United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/024
September 1987
Superfund
Record of Decision:
Sand Springs PetroChem, OK
(Source Control O.U.)
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SAND SPRINGS PETROCHEMICAL COMPLEX
SAND SPRINGS, TULSA COUNTY, OKLAHOMA
SEPTEMBER 1987
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Sands Springs Petrochemical Complex, Tulsa County, Oklahoma. Source
Control Operable Unit.
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for this
site developed in accordance with Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the
extent practicable, the National Contingency Plan (40 CFR Part 300). -
The State of Oklahoma concurs with the on-site solidification and/or
stabilization and off-site thermal destruction of chlorinated «. ^anic
contaminants described in this Record of Decision. The State does not
concur with the on-site incineration concept proposed by EPA at the
start of the public comment period. (Letter attached)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Sand
Springs Petrochemical Complex Superfund Site [index attached]. The
attached index identifies the items which comprise the administrative
record upon which the selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The Record of Decision-addresses the Source Control Operable Unit,
which includes all surface liquids, sludges, and heavily contaminated
soils (within EPA's removal criteria), but does not include minimally
contaminated soil or groundwater. These aspects of the site will be
addressed in another Record of Decision at a later date.
After reviewing all available information, it is EPA's judgement that
on-site thermal destruction of wastes (Alternative 2 in the attached
"Summary of Remedial Alternative Selection") appears to meet more
statutory selection criteria than the other remedies evaluated but
has serious implementation problems. A description of this remedy and
an explanation of how it meets statutory requirements in conparison to
the other remedies is contained in the attached "Summary of Remedial
Alternative Selection."
During the public comment period, the ARCO Petroleum Products Company,
a division of Atlantic Richfield Company (ARCO), one of the potentially
responsible parties for this site, made written and verbal proposals
ror a privately financed remedy for the site. The most effective of
the ARCO proposals provides for:
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1) The excavation and off-site thermal destruction of sludges, at least
to the sludge/soil interface from the portion of the site identified
as the North and South Glen Wynn Lagoons.
2) Solidification and/or stabilization of all remaining sludges and
containment of the resulting matrix in a hazardous waste (RCRA) cell
to be constructed on-site. This cell (or cells) is to meet the
minimum technological requirements of subtitle C of the Solid Waste
Disposal Act.
3) As part of the remedial design ARCO will demonstrate that the
solidification technology wi11 meet EPA approved criteria. This
criteria will include both chemical and physical testing requirements.
Should the solidification technology fail these criteria; thermal
destruction will be the remedy for the above mentioned operable
unit.
4) No liability release for the site or from future maintenance and
monitoring.
5) Repair or restoration of the RCRA cell to ensure no migration from
the unit or destruction or treatment of all or a portion of its
contents, as EPA deems appropriate, should monitoring show that the
solidification and/or stabilization remedy fails.
This proposal is very similar to the solidification alternative evaluated
in the Feasibility Study for this site and in the attached "Summary of
Remedial Alternative Selection" (Alternative 3).
ARCO's proposed remedy appears to be technically feasible and able to
meet applicable, or relevant,and appropriate State and Federal require-
ments. Both the EPA and ARCO remedies are considered "alternative
technologies." ARCO's proposal would greatly reduce the mobility of
wastes, but unlike on-site thermal destruction, the toxicity of wastes
would not be reduced and the volume of wastes would be increased.
The ARCO" proposal has a lower initial cost than thermal destruction and
is supported by State and local agencies and residents.
The lack of demonstrated permanence of solidfied wastes is a concern
of the EPA. Unlike thermal destruction, which would eliminate organic
contaminants from future concern, the capability of solidification
or stabilization techniques to permanently bind high organic wastes,
such as those found at Sand Springs, has not been demonstrated in the
pilot studies conducted on-site. Even though the stabilization/solidi-
fication technology has not been conclusively demonstrated for high
organic wastes, EPA considers ARCO's proposal as a promising innovative
technology. ARCO has assured EPA that if the remedy fails, ARCO will
undertake corrective action.
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All factors taken into consideration, EPA concludes that the ARCO
proposal would provide for the protection of public health and the
environment comparable to the thermal destruction remedy if the effect-
iveness of this concept is adequately assured or if ARCO undertakes
the corrective actions deemed appropriate by EPA should the remedy fail.
DECLARATION
The above described remedy is protective of human health and the environment
attains Federal and State requirements that are applicable or relevant
and appropriate, and is cost-effective compared to equally environmentally
protective alternatives. This remedy satisfies the preference for
treatment that reduces toxicity, mobility, or volume as a principal
element. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
/ c^ 9*
Date Robert E. Layton Jr/ P.E.
Regional Administrator
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Sand Springs Petrochemical Complex (Source Control Operable Unit)
Record of Decision Concurrences
The Sand Springs Petrochemical Complex Record of Decision has been
reviewed and I concur:
Allyn M.*Davis, Director Cafl ^ETT feftrlnd, Chief \
Hazardous Waste Management Division Superfund Program Branch )
Hazardous Waste Managr nt Divirion
Stephen A.--Gilrein, Chief ^ Bonnie'J. DeVos, Chief
ALONM Remedial Section State Programs Section
Superfund Program Branch Superfund Program Branch
Hazardous Waste Management Division Hazardous Waste Management Division
Bennett Stokes, Chief
Solid Waste and Emergency
Response Branch
Office of Regional Counsel
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TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DECRIPTIQN
Site History 1
Geology 4
Remedial Investigation Results 5
Potential Impacts of Site on Human
Health and the Environment 6
II. ENFORCEMENT
Background 7
Pilot Studies 7
III. COMMUNITY RELATIONS HISTORY 8
IV. ALTERNATIVES EVALUATION
Evaluation Criteria 9
Description of Alternatives 12
Evaluation of Alternatives 13
Operation and Maintenance 18
Future Actions 18
V. APPENDICES
A. Tables 1-6
B. Agency for Toxic Substances and Disease Registry (ATSDR)/
Centers for Disease Control (CDC) Evaluation
C. Community Relations Responsiveness Summary
D. Administrative Record Index
E. State Concurrence Letter
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EXECUTIVE SUMMARY
The Sand Springs Superfund site is located in Sand Springs, Oklahoma.
The site is the former location of the Sinclair Refinery which operated
from the turn of the_ century through the 1940's. After the refinery
was shut down, most of the property was conveyed to the Sand Springs
Home. In 1968, Sinclair merged with Atlantic Richfield Company (ARCO)
and the remaining 38 acres retained by Sinclair were absorbed in the
merger. The portion of the complex identified in the Remedial
Investigation/Feasibility Study as the Glen Wynn site operated as a
solvent recycling facility during the late 1960's and early 1970's.
The total known waste volume is approximately 130,000 cubic yards.
Unlined sludge pits on the site contain several thousand cubic yards
of sulfuric acid sludge. In addition to these wastes, the lagoons,
pits, and spray ponds on the site contain various heavy metals and
organics.
The remedial alternatives evaluated focus on controlling or destroying
the source of the contamination. The Main Site Operable Unit will
address the remainder of the site, primarily the groundwater
contamination.
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Summary of Remedial Alternative Selection
Source Control Operable Unit for
Sand Springs Petrochemical Complex
Tulsa County, Oklahoma
September 1987
I. SITE LOCATION AND DESCRIPTION
The Sand Springs Petrochemical Complex Superfund site is located
in Sand Springs, Oklahoma. As shown in figure 1 the site is
located on the northern bank of the Arkansas River, immediately
west of Tulsa, Oklahoma. The site encompasses approximately 235
acres and is the former location of a refinery. As shown in figure
2, the site includes unlined acid sludge pits, a surface impoundment,
surficial sludge contamination, solvent and waste oil lagoons and
contaminated sediments. Figure 2 also shows several subsurface
sludge pits and spray ponds which were discovered subsequent to
the publication of the Source Control Operable Unit Remedial
Investigation and Feasibility Study. These areas will also be
addressed in this operable unit. Total known waste volume is
approximately 130,000 cubic yards. The site is situated in a
sandy alluvial deposit with a'thickness ranging from 26 to 52
feet. This deposit is underlain by approximately 100 feet of
shale. Pits and lagoons have contaminated shallow groundwater.
Site History
The site operated as a refinery from the turn of the century
through the 1940's. The property has since been developed as an
industrial area and consists of an abandoned solvent and waste oil
recycler, an active transformer salvage/recycler, active chemical
manufacturers and various other industries.
The Sinclair Refinery acid sludge pits resulted from refinery
operations which occurred between 1910 and 1949. Refinery operations
were shut down in 1949. By October' 1953, Sinclair had conveyed
most of the refinery property to the Sand Springs Home, with 38
acres still retained by Sinclair. In 1969, Sinclair merged with
the Atlantic Richfield Company (ARCO) and the 38 acre tract of
land was absorbed in the merger. In December 1986 the Chemlink
Division of ARCO, which occupies this property, was sold to
Pony Industries.
Several thousand cubic yards of sulfuric acid sludge, with a pH
ranging from 1.5 to 2.5 and containing heavy metals and organics,
exist in the unlined sludge pits. The sludge deposits on the
river side of the levee are of similar composition as the acid
sludge pits north of the levee.
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LOCATION
FIGURE 1
LOCATION MAP OF THE
SAND SPRINGS
PETROCHEMICAL COMPLEX
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-2
FIGURE 2
MAP OF THE SAND SPRINGS
PETROCHEMICAL COMPLEX
OPERABLE UNIT
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The surface impoundment, located between the large and small acid sludge
pits, drained surface water to the Arkansas River prior to contraction
of the levee. An analysis of the surface impoundment liquid, by the U.S. -
Environmental Protection Agency (EPA) in.1980 indicated a pH of 2.1 and
the presence of chrysene, anthracene, phenanthrene, pyrene, benzene,
1,1-difluorotetrachloroethane, toluene, phenol, nitrobenzene, and
fluoronaphalene.
An area designated in the studies as the "Glen Wynn" portion of the
site was a solvent recycling facility which operated during the late
1960's and early 1970's. During the period of operation hazardous
substances were stored or disposed of in drums, tanks, unlined pits and
lagoons or buried on-site. These substances include-various volatile
and non-volatile organics, chlorinated solvents, and sludges containing
heavy metals. Waste pits have contaminated local groundwater and caused
migration of surface contaminants. Samples from the north and south
Glen Wynn lagoons were collected in 1982. Samples from the south lagoon
showed significant contamination by chlorinated volatiles, benzene,
toluene, and numerous long-chain aliphatic hydrocarbons indicative of
oils. Lead and zinc levels were also high. Samples from the north
lagoon showed the same types of contaminants as the south lagoon.
However, sediments from the north lagoon have shown higher levels of
volatile organics and metals.
In September 1983 the site was proposed for inclusion on the National
Priorities List. Promulgation of the site was in June 1986. In June
1984, the Oklahoma State Department of Health (OSDH) entered into a
Cooperative Agreement with EPA to conduct the Remedial Investigation/
Feasibility Study (RI/FS) at the site. Utilizing funds from this
cooperative agreement, the OSDH contracted with John Mathes and Associates
to perform the sampling, analysis, and technical assessments of the
site.
In an effort to address the obvious contamination in an expeditious
manner, a source control operable unit was established to focus on the
waste in the pits, ponds, and lagoons. This Record of Decision deals
with those sources of- contamination. By placing a portion of the full
feasibility study on an expedited schedule the major sources of contam-
ination can be considered without waiting for completion of the full
FS. The remainder of the site, primarily the groundwater will be
addressed in the full or "Main Site" FS. The Remedial Investigation
report on Sludge and Surface Impoundment Sampling and the Source Control
Operable Unit Feasibility Study are dated April 1987.
Geology
The Sand Springs Petrochemical Complex is located in the alluvial
floodplain of the Arkansas River. The alluvial material consists
primarily of silts and fine-medium grain sands with an estimated
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permeability of 82-300 gallons per day per square foot. The depth of
the alluvial sands on the site ranges from 26 to 52 feet with the
thinner deposits occurring near the river. The groundwater flow
velocity in the alluvial materials is estimated to be in the range of
243 to 764 feet per year.
