Site Report: IHS Kanakanak Hospital - Area 3 STP

Site Name:	IHS Kanakanak Hospital - Area 3 STP
Address:	6000 Kanakanak Road, Demolished Old Sewage Treatment Plant, Dillingham, AK 99576
File Number:	2540.38.005
Hazard ID:	4442
Status:	Cleanup Complete - Institutional Controls
Staff:	Tim Sharp, 9074512131 tim.sharp@alaska.gov
Latitude:	59.001244
Longitude:	-158.535398
Horizontal Datum:	WGS84

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

Fuel oil contamination from historical above-ground fuel storage tanks in vicinity of the former sewage treatment plant. 4,000 cubic yards of contaminated soil were excavated and placed in landfarm (Area 10) between 2001 and 2005. No free product was found in monitoring wells N-AP-100 or N-AP-121 installed in this area in 2006. These wells were sampled for GRO, DRO, RRO, VOCs, and PAHs. Benzene, DRO, and GRO exceeding groundwater cleanup levels were detected in groundwater in monitoring well N-AP-121. Soils from N-AP=100 and N-AP-121 were analyzed for DRO and BTEX; DRO exceeded alternate cleanup levels. Potential sources of contamination at Area 3 include a 21,000 -gallon underground storage tank and/or a 30,000-gallon above ground storage tank. Both tanks have been removed. DRO exceeds the maximum allowable contamination at around 10-11 feet below ground surface. DEC rescinded the alternate cleanup levels in 2020.

