RECORD OF DECISION · site") occupies the Southwest Quarter (SW 1/4) of Section 36, Township 12...

RECORD OF DECISION

FOURTH STREET REFINERY SITEOKLAHOMA CITY. OKLAHOMA

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SEPTEMBER 1992

000316

DECLARATIONFOURTH STREET REFINERY SITE

Statutory Preference/or Treatmentas a Principal Element

is Met and Five-Year Review Not Required

SITE NAME AND LOCATION

Fourth Street Refinery SiteOklahoma City, Oklahoma

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action forthe Fourth Street Refinery Site (FSR site), in Oklahoma City,Oklahoma, which was chosen in accordance with the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments andReauthorization Act of 1986 (SARA), and, to the extent practicable,the National Contingency Plan (NC P ) . This decision is based on theAdministrative Record for this site.

The State of Oklahoma agrees with the selected remedy.

ASgEgSMENT OF THE SITE

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response action selectedin this Record of Decision, may present an imminent and substantialendangerment to public health, welfare, or the environment.

DESCRIPTION OF__THE REMEDY

This Record of Decision (ROD) addresses the source of contaminationboth on and off the site, which includes surface sludges,contaminated waters and sediments, and contaminated soil anddebris. This action is the first operable unit for the FSR site.The first operable, unit will also be referred to as the "SourceControl Operable Unit". A second operable unit for the FSR sitewill address ground waters beneath the site in a subsequent Recordof Decision. The second operable unit will be referred to as the"Groundwater Operable Unit".

This Source Control Operable Unit addresses the principal threat atthe site by neutralizing the acidic sludges thereby reducing thepotential for contaminant migration to surface waters and groundwaters. The principal threat at the DER site is posed by directcontact and inhalation, and potential for migration of contaminants

000317

to the ground water. The remedial objectives are to minimizepotential exposure by direct contact or inhalation, and to reducethe potential for migration of contaminants into the surface watersand ground waters. This action also addresses the low level threatat the site by chemically binding the hazardous constituentstogether in a matrix which eliminates potential exposure via thefollowing pathways; inhalation, incidental ingestion, and directcontact.

The major components of the selected remedy include:

• Cleaning, consolidation, demolition as necessary, and salvage crremoval of contaminated equipment and structures on-site, in orderto implement the remedial components specified below;

• Consolidation of off-site and on-site wastes (an estimated volumeof 42,000 cubic yards of contaminated material) onsite;

• On-Site neutralization of the consolidated acidic wastes;

• On-Site stabilization and solidification of waste containinglead;

• Off-site disposal of the treated waste in a landfill permitted toaccept the waste.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements that arelegally applicable or relevant and appropriate fco the remedialaction, and is cost-effective. This remedy utilizes permanentsolutions and alternative treatment technologies to the maximumextent practicable and satisfies the statutory preference forremedies that employ treatment that reduces toxicity, nobility, orvolume as a principal element*

Because this remedy will not result in hazardous substancesremaining on site above haalth-based levels, no review will heconducted within five years after commencement of remedial actionto ensure that the remedy continues to provide adequate protectionof public health, welfare, and the environment.

L^4AC -i<^B , " J . WynneRegional AdministratorHog ion 6

Date

000318

CONCURRENCE UOCUMENTATION

FOR THE

FOURTH STREET RECORD OF DECISION

' / r //!///

SiteAemedial Proje'"4- Manager

office fit Regional Counsel ^Site Attorney

Carl Edimid/ ChiefSuperfund Programs Branch 6H"S

'^George Alexander/ Jr/' Regional Counsel 6C

) t0^> ^^.^-l^A^^____________

^^/AUynM. Davis, DirectorHazardous Waste Management

Division 6H

000319

FOURTH STKE^T REFINERYSECORD OP DECISION

TABLE OF CONTENTS

I- Site Name, Location, and D e s c r i p t i o n . . . . . . . . . . . . . . . . . . . . . 1

II. Site History and Enforcement A c t i v i t i e s . . . . . . . . . . . . . . . . . . . 6A. Site H i s t o r y . . . . . . , . . . . . . . . . . . . . . . . . , * . . . . « „ . . . . . . . . . 6B. Enforcement A c t i v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

III, Highlights of community p a r t i c i p a t i o n . . . . » , . < . . . - • . . . . . , . 8

IV. Scope and Role of Operable Unit 1 - . . . . . . , . . . , . . . . * . . . . . . , . 9

V. Summary of Site C h a r a c t e r i s t i c s . . . . . . . . . . . . . . . . . . . . . . . . . . 9A. General O v e r v i e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 c\1

B. General Geology and Hydrogeology Characterization... 10 t -C. Site Hydrogeologic C o n d i t i o n s . . . . . . . . . . . . . . . . . . . . . . . 12 mD, Nature e.nd Extent of Contamination. . . . . . , . , . , , . . . , . . 12 ^E. Discrete Areas of C o n t a m i n a t i o n . . . . . . . . . . . . . . . . . . . . . 13 —

1. Tar Mat A r e a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132. Surface I m p o u n d m e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . ie3. Drainage P a t h w a y s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174. Parcel H . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

VI. Summary of Site R i s k s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17A. Human Health R i s k s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17B. Land U s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

1. Current Land U s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 182. Future Land U s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

C. Identification of Chemicals of C o n c e r n , . . . . . . . . . . . . . 20D. Exposure A s s e s s m e n t . . . . . . . . . . . . * . . . . . . . . . . . . . . . . . . . . 20

1. Current Exposure P a t h w a y s . . < . . . . . . . . . . . . . . . . . . . . 202. Future Exposure P a t h w a y s . . . . . . . . . . . . . . . . . . . . . . . . 223. Exposure S c e n a r i o s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

E. Toxicity A s s e s s m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28F. Human Health Risk c h a r a c t e r i z a t i o n . . . . . . . . . . . . . . . . . . 30

1. currp-nt Risk C h a r a c t e r i z a t i o n . . . . . . . . . . . . . . . . . . . 322. Future Risk C h a r a c t e r i z a t i o n . . . . . . . . . . . . . . . . . . . . 32

G. Central T e n d e n c i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35H. Uncertainties with the Human Health Risk

C a l c u l a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35I. Ecological R i s k s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

1. Receptor Characterization and E n d p o i n t s . . . . . . . . . 432. Toxicological Response A s s e s s m e n t . . . . . . . . . . . . . . . 4 *3. Exposure A s s e s s m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 444. Risk C h a r a c t e r i s a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

VII. Remedial Action G o a l s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

000320

VXIt» Description of Alternatives* ....,»...<•................. 46A, remedial Action Alternatives..,...........<.......,,. 47

1. Common Elements- ...,...........*................ 472. No Action...,................................... 483. Limited Action...*.............................. 484 - Onsite Stabilization and Capping................ 495. Onsite Stabilizafcion/Onsite Landfill Disposal.*. 536. Onsite Stabilization/Off site Landfill Disposal.. 557. Onsite Xncineration/Onslte Ash Disposal......... 568. Offsite Incinerafcion/offsite Ash Disposal....... 57

IX. Summary of Comparative Analysis of Alternatives.......... 59A. Mine Criteria....................................... 59

1. Threshold Criteria.............................. 592. Balancing Criteria.............................. 59 \u

3. Modifying Criteria.............................. 60 c\t

4. Comparative Analysis........«.........*......... 60 r~-in

X. The Selected Remedy...................................... 64 ^

XI. Statutory Determinations................................. 66A. Protection of Human Health and Environment..-....,.. 66B. Compliance with ARARs*.... . . , . . . . .-. . . . . .*,. . . . . . . . . 66c. Chemical Specific ARARs.o........................... 66D. Action Specific ARARs............................... 67E. Cost Effectiveness.................................. 67P. Utilization of Permanent Solutions and Treatmento... 67G. Preference for Treatment as a Principal Element..... 68

XII. Documentation of Significant Changes..................... 68

Administrative Record Index......................... Attachment A

Respon^iveness Summary.......,............*........* Attachment B

Letter of State of Oklahoma Preference.............. Attachment C

000321

DECISION SUMMARYFOR THE

FOURTH STREET REFINERY SITEOKLAHOMA CITY, OKLAHOMA

X- SITE NAME. LOCATION. AND DESCRIPTION

The Fourth Street Refinery Superfund Site ("FSR site", or "thesite") occupies the Southwest Quarter (SW 1/4) of Section 36,Township 12 North, Range 2 West and Range 3 West, Indian Meridian,Oklahoma County, Oklahoma City, Oklahoma, Located at 1900 ME FirstStreet, the site is bounded to the south by the Union PacificRailroad tracks, to the north by Northeast Fourth Street, and tothe east by Interstate 35. Martin Luther King Boulevard lies onthe west side of the site as an overpass to the railroad tracks.Two active industrial facilities (vhich have not been associatedwith past site operations) also lie contingent to the mid-northernportion of the site, just south of Northeast Fourth Street.

The Double Eagle Refinery Site ("DER site") lies about 500 feetsouthwest of the FSR site, just south of the railroad tracks andjust west of Martin Luther King Boulevard. The FSR and DER sitesare essentially adjacent to each other, and contain very similarwaste material since both sites recycled used oils. Due to thefact that these sites are in such close proximity and migration ofcontaminants in certain cases overlap, this Record of Decision(ROD) will make reference to the DER site as necessary. The DERsite will be addressed in a separate ROD. Figures 1 and 2 show thelocation of each site in relation to the other.

The FSR site extends over three contiguous tracts of ' , twotracts fenced and one tract unfenced, totaling approxih-^cely 27acres. An active industrial facility is currently operating on thewesternmost tract, which is part of the original refinery property,but is now owned and operated by a separate individual. This tractis fenced and will be referred to as the Pipe Storage Yard,consistent with the active facility's current operations. The PipeStorage Yard contains buried sludge material beneath the site,which is presently covered with gravel. The middle tract of thesite is also fenced and contains the majority of contaminatedmaterial, a large tar mat area and surface pondso This tract willbe referred to as the Main Site Area, consistent with the fact thatmost of the contaminated material and scattered debris can be foundon this tract. The eastern tract of land is unfenced and containsonly surficial contamination carried from the Main Sit® Area viasurface drainage. This tract will be referred to as the EasternDrainage Area.

000322

OKLAHOMA

FIGURE 1

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000323

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000324

Tbe Pipe Storage Yard and the Main Site Area were once the formeroperations area, as evidenced by historical aerials and theextensive piping network discovered during investigations at thesite* The gravel/sand cover in the Pipe Storage Yard has beenineffective in covering buried contaminated sludges; consequently,surface seeps are now apparent. The M& in S ite Area conta insseveral discrete areas of concern: a tar mat area, two smallerearthen impoundments, one small concrete sump, and numerous piecesof abandoned refinery equipment and debris from past uncontrolleddumping. Remnants of the dismantled refinery in the Main Site Areainclude a warehouse foundation, three horizontal tank stands andfoundations, an oil well, and an abandoned concrete oil wellderrick foundation. Figure 3 is a schematic of the FSR site whichshows the surface features and areas of contamination.

0r^

Although industrial areas surround the site, the land use within a1 mile radius of the FSR site is mixed industrial and residential.One residence is located adjacent to the Pipe Storage Yard, just ! -north of the railroad tracks and to the east of Martin Luther King inBoulevard. A small neighborhood is located about 1/4 mile to the ^northwest of the Martin Luther King Boulevard and Northeast Fourth —Street intersection. Four schools (Douglas High School, DunbarSchool, Bath School, and Edwards School) are located within a 1mile radius of the site. Recreational areas close to the siteinclude the Douglas Community center, Douglas Community Park, andWashington Park. Drug Recovery, Inc. is the only medical facilitylocated within a 1 mile radius of the site.

The FSR site has contributed to off-site contamination in an areajust south of the site, the "Parcel H Area". This off-site area isunfenced. The contamination at the Parcel H Area which isattributable to past site operations includes two surficial ponds,approximately 0.5 acre. The Parcel H Area is shown in Figure 3 .The "Landfill Area" in this figure, located just west of the pondson Parcel H, is not attributable to either the FSR or DER site pastoperations.

Both portions of the FSR site and the Parcel H Area have beenidentified as wetlands. The North Canadian River is located justsouth of Interstate 35, approximately one-half mile south of thesite. Although no endangered species have been identified in theseareas, wildlife in the area includes migratory fowl and smallmammals.

No drinking water wells are located within a 1 mile radius of thesite. The oil well drilling operations in the early 1920's mayhave impacted the alluvial aquifer. This zone could be considereda Class III aquifer due to salinity, since the shallow ground waterbeneath both the FSR and DER sites has levels of Total DissolvedSolida ranging from 310 to 13,100 ppm.

4

000325

0 0 5 7 5 1

000326

The interconnection between the shallow alluvium and thedeeperdrinking water aquifer (Garber-Wellington) is currentlyundergoing further study for both the FSR and De;R sites< Xnaddition, the alluvium connection and potential impact of sitecontaminants to the North Canadian River will need furtherevaluation. A separate Record of Decision (ROD) will address thepotential migration of site contaminants via the ground waterpathway for the FSR site as Operable Unit 2.

U. SITE HISTORY AND ENFORCEMENT ACTIVITIES

Site History

The Fourth Street Refinery collected, stored, and re-refined usedoils and distributed the recycled product. The refinery was activein the early 1940's and was noted on historical aerial photographsavailable as early as 1941. Refining operations were conducted onland owned by the Chicago^ Rock. Island and Pacific Railway Company.

Planet Oil and Refining Company participated in the waste oilreclamation business during the early part of the 1940's throughthe early 1960's. Elliot Refining Company conducted waste oilreclamation activities during the late 1940's through the 1960's.Salyer Refining Company performed waste oil reclamation operationsfrom the late 1940's through the 1960's. These three companiesconducted waste oil reclamation activities on-site. Operationsceased in the late 1960's or early 1970's. Currently, exposedunderground pipes at many locations on-site indicate that anextensive piping network was utilized during operations,

Refinery operations at the FSR site apparently recycled used oilsin a similar manner to that process employed at the DER site.Sulfates in the waste suggest the use of sulfuric acid inclarification of the used oils- Sludges generated by thereclamation process were disposed of in on-site impoundments.

A preliminary assessment of the site %as completed in April, 1984,and a reconnaissance site inspection was conducted in October,2.984. Subsequent sampling was performed in June and December of1985, in the; Main Site Area. Further sampling was conducted in1986 along with the installation of ground water monitoring wells.An Expanded site Inspection was conducted in 1987 through 1988,which confirmed that the site should b© ranked for inclusion on theNational Prioritiea List (NPL). In March 1989, the r'SR aite wasadded to the NPL, pursuant to Section 105 of the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA),42 U.S.C. Section 9605, as amended.

Prior to initiation of the Remedial Investigation and FeasibilityStudy (RI/FS) projects for both the FSR and DER sites, review ofthe historical topography of the surrounding area revealed thatdrainage from the DER site onto Parcel H had occurred at one time.

S

000327

A site scoping visit was conducted to follow up on possible ParcelH contamination. Although drainage from the FSR site to Parcel Hdid not appear likely due to the diking on each side of therailroad tracks, historical aerials were the only source ofinformation for the FSR site operations.

Physical dumping at the edge of the eastern-most pond on Parcel Happeared to have occurred. Further sampling conducted on Parcel Hin April of 1990 revealed elevated levels of lead in the sedimentsof ponds on Parcel H- Due to the similar waste characteristics ofboth sites, one objective of the RI/PS was to sample the waste onParcel H for determining the contribution of contamination inrelation to either, or both, the FSR and DER sites.

The RI/FS project was initiated in Hay 1990 for the FSR site. TheRI and FS reports were completed in May 1992 and June 1992,respectively. Due to the close proximity of the ESR and DER sites ^and due to the similar types of wastes present at both sites and at f"-"the parcel H Area, EPA assigned one contractor to conduct the RI/FS ir\projects concurrently. Therefore, distinguishable characteristics c^of. each site could be easily identified and efforts would not beduplicated for the overall study area. The specialized"fingerprinting effort" for the off-site arsas was performed byEPA's Environmental Monitoring Systems Laboratory in Las Vegas,Nevada, in coordination with the Alternative Remedial Contractor(ARCS) given the RI/FS project. This will be discussed further inSection V " Summary of Site Characteristics; Discrete Areas ofConcern.

o

Enforcement Activities

In July, 1989, General Notice Letters were sent to the three (3)current owners of the FSR site. The General Notice Lettersinformed these parties that they may be responsible for futureresponse measures taken at the site. These parties were affordedthe opportunity to conduct the removal at the FSR site? however,the parties expressed an unwillingness to perform or finance theremoval action. In September 1989, EPA performed the removalaction which included fencing the site and posting warning signs toalarm potential trespassers-

In October, 1989, Special Notice of Potential Liability Letterswere sent to the current owners affording them the opportunity toconduct the RI/FS at the FSR site. The current owners declined toparticipate in either the financing, or the actual performance ofthe RI/FS.

Later, in 1990, the RI/FS project was initiated by EPA, and hasbeen completed. Simultaneously with tho performance of the RI/FS,EPA proceeded to collect liability information regarding thecontamination at the site. Currently, the Potentially .ResponsibleParty search investigation is ongoing.

000328

m. HISHUSHTS OF CQMMHmJJE^fflgKAIIQS

This decision document presents the selected remedial action forthe FSR Super fund site, in Oklahoma City, Oklahoma, chosen inaccordance with CERCLA, as amended by the Superfund Amendments andReaufchorization Act (SARA) and, to the extent practicable, theNational Contingency Plan (NCP), 40 CFR Part 300. Th© decision forthis site is based on the administration record. An index for theadministative record is included as Attachment A to this document.

The pu l i participation requirements of CERCLA, sections113 (k) (2) (B) (i-v) and 117, were met during the remedy process. TheRemedial Iryestigation (RI) report, released in May 1992, theFeasibility Study (FS) report, released in June 1992, and theProposed Plan, released in July 1992, were all made available to ^the public in both the administrative record and information ^repositories maintained at the Ralph Ellison Branch Library, theOSDH Central office in Oklahoma City, Oklahoma, and the EPA Region6 Office in Dallas, Texas. The notice of availability for these ln

documents was published in The Daily Oklahomian and The_ BlacH 0Chronicle, on July 17, 1992. 0

The OSDH and EPA held an Open House in Oklahoma City on August 4,1990, to explain the Superfund process and to notify the publicthat RI activities were going to begin. The RI fieldwork wasdiscussed and information about the site was provided to the publicby EPA.

On June 25, 1992, the OSDH and EPA held an Open House in OklahomaCity, to inform the public of the findings of the RI Report whichincluded the results of the Baseline Risk Assessment, EPA and OSDHalso discussed the various alternatives of remediation consideredin the RI/FS.

A 30-day public comment period was held from July 17, 1992 toAugust 15, 1992. No requests were received to extend the commentperiod. One (1) written comment was received during the publiccomment period.

A public meeting was held in Oklahoma City on July 23, 1992. Atthis meeting, representatives from the OSDH and EPA presentedinformation on the RI/FS, and the Risk Assessment (RA) ; andanswered questions about the sit®, the .©medial Alternatives underconsideration, and the Proposed Plan of Action. A response to th<acomments received at this meeting and during the 30-day period isincluded in the Responsivenesa Summary, which is aa Attachment t? tothis ROD.

000329

IV. SCOPE AND ROLE OF OPERABLE UNIT 1 WITHIN THE SITE STRATEGY

Principal threat wastes are those source materials considered to behighly toxic or highly mobile that generally cannot be reliablycontrolled and that present a significant risk to human health orthe environment should exposure occur. The principal threats atthe FSR site are the acidic sludges and contaminated ponds. Thesediscrete waste areas present the most significant risk at the site,due to the potential for exposure through direct contact andinhalation. The risk is also increased due to the concentratednature of the waste which presents a high potential for migrationof contaminants to surrounding areas and the underlying groundwater.

Low level threats are those source materials that generally can bereliably managed with little likelihood of migration and thatpresent a low risk in the event of exposure. The low level threatsat the site are the contaminated soils and tar matrices/ both onand off-site. These areas are not as highly mobile as the acidicsludges and the material in the ponds on-site and the concentrationof contaminants is more dilute which decreases the risk frompotential exposure.

The principal threat at th.2 FSR site is posed by direct contact andinhalation, and potential for migration of contaminants to theground water. The remedial objectives are to minimize potentialexposure by direct contact or inhalation, and to reduce thepotential for migration of contaminants into the surface waters andground waters.

During the RI/FS project for the FSR site, the issues related tothe ground waters beneath the sit-^, were acknowledged as complex incomparison to those issues apparent for the source contamination.Although shallow and deep wells were installed around the perimeterof both the FSR and DER sites, the determination of vertical andlateral migration of contaminants will require further study. Theimpact of the migration of contaminants in ground water and surfacewater will be addressed in a future Record of Decision, OperableUnit 2 (Groundwater Operable Unit - GOU). This ROD will addressthe source of contamination at the DER site. Operable Unit 1(Source Control Operable Unit - SCOU).

V. SUMMARY OF SITE CHARACTERSSTLCS

General Overview

The FSR site and Parcel H Area are not located in the 100 yearfloodplain. Prior to construction of Interstate 35, the NorthCanadian River meandered through the FSR site. During constructionof the highway, the river was diverted to the south side of 1-35,and is now located approximately one half-mile to the south of theFSR site.

000330

Ponde on the FSR site and portions of the Parcel H Area appear onU&Q National Wetlands Inventory Maps (NWI) (U.S. Dept. of Interior,Fish and Wildlife Service, 1989). These maps are based oninterpretation of aerial photographs and not on actual sitesurveys. Vegetation around open water areas in the EasternDrainage Area and on Parcel H appear to consist of grasses, likelyto be prairie grass species rather than wetlands species. Wetlandsclassification of the FSR site and off-site areas will be discussedin detail under Section VI (Summary of Site Risks - EcologicalRisks).

General Geology and Hydro geology Chamcteiiwtion

The FSR site is situated on Quaternary alluvial deposits whichrepresent recent deposition by the nearby North Canadian River.The floodplain deposits typically consist of unconsolidated andinterfingering lenses of sand, silt, clay, and gravel. Thesealluvial sediments are predicted to have relatively highpermeabilities and porosities. The alluvium in Oklahoma Countyranges in thickness from several inches to 90 feet below groundsurface along the river basin.

The predominant outcropping geologic formation beneath the FSR siteincludes the Garber and Wellington Formations. These bedrockformations (i.e., lithified strata below the alluvial channel fill)have a gentle westward homoclinal regional dip of 30 to 40 feet permile and are located approximately 40 to 60 feet below the surfaceat the FSR site. Collectively, the Garber-Wellington consists ofmassive, cross-bedded sandstones irregularly interbedded withsiltstones and shales. The "red bed" sandstones and shales of theGarber and Wellington Formations are similar in lithology andconform gradationally. Therefore, these formations are commonlymapped as a single lithologic unit and classified as a singleaquifer (the Garber-Wellington aquifer). See Figure 4 for a cross-section of the subsurface.

The Garber-Kellington aquifer constitutes the most important sourceof ground water in Oklahoma County. Hells drilled into the waterbearing zone may penetrate as much as 200 to 300 feet of waterbearing sandstone. Artesian conditions exist below 200 feet inareas in which the aquifer is overlain by the Hennssey Group. Thedepths of municipal, institutional, and industrial wells screenedin the Garber-Wellington range from 100 to approximately 1,000 feetin Oklahoma County. Yields of wells less than 250 feet deep rangefrota 5 to 115 gallons per minute (gpm) and average 35 gpm.Reported yields of wells more than 250 feet deep range from 70 to475 gpm and average 240 gpm. The principal hydrologic factorcontrolling the development of the aquifer for fresh water supplyis the presence of a deeper ealine water wedge,

No private wells currently exist within a 1 mile radius of thesite. Residents and industries in the area utilize city water,which is obtained from reservoirs surrounding the city. Results

10

000331

LB3BID:Q Clayey Sand, Sandy Oay^ F^ Mecfiiffn, Cocsse rabed Sand[S Coaree-Grolned Sand & GravelXVfcrterTabte.Y. Infened Water Tabte@ Vtefi Screen

SECTION (A - A') OF SUBSURFACECONDITION, FOURTH STREET

^0 0=5 7 9 7 ^ ^HORIZONTAL DISPLACEMENT (Feet)

000332

frosa sampling the shallow ground water beneath both the FSR and DERsites indicate total dissolved solids from 310 ppm to 13,100 ppm;high conductivities were also documented, >20,OGO ailli moles.These conditions confirm the presence of saline water beneath thesite which would prohibit use of the shallow ground waters fordomestic use.

The Hennessey Group formation, predominantly reddish-brown shalecontaining some layers of siltstone and fine-grained sandstone,overlays the Garber-Wellington Formation in the vicinity of thesite* However, this shale layer was not encountered above theGarber-Wellington aquifer in the deeper borings drilled at both theFSR and OER sites in March of 1992. Due to the absence of theHennessey Shale beneath the site, a separate study is plannned toassess the vertical migration and potential impact of sitecontaminants on the deeper Garber-Wellington aquifer. In addition,the lateral migration and potential impact of site contaminants on rothe nearby Canadian River will be investigated* The results of ^this study will be utilized to complete the ROD for the GOU,

Site HydrogeologicConditions {r\

0Field investigations at the Fourth Street Refinery site included 0portions of the Parcel H area; and revealed that the upper 1 to 20feet of surface material consisted of stained soils within avariable amount of sand, silt and clay matrix. Subsurface strataconsisted of a classic, fining-upwards alluvial sequence of sandand gravel. At depths ranging from 20 to 32 feet, a dense layer ofmedium to coarse-grained sand and gravel in a brick-red matrix wasencountered in several of the borings on the FSR site. Thissurface most likely represents the erosional top of the Permianbedrock.

During drilling operations, groundwater was encountered at varyingdepths that ranged from 4.5 to 9.5 feet below the surface.Subsequent groundwater monitoring indicates that the thegroundwater levels range from about 4 to 12 feet below the groundsurface. The groundwater levels were determined periodically, andexhibited moderate seasonal fluctuations.

Nature and Extent of Contamination

The Source Control RI/FS was focused to provide information fordiscrete areas of concern and subsequent migration pathways, giventhe type of oily matrix encountered at the site. The discreteareas of concern at the FSR site are well delineated waste areas;buried waste material beneath the Pipe Storage Yard Area, & tar matextending across the Main Site Area, two small earthen impoundmentsand one concrete sump in the Main Site Area, various piles of wastematerial and debris from the dismantled refinery scattered acrossthe Main Site Area, and the Eastern Drainage Area. In addition,the off-site "Parcel H" area was included in the investigation, asdiscussed under Section I.

12

000333

Figure 5 is a conceptual model of the site, used for visualisingthe potential exposure pathways of concern, hs discussedpreviously, the ground water pathway is currently unknown.Therefore, this pathway is presented as incomplete in the currentconceptual model, but will be evaluated under the GOU ROD.

From all the chemicals detected in various media at the site,certain chemicals were originally identified as potentialContaminants of Concern (COC). This determination for £>elsation ofa COC is based upon concentrations detected, toxicity of thecompound, and their persistence in the environment. COCsattributable to site activities include Polycyclic AromaticHydrocarbons (PAHs), chlorinated hydrocarbons and polychlorinafcedbiphenyls (PCBs), alkyi benaenes, ketones (particularly 2-butanone), lead, arsenic, and antimony* Lead is the primary COCgiven the widespread occurance in all media and the extremely highconcentrations (approximately 15,000 ppm) in sludge andcontaminated soils or sediments. Exposure to the cocs couldpotentially occur due to direct contact as well as inhalation.The COCs are discussed in Section VI " Summary of Site Risks.

Although the air pathway contributed the greatest risk and hazardindex for organics detected, a trend is not apparant to suggestthat the site contributes to the ambient air contaminant levels ofthe surrounding area. This is due to high gasoline constituentlevels measured upwind of both the FSR and DER sites; probably dueto the areas surrounding both sites being highly industrialised.Similarly, particulate air sampling results for lead were high(32.8 ug/m3) onsite. However, upwind locations were just as high(32.0 ug/m3) ,

Discrete Areas of Concern

a) Zfl M . Exposed and Buried Areas

Evaluation of the tar mat was completed upon visual inspection ofbor ings ov^r a 20 by 20 f oot surveyed gr id system, t ied to thelarger 3 00 by 100 foot surveyed grid system for the entire site(Figure 6). Samples were collected randomly from the smaller grid,both laterally and vertically, for full scan analysis (TargetCompound List - TCL) under the Contract Laboratory Program (CLP).In addition, samples were obtained for indicator parameter analysis(Total Petroleum Hydrocarbons - TPH; pH; Lead; and Chromium) tocorrelate with visual observations and full scan analysis. Also,technology screening samples were collected (physical parameterssuch as density, grain size distribution, solubility, viscosity,heat content, etc.).

