Site Report: IHS Kanakanak Hospital - Area 4 & Sitewide Record

Site Name:	IHS Kanakanak Hospital - Area 4 & Sitewide Record
Address:	6000 Kanakanak Road, Hospital Bldg 401 & Admin Bldg 301, Dillingham, AK 99576
File Number:	2540.38.005
Hazard ID:	682
Status:	Active
Staff:	Tim Sharp, 9074512131 tim.sharp@alaska.gov
Latitude:	59.000418
Longitude:	-158.536207
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 several large historical above-ground fuel storage tanks, and a former vehicle maintenance garage in vicinity of new hospital building 401 and administration building 301. Benzene, DRO, GRO, and RRO exceeding groundwater cleanup levels detected in adjacent monitoring wells. Limited chlorinated-solvent contamination (PCE) was encountered in adjacent monitoring well AP-123. Soil borings immediately east of and adjacent to building 401 were sampled for DRO and BTEX; DRO results exceeded alternate cleanup levels in boring 06-SB-01. It is not practical to excavate to a depth of 15 feet immediately adjacent to buildings 301 and 401 in the rear of the building and in the vicinity of the loading dock. Vapor intrusion evaluation will continue beneath buildings 301 and 401. Groundwater monitoring ongoing, and potential evaluation for in-situ treatment of soil contamination. Proposed new construction east of building 401 will require screening for DRO with possible removal actions. This database record includes historic action descriptions when entire facility was tracked as one site, prior to source area delineation.

