United States
Environmema! Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/017
November 1986
&EPA
Superfund
Record of Decision
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~~
SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
FOR SOURCE CONTROL
HARDAGE/CRINER SUPERFUND SITE
MCCLAIN COUNTY. OKLAHOMA
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J
,
TECHNICAL REPORT DATA
(Pleale read Inrtl'UCIIOffS Off the revene before com"letmgl
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-87/017
',. TITLE AND SUBTITLE 5. REPORT DATE
~UPERFUND RECORD OF DECISION November 14, 1986
Hardage/Criner, OK 6. PERFORMING ORGANIZATION CODE
First Remedial Action
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
I 1. CONTRACT/GRANT NO.
12. SPONSORING AGENCv NAME AND ADDRESS 13. TVPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. ,.. SPONSORING AGENCV CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Hardage/Criner site is located in McClain County, Oklahoma, approximately 15
miles southwest of Norman, Oklahoma. The area is agricultural with land on all sides of
the site used for grazing cattle. From September 1972 to November 1980, the site was
operated by the Royal Hardage Industrial - Hazardous Wasteland and Disposal Facility and
as permitted to accept all types of industrial and hazardous wast.es except radioactive
materials. The types of waste included: oil, recycling wastes, chlorinated solvents,
styrene tars, acids, caustics, paint sludges, lead, chromium, cyanide, arsenic,
pesticides, inks, PCBs, and large quantities of unknown wastes from injection wells and
other facilities including what became the Brio and Bioecology Superfund sites.
Originally, two pits were excavated; liquids and sludges from drums and tank trucks were
discharged directly into these unlined pits. However, both pits filled to capacity.
Wastes from the pits were transferred to temporary ponds and then piled on a sludge
mound. A total of 18 to 20 mill ion gallons of waste was disposed at the site. In 1978,
the State of Oklahoma filed complaints against the facility for suspected lead poisoning
of air around the site. In September 1979, the Oklahoma State Department of Health
(OSDH) began proceedings to revoke the facility permit for operating unpermitted pits,
failure to seal permeable lenses in the pits, improper closure of pits, failure to
retain runoff and improper storage of wastes. Site operations ceased in November 1980.
(S@e Attached Sheet)
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI FII~ld(Group
Record of Decision
Hardage/Criner, OK
First Remedial Action
Contaminated Media: gw, soil
Key contaminants: chlorinated solvents;
chromium; inorganics; lead; organics;
PCBs; VOCs; toxaphene
'ISTRIBUTION STATEMENT 151. SECURITY CLASS ,T/usReponl 21. NO. OF PAGES
None 94
20. SECURITY CLASS IT/us pagel 22 PRICE
None
!PA 110'''' 2220-1 (Rn. 4-77)
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EPA/ROD/R06-87/017
Hardage/Criner, OK
First Remedial Action
16.
ABSTRACT (continued)
Royal Hardage undertook site decontamination and closure efforts which
. extended into 1982. These efforts included; mixing pit fluids with soil;
excavating visibly contaminated soils from mixing areas and temporary ponds;
capping the source areas with a soil cover; and consolidating wastes in the
source areas. The primary contaminants of concern to the soil and ground
water include: chlorinated solvents (1,2-dichloroethane;
1,1,2-trichloroethane; l,l-dichloroethene, tetrachloroethene and
trichloroethene), lead, chromium, PCBs and toxaphene.
The selected remedial action includes: excavation of approximately
180,000 cubic yards from the principal source areas (the drum mound, main
pit, and sludge mound) to bedrock and separation of wastes; treatment and
disposal of solids in an onsite RCRA-constructed and operated landfill cell;
in incineration of organic liquids; treatment and disposal of inorganic
liquids; and, temporarily close areas of residual contamination at former
source areas until remedial action is selected under the second operable
unit. The estimated capital cost is $68,014,000 with present worth O&M
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RECORD OF DECISION
(ENFORCEMENT DECISION DOCUMENT)
Site
Hardage/Criner located in McClain County, Oklahoma
Documents Reviewed
I am basing my decision on the following documents which describe the
cost-effectiveness of source control remedial alternatives for the
Hardage/Criner Site:
0 Field Investigation and Data Summary Report, Royal Hardage
Industrial-Hazardous Waste Site near Criner, Oklahoma, by CH2M Hill,
dated May 1984.
0 Source Control Feasibility Study, Royal Hardage Industrial Hazardous
Waste Site near Criner, Oklahoma, by CH2M Hill, dated February 1985.
0 Preliminary Public Health Assessment for Groundwater Ingestion for
the Hardage/Criner site by CH2M Hill, dated August 1985.
0 Summary of Remedial Alternative Selection, November 1986.
0 Data gathered prior to and during enforcement actions in 1982 as
described in Appendix A to the Summary of Remedial Alternatives.
0 August 1986 memo, Bill Langley to Bob Davis describing review and
confirmation of 1984 data from sludge mound sampling.
0 Public comments received March 10 - April 15, 1986 on the Source
Control Feasibility Study.
0 Community Relations Responsiveness Summary, November 1986.
0 Staff summaries and recommendations.
0 Reference materials for the documents listed above.
Description Of Recommended Final Source Control Remedy
Excavate the principal source areas (drum mound, main pit, and
sludge mound) to bedrock and separate wastes for treatment as follows:
0 Solids - treatment and disposal in an on-site landfill cell constructed
and operated in compliance with the Resource Conservation and Recovery
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,
2
o Organic liquids will be incinerated.
o Inorganic liquids will te treated and disposed by other means,
as apjJropriate.
Temporarily close areas of residual contamination at the former source
areas until remedial action is selected under the second operable unit.
Decision
Consistent with the Comprehensive Environmental Response, Compensation,
and liability Act of 1980 (CERCLA) and the National Oil and Hazardous
Substances Contingency Plan (40 CFR Part 300), 1 select the remedy
described above (alternative number seven from the Source Control Feasi-
bility Study) for the Hardage/Criner site. I have detenmined that this
remedy is cost-effective and is protective of public health and welfare
and the environment. The action will require operation and maintenance
to maintain the effectiveness of the remedy. Since wastes will ,be left
on-site. the remedial action will be reviewed every five years to assure
that the remedy is still protecting public health and the environment.
The State of Oklahoma has been consulted on the remedy. I have considered
Section 121 of the Superfund Amendments and Reauthorization Act of 1986
(SARA). including the cleanup standards thereof, and certify that the
portion of the remedial action covered by this Record of Decision (ROD)
complies to the maximum extent practicable with Section 121 of CERCLA (as
amended by Section 121 of SARA). .
If negotiations are successful. potentially responsible parties (PRPs)
will enter into a Consent Decree with EP.A authorizing the PRPs to implement
the remedial action. In the event that negotiations are unsuccessful.
on-going litigation will be pursued by EPA and the Department of Justice
in an effort to se onmance of the remedial actions.
- ances E. Phillips
Acting Regional Administrator
If hA./ /s"
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.
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
--..-
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
HARDAGE/CRINER
MCCLAIN COUNTY. OKLAHOMA
Site location and Description
Operating History
Current Site Status
Risk to Public Health and Welfare and the Environment
Alternative Development and Screening
Selected Alternative
Compliance of Remedial Action with Applicable or
Relevant and Appropriate Requirements
Operation and Maintenance of the Remedy
Com~liance of Source Control Remedy with Section 121 of the Superfund
Amendments and Reauthorization Act of 19~6 (SARA) to the Maximum
Extent Practicable .
10.0 Other Operable Units
11.0 Enforcement
12.0 Community Involvement
13.0 References
APPENDICES:
A)
B)
Chronology of EPA Site Investigations Prior to 1984
list of Potentially Responsible Parties Identified for the
Hardage/Criner Site
C)
Community Relations Responsiveness Summary on the Source
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ICALI 'N MILII
OKLAHOMA
.CITY
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FIGURE 1:
.PROJECT
liTE
'...)
. ITA fa 0., OKLAHOMA
Site location map
(Hardage/Criner ROD 11/86
"-
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('
nort:h
1" : 300'
FIGURE 2:
Site topographic ~ap
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SUMMARY OF REMEQIA~ ALTERNATIVE SELECTION
HARDAGE/CRINER
MCCLAIN COUNTY, OKLAHOMA
NOVEMBER - 1986
SITE LOCATION AND DESCRIPTION
1.0)
The Hardage/Criner site is located in McClain County, Oklahoma,
roughly 15 miles southwest of Norman, Oklahoma and 1/2 mile east of
the community of Criner (Fig. 1). The area is agricultural with
land on all sides of the site used for grazing cattle. Oklahoma
Highway 24 forms the southern boundary of the site and a gravel
road runs along the east side of the site (Fig. 2).
2.0)
OPERATING HISTORY
The Royal Hardage Industrial - Hazardous Waste land Disposal Facility
was issued an operating permit by the Oklahoma State Department of
Health (OSDH) in September 1972 and commenced construction immedia~
tely. Two pits were excavated, the main pit and the south pit.
Originally, liquids and sludges from drums and tank trucks were
discharged directly to these unlined pits. The methods of liquid
disposal were evaporation and infiltration; however, the main pit
filled to capacity rapidly. Waste from the pit was transferred to
temporary ponds, the "west pond" area, where liquids were slurried
with soil, transfered on to the south pit and disposed concurrently
with styrene tar and oil recycling residues. The south pit was
eventually filled in and waste piled to a height of about 10 feet
above grade, forming the "sludge mound". After the first years
operation, drums were no longer emptied, but rather piled at the
north end of the main pit beginning the "drum mound". The mound ."
was extended southward and built to a height of about thirty feet.-
In all, roughly 18 to 20 million gallons of waste we~ disposed at
the site during its operation. The sequence of operations has been
compiled from OSDH inspection reports and a deposition and hearing
testimony of the facility owner/operator. In 1978, the State of
Oklahoma filed complaints, against the facility for suspected lead
poisoning of air around the site. In September 1979, OSDH began
proceedings to revoke the facility permit for operating unpermitted
pits, failure to seal permeable lenses in the pits, improper closure
of pits, failure to retain runoff, and improper storage of wastes.
In September 1980, the U.S. Department of Justice (DOJ) filed suit
on behalf of the Environmental Protection Agency (EPA) against the
facility under Section 7003 of the Resource Conservation and Recovery
Act (RCRA). Operations ceased in November 1980 prior to the effective
date of RCRA interim status requirements. Royal Hardage then
undertook site decontamination and closure efforts which extended
into 1982. These efforts consisted of mixing fluids in the pits with
soil, excavating visibly contaminated soils from mixing areas and
temporary ponds and capping the source areas with a layer of soil.
During closure, an effort was made to consolidate wastes in the
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4
--.- -
3.0)
CURRENT SITE STATUS:
3.1)
Site Investigations:
The site was inspected frequently by OSDH during its operation.
Inspectors reported widely varying conditions, with problems init-
ially centered around pits filled to capacity and the potential for
overflow. In 1976 OSDH requested that Hardage installed groundwater
monitoring wells in the southwest drainage. Eventually, thirteen
monitoring wells were installed by the operator. These have been
periodically sampled ever since, showing uniformly high levels of
contamination. Some Hardage wells may have become contaminated by
surface runoff entering the well bore during and immediately after
construction. However, repeated purging of these wells has not
lowered the levels of contaminants.
EPA first inspected the site in July 1979 due to asbestos disposal.
EPA contractor Ecology & Environment (FIT) collected samples at the
site in August 1979, August and October 1980, and in March and
August 1982. In 1984, work was begun by EPA contractor CH2M Hill
to gather supplemental data to allow preparation of a Feasibility
Study (FS) for permanent remedial actions on the site. This supple-
mental data was compiled and field work was documented in a Data
Summary Report (DSR) completed in May 1985. A chronology of EPA
sampling"efforts prior to 1984 is given Appendix in A.
3.2)
Contaminants:
The site was permitted to accept all types of industrial and hazardous
wastes except radioactive materials (OSDH-1972). A total 18 to 20
million gallons of waste was logged into the site. The resulting
mixture contains virtually every type of waste produced by industries
operating in the States of Oklahoma and Texas from 1972 through 1980.
The general types of waste accepted at the site included: oil
recycling wastes, chlorinated solvents, styrene tars, acids, caustics,
paint sludges, J.e.ad-, chromium, cyanide, arsenic, pesticides, inks,
PCBs, and large quantities of waste of unknown content from injection
wells and other facilities including what became the Brio and Bio
Ecology Superfund sites (Hardage 1972-1980, Eltex 1985). Under each
of these broad waste types are numerous specific wastes streams
produced from perhaps hundreds of different industrial processes,
each waste having it's own unique characteristics, impurities, and
inherent hazardous and toxic properties.
Some of the contaminants which pose an immediate threat through
groundwater are chlorinated solvents, including: l,2-dichloroethane,
l,l,2-trichloroethane, l,l-dichloroethene, tetrachloroethene, and
trichloroethene (CH2M Hill 1986a). Other compounds such as lead,
. chromium, PCB, and toxaphene are present on the site and will pose
long term or permanent hazards due to their persistence in the
enviro,ment. This is by no means an exhaustive list of either the
wastes sent to the site or the contaminants of concern; further
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5
3.3)
Remaining Features:
Source areas include the main pit, drum mound, and sludge mound
(Figure 2). The slude mound covers 1.5 acres to a thickness of
from 15 to 20 feet above and within the former south pit.
The main pit covers about two acres with a 15 to 20 foot thickness
of waste having been slurried with soil and backfilled into the
pit, bringing it to the grade of surrounding land on the east and
forming a steep berm 10 to 20 feet high on the west. A high concen-
tration of drums is located along the west side of the pit and in
the barrel mound which covers about 0.8 acres to a thickness of 30
to 40 feet. Estimates of the number of unemptied drums remaining
in the source areas ranges from 10,000 to over 20,000, with knowledg~-
of site operations and history favoring the latter (Hardage 1972-80).
Other areas of the site were used as temporary holding and mixing
ponds or may have been incidentally contaminated during site oper-
ations. These areas are the west ponds, east ponds, north pit, and
the southwest drainage (Figure 2).
Two buildings are still on-site. A former sludge drying building
used during the last year of operations is located northeast of the
drum mound. A barn, used as the office, is between the sludge
mound and main pit.
3.4)
Hydrology:
North Criner Creek runs in a northwest to southeast direction south
of the site with the alluvial valley extending nearly to the south-
west corner of the site. This stream is perennial and joins Criner
Creek roughly one mile south of the site. Criner Creek empties
into the Wlshita River thirteen miles south of the site.
A stream runs along the east side of the site, about 400 feet east
of the waste areas. This stream has been impounded to form a chain
of three small lakes totalling about 6 acres. Another two acre
pond lies about 1500 feet west of the drum mound.
3.5)
Geology:
The site lies in what are commonly referred to as Nredbed" sediments.
This is a thick sequence of shales, mudstone, and sandstones which
grade back and forth over the space of tens to hundreds of feet.
The geology was originally described as consisting of the Bison
shale overlying the Purcell sandstone. Site investigations indicated
these units are not differentiated at the site; so shallow bedrock
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-.'- --
6
Beds generally dip to the south and southwest at less than 5°.
No major faults are believed to underlie the site. However, a well
defined regional joint system is present with joint sets obse~~ed
at N 20° W, N 20° E, and N 50° W (Kent 1982).
The alluvium of North Criner Creek is 40 to 60 feet deep at mid
valley and made up of decomposed bedrock from adjacent uplands.
3.6)
Geohydrology:
The groundwater table beneath the site generally follows topography
and flows are to the southwest and east. Adjacent monitoring wells
completed at different depths strongly indicate a vertical (downward)
flow component exists. Shales and mudstones underlying the site
are fractured and provide a secondary permeability which, coupled
with horizontal sandstone beds, has allowed migration of leachate
from 400 to as much 2000 feet laterally through the bedrock and
over 50 feet beneath the bedrock surface. Questions exist on the
method of transport to the southwest, where waste has migrated over
2000 feet by unconfirmed pathways to enter the alluvium of North
Criner Creek and apparently form a plume over 1000 feet. long in the
alluvial aquifer. Further evidence of the bedrock's inadequacy as
a barrier to migration is provided by consideration of contamination
in two of the CH2M Hill- 1984 wells (BW-4, GTW-3) and in a series
of four FIT - 1982 wells (EW-3,EW-5,EW-6, and EW-7) located to the
east and southeast of the sludge mound. These wells are in areas
where no site operatiQns occurred and whe~e runoff would not be
channeled by topography. The observed 400 feet of migration into'
these wells over the twelve years between 1984 and 1972 indicates a
rate of transport greater than 33 feet per year.
3.7)
Areal Groundwater Supplies:
Where possible, resideDts of the area have drilled water supply
wells into the shallow alluvium of streams such as North Criner
Creek. However, farms not located in alluvial valleys and without
access to these supplies can and have drilled producing wells into
the Hennesey formation within one mile of the site. Although not
formally classified, both the Criner and North Criner Creek alluvial
aquifers and the Hennesey formation would generally be categorized
as Class lIb under the EPA Groundwater Protection Strategy.
Fresh water in this area is generally contained in the upper sediments,
with water becoming progressively more salty or brackish with depth
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DlAGRAMMAT1C SECTION SHOWING BASE OF THE FRESH. WATER BODY IN GENTLY DIPPING SANDSTONE BEDS
I
FIGURE 3:
Regional hydr~~eology
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8
3.8)
Extent of Contamination:
Groundwater has been contaminated beneath a~d adjacent to the
source areas, in the southwestern drainage, and to the east and
southeast of the source areas to depths greater than SO feet. The
alluvium of North Criner Creek has been contaminated, as evidenced
by the presence of from 100 to 300 ppb of volatile organic chemicals
in three separate wells, which indicates a plume over 1000 feet
long (Figure 4). The relative contribution of surface and subsurface
pathways to alluvial contamination is unknown. However, transport
rates observed on other parts of the site indicate the source areas
will, over time, continue or begin to introduce contaminants to the.
alluvial aquifer through surface and subsurface migration routes.
Soils may be contaminated over several tens of acres as a result of
indiscriminant operations and closure. Evidence of this is provided
by both visible surface contamination and stressed vegatation.
Determination of the extent of surface contamination will require a
significant sampling effort during the second unit RI to adequately
define the areas requiring remedial measures.
4.0)
RISK TO PUBLIC HEALTH AND WELFARE AND THE ENVIRONMENT
Many of the compounds present at the Hardage site are either known.
or suspected carcinogens. Other compounds either are or are believed
to be acutely toxic or capable of causing damage to specific organs.
Some of these compounds also biD-accumulate in plant, animal, and
human tissues.
The principal routes of exposure for humans are: Groundwater
ingestion, direct contact, ingestion resulting from contamination
of the food chain and possibly exposure to airborne contaminants.
The alluvial aquifer of North Criner Creek represents the most
readily available source of drinking water in the vicinity of the
site. This aquifer is contaminated with varying amounts of several
chlorinated solvents, as evidenced by sampling of water from the
abandoned Corley well and three alluvial monitoring wells. Since
several of the compounds detected in these samples are either known
or suspected of inducing cancer and/or damage to specific organs
of the body, chronic consumption of this groundwater would pose
unacceptable health risks.
