |
USCG sent EPA letter regarding inventory information on the Saint Paul LORAN High Vacuum Extraction System injection well.
1. The injection well is located at USCG LORAN Station Saint Paul Alaska.
2. The USCG POC is Tessa Muehllehner Civil Engineering Unit, P.O. Box 21747 Juneau, AK 99802-1747.
3. The facility is owned by the USCG.
4. The injection well is a class V aquifer remediation well. Water will be extracted from the aquifer at approximately 12 gpm, treated through an oil/water separator and activated carbon filters, and injected cross-gradient from the extraction wells.
5. The injection well will become active in October 1998 and is anticipated to run for approximately three years. |
Ray Dronenburg |
| 10/20/1998 |
Document, Report, or Work plan Review - other |
Ray Dronenburg sent letter to USCG regarding faxed memorandum from Tessa M. USCG. The memorandum reported on September 17, 1998 consultants for the CG had sampled a drinking water well on Saint Paul Island and found toluene and xylene in Fredrika 1 (a drinking water well for Saint Paul). This "hit" for toluene and xylene constituents is of great concern to ADEC as well as the lateness of the USCG reporting the "hit" to ADEC (not notified until October 15, 1998).
ADEC requests the Coast Guard provide, in writing no later than November 1, 1998, notification as to the exact date and some assurance that continued operation for the system is "in place".
ADEC strongly recommends that the CG consider placement of future monitoring wells so that it can be determined if a contamination plume emanating from Telegraph Hill (TPA 15) towards the recharge area or the Coast Guard site exists or not. Additionally, a primary concern for ADEC is the availability of data in a timely manner.
ADEC request that Dames and Moore be instructed to put Public Water System Identification numbers on each water sample taken from a Class "A" drinking water well. In that manner, water sample information from those analyses will be reported directly to the Water Program. |
Ray Dronenburg |
| 10/28/1998 |
Update or Other Action |
ADEC Keven Kleweno Drinking Water and Wastewater Program sent letter to John R. Merculief City Manager regarding Recent Water Quality Tests of water taken from Fredreka Source Wells 1 and 2 PWSID Number 260286. 9/17/98 sampling detected toluene and xylene and 9/28/98 sampling from five source wells were non-detectable for BTEX or DRO. ADEC wishes to emphasize that the levels of toluene and xylene found in Fredreka Source Well 1 (USCG 9/17/98 sampling effort) do not pose a health problem.
Other potential sources for contamination of the aquifer were found during discussion with staff. Material being used in the construction of the Bethel seawall is being blasted and removed by heavy equipment from an area north and west of the Fredreka source wells. A report prepared by the Alaska Division of Water (Munter/Allely 1994) indicates that the Saint Paul aquifer receives recharge near the well field relatively rapidly. A second report by URS Corp. (July 1987) suggests that regional recharge to these basaltic aquifers is probably from barren rocky uplands rimming the watershed from the northwest to the northeast. These reports suggest that the area the rock is being removed from an area that may be the major recharge area for the aquifer that the City of Saint Paul is obtaining water for drinking and commercial uses.
Staff is obtaining information on the location of the blasting and type of material used. If commercial explosives (70%-90% ammonium nitrate by weight) are being used, either spillage or incomplete detonation could leach ammonia or nitrates into the groundwater. Please begin monitoring all water being produced by this well field for nitrate (as nitrogen) on a monthly basis. Over the next 12 months, it is hoped that enough information will be collected and analyzed to determine if the blasting has affected the water quality. All analytical results should be sent to ADEC with the PWSID Number 260286 for review as soon as they become available. |
Kevin Kleweno |
| 10/29/1998 |
Update or Other Action |
USCG to ADEC regarding: meeting with USCG and Keven Kleweno on 10/23/1998. USCG will sample Fredreka 1 through 5 in November and December and sample Fredreka 1, 2, and 5 in late February and March. All sampling will include DRO, BTEX, and water level measurements. All sampling results to be reported directly from the lab to ADEC through Saint Paul's Public Water System Identification Number. USCG will ensure that the City of Saint Paul receives a copy of the results as soon as they are available. The USCG anticipate the HVE system installation to be completed by October 30, 1998 followed by a week of startup testing. After successful startup testing, the system will be operational by the 2nd week of November. USCG to send weekly reports and sampling results during the system startup and initial operation period.
In regards to the suggestion that USCG place monitoring wells near Telegraph Hill (TPA-15) to determine if contamination is coming from that site, the USCG plan to wait until data from the November through March sampling events is available before making a decision. USCG is more than willing to work with NOAA, U.S. Army Corps to ensure the city's water supply is protected. |
Ray Dronenburg |
| 11/5/1998 |
Update or Other Action |
USCG letter with Third quarterly sampling October 1998 report received. No contamination in Fredreka 1 and 2 or South well (city drinking water wells. 0.16 ppm DRO in Eureka well which the USCG suspects to be naturally occurring organics. For the first time toluene and xylenes were detected in DM-12 and DM-13. NOAA and City drinking water wells were incorrectly resurveyed as a part of the scope. Product thickness in feet increased for: DM-2 .24 to .53, DM-3 .40 to .47, DM-4 .82 to .92. DRO concentrations increased in the following wells (concentration in mg/L) from 22.1 to 45.2 for DM-1, DM-8 0.129 to 1.66, DM12 1.38 to 15.7 and DM-14 0.671 to 1.38 mg/L. Eureka drinking water well increased from ND to 0.160 mg/L (160 ug/L) which is still below the 18 AAC 75 Table C values of 1.5 mg/L criteria. |
Ray Dronenburg |
| 11/17/1998 |
Update or Other Action |
Ray Dronenburg sent USCG letter regarding High Vacuum Extraction system. Questions still remain regarding the site. For example, the extent of the plume from the USCG Loran Station remains unknown. ADEC suggests there is an immediate need to:
1. Identify the limits of the contamination plume. This will require at minimum of one well between MS-22 and the five Fredreka Source Wells that does not find contamination (outside the plume). It is also recommended other monitoring wells be placed south and north (a discretionary distance) of the clean monitoring well directly between the MS-22 well and the five water system source wells (Fredreka). These monitoring wells should follow the leading edge of the contaminant plume.
2. Identify new monitor wells within the immediate vicinity of the contamination source area that will be dedicated to monitoring groundwater flow direction and potential contamination movement while the HVE system is operational.
3. Identify a line of new monitoring wells just within the leading edge of the contaminant plume as discussed previously.
Ms. Muehllehner has indicated that she anticipates turn on of the system during the first week of December. ADEC requests accommodations from the USCG (flight, room and board) for Ray Dronenburg and Mr. Keven Kleweno to attend this function. Mr. Kleweno will be reviewing the startup with concerns for source protection. |
Ray Dronenburg |
| 1/4/1999 |
Update or Other Action |
FAX from Polarconsult Alaska Inc. to Keven Kleweno regarding Saint Paul Domestic Water Aquifer. Michael Dahl talked to Gary Paulusof Red Samm construction on the proposed breakwater project. Gary is the engineer for Red Samm and stated the blasting agent they use in the quarry during construction of the airport is ANFO. ANFO (ammonia, nitrogen, fuel oil). |
Kevin Kleweno |
| 1/12/1999 |
Update or Other Action |
USCG 12/31/1998 letter regarding 11/12 and 11/17 1998 letters. Only 5 of the existing monitoring wells are hooked up to the HVE system and seven new wells were drilled exclusively for the HVE system. That leaves 7 dedicated monitoring wells surrounding the area of floating fuel under the buildings. All 12 of the HVE wells can and will be used to monitor both the thickness of the floating fuel, and the water contamination levels. Given the complex nature of the subsurface soil structures, the USCG recommend caution when trying to make any conclusions regarding groundwater flow direction and potential contamination movement based on these monitoring wells.
As for placement of additional monitoring wells between DM22 and Fredreka wells, the USCG will make that decision once they have results from the November, December, February and March water sampling. The USCG feels the 8 monitoring wells placed in a circle along the edge of the CG property adequately defines the level of water contamination within the plume. The final configuration of wells will be determined prior to the summer of 1999 field season.
The prelim lab results from the November sampling do not show any DRO or BTEX in DM22 or the Fredreka wells. Sampling of the treated discharge water from the HVE system showed only 0.0054 ppm total xylenes and no DRO.
Sampling of the Fredreka wells at least 3 days after each well is placed on line is not possible as the city rotates the on line wells according to their Operations and Maintenance Plan and only a few wells are on line during any given week. USCG does not plan to collect data on the tidal conditions, barometric pressure and ambient air temperature until the USCG has had a chance to discuss precisely what the data objectives are for the information. The next RAB meeting in February 1999 would be an ideal occasion to discuss this issue.
The USCG can only reimburse for expenses ADEC routinely bills all private and public entities for similar expenses (travel, per diem room and board). If this is the case, please confirm in writing, and submit an invoice to Civil Engineering Unit Juneau after travel has occurred. Once the USCG has determined the expenses would be reasonable, they will process the invoice for payment. |
Ray Dronenburg |
| 2/8/1999 |
Update or Other Action |
Fourth quarterly September 1998 sampling event-January 1999 report received. Product thickness decreased in all wells with product (DM-2 through DM-6). DRO concentrations (mg/L) varied in wells: DM-1 decreased 45.2 to 24.6, DM-8 1.66 to .830, DM-12 15.7 to 6.34, and DM-14 1.38 to 1.29. 18 AAC 75 Table C values for DRO=1.5 mg/L, Ethylbenzene = 0.7 mg/L, Toluene= 1.0 mg/L and Xylenes=10.0 mg/L. Eureka drinking water well shows POL COCs below MCLs but slightly increasing DRO 0.160 to 0.174 mg/L and for the first time: p&m Xylenes 0.00102 mg/L. |
Louis Howard |
| 2/16/1999 |
Document, Report, or Work plan Review - other |
ADEC letter to USCG regarding Hydrologic Monitoring Investigation September 1998. ADEC requests clarification on whether the soil vapor extraction system remains operational or not. ADEC requests data to support the continued recovery of 9-10 gallons per day as reported in the 4th Quarter sampling document.
