| Action Date |
Action |
Description |
DEC Staff |
| 12/22/1976 |
Update or Other Action |
Memorandum of Understanding Pribilof Land Selections. Future Transfers. NMFS agrees to effect in the future to the Tanadgusix Corporation of such houses or other buildings on St. Paul Island as may become unnecessary to the carrying out of NMFS responsibilities under the Fur Seal Act of 1966, 16 U.S.C. 1151, or its successor statute. Such transfers will be carried out by applicable law and regulations.
Joint Use Areas. Areas not shown on Exhibits. Further areas not shown on the attached exhibits which are available for selection by the appropriate Village Corporation, but subject to joint management (category 3 of paragraph 1b above) are as follows: 1) Polovina/Big Lake "Vehicle Boneyard" (Truck Dump)-St. Paul, Scoria Pits. The Telegraph Hill, Polovina and Lake Hills Borrow (scoria) pits on St. Paul are being retained by NMFS subject to joint management, namely TDX Corp. may use scoria from these pits free of charge, subject to priority use by NMFS, for so long as these pits are under control of NMFS. Sanitary Landfills and "Vehicle Boneyards" (truck dumps) which are subject to joint management may be used free of charge for their intended purposes by the nonowning party. |
Louis Howard |
| 12/30/1984 |
Update or Other Action |
According to the "Transfer of Property Agreement" signed in 1984, the United States agrees to convey the certain real properties on St. Paul Island, Alaska to the local and state entitites. These entities agree to accept all right, title, and interest to the real property.
The United States shall retain all rights, title, and interests to the following real property located on St. Paul Island, Alaska: Zapadni-Tolstoi fur seal rookery, Zapadni Rookery Joint Use Area, Reef Rookery, Lukanin-Kitovi fur seal rookery, Polovina fur seal rookery, Northeast Point fur seal rookery, Northeast Point Rookery Joint Use Area, portions of Parcel 14 (NMFS Staff quarters, NMFS office bldg., and GARCO bldg. with 20 ft. perimeter around each and rights-of-way), the National Weather Service Station Site, the U.S. Coast Guard LORAN station, the U.S. Coast Guard navigation beacon site, and the portion of Parcel 10 remaining after conveyance to the State of Alaska (e.g. buildings and grounds of the hospital). |
Louis Howard |
| 4/27/1986 |
Update or Other Action |
Tanadgusix (TDX) Corporation P.O. Box 88 Saint Paul Island 99660 907-564-2312 sent in an ADEC solid waste management permit application for domestic and commercial refuse for an unpermitted existing facility. WWII debris disposal is about 8 miles from the village of Saint Paul. 1,300 cubic yards estimated to be disposed of in a one time event. 99% of the wastes are categorized as demolition waste and 1% as ash and incinerator waste. Junk vehicles will also be a part of the waste stream. Predisposal processing methods will include: incineration, separation/segregation and crushing.
Disposal Site Plan-waste will be brought to the site by dump truck along with some construction remains and considerable scrap metal, a majority of the debris will be crushed metal drums and the hazardous and toxic waste will have been removed at the cleanup and loading site. Site is located 8 miles from village of Saint Paul. It is used as a vehicle dump and carcass (bone) dump from fur seal operations that are long established. Cover over of debris waste dumped under this permit will improve visibility somewhat, however the site does not impact visually from the Village of Saint Paul. No visual screening will be undertaken. 8. Control of pollution: Nature of debris disposal is mainly scrap metal from which identification and disposal of hazardous waste and/or toxic waste has been removed. Surface Pollution: site is a pit. Finish grade to avoid surface run off. No hazardous or toxic debris will be deposited. Litter: this is mainly a scrap metal drum site. Odor: The odor of rotting carcasses will be eliminated with this use, as it will be covered with debris and fill.
D. Geologic/Hydrologic Report: site consists of mainly sand. Leaching of waste into ground water will undoubtedly occur. However, hazardous materials will be removed from waste, which will be mainly scrap metal. Depth to groundwater is unknown without well, we would like to avoid this cost. Tests and evaluation will be prescribed in the contract and regulatory conditions for the job. By removal and consolidation of the WWII debris and waste to this location, the potential for leachate pollution of existing on island water supply will be decreased as a result of the removal.
This site has been used as a dumpsite for scrap autos and seal harvest waste products for at least 30 years (if not more.).
Depth of final soil cover-After deposit of debris site will be covered with clean fill (scojia-scoria, clay and available fill) and seeded for vegetative restoration. No monitoring devices are contemplated at this time. Use of the site will continue as in the past. There is no applicable Coastal Zone regulatory program in place at this time.
Signatures: Letter from local government-has been requested and is forthcoming under separate cover. A land use consent from the Pribilof Island Joint Management Board is also being forwarded. |
Ray Dronenburg |
| 4/28/1986 |
Update or Other Action |
Robert Flint Regional Program Coordinator 4/28/86 letter to Allen Gavle Chase Construction Inc. regarding Solid Waste Management Permit Application Number 8521-BA019 Saint Paul DERA Project. ADEC received the application for a SW permit for the cleanup and disposal of barrels and other abandoned military debris on Saint Paul Island and the final disposal of these debris in the old carcass pit located near the junk car "bone yard" (now TPA 2 STP Vehicle Boneyard Site) and have determined it to be complete. ADEC will be sending your application through the review and public notice process. During the approximately 60 days that this process requires, you may be contacted by the Department staff to clarify points in your application. At the end of this time, a decision on your application will be made by the Department. Questions to be directed to Henry Friedman. |
Bob Flint |
| 4/30/1986 |
Update or Other Action |
Bill Lamoreaux Regional Supervisor sent a memorandum letter dated 4/28/86 to the H&SS, DNR,DF&G, L&WM/DNR, DCRA and cc'd the Anchorage Western District Office who received it on 4/30/86. Attached is an application for a Solid Waste Disposal Permit from Chase Construction Inc. The application is to be issued in conjunction with the Defense Environmental Restoration Account (DERA) project cleanup of Saint Paul Island. The cleanup involves the landfilling of over one thousand empty barrels and other abandoned debris. Liquids and hazardous wastes will not be permitted in the landfill.
The department is required by statute to send a copy of the application to you and to consider your recommendations in our permit decision. As this project lies within the coastal zone boundaries, its consistency with the Alaska Coastal Zone Management Program or the local district coastal management program must be addressed in your review.
We request you and your staff review this application and send your comments to the department within 34 days of the date of this letter. Requests for additional information must be received within 25 days of the date of this letter. |
Bill Lamoreaux |
| 6/5/1986 |
Cleanup Plan Approved |
ADEC Bill Lamoreaux regional supervisor sent letter and approval for waste disposal permit application ADEC file # 8521-BA019 to Chase Construction Inc. 201 East 3rd Avenue, Alan Gayle. ADEC has reviewed your Waste Disposal Permit Application for landfilling abandoned debris on Saint Paul Island. Based on ADEC's evaluation, Permit Number 8521-BA019 is hereby granted. Note conditions in appendices A and B. Permit expires on June 30, 1988 and must be renewed by that date for continued operation of the facility.
Appendix A
This permit is based on an application submitted on September 18, 1985 and as amended on April 9, 1986. Permittee must comply with that application and the document titled the Debris Cleanup and Site Restoration, Defense Environmental Restoration Account Contract Number DACA 85-86-C-0003, unless modified in this permit.
Permittee shall remove all: a. Debris specified in the Corps contract # DACA-85-86-C-0003 from the unpermitted waste sites. b. Soil saturated with petroleum products. c. Soil contaminated with waste defined under 18 AAC 60.087(b) as hazardous that has a contamination concentration exceeding 10 milligrams per kilogram (mg/kg or ppm) of any hazardous parameter. 2. The cement foundation at located at Zapadni Point may be buried on site. A final cover of at least two feet is required. 3. The permittee shall grade the cleaned up area to the natural contours of the area. 4. The permittee shall revegetate cleaned up waste sites with indigenous or existing plant species to prevent erosion.
C. Sampling of Existing Waste Sites: 1. Soil samples are to be taken in Site A (Dumpsite immediately east of the airport covering several acres with 1,000 or more drums several tanks and some machinery) and Site C (Telegraph Hill) where debris are removed and analyzed to verify that contaminated soil, defined in B.1.b and c of this permit has been removed. (NOTE: there are 9 sites on Saint Paul Island A-I referenced in the reconnaissance level survey for DOD debris just for Saint Paul Island). 2. A groundwater sample must be taken at three different locations surrounding site B (Tonki Point Dumpsite-scattered debris including two collapsed fiberboard structures and several pieces of heavy machinery are at this site), the main barrel dump (Telegraph Hill), and analyzed for hazardous waste contamination. If no groundwater is found above the bedrock layer, then water samples are not required. 3. Sample results and a map showing where individual samples were taken must be submitted to the DEC's Southcentral Region Office before the disposal site is closed.
