| Action Date |
Action |
Description |
DEC Staff |
| 1/6/1988 |
Preliminary Assessment Approved |
The high toxicity/persistence of PCBs in the environment combined with the heavy reliance on local groundwater supplies suggests a potential exists that PCBs have migrated into the groundwater in this area. |
Former Staff |
| 11/21/1988 |
Update or Other Action |
(Old R:Base Action Code = SI - Site Investigation). Results of all 12 soil samples: PCB concentrations 1.2 to 380 ppm. EPA states it isn't planning any immediate action but will discuss results and potential future involvement with DEC. |
Former Staff |
| 1/1/1992 |
Site Added to Database |
PCBs. |
Former Staff |
| 12/2/1993 |
Update or Other Action |
(Old R:Base Action Code = NFA - No Further Action Required (CERCLA)). EPA NFA letter. |
Former Staff |
| 4/21/1994 |
Site Ranked Using the AHRM |
Initial ranking. |
Former Staff |
| 12/16/1996 |
Site Ranked Using the AHRM |
Re-ranked site. Changed Quantity Value from 4 to 2.1; Air Exposure Index Value from 0.2 to 0.1; GW Usage Value from 1 to 0.8; and SW Exposure Index Value from 0 to 0.4. |
Scott Pexton |
| 7/21/1998 |
Update or Other Action |
Verbal approval of PCB Sampling Inspection Report, prepared by USEPA Alaska Operations Office. |
Scott Pexton |
| 10/14/1999 |
Site Ranked Using the AHRM |
Site reranked based on file review. |
Scott Pexton |
| 11/29/1999 |
Update or Other Action |
Received email with file attachments with request for guidance on several sampling and regulatory issues. |
Scott Pexton |
| 1/4/2000 |
Meeting or Teleconference Held |
Meeting held with representatives of Prescott Equipment Co., AlasChem Engineering, Alaska Pollution Control, and EPA (via teleconference) to discuss regulatory and site sampling issues. |
Scott Pexton |
| 1/13/2000 |
Update or Other Action |
Received copy of letter to Dan Duncan of Region 10 EPA requesting a determination of occupancy level for the property. |
Scott Pexton |
| 2/23/2000 |
Update or Other Action |
Received copy of letter from EPA Region 10 with a determination of low occupancy level for the property based on information provided in a January 13, 2000 letter from Ralph Hulbert. |
Scott Pexton |
| 2/28/2000 |
Update or Other Action |
Received email with file attachment letter from Ralph Hulbert of AlasChem Engineering that identifies issues of concern regarding timing of site characterization, target cleanup level options, and sampling issues. |
Scott Pexton |
| 3/6/2000 |
Meeting or Teleconference Held |
Meeting with Prescott representative Steve Barber and consultant Ralph Hulbert to discuss site issues. |
Scott Pexton |
| 8/1/2000 |
Update or Other Action |
Received email from Ralph Hulbert with attachments of the draft site characterization work plan. |
Scott Pexton |
| 8/7/2000 |
Meeting or Teleconference Held |
Meeting with Prescott representative Steve Barber, Ralph Hulbert (AlasChem Engineering), Carl Luchsinger, (Alaska Pollution Control), and Dan Duncan (via telephone) to discuss site characterization. |
Scott Pexton |
| 8/10/2000 |
Update or Other Action |
Received fax from Ralph Hulbert with proposed site characterization sampling schedule. |
Scott Pexton |
| 8/21/2000 |
Update or Other Action |
Received letter from Dan Duncan (Region 10 EPA) that indicates approval of the site characterization plan. |
Scott Pexton |
| 8/31/2000 |
Update or Other Action |
Letter sent with approval of site characterization plan subject to a condition that a suitable field test kit comparison study be completed to demonstrate an acceptable correlation between field test kit results and Method 8082 laboratory results. |
Scott Pexton |
| 9/22/2000 |
Update or Other Action |
Received email from Ralph Hulbert with attachments providing a status report of work activities. |
Scott Pexton |
| 11/3/2000 |
Update or Other Action |
Received email from Ralph Hulbert with attachment summary of preliminary lab results. |
Scott Pexton |
| 12/4/2000 |
Update or Other Action |
Received email from Ralph Hulbert with attachment the provided field test kit results of PCB samples collected from various locations at two or six foot depths. |
Scott Pexton |
| 1/10/2001 |
Update or Other Action |
Received email from Ralph Hulbert with PDF file attachment listing lab results for a composite sample tested for metals. |
Scott Pexton |
| 1/17/2001 |
Meeting or Teleconference Held |
Meeting held at ADEC offices with Ralph Hulbert of AlaskChem Engineering, Scott Pexton, Jim Frechione, and David Verbrugge to discuss site characterization/cleanup issues related to petroleum hydrocarbons, metals and PCBs. |
Scott Pexton |
| 1/26/2001 |
Site Ranked Using the AHRM |
Site reranked based on lab and field test kit results submitted to date. Changed quantity value from 2.1 to 3. |
Scott Pexton |
| 2/6/2001 |
Update or Other Action |
Received email message from Ralph Hulbert with several PDF attachments regarding his request for EPA review of his PCB field test kit validation proposal. |
Scott Pexton |
| 3/9/2001 |
Update or Other Action |
Received Interim Site Assessment Report, prepared by Ralph Hulbert of AlaskChem Engineering.
The report noted that 517 surface samples were collected over the approximately 1.5 acre site and analyzed by either field screening test kits or by laboratory analysis for PCBs. Composite sampling was performed on a grid based sampling scenario. 10 with one duplicate sample were analyzed in the laboratory and those results showed PCBs ranging from 4.6 to 345.0 ppm. Sampling using the RaPID Assay field screening kits was performed at 113 locations. Sampling runs for field screening kits, however, were rejected from two of the sampling batchs due to internal quality control problems. Of the RaPID Assay test results from the remaining five sampling runs that were used, the highest PCB level detected was 1,145.7 ppm at area C4 a-4e (run 5).
80 samples consisting of 8 composites were collected from concrete at the site. All samples were <10 ppm except for composite C63 that detected 226 ppm PCBs.
Subsurface sampling was performed to a depth of 6 feet 112 samples were taken from 14 locations and composited.
The report also included an appendix that provided data on a comparison study that Hulbert performed at the site comparing PCB field test kits to laboratory analysis results, and an appendix proposing further cleanup at the site. |
Scott Pexton |
| 4/2/2001 |
Update or Other Action |
Received Site Assessment Workplan for Petroleum and Metals; Revision 1 prepared by AlaskChem Engineering. |
Scott Pexton |
| 4/25/2001 |
Update or Other Action |
Letter sent to Jack and Mary Hendrickson with request for a revised work plan to address ADEC comments. |
Scott Pexton |
| 5/15/2001 |
Site Characterization Workplan Approved |
Letter sent to Jack and Mary Hendrickson with ADEC approval of a Site Assessment Workplan for Petroleum and Metals; Revision 3 prepared by AlaskChem Engineering. Sampling is scheduled to begin within 10 days of ADEC approval. |
Scott Pexton |
| 8/8/2001 |
Update or Other Action |
Letter received from Department of Law indicating a check was received on behalf of ADEC for cost recovery (Bill #CO25106). |
Scott Pexton |
| 8/9/2001 |
Update or Other Action |
ADEC received "Interim Site Assessment Report Screening for Petroleum and Metals" prepared by Ralph Hulbert of AlaskChem Engineering. ADEC also received correspondence from AlaskChem Engineering with Site Assessment Report Overview.
The report showed that samples were collected to 6' BGS at four locations to determine background levels for petroleum and TOC.