ADEC disagrees groundwater flow is predominantly southeast towards the ocean. A limited radial flow pattern is evident in the immediate area of the site and new considerations for tidal influences makes all previous water level measurements suspect.
Use of EPA method 8021B as a method does not meet the needs of the Water Program for use as a Drinking Water Standard. It is therefore requested that sampling methods 502.2 and 524.4 be substituted for 8021B.
Wells DM-13, DM-2 and DM-7 are equally effected by fairly strong tidal influences and would require the same correlation for tides with water level measurements. The resulting data could significantly effect the groundwater flow direction.
ADEC continues to be concerned that groundwater flow direction could be other than that as reported by the Coast Guard. Based on geology as reported on page 3 of the report, "...a vesicular basalt which, depending on the orientation and size of the vesicles, may act as a vertical or horizontal conduit for groundwater....", ADEC is considering that additional groundwater investigation may be necessary.
ADEC proposes the following:
a. CG consider performing analyses on all wells currently used in this study for consideration of tidal influence,
b. CG consider performing a dye test or some other tests that may provide insight into groundwater flow direction,
c. CG consider working with the Tribal Council of Saint Paul Island in a comprehensive look at the "groundwater system" of Saint Paul. The tribal council has received money to perform an environmental assessment.
d. Suggest that a comprehensive discussion with ADEC and Dames and Moore and the USCG to potentially rethink where we need to go in order to reach satisfactory conclusion with this effort.
e. Suggest that consideration be given to creation and dissemination of "Factsheets" on a regular basis for a timely information transfer to the local people of Saint Paul with regards to USCG actions and community concerns. |
Ray Dronenburg |
| 2/26/1999 |
Update or Other Action |
The HVE system begins fulltime operation in February 1999. |
Ray Dronenburg |
| 3/3/1999 |
Update or Other Action |
Ray Dronenburg receives letter from USCG regarding Hydrologic Monitoring Investigation September 1998 report. The blower near the tank farm is outside of the radius of influence of any HVE wells and is still operational. The 9-10 gpd recovery rate was calculated when the SVE system first became operational in 1996 and is no longer applicable now that only one SVE blower is still running. The USCG has switched to method 524.2 for the city well samples and they will continue to analyze all other groundwater samples using method 8021B, the new version of EPA method 8020.
The September groundwater monitoring report conclusions led the USCG to not propose any further groundwater study (analysis of tidal influence, response to rainfall, gradient) aside from continuing to monitor city wells and LORAN station monitoring wells. Both the floating product plume and contaminated groundwater plum are very stable. The contamination in DM22 in September may have been the result of a major leak in the city drinking water piping which caused the city's pumping levels to triple for a six month period. To be on the safe side, with ADEC approval, the USCG has adjusted the quarterly sampling to coincide with the high risk times. For fiscal year 1999 (10/98-9/99) these 4 sampling events were scheduled for November and December 1998 and February and March 1999.
The USCG has distributed the fact sheets at the last two RAB meetings, conducted a public meeting prior to the HVE system construction, given post construction tours of the system, and given presentations at the school in Saint Paul. In addition, all of the USCG reports are available for review in Anchorage and Saint Paul. |
Ray Dronenburg |
| 3/10/1999 |
Update or Other Action |
USCG letter to Keven Kleweno dated 3/10/1999 regarding sampling Saint Paul city drinking water well results. Enclosed is a copy of all the results of sampling and a floppy disk of well logs from 1997 and 1998 from the city of Saint Paul in two excel files. The USCG anticipate having well logs for the beginning of 1999 by the end of March, they may be available within ADEC since the Saint Paul Public Works Department stated it has provided this information on a monthly basis to ADEC drinking water program. Also included is the City's operation and maintenance manual for well with the typical pumping rates at each well. Also an included is an enclosure which shows which wells were online during the USCG sampling events. |
Kevin Kleweno |
| 5/24/1999 |
Update or Other Action |
USCG letter to staff regarding groundwater and contaminant sampling at the site. The actual contamination levels outside the floating product are very low. Only 2 of the monitoring wells have ever exceeded site cleanup standards and only by 0.02 ppm DRO in one well and 14.2 DRO in the other well. In addition, none of the wells outside the floating product have ever exceeded site cleanup standards for BTEX. The USCG therefore proposes to reduce sampling at those wells (DM-8 and DM-12) and city drinking water wells.
Another reason the USCG considers significant for reducing the sampling on the HVE system is to minimize the burden of running the system on the LORAN Station personnel, who took over the operation and maintenance of the HVE system when they were unable to find a local operator. Reducing sampling frequency will allow the USCG to use slightly longer turnaround times which will greatly help control costs. The USCG believes the only truly crucial information on the HVE system is ensuring the water they are reinjecting is clean and determining when the free product has been removed. |
Louis Howard |
| 6/7/1999 |
Document, Report, or Work plan Review - other |
ADEC letter to USCG regarding revised sampling methodology for HVE system at USCG LORAN station. ADEC concurs with elimination of the DRO analysis from the HVE system treated water on a weekly basis. However, when the time is appropriate for closure sampling, ADEC will require the USCG analyze for DRO in addition to polynuclear aromatic hydrocarbons (PAHs) and benzene, toluene, ethylbenzene, total xylenes.
ADEC concurs with the suspension of monitoring the well extraction vapor at each of the HVE wells. ADEC concurs with the recommendations to reduce the quality control samples to 3.3% and 2% matrix spike/matrix spike duplicates. ADEC requests the number of QC samples and matrix spike/matrix spike duplicates be no less than one each per sampling event if the number of samples is 50 or less. For establishing closure, the number of QC samples will be required to return to the 10% duplicate or 5% matrix spike/matrix spike duplicate.
ADEC disagrees with the elimination of BTEX sampling from monitoring wells DM22, 7, 8, 12, 13 and 14 during the annual monitoring at the site. ADEC requests the USCG continue monitoring for DRO and BTEX on an annual basis given the unique site conditions and the proximity of the City Of Saint Paul drinking water wells to the site.
When the time comes for establishing closure, the sampling will include analysis for DRO, BTEX and PAHs. ADEC concurs with the reduction of sampling frequency to March and September. However, ADEC disagrees with the elimination of DRO from the analyses until two consecutive years of sampling have shown that contaminant levels have not increased or exceeded maximum contaminant levels.
After September 2000, ADEC will review the data and determine if the frequency or sampling methods should be reduced. ADEC requests the CG include additional data during each sampling event: tidal conditions, barometric pressure, ambient air temperature, and verification that each source well was online when the water sample was collected. Due to the relatively flat gradient of the aquifer, and its unique hydrogeologic setting, these data may play a bigger part in determining groundwater flow direction, thus the necessity of collecting them. |
Louis Howard |
| 2/11/2000 |
Update or Other Action |
1999 3rd and 4th quarter high vacuum extraction (HVE) system reports received. 100% compliance with wastewater disposal effluent permit and 725 gallons of fuel recovered to date. November monitoring showed that 5 wells had no petroleum contamination(product) and 2 were below ADEC groundwater cleanup levels. One of the two samples contained methylene chloride which is a common chemical found in paint remover and degreasers. It was found at 0.00051 mg/L which is 10 times lower than the EPA drinking water limit and ADEC cleanup level of 0.005 ppm. |
Louis Howard |
| 5/10/2000 |
Update or Other Action |
USCG sent in first quarter 2000 HVE system report. Sampling throughout the period shows 100% compliance with the wastewater disposal permit and 820 gallons of fuel recovered to date. This past quarter only 4 of the 12 HVE wells were extracting product. They were unable to add more wells due to the increased work load of the LORAN Station personnel. To address this issue, they are installing a centrifugal separator, which will allow more wells to be brought online without increasing maintenance work load. The centrifuge was shipped on May 2. The USCG is also pursuing hiring additional on island assistance. The biannual sampling of Fredreka 2 and South well in March did not detect any petroleum contaminants but both Fredreka samples did contain a trace amount of methylene chloride (0.00078 ppm and 0.00074 ppm) at nearly 7 times the EPA and ADEC cleanup levels. |
Louis Howard |
| 10/13/2000 |
Update or Other Action |
USCG sent in a final version of the HVE O&M manual which incorporates the system modifications they have made since the draft manual was prepared. It includes addition of the clay/anthracite filters, replacement of the oil water separator with a centrifuge, and hiring a local operator. The first 2 changes were to more efficiently remove the emulsified product from the product/water mixture being extracted from the ground, which increases recovery rate. They have hired the Saint Paul local resident to operate the HVE system in order to relieve the LORAN station crew of having to divide their time between running the HVE system and the LORAN station. In the 2nd quarter of 2000 (April to June 2000), the USCG has recovered 91 gallons of product and treated 72,788 gallons of contaminated water. All samples taken of the water being reinjected were under the limits of the wastewater discharge permit. |
Louis Howard |
| 3/15/2001 |
Update or Other Action |
Interim Removal Action Report - Southwest Point Battery Site. The approximate latitude and longitude of the Southwest Point Battery Site are 57º 09’ 50” and 170º 24’ 55” (WGS 1984). Southwest Point is located in the southeast and southwest quarters of Section 7, Township 35 South, Range 132 West, Seward Meridian. Southwest Point lies within the 130.77-acre parcel of land surveyed as Tract F, US Survey No. 4943. The battery disposal site is located in Lot 2, which is the western portion of Tract F (BLM 1968 and BLM 1986).
