United States Region VIII May, 1980
Environmental Protection 1860 Lincoln Street
Agency Denver, Colorado 80295
Solid Waste
trEPA A TECHNICAL
ASSISTANCE
PROGRAM REPORT
ASSESSMENT OF A
HAZARDOUS WASTE
DISPOSAL SITE
AT ROSE PARK,
SALT LAKE CITY, UTAH
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
TECHNICAL ASSISTANCE PANELS PROGRAM
Assessment of a Hazardous Waste Disposal
Site at Rose Park, Salt Lake City, Utah
Prepared for:
Technical Assistance Panels
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
Prepared by:
Fred C. Hart Associates, Inc.
Market Center, 1320 17th Street, Denver, Colorado 80202
530 Fifth Avenue, 5th Floor, New York, New York 10036
1025 Connecticut Avenue, Washington, D.C. 20036
May, 1980
-------
Public Law 94-580 - Oct. 21, 1976
Technical assistance by personnel teams. 42 USC 6913
RESOURCE RECOVERY AND CONSERVATION PANELS
SEC. 2003. The Administrator shall provide teams of personnel,
including Federal, State, and local employees or contractors (herein-
after referred to as "Resource Conservation and Recovery Panels") to
provide States and local governments upon request with technical
assistance on solid waste management, resource recovery, and resource
conservation. Such teams shall include technical, marketing, financial,
and institutional specialists, and the services of such teams shall be
provided without charge to States or local governments.
This report has been reviewed by the Project
Officer, EPA, and approved for publication.
Approval does not signify that the contents
necessarily reflect the views and policies of the
Environmental Protection Agency, nor does mention of
trade names or commercial products constitute
endorsement or recommendation for use.
Project Officer: William Rothenmeyer
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TABLE OF CONTENTS
Page
I. EXECUTIVE SUMMARY 1
II. ENVIRONMENTAL SETTING 6
A. Site Geology 6
B. Aquifer Characteristics 6
C. Soils 8
References 10
III. INVESTIGATIONS OF THE INCIDENT 11
A. Preliminary Field Survey and Analysis 11
B. Detailed Field Survey and Analysis 11
C. Results of the Analysis 18
D» Conclusions. 21
E. Assessment of Impacts to Downgradient Water Uses .... 21
IV. RECOMMENDATIONS 24
A. General 24
B. Abatement Procedures 24
C. Costs 25
D. Financial Options 25
APPENDIX A: Files Relating to the Rose Park Refinery
Disposal Site A-l
APPENDIX B: Rose Park Refinery Sludge Dump, Utah Geological
and Mineral Survey, Report of Investigation
No. 128 B-l
APPENDIX C: York Research Corporation Report No. 1-1005,
Rose Park Landfill Site C-l
-------
LIST OF FIGURES
Page
Figure 1 - Topographic Map Showing the Location of the
Rose Park Disposal Site 2
Figure 2 - Rose Park Disposal Site 3
Figure 3 - Groundwater Isopleths Indicating Flow
Directions - Jordan Valley 7
Figure 4 - Soil Series Associated with the Rose Park
Disposal Site 9
Figure 5 - Sample Points 12
Figure 6 - Rose Park Disposal Site Showing Test
Boring Holes 13
Figure 7 - Data Acquired in Testholes South of the
Disposal Site 14
Figure 8 - Data Acquired in Testholes North of the
Disposal Site 15
Figure 9 - Data Acquired in Testholes West of the
Disposal Site 16
Figure 10 - Data Acquired in Testholes East of the
Disposal Site 17
Figure 11 - Environmental Resources Downstream from
Rose Park Oil Sludge Site 22
Figure 12 - Schematic Showing Thickness of the Cap and
Slope of the Edge 26
-------
LIST OF TABLES
Page
Table I - Soil/Groundwater Samples jg
Table II - Water Samples 20
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I. EXECUTIVE SUMMARY
The Rose Park refinery sludge dump is located in Salt Lake City,
Utah at approximately 1500 North - 1200 West on Boyscout Drive, just
east of the Rose Park Golf Course (Figure 1).* The site was used until
1957 as a disposal site for refinery waste and demolition debris by the
Utah Refining Company, now a subsidiary of AMOCO. Reports date this
practice from the 19201s until 1957.
Refinery practice was to dump the sludge, spread a thin layer of
refinery residues and then cover with a thin layer of lime. No mixing
was done. A thin layer of dirt was added and the process repeated.
Active dumping areas within the pit were moved periodically so that the
entire pit was filled at a fairly uniform rate. The pit was supposedly
dug into clay. Layering and covering was done with soil or random
borrow/fill material. Demolition and other construction debris were
added to the pit intermittently. The final pit closing in 1957 was
accomplished by mounding dirt onto the accumulated refuse until no
further extrusions were apparent.
In response to residents' complaints, Salt Lake City bought the
land in 1957 to prevent further dumping. One report states that un-
successful attempts were made to remove the sludge to areas away from
population soon after the land was purchased by the city. Approximately
100 truck loads were hauled away in 1960 to an undisclosed location.
After this effort, the sludge was again covered with a layer of soil.
The property was included in the development of the Rose Park Golf
Course. This golf course was built adjacent to the site during the
1960's. In 1974 the golf course was redesigned, leaving an area for the
park and proposed recreational facilities.
In July of 1976, the City began grading and leveling the site for
construction of tennis courts and a parking lot. (See Figure 2 for
present orientation.) The shaving of the overburden cap structure and
passage over the pit by heavy equipment induced several breaks in the
integrity of the cap; once the cap was broken, sludge extrusions
appeared and continued throughout the construction period. During
construction, employees reported various eye, nose and lung irritations
while working in the vicinity of the disposal pit. In response to these
complaints, the Salt Lake City - County Department of Health analyzed
samples of the sludge and recommended air purifying mist respirators for
all workers in the area.
~The history of the problem was compiled from memos and letters from
local and Federal Agency sources included in Appendix A.
1
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Radio To«*f»
„
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Sewage
Treatment
Plant
Substation ~
Pi- - 1'drk
Golf Course
00
o
<
vt
o
o
c
Amoco
Borrow
Area
Fence
Tennis
Courts
"O
Q>
-1
7T
3*
CO
Rooms
Sludge Dump
Park
Area
Figure 2-Rose Park Disposal Site
Residential Area
-------
The analysis by the Department of Health revealed that the
sludge is a "black-tar", with a softening point of 38°C to 49°C, and
highly acidic with a pH of less than 1.0. On days when the ambient
temperature was above 32°C, the sludge was semi-solid, leading to the
formation of pits on the surface of the site. Gas samples at the site
showed that an acid mist is created by the sludge and is released when
the sludge is agitated. The acid was believed to be sulfuric acid and
showed concentrations up to 46 mg/m . In late 1976, the area was fenced
by the City of Salt Lake to limit access to the disposal site.
Early in 1977, Salt Lake City requested a preliminary investigation
by the Utah Geological and Mineral Survey (UGMS) to determine whether
groundwater contamination was occurring at the site. The report
(Appendix B) by the UGMS in October 1978, presented evidence of an
elevated water table beneath the sludge dump, and demonstrated ground-
water flow through the site from the northeast to the southwest. The
UGMS study also analyzed the oil and grease content of groundwater in
the proximity of the site, with highest values measured to the south and
west, consistent with the flow patterns of the area. The study con-
cluded that the Rose Park sludge disposal site seems to be contributing
oil and grease contamination to the groundwater downgradient from the
site.
Fred C. Hart Associates, Inc. was called in through the Environ-
mental Protection Agency's Technical Assistance Panels Program to assess
the oil refining sludge problem and to provide recommendations for
immediate and long-term solutions. The firm gathered information on the
history of disposal at the site, and the surrounding geology, hydrology,
and soils. Samples of the sludge, plus on-site and off-site samples of
soils and groundwater were also taken.
Lab analysis showed that the sludge contains high concentrations of
organic compounds, including o-xylene, o-dichlorobenzene, and toluene.
Of these, o-dichlorobenzene and toluene are defined as hazardous by EPA.
Soil and groundwater samples were analyzed to determine if the
groundwater has been contaminated by the sludge. The samples were
scanned for the two most concentrated organic constituents in the
sludge, o-dichlorobenzene and o-xylene. These compounds were found in
low concentrations at one sampling point 250 feet south of the site and
at several points just outside the fence line.
The conclusions drawn from this analysis are:
1. There are hazardous materials present in the disposal site,
2. It is likely that these materials have not migrated into the
groundwater at appreciable levels, and
3. The potential for migration of hazardous constituents of the
sludge does exist.
Since tests for only two of the organic constituents (albeit the
most concentrated) were conducted in the soil and groundwater samples,
4
-------
it cannot be conclusively stated that no migration of the sludge con-
stituents has taken place.
Recommended mitigative measures include capping the site with an
impermeable clay cover and installing four 50-foot wells on the southern
and western sides of the site. These wells should be sampled and tested
quarterly to determine if contaminant migration is occurring. The total
cost of these recommended actions is estimated to be $150,000.
Information was compiled on the geology, soils and groundwater
resources in the area to provide a general description of the site
environment.
5
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II. ENVIRONMENTAL SETTING*
A. Site Geology
The Rose Park Site is located in the East Plain Water District near
the City Creek Fan Subdistrict of the Jordan Valley in North-Central
Utah. Jordan Valley is part of the Basin and Range physiographic
province, and is a graben within which detrital sediments have been
deposited, probably since middle Tertiary time, (25 million years ago).