Underlying the floodplain alluvium is the Coffeyville formation. This
formation is composed of shales, thin ripply bedded sandstones, and
siltstones approximately 335 feet in thickness. From a regional
perspective, 70 percent of the formation is composed of shales. Included
in the upper half of the formation is a thick (20 - 50 feet) layer of
sandstone termed Layton Sandstone. This sandstone is readily identi-
fied in the rocky bluffs on the south side of the Arkansas River opposite
the site. Since the site is topographically lower than the sandstone
outcrops, this indicates that the upper portion of the Coffeyville
formation, including the Layton sandstone, has been eroded away in the
area of the Sand Springs Petrochemical Complex. The lower portion of
the Coffeyville is reported to be shale with thin tongues of sandstone.
Remedial Investigation Results
Eleven distinct waste disposal locations were sampled on the Sand Springs
Petrochemical Complex site. At these locations, numerous discrete
interval and composite samples were collected for chemical analysis.
These locations (Figure 2) are referred to as:
Surface Subsurface
o the small acid sludge pit o the round river pit
o the large acid sludge pit o the levee pit
o the river acid sludge pit o the spray ponds
o the South Glen Wynn lagoon o the Con-Rad sludge
o the North Glen Wynn lagoon
o the Chemlink waste pits
o the surface impoundment
The Source Control Operable Unit Feasibility Study considered the sludges
and liquids in seven identified surface pits, ponds and lagoons. Four
subsurface areas consisting of petroleum sludges and acidic sludges
were discovered during the Phase II boring and drilling activities. Soil
and groundwater data from beneath these identified areas indicate they
are sources or potential sources of groundwater contamination. For this
reason volume calculations for these areas were included by addendum to
the volume estimates in the Feasibility Study. Additional analytical
data may be developed during the design phase to further define these
wastes. The additional subsurface areas of sludges represent approximately
a 23 percent increase in volume. A cost sensitivity analysis had already
been developed based on a 25 percent increase in volume. Because the
additionally identified subsurface volume (23 percent increase) so
closely approximates the cost sensitivity analyses (25 percent increase)
no additional cost estimates have been calculated. The costs sensitivity
analysis estimates have been adopted for comparison of alternatives.
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Tables.1 and 2 show the compounds with the highest concentrations as a
result of samples collected from the eleven disposal locations. Lead
had the highest concentration (3,775 mgAg) of all the inorganic compounds
found in the solid samples, while tetrachloroethene had the highest
concentration (19,000 mgAg) of all the organic compounds. In the
liquid samples, chromium had the highest concentration (10,460 mg/1) of
the inorganic compounds found and Bis (2-ethylhexyl) phthalate had the
highest concentration (11 mg/1) of the organic compounds. The most
frequently detected organic priority pollutant compounds detected in
solid samples were chrysene and total xylene. Bis (2-ethylhexyl)
phthalate and toluene were the most frequently detected organic priority
pollutant compounds in the liquid samples. The inorganic compounds
most frequently detected in liquid and solid samples were lead, zinc,
chromium and barium.
A more detailed description of the analytical results can be found in
the Sand Springs Petrochemical Complex Remedial Investigation Report.
Potential Impacts of the Site on Human Health and the Environment
Based on the information gathered in studies of the site, EPA has
concluded that the site poses four major risks to human health and the
environment. These are:
1. Direct contact - many of the organic compounds (benzene, tetrachloro-
ethylene, and others) found on the site have been determined to be
carcinogenics. Absorption through the skin or other routes of
inadvertant ingestion therefore pose potential health risks. In
addition, the wastes and surface waters were found to be highly acidic.
2. Air emissions - consisting of acid fumes and volatile organic
compounds also pose potential health threats. An extreme example of
acute medical impact is evident in an accident that occured in 1980.
During excavation for sanitary sewer improvements on the west side
of the large acid sludge pit, sludge from the pit was uncovered and
a number of people required medical attention from breathing fumes
(probably sulphuric acid). During the remedial investigation, low
levels of trichloroethylene and sulphuric oxides were detected in
the ambien't air.
3. Surface waters - are polluted by the runoff from the site,
especially during heavy rains. There are 550,000 gallons of
contaminated liquids contained in the surface impoundment and
165,000 gallons of liquid in the Glen Wynn lagoons.
4. Groundwater - is being contaminated directly by the Glen Wynn
lagoons and indirectly by runoff from the main site. Relatively
clean sands were found beneath the main waste deposits above
underlying groundwater, indicating that direct contamination by the
main waste deposits does not appear to be significant. Large volumes
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of runoff water (in heavy rains the site is' submerged) do, however,
carry contaminants off the main waste deposits to mix with contaminants
from the other waste deposits. This eventually sinks into the ground-
water from standing pools of water in low places on-site.
It should be noted that the study of Sand Springs groundwater is being
carried out separately. EPA has determined however, that remedying the
identified sources of contamination will not conflict with the ultimate
remedy for the site.
II .ENFORCEMENT
Background
Approximately 300 Potentially Responsible Parties (PRPs) have been
identified at the site. Special notice may be provided to the PRPs
to conduct the -Remedial Design and Action.
. To date, two PRPs have taken action at the site; ARCO and the Sand
Springs Home. The Sand Springs Home, performed a removal action in
1984 under the terms of a Unilateral Administrative Order. ARCO
conducted pilot studies under an Administrative Order.
Pilot Studies
During the summer of 1987, ARCO conducted treatability studies on the
acid sludge wastes under an Administrative Order on Consent. - The
results of these studies were submitted to EPA on July 15, 1987, in
the "Interim Report - Acid Sludge Treatability Evaluations". This
document was placed in the repositories of information for review by
the public. The three treatment processes evaluated are thermal
treatment, stabilization, and solidification. A final version of the.
report was submitted on September 1, 1987.
The thermal treatment processes studied were infrared, rotary kiln,
fluidized bed, and circulating fluidized bed. The actual pilot tests
were conducted using an infrared incinerator, but the results of these
tests should be representative of the other processes. High temperature
incineration was used to destroy the acid sludges and scrub the combustion
gases. Indicator organic compounds, known as principal organic'hazardous
constituents (POHC's), were measured to determine if the incinerator
could attain a destruction and removal efficiency of 99.99% for organics.
This destruction and removal efficiency is required by RCRA for most
hazardous wastes. The results obtained from the pilot test verified
that the thermal treatment unit could attain the 99.99% criteria.
Stabilization was evaluated as a potential remedy for the acid sludges.
This technology uses 'a stabilizing agent, such as lime, to reduce the
mobility of the contaminants and increase the bearing capacity of the
mass containing the contaminants. The toxicity characteristics leaching
procedure (TCLP) was used to evaluate the performance of this technology.
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The analytical results show that without further treatment free liquid
contaminant concentrations were not reduced to meet RCRA land ban
restrictions. The unconfined compressive strength of the stabilized
material was determined by the EPA-Cincinnati laboratory to be 1.8
pounds per square inch (psi), which does not meet the recommended
disposal criteria requiring a compressive strength of 150 psi.
The pilot study of solidification involved mixing a cementing agent with
the waste to produce a brick-like material. This process is also used
to reduce the mobility of the contaminants and increase the bearing
capacity of the mass containing the contaminants. Although this process
meets the RCRA land ban requirements, leaching tests conducted by EPAs
Cincinnati laboratory show that the solidified material leaches contam-
inants, although leaching may diminish over time. Leaching of contami-
nants, and incomplete encapsulation raises questions about the long
term effectiveness and permanence of the process. Visual examination
of the solidified waste shows small globules of waste which are not
fully encapsulated.
III. COMMUNITY RELATIONS HISTORY
On July 24, 1984, the U.S. Environmental Protection Agency (EPA) issued
a news release announcing that funds had been awarded to the Oklahoma
State Department of Health (OSDH) to conduct the RI/FS at the Sand
Springs site.
The completion of the studies was announced to the public via news
releases issued by the OSDH on 'July 9, 1987, and by EPA on July 15, 1987.
The August 4, 1987, public meeting to discuss the proposed remedy for
the site was also announced. EPA prepared a fact sheet describing
alternative cleanup plans and the EPA preferred alternative which was
sent to the interested and affected public on July 29, 1987. The fact
sheet gave a brief site history, described the remedy selection process
and alternatives and gave details about the public comment period and
meeting.
The public meeting was held in Sand Springs on August 4, 1987. The
meeting was changed from the original public library location to the
City Council Chambers so that the large crowd of interested people
could be accommodated. About 180 people attended the meeting which
began at 7:00 pro and ended at midnight.
During the meeting, requests were made for EPA to extend the public
comment period. That request was granted by the presiding official
and the comment period was extended until September 1, 1987. A news
release was issued by the EPA on August 7 announcing the extension.
In addition to the Agency media list, the news release was mailed to all
persons known to have an interest in the site.
Community concerns centered on potential air pollution from thermal
destruction, potential adverse economic impacts on the city and whether
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EPA would guarantee that, if thermal destruction were selected, the
device would be removed after cleanup was completed. Further details
concerning Community Relations are contained in Appendix C.
IV. ALTERNATIVES EVALUATION
Evaluation Criteria
Section 121(a)(b) and (d) of the Superfund Amendments and Reauthorization
Act contains nine factors which EPA must consider in selecting a remedy
for a Superfund site. These are summarized below:
1. Consistency with Other Environmental Laws (ARARs)
In determining appropriate remedial actions at Superfund
' sites, consideration must be given to the requirements of other
Federal and State environmental laws, in addition to CERCLA as
amended by'SARA. Primary consideration is given to attaining
applicable or relevant and appropriate Federal and State public
health and environmental regulations and standards. Not all
Federal and State environmental laws and regulations are appli-
cable to each Superfund response action. The compliance of
each remedi-al alternative with all applicable or relevant and
appropriate environmental laws is shown in Table 3.
2. Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ trea-tment that reduces
toxicity, mobility, or volume must also be assessed. Relevant
factors are:
o The treatment processes the remedies employ and materials
they wi11 treat;
o The amount of hazardous materials that will be destroyed
or treated;
o the degree of expected reduction in toxicity, mobility,
or volume;
o The degree to which the treatment is irreversible;
o The residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bioaccumulation of such hazardous substances
and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed;
considering appropriate factors among the following:
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10
o Magnitude of reduction of existing risks;
o Short-term risks that might De posed to the community, workers,
or the environment during implementation of an alternative
including potential threats to human health and the environment
associated with excavation, transportation, and redisposal or
containment;
o Time until full protection is achieved.
"** Long-term Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness and
permanence they afford along with the degree of certainity that
the remedy will prove successful. Factors considered are:
o Magnitude of residual risks in terms of amounts and concen-
trations of waste remaining following inr°'i>meni':3t 'on of a
remedial action, considering the persistence, toxicity, mobility,
and propensity to bioaccumulate of such hazardous substances
and their constituents;
o Type and degree of long-term management required, including
monitoring and operation and maintenance;
o Potential for exposure of human and environmental receptors
to remaining waste considering the potential threat to human
health and'the environment associated with excavation,
transportation, redisposal, or containment;
o Long-term reliability of the engineering and institutional
controls, including uncertainties associated with land disposal
of untreated wastes and residuals;
o Potential need for replacement of the remedy.
5. Implementability
The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:
o Degree of difficulty associated with constructing the technology;
o Expected operational reliability of the technologies;
o Need to coordinate with and obtain necessary approvals and
permits (e.g., NPDES, Dredge and Fill Permits for off-site
actions) from other offices and agencies;
o Availability of necessary equiprnent and specialists;
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o Available capacity and location of needed treatment, storage,
and disposal services.
6. Cost
The types of costs that should be assessed include the
following:
o Capital cost;
o Operation and maintenance costs;
o Net present value of capital and 0 & M costs;
o-Potential future remedial action costs.
7. Community Acceptance
This assessment should look at:
o Components of the alternatives that the community supports;
o Features of the alternatives about which the community has
reservations;
o Elements of the alternatives which the community strongly opposes,
8. State Acceptance
Evaluation factors include assessments of:
o Components of the alternatives the State supports;
o Features of the alternatives about which the State has
reservations;
o Elements of the alternatives under consideration that the
State strongly opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against
individual evaluation criteria, the alternatives are assessed
from the standpoint of whether they provide adequate protection
of human health and the environment considering the multiple
criteria.
EPA is also directed by SARA to give preference to remedial
actions that utilize treatment to remove contaminants from the
environment. Off-site transport and disposal without treatment
is the least preferred option where practicable treatment tech-
nologies are available.
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Description of Alternatives
In conformance with the National Contingency Plan, initial remedial
approaches were screened to determine which might be appropriate for
this site. (See-the Feasibility Study for details of this evaluation)".
