| Action Date |
Action |
Description |
DEC Staff |
| 7/1/1980 |
Site Added to Database |
CERCLIS Database: M & M Enterprises (NFRAP) - Discovery completed 7/1/1980; EPA Preliminary Assessment completed 9/28/1984; Site Inspection completed 11/09/1988; Site Inspection completed 9/20/1990; and archived site on 9/20/1990. |
Ron Klein |
| 9/24/1980 |
Site Visit |
Site inspection by Ecology & Environment, Inc. (U.S. EPA contractor).
|
Amy Rodman |
| 8/31/1984 |
Document, Report, or Work plan Review - other |
"M&M Enterprises, Anchorage: Potential Hazardous Waste Site Preliminary Assessment" dated August 31, 1984 by TetraTech. EPA ID #AK-D0980664981. Site perimeter survey (windshield inspection summary) conducted on June 14, 1984. Site inspection conducted by TetraTech staff on June 15, 1984. Data gaps noted were disposal practices and soil analysis data. Recommendations: Periodical inspections to ensure proper disposal of spent battery electrolyte solutions; soil sample collection from battery storage area. Potential hazard to environment and/or population: possible soil/surface water aquifer contamination. |
Amy Rodman |
| 7/1/1986 |
Preliminary Assessment Approved |
CERCLA Site Inspection Report, September 1987 by Tryck, Nyman and Hayes (TN&H), Science Applications Int. Corp., and Shannon and Wilson. High lead levels up to 7200 ug/gm. |
Colleen Burgh |
| 4/13/1987 |
Update or Other Action |
Letter to Carl Reller from Tryck Nyman & Hayes RE: Alternate Site Location M&M Enterprises. During our Phase I investigation, TNH reviewed the EPA CERCLIS file and discoverd investigations by EPA contractor personnel at three different sites. The three sites are:
The 620 East International Aiport Road site that was the subject of a Preliminary Assessment conducted by Tetra Tech in 1984 and was assigned a CERCLIS number: AKD980665981.
A residence at 3603 Wyoming Drive owned by Mrs. MacGalliard. She is the owner of M&M Enterprises, the recyling business now located at 620 E. Intl. Rd. According to her, the recycling business was located at her home until 1981. Information in the CERCLIS file indicates that the Wyoming Drive site became a concern because of a neighbor complaints of battery acid flowing off site into a nearby street.
A storage yard located at 3405 Wyoming Drive, the site apparently visited by Ecology and Environment Inc. in 1980 and assigned an EPA site file number of AK-10 016. The map from the CERCLIS file shows that E&E visited a site on the north side of 36th Avenue, having a street number of less than 3600. Either E&E visited the wrong site, or a mistake was made preparing the map.
TNH personnel found a storage yard located at the position shown for the M&M on the map. The storage yard is owned by Mr. James Huffman (Lot 25, Block 7, Woodland Park, Addition #2). E&E personnel may have mistaken the storage yard for the metals recycling yard.
Future investigators should be aware of the differences between the three sites. TNH believes no investigation has ever been made at the MacGalliard's residence, 3603 Wyoming Drive, even though this was the site that generated the original complaint. |
Ron Klein |
| 5/7/1987 |
Update or Other Action |
Letter from ADEC to RP, RE: Superfund Site Investigation - M&M Enterprises (CERCLA AKD 980554981) Draft Report. ADEC provided you with a draft site inspection of the above facility. The inspection was conducted under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), otherwise known as Superfund. Response due to ADEC by June 1, 1987.
ADEC and EPA are currently evaluating the public health and environmental aspects of these findings. If it is determined that actions are needed at the facility to minimize the release of hazardous substances, Superfund policy requires that responsible parties conduct the appropriate actions, such as treatment, capping, removal, etc. Responsible parties may have both joint and several liability and be subject to cost recovery and enforcement actions under State and Federal regulations as a result of this investigation. |
Bill Lamoreaux |
| 12/1/1987 |
Update or Other Action |
EPA inspection summary: M&M Enterprises 3603 Wyoming Drive Anchorage AK 99503. W. Douglas Smith inspected on September 23, 1987 the property. Previous EPA TSCA (PCB) enforcement activity: 9/10/1982- EPA inspection noted no PCBs or PCB items at facility. No Action taken.
Current Inspection: Facilty previously operated as a scrap and salvage yard. No electrical equipment or other evidence of PCBs at facility. Facility does at time take transformer cores from utilities. Inspector noted smell of what he believed to be trichlorobenzene.
Followup by Reviewer (William M. Hedgebeth/EPS): Superfund is aware of site. Preliminary assessment was done in 1984. ADEC has recently done a site investigation-CERCLA has draft report from ADEC but report no yet final and available. Recommend no violation closure letter to facility- no further action by TSCA at this time. |
Ron Klein |
| 7/27/1988 |
Update or Other Action |
ADEC Director sent letter to EPA informing that ADEC would like to be the lead agency, supervising the voluntary cleanup of the site. ADEC intends to use a Compliance Order by Consent (COBC) to ensure adequate site characterization and cleanup. |
Max Schwenne |
| 8/11/1988 |
Update or Other Action |
ADEC sent letter to ANI, regarding M&M Enterprises Site and receipt of August 8, 1988 letter from ANI. ADEC required adequate site assessment prior to removal of materials. ADEC rejects proposal of interim use of the site as a parking lot, until a site assessment has been completed. |
Bruce Erickson |
| 2/15/1989 |
Update or Other Action |
Max Schwenne Environmental Engineer (ADEC) sent Doug Johnson (EPA) letter re: M&M Enterprises. The ADEC has taken the lead in cleanup of the M&M Enterprises Site. The ADEC and Alaska Attorney General Office are currently negotiating the contents of a compliance order by consent with representatives for Hanson Associates, owner of the referenced site.
To ensure comliance with federal guidelines, the ADEC used 40 CFR 761 to determine an appropriate PCB Cleanup level. A 10 ppm cleanup level was selected based on the following sections of 40 CFR 761:
1. The M&M Enterprises site is a "residential/commercial area" and a "nonrestricted access area" as defined in 40 CFR 761.123 (definitions).