The district is bordered on the east by the East Bench Fault, on the
north by the Salt Lake Salient and Salt Lake-Davis County line, and on
the south by the northern most ancient channel scarp of Big Cottonwood
Creek.
The sediments in the East Lake Plain Water District are primarily
blue-gray or yellow lake-bottom clays, with intercalated discontinuous
thin lenses of gravel. In some cases alluvial fans of abandoned flood-
plains deposits may overlay the clays. Within the central area of the
district, less than 25% gravel in intervals in driller's logs has been
found. However, Rose Park is located near City Creek Fan Subdistrict
which has 50% to 100% gravel in intervals, as shown in drillers' logs.
Thickness of the lake bottom sediments in East Lake Plain Water
District is greater than 1,000 feet in most places away from the
boundaries. The rocks are generally semiconsolidated to unconsolidated
having been deposited in the Quaternary as lake or stream sediments.
The Lake Bonneville clay-group underlies these deposits and is primarily
clay.
Field investigations at the Rose Park Site indicate that the strata
surrounding the dump are primarily clay to sandy-clay layers with
discontinuous sand lenses.
B. Aquifer Characteristics
The groundwater flow in the East Lake Plain Water District is
primarily east to west (see Figure 3). Many smal 1-diameter wells
provide a dependable water source from the discontinuous gravel lenses
which occur throughout the lake sediments. The producing gravel beds
are usually 250 to 300 feet deep, but occur in the range of 30 to 600
feet. Within the area surrounding Rose Park, the water source for the
local residents is from the City of Salt Lake public water supply
system. Utilization of groundwater in the area as drinking water is a
rare practice.
~Much of this material has been developed from the references noted
at the end of the chapter.
6
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Disposal
Site
EXPLANATION
Nonf losing well
Flowing well
O 4385 • 4267
Elevation of water surface above mean sea level
measured in the spring of 1958
O (4422) • (4266)
Elevation of water surface above mean sea level reported
or measured ot a time other than the spring of 1958
4600
Contour on water surface, dashed where inferred; arrows
point in direction of flow. Contour intervals 10 and
50 feet, datum is mean sea level
Flowing-well area, 1956; no border where boundary is indefinite
Lond-turfac* contour Interval 200 fe*t, datum it m*on tea level
I O I 2 3 MILES
(42)3)
a
'A
4474
CK4255)
LAKE
SALT
(4455)
r^Q4473
(4238)
(4469)
ration
(46O0!
(4282)
(4256)
4277
SAuT-
4247) ~(4241)
~4278
Fiqure 3 - Groundwater Isopleths indicating Flow Directions Marine,
W.I.; Geology and Groundwater Resources of the Jordan
Valley. USGS, Water Resources Bulletin No. 7. 12/64
-------
Groundwater levels in the area have fluctuated very slowly in
response to climatic changes. This indicates that the permeability of
the strata is low. Within the area of Rose Park, local groundwater flow
is east to west and north to south. Detailed data on the occurence of
the gravel lenses are not available. Within the test borings, water
levels ranged from 5 to 20 feet from the surface. Test borings located
south of the dump filled with water a day after installation. The rock
layers varied in apparent permeability, some of them appearing as a
sludge when removed, others were barely moist. Due to sampling methods,
sections where no material was recovered could potentially have been
pervious sands and/or gravel lenses.
C. Soils
Four soil series are present in the general area of Rose Park
(Figure 4). The refinery disposal site is classified as (Du) Dumps, a
miscellaneous land type that consists of uneven piles of material, such
as waste rock from rock quarries, waste products from smelters, and
garbage dumps.
The land to the northwest and south of the site contains soils in
the Chipman series. This series consists of poorly drained soils of
floodplains primarily adjacent to the Jordan River. These soils formed
from alluvium derived mainly from transported sedimentary and igneous
rocks. Chipman silty clay loam, which is found in Rose Park, is a soil
which occurs on river floodplains primarily adjacent to the Jordan
River. Surface topographic characteristics are generally flat with
slopes of 0 to 1 percent. The soil has a profile described as represen-
tative of the Chipman series. Available water holding capacity is
approximately 12-14 inches to a depth of 5 feet. Soil is nonsaline to
slightly saline in most places, but some areas are moderately
saline-alkaline.
Loamy borrow pits (Lo) extend to the north of the site. This is a
miscellaneous type that consists of deep, stratified alluvial sediments
where from 2-20 feet of material has been removed from the surface for
highway fill or for other purposes. The material that remains is pre-
dominantly sandy loam to clay loam in texture, but in some places, has
layers of sand or clay. Slopes are nearly level.
Made lands (Ma) extend along the eastern side of the site along the
highway. This series is again a miscellaneous land type that consists
of areas covered with such material as gravel, rock, concrete slabs, and
other non-organic materials other than soil. It has been built up for
industrial use, and is not suited for farming use.
8
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Radio Towers
o 0
l rmirrrj
PARK
GO.LF COURSE
« »
fAI»GROUN05
SALT LAKE CITY NORTH, UTAH
KEY N4045—W11152.5/7.5
Ch-Chipman silty clay loam
Ma-Made lands
Du-Dumps from: USDA Soil Conservation
Lo-Loamy borrow pits Service, "Soil Survey of Salt
Lake City Area, Utah", Washing-
Figure 4 -Soil Series Associated with the Rose Park Disposal Site, ton, D. C., April, 1974
-------
REFERENCES
1. Marine, W. I., "Geology and Groundwater Resources of the
Jordan Valley", Utah Geological and Mineralogical Survey,
Water Resources Bulletin 7, December 1964.
2. McMillan, D. T., "Rose Park Refinery Sludge Dump", Utah
Geological and Mineralogical Survey Report of
Investigations No. 128, October 1978.
3. U. S. Department of Agriculture, Soil Conservation
Service, "Soil Survey of Salt Lake Area, Utah",
Washington, D. C., April 1974.
10
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III. INVESTIGATIONS OF THE INCIDENT
A. Preliminary Field Survey and Analysis
On July 12, 1979, a preliminary site visit was conducted. One
sludge sample was collected during this visit. This sludge sample was
analyzed by Gas Chroma tograph/Mass Spectrometer (GC/MS) techniques in
order to determine the constituents of the tar in advance of the major
field effort held two weeks later. The preliminary analysis indicated
the presence of many organic compounds, characteristic of refinery
wastes. Of the seven compounds detected in the preliminary analysis,
the two most prevalent compounds were o-dichlorobenzene and o-xylene.
For the subsequent analyses, these compounds were identified as
indicators of possible off-site migration of contaminants from the
sludge.
It is important to note that toxic substances as defined by EPA
were included in compounds identified during the preliminary GC/MS scan.
These substances included toluene, o-dichlorobenzene, and derivatives of
benzene, napthalene, and phenanthrene. Migration of these substances
from the site could cause a health risk.
B. Detailed Field Survey and Analysis
A detailed sampling scheme of the soil, groundwater, surface water,
sludge, and the sewer traversing the site was developed (Figure 5).
Soil and water samples were taken from test holes in a cruciform
sampling pattern at approximately 50, 100 and 250 foot intervals from
the edge of the fenced area (Figure 6). The soil sample was taken at
the water contact point. If tar was encountered during the drilling,
the drilling was stopped at that point and the auger unit moved further
out from the site. Water samples were collected if groundwater was
encountered or were taken the following day when the bore holes filled
with groundwater.
From July 23-25, 1979, the major field sampling effort was con-
ducted. Soil and groundwater samples were collected from borings
obtained with the assistance of the Utah Geological and Mineral Survey.
Sixteen borings were drilled throughout the site: ten borings were
drilled within the Rose Park recreation area; three borings were drilled
on the adjacent golf course; and three borings were drilled in the AMOCO
borrow pit area. (See Figures 7, 8, 9 and 10 for soil logs taken during
drilling.)
The three borings in the golf course to the west of the site are in
the groundwater migration path toward the Jordan River. The three wells
in this area could be expected to show any contaminant migration toward
the river. Additionally, five sludge samples and two sewer samples were
taken.
Samples were analyzed for pH, sulfate, total organic carbon and the
two indicator compounds: o-dichlorobenzene and o-xylene. The labora-
tory procedures are presented in Appendix C.
11
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Sewage
Treatment
Plant
Amoco
Borrow
Area
• 2
Fence
13 12 11
•20
•22
Tennis
Courts
Substation
Sludge Dump
•21
17*
Rose Park
Golf Course
Rest
Rooms
• 00
•8
Park
Area
•9
Residential Area
Figure 5
Sample Points
-------
Sewage
Treatment
Plant
Substation
Rose Park
Golf Course
Figure 6
Rose Park Disposal Site
Showing Test Boring Holes
-------
SOUTH-
Edge of
Sludge
Dump
3%'
Surface
Brown
Soil
Gray
Clay
10'
Sandy
Blue
Clay
1*
^.Surface
Brown Soil
Light
Yellow
Soil
5'
10'
12%
15''-Water
Light
Gray
Clay
Nothing4
Wet
Clay
5*
_Surface
Light
Brown
Dirt
Light
Gray
Clay
10'
12%'
15'"-Water
15'
Nothing4
Wet
Clay
'-Water
Cross-section of strata south of the sludge pond.
Vert. Scale: 1"= 3'
Horz. Scale: 1"= 80'
"Nothing was brought up by the auger.
Figure 7-Data Acquired in Testholes South of the Disposal Site.
