| Action Date |
Action |
Description |
DEC Staff |
| 11/3/2005 |
Site Characterization Report Approved |
Site Assessment Report prepared by ENSR indicates that elevated concentrations of arsenic contamination exist at several areas across the site. The highest concentrations were found adjacent to the flare pit. Arsenic concentrations in the sampled groundwater monitoring wells were below arsenic cleanup levels. |
Don Fritz |
| 11/4/2005 |
Site Added to Database |
Site added to the Contaminated Sites database. |
Alyce Hughey |
| 11/4/2005 |
Site Ranked Using the AHRM |
Initial ranking done using the AHRM. |
Alyce Hughey |
| 11/4/2005 |
GIS Position Updated |
Using Figure 1-1 from a Site Assessment Report Kenai LNG Facility, from ENSR International, dated April 2003, in conjunction with TopoZone Pro and the KPB Parcel Lookup, entered the coordinates for this site. Metadata includes No Topo Basemap, TopoZone Pro Street Maps, Black and White Aerial Photo, on a Medium Size Map, View Scale 1:24,000, Coordinate Datum NAD83. High degree of confidence in accuracy of location. |
Alyce Hughey |
| 11/4/2005 |
Update or Other Action |
File number 2323.38.036 assigned and entered into the Fileroom database and Contaminated Sites database. |
Alyce Hughey |
| 9/6/2007 |
Update or Other Action |
Phone conversation with Marta Czarneski regarding excavation work that ConocoPhillips intends to do at the site with regard to arsenic concentrations and the potential to encounter petroleum contaminated soil. Discussed options depending on what was encountered and concentrations. Reviewed ENSR report regarding arsenic concentrations across the site. Phone call with Marta Czarneski, requested additional information regarding proposed excavation areas. |
Don Fritz |
| 9/11/2007 |
Update or Other Action |
Denied proposed arsenic background level. History- ConocoPhillips needs to undertake some excavation activity for pipeline maintenance at their facility. I was contacted last week to discuss potentials for encountering petroleum contaminated soil and for encountering soil that may have elevated arsenic levels. On Monday ConocoPhillips submitted a request for a less stringent arsenic cleanup standard based on a statistical evaluation of arsenic concentrations undertaken by Jené Worley. No prior communication/planning regarding the statistical evaluation was conducted with me. Basically, ConocoPhillips wound up utilizing a select group of samples to support their conclusion that background arsenic concentrations should be 12.9 mg/kg.
Several years ago, ENSR collected approximately 350 arsenic samples (including duplicates) to try and determine arsenic concentrations across their site. ConocoPhillips knew that they had some areas that were impacted by facility operations. ENSR utilized arsenic concentrations of 5.5 mg/kg to differentiate between impacted and non-impacted areas. Of the approx. 350 samples, 100 exceeded the 5.5 mg/kg screening standard. Approximately 25 of these 100 samples were not clustered around known areas that had been impacted, however, ENSR concluded that these areas were likely impacted by facility operations, and many of these samples were also clustered. Looking at the ENSR diagrams, a majority of the site met the 5.5 mg/kg arsenic level.
With the results already known, Jené Worley selects samples that she wants to include in their evaluation. They excluded a significant number of the known samples (approx. 170) that met the 5.5 mg/kg standard based on the possibility that they may have been impacted by facility operations. They then included 23 samples that exceeded 5.5 because they were unaware of any impacts that they had in those areas, even though for the most part the samples that were included and that had elevated impacts were in developed locations, and were clustered.
The mean of the samples collected from the undisturbed portion of the site is 4.0 mg/kg arsenic. If I were to utilize their selection of samples and add in the approximately 170 samples that met the 5.5 mg/kg arsenic concentration which were excluded because of potential for impact, I would likely receive an average of less than 5.5 mg/kg.
