Attach 2.2 Eldred Rock SCR 2015.pdf

SITE COMPLIANCE REPORT

Light Station Eldred Rock 17-J4199

Revision 02

DRAFT

March 2015

Prepared for:

United States Coast Guard

Prepared by:

Jacobs Engineering Group Inc.

2015 Site Compliance Report Light Station Eldred Rock – Site Restoration –17-J4199

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SUMMARY OF SCR REVISIONS

Revision Number Year Significant Changes to Site

(Land use patterns, contamination, new information, etc.)

00 2007 First Site Compliance Report completed.

01 2011 Updated with information on institutional controls and remediation treatments.

02 2015 Updated with proposed plans as per Eldred Rock Lighthouse Preservation Association (ERLPA).

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 FACILITY DESCRIPTION

2.1 FACILITY LOCATION

2.2 PHYSICAL DESCRIPTION

2.3 FACILITY OWNERSHIP AND OPERATIONAL BACKGROUND

3.0 REGULATORY FRAMEWORK AND STATUS

3.1 ENVIRONMENTAL DUE DILIGENCE AUDIT

3.2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

3.3 ADVISORY COUNCIL ON HISTORIC PRESERVATION

3.4 AGENCY CORRESPONDENCE

3.4.1 Alaska Department of Environmental Conservation

3.5 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES AND

ENVIRONMENTALLY SENSITIVE AREAS

4.0 INVESTIGATIONS TO DATE

4.1 1994 CIVIL ENGINEERING ASSESSMENT

4.2 1997 PHASE I ENVIRONMENTAL SITE ASSESSMENT

4.3 1997 PHASE II ENVIRONMENTAL SITE INVESTIGATION

4.4 2000 CORRECTIVE ACTION PLAN

4.5 2002 PHASE III SITE INVESTIGATION

4.6 2004 REMOVAL ACTION

4.7 2007 MODIFIED PHASE II/III EDDA INVESTIGATION

4.8 2008 CLEANUP DETERMINATION DOCUMENT

4.9 2009 ECOSCOPING FORM

5.0 CONCEPTUAL SITE MODEL

5.1 GEOLOGY

5.2 SURFACE WATER

5.3 GROUNDWATER

5.4 RELEASE DESCRIPTION

5.5 NATURE AND EXTENT OF CONTAMINANTS

5.6 POTENTIAL RECEPTORS AND MIGRATION PATHWAYS

6.0 DATA GAPS

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6.1 DATA GAPS IN CSM

6.2 ADMINISTRATIVE/REGULATORY UNCERTAINTIES

7.0 ASSUMED PATH TO CLOSURE

7.1 INVESTIGATION ACTIVITIES

7.2 REMEDIATION APPROACH

7.3 LONG-TERM MANAGEMENT APPROACH

8.0 PROJECT RISK PRIORITIZATION

9.0 REFERENCES

TABLES

Table 2-1 Timeline of Events for Light Station Eldred Rock

Table 3-1 Site Drivers and Contaminants of Concern

Table 3-2 ADEC Soil Cleanup Criteria Applicable to Eldred Rock

Table 3-3 EDDA Activities for Light Station Eldred Rock

Table 3-4 NEPA Considerations for Light Station Eldred Rock

FIGURES

Figure 2-1 USCG Lighthouse Locations for Southeast Alaska

Figure 2-2 Eldred Rock Vicinity Map

APPENDICES

APPENDIX A Applicable or Relevant and Appropriate Requirements

APPENDIX B Ecoscoping Forms

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ACRONYMS

AAC Alaska Administrative Code ACL Alternate Concentration Limit ADEC Alaska Department of Environmental Conservation ALM Adult Lead Model ARAR Applicable or Relevant and Appropriate Requirements AST aboveground storage tank CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFATF Civilian Federal Agency Task Force CFR Code of Federal Regulations DRO diesel-range organics ECR Environmental Compliance and Restoration EDDA Environmental Due Diligence Audit EL Environmental Liability EPA U.S. Environmental Protection Agency ERLPA Eldred Rock Lighthouse Preservation Association GRO gasoline-range organics Jacobs Jacobs Engineering Group Inc.

mg/kg milligrams per kilogram NEPA National Environmental Policy Act NHLPA National Historic Lighthouse Preservation Act ppm parts per million RCRA Resource Conservation and Recovery Act RRO residual-range organics SCR Site Compliance Report SHPO State Historic Preservation Officer SVOC semivolatile organic compounds USC United States Code USACE U.S. Army Corps of Engineers USCG U.S. Coast Guard VCP Voluntary Cleanup Program VOC volatile organic compounds

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1.0 INTRODUCTION

The purpose of the Site Compliance Report (SCR) is to summarize project status and regulatory compliance associated with environmental liabilities at the United States Coast

Guard (USCG) Light Station Eldred Rock, Alaska for USCG Environmental Compliance and

Restoration (ECR) Project 17-J4199. For the purpose of this document and the program it details, the term Environmental Liability (EL) refers to a probable, measurable, and reasonably estimable future outflow or expenditure of resources for environmental cleanup costs resulting from releases of petroleum compounds, hazardous materials, or hazardous waste to soil, groundwater, surface water, sediments, or air. The ELs at Light Station Eldred

Rock are described as follows:

• Paints used on the building exteriors contained lead, which was then deposited in the soils surrounding the buildings. In addition, maintenance activities on the exterior paint surfaces released paint chips into the surrounding soils, a practice that continued until the 1990s.

• During a site visit on 7 May 1997, a floor drain was discovered to be discharging from the Paint Shop directly to the ground surface on the north side of the building (USCG 1998), resulting in potential lead contamination in this area.

• The minutes from a December 2014 Eldred Rock Lighthouse Preservation Association (ERLPA) meeting mentioned the potential presence of asbestos tile in the interior of some buildings; these are scheduled for removal in May 2015 (ERLPA 2014).

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2.0 FACILITY DESCRIPTION

This section describes the location, physical surroundings, and operational history of this site.

