United States Office of
Environmental Protection Emergency and
Agency Remedial Response
PB93-964205
EPA/ROD/R06-92/069
June 1992
SEPA Superfund
Record of Decision:
V
%
Oklahoma Refining, OK
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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f
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-92/069
3. Recipients Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Oklahoma Refining, OK
First Remedial Action - Final
5. Report Date
06/09/92
7. Authors)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Protect/Taskwork Unit No.
11. Contract(C)orGrant(G)No.
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
PB93-964205
16. Abstract (Limit 200 words)
The 160-acre Oklahoma Refining site is a petroleum refinery located on the eastern edge
of Cyril, Oklahoma, in Caddo County. Land use in the area is predominantly rural, with
the township of Cyril bordering the western edge of the site and creek systems
bordering the eastern and southern edges. The facility included refinery process
areas, bulk storage tanks, waste pits, wastewater treatment ponds, and a land treatment
area. From the 1920's until 1984, the Oklahoma Refining facility produced refining
products onsite, which included gasoline, naphtha, asphalt, and nonchlorinated
solvents. Wastes generated from these processes were generally disposed of in unlined
product and waste storage pits or were applied to land. Refinery wastewaters were
directed into an oil and water separator, treated in a series of surface impoundments,
and discharged into an adjacent creek. In 1984, the Oklahoma Refining Company (ORC)
removed 5,000 barrels of light non-aqueous phase liquid (LNAPL) from the ground water
table. During the mid-1980's, EPA investigations revealed large-scale organic and
heavy metal contamination of onsite soil and ground water. In 1990, EPA conducted a
removal action, which included characterization and removal of drums, plugging wells,
and wildlife protection measures. This ROD addresses the remediation of onsite
(See Attached Page)
OK
17. Document Analysis a. Descriptors
Record of Decision - Oklahoma Refining,
First Remedial Action - Final
Contaminated Media: Soil, sediment, gw, sw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, phenols),
metals (arsenic, chromium, lead)
b. MenWers/Open-Ended Terms
c. COSATI FiekVGroup
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
182
22. Price
(See ANS(-ZJ9.18)
See Inttructtons on Reverts
OPTIONAL FORM 272 (4-77)
(Formerly NTtS-35)
Department of Commerce
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•
f
EPA/ROD/R06-92/069
Oklahoma Refining, OK
First Remedial Action - Final
Abstract (Continued)
contaminated soil, sediment, surface water, and ground water as a final remedy. The
primary contaminants of concern affecting the soil, sediment, ground water, and surface
water are VOCs, including benzene, toluene, and xylenes; other organics, including PAHs
and phenols; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes in-situ bioremediation of organic
contaminated sediments; in-situ stabilization of inorganic contaminated sediment,
followed by capping; removal and treatment of all surface water collected from surface
impoundments; excavation and containment of contaminated soil and sediments that exceed
health-based levels; excavation and neutralization of low pH sediments, followed by
placement of treated materials as fill in area of origin; and excavating and recycling of
asphaltic materials. Sediment and soil that cannot be treated in-situ will be treated
using prepared-bed bioremediation, followed by stabilization, if needed, and containment.
The remedy includes removal of light non-aqueous phase liquids (LNAPL) using extraction
wells; containing contaminated ground water using interceptor wells; and treatment of the
collected ground water and surface water in an onsite treatment facility, followed by
injection of all treated water into the contaminated portion of the aquifer to enhance
in-situ bioremediation,- recycling the recovered hydrocarbons. The estimated present
worth cost for this remedial action is $31,712,000, which includes an annual O&M cost of
$425,000 over 30 years.
PERFORMANCE STANDARDS OR GOALS: The chemical-specific standards are based on Remedial
Action Objectives (RAOs) for each affected medium. For soil, subsoil, and sediment, RAOs
are health-based depending on whether exposure would result from leaching (ground water
protection) or ingestion. Chemical-specific standards include benzene 22 or 0.20 mg/kg,
toluene 54,000 or 104 mg/kg, xylenes 540,000 or 2,828 mg/kg, PAHs ranging from 0.33 to
81,000 mg/kg (depending on the species of PAH detected), arsenic 25 or 305 mg/kg,
chromium 1,350 or 770 mg/kg, and lead 600 or 865 mg/kg. RAOs for subsoil are based on
ground water protection standards and include benzene 0.20 mg/kg, arsenic 305 mg/kg,
chromium 770 mg/kg, and lead 865 mg/kg. Ground water and surface water RAOs are based on
SDWA MCLs, whenever applicable, but are health-based in xylenes 10 mg/kg, PAHs (for both
naphthalene and 2-methylnaphthalene) 0.15 mg/kg, arsenic 0.05 mg/1, chromium 0.10 mg/1,
and lead 0.015 mg/1.
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REGION VI
JUNE 1992
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DECLARATION
OKLAHOMA REFINING COMPANY
RECORD OF DECISION
JUNE 1992
Statutory Preference for Treatment as a
Principal Element is Met
and Five-Year Site Review is Required
SITE NAME AND LOCATION
Oklahoma Refining Company
Cyril, Oklahoma
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Oklahoma Refining
Company Superfund site, in Cyril, Oklahoma, chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Contingency Plan (NCP). This decision is based on the administrative
record for this site. The State of Oklahoma concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response actions selected in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment
DESCRIPTION OF THE SELECTED REMEDY
The prr ,>al risks at the site are from contaminated soil and sediment, surface water, and ground
water. The selected sediment and soil remedy will address contaminated soil, sediment and
surface water and will consist of the following major components:
- In-situ bioremediation of organic contaminated sediments;
- In-situ stabilization of inorganic contaminated sediments, followed by capping;
- Removal of all on-site surface water from impoundments;
- Treatment of all contaminated surface water taken from surface impoundments in an on-
site water treatment facility;
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- Prepared bed biotreatment of contaminated sediments and soils that cannot be treated
in-situ, followed by stabilization, if necessary, and containment of treated residuals;
- Excavation and containment of contaminated sediments and soils that exceed health-
based levels;
- Excavation and neutralization of low pH sediments, followed by placement of treated
materials as fill in area of origin;
- Excavation and recycling of asphaltic materials.
The selected remedy for treatment of contaminated ground water will consist of the following
components: '
- Removal and recycling of the light non-aqueous phase liquid (LNAPL), primarily
petroleum, floating on the ground water that has commingled with hazardous waste;
- Containment of contaminated ground water by using interceptor wells to prevent
migration;
- Treatment of all collected water in an on-site water treatment facility. Treated water will
be injected into contaminated portions of the aquifer to enhance in-situ bioremediation
treatment of the contaminated ground water.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are legally appb'cable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element.
Because uus remedy will result in hazardous substances remaining on-site 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
enVironr
B. y. Wynne Date
Regional Administrator
U.S. Environmental Protection Agency
Region 6
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TABLE OF CONTENTS
I. SITE NAME, LOCATION AND DESCRIPTION 1
n. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HI. HIGHLIGHTS OF COMMUNITY PARTICIPATION . 5
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY 6
Contaminated Soils and Sediments 6
Contaminated Ground Water 6
Contaminated Surface Water 6
V. SUMMARY OF SITE CHARACTERISTICS 6
Geology and Hydrogeology Characterization 7
Environmental Characterization 8
Contamination Characterization 8
Ground Water 8
On-site Soils and Sediments 12
On-site Surface Water 12
Gladys Creek and Its Tributaries 12
Contaminant Fate and Transport Characterization 12
Remedial Action Objectives and Principal Threat Wastes 13
VI. SUMMARY OF SITE RISKS 18
Human Health Risks 18
Identification of Chemicals of Concern 24
Exposure Assessment 24
Toxicity Assessment 27
Risk Characterization 29
Risk Summary by Receptor 29
Uncertainties Associated with the Human Health Risk Calculations 38
Ecological Risks 39
VII. DESCRIPTION OF ALTERNATIVES 40
Sediment and Surface Soil Remedial Action Alternatives 41
Common Elements 41
Alternative I: No Action 43
Alternative II: Limited Action 43
Alternative HJ: Containment, Neutralization and Biotreatment 44
Alternative IV: In-situ Stabilization, Neutralization and Biotreatment ... 44
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Alternative V: In-situ Stabilization, Recycling, Neutralization and
Biotreatment 45
Alternative VI: In-situ Stabilization, Recycling, Neutralization and LTTD
Treatment 46
Ground Water Remedial Action Alternatives 47
Common Elements 49
Ground Water Alternative I: No Action 52
Ground Water Alternative II: Limited Action 52
Ground Water Alternative III: Containment, Entire LNAPL Plume
Removal and In-situ Bioremediation Enhancement of RSS
Aquifer 52
Ground Water Alternative IV: Containment, Recovery of LNAPL
Commingled with Hazardous Waste and In-situ Bioremediation
Enhancement of the RSS Aquifer 53
Ground Water Alternative V: Active Restoration of the RSS Aquifer ... 53
Ground Water Alternative VI: Active Restoration of the RSS Aquifer
Commingled with Hazardous Waste 54
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 54
Nine Criteria 55
Threshold Criteria 55
Primary Balancing Criteria 55
Modifying Criteria 55
Comparative Analysis of Sediment and Surface Soil Alternatives 56
Threshold Criteria 56
Overall Protection of Human Health and the Environment 56
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) 57
Primary Balancing Criteria 57
Long-term Effectiveness and Permanence 57
Reduction of Toxicity, Mobility, or Volume Through Treatment . . 58
Short-term Effectiveness 58
Implementability 59
Cost 60
Modifying Criteria 60
State Agency Acceptance 60
Community Acceptance 60
Selection of Sediment and Soil Remedy Based on Comparative Analysis . 60
Comparative Analysis,of Ground Water Alternatives 61
Threshold Criteria 61
Overall Protection of Human Health and the Environment 61
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) 62
Primary Balancing Criteria 62
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Long-term Effectiveness and Permanence 62
Reduction of Toxicity, Mobility, or Volume of the Contaminants
Through Treatment 63
Short-term Effectiveness 63
Implementability 64
Cost 64
State Acceptance 64
Community Acceptance 65
Selection of Ground Water Remedy Based on Comparative Analysis .... 65
IX. THE SELECTED REMEDY 66
Sediments and Surface Soils 66
Remediation Goals 66
Performance Standards for the Selected Sediment and Surface Soil
Remedy 67
Ground Water 71
Remediation Goals 71
Performance Standards for the Selected Ground Water Remedy 72
X. THE STATUTORY DETERMINATIONS 75
Protection of Human Health and the Environment 75
Compliance with ARARs 75
Cost-Effectiveness 77
Utilization of Permanent Solutions and Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable 78
Preference for Treatment as a Principal Element 78
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 78
XII. THE RESPONSIVENESS SUMMARY 79
XIII. GLOSSARY 87
APPEN : A: DEVELOPMENT OF RISK-BASED REMEDIAL ACTION OBJECTIVES
(RAOs) 91
APPENDIX B: EXPOSURE ASSESSMENT VARIABLES AND ASSUMPTIONS . . 103
APPENDIX C: RECEPTOR INTAKES AND CALCULATION OF CARCINOGENIC RISKS
AND NON-CARCINOGENIC HAZARD INDICES 118
APPENDIX D: OKLAHOMA STATE DEPARTMENT OF HEALTH CONCURRENCE
LETTER 171
in
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APPENDIX E: OKLAHOMA REFINING COMPANY ADMINISTRATIVE RECORD
INDEX 173
IV
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,*
LIST OF TABLES
Tables
1 Remedial Action Objectives for Ground Water and Surface Water 14
2 Remedial Action Objectives for Sediments and Surface Soils 15
3 Remedial Action Objectives for Subsurface Soils 17
4 Principal Threat Wastes at the ORC Superfund Site 19
5 Chemicals of Concern and Associated Media at the ORC Superfund Site 25
6 Quantitative Pathways of Concern at ORC Site 28
7A Toxicity Values: Potential Non-Carcinogenic Effects 30
7B Toxicity Values: Potential Carcinogenic Effects 34
8 Carcinogenic Risk Summary by Media 36
9 Non-carcinogenic Hazard Indices Summary by Media 37
10 Remedial Action Alternatives for Sediments and Surface Soils 42
11 Remedial Action Alternatives for Ground Water 48
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LIST OF FIGURES
Figures Page
1 Site Map 2
2 Location of LNAPL Detected in Rush Springs Sandstone 9
3 Benzene Concentrations in Upper Rush Springs Sandstone Aquifer 10
4 Arsenic and Lead Concentrations in Upper Rush Springs Sandstone 11
5 Areas with Principal Threat Wastes in Sediments and Soils 23
6 Area of Ground Water and LNAPL Remediation for Alternatives
IV and VI 50
7 Area of Ground Water and LNAPL Remediation for
Alternatives III and V 51
8 Location of Containment Well System for Selected
Ground Water Remedy 74
VI
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THE DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
The Oklahoma Refining Company (ORC) Superfund Site is located in Caddo County on the
eastern edge of Cyril, Oklahoma, at the intersection of U.S. Highway 277 and State Highway 8.
The site is bordered by Gladys Creek to the east, U.S. Highway 277 to the north, the City of
Cyril to the west, and a tributary of Gladys Creek to the south. The site location and boundaries
are shown in Figure 1.
The ORC site covers approximately 160 acres. The site encompasses an area that has been used
for petroleum refining purposes for about sixty years. Approximately one-half of the site consists
of a refinery area and a tank farm area. The other half consists of grasslands and approximately
40 randomly sized pits and wastewater ponds which contain varying amounts of sediment
The topography of the ORC site is basically flat, with a gentle slope to the east and south. At
the eastern and southern borders of the site, a deeply incised creek system forms a steep
embankment. The highest elevation, at the northwest comer, is approximately El. 1380 feet
above mean sea level (msl). The lowest elevation found at the site, at the bottom of Gladys
Creek in the southeast corner, is approximately El. 1290 feet above msl. The elevation of the
ORC site places it above the 100-year floodplain.
The City of Cyril, which has a population of 1,072 (1990 Census), borders the western boundary
of the ORC site. Some residences near the site obtain drinking water from a shallow aquifer, the
Rush Springs Sandstone. The area outside of Cyril is rural and consists of many small farms and
ranches. Typical land uses include wheat farming and cattle grazing. Gladys Creek is primarily
used for fishing, wading, and cattle watering in the Cyril area. Gladys Creek flows into the Little
Washita River approximately two miles south of the ORC site.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Relevant site history dates back to 1920, when the Anderson-Pritchard Oil Corporation (APCO)
was for d and began producing a variety of petroleum products which included gasoline,
naphtha, asphalt, and non-chlorinated solvents.
The facility was purchased in 1978 by the Oklahoma Refining Company. The refinery continued
to produce petroleum products from crude oil. Importation of a maximum of 15,000 barrels of
crude oil per day for processing was reached in 1983. The facility included refinery processing
areas, bulk storage tanks, unlined product and waste storage pits, wastewater treatment ponds,
and a land treatment area.
During the period of active refining operations at the site by APCO and ORC (approximately
1920 to 1984), various refining processes were utilized and included: crude distillation, vacuum
distillation, fluid catalyst cracking, alkylation, bi-metallic reforming and downstream processing.
1
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The waste generated from these processes was generally disposed in pits or land applied. The
wastewaters generated at the refinery were sent through an American Petroleum Institute (API)
separator to recover free floating hydrocarbons and then treated in a series of surface
impoundments. Effluent from the surface impoundments was discharged into Gladys Creek
bordering the eastern edge of the site and its unnamed tributary which forms the southern
boundary of the site. Disposal of hazardous substances occurred at the site before and after
enactment of the Resource Conservation and Recovery Act (RCRA) in 1976.
In 1974, the EPA issued a National Pollutant Discharge Elimination System permit to allow for
the discharge of wastewater from the ORC facility. The Oklahoma Controlled Industrial Waste
Act (OCIDWA) and RCRA, both passed in 1976, brought hazardous wastes under the regulatory
authority of the Oklahoma State Department of Health (OSDH) and the U.S. Environmental
Protection Agency (EPA), respectively. In 1977, ORC began the process -of applying for a
OCIDWA waste disposal site operating permit with OSDH.
In 1983, the Oklahoma Water Resources Board (OWRB), the state agency responsible for
permitting industrial wastewater discharges, issued a letter requiring ORC to correct various
wastewater discharge violations. In 1984, the OSDH issued an order to ORC for corrective
action of RCRA violations which included inadequate closure plans, failure to sample soil in the
land treatment area, and failure to adequately sample ground water in the land treatment area.
In 1984, ORC conducted an investigation of contamination problems on the site and removed
approximately 5,000 barrels of light non-aqueous phase liquid (LNAPL), which consisted of
petroleum product, from the ground water table.
The owners of ORC declared bankruptcy in September 1984 and ceased operations at that time.
In 1986, the Bankruptcy Court allowed ORC to abandon the southern portion of the property
which included the majority of surface wastes and the ground water discharges into Gladys
Creek. Also, in 1986, the EPA investigated the ORC site for possible inclusion on the National
Priorities List (NPL). Their investigation showed hydrocarbons and elevated levels of heavy
metals in the ground water and soils at the site. Based on this investigation and data obtained
from the 1984 ORC investigation, the ORC site was placed on the NPL in June 1988.
In 1987 e Cyril Petrochemical Corporation (CPC) purchased the northern portion of the former
ORC property that was not abandoned, which included the refinery process area, with the
intention of reactivating part of the refinery. In 1991, Cayman Resources purchased CPC with
the expressed intention of reopening the refinery in the spring of 1992 to refine crude oil into
various products.
A number of investigations have been conducted at the ORC site. Most of these investigations
have focused on the characterization of contamination in Gladys Creek and on-site soil, sediments
and ground water.
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Investigations prior to Superfund involvement include the following:
- RCRA part A application, May 28, 1981.
- Soils Report for the Oklahoma Refining Corporation, report by Nova Engineering
Testing Co., Inc., August 28, 1981.
- U.S. EPA, Potential Hazardous Waste Site, Inspection Report, EPA Form T72070-3,
April 1982.
- Oklahoma Water Resources Board, Water Quality Division, Inspection Report, J.J.
Black, August 1985.
- Stanley Engineering, Environmental Investigation, Oklahoma Refining Company, Cyril,
Oklahoma, August 1985.
- -Ecology -and Environment, Inc., Memorandum, Sampling Inspection of ORC Refinery
in Cyril, Oklahoma, TDD-R06-8510-27, May 1986.
- RCRA Facility Assessment Preliminary Review Report, Oklahoma Refining Company,
EPA I.D. OKD091598870, EPA Contract No. 6801-7251, Project No. W68439, June 5,
1987.
Investigations conducted after the site was placed on the NPL include the following:
- Oklahoma State Department of Health, Remedial Investigation Report, September 1991.
- Oklahoma State Department of Health, Feasibility Study Report, December, 1991.
A search for potentially responsible parties (PRPs) was conducted by Jacobs Engineering, Inc.
in 1987. CPC was identified as a PRP. On December 22, 1988, EPA sent CPC a special notice
letter which notified CPC of their potential liability and offered CPC the opportunity to undertake
the Rerr " al Investigation and Feasibility Study (RI/FS).
CPC responded to the EPA special notice in a letter dated March 7, 1989, disclaiming
responsibility for the abandoned portion of the Superfund site and stating that there was no data
or evidence indicating potential releases of hazardous substances, pollutants or contaminants on
CPC's property. Since CPC declined to conduct or finance the RI/FS, the company was notified
by letter dated March 8, 1989, that EPA would proceed with the RI/FS using CERCLA funds.
In 1991, Cayman Resources Corporation (Cayman) acquired 100 percent of CPC's stock. This
asset purchase rendered CPC a wholly owned subsidiary of Cayman. Potentially responsible
parties will be offered the opportunity to conduct or finance the Remedial Design and Remedial
Action.
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An action memorandum, pursuant to Section 104 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), authorizing an EPA removal action at the site was
signed on August 30, 1990. The scope of the removal action consisted of fencing the site,
characterization of the contents and removal of drums, plugging wells in the acid pit area, and
placing netting over several impoundments to protect wildlife. A unilateral administrative order
was issued to CPC on January 25, 1991, ordering the company to perform the fencing on its
portion of the property and the drum characterization. CPC responded to the order to undertake
the actions requested; however, the workplan submitted by CPC to perform the work was not
adequate for the drum characterization. CPC was allowed to proceed with the fencing of its
-property and EPA performed the drum characterization, the well plugging and impoundment
netting. The removal action on CPC's property and the abandoned property was completed in
August 1991.
IH. HIGHLIGHTS OF COMMUNITY PARTICIPATION
This decision document presents the selected remedial action for the ORC Superfund Site, in
Cyril, Oklahoma, chosen in accordance with CERCLA, as amended by the Superfund
Amendments and Reauthorization Act and, to the extent practicable, the National Contingency
Plan (NCP). The decision for this site is based on the administrative record.
The public participation requirements of CERCLA, sections 113(k)(2)(B)(i-v) and 117, were met
during the remedy selection process. The Remedial Investigation report, released in September
1991, the Feasibility Study report, released in December 1991, and the Proposed Plan, released
in February 1992, were all made available to the public in both the administrative record and
information repositories maintained at the Cyril City Hall, the OSDH Central Office in Oklahoma
City, Oklahoma, and the EPA Region 6 Office in Dallas, Texas. The notice of availability for
these documents was published in the newspaper of record, The Cyril News, on January 30,
1992, and also in The Lawton Constitution on February 2, 1992.
The OSDH and EPA held an open house in Cyril on February 6,1990, to explain the Superfund
process and to notify the public that RI activities were going to begin. The RI fieldwork was
discussed and information about the site was solicited.
On h ember 12, 1991, the OSDH and EPA held an open house in Cyril to inform the public
of the findings of the RI Report which included the results of the Baseline Risk Assessment.
Representatives of the Agency for Toxic Substances and Disease Registry also attended this
meeting and solicited public response to the site.
On February 6, 1992, the OSDH and EPA held an open house in Cyril to inform the public about
the Feasibility Study Report and the Proposed Plan of Action. A 30-day public comment period
was held from February 10, 1992 through March 11, 1992.
A public meeting was held in Cyril on February 20, 1992. At this meeting, representatives from
the OSDH and EPA presented information on the Remedial Investigation, Risk Assessment and
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Feasibility Study and answered questions about the site, the remedial alternatives under
consideration, and the Proposed Plan of Action. A response to the comments received during
this period is included in the Responsiveness Summary, which is part of this Record of Decision
(ROD).
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
This ROD addresses the risks posed by conditions at the site. Some or all of the contaminants
identified at the site are "hazardous substances" as that term is defined in section 101(14) of
CERCLA, 42 U.S.C. §9601(14), and 40 CFR §302.4. Response actions authorized by this ROD
for hazardous substances in contaminated media will address the following risks.
Contaminated Soils and Sediments
The risk to human health and the environment from contaminated soils and sediments found in
on-site pits and ponds stems from possible ingestion or dermal contact. There is an additional
threat that contaminants will migrate from these soils and sediments into the underlying ground
water which is a potential source of drinking water. The sediments in Gladys Creek were not
found to contain levels of contamination that would cause and unacceptable health risk and are
not considered a risk.
Contaminated Ground Water
The risk to human health from contaminated ground water stems from possible ingestion. The
contaminated portion of the Rush Springs Sandstone aquifer is not currently used as a drinking
water source but is classified as a potential source. The LNAPL which is floating on the ground
water presents a potential risk of explosion, fire and air pollution to future potential on-site
residents and contributes to the ground water pollution at the site. A risk to the environment
exists from contaminated ground water and LNAPL that discharges into Gladys Creek and its
tributaries and has a detrimental effect on the creeks' ecology.
Contaminated Surface Water
The risK to human health and the environment from contaminated surface water, found in on-site
ponds and drainageways, stems from possible ingestion or dermal contact. The surface water in
Gladys Creek was not found to contain levels of contamination that would cause an unacceptable
health risk and is not considered a risk.
V. SUMMARY OF SITE CHARACTERISTICS
This ROD will address contaminated sediment, soil, surface water, and ground water at the ORC
site.
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Geology and Hydrogeology Characterization
The ORC site is underlain by Quaternary and Permian Age deposits. Quaternary Age deposits,
composed of clay, silt and sand, have been deposited on top of the bedrock in many areas of the
site. These Quaternary Age deposits include thin layers of clay spread across much of the site
and thick layers of clay, silt, and sand deposited in channel fills. The Quaternary Age deposits
are not used as a water source in the Cyril area and are not aquifers of concern.
The uppermost Permian Age strata found at the ORC site is the Weatherford Member of the
Cloud Chief Formation. It is primarily composed of gypsum and underlies thin Quaternary Age
clay deposits in the northwest portion but outcrops or is absent in other areas of the site. The
thickness and elevation of the top of the formation varies because it is an erosional surface. The
greatest measured thickness of the Weatherford at the ORC site was 31.5 feet Ground water was
found to be present in the top few feet of the formation in the northwest portion of the site. The
Weatherford member acts as an aquitard in this area and as a partial barrier to infiltration from
rainfall. However, the Weatherford Member is not used as a water source in the area and is not
identified as an aquifer of concern.
The Rush Springs Sandstone (RSS) Formation conformably underlies the Weatherford Member.
The RSS Formation is approximately 250 feet thick in the Cyril area and consists of even-bedded
to highly cross-bedded, reddish-brown, very fine grained, silty sandstone. The RSS Formation
underlies the entire Cyril area and outcrops on the eastern side of the site. The RSS Formation
contains ground water and is best characterized as an unconfined, water table aquifer.
The RSS Formation aquifer is the currently affected aquifer of concern that is addressed in this
ROD. Recharge of the aquifer in the Cyril area occurs in the topographical high areas, located
west and north of the ORC site, and discharge areas occur where Gladys Creek and its tributaries
intercept the water table, along the eastern and southern borders of the site. The general
horizontal direction of ground water movement across the ORC site is to the southeast, at a
velocity of approximately 11 feet per year. Vertical flow potentials for ground water in the RSS
Formation indicated that upward flow is occurring in the area of Gladys Creek and its tributaries.
Ground water flow direction is primarily horizontal over the rest of the site. Ground water from
the RSS r 'rmation is moving into Gladys Creek and its tributaries above the stream level by
visible .-.^ps and below the stream level by discharge through the alluvial fill materials.
In accordance with the EPA Ground Water Protection Strategy, the RSS Formation aquifer is
classified as a IIA aquifer, a current source of drinking water, in the Cyril area. However, there
is no one currently using the portion of the RSS Formation aquifer that is contaminated or that
could become contaminated from the ORC site. The City of Cyril obtains its drinking water
from a Rural Water District which obtains its water from ground water wells located
approximately 20 miles northwest of Cyril.
The Marlow Formation conformably underlies the RSS Formation. This formation consists
mostly of even-bedded, brick-red sandy shale and fine grained sandstone. It is estimated to be
-------
100 feet thick in the Cyril area. Below the Marlow Formation, in descending order, lie the Dog
Creek Shale Formation, the Elaine Formation, and the Flowerpot Shale Formation. These are
all primarily red shale with some interbedded gypsum, dolomite, siltstone, and sandstone beds.
The combined thickness of these formations is approximately 500 feet The Marlow, Dog Creek
Shale, Elaine, and Flowerpot Shale Formations are not considered as aquifers and act as aquitards
to ground water flow in the Cyril area.
Environmental Characterization
Gladys Creek forms the eastern border of the site and is a gently flowing, small stream that flows
throughout the year. The dimensions of the stream flow in Gladys Creek in the site area average
five feet wide and one foot deep. The 1988 Oklahoma Water Quality Standards (OWQS) have
designated the segment of Gladys Creek adjacent to and downgradient of the site as a habitat
limited fishery and for secondary body contact recreation. The tributary to Gladys Creek, which
forms most of the southern border of the site, also flows continuously throughout the year and
is approximately one half the size of Gladys Creek. This tributary is assumed to be capable of
supporting the beneficial uses of habitat limited fishery and secondary body contact recreation
according to the 1988 OWQS. Gladys Creek and its tributaries provide habitat for many forms
of aquatic wildlife, including fish, turtles and frogs.
The abandoned portion of the site is overgrown with weeds and grasses and provides habitat for
many forms of terrestrial wildlife such as hawks, owls, coyotes, rabbits, cotton rats, and snakes.
The surface impoundments located on the ORC site contain water most of the year. Wildlife
such as water fowl, frogs, and turtles have been observed in these impoundments.
No threatened or endangered wildlife species have been identified at the ORC site and the ORC
site does not contain any federally designated wetlands.
Contamination Characterization
Ground Water
Ground water sampling showed that the upper RSS aquifer is contaminated by LNAPL and
dissolved inorganic and organic compounds. The LNAPL is present in the RSS aquifer over a
large area of the site. The area of LNAPL in the RSS aquifer is shown on Figure 2.
Contamination of the RSS aquifer was found to exist only in the upper 30 feet of the aquifer.
Organic compounds found in the on-site ground water included benzene, toluene, ethylbenzene,
xylene, naphthalene and 2-methyl naphthalene. The concentration of benzene in the upper RSS
aquifer is shown on Figure 3. Dissolved inorganic compounds found in the on-site ground water
included lead, arsenic, and chromium in concentrations exceeding Maximum Contaminant Levels
(MCLs) across a large portion of the site. The concentrations of arsenic and lead in the upper
RSS aquifer are shown on Figure 4.
8
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On-site Soils and Sediments
The ORC site has large areas of surface soil contamination that exceed background levels. Most
of this contamination is from inorganic chemicals such as arsenic, beryllium, lead, and chromium.
The subsurface soils were also found to be contaminated above background concentrations over
a large portion of the site. This contamination is mostly from organic compounds such as
benzene, ethylbenzene, toluene, xylene, phenols, naphthalene, and 2-methyl naphthalene. The
contamination is especially concentrated in subsoils located in areas of LNAPL which is floating
on the ground water. Most of the sediments in the ponds and pits located on-site were found to
contain contaminant concentration levels above background levels. These contaminants are
mostly petroleum related organic and inorganic chemicals such as polynuclear aromatic
hydrocarbons and heavy metals.
