phase i environmental site assessment report scammon bay

Phase I Environmental Site Assessment Report

Scammon Bay Old BIA School and Tank Farm

Scammon Bay, Alaska

Prepared for:

Yukon River Inter-Tribal Watershed Council 323 Second Street, Unit A Fairbanks, AK 99701 Phone (907) 451 2530

Prepared by:

Job Number:APCS-14-01 September 26th , 2014

APC Services, LLC 4241 B Street, Suite 100 Anchorage, AK 99503 Phone (907) 677 9451

ii Scammon Bay Old BIA School and Tank Farm Phase I ESA

Contents 1. SUMMARY ............................................................................................................................................. 2

2. INTRODUCTION ................................................................................................................................... 2

2.1 Detailed Scope of Work ................................................................................................................ 2

2.2 Continued Viability of Environmental Site Assessments .............................................................. 3

2.3 Reliance ........................................................................................................................................ 3

3. PRIOR REPORTS ................................................................................................................................. 3

4. SITE DESCRIPTION ............................................................................................................................. 3

4.1 Location ......................................................................................................................................... 3

4.2 Coordinates and Legal Description ............................................................................................... 3

4.3 Site and Vicinity General Characteristics ...................................................................................... 4

4.4 Description of Structures, Roads, Other Improvements on the Site ............................................. 4

4.4.1. Boiler House (S1). ................................................................................................................. 4

4.4.2. Old Elementary/BIA School (S2) ........................................................................................... 4

4.4.3. Residence (S3) ...................................................................................................................... 4

4.4.4. Residence (S4)/Residence (S5)/Residence (S6) .................................................................. 4

4.4.5. Former Workshop (S7) - demolished. ................................................................................... 5

4.4.6. Tank Farm (TF1) ................................................................................................................... 5

4.4.7. Former Tank Farm (TF2) - removed ..................................................................................... 5

4.4.8. Hillside Street ........................................................................................................................ 5

4.5 Current Use of Adjacent Properties .............................................................................................. 5

4.5.1. New Water Treatment Plant (A1) .......................................................................................... 5

4.5.2. Residence (A2) ...................................................................................................................... 5

4.5.3. Old Scammon Bay High School (A3) .................................................................................... 5

4.5.4. Alaska Army National Guard Armory (A4) ............................................................................ 5

4.5.5. Alaska Army National Guard Building (A5) ........................................................................... 5

4.5.6. Catholic Church (A6) ............................................................................................................. 6

4.5.7. Old Water Treatment Plant (A7/A8) ...................................................................................... 6

4.5.8. Cemetery ............................................................................................................................... 6

5. USER PROVIDED INFORMATION ....................................................................................................... 6

5.1 Environmental Liens and Activity/Use Limitations ........................................................................ 6

5.2 Specialized Knowledge or Experience .......................................................................................... 6

5.3 Valuation Reduction for Environmental Issues ............................................................................. 6

5.4 Commonly Known or Reasonably Ascertainable Information ....................................................... 6

5.5 Degree of Obviousness ................................................................................................................. 6

6. RECORDS REVIEW .............................................................................................................................. 7

iii Scammon Bay Old BIA School and Tank Farm Phase I ESA

6.1 Historical Use Information ............................................................................................................. 7

6.1.1. Target Property ..................................................................................................................... 7

6.1.2. Adjoining Properties (to the extent identified) ....................................................................... 7

6.1.3. Historical Photographs .......................................................................................................... 7

6.1.4. Aerial Photographs ................................................................................................................ 7

6.1.5. Local Street Directories ......................................................................................................... 7

6.1.6. EDR Radius Maps ................................................................................................................. 7

6.1.7. Recorded Land Title Records ............................................................................................... 7

6.2 Physical Setting Sources(s) .......................................................................................................... 7

6.3 Standard and Supplemental Environmental Record Sources, Federal & State ........................... 8

6.3.1. Alaska Department of Environmental Conservation (ADEC) Contaminated Site Database 8

6.3.2. ADEC UST Database ............................................................................................................ 9

6.3.3. ADEC Spill Database ............................................................................................................ 9

6.3.4. Yukon River Inter-Tribal Watershed Council On-line Database ......................................... 10

6.3.5. EPA Hazardous Waste Sites .............................................................................................. 10

6.4 Interviews with State and/or Local Government Officials ........................................................... 10

7. SITE RECONNAISSANCE .................................................................................................................. 10

7.1 Methodology and Limiting Conditions ......................................................................................... 10

7.2 General Observations ................................................................................................................. 10

7.2.1. Underground Storage Tanks (USTs) .................................................................................. 10

7.2.2. Above Ground Storage Tanks (ASTs) ................................................................................ 10

7.2.3. Drums or Containers ........................................................................................................... 11

7.2.4. Odors ................................................................................................................................... 11

7.2.5. Pools of Liquid ..................................................................................................................... 11

7.2.6. PCB-containing Equipment ................................................................................................. 11

7.2.7. Interior Stains or Corrosion ................................................................................................. 11

7.2.8. Interior Floor Drains and Sumps ......................................................................................... 11

7.2.9. Pits, Ponds and Lagoons .................................................................................................... 11

7.2.10. Stained Soil or Pavement .................................................................................................... 11

7.2.11. Stressed Vegetation ............................................................................................................ 11

7.2.12. Solid Waste ......................................................................................................................... 11

7.2.13. Wastewater ......................................................................................................................... 11