D. Disposal Site Preparation- 1. Surface Water Runoff control: Permittee shall construct and maintain diversion structures (ditches or berms) if necessary to prevent surface water from entering the landfill area. 2. Permittee shall notify DEC's Southcentral Regional Office phone 274-2533, when disposal site use is initiated.
E. Site Operation-1. Burial of Demolition and General Debris Waste- Permittee shall: a. Ensure that all barrels and tanks are empty of liquids before crushing and burying; b. Crush and flatten all barrels and tanks; c. Consolidate and compact all deposited waste; d. cover paper and light objects with a minimum of six inches of earth material on the day of deposition to control litter; e. cover all waste with a minimum of two feet of earth material within 90 days after the last waste deposition; f. contour the final cover to prevent ponding and erosion and to minimize the amount of water entering the solid waste; and g. establish a vegetative cover over the closed waste disposal site, using plant species already existing on the island, within the first possible growing season.
2. Burning-Incineration of waste must comply with the Air Quality Control Regulations 18 AAC 50.040. The operation of an incinerator with a rate capacity of 1,000 pounds per hour or more, will require an air quality permit. Open burning of waste must comply with the open burning regulations 18 AAC 50.030.
3. Litter-The permittee shall collect all litter in or adjacent to the facility and return it to the working face for burial.
For additional information see site file. |
Bill Lamoreaux |
| 9/30/1986 |
Update or Other Action |
The 1986 FUDS cleanup project included work on nine separate sites on the island. Based on all the information provided to date, the Corps has not demonstrated that the following areas were adequately characterized, cleaned up or closed: the LORAN Station at Southwest Point - FUDS site A in the 1985-86 cleanup, the Oil Drum Dump Site #1 - site B-1 in the FUDS cleanup, the Barrel Dumps north and east of Big Lake - sites B-2 and B-4 in the FUDS cleanup, and the FUDS Landfill created near the Big Polovina Hill Vehicle boneyard. The documents called for cleaning up hazardous spills and sampling to verify the level of cleanup. Site logs produced by the contractor show that some contaminated soil was excavated and transported to the solid waste disposal area a.k.a. FUDS landfill for disposal. It is unclear what types and concentrations of contaminants were present in the soil that was placed in the FUDS landfill |
Ray Dronenburg |
| 12/22/1986 |
Update or Other Action |
Covered by the Memorandum of Understanding among: TDX, TANAQ, and USDOC NOAA NMFS regarding Pribilof Islands Land Selections. Negotiations undertaken by the parties to resolve potential conflicts between village corporation and federal land selections on the Pribilof Islands under the ANSCA were successfully concluded during a third meeting held on St. George Island in June 1974. The Parties desired to record the items agreed upon during this meeting and during the two previous negotiating sessions held on St. Paul Island in April 1974 and in Seattle WA in February 1974.
The parties intend that this record of agreed items serve as a permanent background against which to compare and construe the land selection requests made by the parties to the BLM, Dept. of Interior, pursuant to the ANSCA.
Joint Use Areas: Further areas not shown on the attached Exhibits which are available for selection by the appropriate Village Corporation, but subject to joint management (*Category 3 of paragraph 1(b)).
*Not Withdrawn, subject to Joint Use Agreement, that is, land and any improvements thereon to be available for selection by the Village Corporation, but subject to joint management by the Pribilof Islands Joint Management Board pursuant to the agreement creating said Board.
Identified as Polovina/Big Lake "Vehicle Boneyard" (Truck Dump) - St. Paul. |
Louis Howard |
| 9/30/1991 |
Update or Other Action |
Referred to as "Site I Boneyard" in 9/30/1991 Preliminary Assessment Report. Discovery action entered in CERCLIS NFRAP Sites for Saint Paul Island EPA ID AKD983066127 on 11/01/1988. A preliminary assessment was entered in on 9/30/1991 for a no further remedial action planned determination under CERCLA. EPA's NFRAP designation will NOT relieve the facility from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket, but as noted earlier in the letter, will be listed for no further action. |
Jennifer Roberts |
| 1/8/1992 |
CERCLA PA |
EPA CERCLA (conducted by ADEC staff Jennifer Roberts during July 29 and 30, 1991 under contract to EPA) Preliminary Site Assessment Report December 1991 received by ADEC staff. The PA was conducted to identify potential public health and/or environmental hazards related to the site and, if present, identify the need for further investigative action. The PA is based on information derived from available files and literature pertaining to the site and a site visit.
Site G-Landing Craft in Saint Paul: There were 2 abandoned landing craft vessels in town. Both have been removed, one of which is now located in the boneyard (a.k.a. Site I or TPA-2 STP). Site I: Bone Yard-The DERA description says that there are several hundred DOD barrels at this site. This site has been used over the past several years as a household dump site by the island residents. It covers an extensive area; approximately 10 acres. There are household appliances, several old vehicles, batteries, and old motor oil drums that are broken up and appear to be empty. The smell of rotting seal carcasses was very strong. Recommendations: No further action is warranted under CERCLA program.
Nature of contamination and the low density population precludes further action under the CERCLA program. Recommendations for the Island: 1) the remaining drums be located and removed, 2) the reports of the bunker containing dynamite capes be verified, and 3) all explosives discovered be either removed by trained professionals or stored in accordance with current safety standards and codes (i.e. Standard Number: 1910.109 Standard Title: Explosives and blasting agents. Sub-Part Number: H Sub-Part Title: Hazardous Materials). |
Jennifer Roberts |
| 10/5/1992 |
Update or Other Action |
NOAA Letter to Eileen Olson regarding cleanup effort on Saint Paul Island for drums, tanks and equipment leftover from when the National Marine Fisheries Service ran the fur seal harvests.
As of September 29, 1992: 400 drums have been tested by Harding Lawson. Preliminary testing has found aviation gas, chlorinated solvents (i.e. cleaning agents) and flammable liquids (these will be positively identified with further lab tests). About 600 drums remain to be looked at. All of the drums will be drained into new 55 gallon drums and stored in the Vehicle Boneyard. 240 vehicles tanks were sampled, drained, and stored in 55 gallon drums (6 total). Six tanks (4 diesel and 2 gas) were drained and stored in 55 gallon drums at the vehicle boneyard. Anticipate this phase of the work to be done by fourth week of October. Contaminated soil was discovered and will be sampled to determine the extent of contamination in the next phase of work during October 6-8. |
Eileen Olson |
| 10/7/1992 |
Update or Other Action |
Draft Master Plan Pribilof Island Cleanup-WASC April 1993. Liability issues: Craig O'Connor 10/07/1992 memo states "The United States is liable under CERCLA for the costs of removing hazardous wastes from the Islands as the current owner and/or the owner at the time of disposal of the wastes. In addition, it is liable for natural resources damages occurring after December 11, 1980, as a result of releases of hazardous waste. In addition, the United States is liable under CERCLA as a current and/or past operator of a facility at which hazardous substances have been disposed of, with respect to the dumpsites and landfills operated by federal agencies or with the government's acquiescence.
The United States' liability under CERCLA will survive any transfers of title to the Pribilovians, and includes an affirmative obligation to perform all remedial action on lands conveyed to the Pribilovians deemed necessary after conveyance. In addition, CERCLA imposes certain hazardous waste disclosure requirements on any agreements for the sale of federally owned contaminated property and deeds conveying same. Finally, the United States' liability as a previous owner or operator also survives conveyance.
The United States may be liable under RCRA if it has obtained neither the requisite permit nor an executive exemption with respect to its landfill and disposal site activities on the Islands. In addition, the United States is likely liable under section 7003 of RCRA with respect to disposal sites which pose an imminent threat to human health or the environment, even where it has not undertaken active supervision or management of the site." |
Ray Dronenburg |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV).
In October 1992, Ecology & Environment, Inc. (E&E) performed a preliminary assessment at the Vehicle Boneyard. Site inspectors noted that the site contained construction debris, tanks, cement trucks, cranes, engine blocks, pipes, assorted heavy equipment, automobiles,
and household waste.
POL products have been removed from vehicles, so remaining sources are potentially petroleum contaminated soils and the potential asbestos containing materials. Recommended actions were to sample the surface and subsurface of the soils to determine the nature and extent of petroleum, oils, and lubricants (POL) and possible CERCLA contamination. |
Jennifer Roberts |
| 5/13/1993 |
Meeting or Teleconference Held |
4/23/1993 update-Scheduled to be bulked, sampled and removed as part of the bulking and sampling effort being proposed. (Minutes from 5/15/1993 Pribilof Island conference). |
Ray Dronenburg |
| 9/30/1993 |
Update or Other Action |
U.S. EPA letter from Mark Ader Federal Facilities Site Assessment Manager to Sharon Lundin Chief USDOC, WASC, Facilities and Logistics Division WC4, 7600 Sand Point Way NE, BIN C15700 Seattle WA 98115. The letter is to inform NOAA that EPA Region 10 has completed its review of the Preliminary Assessment (PA) for the currently owned portion of the Saint Paul Island National Marine Fisheries Site located on the Pribilof Islands. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility could score high enough to be proposed for inclusion on the NPL. Therefore, additional information is needed for EPA to complete the evaluation of the site. Specifically, a Site Inspection should be completed at the facility. Soil samples (surficial and subsurface) should be collected from the source areas to characterize the type of contamination present and delineate the size of the individual sources. Sediment samples should be collected from streams, wetlands and bays located near sources. Soil and sediment samples should be collected to determine background conditions for the area. All samples should be analyzed for the complete EPA Target Compound List (TCL) (organic) and Target Analyte List (TAL) (inorganic). Data generated should be equivalent to the Contract Laboratory Program (CLP) level 4 data quality. Please include the information requested on Enclosure A in the final Site Inspection report.
