United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-89/028
September 1989
Superfund
Record of Decision
Arkansas City Dump, KS

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50272-101
REPORT DOCUMENTATION 11. REPORTNO. 12-
PAGE EPA/ROD/R07-89/028
3. Aedplenta ACC888Ion No.
4. TItle MIl SubtItle
SUPERFUND RECORD OF DECISION
Arkansas City Dump, KS
Second Remedial Action - Final
7. AUlhor(a)
5. R8par1 DaI8

09/19/89
8.
8. Pl8l'formlne Organization R8pt. No.
8. P8r1ormlne Orgalnlzatlon Name and Adc:I....
10. Proj8c1fTa8lllWorII Unit No.
11. ContI8C1(C) Of Gtant(G) No.
(e)
(G)
12- ~ne Organlz8llon Name and Addr8M
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Aapon . PerIod Cov8t8d
Agency
800/000
14.
15. Supplementary No..
18. Abatract (Unlit: 200 _Ida)

The 200-acre Arkansas City Dump site, in Arkansas City, Cowley County, Kansas, abuts a
levee to the west and south which separates the site from the Arkansas River. Between
1916 and 1927, an oil refinery was operated onsite processing between 6,000 and 12,000
barrels of oil per day. After an explosion destroyed the refinery in 1927, the site was
used as a municipal landfill. The refinery treated petroleum fractions with sulfuric
acid to improve color and to remove asphaltenes, parafins, and resinous substances
Igenerating acid sludge waste in the process. The sludge waste was disposed of onsite in
earthen pits in the north waste area and remediation of this area was addressed in a
1988 Record of Decision (ROD), as operable unit one. The second and final operable unit
addresses the remainder of the site, which contains subsurface petroleum contaminants
trapped in the soil below the water table as a result of petroleum spills. Results from
remedial investigations revealed only low levels of soil and ground water contamination
due to onsite disposal of municipal wastes. These contaminants, however, are not being
released in significant concentrations and do not pose a significant threat to human
health or the environment.
The selected remedial action for this site is no further action. Because EPA lacks
jurisdiction or authority under CERCLA/SARA to undertake (Continued on next page)
-
17. Document All81y8la .. Daacrlptora
Record of Decision - Arkansas City
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: petroleum waste
Dump, KS
b. IcMn1IfI8nIOpan-Endad T-
Co COSA TI FIeIdIGroup
18. Avallabilly St8t8m8nI
18. Sacurtty ClaM (Thfa A8port)
None
20. Sacurtty ClaM (TN8 Page)
f\TnnA
21. No. of Pagea
22
I
22. Prfce
(SM AN$.Z38.11)
s..1ne~1I- on RI-
4-11}
(Formarty NTlS-:I5)
OI~.t of Conwnarce

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EPA/ROD/R07-89/028
Arkansas City Dump, KS
16.
Abstract (Continued)
remedial action for petroleum-related contaminant releases, no further action will be
taken under the Superfund program. There are no costs associated with this no action
remedy.

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RECORD OF DECISION
DECLARATION
FINAL REMEDY SELECTION
SITE NAME AND LOCATION
Arkansas City Dump site
Arkansas City, Kansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the final remedy selected
for the Arkansas City Dump site in Arkansas City, Kansas. The
U.S. Environmental Protection Agency (EPA) selected the final
remedy in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and with the National oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. The U.S.
EPA bases this decision upon the documents and information con-
tained in the Administrative Record for this site. Copies of the
Administrative Record are available in the Docket Room at EPA's
Region VII Office (726 Minnesota Ave.) in Kansas City, Kansas, at
the Kansas Department of Health and Environment (Forbes Field,
Building 740) in Topeka, Kansas, and at the Public Library
(120 East 5th Avenue) in Arkansas City, Kansas.
The State of Kansas (Department of Health and Environment,
KDHE) has been the lead agency on this site and concurs with the
final remedy selected by EPA.
DESCRIPTION OF THE SELECTED REMEDY
The EPA, in consultation with the State of Kansas, has
determined that it lacks jurisdiction or authority to undertake
or require additional response or remedial actions under
CERCLA/SARA for the petroleum-related contaminant releases
outside of the first operable unit at the site. Therefore, the
final remedy for the site is "No Further Action."
The EPA and KDHE have already selected remedial actions for
the North Waste Area operable unit (OU NO.1) at the site in an
earlier Record of Decision signed on September 29, 1988. The
wastes and hazardous substances disposed in OU No.1 are not
petroleum-related contaminants and, thus, are not excluded from
CERCLA/SARA response actions.
v

