REMOVAL II ADMINISTRATIVE RECORD FILE FOR THE …

•v UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

\ REGION 6$ 1445 ROSS AVENUE, SUITE 1 £00

* DALLAS, TX 75202-2733

ADMINISTRATIVE RECORD FILE

REMOVAL II

SITE NAME: OKLAHOMA REFINING COMPANY, NPL

CYRIL, CADDO COUNTY, OKLAHOMA

SITE NUMBER: OKD091598870

VOLUME 1 OF 1

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ADMINISTRATIVE RECORD FILE INDEX

REMOVAL ACTION II

SITE NAME: OKLAHOMA REFINING COMPANY, NPL

SITE NUMBER: OKD09159887O

INDEX DATE: DECEMBER 02, 1993

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,v^£0 sr4> r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

5 tSil REGION 6 i l/Z " 1445 ROSS AVENUE, SUITE 1200

DALLAS. TX 75202-2733 -C).

PACT SHEET

Administrative Records in Local Repositories

The "administrative record" is the collection of documents which form the basis for the selection of a response action at a removal site. Under section 113(k) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Super fund Amendments and Reauthorization Act (SARA) , EPA is required to establish an administrative record for every CERCLA response action and to make a copy of the administrative record file available at or near the site.

The administrative record file will be available for public review during normal business hours. The record file is treated as a non-circulating reference document. Individuals may photocopy any documents contained in the record file, according to the photocopying procedures at the local repository.

The administrative record file will be maintained at the local repository until further notice. Documents may be added to the record file as the site work progresses. EPA may send supplemental volumes and indexes to the local repository to be placed with the initial record file.

The Agency may hold formal public comment periods at certain stages of the reponse process. The public is urged to use these formal review periods to submit their written comments. EPA welcomes written comments at any time on documents contained in the administrative record file. Please send any such comments to:

U.S. EPA Removal Administrative Record Coordinator Emergency Response Branch (6E-E) 1445 Ross Avenue Dallas, TX 75202

Printed on Recycled Paper

I

United States Environmental Protection Agency

Office of Emergency and Remedial Response Wasfiington DC 20460

rail ibu/' WH/FS-87-003R

The Superfund Removal Program

Incidents involving hazardous substances that present an imminent threat, to human health or the envirorment may occur or be discovered in any community at any time. These kinds of incidents may include, but are not limited to:

• Illegal disposal of toxic materials or hazardous waste,

• Improper handling or disposal of hazardous substances at landfills,.industrial areas, etc.

• Spills of hazardous substances when a truck or train overturns,

• Discharges of hazardous substances into the air or water during a fire.

The U.S. Envircxmental Protection Agency (EPA) Superfund Elmergency Response Program was created to respond to situations such as these.

How Can EPA Respond to Releases or Threatened Releases of Hazardous Substances?

Under Superfund, EPA may respond to releases or threats of releases of hazardous substances by starting a removal action. A removal action is a short-term action intended

Congress enacted the Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA). commonly Imown as Superfund. in 1980. This law created a tax on the chemical and petroleum industries and provided a broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger put>lic health or welfare qr the environment Over 5 years. SI 6 billion were collected and the tax went to a Trust Fund for cleaning up abandorted or uncontrolled -hazardous waste sites The U S. Environmental Protection AgenTy (EPA) is responsible for running the Superfund program. On Octot>er 17.

1986. the Superfund Amendments and Reauthorization Act (SARA) was signed into law. SARA increases the Trust Fund to $8.5 billion over 5 years and strengthens EPA's authority to conduct cleanup and enforcement activities. Under the Superfund program. EPA can: • Pay for the cleanup of ftazardous waste sites when those responsit>le for such sites cannot t>e found or are unwilling or unable to dean up a site, • Take legal action to force those responsible for ftazardous waste sites that threaten public health or the environment to clean up those sites or pay back the Federal

govermnent for tfie costs of cleanup. The law authorizes two kinds of response actions: • Short-term removals where actions may be taken to address releases or threats of releases requiring prompt response. • Longer-term remedial responses tfiat permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances tftat are serious but not immediately life threatening. They can be conducted ortly at sites on EPA's IMational Priorities Ust (NPL). Remedial and removal responses indude. but are not limited to:

• Destroying, detoxifying or immobilizing the hazardous substances on the site through incineration or other treatment technologies. • Containing the substances on-site so that they can safely remain there and present no further threat. • Removing the materials from the site to an EPA-approved. licensed hazardous waste facility for treatment, containment, or destruction • Identifying and restorirtg contaminated ground water, halting further spread of the contaminants, or in some circumstances providing an alternate source of drinking water

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to stabilize or clean up an incident or site that-poses a threat-to. huran health or the environment. These actions may include: " - _

• Removing and disposing of hazardous substances.

• Constructing a fence, posting warning signs, or taking other security measures to control access of humans _ _ or animals to a site,

• Providing alternate water supplies to local residents vrfiere drinking water has become contaminated,

• Temporarily relocating area residents.

Under Superfund, ratoval actions can last no longer than 12 months in duration or cost more than $2 million, although exenptions may be granted in certain circumstances.

Because the purpose of removal actions is to respond to more imnediate threats and because th^ are short-term actions, they generally cannot deal with long-term environmental problems like area-wide contaminatiw of ground water. In that event, the On-Scene Coordinator refers the site to EPA's Remedial Response Program for further investigation and assessment.

Remedial actions are longer-term actions that step or substantially reduce releases or threatened releases of hazardous substances that are serious but not immediately life-threatening. Remedial actions can be undertaken only at sites on EPA's National Priorities List (NPL), which identifies the most serious uncontrolled or abandoned hazardous waste sites. EPA often conducts both removal and remedial actions at NPL sites. Removal actions may be required if an iirenediate threat is discovered during remedial work. Removals also must jeontribute to the efficient performance of any long-term remedial action.

How Does the Removal Program Work?

The National Contingency Plan (NCP), the Federal regulation that guides the Superfund program, outlines the roles and responsibilities of each agency involved in responding to releases or threatened releases of hazardous substances. The U.S. Coast Guard has primary responsibility for response to releases in or upon the coastal and other navigable waters of the United States, and EPA has primary responsibility for inland response.

The first step in EPA's removal program is the discovery of a release or threatened release of hazardous substances that presents a threat to public health or the envirorroent. EPA may be notified through the National Response Center (NRC) at the 24-hour telephone number 1-800-424-8802, which is operated by the U.S. Coast Guard, or be contacted directly by States, cotmunities, industries or individuals.

The NRC notifies the appropriate government agencies and officials when a release is reported. EPA's On-Scene Coordinator evaluates the situation, and based upon this evaluation, may use Superfund money to clean up the incident if those responsible for the incident cannot or will not conduct the cleanup, or if State or local officials are unable to respond. Other government agencies may be called upon for assistance when necessary, depending upon the nature and extent of the release.

Who Pays For Removal Actions?

Seme ronovals are paid for or conducted by those responsible for creating the emergency. In addition to past and present owners or operators, those responsible may include generators, transporters, storers, or disposers of hazardous substances. The rest may be paid for and conducted by State or county response teams with their own funds, or by EPA, using Superfund money. When Superfund money is used, EPA may take action to force those responsible to reimburse the Federal government for the costs of the cleanup.

COMMONLY USED ACRONYMS

ADPC&E

AO

ATSDR

CDC

CERCLA

EPA

ERB

ERCS

ESD

FOIA

LDEQ

NMED

NPL

CPA

OSC

ODEQ

OSHA

POLREP

PRP

RCRA

SARA

TAT

TNRCC

Arkansas Department of Pollution Control & Ecology

Administrative Order

Agency for Toxic Substances and Disease Registry

Centers for Disease Control

Comprehensive Environmental Response Compensation & Liability Act of 1980

United States Environmental Protection Agency

EPA Emergency Response Branch

Emergency Response & Cleanup Service (EPA Contractor)

EPA Environmental Services Division

Freedom of Information Act

Louisiana Department of Environmental Quality

New Mexico Environment Department (Formerly NMEID)

National Priorities List

Oil Pollution Act

On-Scene Coordinator

Oklahoma Department of Environmental Quality (Formerly OSDH)

Occupational Safety and Health Administration

Pollution Report

Potentially Responsible Party

Resource Conservation and Recovery Act of 1976

Superfund Amendments and Reauthorization Act of 1986

Technical Assistance Team (EPA Contractor)

Texas Natural Resources Conservation Commission (Formerly TWO)

SITE NAME:SITE NUMBER;


REMOVAL ACTION II

OKLAHOMA REFINING COMPANY, NPLOKD09159S870

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE;DOCUMENT TITLE:

AUTHOR:COMPANY/AGENCY:

RECIPIENT:

COMPANY/AGENCY:DESCRIPTION:

08/30/90 FIRST PAGE: 0001 LAST PAGE: 0014Action MemorandumAction Memorandum Request for Removal Action atthe Oklahoma Refining Company NPL Site, Cyril,Caddo County, OKJohn J. Martin, OSCEPA, Region 6Robert E. Layton, Jr., P.E., RegionalAdministratorEPA, Region 6Requests and documents approval for a RemovalAction at the Oklahoma Refining Company NPLSite- Proposed action involves fencing,disposal of wastes, and construction of nettingsystems.

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE:DOCUMENT TITLE:AUTHOR:COMPANY/AGENCY

RECIPIENT:COMPANY/AGENCY

DESCRIPTION:

03/30/90 FIRST PAGE: 0015 LAST PAGE: 0015Enforcement Attachment/Conf identialAttachment 4, EnforcementUnspecifiedEPA, Region 6UnspecifiedEPA, Region 6Enforcement Attachment to the Action Memorandumdated 08/30/90, is Confidential, and located ina separate, Confidential File.

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE:DOCUMENT TITLE:


RECIPIENT:COMPANY/AGENCY;

DESCRIPTION:

01/31/93 FIRST PAGE: 0016 • LAST PAGE: 0034BookletProposed Plan of Action, Oklahoma RefiningCompany, Superfund SiteUnspecifiedEPA, Region 6PublicUnspecifiedIdentifies the preferred options for addressinggroundwater and soil contamination at theOklahoma Refining Company Superfund Site. OSDH,the lead agency, and EPA will select a finalremedy.

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SITE NAME:SITE NUMBER:


REMOVAL ACTION II

OKLAHOMA REFINING COMPANY, NPLOKD091598870

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE:DOCUMENT TITLE;


RECIPIENT:COMPANY/AGENCY:

DESCRIPTION:

06/09/92 FIRST PAGE: LAST PAGE:Record of DecisionRecord of Decision, Oklahoma Refining CompanySuperfund SiteB.J. Wynne, Regional AdministratorEPA, Region 6FileEPA, Region 6Decision document presenting the final selectedremedial action. Document is located at CyrilCity Hall, Cyril, OK, and EPA, Region 6,Dallas, TX.


AUTHOR:

COMPANY/AGENCY:RECIPIENT:

COMPANY/AGENCY:DESCRIPTION;

04/23/93 FIRST PAGE: 0035 LAST PAGE: 0037Letter with CoverOklahoma Refining Company Superfund Site, CaddoCounty, Cyril, OKMark S. Coleman, Deputy Commissioner,Environmental Health ServicesOSDHRussell Phoades, Director, EnvironmentalServices DivisionEPA, Region 6Requests assistance in the abatement of lightnon-agueous phase liquid (LNAPL) surfacing inthe seven sludge traps on site. OSDH does nothave resources available to devote to thisremoval action.



RECIPIENT:COMPANY/AGENCY;

DESCRIPTION:

05/10/93 FIRST PAGE: 0038 LAST PAGE: 0050Site Assessment ReportSite Assessment Report for Oklahoma RefiningCompany, Cyril, Caddo County, OKLeroy G. Hernandez, TATEcology and Environment, Inc. J

John Martin, OSCEPA, Region 6Reports conditions and results of site visitswith OSDH representatives on 04}26/93, and10/17/93. Report includes Photos, Site Sketch,Copy of Logbook, and Copy of TDD.

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REMOVAL ACTION II


OKLAHOMA REFINING COMPANY, NPLOKD091598870

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE:DOCUMENT TITLE:AUTHOR:COMPANY/AGENCY i


DESCRIPTION:

05/18/93 FIRST PAGE: 0051 LAST PAGE: 0068Letter with AttachmentsUntitledGarland L. Swain, Special AgentU.S. Department of the Interior, Fish andWildlifeDennis HrebecOSDHReports conditions found at the Cyril siteduring visit on 04/20/93. Attachments includephotos and aCorporation.

letter sent to Cyril Petrochemical

RECORD NUMBER:DOCUMENT DATE:DOCUMENT TYPE:DOCUMENT TITLE:AUTHOR:COMPANY/AGENCY:


DESCRIPTION:

8LAST PAGE: 007005/26/93 FIRST PAGE: 0069

Map with Fax Cover SheetAbandoned Property and Cyril Petrochemical Co.Terry AndrewsOSDHJohn MartinEPA, Region 6Detailed map of the refinery.



RECIPIENT:


07/06/93 FIRST PAGE: 0071 LAST PAGE; 0076MemorandumAssessment of LKAPL thickness and movement onthe ORC Superfund Site, Cyril, OKTerry Andrews, Senior HydrologistOSDHDennis Hrebec, Ph.D., Superfund DivisionDirectorOSDHReports the measuring of water and lightnon-aqueous phase liquid (LKAPL) elevations inmonitoring wells.

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REMOVAL ACTION II

OKLAHOMA REFINING COMPANY, NPLOKD09159887O



RECIPIENT:


LAST PAGE: 008310

09/17/93 FIRST PAGE: 0077Action MemorandumRequest for a 12-Month Exemption and a RemovalAction at the Oklahoma Refining company NPLSite, Cyril, Caddo County, OKJohn J. Martin, Senior OscEPA, Region 6Russell F. Rhoades, Division Director,Environmental Services DivisionEPA, Region 6Requests and documents approval for a RemovalAction and 12-month exemption at the OklahomaRefining Company NPL Site. Proposed actioninvolves collecting and storing waste, fencing,and repair.




DESCRIPTION:

1109/17/93 FIRST PAGE: 0089 LAST PAGE: 0089Enforcement Attachment/ConfidentialEnforcement Attachment to the Action Memorandumfor the Oklahoma Refining Company NPL SiteSam Becker, Chief, Superfund Enforcement BranchEPA, Region 6Charlie Gazda, Chief, Emergency Response BranchEPAT Region 6Enforcement Attachment to the Action Memorandumdated 09/17/93, is Confidential, and located ina separate Confidential File.

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U N I T E D S T A T E S E M V I R 0 iN M E N T A L P R O T E C T I O N A G E N C Y

i J i n O i : AVEN'LJE iLUTg 1?D

DALLAS T t X ^ S -3^2-2732

3 0 1390

MEMORANDUM

SUBJECT: Action Memorandum Request for Removal Action at theOklahoma Refining Company NPL Site, Cyril, CaddoCounty, Oklahoma

CERCLIS fl OKDO91598S7OSite ID: D9Category of Removal: Time Critical

FROM: John J. MartinQn-Scene Coordinator ( 6E-ES )Removal/Sites Section (6E-ES }

TO: Robert E. Layton Jr., P.E.Regional Administrator (6A)

THRU; Russell F. Rhoades ^>r"'"Di rector ..-''--' - - -sEnvironmental Services Division

I . PURPOSE

This memorandum requeststo the Comprehensive EnviLiability Act ICERCLA) asOklahoma Refining Companyinvolves the installationdisposal of drummed wasteover some of the pits, skthe oil/sludge separatorwe 11s.

approval for a Removal Action pursuantronmental Response', Compensation andamended, 42 U.S.C. 59601 et seq. at the(ORC) MPL site. The proposed actionof a security fence, the propers, the construction of netting systemsimming a layer of waste material fromtraps, and the plugging of old recovery

This action meets the criteria for initiating a removal actionunder S3OO.415 of the National Contingency Plan tNCP) and isanticipated to require less than twelve months and $2 million forcompleticn.

II . BACKGROUND

A. National Significance:

This site is not of national significance.