Discrete depth samples were not planned since an initial inspectionof the exposed tar mat prior to the RI/FS Work Plan approval didnot reveal distinguishable differences vertically within the MainSite Area. However, buried tar material was noted in the form ofseeps in the Pipe Storage Yard Area. Since this matrix appeared

13

000334

F i g u r e 5 ~ J

FOURTH STREET REHNERY ICONCEPTUAL MODEL OF SSTE- j

EXPOSURE PATHWAYS |-- ,^.^_ ___ /'

^^^•fflb

000335

W . r •"•*

000336

more fluid than the weathered material of the -axposied tar mat,samples obtained for characterization of the waste material wereobtained from both the Pipe Storage Yard Area and the Main SiteArea (areas shown in Figure 3).

Results of this sampling effort show that the chemical compositionof the bur ied a nd the exposed tar mat mater ial are notsignificantly different. Vertical versus lateral composition didnot vary significantly, either. In general, the correlationbetween visual observations and indicator parameters was onlyloosely established. However, lead concentrations did increasewith higher TPH content in the sludge matrix and higher acidcontent.

In general, the correlation between visual observations andindicator parameters was only loosely established. However, leadconcentrations did increase with higher TPH content in the sludgematrix and higher acid content. In the Pipe Storage Yard, wastematerial is covered by a thin layer of gravel (approximately 6 to12 inches). The buried sludge extends across the entire pipe yardsite and has an aerial extent of approximately 150,000 square feet.In the Main Site Area, the tar mat extends westward towards anorth-south fence line that represents the eastern boundary of thePipe Storage Yard. The aerial extent of the tar mat isapproximately 300,000 square feet. However, the western-most andthe eastern-most portions of the tar mat are covered with grass.The estimated volume of waste material for the exposed tar mat is26,000 cubic yards and the estimated volume for the buried tarlaaterial is 11,000 cubic yards (total sludge material of 37,000cubic yards).

b) Surface Impoundments

The two impoundments on-site are not considered very large and wereassumed to be homogeneous in nature and composition. Both of theearthen impoundments are unlined. The concrete sump is locatedjust south of Impoundment A, as shown i* . Figure 3. Therefore, onlyone water and one sediment sample were collected from each of theimpoundments and the sump. All samples were analyzed for TCLcompounds and some samples were analyzed for technology screeningparameters.

Mater sample results were limited in use due to matrixinterferences in both impoundments. However, results of thesediment sampling indicated that sediments in the ponds weresimilar in chemical composition to that material in the main tarmat area. The aerial extent of contaminated laaterial in theimpoundments is estimated at approximately 20,000 square feet withan estimated volume of 400 cubic yards.

16

000337

c) Drainage Pathways

Although the tar mat and ponds on-site were o£ major concern,drainage pathway sediments were also investigated. The volume ofcontaminated Material for drainage areas is estimated as 400 cubicyards. This includes sediments in the Eastern Drainage Area.

d) Parcel HArea

The contamination at the Parcel H Area includes oily sediments intwo surface ponds, and these sediments which contain high leadconcentrations. The concentrations of lead encountered in thesludge from the ponds at Parcel H ranged from 199 to 8,780 mg/kg.The concentrations of lead encountered in the sediments from theponds ranged from 5,550 to 19,900 mg/kg. Each pond isapproximately 0.25 acre in size. The volume estimate forcontaminated sediments in both ponds is 2,420 cubic yards, assuminga 3 foot depth for each pond.

The EPA Environmental Monitoring Systems Laboratory (EMSL) hasevaluated existing data and analyzed samples from both the FSR andDER sites, and the Parcel H Area. This specialized fingerprintingeffort was intended to confirm whether or not the waste at theParcel H Area was attributable to the FSR site and/or DER site.The results have indicated that waste from FSR is slightlydifferent in chemical composition than waste from DER. Both siteshave contributed to the Parcel H contamination. Based on thefingerprinting effort, EPA estimates that 50% of the waste atParcel H is attributable to each site and will be addressed as partof each site remedy.

VL SUMMARY OF SITE RISKS

Human Health Risks

As part of the Remedial Investigation at the FSR site, aquantitative risk assessment was performed to estimate human healthrisks from the site. This section presents a summary of theBaseline Human Health Risk Assessment for exposure of humans tocontaminants existing within areas of concern at the FSR site anda non-contiguous area referred to as the Parcel H area.

This ROD does not address the potential contamination ofgroundwater due to site-related activities. The shallow aquifermay be classified as a Class III aquifer (water not suitable forhuman consumption). This pathway of potential contamination andthe possible human health effects which could result from exposureis being evaluated, and will be addressed separately by the GOU.

The purpose of the risk assessment was to compile and evaluateinformation collected in the site investigation in order to

17

000338

estimate the upper limit of potential health risk which may bepresent at the site. In the evaluation of potential human exposurescenarios, on-site sampling and analysis results were used inconjunction with current federal and state guidance documents andprofessional judgement to estimate the potential human health riskattributable to contamination resulting from past site-relatedoperations.

The "risk" values generated within this human health riskassessment will reflect the plausible upper limit to the actualrisk of cancer posed by the site under the exposure scenariosevaluated. These estimates were compared to the SPA'S target riskrange of 1 X 10'4 to 1 X 10'6 for hazardous waste site remediations.The MCP stipulates a 1 X 10'6 risk level as a point of departure inrisk management. Such estimates, however, do not necessarilyrepresent an actual prediction of the risk. Hon-carcinogeniciffipacts are quantified by the "Hazard Index" which is the ratio ofsite concentrations of a contaminant of concern to a referenceconcentration that causes a non-carcinogenic impact. EPA'sremedial goal is to reduce the "Hazard Index" at a site to lessthan 1.0.

The values which are calculated in this assessment are consideredrepresentative of the cancer risk posed by the site only in thatthey represent estimates of the plausible upper bound limit of whatis most probably the risk range. The true risk within the range ofthe upper limit and zero is indeterminable. What is estimated isthe projected reasonable maximum potential additional lifetimecancer risk and potential for adverse health effects. Thereasonable maximum potential risk is calculated in order to behealth protective ("health protective" assumptions are alsoreferred to as "conservative" assumptions in risk assessmentterminology). It should be noted that the risk is an additionalrisk - it is present in addition to the baseline approximate "1 in3" chance which humans share of "getting cancer".

Land Use

a) Current Land Use

The former FSR site is located near the intersection of northeastFourth Street and Martin Luther King (MLK) Boulevard. The immediatearea of the site, the eastern drainage area and Parcel H are zonedfor industrial use. To the west of the FSR site is a residence anda convenience store. Further to the west are industrial facilitiesincluding an insulation plant and an operating waste oilreclamation refinery.

North of the site is a residential area within which are parks andschools. Portions of the residential area, parks and schools arewithin one mile of the site as previously described in this riskassessment. The residents living in these areas ®ay be exposed tocontaminants in the on-site waste areas via atmospheric transport.

18

000339

Soae of the residents may also gain unauthorized access to the siteand could be exposed in a manner similar to transients. Access toParcel H and eastern drainage areas are not controlled since theyare not fenced.

The potential for trespass in this general area is substantial,since the site is situated in the immediate area of the MK&Tmulti-track railway line. There are two major interstate freewaysnearby (1-35 and I"40). These thoroughfares may increase theprevalence of transients in the area* Transients have been observedloitering under the bridge which carries HLK Boulevard over theMK&T railway lines. There are also signs such as gathered firewoodthat May indicate "camping" in good weather under the MLK Boulevardbridge. In addition, the close proximity to a residential areasuggests that children may visit the Parcel H and eastern drainageareas during play activities.

The FSR site and adjacent areas are, for the most part, vacant(i.e., authorized personnel work in the Pipeyard for only part ofthe day). Therefore, there is significant potential for transientsand trespassers to be exposed to contaminants in the waste areas.Pipeyard operations may also create a potentially-exposedpopulation of on-site workers.

The nearest major surface water body is the North Canadian River,which is located approximately one half mile south of the site. Theriver is on th^ far side of the raised freeway with no apparenthydraulic connections with surface drainage features from the site.

b) Future Land Use

Given the current land vise patterns, the Fourth Street site islikely to remain an industrial facility. Two possible scenarios ofusage, not considering remadiation of the site, are possible. Theyare:

The Pipeyard remains with no change in the existing tarmat and impoundments in the undeveloped section of thesite,

The Pipeyard remains; new structures are built; and,workers are present in the tar mat area in a normalworking environment. Even though this is not likelyunless the waste areas are remediated, this scenario willstill be evaluated because it represents a reasonablepossible scenario.

The future use and development of the Parcel H area is somewhatmore uncertain as any development is likely to depend onremediation of the waste area as well as the "landfill/rubbish"area. Because the land use surrounding Parcel H is commercial, EPAexpects future land use at Parcel H to b& commercial. Futurecommercial development at the eastern drainage area is likelyo

19

000340

In the proposed future use scenarios, it. assumed that no specificresaediation of the waste material will occur and that industrialand construction workers will be. exposed to the wastfel material ineach area.

Identification of Chemicals of Concern

The initial chemicals of concern (COCs) were the contaminants onsite which were identified as moat likely to contribute significantcancer risks and non-cancer health effects, and to cause a publichealth concern. The risk assessment focused on contaminants thatwere site-related, but a chemical was included if it materiallycontributed to the overall public health impact. Factors such asfrequency of detection, exposure point concentration and humantoxicity dictated which COCs contributed most to the potentialhuman health risk from exposure to a particular medium of concern.

The FSI site was an oil reclamation plant. As such, the major COCswere expected to be oil-derived contaminants and other materials(such as lead) associated with motor vehicle products. In general,the initial COCs were related to this process. Table 1 lists theinitial COCs, and the media in which they were detected. However,only a few of the chemicals originally identified actually drovethe risk at the FSR site. These specific chemicals will bediscussed later in this Section, Human Health RiskCharacterization.

Exposure Assessment

a) Current Exposure^ Pathwoys

The following is a summary of the selected exposure pathways forthe current use of the FSR site and the surrounding areas:

Oral/dennal exposure o£ on-site Pipeyard workers tocontaminants in the sludge present in the soils;

Inhalation exposure of the on-sito Pipeyard workers tovolatilized contaminants or to particulates carryingcontaminants;

Oral/dermal exposure of trespassers in the tar mat areato the contaminants in the sludge present in theimpoundments, tar mat and soil;

Direct exposure of trespassers in the tar mat area tocontaminants present in the surface water of theimpoundments through accidental exposuro;

Inhalation exposure of the trespassers in th© tar matarea to volatilized contaminants or to particulates

20

000341

TABLE 1

Fourth Street SiteInitial Contaminants of Concern

Compound

CARCIHOGENSArssni-c

Cadmium

Beryllium

Benzene

Tetrachloroethylene

Tric^loroefehylene

Methylene Chloride

Phthalafces

PCBs

Styrens

PAHs

Haptachlor

Chiordane

NOM-CARCINOGENS

Antimony

BariumCopper

Lead

Nickel

Thallium

Vanadium

Zinc

Kefconoa

Alkyi Aromafcica

1^1,1-Yrichloroathane

Polychlorobenzenea

Phenol a

Tar HatSoil

X

X

X

X

X

X

X

X

X

X

X

X

X

PipeyardSoil

X

X

X

X

X

X

X

X

X

X

X

X

Off-flitaSQil

X

X

X

X

X

X

X

X

X

X

X

X

Off-aitaHot Spot

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Tar HatSurfaceWatar

X

X

QSSf-ftita

SucfAceMafcar

X

X

X

X

X

X

Ait

X

X

X ,

X

X

X

X

X

X

X

X

21

000342

carrying contaminants;

Oral/denaal exposure of transionts to thacontaminantspresent in the arose of concern (hot apot) inthe Parcel H and eastern drainage areas;

oral/dennal exposure of transients to the contaminantspresent in the soil/sediment surrounding the site, in theParcel H and in the eastern drainage areas;

Direct exposure of the transients to contaminants presentin tha surface waters of the Parcel H area impoundmentsthrough accidental exposure;

Inhalation exposure of the transients to volatilizedcontaminants or to particulates carrying contaminantswhile in the vicinity of the Fourth Street site or in theParcel H and in the eastern drainage areas; and,

Inhalation exposure of children to volatilizedcontaminants and/or to particulafces carrying contaminantsin the ambient air while in the vicinity of the pool andthe high school.

Table 2 lists the exposure and intake assumptions for dermalcontact and ingestion of surface soil/sludge and surface water, forthe current use scenario. Table 3 lists the exposure and intakeassumptions for inhalation, for both the current and future usescenarios.

b) Future Exposure Pathways

The following is a summary of the selected exposure pathways forthe future use of the FSR site and the surrounding areas;

Oral/dermal exposure of Pipeyard workers to contaminantspresent in the soils;

Inhalation exposure of the Pipeyard workers tovolatilized contaminants and/or to particulates carryingcontaminants;

oral/dermal exposure of on-site workers to contaminantspresent in the sludge and in the impoundments, tar matand the soil of the tar mat area;

Direct exposure of on-site workers in the tar mat area tocontaminants present in the surface water of theimpoundments through accidental exposure;

• Inhalation exposure of the on-site workers in the tar mat

22

000343

TABLE 2Fourth Street Site

Exposure and Intake Assumptions forDermal Contact and Ingestion of S^.- i/Sludge and Surface Water

Current Use Scenario

Age Groups by YearsAseumption

Worker7-ll 12-17 Adult

Duration of Exposure (years)

Dermal Soil Deposition (ag/cia3)

fikin Exposed to Soil (cm3)

Water Ingestion (I/day)

Dttnal Exposure to Water (hr/day)

^^P^J^P-0668^ t0 Water (cm3)

5

1.4

4676

0.1

4

3392

6

1.4

6255

0.1

4

4905

10

1.4

4300

0.1

4

5190

10

1.4

4300

0.1

4

S190i- frit ^-•V^-J,': • fWrf. '••'On-Site at Fourth Street Facility —Pipeyard.;

Dermal Exposure to Soil (day/year)

Soil Ingestion (nig/day)

250

25

On-site At Fourth. Street Facility —;, Tar...Mat/

Denaal Bxposure to Soil (day/year) 0

Deraial Exposure to Water (day/year) 0

Soil Ingestion (ag/dayj____________0

39

12

50

52

12

50. •I?- •"-??*':•,:••••*•'••<•. •V 'v-^'^

"'"" .•?;.-%:1;' • ^

•Transient

Dermal Exposure to Soil (day/year) 117

Dermal Exposure to Hot Spot 12(day/year)

Denaal Exposure to Water (day/year) 39

Soil Ingestion (aig/day) 50

For All Areas:

•Soil Dermal Absorption Factors:

Semivolatile Organics 1 .3%

Volatile organlcs 5%

Metals 1%

•Gut Absorption Factors:

Hetals, Seffiivolatiles 50%

Volatile^ Organ ics_______________100%

117

12

39

50

117

12

39

50

1.3% 1.3% 1.31

5% 5% 5%

1% 1% 1%

50% 50% 50%

100% 100% 100%

Sources; Skin surface areas exposed are from Anderaon et al., (1984);other parameter values were derived as described in the text,

23

000344

TABLE / 3

Fourth Street SiteExposure and Intake Assumptions for Inhalation

Current and Future Use Scenarios

Exposure Exposure Respiratory BodyAge group Duration Frequency Vo luiae Weight

___ _______ (Years) (Days/yr) (n^/day) (kg)

7-11 S 117 4.6 27

12-17 6 117 4.6 48

Adult 10 117 4.6 70

• ^ •• ^p :y ^^^'W^pooi/s^^' • '^W^ .^y' ^^-:^^^^^^^^^^

7-11 5 250 14 27

14 4812-17 6 250

^^^?^».- '•-y?3r,-!-^—^ • ••• -••- . • :'• • ' . - • • • - • :••'•• . • ' • • • " • • . • .Ktefb.LUUIlL-.LuJ>.. • .. •-<::-;••••;<•.':• • • .;.: ••-:..;;.•• •^. :•.•.•:..• '.;;:.' '--y::';-. •.•,.•.•.;•:,•"..•;. '.

18-70 30 365 27.4 70

Industrial 25 150Construction I 250Industrial-Future 25 250

6 70

20 70

20 70

12-17 6 39

Adult 10 52

4.6 48

4.6 70

Sources: USEPA 1991, USEPA 198Sb, Anderson 1984

24

000345

areas to volatilized contaminants and/or to particulatescarrying contaminants;

Oral/dermal exposure of off-site construction workers tothe contaminants present in the areas of concern (hotspot) in the Parcel H and eastern drainage areas;

Oral/dermal exposure of off-site construction workers tothe contaminants present in the soil/sediment surroundingthe site, in the Parcel H and in the eastern drainageareas;

Direct exposure of off-site construction workers tocontaminants present in the surface water of the Parcel Harea impoundments through accidental exposure;

Inhalation exposure of off-site construction workers to /.volatilized contaminants or to particulates carryingcontaminants; ^

nOral/dermal exposure of off-site industrial workers to 3the contaminants present in the soil/sediment surrounding < >the site, in the Parcel H and in the eastern drainageareas;

Direct exposure of off-site industrial workers tocontaminants present in the surface water of the Parcel Harea impoundments through accidental exposure;

Inhalation exposure of off-site industrial workers tovolatilized contaminants or to particulates carryingcontaminants;

Oral/dermal exposure of transients to the contaminantspresent in the areas of concern (hot spot) in the ParcelH and eastern drainage areas;

Oral/dermal exposure of transients to the contaminantspresent in the soil/sediment surrounding the site, in tneParcel H and in the eastern drainage areas;

Direct exposure of transients to the contaminants presentin the surface welter of the Parcel H area impoundmentsthrough accidental exposure;

Inhalation exposure of the transients to volatilizedcontaminants or t.o particulates carrying contaminantswhile in the vicinity of the Fourth Street site or in theParcel H and in the eastern drainage areas;

Inhalation exposure of the children to volatilizedcontaminants or to particulates carrying contaminants inthe ambient air while in the vicinity of the pool and the

25

000346

high school.

Table 3 lists the exposure and intake assumptions for inhalation,for both the current and future use scenarios. Table 4 lists theexposure and intake assumptions for dermal contact and ingestion ofsurface soil/sludge and surface water, for the future use scenario.

c) Exposure Scenarios

There were four major sets of exposure pathways utilized for thisrisk assessiaenfc of current use. They are:

» Pipeyard workers exposure to the on-site contaminants;

• Trespassers exposure to the on-site contaminants in the (^1

Tar Mat area; mr-mo

• Transients and children exposure to transportedcontaminants which includes the Parcel H area; and

• Residents and children to air borne contaminants. c^

Therefore, the current use scenario includes on-site workers,transients both on-site and in the immediate vicinity of the site,and off-site residents. Since the site is only used periodically,exposure assumptions are based on actual use.

There were five major sets of exposure pathways utilized for thisrisk assessment of future use. They are:

® Pipeyard workers with continued operations in thepip^yard area;'

• Transients and children exposure to transportedcontaminants;

» Residents and children to air borne contaminants;.

c Construction workers engaged in building new facilitieson the Parcel H and Tar Mat areas; and

® Industrial workers employed at these new facilities.

The future use scenario assumes more frequent exposure to on-siteworkers based on increased useage of the site. Standard defaultassumptions were utilized^ In addition, industrial redevelopmentof the Main site area, eastern drainage and Parcel H areas isassumed, based on land use trends (previous section). Off-siteworkers were considered under the future use scenario. Theresidential exposure assumptions are the same under the future us©scenario as under the current use scenario. These assumptions wereidentical since the residents could potentially be impacted vxa the

26

000347

TABLE

Fourth Street SiteExposure and Intake Assumptions for Dermal Contact

and Ingestion of Surface Soil/Sludge and Surface Waterfuture Use Scenario

Duration of Exposure (years)

Dermal Soil Deposition (ing/cm2)

Skin Exposed to Soil (cm2)

Soil Ingestion (Big/day)

Skin Exposed to Water (cm2)

Water Ingestion (I/day)

Dermal Exposure to Water (hr/day)

^^^^^^^^-•^^ ..sê'

7-11

5

1.4

4676

50

3392

0.1

4

.reef

Ag12-17

6

1.4

6255

50

4905

0.1

4

Facility

e Groups

Adult I

10

1.4

4300

5C

5190

0.1

4

'- Pipeya

by Years

* Worker c

25

1.4

4300

50

5190

0.1

4

fcrdtiS®IN

;. Worker

1

1.4

4300m

50 /.in519(^.

o-im

4 0

,' '3~ ~"

Derma 1 Exposure to Soil (day/year? 0 250 0Soil Ingestion (ing/day) 25

l ' "l' ;l^l-t^n-siteât•l•ôurth:•:'Street./Fac^ :Tar -Hat

Dermal Exposure to Soil (day/year)Dermal Exposure to Water (day/year)

250

12

250

12

Off-Site

-Transient

Dermal Exposure to Soil (day/year) 117 117 117 250

Dermal Exposure to Hot Spot 12 12 12 0(day/year)

Dermal Exposure to Water (day/year) 39 39 39 12

Soil Ingestion (lug/day) 50 50 50 50

For All Areas;

-Soil Dermal Absorption Factors

Semivolatile Organics

Volatile organics

Metals

1.3%

5%

1%

1 .3%

5%

1%

1.3%

5%

1%

1.3%

5%

1%

-Gut Absorption Factors

Metals, Semivolatiles 50% 50% 50% 50%

Volatile Organics 100% 100% 100% uo%

250

12

12

50

1.3%

5%

1%

50%

100%

Sources: Skin surface areas exposed ars from Andersen ®fc al./ ( 1 9 8 4 ) ; otharparameter values were derived as described in tho toxt.

27

000348

air pathway, which will remains the same in the absence of anyrea&edial action.

Toxicity Assessment

The objective of the toxicity assessment is to weigh availableevidence regarding the potential for particular contaminants tocause adverse ef.fects in exposed individuals. Also, the toxicityassessment provides, where possible, an estimate of therelationship between the extent of exposure to a contaminant andthe increased likelihood and or severity of adverse effects. Thetypes of toxicity information considered in this assessmentinclude the reference dose (RfD) used to evaluate noncarcinogeniceffects and the slope factor to evaluate carcinogenic potential*

RfDs have been developed by EPA for indicating the potential foradverse health effects from exposure to contaminants of concernexhibiting noncarcinogenic effects. RfDs, which are expressed inunits of mg/kg-day/ are estimates of acceptable lifetime dailyexposure levels for humans, including sensitive individuals.Estimated intakes of contaminants of concern from environmentalmedia (e.g., the amount of a contaminated drinking water) can becompared to the RfD. RfDs are derived from human epidemiologicalstudies or animal studies to which uncertainty factors have beenapplied (e.g., to account for the use of animal data to predicteffects on humans and to protect sensitive subpopulations) toensure that it is unlikely to underestimate the potential foradverse noncarcinogenic effects to occur. The purpose of the RfDis to provide a benchmark against which the sum of the other doses(i.e. those projected from human exposure to various environmentalconditions) might be compared. Doses that are significantly higherthan the RfD may indicate that an inadequate margin of safety couldexist for exposure to that substance and that an adverse healtheffect could occur.

No RfD or slope factors are available for the dermal route ofexposure. In some cases, however, noncarcinogenic or carcinogenicrisks associated with dermal exposure can be evaluated using anoral RfD or an oral slope factor. Exposures via the dermal routegenerally are calculated and expressed as absorbed doses. Theseabsorbed doses are compared to an oral toxicity value that is alsoexpressed as an absorbed dose. Toxicity information used in thetoxicity assessment for the Site was obtained from the IntegratedRisk Information System (IRIS) . If values were not available fromIRIS, the Health Effects Assessment Summary Tables (HEAST) wereconsulted.

For chemicals that exhibit noncarcinogenic health effects,authorities consider organisms to have repair and detoxificationcapabilities that must be exceeded by some critical concentration(threshold) before the health is adversely affected. For example,an organ can have a large number of cells performing the same oraimilar functions. To lose organ function, a significant number of

28

000349

those cells must be depleted or impacted. This threshold viewholds that exposure to some amount of a contaminant is toleratedwithout an appreciable risk of adverse effects.

Health criteria for chemicals exhibiting noncarcinogenic effectsfor use in risk assessment are generally developed using EPA's RfDsdeveloped by the Reference Dose/Reference Concentration ("RfD/RfC")Work Group and included in the IRIS.

For chemicals that exhibit carcinogenic effects, most authoritiesrecognize that one or more molecular events can evoke changes in asingle cell or a small number of cells that can lead to tumorformation. This is the non-threshold theory of carcinogenesiswhich purports that any level of exposure to a carcinogen canresult in some finite possibility of generating the disease.

EPA's Carcinogenic Risk Assessment Verification Endeavor (CRAVE)has developed slope factors (i.e., dose-response values) forestimating excess lifetime cancer risks associated with variouslevels of lifetime exposure to potential human carcinogens. Thecarcinogenic slope factors can be used to estimate the lifetimeexcess cancer risk associated with exposure to a potentialcarcinogen. Risks estimated using slope factors are consideredunlikely to underestimate actual risks, but they may overestimateactual risks. Excess lifetime cancer risks are generallyexpressed in scientific notation and are probabilities. An excesslifetime cancer risk of 1 x 10'6 (one in one million) , for example,represents the probability that one additional individual in apopulation of one million will develop cancer as a result ofexposure to a carcinogenic chemical over a 70-year lifetime underspecific exposure conditions.

Slope factors (SFs) have been developed for estimating excesslifetime cancer risks associated with exposure to potentiallycarcinogenic contaminants of concern. SFs, which are expressed inunits of (mg/kg-day)'1 , are multiplied by the estimated intake ofa potential carcinogen, in ing/kg-day, to provide an upper-boundestimate of the excess lifetime cancer risk associated withexposure at that intake level. The term "upper bound" reflects theconservative estimate of the risks calculated from the SF. Use ofthis approach makes underestimation of the actual cancer riskhighly unlikely. Slope factors are derived from the results ofhuman epidemiological studies or chronic animal bioassays to whichanimal-to-human extrapolation and uncertainty factors have beenapplied( e.g., to account for the use of animal data to predicteffects on humans).

There are varying degrees of confidence in the weight of evidencefor carcinogenicity of a given chemical. The ERA system involvescharacterizing the overall weight of evidence for a chemical'scarcinogenicifcy based on the availability of animal, human, andother supportive data» The weight " ofevidence classification isan attempt to determine the likelihood that the agent is a human

29

000350

carcinogen, and thus, qualitatively affects the estimation ofpotential health risks. Three major factors are considered incharacterizing the overall weight of evidence for carcinogenicity:(1) the quality of evidence from human studies; (2) the quality ofevidence from animal studies, which are combined into acharacterization of the overall weight of evidence for humancarcinogenicity; and (3) other supportive information which isassessed to determine whether the overall weight of evidenceshould be modified. EPA uses the weight of evidence classificationsystem to categorize carcinogenicity of contamination as one of thefollowing five groups:

Group A - Human Carcinogen: This category indicates that thereis sufficient evidence from epidemiological studies to supporta causal association between an agent and cancer.

Group B - Probable Human Carcinogen: This category generallyindicates that there is at least limited evidence fromepidemiological studies of carcinogenicifcy to humans (GroupBl) or that, in the absence of adequate data on humans, thereis sufficient evidence of carcinogenicity in animals (GroupB2)

Group C ~ Possible Human Carcinogen : This category indicatesthat there is limited evidence of carcinogenicity in animalsin the absence of data on humans.

Group D - Not Classified: This category indicates that theevidence for carcinogenicity in animals is inadequate.

Group E - No Evidence of Carcinogenicity to Humans; Thiscategory indicates that there is no evidence forcarcinogenicity in* at least two adequate animal tests indifferent species, or in both epidemiological and animalstudies.

