United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
Superfund
Record of Decision:
Sand Springs, OK
EPA/ROD/R06-88/033
June 1988
PROTECTION
AGENCY
DALLAS, TEXAS
UBRMW
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30272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/033
'4. Till* and Subtitle
SUPERFUND RECORD OF DECISION
Sjjpd Springs, OK
pnd Remedial Action
3. Recipient*« Accession No.
5. Repo
8. Performing Organization Rept. No
9. Performing Organization Name and Address
10. Proiect/Task/Work Unit No.
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 235-acre Sand Springs Petrochemical site, located in Sand Springs, Oklahoma, is a
former refinery and solvent recycling facility that operated between 1900 and the early
1970s. The site is located immediately west of Tulsa along the northern bank of the
Arkansas .River and consists of unlined acid sludge pits, a surface impoundment, solvent
and waste oil lagoons, and several subsurface sludge pits and spray ponds. During plant
rations, waste products were disposed of in the unlined pits, surface impoundments
spray ponds. Primary contaminants of concern affecting the soil, shallow ground
er, and sediments were organic solvents and heavy metals. In September, 1987, a
source control Record of Decision was signed to control and destroy the major sources of
contamination. This second Record of Decision deals with the remainder of the site,
primarily shallow ground water and minimally contaminated soil.
The selected remedial action for the remainder of the Sand Springs site is no further
action. Based upon the findings of the RI/FS, the Endangerment Assessment for the
operable unit concluded that no significant risk to public health or the environment
exists. Ground water and the Arkansas River water will be monitored for 30 years after
completion of the source control remedial action, and warning signs and fences will be
erected as part of this no action alternative. Estimated capital cost of the remedy is
$9,300 with annual O&M costs of $45,600.
17. Document Analysis a. Descriptors
Record of Decision
Sand Springs, OK
Second Remedial Action
Contaminated Media: gw,
Key Contaminants: metals, VOCs
b. rdentifien/Open-Ended Terms
soil
18.
SATI Field/Group
>ility Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
43
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MAIN SITE (GROUNDWATER) OPERABLE UNIT
SAND SPRINGS PETROCHEMICAL COMPLEX
SAND SPRINGS, TULSA COUNTY, OKLAHOMA
JUNE 1988
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Sands Springs Petrochemical Complex, Tulsa County, Oklahoma. Main Site
(groundwater) Operable Unit.
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for the
Main Site (groundwater) Operable Unit of this site developed in accordance
with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthori-
zation Act of 1986 (SARA), and to the extent practicable, the National
Contingency Plan (40 CFR Part 300).
The State of Oklahoma concurs with the remedy described in this Record
of Decision. (Appendix D)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Sand
Springs Petrochemical Complex Superfund Site [index attached]. The
attached index identifies the items which comprise the administrative
record upon which the selection of. this remedial action is based.
Based upon the findings in the Remedial Investigation and Feasibility
Study for this operable unit, the Endangerment assessment concluded
that there are no public health threats from the minimally contaminated
soil, groundwater or the Arkansas River. The groundwater and the
Arkansas River are not sources of drinking water and sampling of the
Arkansas River detected no contamination. The attached correspondence
(Appendix B) from the Agency for Toxic Substances and Disease Registry
(ATSDR) concurs with this conclusion.
Description of Selected Remedial Action
o The Environmental Protection Agency has selected No Action with long
term monitoring, following completion of the source control remedial
action, as described in the September 1987 Source Control Record of
Decision (ROD). Included in this remedial action is the placement of
appropriate warning signs, restricting access and collecting and
analyzing groundwater and Arkansas River samples for a period of at
least 30 years.
o Potential off-site and/or active facilities which appear to be
contributing to groundwater contamination in the area of the site
will be further investigated in consultation with the Oklahoma State
Department of Health.
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o If, after the source control remedial action, as described in the
September 1987 Source Control Record of Decision, monitoring reveals
that the site releases contamination such that groundwater or the
Arkansas River is adversely impacted, then further action will be
considered. If no trend toward adverse impacts is detected, deletion
of the site from the National Priorities List will be pursued.
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 as amended by Superfund Amendments and
Reauthorization Act of 1986, and the National Contingency Plan, I have
determined that the No Action alternative, which includes long term
monitoring of groundwater and surface waters, in conjunction with the
approved Source Control Remedial Action, will provide adequate protection
of public health, welfare, and the environment. This remedy attains
Federal and State requirements that are applicable or relevant and
appropriate and is cost effective. It is determined that this remedial
approach is permanent and the use of alternative treatment technologies
have been utilized to the maximum extent practicable.
The state of Oklahoma has been consulted and concurs with this remedial
action for the Main Site (groundwater) Operable Unit. The activities
outlined in the September 1987 ROD for source control operation and
maintenance are incorporated into the selected remedy for the ground-
water unit. If contamin-ants from the site are detected during a
monitoring period which appear to be adversely impacting the groundwater
or the Arkansas River, an investigation will be initiated to determine
the need for future action. For such case, a Record of Decision must
be prepared for any additional future remedial action(s).
.n
Date ~ Robert E. Layton Jr., P.E.
