PROPOSE,D PLAN OF ACTION · 1000 N E 10th St 8th Floor Oklahoma City, Oklahoma 73117 Monday through...

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JL Oklahoma Refining Compam Superfund Site , Cyril, Oklahoma January 31,1992 1 PROPOSE,D PLAN OF ACTION 959112 EPA, OSDH ANNOUNCE PROPOSED PLAN This 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 agency responsible for addressing contamination at the ORC site OSDH is work ing with U S EPA to develop a permanent long term remedy for the site that will protect public health and the environment OSDH and EPA will select a final remedy for the ORCsite after the information submitted dunng the public comment period has been reviewed and considered during the decision 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 Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended in 1986 ] This document summarizes the information that can be found in greater detail in the Remedial Investigation and Feasibility Study (RI/FS) reports and other documents in the Administrative Record File for the ORC site You are encouraged to review these documents in order to gain a more comprehensive understanding of the site and Superfund activities that have been conducted The Administrative Record File is available at the following locations Cyril City Hall 202 W Mam Cyril, OK 73029 Monday through Friday 9am -2pm (405)'464 2411 Oklahoma State Dept of Health Solid Waste Management Service 1000 N E 10th St 8th Floor Oklahoma City, Oklahoma 73117 Monday through Friday 800am -430pm (405) 271-7157 The public is invited to comment on the remedial action alternatives described in the RI/FS report the Proposed Plan of Action, and the Adminis- trative Record File The public comment period begins February 10 1992 and ends March 11 1992 During the public comment penod written comments may be submitted to Mr Donn Walters Community Relations Coordinator US EPA, Region 6 (6H-MC) 1445 Ross Avenue Dallas, Texas 75202 2733 THE PURPOSE OF THIS PROPOSED PLAN ISTO O Identifythepreferredal- ternative to remedy site contamination and ex- plain the reason for the preference, O Describe the other re- medial options consid- ered in detail in the FeasibilityStudyreport, O Sohatpublicreviewand comment on all the al- ternatives descnbed in the Feasibility Study re- port and information contained in theAdrrun- istrative Record File, - O Provide information on how the public can be involved in the rem- edy selection process, and O Provide history and background about the site * Words in bold italics are defined in the Glossary on page 19

Transcript of PROPOSE,D PLAN OF ACTION · 1000 N E 10th St 8th Floor Oklahoma City, Oklahoma 73117 Monday through...

Page 1: PROPOSE,D PLAN OF ACTION · 1000 N E 10th St 8th Floor Oklahoma City, Oklahoma 73117 Monday through Friday 800am -430pm (405) 271-7157 The public is invited to comment on the remedial

JL

Oklahoma Refining CompamSuperfund Site ,Cyril, OklahomaJanuary 31,1992 1

PROPOSE,D PLANOF ACTION959112

EPA, OSDH ANNOUNCE PROPOSED PLANThis Proposed Plan identifies the preferred options for addressing groundwater and soil contamination at the Oklahoma Refining Company (ORC)Superfund site In addition this Plan includes summaries of other alternatives 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 working with U S 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 information submitted dunngthe public comment period has been reviewed and considered during thedecision making process

EPA is issuing this Proposed Plan as part of its public participation responsibilities under the Superfund law [Section 117(a) of the ComprehensiveEnvironmental Response Compensation and Liability Act (CERCLA) asamended in 1986 ] 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 isavailable at the following locations

Cyril City Hall202 W MamCyril, 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 Friday800am - 4 3 0 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 andends March 11 1992 During the public comment penod written commentsmay be submitted to

Mr Donn WaltersCommunity Relations Coordinator

US EPA, Region 6 (6H-MC)1445 Ross Avenue

Dallas, Texas 75202 2733

THE PURPOSE OFTHIS PROPOSEDPLAN IS TO

O Identifythepreferredal-ternative to remedy sitecontamination and ex-plain the reason for thepreference,

O Describe the other re-medial options consid-ered in detail in theFeasibilityStudyreport,

O Sohatpublicreviewandcomment on all the al-ternatives descnbed inthe Feasibility Study re-port and informationcontained in theAdrrun-istrative Record File, -

O Provide informationon how the public canbe involved in the rem-edy selection process,and

O Provide history andbackground about thesite

* Words in bold italics are defined in theGlossary on page 19

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An open house is scheduled for February 6 1992 at theSenior Citizen Building 201 W Ohio, Cyril, OklahomaCome by between 5pm and 7 30 p m to informallydiscuss the Proposed Plan of Action and other alternatives with OSDH and EPA officials

Additionally oral comments will be accepted at a pubhe meeting on February 20 1992 at 7pm at the SeniorCitizen Building Cyril Oklahoma OSDH and EPAwill respond to all comments in a document called aResponsiveness Summary The Responsiveness Sum-mary 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 thepublic in the information repositories The Record ofDecision explains the final remedy selected to correctcontamination problems and to protect the publicshealth at a Superfund site The final remedy could be

Jdif f erent from the preferred alternative depending uponnew 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 ofCyril to the west US 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 declaredbankruptcy and shut down operations

In 1986 the bankruptcy court allowed ORC to abandonthe 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 abandoned which included the refinery process area withthe intention of reactivating the refinery In August1991 Caymen Resources Corporation purchased theCynl Petrochemical Refinery with the intention of re-opening the refinery to refine crude oil into variousproducts

