* •
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/ROC-90/054
November 1989
PA Superfund
Record of Decision
Hardage/Criner, OK
UsJfi.'jiii ?
x
\
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-90/054
3. Recipient1* Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
pardage/Criner, OK
'irst Remedial Action (Amendment)
7. Author(s)
S. Report Date
11/22/89
8. Performing Organization RepL No.
9. Perionning Organization Name and Addreee
10. Project/Taak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponaoring Organization Name and Addree*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
15. Supplementary Notea
16. Abstract (Limit: 200 words)
The Hardage/Criner site is in an agricultural area near Criner, McClain County, in
central Oklahoma. The site is situated in the North Criner Creek drainage basin,
approximately 0.8 miles from the confluence of North Criner Creek and Criner Creek. From
1972 to 1980 the site was operated under a State permit for the disposal of industrial
wastes including paint sludges and solids, ink solvents, tire manufacturing wastes, oils,
solvents, cyanides, and plating wastes sludges. Waste disposal practices have
in the contamination of approximately 70 acres of ground water beneath and
adjacent to the site as well as several acres of surface soil. The principal source of
contamination is approximately 278,000 cubic yards of sludges, waste drums, highly
contaminated soil, and waste liquids contained in three main waste (source) areas near
the center of the property. Additional source areas include scattered mixing ponds,
spill areas, and runoff paths in the vicinity of the main source areas. Dense
non-aqueous phase liquids have pooled beneath the disposal areas and are a continuing
source of contamination to the ground water. A 1986 Record of Decision addressed source
control through incineration, stabilization, and onsite disposal; however, the remedial
action was never implemented due to protracted litigation. The 1989 ROD Amendment
provides a comprehensive site remedy addressing both source control and ground water
remediation and takes into consideration recently enacted land disposal restrictions.
The primary contaminants of concern affecting soil, debris, (Continued on next paqe)
OK
17. Document Analysis a. Descriptor*
Record of Decision -Hardage/Criner,
First Remedial Action (Amendment)
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCBs, PCE, TCE), other organics (pesticides),
metals (arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSATI Reid/Group
Availability Statement
19. Security Ctas* (This Report)
None
20. Security Cla** (This Psge)
None
21. No. of Pages
260
22. Price
(See ANSI-Z39.18)
See Inatructiona on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Pag* la baaed on Guideline* for Format and Production of Scientific and Technical Reports,
ANSI Z39.18-1974 available from American National Standards Institute, 1430 Broadway, New York, New York 10018. Each separately
bound report—for example, each volume in a multlvolume Ml—shall have Its unique Report Documentation Page.
1. Report Number. Each Individually bound report shall carry a unique alphanumeric designation assigned by the performing orga-
nization or provided by the sponsoring organization in accordance with American National Standard ANSI Z39.23-1974, Technical
Report Number (STRN). For registration of report code, contact NTIS Report Number Clearinghouse, Springfield, VA 22161. Use
uppercase letters, Arabic numerals, slashes, and hyphens only, as in the following examples: FASEB/NS-75/87 and FAA/
RO-75/09.
2. Leave blank.
3. Recipient's Accession Number. Reserved for use by each report recipient
4. Title and Subtitle. Title should Indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main
title. When a report is prepared In more than one volume, repeat the primary title, add volume number and include subtitle for
the specific volume.
5. Report Date. Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected (e.g.,
date of issue, date of approval, date of preparation, date published).
6. Sponsoring Agency Code. Leave blank.
7. Author(s). Give name(s) In conventional order (e.g., John R. Doe, or J. Robert Doe). List author's affiliation If It differs from
the performing organization.
8. Performing organization Report Number. Insert If performing organlzaton wishes to assign this number.
9. Performing Organization Name and Mailing Address. Give name, street, city, state, and ZIP code. Ust no more than two levels of
an organizational hierachy. Display the name of the organization exactly as It should appear in Government indexes such as
Government Reports Announcements & Index (GRA & I).
10. Project/Task/Work Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Mailing Address. Include ZIP code. Cite main sponsors.
13. Type of Report and Period Covered. State Interim, final, etc., and, if applicable, Inclusive dates.
14. Performing Organization Code. Leave blank.
15. Supplementary Notes. Enter Information not included elsewhere but useful, such as: Prepared in cooperation with... Translation
of... Presented at conference of... To be published in... When a report Is revised, include a statement whether the new
report supersedes or supplements the older report
16. Abstract. Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the
report contains a significant bibliography or literature survey, mention it here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names, equipment designators, etc. Use open-
ended terms written in descriptor form for those subjects for which no descriptor exists.
(c). COSATI Field/Group. Field and Group assignments are to be taken form the 1964 COSATI Subject Category Ust. Since the
majority of documents are multidisciplinary In nature, the primary Field/Group assignment(s) will be the specific discipline,
area of human endeavor, or type of physical object The application(s) will be cross-referenced with secondary Field/Group
assignments that will follow the primary posting(s).
18. Distribution Statement. Denote public releasability, for example "Release unlimited", or limitation for reasons other than
security. Cite any availability to the public, with address, order number and price, if known.
19. & 20. Security Classification. Enter U.S. Security Classification In accordance with U. S. Security Regulations (i.e., UNCLASSIFIED).
21. Number of pages. Insert the total number of pages, Including introductory pages, but excluding distribution list, if any.
22. Price. Enter price in paper copy (PC) and/or microfiche (MF) if known.
GPO 1983 0 - 381 -526 (8393) OPTIONAL FORM 272 BACK
(4-77)
-------
EPA/ROD/R06-90-054
Hardage/Criner, OK
16. Abstract (Continued)
nd ground water are VOCs including benzene, PCBs, PCE, TCE and other carcinogenic
compounds; other organics including pesticides; and metals including arsenic, chromium,
and lead.
The selected remedial action for the site includes source control and ground water
components. Source control remediation includes installation of liquid extraction wells
to pump out free liquids currently pooled in the three waste areas and any liquids
released from drums buried in the mounds, followed by offsite treatment of the removed
organic liquids and onsite treatment of aqueous liquids; excavation of drummed organic
liquids for offsite destruction; excavation and consolidation of contaminated soil
adjacent to the main source areas with placement in the main source areas, followed by
temporary capping; treatment of the main source areas using in-situ soil vapor
extraction with treatment of air used in soil extraction by thermal destruction;
installation of a permanent RCRA-compliant cap once remedial activities are complete.
Ground water components are designed to control the spread of ground water plumes and
protect downgradient areas because of the technical impracticability of restoration of
the bedrock aquifer. Ground water remediation includes installation of an interceptor
trench downgradient of the source areas to intercept and collect contaminated ground
water migrating in bedrock zones, and a second trench or equally effective system of
extraction wells to intercept and collect contaminated ground water contaminating the
alluvium; design and construction of an onsite ground water treatment system to treat
both organic and inorganic contaminants before discharge of treated water to surface
water. Contaminants already present in the alluvium will be allowed to dissipate by
natural dilution, natural attenuation, and flushing; however, active restoration will be
.mplemented if contaminant reduction goals are not met. In addition, institutional
ontrols, surface water controls, and multimedia monitoring will be implemented, and the
current provision of an alternate water supply will be continued. The estimated present
worth cost of this remedial action is $62,904,655, which includes an annual O&M cost of
$1,300,000.
-------
RECORD OF DECISION AMENDMENT
HARDAGE/CRINER SITE
McCLAIN COUNTY, OKLAHOMA
NOVEMBER 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 6, DALLAS, TEXAS
-------
DECLARATION
FOR THE
RECORD OF DECISION AMENDMENT
SITE NAME AND LOCATION
Hardage/Criner
McClain County, Oklahoma
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the
Hardage/Criner site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as
amended hy the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
This decision is based on the contents of the administrative record for the
Hardage/Criner site. The attached index (Appendix C) identifies the items
which comprise the administrative record upon which the decision to amend
the 1986 Record of Decision (ROD), and the selection of the modified remedial
action is based.
The State of Oklahoma supports a number of the components of the amendment
but has not concurred with all elements of the selected remedial action.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not
addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The 1989 proposed remedy is a comprehensive site remedy addressing both
Source Control and Groundwater operable units at the Hardage/Criner site.
It involves a modification of the 1986 ROD for Source Control, and
incorporates new Groundwater response actions. The major components of
this remedial action consist of the following source control and ground-
water components:
SOURCE CONTROL
the installation of liquid extraction wells in three main source
areas to pump out free liquids current y pooled in these areas and
any liquids released from drums buried in the mounds. The liquids
would he collected and shipped offsite for treatment, thereby
permanently reducing the volume of haz 'dous substances in the
source areas and the potential for the r migration.
-------
excavation as per the 1986 ROD for the direct removal of drummed
liquids in the Barrel Mound and Main Pit. Drum excavation and
liquids removal would reduce the volume of hazardous liquids within
the source areas during the early phases of remedy implementation,
thereby reducing the reliance on long-term active controls otherwise
necessary to address the continued release and migration of hazardous
liquids, many of which are highly toxic, resulting from gradual and
difficult to predict corrosion of drums.
excavation of contaminated soils in areas adjacent to the three
main source areas and transport to the source areas. These materials
would be consolidated under a temporary cap in the main source areas
where they would be treated using soil vapor extraction.
use of soil vapor extraction to draw air through the source areas
after consolidation to evaporate contaminants and permanently
remove them to the surface through air extraction wells. The air
would be treated to destroy the contaminants using the best available
control technology (BACT) by thermal destruction.
permanent source area capping once remediation activities are
complete. A temporary cap will be installed during remediation
activities, followed by a permanent RCRA-compliant cap at the end of
remediation.
GROUNDWATER
Groundwater components summarized below would be implemented in conjunction
with a substantial reduction of the contaminant source areas thereby reducing
the long-term potential contribution of the sources to groundwater.
o the installation of a V-shaped trench located downgradient (west,
south and east) of the three main source areas to intercept and
collect contaminated groundwater migrating in all bedrock zones
existing above Stratum IV. This trench would capture contaminated
groundwater onsite and near the source areas minimizing migration
of contaminants beyond the trench and into the alluvium of North
Criner Creek.
o the installation of an interceptor trench, or equally effective
system of extraction wells, in the southwestern part of the site to
contain contaminated groundwater moving into the alluvium from
bedrock zones above Stratum IV. This interceptor system would capture
migrating contaminants between the V-trench and alluvium of North
Criner Creek.
o the design and construction of an onsite ground rater treatment
system incorporating treatment processes to tre t both organic
and inorganic contaminants to surface water dis.iarge standards.
Collected groundwater would he pumped to the treatment unit, and the
treated water discharged to North Criner Creek.
11
-------
o alluvial groundwater restoration. Contaminants already present in
the alluvium would he allowed to dissipate hy natural dilution,
natural biodegradation and flushing. The interceptor trenches, in
conjunction with source control actions, would abate contaminant
migration into the alluvium of North Criner Creek and allow natural
restoration to Maximum Contaminant Levels to occur. If alluvial
monitoring reveals that estimated natural restoration times and
plume dilution rates are not being met, then active restoration
of the alluvium would be implemented. An increase in contaminant
concentrations in the alluvium after trench installation and pumping,
or a decline in the mass of contaminants of less than 40 percent in
10 years, will trigger active restoration in the alluvium.
In addition to the Source Control and Groundwater components listed above,
the comprehensive remedy calls for the following monitoring and support
components (further described in Section 6) which are necessary as part of
remedy implementation:
o institutional controls, including fencing, deed restrictions, and
maintenance of the availability of an alternate water supply system.
These will be implemented to restrict access to the site and
contaminated groundwater.
o surface water controls to collect surface water drainage from the
source areas during remedy implementation, and to divert
uncontaminated runoff away from the working area in order to
minimize the generation of contaminated groundwater.
o remedial monitoring to verify that the migration of contaminants
has been halted. This monitoring program includes monitoring of
surface water in North Criner Creek, monitoring of alluvial and
bedrock groundwater onsite and offsite, including downgradient of
the alluvial contamination plume, and monitoring of the performance
of the groundwater interceptor trenches (or wells if used in place
of the southwest interceptor trench) to determine their effectiveness
in containing and reducing contamination. The caps proposed as
part of the Source Control will be monitored for differential
settlement or erosion. Finally, air quality would be monitored
during implementation of the remedy both onsite and at the fenceline
boundary. Action levels will be set onsite to assure fiat Maximum
Ambient Air Concentrations are not exceeded at the fenceline.
m
-------
DECLARATION
The selected remedy, if implemented, is protective of human health and the
environment, attains Federal and State requirements that are applicable or
relevant and appropriate to this remedial action and is cost-effective.
This remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility or volume as a principal element
and utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable.
Because this remedy will result in hazardous substances remaining onsite
above health based levels, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
Robert E. Layton Ji^T, P.
l I*
Date
-------
HARDAGE/CRINER - RECORD OF DECISION AMENDMENT
TABLE OF CONTENTS
1.0 Site Location and Description
2.0 Site History and Enforcement Activities
2.1 Disposal Operations
2.2 Enforcement
2.3 Site Investigations
2.4 Highlights of Community Participation
3.0 Scope of Response Action
4.0 Site Characteristics
4.1 Site Conditions
4.1.1 Surface Water Hydrology
4.1.2 Site Geology
4.1.3 Groundwater Hydrology
4.2 Site Contamination
4.2.1 Impact of Disposal Operations
4.2.2 Remaining Contaminant Sources
4.2.3 Pathways and Extent of Contamination
4.2.4 Future Contaminant Migration
5.0 Site Risks
6.0 Description of Alternatives
6.1 Alternative Source Control Components
6.1.1 No Action
6.1.2 On-site Landfill (EPA 1986 ROD)
6.1.3 Containment of Wastes (HSC Proposal)
6.1.4 Incineration
6.1.5 Liquid Extraction Wells
6.1.6 In-Place Drum Lancing
6.1.7 Drum Excavation
6.1.8 Excavation of Wastes in Adjacent Areas
6.1.9 Soil Vapor Extraction and Treatment
6.1.10 Source Area Capping
6.2 Groundwater Remediation Objectives and Alternative
Groundwater Components
6.2.1 U-shaped Trench
6.2.2 V-shaped Trench
6.2.3 Southwest Interceptor Trench
6.2.4 Groundwater Treatment System
6.2.5 Alluvial Groundwater Restoration
6.3 Monitoring and Support Components
6.3.1 Remedial Support Facilities
6.3.2 Institutional Controls
6.3.3 Surface Water Controls
6.3.4 Remedial Monitoring
-------
6.4 Comprehensive Alternatives
-6.4.1 Common Elements
6.4.2 Revised EPA Remedy
6.4.3 Partially Revised EPA Remedy
6.4.4 HSC Remedy
700 Comparative Analysis of Alternatives
7.1 Overall Protection of Human Health and the Environment
7.2 Compliance with Applicable or Relevant and Appropriate Requirements
7.3 Long-term Effectiveness and Permanence
7.4 Reduction of Toxicity, Mobility, or Volume
7.5 Short-term Effectiveness
7.6 Implementabilit-y
7.7 Cost
7.8 State and Community Acceptance
8«0 Selected Remedy Description
8.1 Remediation Goals
9.0 Statutory Determinations
9.1 Protection of Human Health and the Environment
9.2 Compliance with ARARs
9.3 Cost Effectiveness
9.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies
9.5 Preference for Treatment as a Principal Element
9.6 Documentation of Significant Changes
REFERENCES
APPENDICES
A. Evaluation of Applicable or Relevant and Appropriate Requirements
B. Agency for Toxic Substances and Disease Registry (ATSDR)/Center for
Disease Control (CDC) Evaluation
C. Administrative Record Index
D. State of Oklahoma Correspondence
E. Responsiveness Summary
F. 1986 Source Control Record of Decision
G. Detailed Cost Evaluation of the Selected Remedy
-------
LIST OF FIGURES
1-1. Vicinity Map
1-2. Site and Disposal Operations Map
4-1. North Criner Creek Drainage Basin Map
4-2. Surface Water Hydrology
4-3. Geologic Cross-Section
4-4. Hydrogeologic Cross-Section
4-5. Main Pit and Barrel Mound Pit Cross-Section
4-6. Approximate Extent of Groundwater Contamination
4-7. Distribution of Total Volatile Organics in Stratum III
and the Alluvium
6-1. Conceptual Drum Lancing Diagram
6-2. Areas Targeted for Drum Excavation
6-3. Schematic of Soil Vapor Extraction
6-4. Final Source Area Cap
6-5. Alternative C Site Schematic, Second Operable Unit
Feasibility Study
6-6. Alternative E Site Schematic, Second Operable Unit
Feasibility Study
6-7. Site Cross-Section Showing Trenches
8-1. Schematic of Selected Remedy
LIST OF TABLES
2-1. Summary of Drummed Wastes from Manifests
4-1. Carcinogens Detected in the Source Area Characterization
Holes
4-2. Comparison of Groundwater Data with MCLs.
6-1. Summary of Alternative Elements, Second Operable Unit
Feasibility Study
6-2. Comparison of Alternatives
7-1. Comparison Summary According to Statutory Criteria
7-2. Drum Excavations Performed at Other Sites
8-1. Cost of Selected Remedy
-------
1-1
1.0 SITE LOCATION AND DESCRIPTION
The Hardage site is located in a rural area of McClain County in central
Oklahoma, approximately 25 miles south-southwest of Oklahoma City
(Figure 1-1). The site is hounded on the South by old Oklahoma State
Highway 122, on the north by open farmland, on the west by a gravel (County)
road, and on the east by a series of three small ponds (Figure 1-2).
The Hardage site was operated from 1972 to 1980 under a permit issued by the
Oklahoma State Department of Health (OSDH) for the disposal of industrial
wastes. In 1983, EPA placed the site on the "National Priorities List"
(48 Fed. Reg. 40658) for response under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). EPA has taken
the lead in response to this site. OSDH has provided technical support and
advice to EPA, particularly in the early stages of work on the site, and
has been consulted on remedy selection.
As a result of waste disposal practices at the site, chemicals have migrated
vertically and laterally resulting in the contamination of approximately
70 acres of groundwater beneath and adjacent to the site as well as several
acres of surface soil in the immediate vicinity of the main disposal areas.
The principal source of contamination is some 278,000 cubic yards of
sludges, waste drums, highly contaminated soils, and waste liquids contained
in three waste areas near the center of the property.
The disposal areas at the site were a number of permanent and temporary
impoundments into which a variety of liquid, sludge, and solid wastes were
disposed and mixed. These areas, described more fully in Section 2.1, were
primarily the Main Pit, Sludge Mound, and Barrel Mound, and in addition the
North Pit, West (mixing) Ponds, and East (mixing) Ponds (see Figure 1-2).
During 1980 - 1981 the operator consolidated wastes into the Main Pit,
Barrel Mound, and Sludge Mound and capped those areas with two to three
feet of local soil in an effort to permanently close the site. Closure
efforts failed, however, to prevent the migration of hazardous substances
vertically and laterally into groundwater from the impoundments. More
specifically, dense non-aqueous phase liquids have pooled beneath the Main
Pit, Barrel Mound and to some extent the Sludge Mound and now serve as a
continuing source of contamination to the groundwater. Volatile organic
compounds, many of them known or suspected carcinogens, have migrated
from these areas offsite into the alluvium of North Griner Creek, forming a
plume of contamination extending a distance of about 2800 feet southwest of
the Main Pit. Total concentrations of volatile organic compounds in the
plume exceed 25,000 ppb near the source areas and decrease systematically
away from the source areas, with concentrations as high as a few hundred
ppb more than 2500 feet away from the Main Pit to the southwest. Volatile
organic compounds are entering North Criner Creek at sufficient quantities
to cause detectable concentrations in surface water in the Creek.
Present and near-term risks are related primarily to groundwater resources
and any individuals who might use the contaminated groundwater. Over the
long-term, risks will also he posed due to erosion of wastes and their
gradual surface and subsurface migration across and from the site.
-------
SCALE IN MILES
OKLAHOMA
oClTY
•PROJECT
SITE
STATE OF OKLAHOMA
HARDAGE INDUSTRIAL
WASTE SITE
REMEDY COMPARISON REPORT
VICINITY MAP
-------
NORTH PIT AREA
NORTHWEST
FARM
POND
*>EAST
'I POND
-' I AREA
WEST
POND AREA
INTERCEPTOR SLUDGE
TRENCHMOUND
HOMESTEAD
OLD STATE HIGHWAY 122
(COJNTY ROAD)
NORTH
CRINER
CREEK
FIGURE 1-2
SITE AND DISPOSAL OPERATIONS MAP
HARDAGE INDUSTRIAL WASTE SITE
REMEDY REPORT
GENERAL AREA OF WASTE EXCAVATION
-------
2-1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Disposal Operations
In 1972 the site owner and operator Royal Hardage, received a permit from
the Oklahoma State Department of Health (OSDH) to operate a hazardous and
industrial waste landfill at the site. This permit was based on an
application by Mr. Hardage that consisted of a general outline of planned
operations and limj'ted subsurface boring data on site geology.
From September 1972 until November 1980 the site accepted approximately 21
million gallons of hazardous and industrial wastes including paint sludges
and solids, ink solvents, tire manufacturing wastes, oils and solvents such
trichloroethene, corrosives, plating wastes sludges, cyanides, and caustic
wastes, many of which are now regulated as hazardous waste under the Resource
Conservation and Recovery Act (RCRA). The liquid portion of this waste was
initially discharged into the Main Pit. Early in the operation, problems
began to occur due to slower than expected evaporation of wastes. To deal
with this problem, the operator began spraying liquids over the Main Pit to
enhance evaporation and also drained some of the liquids into adjacent
temporary mixing ponds for hulking with soil. The soil/waste mixture was
disposed in a new area called the Sludge Mound. Sludge waste, including
residue from oil recycling and styrene tar production, and some drums of
solid material, were also disposed in the Sludge Mound.
In addition to the bulk waste liquids disposal described above, drums of
waste were also received at the site. These waste drums were initially
opened and dumped into the Main Pit. This practice, however, became less
common after about 1974. During most of the operations, drums were dumped
off trucks into two areas, the west side of the Main Pit and the Barrel
Mound. The Barrel Mound area adjoins the north end of the Main Pit and
was built to a height of 25 to 30 feet by trucks dumping drums off of the
south side of the mound, filling soil over and around the drums, and dumping
of additional drums onto the previously dumped drums. Many of the drums at
the site were carelessly dumped into the pits, without any attempt to avoid
rupturing. Some drums were rolled off trucks down the face of the Barrel
Mound. Other drums dumped into the pits were not sealed to begin with.
As a result, a substantial number of these drums spilled or broke
open during the disposal operation resulting in the direct release of large
volumes of hazardous and carcinogenic chemicals into soils and eventually
groundwater. Many of the drums, however, were disposed intact, as shown
by accounts of the site operation (Hardage, 1987). Moreover, intact drums
were excavated and removed from the site during exploratory excavations in
1988 (EPA, 1988). A summary of drummed wastes brought to the site (from
manifests) is presented in Table 2-1.
In addition to disposal practices in the source areas (Barrel Mound, Main
Pit, and Sludge Mound) waste mixing and transfer operations were conducted
over much of the site in areas known as the North Pit, East Pond area, and
West Pond area. The disposal areas and site activities described above are
illustrated in Figure 1-2.
-------
Table 2-1
SUMMARY OF DRUMMED WASTES FROM MANIFESTS
No. of Estimated
Containers Volume Received(1)
Waste Category Received (gallons)
Paint
Sludge 5,897 324,047
Paints and Related Wastes 1,044 57,420
Solids - - - 451 24,805
Mixed Wastes
Mixed Wastes 2,557 138,600
Tire Manufacturing Wastes
(Carbon Black, Soap,
Oil, Solvents, Rubber} 1,405 77,275
Soap, Oil, Solvents 304 16,720
Acid
Rinse Water 1,867 102,685
Sulfuric Acid 880 48,400
Sludges 676 37,180
Acids 341 18,755
Chromic Acid 248 13,565
Nitric Acid 194 10,670
Acids and solvents 31 1,705
Muriatic Acid 13 715
Acrylic Acid 12 660
Hydrofluoric 4 220
Oils and Solvents (TCE,
Stoddard) 3,253 177,815
Asbestos 1,345 73,975
Oil
Oils 660 36,300
Sludge 132 5,790
Alumina Silica Slurry 747 41,085
Ink
Inks 520 30,425
Solvent 57 3,135
Sludge 47 2,585
Caustic 580 31,900
CVOR211/033.50/1
-------
Waste Category
Table 2-1
(continued)
No. of
Containers
Received
Cupric Ammonium Persulfate
and Toxic Tin
Corrosive
MDI (methylene bisphenyl
isocyanate)
Plastic Wastes
Aromatic Residue
Chemical Wastes
Plating Waste Sludge
Cyanide (Copper, Potassium,
Sodium)
Shopwaste
Nitric Alumina
Glue
Alumina Oxide
Filter Cake
Methanol
Sediment Pit Waste
Zinc, Arsenic
PCBs
Laboratory Chemical Packs
(Phosgene Gas Canister,
Reagents, Waste Chemicals)
Toxaphene
Estimated
Volume Received(l)
(gallons)
435
357
299
261
232
229
214
142
111
91
84
80
80
80
62
33
29
27
145
23,925
19,635
16,325
14,355
12,760
12,595
11,770
7,760
6,105
5,005
4,620
4,400
4,400
4,400
3,410
1,782
1,595
1,385
1,375
CVOR211/033.50/2
-------
Waste Category
Polyacrylamide
Sand Filter Sludge
Ammonium Bifloride
Selenium
Emulsion
Trichloroethene and Aluminum
Chromium
Waste Chlorides
Insecticides
Salt Sludge
Ammonium Hydroxide
Chlorine
Sodium Lead Alloy
2,4-Dinitrophenyl Hydrazine
Pesticide with Arsenic
Vaccine
TOTAL
Table 2-1
(continued;
No. of
Containers
Received
14
11
8
8
6
63
20
142
3
2
55
1
1
1
1
1
25,593
Estimated
Volume Received(l)
(gallons)
770
605
440
440
330
315
300
142
165
110
55
55
28
1,437,809
(1) Unless indicated on manifest, Hardage (1972-1980)
containers were assumed to be 55-gallon drums. All
containers were assumed to be full.
CVOR211/033.50/3
-------
2-5
2.2 Enforcement
In 1979, OSDH and EPA inspections and sampling of the site indicated waste
management-practices were posing potential threats to public health and the
environment. In September 1980, the United States, on behalf of EPA, filed
a complaint in the U.S. District Court for the Western District of Oklahoma.
The complaint sought injunctive relief under Section 7003 of RCRA for the
proper cleanup and closure of the site. The facility ceased operations in
early November 1980, before Interim Status Standards under the RCRA came
into effect.
In 1982, United States amended the existing complaint against the facility
owner and operator Royal Hardage, to request relief under Sections 106 and
107 of the CERCLA. In December 1982, the Court found that the site posed
an "imminent and substantial endangerment to public health and welfare and
the-environment" as defined by CERCLA Section 106 and RCRA Section 7003.
In August 1983, the Court granted a partial judgment for over $211,000 in
response costs, which EPA had incurred through 1982, against Royal Hardage.
Hardage filed for bankruptcy in 1983 and again in 1985, and EPA has to date
not recovered its partial judgment.
In December 1984, EPA mailed letters to 289 Potentially Responsible Parties
(PRPs) requesting information about their waste disposal at the Hardage
site under authority of Section 104(e) of CERCLA and Section 3007 of RCRA
and notifying the PRPs of their potential liability for site cleanup. As
further information was gained, information request and notice letters were
sent to additional PRPs identified. At the present time, over 400 PRPs
have been identified. Various PRPs have gone out of business or cannot be
located; therefore, approximately 340 have been contacted. A group of
these parties organized into the Hardage Steering Committee (HSC) and met
with EPA and OSDH on numerous occasions concerning the site. Initial
meetings with the HSC were held in January of 1985.
In May 1985, EPA released a report entitled Field Investigation and Data
Summary Report (DSR) for the Royal Hardage Waste Disposal Site (EPA, 1985)
documenting investigations conducted in 1984 and earlier. This document
served as a remedial investigation (RI) report for the site.
After completion of the DSR, EPA determined that sufficient data were
available to develop a remedy for the contaminant source areas, but that
the information was inadequate to develop remedial alternatives for the
contaminants that had already migrated from the source areas into ground-
water. Accordingly, selection of a comprehensive alternative for a complete
remedial action, addressing surface and subsurface contamination beyond the
source areas, was not possible at that time. The need for control of the
source areas at the site prompted EPA to consider alternatives that would
reduce or eliminate the spread of contaminants off the site. Therefore,
-------
2-6
EPA decided, in accordance with Section 300.68(c) of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), to divide the
remedial process of the site into two operable units: 1) Source Control and
2) Management of Migration (groundwater).
During 1985, EPA began preparing a Feasibility Study (FS) for the Source
Control Operable Unit primarily addressing the three principal waste source
areas: the Main Pit, the Barrel Mound and the Sludge Mound.
EPA's FS, entitled Feasibility Study - Source Control - Royal Hardage
Industrial Waste Site Nea.r Criner. Oklahoma (EPA. 1986a). presented the
methodology used to develop several remedial action alternatives for the
Source Control Operable Unit. The alternatives, further discussed in
Section 6, were evaluated in accordance with the NCP, and four alternatives
were developed in detail. These four alternatives included onsite waste
stabilization with disposal in a RCRA-compliant landfill, onsite incineration
and disposal, offsite incineration and disposal, and onsite waste stabiliz-
ation and disposal in an offsite RCRA-compliant landfill.
In November 1986, EPA issued its Record of Decision (ROD) outlining the
selected final remedy for the Source Control Operable Unit (see Appendix
F). This remedy was selected in a manner consistent with CERCLA, as amended,
and the NCP as the most appropriate remedy for source control considering
all relevant selection criteria. The selected remedy consisted of excavating,
treating, and disposing of solids in a RCRA-compliant onsite landfill;
removal and offsite incineration of free organic liquids; and the onsite
treatment and disposal of other water-based liquid wastes. After potentially
responsible parties declined to implement the selected remedy, EPA subse-
quently initiated the remedial design process with the design-related field
activities. The detailed design was presented in EPA's Design Report - Source
Control Remedial Design - Hardage Industrial Waste Site - Criner Oklahoma
(EPA, 1988).
Prior to EPA's 1986 ROD, additional field studies were initiated by the
HSC. This work involved the gathering of geologic and hydrologic data at
the Hardage site to assess an in-place containment remedy later proposed by
the HSC. As a result of this work, the HSC submitted the Final
Confirmatory Bedrock Study in December of 1986 (HSC 1986). As a part of
the EPA's public comment process for the ROD, the HSC's report also briefly
presented the the HSC's proposed source cortrol remedy. The HSC remedy
ca'led for in-place containment of the waste source areas by a cut-off
wa 1 supplemented by groundwater pumping. Differences between the HSC and
EPA source control proposals were not resolved and resulted in litigation
ov^r implementation of the selected remedy. Work by the HSC in support of
tl- ir proposed remedy continued at the site through November 1, 1988.
Ac itional characterization of the source areas was conducted and
-------
2-7
reported in the HSC's Mound Characterization Field Study (HSC, 1988). From
these and.other studies performed as a part of the HSC's litigation efforts,
the HSC prepared a Recommended Source Control Remedy design report (HSC,
1988) which provided additional technical details of the HSC's proposed
remedy.
Meanwhile, in July 1985 the Court administratively closed the 1980 case
against Hardage, providing that the U.S. could re-open the case for the
purpose of seeking appropriate relief until April 1, 1986, at which time
the case would otherwise he dismissed. The United States, on behalf of
EPA, filed a motion on March 27, 1986, to amend the existing complaint and
add newly discovered generators and transporters to the existing case. The
Court ultimately denied the motion and dismissed the case. On June 25,
1986, the United States filed a new complaint naming 36 generators and
transporters of waste at the site. The complaint asked for performance of
the EPA selected source control remedy, maintenance of site security, conduct
of a RI/FS for the management of migration (groundwater) operable unit,
implementation of the groundwater operable unit remedy to be selected by
EPA, and recovery of EPA's past and future response costs.
In 1987 the District Court issued a ruling indicating that the case would
be decided in a "de-novo" trial, as opposed to a trial on the Administrative
Record. The Court, in issuing that ruling, cited two factors peculiar to
the case. First, the case was filed prior to the enactment of the Superfund
Amendments and Reauthorization Act of 1986 (SARA), which called for Admin-
istrative Record review at trial. Second, the case was filed under RCRA as
well as CERCLA; and RCRA does not mandate an Administrative Record trial.
After lengthy negotiations, a Partial Consent Decree between EPA and HSC
was entered by the Court in February 1988. Under this Decree, HSC agreed
to conduct a RI/FS addressing management of contaminant migration at the
site under EPA oversight. The second operable unit RI/FS, and Endangement
Assessment reports were submitted to EPA in the spring of 1989, finalized
and sent to repositories in October of 1989.
Throughout 1988 both EPA and HSC took extensive depositions of both fact
and expert witnesses. In early 1989, the Government initiated meetings
with HSC to discuss ways of resolving on-going litigation.
On April 7, 1989 a Consent Decree was lodged with the U.S. District Court
between EPA and approximately 170 "de minimis" (small quantity) PRPs for
the site. Under this agreement, the de minimis parties resolved their
liability for the site by making two cash payments: one to EPA to cover
past cost incurred, and a second to a trust fund to be supervised by the
District Court. The trust fund will be used for site remediation. This
Consent Decree was entered by the court on September 22, 1989. The
de minimi agreement was prepared in accordance with EPA's Interim Guidance
on Settle, ^nt with De Minimis Waste Contributors under Section 122(g) of
SARA (Junt 19. 1987) 52 Fed. Reg. 24333 (June 30. 1987).
-------
2-8
2.3 Site Investigations
Studies o£ the Hardage site have been conducted since 1982. These studies,
some of which were mentioned in Section 2.2, are part of EPA's administrative
record for the site, and are described below:
March 1982
Ecology and Environment (E&E), an EPA contractor, sampled surface soils,
drainage ways, and existing wells at the site. E&E also installed and
sampled ten monitoring wells on and around the site. These wells are
designated EW-1 through EW-10. This investigation is documented in a
May 7, 1982 letter report from Imre Sekelyhidi of E&E.
August 1984
EPA contractor CH2M Hill'and its subcontractors Chen Associates, Wright
Water Associates, and Davenport-Hadley conducted a site investigation in
1984 to supplement the 1982 E&E data and allow selection by EPA of a source
control remedy. This investigation involved installation and sampling of
monitoring wells (the "GTW", "BW", "PW", and "AW" series of wells), limited
coring of bedrock, sampling of the source areas, and sampling of shallow
test pits. This investigation is documented in the the May 1985 report
"Field Investigation and Data Summary Report" (DSR) prepared by CH2M Hill.
July - November 1986
HSC contractor ERM-Southwest conducted an investigation centering on
conditions of the bedrock in the immediate vicinity of the source areas.
This investigation included installation of monitoring wells and well nests
MW-1 through MW-11, sampling of the shallow wells, resampling of some
existing wells, and drilling vertical and slanted test borings 8-1 through
B-13 and SB-1 through SB-7. This investigation is documented in the December
1986 report "Confirmatory Bedrock Study" prepared by ERM-Southwest.
May 1987
E&E, on behalf of EPA, collected samples from all monitoring wells at the
site. This work was monitored, and split samples collected by ERM-Southwest
on behalf of HSC. HSC also recorded all work under the six week long project
on videotape. The results of their sampling are documented in an August 31,
1987 letter repc t from E&E and in the Management of Migration RI.
October 1987 and March 1988
ERM-Southwest, c behalf of HSC, drilled fourteen cores MB-1 through MB-14
into the waste «-jrce areas for chemical sampling and observation of physical
conditions. Thi activity is documented in the HSC's "Mound Characterization
Field Study" prepared by ERM-Southwest in November of 1988.
-------
2-9
January - April 1988
ERM-Southwest, acting as litigation consultants on behalf of HSC, conducted
a variety of activities on the site, including drilling of deep core holes
(the "DH" holes), drilling of slant cores, photo-linear analysis, geophysical
logging, reflection and cross-hole geophysics, radioisotope dating, and
sampling of chloride for geochemical modeling. This activity is documented
in the November 1988 report "Hydrogeologic Issues of Relevance to the
Hardage Site" prepared by S.S. Papadopulos Associates.
April 1988 - October 1988
CHgM Hill and its subcontractor Chen Associates, acting on behalf of EPA,
drilled eight bore holes into the source areas to retrieve samples for
geotechnical and stabilization testing and to provide data on air emission
of VOCs. Two test pits were also excavated to provide further data on air
emmissions and on integrity of the buried steel drums. This activity is
documented in the November 1988 report "Source Control Remedial Design"
prepared by CH2M Hill.
July - October 1988
ERM-Southwest, on behalf of HSC and working under EPA oversight, conducted
a comprehensive investigation of the extent of contamination and physical
conditions at the site relative to migration of contaminants. This activity
is documented in the May 1989 draft report "Second Operable Unit Remedial
Investigation" (also refered to as the Management of Migration RI or
Groundwater RI). ERM-Southwest also prepared and submitted to EPA a May
1989 draft "Second Operable Unit Feasibility Study Report" (or Groundwater
FS). Both of these reports underwent revision based on EPA comment, were
then approved by EPA and sent to repositories in October of 1989. HSC
provided replacement pages to EPA during the public comment period which
are addressed in the responsiveness summary in Appendix E.
2.4 Highlights of Community Participation
In preparation for this ROD amendment, EPA held a public comment period on
the proposed comprehensive remedy. The comment period began October 13,
1989, and closed November 2, 1989. EPA provided notice of the public comment
period through announcement in the newspaper on October 1, 1989, and at
that time announced a public meeting on the proposed remedy. A fact sheet
was prepared by EPA summarizing alternatives for both source control and
groundwater and was sent to repositories and addressees on the site mailing
list on October 12, 1989. EPA's Remedy Comparison Report and Remedy Report,
along with the Administrative Record, were also sent to repositories on this
date. A public meeting on the proposed remedy for the site was held on
October 26, 1989, and approximately 40 people were in attendance.
EPA has addressed questions received during the public comment period,
includi g those received at the public meeting, in the responsiveness
summary 'Appendix E).
-------
3-1
3.0 SCOPE OF RESPONSE ACTION A
The proposed remedy would address both the Source Control and Groundwater
(Management of Migration) aspects of the Hardage site in a comprehensive
remedial action. This proposed comprehensive remedy would remove a
substantial portion of the liquid wastes, including many highly toxic and
mobile volatile organic compounds, from source areas, thereby reducing the
volume, toxicity, and mobility of the hazardous substances at the site.
Moreover, this proposed comprehensive remedy would prevent further
contamination of the alluvial aquifer.
To date the site has been investigated as two "operable units" - Source
Control and Management of Migration or Groundwater. This approach was
adopted in 1985 in an effort to speed remediation of the site. On November
14, 1986, EPA issued a ROD for the Source Control Operable Unit. This ROD
selected a remedy, as previously discussed in Section 2.2, consisting of
waste excavation and segregation followed by incineration of organic liquids
and stabilization and consolidation of solids into a new landfill to be
constructed on the site. Protracted litigation from 1986 through 1989
delayed implementation of the selected source control remedy.
In 1987 HSC agreed, pursuant to a partial Consent Decree with EPA, to conduct
a RI/FS for the Groundwater Operable Unit of the site. Field studies were
conducted in 1988 and a draft FS report was completed in May 1989 evaluating
several remedial alternatives for groundwater at the site. It was proposed
that any groundwater actions would be implemented in conjunction with a
Source Control remedy.
Subsequent to the completion of EPA's Remedial Design Report, an issue
arose concerning the potential impact of the RCRA land disposal
restrictions on certain elements of the Source Control remedy selected in
the 1986 ROD. The Agency's interpretation of the applicability of the land
disposal restrictions to CERCLA response actions was then still evolving.
Due to uncertainties over the ultimate resolution of this issue, EPA began
to consider other alternatives for the Source Control remedy, which could
unquestionably be implemented consistent with the RCRA requirements.
Because of the timing of the draft Groundwater FS, and the concurrent evaluation
of new Source Control technologies, EPA found it efficient and logical to
combine Groundwater and Source Control alternatives in order to develop
remedial alternatives that would address the entire site. As a result, a
number of comprehensive remedial alternatives were assembled from source
control and groundwater operable unit alternatives. Comprehensive alternatives
are addressed in Section 6.4 and involve amendments to the 1986 ROD for
source control and the selection of a remedial response actions for contam-
inated groundwater. One of those alternatives is presented as the selected
comprehensive -emedy for the site (see Section 7 for remedy selection criteria).
-------
3-2
The proposed remedy would remove a substantial portion of the liquid wastes
from the source areas. The Barrel Mound, and those portions of the Main
Pit believed to contain drums, would he excavated. Containerized liquids,
and free-phase liquids in the source areas, would be removed for offsite
destruction. In addition, a relatively new technology, in-situ soil vapor
extraction, would be implemented in the source areas to reduce those
compounds most mobile in the environment. Soil vapor extraction would be
effective in removing volatile and semi-volatile compounds, a number of which
are carcinogenic, from the vadose zone, and from the surface of free-phase
liquids in the source areas.
The proposed remedy would also prevent further contamination of the
alluvial aquifer associated with North Criner Creek. Groundwater
interceptor trenches (or possibly interceptor wells in the alluvial
recovery area) would be installed to arrest migration of the plume of
contamination from the site, and thereby allow the gradual process of
restoration in the bedrock and alluvial systems to begin. Groundwater
monitoring, institutional controls, and controls on the use of groundwater
and surface water would be implemented to assure that humans are not
exposed to contaminants.
-------
4-1
4.0 SITE CHARACTERISTICS
4.1 Site Conditions
The Hardage site is situated on gently rolling property in a rural area of
South Central Oklahoma. The principal disposal operations were conducted
along a north-south trending ridge at the center of the property. Relief
is about 100 feet from the ridge to the adjacent stream valley. The site
is hounded on the southwest by the floodplain of a small perennial stream,
and on the east by a series of three small ponds. Soil cover on the site
is thin and subject to erosion. The underlying bedrock consists of a series
of interbedded sandstones, siltstones, and mudstone. These rocks are
fractured, as is well documented in various published studies including
observation of cores, rock outcrops, and geophysical logs of borings.
The waste remaining onsite is primarily located in three source areas, the
Main Pit, Barrel Mound and Sludge Mound. These three source areas will
continue to release contaminants into the environment primarily via ground-
water flow. At present, a groundwater plume of volatile organic contamination
extends some 2800 feet southwest of the Main Pit with concentrations of
volatile organic compounds exceeding 25,000 ppb. The plume ranges in width
from about 1800 feet near the source areas to about 800 feet in the southwest
corner of the site (see Section 4.2.3, Figure 4-6). Contaminants have
migrated vertically and laterally from the source areas into the surround-
ing and underlying bedrock, both in dissolved form and as non-aqueous phase
liquids (NAPL). The present and future migration of contaminants will
continue via groundwater flow. Eventually, erosion may also carry wastes
off the site from the three source areas and adjacent mixing areas.
4.1.1 Surface Water Hydrology
The site is situated in the North Criner Creek drainage basin, approximately
0.8 miles from the confluence of North Criner Creek and Criner Creek (Figure
4-1). The drainage basin drains approximately 5,000 acres, and extends about
four miles north of the site to the regional drainage divide between the
Washita and Canadian rivers. The site, as stated above, is disected by a
north-south trending ridge which controls runoff from the site (see Figure
4-2). Runoff from the western side of the site eventually enters a perennial
stream, North Criner Creek, west and southwest of the site. Runoff from
the east side of the site enters a series of three small ponds (the East
Farm Ponds). These ponds drain southward through a fourth pond located on
adjacent property before entering North Criner Creek south of the site.
Drainage from the east side of the site is diverted from the east farm
ponds by a berm and enters th~ stream below the southern most pond.
Drainage on the west side of the site from the source areas and much of the
former operation area is channeled around an interceptor trench constructed
by Royal Hardage to an impou' lent known as the South Pond at the southwest
corner of the site. The sout , pond is constructed such that an open discharge
-------
AREA - 575 ACHES
OUTLINE
NORTH CRIME
CREEK
WATER SHED
RECTIFIED
CHANNEL
SECTION
NOTES
1 NORTH CRMER CREEK WATERSHED AREA - MOO ACRES.'
2 RECTFCD NORTH CRMR CREEK CHANNEL SECTION
SOUTHWEST OF SITE COMPETED PRIOR TO If 41
1 SOL CONSERVATION SERVICE RETAMNG POND ft
AREA - 2*02 ACRES
SOL CONSERVATION SERVICE RETANNG POND
flfc* - 575 ACRES
»3
SOURCE QUADRANGLE. COLE. OKLAHOMA H35OO W»7Mf7 5
SCALE
toe
1DMS
• 0 NO
7661M70
NORTH
CM«r.
FIGURE 4-1
-------
o
33
o
b
r5
-------
4-4
pipe near its base releases water to flow south into a roadside ditch.
An unknown fraction of this water infiltrates downward from the pond. Runoff
from the westernmost portion of the site is diverted around the south pond
and enters-the roadside ditch directly.
The southwest corner of the site abuts the North Criner Creek flood
plain. North Criner Creek is a perennial stream with a nominal discharge
of 0.8 to 1.3 cfs. The stream has been channelized directly south of
the site.
The principal ponds, streams, and surface flow divides and paths
are shown on Figure 4-2.
4.1.2 Site Geology
Bedrock beneath the site consists of a sequence of Permian aged sediments
which grade from sandstone to siltstone, and mudstone. Despite the gradi-
tional nature of these deposits, extensive core samples have illustrated
lateral continuity of four shallow bedrock zones refered to as Stratum I
through IV. Bedding dips at outcrop locations near the site are less than
one degree to the west and southwest.
Bedrock immediately beneath the Main Pit and Barrel Mound is comprised of a
thin sequence of sandstone and siltstone (Stratum I). Approximately twenty
feet beneath the Main Pit begins a sequence of mudstone/siltstone (Stratum
II) approximately 20 feet thick. Beneath this is a sandstone/siltstone
sequence (Stratum III) which is about 30 feet thick. Underlying Stratum
III is a thick sequence of low permeability siltstone and mudstone, the
upper 20 feet of which exhibits a predominance of siltstone. This bedrock
sequence is illustrated in the generalized geologic cross-section shown in
Figure 4-3. Bedrock over the entire site has been subject to natural
weathering processes. As a result, the upper 20 to 40 feet of bedrock has
been appreciably altered.
Fracturing has been observed in the bedrock layers, both in surface outcrops
and in subsurface drill cores recovered from site investigations. Both low
angle (less than 10 degrees from horizontal) and high angle (40 degrees on
up to vertical) fractures have been reported. All three primary rock types
(sandstones, siltstones, and mudstones) have had fractures reported. In
addition, EPA believes that free-phase organic chenrcals released from the
source areas may have desiccated materials adjacent to fractures causing
further opening of the fractures. The irregularity and heterogeneity of
fracture distribution, interconnection and openness contribute to a relatively
high degree of uncertainty regarding the large-seal? hydraulic properties of
the bedrock strata at the site, and therefore, high uncertainty regarding
future waste migration rates and patterns.