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B. Sits Desc r i ct i on;

The ORC Site is Iocs ted in Caooo County on the eastern edê ofCyri'!, Oklahoma lust south of the i nte r sect 'ion ot U.S. Highway27 7 and State Highway 65. The Sits covers approximately 150acres and ": s bounded by the town's residential and commercialareas to the north and west, by Gladys Creek tio the northeast andeast, and by an unnamed creek to the south, A segment of theBurlington Northern Railroad divides the ORC Site and the town!srodeo grounds are located immediately adjacent, to the Site's landtreatment arsa. Ths present population of Cyril is approximately1 ,600 pecole with the nearest residences 1 ocatied adjacent to thegiro, A =ite location map is shown on Attachment, 1 ,

As j art of norm a! refinery operations, sludges, oils sndpetroleum products, solvents, and other chemicals were staredand/or generated at the site. V/astes generated during refineryoperations were processed using the waste source units (pits,conds and land treatment area). These waste typically were oilysludges, tank bottoms, caustic sludges, acid w'astes, asohalticwastes, and process wastewaters. j

Recently, the site has been divided into two s,ect i ons for thepurpose of reopening the pr ocsss i ncj facilities] (Attachment 2).The section containing the processing eauiomen't and the majorityof the storage tanks is the Active Area. The jngw property ownerfor ti-ie Active Area has hired a contractor that! is currentlysalvaging the unnecessary equipment and tanksJ The other sectionis the Inactive Arsa consisting of the South Pond System. LandTrsatment Area, the storage pits and the oil/sjludge tracs

C. Incident Characteristics:

The ORC retinine facility was active trom 1920! to 1984. when th»ORC declared bankruptcy. Various refining oro!cesses- wereemployed as follows: crude distillation, vacuum distillation,fluid catalyst cracking unit, alkylation, bi-metallic reformingand downstream processing. ORC produced gasoline, diesei, jetfuel ,' naohtha. heating oil. asohalt. and industrial solvents.The raw materials were received by pipeline, rail and surfacetransport and included crude oil, tetraethyl lead, sulfuric acid,caustic soda and hydrofluoric acid. Importation of a maximum of15,000 barrels of crude oil per day was reached in 19S3 forprocessing at the refinery. It is believed that events in thehistory of the site including breaching of dikjes, leakingunderground pices, soil lass during facility opprations, flooding,and leaking tanks have contributed to site contamination.

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A nu inter of surface impoundments '.vere useo" curing ops rat ion ofche oil refining facility and included a lime soda storage pit.aoid waste pits, temporary slop oil ponds, waste water storagepits, sludge traps, and ponds. Some of the wastes were tilledinto the soil as part of a landfarming operation. The highestcontaminant levels were found in oily wastes detected in soilscollected from on-site storage pits. The predominatecontaminants are lead and chromium but a number of other heavymetals and organic compounds are also common. ! The wide varietiesand large volumes of contaminants found throughout the site'ssurface soils and pits pose a health threat vija dermal contact,incidental ingestion, and inhalation of dusts,; Also, there areseveral deteriorating drums containing product; materials andhazardous wastes scattered throughout the site which pose athreat of release.

Two significant burial areas have been identified near the deepGladys Creek and its unnamed tributary. These burialcontaminating surface water and grouncfwater. One area

ravine cfareas areis the buried acid pits located just south of the North PondSystem, The second burial area is the caustic and lime sodastorage pits located just south of the South Rond System. Bothof these areas continue to leach corrosive and1 hazardousmaterials -into the adjacent creeks. The leachate has had anadverse impact on aquatic plants and animals and has increasedthe potential of human contact to toxic mater i'al;s. These areasare located in the recharge zone of the Rush Springs Sandstoneaquifer. The Rush Springs aquifer has favorable water qualityand serves as a potable water source for localmuni c i pal we 11s.

domestic and

Additionally, severar of the site's monitoring and recovery wellsthat were installed during the facility's operation are locatedin these two burial areas. The wells were constructed with slitsevery foot to a depth of sixty feet, which is below the elevationof the creek beds. These slotted well casings are providing amigration route for the transport of contaminants throughout theshallow and deep portions of the aquifer thereby increasing thedifficulty of remediation. They could be providing conduits forthe plume to extend beyond the natural boundary of the creek.The wells will not be used in the future remedial activities.

D. Quantity and Types of Substances Present:

Hazardous wastes generated by the facility included: APISeparator sludge, tank bottoms from leaded gasoline andtetraethyl lead storage, and other tank bottoms. These wasteswere stored in tanks and earthen pits and treated cnsite by landtreatment. There are approximately 100 impoundments (manyunlined) with flammable or reactive waste. Principle pollutants.

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which are included >n the CERCLA list cf hazardous substances (40rcc Part 302) include arsenic, lead, chrorrn urn, beryllium, andxylene. The volumes of wastes were not documented duringrefinery operations based on review of existing records but roughestimates of waste volume is near -15,000 cubic yards. Also, muchof tne processing equipment has deteriorating insulation whichcontains friable asbestos, also a CERCLA listed hazardoussubstance. The total volume of waste will be defined moreaccurately during the Remedial Investigation.!

E. State and Local Authorities:

The Oklahoma State Department of Health (OSOHJ! has begun thepreliminary stages of the Remedial Investigation and Feasibility1

Study. OSDH has requested EPA Emergency Response Branchassistance to reduce or remedy some of tne more imminent healthhazards at the site.

F. Other Actions to Date:

A limited number of investigations have been conducted at the ORCSite. These investigations have primarily focused on sitesampling activities at waste sources, surfaceiwater, surfacesoil, sediment, and a limited number of drinking water wells andmonitoring wells. The purposes of these investigations were todocument locations of onsite contamination and to gather back-ground data for future site evaluation.

G. MPL Status:

The ORC Site is an Update 7 site proposed for!the National Priorities List fNPL). The field activities of Phase I RemedialInvestigation began February, 1990.

•

III. THREAT TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT

A. Threat to Public Health or Welfare:

The probability of direct exposure of contaminants in the surfacesoils, pit wastes, and lagoon bottoms and standing water issignificant throughout the Site. The contaminates that pose aprominent health threat include several metals, poiynucleararomatics, and corrosive liquids. Also, there are ResourceConservation & Recovery Act (RCRA) listed hazardous wastes fromspecific sources of the petroleum refining industry: slop oilemulsion solids (KO49 wastes), heat exchangerJbundle cleaningsludge (K.O50 wastes), API separator sludge (KO51 wastes), andleaded tank bottoms (KO52 wastes). The flammable or reactivewastes (RCRA characteristic wastes) found in many of theimpoundments and drums also pose fire or explosion risks. Some

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C*T T ^ S r ujn ri a v e Deer- -L?^cTijrad b o u"" "' e t h e s. Onsets21rcorne carfcuiares SUCH as ascestos or phenoi ic odors may alsosycesG s are levels for different members of the public, SeeAttachment 3 for a summary of the health effects of the principlecontaini nants.

The acid and caustic burial pits pose a threat of groundwater andsurface water contamination. Highly corrosive leachate withelevated concentrations of metals and phenols discharges from thepits into Gladys Creek and the unnamed intermittent tributary.The corrosive leachate has a detrimental effect on aquatic lifein the creeks and may migrate to the Rush Springs Sandstoneaquifsr. Additionally, the wells located in the pits canpotentially serve as conduits for cc-ntaminat ion to migratefurther into the aquifsr and beyond the natural barrier of thecreek beds. The wells serve as a conduit because they wereimproperly constructed with casing slots every foot and theyextend to a depth below the creek beds. Some of the these wellsalso .have been artesian and thus have provided another route ofmigration of the contaminants to the ground surface.

In addition to the burial pits, surface runoff from other areasof the site transports contamination into the two nearby creeks.Gladys Creek flows into Chetonia Creek approximately one miledownstream and into the Little Washita River 1,75 miles south ofthe facility. The Little Washita River is designated as a publicuse stream with potential uses as public and private watersupplies and recreational Uses. !

B. Threats to the Environment:

The oily and corrosive, pits pose a serious threat to migratorybirds that have been reported to land and rest on the site's manylagoons. Domestic animals may become entrapped in the pits.There has been at least one instance when a dog became entrappedin a pit and site investigators were present to rescue him. Therehave also been several reports that cattle from nearby pastureshave wandered onto the Site,

The ORC facility has had an impact on aquatic life in GladysCreek, Preliminary studies of free-swimming and benthic countsin the Bite's leachate and discharge areas have shown asignificant decrease in populations from an upstream location.The Little Washita River, two miles downstream of the Sitereportedly "showed impact" from Gladys Creek's contamination,

IV. ENFORCEMENT

See Attachment 4.

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;',-• r T r.ry.^ JMI"I

P T O P O £ 6d A C t 1 O ri E !

The proposed actions involve the installation of fence,some of the pits, disposal of drumrrrea waste off sits at a licenseddisposal facilitv, and Diuggmg/caooifig of the we!'is located inthe waste Duna'l areas. Sines the Site's processing facilitiesare currently active, the proposed actions will be dividecf intotwo sections; an active area and an i rs active | area. The proposedremoval action is consistent with the lonq-term remeoial action.

The Active Area consists of the no rt-hern portion of the OP.O Sitsanfl -i a ji viosd ov tns r.ji ! roao ! Att achmetit 5 ! . It corta ins therefinerv Drocess area and the majority of the tanks. This areaw = 5 ree-peneo after m e Site's closure ano is currently b e m oprepared to become operable. WPI i le (rujch of the .northern ancws£te.rn perimeter is fenced with chain-'! ink. there are severalareas that are unrestricted to public access. Approximately G5€>feet of chain-1ink fence is needed and the existing fencereplaced or repaired- Ho^ wire fence is proposed to be ~nsralledalong c-oth sides of the railroad tracks which1 will total about4240 feet. The southern section of this hcg-jwi re fence will beconnected to the Inactive Area's fence on thej west and willrequire apDrov.i mat© ! y 1S00 feet of barbed wiê fence -nsta! ! s c! toconnect witn the Inactive Area's fence on the east. Thedifferent fabrics of fence proposed to be installed wi i '!•aH&arjqta i •/ r"°striot **> t.e access whi le rsrnainimo cost effective.Along the perimeter of this fence, warring sijgns wil I c-e posted= nci eight gates wi 1 } be installed at the locations established incoordination with OSDH. Sixty-three miscellaneous containers ofwastes ir. the Active Area wi 11 be over packed !and disposed ofcrooer•y.

b- Inactive Area

The Inactive Area is the southern ooftion of itne s H e and itcontains the land treatment area, tne storage pits, and thewaste burial areas (Attachment 61. Approximately 1480 fest ofchain-link fence is needed in the southwestern corner of thisArea which is ad.iacent to the rodeo grounds and a few houses.The restriction of site access from the east and southeast will

ire fence. WarningTen decaying

be achieved DV installing 3360 feet of barb wsigns will be posted and one gate constructeddrums of waste scattered throughout the Inactive Area will becveroacked ano disposed of proper Iv off site at a license-ddisposal facility. Netting material will be p' aced over the API'separator oits arid othsr cits containing wastes that exhibit anoi!v or corrosive characteristic. There ns one pit that

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currently has a very nâvy sheen Q? .iscritna m a t :-n ] 1 be s k i jnfns •and p rope r 1 y d 1 so~ssd of of f E i ts at s. 1 "i censed d i sposa 1 f ac it ;ty.This action will benefit migratory fowi and other birds which sreendangered by t:ne open pits. Twenty-five recovery wells locatedaround the acid disposal pit will be plugged and capped toprevent the advancement of contamination to greater depths andpossibly beyond the natural boundary created by Gladys Creek.

The estimated total project cost is $461,000. The cost is basedon the total 11,430 feet of fence, disposal of seventy-threedrums of hazardous waste, netting of the pits, and the pluggingof wells. It is expected that this project will require 30working days to complete. This removal is consistent with thelong-term remedial action.

B. Cost Summary:

EXTRAMURAL COSTS

EfiCS Cleanup Contractor 3 290,000TAT Costs $ 66 t 000CLP Costs $ 0ERT Contract f REAC ) $ 0IAG'S $ Q

Subtotal Extramural Direct Costs....$ 356,000

15% Contingency of Above Costs i 54.000

TOTAL Extramural Costs' $ -110,000

INTRAMURAL COSTS

Intramural Direct Costs $ 21,300

Intramural Indirect Costs £ 29.700

TOTAL Intramural Costs £ 51. OOP

TOTAL REMOVAL PROJECT CEILING ESTIMATE $ 461,000VI. ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE

STANDARDS (ARARE)

The removal action will be conducted to eliminate the threat orpotential threat of a hazardous substance, pollutant orcontaminant pursuant to the Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) and the SuperfundAmendments and .Reauthorization Act (SARA) [42 U.S.C.§S9B01-9675}, gnd in a manner consistent with the NationalContingency Plan ;40 CFR Part 300} as required in {33 U.S.C.5 t 321f c)f 2 ) > and [A2 U.S.C, §9605}.

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Any hazardous substance, pollutant, or contaminant that willremain on-site must achieve any standard, requirement, criteria,or limitation under any Federal environmental law, including, butnot limited to, the Toxic Substances Control Act (TSCA) {15U.S.C. 72601 et. seq.}, the Safe Drinking Water Act (SDWA) {4£U.S.C. 300f et sog.}, the Clean Air Act (CAA) {42 U.S.C. §7401 etseq,). the Clean Water Act (CWA) {33 U.S.C. 51251 e^ seg.} ,_the__Solid Waste Disposal Act {42 U.S.C, §6901 at seq.},^The Migratory"Bird Treaty Act {16 U.S.C, §701 et seq.}, or any promuI gated """standard, requirement, criteria, or 1 imitation under a Stateenvironmental or facility siting law that is more stringent thanany federal standard, requirement, criteria, or limitationcontained in a program approved, authorized or delegated by theAdministrator and identified to the President by the State. Atthe completion, a level or standard of control for such hazardoussubstances or pollutants or contaminants which at least attainssuch legally applicable or relevant and appropriate standard,requirement, criteria or limitation shall be achieved. Actionshall require a level or standard of control which at leastattains Maximum Contaminant Levels (MCLs) established under theSDWA and water quality criteria established under section 303 or304 of the CWA, or where such goals or criteria are relevant andappropriate under the circumstances of the release or threatenedrelease. " ;

r

The ability and qualifications of all parties conducting theproposed Removal Action will be demonstrated, All partiesinvolved will be experienced to conduct the Removal Actionproperly and promptly as required by CERCLA.

Transportation of hazardous substance, pollutants, orcontaminants will be in accordance with the Hazardous MaterialsTransportation Act, (4g LF.S.C.51801 et, seq. } and the applicableDepartment of Transportation regulations, and any additionalapplicable or relevant and appropriate Local, or State, and/orFederal Regulations.

Disposal of hazardous substances, pollutants, or contaminantswill be in accordance with the Resource Conservation and RecoveryAct (RCRA) of 1976, {42 U.S.C. §6901 et seg.}, the regulationspromulgated under that act, and EPA's Off-site Disposal Policy,Section I21(d)(3) of CERCLA, 42 U.S.C. §961 (dl(3) as implementedby CSWER Directive 9834.11 (November 13, 1987), Such hazardoussubstances, pollutants, or contaminants shall only be transferredto a facility which is operating in compliance with

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section 2004 and £006 of the So'iid Waste Dispose"! Act M 2 U.S.C.fi 5 6 9 2 4 and 6925} (or, where applicable, in comp \ i ance with cheTSCA or other applicable Federal law) and all applicable Staterequi rements.

Requirements under the Occupational Safety and Health Act (OSHA)of 1970 {29 U.S.C. S651 et seg.) and under the laws of Stateswith plans approved under section 16 of the States OSHA laws, aswell as other applicable safety and health requirements will befollowed. Federal OSHA requirements included among other things,Hazardous Materials Operation {20 CFR Part- 1910, and amended by54 Fed. Reg. 9317} (March 5, 19S9), all OSHA General Industry {29CFR Part 19.10}, and Construction {29 CFR Part 1926}, standardswherever they are relevant, as well as OSHA recordkeeping andreporting regulations, and the EPA regulations set forth in 40CFR Section 300, relating to the conduct of work at SuperfundSites.

VII- EXPECTED CHANGE IN THE SITUATION SHOULD NO ACTION BETAKEN

This site poses a threat to the public health and surroundingenvironment from direct contact with the hazardous materials onthe site. Should the proposed action be disapproved, the Siteremains in its present unrestricted state until the long-termremediation is implemented and immediate actions taken to protectpublic health will not otherwise be provided in:a timely manner.

VIII, IMPORTANT POLICY ISSUES

Not apc-1 i cabl e .

IX. RECOMMENDATION

Because conditions at the site meet the NCP Section 300.4!5fb)(2) criteria for a removal", I recommend your approval of theproposed action. The estimated total project cost is $461,000 ofwhich $410,000 is for extramural cleanup contractor costs.Please i nd i cate '?pur .apprâl or disapproval by signing below.

| A L <APPROVED: \j , / }/)&U>L&' DATE:

DISAPPROVED: ,. DATE:

Attachments

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Of/ :U . ,£:

SCALE 1:24000a I NILE

1000 a MOO ?ooo tor

KljjQMETFC

OKLAHOMA REFINING COMPANYCYRIL,CADDO COUNTYÔKLAHOMA

QUADRANGLE LOCATION

Attachment I000010

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tN

Attachment 2: Oklahoma Refining Company

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HEALTH EFFECTS OF SIGNIFICANT COMPOUNDS

HazardousSubstance

TargetCretans Potential Health Effects

Asbestos Lungs Both short and long term exposureincrease the risk of lung cancerand other chronic lung disease.