7.2.14. Wells .................................................................................................................................... 11

8. INTERVIEWS ....................................................................................................................................... 12

8.1 Key Site Manager - Mr. Brandon Aguchak ................................................................................. 12

iv Scammon Bay Old BIA School and Tank Farm Phase I ESA

8.2 Prior Occupant/Occupant Interviews .......................................................................................... 12

8.2.1. Mr. Mike Akerelrea Tribal Council Member ......................................................................... 12

9. SCOPE LIMITATIONS/DEVIATIONS/SIGNIFICANT DATA GAPS .................................................... 12

9.1 Scope of Work Limitations .......................................................................................................... 12

9.2 Significant Data Gaps ................................................................................................................. 13

10. FINDINGS AND CONCLUSIONS ................................................................................................... 13

11. RECOMMENDATIONS ................................................................................................................... 14

12. REFERENCES ................................................................................................................................ 14

APPENDICES

Appendix A - Maps and Figures

Appendix B - Site Photographs

Appendix C - Environmental Professional Qualifications

Appendix D – Title Search

1 Scammon Bay Old BIA School and Tank Farm Phase I ESA

ABBREVIATIONS

AAI All Appropriate Inquiry ACM Asbestos Containing Material ADEC Alaska Department of Environmental Conservation AST Above Ground Storage Tank BIA Bureau of Indian Affairs CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations DRO Diesel Range Organics EP Environmental Professional EPA Environmental Protection Agency ESA Environmental Site Assessment LLP Landowner Liability Protections LUST Leaking Underground Storage Tank LYSD Lower Yukon School District NPL National Priorities List PCB Polychlorinated Biphenyl REC Recognized Environmental Condition USACE United States Army Corps of Engineers USGS United States Geological Survey UST Underground Storage Tank WELTS Well Log Tracking System YRIWTC Yukon River Inter-Tribal Watershed Council


1. SUMMARY A Phase I environmental site assessment (ESA) was undertaken by APC Services, LLC (APCS) on the property known as the Scammon Bay Old BIA School and Tank farm in Scammon Bay, Alaska on behalf of the Yukon Inter-Tribal Watershed Council (“the client”) following the practices outlined in ASTM E1527 - 13; - “Standard Practice for Environmental Assessments: Phase I Environmental Site Assessment Process”. The ESA was conducted by Dr. Keith Torrance, a Senior Environmental Geologist employed by APCS who meets the definition of an Environmental Professional as defined in ASTM E1527 – 13.

The property is occupied by buildings and structures constructed after 1975 and used as a school until 2005. Eight large fuel storage tanks supplied a boiler house used to heat the school and teacher housing. The buildings are currently used as residences and community offices. Historical records indicate no prior structures on the site.

The Phase I environmental site assessment was completed in August 2014 and identified several recognized environmental conditions:

• Three abandoned aboveground storage tanks that have the potential to further deteriorate and facilitate a release of residual fuel.

• The presence of soil contaminated by hydrocarbons discovered and removed during the construction of the Catholic Church down gradient of the property in 2011 and during the installation of a road culvert on Hillside Street in 2014 that suggest past releases from the fuel pipe supplying the tank farms within the subject property.

• Past releases of fuel on the property discovered during historical research and interviews. • The possible presence of asbestos containing material within the boiler house noted during a

previous Phase I site assessment summary conducted in 2006.

2. INTRODUCTION

2.1 Detailed Scope of Work The overall objective in this project was to identify and evaluate any recognized environmental conditions (RECs) of the Scammon Bay property following the standards outlined in ASTM E1527 - 13. This consisted of the following components:

• A review of relevant historical site records (background documents, photos and maps) provided by the Yukon River Inter-Tribal Watershed Council (YRITWC) Brownfield Tribal Response Program and other sources.

• A site reconnaissance visit to the property. • Interviews with relevant stakeholders and written summary of the interviews (may include but is

not limited to landowners, community members, government officials). Participation in a community and/or Tribal Council meeting if held during the site visit or as follow-up to the final Phase I Environmental Site Assessment (ESA).

• Participation in planning and follow-up sessions with various stakeholders via teleconference; • Evaluation of all information and the compilation of a Final Phase I Environmental Site

Assessment Report including standardized records (land title, environmental and historical records) and recommendations for additional investigation under separate cover;

• Limitations and Exceptions of Assessments.


Along with the limitations set forth in the various sections of the ASTM 1527 – 13 Standard Practice, the accuracy and completeness of this report may be limited by the following:

• During the reconnaissance visit of July 29, 2014, much of the site was covered by high grass which obscured the ground conditions and the presence or absence of staining could not be ascertained.

• The interior of the residences on the property could not be accessed. • Some historical reports could not be located.

2.2 Continued Viability of Environmental Site Assessments Pursuant to Section 4.6 of ASTM E1527 – 13, Phase I ESAs are considered viable for 180 days.

2.3 Reliance This report was prepared solely for the use of the Yukon River Inter-Tribal Watershed Council (YRITWC) and is not intended for use by third parties. Unauthorized third parties shall indemnify and hold APC Services, LLC harmless against any liability for any loss arising out of, or related to, reliance by any third party on the work performed hereunder, or the contents of this report.

3. PRIOR REPORTS A Phase I report was carried out on behalf of YRITWC in 2006 but a copy of the report could not be located by the client. A summary of the report is posted on the YRITWC brownfield database.

Ahtna Engineering carried out remediation work on the adjoining AKARNG Federal Scout Armory and published a remedial action report in 2010.