On-site Surface Water
Surface water in on-site surface impoundments did not contain detectable levels of contaminants
except for the two Slop Oil Ponds, which contained levels of arsenic above MCLs, and Sludge
Trap #5, which contained various levels of polynuclear aromatic hydrocarbons and lead.
Gladys Creek and Its Tributaries
Surface water in Gladys Creek and its tributaries was found to be uncontaminated except for low
concentrations of phenolic compounds downstream of the caustic area. The sediments of Gladys
Creek and its tributaries were found to be contaminated by very low levels of organic and
inorganic contaminants. The sediments one-half mile downgradient of the site were found to be
at background concentrations.
Contaminant Fate and Transport Characterization
The transport and fate of contaminants from a source are dependent upon the physical and
chemical properties of the waste constituents and the characteristics of the environmental media.
Potential migration pathways of contaminants at the ORC site include air, surface water,
subsurft soil and ground water.
The migration of organic contaminants by volatilization depends primarily upon the vapor
pressure (volatility) of the specific contaminants. Inorganic and organic contaminants can also
migrate in the air attached to dust particles. Most of the organic contaminant chemicals found
at the ORC site have relatively low volatility. However, some chemicals, such as benzene and
toluene, are readily volatilized and were found in various media across the site. Results of air
sampling activities during the RI indicated very low contaminant concentrations (near detection
limits) of volatile organic and inorganic compounds in the air on the ORC site.
Surface water runoff from contaminated areas is a pathway for contaminant migration from the
ORC site into Gladys Creek and its unnamed tributaries. Most of the surface contaminated areas
12
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at the site do not add significantly to this pathway because they are well diked and termed;
however, contaminants are migrating from the acid and caustic pit areas via surface runoff into
Gladys Creek. LNAPL is seeping into the sludge trap ponds and is migrating through the pond
system and discharging into Gladys Geek.
Subsurface soil is a pathway for the migration of contaminants from contamination sources to
the ground water. Subsurface soils trap contaminants and act as sources which slowly release
contamination to the ground water. The amount of contamination that is trapped in the soils
depends on the concentration and partitioning coefficients for each contaminant. The partitioning
coefficient is an indicator of the sorbing potential for each contaminant The organic
contaminants found at the ORC site are both strongly sorbing and weakly sorbing chemicals. As
uncontaminated infiltration waters pass through the contaminated soils, the contaminants will
desorb and dissolve into the infiltration waters. The desorption process is a very slow process
because infiltration waters move very slowly through clay soils and large volumes of water are
necessary to remove strongly sorbing chemicals.
Ground water is a pathway of contamination because ground water discharges from the ORC site
into Gladys Creek and moves off-site toward the Washita River and potential receptors.
Migration of the contamination plume in the RSS aquifer is in the direction of ground water flow,
which is toward Gladys Creek and its tributaries. The contaminated ground water is then
discharged into the surface water in Gladys Creek and its tributaries. Migration of the
contaminated plume in the RSS aquifer beyond Gladys Creek and its tributaries does not occur.
The LNAPL which is floating on the ground water is also moving with the ground water toward
Gladys Creek.
Remedial Action Objectives and Principal Threat Wastes
A Remedial Action Objective (RAO) is a chemical-specific concentration for each chemical of
concern that dictates whether a contaminated media may be left in place or must be addressed
by in-situ treatment or excavated. Those wastes that exceeded RAOs will be addressed to meet
requirements set forth in the performance standards for each media. RAOs were developed for
sediments and surface soils, subsurface soils, surface water, and ground water assuming that the
site coulr1 be used as a residential setting (the reasonable maximum scenario). RAOs were
develop- * for 35 chemicals of concern found at the ORC site. The RAOs developed for
contaminants at the ORC site for each media are listed in Tables 1 through 3. The method for
RAO determination is outlined below and explained in detail in Appendix A.
Ground water RAOs are set at levels which would allow use of the water as a primary drinking
water source. The RAOs are set at MCLs where available. When MCLs were not available
(e.g.. naphthalene), human health-based risk values were used. The health-based risk values were
calculated so that the use of ground water as a drinking water source would not pose a cancer
risk greater than one in one million. The ground water RAO levels will also be used as the
treatment level.
13
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TABLE 1
REMEDIAL ACTION OBJECTIVES FOR GROUNDWATER
AND SURFACE WATER AT THE ORC SUPERFUND SITE
Chemical of Concern
1. Arsenic
2. Barium
3. Beryllium
4. Cadmium
5. Chromium
6. Copper
7. Lead
8. Nickel
9. Zinc
10. Benzene
11. 1,2-Dichloroethane
12. Ethylbenzene
13. Toluene
14. Xylenes
15. Naphthalene
16. 2-Methylnaphthalene
17. Phenol
18. 2-M«thylphenol
19. 4-Methylphenol
20. 2,4-Dimethylphenol
RAOs"*, mg/l
0.05
1.00
0.001
0.005
0.10
1.00
0.015
0.10
5.00
0.005
0.005
0.70
1.00
10.00
0.15
0.15
22
1.8
1.8
0.73
Basis
MCL(2)
MCL
MCL(3)
MCL<4)
MCL(4)
MCL'51
Action level(6)
MCL<3)
MCL(5)
MCL
MCL
MCL
MCL
MCL
HBR(7)
HBR(7)
HBRm
HBR(7)
HBR(7!
HBR(7)
(1) Remedial action objectives
(2) Maximum contaminant level
(3) MCL proposed on 07/25/91
(4) Proposed MCL becomes effective 07/31/92
(5) Secondary drinking water standard
(6) June 21, 1990 Memorandum from Henry L. Longest, Office of Emergency and Remedial Response of EPA,
Washington. DC
(7) Health-based risk is based upon Hazard Index = 1.00
14
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TABLE 2
REMEDIAL ACTION OBJECTIVES FOR SEDIMENTS
AND SURFACE SOILS AT THE ORC SUPERFUND SITE
Chemical of Concern
1. Arsenic
2. Barium
3. Beryllium
4. Cadmium
5. Chromium
6. Copper
7. Lead
8. Mercury
9. Nickel
10. Zinc
11. Benzene
12. Ethylbenzene
13. Toluene
14. Xylenes
15. Acenaphthene
16. Anthracene
17. Benzr anthracene
18. Benzo(a)pyrene
19. Benzo(b)fluoranthene
20. Benzo(g,hj)perylene
21. Benzo(k)fluoranthene
22. Chrysene
23. Dibenzo(a,h)anthracene
24. Fluoranthene
25. Fluorene
RAOs(I), mg/kg
25 or 305
13,500
0.50
135
1350 or 770
351,000
600 or 865
81
5,400
54,000
22 or 0.20
27,000 or 191
54,000 or 104
540.000 or 2,828
16,000 or 4,424
81, 000 or 55,752
4.1
0.33
0.69
1,080
13
46
0.33
10,800
10,800 or 8.888
Basis
HBR<2> or Groundwater Protection
HBR<3)
Detection Limit
HBR(3)
HBR(3) or Groundwater Protection
HBR(3)
HBR<4> or Groundwater Protection
HBR<3)
HBR(3)
HBR(3)
HBR(3) or Groundwater Protection
HBR(3) or Groundwater Protection
HBR(3) or Groundwater Protection
HBR(3) or Groundwater Protection
HBR(3) or Groundwater Protection
HBR<3) or Groundwater Protection
HBR(3)
Detection Limit
HBR(3>
HBR(3)
HBR(3)
HBR(3)
Detection Limit
HER'31
HER™ or Groundwater Protection
15
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TABLE 2 (continued)
Chemical of Concern
26. Indeno(123/c,d)pyrene
27. Naphthalene
28. Phenanthrene
29. Pyrene
30. 2,4-Dimethylphenol
31. 2-Methylnaphthalene
32. 2-Methylphenol
33. 4-Methylphenol
34. Phenol
RAOs(I), rag/kg
3.2
79
1,080
8,100
5.400 or 66
1080 or 510
13,500 or 12
13,500 or 14
162,000 or 125
Basis
HBR'3)
Groundwater Protection
HDR<3)
HBR<3)
HBR(J) or Groundwater Protection
HBR(3) or Groundwater Protection
HBR(3> or Groundwater Protection
HBR(3) or Groundwater Protection
HBR(3> or Groundwater Protection
(1) Remedial action objectives
(2) Health based level developed by EPA, Region VI
(3) Health based risk level developed as in Appendix A
(4) The EPA Uptake/Biokdnetic Lead Model was used to calculate the health-based RAO for lead (see Appendix A).
16
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TABLE 3
REMEDIAL ACTION OBJECTIVES FOR SUBSURFACE SOILS
AT THE ORC SUPERFUND SITE
Chemical of Concern
J. Arsenic
2. Chromium
3. Lead
4. Benzene
5. Naphthalene
6. Phenol
7. 2-Methylphenol
8. 4-Methylphenol
9. 2,4-Dimethylphenol
10. 2-Methylnaphthalene
RAOs"1, mg/kg
305
770
865
0.20
79
125
12
14
66
510
Basis
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
Groundwater Protection
(1) Remedial Action Objectives
17
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Surface water at the site will be removed to perform response actions as needed. If necessary,
the surface water will be treated to meet the ground water treatment levels (ground water RAOs)
and injected into the RSS aquifer.
Surface soil and sediment RAOs address the following two different pathways of potential
exposure: 1) ingestion by humans; and 2) ground water contamination through leaching. Health-
based risk values were calculated so that human ingestion of soil or sediments would not pose
a cancer risk greater than one in one million. Contaminant concentrations of soils that could
leach and cause ground water to be contaminated above ground water RAOs were calculated
using an analytical model which is explained in Appendix A. Since a "health-based" RAO and
a "ground water protection" RAO were developed for sediments and surface soils, the lower of
the two numbers was used to determine the type of action necessary to address the contaminated
media.
Subsurface soil RAOs were set by determining the concentrations that could leach and cause
ground water to be contaminated above ground water RAOs.
Wastes identified at the ORC site as principal threat wastes are wastes which exceed RAOs.
Principal threat wastes at the ORC site include contaminated sediments and subsoils in some of
the pits and ponds; contaminated surface soils located in various areas; and LNAPL commingled
with CERCLA hazardous substances floating on the ground water in the RSS aquifer. Table 4
lists the principal threat waste sources, their associated contaminants and volumes, and their
RCRA hazardous waste code. Figure 5 shows the locations of the principal threat wastes which
are soils and sediments. Figure 2, shown previously, shows the location of the LNAPL in the
RSS aquifer.
The concept of "low-level waste" was not utilized at the ORC site because all waste sources
which contain contamination levels above RAOs could potentially pose significant risks to human
health or the environment should exposure occur.
VI. SUMMARY OF SITE RISKS
As part the ORC Remedial Investigation, a quantitative baseline risk assessment was
performed to estimate human health risks from the ORC site. The baseline risk assessment was
performed to estimate the risk to current and future receptors that may come into contact with
site contaminants through direct contact with soils, waste sediments, surface water and ground
water, should no remedial action (i.e., the "no-action" alternative) take place. A qualitative
ecological risk assessment was performed as pan of the baseline risk assessment.
Human Health Risks
The estimation of human health risk attributed to contaminant exposure is calculated using a
series of mathematical formulas, which take into account the toxicity of the contaminants and the
dosage to an individual. Actual chemical concentrations at the ORC site and conservative
18
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TABLE 4
PRINCIPAL THREAT WASTES AT THE ORC SUPERFUND SITE
WASTE
SOURCE OR
LOCATION
API Separator
Asphalt Flow
Area
Asphalt Pit #1
Asphalt Pit #2
Buried
Acid Pit #1
Lime Soda
Storage Pit
North Pond #1
North Pond #7
Oil nmer
Poru #1
Oil Skimmer
Pond #2
Old Storage Pit
#2
Old Storage
Pit #4
Old Storage
Pit #5
CONTAMINANTS THAT
EXCEEDED RAOs(I> IN
SEDIMENTS (maximum
concentration in mg/kg)
Arsenic (26)
Benzene'3' (3.2)
Chromium (895)
Benzene (0.7)
2-Methylphenol (35)
4-Methylphenol (28)
Arsenic (123)
Lead (19390)
Benzo(a)anthracene (14)
Benzo(a)pyrene (16)
Dibenzo(a.h)anthracene(4)
pH<2 standard units
Benzene (1.2)
Naphthalene (110)
Benzene (0.7)
Benzo(a)anthracene (9.8)
Benzo(a)pyrene (1.1)
Beryllium (1.3)
Arsenic (107)
Arsenic (25)
Lead (976)
Benzo(a)anthracene (23)
Benzo(a)pyrene (16)
Chrysene (51)
Benzene (13)
Lead (1875)
Naphthalene (240)
2-Methylnaphthalene (510)
Lea-i (20530)
CONTAMINANTS THAT
EXCEEDED RAOs"' IN
SOILS (maximum
concentration in mg/kg)
No sample collected
None
None
No sample collected
pH<2 standard units
None
None
No sample collected
Benzene (0.2)
Lead (1313)
Benzene (1.8)
Lead (3724)
None
2-Methylphenol (33)
4-Methylphenol (60)
None
TOTAL
VOLUME
(cubic yards)
90
1667
417
15277
13241
41667
500
2312
1793
127
4147
612
19
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TABLE 4 (continued)
WASTE
SOURCE OR
LOCATION
Old Storage
Pit #6
Old Storage
Pit #7
Pitch Pits #1,2
and 3
Process Sewer
Slop Oil Pit #1
Slop Oil Pit #2
Sludge Trap #1
Sludge Trap #2
CONTAMINANTS THAT
EXCEEDED RAOs(1) IN
SEDIMENTS (maximum
concentration in mg/kg)
Benzene (0.5)
Chromium (934)
Lead (2488)
Benzo(a)pyrene (0.9)
Beryllium (1.3)
pH<2 standard units
Benzo(a)anthracene (73)
Benzo(a)pyrene (280)
Benzo(b)fluoranthene (45)
Chrysene (120)
Dibenzo(aji)anthracene (23)
Indeno(123/c,d)pyrene (84)
Pyrene (190)
Arsenic (48)
Benzene (40)
Chromium (1469)
Lead (724)
Arsenic (200)
Benzene (17)
Benzo(a)amhracene (300)
Benzo(a)pyrene (222)
Benzo(b)fluoranthene (120)
Benzo(k)fluoranthene (40)
Chrysene (456)
Chromium (3820)
Dibenzo(aji)anthracene (34)
Indeno(123/c,d)pyrcne (40)
Lead (2348)
2-Methylnaphthalene(2000)
Naphthalene (350)
Phenanthrene (1100)
Arsenic (45)
Benzo(a)pyrcne (39)
Chrysene (136)
Chromium (1712)
Lead (880)
2-Methylnaphthalene (571)
Naphthalene (122)
Benzene (4.1)
Lead (732)
Naphthalene (253)
CONTAMINANTS THAT
EXCEEDED RAOs"' IN
SOILS (maximum
concentration in mg/kg)
Beryllium (13)
ph<2 standard units
None
No sample collected
Benzene (0.5)
Benzo(a)pyrene (0.6)
None
None
Not applicable
TOTAL
VOLUME
(cubic yards)
3014
574
8200
104
1833
3259
917
207
20
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TABLE 4 (continued)
WASTE
SOURCE OR
LOCATION
Sludge Trap #3
Sludge Trap #4
Sludge Trap #5
Sludge Trap #6
Sludge Trap #7
Surface soils in
area NW of
cooling towers
Surface soils in
Railroad loading
area
Surface soils in
area east of
warehouse
Surface soils in
Tar' diked
area
Surface soils in
Tank #2 diked
area
Surface soils in
Tanks #6,7,& 47
diked area
Surface soils in
Tanks #29 &. 68
diked area
CONTAMINANTS THAT
EXCEEDED RAOs(1) IN
SEDIMENTS (maximum
concentration in mg/kg)
Benzene (2.4)
Arsenic (26)
Benzene (2.6)
Chromium (24020)
Benzene (2.2)
Chromium (1410)
Arsenic (30)
Benzene (1.1)
Chromium (1151)
Benzene (2.3)
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
CONTAMINANTS THAT
EXCEEDED RAOs"' IN
SOILS (maximum
concentration in mg/kg)
Not applicable
Benzene (25)
Not applicable
None
None
Beryllium (1.4)
Benzo(a)anthracene (5.3)
Benzo(b)fluoranthene(6.5)
Arsenic (70)
2,4-Dimethylphenol (200)
2-Methylphenol (160)
4-Methylphenol (1800)
Phenol (3200)
Arsenic (28)
Beryllium (1.1)
Arsenic (84)
Lead (716)
Beryllium (1.1)
Arsenic (80)
Beryllium (1.0)
2,4-Dimethylphenol (160)
2-Methylphenol (1700)
4-Methylphenol (5400)
Phenol (4200)
TOTAL
VOLUME
(cubic yards)
667
3791
2578
4978
3667
300
726
177
3244
1301
572
741
21
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TABLE 4 (continued)
WASTE
SOURCE OR
LOCATION
Surface soils in
Tank #30 diked
area
Surface soils in
Tanks #35. 36, &
37 diked area
Surface soils in
Tanks #43 & 44
diked area
Surface soils in
Tank #66 diked
area
Surface soils in
Tanks #79 & 80
diked area
Surface soils in
Tank #127 diked
area
Surface soils in
Tank #177 diked
area
Surface soils in
area ' of
Sludge Trap #4
Surface soils in
area near SBB-22
CONTAMINANTS THAT
EXCEEDED RAOs(1) IN
SEDIMENTS (maximum
concentration in mg/kg)
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
CONTAMINANTS THAT
EXCEEDED RAOs(I) IN
SOILS (maximum
concentration in mg/kg)
Arsenic (236)
Arsenic (33)
Benzo(a)pyrene (3.5)
Beryllium (1.4)
Arsenic (56)
Lead (1028)
Arsenic (49)
Beryllium (1.4)
Beryllium (1.1)
Arsenic (65)
2,4-DimethylphenoI (160)
2-Methylphenol (84)
4-Methylphenol (930)
Phenol (1400)
Arsenic (345)
Beryllium (1.1)
TOTAL
VOLUME
(cubic jards)
2080
915
807
1079
966
1418
67
278
740
(1) Remedial action objectives
(2) The hazardous waste codes were obtained from "ORC Superfund Site - Hazardous Waste Determination,
June 3, 1991"
(3) Contaminant exceeded RAO based upon the estimated value of the concentration
22
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assumptions that weigh in favor of protecting human health were used in the calculations.
To protect human health, the primary concern is the probability that exposure to specific
chemicals may result in cancer. Although it cannot be determined who, in their lifetime, will be
affected by the contaminants at the ORC site, an estimate can be made of the number of excess
cancer cases that may occur in addition to the normal cancer rate. An estimate can also be made
whether there would be a concern for health effects due to non-carcinogenic effects of
contaminants found at the ORC site.
Identification of Chemicals of Concern
The ORC baseline risk assessment began by compiling a list of contaminants from the results of
site sampling. Contaminants evaluated were selected based on their presence in six types of
environmental media sampled at the site (surface water, ground water, sediment, surface soil,
subsurface soil, and air).
Site-specific chemicals of concern (COCs) were identified as contaminants above the minimum
detection limit that had high concentrations and/or high detection frequencies and had toxicity
data available. Based on these criteria, thirty-five (35) COCs associated with the ORC site were
identified. These COCs include ten carcinogens and 25 non-carcinogens. Table 5 lists the
COCs, the media in which they were detected, and the 95th percentile concentration which was
used to calculate the receptor intakes.
Exposure Assessment
The purpose of the exposure assessment was to identify and evaluate the mechanisms by which
people might be exposed to the chemicals of concern at the ORC site. The exposure assessment
included three steps.
The first step was the characterization of the exposure setting. It was determined that the ORC
site is currently fenced and has restricted access. The portion of the ORC site that is owned by
CPC is currently being refurbished with the intent of starting refinery operations. The abandoned
portion < 'he, ORC site is not currently in use. However, the entire site could be used in the
future for residential property since no zoning restrictions exist Therefore, for purposes of the
ORC baseline risk assessment, it was assumed that there could be four potential human exposure
scenarios. These exposure scenarios include:
• Current off-site resident;
• Potential on-site intruder;
• Potential on-site worker (acute and chronic exposures); and the
• Potential on-site resident.
The potential on-site resident exposure scenario was considered as the reasonable maximum
exposure and was used in the calculation of health-based RAOs.
24
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TABLE 5
CHEMICALS OF CONCERN AND ASSOCIATED MEDIA
AT THE ORC SUPERFUND SITE
CHEMICALS OF CONCERN
1. Acenaphthene
2. Anthracene
3. Arsenic
4. Barium
5. Benzene
6. Benzo(a)anthracene
7. Benzo(a)pyrene
8. Benzo(b)fluoranthene
9. Benzo(gji,i)perylene
10. Benzo(k)fluoranthene
11. Beryllium
12. Cadmium
13. Chromium
14. Chrysene
15. Copper
16. Dibenzo(a,h)anthracene
17. 1. ' 'ichloroethane
18. 2,4-Dimethylphenol
19. Ethylbenzene
20. Fluoranthene
21. Fluorene
22. Indeno(123/c,d)pyrene
23. Lead
24. Mercury
MEDIA (95th PERCENTILE IN PPM)
SED(6.7), SBS(0.7)
SED(7.6). SBS(0.5)
SED(20.4), SBS(5.9), SFS(57.0). SW(0.2), GW(0.08)
SED(172), SBS(197), SFS(281), SW(0.2), GW(l.l)
SED(24), SBS(1.3), SFS(0.2), SW(O.l), GW(0.5)
SED(18.6), SFS(2.0)
SED(22.4)
SED(7.3), SFS(2.0)
SED(24)
SEDK4.4)
SED(l.l), SBS(0.7), SFS(0.9), SW(0.02), GW(0.014)
SED(0.7), SBS(0.3), SFS(1.4), SW(0.005), GW(0.009)
SED(1264). SBS(llO), SFS(65.4), SW(0.04), GW(0.11)
SED(35.6). SBS(0.6), SFS(3.1), SW(0.013)
SED(51.5), SBS(30), SFS(107), SW(0.04), GW(O.ll)
SED(3.8)
GW(0.02)
SED(4.0), SBS(2.4), SFS(28.4), SW(l.g)
SED(22.3), SBS(6.6). SFS(0.2), SW(0.12), GW(O.ll)
SED(7.1)
SED(16.5), SBS(l.O)
SED(5.9)
SED(1460). SBS(160), SFS(241), SW(O.ll), GW(0.22)
SED(l.l). SBS(0.3), SFS(2.3)
25
-------
TABLE 5 (continued)
CHEMICALS OF CONCERN
25. 2-Methylnaphthalene
26. 2-Mclhylphenol
27. 4-Methylpheno!
28. Naphthalene
29. Nickel
30. Phenanthrene
31. Phenol
32. Pyrene
33. Toluene
34. Xylene
35. Zinc
MEDIA (95th PERCENTILE IN PPM)
SED(143). SBS(12.5), SFS(2.2), SW(0.06), GW(1.38)
SED(3.9). SBS(5.4). SFS(142), SW(5.6)
SED(5.0), SBS(15.0). SFS(526), SW(7.0)
SED(35.5). SBS(3.6), SW(0.05), GW(0.91)
SED(17.4). SBS(16.1), SFS(14.1), SW(0.22), GW(0.13)
SED(75.3), SBS(3.6), SFS(1.9)
SED(4.2), SBS(21.7), SFS(556), SW(3.5)
SED(64.7), SBS(1.9), SFS(2.2)
SED(27.1), SBS(12.7), SFS(0.2), SW(0.14), GW(0.53)
SED(93.5), SBS(42.1), SFS(0.2), SW(0.14), GW(0.45)
SED(182), SBS(41.6), SFS(172), SW(0.32), GW(0.23)
SED - Sediments
SBS - Subsurface Soils
SFS - Surface Soils
SW - Surface Water
GW - Ground Water
26
-------
As evidenced by site inspections, the land surrounding the site is used in a combination of ways
including residential, recreational, commercial and agricultural. It is expected that the
surrounding lands will continue to be used for these purposes.
The second step in the exposure assessment is to determine the exposure pathways. Table 6 lists
the quantitative pathways of concern at the ORC site. The ORC baseline risk assessment
determined that the following exposure pathways are of current and future significance to the
ORC Site:
• Dermal contact with ground water, surface waters, sediments and soils;
• Ingestion of ground water;
• Incidental ingestion of surface water, sediments and soils; and
• Inhalation of the air and volatilized chemicals from the ground water.
The third step in the exposure assessment was to estimate the potential doses (intakes) of
contaminants by each receptor. In general, standard exposure factors, as defined in the Human
Health Evaluation Manual, Supplemental Guidance: Standard Default Exposure Factors
(OSWER Directive 9285.6-03), were used for this determination. The exposure factors used are
shown in Appendix B.
Toxicity Assessment
The purpose of the toxicity assessment was to weigh available evidence regarding the potential
for contaminants to cause adverse effects in exposed individuals.
The toxicity assessment involved two steps: hazard identification and dose-response assessment.
The hazard identification determined whether exposure to a chemical could cause an increase in
the incidence of a particular adverse health effect (carcinogenic or non-carcinogenic) and whether
the adverse health effect would likely occur in humans. The second step, dose-response
assessment, quantitatively evaluated the toxicity information and characterized the relationship
between the dose of the chemical received and the incidence of adverse health effects in the
exposed Population.
Toxicity values (i.e.. reference doses for non-carcinogens and slope factors for carcinogens) are
used in the risk characterization to estimate the likelihood of adverse effects occurring in humans
at different exposure levels and are specific to exposure routes. The EPA has established a
weight-of-evidence classification system for carcinogens as follows:
• Group A - Human carcinogen
• Group Bl or B2 - Probable human carcinogen; Bl indicates that limited data are available and
B2 indicates sufficient evidence in animals and inadequate or no evidence in humans
• Group C - Possible human carcinogen
• Group D - Not classifiable as to human carcinogenicity
• Group E - Evidence of non-carcinogenicity for humans
27
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The EPA has performed the toxicity assessment for numerous chemicals and this data is available
through several sources. The toxicity values and their sources for the 35 COCs at the ORC site
are listed on Tables 7A and 7B.
Risk Characterization
The risk characterization is the final step of the baseline risk assessment process. This step
summarizes the toxicity and exposure assessments as expressions of risk. Once the exposure
scenarios were developed and the chemicals of concern and their toxicib'es established, the risk
associated with each pathway was calculated. The exposure pathways were summed to calculate
a cumulative risk for each scenario. The chemical intakes, the carcinogenic risks and the non-
carcinogenic hazard indices for each receptor and each pathway are shown in Appendix C.
The NCP has established what is considered to be an target range of excess cancer cases
associated with Superfund sites. To protect human health, the NCP has set the target risk range
from 10"4 to 10"*. This range may also be described as one in ten thousand to one in one million
excess cancer cases above the normal cancer rate. The level of concern established by the NCP
for non-carcinogenic contaminants is determined by calculating a hazard index. If the hazard
index exceeds one (1), there may be concern for potential non-cancer effects. It is the goal of
the Superfund program to reduce hazard indices to 1.0 or less.
Risk Summary by Receptor
A summary of the carcinogenic risks and the non-carcinogenic hazard indices is shown on Tables
8 and 9. The receptors and their associated risks are described below.
The first exposure scenario, the current off-site resident, was developed to depict a person
currently living off-site who does not enter the ORC site property but does contact surface water
and sediments in Gladys Creek and breathes the ambient air. The carcinogenic risk was found
to be 3 x 10'6 which is within the target range established by the NCP for carcinogenic
compounds. The non-carcinogenic hazard index was 0.08 which is below the NCP level of
concern f->- non-carcinogenic compounds.
The second exposure scenario, the potential on-site intruder, was developed to depict an
intruder that would come into contact with contaminated ground water, surface water and
sediments in both the on-site ponds and Gladys Creek, surface soils on-site and ambient air. The
carcinogenic risk was found to be 3 x 10'5 which is within the target range established by the
NCP for carcinogenic compounds. The non-carcinogenic hazard index was 0.9 which is below
the NCP level of concern for non-carcinogenic compounds.
The third exposure scenario, the potential on-site worker (acute exposure), was evaluated for
exposures to all media over a period of two weeks. The potential on-site worker (chronic
exposure) was evaluated for exposure to surface soil and air over a period of 30 years. The
carcinogenic risk for the acute exposure scenario was found to be 1 x 10"6 which is within the
29
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target range established by the NCP for carcinogenic compounds. The carcinogenic risk for the
chronic exposure scenario was found to be 2 x 10"4 which is not within the target range
established by the NCP for carcinogenic compounds. The non-carcinogenic hazard index for the
acute exposure was 0.3 which is below the NCP level of concern for non-carcinogenic
compounds. The non-carcinogenic hazard index for the chronic exposure was 1.2 which is
slightly above the NCP level of concern for non-carcinogenic compounds.
The fourth exposure scenario, the potential on-site resident, was developed to depict a person
who could move onto the ORC site and set up a residence, and use the contaminated ground
water as a primary drinking water source. This exposure scenario is considered as the reasonable
maximum exposure for the development and selection of appropriate alternatives for site
remediation. It was assumed that the future potential on-site resident would come into contact
with all media. The carcinogenic risk was found to be 5 x 10~3 which is not within the target
range established by the NCP for carcinogenic compounds. The non-carcinogenic hazard index
was 87 which exceeds the NCP level of concern for non-carcinogenic compounds.
The unacceptable carcinogenic risk and unacceptable hazard index for the potential on-site worker
and resident scenarios provide the necessary justification for taking action at the ORC site.
Uncertainties Associated with the Human Health Risk Calculations
Risk assessment as a scientific activity is subject to uncertainty. In addition to the use of many
conservative assumptions and approximations, the identification and analysis of environmental
conditions is difficult and inexact. The ORC risk assessment is subject to uncertainty from a
variety of sources including:
• sampling and analysis;
• toxicological data;
• exposure estimation;
• fate and transport estimation; and
• risk characterization.