A timeline of events is provided in Table 2-1.

2.1 Facility Location

The Light Station Eldred Rock is located in southeast Alaska on Eldred Rock Island in the

Lynn Canal, 25 miles south of Haines and 50 miles northwest of Juneau, at 58°58’03”N and

135°12’02”W. Figure 2-1 depicts the locations of USCG locations in southeast Alaska; Figure

2-2 shows the location for Light Station Eldred Rock.

2.2 Physical Description

Light Station Eldred Rock is Alaska’s oldest lighthouse, constructed as part of a

Congressional program passed in 1900 to build light stations in Alaska. Original lighthouse equipment included a first-order compressed-air fog signal, and a fourth-order 2,100-candle-power light. Construction of the Lighthouse began in 1905, and the station was first lit on

1 June 1906. The Lighthouse was built in a two-story, octagonal design. The first story was created from concrete and the second story from timbers brought to Eldred Rock by the government in 1905. A radio telephone, fuel tanks, and lamp posts were installed in the

1930s. In 1966, a wooden helicopter pad was constructed on the northern end of the island.

Light Station Eldred Rock was decommissioned in 1973 and is now operated remotely as a minor aid to navigation. The site was converted to solar power in the 1980s (USCG 2004).

2-1

2015 Site Compliance Report

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USGS SITE COMPLIANCE REPORT USCG LIGHT STATION, SENTINEL ISLAND, ALASKA

I:\ERS-UR\TO09-13 USCG\TO13 SCRS\ELDRED ROCK\ELDRED ROCK SCR_2011_9.DOC

Figure 2-2 Eldred Rock Vicinity Map

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The Lighthouse reservation encompasses the entire island, which is approximately 2.4 acres.

Original facilities at Light Station Eldred Rock included a Lighthouse, water cistern, Paint

Shop, Carpenter Shop, seven aboveground storage tanks (AST), two day tanks, Bunkhouse, Boathouse, and Tramway. A Helicopter Pad was built later. The Lighthouse sits on the high point at the southern end of the island, approximately 35 feet above mean high water. The topography drops steeply to the rocks of the tidal zone to the east, south, and west of the

Lighthouse. The topography drops gradually toward the other buildings on the island to the north of the Lighthouse (CH2M HILL 1997b).

2.3 Facility Ownership and Operational Background

From 1906 to 1973, USCG operated the Light Station Eldred Rock as a major aid to navigation. USCG decommissioned this site and defined it as an excessive property and, in

2004, prepared to turn the land over to the Bureau of Land Management under the National

Historic Lighthouse Preservation Act (NHLPA) of 2000 (USCG 2004). At the time of SCR

Revision 00, USCG was in the process of conveying Eldred Rock to the Eldred Rock

Lighthouse Committee under the sponsorship of the Sheldon Museum and Cultural Center.

The committee planned to restore the Lighthouse and open it to the public (USCG 2007a). It is uncertain if this has been completed. The National Weather Service maintains a meteorological observation tower on the island.

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Table 2-1 Timeline of Events for Light Station Eldred Rock

Year History of Light Station Eldred Rock

1905 Construction of the Light Station completed 1906 Light first lit 1939 Radio telephone installed at the Light Station 1973 Light Station becomes automated 1975 Eldred Rock Lighthouse added to the National Register of Historic Places 1980 Light Station converted to solar power

1994 Civil engineering assessment performed

1997 Site added to Alaska Department of Environmental Conservation’s (ADEC) Voluntary Cleanup Program (VCP) (CH2M HILL 1997a)

1997 Phase I and II Environmental Site Assessments conducted by CH2M HILL

2002 USCG reports the Light Station as excess property; Phase III site investigation conducted by CH2M HILL

2004 Removal action conducted by Jacobs

2007 Modified Phase II/III Environmental Due Diligence Audit (EDDA) performed by Jacobs

2008 Initial ranking with Exposure Tracking Model completed

2009 Ecoscoping form completed by Jacobs

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3.0 REGULATORY FRAMEWORK AND STATUS

This property falls under Alaska Department of Environmental Conservation (ADEC) Alaska

Administrative Code (AAC), Title 18, Chapter 75, Oil and Hazardous Substances Pollution

Control. This regulation describes methods and/or approaches for arriving at soil and groundwater cleanup criteria.

Lead cleanup levels must be determined on a site-specific basis, based on land use. ADEC had approved an Alternate Concentration Limit (ACL) for Southeast Alaska Light Stations of

1,064 milligrams per kilogram (mg/kg) (USCG 2007a). Table 3-2 lists the ADEC soil cleanup criteria applicable to Eldred Rock.

Table 3-1 Site Drivers and Contaminants of Concern

Location COCs Driving Authority

ASTs RRO ADEC

Soil surrounding buildings Lead ADEC

Notes:

For definitions, see the Acronyms and Abbreviations section.

Table 3-2 ADEC Soil Cleanup Criteria Applicable to Eldred Rock

ADEC Soil Cleanup Level Cleanup Level Calculation Approach Soil (over 40-inch precipitation zone)

Contaminant Ingestion (mg/kg) Inhalation (mg/kg)

RRO 13,700 22,000

Lead ADEC-approved ACL of 1,064

Note:

For definitions, see the Acronyms and Abbreviations section.

3.1 Environmental Due Diligence Audit

An Environmental Due Diligence Audit (EDDA) is a systematic investigation of real property to determine if activities involving hazardous materials have occurred at a site or resulted in

Page| 8 environmental contamination. This process is one that is based on the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA) and specified to facilitate the disposition of properties using the rigorous process identified in Civilian Federal

Agency Task Force (CFATF) guidance (CFATF 1998). The three phases are as follows:

• Phase I: Determines whether environmental contamination is likely to be present on a property.

• Phase II: Confirms the presence or absence of contamination by means of a site characterization.

• Phase III: Provides information to agency decision-makers regarding the extent and magnitude of contamination liability.

Each phase of the EDDA process is undertaken only if the results of the previous phase indicate that further action is warranted.