The Southwest Point Site is located on the extreme southwestern corner of Saint Paul Island, Alaska. The site is not a Two-Party Agreement site. Southwest Point was the site of a United States Army Loran Station operated by the U.S. Coast Guard during the 1940s. The buildings were demolished and drums and debris were removed in the 1950s through the 1990s. The site is now in light recreational use.
In 1999 discarded lead-acid battery fragments were discovered in a low swale at the site. The origin of the batteries is not known. The batteries were removed and soils were sampled, showing residual lead contamination. In September, 2000 an Interim Removal Action was conducted. Lead-contaminated soils were physically removed, staged, and disposed of off-island. The swale was backfilled with clean scoria. The Interim Removal Action was successful in preventing human and environmental exposure and in mitigating any further leaching of the lead-contaminated soils.
|
Louis Howard |
| 4/6/2001 |
Update or Other Action |
USCG sent the second annual operating report for the HVE system at the LORAN station. Highlights of the report: 100% compliance with the wastewater disposal permit, 1,191 gallons of fuel recovered to date, no petroleum contamination in the city drinking water wells in March and September 2000 sampling events, 3 perimeter groundwater monitoring wells showed a slight increase in contamination levels, the other 4 wells located between the loran station and the city wells did not have any contamination and 29% increase in hours of operation and 49% increase in gallons of groundwater treated due to the hiring of a local HVE system operator and installation of a centrifuge. |
Louis Howard |
| 4/17/2001 |
Update or Other Action |
Staff commented on proposal for groundwater and HVE system monitoring reductions in sampling and monitoring. ADEC concurs with suspension of TAH and TAqH sampling of HVE system, suspension of HVE system vapor effluent sampling, and elimination of BTEX sampling at DM 7, 8 12, 13, 14, 22 and the former drinking water well. Closure sampling at some point in the future will require sampling for GRO, DRO, BTEX and PAHs (Acenaphthene, anthracene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, chrysene, dibenzo(a,h)anthracene, fluorene, indeno(1,2,3-c,d)pyrene, naphthalene, and pyrene). ADEC concurs with elimination of DRO analysis in the City of Saint Paul drinking water wells. DRO and BTEX sampling will be required in the City wells if for two events the USCG wells (DM 7, 8 and 12) show increases in contaminant levels. Monitoring of all USCG groundwater wells will be reduced from twice yearly to once a year in September/October time period. |
Louis Howard |
| 5/24/2001 |
Document, Report, or Work plan Review - other |
ADEC staff reviewed and concurred with the conclusions in the Interim Action Report for SW Point Batter Site Non-TPA Site, St. Paul Island Version 2.0 dated March 15, 2001. The cleanup action was successful and no additional remedial action is required. |
Louis Howard |
| 4/11/2002 |
Update or Other Action |
Staff approved the US Coast Guard's request to switch the groundwater sampling period from September to March for the city drinking water wells. It is during this time the seafood processing plant used the most water and thus would most likely to potentially create a drawdown effect of the groundwater table. |
Louis Howard |
| 5/16/2003 |
Update or Other Action |
Staff received and reviewed the Coast Guard's request to shutdown the High Vacuum Extraction System at the LORAN station. Based on a review of the data in the document, the Department concurs with the request to discontinue the high-vacuum extraction (HVE) system operations and continue sampling of the perimeter monitoring wells for diesel range organics. From 1999 through 2003, the HVE system treated 1.7 million gallons of contaminated groundwater and recovered 1,824 gallons of product. During the first year of operation in 1999, the system extracted an average of 70 gallons of free product per month. The average extraction rate gradually declined until January of 2003, when it removed zero gallons of free product. At this point, use of the HVE system was discontinued and the system was dismantled.
Currently, none of the monitoring wells have been above groundwater cleanup levels for two consecutive years. The Department concurs with the free product survey on a quarterly basis. The Department interprets “significant” free product as being greater than 0.1 feet (1.2 inches) in thickness. This product thickness is the technically practicable threshold that has been implemented at other free product recovery operations in Alaska. Only well DM-4 exceeds this threshold (0.15 feet).
Perhaps an alternative to the HVE may be implemented at this well, such as a dedicated skimmer pump placed in the well, or more frequent bailing of this well than on a quarterly basis. The Department is open to suggestions on how to address this issue. The Department reserves its rights, under 18 AAC 75, 18 AAC 78, and AS 46.03 to require additional assessment and/or corrective actions, if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or to the environment. The Coast Guard is to be commended on its aggressive and successful efforts with the HVE system to ensure continued protection of human health, welfare and the environment. |
Louis Howard |
| 5/3/2004 |
Update or Other Action |
Staff received and reviewed the Free Product Survey. Based on a review of the data in the document, the Department concurs with the request to discontinue the quarterly free product surveying. Instead the Coast Guard may conduct these surveys in conjunction with the annual LORAN Station groundwater sampling event (currently every September). The Department reserves its rights, under 18 AAC 75, 18 AAC 78, and AS 46.03 to require additional assessment and/or corrective actions, if information indicates the site conditions pose an unacceptable risk to human health, safety, or welfare, or to the environment. |
Louis Howard |
| 4/8/2005 |
Update or Other Action |
Staff received a free product survey for the former high-vacuum extraction (HVE) system extraction wells. All monitoring well DRO concentrations were below 18 AAC 75 Table C groundwater cleanup levels. This includes a significant decrease in a monitoring well which had previously exceeded the cleanup level. Additionally, the HVE system was disassembled and staged onsite for future shipment. All activities were completed between October 29 and November 4, 2004. |
Louis Howard |
| 2/12/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 2/12/2007 |
GIS Position Updated |
Correction per Loran Chain Information: Loran-C Chain Information in WGS 84 Coordinates.
|
Louis Howard |
| 5/9/2007 |
Update or Other Action |
Final October 2006 St. Paul Annual Groundwater Sample Results received. In accordance with the agreement between the U.S. Coast Guard (USCG) and the Alaska Department of Environmental Conservation (ADEC), analytical groundwater samples were collected from six of the seven monitoring wells located around the perimeter of the USCG St. Paul LORAN Station on 29 October 2006. The USCG well, which is the former LORAN Station drinking water well, could not be sampled due to physical obstructions in the well vault.
Groundwater samples were analyzed for diesel-range organics (DRO) by laboratory method AK102. Sample results from the last seven monitoring events are summarized in Table 1. Analytical results from monitoring well DM-12 indicate a slight exceedance of the ADEC groundwater cleanup level of 1.5 mg/L. All remaining DRO concentrations were below this criterion. With permission from ADEC, purge water from the monitoring wells was discharged to the ground surface adjacent to each well.
In addition to groundwater sampling activities, a free product survey was conducted in
accordance with the shutdown agreement between the USCG and ADEC. The 12 free product extraction wells located at the LORAN Station are surveyed for free product annually. During this field effort, DM-18 could not be located. It may have been covered during recent
construction activities.
The product thickness increased in wells DM-4 (from a sheen to 0.29 feet) and DM-5 (from no product detection to 0.01 feet) since last measured during the October 2005 survey. Well DM-6 showed a decrease in product thickness of 0.28 feet since 2005. No product was detected in the remainder of the wells during the October 2006 survey.
Conclusions and Recommendations
Analytical results from one monitoring well (DM-12) exceeded the ADEC groundwater cleanup level for DRO of 1.5 mg/L with a concentration of 1.6 mg/L. Results of the remaining monitoring wells were two orders of magnitude below the cleanup level. Free product thickness has decreased in DM-6 since the October 2005 survey, but has slightly increased in DM-4 and DM-5 over the same period. The thickest product measurement (0.36 feet) has consistently been collected from DM-6.
This is equivalent to less than 0.06 gallons of free product in a two-inch diameter well and 0.23 gallons of free product in a four-inch annulus. Based on these data, it is recommended that annual groundwater monitoring and free product surveys continue until such time that cleanup levels are achieved for two consecutive monitoring events and no free product has been detected for two consecutive monitoring events. |
Louis Howard |
| 8/20/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed the EDDAI workplan Phase II and III August 2007. ADEC does not concur with the use of an alternative cleanup level (ACL) of 1,064 mg/kg for lead contaminated soil (e.g. page 4-1 reference technical memorandum "Alternative Cleanup Levels for Soil at USCG Light Stations in Southeast Alaska CH2MHILL 2003) at the St. Paul LORAN station.
Any discussion of site specific ACLs through a prior ADEC approved risk assessment work plan and subsequent risk assessment for the St. Paul Island LORAN station will require implentation of enforceable land use controls (i.e. institutional controls) and ADEC concurrence. The industrial cleanup level for lead in soil is 1,000 mg/kg, assuming the land use at the demolished facility remains industrial and any intended future use is industrial.
