| Action Date |
Action |
Description |
DEC Staff |
| 1/11/2002 |
Site Added to Database |
Waste oil release to surface soils. |
Bruce Wanstall |
| 1/11/2002 |
Site Ranked Using the AHRM |
Preliminary ranking. |
Bruce Wanstall |
| 1/7/2003 |
Update or Other Action |
Landowner changed to US Air Force. |
Debra Caillouet |
| 5/12/2004 |
Update or Other Action |
The Air Force sent photographs of this area taken yesterday showing approximately 100 additional drums, AST's, vehicles and other containers of potentially hazardous substances have been added to this site. Several of the photographs indicate ongoing releases. |
Debra Caillouet |
| 5/18/2004 |
Meeting or Teleconference Held |
Staff met with the Alaska Energy Authority, Air Force, and PERP to discuss an area where tanks and drums have been abandoned in Nikolski. The area impacted is on Tract 39A and Tract 39B. The Air Force is the landowner for Tract 39A; the other landowner is unknown but may be the Chaluka Corporation. The AEA did place the tanks from the village tank farm upgrade there and drums filled with approximately 1200 gallons of oily water that had been removed from the village's fuel tanks. The tanks were not cleaned but were drained. The tanks have holes in the tops of them and will collect water. AEA is planning on decommissioning the tanks in 2005 by cleaning and cutting the bungs and placing signs on them to not use them. Even though the source of the rest of the drums is the powerhouse, AEA does not believe it can dispose of them with the funding it has to cleanup the powerhouse site. AEA is installing a new powerhouse for the village this summer and it will have a used oil burner but, they say that the burner is not capable of burning the oil the powerhouse has drummed and left on Tracts 39A & B. |
Debra Caillouet |
| 8/18/2004 |
Site Characterization Workplan Approved |
Plan is to characterize the contents of the drums left on site by AEA, drums that are from the IRA council will be addressed separately. |
Debra Caillouet |
| 11/2/2004 |
Site Characterization Report Approved |
AEA characterized the drums that they left on the site. The report identifies 64 drums located in the area of concern, two of them showing signs of leakage, fourteen could not be opened due to rusted bungs, and three were found to be empty. All drums that could be opened were sampled with a Coliwasa and measurements of the amount of each phase found recorded. Samples of the water phase were collected from seven drums, oil samples from four drums. The sampling plan that was approved by DEC stated that ten drums would be sampled.
The results from the samples that were acquired show that all seven water samples contain petroleum contamination above DEC 18 AAC 75.335 Table C values and in three of seven drums, benzene concentrations that are above the RCRA standard of 0.5 mg/L. The four petroleum phase samples that were analyzed for the oil burning specifications did not have halogens, PCBs, or metals above their respective limits for on-specification used oil. The flash points measured from 102 °F to 165 °F. The on-specification standard for used oil is a minimum flash point of 100 °F. RCRA ignitability is a flash point less than 140 °F, therefore the oil phase is regulated by EPA. The report estimates 1,515 to 2,285 gallons of water and 642 to 1,142 gallons of diesel fuel is located within the drum cache.