From these possible remedies, six alternatives were chosen for more
detailed evaluation and comparison with the remedy selection criteria
outlined above. Each is summarized below:
ALTERNATIVE 1, NO ACTION - This remedy consists primarily of
restricting public access to the contaminated areas and monitoring
the site. The areas would be secured using fencing and warning
signs. Site monitoring will involve air monitoring and an
established warning system for evacuation of the nearby public in
case contamination is detected above any applicable standards.
Groundwater and berra conditions will be monitored periodically.
The estimated cost to implement the "No Action" alternative is
3525,000.
All five of the remaining alternatives require excavation of the
contaminated materials. If any waste remains on-site, a landfill -
constructed in compliance with RCRA requirements will be used to reduce
groundwater infiltration and the chances of any contaminants migrating
off-site. In addition the site will be monitored for at least 30 years.
Each remedial action alternative also includes removal and treatment of
the liquids in the surface impoundments, the north and south Glen Wynn
lagoons and collected stormwater. Surface impoundment liquids and
liquids from the north and south Glen Wynn lagoons will be pumped
treated, and discharged.
The specified treatment unit will be capable of removing the metal and
organic contaminants from the liquids to result in concentrations that
comply with Federal and/or State standards for direct discharge to the
Arkansas River. Stormwater will be collected within the individual
areas as they are being remediated. It is assumed that the collected
stormwater will have similar or lower concentrations of hazardous
substances as the surface impoundment liquids and will be treated.in
"the same manner.
ALTERNATIVE 2, ON-SITE THERMAL DESTRUCTION - Involves removing
and -transporting the hazardous material to an on-site thermal
treatment unit. Materials handling will likely include hauling
the hazardous waste to the thermal destruction unit, possibly
adding chemicals to neutralize the low pH sludges, mixing the
waste and chemicals to make them as homogeneous as possible,
and reducing the solid materials to a suitable size for thermal
destruction. Stack gases will be scrubbed and treated prior to
atmospheric release. The residual ash will be tested, solidified,
and landfilled to comply with RCRA requirements, if necessary.
The estimated cost of this alternative is $67 million.
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ALTERNATIVE 3> SOLIDIFICATION AND ON-SITE LANDFILL - In general,
solidification technologies involve uniformly combining the
hazardous material with cementitious materials, such as Portland
cement or fly ash and letting the mixture harden. This remedy
involves neutralizing and excavating the hazardous material and
placing it in an on-site blending unit for mixing with the
solidification agent. The solidified mixture would be disposed of
in an on-site RCRA specification landfill. Prior to landfilling,
relevant tests would be performed to confirm the effectiveness of
the solidification technology. Implementation of this alternative
may produce a total volume increase of 50 to 200 percent that of
the original volume. A fence would be installed to restrict site
access and groundwater monitoring would be performed for at least
a 30 year period following closure. The cost of this alternative
is estimated to be $38 million.
ALTERNATIVE 4, ON-SITE SOLVENT EXTRACTION - This remedy entails
the excavation and neutralization of the hazardous sludges,
treatment in an on-site facility, and proper disposal of the
three by-products (oil, water, and solids). Solvent extraction
treatment includes sizing and pretreating the material prior to
extracting the oil with a solvent. Each waste stream of oil,
water, and solids will require sampling and analysis to determine
the appropriate method of disposal. This alternative would require
pilot studies prior to development of performance specifications
to determine the degree which products may be contaminated and how
to treat the oil, water, and solids product streams, if necessary.
The estimated cost of this remedy is $272 million.
ALTERNATIVE 5, OFF-SITE THERMAL DESTRUCTION - This remedy would
involve removal and transport of hazardous material to an off-site
thermal destruction unit in compliance with the Superfund off-site
policy. The description of the off-site thermal destruction
technology is similar to alternative 2. The estimated cost of
the remedy is $429 million. Transportation cost is the primary
reason for the cost differential between alternative 2 and
alternative 5..
ALTERNATIVE 6, OFF-SITE SOLVENT EXTRACTION - This rettedy is similar
to alternative 4, although it requires transporting the material
off-site to a treatment facility in compliance with the Superfund
off-site policy. The estimated cost of the off-site solvent extraction
alternative is $294 million.
Evaluation of Alternatives
The degree that the six remedial alternatives meet the nine selection
criteria is contained in Table 4. The following values were assigned
to compare remedial selection criteria:
++ Alternative would greatly exceed a selection criterion when
compared to other alternatives.
-------
14
+ Alternative would exceed a criterion in comparison to other
alternatives.
0 Alternative can be designed to meet the selection criterion.
- Special efforts will be necessary in the design of the remedy
to meet the selection criterion.
-- In comparison to other remedies, these alternatives would present
most difficulty in achieving a selection criterion.
The rationale for the ratings assigned in this table is as follows:
1. Complies with ARARS (i.e. meets or exceeds Applicable, or Relevant
and Appropriate Federal and State.Requirements).
a. No Action was assigned a "" because it would violate RCRA
corrective action requirements requiring remediation of a hazardous
waste site and does not comply with the National Contingency Plan
provisions to respond to a threat of release.
b. On-site Thermal Destruction was rated "+" based on the growing
body of knowledge the agency has about the ability of this process
to meet environmental standards and the highly incinerable
characteristics of waste at the site. In addition, an on-site
pilot test of a thermal destruction unit showed that 99.99%
destruction of organics (a RCRA requirement) was achievable
after fuel to air ratios were adjusted. All other standards (and
water quality standards) should be met as well.
c. On-site Solidification and Landfill was rated "-" for both the
solidification and stabilization processes evaluated broadly i-n
the Feasibility Study and in more detail in the field pilot
studies. The waste at this site contains 50% organic compounds
raising doubts about the ability of stabilized or solidified
waste to meet RCRA requirements in the long term. The "tabi1ization
pilot tests showed that stabilized waste may require a support
stricture* to support a RCRA cap due to low compressive strengths
(1.8 psi). It is recommended that Tandfilled solids attain- 150
psi if a cap is installed without a support structure. Liquids
(up to 40% by volume) separated from stabilized material would
require further treatment* before disposal to meet RCRA requirements,
The solidified waste contained visible chunks of waste from pea
to fist size and had a wide variation in compressive strengths
(from 180 to 650 psi). Tests to determine the long term ability
of the solidifying matrix to contain the waste were not conclusive
due to the lack of a reliable test methodology. A modified leaching
test (see ORD report) on pilot study samples did show obvious
degradation of the solidifying matrix following analyses for
total organic content.
* not included in Feasibility Study cost estimates
-------
15
Finally, available pilot project data indirectly points to the
potential for significant air emissions from both the solidification
and stabilization processes. Analysis of solidified or stabilized
waste shows that the quantity of low volatile compounds remained
unchanged in treated samples. Compounds with higher volatility
however, nearly disappeared. Tulsa County is designated by EPA
as nonattainment for ozone; the possibility of significant additions
of hydrocarbon compounds must be considered.
The net assessment is that solidification or stabilization processes
present difficult problems with respect to meeting ARARs.
*
. d. Other Alternatives were all rated "0" because all involved
treatment processes that can be designed to meet ARARs.
2. Reduces: Toxicity, Mobility, and Volume
a- No Action was rated "-" because it does nothing to reduce
any of these parameters.
b. Qn-site Thermal Destruction was rated "+" in each category because
this process would eliminate organic compounds that constitute
50% of the waste.
c. Solidification/Stabi1 ization was rated differently for each of
the parameters.
i. Mobil ity - was rated "-*" because pilot studies suggest this
remedy reduces mobility. It was not rated "++" because of
the possibility for leaching exists even though the contaminants
will be fixed to^a solidifying agent.
^- Toxicity - was rated "-" because none of the metals or
organic compounds were removed from the waste except
the elimination of possible air emissions.
iii. Volume - was rated "--" because of pilot data showing a
volumetric increase of 50% .to 200% for these remedial'
techniques.
d. Other Remedies - were all rated "+" because each involves removal
of the organic components of the waste.
3. Short-term Effectiveness
With the exception of the No Action remedy all alternatives were rated
at least "-" because of the potential for release of acid fumes or
other noxious gases during waste excavation. This problem can probably
be avoided by the use of foams, cautious work practices, or temporary
enclosures and will need to be addressed -in the design of the remedy.
-------
16
Off-site remedies were all rated "--" because, in addition to the
excavation problems, transportation of the waste off-site poses
additional environmental risks. No action was also, rated " "
because of the risk the site presents, as demonstrated by the water
company worker injuries.
4. Long-term Effectiveness and Permanence
The highest ratings; "++" were given to the thermal destruction
options since they entailed the destruction of organics and solidifi-
cation of any toxic ash. Solidified ash should be extremely stable
in the environment because the organic compounds will have been
eliminated. Lower ratings of "+" were given to the solvent extraction
options because slight inefficiences in the water-oil-solids separation
process will result in somewhat "dirtier" end products than the
thermal destruction techniques.. The solidification alternative was
given a "-" due to the general lack of proven effectiveness, pilot
study data, and doubts about the long term stability. The no action
alternative was rated "--" because of the risks involved with leaving
the untreated waste on-site.
5. Implementabi1ity
All alternatives that entailed the excavation of the waste were
rated at least "-" due to expected difficulties in materials handling.
These problems became apparent during the pilot studies and will
require attention during the design phase. The processes that would
treat the waste on-site are judged to each have the same degree of
implementability. Solidification and stabilization would likely
require waste to be more finely pulverized than many thermal
destruction techniques and require staging and curing areas with
associated leachate collection and treatement systems. On the other
hand, thermal destruction systems would require exhaust gas capture,
pollutant removal, and treatment systems that would not be required
by the solidification/stabilization techniques. Off-site remedies
received an additional "-" due to the added transportation problems.
6. Cost
Estimated costs for each remedial action alternative are summarized
in Table 5. Included in this table are total capital and implementation
costs, annual operation and maintenance costs, total present worth,
and replacement costs. Replacement costs were included to evaluate
the costs involved in remediation if the alternative were to fail.
The potential for failure was determined to be greatest for the on-site
solidification remedy, since the potential for contaminants leaching
from the -solidified material exists. Replacement cost is estimated to
be $100 million, assuming on-site thermal destruction is the replacement
clean up technology.
-------
17
The no action remedy has the lowest present worth of the alternatives,
but has an annual operating and maintenance cost of over $25,000.
This expense is due to groundwater monitoring, air monitoring, and site
inspections.
The projected cost for on-site thermal destruction is $67 million,
which is over $350 million less than off-site thermal destruction. The
primary reason for this difference is the higher cost that vendors
charge at permitted off-site facilities. These cost can be attributed
to off-site permitting requirements and the liabilities incurred by the
operators.
The o'n-site solidification alternative was estimated to cost $38 million.
The largest portion of this cost can be attributed to construction and
implementation expenses.
Transportation costs are the primary reason for the difference in the
cost between on-site and off-site solvent extraction. Although on-site
solvent extraction is less expensive than off-site solvent extraction,
the on-site versfon also requires annual operation and maintenance
which is not required for off-site treatment.
7. Community Acceptance
At the public meeting on August 4, 1987, the residents' comments centered
on the on-site thermal destruction and the solidification alternatives.
There was general agreement favoring some form of remedial action for
the site.
The community was concerned that the site would, be used in the future
to destroy hazardous waste from other sites, that the thermal destruction
option would add to existing air pollution and that the local economy
might suffer from the presence of a hazardous waste incinerator. Some
residents favored destruction of the waste, however. Because of the
aforementioned concerns; the on-site thermal destruction option was rated
as less acceptable to the community than solidification/stabilization.
On-site thermal destruction received a rating of "-", while the
solidification remedy received a rating of "+". A rating of "0" was
given to the other remedial alternatives due to a lack of comment about
these options.
8. State Acceptance
The Oklahoma State Department of Health cited concerns similar to those
voiced by residents. Likewise, the on-site thermal destruction remedy
received a rating of "-", the solidification remedy received a rating
of "+", and all other remedies were rated "0".
9. Overall Protection of Human Health and the Environment
On-site and off-site thermal destruction received the highest rating of
"++". Thermal treatment results in elimination of the contaminated
-------
18
material. The thermal treatment unit will be designed to meet RCRA
standards. It is possible that noxious gases will be given off by
excavation activity, but a contingency plan will be developed to address
this problem. That level of destruction required by RCRA, 99.99% of tne
organic contanination, should be destroyed. Solidification of the fly
ash that might contain metals, has been shown to be very stable in the
environment.