Action Information

Action Date	Action	Description	DEC Staff
12/1/1990	Site Added to Database	Diesel contaminant.	Former Staff
5/24/1993	Site Characterization Workplan Approved	(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). WDO sent a letter approving phase I remediation plan "Work Plan, Free-Product Recovery, Kanakanak Hospital, Dillingham, Alaska" of May 11, 1993, prepared by the U.S. Army Corps of Engineers for the U.S. Public Health Service. Submittal of the work plan followed an April 8, 1993 meeting held between PHS (Dan Carpenter, Delton Woodford, and Chuck Bailey), the corps (Joe Burwell, Molly TeVrucht, Bob Haviland), and ADEC (Eileen Olson in person, and Max Schwenne present via conference call for part of the meeting to discuss risk assessments). Phase I work is scheduled to begin July 17, 1993, and entails free-product recovery by using a skimmer pump in an existing 4-inch diameter monitoring well in the vicinity of the hospital sewage treatment plant. Conditions of plan approval included bi-weekly reports to WDO of the quantity of product recovered. According to the work plan, Phases 2 and 3 will be addressed in separate work plans following Phase I. Phase II will consist of performing a risk assessment and developing a remedial design. This will begin in the summer of 1993 and conclude in early 1994. Phase III will consist of the final remediation design and its implementation.	Former Staff
6/15/1995	Site Ranked Using the AHRM	Initial ranking. Action code added because it wasn't when the site was originally ranked.	Ray Dronenburg
9/3/1996	Long Term Monitoring Established	Long-term Monitoring needed before site is closed.	Ray Dronenburg
10/31/1996	Meeting or Teleconference Held	Meeting at PHS office in Anchorage to discuss corrective actions when contaminated soils will be encountered during excavation. Meeting participants were Corey Lloyd (Dowl Engineers), Shah Alam (ADEC), Dan Carpenter (PHS), John Muir (BBAHC) by phone.	Shah Alam
11/6/1996	Update or Other Action	ADEC mailed cost recovery letters for project oversight and risk assessment review.	Shah Alam
12/23/1996	Update or Other Action	On 12/23/1996, ADEC received "Space Planning Study and Site Master Plan" for Kanakanak Hospital dated 11/1/1996. Architects Alaska prepared this two-volume document.	Shah Alam
12/24/1996	Update or Other Action	ADEC mailed letters commenting on the "Space Planning and Site Master Plan."	Shah Alam
1/9/1997	Update or Other Action	ADEC received a letter from PHS (Dan Carpenter). PHS requested to spread lightly contaminated soils on a road.	Shah Alam
1/23/1997	Update or Other Action	ADEC mailed risk assessment review comments to PHS.	Shah Alam
1/31/1997	Update or Other Action	Shah Alam and Scott Pexton (both ADEC) met Dan Carpenter (PHS) to discuss the risk assessment review comments. Mr. Carpenter will submit a written response addressing the review comments.	Shah Alam
2/5/1997	Update or Other Action	ADEC received a response to some of the risk assessment review comments.	Shah Alam
2/6/1997	Update or Other Action	ADEC denied the request to spread lightly contaminated soils on road surface.	Shah Alam
2/27/1997	Meeting or Teleconference Held	A meeting was held on 2/2/1997 to discuss risk assessment and site remediation. The participants were Shah Alam (ADEC), Ron Klein (ADEC), Jim Frechione (ADEC), Linda Himmelbauer (ADEC), Ray Dronenburg (ADEC), Dan Carpenter (PHS), Joe Burwell (COE), Bob Haviland (COE), Victor Harris (Montgomery-Watson). John Muir (BBAHC), John Smart (BBAHC) and John Delap (Delap Consulting) were on teleconference. Ron Klein and Ray Dronenburg attended only parts of the meeting. PHS contended that ADEC letter dated 4/17/1995 was an approval to the risk assessment. ADEC maintained that the letter was only review comments. Meeting participants discussed the review comments not addressed previously. PHS will be submitting responses to the outstanding review comments. ADEC project manager agreed with one additional monitoring well location located to the west of the Building 401. PHS plans to sample soil and groundwater this summer.	Shah Alam
3/6/1997	Update or Other Action	ADEC denied a second request to spread lightly contaminated soils on a road surface.	Shah Alam
3/10/1997	Update or Other Action	ADEC received a 1983-Shannon and Wilson report on geotechnical foundation and site study. PHS could not locate drinking water well logs to submit to ADEC.	Shah Alam
5/2/1997	Update or Other Action	ADEC staff informed U.S. Public Health Service (PHS) that additional contamination data from surficial soils would be necessary to decide cleanup levels. In response to PHS' request to backfill water line excavations with contaminated soils, staff informed RP that ADEC needed to be sure that the contaminants would not deteriorate the pipeline materials during the life of the pipeline. PHS responded with pipeline manufacturer's specifications to show that the pipeline materials were satisfactorily resistant to chemicals.	Shah Alam
5/14/1997	Meeting or Teleconference Held	Meeting at ADEC building among ADEC/CS, ADEC/DW, PHS, and COE. Among the participants were Michael Lu, Shah Alam, Jim Frechione, Dan Carpenter, Bob Haviland, Richard Jackson, Molly TeVrucht, Bret Walters (COE). Michael Lu discussed the plan review requirements for placing water pipeline in the contaminated soils. Michael mentioned the following: bedding soil under the water pipe (may act as a conduit for the contaminants), different pipeline materials may react differently (not applicable in this case because the pipeline here is one material - DRISCOPIPE's HDPE), QA/QC of pipeline placement operation, placing a liner before placing contaminated soils.	Shah Alam
5/28/1997	Update or Other Action	ADEC staff visited Kanakanak Hospital site.	Shah Alam
2/6/1998	Update or Other Action	ADEC received soil and groundwater sampling results. These samples were collected last summer. ADEC project manager conducted a contaminated site-wide peer review. CS project managers agreed with the approach of deciding ACLs.	Shah Alam
2/9/1998	Update or Other Action	Teleconference with Dan Carpenter, COE (Bob Haviland, Molly), ADEC (Shah, Jim Frechione) to discuss ACLs. ADEC project manager explained rationale of ACL decisions.	Shah Alam
5/11/1998	Cleanup Level(s) Approved	ADEC program manager issued a cleanup letter dated May 11, 1998 to PHS. ACL for diesel contaminated soils is 5,000 mg/kg.	Shah Alam
1/6/1999	Update or Other Action	ADEC wrote to USPHS clarifying depth limit for alternative soil cleanup levels and requesting additional information for excavated contaminated soils.	Shah Alam
1/21/1999	Update or Other Action	U.S. Public Health Service submitted ADEC requested supplemental information related to the 350 cubic yards of DRO contaminated soil.	Shah Alam
2/18/1999	Update or Other Action	U.S. Public Health Service submitted annual ground water sampling data for 1998.	Shah Alam
4/22/1999	Cleanup Plan Approved	ADEC approved reuse of contaminated soils. The soils were excavated from the location of Emergency Room Addition, to the northwest of the existing hospital building. The excavated contaminated soils did not exceed the ACLs established for this contaminated site. The soils will be spread at the location identified as Building 401 Excavated Soil Pad near soil boring locations AP-110 and AP-111 (Figure 4-1, Kanakanak Hospital Risk Assessment report 1994), south of the main hospital building and along the east side of the road to the dump.	Shah Alam
4/29/1999	Update or Other Action	ADEC has reviewed a draft Corrective Action Plan (CAP) and provided comments to the U.S. Public Health Service. ADEC agreed to defer excavation of contaminated soils at the Sewage Treatment Plant area. The excavation will compromise the existing building. The building will be demolished in 2001.	Shah Alam
5/10/1999	Update or Other Action	ADEC received the final version of the Corrective Action Plan (CAP). The CAP has incorporated all of the ADEC comments.	Shah Alam
5/21/1999	Update or Other Action	ADEC approved a cleanup work plan. Proposed work includes demolition of a fuel tank and contaminated soil excavation at the Above Ground Fuel Storage Area, free product recovery at the monitoring well AP-121 in the Sewage Treatment Plant Area, and, ground water monitoring data collection from existing monitoring wells.	Shah Alam
7/19/1999	Update or Other Action	Dan Carpenter of USPHS reported about the free product recovery at the monitoring well AP121. Over the past month recovered approximately two gallons of DRO. As of July 15, 1999, the skimmer pump in the well has been fully operational. Prior to that time, DRO was recovered either by hand bailing the well or by the periodic use of the skimmer, when functional. The operation of the skimmer has been complicated due to the clogging of a filter in the skimmer by what seems to be iron bacteria, naturally present in the high iron content groundwater (this occurs in other wells in the Bristol Bay area). Given a steady state condition, PHS expects to recover one gallon of free product every nine days for the remainder of the season. However, the static water level in the well has fallen over the past month of operation. If this continues at the same rate, it may no longer be practical to operate the skimmer.	Shah Alam
11/1/1999	Update or Other Action	USPHS (Dan Carpenter) encountered an area of petroleum contaminated soil (exceeding the ACL for DRO) during removal of non-regulated underground fuel storage tanks on the last week of September 1999. Approximately 50 cubic yards of contaminated soil was excavated from the underground storage tank that served Buildings 3 and 4. A larger quantity of contaminated soil was not excavated and remained at the site. A laboratory sample collected from the excavation pit before backfilling showed DRO contamination of 14300 mg/kg. USPHS will submit a cleanup workplan for this newly discovered contaminated soils.	Shah Alam
11/10/1999	Update or Other Action	Cost recovery for the amount of $4,589.74.	Shah Alam
12/2/1999	Update or Other Action	USPHS (Dan Carpenter) reported encounter of petroleum contaminated soil (exceeding the ACL for DRO) near and asphalt-paved area on the southeast corner of the parking area for Building 301. Approximately 100 cubic yards of contaminated soils has been stockpiled at the site. One soil sample indicated DRO concentration of 18100 mg/kg. Workplan for additional characterization of this area proposed.	Shah Alam
12/8/1999	Update or Other Action	Wrote USPHS requesting to characterize newly discovered contaminated soils and asked to submit a report describing the results of the free-product recovery system, the excavation at the above ground storage tank area and the ground water monitoring data for 1999.	Shah Alam
12/13/1999	Update or Other Action	USPHS (Carpenter) responded to the Department's ADEC 8, 99 letter with a facsimile. Annual groundwater monitoring report is under preparation by USACE. The report will address free product recovery from well AP121. Contaminated soil at the 30,000 gallon tank was not excavated in 1999, however, the tank was removed. Soil excavation is scheduled for summer 2000.	Shah Alam
12/30/1999	Update or Other Action	USPHS submitted groundwater monitoring data for 1999 and reported cleanup works conducted in 1999. Groundwater samples were collected from nine wells and tested for DRO and BTEX. AP-123 was tested for VOC. AP-121 contained 0.35 feet of floating product; DRO concentration of 2.7 mg/L in AP-100 exceeded Table C (18 AAC 75) value (1.5 mg/L), tetrachloroethene was 36 ppb at AP-123 (Table C standard is 5 ppb). The tank 30,000 gallon AST and the contents have been removed from the site in 1999 but the soil excavation did not occur partly due to unfavorable weather conditions. The soil excavation is scheduled for next summer (2000). Approximately 22 gallons of free product were recovered last year from shallow groundwater.	Shah Alam
1/4/2000	Update or Other Action	ADEC responded to the 1999 cleanup report and requested a phase II cleanup workplan.	Shah Alam
1/13/2000	Update or Other Action	USPHS submitted information that ADEC (William Rieth) has approved construction of a new sewage lagoon. No contaminated soil above ACL is expected to be encountered.	Shah Alam
8/2/2000	Update or Other Action	ADEC has approved a Corrective Action Plan (CAP) dated July 13, 2000 as submitted. The CAP listed, summarized status, and proposed cleanup work for all known contaminated areas within this contaminated site. ADEC has also agreed with landspreading locations (a soil pad and a closed solid waste disposal site) proposed on July 28, 2000 with the following comments: (1) the landspreading operation at the solid waste disposal site should not damage cover materials for buried asbestos containing materials; (2) revegetation following the landspreading operation at the solid waste disposal site will be required.	Shah Alam