In addition, 14 samples were collected at the surface at the direction of DEC where staining was observed. Samples were analyzed for GRO, DRO, RRO, BTEX, arsenic, cadmium, chromium and lead. DRO was detected up to 3,350 mg/kg, RRO up to 13,300 mg/kg, arsenic up to 17.3 mg/kg, cadmium up to 8.07 mg/kg, total chromium up to 42.5 mg/kg, and lead up to 465 mg/kg. |
Scott Pexton |
| 10/29/2001 |
Site Ranked Using the AHRM |
Site reranked based on information in the Interim Site Assessment Report and other information on file. SW Environments value changed from 2 to 0 (Ship Creek is located more than 1/4 mile from site). |
Scott Pexton |
| 11/9/2001 |
Update or Other Action |
ADEC received a copy of a letter from Department of Law indicating a check was received on behalf of ADEC for cost recovery (Bill #CO25155). |
Scott Pexton |
| 11/12/2001 |
Update or Other Action |
Email with attachment received from Ralph Hulbert of AlaskChem Engineering with proposed actions levels for PCBs and petroleum. The proposal referred to a cleanup option specified in 40 CFR 761.61(a)(4)(i)(B)(2): bulk PCB remediation wastes may remain at a cleanup site at concentrations greater than 25 ppm and less than or equal to 50 ppm if the site is secured by a fence and marked with a sign including the ML mark. All soil above 50 ppm (estimated 35-80 cubic yards) would be excavated and disposed at a permitted facility. Proposed ACLs for DRO and RRO at 3 foot depth are 1260 and 22,000 mg/kg, respectively. Institutional controls would include a deed notice identifying PCB and DRO ACLs and preserving low occupancy status, and requiring perpetual maintenance of the fence. |
Scott Pexton |
| 11/20/2001 |
Meeting or Teleconference Held |
Meeting held at ADEC offices in Anchorage with Mrs. Hendrickson, Ralph Hulbert of AlaskChem Engineering, Jim Frechione, Scott Pexton and via teleconference, Dan Duncan and Ray Nye of EPA Region 10. Meeting focused on State regulatory process regarding alternative cleanup levels for PCBs. It was determined that a risk assessment under method 4 of 18 AAC 75.340 would be necessary to determine the acceptability of alternative cleanup levels greater than 10 mg/kg for PCBs in surface soil or greater than 25 mg/kg for PCBs in subsurface soil. |
Scott Pexton |
| 1/17/2002 |
Meeting or Teleconference Held |
Meeting held at ADEC offices in Anchorage with Mrs. Hendrickson, Ralph Hulbert of AlaskChem Engineering, Jim Frechione, Scott Pexton and via teleconference, Dan Duncan of EPA Region 10 and Stephanie Pingree of ADEC. Meeting focused on State regulatory process regarding alternative cleanup levels for PCBs using a risk assessment under method 4 of 18 AAC 75.340 A Generic PCB Risk Assessment of Commercial and Industrial Exposure guidance was distributed and discussed. The PCB soil cleanup levels calculated using the default parameters for the commercial/industrial land use scenario was 10 mg/kg. |
Scott Pexton |
| 2/27/2002 |
Update or Other Action |
ADEC received a copy of a letter from Department of Law indicating a check was received on behalf of ADEC for cost recovery (Bill #CO25255). |
Scott Pexton |
| 6/10/2002 |
Record of Decision |
Record of Decision signed. ADEC DECISIONS
PCBs: The applicable cleanup level for Total PCBs at the site is 10 mg/kg in surface soil and 25 mg/kg in subsurface soil with a condition to require an institutional control that restricts land use to commercial/industrial uses as defined at 18 AAC 75.990. However, PCB concentrations that exceed the cleanup levels may remain in place at the site if the cleanup is conducted in accordance with an approved plan under the cleanup operations requirements at 18 AAC 75.360 and if applicable institutional controls required under 18 AAC 75.375 are maintained.
Petroleum hydrocarbons: diesel range organics (DRO) and residual range organics (RRO)
The applicable alternative cleanup level for DRO is 504 mg/kg and the applicable alternative cleanup level for RRO is 21,900 mg/kg.
Lead: The applicable cleanup level for lead at this site is 1,000 mg/kg with a condition to require an institutional control that restricts land use to commercial/industrial uses as defined at 18 AAC 75.990. The maximum concentration of lead was 827 mg/kg, which meets the cleanup level. Therefore, lead is not considered a chemical of concern in soil provided the land use at the site remains commercial/industrial.
Arsenic, cadmium, and chromium:
Based on a review of background information in Southcentral Alaska, ADEC determined that chromium at this site is within background concentrations. There were a couple of samples of arsenic and one sample of cadmium that fall outside the range of background concentrations but ADEC does not consider these significant enough to require cleanup action at this time. However, ADEC will require groundwater sampling to determine whether cadmium exceeds applicable groundwater cleanup levels.
Groundwater Investigation Required:
ADEC has determined that 18 AAC 75.345 Table C cleanup levels are applicable at this site. Groundwater investigation is required for site characterization purposes in accordance with 18 AAC 75.335. A minimum of three groundwater monitoring wells must be installed on the property and groundwater samples collected and analyzed for PCBs, DRO, RRO, cadmium, and volatile organic compounds. A monitoring plan and schedule will be required as part of the site cleanup plan to ensure protection of human health and the environment.
Institutional Controls Required:
ADEC has determined that institutional controls in accordance with 18 AAC 75.375 will be required to ensure compliance with applicable cleanup levels and to protect human health and the environment. The institutional controls will include a notification that must be approved by ADEC and subsequently recorded in the State of Alaska Anchorage District Recording Office. The Notice of Environmental Contamination must indicate that land use on the property is restricted to commercial/industrial uses as defined at 18 AAC 75.990 and describe areas with known or potential contamination on the property. In addition, an entry into the ADEC Contaminated Sites Program's database will be made to indicate that an institutional control has been established to require prior approval by ADEC before moving or disposing of soil or groundwater from the site to another location.
Interim Removal Action Plan Requested:
ADEC has determined that an interim removal action is necessary to prevent human exposure to high levels of PCB concentrations in surface soil at the site. Surface soil areas with PCB concentrations greater than 50 mg/kg should be excavated for transport to an approved offsite treatment and disposal approved facility. Therefore, ADEC requests that the Prescott Equipment Company submit an interim removal action plan and a groundwater investigation plan for ADEC review and approval in accordance with 18 AAC 75.330 and 18 AAC 75.335.
In a March 15, 2002 letter, AlaskChem Engineering indicted that the owner is willing to attempt remediation of PCBs to 50 ppm, but lacks resources to clean up to 10 ppm. In an April 8, 2002 letter, AlaskChem Engineering suggested encapsulating PCB contamination between concentrations of 5 and 100 ppm into an onsite cell. AlaskChem Engineering has proposed excavation and removal of PCB soil contamination exceeding 100 ppm for transport to a regulated landfill and use of engineering controls to limit exposure to any remaining PCBs. ADEC does not conceptually object to this approach, but will limit any concentrations of total PCBs left on site in an engineered cell or cap to less than 50 mg/kg. ADEC shall seek public participation if this approach is proposed as the preferred final cleanup plan. |
Scott Pexton |
| 6/13/2002 |
Update or Other Action |
Received notification of receipt of cost recovery check (Bill #C025427). |
Scott Pexton |
| 10/15/2002 |
Update or Other Action |
In a letter dated 10/15/02, CSP notified Mrs. Henrickson and AlaskChem that it had no objection to AlaskChem implementing its "Prescott - Chipperfield Fall 2002 Workplan" dated 10/5/02. The plan had been received via e-mail on 10/5. The workplan proposed to investigate a sewer drain at the site, and cover 5 highly contaminated PCB areas at the site with plastic sheeting and place concrete over it for a "simple risk abatement" approach until a final remediation plan can be developed and implemented. The workplan also noted that it expected that AlaskChem would being excavation work in spring 2003, i.e., to address the June 2002 ROD decision for "interim removal action" at the site. CSP's 10/15 letter also noted that it expected a groundwater monitoring plan to be submitted to it per the ROD. |
Rich Sundet |
| 11/13/2002 |
Update or Other Action |
In a submittal dated 11/12/02 that was received by CSP on 11/13, AlasChem provided a report of the work performed in accordance to his workplan dated 10/5/02. The work focused on the investigation of a sewer line. The outlet of the drain line and around the sump showed some low levels of arsenic, cadmium, chromium, lead and petroleum. The report did show PCBs were detected at 198 mg/kg in sludge that was collected from the drainline and would be held until it could be disposed off site as a TCSA waste. The investigation had shown that the drain line ran just under a concrete slap on site and ended about 15 feet from the slab. The sludge with elevated PCB level was found plugging the drain line.
