United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/025
September 1987
EPA Superfund
Record of Decision:
DALLAS, 1HXAS
Compass Industries, L.F., OK
Vo
N
K
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
ROD/R06-87/024
3.
47TTTLE ANOSUCTITLK
SUPERFUND RECORD OP DECISION
Compass Industries Landfill, OK
First Remedial Action - Final
3. RECIPIENT'S ACCESSION NO.
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSOR!
Y CODE
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
The Compass Industries site is an abandoned landfill west of Tulsa, Oklahoma and in
close proximity to a county recreational facility. The landfill is situated 200 feet
pve the Arkansas River, into which surface water drains from the site in the form -of
ff, springs and streams. From 1930 through 1950 the site operated as a limestone
rry. From 1972 to 1976 it operated as one of the major landfills for municipal and
industrial wastes in the Tulsa area under permit by the Oklahoma State Department of
Health. There is evidence, however, that dumping occurred as early as 1964. Few
records were kept on the exact type, quantity and location of wastes in the landfill
during its operation, although, during the 1970s and 1980s air quality monitoring
identified organic chemicals at non-hazardous levels. Sampling performed in conjunction
with the remedial investigation identified numerous organic and inorganic pollutants.
The total volume of waste is estimated to be 620,000 yd^. The primary contaminants of
concern affecting a shallow aquifer and overlying soil include inorganics (zinc, lead,
copper, barium, chromium) and organics (2-methynaphthalene, phenanthrene,
bis(2-ethylhexyl)xylenes, benzo(b)-fluoranine, benzo(a)anthylenepyrene phthalate).
The selected remedial action for this site includes: installation of a RCRA cap,
site grading, surface water diversion and air emissions monitoring; installation of
(See Attached Sheet)
17.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Croup
Record of Decision
Compass Industries Landfill, OK
First Remedial Action - Final
Contaminated Media: gw, soil
Key contaminants: organics, inorganics,
heavy metals
TRIBUTION STATEMENT
19. SECURITY CLASS (Tha Rtport)
None
21. NO. OF PAGES
38
20. SECURITY CLASS (This pagei
None
22. PRICE
EPA Form 2220.1 (R««. 4-77) PMKVIOU* COITION i* OMOLCTC
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EPA/ROD/R06-87/024
Compass Industries Landfill, OK
First Remedial Action - Final
16. ABSTRACT (continued)
security fences and warning signs; and implementation of ground water and air monitoring
analysis programs. The estimated capital cost for this remedial action is $9,300,000
with annual O&M of $270,000.
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t
I
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMPASS INDUSTRIES LANDFILL
TULSA COUNTY, OKLAHOMA
SEPTEMBER 1987
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Compass Industries, Tulsa County, Oklahoma.
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for this
site developed in accordance with Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and the
National Contingency Plan (40 CFR Part 300).
The State of Oklahoma has concurred on the selected remedy.
(Letter attached)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Compass
Industries Superfund Site [index attached]. The attached index identifies
the items which comprise the administrative record upon which the
selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The major components of the selected remedy include:
Installation of a cover which isolates contaminated material from
human contact and reduces infiltration or precipitation through the
landfill area. The capping and closure procedures will be designed
in accordance with the Resource Conservation and Recovery Act (RCRA)
to achieve a goal of 10~' cm/sec premeability. If a synthetic
liner is determined to be technically feasible and cost effective
in accordance with the preliminary cost estimates developed in the
Feasibility Study, that liner shall be no thicker than 30-40 mil.
t Collection and on-site treatment of contaminated groundwater in the
upper, perched water bearing zone, if deemed necessary through compliance
monitoring following installation of the cover material.
Installation of fences and signs along the perimeter of the cap.
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DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate and is cost-effective. Finally it is determined that
this remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
ate Robert E. Layton Jr/, P.
Regional Administrator
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Compass Industries Landfill
Record of Decision Concurrences
The Compass Industries Landfill Record of Decision has been reviewed
and I concur:
Q!
Allyn M.TSavis, Director
Hazardous Waste Management Division
Carl^TEdluria1, Chief
Superfund Program Branch
Hazardous Waste Management Division
~St"ep>fen AGiilreini, Chief
AL0NM Remedial Section
Superfund Program Branch
Hazardous Waste Management Division
.
ronnfe J. DeVos, Chief
State Programs Section
Superfund Program Branch
Hazardous Waste Management Division
Ben
Jennett Stokes, Chief
Solid Waste and Emergency
Response Branch
Office of Regional Counsel
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TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DECRIPTION
Site History 1
Geology 3
Remedial Investigation Results 3
Potential Impact of Site on Human
Health and the Environment 7
II. ENFORCEMENT 7
III. COMMUNITY RELATIONS HISTORY 7
IV. ALTERNATIVES EVALUATION
Evaluation Criteria 8
Description of Alternatives 11
Evaluation of Alternatives 13
V. PROPOSED REMEDY
Rationale 16
Consistency with the National Contingency Plan
and Superfund Statutes 17
Operation and Maintenance 18
Future Actions 18
VI. APPENDICES
A. Tables 1-4
B. Community Relations Responsiveness Summary
C. Agency for Toxic Substances1 and Disease Registry (ATSDR)/
Centers for Disease Control (CDC) Evaluation
D. Administrative Record Index
E. State Concurrence Letter
f
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EXECUTIVE SUMMARY
The Compass Industries site is an abandoned landfill located west of
Tulsa, Oklahoma. The site occupies an abandoned limestone quarry.
From 1972 to 1976 the site was permitted and operated as a solid and
Industrial waste landfill.
Geologic investigations verify that the site Is underlain by two
aquifers. The Hogshooter Formation contains a shallow aquifer and the
Layton Sandstone member of the Coffeyville Formation forms a deeper
aquifer. The Hogshooter Formation forms an unconfined, low-yield
perched aquifer. Between the upper and lower aquifers is a sequence of
32 to 50 feet of shales. The relatively low permeability of these
shale units acts as a partial confining bed that restricts the downward
migration of groundwater. Therefore, most of the groundwater contamination
is confined to the Hogshooter Formation and the overlying soils.
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Summary of Remedial Alternatives Selection for
Compass Industries Landfill
Tulsa County, Oklahoma
July 1987
I. SITE LOCATION AND DESCRIPTION
The Compass Industries site is an abandoned landfill located in a
former limestone quarry west of Tulsa, Oklahoma (Figure 1). It is
situated directly west of the Chandler Park softball facility, which
is owned and maintained by Tulsa County. Physically, the site is
situated on a bluff approximately one-quarter mile south and 200
feet above the Arkansas River. The site's topography slopes downward
to the west and north and ranges in elevation from approximately 770
to 860 feet above mean sea level. The majority of runoff flows
through water gaps in the ridge between the landfilled area and the
river or to ponds on the landfill. The clayey topsoil that is present
is derived from cover material utilized by the landfill operation.
The natural soils in the area are composed mainly of limestone residuum
and similar constituents. Pioneer plant species and grasses cover
most of the site.
Site History
The Compass Industries site is located in a former limestone quarry
which operated from the 1930's through the 1950's. The site was
permitted by the Oklahoma State Department of Health and operated as
a landfill from 1972 to 1976. There is evidence that dumping occurred
as early as 1964. As .one of the major landfills in the Tulsa area
during those years, It accepted both municipal and industrial wastes.
Unlike most landfills in current operation, the operators of Compass
Industries landfill apparently kept few records concerning which
wastes were disposed in the landfill. In addition, site data indicates
that disposal of the waste was done in an irregular manner, making
it difficult to ascertain where the wastes are located.
During the 1970's, several fires were reported at the landfill. The
most recent fire burned out in late 1984. It had burned underground
for several years, breaking through the topsoil cover on occasion.
During this same time period, citizen complaints of odors prompted
air monitoring in the vicinity of the landfill. The results obtained
from this monitoring revealed the presence of some organics, but at
levels that were considered non-hazardous. Currently there are no
known underground fires at the site; however, there exits a potential
for future fires.
The Compass Industries site was listed on the National Priorities
List (NPL) in September 1984, and funding for the remedial investigation
and feasibility study was provided by the U. S. Environmental Protection
Agency (EPA).
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FIGURE 1
LOCATION MAP
COMPASS NDUSTRES LANDFILL Sll
TULSA. OKLAHOMA
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Geology
The Compass Industries site occupies an abandoned limestone quarry on a
hilltop about 200 feet above the Arkansas River, and 1/4 mile south of
the site on the north. Surface water from precipitation runoff, springs,
and seeps flows Into the Arkansas River through a simple network of
small streams.
The Hogshooter Formation and the Coffeyville Formation outcrop 1n and
around the site (Figure 2), and comprise part of a sequence of shales,
sandstones, and limestones formed in shallow marine and deltaic
environments in late Pennsylvanian time.
The Hogshooter Formation forms an unconfined, low-yield perched aquifer
that is exposed at the surface on all sides of the site. This aquifer
1s recharged directly from local precipitation infiltration and is
discharged through seeps and springs into surface'waters near and
within the site.
A thick sandstone zone, the Layton Sandstone member of the Coffeyville
Formation, forms a second, somewhat deeper aquifer. It too recharges
from precipitation and discharges through seeps to surface water. No
use of water from either of these aquifers is known. Water table contour
maps of each aquifer indicate that groundwater flows to the west-northwest
at the site.