Surface
Brown Soil
Light
Brown
Soil
5'-
Gray
Clay
10'
Nothing*
18'
20'
Wet
Clay
u Water
-------
NORTH ~
Edge of
Sludge
Pond
Surface
5'
10'
Brown
Clay
Brown-
Black
Clay
L- Water
Cross-section of strata north of the sludge pond.
Vert. Scale: 1"= 3'
Horz. Scale: 1"=80'
Figure 8-Data Acquired in Testholes North of the Disposal Site
Surface
.Soil
Brown
Clay
Gray
Brown
Clay
Yellow-
Gray
Clay
3'
5'
Surface
Dry
Sandy
Clay
Red-
Brown
Clay
10'
Gray
Clay
Brown
Clay
Water
15'
Water
-------
WEST-
Edge of
Sludge y
Dump
5'
10'
15'
Surface
Sludge
Gray
Clay
Light-
Gray
Clay
Sandy
Clay
_ Water
5'
8*
10'
15'
Surface
Dark
Brown
Soil
Gray
Clay
Sandy
Clay
Clay
'L Water
4
5
10'
Cross-section of strata west of the sludge pond.
Vert. Scale: 1"= 3'
Horz. Scale: 1"= 80'
Figure9-Data Acquired in Testholes West of the Disposal Site.
Surface
Surface
Dark
Brown
Soil
Gray Mud
Gray
Clay
_ Water
15'
Clay
Sandy
Clays
Wet
Sandy
Clays
20'L Water
-------
EAST-
Edge of
Sludge
Pond
5'
10'
15'
Surface
Dark
Brown
Soil
Gray-
Blue
Clay
Dark
Gray
Clay
Gray-
Blue
Clay
7'
9'
10'
15'
16'
SurfacQ
Red-
Brown
Clay
Gray-
Brown
Clay
Tar and Clay
Dark
Gray
Clay
Gray Sandy Clay
" Water
20'
Water
Surfare
Brown
Rocky
Soil
5'
Gray-
Brown
Clay
10'h
Wet Gray Clay
11'u Water
Cross-section of strata east of the sludge dump.
Vert. Scale: 1"= 3'
Horz. Scale: 1"= 80'
FigurelOData Acquired in Testholes East
of the Disposal Site.
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C. Results of the Analysis
The results of the analysis are presented in Tables I and II.
General
It is important to view the groundwater data and the soil data
separately, as the data are not directly comparable. Groundwater
samples were samples of water taken after drilling. Soil samples
on the other hand, were samples taken at the depth of water con-
tact. The leachate from the soil sample was analyzed to produce
the soil data.
Q-Xylene and O-Dichlorobenzene
Due to their higher concentrations o-xylene and o-dichloro-
benzene were selected as indicators of contaminant migration for
this study. The sampling program did not detect any significant
migration of these substances, except on the immediate periphery of
the site. It is evident from the sampling data that the sludge
occupies an area larger than originally suspected. Aerial photo-
graphic analyses of the area in 1952 and 1978 confirm this conclu-
sion. It is apparent from the photographs that the park rest rooms
are located over the sludge dump pond defined in the 1952 photo-
graphs.
fiH
Earlier tests of the sludge by the Utah Department of Health
found the sludge to be highly acidic. The pH of the sludge samples
taken for this study confirmed this, although there was wide varia-
bility among the five samples. This variability is expected
because of the nature of the dump, i.e., wastes arriving randomly
over a long period of time and being dumped for convenience rather
than control.
The groundwater samples have a pH near neutrality (7.0) while
the leachates extracted from the soil samples are somewhat basic
with pH values near 8.0, reflecting the alkalinity of soils within
the Great Salt Lake Basin. It appears that either off-site migra-
tion of highly acidic sludge leachate is not occurring, or the
acidic leachate is being neutralized through the exchange capacity
of the soil at or near the site.
Sulfate
Sulfate measurements are not a sensitive and unique indicator
of off-site migration of the sludge leachate. The variation in
sulfate concentrations is generally more characteristic of site
specific geology than potential migration. However, sulfate con-
centrations would be expected to offer confirmation of migration
detected by other tests.
The test results from groundwater showed high concentration of
sulfate in close proximity to the dump site. These decline rapidly
18
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Table I
SOIL/GROUNDWATER SAMPLES
Sample York Research pH Sulfate Total o-dichlorobenzene o-xylene
ID Analysis ID (mg/1) Organic Carbon ppm ppm
(mg/1)
North 1
2 Sample Broken In Transit
3
East 4a
60729
8.20
23.5
15.5
189.73
12.25
4b
32651
8.19
110.0
5.5
17.46
1.04
5
32652
7.96
31.0
1.5
*
6
32653
5.86
302.5
<1.0
*
South 7
60725
8.27
117.5
<1.0
~
**
8
60726
8.03
117.5
1.0
~
**
9
60727
8.43
68.5
<1.0
4.56
1.91
10
60728
7.79
23.5
2.5
*
**
West 11a
32654
8.89
10.0
<1.0
~
**
lib
32655
8.68
13.0
1.5
*
**
12
32656
8.07
14.5
6.5
*
**
13
32657
7.85
5.0
<1.0
*
*~
Golf 14
32658
7.20
12.5
6.0
N/A
-
Course 15
N/A
-
-
-
-
-
16
32666
7.56
9.0
5.5
Sludge 19
60768
7.58
13.0
6.5
-
-
20
60765
5.92
2.0
<1.0
-
-
21
32669
3.42
235.0
583.0
100.18
34.74
22
60766
2.27
420.0
<1.0
-
-
23
60767
7.52
2.0
3.0
36.43
7.64
Composi te
* NO = <0.35 ug/g per xylene
** NO = <3.00 ug/g fur o-dichlorobenzene
19
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Table II
WATER SAMPLES
Sample
ID
York Research
Analysis ID
pH
Sulfate
(mg/1)
Total
Organic Carbon
(mg/1)
o-dichlorobenzene
ppm
o-xylene
ppm
North
1
32672
6.90
2200
79.0
*
**
2
Sample
Broken In
Transit
-
-
3
32670
7.20
2850
48.5
*
East
4
5
c
32661
7.89
6200
1108.0
3.32
0.75
South
6
7
32675
7.12
5700
68.5
~
0.09
8
32673
6.96
3300
112.5
*
**
9
32674
7.01
1775
101.5
~
~~
10
-
-
-
-
—
•
West
11
32659
7.92
1250
81.0
0.57
0.35
12
32660
8.10
625
52.5
~
**
13
-
-
-
-
—
_
Golf
14
32668
7.80
800
99.0
*
**
Course
15
32667
7.30
1825
67.0
~
**
16
-
-
-
-
•
—
Sewer
17
32663
7.94
1825
29.0
~
**
18
32664
3.07
900
10.0
*
**
* ND = < 0.35 ug/g per xylene
** ND = < 3.00 ug/g for o-dichlorobenzene
20
-------
as the drill holes move away from the site. No conclusions can be
drawn since sulfate analysis would be only a confirming test for
acidic conditions.
Total Organic Carbon
The total organic carbon (TOC) test is employed to determine
migration of organic compounds other than those selected for
detection, in this case o-xylene and o-dichlorobenzene. Should
other organic compounds be migrating, TOC gives a general
indication of presence but does not identify specific compounds.
Given the highly mineralized nature of the soils in this area,
extraneous organic material was not expected; thus, TOC would be a
good indicator of potential organic compound migration. No
migration was detected.
D. Conclusions
Materials defined as hazardous by EPA are present in the disposal
site. A preliminary GC/MS scan revealed 21 major components found in
the sludge material. Two components (Toluene and o-dichlorobenzene) are
found in EPA's proposed list of hazardous substances. Other components
are derivatives of hazardous compounds. These derivatives may produce
analogous adverse health effects.
All samples were analyzed for o-xylene, o-dichlorobenzene, pH, sul-
fates and TOC. The data analysis indicated that (1) the fenced area
does not correspond to the original dump site, and (2) off-site
migration was not detected. No conclusions, either way, can be drawn
from the sulfate measurements. The soil and geologic conditions in the
area, however, show the potential for substantial migration and possible
groundwater contamination. Further testing for other compounds identi-
fied in the disposal site could reveal the migration of these compounds.
Additional monitoring should be established at the site to detect pos-
sible future migration.
E. Assessment of Impacts to Downqradient Water Uses
As can be seen from Figure 11, several important environmentally
sensitive areas exist downgradient of the sludge disposal site. These
include: the Farmington Bay Waterfowl Management Area (7 miles north)
on the shores of the Great Salt Lake, the Jordan River (3/4 miles west)
and several salt manufacturing industries (10 miles west). Based on the
information assembled to date, the Rose Park waste oil/sludge dump
currently poses no immediate hazard to these areas. This conclusion is
based on the fact that any detected migration from the dump was limited
to the vicinity near the site (no greater than 250 feet off-site). This
does not, however, negate the fact that future, more extensive migration
may occur.
The Jordan River would be the receiving water most likely to be
affected by subsurface discharge from the sludge dump, should any con-
tamination occur. The Jordan River drainage is depicted also in Figure
11. The groundwater of the project vicinity is within the recharge area
of the Jordan River. Groundwater discharge into the river is carried
21
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MUD
Environmental Resources
Downstream from Rose Park Oil
Sludge Site
S«a Gull
Point
Airwty
8 MW
SMHan i
V UrM I
My o
North Si It Lak<
9H A 4225
Radio
Tow«r*
Saltair
Saltair B«ich
, m 42iy!