Action Information

Action Date	Action	Description	DEC Staff
8/7/2007	Site Added to Database	Site added to the database.	Mitzi Read
10/23/2008	Exposure Tracking Model Ranking	Initial ranking with ETM completed for source area id: 75429 name: IHS Kanakanak Hospital - Area 3	Kim DeRuyter
1/8/2009	Document, Report, or Work plan Review - other	Site Characterization workplan approved. Three downgradient monitoring wells will be installed in summer '09.	Kim DeRuyter
5/22/2014	Update or Other Action	Kanakanak Hospital UVOST Soil Characterization Work Plan submitted. The work plan proposes using Laser Induced Fluorescence/Utltraviolet Optical Screening Tool (LIF/UVOST) screening methods for soil characterization of Areas 3, 4, 8, 9, and 11 at the Kanakanak Hospital site.	Meredith Savage
2/9/2015	Update or Other Action	Received two reports for review: Kanakanak Hospital Dental Clinic and Administrative Offices Vapor Intrusion Mitigation Design, and Contaminated Soil Materials Management Plan.	Meredith Savage
4/1/2015	Document, Report, or Work plan Review - other	The Alaska Department of Environmental Conservation (ADEC) received a report titled Contaminated Soil Materials Management Plan, Dental Clinic and Administrative Offices on April 1, 2015. The report provides details on how excavated soil will be handled during construction of the Kanakanak Dental Clinic and Administrative offices. The clinic will be constructed within Area 3 of the hospital complex, a known area of petroleum hydrocarbon contaminated soils. Although extensive remediation has occurred within this area, contamination remains within the groundwater smear zone. To address the potential for encountering contaminated soils and to help ensure that unacceptable exposure does not occur during construction, all excavation activities will be monitored for signs of soil contamination, excavated soil will be field screened, and potentially contaminated soil will be stockpiled. A multi-incremental sample will be collected from the base of the excavation to document any potential residual contamination; the sample will be analyzed for diesel range organics (DRO), residual range organics (RRO), gasoline range organics (GRO), polycyclic aromatic hydrocarbons (PAH), and benzene, toluene, ethylbenzene, and xylenes (BTEX). Samples will also be taken from the stockpiled soil and any contaminated soil will be landfarmed onsite within the remedial treatment area (RTA) or an alternative onsite location if the RTA is not available.	Meredith Savage
4/17/2015	Document, Report, or Work plan Review - other	The Alaska Department of Environmental Conservation (ADEC) received a report titled Vapor Intrusion Mitigation Design, Dental Clinic and Administrative Offices on April 7, 2015. The report describes the measures being taken to address the potential for vapor intrusion migration into the new dental clinic and administrative offices building proposed for construction in 2015. The building is to be constructed within Area 3 of the Kanakanak Hospital campus, an area known to have petroleum contamination remaining in the soil-groundwater interface zone. An earlier report dealt with management of any contaminated soils encountered during excavation of the building foundation. This report details the five design factors being used to mitigate the potential for vapor intrusion into the new building: placement of a subsurface vapor barrier, placement of structural fill, installation of a vapor venting, sub-building depressurization system, use of mechanical mitigation measures such a building pressure differentials, and the monitoring of crawlspace air and near foundation soil gas. Following installation and set-up of the vapor intrusion mitigation system it will be tested and monitored to maintain proper system operation and to verify that the remedial action objectives for the building are being achieved.	Meredith Savage
4/23/2015	Exposure Tracking Model Ranking	A new updated ranking with ETM has been completed for source area 75429 IHS Kanakanak Hospital - Area 3.	Meredith Savage
5/14/2015	Cleanup Complete Determination Issued	DEC has issued a determination of Cleanup Complete with Institutional Controls (ICs) for Area 3 of the Kanakanak Hospital Complex. No further remedial action will be required for Area 3 as long as compliance with the IC conditions is maintained.	Meredith Savage
8/7/2015	Update or Other Action	Transferred to Fairbanks	Susan Carberry
8/13/2015	Site Visit	Conducted site investigation of Areas 3, 5, 10, and 12 and all monitoring wells. Work at Areas 3 and 12 is going according to plan. Area 10 remedial treatment area (RTA) has completed 8 tilling events according to the work plan but additional tilling events will be required because soil has not yet reached alternative cleanup levels (ACLs). Area 5 excavation has contaminated soil that needs to be excavated, but the area is too wet for equipment due to consistent flow of water from building footer drain. Drain should be diverted, which will hopefully allow water to subside and excavation activities to continue.	Joy Whitsel
2/2/2016	Institutional Control Update	DEC approved the final report titled "Dental Clinic and Administration Offices Cleanup Report." The report describes how excavated soil was handled during construction of the Kanakanak Dental Clinic and Administrative offices, in accordance with agreed upon Institutional Controls. Contaminated soil was segregated from clean soil based on field screening and was either placed in Area 10 Remediation Treatment Area (RTA) for landfarming or was stockpiled in Area 12 for landfarming within 24 months of excavation. Clean material (i.e., soil with in-situ PID readings < 20 ppm) was placed in a stockpile to the south of the parking lot south of Area 11, or in a stockpile to the south of Area 10. Multi-incremental sampling was conducted to assess soil contaminant levels remaining at the base of the excavation, and results for all analytes were below Alternative Cleanup Levels established for the site.	Joy Whitsel
10/19/2016	Site Characterization Workplan Approved	DEC approved the Kanakanak Hospital Monitoring Work Plan. The work plan describes monitoring to be conducted on the Dental Clinic and Administrative Office (DAO) footer drain, the Building 401 footer drain, vapor intrusion system performance monitoring of the DAO, and multi-increment sampling from the Remediation Treatment Area at the Kanakanak Hospital campus in Dillingham, Alaska.	Joy Whitsel
9/28/2017	Site Visit	DEC conducted a site visit of Kanakanak Hospital, focusing on the vapor mitigation measures taken at the DAO (Area 3), regrading of Area 5 and cleaning of the oil water separator, construction of the Area 6 landfarm, the adjacent Area 12 landfarm, and the Area 10 landfarm. A trip report documenting observations recorded during the site visit was provided to IHS and BBAHC. In general, all work was proceeding according to the applicable work plans and was protective of human health and the environment. One exception was the lack of berms present around the Area 10 landfarm to prevent runoff of contaminated soil. A letter was sent to IHS requesting corrective action.	Joy Whitsel
10/4/2017	Institutional Control Periodic Reporting	Provided results of 2016 vapor intrusion monitoring. No contaminants of concern were above benchmark levels.	Joy Whitsel