Uncertainties associated with sampling include the representativeness of the samples; sample
cross contamination; statistically significant sample size; sampling strategy (i.e.. purposive,
random, systematic); temporal changes; and seasonal variability.
Uncertainties associated with sample analysis include the inherent variability in the laboratory
equipment; laboratory contamination; contamination introduced during sample dilution; and
estimated values. Although the quality assurance/quality control (QA/QC) program used during
the RI serves to reduce the sources of variability, it cannot eliminate all variability associated
with sampling and analysis.
Uncertainties associated with the toxicological database (e.g.. Integrated Risk Information System
(IRIS), Health Effects Assessment Summary Tables (HEAST)) include extrapolation from high
38
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experimental doses to low environmental doses; extrapolation from animal data to humans;
species difference in uptake, metabolism, and organ distribution; species difference in target
organ susceptibility; and human population variability with respect to diet, environment, activity
patterns, and cultural factors.
Uncertainties associated with exposure estimation include the description of current actual and
future potential exposure scenarios. The variables and assumptions in these scenarios include
physical parameters (e.g.. body weight, contact rates); activity patterns of potential receptors;
physiological variability of individuals; and the presence and exposure of sensitive populations.
There are a number of uncertainties regarding the assumptions made for likelihood of exposure;
frequency of contact with contaminated media; the concentration of contaminants at exposure
points; and the time period of exposure. These assumptions tend to simplify and approximate
ORC site conditions.
Uncertainties associated with fate and transport can be attributed to the estimation of chemical
movement through different media and the assumption that all conditions remain constant over
time. The ORC baseline risk assessment made the assumption that no contaminant loss or
transformation occurred. The choice of data to represent exposure point concentrations is an
additional source of potential error. In particular, the surface water data were divided into
subsets (i.e.. Gladys Creek and on-site ponds) for certain receptors and exposures.
Uncertainties associated with risk characterization include potential chemical interactions (e.g..
synergy). There is no guidance for determining synergistic effects in risk characterization.
Therefore, it is assumed that all risks are additive and slope factors are based on a multi-stage
model that assumes the dose-response relationship is linear.
Uncertainty in the ORC baseline risk assessment is a function of risk assessments in general and
a function of the uncertainty specific to the ORC site in particular. Although all risk assessments
contain a certain amount of uncertainty, an attempt to reduce the uncertainty in the ORC baseline
risk assessment was made whenever possible.
Ecological Risks
The ORC baseline risk assessment performed a qualitative evaluation of the environmental risks
at the ORC site. The site ecology was evaluated to determine if the contamination from the site
was causing any significant adverse ecological impact.
Remedial Investigation activities at the ORC site showed stained areas and stressed or absent
vegetation in waste source areas. The most significant absence of vegetation was in the buried
acid pit area and near the caustic seep discharge area.
Remedial Investigation activities at the site found the skeletal remains of turtles and hawks
trapped in old asphalt pits. Turtles were killed when heavy rains caused the rise of contaminated
ground water and LNAPL into the sludge trap system. A threat to migratory waterfowl exists
39
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from oily waste ponds. Netting was placed over some of the ponds as a temporary measure to
prevent waterfowl from coming into contact with the pond waters.
Except for low levels of phenol and methyl phenol found during one sampling event, the surface
water in Gladys Creek was not found to be contaminated. However, Gladys Creek has been
visibly impacted by the leaching of acidic (low pH) and caustic (high pH) wastes. A study of
the benthic macroinvertebrates in Gladys Creek showed a decrease in the population and species
diversity of these organisms in areas immediately below the acid and caustic leachate areas.
A fish population survey of two ponds along Gladys Creek, one downstream and one adjacent
to the site, indicated a good population and no apparent physical damage to the fish. Fish tissue
was analyzed for inorganic priority pollutant contamination. The results showed low levels of
inorganic contaminants which did not exceed the State's level of concern for the prevention of
human bioaccumulation.
No records of rare or endangered species or significant ecological communities on or in the
vicinity of the ORC site were found in record searches conducted by the Oklahoma Natural
Heritage Inventory and by the Oklahoma Department of Wildlife Conservation.
In summary, actual or threatened releases of hazardous substances from this 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.
VII. DESCRIPTION OF ALTERNATIVES
A Feasibility Study was conducted to develop and evaluate remedial alternatives for the ORC
site. Remedial alternatives were assembled from applicable remedial technology process options
and were initially evaluated for effectiveness, implementability, and cost based on engineering
judgement The alternatives selected for detailed analysis were evaluated and compared to the
nine criteria required by the NCP (see Section VUL). As a part of the remedial alternatives, the
NCP requires that a no-action alternative be considered at every site. The no-action alternative
serves as a point of comparison for the other alternatives.
The RAOs set for the ORC site (discussed in the Summary of Site Characteristics section) are
the concentration levels below which the media can be left in-place without treatment This
applies to all media except surface water in on-site ponds which must be removed to allow for
excavation and filling and grading.
The descriptions and evaluations of remedial action alternatives are separated into six alternatives
addressing contaminated sediments, surface soils, and surface water and six alternatives
addressing contaminated ground water.
40
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Sediment and Surface Soil Remedial Action Alternatives
Remedial action alternatives for sediments and surface soils were developed by organizing the
wastes into groups with similar characteristics. See Table 10 for the sediment and surface soil
remedial action alternatives and the associated group numbers for each alternative.
The alternatives for the sediment, surface soil and surface water remedial action are as follows:
• Alternative I: No Action
• Alternative II: Limited Action
• Alternative ID: Containment, Neutralization and Biotreatment
• Alternative IV: In-situ Stabilization, Neutralization and Biotreatment
• Alternative V: In-situ Stabilization, Recycling, Neutralization and Biotreatment
• Alternative VI: In-situ Stabilization, Recycling, Neutralization and LTTD Treatment
Common Elements
All of the sediment and surface soil alternatives, with the exception of Alternative I, have the
following common elements: site preparation; the installation of office, storage, and security
facilities; the installation of surface water runoff control measures; installation and maintenance
of warning signs and fencing; placement of a notice to the property deed warning of site hazards;
restoration of the site surface upon completion of the remedial action; and air monitoring and
dust control to minimize any potential short-term adverse health effects during the remedial
action.
All of the alternatives, with the exception of Alternatives I and n, would involve the removal and
placement of RCRA listed hazardous wastes. The RCRA listed hazardous wastes that are
actively managed in Alternatives III through VI must meet the applicable RCRA Land Disposal
Restrictions (LDRs). LDRs are the restrictions placed on the land disposal of RCRA hazardous
wastes (40 CFR 268). LDRs do not apply for any in-situ treatment.
All of the alternatives, with the exception of Alternative I, involve treating and/or containing soils
and sec1 cnts which have contaminant concentrations that exceed RAOs.
All of the alternatives, with the exception of Alternative II, have included a no action response
action for Group 7 (Pump Pits 1 and 7) since no RAOs were exceeded in the Group 7 sediments.
All of the alternatives, with the exception of Alternative I, have included a limited action for
Group 5 (North Ponds 3, 4, 5, 6 and 8, South Ponds 1-8, and Oil Skimmer Pond 3) since no
RAOs were exceeded in Group 5 sediments but filling and grading is necessary for
implementation of several of the alternatives.
All costs and implementation times are estimates. The costs have a degree of accuracy of +50%
to -30% pursuant to the "Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA - Interim Final" OSWER Directive 9355.3-01, October 1988.
41
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A brief description of the six alternatives evaluated to address contaminated sediments, surface
soils and surface water follows.
Alternative I: No Action
Alternative I is a "no action" alternative for contaminated sediments, surface soils and surface
water. Since wastes will be left on the site above RAOs, a review of the status of the ORC site
is required every five years. As required by the NCP, a no action alternative was included as
a basis for comparison with evaluating other alternatives.
The Applicable or Relevant and Appropriate Requirements (ARARs) for this alternative include
Subparts F (releases from solid waste management units) and G (closure and post-closure) of 40
CFR 264. Alternative I will not meet these ARARs.
There is no capital cost associated with this alternative. Operation and maintenance (O&M) costs
are estimated to be $5,000 every five years for the performance of five-year reviews. The
present worth cost is estimated to be $15,000.
Alternative II: Limited Action
Alternative II consists of taking limited action designed to control direct contact with the
sediments, surface soils and surface waters at the ORC site. Restricting access to these media
would be accomplished through the use of notices placed in the property deed; warning signs
surrounding the site and waste sources; maintenance of the existing fence surrounding the site;
diversion of surface water currently flowing through waste impoundments; collection and
treatment of on-site surface water, and covering all contaminated sediment and surface soil areas
with soil and vegetation.
Surface water that currently flows through waste impoundments would be routed away from the
waste impoundments using diversion ditches. If uncontaminated, the diverted water would be
allowed to flow directly into Gladys Creek and its tributaries. Surface water in the waste
impoundments would be removed and, if contaminated, treated in the ground water treatment
system, rhe waste sediments would then be covered with soil and vegetation. Long-term
maintenance of the soil and vegetation covering the waste sediments would be required.
The ARARs for this alternative include Subparts F (releases from solid waste management units)
and G (closure and post-closure) of 40 CFR 264. Alternative II will not meet these ARARs.
The RCRA LDRs would not be applicable because no RCRA hazardous waste would be moved.
Contaminated surface water would be treated to meet the Maximum Contaminant Levels (MCLs)
established for drinking water since the water would be injected into the aquifer along with
treated ground water.
43
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The estimated capital cost for this alternative is $1,553,000, with annual O&M costs estimated
to be $24,000. The present worth of this alternative is $1,918,000. The estimated time to
implement this remedy and to meet the remediation goals is approximately 6 months.
Alternative HI: Containment, Neutralization and Biotreatment
Alternative in consists of containing approximately 86,000 cubic yards of contaminated
sediments and surface soils in-place by the use of low permeability caps (groups 2, 3, 4, 6, 10,
11, 12, 14 and 15). Approximately 33,900 cubic yards of sediments and surface soils that
contain contaminants that have low mobility and are therefore not expected to leach into ground
water would be left in-place with soil and vegetation placed over them (groups 5, 9, 13, 16 and
18). Approximately 51,200 cubic yards of low pH sediments would be treated by neutralization
(group 8). Biotreatment of wastes in a lined surface impoundment would permanently destroy
90-95% of the organic contaminants in approximately 17,900 cubic yards of contaminated
sediments and surface soils. The biotreated residuals that contain inorganic contaminants above
RAOs would be stabilized and then contained on-site. The excavated areas would be filled and
graded with clean soil and vegetated.
The optimum biological conditions necessary for the biological degradation of the organic
contaminants would be determined during a pilot-scale study. The specific construction of the
impoundment and the containment cell would be determined during Remedial Design. The
optimum stabilization mixture may be determined using information that was gathered during a
stabilization laboratory treatability study performed during the ORC Remedial Investigation
and/or an additional treatability study performed during the Remedial Design.
Some of the ARARs for this alternative include Subparts F (releases from solid waste
management units) and G (closure and post-closure) of 40 CFR 264. Alternative HI would meet
these ARARs. This alternative involves the excavation and placement of RCRA hazardous
wastes in a surface impoundment. Therefore, the RCRA surface impoundment exemption and
the RCRA LDRs would be applicable. Contaminated surface water would be treated to meet the
MCLs established for drinking water since the water will be injected into the aquifer along with
treated ground water.
The estimated capital cost for this alternative is $9,369,000, with annual O&M costs estimated
to be $114,000. The present worth of this alternative is $10,978,000. The estimated time to
implement this remedy and to meet the remediation goals is approximately 24 months.
Alternative IV: In-situ Stabilization, Neutralization and Biotreatment
Alternative IV primarily consists of treating contaminated sediments and surface soils using
various methods. Approximately 33,900 cubic yards of sediments and surface soils that contain
contaminants that have low mobility and are therefore not expected to leach into ground water
would be left in-place with soil and vegetation placed over them (groups 5, 9, 13, 16 and 18).
Approximately 8,900 cubic yards of waste would be stabilized in-situ and capped (groups 3, 6
44
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and 15). Approximately 51,200 cubic yards of contaminated sediments would be neutralized
(group 8). Biotreatment of wastes in a lined surface impoundment (groups 1, 2, 10, 11, 12, 14
and 17) and in-situ biotreatment (group 4) would permanently destroy approximately 90-95% of
the organic contaminants in approximately 95,100 cubic yards of contaminated sediments and
surface soils. The biotreated residuals that contain inorganic contaminants above RAOs would
be stabilized and then contained on-site. The excavated areas would be filled and graded with
clean soil and vegetated.
The optimum biological conditions necessary for the biological degradation of the organic
contaminants would be determined using a pilot-scale study during the Remedial Design. The
specific construction of the impoundment and the containment cell would be determined during
Remedial Design. The optimum stabilization mixture may be determined using information that
was gathered during a stabilization laboratory treatability study performed during the ORC
Remedial Investigation and/or an additional treatability study performed during the Remedial
Design.
Some of the ARARs for this alternative include Subparts F (releases from solid waste
management units) and G (closure and post-closure) of 40 CFR 264. Alternative FV would meet
these ARARs. This alternative involves the excavation and placement of RCRA hazardous
wastes in a surface impoundment Therefore, the RCRA surface impoundment exemption and
the RCRA LDRs would be applicable. Contaminated surface water would be treated to meet the
MCLs established for drinking water since the water will be injected into the aquifer along with
treated ground water.
The estimated capital cost for this alternative is $19,952,000, with annual O&M costs estimated
to be $120,000. The present worth of this alternative is $21,545,000. The estimated time to
implement this remedy and to meet the remediation goals is approximately 24 months.
Alternative V: In-situ Stabilization, Recycling, Neutralization and Biotreatment
Alternative V primarily consists of treating contaminated sediments and surface soils using
various methods. Approximately 11,100 cubic yards of waste that do not exceed RAOs and do
not req e treatment or capping, would be covered with soil and vegetation (group 5).
Approximately 8,900 cubic yards of waste would be stabilized in-situ and capped (groups 3, 6
and 15). Approximately 10,200 cubic yards of asphalt would be recycled (group 9) and
approximately 51,200 cubic yards of low pH sediments would be excavated, neutralized, and
placed back in their area of origin (group 8). Biotreatment of wastes in a lined surface
impoundment (groups 1, 2, 10, 11, 12, 14, 16 and 17) and in-situ biotreatment (group 4) would
permanently destroy approximately 90-95% of the organic compounds in approximately 99,400
cubic yards of contaminated sediments and surface soils. The biotreated residuals and the
sediments and soils in groups 13 and 18 that contain inorganic contaminants above RAOs would
be stabilized and then contained on-site. The excavated areas would be filled and graded with
clean soil and vegetated.
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The optimum biological conditions necessary for the biological degradation of the organic
contaminants would be determined using a pilot-scale study during the Remedial Design. The
specific construction of the impoundment and the containment cell would be determined during
Remedial Design. The optimum stabilization mixture may be determined using information that
was gathered during a stabilization laboratory treatability study performed during the ORC
Remedial Investigation and/or an additional treatability study performed during the Remedial
Design.
Some of the ARARs for this alternative include Subparts F (releases from solid waste
management units) and G (closure and post-closure) of 40 CFR 264. Alternative V would meet
these ARARs. This alternative involves the excavation and placement of RCRA hazardous
wastes in a surface impoundment. Therefore, the RCRA surface impoundment exemption and
the RCRA LDRs would be applicable. Contaminated surface water would be treated to meet the
MCLs established for drinking water since the water will be injected into the aquifer along with
treated ground water.
The estimated capital cost for this alternative is $22,302,000, with annual O&M costs estimated
to be $132,000. The present worth of this alternative is $24,044,000. The estimated time to
implement this remedy and to meet the remediation goals is approximately 24 months.
Alternative VI: In-situ Stabilization. Recycling. Neutralization and LTTD Treatment
Alternative VI primarily consists of treating contaminated sediments and surface soils using
various methods. Approximately 11,100 cubic yards of waste that do not exceed RAOs and do
not require treatment or capping, would be covered with soil and vegetation (group 5).
Approximately 8,900 cubic yards of waste would be stabilized in-situ and capped (groups 3, 6
and 15). Approximately 10,200 cubic yards of asphalt would be recycled (group 9) and
approximately 51,200 cubic yards of low pH sediments would be neutralized (group 8). The
organic compounds in approximately 107,600 cubic yards of contaminated sediments and surface
soils would be removed through the use of low temperature thermal desorption (LTTD) (groups
1, 2, 4,10, 11,12, 13,14,16,17 and 18). The collected organic contaminants would be recycled
and the thermal treatment residues would be stabilized and placed in an on-site landfill. A pilot-
scale tie oility study of organic removal using low temperature thermal desorption would be
performed during Remedial Design to determine the optimum design conditions. The excavated
areas would be filled and graded with clean soil and vegetated.
Some of the ARARs for this alternative include Subparts F (releases from solid waste
management units) and G (closure and post-closure) of 40 CFR 264. Alternative VI would meet
these ARARs. This alternative involves the excavation and placement of RCRA hazardous
wastes. Therefore, the RCRA LDRs would be applicable. Contaminated surface water would
be treated to meet the MCLs established for drinking water since the water will be injected into
the aquifer along with treated ground water.
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The estimated capital cost for this alternative is $51,840,000, with annual O&M costs estimated
to be $103,000. The present worth of this alternative is $52,645,000. The estimated time to
implement this remedy and to meet the remediation goals is approximately 20 months.
Ground Water Remedial Action Alternatives
Six comprehensive remedial action alternatives were developed to address contaminated ground
water assuming surface soil and sediment contamination sources would be remediated. After
remediation, contaminants in these soils and sediments would be reduced to levels which would
not be expected to leach and would not cause further contamination of the ground water. See
Table 11 for the remedial action alternatives for ground water.
The alternatives for the ground water remedial action are as follows:
• Alternative I: No Action
• Alternative II: Limited Action
• Alternative IE: Containment, Entire LNAPL Plume Removal and In-situ
Bioremediation Enhancement of RSS Aquifer
• Alternative IV: Containment, Recovery of LNAPL Commingled with Hazardous Waste
and In-situ Bioremediation Enhancement of the RSS Aquifer
• Alternative V: Active Restoration of the RSS Aquifer
• Alternative VI: Active Restoration of the RSS Aquifer Commingled with
Hazardous Waste
The shallow ground water beneath the ORC site has a hydrocarbon layer floating on it This
hydrocarbon layer, which is called LNAPL, is primarily the result of petroleum hydrocarbons
which leaked or spilled from refinery process and storage facilities. Some of the LNAPL plume
has floated on top of the ground water and has moved with the water into waste source
contaminated areas which contain CERCLA hazardous substances. Leachate from these waste
sources has mixed with the LNAPL in these areas.
Under CERCLA (1980) the terms "hazardous substance" used in Section 101 (14) and "pollutant
or contr .riant" used in Section 104 (a)(2) do not include petroleum, including crude oil or any
fraction tnereof. Therefore, ground water contaminated by only petroleum hydrocarbon product
cannot be addressed due to the exclusion of petroleum. However, this contamination may be
addressed under other Federal and State authorities. Ground water contaminated with petroleum
hydrocarbon product that is commingled with a CERCLA hazardous substance, pollutant or
contaminant can be addressed.
Although ground water contaminant types are similar across the site, no evidence was gathered
during the RI to indicate that the LNAPL plume located beneath the refinery portion of the ORC
Site is commingled with hazardous substances. The plume beneath the refinery portion of the
site cannot be addressed as part of the Superfund remedial action because of the petroleum
exclusion under CERCLA.
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Two separate alternatives for containment and in-situ treatment and two separate alternatives for
pump and treat remediation of the RSS aquifer were developed. Two alternatives were developed
because the ground water beneath the refinery process area is primarily contaminated by
petroleum hydrocarbons while the LNAPL plume and ground water in other portions of the site
are contaminated by a mixture of petroleum hydrocarbons and leachate from waste sources.
In both cases, one alternative is provided which would remediate all ground water contamination
at the ORC site regardless of the source and a second alternative is provided which would
remediate only the portion of ground water and LNAPL contaminated by hazardous substances.
Due to the petroleum exclusion, the alternatives to remediate all contaminated ground water are
prohibited under CERCLA authority, but the alternatives which remediate only the portion of the
aquifer commingled with hazardous substances can be addressed by CERCLA authority. The
areas of ground water and LNAPL remediation for alternatives HI through VI are shown on
Figures 6 and 7.
Common Elements
All of the alternatives, with the exception of Alternative I, have the following common elements:
Site preparation and the installation of office, storage, and security facilities; plugging existing
wells which are suspected to be conduits of contaminant migration; installation and maintenance
of warning signs and fencing; placement of a notice to the property deed warning of site hazards;
and ground water monitoring.
All of the alternatives, with the exception of Alternatives I and II, involve containing or treating
ground water which has contaminant concentrations that exceed RAOs. The water treatment
process for all extracted water would be the same for all alternatives. The treatment process for
heavy metals removal would consist of either oxidation, reduction, chemical precipitation and
filtering or a combination of these processes. The treatment process for hydrocarbon contaminant
removal would consist of air stripping and/or carbon adsorption. The sludges created during the
treatment of the contaminated ground water will be tested to determine if they are RCRA
characteristic waste. If they are found to be RCRA waste, they will be disposed off-site at an
approved RCRA facility. If they are not RCRA waste, they will be disposed off-site at an
approve >lid waste facility. If carbon adsorption is used, the spent carbon will be regenerated
off-site.
All of the alternatives have the following common ARARs: National Primary and Secondary
Drinking Water Standards.
All costs and implementation times are estimates. The costs have a degree of accuracy of +50%
to -30% pursuant to the "Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA - Interim Final" OSWER Directive 9355.3-01, October 1988.
A brief description of the six alternatives evaluated to address contaminated ground water
follows.
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^
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Ground Water Alternative I: No Action ^ft
Ground water Alternative I is the no action alternative and consists of reviewing the status of the
ORC site every five years. It provides a baseline against which the other alternatives can be
compared Ground water Alternative I would not provide any measure of protection for the
environment since contaminated ground water would be allowed to migrate into the surface
waters of Gladys Creek and its tributaries. Based on the results of the baseline risk assessment,
this alternative would not provide overall protection of human health for a future potential on-site
resident receptor. This risk would only be realized if a ground water well is actually drilled on-
site and is used for a drinking water source.
This alternative does not comply with all ARARs since the MCLs for contaminants in a potential
source of drinking water will not be met. There is no capital cost associated with this alternative.
O&M costs are estimated to be $5,000 every five years for the performance of five-year reviews.
The present worth cost is estimated to be $15,000.
Ground Water Alternative II: Limited Action
Ground water Alternative II consists of taking limited action toward controlling access to the
contaminated ground water at the ORC site. Restricting access to the ground water would be
accomplished through the use of notices placed in the property deed; warning signs surrounding
the site; and maintenance of the existing fence surrounding the site. The existing on-site wells,
which are conduits for migration of contamination, would be plugged.
This alternative does not comply with all ARARs since the MCLs for contaminants in a potential
source of drinking water will not be met.
The estimated capital cost for this alternative is $84,000, with annual O&M costs estimated to
be $94,000. The present worth of this alternative is $1,540,000. The estimated time to
implement this remedy is approximately 1 month.
Ground Water Alternative III: Containment. Entire LNAPL Plume Removal and In-situ
Biorem
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This alternative is not expected to comply with all ARARs because bioremediation enhancement
would not destroy inorganic contaminants and therefore the MCLs for inorganic contaminants
in a potential drinking water source will probably not be met The MCLs for organic
contaminants may be met
The estimated capital cost for this alternative is $3,935,000, with annual O&M costs estimated
to be $315,000. The present worth of this alternative is $8,786,000. The estimated time to
implement this remedy is approximately 30 years.
Ground Water Alternative IV: Containment. Recovery of LNAPL Commingled with
Hazardous Waste and In-situ Bioremediation Enhancement of the RSS Aquifer
Ground water Alternative IV is exactly the same as ground water Alternative III except that the
LNAPL plume and ground water areas to be remediated are different Ground water Alternative
IV will only remediate the portion of LNAPL and ground water contaminated with hazardous
substances that can be remediated under CERCLA authority. This alternative would prevent
contaminated ground water from discharging into the creek systemsxuid migrating off-site by the
use of an interceptor well system (approximately 56 wells) located near the downgradient borders
of the site. The extracted water would be treated on-site. Nutrients and oxygen may be added
to the treated water which would be injected into hazardous waste contaminated portions of the
RSS aquifer to enhance in-situ bioremediation. A portion of the LNAPL plume, which is a
significant source of contamination to the ground water, would be removed with an extraction
well system (approximately 81 wells) and recycled.
This alternative is not expected to comply with all ARARs because bioremediation enhancement
would not destroy inorganic contaminants and therefore the MCLs for inorganic contaminants
in a potential drinking water source will probably not be met The MCLs for organic
contaminants may be met
The estimated capital cost for this alternative is $3,155,000, with annual O&M costs estimated
to be $293,000. The present worth of this alternative is $7,668,000. The estimated time to
implement this remedy is approximately 30 years.
Ground Water Alternative V: Active Restoration of the RSS Aquifer
Ground water Alternative V consists of active restoration of the RSS aquifer contaminated by the
ORC site using pump and treat remediation technology. Pump and treat remediation technology
involves the removal of many pore volumes of ground water from contaminated portions of the
aquifer using a very extensive well system. An extraction well system (approximately 697 wells
and 70 well points) installed across the area of ground water contamination would extract LNAPL
and contaminated ground water. This water would be treated in an on-site treatment system and
recovered hydrocarbons would be recycled. Treated water would be injected into the aquifer.
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This alternative is not expected to comply with all ARARs since the MCLs for organic
contaminants will probably not be met. A high level of uncertainty exists whether organic MCLs
can be met because of the significant amounts of contamination sorbed to the subsurface soils.
Leachate from contaminated subsurface soils are likely to continue to slowly migrate and
recontaminate the ground water after active restoration. The MCLs for inorganic contaminants
may be met.
The estimated capital cost for this alternative is $11,146,000, with annual O&M costs estimated
to be $727,000. The present worth of this alternative is $22,339,000. The estimated time to
implement this remedy is approximately 10 years.
Ground Water Alternative VI: Active Restoration of the RSS Aquifer Commingled with
Hazardous Waste
Ground water Alternative VI is exactly the same as ground water Alternative V except that the
area of contaminated ground water to be remediated is different Ground water Alternative VI
would only remediate the portion of ground water contaminated with hazardous waste that can
be remediated under CERCLA authority. Ground water Alternative VI consists of active
restoration of the RSS aquifer using pump and treat technology. An extraction well system
(approximately 425 wells) installed across the area of ground water contamination would extract
LNAPL and contaminated ground water. This water would be treated in an on-site treatment
system and recovered hydrocarbons would be recycled. Treated water would be injected into the
aquifer.
This alternative is not expected to comply with all ARARs since the MCLs for organic
contaminants will probably not be met. A high level of uncertainty exists whether organic MCLs
can be met because of the significant amounts of contamination sorbed to the subsurface soils.
Leachate from contaminated subsurface soils are likely to continue to slowly migrate and
recontaminate the ground water after active restoration. The MCLs for inorganic contaminants
may be met
The estim?fed capital cost for this alternative is $6,986,000, with annual O&M costs estimated
to be $-,, ->,000. The present worth of this alternative is $14,576,000. The estimated time to
implement this remedy is approximately 10 years.
VIE. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The EPA uses nine criteria to evaluate alternatives for addressing a Superfund site. These nine
criteria are categorized into three groups: threshold, primary balancing, and modifying. The
threshold criteria must be met in order for an alternative to be eligible for selection. The primary
balancing criteria are used to weigh major tradeoffs among alternatives. The modifying criteria
are taken into account after state and public comment is received on the Proposed Plan of Action.
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Nine Criteria
The nine criteria used in evaluating all of the alternatives are as follows:
Threshold Criteria
Overall Protection of Human Health and the Environment addresses the way in which an
alternative would reduce, eliminate, or control the risks posed by the site to human health and
the environment. The methods used to achieve an adequate level of protection vary but may
include treatment and engineering controls. Total elimination of risk is often impossible to
achieve. However, a remedy must minimize risks to assure that human health and the
environment are protected.
Compliance with ARARs. or "applicable or relevant and appropriate requirements," assures that
an alternative will meet all related federal, state, and local requirements.
Primary Balancing Criteria
Long-term Effectiveness and Permanence addresses the ability of an alternative to reliably
provide long-term protection for human health and the environment after the remediation goals
have been accomplished.
Reduction of Toxicitv. Mobility, or Volume of Contaminants through Treatment assesses how
effectively an alternative will address the contamination on a site. Factors considered include
the nature of the treatment process; the amount of hazardous materials that will be destroyed by
the treatment process; how effectively the process reduces the toxicity, mobility, or volume of
waste; and the type and quantity of contamination that will remain after treatment.
Short-term Effectiveness addresses the time it takes for remedy implementation. Remedies often
require several years for implementation. A potential remedy is evaluated for the length of time
required for implementation and the potential impact on human health and the environment
during imnlementation.
Implementabilitv addresses the ease with which an alternative can be accomplished. Factors such
as availability or materials and services are considered.
Cost (including capita] costs and projected long-term operation and maintenance costs) is
considered and compared to the benefit that will result from implementing the alternative.
Modifying Criteria
State Acceptance allows the state to review the proposed plan and offer comments to the EPA.
A state may agree with, oppose, or have no comment on the proposed remedy.
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Community Acceptance allows for a public comment period for interested persons or
organizations to comment on the proposed remedy. EPA considers these comments in making
its final remedy selection. The comments are addressed in the responsiveness summary which
is a part of this ROD.
Comparative Analysis of Sediment and Surface Soil Alternatives
Threshold Criteria
Overall Protection of Human Health and the Environment
Except for Alternative I, all of the alternatives provide overall protection of human health.
Except for- Alternatives I and II, all of the alternatives provide overall protection of -the
environment. The degree to which each of the alternatives protects human health and the
environment is discussed below.
