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Site Report: IHS Kanakanak Hospital - Area 9

Site Name: IHS Kanakanak Hospital - Area 9
Address: 6000 Kanakanak Road, Loading Dock Between Bldgs 401 & 301, Dillingham, AK 99576
File Number: 2540.38.005
Hazard ID: 4444
Status: Active
Staff: Tim Sharp, 9074512131 tim.sharp@alaska.gov
Latitude: 59.000036
Longitude: -158.535707
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.

Problems/Comments

Fuel oil contamination from several large historical above-ground fuel storage tanks in the vicinity of the loading dock between hospital building 401 and administration building 301. PCE exceeding cleanup levels has also been detected in the groundwater. Excavation of contaminated soil is not considered appropriate because of the density of the utility conflicts in Area 9 and adjoining Area 4. Monitoring wells 04-MW-02, 04-MW-09, N-04-MW-10, and AP-123 were sampled for GRO, DRO, RRO, VOCs, and PAHs. Benzene, GRO, DRO, and RRO exceeding groundwater cleanup levels were detected in N-04-MW-10. PCE exceeding the groundwater cleanup level was detected in AP-123. A soil gas survey completed in 2005 provided further contaminant delineation and characterization.

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: 75431 name: Kanakanak Hospital - Area 9 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
8/7/2015 Update or Other Action Transfer to Fairbanks Susan Carberry
9/22/2017 Update or Other Action DEC approved all responses to comments for the tech memo evaluating cleanup alternatives at Areas 4, 8, 9, and 11 and concurs with the recommended remedial alternatives. DEC will approve the tech memo as final upon receipt of the final draft and backchecking that all responses to comments were incorporated into the text. Joy Whitsel
5/21/2019 Update or Other Action DEC reviewed a closure request memorandum for Kanakanak Hospital Areas 4, 8, and 9. Diesel range organics (DRO), tetrachloroethene (PCE), and polycyclic aromatic hydrocarbons (PAH) contamination within the areas requested for closure continue to exceed cleanup levels. These areas are currently subject to long-term monitoring and institutional controls as a remedial action. DEC has determined that Areas 4, 8, and 9 are not eligible for closure with institutional controls at this time. This determination is based on three primary considerations: 1) DEC has determined that the Kanakanak Hospital does not meet the requirements for a groundwater use exemption under 18 AAC 75.350; 2) contaminant levels in soil and groundwater continue to exceed cleanup levels, and 3) there is insufficient evidence to indicate that contaminant concentrations in groundwater are decreasing. Table 1 in the above-referenced document provides a summation of the various site closure criteria. In the enclosed comment table, DEC has provided specific comments on many of the Table 1 entries. DEC understands that site closure was requested in order to facilitate a proposed transfer of the property. Although DEC cannot support a closure with institutional controls at this time. Kevin Fraley
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

Control Type

Type Details

Requirements

Description Details

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