United Slates Region 8
Environmental Protection 1860 Lincoln Street
Agency Denver, Colorado 80295
<&EPA Little Mountain Salvage Yard
Oil Lagoon Clean-Up
Ogden, Utah 1974 - 1976
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LITTLE MOUNTAIN SALVAGE YARD
OIL LAGOON CLEANUP
OGDEN, UTAH
1974 - 1976
n - ¦•¦¦¦¦ Suilc 500
_Denvor, CO
80202-2466
GEORGE B. RICE
OSC
ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
DENVER, COLORADO
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TABLE OF CONTENTS
I. ABSTRACT 1
II. INTRODUCTION 3
III. COORDINATION AND PLANNING 6
A. RRT Meeting, February 15 ---------------- 6
B. Court Hearing, March 12 ----------------- 13
C. Field Investigations ------------------15
D. RRT Meeting, March 22 ------------------16
E. County Commission, March 22 --------------- 18
F. Operational Plan --------------------19
G. Organizational Plan -------------------23
H. Disposal Site, April 1 -----------------23
I. Field Office Opening, April 2-------------- 25
J. Bid Package and Contractor Selection, April 5, April 12 - 26
K. Land Farm Planning -------------------28
L. RRT Meeting, May 24 ------------------- 28
M. Defendant Attorneys Meeting at Site, May 10, May 15 - - - 30
N. Governor Rampton Meeting, June 7 ------------30
IV. OPERATIONS 32
A. Emergency ------------------------32
B. Lagoon - -- -- -- -- -- -- -- -- -- -- -- --37
C. Land Farm ------------------------ 44
D. Concluding -----------------------47
1. Lagoon ----------------------47
2. Land Farm ---------------------48
E. Discussion ---------------------- -
V. COSTS AND RECOVERY 53
VI. RECOMMENDATIONS 53
VII. ACKNOWLEDGEMENT 54
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Figure A-l: Location Map - Lagoon and Disposal Site
A-2: Lagoon Area Map
A-3: 1973 Lagoon Sampling
A-4: March 1974 Lagoon Survey
A-5: Organizational Chart
A-6: Sludge Disposal Site Location Map
A-7: Lagoon Liquid Flow During Emulsion Concentration
A-8: Lagoon Liquid Flow During Emulsion Concentration
A-9: Lagoon Liquid Flow During Evacuation
A-10: July 1974 Lagoon Survey
A-ll: Original Lagoon Outline with Dike Overlay
A-12: Final Placement
A-13: Disposal Site Survey
A-14: Little Mountain Land Farm Disposal Site
A-15: Number of Hydrocarbon-Utilizing Organisms for Land Farm Plots
A-16: Number of Aerobic Bacteria for Land Farm Plots
A-17: Soil Respiration Rate for Land Farm Plots
A-18: Ammonium Nitrogen Content of Land Farm Plots
Table B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9:
B-10:
Summary of Bids, Bid Item #1, April 3, 1974
Summary of Bids, Bid Item #2, April 3, 1974
Summary of Bids, Bid Item #2, April 12, 1974
Suggested Application Rates
Little Mountain Farm Application Rates
Analysis of Lagoon Bottom
Analysis of Lagoon Contents
Volatile Hydrocarbon Concentrations above Disturbed Acid
Sludge during Consolidation
Chart of Daily Operations
Cost Summary
Annex C: Chronological List of Events
Annex D: Participants
Annex E: References
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I. ABSTRACT
This is the On-Scene-Coordinators (OSC) Report for the Little
Mountain Salvage Yard Oil Lagoon incident. Included are details
of the planning and coordination required for the response actions
taken; the emergency, mitigative, removal and disposal operations
involved; and recommendations to improve response to, or to prevent
occurrence of similar problems. The disposal phase of the operation
was completed in October 1975.
The Little Mountain Salvage Yard Oil Lagoon at West Warren, Utah
was used for disposal of acid sludge and clay filtercake waste from
a waste oil processing facility from 1967 to 1972. The 5-acre lagoon
contained more than 1,200,000 gallons of liquid and an estimated
7,000 to 10,000 cubic yards of acid sludge and spent filter clay. In
October 1973 the lagoon was declared an "imminent and substantial
threat" to U.S. waters by the Administrator of the Environmental Pro-
tection Agency by his authority under Section 311(e) of the Federal
Water Pollution Control Act (FWPCA); the threat being attributed to
the type of construction and the lagoon location adjacent to live
drainage flowing into the Ogden Bay Migratory Bird Refuge, the North
Fork of the Weber River, and the Great Salt Lake. Discharge of lagoon
contents through weakened dikes was observed in February and March of
1974 at a time when dike freeboard was critically low in view of the
expected annual precipitation peak and rising groundwater. In addi-
tion, the lagoon surface was trapping and killing large numbers of
local and migratory wildfowl.
A documented discharge and U.S. District Court hearings led to
activation of the Federal Pollution Revolving Fund under Section 311(c)
FWPCA on March 20, 1974. Measures taken prior to and following this
date included construction of a catch basin across the drainage to con-
tain further discharges into the refuge, sandbagging around the lagoon
to increase freeboard and strengthen weakened and eroded dike sections,
alerting equipment suppliers and manpower in the area for immediate
mobilization in event of major dike failure, diverting surface flow
away from the lagoon, and stationing a U.S. Coast Guard Pacific Strike
Team member with an ADAPTS pumping system on site for continuous moni-
toring and standby support.
The oil emulsion in the lagoon was concentrated away from the weak-
ened dike section, pumped into truck tankers, and spread on 40 acres of
nearby land. Disposal of the oil emulsion utilizing soil cultivation
for hydrocarbon biodegradation is considered successful with more than
85% degraded. The oily acid sludge uncovered as the liquid contents
were removed was dehydrated and neutralized by mixing with alkaline
clay. Construction of perimeter and internal dikes served to divide
the original lagoon area into cells and provide work platforms for the
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mixing operation. The mixed sludge and clay were contoured to provide
drainage and a clay cap applied to permanently seal the mix, prevent
major precipitation infiltration, and support vegetation. An intercept
drainage system was constructed to divert groundwater from the former
lagoon site. Monitoring of waters at both the former lagoon site and
at the nearby land farm is conducted periodically to check for unantic-
ipated pollution arising from contaminant migration.
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II. INTRODUCTION
The Western Petroleum Company and Union Pacific Railroad were
involved in operation of a facility in Ogden, Utah for reclaiming
waste journal box and crankcase oils collected from the Union Pacific
Railroad and waste oil collected from other local sources. The
residuals from this process consisted of an acid sludge containing
spent filter clay, up to 30% unrecovered process oil, and various
amounts of metal contaminants accumulated in the feed stock. The
wastes were disposed of on Union Pacific rights-of-way and Weber
County properties prior to 1967. In 1967 the wastes were discovered
to be polluting the adjacent Weber River. At that time, County and
State agencies were instrumental in assisting the company in develop-
ment of a substitute disposal site. In 1967, property was leased
from Little Mountain Salvage Yard, West Warren, Utah, approximately
10 miles west of Ogden, and cut/fill disposal of processing waste
began (Fig. A-l, 2).
For the first 9 months, the disposal was conducted by procedures
called for by the lease agreement. However, the rate and quantity of
waste production and the company's inability to successfully cover
and contain the wastes by the cut/fill method led to creation of the
waste lagoon used for the duration of the 5-year lease. The lagoon
was constructed by erecting temporary dikes across the property drain-
ages. The ponding operation was initiated without removal of the
automobile bodies and junk parts from the impoundment area. In 1972,
the disposal site lease expired, the lagoon was abandoned, and the
reprocessing facility shut down. Upon abandonment, the lagoon covered
approximately 5 surface acres, contained about 1,200,000 gallons of
liquid, and an estimated 10,000 cubic yards of acid sludge.
In 1973, the lagoon contents were sampled by EPA and analyses
obtained on samples of the three layers present. Figure A-3 gives the
values found for these phases; the oil emulsion layer, the aqueous
layer, and the bottom acid sludge. The metals present are typical of
acid sludge wastes produced by similar operations, although the lead
content is lower than that found in the Berks Associates lagoons.
This would be the result of processing waste diesel engine crankcase
and journal box lubricating oil with lesser additional amounts of gaso-
line engine crank case drainings. The thickness of the floating oil
emulsion layer and the total liquid depth was measured in several
areas of the lagoon. These values allowed an estimate of the emulsion
present in the lagoon: approximately 750,000 gallons of the 1,200,000
gallons of liquid. Since precipitation and artesian pressure markedly
affected the total liquid volume, this estimate was good at only the
given gauge height. Only gross estimates of the amount of acid/sludge
were made because survey costs would have been excessive.
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The lagoon was adjacent to an irrigation return canal that flowed
directly into the Weber River delta and the Ogden Bay Migratory Bird
Refuge less than 1/2 mile distant (Fig. A-2). The canal flow then dis-
charged from the Refuge into the Great Salt Lake, 3 miles distant.