LAKE
-------
downstream and ultimately into the Great Salt Lake, along which lies the
Farmington Bay Wildlife Area. The worst case situation, of contaminated
groundwater reaching the Wildlife area and the Great Salt Lake via the
Jordan River, is not anticipated. However, to protect the public health
and the environment, the recommended permanent and two year quarterly
sampling scheme should be implemented. This will insure that any future
migration of contaminants, should that occur, will be detected.
23
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IV. RECOMMENDATIONS
A. General
The waste disposal site at Rose Park is a potential environmen-
tal/health problem if mitigating measures are not implemented. Although
the groundwater and soil analyses resulting from the study do not indi-
cate that there has been substantial horizontal migration of contami-
nants from the site, the potential does exist for movement of the
material into the nearby sand/gravel formations. Based upon the charac-
teristics of the regional geology, these formations are discontinuous,
though their exact extent has not been determined. The water supply for
the residents in the area is from the city water distribution system,
and as such, contamination of well water is not a significant problem.
Significant downgradient migration of sludge leachate has not been
found.
The precise characteristics of the strata under the sludge dump are
unknown at this time, and it is possible that vertical movement of the
material could be occurring. Surface contamination is a considerable
threat, due to the fact that the original cap over the dump has been
partially removed. Contamination of surface water from runoff due to
precipitation or to watering of the park grounds may be a possibility.
A protective fence was installed but did not totally enclose the dump;
this allowed access by the public to a portion of the dump around the
restrooms. Thus, park users may be exposed to the sludge and tar.
To mitigate these problems and to determine if the present situa-
tion changes over time, a preliminary abatement program has been
proposed. The waste disposal site should be covered with an impervious
clay layer to prevent further surface contamination. The surface of the
dump should be contoured and revegetated to control surface runoff and
erosion. Since horizontal movement is currently not a significant
problem, and will pose no problems once the site is covered, no vertical
barriers or containment berms are recommended at this time. However,
monitoring wells should be installed to determine possible movement of
the sludge vertically and horizontally through the soil profiles.
8. Abatement Procedures
The entire site should be covered with an impervious clay cover,
consisting of approximately two feet of compacted clay material, with a
maximum permeability of 10 cm/sec. The clay layer will cover the
entire dump, requiring the removal and relocation of the fence and
bathrooms. Capping of the dump will entail the placement of clay over
an area of approximately 770 ft. by 260 ft. or 4.6 acres. A resistivity
analysis should be performed prior to placement of the cap to determine
the exact boundary of the sludge dump. This will ensure that the entire
surface is covered and will protect against contamination of the air
from the sludge material. The edges of the cap will be graded to a
maximum slope of 33 1/3% (3 to 1 slope).
24
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A minimum of 6 inches of sandy loam should be placed above the clay
to prevent the clay layer from drying and cracking, and to provide an
adequate soil base for a short rooted grass cover (see Figure 12). A
jute mat should be placed on the sloped sides to prevent erosion until
the grass becomes established. The clay cover will prevent precipi-
tation and surface runoff from infiltrating into the dump and will
provide adequate cover for wastes which are currently exposed.
3 3
A total of 55,000 yards of clay and 14,000 yards of sandy loam is
estimated to be necessary. Placement of the cap should be done when
temperatures are low and the sludge material is the most stable. After
placement of the cap, equipment traffic should not be permitted. Sur-
rounding the area with a fence would resolve this problem.
Along the southern and western side of the dump four monitoring
wells should be installed to detect any possible contaminant migration.
Two wells on each side should be drilled to a depth of 50 feet. At this
depth both horizontal and vertical movement of the sludge should be
detected. The water should be sampled and analyzed quarterly for con-
tamination for a minimum period of two years, to adequately determine if
migration is occurring. If there is migration, and a health or environ-
mental problem would result, a surrounding subsurface barrier should be
installed around the disposal area.
C. Costs
The total costs required for the abatement program are:
Item
Clay Cover
Sand, Loam Cover
4 Monitoring Wells
Sampling Analyses
(2 years)
Revegetation
Resistivity Survey
Removal of Bathrooms
Relocation of Fence*
Engineering Mgt.
Total
Contingency @ 15%
Cost
$ 60,300.
$ 16,000.
$ 20,000.
$
$
$
$
$
3,200.
5,000.
6,000.
2,000.
4,100.
12,000.
128,600.
$ 19,290.
Assumptions
3
$4.00/yd.^
$4.00/yd.
$5,000/well
$400/quarter
$l,000/acre
$2.00/ft.
10% of construction
Total
$147,890.
say $150,000.
*A perimeter fence may be necessary to prevent equipment traffic,
over the cap of the sludge dump. This option should be further consid-
ered by City officials.
0. Financial Options
The Environmental Protection Agency (EPA), in cooperation with the
Council on Environmental Quality, recently published a guide to Federal
Financial Assistance for Pollution Prevention and Control. None of the
25
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Figure 12 - Schematic Showing Thickness
of the Cap and Slope of the Edge.
Vegetation
X-MtCrtxrfK a-X A//XL/
6" Soil Layer
Clay Cover
Sludge Dump
-------
alternatives in the section entitled "Assistance for Communities" are
applicable to the Rose Park situation.
The Pollution Revolving Fund under the Clean Mater Act is available
for use in removing oil from navigable waters. Si nee there is no
surface water oil pollution from the site, the Rose Park cleaning would
not be an eligible project. If there was surface water oil pollution
from this site, the City could be liable for the direct and indirect
(salaries, travel, etc.) costs of cleanup. There are no known sources
of funds in other sections of the Act.
The creation of a "Superfund" (under the Hazardous Wastes Act of
1980 and other House and Senate Bills), which would provide for the
cleanup of abandoned hazardous waste disposal sites, is currently being
considered by Congress and has been written out of the House Committee
on Interstate and Foreign Commerce and the Senate Committee on Environ-
ment and Public Works (May 1980). This piece of legislation is almost
certain to become law in the near future, in a form which will provide
financial and technical assistance for hazardous waste cleanup. Under
one proposal, a $600 million cleanup fund would be financed on a 50-50
basis of Federal appropriations and fees charged to suppliers of petro-
chemical feedstocks, certain acids and heavy metals, and crude oil. The
fund is to be used solely for emergency response, cleanup and contain-
ment actions and not for EPA administrative and personnel costs,
although $5 million could be used annually for research and development
of cleanup technologies. The law would extend EPA's authority to allow
it to clean up abandoned hazardous waste sites. This lack of authority
over abandoned sites has become one of the primary limitations of the
Resource Conservation and Recovery Act of 1976, which gave EPA authority
to regulate active generator, transporter and disposers of hazardous
wastes. This fund represents the best opportunity to find outside
funding for the Rose Park cleanup costs. Local officials should remain
in contact with EPA Region VIII representatives and keep current on the
progress of the legislation.
27
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APPENDIX A
Files Relating to the
Rose Park Refinery Disposal Site
-------
n E I) 0 R A ,) U U M
To: Date: 7/26/76
Harry L. Gibbons,, M.D.
From: Director of Health
Re: Report on Tar From the Rose Park Area
Samples of black tar from the Rose Pit/area were examined by the Salt Lake
City-County Health Departmerf^. Itvf^r found to soften at approximately
100-120°F. which means that afiofsummer sun probably does more to liquefy
that and cause the volcano-like pits to form more than weight of materials
on top forcing the tar to the surface. The material is only slightly soluble
in Benzene and Hexane and the most significant finding is that it is extremely
acidic. The pH is less than 1. When the tar is extracted with water the pH
is still less than 1.
The acid present is probably sulfuric acid and therefore any attempts to work
with it would require either stainless steel or plastic contact since a pH of
that nature would cause tremendous reaction with most other metals.
The tar will not support combustion but will burn in heat of a Brunson burner.
[n summary, it appears the most dangerous aspect is the acidic nature of the
materials and, in our opinion, the thing that makes it most dangerous is
*;he fact that it gets hot and becomes quite soft and with weight on top of it
:ends to bubble to the surface. Therefore, we suggest that engineering studies
oe undertaken to consider the possibility of a heavy covering in cold weather
«hen it would not tend to force tar to the surface by the weight of the cover
nd would keep the sun from heating up the materials underneath and keep them
. irm.
lease call us if you have further questions on the report.
A-2
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SAffi'EAKgtlM CORBOMnQN?
.EPH S- FENTON
CITY EMCINCCft
ENGINEERING DEPARTMENT
401 CITY a COUNTY BUILDING
SALT LAKE CITY. UTAH 84111
RICHARD A. JOHNSTON
ALVIN L- MASON
ASSISTANT CITY CNCINIIM
ASSISTANT eiT-r CMCINCCH
Augusc 26, 1976
MEMORANDUM TO: Commissioner Jess A. Agraz
FROM: Richard A. Johnston, P. E.
SUBJECT: Rose Park Development Tar Pit Problem
Attached please find all correspondence relating to the possible health
problem existing in the acid sludge dump area, which was discovered on the
Rose Park Development site. The contractor has indicated that he will pro-
vide air purifying mist respirators for use by his employees as they need
them, and we are taking action to rent such respirators for use by our Project
Engineer and Inspector as they need them.
We are also attempting to work with the Streets Department to place bar-
ricades and caution signs surrounding the tar pit area to alert people of
the possible hazard. Mr. Brady has alsd informed the Police Department to
check the area regularly to keep children away from that particnlar area.
I feel that these actions taken will sufficiently handle the situation
for the interim period until we have cone up with a permanent solution to
this tar pit problem.
cc: File
A-3
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August 12, 1976
MEMORANDUM TOl Richard A. Johnston, P. E.