The report also contained SESOIL modeling results. According to the report, no groundwater impacts were predicted. |
Rich Sundet |
| 11/27/2002 |
Update or Other Action |
In a letter dated 11/27/02, Eileen Olson of CSP approved of AlaskChem's request to transport abt. 2 cubic yards of < 24 mg/kg mercury and 2 mg/kg PCB contaminated soil from Mrs. Hendrickson's 1924 Post Road contaminated site in Anchorage to her Prescott Equipment site at 427 Chipperfield Way site. The letter also noted that while DEC approves transport and storage to the Chipperfield site, DEC can at any time request that the contaminated soil be moved off that site and be adequately disposed of. The letter also requested a workplan for the transport and the storage of the soils at the Chipperfield site. |
Rich Sundet |
| 11/28/2002 |
Update or Other Action |
In a letter dated 11/28/02, Olson approved AlaskChem's 11/27/02 workplan proposing to transport the contaminated soil from 1924 Post Road to the Chipperfield site. The plan proposed to store the soil in supersacks with a waterproof covering within the fenced yard at the Chipperfield site. |
Rich Sundet |
| 3/4/2003 |
Meeting or Teleconference Held |
Sundet and Frechione met w/Hulbert to discuss Hulbert's conceptual cleanup plan for the site. Dan Duncan was on teleconference for the meeting. |
Rich Sundet |
| 3/12/2003 |
Meeting or Teleconference Held |
Sundet and Frechione met w/Hulbert, MaryJane Henrickson and her real estate agent Tim Spernak regarding a follow-up meeting from last week. On teleconference was Dan Duncan of EPA. As the result of the meeting, Hulbert proposed to encapsulate >10 ppm PCBs on site and use a combination of field screening and laboratory sampling for final confirmation sampling both what is left in the ground and what is to be placed into the cell on site. Hulbert proposed that >100 ppm PCBs will be transported off site for treatment/disposal at a TCSA landfill, between 10 adn 100 ppm PCBs be placed into a lined cell on site that will also be encapsulated in concrete, and soil remaining on site and accessible will be <10 ppm. DEC requested that groundwater be characterized because it has not yet been so characterized. Hulbert agreed to provide a workplan to DEC to address the groundwater concerns. The schedule outlined by Hulbert was that he would like approval of the work in May 03 so that cleanup work could commence in June and end by 10/1/03. He was not specific in when the groundwater work would be performed but DEC requested that it be done earlier than later so that if problems are detected in the groundwater, that further work could be performed soon without impacting the PCB cleanup. |
Rich Sundet |
| 3/19/2003 |
Update or Other Action |
CSP provided Dan Duncan of EPA comments via e-mail regarding his draft letter to Ralph Hulbert regarding his PCB comparison study between field test kits and laboratory analytical data that he performed at the site in 2000 and as reported AlaskChem's report "Interim Site Assessment Report Prescott Equipment Co." dated February 2001, and Hulbert's proposal to cleanup the site. |
Rich Sundet |
| 3/19/2003 |
Update or Other Action |
In a letter dated 3/19/03, EPA issued a letter to Hulbert in response to his 2/6 and 4/6/01 letters requesting the EPA to review his PCB Test Kit Validation Proposal and Interim Assessment Report for the Prescott Chipperfield site. EPA concurred with Hulbert's proposal in accordance with the self implementing PCB remediation reguations under 40 CFR 761.61(a)(3)(i)(E) and 761.320-.326.
EPA's letter also noted that they reviewed Hulbert's 4/6/01 Interim Assessment report and that AlaskChem Engineering will conduct verification analyses of 10% of the PCB remediation samples. The PCB remedation waste sampling will include both soil and concrete samples. The letter also requested that a remediation plan be submitted to EPA by 3/31/03. |
Rich Sundet |
| 3/21/2003 |
Update or Other Action |
CSP provided Dan Duncan of EPA comments in writing regarding his draft letter to Ralph Hulbert regarding his PCB comparison study between field test kits and laboratory analytical data that he performed at the site in 2000 and as reported AlaskChem's report "Interim Site Assessment Report Prescott Equipment Co." dated February 2001, and Hulbert's proposal to cleanup the site. |
Rich Sundet |
| 11/20/2003 |
Update or Other Action |
In a letter dated 11/20/03, the A.G.s Offices issued a letter to DEC notifying them that they received a check for $2,500.00 from Prescott Equipment Co. This check was part of Bill C040166 for $4,960.92 and Ms. Henrickson had requested (and was verbally granted by Kay Rawlings of the A.G.s Office) that payment occur in two parts. |
Rich Sundet |
| 12/4/2003 |
Update or Other Action |
In a letter dated 12/4/03, the A.G.s Offices issued a letter to DEC notifying them that they received a check for $2,460.92 from Prescott Equipment Co. This check was part of Bill C040166 for $4,960.92 and Ms. Henrickson had requested (and was granted) that payment occur in two parts. This payment was the second of the two part bill payment. |
Rich Sundet |
| 1/22/2004 |
Meeting or Teleconference Held |
Attended meeting at Andrew Behrend's office with Kennedy. Also attending was Ralph Hulbert. Focus of the meeting was basis for the proposed work whether driven by risk, finances, or combination. Result of the meeting was that the RP was not pursuing potential insurance and that DEC would continue the revised plan submitted by Hulbert in June 2003. |
Rich Sundet |
| 4/30/2004 |
Update or Other Action |
CSP provided a draft public notice of AlasChem's 6/4/03 revised workplan to representatives of Mrs. Henrickson. |
Rich Sundet |
| 5/6/2004 |
Meeting or Teleconference Held |
Sundet initiated a teleconference between Hulbert (AlaskChem) and Dan Duncan of EPA to discuss the draft public notice that was sent to the two parties by DEC last week. The notice would notice AlaskChem's 6/4/03 dated draft workplan to cleanup the site. The plan proposes to transport off site PCBs > 100 mg/kg, and place in a subsurface cell on site PCBs 1-100 mg/kg and petroleum up to 3,350 mg/kg DRO and 21,900 mg/kg RRO. |
Rich Sundet |
| 5/13/2004 |
Update or Other Action |
DEC public noticed AlaskChem's proposed revised workplan dated June 4, 2003 in the Anchorage Daily News on 5/14 and 16, 2004. The notice also referenced the reader to DEC CSP's webpage where it provided the workplan as well as AlaskChem's May 6, 2004 amendment to the plan that further explained the proposed design of the cell. |
Rich Sundet |
| 6/14/2004 |
Meeting or Teleconference Held |
At the request of the Mountain View Council, Sundet attended its monthly meeting on 6/14/04 and gave a brief presentation on the regulatory aspects of the proposed plan that was public noticed. In addition, Ralph Hulbert gave a presentation on the proposed plan on behalf of Prescott Equipment. |
Rich Sundet |
| 7/16/2004 |
Update or Other Action |
On 7/16/04, DEC issued a letter to Prescott Equipment conditionally approving AlaskChem revised workplan dated June 4, 2003 and its amendment dated May 6, 2004 clarify the design of the cell. The plan and amendment were public noticed on May 14 and 16, 2004. Conditions included a 33 foot setback from the property line with Mountain View Drive as it was extended based upon objection by the MOA of the proposed 15 foot setback; a groundwater monitoring plan be submitted by August 15, 2004 and implemented by August 30, 2004; an IC in the form of an equitable servitude be estabished for this property within 60 days of completion of cleanup or by 1/31/05 whichever comes first, the IC shall show that financial assurance approved by DEC has been posted to ensure that post-closure care is performed for 30 years; a final report be provided of the cleanup to DEC and EPA by 1/31/05; and advance notice given to DEC prior to field work on milestones such as installation of the monitoring wells. |
Rich Sundet |
| 8/4/2004 |
Update or Other Action |
In response to Behrend's 7/26/04 letter requesting DEC to reconsider several issues in its conditional approval letter of 7/16/04, DEC issued a letter dated 8/4/04 in response to Behrend's requests.