Several of the initial chemicals of concern have been classified aspotential carcinogens by EPA. Each of these also has been assigneda carcinogenicity weight-of -evidence category. These chemicals arepresented in Table 5 with the respective Referenced Doses andPotency Factors.

Human Health Risk Cftamcteriwiion

For all exposure scenarios, the air pathway contributed thegreatest carcinogenic risk and HI- Direct contact to soil/sedimentand sludge also contributed to the carcinogenic risk. Directcontact to the surface water did not contribute significantly tothe risk. However, the HX do not include the toxic effects of leadand the potential synergistic effects. These estimates suggestthat the receptors are at hazard from exposure to these chemicalsfor potential carcinogenic and toxic effects. The contaminants ofconcern which actually drove the carcinogenic risk and/or HI will

30

000351

TABLE 5Fourth Strttt stia

(tef«f8ffee Poses and Potency FMtorg for Cootarafi'iwts of Concern

Contaminant

Ar-ienitf

l«ryll<un

CAdftfUB

Benzene

TetPsehlorot'tAylerrt

Tricnl<wo«thylene

Hethylene Chloride

Phthatatcs

PCBt

Styrerw

B»n2o(a)pyreftt

Benzo<a) anthracene

8«nzo(b)fluor«nthene

Naphtha lew4

Heptachlor

Chlordtne

Ant isofty

eariun

Copper

LeAd

Hickel

Thalliin

Vanadfua

Zinc

Ketonas5

A Iky I Benzeiies

0) ch I orobefueoes

Phenol(2,4-Oireethyt)

1,1,1"rrfchlor«thane

Bf0<0)iB/lcg-day

1E-3

5E-3

te-3.2

ie-2•

6E-2

2E-2

-

2E-1

46-3

4E-3

&£-3

46-3

5E-4

6£-S

4E-4

SE-2

2E-25

tJD

2E-2

7E-5

TE-3

2E.1

5E-2

2£*0

9E-2

2E-2

%-2

ftfOEl)Bg/ltfl-day

W1

«

MO

-

HO

4

-

w•

NO

-

.

•

-

W

KD

NO

1E-4

NO

rowo..

?3

%-2

2E-1

4E-2

NO

3E-1

CirefnogenCl«8fl

A

«2

91

A

92

B2

82

52

82

B2

B2

fl2

82

-

62

B2

-

•

.

-

•

-

-

-

-

-

.

*

-

Pf(0) ,(ina/ko-dfly) 1

1.8e*i)

fl.46+0

HO

2.9E-2

S.1E-2

1.16-2

"

i.<e-27,7E*0

3.0E-2

1.1E+13

1.1E+03

1.1E+03

-

SE*0

16*0

-

.

-

•h

«

-

-

-

•

.

.

.

'-

P/(U ,<a9/i(g-day)'

S.06*l

&.3E*<;

6.16*0

2.9E-2

3.3E-3

1.7E-2

7.5E-3

-

-

2.06-3

A.1E+0

•

.-

SE+O

1E-*0

-

•

-

-

a.4E-i------.

-

Rf0(0) - Oral reference dosa for non-carcinogenic effects 1.ND msana information rtac detenaioed per HEAST (IWI)HfOtO -Inhalation rafarenca dose for fton-eareinoflenii: effects 2-Dssh Bieara infornBticn not availablePf<0) -Oral pottficy factor for carcinoflenfc tffects S-Proni USEPA Ragfon Vt, personal conriixifcatfon.Pf(!) -Inhalation potency factor for Cflreifwganie affects 4.Used as model for non-carcinogenic effects for PAHs.

5.HEK used as aodel for ketones.

31

000352

be discussed for each pathway:

o-} Current Msk_Charact€rimtwn

The estimated overall risks of carcinogenic effects from exposureto the on-site contaminants for the workers (1.2xl0'4) andtrespassers (2.7xl0'5) are greater than the target risk of IxlO'6.The COCs which drove the risk are Chlorinated Hydrocarbons for theinhalation pathway and PAHs for the soil contact pathway. Theestimated overall His of non-carcinogenic effects from exposure tothe on-site contaminants for the workers (0.89) and trespassers(0.23) are less than the target HI of one (1.0),

The estimated overall risks of carcinogenic effects from exposureto the off-site contaminants for the transient adults (4.8xl0'5),the 7°11 age group (6.5xl0'5) and the 12-17 age group (4.9xl0'5)ar ©greater than the target risk of IxlO'6. The COCs which drove the O")risk are Chlorinated Hydrocarbons for the inhalation pathway and \r\PAHs for the soil contact pathway. The estimated overall His of ^non-carcinogenic effects from exposure to the off-site contaminants .-.for the adults (0.27) , 7-11 age group ( O c 7 0 ) , and 11-17 age group(0.42) are less than the target HI of one (1.0). °

0The estimated overall risks of carcinogenic effects from exposureto the off-site contaminants in the air for the nearby residents(2.1xl0'3) and children at the pool and high school (3.1x10^ for the7"ll age group and 2, IxlO'1 for the 11-17 age group) are greaterthan the target risk of ixlO"6. The COCs which drove the inhalationrisk are Chlorinated Hydrocarbons, Heptachlor and Chlordane.. Theestimated overall HI of non-carcinogenic effects from exposure tothe off "site contaminants for the resident (3.30) and for childrenat the pool and high school (3.00 for the 7"11 age group and 1.?for the 11-17 age group) are greater than the target HI of one(1.0) . The COCs which contributed to the HI are BTEXs, (Benzene,Toluene, Ethylbenzene, Xylenes) and Trichloroethane. Particulateair sampling results for lead were high (17.9 ug/m3) onsite.However, upwind locations were higher (32 ug/m3). Therefore, therisk calculated for children at the pool and the high school ia notattributable to the site, since this location was the upwindmonitoring station.

b) EufurfLSisk Charge femcuion

The estimated overall risk of carcinogenic effects from exposure tothe on-cite contaminants for the future workers (Q.SxiO'4) isgreater than the target risk of IxlO'*. The COCs which drove therisk are Chlorinated Hydrocarbons, Benzene, Heptachlor andChlordane for the inhalation pathway; and PAHs for the soil contactpathway. The estimated overall HI of non-carcinogenic effects fromexposure to the on-site contaminants for the workers (2,60) isgreater than the target HI of one (1.0) . The COCs which contributedsignificantly to the HI are Alkyi Benzene and Ketonos for

32

000353

inhalation; and Chlorinated Hydrocarbons and PAHs for the soilcontact pathway.

The estimated over&ll risks of carcinogenic effects for off-citstransient adults and children on Parcel H and off-site residentsand school children are the same as the current exposure scenario.This is assuming no redevelopment of the off-site areas occurs.

If redevelopment occurs the most reasonable land use would beindustrial, therefore construction workers and full time industrialworkers would be exposed. The estimated overall risk ofcarcinogenic effects from exposure to the off-site contaminants forthe construction workers (3.7xl0'5) and for the future industrialworkers (9.3x10'*) is greater than the target risk of IxlO4. TheCOCs which drove the risk are Chlorinated Hydrocarbons andHeptachlor tor the inhalation pathway; and PAHs and PCBs for the ^aoil contact pathway. The estimated overall HI of non-carcinogenic -effects from exposure t" the off-site contaminants for both typesof worker scenarios ( 1 . 8 ) is greater than the target HI of one r^( 1 . 0 ) . The COCs which contributed to the HI are Alkyi Benzene, uKetones, and Chlorinated Hydrocarbons for inhalation, o

0Qualitative Assessments: Lead was found in high concentrationsthroughout the FSR site (up to 5,000 ing/kg in some locations. Itwas also found at elevated concentrations (up to 1000 mg/kg) inoff"site soil/sediment and waste materials. Since there are nocurrently-accepted toxicity criteria, lead was not quantitativelyevaluated; therfore, a qualitative evaluation was necessary.

Lead and its compounds have a wide variety of industrial uses; assuch, lead contamination is widespread in the environment. Themajor sources of lead exposure in the environment include releasesfrom vehicular exhaust (currently being reduced by EPA fuel leadcontent regulations); discharges from primary and secondarysmelting operations; leaching from lead pipes and solder intodrinking water supplies; and, ingestion of lead-contaminated paintchips, house dust, and soil by children.

The toxic effects of lead depend on the specific compound to whichhumans are exposed. Generally, organic lead compounds, such as thegasoline additive tetraethyl lead, are somewhat more toxic thansoluble lead salts, particularly with regard to the central nervoussystem. This is apparently due to their higher affinity fortissues with high lipid content. Less soluble lead compounds mayalso be less toxic than soluble salts, on the basis of administereddose, because of their less efficient absorption into thebloodstream from the gastrointestinal or respiratory tract.

Lead exposure produces a wide range of adverse effects in humans,ov®r a wide range of exposures. Lead is known to effect thehematopoietic system, the kidneys, the peripheral and centralnervous systems, and the reproductive system. Lead compounds havebeen found to be mutagenic in several test systems, and have been

33

000354

found to cause cancer In several animal bioassays.

Children ara generally Bora sensitive to lead exposures thanadults. The principal concern with regard to lead exposures inyoung children (under age 6) ia the occurrence of impairedneurological development, which nay be associated with a broadspectrum of neurobehavioral disorders. Originally, it waa thoughtthat such effects occurred at laad exposures associated with ablood level greater than 35 ug/dl. Mora r«cant studiee have found•that •uch effects fflay occur at much lower blood lead levels,perhaps &• low aa 10 ug/dl. EPA. currently evaluatee load exposuresIn childran in reference to the latter benchuar^ blood-lead level(10 ug/dl).

EPA has classified lead aa a Claus B2 carcinogon. A number of leadcoBpounde have been found to induce alavated cancer incidence inrats and nice. However, the evidence for the aeBociation betweenlead exposure and elevated cancer rates in apidemiologic studies *- fhuman populations experiencing high lead expoaures is equivocal.EPA has therefore not derived a cancer potency factor for leadcompounds. The EPA has determined that an RfD would not beappropriate to protect children from adverse developmental impactsof lead exposure, due to the complex relationship between leadexpoauree by various routes, blood-lead levels, and the occurrenceof adverse effects. Inatead, EPA had developed a biokinotic nodalfor assessing the impacts of multi-route lead exposures onchildren's blood-lead levels.

EPA reconuaands that this model be used for age groups 0 to 6 yearsto evaluate the health significance of lead exposures using atarget blood lead level of 10 ug/dl aa an indicator of potentialadverse effects. At the FSR a .te thia model was considered, butadapting the model for industrial land use and adult exposuresproduced inappropriate or erroneous information. Alternatively,EPA has provided OSWER (Office of Solid Waste and EmergencyResponse) Directive /9355.4-02, which establishes that an excess oflead in soil of 500 to 1000 ppm is responsible for blood levelincreases in children above background levels. The concentrationsat the fSR site are of such magnitude that exposure to thesomaterials ie likely to be a cause for concern.

Additionally, tha industrial setting of the FSR cite also presentsa problem in evaluating the sir pathway quantitatively. Althoughthe air pathway contributed tha greatest risk and hazard index fororganics detected, a trend is not apparent to suggest that the sitecontributes to the ambient air contaminant levels of theaurrounding area. This is due to high gasoline constituent levelsmeasured upwind of both the FSR and DER sites; probably dua to theareas surrounding both sites being highly industrialized.Similarly, particulate air saipling results for lead were high(17.9 ug/ia3) onsita. However, upwind locations were higher (32u9/"i3) • Therefore, the risk calculated for children at the pooland high school may not be attributable to the eite, since thia

34

000355

location was the upwind monitoring station.

Central TerMncies

BaflQd on a Fabruary 26, 1992, mamorandum from Daputy Administratorr. Henry Habicht, EPA ie raquirad to evaluate both "reasonablemaximum exposure" (RME) and "cantral tandancy" in tha riskassessment at Suparfund •itefi. Tha exposure assumptions associatedwith tha RHE have boan uaad to aatimata tha basalina riaka andultinately tha remedial action goals at sitea. Tha "cAntroltendency" scenario represents the risk from more of an "average"exposure, compared to a "reasonable maximum" exposure.

A compariaon of the differences in the rifik aaauinptiona between theRME and central tendency ia shown in Table 6. For the FSR site thecentral tendency risks would decrease from 3.0xl0'1 to l.OxlO'3 for ,-the current risk and from l.OxlO'2 to 3.0xl0'3 for future risk to ^on-site workers. r-Uncfrfainties Associated with the Human Health Risk Calculations ln

0Within the Superfund process, baseline quantitative risk 0assessiBents are perfonned in order to assess tha potential humanhealth impacts of a given site under currently existing conditions.They are performad in order to provide risk managers with anumerical representation of the severity of contamination presentat the site, as veil as to provide an indication of the potentialfor adverse public health effects. There are many inherent andimposed uncertainties in the risk assessment Methodologies.

This section addresses potential sources of uncertainty in tha riskestimates, possible inpacts of the various sources of uncertaintyand potential bias in the risk estimates. This discussion providesa context in which the significance and limitations of the variousresults can ba better understood to evaluate the overall potentialhealth impacts of the Fourth Street site.

Significant uncertainties are associated with estimates ofexposures and human health risks presented in the risk assessment.The uncertainties in these results are unavoidable in that they alldepend, to a greater or lesser extent, upon many technicaljudgements and, to a lesser extent, upon imperfect mathematicalmodels of physical, chemical, and biological processes.

Several techniques have been developed to address theseuncertainties. These techniques include the following:

• use of multiple exposure and risk scenarios to illustrate therange of variability in risk estimates associated withspecific analytical methods and assumptions;

• qualitative discussion of the levels of uncertainty associatedwith apeclfic models and assumptions, and how they contributa

35

000356

TABI£ 6

Average orCentral Tendency

ReasonableMaximum Eimosure

Contact Ratge f<rJU

Water Ingeation Rates

Children ( 1 - 6 yra)

Adulta

Workers

Soil Ingestion Ratc.s

Children ( 1 - 6 yns)

Adults

Workers

Fish Ingestion Rates

Adults

Air Inhalation Rates

Children ( 1 - 6 yra)

Adults

Dermal Exposure

Adherence factor (AF)

Absorption factor (ABS)

Total Surface Area (SA)

Children

Adults

BQdvWeiahtfi YBW^

Children ( 1 - 6 yrs)

Adult

Workers

0.7 L/day

1 .4 L/day

0.7

200 mg/day

100 lag/day

50 ing/day

6.5 g/day

5 cu. TO/day

20 cu.m/day

0.2 mg/ cm^

Chemical-specific

7,200 c^/event'

20,000 cn^/event

16 kg

70 kg

70 kg

1 L/day

2 L/day

1 L/day

200 ing/day

100 mg/day

50 rag/day

54 g/day

5 cu.m/day (50%)

20 cu.la/day (50%)

1 lag/cm2

Chemical-specific

7,200 cm2/event

20,000 cm2/event

16 kg (50%)

70 kg (50%)

70 kg (50%)

36

000357

Average orCentral Tendency

ReasonableMaximum Exposure

Exposure Duration (ED)

Residential

Industrial

Exposure Frequency (EF)

Residential

Industrial

Averaging Time (AT)

Carcinogenic effects

Noncarcinogenic effects

9 years

9 years

350 days/year

250 days/year

70 years

El)

30 years

25 years

350 days/year

250 days/year

70 years

ED

C, References For, Central Tendency.Exposure Parameters

Central Tendency

Concentration Term (Cl

Site-specific value 95% UCL

contact Rates _ fCR)

Water ingestion Rates

children ( 1 - 6 yrs)

Adults

Basis/Reference

US EPA, 1992a

0.7 L/day

1.4 L/day

0.7

US EPA, 1989a

US EPA, 1989b

Workers 5 0 % Adul t sIngestion Rate

Soil Ingestion Rates

Children ( 1 - 6 yrs) 200 mg/day

100 ing/day

50 nig/day

6.5 g/day

US EPA, 1989C

US EPA, 1989C

US EPA, 1991

US EPA. 1989b

Adults

Workers


Adults

37

000358



Adults

Central Tendency

5 cu. m/day

20 cu.m/day

Basis/Reference

US EPA, 1989a

US EPA, 1989B;US EPA, 1989b

Dermal.Exposure

Adherence factor (AF) 0.2 ing/cm2

Absorption factor (ABS) Chemical-specific

Total Surface Area (SA) '

Children ( 1 - 6 yrs) 7,200 cm2/event

Adults 20/000 c^/event

16 kg

70 kg

.70 kg

-B^dy..Jgei h^S, (BWj.


Adult

Workers

US EPA, 1992b

US EPA, 1989a;US EPA, 1989b

US EPA, 1992b

US EPA, 1989b

US EPA, 1989b;US EPA, 1991

US EPA, 1991

Exposure Duration fED)

Residential 9 years

Industrial 9 years

US EPA, 1989b

= to residential

£>cpos_ur_e Frequency (.EF)

Residential

Industrial

AveraqlngTime (AT}

Carcinogenic effects

Noncarcinogenic effects

350 days/year

250 days/year

70 years

ED

US EPA, 1991

US EPA, 1991

US EPA, 1989b

US EPA, 1989b

38

000359

D_._Re_asonable Maximum Exposure Parameters

Xeaso_nabl'e_ Maximum

Concentration Term (Cn

Site-specific value 95% UCL

Contact Rates__(CR).

Water Ingestion Rates


Adults

1 li/day

2 L/day

1 L/day

200 Big/day

100 fflg/day

50 mg/day

54 g/day

5 cu. la/day

20 cu.m/day

30 cu.m/day

Workers

Soil Ingestion Rates


Adults

Workers


Adults



Adults

Adults

39

US EPA, 1992a

US EPA, 1989a

US EPA, 1989b;US EPA, 1991

US EPA, 1991

Average value,US EPA, 1989C

Average value,US EPA, 1989C

Average value,US EPA, 1991

US EPA, 1991

US EPA, 1989a

AverageUS EPA,US EPA,

value,1989a;1989b

Upper bound ifUS EPA, 1989a;US EPA, 1989b

000360

Dermal Exposure

Adherence factor (AF)

Absorption factor (ABS)

Reasonable Maximum

1 ing/cm2

Chemical-specific

US EPA, 1992b

Total Surface Area (SA)

Children ( 1 - 6 yrs) 7,200 cn^/event

Adults 20,000 cm2/event

16 kg

70 kg

70 kg

Bo_dy Weights _ fBW)

Children (1 ~ 6 yrs)

Adult

Workers

Exposure Duration (EPI

Residential 30 years

Industrial 25 years

Average value,US EPA, 1989a;US EPA, 1989b

Average value,US EPA, 1992b

Average value/US EPA, 1989b

Average value,US EPA, 1989b;US EPA, 1991


US EPA, 1989b;US EPA 1991

US EPA 1991

Exposure Frequency /EF^

Residential 350 days/year

Industrial 250 days/year



^veragjing YiM. ML

Carcinogenic effects 70 years

Noncarcinogenic effects ED

40

US EPA, 1989b

US EPA, 1989b

000361

K. References

OS EPA. 1989a. Exposure Factors Handbook. EPA/600/8-89/043.

US EPA. 1989b. Risk Assessment Guidance for Superfund, Volume I,Human Health Evaluation Manual (Part A) . EPA/540/1-89/002.

OS EPA. 1989c. Interim Final Guidance for Soil Ingestion Rates.OSWER Directive 9850.4.

US EPA. 1991* Kisk Assessment Guidance for Superfund, Volume I,Human Health Evaluation Manual, Supplemental Guidance, StandardDefault Exposure Factors. OSWER Directive 9285.6-03.

US EPA. l992a. Supplemental Guidance to RAGS: Calculating theConcentration Term. Publication 9285.7-081. r"'

v0US EPA. 1992b. Dermal Exposure Assessment: Principles and r-Applications. EPA/600/8-91/011B. ^

0

0

41

000362

to uncertainties in the overall assessment; and,

• use of probabilistic risk models or formalized sensitivityanalyses which quantify uncertainties in each step of the riskassessment.

The approach taken in this assessment has been to apply acombination of the first two methods, multiple exposure and riskscenarios and qualitative discussions of uncertainty in specificaspQcto of the models, to characterize the level of uncertaintyassociated with risk estimates. One probabilistic model wasperformed to examine the assumptions used in this risk assessmentand to illustrate the uncertainty. Multiple exposure scenarioshave been developed which illustrate the potential range ofexposures that can occur at the site under present and possiblefuture use. Exposures have been assessed with regard toindividuals in multiple age categories as a means of determininghow physiological and behavioral characteristics of thesepopulations might affect exposure and dose levels.

The overall strategy employed in assessing exposures has been todefine methods and assumptions in such a way aa to developreasonable maximum estimates for all of the major assumptions usedin the risk modeling. That is, where there is a range of models tochoose from, or a range of parameter values to be used in thesemodels, the specific models used and parameters chosen are thosewhich are at the upper-bound of realism and reasonableness, basedupon professional judgement and information available in theliterature. The overall impact of this technique on the assessmentof risks is to generate results which, if assessed in aquantitative probabilistic way, would lie at the upper end of theexpected probability distribution of risk. It is unlikely thatactual risks calculated for any pathway will exceed thosepredicted. For example, if it is assumed that a given riskestimate is derived from three independent models of contaminantconcentrations/ contaminant transport, and dose/riskcharacterization, and that the parameter values chosen for use ineach model are at or above the 90-percent upper-bound confidenceinterval of their actual expected value, then statistically, theprobability that the resulting risk estimate will exceed(overestimate) the actual risk will be 99.9 percent. That is,there would be only a O.I percent (one in one thousand) probabilitythat actual risks will exceed calculated risks. '

Ecological Risks -: ''.Ss^

The baseline ecological risk assessment, performed by the EPA,provides a qualitative evaluation of the environmental risks at theDouble Eagle site. The site ecology was evaluated to determine ifthe contamination from the site was causing any significant adverseecological impact. ..StSHSHSS^:

The ecological risk assessment is aummarizedAaa«£oUows:

42

000363

a} Receptor Characterimtion and Emipoints

fieceptor Characterization: Potential environmental receptorsinclude fish populations in the North Canadian River, woody orherbaceous (non-woody) plants, birds or mammals feeding on thisvegetation, and animals incidentally using the open water areas(•migratory waterfowl and mammals).

Site visits have resulted in observation of a killdeer with itsneat of eggs on the Fourth Street site. Small tadpoles have beennoted in the larger impoundment on site. Turtles and froga havebeen observed at the Double Eagle site. Rabbits are common in thearea of both sites and egrets and other migratory waterfowl havebeen sited at the impoundents on parcel H.

A site survey during collection of samples for the toxicitytesting on Parcel H demonstrated that no minnows were available inthe impoundments that could be collected for bioaccumulationstudies, as originally planned. A black snake, believed to be aKing Snake, of about 6 feet in length was encountered at the RadioTower Area.

Impoundments on both sites appear on the National wetlandsInventory Maps (NWI) (U.S. Dept. of Interior, Fish and WildlifeService, 1989) . However, since these NWI maps were developed (themapping process began in 1991) , site changes have likely occurred.These maps are baaed on interpretation of aerial photographs andnot actual site surveys.

The Parcel H area incudes three different classification areas:PUBFx, PUBHx, and Palustrine, Emergent, Semi-Permanently FloodedWetlands (PEMF).

Vegetation around open water areas at Fourth Street and Parcel Happears to consist of grasses, likely to be prairie grass speciesrather than wetlands species. The former operations area of FourthStreet and the Eastern Drainage and Parcel H areas appear to havegrass and shrubby vegetation. They are generally open areas thatmight not provide much shelter or food for permanent populations ofwildlife species other than small mammals as mentioned above.

Endpoints: Biological Integrity: An assessment endpoint is themaintenance of biological integrity (i.e., the maintenance of thestructure and function of aquatic ecosystems). The measurementendpoints for this assessment endpoint will be "toxicity" asdemonstrated by aquatic toxicity tests. The objective of aquatictoxicity tests is to estimate the "safe" or "no effect"concentration which permits the normal propagation of fish andother aquatic life (U.S. ERA 1988). Toxicity testing assessed thetoxicity of the oily wastes from the site on aquatic life.

43

000364

b} Toxtcohgical'Respowe. ./^e^fflg^

Heavy metals, lead and chromium, present long-term threats andcould present a serious environmental effect. Due to the habitat,impacts on the aquatic environment would be more serious thaneffects on the terrestrial environment. Therefore, only aquaticeffects were studied.

Toxicity tests were conducted on water from the Parcel Himpoundments (Bio-Aquatic Testing, 1990), in which Ceriodaphniadubia survival and reproduction, Pimepbales promelas. larvalsurvival and growth, and bacterial luminescence (MicroTox tests)were measured. Results of toxicity tests indicate that impoundmentwater could have toxic effects on aquatic life. The maintenance ofbiological integrity in these impoundments could be impaired bysite related contaminants.

cJ Exposure Assessment

There is no current drainage connection between the sites and theNorth Canadian River, although it should be noted that there was aconnection in the past. Potential impacts of the sites on fishpopulations, esnecially game fish, are not currently an issue giventhe assumption that the impoundments do not support a fishpopulation. However, other on-site environmental receptors couldbe exposed to site related contaminants. These receptors might bewoody or herbaceous (non-woody) plants growing in locations ofrelatively high contamination, birds or mammals feeding on thisvegetation, and any organisms (migratory waterfowl and mammals)incidentally using the open water areas.

d} Risk Characterization

The EPA indicates that environmental receptors, in particularmigratory fowl, could be adversely affected by site relatedcontaminants. Toxicity tests indicate that the potential for toxiceffects from the Parcel H impoundment water on aquatic life doexist. The analytical result from surface water samples from theParcel H impoundments indicate that the chronic water qualitycriteria for copper, and the chronic and acute water qualitycriteria for lead were exceeded. Therefore, the maintenance ofbiological integrity in these impoundments could be impaired bysite related contamination.

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response action selectedin this Record of Decision, may present an imminent and substantialendangerment to public health, welfare, or the environment.

44

000365

vn. REMiaMAL ACTCttLGQALS

Reeultfl of fiold invaatigationo, laboratory test raeultf, andengineering analyses have identified the following contaainantsource areas on the FSR site with associated affected aedia:

&Uff AreaTar mat area

Pipe yard area

Impoundments

Exposed waste(off-site)

Structures

H«&iaSludge, debris and air

Sludge and air

Sediaent, surface water and air

Sediment, surface water and air

Tank stands, concrete foundationsand debris

Principal threat wastes are those source materials considered to behighly toxic or highly mobile that generally cannot be reliablycontrolled and that present a significant risk to human health orthe environment should exposure occur. The principal threats atthe FSR site are the acidic sludges and contaminated ponds. Thesediscrete waste areas present the most significant risk at the site,due to the potential for exposure to lead through direct contactand inhalation. The riek is also increased due to the concentratednature of the waste which presents a high potential for migrationof contaminants to surrounding areas and the underlying groundwater.

Low level threats are those source materials that generally can bereliably managed with little likelihood of migration and thatpresent a low risk in the event of exposure. The low level threatsat the site are the contaminated soils and tar matrices, both onand off-site, ^hese areas are not as highly mobile as tha acidicsludges and the material in the ponds on-site and the concentrationor contaminants is more dilute which decreases the risk frompotential exposure,

The principal threat at the FSR site is posed by direct contact andinhalation, and potential for migration of contaminants to theground water. The remedial objectives are to miniaiisge potentialexposure by direct contact or inhalation; and to reduce thepotential for migration of contaminants into the surface waters andground waters.

During the RI/FS project fcr the FSR site, the issues related tothe ground waters beneath the site were acknowledged as complex incomparison to those issues apparent for the source contamination.Although shallow and deep wells were installed around the pariaieterof both the FSR and DER sites, the determination of vertical end

45

000366

Xataral aigration of contaminants will requira further s.tudy. Thaiwpact of the xigration of contaminants in ground wat«r and surfacawater will ba addrassad In A future ROD, Oparabia Unit 3(Groundvater Operable Unit - GOU) . This ROD will address thasource of contaaination at tha FSR site, Oparabia Unit l (SourcaControl OparabXa Unit - SCOU) .