Regional Administrator
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TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DECRIPTION
Site History 1
Geology 1
Remedial Investigation Results 2
Potential Impacts of Site on Human
Health and the Environment 4
II. ENFORCEMENT
Background 4
III. COMMUNITY RELATIONS HISTORY 4
IV. ALTERNATIVES EVALUATION
Evaluation Criteria .- 5
Description of Alternatives 8
Evaluation of Alternatives 10
V. SELECTED REMEDY
Rationale 12
Consistency with the National Contingency Plan
and Superfund Statutes 13
Operation and Maintenance 13
Future Actions 14
VI. APPENDICES
A. Tables 1-4
B. Agency for Toxic Substances and Disease Registry (ATSDR)/
Centers for Disease Control (CDC) Evaluation
C. Administrative Record Index
D. State Concurrence
E. Responsiveness Summary
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EXECUTIVE SUMMARY
The Sand Springs Superfund site is located in Sand Springs, Oklahoma.
The site is the former location of the Sinclair Refinery which operated
from the turn of the century through the 1940's. After the refinery
was shut down, most of the property was conveyed to the Sand Springs
Home. In 1968, Sinclair merged with Atlantic Richfield Company (ARCO)
and the remaining 38 acres retained by Sinclair were absorbed in the
merger. The portion of the complex identified in the Remedial
Investigation/Feasibility Study as the Glenn Wynn site operated as a
solvent recycling facility during the late 1960's and early 1970's.
The total known waste volume is approximately 130,000 cubic yards.
Unlined sludge pits on the site contain several thousand cubic yards
of sulfuric acid sludge. In addition to these wastes, the lagoons,
pits, and spray ponds on the site contain various heavy metals and
organics.
A Source Control Record of Decision signed in September 1987 dealt with
controlling or destroying the major sources of the contamination. This
Record of Decision will address the remainder of the site, which includes
minimally contaminated soils and groundwater contamination.
Based on the findings in the Remedial Investigation and Feasibility
Study for this operable unit, the Endangerment Assessment concluded
that there are no public health threats from the minimally contaminated
soil, groundwater or the Arkansas River. The groundwater and the Arkansas
River are not sources of drinking water and sampling of the Arkansas
River detected no contamination. Also it was discovered that much of
the site and surrounding area contains high inorganics or metals possibly
due to local smelter operations. The site is also being impacted from
offsite sources of organics, primarily solvents.
Of the four alternatives proposed for detailed analysis, the Environmental
Protection Agency (EPA) has selected No Action with monitoring, following
the Source Control Remedial Action. The site would be monitored for at
least 30 years. The estimated cost of this alternative fs $440,000.
Potential off-site and/or active facilities which may be contributing
to groundwater contamination in the area of the site will be further
investigated in consultation with the Oklahoma State Department of
Health.
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Summary of Remedial Alternative Selection
Groundwater Operable Unit for
Sand Springs Petrochemical Complex
Tulsa County, Oklahoma
June 1988
I. SITE LOCATION AND DESCRIPTION
The Sand Springs Petrochemical Complex Superfund site is located
in Sand Springs, Oklahoma. As shown in Figure 1 the site is located
on the northern bank of the Arkansas River, immediately west of Tulsa,
Oklahoma. The site encompasses approximately 235 acres and is the
former location of a refinery. As shown in Figure 2, the site includes
unlined acid sludge pits, a surface impoundment, surficial sludge conta-
mination, solvent and waste oil lagoons and contaminated sediments and
several subsurface sludge pits and spray ponds. The Source Control
Operable Unit Remedial Investigation and Feasibility Study and Record
of Decision (ROD) further describes the sources of contamination and
the selected remedial action for them. In general the ROD called for
removal and treatment of the sources of contamination. The site is
situated in a sandy alluvial deposit with a thickness ranging from 25
to 41 feet. This deposit is underlain by approximately 100 feet of
shale. Pits and lagoons have contaminated shallow groundwater.
In September 1983 the site was proposed for inclusion on the National
Priorities List. Promulgation of the site was in June 1986. In June
1984, the Oklahoma State Department of Health (OSDH) entered into a
Cooperative Agreement with EPA to conduct the Remedial Investigation/
Feasibility Study (RI/FS) at the site. Utilizing funds from this
Cooperative Agreement, the OSDH contracted with John Mathes and Associates
to perform the sampling, analysis, and technical assessments of the
site.
In an effort to address the obvious contamination in an expeditious
manner, a source control operable unit was established to focus on the
waste in the pits, ponds, and lagoons. The Source Control Record of
Decision addresses those sources of contamination. The remainder of
the site, primarily the groundwater, is addressed in the full or "Main
Site" RI/FS dated March 1988 and April 1988 respectively.
Hydrogeologic setting
The Sand Springs Petrochemical Complex is adjacent to the Arkansas
River on an alluvial flood plain. A geologic cross-section of the site
is presented in Figure 3. The thickness of the alluvial materials,
based on boring logs from the site, ranges from 25.0 feet to 41.2 feet.
In general, the alluvium thickness averages 35-40 feet near the river
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John Mathes & Associates. Inc
SURFICIAL GEOLOGY OF
SAND SPRINGS PETROCHEMICAL
COMPLEX AREA
12862459
FIGURE 1
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John Mathes & Associates, Inc.