The EDDA process is governed by CFATF guidance (CFATF 1998). Table 3-3 summarizes the current state of the EDDA process for Light Station Eldred Rock.

Table 3-3 EDDA Activities for Light Station Eldred Rock

Project Number Phase I Phase II Phase III

17-J4199 Notes:

= Phase has been completed = Phase has been partially completed = Phase has not been completed

Remedial action may begin following the evaluation of remedies and the completion of a proposed plan and record of decision for CERCLA cleanup actions, or corrective action plans for State of Alaska only projects. In general, cleanup plans must include an evaluation of

Applicable or Relevant and Appropriate Requirements (ARAR) and present the methods for achieving cleanup goals. Cleanup goals are determined using CERCLA (42 United States

Code [USC] 9601 et seq.) and ADEC 18 AAC 75.

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3.2 Applicable or Relevant and Appropriate Requirements

ARARs are defined as federal or state laws, regulations, standards, criteria or requirements that would apply to the cleanup of hazardous substances at a particular site. Specific ARARs applicable to Light Station Eldred Rock are listed in Appendix A.

3.3 Advisory Council on Historic Preservation

In December 1975, Light Station Eldred Rock was added to the National Register of Historic

Places. Because of this listing, no work can be undertaken that would affect the structural integrity, appearance, cultural use, or archaeological value of the property without written permission from the State Historic Preservation Officer (SHPO).

The NHLPA (16 USC 470) authorizes the disposal of historic lighthouses reported by USCG to be excess property. The act allows these excess properties to be transferred at no cost to federal agencies, state and local governments, nonprofit corporations, and community development organizations for recreational, cultural, historical, and educational uses. In 2004, USCG reported Eldred Rock as excess property that was in preparation for transfer to the

Bureau of Land Management under NHLPA (USCG 2004).

3.4 Agency Correspondence

USCG property transfer guidelines require that they determine if remedial action is necessary to protect human health and the environment. If an action is justified, that action must be approved of by the U.S. Environmental Protection Agency (EPA) or the state-authorized agency (e.g., ADEC) and put in place at the time of property transfer. Appropriate remedial actions can include deeded land use controls, treatment, removal of contaminants, and/or monitoring (USCG 2003).

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3.4.1 Alaska Department of Environmental Conservation

In a letter dated 21 April 2006, ADEC determined that the concentrations of diesel-range organics (DRO) remaining on site do not pose an unacceptable risk to human health or the environment.

The letter also noted, “This determination is based upon the current location of the soil and may not be appropriate if the soil is moved to another location.” Regarding residual-range organics (RRO) concentrations, ADEC wrote, “Concentrations of residual-range organics exceed the default cleanup level of 8,300 mg/kg, which is based upon the ingestion pathway.

Additional sampling, cleanup, or discussion should be held in order to address this small area of contamination” (ADEC 2006).

The letter also required a proposal to assess the presence of lead-contaminated soil on site in a similar manner as the investigation at Cape St. Elias and that USCG determine a method of tracking the presence of this soil to ensure that it does not inadvertently become excavated and disposed of inappropriately.

In a letter report dated 22 October 2007, Jacobs Engineering Group Inc. (Jacobs) summarized the objectives and field activities performed during the Modified Phase II/III EDDA investigation (USCG 2007b).

3.5 National Environmental Policy Act Issues and Environmentally Sensitive Areas

The National Environmental Policy Act (NEPA) requires federal agencies to incorporate environmental values into their decision-making processes by considering the environmental impacts of their proposed action and reasonable alternatives to those actions. The following table summarizes some NEPA considerations.

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Table 3-4 NEPA Considerations for Light Station Eldred Rock

Tribal, Federal, State, Local Jurisdictions Consultation/NEPA Requirements

Land Use Patterns Minor aid to navigation.

Social Environment Lighthouse is unmanned; may have seasonal visitors.

Wetlands, Fish and Wildlife (including Threatened & Endangered/Protected Species)

No wetlands on Eldred Rock.

Area of bald eagle habitat. Bald eagle species has been upgraded from endangered to threatened;

however, it is still protected under the Endangered Species Act.

Steller sea lions may reside in the upper intertidal zone of Eldred Rock.

Archaeological and Historical Resources Added to the National Register of Historic Places in 1975; preservation of site structures and other artifacts needs to be considered.

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4.0 INVESTIGATIONS TO DATE

Since the mid-1990s, several investigations have been performed at this site to determine the extent of RRO and lead contamination, and to remediate the contaminants. Phase I, II, and III site assessments have been conducted. Details on these investigations are outlined below.

4.1 1994 Civil Engineering Assessment

An onsite civil engineering assessment of Light Station Eldred Rock concluded that the buildings were suffering from years of neglect since the station’s automation, and in the case of the Lighthouse, neglect was threatening the building’s structural integrity (USCG 1994).

The building was recommended to be brought up to safe standards with concurrence of the

SHPO and 36 Code of Federal Regulations (CFR) 800 so the property could be transferred.

The following work projects were recommended for the station to meet safe standards:

• Lighthouse: Scrape and paint exterior; scrape loose paint in interior; repair/replace Lexan storm windows; replace exterior siding; replace interior stair guardrail; replace south entry doors; install ventilation; restore lantern room; repair exterior walk at lantern room; remove asbestos pipe insulation

• Boat House: Replace missing wall shingles; scrape and paint exterior; repair damaged concrete at foundation walls; repair exterior deck at south side; repair/replace Lexan storm windows

• Carpentry Shop: Repair exterior siding; scrape and paint exterior; paint exterior decking;

clean out bird's nests; repair/replace Lexan storm windows

• Site: Remove tank saddles; repair concrete stairs and railing

4.2 1997 Phase I Environmental Site Assessment

In May 1997, CH2M HILL performed a Phase I Environmental Site Assessment for the

USCG for the initial identification of potential contamination (CH2M HILL 1997b). CH2M

HILL reported the following:

• Fuel odors were detected in soil near one of the former ASTs south of the Lighthouse.