On-site solidification was given a lower rating of "+". This rating is
largely due to the fact that the source of the contamination will not be
destroyed and the potential for leaching of contaminants exists.
On-site and off-site solvent extraction were given a rating of "0".
Solvent extraction would separate the oil, water and solid phases but
may require further treatment of each waste stream to meet RCRA disposal
criteria, "i ne contaminants will not be destroyed and the potential for
future exposure exists.
The risk involved with leaving untreated waste on-site is the
principal reason that the no action alternative received a rating
of "--".
Operation and Maintenance (O&M)
The need for future operation and maintenance will be minimized since
the source of the contanination will be removed. Site operation and
maintenance will include a monitoring well sampling and analysis
program. Additional site maintenance will entail the inspection of
surface vegetation, periodic repair of the perimeter fencing, and
inspection ~of the on-site RCRA landfill. The State of Oklahoma will be
responsible for the cost of 0&M for a period of at least 30 years after
the completion of the remedial action.
Future Actions
No future actions are anticipated for the Source Control Operable Unit.
Future groundwater remediation will be addressed in the Main Site
Operable Unit. The proposed remedial action is considered-permanent.
If, however, significant, unforeseen, off-site migration or contamination
occurs as a result of the site, appropriate remedial measures will be
taken.
Remedial Action Schedule
Approve Remedial Action (sign ROD) September 1987
Complete Enforcement Negotiations January -1988
Obligate Funds (Start Remedial Design) January 1988
for State or US Army Corps of Engineers
to Conduct Remedial Design (assuming
the PRPs do not take over)
Complete Design March 1989
Obligate Funds to Start Remedial March 1989
Action
Complete Remediation November 1991
-------
APPENDIX A
-------
COMPOUND CC
:ENTBATIONS FOR SOLID SAMPLES
H i g h e s t
Co ne'er, t r a 11<
"Inorganic
Compounds
(mg/kg
Small acid
sludge pit
Large acid
s 1 udge pit
River acid
sludge pit
South Glen
Wvnn laaoon
North Glen
Wynn lagoon
Cheml ink
waste pits
Surface
i mpoundren t
Lead*
Bar i um
7 ' n " *
L, » r. -
Lead*
Barium
Chromium*
Zinc*
Lead*
Chromium*
Lead*
Zinc*
Barium
Lead*
Zinc*
Copper*
Bar i um
Lead*
Zinc*
Zinc*
Lead*
Ba r i um
317
66
38
617
239.
235
235
192
151
2,022
1,845
760
3,775
- 3,422
2,745
164
27
23
3,504
2,077
1,246
.5
.5
.9
.5
.. 1
.6
.9
.8
.1
.5
.8
.4
.7
.Highest3
Concentration
Organic
Compounds
(mg/kg)
Benzoic acid 1,700
Chrysene* 240
Total Xylene 81
Chrysene* 480
Benzo(a)pyrene* 390
Benzoic acid 240
Chrysene* ' 57.0
Total Xylene 24 .0
Phenanthrene* 18.Ob
Tetrachloroethene* 19,000
Trichloroethane* 3,400
Total Xylene 5,400
Toluene* 3,500
Tetrachloroethane* 3,000
Total Xylene 2,300
Total Xylene 380
4-methyl-2-pentanone 350
2-methylnaphthalene 130
2-methylnaphthalene* 300
p-chloro-m-cresol* 260
bis-(2-ethylhexyl)
phthalate* 240
a
fa-
Priority Pollutant Compound
Tentatively identified compounds were not included
(e.g. , hydrocarbons)
An estimated value
-------
.-ABLE 2
HIGHEST COy.-?3'JNO CONCENT-RATIONS FOR LIQLTD SAMPLES
Highest Concentration
Inorganic Compounds
(mg/1 ) -
South Glen
Wynn lagoon
Zinc*
Barium
Lead*
North Glen
Wynn laj -on
Chromium*
Zinc*
Lead*
Surface
impoundment
Zinc*
Lead*
Barlum
627
596
593
10,460
5,873
2,692
742
366
189
Highest5 Concentration
Organic Compounds
(mg/1)
Bis(2-ethylhexyl )phthal-ate*
trans 1,2-dichloroethene*
Toluene*
Toluene*
Bis (2-ethyhexyl'Jphthalate*
trans 1,2-dichloroethene*
Chrysene*
benzo(a)pyrene*
bis(2-ethyhexyl
11.0
1.20
0.620
0.490
0.330
0.280
phthalate*
0 .040
0.0076
0 .0049
* Priority Pollutant Compound
a Tentative.ly identified compounds not included
hydrocarbons)
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-------
TABLE 6
Anticipated Excavations
Location
Contaminated
Interval
Smal 1
Large
River
South
North
Acid
Acid
Acid
Glen
Glen
Pit
Pit
Pit
Wynn
Wynn
Lagoon
Lagoon
Chemlink Waste Pits
Round R-: .ar Pit
Levee Pit
East Spray Pond
West Spray Pond
Con-Rad Sludge
Surface Impoundment Sediments
0 to 6'
0 to 6'
0' to 8'
0' to 5'
0 to 2'
0' to 1'
0' to 16
3' - 10'
4' - 8'
2' - 8'
o1 to r
0' to 1'
- 9'
- 9'
- 10'
- 7'
- 3'
- 2'
' - 18
- 8'
- 2'
Estimated
Volume
14,489
46,775
37,995
1,133
648
627
2,844
4,537
1,589
3,756
8,889
2,055
TOTAL 125,337 cu. yds,
South Glen Wynn Lagoon
North Glen Wynn lagoon
Surface Impoundment
Contaminated Liquids
76,300
89,000
545,987
TOTAL 711,287 gals,
-------
APPENDIX B
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Agency for Tox.c Substances
and Disease Registry
Atlanta GA 30333
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APPENDIX C
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Sand Springs (Petrochemical Complex)
Sand Springs, Oklahoma
Responsiveness Summary
This Community Relations responsiveness summary is divided into
two sections:
Section I: Background on Community Involvement and Concerns. This
section provides a brief history of community interest and
concern raised during the remedial planning activities at
the Sand Springs Superfund site.
Section II: Summary of Major Comments Received during the Public
Comment Period and the EPA Responses to the Comments.
Both written and spoken comments are categorized by
topics. EPA responses to these relevant major topics are
also presented.
I. Background on Community Involvement
The Sand Springs Petrochemical Complex Superfund site lies three
miles west of Tulsa along the Arkansas river, in the city of Sand
Springs, Oklahoma. The site is in an industrial complex with no
residential neighborhoods nearby. There is one family living
within the site boundaries.
During the August 1984 on-site assessment conducted by the OSDH,
every business and industry occupying the site was contacted along
with the resident family. Many people expressed concern about acid
pits from the old on-site refinery. Concern was expressed about an
incident where construction activities exposed part of one pit and
the released fumes caused a factory to be evacuated. Several
people required medical attention. The family living on site
expressed concern about the poor quality of groundwater. They had
drilled two wells, neither-of which could be used because of the
poor water qua!ity.
On the afternoon of August 4, 1987, officials of the EPA met with
Sand Springs city officials to brief them about the results of the
studies on the site and discern EPA's preferred remedy. Among
those in attendance were Mayor George Hooper, city Manager
Loy Calhoun, Chamber of Commerce representative Jim Dougherty,
County Commissioner John Selph and some fifteen other officials.
During the meeting a great deal of concern was expressed that if
EPA finally selected on-site incineration as the remedy, considerable
economic hardship could be suffered by the city. It is believed
that incineration going on in Sand Springs would discourage new
business from locating in the city. Further fears were expressed
that once an incinerator was on-site, it could be used to incinerate
hazardous materials from other sources. The leadership was adament
that the people of Sand Springs would not want that outcome.
That evening at 7:00 p.m., the public meeting was scheduled to
begin at the Page Memorial Library. So many people arrived that
the Mayor and City Manager offered the City Council Chambers. The
presenters and audience went across the street to the city offices
and the meeting commenced; Some 180 people were in attendance.
-------
II. Summary of Major Comments Received during the Public Comment
Period and the EPA Responses to the Comments.
1. Comment: There is not a good estimate of the amount of contaminated
soils on-si.te.
Response: EPA disagrees. Sufficient information has been gathered
to formulate a decision on basic clean up concept. Additional
information will be gathered during design studies, to the extent
it is need, to accurately fix construction specifications.
2. Comment: EPA failed to provide sufficient time to reivew and
evaluate the impact on the plan by the community and by potentially
responsible parties (PRPs).
Response: A two week public notice and three week public comment
period was provided. As a twenty one day public comment period is
required by the National Contingency Plan. In addition, a two
week extension to the public comment period, for a total of seven
weeks, was provided. In addition, separate notices were sent to
the PRPs to alert them to the impending decision though not
required by the statute or regulations. Design plans will not
commence until PRP's have been given time to indicate whether
they wish to take over the project. Most of the questions
raised by the public relate to design issues and will be the
topic of the future public meetings as the design plans progress.
3. Comment: Little or no consideration has been given to the horrendous
cost imposed on private industry that is obviously passed on to
the consumer.
Response: EPA disagrees with this conclusion; cost effectiveness
is a major consideration in selecting a remedy. The Comprehensive
Environmental Response Compensation and Liability Act (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and the National Contingency Plan of 1985 (NCP) requires
consideration of cost from the standpoint of eliminating higher
costs alternatives when comparing alternatives which are equally
protective of public health and the environment.
4. Comment: EPA has failed to give adequate consideration to the
potential environmental and health risks that would be imposed by
the thermal destruction process.
Response: EPA disagrees with this conclusion. Much more information
is available regarding the reduction and control of emissions
from thermal treatment processes. Furthermore, standards for
emissions have been set and'can be met with the thermal treatment
process. Volatile organic releases, reactive processes and
controllability of emissions from the stabilization and solidi-
fication processes are not as well known.
-------
5. Comment: EPA has failed to give adequate consideration to the potential
economic and social impact on the community which would be imposed by the
thermal destruction process.
Response: Concerns of the local community have been incorporated into this
Record of Decision and will be addressed in more detail in the design of
the remedy. The thermal destruction system has been defined as a temporary
operation that will be removed from the site. The design wi.ll ensure that
the operation of this system will be environmentally sound and unobtrusive.
Wastes from other sites will not be treated at Sand Springs. Finally, by
eliminating the exposed hazardous waste, EPA believes that the community
will benefit socially and economically as well.
6. Comment: "Solidification would more effectively deal with the problem of
a majority of the waste and would protect public health and environment
without air, water and hazardous ash generated by incineration at a
drastically lower cost."
Response: While a hazardous waste landfill of solidified waste would protect
public health in the short term, the long term stability of this material
is not proven.
7. Comment: What guarantee is there to the citizens of Sand Springs that the
site will not be used as a commercial incinerator for wastes from other
sites in the future?
Response: The EPA proposal stated that the thermal destruction unit would be
used only during remedial activities at the Sand Springs site and would be
dismantled and removed from the site following those activities.
8. Comment: Citizens need a written guarantee that the thermal destruction unit
will operate 99.99 percent efficiently all the time.
Response: If employed, states that the thermal destruction unit will be
required to meet the 99.99 percent combustion standards of RCRA in addition
to all State and Federal emissions standards.
9. Comment: Solidification meets the requirements of SARA for treatment which
permanently and significantly reduces the volume, toxicity, or mobility of
the hazardous substances.
Response: EPA disagrees with much of these claims. Based on the technical
information obtained during the pilot studies, solidification increases,
rather than reduces, volume; toxicity remains essentially the same; and,
the mobility of organic contaminants is unknown over the long term. A more
detailed discussion of these findings is provided in the body of the Record
of Decision.
-------
t
10. Comment: Why does EPA not have to go through the permit process as would
private industry?
Response: CERCLA as amended by-SARA exempts EPA remedial action from going
through the administrative process of acquiring a permit for on-site
activity, however, EPA is required to meet standards of State and Federal
environmental laws.
11. Comment: Tulsa City-County Department of Health has not been adequately
involved in the Sands Springs project.
Response: The Tulsa City-County Department of Health entered into an
Interagency Agreement with the Oklahoma State Department of Health (OSDH)
and received funding fron the OSDH-EPA cooperative agreement to conduct
sampling at the site. The Sands Springs site activities were a ."State-
lead" project and coordination should be initiated at the City/County
Health Department level by the State.