8/2/2018	Document, Report, or Work plan Review - other	DEC approved the 2016 Fall Kanakanak Hospital Monitoring Report, dated July 23, 2018. The report describes monitoring activities at Area 5 (monitoring the footer drain from Building 401), Area 3 (vapor intrusion system performance monitoring for the Dental and Administrative Offices), and Area 10 (multi-incremental sampling at the landfarm). The 2016 report recommends the Oil-Water Separator be cleaned to prevent sediment from accumulating in the Bldg 401 footer drain. Vapor intrusion results from the Dental and Administrative Offices (DAO) were below the commercial indoor air target levels for volatile organic compounds (VOCs). Multi-incremental results at Area 10 indicated the fifth layer of contaminated soil has been treated to contaminant levels below the alternate cleanup level for diesel range organics (DRO). Concentrations still remain above 18 AAC 75 Table B2 values. Monitoring of these areas is expected to continue.	Erica Blake
8/2/2018	Document, Report, or Work plan Review - other	DEC approved the February 2018 Kanakanak Hospital Monitoring Report, dated July 23, 2018. The report describes activities conducted on October 17, 2017 and February 6-12, 2018. Activities conducted on October 17, 2017 included collecting one analytical sample from the footer drain of the main hospital building (Building 401). Activities conducted February 6-12, 2018 included; soil removal and sample collection from Area 5, baseline multi-incremental sampling from Area 6 and Area 10, analytical groundwater sampling from monitoring wells around the hospital building, collecting indoor air samples from the Dental and Administrative Offices (DAO) building (Area 3), collecting a soil gas sample from the vapor monitoring point south of the DAO building, and collecting an analytical sample from the outfall of the oil-water separator (OWS) for physical and chemical parameter analysis. Monitoring at these areas is expected to continue.	Erica Blake
5/8/2020	Update or Other Action	DEC conducted a teleconference with IHS, BBAHC, and ERM representatives for the site. Discussed summary of site. Additionally, clarified that the Alternative Cleanup Levels (ACLs) from 1998 would no longer apply as regulations have been introduced that are more stringent than these values. DEC will send a formal letter explaining the decision to rescind old cleanup levels and clarifying applications of newer levels as detailed in 18 AAC 75.340 and 345.	Tim Sharp
7/21/2020	Update or Other Action	Due to numerous regulatory changes, updated toxicological information, and groundwater impacts at the site, the 1998 ACLs previously accepted by DEC have been rescinded. The contaminated sites at Kanakanak Hospital are subject to the “site cleanup rules”, 18 AAC 75.325 – 18 AAC 75.390. Thus, in lieu of the 1998 ACLs, the currently promulgated cleanup levels in 18 AAC 75 apply. For contaminants in soil, the Human Health, Maximum Allowable, and Migration to Groundwater cleanup levels apply, as listed in Tables B1 and B2 of 18 AAC 75.341. For contaminants in groundwater, the Groundwater Cleanup Levels in Table C of 18 AAC 74.345 apply. Sites that were previously categorized as 'Cleanup Complete' or 'Cleanup Complete with Institutional Controls' may be subject to further review. DEC has sent a formal letter to IHS and BBAHC representatives explaining this change.	Tim Sharp
8/17/2020	Document, Report, or Work plan Review - other	DEC supplied comments for the Site Wide IC Management Plan. The IC MP details the history of each area of concern at the site and the specific ICs in place for each of the closed sites with ICs. Due to the rescission of the 1998 ACLs, DEC requested each AOC be analyzed by IHS to determine if the ICs are still protective of human health and the environment. Other comments call attention to potentially complete pathways to consider, and further monitoring of groundwater at landfarms.	Tim Sharp
9/21/2020	Update or Other Action	DEC received the Draft Plan to Develop ACLs at Kanakanak Hospital Memo. The RP has chosen to use the hydrocarbon risk calculator to develop new ACLs. The methods listed include using previous data for Toc values, while collecting new samples for EPH/VPH analysis. Conservative values will be used for bulk density, aquifer thickness, and porosity. A list of data gaps involving drill rig mobilization is also included.	Tim Sharp
10/23/2020	Document, Report, or Work plan Review - other	DEC provided comments for the Draft Plan to Develop ACLs Memo. Comments regarded including figures for sampling locations, methodology clarification, and bringing attention to data gaps that would require a drill rig to close (Area 3 and 7 MAC exceedances).	Tim Sharp
5/4/2022	Site Characterization Workplan Approved	DEC Accepted the Final Kanakanak Supplemental Site Investigation Work Plan. Soil and groundwater samples will be collected at eight areas of concern (AOCs), which will be used to assist in characterizing contamination at the site, as well as developing site-specific alternative cleanup levels (ACLs).	Tim Sharp
7/19/2022	Site Visit	DEC performed a site visit for all areas of concern on the Kanakanak Hospital campus. As part of the site visit, IHS, BBAHC, ERM and DEC held a meeting to discuss the proposed next steps at the site to evaluate remaining contamination and potential transfer of property from IHS to BBAHC.	Tim Sharp
1/3/2023	Document, Report, or Work plan Review - other	DEC reviewed and submitted comments for the Proposed Alternative Cleanup Levels Memo for Kanakanak Hospital. The Memo proposes new alternative cleanup levels (ACLs) intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. ACLs were developed using the Hydrocarbon Risk Calculator (HRC) as allowed under 18 AAC 75.340 (d) – (f). The ACLs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed ACLs given the three- and four-phase calculations conducted using new and historical site-specific data.	Tim Sharp
3/24/2023	Document, Report, or Work plan Review - other	DEC approved the Proposed Preliminary Remediation Goals (PRGs) based on Hydrocarbon Risk Calculator (HRC) Calculations Tech Memo for Kanakanak Hospital in Dillingham. The tech memo proposes new PRGs intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. PRGs were developed using the HRC. The PRGs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed PRGs given the three- and four-phase calculations conducted using new and historical site-specific data. The technical memorandum asserts that the results of the HRC require validation. Upon attaining PRGs in soil at a given area of concern, model validation will be considered complete when measured concentrations in groundwater fall below 18 AAC 75.345(b), Table C groundwater cleanup values in at least two successive sampling events, accounting for seasonal variability. If these values cannot be attained, reassessment of the PRGs may be appropriate to adjust them downwards.	Tim Sharp
8/25/2023	Document, Report, or Work plan Review - other	DEC completed a review of the Draft Supplemental Site Investigation Report. The SI Report details soil and groundwater sampling at eight areas of concern (AOCs) at the Indian Health Service (IHS) Kanakanak Hospital Site. These samples are being used to assist in characterizing contamination at the site, and are being evaluated in tandem with the recent preliminary remediation goals (PRGs) identified in the Proposed Preliminary Remediation Goals based on Hydrocarbon Risk Calculator Calculations memorandum, approved by DEC. Future review of previously closed sites is recommended, and a feasibility study will be prepared for evaluation of remediation options.	Tim Sharp