Adjacent to the site, and associated with North Cri ar Creek, is an uncon-
solidated alluvial deposit with thicknesses up to f feet. Alluvial borings
completed during the second operable unit RI typicc ly encountered a thin
silt/clay zone at a depth of 10-15 feet, which in t rn was underlain by
medium to coarse-grained silty sands. Bedrock undf lying the alluvium was
found to be a fine-grained silty mudstone, with sor degree of weathering
immediately beneath the alluvium.
-------
BARRCL MOUND/
MAIN PIT-
1130
1100
10SO-
1000-
950-
HIGHWAY
SOUTH POND
900
SANDSTONE
^''^STRATUM II PREDOMINANTLYMUOSTONC
STRATUM III SANOS70NC, SLTSTONC
PKFDOUI,
SW
SCHEMATIC CROSS SECTION
NE
FIGURE 4-3
GEOLOGIC CROSS-SECTION
HARDAGE/CRINER SITE
•
-------
4-6
4.1.3 Groundwater Hydrology
The geologic units described above, given their fractured and weathered
conditions, have combined to form a hydrogeologic system as illustrated in
Figure 4-4. This figure illustrates the hydrogeologic units at the site:
(A) moderately permeable weathered shallow bedrock with general groundwater
flow to the southwest-into the alluvium of North Criner Creek (Stratum I-III
and the top of Stratum IV, especially in the vicinity of the southwest
alluvium); (B) a sequence of variably fractured siltstone and mudstone
(the lower portions of Stratum IV); and (C) the North Criner Creek alluvium,
a third hydrogeologic unit. The weathered zone and alluvial aquifer are
the most permeable units at the site and, consequently, are the units most
active in the local groundwater flow regime.
The water table across the site forms a continuous surface across Stratum
I, II, and III, and is roughly parallel to the land surface as shown in
Figure 4-4. The hydraulic conductivity reported for Stratum I through III
ranges from about 2 x 10~' cm/sec to about 1.5 x 10" . Flow in these
units has a large horizontal component with a gradient of about 0.01 to
0.07. Lower and higher hydraulic conductivities correspond to an estimated
average flow velocity of 18 to 180 feet per year, consistent with the known
distribution distances and patterns of contaminants in groundwater at the
site. Stratum II has a somewhat lower hydraulic conductivity than Stratum
I or III.
Groundwater flow in Stratum I-III in the vicinity of the east farm ponds
varies seasonally and is affected by surface water levels in the ponds and
recharge to soils. It is generally accepted that the ponds form a discharge
boundary for groundwater flow. However, monitoring during and after any
remedial action will be required to assure that contaminants are not migrating
eastward, beneath the ponds.
Alluvial deposits of North Criner Creek can be separated into upper and
lower portions that act as a single unit hydraulically. Nested monitoring
wells in the alluvium indicate a general upward gradient through these
deposits, implying upward flow out of Stratum IV into the alluvium. Pumping
tests indicated an overall effective permeability on the order of 5 x 10
cm/sec. Transmissivity values range greatly in the alluvium, however, the
overall transmissivity is about 3200 to 3500 gpd/ft. Effective porosity
ranges between 0.25 and 0.30.
Groundwater flow in the alluvium of North Criner Creek is generally toward
the Creek, though skewed down-valley. Contaminants detected in the alluvial
aquifer are also found in the source areas of the site. The concentration
of total volatile organic compounds (which include toxic substances such as
1,2-dichloroethene and trichloroethene) are several hundred ppb i at least
three alluvial aquifer wells. In general, North Criner Creek for- 3 the
discharge boundary to groundwater flow from the site, limiting mi -ation of
contaminants across the Creek.
-------
1130
900
BARREL MOUND/
MAIN PIT-
HIGHWAY 122
SOUTH POND
NORTH
CXIHER
A (Stratum I, II, III and upper
Stratum IV)
B (lower Stratum IV)
SCHEMATIC CROSS SECTION
FIGURE 4-4
HYDPOGEOLOGIC CROSS-SECTION
HARDAGE/CRINER SITE
-------
4-8
4.2 Site Contamination
During the site operations, approximately 21 million gallons of industrial
wastes including acidic, caustic and corrosive wastes, many classified as
carcinogenic, were disposed on the Hardage site. During and after the
operations, waste liquids migrated downward from several unlined impoundments,
principally the Main Pit, North Pit, and West Pond (mixing) areas and to a
lesser extent from the Sludge Mound, and East Pond (mixing) areas, and
random spills on the site. Presently, approximately 70 acres of groundwater
on and adjacent to the site is contaminated by organic compounds. Ground-
water contaminant plumes have migrated east and southwest of the site.
Contamination has entered the North Criner Creek alluvium, and has recently
had a low hut measurable impact on surface water quality (August 7, 1989
sampling). Surface and shallow subsurface soils at and around the source
areas are contaminated by.low levels of metals. Approximately 278,000
cubic yards of highly contaminated material exists in the Main Pit, Barrel Mound
and Sludge Mound which contains soil, sludge, waste liquid, and intact
drummed waste.
4.2.1 Impact of Disposal Operations
During operation of the site, several potential sources of groundwater
contamination existed. These were:
o Main pit/Barrel mound
o Sludge Mound
o North Pit
o West Pond (mixing) areas
o East Pond (mixing) areas
o Miscellaneous spills, drum leaks, etc.
o Contaminated runoff paths and south pond
Since liners were not constructed in any of these areas to limit waste
seepage, and since the permeability of the soil profile and shallow bedrock
is relatively uniform across the site, it is believed that those areas
where waste liquids were impounded for the longest periods of time
contributed most to groundwater contamination. The longer-term liquid
storage and disposal areas were the Main Pit, Barrel Mound, Sludge Mound,
West Pond, North Pit, and to some extent, the East Pond (see Figure 1-2).
The remaining areas contributed lesser amounts of contaminants to groundwater
contamination for reasons as follows:
o Miscellaneous Spills - these were due to the nature of operations.
Although drums were occasionally stored on site, the typical practice
was to immediately discharge or dump wastes into the pits upon receipt.
Therefore, spills probably did not release large volumes of waste liquids.
-------
4-9
o Runoff -.No information exists to indicate any impoundments were breached,
or liquid waste was directly released except for limited seeps. Rainfall
presumably contacted wastes, dissolving contaminants and carrying them down
slope from the source areas. However, the contaminants in runoff would be
highly dilute, as compared to that in waste pits. In addition, any
infiltration of runoff would be transient, as compared to the continuous
release from pooled waste liquids such as those in the main pit.
4.2.2 Remaining Contaminant Sources
In addition to contaminants which have dissolved into groundwater beneath
and adjacent to the site, .several potent "sources" exist which will tend to
release further contamination from the site. These sources are:
a) Main Pit/Barrel Mound
h) Sludge Mound;
c) Residual soil contamination in the North pit and immediately west of the
main pit; and
d) NAPL in bedrock beneath the source areas.
The content and character of these four sources is generally as follows:
a) Main Pit/Barrel Mound:
The Barrel Mound was built by random dumping of drums and the periodic
spreading of soil to allow further drum dumping. As a result, the
Barrel Mound is highly variable. Based on the history of disposal
operations and data from three exploratory borings done in 1988, the
mound consists of a two to three foot cover of native soils underlain by
randomly oriented drums mixed with soils and waste sludges. At a depth
of 5 to 10 feet, drilling yielded little data other than the depth to
liquids, due to minimal core recovery. The liquids present at the base
of the Barrel Mound appear to consist of a 6 inch layer of waste floating
on water (L-NAPL or light non-aqueous phase liquids); 4 feet of water;
and 4 feet of heavier than water wastes (D-NAPL or dense non-aqueous
phase liquids) on the bedrock surface (see schematic illustration,
Figure 4-5). The Barrel Mound would, due to the nature of its construc-
tion, be expected to have a large number of voids in and around drums.
This expectation was supported by difficulties encountered in closing
one boring (high grout take) and the inability to hail down waste liquid
levels in two other borings. The other significant finding in the barrel
mound borings was the apparent contamination of bedrock immediately
underlying wastes.
At its southern end, the Barrel Mound grades into the Main Pit. The
Main Pit is predominantly contaminated soil, however, concentrations of
drums similar to those found in the Barrel Mound are present in about
1/3 of the main pit, particularly along the west hank. Locallized pools
of waste, similar to that in the Barrel Mound, are likely to be present
in the Main Pit. While exploratory borings did not encounter such pooled
liquids, areas of drum concentrations, those areas where pooled liquids
would most likely be present, were intentionally avoided in drilling.
-------
-ion vauove MSL)
o
o
N)
o
•— c
• O.
PO fD
o o
-i c
3
CO
. ft,
U1 fD
• 3
O 0.
O) Ol
n ->-
T 3
CO
O!
01
en
03
o
O
O
tn w ^<
O o en
O o o
o o o
ua
o
3
(/I
Ol
_J
«t
o
3
t/>
<
at
CL
O
i/\
V
ro
N
O
3
ro
a* a, ai
•^ ^^ Md
o o o
333
«/> t« to
•o -•."<*
o 3 a>
0 Q.
— Q. 0
cn
0
c
ft
n
n
>
i-t
n
cu
CO
tw T I/I
CL c a>
3
— * on fvi
-• «_ o
-Q 3
«= fD
CL
01
H
<-(
(D
(B
•o
c
• ' ' : ,-, \ s
- 1 1 AS
- -i ... .;• A-
1 ••• :« - .- A
o a>
co i-i
ro i-t
co ro
i—'
O CO
3
o <»
>^i n
3-
CT ID
<~\ ro
>-h -a
O i-l
^ ro
CO
H- ro
H- 3
h-1 rr
C 01
CO rr
rt H.
1 O
flj a
z
•a
i—i
H
>
Z
O
CD
M
O
c
z
o
n
»
o
Crt
co
I
w
M
n
O
o
3
-------
4-11
Approximately 113,500 gallons of liquid are present in the soils of the
the Main Pit/Barrel Bound (vadose zone) which together total 3.62 acres.
An estimated 18,000 drums are buried in these areas representing some
660,000 gallons of stored liquids. (This assumes that two-thirds of the
drums may be full).
b) Sludge Mound:
The Sludge Mound consists of layers of contaminated soil, oil recycling
residues, and styrene tar wastes. Borings in the Sludge Mound indicated
pockets of moist "stringy" sludge in addition to the overall soils cont-
amination.
Approximately 58,000 gallons of liquid are present in the Sludge Mound
(totalling 1.72 acres) weakly held in soil pores under capillary forces.
c) Residual Soil Contamination:
The former North Pit is underlain by a number of pockets of contaminated
soils and 50 to 80 drums buried in shallow trenches. Sediment in the
drainage channel along the west side of the Main Pit has been heavily
contaminated by waste seepage from the Main Pit to a depth of five to
ten feet. Contaminated soils are also present in the west pond area.
d) NAPL in Bedrock:
Pure free-phase (NAPL) has been observed at three locations adjacent to
the source areas (B-13, MW-6, and MW-2). These wastes are present both
at the water table and in the deeper more competent sandstone (Stratum
III). The NAPL tends to be several thousand times as contaminated as
the surrounding groundwater. However, similar to an oil layer floating
on water, the separate phase waste cannot fully dissolve into the water.
In the subsurface, clean groundwater tends to pick up dissolved contaminants
as it flows around and through the NAPL. In this manner, the NAPL acts
as a potent source of continuing contamination within the normal ground-
water flow regime. Pockets at and beneath the water table are in a
position to readily contaminate the surrounding groundwater.
Liquid accumulations have created a pool of liquids at the bottom of the
main source areas estimated to he 956,000 gallons (see Figure 4-5).
The Main Pit, Barrel Mound and Sludge Mound are the largest sources of
potential further site contamination. Exploratory borings have indicated
that these areas consist of 278,000 cubic yards of wastes. Chemical sampling
has indicated that some 171,500 gallons (113,500 + 58,000) of volatile
chemicals are suspended in the soil vadose zone. Pooled liquids and intact
drums are estimated to total 1,616,000 gallons (660,000 + 956,000),
although precise quantification of the volume is not possible.
Table 4-1 lists a number of EPA classified carcinogens detected in the
source area characterization holes.
-------
Table 4.-1
CARCINOGENS1 DETECTED IN THE SOURCE
AREAS CHARACTERIZATION HOLES2
Compound Class
2,4,6-trichlorophenol 12
bis(2-chloroethyl)ether B2
1,4-dichlorobenzene B2
2,6-dinitrotoluene B2
1,2-diphenylhydrazine B2
isophorone C
N-nitrosodiphenylamine B2
bis(2-ethylhexyl)phthalate B2
butyl benzyl phthalate C
beno (a) anthracene B2
benzene A
1,2-dichloroethane B2
1,1,2,2-tetrachloroethane C
chloroform B2
1,1-dichloroethene C
methylene chloride B2
tetrachloroethene B2
trichloroethene B2
PCB-1260 B2
toxaphene B2
vinyl chloride A
1,1,2-trichloroethane C
EPA classifiedcarcinogens
Reference: USEPA, Health Effects Assessments Summary
Tables, Second Quarter, 1989.
2 Source USEPA (1985)
CVOR211/034.50/1 September 27, 1989
-------
4-13
4.2.3 Pathways and Extent of Contamination
Contaminants have been transported on and away from the site hy groundwater
flow. Additional contaminants have also migrated from the source areas hy
way of surface water runoff; however, sampling data from wells in the alluvial
aquifer indicate that groundwater flow, rather than surface water runoff,
has been the predominant pathway for migration. Groundwater containing
dissolved contaminants migrates vertically and southwestward toward the
North Criner Creek alluvium and then upward into the alluvium and into the
Creek.
Upward migration of groundwater from Stratum IV into the alluvium of North
Criner Creek is documented by upward gradients in water levels of wells
constructed at different depths in the alluvium. If contaminants are
entering the alluvium primarily from the underlying bedrock (Stratum IV)
and moving upward, contaminant concentrations should be higher in the lower
part of the alluvial aquifer than in the upper portion. Conversely, if the
contaminants are entering the alluvial aquifer primarily by percolating
downward from the surface runoff water, the concentrations in the upper
groundwater should be higher than in the lower groundwater. Sample analyses
data from two different depths in the aquifer (wells MW-12S, -12M and MW-13S,
-13M) show that the volatile organic chemical concentrations are greatest
in the lowest portion of the aquifer, indicating that the contaminants have
probably migrated through the bedrock from the site and into the lower
alluvium (as opposed to the surface water pathway) (Reference, Affidavit of
John B. Robertson).
During site operations, volatilization of chemicals into ambient air resulted
in the release and transport chemicals offsite. This pathway was reduced
with closure of the pits and capping of wastes. No residual effects have
been identified, and none are believed to exist from air pathway transport
due to the volatile organic nature of contaminants. At the present time
and in the near future, transport of contaminated groundwater and discharge
to surface waters are the only pathways of consequence. If the site is not
properly remediated, contaminants will also eventually be released from the
site in substantial quantities by erosion and runoff and to a lesser extent
through slow volatilization to the atmosphere. As contaminants are exposed
there would be an additional pathway for risk through direct contact with
contaminated materials. The above pathways are discussed in further detail
below.
Groundwater:
The principal pathway of contaminant migration at the Hardage site is through
dissolved phase groundwater flow. Groundwater contamination emanating from
the source areas extends approximately 600 to 800 feet to the east farm
ponds. The contamination plume extends offsite to North Criner Creek,
approximately 1600 feet. The plume in the alluvial aquifer is distorted,
both parallel to and towards North Criner Creek. Overall, the groundwater
plume underlies approximately 70 acres on and adjacent to the site (Figure
4-6, Area 3).
-------
APPROXIMAT:
GROUNDWATEl
FIGUEF: 4-6
ra
n PI
o x
2 H
H W
2 O
I \ 1 1 \ 1 1
i a Sis
J ; 53?
is i
-------
4-15
The groundwater contaminant plume contains a wide variety of volatile
organic chemicals which include toxic compounds such as 1,2-dichloroethene
and trichloroethene. A summary of contaminants and their concentration for
onsite wells is presented in Table 4-2. Beneath and immediately adjacent
to the source areas (Figure 4-6, Area 1) volatile, semivolatile, and pesticide
compounds are present at their highest levels, in some cases exceeding
25,000 pph for volatile organics. At three locations NAPL has been encountered
(MW-6, 8-13, and MW-2). Additional pockets of NAPL are almost certainly
present in other areas beneath the source areas, particularly at the Barrel
Mound. A somewhat larger portion of the plume (Figure 4-6, Area 2) contains
both volatile and semivolatile contaminants, but not NAPL. This, the
"semi-volatile plume", extends over 600 feet eastward to where the plume
discharges into the east farm ponds. To the southwest, the semi-volatile
plume extends only about 200 feet (to well MW-45). Contamination by volatile
organic chemicals (VOC) is most widespread and defines the extent of contam-
ination. The VOC plume extends southeast into the alluvium of North Criner
Creek (see Figures 4-6, Area 3). Contaminated groundwater flowing southwest
through the onsite bedrock discharges to the alluvial aquifer. This discharge
constitutes the source of continuing contamination in the alluvium (see
Figures 4-4 and 4-7,. Average flow rates along this pathway have been
estimated at 110 feet per year (Affidavit of John B. Robertson).
Discharge of Contaminated Groundwater to Surface Water:
Both the east farm ponds and North Criner Creek receive contaminants via
discharge of groundwater to the surface waters. The contaminants entering
North Criner Creek are chlorinated ethanes and chlorinated ethenes. Since
these chemicals are volatile, natural processes rapidly strip volatiles
from the surface waters, and release them to the air. Sampling of North
Criner Creek has only most recently detected contamination (1-2 dichloro-
ethene, 5 ppb and trichloroethene approximately 2 ppb), and supports the
belief that the discharge of contaminated groundwater can have a measureable
impact on surface water quality in the Creek.
Volatile chemicals also enter the east farm ponds. Sampling to date has
not indicated the presence of volatiles; however, more persistent
semivolatile chemicals are seeping into the southernmost east farm ponds
and are impacting water quality in the immediate vicinity of the seeps.
These compounds appear to be entering the farm pond due to seepage of NAPL
along the bedrock surface. Dilution of this seepage is presently occuring
so that impacts on water quality of the pond have not been measureable.
-------
H
ca
-------
-------
M O
•Z M
C/J
W H
H 70
30 M
> CO
H G
M O
•Z H
a o
H
H >
3: r1
M
G H
< i-(
M I-1
a «
So
so
n
en
a
»
PI
*>
-\
-------
4-19
Surface Water Runoff and Sediment Transport:
Surface water runoff and sediment transport will constitute substantial
pathways for contaminant transport from the site over the long-term if the
site is left unremediated. Vegetation over much of the site, including
the source areas, is sparse due to the removal of the topsoil in the course
of site operations. The lack of vegetation contributes to soil erosion.
In addition, the final contour of the waste mounds is not conducive to
long-term stability. Leachate seeps from the western side of the waste
mounds are common in the wet, spring months. Rainfall runoff tends to
spread this leachate downslope, resulting in visible contamination as far
southwest as the existing interceptor trench.
4.2.4 Future Contaminant-Migration
Left unremediated, contaminants will continue to migrate off of the site and
spread on the site by the following general pathways:
1. expansion of the plumes of contaminated groundwater;
2. leakage and spread of waste liquids from the Barrel Mound and
Main Pit, which will in turn continue to feed the plumes on
contaminated groundwater;
3. dissolution of contaminants by groundwater infiltrating through the
the Sludge Mound, Main Pit, Barrel Mound, and areas of residual
contamination; and
4. transport of wastes and contaminated soils from the Main Pit,
Barrel Mound, Sludge Mound and adjacent mixing areas via erosion
and runoff.
5. long-term low-level releases of volatile compounds to the atmosphere
The groundwater contaminant plumes present at the Hardage site have developed
over the 17 years since operations started at the Hardage site. Left
unremediated, plumes of contamination in the vicinity of both the east
farm ponds and North Criner Creek will expand. Modelling of the southwest
alluvial plume in the Remedy Report (EPA, 1989) predicted a gradual expansion
approaching 2000' (with dilution) even with the source of contamination to
the alluvium cut off. Without source control and groundwater remedial
actions, the southwest alluvial contaminant plume would certainly continue
to expand southeastward, parallel to the stream. The plume near the east
farm ponds may expand eastward beneath the ponds, although this is uncertain
due to remaining questions about groundwater and surface water interaction
acting as a barrier to migration around the ponds.
Waste liquids in the Barrel Mound and Main Pit will continue to migrate
into the surrounding bedrock and groundwater in accordance with the
conceptual model illustrated in Figure 4-5. Liquids in the Barrel Mound
are released as drums of waste liquid corrode and as liquids drain from saturated
soils (under gravity and consolidation). These liquids drain downward through
the permeable mounds and accumulate on the less permeable sandstone and
siltstone bedrock surface at the base of the pit. This pool of waste liquids
tends to drain downward under gravity through pores and fractures in the
shallow bedrock. As the liquids move downward some 10-15 feet below the
base of these pits, they encounter a less permeable bedrock horizon and
tend to spread out across the upper surface of that horizon and migrate
with a lateral component, as seen at locations MW-2 and MW-6.
-------
4-20
In their present condition, the source areas are susceptible to infiltration
of rainfall. As this water percolates downward through the source materials,
it dissolves contaminants and carries them downward to the groundwater
system. This is a potential continuing source of release on the site.
Over time, erosion of contaminated soils is expected to increase to a point
where substantial offsite releases occur via erosion and runoff.
-------
5-1
5.0 SITE RISKS
The Hardager site received hazardous wastes that are either known or
suspected carcinogens such as vinyl chloride and benzene. Table 4-1 gives
a more complete list of carcinogens found at the site. Other compounds
either are or are believed to be acutely toxic or capable of causing damage
to specific organs. Some of these compounds also bio-accumulate in plant,
animal, and human tissues. The Hardage Site was permitted to receive all
types of industrial and hazardous wastes except radioactive wastes.
Table 2-1 lists some of the wastes known to have been received at the site.
There are four primary ways humans can be exposed to the hazardous wastes
at the Hardage site. The first and most important of these is exposure to
contaminated groundwater. -The groundwater at the Hardage site is contami-
nated with waste migrating from the source areas into the bedrock and
alluvial groundwater systems. Not only is the groundwater under the site
contaminated with these hazardous wastes, hut the contamination has spread
beyond the site to the south and has already forced local residents to stop
using their water wells.
The contaminated water wells are located in the North Criner Creek Alluvium
which lies below the Creek south of the site. This aquifer is contaminated
with the chemicals exceeding the standards for consumption of drinking water
as set under the Safe Drinking Water Act that are also given under the
column titled MCL in Table 4-2.
As Table 4-2 shows, eight of these contaminants are already above the
limits. The nearest of the contaminated residential wells is the old
Corley well. The old Corley well is located approximately 500 feet
southwest of the site. Estimates of the risk of cancer from lifetime use
of residential water contaminated at the level of the old Corley well range
from 0.0007 (seven per ten thousand) to 0.006 (six per thousand) far above
the one in one million level commonly used as an acceptable risk. These
estimates were arrived at using average concentrations of contaminants in
the old Corley well and making assumptions about standard ingestion of
water, inhalation exposures and dermal exposures from household use.
-------
5-2
With the North Criner Creek alluvium already contaminated, one of the goals
of the cleanup will be to restore the groundwater to a useable condition.
The standards used to judge the effectiveness of the cleanup alternatives
for groundwater will be the Maximum Contaminant Levels set under the Safe
Drinking Water Act (MCLs). The effect of the proposed cleanup plans can
be compared through their effects on the concentration of contaminants in the
North Criner Creek alluvium. The proposed EPA remedies would result in
lower concentrations of contaminants in groundwater in the alluvium of North
Criner Creek through removal and destruction of contaminants at the source
and interception and treatment of groundwater by trenches. While it is not
possible to accurately assess how long the source areas would continue to
bleed contaminants into the groundwater systems, it does not require and
expert to conclude that if- the HSC remedy leaves 10 or 100 times more of
the most problematic waste liquids in the site than EPA's remedy, then the
long-term duration of the EPA remedy would he shorter. The EPA remedy would
therefore attain MCLs more quickly than the HSC remedy.
Direct contact with wastes on the surface of the site also poses hazards;
however, the health risk is highly variable depending upon area of exposed
waste and level of human traffic and has not been quantified. Human
traffic on the site is minimal; but cattle did occasionally graze on the
site. Contamination of the food-chain (for example beef and milk from cattle
eating contaminated grass) by lead, chromium, pesticides, and PCBs on the
surface of the site poses long-term hazards. This concern prompted construction
of a fence to keep cattle and people off of the source areas. Certain
compounds such as pesticides and PCBs have the ability to bioconcentrate
through successively higher levels of the food chain (EPA, 1985a).
Inhalation of volatiles and concentrated airborne particulates on and
possibly adjacent to the site may also pose long-term hazards if the site
remains unremediated, but again this risk is highly variable depending upon
the quantity of exposed contamination.
-------
6-1
6.0 DESCRIPTION OF ALTERNATIVES
A large number of remedial alternatives have been formulated to address part
or all of the Hardage site. As discussed in Section 3, the site has been
considered as two "operable units". Source Control measures were considered
by EPA in a 1986 FS. In November 1986, EPA issued a ROD which selected a
Source Control remedy with incineration of liquid wastes and stabilization
and containment of solids in a new landfill to be built on-site. HSC objected
to the selection of this Source Control remedy and proposed an alternate
Source Control remedy in December 1986 which called for in-place containment
of the waste source areas by a cut-off wall and groundwater pumping. HSC
declined to implement the EPA selected remedy which resulted in litigation
in 1986. EPA maintained that the remedy selected in the 1986 ROD was
technically sound and completed the Source Control Remedial Design in 1988.
In 1987, HSC signed a partial Consent Degree with EPA for the conduct of an
RI/FS for groundwater (Management of Migration). In May 1989 HSC, pursuant
to the Consent Decree, submitted a draft FS on Management of Migration to
EPA for review and approval.
During conduct and preparation of the groundwater RI/FS, uncertainty arose
over the impact of RCRA Land Disposal Restrictions on the EPA selected
Source Control remedy. To alleviate this uncertainty, EPA undertook considera-
tion of an alternative Source Control remedy based upon the new technology
of in-situ soil vapor extraction. Evaluation of soil vapor extraction in
conjunction with alternative presented in the groundwater FS resulted in
consideration of alternatives addressing the entire site in contrast to the
original Operable Unit approach. On June 30, 1989, the United States
advised the District Court of EPA's decision to consider a comprehensive
site remedy.
On July 6th and in greater detail on October 13, 1989 the defendants presented
to the court their plan to further define an additional remedial alternative.
This, the HSC alternative, was similar to EPA's alternative except that the
HSC plan did not include soil vapor extraction, enhanced recovery of container-
ized liquids, or the shallow waste liquid recovery trench proposed by EPA.
Previous and new alternatives for the control of the contaminant sources
are summarized below in Section 6.1. Alternatives for groundwater as
contained in the groundwater FS are summarized in Section 6.2. Common
monitoring and support components for Groundwater and Source Control
alternatives are listed in Section 6.3. Finally, Source Control and
Groundwater alternatives are combined and summarized in Section 6.4.
-------
6-2
6.1 Alternative Source Control Components
A number of alternatives were considered for remediation of the Source
Control areas prior to the 1986 ROD. These can he seen in more detail in
the 1986 ROD in Appendix F, along with evaluation criteria for remedy
selection. Those remedies which were considered fell into four basic
categories: no action; disposal onsite in a landfill (the EPA selected
remedy in the 1986 ROD); containment of wastes in place (the HSC counter
proposal of a cut-off wall); and incineration (also considered in the 1986
ROD). The following four sections summarize each of these categories.
6.1.1 No action. As the title implies, no work would be done to mitigate
hazards from the site. The alternate water supply, security fence,
and site stability measures would not be maintained.
6.1.2 Onsite Landfill (EPA 1986 ROD Remedy). The source areas would be
excavated and separated for treatment. Organic liquids would be
bulked and shipped offsite for thermal treatment at a permitted
facility. Inorganic liquids would be treated and discharged to an
onsite impoundment for evaporation. Solids would be stabilized by
blending with 8-10% cement kiln dust and placed in a new double
lined landfill cell constructed on-site in accordance with the
Minimum Technology Requirements (MTR) of RCRA. The 1986 estimate
of most probable cost was 70 million dollars.
6.1.3 Containment of wastes, Cap and Cut-off wall (HSC Proposal). A
plastic cement "cut-off" wall would be constructed in panels so as
to encircle the source areas. This wall would range from 70 to 130
feet in depth and, at its base, key 10 to 20 feet into the low
permeability siltstone and mudstone of Stratum IV. Wells would be
drilled through the Source areas and completed in the bedrock within
the periphery of the wall. The water and wastes would be pumped
from these recovery wells in an effort to induce a hydraulic gradient
inward through the wall and prevent the outward migration of contami-
nants. Pumping would be conducted indefinitely.
Vertical waste liquid extraction wells would be drilled into the
Barrel Mound and pumped in an effort to remove pooled liquid for
treatment. In addition, lateral drains would be drilled from the
west into the base of the Barrel Mound. These drains would slope
slightly downward out of the mound to allow free drainage of waste
liquids and groundwater from the Barrel Mound over time.
An effort would be made to speed consolidation of the Barrel Mound
by placing a 20 foot thick soil layer as a surcharge for a period
of 6 months to a year. After removal of the surcharge, a MTR cap would
be installed over the source areas. The most probable cost estimate
was 25 million dollars.
-------
6-3
6.1.4 Incineration (EPA Proposal in 1986 ROD). The source areas would he
excavated. Wastes would he incinerated in a kiln constructed onsite
or at a commercial incinerator offsite. The ash would still contain
metals and until it could he proven otherwise through de-listing,
would require disposal as a hazardous waste. Estimates in 1986 for
cost of incineration ranged from 133 to 374 million dollars.
The no action alternative was eliminated from consideration early as not
being protective of human health or the environment due to continued vertical
and lateral migration source area wastes offsite. Containment of the
contamination in place was eliminated due concerns over continued migration
of the contamination, doubts that containment techniques such as slurry
walls could be installed effectively, and concerns relating to merely containing
the sources of contamination rather than actively remediating them to achieve
a permanent reduction in their volume, toxicity, or mobility.
The alternatives that remained were onsite disposal and incineration. The on-
site landfill alternative was eventually selected as providing a degree of
protection to human health and the environment similar to that which could
be achieved with complete incineration, hut which could he carried out in a
shorter time and at a reduced cost. A more detailed comparison is given in
the 1986 ROD in Appendix F. With this background, onsite disposal was
selected in the 1986 ROD.
The new alternative for Source Control in the October 1989 Proposed Plan
contained components for a new approach to Source Control. These
components are as follows:
6.1.5 Liquid Extraction Wells
A system of vertical extraction wells would he installed throughout the
three main source areas. The wells would he used for extracting free liquids
that are found in the source areas, and liquids that would be released from
the drums as a result of the lancing procedure described below, should it
be used. The wells could also he used as part of the soil vapor extraction
process described below.
An estimated approximately 956,000 gallons of aqueous and nonaqueous liquids
presently reside in the saturated portions of the source areas. The quantity
of residual liquids trapped within the unsaturated portion of the source areas
is estimated as at least 170,000 gallons.
Additional liquids are likely to be found in drums buried in the source areas.
Assuming that one third of the 18,000 drums estimated to be in the Main Pit/
Barrel Mound contain organic liquids, an additional 660,000 gallons of
liquids may be present that require removal and offsite disposal.
The liquids pumping operation is not expected to remove all of the free
fluid found within the source areas due to localized pooling between wells,
nor will it address the liquids residing in the unsaturated zone.
-------
6-4
The nonaqueous-phase liquids removed from the extraction wells and trenches
will he sent to a hazardous waste treatment, storage, and disposal (ISO)
facility for incineration.
6.1.6 In-PTace Drum Lancing
One method considered to assist in the removal of the liquids remaining in
the buried drums was to lance the drums in place. The lancing process
would release the liquids for subsequent removal by the wells or through
the soil vapor extraction process (see Figure 6-1).
The lancing effort would be accomplished using commercially available
construction equipment capable of driving solid spark-resistant Cu-Be
rods to subsurface depths greater than 40 feet. The lancing would take
place throughout the Barrel Mound and in areas of significant concentration
of drums in the Main Pit. 'Magnetometer data highlighting areas of drum
concentrations would be used to select appropriate areas in the Main Pit
for lancing.
The lances would be advanced to the bottom of each target area at a nominal
triangular spacing of 22 inches. The released liquids would be collected
and removed via the extraction wells, a U-shaped trench (described
later), or the soil vapor extraction system (described later).
The progress of the lancing operations would be controlled by monitoring the
rise of fluid levels in nearby extraction wells. The effort would be made
to prevent the accumulation of fluids to greater levels than those that
currently exist in the source mounds. Non-aqueous phase liquids (NAPL)
released by the lancing process and removed in the liquid extraction system
would be sent to a TSO facility for treatment and disposal.
While lancing was considered as an option for the removal of drummed
liquids, excavation of drums has several advantages over lancing for the
removal of liquids. These include the assurance that all liquids are
removed and the elimination of the introduction of additional liquids to
the vadose zone on the short-term.
6.1.7 Drum Excavation
Liquids in drums from the Barrel Mound and the west side of the Main Pit
can be removed from the source areas by excavating the drums as originally
intended in the 1986 ROD instead of performing drum lancing. The
excavation option would remove free liquids directly from the surface
and from any drummed liquids in the source areas by direct removal. It is
expected that excavation, utilized successfully at a number of other sites,
would he more efficient than lancing in removing free and containerized
liquids in the Main Pit/Barrel Mound. Figure 6-2 indicates areas that
would be targeted for drum excavation. Drums that are removed from the
source areas would be staged for sampling and consolidation with similar
wastes. Drummed organic liquids would he consolidated for offsite treatment
and disposal. The liquids would he transported to a hazardous waste treat-
ment, storage and disposal (TSD) facility for incineration. Aqueous liquids
would be treated onsite by the groundwater treatment facility. Any drums
containing solids, or having solid residues in them after liquids are removed
would be placed back into the source areas.
-------
****************************
*****************************
****************************
****************************
****************************
****************************
****************************
LANCING MACHINE
BOTTOM OF
SOURCE AREA
ttfteftt
xxxxxxxx
xxxxxxxx
xxxxxxxx
xxxxxxxx
xxxxxxxx
xxxxxxxx
§ r
77^v
-------
FIGURE 6-2
AREAS TARGETED FOR DRUM EXCAVATION
BARREL MOUND AREA
LEGEND
EXTENT OF DRUM REMOVAL
DRUM CONCENTRATIONS
SCATTERED DRUMS
AREA OF SIDE SLOPES
EXPECTED TO BE REMOVED
TO FACILITATE DRUM REMOVAL
MAIN PIT AREA
100
20O
1 INCH - 100 FEET
-------
6-7
6.1.8 Excavation of Wastes in Adjacent Areas
Contaminated surface soils and waste materials located away from the source
areas will be excavated and transported to the source areas. These materials
will he consolidated under a temporary cap for soil vapor extraction along
with trench excavation materials and other materials generated during imple-
mentation of the remedy. The greatest concentration of contaminated soils
and wastes away from the source areas occurs in the North Pit area, where
up to 80 drums of wastes as well as contaminated soils are believed to be
buried, and in the West and East Pond Areas (see Figure 1-2).
If contaminated water or liquid wastes are encountered in these drums, they
will be treated in the groundwater treatment facility to surface water
discharge standards, or taken offsite for disposal, whichever is appropriate.
The contaminated solids and soils will be remediated as part of the overall
remediation program, once they are placed within the source areas and capped.
6.1.9 Soil Vapor Extraction and Treatment
Soil vapor extraction would be conducted in the three main source areas as a
means to further capture and destroy the liquids present. Soil vapor
extraction is expected to remove a large volume of the highly toxic and mobile
volatile organic compounds present in the source areas. The soil vapor
extraction systems would consist of a network of extraction wells screened
in the contaminated (vadose) zone of the Main Pit/Barrel Mound and Sludge
Mound. The dual-purpose extraction wells installed to remove liquids would
be used as part of the vapor extraction system.
The liquids pumping operation is not expected to remove 100 percent of the
liquids present. Numerous field studies have shown that in excess of 40
percent of the available liquids may remain trapped in the unsaturated zone
following gravity drainage and pumping efforts. While not readily amenable
to pumping, these residual liquids are subject to further removal by vapor
extraction.
Soil vapor extraction works by drawing air through areas containing contami-
nation thereby creating a vacuum in the source areas (see Figure 6-3).
This, in turn results in a high evaporation rate of volatile and semi-volatile
organic compounds, including significant quantities of toxic and carcinogenic
contaminants that are in contact with groundwater and atmosphere. Such
contaminants evaporate into the air drawn into the mounds. The contaminated
air is then extracted through air extraction wells and is treated o'.site to
destroy the ontamination.
If lancing - used, vapor extraction is also expected to remove a
significant uantity of the liquids that remain trapped in the drums.
If there are pockets or low spots in the mounds between the liquid
extraction v 11s, the vapor extraction process will further aid in the
removal of " ^uids that cannot migrate towards the extraction wells.
The air stn n and vapors removed by the soil vapor extraction system will
be treated ing the Best Available Control Technology for thermal destruction
-------
men
m>
O
O
-------
6-9
of toxic vapors prior to discharge to the atmosphere. Vapors generated by
the groundwater treatment system will also he destroyed in this thermal
treatment system.
6.1.10 Source Area Capping
Two types of source area capping are planned for the site. A temporary
cover would he installed during remediation activities, and a permanent RCRA-
compliant cap would be installed once soil vapor extraction and liquid
extraction activities are complete. The temporary cover will consist of
compacted, minimum 1-foot thick, low-permeahility soil with vegetation to
minimize erosion. Repairs will be made as needed to compensate for damage
from settlement and erosipn.
Permanent RCRA-cap installation would he initiated once the drummed liquids
are removed, soil vapor extraction has been completed, and the liquid extrac-
tion wells have been decomissioned. The cap will be location over the Main
Pit, Barrel Mound and Sludge Mound areas as illustrated in Figure 6-4.
Section 6.2 Groundwater Remediation Objectives and Alternative
Groundwater Components
In addition to the new components considered for Source Control, remedial
alternatives for contaminated groundwater were developed and described in
detail as part of the Management of Migration Operable Unit RI/FS reports.
All alternatives were developed assuming some form of concurrent Source
Control remedial action. The alternatives were developed in light of the
overall goal of restoring groundwater to its beneficial use within a reason-
able timeframe.
Consideration of the hydrology and contamination of the bedrock aquifer at
the site has led to the conclusion that restoration of bedrock groundwater
underneath the source areas is technically impractical over a reasonable
time period (a few decades). This conclusion is supported by the fact the
some D-NAPL has escaped from the source areas and will continue to serve as
as source for dissolved contaminants in groundwater. Also, some contaminants
have diffused into dead-end cracks and fine-grained pores in the rock matrix;
those materials will take a relatively long time to diffuse out of the
pores and cracks during an active or passive restoration program. In view
of these facts, the most effective way to address groundwater contamination
onsite is through various -ontainment efforts designed to control the spread
of groundwater plumes and ~otect downgradient areas from future plume
migration. Such efforts w 11 be significantly aided by source control
actions that in a timely manner permanently reduce the potent source liquids
which continue to load the groundwater system with contaminants. Consequently,
component alternatives wer screened and refined based on their effectiveness
in meeting the following c jectives:
o intercept and captu • groundwater that is migrating towards the
alluvial aquifer an the east farm ponds, thereby protecting
offsite areas from jture contaminant impacts, and commencing
the process of natu tl restoration in the alluvial system;
-------
on
o
G
TO
n
33
M
n
>
-a
-------
6-11
o monitor and control contaminated groundwater discharge to North
Criner Creek to assure that Oklahoma Water Quality Standards for
North Criner Creek and Criner Creek are met; and
o prevent domestic and agricultural use of contaminated groundwater
through continued supply of alternate water to affected residents.
In view of these objectives, ERM-Southwest, on behalf of the HSC (and
pursuant to a partial Consent Decree with EPA) developed and evaluated 21
remedial action alternatives by combining 6 remedy elements (see Table 6-1).
Details of this analysis is presented in the Management of Migration FS.
All of the initial alternatives developed included groundwater and surface
water monitoring, as well as actions to minimize runoff from the source
areas. All alternatives relied on institutional controls (such as deed
restrictions) to prevent the use of potentially contaminated groundwater
as a drinking water supply. The alternatives also included continued
operation of alternate water supplies to nearby residents.
Screening of these alternatives was conducted in the FS based on effectiveness
in containing and capturing contamination, and cost. Six groundwater alter-
natives were retained after this screening for detailed analysis, and were
summarized below:
Alternative
Description
No Action
Primary Controls - institutional controls on groundwater
use, maintenance of alternate water supplies, and surface
water controls to limit the discharge of contaminated
groundwater to surface water.
Alternative B and Alluvial Recovery - groundwater recovery
from the North Criner Creek alluvium using a well network
or interceptor trench system (see Figure 6-5)
Alternative B and Alluvial, South Pond and Southeast
Area Recovery - groundwater recovery from the North
Criner Creek alluvium, from bedrock southwest of the
Main Pit, Barrel Mound and Sludge Mound, and from
bedrock east and southeast of these three source areas
(see Figure 6-6) using a well network or interceptor
trench system
Alternative B and South Pond Area Recovery - groundwater
recovery from bedrock >uthwest of the three main source
areas using a well network or trench system, with the
the option of a local it-off wall along the site fence
boundary in place of a umber of recovery wells
Alternative B and Main Source Area Recovery - groundwater
recovery associated wi' i source control measures using
a well network.
-------
(A "O
M
•o •<
So
a O
sf
rt a>
Si
(»
x
X
X
r Imary con
loremedlitl
outheasl R<
0 O "
S . 2,
•< 3
a —
3
Ul
C
x
x
x
X
r Imary 'con
loremedlatl
rea and sen
»!;
n v>
2 | *
"*
x
X
X
X
I
r Imary conl
loremedlat I
rea Recovel
•< o •*
3 o
a* w>
i_
Ul 3
Is
e
•o
|
X
X
X
X
O
m TS
i Imary conl
1 or emed 1 a 1 1
Wi
•B
3
a
3
c
x
X
X
-n
M 13
r Imary conl
nd southea;
sl
g >
< c
<
Q»
-
X
X
X
WI WI *O
r Imary conl
oulh Pond i
outheati Ri
n — ^
I 2r
* a >
c
<
^
X
X
X
x
X
o
JO M "5
r Imary Conl
nd south P(
ecovery
Q. O
it
=
<
E
X
X
x
"
o
o 5
n —
3 S
o. -•
So
It 3
s|
< fl»
ft 3
•^ a
—
1
a*
x
x
X
09
13
I
O
w*
x
X
*
NO ACl IOn"
X
Remedy
I
3
**
!
'o
3
O
° 2
| f
0 -
n —
S|
i:
— ^
» c
— OB>
S 0
* o
It C
o > —
0-3-
<
-------
en
3
a
n
a*
les element Is in
rt
C
a
a
3
o
i*
3
»
W
i
A
M
i
3
fit
<
n
ft
ft
3
3
(O
C
<*
(9
C
^ (9 O "
<% n £ —
» S ^ -
f controls . At luv
'ond, Southeast
ry and Main sourc
?covery
a*
x
x
x
x
x
x
H
§*7
»,i
i control s . Main
scovery. soulheas
'ond Recovery,
.§
3 ^
a n
x
x
x
x
x
VI
IS-
S » -
r controls . south
•cover y and Main
Area Recovery
.1
I
Q,
X
X
X
M
S f» O —
n o a*
* S !<
™ IP ^
> o a
<• — 3
» •< J -
(> 3 O
O M • —
S3 «•
Q. Ul •
2«2-
-< S — 3
3 W<
•o —
t C
X
X
X
X
X
O
i o —
* 3 2
f control s , in si
sdlat Ion. and Mai
Area Recovery
3 — >
C
X
•
x
X
X
T3
<» n O. —
».s?
A _ 2E _^
i controls . Al luv
j|h Pond Area
V and Main sourc
"coverv
<* —
Q»
X
X
X
X
X
O
ft rt ~
- s i
i control s . Al luv
ry and Main sourc
"cover y
M
X
X
X
Z
i -
S ?
1 controls and Ma
Area Recovery
3
X
X
I
§ -
a -
1 controls and
is) Recovery
X
X
X
^
88-
f ; \
Y controls
'ond Area and
is I Recovery
X
X
X
X
JB
fmedy Elements
1
2.
o
3"
—
O - 3-
< <*
(V » "V
•< 3
Si
n —
Sf
1* »
JO
-• n
3S
O V)
i i
"5s =
— — a
— r» —
- I
•< 3
-------
POND
HOMESTEAD
LEGEND
WELL LOCATIONS AND NUMBERS ARE
APPROXIMATE AND ARE SHOWN FOR
CONCEPT ILLUSTRATION PURPOSES ONLY.
SOIL REVEGETAT10N AREAS ARE NOT EXACT
AND ARE SHOWN FOR CONCEPT ILLUSTRATION
PURPOSES ONLY.
SURFACE SOIL
REVECCTAT1ON
RECOVERY
TRENCH OR
WELLS
MONITORING WELL
RECOVERY WELL
ERM-5oothw«st, inc.
NEW ORLEANS, LOUISIANA
HOUSTON. TEXAS
DATE 05/24/89
W.Of." 7663A001E89
FIGUF 6-5
ALTERNATIVE C Si : SCHEMATIC
SECOND OPERABLE UNI" FEASIBILITY STUDY
ROYAL HARD 3E SITE
CRINER, OK
-------
PONO
W
I
?
I
WELL LOCATIONS AND NUMBERS ARE
APPROXIMATE AND ARE SHOWN FOR
CONCEPT ILLUSTRATION PURPOSES ONLY.
SOIL REVEGETATION AREAS ARE NOT EXACT
AND ARE SHOWN FOR CONCEPT ILLUSTRATION
PURPOSES ONLY.
RECOVERY
TRENCH OR
WELLS
MOM TOW NC WELL
RKOVEITt WELL
ERM-Soflthwest. inc.
NEW ORLEANS. LOUISIANA
HOUSTON, TEXAS
DATE 05/24/89
W.O.NO. 7663A001E89
FIGURE 6-6
ALTERNATIVE E SITE SCHE 'ATIC
SECOND OPERABLE UNIT FEASIE JTY STUDY
ROYAL HARDAGE SITE
CRINER, OKLAHOMA
-------
6-16
Alternative E (illustrated in Figure 6-6) involves the recovery of contaminated
groundwater in the southwest alluvial area of North Criner Creek and onsite
groundwater recovery west, south, and east of the main source areas. Alter-
native E has been modified and includes two groundwater components. The
onsite interceptor system is known as the V-Shaped Trench. The southwest
interceptor system is known as the Southwest Interceptor Trench. Both the
V-shaped and Southwest interceptor trenches would he capable, in combination
with Source Control components of the comprehensive remedy, of modifying
groundwater gradients at the site so as to contain and capture groundwater
and D-NAPL migrating from the source areas and off the site.