18 AAC 75.340. Soil cleanup levels; general requirements.
(a) This section provides the requirements for cleanup levels for hazardous substances in soil. For each site, except as provided in (b) of this section, a responsible person shall propose soil cleanup levels for approval, shall base those cleanup levels upon an estimate of the reasonable maximum exposure expected to occur under current and future site conditions, and shall develop those cleanup levels using one or more of the following methods:
(1) method one for petroleum hydrocarbon-contaminated soil in
(A) a non-Arctic zone as set out in Table A1 of 18 AAC 75.341(a); or
(B) an Arctic zone as set out in Table A2 of 18 AAC 75.341(b);
(2) method two for soil contaminated with
(A) chemicals other than petroleum hydrocarbons as set out in Table B1 of 18 AAC 75.341(c); or
(B) petroleum hydrocarbons as set out in Table B2 of 18 AAC 75.341(d);
(3) method three, as described in (e) of this section, for developing site-specific alternative cleanup levels; or
(4) method four, as described in (f) of this section, for developing site-specific alternative cleanup levels.
(b) Alternative soil cleanup levels developed under method three or method four may NOT be used at another site without prior approval. If alternative cleanup levels are developed for one site WITHIN a facility with multiple similarly contaminated sites, and if the department determines that the use of those cleanup levels at another site WITHIN that facility will be protective of human health, safety, and welfare, and of the environment, the department will approve the use of those cleanup levels at the other site.
Page 5-3
Text states: Thirty two samples are proposed to be collected from two different soil horizons: 0-3 inches bgs and 3 - 27 inches bgs. The averagel of the 32 analytical results from each soil horizon will be compared to the ACL of 1,064.
ADEC does not agree. The highest single value of will be compared to 400 mg/kg and 1,000 mg/kg and determine the necessity for remedation of lead based paint/soil. Not the average value from 32 samples.
Is there an anticipated transferee for the STP USCG LORAN Station? Tribal, local governement, other federal government agency looking at receiving the property? It was not listed in the work plan.
In addition to meeting ADEC's lead cleanup levels in soil, be forewarned, the US Coast Guard will be required to ensure the lead contaminated soil/paint samples do not fail RCRA's TCLP lead limit (5.0 mg/L). Another federal agency, NOAA, had issues on St. Paul Island with lead based paint contamination at a few buildings last year which failed TCLP for lead. NOAA had to treat (with EPA Region 10 prior approval-Contact Jan Palumbo EPA Region 10, RCRA Permitting Coordinator) the soil with Ecobond to reduce the leachability of the soil for lead and show it would pass TCLP.
ADEC's review of the US Coast Guard's (USCG's) proposed work plan is to ensure that the work is in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments do not relieve the USCG or its consultants, contractors, subcontractors, agents acting on its behalf or the USCG's civilian personnel from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 11/27/2007 |
Update or Other Action |
USCG 18 AAC 75.350 Criteria Application to St. Paul Runway Site evaluation received. GW in the vicinity of the JP-5 fuel release is not used for a private or public drinking water (DW) system. GW at the fuel release site is not within the zone of contribution of an active private or public DW system and is not within the recharge area for a private or public DW well, a wellhead protection area, or a sole source aquifer.
Although GW in the immediate vicinity of the recent fuel release has not been characterized, there are other more attractive sources for potential future DW sources on the island, including expansion of the existing City of St. Paul wellfield.
The recent fuel release is located on the edge of the runway within the controlled area of the St. Paul Island Airport, which is owned & operated by the SOA; therefore, access is limited. Surrounding land is unoccupied & will likely remain as such in the foreseeable future. The site of the recent fuel release (the St. Paul Island Airport) is not expected to change within the foreseeable future & is not likely to ever be utilized as a residential property. Therefore, it is unlikely that residential drinking wells will ever be installed in this area.
The current & potential future water use demands for St. Paul Island can be accommodated by expansion of the existing City of St. Paul wellfield. Expansion of the wellfield will most likely occur within the existing watershed easement. Without sampling the GW in the direct vicinity of the recent fuel release, it is unknown whether or not this location would be exempt under 40 CFR 146.4
The majority of the contaminated soil associated with the recent fuel release was removed as part of the 2006 Corrective Action. The impacts to GW are assumed to be minimal based on the known surface hydrological information at St. Paul Island. It has no permanent surface drainage network, with limited water percolating from the surface to GW. In addition, the vertical permeability is much less than the horizontal permeability.
The primary contaminant of concern at this site is JP-5, which may be broken down by bacteria & other organisms in soil & water. Confirmation sample results from the 2006 Corrective Action indicate that only a de minimis volume of soil containing elevated contaminant levels remain in the ground. These samples are located at the bedrock interface.
The location of the recent fuel release is outside of the estimated city of St. Paul wellfield watershed, which is the only known private or public DW source on St. Paul Island. There is a low likelihood of an aquifer connection due to well construction practices in the area where the site is located. Jet fuel (JP-5) is the contaminant of concern at the runway release site.
Dense basalt is found in one or more layers underlying unconsolidated surface deposits. The geologic information available comes from wells logs from three sources 1) the city of St. Paul DW wells, 2) Telegraph Hill FUDS MWs, & 3) USCG LORAN Station MWs.
The City of St. Paul DW wellfield watershed (less than a mile away from the spill location) may present insight into the geology in the vicinity of the location of the recent JP-5 fuel release. The well logs indicate a layer of unconsolidated surface deposits consisting of surface vegetative mat, sands, silts, gravel, cobbles, and boulders. This layer generally extends to a depth of 0 to 40’ bgs.
Dense basalt is found in one or more layers underlying the unconsolidated surface deposits. The dense basalt is discontinuous and varies from nonexistent to 50’ thick.?Vesicular or fracture basalt is found underlying the dense basalt or in alternating layers with it. This layer extends to the bottom of most wells with a thickness from 3 to 40’. Well logs indicate the presence of voids ranging from 4 inches to several feet within this layer. The aquifer tapped by the City of St. Paul is within the vesicular or fractured basalt layer
The local climate is described as arctic maritime. No predictive modeling was performed for the site.
The ADEC has already received the 2006 Corrective Action Report, which provides detailed information regarding sampling locations, results, and remaining contamination levels. MWs are located between the recent USCG JP-5 fuel release and the City of St. Paul’s DW wells. Sampling of these wells has been done on an annual basis. In addition, the city of St. Paul’s DW wells are sampled and analyzed for contaminants. Future drilling, especially in the immediate area of remaining contamination at the bedrock interface, may provide a potential pathway for migration of contaminants to the underlying aquifer.
Existing information regarding the City of St. Paul’s wellfield, the only known private or public DW source on St. Paul Island, should provide additional information regarding projected GW flow. |
Louis Howard |
| 1/6/2008 |
Update or Other Action |
USCG sent ADEC the conclusions and recommendations from the fate and transport model SESOIL. Jet propellant 5 (JP-5) fate and transport in the unsaturated zone was simulated using SESOIL (Bonazountas and Wagner, 1984 and Hetrick et al. 1993). Unfortunately, there is no nearby default weather station in the SESOIL database that can be used for the conditions of the St. Paul, Alaska. Therefore, the mean monthly data on precipitation and temperature from an online source (www.weather.com) were used. The generic frequency and length of storms, cloud cover fraction, and relative humidity data were used.
The St. Paul excavation focused on removal of JP-5 contaminated soil near the south end of the
runway. The lateral and vertical extents of the spill were delineated during excavation. The final limits of the excavation measured approximately 90 feet from east to west, and 40 feet from north to south. Table 1-1 presents the analytical results and location depths of soil samples collected from the borders of the excavation. Two soil samples collected at the floor of the excavation, directly beneath the spill source, had reportable amounts of JP-5 (4,300 mg/kg and 2,000 mg/kg).
Further removal of soil at these locations was not possible since the excavation reached an impenetrable basalt layer. All other samples collected from the excavation walls and floor were below ADEC Method Two cleanup criteria. No free product (NAPL) was found on the floor of the excavation. Several methods, including the SESOIL modeling, were used to determine if any JP-5 remaining at the excavation site had the potential to migrate and significantly impact any drinking water source. These methods included an evaluation of the excavation location relative to the St. Paul drinking water aquifer recharge area, research on any future drinking water expansions, and a mass balance calculation to estimate the recovered fuel volume from the excavation.
USCG reported that the runway mishap resulted in a release of approximately 1,000 gallons of
fuel. The calculated volume of fuel recovered was 744 gallons. This calculated amount is in the
expected range of the estimated fuel volume spilled. Modeling results for 100-year simulations
for various soil types indicate that the JP-5 did not significantly migrate into the unsaturated zone based on its chemical properties, unsaturated soil properties, and source strength. JP-5 has Kd values greater than 1, implying that these contaminants are preferentially adsorbed to the solid phase. The SESOIL model predicted minimal movement of any remaining JP-5 (less than 1 meter) over a 100 year period using conservative values for soil density, intrinsic permeability, and recharge rate. The attached figure outlines the water recharge area and flow for the City of St. Paul drinking water wells. The attached figure shows at low winter precipitation levels, and with a pumping rate well above any historical rate, the excavation area does influence the water recharge area. The excavation is over 2,500 feet outside any potential watershed recharge boundaries and is crossgradient to the groundwater flow.
With an evaluation of the information available to date, Method Two Ingestion or Inhalation
cleanup criteria should be applied at this site. Cleanup levels under these categories are 10,250 and 12,500 mg/kg DRO, respectively. |
Louis Howard |
| 3/4/2008 |
Update or Other Action |
Staff reviewed and commented on the report for the St. Paul Runway site-ADEC Spill ID 06259917901; USCG St. Paul C130 runway fuel release.
Based on the information provided by the USCG to date, ADEC will be requiring no further investigation at the JP-5 fuel release near the south end of the St. Paul Island Airport. Further removal of soil at this location was not practicable since the excavation reached an impenetrable basalt layer. Pending successful treatment of the excavated soil from this site later this year, ADEC will provide the USCG a written confirmation of site closure. ADEC looks forward to reviewing the work plan on the proposed soil treatment.