Section 120 of the Superfund Amendments and Reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an HRS evaluation. As such, EPA requests that you provide us with the above information within 180 days of receipt of this letter. If your facility anticipates an inordinate amount of delay in compiling this information, please send us with 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. EPA would like to be involved in the development of the work plan for the site. Please contact EPA to schedule a meeting to discuss sampling locations for the Site Inspection. |
Ray Dronenburg |
| 10/1/1993 |
Update or Other Action |
City of Saint Paul Public Notice to: Contractors/Regulatory Agencies. The City of Saint Paul hereby notifies you of the potential presence of hazardous materials on the island. The attached maps should be used as a general reference for identification of potential hazardous materials in planning your project. For the proposed utility projects within the Harbor Area planned for construction during the summer of 1993, the City does not believe that any hazardous materials are present. However, landowners and contractors are responsible for assuring compliance with federal and state regulations and should not rely on information provided herein.
If contractors on City Projects (and/or City Property) or on projects which are to become property of the City, believes that hazardous materials may or have been encountered, they must immediately cease any and all construction activity, immediately notify the Public Works Director and City Manager orally and in writing and comply with the attached guidelines. No further construction work can be done unless explicitly authorized in writing by the Public Works Director and City Engineer.
City of Saint Paul Hazardous Materials Procedures-
1) Review attached maps. If project includes construction within areas noted as potentially contaminated or if you encounter potential environmental contamination during construction, the following procedures must be followed:
2) Notify NOAA and the City of the potential problem;
3) conduct standard ADEC screening tests and provide in writing at a minimum-to NOAA and the City: a) exact location of area and land ownership, b) Quantity of material, c) Characteristics of material and contamination, d) documentation the contractor has certified persons to 1) conduct screening tests and 2) handling and disposal of hazardous wastes, e)Provide a detailed cost estimate for the initial screening, stockpiling, and testing of the material including labor, materials, equipment, testing, etc, f) provide a schedule for the final removal of any stockpiled materials, g) identify the location and specifications for stockpiling the materials.
4) If the material does not appear to require remediation according to ADEC and EPA regulations, the City Engineer and City Public Works Director will authorize the construction to proceed.
5) If the initial screening per ADEC and EPA regulations indicates that the material must be stockpiled for further testing (NOTE to file states Should not be removed until an approved plan is submitted), then the contractor must comply with the protocol approved by NOAA and the City. At a minimum, this protocol would include the stockpiling of excavated materials, the placement of an impermeable liner in the construction utility corridor, the installation of utility lines covered with non-contaminated materials, and the testing of stockpiled materials for analysis and disposal per ADEC and EPA regulations.
For additional information see site file. |
Ray Dronenburg |
| 10/19/1993 |
Update or Other Action |
Letter from DOC/NOAA WASC Sharon Lundin to U.S. EPA Mark Ader in response to the September 30, 1993 letter informing NOAA of the need to complete a Site Inspection (SI) for Saint Paul Island. NOAA recognizes its responsibility to comply with all statutory requirements under Section 120 of the Superfund Amendments and Reauthorization Act. However, there are some unalterable circumstances that will prevent NOAA from providing EPA the required information within the 180 days allowed in the regulation.
Saint Paul Island is located approximately 800 miles west of Anchorage, Alaska, in the middle of the Bering Sea. The island's location and arctic weather conditions provide a very limited construction season, usually a window from May until September. Additionally, because of the remoteness of the island, the availability of equipment is extremely limited. NOAA must lease equipment from the island entities (City of Saint Paul or TDX Corporation) for any work they do. Although this may sound like a simple process, they must compete with other contractors and/or City and Corporation for whatever equipment is available. This summer, the Island was in a boom period, with fisheries processing facilities being constructed around the clock. Because of this competition for equipment, it will be necessary for us to negotiate for its use far in advance of when we actually need it.
The current construction season has passed, to allow us the necessary time to schedule the equipment, NOAA requests an extension of 180 days. We anticipate beginning the planning process immediately. We will begin work as early as May, 1994 as weather permits. We will provide you with the information you have requested no later than August 30, 1994. Again, NOAA understands their obligation to comply with these requirements and will do everything they can to expedite the process of obtaining it. |
Ray Dronenburg |
| 11/2/1994 |
Update or Other Action |
EPA Mark Ader Federal Facilities Site Assessment manager sent letter to Sharon Lundin, Chief U.S. DOC Western Administrative Support Center, Facility and Logistics Division WC4, 7600 Sand Point Way, Bin C15700; Seattle, WA regarding EPA Region 10 has completed the review of Site Inspection (SI) for the currently owned portion of the Saint Paul Island, National Marine Fisheries Site located in the Pribilof Islands, Alaska. The report has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
RCRA ID AK0131490021 CESQG CERCLIS EPA ID AKD98306612-St. Paul Island and CERCLIS ID AK0131490021 USDOC NOAA National Marine Fisheries Service NFRAP. EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests your portion of the facility may score high enough to be proposed for the NPL, EPA must reevaluate accordingly.
EPA's NFRAP designation will NOT relieve NOAA from complying with appropriate Alaska State regulations. The Superfund amendments and Reauthorization Act (SARA) of 1986 Section 120(a) (4) requires federal facilities (including NOAA/NMFS) to comply with State cleanup requirements and standards when not listed on the NPL. This facility will not be removed from the Federal Agency Hazardous Waste Compliance docket.
NOTE To file: SEC. 120. FEDERAL FACILITIES.(a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.—
(1) IN GENERAL.—Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this Act in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act.
Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 and 107.
(2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.—
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this Act for facilities at which hazardous substances are located,
applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities
shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines,
rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this Act.
(3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility
which is owned or operated by any department, agency, or instrumentality of the United States.
(4) STATE LAWS.—State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) when such facilities are not included
on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than
the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.
|
Jennifer Roberts |
| 12/30/1994 |
Update or Other Action |
In the summer of 1994 Oil Spill Consultants (OSC) conducted an inspection of the Vehicle Boneyard and identified 213 drums at the site, 211 of which were mostly empty. The other two drums were filled with petroleum product. Field screening of the petroleum product revealed that it was noncombustible and nonreactive and did not contain polychlorinated biphenyls (PCBs) or chlorinated hydrocarbons. OSC removed all drums at the Vehicle Boneyard and shipped them to Basin Oil Company in Seattle, Washington, for disposal. |
Louis Howard |
| 2/24/1995 |
Update or Other Action |
Iliodor Philemonof (STG Tanaq Corporation) sent fax to Marianne See regarding Joint Management Board Meeting at West Coast International Inn March 21, 22, 1995. Draft agenda sent by Ron Philemonof CEO TDX Corporation. Requested ADEC presence for the meeting. |
Marianne See |
| 6/1/1995 |
Site Added to Database |
Site added to database. |
Ray Dronenburg |
| 1/6/1996 |
Update or Other Action |
Public Law 104-91-January 6, 1996.
SEC. 3. PRIBILOF ISLANDS. <<NOTE: Alaska. Hazardous wastes. 16 USC 1165 note.>>
(a) In General.—
The Secretary of Commerce shall, subject to the availability of appropriations provided for the purposes of this section, clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants, including petroleum products and their derivatives, left by the National Oceanic and Atmospheric Administration on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred or are obligated to transfer, to local entities or residents on the Pribilof Islands, Alaska, pursuant to the Fur Seal Act of 1966 (16 U.S.C. 1151 et seq.), as amended, or other applicable law.
(b) Obligations of Secretary.—
In carrying out cleanup activities under subsection (a), the Secretary of Commerce shall--
(1) to the maximum extent practicable, execute agreements with the State of Alaska, and affected local governments, entities, and residents eligible to receive conveyance of lands under the Fur Seal Act of 1966 (16 U.S.C. 1161 et seq.) or other applicable law;
(2) manage such activities with the minimum possible overhead, delay, and duplication of State and local planning and design work;
(3) receive approval from the State of Alaska for agreements described in paragraph (1) where such activities are required by State law;
(4) receive approval from affected local entities or residents before conducting such activities on their property; and
(5) not seek or require financial contributions by or from local entities or landowners.