Staining and stressed vegetation was observed in the area occupied by the drums and tanks but no soil samples were taken. The report concludes that the water will require treatment and is considered a RCRA regulated waste and that the oil is diesel fuel and can be burned in a used oil burner. It recommends soil samples be collected and tested to determine the type and amount of contamination and then selection of a treatment method. |
Debra Caillouet |
| 11/23/2004 |
Update or Other Action |
A conditional approval was granted for the drum and tank cleanup plan. Items to be addressed in an addendum include: DEC does not object to treating petroleum contaminated water, some of which has been determined to be a hazardous waste, on-site in a tank or container as long as the resultant wastewater meets applicable discharge standards prior to discharge and other wastes (i.e., fuel that is not suitable for reuse, filter material and any other wastes) are properly treated or disposed. However, the plans should be coordinated with EPA to ensure applicable RCRA requirements are met; DEC does not concur with treating hazardous waste in the soil remediation units and has not approved this as part of the operation plan for the units; Prior to shipping wastes off-site for treatment or disposal, please submit an addendum to the workplan providing the name and location of the treatment or disposal site(s) that will be used;
DEC does not concur with hauling contaminated soil from the drum site to the soil treatment site using a front-end loader. Since there are dump trucks on site, they should be used to transport the contaminated soil, which should be more efficient and minimize the potential for spilling and tracking contaminated soil between the two sites; Please remove the reference to injecting the drum wastewater into the soil treatment system. Treated wastewater should be discharged where it will not contact surface water or more stringent discharge standards (10 ug/L total aromatic hydrocarbons, 15 ug/L total aqueous hydrocarbons) will apply. Please show, in the workplan addendum, the planned discharge area; and, As noted above, DEC does not approve treating petroleum contaminated water that is a hazardous waste by injecting it into the M1-12 soil remediation units. |
Debra Caillouet |
| 12/14/2004 |
Cleanup Plan Approved |
An addenum addressing the gaps identified in the conditional approval was reviewed and approved. |
Debra Caillouet |
| 1/6/2005 |
Site Visit |
Staff traveled to Nikolski and inspected the site cleanup operations. The drums and tanks that AEA had identified as their responsibility have been cleaned and moved to a lined and bermed area on the AF property near the thermal treatment units. There was some evidence of sheen in the containment that should be addressed during demob. |
Debra Caillouet |
| 3/1/2005 |
Interim Removal Action Approved |
Work plan to consolidate the village drums and then move into the tank farm area approved. The contents of the drums still need to be addressed and the soil contamination they left along with the other miscellaneous debris. |
Debra Caillouet |
| 4/29/2005 |
Update or Other Action |
Staff sent a comment letter to AEA regarding the draft Old Tank Farm and Drum cleanup report. |
Debra Caillouet |
| 10/4/2005 |
Interim Removal Action Approved |
Staff sent an approval letter for consolidation and characterization of drum contents by the IRA Council |
Debra Caillouet |
| 10/4/2005 |
Site Characterization Workplan Approved |
Staff also approved the site characterization work plan that was included in the drum consolidtation plan. |
Debra Caillouet |
| 12/12/2005 |
Update or Other Action |
Staff approved the discharge of treated wastewater from the cleaning on the drums
|
Debra Caillouet |
| 1/4/2006 |
Site Characterization Report Approved |
Staff conditionally approved the site characterization and drum consolidation report. The report does not include the MDLs in the summarized data table and does not provide a discussion of the elevated MDLs and the impact on the site characterization where that occurred. |
Debra Caillouet |
| 5/2/2006 |
Update or Other Action |
Drum Consolidation & Site Characterization Report received for review and comment. The ADEC provided conditional approval for the December 27, 2005 Draft Nikolski Drum Consolidation and Site Characterization Summary Report on January 4, 2006 as long as their concerns are considered in the development of a remedial action plan for the site. This amendment first addresses ADEC comments, followed by the USAF comments. TPECI follows each agency comment with a response.
The Nikolski IRA plans on excavating petroleum-contaminated soil from the drum storage area during the summer of 2006. Nikolski proposes to excavate approximately 920 cubic yards (yds3) of petroleum contaminated soil from the site. The IRA will excavate soil up to three feet in depth in the area that is proposed on Figure 9. The IRA will temporarily stockpile soil across the road within the lined containment area. New containment liner may be necessary if the existing liner has been compromised. The IRA will allow the excavated soil to sit in the containment area allowing the water to leach from the soil so the leachate water can be treated & discharged on site. By allowing the soil to dewater, the IRA will minimize the potential for spreading contamination during transport & will remove some of the potential contamination from the soil.
Soil will be excavated using a backhoe & a Caterpillar 966 front-end loader. The IRA will have oil-boom on site while excavating the soil. As the excavation proceeds the boom will be placed into the water to capture any free product that weeps from the soil. The boom will stop free product from contaminating the side walls of the excavation. The IRA will only excavate up to three feet in depth because the GW is shallow & any free product should remain on top of the water.