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DECLARATION
Under CERCLA, the governmental response authority, release
notification requirements and liability are largely tied to a
release of a "hazardous substance." Section 104 authorizes the
government respond to releases or threatened releases of
hazardous substances, contaminants or pollutants.
The term "hazardous substances" is defined under CERCLA
section 101(14) to include approximately 714 toxic substances
listed under five environmental statutes, including CERCLA. Both
the definition of a hazardous substance and the definition of
"pollutant or contaminant" under Section 104(a) (2) exclude
"petroleum, including crude oil or any fraction thereof," unless
specifically listed under one of the five statutes. Furthermore,
as "petroleum" is defined, hazardous substances normally found in '
refined petroleum fractions are excluded from CERCLA response
actions. Hazardous substances found at levels which exceed those
normally found in such petroleum fractions, as well as substances
not normally found in petroleum products, are not excluded from
CERCLA response actions.

This operable unit addresses only petroleum products and
fractions thereof. The petroleum exclusion therefore precludes
additional response actions on this operable unit from being
undertaken under CERCLA authority. Therefore, no further action
(beyond the remedial action selected in the first ROD on this
site on OU NO.1) is selected as the final remedy on the Arkansas
City Dump site.
q- I r-
crr-1
dv/~~

~ Morris Kay
Regional Administrator
Date
2

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RECORD OF DECISION
Arkansas City Dump Site
Arkansas City, Kansas
Prepared by:
u.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1989
3.
(EPA)

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RECORD OF DECISION
Table of Contents
Declaration
Page 1
Page 3
Title Page
Table of Contents
Page 4
Section 1, Introduction
Page 5
section 2, Community Participation
Page
9
Section 3, Scope of Response Actions
Page 10
Page 10
section 4, Site Characteristics
section 5, statutory Authority
Page 12
Figures
Figure 1, Location of Arkansas City, Kansas
Figure 2, Location of Refinery Wastes 
Figure 3, Location of Municipal Refuse
Page
6
Page
7
Page
8
4

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DECISION SUMMARY
SECTION 1,
INTRODUCTION
1.1
Site Location
The Arkansas City Dump site is located in Arkansas City,
Cowley County, Kansas, about 3~ miles north of the Kansas-
Oklahoma state line (Figure No.1). The site is located in the
southwest part of Arkansas City, covers about 200 acres, .and is
bound on the west and south by a levee that follows the Arkansas
River. The eastern boundary of the site is 8th Street. The
northern boundary of the site is located just south of the rail-
road bed between the levee on the west and lOth Street on the
east (figure 2).
1.2
Site Historv
An oil refinery was located at the Arkansas City Dump site
between 1916 and 1927. The refinery processed between 6,000 and.
12,000 barrels of oil per day until it was destroyed by an explo-
sion and fire in 1927. The refinery was initially called the
Milliken oil Refinery but was later referred to as the Arkansas
City oil Refinery. The site was used as a municipal landfill
after the refinery was closed.