Basically, their approach just did not appear to be very scientific or unbiased, at least from my viewpoint. ConocoPhillips has a fair amount of undeveloped land at their facility, and they will be submitting a work plan to evaluate background arsenic levels by collecting soil samples in the undeveloped area (area with trees or topsoil remaining in place).
|
Don Fritz |
| 9/12/2007 |
Exposure Tracking Model Ranking |
Intitial Ranking Complete for Source Area: 74907 (Autogenerated Action) |
|
| 9/24/2007 |
Update or Other Action |
Received diagram depicting proposed background sampling locations from Conoco Phillips staff. Requested a work plan for the sampling effort. |
Don Fritz |
| 10/23/2007 |
Update or Other Action |
Phone conversation with Marta regarding her requesting placing low level arsenic contaminated soils back into excavations until a background concentration can be determined. Approved her request. |
Don Fritz |
| 5/14/2008 |
Update or Other Action |
Staff from Weston contacted Linda Nuechterlein in an effort to obtain concensus on background sampling efforts. Requested a meeting to address issues. |
Linda Nuechterlein |
| 5/27/2008 |
Meeting or Teleconference Held |
Marty, Earl and I met with Judd Peterson and Nathan ? (who were representing Conoco). We discussed the problems with the statistical approach that was previously submitted to ADEC by Conoco to determine arsenic background at this site. It was explained that they must use some statistically valid approach to selecting data points. Judd indicated (on behalf of Conoco) that they will revise their statistical approach, and will attempt to use existing sampling data to select points that represent background. It was suggested/requested that Conoco contact ADEC prior to revising their statistical analysis to make certain we are in agreement with the sampling points they select as background. |
Linda Nuechterlein |
| 6/17/2008 |
Update or Other Action |
Jene Worley requested a work session to "discuss my approach for calculating background threshold values (BTV) for arsenic in soil at the ConocoPhillips LNG plant". The objective of this work session is to discuss my analysis in detail and reach a consensus with ADEC about the approach that should be used to calculate a BTV.
I hope our conversation will include the following:
• The site conceptual model.
• The rationale for defining background areas vs. areas of concern.
• The comparison of surface soil data to soil collected at 2 ft. BGS.
• How distributional assumptions of each data set were tested and verified.
• Which statistical methods are appropriate based upon the above.
• How extreme values are tested to determine the presence of outliers.
• Any other relevant considerations.
Once we have come to a consensus about the approach, I will re-run any calculations as needed, then submit a detailed report describing the methodology, data, analyses, and findings for the BTV calculations. I propose this report be used to develop the cleanup standard for arsenic in soil at the LNG Plant.
I would like to first chat with you by phone or email so I can get a good understanding of any specific questions or concerns you might have. After that, let’s meet in person to finalize our approach. I will prepare maps and aerial photos of the site that will help you visualize our rationale for defining the background areas vs. areas of concern."
|
Don Fritz |
| 8/4/2008 |
Meeting or Teleconference Held |
Contaminated Site staff (Nuechterlein, Marty Brewer, Fritz) met with Jene Worley regarding background arsenic sampling at the Phillips Petroleum LNG Plant-2002 site. Jene was representing Conoco Phillips (Marta Czarnezki participated via teleconference), and wanted to further discuss and defend her prior efforts to determine background arsenic concentrations using historical data collected to characterize arsenic concentrations across the site. Staff agreed to further review the use of the data. |
Don Fritz |
| 9/28/2009 |
Update or Other Action |
Reviewed initial work plan for arsenic contamination. Phone call with Jene explaining why ADEC could not accept the work plan as proposed. |
Don Fritz |
| 10/1/2009 |
Update or Other Action |
Sent letter to ConnocoPhillips identifying concerns with the data set selected for purposes of representing background concentrations. Provided further recommendations for determining background concentrations. |
Don Fritz |
| 10/5/2009 |
Update or Other Action |
Reviewed revised work plan for arsenic contamination. Phone call with Jene identifying ADEC comments & concerns with the work plan as proposed. Jene will utilize the comments to formulate a revised work plan. |
Don Fritz |
| 10/13/2009 |
Site Characterization Workplan Approved |
Reviewed revised work plan and issued an approval letter. |