The Smith and Atkinson/Bearden wells are located 200 and 700 feet
respectively from contaminated monitoring wells. Domestic use of
water from the abandoned Corley well or the EPA monitoring well
AW-S03 would pose lifetime cancer risks in excess of 10-4. Use of
groundwater from on-site would pose an excess lifetime cancer risk
-------
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VOLATlI.l ORGANICS ~l COI 1\01 SU3 SOl
1,I-dtchloroethane 29 14 20 NO
1,1- dichloroethene 12U 82 6U 14
tetrachloroethene 6.6 5.5 <4 NO
1,2-tralls-dichloroethene 79 < 4 1 NO
trich1oroethene 9.2 NO <3 NO
l,I,l-trich1oroethane 63 6.1 30 <
1,I,2-trich1oroethane 11 < 5 NO
< l"c;s than detection limit
NO ot detected
.
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horth
Criner Creek
(approximate
location)
. Domestic (OW) and
Alluvial (AW) wells
* Contaminated well, results from
1984 sampling shown
0' 500' 1000'
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1 inch: 800 feet
FIGURE 4:
Contamination observed in
off-site alluvial aquifer
of North Cri 'Creek
(U.....A..,.,..fr............
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10
---- ....
Direct contact with wastes on the surface of the site also poses
hazards; however, the health risk has not been quantifi€d. Deter-
mination of acceptable levels of surface contamination will be a
primary concern in the second unit FS. Current human traffic on
the site is minimal; but cattle do occasionally graze on the site.
Contamination of the food-chain by lead, chromium, pesticides, and
PCBs, on the surface of the site poses long-term hazards. This
concern has prompted construction of a fence to keep cattle off of
the source areas; however, there is evidence of continued intrusion
by cattle, giving rise to concerns of food chain contamination.
Certain compounds such as pesticides and PCBs have the ability to
bioconcentrate through successively higher levels of the food chain
(EPA 1985a).
Inhalation of volatiles and contaminated airborne particulates on
and possibly adjacent to the site may also pose long term hazards;
however, this has not been confirmed.
5.0)
ALTERNATIVE DEVELOPMENT AND SCREENING
In accordance with Section 300.68(f) of the NCP and EPA guidance
documents (EPA 1985b), several alternatives were developed for
source control remedial actions at the Hardage/Criner site. Scoping
of general alternatives and objectives for remedial action was first
discussed in a 1983 meeting between EPA, OSDH, and EPA contractors.
After reconsidering these objectives and alternatives in light of
the decision to proceed with a source control operable unit, .
eleven alternatives were developed (Table 1), as documented in the
FS. Of these alternatives, four were retained after screening and
developed in further detail (see Section 5.2-5.5 below). Estimated
cost ranges for the four alternatives retained are shown in Figure 5.
5.1)
Alternatives eliminated in screening:
The most notable result of alternative screening was the elimination
of those plans for containing the wastes in place. Several methods
of isolating the wastes and reducing or eliminating their release.
were considered. After screening of technologies, severa~ in-situ
containment plans were developed. Of these, capping in conjunction
with vertical trenches to intercept shallow groundwater (Alternative
#5) would be expected to be the most effective. While this plan
may be the most effective in-situ containment plan, it can by no
means be considered as an adequate remedy on that basis alone.
Consideration of this alternative did, however, serve as a test of
whether or not any form of capping-in-place remedy would sufficiently
contain the source areas. Technologies such as slurry walls and
groundwater injection/withdrawl were eliminated due to the presence
of fractured bedrock, obser',ed vertical migration of contaminants,
-------
4
11
TABLE 1 - Source Control Remedial Alternatives
)
Alternative No. 1 - No ~ion: no lIte r~ial a~1on tAken.
Alternative ~o. 2 - Li1rJted A..--tIon: r~ial L.--tion CQ~ists of
vracHr.;, re\1e~tation, fe:i:in; ~ institutional restr ic:tions for
the lite. .
>
)
Alternative No. 3 - ~ring: ~-~ 8O:Jroe areas te.u~ be left in
pla...--e a.rx5 co \Ie r ~ wi th a IrIiJl t i -lajle r ~ cAp.
Alternative N:>. 4 - Op;r~ierrt Cruns: the 8OIJroe areas teu.l~ be
le...~ in plA...--e, cover~ with a nJlti-laj'er Cat' W up;ra~ent
.. r cu ~ toe r c!.r Ai rs CO:"aS t.r 1JI:t.8d . "
)
)
Alternative N". 5 - Perin'eter t>ralns: ~IJroe areas '-C~~ be left in
p~, co'.lered with a ~ti-la:ter C8? ~ up;r~ie~ and
c5~r~ie::'t ~round.eter c!rLins cor.str~8d.
Alternative N". 6 - Pa..""'tial ~val: a ~ W per ~er c5rainl
~~~ be cc:-.strOJ:'ted &rO~~ the "ll:J~3e II:C~, t.~e lMin pi t L~
barrel m::>.rd v.:>;.Ud be excavated, the ~tes treat~, as needed, ant5
c5iaro~ of in L"i on-sit.e ~liL...t ~ 1A..~ill.
)
)
Alternative N:>. 7 - ~~ite Cirposals both ~W'oe areas WQ~~ be
e.xcavat~, the wa.stes treated, as ~, ...~ c!il;os.ed of in L"j ~-
aite ~ ~liL"it lL~ill.
Alternative N". . - ~Iite Incineration L~ Cilposal: ~..h 8OIJroe
areas ~~~ be ex::aV8t~, the -.stes 1ncinerat~ on~ite ...~ c!il-
p:>sed of in L"'1 on-lite ~ CcrTpliL"'1t ~fill.
)
)
Alternative No. , - On1Ite Inclnerat1on/Off-site CilpolUS aoW'ce
areas w:>~~ be exc:avat8d, the ..utes incinerated on lite ...~ 4i1-
ped cf in In cff1ite ~ ~liL"%t 1.tM!W.
Alternative No. 10 - Off-slte CiSiClals both 8OI.2roe areas tCul~ be
8Xcavat~, the wastes treated on..it.e to .et 1a.ndfill criteria an~
trL~FOrt~ to an off-lite kCV\ ~11&nt ~fill.
)
AltematiYe ~. " - "0!!1ite Incinerations bo"..h ao:.ree areas wo;A~
be e.xcava~ L~ the ajor1ty of the ..utes trL~;crted to an off-
aite inoMrator for 1nd.neratlon ~ c!i1p08&l.
* Off-site incineration was assumed in some cases for cost-estim~ting
purposes. This does not reflect a final decision to use off-s,te
disposal facilities for any waste from the Hardage site.
-------
. .00
-
ID
K
C
-
eJ
C 100
c
~
c
.
a
2
eJ
.I
- 100
a
-
..
.
0
Co>
100
----.-- -- ----
o
AL TI"NA "VI
"0.
"AWE
100
- .
---- --
'.0
-
..,
-
I'.
.
II'
-
I"
II'
-
",
'II
- 10. .
'0 ,.
-- .. -- - -- --- - ---- --
- - - -----.-
100
,
. .
ON-'rTE OW-lrtE
IHCINERA T.oN 8HCINERA'ttONI
ANO DJI'OIAL C"-lrTl
DII'O.AL
'0
ON- liTE
DI"O'AL
O',-lrTE
DII'O.AL
U"I" MU..r" al'''III'-'1 U" I" .IOU.-D CO.-DI'IO..,
_'DDLI "U"II" "I'''III.-T' IA.I CO.DITIO..,
&,0-1" "U"II" "1'''111.-,. LOWI".IOU.D CO.-DI'IO..
-FIGURE 5:
Costs and sensitivity
ranges for source control
remedial alternatives
-------
13
reasonable depth with sufficient integrity to provide a natural base
to any engineered containment system. Further discussion of these
capping-in.p~ace or in-situ containment technologies and the rationale
for their rejection is presented in both the Source Control FS and
the Responsiveness Summary (Appendix C).
Consideration of the cap and drain alternative revealed the presence
of the same flaws as existed in other plans for containing wastes.
The drains were first considered to a depth of five feet below the
present groundwater surface. However. migration has been observed
to over thirty feet below the water table. indicating that intercep-
tion substantially deeper than five feet would be necessary to
provide meaningful reductions in the releases now occuring. In
addition. free liquids present in the landfill and in drums which
will continue to deteriorate and burst would be released and allowed
to migrate vertically until the source was exhausted. The plan
involving shallow (five foot) trenches was estimated to cost $35-40
million. Extensive and continous operation and maintanence (0 & M)
for the indefinite future would be necessary to maintain the collection
system. It was estimated that for collection rates greater than
0.5 gallons per minute, economics would indic!te construction of an
on-site treatment plant. The problems associated with operating
such a system for the indefinite future, meeting discharge requirements
and handling occasional peak flows could be significant. In addition.
there is no method for assuring the longterm operation of such a
treatment system.
The continued release of hazardous wastes and hazardous substances
with only negligible lateral interception and no vertical intercep-
tion, the need for indefinite 0 & M when such cannot be assured.
the potential for continued off-site impacts. and the entire
"band-aid" type of approach that this. the most viable in-situ
containment alternative entails is wholly inadequate to meet the
objective of CERCLA and the directive of the NCP to provide a
permanent remedy meeting or exceeding applicable or relevant and
appropriate Federal public health and environmental requiremnts.
As a result, closure in place was rejected as being incapable of
containing wastes in the immediate vicinity of the site and unac-
ceptable as a permanent source control remedy.
5.2)
Alternative 7 - On Site Disposal:
The source areas (drum mound. main pit. and sludge mound) would be
excavated. Solids would be treated and disposed in a landfill cell
constructed on-site. Liquids would generally be incinerated.
After completion. the landfill would be closed with a multi-layer
cap and gas venting system. The Remedial Action (RA) would require
about 18 months to complete at a present worth C0st of $70 million
-------
1,
--'--"-
TABLE 2:
ALTERNATIVE NO. 7--0N-SITE DISPOSAL
ITEM
GENERAL
EXCAVATION, SEPARATION, SAMPLING
TREAT AND TRANSPORT DRUMMED WASTES
pN-SITE DISPOSAL
SITE RESTORATION
EVAPORATION/COLLECTION POND FOR SURFACE
WATER
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL
OTBER PROVISIONS
Construction Subtotal
Bid Contingencies (15')
Scope Contingencies (20')
Construction Total
Permitting and Legal (7')
Services During Construction (10')
Total Implementation Costs
Engineering Design Costs (10')
TOTAL CAPITAL COSTS
OPERATION AND MAINTENANCE
(Present Worth)
Bid Contingencies for Operation and
Maintenance (15')
Scope Contingencies for
Maintenance (20')
Operation and
TOTAL OPERATION AN~ MAINTENANCE
(PRESENT WORTH)
TOTAL PRESENT WORTH
* Off-site incineration was assumed for cost-estimati~g pu~poses.
This does not reflect a final decision to use off-slte dlsposal
. facilities for any waste from the Hardage site.
COST
$ 1,800,000
$12,979,000
$ 5,450,000
$12,789,000
$
196,000
$
280,000
. $ 5,403,000
s
249,000
$39,146,000
$ 5,872,000
$ 7,829,000
$52,847,000
$ 3,699,000
$ 5,285,000
$61,831,000
$ 6,183,000
$68,014,000
$ 1,690,000
,
$
254,000
$
338,000
S 2,282,000
-------
15
5.3)
Alternative 8 - On Site Incineration and Disposal:
The source areas would be excavated. Wastes would be incinerated
in a kiln constructed on-site. Ash would still contain metals and,
until proven otherwise through de-listing, would require disposal as
a hazardous waste. Disposal would be in a landfill cell constructed
on-site. This alternative would require four to eight years to
implement at an estimated present worth cost of $326 million (Table 3).
5.4)
Alternative 9 - On Site Incineration and Off Site Disposal:
The source areas would be excavated and wastes incinerated as above.
The difference between this and Alternative 8 would be the off-site
disposal of incinerator ash. This alternative would require four
to eight years to implement at a cost of $374 million (Table 4).
Future 0 & M for this source control remedy would be non-existent.
5.5)
Alternative 10 - Off Site Disposal:
The source areas would be excavated; and wastes would be transported
off-site to existing Treatment Storage and Disposal (TSD) facilities
for landfilling, incineration, reuse/recycling, or other treatment
as appropriate. This alternative could be implemented in about 2
years at an estimated present worth cost of S133 million (Table 5).
As with alternative 9, 0 & M would be non-existent.
6.0)
SELECTED ALTERNATIVE:
Alternative 7 (On-Site Disposal) is selected as the appropriate
remedy for source control at the Hardage/Criner site. The process
by which this alternative was chosen over the other three under
consideration is outlined below.
6.1)
Remedial alternative selection procedure:
EPA is required by Section 300.68(i) of the NCP to determine the
appropriate extent of remedy by, "Selection of a cost-effective
remedial alternative that effectively mitigates and minimizes
threats to and provides adequate protection of public health and
welfare and the environment". The NCP goes on to state that the
selected remedy will attain or exceed applicable or relevant and
appropriate Federal environmental and pUblic health requirements.
EPA has considered the cost, technology, reliability, administrative
and other concerns in selecting Alternative 7 as the appropriate
remedy, as documented below. These considerations have only been
applied to alternatives meeting or exceeding the above noted
-------
TABLE 3:
ALTERNATIVE NO. 8--0N-SITE INCINERATION AND DISPOSAL
ITEM
GENERAL
EXCAVATION, SEPARATION, SAMPLlNG
ON-SITE INCINERATION OF WASTE FILL
TREAT AND TRANSPORT DRUMMED WASTES
.
ON-SITE DISPOSAL
SITE RESTORATION
EVAPORATION/COLLECTION POND FOR
SURFACE WATER
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL
OTHER PROVISIONS
Construction Subtotal
Bid Contingencies (15%)
Scope Contingencies (20')
Construction Total
Permitt~ng and Legal (7')
Services During Construction
Total Im~lernentation Costs
(10\)
Engineering Design Costs (10%)
TOTAL CAPITAL COSTS
OPERATION AND MAINTENANCE
(Present Worth)
Bid Contingencies for Operation
and Maintenance (15\)
Scope Contingencies for Operation
and Maintenance (20\)
TOTAL OPERATION AND MAINTENANCE COSTS
(PRESENT WORTS)
TOTAL PRESENT WORTH
* Off-site incineration was assumed for cost-estimating purposes.
This does not reflect a final decision to use off-site disposal
facilities for any waste from the Hardage site.
COST
$ 7,352,000
$ 12,979,000
$130,500,000
$
2,916,000
$ 10,175,000
$
$
196,000
310,000
$ 21,611,000
$ 249,000
$186,288,000
$ 27,943,000
$ 37,258,000
$ 2 5 1 , 4 8 9 , 0.0 0
$ 17,604,000
$ 25,149,000
$294,242,000
$ 29,424,000
$323,666,000
$
1,384,000
$
$
208,000
277,000
$
1,869,000
-------
TABLE 4:
ALTERNATIVE NO. 9--0N-SITE INCINERATION/OFF-SI~E DISPOS;
ITEM
COST
GENERAL
$
7,928,000
EXCAVATION, SEPARATION, SAMPLING
ON-SITE INCINERATION OF WASTE FILL--
. Design, Construction and Operation
$ 12,979,000
$130,500,000
TREAT AND TRANSPORT DRUMMED WASTES
$
3,788,000
OFF-SITE LANDFILL DISPOSAL CHARGES
$ 16,958,000
$ 20,850,000
WASTE FILL REMOVAL TO OFF-SITE LANDFILL
SITE RESTORATION
$
196,000
EVAPORATION/COLLECTION POND FOR
SURFACE WATER
$
310,000
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL
Construction Subtotal
Bid Contingencies (15')
Scope Contingencies (20%)
$ 21,611,000
$215,120,000
$ 32,268,00"
Construction Total
Permitting and Legal (7')
Services During Construction (10')
Total Implementation Costa
Engineering Design Costs (10')
TOTAL CAPITAL COSTS
$ 43,024,000
$290,412,000
$ 20,329,000
$ 29,041,000
$339,782,000
$ 33,978,000
$373,760,000
OPERATION AND MAINTENANCE
(Present Worth)
Bid Contingencies for Operation an~
Maintenance (15')
Scope Contingencies for Operation and
Maintenance (20%)
TOTAL OPERATION AND MAINTENANCE COSTS
(PRESENT WORTS)
$0
$0
$0
$0
TOTAL PRESENT WORTH
-------
,
TABLE 5:
ALTERNATIVE NO. 10--0FF-SITE DISPOSAL
ITEM
GENERAL
EXCAVATION, SEPARATION, SAMPLING
TREAT AND TRANSPORT DRUMMED WASTES
~STE FILL REMOVAL TO OFF-SITE LANDFILL
OFF-SITE LANDFILL DISPOSAL CHARGES
SITE RESTORATION
EVAPORATION/COLLECTION POND FOR
SURFACE WATER
SURFACE WATER TRANSPORTATION, TREATMENT
AND DISPOSAL
Construction Subtotal
Bid Contingencies (15%)
Scope Contingencies (20')
Construction Total
Permitting and Legal (7')
Services During Construction
Tota: Implementation Costs
(10')
Engineering Design Costs (10')
TOTAL CAPITAL COSTS
OPERATION &~D MAINTENANCE
(Present Worth)
Bid Contingencies for Operation
and Maintenance (15%)
Scope Contingencies for Ope:ation and
Maintenance (20')
TOTAL OPERATION AND MAINTENANCE COSTS
(PRESENT WORTH)
TOTAL PRESENT WORTH
COST
$ 2,538,000
$ 12,979,000
$
7,584,000
$ 21,228,000
$ 26,100,000
$
196,000
$
280,000
$ 5,403,000
$ 76,308,000
$ '1,446,000
$ 15,262,000
$103,016,000
$ 7,211,000
$ 10,302,000
$120,529,000
$ 12,053,000
$132,582,000
$0
$0
$0
$0
-------
19
6.1.1 )
Comparison of on-site versus off-site remedial action alternatives:
Two alternatives, 7 and 8, involve on-site disposal of wastes excavated
from source areas. Alternatives 9 and 10 entail complete off-site
disposal of wastes. The alternatives 7 and 10 involve essentially
the same operations (i .e. excavation with limited incineration and
landfilling for the bulk of wastes), except that they are on and
off-site variations of basically the same alternative. Similarly,
alternatives 8 and 9 are basically on and off-site disposal options
for residue from the on-site incinerator. Based on this point, the
analysis below compares on-site to off-site disposal.
Cost: The cost of off-site landfilling and incineration alternatives
exceed their on-site counterparts by 90% ($63 million) and 15% ($48
million) respectively.
Technology: The on and off-site options will be virtually identical
in the treatment and disposal technologies employed. Control of
the quality of work done under the on-site alternatives may be
somewhat superior in this respect however, since these actions
would be conducted under EPA oversight and off-site treatment or
disposal would not.
Reliabilit~: The off-site disposal options will provide reliability
in preventlng releases from this site, simply because wastes would
not remain on-site. However, .off-site disposal has the pot~ntial
to increase health risks at other sites. It is not certain that any
significant advantage exists in reliability of off-site over on-site
disposal lo:ations. The Hardage/Criner facility is in compliance
with the siting requirements currently governing location of
commercial disposal facilities. For this reason, any particular
vulnerabilities which are present on the Hardage site would not
necessarily be absent at off-site facilities.