Action Date

Action

Description

DEC Staff

8/7/2007

Site Added to Database

Site added to the database.

Mitzi Read

10/23/2008

Exposure Tracking Model Ranking

Initial ranking with ETM completed for source area id: 75429 name: IHS Kanakanak Hospital - Area 3

Kim DeRuyter

1/8/2009

Document, Report, or Work plan Review - other

Site Characterization workplan approved. Three downgradient monitoring wells will be installed in summer '09.

Kim DeRuyter

5/22/2014

Update or Other Action

Kanakanak Hospital UVOST Soil Characterization Work Plan submitted. The work plan proposes using Laser Induced Fluorescence/Utltraviolet Optical Screening Tool (LIF/UVOST) screening methods for soil characterization of Areas 3, 4, 8, 9, and 11 at the Kanakanak Hospital site.

Meredith Savage

2/9/2015

Update or Other Action

Received two reports for review: Kanakanak Hospital Dental Clinic and Administrative Offices Vapor Intrusion Mitigation Design, and Contaminated Soil Materials Management Plan.

Meredith Savage

4/1/2015

Document, Report, or Work plan Review - other

The Alaska Department of Environmental Conservation (ADEC) received a report titled Contaminated Soil Materials Management Plan, Dental Clinic and Administrative Offices on April 1, 2015. The report provides details on how excavated soil will be handled during construction of the Kanakanak Dental Clinic and Administrative offices. The clinic will be constructed within Area 3 of the hospital complex, a known area of petroleum hydrocarbon contaminated soils. Although extensive remediation has occurred within this area, contamination remains within the groundwater smear zone. To address the potential for encountering contaminated soils and to help ensure that unacceptable exposure does not occur during construction, all excavation activities will be monitored for signs of soil contamination, excavated soil will be field screened, and potentially contaminated soil will be stockpiled. A multi-incremental sample will be collected from the base of the excavation to document any potential residual contamination; the sample will be analyzed for diesel range organics (DRO), residual range organics (RRO), gasoline range organics (GRO), polycyclic aromatic hydrocarbons (PAH), and benzene, toluene, ethylbenzene, and xylenes (BTEX). Samples will also be taken from the stockpiled soil and any contaminated soil will be landfarmed onsite within the remedial treatment area (RTA) or an alternative onsite location if the RTA is not available.

