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.)

-------
SUMMARY OF REMEDIAL  ALTERNATIVE SELECTION




    SAND SPRINGS  PETROCHEMICAL COMPLEX



   SAND SPRINGS,  TULSA COUNTY, OKLAHOMA




              SEPTEMBER 1987

-------
                  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:

-------
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.

-------
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

-------
   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

-------
                           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

-------
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.

-------
             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.

-------
•/ 'o* n*3=££^**—r iTi-^-—
                             LOCATION
                                                                    FIGURE  1
                                                                    LOCATION  MAP  OF  THE
                                                                         SAND SPRINGS
                                                                  PETROCHEMICAL  COMPLEX

-------
                   -2—
FIGURE 2


MAP OF THE SAND SPRINGS
 PETROCHEMICAL COMPLEX
      OPERABLE UNIT

-------
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

-------
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.

-------
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

-------
    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.

-------
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

-------
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:

-------
                              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;

-------
                              11
   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.

-------
                                    12
 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.

-------
                                    13
      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)
                                                             e.g

-------







































CO
UJ
CO
•a:
t—





























































OO
z
0
»— *
1—
-
<^
s:
5
»« ~t
^
^*^
































UJ
t—

1
u_
u.
o



LU
1—
•M4
(/I
1
u.
o




UJ
*— 4
00
\
z
o





UJ
r—
«— »
°?
z
o






UJ
p.
t«t
oo
1
z
o












































1 —
z
UJ
_J
o
CO




_l
<:
y
ai
UJ
-Ml_
_iL.
t—





z
UJ
>
_J
o
to



z
o
t—
f^
c ^
— •
u.
2
o




	 1
e£

f^
UJ
"7~
l»_






o
z




































o
•— *
1—
<_)
ee
i—
X
UJ

t

X XX X





z
o
»— <
t—
o
"^
a;
C/1
UJ
Q




X X X . X






Z
O
1 —
O
«c
a:
i —
X
UJ




XX XX







o
t^
_J
1
•— •
l~L_
z
	 i


. — . . — .
r—< r~~ (
**— " V — -
XXX X X




-
z
o
>— •
t—
o

cc
}—
OO
UJ
C3




XX XX
-







"^
0

i —
(_>


X X XX


-a -a
QJ ^J GJ ^J
oo Q 4_> ^— OJ OJ •*-* »~~ QJ ^>
C UfO-O •— O fO JD <— r—
oo
»— •*
in
^»
_i

~y*
^
O C(--«- jQCt-->-J3 JD
•r— (^ 4^ CO 1^ lO 4-* OO ^O fO
4->>>-i— oiits U -i— in >e u U
« 1— r- C Ol -r- r— C OJ -1- ••-
^— O) Q- O *t- -— CLO<*-r— r—
Oji^EE *->CuES CL +->O.
•r--r- OOJI- OCL OOlt- CL OCL
2> r-— C-J "O O Z ^ O T3 O «3T Z ,
O «- *J '-^
•r— O --— N.  *-> ex. <: c o:3<3;H-
L. *T3 — -* O* ^ ^ t— z: o
(/) C. 4/1 H~ 4-> ^O C. 	 •* C .it.--1
COJ '3 U C ••- tJU
Q > O (/> <^ Q <£ 4/1 ^j <^
O O "O ' — •!— "O CO
O i— t3 L. 4-J ^J C. .iQ r—
^) ^J ^~^« rtj 'r** "p— fQ J^ ^J *"3 ^J
^~ O Cg ^ fsl t.  cC 2T -!-o
"O oO ^ ^— * r— 3> ry ^j rQ «^ {^ x C_?
O OJ O i — O
U- CC O O 1 —



X



00
CJ
3

00

X *->
O

CL

•—
C
C
•'-
•tf
~^
X T3
f^

t-
ai
>
Qj
3
O
"=
•k
c
x o
4-J
S
M-
-a
^^
0
uo

QJ
X *->
>r.
00
1
c
c

.cr
.^f
2

X >,
^^
QJ
'^T

' 
•r- -r- (T3

4-> CL O. O
O CL CL -r-
Z e£ «C >

OJ
4->
O
- e .t—
QJ T3
4-> -U C
C oo -i—
+-> OO 00
3 00 QJ
^— C 4-) -r-
r— O C "O
O QJ -i- OJ 3
a. cn *j E *->
C~ ^ *"~ ** QJ oo
i — rO C OO !-
rQ JT -r- UJ ••- - -M
C U E O 3 O
o oo •!- Q. cr . —
.,- -p- r— Z QJ ••-
*J O UJ - — • OH CL.
*3
Z ' ^





























