Please ensure the contaminated soil stockpile is protected from weather with no less than a six-mil, reinforced polyethylene liner or its equivalent, with the edge of the cover lapped over the bottom liner to prevent water running through the soil; and inspect and maintain the contaminated soil stockpile regularly to ensure that the cover remains intact and that the soil and any liquid leachate derived from the soil is contained. |
Louis Howard |
| 4/25/2008 |
Update or Other Action |
Staff received the USCG Landspread Work Plan U.S. Coast Guard LORAN Station, St. Paul, Alaska
(17-441442) for review and comment.
On 29 June 2006, a USCG C-130 Hercules aircraft experienced a runway mishap at the
St. Paul Airport while on a support mission for USCG LORSTA St. Paul. The mishap
resulted in the release of approximately 1,000 gallons of JP-5 fuel approximately 150 feet
from the northwest edge of the runway (USCG 2006). The general spill area was consistent
with local topography (comprised of volcanic rock and rocky tundra).
In response to the C-130 mishap, a field effort was conducted in November 2006 to mitigate
soil contamination. Approximately 450 cubic yards of soil was excavated from the spill site
and stockpiled at the LORSTA. Based on field screening and analytical soil sample results,
the lateral extent of contamination from the spill was delineated and excavated. The vertical
extent of contamination was bounded by an impermeable bedrock layer at approximately 11
feet below ground surface during the field effort. Closure will be obtained at this site after soil is landspread and DRO cleanup levels are reached.
Currently, two soil stockpile cells are located near the USCG LORSTA aboveground storage
tanks (Figure 2-2). Soil removed as part of the cleanup response to the C-130 mishap was
segregated into two stockpiles. Stockpile #1 was constructed to hold highly contaminated
soil (approximately = 5,000 milligrams per kilogram [mg/kg] diesel-range organics [DRO]).
Stockpile #2 was constructed for less-contaminated soil (approximately < 5,000 mg/kg DRO).
Each stockpile cell measures 40 feet by 40 feet and is lined with geotextile fabric. A layer of
granular activated carbon material is above the geotextile liner in Stockpile #1, and a thin
layer of sand was used to cover the geotextile liner of Stockpile #2. Each cell is lined with
20-millimeter high-density polyethylene (HDPE) material.
Stockpiles were sampled to determine the average DRO concentration in the stockpiled soil.
Stockpiles #1 and #2 were measured at DRO concentrations of 5,000 and 3,800 mg/kg, respectively.
The objective of this project is to bring contaminant concentrations below cleanup levels
through landspreading, a technology that involves thinly spreading the contaminated soil
over a relatively large area without a liner while using methods protective of human health
and the environment. This technology promotes biological degradation of fuel compounds
and may also increase contaminant volatilization and photochemical oxidation.
Landspreading will be performed to reduce fuel-related contaminant concentrations in the
stockpiled soil and eventually bring those contaminant concentrations below the cleanup
levels (Table 4-1). Landspreading will be conducted in accordance with Technical Basis for
Landspreading and Landspreading Design Manual for FAA Stations in Alaska (Federal Aviation Administration [FAA] 1999).
Landspreading will generally be accomplished by placing stockpiled soil into dump-trucks
and broadcasting the soil across the selected landspreading location. The soil will be graded
to a relatively uniform thickness of approximately 18 inches to provide a low-density, high porosity soil (FAA 1999). Materials remaining from the stockpile disassembly, including
geotextile fabric and HDPE liner, will be containerized for disposal.
The area required for landspreading is estimated to be a 200-foot by 100-foot plot, or surface
equivalent. Four locations have been selected for potential landspreading (Figures 5-1 and
5-2). Area 1 would encompass the location currently used for stockpiling soil and would
extend the bounds of that area. Area 2 would be located just south of the Tank Farm, and
soil would be spread over an area determined to contain subsurface contamination. Area 3
would be located just south of the Power/Signal Building, also over a zone with known
subsurface contamination. Area 4 would be located in the area currently occupied by the
fuel tank farm.
Once landspreading is complete, signs will be placed on each side of the broadcast area to
note the location of the soil and inform the community of the treatment taking place. The
landspreading location will be recorded using GPS and the location dimensions measured
and noted for records.
Periodic monitoring will be conducted at the landspread area to evaluate fuel-contaminant
degradation over time. Based on average detected concentrations, DRO drives the degradation time at the site; therefore, early monitoring may be limited to DRO. Monitoring is recommended at two-year intervals until cleanup levels are reached (FAA 1999). |
Louis Howard |
| 5/1/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Landspread Work Plan for the USCG C-130 fuel release stockpiles at the LORAN Station on St. Paul Island.
Table 4-1 Soil Cleanup Levels (Method Two Under 40-inch Zone)
The table lists the average detected concentration based on two multi-incremental (MI) stockpile characterization samples. It appears that MI sampling was conducted without ADEC approval or review. The table appears to only highlight benzene, ethylbenzene, toluene, and total xylenes (BTEX) as applicable cleanup levels. ADEC disagrees.
The US Coast Guard shall meet the most stringent cleanup levels (regardless of pathway) for: BTEX, gasoline range organics ), GRO and diesel range organics (DRO) based on the maximum concentration detected in the soil not the average detected concentration. October 2006 test pit sampling showed GRO at 610 mg/kg (TP-2) at 0.5 ft. and DRO at 24,000 mg/kg in TP-6 at two feet. So it appears that DRO concentrations have the potential to be present in the stockpiles at a much higher concentration than what is presented in the text at 5,000/3,800 mg/kg or as presented in the table as an average.
ADEC will require final cleanup levels to be based on discrete samples, or with prior approval, MI sampling. If the US Coast Guard chooses to conduct MI sampling in the future, it shall be conducted in full accordance with ADEC Guidance on Multi-Increment Soil Sampling (eff. March 2007). The latest version of the guidance is available for download http://www.dec.state.ak.us/spar/guidance.htm#csp). The US Coast Guard shall submit a separate work plan for review and approval to ADEC prior to conducting periodic monitoring sampling or closure sampling.
ADEC will require the US Coast Guard to conduct landspreading in accordance with ADEC UST Procedure Manual (eff. November 2002). The US Coast Guard may choose to supplement the ADEC Procedure Manual with the FAA Landspreading Design Manual, however, if there is any discrepancy or conflict between ADEC UST Procedure Manual and the FAA Manual, the ADEC Procedure Manual will prevail and be the final authority for landspreading.
Finally, ADEC will require the US Coast Guard to provide written confirmation from the real property owner (US Dept. Of Commerce) on its approval for the US Coast Guard to landspread contaminated soils on their property.
ADEC will consider the plan final upon incorporation of the above comments. Please note, ADEC’s review of the work plan is to ensure compliance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence on the document does not relieve the USCG or its consultants, contractors, subcontractors, or civilian personnel from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 5/29/2008 |
Update or Other Action |
Final work plan received for landspreading from the USCG. The objective of this project is to bring contaminant concentrations below cleanup levels through landspreading, a technology that involves thinly spreading the contaminated soil over a relatively large area without a liner while using methods protective of human health and the environment. This technology promotes biological degradation of fuel compounds and may also increase contaminant volatilization and photochemical oxidation.
Prior to landspreading, baseline groundwater and soil samples for fuel-related compounds
will be collected from any areas of known contamination near the site. This sampling will
assist in evaluation of contaminants present so that any contaminant migration from landspreading can be effectively measured. Approximately four borings are planned for the
landspread location, with one soil sample per boring at the depth of the highest field
screening result. Samples will be submitted for laboratory analysis of DRO, RRO, BTEX, and PAHs. Advancement of borings and baseline sampling will be performed in accordance with the Phase II and III Environmental Due Diligence Audit Investigation Work Plan (USCG
2007).
Landspreading will be performed to reduce fuel-related contaminant concentrations in the stockpiled soil and eventually bring those contaminant concentrations below the cleanup levels (Table 4-1). Landspreading will be conducted in accordance with ADEC UST Procedure Manual (ADEC 2002) and supplemented by Technical Basis for Landspreading and Landspreading Design Manual for FAA Stations in Alaska (Federal Aviation Administration [FAA] 1999).
Landspreading will generally be accomplished by placing stockpiled soil into dump-trucks and broadcasting the soil across the selected landspreading location. The soil will be graded to a relatively uniform thickness in the range of 6-18 inches, depending on space available, to provide a low-density, high-porosity soil (FAA 1999). Materials remaining from the stockpile disassembly, including geotextile fabric and HDPE liner, will be containerized for disposal.
The area required for landspreading is estimated to be a 200-foot by 100-foot plot, or surface
equivalent. Four locations have been selected for potential landspreading (Figures 5-1 and 5-2). Area 1 would encompass the location currently used for stockpiling soil and would extend the bounds of that area. Area 2 would be located just south of the Tank Farm, and soil would be spread over an area determined to contain subsurface contamination. Area 3 would be located just south of the Power/Signal Building, also over a zone with known subsurface contamination. Area 4 would be located in the area currently occupied by the fuel tank farm. Written confirmation from the real property owner on its approval for the US Coast Guard to landspread contaminated soils will be obtained before soils are landspread.
Once landspreading is complete, signs will be placed on each side of the broadcast area to
note the location of the soil and inform the community of the treatment taking place. The
landspreading location will be recorded using GPS and the location dimensions measured and noted for records.