Field screening of the soil indicated that the volume of soil is de minimus, as defined by the ADEC Voluntary Cleanup Program (VCP).

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• Discarded portions of asbestos-insulated piping were observed on the rocks west of the Boat House. The material was subsequently removed in 2004 (U.S. Army Corps of Engineers [USACE] 2005).

• Interior paint samples collected from the Lighthouse contained lead in excess of 5,000 mg/kg, the maximum allowable concentration for public housing.

• Two drains originating within the Lighthouse discharged onto the bluffs.

• Most of the fuel piping remained in place. The material was subsequently removed in

2004 (USACE 2005).

• A 55-gallon drum, partially filled with gasoline, was found in the Paint Shop along with an empty drum. About 40 gallons of paint and concrete repair compounds were observed in the Paint Shop. These items were subsequently removed before 2000, as reported by CH2M HILL in 2000.

• A drain was observed discharging from the Paint Shop to the ground.

• One discarded lead-acid battery was observed on the rocks below the helicopter pad.

The material was subsequently removed in 2004.

• Wood preservatives had likely been used on the support timbers of the Helicopter Pad.

4.3 1997 Phase II Environmental Site Investigation

In August 1997, CH2M HILL conducted a Phase II follow-up site investigation. Four soil samples from the AST saddle area were field screened for petroleum hydrocarbons and found to contain concentrations between 14 and 29 mg/kg (CH2M HILL 1997b). Because the volume of the potentially contaminated soil appeared to be de minimus, according to ADEC

VCP guidelines, and because the concentrations of organic vapors were within 5 to 7 parts per million (ppm) of the concentrations of vapors detected in the background soil sample, soil samples were not collected for offsite analysis (CH2M HILL 1997a).

One soil sample and a duplicate were collected from the ground outside the Paint Shop floor drain discharge for laboratory analysis. The samples contained DRO concentrations of 3,600 and 5,000 mg/kg and RRO concentrations of 19,000 and 20,000 mg/kg. One of the samples was analyzed for gasoline-range organics (GRO) and volatile organic compounds (VOC), including benzene, toluene, ethylbenzene, and xylenes. GRO and VOCs were not detected in the sample. Both samples were analyzed for semivolatile organic compounds (SVOC), which were not detected in one sample. One SVOC constituent, di-n-butylphthalate, was estimated

Page| 14 by the laboratory at a concentration below its method reporting limit in the other sample

(CH2M HILL 1997b).

Moisture content of both these samples was high, at 25 and 28 percent, respectively. In comparison, well-drained, sandy soils with low organic content typically have a moisture content ranging from less than 1 percent to about 25 percent at saturation.

The laboratory determined that biogenic interference caused by the presence of peat and other organic materials was likely affecting laboratory results. Silica gel cleanup analysis indicated a decrease of DRO concentration from 6,200 mg/kg before silica gel cleanup to 3,800 mg/kg after cleanup (approximate 40 percent decrease), and a decrease of RRO concentration from

26,000 mg/kg before silica gel cleanup to 13,000 mg/kg after cleanup (50 percent decrease)

(CH2M HILL 1997b).

Total organic carbon analysis was conducted on one soil sample and reported to be 20 percent.

Both soil samples were analyzed for the eight Resource Conservation and Recovery Act

(RCRA) metals. Low levels of barium, cadmium, chromium, and mercury were detected in the samples. Lead was detected at concentrations of 450 and 560 mg/kg, which is low compared to the ADEC ACL for Alaska Light Stations (1,064 mg/kg). Arsenic was detected at concentrations of 6.2 and 6.6 mg/kg, but these amounts may be indicative of natural background concentrations for the area compared to the ADEC proposed arsenic cleanup standards of 3.7 mg/kg (Direct Contact) and 3.9 mg/kg (Migration to Groundwater) (ADEC

2012).

4.4 2000 Corrective Action Plan

In 2000, CH2M HILL prepared a Cleanup Action Plan which called for the removal of soil at the location of the high DRO and RRO concentrations. The cleanup plan was not

Page| 15 implemented because it was decided that resampling was required in the areas to better delineate contamination.

4.5 2002 Phase III Site Investigation

In May 2002, CH2M HILL conducted a Phase III site investigation to collect soil data in order to develop ACLs for lead and diesel fuel-affected soil (CH2M HILL 2002).

Seventeen soil samples were analyzed for lead. Four samples exceeded 1,000 mg/kg, the soil cleanup level for commercial or industrial land use, as applied in 18 AAC 75.340(e)(3). The highest concentration of lead was 1,600 mg/kg, and the sitewide average lead concentration was 608 mg/kg. The lead samples with the highest concentrations were those closest to painted buildings and painted tanks and saddles.

Twelve soil samples were analyzed for DRO. The highest concentration was 6,000 mg/kg at the east end of the tank saddle area. There were no samples exceeding 8,250 mg/kg, the

ADEC Method Two DRO soil cleanup level (ingestion pathway) for areas with over 40 inches of rainfall per year.

Four samples were analyzed for RRO. The highest concentration was 420 mg/kg, and the lowest was 100 mg/kg, both below the ADEC Method Two soil cleanup level.

Two samples were collected south of the Lighthouse and analyzed for RCRA metals.

Concentrations were all lower than ADEC Method Two soil cleanup levels. No significant detections of other contaminants were reported.

4.6 2004 Removal Action

In November 2004, Jacobs conducted removal actions for USCG at Light Station Eldred

Rock. The objective of this project was to remove approximately 1,000 pounds of miscellaneous waste and debris, 926 feet of fuel pipeline, 10 feet of asbestos-insulated pipe, and one lead-acid battery from the subject property. All asbestos waste was transported to

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Anchorage, Alaska, for disposal at the Municipality of Anchorage landfill. The lead-acid battery was disposed of at NAPA Auto Parts in Anchorage (USACE 2005).

