Site Report: Nikolski RRS OT010

Site Name:	Nikolski RRS OT010
Address:	High Hill, Nikolski, AK 99638
File Number:	2621.38.004
Hazard ID:	4354
Status:	Active
Staff:	Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude:	52.971667
Longitude:	-168.855000
Horizontal Datum:	NAD83

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

Two analytes were detected at concentrations above reglatory limits, arsenic and polychlorinated biphenyls (PCBs). The arsenic is believed to be background. PCBs were detected at 14.1 mg/kg and estimated at 70 cubic yards in volume. The remedial investigation recommendation is to remove or remediate the PCB-contaminated soil. Note that the site was originally investigated as OT001 but because it is on a lower plateau and separated from the area of the main composite building it was separated for reporting in the Remedial Investigation.

Action Information

Action Date	Action	Description	DEC Staff
8/1/2002	Update or Other Action	While not listed on the NPL, the Air Force must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality].	Louis Howard
8/2/2002	Update or Other Action	Air Force Statement of Objectives (SOO) for a performance based contract. The purpose of the project is to complete remedy selection and implementation at 11 contaminated sites, and conduct demolition and debris removal at, and in the vicinity of, the former Air Force (AF) Nikolski Radio Relay Station, located near Nikolski, Alaska. Work shall include removal of unsafe buildings and other structures. The property shall be rendered suitable for future use by preventing exposure to contamination that may result in unacceptable risk to human health and the environment. Remedies shall achieve the required cleanup levels at each site identified herein, as required by the applicable state and federal law. The Contractor shall submit a Proposed Plan(s) that meets the requirements of the Draft Proposed Plan Checklist dated 07 Feb 2005 posted on the AFCEE web site. The plan describing remedy alternatives shall be submitted for Air Force Headquarters review prior to submittal to the ADEC. The Contractor is required to coordinate with the AF early in the process to ensure all requirements for formats and inclusions are met. Approximately 6-9 months will be required for Air Force Headquarters coordination, review, and signature approval. Per the Air Force policy letter, dated 12 March 2004, posted on the AFCEE website, a Decision Document/Record of Decision (ROD) describing the selected remedy shall be submitted for Air Force Headquarters review prior to submittal to the Alaska Department of Environmental Conservation (ADEC). The Contractor is required to coordinate with the AF early in the process to ensure all requirements for formats and inclusions are met. Approximately 6-9 months will be required for Air Force Headquarters coordination, review, and signature approval. The document shall conform to the Draft Checklist for Records of Decision, dated 07 Feb 2005 located on the AFCEE website.	Louis Howard
3/4/2003	Document, Report, or Work plan Review - other	Staff commented on the Nikolski Radio Relay Station, Approval of Feasibility Study for Sites, LF-001, AOC-01, SS-002, SS-005, SS-006, AOC-08, AOC-09, and OT-010 The Alaska Department of Environmental Conservation (DEC) received your response to our comments of October 14, 2002 on February 21, 2003. The response to comments has met the requirements of 18 AAC 75.335(c)(5) for the above listed nine of the thirteen sites investigated. The cleanup methods proposed in the document have been reviewed by DEC but will need to be presented for public review and comment before they can be approved. The Risk Assessment that is proposed for sites OT-001, SS-003, SS-004 and WP-007 should follow the guidance found in the Risk Assessment Procedures Manual, June 2002 and User's Guide for Selection and Application of Default Assessment Endpoints and Indicator Species in Alaskan Ecoregions, June 1999.	Debra Caillouet
3/17/2004	Document, Report, or Work plan Review - other	Your letter of 25 February 2004, Air Force Response to Comment, Nikolski RRS, Baseline Risk Assessment The response has been reviewed by the risk assessor and me. Overall the response to ADEC comments was well-done and the proposed changes are acceptable. In regards to the response to Lindsay Smith's Comment 5 about calculating cumulative risk, it is acceptable to treat sediment and soil as well as fresh and marine water separately. However the potential cumulative risk to a future resident should be presented as the sum of risks from groundwater and soil. In addition to the previous comments submitted, the clean up level calculated for DRO at the POL tank area (section 6.1.2.2) needs to be addressed. ADEC’s Clean Up Level Guidance and the Guidance for Clean up of Petroleum Contaminated Sites only specify site specific soil conditions that can be modified to develop alternative clean up levels. Dividing the calculated ACL by 40% is not a justifiable method for dealing with the different sorption capabilities of the aromatic and aliphatic portion of DRO. The clean up level will have to be modified before the Risk Assessment can be accepted. It should be the number that was originally calculated in the Remedial Investigation, Appendix K, including both fractions, i.e. 1190 mg/kg.	Debra Caillouet
12/16/2004	Document, Report, or Work plan Review - other	Staff provided comments on the draft PP for AOC-01 dam and pump house foundation, SS-002 former water supply house and aboveground storage tank, SS-005 runway lighting vault building and underground storage tank, SS-006 former drum storage area, AOC-07 construction camp septic tank, AOC-08 composite building septic tank and outfall, AOC-09 two 20,000 gallon underground storage tanks, OT-010 former transfer building and White Alice Arrays. Page 18, OT-010 - Former Transformer Building and Associated White Alice Arrays: Please include in the description of the preferred alternative the source of the cleanup levels. The second sentence in the preferred alternative section should read, "… would prevent exposure to soils containing…"	Louis Howard
5/29/2006	Document, Report, or Work plan Review - other	Staff provided comments regarding State of AK requirements for Proposed Plans and site specific comments. OT-010 Former Transformer Building and Associated White Alice Arrays – Soil contaminated with PCBs above 1 mg/kg will be excavated and treated off-site.	Debra Caillouet
6/30/2006	Document, Report, or Work plan Review - other	Your letters on the Technical Approach for Re-Evaluation of Human Health Risk for SS004, POL Tank Area, Nikolski Radio Relay Station (RRS), dated June 1 & June 28, 2006 The Alaska Department of Environmental Conservation (DEC) received the letters referenced above & met with you on June 261h to discuss the issues. The first letter outlines an Air Force proposal to re-evaluate potential risks posed by petroleum contamination at former fuel tank site using a revised, limited future land use scenario & cites the basis for redoing the risk assessment as a October 2004 Air Force land disposal policy. That policy, which was issued after the Nikolski RRS Baseline Risk Assessment had been completed in June 2004, states, "prior to risk assessment, the future resource use should be assumed, to the extent consistent with applicable law, to be the same category of resource use while the property was part of an active installation." Alaska's oil & hazardous substance cleanup regulations (18 AAC 75, Article 3 - site cleanup rules) define cleanup procedures, levels & associated requirements. Site specific alternative risk-based cleanup levels may be approved. 18 AAC 75.340(f) defines requirements for alternative cleanup levels based on risk assessments, including: (1) the need to follow the department's Risk Assessments Procedures Manual (RAPM), & (2) the responsible party obtaining "the consent of each landowner who is affected by the contamination at the site that a cleanup level less stringent than a cleanup level appropriate to residential land use is appropriate for the site". Section 3.2.2.1, Land Uses, in the RAPM requires reasonably anticipated future land use scenarios be identified in the work plan. Estimating future exposure requires assumptions about how the site & surrounding land will be used in the future. It is one of the most important steps in the exposure assessment because assumptions about the future use of land are a major determinant in calculating risk-based cleanup levels. For alternative cleanup level determinations, assumed limitations on future land use require ADEC concurrence. As discussed during our June 26th meeting & documented during completion of the existing baseline risk assessment for the site, land at SS04 is suitable for residential development. Congress passed legislation requiring the Air Force to cleanup the property & transfer it to the local village corporation. Thus, the corporation is a landowner affected by contamination at the site & according to Alaska law the Air Force must obtain concurrence from the corporation that cleanup to levels less protective than would allow for residential use is required before the DEC could approve such alternative cleanup levels. Additionally, if the affected land owners consent to limitations on future land use, the Air Force, as the responsible party for cleanup, must develop appropriate institutional controls that would restrict future land use to those scenarios for which the cleanup is protective. See 18 AAC 75.340(d) & 18 AAC 75.375. To date, the Air Force has not provided any information to demonstrate how it would establish such controls. See site file for additional information.	Debra Caillouet