•
QJ
>
• r—
I ^
"3
C

QJ
t ^
P— .
(^

QJ
^
• P—
00

QJ
"C7

>-j
^D
£



-------
          —I  LU O
          OO  > <£.
            '  _i ce:
          U.  O H-
          u-  oo x
          O     LU
                                                      X     -><
                 o
          LU _| i—i
          t— «C I—

          oo a: rs
            I  i i i n*
          u. z t—
          Ll_ I— OO
          O    LU
                 Q
                                            X     X
                 o
          LU t— —••
          t— Z. t—
          •—i LU <_3
          OO =» 
c
o
•— O)
o ^

> 1—
Ol OJ
OJ j_> r—
U to jQ
C t- •!-
 O.
O Q.
•z. <
liance
nstrated
CL O
S E
O OJ
<_3 -0
easible
i+-

t_
o
to
c
o
i— O)
o _*
•^ «^-
> t—
a;
u
c
CL
£
0
O
nstrated
easible
o <+-
c
5 t_
^3 O
                 o
                 I—
                 <
      o
      LU
      ce.

      ce.
      o
                        O)
                        C
                        
OJ O
•— c
"^ O
•r- 4_>
C
C ^3 ^t
13 i- O
0 3
.C O U.
^1 C_5 • — •
>p_
U-
0)
4-> .
CO
3
-a
-.- 1/1
r— C
0 O
00 -i-
4-)
5 's
OJ
4->
T3
4_J
OO
JC 01
03 a>
•— ce.
^
0
t_
•^-
•a:
c
03
o>
o
03
o
JZ 4->
03 O
r~" ^C
*-*
o

-------
                 o
          UJ t—  —•i
          i— z  i—
          »—i UJ  t_J
          oo >  <:
           i  _j  a:
          LL. o  i—
          Ll_ OO  X
          O     UJ
          I— —1
             z h-
             LU <_3
          Z O I—
          O CO X
T3
 OJ
   O  CJ5

UJ I—  •—i
I— -
_l

o
•z.
OJ
!Z
)
n3 i —
i— OJ
0 ^
•r™ 'f™
=> •—
pliance
onstrated
E
O
(_)
c=
01
T3
QJ
J3
CO
t3
Ol
ct-

t.
O

j->
0
•z.
OJ
s
(O
o
Q.
O.

t- T3
T3 i—
NJ 3
ft) cn
Z OJ
Q£
iT3
E OJ
O J->
JM CO
ffl T3
•— 3
_^
O
co
-o
L.
r<3
T3
5_ C
OJ (O
•!-> +->
>
fO jj
= •,-
O r-
(— 
-------
      OO
      >    _J
      —.    CL.
««
Z
a:
             o
             o
             C_> LU
       — I     LU OO
^r     <     31
       —     o a
LU     a     o z
_i     LU     a: ^>
CQ     z:     H- u-
 o: u_
o a. o
i i o.
1 — LU-
O «C
h- •
Z CL
3 LU
2: o
0 •
LU h-

LU _J

Q- CO
t—
o z: o
z a£ LU
O LU U_
I ^_ i i
LU
i- s: t-
0:0:0
O LU LU
:r »— u-
oo u_
LU
.
0
LU •
0 X
=2 0
0 h-
OH •
CO
• i
LU -CO
•— ' z QC
a. •— i a:
z: 3 <
o
o