Don Fritz |
| 1/14/2010 |
Meeting or Teleconference Held |
Phone conversations with Jene regarding arsenic soil sample results from their background sampling effort and sulfolane/sulfolene usage at the LNG Plant/Beluga River as pertaining to Flint Hills. |
Don Fritz |
| 6/16/2010 |
Site Visit |
Site visit with Paul and Linda to familiarize Linda with the areas impacted by arsenic. |
Don Fritz |
| 9/13/2011 |
Cleanup Level(s) Approved |
Reviewed the August 11, 2011 transmittal letter, Kenai LNG Plant, Background and Cleanup Level Determination for Arsenic in Soil (Revised) and the Kenai Liquid Natural Gas (LNG) Facility, Cleanup Level Determination for Arsenic in Soil Final-Revision 1, August 2011 report, prepared by Weston Solutions, Inc., for ConocoPhillips Alaska. Approval for the proposed soil cleanup level of 16 mg/kg for arsenic in soil was issued contingent upon the recognition that this cleanup level is based upon an industrial/commercial exposure scenario, with this stipulation/condition: (Site occupation and use remains industrial/commercial. Should site occupation and use change to any exposure category that could present greater risk to human exposure and health, ConocoPhillips must notify ADEC of this change. A revised soil cleanup level determination for arsenic will likely be required.) Also approved the three bulleted recommendations presented in the Section 4 Recommendations portion of this Weston Solutions' report. 1) Perform additional discrete soil sampling to further delineate areas containing elevated arsenic in soil at the Kenai LNG Facility; 2) Following discrete soil sampling, develop a site map depicting concentration zones of arsenic in soil, to display areas that may require future remediation efforts (high risk), require institutional controls, and are at or below natural background levels (low risk) and; 3) Prepare a Soil Management Plan to be implemented during operations at the Kenai LNG Facility that clearly state how soil from the various arsenic management zones will be managed. |
Paul Horwath |
| 9/13/2011 |
Commercial/Industrial Land Use Determination |
ADEC determination issued that a commercial/industrial land use is appropriate and acceptable for this site. |
Paul Horwath |
| 10/4/2012 |
Document, Report, or Work plan Review - other |
Reviewed the June 2012, Kenai Liquefied Natural Gas (LNG) Facility Soil Sampling Findings Report from Weston Solutions. On October 3rd through October 5th of 2011, a total of 106 XRF field screening samples and 22 soil laboratory analytical samples (20 samples + 2 duplicates) were collected from the three different zones previously identified as having arsenic concentrations exceeding the ADEC approved alternate cleanup level for arsenic of 16 mg/kg. Zone 1, located in the northwest section of the facility near the north end of the diversion dike had field screening and laboratory sample results ranging from 3.3 to 25.4 mg/kg at depths of 0-2 ft bgs. Zone 2, located west/southwest of the burn pit had field screening and laboratory sample results ranging from 6.1 to 12.4 mg/kg at depths of 0-2 ft bgs. Zone 3, located south and west of the oxidation pond was subdivided into Zones 3, 3A, 3B, 3C, 3D and 3E. Zone 3 is located to the west of the oxidation pond with field screening and laboratory sample results ranging from 6.2 to 61.8 mg/kg at depths of 0-2 ft bgs. Zone 3A is located on a gravel road to the west of the oxidation pond with field screening and laboratory sample results ranging from 5.8 to 26.4 mg/kg at depths of 0-2 ft bgs. Zone 3B is located north of Zone 3 with field screening and laboratory sample results ranging from 4.7 to 43.6 mg/kg at depths of 0-2 ft bgs. Zone 3C is located southeast of the oxidation pond with field screening and laboratory sample results ranging from 7.3 to 41.7 mg/kg at depths of 0-2 ft bgs. Zone 3D is located due south of Zone 3C in an area believed to be a storage area with field screening and laboratory sample results ranging from 3.6 to 15.5 mg/kg at depths of 0-2 ft bgs. Zone 3E is a small extension of Zone 3, located along the road with field screening and laboratory sample results ranging from 3.9 to 9.3 mg/kg at depths of 0-2 ft bgs. One sample collected in Zone 3, labeled "Suspect" had field screening results of 182 mg/kg and the laboratory sample detected 175 mg/kg arsenic at a depth of 4 inches bgs. This area had been previously posted with a Caution sign that said “Caution Soil May Contain Organic Arsenic Contact Safety or Environmental Prior to Excavating”. Of the eight different sampled zones, five had sample results exceeding the alternate arsenic cleanup level of 16 mg/kg (Zone 1, 3, 3A, 3B, and 3C), with an estimated 56,123 square feet of soil exceeding the alternate cleanup level.