REGULATORY HISTORY

Prior to the 1970 s there were few environmental regu-lations to prevent pollution The state ControlledIndustrial Waste Act and the federal Resource Conser-vationandRecoveryAct(RCRA)passedml976,\)roughthazardous wastes under the regulatory authority ofOSDH and the EPA respectively In 1974 the EPAissued a National Pollutant Discharge Elimination Systern 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 Oklahoma Water Resources Board (OWRB) issued a letterrequinng ORC to correct various discharge violationsIn 1984 the OSDH issued an order to ORC for correctiveaction of RCRA violations which included inadequateclosure plans failure to sample soil in the land treatmentarea and failure to adequately sample groundwater inthe land treatment area In 1984 ORC conducted aninvestigation of contamination problems on the siteShortly after this investigation was completed, ORCwent bankrupt and abandoned the site

In 1986 the EPA investigated the ORC site for possibleinclusion in the Superfund program Their investigation confirmed previous findings that showedhydrocarbons and elevated levels of heavy metals in thegroundwater and soils at the site Based on this mvestigation and data obtained from the 1984 ORCinvestigation the ORC site was placed on the SuperfundNational Priorities List (NPL) in June 1988

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 perform 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 contammants were primarily petroleum related organicchemicals and heavy metals Benzene ethylbenzenephenol methyl phenol toluene naphthalene and 2methyl naphthalene were commonly found organiccontaminants Lead chromium and arsenic were commonly found heavy metals

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The groundwater in the uppermost aquifer the RushSprings Sandstone Aquifer was found to contain contaminants similar to those found in surface impoundmentsediments A large area which encompasses part of therefinery and the abandoned portion of the site wasfound to have light non-aqueous phase liquid (LNAPL)floating on the groundwater The LNAPL is composedmostly of gasoline and is contributing to the groundwa-ter and surface water contamination

The Rush Springs Sandstone Aquifer is an importantdrinking water source for the Cyril area The extent ofcontamination in the aquifer is limited to the area underthe ORC site and extends north to the northern tributaryof Gladys Creek There is no one currently using thecontaminated groundwater as a drinking water source

The Rush Springs Sandstone Aquifer is approximately250 feet thick The groundwater was found to be contammated with acidic and caustic wastes from several

_wastesourcepits in two separateareas Groundwater inthese areas was found to have either a very low pH(acidic) or a very high pH (caustic) This groundwaterhas visible seeps along the bank of Gladys Creek and haskilled all plant life in these areas

Groundwater contamination was found only in theuppermost 30 feet of the aquifer and primarily in theuppermost 10 feet RI field work results showed thatgroundwater and contaminant movement in the RushSprings Sandstone Aquifer beneath the ORC site movesto the south and southeast toward Gladys Creek and itstributaries Groundwater flow is moving perpendicularto the creeks at an estimated rate of 11 feet per year Thecontaminated groundwater was found to be movingupward as well as horizontally and is being dischargedinto Gladys Creek and its tributaries Groundwatercontamination cannot migrate beyond the creeks because the contaminated groundwater flow is opposedby uncontammated groundwater flow on the other sideof 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 migrateupgradient against the groundwater flow Thus thecreeks form hydrological barriers that prevent the lateral 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

sediments in Gladys Creek and its tributaries containedvery low levels of petroleum related organic chemicalsand heavy metals

A study conducted during the Rljield work whichfocused on benthic macroinvertebrates (crayfish, bloodworms etc) m Gladys Creek indicated a decrease inmacromvertebrate species diversity and population inareas immediately below the acid and caustic leachateareas The study concluded that a negative impact tomacromvertebrates in Gladys Creek has occurred inthese areas A fish population study in ponds on GladysCreek indicated a diverse and physically healthy population and did not find evidence of negative impact tofish from the ORC site

Air sampling for volatile organic compounds and heavymetals was conducted near waste sources and on theperimeter of the ORC site to determine concentrations ofairborne contaminants that may be leaving the site Airsamples showed extremely lowlevels of volatile organiccompounds

SUMMARY OF SITE RISKS

Based on the information gathered during the RI fieldwork a baseline nsk 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 placeThe risk associated""with both carcinogenic andnon-carcinogenic effects was assessed

Carcinogenic risks are estimated as the probability of anindividual developing cancer dunng his or her lifetimeas a result of exposure to a potential carcinogen Forexample, a 1 in 1 million excess lifetime cancer riskmeans that for every one million people exposed to thecarcmogen(s) throughout their Lifetimes the averageincidence of cancer is increased by one extra cancer caseThe baseline nsk assessment considered an acceptablecarcinogenic risk to be any nsk less than 5 in 1 millionexcess cancer incidences The National Oil and Haz-ardous Substances Pollution Contingency Plan (NCP)states that for known or suspected carcinogens acceptable exposure levels represent an excess lifetime cancerrisk to an individual of between 1 in 10 thousand and1 in 1 million The acceptable risk range established

by the NCP will be used for the Proposed Plan andRecord of Decision

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The level of concern for non-carcinogenic contaminantsis determined by calculating a hazard index If thehazard index exceeds one (1), there may be concern forpotential non-cancer effects