(c) <<NOTE: Reports.>> Resolution of Federal Responsibilities.—
(1) Within 9 months after the date of enactment of this section, and after consultation with the Secretary of the Interior, the State of Alaska, and local entities and residents of the Pribilof Islands, the Secretary of Commerce shall submit to the Committee on Commerce, Science, and Transportation of the Senate, and the Committee on Resources of the House of Representatives, a report proposing necessary actions by the Secretary of Commerce and Congress to resolve all claims with respect to, and permit the final implementation, fulfillment and completion of--
(A) title II of the Fur Seal Act Amendments of 1983 (16 U.S.C. 1161 et seq.);
(B) the land conveyance entitlements of local entities and residents of the Pribilof Islands under the Alaska Native Claims Settlement Act (43 U.S.C. 1601 et seq.);
(C) the provisions of this section; and
(D) any other matters which the Secretary deems appropriate.
(2) The report required under paragraph (1) shall include the estimated costs of all actions, and shall contain the statements of the Secretary of Commerce, the Secretary of the Interior, any statement submitted by the State of Alaska, and any statements of claims or recommendations submitted by local entities and residents of the Pribilof Islands.
(d) Use of Local Entities.—
Notwithstanding any other law to the contrary, the Secretary of Commerce shall, to the maximum extent practicable, carry out activities under subsection (a) and fulfill other obligations under Federal and State law relating to the Pribilof Islands, through grants or other agreements with local entities and residents of the Pribilof Islands, unless specialized skills are needed for an activity, and the Secretary specifies in writing that such skills are not available through local entities and residents of the Pribilof Islands.
(e) Definition.--For the purposes of this section, the term ``clean up'' means the planning and execution of remediation actions for lands described in subsection (a) and the redevelopment of landfills to meet statutory requirements.
(f) Authorization of Appropriations.--There are authorized to be appropriated not to exceed $10,000,000 in each of fiscal years 1996, 1997, and 1998 for the purposes of carrying out this section. |
Jennifer Roberts |
| 5/2/1996 |
Site Ranked Using the AHRM |
Ranked by Shannon and Wilson |
S&W |
| 1/17/1997 |
Document, Report, or Work plan Review - other |
Letter to Minh Trinh NOAA PPO PM, UST comments to be covered under separate comment letter relating to any and all activities relating to removal of USTs. Comments mainly for portion of the plan that deals with debris removal and stockpiling of contaminated soils.
a) The stockpile plan identified in section seven (7) is approved as written.
Debris Removal (vehicles). The Department does not assume nor will the contractor "assume" that vehicles identified as debris under the TPA are free from hydrocarbons. In fact, the Department will require that all vehicles be checked for fluids before being compacted and stockpiles for shipment off island.
Open Burning. The department has promulgated new regulations regarding open burning. The document dated January 18, 1997 has been provided by the contractor. |
Ray Dronenburg |
| 7/21/1997 |
Update or Other Action |
RA Environmental submitted a corrective action plan for the stockpiled drums and contaminated soils near the Vehicle Boneyard. The document is actually a transportation and long-term stockpiling plan for the contaminated soils. Source of contaminated soils was from a spill that occurred from previous spills at the POSS camp site drums of which TDX is the landowner. During 1996 142 cubic yards of contaminated soils were excavated. However, further excavation is required at the POSS spill site to remove all soils above 1,000 mg/kg DRO. |
Ray Dronenburg |
| 12/19/1997 |
Update or Other Action |
Simon Mawson ADEC Letter to NOAA dated December 19, 1994 to Kelly Sandy-Re: outstanding issues regarding the substantial endangerment as it applies to the school yard dump and whether or not the State of Alaska solid waste disposal regulations require excavation of and removal of the solid waste in old dumps for closure purposes.
NOAA's letter 12/8/1994 from Kathleen Chorestecki seems to limit NOAA's concern to subsidence at the old dump and safety issues that may be associated with subsidence. Her letter indicates that this matter seems to be "driving factual element" behind the substantial endangerment argument and that "rumors" of subsidence cannot be substantiated. ADEC does not agree that subsidence is the only concern or even the primary concern. For many years the island of Saint George was operated by NOAA. There is no indication it was NOAA's practice to export waste materials from the island. To the contrary, the presence of three dumps (*note to file-see TPA 4 STG Active landfill, TPA 5 STG Open Dump Site, TPA 7 Ballfield and Former landfill on STG) tend to support the argument that these wastes materials were routinely disposed of on the island.
These wastes would be those typical of operation of a small municipality and fur seal harvesting operation. NOAA leased houses to the island residents and operated all of the utilities in support of the community. All fuel, solvents, medical supplies and equipment were shipped to the island primarily by barge. Wastes were disposed of by generally accepted practice at the time of operation which was in the dumps. Additionally, residue from spills typical of bulk fuel storage operations at the time were also not cleaned up. It is the disposition of these materials that gives ADEC primary concern for risk to residents of the islands, not just subsidence of the approximately 3,000 drums that were disposed of in the schoolyard dump.
18 AAC 60 Article 4 is the regulation that describes actions that must be taken for closure of solid waste disposal facilities. These regulations do not require that solid waste materials be excavated and removed for proper disposal from illegal dumps. Rather they describe some specific criteria and performance measures that must be met when dumps are closed out. These regulations do not preclude excavation and proper disposal of waste materials and based on the evaluation of alternatives and costs associated with each alternative as well as location of the illegal dump, excavation and removal of these materials may be the preferred and required alternative. Several requirements of 18 AAC 60 should be considered, 18 AAC 60.401(b)(4) "ensuring that the cap is revegetated or otherwise treated in a manner appropriate to the long term use of the facility" as well as the long term monitoring requirements. |
Simon Mawson |
| 12/29/1997 |
Update or Other Action |
In 1997, Bering Sea Eccotech, Inc. (BSE) removed bulk surface debris from the Vehicle Boneyard and smaller amounts from several other sites as part of a Phase I cooperative agreement with NOAA (Aleutian Enterprises 1998). During the debris removal, NOAA removed 2,359.3 tons of steel, 88.2 tons of tires, and 8.75 tons of batteries for off island recycling and disposal (BSE 1997). Soil samples were not collected during the debris removal. No visually stained soils were identified during the debris removal project. After the surface debris was removed, BSE attempted to revegetate the area using native flora. |
Ray Dronenburg |
| 3/9/1998 |
Update or Other Action |
Workplan for environmental sampling during removal action at the site received. Soil samples for VOCs, SVOCs, Organic PCBs, Pesticides, Metals, TPH, GRO/BTEX, DRO, RRO, were included in the plan. However, in the NOAA scope there were no provisions for laboratory analysis, or site characterization since it mainly focused on debris removal. |
Ray Dronenburg |
| 3/19/1998 |
Update or Other Action |
1997 Aleutian Enterprises (Bering Sea Ecotech/Bristol Environmental JV) NOAA Debris Cleanup Project close-out report received. The site contained the majority of the debris that was to be removed. Miscellaneous metallic debris and vehicles were removed from the surface. No screening for contaminated soils or confirmation soil samples were taken nor were any attempts to dig or determine if there were other debris buried at the site. |
Ray Dronenburg |
| 5/8/1998 |
Update or Other Action |
John Halverson sent letter to Department of Army Corps CEPOA-PM-E-F (Chivvis) regarding Saint Paul and Saint George FUDS. There have been numerous questions raised regarding the FUDS program cleanup on the islands during 85-86. ADEC has corresponded in the past (i.e. Telegraph Hill), however more information is needed to be compiled and made available to ADEC and the restoration advisory board to address the questions being asked.
One specific area of concern is the FUDS landfill built near the boneyard (TPA #2 Vehicle Boneyard Site) by Chase Construction. Corps staff inspected the site in 1996 and reported it was adequately covered and vegetated. However, the solid waste permit issued for the work specified that three monitoring wells be installed around the site and monitored for minimum of 3 years (see permit# 8521-BA019 June 5, 1986). ADEC does not have the information showing that the wells were installed or sampled. Since drinking water on the island is obtained from a sole source aquifer, there is a concern over any contaminants that are, or could, impacting the aquifer. If the wells were not installed and monitored, that work still needs to be done.
Additionally, ADEC has very limited information on FUDS cleanup work done on the islands. This letter is a request that records be compiled and made available for our review and copying. ADEC needs to determine and agree whether any additional investigation and/or cleanup are necessary. If additional fieldwork is necessary, coordinating it with NOAA's work would likely make it much more cost effective. If additional fieldwork is not needed, ADEC needs to be able to provide sufficient information to the RAB to address its concern. |
John Halverson |
| 5/20/1998 |
Update or Other Action |
Laura Ogar Solid Waste Program re: Expectations for Remaining Work and Regulatory Compliance for Solid Waste Projects Pribilof Islands. Of primary importance to the Department will be NOAA's assessments of the source areas (SA) to identify the extent of solid waste and any solid waste impacts at each site. Specific expectations for the SA's include:
Documentation at SA's containing buried waste must include and estimation of the footprint area and depth of the waste material and include the site longitude and latitude to accurately identify the waste disposal area. Information on groundwater (depth to, gradient, etc,) must also be provided.