TEOMi Ray Brady
SUBJECT! Possible Health Hazard To VoTkera
Roaa Park Development
Construction activities In the area of the acid sludge iump portion of
the Rose Park Development have caused continual flow and upwelllng of the
addle bitumen found in the Northern Portion of the area.
The acrid odor associated vith these liquids has apparently caused
07a, nose and lung Irritation in City personnel and employees of the con-
tractor on site. The odors and gases, even vith the Southerly winds, do not
appear to reach subdivided areas to the South of the dump, and tho problem
seems to be confined to the Northern poreion of the development area.
I have notified the Salt Lake City/County Baalth Department of thla
possible hazard, and they will respond vith recomaendationB for assuring
the personal safety of the workers involved.
It is ny opinion that when construction activities in the area cease,
equllibrlua of the acid sludge-cover systen will return, and the ealsalon
of acidic odors and any associated air quality problems will decrease and
probably be eliainated.
cci John D. Illskey
f&chard Ranek
Stewart R. Pendslton
File
A-4
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SALT tAJ® til GjDJ.?l?01?ATIQ^t
JOSEPH S FENTON
CITT 1MCINCCR
ENGINEERING DEPARTMENT
401 CITY ft COUNTY BUILDING
SALT LAKE CITY. UTAH 84111
August 26, 1976
RICHARD A. JOHNSTON
ASSISTANT CITT CMOINKM
ALVIN L MASON
ASSISTANT CITT INOINCCII
R. C. Jones & Company
5899 South State
Salt Lake City, Utah 84107
Gentlemen:
Enclosed is a copy of a report on occupational health hazards, prepared by
the Salt Lake City & County Health Department at the Rose Park Development cur-
rently under construction by your company. Men employed by your company during
the time between issuance of the report (August 11, 1976), and my receipt of
the report (August 24, 1976), have continued to report to me various odor related
¦'istresses when working in the vicinity of the acid sludge pit.
In conformance with the Utah Occupational Safety and Health Act, and with
the safety and health of your employees of paramount importance, the recommenda-
tions of the Salt Lake City & County Health Department will be complied with.
Air purifying mist respirators will be provided by you for all employees of your
company working in or near the acid sludge pit, and will be used whenever pre-
vailing conditions make the acidic odor noticeable. It is noted and appreciated
that you have made available your water truck and filter masks when dusty con-
' "i tions prevail.
It should be further mentioned that a report from E.P.A., recently made
available to us, stressed the toxic and caustic properties and possible health
hazards in an acid sludge pit, of nearly identical material, in Little Mountain,
Utah.
Your prompt compliance will be appreciated.
RJB:ph
Enclosure
cc: Joseph S. Fenton
Richard B. Ranck
Richard A. Johnston
File
Very truly yours
/"
Raymond J. €ri
Project Engineer
A-5
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N E M 0
TO: Stew Pendleton, Director FROM: Richard B. Ranck Jr., Chief
Environmental Health Occupational Health and
Noise Control Section
DATE: August 11, 1976 SUBJKCT: Rose Park Tar Pit Area
Employees of the Salt Lake City Engineers office, Ray drjdv and Lynn
/ Milorson, requested and received medical assistance at CCMAC today. They
reported eye and nasal irritation, headaches and pulmonary distress. They
have been working in tho area of the tar pit in Rose Park and believed that
to be the cause of their complaints.
We surveyed this area again today where the R.C. Jones Construction
Company is buildinj; a park adjacent to the tar pit. This company has from
four to six employees working on the site daily along with the construction
inspector, Mr. Anderson from the City engineers office. Mr. flrady, the pro-
ject engineer, visits the site frequently. Employees of the construction
company report similar irritation of the eyes and mucous membranes when they
are working on or near the tar pit area. This is especially true when Clio
wind is blowing. An irritating odor was noticed coming from the exposed areas
on this pit. The area around the pit contained a fine dust that is also
causing problems for employees in this area.
Until this tar pit area is effectively neutralized or covered and
while people are working in tlie area, we recommend the following:
When employees arc working near exposed tar areas .ltul the fumes arc
noticed or irritating, the employer should provide air purifying mist respira-
tors with cartridge and full facepiece. When away from tho tar pit and in
a dusty area, the employer should provide respirators for protection against
dust. This area,south of the tar pit, should also be kept wet to minnimize
the dust hazard.
RBR/td
A-6
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February 9, 1977
TO: Harry L. Gibbons, M.D., MPH
Director of Health
FROM: William Davis
SUBJECT: Rose Park Sludge Dump
The following information has been gathered on the sludge material deposited in
Rose Park.
1. Laboratory analysis shows that the pH of the sludge is less than 1 which can be
irritating to the skin. The sludge has an irritating odor.
2. Gas samples taken show that an acid mist is created by the sludge and has
been released when the sludge is pgitated. The acid is likely sulfuric
acid. Measurements made ranged from 0 to 46 mg/m^. The TLV for sulfuric
acid is 1 mg/m^ occupational exposure for an 8 hour day.
3. The odor or mist from the sludge during the warmer months has caused workers
in the immediate area of the dump to have eye and nasal irritation and
headaches. Richard Ranck has recommended to the city that workers wear
respirators with cartridge and full facepiece during times of high exposures.
4. Depth of the sludge is estimated at 14 feet or more which may create an
affect on the groundwater in the area. However, we have no substantial
information on groundwater in this area and the impact the sludge does or
does not have on it.
As mentioned, most of what has been observed has occurred during the summer
months of the year. A visit to the site February 2, 1977 was made and no odor was
noticeable and most of the surface of the site was covered with snow. The sludge
area has been fenced.
In a brief conversation with Mr. Thatcher of the State Division of Health he felt
that the health hazard of the sludge site had been reduced within reason when the site
had been fenced.
A-7
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SAi:r LAKE GUY CORPORATION
TEQ WILSON
M AVOft
92«>7?04
DEPARTMENT OF PAKKS & PUCLIC PROPERTY
JOHN GUST
PAftr.S Sy^C»iNlENOCNT
300 CITY ft COUNTY BUILDING
SALT LAKE Cfi'V, UTAH H4111
BlIOGtT DIRECTOR
PAUL. F. BARBER
aOMIhisibativc assistant
JOHN HISKEY
SHANNA SANFORO
SPECIAL ASSIST ANT
February 2, 1977
Dr. Harry L. Gibbons
Director of Health
610 South 2nd East
Salt Lake City, Utah 84111
Dear Dr. £ibteerrS,
I have recently met with Representative Gerald Woodmansee and
Mr. David Lewis in regard to the sludge dump in Rose Park.
Tiv»y have advised me that their research shows that the best
possible solution is that of an on site mixing process.
The obvious obstacle to this solution is the cost factor involved .
Estimates have shown that at least $800,000 could be spent on
this project. Indeed such an expenditure will warrant justifica-
tions for an appropriation of this magnitude.
Thus, I am in need of specific data relative to the hazard of this
sludge dump to the surrounding neighbors and the Park patrons.
For example, what specific dangers are therefor small children?
Could fumes from the sludge dump pose any health hazards to the
Park patrons or neighbors?
I would greatly appreciate your advice on these matters and perhaps
any further assistance we might gain from State Health officials. My
staff in the Parks Department would be only too happy to assist you
in your efforts.
TW:dg
cc: Dave Lewis
cerely \^urs
ed Wilso
Mayor
A-8
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SALT LAKE fct/ CITY-COUNTY
HEALTH ^DEPARTMENT
- w n w n h iiirr?V
Salt Lake County
C.D. CmRK, D.D.S.
BOYD N. TWIGGS. Mayor
KENNETH J. REID
LUTHER GIDDINGS, M.D.
ROBERT L. SORBONNE, D.D.S.
HELEN B. URE
RICHARD A. VAN WINKLE
JEAN OSBORNE
SANDRA K ERCANBRACK, Secretary
Murray City
WILLIAM E. DUNN, Commissioner
' Salt Lake City
VAUGHN C. SOFFE, Mayor,
BOARD OF HEALTH
WILLIAM T. SOUTH, Chairman
L C. ROMNEY, Vice-Chairman
GLEN GREENER, Commissioner,
610 South 2nd East. Salt Lake City, Utah 84111
Phone: 532-2002
HARRY L. GIBBONS, M.D., MPH
Director o' Health
February 10, 1977
Mayor Ted Wilson
City and County Building
Salt Lake City, UT 84111
Dear Mayor Ted;
You write nice letters. They have a warm tone to them.
Regarding the sludge material in Rose Park:
1. Laboratory analysis revealed a pH of less than 1. That is
quite caustic and could be extremely irritating to the skin.
It also has an irritating odor.
2. Gas samples show than an acid mist is created by the sludge
and is released when the sludge is agitated. The acid is
probably sulfuric acid, and measurements range from 0 to 46
mg. per cubic meter. The limit for sulfuric acid is 1 mg.
cubic meter occupational exposure for an eight hour day.
3. The odor emitted from the sludge during warmer weather has
caused workers in the immediate area to have eye and nasal
irritation, and headaches.
It has been recommended previously by our industrial hygienist
that city workers wear respirators with a cartridge and full face
piece during times of high exposure.
4. Depth of sludge is estimated at 14 ft. which could create an effect
on ground water in the area. We do not have any substantial in-
formation on the ground water and whether or not the sludge is
affecting it.
A-9
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Mayor Ted Wilson
February 10, 1977
Page 2
A visit made in the first week of February revealed no noticeable
odor. Most of the surface is covered with snow.
Please don't hesitate to contact us if you have further questions.