The 8/4/04 letter noted 1) that DEC re-evaluated Condition 1 on the 33 foot setback from the cell to Mt. View Drive and agreed that 15 feet appeared adequate 2) agreed to extend the deadlines that the groundwater monitoring plan need to be provided to DEC and did so extend it to September 15, 2004 and be implemented by October 30, 2004, the fall groundwater monitoring event be postposed to November 2004 if necessary, but that all other conditions applied and were not believed to be "unnecessarily extensive" as Behrend alledged. It also noted that the monitoring wells need to adequately address both the contamination that may have leached from the soil as well as from the cell 3) agreed to extend when the work would be completed and therefore extended the recording date for the IC and the final cleanup report needed to be provided to DEC to 1/31/04. The IC would need to be recorded w/in 60 days of completion of cleanup activities or by 1/31/05 whichever comes first 4) requested Prescott Equipment's consultant to re-evaluate their 5/22/03 letter on estimated costs for post-closure care because $5,000 appeared to be low for 30 yrs of monitoring/post-closure care work. DEC estimated $3,375 for just laboratory analysis of groundwater samples at a minimum of 5 sampling events over that time. |
Jim Frechione |
| 8/16/2004 |
Update or Other Action |
In response to AlaskChem's 8/10/04 letter and Behrend's email of 8/11/04, DEC responded to the comment why it could not "unconditionally" approve of AlaskChem's 6/4/03 workplan. CSP noted that groundwater monitoring needed to occur and disagreed with the scenario as proposed in the plan. It also noted that unlike what AlaskChem alleged, in that it could not implement the plan because it was not approved, DEC noted that the plan was conditionally approved by DEC on 7/16/04 and that Prescott Equipment just did not elect to initiate the plan because it contested all of the conditions in the 7/16/04 approval letter. DEC also noted in their 8/16/04 letter that the Attorney General's Office is more than willing to work with Prescott Equipment's counsel to develop a draft equitable servitude that will satisfactorily address issues such as financial assurance that post closure care will be adequately addressed, and which DEC considered AlaskChem's estimate of $5,000.00 for post-closure care to be low. |
Jim Frechione |
| 8/19/2004 |
Meeting or Teleconference Held |
On 8/19/04, a teleconference occurred between Frechione and Bainbridge of DEC with Hulbert. Focus of the meeting was on DEC's 8/16/04 response. |
Jim Frechione |
| 8/23/2004 |
Update or Other Action |
On 8/23/04, DEC issued a letter in followup to the 8/19/04 teleconference. The letter noted that DEC's has attempted to work with Mrs. Henrickson and her consultant on a cost effective approach to address the contamination while conforming with the regulations. The letter noted that if Mrs. Henrickson was still unsatisfied with the conditions in the 7/16/04 approval letter as amended on 8/4/04 that she could appeal the decision within 15 days in accordance to 18 AAC 15.185. |
Jim Frechione |
| 10/5/2004 |
Meeting or Teleconference Held |
On 10/5/04, Sundet met with Andrew Behrend and on t/c was Dan Duncan of EPA. The meeting was requested by Behrend to discuss Hulbert's 9/15/04 submittal to DEC in which he raised issues that his client Prescott was being held to more stringent cleanup requirements than the three sites (Standard Steel, Arctic Surplus, and M&M Hanson sites) referenced in DEC's 8/16/04 letter. Sundet and Duncan noted that the Standard Steel and Arctic Surplus sites could not be compared with the Prescott site because they were Superfund sites and TSCA regulations are viewed as ARARs in that situation. The M&M Hanson site can be compared and Duncan described the TSCA sampling requirements and while a bit less stingent than required at Prescott, it was because Hanson proposed discrete sampling vs composite at Prescott and that the cleanup level was 1 and 10 ppm PCBs vs <100 ppm at the Prescott site. Contrary to what was stated in the 9/15 submittal, groundwater monitoring was performed at all 3 referenced sites before cleanup commenced and is required for long term. At this time, groundwater has not yet been even characterized at Prescott. DEC and EPA are open to any proposed modification to the approved plan. In the agencies viewpoint, Prescott is being treated no more stingently than what was required at the M&M Hanson site. Based on the meeting, Behrend was going to discuss other options to address the contamination at the site with Mrs. Henrickson and Hulbert. |
Rich Sundet |
| 12/8/2004 |
Update or Other Action |
On 12/8/04, the Attorney General's office informed DEC that it received payment from Prescott Equipment for $3,225.71 for its 12/1/04 bill. |
Rich Sundet |
| 1/19/2005 |
Meeting or Teleconference Held |
On 1/19/05, Sundet, Dan Duncan of EPA, and Hulbert and Behrend held a teleconference to discuss the revised Nov. 18, 2004 revised AlaskChem "Amended Remediation Workplan" to cleanup the site. The section discussing the equitable servitude was postponed until next week to allow DOL to comment upon. |
Rich Sundet |
| 3/3/2005 |
Update or Other Action |
On 3/3/05, CSP provided comments to EPA regarding their draft letter approving AlaskChem's 1/24/05 revised workplan to remediate the site. |
Rich Sundet |
| 3/9/2005 |
Update or Other Action |
In a letter dated 3/9/05, EPA conditionally approved AlaskChem's 1/24/05 revised workplan to remediate the site which included that all PCBs in concentrations greater than25 ppm would be disposed/incinerated of in a TSCA permitted facility in accordance to 40 CFR 761.61. |
Rich Sundet |
| 5/20/2005 |
Update or Other Action |
On 5/20/05, Sundet emailed Hulbert three of the conditions that would be in the letter approving Hulbert's 1/24/05 revised workplan, specifically conditions with the implementation of the workplan. |
Rich Sundet |
| 5/23/2005 |
Cleanup Plan Approved |
On 5/23/05, DEC conditionally approved AlaskChem's 1/24/05 revised workplan to excavate contaminated soils and transport soils with >25 ppm PCBs off site, and place PCBs <25 ppm and petroleum contaminated soils and some metal contaminated soil into a cell onsite, and install two monitoring wells and sample those wells. |
Rich Sundet |
| 5/23/2005 |
Update or Other Action |
On 5/23/05, Hulbert faxed a response to DEC's 5/20 email and notified DEC that well drilling would be soon, removal of the soil would begin on 5/27/05 and construction of the cell has many phases but would notify when excavation began. |
Rich Sundet |
| 7/25/2005 |
Update or Other Action |
On 7/25/05, AlaskChem began excvating soil in accordance to their approved workplan. |
Rich Sundet |
| 8/1/2005 |
Update or Other Action |
On 8/1/05, DEC received via email a status report from AlaskChem that noted that they had:
- began installing 2 monitoring wells on 5/23/05,
-sampled the monitoring wells on 5/27 and detected carbon tetrachloride (81.6 ug/L) and TCE (51.8 ug/L) above Table C levels in the monitoring well installed on an upgradient portion of the property;
-began excavation on 7/25/05 with 2 tons of soil placed in supersacks that were above 25 mg/kg PCBs and skimmed soil off the surface of about 1/5 of the property to begin meeting the target cleanup level of 1 mg/kg PCBs. |
Rich Sundet |
| 5/18/2006 |
Update or Other Action |
On 5/18/06, EPA issued a letter to Hulbert notifying him that EPA had reviewed his AlaskChem Engineering December 2005 PCB Remediation Report and Appendices for the Chipperfield site and noted that it met the conditions outlined in their March 9, 2005 letter under 40 CFR 761.61(a). |
Rich Sundet |
| 6/6/2006 |
Update or Other Action |
On 6/6/06, DEC provided comments to Mary Jane Henrickson and Justin Green of Alaska Demolition regarding AlaskChem's "Remediation Report for 427 Chipperfield Drive Lot 30A Block 6, First Addition Alaska Industrial Sub." dated December 2005. DEC received the document on 1/24/06. The report describes work performed in 2005 including: the installation of two monitoring wells and twice sampling of those wells; excavation work performed; and, constuction of the cell on site where 2005 sampled petroleum contaminated soil up to 444 mg/kg DRO and 1,010 mg/kg RRO, and PCB composited contaminated soil up to 32.2 mg/kg was placed in the cell. The report also showed that 18 composited samples from 141 discrete samples identified up to 2.68 mg/kg PCBs remaining after excavation in the yard, and limited discrete samples analyzed for DRO and RRO showed up to 129 mg/kg DRO (7 samples) and 81.8 mg/kg RRO (3 samples) remained in the yard after excavation. The report noted that two previously unknown underground fuel tanks were discovered during the excavation and removed from site, and a layer of dense petroleum contaminated soil on the near surface 1-3 inches thick covered by 2-8 inches of gravel was identifed that covered about 80% of the site. |
Rich Sundet |
| 6/6/2006 |
Update or Other Action |
On 6/6/06, DEC provided written comments to Alaska Demolition and Prescott Equipment Co. regarding its review of AlaskChem Engineering’s (AlaskChem) report “Remediation Report for 427 Chipperfield Dr. Lot 30A Block 6, First Addition Alaska Industrial Sub.” dated 12/2005. DEC received the report on 1/17/2006. Earlier on 5/23/2005, DEC issued a conditional approval of AlaskChem’s “Amended Remediation Workplan for 427 Chipperfield Dr.” dated 1/24/2005 (hereinafter referred to as the workplan) to perform a cleanup. As noted below, DEC has several comments regarding the report. Earlier on 5/2/2006, Sundet had briefly discussed the report and several preliminary comments with Mr. Ralph Hulbert of AlaskChem and he subsequently provided DEC written response via e-mail on May 3rd to those questions/comments. The 6/6/06 comments are additional comments and/or follow-up to that earlier correspondence with Mr. Hulbert.