11/20/2006	Document, Report, or Work plan Review - other	Your letter Technical Approach for Evaluation of Human Health Risk for SS004, POL Tank Area, Nikolski Radio Relay Station (RRS), dated 2 November 2006 The Alaska Department of Environmental Conservation (DEC) received the letter referenced above on November 14, 2006. The letter outlines an Air Force rationale for proceeding with a risk assessment using a revised, limited future land use. It also states that the Air Force acknowledges that ownership of the land might not be conveyed if limitations on land use are established. While your letter only asks that DEC provide a response that the Air Force will not be expected to obtain consent of the corporations for a site-specific risk assessment that does not protect residential use, DEC would like to point out that there are specific procedures that must be followed for a risk assessment to be approved. In the Risk Assessment Procedures Manual (adopted by regulation) in Section 1.3, Risk Assessment Requirements, DEC's risk assessment procedures include, at a minimum, the steps in the ADEC Risk Assessment Checklist and Scoping Meeting Checklist. Your letter does not relieve the Air Force of the responsibility of complying with the requirements of 18 AAC 75 or specifically the requirements of the Risk Assessments Procedures Manual. Until the Air Force complies with requirements in the Risk Assessment Procedures Manual, DEC will not issue any determination on the applicability or acceptability of a revised risk assessment. Please contact me at 907-269-0298 and our risk assessor, Marty Brewer at 269-3084 to set up a Risk Assessment Scoping Meeting.	Debra Caillouet
2/16/2007	Site Added to Database	Site added to the database.	Mitzi Read
2/20/2007	Document, Report, or Work plan Review - other	Staff provided comments on the draft proposed plans for six sites at Nikolski RRS. General Comment 1) All of the draft Proposed Plans state the U.S. Environmental Protection Agency has not provided comment on the recent studies or the Proposed Plan and also include a section indicating that the EPA issued a No Further Remedial Action Planned determination in 1994. DEC is unaware of the submittal of any documents to EPA for review since the NFRAP decision was issued. Please revise as necessary to be consistent with actions. Comment on Draft Proposed Plan SSOlO Former Transformer Building and Associated White Alice Arrays 12) DEC does not concur with the proposed "no action required" status for this site. Establishing and enforcing institutional controls and conducting Five Year reviews are actions that are required to prevent exposure to contamination.	Debra Caillouet
3/9/2007	Exposure Tracking Model Ranking		Debra Caillouet
3/9/2007	Document, Report, or Work plan Review - other	On behalf of the Alaska Department of Environmental Conservation the attached pages provide the department's comments on the Proposed Plans for: Site WP007, Composite Building Outfall, Site OT001 Former Composite Building and White Alice Arrays, Site ST017 Construction Camp Septic Tank, Site SS010 Former Transformer Buildings and Associated White Alice Arrays, and request for a public meeting at a time other than the one included in the Proposed Plans. Proposed Plan for Site WP007, Composite Building Outfall 1 The Proposed Plan does not present the remedial alternatives that were analyzed for the site. a. The National Contingency Plan in 40 CFR 300.430 (f) (2) states: The proposed plan. In the first step in the remedy selection process, the lead agency shall identify the alternative that best meets the requirements in Sec. 300.430(f)(1), above, and shall present that alternative to the public in a proposed plan. The lead agency, in conjunction with the support agency and consistent with Sec. 300.515(e), shall prepare a proposed plan that briefly describes the remedial alternatives analyzed by the lead agency, proposes a preferred remedial action alternative, and summarizes the information relied upon to select the preferred alternative. … At a minimum, the proposed plan shall: Provide a brief summary description of the remedial alternatives evaluated in the detailed analysis established under paragraph (e) (9) of this section; b. Contamination is present that requires the use of Institutional Controls or Land Use Controls. A No Action Decision is not appropriate. i. The EPA, in A Guide to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection Decision Documents (EPA 540-R-98-031), Section 8.1 Documenting No Action Decisions starts out, "The lead agency may determine that no action (i.e., no treatment, engineering controls, or institutional controls) is warranted…. ii. The Department of Defense has also supported this in the Memorandum Interim Guidance on Environmental Restoration Record of Decision (June 4, 2002). In the second paragraph, "When a remedial action is taken, it must be documented in a ROD as required by CERCLA and its implementing regulation, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This requirement fully applies to remedies that have a use restriction component." c. Contamination is present that exceeds standards identified in the Alaska Administrative Code, Chapter 18 Article 3. This is an Applicable Relevant and Appropriate Requirement (ARAR) as identified in the Remedial Investigation and the Feasibility Study. (i) 18 AAC 75.325 requires that the responsible person perform a cleanup of surface soil staining and that free product be removed to minimize the spread of contamination and avoid additional discharge. The RI in Section 6.12 states that soil at the top center of this section is stained black. POL contamination is visible near the bottom center of this section where water seeps out. The petroleum stained soil and any free product must be addressed. See site file for additional information.	Debra Caillouet
5/10/2007	Document, Report, or Work plan Review - other	Staff provided comments on the draft decision documents for Nikolski RRS. Thank you for providing the draft CERCLA Decision Documents for the Environmental Restoration Program Sites WP007, SS010, SS005, ST017, OT001, and ST018 at the Nikolski Radio Relay Station. The Alaska Department of Environmental Conservation is deferring comment on these documents pending completion of the public comment period, consideration of all comments received and resolution on land transfer and “affected landowner” issues. These issues are critical to the remedy selection. Please forward copies of all comments that are received on the Proposed Plan for department consideration	Debra Caillouet
1/18/2011	Document, Report, or Work plan Review - other	Staff provided comments on the draft ROD. 1.1 The site does have a CERCLIS ID, # AK4570028684 which has been archived. 1.2 Last sentence of the first paragraph on this page, please change to read: the Alaska Department of Environmental Conservation (not restoration) agrees that the selected remedy complies with state law. See site file for additional information.	Debra Caillouet