Administrative: Each alternative will comply with RCRA Part 264
requirements, long-term objectives of CERCLA as amended, and all
applicable or relevant and appropriate requirements for protection
of public health and welfare and the environment. Since wastes
will be left on-site, the remedial action will be reviewed every
five years after it's completion, as required by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), to assure that
the remedy is still protecting public health and the environment.
Other concerns: (Safety during implementation) Both on and
off-site alternatives carry inherent risks during excavation.
As di scussed 1 ater, these impacts can be controlled. The prima ry
difference between the on and off-site alternatives with respect
-------
20
or spills during off-site transport of the wastes. For example,
an estimated 11,000 loads would be required to transport the
entire 180,000 cubic yards of waste off-site. Fo~ the 400 to
800 mile transport distance ass'umed in the FS, trucks carrying
waste from the Hardage site would be on the road from four to
eight million miles.
Consideration of the components of the four remedial action alterna-
tives evaluated shows that the key difference is the presence of
. an on-site landfill under the two on-site alternatives. Information
collected to date indicates that an adequate landfill cell could be
constructed on-site and successfully maintained. The site meets
RCRA Section 264.18 siting requirements for seismic stability and
flooding potential. Due to the hazards and costs arising from
off-site disposal and transport, clear and significant benefits
should be present before off-site disposal is selected. Those
benefits are not significant or certain in this case. While such
benefits may exist in the off-site treatment of small to moderate
quantities of specific wastes, organic liquids may be an example,
off-site disposal for the entire waste quantity is not preferred
over on-site management of wastes in this case. Therefore, the
off-site alternatives are eliminated from consideration, and the
on-site disposal alternatives (7 - On-site disposal; 8 - On-site
incineration and disposal) will be carried on for further evaluation.
6.1.2)
Comparison of the two on-site alternatives:
Cost: Alternative 7 would cost $39-109 million to implement, with
rne-most likely cost being $70 million. Alternative 8 would cost
$171-495 million, the likely fi.~ure being $326 million. Therefore,
the benefits to be derived from incineration of all waste would
come at a cost of 470~ ($256 million) greater than landfil11ng.
Technolo~~: Incineration is a key component of both alternatives 7
and 8. lnce some wastes are liquids which cannot be landfi"ed,
the decision to incinerate organic liquids is appropriate.
Incineration of all wastes will have the net benefit of destroying
virtually all organic materials. Even with incineration however,
heavy metals will still be present in the residue. These materials
simply cannot be destroyed. The mObility can be reduced by treating
the waste to reduce it's acidity; this would be done under either
alternative.
Reliability: By incineration, virtually all organics are destroyed,
leaving an ash with varying contents of heavy metals requiring
stabilization and disposal as a "characteristic" hazardous waste.
The landfilling alternative, with limited incineration, removes
only the free organic liquids with the greatest potential for
-------
21
Landfilling and incineration of liquids are established technologies,
with a demonstrated ~bility to perform under similar conditions.
Incineration of soils contaminated by a heterogenous mixture of
wastes, while feasible, has not yet been attempted on a scale such
as would be required for complete incineration at the Hardage site.
Administrative: Both alternatives would meet all aplicable or
relevant and appropriate requirements for protection of public
health and welfare and the environment. Since wastes would be
left on-site, the remedial actions would have to be reviewed
every five years as required under Section 121 of SARA.
Other concerns: (time to implement) Landfilling can be accomplished
in 12 to 18 months. Incineration will take four to eight years.
Based on the factors considered above, Alternative 7 (On-site
landfill with liquids incineration) is selected as the appropriate
remedy for the Hardage/Criner site. This alternative will provide
a degree of protection to public health and welfare and the environ-
ment similar to that which could be achieved with complete inciner-
ation. This remedy can also be carried out in a shorter time using
proven technologies which are currently in wide-spread application.
6.2)
Detailed Description of the Recommended Alternative:
The following is a general sequence of operations and construction
activities required to implement on-si~e disposal for a source
control remedy at the Hardage/Criner site. The timing and spec-
ifications will be developed in detail during the Remedial Design
(RD) phase of response.
A landfill cell will be constructed to meet the minimum technology
requirements for hazardous waste landfills as set forth in RCRA
Section 264.301. The key feature of such a landfill cell is a
double liner system with interior leachate monitoring and collection
(Figure 6). The landfill will be constructed above grade on the
high ground west and north of the present source areas, as indicated
in the FS. If at all possible, construction of the landfill cell
over significant residual contamination will be avoided. The exact
siting of the landfill cell will be based on the results of surface
soil sampling during the second unit RI, consideration of topography
and hydrology of the site, and possibly additional geotechnical
data collected during the RD. Sufficient land is available on
which to site a landfill cell.
The sludge mound, main pit, and drum mound will be excavated. This
represents a volume of approximately 180,000 cubic yards, and includes
in excess of 10,000 to 20,000 unemptied drums. tor this operable
unit, the vertical extent of waste excavation will be to the upper
-------
,....,.. .."....,
C..'O. .....
".It". L.Y'.
. .... -:.,
. '",
...
-1' I.'.I..~'
.' ..,..., '0"
.. ...."'.. ~.,..
.. ... .1.'..'''.
,.".
.' C,., "...
U.'..
~ ..na
'.L~
::::: ..:.;:.:.: .:. '....-
~ ...... .- .. ....------
""'~':' =:: ;:..";": .
.. ,.. P'.".'."" ....
H' ,. IC."
FIGURE
6:
Typical
on-site
cross-section
landfill
-------
23
After waste excav~tion, treatment, and disposal (described below),
the empty waste p1ts and bedrocK now underlying the waste piles
will still remain. This upper bedrock surface is believed to be
saturated with waste s~epage to an unknown depth. Such residual
contamination will generally not be removed during the source control
remedial action, since the appropriate extent of vertical excavation
cannot,yet be defined. In order to prevent contamination of surface
runoff waters and to eliminate direct contact exposure hazards from
open areas of residual waste, it will be necessary to construct a
protecti've temporary cap over the former source areas. This temporary
cap will serve the dual purposes of preventing direct rainfall from
leaching the contaminated bedrock and eliminating direct contact
hazards. The cap will be constructed so as to achieve these goals
and at the same time be of a design to allow upgrading to meet rele-
vant and appropriate RCRA closure standards should it be determined
by the second operable unit RIfFS that closure in-place is an
appropriate permanent remedy for residual contamination beneath the
former source areas. Considering the relative times required for
design of the source control remedy and conduct of the management
of migration RIfFS, it is possible that final clean-up levels will
have been developed for the site prior to waste excavation. If
such clean-up levels are available, the interim cap would be unneces-
sary and remedial action for residual contamination in the bedrock
beneath the former source areas c~n proceed directly from excavation
of the source areas.
Since wastes excavated in the source areas will range in consistency
from dry solids to relatively pure liquids, and since the appropriate
means of waste treatment and disposal is in l~rge part determined hy
the physical consistency of the material. it is clear that criteria
will have to be developed during the RD which allow segregation of:
liquids for incineration or other treatment. solids whose moisture
content is appropriate for landfilling. and solids requiring moisture
reduction prior to landfilling.
Liquids will be defined by the relevant and appropriate RCRA testing
procedures (currently the Paint Filter Test) ~hich are effective at
the time the remedial design ;s approved. Liquds will be segr~gated
based on their chemical make-up (i .e. organic versus inorganic as
described in the F~). The RD will develop criteria for making this
distinction.
Solids, as defined by testing procedures noted in the above paragraph,
will be handled in a manner based on decisions made in a moisture
content evaluation, described below under Section 6.2.3. Rased on
the criteria developed there, wastes will have to have to fall below
-------
24
disposal bans. do not preclude their placement in the landfill.
Based on the determinations and criteria from the RD. the wastes will
be treated and disposed as indicated in the general schematic shown
in Figure 7. Discussion of waste treatment and disposal is provided
below.
Treatment of or anic li uids: These liquids will be incinerated.
ased on the economlCS 0 t e volume of materials encountered, this
would be done either at an off-site facility or on-site with a
portable or modular incinerator.
Treatment of inorganic li~uidS: Based on the economics of the
volume and character of t e liquids encountered. treatment and
disposal may be done either on or off-site. On site treatment
would generally be through physiochemical methods capable of removing
both organics and metals. to allow discharge under an NPDES permit
or transport to a publicly owned treatment works. If off-site
treatment is selected. either deep well injection or treatment at a
commercial facility would be available.
Treatment of Solids: Solids will ultimately be placed in the landfill
cell constructed on-site. Prior to disposal, the wastes will be
subjected to treatment aimed at reducing their toxicity and mObility.
Since a large volume of contaminated soil is present. significant
volume reduction would not be possible. Such treatment may include
addition of materials to stabilize the fill or physiochemical
treatment designed to remove or alter specific hazardous constituents
or classes of compoundS. Treatment tec~nblogies identified are:
o chemical neutralization (pH adjustment).
o solidification by addition of lime. cement.
other proprietary agents.
o reduction of liquid content,
o chemical oxidation or reduction, and
o air stripping to remove volatiles.
fly ash, or
Other alternative treatment technologies identified during the
remedial design will also be considered for application, and those
technologies showing promise for the specific wastes and situations
at the Hardage site will be evaluated further through bench tests or
pilot studies as appropriate
During the remedial design, an evaluation including bench testing
will be conducted to determine an appropriate upper limit on the
moisture content of fill which could be placed in the on-site land-
fill. This evaluation will consider the potential composition of
pore fluids in the waste. the reaction of various soil/fluid combin-
-------
WASTE FIll FROM EXCAVATION
~
..
)RCRA test
T
ICriteria developed I
in remedial design
I~
Inorganic liquids
~
I Economi cs of I
volume
I
(high
volume)
J- s lte
phjsiochemical
rotment r
SOlts L1guids
~
Isurface Dlscharge I
Under NPDES Penmit
for liqUidS~
Solid
Treotme~: neutrol1zot,on,1
fixation, or other methods I
determined during remedial
desi n . . I
IEconomics of
volume
I
(high
volume
~
I Un-51te I
incineration
with Inobl1e
or modular
unit
I
Solid
Residues
(low
volume)
~
Off~site
phys i ochemi cal
treatment or
deep well
injection
,on-slte I
Landf; 11
~.
,on-slte I
Landfill
I -s I
/incineratior '
at an existi. f
Ijl
Residues
~
IOff-Sitel
di sposall
r
L1 qui d
Residues
-r
Recycle or treat
and discharge under
NPDES penmi t . .
FIGURE 7:
Treatment schematic for
alternative number 7 -
on-site landfill wit
liquids inc;neratiol
-------
20
~
landfill, the potential for long and short-term leachate generation,
and the effects of such leachate on various liner systems proposed
for the landfill cell. Based on the results of this evaluation, an
upper limit will be imposed on the moisture content of wastes which
can be disposed in the landfill. Wastes placed in the landfill will
in no case be of the type which:
a) would be classified as "liquids" by applicable or relevant and
appropriate testing procedures pursuant to the RCRA prohibition
.on the disposal of liquids in landfills; or
b) are the subject of any land disposal bans under the Hazardous
and Solid Waste Amendments to RCRA or the Toxic Substances
Control Act which are determined to be applicable or relevant
and appropriate.
Treatment technologies will be further refined during the RD phase;
and additional design data may be required. The variability of
wastes present in the source areas precludes any extensive character-
ization of wastes prior to excavation. For this reason, final
determinations on appropriate treatment will in some cases have to
be made during the RA itself.
6.3)
Clean-up Levels for the Source Control Operable Unit:
Selection of clean-up levels will be a concern of the second operable
unit (Management of Migration). Ultimately, ,lean-up levels will
have to be selected for the base of the pits and for surface soils
on-site. In the pit areas, the criteria will generally include
potential for migration of metals and organics which have already
migrated out of the pits. The surface soil criteria will focus on
metals, PCBs, and pesticides due to their persistence in the
environment, direct contact exposure hazards, and potential to
contaminate surface runoff.
The Source Control operable unit deals exclusively with the concen-
trated pits and piles of ~astes. In this :ase, selection! of
compounds of concern and selection of clean-up levels ba~ed on soil
concentrations of these compounds is not appropriate. The criteria
to be used for determining the extent of clean-up will be the
surface of undisturbed bedrock. If, at that point in the RA,
additional data from the second operable unit RIfFS or the Source
Control RD has allowed determination of a final clean-up level,
then excavation, in-situ treatment, or permanent capping may be
implemented for the residual contaminants. If such data is not
available, a temporary cap will be installed over the excavated
-------
6.4)
7.0)
7.1)
27
Health and Safety Concerns During Implementation
Excavation of the waste piles and pits will pose hazards to workers
via air and direct contact in addition to the physical hazards
normally associated with such construction. In many cases the
waste excavation and handling will have to be conducted under level
B protection (containerized air and protective clothing) to mimize
hazards to the workers. Air release of volatile organics will
likely increase during waste excavation. Continuous monitoring of
air around working areas, at the site perimeter, and near offsite
homes will allow identification of health threats to off-site
residents and prevent problems from going undetected. Dust and
vapor suppression measures, maintenance of a small working face of
exposed waste, and possible use of a temporary structure over the
excavation will help to minimize air releases. .
Runoff retention structures and emergency holding ponds will be
used to prevent chronic or sudden releases during construction.
COMPLIANCE OF REMEDIAL ACTION WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR PROTECTION OF PUBLIC HEALTH AND THE
ENVIRONMENT .
Section 300.68(i) of the NCP directs that EPA will, except in narrow
cases such as "fund-balancing", select a remedy that "attains or
exceeds applicable or relevant and appropriate Federal public health
and environmental requirements that have been identified for the
~pecific site." These applicable or relevant and appropriate
requirements (hereinafter "Requirements") are discussed in an
October 2, 1935 memorandum from Winston Porter, Assistant Adminis-
trator for EPA's Office of Solid Waste and Emergency Response,
"CERCLA Compliance with Other Environmental Statutes", which is set
forth in the preamble to the NCP at 50 Fed. ~. 47912, 47946
(November 20, 1985).
The principal requirements and policies to be considered during
conduct of the RA will be as follows:
RCRA Subtitle C Penmit Requirements, 40 CFR Part 264:
While not deemed applicable to the site since it closed prior to
November 19, 1980, these requirements are considered to be relevant
and appropriate to this CERCLA response action to the extent indicated
below. leaving engineering considerations aside, the Part 264
permit requirements are considered appropriate rather than the Part
265 interim status requirements. The facility closed prior to the
effective date of interim status, rather than attempt to comply
with these standards. Royal Hardage notified EPA of hazardous
waste activity under RCRA in August 1980, but .withdrew the notifi-
cation in November 1980 and did not file Part A of the RCRA permit
-------
28
standards without bankrupting the facility. As indicated previously,
wastes were disposed haphazardly in unlined pits and the treatment,
storage, and disposal of hazardous wastes at the facility as far
below the standards required for interim status facilities. Indeed,
EPA filed a lawsuit seeking clean up and closure of the facility
under RCRA, Section 7003 in U.S. District Court in Oklahoma City on
September 8, 1980. EPA has conclusive and demonstrable evidence of
releases of hazardous wastes and hazardous substances from the
disposal units of the Hardage site. Given this situation, the most
appropriate Federal environmental requirements to apply to the
source control action, which is consistent with and forms a
substantial increment of a permanent site remedy, would be the Part
264 requirements, applicable to new facilities, along with their
more stringent closure requirements.
Additionally, EPA believes that the physical nature of the site,
it's hydrology, and underlying geologic conditions dictate that the
waste materials not be left in-place. Accordingly, it is clear
that the Part 264 permitting and closure requirements should be
applied to the construction and closure of new disposal units
necessary for this facility.
Finally, it should be noted that, as the preamble to the NCP states,
. "... although the Subtitle C regulations differ as to whether a
hazardous waste facility has a RCRA permit (40 eFR Part 264) or is
operating under interim status (40 eFR Part 265), remedies will
generally have to be consistent with the more stringent Part 264
standards, even though a permitted facility is not involved. The
Part 264 standards represent the ultimate RCRA compliance standards
and are consistent with eERClA~s goals of long term protection of
public health and welfare and environment.u 50 Fed ~ at 47918.
7.1.1) Subpart B - Siting Requirements:
This will govern placement of the landfill cellon-site. The
principal concerns stated in this subpart are seismic stability and
flooding potential. Neither factor appears to be a major concern
at the Hardage site; therefore, compliance does not seem to pose
problems.
7.1.2)
Subpart F - Groundwater:
This subpart will determine the extent to which the on-site
landfill will be monitored. It will have a much wider application
-------
7.1.3)
7.1.4)
7.1.5)
29
Subpart G - Closure and Post-Closure:
These standards will apply to closure of the landfill cell(s) after
completion of the source control RA. The remedy will comply with
this subpart.
Subpart K - Surface Impoundments:
This will apply to any temporary impoundments constructed during
the RA that treat.~ore.or dispose hazardous wastes. Impoundments
will be lined. op~ ed. closed. and if necessary monitored in
compliance with thi subpart.
Subpart N - Landfills:
This subpart will govern construction and operation of the landfill
cell. The landfill will ~
~meet requlrements set forfh for new landfills.
7.2)
Toxic Substances Control Act:
This would come into application if PCBs are encountered at levels
greater than 59 ppm. since such materials are banned from land
disposal. In that case. alternative treatment would be required
and implemented in order to comply with the Act.
7.3)
EPA CERCLA Off-Site Policy (memorandum dated May 5. 1985; "Procedures for
Planning and Implementing Off-site Response Actions"):
This policy will determine which TSD facilities are eligible for receipt
of hazardous substances from the site. The policy generally requires a
facility to be permitted and have no significant RCRA violations or
conditions affecting it's satisfactory operation. Prior to disposing
or authorizing disposal of wastes from this site the Region will
contact the State in which the facility is located. review the
facility's record of operation. and if appropriate contact other
Regional offices of EPA where the facilities may be located to
evaluate compliance with this policy. No wastes will be disposed at
any site not meeting the criteria set forth in the policy.
7.4)
Occupational Safety and Health Standards (29 eFR Part 1910):
These standards will be applied during remedial actions to protect
workers from exposure to hazardous substances and other physical
hazards associated with implementation of the RA. Methods for
assuring the safety of workers involved in the Rh will be devloped
.' and descri bed in a "Site Safety Pl an" developed as part of the
-------
30
7.4)
Hazardous and Solid Waste Amendments to RCRA of 1984:
The Hazardous and Solid Waste Amendments to RCRA of November 1984
(HSWA). 42 U.S.C. 6901 et ~. contain provisions setting several
statutory dates for banning-Tand disposal of hazardous wastes The
provisions discussed here are RCRA Section 3004 (d)(e) and (g). due
to the possible intersection of their statutory deadlines with the
construction schedule for a source control remedy at the Hardage
site.
The HSWA land disposal amendments are in fact not yet applicable or
effective Federal requirements with respect to CERCLA Section 104
or 106 response actions. since their implementation dates are still
some time off in the future. The bans found in subsection (g) are
to be implemented during three periods over 21 months for 1/3. 2/3.
. and finally all of the RCRA subtitle C "listed" hazardous wastes
commencing August 8. 1988. as determined by EPA. Those determinations
will be made by rulemaking. See 50 Fed. ~ 19300 (May 28. 1986)
for the list of wastes to be considered.
