c cStanley Engineering, Inc.

ENVIRONMENTAL ENGINEERING

OKLAHOMA REPINING COMPANY

CYRIL, OKLAHOMA

CLOSURE PLAN

Superfund^AdmJnistrativeRecon^D6d^nent

000 I f a f e

R E C E I V E D

NOV 2 5 ^85

®«&%®'^«

NOVEMBER 23. 1985

MM N- MAY SIH'H-.WW OKt-AIIOMA OTY OK/jl l lssSisiSssa^^^&

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c cTABLE OF CONTENTS

PACK

CERTIFICATION -..----———.—————.—————.—————————— 1

SITE LOCATION ,-.———.——————.——.-.—————.——.————— 2

INTRODUCTION ,^—————~-.^w^-»^——,—^—.-^^^-»————— 3

RCRA UNITS -,^—-«—.—.-.-—."———.———.————.«—————- 7

IDENTIFICATION OF UNITS REQUIRING CLOSURE ————————— 8

CLOSURE SCHEDULE —————————————.——-.—————.——.- 9

CLOSURE PLAN BLEMENTS——————.—————"————-"—————10

Overview—-•"—----—--—----"—-•—---—-*-•---•"•---'--"•--"-*•--"• "--10

Soi.l Fami——»ww>-——•-"*"-•—~—^—-•———— — — — — — - . — — - . — — — — — — - - • — - " — llMaximum Inventory of Waste —--—-.-.-——-^————- nDescription,of Closure/P^st Closure Activities—— 11Ground Water Monitoring —-———"-«-.-.—.-—--.--..-.-» 12- ;, fw tn-^-

API Sepax'ator/Slop Oil Tank Bottoms ---——-—-.———--15Maximum Inventory of Wastes —.-.——-----.—.--.»-.-.-.-—.15Description of Closure/Post Closure Activities-—--l5

Leaded Tank Bottoms-"-—-—"--——•——-——--——-------18Maximum Inventory of Wastes -—-.-———--—--—-----isDescription of Closure/Post Closure Activities--—-18

Security Contingency During Closure --.———--------20

CLOSURE COST ESTIMATES-————.———————————————21

Soil Farm Land Treatment Unit ————-.---—.--—^----^21

API Separator/Slop Oil Tank Bottoms-"--—--"------—-23

Leaded Tank Bottoms --.—-—--————-——-—-"—- ----.--.23

Superfund AdministrativeR&cord Document

c cCKRTIFICATIQN

This Is to certify that the Principal of "good engineering and

Industrial hygiene practices" have been applied in the developmentQ£ this Closure Plan. Applicable requirements of 40 CFR 265 and

IfMiated KCRA regulations have been addressed so as to'.a

accomplish closure in a manner which protects adverseImpact on human health and the environment.

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SITE LOCATION

The Oklahoma Refining Company at Cyril Oklahoma ia locked in the

Southeastern part of Caddo County. Ug, ^g .. . ^nd "2"

show this location in respect to the sui -ounding area. Figure

"3" illustrates its location in the town of Cyril. An

aerial view of the actual site's topography is provided

w-th the packet to blueprints provided with these plans.

ouperfund AdministraUveRecord Document

''« i" ^ - ^* ; ^ IS. f . .

Sfe'" •0 0 0 1 6 9

cINTRODUCTION

^—^.^The Oklahoma Refining Company applied for ^Storium^gtfltna

as & generator of hazardous waaf in May of 1081. The facility

A ^ .operatod and gonarated varioua wa<ta» until ontariag^^-V^t^.^

^ba-nkruptcy in October of 1884. BKorta to nddrade ^ha

manftgamant of wastoa in troatm«nt, atorage and disposal

un i t s pre««n6 at the facility hava continued sinco entering

th^ aanlsruptcy period. Thia report outlines the actions

which ORC feels aro appropriate to cloae out uni ts which

contain regulated wa-s^QS in a manner purauant to th®

requirements of 40 CJPH 205 and Qthgr appropriate criteria.

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SCALE 1:24000o

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The Part A application which O . R . C . submitted in May of1981 listed the following units as part of the facility'sWaste Management system; • .