WASTE DISPOSAL AREAS
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and decreases to the north. The alluvial materials primarily consist
of silt and fine- to medium-grained sand. Terrace deposits, primarily
thick alluvial deposits of fine- to medium-grained sand, exist just
north and upgradient of the site.
The alluvial groundwater is recharged by infiltration of rainfall and
surface water through the Newblock Park terrace and Arkansas River
alluvium. This recharge is expected to add to the amount of groundwater
flow beneath the site, which based on measured groundwater flow conditions,
discharges into the Arkansas River. Figure 3 is a generalized geologic
cross section through the Arkansas River Valley illustrating the spatial
relationship between the terrace deposits and flood plain alluvium.
The lateral hydraulic gradient (slope) within the alluvium deposits is
based on fluid elevation measurements. Based on monitoring well measure-
ments, the direction of groundwater flow was found to be toward the
Arkansas River. These measurements coincide with conclusions presented
in Tulsa's Physical Environment (Tulsa Geological Society, 1973) that
the Arkansas River is predominately an effluent strean-, The groundwater
flow velocity in the alluvial materials is estimated to be in the range
of 198 to 764 feet per year.
The uppermost bedrock underlying the site is the Coffeyville Formation,
which is composed of shales, thin bedded sandstones, and siltstones.
The portion of the Coffeyville Formation underlying the site is
estimated to be approximately 280 feet thick (OSDH, 1986b).
Insitu aquifer tests performed at the site indicate high hydraulic
conductivities. Based on these tests the alluvial aquifer appears to
be very consistent in hydraulic conductivity throughout the site.
Measured hydraulic conductivities ranged from 403 to 1272 (gallons per
day/per square foot). Hydraulic conductivity data for the Coffeyville
Formation is not available, but field observations of rock cores and
borehole tests indicated hydraulic conductivities to be several orders
of magnitude lower than for the overlying alluvial deposits. The
difference in hydraulic conductivity indicates that movement of contami-
nated groundwater will primarily be lateral within the alluvium. The
extremely low hydraulic conductivity of the underlying shale will
restrict the infiltration of groundwater from alluvium to bedrock.
Main Site remedial investigation summary
During the Main Site RI of the Sand Springs Petrochemical Complex,
samples were collected of soil, surface water, groundwater, and soil
gas to evaluate if significant pollutant concentrations are present.
Groundwater monitoring well installation, groundwater sampling, and
water level monitoring were performed in two phases of the investigation.
Phase I occurred during the summer of 1986 and Phase II occurred during
early 1987. A total of 24 monitoring wells were installed during both
phases. These 24 new wells and the 11 existing wells installed by U.S.
Environmental Protection Agency (EPA) contractors were sampled for this
RI.
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GENERALIZED CROSS SECTION
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12862459
FIGURE 3
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Subsurface soil was sampled during drilling of all monitoring wells and
borings. In summer of 1986, soil gas samples were collected and analyzed
at 87 locations. The results of these analyses were used in selecting
some phase II boring and monitoring well locations.
The extents of the plumes (Figure 4) of contaminated groundwater and
areas of contaminated soils were estimated based on monitoring well and
boring data. Table 1 shows the maximum groundwater concentrations
for selected inorganic and organic compounds. Both surface runoff and
groundwater move from the site to the adjacent Arkansas River. The
impact on Arkansas River water quality has been determined to be insigni-
ficant. This conclusion is based on actual sampling of the river and
on computer modeling performed by the Oklahoma Water Resources Board
(FY-85 Water Quality Management Plan, 1986).
Inorganic priority pollutant compound contamination was found to be
widespread. Most sampled areas on-site, including background monitoring
wells, were contaminated to some extent. Smelter slag wastes, (normally
high in metals) used as fill in the area for several decades may have
leached and created the metal concentrations detected in the soil and
groundwater samples. Concentrations of barium in soil and groundwater
may have been caused by disposal of drilling muds containing barium,
orginating from extensive oil and gas well drilling in the area. Due
to the high background concentrations of inorganics, the alluvial
aquifer in the area of the site could be classified as a Class III or
imuseable aquifer.
Based on studies of site use, it appears that much of the base-neutral
organic priority pollutants found on-site are the result of oil contami-
nation. A source of subsurface petroleum hydrocarbons appears to have
been leakage from the former refinery tank farm and processing areas.
The lateral movement of the oil plume is apparently small because migration
of the plume beyond the boundaries of the former refinery and waste pit
areas does not appear to have occurred.
The groundwater contaminant plumes of volatile organic priority pollutants
have originated from several sources, some of which are located upgradient
of the site. The origin of the upgradient plumes is unknown. The
source of the on-site plume appears to be from soil contamination and
lagoons at the Glenn Wynn site, as indicated in Figure 5.
Although the nearest residential drinking water wells are approximately
one mile northeast of the site, these wells are not downgradient of the
site since the site groundwater discharges southeast to the Arkansas
River. The USEPA's Field Investigation Team collected samples for
metals analysis from seven of the residential drinking water wells in
December of 1980. Significant concentrations were not detected in
these samples. A full chemical analysis was performed on three of the
residential wells in September 1987 and the sample results showed that
no contaminants were detected. Should these residential drinking water
wells ever become contaminated from some upgradient source, a municipal
water system is available in the neighborhood.