The statutory ban on the "California List" wastes and solvents in
subsections (d) and (e) and the prospective bans laws of subsection
(g) are not considered relevant and appropriate at this time. since
their applicability to CERCLA waste disposal is in the future. The
effect of the bans in subsection (g) on the remedy is speculative
at best. since EPA is required to engage in rulemaking for methods
of land disposal and pretreatment for such disposal. 42 U.S.C. 6924
(9)(5) and (m)oFuthermore. it must be emphasized that CERCLA.
requires the selection of cost-effectiveoremedies and does not
require EPA to implement standards that are'not in effect.
During the course of remedial action and construction. EPA intends
to further review the effect of land disposal bans on waste disposal
at the site and the issues of how such laws will be implemented
should they intersect the construction schedule. Additionally.
bench tests and/or pilot studies may be performed with respect to
pre-treatment methods for solvents and oth~r organics potentially
impacted by such bans. .
B.O)
OPERATION AND MAINTENANCE
The on-site landfill will require little routine operation and
maintenance (0 & M). Monitoring of the interior leachate detection
system will be required. as will periodic inspections of the cap
and monitoring of gases leaving the venting system. Development
and routine sampling of a groundwater monitoring network will also
be necessary for 30 years. at which time the need for additional
-------
9.0)
9.1)
9.2)
9.3)
31
To provide a contingency in project cost estimates, it was assumed
that at 30 years after construction replacement of the landfill
liner and cap might be necessary. The cost is reflected in the
present worth cost estimate of $70 million~ Operation and maintanence
costs on a present worth basis are estimated as $2,282,000 in 1985
doll ars.
COMPLIANCE OF SOURCE CONTROL REMEDIAL ACTION WITH SECTION 121 OF
THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF '1986 (SARA) TO
THE MAXIMUM EXTENT PRACTICABLE
Basic Certification:
The selected remedy will comply with Section 121 of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA),
as amended by SARA, including the cleanup standards thereof, to the
maximum extent practicable. The selected remedy is considered to
be cost effective and protective of human health and the environment
as well, in accordance with the NCP.
Permanent Solutions and Technologies
In selecting this remedy, EPA has considered a full range of alterna-
tives and solutions and alternative treatment technologies that
will result in a permanent and significant decrease in toxicity,
mobility, or volume of the hazardous substances present. In conduct-
ing its assessments of remedial alternatives and treatment technol-
ogies. EPA ha~ considered:
1) The lo~g term uncertainties of land disposal;
2) goals and requirements of the Solid Waste Disposal Act ("RCRA");
3) persistence, toxicity, mobility and bioaccumulation potential
of the wastes;
4) short and long te~ potential for adverse human health effects;
5) long term maintena~ce costs of the remedy;
6) potential for future remedial actions costs if the remedy fails;
7} potential threat to human health and the environment from the
excavation. transportation, and redisposal, or containment of
hazardous substances.
Remedy Analysis:
The selected remedy is a remedy for the first operable unit of
remediation - source control. It is a significant part of overall
remediation at the Hardage site and is consistent with a permanent
remedy for the site. The second operable unit. "management of
-------
32
This remedy will employ treatment through incineration of all free
liquid organics in the estimated 175,000 cubic yards of waste fill,
as well as the more than 18,000 estimated drums of waste buried
on-site. Remaining waste fill and inorganic solid drum contents
will be treated through stabilization measures prior to redisposal
in a double lined on-site .RCRA compliant landfill cell. In carrying
out these measures, EPA will be permanently and significantly
reducing the volume, toxicity, and mobility of the hazardous sub-
stances present at the Hardage site. Further, EPA will avoid in
large measure the potential dangers and uncertainties of transport
and disposal off-site, with its on-site approach for the bulk of
wastes. EPA requires that this source control remedy be reviewed
not less than every five years to assure that human health and the
environment are being protected.
As noted previously, in Section 7 herein, EPA has scrupulously
considered the applicable or relevant and appropriate federal
requirements for protection of public health and the environment in
accordance with the NCP. EPA has also looked into the issue of
applicable or relevant and appropriate state environmental laws and
has determined that the "RCRA analogous" regulato~ requirements of
the Oklahoma Controlled Industrial Waste Disposal Act, as amended,
authorized by EPA under RCRA to operate in lieu of the EPA regulations,
are met or exceeded by the selected remedy. In a nutshell, EPA has
complied with the SARA Section 121 cleanup standards to the maximum
extent practicable.
10.0)
OTHER OPERABLE UNITS
EPA's response actions on the Hardage/Criner have been divided into two
operable units: Source Control (the remedy discussed in this document)
and Management of Migration (also referred to as the groundwater/off-site
operable unit).
The source control response is limited to the source areas of the site
(sludge mound, main pit, and drum mound). The bases of the main pit and
southern pit (beneath the sludge mound) at approximate elevations of 1109
and 1093 feet MSL respectively form the lower bound of the source areas.
The lateral bounds of the source areas are described by the base of the
slopes on the north, south, and west faces of the waste piles and pits,
and as the lateral extent of the excavated pits on those sides of the
source areas where wastes and cover have been backfilled to ground level.
The management of migration RI/FS will include the following:
o
Definition of the extent and levels of contamination present
in soils and rock outside the source are~;
o determination of the extent and fate of groundwater contamination
in the alluvium of North Criner Creek and the feasibility
-------
33
o
determination of permanent surface clean-up levels on-site to
prevent or minimize further degradation of potential surface
and ground water supplies, direct contact hazards to the
public, and other long term hazards.
11.0)
ENFORCEMENT
11~1) Hardage I:
In 1979, EPA inspections of the site indicated poor waste management
practices posing potential threats to pUblic health and welfare and the
environment. In September 1980, the U.S. Department of Justice (DOJ)
filed a complaint on behalf of EPA in U.S. District Court in Oklahoma
City, Oklahoma. The complaint alleged violations of Section 7003 of RCRA
and sought proper cleanup and closure of the site. The facility
had ceased operations in early November 1980, before RCRA Interim
Status Standards came into effect.
In 1982, DOJ and EPA amended the existing complaint against the
facility owner and operator Royal Hardage. The complaint was
changed to include allegations and requested relief under Sections
1U6 and 107 of the Comprehensive Environmental Response Compensation
and Liability Act (CERCLA). In December 1982, the Court found that
the site posed an imminent and substantial endangerment to public
health and welfare and the environment as defined by CERCLA Section
106 and RCRA Section 7003. In August 1983, the Court granted a
partial judgment for over $211,000 in response costs, which EPA had
incurred through 1982, against Royal Hardage.
Hardage filed for bankruptcy in 1983 and again in 1985, and EPA has
never recovered its partial judgment.
11.2) Hardage II
EPA compiled available records
daily and monthly site logs of
and disposal plans and records
generators and transporters of
from the sites operations including
wastes received, waste manifests,
filed with the State of Oklahoma by
waste to the site.
As a result numerous Potentially Responsible Par~ies (PRPs) were
identified. In December 1984, EPA mailed letters to 289 of these
PRPs requesting information about their waste disposal at the
Hardage site under authority of Section 104(e) of CERCLA and Section
3U07 of RCRA and notifying the PRPs of their potential liability
for site cleanup. As further information was gained, information
request and notice letters were sent to additional PRPs identified.
At the present time, over 400 PRPs have been identified. Various
PRPs have gone out of business or cannot be located; therefore,
approximately 340 have been contacted. A number of these parties,
have organized into the Hardage Steering Committee (HSC). The HSC
has met with EPA and OSDH on numerous occasions si~ce EPA's first PRP
-------
12.0)
,)'+
Since the FS was on going at the time the PRPs were notified and
CERCLA progam policy previously did not allow PRP conduct of RIfFS
studies without a signed agreement to also implement the EPA selected
remedy. the PRPs were not involved in preparation of the FS. In
May 1985. EPA released the DSR documenting 1984 site investigations:
and HSC also obtained all EPA files on the site. The HSC has retained
Dames & Moore and more recently ERM-Southwest to provide technical
support in their dealings with EPA.
In July 1985 the Court administratively closed the 1980 case against
Hardage, providing that the U.S. could re-open the case for the
purpose of seeking appropriate relief until April 1. 1986. at which
time the case would otherwise be dismissed. DOJ. on behalf of EPA,
filed a motion on March 27, 1986, to amend the existing complaint
ana add generators and transporters to the existing case. The Court
ultimately denied the motion and dismissed the case, providing that
Royal Hardage could be named for limited purposes in a subsequent
case.
On June 25, 1986. DOJ filed a new complaint naming 36 generators
and transporters of waste at the site. The complaint asks for
performance of the EPA selected source control remedy, maintenance
of site security, conduct of a RIfFS for the management of migration
operable unit and any subsequent EPA selected remedy. and recovery
of EPAs' past and future response costs. A status conference was
held on September 3, 198fi, and a second status conference has been
set for January 7.1987.
COMMUNITY I NVOL VEMENT
Due to the large number of PRPs for this site, the majority of
meetings. comments on the FS. and other external communication has
been with these parties, However, attention has been given to the
concerns of near site residents and other interested parties.
When the draft FS was completed on February 20, 1986, a press release
was issued announcing this fact, copies of the FS were placed in
repositories. and a copy was provided directly to the Hardage
Steering Committee. The public comment period was from March 10-
April 15, 1986. A public meeting was held in Chickasha, Oklahoma
to answer questions and receive comments on the FS on March 20. The
response to questions, comments. and concerns raised during this
-------
35
13.0 REFERENCES
CH2M Hi 11 1985
Field Investi ation and Data Summar Report, Royal Harda e
Industri a Hazardous Waste Site, CH2M Hil , May 22, 1985
CH2M Hill 1986a . . .
. Preliminary Public Health Assessment, CH2M Hill, August 1986
CH2M Hi 11 1986b
Source Control Feasibility Study, Royal Hardage Industrial
Hazardous Waste Site, CHZM Hill, February 20, 1986
EPA 1985a
Public Health Assessment Manual, EPA - Office of Solid Waste
and Emergency Response, November 1985
EPA 1985b
Guidance on Feasibility Studies Under CERCLA, EPA, June 1985
EPA 1986
Superfund Remedial Design and Remedial Action Guidance, EPA,
June 1986
Eltex 1985
Letter from Eltex Chemical and Supply (Houston, Texas) to
Stephen Phillips (EPA-Dallas), August 1985
Hardage 1972-80
Monthly waste site 109 of materials received at the Hardage site
Waste
OSDH 1972
Industrial-Hazardous waste landfill permit issued September 12,
1972 to Royal HJartdag? by OSDH
USGS 1966
Base of Fresh Groundwater in Southern Oklahoma, D.L. Hart,
-------
I .
APPENDIX
A
CHRONOLOGY OF EPA SITE INVESTIGATIONS
-------
APPENDIX
A
June 27, 1979
EPA Sampling and Inspections of Hardage/Criner prior to 1984:
Inspector:
Purpose:
Result:
Documentation:
August 15, 1979
Inspector:
Purpose:
Result:
Documentation:
August 14, 1980
Inspector:
Purpose:
Result:
Document at ion:
October 1, 1980
Inspector:
Purpose:
Result:
Ralph Hawkins (EPA-Ada Branch) accompanied by Oklahoma
State and County Health Department personnel
NESHAPS inspection due to asbestos disposal
Recommended Sampling of site
7/3/79 memo, Hawkins to Charles Gazda (EPA-Dallas)
s.c. Vin (EPA - Ada Branch) with other EPA and State
Health Department personnel
Obtain samples and inspect site
Nine soil, water, and waste samples taken, analyzed for
metals and organics; photos taken
9/10/79 memo, Vin to Charles Gazda (EPA-Dallas)
10/26/79 memo William Langley (EPA-Houston Lab) to Oscar
Ramirez (EPA-Dallas) transmitting analytical results.
Thomas Smith of Ecology & Environment (FIT) for EPA
Off-Site sampling
Three samples taken from off-site drainage pathways;
analyzed for metals and organis~ photos taken
8/21/80 memo T. Smith to Charles Gazda (EPA-Dallas);
9/23/80 memo William Langley (EPA-Houston Lab) to William
Librizzi (EPA-Dallas) transmitting analytical results
s.C. Yin (EPA-Ada Branch) with FIT personnel
Off-site sampling
Thirteen (13) samples tak~n from off-site drainage ann
domestic water wells, analysis for'metals and organics,
-------
. .
Documentation:
A-c.
10/23/80 memo, Vin to William Librizzi (EPA-Dallas);
10/lS/80 memo William Langley (EPA-Houston Lab) to
Librizzi transmitting analytical results
Inspector:
March 23 - April 8, 1982
Purpose:
Result:
August 16, 1982
Inspector:
Purpose:
Result:
Imre Sekelyhidi (FIT) personnel and other FIT employees
for EPA
Detailed on and off-site sampling of the site
3/23-24/82, 29 samples collected;
3/30-4/1/82, 6 domestic wells sampled
3/30-4/2/82, 10 monitoring wells drilled, by Shepard
Testing and Engineering Co., Inc. of Norman, Oklahoma
at locations directed by Jerry Thornhill (Hydrogeologist,
EPA-Ada Branch)
soil borings and monitoring well samples collected from
each new monitoring well
Ecology.& Environment (FIT) for EPA
Second sampling round for the wells drilled by FIT
in Ma rch 1982
-------
APPENDIX
B
LIST OF POTENTIALLY RESPONSIBLE PARTIES
-------
c .:
. 709
710
711
712
713
714
7'C'
.l.iJ
716
717
718
719
720
721
7_._.
o::.~
, '
. ,
723
72.4
725
726
727
728
729
731
7:32
733
734
735
73£ '
737
7.38
73'3
740
741
742
743
744
74~
746
747
746
749
7~0
751
752
753
754
755
756
-757
758
75'3
760
7£1
762.
7E.3
',' 764
765
766
, ;
I
i .
AAR CORP.
A BETTER SANITATION
ABL~ lINT!='OR""! REI\:TAL
ACI':E FENCE
ADVANCE PACKAGING
AGLA~D, INCORPORATED
ALTEC SOUND PRODUCTS DIVISION
A~ERICAN,AIRLI~ES, INCORPORATED
AME~ICAN DISPOSA~ SERVICE
A~ERICAN FA~M LINES, INCORPORATED
AMER!CA~ FURNITwRE STRIPPING
AMERICAN TRAILERS, INCDRPORATED
AMOCO PRODU:iION COMPANY & RESEARCH
A-ONE BIT & TOOL COMPANY
ATLANTIC RICHFIELD CO~PANY
A~~A~SAS BEST COR~DRATION
ARROW 7ANK TRUCK, INCORPORATED
ARTHUR G. ~cGEE A~D CD~PANY
ASHLA~D CHE~IC~L CO~PANY
BALON COR~ORATjON
,BEAUTY CRAFT TILE OF THE SOUTHWEST, INC.
BI~NEY I. S~ITH, INCOR~O~ATED
BOB MOORE OILWELL SERVICE
BORDEN CHE~:CA~ DIVISION
BRITTAIN B;OT~ERS (NAPA)
BROADwAY MACHINE & MOTOR SUPPLY
BRCW~ AND ROOT, INCORPORATED
BRO~N~NG-F£RRIS INDUSTRIES, INCORPORATED
B.S. & S. E~GINEERING COMPANY
CAPITOL GR~ASE COMPANY
CATD OIL & G~~~SE
C.E. NATCO
CHARLES MAC+-:II\;'E wORKS, INCORPORATED
CHROM ALLOY DIVISION
CHRD~IUM PLATI~G CO~PA~Y
CIMARRON MA~UFACTURING COMPA~Y
CITIES SERVICE OIL COMPA~Y
CITY SERVICE
CITY OF NOR~AN
C~AY70N PLATING COMPANY
CLYDE'S CARBURETOR SERVICE
CMI CORPORATION
COMPETITION AUTO~OTIVE
CC~OCO, INCORPORATED
CO~SDLIDATED CLEANING SERVICE CO~PANY
CONTAINER CORPORATION OF AMERICA
CORE LABORATORIES
CO~NTY HOME MEAT CO~PANY
CRANE CARRIER CORPORATION
GROSBY GROUP, McKISSICK PRODUCTS DIV.
CROWL MACHINE & HEAT TREATING
CROWN TRANSPORT COMPANY
DAL-WORTH INDUSTRY, INCORPORATED
DAYTON TIRE & RUBBER COMPANY
DE~ PAINT ~A~UFACTURING
DELTA FAUCET COMPANY
DELTA TRANSMISSION
THIS lIST REPRESENTS EPAIS PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATION CONCERNING THE LIABILITY OF ANY PARTY
-------
. ..
7E:3
, 770
771
772
773
774
775
776
777
778
77'3
780
781
782.
783
784
785
786
787
788
78'3
790
7'31
792
7'33
794
795
79E.
797
798
79'3
800
801
802
803
804
805
806
807
808
80'3
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
825
DESOTA, INCORPDRATED
D8UBLE EAGLE REFINING LUBRICANTS, INC.
DOVER CORPORATION
DOW CHEMICA~ CO~PPNY
DO~~TOWN AIRPARK, INCORPORAT~D
DRILLERS ENGINE & SUPPLY
D~RA-CMRO~E I~D~STRY
EASON & SMITH, WASTE HAULERS
EASON ENTERPR!SES
EASON OIL
E.I. DUPONT DE NEMOURS
ELTEX CHEMICAL AND SUPPLY COMPANY
ENGINEERING ENTERPRISES
EQUIPMENT RENEWAL COMPANY
ERNEST ST. CLAIR
EUREKA TOOL COMPANY
EVAN'S ELECTRIC SERVICE CENTER ~
FAA AERONAUTICAL CENTER . ~
,FIBERCAST CORPORATION
FINE CANDY CO~PANY
FIRST NATIONAL MANAGEMENT CORPORATION
FLINT STEEL CORPORATION
FORD GLASS PLANT
FOSTER FEED & SEED
FOSTER SEPTIC TANK CLEANING
FRED JO~ES MAN~FACTURING
FREwHA~F CORPORATION
GARD~ER-DENVERCOMPANY
GE;\IERA~ E~ECTRIC
GEI\ERA~ L.ECTRIC
GENERAL TIRE & R~BBER
GEOPMYSICAL RESEARCH
GLIDDEN CO~TINGS & R~SI~S CO~PA~Y
GLOW-LITE DIVISION OF DUTC~ BOY, I~C.
GOODYEAR TIRE & RUBBER CO~PA~Y
GOVER~AIR CORPORATION
GROE~DY~E 7RANS~DRT, INCORPORATED
HALLIBURTON SERVICES
ROYA~ M. HA :WAGE
HART INDUSTRIAL DISPOSAL
HATHAWAY INDUSTRIES
HELM & WEAVER
HERMETIC SWITCH, INCORPORATED
HOLLEY CARBURETOR
INDUSTRIAL UN:FORM
INDUSTRIAL DISPOSAL SUPPLY, INCORPORATED
INTERNATIONAL C~V5TAL MANUFACTURING
JOHN ZINK COMPANY
JONES-SLAIR PAINT COMPANY
KELSEY-HAYES
KELTRONICS CORPORATION
KERR ~cGEE, PRESIDENT
KI~BA~L CHEMICA~ COMPA~Y
KOBE, INCORPORATED
KOCO-TV .
