The U.S. Government’s management of the commercial fur-sealing industry contributed to some degradation of environmental quality on the Pribilof Islands. The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA), through its Office of Response and Restoration, Pribilof Project Office, was responsible for site characterization and restoration activities on two of the Pribilof Islands, St. Paul and St. George. Public Law No. 104-91 of 1996 (see Document Library), commonly known as the Pribilof Islands Environmental Restoration Act, mandated the Secretary of Commerce to clean up landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, and contaminants left by NOAA on lands which it and its predecessor agencies abandoned, quitclaimed, or otherwise transferred, or are obligated to transfer to local entities, or residents on the Pribilof Islands pursuant to the Fur-Seal Act of 1966 (see Document Library). A Pribilof Islands Environmental Restoration Agreement (see Document Library), commonly referred to as the Two-Party Agreement (TPA) signed by NOAA and the State of Alaska in 1996 provided the framework for NOAA’s cleanup activities on St. Paul and St. George Islands.
Public Law No. 106-562 of 2000 (see Document Library), the Pribilof Islands Transition Act, reauthorized funding for environmental restoration on the Pribilof Islands. Further, it made third parties responsible for the clean up of any contamination, debris, or unsafe conditions to which they contributed after March 15, 2000, and it relieved the Department of Commerce of any liability for contamination or debris left by the Department of Defense at formerly used defense sites (FUDS). The Department of Commerce and NOAA have otherwise assumed responsibility on behalf of NOAA and its predecessor agencies for the environmental restoration of the Pribilof Islands.
The Introduction briefly mentioned that a general lack of concern over environmental protection resulted in uncontrolled petroleum product releases and the accumulation of solid wastes. The reliance on petroleum fuels for home heating, electrical generation, and automotive needs began in the early 1900s, and increased in the mid-1960s when coal as fuel went by the wayside. Uncontrolled releases occurred at tank farms, underground storage tanks, and corroded fuel transfer lines. Waste oils accumulated in barrels deposited on the tundra. Corrosion, dumping, and bullet holes in the barrels led to soil and groundwater contamination. Household and industrial waste dumps and landfills dotted the islands. These problems could not hide forever from the nation’s relatively newly acquired awareness of environmental quality.
One of the earliest documented discussions of contamination on the Pribilof Islands came from an investigation undertaken in October 1983 by Carl Harmon (1984) of the Alaska Department of Environmental Conservation. NOAA first surveyed sites on the Pribilof Islands for debris and contamination in 1990, in response to concerns expressed by local entities regarding lands either transferred under the Alaska Native Claims Settlement Act or scheduled for transfer under the Transfer of Property Agreement (see Document Library; and, NOAA 1984) between NOAA and local entities. Steve Buckel, a NOAA civil engineer, traveled to the Pribilof Islands to evaluate the sites brought to NOAA’s attention. In his report, Buckel stated, “It became evident during the site surveys that the scope of the compliance problems were far more extensive than was originally anticipated…” (Buckel 1990).
Subsequently, NOAA initiated a preliminary assessment intended to present information concerning past NOAA activities and report on the Pribilof Islands’ site conditions (Ecology and Environment 1993). NOAA contractors conducted environmental assessments to sample, consolidate, and inventory fluids from drums, vehicles, and other containers at several sites on the islands (Harding Lawson Associates 1993; Woodward-Clyde 1994). By the mid-1990s, NOAA requested expanded site inspections to determine the nature and extent of chemical contamination on St. Paul and St. George Islands (Woodward-Clyde 1994; Woodward-Clyde 1995; Hart Crowser 1997). The results of these investigations provided the basis for the direction ascribed in the TPA signed by NOAA and the State of Alaska (NOAA 1996).
NOAA agreed to identify, assess, remedy, and monitor environmental contamination at twenty sites on St. Paul Island and twenty-two sites on St. George Island under the TPA (TPA Attachment A-Source Areas). Since 1996, some of the sites in Attachment A have been subdivided. Sites have also been added to the list of source areas. In conjunction with environmental restoration actions, the TPA called on NOAA to establish a restoration advisory board (RAB) and to maintain an administrative record.
Causes of Environmental Contamination
The primary contaminant of concern on St. Paul and St. George Islands has been diesel fuel, although gasoline, kerosene, and waste oil also contributed to the need for remediation. Until the mid-1980s, St. Paul Island lacked a protected harbor. At St. George Island, it was not until 1993 that sufficient funding became available to construct a harbor. Without docking facilities, goods and supplies were lightered from ships anchored offshore onto skin boats called baidars, or onto small barges. Fuels used for home and commercial heating, electrical generation, and vehicle operation went ashore in drums or barrels. Beginning about 1970, barges lightered fuels through floating lines connected to onshore transfer pumps or connected directly to aboveground or underground storage tanks (ASTs and USTs). In addition, aboveground and underground pipelines facilitated transfer from one tank to another or to a facility, such as an electrical generating station or gasoline station. ASTs ranged from fifty-five-gallon home heating oil tanks to 200,000-gallon bulk storage tanks. USTs supplying homes with heating fuel typically held 500 to 3,000 gallons, whereas tanks for the electrical generating station held as much as 10,000 gallons. These processes resulted in inadvertent fuel spills and leaks. Barrels tipped over; pipelines and tanks corroded; and valves were occasionally left open.