Federal, State, and County agencies concerned about the potentially
hazardous situation held meetings with the responsible parties in 1972
and 1973 to resolve the problem. Investigations were intensified in
1973 when it was found that large numbers of waterfowl and birds, ap-
parently mistaking the lagoon for a fresh water pond, were perishing
on the liquid surface. Further, the dike construction was unsound.
Evidence of dike topping and dike erosion as well as liquid seepage
through the dikes indicated a discharge of lagoon contents into waters
of the United States had probably occurred. There were no corrective
actions taken during this period by the responsible parties.
These investigations formed the basis for the following determina-
tion made by the Administrator of the Environmental Protection Agency
on October 17, 1973:
"By virtue of the authority vested in me by Section
311(e) of the Federal Water Pollution Control Act, as
amended; 33 USC 1251 et. seq., (1972), and Subsection (3)
of Section 1, Executive Order 11735, promulgated by the
President of the United States, August 3, 1973, and as
Administrator of the Environmental Protection Agency, I
have determined as follows:
That there is an imminent and substantial threat to
the public health and welfare of the United States, in-
cluding fish, wildlife, and public and private property,
because of a threatened discharge of oil; to wit, approx-
imately 100,000 gallons of waste oil and oil sludge
threatened to be discharged into and upon the navigable
waters of the United States; to wit, the navigable body
of the Great Salt Lake, from an onshore facility; to wit,
the property located at West Warren, Utah, including
earthen diked lagoons located thereon and containing oil
and oil sludge.
By virtue of the further authority vested in me by
the above authorities and titles, I hereby require and
authorize United States Attorney for the District of
Utah to bring action in the United States District of
Utah against the three named defendants and such others
as he may deem appropriate and necessary, to secure
such relief as may be necessary to abate the above
threat, and to request such other relief as the public
interest and equities of the case may require."
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Following this determination of an imminent and substantial
threat, further negotiations were held with the responsible parties
to institute corrective action by the Spring of 1974, the time of
the semiannual waterfowl migration, the period of annual high water
due to snow melt runoff, and occurrence of the precipitation peak
in mid-April. With the approach of this critical period, prompt
action to avert additional deaths of migrating waterfowl and a
possible major discharge of lagoon contents was necessary. A meet-
ing of the EPA Region VIII Regional Response Team was convened on
February 15, 1974 to plan a course of action preparing for either
Federal cleanup or Federal monitoring of a cleanup conducted by the
responsible parties.
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III. COORDINATION AND PLANNING
The meetings and negotiations necessary to coordinate and plan
for the cleanup, mitigation, and disposal operations occurred prior
to and after the actual startup of operations at the lagoon site and
are described step-by-step in this section to illustrate and provide
insight into the functioning of the National Oil and Hazardous Sub-
stances Pollution Contingency Plan. Participants and roles of those
involved in the overall operation are listed in Annex D.
A. RRT MEETING, FEBRUARY 15
A meeting of the Environmental Protection Agency Region VIII
Regional Response Team (RRT) was held on February 15, 1974 in the
conference room of the Utah State Division of Health in Salt Lake
City, Utah. The RRT considered and developed a plan for mitigation,
removal, and disposal of the lagoon contents. The Team discussed
various courses of action in the event a Federal cleanup was required,
the necessity to provide guidance for and evaluation of proposals for
cleanup made by the responsible parties and documentation needed by
the Court in the event hearings seeking injunctive relief of the
responsible parties were held.
Primary and advisory members at the February 15 and subsequent
RRT meetings included representatives from EPA Region VIII; EPA Divi-
sion of Oil and Hazardous Materials (DOHM), Washington, D.C.; United
States Coast Guard District 12 (USCG), San Francisco; United States
Coast Guard Pacific Strike Team (PST), San Francisco; Department of
Justice (DOJ), Utah District Court; National Oceanic and Atmospheric
Administration (NOAA); National Weather Service (NWS); United States
Fish and Wildlife Service (USFWS); United States Air Force, Hill Air
Force Base (HAFB); United States Defense Supply Agency, Defense Depot,
Ogden (DDO); United States Army Corps of Engineers (COE); Utah State
Division of Health; Utah Division of Wildlife Resources; Weber County
Commission; Weber County Health Department; Weber County Road Depart-
ment. Meetings were conducted by Dr. George B. Rice, EPA Region VIII
On-Scene-Coordinator (OSC).
The local members were, for the most part, familiar with the lagoon
site and local conditions. Those members from out of town arrived in
Salt Lake City prior to the initial RRT meeting to permit on site inspec-
tion and familiarization in company with the OSC. At the time of this
inspection the lagoon site was partially snow covered. Pools accumulat-
ing below the dike were estimated to contain several hundred gallons of
oil. Snowmelt, due to warm afternoon temperatures, had caused oil drop-
lets and a sheen to be transported west onto the drainage on property
adjacent to the Little Mountain Salvage Yard and into the irrigation
return canal flowing south towards the Weber River. Oil beyond the point
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of canal entry could not be directly observed and traced at the time
due to ice and drifted snow covering the canal, the Ogden Bay Migratory
Bird Refuge, and the Weber River Delta. The water, snow, and ice
covering the land surrounding the lagoon made use of heavy equipment
impossible. The maximum freeboard of the lagoon dike was estimated to
be less than 5 inches. These conditions, observed on February 14, dic-
tated that immediate protective, containment, and mitigative actions
be the first item on the agenda for the RRT meeting.
The emergency actions implemented after recommendation by the RRT
members are described in Part IV. A $10,000 allocation for initial
investigations and emergency operations was provided by EPA, DOHM, and
Headquarters to Region VIII. U.S. Coast Guard operational funds covered
expenses of 12th District and PST personnel and operations.
The second agenda item was consideration of various removal/disposal
alternatives for cleanup of the lagoon site. Consideration was given to
all tendered alternatives: salvage, burning, and various land disposal
methods. Various possibilities had been studied by EPA prior to the RRT
meeting, and we were determined to continue to explore all potential
methods until commitment was necessary.
The problem of disposal was difficult in this instance for the
following reasons:
(1) Timeliness was important from the standpoint of having the
lagoon site under control by the Spring of 1974, particularly in view
of the site conditions observed on February 14, 1974, the predicted
additional precipitation, and the Spring wildfowl migration.
(2) The high metals content, especially lead, and the high sulfur
content would necessitate stringent, and therefore expensive, air pollu-
tion control devices with any incineration method used.
(3) The presence of heavy metals limited introduction or blending
of lagoon liquids into refinery feed stocks.
(4) The emulsion formed between the filter clay, carbon, acid,
water, oil residues, and additives was very stable. Since many of the
possible salvage methods required the emulsion to be broken, this
stability proved a major limiting factor in reclamation.
(5) Keeping costs down was essential. For example, it was necessary
that the removal/disposal method selected have short haul distances and
that turnaround times be as brief as possible.
(6) The strong acid, the probable carcinogen content, the sulfur di-
oxide concentrations, and the volatile, low molecular weight hydrocarbons
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made safety a primary consideration in the disposal method to be employed.
The most desirable method of disposal, particularly during a time
of energy shortage was, of course, salvage. Inquiry to local companies
as to their possible use of the lagoon liquids as blends for roofing,
coking, or asphalt had yielded negative response. Blending with crude
feed stocks at local refineries or blending with residuals for burning
as a power source were to be further studied. Samples were to be supplied
to all identified potential users up to the time of final method selection.
A variety of incineration methods were considered:
(1) Open pit incineration using wicking materials and/or igniter
fuel as heat source was discussed. The method could be controlled by
feeding lagoon contents into an auxilliary burning pit. However, the
tight emulsion, the high water content, the fact that there would remain
a significant quantity of solid residue, and the toxic sulfur and lead
oxides generated, eliminated this possibility from EPA consideration.
The State of Utah and the responsible parties were insistent on conducting
a burn experiment and did perform a trial burn before abandoning this
concept.
(2) On site disposal in a specially designed incinerator had been
proposed for eliminating the lagoon requirements of Berks Associates,
and these cost figures and engineering studies were available to the RRT
members. In addition to the expense involved, the long procurement time
and slow throughput eliminated this alternative on basis of timeliness.
(3) The Ogden municipal incinerator was considered for off site
burning but was eliminated after considering the slow throughput due to
the necessity of thoroughly mixing the lagoon contents with the solid
waste incinerator feed stock. Further, the corrosive and toxic nature
of the material and combustion products formed would result in equipment
damage and introduction of pollutants to the atmosphere.
Four types of land disposal methods were proposed:
(1) The oil could be directly applied to or mixed with sand and
gravel for application on roads for dust control. However, the problem
of heavy metal and oil migration during periods of precipitation had to
be considered. The Utah State Highway Department was studying the
feasibility of this method of disposal in their Highway Materials Labor-
atory.