Information must be provided on the depth to groundwater as a potential receptor for contamination if buried waste is present and/or suspected surface contamination is sufficient to warrant concerns for leaching. Where surface debris has been removed, the Site Investigation will be required to include evidence to support a conclusion that surface contamination does not exist.
Any surface debris removal must be fully documented to include a description of the volumes and types of wastes removed, and identify the approved final disposal location of any wastes removed from a SA through tipping fees, shipping records, etc.
Locations where buried waste will remain in the ground, solid waste landfill closure standards of 18 AAC 60 must be met. Typical landfill closure standards include the placement of final cover over the buried waste footprint to minimize infiltration and erosion. The applicable closure standards for the individual sites should be discussed with the SW Program staff prior to the development of a closure plan being developed. A closure plan must be submitted to the SW Program for review and approval prior to work being performed.
Permanent markers or survey monuments must be established from which the exact location of a facility can be determined. A notation must be recorded on the deed of the property containing the waste disposal site stating that the land has been used as a landfill and future use of the land may be restricted in order to protect and maintain the final cover and any monitoring devices in place.
Post closure monitoring for a period of five (5) years following the placement of final cover and landfill closure. Post closure monitoring will include but may not be limited to annual visual monitoring of the sites and required looking for signs of damage settlement or erosion. Surface and or ground water monitoring may be required if the department finds that pollution from the facility is likely to endanger public health or cause a violation of the water quality standards in 18 AAC 70. |
Ray Dronenburg |
| 5/28/1998 |
Update or Other Action |
NOAA 5/21/1998 letter to Breck Tostevin Attorney General regarding Dronenburg letter 5/8/98 broadly asserting that NOAA is legally responsible for any possible environmental contamination which may have resulted from activities of the federal government on the Pribilof Islands.
NOAA asserts it is not, nor can be, legally responsible for any potential environmental contamination created by activities of other, unrelated federal agencies. NOAA cannot accept responsibility for the activities of the Army of Corps of Engineers. Signed Eva L. Dillard Attorney-Advisor Office of General Counsel Washington D.C. |
Ray Dronenburg |
| 7/16/1998 |
Update or Other Action |
CORPS Robert Chivvis 7/14/1998 letter to John Halverson regarding 5/8/98 letter requesting information on Corps cleanup work on Saint Paul and Saint George Islands. With regards to the 3 monitoring wells and monitoring requirements for 3 years, the Corps suggests ADEC address its concerns to the CORPS' contractor Chase Construction. They constructed the landfill and obtained the Permit to dispose of not only the CORPS' non-hazardous debris, but also other debris located on the island as directed by the local Native leaders. Information on all FUDS cleanup work done on the islands was compiled and made available to Ray Dronenburg who visited the Corps office last month (June 1998). He was satisfied with the information provided in order to address the subject at the next Pribilof Islands RAB meeting. |
John Halverson |
| 8/5/1998 |
Potentially Responsible Party/State Interest Letter |
John Halverson sent a potential responsible party notification letter to NOAA Mr. Minh Trinh. The letter is to advise NOAA that a pollution incident potentially exists for which NOAA may be a liable party. Potentially five (5) sites have been identified which are associated with the Army Corps of Engineers actions during a project which occurred in the 1980s. These sites are on NOAA property or property that were conveyed by NOAA to other parties. (Public Law 104-91 states, in part "The Secretary of Commerce shall clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants, including petroleum products and their derivatives, left by the National Oceanic and Atmospheric Administration (NOAA) on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred or are obligated to transfer, to local entities or residents on the Pribilof Islands, Alaska..." Consistent with the Two Party Agreement, the Department is requesting that all sites as determined by those data available be added to the agreement and investigation be conducted as appropriate to determine (a) the level of contamination, and (b) appropriate clean up action if required. Site description and location maps are attached for NOAA's information and no action dates have been established at this time. However, please respond in writing within 30 days from the date of this letter addressing your responsible party status and intended actions with respect to these pollution incidents. |
Ray Dronenburg |
| 9/1/1998 |
Update or Other Action |
NOAA letter dated 8/27/1998 from Thanh Minh Trinh regarding 8/5/1998 PRP letter notification.
While NOAA appreciate ADEC's need to remediate the sites, it is troubling to NOAA that a failure to follow through by the Corps on the pre-existing agreement with the Corps could result in this type of action against NOAA. During the negotiation of the TPA, it was NOAA's understanding that ADEC would pursue an independent course of action on the FUDS sites. It is still NOAA's position that this is the appropriate course of action.
The financial resources to address cleanup have come as special Congressional appropriations (NOTE: Not in the Department of Commerce Budget submitted by NOAA for the Pribilof Islands Agreement). NOAA does not have a congressionally supported and funded formal program for cleanup like the Corps and FUDS program. NOAA's position is that the TPA addresses all the requirements under Section (3) of PL 104-91. NOAA's position is that PL 104-91, as a federal law, does not give rise to any new authority for the State to compel remediation of another agency's former contamination.
It is doubtful that any additional funding will be made available for subsequent remedial actions when a Congressionally funded program already exists to address this issue (i.e. DOD/FUDS). In light of the foregoing, please be advised that NOAA will not entertain reopening the TPA to address these sites.
With regard to Alaska's separate action of pursuing NOAA as an owner/operator PRP under Alaska Statute, this matter has been referred to legal counsel for an analysis of sovereign immunity and potential referral to the Department of Justice. Initial reactions are that the State does not have authority to bring action against the Federal Government. This position is consistent with the underpinnings of negotiations undertaken with Breck Tostevin at the time of the TPA negotiation in 1995. |
Ray Dronenburg |
| 4/5/1999 |
Update or Other Action |
Project manager changed to Louis Howard from Ray Dronenburg. |
Ray Dronenburg |
| 5/11/1999 |
Update or Other Action |
ADEC (L. Dietrick) Director of SPAR sent a letter to Mr. John Lindsay Pribilof Project Manager NOAA, OR&R, Bldg. 4 7600 Sand Point Way, N.E. Seattle, Washington 98115: As required by paragraph 42 of the Two-Party Agreement you are advised that Mr. Louis Howard is hereby designated as Interim Pribilof Project Manager for the Department of Environmental Conservation. Please consider this modification to the agreement as effective May 15, 1999. As required by the agreement please direct all official communications regarding the agreement through Mr. Howard. |
Larry Dietrick |
| 8/23/1999 |
Site Characterization Workplan Approved |
Comments sent to be incorporated into TPA 2's closure confirmation sampling plan. |
Louis Howard |
| 8/27/1999 |
Update or Other Action |
Staff sent PRP Notification/Request for site characterization and possible remedial action for the Saint Paul Island Formerly Used Defense Sites (FUDS). ADEC does not agree with the Alaska District's position that no further work should be done under the FUDS program. Insufficient information has been provided to document that the FUDS were adequately cleaned up.
Therefore, the Department of Defenses has outstanding responsibilities for investigation and possibly cleanup on the Island. ADEC is requesting that the Corps, as DOD's agent for cleanup at FUDS, conduct additional work under the FUDS Program to complete site characterization and any necessary cleanup. ADEC requests that the Corps of Engineers work with NOAA to conduct site characterization and any necessary cleanup in these areas. Working together cooperatively will help ensure a timely and cost effective response. the Corps has not demonstrated that the following areas were adequately characterized, cleaned up or closed: the LORAN Station at Southwest Point - FUDS site A in the 1985-86 cleanup, the Oil Drum Dump Site #1 - site B-1 in the FUDS cleanup, the Barrel Dumps north and east of Big Lake - sites B-2 and B-4 in the FUDS cleanup, and the FUDS Landfill created near the Big Polovina Hill Vehicle boneyard. Telegraph Hill is located in the recharge area for what appears to be a surface influenced sole-source aquifer for the community of Saint Paul. The site is directly upgradient from the water supply wells. Periodic petroleum contamination has been documented in the water wells.
ADEC does not agree that FUDS on Saint Paul Island have been adequately characterized and cleaned up. ADEC requests that the Alaska District work with NOAA to ensure that all necessary site characterization and cleanup work is completed. This work needs to be done following plans reviewed and approved by ADEC, to ensure federal government's (including DOD's) responsibilities are addressed and that the sites are cleaned up to acceptable levels. ADEC requests a written response from the Corps on this matter by September 30, 1999. |
John Halverson |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. NOAA will receive site report 1/14/2000. NOAA needs to install monitoring wells at the site and desires to convey the site to the City of Saint Paul. |
Louis Howard |
| 12/15/1999 |
Update or Other Action |
ADEC responds to Corps letter of 11/10/99 which failed to address the legal and factual information contained in the 8/27/99 letter to the Corps. The response failed to address the site conditions, the potential threat to the community drinking water wells and the fact that insufficient documentation has been provided to demonstrate that the past FUDS cleanup work is protective of human health, safety, welfare and the environment. ADEC does not agree with the Alaska District's position regarding DOD's responsibility at these sites. |
John Halverson |
| 12/27/1999 |
Update or Other Action |
In 1999, Tetra Tech EM, Inc. (TTEMI), conducted closure confirmation activities at the site. TTEMI initially performed a visual site reconnaissance. After conducting the visual site reconnaissance, TTEMI personnel completed a site walk through the southwestern half of the site. During the site walk, TTEMI consolidated metal, wood, plastic, and rubber debris (mostly former car parts and heavy machinery). In total, TTEMI consolidated about 18,500 lbs. of debris. Any debris requiring the use of heavy equipment to conduct a removal action was left in place. All removed debris was transported to the designated debris staging area at Tract 38, along the northern side of Polovina Hill.