5/25/2011	CERCLA ROD Approved	Response action is required under Alaska state law to address the polychlorinated biphenyl contamination (PCB) onsite at concentrations greater than 1 mg/kg. The response action selected in this ROD under CERCLA will satisfy requirements under State law to protect the public health or welfare or the environment from actual or threatened release of hazardous substances into the environment. The contaminant of concern (COC) is PCBs, which have been detected above 18 AAC 75 soil cleanup levels. The general response actions that can be undertaken to satisfy remedial action objectives for protecting human health and environment at the installation include limited actions (e.g. institutional controls), containment, ex-situ treatment, in-situ treatment, and excavation and offsite land disposal of contaminated soils. Remedial alternatives for the Transformer Building and White Alice Arrays (OT-010) were developed and evaluated during the Feasibility Study (USAF 2003). Based on the results of the Feasibility Study (FS), USAF selected excavation and offsite land disposal of soils contaminated with PCBs in concentrations above 1 milligram per kilogram (mg/kg) as the preferred alternative for OT-010. The overall remedial action objective (RAO) for ERP sites at Nikolski RRS is protection of human health and the environment. The site-specific RAO for OT-010 is: Prevent exposure to surface soils containing PCBs in excess of 1 mg/kg There will be no CERCLA 5-year reviews conducted for OT-010 because no concentrations of contaminants will remain onsite above levels that allow for unlimited use and unrestricted exposure.	Debra Caillouet
12/11/2014	Document, Report, or Work plan Review - other	Draft Remedial Action Work Plan for Remedy Implementation at the Former Nikolski Radio Relay Station, Alaska December 2014, The plan is deficient in many details and requires significant revision. A complete revised DRAFT document is required. One major deficiency noted is the expectation for a three day turn around time for samples results. Flights out of Nikolski are frequently delayed due to weather conditions or scheduling issues. Predicating a schedule on this is not wise. Page 1-2 1.2 The phrase "samples from the eights excavation extents to confirm" needs to be corrected. Page 3-1 3.1 As the road and other areas are not under Air Force ownership or control, any restrictions will need to be coordinated with the landowner(s). Page 3-7 3.2.3 The ROD states that approximately 2300 cubic yards will need to be excavated. Explain how the scope is for less than 10% of the required volume. Page 3-10 3.2.14 Please read the ROD and comply with the selected remedy regarding ICs. Page 3-12 3.3.2 Peristaltic pumps are not recommended for VOC sampling and are not to be used to demonstrate cleanup complete. Use a bladder pump or a submersible. ii SOP-6 Remove this disclaimer. Sampling plans are to be approved by ADEC, including the SOPs. Changes to an approved work plan are not an unrestricted management right See 18 AAC 75.360. See site file for additional information.	Debra Caillouet
2/10/2015	Meeting or Teleconference Held	Meeting with AF, contractor and ADEC re: Remedy implementation at Driftwood/Nikolski RRS. Nikolski RRS The four sites in order of field execution: 1. OT010 – Former Transformer Building and White Alice Arrays (PCB-impacted soil) 2. SS006 (aka SA593) – Former Drum Storage Area (DRO, RRO, and trichloroethylene (TCE)-impacted soil) 3. SS003 – POL Pipeline (DRO- and RRO-impacted soil) 4. SS004 – POL Tank Area (DRO-, PAH-, and benzene-impacted soil) OT010 – Former Transformer Building and White Alice Arrays. - Excavate/dispose off-site of 100 cubic yards (cy) of PCB-contaminated soil - Collect confirmation samples. SS006 –Former Drum Storage Area. - Excavate/dispose off-site approximately 186 cy of DRO/RRO-contaminated soil - Excavate/dispose off-site approximately 39 cy of TCE-contaminated soil from two locations - Collect confirmation samples from the three excavations - Collect one post remediation groundwater monitoring round as part of LTM ?- Replace damaged wells resulting from the RA (MW-4 and MW-5) SS003 – POL Pipeline. - Excavate/dispose off-site 500 cy of POL-impacted soil from three areas; - Collect confirmation samples from the three excavation areas. SS004 - POL Tank Area. - Excavate/dispose off-site 183 cy of PAH-contaminated soil - Excavate/dispose off-site 2,125 cy of DRO-contaminated and RRO-contaminated soil from seven locations - Collect confirmation samples from the excavation areas - Collect one post remediation groundwater monitoring as part of LTM ? - Replace damaged well as result of RA (MW08) ? - Plug and abandon monitoring wells MW01, MW02, MW03, MW06, MW07, MW09 and MW10.	Debra Caillouet
5/4/2015	Document, Report, or Work plan Review - other	Staff commented on the Draft-Final RA WP for Remedy Implementation at SS003, SS004, SS006 and OT010. Page 3-6 Table 3-1 Review and correct. Holding time for VOCs is not 180 days. There are six methods in EPA 540-R-09-03 Jan 2011, Appendix B for low level VOCs in soil, the method you have chosen has this caveat This option is NOT a Preferred Option for the CLP because: NaHS0-1 preservation creates low pH conditions that will cause the destruction of certain CLP target analytes (e.g., vinyl chloride, trichloroethene, trichlorofluoromethane, cis- and trans-1,3-dichloropropene). As vinyl chloride and trichloroethene are two of the COCs please chose one of the three recommended methods. VOC water samples are not collected in 1 liter bottles nor are TLC caps used. This also has to be corrected in the UFP-QAPP. Provide method for RRO in water. Table 4-2 The sub-sites/areas that are shown in this table are not identified in the figures. The RODs do not include sub-sites. Provide figures with the sub-sites identified, once that occurs ADEC may or may not concur with the analytes for each area. Duplicates are to be collected at a rate of 10% minimum. 24 is less than 10% of 245. Verify all and correct, as there are others also shown at less than 10%. At SS004 confirmation sampling is to include PAH. Long-Term monitoring at SS006 is to include GRO and DRO. Page 4-1 4.3 The volumes in this section, 39 cy TCE and 186 cy DRO are not in the ROD. The ROD states "estimated volume of soil to be excavated at SS006 is approximately 200 cubic yards". See comment 7, sub-sites are not shown on Figure 4-4. Also note that sample SS6-HA31 has TCE at 0.484 mg/kg which is above the cleanup level but the value is not bolded on Figure 4-4. UFP-QAPP Page 11 Worksheet 6 should be Communications Pathways. Worksheet 10 is the Conceptual Site Model. The information in the table does not apply to either. Please review and fix. The rest of this UFP-QAPP, is not being reviewed. Please do an internal review of this document to assure that the contents of each worksheet is what is explained in the Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans Optimized UFP-QAPP Worksheets March 2012. Please note that the Executive Summary of said document includes this: ... "the information contained in the worksheets continues to capture the elements that would comprise related project-planning documents, such as a Sampling and Analysis Plan (SAP), Work Plan (WP), and Field Sampling Plan (FSP)" and" ... the final, approved QAPP is designed to be a stand-alone document containing all specifications and procedures necessary for project personnel to carry out their assigned responsibilities. For example, the field team should be able to rely on the QAPP for complete sampling instructions, including how to sample, where to sample, how many samples to collect, the types of bottles, preservatives, related QC, etc. If the approved QAPP provides insufficient procedures to carry out all tasks, then SOP's must be attached to the QAPP. If required elements are contained in other documents, those documents may be referenced; however the documents must be available to all personnel responsible for reviewing and implementing the QAPP" ADEC can review this document with the separate Work Plan and Waste Management Plan Quality Control Plan Page 5-2 5.7 The UFP-QAPP has many obvious omissions/errors. Please explain what type of review occurred and why future QA/QC on the actual performance of the work should be trusted. See site file for additional information.	Debra Caillouet
11/30/2015	Meeting or Teleconference Held	Meeting with MWH scoping 5 year review for Nikolski sites. 5YR under CERCLA will not include this site as remedy was implemented in 2015 and cleanup report is not final.	Fred Vreeman