As diacuasad in tha Riak Charactarization •action, tha surfacevfttar praaant at tha F6R aita doaa not poaa a significant thra&t.ThA PAHa, PCBa and laad found in pond aadiaanta and aludaas poaatha Bo«t significant thraat (carcinogenic axcass rinks) dua todir«ot contact. Tha Chlorinatad Hydrocarbons, Hftptachlor,Chlordana, BTEXa (Banzana, Toluana, Kthylbanzana, Xylana),TrichXoroathana, Alkyi Banzana and Ketonae poaa tha Boat•ignifleant throat (carcinoganic axcaaa riaka) dua to inhalation.

Since the romadial action goal for tha PSR flito ia to oliminata orreduca riak to human health and tha anvironiaont, targat actionlevola for aoil, •odimantfl, and aludga« hava b«an GfitabllBhad. Aadiacuaaad in tha Qualitative AaaaaflmGnt eoction, tha OSWER guidancevaa utilizad for load. ^ target action loval of 500 ppa for laadwill be utilized, baaed on industrial land use for the DEH Bits.For PCBa, a targat action laval of 25 ppm corraapondx to the ToxicSubatancea Control Act cleanup level for induatrial lend uae.However, the maximum concontration of PCBa detected at the DER aiteifl Buch less than thia level and therefore already moeta theremedial objectivea. Por PAHs, a target lavel of 30 ppm TotalBanzo(a)Pyrene Equivalents has been set. This concentrationrapreaenta approxi»ately n 10'1 excess cancor riak and was selectedbased on Regional guidance for setting reioadial goals for PAHs.

By addressing tha source of contamination at the DER site (soils,sodiroonts/ and sludges)^ the risk associated with the air pathwaywill be eliminated. Howsvor, shorfe-t&rai risks du® to air emissionsduring a remadial action will also be addressed by usa of Region 6Standard Operating Procedures (SOP) for air emissions, duringremedial dseign. The SOP for air emissions is dated November,1991.

Vm. DESCRIPTION OF ALTERNATIVES

A Feasibility Study was conducted to develop and evaluate remedialalternatives for tha PSR fiito. Remedial alternatives ware assembledfrom applicable remedial technology process options and wereinitially evaluated for effectiveness, iaplementability, and costbased on engineering judgement. The alternatives eelected fordetailed analysis were evaluated and compared to the nine criteiarequired by the NCP. As a part of the evaluation, the NCP requiresthat a no-action alternative be considered at avery site. The no-action alternative serves as a point of comparison for the otheralternatives.

46

000367

The Romedial Action Goals aet tor the FSR Bite are theconcentration levels balow which the aodia can be left in-placewithout treAtBent. The descriptions and evaluations of remedialaction alternatives included in thia ROD addressee surfacecontamination, contamination asBOciatod with surface aoil and thematerial in the impoundments on the main sit®, •oiX and sludges onParcel "H". Ground water contamination will be investigatedneparataly in the GOU. Upon completion of thia investigation, 1!PAwill propose a plan of action to addreee any potential problemsfrom ground water contamination identifed at the aite.

The deftcriptionB and evaluations of remedial action alternativesare Reparated into coven alternatives addresaing contaminated•ediaents, aurface aoila, euface water, and sludges*

Remedial Action Alternatives

The remedial action alternatives for the SCOU are presented belowwith a description of the common elements contained in eachalternative.

• Alternative l• Alternative 2• Alternative 3• Alternative 4

• Alternative 5

• Alternative 6

Alternative 7

No ActionLimited ActionOn-eite Stabilization and CappingOn-site Stabilization and Disposal in anOn-site LandfillOn-site Stabilization and Disposal in anOff-site LandfillExcavation, On-site Incineration, andOn-siteCapping of AshExcavation, Off-site Incineration and

Disposal of Ash

Common Elements

All of the SCOU alternatives, with the exception of Alternative 1,have the following common elements: flite preparation; theinatallation of office, storage, and security facilities; theinstallation of surface water runoff control measures; installationand maintenance of warning signs and fencing; placement of a noticeto the property deed warning of site hazards; restoration of thesite surface upon completion of the remedial action; and airmonitoring and dust control to minimize any potential short-termadverse health effects during the remedial action.

All of the alternatives, with the exception of Alternative 1 and 2,involve treating and/or containing soils, sediments and sludgeswhich have contaminant concentrations that exceed remedial goals.These alternatives were developed to address the specific mixtureof wastes at the FSR site. The high concentration of lead at thesite precludes biological treatment as an alternative and increasedthe need for air pollution controls and residuals treatment for

47

000368

incineration. The low organica concentration in the sludges (belowhealth baaed cleanup levels) allowed stabilization to occur, aa•hown in treatability studies, conducted in the feasibilty study.

All coats and implementation times are estimates. The costs havea degree of accuracy of +50% to -30% pursuant to the "Guidance forConducting Remedial Investigations and Feasibility Studies UnderCERCLA - Interim Final" OSWER Directive 9955.3-01, October 1988.

A brief description of the seven alternatives evaluated to addresscontaminated sludges, sediments, surface soils, and surface watersfollows;

Ahemafi^ 1: M? Action

Alternative 1 is a "no action" alternative for contaminatedsludges, sediments, surface soils, and surface water. Thisalternative does not provide a means for source control or theaonitoring of the environmental media to determine if contaminantreleases are occurring.

Ho action alternatives are normally evaluated to determine what thethreat would be, based on a risk assessment, to human health andthe environment if no further actions were taken. The riskassessment performed assuming a no action alternative provides abaseline for the comparison of other alternatives. The no actionalternative would not reduce or eliminate the threat posed by thecontaminants of concern presently on-site; therefore, the remedialaction objectives would not be met. Without enhanced sourcecontrol, contaminant releases into the air and groundwater couldoccur, potentially endangering human health and the environment.

Although the no action alternative would not reduce the risk fromthe site, the MCP requires that the no action alternative becarried through to the detailed analysis of alternatives. The noaction alternative will therefore be carried through to provide abaseline of comparison to the alternatives utilizing remedialaction.

There are no costs associated with Alternative 1.

dIfmQfm ; JMM..Actm

Ma-lor components of the Limited action Alternative: Components ofthis alternative include: consolidation of approximately 1,200cubic yards of contaminated waste material from Parcel H; nettingthe ponds on-site to comply with Migratory Bird Act; constructionof security fencing and posting signs around the site; deed noticesto identify material remaining on-site; perpetual operation andlaaintenance of the site; and five year reviews of the remedialaction.

43

000369

Access restrictions would be provided by the construction of afence with the addition of a sufficient number of warning signssurrounding the site. This would restrict access to the site byunauthorized persons and possibly wildlife inhabiting thesurrounding environment. A deed notice would be filed to notifyfuture land owners of the hazards associated with this site. Fiftyper cent of the volume of the waste from Parcel H (1,200 cubicyards), which is above the remedial action goals discussed inSection VII of this ROD, will be consolidated with the material onthe site. This operation will eliminate the risk from exposure totha contaminants of concern and the need for fencing, deednotification and perpetual maintenance for Parcel H. The excavatedoff-site areas will be backfilled to grade with clean fill.Perpetual maintenance to ensure the integrity of the nets andfences onsite would be requir&d.

General Components; The estimated time to implement this remedy is12 months. The estimated cost associated with implementingAlternative 2 are: Capital Costs: $150,000; Annual Operation andMaintenance Costs: $10,000; Present Worth; $300,000.

Alternative 3: On-sile Stabilisation and Cappine

Ha-ior Components of the Remedial alternative. The major features ofthis alternative consists of the consolidation of off-site wastes(as discussed in alternative 2), neutralization of the acidicwastes and In-situ stabilization of 42,000 cubic yards of materialcontaminated above the target levels discussed in Section VII ofthis ROD, installation of a Subtitle C cap (approximately 2 acres)over the treated waste, fencing, warning signs, deed notice,perpetual maintenance and 5 year reviews. Perpetual maintenance isrequired because the waste materials will remain on site as aresult of this reaediation effort.

Treatment components: Alternative 3 utilizes an in-situstabilization/ solidification technology as a treatment process forthe waste material. Sfcabilization/solidification of the wastematerials utilizing commercially available materials such asflyash, kiln dust or portland cement, will provide a neutralizedend product of sufficient structural strength to support a finalcover system.

Stabilization refers to the transformation of the waste into a formwhere chemical reactions, or the potential for chemical reactions,is eliminated over the long-term. Stabilization would place theinorganic contaminants, like lead and other heavy metals, in a lesssoluble form and t* °re£ re, reduce the mobility of the contaminant.Solidification doe3 not necessarily involve a chemical interactionbetween the waste and the aolidifying agents, but may mechanicallyencapsulate the waste into a monolith. Contaminant migration isrestricted by decreasing the surface area exposed to leachingand/or by isolating the wastes within an impervious capsule.

49

000370

Treatability studies conducted as part of the feasibility studyindicate that stabilization/ solidification is an effectivetechnology for the wastes at the FSR site. The results of thesestudies are shown in Tables 7 and 8, These results indicate thatfollowing treatment, none of the TCLP chemicals were detected abovetheir respective TCLP regulatory levels (40 CFR Part 261.24) . Theoptimum mixture yielding these results was 150% kiln dust and 10%liffif-' by weight. The low levels of organic COCs and PCBs allows thestabilization/ solidification to occur, while immobilizing the leadas well. This alternative will meet the Remedial Action Goals byminimizing potential exposure by direct contact or inhalation, andreducing the potential for migration of contaminants into thesurface waters and ground waters.

Implementation of this alternative will require demolition of somestructures on the site. Contaminated off-site soils from Parcel Hwill be excavated and consolidated with the materials onsite. Thestabilization/ solidification process will require the addition ofkiln dust and lime, resulting in an increase of volume of waste tobe disposed by 30%. The total volume of treated waste is estimatedto be 54,600 cubic yards. There is an acceptable amount ofdisposal capacity at the FSR site.

containment components; Consolidation of adjacent contaminatedsoils will allow the stabilization/solidification process to becentrally located on the la^uon site and reduce the area needed fordisposal. The estimated area necessary for disposal of the treatedwaste is 2.4 acres, and will be capped and closed as a RCRASubtitle C landfill in accordance with the requirements specifiedin 40 CFR 264.310 for landfill closure, which will require a cap tohave a permeability less than or equal to the permeability of thenatural underlying soil. Closure of the area would also complywith the State of Oklahoma requirements. The cap will be designedand constructed to promote drainage, minimize erosion of the cover,and provide long-term minimization of migration of liquids throughthe underlying contaminated soils. Consistent with therequirements of 40 CFR 264.117, long-term operation and maintenance(O&M) would be conducted to monitor the ground water around thelandfill and to ensure the integrity of the cap.

The stabilization/solidification process will be performed in-situwith heavy construction equipment such as a backhoe and proceedsequentially froa one end of the lagoon to the other. Generally,treatment of the waste material will be performed within the areaof contamination (sludge lagoon) followed by excavation,stockpiling or placement in an area previously treated andexcavated to the remedial action objective. Throughout treatment,a buffer zone will be maintained to separate treated material fromuntreated material allowing complete treatment and excavation ofwaste material in excess of the treatment standards. The above-ground containment dikes will be reinforced structurally by thesame stabilization/ solidification process to support the final

50

000371

Table 7 •TCLP Data Summary

Fourth Street Site

Sludge Composite Admixture Ratio:(% iin dust / % lime)

Analvte fmq/L)Inorganic

BariumCadmiumChromiumLead

Organicp-Cresot

RAWanalytical

< 0.100.050.028.16

0.137

FS350/0

analytical correctedianafyticat

0.330.06

< 0.011.87

< 10.0

0.500.09

< 0.022.81

< 15.0

FS450/1

analytical corrected[analytical

0.300.06

< 0.011.48

< 10.0

0.450.09

< 0.022.23

< 15.1

FS550/5

analytical correctedS analytical

0.360.02

< 0.010.44

*

0.560.03

< 0.020.68

*

TCLPRegulatory

Level

100.01.05.05.0

200.0

* Not analyzedNote: "Corrected Analytical" data represent concentration values that have been adjusted to 100 % sludge.

Sample dtution results from the addition of reagents.(i.e.. Sludge sample weight + KHn Dust weight + lime weight / Sludge sample weight = Correction Factor)

0 0 5 7 7 7

000372

T&Ms, 8TWA Data Summary

Fourth Street Sttft

Sludga '^o'mpoafta # FS 3 FS 4 i-S 5AdmbctUJ'tf Ralfo:

f% Kitn Out / % Umo^

i 1 1 ' "•'Y1" "'W.———.Inorganic

AraflnieBariumCadmiumChromiumLaadMercurySeleniumSilver

VoffttBe OrganicBanwnftn-ButylbBnzBnesac-Sutylbenzonetart-Butylbenzenet .2 - Dfohlorobanzono1,3-0tchtofoben»net .4 - Qichtofob&nzenBElhyiba ciienstsopropylbonzeoep-lsopropyltoluenoMelhyt faobutyl kalanaMathylena chiaridaNttptWhatenen—PropytbonzeneTotuweTrichtocoalh»no1,2,4 -Trtmothy(b*rc»na1.3,5-Trimathyf benzeneTotal Xytonaa

Sami-volttt* OrganicAnthracenePhenanthrana1.2-OtchEorobenzanft£- MothytnaphthalwnoNcphthaf«ne

RAWAftBfyUoftI

< 12.8190

7.54I S.I

7810•

< 12.60.89

0.9022.241.062.0229.71.114.422.04

0.883< 0.050

*

•= 0.05011.62.274.01

0.58315.68.287.33

26.732.825.025.025.0

SOanaJytJoai

2.4303104.1S

12.202250

< 0.310< 0.125

0.28

< 0.50< 0.50

0.90< 0.50

15.70.602.001.020.571.80

< 0,5016.4012.601.55

51.70< 0.50

12.807.253.51

< 100< 100< 100<: 100< 100

/0sweated•naMJccI

3.6454656.23

18.303375

< 0.465< 0.186

0.42

< 0.75< 0.75

1.35< 0.75

23.60.903.001.S30.862.65

< 0.75246018.902.33

77.55< 0.75

19.20i&.Ba5.27

< ISO< 150< 150< 150< 150

SOn 50<an«ty1to«f oorfctild Bn«*ytto«(

(k:n*(ytfc«{ 1

2.160315

S.W6.972570

< 0.310< 0.125

0.26

< 0.50< 0.50

0.92< 0.50

15.60.572.010-890.542.16

< 0-501.83

12.901-47<.78

< 0.5012.407.033.20

< 100< TOO< 100< 100< 100

3.2624765.88

13.543881

< 0.466<; 0.189

0.39

< 0.76< 0.76

1.39< 0.76

23.60.863.041.3tO.B23.29

< 0.762.76

19.432.227.22

< 0.7618.7210.624.63

< l5f< t5f<: 151< t5l< 151

1.062310

2.&T9.752160

< 0.310< 0.125< 0.25

•*••

•«•••***«•*•••

••••*

/5oorraotod•nalvtfoai

1.6464813.67

15.113346

< &,481< 0.194< 0.39

•••••«••••••••**•••

•0

•

•

«

* Not anaJyzadNota; 'Corrooted AnatytfooP data fpraaent cono»rrtratlon values that h*sw bean ftdfuttodto 100 % stuffy.

Sample dilution rosufb from the addition of reagents.(!.«., Studgo oamplft wwfght + Kiln Dust weight + Lfmo weight / Sludgo sampio weight " Corractioo Fccto^

0 0 5 7 7 3

000373

cover. Contaminated surface water will b« utilized for dustcontrol and ae an admixture with the etabilization/ Bolidificationreagent(a) to iaprove mixing efficiency. Capping the aite willeliminate the risk from direct contact and inhalation exposure.The stabilization proceae will immobilize the contaminants andminimize the potential for future ground water contamination.

General Components: Tha estimated time to implement thia remedyand to meet the cleanup levels is 24 souths. The estimated costsfor this alternative are: Capital Costs: $4,900,000; AnnualOperation and Maintenance Costs: $ 10,000; Present Worth s$5,100,000.

Alternative 4: On-site Stabilization and Disposal in an On-site Landfill

Ha^or Components of the Remedial Alternative. The major features ofthis alternative 4 consists of neutralization of the acidic wasteand immobilization of the inorganic contaminants in place withstabilization/solidification technology, excavation of theneutralized waste, construction and placement of approximately54,600 cubic yards of the treated waste into a new on-site landfillwith a cap system, meeting the requirements of the RCRA Subtitle Dregulations, 40 CFR Part 258, backfilling the excavated areas,installation of fencing and warning signs, deed notification,perpetual maintenance and 5 year reviews. Perpetual maintenance isrequired because the waste materials will remain on-site aa aresult of this remediation effort.

Treatment Components; Alternative 4 utilizes the samestabilization/ solidification technology as described underAlternative 3, however the waste material will be encapsulated ina new on-site landfill (bottom and cover) constructed meeting therequirements of the RCRA Subtitle D regulations. The RCRA SubtitleC cap utilized in Alternative 3 is deleted from this alternative infavor of the base liner and capping requirements identified underSubtitle D. The RCRA Subtitle D criteria are typically associatedwith municipal solid waste landfills, and is appropriate becausethe stabilization process will remove the hazardous characteristicsof the waste.

Upon neutralization of the waste utilizing stabilization/solidification technology, the resulting waste mass is assumed tobe a nonhazardous waste by not exhibiting the hazardous corrosivitycharacteristic or exceeding the limitations identified in theToxicity Characteristic Leaching Procedure rule. Treatabilitystudies, as described in Alternative 3, indicate thatstabilization/ solidification to meet these criteria can beaccomplished. By meeting these two criteria, the waste may bedeposited in a Subtitle D landfill. The alternative descriptionfor the remaining portions of Alternative 4 will apply to thisalternative. However, stockpiling of treated material will benecessary prior to placement in the landfill.

53

000374

Contaiaaant Coaponontu The additional raquircBenta associated withthis alternative involve the conittruction of a new on-aite landfillMating the RCRA Subtitle D raquireiBanta idantifiad under 40 CFRPart 258 (Subpart D) . A RCRA Subtitle D landfill incorporates theuae of a single compoaite bottom linor ayetem or an altarnatabottom liner ayrtam masting tha parformanca requirements idantifiadin 40 CFR Part 258. Tha RCRA SubtitlQ D requirements idantifiadundar 40 CFR Part 258 hava baan approvad by ERA. Theseraquiramanta ara not presently effective, but ara expected to baaffoctiva bafora disposal activities will ba accomplished. TheState of Oklahoma is currently •aeking approval of their raviaedSubtitle D permitting program. A coapoaite liner ayatem conaiataof two components; tha upper component must be a minimum 30-milflexible membrane liner, and the lover conponent must be of atleast a two-foot layer of compacted coil with a hydraulicconductivity of no more than 1 x 10'7 cm/eec* The composite linersystem decreases the potential for leachate to escape the containedlandfill cell.

The cover system will meet the requirements outlined in 40 CFR Part258.60, Closure and Post-Closure Care, and will be comprised of anerosion layer underlain by an infiltration layer comprised of aminimum of 18 inches of earthen material that has a permeabilityless than or equal to the peccability of the bottom liner systemor natural subsoils present, or a permeability no greater than 1 x10"5 cm/sec., whichever is less. Upon completion of the landfillingoperation, portions of the site area unused by the on-site landfillwill be backfilled with clean imported fill material. Aspreviously described under Alternative 3, contaminated surfacewater will be utilized in the stabilization/ solidificationprocess.

Implementation of this alternative will require demolition of theon-site equipment, tankage and structures, to provide sufficientarea for construction of the new landfill cell. Demolition of thesite structures will provide sufficient area to stockpile treatedmaterial prior to construction of the landfill and placement of thetreated material into the landfill. The new landfill cell willutilize approximately 4 acres, at a depth of 10 feet, with thebottom of the landfill cell a minimum of 5 feet above the seasonalhigh groundwater elevation. Since the depth of the sludge lagoonis within 5 feet of groundwater, a 5 foot layer of fill materialwill be placed in the excavated sludge lagoon area prior toconstruction of the landfill. The landfill cover will eliminatethe risk from direct contact and inhalation exposure. Thestabilization process will immobilize the contaminants and minimizethe potential for future ground water contamination.

General Components! The estimated time to implement this remedy andto meet the cleanup levels is 24 months. The estimated costsassociated with implementing Alternative 4 are: Capital Costs;$7,100,000; Annual Operation and Maintenance; $10,000; PresentWorth: $7,300,000.

54

000375

Ahf.twsfiw S- On-sile Stabilsiarion and Disposal in an Off-silt Landfill

M^or Componanta of the R*m«dial Alternative. The major features ofAlternative 5 involves the neutralization of acidic waste andimmobilization of inorganic contaminants in place utilizing•tabilization/solidification technology, excavation and shipment ofapproximately 54,600 cubic yards of the non-hazardous vast* to acottaarcial landfill, and backftiling the excavated area with cleanimported fill malarial. Thi« alternative would constitute a cleanclosure for the aite and would not necessitate fencing, warningf'.gna, deed notices, perpetual maintenance or 5 year reviews.

Contai&aant Components< Alternative 5 is the saiae as Alternative 4,except this alternative involves disposing the wastes at apermitted off-site landfill meeting the requirements of RCRA. Theoff-site materials on Parcel H will be excavated and consolidatedwith the material onsite for treatment. Implementation of thisalternative will require demolition of above-ground structuresonsite. Material will be neutralized and stabilized/ solidified toremove the hazardous corrosivity characteristic of the waste, andexceedance of the toxicity regulatory limits sot in 40 CFR Part2 6 1 . 2 4 (Toxicity Characteristics Leaching Procedure). By meetingthese two criteria, the waste may be deposited in an off-siteSubtitle D landfill meeting the RCRA requirements identified under40 CFR Part 258 (Subpar-^ D) . Off-site transportation of thetreated waste will be in accordance with the applicable Departmentof Transportation regulations. Waste not treated to remove thecorrosivity or that exceeds the toxicity regulatory limits aftertreatment will require disposal at a RCRA Subtitle C facility.Addition of the neutralizing reagents will increase the volume ofwaste material to be disposed by approximately 30%. As previouslydescribed under Alternative 3, contaminated surface water will beutilized in the stabilization solidification process.

The neutralized and conditioned waste material will be excavated,loaded on trucks and transported to a permitted off-site facility,aeeting the requirements of a RCRA Subtitle D landfill^ anddisposed. Excavated areas on and off-site would be backfilled,graded, and revRgetated. Backfill materials will consist of cleanimported material. The risk from direct contact and inhalationexposure, and the potential for future ground water contaminationwill be eliminated by completely removing the waste from the FSRsite.

General Components: The estimated time to implement this remedy andto meet the cleanup levels is 24 months. The estimated costsassociated with implementing Alternative 5 are: Capital Costs;$6,400,000; Annual Operation and Maintenance: Hone; Present Worth:§6,400,000.

55

000376

Alternative 6: Excavation. On-site Incineration, and On-site Cappine of Ash

Ma-^er Conponentg of the Remedial Alternative: The major features ofthis alternative involves the consolidation of off-site waste, asdiscussed in previous alternatives, neutralization of acidic wastein place utilizing stabilization/solidification technology,treatment of the waste in an on-site incinerator for thedestruction of organics, stabilization and disposal of residualash, installation of a RCRA Subtitle c cap, fencing, warning signs,deed notification, perpetual maintenance and 5 year reviews.Perpetual maintenance is required because the waste materials(metals) will remain on site as a result of this remediationeffort.

Treatment Componentss Alternative 6 involves the on-siteneutralization, excavation and destuction of the organiccontaminants of the waste material in a transportable on-siteincinerator, on-site stabilization/ solidification and disposal of r^the incineration residues and backfill of the unused excavated area ir\with clean imported fill. Neutralization is required due to the ocorrosivity characteristic of the waste and its effect on the -^incineration equipment. Operation of the incinerator would be inaccordance with RCRA (40 CFR 264 Subpart 0).

C\l

CO

Several forms of transportable incinerators are presently availablefor the treatment of CERCLA wastes. Many are equipped with highefficiency, off-gas scrubbers and particulate removal systemsessential for the compliant treatment of the Fourth Street wastes,High efficiency emission control systems may be a major factor toevaluate due to considerable lead contamination. Lead in thewastes will volatilize at temperatures below those of an operatinghazardous waste incinerator and will be entrained in the off-gasprocess stream. High efficiency off-gas scrubbing systems arecapable of precipitating the metal from the gas stream and removingit as a blowdown solid. The transportable incineration processesthat are applicable for the on-site treatment of the Fourth Streetwastes include rotary kilns, circulating bed combustors andinfrared furnaces. These systems are similar in operationalcharacteristics as those found at permanent installations. Processunits are skid mounted for transportation and are connectedtogether when mobilized to the site. Selective demolition anddisposal of on-site equipment and tankage is required toaccommodate a transportable incinerator, off-gas scrubbing system,blowdown water treatment facilities, materials handling(pretreatment) units and other ancillary equipment necessary foreffective and efficient operations. The total area required forthe incinerator and ancillary equipment is approximately 3 acre®.

Containment Components s Residues from the incineration process,including ash and scrubber blowdown solids, would containconcentrated levels of heavy metals and would therefore, requirestabilization prior to on-site disposal. Based on current analysesof the Fourth Street wastes, it is estimated that through

56

000377

incineration, the volume of waste would be reduced to approximately15,000 cubic yards of residual ash and soil. If a bulking factorof approximately 30% is assumed for the addition of stabilizationadditives, a total of approximately 20,000 cubic yards of materialwould be backfilled onsite. Additionally, approximately 22,000cubic yards of clear; fill would be imported in order to restore theFourth Street site to current elevations. A RCRA Subtitle C capwould be installed over the backfilled waste, because of the lackof a bottom liner containment system beneath the waste. TheSubtitle C cap would be designer and constructed in accordance withthe requirements specified under 40 CFR 264. Contaminated surfacewater and blowdown water from the scrubber system will be utilizedfor dust control and as an admixture with thestabilizafcion/solidification reagent to improve mixing efficiency.Closure of the site would necessitate fencing, signs, deed notice,perpetual maintenance and five year reviews.

The landfill cover will eliminate the risk from direct contact andinhalation exposure. The stabilization process will immobilize thecontaminants and minimize the potential for future ground watercontamination *

General Components s The estimated time to implement this remedy andto meet the cleanup levels is 24 morths. The estimated costsassociated with implementing Alternative 6 are: Capital Costs:$32,400,000; Annual Operation and Maintenance: $10,000; PresentWorth: $32,600,000.

Alternately Excavation. Off-site Incineration and Disposal of Ash

Major CoBponeata of the Hern^al Alternative: The major features ofthis alternative involves consolidation of waste from Parcel H , aspreviously discussed, the neutralization of acidic waste in placeutilizing stabilization/solidification technology, excavation andshipment of neutralized waste to a commercial facility for thethermal destruction of organic contaminants, stabilization anddisposal of residual ash. The excavated areas of the site would bebackfilled, with clean imported material. This alternativeprovides for clean closure of the site and would not require theitems required under Alternative 2 , Limited Action.

Treatment Componentss Alternative 7 involves the neutralization andexcavation of waste on the Fourth Street site, followed bytransportation to an off-site thermal treatment or energy recoveryfacility. The excavated areas will be filled with clean importedbackfill. Clean closure of the site would not necessitate fencing,signs, deed notice, perpetual maintenance or a five year review.Sevaral forms of thermal destruction are presently available forthe treatment of CERCLA wastes. Numerous facilities existthroughout the country where both the thermal destruction of thewaste organic constituents and the disposal of the residual ashcould be achieved* Other facilities, although capable of thermallyprocessing the waste would be required to address the ultimate

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disposal of residuals. Operation of the incinerator would be inaccordance with RCRA (40 CFR 264 Subpart 0).