The improper storage and disposal of waste oil and antifreeze on the islands also led to environmental contamination. Poor management practices of waste oil arose, in part perhaps, from the cost and difficulty associated with shipping the waste off the islands for disposal. Not until the construction of harbors on St. Paul and St. George Islands did opportunity improve to rid the islands of its waste oil. Yet, even then, the disposal situation did not improve. In fact, some vessels of the Bering Sea fishing fleet discarded their waste oils in barrels on the islands with little concern for proper disposal. Not until about 2004 did local entities on St. Paul Island invest in used oil burners as a cost-effective solution to the issue. On St. George Island, however, waste oil was stored in a dilapidated building located west of town. The building housed more than one hundred stacked, rusting drums filled with waste oil from the past ten to fifteen years. During 2007 and 2008, NOAA worked with the St. George community to rid it of its waste oil problem.
NOAA Actions to Restore the Pribilof Islands
By the end of 1997, NOAA and its contractors had consolidated and removed thousands of tons of debris consisting of old cars, trucks, tractors, barrels, storage tanks, batteries, scrap metal, and tires from St. Paul and St. George Islands (Aleutian Enterprises 1997; Polarconsult 1997). Another major debris removal effort took place on St. Paul Island in 2000 (Nortech 2001); during this time NOAA afforded the community an opportunity to dispose junk vehicles, tires, and other debris. NOAA continued to remove smaller quantities of debris from the islands on multiple occasions through 2005.
Beginning in 2002, NOAA focused cleanup efforts on the remediation of soil contamination and the characterization of groundwater. NOAA and its contractors sampled for soil and water contamination at known or suspected sites. NOAA applied analytical sample results to determine the nature and extent of contamination, and to direct corrective actions where necessary.
NOAA completed cleanup of contaminated soil at all sites for which it is responsible on St. Paul and St. George Islands in 2007. When consistent with the nature of sites, NOAA has restored sites by applying fertilizer, native grass seeds, and other appropriate techniques to topsoils.
NOAA extensively characterized physical and chemical properties of groundwater in the vicinity of sites where soil contamination is or was present. NOAA plans to conduct free product (i.e., a non-aqueous phase liquid, in this case a plume of mostly diesel fuel and some gasoline floating on top of the groundwater table) recovery in the St. George Island industrial oceanfront area (SLR Alaska 2005). NOAA also intends to conduct long-term groundwater monitoring on both islands; the Alaska Department of Environmental Conservation has approved monitoring plans for both islands at sites where groundwater contamination persists (NOAA 2005b; NOAA 2005c).
NOAA restoration priorities also included the close out of the unpermitted municipal solid waste (MSW) and solid waste landfills that began during the time of the federal government’s management of the islands (e.g., the municipal landfill, ocean dumpsite, and the ballfield landfill on St. George; the municipal landfill, vehicle boneyard, and village cliffside landfill on St. Paul). Public Law No. 104-91 mandated the development of new MSW landfills on St. Paul and St. George Islands. Prior to closing out the currently functioning landfills on each island, NOAA worked with the two island communities to develop new and permitted MSW landfills. St. Paul and St. George Islands’ new landfills began operations during 2005 and 2007, respectively.
Completion of Corrective Actions
Upon completion of corrective action activities, NOAA submitted to the Alaska Department of Environmental Conservation (ADEC) a request for a conditional closure determination, also known as a “no further remedial action planned,” or “no further action determination.” Each request summarized a restored site’s history, previous investigations, and cleanup actions using text, tables, and figures. A request presented NOAA’s efforts to complete site restoration activities according to State of Alaska regulations. The Alaska Department of Environmental Conservation project manager’s signature on the request confirmed the state’s concurrence. On June 4, 2008, NOAA's corrective action activities for the St. Paul Operable Unit was closed. NOAA anticipates ADEC will closeout the St. George Island Operable Unit by October 2008.