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A more detailed description of the analytical results can be found in
the Sand Springs Petrochemical Complex "Main Site" Remedial Investigation
Report.
Because of the petroleum exclusion under the Comprehensive Environmental
Response Compensation and Liability Act as amended by the Superfund
Amendments and Reauthon'zation Act (Section 101 (f)) the subsurface oil
contamination at this site cannot be dealt with as a Superfund waste.
Those plumes of groundwater contamination which appear to be originating
from off-site or from active facilities will undergo further investigation
in consultation with the Oklahoma State Department of Health Preliminary
Assessment/Site Inspection Program and the Resource Conservation and
Recovery Act Program. Because of these findings the "Main Site" Feasibility
Study and this Record of Decision deals primarily with the groundwater
contamination associated the "Glenn Wynn area" of the site.
Potential Impacts of the Site on Human Health and the Environment
Groundwater has been contaminated directly by the Glenn Wynn lagoons and
indirectly by runoff from the site, however, following the Source Control
Remedial Action, groundwater quality is anticipated to improve. Relatively
clean sands were found beneath the main waste deposits above underlying
groundwater, indicating that direct contamination by the main waste
deposits is not significant. Discharge of the-Glenn Wynn "plume" to
the Arkansas River has not proved to be a.degradation to surface water
quality, based on the sampling conducted during the Remedial Investigation.
Also, sediment sampling adjacent to the Glenn Wynn area did not indicate
significant contamination.
Based on the information gathered in studies of the site, EPA has
concluded that the groundwater and minimally contaminated soils on the
site pose no significant risks to human health and the environment.
Attached correspondence (Appendix B) from the Agency for Toxic Substances
and Disease Registry (ATSDR) concurs with this finding. Sampling of
area residential wells and the Arkansas River has not detected any
contamination from the site. Primary drinking water is supplied by
Lake Spavinaw and Lake Eucha in Delaware county northeast of Tulsa on
the Grand River system. Also, following the Source Control Remedial
Action, no risks to human health and the environment are expected to
exist via the direct contact, air emissions or surface water exposure
routes.
II. ENFORCEMENT
Background
Approximately 700 Potentially Responsible Parties (PRPs) have been
identified at the site. Special notice was given to ARCO to conduct
the Source Control Operable Unit Remedial Design and Action. A consent
decree has been finalized and will be forwarded to the Department of
Justice for lodging with the court.
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To date, two PRPs have taken action at the site; ARCO and the Sand
Springs Hone.. The Sand Springs Home, performed a removal action in
1984 under the terms of a Unilateral Administrative Order. ARCO
conducted soldification and incineration waste treatability studies
under an Administrative Order.
III. COMMUNITY RELATIONS HISTORY
Investigations at the Sand Springs site focused on two areas of study,
the Source Control Operable Unit and the Main Site Operable Unit (ground-
water and soils). On July 24, 1984, EPA announced through a press
release that funds were available to the Oklahoma State Department of
Health to conduct studies at the site. The Source Control study was
subject to a public comment period and public meeting during August 1987.
The Record of Decision was signed on September 29, 1987. The Main Site
study was completed in the Spring of 1988. On March 24, 1988, OSDH
announced via a press release that the Remedial Investigation was
available in repositories for public review. On May 4, 1988, EPA
announced through a press release that the public comment period on the
Main Site Remedial Investigation Feasibility study wou*j be held between
May 9 and June 7, 1988. Also the press release announced that a public
meeting to discuss the proposed remedy would be held at the Sand Springs
Municipal Building on May 24, 1988.
The press release and an EPA prepared fact sheet describing the various
remedial alternatives and the EPA preferred alternative was mailed to
the site mailing list. The fact sheet provided a brief history, described
the remedy selection process, listed the remedial alternatives and
provided details about the public comment period and public meeting.
On May 24 at 3:00 p.m. EPA and OSDH representatives briefed the Mayor,
Members of the City Council, the City Manager, other members of the
city and staff and representatives of civic organizations on the
proposed remedy. All those present agreed with EPA's preferred
alternative.
The public meeting began at 7:00 p.m. About 65 people were in attendance.
All speakers at the meeting agreed with EPA's preferred alternative,
including the Oklahoma State Department of Health, the city of Sand Springs,
the Sand Springs Chamber of Commerce and interested citizens. A request
was made to extend the public comment period. However, EPA later deter-
mined that since all communication efforts were made to provide adequate
notice about the comment period and that the parties making the request
agreed with the proposed remedy, there was no need to extend the public
comment period. The meeting adjourned at 7:45 p.m. No additional comments
were submitted during the public comment period, however comments which
were received prior to this Record of Decision are responded to in
Appendix E.
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IV. ALTERNATIVES EVALUATION
Evaluation Criteria
To ensure compliance with Section 121(a)(b) and (d) of the Superfund
Amendments and Reauthorization Act, the following nine factors are
considered in selecting a remedy for a Superfund site. These are
summarized below:
1. Consistency with Other Environmental Laws (ARARs)
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 appli-
cable to each Superfund response action. The compliance of
each remedial alternative with all applicable or relevant and
appropriate environmental laws is shown in Table 4.