A third trench, known as the U-Shaped Trench, was considered by EPA during
the development of groundwater alternatives in order to prevent uncontaminated
groundwater in the vicinity of the Main Pit/Barrel Mound from coming into
contact with the source waste materials during remediation, as well as to support
source liquids removal operations by intercepting lateral seepage that may
ensue from the source areas.
These three recovery systems could be installed at the site to capture
contaminated groundwater migrating towards the alluvium and the east farm
ponds, provided Source Control measures are also instituted. Collected
groundwater from any or all of these systems would be treated onsite
to discharge standards before discharge to North Criner Creek. These
collection systems are illustrated in Figure 6-7 and each is further described
below:
6.2.1 U-shaped Trench
The first trench, known as the U-shaped trench, would intercept shallow
seepage issuing laterally from the Barrel Mound and the Main Pit and to
collect contaminated groundwater from Stratum I in the vicinity of the
Barrel Mound and Main Pit.
6.2.2 V-shaped Trench
The V-shaped trench would intercept and collect contaminated groundwater
from all bedrock zones existing above Stratum IV. The trench will be
located so that groundwater contaminants already migrating eastward
towards the east farm ponds will be captured by the trench, negating the
need for additional gorundwater recovery measures east and southeast of
the trench.
6.2.3 Southwest Interceptor Trench
The Southwest Interceptor Trench is to intercept and collect contaminated
bedrock system groundwater prior to its natural discharge to the offsite
alluvial aquifer along North Criner Creek. The trench will extend to Stratum
IV and will collect contaminated groundwater from all bedrcx zones above
Stratum IV. A system of extraction wells could be used as an alternative
to the Southwest Interceptor Trench provided they are equally effective at
intercepting and collecting contaminated groundwater.
-------
11 SO
1100-
10SO-
1000-
930-
900
WOMINANTLY
SANDSTONE
STRATUM II PHEBOMNAHTLYMUOSTONS
HIGHWAY 122
SOUTH POA/0
STRATUM III SANDSTONE. S1LTSTONE
SOUTHWCST 7PfA/CH
FIGURE
SITE CROSS : £CT!ON
SHOWING TRf ^CHES
-------
6-18
6.2.4 Ground Water Treatment System
An onsite_treatment plant would he provided to treat collected groundwater
and surface water. The plant would he sized to handle flows from the
groundwater collection trenches and the surface water collection system.
The plant incorporates appropriate treatment processes to handle hoth
organic and inorganic contaminants as necessary.
Following treatment, the plant would discharge to North Criner Creek. The
plant would he designed to meet the applicable discharge requirements set by
the Oklahoma Water Resources Board and the Oklahoma State Department of
Health.
6.2.5 Alluvial Ground Water Restoration
Contaminants already present in the alluvial aquifer would he allowed to
dissipate hy natural dilution, biodegradation, and flushing. Future
contaminant inputs to the aquifer will he abated hy the trenches and the
Source Control elements presented above to allow restoration to Maximum
Contaminant Levels in the North Criner Creek alluvium. If alluvial
monitoring reveals that estimated natural restoration time and plume
dilution rates are not being met, then active restoration would be
implemented. An increase in contaminant concentrations in the alluvium
after trench installation and pumping, or a decline in the mass of
contaminants of less than 40 percent in 10 years, would trigger active
restoration in the alluvium.
6.3 Monitoring and Support Components
6.3.1 Remedial Support Facilities
Several components are needed to support the implementation of the remedy.
These site control facilities consist of a command post, medical services
station, close support analytical laboratory, sanitary facility, equipment
maintenance shop, decontamination facilities for hoth equipment and
personnel, and a supply center, gate guard, and communication center.
6.3.2 Institutional Controls
Institutional controls, including fencing, deed restrictions, and
maintenance of the availability of an alternate water supply system would
be implemented to restrict access to the site and contaminated groundwater.
6.3.3 Surface Water Controls
During implementation of the remedy, surface water drainage from the sourc
areas would he collected as needed. Berms would he constructed to divert
uncontaminated runoff water away from the working area to minimize the
generation of contaminated water. A retention pond would he used to col It .t
and store surface water prior to treatment. A Treated Water Retention Por
would also he used to store treated groundwater prior to discharge to the
surface drainage system for North Criner Creek.
-------
6-19
Once the temporary cover is in place and the remedy has been implemented,
surface water control and treatment would not he necessary. The diversions
would he maintained over the life of the remedy as a means to control
erosion of the cover.
6.3.4 Remedial Monitoring
A monitoring program would he instituted as part of the remedy to verify
that the migration of contaminants has heen halted. Streamwater in North
Criner Creek would he monitored periodically for an indefinite future time
to provide assurance that surface water discharge limits are not heing
exceeded downstream.
A line of monitoring wells at the downstream end of the alluvial
contamination plume would-he used to provide assurance that the plume is not
expanding downgradient in the alluvial aquifer ahove acceptable levels.
The quantity and quality of liquids collected from the trenches would also
he monitored. The effectiveness of the trenches in maintaining the desired
hydraulic gradients and capture zones will he monitored hy a series of
piezometers positioned along lines perpendicular to the orientation of the
trenches.
Bedrock groundwater monitoring wells (hoth new and existing) would he used
to further verify the effectiveness of the trenches in controlling the
spread of contaminated ground water.
The cap will also he monitored periodically to assure that differential
settlement or erosion processes are not compromising the integrity of the
caps.
Monitoring would he used to verify that the quality of downstream water
resources is not heing jeopardized during the natural restoration process.
Air quality would he monitored hoth onsite and at the site fenceline to
assure that hoth onsite action levels and Maximum Amhient Air Concentrations
are heing met during remedy implementation.
6.4 Comprehensive Alternatives
From all of the components described in Sections 6.1, 6.2 and 6.3,
three comprehensive remedial alternatives were assembled for consideration.
These three alternatives, the Revised EPA Remedy, the Partially Revised EPA
Remedy, and the HSC Remedy are described below and in Table 6-2.
-------
6-20
6.4.1 Common Elements
Certain of the components from Section 6.1 are included in all three of the
comprehensive alternatives. These are Institutional Controls (6.3.2),
Surface Water Controls (6.3.3), Remedial Monitoring (6.3.4), and Remedial
Support Facilities (6.3.1)
6.4.2 Revised EPA Remedy
The Revised EPA Remedy is a new source control remedy combined with ground-
water collection and treatment. This remedy would remove a substantial
portion of the liquid wastes, including many highly toxic and mobile
volatile organic compounds, from source areas, thereby reducing the volume,
toxicity and mobility of'hazardous substances at the site. It calls for:
- Liquid Extraction Wells (6.1.5)
- In-Place Drum Lancing (6.1.6)
- Excavation of Wastes in Adjacent Areas (6.1.8)
- Soil Vapor Extraction and Treatment (6.1.9)
- Source Area Capping (6.10)
- U-shaped Trench (6.2.1)
- V-shaped Trench (6.2.2)
- Southwest Interceptor Trench (6.2.3)
- Groundwater Treatment (6.2.4)
- Alluvial Groundwater Restoration (6.2.5)
6.4.3 Partially Revised EPA Remedy
This remedy is essentially the same as the Revised EPA Remedy except that
the buried drum concentrations in the Main Pit and Barrel Mound would be
excavated (6.1.7) rather than lanced, and the U-shaped trench would not be
needed. The use of excavation assures that all drummed liquids are removed
and eliminates the short-term introduction of additional free liquids to
the vadose zone resulting form lancing.
6.3.4 The HSC Remedy
This remedy is described in the Remedy Status Report which the HSC filed
with the Federal District court in Oklahoma City on June 30, 1989 and described
in greater detail in the HSC's Preliminary Design Report dated October 12,
1989, and also filed with the Court. It includes the following elements:
- Liquid Extraction Wells (6.1.5)
- V-shaped Trench (6.2.2)
- Southwest Interceptor Trench (6.2.3)
- Excavation of Wastes in Adjacent Areas (6.1.8)
- Groundwater Treatment (6.2.4)
- Alluvial Ground Water Restoration (6.2.5)
The HSC Remedy also includes capping of the three main source areas, but
with a less effective cap than that proposed in the EPA remedies. The HSC
cap does not meet RCRA requirements.
-------
TABLE 6-2
SOURCE CONTROL
Excavation of Drums
Liquid Extraction Wells
Drum Lancing
U-Shaped Trench
Soil Vapor Extraction
Consolidation & Cap-
ping
GROUNDWATER
V-Shaped Trench
Alluvial Recovery
Common Groundwater
Elements
HARDAGE SITE
COMPARISON OF ALTERNATIVES
HSC REMEDY
X
X
X
REVISED EPA
REMEDY
X
X
X
X
PARTIALLY REVISED
EPA REMEDY w
X
X
-------
6-22
The HSC remedy does not contain the following Source Control components
integral to both of the EPA remedies:
- Drum Excavation (6.1.7)
- Soil Vapor Extraction and Treatment (6.1.9)
- In-Place Drum Lancing (6.1.6) & U-shaped Trench (6.2.1)
(in Revised Remedy)
A comparative analysis of each of these remedies is the subject of Section 7,
-------
7-1
7.0 Comparative Anaysis
The remedial alternatives described in Section 6 have been assessed in
light of criteria defined in CERCLA Section 121. This Section of CERCLA
specifies that remedial actions must:
- Be protective of human health and the environment;
- Attain applicable or relevant and appropriate requirements (ARARs);
- Be cost-effective;
- Utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable;
- Satisfy the preference for treatment that reduces volume, toxicity, or
mobility as a principal element or provide an explanation in the ROD as to
why it does not.
In addition, CERCLA places an emphasis on evaluating long-term effectiveness
and related considerations for each of the alternative remedial actions
(§121(b)(l)(A)). These statutory considerations include:
A) the long-term uncertainties associated with land disposal;
B) the goals, objectives, and requirements of the Solid Waste Disposal Act
(i.e., RCRA)
C) the persistence, toxicity, and mobility of hazardous substances and
their constituents, and their propensity to bioaccumulate;
D) short- and long-term potential for adverse health effects from human
exposure;
E) long-term maintenance costs;
F) the potential for future remedial action costs if the alternative
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.
Nine evaluation criteria have been developed to address the CERCLA
requirements and considerations listed above, and to address the additional
technical and policy considerations that have proven to be important for
selecting among remedial alternatives. These nine criteria are discussed
in a memorandum entitled "Interim Guidance on Superfund Selection of Remedy"
from J. Winston Porter, Assistant Administrator dated December 24, 1986.
The nine criteria are organized into three groups:
Threshold Criteria:
1. Overall protection of human health and the environment;
-------
7-2
2. Compliance with applicable or relevant and appropriate requirements (ARARs);
Primary Balancing Criteria:
3. Long-term effectiveness and permanence;
4. Reduction of volume, toxicity and mobility through treatment;
5. Short-term effectiveness;
6. Implementahility;
7. Cost
Modifying Criteria:
8. State acceptance;
9. Community acceptance.
If an alternative satisfies the threshold criteria, it is eligible for
further analysis under the Primary Balancing criteria. The comparison of
alternatives is given below as well as in Table 7-1. This comparative
analysis provides the basis for EPA preference for the EPA excavation
remedy.
7.1 Overall Protection of Human Health and the Environment:
The EPA excavation remedy provides the most overall protection of human
and the environment. Both the EPA remedies provide short-term protection
through the provision of alternate water supply the maintenance of site
security, and land use controls to prevent exposure to contaminated
groundwater. Although the EPA excavation remedy involves certain additional
short-term risks in implementation, these risks can be significantly reduced
or eliminated, primarily through controls on the emission of vapors and
dust during excavation.
The EPA remedies provide long-term protection through the removal of a
substantial volume the most highly toxic and mobile contaminants present
in the source areas. The EPA excavation remedy is more effective in the
removal of these contaminants than the EPA lancing remedy. Further long-
term protection is provided by continued monitoring to assure that the
remedy components continue to function as expected.
The HSC remedy provides the least overall protection of human health and
the environment, particularly over the long-term. It would leave a large
volume of untreated, toxic and mobile compounds, both in buried drums and
in source area soils. These contaminants would pose a continuing threat
threat to human health and the environment. The HSC remedy does not
address the liquids from the source areas until they have migrated to the
interceptor trenches. This process will take a long period of time,
resulting in considerable uncertainty. The HSC remedy also relies on
institutional controls to limit exposure to contaminated groundwater and
surface water. The long-term maintenance of institutional controls
-------
Sf » 30
IP ^^
• n so
SB
n M
«i
n °
X OB
n =T
S 3
Q 3*
ja
n Si
5. o
3^ »
a.3 3 3 8
»
Reduces the potential
contaminants being released f
sources, migrating away f
sources, and escaping from dc
gradient collection areas
offsite.
w ^ 3 2 _*,
&? 3 3 2
p Mitf m?iiiffis>
§.|* § a. 8 af 1 ^H^'S ? S |.|.iL8
-i8- asr«§» gsi a?-8-, |a
— — o ^-v £? a £• ST. 3 o CL a o 3 » 3 2
85 ? Q 5' ** 3l!-cro_.3oE.Q"33
_ n Soo • « a 9 o ~ 2. 3
is g-"aSS »a-S||l'2s|
2.8. 5 o » jf Q. ™ « ^8 § ffSa
s* 3. « 3 Q9 o 3 =- s; 3. — 2' *> »
MM ^* ^^? ^Me ^S ^^ ^5 **.' !3 *0 SS* ^3
n O^>n3 § ZT n 2 os 3Q.
2JL "^flflQIlB3^ CO S ** Si 3 •••
•" gsisg 2»--.»<'so'?3;aj
3 P"^ 8s»~ eg n-^»,3^nQ.
2 < H o 3. flTa.o<»ri?c/3g
i-o'sr§ » g B g 3 § ^ » i"2
§ 5^§» s, 1 2.1" B 8 1 1.!" 1
on
Q
?3
n
3
o
a
• • •
*es^o^c2 ^t2*^?!"^no/0 S-S1*
92.|§siff 2. •losisf «3«
fi^ias-His F|?g^H| ss|
*l « S. - <3 ««3S§»| 2 a. 8
3^° 3^-^ » 5-S"3.338 i'S.8
o^aBrt-n BB o»asi«::° oSs^.
2- «133^ ««3^Sg» 3~j?
o- -§S? Sg-gl^S. |o«
i-° o §3*5 aS^.§ 5- jfi- 33-3
^-^2^1^ 135s-! i5 ' Ii
UN lSlin i!
»* 2. «« £» 3 2 3SOC«3 a> 5,-n
n3 "o SS2'*>2*11^ w J^
» — Ssej^^,*1 o^
3c7nnv^^ 3D.a:«3'rtS» o.°?
3" «»"
. B
HH1!! P!
HHS 5}tMa« i?
fs-il|lj Uf
1 asti: HSH-l ?il
— s s^ a, o a y s tt 5>-
°8i:3 2, |iess?s =|
33ga«« ^-|g.£-os 3- g-
« ff 1 g 8 § So^^K-g 2^
~|22|8 S|^c£5' 1 Ii
•^^•-••o"^, — • E. «< c. ^ •" "* ai2
3^nrt2§in 5S>rnn5'r»2, a.0?
EPAV Remedy
With Excavation
•
O
£
i
?
»»
s*
a
•^
. 9B
e
•
!
f^
0
B
1 the Environment
8
1
5
3S
o
z
w
e
Table 7-1
MMARY ACCORDING TO
3
>
»
•<
n
RITERIA
-------
flip
&S£§->a
v>
g 0
£§ c I
a M 3 <
5? —' '
rt 2 a —•=
OB ^ 3 o c
M » 2 =/
3 3 £ S
llis I
83 Sg
3!" ;*•
09 3
w*
S o
g-3
£ »
Cn
C
oo
n
e«*
?3
rt
n
1°
•^
5*
i
^
5
f?
o o
s to
3 *• ft £T.
03 S o
i^Ilo
e CX n O
|0-
Q. 3
as 3
£ n
a«
s*
ea
I
i
3 2
2.3
3 ™
Ir
o"£.O>STBSH ^->
(gQE^gg.? 5
* e.S
r* c«
'
-
^ a O » S 5' <' C
« S _ a 5-£ § if >
2.
-
;jl
. n IS
OB a =•
3 M § 5' - - «
C^3 = = =:OS
n - *»
I'slfSlI
21
il
gq A
« 8.
M
g o
frg
3.2
s*
M
C
0
o
rt
»»•
8?
S 3
* rt
-------
S° » £<
o?3 25'2
§3 &3^
3 9 50 -
S X "*» Q
Mil:
Frll
Q.O O —*<•
•y ^*
if ilf
«A
-a,589
3* 3 ..
O 0.0.
CTJ =r "C 2. 03 _j
£ft C/5£2 3
>g O^S1™
«•i ••• * 5.,
2 a -. =n 2
oe 5
as-
sagg/S
*** ^^ *• ^4
f|i|*
r- O ~ 9--.
S
V3
Q
6«"
9
n
f
M
f
3 » S2. « •«
li^^S
a sag.
S/ o 3. Q.
Ifll8
all2?
—. «n 09
f* fi e*
rt&°"s
SB" S. 8 o 2 5
*Kff mi^
I If s-lj^
M « r-l s
S'H 3
f» 5? 03 3
3 rt
2 3
5' o
OQ.Q.
for co
Exca
tech
cont
Pit/
redu
|S,| 228 S
» o 5 | Is
v> ~
q? c
slSI-aS.
-i ft C. ft 3 U
• The dej
manageme
minimized
are remov<
i> -« w
aS"S3
09 x n
3 M 3
O. C ft
M n
=; rt ft o
« n % ~>
* X 09
«• O -J
«•) «M t\J
J* 3 *< _
P- SB O
i.15
mm *^ 1
i «
09 rt
3 — r "^
•» Z 3
M ft 3
•
3 5,2- 2.^
la|fi.
|>Ifs
*^ "* S
O 9 3 CM O
^» O 5 "i
_ . •* 09
f"^
3** I
2. o o "i ft
a§ o n •«
HI if
— • _. 3 Oq
K* 300^.
• — M f?
3* 3 "•
ft 47 03 3
^^s
-2
m«-
S?
ol 3
•T ^*
o'3-
3 ^^
-------
III
C/5
o
n
Reduction
rt
ment
SZ
— ft
, ^i
g-jn
8§
II
Sf
I?
» «
M* **
ST ^
n g
o'
II1H? f?f If 1
-
1
as
3
BS
55-0.
f!
sl
.M
2. n
Is
i
e ™
§3-
||
2
•^^ v»
S'*
-------
-i f> ea
i S-o
S Q
n =. 5
is
IEL
2.1
£5
TO
ft
sr
n
x
S
n
to
Q.
3 I.
5\3
l|
I'
•a rt S
T2. os^
3 -*
OP ~ Ct
• ars-
"S
w n
^3.
rt 0
^9-
9
S?
I
Me
^
V
i'g"
"S-l
3 «
9 ••*
rt *
3
» o
2; 3
i'«
^ 0
il
= 3
ITS
3<*
fa
3 e
£•3-
' S
•
§3?*
09 03 3 ft
CSP S. 3 09
J*83
S »>2 S
fst§
5" 3
2 0 09 <
• S' 3 S.
»* SJ
*• — cr
?3 «
S g-o
3 I 5
u p^
^ "* n
£ n
2. •»
^* or o
3-*ig Q.
S?
=•>
m»'
8 »
n? ft
~ n
s'*
-------
s?
O
<*>'
j
w
w
8
5'
I
g'S
1»
18.
I
et
I
o 9
i
BO
a
^
I?
-
a
e
2.
I « <
SB «i ee
*•!•§
«^2 o
CA O ^
-. n v>
3 "
O Q
O.OQ 03
^•> ft a •
sai
65 —
Si§
V Q. Q.
£3
§•2.
3*<
-------
s
I
n
3 I
- »
i'a
n
3 FT
s§.
on
n
6»r
50
n
3
«
i
ff»BJ
3" -n <*
§ 89 3
O O
5*3 I'I?
I*-3*
I s-r
I«|
« a 2.
S-S*
n - 3-
• ea
3SS
3 Sip
T3 S =
•* •• s
3 O."
t» w
•as
s&
08 o
II
S3*
i^-»>
5I
£.3
^
0?
PS
B
B
« 2. 2 H
o *5 S •?
LIE
SV
con
ope
cha
< c ^
1^1
«sl
n 0)
c. t«
K (t
— v>
0
S
S?glm
8SB.
s.ai
••• W ^M.
P " 2
£»i
88.
•a S =:
3 * -c
5 » S
n 3 Q"
3 a. w
01
I??
8 50
g n
ȣ
ff. ft
-------
= 8
3 -•
E^B
o' 3
= 8
> 3
QJ
N) QJ
IP
=• v>
O ~
3 II
O
r
-------
-
*
oi oi ro oo
3 Q. x rf
Q.C-I. rf 01
at -j rf
(/> o 01 ro
o ro o
-•• 3 rf m
—j rf -•• C
o -o
< Oi 3 T3
Ol -J • O
ra ro -i
O Oi ro rf
•J (/> X
« o
ro oi — >
X O < -••
n- 01 01 .a
T "O rf c
Oi T3 -i. -•.
O -•• O Q.
rf 3 3
"^ * tf}
O - 0
3 -f.
«
*
ro o ro oo
X Oi X rf
rf ~o n oi
-J -O Ol rf
oi -•• < ro
O 3 Oi
rfto rf (/>
-•.. -— c
O O -0
3 Oi 3 •Q
• 3 O
Q. O T
-*» rf
i/) in
O Oi
-.. Q. — •
Ol r\
< n c
oi ro -••
•o 3 a.
O rf
T ro
Oi X
T rf
ro T
Ctf flu
to n
• rf
o'
3
*
•0 -» oo oo
C -<• Oi rf
3" -h ai
— • *• ro rf
-«. rf ro
0 rf«<
• 0 3"
O Oi
f. -ft w>
0
T a. o
7C -J O
ro c 3
-530
t/i ro
— < -j
Oi QI 3
3 3 in
a. n
_.. -j
rf 3 ro
3* (O (Q
ro ai
Qi T
3 Q.
Q. -••
3
(0
*
rf 1/1 oo
O Oi rf
-f, O)
i ro rf
O rf ro
T ^<
?^ 3*
ro o ai
i -h t/>
(/!
ro o
Ol X O
3 n 3
a. oi n
< ro
rf oi -1
3" rf 3
ro -<•
o
•O 3 T
c ro
C^ Cu tQ
— • 3 Ol
-»• Q. -J
n a.
-" 3
O^lQ
*
ro oo
— •* rf
ro oi
3 rf
ro ro
3
rf in
vn C
. -a
•a
o
-i
rf
in
0
o
3
-J
ro
2
ro
Q.
*
ro oo
— ' rf
ro a>
3 rf
ro ro
3
rf co
in c
« -a
•a
o
-j
rt
o
O
3
-J
ro
S3
ro
Q.
*<
*
ro oo
— ' rf
ro oi
3 rf
ro ro
3
rf in
en C
• -o
•a
0
-J
rf
m
O
O
3[
0
3
•^
ro
fD
a.
^
*
oo o
n- o
ai 3
rf T3
ro o
3
€ ro
0 3
c rf
_4 (/)
CL
Ol
•a -j
T ro
ro
•^ Ol
ro n
-s n
ro
§"^
rf
T Oi
ro or
-s ro
ro -
< c
O) rf
*
3 « oo
ro oi rf
3 rf oi
rf ro rf
-j ro
ro
— ' -5 (/»
ro ro c
33-0
ro o -a
3 < O
rf 0) -j
4/» — ' rf
• in
Ol
3 01
Q. — '
rf
-J CQ
ro i
Ol O
rf C
1 3
^r*
00
o
«
in
•X)
ro
3
ro
a.
^^
3C m
—i. ~&
rf >
3" -
in
I—
01 33
3 ro
^* ro
3 CL
US ^<
Q.
*
ro £ oo
— ' Oi rf
ro rf oi
3 ro rf
ro -j ro
3
rf T in
(/» ro C
§~O
•a
< o
CW T
— « rf
in
at
3 Oi
a. — <
rf
T !£)
ro T
Oi O
rf C
ro a.
3
rf
£
-.. rn
rf -D
3" J»
•
m in
x
O ^3
QI ro
< 3
oi ro
rf QL
— *• *•<
O
3
CO "-" — 1
« f) Q)
O 3-
3 — •
oo rf ro
rf -<•
Ol 3 ^|
rf c I
ro ro i— *
a.
-^ ^_j
o
o
ro
•a
rf
at
3
O
ro
-------
~i o
ro o
n
o
Q) < C
3 01 3
3 r-r
CD a/ "•<
3 3
r* Q.-Q
-J
oo a. ro
o ro -t>
c oo ro
~i rr ~t
O T oo
ro c
oo n 3
o
3
O
o
o
o —i
o ai
3 -3-
r-t" —i
--• ft)
3
C -~J
ro i
Q. I—
o
oo
73
ro
ro
a.
O
n
ro
•a
<-»•
O)
3
n
ro
T Q. r* O
ro ro — o
3 oo o 3
ro n- 3 3
Q. -i fl> C
<< = — ' 3
• O -••
rr -J re
— ro <<
O 3
3 O l/>
< C
_i. O) "O
3 — '-a
o
el- Qi T
3" 3 rt
ro o. oo
a.
a.
oo
a>
3
n
ro
3 a.
oa <<
3- ro o
ro 3 3
o 3
rn < c
-a a» 3
-J Oi *<
ro 3
3 a.
ro c
a. CL-O
<< ro T3
• oo o
n- -j
-I rf
C 00
n
_i. a,
rr Q.
O Q.
3 -••
3 O
3
m oo
x
n 73
a* ro
< 3
ai ro
(-1- Q.
-------
7-13
results in further uncertainty.
The EPA remedies take a more direct approach to protection of human health
and the environment. The first element of this is the removal of contaminants
from the source areas and destroying them. By removing and destroying the
contamination at the source, any uncertainties as to their future threat are
minimized.
The threat to human health and the environment is most acute from those wastes
which migrate the easiest and by those which are known or suspected to cause
cancer. The EPA remedies both protect human health and the environment through
the rapid removal and destruction of those contaminants that are the most
mobile and carcinogenic. Both minimize contaminant migration through the
elimination of contaminants at the source not only through removal of
liquids through extraction wells and either excavation or lancing of drums,
but have the added protection of soil vapor extraction (SVE). The SVE
system is predicted to remove 99% of the volatile, carcinogenic wastes from
the source areas. When they are destroyed following their removal the threat
from these contaminants will have been eliminated. In addition to controlling
the contamination at the source, the EPA remedies also protect against
those contaminants which remain through the groundwater recovery trenches
and elimination of infiltration with a regulatorily compliant cap.
Therefore, the EPA remedies have the multiple protection of extensive
removal and destruction of the contaminant sources combined with a ground-
water collection and treatment system to capture any residual contamination.
The primary element of the HSC remedy, on the other hand, is groundwater
capture and treatment alone.
In terms of two EPA proposals, the comparison is basically between the
excavation of the buried drums or lancing them in association with the U-
shaped trench. Both activities have elements of risk associated with
implementation, but the risk associated with excavation of the drums is
less than that of lancing as discussed in Sections 6.1.6 and 6.1.7. .
Therefore the combined remedy retaining excavation of the drums is overall,
more protective.
-------
7-14
7.2 Compliance with ARARS:
Section 121 of CERCLA provides that, except under certain narrow
exemptions., remedial actions shall comply with Federal and State laws that
are legally applicable or relevant and appropriate to the contaminants and
circumstances of the site. The process by which potential ARARs are
identified, screened, and analyzed to determine if they actually are ARARs
is described in "CERCLA Compliance with Other Laws Manual" (EPA 1988a).
The alternatives described in Section 6.4 are broken down below into
remedial elements to facilitate the analysis:
ARARs may be identified in three general classes:
1. chemical specific - for example, a drinking water "MCL" defines a
maximum acceptable concentration for drinking water;
2. action specific - for example, a landfill built to accept hazardous
wastes would have to meet RCRA 264, Subpart N regula-
tions and associated requirements on design of the
landfill;
3. location specific - for example, the hazardous waste landfill described
above could not be built on a flood plain.
Key among those ARARs, shown in more detail in Appendix A, are the chemical
specific drinking water requirements or Maximum Contaminant Levels (MCLs)
established under the Safe Drinking Water Act, and the requirements under
the Resource Conservation and Recovery Act (RCRA) which relate to the
construction of hazardous waste facilities and their closure. Table 4-2
gives the chemical specific MCLs that would apply to those contaminants
that have already migrated into the North Criner Creek alluvium. None of
the alternatives would result in rapid restoration of the groundwater onsite
to drinking water standards. However, the two EPA remedies would accomplish
this goal more rapidly than the HSC through the elimination of contaminant
sources. The HSC remedy would also fail to meet the RCRA requirements for
its cap. The RCRA requirements for the construction of caps are very specific
and the HSC cap does not meet them. The cap proposed under the EPA remedies
would meet these requirements.
7.3 Long-term Effectiveness and Permenance
Both of the EPA remedies emphasize recovery and destruction of the
contamination at the source. Through the removal of the liquids still
contained in the drums, and of contaminants in the contaminated soils and
sludges through soil vapor extraction, direct elimination of contaminants
-------
7-15
at their source is achieved. These contaminants are then destroyed through
treatment. It is through this early removal of the contaminants at their
source that the EPA alternatives are superior to the HSC alternative. Long-
term effectiveness is dependent upon the performance of the alternative
over time-. This long-term effectiveness is best enhanced through the
elimination of uncertainties associated with an alternative. The greatest
uncertainty with these alternatives is the potential for long-term
migration of contaminants out of the source areas. The uncertainty of the
capture of migrating contaminants by the groundwater trenches will always
remain and will grow as the time of operation needed for those trenches
increases. The EPA remedies effectively address these uncertainties through
the elimination of contaminants at the source. Once the contaminants are
removed and destroyed the uncertainty is eliminated. Moreover, the
uncertainty as to long-term effectiveness of the groundwater capture and
treatment systems is also reduced by the elimination of contaminants at the
source. If the magnitude of the sources of the migrating contaminants is
reduced, then any future risk of their movement through or around the
capture and treatment system is also reduced as is the time of operation of
the trenches.
The HSC remedy would do considerably less than the EPA remedy to remove
contaminants at the source and would allow their continued migration for an
undetermined amount of time. By allowing contaminants to remain in place
for a longer period, the HSC remedy is less effective over the long-term
than either of the EPA remedies. This is shown through the compound
uncertainties associated with the HSC alternative. The first of these is
uncertain length of operation of the HSC alternative due to remaining
contaminant sources. Added to this uncertainty are those of the ability to
maintain the system over this length of time and the increased opportunity
for contaminants to escape over this period.
7.4 Reduction of Volume, Toxicity or Mobility
CERCLA states, in section 121(a)(l), a clear preference for remedies which
reduce the volume, toxicity, and mobility of waste. The EPA remedies
would both reduce the mobility and volume of the contaminants through their
removal and destruction at the source. The soil vapor extraction, more-
over, would remove the most highly mobile volatile organic compounds from
the soils of the source areas. The HSC remedy allows both greater mobility
and volumes of waste since the HSC alternative would only recover the
contaminants that enter the two HSC interceptor trenches. Waiting for the
wastes to migrate to the trenches allows for a greater volume of contaminated
material as the contamination spreads to greater amounts of groundwater
and soils as it migrates. The mobility of the wastes is also greater in
the HSC remedy than in the EPA remedies as it allows the wastes to migrate
and become more dilute rather than taking the more efficient approach of
capturing them and destroying them in concentrated form in the source
areas.
-------
7-16
The treatment of source areas with soil vapor extraction would remove a
portion of the carcinogenic compounds in those areas and destroy them
reducing the toxicity of the contaminants rapidly. Again, the HSC relies on
all contaminants to enter their collection systems. As for volume of contami
nants, the EPA remedies, by eliminating contamination at the source, would
directly reduce contamination through the recovery and destruction of
contaminants and would reduce the future volume of contaminated material by
eliminating the migration of these (contaminants and their subsequent
contamination of soil and groundwater as they spread). The HSC remedy would
allow the migration of contaminants out of the source areas not only
further contaminating the groundwater and soils between the source areas
and the collection trenches, but increasing the potential for the escape of
contamination both vertically and horizontally either under or around the
control systems.
7.5 Short-term Effectiveness
The short-term effectiveness for the HSC remedy would be higher than that
for either EPA remedy as, since nothing would he done about the
contamination at the source, there would be none of the attendant risks of
taking action. It should he noted, however, that the short-term risks of
taking action can be addressed through use of appropriate safety and
engineering methods.
Both EPA remedies pose certain short-term risks. If the drums in source
areas are excavated, then the soils around the drums will he disturbed and
exposed to air. This creates an opportunity for volatilization of
contaminants. The risks associated with excavation and lancing of drums
have been examined. The risks to onsite workers are related to the
excavation and handling of the waste drums and the surrounding materials.
Drum excavation has been successfully implemented at a number of hazardous
waste sites (see Table 7-2) and the effects are known. Exposure of site
workers to hazardous substances and situations during the implementation of
either EPA remedy can be minimized or prevented with well-planned and
implemented personnel training programs, the supply and utilization of the
appropriate safety and personal protection equipment and the development
and use of an effective site safety plan.
The risk to individuals offsite has also been examined. The primary risk to
those offsite comes from release of volatile chemicals or contaminated dust
from the site. This contamination could reach individuals through two primary
pathways, inhalation of volatile chemicals or consumption of beef and milk
from livestock maintained in the area. The total extra lifetime human
cancer risk from ingestion of beef and milk is estimated to be seven in ten
million. This also assumes, conservatively, that the ten million
individuals exposed obtain 100% of their beef and milk from the effected area.
More realistic stimates of exposure and ingestion would reduce the seven
extra cancer ri ; in ten million exposures even further.
-------
M
IS
(*
H
•r
23
I
?
I
<°
I
-i
I:
9
IB'
O
z
i
S3
r*
i
lo
3
•
to
o
S
a.
a.
e
r
o
o
•r » f->
-------
Zi
M
M
« w
OF
I
1
o
o
3
3
(0
Q.
r
Us
fl?'
* 8 to
yaara
2,-
f
r
i
B.
f
S
I
B
-------
-------
7-20
The total extra lifetime human cancer risk from inhalation of chemicals
released during excavation of the Barrel Mound and part of the Main Pit is
estimated to be one in ten million. The estimated risk from operating of
the SVE system is six in ten billion.
The opportunity for volatilization can be reduced through using the smallest
possible working face and thereby limiting the contaminated materials exposed
to the air. Common sense precautions such as excavating during cooler
weather will also reduce volatilization. The use of volatilization control
techniques such as foam supressants can also be used.
Other short-term risks were also considered. The intermingling of the
drummed liquids can he limited through the segregation of the drum contents
as they are removed. The short-term risks associated with the drum lancing
proposal include those associated with the physical puncturing of the drums
and of the mixing of the liquids after they are released by the lancing.
The risks of lancing can be reduced through the use of controlled lancing.
The work would proceed gradually with the removal of liquids released as
rapidly as feasible during the lancing. The lancing work could also be
done by remote control to protect site workers. The risks of puncturing
the drums could be reduced through the use of non-sparking materials on the
lance points and through the use of carbon dioxide to eliminate the oxygen
supply through the lance hole if needed. It is important to note that there
is already extensive mixing of the source area liquids as evidenced by the
amount of pooled liquids in the Barrel Mound. This would indicate that the
risks from further mixing are less than might otherwise he anticipated.
Of these two alternatives, excavation poses less of a short-term risk. It
allows greater control and observation of the hazardous materials that are
disturbed.
7.6 Implementahility
The majority of all three alternatives use established technologies and
could he implemented. Only the lancing of drums has not been attempted at
a hazardous waste site. The lancing technique has been demonstrated for
the puncturing of buried drums and has been used for other industrial
purposes. This one point leads to a slight preference for the EPA
excavation alternative and the HSC proposal over lancing for this criteria.
7.7 Cost
Because it is a less extensive remedy, the HSC remedy is cheaper than either
of the EPA remedies. It is important to remember that the HSC proposal is
not an equally protective remedy when compared to the two EPA proposals.
The relative estimated costs for the three alternatives are: HSC $46 million,
EPA with excavation $63 million, and EPA with lancing $59 million. An
additional consideration is costs associated with remedy failure.
-------
7-21
With greater amounts of waste remaining in the source areas for a longer
period under the HSC remedy, the potential exists for greater costs should
additional- remedial work he required.
7.8 State and Community Acceptance
State comment on the proposed plan for remedial action can he found in the
transcript for the public meeting held on Octoher 26, 1989 and in their
letter of November 13, 1989. Basically the Oklahoma State Department of
Health as representative of the State of Oklahoma supports elements of
EPA's selected remedy including soil vapor extraction, hut disagrees with
with the excavation or lancing of the drums in the source areas, and with
the use of catalytic oxidation as a thermal treatment.
Public comment expressed at the public meeting showed a preference for
quicker action and for more permanent remediation. To quote one of the
local residents who spoke at the public meeting,
"... Personally, I think that the way that some of the basic
ideas that you have got about addressing the cleanup of this
is good. I particularly like the idea of removing the drums.
When you start taking these materials out, when you remove
them from the site completely, it's the only way that you are
going to create any kind of confidence that you have really
cleaned it up."
-------
8-1
SECTION 8: THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA as specified in
Section 7.0 of this document, the detailed analysis of the alternatives,
and State and public comments, EPA has determined that the Partially Revised
EPA Remedy involving the excavation of drums for liquids removal, is the
most appropriate remedy for the Hardage/Criner site near Criner, Oklahoma.
A schematic of the selected remedy is shown in Figure 8-1.
The first element of the selected remedy is the removal and destruction
of contaminants in the source areas. Free liquids within the three major
source areas, the Barrel Mound, Sludge Mound and Main Pit, would be removed
through extraction wells. Organic liquids would be transported offsite for
destruction and aqueous liquids treated onsite. Drum concentrations in the
Barrel Mound and Main Pit would be excavated. Liquids in the drums would be
removed and taken offsite for destruction. Solids would be restored to the
three main source areas." Contamination from adjacent areas would be consoli-
dated into the three main source areas. These source areas would be treated
through soil vapor extraction (SVE) to remove contaminants. The resulting
SVE effluent contaminants would be destroyed onsite using thermal treatment.
It is this element of the recovery and destruction of the contamination at
its source that is missing from the HSC remedy and which confers the greatest
degree of superiority to the selected remedy over that recommended by the
HSC. The reduction in the long-term uncertainties associated with leaving
large portions of the source areas of contamination unremediated, as in the
HSC alternative, is another area in which the superiority of the selected
remedy over the HSC alternative is demonstrated.
The second element of the selected remedy would be control of residual
contamination. The major source areas would be capped first temporarily
during treatment and removal in the source areas, and then permanently with
a regulatorily compliant cap following completion of the main treatment and
removal phase. Groundwater would be collected through interceptor trenches
and treated onsite. Surface water controls would be instituted to minimize
contaminated runoff.
Finally, institutional controls would be implemented to prevent use of contam-
inated groundwater downgradient of the source areas. Alternate water supplies
would be continued to replace supplies lost through contamination. The site
boundaries would he expanded from the original site to the area indicated
in Figure 4-6 to facilitate the implementation of the institutional controls.
The estimated cost for the selected remedy is $63 million. Table 8-1 gives
a breakdown of this estimate and a detailed cost estimate can be found in
Appendix G.
8.1 Remediation Goals
The purpose of this action is to protect human health and the environment
through control of risks posed by the Hardage/Criner site and minimizing
further migration of the site contaminants. Estimates of the risk of cancer
from lifetime use of residential water contaminated at the level of the Old
Corley well range as high as 0.0007 (seven per ten thousand) to 0.006 (six
per thousand) far above the one per hundred thousand risk which is the upper
-------
DRUM STAGING
ic CONSC. DAT1CN
NORTHWEST
FARM
POND
i DRYING
\ SHED
L'QUIDS STORAGE
AND TRANSFER
BARREL
MOUND
EXTENT OF
PERMANENT
CAP
DECONTAMINATION
STORMWATER
DETENTION
BASIN
LIQUIDS /
EXTRACTION
/ CONTROL'/
i BUILDING/
V-SHAPED
TRENCH
SOIL/
VAPOR
EXTRACTION
CONTROL
8UILDIN
WEST
FARM1
PONC
SLUDGE!
MOUND
/ TREATMENT
INTERCEPTOR \
TRENCH
EAST FARM
POND £2
GROUNDWATER
TREATMENT
PLANT
- ACCESS
ROAD
EAST FARM
POND #3
SOUTHWEST
INTERCEPTOR
TRENCH
SITE SUPPORT AREA
HOMESTEAD
TREATED WATER
RETENTION POND
OLD STATE HIGHWAY 122
(COUNTY ROAD)
FIGURE 8-1
NORTH
CRINER
CREEK
SCHEMATIC OF SELECTED REMEDY
w/ excavation in Barrel Mound
and Main Pit)
HARDAGE INDUSTRIAL WASTE SITE
REMEDY COMPARISON REPORT
-------
TABLE 8-1
COST SUMMARY FOR THE SELECTED REMEDY1
Liquids Removal anj. .CpntrgJ $ 6,449,745
Drummed Waste Staging/Consolidation Area
and Storage ' 2,813,516
Soil Vapor Extraction and Treatment 3,098,052
Removal of Adjacent Wastes 2,168,834
Source Area Capping 3,722,605
Ground Water Extraction and Treatment 5,971,286
Remedy Support Facilities- 3,237,290
Surface Water Controls 196,000
Remedial Monitoring 41,250
Institutional controls 608,250
$28,306,837
Bid and Scope Contingency 9,907,393
Implementation Costs 10,317,842
Conversion to September 1989 dollars
Operation and Maintenance for 30 Years 14,309,500
TOTAL $62,904,655
1 Source: Remedy Report for the Hardage Industrial Waste Site, Criner,
Oklahoma, October 13, 1989.
-------
8-4
boundary of acceptable risk set in the National Contingency Plan.
To accomplish this goal, the remedy would permanently and significantly
reduce the volume, toxicity, and mobility of contaminants in the source
areas. This is accomplished through removal of liquid contaminants quickly
and directly through liquid extraction wells and excavation of drum liquids.
By following these steps with soil vapor extraction, removal and destruction
of the most mobile contaminants, including most of the known and suspected
human carcinogens, will be acheived. The goal of soil vapor extraction would
be a. 99% reduction of the volatile organic concentrations found at the
beginning of soil vapor extraction.
Beyond reduction of the source, the goal of this action is to restore the
groundwater to levels below MCLs. This action is particularly directed at
the alluvial aquifer assoicated with North Criner Creek.
The superiority of the selected remedy is demonstrated in the comparison of
the alternatives through the use of the nine criteria given in Section 7 of
this document. The reduction in the sources of the contamination associated
with the selected remedy confers advantage to the selected remedy over the
remedy recommended by the HSC. By eliminating the contaminants at their
source the selected remedy is more protective of human health and the
environment, has greater long-term effectiveness and permanence and provides
for greater reduction in the volume, toxicity and mobility of contaminants
than provided by the HSC remedy. The selected remedy can he implemented
using existing technologies and methods. Its cost is greater than that of
the HSC proposal, but the selected remedy through its source control elements
provides greater and more efficient levels of remediation. In this regard,
the additional costs associated with the selected remedy are reasonable.
The selected remedy would also comply with existing ARARs on cap construction,
which the HSC alternative would not do, and would attain the standards for
drinking water quality in the alluvial aquifer as expressed through the Safe
Drinking Water Act MCLs in a shorter period of time than the HSC proposal
would. The State of Oklahoma through its representatives has expressed
concerns about the short-term effectiveness of the selected alternative,
and some short-term risks do exist. However, these risks have been considered,
and they can be controlled or eliminated through the application of prudent
engineering and safety techniques. Finally, the local community, through
the public comment period on the alternatives expressed a preference for
removal and destruction of as great an amount of the contamination as possible
from the source areas. The selected remedy provides for far greater direct
removal of the source area contaminants than does the HSC proposal.
The selected remedy also holds advantage over the other EPA alternative
which included lancing. The lancing techniques have not been used at a
hazardous waste site before and therefore their implementability is not as
well known as the excavation of drums in the selected remedy. There are
also greater uncertainies associated with in-place release of the drummed
liquids through lancinc that will not exist with the selected excavation
program with actual ph; ncal removal of the drummed liquids.
-------
9-1
9.0 STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund
sites is to undertake remedial actions that achieve adequate protection of
human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences. These
specify that when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental laws
unless a statutory waiver is justified. The selected remedy also must he cost-
eff^tive and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. Finally, the statute expresses a preference for remedies which
significantly reduce the volume, toxicity, or mobility of hazardous wastes
as their principal element. The following sections discuss how the selected
remedy meets these statutory requirements.
9.1 Protection of Human Health and the Environment
The remedy seeks remove liquid contaminants quickly and directly through
liquid extraction wells and excavation of drum concentrations. By
following this removal with soil vapor extraction, removal and destruction
of the most mobile contaminants including most of the known and suspected
human carcinogens will be acheived.
Along with effective reduction of contaminant sources, the selected remedy
protects human health and the environment through intercepting and treating
contaminated groundwater with interceptor trenches. The North Criner
Creek alluvial aquifer is the nearest groundwater used as a residential water
source. The selected remedy provides better protection of human health and
the environment as it will achieve the goals for groundwater cleanup more
quickly than the HSC proposal. The selected remedy will eliminate uncer-
tainties associated with the continued presence of toxic and mobile volatile
contaminants in the source areas by recovering and eliminating contaminants,
unlike the HSC alternative which would allow these contaminants to migrate.
-------
9-2
9.2 Compliance with Applicable or Relevant and Appropriate Requirements
The elements of the selected remedy would all comply with applicable or
relevant and appropriate requirements (ARARs) established for this site. A
more complete examination of ARARs can be found in Appendix A. Key among
these ARARs are the Safe Drinking Water Act chemical specific requirements
known as MCLs (maximum contaminant limits), and the requirements under the
Resource Conservation and Recovery Act (RCRA) which relate to the
construction of hazardous waste facilities and their closure.
ARARs include:
1) RCRA requirements for landfill closure in 40 CFR 264.111 Subpart G
and 264.310 Subpart N which specify cap requirements for landfills;
2) RCRA requirements in 40 CFR 264.117 Subpart G dealing with Post-
closure;
3) Requirements under State of Oklahoma Air Regulations requiring use of
Best Developed Available Control Technology for treatment of the air
from the SVE system.
4) Maximum Contaminant Levels (MCLs) established under the Safe Drinking
Water Act;
5) State of Oklahoma maximum acceptable ambient concentrations (MAACs) for
air contaminants;
6) Oklahoma Water Quality Standards for discharge to a surface stream.