The volume of the waste was determined to be approximately 620,000
cubic yards. The average groundwater flow rate of both aquifers is 720
gallons per day or an estimated 263,000 gallons of water per year.
Remedial Investigation Results
During the RI of the Compass Industries site, samples were collected
from soil, water, and air to determine if significant pollutant
concentrations are present. Routes of off-site migration include
surface runoff, groundwater (by way of recharge to seeps and surface
runoff), transported sediments, and air.
Analytical results of the samples collected from the site indicate a
large number of organic and inorganic priority pollutants were
detected. They include a total of 12 inorganic priority pollutants and
at least 33 organic priority pollutants, the most common priority
pollutants being base-neutral compounds. The concentrations were
greatest in samples of waste collected from the surface and in test
trenches.
Groundwater samples were collected from 19 monitoring wells during the
RI. These include 18 samples collected from 14 shallow wells completed
in the perched water table aquifer, and eight samples collected from
five deep wells completed in the Layton Sandstone.
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ADAPTED FROM: BENNISON, 1972
4000
Scale, Feet
LEGEND
QUATERNARY DEPOSITS
FLOODPLAIN ALLUVIUM
QUATERNARY DEPOSITS
UNDIFF. TERRACE DEPOSITS
NELLIE ELY FM-GRAY SHALE
HOGSHOOTER FM-LIMESTONE
COFFEYVILLE FM-GRAY SHALE
LTZ3 COFFEYVILLE FM -LAYTON SANDSTONE
N
FIGURE 2
GEOLOGIC MAP
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Surface water runoff and sediment samples from drainageways were collected
around the perimeter of the landfill to determine if contaminated
runoff and sediments were leaving the site. Sampling sites for surface
water runoff were selected following several on-site inspections during
rainfall events. The general direction of surface runoff is to the
north and northwest. Sites for sediment sampling were located using
aerial photographs, topographic maps, and on-site field surveys. Seven
sediment samples from seven locations were collected, generally in the
same areas where runoff samples were collected.
Ten seep samples were collected to determine if contaminants were
being leached out of the landfill wastes and transported. Seepage
occurs along the perimeter of the landfill near the contact between the
Hogshooter Formation and Coffeyville Formation. Sampling sites were
located following a period of wet weather by observing potential seep
areas identified during the preceding winter. Freezing conditions
during the winter permitted the Identification of seeps as ice was
formed at the point of discharge from the bluffs.
Surficial soil samples were collected randomly around the perimeter and
within the interior of the site to determine 1f surficial soils were
contaminated. Eleven soil samples were collected at the 11 locations.
One sample was collected near the site entrance as a background sample
for comparing constituent concentrations.
In order to determine the extent, characteristics, and distribution of
the waste at the site, samples were also collected from the bottom of 17
backhoe trenches.
Air samples were collected by the EPA Technical Assistance Team (TAT)
during trench excavation and waste sampling. These samples were collected
immediately upwind, downwind, and within the test pit. In addition,
air monitoring using an organic vapor analyzer (OVA) was performed at
each trench during excavation.
Conclusions
The hydrogeologic and topographic setting of the Compass Industries
site appears to minimize the migration of contaminated groundwater both
laterally and vertically. The site is located on a bluff a short
distance above the Arkansas River. Both the shallow and deep aquifers
(the Hogshooter Formation and Layton Sandstone member of the Coffeyville
Formation, respectively) outcrop around the entire perimeter of the
site. The deep aquifer is separated from the shallow aquifer by 35 to
50 feet of shale units. The relatively low permeability of the shale
acts as a partial confining bed that appears to restrict most of the
downward migration of contamination to the deep aquifer. Therefore, it
appears that most of the contaminated groundwater at the site is contained
within the Hogshooter Formation and overlying soils.
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5
An evaluation of all sample results presented in the Remedial Investigation
Report for the Compass Industries site has resulted in the following
Interpretations on the extent and concentration of hazardous wastes at
the site.
1. Migration of contaminants in the groundwater 1s currently being
mitigated by attenuating mechanisms since much greater concentrations
were measured in solid samples. Possible attenuating mechanisms
include compounds with relatively low solubility and miscibility and
high soil adsorption capacities.
2. Table 1 provides a list of the three highest concentrations of
inorganic and organic priority pollutant compound concentrations for
samples of groundwater and waste. This table shows that greater
contaminant concentrations are present in the wastes than in groundwater
and that the deep groundwater is less contaminated than the shallow
groundwater. The highest concentrations of organic compounds for
aqueous samples were detected in the sample from USEPA/TAT well
number one. This sample is probably of an isolated zone of disposed
liquid wastes.
3. Off-site contaminant migration is currently limited to surface
runoff and seeps (which are fed by groundwater). Currently this
does not present a significant health threat.
4. Samples of groundwater from monitoring wells on the site is highly
contaminated. This indicates a degradation of groundwater quality
due to waste disposal in both the perched and deep aquifers. The
perched aquifer is much more severely contaminated than the deep
aquifer.
5. Where wastes were sampled at the ground surface many samples
contained significant concentrations of both inorganic and organic
priority pollutants. The surface waste samples were similar in
composition to wastes sampled from trenches.
6. The site's impact on air quality appears to be minimal at this time
and it is only during intrusive activities, such as trenching or
during fires, that elevated levels of air contaminants may present a
health hazard.
7. The volume of the waste was determined to be approximately 620,000
cubic yards. The average groundwater flow rate of both aquifers is
720 gallons per day. Groundwater remediation will require treatment
of an estimated 263,000 gallons of water per year.
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Potential Impact of Site on Human Health and the Environment
The three major pathways of possible off-site contaminant migration are
surface water, groundwater, and air. The possibility also exits for
direct contact at the site with contaminated source materials, such as
sludge, soil, or sediments.
Surface water runoff and seeps that discharge along the perimeter of the
site are the most significant pathways of contaminant migration off-
site. Exposure to surface water can be by direct contact or by
ingestion. The transfer of contaminants to off-site surface water 1s
another possible exposure pathway.
The majority of the contamination in the groundwater is confined to the
upper aquifer. Relatively impermeable shales between the upper and
lower aquifers serve to reduce the flow of contaminants to the lower
aquifer. Significant concentrations of organic and inorganic
contaminants were detected in the shallow aquifer. A detailed analysis
of the contaminants detected is contained in the RI report.
The site contains a significant concentration of relatively low hazard
gases, and exhibits only trace quantities of toxic volatile organic
vapors. A minimal respiratory hazard is posed by the site, although
a potential hazard may exist in the event of a subsurface disturbance
or fire. Exposure due to air emissions can be by inhalation or indirect
contact. The source material poses an exposure risk due to direct
contact or by inhalation and ingestion of airborne dust.
II. ENFORCEMENT
Approximately 20 Potentially Responsible Parties (PRPs) have been
identified, and may be given special notice to conduct the Remedial
Design and Action. To date, there has been no PRP involvement at the
site.
i
III. COMMUNITY RELATIONS HISTORY
Several fires were reported in the landfill during the 1970's. The
most recent fire burned for several years before it apparently burned
out in 1984. Air monitoring was conducted at the site in response to
citizen complaints of strong odors coming from the landfill. The results
obtained from the air monitoring showed the presence of organics, but
at non-hazardous levels. Investigations conducted by the Environmental
Protection Agency (EPA) led to the sites inclusion on the National
Priorities List in September 1984.
On July 25, 1984, the U.S. Environmental Protection Agency (EPA) issued
a news release announcing that funds had been awarded to the Oklahoma
State Department of Health (OSDH). That money was used to conduct
studies at the Compass Industries site.
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The OSDH held a public meeting at the Berryhill High School on August 20,
1984, to explain the project, answer questions, and take comments.
The completion of the studies was announced to the public via news
releases issued by the OSDH on July 16, 1987, and the EPA on July 22,
1987. The scheduling of the August 18, 1987, public meeting to discuss
the proposed remedy for the site was also announced.
An EPA prepared fact sheet which described alternative cleanup plans
along with the EPA preferred alternative was sent to the interested and
affected public on July 22, 1987. The fact sheet gave a brief site
history, described the process and alternatives and gave details about
the public comment period and public meeting.
Because of the increase in public interest the public meeting on August
18 was changed from the original public library location to the Berryhill
School auditorium so that enough seating was assured. The change of
location was announced in an EPA news release issued August 7, 1987.
Approximately 65 people attended the August 18, 1987, public meeting.
Community concerns centered around costs of the alternative remedies,
efficiency and public health.
Further details concerning Community relations are contained in
Appendix C.
IV. ALTERNATIVES EVALUATION
Evaluation Criteria
Section 121(b)(l)(A-G) of the Superfund Amendments and Reauthorization
Act contains the nine factors which EPA must consider in selecting a
remedy for a Superfund site. These are summarized below:
1. Consistency with Other Environmental Laws
In determining appropriate remedial actions at Superfund sites,
consideration must be given to the requirements of other Federal
and State environmental laws, in addition to CERCLA as amended
by SARA. Primary consideration is given to attaining applicable
or relevant and appropriate Federal and State public health and
environmental regulations and standards. Not all Federal and
State environmental laws and regulations are applicable to each
Superfund response action. The compliance of each remedial
alternative with all applicable and relevant environmental
laws is shown in Table 2.