Miscellaneous waste compromised of pipe and other debris was disposed of at Haines

Sanitation Inc. in Haines, Alaska. Two pieces of miscellaneous metal protruding from under a boardwalk near the boat house were not removed due to the impracticability of access and the inability to positively identify them as nonhistorical debris.

4.7 2007 Modified Phase II/III EDDA Investigation

In October 2007, Jacobs conducted a Modified Phase II/III EDDA investigation at Light

Station Eldred Rock. The objective of the investigation was to develop a sitewide average lead concentration and delineate potential RRO contamination near the Paint Shop (USCG

2007b).

Forty-five analytical soil samples were collected for lead analysis from the elevated vegetative areas and a small section of the beach that exhibited signs of recreational use. A preliminary assessment of analytical results indicated a sitewide average lead concentration above the ADEC-approved ACL of 1,064 mg/kg. Analytical results showed a lead range from

23.7 mg/kg to 31,000 mg/kg (later identified as a statistical outlier), with the next highest result being 7,990 mg/kg. The average lead concentration was 1,492 mg/kg (USCG 2008).

Eleven analytical soil samples were collected to delineate potential RRO contamination in the area surrounding the Paint Shop. A preliminary assessment of the analytical results indicated that RRO would not remain as a contaminant of concern at the Light Station Eldred Rock site.

RRO results ranged from 440 mg/kg to 1,300 mg/kg. The average RRO concentration was

755.45 mg/kg (USCG 2008).

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4.8 2008 Cleanup Determination Document

Two U.S. Environmental Protection Agency (EPA) models were used to evaluate risk associated with possible and probable future land use: the Adult Lead Model (ALM) and the integrated exposure uptake biokinetic (USACE 2009b).

Using the EPA ALM, various human health exposure scenarios were assessed. It is probable that visits would take place only in the summer months, so 90-day and 120-day exposure scenarios would be both protective and reasonable. The selected scenario accounts for a pregnant adult and excludes children. The results of the modeling for 120 days exposure scenario was 1,449 mg/kg. This is below the sitewide average but is within the margin of error for the calculation. For the purposes of comparison, the ALM 90-day exposure revealed a value of 1,932 mg/kg. It is assumed that any exposure scenario for children would be considerably less than the 120 days, given that most visits would be day visits or overnight stays. The island currently has no facilities or services that would encourage long-term visitation.

Based on the above, seven remedy options were presented:

1. No Action

2. Institutional Controls

3. Lead Hazard Mitigation, Soil Capping, and Institutional Controls

4. Lead Hazard Mitigation, Soil Removal, and Backfill

5. Develop ACLs and Institutional Controls

6. Develop ACLs, Soil Removal, and Institutional Controls

7. Chemically Stabilize Lead in Soil, and Institutional Controls

Option 5 (Develop ACLs and Institutional Controls) was selected because the calculated sitewide average for lead is 1,492 mg/kg, indicating that a risk-based cleanup level protects human health and the environment. Proper maintenance of the Light Station facilities in accordance with the Quit Claim will adequately protect the environment from future flaking paint chips. Lead exposure scenarios using EPA models support the premise that the current sitewide average concentration of lead (1,492 mg/kg) does not pose a threat to future land

Page| 18 users that restrict time on site to 90 or fewer days. Deed restrictions and signs will sufficiently convey limits of land use and restrictions.

4.9 2009 Ecoscoping Form

This form evaluated the ecological risk of any remaining contaminants on site to local biota

(USACE 2009a). It was determined that no further ecological evaluation is necessary. Eldred

Rock presents no beneficial habitat for birds or land-based mammals and, although Sea Otters have been observed on and near Eldred Rock, Alaska Department of Fish and Game notes that they are seldom found more than a few yards from water. Four soil samples were collected from the only reasonable haul-out location on the coastline, which yielded a maximum concentration of 23.7 mg/kg lead. These samples were located at the base of the bluff near the water line, directly below areas characterized by higher concentrations of lead at the top of the bluff. These results indicate that contamination does not migrate from the buildings to the water.

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5.0 CONCEPTUAL SITE MODEL

This section describes information that is pertinent to the development of a conceptual site model for Light Station Eldred Rock.

5.1 Geology

Soil at this site is relatively shallow (a few inches to a few feet). Bedrock is either exposed or very near the land surface. The soils are typically poorly drained, fine grained soils with high organic content (USCG 2003).

5.2 Surface Water

The Lighthouse is situated at the high point of the island, approximately 60 feet above mean low water. Surface drainage is away from the building in all directions. East, south, and west of the Lighthouse, the topography drops abruptly to rocks in the tidal zone. North of the

Lighthouse, the topography drops gradually to moderately toward the Carpenter Shop and

Boathouse.

5.3 Groundwater

Groundwater that may exist at the site is generally not considered a drinking water source.

Groundwater is generally not found within a contribution zone of an active drinking water system and is not within the recharge area for any drinking water well, wellhead protection area, or sole source aquifer (USCG 2003).

When these facilities were manned, rainwater was typically collected from the roof of the

Lighthouse for storage in water cisterns on site. This suggests that no dependable source of groundwater, or that non-potable groundwater, is found at these locations. The USCG has no plans to try to locate groundwater at the sites or provide onsite groundwater or surface water drinking water supplies at these locations. It is unlikely that future owners or leaseholders of the sites would consider groundwater, if present, for use as potable water. Future use of the sites would rely on outside sources of drinking water. Migration to groundwater ACLs were

Page| 20 not developed for the Light Station because groundwater is not used for drinking water purposes.

5.4 Release Description

Individual releases are from lead paint, which was used into the early 1900s, and fuel storage tank leaks/spills.

5.5 Nature and Extent of Contaminants

There remains an area of RRO-impacted soil near the Paint Shop; however, it has been determined to not be a contaminant of concern. RRO was detected in all samples below applicable cleanup criteria. Silica gel cleanup was also run on each sample to remove biogenic organics. RRO concentrations were significantly lower after being run through the process. It is recommended that no further remedial action or investigation is performed in this area for

RRO.