None of the alternatives would result in rapid restoration of the ground-
water within the site to MCLs. However, the selected remedy would
accomplish this goal more rapidly than the HSC remedy through the
elimination of contaminant sources. The selected remedy would also meet
RCRA requirements for the construction of the cap over the source areas;
the proposed HSC alternative does not meet these requirements.
9.3 Cost Effectiveness
The selected remedy is cost effective and would cost an estimated 63 million
dollars. It includes some 20 million dollars of cost directly related to
contaminant source area reductions, through excavation, soil vapor extraction,
and liquids extraction. The HSC remedy does not include these costs. This
additonal cost is reasonable considering the added long-term protection of
human health the environment provided by direct and permanent reductions to
the source areas.
-------
9-3
9.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies.
The selected remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost effective manner. The
amendment of the 1986 ROD, which called for land filling and stabilizing the
source soils and sludges, to the new selected remedy of excavation, liquid
extraction, soil vapor extraction and capping provides for a permanent
solution through additional recovery and treatment of contaminants.
The emphasis in the selected remedy is on the recovery and permanent destruc-
tion of the contaminants at the source. This begins with the recovery of
the free liquids and the liquids in the buried drums through excavation and
liquid extraction, and the subsequent destruction and treatment of these
liquids offsite in a permitted Treatment, Storage, and Disposal facility
and in the onsite water treatment system. It also includes soil vapor
extraction of the Main Pit, Barrel Mound and Sludge Mound to remove volatile
organic compounds.
Another aspect of permanence is the reduction of the mobility, toxicity or
volume of the wastes. The selected remedy accomplishes all of these goals
through removal of contaminants at the source, unlike the HSC alternative
which would allow contaminants to migrate out of the source areas.
Through removal and destruction of contaminants by SVE the amended selected
remedy provides permanence, particularly when combined with the groundwater
collection and treatment elements of the selected remedy. The groundwater
portions of the selected remedy utilize permanent solutions through removal
and treatment of contaminated groundwater and the destruction of the organic
contaminants removed during treatment.
9.5 Preference for Treatment as a Principal Element
Treatment is central to the selected remedy. Treatment is used extensively
to address each of the three primary contaminated media. Free organic
liquids from the source areas and organic liquids from the excavated drums
will be taken offsite for destruction or treatment at an appropriate,
permitted Treatment, Storage and Disposal facility. Contaminated soils and
sludges that remain following liquids removal and treatment will be consoli-
dated into the three main source areas for treatment with a soil vapor extrac-
tion (SVE) system. The goal of the SVE system will be removal of 99% of
the volatile organic contaminants from the contaminated soils and sludges.
The air from the soil vapor extraction system, and air effluent streams
from other remedy components, will be treated onsite with .\ thermal treatment
system, to treat and destroy the contaminants within the a^f streams. The
third major contaminated media is the aqueous liquids including groundwater,
-------
9-4
aqueous liquids from the buried drums, and surface run-off. All of these
liquids will be treated in an an onsite water treatment plant. The water
treatment_plant will be designed to treat the influent liquids to standards
for discharge in accordance with Oklahoma Water Quality Standards.
Additional advantages in the treatment in the selected remedy are gained by
treatment of the contaminants in a more concentrated form. This is true of
the free and contained liquids in the source areas due to the liquid
extraction wells and collection of the free liquids and the excavation of
the buried drums. The SVE system will also recover the volatile contaminants
from the soils and sludges in the three source areas allowing them to be
treated in a concentrated air stream rather than diffused through the soils
and sludges. Treatment of the contaminants at their source will also
improve the effectiveness of the water treatment system through reduction
of contaminant migration to groundwater. The contaminants will be treated
before they migrate into the groundwater where they would spread and be dilutedc
9.6 Documentation of Significant Changes
The Proposed Plan for the Hardage/Criner site was released for public
comment on October 13, 1989. The Proposed Plan identified the use of drum
lancing as an option for addressing the buried drums. Comments received
during the public comment period indicated particularly strong opposition
from the State of Oklahoma to retention of this option. While EPA feels
that drum lancing could be implemented, the option of drum lancing and
associated U-shaped trench has been deleted from the selected remedy and
only excavation is part of the selected remedy.
-------
REFERENCES
Hardage, Royal N., 1987. Deposition.
EPA, 1985. Field Investigation and Data Summary Report, Royal Hardage
Industrial Hazardous Waste Site, CH2M Hill, May 22, 1985.
EPA, 1985a. Public Health Assessment Manual, EPA, Office of Solid Waste
and Emergency Response, November 1985.
EPA, 1986a. Source Control Feasibility Study, Royal N. Hardage Industrial
Waste Site, CH2M Hill, February 20, 1986.
EPA, 1989. Remedy Report, CH2M Hill, October 12, 1989.
HSC, 1986. Final Conformatory Bedrock Study, ERM-Southwest, December 31,
1986.
EPA, 1988. Design Report - Source Control Remedial Design - Hardage
Industrial Waste Site - Criner Oklahoma, November, 1988.
HSC, 1988. Mound Characterization Field Study, ERM-Southwest, November 7,
1988.
HSC, 1988. The Hardage Steering Committee's Recommended Source Control
Remedy.
HSC, 1989. Second Operable Unit Management of Migration Remedial
Investigation Report, ERM-Southwest, May 10, 1989, as amended by EPA
Comments.
HSC, 1989. Second Operable Unit Management of Migration Feasibility
Report, ERM-Southwest, May 10, 1989, as amended by EPA Comments.
-------
APPENDIX A
EVALUATION OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
-------
I ;
! in •
3 511 s ;
" -.; $ ?
n
}5
1!!
fl
(CM
M
>l
^
II
-I
¥-
ss
}•
'"I
1
i
ff
•
•*
•
i
f
&
M
?? *!* 5H i:
-i Hi Hf -! ?
i 1 5 a » •* 3 • i. lS
?• 11 * ft-- ; [i
s? "If « a i
i *l '-! Si
n
ff
*
•^
5
*w
s
s
r
5
f
i
=5*1
*«• z
8
3
2 8
;?9
i!
ill
hi
lit
ii
';
{lip! HI
if* "
I
II
§?
5?
lil?
5TJJ5
1 3 » 5
si|5
Z. wT — JT
s^?^
? ° « 3
JgS
H!
!is
« M
< —
3 »
!S5
'I?
!l
^ »»
i ?
:i
!?
(• r*
s:
ii
*» 3
i"
J*
O. ts»
ss
y -»
•• •*
-1 -•
«n
T
1 *
2 c
u
II
w«
»
1*
Hi
1*
&
C
1
1 • • •
|K!
i
s
?
1
•
^
«
2
e
!
I
1*
i
*ft
n
!=
u
u
- 3
9 ?
' )
;*
* T
I
p
J"
ii
I-
-,
HI
ii
It
* ^
•i
f
-------
*
|
1
i
>
I
i
«
i
f
3
J
*
i
I
£
a
I
n
•j
«9
5
Ivltlaa that affect or •
let enr of the rivera
rifled In Section UTtla
?"?!
li 2
5""™*
Wiat avoid taking or aaslatinf
In action thai vlll have direct
advaraa affert on acenir river.
I
f
iff
rTo.£
i T a"
* «*T>
T —
s> •»
f|
sT
r*
S.
3 <«
^
H ••?
•s> •
li
*
a a • o
*i?l
fi!
= Jo
'iy
SI
* — e.
2 -
Nuat take action to protect flah
or olldllfe
3
!
•o. o
1?
a. -i
wi
X3 O
oE
-* 3"
i-» O
1 f»
i;
a?
O> I1J
^* W
o —
3 M
fit
&
lu
- i
n
-
m'n 52
rratlan of terrain that
patens significant
mtlflc, prehlatorlcal,
torlcal, or archaaoloqlc
i
•
III
sl
s
Must lake action to recover and
preaarve artifacts.
J
1
= 2?
= 73
X* a
• 23
??|
o 3
•«
• rt
at aa»
^ 1
fl
0 ^
|5
\
i
|f
C 1
;
•;
s
i
i
i
!
i
f
*
a
4
a
(
;
lied or bulk liquid hsiarrtous
vaate In a ault dosie formation.
aall bed forvatlon, undernround
•Ine, or cave Is prohibited.
?
S
;:-:|
J ^2 "3
?• jT_
a.:?;
lllll
in if
rj-t
- JH; ?
•• * ^* *3 •
5 * ~ *
jj *
2T
3 0
w *
i
F a?;:?
V--9 *
Z A » A ^
Ion that vlll occur In •
id plain II. a., lovlanda
itlvelf flat areaa ad)ol
ind and coastal vaters,
ft flood-prone areaal
: Hi
' s>!
i *JL
( 3?
> i
a>
i
•hist take action to avoid or
alnlnlie potential hara) tn flood
plalna, and reatora and preaerve
natural and beneflrlal values.
u*
'•
4 s>
tt n
-•» o
o
O r*
O. 3>
— v»
3 19
J
5
3
3"
i
3
1*
is
1 haiardou* Mete, treat
, atoraoe, or disposal
i
S
i
X
«
•
5
Treat ornt, storage, or disposal
facilities vlthln the ITO-vear
flood plain aust be designed,
constructed, operated, and
•alntalned to prevent vashout.
•5
V
;
H
? i
-* o
si
"
-— v*
3 li-
lt
§
If
23
^ o
<« a
a3
•
5
—
| 1
J 5
•» •
e •
^ «*.
s:
:•
i
*
O
0
JJ
c
Cl
•T
— ^« a B
*nf!
!ui
lit*
— a •
— a i i*
a
.
f
2?
n
i •
• *
w
1
F
w
a]
T
3
•V
f
[
n
£
oui. tnrATioH-snrii
^
O
»
w
-------
3 — 99
5 * f 2
S ! -7
^ ' !«
a* 0 ^
:' i!
i i'
H i
o •
• •» 1°
1 |J
5 ' t
Z 92
- I1
I;
Q <*
i f
a ••>
8 1
y fs?f
1 2-1:
i : 1s
i
«
Mist take action t
destruction, loss,
dear adat Ion of vet
proprlate.
i'i
a
m
a
**
9
a
f
?
"?
17.
i-
S"
*•
-1
Yl
A •
i r
„ |
i?
- 1
- •
i
j
•
j
2f5
rti
abltat upon
species or
species de
1 *
SJ2S5
3 3 "l» 1
§1 '
Nust take action t
endangered species
species.
o conserve
or threatened
f
?i?
a w
s,-
u t
If!
lr^ *
^ 1
Iff
^
3 —
a
?? *
* 5 a"
i:|
872
9 W
51
• o
III
jii
r
*ss
31* ^
^
^B»
Must taka act Inn t
historic proprrtle
ront rolled by fedr
Misl plan action 1
hara to National H
landMrks.
o preserve
s ovnrd or
ral earner.
o ejnlalte
Istoric
f
f
5S?
If?
51
.-!
' *-
— s
li
if
~
3
•
*
*
i
f
"
j
s j
a —
• s
1
affectlne,
i
f
i
WM <•»
83
§g
"?
o
a — • <» BI
?!?$!
rt —•.—•»
"S.lft
:S7S!
fU!3
*fi*l
• Sin
a 9 I
5**H
?!K
?a»
9
z
o
W»
1 £ ^
3 1
— . ro 1/1
r» a* r*
03-1
T C
— . — . fl
3 t/t ft
* -0 T
a>
3 O
3 1
(D
0 -1
T 3
3* e
at i
3 -•*
Qi
rD
i*?2
4 So
J"*
«• V
* » w»
5*1
5
!
s,
i
5
f
w
w
;
I
§
5
Must avoM undesir
upon landaarks.
able Impacts
f
f
fW
n
• a
ill
f * t
j ~ »
'«s«
» —
F-f
. | _
?2
n » "^
— i
-'•i
'
§
q
• w
i
I
*
o
f
f
£
* *
0 w
n "
la
*d 1
9t
Art Inn to dispose
•aterlal Into nrea
prohibited vlthout
;I
=!?
•
f
?
•a z
1 O
o
-o a»
o n
Wl f^
n -•
a o
3
CM
r*
m
vt a
n
• I
m
aw
V*
? 2
= 5
S T
rt
I
>
2?
5> 2
M N
1
|
e
f
£
s
o
*
I
1
•
Art Ion to dispose
•aterlal Intn ore*
prohibited vlthout
;iJ
3:1
rl*
«
f
3C
• o
a>
n
,-»•
a
3
o
' Q.
. ta
. 3
at
«-••
O
i
a*
VI
??
I i
1 *
iS1
-
Hi!
•< •» w •»
llsf
Ii]
!r
'rfs
11 i^
nXist conduct actlv
•anner consistent
slate .anaaeavnt f
II;
>t;
0 «
3
a
f
f
*?
•• VI
ii&
»»•<
• •
jj
VI <••
'*
3 -*
* 9
M —
l5
|'
Z
*
i
I
•i
«
i
w
*
H
n
a
7
3
?
Lt
rrlptlon
.1
^ t
O
» •
1*
1
vl
-------
a
I
H
* 7
t f8
S
€
??
&
I5
l~ o
n
155
m
wtal
(ha
I < a
< » f
i •• ^
-1
i
If.''
LI
ii
It •
?i
f:
• «
ci
• >~i
•" i
•? II
Ti
3 •<
il
-------
I f
8 !
v* «
i
i
tt
1
I
8
7
*
4
ft
3
|
i
i
22 ??T
11
? 'I
S
ru ft?
i ? £ ?? —
* *
3 *
f !
e> •»
II!
m
™**
3 *
I1
ill
*
1
*«>
t Contlnftncf 1
teriqvncr ft<
II
HI
!!l
rtf
** 3
j"
f
a
f!
i
•*!
!i
Is
" 4
*
|
o
o
M Cl
1!
*|
*
<•
il
t{
it
If
y i
1
f&
Esffi
i* il
1 «,'
f
i
i
1
*
s
o
a
1
ill
-i
is
il
II
£*
s
S
x
:f|
Hi
flf
\s
H
I
A
5,
f
•I
S
n
S
W M T
""Is
-I
:s
|i
if
•0
S
I
o
n
I
\ll
M *•
f"
1
f
ft
i
s
ri
I
?y :
?-In '«
«» *• • •*
* — S 2
5~ J
o
f
k
w
*
S :
n "
3 ^
S *
!
1
3
: ? ?
Ho/Tra
1
f
I!
ss
*»
ft! 5I!" *!!!? i'
2?i il :=« |I ?|f -i
»« I *• 5e» t> •> J s -»
?Ii i: :5i }l ii: :i
atn | 5»i «a »1^ f.
j> e • 5 yi • « 9 * a *• < •
;! l| J|S -IJll't
» - s - * » » . r
:? 3-!
=
f 7«2,<
tS fQ T
fir
1
y
?
i
im
!
^
t*
a> sr T — .
r» a* n —
3 is. n n
3 T < V
o -i m
»/i C fD
ft rt) ^. O
3 k/* ^ -«»
c a.' wi
-------
j J
i
^ •
§ '.
I
\
3
-
!
s
2
f
S
r
7
4
i
i
i
i
II
* *
• r
f
M
.5
if
H
if
'•
O
3
5
0
li
ii
H
!|
• J
Hi
•r
•
*
o
3
*
|I}[f
"fffis
"!l*
w ^ ^
}•'
!1
13
11
^r
i
i
*
s
i
x
-
f-f • f I
J * — « 4 ft
i^U;
£ i\H*
5 -*5
'*J
~ • n
* ••
*;
<* •
i*
a «
§
i
X
»
1* j ~f ;
•• O — • ^ ^
fHl;
•?;i|
|sil
• :?
•i
s
3
X
Wi
Q
a
5"
_
i"
f
•
i?
••
li
i)
— .
ft
f
i
|
gg
-
*
[
|
SIT
li
??
*
i
r
•
•«
I
!
9
f
11
3 =
n
i
m
•
^
•
"9 Ul
a, c
i o-
u
ISJ 1
L *
o
J
a
2
I
a
n
n
9
•«
•
n
t
r
•
r
•
!
f
*
4
:f
? I
n
is
2r
H
1
if i
' i
I "
1
pr si
|»J ;}
•:h!
!. 1.
?* r~
:;;;
ir ;r
li i
4
! !
-i
5
[i
1
If
^1
it
•
i;
"r
•
f
M
f
1 •
4 I
;i k
V
*•!
!J!
i S^
* • *•
iii
=ai
•»aj
3"
1
( 13
:->
25
-;*
u
i!
12
;s
»
a
r
f
ii?
I;i
8 —
• •
r j
* •
' »
:'-
u
3 ?
a •
§
mi
ill;
H
'-f!
{!H
hn
J£»s
J •
^
1
If
•• ?
i!
? 1
i
*
•
j
f!ri} !
ISS-i frj
Jl!l*iJ
ih^;1!
SJHfH
•II&MI
?•*•!!-
TiiUf
a:=iii
f 'S
•
I
1
Mill
• a * *
* f IS
:;|l
' 5 —
r 1, 2
? ?
[?}{
i ? *
5 M!
;2 * • }
«=H*
1 » 5"* 3
Hill
1:5!
^ 5 •
IHr
i""
m
I
1
2 •
a ?
i i
?r
i;
i^
^ ~
'"!
;
» ^
r-5i=i|iii
M-^ahn
;i«r=::-:j
=ri.:.iir.
:• 1 ;- ii tl
ISfftilll
?i»*-':!i
Sf 5ilf i
is ;
f
^
i'
~ y
rg
«•
s
T
j
•
c
« a 01 •
5 i.£ »
—i 3-
— 'Ji
V Z"
-^ /.
3 J)
— 1J
3 1
30 O,
yi
n
li -n
•a o
i
i
J3 a
C N
-* to
t 0,
3 O
3 on
'— C
a>
(fl
F : J J
? "i" »_ f
I
I
f M^ ? If
. Is^S 1 *l
* i a M n i _ ^
* 0 ^ — — ^ J2
1 15=5 o J
» sZsC - I
1 "°.3 ;• i
Z J|^ | _
* •* •» !L a
S 5»o ~ -
- Is! -;i
~ 3 ^ 3
*
s
^
9
f
|
-f
V
^»
•
*
£
.
I
C
I
m
; 5 ; ;
» > » »
S ? ? 5
ii t '
iii
S£ jf ;jj
3 — I ' ii
r* -*. ^. < •
T n • - t
El I -1}
:? ! ;:«
°» li
|| .- !$
Q. Q* » 0
n J
a, ^ •
ai 3' e —
Q. O * 5
0 C .1
C 3 * M
i/i Q. ^
3 v
< S
Oi 3
;
o
9
a
1C
fl
- f
J*
• 9
'i
A
1
1
-------
i S
— 1
-•
J
i :
JB a
»
t
I
1 Is ajBl Irani*. It
n
a
S
7
*
7
1
i
1
|
•
i
55! f 1-f
Zll 5 5*!
s-i ^ IE
521 : **
* z S O * r»
•i § 51
f 1
r 2
i i
• •»
*\ «»
i i
r
1
•
s s - =
i« M
" 1 i
i
pi! illl
!*iri l&a?«
»n« • — •» *
Hi} lllii
f bm
l! Kill
1 * n
r ll
» f
1 r
n -i cyi • 2
3 fw o *r
— — 3 r i
i^ r» fO * i
1^ <
— . oi -o •
O 3 O •»
3 r* 1 «
trt r* •
-^ 3 O' ••
-I 0. 3 •
la"1 j
•a o J
™ 3 I »
•a o a
<5 ~* ^^ '
51 "*50 1
3 O ^
*"" 0 0 »
?o«lc Subalancrs Control
(U-t IT5l»(
?
Ss5
iijj
2 1
i
ii
If
ss
|
•*
•» — n
a. f»
f-o OB
•> 1 W>
-» 3 a.
i a.
19 1* r*
< a. i*
— « O r»
•*i a.
- 3
7
H*rlf-« l^rotvrtlofi
•tetearrti •**4 Sanctvarlv*
Art
i
-
z
jj
i
*
i
i
1
|
ll
ll
3
^
Tot l*r PoHutanl
tf fluent Standard
Ii
* •
if
<8 O
a"
s
n
•»
talab(l«n*«
or prnhlbttl
toilc noilul
rfflvrnt atandarda
Ions for c*rtaln
> lit S .
i
i
i!
S|
|
I
•
•*
W •
a ••
• 1
& —
«
v
*
«
1
Pollutants that pai
•r lnt*rf*r* »lth I
prorrasaa In POTIrs
~ a
9i
:•
If
o
S 2
3 %
•a* M
"• » ^
^ *> — •
«' iSS
I?0!?
1
i i 3*' i
rllffM
•« 5 ** * ~ • j
^'•I'i
=iH-
3T7;v}
!!»!--
1 " J** 2 •
_ j - -
UMlr><|rnund Infer (Ion
-«ulj<( <•«•• bu| |» MK>I*
.(|»l |U (01(00, 10)
uu||a|iuWg iiMixtui^
— £
i »
JTSJ7
I'll
2 " at It
mAcr* «ou!4 require
HI ot vol«t 1 le
»slong fro* Prorturt
Vessel.
M
C •
~ •»
^ 9
;j
* «
?i
i
•
1
—
Drwlrrqioontf 5lor4)*ye
i*m** nrrri
f
1
i
i
*
a
n
S
a ?
•i
0 mt
H
ii
w •
£
**.
„
tt
if;
|f
• 1
i -
^ ••
-1
3
B
I
7
n
I
I*
m
5
f
if
a —
If
If
j
•
-------
8
7
1
•
«
4
!
j
i
I
w
HZ » «
- • 5 •
5:3;
<* ** 00
f?!=
ft u
!:
^ S
j* e
"£
3
0
M
|
6
Is
?2
*
If
«*
1
f
IT
?
S
2
I
•
i
W
H
5§
st
*«
a,
i
a
£
n
i
8
"
UB
is
11
5
a
3
f
w
ft
1
3
I
S
||
2f
*
j
0
S
£
i
^
1
~
-3 8
S C
Si
f!
8?
75
^ (•
n
W *"
• ft
3
O
M e * u v i* -• w
l!f H |«
if? r« "Si
2*3 "7 "
&?§ ? !•}
8» a *• — — a
w — 7 o » H
t 5 J 5 a" a
3"S a !S
' - ^?
f !
l!
i ^ ^
• * 3
• w a
• t
«l
• |3 i(
" s • • -
i" ?;ii«
-------
if r° n
H 1 =:
~° i "
= o
t| = S
»*• " ?
-i
*«*
a. »
- O 3 JO
£ J ?• •»
2
i
£
T
I
I
a
3 -y
I I
S?S
3 Ml *
I!
? if
— «
s-
aa
•
o
s
0 S
» 1 — a o
« 3 t f*
— »» M e B
Hrll
S5ls*
f 5*??
S-* — -i •
« * **
-»<••*
n° '^3
^^5»«
-2-JS
C » 0. r*
-» **^ *•
MiL'
1 ??§
y * c *
i n-*
J . 0.
0 »e •»
-» y wt t
t-n
?*ss
• j?-
s-s-*^
:==s
^E2
-» 0 3
?;is
? I" 2
•» «• * 3
15J
a 3
f .!
» w» —
— w* rt
« -I »
II
• *
-i t S
517
as
-------
APPENDIX B
AGENCY FOR TOXIC SUBSTANCES DISEASE
REGRISTRY EVALUATION
-------
Health
Assessment
for
ROYAL HARDAGE INDUSTRIAL HAZARDOUS WASTE LAND DISPOSAL FACILITY
CRINER, OKLAHOMA
DECEMBER 1988
I
-------
SUMMARY
The Royal Hardage Industrial Hazardous Waste Land Disposal Facility
(Hardage/Criner) National Priorities List (NPL) Site is located in Criner,
McClain County, Oklahoma. The site is located in an agricultural area.
There are volatile organic compounds (VOC's) and several heavy metals
present in the groundwater and soil, and VOC's in surface water and
sediment. The Record of Decision (ROD) for the first operable unit
(source control) signed November 1986, selected several remedial actions
which included excavation of the primary source material and separation of
the wastes for treatment: solids to be disposed of in an on-site landfill
which meets Resource Conservation and Recovery Act (RCRA) requirements,
organic liquids to be incinerated, and inorganic liquids to be treated by
other means as necessary. This site is currently in the remedial design
phase.
-------
BACKGROUND
A. SITE DESCRIPTION
The Hardage/Criner NPL Site is located in McClain County, Oklahoma, on
60 acres. Operations began at the facility in 1972. Several pits were
excavated in the early years to receive wastes from barrels and tank
trucks. The pits filled rapidly. The wastes were then transferred to
temporary ponds. In the west pond, the wastes were slurried with soil and
transferred to the south pond. The south pond was eventually filled and
the wastes were then stacked to a height of 10 feet above grade. This
became known as the sludge mound (see Appendix).
During the mid-1970's, drums were no longer emptied into the pits, instead
they were piled at the north end of the main pit. This became known as
the drum mound (see Appendix). During the late 1970's monitoring wells
were constructed in the southwest corner of the site. These wells
indicated the presence of contamination.
The wastes received by the facility included: oil recycling wastes,
chlorinated solvents, styrene tar, acids, caustics, paint sludges, lead,
chromium, cyanide, arsenic, pesticides, inks, polychlorinated biphenyl's
(PCB's) and large quantities of waste from injection wells and other
nearby facilities including two NPL sites, Brio and Bio Ecology.
Operations ceased in November 1980. Closure activities continued into
1982. There was an effort made during the closure activities to
consolidate the wastes into major source areas. These source areas are
identified in the Appendix.
The ROD for the first operable unit signed November 1986, selected several
remedial actions which included excavation of the primary source material
and separation of the wastes for treatment: solids to be disposed of in
an on-site landfill which meets RCRA requirements, organic liquids to be
incinerated, and inorganic liquids to be treated by other means as
necessary. This is presently in the design phase. A second Remedial
Investigation (RI) was begun in February 1988 to determine what type of
migration control should be implemented at this site.
B. SITE VISIT
ATSDR has not conducted a site visit at this time.
ENVIRONMENTAL CONTAMINATION AND PHYSICAL HAZARDS
A. ON-SITE CONTAMINATION AND OFF-SITE CONTAMINATION
The project site boundary depicted in the Appendix was the basis for
aefining on-site and off-site in this Health Assessment. The values
recorded in the tables below reflect the data presented in the Field
Investigation and Data Summary Report, Volume 1. Although there were
other data received by ATSDR, sampling points were not adequately
ident-fied, and therefore, were not utilized in the tables.
Page 1
-------
The results for the surface water and sediment sampling recorded in
Appendix H of the Field Investigation and Data Summary Report were not
provided to ATSDR for review. However, the discussion provided in the
text indicated that methylene chloride and bis (2-ethylhexyl) phthalate
(DEHP) were detected in the surface water samples and methylene chloride,
fluorotrichloromethane, DEHP, and chloroform were detected in the
sediment. (These contaminants may be laboratory artifacts and not
site-related.)
Table 1
ON-SITE CONTAMINATION
Contaminants
Chloroform
1, 2-Dichloroethane
1, 1-Dichloroethene
Tetrachloroethene
1,1,1-TCA
1,1,2-TCA
Trichloroethene "
trans-l,2-DCE
1,2-DCB
DDT
Chromium
Lead
Methylene Chloride
Xylene (total)
Toxaphene
Aroclor 1260
Soil (mo/Ka)
ND--.0006
ND— .180
ND— 6.2
ND~16,000
ND— 6,000
ND--1,100
ND— 1,500
ND— .009
ND— 150
ND— 937
ND— 5,470
ND— 1,300
ND— 1,500
ND— 160
ND— 19
Groundwater iua/L)
3—40
ND— 1,500
10—5,300
ND— 1,800
33—32,000
ND— 1,200
29—36,000
10—46,000
ND— 4,300
ND— 57
ND— 28
—
24—49,000
—
—
—
Table 2
OFF-SITE CONTAMINATION
Contaminants
Chloroform
1, 2-Dichloroethane
1, 1-Dichloroethene
Tetrachloroethene
1,1,1-TCA
1,1,2-TCA
Trichloroethene
trans-l,2-DCE
1,2-DCB
Chromium
Lead
Monitorina (ua/L)
ND— 1,300
ND— 140,000
ND— 4,900
ND— 24,000
ND— 31,000
ND— 50,000
ND— 8,000
ND— 3,600
ND— 40
ND— 223
ND— 23
Residential (ua/L)
—
—
ND— 6.6
ND— 9.2
ND— 29
ND— 120
ND— 63
ND— 79
—
—
ND— 23
Legend
TCA trichloroethane
DCE dichloroethene
DCB dichlorobenzene
DDT dichlorodiphenyltric'- loroethane
no concentration reported
Page 2
-------
B. PHYSICAL HAZARDS
There are no reported physical hazards present at this site.
DEMOGRAPHICS OF POPULATION NEAR SITE
The area surrounding the site is used to graze cattle. A chain-link fence
was installed in 1987 which eliminated the past problem with cattle
grazing 6n-site. There are two buildings located on-site. One was the
former sludge drying building located northeast of the drum mound. The
other was a barn located between the sludge mound and the main pit, which
was used as an office. The site is located 15 miles southwest of Norman,
Oklahoma, and one-half mile east of the community of Criner. The nearest
residence is located along the southwest site boundary.
EVALUATION
A. SITE CHARACTERIZATION (DATA NEEDS AND EVALUATION)
1. Environmental Media"
The soil contamination has been well defined. The groundwater and surface
water, and the interactions between them, will need to be more completely
characterized in the future to determine public health implications. This
further characterization should be addressed in the second operable unit
(migration control) RI. A drinking water survey should be conducted and a
map developed which indicate the location and population using the
groundwater (public and private wells) or the surface water.
2. Land Use and Demographics
The land use and demographic data provided to ATSDR were incomplete.
Additional information on the current use of residential wells near the
site would be useful to ATSDR. If this information does not already exist
it should be gathered during the second RI.
3. Quality Assurance/Quality Control
Conclusions contained in this Health Assessment are based on the
information received by ATSDR. The accuracy of these conclusions is
determined by the availability and reliability of the data.
B. ENVIRONMENTAL PATHWAYS
The bulk of the contamination present on-site is located in the subsurface
soil. This contamination is the primary source of the contamination in
the other media. The first operable unit ROD requires the excavation of
all principal source areas and the appropriate treatment and disposal of
such .aaterials. This action should help to decrease the migration of the
contamination from these source areas. Additional soil sampling during
the second operable unit RI should identify any additional areas of soil
contamination.
Page 3
-------
The groundwater at the site is located in two geologic formations near the
site. One formation which is the primary source of drinking water in the
area, is the alluvium of North Criner Creek, which is 40 to 60 feet deep
at mid-valley. The other formation is the Hennesey Formation which is
composed of fractured shale, mudstone, and sandstone. The water located
in the upper sediments is potable, but deeper it becomes salty and
brackish.
The flow of the groundwater has not been well defined at this time. It
appears to flow to the southwest and the east. Leachate has been detected
up to 50 feet below the bedrock as well as 400 to 2,000 feet laterally in
the bedrock. This is a result of the strong downward gradient and the
fractured Hennesey Formation. Contamination has also been detected in the
alluvium of North Criner Creek 2,000 feet southwest of the site. The
plume ia estimated to be 1,000 feet long. The mechanism of this transport
is unknown and will be the subject of further study during the second
operable unit RI.
The North Criner Creek flows from the northwest to the southeast and is
located south of the site. Its alluvial valley extends almost to the
southwest corner of the site. North Criner Creek joins Criner Creek
approximately 1 mile south of the site. There is also a creek located
about 400 feet east of the waste disposal areas. This stream was
impounded to create 3 small lakes which cover approximately 6 acres,
total. There is a 2-acre pond located 1,500 feet west of the drum mound.
Surface water and sediment samples were taken at various locations at the
site. These samples indicated the presence of contamination. The
additional sampling planned for the second operable unit RI should include
surface water and sediment samples to better characterize those media.
There was no ambient air sampling conducted at this site. Without any
data to the contrary, air must be considered a potential medium of
concern.
Potential environmental pathways at this site include migration of
contamination from the primary source areas and the soil to the
groundwater, surface water and sediment, biota, and air. There is also
the potential for the contamination to migrate between the various media.
C. HUMAN EXPOSURE PATHWAYS
The potential human exposure pathways for this site are ingestion of
contaminated soils, groundwater, and surface water; inhalation of dusts or
vapors from the source areas, the contaminated soil, or the contaminated
groundwater; and dermal exposure to contaminated soil, groundwater,
surface water, or sediment.
Inhalation of dusts and vapors generated on-site from the soils is a
potential exposure pathway for remedial workers and trespassers at the
site. People may be exposed to contamination while performing tasks that
require disruption of the soil, thereby causing a release of contaminated
dust and vapors. This potential exposure will decrease once remedial work
requiring excavation of the contaminated ul and construction of the
on-site landfill is complete. Off-site t >re is a potential for exposure
Page 4
-------
from fugitive dusts and vapors generated by disrupting the soil at the
site, and inhalation of vapors generated while using the contaminated
groundwater could occur if water from contaminated wells was used for
showering, irrigation, washing cars, etc.
Ingestion of contaminated groundwater is a potential public health
concern, off-site. The maximum concentration of trichloroethylene (TCE)
(63 ug/L), and trans-l,2-DCE (120 ug/L) reported in Table 2 above, were
detected'in a residential well that was no longer in use at the time of
the sampling. However, the maximum concentration of lead (23 ug/L)
reported, was detected in a residential well which was still in use. This
concentration of lead is of public health concern. According to the
Environmental Protection Agency these homes have been provided alternate
water. There is no known use of the groundwater on-site. The
concentrations of contaminants detected in the groundwater monitoring
wells located on-site are of public health concern and the water should
not be used for domestic or agricultural purposes.
Ingestion of soil is a potential human exposure pathway on-site. The
problem will center around the workplace (people eating lunch with dirty
hands, wiping dirt on. their face, etc,). Dermal exposure is a potential
human exposure pathway from working with the contaminated soils,
especially in the locations of the primary source areas. This potential
exposure will decrease once the contaminated soils are contained within
the landfill.
There is a possibility of incidental ingestion and dermal exposure to
surface water and sediments at the site. The surface water features in
the area may be used for recreational activities (e.g., wading, fishing,
etc.) .
Human exposure pathways that are of public health concern are inhalation
of fugitive dusts and vapors generated on-site and vapors generated from
use of groundwater off-site; ingestion of contaminated soils, surface
water, and groundwater; and dermal absorption of contamination from soil,
sediments, ourface water, and groundwater.
PUBLIC HEALTH IMPLICATIONS
Much of the contamination detected in the various media are VOC's. Some
of these VOC's may cause depression of the central nervous system at high
concentrations. Also, some VOC's cause liver and kidney toxicity as well
as damage to the pulmonary and hematopoietic systems. In addition, there
is evidence that some VOC's are carcinogenic in laboratory animals.
TCE given orally in doses of 24 or 240 mg/kg/d for a period of 14 days
produced effects including increased liver weight, decreased hematocrit,
and depressed cell-mediated immune response (Tucker et al., 1982, S'nders
et al., 1982). Based on liver tumor production in mice, the Environmental
Protection Agency (EPA) has designated TCE as a potential human
carcinogen. It is unknown how long residents may have been drinking or
using for domestic purposes the highly contaminated water present in the
plume. Long-term exposure to TCE at the maximum contamina ion detected in
residential wells could result in a significant, increased risk of
Page 5
-------
cancer and other non-carcinogenic toxic effects such as liver damage and
depression of immune function. Therefore the use of this groundwater for
drinking, bathing, and other domestic uses is not acceptable.
Lead is known to cause neurological effects in gestating fetuses,
neonates, and young children. It can also cause peripheral neuropathy in
adults. Other adverse health effects caused by lead include:
hypertension, growth retardation, and effects on heme synthesis enzymes
and the eell membrane. The maximum concentration of lead detected in the
soil at this site was 5,470 mg/Kg and in the residential wells, 23 ug/L.
Ingestion of lead at these concentrations is of public health concern.
Acute PCB-related health effects typically occur at higher concentrations
than those detected on-site. However, for this site, the primary
identified potential health effects, resulting from exposure to PCB's
through ingestion, inhalation, and dermal contact, are carcinogenic
effects. PCB's, have been designated as Group B2—Probable Human
Carcinogens (EPA 1987). This designation is based on experiments which
demonstrated the induction of hepatocellular carcinomas in laboratory
animals fed high doses of PCB's in their diet (Kimbrough et al., 1975;
Norback and Weltman, 1985).
The toxicity of chromium is dependent upon the valence of the cation
present (Cr VI or Cr III) and the anion to which it is bound. The valance
of the chromium detected at the site was not established; therefore, this
assessment is based on the potential toxic effects of Cr VI, which is the
more toxic form. The cell membrane is penetrated by Cr VI more easily
than Cr III. Once inside the cell, Cr VI is converted to Cr III, which
then complexes with deoxyribonucleic acid (DNA) providing an opportunity
for cell mutation (EPA 1987). Dermal contact with Cr VI may result in
dermatitis or skin ulceration. Chromium can also cause kidney and liver
damage. The maximum concentration found in the soil was 937 mg/Kg.
Ingestion of chromium at this concentration is of public health concern.
CONCLUSIONS AND RECOMMENDATIONS
A. CONCLUSIONS
This site is of potential health concern because of the risk to human
health resulting from possible exposure to hazardous substances at
concentrations that may result in adverse health effects. As noted in the
Environmental Pathways and Human Exposure Pathways Sections, human
exposure to contaminated soil, groundwater, surface water, sediment, air,
and biota may have occurred in the past or may be occurring now. The
actions in the ROD should reduce the potential exposures to the soil and
should reduce the potential for the migration of contamination from the
source. The second operable unit RI should provide the additional
information required to determine what migration controls should be
implemented at the site.
Page 6
-------
B. RECOMMENDATIONS
1. During remediation, measures should be taken to protect people on-site
and off-site from exposure to any dusts or vapors that may be released.
Workers on-site should be provided adequate protective equipment and
training, in accordance with 29 CFR 1910.120, and should follow
appropriate National Institute for Occupational Safety and Health and
Occupational Safety and Health Administration guidelines, when involved in
activities that may result in an exposure. Workers should implement
optimal dust control measures. During working hours, appropriate
monitoring should be utilized at the worksite periphery to protect nearby
workers and residents.
2. The information requested in the Data Needs and Evaluation Section of
this Health Assessment should be provided to ATSDR.
3. In accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act as amended, Hardage/Criner NPL Site has
been evaluated for appropriate follow-up with respect to health effects
studies. Although there are indications that human exposure to on-site or
off-site contamination may have occurred in the past, this site is not
being considered for follow-up health studies at this time because the
level and extent of possible human exposure to site chemicals has nc'c been
defined and it is unclear that current exposure is occurring. However, if
data become available suggesting that human exposure to significant levels
of hazardous substances is currently occurring or has occurred in the
past, ATSDR will reevaluate this site for any indicated follow-up.
PREPARERS OF REPORT
Environmental Reviewer: Susan L. Mueller, Environmental Health
Specialist/ Health Sciences Branch.
Regional Representative: Carl Hickam, ATSDR Regional Representative,
Region VI.
Page 7
-------
REFERENCES
1. Record of Decision, Hardage/Criner, McClain County, Oklahoma, 1986.
2. Field Investigation and Data Summary Report, Volume 1, Royal Hardage
Industrial Hazardous Waste Site, CH2M Hill, 1985.
3. Hardage/Criner Oklahoma Superfund Site, Partial Summary of Data, 1987.
4. Final Preliminary Public Health Evaluation, Technical Memorandum,
Royal Hardage Industrial Hazardous Waste Site, CH2M Hill, 1986.
5. USEPA Drinking Water Criteria Document for Chromium, 1987.
6. USEPA Drinking Water Criteria Document for Polychlorinated Biphenyls
(PCB'S) ECAO-CIN-414, 1987.
7. Kimbrough, R.D., Squire, T.A., Linder, R.E., Strandberg,
J.D., Montali, R.J., Burse, V.W., JNCI 55: 1453-1459, 1975.
8. Norback, D.H. and Weltman, R.H., Environ. Health Perspect. 60: 97-105,
1985.
9. Tucker A.N., Sanders V.M., Barnes D.W., et al., 1982. Toxicology of
trichloroethylene in the mouse. Toxicol Appl Pharmacol; 62:351-357.
10. Sanders V.M., Tucker A.N., White K.L., Jr, et al., 1982. Humoral and
cell-mediated immune status in mice exposed to trichloroethylene in
drinking water. Toxicol Appl Pharmacol; 62:358-368.
11. Casarett and Doull's Toxicology, The Basic Science of Poisons, Ed. 3,
Curtis D. Klaassen, Ph.D. et al., Macmillan Publishing Company,
New York, 1986.
12. Environmental and Occupational Medicine, Rom, 1983.
13. ATSDR File.
Page 8
-------
APPENDIX
LocA-Ti
A/
PURCELL SERIES WELLS
HARDAGE/CR1NER SITE OK-86
-------
APPENDIX C
ADMINISTRATIVE RECORD INDEX
(with Addendum)
-------
APPENDIX D
STATE OF OKLAHOMA CORRESPONDENCE
-------
SENT SY:CKLA ST DEPT HEALTH ;n-:3-_WE32:o4PM ENVIRONMENTAL HEALTH-
— - /•» r p , | ' • .
• .I'.-'r: V;
JOslH K. LaWfRr M*O« •' * 7 * i* * \ | " • 'c* " »(** X4 T Pi\'
Commissioner . .H..M. _j-.< . -^ , •_ , ,^.. i. L/I /
\**'!ff Sea:
. B.er:J0. 1000NATBITH
JomS CjKncrvn. DCS. 9jregf FCntn. M0. fWl ftHTIMfl ^^^ ftaf »•<»»
vce-Presoent uui M jotwn. M J wu^«wii« wi«, %M% »IM
S^-iwy'-tMJw LwW'aden ANaxw.o»»0»njNfTV|M>ioY|»
November 13,1989
Allyn M. Davis, Ph.D (8H)
Director
Hazardous Waste Management Division
EPA Region VI
1445 Ross Ave.
Dallas TX 75202
Dear Dr. Davis:
Criner Proposed Remedial Action Plan. We were awaiting additional information and we
were given only one working day to formulate a reply.
Please be advised that trie discussions we have had wtth representatives of your
agency have not served to eliminate several of our concerns rega/ding your proposed
plan. As you are aware, the Oklahoma State Department of Health (OSDH) received the
Remedy Raport for the Hardaga Industrial Waata Sfla on October 13, 1969 and subse-
quently requested briefings in order to gain an appreciation of your proposal. During the
briefings your staff was unable to answer any of our questions relative to risk analysis,
condition of the barrels and amount of liquids in barrels. Additionally, only some of our
concerns relative to control of air emissions and other basic information and assump-
tions upon which the proposed plan is built were answered.
Your staff promised to forward Information relative to some of these issues; however, the
information received was either unconvincing or not pertinent to these Issues. The
important question of relative risk has been left unanswered.
OSDH believes that several of the remedial action technotoglee proposed for site
.clean up have merit and in the interest of public health should be Instituted as soon as
practicable.
elements of merit:
Southwest trench or welte - institute Immediately
V-shaped trench - Institute immediately
Liquid extraction wells
Vapor extraction welis - if this element is part of a permanent
cap with a vapor control component
OSDH also believes that there are serious problems with everal proposed clean up
technologies presented in the Remedy Report and that these i ?ments of the plan have
potential for increasing health risks to the public.
-------
elements of disagreement:
Drum lancing • not recommended
Excavation of drums - not recommended
U-shaped trench - not recommended
Catalytic thermal treatment - as presented will not meet CAA
requirements or BACT.
The Oklahoma State Department of Health does not agree with significant elements
of EPA's Remedial Action plan for the Hardage/Crlner Superfund site as presented and
explained to us, therefor, 08DH cannot concur with the proposed plan based on the
information currently available.
If you have any questions regarding this matter please call me at (405) 27 1-8056.
Very truly yours,
Mark 8. Coleman
Deputy Commissioner
for Environmental Health
-------
APPENDIX E
RESPONSIVENESS SUMMARY
-------
Hardage/Criner Site
Community Relations Responsiveness Summary
The Community Relations Responsiveness Summary has been prepared to provide
written responses to comments submitted regarding the proposed plan at the
Hardage/Criner hazardous waste site. The summary is divided into two
sections:
Section
section
I: Background of Community Involvement and Concerns. This
provides a brief history of community interest and concerns
raised during the remedial planning activities at the Hardage/Criner
site.
Section II: Summary of Major Comments Received. The comments (both
oral and written) are.summarized and EPA's responses are provided.
I. Background of Community Involvement and Concerns
Individual interest or attention to the site has been moderate since the
signing of the 1986 Record of Decision for source control. Individual
residents are concerned about their health, food chain impacts, as well as
the economy of the area. Residents at the public meeting in October of 1989
indicated their desire for more frequent updates on activities and plans
for the site, and for credibility of the remediation through the removal
of wastes from the site.
II. Summary of Major Comments Received
Public notice announcing the public comment period and opportunity for a
public meeting was given on October 1, 1989. The Proposed Plan fact sheet
was distributed to the site mailing list on October 12, 1989. Fact sheets
were also sent to site repositories on this date, along with documents
comprising EPA's Administrative Record for the site. The comment period
began on October 13 and ended on November 2, 1989. A public meeting was
held on October 26, 1989, at the Grady County Fairgrounds Community Building
in Chickasha. The purpose of this meeting was to explain the results of
the Remedial Investigation and Feasibility Study for groundwater, and to
explain changes in the source control remedy since the 1986 Record of
Decision for the site. Approximately 40 people were in attendance, and a
number of questions and comments were received. Two letters were received
with questions as well.
The comments/
-------
Comments were received from the following citizens: Marvin Lyles, Edwin
Kessley, Royce Smith, Eilene Whitehead, Kay Hixon and George (Buddy)
McKinnon. Letters were received from George McKinnon and Lisa Ozment with
Progressive Environmental Management, Inc. Comments received are summarized
below, along with EPA responses.
Question #1. Will there be any problems with the roads due to movement of
equipment?
Response: The majority of the activities at the site during remediation will
take place within the site boundaries. There will be some movement of equipment
onto the site to perform the work. The only regular movement will be the
shipment of the liquids removed from the source areas as they are taken offsite
to be destroyed. These liquids will be accumulated until a load is ready for
shipment.
Question #2. Why weren't the source areas covered during the time of the
investigations to prevent the infiltration of rainwater?
Response: Actions were taken to eliminate immediate threats at the site,
such as erosion of the Barrel Mound. From the end of 1982 when the Hardage
property became a Superfund site it was not anticipated that it would take as
long as it has for clean-up to begin. This is particularly true of the delay
for litigation which has taken place since 1986.
Question 13. Why are there differences in the locations shown for the southwest
trench locations in the fact sheet and the overhead during the presentation?
Response: Trench or interceptor well locations shown on overheads during the
presentation were only approximate locations specified for the purpose of
evaluating alternatives for groundwater control. The trench or interceptor
well locations specified in the fact sheet are also approximate and based on
the current spread of groundwater contamination. The exact location of the
proposed interceptor system will be determined during final design stages of
the project, and will be based on the following considerations:
a) the spread of groundwater contamination immediately upgradient of the
alluvium;
b) the hydraulic properties of the bedrock (these dictate the exact design
requirements); and
c) the location of residential structures and property.