2. Reduction of Toxicity. Mobility or Volume
The degree to which alternatives employ treatment that reduces
toxicity, mobility, or volume must also be assessed. Relevant
factors are:
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The treatment processes the remedies employ and materials
they will treat;
The amount of hazardous materials that will be destroyed
or treated;
t the degree of expected reduction in toxicity, mobility,
or volume;
The degree to which the treatment is irreversible;
0 The residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bioaccumulation of such hazardous substances
and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed
considering appropriate factors among the following:
t Magnitude of reduction of existing risks;
Short-term risks that might be posed to the community,
workers, or the environment during implementation of an
alternative including potential threats to human health and
the environment associated with excavation, transportation,
and redisposal or containment;
Time until fuVl protection is achieved.
4. Long-term Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness and
permanence they afford along with the degree of certainty that
the remedy will prove successful. Factors considered are:
Magnitude of residual risks in terms of amounts and concen-
trations of waste remaining following implementation of a
remedial action, considering the persistence, toxicity,
mobility, and propensity for bioaccumulation of such hazardous
substances and their constituents;
Type and degree of long-term management required, including
monitoring and operation and maintenance;
Potential for exposure of human and environmental receptors
to remaining waste considering the potential threat to human
health and the environment associated with excavation,
transportation, redisposal, or containment;
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10
t Long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals;
Potential need for replacement of the remedy.
5. Implementability
The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:
Degree of difficulty associated with constructing the
technology;
Expected operational reliability of the technologies;
Need to coordinate with and obtain necessary approvals and
permits (e.g., NPDES, Dredge and Fill Permits for off-site
actions) from other offices and agencies;
Availability of necessary equipment and specialists;
Available capacity and location of needed treatment,
storage, and disposal services.
6. Cost
The types of costs that should be assessed include the
following:
Capital cost;
Operation and maintenance costs;
t Net present value of capital and 0 & M costs;
Potential future remedial action costs.
7. Community Acceptance
This assessment examines:
Components of the alternatives that the community supports;
Features of the alternatives about which the community has
reservations;
Elements of the alternatives which the community strongly
opposes.
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11
8. State Acceptance
Evaluation factors Include assessments of:
Components of the alternatives the State supports;
t Features of the alternatives about which the State has
reservations;
Elements of the alternatives under consideration that the
State strongly opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against individual
evaluation criteria, the alternatives are assessed from the
standpoint of whether they provide adequate protection of human
health and the environment considering the multiple criteria.
EPA is also directed by SARA to give preference to remedial
actions that utilize treatment to remove contaminants from the
environment. Offsite transport and disposal without treatment
is the least preferred option where practicable treatment
technologies are available.
Description of Alternatives
In conformance with the National Contingency Plan, an initial set of
remedial approaches were screened to determine whether they might be
appropriate for this site. (See the Feasibility Study for details of
this evaluation). From these possible remedies, six alternatives were
chosen for more detailed evaluation and comparison with the remedy
selection criteria outlined above. Each is summarized below:
ALTERNATIVE 1. NO-ACTION - This remedy, consists primarily of
restricting public access to the contaminated areas and monitoring
the site. The area will be fenced and warning signs will be
installed. Site monitoring will involve periodic air and groundwater
sampling and analysis. The estimated cost to implement the no
action alternative is $672,000.
Four of the remedial action alternatives Include a cap which meets RCRA
specifications. The RCRA specification cap will isolate the contaminated
source material from potential public and wildlife contact and will
significantly reduce the infiltration of precipitation through the
landfi-lled area. Surface water diversion technologies will also be
implemented to reduce flow over the surface and to reduce the potential
for infiltration. The cap will be graded to encourage site run-off and
simultaneously prevent erosion of the soil and vegetative cover. The
cap design includes gas collection and atmospheric venting, which will
be monitored up-gradient and down-gradient of the site in both the
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12
shallow and deep aquifers. Groundwater that emerges from the downgradlent
hillside to become surface water will also be monitored. Fences and
signs will be placed along the perimeter of the site to protect the cap
from disturbances.
ALTERNATIVE 2. CAP AND ON-SITE GROUNDWATER TREATMENT - This
alternative, Is comprised of site grading, cap placement,
diversion of surface water, groundwater collection and treatment,
and air emissions monitoring. The grading, cap design, gas venting,
and surface water diversion technologies were presented In the
previous paragraph. Groundwater will be collected prior to Its
emergence from the down-gradient hillside. The contaminated ground-
water will be collected, combined, and treated to State and Federal
standards prior to discharge to the Arkansas River. A filtration
unit will be specified such that effluent solids levels meet
National Pollution Discharge Elimination System (NPDES) requirements.
The precipitated metals and other solids from the separation unit
will be dewatered. For purposes of cost estimation it is anticipated
that the solids will be processed in a mechanical filter unit and
disposed as a hazardous solid waste material in a permitted, off-site
landfill 1f the material meets the criteria for land disposal.
The estimated cost of the cap and on-site groundwater treatment
alternative is $12 million.
ALTERNATIVE 3. CAP AND OFF-SITE GROUNDWATER TREATMENT ALTERNATIVE -
This remedy is similar to Alternative 2 except that the groundwater
will be collected and transported to an off-site treatment facility.
It is anticipated that the groundwater will be placed into a 10,000-
gallon holding tank. Groundwater will be routinely transported
for off-site treatment and disposal. The estimated cost of the
cap and off-site groundwater treatment alternative is $13 million.
ALTERNATIVE 4. FULL ON-SITE THERMAL DESTRUCTION ALTERNATIVE -
Involves removing all landfilled material and destroying it in
an on-site thermal destruction unit for destruction or removal of
99.99 percent of the organics. Materials handling will include
hauling hazardous waste materials, contaminated soils and sediments,
and the non-hazardous landfill material to the on-site thermal
treatment unit. Upon thermal destruction, the released volatile
gases will be collected and burned at a higher temperature and the
stack gases will be scrubbed and treated prior to atmospheric
release. The residual ash will be tested, solidified if necessary,
and disposed of in an appropriate manner dependent upon performance
of the toxidty characteristic leaching procedure (TCLP) and other
relevant tests. The groundwater will be collected and treated
similar to Alternative 2. Performance specifications for treatment
would be developed during remedial design from information obtained
during RI and would be the basis for the level of thermal destruction.
The performance specifications would address pretreatment requirements,
materials handling, testing, and disposal options. The estimated
cost of the full on-site incineration alternative is $339 million.
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13
ALTERNATIVE 5, PARTIAL ON-SITE THERMAL DESTRUCTION AND CAP -
Consists of excavating and thermally destroying the source areas
of contaminated material, capping the entire site, installing
barriers, and collecting and treating the contaminated groundwater.
Residual ash will be solidified if necessary, and disposed of in
an on-site landfill which meets RCRA specifications or in an appro-
priate manner following performance of the TCLP and other relevant
tests. The estimated cost of the partial on-site thermal destruction
alternative 1s $17 million.
ALTERNATIVE 6. PARTIAL OFF-SITE THERMAL DESTRUCTION AND CAP - This
alternative is similar to Alternative 5 except treatment of
contaminated wastes and groundwater will be performed off-site on
a service basis. The hazardous material will be removed and trans-
ported to the off-site thermal treatment unit, sized, and destroyed.
Residual ash will be solidified, if necessary, and disposed of in
an off-site landfill which meets RCRA specifications or in an
appropriate manner following performance of the TCLP and other
relevant tests. The estimated cost of the partial off-site thermal
destruction alternative 1s $45 million.
Evaluation of Alternatives
The degree that the six remedial alternatives meet the nine selection
criteria is contained in Table 3. The following values were assigned
to compare remedial selection criteria:
++ Alternative would greatly exceed a selection criterion when
compared to other alternatives.
+ Alternative would exceed a criterion in comparison to other
alternatives.
0 Alternative can be designed to meet the selection criterion.
- Special efforts will be necessary in the design of the remedy
to meet the selection criterion.
In comparison to other remedies, these alternatives would present
most difficulty 1n achieving a selection criterion.
The rationale for the ratings assigned in this table 1s as follows:
1. COMPLIES WITH ARARs (i.e., meets or exceeds applicable or relevant
and appropriate Federal and State requirements)
Incineration was rated the highest for this criterion (++) because in
addition to exceeding all environmental rules, this alternative most
effectively meets the preference in SARA for destruction of
contaminants. All other alternatives, except for the no action
alternative, received a rating of "+" because they all can be designed
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14
to exceed applicable standards. The no action remedy was rated "--"
because it does not meet the intent of the RCRA and Superfund requirements
for remediation of a hazardous waste site. The National Contingency
Plan provisions to respond to a threat of release are also violated
by this remedy.
2. REDUCES HOB.. TOX.. VOL. (i.e., Reduces the Mobility, Toxicity, or
Volume of Uaste)
a. No Action was rated "--" because it does nothing to reduce any of
these parameters.
b. Cap and On-site Groundwater Treatment and Cap and Off-site
Groundwater Treatment (Alternatives 2 and 3) - Both of these
alternatives were judged to effectively reduce the mobility of
contaminants. The groundwater treatment serves to reduce the
volume and toxicity of wastes on site to some degree and were
therefore rated "0".
c. Full On-site Thermal Destruction was rated "++" for each
parameter because this process would destroy the organic
compounds in the waste.
d. Partial On-site Thermal Destruction. Cap, and Groundwater
Treatment and Partial Off-site Thermal Destruction. Cap, and
Groundwater Treatment (Alternatives 5 and 6) - Because these two
remedies would reduce the mobility of wastes only slightly
better than Alternatives 2 and 3, they were assessed to be
essentially equivalent and were rated "+". The partial
destruction of wastes does result in reductions in toxicity
(meriting a singl-e +) and a small reduction in volume (a rating
of 0) when compared to the simple cap and groundwater treatment
remedies.