4. SITE DESCRIPTION

4.1 Location The property, known as the Scammon Bay Old School Tank Farm, is located in Scammon Bay, Alaska, within the USGS Hooper Bay D-2 quadrangle map. The property is comprised of a tract of land approximately 2.65 acres located within lots 1 & 2 of U.S. Survey 4099.

4.2 Coordinates and Legal Description Coordinates: 61.84099(N); -165.58216(W) (WGS84)

Legal description: A tract of land located within Lots 1 & 2, of U.S. Survey 4099, an additional un-surveyed lands in Sec. 10 T., .20 N., R. 90W, Seward Meridian more particularly descripted as:

Beginning at the point for corner No. 1. Identical with corner No. 2, U.S. Survey No. 4099; From corner No. 1, by metes and bounds, S. 6°31' E., 20.00 ft., to corner No. 2, a point on the 2-6 lines of U.S. Survey No. 4099; thence N. 83°29' E., 149.82 ft., to corner No. 3; thence S. 6°31' E., 100.78 ft., to corner No. 4; thence N. 83°29' E., 49.82 ft., to corner No. 5; thence N. 6°31' E., 254.22 ft., to corner No. 6; thence N. 83°29' E., 300.00 ft., to corner No. 7; thence N. 6°31' W., 375 ft., to corner No. 8, a point on the 1-2 line of U.S. Survey No. 4099;


thence N. 83°29' E., 200.00 ft., to corner No. 1 the true point of beginning. containing approximately 2.65 acres.

The property is leased from the Askinuk Corporation by the Lower Yukon School District (LYSD).

4.3 Site and Vicinity General Characteristics Scammon Bay, a town of approximately 550 residents, is situated on the Kun River at the northern foot of the Askinuk Mountains in the Lower Yukon region, approximately 525 miles west of Anchorage. The region is almost entirely composed of the flat, low-lying estuarine deltas of the Yukon and Kuskokwim Rivers, as shown in Figure 1. The Askinuk Mountains rise 1,500 feet above the delta plain and consist of granite/granodiorite intrusive rocks.

Intermittent permafrost underlies most of the village at depths of 4 feet and greater (Ahtna Engineering, 2010). Scammon Bay is subject to flooding which has inundated the area around the property. The position of the target property in the 2007 Scammon Bay community map is shown in Figure 2.

4.4 Description of Structures, Roads, Other Improvements on the Site There are six buildings and three in-line large vertical aboveground storage tanks on the property as shown in Figure 3. In this figure, buildings on the site use the prefix “S” and adjacent buildings use the “prefix “A”. This notation is used throughout this report. A seventh structure on the property (S7) was demolished in 2012. There is a bank of three above ground storage tanks (AST) which are denoted as TF1 on the map. A second tank farm that contained five above ground storage tanks (TF2) was removed sometime after 2007. These tanks can be observed in use at other parts of the village.

All of the buildings are supplied by city water with the exception of one residence (S6). All of the buildings on the site are raised above grade on piles because of frequent flooding on the Kun River. All buildings have oil-fired heating supplied by tanks attached to the structures and connection to the city sewer system. These structures are indicated in Figure 3 and described below:

4.4.1. Boiler House (S1). This building housed the oil-fired boilers which supplied the school with heat. The boilers were removed in 2007 and the two rooms that form the southern side of the building are dilapidated and abandoned. A previous Phase 1 report summary indicated the likely presence of asbestos containing material (ACM), but the complete report could not be located. The rooms on the northern side of the building are currently used as a residence.

4.4.2. Old Elementary/BIA School (S2) This building was the former Bureau of Indian Affairs (BIA) School and was constructed in the 1950s. It also served as the elementary school from 1975 until the construction of the new high school in 2005. It currently houses the village laundry, tribal offices and community meeting rooms. It is heated by an oil-fired boiler supplied by a 300 gallon AST.

4.4.3. Residence (S3) This building may have been used as a store and sold fuel from an AST outside.

4.4.4. Residence (S4)/Residence (S5)/Residence (S6) These residences were previously used as teacher housing and are all currently occupied.


4.4.5. Former Workshop (S7) - demolished. This building housed a workshop used for building maintenance and was demolished in 2007. The area where the structure stood is clear of vegetation.

4.4.6. Tank Farm (TF1) This consists of three steel 10 foot diameter 8,000 gallon vertical fuel tanks (Figure 7) secured to a wooden foundation within a bermed area constructed of gravel and reinforced with sandbags with a liner. The tanks appear to be in good condition. Pipework connecting the tanks to the other properties has been removed. The tanks were supplied via a pipeline which ran from the Kun River (source: Mike Akerelrea). The tanks are assumed to be empty, but may contain residual amounts of fuel in the tanks and connecting pipework.

4.4.7. Former Tank Farm (TF2) - removed Aerial photographs back to 1975 show a bank of five vertical 8-foot diameter AST tanks that were removed after 2007. The bermed area is largely intact and lined as shown in Figure 8. These tanks pre-date the existing tank farm.

4.4.8. Hillside Street The property under investigation includes a portion of Hillside Street on its northern boundary, which is a broad, gravel road.

4.5 Current Use of Adjacent Properties A map of adjacent properties is shown in Figure 3. A description of the current use of these properties is as follows-

4.5.1. New Water Treatment Plant (A1) This is a new building constructed in 2013 and used to house water treatment equipment. It is supplied by two 6,000 gallon double walled external fuel tanks. Historical aerial photos indicate that there were no previous structures on this site.