In summary, the cleanup actions removed about two cubic yards of PCB contaminated soil from one area at an average concentration of 29.6 mg/kg (apparently Node C15). This soil was transported off site to a Class D landfill in Oregon; while 2,000 cubic yards of soil contaminated with petroleum and PCBs was placed in a lined/covered cell on site. The composite samples collected from the on site soil cell in 2005 identified 32.2 mg/kg PCBs, 444 mg/kg DRO and 1,010 mg/kg RRO. The in situ soil (that soil on site remaining in the excavation and not in the cell) identified 2.68 mg/kg PCBs (18 composited samples from 141 discrete samples) and limited discrete samples measured 129 mg/kg DRO (7 samples) and 81.8 mg/kg RRO (3 samples).
DEC requested clarificaton on several issues including the petroleum layer that was detected when excavation occurred and the final cell construction and design.
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Rich Sundet |
| 6/23/2006 |
Update or Other Action |
In a letter to the AG's office dated 8/15/06 letter from Mrs. Mary Jane Henrickson, she informed the AG's office that she sold the subject site to Justin Green, DBA Alaska Demolition, in October 2005 and sent recent bills from the AGs to his office. |
Rich Sundet |
| 8/23/2006 |
Update or Other Action |
In a letter dated 8/23/06, the AGs informed DEC that Prescott Equipment had paid its bill of $3,762.11 for DEC's oversight expenses. In its letter, the AG's office included a 8/15/06 letter from Mrs. Mary Jane Henrickson that informed the State that she sold the subject site to Justin Green, DBA Alaska Demolition, in October 2005 and sent the recent bills to his office. |
Rich Sundet |
| 9/27/2006 |
Update or Other Action |
On 9/27/06, DEC provided commments to Alaska Demolition regarding its review of AlaskChem Engineering’s (AlaskChem) response “Chipperfield Site; Your 6/6/06 Request for Additional Information” dated July 10, 2006. The response was to our June 6th letter regarding AlaskChem’s “Remediation Report for 427 Chipperfield Dr. Lot 30A Block 6, First Addition Alaska Industrial Sub.” dated December 2005. DEC received the report on 1/17/2005. Earlier on 5/23/2005, DEC issued a conditional approval of AlaskChem’s “Amended Remediation Workplan for 427 Chipperfield Dr.” dated 1/24/2005 (hereinafter referred to as the workplan) to perform a cleanup. In addition, the 9/27 letter is in follow-up to a meeting that Sundet had with Mr. Mike Waddell of Alaska Demolition on September 21, 2006 to discuss the background of the site and what future actions need to be taken to reach a satisfactory resolution with this contaminated site.
As DEC informed Mr. Waddell, AlaskChem’s July response addressed a number of our comments or questions that we raised in our June letter. However, several comments were not fully addressed or information provided as requested. Therefore, the 9/27 letter reiterated several of these comments as well as providing several others. DEC requested a response to the comments and a workplan by 10/10/2006.
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Rich Sundet |
| 9/27/2006 |
Update or Other Action |
On 9/27/06, CSP provided comments to Alaska Demolitions regarding AlaskChem's 7/10/06 response and a meeting with Mike Waddell of that firm on 9/21/06. CSP noted that while many of the comments were addressed in AlaskChem's 7/10/06 submittal to CSP's 6/6/06 letter commenting upon AlaskChem's 12/2005 cleanup report, there were several outstanding issues remaining. One issue was that few confirmation samples were collected after a layer of petroleum was discovered below the surface of about 80% of the site. Another primary issue was that concrete slabs were not placed on top of the cell as the approved workplan specified to act as a protecting armor. DEC requested a workplan to further characterizate the site to address the petroleum issue and other information to address other comments raised. |
Rich Sundet |
| 6/17/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Rich Sundet |
| 9/24/2008 |
Update or Other Action |
On 9/24/08, DEC issued a reminder letter to Alaska Demolitions to submit a work plan and response to DEC's 9/27/06 comment letter on AlaskChem's cleanup report by 10/15/2008. |
Rich Sundet |
| 6/1/2009 |
Update or Other Action |
On 6/1/09, DEC issued a reminder letter to Alaska Demolition to submit a work plan and a response to DEC's 9/27/06 comment letter on AlaskChem's cleanup report by 6/22/2009. The reminder letter was in followup to DEC's 9/27/2006 and 9/24/08 letters, and conversations with Mike Waddell of Alaska Demolitions on 8/30/2007 and 5/28/2009 regarding this matter.
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Rich Sundet |
| 6/18/2009 |
Update or Other Action |
On 6/18/09, Matt Hemry called Sundet and notifed DEC that Alaska Demolitions had contracted S&W to address DEC's 6/1/09 letter to them, which referenced several earlier letters. As a result, Hemry noted that he would be reviewing DEC's file on the subject site. After that discussion, Hemry requested an extension to provide a response and work plan by one month from the deadline posed within DEC's 6/1/09 letter. DEC granted the extension request until July 31, 2009 via email. |
Rich Sundet |
| 10/1/2009 |
Site Characterization Workplan Approved |
On 10/1/09 after discussing the plan with Dan Duncan of EPA's TSCA program on 10/1/09, DEC issued a letter of non objection to Alaska Demolitions to implement their consultant Shannon & Wilson’s work plan titled “Draft Site Characterization Work Plan, 427 Chipperfield Driver, Anchorage, Alaska” dated August 23, 2009. The plan was submitted to DEC via e-mail on 8/28/2009 in response to several letters since 2006. On 6/6/2006, DEC had commented upon your consultant AlaskChem’s cleanup report and on 9/27/2006 provided comments on AlaskChem’s 7/10/2006 response.
The work plan outlines four tasks:
1) Perform a file review and conduct interviews with Mr. Ralph Hulbert of AlaskChem on the construction of the cell and other work performed during his cleanup including the disposition of the two supersacks of contaminated soil generated from the Prescott Equipment Post Road site (CSP File #2100.38.040);
2) Perform a preliminary site visit to evaluate the potential impact, if any, of apparent work plan variations on site development;
3) Perform site characterization of:
• The near surface soils to document petroleum concentrations remaining after the prior cleanup activities performed by AlaskChem and based upon their 2005 cleanup report;
• Recommended placement of a concrete cap over the buried cell of PCB and petroleum contaminated soil that was generated during AlaskChem’s 2005 activities, and a long-term inspection checklist would be created and provided to DEC;
• Provide, if possible and upon discussion with DEC, information on the screening specifications for the material placed to the liner material of the cell; and,
• Sample the two existing monitoring wells on site and discuss with DEC additional groundwater monitoring requirements.
4) Submit a report that summarizing the work activities/findings, a conceptual site model and completed laboratory checklists.
In its letter, DEC notifed Justin Green of Alaska Demolitions that it had no objection to him implementing the plan. However, every effort needs to occur to provide outstanding information on the cell per DEC's 9/27/2006 letter such as views of the cell and screening material (comments #3 and 4) and why the cell was placed closer than the 15 feet separation distance as noted in the work plan to the nearest property lines to the east and south (comment on first paragraph of page 5), and providing the complete laboratory analytical package for the September 23,2005 groundwater sampling event (comment #6).
In its letter, DEC also noted that it is unclear whether Alaska Demolitions are requesting in the work plan our approval to construct the concrete cap over the cell as described on page 6 or whether Alaska Demolitions wanted to with their consultant discuss this task with us. It would appear, however, that Alaska Demolitions/S&W may want to discuss this option with DEC prior to constructing the concrete cap to address the issue whether Alaska Demolitions need to perforate the cell lining to verify the screening material placed next to the cell’s liner material.