3. SHORT TERM EFFECTIVENESS
The simple capping remedies (alternatives 2 and 3) were judged
capable of being designed to present essentially no risks to workers
or residents. The on-site thermal treatment options were assigned a
single "-" because these risks can be prevented but would require
attention in the design. The added risks of transporting untreated
waste long distances resulted in off-site thermal treatment receiving
a "" rating. Doing nothing leaves contaminated seeps and waste
exposed to the public, thus no action rated "".
4. LONG TERM EFFECTIVENESS
All alternatives, except no action, will successfully reduce long
term risks to human health and the environment. Because of the
added assurance from the destruction of the organic waste, the full
incineration was rated "++".
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15
5. IMPLEMENTABILITY
Onsite Incineration remedies (alternatives 4 and 5) will require
relatively more attention during design than other remedies to
ensure implementability and were therefore rated lower ("-") than
the other alternatives.
6. COST
Estimated costs for each alternative are summarized in Table 4.
Included in this table are total capital and implementation costs,
annual operation and maintenance costs, total present worth, and
replacement costs. Replacement costs were included to evaluate the
cost of remedial action if the alternative were to fail. A replacement
cost of $5 million was assessed for the cap and on-site groundwater
treatment alternative and the cap and off-site groundwater treatment
alternative. This replacement cost is an estimate of replacement of
the cap.
The no action alternative had the lowest present worth and operation
and maintenance costs. The cap and on-site groundwater treatment
and the cap and off-site groundwater treatment alternatives were the
next least expensive, with costs of $12 million to $13 million.
Most of the added costs for the remedy involving off-site groundwater
treatment are due to added transportation expenses. The partial on-
site and partial off-site thermal treatment remedies have a present
worth of $17 million and $45 million respectively. The increased
cost of the partial off-site thermal destruction, cap, and groundwater
treatment alternatives is due to transportation expenses and the
higher prices vendors charge at permitted off-site thermal treatment
facilities. The full on-site thermal destruction and groundwater
treatment alternative has an estimated present worth of $339 million.
This alternatives excessive cost over the partial thermal treatment
remedies is due to the increased volume of waste to be treated.
Only 2 percent of the waste will be treated with the partial thermal
treatment remedies.
7. COMMUNITY ACCEPTANCE
At the public meeting on August 18, 1987, the public had several
comments and concerns pertaining to all of the remedies. Questions
ranged from the damage the remedies will cause to the environment to
the time required for cleanup of the site. The no action alternative
was left blank because it was not discussed by the public. The
remedies involving a cap and groundwater treatment were rated M+"
because the public was in favor of this action over thermal treatment
of the waste. A rating of "-" was given to the alternatives involving
thermal destruction because of the public concern that the thermal
treatment unit would create hazardous emissions and increase the
potential for exposure.
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16
8. STATE ACCEPTANCE
A rating of "0" was given to the cap and on-site groundwater treatment
remedy as proposed in the Feasibility Study. The State (i.e., the
Oklahoma State Department of Health) has concurred with the capping
portion of this remedy. The final decision for this site defers
treatment of groundwater. A rating of "-" was given to all other
alternatives because the State did not support any of the other
proposed remedies.
9. Overall Protection of Human Health and the Environment
MJ.J.U
»
Full on-site thermal destruction received the highest rate of
because it results in elimination of the organic contaminants. The
thermal treatment unit would be designed to meet RCRA standards.
The possibility exists that noxious odors will be given off during
the treatment process, but a contingency plan will be developed to
address this problem. Destruction of 99.99% of the organic
contamination will reduce the potential for human exposure.
The remaining alternatives, except for the no action alternative,
were rated "+". This rating is due to the health threat posed by
untreated waste remaining on-site. The no action alternative
received a rating of "--" for the same reason. This remedy provides
no reduction in exposure pathways.
V. PROPOSED REMEDY; RCRA CAP
Rationale
Considering the current and potential site hazards, and also taking
into account the unique hydrology of the area, the recommended remedy
is a RCRA cap. This alternative consists of site grading, cap placement,
diversion of surface water, and air emissions monitoring. The site cap
will be required to meet RCRA specifications. Groundwater will be
treated at a later date if found to be necessary. This alternative
will also require installation of security fences and signs to restrict
access to the site.
The site will be monitored for a period of at least 30 years (post-
closure time period stipulated under RCRA) to ensure that no significant
contaminant concentrations migrate from the site. If however, future
migration does occur appropriate remedial actions will be taken.
This alternative is protective and cost-effective, attains applicable or
relevant and appropriate Federal and State standards, and utilizes
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17
permanent solutions and treatment technologies to the maximum extent
practicable. The reasons for elimination of the other remedies are as
follows:
Alternative No. 1; No-action; this alternative is not protective of
public health and the environment. It does not meet
the intent of RCRA or SARA.
Alternative No. 3; Cap and off-site groundwater treatment; this
alternative is the same as alternative 2 except that
it entails off-site groundwater treatment. This
remedy meets the requirements listed in RCRA, however
it is relatively more costly. The potential for
human exposure would be increased due to off-site
transport of contaminants.
Alternative No. 4; Full on-site thermal destruction; complies with RCRA
regulations and also meets many of the preferences
listed in SARA. However, this remedy is not cost-
effective ($339 million vs. $12 million).
Alternative 2 provides a safe solution to the hazardous
waste problem which allows that the waste be left
on-site. It also takes advantage of the site's unique
hydrology and a RCRA cap to halt migration and further
contamination of the groundwater. For this reason,
it can be assumed that alternative 2 is protective
to human health and the environment.
Alternative No. 5; Partial on-site thermal destruction and cap; this
alternative is also not cost effective ($17 million
vs $12 million). Under this proposal only one
percent or so of wastes would be destroyed yielding
negligible environmental benefits. As just stated,
the increase in cost does not justify the negligable
increase in protection to human health and the
environment.
Alternative No. 6; Partial off-site thermal destruction and cap; this
alternative meets the requirements of RCRA and SARA.
The potential for human exposure would be increased
due to off-site transportation. The minor increase
in protection to human health and the environment
does not justify an increased cost of $45 million.
Consistency with the National Contingency Plan (NCP) and the Provisions
of the Superfund Amendments and Reauthorization Act of 1986 (SARTT
The proposed remedy provides adequate protection of public health,
welfare, and the environment. This alternative is also consistent with
the National Contingency Plan (NCP), in 40 CFR 300.68(h)(2)(iv) and
(vi) (Federal Register, 1985) which requires:
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18
(iv) An assessment of each alternative in terms of the extent to which
it is expected to effectively mitigate and minimize threats to and
provide adequate protection of public health, welfare and the
environment.
(vi) An analysis of any adverse environmental impacts, methods for
mitigating these impacts, and costs of mitigation.
Additionally, the long-term effectiveness factors cited in SARA Section
§121(b)(l) were addressed. These include:
A) The long-term uncertainties associated with land disposal;
B) The goals, objectives, and requirements of the Solid Waste Disposal
Act;
C) The persistence, toxicity, mobility, and propensity to bioaccumulate
of such hazardous substances and their constituents.
D) Short- and long-term potential for adverse health effects from human
exposure;
E) Long-term maintenance cost;
F) The potential for future remedial action costs if the remedial action
in question were to fail; and
G) The potential threat to human health and the environment associated
with excavation, transportation, and redisposal, or containment.
Operation and Maintenance (O&M)
Site operation and maintenance will include a groundwater and air
monitoring and analysis program, inspection of the surface vegetation,
and the periodic repair of the perimeter fence. Cap maintenance will
entail the inspection of the cap and the maintaining and replacing of
the passive gas filters associated with the gas collection and venting
system. The State of Oklahoma will have the responsibility for O&M for
a period of a least 30 years after completion of the remedial action.
Future Actions
No future remedial actions are anticipated. The selected remedial
action is considered permanent. If, however, significant unforeseen
off-site contamination occurs as a result of the site, appropriate
remedial measures will be taken. As stated under the O&M section, the
site will be monitored for a least 30 years to ensure the reliability
of the implemented remedial action.
SARA also states that if an alternative results in any hazardous
substances, pollutants, or contaminants remaining onsite, the remedy
will be reviewed at least every five years to assure that human health
and the environment are being protected.
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19
Remedial Action Schedule
Approve Remedial Action (sign ROD) September 1987
Complete Enforcement Negotiations January 1988
Obligate Funds to Begin Remedial Design January 1988
(assuming the PRPs do not take over)
Complete Design March 1989
Obligate Funds to Start Remedial Action March 1989
Complete Remediation September 1990
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APPENDIX A
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Table 1
COMPOUNDS HAVING HIGHEST CONCENTRATIONS IN
SAMPLES OF GROUNDWATER
Shallow Well
(ug/L)
Inorganic Compounds
zinc*
lead*
copper*
7497
3397
3162
Organic Compounds
2-methynaphthalene 98000
phenanthrene* 62000
bis(2-ethylhexyl)*
phthalate 46000
Deep Well
(ug/L)
Inorganic Compounds
barium 1450
zinc* 1128
chromium* 353
Organic Compounds
bis(2-ethylhexyl)
phthalate* 30
toluene* 6
di-n-butyl phthalate* 0.8
COMPOUNDS HAVING HIGHEST CONCENTRATIONS
IN SAMPLES OF WASTE
Trenches
(mg/kg)
Inorganic Compounds
zinc* 2132
chromium* 1639
lead* 1555
.