1. Pump Pits2. /Asphat)in Drums3. Slop Oil Ponds4. Caustic Storage Pits5. API and Oil Separation Traps6. Soil Farm Land Treatment Area7. Pitch and Asphalt Pits8. Bio-oxidation Ponds9 . Leaded Gasoline Tank Bottoms

10. Slop Oil Tank Bottoms

The following pages give a summary of the types of Wastesand Process Codes which this application summarized aswastes which were or would be generated at the facility,

STORED WASTE

EPA PROCESSCODE

TREATMENT FACILITIES

SPA HAZARDOUS^ASTE HO.D002

K049

K049

D002

DESCRIPTIONEarthen pits designed to catchseepage migrating to the surfacein the acid leachate area. It isimportant to note that this wastewas pumped to the biolog-ical treatmentponds.

^ >,..*•(Off specification asphalt was storedin drums. It has been delisted.(Letter attached).Temporary slop oil ponds. This isslop oil from miscellaneous process.It is skimmed and recycled through anew slop oil facility. Remainingwater is pumped to pond ^1. T;;ese pxcswere in process^not storage. Useof this pit was discontinued prior to1981.Old storage pits north of causticleachate area. /

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K051 API and oil separator traps. Sludgesfrom both systems have been placed onthe soil farm. Treatment consists ofseparation and skimming.

0 0 0 1 7 5

^ DISPOSAL rACrXJTIES

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1

EPA PROCESS_COrJ£

D81

D83

D83

EPA HAZARDOUSyASTE NO.

NA

K049

NA

DESCRIPTIONThe soil farm is located on 8 . 7acres and is within the S . W .& S . E . quarters of the S . w .quadrant. This facility was inexistance at the time permitswere required> Xt is designatedas a treatment facility to ^receive various waste generatedon the site.Earthen ditch and asphalt pits.Letter received delisting thesematerials.Surface Impoundments or bio-oxidation ponds. North andSouth System.

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IDEKTIFICATION OF UNITS REQUIRING CLOSURE

The Part " A " application filed by ORC was prepared earlyin the RCRA era. The staff who prepared the applicationapparently did not understand the definition of RCRAUnits and the processes at the plant. The result is R long '}list of units most of which should never have been included ^in the application. ^

The following units are identified in these plans as havingbeen actively used to treat, store or dispose of hazardouswaste throughout the facility's operation by ORC.

1. API Separator2. Slop Oil Tanks .t'3. Leaded Gasoline Tanks ^^4. Soil Farm Land Treatment Area.

All remaining units were improperly listed as RCRA regulatedunits. ORC has no records which indicate that listedwastes were handled by these "other" units. In addition,these "other" units have been tested for the presence 01Characteristic Wastes. No evidence has been forth comingwhich would indicate that they contain characteristicwastes in excess of regulatory thresholds set forth in 40

CFR 261.Superfund Administrative

Record Document" ..,!•

000177

c cCLOSURE SCHEDULE

DATESSoil Farm

. _——.-^™f ^ JL Jf •

' - • '"Begin Work on Sita Prdparatton^*'-'"' /. ' ^- .' —Haul Clay Cap " f c *

Placamant of Clay Cap

Placement of Final Cover Material

Contour, Grade for Errosion ControlPlant Grass

/'API Separator/Slop Oil Tanks ^

Begin Work on Site Preparation

Remove & Concentrate Listed Sludge Material

Haul and Dispose of Waste on Soil Farm

Decontaminate Equipment

III Leaded TankBottoms

March 3, 1986 tobe completed by^Sptombar 8, 1036

i '^•/<'"•' l

March 3 , 1986 tobe completed bySeptember 8. 1886

Haul Listed Wastes Consisting of TankBottoms to Approved Disposal SiteDecontaminate equipment

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At End of LifeExpectancy to beCompleted within180 Days.

9

Superfund AdministrativeRecord Document

000178

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l»- -;,-•'CLOSURE PLAN ELEMENTS-.»»t

i?fOverview ..• •" ^——————» ,,' ^

^T

The following plans discuss the closure details pursuant,/to 40 CFR 205 and Identify the closure strategy to be employed

in each element of the plan. Certain portions of the facility

ere still being considered for.usa.in lease agreements presently

being developed. As such, process related units and product

storage units may not be closed but plans are submitted

i J^'^Oto address closure when necessary. The time frame for .(i^* 0f • V '

•- -0closure will necessarily have to exceed 180 days largely •/ , "-''^. — - — — . -.

because of the bankruptcy status which complicates the time '',.///' <«frames necessary for court approved expendaturea of assetts '^/ '

and the size and number of units requiring closure. The

goal of closure is total closure of the existing API Separator and

Slop Oil Tanks and partial closure of the Farm with Poaty^

Closure Monitoring. Leaded gasoline tanks are considered ' . , • " '' ./

still in process by virture of their use in bulk products

storage and transfer. Continued lease of the pipe line and

bulk transfer station necessitate postponment of its closure

unti l the life of the facility expires.