Soil remains impacted by lead. The sitewide average lead concentration exceeded the ACL of

1,064 mg/kg with a concentration of 1,492 mg/kg. There is no likely unconfirmed contamination remaining at this site. A report of the 2007 Modified Phase II/III EDDA investigation indicated that the only remaining contaminant of concern at the site was lead

(USCG 2007b).

5.6 Potential Receptors and Migration Pathways

Based on current understanding of reasonably anticipated future uses of the Light Station

Eldred Rock, the most plausible exposure scenarios are incidental ingestion, inhalation, and dermal contact with onsite soil. Potential receptors at this site include workers, and/or seasonal residents and visitors.

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6.0 DATA GAPS

This section identifies any data gaps involved in the existing studies that are pertinent to site closure.

6.1 Data Gaps in CSM

The minutes from a December 2014 ERLPA meeting mentioned the presence of asbestos tile in the interior of some buildings; these are scheduled for removal in May 2015

(ERLPA 2014).

6.2 Administrative/Regulatory Uncertainties

There are no current administrative/external factors preventing final remedy selection/implementation, nor are there uncertainties relative to remedial action objectives and site closure.

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7.0 ASSUMED PATH TO CLOSURE

A risk screening evaluation and calculation of ACLs has been developed, accompanied by a draft Quit Claim deed administering controls; notable that the public shall have a right to use this site for recreational purposes and that the Grantee shall comply with federal environmental laws in the maintenance of this property. As of the 2011 SCR, ADEC had not responded to these documents (USCG 2011).

7.1 Investigation Activities

Currently no work is planned at Light Station Eldred Rock, though remediation of lead-impacted soil is recommended.

7.2 Remediation Approach

Based on the remote nature of the site and the vegetative mat on top of the bedrock, invasive remedial action activities such as excavation may pose unacceptable consequences to the environment. These actions would further disturb the natural condition of the site, requiring extensive site restoration to bring the site back to its natural condition after remedial activities were conducted.

Reducing the bioavailability (or fraction available for absorption by humans) by chemical in situ treatments is a more viable option. Chemical treatments have a proven track record in reducing Toxicity Characteristics Leaching Procedure concentrations of lead in the soil by bonding with the mineral to form an insoluble compound. Therefore, the anticipated remedy includes administering institutional controls and/or distribution of readily available hydroxyapatite to fix metals from leaching and from bioavailability to humans (USCG 2011).

In May 2015, ERLPA has planned to stabilize all buildings and perform interior building maintenance (e.g., remove lead paint and asbestos tile).

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7.3 Long-Term Management Approach

Due to the isolated nature of this site, institutional controls should be sufficient. If this site is to be opened to the public, the success of remediation efforts should be verified to ensure no risk to site visitors exists.

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8.0 PROJECT RISK PRIORITIZATION

Once we get information from SILC, we will get this section set up

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9.0 REFERENCES

ADEC (Alaska Department of Environmental Conservation). 2012 (April). Oil and Other Hazardous Substances Pollution Control (18 AAC 75).

ADEC. 2006 (April). Letter from ADEC (John Halverson) to USCG (Mr. Mark Ridgway).

Subject: Review of Debris Removal Report and Requirements for Closure, USCG Eldred Rock Light Station, RecKey: 1997110122305.

CH2M HILL. 2002 (12 December). Phase III Site Investigations, Southeast Alaska Light Stations, Eldred Rock Light Station Summary. Prepared for USCG.

CH2M HILL. 1997a (August). Alaska Department of Environmental Conservation Voluntary Cleanup Program Notice of Intent Form: Eldred Rock Light Station. Prepared for

USCG.

CH2M HILL. 1997b (October). Phase I Environmental Site Assessment Report, Eldred Rock Light Station. Prepared for USCG.

ERLPA (Eldred Rock Lighthouse Preservation Association). 2014 (December). Meeting Minutes. http://eldredrocklighthouse.org/meetings

USACE (U.S. Army Corps of Engineers). 2009a (April). Eldred Rock Ecoscoping Form.

Prepared by Jacobs Engineering Group Inc.

USACE. 2009b (June). Eldred Rock Cleanup Determination Document.

USACE. 2005 (April). Debris Removal Report, Eldred Rock Light Station, Final. Prepared by Jacobs Engineering Group Inc.

USCG (U.S. Coast Guard). 2011 (September). USCG Site Compliance Report. USCG Light Station, Eldred Rock, Alaska. Prepared by Jacobs Engineering Group Inc.

USCG. 2008 (April). Eldred Rock; Project 17-J4199; Draft October 2007 Eldred Rock Sample Results. Prepared by Jacobs Engineering Group Inc.

USCG. 2007a (December). USCG Site Compliance Report. USCG Light Station, Eldred Rock, Alaska. Prepared by Jacobs Engineering Group Inc.

USCG. 2007b (October). Eldred Rock Light Station Modified Phase II/III EDDA Trip Report.

Prepared by Jacobs Engineering Group Inc.

USCG. 2004 (June). Eldred Rock Environmental Characterization and Recommended Actions Report. Draft. Prepared by CH2M HILL.

USCG. 2003 (October). Environmental Compliance Evaluation. Final. Prepared by URS.

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USCG. 1998 (January). Memorandum: Eldred Rock Light Station Summary of Soil Sampling and Analysis Results. Prepared by CH2M HILL.

USCG. 1994. Civil Engineer Assessment for Eldred Rock Light Station.

APPENDIX A

Applicable or Relevant and Appropriate Requirements

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Table A-1 ARARs at Light Station Eldred Rock

Act or Regulation Description Comments

Endangered Species Act of 1973 (16 USC

1531. et seq.: 50 CFR

200; 50 CFR 402)

Provides for the protection of endangered and threatened species. Applicable

Migratory Bird Conservation Act (16

USC 715)

The main purpose of the Act is to conduct investigations, to publish documents related to North American birds and to maintain and develop refuges.