Arsenic Central nervoussystem(CNS)Gastroenteritis

Produces severe gastritis leadingto loss of fluids and electro-lytes. Results may includecollapse and death.

Beryllium LungsSkin

Exposure to beryllium dust maycause assorted pulmonaryproblems. Skin contact canresult in varying degrees ofdermatitis *

BenzeneEthyl-benzeneTolueneXylene

Bone marrowBloodEyesCNSLiverKidney

All cause CNS depression, Ethyl-decressed alertness, and loss ofconsciuosness. Xylene vapor maycause irratation of eyes, noseand throat. High Xyleneconcentration may cause damage toliver and kidney. Ethylbenzeneis a lacrimator; severelyirratating to the eyes and mucousmembrane.

Chromium LungsKidneys

Most common hazardous effect isfrom inhalation of dust.Exposure to dust from Chromium VImay cause some forms of cancer.

Lead BloodSkinCNSLiverLungsGastrointestinal

Lead is cumulative poison.Symptoms may include anemia andnausea- Longterm eaposure maylead to kidney damage. Very highlevels in blood may effect CNSand decreased mental activity.

Phenols LungsSkinGastrointestinalCNS

Skin absorption is the primaryroute of entry. Results mayinclude shock, collapse, coma anddeath. Ingestion of amounts aslittle as l gram may be lethal.

Polynuclear Lungsaromatic Skinhydro- Gastrointestinalcarbons

Highly lipophilic and easilyabsorbed through the linings ofrespiratory and gastrointestinaltracts. Several individual PAHsare probable carcinogens-

Attachment 3

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Attachment 5: Oklahoma Refining Company - Active Are£

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=^r /

A / Stora

INACTIVE AREA

LandTreatmentArea

Attachment SJ Oklahoma Refining Company - Inactive Area

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CONFIDENTIAL DOCUMENT

LOCATED IN A SEPARATE, CONFIDENTIAL FILE

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PROPOSED PLANOklahoma Refining Company

Superfund SiteCyril, OklahomaJanuary 31 , ^992 '.•

'*S?J?i*i'

EPA, OSDH ANNOUNCE PROPOSED PLANThis Proposed Plan identifies the preferred options for addressing ground-water and soil contamination at the Oklahoma'Refining Company (ORC) -Superfund site. In addition, this Plan includes summaries of other alterna-tives analyzed for this site. Under provisions of the Superfund* program,the Oklahoma State Department of Health (OSDH) is the lead agencyresponsible for addressing contamination at the ORC site- OSDH is work-ing with US, EPA to develop a permanent, long-term remedy for the sitethat will protect public health and the environment. OSDH and EPA willselect a final remedy for the ORC site after the informs tion submitted during.the public comment period has been reviewed and considered during thederision-making process-

EPA is issuing this Proposed Plan as part of its public participation respon-sibilities under the Superfund law [Section 117(a) of the ComprehensiveEnvironmental Response Compensation and Liability Act (CliRCLA) asamended in 19S6.] This document summarizes the information that can befound in greater detail in the Remedial Investigation and Feasibility Study(RI/FS) reports and other documents in the Administrative Record File forthe ORC site. You are encouraged to review these documents in order togain a more comprehensive understanding of the site and Superfundactivities that have been conducted. The Administrative Record File isa va ilable a t th e folio wing I oca tions:

Cyril City Hall202 W. MainCyril, OK 73029Monday through Friday9 a:m. - 2 p.m,(405) 464-2411

Oklahoma State Dept. of HealthSolid Waste Management Service1000 N.E. 10th St. - 8th FloorOklahoma City, Oklahoma 73117Monday through Friday3:00 a!m. - 4:30 p.m.(405)271-7157

The public is invited to comment on the remedial action alternativesdescribed in the RI/FS report, the Proposed Plan of Action, and the Adminis-trative Record File. The public comment period begins February 10,1992 andendsMa rch 11H 992. Du ring the public comment p er iod/writ ten commentsmay be submitted to:

Mr. Dorm WaltersCommunity Relations Coordinator

U.S. EPA, Region 6 (6H-MC)1445 Ross Avenue

Dallas,, Texas 75202-2733

THE PURPOSE OFTHIS PROPOSEDPLAN IS TO:

O Identify the preferred al-ternative to remedy sitecontamination and ex-plain the reason for thepreference;

O Describe the other re-medial options consid-ered in detail in theFeasibility Study report;

O Solicit public reviewandcomment on all the al-ternatives described inthe Feasibility Study re-port and informationcontained in the Admin-istrative Record File;

O Provide information,on how the public canbe involved in the rem-edy selection process;and

O Provide history andbackground about thesite.

• * Words in bold itatkn are defined in dieGlossary on page 19,

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REGULATORY HISTORYhouse-is scheduieWBr February 6,1992at theSenior Citizen Building, 201W. Ohio, Cyril, Oklahoma,.Corne by between 5 p.m, and 7:30 p.m. to informallydiscuss the Proposed Plan of Action and other alterna-tives wi t h OSDH and EPA officials.

Additionally, oral comments will be accepted at a pub-lic, meeting on February 20,1992 at 7 p,m. at the SeniorCitizen Building, Cyril, Oklahoma. OSDH and EPAwill respond to all comments in a document called a..Responsiveness Summary, The Responsiveness Sumrmaiy will be sent to all those who comment in writingor.: at the public meeting and will be attached to theRecord of Decision. It also will be made.available to the -public in the information repositories. The Recoiti oi:

Decision explains the final remedy selected to correctcontamination problems and to protect the public'shealth at a Super fund site- The final remedy could be.d i f ferent fr om.the preferred altema tive, depending u ponnew information EPA may consider as a result of publiccomments.

SITE BACKGROUND

The ORC Superfund site is located on the eastern edgeof Cyril, Oklahoma, approximately 75 miles southwestof Oklahoma City. The ORC Superfund site coversapproximately 160 acres and is bordered by the City of *Cyril to the west, U.S;Highway 277 to the north, GladysCreek to the east and an unnamed tributary of GladysCreek, private lands and City property to the south.

Crude oil refining at the ORC Superfund site dates backto 1920. In 1978, the refinery was purchased by theOklahoma Refining Company (ORC) which continuedrefinery operations until 1984, when ORC declaredban krup tcyandshut.downpperations.

In 19S6, the bankruptcy court allowed ORC to abandonI he southern and eastern portions of the property. Theabandoned portion of the property is primarily whererefinery wastes were disposed in numerous, pits andponds. In 1987, the Cyril Petrochemical Corporationpurchased the portion of the site that was not aban-doned, which included the refinery process area, withthe intention of reactivating the refinery: In August1991, Caymen Resources Corporation purchased theCyril Petrochemical Refinery with the intention of re-opening the refinery to refine crude oil into variousproducts.

Prior to the 1970's, there were few environmental regu-lations to prevent pollution. The state ControlledIndustrial Waste Act and the federal Resource Conser-vation and Recovery Act (RCRA) passed in 1976, broughthazardous wastes under the regulatory authority ofOSDH and the EPA, respectively- In 1974, the EPAissued a National Pollutant Discharge Elimination Sys-tem permit to allow for the discharge of wastewaterfrom the ORC facility. In 1979, ORC began the processof applying for a controlled industrial waste disposalsite operating permit with OSDH. In 1983, the Okla-homa Water Resources Board (OWRE) issued a letterrequiring ORC to correct various discharge violations.In 1984, the OSDH issued an o rder to ORC for correcti veaction of RCRA violations which included inadequateclosure plans, fa i lu re to sample soil in t he land tr ea tmentarea, and failure to adequately sample ground water inthe land treatment area. In 1984, ORC conducted aninvestigation of contamination problems on the site.Shortly after this investigation was completed, ORCwent bankrupt and abandoned the site-

In 1986, the EPA investigated the ORC s ite for possibleinclusion in the Superfund program. Their investiga-tion confirmed previous findings thai showedhydrocarbons arid elevated levels of heavy metals in theground water and soils at the site. Based on this inves-tigation and data obtained from the 1984 ORCinvestigation, the ORC site was placed on the SuperfundNa thn a t Prio rities Lis t (NPL) in June 19 88,

REMEDIAL INVESTIGATION

In November 1988, the OSDH was awarded fundingthrough a cooperative agreement with the EPA to begina Remedial Investigation .(RI) at the ORC site. Thepurpose of an Ri is to characterize the nature and extentof contamination and to evaluate the extent of risk{s)posed by contamination. The OSDH contracted withBechtel Environmental, Inc, of Houston, Texas to per-form the RI. The RI field work was conducted in threephases between October 1989 and April 1991.

The results from the RI field work showed numerouscontaminants in many of the surface impoundmentsediments, surface soils, and subsurface soils. The con-taminants were primarily petroleum-related organicchemicals and heavy metals. Benzene, ethylbenzene,phenol, methyl-phenol, toluene, naphthalene, and 2-metbyl naphthalene were commonly found organiccontaminants. Lead, chromium, and arsenic were com-monly found heavy metals.

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1 The ground water in the i^permost aquifer, the Rush sediments in Glaays Creek and its tributaries con tainedSprings Sandstone Aquifer, was found to contain con-taminants similar to those found in surface impoundmentsediments. A large area, which encompasses part of therefinery and the abandoned portion of the site, wasfound tohavH livht nnn-aqtif>niif: t>ha'jf, liquid /T.7SL4JPO

i The LNAPL is composed

very low levels of petroleum-related organic chemicalsand heavy metals.

A study conducted during the RI field work whichfocused on benthicmacroLn vertebrates (crayfish, blood-worms, etc.) in Gladys Creek indicated a decrease in

mostly of gasoline and is contributing to the groundwa- macroin vertebrate species diversity and population inter and surface water contamination. areas immediately below the acid and caustic leacbate

; : areas. iTie study concluded that a negative impact toThe Rush Springs Sandstone. Aquifer is an important • rnacroinvertebrates in Gladys Creek has occurred in.drinking water source for the Cyril area, t he extent of these areas. A fish population study in ponds on Gladyscontamination in the aquifer is limited to the area under Creek indicated a diverse and physically healthy popu-the ORC site and extends north to the northern tributary lation and did not find evidence of negative impact toof Gladys Creek. There is no one currently using the fish from the ORC site.contaminated ground water as a drinking water source.

The Rush Springs Sandstone Aquifer is approximately250 feet thick. The ground water was found to be con-taminated with acidic and caustic wastes from severalwaste so urce pits in two separa te areas, G round water inthese areas was found to have either a very low pH(acidic) or a very high pH (caustic). This ground waterhas v is i bl e see ps alo ng the bank of G lad y s Cr eek a nd haskilled all plant life in these areas.

Ajrsamplingforvolatileorganic compounds and heavymetals was conducted near waste sources and on theperimeteroftheORCsitetode termine concentrationsofairborne contaminants that may be leaving the site. Airsamples showed extremely lowlevelsofvolatile organ iccompounds.

SUMMARY OF SITE RISKS

Based on the information gathered during the RI fieldwork, a baseline risk assessment was performed todefine and estimate the actual and potential risks tohuman health and the environment from the contami-nants at the ORC site if remediation did not take place.The risk associated with both carcinogenic andnon-carcinogenic effects was assessed.

Ground water contamination was found only in theuppermost 30 feet of the aquifer, and primarily in theuppermost 10 feet. RI field work results showed thatground wafer and contaminant movement in the RushSprings Sandstone Aquifer beneath the ORC site movesto the south and southeast toward Gladys Creek and itstributaries. Ground water flow is moving perpendicularto t he creeks a t an estima ted ra te o f 11 fee t per year. The Carcino genie risks are estimated as the probability o f a ncontaminated ground water was found to be moving individual developing cancer during his or her lifetimeupward as well as horizontally and is being discharged as a result of exposure to a potential carcinogen. Forinto Gladys Creek and its tributaries. Groundwater example, a "1 in I million" excess lifetime cancer riskcontamination cannot migrate beyond the creeks be- means that for every one million people exposed to thecause the contaminated groundwater flow is opposed carcinogen(s) throughout their lifetimes, the averageby uncontaminated ground water fl ow o ri the other side incid ence of cancer is increased by one extra ca ncer case.of the creeks, which is also moving toward the creeks atapproximately the same rate. This opposition in flowdirection does not allow contaminants to migrate pastthe creeks since contaminants would have to migrate

The baseline risk assessment considered an acceptablecarcinogenic risk to be any risk less than "5 in 1 million"excess cancer incidences. The National Oil and Haz-ardous Substances Pollution Contingency Plan (NCP)

upgradient against the groundwater flow. Thus, the states that for known or suspected carcinogens, accept-creeks form hydrological barriers that prevent the kit- able exposure levels represent an excess lifetime cancereral migration of groundwater contaminants in thesubsurface.

Surface waters in on-site ponds are contaminated withsimilar contaminants as those in the groundwater. Thesurface water in Gladys Creek and its tributariescontained very low concentrations of phenols. The

risk to an individual of bet ween 'Tin 10 thousand" and"1 in 1 million." The acceptable risk range establishedby the NCP will be used for the Proposed Plan andRecord of Decision.

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i ";-Theleveidfconbernrf6rnbfiJis determined by calculating .a hazard index. If thehazard index exceeds one (1), there may be concern forpotential non-cancer effects.

Four exposure scenarios were developed during thebaseline risk assessment.

The first exposure scenario, the current off-site resi-dent, was developed to depict a person currently living.off-site who does not enter the ORC site property butdoes contact surface, water and sediments in GladysCreek and breathes the ambient air. The carcinogenicrisk was found to be "3 in 1 million,' which is within theacceptable range established by the NCP for carcino-gens. The non-carcinogenic hazard index was "008''which is below the level of concern-

The second exposure scenario, the potential on-siteintruder, was developed to depict an intruder whowould come into contact with contaminated ground wa-ter, surface water and sediments in both the on-siteponds and Gladys Creek, surface soils on-site and am-bient air. The carcinogenic risk was found to be "3 in 100thousand" which is within the acceptable range estab-lished by th e NCP ior carcinogens. The non-carcinogenichazard index was "0.9" which is below the level ofconcern. .

The third exposure scenario, the potential on-site worker(acute exposure) was evaluated for exposures to allmedia over a period of two weeks. The potential on-siteworker (chronic exposure) was evaluated for exposureto surface soil and air over a period oi 30 years. Thecarcinogenic risk for the'acute exposure scenario wasfound to be "8 in 10 million" and for the chronic expo-sure scenario was found to be "3 in 1 million" both ofwhich are within the acceptable range established by theNCP for carcinogens- The noncarcinogenic hazard in-dex for acute exposure was "0.3" which is below thelevel of co ncern. The non-carcin ogenic hazard ind ex forchronic exposure was "1,2", which is only slightly abovethe level of concern for potential non-carcinogenic ef-fects, . •. •'

The fourth exposure scenario, the potential on-siteresident, was developed to depict a person who couldmove onto the ORC site, set up a residence and usecontaminated ground water as a primary source of drink-ing water. This exposure scenario is considered as thereasonable maximum exposure for the developmentand selection of appropriate alternatives for site

1. thaf the future poten tialon-site resident would come into contact with all me-dia. The carcinogenic risk was found to be "2-in 1thousand" which is not within the acceptable rangeestablished by the NCP for carcinogens. The non-carci-nogenic hazard index was "87" which warrants concernabout potential non-cancer effects-

FEASIBILITY STUDY

The OSDH contracted with Bechtel Environmental,Inc., to perform a Feasibility Study (FS) for the ORC site.The FS used information gained during the RI to de-velop several alternatives for remediation. As part ofthe FS, remediation goals for chemical concentrations ofcontaminants were developed. These remediation goals,which are called Remedial Action Objectives (RAOs),were used to determine the areas of the site whichrequire remediation (see Figure 1)-

A RAO is a chemical-specific concentration that corre-sponds to a regulatory level, where applicable, or to a "1in 1 million" excess lifetime cancer risk. RAOs weredeveloped for sediments, surface soils, subsu rface soi Is,surface water, and ground water assuming that the sitecould be used as a residential setting and people couldaccidentally or intentionally ingest contaminants fthepotential on-site resident scenario). Ground water pro-tec tion RAOs were also developed for soils andsediments to address the potential for these media toact as a continuing source of ground water contamina-tion through kaching, RAOs were developed for 35chemicals of concern found at the ORC site. The RAOsdevelopedforsomeofthemost prevalent contaminantsat the ORC site are as follows:

SEDIMENT AND SU RFACE SOIL RAOS

Benzene:22 ppm for human health ingestion protection;0.2 ppm for ground water protection due to leaching

3-Methyf naphthalene:i;0S0 ppm for human health ingestion protection,510 ppm for ground water protection due to leaclung

LeadGOO ppm for human h ea lth ingesti on protec ti on;865 ppm for ground water protection due to leaching

Chromium1,350 ppm for human health ingestion protection;770 ppm for ground water protection due to leaching

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I

Benzene0.005 ppm for human health ingestion protection

2-Methyl naphthalene0.15 ppm for human health mgestion protection

Lead

RAOs. -

All of the alternatives, with the exception of AlternativeII, have included a no action response action for Group7 (Pump Pits 1 and 7} since no RAOs were exceeded.