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:
o The treatment processes the remedies employ and materials
they will treat;
o The amount of hazardous materials that will be destroyed
or treated;
o the degree of expected reduction in toxicity, mobility,
or volume;
o The degree to which the treatment is irreversible;
o 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:
o Magnitude of reduction of existing risks;
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o 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;
o Time until full 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 certainity that
the remedy will prove successful. Factors considered are:
o 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 to bioaccumulate of such hazardous substances
and their constituents;
o Type and degree of long-term management required, including
monitoring and operation and maintenance;
o 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;
o Long-term reliability of the engineering and institutional
controls, including uncertainties associated with land disposal
of untreated wastes and residuals;
o 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:
o Degree of difficulty associated with constructing the technology;
o Expected operational reliability of the technologies;
o 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;
o Availability of necessary equipment and specialists;
o Available capacity and location of needed treatment, storage,
and disposal services.
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6. Cost
The types of costs that should be assessed include the
following:
o Capital cost;
o Operation and maintenance costs;
o Net present value of capital and 0 & M costs;
o Potential future remedial action costs.
7. Community Acceptance
This assessment should look at:
o Components of the alternatives that the community supports;
o Features of the alternatives about which the community has
reservations;
o Elements of the alternatives which the community strongly opposes.
8. State Acceptance
Evaluation factors include assessments of:
o Components of the alternatives the State supports;
o Features of the alternatives about which the State has
reservations;
o 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. Off-site transport and disposal without treatment
is the least preferred option where practicable treatment tech-
nologies are available.
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Description of Alternatives
In conformance with the National Contingency Plan, initial remedial
approaches were screened to determine which might be appropriate for
dealing with groundwater contamination at the site. (See the Feasibility
Study for details of this evaluation). The Source Control Remedial
Action as described in the September 1987 Record of Decision was given
consideration during development of the groundwater remediation alter-
natives. The Source Control Remedial Action will be performed prior to
implementation of any selected groundwater alternative. The estimated
duration and costs for each alternative was based on remediation to
background concentrations of contaminants found in upgradient monitoring
wells. Each groundwater remedial action alternative would require
treatability studies to determine effectiveness and the capabilities of
each technology for remediating contaminated groundwater at the site.
From the initial remedial approaches four alternatives were chosen for
more detailed evaluation and comparison with the remedy selection criteria
outlined above. As previously mentioned, these alternatives deal with
groundwater contamination associated with the Glenn Uynn area of the
site. Each is summarized below:
ALTERNATIVE 1, No Action, consists of monitoring the site following the
Source Control Remedial Action. The No Action alternative is included
to evaluate the groundwaters degree of threat to public health and the
environment following the Source Control Remedial Action and for
comparison with all other alternatives. Included in the no action
alternative is the placement of appropriate warning signs, restricting
access and the collecting and analyzing of groundwater and Arkansas
River samples for a period of 30 years. The cost of this alternative
is approximately $440,000.
ALTERNATIVE 2, Bioreclamation, consists of interception of groundwater
upgradient of the Glenn Wynn lagoons, addition of nutrients and an
oxygen source around the lagoon area, enhanced biodegradation of
groundwater contaminants insitu, removal of a major portion of the
groundwater flow at the levee for recycling to the lagoon area, and the
natural flow of remediated groundwater to the Arkansas River system.
Venting of the subsurface soil above the groundwater would also be
performed. Because of the need for bench-scale treatability studies
for design of a bioreclamation system, engineering was estimated to be
15 percent of construction costs for this alternative.
Bioreclamation is estimated to require five years to remediate the
subsurface soil and groundwater. The estimated cost of this alternative
is approximately $7.9 million dollars.
ALTERNATIVE 3, Biological Treatment, consists of removing the groundwater
downgradient of the Glenn Uynn lagoon area and biologically treating the
contaminated groundwater in an activated sludge reactor. Venting of
the subsurface soil above the groundwater would also be performed.
Groundwater would be removed using a subsurface collection system down-
gradient of the Glenn Wynn lagoon area. The water would be pumped from
-------
10
the lift station at an estimated rate of 100 GPM to a hydrocarbon/water
separator, then to a flow equalization tank. The water would be pumped
to the activated sludge reactor, passed through a clan'fier, and filtered
prior to discharge to the Arkansas River.
Alternative 3 is estimated to require 10 years to complete. Treatability
studies would be necessary to determine the technology's effectiveness
on the sites contaminated groundwater. The estimated cost of this
alternative is approximately $7.3 million.
ALTERNATIVE 4, Physical Treatment, consists of removing groundwater
downgradient of the Glenn Wynn lagoon area with a subsurface collection
system and treating it in physical treatment units before discharging
it to the Arkansas River. This alternative involves filtration, air
stripping and carbon adsorption. Venting of the subsurface soil is
also included in this alternative.
Applicable regulatory standards would be attained for Alternative 4.
The treatment units would be sized to achieve acceptable effluent
concentrations at a groundwater flow rate of 100 GPM. The estimated
duration of remediation using Alternative 4 is 10 years. The estimated
cost of this alternative is approximately $7.3 million.
Evaluation of Alternatives
The degree that the four groundwater remedial alternatives meet the
nine selection criteria is contained in Table 3. The groundwater
remedial alternatives are evaluated taking into consideration the
approved Source Control Remedial Action. The following values were
assigned to compare remedial, selection criteria:
-i- 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.