8/7/2000	Update or Other Action	Staff approved placement of new sewer main near the area of DRO contamination known to exist at the sewage treatment plant (STP). If contaminated soil is encountered during excavation for the sewer main, the soils will not removed. USPHS will identify the location of contaminated soils through sampling. The contaminated soils will be removed when the STP will be demolished next year.	Shah Alam
8/18/2000	Update or Other Action	Received landspreading project data.	Shah Alam
11/9/2000	Update or Other Action	Received corrective action report regarding summer landspreading activities.	Renee Evans
2/28/2001	Update or Other Action	Received groundwater monitoring report for 2000 activities.	Renee Evans
4/25/2001	Update or Other Action	Faxed request for "qualified person" groundwater sampling at site.	Renee Evans
5/16/2001	Update or Other Action	Received and approved groundwater monitoring plan for summer 2001.	Renee Evans
5/17/2001	Update or Other Action	Received draft corrective action plan for summer 2001.	Renee Evans
6/26/2001	Update or Other Action	Received revision to corrective action plan and approved plan and revisions.	Renee Evans
7/23/2001	Update or Other Action	Groundwater monitoring update - well decommissioning and new well installation.	Renee Evans
8/15/2001	Update or Other Action	Update for corrective action work schedule - to begin in September.	Renee Evans
8/20/2001	Cleanup Plan Approved	Approval for use of geomembrane to distinguish lifts at landspreading area.	Renee Evans
6/10/2002	Update or Other Action	Cost Recovery invoice reviewed, forwarded to AG's office for mailing.	Lynne Bush
1/16/2003	Update or Other Action	The Solid Waste Program plans to grant no further action to the landfill near this site. Five years of monitoring show no leaching.	Lynne Bush
9/15/2003	Update or Other Action	On 9/15/03, CSP approved the Federal Public Health Service's workplan to demolish a portion of the underground fuel piping at the Kanakanak hospital site. The work is scheduled to begin on 9/16/03 and will investigate for leakage 1,500 linear feet of pipeline that will be removed at the site. Suspected contaminated soil will be stockpiled on site and may be landfarmed on site.	Rich Sundet
1/14/2004	Meeting or Teleconference Held	On 1/14/04, Sundet participated in a meeting held between Indian Health Service (including Dan Carpenter) and the Kanakanak Environmental Advisory Group (EAG) that includes the Bristol Bay Native Health Corporation. Discussion was focused on the contamination remaining and plans to address the contamination and identify areas considered uncharacterized by the EAB.	Rich Sundet
2/26/2004	Meeting or Teleconference Held	On 2/26/04, Sundet participated in a followup meeting to the 1/14/04 meeting held between Indian Health Service (including Dan Carpenter) and the Kanakanak Environmental Advisory Group (EAG) that includes the Bristol Bay Native Health Corporation. Continued discussion was focused on the contamination remaining and plans to address the contamination and identify areas considered uncharacterized by the EAB.	Rich Sundet
3/3/2004	Update or Other Action	On 3/3/04, CSP issued a letter to IHS in response to the January and February 04 meetings. The letter was intended to assist both IHS and EAG in developing plans to address the contamination at the site and meet the intent of the 1998 ROD issued for this site. The letter requested an evaluation by IHS regarding the two areas where free product had been detected, the groundwater monitoring program, and assessment of the landfarm area.	Rich Sundet
5/26/2004	Update or Other Action	On 5/26/04, CSP provided comments to IHS regarding their “Draft Corrective Action Site Plan” dated May 7, 2004 for the Kanakanak site. The plan proposes among other tasks, the tilling of the contaminated soil in the existing landfarm; excavation of test pits in the area of the old sewage treatment plant and the hospital to observe for free petroleum product (these are areas where free product had been detected in the past); excavation of about 20 cubic yards of contaminated soil from 10 areas that will be brought to the landfarm area for treatment; and, removal of 1,000 feet of abandoned fuel oil piping throughout the site.	Rich Sundet
5/27/2004	Update or Other Action	On 5/27/04, DEC conditionally approved IHS April 27, 2004 “Groundwater Monitoring Plan” at the Kanakanak Site and approved of the May 26, 2004 “Work Plan for Monitoring Well Installation” by Oasis on behalf of BBAHC for the Kanakanak Hospital Site. Oasis proposed to install 15 additional monitoring wells on site. IHS will monitor the existing wells and the 15 new wells as well as survey the wells.	Rich Sundet
6/15/2004	Update or Other Action	Project transferred from Sundet to Mike Jaynes. Sundet notified IHS and BBHS of the change in project managers.	Rich Sundet
7/6/2004	Update or Other Action	In a letter dated 7/6/04, DOL informed DEC that it received a check from BBAHC fro $1,0041.80 for its cost recovery bill sent to them.	Rich Sundet
1/10/2005	Meeting or Teleconference Held	Attended by phone latest meeting of Environmental Advisory Group (EAG). Informed of latest well sampling results and plans for the upcoming season. More well sampling to continue to establish trend for groundwater wells.	Mike Jaynes
3/2/2005	Meeting or Teleconference Held	Attended meeting by phone regarding last season's work and upcoming sampling by IHS. Some conflict as to sampling methods. Scheduled a meeting for 3/16/05 for resolving technical issues.	Mike Jaynes
3/17/2005	Meeting or Teleconference Held	Meeting with BBNHC (Operator of Site), IHS representatives, Oasis (BBHNC consultant) and ADEC PM in Anchorage. Asked each party to take a look at big picture for the site and take a look at overall progress. All parties looked at each of the ten AOCs and came to partial agreement on steps to final closure for the site. The EAG will be responsible for memorializing this document.	Mike Jaynes
5/10/2005	Meeting or Teleconference Held	Phone meeting with IHS representatives to discuss goals of AOC9 soil vapor testing proposal by Oasis Enviro. DEC goal for testing of AOC9 is to verify the air inhalation pathway is imcomplete.	Mike Jaynes
3/2/2006	Update or Other Action	Reviewed monitoring well data for the past 11 years and recommended IHS reduce their sampling to five wells, AP123, MW-02, MW-09, MW-10, MW-11 and reduce monitoring at wells MW-08, MW-12,MW-14, MW-15, WP-02,WP-03. Details in file. Review sent to EAG Workgroup.	Mike Jaynes
6/6/2006	Update or Other Action	2006 Monitoring Well sampling plan reviewed and approved by email.	Mike Jaynes
7/19/2006	Update or Other Action	Worked on EAG Action plan for the site. Site is now divided into 10 areas of concern (AOC) with known surface or subsurface petroleum contamination including 1) Previous above-ground fuel storage tank, 2) Footing drain for Building 318, 3) Previous sewage treatment plant (STP), 4) Building 301/401 complex, 5) Oil/water separator and containment pond, 6) Soil pad constructed of material excavated during construction of Building 401, 7) Site of the storage tank demolition at staff housing buildings 3 & 4, 8) Route of underground electrical conduit at the corner of parking area for Building 301, 9) Loading dock area between buildings 301 and 401, and 10) Site of the current 2,000 CY capacity, fenced, petroleum contaminated soil (PCS) land farm.	Mike Jaynes
8/22/2006	Site Characterization Workplan Approved	Reviewed the workplan, Draft 2006 Environmental Monitoring and Remediation Work Plan, Kanakanak Hospital received by email on August 11, 2006. The plan discussed this year’s project objectives – a Soil Vapor Extraction system pilot test, quarterly vapor monitoring of the Building 301 and 401 crawlspaces, and groundwater level monitoring. Workplan approved with minimal comments.	Mike Jaynes
8/28/2006	Update or Other Action	New Cost Recovery Memo sent to Pamela Post at AG's office. Letter is on G drive at G:\SPAR\CS\Contaminated Site Files (38)\2540 Dillingham\2540.38.005 Kanakanak Hospital\Cost Recovery Memo Kanakanak Hospital 082806.doc	Mike Jaynes
2/15/2007	Meeting or Teleconference Held	CS personnel attended a meeting of the Environmental Advisory Group (EAG) in Anchorage. The group reviewed and updated the EAG Strategic Plan for monitoring and remediation at sites in the hospital vicinity. The need for remedial action was discussed at a few of the petroleum contaminated sites, although final decisions were tabled until new EAG members could become more familiar with the site history. Contractors to the Bristol Bay Area Health Corporation summarized their findings from 2006 field work, including SVE pilot testing and soil gas/indoor air sampling, and their recommendations for future work.	Colin Craven
4/3/2007	Update or Other Action	ADEC submitted comments on the following four reports: Draft 2006 SVE Pilot Test Report, Final 2005 Soil Gas Survey Report, Draft 2006 Soil Sampling & Analysis Report, Draft 2006 Groundwater Monitoring Report. The most significant deficiencies were a lack of lab analytical data quality assurance checklists and conceptual site models. ADEC expects discussion of the comments within a month.	Colin Craven
9/24/2007	Update or Other Action	Contaminated Sites provided approval to the IHS (via email) for not conducting the 2007 round of groundwater monitoring to refocus resources on better defining long-term goals for the environmental restoration projects.	Colin Craven
2/6/2008	Meeting or Teleconference Held	Contaminated Sites and state epidemiologist Dr. Lori Verbrugge participated in a teleconference with the IHS, ANTHC, BBAHC and their contractors about the potential for vapor intrusion into hospital. Discussion centered around a report prepared by BBAHC contractors presenting a year's worth of crawl-space air sampling under the hospital buildings. The samples contained benzene, TCE, and PCE at low concentrations, but still exceeding EPA default screening levels for indoor air in a few samples. Dr. Verbrugge stated that the concentrations found were not of concern, but concurred with CS's recommendations for a few additional sample points to ensure that adequate coverage across the hospital was achieved. Both Dr. Verbrugge and CS will document their findings in letters to make the recommendations more specific.	Colin Craven
6/23/2008	Site Characterization Workplan Approved	ADEC approved a workplan developed by contractors of BBAHC to investigate potential petroleum contamination during the removal of three underground storage tanks, and potential petroleum and chlorinated solvent contamination in an utilidor excavation adjacent to the hospital.	Colin Craven
7/9/2008	Site Characterization Workplan Approved	ADEC approved the annual groundwater monitoring sampling and analysis plan submitted by IHS personnel.	Colin Craven
8/7/2008	Meeting or Teleconference Held	ADEC toured the hospital facilities and contaminated sites with IHS and BBAHC personnel. Time was spent mostly at sites covered in the strategic plan of the Env. Advisory Group (e.g. Areas 1, 3, 4, 5, 9 and 10) and the beach where debris and graves slowly are exposed as old unpermitted dumps erode. Locations for new monitoring well installations were identified for Area 3, and subslab soil gas monitoring point locations were discussed for Bldg 301 (Area 4 and 9).	Colin Craven
9/17/2008	Site Characterization Workplan Approved	Received the September 2008 Work Plan; 2008 UST removal report, and 2008 Soil sampling and analysis report. The work plan proposes to install additional monitoring wells, transfer soil for the soil stockpile to the remedial treatment area (RTA), pump and dispose of containment water from the RTA to the evaporation pond and dispose of debris from the eroding landfills. The UST removal report documents removal of 3 regulated USTs, an 8,000 gallon diesel tank near building 401, and a 1,000 gallon diesel, and 2,000 gallon unleaded gasoline tank from the south side of building 402. All samples collected from the 8,000 gallon UST removal were below ACLs for the site. Contamination beneath the tanks adjacent to building 402 exceeded ACLs for DRO, GRO, BTEX and 1 & 2-Methylnapthylene. Groundwater was not detected, but was likely less than 5 feet below the bottom of the excavation. The soil sampling at the RTA did not detect any contaminants above the ACLs. The site characterization described in the workplan has been delayed until summer '09. A combined approval and comment letter sent 12/1/08.	Kim DeRuyter
10/22/2008	Exposure Tracking Model Ranking	Initial ranking with ETM completed for source area id: 71661 name: Kanakanak Hospital	Kim DeRuyter
1/6/2009	Document, Report, or Work plan Review - other	Reviewed and Approved the 2008 Groundwater Monitoring Plan and updated the site summary	Kim DeRuyter
1/7/2009	Update or Other Action	Cleanup Complete wth ICs agreement for Area 1 sent to Indian Health Service, may need to be re-sent as signatory authority for IHS has not been determined.	Kim DeRuyter