12. Comment: Can a local government or agency be a party to an EPA consent
decree with a potentially responsible party (PRP) to insure that an on-site
thermal destruction unit would not be used to treat waste from other sites?
Response: Yes, section 113(i) of CERCLA (42 U.S.C. §9613(i) provides the
right of intervention to any person who has an interest relating to the
subject of a court action which may be impaired or impeded by judicial
disposition of that action. Thus, if a local government or agency can
show the court that it has an interest in the action and that the local
government's interest will be impaired if the government is not allowed
to be a party to the action, that government may intervene as a party.
If it chooses to do so, the intervenor will share all the rights and
responsibilities and costs borne by other parties.
13. Comment: If on-site thermal destruction is selected, how long will the
process take?
Response: The feasibility study estimated 3.5-4 years to conduct the
remedial design, procurement of contractor and on-site thermal
destruction of the wastes.
14. Comment: "Incineration is not favored at the Sand Springs site because
Tulsa County already has existing air pollution problems. Another
source of air pollution which might cause Tulsa County to exceed
ambient air quality standards is not wanted."
Re-sponse: The existing major source of particulate matters, Sheffield
- Steel, is scheduled to come into compliance in the next year. The
incinerator emissions would have an insignificant impact on air quality.
15. Comment: Solidification should get more consideration before a decision
i s made.
-------
Response: Solidification was considered in detail during the Feasibility
Study and actual pilot studies. Adequate information is available on
which to base a decision.
16. Comment: "How dangerous is the acid sludge to workers in the area?"
Response: Acid sludge at the Sand Springs site currently poses a direct
contact threat due to the highly acidic characteristic of the waste
(this means skin burns can result from touching the material). There
have also been reports of respiratory tract irritations requiring
hospital treatment of workers in and around the acid sludge material
due to the release of sulfuric acid gases. The potential also exists
for workers to come in contact with acidic surface runoff waters. A
health and safety plan will be developed prior to the initiation of
on-site activities.
17. Comment: Did EPA make its final decision on selecting a remedy for
Sand Springs prior to the public meeting?
Response: No. CERCLA requires EPA to indicate a preference to allow the
public an opportunity to focus their comments. A final decision on
selecting a remedy is not made until after the public comment period,
then all comments are reviewed and considered and the Record of Decision
is signed.
18. Comment: Solidification technologies are only experimental and have not
been proven.
Response: Solidification technologies can be effective on low organic
wastes and heavy metals. High organic waste such as the acid sludge at
the Sand Springs site creates difficulties in producing a non-leachable
product, as shown in the pilot studies.
19. Comment: "What interaction will there be between the currently on-going
groundwater study and those recommendations for clean-up compared to
what EPA is recommending to do with the acid sludge pits."
Response: The NCP requires operable units to be consistent with overall
remedies. Information from the groundwater study is currently being
utilized. The feasibility study for the groundwater is scheduled for
completion in early 1988, which coincides with the beginning of the
design phase for the Source Control remedy. Coordination for treatment
options and implementation logistics will_be addressed at that time.
20. Comment: No samples were taken outside the actual sludge pits.
Response: Phase I of the remedial investigation addresses the known major
sources of contamination and samples were taken from these areas primarily
to characterize and quantify these known sources. Phase II sampling was
conducted over the entire 235 acre site and this information is being
utilized, as evidenced in the inclusion of the additional subsurface
areas of contamination in the Source Control Operable Unit.
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21. Comment: How many ti'mes has thermal destruction been used and what has
been the outcome when it was used?
Response: Thermal destruction has been shown to be effective in destroying
organic pollutants in literally thousands of applications. EPA is convinced
that, with adequate pollution control engineering, thermal destruction
can be effective at the Sand Springs site.
22. Comment: Why is there such a great difference in cost between on and
off-site incineration?
Response: Transportation is a portion of the cost difference. The cost
for incineration both on and off-site as well as all other alternatives
are based on actual vendor quotes and historical information.
23. Comment: What is the basis for naming the four eastern sludge pits
identified in the fact sheet as the Chem Link Waste Pits, "an the name
be changed?
Response: These pits were named the Chem Link Pits for ease of identifi-
cation because they are within the Chem Link facility boundary. Their
names may be changed in the design phase of this project.
24. Comment: Incineration of the Sand Springs sludges will result in a volume
reduction of only 40-50%.
Response: Pilot studies were conducted using one particular thermal
destruction technology which required the addition of neutralizes prior
to processing. Other technologies could require considerably less or no
neutralization. Laboratory incineration tests on 19 samples indicate
an average volume reduction of approximately 85%. Even 40% or 50% reduc-
tion in volume is considered "significant".
25. Comments: The Federal guidelines which OSDH had to follow to produce the
the Remedia.l Investigation and Feasibility Study (RI/FS) reports are
faulty and do not allow the freedom to gather detailed engineering data
needed to build a design. Not enough engineering data is available to
make a treatment selection at this time.
Response: EPA disagrees with this viewpoint. The RI/FS met the statutory
and regulatory requirements. Detailed engineering information, necessary
for the design stage, is not needed to select a remedial concept.
26. Comment: The risk of- air emissions and runoff contamination have not been
addressed.
Response: EPA disagrees. These routes of exposure have been fully
addressed in the Feasibility Study and summarized in the body of the
Record of Decision.
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27. Comment: How are you going to protect the groundwater from further con-
tamination while excavating for the removal options.
Response: Details of protection of the groundwater during excavation will
be addressed in the upcoming design phase.
28. Comment: The Feasibility Study does not give the solvent extraction
alternative credit for 200,000 barrels of oil that could be recovered
by solvent extraction.
Response: The Feasibility Study viewed the oil being extracted from the
hazardous waste as also being hazardous under RCRA. This would render it
a non-salable product and therefore requiring additional treatment.
29. Comment: Treated material produced during the stabilization/solidification
pilot studies pas-sed the Toxicity Characteristic Leaching Procedure (Tf"LP)
tef : and therefore these processes should be considered effective.
Response: The TCLP test was only one of many analytical and physical tests
performed and considered during the remedy selection process. Although
some samples met existing leaching standards for landfillable materials
under RCRA, other samples did show evidence of leaching contaminants.
Leaching of contaminants was a-1 sc seen in other analytical extraction
techniques conducted by the EPA Cincinnati laboratory. Leaching of contami-
nants, even at low levels, indicates questionable long term effectivness
and permanence of these stabilization/ solidification techniques. Also
there is concern that the TCLP test may not detect all potential contami-
nants due to the filtering mechanism of the test and the oily nature of
the waste.
30. Comment: Do PRPs have to implement the Record of Decision or can new
concepts and ideas for study be reviewed?
Response: After the Record of Decision is signed for a conceptual remedy
a treatment process within those technologies should be implemented either
by the PRP or EPA. The details of implementation of the remedy are addressed
in the design phase.
31. Comment: How can people who have received notification letters of being a
PRP find out additional information regarding their position.
Response: Contact FOIA requestor Branch Chief, EPA Region 6 Enforcement
Branch.
32. Comment: "Why are separate entities on one geographic location bound into
one Superfund site creating PRPs that should have a small responsibility
and a small site, into a PRP with, a larger responsibility and a large
site?" .
Response: The Superfund site boundaries were delineated based on the
expected extent of contamination.
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33. Comment: Are the cost estimates in the 'Feasibi1ity Study actual contractor
costs to do the work or are they site costs plus State and EPA oversight
costs.
Response: Cost estimates in the Feasibility Study are estinates within a
range of -30% to +50% of the costs to implement the remedies and do not
include State or EPA oversight costs. These cost figures are only valid
for comparison of the alternatives studied, they do not represent actual
bids.
34. Comment: The final remedy that EPA selects should recognize the different
types of waste present at the Sand Springs site.
Response: EPA agrees. The variability in wastes has been taken into
consideration.
35. Comment: It would be feasible to solidify the acid sludges on the site
in one year which is not achievable by thermal destrjcti'
Response: The Feasibility Study indicates all remedies could be imple-
mented in approximately 3-4 years. Actual implementation tine for
solidification and thermal destruction is comparable, however, it is
variable depending on the amount of equipment, number of treatment units
etc., which is utilized.
36. Comment: Where did the testing criteria for the solidification pilot
studies cone from?
Response: The EPA Cincinnati laboratory supplied the document "Test
Methods for Solidified Waste Characterization" which was incorporated
into the workplan of the EPA Administrative Order with ARCO.
37. Comment: An adequate health risk assessment of the existing health risks
at the site and determination of the health risks of the remedial altern-
atives has not been conducted.
Response: At sites where source control remedial measures are evaluated,
as for the Sand Springs site, a qualitative assessment of the potential
public health threats in the absence of remedial action is 'generally
conducted. This was accomplished in the Sand Springs Source Control
Operable Unit Endangerment Assessment under the Cooperative Agreement
with OSDH. Quantitative health risk assessments are not required for
alternative selection or design of source control remedies.
33. Comment: The Source Control Operable Unit Feasibility Study does not
satisfy the National Contingency Plan because it is based on inadequate
data and on evaluations which have not adequately addressed the require-
ments of the National Contingency Plan, the Superfund Amendments and
Reauthorization Act, or the EPA Guidance on Feasibility Studies under
.T3"| A
i^ i r\ \_< I rA *
-------
Response: Adequate data has been gathered and the evaluations have been
conducted to satisfy those necessary guidance documents and statutory
requirements on which to base a decision for a source control remedy,
^_ 39. Comment: The selection of a source control remedy for the Glen Wynn
%__ lagoons is unnecessary since removal of the majority of waste at this
facility has already been completed.
- - Response: Only the drummed and containerized waste have been removed from
the Glen Wynn facility. No wastes have been removed from the Glen Uynn
lagoons.
40. Comment: In accordance with a consent order, ARCO developed for EPA site
performance data specific to the effectiveness of three remedial alternatives
(i.e. thermal destruction, stabilization and solidification) for the acid
sludge at the Sand Springs Petrochemical Complex. Use .of this data gives
the agency a basis for selecting a remedial alternative for the acid
sludge ponds consistant with a permanent remedy for the site, as
preferred under SARA.
Response: EPA agrees. The pilot studies had a major influence on the
remedy selected.
41. Comment: Human health and the environment can be protected a^ well as
the studied alternatives by much simpler remedies. Why not just add
additional fencing around the site and increase security or cover the
wastes with a simple earthen cap?
Response: Increased security at the site may reduce the chance for direct
human contact with the wastes but it would do nothing to solve the surface
and groundwater pollution that is taking place. Installation of a simple
cap is not practical because of the instability of the tarry sludges;
on warm days the weight of the cap would cause sludges to ooze out from
under or through the cap. Both of these approaches fall far short of
meeting the minimum requirements of the CERCLA.
42. Comment: Why not use an oil extraction thermal process to treat the waste?
The sale of the thousands of barrels of oil derived would offset expenses
and bring the total cost down to $24 million.
Response: The oil extraction thermal process is similar to the solvent
extraction process, except that it uses heat instead of solvents to
separate the oil, water, and solids. Unfortunately, RCRA regulations state
that any constituent derived from a hazardous waste must be treated as
hazardous until, proven otherwise. The overall cost of this alternative
would be much greater "than $24 million since the oil could not be sold -and
the remaining hazardous constituents would require further treatment prior
to disposal.
-------
43. Comment: How much residual ash will be created by thermal destruction and
where will it be disposed?
Response: Thermal destruction would be used to treat approximately 125,000
cubic yards of waste. EPA studies indicate that thermal destruction will
attain an 85 percent reduction in volume, while ARCO's studies, using a
neutralizing material before thermal treatment, indicate a 40 to 50 percent
reduction in volume. If the neutralizing material is not required to treat
the waste, an estimated 18,750 cubic yards of residual ash will remain
after thermal destruction. The residual ash would be solidified, if
necessary, and landfilled on-site.
44. Comment: What types of air quality problems does solidification pose?
Response: Pilot studies have shown that some volatile compounds are driven
off during excavation and mixing of the waste with the solidifying agent.
Mass emission rates have not been quantified.
45. Comment: Has the solidification remedy been sufficiently tested over the
range of the waste?
Response: Solidification pilot studies were only conducted on the surficial
acid sludge waste. Additional waste characterization and pretreatment
studies will need to be performed on the subsurface petroleum wastes.