The following alternatives were evaluated to addresscontaminated sediments, surface soils and surface wa-

0-015 ppm for human health ingestion protection ten

Chromrum .0.10 ppm for human health ingestion protection

A complete listing of the chemicals of concern and theirassociated RAOs can be found in Tables 3-3 through 3-6 of the ORC Feasibility Study report-Once the RAOs were developed, the FS then used ascreening process to develop several alternatives fromnumerou s technologies th a t c ould po ten tia Uy remedia tethe ORC site, :

SUMMARY OF ALTERNATIVES

The descriptions and evaluations of remedial actionalternatives are separated into six alternatives address-ing contaminated sediments, surface soils, and surfacewater and six alternatives addressing contaminatedgroundwater. • • • '

Sediment and Surface Soil RemedialAction Alternatives

Remedial action alternatives for sediments and surfacesoils were developed by organizing the wastes intogroups with similar characteristics. See Table 1 for thesediment and surface soil remedial action alternativesand the associated group numbers associated with eachalternative.

Common Elements: All of the alternatives, with theexception of Alternative I, have the following commondement;: site preparation, the installation of office,storage, and security facilities; the installation of surfacewater runoff control measures; installation and mainte-nance of warning signs and fencing; placement of anotice to the property deed warning of site hazards; andthe restora uo n of the site surf ace u pon comp le tion o f theremedial action.

All of the alternatives, with the exception of AlternativeT, involve containing or treating soils and sediments

Alternative I (No Action)

Capital Cost: Not Applicable .Operation and Maintenance Cost: $5,000 every

five yearsPresent Worth: SI 5,000Implementation Time: Not Applicable

Alternative I is a "no action" alternative for contami-nated sediments, surface soils and surface water andconsists of reviewing the status of the ORC site everyfive years. As required by CERCLA, a no action alterna-tive was included as a basis for evaluating otheralternatives.

Alternative El {Limited Action) '.. •

Capital Cost: $1,553,000Annual Operation and Maintenance Cost: $24,000Present Worth: $1,918,000Implementation Time: 6 months

Alternative li consists of taking limited action towardcontrolling access to the sediments, surface soils andsurface waters at the ORC site through the use of deednotices; warning signs; diversion, collection and treat-ment of on-sile surface water; and covering allcontaminated sediment and surface soil areas with soiland vegetation.

Alternative IK (Containment, Neutralization andBiotr eat merit)

Capital Cost: $9,369,000Annual Operation and Maintenance Cost: $114,000Present Worth: $10,973,000 ' • •Implementation Time: 24 months -

Alternative 111 consists of containing 86,020 cubic yardsof sediments and surface soils in-place by the use of towpermeability caps (groups 2,3,4,6,10,11,11, l4~and 15).Another 33,861 cubic yards of contaminated sediments

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' J

I ,

: and surface jMils'that ebriexpected to leach into ground water would, be. con-tained in place by placing soil and vegetation over them(groups 5,9,13,16 and 18). A total of 51,184 cubic yard sof low pH sediments would be treated by neutraliza-tion (group 8). Through biotreatment, approximately90- 95% of the organic contaminants in a total of 17,894cubic yards of contaminated sediments and surfacesoils would be treated and permanently destroy ed andthe .residuals would be stabilized and capped (groupsl a n d 1 7 5 : / • . - • . • • . = . • ; ..; _ : , . : . . > . . -

Alternative iV (In-situ Stabilization, Neutralizationand B iotreatme nt) . •;' • •'. •'. -

Capital Cost: $19,952,000Annual Opera tion and Maintenance Cost: $120,000Present Worth: $21,545,000Implemen la tion Time: 24 months

Alternative IV consists of treating,sediments and sur-face soils using various m eth ods, A total of 33,8 6 T cub icyards of waste that are not expected to leach contami-nants into ground water would be covered with soiland vegetation (groups 5, 9,13,16 and 18). A total of8,852 cubic yards of waste \vou\d.be stabilized in-situand capped (groups 3, 6 and 15), Prepared bedbiotreatment or in-situ biotreatment would perma-nently destroy approximately 90-95% of the organics ina total of 95,062 cubic yards of contaminated sedimentsand surface soils (groups 1, 2,4,10,11,12,14 and 17).The biotreated residuals that contain inorganics aboveRAOs would be stabilized and then capped. A total of51,184 cubic yards of contaminated sediments wouldbe neutralized (group 8).

I n-sftu Stab i J i zati o n, R ecyc 11 ng,Neutralization and BFotreatment)

Capital Cost: $22,302,000Anni^l Operation a nd Maintenance C os t: $132,000Present Worth: $24,044,000Implementation Time; 24 months

Alternative V consists of treating sediments and sur-face soils u sing va rious methcds- A total of 11,085 cubicyards of waste that do not exceed RAOs and do notrequire treatment would be covered with soil andvegetation (group 5). A total of 8,852 cubic yards ofwaste would be stabilised in-situ and capped (groups3, fi and 15). A total of 10,208 cubic yards of asphaltwould be recycled (group 9) and 51,184 cubic yards oflow pH sediments would be neutralized (group 8).

g n l i n n in m i n i ' I I I frrtfiiiricijî ( g H p a ^ t ^ f 2 , 4 , 1 0 , 1 1 , 1 2 , 1 3 ,

14,16,17 and 18), The biotreated residuals that containinorganics above RAOs would be stabilized and thencapped- j

Alternative VI {In-situ Stabilization, Recycling,Ne utral Izatl o n an d LTTDTreatmem)

Capital Cost £51,840,000 -Annual Operation and Maintenance Cost: $103,000Present Worth: $52,645,000

. Implement?tion Time: 20 months .

Alternative.VI.consists of treating sediments and sur-face soils using various methods. A total of 11,085 cubicyards of waste that do not exceed RAOs and do notrequire treatment would be covered with soil and veg-etation (group 5), A total of 8,852 cubic yards of wastewould be stabilized in-situ and capped (groups 3,6 and15). A total of 10,206 cubic yards of asphalt would berecycled (group '9) and 51,184 cubic yards of low pHsediments would be neutralized (group 8). The organ-ics in a total of 107,630 cubic yards of contaminatedsediments and surface soils would be removed throughthe use of low temperature thermal desorption (groups1, 2, 4,10, 11,12,13,14,16,17 and 18), The residualswould be stabilized and then placed in an on-site land-fill. The collected organic contaminants could be recycledon-site or off-site.

EVALUATION OF SEDIMENT AND SOILREMEDIAL ACTION ALTERNATIVES ANDTHE PREFERRED ALTERNATIVE

The preferred alternative for ad dressing the contamina-tion of sediments and surface soils at theORC Superfundsite is Alternative V (In-situ Stabilization, Recycling,Neutra lization and Bi otrea trnen t). Based on new infor-mation or public comments, the EPA and OSDH maymodi fy the preferred alternativeorselect another remedialaction presented in this Proposed Plan and the FS report.Therefore, the ptiblic is encouraged to review and corn-men t on all of the alternatives id en tified in this Prop osedPlan. j

The following nine criteria were used to evaluate theremedial action alternatives for the ORC Superfundsite. (See "Selecting a Remedy" on the insert for anexplanation of the nine cri teria.)

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1, Overall Protection of flfTman Health and theEnvironment

Except for Alternative I all of the alternatives provideo veraII protection of human health. Except fo r A lte rna-tives 1 and H all of.the alternatives provide overallprotection of the environment. The degree to whicheach of the alternatives protect human health and theenvironment is discussed below.

Alternative I provides no increase in the overall protec-tion of human health and the environment. Under the.no action alternative, all of the current and future poten-tial risks to hunwi health and the en virorment with the OTCC site would remain the same.

Alternative H should protect human health by prevent-ing direct contact with contaminated sediments andsurface soils because they will be covered with soil andvegetation. Alternative H will not provide overall pro-tection for the environment because soil and vegetationwill not stop the infiltration of surface water throughwastes and Ihe migration of leachate to ground water.

Alternative III would provide more protection of theground water than Alternative II since a low permeabil-ity cap would be used to contain waste sources andthose materials that are in direct con tact with the ground-water would be excavated and treated. Alternative IIIwould reduce both the potential for direct human con-tact with wastes and the potentia 1 for future ground watercontamination.

Additional protection of huinan hea! th and the environ-ment is provided by Alternatives IV through VI whichprovide for stabilizing the wastes that contain highlevels of inorganics before covering them with a lowpermeability cap. Alternatives IV and V would de-stroy organics through biological treatment andAlternative VI would remove organics through low-temperature thermal desorption.

Alternative III is not as protective as Alternatives IVthrough VI because only 36% of the total wastes will betreated as opposed to 82%, 89% and 89% of the totalwastes in Alternatives IV, V and VI, respectively.Therefore, Alternatives IV through VI are more protec-tive of ground water than Alternative ffl and are moreprotective of human health than Alternative 1IL

RAOs would "be treated in Alternative V whileAlternative IV would provide soil and vegetative coverfor a few wastes that are not expected to leach but couJdpose a potential risk to humans who might come intodirect contact with the wastes. As long as soil andvegetative covers placed over contaminated areas inAlternative IV are maintained, Alternatives IV throughVI are comparable in terms of overall protection ofhuman health and the environment.

2. Compliance with Applicable or Relevant andAp pro p r I ate Req u f rem e nts {A R A Rs >

ARARs are the federal and state requirements that aselected remedy must meet All of the alternatives havea common ARAR, which includes Subparts F and G ofthe Standards for Owners and Operators of HazardousWaste Treatment, Storage, and Disposal Facilities (40CFR Part 264). Subpart F requires that any hazardouswaste releases be investigated and corrective actiontaken if necessary. Subpart G requires the proper clo-sure of hazandous waste units. ^

The RCRA Land Disposal Restrictions (LDRs) are ap-plicable to Alternatives m through VI, LDRs are set byfederal regulation and require that hazardous wastes betreated to a certain level prior to land disposal, LDRswill be used as RAOs at the ORC site when certainRCRA hazardous wastes are actively managed.

Alternatives I and II do not meet all ARARs. Alterna-tives III through VI will meet all ARARs.

3. Long-term Effectiveness and Permanence

Alternatives I and II would not provide a long-termeffective or permanent solution or provide any controlsfor the protection of human health and the environmentsince no treatment of contaminated media will occur.

Alternatives Hi and IV involve the covering and con-tainment of treated and untreated wastes. The risk tohuman health and the environment from the untreatedcapped and covered wastes would be low and the riskfrom the treated residuals would be negligible. Withproper maintenance, the low permeability cappingof untreated wastes in Alternative TTT should provideadequate and reliable control for the protection of hu-man heal th and th e environmen t.

Alternative V may be slightly more protective lhan Altema lives V and VI pro vide the most long-term effec-A lterna tive IV i n th e 1 ong-term, A U wastes t ha t exceed tiveandpermanentremedies, sinceeachofthemtreat

a 11 of the contaminated sed im ents and surface soils tha t

7 000022

002447

^ ^ ^ ^ ^ * ^ ^ ^ ^ ^ ^ ^ ^ ^

are above RAOs. The risk ternlimarirhea 1th and. theenvironment from the covered wastes and the treatedresiduals would be negligible- These alternatives pro^vide an effective and permanent remedy for thecontaminated sediments and surface soils.

A. Reduction of Toxicity, Mobility, or Volume of theContaminants Through Treatment

Alternative I offers no reduction in the toxicity, mobil-ity or volume of the contaminated sediments, surfacesoils or on-site surface water. ;

Alternatives IT through VI would eliminate the mobil-ity, toxicity and volume of surface water since on-sitesurface water would be removed and treated.

Alternative IT would not reduce the toxicity, mobilityor volume of contaminants in sediments or surface soilsthrough treatment-

Alternatives IE through VI would reduce the toxicityand mobility of the contaminated sediments and sur-face soils through the use of treatment. Alternative IIIwould treat 36% of the total wastes, Alternative IVwould treat 82% of the total wastes, and Alternatives Vand VI would treat 89% of the total wastes. The volumeof contaminants would be reduced since some organicswould be destroyed during biotreatment or removedthrough low temperature thermal'desorption. Thetoxicity and volume of contaminants that are containedwould not be reduced through treatment but the mobil-ity would be reduced through containment-

5. Sho rt-te r m Effect)ven ess

Alternative I would pose no short-term risk toworkers or the surrounding community

Alternative II would not involve significant generationof dust or vapor releases and would pose no significantshort-term risks to on-site workers or the surroundingcommunity.

Alternatives III through VI involve excavation, mate-rial handling, and treatment which could pose a slightrisk to on-site workers or the surrounding community.These activities have the potential to generate dust andvapors, and for the thermal treatment process, air emis-sions. Risks to the community would be minimized byproviding strict controls for these activities such as airmonitoring, dust suppression and air pollution controldevices. A contingency plan would be developed to

itetaddress any potential for emergencies" duringremediation activities. Risks to workers onsite wouldbe minimized by adherence to Occupational 5a fety andHealth Administration requirements which will beoutlined in a worker health and safety plan.

6. liriplamentabllityi

Alternative I through V could be readily implemented.Alternative Vl'coiikj be implemented but would re-quire more extensive materials handling and specializedequipment, ..

7". Cost ;

The present worth cost of the preferred alternative is$24,044,000. Alternatives 1, II, III and IV have a lowerpresent worth of $1^,000; $1,918,000; $10,978,000; and$21,545,000, respectively. Alternative VI has a higherpresent worth of $52,645,000.

8. State Acceptancei . '

OSDH is in agreement with the selection of AlternativeV as the preferred remedy for the contaminated sedi-ments and surface soils at the ORC Super fund site.However, the final determination of State acceptance ofthis alternative will not be made until public commentshave been received and evalu a ted.

9. Community Acceptancei

Community comment will bean important factor in thefinal evaluation of the remedial alternatives.

GROUNDWATEI^ REMEDIAL ACTIONALTERNATIVES!

1 i• • i

Six comprehensive remedial action alternatives weredeveloped to address contaminated ground water as-suming surface soil and sediment contamination sou rceswould be remediated. After remediation, contami-nants in these soils and sediments would be reduced tolevels which would not be expected to leach and wouldnot cause further contamination of the ground water.See Table 2 for the remedial action alternatives forground water,

•

The shallow ground water beneath the ORC Site has ahydrocarbon layer floatinglayer, which is called ajH

is primarifythe result of petroleum hydro-carbons which leaked or spilled from refinery process

002448

and storagewith

rtt astesourco contanunatod-areao which.lLUJiQuayyubbUiwcs. Leachatefrom

these hazardous waste sources has mixed with theLNAPL in these areas.

Under current CERCL A.authority, groundwater con-taminated by only petroleum hydrocarbon productcannot be addressed due to thdGroundwater contaminated with petroleum hydrocar-bon product that is commingled with a CERCLA.hazardous substance, pollutant, or contaminant can beaddressed. . . •

Although groundwater contaminant types are similaracross the site, no evidence was gathered during the RIto indicate that the LNAPL plume located beneath therefinery portion of the QRC site is commingled with

< hazardousi5|iub.starices£Because of the petroleum exclu^sion under CERCLA; the plume beneath the refinery]portion of the site cannot be addressed as part of the]Superfund remedial action.

Because the groundwater beneath the refinery processarea is primarily contaminated by petroleum hydrocar-bons while the LNAPL plume and groundwater inother portions of the site are contaminated by a mixtureof petroleum hydrocarbons and leachate from hazard-ous waste sources, two separate alternatives forcontainment and in-siru treatment and two separatealternatives for pump and treat remediation of the RushSprings Sandstone Aquifer were developed.

In both cases, one alternative is provided which wouldremediate all groundwater contamination at the ORCsite regardless of the source and a second alternative isprovided which would remediate only the portion ofgroundwater and LNAPL contaminated by hazardouswaste. The alternatives to remediate all contaminated!groundwater are prohibited under CERCLA authority,!but the alternatives which remediate only the portion of?the aquifer commingled with hazardous waste can be 5addressed by CERCLA authority.

which.are suspected to"be "conduits7orc6rrtaminant

signs-and-fancing; placement of a notice to the propertydeed warning of site hazards; and groundwater moni-toring.