4.5.2. Residence (A2) This building is used as a residence. The 1994 community map indicates that this building was previously used as the Lower Yukon School District (LYSD) store.

4.5.3. Old Scammon Bay High School (A3) This building was constructed between 1975 and 1982 as the village high school and closed in 2005. The building is currently used for housing.

4.5.4. Alaska Army National Guard Armory (A4) The Federal Scout Armory (FSA) is listed in the ADEC contaminated site database, which indicates that 413 tons of DRO-contaminated soil were excavated and transported to a landfill in Oregon for disposal. The source of the contamination was believed to be from two 3000 gallon ASTs on the south side of the property which were removed in 1993.The site was closed in 2010 without institutional controls (Ahtna Engineering, 2010). As the site is down gradient from the target property it is therefore unlikely to have impacted the target property. There is a 1,500 gallon AST on the north side of the armory building.

4.5.5. Alaska Army National Guard Building (A5) This is a relatively new building with an external AST.


4.5.6. Catholic Church (A6) This building was constructed in 2011 and replaced an older catholic church on the same site. An interview with Mr. Mike Akerelrea of the village council indicated that DRO-impacted soil was encountered during construction and several hundred cubic yards of contaminated soil was removed.

4.5.7. Old Water Treatment Plant (A7/A8) These buildings housed water treatment equipment installed in the 1970s. There are several ASTs around the buildings (Figure 14) but the property is down-gradient of the target property. The buildings appear to be unused.

4.5.8. Cemetery The village cemetery is northeast of the target property and is presumed to have had no previous use.

5. USER PROVIDED INFORMATION ASTM E1527 outlines tasks to be completed by the “user” to satisfy the “All Appropriate Inquiries” Final Rule (40 CFR Part 312) to satisfy Landowner Liability Protection (LLP) or brownfield grantees under CERCLA. Dan Goodman of YITWRC provided the following answers:

5.1 Environmental Liens and Activity/Use Limitations There are no known environmental liens or use limitations.

5.2 Specialized Knowledge or Experience The user has no specialized knowledge of the property.

5.3 Valuation Reduction for Environmental Issues This Phase I assessment is being conducted for the grantee under the EPA’s brownfield program and ownership of the property under investigation is not being transferred.

5.4 Commonly Known or Reasonably Ascertainable Information The user stated that all known knowledge has been passed on to the Environmental Professional.

5.5 Degree of Obviousness Fuel has been stored at the site since 1975. There are known historical releases.


6. RECORDS REVIEW

6.1 Historical Use Information

6.1.1. Target Property The school building (S1 on Figure 3) was constructed by the Bureau of Indian Affairs (BIA) as a purpose-built school and has had no previous use. Buildings S4, S5 and S6 were built as teacher housing and continue to be used as residences. Diesel has been sold and distributed from an AST outside of the residence at the corner of Hillside Street (S3) and the building was used as a village store in the past.

6.1.2. Adjoining Properties (to the extent identified) The residence east of the old elementary school building (A2) is marked as the LYSD store in the 1994 community map. Known past uses of other adjoining properties is included in section 4.5.

6.1.3. Historical Photographs Historical photographs were examined to determine past uses of the property and the sequence of construction. Figure 12 shows the school site in 1982 with two tank farms visible.

6.1.4. Aerial Photographs Alaska community profile maps compiled by the Alaska Department of Commerce and available at http://www.commerce.alaska.gov/dnn/dcra/PlanningLandManagement/CommunityProfileMaps.aspx contain embedded aerial photographs dated 1979, 1994 & 2007. These maps were examined to identify the presence of structures and buildings on the target property and to determine past property uses.

6.1.5. Local Street Directories No local street directories have been published for Scammon Bay.

6.1.6. EDR Radius Maps A data search package from EDR, Inc. was not ordered because of the remote location of the site and the limited information available.

6.1.7. Recorded Land Title Records Land Title Records were examined to determine previous owners and use of the site. These are included as Appendix D.

6.2 Physical Setting Sources(s) The property under investigation is approximately 2.65 acres in area, sloping from north to south at the boundary between the uplands and the deltaic flood plain. The more elevated southern portion of the property is undeveloped. The underlying soil types are predominantly fine gravel, probably derived from erosion of the Askinuk Mountains, grading into sands/sandy silts forming the estuarine deposits of the delta. An unnamed creek borders the western edge of the lot and is the source of drinking water for the village, via a water treatment plant. The following physical setting sources were consulted:

• USGS Topographical Map, Hooper Bay, B-2 published in 1953. • USGS Reconnaissance Geological Map of the Lower Yukon River Region, Alaska, published in

2006. • The United States Army Corps of Engineers report on the feasibility of hydroelectric power in

Scammon Bay provides an overview of the village, hydrology and topographical setting (USACE, 1982) as well as some historical photographs.

http://www.commerce.alaska.gov/dnn/dcra/PlanningLandManagement/CommunityProfileMaps.aspx


6.3 Standard and Supplemental Environmental Record Sources, Federal & State

6.3.1. Alaska Department of Environmental Conservation (ADEC) Contaminated Site Database

The ADEC database of contaminated sites was last searched on August 5th 2014 and returned 17 records of which 16 relate to former military installations at Cape Romanzof, which is approximately 15 miles west of Scammon Bay and therefore outside of the search radius. These records are shown in Table 1.