LAWTON PLATI~G COMPANY
LEAR SIEGLER, INCORPORATED
THIS lIST REPRESENTS EPAIS PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATION CONSERNING THE LIABILITY OF ANY PARTY
-------
826
'827
82'3
830
831
8~2
833
834
835
8Z€,
. .. 837
838
839
S40,
S41
8042
843
S1,4
~45
BL;E,
847
8'-,8
849
850
8"'.
.-.
8-'-'
.-Co
S53
854
BI:'I:'
..J..J
55€,
857
55B
85S
SSO
8E.1
6:'2
8e.3
8EA
S€,5
866
867
SS8
8S9
870
871
872
873
. 874
875
876
877
S78
879
880
681
882
863
L. & S. BEARING COMPA~Y
LEEWAY MOTOR FREIG~T(C.L. MOTOR FREIGHT)
MAREMO~T CORPORATION
:ortASTER /':OTO~S
~ATERIALS RECOVERY ENTERPRISES
McDONNELL DOUGLAS
McKESSO~ CHEMICAL COMPANY
MANUFACTURING MERCURY MARINE
METROPLEX SANITATION
MIKE MON~ONEY AERONAUTICAL
~OBIL CHEMICAL COMPANY
NA~EPLATES, INCORPORATED
NATIONAL CAN CORPORATION
NATIONAL PACKAGING COMPANY
NELSO~ ELECTRIC CO~PA~Y
~EWS~APE~ PRI~TING CO~~ORATION
~ICK~ES ~A:~I~E CORPO~ATrON
~GRDhA~. I~CORPORATED
NO~T~~QC Wnq~DW!D~ P!RCRP~~ 5E~V:CE !~C.
'NU CHRO~E PLA7IN3
O'~RrE~ PAINT CORPORATION
DCC!~~~~A~ CHE~ICA~
D~LA~~~P CITY DISPOSAL
OK~A~O~A GAS & E~EC;RIC
O;A DEPPRTfI'.Er\T OF CO~RECTIO"i
D~LA~O~A STATE DE~A~T~E~T OF HEALTH
O.K. PJBLIS~I~G CGMPA~Y
OKLA~O~A MAC~I~E ~A~U~ACTURING
O.K. NPT!O\A~ STOC~YARDS COMPA~Y
0.1-. NATGRA~ GAS CD~PA~Y
O.K. TAN~ SE~VICE, INCORPORATED
O.K. TRA~SPORTATION COMPANY
ORAL ROBERTS UNIVERSITY
PAG::: II\DUSTRI'::S
PATTERSON SARGENT
P:-IARXASEAL ~ABS
PH~~LIPS C~E~!CA~
PHI~LI~S PE~RD~EU~
PO~E~L SA'!iAT~O~ S£RV!CE
POw;~L =ERVIC~ C~~~ANY
PR;S?YTERIAN hOSPITAL
P~ESTC_!TE CG~PC~AT!DN
P~YOR FOU~D~Y, INCD~PQ~~TED
~~BLI: SERVrC~ C~~~A~Y
RA hA~ C!RCWITS, IN:O~POR~TED
RA:\lDY ~~LIO
~EAG;~T CHE~ICAL & R~SEARC~, I~C.
R~D BA~L ~QTO~ FR;IG~i
ROCK~E~L INTER~~iIONAL
ROC~~~LL IN7ER,\lATIG~AL CORPO~Q7IO~
RCDCO, I~COR~C~A~ED
R~TEX CO~~ORA~IO~
ST. A~THO~Y ~OS~ITAL
5.&5. P~A7:~3 CO~~A~Y
SA~TA FE RAILROAD
, THIS LIST REPRESENTS EPAIS PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATION CONCERNING THE LIABILITY OF ANY PARTY
FOR THE HAZARD OR CO~TA~INATION AT THE HARDAGE SITE
-------
885
E~S
897
eBB
88'3
890
8'31
a~ -.
:,..:,
8'33
8S4
8'=:C"
~...
89S
8'37
8SB
8'39
900
901
902
903
304
905
906
907
908
909
910
911
912
913
914
915
916
917
918
919
9.2(1
921
9.22
923
924
925
9.26
927
928
929
930
931
932
933
934
93~
93S
937
938
.940
939
S~A~S AU~O CEN-~H
SS~;~Y ~A~U~ACTJ~ING
SER~ETE~, INCORPORA7~D
SS~vlC~ PA~NT ~AN~FACTuRI~G CD~~A~Y
ShA~LE~ CCROORATIDN
SHE~~I~-WI~LIA~ CD~~A~Y
!:KY hITC'-1
SC~VENT MA~UFACTURING COMPANY, INC.
SOOr-.:E~ FORD
SDC~ER QIL PATCH S~RVIC~S, INCO~~J~ATED
SOuT~ERN HILLS COU~TRY CLUB
SOUTH P~A!R!E CONSTRUCT:O~
SOUT~~EST ELECTRIC CC~PANY
SS~Trl~SST~RN STSEL.RO~LI~G DOOR CO~~A~Y
50~T~WEST U~ITED I~DUSTRIES
S~SR~Y VICKER CO~PANY
S:A~ RA~SEY CO~~ANY, INCORPOR~:ED
S~PNDARD C~E~ICAL CO~PANY
STA~ ~A~~FACTURI~G COMPANY
STEELCRAFT, INCORPORA;ED
STOR~ PLASTICS, INCORPORATED
SUBLETT , ASSDCIAT~S
SUI\! GAS
TEXAC8. I~CORPORAT~D
TEXAS INSTRUMENTS
TEX PRODUCTS, INCORPORATED
THE BUC~ET SHOP, INCORPORATED
SA~UEL ROB~RTS NOBLE FOUNDATION, INC.
THOMAS & BETTS
THC~PSON HAYWARD CHEMICAL CO~PANY
UNITED S~ATES AIR FORCE ---
TRIBONETICS CO~pqNY
TO~ BROW~'S OPTICAL
TOX
TR!Gs DRILLING
TwFTS & SON OF OKLAHOMA
UNARCO COMMERCIAL PRODUCT
UNIROYAL TIRE CC~PANY
UNIT PARTS, BORG-WARNER CO~PANY
UNITED FOAM
UNITED PLATING WORKS, INCORPORATED
UNIVERSAL OIL PRODUCTS
UN:VERSITY OF OKLAHOMA
UNIVE~SITY OF O~LAHOMA
UNIV. OF OKLAHOMA HEALTH SCIENCE CENTER
UNIVERSITY OF OKLAHOMA
CDLONEL ~ARV FELTS
U.s. CORPS DF ENGINEERS
U.s. DEPARTMENT OF ENERGY
u.S. PO~LUTION CONTROL
u.s. POLLUTION CONTROL
VETE~qNS AD~INIS~RATION
WAYNE C!~C:UIT
WE~CH OIL COMPA~Y
WESTERN ELECTR!C CD~PA~Y
WSSTERN EXTRACT ~ANU~ACTUR!~G CO~PA~Y
THIS LIST REPRESENTS EPAIS PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A fINAL DETEMINATION CONCERNING THE LIABILITY OF ANY PARTY
-------
. .
941 ~E5TI~S~J~SE ELEC7RIC COR~OqA~ION
942 ~EYER~A~U5~~ CC~~~AY
943 WILSO~ DOw~~OLE SE~VICES
944 W.J. ~P~B~~TO~
945 WO~VERINE ~IPE
946 Z~~CC~ INDWS7~IES
947 OK~AHO~A GRAPHICS
948 U.S. S~A~L BUSl~~SS AD~INIS7~A:ION
949 GENERAL MOTORS
950 SU~£~IDR LI~EN
951. O.K. MEMORIAL HOSPITAL
952 JIM'S SEPTIC SERV:CES
953 A-A E~E~GENCY PLU~BING
954 RIVERSIDE INDUSTRIES
955 WASTE MA~AGEMENT
955 IN~E~~~TIONAL SYSTE~ & CONTROL
957 P.A. INDUSTRIES-PO~A~ MANUFACTURING
958 AMAX, INCORPO~ATED
959 WASTE ~A~AGEMENT, I~CORPORATED
9~O SA~D~~A~ SE~VIC~
961 ~DST£R FEED & SEED CO~PANY
952 JDC OIL £XPL8RA~ION CD~PA~Y, !NC.
953 ALLIED ~AI~: COR~ORATION
9S4 BO~G-~AR~~R COROORATION
955 CLl~~CO, !~CORPORA~ED
9S6 ~C~EY~E~L CD~PA~Y
957 COJK P~I~T A~D VARNrS~ CO~PANY
9~8 CHE~I~A~ LEA~A~ TANK LI~~S. INCDRPORATED
9S9 DIA~O~D PAINT CO~PANY
~70 EXXON C~E~ICA~ COMPA~Y
971 w.R. GRACE & CO~PANY
972 GULF STATES PAI~T CO~PA~Y
973 RA~PH LOW~ . .
974 ~AGNA COR~ORATION
975 NA~CD CHEMICAL CO~~ANY
975 T~E O'BRIEN CORPORATION
977 p.P.G. INOUST~!ES
978 RELIANCE UNIVERSAL, INCOR~ORATED
~79 RO~~ A~D HAAS TEXAS, INCORPORATED
980 WIiCD CHE~ICAL COMPANY
981 TRIA~GLE ENGINEERING COMPANY
THIS lIST REPRESENTS EPAIS PRELIMINARY FINDINGS ON THE IDENTITIES OF
POTENTIALLY RESPONSIBLE PARTIES. INCLUSION ON THIS LIST DOES NOT
CONSTITUTE A FINAL DETEMINATION CONCERNING THE LIABILITY OF ANY PARTY
-------
APPENDIX
c
COMMUNITY RELATIONS RESPONSIVNESS SUMMARY.
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
ON THE SOURCE CONTROL FEASiBILITY STUDY
HARDAGE/CRINER SUPERFUND SITE
MCCLAIN COUNTY,.OKLAHOMA
-------
C-2
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY ON THE
SOURCE CONTROL FEASIBILITY STUDY
HARDAGE/CRINER SITE
MCCLAIN COUNTY, OKLAHOMA
This document summarizes public comments and Environmental Protection
Agency (EPA) responses to questions and concerns raised during the public
comment period. The responsiveness summary is divided into four sections:
I. Overview
II. Activities to illicit input and address concerns
I I 1.
IV.
Summary of public comments and EPA response, and
-------
L-j
I .
OVERVIEW
At this time, the Environmental Protection Agency (EPA) is presenting its
response to comments on the Source Control Feasibility Study (FS) prepared
for the Hardage/Criner site. EPA has not yet selected its preferred
remedy but has developed four remedial alternatives which it believes to
be cost-effective plans, meeting all applicable or relevant and appropriate
Federal requirements for protection of public health and welfare and the
environment.
This site is being managed through the EPA enforcement program. As such,
EPA will make a decision on the "baseline" remedy which it feels to be
acceptable. EPA will then negotiate with private parties believed liable
for the'site in an effort to achieve voluntary cleanup of the site. In a
parallel manner, EPA is pursuing direct enforcement action under Section
106 of the Comprehensive Environmental Response Compensation and Liability
Act of 1980 (CERCLA) and under Section 7003 of the Resource Conservation
and Recovery Act of 1976 as amended (RCRA).
When a remedy is proposed, EPA will be seeking public comment. Only
-------
. 11.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Major Concerns and Issues
One of the major concerns at the Hardage (Criner) hazardous waste site is
evidence from monitoring wells of migration of contaminants from the site
and contamination of residential wells offsite. The North Criner Creek
alluvium is the primary aquifer of concern.
Deteriorating conditions at the site (i .e., continuous seepage from the
pits, exposed barrels from the mound, etc.) and inadequate barriers to
retard migration, have given rise to concern for potential surface and
groundwater contamination.
Activities to Elicit Public Input and Address Concerns
EPA has kept members of Congress, as well as other elected officials and
citizens informed of meetings, plans, and alternatives under
consideration. Elected officials and citizens were notified prior to
start of the Remedial Investigation and Feasibility Study (RIfFS) process.
Ten families live in the immediate vicinity of the site. Each family was
interviewed by representatives of the Oklahoma State Department of Health
(OSDH) and the EPA to ascertain their concerns and feelings about the
site. Primarily, these citizens' concerns centered around contamination
of the groundwater, which was originally discovered in the mid 1970s by
the State of Oklahoma in onsite monitoring wells. Since that time, EPA
and OSDH have expended considerable joint effort and resources to determine
the nature and extent of the contamination. Royal N. Hardage, owner and
operator of the site, was sued by the United States in September 1980,
seeking investigation and clean up of the site. Although the United
States established it's case and won a partial judgement against Royal
Hardage, it was unsuccessful in obtaining site clean up, in large part due
to Mr. Hardage's rankruptcy. The U.S. Government filed suit in June 1986
against 36 companies believed to be responsible for public health threats
posed by the site, seeking performance of remedial actions and further
studies as directed by EPA as well as reimbursement of all Superfund
costs incurred, which is more than $1.4 million.
A press release announcing the end of the Feasibility Study, start of the
public comment period, and a public meeting, was issued by EPA on February
24, 1986. Copies of all formal documents concerning the site were placed
in five strategic repositories for the public to review preparatory to
making their comments. Preceding the public meeting held on March 20,
1986, EPA briefed the mayors and other city officials of both Chickasha,
OKlahoma and Purcell, Oklahoma. At this briefing, EPA reviewed past
-------
C-5
SUMMARY OF PUBLIC COM~E~~S RECEIVED DURING
THE CO~ME~T PERIOD AND EPA RESPONSE
The public comment period on this FS was from March 10 through April 15, 1986.
The FS was placed in repositories and provided to the Hardage Steering Committee
(HSC) on February 25. the day after a press release announced the end of
FS activities. A March 20, 1986, public meeting was attended by approximately
seventy people. nine of whom made statements. Fourteen sets of written comments
were received, consisting of over 200 pages. These comments were received
from:
1)
2)
3)
B&F Engineering - for Weyerhauser
Gardere & Wynne - for L&S Bearings, Rotex. and Tribonetics
Hardage Steering Committee - a PRP group representing 135 parties,
submitted their own comments as well as those of three consulting firms
retained by the HSC: Dames & Moore, ERM-Southwest, and MDK Consultants
Hildebrandt Tank Service
Hill & Robbins - representing U.S. Pollution Control, Inc.
The Hardy Horton Family
Hunton & Williams - representing Oklahoma Gas & Electric, comments
endorsed by AT&T
Kerr McGee
League of Women Voters
Rajeanna Mayo
Oklahoma Center for Veterans Rights
Pat Shepherd
Thompson & Knight - representing Firestone
Glenn Webb
4)
5)
6)
7)
8)
9)
10)
11)
12)
13)
14)
Comments were also received during the public meeting from the following
parties: Glenn Webb, Kinnan Goleman (for HSC). Neal Garrett, Tom Smith,
Rocerta Olefield. Linda Wall, Faith Hurley. Ben Kalas (for KWCL news) and
Mark Fox.
After analysis of the comments, it was decided to organize the responsiveness
summary into seven sections. each dealing with comments on a specific
subject. These seven categories are:
A)
B)
C)
D)
E)
F)
G)
Adequacy of data.
Operable unit approach.
Compliance with the NCP.
Feasibility Study process,
Opportunity for public participation,
Recommendation for additional study or
Other comments.
-------
A)
C-6
ADEQUACY OF EXISTING DATA ON THE HARDAGE/CRINER SITE
Several commenters suggested that existing data is inadequate to fully
characterize the site and develope a permanent and cost effective remedy.
Based on the volume of comments, it appears that either the consultants
which these individuals employed are not fully aware of the amount of
existing data or that a substantial difference of opinion exists between
EPA and the Hardage Steering Committee (HSC) as to what would constitute
"adequate data". EPAs "Guidance on Remedial Investigation under CERCLA"
indicates in Section 7.2.3 that the extent of investigation should not be
more than is "necessary and sufficient" to satisfy site-specific objectives.
SuCh objectives w~re defined early by EPA and are documented in the November
1983 work plan prepared by CH2M Hill. In the case of a source control
action data must be, and in tnis case is, adequate to establish the degree
of containment of the waste materials with reasonable certainty. The data
must also allow developement of feasible alternatives for remediation of
the site, screening of these alternatives, and ultimately selection of an
appropriate cost-effective alternative for remedial action. As in any
engineering or scientific study, 100% of the available data could never be
gathered. As more and more is learned about the site, further data gathering
efforts will become less productive and of less value in providing new
information and more duplicative of previous studies. At this point, the
Agency believes that sufficient knowledge of the source areas of waste and
their current state of containment does exist to allow decisions based on
fact and sound engineering principles (not on assumptions or conjecture)
to be made as ta the appropriateness, feasibility, and cost effectiveness
of a range of source control remedial alternatives as requirpd by the
National Oil and Hazardous Substances Contingency Plan (NCP), 50 Fed. ~.
47950, November 20, 1985.
The level of data gathering suggested by some commenters indicates confusion
about the purpose of an FS and the preceding investigative efforts. The
data gathered prior to remedy selection on a Superfund site is not intended
to be so complete as to allow preparation of detailed design for each
remedial alternative or even for the remedy selected. For example, it
would make no sense to collect the extensive data required to design four
remedies when only one will be selected. The data only needs to be sufficient
to determine the most cost-effectivr feasible remedy protective of public
health and welfare and the environment, not inconsistent with the NCP.
Several commenters pointed out what they believed to be data gaps in EPA's
characterization of groundwater hydraulics and other contamination outside
the source areas. Since a separate RI/FS is planned to specifically address
this, the second operable unit, the comments are noted for future reference
in development of the workplan for the second operable unit (Management of
-------
C-7
Response to specific questions and comments regarding the adequacy of
data is provided below:
Comment:
Response:
Certain data indicate that the bedrock may be fairly impe~eahle
and caple of preventing waste migration. specifically: the
yield of water from interceptor wells installed by the operator
are low. as reported in the FS; the packer permeability tests
conducted by EPA contractors in 1984 indicate the permeability
of bedrock is very low. less than 10-7 cm/sec.
It should be noted that the packer tests indicated permeabilities
were less than 8 x 10-7 cm/sec. Packer tests. when conducted
properly and under favorable conditions. can provide an indication
of the permeability around the well bore. This does not
necessarily reflect overall permeability of the bedrock or
the ability of seepage to move rapidly through joints. The
intact bedrock. especially shales. at this site may have
hydraulic conductivities on the order of 10-7 cm/sec. or
less. However. EPA believes secondary permeability (fractures/
joints) rather than porosity. characteristics have allowed
existing contaminant transport. As stated in the FS. the
results of site packer permeability tests would not have been
signifi.cantly affected by thin. occasional layers with hydraulic
conductivities on the order of 10-1 to 10-3 cm/sec or an
occasional tnin fracture. This statement is based on estimations
of the water loss through a thin pervious layer within the
packer test sections. Based on the tests conducted at the
site. such a layer would not result in sufficient water loss
during the test to result in an overall hydraulic conductivity
of greate~ than 10-7 cm/sec. but would allow'contaminant
migration at relatively high velocities in these secondary
channels. .