2. 40 CFR 761.125(c)(4)(5) requires a soil cleanup level of 10 ppm in nonrestricted access areas. Note that the amount and concentrations of PCB material originally spilled on the site can not be determined so 761.125(b) was not deemed appropriate.
Legal counsel representing Hanson and Associates has objected to the PCB cleanup level of 10 ppm specified in the compliance order. To assist in convincing Hanson Associates that a 10 ppm PCB concentration is both appropriate and necessary, the ADEC requests written verification from the EPA that the M&M site must be cleaned up to 10 ppm PCBs to comply with 40 CFR 761. |
Max Schwenne |
| 3/7/1989 |
Cleanup Level(s) Approved |
EPA (EPA AK Ops. Office) sent letter to ADEC regarding M&M Enterprise Site. The following is in response to your request of February 15, 1989 regarding the determination of appropriate PCB cleanup levels for soil at the M&M Enterprises Site, Anchorge, Alaska.
As I previously stated, I forwarded your request with copies of our files that pertain to M&M to Bill Hedgebeth, Toxic Substances Section Region 10 for clarfication and determination of the cleanup levels. I have included a copy of his March 3, 1989 memo for your information and background.
Based on this memo, the appropriate numerical cleanup standard for the upper threshold for PCB contaminated soil is 10 ppm. This is also to include a soil cap of at least 10 inches of clean soil (soil containing less than 1 ppm PCB) after the removal of a minimum 10 inches of contaminated soil. This should answer your request of February 15, 1989. |
Max Schwenne |
| 5/9/1989 |
Update or Other Action |
(Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Pollution Assessment Plan, May 9, 1989 by America North Inc.; Revised Pollution Assessment Plan, June 22, 1989, America North Inc. |
Former Staff |
| 5/11/1989 |
Update or Other Action |
ANI revised sampling plan for polychlorinated biphenyls (PCBs) in soil exceeding 10 ppm, the level agreed on in COBC 89-2-1-9-130-1. During PCB excavation process, confirmation samples will be collected to verify removal of PCBs. Following remediation of PCBs in soil, if warranted, onsite soils to be fixated in place for lead. |
Ron Klein |
| 6/15/1989 |
Update or Other Action |
Letter from ADEC to ANI RE: 620 East International Road, Anchorage, Alaska May 9, 1989 Pollution Assessment Plan COBC# 89-2-1-9-130-1. The department has the following comments: 3.1 of the plan: states that the background level for PCB is less than three (3) parts per million (ppm). Background levels for PCBs are zero (0).
The department finds the proposed phased approach outlined in section 3.1 for determining the vertical and horizontal distribution of elemental lead, total lead compounds, and PCB soil and water contamination unacceptable. The department does not agree that a finding of no contamination at the surface is evidence that subsurface contamination does not exist. Inorganic compound contaminated soil may have migrated below grand and/or PCB and inorganic compound contaminated soil may have been moved below grade during site activities.
Any finding of non-contamination must be based on verified data. Before soil is moved off site it must be verfied as non-contaminated (as defined by the standards in section 10 of the Compliance Order) through laboratory analysis.
3. If contamination is found in soil samples at the water table, additional monitoring well installation will be needed as part of this scope of work. The number of wells and well locations must be determined through consultation with the department.
4. The proposed representative sample location is unacceptable. According to the Tryck, Nyman and Hayes September 1987 site investigation report, a surface sample near the proposed location reported a lead concentration of 43 ppm which suggested that the sample may have been contaminated by fugutive lead emissions from automobile emmissions. Samples taken from two undeveloped areas within a 500 foot radius of the site would provide a better indication of background. |
Ron Klein |
| 7/6/1989 |
Update or Other Action |
(Old R:Base Action Code = SI - Site Investigation). Pollution Assessment Report Phase I, August 1989 by America North Inc.; Revised Pollution Assessment Report, October 1989 by America North. |
Former Staff |
| 9/19/1989 |
Update or Other Action |
ADEC letter to ANI RE: 620 East International Road, Anchorage, AK August 23, 1989 Phase I Pollution Assmt. Rep. COBC# 89-2-1-9-130-1. Comments on the proposed work plan for addtional assessment activities be modified to incorporate ADEC comments:
1. Para. 4.3 Sampling data obtained two years ago by TN&H should not be used in conjuction with data obtained by ANI to estimated leaching potential or to assume water quality. Meaningful comparisions and water quality evaluations can only be accomplished by collecting samples using appropriate methods and comparing laboratory data from the same techniques. All department data for the site has been reevaluated and is suspect due to unacceptable quality control practices by the DEC contractor.
2. Para 4.3 Contamination plumes could easily be undetected by the proposed monitoring well placement. Justification for selection of the monitoring well locations is requested. Due to the suspect quality of monitoring wells previously installed by TN&H, the department requests that the proposed boring ANIB-1 be completed as a monitoring well. Depending on results additional monitoring wells may be necessary.
3. Para 4.4 One sample from lots on each side of the site is not sufficient to establish the status of off site contamination. At a minimum, at least three surface samples from each of the three sides should be collected. Samples must be taken from off-site locations in close proximity to where on-site contamination was identified.
4. Para 4.3. The department requests that subsurface samples be taken at all surface locations where contaminant concentrations above the cleanup levels have been identified. Subsurface samples need to be taken until contaminant concentrations which do not exceed the cleanup levels have been identified.
5. Para 4.5 Excavation is the only method available to establish the condition of the sewer pipe.
6. Para 4.6 Decontamination water can not be discharged without testing and treatment. Recommend collection of decontamination water in drums. Disposal alternatives will be evaluated based on laboratory analysis.