Wastes on the Fourth Street site will require pretreatment forneutralization in order to Bake them acceptable for off-sitetransport and/or to meet the requirements of a thermal treatment orenergy recovery facilityo Off-site contaminated soils from ParcelH and fch© on-site contaminated soils will be consolidated with thtotar material onsite. Soils/ sediments and sludges would beneutralized in situ, and then excavated f"- loading and transport.Contaminated surface water will be utilized in the neutralizationprocess. Transportation of waste materials to a permitted off-site-facility will be in compliance with DOT regulations (i.e.,placards, proper shipping containers, etc.). Selective demolitionof on-site equipment and tankage will be required to implement theneutralization and excavation operations. Although dependent on "the progress of tue neutralization effort, it is estimated that the ^0final excavation and transport of the waste on the Double Eagle r-~site would take approximately 6 to 8 months. LH

Once received at the off-site thermal treatment facility, bulkwaste would be unloaded for temporary RCRA compliant storage or °directly fed to the treatment unit. This alternative alsoincorporates co-combustion of the waste, or use of the waste asfuel in devices whose primary purpose is energy production, such asboilers, furnaces, and process heaters. The thermal treatmentprocesses provide high temperature destruction of organics in thewaste and scrubbing of the combustion gases. The thermal tredtmentprocesses that are applicable for the treatment of the FourthStreet waste include rotary kilns, pyrolysis, circulating iaedcombustors, infrared furnaces and some industrial installations(boilers, kilns and furnaces). Thermal destruction is a treatmentprocess employed to destroy organic contaminants in liquid, gaseousand solid waste str&cins. Thermal treatment will not destroyinorganic contaminants such as lead, therefore, the ash residuemust be stabilized prior to disposal.

The operation of a thermal system results in exoneration ofresidual/effluent streams consisting of ash, decontaminated soils(if soils are present in the feed stream), scrubber water orblowdown, and flue gases. A detailed waste analysis is requiredbefore a waste is accepted by ; treatment/disposal facility. Amongthe most important factors which a facility owner considers indetermining the suitability of wastes for thermal treatmentinclude: BTU content of ths waste, viscosity, water content,halogen content and ash content.

Confcaiafflent Components: Based on current analyses of the FourthStreet wastes, it is estimated that through thermal treatment thevolume of waste would be reduced to approximately 20,000 cubicyards of residual ash, soil and bulking reagent. Because of theheavy metal (lead) content of these residuals and solids generatedfrom the facility's air pollution control system, stabilization

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would be required prior to final dispof ion in a landfill. Thetreated material would have to meet ths TCLP requirementspreviously discus-sed prior to landfill disposal, severalalternative thermal destruction options are available for the wasteat. the Fourht street site. The risk from direct contact andinhalation exposure, and the potential for future ground watercontamination will be eliminated by completely removing the wastefrom the FSR site.

General cofflpo^safes: The estimated time to implement this remedy andto meet the cleanup levels is 12 months. The estimated costsassociated with implementing Alternative 7 are: Capital Costs:$23,900,000; Annual Operation and Maintenance: None; Present Worth:$23,900,000.

inCO

EC. SUMMARY OF COMPARATIVE ANALYSTS OF ALTERNATIVES ^

t^The EPA uses nine criteria to evaluate alternatives for addressing â Superfund site. These nine criteria are categorized into threegroups: threshold, primary balancing, and modifying. The threshold ^criteria must be met in order for an alternative to be eligible forselection* The primary balancing criteria are used tc weigh majortradeoffs among alternatives. The modifying criteria are taiceninto account after state and public comment i", received on theProposed Plan of Action.

fîne Critena

The nine criteria used in evaluating all of the alternatives are asfollows:

a) 'threshold Criteria

Overall Protection of Human Health and the Environment addressesthe way in wich an alternative would reduce, eliminate, or controlthe risks posed by the site to human health and the environment.The methods used to achieve an adequate level of protection varybut may include treatment and engineering controls. Total.elimination of risk is often impossible to achieve. However, ^remedy must minimize risks to assure that human health and theenvironment are protected.

Compliance with ARARs, or "applicable or relavent and appropriaterequirements", assures that an alternative will meet all relatedfederal, state, and local requirements.

b) Priman Balancing Criteria

£fQ_ng"-jêrm Effectiveness and Permanence addresses the ability of analternative to reliably provide long-term protection for humanhealth and the environment after the remodiation goals have been

59

.^^, . ._ , - (_• . . ^^.... . m. l. A^ .JB^

000380

accornpl ished.

Reduction of_To^icity. Mobility, or Volume_of _Contaminants throughTreatment assesses how effectively an alternative will address thecontamination on a site. Factors considered include the nature ofthe treatment process; the amount of hazardous materials that willbe destroyed by the treatment process; how effectively the processreduces the toxicity, mobility, or volume of waste; and the typeand quantity of contamination that will remain after treatment.

Short-term Effectiveness addresses the time it takes for remedyimplementation. A potential remedy is evaluated for the length oftime required for implementation and the potential impact on humanhealth and the environment during implementation.

Iiaplementabilitv addresses the ease with which an alternative can \0

be accomplished. Factors such as availability or materials and c0

services are considered, ("-•in

Cost (including capital costs and projected long-term operation and Qmaintenance costs) is considered and compared to the benefit that ^will result from implementing the alternative.

c) Modifying Criteria

State Acceptance allows the state to review the proposed plan andoffer comments to the EPA. A state may agree with, oppose, or haveno comment on the proposed remedy.

Community Acceptance allows for a public comment period forinterested persons or organizations to comment on the proposedremedy. EPA considers these comments in making its final remedyselection. The comments are addressed in the responsivenesssummary which is a part of this ROD.

Comparative Analysis

The following discussion provides the comparative analysis for eachof the nine criteria:

I. overall Protection of Human Health and the Environsaent

All of the alternatives, except No Action, will provide some degreeof overall protection of human health and the environment. Thedegree to which each alternative provides this protection isdiscussed below.

The No Action alternative provides no increase in the overallprotection to human health and the environment. Under thisalternative, al? of the potential risks to human health and theenvironment associated with the FSR. site would remain.

Alternative 2, Limited Action, will eliminate the risk associated

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with the contaminated material on Parcel " H " since this materialwill be excavated, placed on site and replaced with clean fill.Direct contact with material on site will be reduced as long as thefences are maintained trespassers are kept away from the site« Therisk associated with potential air emissions will not be reduced,nor will this alternative address the potential risk to futureworkers on site*

Alternative 3 , On-site Stabilization/ On-site Capping, willeliminate the offsite direct contact risk Parcel H similarly tothe Limited Action Alternative. This alternative will also reducethe risk from direct contact with the sludges and soils onsite bycovering the stabilized material with a cap. The cap will alsoeliminate the potential for air emissions from the site. Some riskfrom direct contact and migration to the ground water may remain i -from possible failure of the cap; however, the potential for ^failure would be minimized by proper annual maintenance. -^

Alternative 4 , On-site Stabilization/On-sifce Landfill Disposal, ln

offers levels of overall protection similar to the capping 0alternative. However, this alternative provides an additional olevel of protection to the ground water by the construction of aliner beneath the stabilized material* This liner will minimizethe possibility that contaminants can migrate to the ground waterunder the site.

The On-site Stabilization/Off-site Landfill Disposal and Off-siteIncineration alternatives, Alternatives 5 and 7, provideprotection of human health and the environment by the ultimateremoval of the contaminated material from the site. Because thematerial would be removed, the potential for migration to groundwater and for air emissions would be eliminated.

The risk associated with contact with material on Parcel " H " 11be eliminated by Alternative 6 , since this material wi beexcavated and replaced with clean soil. The risk associated withexposure to the organic contaminants will be eliminated bydestruction of these contaminants- Exposure to lead on the DoubleSag 1 e property will be reduced by thi s a Iternat ive by thestabilization and capping of the metal-contaminated ash from theincinerator*

2. Compliance with Applicable or Relevant and AppropriateRequirements (AHAHS)Contaminated material stabilized on-site will have to be treated tothe extent that it is no longer considered a RCRA characteristichazardous waste (40 CFR 2 6 1 ) . All of the stabilizationalternatives will attain this degree of treatment. Thealternatives involving incineration will be required to isisest thestandards set by the federal government for the operation ofhazardous waste incinerators (40 CFR 264 Subpart 0 ) . Thealternatives involving landfill disposal will be required to meetthe standards for landfill construction and operation set by the

61

i i i M.iii.iiiniiiMiiiM-Jiiiii.itiiUiM'antitfltffflfiiirfMiftT

000382

federal government (40 CFR 264 Subpart M),

3« Long-term Effectiveness and PermanftncQ

The No Action and Limited Action alternatives would not providelong-term effectiveness or a permanent solution to potential risksassociated with material onsite. However, Limited Action wouldeliminate the risk from Parcel "H" by excavating the contaminatedmaterial in these areas and backfilling with clean soil.

Alternative 3 provides a higher degree of long-term effectivenessand permanence by physically and chemically binding theconsolidated waste material into a stabilized mass, and coveringthe treated material with an impermeable cap. The effectivenessand permanence of this alternative depends on the perpetualma intenance of the cap. Alternative 4 provides even greatereffectiveness through the construction of a liner to collect anyleachate generated on site, thereby protecting the ground water.The overall effectiveness and permanence of this alternative alsodepends on perpetual maintenance of the cap.

On-site incineration will provide the greatest degree of long-termeffectiveness and permanence of the on-site alternatives evaluated,by destroying the organic contaminants in the waste, eliminatingthe risk from the polynuclear aromatic hydrocarbons at the site.Permanence of this alternative will depend on perpetualmaintenance of the cap over the stabilized, metal contaminatedresidual from the incinerator,

The Off-site Landfill and Off-site Incineration alternativesprovide the greatest degree of long-term effectiveness andpermanence since the contaminants are removed from the site and nomaintenance actvities would be necessary.

4. Reduction of Toxicity, Mobility or Volume Through Treatment

The No Action and Limited Action alternatives do not provide anytreatment to reduce the toxicity, mobility, or volume of thecontaminated material. Alternatives 3, 4, and 5 use treatment toreduce the mobility of the metals and, to a lesser degree, themobility of the organic contaminants. The volume of material wouldincrease approximately 30%, by the addition of the neutralization/stabilization reagents. Alternatives 6 and 7 would reduce thetoxicity and volume of contaminated material through thedestruction of the organicss. Following treatment of the organicmaterial, the mobility of lead would be reduced by stabilization ofthe ash.

5. Short-Term Effectiveness

There would be no short-term risks associated with constructionunder the no action alternative. However, the risks currentlyassociated with wastes at the site would remain. There would be

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potential short-term risks to site workers during the consolidationof the material from Parcel "H" and fron the transportation of theexcavated material to the site area associated with Alternatives 2,3, 4, and 6. Some increase in air emissions may occur because ofexcavation and during the stabilization process onsite. However,engineering controls and monitoring will reduce the potential forany adverse impacts during implementation of the remedy. Airpollution emissions can be detected very quickly with standardindustrial hygiene monitoring equipment and visible monitoring. Acontingency plan would be developed to address any potential airemissions during remedial activities* Alternatives 5 and 7 alsohave short-term risks associated with the transportation of wastesto an off-site facility. These risks can be significantly reducedby a detailed transportation/ spill prevention plan. The estimatedtime to implement Alternatives 3, 4, and 5 is 24 months. Theestimated time to implement Alternatives 2, 6, and 7 is 12 months.

6. iMpleaentability

Treatability studies conducted on material from the FSR siteindicate that stabilization (Alternatives 3, 4, and 5) wouldeffectively immobilize and address the hazardous charateristics ofthe contaminated materials at the site. The concentration oforganic chemicals is sufficiently low that stabilization is notinhibited. The construction of a cap (Alternative 3) over thetreated material would be easily implemented. Alternatives 5, 6,and 7 are also easily implementable. However, the implementabilityof Alternatives 5 and 7 will depend upon the availability offacilities that are compliant with the Superfund Off-site DisposalPolicy Construction of a landfill on°site (Alternative 4) wouldrequire the demolition of several of the site structures inaddit ion to the tanks and process equipment. An area to storeexcavated material during on-site landfill construction would alsobe required.

7. cost

The present worth cost of the preferred alternative is $6,400,000.The Limited Action and Onsite Capping alternatives have lowerpresent worth costs of $300,000 and $5,100,000, respectively, On-site Treatment end disposal in an on-site landfill is slightlyhigher with a cost of $7,300,000. Onsite and offsite Incinerationare the most expensive alternatives; $32/600,000 and $29,400,000,respectively.

6. State Acceptance

The Oklahoma State Department of Health (OSDH) has reviewed thealternatives and does not believe that the No-Action and LimitedAction alternatives (1 and 2) are acceptable. OSDH doas notbelieve that Alternative 3 will provide adequate protection of theground water because of the uncertainty associated with the depthof waste on aite. The State does not believe that incineration

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000384

(Alternatives 6 and 7) of the waste is appropriate because it wouldnot address the risk associated with the lead at the FSR site.

The OSDH does not have a technical objection to Alternative 4,which is EPA's preferred alternative and was the Proposed Plan forpublic comment. However, prefers Alternative 5, Heutra1i z at ion _Stabilization, and Off-site Landfill disposal. The State ofOklahoma prefers this alternative because 1) the cost of thealternative and subsequent 10% State match, is lower thanAlternative 4, and 2) long term operation and maintenance would notbe required because ail of the contaminated material would beremoved from the site.

9. Community Acceptance

Comments received during the public comment period indicated apreference for off"site disposal, although one conmenter indicatedthat off-site incineration was most preferable. Other commenterssuggested that technologies other than landfill disposal andincineration should be developed. All comments received during thepublic comment period and EPA responses are in the attachedResponsiveness Summary.

X. THE SELECTED REMEDY

Based upon consideration of the requirements of Super fund, thedetailed analysis using the nine criteria, and the public comments,EPA has determined that Alternative 5 - Neutralization/ Excavation,On-site stabilisation, and Off"site Landfill Disposal of thestabilized material is the most appropriate remedy for the FSRsite. The major componenets of this remedy include:

Excavation of the contaminated material on Parcel "H"(approximately 1,200 cubic yards)Consolidation of this material with the contaminated materialon the FSR propertyDemolition of onsite structures and disposal of the asbestosinsulation, as necessaryUse of the surface water in the impoundments in thestabilization processOn-site stabilization of 42,000 cubic yards of theconsolidated material to immobilize and address the hazardouscharacteristics of the contaminantsDisposal of the stabilized material in a fully permitted off-site landfill

The principal threat at the FSR site is posed by direct contact andinhalation of contaminants in aite soils and sludges, and potentialfor migration of contaminants to the ground water. The remedialobjectives are to minimize potential exposure by direct contact orinhalation, and to reduce the potential for migration ofcontaminants into the surface waters and ground waters.

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000385

This alternative will significantly reduce the risks from directcontact with the sludges, soils and sediment at the FSR site by•stabilizing and isolating the contaminants in an off site landfillpermitted to accept this type waste. Since all of the materialcontaminated above EPA's remedial action goals (lead, 500 ppm;PAHs, 30ppm; PCBs 25ppm) will undergo treatment and be isolated inan off-site landfill, the long-term effectiveness is better thanfor the stabilization and capping alternative. This alternativewill also comply with all ARARs for stabilization and off"sitelandfill disposal. The consolidated material will be stabilized toensure that leaching of COCs does not exceed the TCLP regulatedstandards listed in 40 CFR 261.24. On-site stabilization and off"site landfill disposal uses treatment technologies and permanentsolutions to the maximum extent practicable and is cost effective,offering a degree of protection similar to the incinerationalternatives at a lower cost. The selected alternative will alsosatisfy the preferences for treatment as a principal element of theremedy and for on-site remedies written in the Superfund law. l

inThe Ho Action and Limited Action alternatives (Alternatives 1 and 02) are not being considered at this time because neither oalternative provides for overall protection of human health and theenvironment. The Onsite Stabilization/Capping alternative(Alternative 3) presents technical issues due to the uncertainty oftreating contaminated material near the bottom of the impoundmentsonsite without excavation of the material. The selected remedydoes not satisfy the preference in the Superfund law for onsiteremedies. However, it is more cost-effective than the onsitedisposal alternative, and preferred by the State of Oklahoma. Theonsite and offsite incineration alternatives (Alternatives 6 and 7)are much less cost effective than the preferred alternative.Because each would require stabilization of the incirxerator ashprior to disposal, EPA does not believe that the incineratoralternatives offer additional protection in line with theadditional cost.

The selected remedy uses treatment and permanent solutions toaddress the risks posed by the COCs at the site to the maximumextent practicable. The selected remedy does not, however, satisfytne preference in SARA for on-aite remedies. EPA's originalproposed plan, Alternative 4, would satisfy this preference in thelaw. However, EPA is deferring its preference in consideration ofpublic comments and the State of Oklahoma's comments. The selectedremec .. ,11 be less costly and not require expenditure of State orEPA i. ^ for operation and maintenance.

Upon completion of the remedial action, future source controloperation and maintenance activities will not be required, sinceall of the wastes will be removed from the site,

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XI. THE STATUTORY KETERMI^ATiQ^g

EPA's primary responsibility at Superfund sites is *co selectremedial actions that are protective of human health and theenvironment. Section 121 of CERCLA also requires that the selectedremedial action for the site coinply with applicable or relevant andappropriate environmental standards established under Federal andState ©nvironinental laws, unless a waiver is granted. The selectedremedy must also be cost-effective and utilize treatment orresource recovery technologies to the maximum extent practicable.The statute also contains a preference for remedies that includetreatment as; a principal element. The following sections discusshow the selected remedies for contaminated soils, sediments andsludges at the PSR site meet the statutory requirements.

Protection of Human Health and the Environment c\1

c^In order to protect human health and the environment, the r"-contaminated soils, sediments, sludges, and ground water that tnexceed RAOs will undergo a combination of excavation, treatment and Qdisposal. These media will be treated and contained to meet the ^performance standards set forth in this ROD. These performance °standards will assure that site risks fall within the target cancerrisk range of l<r1 to 10-6 and the non-carcinogenic hazard index willbe reduced to less than one (1) . The performance standards willalso assure that 1) direct contact with contaminated sediments,sludges, and surface soils will cease, and 2) contaminatedsediments, sludges, and surface soils will cease to act as a sourceof ground water contamination*

The selected remedy protects human health and the environment byreducing levels of contaminants through treatment and disposal. Ofall the alternatives evaluated for the contaminated sediments,sludges, and soils, the selected alternative provides the bestoverall protection to human health and the environment. Nounacceptable short-term risks will be caused by implementing thisremedy.

Compliance with ARARs

The selected sediment, sludqe and surface soil remedy, whichutilizes excavation, consolidation, neutralization andstabilization, and ultimate disposal will comply with allapplicable or relevant and appropriate requirements. The ARARs arepresented as follows:

Chemical-Specific ARARsfor Soils and Sediments

1. Identification and Liuting of Hazardous Haata (40 CFR Part261) , Subpart C - Characteristics of Hazardous Waate aad suhparfc D" Lists of Hazardous Waste. Applicable because characteristicallyhazardous waste will be managed.

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2. National Eraisaion Standards for Hazardous Air Pollutants (40CTR Part 6X) • Relevant and appropriate during excavation,neutralization and stabilisation processes.

3. Air Pollution Permits (Oklahoma Air Pollution Control Rules,OAC 3l0s200-7). applicable during excavation, neutralization andstabilization processes if emissions exceed one pound per hour forany one criteria pollutant,

4. control tflf Emissions of organic Materials (Oklahoma AirPollution Control Rules, OAC 310; 200-37). May be applicabledepending on the specific air emissions during biotreatment,neutralization and stabilization processes;.

5. control of Emission of Hazardous and Toxic Air Contaminants(Oklahoma Air Pollution control Rules, OAC 310:200-41). May beapplicable depending on the specific air emissions duringexcavation, neutralization and stabilization processes,

Action-Specific ARAR for Sollfi, Sludges and Sediments

Standards for Owners and Operators of Hazardous Waste Treatment,Storage/ and Disposal Facilities (40 CFR Part 2 6 4 ) . Relevant andappropriate during excavation, neutralization and stabilizationprocesses.

Cost-liffectiveness

EPA believes that the selected remedy is cost-effective inmitigating the threat of direct contact with site wastes. Section300.430 (f) (ii) (D) of the NCP require.? EPA to determine cost-effectiveness by evaluating the following three of the fivebalancing criteria to determine overall effectiveness: long-termeffectiveness and permanence, reduction of toxicity, mobility orvolume through treatment/ and short-term effectiveness. Overalleffectiveness is then compared to cost to ensure that the remedy iscost effective. EPA believes the selected remedies meet thesecriteria. The estimated present worth cost for the selected SCOUremedy is $6,400,000.

Utilization ofPennanent Solutions and Treatment or Resource Recovery Technologies to theMaximum Extent Practicable

EPA believes the selected remedy represents the maximum extent towhich permanent solutions and treatment/resource recoverytechnologies can be utilized in a cost-effective manner for the FSRsite. Of those alternatives that axe protective of human healthand the environment and comply with ARARs, EPA and OSDH havedetermined that the selected remedies provide the best balance inconsidering long-term effectiveness and permanence; reduction intoxicity, mobility or volume through treatment; short-termeffectiveness; iwplementability; and cost, as well as considering

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the statutory preference for treatment as a principal element andconsidering state and community acceptance.

Preference/or Treatment as a Principal Element

The selected remedy satisfies the statutory preference fortreatiiienfc as a principal element. The Source Control remedy willuse stabilization/solidification, and neutralization as treatmentmethods.

X1L DOCUMENTAL W OF SIGNIFICANT CHANGE: A Proposed Plan forthe FSR site was released for public comment on July 17, 1992. TheProposed Plan ^d&ntified Alternative 4, consolidation,Neutralization, On-site Stabilisation and On-site Landfill Disposalas ERA'S preferred alternative for soil, sludge, and sediment < -contamination. At the same time, EPA requested the preference of ^the State of Oklahoma regarding the Proposed Plan. In a letter ^dated August 18, 1992, (Attachment C) the OSDH indicated that theState of Oklahoma preferred Alternative 5 "' consolidation,Neutralization, On-site Stabilization, and Off-site Landfill °Disposal. OSDH cited the lower cost of the remedy and subsequent 0lower State match. As a result of State and general publiccomments, EPA has decided to select off"site landfill disposalrather than on-site landfill disposal for the FSR site.

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ADMINISTRATIVE RECORD INDEX

INTERIM

SITE NAME: FOURTH STREET REFINERY SITE

SITE NUMBER; OKD 980696470

INDEX DATE: 03/06/91

000390

INTRODUCTION

Section 113(j)(l) of the Comprehensive Environmental Response, Compensation andLiability Act (CERCT-A) provides that judicial review of any issues concerning the adequacyof any response action shall be limited to the administrative record which has beencompiled for the site at issue.

Secdon 113(k)(l) of CERCLA, requires that the United States Environmental ProtectionAgency (Agency) establish administrative records for the selection of CERCLA responseactions. The administrative record is the body of documents upon which the Agency basedits selection of a response action must be documented thoroughly in the administrativerecord. The Agency must ensure that the record is a compilation of documents leading upto and reflecting the Agency's response decision. \o

c-In accordance with U.S. EPA Headquarters OSWER Directive 9833J. Section 113(k) of ^~the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), (Has amended in 1986 by the Supcrfund Amendments and Reauthorization Act (SARA) the QU.S. EPA is required to compile and make available to the public Administrative Records -^containing documents used to support response actions authorized under CERCLA andSARA. The Administrative Records are to be maintained at the relevant U.S. EPARegional Offices as well as "at or near the facility at issue."

This Administrative Record File Index consists of information upon which the Agency basedits decision on selection of response actions. It is a subset of information included in thesite files. The records in this Administrative Record File Index have been arranged inchronological order (from the earliest date to the most recent date), based on the date ofthe corresponding document. Each document contained in the Administrative Record Filehas been stamped with sequential document numbers, to assist in the location of thedocument within the Record File.

This Administrative Record File Index has been compiled in accordance with OSWERDirective Number 9833.1a Interim Guidance on Administrative Records for Decisions onSelection of CERCLA Response Actions. This guidance reflects, to the extent practicablerevisions being made to the National Contingency Plan (NCR).

000391


SITE NAME;SITE NUMBER:

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PACKSAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

INTERIM

FOURTH STREET REFINERY SITEOKD 980696470

000001 - 000012Undated012Office of Waste Programs EnforcementU . S . EPA HQU . S . EPA Region 6 Site FilesCompendium Users ManualList of guidance documents used during development andselection of response actions under the ComprehensiveEnvironmental Response, Compensation, and Liability Act(CERCLA)

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

000013 - 00001604/02/84004Jerry Svec, Field Investigation Team (FIT)Ecology and Environment, Inc.U . S . EPA Region 6 Site FilesReportPotential Hazardous Waste Site Investigation and PreliminaryAssessment

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000017 - 00002307/10/84007William Langley. ChiefU . S . EPA Region 6 - Houston BranchKeith Bradley, Hazardous Waste Section, U . S . EPA Region 6Contract Lab Program (CLP) Data ReviewReview of organic samples taken for Case No. 2662 with OrganicQA Checklist (Raw data summarized in the 09/19/88 ExpandedSite Inspection Report, Document No. 1472 - 1743)

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000024 - 00002709/07/84004William Langley, ChiefU . S . EPA Region 6 - Houston BranchKeith Bradley, Hazardous Waste Section, U . S . EPA Region 6CLP Data Review and AttachmentsReview of inorganic samples taken for Case No. 2662 (Raw datasummarized in the 09/19/83 Expanded Sice Inspection Report.Document No. 1472 - i743)

000392


INTERIM

SITE NAME:SITE NUMBER:

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


000028 - 00005610/01/84029Jerry Svac, FITEcology and Environment, Inc.U.S . E.?A Region 6ReportPotential Hazardous Vaste Site Investigation Report

DOCUMENT NUMBER:DOCUMENT DATE:KUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:

DOCUMENT TYPE:DOCUMENT TITLE:

000057 - 00005710/26/84001Dave Peters, Chief, Hazardous Waste SectionU . S , EPA Region 6Martha McKee. Chief, Superfund Compliance Section. U . S . EPARegion 6Cover SheetOutline of attachments and comments regarding 04/10/84sampling activity


000058 - 00005801/02/85001G . W . GuerraU . S . EPA Region 6U . S . EPA Region 6 Site FilesTentative Deposition"Potential Hazardous Waste Sice Tentative Disposition'

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:

RECIPIENT:

DOCUMENT TYPE:I50CUMENT TITLE:

000059 - 00006003/25/85002Samuel L. Note, Chief, Superfund BranchU.S . EPA Region 6Raymond Friedlander, c/o Karchmer Pipe and Supply Company,Inc.Notice LetterSite access must: be obtained from M r . Friedlander in ordarconduct an on-site inspection

000393


INTERIM

SITE NAME;SITE NUMBER:

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:&OCUMENT TYPE:DOCUMENT TITLE:


000061 - 00006103/29/85001Martha McKee, Chief. Superfund Compliance SectionU . S . EPA Region 6Raymond Friedlander c/o Karchman Pipe and Supply Company, IncCover LetterRe: ( 1 ) Submittal of 04/84 inspection report; (Reference Pg. Sof Document No. 28 - 5 6 ) ; and ( 2 ) Ecology and Environment,Inc. will contact Mr. Friedlander to set up date for furthersite inspection

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000062 - 00006304/25/85002Paul VaselU . S . EPA Region 6U . S . EPA Region 6 Site FilesTentative Disposition"Potential Hazardous Waste Site Tentative Disposition"

DOCUMENT NUMBER:DOCUMENT DATE:NX'MBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:

DOCUMENT TYPE:DOCUMENT TITLE;

000064 - 00006405/24/85001Martha McKee, Chief , Superfund Compliance SectionU . S . EPA Region 6Gerald Fontenot, Chief, Emergency Response Branch ( E R B ) , U . S .EPA Region 6MemorandumRequest to review Fourth Street Refinery for possible removal.action based upon high level of lead contamination

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:


000065 - 00006506/04/85001Martha McKee, Chief, Superfund Compliance SectionU . S . EPA Region 6Raymond Friedlander, c/o Karchmer Pipe and Supply Company,Inc.Cover LetterSubmittal of site inspection report and sample analysesprepared by Ecology and Environment, Inc. af ter their 04/10/84site visit

000394




INTERIM


000066 - 00006606/14/85001Staff ConsultantSpectrtx CorporationU.S. EPA Region 6 Site PilesNarrativeSummary of sample analysis for Case No. 4465


000067 - 00006807/24/85002Ken D. Faust, Section Manager, EPA Organic Superfund DivisionRocky Mountain Analytical LaboratoryTony Nesky, Sample Management Off ice . Alexandria, VACover LetterResults for SAS 1790F (Raw data summarized in Che 09/19/88Expanded Site Inspection Report, Document No. 1472 - 1743)