Meredith Savage

4/17/2015

Document, Report, or Work plan Review - other

The Alaska Department of Environmental Conservation (ADEC) received a report titled Vapor Intrusion Mitigation Design, Dental Clinic and Administrative Offices on April 7, 2015. The report describes the measures being taken to address the potential for vapor intrusion migration into the new dental clinic and administrative offices building proposed for construction in 2015. The building is to be constructed within Area 3 of the Kanakanak Hospital campus, an area known to have petroleum contamination remaining in the soil-groundwater interface zone. An earlier report dealt with management of any contaminated soils encountered during excavation of the building foundation. This report details the five design factors being used to mitigate the potential for vapor intrusion into the new building: placement of a subsurface vapor barrier, placement of structural fill, installation of a vapor venting, sub-building depressurization system, use of mechanical mitigation measures such a building pressure differentials, and the monitoring of crawlspace air and near foundation soil gas. Following installation and set-up of the vapor intrusion mitigation system it will be tested and monitored to maintain proper system operation and to verify that the remedial action objectives for the building are being achieved.

Meredith Savage

4/23/2015

Exposure Tracking Model Ranking

A new updated ranking with ETM has been completed for source area 75429 IHS Kanakanak Hospital - Area 3.

Meredith Savage

5/14/2015

Cleanup Complete Determination Issued

DEC has issued a determination of Cleanup Complete with Institutional Controls (ICs) for Area 3 of the Kanakanak Hospital Complex. No further remedial action will be required for Area 3 as long as compliance with the IC conditions is maintained.

Meredith Savage

8/7/2015

Update or Other Action

Transferred to Fairbanks

Susan Carberry

8/13/2015

Site Visit

Conducted site investigation of Areas 3, 5, 10, and 12 and all monitoring wells. Work at Areas 3 and 12 is going according to plan. Area 10 remedial treatment area (RTA) has completed 8 tilling events according to the work plan but additional tilling events will be required because soil has not yet reached alternative cleanup levels (ACLs). Area 5 excavation has contaminated soil that needs to be excavated, but the area is too wet for equipment due to consistent flow of water from building footer drain. Drain should be diverted, which will hopefully allow water to subside and excavation activities to continue.

Joy Whitsel

2/2/2016

Institutional Control Update

DEC approved the final report titled "Dental Clinic and Administration Offices Cleanup Report." The report describes how excavated soil was handled during construction of the Kanakanak Dental Clinic and Administrative offices, in accordance with agreed upon Institutional Controls. Contaminated soil was segregated from clean soil based on field screening and was either placed in Area 10 Remediation Treatment Area (RTA) for landfarming or was stockpiled in Area 12 for landfarming within 24 months of excavation. Clean material (i.e., soil with in-situ PID readings < 20 ppm) was placed in a stockpile to the south of the parking lot south of Area 11, or in a stockpile to the south of Area 10. Multi-incremental sampling was conducted to assess soil contaminant levels remaining at the base of the excavation, and results for all analytes were below Alternative Cleanup Levels established for the site.

Joy Whitsel

10/19/2016

Site Characterization Workplan Approved

DEC approved the Kanakanak Hospital Monitoring Work Plan. The work plan describes monitoring to be conducted on the Dental Clinic and Administrative Office (DAO) footer drain, the Building 401 footer drain, vapor intrusion system performance monitoring of the DAO, and multi-increment sampling from the Remediation Treatment Area at the Kanakanak Hospital campus in Dillingham, Alaska.

Joy Whitsel

9/28/2017

Site Visit

DEC conducted a site visit of Kanakanak Hospital, focusing on the vapor mitigation measures taken at the DAO (Area 3), regrading of Area 5 and cleaning of the oil water separator, construction of the Area 6 landfarm, the adjacent Area 12 landfarm, and the Area 10 landfarm. A trip report documenting observations recorded during the site visit was provided to IHS and BBAHC. In general, all work was proceeding according to the applicable work plans and was protective of human health and the environment. One exception was the lack of berms present around the Area 10 landfarm to prevent runoff of contaminated soil. A letter was sent to IHS requesting corrective action.

Joy Whitsel

10/4/2017

Institutional Control Periodic Reporting

Provided results of 2016 vapor intrusion monitoring. No contaminants of concern were above benchmark levels.