46. Comment: "It seems surprising that after five years of preliminary study
when no information was available on the site, a hurried ROD must be
prepared."
Response: A hurried ROD has not been prepared. The alternative evaluation
process has been ongoing since the initial stages of the Remedial Investi-
gation/Feasibility Study. The Record of Decision is merely a summarization
and culmination of these studies.
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APPENDIX 0
-------
ADMINISTRATIVE RECORD
Job. No. SS-1977
)ocument Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Job No. SS-1980
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Viginator - Affiliation
rtecipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
I'P .MLfr.ll Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation -
Description
Number of Pages
ocument Number Sequence
6/22/77
Inspection Report
Rob Simms
Oklahoma Water Resources Board
Investigation of Complaint
2
1
6/12/80
Potential Hazardous Waste Site Inspection Rpt.
Gary McDonald
OSDH
For Hazardous Waste Log File
Oil Bottom Sludge Pit Improvement
9
2
6/13/80
Interoffice Correspondence
Tom Drake
Oklahoma Air Quality Service
Initial Investigation of Spill
1
3
6/18/80
F.'le^lial Hazardous Waste Sito Inspectiou Li-
Gary McDonald
OSDH
For Hazardous Waste Log File
Oil Bottom Sludge Pit Impoundment
9
8/1/80
Communication/Record
Larry Wright
USEPA (6AE6H)
Mike Wright
Tulsa County Health Dept.
Accident at SS Pit
1
5
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ADMDIISTRATIVB RECORD
Job. No. SS-1981
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Tyoe
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originacor
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Job No. SS-1981
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
1/9/81
RCRA Compliance Inspection Rpt. Facilities
Checklist
Industrial Waste Division
OSDH
Industrial Solid Waste Division
OSDH
Monthly Rpt. v/shipping manifests
11
6
2/2/81
Monthly Report Controlled Industrial Waste
Receiving Site
Glenn Wynn
Site Owner/Operator
Industrial and Solid Waste Division
OSDH
Monthly Report with Shipping Manifests
11
7
2/19/81
Letter
Diana Dutton
OSEPA (6AE)
Glenn Wynn
Initial Inspection of Site
7
8
2/25/81
Communication
Jim Turner
USEPA (6AELG)
Richard Holmes
Attorney
Phone call concerning Glenn Wynn
1
9
2/27/81
Controlled Industrial Waste Shipping Manifest
Glenn E. Wynn
Vacuum 4 Pressure Tank Truck Svcs., Inc.
Industrial Waste Division
OSDH
Hazardous Waste Manifests for Month
11
10
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ADMINISTRATIVE RECORD
Job No. SS-1981
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
2/27/81
Plan
Glenn E. Wynn
Vacuum 4 Pressure Tank Truck Svcs., Inc.
Ind. & Solid Waste Div., OSDH
Controlled Ind. Waste Disposal Plan
8
11
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
3/6/81
Order/Tulsa City-County Health Dept.
Ray Bishop, R.P.S.
Tulsa City-County Health Dept.
Fred Whitaker
Resource Recovery & Refining Corp.
Order to Cease Operation of Facility
1
12
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/27/81
Supplemental Laboratory Report
William D. Langley
Chief Laboratory Svcs. Section, 65A-HL
William J. Librizzi
Dir. Surveillance & Analysis Div. 65A
Supplement to 3/19/81 Preliminary Data Report
13
Document Date
Document T/pe
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
6/29/81
Magazine Article
Chemical Business, Page 7
Article on Solvent Recovery Business & Process
2
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ADMINISTRATIVE RECORD
Job. No. SS-1981
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/2/81
Controlled Industrial Waste Shipping Manifest
Bob Ossery
Vacuum Pressure Tank Truck Services
Industrial 4 Sand Waste Division
OSDH
Waste Shipping Manifests & Monthly Receiving
Site Reports
2
15
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/22/81
RCRA Inspection Site Identification
Kenneth C. Burns, Senior Environmental Specialist
OSDH
Compliance Inspection Rpt. of Resource Recovery
& Refining Corp.
7
16
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/22/81
RCRA Compliance Inspection Report
Industrial Waste Division
OSDH
RCRA File
Facility Standards Checklist
13
17
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/22/81
RCRA Inspection
Kenneth C. Burns, Sr. Environmental Specialist
DH
RCRA File
Site Identification & Inspection Information
1
18
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ADMINISTRATIVE RECORD
Job No.. SS-:981
Document Date
Document Type
Originator
Originator - Affiliation
Recipient .
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
10/23/81
Industrial Waste Receiving Site Monthly Rpt.
Industrial & Solid Waste Division
OSDH
RCRA File
Monthly Rpt. of Delivered Waste for September, 1981
1
19
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
11/16/81
Lease
S. Neal Johnson
Sandsprings Home
Sam Farmer
Recyclon Corporation
Lease for Purpose of Conducting Re-Refining 4
Treatment of Solvents, Crude & Lube Oils
6
20
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Job No. 1982
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
12/18/81
Spill Prevention Control & Countermeasure Plan
Dennis I. Kelley
0'Kelley Engineers
llenn Wynn
Vacuum Pressure Tank Truck Services, Inc.
Plan to Prevent and Contain Oil Spills
9
21
2/4/82
Industrial Waste Receiving Site Monthly Rpt.
Shipping Manifests
Bob Ussery
Siteowner/Operator
Industrial & Solid Waste Division
OSDH
Waste Shipping Manifests & Monthly Receiving
Site Reports
9
22
-------
Job No. SS-1982
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
2/26/82
Data Reports w/Cover Letters
Peters, Chief
Hazardous Waste Section (lES-SH)
Nott, Chief
Enforcement Section (lAW-SE)
Copies of the Analysis of Samples Collected at
Vacuum & Presssure Tank Truck Services.
5
23
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/1/82
Acknowledgement of Notification of Hazardous
Waste Activity
Dwight Corley
RCRA
Whitier
Resource Recovery & Refining Corp.
Letter Changing Organization's EPA I.D. Number
10
21
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/10/82
Civil Action Brief
Carol E. Dinkins
Asst. Atty. leneral, Land 4 Natural Resources
Division, DOJ
Northern District of Oklahoma
Complaint of EPA vs. Def. Site Owners (PRP's)
Petition for a T.R.O. Prohibiting Recycling
23
25
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description.
Number of Pages
Document Number Sequence
8/11/82
Memorandum
Rod Huffman
Piles
Listing of Violations by Recyclon Found During
Inspection
1
26
-------
ADMINISTRATIVE RBCORD
Job No. SS-1982
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/27/82
Petition
State of Oklahoma
District Court Tulsa County
State of Oklahoma
Pet. for a TRO Prohibiting Recyclon from
Receiving at Site
9
27
Document Date
Document Type
0-< ^inator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/27/82
Affidavit
Rod Huffman
Inspector
District Court Tulsa County
State of Oklahoma
Deposition of Unchanged Conditions at Site
after Several Visits w/Remedial Orders.
3
28
Document Date
Document Type -
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Page?
Document Number Sequence
8/27/82
Memorandum
William W. lordon, Jr., Enforcement Officer
OSDH
Hark S. Coleman
Deputy Commissioner for Environmental Health Svcs.
Memo tells of "Recyclon" Cleanup after hearing
of Potential Lawsuit and Lists Alternatives
1
29
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/27/82
Correspondence
Joan K. Leavitt, M.D., Commissioner of Health
OSDH
Hon. David Moss, District Attorney
Tulsa County Courthouse
Request for Prosecutorial Procedures to facil-
itate compliance at Site.
1
30
-------
ADMINISTRATIVE RECORD
OOu 11 0. OO I
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
9/1/82
Memorandum
Rod Huffman
OSDH
Files
Follow-Up Inspection on 8/20/82 showed viola-
tions persisted.
1
31
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
9/9/82
Memorandum & Water Analysis Report
Rod Huffman
OSDH
Files
Samples Taken g Recyclon 9/7/o2 of Barrels &
Soil
5
32
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Job. No. SS-1983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
9/30/82
Memorandum
Rod Huffman
OSDH
Files
Unchanged Condition of Site as of 9/2U/82
1
33
2/1/83
Industrial Waste Receiving ?ite Monthly Rpts.
Bob Ussery
Site Owner/Operator
Industrial & Solid Waste Division
OSDH
Monthly Reports of Delivered Waste (January 1983)
5
-------
ADMINISTRATIVE .RECORD
Job. No. SS-1983
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
4/10/83
Petition
State of Oklahoma
(OSDH)
District .Court Tulsa County
State of Oklahoma
Request for TRO & Permanent Inlunction Prohib-
iting Operation.
5
35
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
6/8/83
Correspondence
Joan K. Leavitt, J.D., Commissioner of Health
OSDH
Hon. David Moss, District Attorney
Tulsa County Courthouse
Request for Prosecutorial Proceedings under 63
O.S. 198).
1
36
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Dale
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
6/8/83
QA Summary
Cynthia Pachunas
OSDH
Oklahoma Stace Agency
Summary Sheet - NPL
2'
37
7/5/83
Industrial Waste Receiving Site Monthly Rpts.
(June-Dec. 1983)
Bob Ussery
Site Owner/Operator
Industrial and Solid Waste Division
OSDH
Monthly Reports of Delivered Waste
8
38
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description .
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/11/83
Petition
State of Oklahoma (OSDH)
District Court Tulsa County
State of Oklahoma
Prayer for Civil Penalty A'ssessment for Des-
cribed Violations
7
39
1/25/84
Route Slip
Ken Burns
OSDH
Jeff lilley
EPA-6
File listings of likely to be found Sand
Springs material
13
40
2/2/84
Industrial Waste Receiving Site Monthly Reports
(Jan-April '84)
Bob Dssery
Site Owner/Operator
Industrial and Solid Waste Division
OSD
Monthly receiving site reports
3/1/81
Action Memo
Dick Whittington, P.E.
Regional Administrator (6A)
Lee M. Thomas, Assistant-Administrator
Solid Waste and Emergency Response
Basis for decision to spend superfund money for
immediate removal action
4
42
3/2/84
Administrative Order
Dick Whittington, P.E.
DSEPA
Rodney Wilson, Claire Wilson, Bill Creel,
Dennis Bergstrom, David Nieman, Fred Whittier
Wynn Site Operating Corporations
Orders various actions to be taken by site operator
13 '
43
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequence
3/13/84
Administrative Order
Dick Whittington
U.S.E.P.A.
Samuel C. Fanner, Peggy Fanner, Jeffrey B. Nooleen
Recyclon Corporation, Wynn Site
Order directs action to protect public health and
the environment
12
44
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/9/84
Notice of Public Meeting
OSDH
General Public
Summary of work to be performed at site
12
45
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document .Number Sequence
5/31/84
Community Relations Plan
OSDH
Interested Parties
Plan to keep interested parties informed of
progression site
11
46
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/31/84
Site history and location
U.S.E.P.A.
Interested Parties
Site history and summary of inspections and lab analy:
47
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/31/84.
File Sumnary
U.S.E.P.A.
Interested Parties
File summary of inspections and analysis (June 13,
1980-May 31, 1984)
4
48
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number.Sequence
6/22/84
Correspondence
William C. Anderson
Doerner, Stuart, Saunder, Daniel & Anderson
All parties listed as "generators"
Wynn Site Operation
Demand on "generators" to reimburse the home for
Phase I Cleanup
5
49
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
7/1/84
Health and Safety Plan for S.S.P.C.C. RI
Waste Management Service
DSDH
Interested Parties
To protect health of public near the site and
provide information concerning health of
personnel working on site during RI period
31
50
-------
ADMINISTRATIVE RECORD
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Number Sequence
March 1, 1985
Work Plan Summary
Oklahoma State Dept. of Health
Public
Sunnary of technical work plan - Sand Springs
5
51
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber Sequence
3/1/85
Information Sheet
Oklahoma State Dept. of Health
Public
Emergency responder information sheet - Sand
Springs
2
52
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber Sequence
3/19/85
Cover letter, response plan
Dennis Kelley - President
O'Kelley Engineers, Inc.
Kenneth Burns
Oklahoma State Health Dept.