Table 1. Entries from the ADEC Contaminated Sites Database.

Site # Name Location Status File ID 1329 Cape Romanzof SS015 & USTs South of SS07,

Scammon Bay, AK 99662 Cleanup Complete - Institutional Controls

2526.38.010

1334 Cape Romanzof SS010 Wells 2 & 3

Weather Station Building, Scammon Bay, AK 99662

Open 2526.38.007

1335 Cape Romanzof SS013 Large Fuel Spill

SW of SS15 Area & South, Scammon Bay, AK 99662

Cleanup Complete - Institutional Controls

2526.38.008

1336 Cape Romanzof SS007 WAA 1 Spill/Leak 1 & 2

Cape Romanzof, Scammon Bay, AK 99662

Cleanup Complete

2526.38.005

1337 Cape Romanzof LF004 Landfill #3



2526.38.002

1338 Cape Romanzof LF012 5099th Landfill


Cleanup Complete

2526.38.003

1339 Cape Romanzof ST009 Spill# 3 POL Fill Stand

North of the Barge Landing Area, Scammon Bay, AK 99662


2526.38.011

1340 Cape Romanzof SS014 Former Drum Storage

Near Barge Landing Area, East of the Scammon Bay, AK 99662


2526.38.009



Open 2526.38.001

1342 Cape Romanzof OT005 Road Oiling


Cleanup Complete

2526.38.004

1343 Cape Romanzof SS008 Waste Accum. Area 3


Cleanup Complete

2526.38.006

1344 Cape Romanzof DP011 Towek Mtn Debris

Near Upper Camp & Former White Alice, Scammon Bay, AK 99662


2526.38.015



Cleanup Complete

2526.38.014

1346 Cape Romanzof OT006 White Alice Site


Cleanup Complete

2526.38.013

1347 Cape Romanzof SS001 WAC Area No. 2


Cleanup Complete

2526.38.012

2821 AKARNG Scammon Bay FSA Hillside Street, Scammon Bay, AK 99662

Cleanup Complete

2445.38.001


The AKARNG Federal Scout Armory contaminated site (2445.38.001) in Table 1 adjoins the property under investigation and is therefore within the minimum search distance. The record of file 2445.38.001 was examined and reviewed at ADEC’s office in Anchorage on August 8th 2014 which identified the source of the release as a former AST outside of the old armory building. According to the final remedial action report (Ahtna Engineering, 2010) 413 tons of soil were removed in 2010 but soil contamination did not extend into the target property. Contaminated soil was transported to the Colombia Ridge Landfill in Arlington, Oregon for disposal. The cleanup is documented as complete and this file is now closed without institutional controls.

6.3.2. ADEC UST Database The ADEC UST database was last searched on August 5th 2014 and returned no entries.

6.3.3. ADEC Spill Database The ADEC spills database was last queried on August 6th and returned several fuel spill records as shown in Table 2. Because of the limited location information in this database all of these records are included.

Table 2. Local Entries in the ADEC Spills Database

Incident Location Date Qty. spilled

Bering Sea between Toksook Bay & Scammon Bay Vitus Marine

6/8/14 200 gallons

Community Service Center No Street Name 11/9/13 250 gallon

LYSD Scammon Bay Complex #1 Teacher Housing 1/19/11 55 gallons

LYSD Scammon Bay Piping LYSD Scammon Bay School 9/16/10 10 gallons

SCAMMON BAY AVEC TANK FARM no address 7/7/97 200 gallons

SCAMMON BAY BARGE LANDING AT TANK FARM

no address 8/4/97 14 gallons

SCAMMON BAY BARGE LANDING no address 8/8/97 5 gallons

Scammon Bay Post Office 102 Johnson Road 9/25/12 5 gallons

Scammon Bay Road Culvert Project below old school (old spill) 8/5/14 100 gallons

SCAMMON BAY SCHOOL LYSD Scammon Bay School 10/18/04 30 gallons

SCAMMON BAY TANK FARM INSIDE CONTAINMENT

Askinuk Corporation 9/8/04 1,500 gallons

Scammon Bay Tank Farm Sheen Scammon Askinuk Corporation Tank Farm 10/2/12 1 gallon

Scammon Octagon Housing Unit no address 6/8/07 5 gallons

Water treatment facility no address 10/25/09 100 gallons Records in bold are on or close to the target property.


Several of these records relate to the target property and indicate that there have been historical releases of fuel associated with the AST’s on the site. Some of these spills represent a “de minimis condition”1, as defined in ASTM E1527 – 13 which is not considered to be a REC. It is probable that other historical releases were not reported and are not included in this database.

6.3.4. Yukon River Inter-Tribal Watershed Council On-line Database YRITWC maintains a brownfield information database covering properties within the Yukon watershed. A search of this database found a total of 9 entries for Scammon Bay, including the BIA school tank farm (TF1), boiler house (S1) on the target property and the adjoining water treatment buildings (A& & A8). The source material for this database could not be located.

6.3.5. EPA Hazardous Waste Sites The United States EPA maintains a database of unmanaged and/or forsaken hazardous waste sites, known as the National Priorities List (NPL). The database was last accessed on August 6th, 2014 and showed that there are no sites within 1 mile of Scammon Bay. The EPA Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) database was last accessed on August 6th, 2014 and indicated no sites within 5 miles of Scammon Bay.

6.4 Interviews with State and/or Local Government Officials Mr. Aguchak, who is the Village Administrator, was interviewed on July 30th 2014 in Scammon Bay. See Section 8.1.