Alternative I provides no increase in the overall protection of human health and the environment
Under the no action alternative, all of the current and future potential risks to human health and
the environment associated with the ORC site would remain the same. Alternative n should
protect human health from direct contact with contaminated sediments and surface soils because
they will be covered with soil and vegetation. Alternative n will not provide overall protection
for the environment because soil and vegetation will not stop the infiltration of surface water
through wastes and the migration of leachate to ground water.
Alternative HI would provide more protection of the ground water than Alternative II since a low
permeability cap would be used to contain waste sources and those materials that are in direct
contact with the ground water would be excavated and treated. Alternative HI would reduce both
the potential for direct human contact with wastes and the potential for future ground water
contamination. However, a low permeability cap may not prevent infiltration of water from
below. Leachate created from possible water infiltration could contaminate the ground water.
Additional protection of human health and the environment is provided in Alternatives IV
through , by stabilizing the wastes that contain inorganic contaminants before covering them
with a low permeability cap and destroying organic compounds through biological or low
temperature thermal desorption.
Therefore, Alternative in is not as protective as Alternatives IV through VI because only 36%
of the total wastes will be treated as opposed to 82%, 89% and 89% of the total wastes in
Alternatives IV, V and VI, respectively. Alternatives IV through VI are more protective of
ground water than Alternative III and are more protective of human health than Alternative HI.
Alternative V may be slightly more protective than Alternative IV in the long-term because it
provides for all wastes that exceed RAOs to be excavated, treated if necessary and contained.
Alternative IV allows for soil and vegetative covers to be placed over those wastes that are not
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expected to leach but could pose a potential risk from direct contact with the wastes if they are
not covered. As long as the soil and vegetative covers placed over contaminated areas in
Alternative IV are maintained, Alternatives IV through VI arc comparable in terms of overall
protection of human health and the environment
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
ARARs are the federal and state requirements that a selected remedy must meet All of the
alternatives have a common ARAR which includes Subparts F and G of the Standards for
Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities (40 CFR
Part 264). Subpart F requires that any hazardous waste releases be investigated and corrective
action taken if necessary. Subpart G requires the proper closure of hazardous waste units.
The RCRA LDRs are applicable to the hazardous wastes that are actively managed in
Alternatives III through VI. LDRs are set by federal regulation and require that hazardous wastes
be treated to a certain level prior to land disposal.
Alternatives I and II do not meet all ARARs. Alternatives in through VI will meet all ARARs.
Primary Balancing Criteria
Long-term Effectiveness and Permanence
Alternatives I and n would not provide a long-term effective or permanent solution or provide
any controls for the protection of human health and the environment since no treatment of
contaminated media will occur.
Alternatives III and IV involve the covering and containment of treated and untreated wastes.
The risk to human health and the environment from the untreated capped and covered wastes
would be low and the risk from the treated residuals would be negligible. With proper
maintenance, the low permeability capping of untreated wastes in Alternative IE should provide
adequate and reliable control for the protection of human health and the environment If cap
maintc ice were to cease, the caps could deteriorate over time and there would be a chance that
wastes would be exposed. There is also the possibility that ground water or surface water could
infiltrate the untreated waste from below. This infiltration could cause ground water
contamination.
Alternatives V and VI treat all of the contaminated sediments and surface soils that are above
RAOs. The risk to human health and the environment from the covered wastes and the treated
residuals would be negligible. These alternatives provide the most effective and permanent
remedy for the contaminated sediments and surface soils.
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Reduction of Toxicitv. Mobility, or Volume Through Treatment
Alternative I offers no reduction in the toxicity, mobility or volume of the contaminated
sediments, surface soils or on-site surface water.
Alternatives II through VI would reduce the mobility, toxicity and volume of contaminated, on-
site surface water through surface water removal and treatment
Alternative II will not reduce the toxicity, mobility or volume of contaminants in sediments or
surface soils through treatment
Alternatives in through VI would reduce the toxicity and mobility of the contaminated sediments
and surface soils through the use of treatment
Alternative III would treat 36% of the total wastes. Biotreatment would be performed in a lined
surface impoundment and is expected to destroy 90-95% of the organic contaminants. If
inorganic contaminants exceed RAOs, the biotreated waste residuals would be stabilized. Thus,
the toxicity, mobility and volume of contaminants in 36% of the total wastes would be reduced
through treatment. The toxicity, mobility and volume of contaminants that are contained would
not be reduced through "treatment" but the mobility of contaminants would be reduced through
"containment".
Alternative IV would treat 82% of the total wastes. Biotreatment would be performed in a lined
surface impoundment and is expected to destroy 90-95% of the organic contaminants. If
inorganic contaminants exceed RAOs, the biotreated waste residuals would be stabilized. Thus,
the toxicity, mobility and volume of contaminants in 82% of the total wastes would be reduced
through treatment.
Alternative V would treat 89% of the total wastes. Biotreatment would be performed in a lined
surface impoundment and is expected to destroy 90-95% of the organic contaminants. If
inorganic contaminants exceed RAOs, the biotreated waste residuals would be stabilized. Thus,
the toxicity, mobility and volume of contaminants in 89% of the total wastes would be reduced
through . atment
Alternative VI would treat 89% of the total wastes. LTTD treatment would remove 95-99% of
the organic contaminants. LTTD treatment would desorb organic contaminants from sediments
and surface soils. The desorbed organic compounds would be sent off-site for recycling. If
inorganic contaminants in the LTTD treatment residuals exceed RAOs, the treated waste residuals
would be stabilized. Thus, the toxicity, mobility and volume of contaminants in 89% of the total
wastes would be reduced through treatment.
Short-term Effectiveness
Alternative I poses no short-term risk to on-site workers or the surrounding community.
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Alternative II does not involve significant generation of dust or vapor releases and poses no
significant short-term risks to on-site workers or the surrounding community. The estimated time
for implementation of Alternative II is six months.
Alternatives III through VI involve excavation, material handling, and treatment which have the
potential to generate dust and vapors and, for the thermal treatment process (Alternative VI), air
emissions. Risks due to these activities would be minimized by providing strict controls such
as air monitoring, dust suppression and air pollution control devices. A contingency plan would
be developed to address any potential for emergencies during remediation activities. No
unacceptable risk to the surrounding community or on-site workers is anticipated. Workers
would be required to adhere to Occupational Safety and Health Administration requirements
which would be outlined in a worker health and safety plan.
The estimated times for implementation are 24 months for Alternatives HI, IV and V and 20
months for Alternative VI.
Implementabilitv
Alternative I requires no implementation.
Alternative II could be very easily implemented since it requires only covering contaminated
areas with soil and vegetation.
Alternative ID could be easily implemented since its main component is excavation and
containment of contaminated sediments and soils. Alternative El requires more material handling
than Alternatives I and n but the material handling is primarily excavation and placement of
materials.
Alternatives IV and V would require extensive treatment of sediments and soils through the use
of stabilization, neutralization and biotreatment. These treatment processes have been proven to
be effective on the types of contaminants present at the ORC site and are not expected to cause
any unusual problems in their implementation. The biggest difference in the implementation of
these c....'natives compared to Alternatives I through in is the large amount of material handling
necessary. Alternative IV requires less material handling than Alternative V since not all of the
materials are excavated but some are covered with soil and vegetation. Although the material
handling is extensive, this should not hinder the implementation of either of these alternatives.
No specialized equipment is necessary to implement these alternatives. In sum, Alternative IV
is thought to be slightly easier to implement than Alternative V.
Alternative VI would require extensive treatment of sediments and soils through the use of LTTD
treatment and stabilization. These treatment processes have been proven to be effective on the
types of contaminants present at the ORC site. Stabilization is not expected to cause any unusual
problems in its implementation. LTTD treatment may be difficult to implement due to the
extensive material handling. This treatment process would require as much or more material
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handling as Alternative V depending on the material sizing requirements for placement in the
LTTD unit. Alternative VI requires the use of a LTTD unit which would require the
procurement of specialized equipment. In sum, Alternative VI is expected to be harder to
implement than Alternative V.
Cost
The costs for each sediment and soil alternative are as follows:
Alternative Number
I
n
m
IV
V
VI
Capital Cost
0
$1,553,000
$9,369,000
$19,952,000
$22,302,000
$51,840,000
O&M Cost
$5,000 every five
years
$24,000
$114,000
$120,000
$132,000
$103,000
Present Worth
$15,000
$1,918,000
$10,978,000
$21,545,000
$24,044,000
$52,645,000
Modifying Criteria
State Agency Acceptance
The Oklahoma State Department of Health is in agreement with the selection of Alternative V
as the preferred remedy for the contaminated sediments and soils at the ORC Superfund site (See
Appendix D).
Community Acceptance
EPA solivited input from the community on the remediation alternatives proposed to address
sediment and surface soil contamination at the ORC site. The comments received from the
public indicated that, other than an objection by a potentially responsible party to the cost of the
proposed remedy, the community is supportive of the proposed remedy. All comments received
during the public comment period and the EPA responses are in the attached Responsiveness
Summary.
Selection of Sediment and Soil Remedy Based on Comparative Analysis
Based on consideration of the requirements of CERCLA, the comparative analysis of alternatives,
and public comments, the EPA has determined that Alternative V (No Action, Limited Action,
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In-situ Stabilization, Recycling, Neutralization and Biotreatment) will best provide a remedy that
is protective of human health and the environment.
Alternatives I, n, HI, IV and VI were eliminated based on the following reasons.
Alternatives I and n have been eliminated from further consideration because neither alternative
provides overall protection for public health and the environment.
Alternative ffl has been eliminated because the majority of wastes would not be treated but
would be contained beneath low permeability caps. Although proper maintenance of the caps
should prevent direct contact, this alternative does not satisfy the statutory preference for
reduction of toxicity, mobility and volume through treatment as completely as Alternatives IV
through VI. An additional concern with Alternative m is that if the caps were not maintained
and the wastes were uncovered, a direct contact risk would exist
Alternative IV has been eliminated because it does not address all of the wastes that exceed
RAOs. It treats all waste that have the potential to leach contaminants to ground water but it
leaves some wastes on the site that, if uncovered, could pose a risk to human health.
Alternatives V and VI address all wastes that exceed RAOs. Alternative V uses biotreatment to
destroy an estimated 90-95% of the organic contaminants while Alternative VI uses LTTD
treatment to remove an estimated 95-99% of the organic contaminants from sediments and soils.
Both alternatives achieve the same goal of removing the organic contaminants from sediments
and soils; however, the additional potential 4% increase in removal efficiency of LTTD treatment
would cost an additional $28.6 million. The slight increase in the treatment effectiveness of
Alternative VI does not justify the increase in the cost over Alternative V.
Based on the information currently available, EPA and OSDH believe that Alternative V will
eliminate the risk of direct human contact with surface water and will significantly reduce the
risk of direct human contact with contaminated sediments and surface soils. Based on further
review of Alternative V, the EPA and OSDH have determined that Alternative V should be
slightly modified and selected as the remedy for sediments and soils. The minor modifications
to Alte. . rive V are discussed in Section XI of this ROD.
Comparative Analysis of Ground Water Alternatives
Threshold Criteria
Overall Protection of Human Health and the Environment
Overall protection of public health and the environment is provided by all of the ground water
alternatives except the no action and limited action alternatives. Each of the other alternatives
would protect human health by utilizing institutional controls to prevent the potential use of
contaminated ground water as a drinking water supply. Each of the other alternatives would
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protect the environment by preventing ground water discharge into the creek systems by using
extraction well interceptor lines.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
ARARs arc the federal and state regulatory standards that a selected remedy must meet Ground
water alternatives are not expected to meet the National Primary Drinking Water Standards and
the Health Based Standards. All other ARARs will be met (see Section X.).
All ground water alternatives, except the no action and the limited action alternatives, would
utilize ground water remediation technology to lower contaminant levels in the aquifer. The goal
of ground water Alternatives HI and IV is to contain ground water contaminants on the ORC site
and to aid the biodegradation of contaminants in the aquifer. Alternatives HI and IV are expected
to lower ground water contaminant concentrations but are not expected to reduce contaminants
to meet ARARs.
The goal of ground water Alternative V is to lower contaminant levels to meet RAOs within ten
years. However, this goal is probably not achievable due to the large amount of clays in the
subsurface at the ORC Site which contain contamination. It has been found at many other
Superfund sites with similar contaminants and geologic situations that aquifer clean-up goals are
often not achieved because of the continued desorption of contaminants from soils. The
remediation of the clay soils would only be accomplished by excavation and treatment and this
is not cost effective due to the enormous volume of soil that would require remediation.
As in ground water Alternative V, the goal of ground water Alternative VI is to lower
contaminant levels to meet RAOs within ten years. However, this goal is even less achievable
than in ground water Alternative V. Not only does the contaminated subsurface clay problem
exist, but also a significant contamination source, the LNAPL plume and the petroleum-
contaminated ground water that cannot be addressed under CERCLA, are located hydraulically
upgradient of the area of ground water to be remediated in this alternative. This upgradient
contamination would continue to migrate and recontaminate the area of remediation. Unless this
petroleum contamination upgradient of the hazardous waste contamination is remediated, it is
unlikely -a this alternative would achieve its remediation goal.
Primary Balancing Criteria
Long-term Effectiveness and Permanence
Alternatives I and II would not provide a long-term effective or permanent solution for the
protection of human health and the environment. These alternatives would not prevent the
migration of contaminated ground water into the creeks or prevent the degradation of the creek
environment.
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Alternatives III through VI would be effective in the long-term for the protection of human health
and the environment. Institutional controls such as warning signs, property deed notices, and
fences would be used to prevent the contaminated ground water from being utilized as a source
for drinking water. The containment well system used for alternatives in and IV, and the
recovery well systems used for Alternatives V and VI, would prevent the discharge of
contaminated ground water into the creek environment. As long as the institutional controls and
the containment well systems are maintained, the protection of human health and the environment
would be effectively achieved.
None of the alternatives are expected to quickly achieve a permanent solution to the contaminated
ground water problem. The problem of LNAPL residual contamination in subsurface clays
cannot be solved using current ground water remediation technologies. However, the in-situ
bioremediation treatment utilized by Alternatives ID and IV, and the pump and treat-active
restoration treatment utilized by Alternatives V and VI should both help restore the ground water
in the long term.
Reduction of Toxicity. Mobility, or Volume of the Contaminants Through Treatment
All of the alternatives except the no action and limited action alternatives would reduce the
toxicity, mobility, or volume of contamination through treatment. Alternatives III and IV utilize
in-situ biotreatment to lower organic contaminant concentrations in the contaminated aquifer and
utilize pump and treat technology at the downgradient borders of the site. Alternatives V and
VI utilize pump and treat technology throughout the contaminated aquifer. Therefore,
Alternatives in through VI meet the statutory preference for using treatment as a principal
element.
Short-term Effectiveness
Alternative I poses no short-term risk to on-site workers or the surrounding community.
Alternative II poses no short-term risk to the surrounding community but could pose a short-term
risk to on-site workers during the plugging of existing wells. The estimated time for
implerr ation of Alternative II is one month.
Alternatives in through VI are not expected to pose any unacceptable short-term risk to the
community or to on-site workers. Any short-term risk would be minimized during ground water
remediation by maintaining strict controls on treatment processes and waste streams and by
adherence to Occupational Safety and Health Administration requirements which will be outlined
in a worker health and safety plan. A contingency plan would be developed to address any
potential for emergencies during remediation activities.
The estimated times for implementation are 30 years for Alternatives IH and IV and 10 years for
Alternatives V and VI.
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Implementability
Alternative I requires no implementation.
Alternative II is readily implementable with local resources.
. Alternatives in and IV both have containment systems that would be readily implementable after
performing aquifer testing. The use of interceptor wells is a proven technology for capturing
ground water and preventing the migration of contaminants. The LNAPL recovery system would
also be readily implementable after performing aquifer testing. The use of extraction well
systems to recover LNAPL from the ground water has been successfully implemented in many
sites with similar characteristics. The in-situ bioremediation of the aquifer is an innovative
technology and will require a pilot study to determine the best ground water bioremediation
enhancement procedure.
Alternatives V and VI both use extensive pump and treat systems that would be readily
implementable after performing aquifer testing. Pump and treat systems are a proven technology
for the removal of aquifer contaminants. Their effectiveness depends on the aquifer conditions
and the contaminant characteristics.
lost
The costs for each groundwater alternative are as follows:
Alternative Number
I
II
m
IV
V
VI
Capital Cost
0
$84,000
$3,935,000
$3,155,000
$11,146,000
$6,986,000
O&M Cost
$5,000 every five
years
$94,000
$315,000
$293,000
$727,000
$493,000
Present Worth
$15,000
$1,540,000
$8,786,000
$7,668,000
$22,339,000
$14,576,000
State Acceptance
The Oklahoma State Department of Health is in agreement with the selection of Alternative IV
as the preferred remedy for the contaminated ground water at the ORC Superfund site (See
Appendix D).
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Community Acceptance
EPA solicited input from the community on the remediation alternatives proposed to address
ground water contamination at the ORC site. The comments from the public indicated that the
community is supportive of the proposed remedy. All comments received during the pubb'c
comment period and the EPA responses are in the attached Responsiveness Summary.
Selection of Ground Water Remedy Based on Comparative Analysis
Based on consideration of the requirements of CERCLA, the comparative analysis of alternatives,
and public comments, the EPA has determined that Alternative IV (Containment, Recovery of
LNAPL Commingled with Hazardous Waste and In-situ Bioremediation Enhancement of the
Rush Springs Sandstone Aquifer) will best provide a remedy that is protective of human health
and the environment.
Alternatives I, II, HI, V and VI were eliminated based on the following reasons.
Alternatives I and 13 have been eliminated from further consideration because neither alternative
provides overall protection for public health and the environment.
Alternatives III and V have been eliminated from further consideration because these alternatives
are prohibited under current CERCLA authority since they include remediating a portion of the
ground water which has only been contaminated by petroleum product
Alternative IV reduces contamination through the use of in-situ bioremediation. Alternative VI
reduces contamination through the use of pump and treat technology. It is difficult to predict
which of these alternatives would be more successful in restoring the aquifer or whether either
will be able to fully restore the aquifer due to contaminants trapped in the subsurface clay soils.
Both of these alternatives contain and prevent migration of contamination from the site.
However, Alternative IV achieves containment of contaminated ground water and possible aquifer
restoration with a much lower total cost. Therefore, Alternative IV is the selected ground water
remedy.
In summary, the selected ground water remedy is believed to provide the best balance among
alternatives with respect to the criteria used to evaluate remedies. Based on the information
currently available, EPA and OSDH believe the selected remedy provides adequate protection of
human health and the environment, utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and will be cost effective. The selected ground
water remedy will also satisfy the preference for treatment as a principal element.
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IX. THE SELECTED REMEDY A
Sediments and Surface Soils
Remediation Goals
The goal of the selected sediment and soil remedial action is to prevent current or future
exposure to the contaminated soils, sediments and surface water and to reduce contaminant
migration into the ground water. This will be accomplished by treating contaminated soils and
sediments using bioremediation, stabilization, neutralization and containment and the collection
and treatment of surface water to meet drinking water quality levels.
Since all contaminated sediments and surface soils above ground water protection RAOs will
undergo treatment, the long-term effectiveness and permanence of the selected remedy is
excellent. There are not expected to be any unmanageable short-term risks associated with this
remedy, and this remedy complies with all ARARs. The selected remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable, and will be
cost effective. The selected remedy will also satisfy the preference for treatment as a principal
element. Therefore, the selected remedy provides the best balance among alternatives with
respect to the criteria used to evaluate remedies.
Based on other successful bioremediation studies that have been conducted on organic wastes
similar to those found at the ORC site, it is known that biorcmediation will degrade the organic
contaminants found at the ORC site. The selected remedy will require that treatability studies
be performed during the Remedial Design to determine the optimum conditions for biotreatment
of wastes. Treatability studies for stabilization were performed during the Remedial Investigation
and data from those studies may be sufficient for design of the stabilization portion of the
remedy.
The selected remedy assumes that, where applicable, organic contaminants will be treated to meet
RCRA LDRs. The RCRA LDR levels for organic compounds were developed using incineration
as the trf nent method. Although every reasonable effort will be made to biotreat the applicable
wastes to meet the organic LDR levels, it is impossible to establish whether the LDR levels can
be met prior to conducting a bioremediation treatability study. In the event that the LDR levels
cannot be met for RCRA listed wastes, a "No Migration Variance" has been granted as part of
this ROD.
A No Migration Variance allows for the land disposal of wastes that do not meet the RCRA LDR
levels. The concentrations of hazardous constituents or emissions rates at the edge or boundary
of the disposal unit must not exceed health-based levels or environmentally protective levels^for
ground water, surface water, soil, and air for as long as the waste remains hazardous. For this
reason, the containment of RCRA listed waste treatment residuals at the ORC site must meet the
strict requirements for hazardous waste disposal and must assure that no migration will take
place.
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Although it is expected that biotreatment of the ORC wastes will meet the RCRA LDR levels,
the No Migration Variance will allow for the land disposal of any restricted wastes not meeting
the LDR treatment levels. The No Migration Variance is suitable for the restricted wastes at the
ORC site because the only organic constituents that may not be degraded to fully meet the LDR
levels are certain polynuclear aromatic hydrocarbons (PNAs) which have multiple aromatic ring
structures. The PNAs that will be difficult to biodegrade at the ORC site do not have a tendency
to migrate from soils into water. This was clearly shown in data from the ORC site which did
not indicate the migration of these PNAs from waste units into ground water or surface water.
Therefore, the available data demonstrate that there will be no migration of hazardous
constituents from the ORC biotreatment units as long as the waste remains on-site.
Performance Standards for the Selected Sediment and Surface Soil Remedy
The selected remedy for contaminated surface water, sediments and surface soils at the ORC site
is composed of twelve major components. Although the ORC Feasibility Study did not attempt
to design these components, there are certain minimum performance standards that must be met
to ensure protection of human health and the environment. If during the course of the Remedial
Design or Remedial Action, additional volumes of waste are encountered that exceed RAOs,
these wastes will be placed in the appropriate group and treated accordingly. The following is
a list of the major components that comprise the selected remedy and their minimum performance
requirements.
1. Surface Water Removal
Surface water in all on-site impoundments shall be removed. Those surface waters that are
contaminated shall be treated to meet ground water RAOs in the same water treatment system
used to treat contaminated ground water. The treated surface water shall be injected into the RSS
aquifer. Stormwater generated during the excavation of contaminated sediments shall be
collected. If the stormwater is contaminated above ground water RAOs, the collected Stormwater
shall be treated to meet ground water RAOs in the same water treatment system used to treat
contaminated ground water. The treated stormwater shall be injected into the RSS aquifer.
2. Lir,..ed Action
Group 5 shall undergo limited action. Limited action includes filling the dewatered
impoundments to grade and vegetating.
3. In-situ Stabilization and Clay Capping
The sediments and subsoils in Groups 3 and 6 that are above sediment and subsoil RAOs
respectively, shall undergo in-situ stabilization. The stabilized materials shall be tested using the
Toxicity Characteristics Leaching Procedure (TCLP) (40 CFR 261, Appendix II) to verify that
any leachate produced will be protective of ground water. Arsenic and lead were detected above
RAOs in these groups and the TCLP leachate shall not exceed 5 ppm for arsenic and 1.5 ppm
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for lead to insure the protection of ground water. These concentrations were determined by
multiplying an attenuation factor by the ground water RAO. The attenuation factor for this site
was calculated to be 101 and was developed as shown in Appendix A.
Data from a bench-scale treatability study performed during the ORC RI shall be used to
determine the optimum stabilization mixtures. If the bench scale treatability study data is
insufficient, additional bench or pilot scale treatability studies shall be performed as necessary
during the Remedial Design.
The stabilized sediments and surface soils shall be capped with 2.5 feet of clay followed by 1
foot of subsoil followed by 0.5 feet of topsoil. The topsoil shall be vegetated. The cap shall
have a hydraulic conductivity of 1 x 10'7 cm/sec or less and shall be sloped to prevent ponding
of water and minimize erosion.
4. Recycling of Asphalt
Group 9 shall undergo recycling of asphalt. The asphalt shall be excavated and reused on-site
or transported off-site for reuse. The excavated areas will be filled to grade and vegetated.
5. In-situ Biotreatment
The sediments and subsoils in Group 4 that are above sediment and subsoil RAOs respectively,
shall undergo in-situ biotreatment. RCRA land disposal restrictions do not apply to this RCRA
listed waste because treatment of the contaminated sediments will be in-situ. However, sediments
and subsoils contaminated above their respective RAOs must be treated to reduce the organic
contaminants above RAOs by at least 90%. The biotreated materials shall be covered with
topsoil and then vegetated.
6. Neutralization
The sediments in Group 8 shall undergo neutralization. Low pH sediments and subsoils in the
acid pits rV ill be excavated and treated to raise the pH to approximately 6-8 standard units. The
neutralized materials shall be returned to their area of origin and the area shall be leveled to
grade and vegetated.
7. Surface Water Diversion
Groups 1 and 2 shall require surface water diversion prior to their excavation. Stormwater from
the City of Cyril and the refinery area flows into these impoundments and is discharged into
Gladys Creek and its tributaries. This stormwater shall be diverted through a new drainage
system to Gladys Creek or its tributaries.
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8. Depression of Ground Water Table
The ground water table in the area of the sludge traps (Group 1) shall be lowered such that the
ground water commingled with LNAPL and hazardous waste does not enter the sludge traps
during their excavation. This shall be accomplished with extraction wells put in place as part
of the ground water remedial action.
9. Prepared Bed Biotreatment
The sediments in Groups 1, 2, 10, 11, 12, and 14 shall undergo prepared bed biotreatment. All
sediments in these groups shall be excavated. The surface soils in Groups 16 and 17 shall also
undergo biotreatment. The surface soils shall be excavated to a depth of one foot The subsoils
beneath the sediments and surface soils shall be excavated to a depth that is visually clean. The
subsoils shall then be tested to confirm that they meet subsoil RAOs. This procedure shall
continue until the subsoil concentrations meet subsoil RAOs or until bedrock is encountered. The
excavated areas shall be filled to grade and vegetated.
The excavated sediments, surface soils and subsoils shall be treated in surface impoundment
treatment beds. The surface impoundment treatment beds shall be constructed with clay,
synthetic liners, and leachate collection systems. The surface impoundments shall be constructed
so that the lining system will withstand the use of heavy equipment.
The contaminated sediments that are considered RCRA listed hazardous waste (Groups 1 and 12)
shall be treated in surface impoundment bed(s) to reduce organic contaminants above RAOs by
at least 90% or to meet RCRA LDRs, whichever is less. The non-RCRA sediments and surface
soils shall be treated in surface impoundment bed(s) to reduce the organic contaminants above
RAOs by at least 90%.
During the Remedial Design, a field pilot study shall be conducted to determine the optimum
conditions for biodegradation. The pilot study may be conducted in a smaller lined impoundment
or it may be conducted in the impoundment constructed for the treatment of the RCRA listed
wastes.
After biotreatment, if inorganic contaminants in the biotreatment beds exceed ground water
protection RAOs, the biotreated material shall be stabilized to prevent migration. The stabilized
materials shall be tested using the TCLP to verify that any leachate produced will be protective
of ground water. Arsenic, lead and chromium were detected above RAOs in these groups and
the TCLP leachate shall not exceed 5 ppm for arsenic, 1.5 ppm for lead and 10 ppm for
chromium to insure the protection of ground water. These concentrations were determined by
multiplying an attenuation factor by the ground water RAO. The attenuation factor for this site
was calculated to be 101 and was developed as shown in Appendix A.
Upon completion of biotreatment and any necessary stabilization, the treated materials shall be
contained on-site. Containment may be in the prepared bed surface impoundment, which will
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be capped, or a separate on-site cell. The choice of containment cells shall be made during the
Remedial Design. In either case, the containment cell shall meet the minimum technology
requirements of a RCRA Subtitle C landfill for the RCRA-listed wastes and the RCRA Subtitle
D requirements for the non-RCRA wastes. If the RCRA wastes meet the LDRs, the containment
cell cap shall meet the requirements of a RCRA Subtitle D cap.
10. Excavation and Disposal
Groups 13 and 18 shall be excavated. The sediments and surface soils in these groups do not
exceed ground water protection RAOs and shall be disposed in the same on-site RCRA Subtitle
D landfill used to dispose biotreatment residuals. The sediments and surface soils shall be
excavated to a minimum depth of one foot and subsoils shall be tested to confirm that the
inorganic contaminants, arsenic, beryllium, chromium and lead, have been removed to meet the
surface soil RAOs. If RAOs are not met, additional soil shall be excavated until the surface soil
RAOs for arsenic, beryllium, chromium and lead have been met
11. Excavation, Stabilization and Disposal
The soils in Group 15 shall be excavated to a minimum depth of one foot and the subsoils shall
be tested to confirm that arsenic has been removed to meet its surface soil RAO. If the RAO
is not met, additional soil shall be excavated until the surface soil RAO for arsenic has been met
The excavated soils shall be stabilized. The stabilized materials shall be tested using the TCLP
to verify that any leachate produced will be protective of ground water. Arsenic was detected
above its RAO in this group and the TCLP leachate shall not exceed 5 ppm for arsenic to insure
the protection of ground water. This concentration was determined by multiplying an attenuation
factor by the ground water RAO. The attenuation factor for this site was calculated to be 101
and was developed as shown in Appendix A.
The stabilized soils shall be disposed in the same on-site RCRA Subtitle D landfill used to
dispose biotreatment residuals.
12. Ace Restrictions
A notice shall be attached to the property deed that informs future land owners that there are
treated waste residuals contained on the ORC site that should not be disturbed.
Maintenance of the fence and warning signs shall also be performed around the perimeter of the
site.
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Ground Wafer
Remediation Goals
The selected ground water remedy consists of three goals. The first goal, to contain
contaminated ground water and prevent it from moving off-site, will be achieved by constructing
and operating an interceptor well system at the downgradient borders of the site. The second
goal, to remove the LNAPL that has commingled with CERCLA hazardous substances from the
RSS Aquifer, will be achieved by constructing and operating an LNAPL recovery well system
until the LNAPL is removed. The third goal, to restore the ground water to its beneficial use as
a drinking water aquifer, will be addressed by injecting treated water into portions of the aquifer
to encourage biodegradation. This goal will be an attempt to reduce contaminant levels to meet
MCLs, health-based levels where MCLs are not available, and the remediation level for lead
pursuant to the "Cleanup Level for Lead in Ground Water" (Memorandum from Henry L.