Periodic monitoring will be conducted at the landspread area to evaluate fuel-contaminant
degradation over time. Based on average detected concentrations, DRO drives the degradation time at the site; therefore, early monitoring may be limited to DRO. Monitoring is recommended at two-year intervals until cleanup levels are reached (FAA 1999). Monitoring specifics will be addressed under separate cover.
The stockpiled soil to be treated using landspreading was sampled in November 2007. No
additional sampling is anticipated for 2008. |
Louis Howard |
| 10/28/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft USCG Landspread report dated October 2008.
5.0 Conclusions and Recommendations Page 5-1
The text states “Based on average detected concentrations, DRO will drive degradation time at the site.” ADEC will require final cleanup levels to be based on discrete soil samples, or with prior approval, Multi-increment (MI) sampling. If the US Coast Guard (CG) chooses to conduct MI sampling, it shall be conducted in full accordance with the latest ADEC Guidance on Multi-Increment Soil Sampling (eff. March 2007). The latest version of the guidance is available for download http://www.dec.state.ak.us/spar/guidance.htm#csp). The CG shall submit a separate work plan for review and approval to ADEC prior to conducting periodic monitoring sampling which does not use discrete sampling or final closure sampling.
6.0 References Page 6-1
Contaminated sites regulations have been changed. ADEC requests the Coast Guard change the text to reflect the most current version in effect (revised as of October 9, 2008). |
Louis Howard |
| 12/19/2008 |
Update or Other Action |
Draft August 2008 St. Paul Annual Groundwater Sample Results received. The objectives
of this monitoring event were as follows:
- Conduct baseline groundwater sampling as part of an Alaska Department of Environmental Conservation (ADEC) and National Oceanic and Atmospheric Administration (NOAA) approved landspread plan.
- Assess diesel-range organics (DRO) concentration levels and survey free product in monitoring and extraction wells in accordance with the agreement between USCG and ADEC.
- Evaluate groundwater quality as part of a comprehensive site characterization in accordance with the Civilian Federal Agency Task Force Guide for Evaluating Environmental Liability.
The purpose of this technical memorandum is to document and distribute the results of the groundwater monitoring event. These results will also be presented under separate covers to meet other stated objectives.
Groundwater samples were collected from six of the seven monitoring wells located around the perimeter of the LORAN Station (Attachment 1 LORAN Station Well Maps). The USCG well, which is the former LORAN Station drinking water well, was removed from the sampling program because it was not associated with a contaminant plume and was no longer used as a drinking water well.
Groundwater samples were analyzed for DRO by laboratory method AK102. Table 1 summarizes sample results from the last eight monitoring events. Analytical results from all monitoring wells sampled in 2008 were below the ADEC groundwater cleanup level of 1.5 milligrams per liter (mg/L) (Attachment 2). With permission from ADEC, purge water from the monitoring wells was discharged to the ground surface adjacent to each well.
In addition to groundwater sampling activities, a free-product survey was conducted in accordance with the shutdown agreement between USCG and ADEC. The 12 free product extraction wells located at the LORAN Station will continue to be surveyed for free product until two consecutive events are clean. During this field effort, DM-2 and DM-18 could not be located. The use of a metal detector did not reveal DM-2, and DM-18 was likely covered during construction activities in 2006. Wells DM-4 and DM-15 were dry, and the well vault of DM-5 was full of water. A potential safety hazard was noted by the sampling team because some of the plywood covers to the vaults have decomposed over time.
In 2008, Wells DM-2 and DM-18 were not located. However, Well DM-1 was located and was in close proximity to Well DM-2. Wells DM-4 and DM-15 were dry and therefore contained no product. The well vault for DM-5 was full of water, but no product or sheen was observed. The product level in DM-6 was measured in a bailer at 0.5 feet. Therefore, all the wells that had product during past events are now free from product, except well DM-6, within which the product level appears to remain stable.
No analytical results from the monitoring wells exceeded the ADEC groundwater cleanup level for DRO of 1.5 mg/L. Results of the monitoring wells were at least one order of magnitude below the cleanup level.
Free product is present only in one well (DM-6), which has had a relatively stable product level since 2005. The product thickness measurement from 2008 (0.5 feet) is equivalent to approximately 0.082 gallons of free product in a 2-inch-diameter well and 0.33 gallons of free product in a 4-inch annulus.
Based on these data, it is recommended that annual groundwater monitoring be conducted for well DM-12 until such time that cleanup levels are achieved for one additional consecutive monitoring event. It is also recommend that free-product surveys continue on wells that previously contained free product until such time that no free product has been detected for two consecutive monitoring events.
Free-product surveys should continue for monitoring wells DM-1, DM-2, DM-4, DM-5, DM-6, and DM-18. It is also recommended that although the integrity of most vault covers appears to be
intact, they be inspected occasionally and repaired if necessary to avoid potential physical
hazards. USCG should also evaluate pumping the water-filled vault. |
Louis Howard |
| 12/22/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft annual groundwater sample results document.
Conclusions and Recommendations
The text states that no analytical results from the monitoring wells exceeded the ADEC groundwater cleanup level for diesel range organics (1.5 mg/L). ADEC concurs, however, efforts should be made one more time to locate DM-2 and DM-18 which could not be located in August 2008. Cooler temperatures appears to be outside the acceptable range of 4 degrees C plus or minus 2 degrees C (e.g. cooler temperatures of 7 degrees and 6.4 degrees C).
6.0 References Page 6-1
Contaminated sites regulations have been changed. ADEC requests the Coast Guard change the text to reflect the most current version in effect (revised as of October 9, 2008 |
Louis Howard |
| 1/21/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft St. Paul LORAN Station 2008 Phase II and III Environmental Due Diligence Audit Investigation (17-J3866) January 2009. The text states the site investigation activities included sampling surface soil within a human exposure area for lead contamination to determine a site-wide average. ADEC soil cleanup levels are based on “... the reasonable MAXIMUM exposure expected to occur under current and future site conditions.” and not the average (18 AAC 75.340 Soil Cleanup levels; general requirements).
18 AAC 75.380(c) also states: “The department will determine final compliance with the
(1) applicable soil cleanup levels, based on sampling results from onsite
contaminated soil and from contaminated soil moved offsite for treatment or disposal, and based on the maximum concentrations detected, unless the department approves an appropriate statistical method, in which case compliance will be based on the mean soil concentration at the 95th percent upper confidence limit; approval of a statistical method will be based on
(A) the number and location of samples taken;
(B) whether large variations in hazardous substance concentrations relative to the mean concentration exist; and
(C) whether a large percentage of concentrations are below the method detection limit”
Please note samples analyzed with field screening devices may not be substituted for required laboratory samples.
Table 203 Page 2-9
The table shows DM-12, DM-12(FD) and DM-13 as being below 1.5 mg/L for diesel range organics (DRO). However, the cooler receipt form on page 244 of the draft document for COC Number 2008STP011/Lab SDG K0807734 showed a temperature blank reading of 6.9 degrees Celsius and a cooler temperature reading of 7.0 degrees Celsius. The samples associated with the cooler “We’ll All Go Down Together” and the DRO data derived from the samples will not be used for closure purposes or meeting cleanup levels.
4.1 Soil Page 4-1
The text states that Method Three alternative cleanup levels (ACLs) were calculated using the total organic carbon (TOC) data collected during the 2008 investigation (Appendix G). It appears that the TOC samples were not analyzed for diesel range organics (DRO) as required by the ADEC Technical Memorandum -08-002 September 30, 2008. ADEC recognizes the work plan was approved prior to the updated requirements and will not require DRO analysis for these TOC samples.
For future reference regarding TOC sampling, the memorandum states: 9) TOC sample locations must also be analyzed for the site specific fuel contaminant of concern; GRO and/or DRO/RRO, as applicable. If results indicate the presence of DRO or RRO hydrocarbons, the sample extract may be passed through a silica gel column and reanalyzed to remove polar compounds attributed to a biogenic source, per DEC Technical Memorandum 06-001. If re-analysis determines the hydrocarbons to be biogenic interference, the TOC data can be used to determine a site-specific cleanup level. If the hydrocarbons are determined to be from a petroleum source, the TOC data will be rejected and additional TOC samples representative of non-impacted soils will need to be collected.
7.0 Data Quality Assessment Page 7-1 and Appendix B
The text states Appendix B contains the sample summary table, analytical data table, laboratory backup, and ADEC laboratory data review checklists. ADEC requests the Coast Guard provide the laboratory report as well as required by the Technical Memorandum 06-002 October 9, 2006. |
Louis Howard |
| 6/16/2009 |
Meeting or Teleconference Held |
Phone call email memorandum for St. Paul LORAN Station work by Jacobs.
As we discussed, we plan on heading out to St. Paul to backfill the HVE vaults that currently pose a potential safety concern to LORAN Station personnel. We plan to extend the PVC piping to the ground surface and backfill around them to mitigate potential safety issues. While we are in St. Paul, we will also collect the groundwater, surface water, sediment, and soil samples as discussed in our responses to your comments in the 2008 St. Paul Phase II/III EDDA Investigation Report. We were planning on conducting this field effort by the end of this month, but schedule constraints have pushed the effort to the end of July. After we complete our field activities, we will prepare a report summarizing the work conducted. We will send this report to you for comments, but do not plan on submitting anything prior to execution of this work. |
Louis Howard |
| 8/4/2009 |
Update or Other Action |
Email from JACOBS RE: USCG has been planning the demolition of two 150,000-gallon ASTs and the old transmitter building. This email is to inform you of progress and plans for this demolition.
In general the plans are to accomplish this demolition in an environmentally protective and responsible manner consistent with applicable federal, state, and local regulations. The hazardous building materials survey and environmental assessments conducted last year have been used as the basis of design.