The following plans break up the Closure Plans into individual

sections for each unit.

Superfund AdministrativeRecord Document

c cSOIL FARitf

Maximum Inventory of pastes

Yfoe refinery's land treatment occupies an 8.7 acre tractin the refinery's southwest quadrant. An untold q u a n t i t y

of oil waate sludges, tank. bottoms ruat« and other solids

have been placed on the Soil Farm during the period of OHC's

use. The permit referenced 1,023,000 gallons of waste

intended for processing. The unit operated for about .10% of itsexpected 70 year life expectancy. As such the maximum

inventory of wastes entrained on the treament area isnot expected to be more than 102,300 gallons.

J^ggg^P.^10"- of AlQs^re/post-•C^PSUre Ac t i v,itj,es a t . S o 11 Farm

/-9The Soil Farm will operate and receive one remaining load (/ ' ' |Q

/ f ^ , - ''of sludges from the closure of the API Separator and Slop • ^'

Oil Tank Sludges. This last waste allocation will take placejust prior to the starting date of Closure. The start ing

date for Closure is either March 3, 1985 or 90 days after

receipt of government approval of these plans. The remaining

waste allocation will be applied and tilled weekly for

four weeks then the application of clay cap will commence.

The existing berms present around the site wil l serve to .

protect against r u n o f f . The site has already been graced

and contoured during the past f ive years of operation to

guard against r'-inon and errosion.

ORC will acquire sufficient clay fill material from off-

site locations to cover the soil farm's 8.7 acres to a depth or— -r- " •• '-'*- . /?

•",, ^Tthickness of 2 feet. The coefficient of permeability will "^- /'^.,,.,_-7 ~ ' - - - — — - - -

exceeds 10" cm/sec. Sufficient testing will be submitted 0('" ". .^T '- - ———— /i •vi^ ^s?with Closure Certification to document the quality of theclay seal.

Once the clay seal is in place, a layer of top soil will

be spread on the clay a.nd the site graded to existing

surface contoors. The area will be planted wi th grass

and a six foot chain link fence or equivalent will be

constructed around the soil farm's- p e r m e t e r J 1

Groundwater ^onjto^j.ng

9 The soil farm has had a groundwater monitor ing plan in

effect which was upgraded in October, 1984 to assess groundwater

contamination. Nine additional wells were added. The pre-

existing 2" up-gradieiit and downgradient wells were abandoned.

The soil farm monitoring ivells are shown on the blue-prints

provided with this plan. .i ; *

Superfund AdministrativeRecord Document

00

First stage groundwater clean-up of gasoline contaminationcontinues in response to O . W . R . B . Consent Agreement;wells SFUG-1,2,3,5 and SFDG- 4. This system of productrecovery and clean-up of groundwater contamination willcontinue as long as necessary.

\Post Closure Monitoring of Groundwater will consist of ^-\fi'

monitoring of one upgradient and two down gradient wells

cosen from the network of monitoring wells which were installedto accomplish groundwater assessment.

The following wells will be selected for annual Post-ClosureMonitoring.UPGRADIENT WELLSSFUG-1

POWNGRADIENT WELLS

SFDG-1SFDG-4

Monitoring will be performed in September of each post-closure year

Analysis will be performed for the following parameters.pHSpecific ConductanceT.O.C.T.O.H .PhenolsLeadChromiumArsenicVolatile Organic Hydrocarbons ( i .e . Gasoline Cons t i tuen ts ) .

Superfund Administrative^ord Document

°001S5

cSampling and Analysis will be performed in accordance withguidelines and methods outlined in SW-846 . .) /\ ^.^'-^

Annual groundskeeping will consist of mowing grass andinspection of monitoring wells and fences.