0

0

00

inoo


000069 - 00007007/31/85002Kendall Young, Chief, Laboratory SectionU . S . EPA Region 6 - Houston BranchKeith Bradley, Hazardous Waste Section, U . SCLP Data Review and Attachment;Review of organic samples taken for Case No(Summary of organic samples included in theSite Inspection Report, Document: No. 1472 -

EPA Region 6

4465/SAS 1790S09/19/88 Expanded1743)

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000071 - 00011209/24/85042Kendall Young. Chief, Laboratory SectionU.S. EPA Region 6 - Houston BranchKeith Bradley, Hazardous Waste Section. U . S . EPA Region 6CLP Data Review and AttachmentsReview of organic samples for Case No. 4465

4

000395


DOCUMENT NUMBER:DOCUMENT DATE:SUMBER OF PAGESAUTHOR:COMPANY/AGENCY:

RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


INTERIM


000113 - 00014611/01/85034A . B . Divers, Environmental ProgramsLockheed Engineering and Management Services Company, Inc.Las Vegas, NVU . S . EPA Region 6 Site FilesAnalysisAerial Photographic Analysis of the Double Eagle and FourthStreet Refinery Sites

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:

COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000147 - 00018212/20/85036Keith Bradley, FIT Regional Project Officer ( R P O ) , HazardousWaste SectionU . S . EPA Region 6Martha McKee, Chief, Compliance Section, U . S . EPA Region 6Memorandum and AttachmentsSampling at Fourth Street Refinery conducted on 06/12/85

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:


000183 - 00018312/27/85001Martha M. McKee, Chief, Superfund Site Assessment SectionU . S . EPA Region 6Raymond Friedlander, c/o Karchmer Pipe and Supply Company,Inc.Cover LetterMemorandum sampling inspection report prepared by Ecology andEnvironment, Inc. after their 06/12/85 site visit

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY;RECIPIENT:


000184 - 00018501/08/86002James L. Graham, J r . , P . E . , Chief, Public ^ater Supply SectionU . S . EPA Region 6Martha McKee, Chief, Superfund Compliance Section, U . S . EPARegion 6Memorandum and AttachmentComments on CERCLA investigation reports

000396



DOCUMENT NUMBER:DOCUMENT DATE:HUMBER OF PAGESAUTHOR:COMPANY/AGENCY:aECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

INTERIM


000186 - 00054002/24/86355EPA StaffU . S . EPA Region 6U . S . EPA Region 6 Site FilesHazardous Ranking System (HRS) PackageGeneral information concerning site description, sitebackground, site inspection data, and HRS scoring of FourthStreet Refinery

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES;AUTHOR:COMPANY/AGKNCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000541 - 00054203/06/86002Amy LayneU . S . EPA Region 6U . S . EPA Region 6 Site FilesTentative Disposition"Potential Hazardous Waste Site Tentative Disposition"

DOCUMENT NUMBER:DOCUMENT DATE:SUMBER OF PAGESAUTHOR:

COMPANY/AGENCY:RECIPIENT:


000543 - 00054303/06/86001Amy M. Layne, Environmental Protection Specialist, SuperfundSite Assessment SectionU . S . EPA Region 6Raymond Friedlander, c/o Karchmer Pipe and Supply Company,Inc.CorrespondenceConfirmation of 03/05/86 phone conversation regarding the needfor additional sampling of the sludge pits/lagoons on thesouthern portion of Mr. Friedlander's property


000544 - 00054403/28/86001Raymond FriedlanderKarchmer Pipe and Supply Company, Inc.Amy M . Layne, U . S . EPA Region 6CorrespondenceNotification that Mr. Friedlander will proceed with buildingplans on the northern and western portions of the site asdiscuss&d In 03/05/86 phone conversation

000397


INTERIM

SITE NAME:SITE HUMB.".:

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COHPANY/AGENCY:

RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


000545 - 00055206/23/86008 b

Staff ConsultantsInternational Technology Corporation (ITC)/Contract ComplianceScreening (CCS)U.S. EPA Re&ion 6 Site FilesLaboratory Response and AttachmentsLaboratory response to results of CCS for Case No. 5872

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR.COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE:

000553 - 00055506/26/86003Kendall Young, Chief, Laboratory SectionU . S . EFA Region 6 - Houston BranchKeith Bradley. Hazardous Waste Section, U . S . EPA Region 6CLP Data Review and AttachmentsReview of organic samples for Case No. 5872/SAS 2232F (Rawdata is summarized in the 09/19/88 Expanded Site InspectionReport, Document No. 1472 - 11743)

DOCL'MENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000556 - 00058808/12/86033Staff ConsultantsVersar Inc.U . S . EPA Region 6 Site FilesSampling AnalysisData Results of inorganic samples taken on 04/29/86 £or CaseNo. 17621


000589 - 00060709/05/86019Kendall Young, Chief, Laboratory SectionU.S. EPA Region 6 - Houston BranchJoan Fisk, Project Officer, U.S. EPA HQMemoranduia and AttachmentsCLP Data Review for Case No. 5872 (Raw data is summarized inthe 09/02/88 Expanded Site Inspection Report, Document No.1472 - 1743)

000398




INTERIM


000608 - 00064009/26/86033F . A . Verhalen. FIT Environmental ScientistEcology and Environment, Inc.Keith Bradley, Region 6 RPO, U . S . EPA Region 6Memorandum and AttachmentsSampling inspection report for HRS support

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT;DOCUMENT TYPE:DOCUMENT TITLE:

000641 - 00069712/19/86057Technical Assistance Team (TAT)

Roy F. Weston. Inc,U.S. EPA Region 6 Site FilesReport"CERCLA Site Investigation/Removal Action Report for FourthStreet Abandoned Refinery Site"

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000698 - 00075812/29/86061Craig Bond, Region 6, TATJacobs Engineering Group, Inc.Pat Hammack, OSC, ERB, U . S . EPA Region 6ReportImmediate Removal Preliminary Assessment ( T R PA) for FourthStreet Refinery (Poor quality original)


000759 - 00076001/23/87002Doug FassettU . S . EPA Region 6U . S . EPA Region 6 Site FilesTentative Disposition"Potential Hazardous Waste Site Tentative Disposition"

000399


DOCUMENT NUMBER:DOCUMENT DATE:HUMBER OF PAGESAUTHOR:GOMPANY/AGENGY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


INTERIM


000761 - 00076102/24/87001Martha M. KcKee, Chief, Superfund Site Assessment SectionU . S . EPA Region 6WilUe Cross, Superintendent. Del C.i.ty, OKCover LetterSubmittal of memorandum site inspection report ar.d sampleanalyses prepared by Ecology and Environment, Inc. after their04/29/86 - and 04/30/86 site visit (Reference Document No. 596 ln

- 628) 0

CO

in


000762 - 00078107/08/87020John I . Hogue, Region 6 , TATEcology and Environment, Inc.Staff, ERB, U . S . EPA Region 6ReportIR Potential Assessment for Fourth Street Refinery

0

0


000782 - 00087808/10/87097Ecology and Environment StaffEcology and Environment, Inc.U . S . EPA Region 6 Site FilesWork PlanExpanded Site Inspection ( S I ) Final Work Plan for FourthStreet Abandoned Refinery Site




000879 - 00087909/01/87001Douglas Fassett, Environment Engineer, Superfund SiteAssessment SectionU . S . EPA Region 6Scott Thompson, Solid Waste Division, Oklahoma StateDepartment of Health (OSDH)Cover LetterSubmittal of final Expanded SI work plan for Fourth StreetRefinery (Reference Document Number 770 - 866)

000400


SITE NAME:SITE WJMBER:

DOCUMENT NUMBER:DOCUMENT DATE:&RMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

INTERIM


000880 - 00088002/19/88001ERA StaffU . S . EPA Region 6U . S . EPA Region 6 Site FilesUpdate FormSite visit planned for 02/23/88 to evaluate feasibility offencing to restrict access to site


000881 - 00089703/05/88017John I . Hogue, TATEcology nd Environment, Inc.Greta Fanning, ERB, U . S . EPA Region 6ReportSite Assessment and Fencing Action Report

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

000898 - 00145107/01/88554Agency for Toxic Substances Disease RegistryU . S . Department of Health and Human ServicesU . S . EPA Region 6 Site FilesFinal Report"The Nature and Extent of Lead Poisoning in Children in theUnited States: A Report Co Congress" (This document; may bereviewed at U . S . EPA Region 6 , Dallas, TX)

DOCUMENT NUMBER:DOCUMENT DATE:?TUMBER OF PAGESAUTHOR:



001452 - 00145207/01/88001Mark S . Coleman, Deputy Commissioner, Environmerf.aL HealthServicesOSDHAllyn M . Davis, Hazardous Waste Management Division, U . S . EPARegion 6CorrespondenceOSDH requests to be designated as the lead agency for Four!:hStreet Refinery

10

000401



DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:


INTERIM


001453 - 00145307/26/88001Allyn M. Davis, Director, Hazardous Waste Management DivisionU . S . EPA Region 6Mark Coleman. Deputy Commissioner, Environmental HealthServices. OSDHCorrespondenceThe lead agency for the RI/FS Co be determined at a later datewhen funds become available

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

001454 - 00145409/08/88001Allyn M. Davis, Direccor, Hazardous Waste Management: DivisionU . S . EPA Region 6Mark Coleman, Deputy Commissioner, OSDHCorrespondenceRe: Multi-site cooperative agreement requesting project fundsfor Fourth Street Refinery and Double Eagle should betransmitted by 10/31/89 (Poor quality original)


COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

001455 - 00145709/09/88003Presley B . Hatcher. Acting Chief , Superfund Site Assessment:SectionU . S . EPA Region 6David Wir.eman. FIT RPO, U . S . EPA Region 6MemorandumQuestions and comments upon review of the fourth Street-Refinery Draft Expanded SI



001458 " 00172909/29/83272Presley B . Hatcher, Acting Chief, Superfund Site AssessmentSectionU . S . EPA Region 6Fenton Rood, Director, Solid Waste Division. OSDHCover Letter and ReportSubffilttal of final Expanded SI Report

11

000402


INTERIM


DOCUMENT NUMBER:DOCUMENT DATE;HUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE:


001730 - 00173111/08/88002William Rows, Superfund Enforcement SectionU.S. EPA Region 6U.S. EPA Region 6 Sice FilexRecord of Communication (ROC)/AttachmentRequest for Jim Mull ins of ERB to assess degree of , orpotential for. off-site contamination during field visit toFourth Street Refinery

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PACES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

001732 - 00175202/L3/89021Mofihen Erfani , TATEcology and Envirorosent, Inc.Greta Fanning, ERB, U . S . EPA Region 6ReportSite assessment conducted at Fourth Street Ref ine ry on01/09/89




001753 - 00176305/09/89OilGreta C. Fanning, On-Scene Coordinator ( O S C ) , Investigationand Emergency Response SectionU . S . EPA Region 6Robert E. Layton, J r . , P . E . , Regional Administrator ,RA) . L ' . SEPA Region 6Action MemorandumRequest for Renoval Action at the Fourth Street Refinery


001764 - 00176606/20/89003Allyn M . Davis, Director. Hazardous Waste Management DivisionU . S . EPA Region 6Raymond Friedlar.der, Karchner Pipe and Supply Company, Inc.Notice Letter and AttachmentNotification Chat EPA Region 6 is proposing to undertakecertain work at Fourth Street Refinery and opportunityextended to Mr. Friedlander to undertake removal actionactivities at the site

12

000403

ADt . 7ISTRATIVE RECORD INDEX


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY-RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE:

INTERIM


001767 - 00176707/20/89001William Rowe, Superfund Enforcement SectionU.S. EFA Region 6U . S . EFA Region 6 Site FilesROCRe: Phone conversation with Marilyn Garcia of National ToxicsCampaign, Oklahoma City, OK about statement made in mereo tothe Fourth Street Refinery file regarding offsice drainage


001768 - 00177407/31/89007Allyn H. Davis, Director, Hazardous Waste Management DivisionU . S . EPA Region 6Chevis King, J r . , Adroit ManufacturingNotice Letter and AttachmentsRequest to notify EPA whether or not Mr . Chevis wil l . undercakc-cleanup activities at Fourth Street Dump


001775 - 00178107/31/89007Allyn M . Davis, Director, Hazardous Waste Management DivisionU . S . EPA Region 6Thomas J . Murphy, Caddo Chemical Can Company (TJM , Inc)Notice Letter and AttachmentsRequest to notify EPA whether or not M r . Murphy will undertakecleanup activities at Fourth Street Dump

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES;AUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

001782 - 00178807/31/89007Allyn H . Davis, Director, Hazardous Waste Management DivisionU . S . EPA Region 6Raymond Friedlander c/o Karchmer Pipe and Supply Company, IncNotice Letter and AttachmentsRequest to notify EPA whether or not Mr. Friedlander willundertake cleanup activities at Fourth Street Dump

13

000404


DOCUMENT NUMBER:DOCUMENT DATE:WJMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:OOCUMENT TYPE:DOCUMENT TITLE:


INTERIM


001789 - 00178908/11/89001William Rowe, Superfund Enforcement SectionU.S. EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Phone conversation with T.J . Murphy of Caddo Chemical CanCompany regarding the removal notification letter o

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

001790 - 00179008/14/89001William Rowe, Superfund Enforcement SectionU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCR e : Phone conversation with Raymond Friedlander of FourthStreet Refinery concerning the fencing notification lector EPAfaxed to him on 08/10/89

00

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001791 . 00179308/21/89003Diana C . DuttonAkin, Guisp. Strauss, Hauer & FeldAllyn H . Davis, P h . D . , Director, Hazardous Waste ManagementDivision, U . S . EPA Region 6Response LetterRaymond Friedlander acquired the property in question unawareof contamination and should be covered by the innocentlandowner provision and does not wish to undertake cleanupwork of the site

DOCUMENT NUMBER:DOCUMENT DATE:SUMBKR OF PAGES;AUTHOR:COMPANY/AGENCY:RECIPIENT:50CUMENT TYPE:DOCUMENT TITLE;

001794 - 00179408/23/89001William Rowe, Superfund Enforcement SectionU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Phone conversation with Chevis King of AdroitManufacturing Company to follow up non-receipt of notificationlnitter concerning Mr. King's participation in remedial actions

14

000405




INTERIM


001795 - 00179508/25/89001Chevis King, J r . , PresidentAdroit Manufacturing Inc.William Rowe, U . S . EPA Region 6Response LetterCompany will cooperate with EPA in their efforts Co fence offthe designated "contaminated area" on their property line

DOCUMENT NUMBER:DOCUMENT DATE:WJMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

001796 - 00181608/30/89021Allyn M . Davis, Director, Hazardous Waste Management DivisionU . S . EPA Region 6Listed Addressees on AttachmentRequest LetterSecti&n 104(e) Information Request Letter with regards toAddressees involvement with specific activities at the site

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001817 - 00181708/30/89001Will iam Rowe, Superfund Enforcement BranchU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe; Phone conversation with T.J . Murphy of Caddo Chemical CanCompany Co follow up non-receipt of notification letterconcerning Mr. Murphy's participation in remedial activities

DOCUMENT NUMBER:DOCUMENT DATE:MUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT;DOCUMENT TYPE:DOCUMENT TITLE:

001818 - 00181808/30/89001William Rove, Superfund Enforcement SectionU . S . EPA Region 6U . S . Region 6 Site FilesROCRe: Phone conversation with Chevi'.s King of AdroitManufacturing Company concerning company's inability toparticipate in funding the fencing at Fourth Street Refinery

15

000406



DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

INTERIM


001819 - 00181909/01/89001Will lain Rowe, Superfund Enforcement BranchU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Phone conversation with T . J . Murphy of Caddo Chemical CanCompany concerning receipt of notification letter for fencing


001820 - 00182309/01/89004EPA StaffU . S . EPA Region 6U . S . EPA Region 6 Site FilesSuperfund Fact SheetInformation regarding site history, environmental-investigation, the Superfund Program, and how to keep updatedon the on-going investigation at the site

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

001824 - 00182409/07/89001William D . Rowe, J r . , Superfund Enforcement SectionU . S . EPA Region 6Lisa Lyhane, Waste Management Service, OSDHCorrespondenceR e : 1) Correspondence related to Fourth Street Refinery beingsent to M s . Lyhane; and 2) scoping meeting on vorkplan fornegotiations to be held at U . S . EPA Region 6 on 09/11/89


001825 " 00182709/08/89003David R. Parker, House CounselCrinco Investments, Inc.William Rowe, Superfund Enforcement Branch, U . S . EPA Region 6Response LetterResponses of J .A. Cardwell, owner of Crinco Investments, Inc.and Jerry Hendrix, Arrow Building Corporation (a subsidiary ofCrinco Investments) regarding their involvement with FourthStreet Refinery

16

000407


INTERIM




DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


001828 - 00182809/14/89001Clay Wilson, Jr . , President19th Seed CompanyAllyn M. Davis. Director, Hazardous Waste Management Division,U . S . ERA Region 6Response LetterMr. Wilson, fonaer owner of the Crinco property south ofFourth Street Dump, sold the property to Crinco upon discovery ^of serious pollution problem y

CO

in001829 - 001834 009/20/89 0006Frances Garrigues, Vice PresidentOklahoma Metal Processing Company, Inc.William Rowe, Superfund Enforcement Branch U . S . EPA Region 6Response Letter and AttachmentsResponse to Allyn Davis' 08/30/89, 104(e) letter regardingOklahoma Metal Processing Company's possible involvement withactivity at the Fourth Street Refinery


001835 - 00183509/20/89001William Rowe, Superfund Enforcement SectionU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Jim Smith, attorney for Cameron Kerrdn, requesting anextension until 11/15/89, for response to the l04(e) letter


001836 - 00185409/25/89019El»o Noflsaomn, OwnerRed Hen Oil CompanyWilliam Rowe, U . S . EPA Region 6Cover Letter and AttachmentsResponse to AlLyn Davis' 08/30/89, 104(e) letter regarding RedHen's possible involvement with activity at: the Fourth StreetRefinery site

17

000408


INTERIM




001855 - 00185509/25/89001Uilliaa Rowe, Superfund Enforcement BranchU . S . &PA Region 6U . S . ERA Region 6 Site FilesROCRe: Phone conversation with Mark Fox, representative for RedHen Oil Company, discussing Red Hen's involvement at theFourth Street Refinery


001.856 - 00185709/26/89002T . J . MurpheyCaddo Chemical Can Company (TJM, I n c . )Willian Rowe, U . S . EPA Region 6Response LetterResponse to 08/30/89, 104(e) information request letterregarding M r . Murphy's possible involvement with activities aithe sice


001858 - 00187909/28/89022William M. Sharp, P h . D . , SecretaryCommissioners of the Land OfficeWilliana Rowe. U . S . EPA Region 6Cover Letter and AttachmentsResponse to request for information concerning the FourthStreet Refinery


001880 - 00195210/02/89073Edmund R . Papazian, Senior Attorney - Environmentalyitco CorporationWilliaffi Rowe, Superfund Enforcement Branch, U . S . EPA Region 6Response Letter and AttachmentsResponse to 104(e) information request letter regardingWitco's possible involvement wich activities at the FourthStreet Refinery

18

000409

SITE NAME:SITE NUHBER:

DOCUMENT NUMBER:DOCUMENT DATE:BDKBER OF PAGESACTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


INTERIM


001953 - 00195310/02/89001William Rowe, Superfund Enforcement BranchU.S. EPA Region 6U.S. EPA Region 6 Site FilesROCRe: Phone conversation with Lisa Lyhane (OSDH) regardingenforcement plans and schedules and setting up scopingmeetings with OSCH


001954 - 00195510/04/89002Renda J . Mil ler, AttorneyAkin, Gump, Strauss, Hauer & PeldWilliam Rowe. Superfund Enforcement: Branch, U . S . EPA Region 6Response LetterMs. Miller reques'-s, on behalf of Mr. Friedlander, a 30-dayextension to 11/06/89 for his response to the 'iO^(e) letter

DOCUMENT NUMBER:DOCUMENT DATE:SUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECipmrr:


001956 - 00196110/06/89006Allyn M. Davis. Director, Hazardous Waste Management DivisionU.S. EPA Region 6Raymond Friedlander c/o Kacchmer Pipe and Supply Company, I",cand Addressees listed on Attachment;Notice Letter and AttachmentsRequest to notify EPA if M r - Friedlander and Addressees areinterested in undertaking any port: in of the RI/FS


001962 - 00196210/06/89001William Rowe, Superfund Enforcement BranchU.S. EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Ms. Renda Miller, attorney for Raymond Fried'Lander,requests an extension of time to respond co the 10^(eJ lett°L-

19

000410


SITE NAME:SITE NUMBER;

DOCUMENT NUMBER;DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPAHY/AGENCY:RECIPIENT:


INTERIM


00X963 - 00196410/27/89002Betty Williamson, Chief, Superfund Management: BranchU . S . EPA Region 6Marilyn Parris-Garcia, Oklahoma Director. National ToxicsCampaignCorrespondence and AttachmentRe: EPA representatives to attend 11/07/89 meeting to addressgeneral concerns and site issues


001965 - 00200311/02/89039Raymond FriedlandcrKarchmer Pipe and Supply C o . , Inc.William Rowe, Superfund Enforcement Branch, U . S . EPA Region 6Response Letter and AttachmentsResponse to Allyn Davis' 08/30/89 104(e) letter regarding M r .Friedlander's possible involvement with activities at theFourth Street Refinery sice

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002004 - 00200711/07/89004EPA StaffU . S . EFA Region 6U . S . EPA Region 6 Site FilesMeeting AgendaAgenda of 11/07/89 community meeting to discuss toxic sites inthe northeastern portion of Oklahoma City

DOCUMENT NUMBER;DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:

DOCUMENT TYPE;DOCUMENT TITLE:

002008 - 0020G911/09/89002William Rove, Superfund Enforcement SectionU . S . EPA Region 6Ray Churan, Regional Environmental Off icer , Department of theInterior (DOI) " Albuquerque, NMCorrespondenceAnnouncement of 11/16/89 initial planning meeting to be heldat U . S . EPA Region 6

20

000411


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


INTERIM


002010 - 00201211/16/89003EPA StaffU.S . EPA Region 6U.S . EPA Region 6 Site FilesMeeting Outline and AttachmentsRe: i) Planning meeting held 11/16/89 for Fourth StreetRefinery, 2) highlights of previous site investigations, and3) list of attendees at the meeting

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGESAUTHOR:


002013 - 00201312/18/89001William Roue, Superfund Enforcement Section and Cindy Kale:Texas Remedy SectionU . S . EPA Region 6Jim Mullins, Removal/Sites Section, U . S . EPA Region 6MemorandumInterim Action at Fourth Street Refinery

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGESAUTHOR:

COMPANY/AGENCY:RECIPIENT-DOCUMENT TYPE:DOCUMENT TITLE:

002014 - 00201412/18/89001William Rowe, Superfund Enforcement Section and Cindy Kaler iTexas Remedy SectionU.S. EPA Region 6Jon Rauscher, Texas Remedy Section, U . S . EPA Region 6MemorandumPerformance of a Preliminary Exposure Assessment for fheFourth Street Refinery

DOCUMENT NUMBER:DOCUMENT DAIE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:

DOCUMENT TYPE;DOCUMENT TITLE;

002015 - 00203012/26/89016Donald H. Will iams, Chief, Oklahoma/Texas Remedy SectionU . S . EPA Region 6Dennis Hrebec, Acting Director, Solid Wast-e Management:Division, OSDHCorrespondence and AttachmentsEPA Region 6 comments on the OSDH's technical SCacement; ofWork (SOW) submitted to EPA on 12/04/89

21

000412




INTERIM

FOURTH STREET REFINERY SITEOKT. 980696470

002031 - 00204501/18/90015Scott Thompson. Environmental SpecialiseOSDHRoberta K. Hirt, U .S . EPA Region 6CorrespondenceOSDH's response to EPA's comments on SOW for the Double Eagleand Fourth Street Cooperative Agreement:

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PACESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002046 - 002073oi/26/yo028Staff ConsultantsICF Technology IncorporatedU . S . EPA Region 6 Site FilesPlanFinal Community Relations Plan


002074 - 00207902/02/90006Cynthia J . Kaleri , Regional Project Manager (RPM)U . S . EPA Region 6Scott Thompson, Environmental Specialis-;. OSDHCorrespondence and AttachmentsReferences to EPA's comments on the O S D H ' s SOW notincorporated in the Request for Proposals (R.FP) packagesubmitted by OSDH



002080 - 00208002/08/90001T. Craig Carlton, OSC, Emergency Response and SiteInvestigationsU.S . EPA Region 6Cynthia Kaleri, RPM, U . S . EPA Region 6MemorandumDocumentation of areas ERB would conduce work uiid&r theRemoval Program

22

000413




nn-ERIH


002081 - 00208102/16/90001AIlyn M. Davia, Director. Hazardous Waste Hanaganiant DivisionU . S . EPA Region 6Diana C. Dutton, Esquire, Akin, Gurap, Strauss. Hauer & FeldCorrespondenceRe: 1) Acknowledgment of 08/21/89 and 11/02/89 correspondenceon behalf of Raymond Friedlander; and 2) EPA Region 6 willconduct the RI/F£"

DOCUMENT NUMBER:DOCUMENT DATE:NUHBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002082 - 00208303/09/90002Carl E. Ediund, Chief, Superfund Programs BranchU . S . EPA Region 6Damon Wingfield, OSDHCorrespondenceDouble Eagle and Fourth Street: RemedialInvestigation/Feasibility Study (RI/FS) investigations shouldbe conducted with EPA as the lead agency and OSDH as thesupport agency

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE:

002084 - 00208603/22/90003Cyndi Kaleri. RPM, Oklahoma/Texas Remedial SectionU . S . EPA Region 6U . S . EPA Region 6 Site FilesFax Cover Sheet and AttachmentsMap of the area surrounding the Double Eagle and Fourth Streetsites and map of Oklahoma City vicinity

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002087 - 00208904/05/90003Scott A . Thompson, Senior EnvtronreenCal ScientistOSDHU . S . EPA Region 6 Site FilesMemorandum"Meeting of the Eastside Environmental Coalition on April 31990"

23

000414


SITE RAHE:SITE NUMBER-

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COHPAHY/AGENCY:RECIPIENT:OOCUKXHT WE:DOCUMENT TITLE:

IMTERXM

FOURTH STILEET REFINERY SITEOKD 980696470

002090 - 00209005/11/90001EPA StaffU.S. EPA RAftion 6U.S. EPA Ragion 6 Site FllaeAgenda"KIc^-Off M««ting for Fourth Street and Double Eagle RI/FSProject:*"

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002091 . 00209505/22/90005Barry L. Haynie. ARCS Health and Safety ManagerFluor Daniel ARCS TeamCynthia Kaleri. RPM. U .S . EPA Region 6Cover Letter and AttachmentRe: Enclosure of the Health and Safety Plan for the initialsice vi»lt c*. the Double Eagle Refinery and the Fourth StreetRefinery altes

DOCUMENT NUMBER:DOCUMENT DATE:N'UMPER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002096 - 00209705/25/90002Scott A. ThofBpson. Senior Environmental. ScientistOSDHU . S . EPA Region 6 Site FilesMeaoranduaRe: Investigation of allegations that concaaination fromNational Priorities List (HPL) sices right be affecting alocal restaurant

DOCUMENT NUMBER:DOCUMENT DATE:KUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002098 - 00210^.06/06/90007Robert K . Franke, ARCS Project ManagerFluor Daniel ARCS TeaaCynthia Kaleri. RPM. U .S . EPA Region 6Correspondence and AttachaentRe: Enclosure ot the Investigation/Sanpling Plan for thesecond Site Scoping Visit and the revised Health and SafetyPlan for the 06/08-09/90 sice visit:

24

000415



DOCUMENT NUMBER:DOCUMENT DATE:mJHBKR OF PAGESAUTHOR:COMPAHY/ACEMCY:RICIPIBNT:DOCUMENT TYTE:DOCUMEHT TITLE:

INTERIM


002105 • 00211106/11/90007Cynthia K«l«ri and Jon RauacharU.S. EPA Region 6U.S. EPA Region 6 Sito FllfFAX Covr Sheet: wad Attach—nr.«Information and up* about the Fourth Street and Double Eagle«if« for envlronfliental •s«essaent planning