I anticipate that the AST demolition is of most potential interest to you. The contractor (BSE) plans to employ chemical remover of paint in strips where cutting is planned based on positive lead based paint results. The chemical, once used, is not anticipated to be regulated by RCRA unless the TCLP for lead is high. The crew will reduce the ASTs to 2 ft by 5 ft sections for offsite shipment and recycle. The remover, rags, and such will be sampled, analyzed, and managed appropriately. Although the system was drained when decommissioned, adequate protections are anticipated. Underground piping will be cleaned, pigged, capped, and abandoned in place. USCG and BSE will document observations during the removal of the tanks, containment liner, and ancillary piping. The area surrounding the ASTs was characterized in 2008, identifying limited petroleum impact southeast of the tanks. Additionally, the landspreading area is located southwest of the existing ASTs. The contractor plans to avoid disturbance of the landspread area.
|
Louis Howard |
| 8/5/2009 |
Document, Report, or Work plan Review - other |
ADEC has not seen a work plan for this AST demolition & expects the USCG to properly assess the area beneath the ASTs for soil contamination during demolition activities & the piping runs which will be properly decommissioned or removed.
Will there be field screening & confirmation sampling (DRO, GRO, RRO, BTEX) of the soil beneath the ASTs & around the piping? Will there be field screening & sampling (DRO, GRO, RRO, BTEX) of the soil beneath the liner? Was a field sampling plan or work plan developed for this which covers environmental sampling?
Not that it matters at this stage since work will be conducted in the very near future if not already occurring at this time, but here are a few ADEC comments regarding sampling, analysis & reporting requirements to keep in mind:
Field Screening
Field screening is the use of portable devices capable of detecting petroleum contaminants on a real-time basis or by rapid field analytical technique. Field screening must be used to help assess the following locations where contamination is most likely to be present: & direct where confirmation samples will be taken.
Tank Area
* areas of suspected or obvious contamination;
* adjacent to & below all fill & vent pipes;
* excavation sidewalls below the tank midline;
* one representative sample for at least every 100 square feet of excavation bottom
Piping Run
* areas of suspected or obvious contamination;
* below piping joints, elbows, connections, & damaged piping components; if these locations are unknown then screening must occur below original level of piping at 10 foot-intervals; the 10-foot interval is chosen because pipe sections commonly used are 10-foot lengths & because of limits of detection of soil gas vapors from the release source;
Piping
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 (adopted by reference by 18 AAC 75 & applicable to this project);
Tanks/piping
(i) of an individual tank with an excavated pit area less than 250 square feet, at least two samples must be collected from two different positions in the pit area, with position one on the longitudinal axis, centered between the ends of the tank, underneath where the tank was located, & position two on the longitudinal axis, underneath where the tank was located, where contamination is most likely to be present, as determined by field screening conducted as required by the UST Procedures Manual;
(ii) of an individual tank with an excavated pit area equal to or greater than 250 square feet, at least two samples must be collected from the pit area as required under (i) of this subparagraph; one additional sample must be collected for each additional 250 square feet of pit 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 pit area is 1,270 square feet, five additional samples are required;
(ii) of multiple tanks, by taking the samples for each excavated pit area according to (i) or (ii) of this subparagraph, as applicable; the same sample location may be used to meet the requirements applicable to more than one tank, if that sample location meets the requirements for each tank separately; (iv) of dispensing areas, at least one sample must be collected where the dispenser had been located;
(iv) of piping trenches, at least one sample must be taken at points along the piping trench where contamination is most likely to be present;
(v) soil samples for assessments under this subparagraph must be collected from native soils located at an elevation that is below, & within two feet of the bottom of, the excavated pit, & that is within two feet below the lowest point of the piping for the dispensing equipment; &
(vi) in this subparagraph, "the excavated pit area" is determined by the amount of ground surface that was excavated;
(vii) If the borings or test pits cannot be placed or if samples cannot be collected in the manner described above, any alternative sample location plans must be approved by the department.
Within 60 days after closure, the owner or operator shall provide to the department a site assessment report that includes a compilation of the information collected & results &
* the owner's name & address;
* the operator's name & address, if different from the owner;
For additional information see site file. |
Louis Howard |
| 8/7/2009 |
Update or Other Action |
Response email sent to ADEC re: AST demolition activities
Thank you for your comments and guidance during USCG's AST demolition activities. Attached is a figure depicting the current AST pipeline system and the previous tank pipeline system. Hopefully this will give you a better idea of the layout and the underground piping that will be abandoned in place. The tanks were installed in 1986 with a secondary containment area comprised of earthen berms covered with a polyethylene liner; the liner is covered with another layer of soil. A concrete catch basin was used to collect spills and is located in the containment area.
Once the liner forming the secondary containment for the tanks is removed, the soil will be evaluated for any signs of contamination by sight and smell. Observations during pipeline decommissioning activities will also be documented. If there is any indication that the containment was compromised or stained soil is observed, a field sampling plan will be developed detailing the field screening and confirmation sampling that will take place to characterize the extent of contamination below the tanks. We will send this plan to you for review before conducting screening/sampling activities.
Also, if signs of a spill around the tanks are observed, an ADEC Oil and Hazardous Materials Notification Form will be filled out and submitted. An Oil and Hazardous Materials Incident Final Report will also be completed after determination of site conditions. Both example forms are attached.
|
Louis Howard |
| 11/23/2009 |
Update or Other Action |
Staff received a memorandum from USCG RE: Draft July 2009 St. Paul Annual Groundwater Sample Results. Jacobs Engineering Group Inc. (Jacobs) conducted groundwater monitoring activities at
U.S. Coast Guard (USCG) LORAN Station (LORSTA) St. Paul on 29 July 2009. The objective of this monitoring event was to assess diesel-range organics (DRO) concentration levels and survey free product in monitoring and extraction wells in accordance with the agreement between USCG and ADEC.
The purpose of this technical memorandum is to document and distribute the results of the groundwater monitoring event. Groundwater samples were collected in 2009 from monitoring wells DM-12 and DM-13 (Attachment 1 ? LORSTA Well Maps). The analytical results were intended to fill potential data gaps associated with the previous sampling event. The USCG well, which is the former LORSTA drinking water well, was removed from the sampling program because it was not associated with a contaminant plume and was no longer used as a drinking water well. Monitoring wells DM-7, DM-8, DM-14, and DM-22 were also eliminated from the program when the results from
three events indicated consistent decreasing trend.
Groundwater samples were analyzed for DRO by laboratory method AK102. Table 1 summarizes sample results from the last nine monitoring events. Analytical results from monitoring wells sampled in 2009 were below the ADEC groundwater cleanup level of 1.5 milligrams per liter (mg/L) (Attachment 2). Wells DM-12 and DM-13 were sampled based on responses to comments from the 2008 Phase II and III Environmental Due Diligence Audit Investigation. In reviewing these comments DM-13 was inadvertently sampled. Wells DM-7, DM-8, and DM-22 had cooler temperatures exceeding criteria in 2008, but were not sampled in 2009. With permission from ADEC, purge water from the
monitoring wells was discharged to the ground surface adjacent to each well.
In addition to groundwater sampling activities, a free-product survey was conducted in accordance with the shutdown agreement between USCG and ADEC. Free-product extraction wells located at the LORAN Station will continue to be surveyed for free product until two consecutive events are clean. During this field effort 8 extraction wells were monitored. This included wells DM-2 and DM-18 which were located with the use of a metal detector. Once located, swing tie measurements were collected (Attachment 4). Table 2 presents 2009 groundwater depths and free-product survey results for the 2 monitoring wells and 8 extraction wells.
Table 3 provides the free product survey data collected since the HVE system shut down. In 2009, Wells DM-2 and DM-18 were located. DM-18 contained 0.21 feet of free product. Well DM-6 is the only other well that contains free product; the product level appears to remain stable. Well DM-15 was dry and therefore contained no product.
Conclusions and Recommendations
No analytical results from the monitoring wells exceeded the ADEC groundwater cleanup level for DRO of 1.5 mg/L. Results of the monitoring wells were at least one order of magnitude below the cleanup level. Free product is present only in two wells (DM-6 and DM-18). DM-6 has had a relatively stable product level since 2005. The product thickness measurement from 2009 (0.25
feet) is equivalent to approximately 0.041 gallons of free product in a 2-inch-diameter well and 0.16 gallons of free product in a 4-inch annulus. The product thickness measurement for DM-18 from 2009 (0.21 feet) is equivalent to approximately 0.034 gallons of free product in a 2-inch-diameter well and 0.14 gallons of free product in a 4-inch annulus.
Based on these data, it is recommended that annual groundwater monitoring be deemed complete for all wells. Well DM-12 achieved two consecutive monitoring events below cleanup levels. Wells DM-7, DM-8, and DM-22 have been below cleanup levels since 2000.
It is recommended that free-product surveys continue on wells DM-2, DM-4, and DM-5 until such time that no free product has been detected for two consecutive monitoring events. For wells DM-6 and DM-18, a passive bailer is recommended to collect free product. During the next field effort, the product collected in the passive bailers will be measured and compared to the product thicknesses encountered during previous product surveys. |
Louis Howard |
| 12/1/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2009 Annual Groundwater Sample results Tech Memo.
ADEC disagrees with the recommendation to discontinue groundwater monitoring at all wells. Free product is present in two wells DM-6 and DM-18 and sentinel well monitoring will continue until such time free product is no longer present. Therefore, for wells DM-6 and DM-18, sentinel wells DM-12 and DM-13 will be monitored (unless the Coast Guard has alternate sentinel wells to propose) for all contaminants of concern. ADEC concurs with the continued free-product surveys at DM-2, DM-4, DM-5.