Joy Whitsel

8/2/2018

Document, Report, or Work plan Review - other

DEC approved the 2016 Fall Kanakanak Hospital Monitoring Report, dated July 23, 2018. The report describes monitoring activities at Area 5 (monitoring the footer drain from Building 401), Area 3 (vapor intrusion system performance monitoring for the Dental and Administrative Offices), and Area 10 (multi-incremental sampling at the landfarm). The 2016 report recommends the Oil-Water Separator be cleaned to prevent sediment from accumulating in the Bldg 401 footer drain. Vapor intrusion results from the Dental and Administrative Offices (DAO) were below the commercial indoor air target levels for volatile organic compounds (VOCs). Multi-incremental results at Area 10 indicated the fifth layer of contaminated soil has been treated to contaminant levels below the alternate cleanup level for diesel range organics (DRO). Concentrations still remain above 18 AAC 75 Table B2 values. Monitoring of these areas is expected to continue.

Erica Blake

8/2/2018

Document, Report, or Work plan Review - other

DEC approved the February 2018 Kanakanak Hospital Monitoring Report, dated July 23, 2018. The report describes activities conducted on October 17, 2017 and February 6-12, 2018. Activities conducted on October 17, 2017 included collecting one analytical sample from the footer drain of the main hospital building (Building 401). Activities conducted February 6-12, 2018 included; soil removal and sample collection from Area 5, baseline multi-incremental sampling from Area 6 and Area 10, analytical groundwater sampling from monitoring wells around the hospital building, collecting indoor air samples from the Dental and Administrative Offices (DAO) building (Area 3), collecting a soil gas sample from the vapor monitoring point south of the DAO building, and collecting an analytical sample from the outfall of the oil-water separator (OWS) for physical and chemical parameter analysis. Monitoring at these areas is expected to continue.

Erica Blake

5/8/2020

Update or Other Action

DEC conducted a teleconference with IHS, BBAHC, and ERM representatives for the site. Discussed summary of site. Additionally, clarified that the Alternative Cleanup Levels (ACLs) from 1998 would no longer apply as regulations have been introduced that are more stringent than these values. DEC will send a formal letter explaining the decision to rescind old cleanup levels and clarifying applications of newer levels as detailed in 18 AAC 75.340 and 345.

Tim Sharp

7/21/2020

Update or Other Action

Due to numerous regulatory changes, updated toxicological information, and groundwater impacts at the site, the 1998 ACLs previously accepted by DEC have been rescinded. The contaminated sites at Kanakanak Hospital are subject to the “site cleanup rules”, 18 AAC 75.325 – 18 AAC 75.390. Thus, in lieu of the 1998 ACLs, the currently promulgated cleanup levels in 18 AAC 75 apply. For contaminants in soil, the Human Health, Maximum Allowable, and Migration to Groundwater cleanup levels apply, as listed in Tables B1 and B2 of 18 AAC 75.341. For contaminants in groundwater, the Groundwater Cleanup Levels in Table C of 18 AAC 74.345 apply. Sites that were previously categorized as 'Cleanup Complete' or 'Cleanup Complete with Institutional Controls' may be subject to further review. DEC has sent a formal letter to IHS and BBAHC representatives explaining this change.

Tim Sharp

8/17/2020

Document, Report, or Work plan Review - other

DEC supplied comments for the Site Wide IC Management Plan. The IC MP details the history of each area of concern at the site and the specific ICs in place for each of the closed sites with ICs. Due to the rescission of the 1998 ACLs, DEC requested each AOC be analyzed by IHS to determine if the ICs are still protective of human health and the environment. Other comments call attention to potentially complete pathways to consider, and further monitoring of groundwater at landfarms.

Tim Sharp

9/21/2020

Update or Other Action

DEC received the Draft Plan to Develop ACLs at Kanakanak Hospital Memo. The RP has chosen to use the hydrocarbon risk calculator to develop new ACLs. The methods listed include using previous data for Toc values, while collecting new samples for EPH/VPH analysis. Conservative values will be used for bulk density, aquifer thickness, and porosity. A list of data gaps involving drill rig mobilization is also included.

Tim Sharp

10/23/2020

Document, Report, or Work plan Review - other

DEC provided comments for the Draft Plan to Develop ACLs Memo. Comments regarded including figures for sampling locations, methodology clarification, and bringing attention to data gaps that would require a drill rig to close (Area 3 and 7 MAC exceedances).

Tim Sharp

5/4/2022

Site Characterization Workplan Approved

DEC Accepted the Final Kanakanak Supplemental Site Investigation Work Plan. Soil and groundwater samples will be collected at eight areas of concern (AOCs), which will be used to assist in characterizing contamination at the site, as well as developing site-specific alternative cleanup levels (ACLs).