1/8/2009	Meeting or Teleconference Held	Staff (DeRuyter, Vreeman) participated in a teleconference with BBAHC, ANTHC, OASIS, IHS to discuss the status of each area of concern, pending site closures, and reports reviewed in 2008. BBAHC was interested in recent DEC policy changes, such as the risk based approach to site closures, increased scrutiny of data quality,and changes to the site closure policy. IHS voiced concerns that institutional controls could hamper the property transfer to under CERCLA. BBAHC voiced concerned that staff turnover at DEC (7 project managers in the last 10 years) had caused delays in report review and increasing contractor and regulatory costs.	Kim DeRuyter
6/17/2009	Leaking Underground Storage Tank Cleanup Initiated - Petroleum	Reviewed and approved the Final Boiler Building Utilidor Excavation and UST removal report. Diesel and gasoline range organics were encountered in the smear zone at building 402. Groundwater characterization will take place this summer.	Kim DeRuyter
10/1/2009	Update or Other Action	Contaminated Sites staff received an update on the Indian Health Service (IHS) Kanakanak Hospital site in Dillingham. New monitoring wells were installed down gradient of the old sewage treatment plant to evaluate potential groundwater contamination between the former facility and Nushagak Bay. Soil borings were advanced down gradient of the hospital to assess potential soil contamination in the location of a proposed dental facility. Contamination was encountered in the borings and although analytical data is still pending, IHS is considering other locations for the dental facility to avoid potential indoor air quality concerns. The Alaska Native Tribal Health Consortium (ANTHC) has not conducted the sub-slab and crawl space monitoring planned for this summer. This sampling was proposed as a follow-up to the vapor intrusion evaluation conducted in 2007. Groundwater is several feet higher than normal at the site and staff has contacted ANTHC to urge that the samples be collected to document potential vapor intrusion during this unusual groundwater event.	Kim DeRuyter
10/2/2012	Document, Report, or Work plan Review - other	ADEC sent comments on the draft work plan for soil and groundwater investigation at Areas 2, 5 and 7. Soil borings will be advanced, monitoring wells will be installed, and soil and groundwater samples will be analyzed in order to further delineate contamination at each area. The work will be completed in early October. Additional investigation is planned for summer 2013.	Meghan Dooley
11/28/2012	Document, Report, or Work plan Review - other	ADEC received the Final Work Plan for the Kanakanak Hospital Site and approved it on this date.	Meghan Dooley
2/20/2013	Document, Report, or Work plan Review - other	Approval provided for the Final Vapor Intrusion Monitoring Work Plan for the Kanakanak Hospital Site, Dillingham, Alaska.	Meghan Dooley
7/24/2013	Document, Report, or Work plan Review - other	Draft report received: 2013 Soil Remediation Work Plan for the Kanakanak Hospital Site, Dillingham, Alaska.	Meghan Dooley
8/21/2013	Document, Report, or Work plan Review - other	Received: 2012 Annual Groundwater Monitoring Report.	Meghan Dooley
8/27/2013	Document, Report, or Work plan Review - other	Approval given for Final February and May Vapor Intrusion Monitoring Reports for the Kanakanak Hospital Site, Dillingham, AK.	Meghan Dooley
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
7/24/2014	Document, Report, or Work plan Review - other	Approved final 2014 Kanakanak Hospital UVOST Soil Characterization Work Plan.	Meredith Savage
7/29/2014	Meeting or Teleconference Held	Teleconference held with representatives from ADEC, Indian Health Services, Bristol Bay Area Health Corporation, and ERM Consultants. Site status discussed: Area 1- cleanup complete with Institutional Controls (ICs); Areas 2 and 7- proposed for cleanup complete with ICs, Areas 3, 4, 8, 9, 11- remedial action ongoing; Area 5- remedial activities being evaluated; Area 6- cleanup complete; Area 12- stockpiled soil to be removed to the remedial treatment area (RTA).	Meredith Savage
8/4/2014	Document, Report, or Work plan Review - other	Received electronically: Draft Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska. The work plan outlines sampling efforts to be conducted at two sites within the Kanakanak Hospital property: a proposed new dental clinic and a proposed new boarding facility. Both proposed structures would be located within known petroleum product contaminated areas: dental clinic-Area 3, boarding facility-Area 4. The sampling effort is part of an overall geotechnical sampling activity and will help identify the likelihood of encountering contaminated soils during future construction activities.	Meredith Savage
8/6/2014	Meeting or Teleconference Held	Teleconference held with representatives from ADEC, Indian Health Services, Bristol Bay Area Health Corporation, and ERM Consultants. Meeting held to discuss current soil screening and sampling efforts, and locations for additional sampling.	Meredith Savage
8/11/2014	Document, Report, or Work plan Review - other	Received electronically on 8/04/204: Revised Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska. ADEC comments provided on 8/05/2014. Final work plan received electronically on 8/07/2014. Final approval provided on 8/08/2014, contingent on one additional change. Received electronically on 8/11/2014: Final Revised Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska	Meredith Savage
10/8/2014	Document, Report, or Work plan Review - other	ADEC received the Final 2013 Annual Groundwater Monitoring Report on September 30, 2014. This report addresses field activities completed at the Kanakanak Hospital project site in September 2013 and presents water level gauging data, well point installation and development data, and groundwater sample analytical results for Areas 2, 3, 4, 5, 7, 8, 9, 11, and the Beach area. Areas 2 and 7 have been recommended for closure and the decommissioning the groundwater wells; Areas 3, 4, 8, 9, and 11 have been recommended for continued annual groundwater monitoring; and Area 5 is recommended for remedial work (addressed in a separate report) and groundwater monitoring in 2016.	Meredith Savage
8/7/2015	Update or Other Action	Transfer to Fairbanks	Susan Carberry
9/10/2015	Update or Other Action	Had phone conversation with ERM contractor, in which it was determined that analytical samples would be taken of water coming from Building 401 footer drain in support of characterization and eventual closure for this Area of Concern. Samples will be taken prior to passing through the oil-water separator outside Area 5. Samples would be analyzed for DRO/RRO, VOCs, and PAHs. Analytical results would be used to calculate TAH and TAqH values. DEC proposed quarterly sampling; awaiting concurrence from BBAHC on sampling frequency.	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
9/22/2017	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
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
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
10/19/2018	Document, Report, or Work plan Review - other	DEC approved the Kanakanak Hospital Area 11 Vapor Intrusion Monitoring Work Plan, dated October 16, 2018. The document describes proposed vapor intrusion activities at Area 11 of the Indian Health Service (IHS) Kanakanak Hospital site located approximately 3 miles southwest from Dillingham, Alaska. The intent of the above-referenced work plan is to assess if vapor intrusion is occurring at Building’s 310 and 402, and to determine whether interior vapor concentrations pose a potential health risk to the people using the buildings now or in the future. The proposed work includes drilling two permanent soil-gas monitoring points (one on the exterior south side of Building 310 and Building 402) and collecting indoor air samples from within the crawlspaces and breathing zones of the two buildings.	Erica Blake
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
11/13/2019	Document, Report, or Work plan Review - other	DEC approved the Kanakanak Hospital Area 11 Vapor Intrusion Monitoring Report, Dillingham, AK, Dated November 2019. This report details findings from a vapor intrusion (VI) assessment at Area 11 of Kanakanak Hospital in Dillingham, Alaska. The VI assessment was conducted in November 2018 to evaluate whether underlying petroleum contamination was resulting in a vapor intrusion concern at commercially-used Buildings 310 and 402 in Area 11 of the Kanakanak Hospital. Building Inventory and Indoor Air Sampling Questionnaires were completed for both buildings. Additionally, soil gas monitoring points were installed and soil gas samples were taken. Photoionization detector (PID) surveys were conducted inside each building, and indoor air samples were collected at locations with the highest PID readings. No exceedances of DEC target levels for commercial indoor air for petroleum contaminants were observed, although dichlorodifluoromethane (Freon 12) equaled the DEC target level in one soil gas sample. DEC concurs with the recommendation for at least one more sampling event to capture seasonal variation in vapor intrusion and confirm that Freon 12 VI is not posing an unacceptable risk to human health.	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
6/10/2020	Document, Report, or Work plan Review - other	DEC Approved the Final May 2019 Interim Report, which detailed multi-incremental soil sample results to assess whether the contaminated soil in the Area 6 and Area 10 landfarms that originated from Area 5 have been remediated below ACLs. Additionally, groundwater samples were collected and analyzed from seven monitoring wells at Area 5. 04MW-10 tested above CULs for benzene, ethylbenzene, and naphthalene. Finally, a bench test was performed to assess treatment options for the Building 401 footer drain. ERM recommends further groundwater monitoring, with ceasing sampling at two wells that have tested below Table C for several concurrent sampling events. The footer drain treatment system report is under review currently.	Tim Sharp
6/25/2020	Update or Other Action	DEC Approved the Final Kanakanak Hospital Preliminary Design Report for Building 401 Footer Drain. The Report presents results from a bench test from the effluent of the footer drain after aeration and settling, as well as a design to convert the onsite oil/water separator to an aeration system. There is a point of compliance downgradient of the aeration tank, and samples will be collected from prior to treatment as well as immediately after treatment. The bench test showed a reduction of contaminants in the footer drain effluent to below TAH and TAqH AWQS.	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
7/28/2020	Update or Other Action	DEC provided comments for the 2019 Draft Report for Area 5 Excavation and Area 11 Vapor Intrusion Monitoring. Comments included notes about the rescinding of the 1998 ACLs, clarification on concentrations of contaminants remaining in soil, landfarm contaminant concentration levels (Areas 6 and 10), and requesting scheduling groundwater monitoring at these landfarms.	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
8/28/2020	Document, Report, or Work plan Review - other	DEC approved the 2019 Final Report for AOC 5 excavation and AOC 11 VI Monitoring. 2750 cy of contaminated soil was transferred to the AOC6 and AOC 10 landfarms, but more contamination remains at the extents of the excavation. Naphthalene and ethylbenzene were detected in Building 402, but may be attributable to background sources. Another round of sampling is recommended. Groundwater monitoring in AOC 5 and near the landfarms is also recommended. IHS, ERM, and BBAHC will prepare ACLs using the HRC, and once those have been agreed upon, further remedial actions will be planned.	Tim Sharp
9/2/2020	Exposure Tracking Model Ranking	A new updated ranking with ETM has been completed for source area 71661 Kanakanak Hospital.	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
10/20/2020	Meeting or Teleconference Held	DEC met with ERM, IHS, and BBAHC representatives to discuss the Development of ACLs Plan memorandum. Topics covered included EPH and VPH sampling in Area 5 and alternatives, TOC soil collection method 415.1 modified (typically a water sampling method), aquifer thickness variability across the site (20 feet seems conservative for the model), and validity of the use of samples taken in 1994 (range of data and selection qualifiers are acceptable). Some data gaps were discussed, along with MAC exceedances and what that means for the future of management of the site. DEC will discuss the MAC exceedances internally to determine if EPM II or III approval is necessary. Overall the methods proposed seem sound.	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
3/17/2022	Document, Report, or Work plan Review - other	DEC sent comments on the Draft Supplemental Site Investigation Work Plan. Soil and groundwater samples will be collected from all AOCs on the CSP database (so excluding Areas 11 and 12) to further characterize contaminants at the site and develop new alternative cleanup levels (ACLs) using the Hydrocarbon Risk Calculator (HRC).	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