Four exposure scenanos were developed during thebaseline risk assessment

The first exposure scenario the current off-site resident was developed to depict a person currently livingoff 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 0 08which 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 water 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 hshed by the NCP for 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 of 30 years Thecarcinogenic risk for the acute exposure scenario wasfound to be 8 in 10 million and for the chronic exposure scenario was found to be 9 in 1 million both ofwhich are within the acceptable range established by theNCP for carcinogens * The noncarcmogenic hazard index for acute exposure was 0 3 which is below thelevel of concern The non-carcinogenic hazard index forchronic exposure was -1 2 which is only slightly abovethe level of concern for potential non-carcinogenic effects r

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 groundwater as a pnmary source of drinking water This exposure scenario is considered as thereasonable maximum exposure for the developmentand selection of appropriate alternatives for site

remediation It was assumed that the future potentialon site resident would come into contact with all media The carcinogenic risk was found to.be 2 in 1thousand which is not within the acceptable rangeestablished by the NCP for carcinogens The non-carcinogemc hazard index was' 87 which warrants concernabout potential non-cancer effects

FEASIBILITY STUDY

The OSDH contracted with Bechtel EnvironmentalInc to perform a Feasibility Study (FS) for the ORC siteThe FS used information gained dunng the RI to develop 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 correspends to a regulatory level where applicable or to a 1in 1 million excess lifetime cancer risk RAOs weredeveloped for sediments surfacesoils subsurface soilssurface water and groundwater assuming that the sitecould be used as a residential setting and people couldaccidentally or intentionally ingest contaminants (thepotential on site resident scenario) Groundwater protection RAOs were also developed for soils andsediments to address the potential for these media toact as a continuing source of groundwater contammation through leaching RAOs were developed for 35chemicals of concern found at the ORC site The RAOsdeveloped for some of the most prevalent contaminantsat the ORC site are as follows

SEDIMENT AND SURFACE SOIL RAOS

* -

Benzene22 ppm for human health mgestion protection0 2 ppm for groundwater protection due to leaching

2 Methyl naphthalene1 080 ppm for human health mgestion protection510 ppm for groundwater protection due to leaching

Lead600 ppm for human health mgestion protection865 ppm for groundwater protection due to leaching

Chromium1 350 ppm for human health mgestion protection770 ppm for groundwater protection due to leaching

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GROUNDWATER AND SURFACE WATER RAOs

Benzene0 005 ppm for human health ingestion protection

2 Methyl naphthalene ''015 ppm for human health ingestion protection

Lead0 015 ppm for human health ingestion protection

s

Chromium010 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 fromnumerous technologies that could potentially remediate

- the ORC site

SUMMARY OF ALTERNATIVES

The descriptions and evaluations of remedial actionalternatives are separated into six alternatives addressmg 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 alternativesa~nd the associated group numbers associated with eachalternative

Common Elements All of the alternatives, with theexception of Alternative I have the following commonelements site preparation the installation of officestorage and security facilities the installation of surfacewater runoff control measures, installation and mamtenance of warning signs and fencing placement of a

,- notice to the property deed warning of site hazards andthe restoration of the site surface upon completion of theremedial action

All of the alternatives with the exception of Alternative1 involve containing or treating soils and sediments

which have contaminant concentrations that exceedRAOs

All of the alternatives with the exception of Alternativen 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

.-1 *S

ter

Alternative I (No Action)

- Capital Cost Not ApplicableOperation and Maintenance Cost $5 000 every

five yearsPresent Worth $15000Implementation Time Not Applicable

Alternative I is a no action alternative for contaminated sediments surface soils and surface water andconsists of reviewing the status of the ORC site everyfive years As required by CERCLA a no action alternative was included as a basis for evaluating otheralternatives

Alternative II (Limited Action)

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

Alternative II 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 site surface water and covering allcontaminated sediment and surface soil areas with soil

-and vegetation

Alternative III (Containment, Neutralization andBiotreatment)

Capital Cost $9369000Annual Operation and Maintenance Cost $114 000Present Worth $10978 000Implementation Time 24 months

Alternative HI consists of containing 86,020 cubic yardsof sediments and surface soils m-place by the use of lowpermeability caps (groups! 3 4 6 10 11,12 14andl5) -Another 33 861 cubic yards of contaminated sediments

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and surface soils that contain contaminants that are notexpected to leach into groundwater would be con-tained m place by placing soil and vegetation over them(groupsS 9,13 16andl8) A total of 51,184 cubic yards

- of low pH sediments would be treated by neutraliza-tion (group 8) Through bwtreatment approximately90 95% of the organic contaminants in a total of 17 894cubic yards of contaminated sediments and surfacesoils would be treated and permanently destroyed andthe residuals would be stabilized and capped (groupsland 17)

Alternative IV (In-situ Stabilization, Neutralizationand Biotreatment)

r

Capital Cost $19952000Annual Operation and Maintenance Cost $120 000Present Worth $21 545 000Implementation Time 24 months

Alternative IV consists of treating sediments and sur-face soils using various methods A total of 33 861 cubicyards of waste that are not expected to leach contaminants into groundwater would be covered with soiland vegetation (groups 5 9 13,16 and 18) A total of8 852 cubic yards of waste would 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)

Alternative V (In-situ Stabilization, Recycling,Neutralization and Biotreatment)

Capital Cost $22302000" Annual Operation and Maintenance Cost $132000

Present Worth $24 044 000 "Implementation Time 24 months

Alternative V consists of treating sediments and surface soils using various methdds 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 stabilized in situ and capped (groups3 6 and 15) A total of 10 208 cubic yards of asphaltwould be recycled (group 9) and 51184 cubic yards oflow pH sediments would be neutralized (group 8)

jatrrtePrepared bed biotreatment or in-situ biotreatment wouldpermanently destroy approximately 90 95% of the or-ganics in a total of 107 630 cubic yards of contaminatedsediments and surface soils (groups 1,2 4 10,11 12 1314 16 17 and 18) The biotreated residuals that containinorganics above RAOs would be stabilized and thencapped