(2) Landfill disposal of material would be promising if a suitable
fill site could be found reasonably close to the lagoon and situated so
that leaching would not endanger nearby surface or groundwater. Utah
State Division of Health was to follow up on this method and determine
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availability of a suitable fill site.
(3) Well-injection of the material was briefly considered.
However, disregarding this concept appeared academic for several
reasons: the nonavailability of abandoned wells in the immediate
area, the reluctance of the State Division of Health to set a prece-
dent of endangering any aquifer, and the pumping capacity needed to
overcome the high emulsion viscosity.
(4) Land farming of the oil by spreading and mixing on suitable
soil, chosen to minimize surface and groundwater pollution appeared
feasible. The oil would be disced or harrowed into the soil and
nutrients added to promote growth of soil microorganisms to hasten
the biodegradation of the deposited oil. Utah State, the Federal
Government, and Union Pacific Railroad each had plots near the oil
lagoon and each plot was subsequently investigated for suitability
for use as a land farm disposal site.
The magnitude of the bottom acid/sludge disposal problem could
not be estimated at this time. A core survey of the sludge layer
thickness had not been made because of excessive costs. RRT members
agreed that this problem would be set aside for study until the
liquid contents of the lagoon had been removed and disposed of. The
bottom acid/sludge layer would then be exposed, permitting problem
definition and evaluation.
Removal of the liquid contents was dependent on the disposal
method chosen. However, it was apparent that pumps, booster pumps,
hose, pipeline, and skimmers would be utilized in most of the methods
being considered. The PST had pumping expertise, pumping equipment
available from Coast Guard supplies and ready access to other sources
of pumping equipment. They would assist and advise the OSC in pumping
equipment specification and selection.
Action recommendations by the RRT members are summarized:
(1) The preventive, protective, and mitigating measures should
be implemented immediately to protect the refuge from further lagoon
discharge from flooding, vandalism, or massive structural failure.
(2) The disposal alternatives should be investigated via literature
search and industry contacts, and samples of material should be provided
to refineries, rerefineries, Highway Departments and other interested
parties as identified.
(3) Pumping requirements and specifications were to be investigated
by PST experts.
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(4) The sludge problem should be set aside until the sludge
layer was exposed.
(5) Documentation of discharge from the lagoon into U.S. waters
should be continued.
Investigation and surveillance during the period following the RRT
meeting indicated that the situation was becoming increasingly critical
With two additional storms forecast for the area, the OSC sent a pollu-
tion report (POLREP) on February 24 to members of the RRT and National
Response Team (NRT), describing the situation and recommending that
immediate emergency actions be taken to prevent a major discharge from
the lagoon. This POLREP read as follows:
"1. Situation
a. Subject lagoon on the Little Mountain Salvage Yard
owned by Troy Nipper at 8500 W. 900 S. West Warren, Utah is
located at 112 DEG 12' 23", 41 DEG 14' 33". The lagoon,
formed by an earth dike across a shallow drainage contains
approximately 1.2 million gallons of waste oil, sludges, and
waste oil emulsion deposited at the site by Western Company
from 1967 to expiration of lease in November 1972. Since
that date the lagoon has not been used for oil wastes, nor
has the temporary earth dike been properly maintained.
b. Drainage from the lagoon flows directly into the
Ogden Bay Migratory Bird Refuge located in the Weber River
Delta and flowing thence into the Great Salt Lake.
c. The Administrator of EPA has declared the lagoon in
question an imminent and substantial threat to the public
health and welfare of the United States under Section 311(e)
of the FWPCA. Injunctive relief is being sought in Court
having jurisdiction the week of February 24, 1974.
d. Utah Wildlife Resources state that the northward
migration of wildfowl has started and that the migratory
bird population will reach its peak of up to 1/2 million
birds along the front in the Ogden Bay area in March. Snow
geese are due in one week.
e. NOAA member to RRT reports a record high water table
forecast this Spring for the area. The Great Salt Lake level
will be highest in 42 years.
f. During heavy snow and rainfall this week, the level
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in lagoon was raised approximately two inches. The level is
presently only four inches from the top of the dike. Estimate
that one inch of precipitation would be critical. March -
April are high precipitation periods for this area and
probability for weekly precipitation of this magnitude is
5% increasing to 12 - 17% by mid April.
g. It has been established that oil is being discharged
from the lagoon into U.S. waters in violation of the FWPCA.
2. Action
a. Dr. George Rice, Emergency Response and Planning
Branch, EPA Region VIII has been designated On-Scene-
Coordinator for this incident.
b. RRT meeting held February 15, 1974, in Salt Lake
City to discuss situation with Federal, State, and County
of f ic ials.
c. Present discharge is being contained at a site on the
Ogden Bay Migratory Bird Refuge established as a holding and
collecting point should an overflow occur.
d. Discharge is being documented and further evidence
obtained.
e. Negotiating with adjacent property owner for permission
for construction of emergency containment to protect refuge
in event of total dike failure.
f. EPA aircraft from NERC, Las Vegas has conducted over-
flight of the area.
g. Corps of Engineers made evaluation of earth dike at
lagoon, awaiting report. Bureau of Reclamation report temporary
nature of dike and consider it a potential hazard due to lack
of freeboard and apparent piping or erosion on the dike.
h. Have established contact with local companies, con-
tractors and officials for materials, equipment and manpower
standby.
i. NWS is providing forecasting and alerting assistance
for the lagoon area.
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j. Investigating various disposal methods should
Federal removal of oil from pond be required.
3. Plans
a. Monitor situation closely. Continue protective/
preventive measures.
b. In event Federal removal becomes necessary, request
Coast Guard Strike Force provide ADAPTS pumping system with
operating personnel through Commander Pacific Area Coast
Guard.
4. Recommendations
Injunctive relief is to be sought in court having juris-
diction. Pleadings initially were to have been entered
February 19, 1974; then on February 22 or 25, 1974; and at
present toward end of the week of March 4, 1974, according
to information provided OSC. Decision to await court action
increased criticality of situation.
a. As discharge has been established, proceed with
removal action under Section 311(c), FWPCA, and the National
Contingency Plan including notification of owner. In view
of high water table, migratory bird situation, high level of
oil in lagoon, normal seasonal precipitation and runoff, and
instability of temporary earth dike, situation deemed
critical.
b. Take immediate action on the lagoon site to increase
freeboard using sand bags and sheeting at low points in the
dike.
c. Take immediate action on the lagoon site to divert
all drainage from the lagoon due to rain and snow melt
runoff by construction of diversion ditch."
Following this report, permission to proceed with protective action
at the lagoon site was obtained from the U.S. Attorney, Salt Lake City,
Utah, and DOHM allocated funds to cover all emergency and protective
action items. The request for the ADAPTS pump system and operator from
the PST resulted in immediate delivery and pump staging at the oil
lagoon site for emergency use. The PST member provided site surveillance
and assisted the OSC in directing emergency contractor actions described
in Part IV.
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B. COURT HEARING, MARCH 12
Hearings were held March 12, 1974 in the U.S. District Court of
the Northern District of the State of Utah. The OSC was the only
witness called. He testified that a discharge from the lagoon in the
U.S. waters had been documented, that further investigations were
being undertaken to obtain samples for fingerprinting the discharge
by gas chromatographic methods, and that emergency protective actions
had been initiated. The plaintiff and the defendants agreed that they
would cooperate in cleanup and entered into the following stipulations:
"The parties by and through their attorneys hereby
stipulate subject to Court approval as follows:
1. Plaintiff pursuant to Section 311(c) of the Federal
Water Pollution Control Act 33 USC 1321(c), shall, as soon
as possible take the actions necessary to remove and dispose
of any oil and oil sludge which has discharged from the oil
sludge lagoon near West Warren, /Jtah into the navigable
waters of the U.S. and adjoining chorelines, and will remove
all the material from the oil sludge lagoon necessary to
minimize and mitigate damage to the public health or welfare.
2. Defendants acknowledge that, for purposes of 311 of
the FWPCA, a discharge of oil from the above mentioned oil
lagoon into the navigable waters of the U.S. and adjoining
shorelines has occurred and that they have taken no steps to
remove the oil from the water or from the lagoon. Defendants
agree that, in any actions against them by plaintiff to
recover removal and disposal costs, they will not raise the
defense and/or the issue of whether there was a discharge
into the navigable waters of the U.S., pursuant to Section
311, and that the United States should remove all the material
from the lagoon necessary to minimize and mitigate damage to
public health or welfare.
3. Defendants will not, in any action by plaintiff to
recover removal or disposal costs with relation to the above
lagoon, raise the defense that the discharge was caused solely
by a) Act of God, b) Act of War, or c) negligence on the part
of the U.S. Government.
4. Defendant, Union Pacific Railroad Company, agrees to
make a reasonable effort to provide to plaintiff a sufficient
parcel of land at no cost on which the material in the lagoon
may be disposed of properly and which is acceptable to the
Administrator of Region VIII of the EPA.
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5. Each of the parties hereto shall endeavor to
cooperate to secure the effectuation of paragraph 1 above
at the lowest possible cost.