Longest, EPA Office of Emergency and Remedial Response, Washington, D.C., June 21, 1990).
The EPA and the OSDH believe that the selected remedy may be able to achieve these goals.
When implemented, the ground water remedy systems will be carefully monitored on a regular
basis and adjusted as warranted by the performance data collected during operation.
Modifications of these system may include any or all of the following:
- Discontinue the in-situ biodegradation enhancement in areas of the RSS Aquifer where
remedial goals have been attained.
- Discontinue the operation of interceptor wells in areas where the ground water being removed
by the interceptor wells reaches contaminant levels that can be allowed to move into Gladys
Creek without harming public health or the environment
- Install additional extraction or injection wells to facilitate or accelerate containment or
remediation of the contaminant plume.
To ens that remediation levels are maintained, the aquifer will be monitored at those wells in
areas of the aquifer where remedial action has ceased.
The area of attainment for the third goal of the ground water remedy, to restore the RSS Aquifer
as a drinking water aquifer, is shown on Figure 6. The ability to achieve remediation levels at
all points throughout the area of attainment cannot be determined until the ground water remedy
has been implemented and modified as necessary and the contaminant plume response has been
monitored over time. If it is determined that the selected remedy cannot meet the restoration
goal in any portion of the area of attainment, the contingency measures and objectives described
in this section may replace the selected remedy and remediation levels for these portions of the
attainment area. These measures and objectives are considered to protect human health and the
environment, and are technically practicable under the corresponding circumstances.
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The contingency measures and objectives are as follows:
- Waive chemical-specific ARARs for those portions of the aquifer based on the technical
impracticability of achieving further contaminant reduction.
- Continue monitoring of wells within and around the area of attainment
- Discontinue the enhancement of the in-situ biodegradation of the aquifer, however, treated
water will continue to be injected into the RSS aquifer as long as the interceptor well system
is operating.
- Reevaluate remedial technologies for ground water restoration periodically.
The decision to invoke any or all of these measures may be made during periodic reviews of the
remedial action.
Performance Standards for the Selected Ground Water Remedy
The selected remedy for contaminated ground water at the ORC site is composed of five major
components. Although the ORC Feasibility Study did not attempt to design these components,
there are certain minimum performance standards that the selected remedy must meet to ensure
protection of human health and the environment. Following is a list of the major components
that comprise the selected remedy and their minimum performance requirements.
1. Water Treatment Facility
The water treatment facility will be constructed during the initial implementation of the remedy.
The facility will be designed and built to treat collected surface water and ground water to meet
ground water RAOs. Treatment methods for removal of organic contaminants will consist of
oil/water separation and air stripping and/or activated carbon adsorption. Treatment for removal
of inorganic contaminants will consist of either oxidation, reduction, precipitation, filtering, or
a combin^'on of the above.
2. Treated Water Injection System/ In-situ Biotreatment of Ground water
After treatment, the water will be injected into the upper RSS aquifer by wells located in areas
of ground water contaminated by CERCLA hazardous substances at the ORC site. This area is
shown on Figure 6. A pilot study will determine if nutrients or electron acceptors (e.g..oxygen")
will be added to the water to enhance the in-situ bioremediation of the RSS aquifer. The in-situ
bioremediation process of the RSS aquifer will be modeled using a code capable of predicting
contamination migration and in-situ bioremediation impacts. The determination of the injection
well locations, injection rates, and nutrient/electron acceptor concentrations will be aided by the
use of the model. Wells used for injection will consist of properly constructed monitoring wells
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and specially constructed injection wells. Monitoring the RSS aquifer contamination plumes and
subsequent recalibration of the model with actual data will be necessary.
3. LNAPL Removal System
The LNAPL removal system will involve the placement of ground water extraction wells in the
areas where LNAPL is commingled with CERCLA hazardous substances. This area was shown
on Figure 6. The extraction wells will be placed so that the zones of hydraulic influence
resulting from the pumping of each well will converge and cover the entire area of LNAPL
recovery. The wells shall be screened in a manner that will allow the LNAPL to freely enter the
well casing. Pump and recovery tests, conducted during the Remedial Design, will determine the
spacing, construction and operation of the LNAPL recovery system.
Unless another design is more effective, a two pump system will be operated in each well that
will use one pump to extract water from near the bottom of the well and the other pump to
remove the LNAPL. The maximum drawdown of the ground water in any well shall not exceed
15 feet. All water that is extracted will be piped to the water treatment facility, treated, and
injected into the RSS aquifer. The LNAPL recovered will be piped to a collection tank and
recycled. The LNAPL removal system will operate until the recovery of LNAPL ceases to be
effective. After LNAPL removal, all LNAPL recovery wells not needed for the injection well
system will be plugged with grout.
4. Containment Well System
The implementation of the containment well system will involve the placement of a line of
interceptor wells in the area shown in Figure 8. The wells will be spaced so that the zone of
hydraulic influence resulting from the pumping of the well system will prevent contaminated
ground water from moving past the interceptor well line. The interceptor well system shall be
designed based on pump and recovery tests conducted during the Remedial Design. Extracted
ground water will be piped to the water treatment facility, treated, and injected into the RSS
aquifer. The RSS aquifer will be monitored to insure that containment of contaminated ground
water is Complete.
4. Plugging of Existing Wells
All monitoring wells, recovery wells, and water production wells which are constructed
improperly or are unnecessary to the ground water monitoring, extraction, or injection systems
shall be plugged with grout. The plugging method shall insure that the wells cannot function as
conduits for contaminant migration.
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5. Access Restrictions
A notice shall be attached to the property deed that informs future land owners of the ORC site
that the ground water contains contamination and should not be used as a drinking water source.
Maintenance of the fence and warning signs shall also be performed around the perimeter of the
site.
X. THE STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select remedial actions that are protective
of human health and the environment. Section 121 of CERCLA also requires that the selected
remedial action for the site comply with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws, unless a waiver is granted.
The selected remedy must also be cost-effective and utilize treatment or resource recovery
technologies to the maximum extent practicable. The statute also contains a preference for
remedies that include treatment as a principal element. The following sections discuss how the
selected remedies for contaminated soils and sediments and contaminated ground water at the
ORC site meet the statutory requirements.
Protection of Human Health and the Environment
In order to protect human health and the environment, the contaminated sediments, surface soils,
surface water and ground water that exceed RAOs will undergo a combination of excavation,
treatment and containment These media will be treated and contained to meet the performance
standards set forth in this ROD. These performance standards will assure that site risks fall
within the target cancer risk range of 10"4 to 10"6 and the non-carcinogenic hazard index will be
reduced to less than one (1). The performance standards will also assure that 1) direct contact
with contaminated sediments and surface soils will cease, 2) contaminated sediments and surface
soils will cease to act as a source of ground water contamination, 3) containment of the ground
water will stop the infiltration of contaminated ground water to Gladys Creek and its tributaries,
and 4) contamination in the Rush Springs Sandstone Aquifer will be reduced.
The se' ,ed remedies protect human health and the environment by reducing levels of
contaminants through treatment and containment. Of all the alternatives evaluated for the
contaminated sediments, surface soils and contaminated ground water, the selected alternatives
provide the best overall protection to human health and the environment. No unacceptable short-
term risks will be caused by implementing these remedies.
Compliance with ARARs
The selected sediment and surface soil remedy, which combines biotreatment, recycling,
neutralization and stabilization, will comply with all applicable or relevant and appropriate
requirements. The ARARs are presented as follows:
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Chemical-Specific ARARs for Soils and Sediments
1. Identification and Listing of Hazardous Waste (40 CFR Part 261), Subpart C - Characteristics
of Hazardous Waste and Subpart D - Lists of Hazardous Waste. Applicable because hazardous
waste will be managed.
2. Land Disposal Restrictions (40 CFR Part 268), Subpart A (268.4) - Treatment Surface
Impoundment Exemption and Subpart D - Treatment Standards. Applicable because hazardous
waste will be treated and land disposed.
3. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61). Relevant and
appropriate during biotreatment, neutralization and stabilization processes.
4. Air Pollution Permits (Oklahoma Air Pollution Control Rules, OAC 310:200-7). Applicable
during biotreatment, neutralization and stabilization processes if emissions exceed one pound per
hour for any one criteria pollutant.
5. Control of Emissions of Organic Materials (Oklahoma Air Pollution Control Rules, OAC 310:
200-37). May be applicable depending on the specific air emissions during biotreatment,
neutralization and stabilization processes.
6. Control of Emission of Hazardous and Toxic Air Contaminants (Oklahoma Air Pollution
Control Rules, OAC 310:200-41). May be applicable depending on the specific air emissions
during biotreatment, neutralization and stabilization processes.
Action-Specific ARARs for Soils and Sediments
1. Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities (40 CFR Pan 264). Relevant and appropriate during biotreatment, neutralization and
stabilization processes.
2. Treatment Surface Impoundment Exemption (40 CFR 268.4). Applicable for the treatment
of RCI . hazardous wastes in a surface impoundment. EPA will exempt restricted waste
treatment in a surface impoundment if the requirements of this exemption are met
The selected ground water remedy, which combines containment, recovery of LNAPL
commingled with hazardous waste, and in-situ bioremediation enhancement of the Rush Springs
Sandstone Aquifer, will comply with most of the applicable or relevant and appropriate
requirements. The only ARAR which may not be met is the National Primary Drinking Water
Regulations ARAR. The ARARs are presented as follows:
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Chemical-Specific ARARs for Ground Water
1. Identification and Listing of Hazardous Waste (40 CFR Part 261), Subpart C - Characteristics
of Hazardous Waste. Applicable if treatment sludge is hazardous by characteristic.
2. National Primary Drinking Water Regulations (40 CFR Part 141). Maximum Contaminant
Levels (MCLs) are relevant and appropriate and will be met for the treated ground water prior
to reinjection. The aquifer contaminant levels will be monitored; however, MCLs for the aquifer
itself may not be met due to the residual contamination in subsurface soils.
3. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61). Relevant and
appropriate if air stripping is used to treat contaminated ground water.
4. Control of Emissions of Organic Materials (Oklahoma Air Pollution Control Rules, OAC 310:
200-37). May be applicable depending on the specific air emissions if air stripping is used to
treat contaminated ground water.
5. Control of Emission of Hazardous and Toxic Air Contaminants (Oklahoma Air Pollution
Control Rules, OAC 310:200-41). May be applicable depending on the specific air emissions if
air stripping is used to treat contaminated ground water.
Action-Specific ARARs for Ground Water
1. Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities (40 CFR Part 264). Relevant and appropriate if treatment sludge is hazardous by
characteristic.
2. Standards Applicable to Transporter of Hazardous Waste (40 CFR Part 263). Applicable
only if treatment sludge is hazardous and must be transported off-site for disposal.
Cost-Effectiveness
EPA tx -es that the selected remedies are cost-effective in mitigating the threat of direct
contact with site wastes and containing contaminated ground water within the site bounds.
Section 300.430 (f) (ii) (D) of the NCP requires EPA to determine cost-effectiveness by
evaluating the following three of the five balancing criteria to determine overall effectiveness:
long-term effectiveness and permanence, reduction of toxicity, mobility or volume through
treatment, and short-term effectiveness. Overall effectiveness is then compared to cost to ensure
that the remedy is cost effective. EPA believes the selected remedies meet these criteria. The
estimated present worth cost for the selected sediment and surface soil remedy is $24,044,000
and the estimated present worth cost for the selected ground water remedy is $7,668,000.
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Utilization of Permanent Solutions and Treatment or Resource Recovery Technologies to the
Maximum Extent Practicable
EPA believes the selected remedies represent the maximum extent to which permanent solutions
and treatment/resource recovery technologies can be utilized in a cost-effective manner for the
ORC site. Of those alternatives that are protective of human health and the environment and
comply with ARARs, EPA and OSDH have determined that the selected remedies provide the
best balance in considering long-term effectiveness and permanence; reduction in toxicity,
mobility or volume through treatment; short-term effectiveness; implementability; and cost, as
well as considering the statutory preference for treatment as a principal element and considering
state and community acceptance.
Preference for Treatment as a Principal Element
The selected remedies satisfy the statutory preference for treatment as a principal element. The
sediment and surface soil remedy will use biotreatment, stabilization and neutralization as
treatment methods. The ground water alternative will use air stripping and/or carbon adsorption
for organic removal and filtering and chemical precipitation for inorganic removal for the
treatment of contaminated ground water that is removed from the RSS aquifer. Nutrients may
be added to the treated water which will be injected into the aquifer to enhance bioremediation.
XL DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan of Action for the ORC site was released for public comment on February 10,
1992. The EPA and OSDH proposed Alternative V (No Action, Limited Action, In-situ
Stabilization, Recycling, Neutralization and Biotreatment) as the best remedy for sediments and
soils to protect human health and the environment.
Upon further review of Alternative V, EPA and OSDH determined that Alternative V should be
slightly modified to allow the surface soils in Groups 13 and 18 (soils exceeding health-based
RAOs) to be placed in the containment cell without stabilization. Since the purpose of
stabilization is to prevent the migration of inorganic contaminants into the ground water, and the
surface us in Groups 13 and 18 do not exceed ground water protection RAOs, stabilization is
unnecessary.
A second modification will change the "in-situ stabilization" of Group IS soils to "stabilization
and containment in the containment cell" of Group 15 soils. This modification will allow for the
consolidation of stabilized materials and will reduce the O&M costs by eliminating an additional
capped area to be maintained.
These minor modifications to Alternative V, the selected remedy for sediments and soils, do not
significantly impact the evaluation of any of the nine criteria used in the comparative analysis
of alternatives.
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XII. THE RESPONSIVENESS SUMMARY
The Responsiveness Summary has been prepared to provide written responses to comments
submitted regarding the Proposed Plan of Action at the Oklahoma Refining Company (ORC)
Superfund site. The summary is divided into two sections.
Section I: Background of Community Involvement and Concerns. This section provides a brief
history of community interest and concerns raised during the remedial planning activities at the
ORC site.
Section II: Summary of Major Comments Received. The comments (both oral and written) are
summarized and EPA's responses provided.
I. Background of Community Involvement and Concerns
Interest in the ORC site on the part of residents, local government officials, and potentially
responsible parties (PRPs) has been moderate. Community relations activities were initiated in
1988 when the site was proposed for inclusion on the National Priorities List A Community
Relations Plan (CRP) was developed to identify and address community concerns raised during
the RI/FS. Copies of the CRP are located in the information repositories. The CRP identified
that the primary interest in the ORC site lies with PRPs and those residents who live near the
site. Area residents are concerned that they might be affected by the contamination from the site.
When ORC closed refinery operations in 1984 there was a significant economic impact on the
community. Therefore, local government officials and residents are concerned about the potential
for future commercial and industrial activities and development at the site. The PRPs are
interested in the scope and cost of any response actions undertaken at the site.
n. Summary of Major Comments Received
Public notice announcing the public comment period and opportunity for a public meeting was
printed in The Cyril News on January 30, 1992. The proposed plan fact sheet was distributed
to the site mailing list on January 31, 1992. An open house was conducted on February 6, 1992,
to infor the public about the Feasibility Study Report and the Proposed Plan of Action. The
comment period began on February 10, 1992, and ended March 11, 1992. At the meeting EPA
and OSDH officials discussed the contamination problems at the site, presented the various
remedial alternatives that were considered, and presented the preferred alternative for the
remediation of the ORC site.
Approximately twenty people were in attendance at the public meeting. The public was given
the opportunity to make comments or ask questions. Seven people made comments or asked
questions. A full account of the public meeting can be found in the public meeting transcript
which is documented in the ORC Administrative Record. Three letters were received with
comments or questions.
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The comments/questions received during the public comment period and EPA's and OSDH's
response is as follows:
1. Comment:
The commenter read a prepared statement consisting of partial quotes from the ORC Proposed
Plan of Action that indicated a diverse and healthy fish population in Gladys Creek; very low
levels of volatile organic compounds found in site air sampling; and the carcinogenic risk for the
potential on-site worker over a period of 30 years was found to be acceptable. He stated that
these were comforting statements but also acknowledged that the ORC reports disclosed hazards
associated with the ORC site.
Response:
The study of the fish in ponds along Gladys Creek did not indicate environmental problems.
However, a study of macroinvertebrates in Gladys Creek did indicate damage to the ecology of
the stream adjacent to the ORC site.
The statement in the ORC Proposed Plan of Action that the potential on-site worker (chronic
exposure) had an acceptable risk due to carcinogens was in error. The error occurred due to the
use of an incorrect slope factor used in the calculation of the carcinogen, arsenic. The correct
slope factor was used and the risk was calculated to be unacceptable for the on-site worker (30
year exposure). An errata sheet explaining the error was published on February 12, 1992, and
was added to the Administrative Record.
2. Comment:
The commenter stated that evaluating the alternatives for sediment and soil remedial action was
difficult. He stated that paragraphs two and three on page seven of the ORC Proposed Plan of
Action stated that Alternative HI will meet all ARARs and that the risk to human health and the
environment from the untreated capped and covered waste would be low and the risk from the
treated rcci duals would be negligible.
Response:
EPA and OSDH have reviewed the sediment and soil alternatives and have concluded that
although Alternative III would meet all ARARs, Alternative V has been deemed more protective
of human health and the environment due to its use of treatment as a primary element
Alternative in was designed as a containment option. Capping contaminated sediments and soils
in-place would be the primary action in this alternative. The contaminated materials that are
capped would not pose a public health threat as long as the caps were well maintained and the
sediments and soils did not leach contaminants into the ground water. The long-term
effectiveness and permanence of capping untreated wastes is unknown because the possibility
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exists that the caps will not be perpetually maintained and that the wastes might eventually leach
contaminants into ground water.
Alternative V increases the use of treatment to include the majority of contaminated sediments
or surface soils that exceed Remedial Action Objectives (RAOs). Most of the wastes will be
treated using biotreatment. Those areas that contain only organic contaminants above RAOs will
be treated using in-situ biotreatment. Those areas that contain both organic and inorganic
contaminants will be excavated, biotreated to destroy organic compounds and stabilized to
prevent migration of inorganic contaminants. Those areas that contain surface soils with
inorganic contaminants below ground water protection RAOs but above health-based RAOs will
be excavated and landfilled on-site.
3. Comment:
The commenter noted that the land treatment area, used by the refinery to treat petroleum
contaminated waste, was found to have no contamination and was an effective treatment area
without modem technology-. Therefore, he stated, Alternative HI, which is thirteen million dollars
less than the proposed alternative, Alternative V, deserves serious consideration with in-situ
biotreatment volumes increased.
Response:
The statement that the land treatment area used during refinery operations showed no detectable
levels of organic contaminants is correct. The success of the land treatment area in degrading
organic contaminants provides evidence that the remaining wastes at the ORC site should be
amenable to bioremediation. Although Alternative in is thirteen million dollars less than
Alternative V, the increase of in-situ biotreatment, as suggested by the commenter, would
increase the cost of Alternative in.
4. Comment:
The commenter stated that the abandoned land south of the plant site should be used for
industr ievelopment only.
Response:
The abandoned portion of the ORC Superfund site could possibly be used for many things. The
EPA does not have the authority to restrict its use to industrial purposes only.
5. Comment:
The commenter stated that the selection of Alternative IV for ground water remediation appears
to be reasonable and effective if pilot studies support the technology conclusively.
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Response:
Pilot studies and pump tests will be conducted during the Remedial Design to evaluate
performance of the ground water remediation system and to establish design parameters.
6. Comment:
The commenter stated that he encouraged continuing information about the Superfund program
and strongly urged the employment of local contractors and labor wherever possible. Information
to the public about the ORC Superfund site will continue as the site remedial design and
remediation progresses.
Response:
Although the use of local contractors may occur, the federal government will use a competitive
bidding process to determine the contractors that will be used on the ORC site.
7. Comment:
Is there a risk to the citizens of Cyril from the ORC site and would the implementation of the
remediation put the citizens of Cyril at risk?
Response:
The risks calculated in the baseline risk assessment for the current actual resident living in Cyril
are based on an exposure of 30 years and fell within the target carcinogenic risk range and below
the level of concern for non-carcinogens. The risks associated with the implementation of a
remedial action are short-term risks and there is no way to calculate a numerical risk. Short-term
risks that are possible include the emission of dust and volatile organic compounds. Short-term
emissions will be controlled to within acceptable levels by providing dust suppression, air
pollution control devices, and air monitoring.
8. Con jit:
Where and how many surface soil samples were taken at the ORC site and surrounding the site?
Response:
Thirty-three (33) surface soil samples (top 12-inches of soil) were taken on the ORC site. Five
samples were taken off-site. Two of the off-site surface soil samples were used as background
samples to determine the naturally occurring levels of contaminants in the ORC site area.
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9. Comment:
The commenter stated that he thought that the purpose of the investigation at the ORC site was
to calculate the difference in contamination between a typical soil sample in the area and samples
taken from on-site in an effort to compare the difference. The commenter asked if, for example,
samples taken two miles from the site could have contamination above levels established from
samples on the site.
Response:
The purpose of the investigations was to address contamination at the site or related to the site.
Background samples were taken near the site to determine the naturally occurring levels of
contamination in the ORC site area and as a basis of comparing samples on-site with samples
outside the contaminated area, but near the site. It is possible that there could be off-site
contamination in the area, not related to the site, with contamination levels higher than the levels
detected on-site. Superfund is authorized to address contamination related to the site and is not
authorized to address contamination in the area unrelated to the Superfund site.
10. Comment:
Is removal of soil and off-site treatment being considered as one of the alternatives?
Response:
Off-site disposal of both treated and non-treated wastes was considered in the ORC Feasibility
Study in the initial screening of technologies. Compared to on-site disposal, off-site disposal was
more expensive.
11. Comment:
The commenter asked if the estimated costs of the preferred alternatives for both soil remediation
and the ground water remediation as they apply to the Cyril Petrochemical property had been
separ 1 from the remainder of the Superfund site and if they had not, could they be.
Response:
At the time of the public meeting the costs had not been separated to show the costs for the site
in terms of the abandoned property and the Cyril Petrochemical property. OSDH subsequently
provided the commenter with the estimated unit costs for the sediment and soil wastes on the
Cyril Petrochemical property.
12. Comment:
The commenter asked when the work would begin.
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Response:
The Remedial Design is scheduled to begin this fall (1992) and will take approximately 18 to 24
months to complete. The Remedial Action will follow the Remedial Design.
13. Comment:
The commenter asked whether during the two years it takes to design the remedy would nature
already clean-up some of the contamination and might the study have to be redone.
Response:
Although there will be some environmental changes that occur over the next two years, it is not
anticipated that the organic concentrations in sediments will be significantly reduced. This is
partly due to the fact that many of the sediments are covered with water which does not provide
adequate oxygen for rapid biodegradation. The inorganic concentrations in the sediments should
remain constant unless the inorganic contaminants migrate into the ground water. The ground
water will continue to become contaminated as long as the light non-aqueous phase liquids
remain floating on the ground water table. No additional study of the site is necessary except
for those treatability studies and analytical tests that are necessary during the Remedial Design.
14. Comment:
The commenter asked who now held title to the portion of the site property that was abandoned.
Response:
When a property is abandoned in bankruptcy, title returns to the last debtor in possession. In this
instance ORC was the last debtor in possession, therefore title reverts to ORC.
15. Comment:
The cor ^nter asked what was the price of the study and who calculated the risks.
Response:
The cost of the contractual part of the Remedial Investigation, Feasibility Study and Risk
Assessment was approximately $1,800,000. The baseline risk assessment was performed by
Bechtel Environmental, Inc. and reviewed by the EPA and OSDH.
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16. Comment:
Is there anything in the National Contingency Plan (NCP) or the preferred alternatives that
requires EPA to consider residential use or the highest use in determining the final alternative:
Response:
The preamble to the NCP and EPA Superfund risk assessment guidance both discuss evaluating
the risk from potential future land use. They also direct EPA to consider both industrial and
residential exposures. Because we cannot control future land uses, EPA must consider residential
land use if that is a reasonable possibility. Residential use is the reasonable maximum exposure
scenario that remediation levels were based on for the ORC site. The NCP does say that we
shall not consider institutional controls as a primary part of the remedy.
17. Comment:
The commenter asked whether it would be cheaper for the State of Oklahoma to buy this
property and prevent anyone from living on it.
Response:
Purchasing the property by the State of Oklahoma as a means of preventing or minimizing
exposure to contamination would be considered an institutional control and institutional controls
are not allowed as the primary remedy for Superfund sites. Furthermore, this approach fails to
attain the remedial goals of the Superfund program by not reducing or resolving the existing
public health and environmental problems posed by the site.
18. Comment:
The commenter asked who will pay for the clean-up.
Respon^r
EPA initially attempts to reach an agreement with the responsible parties to finance or implement
a remedy. If an agreement cannot be reached, then the government will utilize federal Superfund
money (90%) and state money (10%) to remediate the site. The government will then seek to
recover costs from the responsible parties.
19. Comment:
The commenter asked whether there was some potential for recycling the asphalt and could the
income be used to defray the costs of the state's match.
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Response:
The preferred alternative will recycle the asphalt The asphalt may be used on-site or may be
sent off-site for reuse. If income is generated from the asphalt recycling, depending on
ownership of the recycled materials, ninety percent of the income could be used to offset the
federal cost and ten percent could be used to offset the state's cost.
20. Comment:
One commenter stated that he owned the asphalt pits because they are on Cyril Petrochemical
Corporation (CPC) property and not on the abandoned site.
Response:
The asphalt pits located on the CPC property of the Superfund site belong to the CPC landowner.
21. Comment:
The commenter asked if the City of Cyril annexed the abandoned site, wouldn't that prohibit it
from being cleaned up.
Response:
Annexation of the abandoned property by the City of Cyril would not prohibit the site from being
cleaned up. Annexation as an institutional control would not be adequate justification for taking
no action on the site since institutional controls are not allowed as the primary remedy for
Superfund sites.
22. Comment:
The commenter asked what the rule was regarding municipality ownership of a site.
Respon^.
If a municipality owned or operated a Superfund site, then the municipality must pay fifty percent
of all response costs.
23. Comment:
The commenter asked what the chance was of the EPA running out of money before the site; is
finished or could another site take priority over the ORC site for remediation.
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Response:
The money for the ORC Remedial Design has been budgeted. Funding of construction and
actual site remediation work is a high priority.
24. Comment:
One commenter stated that they owned land just east of the ORC site and suggested that an EPA
approved recycling center, which includes incineration and landfilling, be placed on this land.
Response:
Incineration was considered in the initial screening of technologies, but was screened out due to
concerns about the potential for the emission of toxic metals. Another disadvantage of
incineration is its high cost, which is estimated to be significantly in excess of low temperature
thermal desorption, which was the highest cost soil treatment alternative. The proposed remedy
utilizes on-site bioremediation, neutralization, and stabilization to treat contaminated materials.
The treatment residuals would remain on-site. Off-site disposal of residuals is estimated to be
more expensive.
Xin. GLOSSARY
Air Stripping: A process used to transfer volatile organic compounds from a water stream into
an air stream by contacting clean air with contaminated water usually in a column.
Applicable or Relevant and Appropriate Requirements (ARARs): ARARs are the federal and
state requirements that a remedial alternative must meet ARARs are one of nine criteria used
to evaluate remedial alternatives for a site.
Baseline Risk Assessment: A study performed on a Superfund site prior to any remedial action
to assess the actual and potential risks of the site if it is not remediated.
Biotrtu,*nent: A process used to biologically treat solids or liquids contaminated with organic
compounds through the use of naturally occurring microorganisms. The process is enhanced
through the use of nutrients, oxygen and water.
Carbon Adsorption: A water treatment process that removes organic compounds by passing
water through activated carbon.
Carcinogenic: Cancer causing.
CERCLA: An acronym for the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980. The statute that allowed response to hazardous substance releases, liability
and compensation. Also known as "Superfund."
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Chemical Precipitation: A process used to remove heavy metals from a contaminated liquid
stream by the addition of chemicals that react with the heavy metals to form a solid precipitate.
The precipitate can then be separated from the liquid and properly disposed.
Containment: A process used to prevent contaminated solids from migrating by placing them
in a landfill.
Feasibility Study (FS): A study required by CERCLA to establish criteria for remediating a
Superfund site, to identify and screen alternatives for remedial action, and to analyze in detail
the alternatives and their costs.
Filtering: A process used to remove suspended solids from a liquid through the use of a filter.
Group: The term given to sediment and soil areas at the ORC site that have similar physical,
chemical and hydrogeological characteristics. There are 18 groups for the ORC site.
Hazard Index: A numerical indicator of the acceptability or unacceptability of exposure to non-
cancer causing chemicals. A hazard index below unity (1) is considered acceptable while a
hazard index exceeding unity may warrant concern for non-cancer effects due to exposure.
In-situ: In-place.
Land Disposal Restrictions (LDRs): Restrictions placed on the land disposal of RCRA
hazardous wastes.
Light Non-Aqueous Phase Liquid (LNAPL): A liquid that is less dense than water and
therefore floats as a separate layer, or phase, on top of the water.
Low Permeability Caps: A covering made out of synthetic and/or natural materials that is used
to cover contaminated sediments or surface soils and allows only very small quantities of water
to infiltrate.
Low Temperature Thermal Desorption (LTTD): A treatment process which removes volatile
and semi-volatile contaminants from soils and sediments by heating them to temperatures ranging
from 400 to 1000°F.
Maximum Contaminant Levels (MCLs): Concentration levels set for specific chemicals by
the EPA for drinking water sources.
National Oil and Hazardous Substances Pollution Contingency Plan (NCP): The regulation
that sets forth the requirements of the Superfund program as mandated by CERCLA.