Ms. Debra Caillouet of the Alaska Department of Environmental Conservation was contacted on 7th August 2014. Ms. Caillouet reviewed the remedial action report on the Federal Scout Armory on behalf of the State of Alaska. She had no knowledge of any additional contaminated sites in Scammon Bay.

7. SITE RECONNAISSANCE

7.1 Methodology and Limiting Conditions The Scammon Bay site reconnaissance visit was conducted on July 29th, 2014 by Dr. Keith Torrance. The methodology followed the procedures outlined in E1527 – 13. There were no significant limiting conditions that affected the site reconnaissance.

7.2 General Observations

7.2.1. Underground Storage Tanks (USTs) No indication of the presence of USTs (vent pipes, supply pipes etc.) was found on the property.

7.2.2. Above Ground Storage Tanks (ASTs) Numerous ASTs of different sizes are present on the property including, three large 8,000 gallon ASTs that form the remaining tank farm (TF1). Five large AST’s have been removed from the site since 2007. The position of ASTs is shown in Figure 4.

1 ASTM E1527- 13 defines a “de minimis condition” as a condition that generally does not present a treat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate government agencies.


7.2.3. Drums or Containers Numerous empty 55-gallon steel and plastic drums are present on the property. Two 55 gallon drums containing oil are present in the Boiler House (S1). Several abandoned propane tanks were observed on the ground, as indicated in Figure 4.

7.2.4. Odors Light hydrocarbon odors were detected at the tank farm (TF1) and inside the Boiler House (S1).

7.2.5. Pools of Liquid No pools of liquid were observed during the reconnaissance of the property.

7.2.6. PCB-containing Equipment No PCB-containing equipment was observed during the reconnaissance of the property. There is a utility pole on the north boundary of the property with two mounted transformers, as shown in Figure 10. These transformers appear to be in good condition and of an age when PCB’s were not used.

7.2.7. Interior Stains or Corrosion No interior stains were observed in any of the buildings on the property.

7.2.8. Interior Floor Drains and Sumps No floor drains or sumps were observed during the reconnaissance of the property. All of the buildings are connected to the city sewer system.

7.2.9. Pits, Ponds and Lagoons No pits, ponds or lagoons were discovered during the reconnaissance of the property.

7.2.10. Stained Soil or Pavement No significant oil stains were observed during the reconnaissance of the property. There was minor oil sheening on the standing water within the tank farm enclosure.

7.2.11. Stressed Vegetation No stressed vegetation was observed during the reconnaissance of the property.

7.2.12. Solid Waste Solid waste is present in several areas. Between buildings S1 and S2 there is a quantity of solid waste, including empty 55-gallon drums and a propane cylinder. On Hillside Street there is solid waste in front of buildings S3 and S3 comprising discarded vehicles, auto parts and empty 55- gallon drums.

7.2.13. Wastewater All of the buildings on the property are connected to the city sewer system.

7.2.14. Wells No wells were observed on the property. A search of Alaska’s WELTS database returned no records of wells in Scammon Bay. The village is supplied with drinking water from a water treatment facility that draws water from an infiltration bed upstream in the unnamed creek adjacent to the property.


8. INTERVIEWS

8.1 Key Site Manager - Mr. Brandon Aguchak Mr. Aguchak who is the Village Administrator and was identified as the key site manager was interviewed on July 30th 2014 in Scammon Bay. Mr. Aguchak is a lifelong resident of the village and has good knowledge of the uses and physical characteristics of the target property.

Mr. Aguchak stated that there had been no major releases of fuel from the large tanks but several minor spills through over filling of ASTs and accidents. He confirmed that there were never any underground storage tanks on the property. He stated that there are no cesspits on the property.

Mr. Aguchak contacted me on August 5th 2014 to report that contaminated soil had been uncovered on Hillside Street during the installation of a culvert shortly after the reconnaissance visit. This incident is now listed in the ADEC spill database (Table 2) but has yet to be resolved.

8.2 Prior Occupant/Occupant Interviews

8.2.1. Mr. Mike Akerelrea Tribal Council Member Mr. Akerelrea, who is a Tribal Council member who occupies the old school building, was interviewed on July 30th in Scammon Bay. Mr. Akerelrea had knowledge of DRO-contaminated soil that was uncovered during the construction of the Catholic Church (A5) in 2011, which extended south underneath Hillside Street. The full extent of the contamination was not determined at the time but Mr. Akerelrea speculated that it might originate from damage to a supply pipe on the target property that ran from the river to the tank farm and was used to fill the tank farm. According to Mr. Akerelrea, this pipeline ran from the tank farm to the Kun River and is probably still in place.

9. SCOPE LIMITATIONS/DEVIATIONS/SIGNIFICANT DATA GAPS

9.1 Scope of Work Limitations There may be additional environmental issues or conditions at the property that stakeholders may wish to assess that are outside the scope of this Phase 1 report. ASTM 1527 – 13 does not include the following considerations

• Asbestos containing building materials • Biological agents • Cultural and historical resources. • Ecological resources • Endangered species • Health and safety • Indoor air quality unrelated to releases of hazardous substances or petroleum products into the

environment • Industrial hygiene • Lead-based paint • Lead in drinking water


• Mold • Radon • Regulatory compliance • Wetlands

9.2 Significant Data Gaps Scammon Bay is a remote community that is only accessible by air and river. There are no insurance maps of Scammon Bay or commonly used historical sources and street directories. Consequently, the list of former property uses may be incomplete.