Sincerely yours
Harry L. Gi
Director ofi
Harry L. Gibbons, M.D., M.P.H.
Director oft Health
HLG/se
A-10
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ENVIRC \ir,;E:v'TAL PROTECTION AGENCY
MAY 2 1977
REFi GS-EP
The Honorable Jafce Garn
United States Senate
Washington, D.C. 20510
Dear Senator Gam:
Your correspondence to tha Beparfcr:ent cf Defense regarding the oil
sludge problem In the Rose Park Area of Salt Lake City has been
referred to this office.
Our involvement In seeking a resolution to this proMerc and our
position on funding was presented 1n letters I i.rote to Senator Frank
'fcss and Salt Laf-e City f'-ayor, Ted I. Wilson. Copies of these letters
are attached for your Infcrraticn and use.
As stated 1n both letters, the Environncntcl Protection Agency does
not have any funding authority cr funds available to assist tlie City in
resolving tJiis oil sluoce prol-lerc.
I hope the information provided will be useful to you in responding to
your constituent.
% best personal regards.
Very truly yours,
ORIGINAL SIGNED BY
JOHN A.
John A. Green
Regional Administrator
Enclosure
bcc: Dean Morris
CAYorkerjb: 4/29/77
CONCURRENCES
tTMiCH. ^
WRKAMC ^
LaZc&>
<+[??
W
JLTA FORM I3ZO-I
OFFICIAL FILE COF
A-ll
-------
July 14, 1977
Rose Park 011 Residue Pit - Salt Lake City. Utah
C. Alvln Yorke, Chief
Emergency Planning 4 Response Branch
THRU: Keith 0. Schwab, Director, Surveillance & Analysis Division
David Wagoner, Director, Air & Hazardous Materials Division
John A. Green
Regional Administrator
This jseno presents a siresary of EPA involvenent on the subject.
History of Pit
The subject pit Is located approximately at 1500 North 1200 West* Just
north of the Eastern end of Rose Pari: Golf Course, and is approximate!/
300* x 1103* * 10'-20* deep. (See attached nap) It was used until 1957
as a disposal site for refinery waste and desoli^lon debris. Salt Lake
City bought the land In 1957 to prevent further dumping, '
As explained by Arsoco Refinery representative at a site meeting on July 15.
1976, Refinery practice was to dunq> and spread a thin layer of Refinery
residues and then cover with a thin layer of lime, So nixing was done, A
thin T^yer of dirt was added and the process repeated. Active dumping
areas within the pit were moved periodically so that the entire pit was filled
at a fairly unifona rate. The pit was supposedly dug into clay. Layering
and covering was done with soil or random borrow/fill material. Demolition
and other building street debris were added to the pit on a non-routine
basis. Final pit closing in 1957 was accocplished by mounding dirt onto
the accumulated refuse until no further extrusions were apparent.
^-In early July 1976. the City began grading and leveling the site for con-
struction of tennis.courts and a parking lot. Shaving the overburden and
passage over the pit by heavy equipoent action) caused several
breaks 1n the integrity of the pit cap. Once the cap was broken, sludge
extrusions began and continued at an accelerating rate.
EPA Involvement
^ — Floyd Nichols and George Rice Teamed of the problem frora Russ Hinshaw
"of the Utafftoealth DepartoenT on July 14, 197(L. They attended the meeting
held at the site on July 15, 397S. Also present at the ceeting were Russ
Hinshaw; Messrs. John Hlskey. Ho/ Brady, and Rick Johnston of the Salt Lake
City Department of Public Works; and an official of the Amoco Refinery.
The Refinery official reviewed the history of the pre-]957 site operations
for the group.
-------
-2-
Slnce extruded sludge 1s very similar to that found at Ogden (odor, texture,
consistency and acidity - no pH measurement made), George and Floyd dis-
cussed at length the EPA operations at Ogden. They Informed City Department
of Parks and Public Works representatives of the alternatives considered,
selected method and reasoning used In that evaluation/selection. Within
a week, George furnished a copy of the 0S£jceport, along with tha biblio-
graphy, to the Department. They stated that EPA financial assistance was
not available. They did state, however, that our expertise, principally
George, would be readily available to them. They also recommended in-unsdiate
Isolation (fencing) and posting of the site. George has had followup con-
versations with the Department but to the best of our knowledge, we have
not been requested to supply anything but money.
EPA has made no atteaipt to determine if offsite migration of pit contents
has or 1s occurring. As found during the February/March A,-noco_elpeline
incident, ground water Just south of the pit Con the opposite side of the
golf course) 1s approximately 10 feet below the ground surface. Therefore,
the pit bottcra 1s probably within the water table. Extensive ground water
sampling around the pit would be needed to determine 1f ground water pollu-
tion Is occurring. There has been no reported surface or ground water
pollution frora the pit.
Correspondence!
3-24-76: John A. Green to Ted t. Wilson, Salt Lake City Hayor
(copy attached).
This letter answers Wilson's letter requesting assistance
in seeking solutions to save the land for a park and recrea-
tional use. Response discusses the July 15, 1976 meeting,
offers further technical assistance from George Rice and
Russ Hlnshaw, and presents two general solutions to the prob-
lems removal and redlsposal, or treatment at site*
11-1-76: John A. Green to Senator Frank floss (copy attached).
This letter answers Moss' request for technical expertise
In solving the problem. Response states the technical
assistance has already been provided but mentions the pos-
sibility of technical assistance funds becoming available
under the Resource Conservation and Recovery Act of 1976,
Response also states that EPA does not have funding authority
to assist city 1n carrying out disposal alternatives*
A-13
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- 3 -
5-1-77: John A. Creen to Senator Jake Garn (copy attached).
This letter answers fiarn's request to the Department of Oefense
(transferred to ETA) for suggestions for funding cleanup of the
oil sludge problem.
Response provides copies of letters to Wilson and Moss and restates
that EPA does not have funding authority or funds available to
assist the city 1n resolving this oil sludge problem.
Funding Possibilities
A. F &CA
The pollution revolving fund under Section 311(k) 1s available for
use In removing oil from navigable waters of the U.S. Since there
is no surface water oil pollution froo tht site, the fund 1s not avail-
able 1n this Instance. (Discussed with Diglane on 7-13-77). If
there vas surface water oil pollution frorc the site, the City could
be liable for the direct and indirect (salaries, travel, etc.) costs
of cleanup. Plus, the City night be liable for violations of Section
311(b)(6) (discharge of oil), 311(J)(l)(r (failure to prepare and
implement SPCC Plan).
There are no knots) sources of funds 1n other sections of the Act.
B. flesource Conservation and Recovery Act of 1976.
According to the Office of Solid Waste and Will 1am Rosecrantz
(Director, Waste ftenageosnt Division - Office of Research and
Development), funds Eight be available 1n FY 78 under Subtitle
H of the RCRA for a demonstration project. However, unless sobs
new technology (other than that used at Gcden Bay) could 1>e dea-
onstrated, it 1s doubtful that a project at the site could be
approved.
C. Other Sources
There are no known funds available under other EPA legislative
authorities. Other federal agencies eight be sources of funds.
Ve understand that a grant of $200,003 has been Issued by the
Bureau of Outdoor Recreation (Department of Interior) which 1s
matched with a Cocnunity Development fund of $185,000.
A-14
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ENVIRONMENTAL PROTECTJON AGENCY
AUG- $76
AUG 2 4 197$
tlEFi 8 S-EP
The Honorable Ted L. Vilson
300 City and County Building
Salt Lake City, Utah 84111
13ear T^ayor Wilson:
I apologize for not responding sooner to your letter of July 15, 1976
concerning the oil dump in the Rose Park. area. Our technical personnel
reviewing your proeles had to be diverted to the Big Xbo&pson disaster effort.
Prior to receiving your letter I>r. George Rice and Floyd Nichols of ay staff
•set at the Zlose Parle area site on July 15 srith !Ir. 3nss Ilinshav of the Utah
Division of Health and Hessrs John Histey, Say Brady, and Riek Johnston of
your Dep&rt&ent of Parks and Public Vorks.
At the July 15 seeting onr personnel explained that there are Tto\ funds
available froa this agency to assist the City in cleaning this old sludge
duaping area. It is our understanding that the City "bought this site in
the aid-1950*s for the purpose of halting any further sludge dumping in
the «tp». Therefore, the City has "been veil aware of the potential con-
flict vlth park expansion for at least 20 years*
In accordance with the discussion on July 15, there are basically two general
solutions.
(1) Zeraxval of the caterlal end redlspocal at a new site, or
(2) treatment of the material at the present site.
Seaoval of tba old dndge to another site voold have to meet regulations and
siting criteria of the State Health Department. Presently, no hazardous waste
disposal sites have "been designated by the State and disposal of hasardooa
vastes are handled on a ease by case basis. Tt appears to us that treatment
at present site wold he less costly and easier to accomplish. This obser
vatlon is based oa onr experience vlth cleanup of a caste oil la°oon near Vest
TZarren, Utaa during the spring and susser of 1974 and our -discussion of the
Hose Park area problem with City representatives oa July IS.
A-15
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Since tha technical problens encountered at West Varren vera sorazvhat
similar to thosa existing in the Rosa Tarlc area, our personnel reviewed
the Veat barren operation at the July 15 nectlng. During the tfest Varrea
cleanup, approxinately 10,000 cubic yards of oil sludge naterial siollac
to that unearthed "by the City in Rose carle was encountered, treated, and
sealed in place.