7. Para 4.6 The term "periodic monitoring" requires definition. A frequency of testing should be proposed.
8. Para 6.0 The need for additional groundwater monitoring beyond the three year period will be determined based upon the concentration levels reported at the end of the three year period. The department requests that the monitoring well ANIB-3 be included. The department requests that the spring/summer samples be scheduled to coincide with peak runoff conditions. |
Ron Klein |
| 10/13/1989 |
Update or Other Action |
ADEC letter to ANI RE: 620 East International Road Anchorage, AK October 11, 1989 Revised Phase I PAR, COBC# 89-2-1-09-130-1. The department had completed its review of the above document and the Phase II work program is approved for implementation with the following requested modification:
It is the Department's expectation that Phase II assessment activities will continue until the horizontal and vertical level and extent of on-site and off-site contamination has been identified. If sample results for the sampling points indicate further assessment is necessary, additional surface or subsurface samples will need to be taken as part of this scope of work. Please review any additional proposed sampling locations that may be necessary with me prior to sampling. Any request for a deadline extension beyond the (30) thirty day period for this phase, necessary to undertake additional sampling not identified in the work plan, will be approved if reasonable. |
Ron Klein |
| 10/17/1989 |
Update or Other Action |
R. Klein Supervisor-Contaminated Sites Investigation (ADEC) sent letter to Brad Authier America North Inc. (ANI) on October 17, 1989 SUB: 620 East International Rd. October 13, 1989 Deadline Extension Request COBC# 89-2-1-09-130-1. The deadline extension request in your October 13, 1989 letter has been granted. The new submittal date for the Phase II PAR is December 7, 1989. |
Ron Klein |
| 12/27/1989 |
Update or Other Action |
Letter from ADEC to ANI RE: 620 East International Airport Rd. Dec. 7, 1989 Phase II PAR COBC# 89-2-1-09-130-01. The Pollution Assessment Report is approved with the following reservations:
1. During the Phase I investigation, lead contamination exceeding the maximum contaminant concentration was identified in a water sample taken from a well point completed in the shallow aquifer. None of the monitoring wells installed during the Phase II investigation were completed in the shallow aquifer. The monitoring wells have done an adequate job of characterizing lower aquifer water quality. Additional information is needed to characterize the level and extent of shallow aquifer contamination. The information can be obtained through a limited well point sampling project.
2. Additional off-site assessment work east of the property fence needs to be undertaken to identify the vertical and horizontal level of lead contamination.
3. Enough on-site data has been developed to provide a basis for designing a remedial action project.
4. Please provide another copy of the PH profiles for ANI B-3 and ANI B-4. The profiles are not clearly defined in Plate 8.
The additional assessment work can be completed concurrently with the remedial action program. Proposes work plans can be incorporated into the Cleanup Plan. Per Paragraph 9(a) of the compliance order, the Cleanup Plan is expected within fifteen (15) business days of receipt of this letter.
|
Ron Klein |
| 1/12/1990 |
Update or Other Action |
R. Klein Supervisor-Contaminated Sites Investigation (ADEC) sent letter to Brad Authier America North Inc. SUB: January 3, 1990 Deadline Extension Request Hanson Associates/M&M Site 620 East International Realty. The January 3, 1990 deadline extension request has been granted. The new submittal date for the clean up plan is February 17, 1990. We will be responding in a separate letter to the issues raised in your letter. |
Ron Klein |
| 3/20/1990 |
Update or Other Action |
Letter from Bill Lamoreaux Regional Supervisor (ADEC) to Brad Authier ANI Sub: February 12, 1990 Deadline Extension Request Hanson Associates/M&M Site 620 International Airport Road, Anchorage. The Department is agreeable to separating the contaminated soil issue from the solid waste removal issue. The proposed April 10, 1990 deadline for submittal of the solid waste removal plan is acceptable. It is expected that the solid waste removal plan will include an implementation schedule. We are expecting solid waste removal activities to commence no later than June 1, 1990.
As stated during the meeting, we are willing to provide Hanson Associates with additional time to research alternative remedial technologies. The Department is agreeable to providing Hanson Associates a deadline extension to June 15, 1990 for submittal of the Cleanup Plan. The June 15, 1990 deadline will provide sufficient time for researching alternative remedial technologies and will be early enough to permit remedial activities to begin this summer. If necessary, implementation of the cleanup plan can be coordinated with the solid waste removal activities.
In lieu of agreeing to meet on specific dates, we would prefer to leave the option available to meet during the weeks of April 2, 1990, May 7, 1990, and June 4, 1990. Please contact Ron Klein the week before to schedule a specific meeting date.
Hanson Associates will be subject to the stipulated penalties established in the compliance order for failure to meet the new deadlines established in this letter, unless further extensions are granted. |
Bill Lamoreaux |
| 4/20/1990 |
Site Ranked Using the AHRM |
Initial ranking. |
Former Staff |
| 5/1/1990 |
Update or Other Action |
Letter from Ron Klein Contaminates Sites Investigation (ADEC) to Edward S. Cronick Sound Environmental Services Inc. SUB: April 11, 1990 Proposed Alternative Cleanup Plan M&M Ent. COBC# 89-2-1-9-130-1. Per our May 1, 1990 telephone conversation, I have provided conceptual approval for the non-hazardous solid waste removal plan outlined in the April 11, 1990 Proposed Cleanup Plan. A detailed solid waste removal design and work plan will be submitted to this office by May 11, 1990. A tentative meeting has been scheduled for May 16, 1990 to discuss the plan.
It is my understanding that you and/or Rich McManus will be contacting Doug Johnson with the EPA's Anchorage Office prior to the May 16, 1990 meeting to discuss your client's request for a relaxation of the PCB cleanup levels outlined in the compliance order. Please be prepared to provide a progress report on the development of a satisfactory clean up plan. |
Ron Klein |
| 5/17/1990 |
Update or Other Action |
Letter from ADEC to Sound Environmental Services Inc. SUB: May 11, 1990 Onsite Segregation and Waste Disposal Plan M&M Ent. COBC# 89-2-1-9-130-1. During our May 16, 1990 meeting I provided approval the May 11, 1990 work plan for onsite segragation and waste disposal at M&M Enterprises. During the meeting I asked for additional information on the design specifications for the rinsate collection system and soil stockpiles.
Per the Department's March 20, 1990 letter agreeing to alternative deadlines, we are expecting solid waste removal activities to commence, no later than June 1, 1990. |
Ron Klein |
| 6/20/1990 |
Update or Other Action |
R. Klein Supervisor CS Investigations sent Brad Authier letter sub: M&M Enterprises June 11, 1990 Deadline Extension Request. The department has no objection to the proposed June 29, 1990 deadline extension for submittal of the contaminated soil treatment/disposal plan for the M&M Site. Per our June 19, 1990 discussion we will be meeting at 1:30 p.m. June 20, 1990 to discuss the status of the treatment and disposal plans and the solid waste removal program. |
Ron Klein |
| 7/10/1990 |
Update or Other Action |
R. Klein LUST Program manager sent ANI a letter Re: June 29, 1990 Contaminated Soil cleanup proposal M&M Ent. COBC# 89-2-1-9-130-1. The department reviewed the June 29, 1990 contaminated soil proposal for the M&M Enterprises.