The rationale for the ratings assigned in this table is as follows:
1. Complies with ARARS (i.e. meets or exceeds Applicable, or Relevant
and Appropriate Federal and State Requirements).
a. No Action (monitoring the groundwater following the Source Control
Remedial Action) was assigned "0" because following the Source
Control Remedial Action it is anticipated that the natural flushing
action of the alluvial aquifer will decrease the level of ground-
water contamination over time. Sampling of the Arkansas River
was unable to detect contamination from the site and a "worst case"
computer modeling of the Glenn Wynn plume indicated that, although
undetected, the hypothetical discharge would be 4.6 times less than
NPDES regulatory standards. Primary drinking water is supplied by
-------
11
Lake Spavinaw and Lake Eucha on the Grand River System northeast
of Tulsa. Based on sampling, residential wells within one mile
of the site have not been affected and are not anticipated to be
impacted based on the direction of groundwater flow, which is
towards the Arkansas River. Long term (at least 30 years) monitoring
would be conducted to ensure the effectiveness of the remedy.
b. All treatment alternatives (Insitu Biproclamation, Biological
Treatment and Physical Treatment) were also rated "0" because
each alternative could be designed to meet the applicable or
relevant and appropriate Federal and State regulatory
requirements.
2. Reduces: Toxicity, Mobility, and Volume
No Action (monitoring following the Source Control Remedial Action)
and all featment alternatives (Insitu Bioreclamtion, Biological
Treatment and Physical Treatment) were rated "+" because each
alternative, although in varying degrees, would reduce each of these
parameters. Because the major sources of contamination will be
removed, the natural flushing action of the alluvial aquifer will
reduce groundwater contamination over time, therefore the "No Action"
alternative meets these parameters. All treatment alternatives
could potentially reduce mobility, toxicity and volume based on
previous aoplications of the technologies, however treatability
studies would be required to determine the level of effectiveness on
the particular contamination at the site.
3. Short term Effectiveness
The "No Action" (monitoring following the Source Control Remedial
Action) was rated "0" in relation to the treatment alternatives,
which were rated "+", because of the relative differences in time
between the natural flushing action of the alluvial aquifer versus
the active pumping associated with the treatment alternatives.
4. Long-term Effectiveness
Because the natural flushing of the alluvial aquifer associated with
the "No Action" alternative and all treatment alternatives can
potentially reduce groundwater contamination effectively in the long
term, each alternative was rated "+".
5. Implementability
The "No Action" (monitoring following the Source Control Remedial
Action) and Physical Treatment alternatives were both rated "+"
relative to the other treatment alternatives because of their known
effectiveness and predictability based on previous applications.
The Insitu Bioreclamation and Biological Treatment alternatives were
rated "-" because of the unknown level of effectiveness of any biological
technology on the particular groundwater contamination at the site.
-------
12
6. Cost
Estimated cost for each remedial action alternative are summarized in
Table 2. Included in this table are total capital and implementation
costs, annual operation and maintenance costs, total present worth.
and replacement costs. Replacement costs are included to evaluate
the costs involved if the alternative were to fail and replacement of
equipment associated with each remedy was necessary. Replacement
costs for each treatment alternative are approximately $3 million.
Replacement costs associated with the "No Action" alternative is
approximately $8,000. The present worth of the "No Action" (monitoring
following the Source Control Remedial Action) alternative is approxi-
mately $440,000. All treatment alternatives are estimated to cost
$7-8 million.
7. Community Acceptance
Based on the favorable public responses at the public meeting and
during the public comment period the "No Action" (monitoring
following the Source Control Remedial Action) was rated "+" and all
treatment alternatives were rated "0".
8. State Acceptance
The State of Oklahoma concurs with the selected remedy (See Appendix D).
Therefore, the "No Action" (monitoring following the Source Control
Remedial Action) alternative was rated "+" and all treatment alternatives
were rated "0".
9. Overall Protection of Human Health and the Environment
The "No Action" (monitoring following the Source Control Remedial
Action) alternative and all treatment alternatives were rated "+".
Each treatment alternative, including the natural flushing of the
alluvial aquifer associated with the "No Action" alternative can
potentially reduce groundwater contamination. Sampling of area
residential wells and the Arkansas River has not detected any
contamination from the site.
The long term monitoring (at least 30 years) of the groundwater
which is including in the "No Action" alternative would ensure
effectiveness of the remedy.
V. SELECTED REMEDY: No Action (monitoring following the Source Control
Remedial Action)
Rationale
Based upon the findings of the RI/FS, the Endangerment Assessment
for this operable unit concluded there are no public health threats
from the minimally contaminated soil, groundwater, or the Arkansas
River. The groundwater and the Arkansas River are not sources of
-------
13
drinking water and sampling of the Arkansas River detected no
contamination. Considering these findings the selected remedy for
this operable unit is No Action (monitoring following the Source
Control Remedial Action). A "worst case" computer modeling of the
site indicated that, although undetected, the hypothetical discharge
would be 4.6 times less than NPDES regulatory standards. Primary
drinking water is supplied by Lake Spavinaw and Lake Eucha on the
Grand River System northeast of Tulsa. Based on sampling, residential
wells within one mile of the site have not been affected and are
not anticipated to be impacted based on the direction of groundwater
flow, which is towards the Arkansas River.