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Rich Sundet |
| 3/4/2011 |
Update or Other Action |
In followup to email correspondence with Jessica Busey of S&W on 3/4/11 who noted that S&W was not given authorization to implement its workplan “Draft Site Characterization Work Plan, 427 Chipperfield Driver, Anchorage, Alaska” dated August 23, 2009, on 3/4/11 DEC issued a letter to Justin Green requesting that S&W's workplan be implemented by 4/30/11. In addition, DEC requested that Justin Green also provide the field notes and address several other issues as identified in its 10/1/09 letter of non objection to implement the S&W 2009 draft plan. |
Rich Sundet |
| 10/20/2011 |
Meeting or Teleconference Held |
On 10/20/11, Sundet met with Mike Waddell of AK Demolitions and their consultant Dan McMahan of S&W to discuss S&W's report Site Characterization 467 West Chipperfield received at DEC on 10/13/11. Work included S&W meeting with Ralph Hulbert to discuss outstanding issues in DEC's 2006 letter; perfoming surface and groundwater sampling; and coordination with EPA and DEC. The report noted that little to no useful information was obtained from Hulbert to resolve outstanding issues; only two samples and that was for PCBs were above DEC's most stringent cleanup levels for DRO, BTEX, GRO, RRO and PCBs in soil; the two samples with an issue for PCBs showed 9.89 mg/kg and its duplicate showed 16.2 mg/kg, and the other sample showed 2.08 mg/kg; no detections of DRO, BTEX, GRO or PCBs was detected in the two monitoring wells on site. The outcome of the meeting was that S&W would submit another plan to address the area where the PCB sample at 9.89 mg/kg and above the 1.0 mg/kg PCBs threshold. |
Rich Sundet |
| 3/15/2012 |
Document, Report, or Work plan Review - other |
On 3/15/12 at the request of Mike Waddell, DEC issued a letter to Alaska Demolitions informing them that DEC was in its final review regarding their consultant Shannon & Wilson's “Site Characterization 467 West Chipperfield Dirve, Anchorage, Alaska” dated October 2011 and “Work Plan for Cleanup Activities, 467 West Chipperfield Drive, Anchorage, Alaska” dated November 15, 2011 for 427 Chipperfield Dr., Lot 30A, Block 6, First Addition Alaska Industrial Subdivision. DEC's letter noted that it had been in communication with EPA becasue the site contains PCBs and as such is regulated also by EPA (i.e., under EPA's Toxic Substance Control Act). DEC informed Alaska Demolition that it also shared a draft response letter of its review of the report and work plan with EPA and upon receiving comments from EPA, will finalize its letter.
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Rich Sundet |
| 4/5/2012 |
Update or Other Action |
On 4/5/2012, Dave Bartus of EPA in follow-up to a conversation with Dan McMahon of Shannon & Wilson on behalf of Alaska Demolitions, issued an email to McMahon that sumamrized its earlier 4/5 conversation. In that email, EPA noted that its review of S&W's “Work Plan for Cleanup Activities, 467 West Chipperfield Drive, Anchorage, Alaska” dated November 15, 2011 and information in its file reiterated that there were outstanding issues remaining after AlaskChem's cleanup and that AK Demolitions or S&W submit the plan to EPA that the work specified in the subject plan would be conducted as a self implementing cleanup under 40 CFR 761.61(a). In addition, EPA recommended that a discussion occur between EPA, DEC, and S&W to discuss the outstanding issues and ensure cleanup meets DEC and EPA requirements and as related to land use. Earlier, Sundet and discussed with Bartus and shared with him DEC's draft review of the work plan. |
Rich Sundet |
| 4/24/2012 |
Cleanup Plan Approved |
On 4/24/12, DEC conditionally approved of Shannon & Wilson's report “Site Characterization 467 West Chipperfield Drive, Anchorage, Alaska” dated October 2011 and conditionally approved its “Work Plan for Cleanup Activities, 467 West Chipperfield Dirve, Anchorage, Alaska” dated November 15, 2011. The report was received at DEC on 10/13/11 and a hard copy of the work plan was received at DEC on 12/5/11. A cleanup was performed by AlaskChem in 2005 and its report of that work resulted in letters by DEC on 6/6/06 and 9/27/06 requesting clarification of several issues. The 2005 AlaskChem report noted that for the most part, excavated PCB contaminated soil between 1.0 mg/kg to 25 mg/kg was placed into a containment cell on the property that showed PCBs up to at least 32.2 mg/kg (composite sample P106-7 consisting of 9 subsamples). Several outstanding issues resulted in the work performed by S&W in 2011. The subject S&W report documented a S&W meeting with your former consultant Ralph Hulbert of AlaskChem to discuss outstanding issues in DEC's 9/27/06 letter; performing surface and groundwater sampling; and coordination with EPA and DEC. The report noted that little to no useful information was obtained from Hulbert to resolve outstanding issues; of the 15 samples collected/analyzed (plus two duplicates), only two sample locations showed PCBs above DEC’s most stringent cleanup level of 1.0 mg/kg (at B2S and B10S, at 16.1 mg/kg and 2.08 mg/kg respectively); no soil samples analyzed for BTEX, GRO, DRO, or RRO were above their most stringent cleanup levels (migration to groundwater); no detections of DRO, BTEX, GRO or PCBs were detected in the two monitoring wells on site where groundwater was encountered at about 35.5 feet below ground surface (bgs). The report noted that Mr. Hulbert: was unable to provide any figures showing the entire length or width of the containment cell from the top or side views that he oversaw construction; had no records regarding the screened material placed next to the liner material within the subject containment cell; the two supersacks containing low levels of PCBs from the Prescott Equipment - Post Road site (Hazard ID# 2745) were placed in the south corner of the subject containment cell; and, was unable to provide the laboratory data package for groundwater samples that were collected on 9/23/05. The report also provided an up-to-date Conceptual Site Model (CSM). DEC's letter also noted that upon CS's initial review of the subject report, Mr. Mike Waddell of Alaska Demolition and Mr. Dan McMahon of S&W met with Sundet on 10/20/11 to discuss CS's initial review of the report and next steps to address several issues that remained outstanding from DEC’s 9/27/06 letter.The outcome of the meeting was that S&W would submit another plan to address the area where the PCB sample was detected at B2S, sample the two groundwater monitoring wells for volatile organic compounds, and submit a report of that work. DEC's 4/24 letter also noted that during the 10/20 meeting that further investigation would occur regarding options to dispose of soil generated in the area of B2S but possibly in the area of the existing cell dependent upon analytical findings that showed that PCBs were less than 10 mg/kg; in addition, a cap over the cell in the form of an asphalt cap would be placed over the cell in spring 2012. Lastly DEC's 4/24 letter noted that EPA has recommended that Alaska Demolitions provide a notice of self-implementing cleanup pursuant to 40 CFR 761.61(a) for the existing excavation work plan and EPA will be sending you an outline of issues that need to be resolved under TSCA regarding the existing disposal cell, final cover, and related issues. |
Rich Sundet |
| 4/24/2012 |
Update or Other Action |
On 4/24/12, Dave Bartus of EPA provided comments via e-mail to Alaska Demolitons and Shannon & Wilson. on various issues outstanding of the site and outlined a path to move forward to comply with TSCA regulations. EPA noted that based on information available to EPA, it appeared that the facility did not satisfactorily fulfill the requirements of the existing self-implementing cleanup as approved by EPA. Further, it is not clear whether or not it makes sense, or if is technically practicable, to satisfy such requirements at this time. Therefore, EPA proposes to revisit the existing cleanup, and reach agreement on a set of technical and regulatory requirements which will provide a defensible basis for demonstrating compliance with applicable EPA and ADEC requirements, and which are consistent with how the property can reasonably be expected to be used. EPA anticipates that resolution of outstanding issues will be in the form of a risk-based disposal approval pursuant to 40 Code of Federal Regulations (C.F.R.) § 761.61(c). EPA also suggested in its email that it would like to initiate a discussion with the facility owners, their consultant, and ADEC to reach agreement on a framework to complete cleanup at this site. EPA’s sense is it may be appropriate to revise the existing self-implementing cleanup as a TSCA/PCB risk-based cleanup that would allow a more flexible approach that better reflects current site conditions, ADEC cleanup program requirements, and TSCA/PCB cleanup requirements. In addition, EPA suggests that these discussions consider issues raised by ADEC in their April 24, 2012 letter to Alaska Demolition, including the requested plan for a final cover over soils remaining on-site to ensure full integration of requirements under ADEC and EPA authority.