5/31/2016	Offsite Soil or Groundwater Disposal Approved	Soil transport request approved to Columbia Ridge Landfill for disposal See site file for additional information.	Louis Howard
1/31/2018	Update or Other Action	Draft RAO LTM report received for review and comment. A total of 45 analytical samples were collected and at least one analytical sample was collected from each soil boring and sample location. Review of the analytical results from the PCB delineation effort indicate that concentrations of PCB-contaminated soil remains across the site and within and around the Excavation 1/2 and Excavation 3 areas that were excavated in 2015. A sample collected from the 0.5-ft to 1-ft interval at borehole location BH-288 contained a PCB concentration of 59.4 mg/kg, which exceeds the TSCA hazardous waste criterion of 50 mg/kg for PCBs. All other sample results were below the TSCA hazardous waste criterion but exceeded the ADEC Method Two Cleanup levels for PCBs in all but six of the samples submitted to SGS for analysis. Review of the analytical results from the PCB delineation effort at OT010 show that the extent of PCB contamination at this site is still unknown and suggests that the volume and extent of contaminated soils is greater than previously anticipated. Additional investigation is needed to delineate the final extent of the PCBs in order to accurately perform a volume calculation for future removal activities. See site file for additional information.	Louis Howard
3/7/2018	Document, Report, or Work plan Review - other	Draft Remedial Action – Operations/LTM Report for Nikolski RRS reviewed. Staff agreed that the extent of PCB contamination at this site is still unknown and the volume and extent is greater than previously anticipated. ADEC concurs that additional investigation is needed for delineating the final extent of PCBs at OT010 for future removal activities. See site file for additional information.	Louis Howard
9/17/2018	Document, Report, or Work plan Review - other	A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at Nikolski Radio Relay Station. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law. See site file for additional information.	Louis Howard
9/17/2018	Document, Report, or Work plan Review - other	Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds. See site file for additional information.	Louis Howard
1/22/2019	Document, Report, or Work plan Review - other	Staff commented on the WP Addendum. Main comments were to require that the complete laboratory report be included as part of the technical memorandum when the investigation is complete. See site file for additional information.	Louis Howard
3/8/2019	Document, Report, or Work plan Review - other	Staff approved the Draft Supplemental Work Plan for Various Sites at Nikolski RRS, Alaska dated April 2019	Louis Howard
5/9/2019	Document, Report, or Work plan Review - other	Work plan addendum for 2019 Remedial Action Operations, Land Use/Institutional Control Former Nikolski Radio Relay Station Sites LF001, OT001, OT010, SA593, SS003, SS004, ST017, TU019, and WP007 approved by ADEC.	Louis Howard
4/8/2020	Document, Report, or Work plan Review - other	Staff reviewed the Draft Technical Project Report for LF001, OT001, OT010, SS006, SS003, SS004, ST017, and WP007 at the Former Nikolski Radio Relay Station dated April 2020. Main comments were to request the Air Force to implement the land use controls for OT010 for residual contamination and install signage warning of residual PCBs in the ground at the site. See site file for additional information.	Louis Howard
4/27/2020	Document, Report, or Work plan Review - other	Staff approved the request for use of dedicated tubing in monitoring wells on the Pribilof Islands. See site file for additional information.	Louis Howard
6/1/2021	Document, Report, or Work plan Review - other	Staff provided comments on the 2021 Draft Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period.	Axl LeVan
6/17/2021	Document, Report, or Work plan Review - other	DEC reviewed and provided comments for the "Revised Proposed Plan for Site SS-010: Former Transformer Building and White Alice Arrays, Nikolski Radio Relay Station, Nikolski, AK, April 2021" received May 18, 2021. The Revised Proposed Plan outlines a new preferred alternative for the USAF in remediating PCB contamination at site SS-010. The new preferred alternative is to cover the remaining contaminated soil with a cap and manage the site with Long Term Monitoring and land use controls. DEC noted that the new preferred alternative currently does not pass the Threshold Criteria for comparison of Remedial Alternatives due to a lack of compliance with the Toxic Substances Control Act regarding concentrations of PCBs remaining at the Site. Additionally. further information is required to ensure that the new alternative would be protective of Human Health and the environment.	Axl LeVan
8/20/2021	Document, Report, or Work plan Review - other	Staff approved the 2021 Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, August 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period.	Axl LeVan
7/21/2022	Document, Report, or Work plan Review - other	The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of the Draft-Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, June 2022 on June 27, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004.	Axl LeVan
9/7/2022	Document, Report, or Work plan Review - other	The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program approved the Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, August 2022 on August 26, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004.	Axl LeVan
3/7/2023	Document, Report, or Work plan Review - other	DEC reviewed and provided comments on the "Draft Work Plan, PCB Remedial Investigation/Removal Action, Site SS-010, Former Nikolski Radio Relay Station, January 2023". DEC received a copy of the document on February 13, 2023. The work plan describes both the removal of PCB contaminated soil off-site and a delineation and capping of contamination where removal is limited by the steep conditions at the site.	Axl LeVan
5/16/2023	CERCLA Removal Action Plan	DEC reviewed and approved the "Final Work Plan, PCB Remedial Investigation/Removal Action, Site SS-010, Former Nikolski Radio Relay Station, January 2023". DEC received a copy of the document on May 15, 2023. The work plan describes both the removal of PCB contaminated soil off-site and a delineation and capping of contamination where removal is limited by the steep conditions at the site. All DEC comments had been addressed and integrated into the final document.	Axl LeVan
5/21/2024	Long Term Monitoring Workplan or Report Review	DEC reviewed and provided comments on the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, April 2024." This report presents the results of the 2023 Long-Term Management (LTM) performed at the Former Nikolski Radio Relay Station.	Axl LeVan
7/15/2024	Document, Report, or Work plan Review - other	DEC reviewed and approved the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, July 2024." based on updates addressing DEC comments on the draft. The report documents long term management at LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007.	Axl LeVan
7/22/2024	Document, Report, or Work plan Review - other	DEC reviewed and provided comments on the draft report "PCB Remedial Investigation/Removal Action, Nikolski Radio Relay Station, Site SS-010, Alaska, April 2024". DEC additionally requested information on whether an ADEC Transport and Approval form had been provided.	Axl LeVan
10/9/2024	Compliance Advisory Letter	DEC sent a Compliance Advisory Letter regarding a failure to follow approved workplans and regulations at Eielson Air Force Base (EAFB) and Nikolski Long Range Radar Station (LRRS). At EAFB this occurred with work related to the Installation Wide Monitoring Program. At Nikolski LRRS the work was associated with the PCB removal action at SS010. In both projects contaminated soils and/or water were transported from the site without DEC approval in the form of a signed "Contaminated Media Transport and Treatment or Disposal Approval Form".	Axl LeVan
11/4/2024	Document, Report, or Work plan Review - other	DEC reviewed and approved the "Final Report, PCB Remedial Investigation/Removal Action, Nikolski Radio Relay Station, Site SS-010, Alaska, October 2024". This report presents polychlorinated biphenyl (PCB) remedial investigation (RI) and removal action (RA) at the Former Transformer Building and White Alice Antenna Array (Site SS-010/OT010)	Axl LeVan