All of the alternatives, with the exception of Alterna-tives I and II, involve containing or treating groundwaterwhich has contaminant concentrations tha t exceed RAOs.

pThe water treatment process for all extracted waterwould be the same for all alternatives. The treatmentprocess for heavy*metals removal would consist ofoxidation, reduction, chemical precipitation and filtering or a combination of these processes. The treatmentprocess for hydrocarbon contaminant removal wouldconsist of air stripping followed by carbon adsorption. I

The areas of groundwater and LNAPL remediation foralternatives III through VI are shown on Figures 2 and3- •

Common Elements: All of the alternatives, with theexception of Alternative I, have the following commonelements: site preparation and the installation of office,storage, and security facilities; plugging existing wells,

All of the alternatives have the following commonARARs: National Primary and Secondary DrinkingWater Regulations; health-based goals consisting ofRAOs; and an EPA recommended action level for lead.

Groundwater Alternative I (No Action)

Capital Cost: Not ApplicableOperation and Maintenance Cost: $5,000 every

five yearsPresent Worth: $15,000Implementation Time: Not Applicable

Groundwater Alternative I is the no action alternativeand consists of reviewing the status of the ORC siteevery five years. It provides a baseline against which theother alternatives can be compared. Groundwater Al-ternative I would not provide any measure of protectionfor the environment since contaminated groundwaterwould be allowed to migrate into the surface waters ofGladys Creekand its tributaries. Based on the results ofthe baseline risk assessment, this alternative would notprovide overall protection of human health fora futurepotential on-site resident. This risk would only berealized if a groundwater well is actually drilled on-siteandisused for a drinking water source. This alternativedoes not comply with all ARARs since the MaximumContaminant Levels (MCLs) for contaminants in a po-tential source of drinking water will not be met.

Groundwater Alternative II (Limited Action)

Capital Cost: $84,000Annual Operation and Maintenance Cost: $94,000Present Worth: 51,540,000Implementation Time: 1 month

000024

002449

•"i

OLDCWJEllC f

Is.

crnr• ClfiH.

LEGEND

FIGURE 1

OKLAHOMA RETIMNG C0WPAN1SUPERFlJHD SITE

LOCATION MAP OFWl-BCH EXCEED

ACTION OBJECTIVES

•"•• V t l i

•'•• '4

002450

Groundwater Alternative TTprovides ho'extractibrTbrcontainment of ground water. It consists of maintainingthe fence and warning signs around the site and perma-nently affixing a warning notice to the property deed.The existing on-site wells, which are conduits for migra-tion of contamination^would be plugged.

Groundwater Alternative. Ill (Containment, EntireLNAPL Plume Removal and In-situ BioremediationEnhancement of Rush Springs Sandstone Aquifer)

Capital Cost: $3,935,000. ' ;Annual Operation and Maintenance Cost: $315,000'Present Worth: $8,786,000 '. ' .'Implementation Time: 30 years '

Groundwater Alternative III was designed to preventcontaminated groundwater from discharging into thecreek systems and migrating pff-site by the use of aninterceptor well system located near the downgradientborders of thesite. The extracted water would be treatedon-site. Nutrients and oxygen may be added to the

, treated water, which would be injected into contami-nated portions of the Rush Springs Sandstone Aquiferto enhance in-situ bioremediation. With enhancementof the natural biodegradation processes, the organiccontamination would be broken down into harmlesscompounds. The LNAPL plume, which is a significantsource of contamination to the groundwater, would beremoved with an extraction well system.

Groundwater Alternativ^SSfcontainment, Recov-ery of LNAPL Commingled with Hazardous Wasteand In-situ Bioremediation Enhancement of theRush Springs Sandstone Aquifer)

Capital Cost: £3,155,000 . .Annual Operation and Maintenance Cost: $293,000Present Worth: $7,668,000Implementation Time: 30 years

Groundwater Alternative IV is exactly the same asGroundwater Alternative III except that the LNAPL.plume and groundwater areas to be remediated aredifferent.

.This alternativewould prevent contaminated groundwater from dis-charging into the creek systems and migrating off-siteby the use of an interceptor well system_ngar_thedowngradient borders of the site.l

f Nutrients and oxygen may be 'added to the treated water, which would be injected intohazardous waste contaminated portions of the RushSprings Sandstone Aquifer to enhance in-situbioremediation. A portion of the LNAPL plume, whichis a significant source of contamination to the ground-water, would be removed with an extraction well systemand,recycled X • '

Groundwater Alternative V (Active Restoration ofthe Rush Springs Sandstone Aquifer) . ..

/CapitalCost: $11447;000 _'*. *"'<'' •. •"•'. "•. '•;v Annual Operation and Maintenance Cost: $727,000-.; Present Worth: $22,339,000

Implementation Time: 10.years " •

Groundwater Alternative V consists of active restora-tion of the Rush Springs Sandstone Aquifercontaminated by the ORC site using.pump and treatremediation technology. An extraction well.systemwould extract LNAPL and contaminated groundwaterfrom across the site. This water would be treated in anon-site treatment system, and recovered hydrocarbonswould be recycled. Treated water would be injectedinto the aquifer. . ,

Groundwater Alternative VI (Active Restoration ofthe Rush Springs Sandstone Aquifer Commingledwith Hazardous Waste) V •

Capital Cost: $6,986,000Annual Operation and Maintenance Cost: $493,000Present Worth: $14,576,000Implementation Time: 10 years • •'

Groundwater.Alternative VI is exactly the same asGroundwater Alternative V except that the area of con-taminated groundwater to be remediated is differentsince Ground water Alternative VI would only remediatethe portion of groundwater contaminated with hazard-ous waste that can be remediated under CERCLAauthority. Groundwater Alternative VI consists of ac-tive restoration of the Rush Springs Sandstone Aquifercontaminated by the ORC site using pump and treattechnology. An extraction well system would extractLNAPL and contaminated groundwater from acrossthe site. This water would be treated in an on-sitetreatment system and recovered hydrocarbons wouldbe recycled. Treated water would be injected into theaquifer.

12.

002451

^ v ' "' '':i''i"•""" ^ ^ ^ ' '

EVALUATION OF ! GWU NdWATER'REMEDIAL ACTION ALTERNATIVES ANDTHE PREFERRED ALTERNATIVE

The preferred alternative for addressing the contamina-tion 0/ groundwater at the ORC Superfund site isAlternative IV. Based on: new information or publiccomments, the EPA and OSDH may later modify thepreferred alternative or select another remedial actionpresented in this Proposed Plan" and the FS-report,Therefore,.the public is encouraged to review and conv

w^^j}f^m^M^

Plan.

The following nine criteria were used to evaluate theremedial action alternatives for the ORC Superfund site.(See "Selecting a Remedy" on the insert for an explana-tion of the nine criteria)

1. Ove ra 11 Protection ofHumanHealthandtheEnvironment

Overall protection of public health and the environmentis provided by all of the groundwater alternatives ex-cept the no action and limited action alternatives; Eachof the other alternatives would protect human health byutilizing institutional controls to prevent the potentialuse of contaminated groundwater as a drinking watersu pply. Each of the 0 th er alternatives would pro tec t th eeh v ironm en t by pr e v enhng ground wa ter disc har ge in tothe creek-systems by using extraction well interceptorlines.

2. Compliance with Applicable or Relevant andAppropriate Requirements {ARARs}

ARARs are the federal and state regulatory standardsthat a selected remedy must meet. Groundwater alter-natives will meet all ARARs except the National Primaryand Secondary Drinking Water Regulations and theHealth Based Standards. All ground water a I tematives,except the no action and the limited action alternatives,would utilize groundwater remediation technology tolower contaminant levels in the aquifer. The goal ofGroundwater Alternatives III and IV is to containgroundwater contaminants on the ORC site and to aidthe biodegradation of contaminants in the aquifer. Al-ternatives IIT and IV are ex pected to lo wer ground wa tercontaminant concentrations but are not expected toreduce contaminants to meet ARARs

The goal .of Groundwater Alternative V is to lowercontaminant levels to meet RAOs within ten years.However, this goal is probably not achievable due to thelarge amount of clays in the subsurface at the ORC Sitewhich contain contamination. Tt has been found atmany other Superfund sites with.similar contaminantsand geologic situations that aquifer cleanup goals areoften not achieved because of the continued desorptionof contaminants from soils. The remediation of the claysoils would only be accomplished by excavation andtreatment and this is not cost effective due to the enor-mous volume of soil that would require:remediation.

As in Groundwater Alternative V, the goal of Ground-water Alternative VT is to lower contaminant levels tomeet RAOs within ten years- However, this goal is evenless achievabl e than in Ground water Al ternative V: Notonly does the contaminated subsurface clay problemexist, but also a significant contamination source (theLNAPL plume not commingled with hazardous waste)and petroleum-contaminated ground water are locatedhydraulically upgradient of the hazardous waste con-taminated area and would not be remediated. Thisupgradient contamination would continue to migrateand recontaminate the area of remediation: Unless thispetroleum contamination upgradient of the hazardouswaste contamination is remediated, it is unlikely thatthis alternative would achieve its remediation gpal.

3, Long-term Effectiveness and Permanence

Alternatives I and II would not provide a long-termeffective or permanent solution for the protection ofhuman health and the en vironment. These alternativeswould not prevent the migration of contaminatedgroundwater into the creeks or prevent the degradationof the creek environment.

Alternatives ill through VT would provide a 1 ting-termeffective solution for the protection of human healthand the environment. Institutional controls such aswarning s igns, property deed notices; and fences w ouldbe used to prevent the contaminated ground water frombeing utilized as a drinking water source. The contain-ment well system used for Alternatives HI and IV, andthe recovery well systems used for Alternatives V andVI,. v«Jtild prevent the discharge of contaminatedgroundwater into the creek environment. As long as theinstitutional controls and the containment well systemsare maintained, the protection of human health and theenvironment would be effectively achieved.

000027

002452

j !

None of the alternatives are expected to quickly achievea permanent solution to the contaminated ground waterproblem. The problem of LNAPL residual contamina-tion in subsurface clays cannot be solved using currentground water remediation technologies. However, thein-situ bioremediation treatment utilized by Alterna-tives 111 and IV, and the pump and treat active restorationtreatment utilized by Alternatives V and VI should bothhelp restore the ground water in the long term.

4. Reduction of Toxlctty, Mobility, or Volume of theContaminants Through Treatment .

All of the alternatives except the no action and limitedaction alternatives would reduce the toxidty, mobilityor volume of contamination through treatment: Alter-natives HI and IV utilize.in-situ bibtreatment to lowerorganic contaminant concentrations in the contami-nated aquifer and utilize pump and treat technology atthe downgradient borders of the site. Alternatives Vand VI utilize pump and treat technology throughoutthe contaminated aquifer. Therefore, Alternatives IIIthrough VI meet the statutory preference for usingvtreatment as a principal element

5. Short-term Effectiveness

Alternative I poses no short-term1 risk to on-site workersor the surrounding community.

Alternative fl poses no short-term risk to the surroundsing community but could pose a short-term risk toonrsite workers during the plugging of existing wells.

Alternatives 1G through VI pose little risk to the commu-nity but could pose a short-term risk to on-site workers.The risk to the community would be minimized duringground water remediation by maintaining strict con-trols on treatment processes and waste streams. Acontingency plan would be developed to address anypotential for emergencies during remediation activities.Risks to on-site workers would be minimized by adher-ence to Occupational Safety and Health Administrationrequirements which will be outlined in a worker healthand safety plan,

6. Impiementability

The no action alternative requires no implementation.Alternative II is readily implementable with local re-sources. Alternatives t through V F incorporate proventechnologies, and vendors providing these systems arereadily available. Alternatives Jll and IV will require a

pilot study To determine the best bioremediation • en-hancement procedure. Alternatives V and VI will needadditional aquifer testing and pilot studies to determinethe best implementation of the ground water extractionand treatment systems. Alternatives III and IV wouldrequire 30 years of implementation. Alternatives V andVI would require 10 years of implementation.

7. Cost

The present worth cost of the preferred alternative is$7,668,000. Alternatives 1 and IT are lower in present

• worth cost at $15,000 and $ 1,540,000 respectively. Alter-natives III, IV and VI are higher in present worth cost at$8,786,000; $22,339,000; and $14,576,000, respectively,

8. State Acceptance

The Oklahoma State Department of Health is in agree-ment with the selection of Alternative IV as the preferredremedy for the contaminated groundwater at the ORCSuperfund site- However, the final determination ofState acceptance of this alternative will not be madeuntil public comments have been received and evalu-ated,

9. Community Acceptance

Community comment will be an important factor in thefinal evaluation oi the remedial alternatives,

SUMMARY OF THE PREFERREDREMEDIAL ALTERNATIVES

Sed i merits a n d S u rf ace So i I s

The selection of Alternative V as the preferred alterna-tive for contaminated sediments and surface soils isbased on the following reasons. Alternatives I and IIhave been eliminated from further consideration becauseneither alternative provides overall protection for publichealth and the environment. Alternative IE has beeneliminated because the majority of wastes will not betreated but will be contained beneath low permeabilitycaps. With proper maintenance of the caps, contain-ment of the untreated wastes should protect humanhealth and the environment. However, this alternativedoes not satisfy the statutory preference for reduction oftoxicity, mobility and volume through treatment aseffectively as Alternatives IV through VI. Alternative FVhas been elimina ted because it does not treat all wastesthat exceed RAOs. It treats all waste that has the

14000028

002453

potential to; leach coritaileaves some waste on the site that, if uncovered, couldpose a risk to human health; Alternative VI has beeneliminated because it will achieve the same goal asAlternative V but is more than twice the cost ofAlternative V,

> ground toiater bij t • i r" reinedies, reKed on the infbnria tibn currently available,EPA and OSDH believe the preferred alternative pro-vides adequate protection of human health and theenvironment, utilizes permanent solutions and alterna-tive treatment technologies to the maximum extentpracticable, and will be cost effective. The preferredalternative will also satisfy the preference for treatment

In summary, based on the information currently avail- as a principal element.able, EPA and OSDH believe that Alternative V willeliminate the risk of direct human contact with surfacewater and will significantly reduce the risk of directhuman contact with contaminated sediments and sur-face soils; Since all contaminated sediments and surfacesoils above RAOs will undergo treatment; the long-termeffectiveness and permanence of this alternative is ex-cellent. There are not expected to be any unmanageableshort-term risks associated with this alternative and thisalternative complies with all AHARs. Alternative Vutilizes permanent solutions and alternative treatmenttechnologies to the maximum extent practicable, andwill be cost effective. The preferred alternative will also

FOR MORE INFORMATION

For more' information about the public involvementprocess or if you have questions about activities at theORC site, please contact:

LUaLyhane, Project ManagerOSDH * Superfund Program

; 10DO N.E. 10th St.Oklahoma City, OK 73117-1299

(405) 271-7157

satisfy the preference for treatment as a principal ele-ment. Therefore, Alternative V provides the best balanceamong alternatives -with respect to the criteria used toevaluate remedies. ..

Ground water

The selection of Alternative IV as the preferred alterna-tive for ground water remediation is based on thefollowing reasons. Alternatives I and II have been elimi-nated from further consideration because neitheralternative provides overall protection for public healthand the environment- Alternatives III and V have beeneliminated from further consideration, because thesealternatives are prohibited under current CERCLA au-thority since they include remediating a portion of thegroundwater which has only been contaminated bypetroleum product. Altemati ve IV reduces contamina-tion through 30 years of irvsitu bioremediation.Alternative VI reduces contamination through 10 yearsof pump and treat technology, ft is difficult to predictwhich of these alternatives would be more successful inrestoring the aquifer. Both these alternatives containand prevent migration of contamination from the site.However, Alternative IV achieves containment of con-taminated ground water and possible aquifer restorationwith a much lower total cost.

In summary, Alternative IV, the preferred groundwateraitem ative, is believed to pro vide the bes t balance amongalternatives with respect to the criteria used to evaluate

Noel Bennett, E\E, Remedial Project ManagerUS.EPA (6H-SR)1445 Ross Avenue

Dallas, TX 75202-2733(210655-6715

1-800-533-3508 (Toll-free)

Donn Wallers, Community Relations CoordinatorU.S.EPA (6H-MC)1445 Ross Avenue

Dallas, TX 75202-2733(214)655-2240

1-800-533-3508 (Toll-free)

Media inquiries should be directed to Roger Meachamor Dave Bary, EPA Region 6 Press Officers, at (214) 655r

2200,

Q If you plan to attend the public meeting onr^-\ February 20,1992 a nd need specia I assistancev _ y v because of physical limitations or visual orhearing impairments, call Donn Walters before Febru-ary H at (214) 655-2240.