DOCUMENT NUMBER:DOCUMEHT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DC ;MENT TITLE;

002112 - 00211206/15/90001Mark I . deLoririer, ARCS Prograia ManagerFluor Daniel ARCS TearLarry Kalwei , Contracting Off icer , U . S . EPA Region 7Cover LetterR-a: Enclosure of draft Project Vork Plans for the RI/FS to :conducted at the Fourth Street and Double Eagle sices (WorkPlan* not enclosed with this cover letter)

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;COMPAQ/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002113 - 00211706/26/90005Cynthia J . Kalcri , RPHU.S. E^A Region 6Robert K . Franke. ARCs Project Manager, Fluor Daniel, IncCorrespondence and AttachmentEPA Region 6's initial coBrents upon review of the FrojecWork Plan

DOCUMENT NUMBER:DOCUHENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002118 - 00212707/03/90010Rob K . Franke, ARCS Project ManagerFluor Daniel ARCS TearCynthia Kaleri, RPH. U . S . EPA Region 6Correspondence and AttachmentAdditional inforaacion submitted for Project Work Plans perRPM's request

25

000416




INTERIM


002128 - 00216207/03/90035Cynthia J. Kaleri, RPMU . S . ERA Region 6U . S . EPA Region 6 Site FilesMemorandum and AttachmentsResults from ERB sampling and off-site areas associated withoperations at Fourth Street and Double Eagle


002163 - 00216407/16/90002Cynthia J . Kaleri. RPMU . S . EPA Region 6Scott A . Thompson, Environmental Specialist, 05DHCorrespondenceEnclosure of the results from the ERB sampling effort: at: theFourth Street site



002165 - OU216607/20/90002Cynthia J . Kaleri, RPMU . S . EPA Region 6Stephen Forsythe. Field Supervisor, U . S . Fish and WildlifeServices - Tulsa, OKCorrespondence-Request written comments on draft investigative Work Plan

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002167 - 00217008/01/90004Scott A . Thompson, Solid Waste ServiceOSDHCynthia J . Kaleri. RPM, U . S . EPA Region 6Correspondence and AttachmentComments on the draft Work Plan for conducting the RI/F3

26

000417


INTERIM




002171 - 00217308/08/90003Robert K. Franke, ARCs Project ManagerFluor Daniel, Inc.Cynthia J . Kaleri. RPM, U . S . EPA Region 6Correspondence and AttachmentSummary of 08/05/90 site visit


002174 - 00217408/15/90001Stephen W. Forsythe, Field SupervisorU.S. Field and Wildlife ServicesCynthia Kaleri, RPM, U.S. EPA Region 6CorrespondenceComments and recommendations on draft investigative work planand surface water assessment


002175 - 00219908/17/90025Cynthia J . Kaleri, RPMU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Fluor Daniel., IncCorrespondence and AttachmentComments on RI/FS Work Plans

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002200 - 00220108/23/90002Cynthia J . Kaleri, RPMU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Fluor Danial, Inc-CorrespondenceSampling considerations for an environmental assessmentstrategy for the areas outaide of the former operations area(ponds on Parcel H and the ox bov lake)

27

000418





DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

INTERIM


002202 - 00220208/23/90001Cynthia J. Kaleri. RPMU.S. EPA Region 6Stephen Forsythe, Field Supervisor, U . S . Field and WildlifeServicesCorrespondenceRe: Biological coxicity testing to be conducted as part oC che ^RI/FS ^1

COino

002203 - 002204 008/29/90002Cynthia J . Kaleri., RPMU'.S. ERA Region 6Scott A. Thompson, Environmental Specialist, OSDHCorrespondenceEPA's concerns with regard to the RI/FS Work Plan

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE:

002205 - 00220708/30/90003Cynthia J. Kaleri, RPMU . S . EPA Region 6Robert K. Franke, ARCS Project Manager, Fluor Daniel , IncCover Letter and AttachmentComments on Project Work Plan

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY :RECIPIENT;DOCUMENT TYPE:DOCUMENT TITLE;

002208 - 00221208/31/90005Robert K. Franke, ARCS Project ManagerFluor Daniel, Inc.Cynthia Kaleri, RPM, U . S . EPA Region 6Correspondence and AttachmentsProposal of methods to be used in sampling and investigationof the large lagoon

28

000419



DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESACTHOR:

COKPANY/AGEHCY:RECIPIENT:DOCUMENT TYPE:DOCOMENT TITLE:

INTERIM


0022i.3 - 00221409/24/90002CynchU J. Kaleri. RPHU.S. EPA Region 6U.S. EPA Region 6 Site FilesROCRe: Discussion with Fluor Daniel,Plan sampling proposal

Inc. about: a revised Work


002215 - 00226809/24/90054Staff ConsultantsFluor Daniel, Inc.U.S. EPA Region 6 Site FilesWork Plan"Final Project Work Plan for che Remedial Investigation andFeasibility Study at the Fourth Street Refinery SLte"

DOCL-MENT NZ-MflER:DOCUMENT DATE:NU?»ER OF PAGES:AUTHOR:

COHPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002269 - 00226910/04/90001Cynthia J. Kaleri, RPMU.S. EPA Region 6Robert K. Franke. ARC& Project Manafier Fluor Daniel, IncCorrespondenceRe: EPA's approval of Fluor Daniel. Inc's proceeding wi^haobilizacion activities on 10/08/90

DOCL'HENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:

COKPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002270 - 00227010/11/90001Cynthia J . Kaleri. RPMU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Phone conversation with Scott Thompson (OSDH' abou'preliminary work at the site

29

000420

ADMINISTRATIVE RECORD L:DEX


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

INTERIM


002271 - 00227310/11/90003Cynthia J. Kalarl, RPMU.S. EPA Region 5Scott A. Thompson. Environaiantal Specialist. OSDHCorroapondence and AttachmentSuanaary coarasncs of th® 09/21/90 meeting held with the OSDHregarding the Sanpling and Analysis Program for the DoubleEagle and Fourth Street Sites


00227^* . 00227^*10/12/90001Cynthia J. Kaleri, RPHU . S . EPA Region 6U . S . EPA Region 6 Site FilesROCRe: Phone conversation with Robert Franke (Fluor Daniel . I n c . *about OSDH not receiving revised Work Plan

DOCUMENT NUMBER:DOCUMENT DATE;.WMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002275 - 00227610/2<*/90002Cynthia J. Kale-.i. RPMU.S. EPA Region 6U.S. EPA Region 6 Site HiesROCRe: Fluor Dani fc l ' s phor.s conversation with David Smith(Bio-Aquatic) about environmental sampling planned for ParcelH


COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002277 - 00227811/01/90002Scott A. Thompson. Enviro^?ent:.•ll Specialist: Supervisor, SolidWaste Management ServiceOSDHCynchia J. Kaleri. RPM. U . S . EPA Region 6Cover LetterRe: Cofflfaencs on the draft RI/FS Work Flan Revision I

30

000421



DOCUMENT NUMBER:DOCUMENT DATE:?%a<BER OP PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

INTERIM


002279 - 00227911/02/90001Cynchia J . Kaleri, RPMU . S . EPA Region 6Robart K. Franke, ARCs Project Manager, Floor Daniel, Inc.Corra«pond«nc«Re; EPA approval for Fluor Daniel to proceed wich mobilizationaccivities on 11/05/90

DOCUMENT NUMBER:DOCUMENT DATE:.WNBER OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002280 • 00228611/20/90007Cynthia J . Kaleri, RFMU . S . EPA Region 6Robert K. Franke. ARCs Project Manager. Fluor Daniel, Inc.Cover Letter and AttachmentR e : 1) Request to incorporate enclosed comments for the RI/FSwork plan; and 2) EPA approves the work plan uponincorporation of comments for the work plan


002287 00228811/21/90002Cynthia J . Kaleri, RPMU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Fluor Daniel, Inc.CorrespondenceRe: Docuaentation of errors associated with FLuor Daniel's useof the Contract Laboratory Program during the Phase I fieldeffort


002289 - 00229212/18/9000 .Cynthia J. Kaleri , RPMU.S. EPA Region 6U.S. EPA Region 6 Si»:e FllaaCover Letter and AttachmentEPA's consents upon review of RI/FS workplan

31

000422



DOCUMENT NUMBER:DOCUMENT DATE;KUHBEB OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

INTERIM


002293 - 00229412/20/90002Cynthia J. Kdltrl., RfMU.S. SPA Region 6U.S. EPA Region 6 Sif FilesROCR«: Phone convrsaClon with George P<ctlgrcv (ATSDR) onobservation* resulting from Phase I effort at Fourch Streetsite

DOCUMENT NUMBER:DOCUMENT DATE:^BER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002295 - 00229812/20/90004Cynthia J. Kaleri, RPMU . S . EPA Region 6U.S . EPA Region 6 Site FilesROCRe: 12/20/90 meeting wich EPA and Fluor Daniel representativesEo discuss observations and actual work corcpi.eted in Phase Ifield effort and considerations for Phase II work

DOCUMENT NUMBER:DOCUMENT DATE:NL-MBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002299 - 00230212/21/90004Cynthia J. Kaleri. RPMU . S . EPA Region 6Scotc A . Thoapson, OSDHCorrespondenceRe: EPA's concerns about technical quality of the RI/F3project for Fourth Street site

^OCc-HENT NUMBER:DOCUMENT DATE:MJMBER OF PAGES;AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

002303 - 00230301/11/91001Cynthia J . Kaleri, RPKU . S . EPA Region 6U . S . EPA Region 6 Site FiLcsROCRe: Incoming data for Fourth Street site

000423


ISTER1M

SITE HAKE: FOURTH STREET REFINERY SITESITE NUMBER: OKD 980696470

DOCUMENT HUHBER: 002304 - 002913DOCUMENT DATE: 01/18/91KUHfiER OF PAGES: 610AUTHOR: Staff ConsultantsCOKPANY/AGEHCY: Fluor Danial, Inc.RECIPIENT: U.S. EPA Region 6 Site FllaaDOdWEMT TYPE: Work PlanDOCUMENT TITLE: "Remedial Inveatlgaclon/Feasl-billty Study Work Plan, Revision

2 - Final" r^

CM

COmoo

33

000424


ADDENDUM

SITE NAME: FOURTH STREET REFINERY SITE

SITE NUMBER; OKD 09806970


000425

A&HIHISTRATIVE UCOfiO IHDCC

SITE MAKE:SITE NUMBER:



ADDEHDW

FOURTH STREET REriHE&Y SITEOKD 09S06970

002901 - 00290101/25/91001Cynthia J. Kaleri. RPM - T<xa</Oklahoma Unadia* SacCionU.S. EPA Ra&ion 6Dan Harcin, Concaainiinc Spacialiflt, U.S. fish and Wl.ldll.ecSot-vicesCorreapondancaRa: Receipt; of cha dat-aUa1 flaaedialInveatigatlon/FeaaibUicy Study (RI/FS) Work Plana,rspreaenting ch« Phaae I tnvesclgati.v afforc

DOCUMENT WUMBER;DOCUMENT DATE:NI MBER OF PAGESAUTHOR:COMPAQ/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

002902 - 00290302/01/91002Roberta K. Hire, Oklahooia SLaee Coordinacor and TAG SpeciaUttU.S. EPA Region 6Minnie Jones, InCttri.B Chairperson - Eascside CoalitionCorrespondenceRe: Concerns discussed during che Fourth Streec workshop inDecersber 1990

DOCUMENT NUMBER.DOCL'MENT DATE;.SZ'MBER OF PAGESAUTHOR;COMPANY/AGENCY;RECIPIENT:

DOCUMENT TYPE:OOCL-MKNT TITLE;

002904 - 00290503/11/91002Cynthia J . Kaleri , RPM - Texas/Ok. Lahoiaa tIeKa'iies SectionU . S . EPA Region 6Ghassen Khoury. Toxicologisc - Texas/Oklahoaa RemediesSection, U . S . EPA Region 6Memorandua w/o AccachraentsDrafc Baseline Risk Assessment: Approach for the Fourth Streesice --p^esent-ed by ARCs

DOCUMENT SUMBF.R:DOCUMENT DATH:•.T-M3ER Or PAGESAUTHOR:COMrANY/AGENCY:RECIPIENT:


002906 - 0029L703/14/91012Bob Helmberger. ARCs Project ManagerFlour Daniel, Inc.Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies Section.EPA Region 6Faxed Lab DataDaily record of samples caken at: t:he Fourth Street: siee;copies of the inorganic craffic reporca are also included

000426

SITl KAMI:sin mJKm:

OOCUHEWT KUKBEA:OOCUkEKT DATE:JRKSKXt Or PACUAOTHOR;OaKPAKY/ACWCY:IttClPIEWT:OOCUHJWT Tm:DOCUKDTr TITLE:

SOCVHEKT WKBER;&OCIMHT DATE;NUMBER Or PACESAUTHOR:COPtPAHY/ACENCY;R£CIPIE»T:DOCUMENT TYPE;roCUHEHT TITLE:

DOCL'HENT NUMBER:OOCL'HENT DATE:;nMER OF PAGESnirnioR:COHrAWY/AGr.KCY:RECIPIENT.

SOCUHENT TYPE;SOCL'ME.ST TITLE:

;OCJMENT -HBER:OCCrME^T DATE:NZ'MSER OF PAGESAITHOR:CCMPANY/AGENCY:RECIPIENT;

^OCJME^T TYPE:30CL-MENT T:TLE;

AlHUMUTBATlVl 2XCORO IMDCX

AX^KHDUK

rouRTH STUKT REritfm SITBOtCD 09106970

002918 . 00292203/15/91005Cynchi* J. K«lTl. IPH • T«KA«/Oklahoft« RtudLai S«cclonU.S. tPA Ifl&lon 6Myra P«r*2, rrlMry RSCC (61-HL), U.S. KPA R«ftion 6HaoorAXiduRInorganic Analyif for Ground Vacar ac ch« Fourth Screac «ic«<CA«6 Ho. 15370)

002923 • 00296903/27/91OA7Cynchl« J. Kal«ri. RPH • T«xa»/0klaho«a R«a«di«« SeccionU.S. EPA Region 6Rob«rc K. Franka. AXCa Project Kanagar, Fluor Daniel., Inc.Corr««pond«ncc w/Accach««ncsRPH'• cownca on Flour' s «ubniiccal of •.he Risk Assftssrencprotocol to b* ua«d for Fourth Screec

002970 - 00297103/28/91002Cynthia J. Kalcri. RPH - Texas/Cklahotaa Reracdies 5ec-:ionU.S. EPA Region 6Scocc A. ThoHipson, Envlronaencal. Specialise Supcr-.-isor.Okldhoaa StaCe D<parca»nc of Health (OSDH)CorrespondenceRe: Transiaiccal of the dac-a disk and '-he RisK Assessnencprotocol recoaniended by Flour Daniel

002972 - 00297203/29/91001Cynthta J. Kaleri, apH - Texas/Oklahoma Remecies SectionU.S. EPA Region 6Dr. Ghaascn Khoury- Toxicologiat (6H-SR) and Susan Swnson.geologist: (6H-SR), ' J . S . EPA Region 6HemornndumResulcs of ^he coxicicy Caacing on Parcel H far Four^n Scraet:

A-2

C^•/•

•

moo

000427

»ITK HAME:SITS WUHflM:

oocuKBrr NUMBER:DOCUHEKT DATE:mmEA OF PACESAUTHOR:

COMPAKY/AGEKCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

ADMINISTRATIVE MCORO INDXX

ADDKNDUK

roURTH STMET RiriKEttY SITEOKD 09806970

002973 - 00297404/03/91002Scott A. Thompson. Environnantal Sp«clali«c Superviaor,Tftchnic&l Programa DivisionOSDIIFranklo Richarda, RftdanL of Oklahoma City, OKCorreapondenceR««ulCJ of reBidanc tap water samples cakan on 02/25/91

DOCUMEHT mJMBER:DOCUHEHT DATE:NUMBER OF PACESAUTHOR;

COMPANY/AGENCY;RECIPIENT:DOCLMENT TYPE;DOCUMENT TITLE:

002975 - 002976OA/03/91002Scott A. Thonpaon, Environnencal Specialise Supervisor,Technical Programs DivisionOSDHMinnie Jonea. Resident: of Oklahoma Cicy, OKCorrespondenceResults of tap vacer sample collecced on 02/25/91

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER CF PAGLSAUTHOR:COMPANY/AGENCY':RECIPIENT:

OOCl-MENT TYPE:DOCUMENT TITLE:

002977 - 0029820^/09/91006Cynchia J. Kaleri. RrX - Texas/Oklahoma Remedies SeccLonU.S. EPA Region 6Hyra Perez, Priaary RSCC. 6E-HL - Houston Office, U.S EPARegion 6Transmiccal Fona w/Accached Lab ReportsInorganic Traffic Reports l-DE - l-FS

DOCUMENT NUMBER:DOCUMENT SATE:MJMBEft OF PAGES:AUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT riTLE:

002983 - 00301304/16/91031Cynthia J. Kalari, RPM - Taxas/Oklahonia Remedies SectionU.S. EPA Region 6Dr. Lubow Jowa, Flour Danial, Inc.Transmittal Forai v/Acr-ached MemorandumHuman Health Evaluation Manual, Supplemental Guidance;"Standard Default Exposure Factors"

A-3

000428

ADMINISTRATIVE RECORD IHDEX


DOCUMENT NUMBER:DOCUMENT DATE:KXBER OF PAGESAUTHOR:COMPANY/AGENCY:ftCCIFIENT:


ADDENDUM


003014 - 00301704/24/91004Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU.S. EPA Region 6Ken Brown, Direccor, Monitoring & Site Characterization(EMSL-LV), U.S. EPA Region 6Transaittal Form w/Attached MemorandumTechnical Support Request for fingerprinting wastes at twoOklahoma City sites via the Environmental Monitoring SystemLaboratory in Las Vegas, ^eveda (EHSL-LV)

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES;AUTHOR:



003C18 - 00302204/26/91005Scott A. Thompson, Environmental Specialist Supervisor,Technical Programs DivisionOSDHCynthia J. Kaleri. RPM - Texas/Oklahoma Remedies Section, L'.SEPA Region 6Correspondence w/o all Ref . AttachmentsRe: Oklahoma regulations concerning chemical specific ARARsfor the Fourth Street sites

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AL-THOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003023 - 00302504/30/91003Cynthia J . Kaleri , RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Robert K . Franke, ARCs Project Manager, Fluor Danie l , IncCorrespondenceRegarding additional funding needed Co complete the S.I/FSprojects Cor Fourth Street

DOCUMENT NU1BER:DOCUMENT DATE:NUHBER OF PAGESAUTHOR:

COHPANY/AGENCY:RECIPIENT:


OOJ026 - n0302605/07/91001Scott A- Thompson, Environmental Specialist Supervisor,Technical Programs DivisionOSDHCynthia J. Kaleri., RPM - Texas/Oklahoma Remedies SecLion, L ' -SEPA Region 6CorrespondenceRe: Review of the Fourth Street Superfund Baseline RiskAssessment Draft Protocol

A.4

000429


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER CF PAGESAUTHOR:COMPANY/AGENCY:KECIPIENT:



ADDENDUM


003027 . 00304405/08/91018Robert K. Franke, ARCs Project ManagerFluor Daniels, Inc.Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies Section, U.S.EFA Region 6Correspondence w/AttachmentsFourth Street Sites Risk Assessment Chemicals of Concern

DOCUMENT NUMBER;DOCUMENT DATE:STUMBER OF PAGESAUTHOR-COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003045 - 00304705/14/91003Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU . S . EFA Region 6U . S . EPA Region 6 Superfund Site FilesROCConference call between EPA and Fluor Daniel's Risk Assessor'sfor the Fourth Street site

DOCUMENT NUMBER:DOCUMENT DATE:^"MBER OF PAGESAUTHOR:COMPANY/AGENCY.RECIPIENT:


003048 - 00304905/21/91002Robert K . Franke, ARCs Projects ManagerFluor Daniel, Inc.Cynthia J - Kaleri , RPM - Texas/Oklahoma Remedies Section, U . SEPA Region 6CorrespondenceRe: Incorporation of the radio tower and Parcel H into theRisk Assessment for the Fourth Street site

DOCUMENT NUMBER;DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COHPANY/AGENCY:RECIPIENT:


003050 - 00305C-07/08/91001Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Don Will iams, Chief - Texas/Oklahoma Semedies Section, U . S .EPA Region 6MemorandumR«: Concurrent inveitL^ative work for the Fourth Street site

A - 5

000430


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAOTHOR:COMPANY/AGENCY:RECIPIENT:



ADDENDUM


003051 - 00305108/22/91001Bob Helmberger, ARCs Project EngineerFluor Daniel, Inc.Cynthia J. Kaleri. RPM - Texas/Oklahoma Remedies Section. U.S.EPA region 6Correspondence w/o EnclosuresRe; Preliminary draft Remedial Investigation reports forFourth Street Refinery areas

DOCUMENT NUMBER-DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;

COMPANY/AGENCY;RECIPIENT:

DOCUMENT TY?E;DOCUMENT TITLE:

003052 - 00305409/03/91003G. Wayne Sovocool, Chemist, Quality Assurance Research Branch,QADU . S . EPACynthia J. Kaleri, RPM Texas/Oklahoma Remedies Section. U . S .EPA Region 6MemorandumInterim report on the Technical Support Request fingerprintingwastes ac two Oklahoma City sices received from Region 6

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHORCOMPANY/AGENCY:RECIPIENT;

OCCIDENT TYPE:DOCUMENT TITLE:

003055 - 00305509/11/91001Robert K. Franke, ARCs Project ManagerFluor Daniel, Inc.Scott Thompson, Environmental Specialist Supervisor, TechnicalPrograms Division, OSDHCorrespondenceRe: Appendices to Remedial Investigation Reports for DoubleEagle and Fourth Street Refinery areas

DOCL-MENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:


DOCUMENT TYPE:DOCL-MENT TITLE:

003056 - 00305909/19/91004G. Wayne Sovocool, Quality Assurance Research Branch, QualityAssurance & Methods Development Div.U . S . EPA Region 6Cynthia J . Kaleri. RPM - Texas/Oklahoma Remedies Section, U . S .EPA Region 6Faxed Copy of ReportRe: Summary report on technical support request fcom Ragion 6- two Oklahoma City sites

000431



DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PACES;AITTHOR:COHPANY/AGENCY:RECIPIENT:


ADDENDUM


003060 - 00306010/01/91001Bob Helfflbergey, ARCa Project EngineerFluor Daniel, Inc.Cynthia J. Kalari, RPM - Taxaa/Oklahoaa Reniedica Section, U.SEPA Region 6CorrespondenceRe; Draft Phase II Work Plan AsiendiBencs for cha Double Eagiaand Fourth Street Refinery areas


003061 - 00306810/01/91008Gary Baker. SAICU . S . EPA HeadquartersU . S . EPA Region 6 Superfund Sice FilesEngineering NewsletterControl of Air Emissions from Materials Handling DuringRemediation


003069 - 00312610/07/91058Lynda L. Werner, CPCM, Goveir^nienc Contract ManagerFluor Daniel, Inc.Brenda Durden, EPA Contract Off icer , U . S . EPA Region 6Correspondence w/AtCached ReportRequest for consent to subcontract air .-noni coring analyticalservices for Fourth Street and Double Eagle sites

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCL-MENT TITLE:

003127 - 00312810/07/91002Cynthia J. Kaleri , RPM - Texas/Oklahoma Remedies >ci;lonU.S . EPA Region 6Robert K . Franke. ARCs Project Manager, Fluor Dan-el, Inc.Correspondence v/Fax Cover SheetRe: Discussion concerning continued protilems exp-eri.enced wi.chthe contractor in prepartion of the Draf^ RiskAdses-ment'-preliminary draft submitted ',n 07/25/51

A - 7

000432

SITE HAKE;SITE NUMBER:

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER Of PAGESAUTHOR:

COHPANY/AGENGY:RECIPIENT:


ADMINISTRATIVE RECORD IHDEX

ADDENDUM

FOURTH STREET REFINERY SITEOKO 09806970

003129 - 00313210/08/9100&M rk S. Coleman, Deputy Conuaiflfltonar, EnvironmantaX HaalthSarviceaOSDHMyron Knudson. P,E. . Director. Hazardous Waste ManagementDivision (KWMD). U.S. EPA Region 6Correspondence w/Fasc Cover SheetRe: OSDH's cocunencs concerning the Agency's projectedcompletion of the RI/FS phase for the Fourth Street and DoubleEagle Refinery sites




003133 - 00313510/24/91003G. Wayne Sovocool. Chemise, Quality Assurance Research Branch,QADU.S. EPACynthia J . Kaleri , RPM - Texas/Oklahoma Remedies Section, U . S .EPA Region 6MemorandumTechnology Evaluation Report for the Double Eagle and FourthStreet sices


003136 - 003UO10/31/91005Cynthia J . Kaleri , RPM - Texas/Oklahoma Remedies SectionU.S . EPA Region 6Robert K . Franke. ARCs Project Manager, Fluor Daniel. Inc.Fax Cover .^heet w/AtcachaientsEPA updates for <1) April 1990 Air/Superfund CoordinationProgram (2) January 1990 Air Pathway Analysis Procedures


003141 • 00314810/31/91008Cynthia J . Kaleri. RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Fluor Daniel, Inc.Correspondence w/AttachmencsRe; Discussion concerning an interim accion remediacion ofthe Double Eagle and Fourth Street sites and example tableformat for potential ARAfi-s

A-8

000433


SITE MAKE:SITE tfUMBER:

DOCUMENT NUMBER:DOCUKEHT DATE:yUHflER OF PAGESAUTHOR:COMPAHY/AGEKCY:RECIPIENT:


ADDENDUM

FOURTH STREET ILEHHClY SXTKOKD 09806970

003U9 - 003151U/05/91003Robarc K. Franke, ARCa Project ManagerFluor Dauiel, Inc.Cynthia J. Kalori. RPM - Texas/Oklahoma Raaadiaa Section, U.S .BPA Region 6CorrespondenceRe: Discussion concerning the Double Eagle Refinery andFourth Street Refinery Risk Assessments



003152 - 003156U/26/9L005Myron 0. Knudson, Director, HWKDU . S . EPA Region 6Hark S. Coleman, Deputy Commissioner, Environmental HealthServices. OSDHCorrespondence v/AttachraentRe: Agency's response to comments made by OSDH concerningEPA's progress on the Double Eagle and Fourth Street- sicesRI/FS activities

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:


003157 - 00316112/17/91005William Kirchner, Technical Assistance Seccion (6E-FT)U . S . EPA Region 6Cynthia J. Kaleri , RPM - Texas/Oklahoma Remedies Section, U . SEPA Region 6MemorandumWetlands, Double Eagle and Fourth Street Superfund Sices,Oklahoma City, Oklahoma

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR;COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003162 - 00318701/14/92026Carl R. Hickman, R . S . , Sanior Regional RepresentativeAgency for Toxic Substance and Disease Registry (ATSDR)Allyn M. Davis. P h . D . , Director, HWMD, U . S . £FA Region 6Correspondence w/ACCached ReportRe: Submittal of the Interim Preliminary Health Assessmentfor the Fourth Street Refinery

A-9

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ADHIMISTRATIVE RECORD INDEX

SITE SAME:SITE NUMBER:

DOCUHEKT NUMBER:DOCUMENT DATE:HUKBOl OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:


ADDENDUM


003188 - 00319101/21/92OOAScoCt A. Thompson, EnvironaanCal Specialise SuparviaorOSDHCynchia J. Kalori, RPM - Texas/Oklahoma Racudias Section, U.SEPA Region 6Correapondenco v/AttachnientsRa: OSDH comments on th« Fourth Street Draft RemedialInvaacigation Reports

DOCUMENT NUMBER:DOCUMENT DATE:MUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003192 - 00319401/23/92003Cynthia J . Kaleri, RPM - Texas/Oklahoma Remedies SectionU.S. EPA Region 6Robert K. franke, Fluor Daniel, Inc.ROCDiscussion concerning comments on the project work plan (PjWP)amendments for Phase II and Phase III of the RI/FS project:

DOC'JMENT W;MBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR•COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003195 - 00322501/27/92031Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU.S. EPA Region 6Robert K. Franke, ARCa Project Manager, Fluor Daniel. IncCorrespondence w/AttachmentsRe: RPM's detailed comments on the draft version of cheRemedial Investigation/Feasibility Study (RI/FS) for theFourth Street sice


003226 - 00322601/29/92001Cynthia J. Kaleri. RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Eve Boss, Superfund Contract Management:, L ' .S . EPA Region 6ROCRe; Discussion concerning comment cover Let ter on the draftRI , dated 01/27/92

A-10

000435


SITE HAME;SITE NUMBER:

DOCUMENT NUMBER:DOCUMENT DATE:HUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


ADDENDUM

FOURTH STREET REFINERY SITBOKD 09806970

003227 - 00322901/29/92003Cynthia J. Kalari, RPM • Texas/Ok lahofflfl Ramadl-oa SectionU.S. EPA Rftgion 6Robarc K. Franks, ARCa Project Mflnagsi:. Fluor Daniel, Inc.Correspondence w/AccachmencaRe: Comments on the Draft Remedial Investigation for theFourth Street site submitted by OSDH

003230 - 00323101/30/92002Cynthia J. Kaleri. RPM " Texas/Oklahoma Remedies SectionU.S. EFA Region 6Don Bovn, City Manager, City of Oklahoma City, OklahomaCorrespondenceRequest for access to ciCy owned property, by EPA and itscontractors, to perform RI/FS casks currently being conductedfor the Fourth Street sites

-t

-'Oinoo


003232 - 00323602/13/92005Cynchia J. Kaleri , RPM Texas/Oklahoma Remedies SeccionU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Fluor Dani-el, Inc.CorrespondenceEPA's response to contractors request: for 'nore guidance on thescope of effort for che Bench ScaLe Treatability Study for theFourth Street project

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003237 - 00324202/14/92006Cynchia J. Kaler i , RPM - Texas/OkLihoma Remedies SectionU . S . EPA Region 6Robert K. Franke, ARCs Project Manager. F^uor Daniel., Inc.CorrespondenceRe; RPM's outline of comments discussed vi.ch the contractoron 02/11/92, concerning the draft retailed Work Plan Amendment:for Phase III (Ground Water F.ffor" only)

A-ll

000436





ADDaffiUM


003243 - 00324302/24/92001Scocc A. Thompson, Enviornniental Specialist SupervisorOSDHCynthia J. Kaleri, RPM - Texas/Oklahoma Remedies Section, U.SEPA Region 6CorrespondenceOSDH commenCs on the Phase III workplan amendment:

DOCUMENT NUMBER;DOCUMENT DATE:^HJMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:


003244 - 00324403/03/92001Donald D. Brown, Cicy ManagerCity of Oklahoma Cicy. OKCynthia J. Kaleri - RPM, Texas/Oklahoma Remedies Section. U .SEPA Region 6CorrespondenceRe: EPA request for access to NE 4th and Martin Luther KingBlvd. properties Co perform various Casks associated with i:hesubject site

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR :COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003245 - 00326603/OG/92022Cynthia J. Ka-Ler i , RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Robert K . Franks, ARCs Project Manager, Flour Daniel , Inc.Correspondence w/AttachmentsDetailed comments on the draft Remedial Investigation for theFourth Street Refinery Site

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES;AUTHOR:COMPANY/AGENCY:RECIPIENT;DOCUMENT TYPE;DOCUMENT TITLE:

003267 - 00327303/12/92007Cynchia J . Kaleri , RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Robert K , Franka, ARCs Project Manager , Flour Daniel. , Inc .Transmittal Memo w/ROCCall to Dr. Soundararajan regarding usage of his copyrightadreport on Total Waace Analysis Procadures

A-12

u Itlri.. L—— h—uUJMAUMIINltttiMMhbft'i'lU-

000437



ADMINISTRATIVE RECORD INDEX•

ADDENDUM


00-274 - 00327403/K/92001Cynthia J. Kaleri. RPMU . S . EPA Region 6Robert K. Franke, ARCSCor reapordenceNotice to proceed viunthe revised work p^an

" Texas/Oklahoma Remedies Section

Project Manager. Flour Daniel. Inc.

mobilization activities as specified in

DOCUMENT NUMBER:DOCUMENT DATE;NUMBER OF PAGESAUTHOR;COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003275 - 00327503/16/92001Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6U.S . EPA Region 6 Superfund Site FilesROCCa.11 to Bob Heimberger to discuss access for che Phase IIIeffort of the RI/FS Project

DOCUMENT NUMBER:[>OCUMENT DATE:EWMBER OF PAGES:AUTHOR :COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003276 - OC327703/23/92002Cynthia J. Kaleri, RPK - Texas/Oklahoma Remedies SectionU . S . EPA Region 6U.S . EPA Region 6 Superfund Site FilesROCConference call with Flour Daniels concerning Risk Assessorsfor calculating the 95X UCL

DOCUMENT NUMBER:DOCUMENT DATE:^nJMBEH OF PAGES;AUTHOR;COHPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

003278 - 003:'7803/23/92001Cynthia J. Kaleri, RPM - Texaa/Oklahoma Remedies SectionU.S . EPA Region 6U . S . ERA Region 6 Superfund Site FilesROCDiscussion with Mark Hanaen regarding Air/Superfund Liason

A-13

000438

ADMINISTRATIVE RECORD .TNDEX


DOCUMENT NUMBER:DOCUMENT DATE:HUMBER OF PAGESALTOOR:COMPANY/AGENCY:RECIPIENT:BOCIJMENT TYPE:DOCUMENT TITLE:

ADDENDUM


003279 - 00327903/24/92001Cynthia J. Kaleri. RPM- Taxaa/Oklahorca Reffledies SectionU . S . EPA Region 6U.S. EPA Region 6 Superfund Siti. PilesROCConference call with George Pettigrew concerning Phase II AirMonitoring Results

DOCUMENT NUMBER:DOCUMENT DATE:NL-HBER OF PAGES;AUTHOR:COMPANY/AGENCY;RECIPIENT;DOCUMENT TYPE;DOCUMENT TITLE:

003280 - 00328003/26/92001Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6U .S . EPA Region 6 Superfund Site FilesROCConference call with Scott Thompson of OSDH concerning PhaseII Air Monitoring Results

DOCUMENT NUMBER:DOCIJMENT DATE:NUMBER OF PAGESAUTHOR.COMPANY/AGENCY;RECIPIENT:


003281 - 003:';'>04/03/92002William Kirchner, Technical Assistance SectionU.S . EPA Region 6Cynthia J. Kaleri , RPM " Texas/Oklahoma Remedies Section, U . SEPA Region 6Memorandum w/AttachmentWetlands classifications for Double Eagle and Fourth StreetSuperfund Sites

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES;AUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

003293 - 00328304/06/92001Cynthia J. Kaleri , RPM - Texas/Remedies SectionU . S . EPA Region 6Todd Adornaco, U . S . Fiah and Wildlife SarvicesTransmittal Form w/o Draft AttachmentTransmittal of the Draft Baseline Ecological Xi.yk Assessmentfor the Double Eagle/Fourth Street Site

A - 1 4

000439




ADDENDUM


003284 - 00328404/06/92001Cynthia J . Kaleri, RPM - Texas/Remedies SectionU.S. EPA Region 6Todd Adornato, U . S . Fish and Wildlife Services - Tulsa, OKROCRe: Phone conversation with He. Adornato to request hisreview and comment on che text summary of the Ecological RiskAssessment

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT;DOCUMENT TYPE:DOCUMENT TITLE:

003285 - 00328604/07/92002Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU . S . EPA Region 6U . S . EPA Region 6 Superfund Sice FilesROC - 3:10 p . m .Phone conversation wich Todd Adornato about che Draft BaselineEcological Risk Assessment

DOCUMENT N'UMfiER;DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003287 - 00328804/08/92002Cynthia J. Kaleri., RPM - Texas/Oklahoma Remedies SectionU.S . EPA Region 6Robert K. France, ARCs Project Manager. Flour Daniel, Inc.CorrespondenceNotification given to Contractor of the Agency's conditionalapproval of the Project Work Plan Amendments

DOCUMENT NUMBER;DOCUMENT DATE;NUMBER OF PAGESAUTHOR:COMPANY/AGENCY;RECIPIENT:


003289 - 00329104/09/92003Diana G. Ayers. Chief , Houston BranchU.S . EPA Region 6Carl Ediund, Chief - Superfund Programs Branch, U . S . EP/vRegion 6Memorandum w/AttachmenCsLaboratory results for the Fourth Street: Refinery sice

A-15

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ADDENDUM

FOURTH STREET REFINERY SITEOKD,09806970

003292 - 00329604/13/92005Cynthia J. Kaleri. 8PM - Texas/Oklahoma Remedies SectionU.S. EPA Region 6Robert K. Franks, ARCs Project Manager, Flour Daniel, Inc.Fax Cover Sheet: w/AttachmentsRe: Risk Assessment - Double Eagle/Fourth Street SitesBackground Lead Results

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE;DOCUMENT TITLE;

003297 - 00329704/14/92001Cynthia J. Kaleri, RPH - Texas/Oklahoma Remedies SectionU . S . EPA Region 6Robert K . Franke, ARCs Project Manager, Flour Daniel, Inc.Fax Cover Sheet v/o Ref . AttachmentsRe: Environmental Assessment for RI Reports for Double Eagleand Fourth Street Sites

DOCUMENT NUMBER:DOCUMENT RATE:NUMBER OF PAGES:AUTHOR:

COMPAQ/AGENCY:RECIPIENT:


003298 - 00330004/24/92003Dr. Jon Rauscher, Toxicologist and Cynthia J. Kaler i , RFM -Texas/Oklahoma Remedies SectionU . S . 6'PA Region f>Dr. David Charters, Environmental Response Team, U . S . EPARegion 6Fax Cover Sheet w/AttachmencsRequest Co review and coin^-ene on summary chapter of "BaselineRisk Assessment", location map, and copy of aerial photograph

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT;


003301 - 00330205/01/92002Robert K. Franke, ARCs Project: ManagerFlour Daniel, Inc.Cynthia J , Kaleri. RPM - Texas/Oklahoma Remedies Section, U .SEPA Region 6Correspondence hf/AccachnientsOutline of Alternatives submitted by EFA and OSDH

A-16

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ADDENDUM


003303 - 00331105/05/92009Cynthia J. Kaleri, RPM - Texas/Oklahoma Remedies SectionU,S. EPA Region CRobert K- Franke, ARCs Project Manager. Flour Daniel, Inc.Fax Cover Sheet w/o Ref- AttachmentsAgency's provision of necessary information for completion ofFeasibility Report for Double Eagle; and, the inclusion ofappropriate comments for the Fourth Street Site


003312 - 00331305/06/92002Cynthia J. Kaleri. RPM - Texas/Oklahoma Remedies SectionU . S . EFA Region 6Scott A. Thompson, Environmental Specialist Supervisor, OSDHCorrespondenceDirections for screening of alternatives for che DraftFeasibility Study

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGES;AUTHOR;COMr-ANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

003314 - 00332705/07/92014Cynthia J. Kaleri , RPM - Texas/Oklahoma Remedies Se/- iU . S . EPA Region 6Robert K. Franke, ARCs Project Manager, Flour Daniel, Inc.Transmictal Memo w/AttachmencsRe: 1-92 memo concerning Hazardous Wasce Management: Division(HWMD) Standard Operating Procedure (SOP) to provide help inthe development of specific short-term air action levels

DOCUMENT NUMBER:DOCUMENT DATE;.WMBER OF PAGESAUTHOR;COMPANY/AGENCY;RECIPIENT;


003328 - 00332805/H/92001Robert; K. Franke, ARCs Project: ManagerFlour Daniel ARCs TeamCynthia J. Kaleri., RPM - Texas/Oklahoma Remedies Section, E J . SEPA Region 6CorrespondenceSubmittal of Feasibility Study Reports for the Fourth ScraacRefinery Site

A - 1 7

000442




ADDENDUM


003329 - 00367405/29/92346Staff ConsultantsFlor-: Daniel, Inc.U.S. EPA Region 6 Superfund Site FilesReportThe Remedial Investigation/Feasibility Study - Volume 1 of

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:

003675 - 00404305/29/92369Staff ConsultantsFlour Daniel, Inc.U . S . EPA Region 6 Superfund Site FilesReportRemedial Investigation Report - Volume 2 of 4

[)OCUMENT .WMBER:DOCUMENT DATE;MJMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

004044 - 00463405/29/92591Staff ConsultantsFlour Daniel, Inc.U . S . EPA Region 6 Superfund Site FilesReportRemedial Investigation Report - Volume 3 of 4

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

0046J5 - 00517405/29/92540Staff ConsultantsFlour Daniel, Inc.U . S . EPA Region 6 Superfund Site FilesReportRemedial Investigation Report: • Volume 4 of 4

A-18

000443


DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGESAUTHOR:COMPANY/AGERGY:RECIPIENT:DOOJMEST TYPE:DOCUMENT TITLE:


ADDENDUM


005175 - 00536506/01/92191Staff ConsultantsFlour Daniel, Inc.U.S. EFA Region 6 Superfund Site FilesReportContaminant Source Control Draft Feasibility Study for theFourth Street Superfund Site



DOCUMENT TYPE:DOCL^ENT TITLE;

005366 - 00539706/02/92032Robert K . Franke, ARCs Project Manager and Mark L. deLoriaiier, P . E . , ARCs Program ManagerFlour Daniel, Ir.c.Cynthia J. K-aleri, RPM - Texas/Oklahoma Remedies Section, U . S .EPA Region 6Correspondence w/Attachmenc-sTransmittal of Revision I to the Remedial InvestigationReports for che subject Site

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:

COMPANY/AGENCY:RECIPIENT;


005398 - 00539806/04/92001Robert K . Franke, ARCs Project Manager and Mark L , deLorifflier, P . £ . , ARCs Program ManagerFlour Daniel, Inc.Cynthia J. KaXer i , RPM - Texas/Oklahoma Remedies Section, U . SEPA Region 6Cor responds neeTrans.TBittal of a set of keys Cor the groundwater monitoringwells and gates for the Fourth Street Site

DOCUMENT .SLUMBER:DOCUMENT LATE:NUMBER OF PAGESAUTHOR;COMPAQ/AGENCY:RECIPIENT:

DOCUMENT TYPE;DOCUMENT TITLE:

005399 - 00539906/04/92001Robert K . Franke, ARCs Project ManagerFlour Daniel ARGs TeamCynthia J. Kaleri , RPM - Texas/Oklahoma Remedies Seccion, U , SEFA Region 6CorrespondenceSection 5.0 of the Remedial Investigation Report for theFourth Street Refinery Site

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000444


DOCUMENT NUMBER:DOCUMENT SATE:NUMBER OF PAGESAUTHOR:COMPANY/AGENCY:RECIPIENT:



ADDENDUM


005400 - 00552406/30/92125Staff ConsultantsFlour Daniel, Inc.Cynthia J. Kaleri, RPM -EPA Region 6 Texas/Oklahoraa Remedies Section, U . S .Draft Report

Bench-Scale Treatability Study Report for the Fourth StreetSuperfund Site

DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGES:AUTHOR :COMPANY/AGENCY:RECIPIENT;


005525 " 005:)4207/08/92018

Community Relations StaffU.S. fcPA Region 6

Residents of Oklahoma City, OK and U . S . EPA Region 6 SuperfundSite FilesProposed Plan

The Agency's proposed approach for addressing the contaminatedsoil and sludges at the Fourth Street: Refinery sice

A-20

000445


ADDENDUM

SITE NAME; FOURTH STREET REFINERY SITE

SITE NUMBER: OKD 980696470


000446


DOCUMENT NUMBER;DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY:RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE:


ADDENDUM


005543 - 00567306/30/92131Staff ConsultantsFluor Daniel, Inc.U . S . EPA Region 6 Site FilesReport"Draft Bench-Scale Treatability Study Report"


005674 - 00571807/23/92045Julie CurryBailey Court ReportingU . S . KPA Region 6 Site FilesTranscript"Double Eagle/Fourth Street Public Meeting Transcript"

DOCUMENT NUMBERDOCUMENT DATE:NUMBER OF PAGESAUTHOR:



005719 - 00571908/09/92001Mark S. Coleman, Deputy Commissioner, Environmental HealthServicesOklahoma State Department o£ HealthAllyn M. Davis, Director, Hazardous Waste Management Division,U . S . EPA Region 6CorrespondenceState's preference for onsite stabilization and neutralizationof wasces followed by disposal In offsite commercial landfillas nonhazardoua waste

DOCUMENT NUMBER:DOCUMENT DATE:NUMBER OF PAGES:AUTHOR:COMPANY/AGENCY;RECIPIENT:DOCUMENT TYPE:DOCUMENT TITLE;

005720 - 00585809/28/92139B . J . Wynne, Regional AdminiatratorU.S. EPA Region 6U . S . EPA Region 6 Sits FilesRecord of Decision"Record of Decison for Fourth Street Refinery Site, OklahomaCity, OK" (Responsivanoss Summary is Attachment B of theRecord of Dociaion.)

A-l

000447

ATTACHMENTS

THE RESPQNSiyENESS SUMMARY

The Responaiveness Summary has been prepared to provide writtenresponses to comments submitted regarding the Proposed Plan ofAction at the Double Eagle Refinery Superfund site. The summary isdivided into two sections.

section Is Ba^grQu_pd .of ,goitimijLnity.._Xnyolvem.ent,An, Concerns. Thissection provides a brief history of community interest and concernsraised during the remedial planning activities at the FSR site.

Section II: Summary of Major Comments Rece.ivecL The comments (bothoral and written) are summarized and EPA's responses provided.

7. Background of Community Involvement and Concerns

Interest in the FSR site on the part of the residents, localgovernment officials, and potentially responsible parties (PRP's)has been moderate. Community relations activities were initiatedin 1989 when th^ site was proposed for inclusion on the NationalPriorities List. A Community Relations Plan (CRP) was developed inDec. 1989, and the final published and released to the public onJan. 26, 1990. The CRP was prepared to identify and addresscommunity concerns raised during the RX/FS. Copies of the CRP arelocated in the information repositories. The CRP identified thatthe primary interest in the FSR site lies mostly with the residentswho live near the site. No PRP's have come forward concerning theFSR site although some have identified themselves as possiblePRP's.

H. Summary of Mawr Comments Received

Public notice announcing the public comment period and opportunityfor a public meeting was printed in the The .D_aily QklahOJnian andThe Black Chronicle on July 17, 1992. The proposed plan fact sheetwas distributed to the site mailing list on July 3.0, 1992. An openhouse was conducted on July 23, 1992, to inform the public aboutthe Feasibility Study Report and the Proposed Plan of Action. TheGonunQnt period began on July 17, 1992, and ©nded on August 15,1992. At the meeting, EPA and OSDH officials discussed thecontamination problems at the site, presented the various remedialalternatives that were considered„ and presented the preferredalternative for the remediation of the FSR site.

Approximately thirty people wera in attendance, at the meeting.The public was given the opportunity to make comments or askquestions. Seven people made comments or asked questions. A fullaccount of the public meeting can bo found in the public meeting•transcript which i& documented in the FSR Adwinistative Record.One latter was received with comments.

69

000448

a) SteEteaJL fflaiaBte

The comments/questions received orally during the public meeting onJuly 23, 1992 are as follows:

1. Comment:

The commenter expressed concern that the stabilization alternativeis not permanent, and that from research it appears that at othersites, casings have deteriorated, resulting in pollution enteringthe soil and groundwater. The conumanter further raad a list ofchemicals that have be^i encountered at the sites (both FSR and DERsites), and the reuxt^g health effects seen in experimentalanimals upon exposure to many of these hazardous sub-stances. Thecommenter concluded bj- recommending that alternative ^7"Excavation, off-site Incineration and Disposal of Ash" be utilizedat the site. ^

1 1 ' '\Response i\,

The stabilized mass referred to in Alternative #5 is permanentsince it chemically binds the contaminants in the stabilized massto achieve immobility. At the public meeting, EPA indicated thatthe treated waste would be placed in an on'-site landfillconstructed on the FSR property, with a leachate collection system,linei: and impervious clay layer placed beneath the waste. However/in the selected remedy the waste will be placed in an off-sitacommercial landfill permitted to accept this type waste. Any waterthat might percolate down through the low permeability clay cap canbe pumped out periodically, removed and treated.

The risk assessment has revealed that even though 26 hazardouschemicals were identified to be present at the FSR site, the onlythreat to humans are from exposure to lead. Incineration will notaddress the risk associated with the metals contamination at thesite. Once the lead is stabilized and covered in the landfill thesource will be eliminated and consequently the threat to humanhealth. The remaining contaminants identified at the FSR site arebelow th?. clean-up levels determined to pose a threat in theRemedial Investigation.

2. Comment:

The commenter stated that all EPA sites should be covered as soonasi we find out a potentially hazardous condition exists, to protectnot only transients and animals from wande-ring on the aite? butalso birds and other migratory fowl that might fly in and carry oftcontaminants.

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000449

Response:

The EPA has investigated the possibility of placing nets over anysurface of the suface impoundments, lagoons, and the tar mat areaat the FSR and DER sites, and have are looking into the possibilityof placing the nets over any contamination.

3. Comment:

The coannenter asked what volume of sludge is present at the FSRsite.

Response:

Approximately 43,000 cubic yards of oily re-refinery waste ispresent at the FSR site.

4. Comment:

The conuaenfcer asked if the EPA planned to clean up both the FSR andDER sites at the same time.

Response:

The FSR and DER sites have been a^d will continue to be run asconcurrent sites.

5. Comment:

The connaenter made a general statement that the people in the areaof the FSR and DER sites want the contaminants "out of theirbackyard"; but the dilemma remains as to where the waste will gofrom the sites (i.e. in whose "backyard" wi.i-1 the waste go?) Thecommenter stated that the alternatives that the EPA leaves thecitizens are landfilling and or incineration; and neither of thosealternatives are acceptable. The commenber wants more choices thanare presently available and is frustrated that more research isnot being conducted to provide more alternatives to the problemsassociated with Superfund sites.

Response:

Research is presently being conducted to develop new technologiesfor remediation of Superfund sites. However, the EPA must continuewith the clean up of these site with the technology that isavailable.

<$. Comment:

The commenter asked why the Hazard Index was higher for off-siterather than on-site worker exposure for both sites.

71

000450

Response:The assumption used for the off-site exposure scenario considereda residential setting with a longer exposure duration and frequencyinvolving children. The assumption used for the on-site exposurescenario considered an industrial setting vith a shorter exposureduration and frequency involving adult workers.

7. Comment:

The commenter asked what the stabilization ratios were used todevelop the cost estimates.

Response:

150% cement kiln dust by weight.

8. Comment:

The commenter asked for a clarification on what type of kiln dustwas being referred to in comment #7, since some kilns burnhazardous waste.

Response:

The kiln dust being referred to ir; comment #7 is cement kiln dustfrom the production of Portland cement and will not contain anyhazardous constituents.

9. Comment:

The commenter asked what has been found in the ground wateraonitoring wells off-site, especially with respect to alluvial flowtoward the North Canadian River.

Response:

Analysis from groundwater sampling revealed the presence of thesame type contaminants as found in the sludges; primarily lead,cadmium, vinyl chloride and benzene, all above drinking waterstandards. Additionally, very high total dissolved solids weredetected at the FSR and DER sites. Salt concentrations encounteredat the sites were as high as 13,000 parts per million.

10. Comment:

The commenter asked if any other governmental body was involvedwith the site remediation other than the EPA and OSDH.

Response:

No ox-her agency is directly involved, however but the city andcounty agencies have been kept informed throughout the entire

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process.

11. Comment:

The commenter asked what disposal repository was used whenpreparing the cost analysis for off-site disposal.

Response:

No sing.le disposal facilit was used in the cost estimate. Severalfacilities in the vicinity were considered, then an average costdetermined.

12. Comment:

The commenter asked when the second phase of the groundwaterinvestigation will begin.

Response:

The planning process has begun and a scope of work has beensubmitted to a contractor. A formal work plan will be developed andreviewed during the fall '92.

13. Comment:

The conunenter asked what the high salt levels in the alluvialaquifer was attributed to*

Response:

The high salt concentrations could be naturally occurring levels,although it is more likely that it is due to historical petroleumproduction in the general vicinity.

14. Comment:

The commenter stated that the high salt concentrations in thealluvial aquifer were probably from the disposal pits at the siteformally being used as repositories for salt water from theOklahoma City field in the 1920's.

Response:

Information is available on the FSR and DER properties from whenthey started accepting used oils, but prior to that no informationis available on the type activities at tha sites, therefore noexact determination can be made as to the origin of the high saltcontent in the alluvial aquifer beneath the refinery sites.

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a) writseiL^ommeafcs

The following comments were received in writing by the EPA on Aug.13, 1992:

1. Comment:

Of the remedial alternatives proposed for the site, alternative #5,"On-site Stabilization and Disposal in an off-site Landfill"appears to be the most reasonable because of the followingadvantages. A) The contaminated material would be removed from thepresent site thereby permanently decreasing human exposure in thisarea. B) There would be no long term site maintenance andmonitoring required. C) There would be no further risks to theground water of this area or the water of the North Canadian River.D) Option #5 is estimated to be more cost effective than Option #4selected by the EPA.

Response:

Congressional mandate dictates preference to an on~s ite remedy whenever practicable. However, the State of Oklahoma prefers thealternative requiring less cost, no operation and maintenance, andthat results in a better ultimate disposal of the waste.

2. Comment:

The completeness of the PRP list, those that received the 8/23/91104(e) Information Request Letter, and the method used to compilethis list are questioned. First, it is not reasonable to expectgreater than 70 percent of an alphabetic list of PRPs to appearunder the letters A thru D, It appears PRPs were less likely to beincluded on the EPA list if the name happened to begin with aletter that occurs later in the alphabet. Second, the practice ofnaming PRPs solely because of their association with a particularwaste oil service may cause entities to be named as a PRP when infact there was no involvement. This uncertainty should justify aprocess to allow evaluation of an entity's involvement or extent ofinvolvement on an individual basis.

Response:

EPA is continuing the search for PRP's and the FRP list is by nomeans final.

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ATTfiCHMEWT C

Joan K. LeoviH/ M.D. OKLAHOMA:STAT&C^missioner ______ DEPARTMENT pP,HlgA :;

Board of Health IClpOWTENTHOKLAHOMA tY?0^

73117-1299HAZA?-;.:^ ••.,;,^

AN EQUAL OPCCftTUNOY EMrtOYER

John B. Cormichcwl, D.D.S. Gordon H. Decker!, M.D.Pr»»denf Don H. Heker, D.O.Ernest 0. Mor'in, It.Ph. Undo M. Johnson, M.D.Vie* President Walter Scoti Mason, 1 ( 1Burdge P. Greon. M.O. Lee W. PodenSecretory-Traas uref

August 4,1992

Mr. Allyn Davis, DirectorHazardous Waste Management Division (6H)U.S. Environmental Protection Agency1445 Ross Ave» Suite 1200Dallas. Texas 75202-2733

Dear Mr. Davis:

This letter is in reply to your letter of July 6, 1992. Your letter requests that the OklahomaState Department of Health (OSDH) provide comments on the Proposed Plans for theDouble Eagle Refinery and the Fourth Street National Priorities list (NPL) sites. OSDHprefers the onsite stabilization and neutralization of wastes followed by the disposal in anoffsite commercial landfill as nonhazardous waste. OSDH has no technical objection to theonsite landfill recommended by EPA, but prefers the offsite landfill because the FeasibilityStudy indicates a significantly higher cost for the onsite landfill.

The offsite landfill also has the advantage of saving taxpayers the cost of operation andmaintenance each year. EPA would not be required to conduct five-year reviews of theremedy because the waste would be removed from the site.

Thank you for your time. If you wish to discuss these matters in more detail please call me at(405)271-8056.

Sincerely,

f^tl c^l J 6iA^

Mark S. Coleman, Deputy CommissionerEnvironmental Health Services

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RECORD OF DECISION · site") occupies the Southwest Quarter (SW 1/4) of Section 36, Township 12...

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Transcript of RECORD OF DECISION · site") occupies the Southwest Quarter (SW 1/4) of Section 36, Township 12...