As discussed in the FS. difficulties are inherent in monitoring
groundwater quality in a fractured aquifer. The absence of
contamination in a single well. for example. cannot be taken
with any confidence to mean that contaminants have not reached
that general area. This is apparent when one considers the
relatively minor area intersected by a well bore as compared
to the areal and vertical extent of the aquifer which this
well would be intended to monitor (a six inch well bore with
a twenty foot long screened-sampling-section might be placed
hundreds to thousands of feet from other wells and represent
the only data on this section of the aquifer). When groundwater
-------
Comment:
Response:
Comment:
Response:
C-8
interce~tion of contaminated flow pathways is largely reduced
to a matter of chance. The consistent presence of contamination
in the majority of wells spa~ed over a wide area carrip.s
great weight in proving the aquifer to be contaminaterl; and
such a situation is correctly taken to represent contamination
of the entire area monitored by the contaminated wells.
The yield of the Hardage Wells was reported incorrectly in the FS as
one barrel per day. The yield, as stated by Royal Hardage in a 1980
deposition was in fact 25 barrels per day for each of two wells.
The groundwater contour map presented in the FS was developed
with data from different zones. This is not a correct
procedure since deeper bedrock may be hydraulically confined or
vertical gradients may exist, making contours developed in this
manner deceiving.
The Bison and Purcell Formations are undifferentiated at the
site. comprising a single unconfined hydrogeologic unit; and
present data indicates the bedrock is hydraulically connected
in the vertical direction and in communication with the alluvium.
Therefore, the use of all water level measurements at the site
in preparing the ground-water contour map presented in the
FS is only subject to errors caused by vertical gradients.
Vertical gradients in ground-water do exist and do influence
the phreatic surface obtained from monitoring wells installed
to various depths. During the investigation for the second
operable unit. nested wells will likely be installed to further
evaluate vertical gradients at the site. Based on this information.
a refined contour map may be developed. Overall. this only has an
impact on the second (management of migration) operable unit.
Data from waste characterization holes drilled through the
sludge mound and main pit suggest that vertical barriers to
seepage exist beneath these areas.
Some data, when analyzed in a cursory manner, could indicate
barriers to seepage exist below source areas. However, the
observed vertical migration of contaminants and their lateral
spread into areas where no other pathway could exist but
through groundwater transport overwhelmingly indicates that
vertical barriers do not prevent susbstantia1 releases of
-------
Comment:
Response:
Comment:
Response:
Comment:
Response:
L-~
The vertical extent of contaminant migration has not been
defined, neither have the vertical flow gradients that would
induce such migratio~. Such information is needed to fully
characterize site hydrogeology and adequately develope and
evaluate remedies.
Vertical migration of contaminants through the bedrock to depths
greater than 40 feet has been documented to the east, southwest,
and directly beneath the source areas. The information obtained
from the waste characterization (WT) holes does indicate vertical
contaminant migration beneath the source areas, as discussed in
the response to latter comments. In addition, ground-water
contamination found in wells EW-01, BW-Ol, BW-04 and GTW-03
indicates contaminants in ground water at depth. In each of
these wells, the well screen interval was placed beneath the
phreatic surface measured at the well location, thus contam-
ination found at these well locations are beneath the surface
of the ground-water table and confirm vertical migration. In
addition, several wells and exploratory boring locations were
installed adjacent to deeper wells. Although these were not
specifically intended to constitute nested wells, information
obtained from these locations indicates a gradient from shallow
to deep groundwater. .
Piezometric levels of groundwater were measured in January
and aren't representative of the entire year due to seasonal
fluctuations. This limited data cannot indicate to what degree
wastes in the source areas are beneath the water table.
EPA agrees that the levels may represent a low as compared
to the rest of the year. However,. relative. levels and the
shape of groundwater contours and flow directions likely
represent an annual average and are consistent with those
developed by earlier investigators (Baker & Burns, 19BO; Kent,
1982). Seasonal fluctuations could be better defined in
further studies.
Geologic cross-sections were not compiled. Such sections
could aid in analyzing site geohydrology, and are a tool
commonly used to perform such analyses.
The bedrock consists of shales, mudstones, and sandstones
which are deposited in discontinous layers. These layers
grade gradually back and forth from one rock type to another.
Since this gradation occurs in three dimensions, the classical
concept of a well defined sequence of horizontal or consistently
-------
Comment:
Response:
Comment:
C-10
sequence from one borehole to the next is not applicable.
As a result of this graded lithology, EPA could make only
limited interpretations and would have had virtually no .
confidence in cross-sections compiled with data fro~ these
or any other bedrock borings. For this reason, cross-sections
were not refined or published.
The site may not be suitable for locating a landfill cell in
compliance with RCRA Part 264 regulations; and data is
inadequate to make this determination. This should have been
considered before retaining the On-site Disposal Alternative
through final screening.
EPA believes the existing data indicates that the site is
suitable for placement of a RCRA vault; and further study
will be conducted for design should this alternative be
selected. Due to the widespread contamination on-site, low
levels of residual contamination will remain in the soils
over which the landfill would be constructed. A questions
was raised by one commenter as to the potential problems of
monitoring for leaks from the landfill cells, that is, if
contamination were seen in monitoring wells questions could
arise as to whether it is coming from trace landfill's liner
systems. It is EPA belief that monitoring in a possibly
contaminated environment will not present insurmountable
technical problems since: (1) The vault will have an interior
detection system capable of detecting any leaks before they
enter a contaminated zone; (2) the vault will be above the
groundwater table, eliminating potential up-flow of contam-
inants into the interior detection system; (3) regular
monitoring will likely be required for any remedy, and long
term water quality trends could be established, allowing
signlficant leaks from the exterior liner to be detected.
The site is located over several thousand feet of sediments
and is not prone to earthquakes. The area of the site considered
for locating a landfill cell is far above the 100 year flood
and also above the probable maximum flood. Thus, the site
meets the requirements set forth in 40 CFR Section 264.18.
The geometry of waste fill is not defined. Without such
data, it is not possible to adequately evaluate any alternatives
or determine either the Feaibility in in-situ containment or
-------
Res~onse:
Comment:
Response:
Comment:
Response:
C-11
The base of pits excavated during site operations and later
backfilled is defined by depositions of the operator Royal
Hardage and confirmed by test holes in these source areas.
The borings show bedrock at consistent elevations of about
1109 and 1093 feet mean sea level (MSL) beneath the
main pit and sludge mound respectively, thus defining the
base of the pits. Magnetometer surveys have located substantial
drum concentrations in the drum mound and along the west side
of the main pit. also confirming early site inspections and
the Hardage depositions.
A Quality Assurance plan was not prepared in accordance with
the NCP. As such. the accuracy of the data and the methods
of data collection are questionable.
The Quality Assurance Project Plan (QAPP) is included as
Appendix A to the May 1985 Data Summary Report. This
QAPP meets all the requirements of the NCP (1982 edition).
including concurrence on the plan by the Regional QA officer.
Sampling from three test holes in the sludge mound failed
EPA's requirements for QA/QC. This lack of data prevents EPA
from making decisions on the disposition of the materials
since it can make no judgement on it's potential threats.
After completion of the Feasibility Study. EPA's Houston Lab was
asked to review the data. The principal problem was that lab
reporting sheets indicated the units to be parts per million
(ppm). Summing the various constituents indicated certain
samples with a sum greater than a million ppm. indicating
an obvious error. The Houston Lab's review showed that the
units were incorrectly reported and in reality should have
been parts per billion (~) rather than ppm. This has
corrected virtually all problems with this-Qata set.
The Houston Lab review is documented in an August 1986 letter
from Bill Langley (EPA-Houston) to Bob Davis (CH2M Hill-
Dallas).
Data also eXlsts from previous sampling of the sludge mound
and in some cases for wastes disposed there. In addition.
the types of wastes disposed in the sludge mound are known
for the most part to be: styrene tars; drummed aresenic and
cyanide; PCB contaminated equipment; and sludges from oil
recycling. the analysis of which showed extremely high levels
of lead and phenol as well as over 50 ppm of PCBs; and a
composite of all other wastes disposed at the site as a
-------
Comment:
Responses:
C-12
from the surface of the sludge mound indicated PCB-1260,
lead, chromium, anthracene/phenanthrene, dichloropheonol, and
other heavy metals and synthetic organics.
Poor well drilling techniques may have resulted in cross-con-
tamination of some monitoring wells and waste characterization
holes; thus the results may not indicate deep contamination
of soil and/on groundwater.
Discussion is made regarding the contamination found in the
waste characterization holes (WT) beneath the source areas.
It is suggested by the commenter that only trace levels of
contaminants were detected in bedrock samples beneath the
pits and that they are "probably associated with inadequate
sampler decontamination... or laboratory contaminants". As
presented in the Data Summary Report, EPA (1985), rinsate
samples taken from the sampler after decontamination did
indicate a few contaminants at parts per billion levels in
addition to laboratory contaminants. The contention by some
commenters is that bedrock contamination beneath source areas
was mainly the result of sampler and laboratory contamination;
however, this is not substantiated by overall sample analyses.
Consistently, compounds other than those found in the rinsate
and laboratory blank samples were found in bedrock samples
beneath the sources. In many instances, these compounds had
concentrations in the parts per million range (orders of .
magnitude higher than that shown in blanks). In addition, in
several holes, compounds were found in the underlying bedrock
sam les which were not found in samples taken within the
source area nor 1n r1nsa e or laboratory blank samples.
These compounds are however components of wastes known to
have been disposed at the site. The obvious conclusion here
is that the wastes were not, as the commenter suggested,
carried down the borehole by careless sampling procedures,
nor were the compounds introducted at the lab or at any time
after the samples were collected; rather the contaminants are
in fact, as EPA has previously stated, at depth beneath the
source areas and represent the result of actual waste migration
vertically out of the waste pits and into underlying sediments.
In waste characterization hole (WT-006). the results of the
analysis of the composite sample comprised of samples from
28,33 and 38 feet showed very few volatile compounds; however,
the sample taken at 43 feet showed many more volatile compounds
present. EPA believes this pattern of contamination is more
indicative of vertical migration through the bedrock along
-------
Comment:
Response:
Comment:
Response:
Comment:
Response:
C-13
contamination on sampling tools. Well GTW-03 showed contamination
in groundwater as did the nearby BW-04 well; however. analysis
of borings taken from GTW-03 showed no contamination of the
overburden. thus precluding contamination of this well during
construction.
(For further discussion. refer to a previous comment
on vertical migration of waste page C-8).
No data exists to support EPA's contention that a hazard exists
from air on the site.
EPA recently sent its Emergency Response Branch (ERB) to the
site for purposes other than air monitoring; however. this
was also done while on-site, sampling with a photoionization
unit showed readings less than 1 ppm in air. It has been
observed that odors are much worse on-site in wet weather
than dry wheather-when ERB visited the site. At this time,
EPA must reply that it has no data which indicates an air
hazard from organic vapors exists on-site at this time. It
is entirely possible however. that deteriorating site conditions
could pose threats by this exposure pathway.
Use of area groundwater is not adequately assessed to determine
the need for remedial actions.
Those groundwater supplies with the potential to be immediately
affected have been considered. Other supplies which could
ultimately be impacted as wastes migrate farther from the.
site will be assessed in detail during groundwater/off-site
studies.
The groundwater pathway of contamination transport off-site
has not been sufficiently defined. The potential for
groundwater contamination has been cited as one factor
requiring remedial action. yet it's potential impact have not
been adequately assessed.
Pathways of groundwater. contamination transport were only
considered insofar as they indicate a general inability of
the bedrOCK to provide a reasonable degree of containment of
wastes in the source areas. The presence of contamination in
the alluvial aquifer of North Criner Creek and the route of
transportation from the source areas are by and large irrelevant
-------
Comment:
Response:
Comment:
Response:
Comment:
C-14
source areas several thousand feet away. EPA still believes
that contamination of this aquifer has resulted from combined
runoff and sub-surface transport. The question of which
pathway has contributed what to current contamination is of
only academic importance, since significant subsurface migration
has occurred in this and other directions, and contamination
of the alluvium by this method will continue or began to occur
until the sources are exhausted.
Source areas may exist which have not yet been identified.
If this is the case, then the source control FS is incomplete.
Sufficient information on the operating history of the site
is available from Oklahoma State Department of Health (OSOH)
inspections from 1972-1980 and from the operators depositions
to confirm that Mr. Hardage made efforts to consolidate wastes
in the main pit/drum mound and sludge mound. Site samplings
and recent inspections give no reason to doubt the belief
that the major concentrations of solids, sludges, and drummed
wastes are located in the three principal source areas
addressed by EPA in its FS.
Even if other major source areas did exist, it would not
preclude EPA from addressing the drummond, main pit, and
sludge mound as a single operable unit. The NCP provides
no such constrainst on what must be included in an operable
unit or on how many operable units a site may be divided
into.
Background quality of groundwater has not be~n determined.,
Without knowledge of background concentrations of chemicals
or elements, it is impossible to determine if the site is
contributing the compounds or if the levels are naturally
elevated and unrelated to the site.
The background levels of synthetic organics (such as solvents)
in this rural area is essentially zero with the possible
exception of pesticides from agricultural application, and
trace levels of natural phenol in groundwater. The background
levels of inorganics will be fully addressed in the Management
of Migration RI. '
The extent of groundwater contamination has not been adequately
defined; and no plume has been shown to emanate from the
source areas. As a result, it is premature to determine that
-------
Response:
Comment:
Response:
Great difficulties exist in monitorlng a fractured aquifer
where migration is along preferential channels, and where a
heavily contaminated zone might lie within a few feet of an
apparently clean monitoring well. This characteristic makes
the classical concept of a cOT1taminant "plume" misleading and
inappropriate for describing migration patterns at this site.
In future studies, EPA will undertake to delineate the plume
present in alluvium of North Criner Creek, further define the
lateral extent of groundwater contamination in the bedrock,
and evaluate the potential for contaminants to migrate beneath
stream drainage divides near the site. Such investigative
activities properly fall within the scope of the second
operable unit.
Trends show water quality is improving with time. This could
indicate that the situation is not worsening, but rather that
the groundwater system is recovering by natural processes.
The historical water quality data is indicative of the presence
of off-site contamination. It is not felt that trends in
contaminant concentrations can be drawn from the information,
since the samples were taken by various parties using widely
varying sampling procedures. Specifically. some samples were
obtained from taps at the. residences rather than directly
from the well. thus subjecting the water to aeration during
pumping and stripping of some volatiles.
If off-site sampling results from various sources were comparable,
the well with the largest historical data base (the old
Corley well). does not show any trend whatsoever. Contamination
is similar to the levels first seen in late 1982. two years
-------
B)
C-16
EPA's OPERABLE UNIT APPROACH TO THE HARDAGE/CRINER SITE
Comments were received which questioned the technical ann legal justification
for EPA's decision to divide the site remediation of groundwater/off-site
contamination as discrete and separable problems.
EPA has addressed a substantial number of NPL sites, including several in
Region 6 (Bayou Bonfuca, Gurley Pit, Vertac, Motco, Highlands Acid Pits,
Odessa Chromium I, and Odessa Chromium II), by dividing the response into
operable units.. These divisions are made based on technical information for
the sit~ and the criteria presented in the NCP. As noted in the FS, EPA
believed at the time the division was made, and continues to believe, that a
substantial quantity of wa~tes remain in or near their original location and
are not contained by adequate barriers and that a remedy for source control
will be cost-effective and consistent with a premanent overall remedy for the
site, thus meeting criteria set forth in the NCP for operable unit remedial
response. The best engineering judgement of the Remedial Site Project Officer
(RSPO), EPA Regional and Headquarters managers, and EPA contractors was that
the vast majority of releases of hazardous substances to the environment
could be abated by controlling these source areas which comprise less than
10% of the site area. Strategies for cleanup of existing groundwater contam-
ination or knowledge of the necessity of such actions is not necessary in
order to determine the best method of containing the wastes. Source control
and management of migration are in this case clearly seperable; therefore,
further delays are unnecessary and would be inconsistent with provision of a
timely response to a situation posing an imminent and substantial endangerment
to public health and welf~re and the environm~nt.
Response is provided below to specific comments on the operable unit approach
taken on the .Hardage site.
Comment:
No technical justification exists for an operable unit approach to
the Hardage site; the decision to address the site in this manner
was ariven by budgetary problems and previous delays in completion
of the FS.
Response:
The technical justification for splitting the site into operable
units is strong, as discussed above. The questions about pathways
of contaminant transport to offsite alluvium and the extent of .
surface contamination away from the source areas are not mandatory
considerations in the question of source control and the existence
of barriers to migration. Since all proposed source control alter-
natives involve waste excavation and stabilization, which remedy is
finally selected is not a concern in relation to the Management of
Migration operable unit, therefore delays to determine the ground-
water/offsite remedy are unnecessary. The criteria set forth in
the NCP for use of operable units has been met; and no strong
justification exists for not using the approach and further postponing
cleanup of the site. The comment that EPA employed operable units
due to budgetary problems is unfounded; the cost of the DSR/FS
project was slightly over $800,000 less than is sometimes sp~nt or
-------
, "
Comment:
Response:
Comment:
Response:
Comment:
Response:
Coment:
Response:
C-17
EPA has worked on the site for three to five years; so expediting
the remedy makes no sense at this point. Further studies should
be conducted and a new FS prepared to address the site as a whole
rather than as operable units.
EPA first inspected the Hardage site in July 1979; and a complaint
was filed against the operator in September 1980 under Section 7003
of RCRA. While EPA has been involved with the Hardage site for nearly
seven years now. active Superfund involvement did no begin until 1984.
Field work was commenced by EPA in July 1984 and the FS was released
in February 1986. twenty months later; the normal period of time in
which EPA attempts to complete its investigations and FS on Superfund
sites is eighteen months. Delays on this site under Superfund have
have not been exceptional; and any delays which have occurred do
not provide a justification for further unnecessary delays.
A cost effective remedy can't be selected without knowing the final
remedy for other parts of the site.
The situation at Hardage is such that excavation and treatmpnt of
the waste piles and pits is required (FS. pages 3-22 through 3-36).
Therefore. the cost-effectiveness consideration is reduced to a
comparison of various treatment technologies and their relative
feasibility. benefits. and permanence. Cost-effectiveness
considerations are only to be applied in comparisons between
acceptable remedies in accordance with Section 300.68 of the NCP.
A remedy for source control should not have to m~et applicable or
relevant and appropriate requirements since it is not the final
remedy [(NCP; Section 300.68 (i)(5)(1)].
The remedies which EPA has developed and evaluated. while not
addressing the entire site. are perma"nent for the source control
operable unit. As such. response actions must be in accordance
with these requirements just as if this remedy were for all aspects
of the site. The passage cited in the NCP refers to interim remedial
measures (such as a temporary cap) which may be implemented while
further study or planning is conducted for the permanent remedy.
The lack of data needed to complete a FS for the entire site prompted
EPA to divide the site into operable units; and these same data
gaps also plague the source control FS. This prevents EPA from
determining the nature and extent of the threat posed or evaluating
proposed remedies.