This Proposed Plan is printedon recycled paper with

ink free of cadmium and lead

• . 1 5 000029

002454

Figure 2 'AREA OFGROUNDWATER AND LNAPL

RE MED (AT ION FOR

Figure 3 L

AREA OFGROUNDWATER AND LNAPLREMEDIATION FOR

1 ALTERNATIVES II! & V

300030

002455

002456

Response Actlom

Groundwater extraction wells, entire aquifer contaminated by ORC .

Groundwater ei>;lraction wells, RSS aquifer commingled wilh haz.a rdous waste ·

REMEmAf~ ACTION ALTERNATIVES F_OH. GROUNDWATER FF..ASIBIUIT STUOY

OKLAHOMA REFINING COf'I-WANY SUPERFUND SlTK CYRIL, OKlAUOMA

· A.lterriatlve I NoAeti.oir.

Altemativt U Limiled Aclion

Alternative Ill ConJainriu:nl, · E""re U:APL

· .Plume Rarwva4' 111-Silu .

Birlremediatkm E~of

RSS Aquifu

"' •

•

/"Aif.erna·ti~ w > · · At~ttye :v -.-~-~J·: .4~f

-: -IJsiiMrj "of ,- . -~·of ', . LNAPL' -· Rum. Springs .

_:'G.ommingteJ wilh ~ · Sawlskme if.~·~-w.~~: -~~-~.

- ,· fti~iJi,l '.

. ..

..

. .. . ... •

.. Response action t~ppropriatc to this alternative.

Alternative VI Active

Resrororfun of RSS Aquifei Commingled

with HazardOU5 Waste

. . •

aS

ft

TABLE 1

ItEMEDIAL ACTION ALTERNATIVES TOR SEDIMENTS AND SURFACE SpIDjiFEASIBILITY STUDY

OKIAHOMA RERNfNG COMPANY SUPERFUND SITECYKJL, OK1AH0MA

Response Actions

(1) No action

(2) Limited action

(3) Containment (low permeability cap)

(4) In-situ stabilization with cap

(5) Excavate/recycle

(6) In-situ biotreatmcnt •

(7) Excavaic/nculralize/disposal in,area of origin

(8) ®&SBfflgtiBffi&^0^&^$g^^ '

(9) Excavate/LTTD treatment and/ofstabilize/dfeposaj in Subtitle C landfill

AlternativeI

all groups

IfltBlfl

BIIIHH

Attentatfve

all groups

ilililS

Alternativein r

7

5^,13,16,18

2,3,4,6^10,11,12,14,15

lililHBils1,17

IllHipli;

Alternativeiv '•

7 • . '.

5,9,13,16,IS

illlHlH3,6f15

4

S

12,14,17'

liiilii

i " •••• • • ' • "

5 • • • !

(§§•13,6,15

" 9 ' ' •

4 '. •'

8

12,13,14,16,17,18

AlternativeVI

v - - ' •'-.

5

3,6,15

,,9

8

. 1,2.4,10,1.1,12,13J4,16,17,18

Note: Applicable group numbers arc shown in each box under each alicrnalive. The numbers shown in the boxes correspond to the followinggroup numbers: •

Group 2; Oil Skimmer Fond* 1 and 2'Group 3: Asphalt Pit 1 , 'Group 4: North Paaiis ] and 2, Asptmli Flow AreaGroup 5: North Ponds 3, A, 5, 6 and ft, South Pond* 1-8, Oil Skimmer Pond 3Group 6: Old Storage Tils 5 and 7 ' • 'Group 7: Pump Pits 1 and 3Group 8: Buried Acid Pits 1 and 3Group 9: Old Sinrnic Pits 1, 2, and 3. pitch Pits 1-3, and AsphaJt Pits 2 and 3

p 10t Old Storage Pit 4Croup 11: Old CaujsiicFils S and 9 and the Lime Soda Stcnage PitGruup 12: . Slop Oil Ponds 1 and 2 and API separator sedimentsGroup 13: Ntirth Poad 7 , ' 'Group 14: Old SlflfiagcPit 6Grolip If: Surface soils wjih itior^tnics erc*edin| iâundwster protection RAOsGroup 16: Surface WLM wilh brganks exceeding hettlh-bastd RAOs

• • Gmup 17: Surface soils associated with phenol spiE[ ureftsGmup Jd- Surface soils with inurânics atreding heflilti-hawd KAOs

••.-*••>&

002457

GLOSSARYAir Stripping: A process used to transfer volatileorganic compounds from a water stream into anair stream by contacting clean air with contami-nated water usually in a column.

Ambient Air: The surrounding air.

AppiicableorRelevantandApproprl ate Require-ments (ARARs): ARARs are the federal and staterequirements that a remedial alternative must meet.ARARs are one of nine criteria used to evaluateremedial alternatives for a site.

Baaelihe Risk Assessment: A study performedon a Superfund site prior to any remedial action toassess the actual and potential risks of the site if it isnot remediated. ~

Biotreatment: A process used to biologically treatsolids or liquids contaminated with organic com-pounds through the use of naturally occurring rnircroorganisms. The process is enhanced through theuse of nutrients, oxygen, and water.

Carbon Adsorption: A water treatment processthat removes organic compounds by passing waterthrough activated carbon.

Carcinogenic: Cancer causing.

Chemical Precipitation: A process used to removeheavy metals from a contaminated liquid stream bythe addition of chemicals that react with the heavymetals lo form a solid precipitate The precipitatecan then be separated from the liquid and properlydisposed, . •• • . . . .

Containment: A process to prevent contaminatedmaterials from migrating, such as placing solids in alandfill or cons tni c ting low permeability or hydrau-lic barriers for liquids.

Feastbllity Study (FS): A study required byCERCLA to establish criteria for remediating aSuperfund site, to identify and screen alternativesfor remedial action, and to analyze in detail thealternatives and their costs.

Fiitering: A process used to remove suspendedsolids from a liquid through the use of a filter.

Group: The term given to waste areas at the ORCsite that have similar physical, chemical andhydrogeological characteristics. There are 18 groupsfor the ORC site/

Hazard Index: A numerical indicator of the accept-,ability or unacceplability of exposure to non-cancercausing chemicals- A hazard index below unity (1)is considered acceptable while a hazard index ex-ceeding unity may warrantconcern for non-cancereffects due to exposure.

In-sliu: kwplace.

Land Disposal Restrictions <LDRs): Restrictionsplaced on the land disposal of RCRA hazardouswastes. •

Light Non-Aqueous Phase Liquid (LNAPL): Aliquid that is less dense than water and thereforefloats as a separate layer, or phase, on top of thewater.

Low Permeability Caps: A covering made out ofsynthetic and/or natural materials that is used tocover contaminated sediments or surface soils andallowing only small quantities of water to infiltrate-Low Temperature Thermal Desorption (LTTD):A treatment process which removes volatile andsemi-vola tile contaminants from soils and sedimentsby heating them to temperatures ranging from 400°to 1000* Fahrenheit-Maximum Contaminant Levels (MCLs): Concen-tration levels set for specific chemicals by the EPAfor d rinking water sources.

National Oil and Hazardous Substances Pollu-tion Contingency Plan (NCP): The regulation thatsets forth the requirements of the Superfund pro-gram as mandated by CERCLA.

(Continued on back page)

19 000033

002458

GLOSSARY (Cont.)

National Priorities List (NPL): EPA's list of themost serious uncontrolled or abandoned hazardouswaste sites identified for possible long-term reme-dial response using money from the Trust Fund. Thelist is based primarily on the score a site receives onthe Hazard Ranking System (HRS). EPA is requiredto update the NPL at least once a year.

Neutralization:-A treatment process which consistsof adding an acid or base to contaminated solids orliquids to neutralize the pH.

Non-carcinogenic: Non-cancer causing.

Oxidation: A water treatment process which causesthe chemical oxidation of contaminants and theirsubsequent precipitation from the water.

Pump and Treat Remediation: A groundwatertreatment method using extraction wells to removewater frorn the contaminated portion of an aquiferand then treat it in a water treatment facility.

p p m: An abbre via ti on fo r "parts per m il 1 ion, "whichis a unit commonly used to express low concentra-tions of contaminants. For example, 1 gram of achemical in 1 million grams of water would have aconcentrationoflppm.

Record of Decision: The official EPA decisiondocument on the selection of a remedy that makesthe determinations and findings required by statuteand regulation. .

Recycling: The reuse of a substance or material.

Reduction: A water treatment process which causesthe chemical reduction of contaminants and theirsubsequent precipitation from the water.

Remedial Action Alternatives: A method, or com-bination of methods designed to protect public health,welfare and the environment over the long-termfrom releases of hazardous substances at a Superfundsite. Remedial alternatives are usually a combina-tion of technologies that contain, remove or destroy

most of the contaminants in the air, water, soil andgroundwater at a Superfund site.

Remedial Action Objectives (RAOs): Media-specific dean-up goals for protecting human healthand the environment. These goals were determinedin three ways: l)\by using levels set by regulatoryagencies, 2) by calculating a concentration thatwould not leach from soils and sediments and con-taminate groundwater, and 3) by calculating thechemical concentration that would cause a. "one inone million" risk of cancer by exposure throughingestion of the media.

i .RemedlaMnvestlgatlon (RIJ: A study which gath-ers and presents the data necessary to determine thetype and extent of contamination at a Superfundsite.

Resource Conservation and Recovery Act(RCRA): A Federal law that established a regula-tory system to track hazardous wastes from the timeof generation to disposal. The law specifies proce-dures to be used in treating,, transporting, storing,and disposin g of hazardous was tes.

Rush Springs Sandstone Aquifer: A PermianAge, underground rock formation composed of finegrained sandstone which has the capacity to holdand transmit economical volumes of water.

Sediments: Soil-like, material found indrainage ways, pits and ponds.

Stabilization: A treatment process whereby a wasteis mixed with various reagents such as cement or flyash, which harden and transform the waste into asolid mass. The cqnlaminants within the solid wastema teria 1 are held Dy s tron g chemical bond ing, whic hprevents the contaminants from leaching away.

Superfund: The common name used for the Com-prehensive Environmental Response, Compensa-tion, and Liability Act.

000034

002459

Ifcard oiHeallh

Jfjhn B. Cfl'tnichael, D.D.S,PrtSkierU

trrss'l 0. Maitin, R_Ph.

iiurdjc £ Grocn, M. D.

Cordon !•[. EteVtft, M D.

Dan R Fickci; D.O.

Waller Seed Mason. LiJ, laq.

: i Bjenlii[nilh,.M.D.

93 APR 29 PH 3- 21 OKLAHOMA STATE DEPARTMENT OF HEALTH

THOMAS D. PEACE. Ph.D.COMMISSIONER

April 23, 1993

Mr. Russell Rhoades, DirectorEnviron mental Services DivisionU.S. Environmental Protection Agency1445 .Ross Avenue, Suite 1200 •Dallas, TX 72502-2733 .

Re: Oklahoma Refining Company Superfund SiteCaddo County, Cyril, Oklahoma

Dear Mr. Rhoades;

This letter is to request assistance in the abatement of light n on-aqueous phaseliquid (LNAPL) surfacing in the seven sludge traps on the Oklahoma RefiningCompany (ORC) Superfund Site in Cyril, Oklahoma. The LNAPLs are floatingon the ground water beneath the site, and migrate to surface water in the sludgetraps when the ground water elevation rises. The sludge traps are a series ofsmall ponds that discharge into a small tributary of Gladys Creek. This occurredin several of the sludge traps in October 1990, and the Emergency ResponseBranch (ERB) responded by netting the sludge traps and placing booms on thesurface to prevent the LNAPL from discharging to nearby surface waters. Theheavy rains in the past few months have caused the LNAPLs to surface in allseven of the sludge traps and the old booms are no longer effective. In addition,the nets that had been placed across the traps have slumped to the point that theyno longer provide an effective barrier to waterfowl.

The primary threats associated with the LNAPL in the sludge traps include thepotential for exposure of trespassers and wildlife and the environmental damageto Gladys Creek and its tributary. Your assistance is requested because, at this

-00035

1000 HE TENTH- •" OKLAHOMA CITV, OK • .7 3 11 7- ] 299

002460

April 23, 1993Russell RhoadesPage 2

time, the Oklahoma State Department of Health does not have specific resourcesavailable to devote to this removal action.

If there are any questions regarding this site your staff may contact Terry Andrews at (405) 271-7157or Kelly Dixon at (405) 271-7156.

Sincerely,

wtJiMark S, Coleman, Deputy CommissionerEnvironmental Health Services

cc: Noel Bennett, EPA

000036

002461

Wastet

tate Departrrufni oi healthsast Ten tin Street551;ity, Oklahoma 73152

LU

j

nsb'sn

= (124§

POSTAGE

• • ' ' *

•a

aO<0

Mr, Russell Rhosides, DirectorEnvironmental Services DivisionUS EPA Region VI1445 Ross Ave.Dallas, XX 752O2-Z733

L J ^<t. ,_.

- T ' r r, <•

002462

SITE ASSESSMENT REPOETFOE

Oklahoma Refining CompanyCyrill, Caddo County, Oklahoma

May 10,

Prepared for:

J, Chris PecersenDeputy Project Officer

Emergency Eesponse BranchEPA - KEG I ON 6

Contract Number: 68-W0-0037

ecology and environment, inc.1999 BRYAN STREET, DALLAS, TEXAS 75201, TEL. (214) 220-0313

International Specialists in [he Environment

000038

002463

ecology and environment, inc.1339 BRYAN STREET, DALLAS. TEXAS 75201. TEL- U14) 220-0316

Intemationaf Spoaafists in the Envfronme/it OKD09159S870

Date: May 10,1993

To: John Martin, OSGEPA Eegion 6, Emergency Response Branch

Thru: J. Chris Fetersen, DPOEPA Eegion 6, Emergency Response Branch

Thru: Christopher Quina, TATLRegion 6, Technical Assistance Team

From: leroy G. HernandezRegion 6, Technical Assistance Team

Subj: Site Assessment: Oklahoma Refining CompanyCyrill, Caddo County, OklahomaTDD#: T06-9304-020PAN r EOK0067SB

On April 22, 1993, The Region 6 Technicai Assistance team (TAT)was tasked by the Environmental Protection Agency, j EmergencyFesponse Branch (EPA-ERB) to conduct a site assessment at CheOklahoma Refining Company (ORC), located in Cyrill, Caddo County,Oklahoma, The site is on the Superfund National Priority .list{NPL}, and has previously undergone a removal action by EPA (seeRemoval Report for TDM TO6-9O1O-065). Specific tasksj requestedof TAT, under the mast recent TDD, included coordinating, andmeeting with, Oklahoma State Department of Health (OSDH)representatives Mr. Tarry Andrews and Ms. KelJLy Dickson at thesite; assess the need for further removal action; place! absorbentboom in API separator sludge trap lagoons; photodocument

activities;situation,

submit a polrep; and brief the OSC on \ the site

TAT members met on-site with the OSDH representatives on April26, 1993. During a brief walk-over of the site TAT members andOSDH representatives noticed that the bird netting over three ofthe lagoons was sagging into the liquid, and that the existingabsorbent booms were saturated with oil (see photos, AttachmentA). The bird nets and absorbent booms had been installed duringthe EPA1 s previous removal action at the facility!, OSDHexplained that their department was in the process of completinga Remedial Investigation (R,I.) of the site, but that one oftheir immediate concerns is the presence of non-aqueous phaseliquids (NAPLs) infiltrating the API separator sludge traplagoons by shallow groundwatec forces. According to| OEDH, the

recycled £ac s:

000039

002464

source plume Uea directly under the lagoons and is travellingsouth toward an intermittent stream. The OSDH representativeswere concerned that heavy rains or high winds could cause some ofthe NAPLs to drain out of the lagoons and flow into the stream,which eventually flows into neighboring Gladys Creek, during thewalk-over, TAT members observed no visible evidence of past orpresent off-site SAPL plume migration, or releases jfrom thelagoons into the creek. Groundwater seeps into the stream alsoshowed no visible indication of NAPLs. The MAFLs rising to thesurface appeared to be contained within six of the seven lagoons.Mo visible evidence of infiltration was observed in the seventh,most downgradient, lagoon.

At the request of OSDH and EPA, TAT members |instailedapproximately 660 feet of absorbent boom in the four mostdowngradient lagoons to prevent the potential release j of MAPLsfrom the lagoons Into the stream. After installing the boom, TATmembers photographed the lagoons and departed the site.

On May 17, 1993, TAT and OSC Martin returned to ORC to meet withOSDH representative Terry Andrews and to install an additionalseries of absorbent booms In lagoons 6 and 7, OSC Martininformed Mr. Andrews that EPA may try to implement a more costand time efficient solution to the NAPL problem without directlyinterfering with the OSDH's on-going R.I,, and that j he wouldinform OSDH of any developments.

ATTACHMENTS:

A.B.C.D.E.