National Priority List (NPL): EPA's list of the most serious uncontrolled or abandoned
hazardous waste sites identified for possible long-term remedial response using money from the
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Trust Fund. The list is based primarily on the score a site receives on the Hazard Ranking
System (MRS). EPA is required to update the NPL at least once a year.
Neutralization: A treatment process which consists of adding an acid to a base, or a base to an
acid to neutralize the pH.
Non-carcinogenic: Non-cancer causing.
Pump and Treat Remediation: A ground water treatment method using extraction wells to
remove water from the contaminated portion of an aquifer and then treat it in a water treatment
facility.
ppm: An abbreviation for "parts per million", which is commonly used to express concentrations
of contaminants. For example, 1 liter of a chemical in 1 million liters of water would have a
concentration of 1 ppm. Other expressions for parts per million include milligrams/liter (mg/1)
and milligrams/kilogram (mg/kg).
Record of Decision: The official decision document on the selection of a remedy that makes
the determination and findings required by statute and regulation.
Recycling: The reuse of a substance or material.
Reference Dose: Toxicity values that have been developed by EPA for indicating the potential
for adverse health effects from exposure to contaminants of concern exhibiting non-carcinogenic
effects. Reference doses are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for the use of animal data to predict
effects on humans).
Remedial Action Objectives (RAOs): RAOs are the concentration levels used to determine
whether a contaminated media can be left in-place or whether it must be addressed through in-
situ treatment or excavated. These concentration levels were determined in three ways: 1) by
using regulatory set levels, 2) by calculating a concentration that would not leach from soils and
sedime; and contaminate ground water, and 3) by calculating the chemical concentration that
would cause a "one in one million" risk of cancer by exposure through ingestion of the media.
Remedial Action Alternatives: A method, or combination of methods designed to protect public
health, welfare and the environment over the long-term from releases of hazardous substances
at a Superfund site. Remedial alternatives are usually a combination of technologies that contain,
remove or destroy most of the contaminants in the air, water, soil and ground water at a
Superfund site.
Remedial Investigation (RI): A study which gathers and presents the data necessary to
determine the type and extent of contamination at a Superfund site.
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Resource Conservation and Recovery Act (RCRA): The Federal law that established a
regulatory system to track hazardous wastes from the time of generation to disposal. The law
specifies procedures to be used in treating, transporting, storing, and disposing of hazardous
wastes.
Rush Springs Sandstone (RSS) Aquifer: A Permian Age, underground rock formation
composed of fine grained sandstone which has the capacity to hold and transmit economical
volumes of water.
Sediments: Soil like material deposited under water and found in drainageways, pits and ponds.
Slope Factor: Toxicity values developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic
contaminants of concern. Slope factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied (e.g.. to account for the use of animal data to predict effects on
humans).
Stabilization: A treatment process whereby a waste is mixed with various reagents such as
cement or fly ash, which harden and transform the waste into a solid mass. The contaminants
within the solid waste material are held by strong chemical bonding, which prevents the
contaminants from leaching away.
Superfund: The common name used for the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA).
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APPENDIX A
DEVELOPMENT OF RISK-BASED
REMEDIAL ACTION OBJECTIVES (RAOs)
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APPENDIX A
DEVELOPMENT OF RISK-BASED REMEDIAL ACTION OBJECTIVES
A-1.0 Ground Water
Health-based risk from contaminants in ground water at the ORC Site is assumed to be from
direct ingestion of ground water only.
Maximum Contaminant Levels (MCLs) established under the authority of the Safe Drinking
Water Act were available for use as Remedial Action Objectives (RAOs) for 13 of the 16
chemicals of concern in ground water at the ORC Site.
One of the three chemicals of concern without an MCL was lead. The RAO for lead in ORC
ground water was set at 15 ppb. This level corresponds to the highest level of lead in drinking
water that would correlate to blood lead levels of 10 ug/dl, which is the level of concern in
children.
The two remaining chemicals of concern in ground water at the ORC Site that do not have MCLs
are naphthalene and 2-methyl naphthalene. The health-based risk for these two non-carcinogenic
compounds was calculated as follows:
Total risk from ground water = Risk from ingestion (adult)
The total risk for non-carcinogens is called the hazard quotient. Therefore,
„ . f. .. . C x IRw x EF x ED
Hazard Quotient -
KfD, x BW x AT x 365
92
-------
Solving for C:
HQ x RfD. x BW x AT x 365
C -
IRw x EF x ED
Where:
Parameters Definition Value
C chemical concentration in water (mg/L)
HQ target hazard quotient (unitless) 1
RfD0 oral chronic reference dose (mg/kg-day) chemical-specific
BW adult body weight (kg) 70 kg (adult average)
AT averaging time (yrs) 30 yrs (always equal to ED)
EF exposure frequency (days/yr) 350 days/yr
ED exposure duration (yrs) 30 yrs (90th percentile at a residence)
JR. daily water ingestion rate (L/day) 2 L/day
Substituting the values listed above and reducing the equation gives:
73 x
C (mgfl; HQ-1) --
The RfD0 for both naphthalene and 2-methyI naphthalene is 0.004 mg/kg-day.
Therefore,
C - 73 * P' - 0.15
for both naphthalene and 2-methyl naphthalene.
93
-------
A-2.0 SURFACE SOILS AND SEDIMENTS
Health-based risk from contaminants in surface soil and sediments at the ORC Site is assumed
to be from direct ingestion of these media only. The soil/sediment ingestion rate is different for
children and adults. Therefore, the risk due to direct ingestion of soil/sediments is calculated
using an age-adjusted ingestion rate factor. This assumption leads to a more protective risk-based
concentration compared to an adult-only assumption.
The age-adjusted soil/sediment ingestion rate factor (IRFMU/«ij) takes into account the difference
in soil ingestion for two groups: children of 1 to 6 years and others of 7 to 31 years. The factor
is calculated as follows:
(mg-yeanlkg-day) -
1-6 * EDage 1-6 + IR soillaee 7-31 * ED afe 7_31
1-6 BW age 7-31
Where:
Parameter
BW.pM
BW.,c7.31
Definition Value
average body weight from ages 1-6 (kg) 15 kg
average body weight from ages 7-31 (kg) 70 kg
exposure duration during ages 1-6 (yrs) 6 years
exposure duration during ages 7-31 (yrs) 24 years
ingestion rate of soil age 1 to 6 (mg/day) 200 mg/day
ingestion rate of soil other ages (mg/day) 100 mg/day
Using : values listed above:
IRFsoUladj -
114 mg-years
kg-day
94
-------
This is the value used to calculate the health-based risks due to both carcinogenic and non-
carcinogenic compounds found in soil and sediments at the ORC Site.
A-2.1 Carcinogenic Effects
The total risk for carcinogenic effects of contaminants in surface soils/sediments is
calculated by combining the appropriate oral slope factor (SF0) with the ingestion intake
from soil:
Where:
Total risk = SF, x Intake from soil I sediment ingestion
Total risk (TR) - SFt x
C x lQ-*kglmg x EF xJRFsaiiiadj
AT x
Solving for C: C
T*D v A T v
MK* AI *
SF. x 10-* kglmg x EFx IRF
Parameters Definition (units)
chemical concentration in soil (mg/kg)
target excess lifetime cancer risk
(unitless)
oral cancer slope factor ((mg/kg-day)"1)
averaging time (yr)
exposure frequency (days/yr)
SF,
AT
EF
Value
10'6
chemical-specific
70yrs
350 days/yr
IRF^jy^ age-adjusted ingestion rate (mg-yr/kg-day) 114 mg-yr/kg-day
95
-------
Substituting the values listed above and reducing the equation gives:
C (mglkg-, risk - 10-«) - ^
As an example, for the contaminant benzo (a) anthracene in surface soils and sediments:
SF - 0.1545
Therefore,
.
A-2.2 Non-Carcino2enic Effects
The total risk for non-carcinogenic effects of contaminants in surface soils/sediments is
calculated by dividing the intake from ingestion of soil/sediments by the appropriate oral
reference dose (RfD0). This total risk is called the hazard quotient.
Hazard Quotient = Intake from Ingestion I RfD0
u * ^ * , C x 10"6 kglmg xEF x
Hazard Quotient
x AT x 365
96
•
-------
Solving forC:
10-» kglmg xEFx
Where:
Parameters Definition (units) Value
C chemical concentration in soil (mg/kg)
HQ target hazard quotient (unitless) 1
RfD0 oral chronic reference dose (mg/kg-day) chemical-specific
AT averaging time (yr) 30 yrs (always equal to ED and incorporated in
EF
exposure frequency (days/yr)
age-adjusted ingestion rate factor
(mg-yr/kg-day)
350 days/yr
114 mg-yr/kg-day
Substituting the values listed above and reducing the equation gives:
(mglkg; HQ-i) - 2.7 * 105 (XfDj
As an example, for the contaminant phenol in surface soils and sediments:
BfD. - 0.6 mgjkg-day
C - 2.7 x 10s (0.6) - 162,000 mglkg
97
-------
Notes: Four of the contaminants found in surface soils and/or sediments at the ORC site had
health-based risk numbers that were lower than the current analytical instrument detection
limit. The RAOs for three of these contaminants, beryllium, benzo(a)pyrene and
dibenzo(a,h)anthracene, have been set at the analytical instrument detection limit The
RAO for arsenic was set at a level established by EPA Region VI as being protective of
human health in a residential exposure.
Three of the contaminants found in surface soils and/or sediments at the ORC Site had
leaching levels below the health-based risk level. The calculation for protecting ground
water from these contaminants is explained below.
A-3.0 CONTAMINATION DUE TO LEACHING OF CONTAMINANTS FROM
SURFACE SOILS, SUBSURFACE SOILS AND SEDIMENTS INTO Ground witer
Contaminant concentrations in soils and waste sediments located above the ground water table
have the potential of migrating downward and contaminating ground water. This is accomplished
by rainfall infiltrating through the contaminated media and absorbing contaminants into the water.
The contaminated water, which is called leachate, moves downward and into the ground water.
Acceptable levels of soil and sediment concentrations were calculated to prevent these soils and
waste sediments from contaminating ground water above the ground water RAOs.
The acceptable levels of contaminants in soil and sediments were calculated using three main
parameters. These parameters are as follows:
(1) Volume of infiltration waters from rainfall,
(2) Concentration of leachate after percolating through contamination, and
(3) Volume of ground water in mixing zone of aquifer.
Parameters (1) and (3) were calculated from physical measurement data and observations at the
ORC Site. Parameter (2) was calculated for metals by using leachate tests performed on surface
soils an-" xiiments from the ORC Site. Each metal was found to leach at different rates across
the site. The highest rate of leaching measured was used to represent leachate concentrations.
Parameter (2) was calculated for organic compounds by using the Freundlich equation which
estimates the organic leachate by taking into account the total organic carbon of the soils and the
partitioning coefficient of each contaminant.
The determination of the maximum allowable contaminant concentration to protect the ground
water from leachate is made by multiplying the concentration of leachate by an attenuation factor.
The attenuation factor approximates the degree of mixing and dilution that will occur in the
aquifer and is calculated using the size of the aquifer mixing zone, the amount and rate of
infiltration and the flow rate of the aquifer.
98
-------
Leaching values were calculated for benzene, naphthalene, 2-methylnaphthalene, phenol, 2-
methylphenol, 4-methylphenol, 2-4 dimethylphenol, arsenic, chromium and lead. These values
were used for the subsurface soil RAOs. The benzene and phenols were chosen because they
are prevalent contaminants of concern at the ORC site and are highly mobile organic
contaminants. Naphthalene and 2-methylnaphthalene were chosen because they are the most
mobile of the many polynuclear aromatic hydrocarbons found at the ORC Site. Arsenic,
chromium and lead are prevalent metals of concern and are mobile in low and high pH
environments.
The values calculated for ground water protection for the contaminants chromium, benzene and
naphthalene, found in surface soils and sediments, were used as the RAOs because they had
lower values than the health-based risk values.
The method for determining the maximum allowable contaminant concentration to protect the
ground water from leachate is shown below. Naphthalene is used as an example. This method
can be found in the EPA guidance document entitled "Determining Soil Response Action Levels
Based on Potential Contaminant Migration to Ground water: A Compendium of Examples"
(EPA/540/2-89/057, October 1989, page 33).
Determination Of Soil Clean-Up Levels Of Naphthalene At ORC Site
1st step: Determine fraction of organic carbon (Iv) in clay samples at ORC. Three Total
Organic Carbon (TOC) samples from clays were analyzed; the average TOC concentration was
3560 ppm. These concentrations will be considered as representative of background clays at the
ORC Site. The organic fraction (F.J of these clays is, therefore, 3560/1,000,000 which equals
0.004.
2nd step: Determine K,,,. values for a chemical of concern at the ORC Site; in this case we will
use naphthalene. The K,,. is a partitioning coefficient which quantifies the sorption between
chemical compounds and organic carbon and water. The K^. is unitless and is experimentally
determined for each compound. The K,,,. for naphthalene is 1,300 (from EPA/540/2-89/057).
3rd step: Determine a partitioning coefficient for the clays located at the ORC Site for
naphthalene. We will call this partitioning factor K,, and will derive it using the equation: K^ =
Kd is found to equal 5.2.
4th step: Determine the critical concentration levels for saturated clays. By assuming that the
naphthalene will desorb from the clay in the same manner that it sorbed and that the clays and
water surrounding the clays are at equilibrium, the critical concentration level can be determined
by using the equation: Stu=(K^)(O, where SM is the saturated clay sorbed concentration, K^ is
the partitioning factor, and C is the aqueous concentration. The critical concentration level of
saturated clays was calculated to be 0.79 ppm using the remedial action objective for naphthalene
of 0.15 ppm as the desired C value.
5th step: Determine the clean-up levels for unsaturated clays. The relationship between the
saturated and unsaturated soil concentrations is represented by the equation: Sunsal=(SMi)((e+Q)/e),
99
-------
where SmM is the critical unsaturated soil concentration, $„, is the critical saturated soil
concentration, e is the infiltration volume that is leaching through the contaminated soil, and Q
is the volume of water moving in the aquifer of concern. The result of (e + Q)/e is equal to the
attenuation factor.
The infiltration volume, e, was estimated by taking 50% of the average annual precipitation of
30 inches a year and calculating a volume of infiltration over 1 square foot The value for e was
determined to be 0.003 cubic feet per day.
Q was determined by using the equation: Q=kiA, where k is the hydraulic conductivity of
aquifer, i is the hydraulic gradient, and A is the area of flow or saturation thickness of the zone
of mixing in the aquifer times 1 foot. Therefore, using values k = 0.57 ft/day, i=0.01, and A=50
square feet, a value of 0.30 cubic feet per day was obtained.
Using e=0.003 cubic feet per day and Q=0.30 cubic feet per day, the attenuation factor was
calculated to be 101.
Using these values S^,^ is calculated to be 79 ppm. This corresponds to the highest allowable
concentration of naphthalene in the unsaturated soil to maintain a concentration at or below the
remedial action objective of 0.15 ppm of naphthalene in the ground water.
A.4.0 U. S. EPA LEAD UPTAKE/BIOKINETIC (UBK) MODEL
Lead is commonly found at hazardous waste sites and the ORC Site is no exception. Lead has
been determined to be one of the 35 chemicals of concern (COCs) at the ORC Site. At the
present time, there is no U. S. EPA verified lexicological value (Reference Dose (RfD) and
Cancer potency Factor, i.e.. slope factor), available for use in performing risk assessments or
developing protective soil remediation levels for lead. The ORC risk assessment used an RfD
that was withdrawn from use by the EPA Reference Dose/Reference Concentration Workgroup,
to estimate the impact on human populations, in lieu of totally ignoring the presence of lead on
the ORC Site. This RfD was withdrawn because it did not adequately protect sensitive
populat. ..i (e.g., infants, etc.); therefore, it is not appropriate to use the RfD to develop soil
remediation levels for lead.
The U.S. EPA Lead Uptake/Biokinetic (UBK) Model Version 0.4 (draft, September 1990, ECAO-
CIN-) has been used to develop lead clean-up levels for the ORC Site. The purpose of the UBK
Model is to estimate the total lead uptake (ug Pb/day) in humans, which results from diet,
inhalation and ingestion of soil, dust and paint This model then predicts the blood lead levels
(ug Pb/dL) based on the estimated total lead uptake. These blood lead levels are based on the
following parameters:
• blood lead levels in children (ages 0 to 7 years of age) resulting from exposures to
lead contaminated media;
• lead concentrations in the air, soil, drinking water, diet, paint; and
100
-------
• blood lead concentrations of the mother.
The lead uptake model was used for two purposes:
• to develop lead clean-up levels for surface soil; and
• to predict blood lead levels in the future potential on-site resident (child).
Clean-Up Levels
The following lead concentration variables were used to obtain a mean blood lead concentration
of 5.61 ug Pb/dL:
• 0.20 ug/m3 in air (program default);
• the program defaults for lead in the diet;
• 15 ug Pb/1 in the drinking water, based on the action level set for lead by U.S. EPA;
defaults were used for the daily amount ingested by age;
• 600.0 ug Pb/g in the soil;
• 195 ug Pb/g in the household dust, using the multiple source analysis option (28%
of the soil concentration). The multiple source model sums the contributions of
external environmental sources (i.e.. air and soil) and "all other" sources (Le., indoor
paint dusts, secondary occupational dusts, and hobbies) to arrive at total indoor lead
dust.
• default of 0.00 ug Pb/day, assumed no exposure to leaded paint; and
• maternal blood lead concentration assumed the infant model (7.50 ug Pb/dL).
The re^. -ng mean blood lead level of 5.64 ug Pb/dL was compared to a U.S. EPA designated
cut-off blood lead level of 10 ug Pb/dL. The guideline set by U.S. EPA is that 95% of the blood
lead levels be less than 10 ug/dL. The above variable for an unremediated site will exceed the
blood lead concentration cut-off 4.79% of the time; 95.21% of the time blood lead levels will not
be exceeded.
Receptor Lead Level Estimations
The following concentration variables were used to obtain a mean blood level concentration of
6.31 ug Pb/dL for a future potential resident on-site:
• 0.278 ug/m3 in air (average minimum detection limit for lead);
• the program defaults for lead in the diet;
101
-------
• 116 ug Pb/1, average value from the RI in the drinking water, using defaults for daily
amount ingested by age;
• 160 ug Pb/g, average value from the RI in the soil;
• 64.8 ug Pb/g in the household dust, using the multiple source analysis option (28%
of the soil concentration and 100% of the airborne lead concentration);
• default of 0.00 ug Pb/day, assumed no exposure to leaded paint; and
• maternal blood lead concentration assumed the infant model.
The above variables exceed the blood lead concentration cut-off 60.28% of the time; 39.72% of
the time, the cut-off is not exceeded. The exceedance of 60.28% of the time will result in blood
lead levels that will adversely impact the health of children.
102
-------
APPENDIX B
EXPOSURE ASSESSMENT VARIABLES
AND ASSUMPTIONS
103
-------
Exposure Assessment Variables and Assumptions
All exposure assessments involve numerous assumptions and variables and are, therefore, by their
nature subjective. Conservative assumptions and variables have been used in this assessment
wherever feasible, thereby erring on the side of maximum exposure. The following tables present
all of the variables used to quantify each exposure for the ORC site.
104
-------
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TABLE - I 3
INCIDENTAL SEDIMENT SOIL/INGESTION PARAMETERS
Percent of Daily Exposure by Media'
Surface Subsurface
EF (davs) Soils Soils Sediments Total
7 33 33 33 100
90 50 0 50 100
268 100 00 100
TOTAL 365
Zeros indicate no exposures during that time period.
117
-------
APPENDIX C
RECEPTOR INTAKES AND CALCULATION OF
CARCINOGENIC RISKS AND NON-CARCINOGENIC
HAZARD INDICES
118
-------
INTAKES FOR EACH RECEPTOR
119
-------
CURRENT ACTUAL
OFFSITE RESIDENT (Adult t Child} INTAKES
DERMAL ABSORPTION (mg/kg-dty)
| CARCINOGENIC
| arsenic
| benzene
| benzo(a}anthracene
| benzo(a)pyrene
| benzo(b)fluor«nthene
| berylliuB
| ehrysene
| NOW-CARCINOGENIC
| 2,4-diwthylphenot
| 2-cnethyl phenol
| 2-methylnaphthalene
| 4-Mthyl phenol
| arsenic
| bar i ut
| berylliun
| cadniiM
| chroniui
| ethylbenzene
| lead
| wereory
| nickel
| phenanthrene
| phenol
| pyrene
1 cur> | sw |
| - | 0.00000000 (
| - | 0.00000000 |
| - | 0.00000000 |
| - | 0.00000000 |
| - | 0.00000000 |
| - | 0.00000000 |
| - | 0.00000000 |
| CW0) | SU |
| - | 0.00000230 1
| - ' 0.00001084 |
| - | 0.00000000 I
| - | 0.00001468 |
| - | 0.00000000 |
| - | 0.00000587 |
| - | o.oooooooo |
| - | o.oooooooo |
| - | o.oooooooo |
| - | o.oooooooo |
| - , o.oooooooo |
| - | o.oooooooo |
| - | o.oooooooo |
| - | o.oooooooo |
| - | 0.00000769 |
I - | o.oooooooo |
S/S0> | SED |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000054 |
| 0.00000000 |
SfS°> | SO) |
- | 0.00000000 |
| 0.00000000 |
I o.oooooooo |
| 0.00000000 |
| 0.00000000 |
- | 0.00036763 |
| 0.00000250 |
- | 0.00000000 |
- | 0.00004394 |
- | 0.00000000 |
| 0.00005551 |
— j 0.00000095 |
- t 0.00003144 |
| 0.00000000 |
t o.oooooooo |
| 0.00000000 |
SBS™ |
I
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I
I
I
»sn> |
I
I
I
I
I
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I
120
-------
CURRENT ACTUAL
OFFS1TE RESIDENT (Adult t Child) INTAKES
DERMAL ABSORPTION
| NON-CARCINOGENIC
| toluene
| xylene
| Zinc
• fll . • Ml
| CW ' ' | SV | SFS1 '
| - | o.oooooooo | -
| - | 0.00000000 | -
| - 1 0.00000354 | -
| SEO | StSn
| 0.00000000 |
| 0.00000029 |
| 0.00011677 | -
1
1
1
FOOTNOTES:
(1) Pathway not evaluated for this receptor
CU - Groundwater
SV • Surface Water
SFS - Surface Soil
SEE - Sediaent
SBS - Subsurface Soil
121
-------
CURRENT ACTUAL
OFFSfTE RESIDENT (Adult t Child) INTAKES
INCESTION
-------
CURRENT ACTUAL
OFFSITE RESIDENT (Adult t Child) INTAKES
INCEST ION (ng/kg-day)
| NON-CARCINOGENIC
| toluene
| xyleoe
| Zinc
FOOTNOTES:
| GW™ | SU | SFS°' | SED |
| - | o.oooooooo | - | o.oooooooo |
1 - | o.oooooooo | - | 0.00000012 |
| - | 0.00001881 | - | 0.00004278 |
»sn) I
1
I
I
(1) Pathway not evaluated for this receptor
GU - Grounduatcr
SU - Surface Water
SFS - Surface Soil
SED - Sediment
S8S - Subsurface Soil
123
-------
CURRENT ACTUAL
OFFS1TE RESIDENT (Adult I Child) .INTAKES
INHALATION
| CARCINOGENIC
| benzene
| NON-CA«CINOCENIC
| toluene
| xylene
1 AIR |
| 0.00000046 |
1 AIR 1
| 0.00000215 |
| 0.00000107 |
CUP) | $Uni |
I - I
cun) | $w(1) |
1 - 1
1 - 1
FOOTNOTES:
(1) Pathway not evaluated for this receptor
CW - GroUTdyater
SU - Surface Water
124
-------
FUTURE POTENTIAL
OtiSlTE UTRUDE* IHTACES
DERMAL ABSORPTION (Bg/kg-diy>
| CAXCINOGEMIC
| 1,2-dichloroethvw
| arsenic
| bwizen*
| benzo(«)«mhr»cent
| benzoU)pyrene
| benzo)fluor«nth«r»
| benzo(k)fluoranther»
| berytliim
| eadiiia
| chraaiut
| dirysent
| dibenzo(«h)*mhr»cene
|
-------
roOTMOTES:
FUTURE POTENTIAL
ONS1TE INTRUDER INTAKES
DERMAL ABSORPTION (ao/kg-day)
(1) Pathway not evaluated
CU • Groundwater
SU • Surface Water
SFS • Surface Soil
SEC - Sediaent
S8S • Subsurface Soil
for this receptor
| NON-CARCINOGENIC
| cadmiun
| chroaiui
| ethyl benzene
| fluoranthene
| fluorene
| lead
| mercury
| naphthalene
| nickel
| phenanthrene
| phenol
| pyrene
| toluene
| xytene
| Zinc
1 cu |
| 0.00000008 |
| 0.00000095 |
| 0.00000100 |
| 0.00000000 |
| 0.00000000 |
| 0.00000195 |
| 0.00000000 |
| 0.00000804 |
| 0.00000117 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000464 |
| 0.00000393 |
| 0.00000202 |
SU |
0.00000054 |
0.00000444 |
0.00001315 |
0.00000000 |
0.00000000 |
0.00001205 |
0.00000000 |
0.00000530 |
0.00002479 |
0.00000000 |
0.00038790 |
o.oooooooo 1
0.00001495 |
0.00001567 |
0.00003505 |
SFS |
0.00000013 |
0.00000624 |
0.00000002 |
0.00000000 |
0.00000000 |
0.00002301 |
0.00000022 |
0.00000000 |
0.00000134 |
0.00000018 |
0.00005300 |
0.00000021 |
0.00000002 |
0.00000002 |
0.00001638 |
SEB |
0.00000034 |
0.00057514 |
0.00001014 |
0.00000321 |
0.00000751 |
0.00066451 |
0.00000049 |
0.00001615 |
0.00000793 |
0.00003429 |
0.00000191 |
0.000029U |
0.00001232 |
0.00004256 |
0.00008280 |
»sn) |
I
I
I
I
I
I
!
I
I
I
I
I
I
I
I
126
-------
FUTURE POTEMTIAL
ONSITE 1NTRUDEI INTAKES
IMCESTIOM | SW(1) | SFS |
| - | - | 0.00000064 |
| - | - | 0.00000000 |
| - | - J 0.00000002 |
| - | - | 0.00000000 |
| - | - | 0.00000002 |
| ~" I ~ I 0.00000000 |
| - | - | 0.00000001 |
| - | - | 0.00000003 |
| - | - | 0.00000000 |
| — | — | 0.00000000 |
| CUm | SW0) | SFS |
| - | - | 0.00000223 |
| - J - | 0.000011U |
| - | - | 0.00000017 |
| - | - | 0.00004120 |
I - | - | o.oooooooo |
I - | - | o.oooooooo |
| - | - | 0.000004*4 |
| - | - | 0.00002200 |
| *" | "* | 0.00000000 |
| - | • | 0.00000007 |
1 - 1 - I 0.00000011 |
| - | ~ | 0.00000512 |
| - | - i e. 00000002 |
SO |
0.00000023 |
0.00000027 |
0.00000021 |
0.00000025 |
0.00000008 |
0.00000005 |
0.00000001 |
0.00000040 |
0.00000004 |
0.00000007 |
SEB |
0.00000032 |
0.00000031 |
0.00001117 |
0.00000039 |
0.00000052 |
0.00000059 |
0.00000160 |
0.00001346 |
0.00000188 I
0.00000009 |
0.00000006 |
0.00009891 |
0.00000174 |
«K01 I
1
1
1
1
1
1
1
1
I
1
SKm |
1
1
1
1
1
1
1
1
1
I
1
1
1
127
-------
FUTURE POTENTIAL
OMStTE IHTRUDEI INTAKES
IHGESTION <«s/ke-d«y>
| NON-CAftClNOCCMlC
| fluoranthene
| floorene
| lead
| aercury
| naphthalene
| nickel
| phenanthrene
| phenol
| pyrene
j toluene
| xylene
| line
FOOTNOTES:
| CU01 | SV<" | SFS |
| | - | o.oooooooo |
I | - | o.oooooooo |
| | - | 0.00001889 |
| 1 - | 0.00000018 |
| | 0.00000000 |
| | - | 0.00000110 |
| | - | 0.00000015 |
| | - | 0.00004351 |
| | - | 0.00000017 |
| - . - | 0.00000002 |
| - | - | 0.00000002 |
| - | - | 0.00001545 |
SEO |
O.OOOOOOSS |
0.00000129 |
0.0001 U29 |
0.00000008 |
0.00000278 |
0.00000136 |
0.00000590 |
0.00000033 |
0.00000506 |
0.00000212 |
0.00000732 |
0.00001424 |
MS™ |
1
1
1
1
1
1
I
1
1
1
1
1
(1) Pathway net evaluated for this receptor
CW - Grounduater
SV • Surface Water
SFS • Surface Soil
SCO • Sediment
S8S • S-•>-.-•!•* ace Soil
128
-------
FUTURE POTENTIAL
OHSITE INTKUDEt INTAKES
INHALATION (mg/kj-day)
| CARCINOGENIC
| NON-CARCINOGENIC
| toluene
| xylene
1 »« 1
1 »« 1
| 0.00000002 |
| 0.00000001 |
W0) | 9,™ j
CU | SW |
1 - 1
1 - 1
FOOTNOTES:
(1) Pathway net evaluated for this receptor
CU - Grmnduater
SU - Surface Water
129
-------
FUTURE POTENTIAL
ONSITE CONSTRUCTION WORKER (Acute) INTAKES
DERMAL ABSORPTION (ng/kg'day)
1
1
1
1
1
1
1
1
1
CARCINOGENIC
arsenic
benzene
benzo< a )*nthracene
benzo(a)pyrene
benzo(b) f I uoranthene
benzo( k > f I uoranthene
chrontim
chrysene
di benzo(ah )anthracene
indene(1,2,3 cd)pyrene
I GU |
| 0.00000001 |
| 0.00000009 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000002 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
SU |
00000003 |
00000002 |
00000000 |
00000000 |
00000000 |
00000000 |
00000000 |
00000000 |
00000000 |
00000000 |
SFS |
0.00000010 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000001 |
0.00000000 |
0.00000000 |
0.