A direct-push sampler was then used to collect 20 soil samples from ten locations. Soil samples were collected from depths of 2 to 25 ft below ground surface (bgs). Groundwater was not encountered during this investigation. All of the samples submitted to the laboratory were analyzed for gasoline range organics (GRO); diesel range organics (DRO); residual range organics (RRO); and benzene, toluene, ethylbenzene, and xylenes (BTEX). In addition, 12 soil samples were analyzed for polynuclear aromatic hydrocarbons (PAHs), chlorinated solvents, and heavy metals.
The results of the Geoprobe samples indicated that elevated levels of DRO and RRO were present at one of the sampling locations in shallow soil (sample 02SS09 at 2 feet bgs), with DRO at 4,460 milligrams per kilogram (mg/kg) and RRO at 15,000 mg/kg (Figure 2-1). These levels exceed the ADEC Method Two cleanup levels at the Vehicle Boneyard for DRO and RRO of 250 mg/kg and 10,000 mg/kg, respectively. GRO, BTEX, PAHs, and chlorinated solvents were either not detected or were detected below their applicable ADEC Method Two cleanup levels. Metals were detected at levels within the range of island-specific background concentrations. |
Louis Howard |
| 7/25/2000 |
Update or Other Action |
Staff requested all of NOAA's budget requests made to congress since the agreement was signed in 1996 by both ADEC and NOAA for the environmental cleanup at the Pribilofs. It has come to DEC's attention that NOAA did not make a formal request for funding to Department of Commerce for FY 01 and possibly FY02 (federal fiscal years). This is not in compliance with the TPA which requires NOAA to request adequate funding to meet its obligations under the TPA. NOAA was counting on the U.S. congressional delegation to fund 12 million dollars as a special appropriation for the Pribilofs. The appropriation was much less-3 million dollars for October 2000 to September 2001. Deadline for NOAA to provide a written response was no later than August 18th. |
Louis Howard |
| 12/12/2000 |
Update or Other Action |
Site information update by staff from files. |
Louis Howard |
| 12/23/2000 |
Update or Other Action |
U.S. Congress passed Public Law 106-562 which states in section 107(f)(2) replacement language to PL 104-91 (16 USC 1165 note) is amended (1) by striking subsection (f) and inserting the following Authorization of Appropriations-(2) None of the funds authorized by this subsection may be expended for the purpose of cleaning up or remediating any landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, or contaminants, including petroleum products and their derivatives, left by the Department of Defense or any of its components on lands on the Pribilof Islands, Alaska. |
Louis Howard |
| 12/30/2000 |
Update or Other Action |
During the summer of 2000, Columbia Environmental Sciences Inc. (CESI) performed site characterization work at the site, including a geophysical investigation to locate subsurface magnetic anomalies indicative of buried debris; groundwater monitoring well installation, and soil sampling and analysis. Thirteen monitoring wells were installed from which 35 soil samples were collected during well boring operations. CESI also drilled 3 other soil borings from which 3 soil samples were collected.
The soil samples were analyzed for GRO, DRO, RRO, volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), heavy metals, and total organic carbon. None of the soil samples exceeded any of the ADEC Method Two cleanup levels. The groundwater wells were used for hydrogeologic testing, groundwater sampling, and groundwater analyses for GRO, DRO, RRO, VOCs, SVOCs, and heavy metals. None of the groundwater samples exceeded any of the ADEC Table C cleanup levels (ADEC 2003). Monitoring well MWVB-5 was installed but damaged due to driller mistakenly pumping grout into the well casing, clogging up the screened interval. This well could not be repaired to allow representative sampling, so it was not included in groundwater monitoring.
CESI concluded that:
-Buried and surface debris remains at the site.
-No site-related contaminants of concern that exceeded ADEC Method One or Method Two cleanup levels were present in soil at CESI’s sampling locations.
-No contaminants exceeded ADEC Table C cleanup levels in groundwater.
-Hydraulic conductivities range from 10-4 to 10-6 meters per year.
-The aquifer is tidally influenced, but the influence is damped.
-A groundwater divide is present at the site; groundwater flow west of the site is to the west; groundwater flow beneath the Vehicle Boneyard proper is to the east. |
Louis Howard |
| 3/28/2001 |
Document, Report, or Work plan Review - other |
Staff sent NOAA comment letter on TPA revised schedules for 2001 field season. It appears that NOAA is able to address some of the issues raised in our March 2, 2001 letter.
These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
With one exception, ADEC approves the new schedules, which now include projected work for many of the sites in the calendar year 2002 and beyond. The one exception is as follows:
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force Majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. With these new revised schedules, NOAA has shown it is planning beyond the current year of 2001 and ADEC appreciates the effort that it has gone in providing this information. As you know under section 81, we can adjust the long-term schedules in light of the results of future site investigation and clean-up work. |
Louis Howard |
| 5/25/2001 |
Update or Other Action |
Staff reviewed and commented on the groundwater monitoring plan which covered TPA 2, 5, 9, 11, 15. Comment was on the lack of current lab certification listed in table 10 for two labs. Staff requested proof of current certification and corrected table in the document with latest expiration date. |
Louis Howard |
| 12/30/2001 |
Update or Other Action |
Five rounds of groundwater monitoring were conducted at the Vehicle Boneyard as reported by IT Alaska Inc. Groundwater results from 2000 and 2001 did not detect any DRO nor any other contaminant above ADEC Table C groundwater cleanup levels.
In 2001, NOAA excavated approximately 75 test pits to an average depth of six feet bgs, to determine the locations of buried debris. NOAA surveyed the locations of all the test pits, and recorded which pits contained and did not contain buried debris. The area of buried debris is estimated at 0.9 acres. NOAA also recognized a larger area of small-sized ( approx. less than or equal to 6 inches in diameter) surface debris, estimated at 3.4 acres. |
Louis Howard |
| 2/11/2002 |
Document, Report, or Work plan Review - other |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 3/13/2002 |
Update or Other Action |
Staff inventoried all reports, studies, impact statements, and workplans related to St. Paul Island for Aquilina D. Lestenkof, ECO Co-Director, Aleut Community of St. Paul Island Tribal Government Ecosystem Conservation Office PO Box 86 St. Paul Island, Alaska 99660. They had requested on February 21, 2002 that ADEC provide a list of these documents to them. Their office is developing an Environmental Management Plan for the community of St. Paul Island. Having a list would help to properly site work that has been done and serve as a valuable resource for decision making in any future documents.
Staff inventoried the documents by various agencies on the island: NOAA, US DOD, Army Corps of Engineers, US Coast Guard, US Geologic Survey, City of St. Paul, Tanadgusix Corporation (TDX), State of Alaska-DOT&PF Division of Maintenance and Operations, ADEC.
It was sent it off to the tribal government via electronic mail and got confirmation and thanks the next day from the tribal government regarding the list. |
Louis Howard |
| 12/28/2003 |
Update or Other Action |
In October 2003 TTEMI, with subcontractor Kelly-Ryan Incorporated (KRI), performed site capping preparatory work by bulldozing surface debris in areas of potential dump truck operation to reduce the likelihood of dump trucks containing surface debris or capping material puncturing their tires. During bulldozing operations, KRI encountered a discrete area containing apparent asbestos-cement pipes and shingles within six inches bgs.
NOAA and TTEMI staff investigated this location and found that it contained both asbestos-cement pipes and broken Transite shingles. NOAA staff, certified in handling this type of asbestos-containing material (ACM), removed some of the loose ACM and containerized it. The loose ACM removed was subsequently disposed off-island. NOAA staff noted that the remaining ACM extends to an approximate depth of three ft bgs and is somewhat intermingled with inert demolition debris, like plywood. NOAA video-documented and surveyed the remaining ACM area and temporarily covered over the ACM with plywood and soil until a two feet thick soil cover could be placed atop the combined debris area. |
Louis Howard |
| 11/30/2004 |
Update or Other Action |
October 2004 NOAA Geoprobe sampling. NOAA conducted an additional round of soil sampling on October 9, 2004. NOAA used a hand operated geoprobe to collect 2 samples at each location, one from the 6 inch to 2 foot and one from 2 to 4 foot intervals. NOAA analyzed all of these samples using thin layer chromotography (TLC). The TLC analysis indicated DRO in 4 of these samples.