Alternative VI (In-situ Stabilization, Recycling,Neutralization and LTTD Treatment)

Capital Cost $51 840 000Annual Operation and Maintenance Cost $103 000Present Worth $52645000Implementation Time 20 months

Alternative VI consists of treating sediments and surface 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 vegetation (group 5) A total of 8 852 cubic yards of wastewould be stabilized in situ and capped (groups 3 6 and15) A total of 10 208 cubic yards of asphalt would berecycled (group 9) and 51 184 cubic yards of low pHsediments would be neutralized (group 8) The organics in a total of 107630 cubic yards of contaminatedsediments and surface soils would be removed throughthe use of low temperature thermal Absorption (groups1, 2 4,10 11,12 13 14,16 17 and 18) The residualswould be stabilized and then placed in an on site landfill 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 addressing the contammation of sediments and surface soils at the ORC Superfundsite is Alternative V (In situ Stabilization RecyclingNeutralization and Biotreatment) Based on new mformation or public comments the EPA and OSDH maymodify the preferred alternative or select another remedialaction presented in this Proposed Plan and the FS reportTherefore, the public is encouraged to review and comment on all of the alternatives identified in this ProposedPlan

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 criteria )

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1 Overall Protection of Human Health and theEnvironment

Except for Alternative I all of the alternatives provideoverall protection of human health Except for Alternatives I and n 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 protection of human health and the environment Under theno action alternative, all of the current and future potential risks to human health and the environment associatedwith the ORC site would remain the same

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

Alternative HI would provide more protection of thegroundwater than Alternative n since a low permeability cap would be used to contain waste sources andthose materials that are in direct contact with the groundwater would be excavated and treated Alternative HIwould reduce both the potential for direct human contact with wastes and the'potential for future groundwatercontamination

Additional protection of human health 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 destroy organics through biological treatment andAlternative VI would remove organics through lowtemperature 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 respectivelyTherefore Alternatives IV through VI are more protective of groundwater than Alternative III and are moreprotective of human health than Alternative HI

Alternative V may be slightly more protective thanAlternative IV in the long term All wastes that exceed

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 couldpose 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 v

2 Compliance with Applicable or Relevant andAppropriate Requirements (ARARs)

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 closure of hazardous waste units

The RCRA Land Disposal Restrictions (LDRs) are applicable to Alternatives HI 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 IH 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 thet covering and contamment 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 IE should provideadequate and reliable control for the protection of human health and the environment

f

Alternatives V and VI provide the most long term effective and permanent remedies, since each of them treatall of the contaminated sediments and surface soils that

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are above RAOs The risk to human health and theenvironment from the covered wastes and the treatedresiduals would be negligible These alternatives provide an effective and permanent remedy for thecontaminated sediments and surface soils

4 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 II through VI would eliminate the mobility, toxicity and volume of surface water since on sitesurface water would be removed and treated

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

Alternatives III through VI would reduce the toxicityand mobility of the contaminated sediments and sur-face soils through the use of treatment Alternative IEwould 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 orgamcswould 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 mobility would be reduced through containment

5 Short-term Effectiveness

Alternative I would pose no short term risk to on siteworkers 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 HI through VI involve excavation material handling and treatment which could pose a slightrisk to on site workers or the surrounding communityThese activities have the potential to generate dust andvapors and for the thermal treatment process airemissions 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

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

6 Implementability

Alternative I through V could be readily implementedAlternative VI could 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 I II IE and IV have a lowerpresent worth of $15 000 $1 918 000 $10 978 000 and$21 545 000 respectively Alternative VI has a higherpresent worth of $52 645 000

8 State Acceptance

OSDH is in agreement with the selection of AlternativeV as the preferred remedy for the contaminated sediments and surface soils at the ORC Superfund siteHowever the final determination of State acceptance ofthis alternative will not be made until public commentshave been received and evaluated

9 Community Acceptance

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

GROUNDWATER REMEDIAL ACTIONALTERNATIVES,

Six comprehensive remedial action alternatives weredeveloped to address contaminated groundwater assuming surface soil and sediment contamination sourceswould be remediated After remediation contaminants in these soils and sediments would be reduced tolevels which would not be expected to leach and wouldnot cause further contamination of the groundwaterSee Table 2 for the remedial action alternatives forgroundwater

The shallow groundwater beneath the ORC Site has ahydrocarbon layer floating on it This hydrocarbonlayer which is called a light non aqueous phase liquidor LNAPL, is primarily the result of petroleum hydrocarbons which leaked or spilled from refinery process

8

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and storage facilities Some of the LNAPL plume hasfloated on top of the groundwater and has moved withthe water into waste source contaminated areas whichcontain CERCLA hazardous substances Leachate fromthese hazardous waste sources has mixed with theLNAPL in these areas

Under current CERCLA authority groundwater contammated by only petroleum hydrocarbon productcannot be addressed due to the petroleum exclusionGroundwater contaminated with petroleum hydrocarbon product that is commingled with a CERCLAhazardous 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 ORC site is commingled withhazardous substances Because of the petroleum exclu-sion under CERCLA the plume beneath the refineryportion of the site cannot be addressed as part of theSuperfund remedial action