The eastern stockpile may be fixated and incorporated into the ground surface if PCB concentration levels are below the 10 mg/kg compliance order cleanup level specified by EPA.
According to Plate 2 of the December 7, 1989 Phase II PAR, there is surface PCB contamination above the 10 mg/kg PCB cleanup level in the northeast area of the lot. The surface contamination will need to be cleaned up to below the cleanup level. We recommend resampling at the previous sampling points prior to fixation.
The site will have to be excavated deeper than six inches at locations where PCB concentrations greater than the 10 mg/kg levels have been identified at depths greater than six inches in the December 7, 1989 PAR. Excavated areas will need to be resampled to determine if the cleanup levels have been attained prior to fixation.
Request 12 inch lift rather than the 6-12 inch lift in lead hot spots identified on Plate 6 of the December 7, 1989 PAR.
A sampling plan, QA/QC plan, and a health and safety plan needs to be provided.
Closure will be met when all tasks required by the Compliance Order have been completed. |
Ron Klein |
| 8/29/1990 |
Update or Other Action |
R. Klein Program Mgr. (ADEC) LUST sent letter to Jacqueline Holzman America North Inc. RE: Hanson Associates M&M Enterprises Site Proposal for Performing PCB Confirmation Sampling COBC# 89-2-1-9-130-1. The August 27, 1990 Proposal for Performing PCB Confirmation Sampling is approved for implementation. |
Ron Klein |
| 9/12/1990 |
Update or Other Action |
B. Erickson District Manager (ADEC) sent letter to Brad Authier ANI Sub: Hanson Associates M&M Ent. Site COBC# 89-2-1-1-130-1. Ron Klein will no longer be serving as ADEC project manager for the site due to recent transfer to the SCRO. All future communications concerning the cleanup should be directed to me. |
Bruce Erickson |
| 1/2/1991 |
Update or Other Action |
Letter from B. Erickson Dist. Mgr. ADEC to America North Inc. RE: Progress report for September 1990 M&M Enterprises COBC (compliance order by consent) # 89-2-1-9-130-1. This letter is to acknowledge receipt of the subject report on December 12, 1990. The Department concurs with the request to delay the final sampling until April 30, 1991. |
Bruce Erickson |
| 4/1/1991 |
Update or Other Action |
(Old R:Base Action Code = MS - Monitoring/Sampling). Quarterly monitoring event report to be reviewed. |
Former Staff |
| 7/2/1991 |
Update or Other Action |
S. Bailey (ADEC) sent letter to Jacqueline Holtzman America North Inc. Sub: M&M Ent. Site CS 100.17- Spill# 88-2-1-9-205-1. ADEC has received and reviewed the ANI Letter/report of May 6, 1991 outlining further testing for PCB and lead contamination at the site. The following items were discussed with you and reviewed with the Anchorage District RCRA staff.
Comments: Maps were corrected for direction North since the sampling was shown as on the South Area of the property instead of the West Area of the property.
What time delay for sampling is expected if suspected PCB sampling sites are underwater?
The TCLP 1311 Lead testing samples should be taken in the areas of highest expected lead contamination.
ADEC has normally required that lead contaminated soil be removed from the site and disposed of as hazardous waste. In-situ remediation would just fix the lead contamination in place. Further information on the process and test data results on the process would be required. A risk assessment utilizing long-term monitoring may be required.
When will the new monitoring well casing for ANI b-5 be installed? ANI plans to install the new monitoring concurrent with the site sampling. |
Scott Bailey |
| 11/6/1991 |
Update or Other Action |
(Old R:Base Action Code = MS - Monitoring/Sampling). Monitoring/sampling quarterly report received and reviewed. |
Former Staff |
| 1/1/1993 |
Site Added to Database |
Metals and PCBs. |
Former Staff |
| 9/19/1994 |
Update or Other Action |
ADEC letter to Rolph and Frank Hanson Hanson Associates RE: M&M Enterprises Site, 620 East International Airport Rd. Anchorage, AK (ADEC Incident No. 89-2-1-0-9-130-01, ADO File No. CS100.17). Please provide the department with a progress report by October 15, 1994 on the status of corrective action activities at the M&M Enterprises site. The report should include a description of work performed since EMCON's correspondence to this office of October 8, 1993. The report should also address the items required by Section 12 of the M&M Enterprises 1989 Compliance Order by Consent. In addition, I would like to meet with you and your consultant after we receive the report to discuss the Hanson Associates plans and schedules for completing corrective action at the site. |
Eileen Olson |
| 1/17/1997 |
Site Number Identifier Changed |
Changed Reckey from 1988210920501 to 1989210913001 to reflect the more commonly used # and the # used on the COBC. |
Ray Burger |
| 4/18/1997 |
Meeting or Teleconference Held |
ADEC met with the Hansons and EMCON to discuss remedial alternatives. Solvent washing is being considered but has not been able to meet 2 ppm cleanup level. Solidification is considered too costly and may not be effective. ADEC requested a fence to restrict access be constructed. |
Jim Frechione |
| 4/25/1997 |
Update or Other Action |
Letter from ADEC to EPA RE: PCB Contamination at M&M Enterprises site in Anchorage AK (COBC #892191301). Over 240 tons of soil contaminated with both lead and PCBs has been removed, but it is estimated that at least 700 tons of soil contaminated with up to 7,600 mg/kg PCBs remains. The cleanup has been stalled for the last few years in the expectation that proposed amendments to TSCA were forthcoming that would allow more treatment options. However, the date and form of passage of these amendments is still undetermined. I hope to get this cleanup accomplished without further delay and would like to present the following proposal.