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Superfund AdministrativeRecord Document

, . i 000183

( CAPI SEPARATOR/SLOP OIL TANK_BQTTOMS

Maximum Inventory of Waste

The API Separator Sludges (Waste Code K051) and the Slop

Tank Sludges and Solids (Waste Code K049) were poorly

described and quantified by the facility's Part "A" Application.

The Closure option discussed in these plans are total

Closure by removal of remaining wastes, decontamination of

the units and dismantling or abanding their use after

decontam;nation, The maximum volume of sludges present

in each unit therefore represents the maximum waste inventory.

The combined process design capacity of these units is

288,000 gallons. The expected volume as a result of the

refinery 's moth-ball status is less than half of its maximuminventory or 144,000 gallons." ; ....;.•. •

Description of Closure/Post Closure Activiti esat API Separator and Slop Oil Tanks

Closure of the API Separator will begin by diverting the

inactive sewer f low. This flow presently consists of groundwater

infiltration and occassional storm water r u n o f f . The contents

of the separator will be pumped to the Slop Oil Tanks.

These units ( tanks) will then become the focus of Closureactivities.

••oS©) all the API Separator Sludges are thoroughly removed

by pumping to the fcanks» the concrete and metal separator parts

will be steam cleaned and pressure washed. Cleaning waters will

flow out to the trap for treatment via the NPDES Treatment

System. Once cleaned, the unit will be hurried in place

by back fi l l ing with clay and soils. Then will be graded .<-^ ' " ^

to contours with the adjacent road surface.

Slop Oil Tanks wil l be then full to some extent with a

mixture of their original sludges and API Separator sludges,

These mixtures will be fi l ter pressed. The dry f i l ter cakes ' j ' J

will be applied to the soil farm. Residues of oil produced

will be recycled reclaimed oil . Water fractions will be

tested for waste characteristics in accordance with Subpart

"C" of 40 CFR 261.24. If characterized as toxic waste

they will be hauled to a Controlled Industrial Wastet'. .'--'Disposal Site after on site volume reduction by evaporations ' '

If determined non-hazardous, the water will be released

at a controlled rate to the f ac i l i ty NPDES System. Rates

will be determined by the supervising engineer.

After removal of all sludges and their placement on the,^'soil farm the units and equipment will be triple steam

16

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Superfund AdministrativeRecord Document

OOOJ.8.5.

cleaned. The tanks once certified as clean by the supervisory

engineer, will be dismantled and sold as scrap.

No Post-Closure care is anticipated as a result of

the total removal of wastes and decontamination

Superfund AdministrativeRecord Document

0 0 0 1 8 6

LEADED TANK BOTTOMS

Maximum Inventory of Waste

The leaded tank bottoms consist of t<'-nk bottoms in Tank ^'^

Numbers 21, 25, 66, 118 and 119. These

tanks have always been in process as product storage tanks.

They still hold stored product which is being used in

operation of the bulk transfer station. The Part "A"

Application never specified the annual or process design

capacity for the units waste. Closure vdll only take place

upon expiration of the tanks utility in storage and transfer

of product.

, ^ ^•^^/^/^•/ ' ..

//' , ..;• ^

Description of Closure/Post-Closure Activitiesfor Leaded Tank Bottoms

Leaded Tank Bottoms are listed waste and identified in

40 CFR 261 as K052. The extent to which present Tank

Bottoms and future accumulations may require controlled

disposal upon Closure is indeterminable.

Closure Plans call for the removal of tank sediments by

pumning to a phase separating tank. Recovered Gasoline

will be reclaimed and sold as product. Sludges will be

collected by tank truck and hauled to a disposal facility

which is liscensed to receive this waste.

Superfund AdministrativeRecord Document

0 0 0 1 8 7

ORC presently uses these tanks as part of its tank farm and

bulk transfer operations. The exoected l i fe expectancy is not

able to be calculated but could be 50 to 70 years with proper

maintainance. As a result, closure cost estimates for these ^-/<

^ unxts will have to be secured by appropriate longer term ^•

financial assurance. No Post-Closure care will be requiredas a result of the total removal option. In all likelihood,these units will be transferred to new permits upon eventuallease or purchase of the facility.

„' ^ i :: , '• i.V.-.C,? ...!• • " -

Superfund AdministrativeRecord Document

0 0 0 1 8 S

SECURITY CONTINGENCY DURING CLOSURE

The Refinery is surrounded on three sides by a fence with

locked gates for controlled entrance. Gladys Creek acts

as a natural barrier preventing entrance for the east side.