Two nearby groundwater monitoring wells were sampled and tested for arsenic. Arsenic was detected at 1.44 ug/L and 3.17 ug/L, below the ADEC groundwater cleanup level of 10 ug/L. |
Alyce Hughey |
| 12/4/2012 |
Document, Report, or Work plan Review - other |
Issued a letter to ConocoPhillips identifying areas where the arsenic assessment work failed to define the limits of the areas of impact, and requesting clarification on historical disposal of aresenic containing waste materials. |
Paul Horwath |
| 5/16/2013 |
Update or Other Action |
Received ConocoPhillips May 13, 2013 letter-response to ADEC's report review letter dated December 4, 2012. Sarah Kenshalo, Environmental Coordinater for ConocoPhillips, replaces Micheal Nelson, as the CP project manager and point of contact for ADEC. |
Paul Horwath |
| 6/27/2013 |
Update or Other Action |
Issued a letter replying to ConocoPhillips (CPAI) May 13, 2013, letter. Informs CPAI that further assessment and definition of the areas of arsenic impacted soil are required in order for ADEC to issue a Cleanup Complete decision with Institutional Controls, based on an industrial/commercial exposure soil cleanup level for arsenic. |
Paul Horwath |
| 3/4/2014 |
Document, Report, or Work plan Review - other |
Reviewed Weston Solutions' February 2014 Kenai Liquefied Natural Gas (LNG) Facility Soil Sampling Findings Report 2013 Arsenic Investigation. In the effort to further delineate the extent of arsenic contamination in Zone 1, Zone 3A, Zone 3B and Zone 3C a total of 34 soil borings were advanced, 103 XRF field screening soil samples and 11 analytical laboratory soil samples were collected on October 9 and 10 of 2013. Zone 1 XRF Average Arsenic Results ranged from 3.2 to 14.0 mg/kg, the adjusted XRF Arsenic Results ranged from 3.6 to 21.8 mg/kg, with one exceeding the approved arsenic level at 21.8 mg/kg. Laboratory samples detected arsenic at 6.14 to 9.77 mg/kg. Zone 3A XRF Average Arsenic Results ranged from 2.3 to 5.3 mg/kg, the adjusted XRF Arsenic Results ranged from 2.1 to 7.1 mg/kg, and the single laboratory sample detected arsenic at 4.50 mg/kg. Zone 3B XRF Average Arsenic Results ranged from 1.8 to 20.7 mg/kg, the Adjusted XRF Arsenic Results ranged from 1.2 to 33.1 mg/kg, and laboratory data ranged from 3.77 to 10.70 mg/kg. Three of the Average XRF Arsenic Results exceeded the arsenic cleanup level at concentrations at 16.3 to 20.7 mg/kg, and three of the Adjusted XRF Arsenic Results exceeded the arsenic cleanup level at concentrations from 25.7 to 33.1 mg/kg. Zone 3C XRF Average Arsenic Results ranged from 3.9 to 22.7 mg/kg, with two above the approved arsenic soil cleanup level at 16.3 and 22.7 mg/kg. The Adjusted XRF Arsenic Results ranged from 4.8 to 36.4 mg/kg, with ten samples above the approved arsenic cleanup level at 16.7 to 36.4 mg/kg. Laboratory analytical results ranged from 7.78 to 37.5 mg/kg with one testing above the approved arsenic cleanup level at 37.5 mg/kg at a depth of 0-2 inches below ground surface. Based on the sample results it is estimated that approximately 53,301 square feet of arsenic impacted soils exceed the Method Three Industrial/Commercial soil cleanup level of 16 mg/kg. |
Alyce Hughey |
| 7/9/2014 |
Update or Other Action |
Reviewed Weston Solutions' February 2014 Arsenic Investigation Soil Sampling Findings Report and presented two questions to Sarah Kenshalo with ConocoPhillips, via e-mail:
1) On page 8, in Section 3.6, in the last sentence; the text states “…, remaining soil was spread in Zone C upon project completion.” Does “Zone C” mean Zone 3C, or Zone 3? Perhaps Weston can provide clarification for our understanding?