Included as part of this remedial action is the placement of appro-
priate warning signs, restricting access and collecting and analyzing
groundwater and Arkansas River samples for a period of at least 30
years. Potential offsite and/or active facilities which appear to
be contributing to groundwater contamination in the area of the
site will be further investigated in consultation with the Oklahoma
State Department of Health. If, after the source control remedial
action, as described in the September 1987 Source Control Record of
Decision, monitoring reveals that the site releases contamination
such that groundwater or the Arkansas River is adversely impacted,
then further action will be considered. If no trend toward adverse
impacts is detected, deletion of the site from the National Priorities
List will be pursued.
This alternative is protective and cost-effective and attains
applicable or relevant and appropriate Federal and State standards.
It is determined that this remedial approach is permanent and
-the use of alternative treatment technologies have been utilized to
the maximum extent practicable.
Consistency with the National Contingency Plan (NCP) and the Provisions
of the Superfund Amendments and Reauthorization Act of 1986 (SARA)
The No Action remedy in conjuction with the previously approved source
control remedial action (September 1987 Source Control Record of
Decision) provides adequate protection of public health, welfare, and
the environment. This approach is also consistent with the National
Contingency Plan (NCP), 40 CFR 300.68(h)(2)(iv) and (vi) (Federal
Register, 1985) which requires:
(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) have been considered. These include:
-------
14
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)
The need for future operation and maintenance will be minimized since
the sources of the contamination will be treated as indicated in the
September 1987 Source Control Record of Decision. Site operation and
maintenance will include a monitoring well and Arkansas River sampling
and analysis program. Additional site maintenance will entail inspection
of the site, periodic repair of the perimeter fencing, and monitoring
associated with the Source Control Remedial Action.
Future Actions
The proposed remedial action for the site is considered permanent. If,
however, significant, unforeseen, off-site migration or contamination
occurs as a result of the site, appropriate remedial measures will be
taken.
Based on the studies conducted it appears that potential off-site
and/or active facilities are contributing to groundwater contamination
in the area of the site. Further investigations are being conducted in
consultation with the Oklahoma State Department of Health Preliminary
Assessment/Site Inspection Program and the Resource Conservation and
Recovery Act Program to identify these sources of contamination.
Schedule*
Approve Remedial Action (sign ROD) June 1988
Complete Enforcement Negotiations October 1988
Start Remedial Design October 1988
Complete Design . March 1989
Start Remedial Action March 1989
* This schedule coincides with the schedule outlined in the September
1987 Source Control Record of Decision.
-------
APPENDIX A
-------
TABLE 1
MAXIMUM GROUNDWATER CONCENTRATIOKS
FOR SELECTED COMPOUNDS COMPARED
TO WATER QUALITY STANDARDS
SAND SPRINGS SITE
Parameter
MCL
Concentration
(mg/L)
Maximum
Concentration In
Groundwater Samples
(mg/L)
Location
of
Maximum
Concentration
Inorganic Compounds
Barium
Chromium
Arsenic
Lead
Cadmium
Mercury
1.0
0.050
0.050
0.050
0.010
0.002
98
0.85
1.4
1.4
0.093
0.003
MW10
MW10
MW10
MW10
MW1
MW10
Organic Compounds
Benzene 0.005
Trichloroethylene 0.005
1,1-Dichloroethylene 0.007
1,1,1-Trichloroethane 0.20
1,2-Dichloroethane 0.005
Vinyl chloride 0.002
0.26
0.16
0.029
1.4
0.24
1.8
MW4
MW1
MW16
MH1
MW1
MW4
a MCL = Maximum contaminant level for drinking water under Safe Drinking
Water Act.
Note: This table is for comparison purposes only. The groundwater from the
Sand Springs Site is not used as a drinking water source.
-------
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APPENDIX B
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Agency for Toxic Substances
and Disease Registry
Atlanta GA 30333
MEMORANDUM
To:
From:
Subj ect:
April 2=~d) and orqanics ( b<=r, rene ,
TCE, and viny] chloride). The qroundwater -flow is southeastward to the Arkar
sas River. Date reveals th
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ION :
Iri & v c< ] L'
i £: ti'ie opinion of
tns
the proposed
ac Lion with monitoring alternative fol lowing the source control removal act".
is dpproor ic- if for the =-ite. At the time of the iden ti i icata on of additions
facilities that are or ha/e been contributing to the influence of arcundwate
and pC'=-r. ibis other m&dia. £*'' evaluation of offsite- conditic>n= and potential
ATSDR appreciates t^le LID r.'Ci
fcr the F.-^f1' «ii.e ='.d wjrjijl.-j
|" r r,.,| t h 3 r = i. t t r
ur.i 1 1
to con»Tien
on
he EF'A proposed alterne-. ta . f-
uc-st to be ^fcii't ai:'Dr',-< ised of future act
^. 1 Hi-J A.T.
1 R . H i c i
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tiff-; M-_c: an«l.a
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APPENDIX C
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APPENDIX D
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JOMlK.
M.O.