6. Nothing in this stipulation shall in any way act
as an admission of liability on the part of any of the
defendants.
7. The initial action shall be stayed until the
plaintiff's removal actions have been completed and the
Court notified of such completion."
Under these stipulations, the OSC consulted, informed, and met
with the defendant attorneys throughout the removal/disposal operations.
Specific advice and assistance was requested of the defendants on
several occasions by the OSC:
(1) Mr. Troy Nipper and his attorney cooperated in arranging
removal of all junk cars and dabris from the Little Mountain Salvage
Yard site during the course of [tie cleanup and further indicated their
cooperation in agreeing to a period of observation and monitoring of
the former lagoon site before considering its future use. Weber County
suspended the permit for use of the site as a junk yard during the
course of the cleanup.
(2) Mr. Bill Borin, Western Petroleum Company's Utah representa-
tive, assisted the OSC on several visits to the site in discussion of
lagoon history, of describing cut/fill trench locations and operational
experience in the early cut/fill disposal attempts, and in general,
sharing his acid/sludge disposal experience with the EPA staff.
(3) Union Pacific Railroad attorneys were contacted on several
occasions for advice and assistance:
(a) The company, through UPland Industries, offered nearby
land for Federal use in disposal of the lagoon contents by soil culti-
vation. Representatives of UPland accompanied the land farm planning
group to the land. Unfortunately, it was found to be not suitable for
this use.
(b) The UP attorney advised the OSC of earlier County commit-
ments to assist the defendants, later finalized by the OSC, in furnishing
fill, building an access road, vehicle turnaround, pumping platform,
final site restoration, and in obtaining joint County and State assist-
ance in construction of the perimeter dike for sludge containment.
(c) The urea (45% N) required as nitrogen source for the
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disposal was shipped by a Colorado supplier in a UP car. To avoid
excessive demurrage, UP was asked if they could arrange to defray
these costs. Federal regulations prevented this, and fortunately
arrangements were worked out quickly by the staff to unload, package,
and store the urea without generating excessive demurrage.
(d) Request to UP for test of a double diaphragm pump from
the North Salt Lake UP yards and its possible use during removal opera-
tions was made during the period of study of pumping requirements.
The company agreed to this request, but the EPA engineers had already
determined that a low volume, low head pump would not meet the opera-
tional requirements before details of transferring the UP pump to the
lagoon were arranged.
C. FIELD INVESTIGATIONS
Field investigations, continuous since February 14, 1975 were
still in progress coincident with the court hearings. The discharge
of oil droplets and sheen into drainage adjacent to the lagoon had
been observed during periods of melting snow and rainfall. Samples
for fingerprinting by gas chromatography had not yet been obtained.
Due to alternate freezing and thawing of the canal and periodic snow
cover, the investigators were not present to collect the needed docu-
mentary samples downstream at the appropriate flow period. Further,
the water flow in the canal had increased with the rise in the ground-
water table so that the two 18-inch culverts initially installed for
oil containment at the catch basin on the Refuge (Fig. A-2) were now
undersized and being bypassed. Any discharged oil was therefore
entering the Refuge. Remedying the situation had to await drying of
the gumbo soil so that vehicles, equipment and men could be brought
into the containment area.
Two overflights for photographic documentation of the discharge
were made by aircraft from the EPA National Environmental Research
Center (NERC), Las Vegas, Nevada. An attempt was made to time these
flights to periods of melting snow and visible oil flow. The flight
on March 11 showed oil accumulations in the canal at the Refuge bound-
ary; the flight on February 18 had shown oil flowing in the drainage
located on property adjacent to the lagoon and leading to the ice and
snow covered canal. Field teams from the EPA National Field Investi-
gation Center (NEIC), Denver, Colorado, were able to collect documentary
samples on March 19 and 20. Laboratory analysis by gas chromatograph
fingerprinting established that oil in the pools below the dike and
flowing into the canal south of the lagoon was identical to the oil
within the lagoon. Thus the discharge under Section 311(c) of the
FWPCA was established.
Notification letters were sent to the responsible parties informing
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them that a discharge had been documented and of their responsibility
under the law to take prompt action to clean up such discharge. Each
responded that Federal cleanup had been stipulated as a result of the
March 19 hearings and that no cleanup action would be taken by them.
The Federal Pollution Revolving Fund was activated on March 20 and
subsequent containment, mitigation, and removal/disposal operations
were performed under direct supervision of the OSC.
D. RRT MEETING, MARCH 22
A second meeting of the RRT was held March 22 in Utah State Health
offices in Salt Lake City. The Team was informed of actions taken to
date and assisted in development of an operational plan for the Little
Mountain Salvage Yard Oil Lagoon cleanup.
Additional physical data on the lagoon and contents were reported:
The oil lagoon had been surveyed by the Great Basin Surveying and
Engineering Company to accurately establish the lagoon topography and
volume of the liquid contents (Fig. A-4, 7). Liquid core samples were
taken by EPA using clear plexiglass tubing passed vertically through
the lagoon liquids and pushed forcibly into the bottom sludge. The
tubing did not penetrate the sludge sufficiently to obtain sludge core
samples. However, the thickness of the emulsion and aqueous layers
could be measured and the presence or absence of bottom sludge deter-
mined. During the course of this sampling it became apparent that the
lagoon contents were much more acidic than the laboratory results of
1973 had indicated. Additional samples were being analyzed at this time
by a State approved private laboratory, Ford Laboratories, Salt Lake
City.
The three primary methods of disposal (salvage, burning, land
disposal) were thoroughly discussed and relevant findings presented so
that choice of disposal method could be made.
(1) Companies which had been supplied oil samples for investigation
of possible salvage reported their inability to use the material because
of the emulsion stability.
(2) Methods of incineration had been investigated but were dis-
carded by the OSC and EPA engineers as impractical due to high costs,
lack of timeliness, and resultant air pollution. (It should be noted
that the Utah Air Pollution Board had met and approved open burning as
a disposal method, depending on the outcome of burning experiments. The
position that had been taken by EPA was that burning proposals submitted
by the defendants on January 18 were unsatisfactory due, in part, to the
pollution hazard.) An open burning test was conducted at the site on
March 16 by the Air Quality Division of the Utah State Division of
Health and the defendant attorneys with an EPA observer present. This
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test failed in spite of the addition of fuel in the form of diesel,
junk car seats, tires and scrap lumber, because the aqueous layer
beneath the emulsion, and the water content of the emulsion itself,
served as a heat sink; the fire was thus self-extinguishing.
(3) Disposal in existing landfills was discarded because there
were no State, County or Municipal landfills suitable for containment
and disposal of these materials. The Bureau of Land Management,
Department of Interior, proposed a quarry site at Lakeside, Utah,
on the west shore of the Great Salt Lake as a possible hazardous
materials disposal site. The location on the west end of the Southern
Pacific Railroad causeway made consideration of this site reasonable
but the haul distance and the studies required to prove site adequacy
as a hazardous material landfill would be costly and untimely. This
possibility was therefore discarded.
(4) Spraying of liquid contents of the lagoon for dust control
on road surfaces was discarded because of probable migration of heavy
metals and oil away from the point of application. Also, the oil
failed to harden in tests conducted by the State Highway Materials
Laboratory.
(5) Land farming appeared to be the only practical solution and
action initiating this method of disposal had already been taken.
Dr. J. J. Skujins, soil microbiologist at the Ecology Center, Utah
State University, Logan, Utah, had been recommended by the Utah State
Division of Health as qualified to assist in the disposal operation.
He was retained to assist in land farm disposal site selection, design,
application methodology, and maintaining favorable degradation rates
by tilling and nutrient reapplication.
In order to minimize cost and maximize efficiency, a short haul
distance from the lagoon to the land farm site was mandatory. Potential
land farm sites had already been investigated in a preliminary survey
(see Part H of this section). The sites belonging to Utah State Parks
and Recreation and to the Union Pacific Railroad did not appear suitable
because of their high water table. A third site under the control of
Hill Air Force Base, Ogden, Utah, appeared suitable and preliminary
approval for its use had been obtained.
On the basis of discussion by the members, the RRT recommended
that disposal of the liquid contents of the lagoon be by land farming
and that final site selection be vigorously pursued.
Further action recommendation and commitments made at this meeting
of the RRT included:
(1) EPA staff would pursue the rental of a former laboratory
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building adjacent to the lagoon site, owned by the Great Salt Lake
Minerals and Chemical Corporation, Little Mountain, Utah, for use
as EPA field headquarters during the pending operations.
(2) DDO would provide message service through their communications
center and contractural support through their procurement section. They
would also furnish small amounts of needed equipment and supplies (pri-
marily safety) that could be spared without jeopardizing their primary
mission.
(3) NWS would continue to supply twice daily forecasts direct
to the OSC.
(4) The Weber County Commission and Road Department would upgrade
the access road into the lagoon site and construct a pump stand and
truck turnaround if scheduling could be worked out.