Lab analyses showed that DRO was detected at 1,700 mg/kg and RRO at 10,000 mg/kg. Method three calculator with site specific data determined that DRO alternative cleanup level was 2,920 and RRO was 22,000 mg/kg. NOAA sent aliquots of these 4 samples (with one duplicate) to an offsite laboratory for DRO and RRO analyses. In order to eliminate potential high bias of the analytical results due to the presence of other organic compounds in the samples, NOAA had the laboratory perform a “silica gel cleanup” on the samples prior to analysis. This step had not been performed during the previous lab analysis by Tetra Tech (TTEMI 2000). The NOAA off site lab results indicated that DRO exceeded the ADEC Method Two cleanup level only at the location and depth of the original Tetra Tech 1999 sample. NOAA’s results were significantly lower than the TTEMI 2000 results, with DRO at 1,700 mg/kg and RRO at 10,000 mg/kg (Table 1), and these levels did not exceed the site specific ADEC Method Three cleanup levels.
NOAA will also request a confirmation of closure of the Vehicle Boneyard from ADEC under separate cover, according to 18 AAC 60.490. NOAA will do the following:
Submit a post closure monitoring plan, proposing a program of visual monitoring of the integrity of the cap, to begin at a date to be suggested at that time.
Record a notation to the deed to the property, or other such instrument that is routinely examined during a title search, making notice of the location of the landfill. ADEC will be notified by NOAA in writing when the notation has been recorded.
Submit a report to ADEC at end of 60 months post closure monitoring period describing the site conditions and summarizing information collected during the monitoring period. |
Louis Howard |
| 1/14/2005 |
Document, Report, or Work plan Review - other |
ADEC letter to NOAA-RE: Draft Corrective Action Report TPA 2 - Vehicle Boneyard, St. Paul Island, Dated January 6, 2005. The Alaska Dept. of Environmental Conservation (the Department) received the above mentioned document on January 7, 2005. Based on the data for the Vehicle Boneyard (Site 2/Two-Party Agreement (TPA) Site 2) on St. Paul Island, the Department has concurs that no further remedial action is necessary. This determination assumes the debris will remain covered with a minimum of two (2) feet of soil which is vegetated to minimize soil erosion. NOAA should continue to monitor and improve revegetated areas until the grass provides sufficient surface coverage and root mass to prevent erosion due to wind and runoff.
This decision is based on the most current and complete data provided by NOAA. The Department reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require NOAA to perform additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. |
Louis Howard |
| 6/15/2005 |
Update or Other Action |
NOAA conditional closure request document for Vehicle Boneyard, also known as National Oceanic and Atmospheric Administration (NOAA) Site 2 and Two Party Agreement (TPA) Site 2 received. The site will be referred to as the Vehicle Boneyard herein.
Location: St. Paul Island, Alaska is approximately 800 miles southwest of Anchorage in the Bering Sea. On the island, the Vehicle Boneyard is located on the eastern portion of St. Paul Island north of Polovina Hill and south of Big Lake (57°11’25.50” North Latitude, 170°10’44.36” West Longitude).
Legal Property Description: The area of excavation is located in Township 34 South, Range 131 West, Section 34, of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 1986. Tanadgusix Corporation (TDX) owns the surface property and The Aleut Corporation owns the subsurface property at the Vehicle Boneyard. Type of Release: Potential release mechanisms include: 1) petroleum, oil and lubricant (POL) leaks associated with drums and vehicles disposed at this former “boneyard” and 2) asbestos-containing material (ACM) buried at the site.
NOAA first employed ADEC Method One cleanup criteria, discussed at 18 AAC 75.341(a) (ADEC 2003) to screen the severity of the contamination at the site. For benzene, under the TPA, NOAA had the option to cleanup to the less stringent State of Alaska cleanup level in effect in 1991 (ADEC 1991). Once NOAA determined that the area of contamination around sample 02SS09 was limited to a depth of 2 feet bgs, within a 100 square foot area, NOAA decided to use site specific data to calculate a cleanup level using the ADEC on line Method Three calculator (ADEC 2003). Based on ADEC Method Three, NOAA determined that the highest soil concentration of DRO and RRO allowable at the Vehicle Boneyard site is 2,920 mg/kg and 22,000 mg/kg (NOAA 2005). Cleanup criteria were applied to the maximum extent practicable (18 AAC 75.325 (f), 18
AAC 75.990).
In October 2003 NOAA contractor TTEMI, with subcontractor Kelly-Ryan Incorporated (KRI), performed site capping preparatory work by bulldozing surface debris in areas of potential dump truck operation to reduce the likelihood of dump trucks containing surface debris or capping material puncturing their tires. An estimated 2,750 cubic yards (yd3) of small surface debris and soil were relocated to the area of subsurface debris. The bulldozer also graded the surface debris areas to roughly match the grade of the adjacent undisturbed areas. This component
of the corrective action was completed on November 3, 2003.
On November 9, 2003 TTEMI, BSE and KRI began capping subsurface debris area as shown in Figure 5. An estimated 1,350 yd3 of clean scoria was placed atop the subsurface debris area, including the area of asbestos debris. TTEMI, BSE and KRI also hauled an estimated 2,750 yd3 of clean sand from Vic’s Sand Pit and placed it atop the subsurface debris area, bringing the thickness of the cap to at least 2 feet. Subsurface debris soil cover activities were completed on November 15, 2003.
No removal of contaminated soil occurred at this site. Soil contamination above ADEC Method Method Two levels for DRO and RRO exists at one sampling location northwest of the cover area. Site groundwater does not contain contamination above ADEC Table C cleanup levels, demonstrating that the one soil sampling location with elevated DRO and RRO does not represent a risk to groundwater. No further groundwater monitoring is necessary for the Vehicle Boneyard. NOAA used the ADEC Method Three calculator to calculate a site specific cleanup level for the Vehicle Boneyard site. NOAA believes that contaminant levels at the site are most accurately
depicted by the soil samples collected by NOAA in 2004. These samples do not exceed the ADEC Method Three cleanup levels.
In accordance with paragraph 59 of the Two Party Agreement (NOAA 1996), NOAA requests written confirmation that NOAA completed all appropriate corrective action under 18 AAC 75, to the maximum extent practicable, at the Vehicle Boneyard, NOAA Site 2/TPA Site 2 in accordance with the Agreement and that ADEC grant a conditional closure that soil and groundwater will not require further remedial action from NOAA. ADEC will require additional containment, investigation, or cleanup if subsequent information indicates that the level of contamination
that remains does not protect human health, safety, or welfare, or the environment. |
Louis Howard |
| 6/20/2005 |
GIS Position Updated |
Report from NOAA has updated location information. |
Louis Howard |
| 6/20/2005 |
Conditional Closure Approved |
Staff sent letter concurring no further remedial action is necessary at the site. This letter mirrors what was sent to NOAA on Jan. 14, 2005 commenting on the draft corrective action report. This no further action determination is assuming that the debris will remain covered with a minimum of two feet of soil which is vegetated to minimize soil erosion. NOAA should continue to monitor and improve vegetated areas until the grass provides sufficient surface coverage and root mass to prevent erosion due to wind and runoff. Groundwater monitoring results are below Table C cleanup criteria. However as a former landfill/dump, institutional controls will be in place stating that this is a former landfill and to not to excavate at the site.
This NFA decision is based upon the most current and complete data provided by NOAA. ADEC reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Subtances Pollution Control regulations and AS 46.03 to require NOAA to perform additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required:
1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1;
2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
Louis Howard |
| 6/20/2005 |
Institutional Control Record Established |
Land use controls are required. As a former landfill and part of the post closure monitoring plan, a program of visual monitoring of the integrity of the cap is required. A notation to the deed to the property will be recorded, or other such instrument that is routinely examined during a title search, making notice of the location of the landfill. ADEC will be notified by NOAA in writing when the notation has been recorded.
Submit a report to ADEC at end of 60 months post closure monitoring period describing the site conditions and summarizing information collected during the monitoring period. |
Louis Howard |
| 6/22/2005 |
Update or Other Action |
Year-One Monitoring
NOAA inspected the Vehicle Boneyard cap on June 22, 2005. It was observed that vegetation was growing well with some additional native species taking root to supplement the planted grass; additional fertilizer was deemed unnecessary; no cap erosion noted; maintenance was not deemed necessary. |
Louis Howard |
| 7/9/2006 |
Update or Other Action |
Year Two Monitoring
NOAA inspected the Vehicle Boneyard cap on July 9, 2006 with the following observations made:
a) Wind erosion had begun on a sand dune contiguous with the northeast end of the cap area. While no solid waste was located beneath the eroded area, if erosion continued southwesterly another estimated 10 feet it would have undermined the closure cap.
b) Island residents had used the level area adjacent the southeast edge of the cap area as
a carcass dump for the 2006 northern fur seal subsistence hunt. There was no apparent negative impact to the cap. |
Louis Howard |
| 9/14/2006 |
Update or Other Action |
Based on observations from the July 9, 2006 inspection, NOAA contracted with Bering Sea
Eccotech (BSE) to repair the eroded area. On September 13 and 14, 2006, BSE performed the following repair actions:
a) Armored the sand dune to prevent further erosion using approximately 140 cubic yards of scoria obtained from an off-site quarry.
b) Graded side slopes in the area to a maximum 3:1 (horizontal:vertical) slope.
c) Seeded the restoration area using approximately 7 pounds of government-furnished seed at a mixture rate of 35% boreal red fescue, 35% Bering hairgrass, and 30% beach wild rye. The seed was turned into the scoria by dragging a section of chain link fence behind an all-terrain vehicle.