The "data gaps" are of a quite different nature than the
has implied. Data indicates that releases from the site
uncontrolled; and knowledge to site conditions indicates
situation will worsen.
cOlmlentor
are
-------
C-18
Data is inadequate to determine the appropriate remedy for conta~inants
that have a1re~dy left the site or the extent of cleanup required
for surface mixing areas which may remain contaminated. However,
it is EPAs opinion that the existing data is adequate to allow
development of a source control Feasibility Study. The blanket
statement that these inadequacies plague the FS was not supported
with examples by the commentor. And in the conduct of the FS, EPA
has certainly not felt itself to be "plagued" by this or any other
-------
C-19
C) EPA COMPLIANCE WITH THE NATIONAL OIL AND HAZARDOUS SUBSTANCES
POLLUTION CONTINGENCY PLAN (NCP), 40 CFR PART 300*
Several commenters questioned EPAs compliance with the NCP during conduct
of response action at Hardage. The comments ranged over many points of the
NCP, but were centered on Subpart F - Hazardous Substances Response.
General comments were that EPA had not adequately characterized the site;
the screening of remedial alternatives was flawed or biased; an operable
unit approach is not valid for Hardage; applicable or relevant and appropriate
requirements for protection of public health or welfare or the environemnt
were incorrectly applied or should not have been applied at all; EPA should
have further considered waivers provided in the NCP and further evaluated
those alternatives providing less than adequate protection of public health
and welfare and the environment; and cost-effectiveness was not given adequate
consideration. -
One important purpose served by the NCP is to provide consistency in appli-
cation of CERCLA from one site to another and from one Regional program to
another; and deviations from the NCP could possibly reduce this consistency.
The current NCP was followed at all points through the FS process; and
compliance with the NCP was a major factor in review of drafts of the FS.
Where formal guidance documents and memos covering compliance with the NCP
existed, the material was used. As a result, EPA believes that the FS is
entirely consistent with the NCP. .
Response to specific comments is given below.
Response:
EPAs fai lure to perform a formal RI is inconsistent with the
NCP.sirice: 1) the NCP does not suggest EPA may decide not to
condu(t an RI when one is clearly appropriate; and 2) the data
collected does not serve the purpose of a RI.
The NCP di rects that EPA shall "as appropriate" perform an RI/FS.
This passage does not bind EOA to do an RI if it is not appropriate.
EPA determined that a discrete RI was not appropriate in light
of the already extensive data compiled on the site. The purpose
of an RIfFS, as explained in the nature and extent of the threat
presented by the release and to evaluate proposed remedies (50 Fed
~). ,Thi s purpose has been met. -
. Comment:
.The NCP was promulgated, and is periodically revised, as required by CERCLA,
Section 105. The NCP sets forth the approach to be used in implementing
CERCLA. The most recent revision of the NCP was February 18, 1986 (50 Fed.
-------
C-20
On the other hand, EPA believes that the aggregate of prior
studies and data on the site, when combined with its "Field
Investigation and Data Summary Report", would in fact constitute
a record of substantial equivalence to a discrete RI.
Therefore, the decision was made to move directly to the FS.
EPA must make decisions on how to proceed in cases such as
this based on the best judgement of the RSPO and EPA managers,
and it has acted in a manner not inconsistent with the NCP in
deciding against the additional investment in time and effort
an RI would have involved. The commenter does not elaborate on
why a descrete RI was "clearly appropriate" on this site.
Comment:
The FS is not the functional equivalent of an Environmental Impact
Statement (E1S) as required by the National Environmental Policy
Act of 1969 since the FS does not contain a cost/benefit analysis.
Response:
Conduct of a cost-benefit analysis is not required under CERCLA;
this is confirmed by the Act's legislative history (136 Congo Rec.
916427 (1980).) Furthermore, the public comment period on the FS
serves the opportunity for comments required under NEPA prior to
expenditure of public funds.
The five waivers applying to remedy selection as set forth in the
NCP Section 300.68 (i)(5) should be applied and a remedy selected
which does not meet or exceed applicable or relevant and appropriate
requirements for protection of public health or welfare or the
environment, due to the high cost of rempdial actions meeting these
requirements or due to other circumstances set out in the NCP.
Comment:
Response: The five waivers are stated below along with the reasons they
cannot .be applied to the Hardage site.
1 )
Remed will become art of a more
final remedj for source contro .
remed
- This is the
2)
Fund-Bala~cing - This test is normally applied where there is a fund-
financed response. This is an enforcement lead site; but there is
nothing to indicate fund balancing would be involved even if this were
a fund-financed
response.
Technical 1npracticality - Remedies meeting requirements are technically
feasible and can be implemented.
3)
4)
Unacce table Environmental Impacts - This is not anticipated since the
impacts of continued re ease out weigh those associated with remedial
-------
C-21
5)
Enforcement action where the fund is not available, public desire for
cleanup 1S strong, and llt1gatlon would probably not result ln a better
remedy - EPA believes that, if necessary, litigation will produce the
deslred result and fund may be available. It should be noted that
Hardage/Criner is a National Priority List (NPL) site, so the Superfund
may be applied TO remedy the site if the Agency chooses.
For the above reasons, the waivers will not be applied; and the selected
emedy will comply with all applicable or relevant and appropriate requirements.
Comment:
Consideration of incineration as a disposal option violates the
cost-effectiveness requirement of the NCP.
Response:
Incineration was retained for consideration since the environ-
mental benefits of organics destruction compared to waste treatment
and landfilling are significant. EPA believes consideration
of waste destruction alternatives, such as incineration, is warranted
and that the failure to consider waste destruction would be contrary
to the Agencies commitment to consider permanent remedies including
those which exceed applicable or relevant and appropriate requirements.
Comment:
Scoping of response actions was not conducted in accordance with
Section 3UO.68(e) of the NCP.
Response:
EPA believes that it in fact has properly considered all of the
scoping factors required by Section 300.68 of the current and
former NCP, as appropriate. Other comments on compliance of the
-------
~-LL
0) The FEASIBILITY STUDY (FS) PROCESS
Comments were received to the effect that the technology screening,
alternative development and screening, and other components of the
. FeasiDility Study process were flawed due to a lack of data or non-
compliance with the NCP.
While it is true that a lack of adequate data could bias the results of
the FS by forcing the preparers into unwarranted assumptions, the discussion
provided in Section A of this summary regarding what constitutes "adequate
data" is referenced. And, as in response to comments in that previous
section, it is again stated that EPA believes the data is adequate for
the purpose of a FS on Source Control. The data may not be adequate for
detailed design; but that is not the present objective. The purpose of
this FS is merely to present analysis and discussion sufficient for
selection of a permanent remedy for source control.
Comment:
M(EPA) has rejected alternatives found to be protective of public health
and welfare and cost-effective at numerous other Superfund sites". This
commenter expressed the opinion that EPA had inappropriately rejected in-
place containment alternatives. The commenter went on to cite 15 Supprfund
sites in other Regions which they felt were in conflict with the remedies
considered at Hardage. These sites are:
Region #1
Beacon Heights Lanfill, Connecticut;
McKin County (Landfill), Maine;
Region #2
Love Canal, New York;
GEMS Landfill, New Jersey;
Sinclair Refinery, New york;
Helen Kramer Landfill, New Jersey
Region #3
Heleva Landfill, Pennsylvania;
Lackawana Refuse, Pennsylvania;
Taylor Borough Dump, Pennsylvania
Douglasville Disposal, Pennsylvania
White Hou~e Waste Oil Pits, Florida
Region #4
Region #5
Wanconda Sand & Gravel, Illinois
New Lyme Landfill, Ohio
Region *10
Ponders Corner, Washington
South Tacoma Channel, Washington
-------
C-23
Res~onse:
At tnis time. there are hundreds of sites on the Superfund National
Priority List. These sites present unique combinations of factors
involving geology and hydrology. as well as the age, quantity, and
chemistry of contaminants. among other things. For this and other
reason. neither Congress nor EPA has ever taken the position that
consistency between or among Superfund sites is the measure of the
ap~ropriateness of Superfund remedial action at any given site.
The specific test upon which basis Superfund remedial actions are
judged is their consistency with the NCP. In numerous policy
promulgations, EPA has attempted to further clarify those principles
which guide Superfund response efforts. The policy and guidance
documents have changed during the past six years of Superfund implemen-
tation; and they will continue to evolve and expand their scope in the
future. reflecting a predicted increase in the body of knowledge concerning
contaminant chemistry, health and environmental effects, contaminant fate
and transport. and waste control. treatment. and destruction technology.
among other things. As addressed elsewhere within this responsiveness
summary. as well as within the FS itself, EPA believes that its remedial
action proposals are not inconsistent with the NCP as discussed. in the
previous section of this Responsiveness Summary.
For informational purposes, a brief summary of characteristics, differences.
and similarities of the 15 indicated sites vis-a-vis the Hardage site is
presented below. along with a summarycomparlson of their respective
remedies. As the information presented suggests, the commentator's point
is at best overly simplistic and factually inaccurate. Review of these'
sites readily shows why capping may be an acceptable component of the
remedies (just as capping may be included in the second operable unit at
Hardage). The 15 sites referenced can generally be broken into four
categories as discussed below: .
Contaminated Municipal Landfills:
Beacons Heights. Heleva. Lackawana, Taylor Borough, New Lyme. and Wauconda
fall into this category. Such sites are characterized by relatively
minor amounts of hazardous materials co-mingled with large volumes of
municipal trash. In this type of situation. wastes are of a far different
-------
C-24
Capping of wastes in-places was used only on two sites, Beacon and New
Lyme. At New Lyme, little or no grouRdwater contamination has occured or
is likely due to hydrogeology. At Beacon Heights, contaminants are
dispersed and removal is not feasible. Two other sites, lackawana and
Taylor, utilized capping only after partial waste removal. In both cases,
well defined concentrations of drums were present and were removed; the
wastes capped were almost exclusively municipal in nature. One site,
Wauconda, used a cap as an interim measure. The purpose of the cap was
to control surface seepage to a stream.
,
Waste Oil Recycling/Refining Operations:
The McKin, Sinclair, Douglasville, White House, and South Tacoma sites fall
into this category. At such sites, the principal concerns are open pits
of liquid waste and waste spills. Spills represent dispersed waste for
which removal would rarely be a feasible option. Pits are drained on
most such sites, resulting in almost total source removal. At all five
sites noted above, emergency or remedial actions included partial or
complete source removal followed by capping of contaminated soils in
former source areas. This is analogous to the proposed removal of source
areas and possible capping of the former pits at Hardage.
Hazardous Waste Landfills:
The Love Canal, GEMS, and Helen Kramer sites are in this category.
Hardage is similar to these sites only in the respect that similar waste
types were dis~osed. At Helen Kramer and Love Canal, barriers to vertical
migration exist. The layers make slurry wall cut~off feasible; sands
overlying the aquitards lend themselves to easy construction of the wall
and simple and effective groundwater management. At the GEMS site, no
shallow layer is present; however, a thick sand layer allows effective
groundwater management. In additl0n, drummed liquids are not present as
they are at Hardage.
Presented below is a brief summary of site characteristics, differences
and similarities between the site and Hardage.
Beacon Heights Landfill
Region #1
*203 on NPl
Beacon Falls, Connecticut
o municipal/industrial waste landfill operated 1920-78
o
little drummed or other waste remains; most waste was burned as it was
received and only its residues remain
o
groundwater is contaminated in fractured bedrOCK
-------
L-'~
Comparison to Hardage:
Similarities - fractured bedrock underlies bot!; sites
Differences -
The majority of waste once disposed at Beac)n Heights is
municipal. Little waste remains in its original location,
most has been burned or already released to the groundwater
system.
Remedial Elements:
The sites are not comparable since a well-defined source is present at
Hardage; and the sources at Beacon Heights are dispersed, making source
control inappropriate.
McKin County (landfill)
Region II
133 on NPL
Gray, Maine
o
waste oil recycling site operated in the late 1970s
o
soils are heavily contaminated by spills of solvents
o
all surface tanks and drums have been removed;
Remedy:
Soil contaminated above the clean-up level (11,000 cubic yards) will be
excavated; soil will be aerated and the off-gas burned; capping will be
over areas below the clean-up level
Comparison to Hardage:
Similarities - solvents contaminate both sites
Differences - McKin was a recycling as opposed to disposal facility;
no drummed wastes remain on-site
Consistency with removal at Hardage:
In both cases wastes will be excavated and properly disposed. McKin
is farther along in remedial process (cleanup levels selected already)
-------
~-~o
GEMS Landfill
Region #2
612 on NPL
Gloucester Township, New Jersej
o
industrial waste landfill operated from 1970 to 1974
o
solid and liquid waste was mixed in pits; few or no drums were disposed
o
6 million cubic yards of contaminated fill present
150 feet of permeable sands underlie site, making groundwater recovery
. feasibile
o
Remedy:
Cap site; pump and treat groundwater to remove leachate and lower water
table below wastes
Comparison to Hardage:
Similarities - similar wastes present
Differences - No drums are in the fill at GEMS. Geology makes groundwater
management a feasible and effective method for intercepting
seepage near the source, unlike at Hardage.
Remedial Elements:
At Hardage, drummed liquids are present in the fill and the underlying
interbeded and fractured bedrock does not lend itself to groundwater
management. These complicating factors make the remedy used at GEMS
inapprop~iate for Hardage.
Helen Kramer Landfill
Region '2
*4 on NPL
Mantua Township, New Jersey
o
industrial waste landfill operated from 1970 to 1980
o
2 million cubic yards of waste
o
all types of waste are present including drummed wastes
the site is underlain by a shallow sand aquifer and a deeper aquitard.
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C-27
Remedy:
Cap the fill; install a slurry wall upgradient and a collection trench
downgradient. both with their base tied into the aquitard.
Comparison to Hardage:
Similarities - drummed and bulk wastes in industrial type fill
Differences
Containment of the wastes directly beneath the site is
feasible due to the presence of a barrier to vertical
migration at Helen Kramer.
Remedial Elements:
The lack of a barrier to vertical migration at Hardage prevents effective
containment in place as is possible at Helen Kramer.
Ponders Corner
Region 110
Tacoma. Washington
o dry cleaner dumped sludges on the companies property
o
solvents have contaminated groundwater
o sludge piles (sources) were previously removed by the State of Washington
.Remedy:
Air stripping towers are in-place on municipal wells and are serving the
dual purposes of groundwater collection and treatment; limited excavation
with off-site is disposal planned for the most heavily contaminated soils. '
Comparison to Hardage:
Similarities - solvent contaminated groundwater
Differences - Little of the source remains. ~ost is dispersed into
groundwater system or previously removed; collection
and treatment of groundwater is feasible;
Remedial Elements:
The contaminant source at Ponders Corner has dispersed from it IS original
location. making source control inappropriate. For this reason the
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C-28
Love Canal
Region #2
#136 on NPL
Niagra Falls. New York
o
abandoned canal was backfilled with industrial wastes and closed in 1952; 21.000
tons of wastes including drums are in the fill
o
low-level contamination is present in several media
o
canal excavated in sand overlying plastic clay and till; situation allows
containment in place
Remedy:
Cap was upgraded; slurry walls installed. tied into clay layer; groundwater
collection and on-site treatment system in-place; further studies are
under way due to concern over vertical migration of leachate to bedrock
and the possible inadequacy of in-situ containment.
Comparison to Hardage:
Similarites - drums in fill; similar contaminants
Differences - low-level contamination outside the canal as compared to
Hardage; containment is feasible due to geology
Remedial Elements:
The shallow clay layer beneath Love Canal is thought to allow wastes to be
contained beneath their original location; however. the adequacy of this layer
is still being evaluated. The lack of such a layer at Hardage prevents
consideration of such containment.
Sinclair Refinery
Region 12
'117 on NPL
Wellsville. New York
o
former refinery operation with two on-site landfills; soil was contaminated
by spills
o
fill contains principally bulk wastes
o
small fill area (2 acres and 10-15 feet thick) is adjacent to a river and
is being eroded; larger fill has a clay liner
o
groundwater contamination is present but believed to result from spills
-------
C-29 ,
Remedy:
Excavate the small fill areas. consolidate with the larger landfills and cap;
groundwater will be addressed in other operable units
Comparison to Hardage:
Similarities - Removal is part of the EPA remedy on both sites.
Differences
Groundwater contamination is primarily from spills and
already dispersed contaminants rather than the fill or
concentrated source areas.
Remedial Elements:
The landfills at Sinclair are not leaking; at Hardage they are. For this
reason. source control at Sinclair only needs to stabilize wastes a~ainst
flooding and erosion. If necessary. groundwater management would llkely
be feasible in the river aquifer.
Heleva landfill
Region #3
1152 on NPl
North Whitehall Township. Pennsylvania
o
low level solvents comingled with sanitary waste
o
~source" of off-site contamination appears to be contaminated groundwater
beneath the landfill itself
o
little or no drummed waste is believed present
Comparison to Hardage:
Similarities - Similar contaminants observed off-site
Differences -
little free liquid appears present in the fill at
Heleva. while a large source is present at Hardage.
Since contaminants have generally left the Heleva fill.
Source control is not appropriate
Remedy:
Capping with groundwater pumping and treatment
Remedial Elements:
At Heleva. the "source" of contamination has generally entered the
groundwater system. This type of situation is best remedied by removing
the contaminated groundwater. Since a large volume of free liquids is
not present in the fill at Helelva. capping was assumed adequate to
pr~vent further contanination of the groundwater. Such a system is not
adequate at Hardage due to the physical differences between the sites
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---- -
C-30
Lackawana Refuse
Region #3
#453 on NPL
Old Forge Borough. Pennsylvania
D
sanitary landfill operated through 1976; fill was in old coal pits
10,000 drums dumped in one pit over 4 months in 1976
o
D geology makes the groundwater contamination threat to the public miminal
Remedy:
Remove all drums from pit and dispose off-site; cap former pit area
Comparison to Hardage:
Similarities - drummed wastes present; removal is part of the EPA remedy
Differences - groundwater contamination is less extensive than at Hardage
Remedial Elements:
Hazardous materials will be removed from both sites; at Lackawana the
municipal wastes will be capped. The remedies are consistent since. in
both cases. the wastes will be excavated and properly disposed.
Taylor Borough Dump
Region 3
#635 on NPL
Taylor Borough. Pennsylvania
D municipal/industrial landfill
D
site consists of six distinct areas with varying degrees of contamination
D drums are present in some parts of the filt
D the decision on groundwater issues has been deferred to a later operable
unit
Remedy:
Remove al' drums; cap areas of surface contamination and municipal fill
Comparison to Hardage:
Similarities - drummed waste present; removal is part of the EPA remedy
Di fferences -
surface contamination will be capped at Taylor. while
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C-31 -
Remedial Elements:
Concentrated
both sites.
same general
the remedies
areas of source materials have been or will be removed on
The hazardous wastes at Hardage will be dealt with in the
manner as were similar wastes at Taylor. For this reason,
at both sites appears consistent.
Wauconda Sand & Gravel
Region '5
#126 on NPL
Wauconda, Illinois
o municipal landfill operated from 1940s to 1979
o less than 3~ of the 5 million cubic yards of waste is hazardous/industrial
o fill is in abandoned sand and gravel pit
o groundwater contamination is negligible
Remedy:
Interim remedy is a cap to prevent surface seepage into a nearby stream.
Further study will be done on the groundwater operable unit.
Comparison to Hardage:
Similarities - Both sites have been split into operable units.
Hardage accepted almost exclusively industrial and
hazardous wastes; Wauconda has only a very small percentage
of this type waste. Groundwater has been contaminated
at Hardage. unlike Wanconda.