EPA will make efforts to install ~.ne interceptor system so as to minimize
disruption to homeowners who may !:e impacted by construction and operation
and maintenance activities.
-------
Question 14. Did all of the EPA's information come from the Hardage Steering
Committee's investigation or did EPA do its own studies.
Response: Much of the information about the Hardage site has come from multiple
sources. EPA, the Oklahoma State Department of Health (OSDH), and the Hardage
Steering Committee (HSC) have all gathered information about the site. The
most recent investigation, that of the area groundwater, was conducted by
the Hardage Steering Committee under the terms of a formal agreement with
EPA. Among the terms of the agreement were provisions for EPA oversight of
the work, split sampling by EPA to check the HSC's sample results, and EPA
review and comment upon the investigation reports, and final EPA approval.
EPA has its own experts and employees to examine the information gathered and
is not dependent upon the interpretations put on the raw information by the
HSC.
Question #5. How deep is the underground water in the area of Mrs. Smith's
property?
Response: Water level measurements in the alluvium in this area indicate
that the groundwater table is about 15 feet below the ground surface.
Question 16. Is there any threat from eating from pecan trees that have
roots into the contaminated groundwater?
Response: Wells in the vicinity of the homestead in question (MW-12, 13, and
28, for example) exhibit detectable concentrations of contaminants. Contami-
nants detected in the alluvium include the following compounds at the
concentrations indicated:
Compound Concentration Range Drinking Water Standard
(parts per billion) (parts per billion)
Total volatile
organics (VOC) 39 - 560 not set
Arsenic 1-7 50
Selenium 6-52 10
As the table indicates, selenium and VOCs are present at levels which pose a
concern for drinking water. Whether these contaminanats are taken-up by
pecan tree roots is not known. EPA will search for information on exclusion
mechanisms in pecan trees, and further evaluate this question.
-------
Question #7. There were noxious fumes from the site during its operation.
What about these fumes?
Response: During the time that the Hardage site was open, much of the waste
that was brought to the site was exposed to the air. There were open ponds
containing waste and drums and piles of more solid material were also left
uncovered. This allowed the fumes to escape from these sources. The potential
for escape of fumes is dependent on the surface area of contaminated material
which is exposed. During the selected remedy, the major potential for such
exposure is during excavation of the drums from the Barrel Mound and the Main
Pit. Three direct actions will be taken to control the formation of fumes.
First, the excavation will be done on the smallest practical working face.
This means that the area disturbed to remove the drums and any one time will
be kept at a minimum so that as little contaminated material will be exposed
to the air as possible. The second step will be constant monitoring of the
air both around the excavations and at the fence line. The third is would be
the use of engineering controls to prevent vapor release problems. This
would entail the use of foam supressants to stop the escape of the fumes up
to stopping operations and recovering the exposed areas if the fumes cannot
be controlled.
Question 8. Is EPA aware of a report by Kirk Brown from Texas A & M saying
that contamination is worse than EPA says?
Response: One of the government's experts for the purposes of the upcoming
trial on the Hardage site is Dr. Kirk Brown. Mr. Brown is therefore repre-
senting the government and EPA is in agreement with his opinions, which
involve significant measures to directly reduce contamination in the main
source areas.
Question #9. When will a final decision be made on what will be done to
clean up the site?
Response: The Record of Decision which was issued at the same time as this
Responsiveness Summary completes the EPA's administrative process for selecting
the clean-up method for the site. There is also a trial on this issue which
is scheduled to begin on November 27, 1989 in Federal District Court in
Oklahoma City and which should last no more than twenty days. The Judge will
then give his decision on remedy.
Question #10. The notice that appeared in the Daily Oklahoman was not
sufficient to notify the local residents about the meeting on the sit^.
Notice needs to be provided in papers which the local people use.
Response: The regulations governing the issuing of public notice require
that a daily paper be used to give the notice. However, that doesn't prevent
the placing of additional notices in other papers. In the future adc tional
papers will be used including the Purcell Register, Chickasha Star, a->d the
Blanch^rd News.
-------
Question #11. The meeting should have been held in McClain County where the
site is and not in Grady County.
Response: Euture meetings will be held at a location in Purcell.
Question 112. Will transcripts of the meeting be available to the public?
Response: Yes. A copy of the meeting transcript will be placed in the public
repository for the site in the Purcell Public Library, the offices of OSDH in
Oklahoma City, and at EPA's offices in Dallas. In addition, copies will be
available on request from either Mr. Underwood or Ms. Price at EPA.
Question 113. There are carcinogenic compounds in the water that has been
used by the Whiteheads (including children and infants) over the past 14
years. This contamination is moving to Criner Creek, which in turn runs into
the Washita. At what rate "is it moving?
The Whiteheads were provided alternate water from the McClain County Rural
Water District No. 7 in 1987. Prior to this, domestic water supplies came
from wells installed in North Criner Creek. Groundwater contamination has
migrated to a location in North Criner Creek which is approximately 1600
feet downstream of the North Criner Creek bridge on Old State Highway 122.
Groundwater flow rates for the upper alluvium are estimated to be between 80
and 170 feet per year and that for the lower alluvium between 9 and 19 feet
per year.
Question #14. How many years until this contamination is contained?
Response: Groundwater contamination will be removed when the groundwater
interceptor system and source control components (soil vapor extraction,
drum excavation and liquid extraction wells) are installed. Construction is
expected to take some five months from start to finish. Construction will
begin as soon as the litigation ends and the trench design is approved by
EPA.
Question #15. Do we know how much contamination is present in Criner Creek7
Response: We know there are levels of contaminants in the North Criner
Creek alluvium (see answer to Question #6). Low levels of contaminants have
also been detected in surface water samples of North Criner Creek. Contaminants,
however, have not reached Criner Creek.
Question #16. How much time will be needed from the time a decision is made
to the start of the clean-up?
Response: Once a decision has been made (see Response to Question #9) it
normally takes about nine months for clean-up to begin. Unlike most sites,
much of the preliminary design has been completed for trial, and therefore
work could begin within several months of a final remedy decision.
-------
Question 17. Should the Whiteheads continue to farm?
Response: Results of the Public Health and Environmental Endangerment
Assessment (PHEEA) conducted during the groundwater investigation indicate
that it is safe for the Whiteheads to farm. The PHEEA evaluated exposure
scenarios which assumed dermal contact with affected water and injestion of
affected water, beef and milk for various age groups. The results of risks
associated with exposure scenarios are summarized in the Second Operable Unit
Feasibility Study, which indicate risks below EPA's common acceptability
range for risks associated with Superfund clean-ups (1 in 1,000,000 risk).
Probable scenarios of future land use were developed for exposure calculations
Probable exposure scenarios for a child or adult were a few orders of mag-
nitude below EPA's acceptability range, however, worst case scenario results
showed risks from exposure to be between 10- through 10- .
Question #18. Will appeals be made to the court decision?
Response: We do not know. Certainly all sides in the case have the legal
right to do so, but whether or not that right will be exercised will have to
be seen after a ruling has been made.
Question #19. Some of the residents near the site have been told they will
have to move for the clean-up. What if they do not want to?
Response: It is not and has never been the position of EPA that any of the
area residents would have to move. Because of the need to locate some of the
portions of the groundwater portion of the clean-up off of what was the
original Hardage site, access to some area properties may be needed to
implement the clean-up. EPA does not feel that it is necessary to move for
the purpose of institutional controls, but cannot rule out the possibility
of temporary re-location during remedy construction. If no agreement can be
reached on allowing access to property for implementation of the clean up the
government could as a last resort obtain such access through the use of emminent
domain. However, the need to resort to such a method has been rare.
uestion #20. Is there water contamination to the north? My grandfather
rilled three wells in an area of North Criner Creek north of the area of
contamination shown in the fact sheet.
Response: Data collect for and by EPA does not indicate that contamination
has migrated to this area. To be on the safe side, however, the Oklahoma
State Department of Health (OSDH) has sampled the wells in question. The
has indicated that results were sent to residents, which showed no detectable
contamination.
Question #21. Has all of the seismigraphic work in the area fractured the
bedrock?
Response: Geologic studies at the site have revealed details regarding the
stratigraphy and structure of the site area. While fractures were noted in
the local bedrock, there is no reason to believe these have been caused by
seismic testing in the area.
-------
Question #22. Are there faults in the area?
Response: Studies reported in the literature have provided evidence for
deep, complex faulting in the Criner region. Depths of over 5000 feet are
suggested for such complex faulting. No evidence has been found in the
literature to suggest that these faults extend up into the younger (less than
about 1000 feet deep) bedrock in the vicinity of the site.
Question #23. Something needs to be done quickly to remedy the site problems.
Response: EPA agrees with this statement. Fortunately the upcoming trial is
set for November 27, 1989.
Question #24. The reputation of the area has been devastated and property
values depressed. These things aren't being addressed. The only way to
restore confidence is to remove the drums from the site completely and highly
publicize the event.
Response: The selected remedy calls for the removal and destruction of
contaminants contained in the source areas through liquid extraction,
excavation, and soil vapor extraction. The rapid and permanent destruction
of contaminants is one of the primary benefits of the selected remedy over
other options that have been proposed or considered.
Question #25. Once remediation of the Hardage/Criner Site is complete and
for some unforeseen reason the selected means of remediation does not prove
to be sufficient, will the PRP's be financially responsible for an extended
remediation?
Response: Responsibility remains even after remediation. Should
additional activity beyond that selected in this Record of Decision be needed
the same parties would still be liable for remediaiton. Such determinations
are made on the basis of the 5 year Superfund review process and though re-openers
in consent agreements, which provide for continuing liability if additional
work becomes necessary.
Question #26. If material from the site is transported offsite to another
disposal facility and this facility later becomes a Superfund site will the
PRP's be financially responsible for the material transported to the site
from Hardage/Criner?
Response: The generators of the material would still be responsible for it.
This scenario is not expected to occur as the materials taken offsite should
he destroyed in compliance with EPA regulations.
Question #27. Can the land be put back like it was?
Response: No. The best that can be done is to remove and destroy as much of
the contamination as is possible and to reduce the threat posed by what
contamination remains by limiting its mobility and by careful maintenance and
monitoring of the site. Because of the need to maintain a cap on the site,
the land will very likely lay fallow.
-------
Question #28. (OSDH) The objective of Superfund is the protection of public
health and the environment. Any release of contamination into the water or
air resulting from the remedial action at the site is inappropriate and runs
counter to this objective.
Response: The objective of Superfund is the protection of human health and
the environment. This objective includes protection from both long-term and
short-term risks. The short-term risks posed by excavation of the drums from
the source areas exist, but can be controlled as described in the Response to
Question #7 for releases to air. The excavation of buried drums is an
established technique which has been successful at similar hazardous waste
sites. Experience at such sites has shown the precautions which need to be
taken to minimize any short-term risks to the site workers or to the public.
The long-term risks associated with the Hardage site are a grave concern.
Ultimately this concern can-only be minimized by the recovery and destruction
of the contaminants. No one can predict what will occur over time as the
drums buried in the source areas corrode and continue to release their contam-
ination to escape into the environment. As these wastes mix and migrate the
risks they pose will continue. These risks include chronic, long-term risks
posed by carcinogenic compounds. With no known time limit for the release of
the contamination from the source areas a choice is apparent between rapid
removal and destruction of contaminants using pre-planned engineering and
safety controls successful in other similar excavtions. The alternative is
attempts, with many uncertainties, to achieve long-term containment of
hazardous and carcinogenic contaminants which are mobile and subject to
continued release into the environment under conditions that are neither
known or controlled.
Question #29. (OSDH) The data provided does not support the volume or condition
of the drummed waste that was used to justify the removal component of the
proposed plan.
Response: It is true that assumptions have been made about how many of the
buried drums still contain liquid waste. Faced with the choice of hoping
that perhaps all or most of the drums are empty or making the more conservative
assumption that they are not, EPA assumes that they continue to pose a threat.
Given the stakes, the health of local residents and the environment, we would
rather take the precaution of making this assumption and then discover that
the drums are empty than gamble that they are empty and later be tragically
proven wrong.
Question #30. Can we be confident that all areas relating to soil vapor
extraction have been addressed? Can we be confident in the catalytic oxidation
process and that this in itself would not contaminate the air?
Response: Once EPA selects the final remedy for the site, a detailed remedy
design will be prepared and approved. This design will necessarily address
all areas of concern during remediation, including refining the areas of
contamination, evaluation in detail the performance of soil vapor extraction,
and covering details of health and safety during remedial activities. As far
a catalytic oxidation is concerned, EPA is required to utilize the Best
Available Control Technology (BACT) for the destruction of contaminated vapors
resulting from soil vapor extraction. This is a requirement of the Clean
-------
Air Act and State regulations. If catalytic oxidation does not meet BACT,
then an alternate thermal destruction technology will be used. Air monitoring
onsite and_at site boundaries will be instituted to assure air quality remains
below action levels desiged to protect human health.
Question #31. The rural water system should be extended to those concerned
about possible domestic groundwater contamination.
Response: There are currently no plans to further extend the rural water
system through Superfund. Conditions which would warrent such an extension,
such as threatened or impacted groundwater in drainages outside North Criner
Creek, do not exist. Questions about potential groundwater contamination
from the site have been evaluated and indicates that groundwater plumes are
migrating primarily into the alluvium of North Criner Creek where alternate
water has been supplied. Planned actions in the alluvium would assure that
contamination in the alluvium is geographically controlled and concentrations
reduced.
Question #32. A park or recreation area should be set up with information
about the site.
Response: EPA has established a repository at the Purcell Public Library
which contains all such information.
EPA responses to revisions of the Second Operable Unit reports prepared by ERM-
Southwest are found on the following three pages. These revisions were
submitted to EPA during the public comment period and are treated since EPA
approved the Second Operable Unit RI/FS prior to this time.
-------
TECHNICAL REVIEW COMMENTS
AMENDMENT NO. 1
SECOND OPERABLE UNIT
REMEDIAL INVESTIGATION REPORT
REVISION NO. 1 HARDAGE SUPERFUND SITE
CRINER, OKLAHOMA
The United States Environmental Protection Agency (EPA) con-
ducted a technical review of the Revision No. 1, dated
October 10, 1989, to the Second Operable Unit (OU) Remedial
Investigation Report (RI) prepared by ERM-Southwest, Inc.
Users of the RI should be aware that EPA has a number of
comments and technical concerns regarding the report and its
Revision No. 1.
Previous EPA review comments were organized to align with
the Summary and Conclusions Section (Chapter 6) of the RI
report. Individual responses were presented for each of
54 conclusions in Chapter 6. These responses addressed the
major areas of concern that EPA has with the RI.
This amendment addresses the October 10, 19S9 major
revisions to the Summary and Conclusions section (Chapter 6)
of the RI report. The revised conclusion is noted and the
new response is presented beneath it. Comments could be
raised for each of the revised technical sections and sub-
sections of the report.
Users of the RI should therefore consider EPA's broad
responses and noted data limitations as needed when review-
ing the individual technical sections or appendixes con-
tained within the RI.
Revised Conclusion
Chapter 6—Introductory Paragraphs
EPA disagrees that Stratum II is relatively impermeable;
while it may be of lower overall permeability than overlying
or underlying units, Stratum II contains fractures and sand-
stone lenses. The source mounds are also not entirely
within the bounds of Stratum II. Excavation of the source
mounds into Stratum I sandstones is also suspected.
The presence of irummed solids and liquids in other portions
of the Main Pit besides the west side) is also expected.
1 0
DEN/53R/138.50
-------
Data developed by the HSC expert panel investigation was
sponsored by the HSC for their ongoing litigation purposes.
This study, as part of litigation, has not been endorsed by
EPA.
Revised.Conclusion No. 11
EPA does not agree with the characterization of Stratum II
as a low permeability unit.
The hydraulic head measurements alone do not yield informa-
tion on the vertical rate of groundwater movement through
Stratum II. Hydraulic conductivity and porosity values are
also necessary.
EPA does not agree with ERM's revised groundwater velocities
for Stratum I and Stratum III. ERM's values were calculated
using median hydraulic conductivity values and the lowest
hydraulic gradient observed during the study. Recalculating
the velocities using the range of measured hydraulic conduc-
tivities and hydraulic gradients reveals that Stratum I vel-
ocities could range from 1/2 to 1,000 feet per year and
Stratum III velocities could range from 0.003 to 250 feet
per year.
Revised Conclusion No. 15
No comment.
Revised Conclusion No. 21
EPA desires to state that the period of record, while
revised to include a longer period, is still relatively
short and may therefore not be fully representative of the
range of flows that may be encountered in the creek.
Revised Conclusion No. 26
The peak flow measured for the south pond may not be
relevant since it is controlled by discharge through a pipe
rather than site hydrology.
It should be noted that the pe:iod of record, while revised
to include a longer period, is still relatively short and
may therefore not be fully representative of the range of
flow from the south pond or the alluvium.
DEN/53R/138.50
-------
Revised Conclusion No. 43
The modeling performed by SSPA was not conducted as an
approved task under the second OU work plan. This modeling
is being performed as a result of the ESC litigation effort
and will.be evaluated separately.
As stated in previous responses, EPA does not agree that the
contamination found in the alluvial system is predominantly
the -result of surfical transport.
Revised Conclusion No. 45
See Revised Conclusion No. 43 response.
Revised Conclusion Nos. 54 and 55
The PHEEA does not address the exposure pathway that led to
the provision of an alternative drinking water supply to the
residents previously dependent on well water from the North
Criner Creek alluvium. The PHEEA also ignores the potential
exposure of humans via the ingestion of aquatic organisms,
at an annual consumption of about 5 pounds per year, which
is possible under a recreational scenario for North Criner
Creek. This is very important since the 10"* carcinogencic
risk criteria for some volatile organic compounds, (such as
1,1-Dichloroethene at 1.85 ug/1) relative to the consumption
of aquatic life, is less than CLP contract detection limits.
The PHEEA also does not address a "no action" alternative
that action alternative risk reductions can be compared to.
The range of risks developed in the PHEEA are applicable
only to the exposure scenarios evaluated and are lacking in
that the ingestion of ground water and/or aquatic life
potential exposure scenarios are conspicuously absent.
The PHEEA also does not use reference doses, Rfds, nor does
it follow the more recent EPA guidance for the preparation
of Human Health Evaluations 9285.701A dated July 1989.
12
DEN/53R/138.50
-------
APPENDIX F
1986 RECORD OF DECISION
FOR SOURCE CONTROL
-------
I
I
t
RECORD OF DECISION
(ENFORCEMENT DECISION DOCUMENT)
Site
Hardage/Criner located in McClain County, Oklahoma
Documents Reviewed
I am basing my decision on the following documents which describe the
cost-effectiveness of source control remedial alternatives for the
Hardage/Criner Site:
0 Field Investigation and Data Summary Report, Royal Hardage
Industrial-Hazardous Waste Site near Criner, Oklahoma, by CH?M Hill,
dated May 1984.
0 Source Control Feasibility Study, Royal Hardage Industrial Hazardous
Waste Site near Criner, Oklahoma, by CH2M Hill, dated February 1985.
0 Preliminary Public Health Assessment for Groundwater Ingestion for
the Hardage/Criner site by CH2M Hill, dated August 1985.
0 Summary of Remedial Alternative Selection, November 1986.
0 Data gathered prior to and during enforcement actions in 1982 as
described in Appendix A to the Summary of Remedial Alternatives.
0 August 1986 memo, Bill Langley to Bob Davis descri-bing review and
confirmation of 1984 data from sludge mound sampling.
H ° Public comments received March 10 - April 15, 1986 on the Source
<-- Control Feasibility Study.
(. ° Community Relations Responsiveness Summary, November 1986.
£
[
I
f
e Staff summaries and recommendations.
0 Reference materials for the documents listed above.
Description Of Recommended Final Source Control Remedy
Excavate the principal source areas (drum mound, main pit, and
sludge mound) to bedrock and separate wastes for treatment as follows:
0 Solids - treatment and disposal in an on-s1te landfill cell construe1-»d
and operated in compliance with the Resource Conservation and Recover'
Act of 1976, as amended (RCRA).
AR 00184
-------
i
i
i
L
r
™
E
I
L
I
I
2
0 Organic liquids will be incinerated.
0 Inorganic liquids will be treated and disposed by other means,
as appropriate.
Temporarily close areas of residual contamination at the former source
areas until remedial action is selected under the second operable unit.
Decision
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) and the National Oil and Hazardous
Substances Contingency Plan (40 CFR Part 300), I select the remedy
described above (alternative number seven from the Source Control Feasi-
bility Study) for the Hardage/CMner site. I have determined that this
remedy 1s cost-effectiv* and is protective of public health and welfare
and the environment. The action will require operation and maintenance
to maintain the effectiveness of the remedy. Since wastes will be left
on-s1te, the remedial action will be reviewed every five years to assure
that the remedy is still protecting public health and the environment.
The State of Oklahoma has been consulted on the remedy. I have considered
Section 121 of the Superfund Amendments and Reauthorization Act of 1986
(SARA), Including the cleanup standards thereof, and certify that the
portion of the remedial action covered by this Record of Decision (ROD)
complies to the maximum extent practicable with Section 121 of CERCLA (as
amended by Section 121 of SARA).
If negotiations are successful, potentially responsible parties (PRPs)
will enter into a Consent Decree with EPA authorizing the PRPs to Implement
the remedial action. In the event that negotiations are unsuccessful,
on-going litigation will be pursued by EPA and the Department of Justice
in an effort to seo^«-p«cfprmance of the remedial actions.
/Date
ances E. Phillips
Acting Regional Administrator
ARO '01
-------
HARDAGE/CRINER
RECORD OF DECISION CONCURRENCE
5
I
I
r
p
Allyn M. Davfs, Director
Hazardous Waste Management Division
obert E. Hannesschlage/. Chief
perfund Enforcement/Branch
>*»
OJ4L^
/
Paut Seals
Regional Counsel
Bennett Stokes, Chief
Solid Waste and Emergency
Response Branch,
Office of Regional Counsel
r
Larry D. Wright, Chief
Superfund Enforcement Section
i
c
f
A ,c 0 0 0 I
-------
e
i
f
r
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
HARDAGE/CRINER
MCCLAIN COUNTY, OKLAHOMA
J -
r 1.0 Site Location and Description
2.0' Operating History
|l 3.0 Current Site Status
— 4.0 Risk to Public Health and Welfare and the Environment
F
** 5.0 Alternative Development and Screening
f 6.0 Selected Alternative
7.0 Compliance of Remedial Action with Applicable or
tt Relevant and Appropriate Requirements
8.0 Operation and Maintenance of the Remedy
I 9.0 Compliance of Source Control Remedy with Section 121 of the Superfund
^ Amendments and Reauthorization Act of 1986 (SARA) to the Maximum
Extent Practicable
10.0 Other Operable Units
11.0 Enforcement
12.0 Community Involvement
13.0 References
M
APPENDICES:
A) Chronology of EPA Site Investigations Prior to 1984
B) List of Potentially Responsible Parties Identified for the
Hardage/Criner Site
T C) Community Relations Responsiveness Summary on the Source
L Control Feasibility Study
f-
Ar 100 JS
-------
fi
I
f
E
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
HARDAGE/CRINER
MCCLAIN COUNTY, OKLAHOMA
NOVEMBER - 1986
1.0) SITE LOCATION AND DESCRIPTION
The Hardage/Criner site Is located in McClaln County, Oklahoma,
roughly 15 miles southwest of Norman, Oklahoma and 1/2 mile east of
the community of Criner (Fig. 1). The area is agricultural with
land on all sides of the site used for grazing cattle. Oklahoma
Highway 24 forms the southern boundary of the site and a gravel
road runs along the east side of the site (Fig. 2).
2.0) OPERATING HISTORY.
The Royal Hardage Industrial - Hazardous Waste Land Disposal Facility
was issued an operating permit by the Oklahoma State Department of
E Health (OSDH) in September 1972 and commenced construction immedia-
tely. Two pits were excavated, the main pit and the south pit.
Originally, liquids and sludges from drums and tank trucks were
discharged directly to these unlined pits. The methods of liquid
F disposal were evaporation and infiltration; however, the main pit
>- filled to capacity rapidly. Waste from the pit was transferred to
temporary ponds, the "west pond" area, where liquids were slurried
r with soil, transfered on to the south pit and disposed concurrently
| with styrene tar and oil recycling residues. The south pit was
eventually filled in and waste piled to a height of about 10 feet
, above grade, forming the "sludge mound". After the first years
I operation, drums were no longer emptied, but rather piled at the
*- north end of the main pit beginning the "drum mound". The mound
was extended southward and built to a height of about thirty feet.
1$ In all, roughly 18 to 20 million gallons of waste were disposed at
L the site during its operation. The sequence of operations has been
compiled from OSDH inspection reports and a deposition and hearing
C testimony of the facility owner/operator. In 1978, the State of
Oklahoma filed complaints against the facility for suspected lead
poisoning of air around the site. In September 1979, OSDH began
£ proceedings to revoke the facility permit for operating unpermitted
pits, failure to seal permeable lenses in the pits, Improper closure
of pits, failure to retain runoff, and Improper storage of wastes.
• In September 1980, the U.S. Department of Justice (DOJ) filed suit
f on behalf of the Environmental Protection Agency (EPA) against the
E facility under Section 7003 of the Resource Conservation and Recovery
Act (RCRA). Operations ceased in November 1980 prior to the effective
£ date of RCRA interim status requirements. Royal Hardage then
r undertook site decontamination and closure efforts which extended
into 1982. These efforts consisted of mixing fluids in the pits with
soil, excavating visibly contaminated soils from mixing areas and
I temporary ponds and capping the source areas with a layer of soil.
I During closure, an effort was made to consolidate wastes in the
source areas (sludge mound, main pit, and drum mound).
AR0001S5
-------
FIGURE 1;
Site location map
Hardage/Crlner ROD 11/86!
II (lit I v-.
-------
- -— •- •+r-tr/^
BARREL
W. rs.i
MOUND
SLUDGE MOUND
• ~j i if»
Site topographic map
-------
3.0) CURRENT SITE STATUS:
<
' 3.1) Site Investigations:
K The site was inspected frequently by OSDH during its operation.
jf Inspectors reported widely varying conditions, with problems Init-
ially centered around pits filled to capacity and the potential for
m overflow. In 1976 OSDH requested that Hardage Installed groundwater
• monitoring wells in the southwest drainage. Eventually, thirteen
* monitoring wells were installed by the operator. These have been
periodically sampled ever since, showing uniformly high levels of
f contamination. Some Hardage wells may have become contaminated by
surface runoff entering the well bore during and Immediately after
construction. However, repeated purging of these wells has not
p lowered the levels of contaminants.
( EPA first inspected the site in July 1979 due to asbestos disposal.
EPA contractor Ecology A Environment (FIT) collected samples at the
site in August 1979, August and October 1980, and in March and
August 1982. In 1984, work was begun by EPA contractor CHjM Hill
to gather supplemental data to allow preparation of a Feasibility
Study (FS) for permanent remedial actions on the site. This supple-
mental data was compiled and field work was documented In a Data
Summary Report (DSR) completed in May 1985. A chronology of EPA
sampling efforts prior to 1984 is given Appendix 1n A.
T
t~
L
5
£
£
3.2) Contaminants:
The site was permitted to accept all types of Industrial and hazardous
wastes except radioactive materials (OSDH-1972). A total 18 to 20
million gallons of waste was logged Into the site. The resulting
mixture contains virtually every type of waste produced by industries
operating In the States of Oklahoma and Texas from 1972 through 1980.
The general types of waste accepted at the site Included: oil
recycling wastes, chlorinated solvents, styrene tars, acids, caustics,
paint sludges, lead, chromium, cyanide, arsenic, pesticides, Inks,
PCBs, and large quantities of waste of unknown content from Injection
wells and other facilities Including what became the Brio and Bio
Ecology Superfund sites (Hardage 1972-1980, Eltex 1985). Under each
of these broad waste types are numerous specific wastes streams
produced from perhaps hundreds of different Industrial processes,
each waste having It's own unique characteristics, impurities, and
inherent hazardous and toxic properties.
Some of the contaminants which pose an immediate threat through
groundwater are chlorinated solvents, including: l,2-d1chloroethane,
1,1,2-trichloroethane, 1,1-dichloroethene, tetrachloroethene, and
trichloroethene (CHzM Hill 1986a). Other compounds such as lead,
chromium, PCB, and toxaphene are present on the site and will pose
long term or permanent hazards due to their persistence 1n the
environment. This is by no means an exhaustive list of either the
wastes sent to the site or the contaminants of concern; further
information is contained in the source control FS.
: (I 0 0
-------
[ 3.3) Remaining Features:
Source areas include the main pit, drum mound, and sludge mound
| (Figure 2). The slude mound covers 1.5 acres to a thickness of
( from 15 to 20 feet above and within the former south pit.
E
i
I-
The main pit covers about two acres with a 15 to 20 foot thickness
of waste having been slurried with soil and backfilled Into the
pit, bringing it to the grade of surrounding land on the east and
forming a steep berm 10 to 20 feet high on the west. A high concen-
tration of drums is located along the west side of the pit and in
the barrel mound which covers about 0.8 acres to a thickness of 30
to 40 feet. Estimates of the number of unemptied drums remaining
in the source areas ranges from 10,000 to over 20,000, with knowledge
of site operations and history favoring the latter (Hardage 1972-80).
Other areas of the site were used as temporary holding and mixing "
ponds or may have been incidentally contaminated during site oper-
ations. These areas are the west ponds, east ponds, north pit, and
the southwest drainage (Figure 2).
Two buildings are still on-site. A former sludge drying building
used during the last year of operations is located northeast of the
drum mound. A barn, used as the office, 1s between the sludge
mound and main pit.
3.4) Hydrology:
c
North Criner Creek runs in a northwest to southeast direction south
of the site with the alluvial valley extending nearly to the south-
west corner of the site. This stream is perennial and joins Criner
Creek roughly one mile south of the site. Criner Creek empties
into the Washita River thirteen miles south of the site.
A stream runs along the east side of the site, about 400 feet east
of the waste areas. This stream has been Impounded to form a chain
of three small lakes totalling about 6 acres. Another two acre
pond lies about 1500 feet west of the drum mound.
3.5) Geology:
The site lies In what are commonly referred to as "redbed" sediments.
This is a thick sequence of shales, mudstone, and sandstones which
£ gr- :e back and forth over the space of tens to hundreds of feet.
T, The geology was originally described as consisting of the Bison
sha'e overlying the Purcell sandstone. Site investigations Indicated
f th e units are not differentiated at the site; so shallow bedrock
is -eferred to collectively as the Hennesey formation (Ch^M Hill 1985).
4ROOO
-------
, 0
L
I
f
L
£
t
f-
Beds generally dip to the south and southwest at less than 5
No major faults are believed to underlie the site. However, a well
defined regional joint system is present with joint sets observed
at N 20° W, N 20° E, and N 50° W (Kent 1982).
The'alluvium of North Criner Creek Is 40 to 60 feet deep at mid
valley and made up of decomposed bedrock from adjacent uplands.
3.6) Geohydrology:
The groundwater table beneath the site generally follows topography
and flows are to the southwest and east. Adjacent monitoring wells
completed at different depths strongly Indicate a vertical (downward)
flow component exists. Shales and mudstones underlying the site
are fractured and provide a secondary permeability which, coupled
with horizontal sandstone beds, has allowed migration of leachate
from 400 to as much 2000 feet laterally through the bedrock and
over 50 feet beneath the bedrock surface. Questions exist on the
method of transport to the southwest, where waste has migrated over
2000 feet by unconfirmed pathways to enter the alluvium of North
Criner Creek and apparently form a plume over 1000 feet long fn the
alluvial aquifer. Further evidence of the bedrock's Inadequacy as
a barrier to migration is provided by consideration of contamination
in two of the CH2M Hill - 1984 wells (BW-4, GTW-3) and In a series
of four FIT - 1982 wells (EW-3.EW-5.EW-6, and EW-7) located to the
east and southeast of the sludge mound. These wells are in areas
where no site operations occurred and where runoff would not be
channeled by topography. The observed 400 feet of migration Into
these wells over the twelve years between 1984 and 1972 Indicates a
rate of transport greater than 33 feet per year.
3.7) Areal Groundwater Supplies:
Where possible, residents of the area have drilled water supply
wells into the shallow alluvium of streams such as North Criner
Creek. However, farms not located 1n alluvial valleys and without
access to these supplies can and have drilled producing wells Into
the Hennesey formation within one mile of the site. Although not
formally classified, both the Criner and North Criner Creek alluvial
aquifers and the Hennesey formation would generally be categorized
as Class lib under the EPA Groundwater Protection Strategy.
Fresh water in this area is generally contained 1n the upper sediments,
with water becoming progressively more salty or brackish with depth
as Indicated 1n F1gur? 3 (USGS -1966).
A ^ (1(1(11 S.-.P
-------
1
4 .
E
r
L'
S
f-
«•»! -
«
c
e
o
OJ
fc 0 0 o i x H n
-------
I
C
I
r
F
r
c
§
t
E
3.8) Extent of Contamination:
Groundwater has been contaminated beneath and adjacent to the
source areas, in the southwestern drainage, and to the east and
southeast of the source areas to depths greater than 50 feet. The
alluvium of Nortn Criner Creek has been contaminated, as evidenced
by the presence of from 100 to 300 ppb of volatile organic chemicals
In three separate wells, which indicates a plume over 1000 feet
long (Figure 4). The relative contribution of surface and subsurface
pathways to alluvial contamination Is unknown. However, transport
rates observed on other parts of the site Indicate the source areas
will, over time, continue or begin to Introduce contaminants to the
alluvial aquifer through surface and subsurface migration routes.
Soils may be contaminated over several tens of acres as a result of
indiscriminant operations and closure. Evidence of this is provided
by both visible surface contamination and stressed vegatation.
Determination of the extent of surface contamination will require a
significant sampling effort during the second unit RI to adequately
define the areas requiring remedial measures.
4.0) RISK TO PUBLIC HEALTH AND WELFARE AND THE ENVIRONMENT
Many of the compounds present at the Hardage site are either known
or suspected carcinogens. Other compounds either are or are believed
to be acutely toxic or capable of causing damage to specific organs.
Some of these compounds also bio-accumulate in plant, animal, and
human tissues.
The principal routes of exposure for humans are: Groundwater
ingestion, direct contact, ingestion resulting from contamination
of the food chain and possibly exposure to airoorne contaminants.
The alluvial aquifer of North Criner Creek represents the most
readily available source of drinking water in the vicinity of the
site. This aquifer is contaminated with varying amounts of several
chlorinated solvents, as evidenced by sampling of water from the
abandoned Corley well and three alluvial monitoring wells. Since
several of the compounds detected in these samples are either known
or suspected of inducing cancer and/or damage to specific organs
of the body, chronic consumption of this groundwater would pose
unacceptable health risks.
The Smith and Atkinson/Bearden wells a » located 200 and 700 feet
respectively from contaminated monitoring wells. Domestic use of
water from the abandoned Corley well or the EPA monitoring well
AW-S03 would pose lifetime cancer riskr in excess of 10'4. Use of
groundwater from on-site would pose an xcess lifetime cancer risk
averaging 21 and up to 60S (CH£M Hill, 1986a).
-------
£ o 9 s i 0 0 0 d'7
-------
10
I
Direct contact with wastes on the surface of the site also poses
hazards; however, the health risk has not been quantified. Deter-
mination of acceptable levels of surface contamination will be a
primacy concern in the second unit FS. Current human traffic on
the" site is minimal; but cattle do occasionally graze on the site.
Contamination of the food-chain by lead, chromium, pesticides, and
PCBs, on the surface of the site poses long-term hazards. This
concern has prompted construction of a fence to keep cattle off of
the source areas; however, there is evidence of continued Intrusion
by cattle, giving rise to concerns of food chain contamination.
Certain compounds such as pesticides and PCBs have the ability to
bioconcentrate through successively higher levels of the food chain
(EPA 1985a).
Inhalation of volatiles and contaminated airborne partlculates on
and possibly adjacent to the site may also pose long term hazards;
however, this has not been confirmed.
i
I
F
L
fc
5.0) ALTERNATIVE DEVELOPMENT AND SCREENING
In accordance with Section 300.68(f) of the NCP and EPA guidance
documents (EPA 1985b), several alternatives were developed for
source control remedial actions at the Hardage/Crlner site. Scoping
of general alternatives and objectives for remedial action was first
discussed in a 1983 meeting between EPA, OSDH, and EPA contractors.
After reconsidering these objectives and alternatives 1n light of
the decision to proceed with a source control operable unit,
eleven alternatives were developed (Table 1), as documented in the
FS. Of these alternatives, four were retained after screening and
developed in further detail (see Section 5.2-5.5 below). Estimated
cost ranges for the four alternatives retained are shown in Figure 5.
5.1) Alternatives eliminated in screening:
The most notable result of alternative screening was the elimination
of those plans for containing the wastes In place. Several methods
of isolating the wastes and reducing or eliminating their release
were considered. After screening of technologies, several 1n-situ
containment plans were developed. Of these, capping in conjunction
with vertical trenches to Intercept shallow groundwater (Alternative
15) would be expected to be the most effective. While this plan
may be the most effective in-situ containment plan, It can by no
means be considered as an adequate remedy on that basis alone.
Consideration of this alternative did, however, serve as a test of
whether or not any form of capping-1n-place remedy would sufficiently
contain the source areas. Technologies such as slurry walls and
groundwater injection/withdrawl were eliminated due to the presence
of fractured bedrock, observed vertical migration of contaminants,
and the absence of any continuous horizontal bedrock layer at
AKOOfJf - ~
-------
11
E
r
L
I
L
E
L
£
f
TABLE 1 - Source Control Remedial Alternatives
> Alternative to. i - ib Action: no site rs«dial action taten.
> Alternative No. 2 - Lifted Action: remedial action consitts of
griding, revegetetion, fencing and institutional restrictions for
the site.
> Alternative No. 3 - Capping: both source artaj would be left in
place and covered with a multi-layered cap.
> Alternative No. 4 - Gradient Drains: the scarce areas would be
left in place, covered with a sulti-layer cap and upgradient
frcund\*ter drains constructed.
> Alternative No. 5 - Perimeter Drains: source areas would be left in
place, covered with a sulti-layer cap and upgradient and
downgradier± ground water drains constructed.
> Alternative Ite. 6 - Partial tamoval: a cap and perimeter drains
would be constructed around the 'sludge Bound, the win pit and
barrel Bound would be axcavmted, the wastes treated, as needed, and
disposed of in an on-sit« compliant RCRA Undf ill.
> Alternative No. 7 - On-*ite Disposal! both source areas would be
•xcavated, the wastes treated, as m«d«d, and disposed of in an en-
site JOA compliant landfill.
> Alternative No. 8 - On-site Incineration and Disposal: both source
areas would be excavated, the wastes incinerated en-site and dis-
posed of in an en-site ftCRA ccrpliant landfill.
> Alternative No. f • On-cite Xncineration/0ff-*ite Disposal: source
areas would be excavated, the wastes incinerated en site and dis-
posed ef in an off«*ite JOA compliant landfill.
> Alternative No. 10 • Off-site Disposal: both source areas would be
excavated, the wastes treated on-site to s»et landfill criteria and
transported to an off-site RCRA compliant landfill.
> Alternative No. 11 • Off-*ite Incineration: both source areas would
be excavated and the avjority of the wastes transported to an off-
site Incinerator for incineration and disposal.
Off-site Incineration was assumed in some cases for cost-estimating
purposes. This does not reflect a final decision to use off-site
disposal facilities for any waste from the Hardage site.
• o 001^ f;
-------
• 00 —
^^ . too-
i
C
400-
E f
r ^
I g 100-
E 1
e
L | too-
1 I
^Pp 100-
I— -
0 —
LAITINNATIVE
MO
10t
TO
§§
T
4tl
• It
171
•
• 40
• 74
•
tit
111
74
10
r
NAME
INCIHERAT»OH MCWCMATlONy OM-ifTl
DIMOtAL ANDDlfPOtAl OFF-im OM^OtAL
HUMUM MMttlNTS O^HH-iOUHD COMBmOH,
• IDDLI HUMBIK HIFKItlHTI |Atl COMDITIOH,
lOWll HUMIIK KIFMItlHTI LOWm-IOUHD CQMDITtON.
H6URE 5; AROOOJSfi
Costs and sensitivity
ringes for source centre
remedial alternatives
-------
13
reasonable depth with sufficient integrity to provide a natural base
to any engineered containment system. Further discussion of these
f capping-in-place or in-situ containment technologies and the rationale
| for their rejection •s presented in both the Source Control FS and
the Responsiveness Summary (Appendix C).
r Consideration of the cap and drain alternative revealed the presence
"* of the same flaws as existed 1n other plans for containing wastes.
The drains were first considered to a depth of five feet below the
m present groundwater surface. However, migration has been observed
• to over thirty feet below the water table, Indicating that Intercep-
tion substantially deeper than five feet would be necessary to
E provide meaningful reductions 1n the releases now occurlng. In
addition, free liquids present 1n the landfill and In drums which
will continue to deteriorate and burst would be released and allowed
_- to migrate vertically until the source was exhausted. The plan
j Involving shallow (five foot) trenches was estimated to cost $35-40
**- < million. Extensive and continous operation and maintanence (0 & M)
' for the indefinite future would be necessary to maintain the collection
f system. It was estimated that for collection rates greater than
0.5 gallons per minute, economics would indicate construction of an
on-site treatment plant. The problems associated with operating
p such a system for the indefinite future, meeting discharge requirements
and handling occasional peak flows could be significant. In addition,
there is no method for assuring the longterm operation of such a
treatment system.
'The continued release of hazardous wastes and hazardous substances
with only negligible lateral interception and no vertical intercep-
r tion, the need for indefinite 0 4 M when such cannot be assured,
^ the potential for continued off-site Impacts, and the entire
"band-aid" type of approach that this, the most viable 1n-situ
containment alternative entails 1s wholly Inadequate to meet the
objective of CERCLA and the directive of the NCP to provide a
permanent remedy meeting or exceeding applicable or relevant and
appropriate Federal public health and environmental requiremnts.
-As a result, closure in place was rejected as being Incapable of
containing wastes in the immediate vicinity of the site and unac-
ceptable as a permanent source control remedy.
F
L
£
5.2) Alternative 7 - On Site Disposal:
The source areas (drum mound, main pit, and sludge mound) would be
excavated. Solids would be treated and disposed In a landfill cell
constructed on-site. Liquids would generally be Incinerated.
After completion, the landfill would be closed with a multi-layer
cap and gas venting system. The Remedial Action (RA) would require
about 18 months to complete at a present worth cost of $70 million
(Table 2).
\ * - «• ^- n n i\
-------
TASLE 2:
ALTERNATIVE NO. 7—ON-SITE DISPOSAL
ITEM COST
GENERAL $ 1,800,000
EXCAVATION, SEPARATION, SAMPLING $12,979,000
TREAT AND TRANSPORT DRUMMED WASTES $ 5,450,000
DN-SITE DISPOSAL $12,789,000
SITE RESTORATION $ 196,000
EVAPORATION/COLLECTION POND FOR SURFACE
WATER _ $ 280,000
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL $ 5,403,000
OTHER PROVISIONS $ 249,000
Construction Subtotal $39,146,000
Bid Contingencies (15%) $ 5,872,000
Scope Contingencies (20%) $ 7,829,000
Construction Total $52,847,000
Permitting and Legal (7%) $ 3,699,000
Services During Construction (10%) $ 5,285,000
Total Implementation Costs $61,831,000
Engineering Design Costs (10%) $ 6,183,000
TOTAL CAPITAL COSTS $68,014,000
OPERATION AND MAINTENANCE $ 1,690,000
(Present Worth)
Bid Contingencies for Operation and
Maintenance (15%) $ 254,000
Scope Contingencies for Operation and
Maintenance (20%) $ 338,000
TOTAL OPERATION AND MAINTENANCE
(PRESENT WORTH) $ 2,282,000
TOTAL PRESENT WORTH $70,296,000
*:-itc incineration was assumed for cost-estimating purposes.
Tnis does not reflect a final decision to use off-site disposal
facilities for any waste from the Hardage site. r jjjj^
-------
15
5.3) Alternative 8 - On Site Incineration and Disposal:
The source areas would be excavated. Hastes would be Incinerated
in a kiln constructed on-site. Ash would still contain metals and,
until proven otherwise through de-listing, would require disposal as
a Hazardous waste. Disposal would be in a landfill cell constructed
on-site. This alternative would require four to eight years to
implement at an estimated present worth cost of $326 million (Table 3)
5.4) Alternative 9 - On Site Incineration and Off Site Disposal:
The source areas would be excavated and wastes Incinerated as above.
The difference between this and Alternative 8 would be the off-site
disposal of incinerator ash. This alternative would require four
to eight years to implement at a cost of $374 million (Table 4).
Future 0 A M for this source control remedy would be non-existent.
5.5) Alternative 10 - Off Site Disposal:
The source areas would be excavated; and wastes would be transported
off-site to existing Treatment Storage and Disposal (TSD) facilities
for landfilling, incineration, reuse/recycling, or other treatment
as appropriate. This alternative could be Implemented 1n about 2
years at an estimated present worth cost of $133 million (Table 5).
As with alternative 9, 0 & M would be non-existent.
6.0) SELECTED ALTERNATIVE:
Alternative 7 (On-Site Disposal) 1s selected as the appropriate
remedy for source control at the Hardage/CMner site. The process
by which this alternative was chosen over the other three under
consideration is outlined below.
6.1) Remedial alternative selection procedure:
EPA Is required by Section 300.68(1) of the NCP to determine the
appropriate extent of remedy by, "Selection of a cost-effective
remedial alternative that effectively mitigates and minimizes
threats to and provides adequate protection of public health and
welfare and the environment". The NCP goes on to state that the
selected remedy will attain or exceed applicable or relevant and
appropriate Federal environmental and public health requirements.
EPA has c isldered the cost, technology, reliability, administrative
and other concerns 1n selecting Alternative 7 as the appropriate
remedy, a? documented below. These considerations have only been
applied t alternatives meeting or exceeding the above noted
requireme- .s.
-------
TABLE 3:
ALTERNATIVE NO. 8—ON-SITE INCINERATION AND DISPOSAl
ITEM
GENERAL
EXCAVATION, SEPARATION, SAMPLING
ON-SITE INCINERATION OF WASTE PILL
TR£AT AND TRANSPORT DRUMMED WASTES
«
ON-SITE DISPOSAL
SITE RESTORATION
EVAPORATION/COLLECTION POND POR
SURFACE WATER
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL
OTHER PROVISIONS
Construction Subtotal
Bid Contingencies (15%)
Scope Contingencies (20%)
Construction Total
Permitting and Legal (7%)
Services During Construction (10%)
Total Implementation Costs
Engineering Design Costs (10%)
TOTAL CAPITAL COSTS
OPERATION AMD MAINTENANCE
(Present Worth)
Bid Contingencies for Operation
and Maintenance (15%)
Scope Contingencies for Operation
and Maintenance (20%)
TOTAL OPERATION HD MAINTENANCE COSTS
(PRESENT WORTH;
TOTAL PRESENT WOP^H
* Off-site incineration was assumed or cost-estimating purposes.