Photographs (3 pages)Unused Photographs (Negatives in TAT file}Site SketchCopy of Logbook (pages 1-6}Copy of TDD// T06-9304-020

T06

000040

002465

ATTACHMENT A

Photographs

000041

002466

000O42

002467

SITE HAHE: OKLAHOMA REFINING C M f M r IDDf: T J i - W H Z Dmw- vn mimtmtmmu; umni/wmmuU K : W l i m riME: 1M4 DIRECTIOft: S.E.BIRD NETTING IN API WtfATOK ISP

SITE mv mum REFITO COHPANV mvm m - 102 PHHTDt»APKEH\lf 1TVE£S = M

Wltm STfiE: i i l i DIRECTIUJI: i l . l .Iff

000043

002468

000044

002469

SITE mi:TOO* ]

IUUUG wmi rooi: TU-rciMz: HIWIPAL/HERNANDEZ

TIME- 1SW DIRECTION: N.(FLftCfMENI jN LflGOON « .

iTTE IA HE: JULftKOIift REFiNING COMPflMY TDDC 106-9304-020

DflfE: 0 1 « i / * 3 TIHE= l i i i miECTIDIC: J .E.BD-DIl PLACEMENT IN LASOON U .

000045

002470

000046

002471

mv mmn KFIHING wmc ra>i=: I K FHOIOGMPHERMITNESS:

01/ ! l f l3 T I K i l i l t OIBtCTBH: N,l .PLACEHENI IN LAGOON */.

000047

002472

ATTACHMENT B

Unused Photographs

000048

002473

002474

• ' r .• ~. ' • •

000043!

ATTACHMENT C

Site Sketch

000050

002475

United States Department of the InteriorFISH AND WTLnUFE SERVICE

DIVISION 0? LAW ENFORCEMENT902 NW 59TH Street

Oklahoma City, OK. 73118405^231-5251

TAME

May 18,1953 RECEEVED

MAY 1 r. -1393

Sofiff 'A'**ite -S:*-y;r>-

Mr. Dennis HrebecOklahoma State Dept, of Public HealthSolid Waste Management Service 02061000 NE 10 TH StreetOklahoma City, 0k. 73117-1299

Dear Mr, Hrebec:

Thanks for your phone call on Hay 7th. During that call, I told you that Iwould send you a letter reference the recent activity we had at the Cyri1 andDouble Eagle Superfundt sites. We had officers look at both those sites onApril 20,1993.

1-CYRJL SITE,That site has netting on it, tut that netting is in such a state of disrepairthat the FW5 is concerned about wildlife mortality in that site. Attached isa copy of the letter we sent to CYRIL PETROCHEMICAL CORPORATION and a copy offour photos that depict the condition of that site.

2-DOUBLE EAGLE REFINERY.We found a pigeon and the remains of a ring-billed gull in the concrete vatthere. We also noted and photographed cracks in the vat where fluids areleaking. A dead and rotting opossum was found floating in a clear water pondeast of the structures. Attached are copies of five photos showing the vattpigeon, gull remains, crack, and opo&sum.

If you have correspondence with the Environmental Protectionthese two sites, please keep us advised.

Sincerely,

Agency about

Garland L, SwainSpecial Agent

Attachments

000051

002476

United States Department of the InteriorFISH AND WILDLIFE SERVICE

DIVISIOH OF LAW ENFORCEMENT902 hi.VS. 59th Street

Oklahoma City, Oklahoma 73118

KMP0DCJN

CERTIFIED MAIL # P 306 317 372

May 17, 1993

Mr. Val HeneryCyril Petrochemical CorporationP.O. Box 579Cyril, OK 73029

Gent 1 emen:

The U.S. Fish and Wildlife Service (FWS) is continuing to investigate theunlawful killing of migratory birds in open pits, tanks, and waste disposalsites which contain oil or other toxic substances. !

As part of that investigation, your site located at the E.P,A, Superfund Sitewas inspected on April 20, 1933. The FWS Special Agent and Oklahoma GameWarden present found no migratory birds or other animals dead at yourfacility. However, officers observed conditions that could result in wildlifemortality. For that reason, we have enclosed a packet of information thatcould assist you in preventing that mortality. FWS agents will continue siteinspections to docunent any wildlife mortality. [

If you have questions, please feel free to write the above address or call(405) 231-5251.

Sincerely,

Garland L. SwairSpecial Agent

Enclosure

002477

CYRIL

: • - * , •

OKLAHOMA REFINING'CO,E.P.A. SUPERffljND SITE

SS?^J

* - " i T " - •* •£ •,." * • • "

002478

0 CYRIL

P%_#1%. >r

' • ' * • ' • •

000054

002479

DOUBLE EAGLE REl-IN'ERY

Concrete vat with circle around floating pigeon

Dead pigeon. 0000S5

002480

DOUBLE EAGLE REFINERY

s#r;

Feathers from decomposed ca rcass of r i n g - b i l l e d g u l l .

Leaking CTack in v a t .

002481

DOUBLE EAGLE REFINERY

Rotting opossum carcass.

000057

002482

002483

l N

........................... ____ _

/ /

/ /

/

6

7

I

I

I I R BIID NETTtiG

I - - - - ABSORBENT BOOMS

8 Ecoll)gy and Environmrni, lnr. CERCUS/CASEI: OKD091598870 TODi

• iPchnicaJ Assislan~e Team SOURCE: I R · Vl TEa NCAL ASSiSTANCE mM

eg1on j

ATTACHMENT 8: SITE SKETCH I . OKLAHOMA REFINING coNJrANV

. CYRJLL, CADDO COUNTY, OKLAHOMA I

ATTACHHEKT D

Copy of Logbook

002484

[J ecology andfe) environment, inc,

Specialists in che E|nuirunment

002485

^T^^vV^j"^.,!^

£ & E Job dumber C-QK0OJP>^>^) f £-t

Telephone Code M umber

Site Name 0 fC LA, f\f> *, > ^ ^ r to i iO

City/State <^Sy ^ - i I t - 3 jk LA,

TDD

PAN ^ 0 &L.QQ& V . j j5?

9

Start/Finish Date /?

Book —,/ of

E & E Emergency Response Center: (716) 6S4-8G40

E & E Corporate Center: (716) 684-8060

MEDTOX Hotline: {501) 370-8263

E a E Safety Director (Home): (716) 655-1260

002486

002487

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ATTACHHEBt E

Copy of TDD0 TO6-93O4-O2O

002492

1A. Cost Center:

1B. Account No.:

TAT ZONE II CONTRACTCONTRACT NO. 6B-WO-0037

TECHNICAL DIRECTION DOCUMENT (TDD)

ECOLOGY AND ENVIRONMENT, INC.

2. No,:

- 020

Amendment

3A. Priorityd HighD Medium• Low

3B. Key EPA Contact;

Name:

Phone:

4A. Estimate ofTotal Hours:

Total Costs:

jj> IJ,7OO4B. Overtime

Approved:

3 YesD No

5A. EPA Site Name:

5B. SSIDNo.; 5C. City/ County / Sla<e:

/

6. Source Of Funds:3CERCWDOPAD UST

QCEPP,D Other

7. CERCLISID:

8A.Completion Dale:

SB.Reference Info:D Ves a AttachedBl No • Pick-up

9- Type oi Activity:OPA

• SPCCD On-Scene MonitoringD Spill Clean-up Funded

CERCLA

\3 Site AssessmentD Removal Funded• Removal PRP (AO/CO)D On-Site Monitoring

AS SPECIFIED ABOVE

D Special Project• Analytical ProjectD Corp. Special ProjectD PreparednessD UST ,• FEMA

• Quality AssuranceD TrainingG Program Management• Technical Assistance• Information Management

10 General Task Dascription: f O | j T m f T £AMe*?T CLT TUB OtlfahoMt

l ? . Specific Elements:

A.

11. Desired ReportForm:Q Formal Report(3 Lener R&portD Formal BriefingD Other (Specily)

13. interim Deadlines;

ex.

14. Authorizing D

16. Received by;- $£ Acceofo |D ^cqpfited with Exceptions (Attached) O Rejected (7. Dale:

TATL Signature

Sheet I v/HieSheet t BtisShuHi •] Green

Shaflt 5 PmkShmL fi Golda wod

. DPO Ctspf• TATt Copy- ZPM Copy. POCejy,

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USPH SOLIB WASTE

FACSIMILE COVER SHE&T

SOUD WASTE MANAGEMENT SERVICEOKLAHOMA STATE DEPARTMENT OF HEALTH

1000 N.E, 10TH STREETOKtAHOMA CITV, OKLAHOMA 73117-129*

DATE:

TO:

COMPANY NAME;

TELEPHONE # : _

FACSIMILE #

^(MAIL CODE).

TOTAL PAGES SENT{including cover sheet)

COMPANY NAME:

TELEPHONE *f40SW71Q

FACSIMILE #O5DHf405^71-7079

000070

002495

/ *

MEMORANDUM

DATE: July 6, 1993

TO: Dennis Hrebec, Ph.D.Superfund Division Director

FROM: Terry AndrewsSenior Hydrologist

SUBJECT: Assessment of LNAPL thickness and movement on the ORC Superfund Site,Cyril, Oklahoma.

On June 4, 1993, Kelly Dixon and I measured water and light non-aqueous phase liquid(LNAPL) elevations in monitoring wells located in and around the LNAPL plume on thesouthern portion of the ORC Superfund site. The EPA Record of Decision for this site statesthat the LNAPL in this area will be removed using extraction wells. These elevations had notbeen measured since the RI/FS, which was completed in 1991. Table 1 is a summary of theobserved LNAPL thicknesses that have been measured by OSDH. After measuring these levels,the observed LNAPL thickness was mechanically contoured using the kiidging method fromSURFER. The resulting map of observed LNAPL thickness is shown on Figure 1.

Although the true formation LNAPL thickness is probably not represented by the observedthickness in the monitoring wells, the stratigraphic geology in the LNAPL area is such that theerror due to capillary forces is probably minimal. Since the stratigraphic interval that theLNAPL is affecting is composed mainly of sand and sandstone, the capillary forces should onlyincrease the LNAPL observed thickness by a foot or less,

i

LNAPL thicknesses had been measured several times during the RI/FS. In order to show thechanges in thickness due to the observed movement of LNAPL to the southeast, the earliestmeasurement of LNAPL thickness conducted by the OSDH. in January 1990, was mapped andmechanically contoured using the same kridging method from SURFER. The resulting map ofobserved LNAPL thickness is shown on Figure 2,

By comparing Figure 1 and 2, it is obvious that a significant amount of the LNAPL has movedto the southeast. Figure 3 is a three dimensional cross-sectional view from the south of the 1990and the 1993 observed LNAPL thicknesses. A dramatic eastern migration of LNAPL is obviousby comparing the two cross-sections.

SURFER was also utilized to calculate the volume of the LNAPL, as it is depicted in Figure 1,By assuming an effective porosity of 25 percent, a volume of 37.6 million gallons of LNAPLwas calculated. If a LNAPL removal project was able to extract 30 percent of this volume, 11.3million gallons would be removed. However, the longer it takes to begin the LNAPL removalproject, the lower the LNAPL removal efficiency is likely to be. This is because a largerresidual volume of LNAPL will be trapped in subsurface media.

I l l | III I HI'

OOOO71

002496

©In summary, observed LNAPL thickness measurements indicate that the LNAPL plume on theabandoned property at the ORC Superfund site is moving to the southeast towards Gladys Creek.The rate of movement of the LNAPL appears to be much greater than the rate of movement ofground water. By comparing changes in thickness it appears that the LNAPL is movingsoutheast at a rate of approximately 200 feet per year. If the LNAPL is left unchecked, asignificant thickness will likely reach the creek in approximately three years.

Table 1 - Observed LNAPL Thickness (in feet) in Monitoring Wells

Well

RW-11

RW-12

RW-13

RW-14

RW-18

RW-19

E-1

E-2

E-3

E-4

E-5

SEDG-1

SFDG-2

SFDG-3

SFUG-4

SW-3

SW-4

SE-9

SBB-6

SBB-7

SBB-13

SBB-14

Jan., 1990

7.1

11.1

4.2

8

NM

1.5

0

NM

4.4

0

NM

0

NM

4.3

NM

NM

0

0

—

—

—

—

July, 1990

6.9

1.4

7.1

7.3

0

0.2

0

NM

5.7

0

0

0

0

2.1

0

3.5

0

0

0

0

0

0

Apr., 19

—

—

—

—

—

—

—

--

—

--

—

—

—

—

—

0

0

0

0

91 June, 1993

5.4

0.8

14.7

4.6

0

NM

0

—

5.6

0

0

0

0

.02

0

7.4

0

0

—

0

0

0

000072

002497

Well

SBB-23

SBB-26

SBB-27

SBB-38

SBB-39

OB-1

OB-2

Jan., 1990

—

—

—

—

—

—

—

July, 1990

—

—

—

—

—

—

--

Apr., 1991

.02

4.4

0

0

0

0

0

June, 1993

4.1

10.1

0

0

0

0

0

NM Not measurable amount of LNAPL (sheen)— Not measured

000073

002498

FIGURE 1 OBSERVED LNAPL THICKNESS FTIOM JUNE, 1993 DATA

SCALE: 1 INCH = 200 FEET000074

002499

^•^•^^|3^^

FTGURE 2 - OBSERVED LNAPL THICKNESS FROM JANUARY, 1990 DATA

SCALE: 1 INCH = 200 FEET

00-0075

002500

FIGUKE 3 - THREE DIMENSIONAL CROSS-SECTION VIEWS OF THEOBSERVED LNAPL THICKNESS IN 1990 AND 1993

WEST JANUARY, 1990

I

002501

UNITED STATES ENVIRONMENTAL PROTECTiON AGENCY

REGIONS1445 ROSS AVENUE, SUITE 1200

DALLAS, TX 75202-2733

MEMORANDUM

DATE;

SUBJECT;

TO:

FROM:

September 17, 1993

Request for a 12-Month Exemptionand a Removal Action at theOklahoma Refining Company NPL SiteCyril, Caddo County, Oklahoma

Russell F, RhoadeaDivision DirectorEnvironmental Services Division ( GE )

THRU:

John J, MartinSenior On-Scene/ôordfnator *"Removal/Site Section (GE-ES)

Charles A, GazdaChiefEmergency Response Branch (6E-E)

Site IT) #;CERCLT5 ID#:CATEGORY:

D9OKD091538870Time-Critical

I. PURPOSE

The purpose of this Action Memorandum is to Request approval of aRemoval Action and a 12-month exemption pursuant to theComprehensive Environmental Response, Compensation and LiabilityAct (CERCLA), as amended, 4 2 U.S.G. §9 601 et sea.. at the OklahomaRefining Company NPL Site (the "Site") located in Cyril, CaddoCounty, Oklahoma, This action meets the criteria for initiating aremoval action under the National Contingency Plan (MCP) , 4.0 CFR§300.415. The proposed action involves the collection and storageof a waste-sheen material, the erection, of fencing, and theof existing bird-netting.

repair

\\r000077

i) Printed en

002502

II, SITE CONDITIONS AND BACKGROUND

A, Site Description

1. Removal site evaluation

On August 30, 1990, the Region 6 Regional Administrator signed anAction Memorandum (the "Original Action Memo") approving a time-critical removal action at the Oklahoma Refining Company (ORC)Site, Prom September of 1990 through September of 1991, EPA'sEmergency Response Branch (ERB) implemented the tasks outlined inthe Original Action Memo, which included well plugging, fencing,and drum disposal. The other tasks performed by ERB involved theAPI separator trap lagoons. Specifically, ERB removed an oilysheen from the surface of the lagoons and installed bird-nettingmaterial to protect migratory birds. The Site is a fund-financed,state-.lead Maticnal Priorities List site.

Recently,' at the request of Oklahoma State Department of Health,notv the Oklahoma Department of Environmental Quality (ODEQ) , ERBrevisited the Site to investigate whether further actions needed tobe taken to mitigate current threats. On-site remedial action hasnot begun. OPEQ is in the process of securing bids forimplementation of the remedial design. ODEQ has indicated that oneof their immediate concerns is the presence of light non-aqueousphase liquids (LNAPLs) infiltrating the API separator sludge traplagoons by shallow groundwater forces.

The seven sludge trap lagoons are directly doivn-gradient from theAPI separator and are designed in succession from one to the nextin order to treat the outfall before it is released off-site intoan intermittent creek. (See Attachment 1 for the Site Map). TheLNAPL plume lies directly beneath this area. Apparently, heavyrains cause the L-NAPLs to percolate into the lagoons. High windsand lagoon drainage cause the LNAPL sheen to migrate south in thesuccessive lagoons, eventually reaching the intermittent creek.This creek drains into Gladys Creek.