In 1993, soil from this site was used in a demonstration project by Terra-Kleen for EPA's SITE Program. They were able to physically separate the PCBs from the soil and achieve a byproduct of soil containing less than 10 mg/kg of PCBs, but were unable to reach the 2 mg/kg level. I would like to use this physical separation process at the M&M Site and send the concentrated PCB slurry off site to an incinerator. The remaining soil, with PCBs less than 10 mg/kg, would be kept on site and capped to cut off any pathways to receptors. Institutional controls would also be used to maintain the integrity of the cap and restrict use of the site to commercial/industrial.
I believe that this is a workable and resposible action that will be protective of human health and the environment. Please respond to this proposal as soon as possible so that we may still mobilize a cleanup effort during the '97 work season. |
Ray Burger |
| 5/27/1997 |
Update or Other Action |
ADEC letter to Mr Rolph Hanson, and Mr. Frank Hanson Hanson Associates RE: PCB Contamination at M&M Enterprises site, 620 East International Road Anchorage COBC# 8021913001 CS File# 100.17 In our meeting on April 18, 1997 concerning the lead and PCB contamination at the site, we discussed various options for the remediation of the PCB soils. The solvent washing proposal that you have been pursuing for the last few years has not been implemented due the treatment's inability to reach the 2 ppm regulatory limit specified in the Toxic Substance Control Act (TSCA). There has been a proposed amendment to TSCA that would allow for more options in treating contamination, but that cleanup of the M&M site has been stalled for three years now awaiting this regulatory change and we still do not know when this change may come or in what form it will be. Solidification/Stabilization (S/S) was also discussed as it would isolate the contaminants from the environment, but again this treatment option has not been proven to meet the requirements of TSCA.
The bench scale test you did in 1993 showed that the solvent washing could achieve a cleanup level of 10 ppm, but not the established 2 ppm level. I have been in contact with EPA personnel in both the Anchorage and Seattle offices regarding the idea of physically separating the PCBs from the soil using solvent washing and sending the concentrate to a licensed treatment facility. The proposed alternative cleanup level of 10 ppm is already being considered by the EPA and we should receive a response in the second week of June.
I have also been exploring the possibility of acquiring approval for S/S, but unfortunately, it would be more difficult to get this process approved. Basically there needs to be an extensive treatability study and established site controls to prove that the process would work. Since this is an unproven technology, it would be a long and costly application process with no guarantee of EPA approval.
Given the removal of all of the soil is so costly, and S/S may not be approvable and/or too costly, ADEC recommends that you continue to pursue the solvent wash option. In the event EPA approves the alternative cleanup levels, I would expect at that time, to receive work plans from you within 30 days.
As we also discussed in our meeting, access to the property is presently unrestricted on the east side and protective measures need to be taken to prevent contact with the contaminated soil. A fence along the eastern boundary of the property, to tie into the existing fence, will need to be erected by June 30, to restrict access to the site. |
Ray Burger |
| 8/18/1997 |
Update or Other Action |
EPA letter received indicating that soil washing is an acceptable treatment technique subject to EPA conditions.
1. Hanson Associates will complete the following within twelve months of receipt of this letter:
a. The physical separation (soil washing) of PCBs, up to 10,000 ppm, from an estimated 700 tons of soil to less than 10 ppm PCBs.
b. The replacement of the soil with less than 10 ppm PCBs and capping of this soil.
c. The removal of all PCB contaminated waste from the M&M Enterprises former recycling facility location.
d. The disposal/incineration of all PCB contaminated waste, from the M&M Enterprises former recycling facility, in a chemical waste landfill or at an incinerator approved by the EPA to accept PCB waste subject to the Toxic Substances Control Act (TSCA).
e. Provide copies of Certificates of Disposal for the disposal of the PCB contaminated wastes.
f. Provide copies of Certificates of Destruction for the incineration of the PCB contaminated wastes.
g. The identification on all appropriate facility drawings M&M Enterprises, Anchorage, Alaska, of the existence of PCB contamiantion at the former recycling facility. This identification should indicate the need for additional precautions during any future modification, renovation, or demolition of the facility.
2. Hanson Associates will provide EPA Region 10 and the Alaska Department of Environmental Conservation (ADEC) with the final report documenting the completion of the above items. This report will be provided no later than September 1, 1998. This report will also include:
a. The results of the physical separation (soil washing) of PCBs, up to 10,000 ppm from an estimated 700 tons of soil to less than 10 ppm PCBs.
b. Information on additional pre-and post-cleanup sampling as well as the estimated cost of the cleanup by man-hours and dollars. Although not required for compliance with the PCB Spill Cleanup Policy at 40 CFR 761.125, this information should also be maintained by ADEC as well as Hanson Associates Anchorage, Alaska.
Signed by David Croxton for Michael A. Bussel, Director Office of Waste and Chemicals Management. |
Ray Burger |
| 9/2/1997 |
Update or Other Action |
EMCON letter to EPA clarifying that the Hansons did not request use of soil washing at the site but rather they requested 10 ppm cleanup level (versus 2 ppm) and consideration of various treatment techniques. |
Jim Frechione |
| 10/8/1997 |
Update or Other Action |
EPA letter to EMCON requesting information to justify 10 ppm cleanup level and cost prohibitive removal plan.
EPA understands that the cleanup of the M&M Enterprises site has not been initiated due to problems encountered with the PCB-contaminated soil containing greater than 50 ppm PCBs, and the the soil may not be removed due to site-specific characteristics which may make soil removal cost-prohibitive. It is our understanding that Hanson & Associates is proposing an alternative remediation technology to solidify the contaminated soil and leave the contaminated soil in place.
The PCB regulations at 40 CFR 761.120(c) provide EPA "the flexibility to allow less stringent or alternative decontamination measures based upon site-specific considerations" for a PCB cleanup. Therefore, within 180 days of your receipt of this letter, you should provide our office with documentation certifying that:
The cleanup to numerical decontamination levels is unwarranted because of risk-mitigation factors, e.g. solidification,
The compliance with the procedural requirements or numerical standards, is impracticable at the M&M Enterprises Site, and
Removal of the PCB-contaminated soil from the M&M Enterprises Site is cost-prohibitive.