12/1/1990

Site Added to Database

Diesel contaminant.

Former Staff

5/24/1993

Site Characterization Workplan Approved

(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). WDO sent a letter approving phase I remediation plan "Work Plan, Free-Product Recovery, Kanakanak Hospital, Dillingham, Alaska" of May 11, 1993, prepared by the U.S. Army Corps of Engineers for the U.S. Public Health Service. Submittal of the work plan followed an April 8, 1993 meeting held between PHS (Dan Carpenter, Delton Woodford, and Chuck Bailey), the corps (Joe Burwell, Molly TeVrucht, Bob Haviland), and ADEC (Eileen Olson in person, and Max Schwenne present via conference call for part of the meeting to discuss risk assessments). Phase I work is scheduled to begin July 17, 1993, and entails free-product recovery by using a skimmer pump in an existing 4-inch diameter monitoring well in the vicinity of the hospital sewage treatment plant. Conditions of plan approval included bi-weekly reports to WDO of the quantity of product recovered. According to the work plan, Phases 2 and 3 will be addressed in separate work plans following Phase I. Phase II will consist of performing a risk assessment and developing a remedial design. This will begin in the summer of 1993 and conclude in early 1994. Phase III will consist of the final remediation design and its implementation.

Former Staff

6/15/1995

Site Ranked Using the AHRM

Initial ranking. Action code added because it wasn't when the site was originally ranked.

Ray Dronenburg

9/3/1996

Long Term Monitoring Established

Long-term Monitoring needed before site is closed.

Ray Dronenburg

10/31/1996

Meeting or Teleconference Held

Meeting at PHS office in Anchorage to discuss corrective actions when contaminated soils will be encountered during excavation. Meeting participants were Corey Lloyd (Dowl Engineers), Shah Alam (ADEC), Dan Carpenter (PHS), John Muir (BBAHC) by phone.

Shah Alam

11/6/1996

Update or Other Action

ADEC mailed cost recovery letters for project oversight and risk assessment review.

Shah Alam

12/23/1996

Update or Other Action

On 12/23/1996, ADEC received "Space Planning Study and Site Master Plan" for Kanakanak Hospital dated 11/1/1996. Architects Alaska prepared this two-volume document.

Shah Alam

12/24/1996

Update or Other Action

ADEC mailed letters commenting on the "Space Planning and Site Master Plan."

Shah Alam

1/9/1997

Update or Other Action

ADEC received a letter from PHS (Dan Carpenter). PHS requested to spread lightly contaminated soils on a road.

Shah Alam

1/23/1997

Update or Other Action

ADEC mailed risk assessment review comments to PHS.

Shah Alam

1/31/1997

Update or Other Action

Shah Alam and Scott Pexton (both ADEC) met Dan Carpenter (PHS) to discuss the risk assessment review comments. Mr. Carpenter will submit a written response addressing the review comments.

Shah Alam

2/5/1997

Update or Other Action

ADEC received a response to some of the risk assessment review comments.

Shah Alam

2/6/1997

Update or Other Action

ADEC denied the request to spread lightly contaminated soils on road surface.

Shah Alam

2/27/1997

Meeting or Teleconference Held

A meeting was held on 2/2/1997 to discuss risk assessment and site remediation. The participants were Shah Alam (ADEC), Ron Klein (ADEC), Jim Frechione (ADEC), Linda Himmelbauer (ADEC), Ray Dronenburg (ADEC), Dan Carpenter (PHS), Joe Burwell (COE), Bob Haviland (COE), Victor Harris (Montgomery-Watson). John Muir (BBAHC), John Smart (BBAHC) and John Delap (Delap Consulting) were on teleconference. Ron Klein and Ray Dronenburg attended only parts of the meeting. PHS contended that ADEC letter dated 4/17/1995 was an approval to the risk assessment. ADEC maintained that the letter was only review comments. Meeting participants discussed the review comments not addressed previously. PHS will be submitting responses to the outstanding review comments. ADEC project manager agreed with one additional monitoring well location located to the west of the Building 401. PHS plans to sample soil and groundwater this summer.

Shah Alam

3/6/1997

Update or Other Action

ADEC denied a second request to spread lightly contaminated soils on a road surface.

Shah Alam

3/10/1997

Update or Other Action

ADEC received a 1983-Shannon and Wilson report on geotechnical foundation and site study. PHS could not locate drinking water well logs to submit to ADEC.

Shah Alam

5/2/1997

Update or Other Action

ADEC staff informed U.S. Public Health Service (PHS) that additional contamination data from surficial soils would be necessary to decide cleanup levels. In response to PHS' request to backfill water line excavations with contaminated soils, staff informed RP that ADEC needed to be sure that the contaminants would not deteriorate the pipeline materials during the life of the pipeline. PHS responded with pipeline manufacturer's specifications to show that the pipeline materials were satisfactorily resistant to chemicals.

Shah Alam

5/14/1997

Meeting or Teleconference Held

Meeting at ADEC building among ADEC/CS, ADEC/DW, PHS, and COE. Among the participants were Michael Lu, Shah Alam, Jim Frechione, Dan Carpenter, Bob Haviland, Richard Jackson, Molly TeVrucht, Bret Walters (COE). Michael Lu discussed the plan review requirements for placing water pipeline in the contaminated soils. Michael mentioned the following: bedding soil under the water pipe (may act as a conduit for the contaminants), different pipeline materials may react differently (not applicable in this case because the pipeline here is one material - DRISCOPIPE's HDPE), QA/QC of pipeline placement operation, placing a liner before placing contaminated soils.

Shah Alam

5/28/1997

Update or Other Action

ADEC staff visited Kanakanak Hospital site.

Shah Alam

2/6/1998

Update or Other Action

ADEC received soil and groundwater sampling results. These samples were collected last summer. ADEC project manager conducted a contaminated site-wide peer review. CS project managers agreed with the approach of deciding ACLs.

Shah Alam

2/9/1998

Update or Other Action

Teleconference with Dan Carpenter, COE (Bob Haviland, Molly), ADEC (Shah, Jim Frechione) to discuss ACLs. ADEC project manager explained rationale of ACL decisions.

Shah Alam

5/11/1998

Cleanup Level(s) Approved

ADEC program manager issued a cleanup letter dated May 11, 1998 to PHS. ACL for diesel contaminated soils is 5,000 mg/kg.

Shah Alam

1/6/1999

Update or Other Action

ADEC wrote to USPHS clarifying depth limit for alternative soil cleanup levels and requesting additional information for excavated contaminated soils.

Shah Alam

1/21/1999

Update or Other Action

U.S. Public Health Service submitted ADEC requested supplemental information related to the 350 cubic yards of DRO contaminated soil.

Shah Alam

2/18/1999

Update or Other Action

U.S. Public Health Service submitted annual ground water sampling data for 1998.

Shah Alam

4/22/1999

Cleanup Plan Approved

ADEC approved reuse of contaminated soils. The soils were excavated from the location of Emergency Room Addition, to the northwest of the existing hospital building. The excavated contaminated soils did not exceed the ACLs established for this contaminated site. The soils will be spread at the location identified as Building 401 Excavated Soil Pad near soil boring locations AP-110 and AP-111 (Figure 4-1, Kanakanak Hospital Risk Assessment report 1994), south of the main hospital building and along the east side of the road to the dump.

Shah Alam

4/29/1999

Update or Other Action

ADEC has reviewed a draft Corrective Action Plan (CAP) and provided comments to the U.S. Public Health Service. ADEC agreed to defer excavation of contaminated soils at the Sewage Treatment Plant area. The excavation will compromise the existing building. The building will be demolished in 2001.

Shah Alam

5/10/1999

Update or Other Action

ADEC received the final version of the Corrective Action Plan (CAP). The CAP has incorporated all of the ADEC comments.

Shah Alam

5/21/1999

Update or Other Action

ADEC approved a cleanup work plan. Proposed work includes demolition of a fuel tank and contaminated soil excavation at the Above Ground Fuel Storage Area, free product recovery at the monitoring well AP-121 in the Sewage Treatment Plant Area, and, ground water monitoring data collection from existing monitoring wells.

Shah Alam

7/19/1999

Update or Other Action

Dan Carpenter of USPHS reported about the free product recovery at the monitoring well AP121. Over the past month recovered approximately two gallons of DRO. As of July 15, 1999, the skimmer pump in the well has been fully operational. Prior to that time, DRO was recovered either by hand bailing the well or by the periodic use of the skimmer, when functional. The operation of the skimmer has been complicated due to the clogging of a filter in the skimmer by what seems to be iron bacteria, naturally present in the high iron content groundwater (this occurs in other wells in the Bristol Bay area). Given a steady state condition, PHS expects to recover one gallon of free product every nine days for the remainder of the season. However, the static water level in the well has fallen over the past month of operation. If this continues at the same rate, it may no longer be practical to operate the skimmer.