Because the groundwater beneath the refinery processarea is primarily contaminated by petroleum hydrocarbons while the LNAPL plume and groundwater inother portions of the site are contaminated by a mixtureof petroleum hydrocarbons and leachate from hazardous waste sources two separate alternatives forcontainment and in situ 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 contaminatedgroundwater are prohibited under CERCLA authoritybut the alternatives which remediate only the portion ofthe aquifer commingled with hazardous waste can beaddressed by CERCLA authority

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 prepaiation and the installation of officestorage, and security facilities plugging existing wells

which are suspected to be conduits for contaminantmigration installation and maintenance of warningsigns and fencing placement of a notice to the propertydeed warning of site hazards and groundwater momtoring

All of the alternatives, with the exception of Alternatives I and II, involve containing or treating groundwaterwhich has contaminant concentrations that exceed RAOsThe 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

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 $15000Implementation Time Not Applicable

Groundwater Alternative I is the no action alternativeand consists of reviewing the status of the ORC siteevery five years Itprovidesabasehneagainst which theother alternatives can be compared Groundwater Alternative I would not pro videany measure of protectionfor the environment since contaminated groundwaterwould be allowed to migrate into the surface waters ofGladys Creek and its tributaries Based on the results ofthe baseline risk assessment this alternative would notprovide overall protection of human health for a futurepotential on site resident This risk would only berealized if a groundwater well is actually drilled on siteand is used for a drinking water source This alternativedoes not comply with all ARARs since the MaximumContaminant Levels (MCLs) for contaminants in a potential source of drinking water will not be met

Groundwater Alternative II (Limited Action)

Capital Cost $84000Annual Operation and Maintenance Cost $94 000Present Worth $1 540 000Implementation Time 1 month

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LIMITS OF ORCSUPERFUND SITE

~l

OLD£ K I CAUSTIC

I STORAGE

^ ^~ P1TS

\ %!\ Zt*

//i &\

/

/

BOUNDARY LINE,// SEPARATING THE f

// ABANDONED iM .PROPERTY _

AND CYRILETROCHEMICAL CO H 11\ . Ml tt PUM

UPITS fl2'

IME SODASTORAGE

PIT

PROCESS SEWER

IVlooo PETROCHEMlC/lL LANDTREATMENT

AREA(SOL FARM)

CASOUNE |O\TANKS l|\ !

Vmm,

_

WS&

\L- — — — ~H — — \ — _T~_I~_T"

III III 1

i C IT Y il i 0 F i__ ! ! 'I' is rh rn r

i l l - M i iMi Mi i

r" ri "iC Y Ri

hi. !

-iii — oMI

iLliMi

-rtr - :ihih

OKLAHOMACITY

O• CYRIL

LEGEND

WASTE StMCCTS

WHCH EXCEED RAO'S

SURFACE SOLS

WHCH EXCEED RAO'S

FIGURE 1

OKLAHOMA REFINING COMPANYSUPERFUND SITE

LOCATION MAP OFAREAS WHICH EXCEED

REMEDIAL ACTION OBJECTIVES

10 11

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Groundwater Alternative II provides no extraction orcontainment of ground water It consists of maintainingthe fence and warning signs around the site and perma-nently affixing a warning notice to the property deedThe existing on site wells which are conduits for migra-tion of contamination would be plugged

Groundwater Alternative III (Containment, EntireLNAPL Plume Removal and In-sltu BioremediatlonEnhancement of Rush Springs Sandstone Aquifer)

Capital Cost $3935000Annual Operation and Maintenance Cost $315 000Present Worth $8786,000Implementation Time 30 years

Groundwater Alternative HI was designed to preventcontaminated groundwater from discharging into thecreek systems and migrating off site by the use of aninterceptor well system located near the downgradientborders of the site The extracted water would be treatedon-site Nutnents and oxygen may be added to thetreated water which would be injected into contami-nated portions of the Rush Springs Sandstone Aquiferto enhance in situ bioremediahon 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 Alternative IV (Containment, Recov-ery of LNAPL Commingled with Hazardous Wasteand In situ Bioremediatlon Enhancement of theRush Springs Sandstone Aquifer)

Capital Cost $3155000Annual 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 LNAPLplume and groundwater areas to be remediated aredifferent Groundwater Alternative IV will onlyremediate the portion of LNAPL and groundwater con-taminated with hazardous substances that can beremediated under CERCLA authority This alternativewould prevent contaminated groundwater from discharging into the creek systems and migrating off siteby the use of an interceptor well system near thedowngradient borders of the site The extracted water

would be treated on site Nutrients and oxygen may beadded to the treated water, which would be injected intohazardous waste contaminated portions of the RushSprings Sandstone Aquifer to enhance in-situbioremedianon A portion of the LNAPL plume, whichis a significant source of contamination to the groundwater, would be removed with an extraction well systemand recycled

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

Capital Cost $11147000Annual Operation and Maintenance Cost $727 000Present Worth $22339,000Implementation 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)

Capital Cost $6986,000Annual Operation and Maintenance Cost $493 000Present Worth $14576000Implementation 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 Groundwater 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

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INDVEVALUATION OF GROUNDWATERREMEDIAL ACTION ALTERNATIVES ANDTHE PREFERRED ALTERNATIVE

The preferred alternative for addressing the contammation of 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 reportTherefore the public is encouraged to review and comment on all of the alternatives identified in this ProposedPlan