The report of the Phase I environmental site assessment undertaken by YRITWC in 2006 could not be located.

10. FINDINGS AND CONCLUSIONS I have performed a Phase I Environmental Site Assessment in conformance with the scope and limitations of ASTM Practice E1527 – 13 of Scammon Bay Old School Tank Farm. Any exceptions to, or deletions from, this practice are described in Section 2.2 of this report. This assessment has found no evidence of recognized environmental conditions in connection with the property except for the following:

• Three abandoned aboveground storage tanks (TF1) that have the potential to further deteriorate and facilitate a release of residual heating oil.

• The presence of soil contaminated by hydrocarbons discovered during the construction of the Catholic Church down gradient of the property in 2011 and during the installation of a culvert on Hillside Street in 2014 that suggest releases from damage to the pipe supplying the tank farm on the target property.

• Past releases of fuel on the property discovered during historical research and interviews. • The possible presence of ACM within the dilapidated boiler house (S1) mentioned in the

summary of the 2006 YRITWC site assessment.

I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in §312.10 of 40 CFR §312.

I have the specific qualifications based on education, training and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed all the appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

Dr. Keith Torrance PG

Senior Environmental Geologist

APC Services, LLC Anchorage, AK


11. RECOMMENDATIONS ASTM 1527 – 13 does not include a requirement to provide recommendations to address the RECs identified during the Phase I environmental site assessment. The following recommendations are provided as a service to the client.

• Empty fuel drums, antifreeze drums and abandoned propane cylinders should be removed from the property and transported to the local landfill for disposal in accordance with ADEC regulations.

• Samples of pipe insulation should be collected from the dilapidated boiler house by a certified professional and tested to determine whether they meet the definition of asbestos containing material, and if so, removed by a licensed asbestos abatement professional.

• A Phase II environmental site assessment should be conducted to delineate and quantify the extent and concentration of DRO-impacted soil in the NW section of the property that was uncovered during excavation of the church and culverts as this may be an indication that the supply pipe to the tank farms was damaged at some point and may have experienced a release of fuel.

12. REFERENCES Ahtna Engineering 2010 Final Remedial Action Report – Federal Scout Armory, Scammon Bay, Alaska Contract No. W912RU-09-C-007.

ASTM International 2013 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. E1527 – 13

Environmental Protection Agency (2005) 40 CFR Part 312. Standard Practice for All Appropriate Inquiries Federal Register Vol. 70. No 210.

US Army Corps of Engineers 1982. Scammon Bay Alaska. Small Hydropower Interim Feasibility Study and Environmental Assessment.


APPENDICES


APPENDIX 1 MAPS AND FIGURES

Figure 1. Part of USGS topographical map, Hooper Bay D-2 quadrangle, showing the general location of Scammon Bay, Alaska.

Figure 2. 2007 Scammon Bay Community Map showing the location of the Old School property.


Figure 3. Map showing the annotation of buildings and structures on the target property, with adjacent buildings. Refer to Sections 4.3 and 4.4 for key.

.

Figure 4. Map showing the location of ASTs, drums, propane tanks and utility poles with transformers on the site.


APPENDIX B SITE PHOTOGRAPHS

Figure 5. Photo of the target property taken from the southwest.

Figure 6 Photo of the target property from the northwest.


Figure 7. Above ground storage tank farm (TF1).

Figure 8. Photo of the containment area for the old tank farm (TF2) showing the liner.


Figure 9. Photo showing the interior of the boiler house (S1).

Figure 10. Photo of pole mounted transformers on Hillside Street.


Figure 11. Abandoned 55-gallon drums and propane tank south of the old school building.

Figure 12. Historical photo of the school complex taken in 1982. (Source: USACE)


Figure 13. Photo showing the Boiler House (S1) looking across the site of the woodshop (S7).

Figure 14. Photo of AST at the old water treatment plant (A7/A8), adjacent to the target property.


APPENDIX C PROFESSIONAL QUALIFICATIONS

Keith W. Torrance, Ph.D., CGeol FGS, CPG

Senior Environmental Geologist

Summary Qualifications

Dr. Keith Torrance is a certified professional geologist (CPG), chartered geologist (CGeol) and environmental professional at APC Services, LLC (APCS) with thirty years of experience managing diverse environmental engineering projects and business development. He has extensive experience of contaminated site evaluation, contaminant hydrology, environmental geochemistry and site remediation. He has a master’s degree in Environmental Engineering and a PhD in Environmental Geochemistry from the University of Strathclyde in Glasgow, Scotland, in addition to an undergraduate honors degree in geology. His Ph.D. thesis investigated patterns of arsenic and associated potentially toxic metals at historical mining sites in Alaska, Scotland and Colombia impacted by mine and mine waste. His research interests include mine waste, arsenic geochemistry, coal combustion, acid mine drainage, mercury mobility and contaminated land evaluation. He has expertise in analytical methods, including ICP-MS, AFS, XRF, XRD, and GC-MS. Dr. Torrance was elected a Fellow of The Geological Society in 2009 and a Chartered Geologist in 2014. He meets the requirements of a qualified person (QP) in contaminated land in Alaska as defined by 18 AAC 78.995 and is a licensed Professional Geologist in the State of Alaska. He meets the requirements for an environmental professional set forth in 40 CRF §312.10(b) He was appointed an Honorary Research Fellow at the University of Strathclyde, Scotland in 2014 and also serves as an adjunct professor at UAA.