Your documentation should be accompanied by a complete description of risk-mitigating steps (e.g. solidification, encapsulation, type of encapsulation proposed, maintenance procedures for protecting the integrity of the encapsulation, etc.) Hanson and Associates proposes to put in place in the event EPA approves the proposal. |
Jim Frechione |
| 11/19/1997 |
Site Ranked Using the AHRM |
Site Access Value changed from "1" to "0" to reflect the installation of a fence in 7/97. |
Ray Burger |
| 7/17/1998 |
Update or Other Action |
EMCON continues to provide updates on Hanson's efforts to select a cost efficient technology that will address the PCB and lead contaminated soil at the site. |
Jim Frechione |
| 8/7/1998 |
Update or Other Action |
ADEC CSRP Program Manager Jim Frechione sent letter to Rolph & Frank Hanson re: M&M Enterprises 620 East International Airport Road, Anchorage AK (ADEC No. CS100.17). ADEC has received an assessment report identifying soil contamination on property located adjacent ot the M&M Enterprises site. A suspected battery and solid waste disposal area was encountered at 5333 Fairbanks Street during recent paving operations.
The results of soil sampling analysis indicate contamination is primarily lead and polychlorinated biphenyl (PCB). Preliminary sample results identify excessive lead concentrations requiring it to be processed as a hazardous waste. Since the nature of the contamination is similar to that existing at the M&M site and the proximity of the two sites to one another, you are being informed of this matter for comment. |
Jim Frechione |
| 9/13/2000 |
Update or Other Action |
Toggled the Justification field from "Y" to "N" because the AHRM Score puts this site into a High Priority without the need for Justification. |
Former Staff |
| 4/8/2002 |
Update or Other Action |
Completed file review, added update to the file. Prepared a Chronological History for the file, current though March 2002. |
Lynne Bush |
| 6/18/2003 |
Meeting or Teleconference Held |
Sundet met w/ Alex Tula of Alta Geosciences. Alex discussed the workplan submitted to DEC and EPA, and requested DEC to comment on EPA's draft letter on the cleanup plan and Tula's response to EPA's draft letter. |
Rich Sundet |
| 7/7/2003 |
Cleanup Plan Approved |
On 7/7/03, CSP issued an non-objection letter to Ms. Susan Reeves, legal counsel to the owners of Hanson Properties, for Alta Geosciences to implement their “Site Cleanup Plan Hanson Site Anchorage” dated May 2003 and amendment to the cleanup plan that was received by DEC on June 26, 2003. The amendement was in response to our comments on July 1. In review of the subject plan, CSP also reviewed Alta Geosciences “Site Characterization Report Hanson Site Anchorage” dated April 2003.
The letter also noted that the CSP letter was in followup to a conversation on June 30, 2003 between Sundet and Alex Tula which Sundet reported CSP's general findings of its review of the subject two documents pertinent to the Hanson contaminated site, i.e., the former M&M Enterprises site at 620 East International Airport Road in Anchorage.
As a result of the conversation and cursory comments, Mr. Tula provided an amendment to the cleanup plan on June 26, 2003 and a response to our comments on July 1.
While, the CSP noted that it had no objection to Alta Geosciences implementing the plan, the letter provided some comments that the owners may want to consider prior to or during these work activities that may impact the work, e.g., whether some of the activities will trigger federal Resource Conservation and Recovery Act (RCRA) regulations and sampling for diesel range organic (DRO) hydrocarbons. |
Rich Sundet |
| 8/7/2003 |
Update or Other Action |
Via email on 8/7/03, Alex Tula of Alta Geosciences provided DEC groundwater sampling results for wells ANI-B1, B2, B3 and B4 for DRO. B1 and B4 were N/D, B2 was 0.711 mg/l, and B3 was 0.697 mg/l DRO, which were below the Table C level of 1.5 mg/l DRO. |
Rich Sundet |
| 1/13/2006 |
Document, Report, or Work plan Review - other |
Replacement of Well ANI-B4 and Groundwater Sampling results received. The new well was replaced by overdrilling and installing a new well in the location of the previous well. The new well was drilled to 25 feet bgs and was screened from 14-24 feet bgs. The well installation took place on 10/25/2006 and the well was sampled on 10/26/2006. Despite replacement of the well, the samples were turbid. Groundwater results from well ANI-B4 are as follows: DRO <300 ug/L, Total Lead 14.6 ug/L, and dissolved lead was <1.0 ug/L. |
Julie Fix |
| 3/25/2008 |
Update or Other Action |
On 3/25/08, EPA notified Susan Reeves and Alex Tula representing Rolph Hanson that it had received ALTA Geosciences "PCB Closure Report: Soils Remediation 2003-2004: Debenahm Porperty" report dated November 2004. The report was part of the Hanson Site in Anchorage. In its letter, EPA noted that cleanup and remediation was in accordance to 40 CFR 761.61(a) and the requirements of its 7/9/03 letter, and considered the PCB contamination on the Debenham property as closed. EPA also in its letter noted that EPA's determination did not obviate Hanson Associates, Inc. from complying with DEC regulations under 18 AAC 75. |
Rich Sundet |
| 6/11/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Rich Sundet |
| 3/20/2009 |
Update or Other Action |
On 3/20/09, DEC issued a ROD and Cleanup Complete Determination for the Debenham site (2100.38.091) and the Debenham portion of the Hanson Property Former M&M Enterprises site (CS file 2100.38.007). The findings were based upon DEC's review of a number of reports in association with the Hanson site including but not limited to Alta GeoSciences "Site Characterization Report" dated April 2003. In addition, the determiniation was based upon Alta's "Closure Report Soils Remediation 2003 - 2004 Debenham Property" dated November 2004 and Shannon & Wilson's report "Preliminary Contamination Assessment at 5333 Fairbanks Street" dated August 5,1998. The Alta cleanup report noted that lead was cleaned up to less than 400 mg/kg, DRO less than 250 mg/kg and PCBs to less than 1.0 mg/kg on the Debenham property. However the Alta Site Characterization Report noted that one sample in Grid C-2 showed 1.51 mg/kg PCBs which was above the residential cleanup level of 1.0 mg/kg in 18 AAC 75. DEC performed a statistical