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 Overall Protection of Human Health and theEnvironment

Overall protection of public health and the environmentis provided by all of the groundwater alternatives except 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 watersupply Each of the other alternatives would protect theenvironment by preventing ground water discharge intothe 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 alternatives will meet all ARARs except the National Primaryand Secondary Drinking Water Regulations and theHealth Based Standards All groundwater alternativesexcept the no action and the limited action alternativeswould 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 Alternatives III and IV are expected to lower groundwatercontaminant 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 yearsHowever this goal is probably not achievable due to thelarge amount of clays m the subsurface at the ORC Sitewhich contain contamination It has been found atmany other Superfund sites with similar contaminantsand geologic situations that aquifer clean-up 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 enormous volume of soil that would require remediation

As in Groundwater Alternative V the goal of Ground-water Alternative VI is to lower contaminant levels tomeet RAOs within ten years However this goal is evenless achievable than in Groundwater Alternative V Notonly does the contaminated subsurface clay problemexist but also a significant contamination source (theLNAPL plume not commingled with hazardous waste)and petroleum contaminated groundwater are locatedhydraulically upgradient of the hazardous waste contammated area and would not be remediated Thisupgradient contamination would continue to migrateand recontammate the area of remediation Unless thispetroleum contamination upgradient of the hazardouswaste contamination is remediated it is unlikely thatthis alternative would achieve its remediation goal

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 environment These alternativeswould not prevent the migration of contaminatedgroundwater into the creeks or prevent the degradationof the creek environment

Alternatives III through VI would provide a long termeffective solution for the protection of human healthand the environment Institutional controls such aswarning signs property deed notices and fences wouldbe used to prevent the contaminated groundwater frombeing utilized as a dnnking water source The containment well system used for Alternatives III and IV andthe recovery well systems used for Alternatives V andVI would 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

13

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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 currentgroundwater remediation technologies. However, the.in-situ .bioremediation treatment utilized by Alterha-

" lives HI 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 Toxicity, Mobility, or Volume of theContaminants Through Treatment -

All of the alternatives except the no action and limitedaction alternatives would reduce the toxicity, mobilityor volume of contamination through treatment. Alter-"natives HI and IV utilize in-siru biotreatment to lower

V • . ' ^

organic contaminant concentrations in the contami-nated aquifer and utilize pump and treat technology at

. the dbwngradierit borders, of the site. Alternatives Vand VI utilize pump and treat technology throughoutthe contaminated aquifer. Therefore, Alternatives IHthrough VI meet- the. statutory preference -for using,treatment a s a principal element. ' " ' , ' •

5. Short-term [Effectiveness

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

Alternative n poses no short-term risk to the surround-ing community but could pose a short-term risk-toon-site workers during the'plugging of existing wells.

Alternatives in 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 duringgroundwater remediation by maintaining strict con-.trols on treatment processes arid waste streams. A

• contingency 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 Administration' requirements which will be outlined in a worker health

and safety plan.. . . ,

6. Implementability ;'\ :

The no action alternative requires no implementation.Alternative II is readily implementable with local,re--

; sources. Alternatives.HI through VI incorporate proventechnologies, arid vendors providing these systems arereadily available. Alternatives HI 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 determine. .

- the best implementation of the groundwater extractionand treatment systems. Alternatives HI arid IV wouldrequire 30 years of implementation. Alternatives V andVI wo'uld require 10 years of implementation. '

7. post: ,..;• ;,' ;'.•: ,.

The .present worth cost of the. preferred alternative is ;. $7,668,000. Alternatives I and n are lower in present •worthcostat$15,000and$i,540,00drespectiyely. Alter- .natives.IH, 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 ORC;Superfund site. However, the final determination ofState acceptance of this alternative will not be madeuntil public comments have been received and evalu-ated. ' ... '. . . , ' - • . '_ , . - ' .'.- s.

9:, Community Acceptance . ' < • - . ,

Community comment will be an important factor in thefinal evaluation of the remedial alternatives^ :

SUMMARY OF THE PREFERRED /REMEDIAL ALTERNATIVES

Sediments and Surface Soils /

The selection of Alternative V as the preferred alterna-tiye 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 III has beeneliminated because the majority of wastes will not be vtreated but will be contained beneath low permeability•caps. 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 IV ~has been eliminated because it does not treat all wastes

-that exceed RAOs. It-treats all waste that-has the

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potential to leach contaminants to groundwater but itleaves 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

In summary based on the information currently avail-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 surface soils Since all contaminated sediments and surfacesoils above RAOs will undergo treatment the long termeffectiveness and permanence of this alternative is excellent There are not expected to be any unmanageableshort term risks associated with this alternative and thisalternative complies with all ARARs Alternative Vutihzes^permanent solutions and alternative treatmenttechnologies to the maximum extent practicable andwill be cost effective The preferred alternative will alsosatisfy the preference for treatment as a principal element Therefore AlternativeVprovidesthebestbalanceamong alternatives with respect to the criteria used toevaluate remedies

Groundwater

The selection of Alternative IV as the preferred alterna-tive for groundwater 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 in and V have beeneliminated from further consideration because thesealternatives are prohibited under current CERCLA authonty since they include remediating a portion of thegroundwater which has only been contaminated bypetroleurriproduct Alternative IV reduces contammation through 30 years of in situ bioremediationAlternative VI reduces contamination through 10 yearsof pump and treat technology It is difficult to predictwhich of these alternatives would be more successful inrestoring the aquifer Both these alternatives containand prevent migration of contamination from the siteHowever Alternative IV achieves containment of contaminated groundwater and possible aquifer restorationwith a much lower total cost