NOAA and BSE applied 20-20-10 fertilizer to the cap twice during 2006 to promote vegetative growth. On July 9, 2006 and again on September 14, 2006, NOAA and BSE applied 500 pounds of fertilizer, for a total of 1,000 pounds applied in 2006. The September fertilizer event included application atop the repaired area. |
Louis Howard |
| 1/25/2007 |
Update or Other Action |
NOAA Year One and Year Two Annual Inspection and Maintenance Documentation Post-Closure Monitoring report received. Post closure monitoring began October 6, 2004 and is scheduled to end October 5, 2009. At the conclusion of the five year post closure monitoring period, NOAA intends to submit a report to ADEC describing the site conditions and summarizing information collected during the monitoring period.
On St. Paul Island, the Vehicle Boneyard is located in the eastern portion, north of Polovina Hill and south of Big Lake; 57 degrees 11' 25.50" north latitude, 170 degrees 10' 44.36" west longitude. The capped area is located in Township 34 South, Range 131 West, Section 34, of the Seward Meridian, Alaska, as shown on the plat of rectangular survey officially filed May 14, 1986. The Tanadgusix Corporation (TDX) owns the surface property and the Aleut Corporation (TAC) owns the subsurface property at the Vehicle Boneyard.
Year One: Vegetation is growing well at the site with some additional native species taking root to supplement the planted grass. No additional fertilizer is needed at this time. No erosion of the cap is evident.
Year Two: A blow out began on a sand dune contiguous with the northeast end of the cap area. While no solid waste is located beneath the blow out area, if erosion continues southwesterly an estimated 10 feet, it would undermine the closure cap. It may require about 100 cubic yards of scoria to repair the blow out given the current cap condition. Island residents used the level area adjacent to the southeast edge of the cap area as a seal carcass dump for the 2006 subsistence northern fur seal hunt. There is no apparent negative impact to the cap.
Blow Out Repair Actions (September 13, 14, 2006): Armored the sand dune blow out to prevent further erosion using approximately 140 cubic yards of scoria obtained from an off site quarry. Graded side slopes in the blow out area to a maximum 3:1 (horizontal:vertical). Seeded the restoration area using approximately 7 pounds of government-furnished seed at a mixture rate of 35% boreal red fescue, 35% Bering hairgrass, and 30% beach wild rye. The seed was turned into the scoria by dragging a section of chain link fence behind an all-terrain vehicle. A total of 1000 pounds of 20-20-10 fertilizer was applied to promote vegetative growth. |
Louis Howard |
| 6/4/2007 |
Update or Other Action |
Site conditions as of June 4, 2007: Buried solid wastes, such as metallic debris and an asbestos monofill capped by vegetated soil cover; post-closure cap monitoring until June 20, 2010; deed notice. NFRAP on June 20, 2005. Property owners as of November 6, 2007: TDX/TAC. |
Louis Howard |
| 9/3/2007 |
Update or Other Action |
Year-Three Monitoring
NOAA inspected the Vehicle Boneyard cap on September 3, 2007 and observed a barren area just east of the cap. NOAA had already applied 500 pounds of 20-20-20 fertilizer to the cap area in June 2007; the inspection report recommended application of seed and fertilizer to the barren area observed to the east of the cap. |
Louis Howard |
| 3/12/2008 |
Update or Other Action |
Notice to Deed for a Closed Inert Solid Waste Monofill Formerly Known as Vehicle boneyard. TPA 2. Reckey #;(994250135404) St. Paul Island, Alaska The National Oceanic and Atmospheric Administration, March 12, 2008
This Notice to Deed informs potential purchasers or leaseholders of the property known as the Vehicle Boneyard contains an inert solid waste monofill; that this property may not be suitable for some uses; that maintenance and repairs to this property might become necessary to prevent pollution problems at the site; and that any activity that results in damage to the final cover of the property must be corrected to control potential pollution problems. This Notice to Deed was prepared by the US Department of Commerce. Nation Oceanic and Atmospheric Administration (NOAA). National Ocean Service, Office of Response and Restoration, Pribilof Project Office, Seattle. Washington 98115. This Notice to Deed complies with 18 AAC 60.490 as amended through August 8. 2003 and other applicable laws.
At the time of recording this Notice to Deed, NOAA continues to comply with ADEC's long-term (60
month) monitoring requirement of the site as described in NOAA 2005b. Upon completion of lhe post-closure monitoring period (October 2009), NOAA witt submit a report to ADEC describing the site conditions and summarizing information collected during the monitoring period. At that time, NOAA will request a confirmation of closure of the Vehicle Boneyard from ADEC under 18 AAC 60.490. |
Louis Howard |
| 6/4/2008 |
Update or Other Action |
NOAA and ADEC signed the closure letter for St. Paul Island. In accordance with paragraph 59 of the Pribilof Islands Environmental Restoration Agreement (Two-Party Agreement or TPA) January 1996 by designated officials of the State of Alaska and the National Oceanic and Atmospheric Administration (NOAA), NOAA requested Alaska Department of Environmental Conservation (ADEC), as the duly authorized representative of the State of Alaska, certify NOAA’s completion of corrective action for the St. Paul Island Operable Unit (OU).
As of June 4, 2007, the Vehicle Boneyard has buried drums, surface debris, solid wastel.Buried solid wastes, such as metallic debris and an asbestos monofill capped by vegetated soil cover; post-closure cap monitoring until June 20, 2010; deed notice.
Property Owner as of November 6, 2007 is the Tanadgusix Corporation (TDX) for the surface estate and The Aleut Corporation (TAC) for the subsurface estate. |
Jennifer Roberts |
| 6/17/2008 |
Update or Other Action |
Year-Four Monitoring
NOAA inspected the Vehicle Boneyard cap on June 17, 2008. No problems were observed with the cap; however the area to the east of the cap remained barren. NOAA subsequently applied 500 pounds of 20-20-20 fertilizer to the cap, the barren area and the entrance area. |
Louis Howard |
| 12/5/2009 |
Update or Other Action |
Year-Five Monitoring
NOAA inspected the Vehicle Boneyard cap on December 5, 2009. No problems were observed with the cap which was heavily vegetated. Maintenance was not deemed necessary. |
Louis Howard |
| 6/4/2010 |
Update or Other Action |
Year-Six Monitoring
NOAA inspected the Vehicle Boneyard cap on June 4, 2010. No problems were observed with the cap; maintenance was not deemed necessary. |
Louis Howard |
| 7/8/2010 |
Update or Other Action |
National Oceanic and Atmospheric Administration (NOAA) has completed six years of postclosure
monitoring at the Vehicle Boneyard Site on St. Paul Island, Alaska (Two-Party Agreement Site 21N0AA Site 2). This memorandum provides documentation of each year of monitoring and requests concurrence from Alaska Department of Environmental Conservation (ADEC) Solid Waste Program that NOAA has met and completed its obligations for post-closure monitoring at this site.
In 2003 and 2004 NOAA installed a vegetated closure cap at the Vehicle Boneyard on St. Paul Island, Alaska. In the years since, NOAA performed regular inspections and cap maintenance with a result that in June 2010 the cap is in good shape. Attachment 8 provides a comparison between photos taken in 2005/2006 and photos taken in June 2010 with approximately the same view. As indicated in these photos, the cap is well vegetated with no signs of erosion. Additionally, in March 2008 NOAA filed a Notice to Deed with Alaska Recording District 305 (Attachment 9) describing the history and final conditions of this property. NOAA concludes that it has met its obligation for five years of inspection and maintenance of the Vehicle Boneyard cap and requests that ADEC Solid Waste Program concur with this conclusion.
Site Location and Ownership
St. Paul Island, Alaska is approximately 800 miles southwest of Anchorage in the Bering
Sea. On the island, the Vehicle Boneyard is located in the eastern portion, north of Polovina
Hill and south of Big Lake (see Attachment 3, Figures 1 and 2), 57 degrees, 11' 25.50" north latitude, 170 degrees 10' 44.36" west longitude. The capped area is located in Township 34 South, Range 131 West, Section 34, of the Seward Meridian, Alaska as shown on the plat of rectangular survey officially filed May 14, 1986. The Tanadgusix Corporation (TDX) ownS the surface property and The Aleut Corporation owns the subsurface property at the Vehicle Boneyard. |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73139 name: auto-generated pm edit TPA 02 STP Vehicle Boneyard Site |
Louis Howard |