Organic Compounds
2 methylnaphthalene 5300
phenanthrene* 250
xylenes 190
Surface Waste
(mg/kg)
Inorganic Compounds
copper* 19930
zinc* 5450
lead* 2790
Organic Compounds
benzo (b)
fluoranthene* 1600
benzo (a)
anthracene* 1100
pyrene* 710
* Priority pollutants
NOTE: Units equivalent to parts per million.
Does not include methylene chloride, a suspected lab
contaminant. Tentatively identified compounds (e.g.,
hydrocarbons) not included.
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APPENDIX B
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Compass Industries Landfill Site
Tulsa, Oklahoma
Responsiveness Summary
This Community relations responsiveness summary is divided into two
sections:
Section I: Background on Community Involvement and Concerns. This
section provides a brief history of community interest and
concern raised during the remedial planning activities on
the Compass Industries Superfund site.
Section II: Summary of Major Comments Received during the Public
Comment Period and the EPA Responses to the Comments.
Both written and spoken comments are categorized by
topics. EPA responses to these relevant major topics are
also presented.
I. Background on Community Involvement
The Compass Industries Landfill site is located in a sparsely
populated area of west Tulsa, Oklahoma. The community of Berryhill
and the city of Sand Springs are within two miles of the site. An
elementary school lies within one-half mile and a major regional park
is immediately adjacent to the site.
Local residents and officials have long expressed concern regarding
open burning and other poor practices at the site. The smoke led
citizens and local officials to request studies to determine
potential hazards at the site. The State began extensive air and
water sampling in 1983. EPA also performed sampling and no immediate
health hazards were identified.
The Berryhill Citizens for a Cleaner Environment, organized by
residents reacting primarily to smoke from the site, pressed for
remedial action.
In May 1983 the site was evaluated as a possible candidate for
Inclusion on the National Priorities List under the Superfund law.
The Compass site was included on the list in August 1983.
The preliminary investigation work began at the site in October
1983. The underground fires stopped burning in October 1984.
On the afternoon of August 18, 1987, EPA staff members met with
Tulsa City Officials to brief them on the findings of the remedial
investigation and feasibility studies, to describe the various
remedial alternatives considered, and to describe EPA's preferred
remedy.
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Present were Major Dick Crawford; John Selph, Tulsa County Commissioner;
Kieth Francis representing Congressman Jim Inhofe; Sharon Keasler
representing Senator Don Nickles; Mike Wright and Jerry Cleveland
of the Tulsa City-County Health Department; R. Fenton Rood and
Dennis Hrebec of the Oklahoma State Department of Health; Patrick
Boulder, Houston Adams. Louis Van Landingham, Priscilla Harris and
Herb Van Fleet of the City of Tulsa; Jennifer Kreel and Susan Young
of INCOG; and William Cox and Kenneth Hill of the City of Sand
Springs.
Issues raised include costs of the various alternatives, efficiency
of the EPA preferred alternative and various technical questions.
At 7:00 pm on the evening of August 18, 1987, the public meeting
began in the Berryhill School Auditorium. Representatives of EPA
and OSDH made presentations,-listened, and responded to public
comments. Some 65 people attended.
II. Summary of Major Comments Received during the Public Comment Period
and the EPA Responses to the Comments
1. Comment; Will any drainage or erosion problems along Avery Drive
be caused by the remedial action at the Compass Industries site?
Response: No, Drainage and erosion issues will be addressed and
provided for in the design phase.
2. Comment; Can 32 acres be covered effectively by a synthetic liner?
Response; It is technically feasibility to cover 32 acres with a
liner. Sites as large as 100 acres have been covered effectively
with a synthetic liner. The engineering and implementation of
installing the liner will be addressed in the design phase.
t
3. Comment; Will the seeps going into the Arkansas River be treated?
Response: No, the seeps themselves will not be treated. The
groundwater on-site which generates the seeps may be treated in
the future if necessary.
4. Comment: What quality standards will the treated water be required
to meet?
Response; All State and Federal standards.
5. Comment; What volume of water will be treated?
Response: Treatment of groundwater is deferred pending an evaluation
of the effectiveness of the cap. The feasibility study estimates appro-
ximated a 263,000 gallon yield per year from the aquifers which discharge
off-site. These estimates, calculated over the 30-year operation and
maintenance period amount to a total of approximately 7,890,000 gallons.
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Considering the majority of contaminants are within the upper zone of
the aquifer system, actual volume and timeframe for treatment should be
considerably less.
6. Comment: If the landfill is capped, won't the water dry up
eventually?
Response: In theory, the water in the perched or contained water
bearing zone within the landfill area should dry up. Treatment of
the contaminated liquids, if found necessary, in the landfill area will
additionally reduce the potential for offsite migration of contaminants.
7. Comment: Will the groundwater have to be airstripped? Will the
resulting sludge be landfilled on-site?
Response: Air stripping is a potential treatment alternative,
however, a specific technology is not specified in the
Feasibility Study. If air stripping was selected sludges
could be landfilled on-site.
8. Comment: What protection will there be against air pollution?
Response: Construction of the cap remedy is not anticipated to generate
any uncontrollable adverse air emissions and will reduce the potential
for future emissions.
9. Comment: How can the land be used if the cap and groundwater
treatment remedy is implemented?
Response: Future land use considerations will be evaluated in the
upcoming design phase based on the needs of protection of the cap.
10. Comment; How far along is EPA with identifying PRPs?
Response: Approximately 20 PRPs have been identified.
11. Comment: What is EPA's timetable for implementing a remedy
at the site?
Response; Design, procurement of contractors and construction is
estimated to take approximately 3 years.
12. Comment: Why is there such a large difference in the the State
recommended $1.6 million cap remedy and the EPA $13 million cap
remedy.
Response; No basis for a $1.6 million cap remedy has been submitted
by the State. The construction cost estimates submitted as the
official public comments by the Oklahoma State Department of Health
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(OSDH) for a the cap without liner is represented as costing
$3,412,944. The States proposed cap design is similar to the EPA
RCRA cap design, less the synthetic liner. The estimated construction
costs of the EPA RCRA cap, with liner, is $4,256,000. The balance
of the $12 million cost estimate consists of groundwater collection
and treatment, contingency, implementation, and operation and main-
tenance costs. Therefore the difference in costs is only $843,056.
A more detailed cost comparison is provided on page 11.
13. Comment; A liner would produce toxic fumes if the underground
fires started again.
Response; By reducing oxygen within the landfill interior the
synthetic liner will reduce the potential for reoccurring underground
fires. The possibility of the liner catching fire is remote since
it is contained within a 5* layer of compacted earthen material.
14. Comment; More engineering should be conducted prior to the selection
of remedies.
Response; EPA disagrees with this viewpoint. Congress, through
SARA, has structured the Superfund program to. prevent the unnecessary
expenditure of funds. Detailed engineering information, necessary
for the design stage, is not needed to select a remedial concept.
15. Comment; The Compass Industries site should be considered an improperly
closed solid waste disposal facility and should be closed as required
in the Oklahoma Solid Waste Management Act.
Response; EPA disagrees. The Compass Industries site was permitted
to accept solid and hazardous wastes and was a major landfill in
the Tulsa area. Documents indicate in excess of 40,000 barrels of
refinery sludges and waste liquids were disposed of at the Compass
Industries site. In addition, analytical data gathered during the
Remedial Investigation verifies1the presence of hazardous waste on-site
as well as migrating off-site. Due to the presence of hazardous
waste and the current and potential migration of contaminants off-site
the closure of the site in accordance with Subtitle C of the Resource
Conservation and Recovery Act, which requires a cap with liner, is
relevant and appropriate.
16. Comment; The low levels of compounds migrating off=site from the
seeps establishes a carcinogenic risk factor of 10 (1 in 100,000).
Response; The EPA goal is to reduce carcinogenic risk to 10
(1 in 1,000,000) for groundwater.
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17. Comment: The levels of compounds In the seeps do not cause a
significant increase of contaminants in the surface water of the
Arkansas River.
Response: Levels of contaminants in the Arkansas river have no
bearing on the authority of EPA to respond to the release or threat
of release of contaminants from the Compass Industries site. The
potential exists for direct contact with and ingestion of the seeps
themselves.
18. Comment; A cap without a liner can meet all applicable or relevant
and appropriate requirements.
Response; EPA agrees. However, if technically feasible a cap with
a liner has additional technical advantages and provides greater
protection of public health and the environment. A liner would be
less permeable and would further reduce the infiltration of surface
water. The long term advantage to the liner is that less water
would be generated from the seeps.
19. Comment; Acute and chronic bioassays or multi series bioassays
should have been conducted as well as tests to determine bioaccumilation
and biconcentration of toxics at the Compass Industries site.
Response: EPA disagrees. EPA typically relies on historical toxico-
logical information for evaluating contaminant levels at Superfund
sites. The response authority under CERCLA as amended by SARA
extends beyond current effects from a site to include potential
releases (and effects) of contamination therefore biological studies
although informative, are not required for selecting a remedy.