In summary, Alternative IV the preferred groundwateralternative is believed to provide the best balance amongalternatives with respect to the criteria used to evaluate

remedies Based on the information currently availableEPA and OSDH believe the preferred alternative provides 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 treatmentas a principal element

FOR MORE INFORMATION

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

Lisa Lyhane, Project ManagerOSDH - Superfund Program

1000 N E 10th StOklahoma City, OK 73117-1299

(405) 271-7157

- Noel Bennett, P E, Remedial Project ManagerU S EPA (6H SR)1445 Ross Avenue

Dallas, TX 75202-2733 (214) 655 6715

1 800-533 3508 (Toll free)

Donn Walters, 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 MeachamorDaveBary EPA Region 6 Press Officers at (214) 6552200

0 - If you plan to attend the public meeting onA——s. February 20 1992 and need special assistanceV_V^ because of physical limitations or visual orhearing impairments call Donn Walters before February 14 at (214) 655 2240

This Proposed Plan is printedon recycled paper with

ink free of cadmium and lead

15

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Figure 2AREA OF GROUNDWATER AND LNAPL

REMEDIATION FORl ALTERNATIVES IV & VI

LEGEND

GROUND TCI)REtCUATON ARE

INAPlREtCMATOH ARE

Figure 3 >AREA OF GROUNDWATER AND LNAPL

REMEDIATION FOR1 ALTERNATIVES III & V

LEGEND

GROUNOW CRREkCDIATCN ARC

1.HAPV.RChCCXATCN ARE

N

16

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TABLE 2

REMEDIAL ACTION ALTERNATIVES FOR GROUNDWATERFEASIBILITY STUDY

OKLAHOMA REFINING COMPANY SUPERFUND SITECYRIL, OKLAHOMA

Response Actions

^

Access Restrictions

Plug existing wells

Recovery of entire LNAPL plume

Recovery of LNAPL plumecommingled with hazardous waste

Groundwater monitonng

Groundwater extraction wells siteboundary system

Groundwater extraction wellsentire aquifer contaminated byORC

Groundwater extraction wellsRSS aquifer commingled withhazardous waste

Water treatment

Injection of treated groundwater

Alternative INo Action

Alternative IILimited Action

*

*

*

<f

Alternative IIIContainment,

Entire LNAPLPlume Removal,

In SituBioremediationEnhancement of

RSS Aquifer

*

*

*

*

*

*

*

Alternative IVContainment,Recovery of

LNAPLCommingled withHazardous Waste,

In SituBioremediationEnhancement of

RSS Aquifer

*

*

*

*

*

*

*

Alternative VActive

Restoration ofRush Springs

SandstoneAquifer

*

*

*

*

*

*

*

Alternative VIActive

Restoration ofRSS AquiferCommingled

with HazardousWaste

*

*

*

*

*

*

*

* Response action appropriate to this alternative

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TABLE 1 J'

REMEDIAL ACTION ALTERNATIVES FOR SEDIMENTS AND SURFACE SOILSFEASIBILITY STUDY

OKLAHOMA REFINING COMPANY SUPERFUND SITECYRIL, OKLAHOMA

Response Actions * l

(1) No actionf

(2) Limited action

(3) Containment (low permeability cap)

(4) In situ stabilization with cap

(5) Excavate/recycle

(6) In situ biotreatment

(7) Excavate/neutralize/disposal in area of origin

(8) Excavate/prepared bed biotreatment and/or ^stabilize/cap

(9) Excavate/LTTD treatment and/orstabilize/disposal in Subtitle C landfill

AlternativeI

all groups

t

AlternativeII

all groups

AlternativeIH

7

5 9 13 1618

2 3 4 6 1011121415

>

8

117>

/

AlternativeIV

7

5 9 13 1618

3615<.

4

8

1 2 10 1112 14 17

i

AlternativeV

7

5 ,

3615

9

4

8

121011 '12 13 14 16,1718

AlternativeVI

7

5

3615

9

8

12410,1112 13 1416 17,18

00

Note Applicable group numbers are shown in each box under each alternativegroup numbers

Group 1 Sludge Traps 1 7 Process Sewer SedimentsGroup 2. Oil Skimmer Ponds 1 and 2Group 3 Asphalt Pit 1Group 4 North Ponds 1 and 2 Asphalt Flow AreaGroup 5 North Ponds 3 4 5 6 and 8 South Ponds 1-8 Oil Skimmer Pond 3Group 6 Old Storage Pits 5 and 7Group 7 Pump Pits 1 and 3Group 8 Buned Acid Pits 1 and 3 iGroup 9 Old Storage Pits 1 2 and 3 Pitch Pits 1 3 and Asphalt Pits 2 and 3 ,

The numbers shown in the boxes correspond to the following

Group 10- Old Storage Pit 4Group 11 pld Caustic Pits 8 and 9 and the Lime Soda Storage PitGroup 12 Slop Oil Ponds 1 and 2 and API separator sedimentsGroup 13 North Pond 7 (

Group 14 Old Storage Pit 6Group 15 Surface soils with inorganics exceeding groundwater protection RAOsGroup 16 Surface soils with organics exceeding health based RAOs 'Group 17 Surface soils associated with phenol spill areasGroup 18 Surface soils with inorganics exceeding health based RAOs