Shah Alam

11/1/1999

Update or Other Action

USPHS (Dan Carpenter) encountered an area of petroleum contaminated soil (exceeding the ACL for DRO) during removal of non-regulated underground fuel storage tanks on the last week of September 1999. Approximately 50 cubic yards of contaminated soil was excavated from the underground storage tank that served Buildings 3 and 4. A larger quantity of contaminated soil was not excavated and remained at the site. A laboratory sample collected from the excavation pit before backfilling showed DRO contamination of 14300 mg/kg. USPHS will submit a cleanup workplan for this newly discovered contaminated soils.

Shah Alam

11/10/1999

Update or Other Action

Cost recovery for the amount of $4,589.74.

Shah Alam

12/2/1999

Update or Other Action

USPHS (Dan Carpenter) reported encounter of petroleum contaminated soil (exceeding the ACL for DRO) near and asphalt-paved area on the southeast corner of the parking area for Building 301. Approximately 100 cubic yards of contaminated soils has been stockpiled at the site. One soil sample indicated DRO concentration of 18100 mg/kg. Workplan for additional characterization of this area proposed.

Shah Alam

12/8/1999

Update or Other Action

Wrote USPHS requesting to characterize newly discovered contaminated soils and asked to submit a report describing the results of the free-product recovery system, the excavation at the above ground storage tank area and the ground water monitoring data for 1999.

Shah Alam

12/13/1999

Update or Other Action

USPHS (Carpenter) responded to the Department's ADEC 8, 99 letter with a facsimile. Annual groundwater monitoring report is under preparation by USACE. The report will address free product recovery from well AP121. Contaminated soil at the 30,000 gallon tank was not excavated in 1999, however, the tank was removed. Soil excavation is scheduled for summer 2000.

Shah Alam

12/30/1999

Update or Other Action

USPHS submitted groundwater monitoring data for 1999 and reported cleanup works conducted in 1999. Groundwater samples were collected from nine wells and tested for DRO and BTEX. AP-123 was tested for VOC. AP-121 contained 0.35 feet of floating product; DRO concentration of 2.7 mg/L in AP-100 exceeded Table C (18 AAC 75) value (1.5 mg/L), tetrachloroethene was 36 ppb at AP-123 (Table C standard is 5 ppb). The tank 30,000 gallon AST and the contents have been removed from the site in 1999 but the soil excavation did not occur partly due to unfavorable weather conditions. The soil excavation is scheduled for next summer (2000). Approximately 22 gallons of free product were recovered last year from shallow groundwater.

Shah Alam

1/4/2000

Update or Other Action

ADEC responded to the 1999 cleanup report and requested a phase II cleanup workplan.

Shah Alam

1/13/2000

Update or Other Action

USPHS submitted information that ADEC (William Rieth) has approved construction of a new sewage lagoon. No contaminated soil above ACL is expected to be encountered.

Shah Alam

8/2/2000

Update or Other Action

ADEC has approved a Corrective Action Plan (CAP) dated July 13, 2000 as submitted. The CAP listed, summarized status, and proposed cleanup work for all known contaminated areas within this contaminated site. ADEC has also agreed with landspreading locations (a soil pad and a closed solid waste disposal site) proposed on July 28, 2000 with the following comments: (1) the landspreading operation at the solid waste disposal site should not damage cover materials for buried asbestos containing materials; (2) revegetation following the landspreading operation at the solid waste disposal site will be required.

Shah Alam

8/7/2000

Update or Other Action

Staff approved placement of new sewer main near the area of DRO contamination known to exist at the sewage treatment plant (STP). If contaminated soil is encountered during excavation for the sewer main, the soils will not removed. USPHS will identify the location of contaminated soils through sampling. The contaminated soils will be removed when the STP will be demolished next year.

Shah Alam

8/18/2000

Update or Other Action

Received landspreading project data.

Shah Alam

11/9/2000

Update or Other Action

Received corrective action report regarding summer landspreading activities.

Renee Evans

2/28/2001

Update or Other Action

Received groundwater monitoring report for 2000 activities.

Renee Evans

4/25/2001

Update or Other Action

Faxed request for "qualified person" groundwater sampling at site.

Renee Evans

5/16/2001

Update or Other Action

Received and approved groundwater monitoring plan for summer 2001.

Renee Evans

5/17/2001

Update or Other Action

Received draft corrective action plan for summer 2001.

Renee Evans

6/26/2001

Update or Other Action

Received revision to corrective action plan and approved plan and revisions.

Renee Evans

7/23/2001

Update or Other Action

Groundwater monitoring update - well decommissioning and new well installation.

Renee Evans

8/15/2001

Update or Other Action

Update for corrective action work schedule - to begin in September.

Renee Evans

8/20/2001

Cleanup Plan Approved

Approval for use of geomembrane to distinguish lifts at landspreading area.

Renee Evans

6/10/2002

Update or Other Action

Cost Recovery invoice reviewed, forwarded to AG's office for mailing.

Lynne Bush

1/16/2003

Update or Other Action

The Solid Waste Program plans to grant no further action to the landfill near this site. Five years of monitoring show no leaching.

Lynne Bush

9/15/2003

Update or Other Action

On 9/15/03, CSP approved the Federal Public Health Service's workplan to demolish a portion of the underground fuel piping at the Kanakanak hospital site. The work is scheduled to begin on 9/16/03 and will investigate for leakage 1,500 linear feet of pipeline that will be removed at the site. Suspected contaminated soil will be stockpiled on site and may be landfarmed on site.

Rich Sundet

1/14/2004

Meeting or Teleconference Held

On 1/14/04, Sundet participated in a meeting held between Indian Health Service (including Dan Carpenter) and the Kanakanak Environmental Advisory Group (EAG) that includes the Bristol Bay Native Health Corporation. Discussion was focused on the contamination remaining and plans to address the contamination and identify areas considered uncharacterized by the EAB.

Rich Sundet

2/26/2004

Meeting or Teleconference Held

On 2/26/04, Sundet participated in a followup meeting to the 1/14/04 meeting held between Indian Health Service (including Dan Carpenter) and the Kanakanak Environmental Advisory Group (EAG) that includes the Bristol Bay Native Health Corporation. Continued discussion was focused on the contamination remaining and plans to address the contamination and identify areas considered uncharacterized by the EAB.

Rich Sundet

3/3/2004

Update or Other Action

On 3/3/04, CSP issued a letter to IHS in response to the January and February 04 meetings. The letter was intended to assist both IHS and EAG in developing plans to address the contamination at the site and meet the intent of the 1998 ROD issued for this site. The letter requested an evaluation by IHS regarding the two areas where free product had been detected, the groundwater monitoring program, and assessment of the landfarm area.

Rich Sundet

5/26/2004

Update or Other Action

On 5/26/04, CSP provided comments to IHS regarding their “Draft Corrective Action Site Plan” dated May 7, 2004 for the Kanakanak site. The plan proposes among other tasks, the tilling of the contaminated soil in the existing landfarm; excavation of test pits in the area of the old sewage treatment plant and the hospital to observe for free petroleum product (these are areas where free product had been detected in the past); excavation of about 20 cubic yards of contaminated soil from 10 areas that will be brought to the landfarm area for treatment; and, removal of 1,000 feet of abandoned fuel oil piping throughout the site.

Rich Sundet

5/27/2004

Update or Other Action

On 5/27/04, DEC conditionally approved IHS April 27, 2004 “Groundwater Monitoring Plan” at the Kanakanak Site and approved of the May 26, 2004 “Work Plan for Monitoring Well Installation” by Oasis on behalf of BBAHC for the Kanakanak Hospital Site. Oasis proposed to install 15 additional monitoring wells on site. IHS will monitor the existing wells and the 15 new wells as well as survey the wells.

Rich Sundet

6/15/2004

Update or Other Action

Project transferred from Sundet to Mike Jaynes. Sundet notified IHS and BBHS of the change in project managers.

Rich Sundet

7/6/2004

Update or Other Action

In a letter dated 7/6/04, DOL informed DEC that it received a check from BBAHC fro $1,0041.80 for its cost recovery bill sent to them.

Rich Sundet

1/10/2005

Meeting or Teleconference Held

Attended by phone latest meeting of Environmental Advisory Group (EAG). Informed of latest well sampling results and plans for the upcoming season. More well sampling to continue to establish trend for groundwater wells.

Mike Jaynes

3/2/2005

Meeting or Teleconference Held

Attended meeting by phone regarding last season's work and upcoming sampling by IHS. Some conflict as to sampling methods. Scheduled a meeting for 3/16/05 for resolving technical issues.

Mike Jaynes

3/17/2005

Meeting or Teleconference Held

Meeting with BBNHC (Operator of Site), IHS representatives, Oasis (BBHNC consultant) and ADEC PM in Anchorage. Asked each party to take a look at big picture for the site and take a look at overall progress. All parties looked at each of the ten AOCs and came to partial agreement on steps to final closure for the site. The EAG will be responsible for memorializing this document.