20. Comment; No Endangerment Assessment on the Compass Industries
site has been available for review and no Health Assessment has
been accomplished for the Compass Industries site. Therefore no
balancing of any such risks against the costs of the remedies is
possible.
Response: EPA disagrees. The information developed in the
Endangerment Assessment was in fact incorporated and utilized
in the Feasibility Study and available for public comment,
although not under separate cover. Documents on which the
Record of Decision is based are included in the Administrative
Record which is available for public review prior to the
signing of the Record of Decision. A Health Assessment is not
required prior to the signing of a Record of Decision. Adequate
data has been gathered with regards to potential health impacts
on which to make a selection of a remedy. The Agency for Toxic
Substances and Disease Registry (ATSDR) concurs with the EPA
determination of the need to respond to the current and potential
release of contaminants from the site. ATSDR is currently eval-
uating the information on the Compass Industries site and will
provide a Health Assessment which can be utilized during the
upcoming design phase.
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21. Comment: What long term impacts (20 to 30 years) does the site
pose?
Response: The potential for future fires and continued off-site
migration of contaminants pose adverse human health and environmental
impacts. Other impacts which the site may pose cannot be effectively
predicted. A RCRA cap and groundwater treatment would mitigate
these problems as well as most of the unseen, long term problems.
22. Comment; Is there an approved Federal and/or State hazardous
waste dump in the State of Oklahoma?
Response: No, at this time there are no approved Federal and/or
State hazardous waste disposal sites in Oklahoma. The Lone
Mountain site near Waynoka, Oklahoma is not in compliance with
its permitting requirements. This is not to say that when
remedial action begins at a site there will not be a Federal
and/or State approved disposal facility in the State of Oklahoma.
23. Comment: Is Superfund a congressional appropriation? Does it
have a 12 month limitation on it or is it continuous with an
option?
Response: Superfund under SARA is a congressional appropriation
which contains $8.5 billion for a 5 year period. This 5 year
period began in 1986.
24. Comment; How much of the $62 million in Superfund monies that has been
spent by EPA Region VI went for actual clean ups as opposed to studies?
Response: Since the program began, over $250 million has been obligated
within the Region VI jurisdiction for Superfund evaluations and cleanups
when the commitments by responsible parties are added to the dollars
used from the fund. Of this sum, $200 million is for the design and
construction of remedies however this figure cannot be compared to the
remaining $50 million. The Region has found that, in many instances,
responsible parties do not commit to performing site cleanups until
EPA's evaluations are completed and a decision regarding site clean up
approach is made. In addition, about half of the Regions Superfund
sites are still under study. For these two reasons a simple ratio of
the amount of monies spent on cleanups versus studies is misleading and
inaccurate.
25. Comment; An adequate health risk assessment of the existing health
risks at the site and determination of the health risks of the
remedial alternatives has not been conducted.
Response: A qualitative assessment of the potential public
health threats in the absence of remedial action was conducted.
This was accomplished in the Compass Industries Landfill Endangerment
Assessment dated July 10, 1987, and amended August 10, 1987, under the
Cooperative Agreement with OSDH.
-------
Response; EPA disagrees. Adequate data has been gathered and the
evaluations have been conducted to satisfy the above mentioned guidance
documents and statutory requirements on which to base a decision.
27. Comment; "The Feasibility Study is fundamentally flawed because
it fails to consider lower cost remedial operations that provide
protection similar to more expensive options being considered,
contrary to SARA and F.S. guidance requirements."
Response; EPA disagrees with this comment. Numerous alternatives
with a wide range of costs were evaluated in the Feasibilty
Study. Most of these alternatives were eliminated because they
could not meet the intent of SARA and the NCP and were not cost
effective. EPA has selected the most cost-effective and technically
applicable alternative.
28. Comment; "The Feasibility Study is fundamentally flawed because
it fails to properly evalute the risk to public health."
Response; EPA disagrees. An endangerment assessment was conducted and
incorporated into the ROD. EPA feels that this endangerment assessment
properly evaluates the risk to public health and adequately supports
the proposed remedial action.
29. Comment; "The Feasibility Study fails to properly analyze and
apply applicable or relevant and appropriate requirements (ARARs)."
Response; EPA disagrees. The applicable or relevant and appropriate
requirements (ARARs) are listed in Table 7-3 of the Feasibility Study.
These ARARs were analyzed and used to evaluate the various alternatives
studied.
30. Comment; "Sun was deprived of a reasonable opportunity to
participate in the establishment of an administrative record."
Response; EPA believes that Sun was given sufficient time to evaluate
the RI/FS and to participate in the establishment of an administrative
record. In addition, Sun has been aware of the site activities since
at least August 1984. At this time a letter was sent to Sun requesting
information on the site. This letter requested information on waste
generation, transport, and disposal. Public notice of the upcoming
comment period was issued July 22, 1987. Four weeks were allowed for
the public comment period. The comment period began on August 5, 1987,
and was orginally scheduled to close on August 26. An extention to the
public comment period changed the closing date to September 2.
31. Comment; "Failure of the Remedial Investigation to conform to EPA's
guidance on Remedial Investigation under CERCLA procedures for data
validity and sufficiency."
Response; EPA disagrees. The Remedial Investigation guidance was
adequately followed and a comprehensive study was conducted.
-------
8
32. Comment: "Quality assurance and quality control measures at the
laboratory are not documented."
Response: EPA disagrees. Quality assurance and quality control
procedures were adequately followed and are documented in a QA/QC plan
approved by EPA in April 1984. Actual QA/QC results are included in
the Administrative Record.
33. Comment; "Data used in the RI/FS is questionable."
Response: EPA disagrees. Adequate quality data was compiled in which
to conduct a thorough Feasibility Study and to base a remedial action
decision. The quality of this data was assured through the use of a
QA/QC plan.
34. Comment: "EPA's basis (air route) for listing this site on the
NPL is not borne out by the RI/FS."
Response: Although air sampling showed minimal respiratory
hazard, analysis of on-site waste justifies need for a response/
remedial action. Analytical results of the on-site waste is documented
in the RI/FS.
35. Comment; "The Remedial Investigation did not conform to the
technical workplan submitted by Mathes on April 25, 1986." (Drilling
logs not submitted, etc.)
Response; EPA disagrees. Documentation for the drilling which took
place during the remedial investigation is contained in Appendices A-
E of the Remedial Investigation Report.
36. Comment: "Groundwater data from the lower aquifer is questionable
and may have been introduced by well drilling activity." (This is
assumed to refer to old abandoned petroleum wells existing onsite).
Response; The Remedial Investigation Report indicates that oil well
drilling in the vicinity of the site may have influenced contamination
of the lower aquifer. This was considered in the evaluation of
appropriate remedial actions.
37. Comment: "The quantity of samples is insufficient for a meaningful
site evaluation."
Response; This is incorrect. An adequate number of samples were
collected to properly evaluate the risks posed by the site and
to support the proposed action.
38. Comment; "The Feasibility Study does not address technical
feasibility or remedial options as required by SARA and EPA F.S.
Guidance.
-------
Response; This is incorrect. The technical feasibility of the remedial
options is covered in section 7.2 of the Feasibility Study. Other
references to the technical feasibility of the alternatives can be
found under the title of implementability.
39. Comment: "Cost estimates for remedial alternatives used in the
F.S. are imprecise, do not reflect likely actual costs of the
options and therefore do not allow for meaningful comparison of
costs as required by SARA and EPA's F.S. guidance."
Response: This is incorrect to the extent that the F.S. has adequately
evaluated the cost of the alternatives to enable the selection of the
most cost effective alternative. The intent of the FS cost estimates
1s to evaluate relative costs and not to give the level of cost expected
in a detailed design report. As indicated in the feasibility study,
the costs for the alternatives are based on cost estimates of -30% to
+50%.
40. Comment; "The quality of the background data as reported in the
remedial investigation is admittedly questionable."
Response: EPA disgrees. Due to the random disposal techniques used at
the site and varying hydrogeologic conditions, various contaminant
levels were detected at several different locations. Some background
samples do contain higher levels of some specific compounds compared to
other sampling locations. This merely indicates contamination levels
and compounds vary throughout the site.
41. Comment; "The quality of the data reported in the Remedial
Investigation on PCB contamination is admittedly questionable."
Response; EPA disagrees. The presence of PCBs is documented in two
separate sampling events and is viewed as being reliable data.
42. Comment; "The lack of chain of custody documentation is contrary
to EPA's requirements."
Response: An established chain of custody procedure was followed.
This information is in the Administrative Record.
43. Comment; "The RI and FS fail to analyze and rank compounds
present on-site for potential adverse health effects, as required
by EPA RI and FS guidance."
Response: EPA disagrees. Selected indicator compounds, chosen on
their potential for indicating adverse health effects, are indicated in
the summary of the endangerment assessment in the feasibility study.
44. Comment: "Neither the RI nor the FS addresses information gaps that
are necessary to identify and remediate any potential aquifer
cross contamination prior to selection and implementation of the
remedy."
-------
10
Response; This information is not considered necessary for implementing
the proposed remedy. Since the only use of the groundwater by the
surrounding residents is upgradient from the site, the need to remediate
potential aquifer cross contamination was not evaluated. (No down-
gradient groundwater users exists because the aquifers in question
discharge to the surface just north of the site.