Action Date

Action

Description

DEC Staff

8/1/2002

Update or Other Action

While not listed on the NPL, the Air Force must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality].

Louis Howard

8/2/2002

Update or Other Action

Air Force Statement of Objectives (SOO) for a performance based contract. The purpose of the project is to complete remedy selection and implementation at 11 contaminated sites, and conduct demolition and debris removal at, and in the vicinity of, the former Air Force (AF) Nikolski Radio Relay Station, located near Nikolski, Alaska. Work shall include removal of unsafe buildings and other structures. The property shall be rendered suitable for future use by preventing exposure to contamination that may result in unacceptable risk to human health and the environment. Remedies shall achieve the required cleanup levels at each site identified herein, as required by the applicable state and federal law. The Contractor shall submit a Proposed Plan(s) that meets the requirements of the Draft Proposed Plan Checklist dated 07 Feb 2005 posted on the AFCEE web site. The plan describing remedy alternatives shall be submitted for Air Force Headquarters review prior to submittal to the ADEC. The Contractor is required to coordinate with the AF early in the process to ensure all requirements for formats and inclusions are met. Approximately 6-9 months will be required for Air Force Headquarters coordination, review, and signature approval. Per the Air Force policy letter, dated 12 March 2004, posted on the AFCEE website, a Decision Document/Record of Decision (ROD) describing the selected remedy shall be submitted for Air Force Headquarters review prior to submittal to the Alaska Department of Environmental Conservation (ADEC). The Contractor is required to coordinate with the AF early in the process to ensure all requirements for formats and inclusions are met. Approximately 6-9 months will be required for Air Force Headquarters coordination, review, and signature approval. The document shall conform to the Draft Checklist for Records of Decision, dated 07 Feb 2005 located on the AFCEE website.

Louis Howard

3/4/2003

Document, Report, or Work plan Review - other

Staff commented on the Nikolski Radio Relay Station, Approval of Feasibility Study for Sites, LF-001, AOC-01, SS-002, SS-005, SS-006, AOC-08, AOC-09, and OT-010 The Alaska Department of Environmental Conservation (DEC) received your response to our comments of October 14, 2002 on February 21, 2003. The response to comments has met the requirements of 18 AAC 75.335(c)(5) for the above listed nine of the thirteen sites investigated. The cleanup methods proposed in the document have been reviewed by DEC but will need to be presented for public review and comment before they can be approved. The Risk Assessment that is proposed for sites OT-001, SS-003, SS-004 and WP-007 should follow the guidance found in the Risk Assessment Procedures Manual, June 2002 and User's Guide for Selection and Application of Default Assessment Endpoints and Indicator Species in Alaskan Ecoregions, June 1999.

Debra Caillouet

3/17/2004

Document, Report, or Work plan Review - other

Your letter of 25 February 2004, Air Force Response to Comment, Nikolski RRS, Baseline Risk Assessment The response has been reviewed by the risk assessor and me. Overall the response to ADEC comments was well-done and the proposed changes are acceptable. In regards to the response to Lindsay Smith's Comment 5 about calculating cumulative risk, it is acceptable to treat sediment and soil as well as fresh and marine water separately. However the potential cumulative risk to a future resident should be presented as the sum of risks from groundwater and soil. In addition to the previous comments submitted, the clean up level calculated for DRO at the POL tank area (section 6.1.2.2) needs to be addressed. ADEC’s Clean Up Level Guidance and the Guidance for Clean up of Petroleum Contaminated Sites only specify site specific soil conditions that can be modified to develop alternative clean up levels. Dividing the calculated ACL by 40% is not a justifiable method for dealing with the different sorption capabilities of the aromatic and aliphatic portion of DRO. The clean up level will have to be modified before the Risk Assessment can be accepted. It should be the number that was originally calculated in the Remedial Investigation, Appendix K, including both fractions, i.e. 1190 mg/kg.

Debra Caillouet

12/16/2004

Document, Report, or Work plan Review - other

Staff provided comments on the draft PP for AOC-01 dam and pump house foundation, SS-002 former water supply house and aboveground storage tank, SS-005 runway lighting vault building and underground storage tank, SS-006 former drum storage area, AOC-07 construction camp septic tank, AOC-08 composite building septic tank and outfall, AOC-09 two 20,000 gallon underground storage tanks, OT-010 former transfer building and White Alice Arrays. Page 18, OT-010 - Former Transformer Building and Associated White Alice Arrays: Please include in the description of the preferred alternative the source of the cleanup levels. The second sentence in the preferred alternative section should read, "… would prevent exposure to soils containing…"

Louis Howard

5/29/2006

Document, Report, or Work plan Review - other

Staff provided comments regarding State of AK requirements for Proposed Plans and site specific comments. OT-010 Former Transformer Building and Associated White Alice Arrays – Soil contaminated with PCBs above 1 mg/kg will be excavated and treated off-site.

Debra Caillouet

6/30/2006

Document, Report, or Work plan Review - other

Your letters on the Technical Approach for Re-Evaluation of Human Health Risk for SS004, POL Tank Area, Nikolski Radio Relay Station (RRS), dated June 1 & June 28, 2006 The Alaska Department of Environmental Conservation (DEC) received the letters referenced above & met with you on June 261h to discuss the issues. The first letter outlines an Air Force proposal to re-evaluate potential risks posed by petroleum contamination at former fuel tank site using a revised, limited future land use scenario & cites the basis for redoing the risk assessment as a October 2004 Air Force land disposal policy. That policy, which was issued after the Nikolski RRS Baseline Risk Assessment had been completed in June 2004, states, "prior to risk assessment, the future resource use should be assumed, to the extent consistent with applicable law, to be the same category of resource use while the property was part of an active installation." Alaska's oil & hazardous substance cleanup regulations (18 AAC 75, Article 3 - site cleanup rules) define cleanup procedures, levels & associated requirements. Site specific alternative risk-based cleanup levels may be approved. 18 AAC 75.340(f) defines requirements for alternative cleanup levels based on risk assessments, including: (1) the need to follow the department's Risk Assessments Procedures Manual (RAPM), & (2) the responsible party obtaining "the consent of each landowner who is affected by the contamination at the site that a cleanup level less stringent than a cleanup level appropriate to residential land use is appropriate for the site". Section 3.2.2.1, Land Uses, in the RAPM requires reasonably anticipated future land use scenarios be identified in the work plan. Estimating future exposure requires assumptions about how the site & surrounding land will be used in the future. It is one of the most important steps in the exposure assessment because assumptions about the future use of land are a major determinant in calculating risk-based cleanup levels. For alternative cleanup level determinations, assumed limitations on future land use require ADEC concurrence. As discussed during our June 26th meeting & documented during completion of the existing baseline risk assessment for the site, land at SS04 is suitable for residential development. Congress passed legislation requiring the Air Force to cleanup the property & transfer it to the local village corporation. Thus, the corporation is a landowner affected by contamination at the site & according to Alaska law the Air Force must obtain concurrence from the corporation that cleanup to levels less protective than would allow for residential use is required before the DEC could approve such alternative cleanup levels. Additionally, if the affected land owners consent to limitations on future land use, the Air Force, as the responsible party for cleanup, must develop appropriate institutional controls that would restrict future land use to those scenarios for which the cleanup is protective. See 18 AAC 75.340(d) & 18 AAC 75.375. To date, the Air Force has not provided any information to demonstrate how it would establish such controls. See site file for additional information.