The refinery treated each petroleum fraction with sulfuric
acid to improve product color and remove asphaltenes, paraffins,
and resinous substances. An acid sludge was generated as a wast~
in the operation of the refinery. This waste was unmarketable
and was disposed on the ground or placed into earthen pits on the
site in the North Waste Area. This waste disposal was addressed
in a previous Record of Decision as Operable unit No.1. .
This Record of Decision for Operable Unit No.2, addresses
the remainder of the site, which contains subsurface petroleum
contamination, which resulted from the spillage and handling of
petroleum products. Figure No.2 details the location of the
subsurface oil contamination and the acid sludge.
After the refinery was closed, the 160 acres of the site
south of Madison Street were used for the disposal of municipal
wastes. Based upon ground-penetrating radar data, the majority
of the municipal waste is located adjacent to the access road
along the levee on the western part of the site (Figure No.3) .
5

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. .
001
.. .". ."..". "."." ".- . . .-.; .'.~
figure 1.--location of Arkansas City, Kansas.
. ..- <~. .,. ,.'.
c >~._- - -- ~-~~

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97" 01 ~O'
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a in
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Madison "'''1.-
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sludg onds
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Boundary 01
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II waSil area
II.
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,
EX PLANA TION

. ACID SLUDae
f71 On.-cONT AM IN A TeD AQUIFER seDIMENTS AS
E2J DETERMINED 8Y aEOPHYSICAL MEASUAE""ENTS
o
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o
soo
.
1.000
,
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250 '
t.5OO 2.000 FEET
. I .
soo t.ETERS
Figure 2--Location of Refinery Wastes,
Arkansas City DU8P Site
7

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o
o
o
en
c
a;
37802'30.
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ackson Ave.

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uren Ave.
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Shoo.
eXPLANA TJON
o
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.
1.000 . 1,500 2.000 FEET
250 " ' sOo t.E~S
. LfUNICIPAt. REFUSe
Figure 3--Locatlon ol Municipal Refuse, Arkansas City Dump Site
8

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SECTION 2, COMMUNITY PARTICIPATION
The EPA and the State conduct community relations to ensure
that the local public has input into decisions about Superfund.
actions and is kept informed about the progress of those actions.
As lead agency, KDHE has been responsible for community
relations for OU No.1. The ROD issued September 24, 1985,
relating to OU No. 1, contained a description of historical
community relations on this site, and a Responsiveness Summary
addressing all the public's comments or concerns. A public
meeting was held on the OU No.1 Proposed Plan. A copy of the
ROD on OU No. ~ can be found in the Administrative Record.
Section 117 of CERCLA provides that a notice and brief:
analysis of the Proposed Plan be published, and that the Proposed
Plan be made available to the public. For this operable unit
(No.2), a notice and brief analysis of the Proposed Plan were
published on August 4 and 7, 1989 in the Arkansas City Daily
Traveler newspaper. The notice informed the public of its role
in the decision making process and provided information on the
public comment period, the location of the Administrative Record,
arid methods by which the public could submit oral or written
comments. The notice also presented the preferred alternative
and requested public co~ents on this alternative.

. To provide the community with adequate opportunity to submit
written and oral comments on the Proposed Plan and. related
documents in the Administrative Record, the KDHE and EPA estab-
lished a public comment period from August 7 through 28, 1989..
The KDHE and EPA also held a public meeting in Arkansas City on
April 21, 1989 to present the Proposed Plan, answer questions and
receive comments.
The Proposed Plan and the rest of the Administrative Record
(covering both operable units) were made available for public
review at the Arkansas City Public Library (120 East 5th Avenue,
Arkansas City, Kansas), at KDHE (Forbes Field, Building 740,
Topeka, Kansas), and at the EPA's Region VII Docket Room
(726 Minnesota Avenue, Kansas City, Kansas).
No significant comments were received from the public by
KDHE or EPA on the Proposed Plan or the preferred alternative.
A few people asked questions in the public meeting held. These
questions were answered during the meeting by KDHE and EPA.
9

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SECTION 3, SCOPE OF RESPONSE ACTIONS
As stated above, contamination in OU No.2 is related
primarily to the spillage and handling of petroleum products
the abandoned refinery. Petroleum-based materials and
contaminants in OU No.2 are generally found trapped in soils
the water table and do not appear to be migrating offsite.
from
below
Very low concentrations of a few organic and inorganic
contaminants were found in soils and ground water in OU No.2, which
do not appear petroleum-related. However, such contaminants do
not appear to be migrating offsite and do not pose a significant
threat to human health or the environment. The nonpetroleum
contaminants appear to have resulted from the disposal of
municipal wastes at the site after the refinery closed.
SECTION 4,
SITE CHARACTERISTICS
4.1
TVDes and Characteristics of Wastes and Contaminants
The remedial investigations at the site identified three
main types of wastes or contaminants:
- Acid sludge resulting from refinery operations was
disposed in the North Waste Area. These wastes were
addressed in OU No.1 and are more completely
described in the ROD on OU No.1. Remedial actions by
KDHE and EPA are underway.