Cover letter, response plan. (U acre Wynn's site
Sand Springs)
42
53
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
3/19/85
Report
Dennis Kelly 4 Sami Malaeb
O'Kelley Engineers
USEPA
Site Evaluation Report
34
54
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
1/2/86
Sampling Plan
Oklahoma State Department of Health
Affiliation
Oklahoma State Dept. of Health
Surface runoff water sampling plan for Sand
Springs
7
55
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number'of Pages
Document Number Sequence
3/11/86
Record of Communication
Dave McCartney
EPA Region VI
Dennis Hrebec
Oklahoma State Dept. of Health
Possible Phase II activities - Sand Springs
12
56
-------
ADMIN IS TRATIVEL JIECQRD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber Sequence
5/28/86
Record of communication to file
Dave McCartney
EPA - Region VI
Dennis Hrebec, Hal Cantwell
Oklahoma State Dept. of Health
Sand Springs R1/FS;QA/QC check of lab data
1
57
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber Sequence
6/5/86
Request Letter
Dennis Hrebec, Environmental Consultant
Oklahoma State Dept. of Health
Bill Anderson
Requests permission to conduct activities at Sand Spri
1
58
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/11/86
Ct. Petition, certificate
District Ct. of Tulsa Co. - State of Okla.
Oklahoma State Dept. of Health
Suit brought against Sand Springs parties by State
of Oklahoma
5
59
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
8/29/86
Letter
Chris. Swanberg
ARCO
Regional Administrator (VI)
USEPA
Maintenance of Dyke
1
60
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
9/2/86
Sampling Plan
Oklahoma State Dept. of Health
Oklahoma State Dept. of Health
Organic screening sampling plan-Sand Springs
3
61
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
9/10/86
Memo
David McCartney
USEPA (6H-SA)
Addressees
USEPA
Progress & Planning
2
62
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Dw jnent Number Sequence
9/30/86
Sampling Plan
Oklahoma State Dept. of Oklahoma
Oklahoma State Dept. of Oklahoma
Sludge sampling plan - Sand Springs
7
63
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
11/15/86
Sampling Plan
Oklahoma State Dept. of Oklahoma
Oklahoma State Dept. of Oklahoma
Surface impoundments sampling plan - Sand Springs
20
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
11/20/86
Cover letter, sample analysis
Lisa Lyhane - Environmental Engineer
Oklahoma State Dept. of Health
Mark Kroenig, P.E.
John Mathes & Assoc.
Surface run-off/drainage sediment sample analysis
11
65
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
12/1/86
Sampling Plan
Okla. State Dept. of Health
Okla. State Dept. of Health
Sediments Sampling Plan
6
66 .
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of.Pages
Document Number Sequence
1/16/87.
Cover Letter with Data Attachments
Lisa Lyhane, Environmental Engineer
Solid Waste Division, OSOH
Mark H. Kroenig, P.E.
John Mathes 4 Associates, Inc.
Sample Analysis for Metals, Organics and
Inorganics (sample numbers 88-111)
6
67
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
2/11/87
Order
Larry Gutterridge
ARCO
James Turner
USEPA (6C-H)
Consent Order
22
68
-------
ADMINISTRATIVE RECORD
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Docunent Nunber Sequence
4/10/87
Addendun to the Endangerment Assessment
John Mathes & Associates
Waste Management Service
OSDH
Toxicant profiles, Exhibits A-6
150
69
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber Sequence
4/11/87
Route Slip
Dennis Hrebec
OSDH
Julie Bozich
USEPA (6H-EC)
Map of Site Boundaries
2
70
Docunent Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Docunent Nunber Sequence
5/1/87
Feasibility Study Report
John Mathes 4 Associates, Inc.
Waste Management Service
OSDH
Feasibility Study Report for Operable Unit of SS
Site
nw
71
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber Sequence
5/M/87
Remedial Investigation Report
John Mathes & Associates
Waste Management Service
OSDH
Sludge and Surface Impoundment Sampling
126
72
-------
ADMINISTRATIVE RECORD
Document Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Docunent Number Sequence
5A/87
Remedial Investigation Report, Appendix E,
Analytical Data, Volume I
John Mathes & Associates, Inc.
Waste Management Service
OSDH
Sludge and Surface Impoundment Sampling
281
73
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/4/87
Remedial Investigation Report, Appendix E,
Analytical Data, Volume II
John Mathes & Associates
Waste Management Service
OSDH
Sludge and Surface Impoundment Sampling
273
74
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/5/87
Quality Assurance Procedures
Special Materials Division
Eagle-Picher Industries, Inc.
Waste Management Service
OSDH
Quality Assurance Procedures for the Analytical
Laboratory
156
75
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/6/87
Order
James Turner
USEPA (6C-H)
Larry Gutterridge
ARCO
Administrative Order (Final Revision) ARCO Test
Burn Study
23
76
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber Sequence
5/7/87
Endangerment Assessment
John Mathes & Associates,
Inc.
Waste Management Services
OSDH
Endangerment Assessment for the Operable Unit at
Site
145
77
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/7/87
Work Plan
R. Walter Simmons
ARCO
Robert Layton, Jr.
USEPA - (6A)
Work Plan for Solidification
12
78
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/7/87
Brochure
R. Walter Simmons
ARCO
Robert Layton
USEPA (6A)
Solidification Brochure
8
79
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber Sequence
5/8/87
Plan
Larry Gutterridge
ARCO
James Turner
USEPA (6C-H)
Final Portion of Workplan
8
80
-------
ADMINISTRATIVE RECORD
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
.Recipient - Affiliation
Description
Number of Pages
Docunent Number Sequence
5/13/87
Cover Letter with Data Analysis
Dale C. Markley, Senior Hydrogeolist
John Mathes & Associates, Inc.
Lisa Lyhane
OSDH
Remaining Analysis for Dioxin and Furans run at
the 0.1 PPB detection limits. (First Data sent
4/10/87)
3
8.1 . -
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/15/87
Letter
Robert Hanneschlager
USEPA (6H-E)
Roseann Stevenson
ARCO
Comments on Workplan
3
82
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Number of Pages
Document Number Sequence
5/15/87
Communication Record
Steve Lemons
USEPA (6E-Q)
Paul Sieminski
USEPA (6H-SA)
Review SS Workplan
8
83
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequence
5/18/87
Order
James Turner
USEPA (6C-H)
Robert Layton
USEPA (6A)
Administrative Order
23
84
-------
ADMINISTRATIVE RECORD
'Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Dociment Nunber' Sequence
5/27/87
News Release
Joan K. Leavitt,
OSDH
M.D.
Announcement that R.I. Report is completed and
available.
2
85
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Dociment Nunber Sequence
6/29/87
Letter
Robert Hannesschlager
USEPA (6H-E)
Roseann Stevenson
ARCO
Response to June 2, '87
1
86
letter
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
of Pages
Document Nunber Sequence
7/15/87
News Release
Karen L. Brown
OSDH
Announcement of 8/4/87 public meeting explaining
cleanup operations
2
87
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber Sequence
7/30/87
Report
Kevin Jackson
Jacobs Engineering Group, Inc.
June Bozich
EPA Region 6
Summary of Compliance monitoring activities
1.2
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
Undated
Evaluation
"Research Triangle Institute & U.S. E.P.A.
U.S. E.P.A. Region VI
"Evaluation of TCLP..."
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
Undated
Answers to notice
ChemLink Petroleum
U.S. E.P.A. (6) Sand Springs file
Response to U.S. E.P.A. notice
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
Undated
Test methods
U.S. E.P.A. (6) Sand Springs file
U.S. E.P.A. (6) Sand Springs file
Test methods/solidified waste character
91
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/86
Handbk.
M. Jn. Cullinane, Jr., et al
USAE Waterways Experiment Sta.
U.S. E.P.A. Region VI
Handbk. Stabilization/Solidification
168
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/86
Manual
U.S. E.P.A. (6) Sand Springs file
U.S. E.P.A. (6) Sand Springs file
Test Methods for Evaluating Solid Waste
59
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/22/86
Cover letter/closure report
David McCartney
Mary Ellen McLeary, Bill Taylor, et al
Closure report - Wynn Tank
28
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
10/15/86
Cover letter/report
Jn. Mathes & Assoc., Inc.
Paul Sieminski
U.S. E.P.A..-(6) Sand Springs file
RI report 2 - surface impoundment tech. memo
17
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
1987
Research article
Hazardous Waste & Hazardous Materials
U.S. E.P.A. Region VI
Effect of three organic compounds
12
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs retro-Chemical Complex
Job Number: ' OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
04/1987
Plan
ARCO Petroleum Prod._Co.
U.S. E.P.A. (6) Sand Springs file
Work plan - Pilot Therman Treatment
165
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
04/30/87
Follow-up letter
Carlton C. Wiles/Chief
U.S. E.P.A.
Walt Simmons
ARCO Petroleum Products Co.
Sample tests and analyses
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
04/30/87
Letter
Carleton Wiles - Office of R & D
U.S. E.P.A. Washington
Walt Simmons
ARCO Petroleum Products Co.
Followup to phone conversation 0 /29/S7
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/07/87
Plan
ARCO Petroleum Prod. Co.
U.S. E.P.A. (6) Sand Springs file
Work Plan - Waste Solidification/Stabil.
14
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Pet re-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/11/87
Letter
Walter Simmons, Mgr.
vj » O LJ IT f\
Carleton Wiles
U.S. E.P.A. - HWERL
ARCO's solidification testing
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/11/87
Letter
R. Walter Simmons, Mgr. Environ. Protect,
ARCO Petroleum Products Co.
Carleton Wiles (HWERL)
U.S. E.P.A. (Cincinnati, OH)
Solidification portion - Work Plan
1
Document Date
Document Type
Originator
Originator - Affiliation
recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/21/87
Memorandum
Paul Sieminski (HWD)
U.S. E.P.A. Region VI
Ed Barth, Environ. Engr.
U.S. E.P.A. (Cincinnati, OH)
Review - Solidification/Stabilization Work Plan
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/21/87
Memorandum
Ed Barth, Environmental Engineer
U.S.-E.P.A. - Remedial Action Staff
Paul Sieminski
U.S. E.P.A. - Hazardous Waste Mgtment. Div.,
Review of Work Plan
2
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
: Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number'
.09/25/84
Memo/plan
Ronnie Romo - QA
U.S. E.P.A. (6)
Paul Sieminski, Project Officer
U.S. E.P.A. (6) 6AW-SS
Revised QA/QC Plan Pages
21
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job JIumber: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/02/87
Letter
R. Walter Simmons, Mgr.
ARCO Petroleum Products Co.
Robert E. Hanneschlager
U.S. E.P.A. (6) Sand Springs file
Updated Work Plan - Incineration/Solidif.
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/29/87
Cover letter/sample analyses for wells
Lisa Lyhane - Environmental Engineer
U.S. E.P.A. SuperFund" Program/Solid Waste Div.
Paul Sieminski
U.S. E.P.A. Region VI
Sample analysis for Phase II monitor wells
43
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
6/30/87
Memorandum
Ragan Broyles, Chief
U.S. E.P.A. Region VI (6T-AS)
Steve Gilrein, Chief
U.S. E.P.A. Region VI (6B-SA)
Solidification Process Air Monitoring
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/30/87
Memorandum
Ragan Broyles/ Chief
U.S. E.P.A. - State Programs Section
Steve Gilrein, Chief
U.S. E.P.A. - ALONM Remedial Section
Air monitoring methods
2
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
07/08/87
Research article
Paul Marsden, e.t al
S-CUBED
U.S. E.P.A. Region VI
"Modification of the TCLP.,
8
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
07/15/87
Interim report
AROO Petroleum Products Company
U.S. E.P.A. (6) Sand Springs file
Acid Sludge Treatability Evaluations
486
Document Date
Document Type
Originator .
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/04/87
Letter
Jerry.Cleveland - Assistant Director
Tulsa City - County Health Department
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Supports solidification
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/04/87
Letter/attachment
Reeves D. Ingold
Crestwood Distributors, Inc.
Dennis Hrebec
Oklahoma State Department of Health
Summary of treatment of samples
7
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date 08/04/87
Document Type Public Meeting Transcript
Originator Ann Hart - Certified Shorthand Reporter
Originator - Affiliation
Recipient U.S. E.P.A. (6) Sand Springs file
Recipient - Affiliation
Description Transcript
Number of Pages 172
Document Number
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/06/87
Letter
Russell Karnaugh, Jr. - Attorney
Law office - Conner & Winters
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Cements Re: ROD
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/07/87
Letter
R. J. Morris - Sr. Staff Engineer
ChemLink Petroleum
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comrents Re: ROD
1
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/10/87
Cover letter/attachments
Lisa Lyhane - Environmental Engineer
SuperFund Program/Solid Waste Division/U.Si
Paul Sieminski
U.S. E.P.A. Region VI
Map and sample results
83
E.P.A.