Debra Caillouet

11/20/2006

Document, Report, or Work plan Review - other

Your letter Technical Approach for Evaluation of Human Health Risk for SS004, POL Tank Area, Nikolski Radio Relay Station (RRS), dated 2 November 2006 The Alaska Department of Environmental Conservation (DEC) received the letter referenced above on November 14, 2006. The letter outlines an Air Force rationale for proceeding with a risk assessment using a revised, limited future land use. It also states that the Air Force acknowledges that ownership of the land might not be conveyed if limitations on land use are established. While your letter only asks that DEC provide a response that the Air Force will not be expected to obtain consent of the corporations for a site-specific risk assessment that does not protect residential use, DEC would like to point out that there are specific procedures that must be followed for a risk assessment to be approved. In the Risk Assessment Procedures Manual (adopted by regulation) in Section 1.3, Risk Assessment Requirements, DEC's risk assessment procedures include, at a minimum, the steps in the ADEC Risk Assessment Checklist and Scoping Meeting Checklist. Your letter does not relieve the Air Force of the responsibility of complying with the requirements of 18 AAC 75 or specifically the requirements of the Risk Assessments Procedures Manual. Until the Air Force complies with requirements in the Risk Assessment Procedures Manual, DEC will not issue any determination on the applicability or acceptability of a revised risk assessment. Please contact me at 907-269-0298 and our risk assessor, Marty Brewer at 269-3084 to set up a Risk Assessment Scoping Meeting.

Debra Caillouet

2/16/2007

Site Added to Database

Site added to the database.

Mitzi Read

2/20/2007

Document, Report, or Work plan Review - other

Staff provided comments on the draft proposed plans for six sites at Nikolski RRS. General Comment 1) All of the draft Proposed Plans state the U.S. Environmental Protection Agency has not provided comment on the recent studies or the Proposed Plan and also include a section indicating that the EPA issued a No Further Remedial Action Planned determination in 1994. DEC is unaware of the submittal of any documents to EPA for review since the NFRAP decision was issued. Please revise as necessary to be consistent with actions. Comment on Draft Proposed Plan SSOlO Former Transformer Building and Associated White Alice Arrays 12) DEC does not concur with the proposed "no action required" status for this site. Establishing and enforcing institutional controls and conducting Five Year reviews are actions that are required to prevent exposure to contamination.

Debra Caillouet

3/9/2007

Exposure Tracking Model Ranking

Debra Caillouet

3/9/2007

Document, Report, or Work plan Review - other

On behalf of the Alaska Department of Environmental Conservation the attached pages provide the department's comments on the Proposed Plans for: Site WP007, Composite Building Outfall, Site OT001 Former Composite Building and White Alice Arrays, Site ST017 Construction Camp Septic Tank, Site SS010 Former Transformer Buildings and Associated White Alice Arrays, and request for a public meeting at a time other than the one included in the Proposed Plans. Proposed Plan for Site WP007, Composite Building Outfall 1 The Proposed Plan does not present the remedial alternatives that were analyzed for the site. a. The National Contingency Plan in 40 CFR 300.430 (f) (2) states: The proposed plan. In the first step in the remedy selection process, the lead agency shall identify the alternative that best meets the requirements in Sec. 300.430(f)(1), above, and shall present that alternative to the public in a proposed plan. The lead agency, in conjunction with the support agency and consistent with Sec. 300.515(e), shall prepare a proposed plan that briefly describes the remedial alternatives analyzed by the lead agency, proposes a preferred remedial action alternative, and summarizes the information relied upon to select the preferred alternative. … At a minimum, the proposed plan shall: Provide a brief summary description of the remedial alternatives evaluated in the detailed analysis established under paragraph (e) (9) of this section; b. Contamination is present that requires the use of Institutional Controls or Land Use Controls. A No Action Decision is not appropriate. i. The EPA, in A Guide to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection Decision Documents (EPA 540-R-98-031), Section 8.1 Documenting No Action Decisions starts out, "The lead agency may determine that no action (i.e., no treatment, engineering controls, or institutional controls) is warranted…. ii. The Department of Defense has also supported this in the Memorandum Interim Guidance on Environmental Restoration Record of Decision (June 4, 2002). In the second paragraph, "When a remedial action is taken, it must be documented in a ROD as required by CERCLA and its implementing regulation, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This requirement fully applies to remedies that have a use restriction component." c. Contamination is present that exceeds standards identified in the Alaska Administrative Code, Chapter 18 Article 3. This is an Applicable Relevant and Appropriate Requirement (ARAR) as identified in the Remedial Investigation and the Feasibility Study. (i) 18 AAC 75.325 requires that the responsible person perform a cleanup of surface soil staining and that free product be removed to minimize the spread of contamination and avoid additional discharge. The RI in Section 6.12 states that soil at the top center of this section is stained black. POL contamination is visible near the bottom center of this section where water seeps out. The petroleum stained soil and any free product must be addressed. See site file for additional information.

Debra Caillouet

5/10/2007

Document, Report, or Work plan Review - other

Staff provided comments on the draft decision documents for Nikolski RRS. Thank you for providing the draft CERCLA Decision Documents for the Environmental Restoration Program Sites WP007, SS010, SS005, ST017, OT001, and ST018 at the Nikolski Radio Relay Station. The Alaska Department of Environmental Conservation is deferring comment on these documents pending completion of the public comment period, consideration of all comments received and resolution on land transfer and “affected landowner” issues. These issues are critical to the remedy selection. Please forward copies of all comments that are received on the Proposed Plan for department consideration

Debra Caillouet

1/18/2011

Document, Report, or Work plan Review - other

Staff provided comments on the draft ROD. 1.1 The site does have a CERCLIS ID, # AK4570028684 which has been archived. 1.2 Last sentence of the first paragraph on this page, please change to read: the Alaska Department of Environmental Conservation (not restoration) agrees that the selected remedy complies with state law. See site file for additional information.

Debra Caillouet

5/25/2011

CERCLA ROD Approved

Response action is required under Alaska state law to address the polychlorinated biphenyl contamination (PCB) onsite at concentrations greater than 1 mg/kg. The response action selected in this ROD under CERCLA will satisfy requirements under State law to protect the public health or welfare or the environment from actual or threatened release of hazardous substances into the environment. The contaminant of concern (COC) is PCBs, which have been detected above 18 AAC 75 soil cleanup levels. The general response actions that can be undertaken to satisfy remedial action objectives for protecting human health and environment at the installation include limited actions (e.g. institutional controls), containment, ex-situ treatment, in-situ treatment, and excavation and offsite land disposal of contaminated soils. Remedial alternatives for the Transformer Building and White Alice Arrays (OT-010) were developed and evaluated during the Feasibility Study (USAF 2003). Based on the results of the Feasibility Study (FS), USAF selected excavation and offsite land disposal of soils contaminated with PCBs in concentrations above 1 milligram per kilogram (mg/kg) as the preferred alternative for OT-010. The overall remedial action objective (RAO) for ERP sites at Nikolski RRS is protection of human health and the environment. The site-specific RAO for OT-010 is: Prevent exposure to surface soils containing PCBs in excess of 1 mg/kg There will be no CERCLA 5-year reviews conducted for OT-010 because no concentrations of contaminants will remain onsite above levels that allow for unlimited use and unrestricted exposure.