Professional Experience

January 2013-Present APC SERVICES, LLC, Anchorage, AK Senior Environmental Geologist-Keith is conducting environmental baseline studies at the Pebble Project in southwest Alaska. Field studies include acid rock drainage assessment and surface water hydrology measurements at 19 stations on the Upper Talarik Creek, Newhalen River and road corridor areas. This work includes discharge measurements, field parameter measurements, and collection of surface water samples for laboratory analysis. Keith is also reviewing groundwater data on the former Port Heiden radio relay station site which has subsurface groundwater contamination by TCE and DRO and managing soil landfarming. He also has undertaken many Phase I and Phase I environmental site assessments in Alaska. April 2012-January 2013 TERRASAT, INC., Anchorage, AK Senior Environmental Scientist-Managed field investigations of urban contaminated sites in Alaska impacted by UST releases and oil spills. Coordinated with ADEC on behalf of clients to supervise collection of soil and surface water samples and interpret analytical data. Compiled GIS data and authored Phase II environmental assessment reports for ADEC. August 2011-May 2012 UNIVERSITY OF ALASKA ANCHORAGE, Anchorage, AK Adjunct Professor -As an adjunct faculty member within the department of geosciences, Keith developed and taught GEOL 115L environmental geology laboratory for undergraduate students, with hands-on instruction on hydrology, stream discharge measurements, soil and water sampling. He set up the department’s rock sample preparation facility. September 2008-May 2012 UNIVERSITY OF STRATHCLYDE, Glasgow, Scotland Research Fellow While pursuing his Ph.D., Keith undertook extensive fieldwork in Scotland, Alaska and Colombia at historical mining sites. In Alaska, he worked on projects at Lucky Shot, Golden Zone, Red Devil Mine and the Hi-Yu Mine. As a member of a contaminated land research group, he worked on two urban sites in Glasgow impacted by hexavalent chromium ore processing waste, coal tars and coal mining spoil.


January 1989-September 2008 STRUERS, INC., Westlake, OH Business Manager/Engineer-Keith was responsible for business development for the North American subsidiary of a European manufacturer of laboratory testing and environmental characterization equipment used in the oil, mining and semiconductor industries.

Education Ph.D., Environmental Geochemistry, University of Strathclyde, Glasgow, UK 2012

MRes., Environmental Engineering, University of Strathclyde, Glasgow, UK 2009 BSc (Hons)., Geology, University of Glasgow, UK 1982 Ground Gas Monitoring Course, 2009 Geology of Rare Earth Element Deposits, Alaska Miners Association, 2010 Geology of Iron Oxide-Copper-Gold Deposits, Alaska Miners Association, 2011 Copper Nickel Platinum Deposits Short Course, Alaska Miners Association, 2012 Alaska Mine Geology, Alaska Miners Association, 2013 Air Quality Seminar, PacificRim Institute, 2014 ASTM Training on Phase I and Phase II environmental site assessments, 2014

Certifications Certified Professional Geologist (CPG-11647)

Professional Geologist State of Alaska-(PG - License # 696) Chartered Geologist (CGeol) European Geologist (EurGeol -1208) 38 Hour Army Corps of Engineer Wetland Delineation Training Program (Certificate 7261) 16 Hour Wetland Permitting Training Alaska Certified Erosion & Sediment Control Lead (AK-CESCL) Certified (AGC-13-0502) HAZWOPER 40-hour Certification; 8-hour refresher HAZWOPER Supervisor Training Wildlife Awareness Training CPR Certified. 2013

Publications Torrance, K.; Keenan, H., Munk, L. and Hagedorn, B. (2012). ‘Arsenic speciation and mobility

in surface water at Lucky Shot Gold Mine, Alaska.’ Environmental Geochemistry & Health. 34(6) 711-723. Torrance, K. W. and Keenan, H. E. (2012) ‘Screening for mercury at suspected contaminated land sites.’ International Environmental Technology, 21(11) 1-2. Torrance, K. and Keenan, H. (2012) ‘The environmental cost of the semiconductor elements.’ Compound Semiconductor 18(1) 47 – 51. Torrance, K. W., Rein, G., Switzer, C., Carvel, R., Hadden, R. and Belcher, C. M. (2012) ‘Chapter 20. Self-contained smoldering combustion of a coal waste heap in Central Scotland.’ in Stracher, G. B.; Prakash, A. & Sokol, E. V., ed. (2012), Coal and Peat Fires. A Global Perspective. Volume 2 : Case Studies., Amsterdam : Elsevier. (Sept. 2012). Torrance, K. W.; Keenan, H. E.; Hursthouse, A. S. & Stirling, D. (2010). Measurement of Arsenic and Gallium Content of Gallium Arsenide Semiconductor Waste Streams by ICP-MS. Journal of Environmental Science, Part A. 45(4) 1-5. Torrance, K. W. & Keenan, H. E. (2009). 'Management of Arsenic-rich Waste Streams in III-V Foundries'. Semiconductor Today. 4(9) 62-64.


Memberships Fellow of The Geological Society Geological Society of America American Institute of Professional Geologists Association of Environmental and Engineering Geologists Society for Environmental Geology and Health Geochemical Society International Association of Geochemistry Alaska Geological Society (President 2014/15) Alaska Miners Association


APPENDIX D – TITLE SEARCH

phase i environmental site assessment report scammon bay

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