- The disposal of municipal wastes after the refinery
was abandoned has resulted in low levels of soil and
ground water contamination. However, these contami-
nants are not being released from the site in signifi-
cant concentrations and do not pose a significant
threat to human health or the environment.
- Spillage and the handling of petroleum products during
refinery operations resulted in oil-contaminated soil
and ground water. oil-contaminated sediments were
found during the drilling of many of the boreholes and
monitoring wells on the site. Most of the boreholes
near the former refinery revealed oil-contaminated
aquifer sediments near or below the water table.

A few onsite monitoring wells had free-floating hydrocarbons
at the water table. Remedial investigation (RI) data suggest
that oil is trapped below the water table in areas where the
water table had fluctuated over the years. When the water table
recovered (raised to its previous elevation), oil remained
trapped in the pore spaces of the soil. The oil appears to be
10

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immobile and is not migrating offsite. oil from.boreholes had a'
diesel fuel smell and, it is believed to have from 11 to 19
carbon atoms. Analytical data from the RI confirmed the product
was petroleum-based.
Most of the lighter hydrocarbons, such as benzene, xylene
and toluene, have apparently volatilized or have been flushed
from the site by the normal flow of ground water. Somewhat
greater concentrations of these compounds were found in oily
sediments. The oily materials appear to be weathering to a
jelly-like consistency and are not migrating offsite.
4.2 Ouantities Qf Contaminants
The bulk of the oil-contaminated sediments are found 10 to
20 feet below the water table or 30 to 45 feet below ground .
surface. The average thickness of the oil-contaminated sediments
is 10 to 20 feet. Data from the RI indicate that approximately
nine acres of the site contain oil-contaminated sediments.
No estimate has been made on the quantity of municipal
wastes disposed at the site, because these municipal wastes do
not appear to release significant concentrations of contaminants
into the environment.
4.3
Summary of site Risks
A baseline public health evaluation was conducted on the
potential hazards associated with possible exposure to
contaminants found at the site, to provide an analysis of site
conditions in the absence of remedial actions. It provides an
understanding of the releases of hazardous substances, pollutants
or contaminants from the site, the pathways of potential human
exposure, and the degree to which such releases violate
applicable or relevant and appropriate environmental public
health requirements.

Contamination at the Arkansas City Dump site is primarily
related to the disposal of acid sludge in OU No.1. Significant
levels of contaminants in OU No.2 are related to the spillage or
loss of petroleum products. Soils in OU No.2 contain
polynuclear aromatic hydrocarbon (PAH or PNA) contamination and
other contaminants which are constituents of petroleum products. .
Onsite ground water in OU No.2 also contains PAHs and other
oil-related compounds. Onsite soil contaminant levels pose a
remote threat of direct contact exposures. However, since land
uses are limited, the potential for direct contact exposures to
onsite soil contamination is minimal.
Similarly, there is DQ onsite use of ground water for
drinking. Significant concentrations of organic, or inorganic,
contaminants have not been found moving offsite in ground water.
There are some nearby drinking water wells. However, these water
11