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/12/87
Letter
Wayne Hillin - Attorney
Resources Conservation Company
Jn. Mathes & Assoc., Inc.
Estimated cost cleanup remedy
4
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/12/87
Letter
Frank Smith - Environmental Engineer
Burgess-Norton Manufacturing Company
Al Davis, Director (HWD)
U.S. E.P.A. (6)
Public hearing 08/04/87
3
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/13/87
Cover letter/report
Lisa Lyhane, Environmental Engineer
U.S. E.P.A. SuperFund program
Paul Sieminski
U.S. E.P.A.
Cover letter/Draft RI report
114 pages
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/14/87
Letter
M. F. Reece - Assistant Director
Tulsa City - County Health Department
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comments Re: ROD
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/14/87
Letter
Chas. Scott - Acting Field Supervisor
U.S. Department of Interior - Fish/Wildlife Serv.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFunds Program
Preliminary comments Re: completed studies
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number -
08/18/87
Letter
Steven P. Case - Attorney
Law firm - McGrath, North, et al
Julie Bozich - Compliance Sec.
E.P.A. (6H-EC)
Comments Re: FS report - operable unit
5
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Conplex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/18/87
Letter
Joel Burcat - Attorney
Law firm - Rhoads & Sinon
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Public comment Re: RI/FS
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
tomber of Pages
Document Number
08/18/87
Letter
L. R. Doss
Citizen - Sand Springs, Oklahoma
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comments Re: cleanup
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/21/87 '
Lab results
Edwin Barth - Environmental Engineer
U.S. E.P.A. (Washington, D. C.)
Paul Sieminski - RPM
U.S. E.P.A. Region VI
Pilot work
8
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/21/87
Memorandum
Edwin F. Barth, Environmental Engineer
U.S. E.P.A. - Remedial.Action staff
Paul Sieminski, RPM - Region VI
U.S. E.P.A.
Summary of solidified materials tests
8
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petto-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/24/87
Memorandum/attachments
Allyn M. Davis, Director
U.S. E.P.A. Region VI (6H)
Walter Kovalick, Deputy Director
U.S. E.P.A. Washington (WH-548)
Follow-up to ROD Briefing
5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/24/87
Memorandum
Allyn Davis, Director
U.S. E.P.A. HWMGIE
Walter Kovalick, Deputy Director
U.S. E.P.A.
Record of Decision (ROD) briefing
5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/25/87
Letter
George Hooper, Mayor
City of Sand Springs
Robert Layton, Jr. - Regional Ad.
U.S. E.P.A. Region VI
Response to ROD
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/27/87
Letter/enclosures
R. Fenton Rood, Director
Oklahoma State Department of Health
Carl Edlund, Chief
SuperFund Programs Branch
Comments Re: remedy
9
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM -
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/27/87
Letter
Stanley Reigel - Attorney
Law firm - Morrison, Hecker, et al
Julie Bozich
U.S. E.P.A. (6) Compliance Section
Response to 07/15/87 U.S. E.P.A. letter
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/27/87
Letter
M. Louise McFall - Corp. Counsel
Scrivner, Inc.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Consideration of all remedies
1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nun^r of Pages
Dcx-.ent Number
08/28/87
Letter
Timothy L. Olsen
Savage, O'Donnell, Scott, et al
Julie L. Bozich
U.S. E.P.A. Region VT
Public oonment by Advance Chemical Dist., Inc.
4
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Vincent A. Mietlicki - Attorney
DeSoto, Inc.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Comments Re: RI/FS
4
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Matthew G. Livingood - Attorney
Law firm - Hall, Estill,' Hardwick, et al
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Comments Re: RI/FS
9
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Report
ARCO Petroleum Products Company
Contractor
U.S. E.P.A. Region VI
Review of operable unit 75
33
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Linda Gill Taylor - Attorney
Law firm - Gage & Tucker
Carl Edlund, Chief
U.S. E.P.A. Region VI SuperFund
Comment Re: selection - response action
3 .
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter/attachment
Sherry D. Blum
Terra Resource Management,
Dennis Rebeck/Fenton Rood
Report addendum
3
Inc.
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Michael D. Graves
Hall, Estill, Hardwick, et al
Carl Edlund
U.S. E.P.A. Region VI
Comments upon the RI/FS
9
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Report
Rivkin, Radler, et al/Mittelhauser, Inc.
Law firm/consultants
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comments Re: proposed FS (operable unit)
63
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter/enclosure
Jerry L. Riddles, Corp. Director
Trinity Industries, Inc.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Comments. Re: RI/FS
5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Paul McGough - Vice President
Resources Conservation Company
Carl Edlund, Chief
U.S. E.P.A. (60 SuperFund Program
Operable unit FS
16
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petto-Chemical Complex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient --Affiliation
Description
Number of Pages
Document Number
08/31/87
Letter
Jn. Selph - Co. Commissioner
Board of Co. Commissioners
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Response to ROD
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/31/87
Report (Final)
ARCO Petroleum Products Company
U.S. E.P.A. - Region VI
Acid Sludge Treatability Evaluations
678
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
Joe A. Williams, President
Sand Springs Home
Julie Bozich
U.S. E.P.A. (6) Compliance Section
Response to Bozich letter (07/15/87)
4
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
Roseann C. Stevenson - Manager
ARCO Petroleum Product Company
Allyn M. Davis, Director
U.S. E.P.A. (6) Sand Springs file
Proposal to perform RD/RA
3
-------
ADMINISTRATIVE RECORDS INDEX ADDENDUM
Job Name: Sand Springs Petro-Chemical Conplex
Job Number: 0103980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
Thomas A. Vfeite - Counsel
Boeing Co. - Office General Counsel
Carl Edlund, Chief
U.S. E.P.A. Region VI SuperFund Program
RI/FS - first operable unit
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
Mark D. Edie - Staff Attorney
Ford Co. - Office of General Counsel
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Program
Public comment pc-riod Re: RI/FS
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
R. Fenton Rood, Director
State of Oklahoma Health Department
Carl Edlund, Chief (6H-S)
U.S. E.P.A. (6) SuperFund Program
Public comments Re: remedy
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter/attachment
Lisa Seglin/David Stringham
Waste Management North America, Inc.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Comments Re: RI/FS
11
-------
ADMINISTRATIVE FECQRDS INDEX ADDENDUM
Job Name: Sand Springs Petro-ChemicalvComplex
Job Number: OKD980748446
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/01/87
Letter
Mark D. Edie - Staff Attorney
Office of General Counsel - Ford Co.
Carl Edlund, Chief
U.S. E.P.A. (6) SuperFund Programs
Public comment period - RI/FS
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/03/87
Letter
D. H. Smith
Allyn M. Davis - Director
U.S. E.P.A. (6) Sand Springs
Proposal to perform RD/RA
3
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/05/87
Letter
Lonnie N. Bobo
Citizen - Edmond, Oklahoma
Carl Edlund, Chief
U.S. E.P.A. Region VI - SuperFund
Comments Re: public meeting
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages-
Document Number
09/10/87
Letter
Jerry Lasker - Executive Director
Indian Nations Council of Goverments
Robert Layton - Regional Admin.
U.S. E.P.A. Region VI
Comments Re: ROD
3
-------
APPENDIX E
-------
Joan K. Lc«vh . M.D.
Commi:. oner
OKLAHOMA STATE
DEPARTMENT OF HEALTH
Board of Health
jamei A Co* .r VD
t
jonrscr VC:
aen;
(tooer D McC
V D"
jcrr 3 Z^-
OKLAHOMA CITY, OK 731 52 *.
AN EQUAL OWDt^JNITY EMPLOYER
September 16, 1987
pp.,
Allyn M. Davis, Director Sk <\£sn'
Hazardous Waste Management Division
U. S. Environmental Protection Agency
Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
Dear Dr. Davis:
The Oklahoma State Department of Health (OSDH) does not concur with the alternative
of on-site incineration chosen by the Region VI Environmental Protection Agency for the
Sand Springs Petrochemical Complex Superfund site.
As stated in the public meeting and through written comments, the OSDH prefers a
solidification process for the acid sludge wastes which will be more protective of public
health than incineration. Included in those comments is the rationale for our preference
and an explanation of how solidification meets the requirements of the NCP and CERCLA
as amended by SARA. Please refer to our previous formal comments for the appropriate
explanations and rationale.
Enclosed are OSDH comments on the draft Record of Decision received on September 8,
1987.
Sincerely,
<*»
Mark S. Coleman, Deputy Commissioner
for Environmental Health Services
Enclosure
-------
TECHNICAL REPORT DATA
'Please rtatt tnttmcnom an the reverie txfort
EPA/ROD/R06-87/024
3 «eci"tNr s ACCESSION NO
4. TITLC ANO SUCTITLi
SUPERFUND RECORD OF DECISION
Sand Springs Petrochemical Complex, OK
First Remedial Action
OATI
September 29, 1987
«. »R*O*MING ORGANIZATION COOi
7 AUTMQRIS)
. MR0ORMING ORGANISATION REPORT NQ
9 MR*ORMIN<3 ORGANIZATION NAMI ANO AOORtSJ
10. PROGRAM EtCMfNT NO
CON TR ACT/GR AN T NO
12. SPONSORING AGCNCY NAM ANO AOORCS3
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYM
REPORT ANO PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY coot
800/00
IS. SU^HM«NTARV NOTES
4. ASSTRAcf '
The Sand Springs Petrochemical Complex is a 235-acre site in Sand Springs, Oklahoma
on the northern bank of the Arkansas River. The site includes acid sludge pits, a
surface impoundment, spray ponds, solvent and waste lagoons, surficial sludge
contamination, solvent and waste oil lagoons and contaminated sediments. From the
turn of the 20th century through the 1940s the site operated as a refinery but has
since been developed into an industrial area, which now consists of an abandoned
solvent and waste oil recycler, an active transformer salvage/recycler, active
chemical manufacturers and various other industries. The total known waste volume is
approximately 130,000 yd3. Sulfuric acid sludge exists in unlined sludge pits and
heavy metal and organic wastes are contained in the lagoons, pits and spray ponds.
While both soil and ground water are contaminated, this first operable unit source
control ROD addresses surface liquids, sludges and heavily contaminated soils. The
primary contaminants of concern are organic pollutants: bis(2-ethylhexylJphthalate
and toluene and inorganic compounds: lead, zinc, chromium and barium.
The selected remedial action for this site is onsite thermal destruction of
wastes. The estimated capital cost of this remedial action is approximately
£66,500,000 with annual O&M of $15,000. During the ROD's comment period, ARCO
Petroleum Products Company, one of the potentially responsible parties (PRPs),
(See Attached Sheet)
17.
K«Y WORD* ANO OOCUMINT ANALYSIS
b.lOINTI»lSRS/OMN ENOEO TERMS C. CO3ATI F*ld/Croup
Record of Decision
Sand Springs Petrochemical Complex, OK
First Remedial Action
Contaminated Media: soil, sw, sludge
Key contaminants: VOCs, organics, chromium,
heavy metals, toluene
It. DISTRIBUTION STATEMENT
It SICuRtTY
Rtporn
21 NO OF
None
90
20. SECURITY CLAM .
\T/-»fi o
22
J770-1 («». 4-77) »
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EPA/ROD/R06-87/024
Sand Springs Petrochemical Complex, OK
First Remedial Action
16. ABSTRACT (continued)
formally proposed a privately-financed remedy for the site, which is similar to an
alternative evaluated by EPA. This remedy has a lower initial cost than EPA's thermal
destruction alternative and is supported by State, local agencies and residents. The
PRP will institute the remedy and has agreed to take further corrective action if EPA
deems that the remedy has not been effective. Components of ARCO's proposed remedy
include: excavation and offsite thermal destruction of sludges; solidification and/or
stabilization of all remaining sludges with containment of the resulting matrix in an
onsite hazardous waste RCRA cell; and implementation of chemical and physical
treatability studies. The estimated capital cost for this remedial action is
$37,453,050 with annual O&M of $15,000. PRP replacement costs total $100,000,000.
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