45. Comment; "The RI/FS reports fail to follow the format prescribed
in EPA guidance."
Response; EPA disagrees. The RI/FS and endangerment assessment follow
the format prescribed in EPA guidance.
-------
It
COMPASS INDUSTRIES
OSDH vs EPA REMEDY COST
COST COMPONENT
Site Development
Fencing
Groundwater Monitoring
A1r Monitoring
Cap
Gas Collection &
Venting
OSDH
COST
3
"D" CAP
ESTIMATE
0
0
0
0
,412,944
0
EPA "C" CAP
COST ESTIMATE
150,000
47,700
153,000
6,500
4,256,000
36,000
COST
DIFFERENCE
843,056
Groundwater Collection
System
621,600
Mobilization, Bonds,
Insurance
Health & Safety
Contingency (Bid)
Contingency (Scope)
Engineering
Legal
Construction Management
0
0
0
341,294
0
273,035
263,540
368,956
790,620
1,054,160
500,000(A)
387,404
619,846
158,706
346,811
Total Capitol &
Implementation
4,027,273
9,255,526
Annual O&M (Includes
Groundwater Treatment)
272,830
Total Present Worth
4,027,273
11,827,271
7,799,988
(A) Includes Groundwater Collection & Treatment Design
-------
APPENDIX C
-------
'9?
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Agency for Toxic Substances
and Disease Registry
Atlanta GA 30333
1EMQRANPUM
:>A7E September 15, 1937
:RQM: Senior Regional Pcprasont stive
Regional Office for Health Response
A1SDR/ROHR-VI
FO: Paul SieminiskJ
Remedial Project Manager
ALONM Section (6H-SA)
DK.
ncy -for Toxic Substances and Disease Registry (ATSDR) has been
by the Environmental Protection Agency (EPA) to review and evaluate
i al Investigation/Feasibility Study/End&ngerment Assessment data thet
generated -from ths Compass Industries Super fund Site located in Tuisa,
Currently the ATSDP is reviewing these documents to provide EPA with a com-
prehensive Health Assessment fo>- this site.
Based on our review to date, the ATSDR, Regional Office -for Health Response in
consultation with staff at ATSDR-Headqu.arters is of the opinion that the Com-
pass Industry Super -fund Site does pose a current and potential public health
threat.
Initial indications are that ATSDR recommendations will be directed toward
unacceptable risks associated with direct public contact and/or unintentional
fires at this site.
Carl R. Hickam, R.S.
-------
APPENDIX D
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Compasg jnd.ufitries
Job Number: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/03/75
type Appeal from Decision of City Commission of
Tulsa, Okla.
Troye Kennon
Affiliation Atty. - Compass Industries, Inc.
Dist. Ct., Tulsa County, Okla.
Appeal of Tulsa City Commission ruling
5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
03/08/76
Memorandum
Dennis Bergstrom
Tulsa City/County Health Dept.
Health Dept. Files
March 5, 1976 inspection of land fill
1
Undated, covers inspections from 1/12/76 to
01/19/76
Dennis Bergstrom
Tulsa City/County Health Dept.
Health Dept. Files
Fires at Chandler Land Fill Jan. 12 through
Jan. 19, 1976
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/12/76
Memorandum
Dennis Bergstrom
Tulsa City/County Health Dept.
Health Dept. Files
Summary of Inspections 1/12/76 to 4/12/76
2
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:
Job Nunber:
Comas
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/27/76
Informational Letter
Gary Cox
Public Health Atty. for Tulsa City/Go. Health
Dept.
Doyle and Holmes Law Offices
Receiver for Gonpass industries
Informs receipient that Health Dept. seeks their
compliance with state law Re: land fill closure
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
06/15/82
Summary reports and worksheets
Unknown
Unknown
Computes Hazard Ranking System score
10
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/20/82
Inspection Report, U.S. E.P.A. Form T2070-3
(10/79)
David Anderson
U.S. E.P.A.
U.S. E.P.A. Files
Potential Hazardous Waste Site Inspection Report
14
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
11/05/82
Memorandum
Jinks Nartinr Jr.
Citizen
Jerry Cleveland
Tulsa City/County Health Dept.
Complaint about fumes and smoke
1
-------
ADMINISTRATIVE RBGDRDS INDEX
Job Name: CtmpasfS
Job Number:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
12/20/82
General Complaint Form
Martin Bousura
Citizen
Health Dept. Files
Tulsa City/Co. Health Dept.
Describes problems of Mr. Martin Bousura
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
12/21/82
Complaint Report
Darrell Boeder
Citizen
Health Dept. Files
Tulsa City/Co. Health Dept.
Complaints of a Mr. Darrell Boeder
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/03/83
Complaint Report
Martin Bousura
Citizen
Health Dept. Files
Tulsa City/Co. Health Dept.
Details, complaints of a Mr. Martin Bousum
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/03/83
Complaint Report
Thorunn M. Gilstrap
Citizen
Health Dept. Files
Tulsa City/Co. Health Dept.
Complaints of Mr. Thorunn M. Gilstrap
1
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Canpagg
Job Number:
0983
Document
Document Type
Originator
Originator - AffUiation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
01/14/83
Letter
Mark S. Ooleman
State Dept. of Health
Dr. Edgar Cleaver
Tulsa City/County Health Dept. (TCCflD)
TOCBD as plaintiff in any action brought by Tulsa
Co. Dist. Atty.
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/17/83
Resolution
Terry Young
Tulsa County Board of County Commissioners
Requests Dist. Atty. to initiate action abating
the public nuisance at Tulsa Refuse Dump No. 1
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/28/83
Petition filed in Tulsa County Dist. Ct.
Tulsa County Board of County Commissioners, Tulsa
City/County Health Dept., State of Okla.
Filed in Tulsa County Dist. Ct.
Requests the court hold hearings on
alleged violations
8
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
03/28/83
Memorandum
Gary S. McDonald
Solid Waste Division, Okla. State Dept. of Health
Health Dept. Files
Describes sampling conducted 3/23/83
2
-------
RECORDS INDEX
Job Name: Cantasq
Job Number:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
03/28/83
Memorandum
Joseph Dunagan
Industrial Waste Division, Okla. State Dept. of
Health (OSDH)
Richard Thompson
Solid Waste Division (OSDH)
Reconnaissance of land fill prior to 3/28/83
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
03/28/83
Air quality evaluation of land fill fire
Air Quality Staft, Tulsa City/County Health Dept.
TOCHD
Health Dept. Files
Summarizes monitoring activities from 10/26/82 to
1/28/83
28
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/26/83
Press Release
Eddie Lee
U.S. E.P.A.
Press release stating U.S. E.P.A. will conduct
further air quality tests
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
06/09/83
Record
Cynthia Bachunas
Unknown
Russell Hartley (U.S. E.P.A.) and Ken Raymond
(Okla. State Dept. Health)
Hazard Ranking System
13
-------
ADMINISTRATIVE RECORDS INDEX
Job Name* CPJTIFBSS,
Job Number:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
06/10/83
Section 3007 Request for Information
Dick Whittington
U.S. E.P.A.
Bill Jackson
Owner of Ocrapass Industries landfill
Possible receipt of hazardous waste
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/02/83
3007 Request for Information
Allyn M. Davis
U.S. E.P.A.
John Deatherage -
Standard Industries
Wastes received at Compass and on Standard
Industries' purchase of site
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/10/84
Letter
Russell Hartley
U.S. E.P.A.
Fenton Rood
Okla. State Dept. of Health
Compass Industries Workplan
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
03/01/84
Quality Assurance Project Plan
Okla. State Dept. of Health
Health Dept. Files
Quality Assurance Project Plan
114
-------
ADMINISTRATIVE RECORDS INDEX
Job Name* Ccrrvcags
Job Nunber: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/18/84
Memorandum
Paul Sieminski, Project Officer
U.S. E.P.A. Region (6AW-SP)
Pay Lozanor Coordinator
Office of Quality Assurance
QAPP-Gompass Cooperative Agreement
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
05/07/84
Letter
Paul Sieminski
U.S. E.P.A.
Fentcn Rood
Okla. State Dept. of Health
Approval of 3/1/84 version of Quality Assurance
Project Plan
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
06/15/84
Health and Safety Plan
David Wharton
Okla. State Dept. of Health
Health Dept. Files
Health and Safety Plan for Remedial Investigation
7
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/20/84
Minutes of Public Meeting
Okla. State Dept. of Health
Health Dept. Files
Minutes of public meeting held 8/20/84
3
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Canpasg
Job Number:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
11/28/84
Letter
John R. Totin
Ecolgy and Environment, Inc.
Ren Burns
Okla. state Dept. of Health
Describes monitoring well installation and
sampling
14
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/11/85
Letter of response
Dick Whittington, Regional Administrator Region
VI
U.S. E.P.A.
I.J. Ramsbottom, Environmental Clearance Officer
Dept. Housing & Urban Development
HUD's Draft Environmental Impact Statement
4
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
01/23/85
Letter
Mike Wright/Solid 6 Industrial Waste
Tulsa City/County Health Dept.