Once PID screening indicates that the contamination has been removed, TPECI will collect confirmation samples for DRO, RRO, & BTEX. TPECI will screen every 100 square feet of surface area & collect a confirmation sample for every 250 square feet of surface area. TPECI expects to collect most if not all confirmation samples from the sidewalls of the excavation because TPECI expects the excavation to fill with water as the soil is excavated. However, TPECI will attempt to collect samples from the bottom of the excavation. The Nikolski IRA will excavate contaminated soil from the site to meet ADEC 10-times the cleanup concentrations designated in Migration to GW for the under 40-inch Zone. The IRA will not be able to excavate under the USAF dozer. Boom material & sorbent pads will be used to capture free product on the water surface to avoid contaminating uncontaminated areas. All boom & sorbent pads will be burned in a Smart Ash Burner®.
The IRA will need to excavate monitoring well #2 because it is located within a contaminated area (grid square #12). If possible, a new monitoring well will be placed in the same location. TPECI will collect water samples from MW1, MW2, & MW3 after the excavation has been backfilled. MW3 may not produce a water sample if the well is purged. TPECI may choose to collect the sample without purging the well. TPECI should be able to collect a water sample for GRO & BTEX, but the well may not produce enough water for DRO analysis. GW samples will be required to meet ADEC GW cleanup levels. |
John Halverson |
| 5/4/2006 |
Meeting or Teleconference Held |
Meeting
ADEC had four comments which were addressed within the May 2, 2006 amendment. The ADEC stated that the amendment addressed their comments & that the ADEC was satisfied with the report & amendment.
Mr. Halverson then directed the meeting towards the USAF comments. Overall, the amendment answered most of the USAF questions, but the USAF had a few items that they wanted changed.
Follow up items:
Mr. Tarbox (USAF):
1. Look into additional funding to help the IRA in dismantling the dozer so the IRA can dispose it in the monofill that the IRA has permitted.
2. Check on the statement “TCE was detected in every surface and groundwater sample, ranging from 1.6 to 14,500 µg/L.”
Mr. Anklewich (TPECI):
1. Will make necessary changes to the May 2, 2006 Amendment to address USAF comments. ADEC comments have been addressed sufficiently.
2. Will Prepare a Cleanup Plan outlining IRA activities for remediating the contaminated soil and monitoring potential groundwater contamination.
3. Prepare a Cleanup Summary Report outlining the activities that are performed and summarizing results of the cleanup.
Ms. Kyle (Nikolski IRA):
1. Determine what equipment the IRA owns that could be used for dismantling dozer.
2. Determine available IRA funding and schedule to complete the soil removal.
See site file for additional information. |
John Halverson |
| 7/25/2006 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Corrective Action Plan sent on July 18, 2006 for review and comment.
1. Table 2, page 15. The GW Cleanup Level should be shown as 10 times the level in 18 AAC 75.345 if you are planning to clean up using a determination under 18 AAC 75.350 that the GW is not a potential drinking water source. The values shown in the last row should be benzene—0.05 mg/l, ethylbenzene—7 mg/l, toluene—10 mg/l & xylenes—100 mg/l.
2. Section 4.1. When a final determination of the location for the landfarm is made, a more thorough Operations Plan will be needed than the information in this work plan.
a. It should include:
i. the location of the proposed landfarm
ii. the location of surface water or drinking water sources
iii. an evaluation of the potential for contaminants to leach & impact either surface water or drinking water
iv. the location of roads or other structures with 500’
v. the maximum depth that the contaminated soil will be applied to the area & the dimensions of the landfarm
vi. the use of any additives & the frequency of tilling.
b. The plan should also describe what measures will be used to secure the area from trespass & a letter of concurrence for use of the land by the landowner.
3. Section 5.2. Please expand the excavation depth if GW is not encountered & field screening indicates contamination above the cleanup level exists.