The entire Vest barren operation, including the problens identified, the
alternatives considered, and the final ctethods utilized, is thoroughly^
docunented in the project report. A copy of this report wes given to
Hr. John Histay, your Assistant TstVs Superintendent on July 20. Thia /
report and the references cited in the bibliography will supply your T
Parhs Department vith our aiost comprehensive infonration on
tion to this type of situation. I}£._R^ce—(telephone •nuribe^'"5o3—52?^
,-i-pA Vf. T!inshaw (telephone nustber ^33-6146)^re both located In Salt Lake.
City and can provide consultation.
In response to your second assistance request, a survey of hazardous
waste oaterials generated in Etah and their present disposal scthods
is currently being conducted by the Bureau of Solid Waste ??anageisant,
State Departaent of Health, under an EPA Cr3nt« Further assistance
can he obtained froa Dr. Dale Parher, Director, Fureau of Solid Paste
TIanageaent, Utah Stata Division of Health Ctelephone nuaber 533-6163).
I hope these suggestions and the information provided will be useful
to you in solving the oil dunp probles.
Sincerely yours,
original signed bf
Charles W. Murray, Jfc
John A. Green
Regional Administrator
A-16
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/ f /
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: July 21, 1977
SUBJECT: visit to Rose Park cn July 19, 1977
\j
from: Water Supply Section \pcyvvy!) y ^ / 3 j
Jack W. Hoffbuhr, Chief
Water Supply Section
George Rice and I visited the site with Russ Hinshaw of the Utah
Health Department and John Hiskey of the Salt Lake City Parks
Department. We were informed that some test holes had been drilled
around the site by Dave Crockett of the Utah Geological Survey, but
no one was certain as to the locations of any of the holes. Apparently
some of the holes are still in existence and have plastic pipe with
perforations in them.
George and I went up to the Geological Survey where we were informed
that Mr. Crockett no longer worked for them as of July 15th. His
supervisor, Mr. Kalister, stated that he was not aware of exactly
what had been done on the project at all, other than the fact that
some holes had been drilled and some samples taken. The Director of
the Survey, Mr. KcMillian, indicated that about 15 holes were drilled
and 12 samples were taken to be tested for hydrocarbons by the City
(he thought). He was unsure as to whether any samples were to be
tested for metals. He was unable to lay his hands on any records of
the study at that time. He indicated that he would try to get the
records of the analyses and the drill hole locations and put them
into a report. I suspect that it will be necessary to follow up on
this to make sure we get any information at all.
We talked to the assistant Salt Lake City Engineer, Richard Johnston
and he confirmed that 15 holes had been drilled and 12 samples had
been taken and were to be analyzed by the City sewage plant for
hydrocarbons only. He did not, however, have any results of the
analyses and didn't know where they were. He did have a map showing
the drill hole locations on it and also showing hydrocarbon amounts
for samples taken on two holes on the north side of the pond. One
hole which was immediately adjacent to the pit had 300 ppm hydrocarbons.
A test hole farther from the pit (the distance from the pit is unknown
as the scale was not shown) had 13 ppm hydrocarbons. The distance was
probably about 300 to 500 feet and can be obtained exactly from the
City Engineers's office. The water level information shown on the
map was incomplete and confusing but indications are that the ground-
water probably is moving to the northwest.
CPA Fm IJJO-t fRr«. 3-741
A-17
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In order to really find out what is happening, we need to obtain the
data on the rest of the samples as well as the water level data and
any records of what sort of material was encountered in drilling. It
will probably be necessary to resample the wells end it may be necessary
to put on a few more test holes depending on the information already
collected.
Paul S. Osborne
A-18
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APPENDIX B
Rose Park Refinery Sludge Dump
Utah Geological and Mineral Survey
Report of Investigation No. 128
-------
UTAH GEOLOGICAL AND MINERAL SURVEY
REPORT OF INVESTIGATION
No. 128
Rose Park Refinery Sludge Dump
published by
UTAH GEOLOGICAL AND MINERAL SURVEY
a division of
DEPARTMENT OF NATURAL RESOURCES
STATE OF UTAH
R-?
-------
Report of Investigation
Utah Geological and Mineral Survey
No. 123
Rose Park Refinery Sludge Dump
by
Donald T. McMillan, Director
October 1978
B-3
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ROSE PARK REFINERY SLUDGE DUMP
by
Donald T. McMillan, Director
Utah Geological & Mineral Survey
INTRODUCTION
In the early part of 1977 the Salt Lake City Corporation
asked Utah Geological and Mineral Survey if they could determine
whether groundwater contamination was occuring at the abandoned
oil refinery sludge dump at Rose Park, east of the tennis courts.
Mr. David Crockett, of this agency, undertook to study the prob-
lem by means of fifteen test holes and reported what he called
a "mounding effect" of the groundwater beneath the sludge dump.
Mr. Crockett resigned just after his work at Rose Park and
in November of 1977 I was able to recover nine of his test holes,
five of which had been cased with perforated plastic pipe and
I could sample the water in four of them. As was the case earlier,
the water level beneath the dump was found to be slightly higher
than the surrounding level.
The data gathered by Mr. Crockett and myself was submitted
to Salt Lake City Corporation with an offer to continue the study
if requested. Upon receiving such request from Mayor Wilson's
office i-i January, 1978, our engineering geologist, James Rogers,
was assigned to the study. Mr. Rogers ran a survey to detect
combustible gas over the area and drilled a new set of thirteen
test holes which were cased with perforated plastic pipes. Water
levels ami samples were secured from each of these holes. The
B-4
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-2-
casings project about a foot above ground, have been capped, and
are available for any further testing desired.
Mr. Rogers accepted other employment before he finished
writing his report so I have taken all of the data collected
during our studies at Rose Park and plotted them on a series of
maps. The following discussion pertains to the several sets of
measurements that have been made and their interpretation.
DISCUSSION
Combustible Gas. A Heath Detecto-Pak II combustible gas indicator
was used to survey the sludge site. Readings were made at 100
foot intervals along lines running north-south and east-west
through the center of the dump. Readings away from the dump were
low, near the instrument's level of detection, but on top of the
dump they increased to a maximum of 3.5 ppm combustible gas at
the center. This survey is shown on sheet 1.
Groundwater Level. The groundwater level, or piezometric surface,
is contoured on sheet 2 for the three time periods that water
samples were analyzed: May and November, 1977 and May, 1978.
Although the pattern of water levels is imperfectly seen because
of widely scattered measurements in 1977, nevertheless at all
three sampling dates the groundwater movement, as shown by the
gradients, was from the north and east to the south and west and
the highest water levels measured are beneath the dump.
The perforated casings of holes A through M are capped and
the water levels can be remeasured and samples taken at any time.
B-5
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Oil and Grease Contamination. The oil and grease content of
water samples taken in May and November, 1977 and on May 30, 1978
are shown on sheet 3. The values in November 1977 are 10 times
the May 1977 values where duplicate measurements occur in holes
5 and 7 but the analyst at the Water Reclamation Plant could
find no error in the calculations; instead, this difference may
be caused by the fact that the holes were in poor condition in
November and considerable dirt was sucked up with the few samples
that we could get.
The thirteen samples taken on May 30, 1978 are the most
complete set. They show low oil and grease content east of the
sludge pit, higher values to the north, and increasing values
to the south and west. This pattern seems to indicate that
groundwater moving down from the north has a generally elevated
oil and grease content derived from the several refineries at
North Salt Lake and Woods Cross, that groundwater moving from
the east is relatively uncontaminated and that as the waters
moving from these two directions merge and flow on to the south
and west the contamination becomes universal. To what extent
the Rose Park sludge dump contributes to the oil and grease
content of water moving to the south and west is not clear but
the highest oil and grease values away from the dump itself on
all three sampling dates were found in holes to the south and
west.
CONCLUSIONS
1) There is a concentration of combustible gas arising from the
sludge pit which reaches a maximum of 3.5 ppm. In the open air
B-6
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-4-
this is not considered to be a hazard.
2) There is a slight elevation of groundwater level beneath the
sludge pit, a condition which frequently occurs beneath landfills.
3) There appears to be oil and grease contamination of ground-
water moving southward beneath the oil refineries at North Salt
Lake and Woods Cross, whereas water moving westward from the
Wasatch Fault zone and higher ground to the east is relatively
free of contamination. The Rose Park sludge dump seems to be
contributing oil and grease contamination to groundwater moving
on to the south and west to judge from the values obtained by
sampling.
DONALD T. MCMILLAN
B-7
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APPENDIX C
York Research Corporation Report No. 1-1005
Rose Park Landfill Site
-------
m
Environmental Consultants
CERTIFIED REPORT TRANSMITTAL
Date Sent: October 17, 1979
METHOD: First Class Mail
COMPANY NAME AND ADDRESS: Fred C. Hart Associates
1665 Grant Street
Denver, CO 80203
ATTENTION: Mr. James A, Rogers
REPORT NUMBER: 1-1005 ADDITIONAL COPIES
The above referenced report is enclosed. Copies of this report
and supporting data will be retained in our files in the event
they are required for future reference.
If there are any questions concerning this report, please do not
hesitate to contact the writer.
Naturally, as in the past, our staff will be pleased to quote
on any future requirements you may have.
Very truly yours,
&{/
Kathryn K. Wahl
Manager, Laboratory Services
York Research Corporation
One Research Drive, Stamford, Connecticut: 06906 • Telephone: (203] 325-1371 *TWX: 710-474-3947
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Environmental Consultants
Report No. 1-1005
Fred C. Hart Associates
October 17, 1979
Samples from the Rose Park landfill site identified as YRC No. 60705
sluge oil and YRC No. 60708 - soil were submitted to York Research
Corporation laboratory on July 12, 1979.