Debra Caillouet

12/11/2014

Document, Report, or Work plan Review - other

Draft Remedial Action Work Plan for Remedy Implementation at the Former Nikolski Radio Relay Station, Alaska December 2014, The plan is deficient in many details and requires significant revision. A complete revised DRAFT document is required. One major deficiency noted is the expectation for a three day turn around time for samples results. Flights out of Nikolski are frequently delayed due to weather conditions or scheduling issues. Predicating a schedule on this is not wise. Page 1-2 1.2 The phrase "samples from the eights excavation extents to confirm" needs to be corrected. Page 3-1 3.1 As the road and other areas are not under Air Force ownership or control, any restrictions will need to be coordinated with the landowner(s). Page 3-7 3.2.3 The ROD states that approximately 2300 cubic yards will need to be excavated. Explain how the scope is for less than 10% of the required volume. Page 3-10 3.2.14 Please read the ROD and comply with the selected remedy regarding ICs. Page 3-12 3.3.2 Peristaltic pumps are not recommended for VOC sampling and are not to be used to demonstrate cleanup complete. Use a bladder pump or a submersible. ii SOP-6 Remove this disclaimer. Sampling plans are to be approved by ADEC, including the SOPs. Changes to an approved work plan are not an unrestricted management right See 18 AAC 75.360. See site file for additional information.

Debra Caillouet

2/10/2015

Meeting or Teleconference Held

Meeting with AF, contractor and ADEC re: Remedy implementation at Driftwood/Nikolski RRS. Nikolski RRS The four sites in order of field execution: 1. OT010 – Former Transformer Building and White Alice Arrays (PCB-impacted soil) 2. SS006 (aka SA593) – Former Drum Storage Area (DRO, RRO, and trichloroethylene (TCE)-impacted soil) 3. SS003 – POL Pipeline (DRO- and RRO-impacted soil) 4. SS004 – POL Tank Area (DRO-, PAH-, and benzene-impacted soil) OT010 – Former Transformer Building and White Alice Arrays. - Excavate/dispose off-site of 100 cubic yards (cy) of PCB-contaminated soil - Collect confirmation samples. SS006 –Former Drum Storage Area. - Excavate/dispose off-site approximately 186 cy of DRO/RRO-contaminated soil - Excavate/dispose off-site approximately 39 cy of TCE-contaminated soil from two locations - Collect confirmation samples from the three excavations - Collect one post remediation groundwater monitoring round as part of LTM ?- Replace damaged wells resulting from the RA (MW-4 and MW-5) SS003 – POL Pipeline. - Excavate/dispose off-site 500 cy of POL-impacted soil from three areas; - Collect confirmation samples from the three excavation areas. SS004 - POL Tank Area. - Excavate/dispose off-site 183 cy of PAH-contaminated soil - Excavate/dispose off-site 2,125 cy of DRO-contaminated and RRO-contaminated soil from seven locations - Collect confirmation samples from the excavation areas - Collect one post remediation groundwater monitoring as part of LTM ? - Replace damaged well as result of RA (MW08) ? - Plug and abandon monitoring wells MW01, MW02, MW03, MW06, MW07, MW09 and MW10.

Debra Caillouet

5/4/2015

Document, Report, or Work plan Review - other

Staff commented on the Draft-Final RA WP for Remedy Implementation at SS003, SS004, SS006 and OT010. Page 3-6 Table 3-1 Review and correct. Holding time for VOCs is not 180 days. There are six methods in EPA 540-R-09-03 Jan 2011, Appendix B for low level VOCs in soil, the method you have chosen has this caveat This option is NOT a Preferred Option for the CLP because: NaHS0-1 preservation creates low pH conditions that will cause the destruction of certain CLP target analytes (e.g., vinyl chloride, trichloroethene, trichlorofluoromethane, cis- and trans-1,3-dichloropropene). As vinyl chloride and trichloroethene are two of the COCs please chose one of the three recommended methods. VOC water samples are not collected in 1 liter bottles nor are TLC caps used. This also has to be corrected in the UFP-QAPP. Provide method for RRO in water. Table 4-2 The sub-sites/areas that are shown in this table are not identified in the figures. The RODs do not include sub-sites. Provide figures with the sub-sites identified, once that occurs ADEC may or may not concur with the analytes for each area. Duplicates are to be collected at a rate of 10% minimum. 24 is less than 10% of 245. Verify all and correct, as there are others also shown at less than 10%. At SS004 confirmation sampling is to include PAH. Long-Term monitoring at SS006 is to include GRO and DRO. Page 4-1 4.3 The volumes in this section, 39 cy TCE and 186 cy DRO are not in the ROD. The ROD states "estimated volume of soil to be excavated at SS006 is approximately 200 cubic yards". See comment 7, sub-sites are not shown on Figure 4-4. Also note that sample SS6-HA31 has TCE at 0.484 mg/kg which is above the cleanup level but the value is not bolded on Figure 4-4. UFP-QAPP Page 11 Worksheet 6 should be Communications Pathways. Worksheet 10 is the Conceptual Site Model. The information in the table does not apply to either. Please review and fix. The rest of this UFP-QAPP, is not being reviewed. Please do an internal review of this document to assure that the contents of each worksheet is what is explained in the Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans Optimized UFP-QAPP Worksheets March 2012. Please note that the Executive Summary of said document includes this: ... "the information contained in the worksheets continues to capture the elements that would comprise related project-planning documents, such as a Sampling and Analysis Plan (SAP), Work Plan (WP), and Field Sampling Plan (FSP)" and" ... the final, approved QAPP is designed to be a stand-alone document containing all specifications and procedures necessary for project personnel to carry out their assigned responsibilities. For example, the field team should be able to rely on the QAPP for complete sampling instructions, including how to sample, where to sample, how many samples to collect, the types of bottles, preservatives, related QC, etc. If the approved QAPP provides insufficient procedures to carry out all tasks, then SOP's must be attached to the QAPP. If required elements are contained in other documents, those documents may be referenced; however the documents must be available to all personnel responsible for reviewing and implementing the QAPP" ADEC can review this document with the separate Work Plan and Waste Management Plan Quality Control Plan Page 5-2 5.7 The UFP-QAPP has many obvious omissions/errors. Please explain what type of review occurred and why future QA/QC on the actual performance of the work should be trusted. See site file for additional information.

Debra Caillouet

11/30/2015

Meeting or Teleconference Held

Meeting with MWH scoping 5 year review for Nikolski sites. 5YR under CERCLA will not include this site as remedy was implemented in 2015 and cleanup report is not final.

Fred Vreeman

5/31/2016

Offsite Soil or Groundwater Disposal Approved

Soil transport request approved to Columbia Ridge Landfill for disposal See site file for additional information.

Louis Howard

1/31/2018

Update or Other Action

Draft RAO LTM report received for review and comment. A total of 45 analytical samples were collected and at least one analytical sample was collected from each soil boring and sample location. Review of the analytical results from the PCB delineation effort indicate that concentrations of PCB-contaminated soil remains across the site and within and around the Excavation 1/2 and Excavation 3 areas that were excavated in 2015. A sample collected from the 0.5-ft to 1-ft interval at borehole location BH-288 contained a PCB concentration of 59.4 mg/kg, which exceeds the TSCA hazardous waste criterion of 50 mg/kg for PCBs. All other sample results were below the TSCA hazardous waste criterion but exceeded the ADEC Method Two Cleanup levels for PCBs in all but six of the samples submitted to SGS for analysis. Review of the analytical results from the PCB delineation effort at OT010 show that the extent of PCB contamination at this site is still unknown and suggests that the volume and extent of contaminated soils is greater than previously anticipated. Additional investigation is needed to delineate the final extent of the PCBs in order to accurately perform a volume calculation for future removal activities. See site file for additional information.