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Rich Sundet |
| 5/10/2012 |
Meeting or Teleconference Held |
In follow-up to Dave Bartus of EPA's 4/24/12 email to Alaska Demolitions (AK Demo) and Shannon & Wilson, a meeting was held on 5/10/12 between Mike Waddell of AK Demo, Dan McMahon of S&W, Sundet of DEC and Bartus who was on teleconference. Discussion focused on TSCA regulations and how AK Demo would satisfactorily fulfill the requirements of the existing self-implementing cleanup as previously approved by EPA or risk based cleanup standards, and meet DEC requirements and agency concerns. Concerns discussed how AK Demo would satisfactorily cap the cell, fence and provide signage, and ensure that these engineering controls are maintained and inspected to ensure the public, workers and current/future operators/owners are protected. As noted in DEC's 4/24/12 letter, Waddell stated that he would provide a plan to the agencies to cap the cell by 5/28/12. In addition, Bartus requested that a letter be sent that was a modification of AK Demo's 5/3/12 letter to clarify that the 11/15/11 workplan was to certify that the work would be done in accordance to TSCA's self implementing regulations under 40 CFR Part 761.61(a)(3)(D) and which McGahon stated that he would address this request. |
Rich Sundet |
| 6/28/2012 |
Cleanup Plan Approved |
On 6/28/12, DEC and EPA approved of Shannon & Wilson's plan “467 West Chipperfield Drive, Anchorage, Alaska Capping of PCB Disposal Site” dated May 21, 2012. The plan was in follow-up to a May 10, 2012 meeting with Mike Waddell of your firm, Rich Sundet and (via teleconference) Dave Bartus of the Environmental Protection Agency, and the resultant plan that we requested at that meeting to address the site and buried cell on the property. The subject May 21, 2012 plan was received at this office on May 23rd at which time Sundet forwarded it to Mr. Bartus. The plan states that Alaska Demolition proposes to construct a two inch thick asphalt cap over the entirety of the cell and it will extend from the chain-link fence to five (5) feet beyond the cell boundaries. In addition, the plan proposes that you will inspect the pad annually, and to document the inspections with photographs and a written report. Waddell's letter also noted that Alaska Demolistion could submit the report annually or keep it available for future inspections by DEC and/or EPA.While the agencies have no objection to your implementing annual inspections and documentation of those inspections at this time, these are institutional controls and the agencies will impose such ICs on the property at a later date. As Sundet discussed with Mr. Waddell, DEC have not issued the mechanism which establishes the ICs but had developed in coordination with the former owner’s (Prescott Equipment) counsel a notice for the ICs in the form of an equitable servitude (ES) to be placed on the property. While the mechanism may change from an ES to a deed notice, some such type of notice will be placed on the property and the exact ICs may be somewhat different than those within the draft ES. DEC noted that in essence, the agencies are reserving the right to include further ICs on the property than what is inferred in your letter, i.e., annual inspections, or may require some modification.
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Rich Sundet |
| 8/27/2012 |
Meeting or Teleconference Held |
On 8/27/12, Sundet met with Mike Waddell of AK Demolitions and their consultant Dan McMahon of S&Wilson with Dave Bartus of EPA on teleconference. During the meeting, Dan provided draft data from their 8/8/12 sampling effort which was done in accordance to their approved 11/15/11 workplan. Data showed elevated levels of PCBs in the two areas after excavation that were subject of the plan. Remaining PCBs was up to 2.08 mg/kg in the former location of B10S1 and up to 12.7 mg/kg PCBs in the former area B2. Sundet requested further delineation in these areas. A brief workplan will be submitted to DEC for both areas. |
Rich Sundet |
| 9/4/2012 |
Cleanup Plan Approved |
On 9/4/12, DEC in coordination with EPA, conditionally approved of S&W's "Work Plan Addendum, 467 West Chipperfield Drive, Anchorage, Alaska Capping of PCB Disposal Site" dated 8/30/12. The plan was in followup to a meeting on 8/27/12 between Sundet, Mike Waddell of AK Demolitions and their consultant Dan McMahon of S&Wilson with Dave Bartus of EPA on teleconference. The proposed plan would perform further excavation/characterization around Boring B2 and surface sample B10S1, sample the two monitoring wells for VOCs, and advance 10 test pits to better delineate the contamination around B2. |
Rich Sundet |
| 2/12/2013 |
Meeting or Teleconference Held |
On 2/12/13, Sundet met with Mike Waddell of Alaska Demolitions and their consultant Dan McMahon of S&W along with Dave Bartus of EPA on phone. The conversation focused on S&W's 1/23/13 report "Additional Cleanup Action and Site Characterization Activities, 467 West Chipperfield Drive, Anchorage, Alaska" which was received at DEC on 1/25/13. As a result of the meeting, S&W will prepare and submit another work plan to address 1) the removal of PCB contamination > 1.0 mg/kg from around EX2; 2) capping the existing cell on the property with asphalt and describe the signage and fencing for the facility 3) a plan for annual inspection of the property by a qualified third party and 4) address the two monitoring wells on the property. Waddell requested at the meeting whether the two monitoring wells could be decommissioned.
The document reported characterization and excavation activities performed in August and October 2012 in accordance to S&W's work plans dated 11/15/2011 and 8/30/2012. The report noted that August 8th work removed about 1.75 cy (3.5 cy total) of PCB contaminated soil in each of the two areas of Boring B2 (Excavation EX2)and B10S1 (Excavation EX10). Samples collected at EX2 included two samples with PCBs > 1.0 mg/kg, i.e., at 2.68 mg/kg and 12.7 mg/kg. A sample collected at EX10 contained 2.08 mg/kg. On October 4 about 1.5 cy of PCB contamianted soil was further removed around EX10 and all three confirmation samples were less than 1.0 mg/kg PCBs, a maximum detection of 0.0651 mg/kg. In addition, in October 10 test pits were advanced to delineate the area around EX2 to 2.5 ft. bgs and a one (1) inch layer of stained soil was observed in five of the test pits from 0.7 to 1.5 ft. bgs composing of about 1,320 square feet. Analysis of the oily stained layer in October showed little petroleum contamiatnion, a maximum of 19.9 mg/kg J DRO and 69.7 mg/kg RRO. In addition, samples were collected/analyzed from the two monitoring wells on the proeprty for VOCs and MW CMW-1 showed no detectable concentrations of VOCs while MW CMW-2 showed TCE at 0.0127 mgL and carbon tetrachloride at 0.0207, both of which exceeded their Table C cleanup levels of 0.005 mg/L. The report noted that S&W's earlier July 2011 groundwater sampling at both monitoring wells showed no detections for GRO, DRO, BTEX or PCBs. |
Rich Sundet |
| 5/8/2013 |
Cleanup Plan Approved |
On 5/8/2013, DEC provided comments regarding Shannon & Wilson's report "Additional Cleanup Action and Site Characterization Activities, 467 West Chipperfield Drive, Anchorage, Alaska" dated January 23, 2013 and their "Site Cleanup Work Plan Addendum, 467 West Chipperfield Drive, Anchorage Alaska" dated March 4, 2013. DEC's letter also incorporated comments regarding a meeting Sundet had on February 12, 2013 with Mr. Mike Waddell of AK Demolitions and Mr. Dan McMahon of S&W along with Mr. Dave Bartus of the EPA. As a result of that meeting, the March 4th dated work plan addendum was submitted to DEC via e-mail on 3/26/2013.
The S&W January report noted two excavations occurred in August and another in October 2012: on August 8, 2012 two excavations were performed at EX2 centering upon former boring B2 and at EX10 centering upon former surface soil sample B10SS1. Three test pits were excavated around EX2 to assist in the delineation of the contamination. At both of these former locations, confirmation samples showed that PCBs remained above 1.0 mg/kg (up to 2.08 mg/kg at EX10 and up to 12.7 mg/kg at EX2 – Test Pit 2). A 1-2 inch layer of visibly stained soil was also observed at EX2 about 10 inches below ground surface (bgs).
On 10/4/2012, the excavation at EX10 was expanded to include an additional ten test pits (TP4-TP13). Stained soil was again observed in test pits TP4, TP5, TP6, TP9 and TP12 from 0.7 to 1.5 ft. bgs. and was estimated at covering about 1,320 square ft. along the northeast side of the building on site. Depth of the test pits ranged from 0.8 ft. to 2.5 ft. bgs. Analytical samples were collected from TP4, TP5 and TP12 and those samples showed PCBs less than 1.0 (up to 0.94 mg/kg at TP4), and low levels of DRO and RRO in the stained layer (up to 19.9 mg/kg DRO and 69.7 mg/kg RRO both at TP4).