analysis and determined that the 1.51 mg/kg sample was a potential outlier at the 1% and 5% significance level, and that the site's 95% UCL mean soil sample was well under the 1.0 mg/kg cleanup level as allowed under 18 AAC 75.380(c)(1). In addition, the one groundwater monitoring well on site ANI-B4 had not detected any contaminants that were sampled for above their applicable cleanup levels. Thus, the site met applicable 18 AAC 75.341 and A8 AAC 75.345 Table C groundwater cleanup levels. Alta's cleanup report also noted that the area where the 1.51 mg/kg PCE sample was collected had been collected at 22 inches below ground surface, covered with Geotextile fabric and repaved over after the 2003-2004 cleanup was performed, which elminated the dermal contact and ingestion pathway and reduced the risk to exposure from the inhalation pathway. The clean closure letter noted that information needed to be provided to ADEC by June 15, 2009 demonstrating that well ANI-B4 had been properly decommissioned or that ADEC would place an IC on the property and modify the determination and request periodic reporting on the status of the well. |
Rich Sundet |
| 6/8/2009 |
Update or Other Action |
On 6/8/09, CS issued a letter to Ray Debenham in response to Geosceiences 5/14/09 dated letter that informed CSP that it had properly decommissioned monitor well ANI-B4. DEC received the Geosciences letter via email on 6/8/09. CSP informed Debenham that it approved of the report and no further action needed to occur regarding this issue which was noted in CSP's 3/20/09 ROD issued for the Debenham portion of this site and for Debenham Investiments Building Site (2100.38.091). |
Rich Sundet |
| 2/1/2010 |
Update or Other Action |
On 2/1/10, DEC provided via e-mail a draft ROD for that portion of the site on the Hanson property. Earlier in 2009, a ROD was finalized for the Debenham portion of the site. DEC requested that Alta Geosciences provide answers to the questions in the draft ROD, and on that basis,then EPA and DEC can consider the next actions needed to complete their decisions for this site. |
Rich Sundet |
| 6/30/2010 |
Update or Other Action |
On 6/30/10, after discussing with Alex Tula, Sundet provided via email to Tula a revised ROD based upon comments received from Tula on 5/17/10. DEC had provided an earlier draft ROD to Tula on 2/1/10. |
Rich Sundet |
| 9/8/2010 |
Site Visit |
On 9/8/10, Sundet inspected the site in followup to Alta's 8/13/10 email plan submittal that proposed a cleanup on the 3 ft. wide strip of soil on Tract 2A's boundary with Tract 2B. It was observed that two fences separate the two tracts and that about 1 1/2 - 2 ft. strip of soil lies between the two fences that appeared not to have been part of the last cleanup peformed by Alta in 2004. |
Rich Sundet |
| 9/9/2010 |
Site Visit |
In follow up to the inspection on 9/8, on 9/8/10, Sundet notified Dan Duncan of EPA of the findings of the inspection on 9/8. Later on 9/9, Sundet reinspected the site and took several photos. |
Rich Sundet |
| 9/15/2010 |
Cleanup Plan Approved |
On 9/15/10, in agreement with Dan Duncan of EPA, DEC issued via email a conditional approval of Altageoscienes cleanup plan that Alta submitted via email to DEC on 8/13/10. The plan proposed cleanup of a 3 ft. wide strip of land on Area No. 2 of Tract 2A. Among its conditions, DEC/EPA required that cleanup also occur in the area between the two fences and located between Area No. 2 and Grids A4-A6, and either cleanup or sample the area between the fences that is between Area No. 1 and Gridgs A1-A3 and Area No. 3 and Gridgs A7-A9. From the prior week's inspections, it appeared that no prior cleanup was performed between the two fences as trees were observed up to 10 feet high. |
Rich Sundet |
| 10/12/2010 |
Update or Other Action |
On 10/12/10, Sundet provided via email to Tula a revised ROD based upon comments received from Tula on 5/17/10. DEC had provided the revised ROD to Tula also on 6/30/10 but had only addressed about 1/2 of the original ROD. DEC had initailly provided a draft ROD to Tula on 2/1/10. |
Rich Sundet |
| 3/29/2013 |
Document, Report, or Work plan Review - other |
On 3/29/13, DEC commented on Alta Geosciences "Supplemental Soils Remediation Completion Report M&M Yard and Adjacent Areas” dated October 2012. The supplemental report was received at DEC on October 24, 2012. The response letter was in coordination with Dave Bartus of EPA. This work was done in follow-up to Alta’s cleanup at the site in 2003 and 2004. DEC had earlier approved of a two part regulatory cleanup with the “more recent” subdivided/sold Debenham portion having a more stringent cleanup level so no institutional controls (ICs) (e.g., less than 400 mg/kg lead; and less than 1.0 mg/kg PCBs; and default 18 AAC 75.341 cleanup levels for petroleum constituents such as diesel range organics; 250 mg/kg). Meanwhile, the remaining portion of the Hanson Former M&M Enterprises Site (Tracts 2A, 2B and 2C) would meet 18 AAC 75.341 cleanup levels for a commercial scenario (e.g., less than 1,000 mg/kg lead; less than 10 mg/kg PCBs with a cap; and alternative cleanup levels for petroleum contaminants such as DRO). Both EPA and DEC closed out that portion of the site on the Debenham property without ICs in 2008 and 2009, respectively. The subject report is in follow-up to address the cleanup of the property line area between the two tracts. The subject report clarified:
• the wooden fence is the boundary between Tracts 2A and 2B;
• the strip of land between the wooden fence and chained-link fence was on Tract 2B;
• east of the wooden fence, including the chain-link fence, was Tract 2B and west of the wooden fence was Tract 2A;
• the western strip of land between the wooden fence and west to the asphalt parking lot (hereinafter referred to as the landscaped strip) was about three feet wide and 96 feet long;
• the area on the west side of the chain link fence was identified as the “West Area” in Alta’s Completion Report M&M Yard and Alleyway Areas Soils Remediation 2003 – 2004 dated February 2008; and,
• as described in Alta’s Site Characterization Report dated 2003, sample location within Grid #1 was from the landscape area (on Tract 2A) while sample locations Grids 2 and 3 were in the unpaved soil strip between the chain-link fence and the edge of the asphalt pavement south of the landscrape strip.