A security crew guards the site at night and weekends.

These precautions in pombinatio3 with the warning signs ^ - d . ^ ^ ' ^

and warning tape will be suff icient to prevent unauthorized

personnel from entering the area where closure activities

are occurring.

CLOSURE COST ESTIMATES

"O.S.D.H. Regulated Facilities"

The cost for Closure Activities was thoroughly researched

in July 1985 when ORC completed an extensive Environmental

and Hydrogeologic Assessment of the site. Alternatives

outlined in documents submitted to O . S . D . H . in August.

1985 outlined projected Closure Costs based on a determination

of the residual wastes as characteristic wastes in excess of

regulatory thresholds or documentation of receipt of listed

wastes. The cost estimated below reflect the degree of

controlled industrial waste disposal necessary to effect

total or partial closure as optioned for by the owner/operator.

I. Soil Farm Land Treatment Unit

Methods Partial Closure with Post Closure Care.Cost elements for ClosureClay Cap MaterialTop Soil & Cover Material

$ 111,711.0058,000.0021.501.00

Erosion Control and Planting of GrassFencesEngineering and Related Fees.

Cost. JSlements for Post Closure Care

Maintainance of Property and Site Security

Annual Groundwater Monitoring (30 Vears)

9.700.0022.500.00

$ 83,000.0015,,000.0068.000.00

Rational for Estiraate of Soil Farm Closureand Post Closure Care Costs

The closure plans which include cost estimates for the actual

Soil Farm capping and engineering work are basically the

costs associated with manpower, equipment rental and contracted

services to achieve a partial closure of the,.sj..te. Post

Closure costs consist of the overal sites groundwater monitoring

plan.

The Plan consists of one year of quarter monitoring of RCRA

Subpart "P* monitoring parameters related to annual monitoring

thereafter and maintainance of site security, groundwater

monitoring: wells and grounds keeping activities.

Superfund AdministrativeRecord DociiTOnt

0 0 0 1 9 1

II- API Separator Sludges/Slop Oil Tank Bottoms

Method Total Closure by Removal and Decontamination

Closure Cost Elements $ 49,100.00

Removal of Slop Oil Tank -Solids $ 16,500.00

Removal of Separator Sludges Included Above

Quality Assurance Testing//,/ / $ -3,000.00^———————.—• C/^.C —•&•/*. if,,. •••- ' ., . - -

Deeontamination of Structure and Equipment $ 6,800.00

Engineering Fees Associated with Closure $ 22,800.00

t^ost Closure Care Not Applicable

Costs included in General Site Plan andSoil Farm Post Closure Costs

Rational for Closure Costs

The bulk of the costs estimated above consist of removal

costs, labor and equipment costs associated with the Closure

effort. The total removal and decontamination alternative

eliminate post-closure care costs which would otherwise

occur. However, some post closure care is essentially imolied

by t.ie displacement of wastes to the soil farm.

0^0'-• —

000

1 1 X . Leaded Tank Pottoms

Methods Total Closure by Removal and Decontamination

$ 41 .875 .00cost.. gfflg^g^Qy c'losur-e

Con trolled x*idustrial Waste Disposalof Tank Bottoms and Sludges toApproved Disposal Site

Equipment Decontamination

No Post Closure Car^ Required

^5,000.005.875.00

$

Not App l i cab le

Superfund Administrative„ , Record DocutTisrit

c Superfund Administrative(_ Record. Document

0 0 0 1 ^ 3Rational for Closure Cost Estimated

The Leaded Tanks are in process and not expected to be

closed until the bulk transfer terminal , tank farm and other

leased units have reached the end of their l ife expectancy.

SUMMARY OF CLOSURE COSTS

I, SOIL FARM

II . API SEPARATOR/SLOP OIL SLUDGES

I I I . LEADED GASOLINE TANK BOTTOMS

SUMMARY OF POST-CLOSURE COSTS

$ 111,711.00

$ 49.100,00

$ 41.875.00

SOIL FARM POST CLOSURE CARE $ 8^1.000.00

Total Financial Assurance NecessaryFor Closure/Post Closure $ 285,686.00

24Superfund Administrative

Record Document

000^3