This does not reflect a final deci ion to use off-site disposal
facilities for any waste from the ardage site.
COST
1T,352,000
$ 12,979,000
$130,500,000
$ 2,916,000
$ 10,175,000
$ 196,000
$ 310,000
$ 21,611,000
$ 249,000
$186,288,000
$ 27,943,000
$ 37,258,000
$251,489,000
$ 17,604,000
$ 25,149,000
$294,242,000
$ 29,424,000
$323,666,000
$ 1,384,000
$
$
208,000
277,000
$ 1,869,000
$325,535,000
-------
TABLE A:
ALTERNATIVE NO. 9--ON-SITE INCINERATION/OFF-SITE DISPC
ITEM COST
GENERAL $ 7,928,000
EXCAVATION, SEPARATION, SAMPLING $ 12,979,000
ON-SITE INCINERATION OF WASTE PILL— $130,500,000
Design, Construction and Operation
TREAT AND TRANSPORT DRUMMED WASTES $ 3,788,000
WASTE FILL REMOVAL TO OFF-SITE LANDFILL $ 16,958,000
OFF-SITE LANDFILL DISPOSAL CHARGES $ 20,850,000
SITE RESTORATION $ 196,000
EVAPORATION/COLLECTION POND FOR
SURFACE WATER $ 310,000
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL $ 21,611,000
Construction Subtotal $215,120,000
Bid Contingencies (15%) $ 32,268,000
Scope Contingencies (201) $ 43,024,000
Construction Total $290,412,000
Permitting and Legal (71) $ 20,329,000
Services During Construction (10%) $29,041,000
Total Implementation Costs $339,782,000
Engineering Design Costs (10%) $33,978,000
TOTAL CAPITAL COSTS $373,760,000
OPERATION AND MAINTENANCE $0
. (Present Worth)
Bid Contingencies for Operation and
Maintenance (15%) $0
Scope Contingencies for Operation and
Maintenance (20%) .$0
TOTAL OPERATION AND MAINTENANCE COSTS .$0
(PRESENT WORTH)
TOTAL PRESENT WORTH $373,760,000
-------
TABLE 5:
ALTERNATIVE NO. 10—OFF-SITE DISPOSAL
ITEM COST
GENERAL °^~2,538,000
EXCAVATION, SEPARATION, SAMPLING $ 12,979,000
TREAT AND TRANSPORT DRUMMED WASTES $ 7,584,000
HASTE FILL REMOVAL TO OFF-SITE LANDFILL $ 21,228,000
OFF-SITE LANDFILL DISPOSAL CHARGES $ 26,100,000
SITE RESTORATION $ 196,000
EVAPORATION/COLLECTION POND FOR
SURFACE WATER $ 280,000
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL $ 5,403,000
Construction Subtotal $ 76,308,000
Bid Contingencies (15%) $ 11,446,000
Scope Contingencies (20%) $ 15,262,000
Construction Total $103,016,000
Permitting and Legal (7%) $ 7,211,000
Services During Construction (10%) $ 10,302,000
Total Implementation Costs $120,529,000
Engineering Design Costs (10%) $ 12,053,000
TOTAL CAPITAL COSTS $132,582,000
OPERATION AND MAINTENANCE $0
(Present Worth)
Bid Contingencies for Operation
and Maintenance (15%) $0
Scope Contingencies for Operation and
Maintenance (20%) $0
TOTAL OPERATION AND MAINTENANCE COSTS
(PRESENT WORTH) $0
TOTAL PRESENT WORTH $'32,582,000
(Mi
-------
19
fc
I
£
r
r
t
I
I
6cl.l) Comparison of on-site versus off-site remedial action alternatives:
Two alternatives, 7 and 8, involve on-site disposal of wastes excavated
from source areas. Alternatives 9 and 10 entail complete off-site
disposal of wastes. The alternatives 7 and 10 Involve essentially
the same operations (i.e. excavation with limited Incineration and
landfilling for the bulk of wastes), except that they are on and
off-site variations of basically the same alternative. Similarly,
alternatives 8 and 9 are basically on and off-site disposal options
for residue from the on-site Incinerator. Based on this point, the
analysis below compares on-s1te to off-site disposal.
Cost: The cost of .off-site landfilling and Incineration alternatives
exceed their on-site counterparts by 90% (J63 million) and 15% ($48
million) respectively.
Technology: The on and off-site options will be virtually Identical
in the treatment and disposal technologies employed. Control of
the quality of work done under the on-site alternatives may be
somewhat superior in this respect however, since these actions
would be conducted under EPA oversight and off-site treatment or
disposal would not.
Reliability: The off-site disposal options will provide reliability
In preventing releases from this site, simply because wastes would
not remain on-site. However, off-site disposal has the potential
to increase health risks at other sites. It is not certain that any
significant advantage exists in reliability of off-site over on-site
disposal locations. The Hardage/CMne'" facility 1s 1n compliance
with the siting requirements currently governing location of
commercial disposal facilities. For this reason, any particular
vulnerabilities which are present on the Hardage site would not
necessarily be absent at off-site facilities.
Administrative: Each alternative will comply with RCRA Part 264
requirements, long-term objectives of CERCLA as amended, and all
applicable or relevant and appropriate requirements for protection
of public health and welfare and the environment. Since wastes
will be left on-site, the remedial action will be reviewed every
five years after it's completion, as required by the Superfund
Amendments and Reauthoriration Act of 1986 (SARA), to assure that
the remedy 1s still protecting public health and the environment.
Other concerns; (Safety during Implementation) Both on and
off-site alternatives carry Inherent risks during excavation.
As discussed later, these impacts can be controlled. The primary
difference between the on and off-site alternatives with respect
to safety during implementation is the potential for accidents
AROOO
-------
c
c
E
r
t
L
F
20
or spills during off-site transport of the wastes. For example,
an estimated 11,000 loads would be required to transport the
entire 180,000 cubic yards of waste off-site. For the 400 to
800 mile transport distance assumed in the FS, trucks carrying
waste from the Hardage site would be on the road from four to
eight million miles.
Consideration of the components of the four remedial action alterna-
tives evaluated shows that the key difference is the presence of
an on-site landfill under the two on-s1te alternatives. Information
collected to date indicates that an adequate landfill cell could be
constructed on-site and successfully maintained. The site meets
RCRA Section 264.18 siting requirements for seismic stability and
flooding potential. Due to the hazards and costs arising from
off-site disposal and transport, clear and significant benefits
should be present before off-site disposal 1s selected. Those
benefits are not significant or certain 1n this case. While such
benefits may exist in the off-site treatment of small to moderate
quantities of specific wastes, organic liquids may be an example,
off-site disposal for the entire waste quantity is not preferred
over on-site management of wastes in this case. Therefore, the
off-site alternatives are eliminated from consideration, and the
on-site disposal alternatives (7 - On-site disposal; 8 - On-site
incineration and disposal) will be carried on for further evaluation.
6.1.2) Comparison of the two on-site alternatives:
Cost: Alternative 7 would cost $39-109 million to implement, with
the most likely cost being $70 million. Alternative 8 would cost
$171-495 million, the likely figure being $326 million. Therefore,
the benefits to be derived from incineration of all waste would
come at a cost of 470% ($256 million) greater than landfilling.
Technology: Incineration is a key component of both alternatives 7
and 8.Since some wastes are liquids which cannot be landfilled,
the decision to incinerate organic liquids is appropriate.
Incineration of all wastes will have the net benefit of destroying
virtually all organic materials. Even with incineration however,
heavy metals will still be present in the residue. These materials
simply cannot be destroyed. The mobility can be reduced by treating
the waste to reduce it's acidity; this would be done under either
alternative.
Reliability: By incineration, virtually all organics are destroyed,
leaving an ash with varying contents of heavy metals requiring
stabilization and disposal as a "characteristic" hazardous waste.
The landfilling alternative, with limited incineration, removes
only the free organic liquids with the greatest potential for
penetrating a landfill liner and moving into the environment.
-------
E
I
I
r
c
[
P
L
C
P
21
Landfilling and incineration of liquids are established technologies,
with a demonstrated ability to perform under similar conditions.
Incineration of soils contaminated by a heterogenous mixture of
wastes, while feasible, has not yet been attempted on a scale such
as would be required for complete Incineration at the Hardage site.
Administrative: Both alternatives would meet all apHcable or
relevant and appropriate requirements for protection of public
health and welfare and the environment. Since wastes would be
left on-site, the remedial actions would have to be reviewed
every five years as required under Section 121 of SARA.
Other concerns: (time to Implement) Landfilling can be accomplished
1n 12 to 18 months. Incineration will take four to eight years.
Based on the factors considered above, Alternative 7 (On-site
landfill with liquids incineration) is selected as the appropriate
remedy for the Hardage/Criner site. This alternative will provide
a degree of protection to public health and welfare and the environ-
ment similar to that which could be achieved with complete Inciner-
ation. This remedy can also be carried out 1n a shorter time using
proven technologies which are currently 1n wide-spread application.
6.2) Detailed Description of the Recommended Alternative:
The following is a general sequence of operations and construction
activities required to implement on-site disposal for a source
control remedy at the Hardage/Criner site. The timing and spec-
ifications will be developed in detail during the Remedial Design
(RD) phase of response.
A landfill cell will be constructed to meet the minimum technology
requirements for hazardous waste landfills as set forth 1n RCRA
Section 264.301. The key feature of such a landfill cell 1s a
double liner system with interior leachate monitoring and collection
(Figure 6). The landfill will be constructed above grade on the
high ground west and north of the present source areas, as Indicated
1n the FS. If at all possible, construction of the landfill cell
over significant residual contamination will be avoided. The exact
siting of the landfill cell will be based on the results of surface
soil sampling during the second unit RI, consideration of topography
and hydrology of the site, and possibly additional geotechnical
data collected during the RD. Sufficient land Is available on
which to siie a landfill cell.
The sludge mound, main pit, and drum mound will be excavated. This
represents a volume of approximately 180,000 cubic yards, and Includes
in excess of 10,000 to 20,000 unemptled drums. For this operable
unit, the vertical extent of waste excavation will be to the upper
surface of undisturbed bedrock (see Section 6.3 - Clean-up levels).
A K 0 0 0 1 S
-------
i
£
f
r
i
i
f-
ty
c
3
H
-------
23
After waste excavation, feafnent, and disposal (described below),
tne e"ipty waste pits and bedrock now underlying the waste piles
will still regain. This upper bedrock surface 1s believed to be
satjratec witn waste seepage to an unknown depth. Such residual
conti-^nation will generally not be removed during the source control
remedial action, since the appropriate extent of vertical excavation
cannot yet be defined. In order to prevent contamination of surface
runoff waters and to eliminate direct contact exposure hazards from
open areas of residual waste, 1t will be necessary to construct a
protective temporary cap over the former source areas. This temporary
cap will serve the dual purposes of preventing direct rainfall from
leaching the contaminated bedrock and eliminating direct contact
hazards. The cap will be constructed so as to achieve these goals
and at the same time be of a design to allow upgrading to meet rele-
vant and appropriate RCRA closure standards should 1t be determined
by the second operable unit RI/FS that closure in-place 1s an
appropriate permanent remedy for residual contamination beneath the
former source areas. Considering the relative times required for
design of the source control remedy and conduct of the management
of migration RI/FS, it is possible that final clean-up levels will
have been developed for the site prior to waste excavation. If
such clean-up levels are available, the interim cap would be unneces-
sary and remedial action for residual contamination 1n the bedrock
beneath the former source areas can proceed directly from excavation
of the source areas.
Since wastes excavated in the source areas will range in consistency
from dry solids to relatively pure liquids, and since the appropriate
means of waste treatment and disposal is in large part determined by
the physical consistency of the material, 1t 1s clear that criteria
will have to be developed during the RD which allow segregation of:
liquids for incineration or other treatment, solids whose moisture
content is appropriate for landfilling, and solids requiring moisture
reduction prior to landfilling.
Liquids will be defined by the relevant and appropriate RCRA testing
procedures (currently the Paint Filter Test) which are effective at
the time the remedial design is approved. Liquds will be segragated
based on their chemical make-up (i.e. organic versus Inorganic as
described in the FS). The RD will develop criteria for making this
distinc* on.
Solids, as defined by testing procedures noted 1n the above paragraph,
will be Dandled in a manner based on decisions made 1n a moisture
content valuation, described below under Section 6.2.3. Based on
the crit-ria developed there, wastes will have to have to fall below
an upper limit on moisture content, after treatment, before they can
be dispo ed in the landfill, provided other requirements, such as land
-------
24
k
C
i
F
L
C
disposal bans, do not preclude their placement in the landfill.
Based on the determinations and criteria from the RD, the wastes will
be treated and disposed as indicated in the general schematic shown
in "Figure 7. Discussion of waste treatment and disposal is provided
below.
Treatment of organic liquids: These liquids will be incinerated.
Based on the economics of the volume of materials encountered, this
would be done either at an off-site facility or on-site with a
portable or modular incinerator.
Treatment of inorganic liquids: Based on the economics of the
volume and character of the liquids encountered, treatment and
disposal may be done either on or off-site. On site treatment
would generally be'through physiochemical methods capable of removing
both organics and metals, to allow discharge under an NPDES permit
or transport to a publicly owned treatment works. If off-site
treatment is selected, either deep well injection or treatment at a
commercial facility would be available.
Treatment of Solids: Solids will ultimately be placed in the landfill
cell constructed on-site. Prior to disposal, the wastes will be
subjected to treatment aimed at reducing their toxicity and mobility.
Since a large volume of contaminated soil is present, significant
volume reduction would not be possible. Such treatment may include
addition of materials to stabilize the fill or physiochemical
treatment designed to remove or alter specific hazardous constituents
or classes of compounds. Treatment technologies identified are:
chemical neutralization (pH adjustment),
solic,fication by addition of lime, cement, fly ash, or
other proprietary agents,
reduction of liquid content,
chemical oxidation or reduction, and
air stripping to remove volatiles.
Other a'ternative treatment technologies identified during the
remedial design will also be considered for application, and those
technol-gies showing promise for the specific wastes and situations
at the rardage site will be evaluated further through bench tests or
pilot studies as appropriate
During * ie remedial design, an evaluation Including bench testing
will be :onducted to determine an appropriate upper limit on the
moistur content of fill which could be placed in the on-site land-
fill. "M'S evaluation will consider the potential composition of
pore fl'. ds in the waste, the reaction of various soil/fluid combin-
ations der the type of triaxial stresses to be expected within the
f
R n 0 f) 1 's ~ 7
-------
25
WASTE FILL FROM EXCAVATION
I
|RCRA test for liquids
Liquid
Criteria developed
1n remedial design
Inorganic liquids
I
(Economics of
volume
Organic liquids
(high
volume)
A
On-sue
physlochemical
treatment
Sol
ds
Solid
-X
ent Dy:
Treatment Dy: neutralization,
fixation, or other methods
determined during remedial
design
|On-Site Landfill
I Economics of
volume
Liquids
Surface Discharge
Under NPDES Permit
On-site
Landfill
Dlume)
\
Off-site
physiochemical
treatment or
deep well
Injection
(high \ (low
volume \vo1ume)
1 \
|un-5ite
Incineration
with mobile
or modular
unit
/
Solid Liquid
Residues Residu
\
Un
La
i
-site
ndflll
uTT-site
incineration
at an existing
facility
l
Residues
es
1
Off-s te|
disposal j
>
Recycle or treat
and discharge under
NPDES permit
FIGURE 7;_A p Q 0 0 J x
Treatment schematic for
alternative number 7 -
on-site landfill with
liquids incineration
-------
fc
I
C
r
26
landfill, the potential for long and short-term leachate generation,
and the effects of such leachate on various liner systems proposed
for the landfill cell. Based on the results of this evaluation, an
upper limit will be imposed on the moisture content of wastes which
can.be disposed in the landfill. Wastes placed in the landfill will
in no case be of the type which:
a) would be classified as "liquids" by applicable or relevant and
appropriate testing procedures pursuant to the RCRA prohibition
on the disposal of liquids in landfills; or
b) are the subject of any land disposal bans under the Hazardous
and Solid Waste Amendments to RCRA or the Toxic Substances
Control Act which are determined to be applicable or relevant
and appropriate.
Treatment technologies will be further refined during the RD phase;
and additional design data may be required. The variability of
wastes present in the source areas precludes any extensive character-
ization of wastes prior to excavation. For this reason, final
determinations on appropriate treatment will 1n some cases have to
be made during the RA itself.
6.3) Clean-up Levels for the Source Control Operable Unit:
Selection of clean-up levels will be a concern of the second operable
unit (Management of Migration). Ultimately, clean-up levels will
have to be selected for the base of the pits and for surface soils
on-site. In the pit areas, the criteria will generally Include
potential for migration of metals and organics which have already
migrated out of the pits. The surface soil criteria will focus on
metals, PCBs, and pesticides due to their persistence 1n the
environment, direct contact exposure hazards, and potential to
contaminate surface runoff.
LThe Source Control operable unit deals exclusively with the concen-
trated pits and piles of wastes. In this case, selections of
compounds of concern and selection of clean-up levels based on soil
concentrations of these compounds 1s not appropriate. The criteria
to be used for determining the extent of clean-up will be the
surface of undisturbed bedrock. If, at that point In the RA,
additional data from the second operable un RI/FS or the Source
r Control RD has allowed determination of a f il clean-up level,
then excavation, in-situ treatment, or permanent capping may be
Implemented for the residual contaminants. If such data 1s not
r available, a temporary cap will be Installed iver the excavated
[- areas pending second operable unit remedy d€ >rm1nat1on.
AROIHI I
~; c
-------
G
I
r-
L
f
P
27
6.4) Health and Safety Concerns During Implementation
Excavation of the waste piles and pits will pose hazards to workers
via air and direct contact in addition to the physical hazards
normally associated with such construction. In many cases the
waste excavation and handling will have to be conducted under Level
B protection (containerized air and protective clothing) to mimize
hazards to the workers. Air release of volatile organics will
likely increase during waste excavation. Continuous monitoring of
air around working areas, at the site perimeter, and near offsite
homes will allow identification of health threats to off-site
residents and prevent problems from going undetected. Dust and
vapor suppression measures, maintenance of a small working face of
exposed waste, and possible use of a temporary structure over the
excavation will help to minimize air releases.
Runoff retention structures and emergency holding ponds will be
used to prevent chronic or sudden releases during construction.
7.0) COMPLIANCE OF REMEDIAL ACTION WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR PROTECTION OF PUBLIC HEALTH AND THE
ENVIRONMENT
Section 300.68(i) of the NCP directs that EPA will, except in narrow
cases such as "fund-balancing", select a remedy that "attains or
exceeds applicable or relevant and appropriate Federal public health
and environmental requirements that have been identified for the
specific site." These applicable or relevant and appropriate
requirements (hereinafter "Requirements") are discussed 1n an
October 2, 1935 memorandum from Winston Porter, Assistant Adminis-
trator for EPA's Office of Solid Waste and Emergency Response,
"CERCLA Compliance with Other Environmental Statutes", which is set
forth in the preamble to the NCP at 50 Fed. Reg. 47912, 47946
(November 20, 1985).
The principal requirements and policies to be considered during
conduct of the RA will be as follows:
7.1) 3CRA Subtitle C Permit Requirements, 40 CFR Part 264:
While not deemed applicable to the site since It closed prior to
November 19, 1980, these requirements are considered to be relevant
and appropriate to this CERCLA response action to the extent Indicated
below. Leaving engineering considerations aside, the Part 264
permit requirements are considered appropriate rather than che Part
265 interim status requirements. The facility closed prior to the
effective date of interim status, rather than attempt to cciply
witn these standards. Royal Hardage notified EPA of hazarous
waste activity under RCRA in August 1980, but withdrew the iotifi-
cation in November 1980 and did not file Part A of the RCRA permit
application, most likely because the site could not have me' those
-------
fc
C
•
§
28
standards without bankrupting the facility. As Indicated previously,
wastes were disposed haphazardly in unlined pits and the treatment,
storage, and disposal of hazardous wastes at the facility as far
below the standards required for interim status facilities. Indeed,
EPA filed a lawsuit seeking clean up and closure of the facility
under RCRA, Section 7003 in U.S. District Court in Oklahoma City on
September 8, 1980. EPA has conclusive and demonstrable evidence of
releases of hazardous wastes and hazardous substances from the
disposal units of the Hardage site. Given this situation, the most
appropriate Federal environmental requirements to apply to the
source control action, which is consistent with and forms a
substantial increment of a permanent site remedy, would be the Part
264 requirements, applicable to new facilities, along with their
more stringent closure requirements.
Additionally, EPA-believes that the physical nature of the site,
It's hydrology, and underlying geologic conditions dictate that the
waste materials not be left in-place. Accordingly, 1t Is clear
that the Part 264 permitting and closure requirements should be
applied to the construction and closure of new disposal units
necessary for this facility.
Finally, it should be noted that, as the preamble to the NCP states,
"... although the Subtitle C regulations differ as to whether a
hazardous waste facility has a RCRA permit (40 CFR Part 264) or 1s
operating under interim status (40 CFR Part 265), remedies will
generally have to be consistent with the more stringent Part 264
standards, even though a permitted facility 1s not Involved. The
Part 264 standards represent the ultimate RCRA compliance standards
and are consistent with CErtCLA's goals of long term protection of
public health and welfare and environment." 50 Fed Reg at 47918.
7.1.1) Subpart B - Siting Requirements:
This will govern placement of the landfill cell on-site. The
' principal concerns stated in this subpart are seismic stability and
L flooding potential. Neither factor appears to be a major concern
at the Hardage site; therefore, compliance does not seem to pose
problems.
C
it
7.1.2) Subpart F - Groundwater:
This subpart will determine the extent to which the on-site
landfill will be monitored. It will have a much wider application
under the second operable unit.
-------
I
I
E
29
7.1.3) Subpart G - Closure and Post-Closure:
These standards will apply to closure of the landfill cell(s) after
completion of the source control RA. The remedy will comply with
this subpart.
7.1.4) Subpart K - Surface Impoundments:
This will apply to any temporary Impoundments constructed during
the RA that treat, store,or dispose hazardous wastes. Impoundments
will be lined, opearted, closed, and 1f necessary monitored in
compliance with this subpart.
7.1.5) Subpart N - Landfills:
This subpart will govern construction and operation of the landfill
cell. The landfill will
meet requirements set forth for new landfills.
7.2) Toxic Substances Control Act:
This would come into application if PCBs are encountered at levels
greater than 50 ppm, since such materials are banned from land
disposal. In that case, alternative treatment would be required
and implemented in order to comply with the Act.
7.3) EPA CERCLA Off-Site Policy (memorandum dated May 5, 1985; "Procedures for
Planning and Implementing Off-site Response Actions"):
This policy will determine which TSD facilities are eligible for receipt
of hazardous substances from the site. The policy generally requires a
facility to be permitted and have no significant RCRA violations or
conditions affecting it's satisfactory operation. Prior to disposing
or authorizing disposal of wastes from this site the Region will
contact the State in which the facility Is located, review the
facility's record of operation, and if appropriate contact other
Regional offices of EPA where the facilities may be located to
evaluate compliance with this policy. No wastes will be disposed at
any site not meeting the criteria set forth 1n the policy.
t 7.4) Occupational Safety and Health Standards (29 CFR Part 1910):
These standards will be applied during remedial actions to protect
workers from exposure to hazardous substances and other physical
h- hazards associated with Implementation of the RA. Methods for
' assuring the safety of workers Involved 1n the RA will be devloped
and described in a "Site Safety Plan" developed as part of the
I Remedial Design.
r
c
C
"
f
HUH! !
-------
C
t
L
L
30
7.4) Hazardous and Solid Waste Amendments to RCRA of 1984:
The Hazardous and Solid Waste Amendments to RCRA of November 1984
(HSWA), 42 U.S.C. 6901 et seq. contain provisions setting several
statutory dates for banning land disposal of hazardous wastes The
provisions discussed here are RCRA Section 3004 (d)(e) and (g), due
to the possible intersection of their statutory deadlines with the
construction schedule for a source control remedy at the Hardage
• site.
The HSWA land disposal amendments are In fact not yet applicable or
effective Federal requirements with respect to CERCLA Section 104
or 106 response actions, since their Implementation dates are still
some time off in the future. The bans found 1n subsection (g) are
to be implemented during three periods over 21 months for 1/3, 2/3,
and finally all of the RCRA subtitle C "listed" hazardous wastes
commencing August 8, 1988, as determined by EPA. Those determinations
will be made by rulemaking. See 50 Fed. Reg. 19300 (May 28, 1986)
for the list of wastes to be considered.
The statutory ban on the "California List" wastes and solvents 1n
subsections (d) and (e) and the prospective bans laws of subsection
(g) are not considered relevant and appropriate at this time, since
their applicability to CERCLA waste disposal is 1n the future. The
effect of the bans in subsection (g) on the remedy 1s speculative
at best, since EPA is required to engage 1n rulemaking for methods
of land disposal and pretreatment for such disposal, 42 U.S.C. 6924
(g)(5) and (m). Futhermore, it must be emphasized that CERCLA
requires the selection of cost-effective remedies and does not
require EPA to implement standards that are not 1n effect.
During the course of remedial action and construction, EPA intends
to further review the effect of land disposal bans on waste disposal
at the site and the issues of how such laws will be Implemented
should they intersect the construction schedule. Additionally,
bench tests and/or pilot studies may be performed with respect to
pre-treatment methods for solvents and other organics potentially
impacted by such bans.
8.0) OPERATION AND MAINTENANCE
The on-site landfill will require little routine operation and
maintenance (0AM). Monitoring of the Interior leachate detection
system will be required, as will periodic Inspections of the cap
and monitoring of gases leaving the venting system. Development
and routine sampling of a groundwater monitoring network will also
be necessary for 30 years, at which time the need for additional
monitoring will be reevaluated.
f
-------
E
I
r
i
i
E
£
31
To provide a contingency in project cost estimates, it was assumed
that at 30 years after construction replacement of the landfill
liner and cap might be necessary. The cost 1s reflected in the
present worth cost estimate of $70 million. Operation and maintanence
costs on a present worth basis are estimated as $2,282,000 in 1985
dollars.
9.0) COMPLIANCE OF SOURCE CONTROL REMEDIAL ACTION WITH SECTION 121 OF
THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (SARA) TO
THE MAXIMUM EXTENT PRACTICABLE
9.1) Basic Certification:
The selected remedy will comply with Section 121 of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA),
as amended by SARA, including the cleanup standards thereof, to the
maximum extent practicable. The selected remedy is considered to
be cost effective and protective of human health and the environment
as well, in accordance with the NCP.
9.2) Permanent Solutions and Technologies
In selecting this remedy, EPA has considered a full range of alterna-
tives and solutions and alternative treatment technologies that
will result in a permanent and significant decrease in toxicity,
mobility, or volume of the hazardous substances present. In conduct-
ing its assessments of remedial alternatives and treatment technol-
ogies, EPA has considered:
1) The long term uncertainties of land disposal;
2) goals and requirements of the Solid Waste Disposal Act ("RCRA");
3) persistence, toxicity, mobility and bloaccumulation potential
of the wastes;
4) short and long term potential for adverse human health effects;
5) long term maintenance costs of the remedy;
6) potential for future remedial actions costs 1f the remedy fails;
7) potential threat to human health and the environment from the
excavation, transportation, and redisposal, or containment of
hazardous substances.
9.3) Remedy Analysis:
The selected remedy is a remedy for the first operable unit of
remediation - source control. It is a significant part of overall
remediation at the Hardage site and is consistent with a permanent
remedy for the site. The second operable unit, "management of
migration", is now under development.
-------
32
This remedy will employ treatment through incineration of all free
liquid organics in the estimated 175,000 cubic yards of waste fill,
as well as the more than 18,000 estimated drums of waste buried
on-site. Remaining waste fill and inorganic solid drum contents
wi-11 be treated through stabilization measures prior to redisposal
1n a double lined on-site RCRA compliant landfill cell. In carrying
out these measures, EPA will be permanently and significantly
reducing the volume, toxicity, and mobility of the hazardous sub-
stances present at the Hardage site. Further, EPA will avoid in
large measure the potential dangers and uncertainties of transport
and disposal off-site, with its on-s1te approach for the bulk of
wastes. EPA requires that this source control remedy be reviewed
not less than every five years to assure that human health and the
environment are being protected.
As noted previously, in Section 7 herein, EPA has scrupulously
considered the applicable or relevant and appropriate federal
requirements for protection of public health and the environment in
accordance with the NCP. EPA has also looked into the Issue of
applicable or relevant and appropriate state environmental laws and
has determined that the "RCRA analogous" regulatory requirements of
the Oklahoma Controlled Industrial Waste Disposal Act, as amended,
authorized by EPA under RCRA to operate in lieu of the EPA regulations,
are met or exceeded by the selected remedy. In a nutshell, EPA has
complied with the SARA Section 121 cleanup standards to the maximum
extent practicable.
10.0) OTHER OPERABLE UNITS
EPA's response actions on the Hardage/Criner have been d'vided into two
ope-rable units: Source Control (the remedy discussed in this document)
and Management of Migration (also referred to as the groundwater/off-site
operable unit).
The source control response is limited to the source areas of the site
(sludge mound, main pit, and drum mound). The bases of the main pit and
southern pit (beneath the sludge mound) at approximate elevations of 1109
and 1093 feet MSL respectively form the lower bound of the source areas.
The lateral bounds of the source areas are described by the base of the
slopes on the north, south, and west faces of the waste piles and pits,
and as the lateral extent of the excavated pits on those sides of the
source areas where wastes and cover have been backfilled to ground level.
The management of migration RI/FS will Include the following:
0 Definition of the extent and levels of contamination present
in soils and rock outside the source area;
0 determination of the extent and fate of groundwater contamination
in the alluvium of North Criner Creek and the feasibility
and need for remedial actions in the alluvial valley;
0 0 0
-------
33
determination of permanent surface clean-up levels on-site to
prevent or minimize further degradation of potential surface
and ground water supplies, direct contact hazards to the
puDlic, and other long term hazards.
L
11.0) ENFORCEMENT
11.1) Hardage I:
r
r
c;
L
r
In 1979, EPA inspections of the site Indicated poor waste management
practices posing potential threats to public health and welfare and the
environment. In September 1980, the U.S. Department of Justice (DOJ)
filed a complaint on behalf of EPA in U.S. District Court in Oklahoma
City, Oklahoma. The complaint alleged violations of Section 7003 of RCRA
and sought proper cleanup and closure of the site. The facility
had ceased operations in early November 1980, before RCRA Interim
Status Standards came into effect.
In 1982, DOJ and EPA amended the existing complaint against the
facility owner and operator Royal Hardage. The complaint was
changed to include allegations and requested relief under Sections
106 and 107 of the Comprehensive Environmental Response Compensation
and Liability Act (CERCLA). In December 1982, the Court found that
the site posed an imminent and substantial endangerment to public
health and welfare and the environment as defined by CERCLA Section
106 and RCRA Section 7003. In August 1983, the Court granted a
partial judgment for over $211,000 in response costs, which EPA had
incurred through 1982, against Royal Hardage.
Hardage filed for bankruptcy in 1983 and again in 1985, and EPA has
never recovered its partial judgment.
11.2) Hardage II
EPA compiled available records from the sites operations Including
daily and monthly site logs of wastes received, waste manifests,
and disposal plans and records filed with the State of Oklahoma by
generators and transporters of waste to the site.
As a result numerous Potentially Responsible Parties (PRPs) were
identified. ' i December 1984, EPA mailed letters to 289 of these
r PRPs requesti' Information about their waste disposal at the
[ Hardage site der authority of Section 104(e) of CErtCLA and Section
fe 3007 of RCRA i notifying the PRPs of their potential liability
for site clear p. As further Information was gained, Information
L, request and nr ice letters were sent to additional PRPs Identified.
At the presen- time, over 400 PRPs have been Identified. Various
PRPs have gon jut of business or cannot be located; therefore,
approximately iO have been contacted. A number of these parties,
have organizec nto the Hardage Steering Committee (HSC). The HSC
has met with [ \ and OSDH on numerous occasions since EPA's first PRP
meeting concer ng the site in January 1985.
AK 0001
L
r
-------
fr
I
i
Since the FS was on going at the time the PRPs were notified and
CERCLA progam policy previously did not allow PRP conduct of RI/FS
studies without a signed agreement to also implement the EPA selected
remedy, the PRPs were not involved in preparation of the FS. In
May 1985, EPA released the DSR documenting 1984 site Investigations:
and HSC also obtained all EPA files on the site. The HSC has retained
Dames A Moore and more recently ERM-Southwest to provide technical
support in their dealings with EPA.
In July 1985 the Court administratively closed the 1980 case against
Hardage, providing that the U.S. could re-open the case for the
purpose of seeking appropriate relief until April 1, 1986, at which
time the case would otherwise be dismissed. OOJ, on behalf of EPA,
filed a motion on March 27, 1986, to amend the existing complaint
and add generators and transporters to the existing case. The Court
ultimately denied the motion and dismissed the case, providing that
Royal Hardage could be named for limited purposes 1n a subsequent
case.
On June 25, 1986, DOJ filed a new complaint naming 36 generators
and transporters of waste at the site. The complaint asks for
performance of the EPA selected source control remedy, maintenance
of site security, conduct of a RI/FS for the management of migration
operable unit and any subsequent EPA selected remedy, and recovery
of EPAs' past and future response costs. A status conference was
held on September 3, 1986, and a second status conference has been
set for January 7, 1987.
12.0) COMMUNITY INVOLVEMENT
Due to the large number of PRPs for this site, the majority of
meetings, comments on the FS, and other external communication has
„ been with these parties, However, attention has been given to the
, concerns of near site residents and other Interested parties.
When the draft FS was completed on February 20, 1986, a press release
* was issued announcing this fact, copies of the FS were placed in
i repositories, and a copy was provided directly to the Hardage
Steering Committee. The public comment period was from March 10-
April 15, 1986. A public meeting was held in Chickasha, Oklahoma
i to answer questions and receive comments on the FS on March 20. The
1 response to questions, comments, and concerns raised during this
period is contained in the Responsiveness Summary, Appendix C.
-------
35
13.0 REFERENCES
CH2M Hill 1985
Field Investigation and Data Summary Report, Royal Hardage
Industrial Hazardous Waste Site. CH?M Hill. May 22, 1965
CH2M Hill 1986a
Preliminary Public Health Assessment, CH^ Hill. August 1986
T CH?M Hill 19865
fc* Source Control Feasi5ility Study, Royal Hardage Industrial
Hazardous Waste Site, CH?M Hill. February 20. 1986
B EPA 1985a
Public Health Assessment Manual. EPA - Office of Solid Waste
.jj and Emergency Response, November 1985
' : EPA 19855
Guidance on Feasibility Studies Under CERCLA, EPA, June 1985
| EPA 1986
Superfund Remedial Design and Remedial Action Guidance, EPA,
f June 1986
^ Eltex 1985
Letter from Eltex Chemical and Supply (Houston, Texas) to
Stephen Phillips (EPA-Dallas), August 1985
Hardage 1972-80
f Monthly waste site log of materials received at the Hardage site
Kent 1982
rt Evaluation of Hydrogeoloqy at Royal Hardage Industrial Waste
lUahoma, Douglas C. Kent, Ma
site; Criner, (Jklanoma, Douglas C. Kent. May 1983
OSDH 1972
In
1972 to Royal HJartdage 5y OSDH
USGS 1966
f" Industrial-Hazardous waste landfill permit issued September 12,
f* USlai 1*00
L Base of Fresh Groundwater in Southern Oklahoffla, D.L. Hart,
United States Geological Survey Hydrologic Atlas - 223, 1974
t
r
-------
c
t
L " APPENDIX A
CHRONOL06-, OF EPA SHE mEST,MT,0«
^ PRIOR TO 1984
-------
r
f*
\»
APPENDIX A
EPA Sampling and Inspections of Hardage/Criner prior to 1984:
June 27. 1979
Inspector: Ralph Hawkins (EPA-Ada Branch) accompanied by Oklahoma
State and County Health Department personnel
Purpose: NESHAPS inspection due to asbestos disposal
Result: Recommended Sampling of site
Documentation: 7/3/79 memo, Hawkins to Charles Gazda (EPA-Dallas)
August 15. 1979
Inspector: S.C. Yin (EPA - Ada Branch) with other EPA and State
Health Department personnel
Purpose: Obtain samples and inspect site
Result: Nine soil, water, and waste samples taken, analyzed for
metals and organics; photos taken
Documentation: 9/10/79 memo, Yin to Charles Gazda (EPA-Dallas)
10/26/79 memo William Langley (EPA-Houstpn Lab) to Oscar
Ramirez (EPA-Dallas) transmitting analytical results.
August 14, 1980
Inspector: Thomas Smith of Ecology & Environment (FIT) for EPA
Purpose: Off-Site sampling
Result: Three samples taken from off-site drainage pathways;
analyzed for metals and organis; photos taken
Documentation: 8/21/80 memo T. Smith to Charles Gazda (EPA-Oallas);
9/23/80 memo William Langley (EPA-Houston Lab) to William
' Librizzi (EPA-Dallas) transmitting analytical results
October 1. 1980
Inspector: S.C. Yin (EPA-Ada Branch) with FIT personnel
Purpose: Off-site sampling
Result: Thirteen (13) samples taken from off-site drainage and
domestic water wells, analysis for metals and organics,
photos taken
- r, IJ 0
-------
k
c
E
r
s
r
i
c
F
A-2
Documentation: 1U/23/80 memo, Yin to Wi11iam Librizzi (EPA-Dallas);
10/15/80 memo William Langley (EPA-Houston Lab) to
Librizzi transmitting analytical results
March 23 - April 8. 1982
Inspector: Imre Sekelyhidi (FIT) personnel and other FIT employees
for EPA
Purpose: Detailed on and off-site sampling of the site
Result: 3/23-24/82, 29 samples collected;
3/30-4/1/82, 6 domestic wells sampled
3/30-4/2/82, 10 monitoring wells drilled, by Shepard
Testing and Engineering Co., Inc. of Norman, Oklahoma
at locations directed by Jerry Tnornhill (Hydrogeologist,
EPA-Ada" Branch)
soil borings and monitoring well samples collected from
each new monitoring well
August 16, 1982
Inspector: Ecology 4 Environment (FIT) for EPA
Purpose: Second sampling round for the wells drilled by FIT
in March 1982
Result: 10 groundwater samples collected
A r 0 0 0 1 s:»
-------
i
I
M APPENDIX B
LIST OF.POTENTIALLY RESPONSIBLE PARTIES
£ IDENTIFIED FOR THE HARDAGE/CRINER SITE
£
c
F
I
t
E
F
I
-------
I
k
F
71O A BETTER SANITATION
711 ABLE LIMT
-------
770 DOu&.E EAGi_E REFINING LUBRICANTS, INC.
771 DOVE 9 COMPOSITION
772 DO-' C^EMICA. COMPANY
773 DOWNTOWN ft! SPARK, INCORPORATED
774 DRILLERS EN3INE * SUPPLY
775 DURA-CHROME INDUSTRY
77£ EASON' 4 £»TT>-, WASTE HAULERS
777 EASO.N ENTERPRISES
77S EA&ON OIL
773 E. I. DUPONT DE NEMOURS
780 ELTEX CHEMICAL AND SUPPLY COMPANY
781 ENGINEERING ENTERPRISES
782 EQUIPMENT REMEWfiu. COMPANY
783 ERNEST ST. CLAIR
784 EUREKA TOO- COMPANY
785 EVAN'S ELECTRIC -SERVICE CENTER
78£ FAA AERONAUTICAL. CENTER
787 FIBERCAST CORPORATION
768 FINE CANDY COMPANY
783 FIRST NATIONAL MANAGEMENT CORPORATION
790 FLINT STEEL CORPORATION
73: FORD GLASS P.ANT
792 FOSTER FEED ft SEED
733 FOSTER SEPTIC TANK CLEANING
794 FRED JONES MANUFACTURING
795 FREuirALJF CORPORATION
796 GARDNER-DENVER COMPANY
737 GENERA. ELECTRIC
798 GENERA. ELECTRIC
793 GENERA. TIRE & RUBBER
800 GEOPHYSICAL RESEARCH
801 GLlDDEN COATINGS ft RESINS COMPANY
602 GLO*-LITE DIVISION OF DUTCH BOY, INC.
803 GOODYEAR TIRE ft RUBBER COrPA>JY
804 GOVERNAIR CORPORATION
805 GROEVDYKE -RANSPOR", INCORPORATED
806 HALLIBURTON SERVICES
807 ROYAw M. HARDAGE
808 HART INDUSTRIAL DISPOSAL
809 HATHAWAY INDUSTRIES
810 HELfr ft WEAVER
811 HERMETIC SWITCH, INCORPORATED
812 HOLLEY CARBURETOR
813 INDUSTRIAL UNIFORM
814 INDUSTRIAL DISPOSAL SUPPLY, INCORPORATED
815 INTERNATIONAL CRYSTAL MANUFACTURING
816 JOHN ZINK COMPANY
817 JONES-BLAIR PAINT COMPANY
818 KELSIY-HAYE?
819 KELT^ONICS CORPORATION
610 KERR Me GEE, PRESIDENT
821 KITB^-L CHEMICAL COMPANY
823 KOBE INCORPORATED
B23 KOCO TV
824 LAWT 4 PLATING COMPANY
825 LEAc JiEGLER, INCORPORATED
THIS LIST F RESENTS EPA'S PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY ESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT A PfUin I
CONSTITUTE rlNAL DETEMINATION CONCERNING THE LIABILITY OF ANY PARTY £ MJ U Ui
FOR THE HA2 D OR CONTAMINATION^; TH£ HARDAGE SITE
-------
8£6 L. A S. BEPRIN3
817 LEEWQY P-OTCR FR£I3-«T (C. L. MOTOR FREIGHT)
813 MAREMGNT CORPORATION
830 MASTER MOTORS
831 MATERIALS RECOVERY ENTERPRISES
822 MCDONNELL DOUGLAS
V833 MCKESSON CHEMICAL COMPANY
'834 MANUFACTURING MERCURY MARINE
835 METROPLEX SANITATION
82£ MIKE MON30NEY AERONAUTICAL
837 MOBIL CHEMICAL COMPANY
838 NAMEPLATES, INCORPORATED
839 NATIONAL CAN CORPORATION
840 NATIONAL PACKAGING COMPANY
841 NELSON ELECTRIC COMPANY
84£ NEWSPAPER PRINTING CORPORATION
843 NICK_£S MACHINE CORPORATION
844 NORD»-A»1, INCORPORATED
64*, KiQ»T»-3pP WOR'_OW!DE PTRCRP^T S£°VICE INC.
64£ \U CHR'j.lE wi_ATING
647 O'BRIEN PAINT CORPORATION
Q<8 OCCIDEN-ftw CHEMICAL
649 OKLA-C'^p CITY DISPOSAL.
650 OK.AHOr-A GAS « E_EC~R!C
851 0-S OS-RQ-.TU^I
6£7 PCuE_'_ SAN:*AT:ON SERVICE
8£8 PO^^ SERVICE CC'T^ANY
8£9 PRE = 5VTER1A\ HOSPITAL.
670, PRES'r
671 PRVOR CDU\DRY,
675 PUBLIC SERVICE Cur^
673 RA NBj CIRCUITS, INCORPORATED
S74 RANDY P_i_IO
675 REAGENT CHE^ICPu & RESEARC-i, INC.
876 RED E-.L ^DTC^ FREIGHT
877 ROCKW'.L INTERNCTICNAu
678 RQCKW '.L INTERvJATICNA,.
879 RCDCC
660 ROTZX :
881 ST. A -KCNY HOSPITAL
382 S.»S. BATING CQr?«\Y
883 SANTA -E RAILROAD
THIS LIST RE ESENTS EPA'S PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY SPONSIBlE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A INAL DETEHINATION CONCERNING THE LIABILITY OF ANY PARTY
FOR THE HA2A OR CONTAMINATION At -?riE YARDAGE SITE
-------
837 SER*-ETEL, INCORPORATED
836 SERVICE PPIN7 "-AvuFACTuRINS COr=>A\Y
883 St-AKLEE CORPORATION
890 SrtE^lM-Wl.LlAM COMPANY
831 SKY WITC^
8si SCwVI.V rpNLFACTURlNG COMPA\Y, IMC.
832 SOONER FORD
834 SSCNER OIL PA'CH SERVICES,
835 SOUTHERN HILLS COUNTRY CLUB
896 SUL.TH PRAIRIE CONSTRUC-ION
837 SOUTHU'SST ELECTRIC CC^PftNY
838 SCJ^r-WSSTERiM STEEL ROLLI\G DOCS
839 SOL'THWEST UMTED INDUSTRIES
900 S^ER^Y VICHER CO^PQVY
901 S^AN! RAMSEY COMPANY, INCORPORATED
902 S'A.vDARD CHEMICAL COMPANY
903 STAR MANUFACTURING COMPANY
90A STEELCRAFT, INCORPORATED
905 STORI PLASTICS, INCORPORATED
906 SL'E'-ETT ft ASSOCIATES
907 SUN GAS
90S TEXACO, INCORPORATED
909 TEXAS INSTRUMENTS
910 TEX PRODUCTS, INCORPORATED
9ii THE BUCKET SHOP, INCORPORATED
912 SAMUEL RC&ERTS NOBLE FOUNDATION, INC.
913 THOMAS & BETTS
SI4 THCTPSCN HAYWA9D CHEMICAL COMPANY
913 UNITED S'ATES AIR FORCE
916 TRIBONETICS COMPANY
9l7 TOV BROWN'S OPTICAL
918 TOX
919 TRIGS DRILLING
9iO TUFTS & SON OF OKLAHOMA
921 UNflRCO COMMERCIAL PRODUCT
9ic: UNI ROYAL TIRE CCMPANY
9^:3 UNIT PARTS, BORG-UARNER COMPANY
9iA UNITED FOAM
325 UNITED PuATING WORKS, INCORPORATED
9£6 UNIVERSAL OIL PRODUCTS
927 UNIVERSITY OF OKLAHOMA
929 UNIVERSITY OF OKLAHOMA
9£9 UNIV. OF OKLAHOMA HEALTH SCIENCE CENTER
930 UNIVERSITY OF OKLAHOMA
931 CCLONEL MARY FELTS
922 U.S. CORPS OF ENGINEERS
933 U.S. DEPARTMENT OF ENERGY
934 U.S. PO-LUTION CONTROL
935 U.S. POLLUTION COr TROL
936 VETERANS ADMINIS"" 3TION
937 WAYNE CIRCUIT
938 WE_CU OIL COMPANY
939 WESTERN ELECTRIC t jvpp\Y
940 WESTERN EXTRACT ri- ,UFACTURING
THIS LIST REPRESENTS ERA'S PRF BINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIE . INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATIC CONCERNING THE LIABILITY OF ANY PARTY
FOR THE HAZARD OR COMAT.NATK AT THE HARDAGE SITE
<» «*
-------
t
I
£
f
0
L
•P
1
r
941
94£
943
544
945
946
947
948
949
950
951
952
953
954
955
95S
957
958
959
960
961
963
9£4
965
966
967
968
969
570
971
972
573
974
975
97£
977
978
573
98O
981
WJ:_SO\'
W. J. LP.'"BI.RTQN
WC-VERINE PIPE
*E5TIN3-TJSE ELEC-RIC COR30RA-ION
SERVICES
GRflPHICS
U.S. S",AL_L BUSINESS
SENERQL MOTORS
SUPERIOR LIN-EN
O.K. KEMORIfiL. HOSPITfiL
JIM'S SEPTIC SERVICES
O-« EMERGENCY PLUMBING
RIVERSIDE INDUSTRIES
UflSTE MflNOGEMENT
IN-E.RNQTIONfli_ SYSTEM & CONTROL
P.fi. INDUSTRJES-POLP3 MftNUFflCTURINiG
flMAX, iNCORPOSflTED
W'flSTE r^P.XflGEME\Tf INCORPORATED
S«\DTRft? SERVICE
COSTER FEED t, SEED COMPANY
JOC OIL EXPLORATION COMPANY, INC.