Tim Sharp

7/19/2022

Site Visit

DEC performed a site visit for all areas of concern on the Kanakanak Hospital campus. As part of the site visit, IHS, BBAHC, ERM and DEC held a meeting to discuss the proposed next steps at the site to evaluate remaining contamination and potential transfer of property from IHS to BBAHC.

Tim Sharp

1/3/2023

Document, Report, or Work plan Review - other

DEC reviewed and submitted comments for the Proposed Alternative Cleanup Levels Memo for Kanakanak Hospital. The Memo proposes new alternative cleanup levels (ACLs) intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. ACLs were developed using the Hydrocarbon Risk Calculator (HRC) as allowed under 18 AAC 75.340 (d) – (f). The ACLs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed ACLs given the three- and four-phase calculations conducted using new and historical site-specific data.

Tim Sharp

3/24/2023

Document, Report, or Work plan Review - other

DEC approved the Proposed Preliminary Remediation Goals (PRGs) based on Hydrocarbon Risk Calculator (HRC) Calculations Tech Memo for Kanakanak Hospital in Dillingham. The tech memo proposes new PRGs intended to be protective of human health, safety, welfare, and the environment for “residential land use” as described in 18 AAC 75.990. PRGs were developed using the HRC. The PRGs were established to reflect fate and transport properties, toxicity characteristics, and potential exposure routes of contaminants at the site. Diesel range organics (DRO), benzene, ethylbenzene, ethylene glycol, naphthalene, tetrachloroethene, 1,2,3-trichlorobenzene, and 1-methylnaphthalene all have new proposed PRGs given the three- and four-phase calculations conducted using new and historical site-specific data. The technical memorandum asserts that the results of the HRC require validation. Upon attaining PRGs in soil at a given area of concern, model validation will be considered complete when measured concentrations in groundwater fall below 18 AAC 75.345(b), Table C groundwater cleanup values in at least two successive sampling events, accounting for seasonal variability. If these values cannot be attained, reassessment of the PRGs may be appropriate to adjust them downwards.

Tim Sharp

8/25/2023

Document, Report, or Work plan Review - other

DEC completed a review of the Draft Supplemental Site Investigation Report. The SI Report details soil and groundwater sampling at eight areas of concern (AOCs) at the Indian Health Service (IHS) Kanakanak Hospital Site. These samples are being used to assist in characterizing contamination at the site, and are being evaluated in tandem with the recent preliminary remediation goals (PRGs) identified in the Proposed Preliminary Remediation Goals based on Hydrocarbon Risk Calculator Calculations memorandum, approved by DEC. Future review of previously closed sites is recommended, and a feasibility study will be prepared for evaluation of remediation options.

Tim Sharp

Contaminant Information

Name	Level Description	Media	Comments
DRO	> Table C	Groundwater
DRO	Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation	Soil	Diesel contamination resulting from former above ground storage tanks. Soil was excavated to a depth of 12 feet bgs, but contamination remains below that depth.

Name

Level Description

Media

Comments

DRO

> Table C

Groundwater

DRO

Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation

Soil

Diesel contamination resulting from former above ground storage tanks. Soil was excavated to a depth of 12 feet bgs, but contamination remains below that depth.

Control Type

Type	Details
Notice of Environmental Contamination	Filed with Bristol Bay Recording District 307