0.
0.
0.
0.
0.
0.
0.
SCO |
00000004 |
00000004 |
00000003 |
00000004 I
00000001 |
00000001 |
00000000 |
00000006 |
0.00000001 |
0.
00000001 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
S8S
00000002
00000000
00000000
00000000
00000000
00000000
00000000
00000000
00000000
00000000
1
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NON-CARCINOGENIC
2,4-dinethylphenol
2-wethyl phenol
2-ftethylnaphthalene
4-«ethyl phenol
acenaphthene
anthrac'
arsenic
bariui
benzo(9,h, i )perylene
beryl Uu»
cadmiui
chronriin
ethylbenzene
I cw |
| 0.00000000 |
| 0.00000000 |
| 0.00001625 |
| 0.00000000 • |
| 0.00000000 |
| 0.00000000 |
| 0.00000098 |
| 0.00001276 |
| 0.00000000 |
| 0.00000017 |
| 0.00000010 |
| 0.00000127 |
| 0.00000133 |
su |
0.00002066 |
0.00006S76 |
0.00000072 |
O.OOOOS2S1 |
0.00000000 |
0.00000000 |
0.00000241 |
0.00000271 |
0.00000000 |
0.00000027 |
0.00000006 |
0.00000047 |
0.00000140 |
0
0
0
0
0
0
0
0
0
0
0
0
0
SFS |
.00000362 |
.00001810 |
.00000028 |
.00006690 |
.00000000 |
.00000000 |
.00000724 |
.00003573 |
.00000000 |
.00000012 |
.00000017 |
.00000831 |
.00000002 |
SEC |
0.00000051 |
0.00000050 |
0.00001814 |
0.00000063 |
0.00000085 |
0.00000097 |
0.00000260 |
0.00002186 |
0.00000305 |
0.00000014 |
0.00000009 |
0.00016064 |
0.00000283 |
0.
0.
0.
0.
0.
0.
0.
0.
sss
00000056
00000126
00000295
00000354
00000015
00000013
,00000139
00004653
1
1
i
1
1
1
1
1
1
0 00000000 ' I
0.00000017
0.00000008
0.00002589
1
1
1
0.00000155 |
130
-------
FUTURE POTENTIAL
OMSITE CONSTRUCTION WORKER (Acute) INTAKES
DERKAL ABSORPTION (mg/kg-day)
1
1
1
1
1
1
1
1
1
1
1
1
1
NON-CARCINOGENIC
fluoranthene
fluorene
lead
•ercury
naphthalene
nickel
phenanthreoe
phenol
pyreoe
toluene
xylene
Zinc
1 cu |
| 0.00000000 |
| 0.00000000 |
| 0.00000259 |
| 0.00000000 |
| 0.00001072 |
| 0.00000156 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000619 |
| 0.00000524 |
| 0.00000269 |
0
0
0
0
0
0
0
0
0
0
0
0
sv |
.00000000 |
.00000000 |
.00000128 |
.00000000 |
.00000056 |
.00000264 |
.00000000 |
.00004130 |
.00000000 |
.00000159 |
.00000167 |
.00000373 |
0
0
0
0
0
0
0
0
0
0
0
0
SFS |
.00000000 |
.00000000 |
.00003068 |
.00000029 |
.00000000 |
.00000179 |
.00000025 |
.00007067 |
.00000028 |
.00000003 |
.00000003 |
.00002184 |
0
0
0
0
0
0
0
0
0
0
0
0
SEC |
.00000090 |
.00000210 |
.00018560 |
.00000014 |
.00000451 |
.00000221 |
.00000958 |
.00000053 |
.00000822 |
.00000344 |
.00001189 |
.00002313 |
0
0
0
0
0
0
0
0
0
0
0
0
sts
.00000000
.00000024
.00003761
.00000006
.00000084
.00000379
.00000084
.00000511
.OOOOOOU
.00000298
.00000991
.00000981
I
I
I
I
I
I
I
I
I
I
I
I
I
FOOTNOTES:
CU - Grounduater
SW - Surface Water
SFS - Surface Soil
SEE - Sediacnt
S8S - S-'Tjrface Soil
131
-------
FUTURE POTENTIAL
OKSITE CONSTRUCTION WORKER INTAKES
INCEST ION (mg/kg-day)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
*<
1
1
1
1
1
1
1
1
CARCINOGENIC
arsenic
benzene
benzo(a)pyrene
chrysane
NON-CARCINOGENIC
2.4-dinethylphenol
2-nethyl phenol
2-nethylnaphthalene
4-nethyl phenol
acenaphthene
anthracene
arsenic
bariiB
benzo(g,h, i )perylene
beryllicm
eadBiui
chroaiut
ethylbenzene
f luoranthene
f luorene
lead
•ereury
naphthalene
nickel
| GW<" | SV(1) | SFS |
| - | - | 0.00000001 |
| - | - | o.oooooooo |
I - | - | o.oooooooo |
| - | - | 0.00000000 |
| CWP> | SU(T> | SFS |
| | - | 0.00000051 |
| | - | 0.00000257 |
| | - | 0.00000004 |
| -|_| 0.00000952 |
| | - | 0.00000000 |
| | - | 0.00000000 |
| | - | 0.00000103 |
| | - | 0.00000508 |
| | - | 0.00000000 |
| | - | 0.00000002 |
| | - | 0.00000002 |
| | - | 0.00000118 |
| - | - | 0.00000000 |
I - | - | o.oooooooo |
I - I - | o.oooooooo |
| - | - | 0.00000436 |
| - | - | 0.00000004 |
| - I - | o.oooooooo |
| - | - | 0.00000025 |
0.
0.
0.
0.
0.
SEC |
00000001 |
00000001 |
00000001 |
00000001 |
SED |
00000008 |
0.00000007 |
0.
00000266 j
0.00000009 j
0.00000012 |
0.00000014 |
0.00000033 |
0.00000320 |
0.00000045 |
0.00000002 |
0.00000001 |
0.00002354 |
0
0
0
0
0
0
.00000042 |
.00000013 |
.00000031 |
.00002720 |
.00000002 |
.00000066 |
0.00000032 |
0.
0.
0.
0.
0.
S8S
00000000
00000000
00000000
oooooooo
sss
00000004
0.00000010
0.
00000023
I
I
I
I
I
I
I
I
0.00000027 |
0.00000001 |
0.00000001 |
0.00000011 |
0.00000357 |
0.00000000
0.00000001
0.00000001
0.00000199
0
0
0
D
0
0
0
.00000012
•OOOOOOOO
.00000002
.00000289
.00000000
.00000006
.00000029
I
I
I
I
i
I
I
I
I
I
I
132
-------
FOOTNOTES:
FUTURE POTENTIAL
ONSITE CONSTRUCTION WORKER INTAKES
INGESTION (mg/kg-day)
1
1
1
1
1
1
1
NON-CARCINOGENIC
phenanthrene
phenol
pyrene
toluene
xylene
zinc
| CW(1) | SVPI | SFS |
| - | ~ | 0.00000004 |
| - | - | 0.00001005 |
| - | ~ | 0.00000004 |
| - | - | 0.00000000 |
| - | ~ | 0.00000000 |
| - | - | 0.00000311 |
0
0
0
0
0
SED
.00000140
.00000008
.00000121
.00000050
.00000174
1
1
1
1
1
1
0.00000339 |
0
0
SBS
.00000006
.00000039
1
1
1
0.00000003 |
0.00000023
0
0
.00000076-
.00000075
1
1
1
(1) Pathway not evaluated for this receptor
GU - Grounduater
SU - Surface Water
SFS • Surface Soil
SED • Sediment
SBS - Subsurface Soil
133
-------
FUTURE POTENTIAL
OUSITE CONSTRUCTION WORKER (Acute) INTAKES
INHALATION (ng/kg-day)
| CARCINOGENIC
| NON-CARCINOGENIC
| ethylbenzene
| naphthalene
| toluene
| xylene
I AIR |
I *>R |
| 0.00000000 |
| 0.00000000 |
| 0.00000001 |
| 0.00000001 |
CW |
• cw |
0.00000004 |
0.00000030 |
0.00000019 |
0.00000015 |
$wn) |
su(1) |
1
1
I
1
FOOTNOTES:
(1) Pathway not evaluated for this receptor
CW - Grotnbuater
SW - Surface Water
134
-------
FUTURE POTENTIAL
ONSITE CONSTRUCTION WORKER (Chronic) INTAKES
OERKAL ABSORPTION | SFS | SED(1) |
| - | | 0.00006457 | - |
| - | | O.OOOJ231S | - |
| - | | 0.00000498 | - |
|-| j 0.00119469 | - |
| - | _| 0.00012932 | - |
| - | | 0.00063806 | - |
| - | | 0.00000205 | - |
| - | | 0.00000308 | - |
| - | | 0.00014847 | - |
| - | | 0.00000045 | - |
| - | -| 0.00054778 | - |
| - | | 0.00000522 | - |
| - | | 0.00003200 | - |
| - | | 0.00000440 | - |
| - | | 0.00126188 | - |
| - | - | 0.00000507 | - |
wni |
I
I
1
1
1
1
SBS Pl |
1
1
1
1
1
!
1
1
1
1
1
1
1
1
1
1
135
-------
FOOTNOTES:
FUTURE POTENTIAL
OMSITE CONSTRUCTION WORKER (Chronic) INTAKES
DERMAL ABSORPTION (ng/kg-day)
| NON-CARCINOGENIC
| toluene
| xylene
| zinc
i - i
i - i
i - i
SW0> | SFS |
- | 0.00000045 |
- | 0.00000047 |
| 0.00038999 |
SEC0' | SBSn) |
1 - 1
(1) Pathway not. evaluated for this receptor
CW • Croundwater
SU • Surface Water
SFS - Surface Soil
SED - Sediment
S8S - St*>surface Soil
136
-------
FUTURE POTENTIAL
ONSITE CONSTRUCTION WORKER (Chronic) INTAKES
1NGESTION (mg/kg-day)
| CARCINOGENIC
| arsenic
f benzene
| benzo(a)anthracene
| b*nzo | SW'1' | SFS | SED(1> |
| - | _| 0.00002783 | - |
| - | _| 0.00013929 j - |
| - | | 0.00000215 | - |
| - | _ | 0.00051495 | - |
| _ | _ | 0.00005574 | _ |
| - | - | 0.00027503 | _ |
| _ | _ | 0.00000089 | _ |
| - | _ | 0.00000133 | - |
| - | - | 0.00006400 | - |
| _ | - | 0.00000019 | - |
| - j - | 0.00023611 | - |
| - | - | 0.00000225 | - |
| - | - | 0.00001379 | - |
| - | - | 0.00000190 | - |
| - | - | 0.00054391 | - |
| - | - | 0.00000219 | - |
SBS0) |
I
I
t
I
!
I
«m I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
137
-------
FUTURE POTENTIAL
ONSITE CONSTRUCTION WORKER (Chronic) INTAKES
INGEST ION (nig/kg-day)
| NON-CARCINOGENIC
| toluene
| xylene
| zinc
FOOTNOTES:
I CW(11 | SU'1' | SFS | S£D(1) | S8S<"
| ~ | | 0.00000020 | _ |
| ~ | - | 0.00000020 | „ | -
| ~ | - | 0.00016810 | _ |
<1) Pathway not evaluated for this receptor
CW - Crocnjuater
SU - Surface Water
SFS - Surface Soil
SED - Sediment
SBS - Subsurface Soil
138
-------
FUTURE POTENTIAL
CWSITE CONSTRUCTION WORKER (Chronic) INTAKES
INHALATION (ng/kg-day)
| CARCINOGENIC
| benzene
| NON-CARCINOGENIC
| toluene
| xylene
FOOTNOTES:
| AIR | GW (1) | SU (1'
| 0.00000005 | - | -
| AIR | OW0) | SW(1) '
| 0.00000020 I ~ | -
| 0.00000010 | ~ | -
(1) Pathway not evaluated for this receptor
GU - Grounduater
SW - Surface Water
139
-------
FUTURE POTENTIAL
ONSITE RESIDENT (Adult ( Child) INTAKES
DERMAL ABSORPTION (mg/kg-day)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
CARCINOGENIC
1,2-dichloroethan*
arsenic
benzene
b*nzopyrene
NON-CARCINOGENIC
2.4-diBethylphenol
{-•ethyl phenol
2-acthylr .nalene
i-a»thyl phenol
•cenaphthen*
anthracene
arsenic
baHta
benzo<9.h, i )perylene
berylliv*
1 GU 1
| 0.00000068 |
| 0.00000232 |
| 0.00001462 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000039 |
| 0.00000025 |
| 0.00000302 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
1 cu |
| 0.00000000 |
| 0.00000000 |
| 0.00018008 1
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00001083 |
| O.OOOU139 |
| 0.00000000 |
| 0.00000185 |
su |
0.00000000 |
0.00001930 |
0.00001179 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000216 |
0.00000000 |
0.00000000 |
0.00000121 |
0.00000000 |
0.00000000 |
su |
0.00077151 |
0.00245512 |
0.00002670 |
0.00308086 |
0.00000000 |
0.00000000 |
0.00009004 |
0.00010106 |
0.00000000 |
0.00001006 1
140
SFS |
0.00000000 |
0.00023041 |
0.00000081 |
0.00000795 |
0.00000000 |
0.00000814 |
0.00000000 |
0.00000366 |
0.00000000 |
0.00000000 |
0.00001250 |
0.00000000 |
0.00000000 |
SFS |
0.00053689 |
0.00268681 |
0.00004138 |
0.00993316 |
0.00000000 I
0.00000000 |
0.00107525 |
0.00530508 |
0.00000000 |
0.00001709 |
0.
0.
0.
0.
0.
0.
0.
SEO |
00000000 |
00003038 |
00003566 |
00002761 |
00003336 |
00001083 j
00000646 |
0.00000164 |
0.00000000 |
0.00000000 }
0.00005298 |
0.00000567 |
0.00000879 |
SEC |
0.00002804 j
0.00002716 ]
0
0
0
0
0
0
.00099089 |
.00003436 I
.00004632 j
.00005273 |
.00014180 |
.00119369 |
0.00016676 |
0.00000768 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
S8S
00000000
00000075
00000016
00000000
00000000
00000000
00000000
00000009
00000000
> 00000000
I
I
I
I
I
I
I
I
!
I
I
0.00000008 |
0*00000000
I
0.00000000 |
S8S
I
0.00000142 |
0.00000318 |
0.00000745 |
0
0
0
0
0
0
.00000892
.00000039
.00000033
.00000350
.00011733
.00000000
0.00000042
I
I
I
I
I
I
I
-------
FUTURE POTENTIAL
OMSITE RESIDENT (Adult I Child) INTAKES
OERKAl "ABSORPTION <«ig/kg-day)
1
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1
NON-CARCINOGENIC
cadaiin
chroniuB
ethylbenzene
fluoranthene
f luorene
lead
mercury
naphthalene
nickel
phenanthrene
phenol
pyrene
toluene
xylene
line
1 cu |
| 0.00000115 |
| 0.00001408 |
| 0.00001470 |
| 0.00000000 |
| 0.00000000 |
| 0.00002874 |
| 0.00000000 |
| 0.00011883 |
| 0.00001727 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00006859 |
| 0.00005810 |
| 0.00002983 |
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
su |
.00000214 |
.00001765 |
.00005229 |
.00000000 |
.00000000 |
.00004790 |
.00000000 |
.00002106 |
.00009855 |
.00000000 |
.00154194 |
.00000000 |
.00005943 |
.00006230 |
.00013934 |
0
0
0
0
0
0
0
0
0
SFS |
.00002560 |
.00123444 |
.00000370 |
.00000000 |
.00000000 |
.00455450 |
.00004342 |
.00000000 |
.00026605 |
0.00003658 |
0
0
0
0
0
.01049177 |
.00004218 |
.00000377 |
.00000391 |
.00324253 |
0
0
0
0
e
0
0
0
0
0
0
0
0
0
0
SCO |
.00000515 |
.00877368 |
.00015474 |
.00004898 |
.00011456 |
.01013714 |
.00000746 |
.00024640 |
.00012090 |
.00052315 |
.00002914 |
.00044911 |
.00018796 |
.00064926 |
.00126305 |
SBS
0.00000019
0
0
0
.00006527
.00000390
.00000000
0.00000060
0
0
.00009481
.00000015
1
1
1
1
1
1
1
1
0.00000211 ]
0
0
0
0
0
0
0
.00000955
.00000213
.00001287
.00000110
.00000752
.00002500
.00002472
1
1
1
1
1
1
1
FOOTNOTES:
CW - Groundwater
SU - Surface Uiter
SFS - Surface Soil
SQ> • Sediment
S8S • Subsurface Soil
141
-------
FUTURE POTENTIAL
ONSITE RESIDENT (Adult t Child) INTAKES
INGESTION (ng/ks-day)
| CARCINOGENIC
| 1,2-dichloroethane
| arsenic
| benzene
| benzo
-------
FUTURE POTENTIAL
ONSITE RESIDENT (Adult I Child] INTAKES
INGESTION (mg/kg-day)
1
1
1
1
1
1
1
1
1
I
1
I
1
1
1
1
NON-CARCINOGENIC
cactoium
chromiun
ethylbenzene
f luoramhene
f luorene •
lead
mercury
naphthalene
nickel
phenanthrene
phenol
pyrene
toluene
xylene
zinc
1 cw |
| 0.00069355 |
| 0.00847487 |
| 0.00885021 |
| 0.00000000 |
| 0.00000000 |
| 0.01729695 |
| 0.00000000 |
| 0.07150974 |
| 0.01039414 |
| 0.00000000 |
| 0.00000000 |
| o.oooooooo !
| 0.04127412 |
| 0.03496326 |
| 0.01795137 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
sw |
00000000 |
00001401 |
00015907 j
00000000 |
00000000 |
00005427 |
00000000 |
00001303 |
00000000 |
00000000 |
00004332 |
00000000 |
00016193 |
,00016405 |
00012809 |
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
SFS |
.00000909 |
.00043789 |
.00000131 |
.00000000 |
.00000000 |
.00161561 |
.00001541 |
.00000000 |
.00009438 |
.00001297 |
.00372175 |
.00001497 |
.00000134 |
.00000138 |
.00115023 |
0
0
0
.0
0
0
0
0
0
0
0
0
0
0
0
SCO |
.00000031 |
.00052869 |
.00000932 |
.00000295 |
.00000691 |
.00061086 |
.00000045 |
.00001485 |
.00000729 |
.00003152 |
.00000175 |
.00002706 |
.00001133 |
.00003912 |
.00007611 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
S8S
00000000
00000010
00000000
00000000
00000000
00000014
00000000
00000000
00000001
00000000
00000002
00000000
00000001
00000004
00000004
1
I
1
1
1
1
1
1
1
1
1
1
1
i
1
1
FOOTNOTES:
CW - Groundwater
SU • Surface Water
- SFS - Surface Soil
SED - Sediment
- SBS - Subsurface Soil
143
-------
FUTURE POTENTIAL
ONSITE RESIDENT (Adult I Child) INTAKES
INHALATION (ag/kg-day)
(1) Pathyay not evaluated for thit receptor
GU • Groundwater
SV - Surface Water
| CARCINOGENIC
| 1,2-diehloroethane
| benzene
| NON-CARCINOGENIC
| ethyl benzene
| naphthalene
| toluene
| xylene
FOOTNOTES:
1 AIR |
| 0.00000000 |
| 0.00000046 |
1 AIR |
| 0.00000000 |
| 0.00000000 |
| 0.00000215 |
| 0.00000107 |
GU |
0.00000037 |
0.00003646 |
GW |
0.00005808 |
0.00006596 |
0.00021033 |
0.00013746 |
sw"> |
1
1
sw'1' |
1
1
1
I
144
-------
CARCINOGENIC RISKS AND NON-CARCINOGENIC
HAZARD INDICES FOR EACH RECEPTOR
145
-------
CURRENT ACTUAL OFFS1TE RESIDENT (Adult t Child)
CARCINOGENIC R1SCS AMD NON-CARCINOGEN1C HAZARD INDICES
DERMAL ABSORPTION
| CARCINOGENIC RISKS | CU <1J
| arsenic | —
| benzene |
| benzo(a)anthracene | -
| benze<«)pyrene | —
| benzo(b)f luoranthene | —
| berylliuii |
| chrysene | -
| TOTAL IMPACTS | -
| NON-CARCIMOGENIC HAZARD INDICES | CW Ol
| 2,4-dimethylphenol | -
| 2-methyl phenol |
| 2-methylnaphthalene |
| 4-nethyl phenol | —
| arsenic | —
| b»riu» | -
| berylliun |
| chroaiui |
| ethylbenzene | -
| lead | -
| nercury |
| nickel |
| phenamnrene | -
(2)
\ su I
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
] 0.00000000 |
| 0.00000000 [
| 0.00000000 |
1 sw(2> |
| 0.00011498 |
| 0.00021665 |
| 0.00000000 |
| 0.00029366 |
| 0.00000000 |
| 0.00011748 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
146
SFS(" | seo<" |
| 0.00000000 |
— | 0.00000000 |
- | 0.00000000 |
- | 0.00000000 |
| 0.00000000 [
- | 0.00000223 |
- | 0.00000000 |
- | 0.00000223 |
SFS<" | SED"' |
- | 0.00000000 |
— | 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00735272 |
- | 0.00050019 |
| 0.00000000 |
- | 0.00878846 |
- | 0.00000000 |
- | 0.03964769 |
| 0.00317121 |
- | 0.00157158 |
| 0.00000000 |
S8S0) |
1
1
1
1
1
- ,
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
-------
OJRKEH1 ACTUAL OffSITE RESIDENT (Adult I Child)
CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARD INDICES
DERMAL ABSORPTION
j NON-CARCINOGENIC HAiARO INDICES |
| phenol |
| pyrene |
| toluene |
1 «yl«ne |
1 ii~ |
| TOTAL IHPACTS |
cv'1' | sw'" |
| 0.00001282 |
| 0.00000000 |
- | 0.00000000 |
- | 0.00000000 |
| 0.00001670 I
| 0.00077229 |
S«(1' | SB)'" |
- _ | 0.00000000 |
- | 0.00000000 |
— | o.oooooooo |
- | o.oooooou |
- | 0.00058389 |
~ 1 0.06161740 |
«s(1' I
I
1
1
1
1
1
FOOTNOTES:
(1) Pathway not evaluated for thU receptor
<2) In Gladys Creek and its tribut«rie»
GW - CreLr
-------
CURRENT ACTUAL OFFSITE RESIDENT (Adult 4 Child)
CARCINOGENIC RISKS AMD NON-CARCINOGEN 1C HAZARD INDICES
INCESTION
| CARCINOGENIC RISES
| benzene
| beruo(a)pyrene
| betue |
„ | 0.00000000 |
- | o.oooooooo t
— | 0.00000000 |
- | 0.00000000 |
- | 0.00000085 \
| O.OOOOOOOO |
- | 0.00000085 |
1
1
1
1
1
t
I
| MOM-CARCINOGEKIC HAZARD INDICES |
| 2,4-diaethylphenol 1
| 2-nethyl phenol |
| 2-«ethylnaphth*lene I
| 4-«ethyl phenol |
| arsenic |
| bantu |
| beryllium |
| cadniua I
| chreaiia |
| cthylbemene |
| Mercury 1
| nickel I
| phenartthrene 1
1 phenol I
cu | sw |
| 0.00064765 |
| 0.00122029 |
| O.OOOOOOOO |
| 0.00165401 |
| 0.00000000 |
| 0.00066170 |
| 0.00000000 |
| 0.00000000 |
_ | 0.00000000 |
_. | 0.00000000 |
_ | 0.00000000 |
_ | 0.00000000 |
| 0.00000000 |
_ | 0.00000000 |
_ | 0.00007220 |
148
SfS | SO |
- | 0.00000000 |
— | 0.00000000 |
- | 0.00000000 |
— | 0.00000000 |
- | 0.00000000 |
• | 0.00269406 |
| 0.00018328 |
— | o.onoooooo |
• I 0.00322012 I
— | 0.00000000 |
- | 0.01452704 |
- I 0.00116194 I
- | 0.00057583 I
— [ 0.00000000 |
— | 0.00000000 |
«n)
-
-
-
-
-
-
-
-
-
-------
CURRENT ACTUAL OfFSITE RESIDENT (Adult t Child)
CARCINOGENIC RISKS AND NOW-CARCINOGEN1C HAZARD INDICES
INGEST ION
| NOM- CARCINOGEN 1C HAZARD INDICES |
| pyrene |
| toluene |
I xylene |
I*- |
| TOTAL IMPACTS |
cw'1' | »«» | .«">
| 0.00000000 | -
| 0.00000000 |
- | 0.00000000 | -
| 0.00009407 | -
- | 0.00434992 |
1 SE,'" ,
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00021394 |
| 0.02236227 |
as"' |
1
1
1
1
1
FOOTNOTES:
(1) Pathway not evaluated for ttii» receptor
(2) In GlaOrs Creek and its tributaries
CU - Groundwater
SW - Surface Water
SFS - Surface Soil
SED - Sediaent
S8S - Subsurface Soil
149
-------
CURRENT ACTUAL OFFS1TE RESIDENT (Adult I Olild)
CARCINOGENIC RISKS ANO NON-CA8CIKOCENIC HAZARD INDICES
• INHALATION
I CARCINOGENIC RISES 1 AIR | CV |
**»•••....-.»...»..••"-•""•-*•• -•*«•»•«•*•........«...*.*•*••. ..*.*«.
| benzene | 0.00000001 | - |
».......---.......-»--•"•-••"---•-----•-----...--•.------.---.....•.
| TOTAL IMPACTS | 0.00000001 | - |
,ci"»"
| NON-CARCINOGENIC HA2ARD INDICES | AIR | GU | SW
*-••-•----------••---------•••--"*- --------•-.-.-.*.».»............*.»».
| toluene | 0.00000377 | - |
^....................-.-..-.--.-.-*----...-.--....-*.-.-,...-..-....*.»..
| xylene I 0.00001249 | - |
I TOTAL IMPACTS I 0.00001626 I - I
FOOTNOTES:
(1) Pathway not evaluated for tttii receotor
(2) In Gl»oV3 Creec »no its tributaries
CW • Croironter
SU - Surface Water
150
-------
FUTURE POTENTIAL ONSITE INTRUDER
CARCIKOGEW1C RISKS AND NON-CARCINOGENIC HAZARD IVDICES
DERMAL ABSORPTION
| CARCINOGENIC RISKS |
; arsenic |
1 benzene |
| benzo(a)anthracene |
| benzo(a>pyrene |
| benzo(b)f tuoranthene |
| benzo
-------
FUTURE POTENTIAL ONSITE INTRUDER
CARCINOGENIC RISKS AMD NON-CARCINOGENIC HAZARD INDICES
DERMAL ABSORPTION
| MOM-CARCINOGENIC HAZARD INDICES |
| ethylbenzene |
| fluoranthene |
| floorer* |
1 l««* 1
| mercury |
| naphthalene |
| nickel |
| phenantftrene |
| phenol |
| pyrene |
| toluene |
| xylene |
1 line |
| TOTAL IMPACTS |
GW |
0.00000995 |
0.00000000 |
0.00000000 |
0.00138961 |
0.00000000 |
0.00201075 |
0.00005845 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00002321 |
0.00000197 |
0.00001010 |
0.00784711 |
SW |
0.00013154 |
0.00000000 |
0.00000000 |
0.00860808 |
0.00000000 |
0.00132474 |
0.00123966 |
0.00000000 |
0.000646S1 |
0.00000000 |
0.00007475 |
0.00000784 |
0.00017527 |
0.07707935 |
SFS |
0.00000019 |
0.00000000 |
0.00000000 |
0.01643352 |
0.00073115 |
0.00000000 |
0.00006720 |
0.00004619 |
0.00008833 |
0.00000710 |
0.00000010 |
0.00000001 |
0.00008190 |
0.035U110 |
SED |
0.00010144 |
0.00008028 |
0.00018774 |
0.4746S237 |
0.00163019 \
0.00403798 |
0.00039628 |
0.00857336 |
0.00000318 |
0.00098134 |
0.00006161 |
0.00002128 |
0.00041398 |
0.63700979 |
as"' |
I
I
I
I
- - I
I
I
I
I
I
I
I
I
I
FOOTNOTES:
(1} Pc,.-»y not evaluated for this receptor
CU • GroundMatcr
SU • Surface Water
SFS - Surface Soil
SED • SediMnt
S8S - Subsurface Soil
152
-------
FUTURE POTENTIAL OWSITE INTRICER (Htnter)
CARCINOGENIC RISKS AMD NON-CARCUCGENIC HAiARC INDICES
1MCESTICN
(1)
| CARCINOGENIC RISKS | CW
j arsenic ] —
| benzene |
| benzo(a)antnracene |
| benzo(a}pyrene | ~
| benzo(b)f luorantnene | ~
| berylliun | ~
j chrysene | ~
j dibenzo(aft)antnracene j ~
1 inbeno<1.2,3 cdjpyrene | ~
i TOTAL IMPACTS | -
| MOM-CARCINOCENIC HAZAJtO IN01CES | CV(1>
; 2,4-aimetnylpnenoi | —
j 2-Mtnyl pnenol | -
| 2-nethylnaofithaiene | —
j 4-aethyl phenol | -
| acenaonttier | —
\ anthracene | —
] arsenic | —
j bariia [ —
j benzo(g.ft,i)perylene ] —
| berylliia | -
! caoBim | -
•
chroniuD | —
| ettiylbenzene | _
1 SW01 | SFS |
| - | 0.00000115 |
1 ~ | 0.00000000 |
| ~ | 0.00000000 |
| ~ | 0.00000000 |
| ~ | 0.00000002 |
| ~ | 0.00000004 |
I ~ ; o.oooooooo i
| ~ | 0.00000000 |
| ~ | 0.00000000 |
1 ~ ! 0.00000121 '
.
| SV01 | SFS |
| - | 0.00011153 |
| - | 0.00022286 |
| - 1 0.00004290 |
| - i 0.00823927 |
| - i 0.00000000 |
i - ! o.oooooooo |
| - | 0.00445946 |
1 - ! 0.00044004 |
1 - | o.oooooooo |
I - 1 0.00001417 |
! - ! 0.00021237 |
! - ! 0.00102393 |
| - | 0.00000015 |
SO |
0.00000041 |
0.00000001 |
0.00000003 |
0.00000289 |
0. (50000008 |
0.00000005 |
0.00000001 |
0.00000034 |
0.00000001 |
0.00000383 |
SEE |
0.00001581 |
0.00000612 |
0.00279282 |
0.00000775 |
0.00000870 |
0.00000198 |
0.00159865 |
0.00026915 |
0.00047000 |
0.00001732 |
0.00011598 |
0.01978280 |
0.00001745 |
SB'1' I
i
1
1
1
i
I
!