oo
LU
,__,
| —

2;
o:
LU
1—
	 1


1 + -t-

1 +


0 1 +



O I +



o o o
0
i-H


.— ( p-> CO
VD OO




-t- I 1

-(-

1 •+• 1
1 +

1 1 I

1


1 + 1
1
1 + 1


O +

+


0 . 0



o " o



O 0




CM C7*
r^ CM
CM ^r



i i

i

+ +
+

i i

i


4- 4-

-I- -I-


o




o



o



o




^.
CTi
CM



1

1

*

1

1


4-

+

1 -t- + + + +


1 + 1

1

O
1—4
•z. i—
0 <.
•z. — o
O (— •— '
— > LU 	 1 C_J LU U.
h- \— 


0 0


— 1
C3 LU o:
z => LU
— i _i T: z
_J 0 Z (—0
_l OO O i— '
•— • •— ' LU 1 —
U- LU H- 1— O
Q 1 — O i— i ^3
•z. i— < — <
1— 1— 1—
i— i Z (_>
OO LU  f"y
U 	 II —
U- 0 X
O CO LU
vo

-------
           LD UJ — 1 i— «
f—  OO Qi  ID    «3-
—J   i  uj  a;      "

                                                      «l
                                                    co
                                                    CM
           o
    UJ h-  —
«*•  t— Z  t—

  •  OO >  <
i—   i  _i  a:
_i  z: o  i—
eC  O 00  X
                            CO
                            co
                            O

                            C\J
                              *
                            00
                            r-.
                            CNJ
                               0
                               0
                               0
                                                    CTl
                                         LT)
                                         CO
                                         CM
                                         r»»
                                         CM
Lf) 1—1
Q
UJ UJ
_) n
CO UJ
•=C CC
t—
u.
o
>-
rf
o cj o
^ —• o
LU  -cr o
*"^ O"* CD
LO O
r^» o
ro o


00                   O     CO
O            UJ  _J —i     >-D
O        CM h-  
                            XI
                  CL 4->
                  T3 C ^
                 O O) -b^
                     E -—
                 i— OJ

                 .«-> O_ u^
                  O B  O
                 I— — O
                                C  •
 u -~^
 IT3
'— -t->
 Q. l/l
 Q)  O
ry ;_}

-------
                               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
                                         ? r •" •::•r-' er": t •--11
                                         _,,-  HC.-£< 1 th  f-

'''••3  r •'_;=•• i-i-   -"•.•'•   T •;•   i'..  S v b -:: ^ -: '  i" •
" _c, .•:: 1 1 -2-ci  i:    ti  o   Er";   . »-. _-•••• rp.:."- t ~
.he  '"- c-'-e d : ;- i   I r> -er 1 1 Q :••". j c r-: • - -i-
. "": :• t   i.^U   '/ -7- ": ';• ' ' r- ;: '. .(  i '- '-•:   ': f 1-  ".:
"-'* otect. i ^r
i 'j i 1 a 1 >  St'
J  '£ p -' 1 r: C r
                                                                       F-.'t-c, : i t>~  •   • f^V.-L'R '•   h;- =  bean
                                                                     iq>--ncv   ''£?:'i-«'   t c  r^-'ietj  .^rrj  e •
                                                                      y  :-nd   End :-nq-3'r iT.cn L  >-i s L •.-• 5 ^ IT. e
                                                                     '. p t-r f L' fi d  Bite  1 CC f> L -:
K ' >--• r. -
                                       -t£  ,   L'- •-•
                                        t   *-'<"":-L::;'
                                                                              0*-fiCL-  -for  Hc-=il\h  F.5--
                                                                              i ij  o-  tho  opinion  th?
                                                                 CL""r.3nt  e.rd  potc?rtiel  public
r 1 1 t i =' -   i n d i c £• 1 1 o n
^ -r- ::cc-p •".-"'"] i  '' i •; !  -z
                                ^' r c-  1 1" a t   •'-> T Ej E1 R  r e -r o r> m c n d =•. 1 1 o n E  will   be  directed   t o w ? r d
                               • ; £ oc i ::-t'Td   i->i th  direct  public  contact  end /-or  potent i«?l   -3 i
                                                            '    L 5.:-l   P.   Hick=;m,  R.

-------
APPENDIX C

-------
                  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.

-------
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.

-------
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.

-------
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.

-------
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

-------
                                  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

-------
                                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

-------
                                 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

-------
                                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)   »
-------
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.
                                                                                   \
                                                                                     I

-------