During the August and October excavation work, about 1.75 cy of contaminated soil was removed from EX2 and about 3.25 cy of contaminated soil was removed from EX10, of which were placed in supersacks and were stored on the property.
In addition, the two on site monitoring wells were sampled on August 8, 2012 for VOCs along with one duplicate sample. CMW-1 did not contain any detectable VOCs. CMW-2 showed exceedances to 18 AAC 75.345 for trichloroethylene (0.0127 mg/L) and carbon tetrachloride (0.0207 mg/L). The report noted that earlier sampling in July 2011 did not contain detectable PCBs, GRO, DRO or BTEX constituents.
Site Cleanup Work Plan Addendum, 467 West Chipperfield Drive, Anchorage Alaska dated March 4, 2013
The work plan addendum was submitted to address the findings from the work reported in the January 2013 subject report and as an outcome of discussion in the February 12, 2013 meeting.
The proposed work includes an excavation 4 ft. square by 2.5 ft. deep northwest of EX2 and another excavation of the same volume centering on TP2 in accordance to S&W’s November 15, 2011 work plan and in accordance with 40 CFR 761 Subpart O regulations. On May 8, 2013, Mr. McMahon clarified that using this criteria that S&W will collect three samples for laboratory analysis from each excavation – one from each base and two from sidewalls from each excavation.
The plan also noted that the excavated soil will be placed in supersacks and stored on site pending future off site disposal along with the previously generated soil (i.e., from the August and October 2012 cleanup activities) at a permitted facility.
In the 5/8/13 letter, DEC also ocnditionally approved of S&W's "Site Cleanup Work Plan Addendum, 467 West Chipperfield Drive, Anchorage Alaska" dated 3/4/2013. The work plan addendum was submitted to address the findings from the work reported in the January 2013 subject report and as an outcome of discussion in the February 12, 2013 meeting.
The proposed work includes an excavation 4 ft. square by 2.5 ft. deep northwest of EX2 and another excavation of the same volume centering on TP2 in accordance to S&W’s November 15, 2011 work plan and in accordance with 40 CFR 761 Subpart O regulations. On May 8, 2013, Mr. McMahon clarified that using this criteria that S&W will collect three samples for laboratory analysis from each excavation – one from each base and two from sidewalls from each excavation.
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Rich Sundet |
| 5/31/2013 |
Cleanup Plan Approved |
On 5/31/13, DEC approved Dan McMahon of S&W's 5/29/13 request via e-mail to expand the work under the work plan previously approved by ADEC on 5/8/13 to address findings from S&W's recent work. That work at Excavation EX4 in Test Pit TP2 showed 2.08 mg/kg PCBs. S&W's request was to expand and over excavate the sidewall that contained the elevated PCBs in accordance to its previously approved plan. |
Rich Sundet |
| 10/1/2013 |
Update or Other Action |
Email from Dave Bartus of EPA that they have no objection to paving. |
Robert Weimer |
| 10/4/2013 |
Document, Report, or Work plan Review - other |
DEC approves transport and disposal at Waste Management's Columbia Ridge facility in Oregon of 13 supersacks of PCB contaminated soil generated during the recent cleanup work. They will provide receipts. |
Robert Weimer |
| 11/18/2013 |
Meeting or Teleconference Held |
On 11/18/13, Weimer met with Mike Waddell of Alaska Demolitions and their consultant Dan McMahon and Matt Hemry of S&W along with Dave Bartus of EPA on phone to discuss what work is needed for closure of this site and with the some of the IC's would be. Dave said that EPA hopes to conduct their review by January 2014. We discussed that the proposed signs with DEC as the point of contact was fine. Dave said that EPA usually defers to DEC for cleanup levels for soils outside of the cell. We discussed that based on the available data there is not an off property source for the TCE and Carbon Tetrachloride in the groundwater at the site. They will survey in the two monitoring wells on the property with a nearby monitoring well at the property to the north to get a more accurate groundwater flow direction for the site, then they will provided a work plan for installing additional monitoring wells and soil borings to define the nature and extent of the TCE and Carbon Tetrachloride contamination. We also discussed that long term groundwater monitoring at the site and for the cell will be required. The monitoring wells can be installed flush mounted in trafficed areas. Shannon and Wilson will provide a copy of the most recent report and DEC will send them an electronic copy of the most recent groundwater monitoring report for the site to the north (2774 Rampart Drive). |
Robert Weimer |
| 6/4/2014 |
Document, Report, or Work plan Review - other |
The May 2, 2014 work plan for additional site characterization proposes to collect soil samples from two soil borings, complete them as long term monitoring wells, and collect groundwater samples from the four site monitoring wells. The work plan is approved under the following conditions:
1. The treatment and/or disposal of investigation derived waste are to be submitted on a separate request along with analytical results and field notes/summary report.
2. Complete copies of field notes will be submitted with the summary report.
3. DEC is to be notified 72 hours prior to conducting work it is to be conducted on a Sunday or Monday, 48 hours prior if the site work is to begin on another day of the week.
4. The soil and groundwater analytical samples are to report the full 8260B list of analyses, not just BTEX, TCE, and carbon tetrachloride.
5. Analytical soil samples are to be collected at the soil/water interface in addition to the highest field reading depth if the highest field reading depth is different than the soil/water interface.
6. The collection of the soil and groundwater samples is to be conducted in accordance with the DEC May 2010 Draft Field Sampling Guidance.
7. Analytical soil samples are to be collected with minimal disturbance and transferred to the sample jar immediately (within 10 seconds) upon opening the split spoon sampler. Methanol field preservation needs to be added to the sample jar immediately (within 10 seconds) upon placing soil in the sample jar.
8. The field notes and the summary report need to document that the ground water samples were collected a close as possible to the soil/water interface in that monitoring well at the time of the sampling.
9. Additional soil borings and/or monitoring wells may be required to characterize the nature and extent of the solvent soil and groundwater contamination at this site.
|
Robert Weimer |
| 3/15/2017 |
Document, Report, or Work plan Review - other |
Additional Site Characterization dated August 2014 reviewed on this date. The site characterization describes the sampling and advancement of two borings that were then completed as monitoring wells on June 16, 2014: Boring 3 (B3) completed to monitoring well 3 (MW-3); and Boring 4 (B4) completed to monitoring well 4 (MW-4). Sampling of previously completed wells CMW-1 and CMW-2 were also completed on June 16, 2014. Carbon tetrachloride was detected above ADEC cleanup levels for soil at .0289 mg/Kg at 30.5-31.5 bgs and .0368 mg/Kg at 35-35.5 bgs in B3; while carbon tetrachloride was detected at .0693 mg/Kg at 32.5-33 feet bgs in B4. TCE was detected above ADEC cleanup levels for soil at .0845 mg/Kg at 32.5-33 feet bgs. Carbon tetrachloride was detected above ADEC cleanup levels for groundwater in CMW-2 (.0453 mg/L) and MW-4 (.101 mg/L). TCE was detected above cleanup levels in CMW-2 (.0269 mg/L) and MW-4 (.102 mg/L). It should be noted that groundwater flow direction was east/northeast indicating groundwater flow direction is not uniformly consistent across the site. Impacted drill cuttings are purge water are stored on site in 55 gallon drums awaiting disposal to an appropriate facility. |
Lisa Griswold |
| 5/11/2017 |
Update or Other Action |
Site transferred to Rodman |
Lisa Griswold |
| 5/15/2018 |
Workplan Requested |
Work plan request letter and site summary mailed to RP. Also attached is March 2017 "Additional Site Characterization" report approval letter from ADEC. Work plan due June 30, 2018. |
Amy Rodman |
| 2/1/2019 |
Meeting or Teleconference Held |
Teleconference between ADEC and legal counsel for prospective purchaser of site to discuss possibility of Prospective Purchaser Agreement. |
Amy Rodman |
| 5/22/2019 |
Workplan Requested |
Work plan request letter mailed and emailed to RP. Work plan due June 30, 2019. |
Amy Rodman |
| 12/20/2020 |
Update or Other Action |
J. Fix assigned as new project manager. |
Julie Fix |