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supplies do not appear at risk of contamination because of the
very low levels of contaminants found in ground water onsite, and
because the direction of ground water flow is away from these
wells.
In the area of municipal waste disposal, only very low
levels of contaminants were found in the soil or ground water.
Soil contamination posed no significant threat of direct contact
exposures. Nor did the ground water contaminant levels threaten
any of the nearby drinking water wells.
Environmental risks at the site are considered to be low.
The low solubilities (in water), sorption characteristics, and
biodegradability of the waste contaminants all tend to minimize
environmental risks. Accumulation in plant material of the
contaminants present is not expected to be significant, nor is
its entry into the food chain. Surface water contamination is
not considered to pose a significant risk, nor is it a source for
entry of contaminants into the food chain. Movement from the
currently contaminated soil, acid sludge, and ground water is
unlikely, as are adverse environmental effects, from these
sources.
In summary, the principal hazards posed by the Arkansas City
Dump site are thought to be direct contact with the sulfuric acid
and the organic compounds in the acid sludge waste which are
being addressed in OU No.1, and the potential consumption of
onsite contaminated ground water. Presently, there is no con-
sumption of onsite ground water and the potential for contamina-
tion of offsite ground water used for drinking is remote because
of the direction of ground water flow.
SECTION 5, STATUTORY AUTHORITY FINDING
Under CERCLA, governmental response authority, notification
requirements and liability are dependent upon a release, or a
potential release, of a "hazardous substance." section 104
authorizes governmental responses to releases or threatened
releases of hazardous substances, contaminants or pollutants.
The term "hazardous substance" is defined under CERCLA
section 104 (14) to include approximately 714 toxic substances
listed under five environmental statutes, including CERCLA. Both
the definition of a hazardous substance and the definition of a
"pollutant or contaminant" under section 104(a) (2) exclude
"petroleum, including crude oil or any fraction thereof," unless
specifically listed under one of the five statutes. Accordingly,
no petroleum substance can be a "hazardous substance" except to
the extent that it is listed under one of these statutes.
Furthermore, as petroleum is defined, hazardous substances
normally found in refined petroleum products are excluded from
CERCLA response actions. Hazardous substances found at levels
which exceed those normally found in such petroleum products, or
12

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which exceed those normally found in such petroleum products, or
substances not normally found in petroleum products, are .not
excluded from CERCLA response actions. .
Therefore, as the result of the lack of jurisdiction to
address the petroleum-related contaminants in au No.2 under CERCLA,
no further action will be taken under the Superfund Program as to
those contaminants at the Arkansas city Dump site.
13

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Record of Decision (ROD) for
Arkansas City Dump site
Arkansas City, Kansas
This Responsiveness Summary presents the responses of the
Kansas Department of Health and Environment (KDHE), the lead
agency on the site, and the U.S. Environmental Protection Agency
(EPA) to comments received regarding the final remedy proposed
for the site.
The KDHE released a Proposed Plan and related supporting
documents for 21 days of public review and comment on August 7,
1989. The KDHE held a public "meeting on the remedy proposed on
August 21, 1989 in the City Council Chambers of Arkansas City,
Kansas. The City Manager for Arkansas City, several representa-
tives of the U.S. Army Corps of Engineers (COE), and at least one
member of the community attended the meeting. Region VII of the
EPA attended the meeting in support of KDHE, the lead agency.
No negative or adverse comments on the proposed remedy were
received during the public meeting. Several questions or
requests for clarification were received during the meeting.
However, the responses of KDHE and EPA during the meeting satis-
fied the people who asked the questions. The public meeting has
been transcribed by EPA. A copy of the transcript is included in
the Administrative Record for OU NO.2.
The public comment period on the proposed final site remedy
closed on August 28, 1989. No written comments were received by
either KDHE or EPA. Therefore, the verbal responses by KDHE and
EPA to the questions received during the pUblic meeting, as
reflected in the transcript, constitute the responses of KDHE and
EPA to the public's concerns about the final remedy proposed for
this site.