Applicable

Fish and Wildlife Coordination Act (16 USC 661, et seq., 40

CFR 6.302)

Requires that federal agencies consult with USFWS, NMFS, and state fish and wildlife agencies concerning potential effects on wildlife. Applies to federal and non-federal permitted/licensed water development projects.

Applicable

Magnuson Fishery Conservation and Management Act

Describes management and utilization of fishery resources in the US exclusive economic zone that extends from 3 to

200 miles offshore.

Applicable

Marine Protection, Research and

Sanctuaries Act of 1972

Authorizes EPA to regulate ocean dumping of industrial wastes, sewage sludge, and other wastes through a permit program.

Applicable

Marine Mammal Protection Act (16 USC

1361, et seq.)

Assigns federal responsibility to maintain marine mammal population at sustainable levels through protection of environments and ecosystems in which these animals interact.

Applicable

Federal Coastal Zone Management Act (16 USC Section 1451-

1464)

Requires coordinated land and water use planning in coastal zones to protect important coastal resources. Applicable

Bald and Golden Eagle Protection Act (16 USC

668-6681; 50 CFR 10

and 50 CFR 22)

Prohibits pursuing, hunting, shooting, killing, trapping, capturing, or collecting of bald or golden eagles and their eggs or nests.

Applicable

Migratory Bird Treaty Act (16 USC 703-712)

Prohibits the taking, possession, buying, selling, or barter of any migratory bird listed, including feathers or other body parts, nests, eggs, or products.

Applicable

Executive Order 11990, Protection of Wetlands

(40 CFR 6, Appendix A) Provides for protection of wetlands. Applicable

Alaska Coastal Management Program

(6 AAC 50)

Protects coastal resource districts by requiring projects to undergo review for consistency with Alaska’s Coastal

Management Program.

Applicable

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Federal Regulations

Act or Regulation Description Comments

NEPA (42 USC. 4371,

et seq.)

Establishes a general decision-making procedure for "major federal actions" that may have potential environmental effects. Requires federal agencies to evaluate environmental consequences of their actions, consider all feasible alternatives, mitigate actions, and involve stakeholders.

Applicable

RCRA (40 CFR 240-

281)

Tracks hazardous wastes from "cradle-to-grave" and controls hazardous waste treatment, storage, and disposal facilities. Specifies whether a waste is hazardous.

Applicable

Toxic Substance Control Regulations (for

PCBs) (40 CFR 761)

Defines PCB-containing fluids and regulates their movement. Applicable

Nationwide Permit 38 as part of the Clean

Water Act; Cleanup of Hazardous and Toxic Waste (33 CFR 330, Appendix A)

Covers specific activities involved in the containment, stabilization, or removal of hazardous toxic waste materials, performed by a government agency.

Applicable

Clean Water Act Prohibits the discharge of dredged or fill material that contributes to degradation of water quality or jeopardizes endangered or threatened species.

Applicable

NPDES Storm Water Pollution Prevention

Plan (Point Source and Non-Point Source

Management)

Provides compliance requirements for point source and non-point source discharges. Applicable

Guidance for Conducting RIs and Feasibility Studies under CERCLA (EPA, 1988b)

Outlines procedures for completion of RIs, including use of ARARs, TBCs, and risk-based cleanup levels. Applicable

Management IDWs During Site Inspections

(EPA 1991)

Outlines procedures for handling and disposal of IDW. Applicable

DOT Hazardous Materials, Substances and Waste Regulations (49 CFR Parts 171, 172 and 173)

Oversees transportation of various preservatives, field supplies, IDW supplies and other hazardous materials.

Transportation of hazardous materials within coastal waters is subject to USCG enforcement. USCG regulations require vessels to obtain permits to ship hazardous materials.

Applicable

Occupational Safety and Health

Administration (40 CFR 1910.120)

OSHA requires safe and healthful work practices and environments, including specific training for hazardous or toxic wastes site actions.

Applicable

Alaska Solid Waste Management (18 AAC

60)

Regulates solid waste accumulation, storage, transportation, and disposal. Applicable

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Federal Regulations

Act or Regulation Description Comments

Alaska Oil and Hazardous Substance Pollution Control (18

AAC 75)

Defines release and disposal requirements for discharge and cleanup of petroleum hydrocarbons. Applicable

Transportation of Hazardous Waste (18

AAC 62.230, 18 AAC

62.310)

Outlines hazardous waste transportation regulations. Applicable

ADEC Interim Guidance for Non-UST

POL Soil

Provides guidance for non-UST POL-impacted soils, from storage to sampling, handling, storage, and disposal. Applicable

ADEC Guidance for Wastewater Discharge

Provides guidance for application, permitting, and restrictions for discharge of wastewater. Applicable

APPENDIX B

Ecoscoping Forms

Eldred Rock Light Station Ecological Screening Results—DRAFT

The State of Alaska’s oil and hazardous substance site cleanup regulations [18 AAC

75.325 – 18 AAC 75.390] have established cleanup standards necessary to protect both human health and the environment. The ADEC is in the process of developing Ecological Risk Screening methodology used to evaluate ecological conditions at sites contaminated with hazardous substances. The Ecological Risk Screening evaluation includes the assessment of contaminant toxicity and quantity, quality and availability of habitat, and exposure routes. ADEC ecological screening checklists were completed for selected USCG light stations in Southeast Alaska, including Eldred Rock. The following summary contains the methods used and the detailed results of ecological screening for Eldred Rock.

FIGURE-1

Eldred Rock Island Light House

The light station reservation occupies the entire island, which is located within the boundaries of the Tongass National Forest. There are two small spruce trees growing near the light station buildings. No known streams, rivers or lakes exist on the small island. Sea otters have been observed on the island. The Phase III investigation reported dead sea otters inside the boathouse (CH2M HILL, 2002).

Eld d R k Li ht St ti

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No known protected species or special interest habitat have been noted at this location;

however, the threatened Steller sea lion, eastern stock, may haulout in the upper intertidal zone of Eldred Rock.

The contaminants detected in the Eldred Rock soil investigation include: lead, DRO’s, RRO’s, Barium, Cadmium, Chromium, Mercury, Benzo(a)pyrene, acetone, and benzene.