Mike Jaynes

5/10/2005

Meeting or Teleconference Held

Phone meeting with IHS representatives to discuss goals of AOC9 soil vapor testing proposal by Oasis Enviro. DEC goal for testing of AOC9 is to verify the air inhalation pathway is imcomplete.

Mike Jaynes

3/2/2006

Update or Other Action

Reviewed monitoring well data for the past 11 years and recommended IHS reduce their sampling to five wells, AP123, MW-02, MW-09, MW-10, MW-11 and reduce monitoring at wells MW-08, MW-12,MW-14, MW-15, WP-02,WP-03. Details in file. Review sent to EAG Workgroup.

Mike Jaynes

6/6/2006

Update or Other Action

2006 Monitoring Well sampling plan reviewed and approved by email.

Mike Jaynes

7/19/2006

Update or Other Action

Worked on EAG Action plan for the site. Site is now divided into 10 areas of concern (AOC) with known surface or subsurface petroleum contamination including 1) Previous above-ground fuel storage tank, 2) Footing drain for Building 318, 3) Previous sewage treatment plant (STP), 4) Building 301/401 complex, 5) Oil/water separator and containment pond, 6) Soil pad constructed of material excavated during construction of Building 401, 7) Site of the storage tank demolition at staff housing buildings 3 & 4, 8) Route of underground electrical conduit at the corner of parking area for Building 301, 9) Loading dock area between buildings 301 and 401, and 10) Site of the current 2,000 CY capacity, fenced, petroleum contaminated soil (PCS) land farm.

Mike Jaynes

8/22/2006

Site Characterization Workplan Approved

Reviewed the workplan, Draft 2006 Environmental Monitoring and Remediation Work Plan, Kanakanak Hospital received by email on August 11, 2006. The plan discussed this year’s project objectives – a Soil Vapor Extraction system pilot test, quarterly vapor monitoring of the Building 301 and 401 crawlspaces, and groundwater level monitoring. Workplan approved with minimal comments.

Mike Jaynes

8/28/2006

Update or Other Action

New Cost Recovery Memo sent to Pamela Post at AG's office. Letter is on G drive at G:\SPAR\CS\Contaminated Site Files (38)\2540 Dillingham\2540.38.005 Kanakanak Hospital\Cost Recovery Memo Kanakanak Hospital 082806.doc

Mike Jaynes

2/15/2007

Meeting or Teleconference Held

CS personnel attended a meeting of the Environmental Advisory Group (EAG) in Anchorage. The group reviewed and updated the EAG Strategic Plan for monitoring and remediation at sites in the hospital vicinity. The need for remedial action was discussed at a few of the petroleum contaminated sites, although final decisions were tabled until new EAG members could become more familiar with the site history. Contractors to the Bristol Bay Area Health Corporation summarized their findings from 2006 field work, including SVE pilot testing and soil gas/indoor air sampling, and their recommendations for future work.

Colin Craven

4/3/2007

Update or Other Action

ADEC submitted comments on the following four reports: Draft 2006 SVE Pilot Test Report, Final 2005 Soil Gas Survey Report, Draft 2006 Soil Sampling & Analysis Report, Draft 2006 Groundwater Monitoring Report. The most significant deficiencies were a lack of lab analytical data quality assurance checklists and conceptual site models. ADEC expects discussion of the comments within a month.

Colin Craven

9/24/2007

Update or Other Action

Contaminated Sites provided approval to the IHS (via email) for not conducting the 2007 round of groundwater monitoring to refocus resources on better defining long-term goals for the environmental restoration projects.

Colin Craven

2/6/2008

Meeting or Teleconference Held

Contaminated Sites and state epidemiologist Dr. Lori Verbrugge participated in a teleconference with the IHS, ANTHC, BBAHC and their contractors about the potential for vapor intrusion into hospital. Discussion centered around a report prepared by BBAHC contractors presenting a year's worth of crawl-space air sampling under the hospital buildings. The samples contained benzene, TCE, and PCE at low concentrations, but still exceeding EPA default screening levels for indoor air in a few samples. Dr. Verbrugge stated that the concentrations found were not of concern, but concurred with CS's recommendations for a few additional sample points to ensure that adequate coverage across the hospital was achieved. Both Dr. Verbrugge and CS will document their findings in letters to make the recommendations more specific.

Colin Craven

6/23/2008

Site Characterization Workplan Approved

ADEC approved a workplan developed by contractors of BBAHC to investigate potential petroleum contamination during the removal of three underground storage tanks, and potential petroleum and chlorinated solvent contamination in an utilidor excavation adjacent to the hospital.

Colin Craven

7/9/2008

Site Characterization Workplan Approved

ADEC approved the annual groundwater monitoring sampling and analysis plan submitted by IHS personnel.

Colin Craven

8/7/2008

Meeting or Teleconference Held

ADEC toured the hospital facilities and contaminated sites with IHS and BBAHC personnel. Time was spent mostly at sites covered in the strategic plan of the Env. Advisory Group (e.g. Areas 1, 3, 4, 5, 9 and 10) and the beach where debris and graves slowly are exposed as old unpermitted dumps erode. Locations for new monitoring well installations were identified for Area 3, and subslab soil gas monitoring point locations were discussed for Bldg 301 (Area 4 and 9).

Colin Craven

9/17/2008

Site Characterization Workplan Approved

Received the September 2008 Work Plan; 2008 UST removal report, and 2008 Soil sampling and analysis report. The work plan proposes to install additional monitoring wells, transfer soil for the soil stockpile to the remedial treatment area (RTA), pump and dispose of containment water from the RTA to the evaporation pond and dispose of debris from the eroding landfills. The UST removal report documents removal of 3 regulated USTs, an 8,000 gallon diesel tank near building 401, and a 1,000 gallon diesel, and 2,000 gallon unleaded gasoline tank from the south side of building 402. All samples collected from the 8,000 gallon UST removal were below ACLs for the site. Contamination beneath the tanks adjacent to building 402 exceeded ACLs for DRO, GRO, BTEX and 1 & 2-Methylnapthylene. Groundwater was not detected, but was likely less than 5 feet below the bottom of the excavation. The soil sampling at the RTA did not detect any contaminants above the ACLs. The site characterization described in the workplan has been delayed until summer '09. A combined approval and comment letter sent 12/1/08.

Kim DeRuyter

10/22/2008

Exposure Tracking Model Ranking

Initial ranking with ETM completed for source area id: 71661 name: Kanakanak Hospital

Kim DeRuyter

1/6/2009

Document, Report, or Work plan Review - other

Reviewed and Approved the 2008 Groundwater Monitoring Plan and updated the site summary

Kim DeRuyter

1/7/2009

Update or Other Action

Cleanup Complete wth ICs agreement for Area 1 sent to Indian Health Service, may need to be re-sent as signatory authority for IHS has not been determined.

Kim DeRuyter

1/8/2009

Meeting or Teleconference Held

Staff (DeRuyter, Vreeman) participated in a teleconference with BBAHC, ANTHC, OASIS, IHS to discuss the status of each area of concern, pending site closures, and reports reviewed in 2008. BBAHC was interested in recent DEC policy changes, such as the risk based approach to site closures, increased scrutiny of data quality,and changes to the site closure policy. IHS voiced concerns that institutional controls could hamper the property transfer to under CERCLA. BBAHC voiced concerned that staff turnover at DEC (7 project managers in the last 10 years) had caused delays in report review and increasing contractor and regulatory costs.

Kim DeRuyter

6/17/2009

Leaking Underground Storage Tank Cleanup Initiated - Petroleum

Reviewed and approved the Final Boiler Building Utilidor Excavation and UST removal report. Diesel and gasoline range organics were encountered in the smear zone at building 402. Groundwater characterization will take place this summer.

Kim DeRuyter

10/1/2009

Update or Other Action

Contaminated Sites staff received an update on the Indian Health Service (IHS) Kanakanak Hospital site in Dillingham. New monitoring wells were installed down gradient of the old sewage treatment plant to evaluate potential groundwater contamination between the former facility and Nushagak Bay. Soil borings were advanced down gradient of the hospital to assess potential soil contamination in the location of a proposed dental facility. Contamination was encountered in the borings and although analytical data is still pending, IHS is considering other locations for the dental facility to avoid potential indoor air quality concerns. The Alaska Native Tribal Health Consortium (ANTHC) has not conducted the sub-slab and crawl space monitoring planned for this summer. This sampling was proposed as a follow-up to the vapor intrusion evaluation conducted in 2007. Groundwater is several feet higher than normal at the site and staff has contacted ANTHC to urge that the samples be collected to document potential vapor intrusion during this unusual groundwater event.

Kim DeRuyter

10/2/2012

Document, Report, or Work plan Review - other

ADEC sent comments on the draft work plan for soil and groundwater investigation at Areas 2, 5 and 7. Soil borings will be advanced, monitoring wells will be installed, and soil and groundwater samples will be analyzed in order to further delineate contamination at each area. The work will be completed in early October. Additional investigation is planned for summer 2013.

Meghan Dooley

11/28/2012

Document, Report, or Work plan Review - other

ADEC received the Final Work Plan for the Kanakanak Hospital Site and approved it on this date.