The sludge sample was analyzed by GC/MS. The analysis was run under
the following GC/MS conditions:
Column: 2mx 1/8" 10% SP-2100 on Supelcoport 100/120
Injector: 220°C
Jet: 250°C
Source: 250°C
Analyzer: 100°C
Gain: X6
Injection: 5yl of a 5% mixture in Hexane
Sample was shaken for one hour,allowed to settle before the sample
injection was withdrawn.
The total ion chromatogram indicated the following major components:
YRC No. 60705 Sludge-Oil
Scan #
Total Ion.
Mol. Weight
Identification
9
4382
92
Toluene
13
7636
90?
Unknown
26
2924
106
Similar to xylene
31
1550
106
Xylene
51
1929
120
Mesitylene
52
3020
148?
Unknown
56
6562
Unknown
Unknown
57
7141
146
0 - Dichlorobenzene
74
3821
134
Tetramethylbenzene
76
2859
119?
Unknown
85
5400
162
Triethylbenzene
102
4411
148
Isopropyldimethylbenzene
122
5395
156
Dimethyl Naphthalene
125
5738
156
Ethyl Naphthalene
York Research Corporation(continued page 2)
One Research Drive, Stamford, Connecticut 06906 • Telephone. (203) 325-1371 «TWX 710-474-3947
n-3
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ITS
Environmental Consultants
-2-
Scan #
Total Ion.
Mol. Weight
Identification
127
5305
154
Unknown
176
24119
248?
Unknown
180
12321
192
Methyl Phenanthrene
183
13852
192
Methyl Anthracene
195
17092
206
Ethyl Phenanthrene
199
21348
226
Unknown
207
32423
Unknown
Unknown
Reconstructed total ion chromatogram and copies of the MS scans are
retained in our files.
The soil sample was analyzed by approved procedures for the parameters
listed below.
YRC No. 60708
Soil
Copper
Lead
Zinc
Manganese
Cadmium
Chromium
Iron
Nickel
0.009%
N.D.
0.044%
,066%
005%
0
0
0.097%
48%
Leachate from soil (50g soil/250 ml D.I. water)
PH
Sulfate
8.32
126 mg/1
C-4
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Report No. 1-1005
Environmental Consultants
Fred C. Hart Associates
October 17, 1979
Water, soil, sludge clay tar and clay sand samples from Rose Park
were submitted to the YRC laboratory for analysis. The samples and
their description are as follows:
YRC No.
Date
Sample
Description
60725
7/23/79
Soil GWT
South
00
004
60726
soil GWT
South
100
005
60727
Soil GWT
South
250
006-
60728
Soil GWT
South
500
007
60729
Clay Tar
East
028
008
32651
Clay Tar
East
028
013
32652
Soil GWT
East
128
014
32653
Soil GWT
278
015
32654
Soil GWT
West
027
016
32655
Clay Tar
West
027
017
32656
7/24/79
Soil GWT
West
127
018
32657
Soil GWT
West
267
019
32658
Clay Sand
Gulf
WST
020
32659
Water
West
027
021
32660
Water
West
127
022
32661
7/25/79
Water
East
028
040
32663
Sewer
Downstream
041
32664
Sewer
Upstream
042
32666
Clay Sand
GLF STRM
030
32667
Grd Wtr
GLF STRM
031
32668
Grd Wtr
GLF CRSE
032
32669
Sludge
Middle
033
32670
Water
Nrth
107
034
*32671
Water
Nrth
272
035
32672
Water
Nrth
522
036
32673
Water
South 100
037
32674
Water
South 250
038
iroken in shipment
York
One Research Drive. Stamford.
(continued page 2)
Research Corporation
Connecticut 06906 • Telephone (203) 325-1371 »TWX: 710-474-3947
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Environmental Consultants
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YRC NO.
Date
Sample
Description
32675
60765
60766
60767
60768
Water
Sludge
Sludge
Sludge
Sludge
South 004
039
The samples were analyzed for pH, sulfate, and total organic carbon.
Leachates of the solid materials were prepared by weighing s:0.5g per 100
milliliters of distilled water. The leachate was filtered and subse-
quently analyzed by established EPA procedures and Standard Methods for
the Examination of Water and Wastewater, 1975.
Results are listed in Table I.
TABLE I
YRC No.
PH
Sulfate mg/1
Total Organic Carbon
Water Sampl
es
32659
7.92
1250
81
32660
8.10
625
52.5
32661
7.89
6200
1108
32670
7.20
2850
48.5
32672
6.90
2200
79.
32673
6.96
3300
112.5
32674
7.01
1775
101.5
32675
7.12
5700
68.5
32667
7.30
1825
67
32668
7.80
800
99
32663
7.94
1825
29
32664
3.07
900
10
Leachates of Solid Samples
32669 3.42 235 583
C-6
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Environmental Consultants
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Leachates
of Solid
Samples (.continued)
YRC NO.
PH
Sulfate mg/1
Total Organic
60725
8.27
117.5
<1
60726
8 .03
117 .5
1
60727
8.43
68 .5
<1
60728
7.79
23.5
2.5
60729
8.20
23.5
15.5
32651
8.19
110
5.5
32652
7.96
31
1.5
32653
5.86
302.5
<1
32654
8.89
10.0
<1
32655
8 .68
13.0
1.5
32656
8.07
14.5
6.5
32657
7.85
5.0
<1
32658
7.20
12.5
6
32666
7.56
9.0
5.5
32669
3.42
235
583
60765
5.92
2
<1
60766
2.27
420
<1
60767
7.52
2
3
60768
7.58
13.
6.5
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Environmental Consultants
Preliminary GC/MS analysis (He: YRC No. 60708) indicated the presence
of many compounds which are characteristic of refinery wastes. Of
particular interest were O-dichlorobenzene and 0-xylene which are
not usually considered to originate in refining wastes.
After preliminary solubilization studies, n-hexane was chosen to
extract the aqueous and solid (semi-solid) samples.
The aqueous samples were extracted by separatory funnel techniques
using 100 ml of sample and 25 ml of n-hexane. The remaining samples
(tars, sludges, ground-water-sands) were extracted by agitation of
25 g. of each sample with 50 ml of n-hexane. The sample extracts
were injected into a Perkin-Elmer Sigma 3 Gas Chromatograph (GC)
under the following conditions:
Column @ C:
6' x 1/8"ss
supelcoport
10% SP-2100 on 100/120
50° (1') to 300°C (7') @ 10 /min
Detector @ °C: FID @ 320°C
Injectors;
Carrier Gas:
320°C
Helium @ 30 ml/min
Ancillary confirmation of o-xylene and o-dichlorobenzene was performed
on random samples using a Perkin Elmer model Sigma 3 GC equipped
with a 300 meter SP2100A capillary column.
The results of the analyses are listed in Tables 2 and 3.
TABLE 2
GC Analysis of Water Samples
YRC No.
o-xylene
ppm
o-dichlorobenzene ppm
32659
0.35
0.57
32660
ND*
ND**
32661
0.75
3.32
32663
ND
ND
32664
ND
ND
32667
ND
ND
32668
ND
ND
32670
ND
ND
32671
ND
ND
32672
ND
ND
32673
ND
ND
York Reseat
rch
i Corporation(con't next page)
One Research Drive, Stamford, Connecticut 06906 •
Telephone:'(203) 325-1371 »TWX: 710-474-3947
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Environmental Consultants
YRC No. o-xylene ppm o-dichlorobenzene ppm
32674 ND ND
32675 0.09 ND
*ND = Not Detectable <0.05 ppm
**ND = Not detectable <0.38 ppm
Quantitative GC scans are retained in our files. Copies are available
upon your request.
TABLE 3
Soils; Tar, Sludge Analysis
GC Analyses of Soils, Tar, and Sludge
YRC Sample #
o-xylene yg/g(ppm by wt)
0-dichlorobe
Tar Composite
7.64
36.43
32669
34.74
100.18
60729
12.25
189.73
32651
1.04
17.46
60725
ND*
ND**
60728
ND
ND
60726
ND
ND
60727
1.91
4.56
32652
ND
ND
32656
ND
ND
32653
ND
ND
32654
ND
ND
32657
ND
ND
32665
ND
ND
* ND =*0.35 ug/g per xylene
** ND =<3.00 ug/g for o-dichlorobenzene
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Environmental Consultants
At the request of Jim Rogers of Fred C. Hart Associates, wet sieve
analyses were performed on the Clay Sand samples, YRC Nos. 32658 and
32666.
Results are listed
below
YRC No.
32658
YRC No.
32666
Mesh
Fraction y
wt.la)
%
wt.(g)
%
8
> 2360
N.D.
0
N.D.
0
12
> 1700
N.D.
0
N.D.
0
20
> 841
0.7376
1.85
0.3216
0.701
40
> 425
14.8447
37.29
13.9242
30.33
60
? 250
4.0333
10.13
6.4201
13.98
80
>177
3.2125
8.07
1.9241
4.19
140
> 106
15.2557
38.32
19.2062
14.84
170
> 88
1.1978
3.01
3.4222
7.45
325
> 44
0.4004
1.06
0.2022
0.44
<* 44
0.1300
0.327
0.488
1.06
% Moisture
27.77
25.61
York Research Corporation
One Research Drive, Stamford, Connecticut 06906 • Telephone: (203) 325-1371 •TWX: 710-474-3947
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