Louis Howard

3/7/2018

Document, Report, or Work plan Review - other

Draft Remedial Action – Operations/LTM Report for Nikolski RRS reviewed. Staff agreed that the extent of PCB contamination at this site is still unknown and the volume and extent is greater than previously anticipated. ADEC concurs that additional investigation is needed for delineating the final extent of PCBs at OT010 for future removal activities. See site file for additional information.

Louis Howard

9/17/2018

Document, Report, or Work plan Review - other

A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at Nikolski Radio Relay Station. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law. See site file for additional information.

Louis Howard

9/17/2018

Document, Report, or Work plan Review - other

Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds. See site file for additional information.

Louis Howard

1/22/2019

Document, Report, or Work plan Review - other

Staff commented on the WP Addendum. Main comments were to require that the complete laboratory report be included as part of the technical memorandum when the investigation is complete. See site file for additional information.

Louis Howard

3/8/2019

Document, Report, or Work plan Review - other

Staff approved the Draft Supplemental Work Plan for Various Sites at Nikolski RRS, Alaska dated April 2019

Louis Howard

5/9/2019

Document, Report, or Work plan Review - other

Work plan addendum for 2019 Remedial Action Operations, Land Use/Institutional Control Former Nikolski Radio Relay Station Sites LF001, OT001, OT010, SA593, SS003, SS004, ST017, TU019, and WP007 approved by ADEC.

Louis Howard

4/8/2020

Document, Report, or Work plan Review - other

Staff reviewed the Draft Technical Project Report for LF001, OT001, OT010, SS006, SS003, SS004, ST017, and WP007 at the Former Nikolski Radio Relay Station dated April 2020. Main comments were to request the Air Force to implement the land use controls for OT010 for residual contamination and install signage warning of residual PCBs in the ground at the site. See site file for additional information.

Louis Howard

4/27/2020

Document, Report, or Work plan Review - other

Staff approved the request for use of dedicated tubing in monitoring wells on the Pribilof Islands. See site file for additional information.

Louis Howard

6/1/2021

Document, Report, or Work plan Review - other

Staff provided comments on the 2021 Draft Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period.

Axl LeVan

6/17/2021

Document, Report, or Work plan Review - other

DEC reviewed and provided comments for the "Revised Proposed Plan for Site SS-010: Former Transformer Building and White Alice Arrays, Nikolski Radio Relay Station, Nikolski, AK, April 2021" received May 18, 2021. The Revised Proposed Plan outlines a new preferred alternative for the USAF in remediating PCB contamination at site SS-010. The new preferred alternative is to cover the remaining contaminated soil with a cap and manage the site with Long Term Monitoring and land use controls. DEC noted that the new preferred alternative currently does not pass the Threshold Criteria for comparison of Remedial Alternatives due to a lack of compliance with the Toxic Substances Control Act regarding concentrations of PCBs remaining at the Site. Additionally. further information is required to ensure that the new alternative would be protective of Human Health and the environment.

Axl LeVan

8/20/2021

Document, Report, or Work plan Review - other

Staff approved the 2021 Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Nikolski Radio Relay Station, Alaska, August 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Nikolski Radio Relay Station sites, including annual groundwater sampling for site SS004. The Work Plan covers work being performed over a 5-year period.

Axl LeVan

7/21/2022

Document, Report, or Work plan Review - other

The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of the Draft-Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, June 2022 on June 27, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004.

Axl LeVan

9/7/2022

Document, Report, or Work plan Review - other

The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program approved the Final 2021 Land use/Institutional Controls and Long-Term Management Report, Nikolski Long Range Radar Site, August 2022 on August 26, 2022. This report presents the results of the 2021 Long-Term Monitoring (LTM) performed at the Former Nikolski Radio Relay Station Sites LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007. This work was performed October 15 through 18, 2021 and included institution control (IC) and land use control (LUC) inspections. Groundwater sampling also occurred at site SS004.

Axl LeVan

3/7/2023

Document, Report, or Work plan Review - other

DEC reviewed and provided comments on the "Draft Work Plan, PCB Remedial Investigation/Removal Action, Site SS-010, Former Nikolski Radio Relay Station, January 2023". DEC received a copy of the document on February 13, 2023. The work plan describes both the removal of PCB contaminated soil off-site and a delineation and capping of contamination where removal is limited by the steep conditions at the site.

Axl LeVan

5/16/2023

CERCLA Removal Action Plan

DEC reviewed and approved the "Final Work Plan, PCB Remedial Investigation/Removal Action, Site SS-010, Former Nikolski Radio Relay Station, January 2023". DEC received a copy of the document on May 15, 2023. The work plan describes both the removal of PCB contaminated soil off-site and a delineation and capping of contamination where removal is limited by the steep conditions at the site. All DEC comments had been addressed and integrated into the final document.

Axl LeVan

5/21/2024

Long Term Monitoring Workplan or Report Review

DEC reviewed and provided comments on the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, April 2024." This report presents the results of the 2023 Long-Term Management (LTM) performed at the Former Nikolski Radio Relay Station.

Axl LeVan

7/15/2024

Document, Report, or Work plan Review - other

DEC reviewed and approved the "Draft Final 2023 Land Use/Institutional Controls and Long-Term Management Report, Nikolski Radio Relay Station, Alaska, July 2024." based on updates addressing DEC comments on the draft. The report documents long term management at LF001, OT001, SA593, SS003, SS004, SS010, TU019, and WP007.

Axl LeVan

7/22/2024

Document, Report, or Work plan Review - other

DEC reviewed and provided comments on the draft report "PCB Remedial Investigation/Removal Action, Nikolski Radio Relay Station, Site SS-010, Alaska, April 2024". DEC additionally requested information on whether an ADEC Transport and Approval form had been provided.

Axl LeVan

10/9/2024

Compliance Advisory Letter

DEC sent a Compliance Advisory Letter regarding a failure to follow approved workplans and regulations at Eielson Air Force Base (EAFB) and Nikolski Long Range Radar Station (LRRS). At EAFB this occurred with work related to the Installation Wide Monitoring Program. At Nikolski LRRS the work was associated with the PCB removal action at SS010. In both projects contaminated soils and/or water were transported from the site without DEC approval in the form of a signed "Contaminated Media Transport and Treatment or Disposal Approval Form".

Axl LeVan

11/4/2024

Document, Report, or Work plan Review - other

DEC reviewed and approved the "Final Report, PCB Remedial Investigation/Removal Action, Nikolski Radio Relay Station, Site SS-010, Alaska, October 2024". This report presents polychlorinated biphenyl (PCB) remedial investigation (RI) and removal action (RA) at the Former Transformer Building and White Alice Antenna Array (Site SS-010/OT010)

Axl LeVan

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Site Report: Nikolski RRS OT010

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State of Alaska Department of Environmental Conservation