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State of Kansas
MIke Hayd.n, Governor

Department d Health and Environment
DlYleion of !rMronment
Forbea Fltld, 81C1g. 74Q, TopelC&,lCS ~
. i
t
Stanley C. Grant, Ph.D.. 5eCrelary
(1'3) ,.,53,5
FAX (113) -.u..,
September 18, 1989
.
Dav. Crawford
U.S. EPA Region VII
726 Minna.ot. Ave
Kanaae C1ty, KS 8"01
Doar Mr. Crawford;
I have reviewed the draft of the Record of D.cia;on for the Ark
City Dump Operable Unit .2. I have found the document to be
complete and acceptable tc the dep.rtM8n~. The comment. which wer.
made ~ you during our September '8, 1G88 te'.phon. converaation
w~re .1' v.ry minor. .
11' you ehou1d have changes or addition. to thi. document pleas8
inform me of these changes and provide me with an accurate final
COp y . - --- - . .

Thanl< you 1'or your assi8tance-:in.-:working toward: a -reso1ution of --.
t.hi8 sit.e.
\ Sincer~

:~k~ ~~

Environmenta1 Q.O'0~18~
Bureau of Environmental
Rernedtation
c
Ron Hammerschmidt
.
Q\at188 1(000Igat»'II. oJr.. M.D., M.P.H.,
Oi~, of .....IUI
(0'3) 2Z'JoU
Jarrw, Pow.', ...c..
OI,.o4ot of EnWCWMftI
(813) ~'535
~ne Allilipt. "".D..
DirtCtOt of Information
- ay.18mt
(D1~ 288-1415
~.r eamon, ~.O.,
Clr.c;ior 01 tilt Kansas Health
and Environmental Laboratory
(1131-"".
~

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,
~ L ~ (PV./
1"'10,0'1
ARKANSAS CITY SUPERFUND SITE
ARKANSAS CITY, KANSAS
GEP 1 6 1.
Public Meetina on Final Remedv Selection ODerable Unit No.2
Held in Arkansas City, Kansas
City Hall, The City commission Room
7:00 p.m., August 21, 1989
Gary Blackburn, RPM, KDHE
.0
Introduction
A public meeting was held by the Kansas Department of Health
and Environment (KDHE), the lead agency on the Arkansas City Dump
site. Region VII of the Environmental Protection Agency (EPA)
also attended and participated in the public meeting.

The public meeting was held to offer the community the
oppportunity to comment on the remedy proposed by KDHE and EPA
for the second and final operable unit at the site. The meeting
was recorded. The transcript of the tape is as follows. In
transcribing the tape, certain portions of the tape were not
clear. Additions made by EPA in typing the transcript are shown
in parentheses.
TranscriDt
Gary Blackburn, Remedial Project Manager, KDHE: This meeting is
being conducted to consider the second operable unit of the
Ar~ansas City Superfund Site. The Kansas Department of Health
and Environment (KDHE) and the U. S. Environmental Protection
Agency (EPA) are holding this public meeting to inform the public
of the actions being taken at the site and to give the public a
chance to comment on any issues they would like to bring up
regarding the site before we make the final decision, which will
be placed into the Record of Decision (ROD).

The Regional Administrator for Region VII, EPA, s~qned a ROD
September 29, 1988 regarding the first operable unit for the
Arkansas City Superfund site. That operable unit dealt with the
acid sludqe at the north waste area. The final cleanup for that
will involve neutralization of the acid sludge, followed by a
soil cover along with some deed restrictions to prevent the
public from beinq exposed to it at any time in the future.