:
i
i
SKn) |
1
1
I
1
1
I
1
I
1
1
!
_ ^
>
!
153
-------
FUTURE POTENTIAL ONS1TE INTRUDE*
CARCINOGENIC RISES AND NON-CARCINOGENIC HAZARD INDICES
INCESTION
1
1
1
1
1
1
!
1
1
I
1
1
1
*
1
NO* -CARCINOGEN 1C HAZARD INDICES | GW
fluoranthene I ~
fluorene 1 "~
lead 1
•ereury 1 ""
naphthalene 1 ~
nickel 1
phenantnrene 1 ~
phenol 1 ~
pyrene 1 ~
toluene 1 ~
xylene 1 "~
line 1 ~
TOTAL IMPACTS 1 ~
1 sv" I
1 - | o.
1 1 o.
1 - | o.
1 - | o.
1 - I o.
1 - | o.
1 - | o.
1 - | o,
1 - | o
1 1 c
1 - | o
1 - | o
1 1 o
SFS |
00000000 I
oooooooo i
01349222 |
00060028 |
,00000000 |
,00005517 |
.00003772 |
.00007252 |
.00000583 |
.00000008 |
.00000001 |
.00006724 |
.02909775 |
SO |
0.00001381 |
0.00003229 |
0.08163253 |
0.00028037 |
0.00069447 |
0.00006815 |
0.00147448 |
0.00000055 |
0.00016877 |
0.00001060 |
0.00000366 |
0.00007120 1
0.10955541 |
$Ml" |
I
I
I
I
i
I
I
]
I
I
I
!
I
FOOTNOTES:
(1) Pathway not evaluated for this receotor
GU - jro*»cer
SW - Surface Water
SFS - Surface Soil
SEC - Sedioent
SBS • Subsurface Soil
154
-------
RflVRE POTENTIAL ONSITE INTRUDER
CARCINOGENIC RISKS AND NON-CARCINOGEN1C KAZARC INDICES
INHALATION
| CARCINOGENIC RISKS | AIR | CU(1) | Sv'1'
^.,.................-•-•----•-.-.-*•--.-.-....*....**...-».....*.....*............,
| TOTAL IMPACTS | 0.00000000 | - |
,•>....****».***•-.•*••**••*••*•-••• ••*- ••-•••-•-*«••« .*..*.„*.. »-»»».»..^...,.»»...»,,
«.....*....**...**..*».-••-**-••--«•*•••**•*••-•••-•*••*..•*....*•...«.....«.......
| NOW-CAKCINOCENIC HAZARD I HO ICES | AIR | GW™ | SWn)
«*.....*...*•*...•*.•••••***•*-*•»«•••-*•••*-*•'*••*•«•••..••.•.*.*...«.•.*......,..
| toluene | 0.00000004 | - |
| xytene | 0.00000012 | - |
*-...--.. .......*.*,.••••.•»•••••»«.•••**-*-*....**.«.»...*......*. ..*. ............
| TOTAL IMPACTS | O.OOOOOOU | - I -
FOOTNOTES:
--{1} Pathu»y not evaluated for this receptor
CU - GroindbMter
-SV • Surface water
155
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION UORKER (Acute)
CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARD INDICES
DERHAL ABSORPTION
| CARCINOGENIC RISES |
| arsenic |
| benzo(a)anthracene |
| benzo
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION WORKER (Acute)
CARCINOGENIC RISKS AND NON-CARCINOGEN1C HAZARD INDICES
DERHAl ABSORPTION
1
1
1
1
1
1
1
1
1
1
1
NON-CARCINOGENIC HAZARD INDICES | GU | SV |
•ercury
naphthalene
nickel
phenanthrene
phenol
pyrene
toluene
xylene
zinc
TOTAL IMPACTS
| 0.00000000 |
| 0.00268100 [
| 0.00007794 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00003095 |
| 0.00000262 |
I 0.00001346 |
| 0.01046283 |
0
0
0
0
0
0
0
0
.00000000 |
.00014104 |
.00013198 |
.00000000 |
.00006883 |
.00000000 |
.00000796 |
.00000083 |
0.00001866 |
0
.00820616 |
0
SFS |
.00097446 |
0.00000000 |
0
0
.00008960 |
.00006158 |
0.00011778 |
0
0
0
0
.00000947 |
.00000013 |
.00000001 |
.00010920 |
0.0472S479 |
0
0
0
0
0
0
0
0
0
0
SO) |
.00045531 |
.00112781 |
.00011068 |
.00239456 |
.00000089 |
.00027409 |
.00001721 |
.00000594 |
.00011563 |
.17791794 |
0
0
0
0
0
0
0
0
0
0
S8S
.00019727
.00020921
.00018948
.00021094
.00000851
.00001456
.00001492
.00000496
.00004904
.03633005
1
1
1
1
1
1
1
1
I
I
1
FOOTNOTES:
GU • Groindwater
SU • Surface Water
SFS • Surface Soil
SEO • Sediment
S8S - Subsurface Soil
157
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION WORKER (Acute)
CARCINOGENIC RlStS AMD NON-CARCINOCEKIC HAiASfl INDICES
1MCESTION
| CARCINOGENIC RISES | CU(1) |
! arsenic | — |
| beniooyrene | - |
| dibenzo(an)anthracene | - |
| TOTAL IMPACTS | - |
| NON-CARCINOGENIC HAZARD INDICES | GV (1> |
| 2,4-dimetnylprenol | - |
j 2-metnyl pnenol | — |
| 2-netnylnaohthalene | - 1
| 4 -methyl phenol | - |
| acenaontnene I - !
| anthracene 1 — 1
| arsenic I — 1
| banin | — |
i benio(s,h,i)p«rylene | - i
| berylliui 1 - |
!«•„. ! - 1
| chroaivn I - !
| ethylbenzene | — |
| fluorantnene | - |
| fluorene | - |
| leao 1-1
| mercury I - |
| naontnaiene | - |
| nickel | - |
SU"> | SFS |
| 0.00000002 |
— | 0.00000000 |
— | 0.00000000 |
| 0.00000002 |
SW(1) 1 SFS |
! 0.00002572 |
1 0.00005148 |
| 0.00000991 |
_ | 0.00190327 |
| 0.00000000 |
1 0.00000000 |
_ | 0.00103014 |
_ | 0.00010165 |
I 0.00000000 |
| 0.00000327 |
| 0.00004906 |
| 0.00023653 |
- | 0.00000004 |
- | 0.00000000 |
- ! o.oooooooo |
| 0.00311670 |
| 0.00013867 |
I 0.00000000 |
0.00001274 |
SO |
0.00000002 |
0.00000007 |
0.00000001 |
0.00000010 |
SED [
0.00000376 i
0.00000146 |
0.00066469 |
0.00000184 |
0.00000207 ]
0.00000047 |
0.00038048 |
0.00006406 |
0.00011186 |
0.00000412 |
0.00002760 |
0.00470831 |
0.00000415 |
0.00000329 |
0.00000768 |
0.01942SS4 |
0.00006673 |
0.00016528 |
0.00001622 |
SftS
0.00010662
0.00000000
0.00000000
0.00000000
. SBS
0.00000216
0.00000194
0.00005662
0.00000543
0.00000020
0.00000003
0.00010662
0.00007142
0.00000000
0.00000257
0.00001171
0.00039735
0.00000119
0.00000000
0.00000046
0.00206145
0.00001514
0.00001606
0.00001454
1
1
1
1
1
1
i
1
1
1
1
1
1
1
!
!
1
1
1
1
1
1
1
I
1
158
-------
FUTURE POTENTIAL CNSITE CONSTRUCTION WORKER (Acute)
CASC1NOCEKIC RISES AMD NON-CARCINOGEN1C KAZAKH INDICES
INCESTION
1
1
1
1
1
1
1
1
NON-CARCINOGENIC HAZARD INDICES | Cu"1 |
phenanthrene | - |
phenol | - |
pyrene | - |
toluene | ~ I
xylene | ~ |
line | - 1
TOTAL IMPACTS | - 1
SV™ | SFS |
| 0.00000876 |
| 0.00001675 |
| 0.00000135 |
| 0.00000002 |
| 0.00000000 |
| 0.00001553 |
| 0.00672159 |
0
0
0
p
0
0
0
SO |
.00035093 |
.00000013 |
.00004017 |
.00000252 |
.00000087 |
.00001695 |
.02607418 |
0
0
0
0
0
S8S
.00001619
.00000065
.00000112
.00000115
.00000038
0.00000376
0
.002788U
1
1
1
1
I
1
I
1
FOOTNOTES:
(1) Pathway not evaluated for this reeeotor
GU • Groundwater
SU • Surface water
SFS - Surface Soil
SED - Sediment
S6S - Subsurface Soil
159
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION UORCES (Acute)
CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZAJtO INDICES
INHALATION
| CARCINOGENIC RISKS |
| TOTAL IWACTS |
| NON-CARCINOGENIC HAZARD INDICES |
| toluene |
I xytene |
| TOTAL IMPACTS |
AIR | CU |
0.00000000 | 0.00000000 |
AIR | GU |
0.00000002 | 0.00000034 |
O.OOOOOOOe | 0.00000177 j
0.00000008 | 0.00000211 |
sw(" |
1
sw'1' |
1
I
1
FOOTNOTES:
(1) Pethtoy not eviluateo for this receptor
CU - Croundwater
SU - Surface Water
160
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION UORtER (Chronic)
CARCINOGENIC RISKS AND NON-CARCINOGEN 1C HAZARD INDICES
DERMAL ABSORPTION
| CARCINOGENIC RISCS | GW™ | SWf1)
j arsenic | — I ~
| benzene I ~ ! ~
1 benztfta Anthracene | " 1 ~
| benzo(a)pyrene | - " 1 ~
| ber\zo(b)f luoranthene ( ™ 1 ~
| beryUius | ~ 1 ~
| chrysene | ~ 1 ~
| TOTAL 1HPACTS 1 ~ 1 ~
| NON-CACCINOGENIC HAZARD INDICES | CW | SV
| 2,4-dimethylphenol | - 1
| 2 -methyl phenol | - 1 ~
] 2-methylnaonthaleoe | ~ ! ~
] 4-methyl phenol 1 ~ 1 ~
1 arsenic | ~ 1 ~
1 bariui | - 1
1 beryllium | — 1 ~
) cacniun 1 ~ 1 ~
| chroma | — I ~
| ethylbenxene | - 1 ~
| le«a | - I
| mercury 1 ~ 1 ~
| nickel 1 ~ 1 ~
| phenantnrene 1 " 1 ~
| pnenot 1 ~ 1 ~
1 SfS |
| 0.00009976 |
| 0.00000001 |
| 0.00000030 |
I o.oooooooo |
| 0.00000181 |
| 0.00000379 1
| 0.00000004 |
I 0.00010571 I
! SFS |
| 0. 0032286$ |
| 0.00646302 |
| 0.00124422 |
| 0.23893875 |
| 0.12932433 |
| 0.01276117 |
| 0.00041099 |
j 0.00615871 |
| 0.02969410 1
| 0.00000445 )
| 0.39127434 |
[ C.C174C42S |
] 0.00159994 |
| 0.00109969 I
| 0.00210313 |
S£D(1) | S8S'1' |
I - I
I - I
I ~ I
I - I
I - I
I - I
I - I
! - I
so'1' | sss™ |
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 - 1
1 . - 1
1 - 1
1 - 1
1 - 1
1 - 1
161
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION WORKER (Chronic)
CARCINOGENIC RISKS ANO MOM-CARCINOGENIC HAZARD INDICES
DERKAL ABSORPTION
| NON-CARCINOGENIC HAZARD INDICES | CU (1) | SW P'
I pyene | _ | -
| toluene | _ |
I xylene | _ |
| zinc | _ I
| TOTAL IMPACTS | _ I
| SFS | SED™ |
| 0.00016912 | _ |
| 0.00000227 | -. |
| 0.00000024 | . _ • |
| 0.00194995 | _ ,
{ 0.84563552 | _ |
S8Sfl) |
1
1
1
1
i
FOOTNOTES:
(1) Pathway not evaluated for this receptor
CU • Grouidwater
SW • Surface Water
SFS - Surface Soil
SED - Sediment
SBS - Subsurface Soil
162
-------
FUIUSE POTEKI1AL CWSJTE CONSTRUCTION WORKER (Cfironic)
CARCINOGENIC RISKS AND NON-CARCINOGEN 1C HAZARD INDICES
INGESTICN
f1) I (1) I . p] . fll f
I CARCINOGENIC RISKS | GU | SU J SFS | S£0 | S8S1 ' |
^» . . . ..............«.»..--_...-.--..•.--•>•••••••••••"---*•"•"•*-••"-••--*--»••-•--•••»•"•-- *»*•-• ........... .».*._....•.•.• ..•..•»
| arsenic | | - | 0.00004300 | | _ |
| bemo--..>••.-.**....•.......-....*..-...*.........*............... .«
| MOW-tAJiClNOCENIC HAZARD INDICES | CW(11 | SW01 | SFS | SO '^ | SgS(1> |
| 2.4'dimethylphenoi | ! - I 0.00159166 | - | _ |
«_...*...........*................«..•.-.....*-.»---*-.---»""--.-.-.-»-.--..-..-.--...»--.--.-......•................*..*.
| 2-metnyl phenol | - | - ! 0.00278578 | - | _ |
*•.....*.........*.................*..*.••...-..-*.•.*•...••-.*...••--•*.*..........**....*..... ........... ^*........ ...*...«
| 2-methylnaohthileoe | - | - I 0.00053630 | | _ |
| 4-methyl phenol i - I - i 0.10299084 | | _ |
1 arsenic I - I - I 0.05574325 | | A |
^......,.........*.........*......*..,......»......••••....*......*..«........._--*...*...........*....^................«
| - | - | 0.00550051 ] | - |
| - | - | 0.00017715 | | - |
caeniut I - I - i 0.00265461 | | - j
chrcntio I ~ I ~ I 0.01279918 | ~ j - j
ethylberwene | - | - | 0.00000192 | ~ I ~ I
leaa | - | - | 0.16B65273 | | - |
mercury | - 1 - j 0.00750356 | \ j
nickel I ~ I ~ ! 0.00068963 | | - j
phenantnrene I ~ I ~ I 0.00047401 | - | - j
phenol I -~ I ! 0.00090652 I | - ]
pyen. | - | - | C.00007290 | | - |
Y63
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION WORKER (Chronic)
CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARD INDICES
INGESTION
{ NON-CARCINOGENIC HAZARD INDICES | CW (1) [
| toluene | - |
I xylene | - |
1 Zinc | - |
| TOTAL IMPACTS | - |
» - * •»-
SU(1) | SFS | SED(1) |
| 0.00000098 | ~ |
| 0.00000010 | ~ |
| 0.00084050 | - |
| 0.36372213 | - |
SBS<" |
I
I
I
I
•FOOTNOTES:
(1) Pathway not evaluated for this receptor
GV • Groundwater
SV - Surface Water
SFS - Surface Soil
SEC • Sediment
S6S - Subsurface Soil
164
-------
FUTURE POTENTIAL ONSITE CONSTRUCTION WORKER (Chronic)
CARCINOGENIC RISKS AND NON-CARCINOGENIC HAZARD INDICES
INHALATION
CARCINOGENIC RISKS | AIR | CW(1)
TOTAL IMPACTS | 0.00000000 | -
| NON-CARCINOGENIC HAZARD INDICES | AIR | CWn>
| toluene | 0.00000034 |
| xylene | 0.00000114 |
*....... .-------"•"••-•-""••-••-•--'*-*--""-••••-"--•*----••-•----
| TOTAL IMPACTS | 0.00000148 | -
FOOTNOTES:
•(1) Pathway not evaluated for this receptor
GW • Grouidwater
"SW • Surface Water
165
-------
FUTURE POTENTIAL CNS1TE RESIDENT (Adult I Child)
CARCINOGENIC RISKS AMD NON-CARCINOGENIC HAZARD INDICES
DERMAL ABSORPTION
| CARCINOGENIC RISKS |
| 1,2-diehloro«th»n« |
| arsenic |
| benzene |
| benzo(a)anthracene |
| benzo(a)pyrene |
| benzo(b)ftuoranthene |
| benzo(k>f luoranchene |
| berylliin |
| ehrysene |
| dibenzo(ah)anthracene |
| indeno<1,2,3 edjpyrene |
| TOTAL IMPACTS |
| NON-CARCINOGENIC HAZARD INDICES |
| 2,4-dimethylpheool ~|
| 2-metnyl phenol [
| 2-nethytrupiunalene I
| 4 -methyl phenol |
| acenaghthene |
| anthracene |
| arsenic I
| bariun ]
| bemoO.h.Operylene |
| beryl lien |
cw I
0.00000006 |
0.00000417 I
0.00000042 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000171 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000656 |
G-J |
0.00000000 |
0.00000000 |
0.04501810 |
0.00000000 |
0.00000000 |
0.00000000 |
0.01082681 |
C. 00282790 |
0.00000000 (
0.00036956. |
» I
0.00000000 |
0.00003474 |
0.00000034 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000928 |
0.00000001 |
0.00000000 |
0.00000000 |
0.00004437 |
sw |
0.03257551 |
0.04910244 |
0.00667672 |
0.06161723 |
0.00000000 |
0.00000000 |
0.09004323 |
0.00202118 |
0.00000000 |
0.00201301 |
166
SFS |
0.00000000 |
0.0004H74 |
0.00000002 |
0.00000123 |
0.00000000 |
0.00000751 |
0.00000000 |
0.00001575 |
0.00000017 |
0.00000000 |
0.00000000 |
0.00043942 |
SFS |
0.02684427 |
0.05373609 |
0.01034492 |
0.19866314 |
0.00000000 |
0.00000000 |
1.07525371 |
0.10610144 |
0.00000000 |
0.00341717 |
SED |
0.00000000 |
0.00005468 [
0.00000103 |
0.00000427 |
0.00038460 |
0.00000998 |
0.00000053 [
0.00000707 |
0.00000073 |
0.00004511 |
0.00000174 |
0.00050954 |
SED |
0.00140196 |
0.00054317 1
0.24772305 |
0.00068724 |
0.00077208 |
0.00017578 |
0.14180007 |
0.02387380 |
0.04168870 |
0.00153619 |
SBS
0.00000000
0.00000135
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000039
0.00000000
0.00000000
0.00000000
0.00000174
ses
0.00007095
0.00006365
0.00186017
0.00017837
0.00000644
0.00000110
0.00350281
0.00234644
0.00000000
0.00008456
1
1
I
1
1
!
1
1
I
1
1
1
I
1
1
1
t
i
1
!
1
1
1
1
1
i
-------
FUTURE POTENTIAL OMS1TE RESIDENT (Adult I Child)
CARCINOGENIC RISICS ANO NON-CARCINOGENIC HAZARD INDICES
DERMAL ABSORPTION
1
1
1
1
1
1
1
1
1
1
1
1
!
i
1
1
i
NON- CARCINOGEN 1C HAZARD INDICES | GV |
cadmium
chromium
ethylbenzene
f luoranthene
fluorene
lead
mercury
naphthalene
nickel
phenanthrene
phenol
pyrene
toluene
xylene
zinc
TOTAL 1HP«"S
| 0.00230491 |
| 0.00281649 |
| 0.00014706 |
| 0.00000000 |
| 0.00000000 |
| 0.02052991 |
| 0.00000000 |
| 0.02970644 |
| 0.00086358 |
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.00034292 |
| 0.00002905 |
| C. 0001491 5 |
j 0.11593188 |
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
su |
.00428771 |
.00352969 ]
.00052288 |
.00000000 |
.00000000 |
.03421772 |
.00000000 |
.00526592 |
.00492774 |
.00000000 |
.00256991 |
.00000000 |
.00029714 |
.00003115 |
.00069672 |
.30639590 |
0
0
0
0
SFS |
.05120591 |
.24688848 |
.00003704 |
.00000000 |
0.00000000 |
3.25320973 |
0.14473906 |
0
0
0
0
0
0
0
0
5
.00000000 1
.01330253 1
.00914329 j
.01748628 |
.00140612 |
.00001889 |
.00000196 |
.01621265 |
.22801268 |
0
1
0
0
0
7
0
0
0
0
0
0
0
0
0
9
SED |
.01028743 |
.75473667 |
.00154749 |
.00122463 |
.00286396 |
.24S8159S |
.02486853 |
.06159930 |
.00604531 |
.13078655 |
.00004857 |
.01497030 |
.00093982 |
.00032463 |
.00631527 |
.7175764* |
0
0
0
0
0
S8S
.00038459
.01305434
.00003907
.00000000
.00001497
1
1
1
1
1
I
0.06772578 |
0
0
0
0
0
0
0
0
0
0
.00049737
.00052750
.00047774
.00053185
.00002147
.00003671
.00003762
.00001250
.00012364
.09159964
1
i
1
1
1
1
1
1
1
1
FOOTNOTES:
CW - Groirdwater
SW - Surface W»ter
SFS - Surface Soil
SED - Sediaent
S8S - Subsurface Soil
167
-------
FUTURE POTENTIAL ONSITE RESIDENT (Adult I Child)
CARCINOGENIC RISKS AND NOW-CARCINOCENIC HAZARD INDICES
INGESTICN
| CARCINOGENIC RISKS |
[ 1,2-dichloroethane |
| arsenic I
| benzene I
| b*nxo(a)anthracene |
| benzo(a)pyrene 1
| benio(b)fluoranthene |
| benzo(k)f luoranthene I
| berylliun |
| ehrysene 1
| e!ibenzo(ah)anthracene |
| indeno<1,2,3 ed)pyrene |
| TOTAL IMPACTS |
| NOW -CARCINOGEN 1C HAZAXO INDICES |
| 2,4-dimethylphenol |
| 2-metfiyl pnenol 1
| 2-methylnapfithalene I
| 4 -me thy 1 phenol I
| acenaonthene I
| anthracene I
| arsenic I
| barium {
j benio(g,n,; Jperyiene 1
| beryUiun I
cu |
0.00003741 |
0.00251316 |
0.00025514 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 j
0.00102465 |
0.00000000 |
0.00000000 |
0.00000000 |
0.003S3036 |
CW |
0.00000000 |
0.00000000 |
27.09203750 |
0.00000000 |
0.00000000 |
0.00000000 |
6.51561429 |
1.70184143 |
0.00000000 |
0.22240429 |
SW |
0.00000000 |
0.00014007 |
0.00000107 |
0.00000000 |
0.00000000 |
0.00000000 |
.0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00000000 |
0.00014115 |
» 1
0.00126730 I
0.00122029 |
0.01746137 |
0.0016S401 |
0.00000000 |
0.00000000 |
0.36319430 |
0.00220974 |
0.00000000 |
0.00000000 |
168
SFS |
0.00000000 |
0.00014713 |
0.00000001 |
0.00000044 |
0.00000000 |
0.00000266 |
0.00000000 |
O.OOOOOS5S |
0.00000006 |
0.00000000 (
0.00000000 |
0.00015588 |
SFS |
0.00952248 |
0.01906182 |
0.00366965 |
0.07047183 |
0.00000000 |
0.00000000 |
0.38142503 |
0.03763739 |
0.00000000 |
0.00121217 1
sen |
0.00000000 |
0.00000329 |
0.00000007 |
0.00000026 |
0.00002318 |
0.00000061 |
0.00000002 |
0.00000043 |
0.00000004 |
0.00000272 |
0.00000010 |
0.00003072 |
SED |
0.00008448 |
O.OOOC3273 j
0.01492760 |
0.00004141 |
0.00004652 |
0.00001059 |
0.00854476 |
0.00143861 |
0.00251213 |
0.00009257 |
SBS
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
S8S
0.00000011
0.00000010
0.00000286
0.00000027
0.00000001
0.00000000
0.00000539
0.00000360
0.00000000
0.00000013
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
I
!
1
1
!
1
1
1
1
1
-------
FUTURE POTENTIAL ONSITE RESIDENT (Adult t Child)
CARCINOGENIC RISKS AND NON-CARCINOGEN1C HAZARD INDICES
INCEST ION
| NON-CARCINOGENIC HAZARD INDICES | CU 1
1
!
1
1
1
I
1
1
1
1
1
1
1
I
1
1
c.cfciu*
chromiun
ethylbenzene
fluoranthene
fluorene
lead
mercury
naphthalene
nickel
phenantnren*
phenol
pyrene
toluene
xylene
line
TOTAL 11- '
\ 1.38710000 |
| 1.69497429 |
| 0.08850207 {
| 0.00000000 |
| 0.00000000 |
| 12.35496429 |
| 0.00000000 |
| 17.87743571 |
| 0.51970679 (^
| 0.00000000 |
| 0.00000000 |
| 0.00000000 |
| 0.20637061 |
| 0.01748164 |
| 0.08975686 |
| 69.76818977 |
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
sw 1
OOOOOOOO |
00280112 |
00159070 |
OOOOOOOO |
oooooooo !
03876384 |
OOOOOOOO j
00325770 |
OOOOOOOO |
,00000000 |
00007220 |
,00000000 |
,00080966 |
0.00008203 |
0.00064048 |
0.
43506474 |
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
*« 1
.01816428 |
.08757881 |
.00001314 |
.OOOOOOOO |
.OOOOOOOO |
.15401194 |
.05134332 |
.OOOOOOOO |
.00471881 (
.00324340 |
.00620291 |
.00049880 I
.00000670 |
.00000070 |
.00575112 |
.85453430 |
0
0
0
0
0
0
0
0
0
0
SO |
.00061991 |
.10573906 |
.00009325 |
.00007380 |
.00017258 |
.43632589 |
.00149855 |
.00371192 |
.00036429 |
.00788109 |
0.00000293 |
0.00090210 {
0
0
0
0
.00005663 |
.00001956 |
.00038055 |
.58557351 |
0
0
0
0
S8S
.00000059
.00002007
.00000006
.OOOOOOOO
0.00000003
0
0
0
0
0
0
0
0
0
0
0
.00010411
.00000077
.00000081
.00000073
.00000082
.00000003
.00000006
.00000006
.00000002
.00000019
.00014082
1
1
1
1
1
1
1
i
I
1
1
1
1
1
t
1
1
FOOTNOTES:
CU - Grourawater
SW • Surface water
SFS - Surface Soil
SEC • Sediaem
S8S - Subsurface Soil
169
-------
FUTURE POTENTIAL ONSITE RESIDENT (Adult t Child)
CARCINOGENIC RISES AMD NON-CARCINOGENIC HAZARD INDICES
INHALATION
I CARCINOGENIC RISKS | AIR | GW | SW*1' |
«... —. —... ....... ...+........... — ..*...... .......... ..........^
| 1.2-dichloroethane | 0.00000000 | 0.00000003 | - |
^. ........ —.....................+................*................»...-.....*...._.+
| beruene | 0.00000001 | 0.00000106 | - |
*....... — * . .. —......-».................+............ _...*.......... — -•.-*
| TOTAL IMPACTS | 0.00000001 | 0.00000109 I - I
» »....- » ».. ..........
»— - * - » » —*
I NON-CARCINOGENIC HAZARD INDICES | AIR | GW | Su''' |
* * - « » --«
| toluene | 0.00000377 | 0.00036899 | - |
»-•-- .............. .....*....... , ... .,
| xylene | 0.00001249 | 0.001S9&32 | - |
» • » * *
| TOTAL IMPACTS | 0.00001626 | 0.00196731 | - |
FOOTNOTES:
(1) Pathway not evaluated for this receptor
GW - Groundwater
SU - Surface water
170
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APPENDIX D
OKLAHOMA STATE DEPARTMENT OF HEALTH
CONCURRENCE LETTER
171
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Joan K. Leavitt, M.D. OKLAHOMA STATE
Commissioner DEPARTMENT OF HEALTH
Board of Health 1000 NE TENTH
John B. Carmichoel, D.D.S. Gordon H. Deckert, M.D. OKLAHOMA CITY, OK
President Don H. Fleker, O.O. 73117-1299
Ernest D. Martin, R.Ph. Undo M. Johnson, M.D.
Vice President Waller Soott Mason, III
Bordge F. Green, M.D. Lee W. Poden
Secretary-Treasurer
February 4, 1992
Allyn M. Davis
Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
Dear Mr. Davis:
In response to your letter of January 27, 1992, the Oklahoma State Department of Health (OSDH)
fully supports the Draft Proposed Plan for the Oklahoma Refining Company (ORC) Superfund site.
The Draft Proposed Plan, which provides for a combination of bioremediation, stabilization,
neutralization and recycling of contaminated soils and sediments and for containment and in-situ
bioremediation of contaminated groundwater, was arrived at through the concerted efforts of our
two agencies.
OSDH believes that the proposed remedy for the ORC Superfund site will provide long-term
protection for public health and the environment and is a safe and reasonable approach to the
remediation of contaminants at the ORC site.
OSDH IOUKS forward to our continued cooperative effort on the ORC Superfund site as we proceed
through Remedial Design and Remedial Action.
Sincerely,
* 7l ft /'
M&+
Mark S. Coleman
Deputy Commissioner
for Environmental Health Services
172
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