Meghan Dooley

2/20/2013

Document, Report, or Work plan Review - other

Approval provided for the Final Vapor Intrusion Monitoring Work Plan for the Kanakanak Hospital Site, Dillingham, Alaska.

Meghan Dooley

7/24/2013

Document, Report, or Work plan Review - other

Draft report received: 2013 Soil Remediation Work Plan for the Kanakanak Hospital Site, Dillingham, Alaska.

Meghan Dooley

8/21/2013

Document, Report, or Work plan Review - other

Received: 2012 Annual Groundwater Monitoring Report.

Meghan Dooley

8/27/2013

Document, Report, or Work plan Review - other

Approval given for Final February and May Vapor Intrusion Monitoring Reports for the Kanakanak Hospital Site, Dillingham, AK.

Meghan Dooley

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

7/24/2014

Document, Report, or Work plan Review - other

Approved final 2014 Kanakanak Hospital UVOST Soil Characterization Work Plan.

Meredith Savage

7/29/2014

Meeting or Teleconference Held

Teleconference held with representatives from ADEC, Indian Health Services, Bristol Bay Area Health Corporation, and ERM Consultants. Site status discussed: Area 1- cleanup complete with Institutional Controls (ICs); Areas 2 and 7- proposed for cleanup complete with ICs, Areas 3, 4, 8, 9, 11- remedial action ongoing; Area 5- remedial activities being evaluated; Area 6- cleanup complete; Area 12- stockpiled soil to be removed to the remedial treatment area (RTA).

Meredith Savage

8/4/2014

Document, Report, or Work plan Review - other

Received electronically: Draft Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska. The work plan outlines sampling efforts to be conducted at two sites within the Kanakanak Hospital property: a proposed new dental clinic and a proposed new boarding facility. Both proposed structures would be located within known petroleum product contaminated areas: dental clinic-Area 3, boarding facility-Area 4. The sampling effort is part of an overall geotechnical sampling activity and will help identify the likelihood of encountering contaminated soils during future construction activities.

Meredith Savage

8/6/2014

Meeting or Teleconference Held

Teleconference held with representatives from ADEC, Indian Health Services, Bristol Bay Area Health Corporation, and ERM Consultants. Meeting held to discuss current soil screening and sampling efforts, and locations for additional sampling.

Meredith Savage

8/11/2014

Document, Report, or Work plan Review - other

Received electronically on 8/04/204: Revised Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska. ADEC comments provided on 8/05/2014. Final work plan received electronically on 8/07/2014. Final approval provided on 8/08/2014, contingent on one additional change. Received electronically on 8/11/2014: Final Revised Work Plan for Environmental Soil Sampling at 6000 Kanakanak Road, Dillingham, Alaska

Meredith Savage

10/8/2014

Document, Report, or Work plan Review - other

ADEC received the Final 2013 Annual Groundwater Monitoring Report on September 30, 2014. This report addresses field activities completed at the Kanakanak Hospital project site in September 2013 and presents water level gauging data, well point installation and development data, and groundwater sample analytical results for Areas 2, 3, 4, 5, 7, 8, 9, 11, and the Beach area. Areas 2 and 7 have been recommended for closure and the decommissioning the groundwater wells; Areas 3, 4, 8, 9, and 11 have been recommended for continued annual groundwater monitoring; and Area 5 is recommended for remedial work (addressed in a separate report) and groundwater monitoring in 2016.

Meredith Savage

8/7/2015

Update or Other Action

Transfer to Fairbanks

Susan Carberry

9/10/2015

Update or Other Action

Had phone conversation with ERM contractor, in which it was determined that analytical samples would be taken of water coming from Building 401 footer drain in support of characterization and eventual closure for this Area of Concern. Samples will be taken prior to passing through the oil-water separator outside Area 5. Samples would be analyzed for DRO/RRO, VOCs, and PAHs. Analytical results would be used to calculate TAH and TAqH values. DEC proposed quarterly sampling; awaiting concurrence from BBAHC on sampling frequency.

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

9/22/2017

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

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

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

10/19/2018

Document, Report, or Work plan Review - other

DEC approved the Kanakanak Hospital Area 11 Vapor Intrusion Monitoring Work Plan, dated October 16, 2018. The document describes proposed vapor intrusion activities at Area 11 of the Indian Health Service (IHS) Kanakanak Hospital site located approximately 3 miles southwest from Dillingham, Alaska. The intent of the above-referenced work plan is to assess if vapor intrusion is occurring at Building’s 310 and 402, and to determine whether interior vapor concentrations pose a potential health risk to the people using the buildings now or in the future. The proposed work includes drilling two permanent soil-gas monitoring points (one on the exterior south side of Building 310 and Building 402) and collecting indoor air samples from within the crawlspaces and breathing zones of the two buildings.

Erica Blake

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

11/13/2019

Document, Report, or Work plan Review - other

DEC approved the Kanakanak Hospital Area 11 Vapor Intrusion Monitoring Report, Dillingham, AK, Dated November 2019. This report details findings from a vapor intrusion (VI) assessment at Area 11 of Kanakanak Hospital in Dillingham, Alaska. The VI assessment was conducted in November 2018 to evaluate whether underlying petroleum contamination was resulting in a vapor intrusion concern at commercially-used Buildings 310 and 402 in Area 11 of the Kanakanak Hospital. Building Inventory and Indoor Air Sampling Questionnaires were completed for both buildings. Additionally, soil gas monitoring points were installed and soil gas samples were taken. Photoionization detector (PID) surveys were conducted inside each building, and indoor air samples were collected at locations with the highest PID readings. No exceedances of DEC target levels for commercial indoor air for petroleum contaminants were observed, although dichlorodifluoromethane (Freon 12) equaled the DEC target level in one soil gas sample. DEC concurs with the recommendation for at least one more sampling event to capture seasonal variation in vapor intrusion and confirm that Freon 12 VI is not posing an unacceptable risk to human health.

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

6/10/2020

Document, Report, or Work plan Review - other

DEC Approved the Final May 2019 Interim Report, which detailed multi-incremental soil sample results to assess whether the contaminated soil in the Area 6 and Area 10 landfarms that originated from Area 5 have been remediated below ACLs. Additionally, groundwater samples were collected and analyzed from seven monitoring wells at Area 5. 04MW-10 tested above CULs for benzene, ethylbenzene, and naphthalene. Finally, a bench test was performed to assess treatment options for the Building 401 footer drain. ERM recommends further groundwater monitoring, with ceasing sampling at two wells that have tested below Table C for several concurrent sampling events. The footer drain treatment system report is under review currently.

Tim Sharp

6/25/2020

Update or Other Action

DEC Approved the Final Kanakanak Hospital Preliminary Design Report for Building 401 Footer Drain. The Report presents results from a bench test from the effluent of the footer drain after aeration and settling, as well as a design to convert the onsite oil/water separator to an aeration system. There is a point of compliance downgradient of the aeration tank, and samples will be collected from prior to treatment as well as immediately after treatment. The bench test showed a reduction of contaminants in the footer drain effluent to below TAH and TAqH AWQS.

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

7/28/2020

Update or Other Action

DEC provided comments for the 2019 Draft Report for Area 5 Excavation and Area 11 Vapor Intrusion Monitoring. Comments included notes about the rescinding of the 1998 ACLs, clarification on concentrations of contaminants remaining in soil, landfarm contaminant concentration levels (Areas 6 and 10), and requesting scheduling groundwater monitoring at these landfarms.

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

8/28/2020

Document, Report, or Work plan Review - other

DEC approved the 2019 Final Report for AOC 5 excavation and AOC 11 VI Monitoring. 2750 cy of contaminated soil was transferred to the AOC6 and AOC 10 landfarms, but more contamination remains at the extents of the excavation. Naphthalene and ethylbenzene were detected in Building 402, but may be attributable to background sources. Another round of sampling is recommended. Groundwater monitoring in AOC 5 and near the landfarms is also recommended. IHS, ERM, and BBAHC will prepare ACLs using the HRC, and once those have been agreed upon, further remedial actions will be planned.

Tim Sharp

9/2/2020

Exposure Tracking Model Ranking

A new updated ranking with ETM has been completed for source area 71661 Kanakanak Hospital.

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

10/20/2020

Meeting or Teleconference Held

DEC met with ERM, IHS, and BBAHC representatives to discuss the Development of ACLs Plan memorandum. Topics covered included EPH and VPH sampling in Area 5 and alternatives, TOC soil collection method 415.1 modified (typically a water sampling method), aquifer thickness variability across the site (20 feet seems conservative for the model), and validity of the use of samples taken in 1994 (range of data and selection qualifiers are acceptable). Some data gaps were discussed, along with MAC exceedances and what that means for the future of management of the site. DEC will discuss the MAC exceedances internally to determine if EPM II or III approval is necessary. Overall the methods proposed seem sound.

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

3/17/2022

Document, Report, or Work plan Review - other

DEC sent comments on the Draft Supplemental Site Investigation Work Plan. Soil and groundwater samples will be collected from all AOCs on the CSP database (so excluding Areas 11 and 12) to further characterize contaminants at the site and develop new alternative cleanup levels (ACLs) using the Hydrocarbon Risk Calculator (HRC).

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

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Site Report: IHS Kanakanak Hospital - Area 4 & Sitewide Record

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