Type

Details

Notice of Environmental Contamination

Filed with Bristol Bay Recording District 307

Requirements

Description	Details
Excavation / Soil Movement Restrictions	1. Soils must be managed at Area 3 in accordance with the Contaminated Soil Materials Management Plan, March 2015 developed for the proposed 2015 construction of the Dental Clinic and Administrative Offices. 2. Routine excavation of soil to depths less than 10 feet bgs will be allowed without ADEC notification, but all site workers must be briefed regarding the potential for encountering contaminated soils. If contaminated soils are encountered, ADEC will be notified according to procedures outlined in 18 AAC 75.300, and the contaminated soils will be segregated and stored so as to prevent the spread of contamination. Analytical samples of the excavated soil will be collected and compared to ADEC-approved ACLs for the site. If contaminant concentrations exceed these values, impacted soil will be stored and treated or disposed of in accordance with 18 AAC 75.370. ADEC may require additional excavation and soil treatment or disposal as necessary to protect human health.
New Construction Restrictions	1. ADEC must be provided a work plan for any excavation of soil at depths of 10 feet bgs and deeper and for any excavation for construction of structures that will be regularly inhabited. 2. The building design for any enclosed area proposed for construction within Area 3 must address vapor intrusion concerns and a copy sent to ADEC for review.
Groundwater Use Restrictions	No drinking water wells may be installed in Area 3 and the shallow groundwater should not be used for consumption or any other purpose.
Groundwater Monitoring	The Alaska Area Native Health Service will continue groundwater monitoring at wells AP-100 and AP-121, or approved alternate wells, as part of the 2016 site-wide monitoring event and will continue groundwater monitoring in Area 3 until COC concentrations remain below cleanup levels for at least two consecutive sampling events.
Groundwater Monitoring	Within one year after Condition #7 has been met all groundwater monitoring wells, operating or damaged beyond repair, will be decommissioned in accordance with ADEC guidance, and well decommissioning documentation submitted to ADEC.
Other	ADEC must be informed of any change of ownership and/or land use status within three months of the transfer. Upon change of ownership, wholly or in part, these conditions/institutional controls will be made part of the Quitclaim Deed or other land transfer documents.
Excavation / Soil Movement Restrictions	Pursuant to 18 AAC 75.325(i)(1) and (2), DEC approval is required prior to moving soil or groundwater that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370. At this site, in the future, if soil is removed from the site or groundwater is brought to the surface (for example to dewater in support of construction) it must be characterized and managed following regulations applicable at that time.
Other	Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)

Description

Details

Excavation / Soil Movement Restrictions

1. Soils must be managed at Area 3 in accordance with the Contaminated Soil Materials Management Plan, March 2015 developed for the proposed 2015 construction of the Dental Clinic and Administrative Offices. 2. Routine excavation of soil to depths less than 10 feet bgs will be allowed without ADEC notification, but all site workers must be briefed regarding the potential for encountering contaminated soils. If contaminated soils are encountered, ADEC will be notified according to procedures outlined in 18 AAC 75.300, and the contaminated soils will be segregated and stored so as to prevent the spread of contamination. Analytical samples of the excavated soil will be collected and compared to ADEC-approved ACLs for the site. If contaminant concentrations exceed these values, impacted soil will be stored and treated or disposed of in accordance with 18 AAC 75.370. ADEC may require additional excavation and soil treatment or disposal as necessary to protect human health.

New Construction Restrictions

1. ADEC must be provided a work plan for any excavation of soil at depths of 10 feet bgs and deeper and for any excavation for construction of structures that will be regularly inhabited. 2. The building design for any enclosed area proposed for construction within Area 3 must address vapor intrusion concerns and a copy sent to ADEC for review.

Groundwater Use Restrictions

No drinking water wells may be installed in Area 3 and the shallow groundwater should not be used for consumption or any other purpose.

Groundwater Monitoring

The Alaska Area Native Health Service will continue groundwater monitoring at wells AP-100 and AP-121, or approved alternate wells, as part of the 2016 site-wide monitoring event and will continue groundwater monitoring in Area 3 until COC concentrations remain below cleanup levels for at least two consecutive sampling events.

Groundwater Monitoring

Within one year after Condition #7 has been met all groundwater monitoring wells, operating or damaged beyond repair, will be decommissioned in accordance with ADEC guidance, and well decommissioning documentation submitted to ADEC.

Other

ADEC must be informed of any change of ownership and/or land use status within three months of the transfer. Upon change of ownership, wholly or in part, these conditions/institutional controls will be made part of the Quitclaim Deed or other land transfer documents.

Excavation / Soil Movement Restrictions

Pursuant to 18 AAC 75.325(i)(1) and (2), DEC approval is required prior to moving soil or groundwater that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370. At this site, in the future, if soil is removed from the site or groundwater is brought to the surface (for example to dewater in support of construction) it must be characterized and managed following regulations applicable at that time.

Other

Movement or use of contaminated material (including on site) in a manner that results in a violation of the water quality standards is prohibited (18 AAC 70)

Kanakanak Area 3 Site Closure Letter

Notice of Environmental Contamination

No associated sites were found.

Missing Location Data

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Site Report: IHS Kanakanak Hospital - Area 3 STP

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

Kanakanak Area 3 Site Closure Letter

Notice of Environmental Contamination

Missing Location Data

State of Alaska Department of Environmental Conservation