(5) Investigation of possible methods of treatment of the bottom
sludge would continue, but any decision regarding disposal was set
aside until removal of lagoon liquids was completed.
(6) Emergency actions would be continued under Phase III of the
National Contingency Plan until the oil emulsion was circulated away
from the weakened dike area. The emergency contractor would be retained
until Phase III actions were completed.
(7) The EPA and Department of Justice attorneys and Coast Guard
members of the RRT stipulated that there be complete photo documentation
of all operations.
E. COUNTY COMMISSION, MARCH 22
It had been necessary for the emergency contractor to partially re-
inforce the lagoon access road, the fill being furnished by Weber County
and Murdock Engineering, owner of property on which the quarry and pond
below the land farm site was located. Weber County had previously
offered to assist the defendants should they conduct cleanup operations.
To help minimize costs in the Federal cleanup efforts, assistance of the
defendant attorneys was obtained in arriving at a satisfactory agreement
with the County for the work to be performed. Meetings with the Weber
County Commission and County Attorney initiated March 22 and concluded
March 27 resulted in an agreement for the construction by the Weber
County Road Department of a solid based access road, pump stand and
truck turnaround at the lagoon site with the work to be initiated as
soon as site conditions permitted. The OSC felt obligated to spend
time reaching this agreement, particularly in light of the County's
earlier offer to the defendants.
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F. OPERATIONAL PLAN
A tentative operational plan for lagoon cleanup and contents
disposal, based on RRT recommendations and successful negotiation
with Federal, State, and County agencies, was formalized March 29
and copies were later made available to the defendant attorneys.
The plan permitted preliminary cost and time estimating for various
phases of the intended operation. The plan also specified alterna-
tive steps and modifications which could be made as salient points
surfaced as operations progressed. An early version of the operations
plan is included in this report to provide insight to the preplanning
and problem solving faced, and the functioning of the National Con-
tingency Plan in assisting in solution of these problems. Discussion
of alternative selections, of modifications to the plan, and to the
time schedule followed, are in other sections of the report.
TENTATIVE OPERATIONAL STEPS AND ALTERNATIVES
Little Mountain Salvage Yard Lagoon Cleanup
After sufficient site preparation at the land farm/disposal site,
liquid oil emulsion is to be skimmed from the lagoon surface in the
first step of the removal operation. The aqueous phase of lagoon liquid,
containing mostly contaminated water, is to be removed during the second
stage of removal operation. (This aqueous solution may or may not be
disposed of on the land farm plots dependent on the outcome of further
tests and evaluation.) The third step consists of flushing any free oil
and sludge adhering to the junk and debris and to the exposed lagoon
bottom with high pressure streams of water. The last step will be ex-
tracting part or all of the accumulated sludge along the lagoon bottom.
The tasks are broken into the following operational steps:
1. Site preparation at farming site (38 acres).
Thirteen plots ranging in size of 1 to 11 acres will be located
and identified on the south end of Little Mountain on the eastern edge
of property owned by Hill Air Force Base. Temporary access roads as
designated by the Operations Engineer, will be constructed, and main-
tained as needed thereafter, for equipment and laden trucks moving to
and from the plots and, possibly, a temporary road for access to and
from the lower end of the site. The entire land farm site will be fenced
and posted to prevent entry by unauthorized personnel.
Soil in the marked plots will be scarified to a depth ranging
from 6 to 12 inches. Neutralizer and nutrients will be applied to the
plots at a rate specified by the Operations Engineer. Some plots will
be cultivated before application of any lagoon contents to thoroughly
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mix soil, neutralizer, and nutrients.
This work will commence immediately and by scheduling, will
progress at a pace sufficient to stay well ahead of the acreage needs
for disposal of liquids removed from the lagoon.
2. Site preparation at the lagoon site.
Approximately 1200 feet of temporary road and possibly one or
two additional pump stands will be built around the east and south sides
of the lagoon to provide access for contractor equipment. This involves
importation of fill and gravel from nearby barrow pits. The old dike,
partially visible near the southwestern edge of the lagoon, may be
reestablished with sandbags for temporary liquid retention and diversion.
By using a clamshell, loader, and/or open ended dump trucks,
all junk and debris will be cleared from the work area and piled at a
point to be determined by the OSC.
This work is to commence immediately and proceed as rapidly as
possible to completion. Road patrol will be used for maintenance as
needed. Removal of junk which is mired in the lagoon will be initiated
only after the liquid volume has been reduced to a safe level or the
remaining liquid can be isolated well away from the work area.
3. Oil emulsion removal to the farming site.
From an existing pump stand on the lagoon edge, leakproof tank
trucks, suitable for hauling the lagoon liquids without spillage, will
fill to capacity with oil emulsion skimmed from the lagoon surface and
gauged for volume. The trucks will transport the contents approximately
2 miles west to a predesignated spot on the farming site located on the
south slope of Little Mountain. On a plot designated by the Operations
Engineer, the truck will be emptied in such a manner that a uniform
layer of liquid at a thickness of from % to 1 inch, in a one-time-only
pass, is placed. The truck will then proceed back to the lagoon site
for another load.
4. Aqueous phase removal to the farm site.
After the oil emulsion layer has been skimmed from the surface
of the lagoon, all remaining liquids will be drained to the lowest point
and pumped into leakproof tanks for transport to the farming site on the
south end of Little Mountain. At the farming site, the tank contents
will be spread or sprayed on prepared soil at a saturation rate: as
much as the soil will hold without producing runoff from the immediate
dumping area. Limited farming acreage is needed for this operation
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since repeated passes can be made over any one plot of ground after
soil moisture evaporation or transpiration, and neutralizer and nutrient
retreating.
4A. Water removal - optional release.
After the oil emulsion layer has been removed from the lagoon
surface, it may become feasible to treat the remaining lagoon liquids
so that the water quality would be improved enough to allow direct dis-
charge into a nearby irrigation return/runoff ditch which leads directly
into the Ogden Bay arm of the Great Salt Lake.
If this is found possible, the remaining lagoon liquids will
be treat.ed in place as necessary to meet State discharge requirements,
drained to the lowest point and pumped from there to the irrigation
return/runoff ditch for discharge.
4B. Water removal - optional lagoon site irrigation.
After the oil emulsion layer has been skimmed from the lagoon
surface, it may become feasible to dispose of the remaining lagoon
liquids by spray irrigation of cleared and prepared plots of land on
the Little Mountain Salvage Yard.
5. Final oil cleanup.
After all lagoon liquids have been removed, high pressure
streams of water will be used to flush, as much as possible, all remaining
oil and sludge from the exposed lagoon bottom into a common collection
point. As junk and debris are extracted from the confines of the lagoon,
it will also be flushed with high pressure streams of water. All liquids
resulting from the flushing operation will be pumped into leakproof tanks
and transported to the farming site on the south end of Little Mountain.
There, at a spot designated by the Operations Engineer, the liquid will
be spread in a uniform layer, at a designated thickness, in a once-only
pass on the surface of prepared soil.
6. Drainage of the lagoon site area.
The subsurface water table at the lagoon site is such that it
appears unlikely that the lagoon could ever be pumped dry because of
continual inflow. In anticipation of this, a temporary drainage ditch
will be dug along the east and north sides of the lagoon. This ditch,
approximately 4 feet deep will intercept and divert any additional sub-
surface flow around the lagoon area and allow for a general drop in the
water table influencing the lagoon liquid level.
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(After discussions held at the RRT meetings and individually
with State and County members, it has been decided that we will have to
set aside planning for actual sludge treatment methods until the material
itself could be further investigated and the extent and magnitude of the
problem was exposed, after liquid contents removal. At that time, the
final disposition would be decided upon. At this time, it appears
probable that we have the following viable alternatives: salvage,
incineration, solid fill. Alternative disposal methods will be continu-
ally investigated.)
7. Disposition of the oily sludge at the lagoon site by a cut and
fill operation which in reality would require reinforcement of the dike
and covering of the remaining lagoon contents.
8A. Removal of all or part of the oily acid sludge to the farm
site and land farmed.
8B. Removal of all or part of the oily acid sludge to the farm
site and treated and entombed in a cut and fill operation. This step
would have the advantage of the removal of the sludge from an area of
high water table, but would have the disadvantage of permanently
damaging the cut and fill area.
9. Lagoon site finish.
All junk and debris will be piled in a central location for
easy access during a permanent removal operation. The lagoon area will
be graded so that water will not be ponded on site in the future. The
existing dikes will be 'removed and drainage away from the lagoon area
established.
All portions of the Little Mountain Salvage Yard which have
been contaminated with lagoon contents or crankcase drainings from the
junk cars will be cultivated, treating where necessary as an aid in
contaminant decomposition. The disturbed portions of the salvage yard
will then be returned to as near as possible original contours and
planted with ground cover to provide soil stabilization.