Ken Burns - Supertund Projects
Okla. State Dept. of Health
Steps to contact access to landfill
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
02/00/85
Preliminary Report
Okla. State Dept. of Health
State agency
For Okla. State Dept. of Health files
State agency
Preliminary Report - Compass Industries
9
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Compas^
Job Number: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
03/85
Magazine article, editor's pg., table of contents
Maria Welding, Patsy Varnell
Berryhill Citizens for Safe Environment
Oklahoma Sierran
Sierra Qub/Okla. Chp.
Historical overview of Compass Landfill
3-4/4
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/03/85
Newspaper article
Julie DelCour
Tulsa World Newspaper
Public
- Staft
Dismissal of $150 million Lawsuit
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/22/85
Letter
Ken Bums - Superfund Project Coordinator
Okla. State Dept. of Health
Thomas J. DiRito
Bellanan Community Development
Shenandoah Project - Sand Springs, Okla.
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
06/12/85
Sampling Plan
Okla. State Dept. of Health
State agency
For Dept. of Health files (Okla.)
State Agency
Grouncwater monitoring sampling plan
13
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Compass Industries
Job Number:
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
10/00/85
Planning - Study Reports
Okla. State Dept. of Health Waste Mgmt. Service
For Dept. of Health files (Olda.)
State agency (Okla.)
Health and Safety Plan - RI
33
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Undated, apparently March 1986
Trenching Sampling Plan
Okla. State Dept. of Health
Health Dept. Files
Plan for trenching and sampling
9
04/28/86
Technical Work Plan
Jn. Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
Plan Re: exploration services for RI
27
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
05/01/86
News release
Okla. State Dept. of Health
State agency
Public
Historical background Re: Compass landfill
2
-------
ADMINISTRATIVE RECORDS INDEX
Job Name* Compass
Job Number: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
05/13/86 - 05/31/86
Record
Jn. Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
Daily driller's record
13
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
05/16/86
Letter of Review
Douglas Kent
MDK Consultants
Thomas DiRito
Bellamah Community Development
Review of proposed monitoring plan
14
05/28/86
Letter
Thomas J. DiRito - Tulsa Mgr.
Bellaman Community Development
Hal Cantwell - Environmental Specialist
Okla. State Dept. of Health
Review of proposed monitoring plan
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Undated
Report
Unknown - probably U.S. E.P.A. (6)
U.S. E.P.A. Region VI
U.S. E.P.A. Region VI - Compass File
General overview of site
13
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Canpasfg
Job Number: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
14/01/87
Letter
Allyn M. Davis, Director
Hazardous Waste Mgtment Service/U.S. E.P.A.
Mark Coleman, Deputy Gonmissioner
Okla. State Dept. of Health
Correspondence Re: KL/FS
I
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/03/87
Letter; sampling plan
Hal Cantwell, ES
Superf und Program/Solid Waste Division, Okla.
State Dept. of Health
Paul Sieminski (6H-SS)
U.S. E.P.A.
Industries Dioxin Testing
6
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
04/15/87
Memorandum
R. Fenton Rood, Director
Solid Waste Division
Hark Coleman, Deputy Commissioner
Environmental Health Services
March Progress Report
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
05/13/87
Cover letter, Action Specific Requirements
Hal Cantwell/Environmental Specialist
U.S. E.P.A.
Carl Edlund, Chief
U.S. E.P.A.
Action-specific State of Okla. ARARs
5
-------
Job Name: Qamas5?
Job Ntmber:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
05/21/87
Cover letter, Analytical Results
Dale Markley, Sr.r Hydrogeologist
Jn. Mathes & Assoc., Inc.
Hal Cantwell
Okla. State Dept. of Health
Analytical Results - Dioxin & Furans/Rl/frS
19
Document Date
Document lype
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
07/10/87
Assessment
Dr. Raymond Harlison - Dept. Medical Science
Univ. of Ark.
Jn. Mathes & Assoc., Inc.
Endangermenc Assessment
111
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
07/13/87
Report by engineering firm for Compass
John Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
State agency
PJ Report for Compass Industries/Vol. I
156 - 2 pgs. "References"
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
07/13/87
Appendix -R/I Report/Compass Industries (A-E)
Jn. Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
State agency
Appendix for Engineering logs Vol II
99
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ADMINISTRATIVE RECORDS INDEX
Job Name: pampass Industries
Job Number: 0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
07/13/87
Appendix R/I Report/Compass Industries (F)
Jn. Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
State Agency
Appendix for Analytical Data Vol III
226
07/13/87
Appendix - R/I Report (F continued)
Jn. Mathes & Assoc., Inc.
Engineering firm
Okla. State Dept. of Health
State Agency
Appendix for Analytical Data Vol. IV
22b
07/13/87
Report
John Mathes 6 Assoc., Inc.
Ok. State Dept. Health
Feasibility Study Report
121
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/10/87
Assessment
John Mathes & Assoc., Inc.
Ok. State Dept. Health
Endangerment Assessment
116
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ADMINISTRATIVE RECORDS INDEX
Job Name: Ccn^pass
Job Number:
0983
Document Date
Document
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
08/10/87
Addendum
Jn. Mathes & Assoc., Inc.
OK State Dept. Health
Addendum - Endangerroent Assess. Exhibits A-F
140
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/18/87
Letter
Jerry Cleveland, Asst. Director
Tulsa City/Go. Health Dept.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Response to Health Dept.' s recommend.
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/18/87
Memorandum
Betty Jean Reece, Project Officer
U.S. E.P.A. (6) 6H-SS
U.S. E.P.A. (6) Compass File
Meeting 08/18/87
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/20/87
Letter
Wn. R. Cox - Dir. Utility Plants/Opera.
City of Sand Springs
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comments Re: Compass Site
3
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ADMINISTRATIVE RECORDS INDEX
Job Name: Ccrnrasg
Job Nunber:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
08/21/87
Letter
David Page - Atty.
Boone, Smith, Davis & Burst - Law Office
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Extension of public comment period
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/25/87
Letter
Hal D. Cantwell, Environ. Special.
OK State Dept. Health
Carl Edlund, Chief (6R-S)
SuperFund Program - U.S. E.P.A. (6)
Extension - Public Comment Period
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/27/87
Letter
R. Fenton Rood, Dir.
OR State Dept. Health
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Public comments Re: selection of remedy
5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/27/87
Letter
Evelyn Reid
Citizen - Tulsa, OR
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Response to public meeting
2
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ADMINISTRATIVE RECORDS INDEX
Job Name: panpasf?
Job Number:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/28/87
Letter
Shawn Thorton
Citizen - Bartlesviller OK
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Response to public meeting
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
08/31/87
Letter
John Selph
Board of Co. Commissioners
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
State Health Dept.'s proposed remedy
2
08/31/87
Letter
Hark Coleman, Deputy Commissioner
OK Dept. of Health
Root. Layton, Reg. Admin.
U.S. E.P.A. Region VI
RA alternatives
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/01/87
Letter/attach.
R. Fenton Rood, Director
OK State Dept. Health
Carl Edlund, Chief (6H-S)
U.S. E.P.A. Region VI
Public comments/sunnary table
2
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ADMINISTRATIVE RBOORDR TNT**
Job Name: Compagg
Job Nunber:
0983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
09/01/87
Letter
Charles W. Shipley - Atty.
Law Firm - Shipley & Schneider
Carl Edlund, Chief
U.S. E.P.A. (6) Super Fund Programs
Response to ROD
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/02/87
Letter/attachment
Edward A. Kurent - Atty.
Pepper, Hamilton & Scheetz - Law firm
Carl Edlund, Chief
U.S. E.P.A. (Region VI - 6H-S)
Comments on RI/FS Reports
41
09/10/87
Letter
Jerry Lasker, Exec. Director
Indian Nations Council of Gcvts.
Robt. Layton - Regional Admin.
U.S. E.P.A. Region VI
Garments Re: ROD
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
09/28/87
Letter/attachment
Edward A. Kurent - Atty.
Law firm - Fetter, Hamilton & Scheetz
Carl Edlund/Julie Bozich
U.S. E.P.A. Region VI
Comments Re: RI/FS; unindexed AR docu.
73
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ADMINISTRATIVE RECORDS INDEX
Job Name: Caqpass^ TndUFft rjes
Job Number: 0983
Document Date 09/29/87
Document Type Letter
Originator Mark S. Goleman, Depty. Coraniss.
Originator - Affiliation OR State Dept. of Health
Recipient Allyn Davis, Director
Recipient - Affiliation D.S. E.P.A. Region VI
Description Acceptance of BCD
Number of Pages 1
Document Number Sequence
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APPENDIX E
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Jewi K. U*ttt M.O.
OKLAHOMA STATE
MMMTMffNT Of HEALTH
A OX /.MO
BMRO VfcCUtaugn I DO
jivrciLMeny
RO. BOX MSI1
1000 N J. TENTH
OKLAHOMA CTTY, OK 7I1t2
September 29, 19S7
AJJyn M. Davis, Director
Hazardous Waste Management Division
Environmentai Protection Agency
Region VI
Dalias, Texas 73202-2733
PROTECTION
AGENCY
OALIAS, TEXAS
Dear Dr. Davis:
The Oklahoma State Department of Health (OSDH) has reviewed the Declaration
for the Record of Decision for the Compass Industries site, Tuisa, Oklahoma. The
OSDH does concur with the selected remedy detailed in the Declaration. The
OSDH looks toward to continuing to work together with the EPA towards a solution
to the problems at the Compass Industries site.
Sincerely,
Mark S. Coleman, Deputy Commissioner
for Environmental Health Services
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