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"
./ '
(
2.
The second operable unit, I believe all of you have a copy
of the Proposed Plan for. Operable Unit No.2, deals with the
remaining contaminants at. the site, predominantly with the oil
contaminated sediments within the subsurface. The oil
contaminated sediments have been viewed by EPA to be excluded
(as reliable for response actions) under CERCLA. The EPA is
statutorily prevented from doing a cleanup of the (portion of
the) site that is related to oil spillage of petroleum products,
including crude oil or any fraction thereof. For that reason,
the petroleum exclusion prohibits EPA from taking any fo~ of
action in cleaning up the oil contaminated sediments in the
subsurface.
Looking at your proposed plan at Figure No.2, you can see
where the oil contaminated sediments lie on the site. There has
been estimated to be between 500,000 and 1 million gallons of oil
within the subsurface. That sounds like an extraordinary amount.
of oil to leave behind and not perform a cleanup. However, with
the nature and the spread of the oil, it is not possible to do
any form of effective cleanup at the site. The oil has
been in the subsurface for probably 50 to 60 years since the oil
refinery was burned down. The oil contamination within the
subsurface appears to be basically in a state of equilibrium, in.
that contaminants that are leaching from the oil are limited
since the contamination has been there such a long period of
time, and it seems that the biodegradation taking place naturally
at the site is consuming the contaminants before the oil
contaminated sediments allow movement offsite. For that reason,
the monitoring option for the site is probably the best option at
this time.
The Kansas Department of Health and Environment will
continue to monitor the site. Monitoring wells are already
onsite now and more will be installed at the time the neutraliza-
tion of the sludge takes place. Long-term monitoring will con-
tinue through the future to determine if contamination is migrat-
ing from the site, and if so, the Department will consider taking
action under other authorities. I guess, at this time, we will
open it up for any questions or comments the public would like to
make.
David Combs Corps of Engineers, Tulsa District' (COE): I just had
a real quick question, David Combs, COE. In Operable unit 2, You
talk about not doing anything about cleaning up the petroleum I
contaminants underneath. What about the acid sludges that are on
the surface? Are you all going to propose any (restrictions)
there?
Blackburn:
You mean with the South waste area?
Combs:
Correct.

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Blackburn: From my understanding the south waste area, the
contractor for the Department indicated that most of those sedi-
ments or most of those contaminants are basically neutral at this
time. I understand that recent inspections of the site have
found that the material is still very liquid and mobile. I
believe that is something that we may ask the contractor under
the operable unit to look at regarding whether neutralization is
necessary or a soil cover there might be necessary.
Blackburn:
Other questions?
.
Combs: Only one other question, David Combs. Out of curiosity,
the risk assessment that was done for Operable Unit 2, what did
it show?
Blackburn: The risk assessment was basically the same for
Operable Units Nos. 1 and 2. It showed that if you consume
ground water from the site itself, that there would be a threat
of cancer. ~t this present time, nobody is consuming ground
water immediately below the site and all downgradient water users
appear to be well within a safe margin (distance from the site) .
The Department is, again, working with the city to impose deed
restrictions for the site to prevent anybody from installing
water wells on the site, which might produce water for consump-
tion purposes. So we have considered and are intending to pre-
vent that from being a risk to the public.

David Crawford, EPA: Dave, I guess that I would add that when we
are doing the remedial" design in the first Operable Unit, we want
to make sure that we don't change the ground water flow patterns
and cause contaminant releases that are not now occurring. 50
that is one of the things we intend to keep a handle on during
the remedial design.
Combs, COE: What is the status of the remedial design on
Operable Unit 1 now?

Crawford: I expect I will probably approve the work plan in a
week or two. They will probably need an additional week or two
after that to mobilize.
Blackburn:
Other questions?.........Yes, Mr. Freeland.
curtis Freeland, City Manager, Arkansas City, Kansas: I thought
it might be good for the state to kind of go over what the antic-
ipated plan is now that funding has been provided for this clean-
up for Operable Unit No.1. What kind of timeframe from now
until that work might take place and be completed.

Crawford: Okay. We are using a contractor called Flour Daniel
out of Dallas to do the remedial design for us. The Remedial
Design, just briefly, will involve neutralization of that semi-
liquid sludge and then a soil cover on top of that. In order to

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do that we are going to need to drill several borings to deter-
mine exactly how large that north waste area is. At that time, I
think we will also take a look at the south waste area to see if:
there is anything over there that needs neutralization. In
addition to doing that, though, I also want to determine how they
are going to do the injection of the neutralizing material. How
far apart those holes will have to be and how much material will
have to be injected and exactly what the material will be. Like
I said, I expect to approve that work plan within a wee~.or two,
and they will probably need a week or two after that to begin the
field work. We hope that by the end of October, I believe, we
hope to'be basically done with the remedial design, at least to i
the extent that we can give the state of Kansas a fairly good
estimate on how much money would be required for the remedial
action. At this point, I think the overall plan is still for the
state of Kansas to be the lead agency on the actual remedial
action, but that would not be able to start, because of winter
weather, before spring at the earliest. . .
Freeland: So the state of Kansas would like a contract sometim~
in the spring if everYthing went well or as it is planned now.