10. Farm site finish.
After lagoon contents have been placed and allowed to weather
for a specified amount of time, the soil, neutralizers, nutrients, and
lagoon liquids will be thoroughly mixed with cultivating equipment.
Duration of weathering, cultivating equipment used, and depth of culti-
vation will be determined by a soil microbiologist acting as a consultant
for the project.
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After cultivation is finished, ribbons of straw bales, laid
and fastened end to end, will be placed across the drainage below the
farm plots to intercept any seepage which may occur during precipitation
runoff. If a cut and fill operation for sludge removal is conducted,
excess earth will be spread and contoured to prevent ponding or erosion.
Where possible, suitable ground cover will be planted to provide soil
stabilizat ion.
At periodic intervals thereafter, microbiological samples will
be taken to determine the extent of decomposition and any reapplication
of nutrients or cultivation. At a suitable time, ground cover on the
farm plots will be planted and fencing removed to allow for complete
site restoration.
G. ORGANIZATIONAL PLAN
Following the District Court Hearings of March 12 and development
of the tentative operational plan in conjunction with the RRT meeting
of March 22, an organizational chart was developed (Fig. A-5). The
staffing plan was designed to be flexible as personnel were to be
interchanged in and out of the Washington and Denver offices of EPA
and the Pacific Strike Team. It was also sufficiently flexible to
handle the several phases and alternatives of the operational plan.
A secretary was hired as a temporary EPA employee through the State
Employment Office in Ogden, Utah. The staff was periodically supple-
mented by personnel having expertise in analytical chemistry, solid
waste disposal, hazardous materials, pumping equipment, treatment of
acid/sludge, photographic documentation, safety, and assisted through
consultations with companies and individual consultants. See Annex D
for a listing of individuals, agencies, and companies involved in the
overall cleanup and their roles.
H. DISPOSAL SITE, APRIL 1
Final disposal site selection was made by the OSC in consultation
with EPA engineers, Utah State, and Weber County Health Department
representatives, and Dr. J. J. Skujins. The three sites available for
consideration and near the lagoon were inspected on March 19 to March 23.
(1) The land that could be made available by the Union Pacific
Railroad was 5 miles northeast of the lagoon. The area was flat, the
soil alkaline, and the use nonagricultural with leases for limited cattle
grazing and duck hunting. The elevation was less that 10 feet above the
current level of the Great Salt Lake, a level that had not yet peaked
in the present cycle which was already at a 42-year record high. (Rydrol-
ogists and climatologists were predicting a further rise in the lake
level over the course of the next 3 to 5 years before peaking.) It was
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concluded that this site was not satisfactory for land farm disposal,
and was, in fact, no better than the Little Mountain Salvage Yard
Site.
(2) Land available from the Utah State Parks and Recreation
Department was located 2% miles west of the lagoon. The area was
flat and saline, adjoining the Ogden Bay arm of the Great Salt Lake
and with an elevation less that that of the Union Pacific site. This
site was also unsuitable.
(3) The site controlled by Hill Air Force Base at the south end
of Little Mountain was 1% miles west of the oil lagoon (Fig. A-6).
There were areas of satisfactory soil depth and gentle to 5 percent
slopes that appeared suitable. Drainage from the area was directed
toward a quarry where runoff could be controlled and monitored. Soil
properties had been grossly characterized in surveys published by the
Department of Agriculture Soil Conservation Service. The soil was
nonagricultural and soil texture appeared excellent from the standpoint
of adequate aeration and structure. The elevation ranged 30 to 120
feet above the present levels of the Great Salt Lake.
Meetings with Hill Air Force Base Facilities Section of the Engineer-
ing Division had already been held. On March 22 the OSC submitted a
formal request for a permit to use the designated area for the proposed
land farm/disposal of the lagoon liquids. The permit was approved at
the monthly meeting of the HAFB Facilities Board on March 29 and the
agreement entered into by the OSC for the Regional Administrator of
EPA Region VIII. The permit specified that the area used be kept in
good repair and that the operation plan to be implemented include the
following steps:
(1) Preparation of the site using lime to neutralize acidic oil
wastes and fertilizer to supply nutrient to the soil microorganisms to
facilitate the biodegradation of the oil.
(2) Discing or tilling of the site to enhance receipt of oil and
to incorporate the lime and nutrients.
(3) The plowing of contoured furrows for creation of berms to
prevent erosion of the site and to control drainage to and from the site.
(4) Redressing and reseeding with grasses, if appropriate, upon
completion of the 2-year lease and/or adequate biodegradation of the oil.
(5) Monitoring of the site at frequent intervals.
(6) Preparation by the permittee of any environmental assessment
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candidate studies or impact statements that might be required for
the proposed operation.
The environmental assessment required by the Air Force Logistical
Command Environmental Section, Wright-Patterson AFB, was met by a
negative declaration which read:
"The oil sludge lagoon at West Warren, Utah was designated
an imminent and substantial threat by the EPA Administrator
under 311(e) of the Federal Water Pollution Control Act amend-
ments of 1972, Public Law 92-500, in October, 1973. As a result
of this designation, the case was heard in the United States
District Court and during hearings in March, 1974, an oil dis-
charge into United States waters in violation of 311(c) of the
Act was observed and confirmed. Subsequent actions taken by
the Federal Government under FWPCA and the National Oil and
Hazardous Substances Pollution Contingency Plan, Part 1510,
Chapter 1, Title 40, are actions of the Administrator. The
objectives of these actions are removing, minimizing, and
mitigating harmful effects to the environment from this source.
The disposal involves action taken on Federal land and would
not require an Environmental Impact Statement as provided by
Section 511(c)(1) of FWPCA:
...no action of the Administrator taken pursuant to
this Act shall be deemed a major Federal action
significantly affecting the quality of the human
environment within the meaning of the National
Environmental Policy Act of 1969 (83 Stat. 852)..."
Assurance that the land would be in suitable condition for return
to Hill Air Force Base within the required 2-year period demanded con-
siderable expertise due to the semiarid nature of this land farm site.
To provide this assurance and help meet the monitoring requirements
of the agreement with Hill Air Force Base, Dr. J. J. Skujins, Utah
State University, Logan, Utah, was retained as consultant and a contract
let to the Ecology Center, USU, to provide Dr. Skujins with needed
laboratory support.
I. FIELD OFFICE OPENING, APRIL 2
Headquarters had initially been established in a Salt Lake City
motel so that the OSC and staff would be readily available to the legal
proceedings in progress. Following the hearings on March 12, a motel
in Ogden, Utah was utilized as temporary headquarters until arrangements
for the on site office had been completed. Field headquarters was
established in an office building leased from the Great Salt Lake
Minerals and Chemicals Corporation (Fig. A-2). Office furniture was
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supplied by the Internal Revenue Service, Ogden, Utah, phones were
installed, and the office occupied on April 2.
Coincident with opening of the field office, a press conference
was held at the site by Mr. Don Dubois, Assistant Regional Administrator
for the Environmental Protection Agency, Region VIII. Media relations
to this time had been very satisfactory. The field office opening,
approval for use of the land farm site, and work in progress by the
Weber County Road Department provided opportunity for scheduling the
conference. The site was toured and the operations discussed.
The on site conference happened to be during an inclement period,
thus reporters obtained direct knowledge of the problems faced in early
stages of the cleanup. They were also able to get a feel for the excel-
lent cooperation between County, State, and Federal agencies, and to see
and appreciate the imminent and substantial threat posed by the waste
oil lagoon. Public relations were not a problem throughout the course
of the cleanup and the operation was covered in some detail by the
media. A reporter's firsthand knowledge of site conditions was found
to have a direct bearing on accurate media commentary. Therefore,
after startup of operations, headquarters staff strongly encouraged
a representative's on site visit before in-depth reporting.
J. BID PACKAGE & CONTRACTOR SELECTION, APRIL 5, APRIL 12
After the March 22 RRT meeting, only two major obstacles remained
to delay startup of the full scale removal/disposal operation:
(1) formal permission from Hill Air Force Base to use the south end
of their Little Mountain Facility as a disposal site, and (2) sufficient
drying of the roadway to and around the lagoon to permit the use of
heavy equipment.
Since minimizing overall cost was one primary consideration, the
OSC decided that a short-response bidding process would be undertaken
to insure obtaining the most favorable prices for the work to be per-
formed. Local contractors were notified of the upcoming project,
invited to the site for detailed discussions with the OSC and staff
personnel, and requested to bid on the work items identified.
Pending contractor selection and startup, the emergency contractor
would complete duties under Phase III operations, circulate the oil
emulsion layer away from the weakened dike into the northernmost pond,
recover the oil which had collected in pools below the western dike
toe, and complete the intercept drain to prevent surface and ground-
water from entering the lagoon. Also, the permit for use of the dis-
posal site/land farm would be formalized by Hill Air Force Base, and
Weber County Highway Department crews would upgrade the lagoon access
road and construct the needed truck turnaround and pump stand on the
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lagoon edge. The bidding process, theretore, did not delay initia-
tion of the cleanup operations.