-J-

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GLOSSARY

Air Stripping A process used to transfer volatileorganic compounds from a water stream into anair stream by contacting clean air with contaminated water usually in a column

Ambient Air The surrounding air

ApphcableorRelevantand Appropriate Require-ments (ARARs) ARARs are the federal and staterequirements that a remedial alternative must meetARARs are one of nine criteria used to evaluateremedial alternatives for a site

Baseline 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 mi-croorganisms 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 to 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 constru cting low permeability or hydrauhe barriers for liquids

Feasibility 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

Filtering 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 acceptability or unacceptabihty of exposure to non cancercausing chemicals A hazard index below unity (1)is considered acceptable while a hazard index exceedmg unity may warrant concern for non cancereffects due to exposure

In situ In place

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

r

Low Temperature Thermal Desorption (LTTD)A treatment process which removes volatile andsemi-volatile 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 drinking water sources

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

(Continued on back page)

19

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GLOSSARY (Cont)

National Priorities List (NPL) EPA s list of themost senous 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 from the contaminated portion of an aquiferand then treat it in a water treatment facility

ppm An abbreviation for parts per million whichis a unit commonly used to express low concentrations of contaminants For_example 1 gram of achemical in 1 million grams of water would have aconcentration of 1 ppm

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 combmation of methods designed to protect public healthwelfare and the environment over the long termfrom releases of hazardous substances at a Superfundsite Remedial alternatives are usually a combination 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) Mediaspecific clean up goals for protecting human healthand the environment These goals were determinedin three ways 1) by using levels set by regulatoryagencies 2) by calculating a concentration thatwould not leach from soils and sediments and conlaminate groundwater and 3) by calculating thechemical concentration that would cause a one inone million risk of cancer by exposure throughingestion of the media

Remedial Investigation (Rl) A study which gathers 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 regulatory system to track hazardous wastes from the timeof generation to disposal The law specifies procedures to be used in treating transporting storingand disposing of hazardous wastes

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 indramageways 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 contaminants within the solid wastema tenal are held by strong chemical bonding whichprevents the contaminants from leaching away

Superfund The common name used for the Comprehensive Environmental Response Compensation and Liability Act

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SELECTING A REMEDYU S EPA uses nine criteria or standards to evaluate alternatives for addressing a hazardous waste site The remedy ultimately selected for a site must meet all nine criteria Theyare as follows

1 Overall Protection of Public Health and theEnvironment

This criterion addresses the way in which a potentialremedy would reduce eliminate or control the risksposed by the site to human health and the environment The methods used to achieve an adequate levelof protection may be through engineeringcontrols treatment techniques or othercontrols such as restrictions on thefuture use of the site Total ehmination of nsk is often impossible toachieve However a remedy mustminimize risk to assure that humanhealth and the environment would beprotected

2 Compliance with ARARs

Compliance with ARARs or applicableor relevant and appropriate laws andregulations assures that a selectedremedy will meet all related federalstate and local requirements The re

quirements may specify maximum concentrations ofchemicals that can remain at a site design or performance requirements for treatment technologiesand restrictions that may limit potential remedialactivities at a site because of its location

3 Long Term Effectiveness or Permanence

This criterion addresses the ability ofa potential remedy to reliably protecthuman health and the environmentover time after the remedial goalshave been accomplished

4 Reduction of Toxicity Mobilityor Volume of Contaminants

This criterion assesses how effectively a proposedremedy will address the contaminationproblem Factors considered include thenature of the treatment process theamount of ha/ardous materials that willbe destroyed by the treatment processhow effectively the process reduces the

Calendar

toxicity mobility or volume of waste and the type andquantity of contamination that will remain aftertreatment

5 Short Term Effectiveness

This criterion addresses the time factorTechnologies often require several yearsfor implementation A potential remedy isevaluated for the length of time requiredfor implementation and the potential im

pact on human health and the environment during theremediation

6 Implementability

7 Cost

Implementability addresses the ease withwhich a potential remedy can be put inplace Factors such as availability"of materials and services are considered

Costs (including capital costs required for design and construction and projectedlong term maintenance costs) are considered and compared to the benefitthat will result from implementing the remedy

8 State Acceptance

The state has an opportunity toreview the FS and ProposedPlan and offer comments to

U S EPA A state may agree with oppose or have nocomment on the U S EPA preferred alternative

9 Community Acceptance

During the public comment periodinterested persons or organizationsmay comment on the alternativesU S EPA considers these comments in making its final selectionThe comments are addressed in adocument called a responsiveness summary which ispart of the Record of Decision for the site

FINAL REMEDY

Page 21: PROPOSE,D PLAN OF ACTION · 1000 N E 10th St 8th Floor Oklahoma City, Oklahoma 73117 Monday through Friday 800am -430pm (405) 271-7157 The public is invited to comment on the remedial

COMMENTS

EPA and OSDH would like your comments on the Proposed Plan to remedy soil and groundwatercontamination at the Oklahoma Refining Superfund site Write your comments below (attach additionalsheets if necessary), and mail this form to Donn Walters, U S EPA Region 6 (6H-MC), 1445 Ross Ave,Dallas, Texas, 75202 All significant comments will be addressed in the Responsiveness Summary for thesite If you want to be placed on the ORC site mailing list, include your name and address