(KDHE and EPA nod to indicate affirmative.)
Blackburn:
other comments or questions?
Freeland: I think another question is to discuss during which
nature of the deed restrictions are being proposed and the poten~
tial uses that might be allowed within the deed restrictions. .

Blackburn: This afternoon, Mr. Freeland and I discussed the
potential deed restrictions for the site. As we discussed deed
restrictions we are looking at, we are going to try to keep to a
minimum, such that the site can be used for some sort of indus- :
trial use that won't infringe on the contamination that will be
left onsite in a capsulated form. The one deed restriction that
probably will cover the entire site would be a deed restriction
regarding water use. Because, at this present time, we believe
that the water under the site is contaminated to such a extent
that we prefer not having any use of that site for any use. The
actual deed restrictions will be worked out with the City and
with existing land owners and, like I say, I don't foresee it
being a real restrictive deed restriction once the acid sludge is
covered. As the risk assessment indicated at the present time,
it appeared the only real risk is the human contact with the acid
sludge causing a burn, an acid burn to someone who might contact
the sludge. The other assessment of the site was that basically,
the only other threat existing would be the consumption of ground
water.
Blackburn:
Other Questions?

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5
,warren Mason, COE: In your deed restrictions, have you
contemplated the idea of restricting further disposal on the
area at significant depths which might compact the soils in the
area, thereby pushing out materials already disposed to the
surface?
Blackburn: That is something that we will be considering as
well, especially over the acid sludge or any king of buried oils
onsite. The subsurface oil contamination does not appea~ to be a
threat of that kind as there is not really a pool or mass that
could be forced out. But, yes, that is something we discussed
and probably, over the acid sludge itself, any kind of construc-
tion would be very, very limited. As far as a basic parking lot
or something of that sort that would be acceptable, but no exten-
sive loading could be allowed over the acid sludge.
Question: Is there any formal plan for location for the addi-
tional monitoring wells to be placed?

Blackburn: That should be done by the actual contractor on the
remedial design portion. And again, as Dave had indicated, that
is one thing that we do want to make very certain that we don't
influence the ground water flow direction and the current ground
water status by that neutralization process. 50 the monitoring
network will be fairly intensive around the acid sludge to deter-
mine whether we created a ground water mound and also downgradi-
ent to ensure that we don't disrupt the actual biodegradation
that is currently taking place within the subsurface.
Combs: I would like to talk a little bit about that old landfill
site. We have the map here that is included in the
plan.........(not intelligible on tape).

Blackburn: Right, Figure No.3 shows the area where there is
solid waste located, and within Figure No.3. The Department will
be doing some monitoring of that side also in conjunction with
the ongoing monitoring of the site. The actual landfill area
will probably be another area where we will suggest that struc-
tures not be constructed due to possible decomposition of subsur-
face materials and future collapse. ....... other questions
regarding the site?
Blackburn: The public comment period will remain open until, I
believe, August 28 for' public comments that anyone would want to
submit. The back page of the Proposed Plan contains phone
numbers and addresses for anyone who would want to submit written
public comments, and those public comments can be sent to either
Rowena Michaels or me. Like I say, the public comment period
will remain open for probably an additional week anyway before it
will close, and anybody who would have significant public
comments they would like to make, or if anybody has comments now
v

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they would like to have us address in the Record
will open it up again for those comments. I will
awhile, yet, afterwards if anybody has any other
would like to raise.
of Decision, I
be around for
questions they
I believe this concludes the Arkansas City Public Meeting.
I thank everyone for attending and, like I say, I will stic
around for any other questions that you might have.
Hazardous We
Information RE
US EPA Region
Philadelphia ( F
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