Technical aspects of the bid package were developed by EPA
engineers supported by site surveys, equipment specifications, and
cost estimating provided by the Great Basin Surveying and Engineering
Company, Bountiful, Utah. The procurement office of DDO provided all
other inserts to the bid package so that it then contained all items
necessary to meet Federal guidelines for contractual agreements.
Thereafter, the DDO procurement office monitored the bid package
advertisement, distribution, submission and opening to ensure that
all phases were carried out in the prescribed manner.
The planned work was divided into two separate bid items: (1)
The first item was a cost/hour for laborers and equipment (with oper-
ators) to be used at the farm site for discing, plowing, tilling, road
preparation and maintenance, nutrient and lime application, and fencing
if required, and, at the lagoon site, for hauling, dozing, and loading
sludge and earthfill, and for removing junk and debris from the lagoon
and surrounding work area. (2) The second item was for the pumping,
hauling, and spreading of the liquid contents of the lagoon. The bid
price was to be a lump sum for 750,000 gallons plus a per unit cost
for volumes in excess of that amount.
Considering the short (7-day) reply time, the response was excel-
lent with a total of seven bidders responding, six of whom bid on item
(1) and five on item (2). The bids were opened April 5 under super-
vision of the DDO procurement office. The low bidder was selected for
bid item (1) on the basis of least cost and after verifying suitability
of the contractor's equipment and facilities by EPA engineers (Table
B-l). The bids received for item (2) (Table B-2) were found to be
nonresponsive in that the lowest legal bid received exceeded the govern-
ment estimate by about 25 percent. In addition, the wide range of bids
($35,000 - $75,000) indicated that the problems posed by the operation
under bid item (2) were not completely understood by the bidding con-
tractors. Therefore, the bid package was modified in an attempt to
more clearly define the work required, readvertised, and arrangements
made for a mandatory prebid conference by all potential respondents at
the lagoon site.
The response to the second advertisement was good with five bidders
responding (Table B-3). The range of bids received ($16,975 - $25,000)
indicated that clarification of the work required had been accomplished,
and further, the low bid was less than the EPA estimate. A contract
was signed with the low bidder on April 21, after inspection of the
contractor's equipment and facilities by EPA engineers. The low bidder
on both items (1) and (2) was Miya Brothers Construction Company, Ogden,
Utah.
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K. LAND FARM PLANNING
The use permit issued by Hill Air Force Base covered approximately
200 acres on the south slope of Little Mountain, of which 40 acres were
found suitable for oil application because of slope limitations, soil
depth requirements, rock outcroppings, and preexisting roads. Plots
were laid out and staked by Dr. Skujins and then individually surveyed
by the Great Basin Surveying and Engineering Company (Fig. A-13, 14).
Baseline soil samples were taken and comparative analyses made by Ford
Laboratories, Salt Lake City, and by the Ecology Center, USU. On the
basis of the background analyses and on the projected oil application
rate required to dispose of the lagoon contents, the quantities of lime,
phosphorus, and nitrogen to be added were calculated (Table B-4). Rep-
resentatives from the EPA Water Quality Laboratory, Edison, New Jersey;
National Environmental Research Center, Cincinnati, Ohio; DOHM, the OSC
and staff; Utah State Health; Utah Wildlife Resources and Weber County
Health participated in the land farm planning.
The application rates and procedures recommended by Dr. Skujins
were guides set up with the realization that limitations of equipment,
time, and money could result in considerable modification of these
guides (Table B-5). Varying combinations of oil and nutrient applica-
tion rates between the plots were chosen to provide information which
would allow adjustment of later nutrient application rates to assure
satisfactory biodegradation on all plots. The proposed work plan called
for additional applications of nitrogen (urea) in the Fall of 1974 and
the Spring and Fall of 1975, with reseeding, if necessary, in the Fall
of 1975. It should be remembered that this area is semiarid, annual
rainfall approximately 12 inches, and that previous published informa-
tion on oil waste disposal by soil cultivation processes had been ob-
tained from areas with wetter climates and therefore not directly
applicable to this site. Irrigation would have been desirable to
ensure maximum biodegradation within the 2-year period, but costs
would be prohibitive.
L. RRT MEETING, MAY 24
A third meeting of the Regional Response Team was held May 24,
1974 in the EPA field headquarters. The single item on the agenda
was sludge disposal. The members were briefed on the success of the
operation to date. The reduction of the area affected by the oily
bottom acid/sludge was still in progress by the contractor and the
members were taken on a tour of the site to view the sludge handling
problems.
Analysis of sludge core samples taken by the Great Salt Lake
Minerals and Chemicals Corporation using gasoline powered coring equip-
ment and analyzed in 6-inch segments by Ford Laboratories (Table B-6, 7)
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was reported. All segments showed high content of heavy metals, oil
and grease, and extreme acidity.
The following recommendations were made by the members attending
and their positions supported by followup written concurrence:
(1) The sludge should not be abandoned at the site in its present
state. Otherwise, the accumulation of water in the open sludge pit in
the Fall, Winter, and Spring, and the release of floatable oil from the
bottom sludge, would regenerate the preexisting site conditions. This
would create a death trap to unwary migratory wildfowl and an imminent
and substantial threat to U.S. waters.
(2) The sludge should be left in the present location. Removal
of the sludge to another site would involve unjustifiable hauling costs,
prolong and increase exposure of more operators to the health hazards
posed by the sludge, and lead to semipermanent impairment of the new
site.
(3) Covering of the untreated sludge was not feasible as shown by
extrusions in the cut/fill areas (Fig. A-ll) initially employed by
Western Petroleum Company in 1967 near the south end of the lagoon.
Methods for sludge stabilization would have to be found.
(4) Methods of sludge treating, mixing, and stabilizing should be
further investigated by the OSC and staff. Rock and local clay were
suggested as possible mix materials with inclusion of lime to neutralize
the sulfuric acid present. The final capping would require that the
stabilized material support considerable weight.
(5) Assistance of State and County Highway Departments in the
construction of perimeter and internal dikes to create work platforms
for the mixing process, to contain the material, and to provide lateral
cap support would be unavailable until the Fall. A followup meeting
with the State to seek immediate assistance was recommended.
(6) The safety of on site personnel with respect to the sulfur
dioxide, acid, and noxious fumes from the disturbed sludge should be
monitored carefully.
(7) A monitoring program to detect off site migration of pollut-
ants should be arranged with the State. This would involve continued
monitoring of the quarry pond in the drainage below the land farm site,
and instituting periodic monitoring of the irrigation return canal south
of the lagoon site.
(8) The present contractor would be utilized for the additional
work if a contract extension could be arranged.
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The reduction of the area containing the bottom acid/sludge was
95 percent completed by the end of the work on May 24. Further work
at the site was postponed for 2 weeks to permit the contractor to
meet prior commitments at DDO and to allow for amendment of his con-
tract to cover the time extension necessary to complete the cleanup.
This 2-week period was utilized by the OSC in further coordination
with and obtaining concurrence by Federal, State, and County agencies
on the RRT recommendations and for further investigations into and
development of the mixing and treating techniques.
M. DEFENDANT ATTORNEYS MEETING AT SITE, MAY 10, MAY 15
An on site briefing of the defendant attorneys was held on May 10.
A tour of the site was made and the OSC briefed the group on operations
to date and the project status. The sludge disposal problem was dis-
cussed at length and the attorneys agreed that the lagoon could not be
left in its current state. They realized that abandoning the sludge in
place would result in a redevelopment of a hazard to migratory wildfowl,
as had previously existed, and the continued existence of an imminent
and substantial threat to U.S. waters under 311(e) of the FWPCA. In
addition, the sludge from the original cut/fill attempted by Western
Petroleum Company in 1967 was extruding to the surface. This made it
evident that a simple earthen cover was out of the question. They
stated that they would leave the final solution to EPA and reserve the
right to contest the method employed in court. The defendant attorneys
asked the cost of the operation to date: $90,000 was quoted from the
headquarters ledger.
A second meeting was held on May 15 at the field headquarters with
members of the Weber County Commission and defendant attorneys. The
problem under discussion was, again, the disposal of the oily bottom
sludge, and secondly, obtaining further assistance from the County
Highway Department. The Weber County Commissioners stated that they
could not supply equipment and men at this time because of prior commit-
ments. However, during slack times in the Fall they would be able to
assist. The OSC thought completion of the job at this time would be
more efficient costwise and agreed to the County suggestion to seek
combined assistance from the State and County at the State level.