Lead and Asbestos Abatement
In 2005, another issue on St. Paul Island came to NOAA’s attention. NOAA conducted lead-based paint and asbestos-containing material surveys of its structures on St. Paul Island in preparation for their transfer to local entities. During these surveys, NOAA identified the presence of lead-based paint and asbestos-containing building materials in residential and child care structures. The Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X of the Housing and Community Development Act), specifically Sections 1012 and 1013, requires that NOAA document and disclose the location, material (e.g., painted drywall, window sill), and condition for all identified lead-based paint for all target housing constructed prior to 1978. Additionally, this act required NOAA to abate lead-based paint hazards at all target housing constructed prior to 1960. This act does not require any inspection, disclosure, or abatement of lead-based paint in any other structure, including child care structures. The Asbestos Hazard Emergency Response Act (AHERA)/Asbestos Schools Hazard Abatement Reauthorization Act (ASHARA) required inspections and disclosure of the presence and condition of asbestos-containing building materials in schools serving grades kindergarten through 12. These acts do not require any asbestos inspections or abatement in any other structures, only that any voluntary inspections or abatements in other structures be conducted consistent with federal guidelines for worker qualifications and asbestos practices. In 2006, NOAA abated lead-based paint hazards at five structures on St. Paul Island: duplex 108/109; the former electrical shop; and former teachers' houses 101, 102, and 103. The lead-based paint abatement at the former electrical shop was not required under Title X, however NOAA determined it appropriate given the building’s use by the community for its pre-kindergarten Head Start program. NOAA also abated asbestos hazards at six structures on St. Paul Island: the five-car garage, duplex 108/109; the former electrical shop; and former teachers' houses 101, 102, and 103. None of these asbestos abatements were required under AHERA or ASHARA, however NOAA determined it appropriate given the potential for asbestos exposures by building occupants and visitors.
Department of Defense Environmental Restoration
The Department of Defense has also been responsible for environmental cleanup at the Pribilof Islands. The U.S. Army occupied the islands during World War II and left behind debris and thousands of fifty-five-gallon drums. In 1985, the U.S. Army Corps of Engineers identified twelve sites (referred to as formerly used defense sites or FUDS) at St. Paul and St. George Islands requiring cleanup.32 The Corps summary of work stated that the drums were somewhat consolidated at dump sites on the islands. Though many drums appeared to be empty, they had at one point contained petroleum, oils, and lubricants. Hence, it was possible their contents leaked to the soils on which they were deposited.
At St. Paul Island, the U.S. Army Corps of Engineers 1985 document identified the following sites for cleanup:
- Site A: abandoned LORAN station World War II
- Site B-1: barrel dump near landing strip
- Site B-2: barrel dump east of Big Lake
- Site B-3: wooden structure near Lake Hill
- Site C: Telegraph Hill barrel dump
- Site D: Ridge Wall borrow pit
- Site E-1: debris in and around City of Saint Paul
- Site E-2: other debris below cliff southeast of city
- Site F: Quonset ruins near airport
On St. George Island, the U.S. Army Corps of Engineers identified the following sites for cleanup:
- Site G: barrel dump
- Site H-1: miscellaneous debris
- Site H-2: World War II-era collapsed wooden hut on hill east of airstrip
In 2001, the U.S. Navy additionally identified the former radio station complex on St. Paul Island as a FUDS.
The fact that some of the Pribilof Islands' FUDS became contiguous with NOAA Two-Party Agreement sites complicated cleanup issues. Section 3(f)(2) of Public Law No.10491, as amended by Public Law No. 106562, which authorizes the funding for NOAA’s Pribilof Islands cleanup activities, stipulates: “None of the funds authorized by this subsection may be expended for the purpose of cleaning up or remediating any landfills, wastes, dumps, debris, storage tanks, property, hazardous or unsafe conditions, or contaminants, including petroleum products and their derivatives, left by the Department of Defense or any of its components on lands on the Pribilof Islands, Alaska.” The U.S. Army Corps of Engineers conducted debris cleanup on St. Paul and St. George Islands in the mid-1980s (Chase Construction Inc. 1986). NOAA, in an effort to meet its legal obligations to clean up contamination and debris consistent with statutory requirements and constraints, made efforts to discern and address contamination caused by it and its predecessor agencies. Though both NOAA and the U.S. Army Corps of Engineers contributed to the Pribilof Islands cleanup, disagreement existed at least through 2007 regarding remaining debris and associated cleanup responsibilities (NOAA 2004a; NOAA 2004b; NOAA 2005a).
NOAA prepared and maintains an administrative record of the Pribilof Islands environmental restoration project in accordance with guidance under the Comprehensive Environmental Response, Compensation, and Liability Act of 1986, as amended, the TPA (NOAA 1996), and other applicable laws and agreements. The administrative record contains documents that formed the basis of NOAA’s decisions regarding restoration efforts on the Pribilof Islands. The administrative record is indexed and is searchable via a corresponding database. Copies of the administrative record and database are available at the following locations:
- NOAA, Office of Response and Restoration, Pribilof Project Office, Seattle, Washington
- National Archives and Records Administration, Pacific Alaska Region, Seattle, Washington
- Traditional Council of St. George, tribal office, St. George, Alaska
- St. Paul Tribal Government, Ecosystem Conservation Office, St. Paul, Alaska
- Alaska Resources Library and Information Services, Anchorage, Alaska