4. Section 5.2.2.1.
a. If the containment area south of the site is used, based on an inspection of the liner, what would the capacity of it be (note also this is on Air Force land & would need to be included in the right of entry).
b. Please also provide the proposed location for any additional stockpile(s) that will be created.
c. The collection of leachate from the stockpiles should be expanded to include a location for the water treatment & a method for transporting the leachate to the treatment area.
5. Section 6.1. The treated water will need to meet the 18 AAC 75.345 Table C values to be discharged.
6. Table 6. Please revise the values in the table to show RRO in soil using the 10 times rule at 10,000 mg/kg which is based on the ingestion pathway. The GW cleanup limits in this table are the Table C values & if you are proposing the use of a determination under 18 AAC 350 these should be increased 10 times. The basis for the cleanup level would then be 18 AAC 75.345(2), 10 times the GW cleanup level. The two sentences above Table 6 should also be changed to reflect 10 times the Table C values.
7. My understanding is that the proposed monofill is still in the permitting process. The uncertainty associated with the use of this location for the landfarm is significant. DEC suggests that the IRA Council should look for another site to landfarm the soil or plan for long-term stockpiles of the excavated contaminated soil until either the monofill is completed or another location is approved.
8. Section 7.1. The soil monitoring plan should include how the locations for the field screening samples will be chosen. The final soil sampling should be statistically derived. DEC suggests the use of Visual Sampling Plan to determine the number of samples to calculate a 95% confidence level with a 5% a error. (It can be downloaded from http://dqo.pnl.gov/vsp.
9. Table 7. Please change the cleanup level for RRO to 10,000 mg/kg.
10. Section 11.5. Please attempt to report all soil in one unit of measure & all water in one unit of measure.
11. Section 16.0. Although DEC has no objection to removing soil with contamination below the levels proposed in Table 6 of this work plan, the Nikolski IRA can utilize field screening & laboratory confirmation sampling to minimize the amount of soil below the cleanup levels removed. |
Debra Caillouet |
| 9/26/2006 |
Cleanup Plan Approved |
Robert J. Blankenburg SW Program Coordinator approved the General Permit # SWG0303000 for One-Time Disposal of Construction and Demolition Debris, Drum and Metals Consolidation Project.
The landfill will be located within NW 14, SE 14, Section 33, Township 83 South, Range 136 West Seward Meridian on land owned by the Chaluka Corporation. The Department is issuing this general permit to the Native Village of Nikolski in accordance with Alaska Statute 46.03, and the Alaska Administrative Code, Title 18, Chapters 15 and 60 (18 AAC 15 & 18 AAC 60). Please review the conditions and stipulations contained in the attached permit, and those listed below, and ensure they are all understood. This permit is effective upon issuance and expires January 31, 2008.
To prepare the site for disposal, the permittee must clear the site of all debris and vegetation. The construction and demolition waste must not be commingled with any other waste, and a separation of 4 feet between waste and groundwater must be maintained. Upon completion of the project, the permittee must close the site, cover the waste with at least 24 inches of soil, and post proper signage as stated in the permit. The permittee is responsible for post closure monitoring and maintenance of the site as stated in the permit. Any future actions that may disturb the cover of the landfill must be approved by the Department.
Any person who disagrees with this decision may appeal the decision by requesting an adjudicatory
hearing, using the procedures contained in 18 AAC 15.200-310. Hearing requests must be delivered to the Department of Environmental Conservation, 555 Cordova Street, Anchorage, Alaska 99501, within
30 days of receipt of this letter. If a hearing is not requested within 30 days, the right to appeal is waived and the decision becomes final. Even if an adjudicatory hearing has been requested and granted, all permit conditions remain in full force and effect.
See site file for additional informaton |
John Halverson |
| 11/8/2007 |
Exposure Tracking Model Ranking |
|
Debra Caillouet |
| 11/23/2015 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 74911 name: Drums |
Louis Howard |