ALLIED PAIN^ CORPORATION
BOSS-waRMER CORPORATION
CLI=-TCO, INCORPORATED
CODK PAINT AND VARNISH COMPANY
CH£rlCAi_ LEA^AN TANK LINES, INCORPORATED
DIAMOND PAINT COMPANY
EXXON C.-:E*!lCft_ COMPANY
W. R. GRACE 4 COMPANY
GULF STATES PAINT COMPANY
RA^PH LOWE
MQ3NA CORPORATION
NPuCO CHEMICAL COMPANY
T-fE O'BRIEN CORPORATION
P. P.G. INDUSTRIES
RELIANCE UNIVERSAL, INCORPORATED
RO--M A\D HAAS TEXAS, INCORPORATED
WITCO CHEMICAL COMPANY
TRIANGLE ENGINEERING COMPANY
THIS LIST REPRESENTS ERA'S PRELIMINARY FINDINGS * THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON "> IS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATION CONCERNING THE I ABILITY OF ANY PARTY
FOR THE HAZARD OR CONTAMINATIONS! THt HARDAGE 5 'E
-------
I
i
I
f
c
APPENDIX^ C
L COMMUNITY
"
c
i
c
-------
I - COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
b ON THE SOURCE CONTROL FEASIBILITY STUDY
c
HARDAGE/CRINER SUPERFUND SITE
f?
L MCCLAIN COUNTY. OKLAHOMA
f
S NOVEMBER 1986
L
L
E
AR0001?.'
-------
t
r.
Js
r
C-2
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY ON THE
SOURCE CONTROL FEASIBILITY STUDY
HARDAGE/CRINER SITE
MCCLAIN COUNTY, OKLAHOMA
This document summarizes public comments and Environmental Protection
Agency (EPA) responses to questions and concerns raised during the public
comment period. The responsiveness summary Is divided into four sections:
I. Overview
II. Activities to illicit input and address concerns
III. Summary of public comments and EPA response, and
IV. Remaining concerns
-------
c
I
c
p
r
V.
f
r
F
r
I
C
I
C-3
I. OVERVIEW
At this time, the Environmental Protection Agency (EPA) is presenting its
response to comments on the Source Control Feasibility Study (FS) prepared
for the Hardage/Criner site. EPA has not yet selected its preferred
remedy but has developed four remedial alternatives which it believes to
be cost-effective plans, meeting all applicable or relevant and appropriate
Federal requirements for protection of public health and welfare and the
environment.
This site is being managed through the EPA enforcement program. As such,
EPA will make a decision on the "baseline" remedy which 1t feels to be
acceptable. EPA will then negotiate with private parties believed liable
for the site in an effort to achieve voluntary cleanup of the site. In a
parallel manner, EPA is pursuing direct enforcement action under Section
106 of the Comprehensive Environmental Response Compensation and Liability
Act of 1980 (CERCLA) and under Section 7003 of the Resource Conservation
and Recovery Act of 1976 as amended (RCRA).
When a remedy is proposed, EPA will be seeking public comment. Only
after this comment period will EPA make it's final remedy selection.
-------
C-4
B
E
C
f
s...
L
c
G
I
P
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Major Concerns and Issues
One of the major concerns at the Hardage (Criner) hazardous waste site is
evidence from monitoring wells of migration of contaminants from the site
and contamination of residential welfs offsite. The North Criner Creek
alluvium is. the primary aquifer of concern.
Deteriorating conditions at the site (i.e., continuous seepage from the
pits, exposed barrels from the mound, etc.) and inadequate barriers to
retard migration, have given rise to concern for potential surface and
groundwater contamination.
Activities to Elicit Public Input and Address Concerns
EPA has kept members of Congress, as well as other elected officials and
citizens informed of meetings, plans, and alternatives under
consideration. Elected officials and citizens were notified prior to
start of the Remedial Investigation and Feasibility Study (RI/FS) process.
Ten families live in the immediate vicinity of the site. Each family was
interviewed by representatives of the Oklahoma State Department of Health
(OSDH) and the EPA to ascertain their concerns and feelings about the
site. Primarily, these citizens' concerns centered around contamination
of the groundwater, which was originally discovered in the mid 1970s by
the State of Oklahoma in onsite monitoring wells. Since that time, EPA
and OSDH have expended considerable joint effort and resources to determine
the nature and extent of the contamination. Royal N. Hardage, owner and
operator of the site, was sued by the United States in September 1980,
seeking investigation and clean up of the site. Although the United
States established it's case and won a partial judgement against Royal
Hardage, it was unsuccessful in obtaining site clean up, in large part due
to Mr. Hardage's bankruptcy. The U.S. Government filed suit in June 1986
against 36 companies believed to be responsible for public health threats
posed by the site, seeking performance of remedial actions and further
studies as directed by EPA as well as reimbursement of all Superfund
costs incurred, which is more than $1.4 million.
A press release announcing the end of the Feasibility Study, start of the
public comment period, and a public meeting, was issued by EPA on February
24, 1986. Copies of all formal documents concerning the site were placed
in five strategic repositories for the public to review preparatory to
making their comments. Preceding the public meeting held on March 20,
1986, EPA briefed the mayors and other city officials of both Chickasha,
Oklahoma and Purcell, Oklahoma. At this briefing, EPA reviewed past
ac*. ions and ongoing and future planned site activities.
-------
C-5
SUMMARY OF PUBLIC COMMENTS RECEIVED DURING
THE COMMENT PERIOD AND EPA RESPONSE
The public comment period on this FS was from March 10 through April 15, 1986.
The FS was placed in repositories and provided to the Hardage Steering Committee
(HSC) on February 25, the day after a press release announced the end of
FS activities. A March 20, 1986, public meeting was attended by approximately
seventy people, nine of whom made statements. Fourteen sets of written comments
were received, consisting of over 200 pages. These comments were received
from:
1) B&F Engineering - for Weyerhauser
2) Gardere & Wynne - for L&S Bearings, Rotex, and Tribonetics
3) Yardage Steering Committee - a PRP group representing 135 parties,
submitted their own comments as well as those of three consulting firms
retained by the HSC: Dames & Moore, ERM-Southwest, and MDK Consultants
4) Hildebrandt Tank Service
5) Hill 4 Roobins - representing U.S. Pollution Control, Inc.
6) The Hardy Horton Family
7) Hunton & Williams - representing Oklahoma Gas & Electric, comments
endorsed by AT&T
8} Kerr McGee
9) League of Women Voters
10) Rajeanna Mayo
11) Oklahoma Center for Veterans Rights
12) Pat Shepherd
13) Thompson & Knight - representing Firestone
14) Glenn Webb
Comments were also received during the public meeting from the following
parties: Glenn Webb, Kinnan Goleraan (for HSC), Neal Garrett, Tom Smith,
Roberta .Olefield, Linda Wall, Faith Hurley, Ben Kalas (for tCWCL news) and
Mark Fox.
After analysis of the comments, it was decided to organize the responsiveness
summary into seven sections, each dealing with comments on a specific
subject. These seven categories are:
A) Adequacy of data,
B) Operable unit approach,
C) Compliance with the NCP,
D) Feasibility Study process,
E) Opportunity for public participation,
F) Recommendation for additional study or interim remedial measures; and
G) Other comments
-------
f-
C-6
A) ADEQUACY OF EXISTING DATA ON THE HARDAGE/CRINER SITE
Several commenters suggested that existing data is inadequate to fully
characterize the site and develope a permanent and cost effective remedy.
Based on the volume of comments, it appears that either the consultants
which these individuals employed are not fully aware of the amount of
existing'data or that a substantial difference of opinion exists between
EPA and the Hardage Steering Committee (HSC) as to what would constitute
"adequate data". EPAs "Guidance on Remedial Investigation under CERCLA"
Indicates in Section 7.2.3 that the extent of Investigation should not be
more than is "necessary and sufficient" to satisfy site-specific objectives.
Such objectives were defined early by EPA and are documented 1n the November
1983 work plan prepared by CH^M Hill. In the case of a source control
action data must be, and in this case 1s, adequate to establish the degree
of containment of the waste materials with reasonable certainty. The data
must also allow development of feasible alternatives for remediation of
the site, screening of these alternatives, and ultimately selection of an
appropriate cost-effective alternative for remedial action. As 1n any
engineering or scientific study, 100% of the a-'ailable data could never be
gathered. As more and more is learned about the site, further data gathering
efforts will become less productive and of less value in providing new
Information and more auplicative of previous studies. At this point, the
Agency believes that sufficient knowledge of the source areas of waste and
their current state of containment does exist to allow decisions based on
fact and sound engineering principles (not on assumptions or conjecture)
to be made as to the appropriateness, feasibility, and cost effectiveness
of a range of source control remedial alternatives as required by the
National Oil and Hazardous Substances Contingency Plan (NCP), 50 Fed. Reg.
47950, November 20, 1985.
The level of data gathering suggested by some commenters indicates confusion
about the purpose of an FS and the preceding investigative efforts. The
data gathered prior to remedy selection on a Superfund site is not intended
to be so complete as to allow preparation of detailed design for each
remedial alternative or even for the remedy selected. For example, it
would make no sense to collect the extensive data required to design four
remedies when only one will be selected. The data only needs to be sufficient
to determine the most cost-effective feasible remedy protective of public
health and welfare and the environment, not inconsistent with the NCP.
Several commenters pointed out what they believed to be data gaps in EPA's
characterization of groundwater hydraulics and other contamination outside
the source areas. Since a separate RI/FS is planned to specifically address
this, the second operable unit, the comments are noted for future reference
in development of the workplan for the second operable unit (Management of
Migration) RI/FS.
A; UU
-------
C-7
Response to specific questions and comments regarding the adequacy of
data is provided below:
Comment: Certain data indicate that the bedrock may be fairly impermeable
and caple of preventing waste migration, specifically: the
yield of water from interceptor wells installed by the operator
are low, as reported 1n the FS; the packer permeability tests
conducted by EPA contractors 1n 1984 Indicate the permeability
of bedrock is very low, less than 10'7 cm/sec.
Response: It should be noted that the packer tests Indicated permeabilities
were less than 8 x 10*7 cm/sec. Packer tests, when conducted
properly and under favorable conditions, can provide an Indication
of the permeability around the well bore. This does not
necessarily reflect overall permeability of the bedrock or
the ability .of seepage to move rapidly through joints. The
intact bedrock, especially shales, at this site may have
hydraulic conductivities on the order of 10*7 cm/sec, or
less. However, EPA believes secondary permeability (fractures/
joints) rather than porosity, characteristics have allowed
existing contaminant transport. As stated in the FS, the
results of site packer permeability tests would not have been
significantly affected by thin, occasional layers with hydraulic
conductivities on the order of 10-1 to 10-3 cm/sec or an
occasional tnin fracture. This statement is based on estimations
of the water loss through a thin pervious layer within the
packer test sections. Based on the tests conducted at the
site, such a layer would not result in sufficient water loss
during the test to result in an overall hydraulic conductivity
of greater than 10*7 cm/sec, but would allow contaminant
migration at relatively high velocities in these secondary
channels.
As discussed in the FS, difficulties are inherent in monitoring
groundwater quality in a fractured aquifer. The absence of
contamination in a single well, for example, cannot be taken
with any confidence to mean that contaminants have not reached
that general area. This is apparent when one considers the
relatively minor area intersected by a well bore as compared
to the area! and vertical extent of the aquifer which this
well would be intended to monitor (a six Inch well bore with
a twenty foot long screened-sampling-section might be placed
hundreds to thousands of feet from other wells and represent
the only data on this section of the aquifer). When groundwater
flow occurs through preferential channels, as at Hardage, the
II (I II ! M .»
-------
V
E
r
te
F
t
c
C-8
interception of contaminated flow pathways is largely reduced
to a matter of chance. The consistent presence of contamination
in the majority of wells spaced over a wide area carries
great weight in proving the aquifer to be contaminated; and
such a situation is correctly taken to represent contamination
of the entire area monitored by the contaminated wells.
The yield of the Hardage Wells was reported Incorrectly 1n the FS as
one barrel per day. The yield, as stated by Royal Hardage in a 1980
deposition was in fact 25 barrels per day for each of two wells.
Comment: The groundwater contour map presented 1n the FS was developed
with data from different zones. This Is not a correct
procedure since deeper bedrock may be hydraulically confined or
vertical gradients may exist, making contours developed in this
manner deceiving.
Response: The Bison and Purcell Formations are undifferentiated at the
site, comprising a single unconfined hydrogeologic unit; and
present data indicates the bedrock is hydraulically connected
in the vertical direction and in communication with the alluvium.
Therefore, the use of all water level measurements at the site
in preparing the ground-water contour map presented in the
FS is only subject to errors caused by vertical gradients.
Vertical gradients in ground-water do exist and do influence
the phreatic surface obtained from monitoring wells installed
to various depths. During the investigation for the second
operable unit, nested wells will likely be installed to further
evaluate vertical gradients at the site. Based on this information,
a refined contour map may be developed. Overall, this only has an
impact on the second (management of migration) operable unit.
Comment: Data from waste characterization holes drilled through the
sludge mound and main pit suggest that vertical barriers to
seepage exist beneath these areas.
Response: Some data, when analyzed in a cursory manner, could indicate
barriers to seepage exist below source areas. However, the
observed vertical migration of contaminants and their lateral
spread into areas where no other pathway could exist but
through groundwater transport overwhelmingly indicates that
vertical barriers do not prevent susbstantial releases of
contaminants from the shallow to the deeper groundwater.
-------
C-9
L
E
r
• c
to*fe
r~
I
i
r
•p
Ccxnment: The vertical extent of contaminant migration has not been
defined, neither have the vertical flow gradients that would
induce such migration. Such information is needed to fully
characterize site hydrogeology and adequately develope and
evaluate remedies.
Response: Vertical migration of contaminants through the bedrock to depths
greater than 40 feet has been documented to the east, southwest,
and directly beneath the source areas. The Information obtained
from the waste characterization (WT) holes does Indicate vertical
contaminant migration beneath the source areas, as discussed in
the response to latter comments. In addition, ground-water
contamination found in wells EW-01, BH-01. BW-04 and GTW-03
indicates contaminants in ground water at deptn. In each of
these wells, the well screen interval was placed beneath the
phreatic surface measured at the well location, thus contam-
ination found at these well locations are beneath the surface
of the ground-water table and confirm vertical migration. In
addition, several wells and exploratory boring locations were
installed adjacent to deeper wells. Although these were not
specifically intended to constitute nested wells, Information
obtained from these locations indicates a gradient from shallow
to deep groundwater.
Comment: Piezometric levels of groundwater were measured 1n January
and aren't representative of the entire year due to seasonal
fluctuations. This limited data cannot indicate to what degree
wastes in the source areas are beneath the water table.
Response: EPA agrees that the levels may represent a low as compared
to the rest of the year. However, relative levels and the
shape of groundwater contours and flow directions likely
represent an annual average and are consistent with those
developed by earlier investigators (Baker & Burns, 1980; Kent,
1982). Seasonal fluctuations could be better defined in
further studies.
Comment: Geologic cross-sections were not compiled. Such sections
could aid in analyzing site geohydrology, and are a tool
commonly used to perform such analyses.
Response: The bedrock consists of shales, mudstones, and sandstones
which are deposited in discontinous layers. These layers
grade gradually back and forth from one rock type to another.
Since this gradation occurs 1n three dimensions, the classical
concept of a well defined sequence of horizontal or consistently
dipping beds which allows tracing Individual layers of the
i
A
h
U019
-------
C-10
e
t
c
t
ft.
f-
\
L
sequence from one borehole to the next Is not applicable.
As a result of this graded lithology, EPA could make only
limited interpretations and would have had virtually no
confidence in cross-sections compiled with data from these
or any other bedrock borings. For this reason, cross-sections
were not refined or published.
Comment: The sitt may not be suitable for locating a landfill cell in
compliance with RCRA Part 264 regulations; and data 1s
inadequate to make this determination. This should have been
considered before retaining the On-site Disposal Alternative
through final screening.
Response: EPA believes the existing data Indicates that the site 1s
suitable for placement of a RCRA vault; and further study
will be conducted for design should this alternative be
selected. Due to the widespread contamination on-site, low
levels of residual contamination will remain in the soils
over which the landfill would be constructed. A questions
was raised by one commenter as to the potential problems of
monitoring for leaks from the landfill cells, that is, if
contamination were seen in monitoring wells questions could
arise as to whether it is coming from trace landfill's liner
systems. It is EPA belief that monitoring 1n a possibly
contaminated environment will not present insurmountable
technical problems since: (1) The vault will have an interior
detection system capable of detecting any leaks before they
enter a contaminated zone; (2) the vault will be above the
groundwater table, eliminating potential up-flow of contam-
inants into the interior detection system; (3) regular
monitoring will likely be required for any remedy, and long
term water quality trends could be established, allowing
significant leaks from the exterior liner to be detected.
The site is located over several thousand feet of sediments
and is not prone to earthquakes. The area of the site considered
for locating a landfill cell is far above the 100 year flood
and also above the probable maximum flood. Thus, the site
meets the requirements set forth in 40 CFR Section 264.18.
Comment: The geometry of waste fill is not defined. Without such
data, "it is not possible to adequately evaluate any alternatives
or determine either the Feaibility 1n in-s.itu containment or
the need for excavation of the source areas.
.< ~ o o o i
-------
E
I
B
I
I
C
E
r
C-ll
Response: The base of pits excavated during site operations and later
backfilled is defined by depositions of the operator Royal
Hardage and confirmed by test holes in these source areas.
The borings show bedrock at consistent elevations of about
' 1109 and 1093 feet mean sea level (MSL) beneath the
main pit and sludge mound respectively, thus defining the
base of the pits. Magnetometer surveys have located substantial
drum concentrations in the drum mound and along the west side
of the main pit, also confirming early site inspections and
the Hardage depositions.
Comment: A Quality Assurance plan was not prepared 1n accordance with
the NCP. As such, the accuracy of the data and the methods
of data collection are questionable.
Response: The Quality Assurance Project Plan (QAPP) 1s included as
Appendix A to the May 1985 Data Summary Report. This
QAPP meets all the requirements of the NCP (1982 edition),
including concurrence on the plan by the Regional QA officer.
Comment: Sampling from three test holes in the sludge mound failed
EPA's requirements for QA/QC. This lack of data prevents EPA
from making decisions on the disposition of the materials
since it can make no judgement on it's potential threats.
Response: After completion of the Feasibility Study, EPA's Houston Lab was
asked to review the data. The principal problem was that lab
reporting sheets indicated the units to be parts per million
(ppm). Summing the various constituents indicated certain
samples with a sum greater than a million ppm, Indicating
an obvious error. The Houston Lab's review showed that the
units were incorrectly reported and in reality should have
been parts per billion (ppb) rather than ppm. This has
corrected virtually all problems with thfsdata set.
The Houston Lab review is documented in an August 1986 letter
from Bill Langley (EPA-Houston) to Bob Davis (CH2M Hill-
Dallas).
Data also exists from previous sampling of the sludge mound
and in. some cases for wastes disposed there. In addition,
the types of wastes disposed in the sludge mound are known
for the most part to be: styrene tars; drummed aresenic and
cyanide; PCB contaminated equipment; and sludges from oil
recycling, the analysis of which showed extremely high levels
of lead and phenol as well as over 50 ppm of PCBs; and a
composite of all other wastes disposed at the site as a
result of clean-out of the main pit. Samples taken in 1982
-------
C
I
L
r
E
B
C-12
from the surface of the sludge mound indicated PCB-1260,
lead, chromium, anthracene/phenanthrene, dichloropheonol', and
other heavy metals and synthetic organics.
Comment: Poor well drilling techniques may have resulted in cross-con-
tamination of some monitoring wells and waste characterization
holes; thus the results may not indicate deep contamination
of soil and/on groundwater.
Responses: Discussion 1s made regarding the contamination found in the
waste characterization holes (WT) beneath the source areas.
It is suggested by the commenter that only trace levels of
contaminants were detected in bedrock samples beneath the
pits and that they are "probably associated with inadequate
sampler decontamination... or laboratory contaminants". As
presented in the Data Summary Report, EPA (1985), rinsate
samples tak'en from the sampler after decontamination did
indicate a few contaminants at parts per billion levels in
addition to laboratory contaminants. The contention by some
commenters is that bedrock contamination beneath source areas
was mainly the result of sampler and laboratory contamination;
however, this is not substantiated by overall sample analyses.
Consistently, compounds other than those found in the rinsate
and laboratory blank samples were found in bedrock samples
beneath the sources. In many instances, these compounds had
concentrations in the parts per million range (orders of
magnitude higher than that shown in blanks). In addition, in
several holes, compounds were found in the underlying bedrock
samples which were not found in samples taken within the
source area nor in rinsate or laboratory blank samples.
These compounds are however components of wastes known to
have been disposed at the site. The obvious conclusion here
is that the wastes were not, as the commenter suggested,
carried down the borehole by careless sampling procedures,
nor were the compounds introducted at the lab or at any time
after the samples were collected; rather the contaminants are
in fact, as EPA has previously stated, at depth beneath the
source areas and represent the result of actual waste migration
vertically out of the waste pits and into underlying sediments.
In waste characterization hole (WT-006), the results of the
analysis of the composite sample comprised of samples from
28,33 and 38 feet showed very few volatile compounds; however,
the sample taken at 43 feet showed many more volatile compounds
present. EPA believes this pattern of contamination is more
indicative of vertical migration through the bedrock along
secondary permeability features than the result of trace
AR00019
-------
C-13
I
F
r
r
[
contamination on sampling tools. Well GTW-03 showed contamination
in groundwater as did the nearby BW-04 well; however, analysis
of borings taken from GTW-03 showed no contamination of the
- overburden, thus precluding contamination of this well during
construction.
(For further discussion, refer to a previous comment
on vertical migration of waste page C-8).
Comment: No data exists to support EPA's contention that a hazard exists
from air on the site.
Response: EPA recently sent its Emergency Response Branch (ERB) to the
site for purposes other than air monitoring; however, this
was also done while on-site, sampling with a photoionization
unit showed readings less than 1 ppm in air. It has been
observed that odors are much worse on-site in wet weather
than dry wheather-when ERB visited the site. At this time,
EPA must reply that it has no data which indicates an air
hazard from organic vapors exists on-site at this time. It
is entirely possible however, that deteriorating site conditions
could pose threats by this exposure pathway.
Comment: Use of area groundwater is not adequately assessed to determine
the need for remedial actions.
Response: Those groundwater supplies with the potential to be immediately
affected have been considered. Other supplies which could
ultimately be impacted as wastes migrate farther from the
site will be assessed in detail during groundwater/off-site
studies.
Comment: The groundwater pathway of contamination transport off-site
has not been sufficiently defined. The potential for
groundwater contamination has been cited as one factor
requiring remedial action, yet it's potential impact have not
been adequately assessed.
Response: Pathways of groundwater contamination transport were only
considered insofar as they indicate a general Inability of
the bedrock to provide a reasonable degree of containment of
wastes in the source areas. The presence of contamination in
the alluvial aquifer of North Criner Creek and the route of
transportation from the source areas are by and large irrelevant
to the question of the adequacy of barriers beneath these
AR00019J
-------
C-14
;
G
r
r
source areas several thousand feet away. EPA still believes
that contamination of this aquifer has resulted from combined
runoff and sub-surface transport. The question of which
pathway has contributed what to current contamination is of
only academic importance, since significant subsurface migration
has occurred in this and other directions, and contamination
of the alluvium by this method will continue or began to occur
until the sources are exhausted.
Comment: Source areas may exist which have not yet been identified.
If this is the case, then the source control FS is incomplete.
Response: Sufficient information on the operating history of the site
is available from Oklahoma State Department of Health (OSDH)
inspections from 1972-1980 and from the operators depositions
to confirm that Mr. Hardage made efforts to consolidate wastes
in the main pit/drum mound and sludge mound. Site samplings
and recent inspections give no reason to doubt the belief
that the major concentrations of solids, sludges, and drummed
wastes are located in the three principal source areas
addressed by EPA in its FS.
Even if other major source areas did exist, it would not
preclude EPA from addressing the drummond, main pit, and
sludge mound as a single operable unit. The NCP provides
no such constrainst on what must be included in an operable
unit or on how many operable units a site may be divided
into,
Comment: Background quality of groundwater has not been determined.
Without knowledge of background concentrations of chemicals
or elements, it is impossible to determine if the site is
contributing the compounds or if the levels are naturally
elevated and unrelated to the site.
Response: The background levels of synthetic organics (such as solvents)
in this rural area is essentially zero with the possible
exception of pesticides from agricultural application, and
trace levels of natural phenol in groundwater. The background
levels of inorganics will be fully addressed in the Management
of Migration RI.
Comment: The extent of groundwater contamination has not been adequately
defined; and no plume has been shown to emanate from the
source areas. As a result, it is premature to determine that
groundwater contamination requires any remedial action.
AR00019
-------
C-15
Response: Great difficulties exist in monitoring a fractured aquifer
where migration is along preferential channels, and where a
heavily contaminated zone might lie within a few feet of an
apparently clean monitoring well. This characteristic makes
the classical concept of a contaminant "plume" misleading and
inappropriate for describing migration patterns at this site.
In future studies, EPA will undertake to delineate the plume
present in alluvium of North Criner Creek, further define the
lateral extent of groundwater contamination 1n the bedrock,
and evaluate the potential for contaminants to migrate beneath
stream drainage divides near the site. Such investigative
activities properly fall within the scope of the second
operable unit.
Comment: Trends show water quality 1s Improving with time. This could
Indicate that the situation 1s not worsening, but rather that
the groundwater system is recovering by natural processes.
Response: The historica'l water quality data Is indicative of the presence
of off-site contamination. It is not felt that trends in
contaminant concentrations can be drawn from the Information,
since the samples were taken by various parties using widely
varying sampling procedures. Specifically, some samples were
obtained from taps at the residences rather than directly
from the well, thus subjecting the water to aeration during
pumping and stripping of some volatiles.
If off-site sampling results from various sources were comparable,
the well with the largest historical data base (the old
Corley well), does not show any trend whatsoever. Contamination
is similar to the levels first seen in late 1982, two years
after the site closed.
^ 0 0 0 ! 9 I 3
-------
C-16
B) EPA's OPERABLE UNIT APPROACH TO THE HARDAfiE/CRINER SITE
Comments were received which questioned the technical and legal justification
for EPA's decision to divide the site remediation of groundwater/off-site
contamination as discrete and separable problems.
EPA has addressed a substantial number of NPL sites, including several in
Region 6 (Bayou Bonfuca, Gurley Pit, Vertac, Motco, Highlands Acid Pits,
Odessa Chromium I, and Odessa Chromium II), by dividing the response into
operable units. These divisions are made based on technical information for
the site and the criteria presented in the NCP. As noted in the FS, EPA
believed at the time the division was made, and continues to believe, that a
substantial quantity of wastes remain in or near their original location and
are not contained by adequate barriers and that a remedy for source control
will be cost-effective and consistent with a premanent overall remedy for the
site, thus meeting criteria set forth in the NCP for operable unit remedial
response. The best enyineering judgement of the Remedial Site Project Officer
(RSPO), EPA Regional and Headquarters managers, and EPA contractors was that
the vast majority of releases of hazardous substances to the environment
could be abated by controlling these source areas which comprise less than
10% of the site area. Strategies for cleanup of existing groundwater contam-
ination or knowledge cf the necessity of such actions is not necessary in
order to determine the best method of containing the wastes. Source control
and management of migration are in this case clearly seperable; therefore,
further delays are unnecessary and would be inconsistent with provision of a
timely response to a situation posing an imminent and substantial endangerment
to public health and welfare and the environment.
Response is provided below to specific comments on the operable unit approach
taken on the Hardage site.
Comment: No technical justification exists for an operable unit approach to
the Hardage site; the decision to address the site in this manner
was driven by budgetary problems and previous delays in completion
of the FS.
Response: The technical justification for splitting the site into operable
units is strong, as discussed above. The questions about pathways
of contaminant transport to offsite alluvium and the extent of
surface contamination away from the source areas are not mandatory
considerations in the question of source control and the existence
of barriers to migration. Since all proposed source control alter-
natives involve waste excavation and stabilization, which remedy is
finally selected is not a concern ^n relation to the Management of
Migration operable unit, therefore delays to determine the ground-
water/offsite remedy are unnecessary. The criteria set forth in
the NCP for use of operable units has been met; and no strong
justification exists for not using the approach and further postponing
cleanup of the site. The comment • -;at EPA employed operable units
due to budgetary problems is unfour:ed; the cost of the DSR/FS
project was slightly over $800,000 less than is sometimes spent or
far less complicated sites.
:: 0 0 0 i
-------
C-17
t
I
c
r
f
F
i.
r
Comment: EPA has worked on the site for three to five years; so expediting
the remedy makes no sense at this point. Further studies should
be conducted and a new FS prepared to address the site as a whole
rather than as operable units.
Response:-EPA first inspected the Hardage site in July 1979; and a complaint
was filed against the operator in September 1980 under Section 7003
of RCRA. While EPA has been involved with the Hardage site for nearly
seven years now, active Superfund involvement did no begin until 1984.
Field work was commenced by EPA in July 1984 and the FS was released
in February 1986, twenty months later; the normal period of time in
which EPA attempts to complete its investigations and FS on Superfund
sites is eighteen months. Delays on this site under Superfund have
have not been exceptional; and any delays which have occurred do
not provide a justification for further unnecessary delays.
Comment: A cost effective remedy can't be selected without knowing the final
remedy for other parts of the site.
Response: The situation at Hardage is such that excavation and treatment of
the waste piles and pits is required (FS, pages 3-22 through 3-36).
Therefore, the cost-effectiveness consideration is reduced to a
comparison of various treatment technologies and their relative
feasibility, benefits, and permanence. Cost-effectiveness
considerations are only to be applied in comparisons between
acceptable remedies in accordance with Section 300.68 of the NCP.
Comment: A remedy for source control should not have to meet applicable or
relevant and appropriate requirements since it is not the final
remedy [(NCP, Section 300.68 (1)(5)(1)j.
Response: The remedies which EPA has developed and evaluated, while not
addressing the entire site, are permanent for the source control
operable unit. As such, response actions must be in accordance
with these requirements just as if this remedy were for all aspects
of the site. The passage cited in the NCP refers to interim remedial
measures (such as a temporary cap) which may be implemented while
further study or planning is conducted for the permanent remedy.
Comment: The lack of data needed to complete a FS for the entire site prompted
EPA to divide the site into operable units; and these same data
gaps also plague the source control FS. This prevents EPA from
determining the nature and extent of the threat posed or evaluating
proposed remedies.
Response: The "data gaps" are of a quite different nature than the commentor
has implied. Data indicates that releases from the site are
uncontrolled; and knowledge to site conditions Indicates the
situation wil1 worsen.
AR000191
-------
1
fi
I
E
C
0
I
L
E
b
P
F
C-18
Data is inadequate to determine the appropriate remedy for contaminant
that have already left the site or the extent of cleanup required
for surface mixing areas which may remain contaminated. However,
it is EPAs opinion that the existing data is adequate to allow
development of a source control Feasibility Study. The blanket
statement that these inadequacies plague the FS was not supported
-with examples by the commentor. And 1n the conduct of the FS, EPA
has certainly not felt Itself to be "plagued" by this or any other
lack of information.
AR00019H
-------
C-19
C) EPA COMPLIANCE WITH THE NATIONAL OIL AND HAZARDOUS SUBSTANCES
POLLUTION CONTINGENCY PLAN (NCP), 40 CFR PART 300*
Several commenters questioned EPAs compliance with the NCP during conduct
of response action at Hardage. The comments ranged over many points of the
NCP, but were centered on Subpart F - Hazardous Substances Response.
General comments were that EPA had not adequately characterized the site;
the screening of remedial alternatives was flawed or biased; an operable
unit approach is not valid for Hardage; applicable or relevant and appropriate
requirements for protection of public health or welfare or the envlronemnt
were Incorrectly applied or should not have been applied at all; EPA should
have further considered waivers provided 1n the NCP and further evaluated
those alternatives providing less than adequate protection of public health
and welfare and the environment; and cost-effectiveness was not given adequate
consideration.
One important purpose served by the NCP is to provide consistency in appli-
cation of CERCLA from one site to another and from one Regional program to
another; and deviations from the NCP could possibly reduce this consistency.
The current NCP was followed at all points through the FS process; and
compliance with the NCP was a major factor in review of drafts of the FS.
Where formal guidance documents and memos covering compliance with the NCP
existed, the material was used. As a result, EPA believes that the FS is
entirely consistent with the NCP.
Response to specific comments is given below.
Comment: EPAs failure to perform a formal RI is Inconsistent with the
NCP since: 1) the NCP does not suggest EPA may decide not to
L_ conduct an RI when one is clearly appropriate; and 2} the data
collected does not serve the purpose of a RI.
[ Response: The NCP directs that EPA shall "as appropriate" -erform an RI/FS.
This passage does not bind EOA to do an RI if u is not appropriate,
r EPA determined that a discrete RI was not appropriate in light
• of the already extensive data compiled on the site. The purpose
*- of an RI/FS, as explained in the nature and extent of the threat
presented by the release and to evaluate proposed remedies (50 Fed
r Reg). This purpose has been met.
I
*The NCP was promulgated, and is periodically revised, as required by CERCLA,
Section 105. The NCP sets forth the approach to be used in implementing
CERCLA. The most recent revision of the NCP was February 18, 1986 (50 Fed.
Reg. 47912-47968.
-------
C-20
On the other hand, EPA believes that the aggregate of prior
studies and data on the site, when combined with its "Field
Investigation and Data Summary Report", would in fact constitute
a record of substantial equivalence to a discrete RI.
Therefore, the decision was made to move directly to the FS.
EPA must make decisions on how to proceed in cases such as
this based on the best judgement of the RSPO and EPA managers,
and it has acted in a manner not Inconsistent with the NCP in
deciding against the additional investment in time and effort
an RI would have involved. The commenter does not elaborate on
why a descrete RI was "clearly appropriate" on this site.
Comment; The FS is not the functional equivalent of an Environmental Impact
Statement (EIS) as required by the National Environmental Policy
Act of 1969 since the FS does not contain a cost/benefit analysis.
Response: Conduct of a cost-benefit analysis is not required under CERCLA;
this is confirmed by the Act's legislative history (136 Cong. Rec.
§16427 (1980).) Furthermore, the public comment period on the FS
serves the opportunity for comments required under NEPA prior to
expenditure of public funds.
Comment: The five waivers applying to remedy selection as set forth in the
NCP Section 300.68 (i)(5) should be applied and a remedy selected
which does not meet or exceed applicable or relevant and appropriate
requirements tor protection of public health or welfare or the
environment, due to the high cost of remedial actions meeting these
requirements or due to other circumstances set out in the NCP.
Response: The five waivers are stated below along with the reasons they
cannot be applied to the Hardage site.
1) Remedy will become part of a more comprehensive remedy - This is the
final remedy for source control.
2) Fund-Balancing - This test is normally applied where there is a fund-
financed response. This is an enforcement lead site; but there is
notniny to indicate fund balancing would be involved even if this were
a fund-financed
response.
3) Technical Inpracticality - Remedies meeting requirements are technically
feasible and can be implemented.
4) Unacceptable Environmental Impacts - This 1s not anticipated since the
impacts of continued release out weigh those associated with remedial
action.
r 0 0 0 I \)
-------
C-21
I
i
5) Enforcement action where the fund is not available, public desire for
cleanup is strong, and litigation would probably not result in" a better
remedy - EPA believes that, if necessary, litigation will produce the
desired result and fund may be available. It should be noted that
Hardage/Criner j_s_ a National Priority List (NPL) site, so the Superfund
may be applied to remedy the site if the Agency chooses.
For the above reasons, the waivers will not be applied; and the selected
emedy will comply with all applicable or relevant and appropriate requirements.
Comment: Consideration of incineration as a disposal option violates the
cost-effectiveness requirement of the NCP.
Response: Incineration was retained for consideration since the environ-
mental benefits of organics destruction compared to waste treatment
and landfilling are significant. EPA believes consideration
of waste destruction alternatives, such as incineration, is warranted
and that the failure to consider waste destruction would be contrary
to the Agencies commitment to consider permanent remedies including .
those which exceed applicable or relevant and appropriate requirements
Comment: Scoping of response actions was not conducted in accordance with
Section 3U0.68(e) of the NCP.
Response: EPA believes that it in fact has properly considered all of the
scoping factors required by Section 300.68 of the current and
former NCP, as appropriate. Other comments on compliance of the
FS with the NCP are addressed in the following section.
I
r—
i
£ •-. 0
-------
fc
I
r
1
L
C-22
D) The FEASIBILITY STUDY (FS) PROCESS
Comments were received to the effect that the technology screening,
alternative development and screening, and other components of the
Feasibility Study process were flawed due to a lack of data or non-
compliance with the NCR.
While it is true that a lack of adequate data could bias the results of
the FS by forcing the preparers into unwarranted assumptions, the discussion
provided in Section A of this summary regarding what constitutes "adequate
data" is referenced. And, as in response to comments 1n that previous
section, it is again stated that EPA believes the data is adequate for
the purpose of a FS on Source Control. The data may not be adequate for
detailed design; but that is not the present objective. The purpose of
this FS is merely to present analysis and discussion sufficient for
selection of a permanent remedy for source control.
Comment:
"(EPA) has rejected alternatives found to be protective of public health
and welfare and cost-effective at numerous other Superfund sites". This
commenter expressed the opinion that EPA had inappropriately rejected in-
place containment alternatives. The commenter went on to cite 15 Superfund
sites in other Regions which they felt were in conflict with the remedies
considered at Hardage. These sites are:
Region tl Beacon Heights Lanfill, Connecticut;
McKin County (Landfill), Maine;
Region #2 Love Canal, New York;
GEMS Landfill, New Jersey;
Sinclair Refinery, New York;
Helen Kramer Landfill, New Jersey
Region 13 Heleva Landfill, Pennsylvania;
Lackawana Refuse, Pennsylvania;
Taylor Borough Dump, Pennsylvania
Douglasville Disposal, Pennsylvania
Region *4 White House Waste Oil Pits, Florida
Region 15 Wanconda Sand ft Gravel, Illinois
New Lyme Landfill, Ohio
Region 110 Ponders Corner, Washington
South Tacoma Channel, Washington
L
E
L
f- (No sites were referenced in Region 16, where Hardage/Criner 1s located.)
R 0 0 0 )
-------
k
C
i
I
P
P
4
C-23
Response:
At this time, there are hundreds of sites on the Superfund National
Priority List. These sites present unique combinations of factors
involving geology and hydrology, as well as the age, quantity, and
chemistry of contaminants, among other things. For this and other
reason, neither Congress nor EPA has ever taken the position that
consistency between or among Superfund sites is the measure of the
appropriateness of Superfund remedial action at any given site.
The specific test upon which basis Superfund remedial actions are
judged is their consistency with the NCP. In numerous policy
promulgations, EPA has attempted to further clarify those principles
which guide Superfund response efforts. The policy and guidance
documents have changed during the past six years of Superfund implemen-
tation; and they will continue to evolve and expand their scope in the
future, reflecting a predicted increase in the body of knowledge concerning
contaminant chemistry, health and environmental effects, contaminant fate
and transport, and waste control, treatment, and destruction technology,
among other things. As addressed elsewhere within this responsiveness
summary, as well as within the FS Itself, EPA believes that its remedial
action proposals are not inconsistent with the NCP as discussed in the
previous section of this Responsiveness Summary.
For informational purposes, a brief summary of characteristics, differences,
and similarities of the 15 indicated sites vis-a-vis the Hardage site is
presented below, along with a summary comparison of their respective
remedies. As the information presented suggests, the commentator's point
is at best overly simplistic and factually inaccurate. Review of these
sites readily shows why capping may be an acceptable component of the
remedies (just as capping may be included in the second operable unit at
Hardage). The 15 sites referenced can generally be broken into four
categories as discussed below:
Contaminated Municipal Landfills:
Beacons Heights, Heleva, Lackawana, Taylor Borough, New Lyme, and Wauconda
fall into this category. Such sites are characterized by relatively
minor amounts of hazardous materials co-mingled with large volumes of
municipal trash. In this type of situation, wastes are of a far different
nature than the highly concentrated wastes at Hardage.
-------
I
c
f!
r
c
i.
E
E
L
C
I
f-
C-24
Capping of wastes in-places was used only on two sites, Beacon and New
Lyme. At New Lyme, little or no groundwater contamination has occured or
is likely due to hydrogeology. At Beacon Heights, contaminants are
dispersed and removal is not feasible. Two other sites, Lackawana and
Taylor, utilized capping only after partial waste removal. In both cases,
well defined concentrations of drums were present and were removed; the
wastes capped were almost exclusively municipal in nature. One site,
Wauconda, used a cap as an interim measure. The purpose of the cap was
to control surface seepage to a stream.
s
Waste. Oil Recycling/Refining Operations:
The McKin, Sinclair, Douglasville, White House, and South Tacoma sites fall
Into this category. At such sites, the principal concerns are open pits
of liquid waste and waste spills. Spills represent dispersed waste for
which removal would rarely be a feasible option. Pits are drained on
most such sites, resulting in almost total source removal. At all five
sites noted above, emergency or remedial actions Included partial or
complete source removal followed by capping of contaminated soils in
former source areas. This is analogous to the proposed removal of source
areas and possible capping of the former pits at Hardage.
Hazardous Waste Landfills:
The Love Canal, GEMS, and Helen Kramer sites are in this category.
Hardage is similar to these sites only in the respect that similar waste
types were disposed. At Helen Kramer and Love Canal, barriers to vertical
migration exist. The layers make slurry wall cut-off feasible; sands
overlying the aquitards lend themselves to easy construction of the wall
and simple and effective groundwater management. At the GEMS site, no
shallow layer is present; however, a thick sand layer allows effective
groundwater management. In addition, drummed liquids are not present as
they are at Hardage.
Presented below is a brief summary of site characteristics, differences
and similarities between the site and Hardage.
Beacon Heights Landfill Region II 1203 on NPL
Beacon Falls, Connecticut
0 municipal/industrial waste landfill operated 1920-78
0 little drummed or other waste remains; most waste was burned as 1t was
received and only Its residues remain
0 groundwater is contaminated in fractured bedrock
Remedy-Upgrade cap; groundwater decisions deferred
AROOOIO:
-------
i
f
E
t
§
fe
C
t
I
4
C-25
Comparison to Hardage:
Similarities - fractured bedrock underlies both sites
Differences - The majority of waste once disposed at Beacon Heights is
municipal. Little waste remains in its original location,
most has been burned or already released to the groundwater
system.
Remedial Elements:
The sites are not comparable since a well-defined source 1s present at
Hardage; and the sources at Beacon Heights are dispersed, making source
control inappropriate.
McKin County (landfill) Region #1 133 on NPL
Gray, Haine
0 waste oil recycling site operated 1n the late 1970s
0 soils are heavily contaminated by spills of solvents
0 all surface tanks and drums have been removed;
Remedy:
Soil contaminated above the clean-up level (11,000 cubic yards) will be
excavated; soil will be aerated and the off-gas burned; capping will be
over areas below the clean-up level
Comparison to Hardage:
Similarities - solvents contaminate both sites
Differences - McKin was a recycling as opposed to disposal facility;
no drummed wastes remain on-site
Consistency with removal at Hardage:
In both cases wastes will be excavated and properly disposed. McKin
is farther along in remedial process (cleanup levels selected already)
but the remedies appear entirely consistent.
-------
C
f
L
L
F
C-26
GEMS Landfill Region #2 112 on NPL
Gloucester Township, New Jersey
0 Industrial waste landfill operated from 1970 to 1974
0 solid and liquid waste was mixed in pits; few or no drums were disposed
fc
e 6 million cubic yards of contaminated fill present
0 150 feet of permeable sands underlie site, making groundwater recovery
feasibile
Remedy:
Cap site; pump and treat groundwater to remove leachate and lower water
r table below wastes
Comparison to Hardage:
Similarities - similar wastes present
Differences - No drums are in the fill at GEMS. Geology makes groundwater
management a feasible and effective method for intercepting
seepage near the source, unlike at Hardage.
Remedial Elements:
At Hardage, drummed liquids are present in the fill and the underlying
interbeded and fractured bedrock does not lend itself to groundwater
management. These complicating factors make the remedy used at GEMS
inappropriate for Hardage.
Helen Kramer Landfill Region #2 14 on NPL
Mantua Township, New Jersey
0 industrial waste landfill operated from 1970 to 1980
0 2 million cubic yards of waste
e all types of waste are present including drummed wastes
c the site is underlain by a shallow sand aquifer and a deeper aquitard.
M-OIM)!0
-------
I
C-27
Remedy:
Cap the fill; Install a slurry wall upgradient and a collection trench
downgradient, both with their base tied into the aqultard.
Comparison to Hardage:
Similarities - drummed and bulk wastes 1n Industrial type fill
Differences Containment of the wastes directly beneath the site 1s
feasible due to the presence of a barrier to vertical
migration at Helen Kramer.
Remedial Elements:
The lack of a barrier to vertical migration at Hardage prevents effective
containment 1n place as 1s possible at Helen Kramer.
Ponders Corner Region
Tacoma, Washington
* dry cleaner dumped sludges on the companies property
0 solvents have contaminated groundwater
8 sludge piles (sources) were previously removed by the State of Washington
Remedy:
A1r stripping towers are 1n-place on municipal wells and are serving the
dual purposes of groundwater collection and treatment; limited excavation
with off-site is disposal planned for the most heavily contaminated soils.
Comparison to Hardage:
Similarities - solvent contaminated groundwater
Differences - Little of the source remains, most 1s dispersed Into
groundwater system or previously removed; collection
and treatment of groundwater 1s feasible;
Remedial Elements:
The contaminant source at Ponders Corner has dispersed from It's original
location, making source control Inappropriate. For this reason the
sites are not comparable.