Remedial Elements:
D1 fferences-
Factors making waste excavation necessary at Hardage are not present at
Wauconda. Specifically, Hardage contains a large volume of hazardous
substances which have been and continue to be released and extensive
groundwater contamination is not a driving force behind remedial action
at ~auconda. Source control and the cap are prinicpally directed at
controlling surface seepage. Such differences make comparison of the
sites difficult.
New Lyme Landfill
Ashtabula County, Ohio
Region '5
1626 on NPL
o municipal landfill which accepted industrial waste
o
little is known on volume or types of waste
o
little groundwater contamination
if necessary, groundwater management is probably feasible
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---
C-32
o
groundwater discharge (up-flow) controls local hydrogeology and
protects groundwater below fill
Remedy:
Construction of a RCRA compliant cap over the fill.
Comparison to Hardage:
Similarities - Relatively small amounts of some wastes disposed at
Hardage are present at New Lyme
Diffences - Little groundwater contamination compared to Hardage site.
No significant amounts of industrial waste was disposed at
New Lyme.
Remedial Elements:
The groundwater flow system at New Lyme acts to prevent seepage out of
the landfill. Since such a natural system is present. groundwater is not
extensively contaminated and a large liquid/sludge source of contaminants is
not present. source control is relatively straightforward. If necessary.
groundwater management would likely be feasible unlike at Hardage. The
sites are generally not comparable.
White House Waste Oil Pits
Region 14
1132 on NPL
Whitehouse. Florida
o waste oil recycling facility
o
Emergency Response cleaned out pits and capped the pit areas
o groundwater contamination present
Remedy:
Repair caps; install slur'ry wall and pump and treat groundwater.
Comparison to Hardage:
Similarities - groundwater contamination; waste removal was integral
to remedy
Differences - waste source areas have already been removed at White
House; and geology makes groundwater management feasible
Remedial Elements:
The site remedies are quite similar. In both cases. the source areas were
removed. The capping and slurry wall at White House are similar to
measures which could be considered. for the second operable unit after
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C-33 -
Douglasville Disposal
Douglasville. Pennsylvania
Region #3
#103 on NPL
o
oil recycling facility;
o
site is located adjacent to river and subject to flooding
in previous actions. drums were removed; lagoons cleaned out and sludges
land farmed on-site; spills have contaminated site
o
o
.groundwater and soils are contaminated
o
river alluvium underlies site; slurry walls are feasibile to cut off
lateral flows
Remedy:
Cap site; and build flood control levee; a slurry wall may be part of the
groundwater remedy
Comparison to Hardage:
Similarity - groundwater and soil contaminated
Differences - former oil recycling facility; source areas have already
been removed; groundwater management is feasible.
Remedial Elements:
Source areas have been or will be removed on both sites; the remedies
are consistent in that similar wastes are handled in a similar manner
(i .e. excavate and treat hazardous wastes).
South Tacoma Channel (Commencement Bay)
Tacoma. Washington
Region '10
111 on NPl
o waste oil recycling and tank clean-out facility operated in 1960s
o
filter cake containing tetrachloroethylene (PCE) was used as fill soil
o
contaminants from spills are dispersed in the soil and underlying
aquifer
Remedy:
Excavate hot spots of PCE and install vapor extraction points in the
ground. Continue air~stripping water in a nearby municipal well.
Comparison to Hardage:
Similarites - groundwater contamination
Differences - source of contamination is spill areas which have already
dispersed into th~ groundwater system; grollndwater
-------
Remedial Elements:
C-34
At South Tac()ma, the waste is dispersed and source control is not
applicable. The cap in this case has a very specific and limited
purpose, to allow solvent vapor extraction.
Other comments related to the Feasibility Study process are as follows.
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
MA rotary kiln incinerator has the potential for incinerating
the site wastes, but its feasibility has not been demonstrated.u
Process upset could result in the emission of dioxins and
furans. The ~ixture of wastes present would pose problems over
and above those associated with a costant waste stream.
Incineration of the specific mixture of wastes present at Hardage
has not yet been demonstrated. However, the types of waste
present have generally been destroyed in this manner. The
problems cited contribute to the cost of over $300 million
estimated for incineration alternatives. Bench tests and
possibly pilot studies would be essential to the remedial
design as would be emissions testing.
EPA considers incineration on virtually all Superfund sites
where organic contamination exists. It is never stated that
the construction and operation of an incinerator would be
simple, only that at this point it appears feasible, and warrants
consideration due to it's benefits.
Incinerator ash may be eligible for de-listing as a RCRA
hazardous waste on a site specific basis.
If treatment of ash removes the characteristics of a hazardous
waste (primarilly EP Toxicity in this case), the ash may be
eligible for delisting. Based on a risk-assesment, delisting
could be considered after it is demonstrated that the above
criteria could be met.
On-site incineration provides no time advantage over off-site
incineration, since the off-site treatment won't take 10 years
as assumed in the FS.
The 10 year figure was based on current backlogs for existing
units. While capacity may increase in the future demand will
also increase. Reduction of the 10 year figure is not warranted
at this time.
Groundwater recovery (pumping) would be feasible in the bedrock
and should not have been eliminated from consideration.
The commenter has ignored the extensive .data collected indicating
fracture zones, uniformly low yield, and the fact that wells
pumping from fractured bedrock will produce a small cone of
depression. For this reason, withdrawl wells would have to be
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Comment:
Response:
Comment:
Response:
Comment:
Response:
C-35
Although the system would still allow substantial releases as
described in the FS, groundwater recovery by withdrawl from a
collection trench system as described in Alternatives 4 and 5,
was deemed feasible.
Technologies for reuse or recycling of waste should have been
considered, particullarly .Basic Extraction Solvent Technology"
(BEST) as employed on the Savanaha site in Georgia.
As noted 1n the FS,. the extreme variability of the wastes at
Hardage virtually eliminates the use of known reuse/recycle
alternatives. Solvents Extraction is quite useful where wastes
are homogerous liquids. However, the waste stream at Hardage
is highly varied and much 1s a high density sludge. The application
of solvent extraction to high solids content wastes will only
result in a minimal reduction in volume to be dealt with.
Reuse/recycle treatments will be considered for certain wastes
if technologies become apparent or are developed.
If the site had been operated after 1980 then capping would have
been an acceptable measure for closure under RCRA. Yet EPA
states that capping is not viable ~nough to even consider as an
acceptable remedy.
The site was not operated after November 1980, partially due
to the operators inability to meet new requirements for hazardous
waste land disposal facilities which went into effect at that
time. Facilities. which legally operated after Nov~ber 1980
presumably were better managed with at least some safeguards
built in. In some cases this may make capping adequate for
containing the wastes. The Hardage facility had no such safeguards
and bedrock has been found to provide inadequate barriers;
therefore, simple closure in-place is not acceptable. (Note:
The commenter went on to argue against the application of other
provisions of RCRA as applicable or relevant and appropriate
requirements).
The factors used to screen all alternatives and eliminate several
were inconsistent with those dictated by the NCP. If the
appropriate factors had been applied, then the FS might have
reached different conclusions.
Section 300.68(g) of the NCP states that, .Three broad criteria
shall, as appropriate, be used in the initial screening of
alternatives." The three "broad" factors to be used are cost,
acceptable engineering practice. and effect1vness. The ranking
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Comment:
Response:
Comment:
Response:
C-36
reliability, implementability, safety, environmental, institutional
and cost. The factors considered fell in the broad categories
listed in the NCP and are consistent with the screening factors
listed in EPA"s FS guidance.
The alternatives which should have been retained for further
consideration in the FS were Alternatives: 13-Capping, IS-capping
with perimeter drains, 17-0n-site landfill, and 110 Off-site
disposal.
The commenter suggest considering two .alternatives which EPA
rejected (#3-Capping and 15- Capping with Perimeter Drains).
Documentation for rejection of alternatives numbered 3 and 5 is
provided in the FS on page 3-27,28 and 3-29,30 respectively.
The principal reason for rejecting these alternatives is their
inability to significantly reduce the release of leachate into
the groundwater system.
The commenter also suggest rejecting two alternatives which EPA
retained (#8- On-Site Incineration and Disposal and 19-0n-Site
Incineration/Offsite Disposal). EPA disagrees with the commenter.
Congress, in the 1984 ammendments to RCRA, has determined that
land disposal of soils contaminated with certain wastes, including
many solvents, should be banned, although a two year extension
is provided for CERCLA response actions. Prior to such regulation,
. some facilities may be hesitant to ac~ept a large volume of
waste with bans pending on it. Destruction of organics is an
.enormous benefit, in that the destroyed compounds will no
longer be capable, of posin~ threats to the public or environment.
EPA is specifically directed by the NCP to consider alternatives
exceeding requirements. Incineration falls into this category
and the benefits may prove commensurate with the costs; therefore
consideration of incineration is appropriate.
The adverse effects of waste excavation were not considered.
These may pose unacceptable environmental impacts and be grounds
for selecting an in-situ alternative not meeting requirements.
The hazards associated with excavating the site were recognized
in the FS. It is believed that releases to all media except
air, can be readily controlled. Releases to air will be minimized
by dust control measures, handling and excavation techniques
aimed at minimizing the volume of waste in the open at any
given time, and possibly placement of a tempo~ary structure
over the waste excavation. Air monitoring will be performed
and the potential threat to adjacent residents will be monitored
throughout operations as will be the potential need for their
immediate evacuation. Threats to workers are real; but this is
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D
Comment:
C-37
A risk assesment should have been performed on the Hardage site.
Response: A preliminary Public Health Assessment has been prepared and
will be supplemented as further data is obtained.
Comment:
Response:
Comment:
Response:
The detailed developement and analysis of alternatives presented
in the FS is inadequate and may not allow selection of the most
appropriate remedy from the four finalists.
Section 300.68(h)(2) of the NCP sets out the factors to be
included, as appropriate, in the detailed analysis. These
factors are: 1) refinement and specification of alternatives;
2) detailed cost estimate; 3) engineering evaluation of effect-
ivness, implementability, and constructability; 4) assessment
of effectiveness of remedy in meeting remedial objectivies;
5) analysis of alternate technologies; 6) analysis of costs of
adverse impacts and their mitigation.
These factors were addressed, as appropriate, and alternatives
were refined in sufficient detail to allow selection of an
appropriate remedy. The development is not to a design level,
but it is not intended to be.
The findings of fact and conclusions of law arrived in 1982 by
the U.S. District Court in Oklahoma City concerning the site
should not have been relied upon to develope a remedy.
The findings and conclusions were not used in-the FS in the
manner that the commenter suggested was the case. The facts
which led to development of these findings and conclusions have
for the most part been supported by data obtained since 1982,
and have therefore been properly considered, along with other
relevant investigative and factual information concerning the
site. EPA did not mean to imply that these findings and
conclusions had to be taken at face value, as they certainly
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C-38
E) OPPORTUNITY FOR PUBLIC PARTICIPATION
Comments were received which indicate some parties feel EPA should have
made a greater effort to involve those parties potentially liable for the
site in development of the FS and should have allowed more extensive.
comments on the FS. The NCP as well as current EPA policy is cited as
support for this argument.
Where appropriate. EPA will generally involve PRPs in studies and development
of response actions. The reasons for this are numerous. not the least of
which is the previous experience of the Agency which suggests that those
parties most directly involved in studies and most familiar with the
rationale for EPA decisions will be most willing to participate in voluntary
clean up. At the Hardage/Criner site, the enforcement policy documents
which recommend PRP participation in the RI/FS were appropriate, had not
been promulgated by EPA at the time the FS was committed. In addition. a
PRP search had not yet been completed. For this reason. PRPs were not
involved from the outset. In December 1984. an initial group of nearly
300 PRPs was notified of their potential liability on the site. Since
that time. approximately 135 parties have formed the Hardage Steering
Commi ttee (HSC).
EPA has met with HSC often since its formation. Final documents have
been provided in a timely manner; and over 200 requests for documents and
information have been answered in writing under the Freedom of Information
Act since early 1985. Communication has ~een frequent between both the
technical and legal staffs and have been as open as the enforcement nature
of the site allows.
Comment:
EPA refused to afford HSC the opportunity to participate in
development of the RI/FS. These actions violated EPAs own
guidelines including the March 20, 1984 memo from Lee Thoms.
MParticipation of PRPs in development of RI/FS under CERCLA
and the draft CERCLA Settlement Policy..
The March 20, 1984 memo indicates that PRPs may be allowed. to
where appropriate. to conduct the RI/FS under an EPA approved
scope of work and under a formalized agreement such as a Consent
Decree. This policy in no way requires or indicates that EPA
will abandon on-going studies merely to allow PRP conduct of
an RIfFS. Regional experience has been that when conduct of
an RI/FS has been switched from one EPA contractor to another,
significant delays result. Even greater delays would be expected
in transfer of the RI/FS to a party out-side the Agency. In
addition. previous activities of HSC have not indicated that
an FS could have been completed by them more rapidly than by
EPA. The.Hardage Steering Committee had not been organized at
the time the FS was initiated in January 1984; aside from this
purley practical reason for not allowing HSC to conduct an
RI/FS. other factors enter into this situation.
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0-
...
Corrrnent:
Response:
COlTlTlent:
Response:
C-39 -
The draft MCERCLA Settlement Policy" referenced to in the
comment was issued October 4, 1985, and does not constitute EPA
policy. Instead, EPAls settlement policy is contained in the
Interim CERCLA Settlement Policy as set forth in the Federal
Register on January 5, 1986. At this time the FS was in its
later stages of development.
Insufficient time was allowed for comment on the FS. The document
is extensive and detailed, thus a comment period substantially
longer than the minimum three weeks required by the NCP would
have been appropriate.
There was a 5 week comment period on the FS; this included a 15
day extension requested by HSC. addition, the FS was placed in
repositories and provided to the HSC two weeks before the
formal comment period began, providing a total of approximately
seven weeks for interested parties to review and comment on the
FS. While EPA and its contractor did spend approximately eight
months compiling the 200 page FS, all data from which this FS
was compiled has been available to the public from the time EPA
began the FS in mid-1985. .
EPA must afford the HSC an opportunity to finalize and present
its own response plan before selecting a remedy.
EPA has repeatedly been told that HSC is or will be preparing
some type of response plan. Unfortunantely this work has never
been produced, forcing EPA into the conclusion that such work
may not be done even if EPA were to wait. Any response plan
submitted to EPA will be considered, as have all proposals,
documents, advice, and comments in the past, provided such a
plan is received in a timely fashion. EPA guidlines and
regulations do not, as the commenter states, require EPA to
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C-40
--.-.-
F)
RECOMMENDATION FOR ADDITIONAL STUDY AND/OR INITIAL REMEDIAL MEASURES
The commenters have proposed a general plan for additional studies which
in their opinion. should be conducted prior to selection of a remedy for
the site. These studies would supplement EPA work and be aimed at developing
a RI/FS for both operable units of the site.
These commenters have also proposed to conduct initial measures aimed at
site stabilization. These measures would mainly included:
1 )
2)
fencing of the entire property.
construction of a temporary cap and collection system for surface
seeps
3)
monitoring of drinking water supplies and construction of alternate
water supplies if necessary.
EPA feels that some of the study items suggested by the commenters are
appropriate. Some of the additional study items and are being considered
by EPA as necessary components of studies for the second operable unit.
EPA sees no purpose in rethinking its previous decision to split the site
into operable units.
The IJroposed "removal" actions have also been considered by EPA. An EPA
site assessment team was dispatched to the site in June 1986 and. following
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o
G}
OTHER COMMENTS
C-41 -
Has EPA considered incineration and disposal of the entire
waste volume at Hardage through underground injection. In this
area. formations below 3000 feet often show caverns which take
enormous amounts of fluids and cannot be plugged by addition of
sealant or bridging materials.
Response: Two problems would be presented by disposing wastes in the
fashion suggested: the actual ability to do this and the legal
and permitting constraints.
Corrrnent:
Conrnent:
Response:
Corrment:
The physical problems with injection would be significant. The
volume of waste considered for disposal is roughly 179.000
cubic yards. or 36 million gallons. of soils and sludge. To
allow injection. the waste would have to be slurried with
water. forming a volume in exess of 100 million gallons of
waste slurry. While this volume could theoretically be injected
in the space of a few weeks. the enormous volume of ~olids
would likely clog cavities rapidly. requiring construction of
several wells over an area significantly larger than the site.
Considering the type of waste found at Hardage. it is unlikely
such injection wells would be permitted by EPA or the State of
Oklahoma.
EPA should select the On-site incineration/Off-site Disposal
Alternative. This is the only way to achieve a permanent
remedy for the Hardage site. Several corrrnentors expressed' this
sentiment; one felt that the On-site incineration and disposal
plan would also be adequate.
EPA favors an on-site disposal plan due to several factors including:
1) the volume of waste present;
2} hazards associated with off-site transport;
3) questionable availability of an off-site disposal facility; and
4} the fact that an off-site plan merely shifts hazards to
another location and population.
EPA will give appropriate consideration to the incineration
options. The decision will be available for public comment
before being finalized as a Record of Decision.
Incinceration should not be selected since 10~ destruction of
compounds such as 2.3.7.8 - tetrachlorod1benzo -p-dioxin (TCDD)
cannot be achieved. In addition. particulates should be sampled
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Response:
Coment:
Comment:
Response:
Coment:
Response:
e-42
--~- _.
100% destruction of anything can never be achieved. Incinerator
testing by EPA in Missouri has in all cases achieved greater
than 99.9999% destruction of TeDO and has effectively destroyed
even hard to burn compounds such as carbon tetrachloride. EPA
sets limits on particulate emissions by incinerators and these
solids would be analyzed in test burns and periodically throughout
the operations.
The waste could be disposed as follows:
o seperate water/solids by settling
o dispose the water in an injection well
o heat the solids to dry them
o seal the solids in a plastic/cement "casket" and bury
o dispose the dirt in another manner
This plan is, in some ways. similar to the on-site disposal option.
The waste treatment and handling techniques have not yet been
fi nal i zed. These coments and pl ans wi.ll be considered in the
design phase of remedial planning.
Do provisions exist for indemnifying contractors involved in
remedial work on Superfund s~tes from possible future liability
under CERCLA for hazards arising from the site at some timp.
after this work is completed.
Under current law, the contractor cannot be indemnified even
for actions carried out at EPAs direction. Provisions for
contractor indemnification will likely be in revised CERCLA
statutes being developed Congress.
EPA should have more thoroughly investigated deep bedrock to
identify existing contamination and evaluate the potential for
contamination in the future. This needs to be done since it is
contamination of deeper ground water and transport through that
flow regime which has the potential to affect populations not
in the immediate vicinity on the site.
One of the key purposes of the Management of Migration RI/FS
will be to define the long-tenm potential for migration along
pathways such as the deeper groundwater. Three wells drilled
on-site to depths of 200 feet or more showed no contaminants at
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"
C-43
IV.
REMAINING CONCERNS
After completion of the FS. public
these comments. some concerns will
affected by or otherwise concerned
thought to be as follows:
comment period. and EPA response to
likely remain among those individuals
with the site. These concerns are
1.
Action should be taken immediately to help reduce health hazards
now present since permanent remedial action may take some time to
complete.
The public wants the cleanup to be a permanent one.
2.
3.
Further studies should be conducted to confirm EPAls decisions on
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