Alta performed a two phased excavation in September 2011, removed 80.15 tons of contaminated polychlorinated bi-phenols (PCBs) and lead soils to depths of 3-4 ft., transported the soil to Columbia Ridge Landfill, and filled the excavation with clean fill. The first phase of excavation was excavated to 3 feet below ground surface (bgs) and four samples were collected on September 6, 2011 in the landscape area west of the wooden fence on Tract 2A per Figure 4 with a maximum of lead detected at 506 mg/kg at sample location S1 and for PCBs at 10.9 mg/kg at sample location S3. Based on the higher sample that showed that PCBs still remained above a cleanup threshold, further excavation was performed around S3. The second phase of excavation occurred in the area of S3 and continued to four feet bgs where a soil sample S3R was collected on September 14, 2011. Soil sample S3R showed 0.97 mg/kg total PCBs (i.e., only Aroclor 1260 was detected) and 81 mg/kg total lead. The report shows that contamination remaining after both cleanup phases were completed was a maximum of 1.14 mg/kg PCBs (S4) and 506 mg/kg lead (S1). As a result of their review, the agencies requested clarification on several aspects of the report.
|
Rich Sundet |
| 6/24/2015 |
Update or Other Action |
On 3/29/13, DEC commented on Alta Geosciences "Supplemental Soils Remediation Completion Report M&M Yard and Adjacent Areas” dated October 2012. To date DEC has not received the requested revised report. |
Robert Weimer |
| 6/29/2016 |
Update or Other Action |
Spoke to consultant regarding 2013 ADEC comments and needed revised report. Emailed 3/2013 ADEC letter containing comments to consultant for reference. |
Lisa Griswold |
| 6/29/2016 |
Potentially Responsible Party/State Interest Letter |
Updated PRP letter sent to listed RP. |
Lisa Griswold |
| 5/11/2017 |
Update or Other Action |
Site transferred to Rodman |
Lisa Griswold |
| 6/26/2018 |
Institutional Control Record Established |
Institutional Controls established and entered into the database. |
Amy Rodman |
| 6/26/2018 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 71599 Surface releases. |
Amy Rodman |
| 4/29/2021 |
Site Visit |
Site visit conducted by LKB and RP to observe general condition of property and locate and determine status of monitoring wells (ANIB1, ANIB2, ANIB3, ANIB5). Photos and a photo log have been added to the site file. Staff could not located monitoring wells and will return at a later date with a metal detector. |
Julie Fix |
| 5/5/2021 |
Site Visit |
LKB site visit to investigate location of monitoring well ANI-B1. No evidence that the well still exists. Well was possibly destroyed during previous construction activities. |
Julie Fix |
| 10/15/2021 |
Meeting or Teleconference Held |
Meeting with RP to discuss ICs, environmental covenant, and path to closure. Provided RP with guidance documents. |
Julie Fix |
| 2/18/2022 |
Meeting or Teleconference Held |
Meeting with RP to discuss IC and potential additional cleanup actions moving forward. |
Julie Fix |
| 2/25/2022 |
Meeting or Teleconference Held |
Meeting with RPs to discuss site. Discussed different options for ICs and potential additional site work. |
Julie Fix |
| 3/3/2022 |
Meeting or Teleconference Held |
Meeting with RPs to discuss site. |
Julie Fix |
| 3/9/2022 |
Meeting or Teleconference Held |
Teleconference with responsible party to discuss closure options and potential site work. |
Julie Fix |
| 6/8/2022 |
Document, Report, or Work plan Review - other |
Draft "2022 Work Plan" received on this date. Initial comments sent via email on 6/9/2022. Response to comments received on 6/22/2022 and 7/29/2022. ADEC response to comments sent to RP via email on 8/12/2022. Revised "2022 Work Plan" submitted to ADEC on 9/6/2022. ADEC comments sent to RP via email on 9/21/2022. RP response to comments received on 9/22/2022. |
Julie Fix |
| 9/23/2022 |
Site Characterization Workplan Approved |
The revised "2022 Work Plan" was approved on this date. |
Julie Fix |
| 10/10/2022 |
Site Visit |
Site visit with RP. Observed newly constructed asphalt cap on E7. Observed land spread soils from B4 on F1 and F2. Observed excavated area at B4 (excavation remains open until confirmation sampling results are ready). Observed locations of test pits at A2, A4, A7, S1, and S2. Photos and field notes have been saved to the site file. |
Julie Fix |
| 2/2/2023 |
Document, Report, or Work plan Review - other |
The "Soil Sampling, Northland Industrial Center" report was received on this date. |
Julie Fix |
| 4/10/2023 |
Site Characterization Report Approved |
The "Soil Sampling, Northland Industrial Center" report was approved on this date. |
Julie Fix |
| 6/7/2023 |
Document, Report, or Work plan Review - other |
The draft work plan “Hanson Site M&M Yard”, dated June 7, 2023 was received on this date. Initial comments on the draft work plan were sent to the responsible party on 6/14/2023. A revised work plan was submitted to DEC on 7/14/2023. |
Julie Fix |
| 7/20/2023 |
Site Characterization Workplan Approved |
The revised “Hanson Site, M&M Yard” work plan, dated July 14, 2023, was approved on this date. The work plan proposes collecting 8 soil samples from borings that will be drilled to the north, south, west, and directly adjacent to Borings 2AS1 and 2AS4. Samples will be collected from 2.5-3.5 feet bgs with at least one sample collected from 5 to 7 feet bgs directly adjacent to 2AS1 and 2AS4. |
Julie Fix |
| 8/2/2024 |
Site Characterization Report Approved |
Reviewed/approved the "Soil Sampling, TRACT 2A, Northland Central, Anchorage, Alaska; ADEC File No. 2100.38.007 (dated Nov. 3, 2023)" report. In August 2023, eight soil borings (including 1 duplicate) were collected along the eastern side of the parcel. Polychlorinated Biphenyls (PCB) concentrations exceeded the cleanup level (1.0 mg/kg) in three samples: 2AS1-S (3.08 mg/kg), 2AS4-N (5.83 mg/kg), and 2AS4-S (9.57 mg/kg).The extent of the PCB plume has not been fully delineated to the south. |
Stacee Henderson |
| 8/22/2024 |
Potentially Responsible Party/State Interest Letter |
PRP letter sent on this date |
Stacee Henderson |