The Technical Assistant Team (TAT) visited the Site on April 26,1.993, both to meet with the OfiEQ representatives and to documentthe current conditions at the Site, In addition, the TAT placedapproximately 660 feet of absorbent boom in the four mostdovmgradient lagoons to prevent further migration of the LNAPLsheen into the intermittent creek. On May 17, 1993, the OSC andTAT met with the ODEQ representative at the Site to strategicallyinstall additional boom in lagoons 6 and 7. The previously placedbooms had become completely saturated with LNAPL material,rendering them ineffective. Between Site trips, the volume ofLNAPL sheen had increased significantly, especially in lagoons 1,2,and 3, Furthermore, because a large oily stain leads into thelagoon system, it appears that additional material had been dumpedinto the lagoons, thereby contributing to the sheen.

•t, ij

002503

2. Physical location

The ORG Site is located in Gaddo County on the eastern edge ofCyril, Oklahoma, approximately 75 miles southwest of Oklahoma City.The Site cuvers approximately ISO acres and is bordered by thetown's residential and commercial areas to the west, U.S. Highway277 to the north, Gladys Creek to the east, and an unnamedtributary of Gladys Creek, private lands and City property to thesouth. Gladys Creek is a tributary of Chetonia Creek,approximately one mile downstream. Chetonia Creek empties into theLittle Washita River, 1,75 miles south of the Site. A segment ofthe Burlington Northern Railroad divides the ORC Site.

3- Site characteristics

In September 1984, the principals of Oklahoma Refining Corporationfiled for bankruptcy protection under Chapter 11 of the BankruptcyCode in the U,S, District Court for the Western District ofOklahoma, Case No. 84-02763-A, and ceased operations at that time.On November 4, 1935, ORC'£ Bankruptcy Trustee filed a notice ofintent to abandon the southeast section of the Site (the "InactiveArea11). On July 11, 1986, the Bankruptcy Court granted thatpetition. In 19S7, Cyril Petroleum Company ("CPC-"} purchased thenorthern portion of the Site (the "Active Area") from thebankruptcy estate. The Active Area consists of the processingequipment and the majority of the storage tanks. CPC plans' toreopen the processing facility in the near future. Refinery wasteswere primarily disposed of in numerous pits and ponds in theInactive Area.

4, Release or threatened release into the environment of ahazardous substance, pollutant or contaminant

The Remedial Investigation Report, prepared by ODEQ in 1991> showednumerous contaminants in many of the surface impoundment sediments,surface soils, and subsurface soils. The contaminants wereprimarily petroleum-related organic chemicals and heavy metals.Lead, chromium, and arsenic were commonly found heavy metals.Benzene, ethylbenzene, phenol, methyl-phenol, toluene, naphthalene,and 2-jnethyl naphthalene were commonly found organic contaminants.These substances are defined by section 101(14) of. CERCLA, 42U.S.C. §96 01(14)(c), and 40 C.F,R. Part 30 2.4 as hazardoussubstaaces.

The A!?I Separator and the sludge trap 'lagoons are regulated underthe Resource Conservation & Recovery Act (RCRA) as a listedspecific source of hazardous wastes (KO51 wastes) from thepetroleum refining industry. The contaminated sheen in the sludgetrap lagoons consists of LNAPLs co-mingled with the RCRA"regulatedAPI separator sludge. This contaminated sheen continues toincrease in volume. Consequently, additional contamination ismigrating off-site.

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5. MPL status

The ORC Site was placed on the Superfund National Priorities List(NPL) in Jane 1988. ODEQ estimates that on-site remedialactivities will begin in the spring of 1995,

6, Maps, Pictures and other graphic representations

Attachment 1 Site MapAttachment 2 Health Effects

B. Q_the_r_ Act ions to Date

1• Previous actions

After the Original Action Memorandum was approved on August 30,1990, the On-Soene Coordinator (OSC) mobilized the Site andinitiated a time-critical removal action on September 17, 1990.Site activities began on the Inactive Area of the Site as the EPAnegotiated with the property owner of the Active Area for erectionof a fence and other removal tasks. All tasks proposed in theOriginal Action Memo were completed by the removal completion dateof September 3, 1991. While the PRP erected some of the fence onthe Active Area, ERGS conducted the majority of the removal tasks.The tasks that were approved and completed include:

- the installation or repair of approximately 10t100 feet offenceline to restrict site access. Warning signs were postedalong this fenceline,

- API separator lagoons 1,2, and 3 were netted with specialfabric to protect migratory birds and waterfowl.

After bulking and characterizing thirty-eight drums,eighteen drums representing ten waste streams weretransported off-site for proper disposal,

- An EftCS' subcontractor plugged twenty-three improperlyinstalled wells which were contributing to contaminantmigration off-site,

2, Current actions

As ODEQ progresses with the remedial project to begin on-siteclean-up, the current owners of the Active Area anticipateutilization of some of the processing equipment next fall. Theyare currently refurbishing the equipment that they hope to utilizein their production of unchlorinated solvents.

000080

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C. State and Local Authorities' Roles

1. State and local actions to date

The ODEQ requested assistance from EPA because ODEQ lacks specificresources to devote to the immediate actions needed at the Site.ODEQ is the lead agency responsible for remediating contaminationat the Site. ODEQ is working with EPA to develop a permanent,long-term remedy for the Site. They have completed the RemedialInvestigation and Feasibility Study reports. Currently, ODEQ is inthe process of finalizing contracts for Remedial Design, Remedialon-site field work of the Phase I design is scheduled to begin inthe Spring of 1995, Mark Coleman, Deputy Commissioner of theEnvironmental Health Services for ODEQ, has requested in a letterdated April 23, 1993, that EPA's ERB provide assistance in theabatement of the LNAPL- in the sludge traps,

2. Potential for continued State/local responseI

ODEQ will serve as the lead agency under a cooperative agreementwith EPA. As the lead agency, ODEQ will implement the permanent,long-term remediation project at the Site, But, the time periodbefore on-site remediation begins is too lengthy to mitigate theimminent and substantial threats posed by the current conditionsfound at the Site,

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, ANDSTATUTORY AND REGULATORY AUTHORITIES

The current conditions indicate that the Sitje is a threat to thepublic health, welfare or the environment and a removal action isappropriate under 40 C.F.R. §300 . 4I.5( b) (2 ) of the NationalContingency Plan.

A. Threats to Public Health or Welfare

i) Unauthorised personnel entering the Site will have actual orpotential exposure to hazardous substances and contaminants. Theprobability of direct exposure to hazardous substances andcontaminants found in the surface soils, pijt wastes, and lagoonbottoms ami standing water is significant throughout the Site.While the previous EPA removal action adequately fenced the Site torestrict Site access, the gates to the Activje Area have not beenconsistently locked or secured. Hunters and other persons canenter the Inactive Area through the Active krea's gates without

s knowledge or approval.

oooosi

002506

ii) There are high levels of hazardous substances and contaminantsfound throughout the Site in the surface soils. The wide varietiesand large volumes of contaminants found throughout the Site'ssurface soils and pits pose a health threat via dermal contact,incidental ingestion, and inhalation of dusts. Previous samplingat the Site has shown that the API Separator sludge lagoons to becontaminated with high levels of chromium, arsenic, lead, benzene,toluene, ethylene, and xylene. See Attachment 2 for "HealthEffects1'.

iii) Weather conditions contribute to the release and migration ofthe LNAPL pollutant. As heavy rains increase the groundwatertable, the LNAPL plume beneath the API separator lagoons isreleased into the lagoons thereby producing a sheen. The sheenmigrates via wind and drainage into each successive lagoon beforebeing release into the intermittent creek. The intermittent creekis a tributary of Gladys Creek, which is a tributary of ChetoniaCreek, approximately one mile downstream. Chetonia Creek emptiesinto the Little Washita River, 1.75 miles south of the facility.The Little Washita River is designated as a public use stream withpotential uses as public and private water supplies andrecreational uses.

B. Threats to the Environment

i) The Site has had an impact on aquatic life in Gladys Creek,The TAT conducted preliminary studies of free-swimming and benthiccounts in the Site's leachate and discharge areas. The resultsindicated a significant decrease in the aquatic populationscompared to an upstream location. Discharge of the waste sheenfrom the API Separator sludge lagoons contributes to this adverseimpact.

ii) The oily and toxic properties of the API sludge lagoons posea serious threat to migratory birds and waterfowl that come to theSite to land and rest on the Site's manj' lagoons. The nets thatwere installed in the previous removal action have become so slackand weighted down with debt-is that they hang below the lagoonssurface. Therefore, the nets have become ineffective and need tobe re-stretched.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances, pollutantsor contaminants from this Site, if not addressed by implementingthe response action selected in this Action Memorandum, may presentan imminent and substantial endangerment to the public health,welfare, or the environment.

•000082

002507

V. EXEMPTION FROM STATUTORY LIMITS

Based on §104(c) of CERCLA, 42 U.S.C. §9604(c}, an exemption isbeing requested that is consistent with the remedial action totaken at this Site. Current Site conditions pose an immediate risktc public health or welfare or the environment. Further removalactions are required to mitigate the situation as ODEQ's responsecan not be provided on a timely basis. The proposed responseactions are otherwise appropriate and consistent with the remedialaction to be taken.

VI. PROPOSED ACTIONS AND ESTIMATED COSTS

A, Proposed Actions

1. Proposed action description

The proposed actions to be taken include skimming the APT Separatorlagoons as needed, fencing the Inactive Area entirely, and re-Etretching the protective bird netting. The LNAPL sheen will beskimmed from the API Separator lagoons when a large amount collectson the surface and threatens to be released off-site. Containmentbooms will be placed in the lagoons to minimise migration into thenext successive lagoon and to serve as a diversion point for easiercollection. An nearby above-ground storage tank will be used tostore the LNAPL material until site remediation can begin. It isnot expected that this storage tank will become full. But if itdoes, off-site disposal of the waste material will be necessary.The saturated absorbent booms that were previously placed in thelagoons will be drummed and shipped off-site for proper disposal.

The Inactive Area's northern boundary had restricted access due tothe Active Area's southern fenceline along the railroad tracks.This fenceline has several gates but they are not continuouslylocked. The level of activity in the Active Area has increased asthe owner prepares to restart the processing equipment in thatarea. The majority of the on-site remedial actions will beimplemented on the Inactive Area such that this portion of the Siteshould be segregated by a fenceline which will be approximately3i8DO feet in length and constructed of hog-wire fabric topped withbarbed-wire. The fenceline will have six gates with locks atlocations determined by ODEQ , Warning signs will be posted asneeded.

Finally, bird-netting installed over the three lagoons nearest theAPI Separator pit have become ineffective. The wiring between thepost holding the nets off the surface has become slack such thatthe netting has fallen into the lagoons. These upper lagoonsfrequently hold the thickest sheen of all the API Separator lagoons

000083

002508

and they pose the greatest threat to migratory fowl and waterfowl.The bird-netting -wiring will be re-stretched and the bird-nettingre-secured,

2. Contribution to remedial performance

The actions proposed for the Site are cost effective and consistentwith any long-term remediation strategies that may be or havealready been developed for the Site.

3. Description of alternative technologies

Alternative technologies are not applicable this removal action,

4. Applicable or relevant and appropriate requirements

This removal action will be conducted to eliminate the threat orpotential threat of a hazardous substance, pollutant or contaminantpursuant to CERCLA, 42 U.S.C § 9601 et seq. , and in a mannerconsistent with the National Contingency Plan, 40 CFR Part 300, asrequired at 33 U.S.C. § 1321(c)(2) and 42 U.S.C. § 9605.

As per 40 CFR § 300.415(i), fund-financed removal actions underCERCLA Section 104 and removal actions pursuant to CERCLA Section106 shall to the extent practicable considering the exigencies ofthe situation, attain the applicable or relevant and appropriaterequirements under Federal environmental law, including, but notlimited to, the Safe Drinking Water Act (SWDA), 42 U.S.C. § 300f etseq.. the Clean Air Act (CAA), 42 U.S.C. §7401 et sea.. the CleanWater Act (CWA), 33 U.S.C, 31251 et seq.. the Resource Conservationand Recovery Act (RCRA}, 42 U,S,C % 6901 et seq., the MigratoryBird Treaty Act, IB U-S-C. §701 e t sea., or any promulgatedstandard, applicable or relevant and appropriate requirements,criteria, or limitation under a State environmental or facilitysiting law that is more stringent than any federal standard,requirement, criteria, or limitation contained in a programapproved, authorized or delegated by the Administrator andidentified to the President by the State.

5. Project schedule

Repair to the bird netting and the installation of the fence willrequire approximately five days. Addressing the contaminated sheenand waste material in the API separator lagoon area will continueas needed until the on-site remedial project begins; estimated tostart in the spring of 1995.

000084

002509

B. Estimated Costs

The previous Removal Action ceiling was established at $461,000,The total removal cost for the Site was $342,839 for actions takenpursuant to the Original Action Memo, Funds which had beenobligated for the action but not used have been deobligated.

Extramural Costs

ERCS $ 13 5 f 000

TAT $ 40,000

Subtotal, Extramural Costs ...$ 175,000

Extramural Costs Contingency

(20%) $ 35,000

TOTAL, EXTRAMURAL COSTS $ 210,000

Intramural Costs

EPA Direct Costs $ 15,000

EPA Indirect Costs ' $ 18,000

TOTAL, INTRAMURAL COSTS ' $ 33,000

TOTAL, REMOVAL PROJECT CEILING * 243,000

VII, EXPECTED CHANGE IK THE SITUATION SHOULD ACTION BE DELAYED ORMOT TAKEN

If the proposed actions are delayed or not taken, the wastematerial sheen will continue to migrate off-site thereby impactingGladys Creek. Progression of the sheen further downgradient in thelagoons, away from the protective netting, poses a threat tomigratory birds and waterfowl, Unauthorised personnel to theInactive Area could be exposed to high levels of toxic substances,

VIII, OUTSTANDING POLICY ISSUES

There are no outstanding policy issues associated with the Site orthe proposed clean-up.

IX. ENFORCEMENT

See the attached Enforcement Addendum.

000085

002510

X. RECOMMENDATION

This decision document, the selected removal action for theOklahoma Refining Company NPL Site, in Cyril, Caddo County,Oklahoma, is developed in accordance with CERCLA as amended, 42U.S.C §9601 et sea., and is not inconsistent with the NCP, Thisdecision is based on the administrative record for the Site.

Conditions at the Site meet the criteria for the CERCLA section104(c) consistency exemption, 42 U.S.C. §9604, and the NCP section300,415(b)(2) criteria for a removal. Therefore, I recommend yourapproval of an exemption from the 12-month limit to allow theproposed removal action. The total project ceiling, if approved,will be $243,000, Of this, an estimated $135,000 comes from theRegional removal allowance.

APPROVED y ^ ^ W ? ^ / ^ V T W ^ ^ - DATE:

DISAPPROVED , DATE:

10 ' 000086

002511

[LIME SODASTO.RAGE

OKUHOMA

I - SITE MAP

002512

HEALTH EFFECTS OF SIGNIFICANT CONTAMINANTSFOUND AT THE ORC NPL BITS

HazardousSubstance

TargetOrgans Potential Health Effects

Arsenic Central nervoussystem(CNS}Gastroenteritis

Produces severe gastritis leadingto loss of fluids and electro-lytes. Results may includecollapse and death.

BenzeneEthyl-benzeneTolueneXylene(BETXsJ

Bone marrowBloodEyesCNSLiverKidney

All cause CNS depression, Ethyl-decressed alertness, and loss ofconsciuosness. Xylene vapor maycause irratation of eyes, noseand throat- High Xyleneconcentration may cause damage toliver and kidney. Ethylbenzeneis a lacriraator; severelyirratating to the eyes and mucousmembrane.

Chromium LungsKidneys

Most common hazardous effect isfrom inhalation of dust.Exposure to dust from Chromium VImay cause some forms of cancer.

Lead BloodSkinCNSLiverLungsGastrointestinal

Lead is cumulative poison.Symptoms may include anemia andnausea. Longterm eaposure maylead to kidney damage. Very highlevels in blood may effect CNSand decreased mental activity.

Phenols LungsSkinGastr oirvt est ina 1CNS

Skin absorption is the primaryroute of entry. Results mayinclude shock, collapse, coma anddeath. Ingestion of amounts aslittle as 1 gram may be lethal.

Polynuclear Lungsaromatic Skinhydro- Gastrointestinalcarbons(FAHs)

Highly lipophilic and easilyabsorbed through the linings ofrespiratory and gastrointestinaltracts. Several individual PAHsare probable carcinogens.

Attachment 2. ,,,..Health Effects

002513

CONFIDENTIAL DOCUMENT

LOCATED IN A SEPARATE, CONFIDENTIAL FILE

0GGQ39

002514