The ecological screening results for the aquatic and terrestrial environments are based on all available information.

No known streams or lakes are found on Eldred Rock. Most precipitation falling on the Eldred Rock Light Station area probably runs off rapidly directly into sea (Selkregg, 1976). The soil at Eldred Rock is dominated by well established grass and exposed bedrock. The island is exposed to erosion. It is assumed that if site contamination migrated from the site to the intertidal/subtidal zones, the contaminant would be unmeasurable at the point of entry into Favorite Channel and Lynn Canal due to tidal and current action along the shoreline. Therefore, the aquatic receptor pathway at this site is incomplete and there is no definitive ecological risk associated with the aquatic environment.

Contaminant exposures to the terrestrial environment include both soil and food chain pathways. Lead is known to bioaccumulate and is likely to be taken up by soil invertebrates, which are in turn eaten by higher food chain organisms. The toxicity of lead and RRO is medium and quantity is low (<1 acre). Because this site is relatively developed with little to no natural vegetation the habitat ranking is low. Therefore the overall results to terrestrial ecological risk screening indicate “low potential risk- end screening here.”

The following information has been included to supplement the ADEC Ecological screening results for the Eldred Rock:

2.0 ADEC Summary Form

Photographs Vicinity Map Summary Form

3.0 Application of ADEC preliminary draft Guidance of Ecological Screening Toxicity Quantity Habitat Receptor

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Table 3 Ecological Screening Summary Form Scenario

Terrestrial Aquatic Provide site location figure, USGS map of area, National Wetlands Inventory map and aerial photograph, if available.

Contaminant Toxicity and Quantity List Contaminants of Concern with quantity of contaminated soil and the associated toxicity rating from Appendix C.

Contaminant Quantity of

Contaminated Soil Terrestrial toxicity Rating

Aquatic toxicity Rating

Lead (Pb) Low Medium High DRO's Low Medium High RRO Low Low Medium Barium Low Medium High Cadmium Low Medium High Chromium Low Medium High Mercury Low High High Benzo(a)pyrene Low Medium High Acetone Low Medium High Benzene Low High High

Multiple Contaminants Present?

Yes No

Receptor Pathway Interactions present?

Terrestrial Aquatic

Yes No Yes No Provide graphic Conceptual Site Model and include completed Tables 2 and 3.

Habitat Rating

High Medium Low Provide results of the questions asked in the flow charts in Figures 2 and 3.

Model Result Recommendation

Low Potential Risk – End Screening Moderate Potential Risk – Phase II advised depending on site-specific conditions Moderately High Potential Risk – Phase II strongly advised High Potential Risk – Phase II required No receptor Pathway Interactions – End Screening

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Application of ADEC preliminary draft Guidance on Ecological Screening

SUMMARY MATRIX

Ranking Score = MCF x (Toxicity x Quantity x Habitat x Receptor)

Terrestrial Overall Input Parameter score: (Toxicity x Quantity x Habitat x Receptor) =

(High) (Low) (low) (Yes) (5.1) x (1) x (0.33) x (1) = 1.7

Aquatic Overall Input Parameter score: (Toxicity x Quantity x Habitat x Receptor) =

(High) (Low) (low) (No) (5.1) x (1) x (0.33) x (0) = 0

Multiple Contaminant Factor (MCF) = 1.5

Terrestrial = 2.6 Aquatic = 0 2.6 = Low Potential risks – End Screening here

Toxicity

Contaminant Terrestrial Aquatic Score Lead (Pb) Medium High

DRO’s Medium High GRO High High RRO Low Medium

Toluene High High Xylene High High Barium Medium High

Cadmium Medium High Chromium Medium High Mercury High High High = 5.1

Quantity

Quantity for Terrestrial Evaluation Rating Quantity for Aquatic Evaluation

>5,000 spilled gallons, or > 10,000 cubic yards of contaminated soil, or > 10 contaminated acres

High >5,00 spilled gallons, or > 1,000 cubic yards of contaminated soil, or > 1 contaminated acre

Unknown Quantity Unknown Unknown Quantity

500-5,000 spilled gallons, or 1,000 – 10,000 cubic yards of contaminated soil, or 1 – 10 contaminated acres

Moderate 50-500 spilled gallons, or 100 – 1,000 cubic yards of contaminated soil, or 0.1 – 1 contaminated acres

<50 spilled gallons, or <100 cubic yards of contaminated soil, or < 1 contaminated acre

Low <50 spilled gallons, or <100 cubic yards of contaminated soil, or < 0.1 contaminated acre

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Habitat Figure 1 Terrestrial Habitat Determination score = 0.33

High

No

Are there endangered species in the site vicinity that could potentially be exposed to contamination in the terrestrial environment?

NO Yes

Low

Yes

Are there areas of natural vegetation larger than 10 acres that may be impacted by site contaminants? NO

No

High

No

Are there contiguous areas of natural vegetation larger than 100 acres that may be impacted by site contaminants?

Yes

Moderate

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Figure 2. Aquatic Habitat Determination score = 0.33

No

High

Are there endangered species in the site vicinity that could potentially be exposed to contamination in the terrestrial environment?

NO Yes

Are aquatic habitats such as lakes, wetlands, streams, bays, intertidal zones, or estuaries of any size present within the potential influence of site contaminants? NO Low

Yes

No

If aquatic habitats do exist within the potential impact of site contaminants, are they able to support resident or seasonal fish or other ecological receptors, as documented by ADF&G or other sources? NO

No

Moderate

Do aquatic habitats or wetlands within the potential influence of site contaminants provide “high” habitat values, as documented by ADF&G or other sources? NO

Low

No

Yes

High

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Receptor

Table 1 Terrestrial Receptor-Pathway Interactions score = 1 Pathways and Exposure Routes Yes No Unknown Surface Water

Terrestrial organisms likely to be exposed to water-borne contaminants as a result of wading or swimming in contaminated waters or ingesting…