Laboratory Narrative mentions VOC and PAHs (Cup Lake Page 10, Saucer Lake and Rocky Lake on Page 12 of Field Notebook, not mentioned at all in the report text or any tables):
Volatile Organic Compounds by EPA Method 8260B
Sample Notes and Discussion: Manual integration of one or more chromatographic peaks in samples and standards was required to correct the integration performed by the automated data processing program. The manual integration was performed in accordance with CAS policy, which is consistent with the National Environmental Laboratory Accreditation Program (NELAP), Department of Defense (DOD), and other certifying agencies. Refer to the raw data for the compounds impacted by the manual integration.
No other anomalies associated with the analysis of these samples were observed. Polynuclear Aromatic Hydrocarbons by EPA Method 8270C. No anomalies associated with the analysis of these samples were observed.
COC report for Cooler ID ROCKY Admin Number 09-064 reported 8270-SIM and 8260 BTEX as analyses requested for the following COC sample IDs, but none were mentioned in the report text or in the tables.
09-STP-RL-SW-01, 09-STP-SL-SW-02, 09-STP-CL-SW-03, 09-STP-CL-SW-03D
ADEC requests the PAH and BTEX data and calculated TAH/TAqH values for samples taken from: Cup Lake (CL), Rocky Lake (RL), Saucer Lake (SL) be reported (in a separate document for ADEC's files) as well as the listing of the compounds impacted by manual integration for method 8260B. |
Louis Howard |
| 8/31/2010 |
Update or Other Action |
Site Compliance Report received.
The results of previous investigations at this site adequately define lateral and vertical
extent of contamination. Remediation of contaminated soil should be accomplished to maintain compliance with ADEC regulations.
Groundwater: No analytical results from the monitoring wells exceeded the ADEC
groundwater cleanup level for ORO of 1.5 mg/L. Results of the monitoring wells were at
least one order of magnitude below the cleanup level.
Free product is present only in one well (DM-6), which has had a relatively stable product level since 2005. The product thickness measurement from 2008 (0.5 feet) is equivalent to approximately 0.082 gallons of free product in a 2-inch-diameter well and 0.33 gallons of free product in a 4-inch annulus.
Based on these data, it is recommended that annual groundwater monitoring be conducted for well DM-12 until such time that cleanup levels are achieved for one additional consecutive monitoring event. It is also recommend that free-product surveys continue on wells that previously contained free product until such time that no free product has been detected for two consecutive monitoring events. Free-product surveys should continue for monitoring wells DM-1, DM-2, DM-4, DM-5, DM-6, and DM-18.
It is also recommended that although the integrity of most vault covers appears to be intact, they be inspected occasionally and repaired if necessary to avoid potential physical hazards. USCG should also evaluate pumping the water-filled vault.
Soil: The No Action, Landspreading, and Offsite Disposal/Treatment alternatives should be retained for further evaluation prior to any work being conducted at the St. Paul LORSTA. SVE,
Bioventing, and Onsite Thermal Desorption technologies were eliminated from further
consideration based on effectiveness, implementability, or cost restriction. |
Louis Howard |
| 9/27/2013 |
Document, Report, or Work plan Review - other |
ADEC reviewed the proposed sampling plan sent by email on 9/27/2013 by the Coast Guard.
Soil sampling by a "qualified person" as defined by 18 AAC 75.990 (100) is approved by ADEC on the conditions that soil sampling for DRO in soil will be sampled in accordance with the 2011 St. Paul Landspread Sampling Work Plan.
ADEC will approve the measurement by a "qualified person" as defined by 18 AAC 75.990 (100) of the DTW/DTP from extraction wells DM-1 to DM-6, DM-15, and DM-21, a total of eight (8) wells.
Sampling of wells DM-12 and DM-13 for DRO (AK102) by a "qualified person" as defined by 18 AAC 75.990 (100) is approved by ADEC.
Data reporting requirements for the LTM efforts will be consistent with ADEC's March 2009 Environmental Laboratory Data and Quality Assurance Requirements technical memorandum. The technical memorandum summarizes the minimum requirements for both laboratory data packages and QA Summaries (data reduction, verification, evaluation, etc.) that MUST be included in all reports containing analytical data submitted to the CS program under the 18 AAC 75 and 18 AAC 78 regulations. |
Louis Howard |
| 5/17/2016 |
Meeting or Teleconference Held |
Conf. call with USCG (M. Ridgway) in 3 months expect a work plan to be delivered for groundwater monitoring and sampling the stockpile of contaminated soil that is being tilled for treatment. USCG is staffed up with additional personnel to project manage sites and funding is finally available to do the tasks. |
Louis Howard |
| 11/17/2016 |
Update or Other Action |
Work Plan for Long-Term Management and Environmental Program Support at the United States Coast Guard LORSTA Saint Paul, Alaska received for review and comment.
The work plan covers soil sampling, groundwater sampling, water and free product measurements, and reinstallation of signs. These activities are currently planned to occur every two years.
See site file for additional information. |
Louis Howard |
| 11/18/2016 |
Document, Report, or Work plan Review - other |
Review comments provided on the LTM work plan.
Main comments were regarding inclusion of PAHs, GRO, BTEX as part of the soil and groundwater sampling and using mann-kendall for groundwater results trend analysis for all wells.
See site file for additional information. |
Louis Howard |
| 8/17/2017 |
Update or Other Action |
Report for Long-Term Management and Environmental Program Support at USCG LORSTA received for review and comment. An oil-water interface probe was used to evaluate the presence or absence of product, and measure the thickness, if present. No detectable amounts of free product were detected in 2017; however, two of the wells, DM-20 and DM-21, exhibited strong POL odors.
Results of the linear trend analysis for the six wells from 2003 through 2017 show that all wells have no trend except for DM-8, which is decreasing, and DM-12, which is probably decreasing. The "probably decreasing" trend result shows a lesser degree of confidence of the statistical calculation, but the plume is likely decreasing over time. The "no trend" results for the other wells can be considered as evidence that the plume concentration is not increasing at those wells.
See site file for additional information. |
Louis Howard |
| 8/23/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the LTM Report (draft).
Main comments were to request that future incremental sampling methodology used for the project take at least 30 increments instead of the 24 increments used at the site. ITRC recommends 30-100 increments. Also, staff requested that petroleum VOCs be analyzed for in addition to BTEX and PAHs.
See site file for additional information. |
Louis Howard |
| 5/17/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft work plan for long term mgt. and divestiture support. Main comments were regarding adding residual range organics to the transformer site and recommending polynuclear aromatic hydrocarbons be analyzed sooner than later for the landspread soils.
See site file for additional information. |
Louis Howard |
| 10/31/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the tech memo for LTM & Divestiture Support. Approval was given for the recommendations made in the report. Consideration should be made for conducting a hotspot removal at sample ID 18CGSPSAFR12S02 where lead was detected at 2,110 mg/kg (“J”). Confirmation sampling after removal of soil in this area should be conducted to demonstrate cleanup level of 800 mg/kg for lead has been met.
See site file for additional information. |
Louis Howard |
| 7/31/2019 |
Cleanup Plan Approved |
Staff approved the small arms range removal action work plan |
Louis Howard |
| 10/22/2020 |
Document, Report, or Work plan Review - other |
September 10, 2020. Two workplans submitted: Draft Groundwater Monitoring Report for USCG LORSTA (September 2020) and Draft Landspread Area Soil Monitoring Technical Memorandum for the Long-Term Management and Divestiture Support at the USCG LORAN Station (September 2020).Comments on the FW report explained additional sampling events may be required for closure. The report stated closure could occur after 2 consecutive sampling rounds with COCs below CULs. No comments on the landspreading report. |
Shonda Oderkirk |
| 3/23/2023 |
Document, Report, or Work plan Review - other |
Draft work plan received. Involves well sampling, soil sampling for lead, and landspread ISM sampling. 4/17/2023 Comments sent. 5/31/2023 Comments resolved, approval for final work plan sent. |
Shonda Oderkirk |
| 12/11/2023 |
Document, Report, or Work plan Review - other |
Draft tech memos for GW sampling and Landspread sampling were received. Both memos recommend further GW and landspread sampling. The work plan approved 2 rounds of GW sampling for 2023 and landspread sampling in 2023 and 2024. This is the first set of results from 2023. DRO exceeds migration to groundwater cleanup levels in DM-6 DM-9, DM-19, and DM-20. Soil samples were also collected for lead analysis, as part of the approved work plan. Those results will be submitted under separate cover. 12/28/2023 Comments sent. 4/10/2024 Final Landspread tech memo approved. |
Shonda Oderkirk |
| 3/4/2024 |
Document, Report, or Work plan Review - other |
Draft tech memo for lead-based paint in soil investigation. One sample was taken from drip line of south side of the Power/Signal and Generation Building. The sample location was selected based on previous XRF screening results. The duplicate sample exceeded CUL for lead at 559 mg/kg. Paint chips have not been analyzed for lead or PCBs. Further work is required at this site to determine impacts of LBP on the exterior of the building. |
Shonda Oderkirk |
| 1/15/2025 |
Document, Report, or Work plan Review - other |
Draft report detailing October 2023 sampling received. Twelve wells sampled, three wells still exceeding DRO cleanup levels. Comments sent February 13, 2025 |
Shonda Oderkirk |
| 4/11/2025 |
Document, Report, or Work plan Review - other |
Final October 2023 GW sampling report received and approved. |
Shonda Oderkirk |