-------
i
E-
r
j
(
f-
C-28
Love Canal Region #2 #136 on NPL
Niagra Falls, New York
0 abandoned canal was backfilled with industrial wastes and closed in
tons of wastes including drums are in the fill
0 low-level contamination is present in several media
0 canal excavated in sand overlying plastic clay and till; situation allows
containment in place
Remedy:
Cap was upgraded; slurry walls installed, tied into clay layer; groundwater
collection and on-site treatment system in-place; further studies are
under way due to concern over vertical migration of leachate to bedrock
and the possible inadequacy of in-situ containment.
Comparison to Hardage:-
Similarites - drums in fill; similar contaminants
Differences - low-level contamination outside the canal as compared to
Hardage; containment is feasible due to geology
Remedial Elements:
The shallow clay layer beneath Love Canal is thought to allow wastes to be
contained beneath their original location; however, the adequacy of this l
is still being evaluated. The lack of such a layer at Hardage prevents
consideration of such containment.
Sinclair Refinery Region #2 1117 on NPL
Wellsville, New York
0 former refinery operation with two on-site landfills; soil was contaminated
by spills
0 fill contains principally bulk wastes
e small fill area (2 acres and 10-15 feet thick) 1s adjacent to a river and
Is being eroded; larger fill has a clay liner
* groundwater contamination is present but believed to result from spills
on the site rather than releases from the landfills
AROOOi
-------
I
c
c
c
,t
I
C-29
Remedy:
Excavate the small fill areas, consolidate with the larger landfills and cap;
groundwater will be addressed in other operable units
Comparison to Hardage:
Similarities - Removal is part of the EPA remedy on both sites.
Differences - Groundwater contamination 1s primarily from spills and
already dispersed contaminants rather than the fill or
concentrated source areas.
Remedial Elements:
The landfills at Sinclair are not leaking; at Hardage they are. For this
reason, source control at Sinclair only needs to stabilize wastes against
r flooding and erosion. If necessary, groundwater management would likely
be feasible in the river aquifer.
Heleva Landfill Region 13 1162 on NPL
North Whitehall Township, Pennsylvania
0 low level solvents coming!ed with sanitary waste
6 "source" of off-site contamination appears to be contaminated groundwater
beneath the landfill itself
0 little or no drummed waste is believed present
I
Comparison to Hardage:
terf
Similarities - Similar contaminants observed off-site
B
Differences - Little free liquid appears present 1n the fill at
Heleva, while a large source 1s present at Hardage.
r Since contaminants have generally left the Heleva fill,
( Source control is not appropriate
w
Remedy:
Capping with groundwater pumping and treatment
Remedial Elements:
At Heleva, the "source" of contamination has generally entered the
, groundwater system. This type of situation 1s best remedied by removing
f~~ the contaminated groundwater. Since a large volume of free liquids Is
1 not present in the fill at Helelva, capping was assumed adequate to
prevent further contamination of the groundwater. Such a system is not
i adequate at Hardage due to the physical differences between the sites
1 noted above.
P00019
-------
C-30
lackawana Refuse Region 13 1453 on NPL
Old Forge Borough, Pennsylvania
0 sa'nltary landfill operated through 1976; fill Mas 1n old coal pits
• 10,000 drums dumped 1n one pit over 4 months 1n 1976
* geology makes the groundwater contamination threat to the public m1m1nal
Remedy:
Remove all drums from pit and dispose off-site; cap former pit area
Comparison to Hardage:
Similarities - drummed wastes present; removal 1s part of the EPA remedy
Differences - groundwater contamination 1s less extensive than at Hardage
Remedial Elements:
Hazardous materials will be removed from both sites; at Lackawana the
municipal wastes will be capped. The remedies are consistent since, in
both cases, the wastes will be excavated and properly disposed.
Taylor Borough Dump Region 3 1635 on NPL
Taylor Borough, Pennsylvania
0 municipal/industrial landfill
0 site consists of six distinct areas with varying degrees of contamination
0 drums are present in some parts of the fill
0 the decision on groundwater issues has been deferred to a later operable
unit
Remedy:
Remove all drums; cap areas of surface contamination and municipal fill
Comparison to Hardage:
Similarities - drummed waste present; removal 1s part of the EPA remedy
Differences - surface contamination will be capped at Taylor, while
its disposition at Hardage has not yet been determined.
A \- 0 0 0 i
-------
c
r
c
C-31
Remedial Elements:
Concentrated areas of source materials have been or will be removed on
both sites. The hazardous wastes at Hardage will be dealt with in the
same general manner as were similar wastes at Taylor. For this reason,
the remedies at both sites appears consistent.
Wauconda Sand I Gravel Region #5 1126 on NPL
Wauconda, Illinois
* municipal landfill operated from 1940s to 1979
* less than 3X of the 5 million cubic yards of waste 1s hazardous/Industrial
"fill is in abandoned 'sand and gravel pit
0 groundwater contamination is negligible
Remedy:
Interim remedy is a cap to prevent surface seepage Into a nearby stream.
Further study will be done on the groundwater operable unit.
Comparison to Hardage:
Similarities - Both sites have been split into operable units.
Differences - Hardage accepted almost exclusively Industrial and
hazardous wastes; Wauconda has only a very small percentage
of this type waste. Groundwater has been contaminated
at Hardage, unlike Wanconda.
f* Remedial Elements:
Factors making waste excavation necessary at Hardage are not present at
L
Wauconda. Specifically, Hardage contains a large volume of hazardous
substances which have been and continue to be released and extensive
groundwater contamination is not a driving force behind remedial action
at Wauconda. Source control and the cap are prlnlcpally directed at
controlling surface seepage. Such differences make comparison of the
sites difficult.
New Lyme Landfill Region 15 1626 on NPL
Ashtabula County, Ohio
0 municipal landfill which accepted industrial waste
0 little 1s known on volume or types of waste
• little groundwater contamination
0 if necessary, groundwater management 1s probably feasible
-------
C-32
0 groundwater discharge (up-flow) controls local hydrogeology and
protects groundwater below fill
Remedy:
Construction of a RCRA compliant cap over the fill.
Comparison to Hardage:
Similarities - Relatively small amounts of some wastes disposed at
Hardage are present at New lyme
Oiffences - Little groundwater contamination compared to Hardage site.
No significant amounts of Industrial waste was disposed at
New Lyme.
Remedial Elements:
The groundwater flow system at New Lyme acts to prevent seepage out of
the landfill. Since such a natural system is present, groundwater 1s not
extensively contaminated and a large liquid/sludge source of contaminants 1s
not present, source control 1s relatively straightforward. If necessary,
groundwater management would likely be feasible unlike at Hardage. The
sites are generally not comparable.
White House Waste Oil Pits Region |4 1132 on NPL
Hhitehouse, Florida
0 waste oil recycling facility
0 Emergency Response cleaned out pits and capped the pit areas
0 groundwater contamination present
Remedy:
Repair caps; install slurry wall and pump and treat groundwater.
Comparison to Hardage:
Similarities - groundwater contamination; waste removal was Integral
to remedy
Differences - waste source areas have already been removed at White
House; and geology makes groundwater management feasible
R Tiedial Elements:
I : site remedies are quite similar. In both cases, the source areas were
r ioved. The capping and slurry wall at White House are similar to
IT* :sures which could be considered, for the second operable unit after
t ' sources have been removed.
-------
C-33
Douglasville Disposal Region #3 1103 on NPL
Douglasville, Pennsylvania
0 oil recycling facility;
0 site is located adjacent to river and subject to flooding
0 in previous actions, drums were removed; lagoons cleaned out and sludges
land fanned on-site; spills have contaminated site
0 groundwater and soils are contaminated
0 river alluvium underlies site; slurry walls are feasibile to cut off
lateral flows
Remedy:
Cap site; and build flood control levee; a slurry wall may be part of the
groundwater remedy
Comparison to Hardage:
Similarity - groundwater and soil contaminated
Differences - former oil recycling facility; source areas have already
been removed; groundwater management is feasible
Remedial Elements:
Source areas have been or will be removed on both sites; the remedies
are consistent in that similar wastes are handled in a similar manner-
(i.e. excavate and treat hazardous wastes).
South Tacoma Channel (Commencement Bay) Region #10 #11 on NPL
Tacoma, Washington
0 waste oil recycling and tank clean-out facility operated in 1960s
0 filter cake containing tetrachloroethylene (PCE) was used as fill soil
0 contaminants from spills are dispersed in the soil and underlying
aquifer
Remedy:
Excavate hot spots of CE and install vapor extraction points in the
ground. Continue air-stripping water in a nearby municipal well.
Comparison to Hardage:
Similarites - groun'water contamination
Difference - sourc • of contamination is spill areas which have already
dispe sed into the groundwater system; groundwater
manag ent is feasible.
AFOUUilK!
-------
C-34
k
L
E
r
f
L
C
Remedial Elements:
At South Tacoma, the waste is dispersed and source control is not
applicable. The cap in this case has a very specific and limited
purpose, to allow solvent vapor extraction.
Other comments related to the Feasibility Study process are as follows.
Comment: "A rotary kiln incinerator has the potential for Incinerating
the site wastes, but Its feasibility has not seen demonstrated."
Process upset could result In the emission of dioxins and
furans. The mixture of wastes present would pose problems over
and above those associated with a costant waste stream.
Response: Incineration of the specific mixture of wastes present at Hardage
has not yet been demonstrated.However, the types of waste
present have generally been destroyed In this manner. The
problems cited contribute to the cost of over $300 million
estimated for incineration alternatives. Bench tests and
possibly pilot studies would be essential to the remedial
design as would be emissions testing.
EPA considers Incineration on virtually all Superfund sites
where organic contamination exists. It 1s never stated that
the construction and operation of an Incinerator would be
simple, only that at this point it appears feasible, and warrant
consideration due to It's benefits.
Comment: Incinerator ash may be eligible for de-listing as a RCRA
hazardous waste on a site specific basis.
Response: If treatment of ash removes the characteristics of a hazardous
waste (primarilly EP Toxicity 1n this case), the ash may be
eligible for delistlng. Based on a rlsk-assesment, delisting
could be considered after it Is demonstrated that the above
criteria could be met.
Comment: On-site incineration provides no time advantage over off-site
incineration, since the off-site treatment won't take 10 years
as assumed 1n the FS.
Response: The 10 year figure was based on current backlogs for existing
units. While capacity may increase 1n the future demand will
also Increase. Reduction of the 10 year figure Is not warranted
at this time.
Comment; Groundwater recovery (pumping) would be feasible 1n the bedrock
and should not have been el minated from consideration.
Response: The commenter has ignored t'e extensive data collected Indicating
fracture zones, uniformly 1 v yield, and the fact that wells
pumping from fractured bedr ck will produce a small cone of
depression. For this reaso , withdrawl wells would have to be
closely spaced and very dee , creating an large quantity of
AhUOUll
-------
c
I
r
£-
if
c
r
L
f
C-35
Although the system would still allow substantial releases as
described in the FS, groundwater recovery by withdrawl from a
collection trench system as described 1n Alternatives 4 and 5,
- was deemed feasible.
Comment: Technologies for reuse or recycling of waste should have been
considered, particularly "Basic Extraction Solvent Technology"
(BEST) as employed on the Savanaha site 1n Georgia.
Response; As noted 1n the FS, the extreme variability of the wastes at
Hardage virtually eliminates the use of known reuse/recycle
alternatives. Solvents Extraction Is quite useful where wastes
are homogenous liquids. However, the waste stream at Hardage
1s highly varied and much Is a high density sludge. The application
of solvent extraction to high sol Ids content wastes will only
result 1n a minimal reduction 1n volume to be dealt with.
Reuse/recycle treatments will be considered for certain wastes
if technologies become apparent 01 are developed.
Comment: If the site had been operated after 1980 then capping would have
been an acceptable measure for closure under RCRA. Yet EPA
states that capping 1s not viable enough to even consider as an
acceptable remedy.
Response: The site was not operated after November 1980, partially due
to the operators Inability to meet new requirements for hazardous
waste land disposal facilities which went Into effect at that
time. Facilities which legally operated after November 1980
presumably were better managed with at least some safeguards
built in. In some cases this may make capping adequate for
containing the wastes. The Hardage facility had no such safeguards
and bedrock has been found to provide Inadequate barriers;
therefore, simple closure 1n-place Is not acceptable. (Note:
The commenter went on to argue against the application of other
provisions of RCRA as applicable or relevant and appropriate
requirements).
Comment: The factors used to screen all alternatives and eliminate several
were Inconsistent with those dictated by the NCR. If the
appropriate factors had been applied, then the FS night have
reached different conclusions.
Response: Section 300.68(g) of the NCP states that, "Three broad criteria
shall, as appropriate, be used 1n the Initial .creening of
alternatives." The three "broad" factors to be used are cost,
acceptable engineering practice, and effect1vp'.-ss. The ranking
factors used 1n screening of alternatives 1n t e FS were:
4
AROOOJH
-------
G
r
S
L
F
i
r
C-36
reliability, implementability, safety, environmental, institutid^B
and cost. The factors considered fell in the broad categories ^^
listed in the NCP and are consistent with the screening factors
listed in EPA's FS guidance.
Comment: The alternatives which should have been retained for further
consideration in the FS were Alternatives: *3-Capping. 05-capping
with perimeter drains, |7-0n-s1te landfill, and 110 Off-site
disposal.
Response: The commenter suggest considering two alternatives which EPA
rejected (13-Capping and 15- Capping with Perimeter Drains).
Documentation for rejection of alternatives numbered 3 and 5 is
provided In the FS on page 3-27,28 and 3-29,30 respectively.
The principal reason for rejecting these alternatives 1s their
inability to significantly reduce the^release of leachate Into
the groundwater system.
The commenter also suggest rejecting two alternatives which EPA
retained (18- On-Site Incineration and Disposal and 19-On-Site
Incineration/Offsite Disposal). EPA disagrees with the commentert
Congress, in the 1984 ammendments to RCRA, has determined that
land disposal of soils contaminated with certain wastes, Including
many solvents, should be banned, although a two year extension
is provided for CERCLA response actions. Prior to such
some facilities may be hesitant to accept a large volume of
waste with bans pending on it. Destruction of organics is an
enormous benefit, in that the destroyed compounds will no
longer be capable of posing threats to the public or environment.
EPA is specifically directed by the NCP to consider alternatives
exceeding requirements. Incineration falls Into this category
and the benefits may prove commensurate with the costs; therefore
consideration of Incineration 1s appropriate.
Comment: The adverse effects of waste excavation were not considered.
These may pose unacceptable environmental Impacts and be grounds
for selecting an in-sltu alternative not meeting requirements.
Response; The hazards associated with excavating the site were recognized
in the FS. It 1s believed that releases to all «ed1a except
air, can be readily controlled. Releases to air will be minimized
by dust control measures, handling and excavation techniques
aimed at minimizing the volume of waste 1n the open at any
given time, and possibly placement of a temporary structure
over the waste excavation. A1r aonltorlng will be performed
and the potential threat to adjacent residents will be monitored
throughout operations as will be the potential need for their
Immediate evacuation. Threats to workers are ?al; but this 1s
the reason for extensive safety precautions an health monitoring.
-------
C-37
Comment: A risk assesment should have been performed on the Hardage site.
Response: A preliminary Public Health Assessment has been prepared and
Mill be supplemented as further data 1s obtained.
Comment: The detailed developement and analysis of alternatives presented
1n the FS 1s Inadequate and may not allow selection of the most
appropriate remedy from the four finalists.
Response: Section 300.63(h)(2) of the NCP sets out the factors to be
Included, as appropriate, 1n the detailed analysis. These
factors are: 1) refinement and specification of alternatives;
2} detailed cost estimate; 3) engineering evaluation of effect-
Ivness, 1mplementabil1ty, and constructability; 4) assessment
of effectiveness of remedy 1n meeting remedial objectives;
5) analysis of alternate technologies; 6) analysis of costs of
adverse Impacts and their mitigation.
These factors were addressed, as appropriate, and alternatives
were refined in sufficient detail to allow selection of an
appropriate remedy. The development 1s not to a design level,
but it is not intended to be.
Comment: The findings of fact and conclusions of law arrived 1n 1982 by
the U.S. District Court in Oklahoma City concerning the site
should not have beer, relied upon to d eve lope a remedy.
Response: The findings and conclusions were not used 1n the FS 1n the
manner that the commenter suggested was the case. The facts
which led to development of these findings and conclusions have
for the most part been supported by data obtained since 1982,
and have therefore been properly considered, along with other
relevant investigative and factual Information concerning the
site. EPA did not mean to Imply that these findings and
conclusions had to be taken at face value, as they certainly
were not during the FS but were re-examined as appropriate.
F
£-0001935
-------
C-38
6
E
E
F
E
L
[
E) OPPORTUNITY FOR PUBLIC PARTICIPATION
Comments were received which Indicate some parties feel EPA should have
made a "greater effort to Involve those parties potentially liable for the
site 1n development of the FS and should have allowed more extensive
comments on the FS. The NCP as well as current EPA policy 1s cited as
support for this argument.
Where appropriate, EPA will generally Involve PRPs 1n studies and development
of response actions. The reasons for this are numerous, not the least of
which 1s the previous experience of the Agency which suggests that those
parties most directly Involved 1n studies and most familiar with the
rationale for EPA decisions will be most willing to participate 1n voluntary
clean up. At the Harda.ge/CHner site, the enforcement policy documents
which recommend PRP participation 1n the RI/FS were appropriate, had not
been promulgated by EPA at the time the FS was committed. In addition, a
PRP search had not yet been completed. For this reason, PRPs were not
Involved from the outset. In December 1984, an Initial group of nearly
300 PRPs was notified of their potential liability on the site. Since
that time, approximately 135 parties have formed the Hardage Steering
Committee (HSC).
EPA has met with HSC often since its formation. Final documents have
been provided in a timely manner; and over 200 requests for documents and
information have been answered in writing under the Freedom of Information
Act since early 1985. Communication has been frequent between both the
technical and legal staffs and have been as open as the enforcement nature
of the site allows.
Comment: EPA refused to afford HSC the opportunity to participate 1n
development of the RI/FS. These actions violated EPAs own
guidelines including the March 20, 1984 **mo from Lee Thorns,
"Participation of PRPs in development of .U/FS under CERCLA
and the draft CERCLA Settlement Policy".
Response: The March 20, 1984 memo Indicates that PRPs may be allowed, to
where appropriate, to conduct the RI/FS under an EPA approved
scope of work and under a formalized agreement such as a Consent
Decree. This policy 1n no way requires or Indicates that EPA
will abandon on-going studies merely to allow PRP conduct of
an RI/FS. Regional experience has been that when conduct of
an RI/FS has been switched from one EPA contractor to another,
significant delays result. Even greater delays would be expected
in transfer of the RI/FS to a party out-side the Agency. In
addition, previous activities of HSC have not indicated that
an FS could have been completed by them more rapidly than by
EPA. The Hardage Steering Committee had not been organized at
the time the FS was Initiated in January 1984; aside from this
purley practical reason for not allowing HSC to conduct an
RI/FS, other factors enter Into this situation.
A: 0 0 0 19
-------
C-39
The draft "CERCLA Settlement Policy" referenced to 1n the
comment was issued October 4, 1985, and does not constitute EPA
policy. Instead, EPA's settlement policy is contained in the
Interim CERCLA Settlement Policy as set forth in the Federal
Register on January 5, 1986. At this time the FS was in its
later stages of development.
Comment: Insufficient time was allowed for comment on the FS. The document
is extensive and detailed, thus a comment period substantially
longer than the minimum three weeks required by the NCP would
have been appropriate.
Response: There was a 5 week comment period on the FS; this Included a 15
day extension requested by HSC. addition, the FS was placed 1n
repositories and provided to the HSC two weeks before the
formal comment period began, providing a total of approximately
seven weeks" for Interested parties to review and comment on the
FS. While EPA and Its contractor did spend approximately eight
months compiling the 200 page FS, all data from which this FS
was compiled has been available to the public from the time EPA
began the FS in mid-1985.
Comment: EPA must afford the HSC an opportunity to finalize and present
its own response plan before selecting a remedy.
Response: EPA has repeatedly been told that HSC Is or will be preparing
some type of response plan. Unfortunantely this work has never
been produced, forcing EPA Into the conclusion that such work
may not be done even 1f EPA were to wait. Any response plan
submitted to EPA will be considered, as have all proposals.
documents, advice, and comments In the past, provided such a
plan is received in a timely fashion. EPA guidlines and
regulations do not, as the commenter states, require EPA to
afford the HSC an opportunity to finalize and present this plan.
-------
C-40
L
I
I
r
t
F) RECOMMENDATION FOR ADDITIONAL STUDY AND/OR INITIAL REMEDIAL MEASURES
The commenters have proposed a general plan for additional studies which
in their.opinion, should be conducted prior to selection of a remedy for
the site. These studies would supplement EPA work and be aimed at developing
a RI/FS for both operable units of the site.
These commenters have also proposed to conduct initial measures aimed at
site stabilization. These measures would mainly included:
1) fencing of the entire property,
2) construction of a temporary cap and collection system for surface
seeps
3) monitoring of drinking water supplies and construction of alternate
water supplies if necessary.
EPA feels that some of the study items suggested by the commenters are
appropriate. Some of the additional study items and are being considered
by EPA as necessary components of studies for the second operable unit.
EPA sees no purpose in rethinking its previous decision to split the site
into operable units.
The proposed "removal" actions have also been considered by EPA. An EPA
site assessment team was dispatched to the site in June 1986 and, following
the teams report, action will be taken as necessary.
•r
L
L
AR000193
-------
C-41
L
r
t
c
•
L
p
L
f
f
G) OTHER COMMENTS
Comment: Has EPA considered incineration and disposal of the entire
waste volume at Hardage through underground injection. In this
area, formations below 3000 feet often show caverns which take
enormous amounts of fluids and cannot be plugged by addition of
sealant or bridging materials.
Response: Two problems would be presented by disposing wastes 1n the
fashion suggested: the actual ability to do this and the legal
and permitting constraints.
The physical problems with Injection would be significant. The
volume of waste considered for disposal Is roughly 179,000
cubic yards, or 36 million gallons, of soils and sludge. To
allow Injection, the waste would have to be slurrled with
water, forming a volume In exess of 100 million gallons of
waste slurry. While this volume could theoretically be Injected
in the space of a few weeks, the enormous volume of solids
would likely clog cavities rapidly, requiring construction of
several wells over an area significantly larger than the site.
Considering the type of waste found at Hardage, 1t 1s unlikely
such injection wells would be permitted by EPA or the State of
Oklahoma.
Comment: EPA should select the On-site Incineration/Off-Site Disposal
Alternative. This 1s the only way to achieve a permanent
remedy for the Hardage site. Several commentors expressed this
sentiment; one felt that the On-s1te Incineration and disposal
plan would also be adequate.
Response: EPA favors an on-site disposal plan due to several factors Including:
1) the volume of waste present;
2) hazards associated with off-site transport;
3) questionable availability of an off-site disposal facility; and
4) the fact that an off-site plan merely shifts hazards to
another location and population.
EPA will give appropriate consideration to the Incineration
options. The decision will be available for public comment
before being finalized as a Record of Decision.
Comment: Incinceration should not be selected since 100% destruction of
compounds such as 2,3,7,8 - tetrachlorodlbenzo -p-diox1n (TCOD)
cannot be achieved. In addition, partlculates should be sampled
prior to emmission to the air.
AROOOIO
-------
C-42
k
I
c
r
r
'•I
I
!L
-.P
Response: 100% destruction of anything can never be achieved. Incinerator
testing by EPA in Missouri has in all cases achieved greater
than 99.9999% destruction of TCDD and has effectively destroyed
. even hard to burn compounds such as carbon tetrachloride. EPA
sets limits on particulate emissions by incinerators and these
solids would be analyzed in test burns and periodically throughout
the operations.
Comment: The waste could be disposed as follows:
seperate water/solids by settling
dispose the water 1n an injection well
heat the solids to dry them
seal the solids in a plastic/cement "casket" and bury
dispose the dirt in another manner
This plan is, in some ways, similar to the on-site disposal option,
The waste treatment and handling techniques have not yet been
finalized. These comments and plans will be considered in the
design phase of remedial planning.
Comment; Do provisions exist for indemnifying contractors involved in
remedial work on Superfund sites from possible future liability
under CERCLA for hazards arising from the site at some time
after this work is completed.
Response: Under current law, the contractor cannot be indemnified even
for actions carried out at EPAs direction. Provisions for
contractor indemnification will likely be in revised CERCLA
statutes being developed Congress.
Comment: EPA should have more thoroughly investigated deep bedrock to
identify existing contamination and evaluate the potential for
contamination in the future. This needs to be done since it is
contamination of deeper ground water and transport through that
flow regime which has the potential to affect populations not
in the immediate vicinity on the site.
Response: One of the key purposes of the Management of Migration RI/FS
will be to define the long-term potential for migration along
pathways such as the deeper groundwater. Three wells drilled
on-site to depths of 200 feet or more showed no contaminants at
detectable leve's.
-------
APPENDIX G
DETAILED COST ESTIMATE FOR THE
SELECTED REMEDY
-------
iUMINARY
.-MftQAGE INXfiTRIAL -ASTE SITE
CSI.€S, GKUIHGflA
EPA *)€DY WITH EXCAVATION OPTION
ITE»
UNIT UNIT EXTENDED
QUANTITY £ASUflE COST COST
Section 3 - DETAILED SEJCDY DESCRIPTION
3.1 Source ftooval I Control
3.:.1 Liquids ftesoval and Disposal
DfllH SMOVAL
rquapaent
Traexed Excavator (1-CY)
Tracked Excavator (2-CY)
vacuum Truck
Forklift (2 units)
Backnoe (2 units)
Duap Trucks (6 units)
Flat Bed Truck (2 units)
Pickup Truck (2 units)
Support Equipeant
Air Emissions Control
Material
Labor
Formn (Ifihr/day i Z wn)
Equip Optrators (16 hr/day
x 6 vn)
Truck Drivtrs (16 hr/day x
6 MA)
Labortr (16hr/day x 2 «n)
Industrial Hygient Tfdi
(16 hr/day x 2 «n)
HMlth/Safrty Equipwvt
- Class A
- Class B
Total
16
16
16
32
32
96
32
32
1
32
366
11,776
35,328
35,328
35,32*
MB
MS
KB
MOS
KB
MB
MB
MB
LS
MB
DAYS
MS
MS
MB
HRS
«S,650
8,000
11,040
1,517
2,725
3,050
755
510
112, 000
1,000
300
35,00
31.50
25.60
24.60
WO, 400
128,000
176,640
48,544
87,200
292,800
24,160
16,320
112,000
32,000
110,400
412,160
1,112,832
904,397
869,069
11,776 HRS
32.00 376,832
7,360
8,832
MHW
m-m
135.00
75.00
OM9O HASTE STASINB/COeOLIOATiaN AEA
Sitt Grading 2,047
Building
Concrttt Slab 185
On* Opvninf Am 1
toof Cove-ing 10,000
Stum ATMS 1
Conwyor Racks 210
Equiownt 1
CY
993,600
662,400
16,449,754
M.96 f 1,965
CY
LS
SF
LS
LF
LS
180
14,000
5.15
30,000
48
182,800
33,300
14,000
51,500
30,000
10,080
182,800
-------
HWMflE INDUSTRIAL KftSTE SITE
CRINER, CXLflHOMfl
EPA R0CDY rflTH EICflVATIQN OPTION
ITffl
UNIT 'KIT DTEMDED
QUANTITY ICASURE OBT COST
Section 3 - DETAILED SEJEDY DESCRIPTION
3.1 Source ftewval t Control
3.1.1 Liquids taoval and Disposal
ORUWED WASTE STflBIIS/CONSOLIDATION AREA - Continued
.-oreean
Teen - Level 1 (16 ftrs)
Teen - Level 1 (8 hrs)
Health/Safety Eouipecnt
Maintenance
Disposal of Organic*
Transportation (150 trips)
Incineration
Disposal of Oruvs
Closure
Total
REMOTE STORAGE AREA
Rente Storage Area
3.1.4 Soil Vaoor Extraction
SOIL VAPOR EXTRACTION
Sitem*
Buildine*
Blower Building.
Eauipemt
Blower - 9,000cfs
Tank - 2,OOOgaJ
Pipmq
Monitoring Probes
a, ass
a,a£
4,416
i
i
75,000
300,000
1
1
HRS
HRS
HRS
LS
IS
HI
OILS
LS
LS
35.00
£4.60
34.60
289,800
11,400
3.75
4.04
1,300
39,300
309,120
217,267
108,634
289,800
11,400
281,250
1,212,000
1,300
39,200
1 LS
f 19,900 t!9,900
1
2,160
5
1
1
100
LS
SF
£fl
EA
LS
EA
«10,000
41,000
6,000
900
«10,000
90,000
206,000
6,000
600,000
90,000
2,733,616
19,900
-------
ILIMINARY
INDUSTRIAL 4STE SITE
CHINES, OKLflhOMfl
cPfl REMEDY WITH EXCAVATION OPTION
ITEM
UNIT JUT
QUANTITY MEASUfE COST
EXTENDED
COST
Section 3 - DETAILED REMEDY DESCRIPTION
3. : Sourct Rnoval I Control
3.2.4 Soil Vaoor Extraction
SOIL VAPOR EXTRACTION - Continued
SUBTOTAL - Know Costs Only
General Conditions » » of SUBTOTAL
Finishes t 1* of SUBTOTflL
ElKtrical t 1« of SUBTOTflL
Instrumentation I Controls I 5* of SUBTOTflL
yard Piping t 5* of SUBTOTflL
SUBTOTflL - Pwctntag* Costs Only « 26* of SUBTOTAL
SUBTOTAL - Known and Ptrctntao* Costs Only
Mobilization I M of SUBTOTAL - Knows + *
Pilot Studin 1 IS 550,000
SVE Start-tip Strncw 1 LS 30,000
Subtotal
«1,001, 000
67,635
13,527
135,270
67,635
67,635
tl, 352, 703
67,635
550,000
30,000
12,000,338
AIR TREPJWff
Sitawrh
Concrete
Slab on Grade
Eqvipemt
LP Tank - 18,000pl
BlOMer
ThenHl Oxidation Unit
SUBTOTAL - Know Costs Only
Seneril Conditions 9
Electrical t
Instrumentation I Controls
Yard Piping t
SUBTOTAL - Percentage Costs Only - 70* of SUBTOTflL
SUBTOTflL - Known and Percentage Costs Only
Subtotal
1 LS
267 CY
1 Efl
£ Eft
1 EA
of SUBTOTflL
of SUBTOTAL
of SUBTOTAL
of ^UBTOTAL
. tftt ~* anrnr
200
16,000
38,500
612,000
ra
»10,000
53,400
16,000
77,000
612,000
1768,400
54,886
109,771
54,886
109,771
11,097,714
1,097,714
-------
tfftOAGE INDUSTRIAL 4STE SITE
CSifCR, QKLAHOW
EPfl REKEDY WITH EXCAVATION OPTION
ITB
UNIT WIT EXTENDED
QUANTITY NEASUflE COST COST
Section 3 - DETAILED REfflJY DESCRIPTION
3.1 Source Reeoval t Control
3.1.5 Adjacent Source flMoval
REWVAL Cf ADJACENT WASTES
North ^ond Area
Excavation
Pltctmnt under cap
Onn rtMdiation
Transport
Incineration
West Pond Area
Exc/Haul/Placee*nt
U trench
Exc/HMl/Planecnt
V trench
Exc/Ha«l/Placeamt
SU trend)
East Far* Pond tt (HSC)
East Far* Pond 12
RDOY TOTAL
5,800
5,300
730
lt4flB
63,200
2,704
11,015
1,275
1
1
CY
cy
Ml
GAL
CY
CY
CY
CY
IS
15
MS. 15
11.77
3.75
4.04
17.23
16.54
16.54
16.54
171,000
317,000
«26i,B70
6B,266
2,813
5,999
1, 092.72S
44,724
183,346
21,089
171,000
317,000
12,168,834
-------
1MXJSTRIAL HASTE SITE
CR!:€R, OKLAHOMA
EPfl REJCDV «ITH EXCAVATION OPTION
ITEM
Strtion 3 - DETAILED (BOY DESCRIPTION
3.1 Sourct ftawval t Control
11. S Sourer Area doping
SITE OPS
Storautcr Btra
Sttmticn Basin
Clean Soil Placwnt
Ptriamnt Cap
RMovt Mill
AHOVW Pipiiq f Mills
Scale a*ass
DiK 6'
24' Clay
Will OPE
12* Sand
Strip Drains
Colliction Plot
Scotntili
12* Granular tetmal
GMtntilt
18* Nativt Soil
6* Topsoil
GNMtrii
Covtr
UNIT UNIT
MEASUfE COST
COST
4,000
1
5,800
400
400
33.10
72,957
59,160
88,777
29,580
1
1
88,737
29,580
88,777
44,369
14,790
58,670
88,737
LF
LS
CCY
EA
Eft
A£
SY
CCY
SY
CCY
LS
LS
SY
CCY
SY
CCY
CCY
LS
LS
«4.00
10,000
14.84
100.00
20.00
50.00
0.19
14.84
7.20
15.84
38,830.00
1,680.00
1.20
25.00
1.20
5.13
14.81
1.55
0.33
«6,000
10,000
86,072
40,000
8,000
1,655
13,862
877,934
638,906
468,547
38,830
1,680
106,484
739,500
106,484
227,613
219,040
90,939
31,058
flEHEDY TOTAL
«3,722,605
-------
ITEM
HMMQE 1MXJSTRIAL WASTE SIT
MINER, OKLPHOW
EPA (OEDY WITH EXCflVflTION OPTION
UNIT WIT EXTENDED
QUANTITY MEASURE COST COST
Section 3 - DETAILED KKDY DESCRIPTION
3.2 SroundMatir Extraction t Treatsint
3.2.1 BroundMter Trtncnts
SROUNWATER COLLECTION TRETOES - Continued
V-SHAPED TRENCH
Soil Excavation
Borehole dia 13') 77 holts
Borenole dia<2"> 836 holes
flesove Rita
Irwrt tnd pipt* (77 holts
x 33.5 FT/holt)
Plan coant gravtl
Plact wdiw sand
Plan soil limr
fttplan M^gradt to gradt
yithdraMl Mils (6 *tdi)
Pwps
ElKtric cabin
Ttflon disctMryi howt
to piping
Colltction LiflM
Trtncti HIM
Lattrtl to Plant
Trtncniiq coit (Excava-
tion ft Btcfcfill)
Pu? control Itrs
Withdrawal wlls
P.L Scrnn <6 iich dia)
P.L Casing (6 indi dia)
Protective casinq
Count Sand Backfill
Low Ptr» Soil Backfill
Labor
Observation Wells (71 eacfl)
P.E. Screen (4 inch dia
x 10 If /mil)
P.E. Casing (4 inch dia
x SO LF/Mll)
Gravel Fill (71 wlls)
Lou Oer> Soil Backfill
Protective casing
Lricr
Sub Subtotal
330 LF
2,900
100
3,000
1
60
303
6
77
5
1
710
3,386
970
36
71
1
LF
LF
LF
LS
FT
LF
EA
CY
CY
LS
LF
CY
CY
EA
LS
161.06
35.00
15.92
16.30
2.48
1,265.00
2.00
3.00
5.83
9.89
1.73
3,000
20.00
16.50
250.00
15.92
20.00
6,780.00
6.10
4.17
15.92
20.00
150.00
8,970.00
663,526
22,135
156,318
10,445
28,272
7,590
6,660
990
16,907
989
5,250
5,000
1,200
5,000
1,300
1,226
100
6,780
4,331
14,954
15,442
1,120
10,650
8,970
3,037,3%
-------
HARMGE IttUSTRIflL i*STI SITE
C3INER, QKUVOft
EPfl SS€DY Him EJCflVflTIQN OPTION
ITS!
UNIT
QUANTITY CASUflE
JUT
COST
EXTENDED
COST
Section 3 - DETAILED RENEOY DESW1PTICN
3.2 SroundMater Extraction t Treateent
3.2.1 Sroundiiater Trencnes
SROWOMflTER COLLECTION TRENCHES - Continued
SX7MEST TRENCH
Mobilization
Soil Excavation
Borenole dia (3')- 17 ea
Borehole dia (2*)- 176 ea
Reeovw Rita
Insert end pipes (17 t 30*
Plan coarse gravtl
Plan eediui sand
Plan soil liner
Replace subgrade to grade
Withdrawal Mils
Puapt
Electric cables
Teflon discharge hoses
to piping
Collection Lines
Trench Lines
Lateral to Plant
Trenching Cost (Excava-
tion t Backfill)
MMep control lers
In-line PUB? to transport
over 8* line
VithdraMl Mils
P.E. Screen (6 inch dia)
P.E. Casing (6 inch dia)
Protective casing
Course Sand Fill
LOM Per* Soil Backfill
Labo-
Observation Mils (15 etch)
P.E. -een<4* x 10'/ea)
P.E. &»ing<4* x 27*/ea)
C Sand Fill (15 Mils)
LOM P~i Soil Backfill
Prott ivt casing
Labor
Sub Subtota.
1
2,400
486
5,051
599
510
134
1,008
134
2,400
2
760
60
600
1,200
1,800
1
1
20
74
2
13
2
1
150
400
101
12
IS
1
LS
CY
FT
FT
CY
FT
CY
CY
CY
CY
Eft
LF
LF
LF
LF
LF
LS
LS
FT
LF
EA
CY
CY
LS
LF
LF
CY
CY
EA
LS
•20,000
2.07
66.40
36.95
20.25
161.05
35.00
15.92
16.50
2.48
1265.00
2.00
100
5.83
9.89
1.75
5,000.00
5,000.00
20.00
16.50
250.00
1192
20.00
1,620.00
6.10
4.17
15.92
20.00
150.00
2,000.00
«20,000
4,968
32,403
186,634
12,130
82,136
4,690
16,047
2,211
5,932
2,530
1,520
180
3,498
11,868
3,150
5,000
5,000
400
1,221
500
207
40
1,620
915
1,668
1,608
240
2,250
2,000
387,618
-------
1NARY
-*WDflfiE INDUSTRIAL HASTE SITE
GAINER, OXWHCH1
EPfl 30€DY yiTH EJtCflVflTION OPTION
ITB
UNIT
QUftNTITY CASUAE
WIT
COST
EXTEWED
COST
3. i^-
Sert ion 3 - DETAILED R£!QY DESCRIPTION
3.2 SroundMttr Extract ion I Treitnnt
GroundiMter Trtncnes
SROUMWATER COLLECTION TROCHES - Continued
WSCEUA-COUS ITEMS
Reserve Pi«ps, cables,
Discharge hows - 1 LS
Gtmrators 5 Efl
Suft SuMotai
SufltotaJ
3.2.2 Brountetv- TrtatMit
6MUOMTER TREATKNT
Effluwit Pent
Excavation
Bacfcfill
Spillway
Utir 3* high
fecyclt Lint
V HDPEPip*
Equipon*
Tanks - lS,000|tJ
Nimn - 1 Hp
P«p» - Oiaphrag* l/2hp
Oil/Watir Siparators
Oil Pivp
Solids PIMP
Paduat TrMtHnt Systa
LIM Fttd Systaa
Stttlfr - Sacond
Filter
Effluntt Pum
Effluent Tank
Acid Uttering Systoi
SackMsO Puae
Badniasft Storage Tank
Decant Pu»p
Sludge Puw - BW
Stripper Puip
5,000 25,000
2fl,oao
13,453,294
5,000 CY
5,000 CY
1 LS
1 LS
1,000 LF
t3
5
10,000
5,000
15
115,000
25,000
10,000
5,000
15,000
1
4
2
2
2
2
EflCH
EACH
EACH
EACH
EACH
EACH
130,000
12,000
600
10,000
1,200
7, WO
130,000
46,000
1,200
20,000
2,400
15,600
2
3
6
3
2
2
2
2
2
1
1
2
2
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
EACH
83,000
4,630
20,000
1,200
28,000
600
25,000
4,630
000
20,000
600
1,200
800
170,000
13,890
120,000
3,600
36,000
1,200
50,000
9,260
1,600
20,000
600
2,400
1,600
-------
IMXjSTRIflL «flSTE SITE
C.9L*€R, OXLfrtitf)
EPA REMEDV KITH EXCflVfiTIQN OPTION
ITEM
UNIT JUT EXTENDED
QUANTITY KASURE COST COST
Stction 3 - DETAILED (BOY DESCRIPTION
3.2 GroundMitir Extraction & Tr»at«nt
3.2.2 SrouHjwater Trcatnnt
SROUMDMflTER TSEATWff - Continued
equipment - Continued
flir Strippers
Air BlOMr
SAC - Mittr
Str. Effl. Pun
Sludgt Storage Tank
Sludgt Hixtr
Fiitw Prtw
Filter Pmc Pwp
Tarti - 0. E.
0. E. Nixir
Filtrttt Tank
Filtratt Pwp
Enrpncy Smritor - 60KV
Stup PMP
Air Comrffwor
Piping to Pond
Enrgwcy SMMT t EyMMh
Opmtiom/Nunt Nmul
Bitch TrtttMnt Eqvipvfit
Labor
Opwator (16 hrs)
Operator (8 hrs)
HMlth ( Saftty EqviDMDt
Clowr*
SUBTOTAL - Know Costs Only
3mral Cant 'ion* 9
Finishn 9
Elictrical 9
IiwtnMRtati jn t Controls
Yard Piping f
SUBTDTflL - Pimntaat Costs (
SUBTOTAL - Known and Ptrtsntap Costs Only
feoihzation I » of SUBTOTAL - Knom
Subtotal
3.2.3 Alluvial SroundMtir Aavdiition
ALLUVIAL SROUMMATER PROGRAM
COST INCLUDED IN Section 3.3.3
2 EACH
2 EAOt
4 EACH
2 EAD4
1 EACH
1 EACH
2 EACH
2 EACH
1 EACH
1 EACH
1 EACH
EACH
EACH
EACH
EACH
LS
Era
EACH
1 EACH
5,336 MS
5,336 HRS
1 LS
1 LS
i*of SUBTOTAL
S of SUBTOTAL
ttof SUBTOTAL
i* of SUBTOTAL
* of SUBTOTAL
50,000
2,000
20,000
800
10,000
12,000
35,000
1,200
3,000
1,200
3,000
600
23,000
1,200
12,500
15,000
1,000
10,000
100,000
31.50
31.50
143,420
10,900
r • 54* of SUBTOTAL
Costs Only
-Knom * *
100,000
4,000
80,000
1,600
10,000
12,000
70,000
2,400
3,000
1,200
3,000
600
25,000
3,600
12,500
15,000
1,000
10,000
100,000
168,064
168,084
143,420
10,900
« 1,582, 738
119,904
47,962
239,809
119,904
287,771
«, 398,088
119,904
2,317,992
Monitoring
-------
INDUSTRIAL
MlAEfl, OKUKMfl
EPA RE!€DY WITH EXCflVRTlON OPTION
ITEM
QUANTITY KASURE
LWIT
COST
EXTENDED
COST
Stction 3 - DETAILS) JBOY DESCRIPTION
3.3 Othw ftmdial Ftatum
3.3.1 RtMdial Support ricihtits
GENERAL
Bonds and Insurant (29 of
Construction Subtotal)
Equipmt Mob/Dnob (0.5*
of Construction Suototal)
CoBNnity Rtlatiom
Labor
Materials
Utility Strviet
Tiltqnont, Mtnr, eltctric
Subtotal
SITE SUPPORT
HMlth/Safity Progra*
Air Monitoring
Projtct Adnnistration
Subtotal
SUPPORT FACILITIES
Construction Offict
Antrooi Trailer
Guard Station
Suart Strvict
EquipMnt Naint. Shop
StoragtShtd
On Sitt Laooratory
iMical Sarvicts Stat m
Hitirolofical Station
DKontannation Stations
Roadways
Subtotal
i IS
1 LS
216
1
1
HRS
LS
LS
1 LS
1 LS
1 LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
1600,000
150,000
45.00
10,000
54,800
209,000
171,100
65,000
«20,000
21,800
10,000
101,430
136,240
9,000
809,300
155,400
6,700
489,100
204,700
«600,000
150,000
9,720
10,000
SB, BOO
209,000
171, 100
65,000
tao,ooo
21,800
10,000
101,430
136,240
9,000
809,300
155,400
6,700
489,100
204,700
*B2B,520
US, 100
1,963,670
-------
:1""1NARY
IfCUSTSIflL «flS7E SITE
C3IJCR, OKLflhCWJ
EPA ROCDY WITH OCflVftTIQN OPTION
UNIT U»IT EXTBOED
ITEM QUHTITY «SURE COST COST
SKtion 3 - DETAILS) SEJQY DESCRIPTION
3.3 Other Rntdia! Featurts
3.3.2 Surface Hater Controls
S70&MOTE3 CONTROL
Detention Pond
Excavation - 4,000 CY 13.00 $12,000
Backfill 4,000 CY 5.00 20,000
SaiJloay i LS 10,000 10,000
Lirwr 142,000 CY 1.00 142,000
Disctiargt Lin*
4* WPf Lin* 800 Lf 15.00 12,000
Subtotal *!%,000
3.13 RmdiaJ
«NITOflIf€ PWGMN
Homtonng Mill Installation 6 ER 13,000 *1A,000
Monitoring fintmim 31 ED 750 23,250
Subtotal
3.3.4 Institutional Controls
iNSTiTUTiott. comas
Octd flMtrictions
Lc«al Fm 1 LS 150,000 160,000
Fitlrf Karton 23 EA 250 6,250
Easocnts I Prrmrty Pwcnasn 552,000
Subtotal 608,250
-------
-------
PR!UM!NARY
HAWAflE IHUSTRIAL HASTE SIT!
CftllCR, OKLAHOW
EPA REJOY WITH EXCAVATION OPTION
ITB
UNIT UNIT EJTQCED
QURNTITY KftSUJE COST COST
Section 3 - DETAILED «BCDV DESCRIPTION
CONSTRUCTION SUBTOTAL
CONTINGENCIES
Bid Contingency
Scope Contingmy
Subtotal
TOTAL
128,306.838
INPUNTATION COSTS
Engiiwring Onign
Pwmtting and Lqal
Sirvicn Ouriiq Cowtnction
Subtotal
1»
20X
1W
7t
10*
TOTAL CAPITAL COST Bastd on Octotar 19M Dollar*
Engineering **• AKord Contraction Coct Indn
Dallas Smtntar 1989 318S
Dallas October 1988 3185
Multiplier to change bast to Septe^er
TOTAL CAPITAL COST Baud on September 1989 Dollars
4,246,026
5,661,368
9,907,393
«3B,ai4,23i
3,821,4£3
2,674,9%
3,821,423
10,317,842
«4«,532,073
1989 • 1.0013
146,595,165
OPERATIONS t HAINTENAJCE COSTS
Present Uortft of $661,900 Annual OM Costs assailing
5* Interest Rate ovtr 30 years and 1639,700
Annual OM Costs assuring 5* over B years
TOTAL CAPITAL COST Including Operations I Haintenanct
14,309,500
162,904,665
------- |