OKLAHOMA STATE
n. WO
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Oklahoma State Department of Health Official Statement
Sand Springs Superfund Site Public Meeting
May 24,19SS
Under cooperative agreements with the U.S. Environmental Protection Agency, the
Oklahoma State Department of Health has completed a Remedial Investigation,
Feasibility Study and Endangerment Assessment lor the groundwater portion of the Sand
Springs Superfund site.
During these studies, a considerable amount of data was gathered to assess the impact, if
any, of groundwater from the site on public health and the environment. It was
determined that groundwater at the site is not used for drinking or other purposes. The
hydrogeology of the site is such that the groundwater moves directly into the Arkansas
River. Samples taken from the river did not indicate any contamination. Most likely,
contaminants from the site do reach the river. However, their concentration is so small
and the river flow so great that they are diluted to the point of causing no Impact.
Unable to find any public health threat or significant impact to the river, the Health
Department be."eves that there would be no benefit in restoring the groundwater at the
site to its natural state. Our analysis of the groundwater data indicates that many of the
samples already meet Safe Drinking Water Act standards and those that do not are at
lower levels than most of the current industrial discharges to the river. With this
evidence, the Oklahoma State Department of Health concurs with the U.S. EPA's
preferred remedy of Natural Remediation for the Sand Springs Superfund site. We
commend the EPA for making what we believe to be the appropriate recommendation for
the site.
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APPENDIX E
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Sand Springs Petrochemical Complex
Sand Springs, Oklahoma
Main Site (groundwater) Operable Unit
Responsiveness Summary
Additional information regarding community relations at the site can be
found in Section III. Community Relations History of the Main Site
(groundwater) Operable Unit Record of Decision.
Summary of Major Comments Received Following the Public Comment Period
and EPA Responses to the Comments
1. Comment: If EPA decides to adopt a remedy other than No Action it
should first consider how to address the issue of how
clean is clean, since there is extensive offsite and onsite
contamination.
Response: All treatment alternatives evaluated dun'.-- the Feasibility
Study (FS) were based on remediating grounawater to the
background concentrations found in upgradient monitoring
wells 1A and MW-22. (page 4-3 of FS)
2. Comment:
Response:
3. Comment:
Response:
4. Comment:
Although the FS excludes floating hydrocarbons and heavy
metals, they would have to be removed during any other
remedial effort.
The FS did not exclude floating hydrocarbons and heavy
metals. The FS evaluated these parameters and determined
that due to the statutory petroleum exemption and elevated
background concentrations of heavy metals, subsurface
hydrocarbons and heavy metals should not be specifically
addressed during the detailed analysis of alternatives
(page 2-16-18 of FS). Regardless of this determination
the Remedial Investigation (RI) did not detect any adverse
offsite impacts from these or any other groundwater
contaminants.
Removing the soils on the Glenn Wynn portion of the site
would not alleviate the soil contamina:ion problem; the RI
indicates that soil contamination simi'ar to that found at
the Wynn portion exists at other places on the site.
EPA disagrees. Although lesser amounts of soil contami-
nation exist at other areas of the site, as indicated in
the previously signed Source Control Record of Decision, a
major source of contamination can be eliminated by
heavily contaminated soils from the Glenn Wynn portion
the site. AGSNCY
By denying a reasonable extension of time within whichrcr^S, TEXAS
file comments, commentors were denied due process to
adequately participate in the administrative process,
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Response:
5. Comment:
Response:
6. Comment:
Response:
7. Comment:
Response:
EPA disagrees. A thirty day public comment period was
provided, although only a twenty one day public comment
period is required by the National Contingency Plan. In
addition, separate notices were sent to the Potentially
Responsible Parties to alert them to the impending decisfon
though not required by statute or regulation. Also, all
commentors, including those requesting an extension, agreed
with EPA's proposed No Action (monitoring following the
source control remedial action) alternative, therefore EPA
found no useful purpose in formally extending the public
comment period.
The statement made in the FS indicating that "the lateral
extent of the onsite volatile organic plume which exceeds
15 ug/1 is approximately 70 acres" is disproportionate to
the amount of contamination actually found at the Glenn
Wynn portion of the site.
EPA agrees with this comment however the statement in the
FS is accurate due to the fact that the 70 acres is in
reference to the estimated extent of volatile organic
contamination greater than 15 ug/1 over the entire site,
not just the Glenn Wynn area.
The FS (page 2-20) states that "groundwater contaminants that
exceed drinking water guidelines include arsenic, lead, benzene,
1,2-dichlorethane, tetrachloroethylene and vinyl chloride."
However, Table 2-2 indicates several other parameters that
exceed Maximum Contaminant Level (MCL) concentrations at the
site.
The discussion on page 2-20 of the FS is in reference to the
potential exposure pathways evaluated in the Endangerment
Assessment and is not intended to be a complete discussion on
overall groundwater contamination, which is found elsewhere
in the document. The statement that "groundwater contaminants
that exceed drinking water guidelines include..." is merely
a statement to indicate that contamination is present in a
potential exposure pathway.
One commentor disagreed with the technical approach used to
reach the FS conclusions and with the assumptions made in the
Endangerment Assessment.
Although the commentor disagreed with the methodologies
employed in reaching various FS and Endangerment Assessment
conclusions, the commentor also indicated agreement with the
resulting conclusions. Numerous methods of evaluation and
assumptions could be made during the FS and Endangerment
Assessment process which could result in the same conclusions.
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