2) On page 9, in Section 4.2, in the first sentence; the text states “Zone 1 is located in the northeast section of the LNG Facility.” Zone 1 is actually located in the northwest section of the LNG facility, correct?
Awaiting Ms. Kenshalo's response/answer. |
Paul Horwath |
| 9/24/2014 |
Update or Other Action |
Received ConocoPhillips' reply to the two questions asked about Weston Solution's Feb. 2014 Arsenic Investigation Soil Sampling Findings Report. Placed corrected replacement pages, which were provided by Ms. Kenshalo, into ADEC's copy of the Weston Solutions report. |
Paul Horwath |
| 1/5/2015 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 74907 Phillips Petroleum LNG Plant-2002. |
Paul Horwath |
| 2/12/2015 |
Update or Other Action |
ADEC approved ConocoPhillips February 11, 2015, Plan for Arsenic Signage and Placement. This plan for signage placement is one of the Institutional Controls to control outdoor worker access and exposure to the areas of arsenic contaminated soil. |
Paul Horwath |
| 2/25/2015 |
Update or Other Action |
ADEC approved ConocoPhillips February 13, 2015, Arsenic Training Module. This training module will serves as one of the Institutional Controls to control outdoor worker access and exposure to the areas of arsenic contaminated soil. |
Paul Horwath |
| 3/3/2015 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 74907 Phillips Petroleum LNG Plant-2002. |
Paul Horwath |
| 10/13/2015 |
Update or Other Action |
Send closure decision documents, as revised by ADEC management, to ConocoPhillips' Sarah Kenshalo for final ConocoPhillips' review/comments. |
Paul Horwath |
| 1/7/2016 |
Cleanup Complete Determination Issued |
A Cleanup Complete Determination - Institutional Controls letter was issued to ConocoPhillips Alaska Natural Gas Corporation. ConocoPhillips must sign and record a Notice of Environmental Contamination for each of the two affected properties, with the ADNR Kenai Recorder's Office. |
Paul Horwath |
| 1/8/2016 |
Institutional Control Record Established |
Institutional Controls established and entered into the database. |
Paul Horwath |
| 1/22/2016 |
Update or Other Action |
Attachment A: Cleanup Complete-ICs Agreement and Signature Page received from ConocoPhillips with signature of Michael A. Mindrup. |
Paul Horwath |
| 11/15/2016 |
Institutional Control Compliance Review |
IC compliance review conducted. Staff changed from Paul Horwath to IC Unit. The two Notices of Environmental Contamination were officially recorded with the State ADNR Kenai Recorder's Office on February 4, 2016 (Document Nos. 2016-000974-0 and 2016-000975-0). Reminder system set to follow-up every three years. |
Kristin Thompson |
| 5/10/2019 |
Institutional Control Update |
An Institutional Controls reminder letter was e-mailed to the landowner after contact information updating. |
Mossy Mead |
| 5/30/2019 |
Institutional Control Update |
Received updated arsenic employee training and signage plans from the current responsible party at this site. |
Mossy Mead |
| 2/25/2022 |
Institutional Control Compliance Review |
Received an IC compliance check-in email from the current responsible party on this date. Land use of the property has not changed and they are in compliance with all ICs. |
Evonne Reese |
| 8/31/2023 |
Institutional Control Update |
Marathon contacted Soldotna staff and asked for permission to mine gravel from the south west corner of the LNG plant to their refinery across the highway.
The area of gravel excavation was outside of the identified waste disposal areas specified in the Institutional Controls.
Approval was granted to move gravel.
In the process of reviewing site information a formerly used fire training facility was identified.
Marathon was questioned about the use of any firefighting foams on the facility.
Marathon stated that firefighting foams are not used in the case of LNG fires and that foams are not used for training, and are not stored at the facility.
|
Evonne Reese |