N. GOVERNOR RAMPTON MEETING, JUNE 7
Governor Rampton was briefed by the OSC at the State Capitol in an
open meeting on June 7. Members of the Weber County Commission, Utah
State Department of Highways, the Utah State Division of Health, and
media were in attendance. The OSC reviewed the status of cleanup
operations at the Little Mountain Salvage Yard Oil Lagoon and brought
Governor Rampton up to date on the advice and recommendations of the
Regional Response Team. The purpose of the meeting was to arrange for
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State and County assistance, at this time, in construction of a
perimeter dike around the sludge area. The OSC estimated that 6,000
to 9,000 yards of fill for perimeter dike construction and 3,000 yards
for the internal dikes would have to be transported into the lagoon
site. The Governor made available for this purpose funds from his
emergency account to cover the State costs. County expenses would be
absorbed into their operating accounts. State and County Departments
would make available dump trucks, a grader, dozer, and track loader,
with operators, until hot weather would dictate reassignment of equip-
ment to precommitted road surfacing work.
Details of the arrangement were worked out at a meeting on June 10
in the State Highway District Office, Ogden. The State would provide
three ten-wheel dump trucks, a grader and/or dozer, and the County would
provide a track loader and two ten-wheel dump trucks. The EPA contractor
would support this stage with a water truck, compactor, 5-yard loader,
and a dozer/ripper. County fill would be utilized and the work day
would be 10 hours, starting at 6:00 a.m. on June 11. This combined
effort moved and compacted 5,760 yards of fill from June 11 to June 14.
State and County equipment was no longer available after that date as
daytime temperatures had consistently risen above 100° and road finish
materials had to be laid. The lagoon perimeter dike was 80 percent
completed and, by serving as a road base, allowed the contractor's belly-
dump trucks to efficiently complete the balance of the diking.
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IV. OPERATIONS
The following discussion consists of four parts which correspond
to distinctive stages of the overall operation: A - Emergency Actions,
B - Lagoon Operations, C - Land Farm Operations, and D - Concluding
Operations. Even though actions under parts B and C were carried out
simultaneously, and were initiated before A was concluded, they will be
segregated for clarity.
Part E, an overview, contains comments on the daily routine and
general operating conditions during the entire project. This general
review shows how the various operations were tied together into the
administrative unit supporting the OSC. A synopsis of the Operational
Plan in light of the actual work to completion of the project is included.
A. EMERGENCY
Phase II and Phase III response actions under the National Oil and
Hazardous Substances Pollution Contingency Plan were initiated immedi-
ately after and according to plans developed at the February 15 RRT
meeting. The National Weather Service maintained a weather watch for
the area and issued daily forecasts to the OSC so as to provide him the
necessary lead time in reacting to threatened precipitation. Late
Winter and early Spring storms produced rapid fluctuations in the lagoon
liquid level. One storm on February 23 - 24 decreased the already mini-
mal freeboard by 2 inches.
An emergency contractor, Electric Sewer Service of Ogden, was employed
in February using funds provided by DOHM to fabricate and install two
18-inch T-siphons in a skimming pond in the irrigation return canal inside
the Refuge boundary (Fig. A-2). The skimming pond was placed in the only
location accessible by vehicles, due to the ground conditions at this
season of the year. The two 18-inch T's proved to be inadequate for the
canal flow experienced during snow melt and precipitation runoff. Three
24-inch T's were later added to adequately handle the increased flow.
The adjacent land owner west of the site, Mr. Slater, was contacted
about constructing an emergency catch pond on his property in the drain-
age leading from the lagoon to the canal to contain the lagoon liquids
in case of major dike failure. He was understandably not receptive to
the idea and the point was not pursued. He informed us that oil had been
discharged from the lagoon the previous Spring into water on his property
and into the canal, making it necessary for him to remove cattle which
had been grazing in the pasture and watering from the canal.
Another alternative considered was diversion of the irrigation
return canal, from a point east of the lagoon, into its former channel
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and away from the south edge of the lagoon (Fig. A-2). However,
when the nearby track spur was laid, the culvert was removed, sealing
the old channel and preventing its use. Had the diversion been
possible, the present irrigation return flow ditch would have served
as an emergency catch channel. To increase the holding capacity of
the irrigation canal and to retard the flow of oil in the canal, a
series of plywood baffle skimmers were installed by the emergency
contractor in the canal upstream from the skimming- pond.
Sandbags and sand were stockpiled at the lagoon site and the
skimming pond to enable rapid repair of the dike or pond in the event
of topping or erosion. The emergency contractor located and placed
on standby supplies of fencing, cable, sorbents, and straw. These
items would be immediately available to contain a catastrophic dis-
charge. The OSC arranged for standby manpower, vacuum trucks, tankers,
and pumps from refineries, trucking companies and contractors locally
and in Salt Lake City, 45 miles distant. All forces could be mobilized
on an hour's notice.
The OSC requested and obtained an ADAPTS pump system, with opera-
tor, from the Coast Guard Pacific Strike Team on February 28. The
system was flown from San Francisco to Hill Air Force Base by C-130
aircraft. The pumping equipment was then transported by truck to the
lagoon site where it was held in reserve pending threatened major
discharge. In case heavy rain threatened overflow of the dike, the
ADAPTS unit would have been used to pump the underlying aqueous layer
out of the lagoon in order to increase the freeboard retaining the
overlying emulsion layer. The Coast Guard operator maintained site
surveillance and assisted the OSC in monitoring the activities of the
emergency contractor.
Permission for initiating emergency, mitigative measures on the
lagoon site itself was obtained from the United States District Court
for Northern Utah, following the sudden decreases in freeboard from
precipitation on February 23 and 24. These site operations included
reinforcement of the weakened dikes, prevention of further surface flow
into the lagoon, and as soon as possible, transfer of floating emulsion
then against the dikes into the north pond. Sandbags were filled and
placed around the south and west edge of the lagoon by the emergency
contractor so that an additional 4 inches of freeboard was obtained.
Sandbags were also placed on the dike face to reinforce areas showing
dike seepage and erosion due to previous overtopping. Surface drainage
into the lagoon was controlled by construction of small earth berms and
sandbagging along the east and south edges of the lagoon. This necessi-
tated moving some junk and debris from the work area. The pools of oil
below the west dike were removed by pumping the liquids over the dike
back into the lagoon with a small, gasoline powered, centrifugal pump.
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Further cleanup below the dike was accomplished using straw as sorbent.
A temporary dike was constructed across the drainage at the west prop-
erty boundary to contain oil still seeping through the dike and to pre-
vent any further discharge to the Slater property and the irrigation
return canal.
The access road to the lagoon from 900 South was reinforced by
Weber County Road crews the week of April 1. A pumping stand and turn-
around for vehicles and heavy equipment was also built at this time.
Some roadbase work was required of the emergency contractor prior to
April 1, out of necessity, due to the high groundwater and the effects
of frequent precipitation on the existing road.
Migratory birds, especially during full moonlit nights, were landing
in the lagoon and perishing on the oily surface. The Utah Division of
Wildlife Resources and the United States Fish and Wildlife Service
assisted in obtaining and placing strings of banners, carbide cannons,
and flashing barrier lights around the lagoon in an attempt to frighten
away wildfowl. These were not 100 percent effective. The presence of
workers at the lagoon during the daylight hours was probably more effec-
tive than these devices in preventing bird loss. No attempts at bird
rehabilitation were made as these agencies felt that it would be impos-
sible to clean any bird that had been in the lagoon liquids. Birds
found alive in the lagoon were dispatched as quickly as possible.
A dike and roadway from P]_ (Fig. A-7) and vehicle turnaround area
to the lagoon center island was constructed so as to permit removal of
car bodies and junk from the lagoon interior. It also provided access
to and for installation of a skimming weir (G) fabricated from pipes
and planks found at the site, in the dike separating the north pond from
the remainder of the lagoon. Aqueous liquids were pumped from the lower
strata of the north pond, using a 3-inch trash pump spotted on the
initial pumping stand (P^), across the dike roadway separating the
north pond from the balance of the lagoon. This action flushed the
floating oil emulsion, with wind assistance, toward the south across
the shallow area (A^).
With approximately a 4-inch liquid differential across the skimming
gate (G), the gate was lowered, allowing emulsion to be carried across
the gate by return flow into the north pond. The flow of emulsion into
the north pond was assisted by use of oil booms pulled by rope from the
shoreline. Booms for this operation were borrowed from the Amoco Pipe-
line Company and the Phillips Salt Lake City Refinery. Phillips also
supplied a small, flat bottom boat used in maneuvering and positioning
booms in the lagoon. A handheld high pressure hose was used to help
break up the 12 to 14-inch thick emulsion mass as an aid in crowding it
across the weir into the north pond. After liquid level equalization
across the weir, the gate was raised and pumping continued until another
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4-inch differential was obtained. The gate was again lowered, and
additional emulsion was collected in the north pond. This procedure
was repeated several times each day.
As the first area (A^) was cleared of floating emulsion, straw
bales were placed end to end (B^, Fig. A-8) to isolate the area from
any emulsion return flow. The aqueous discharge point was then moved
by constructing a channel from (P^) along the east edge of the lagoon
to a point beyond the end of B^ to provide flushing to the adjacent
shallow area (A2). As this area was cleaned of floating emulsion by
wind and flushing action, a second string of bales (B2, Fig. A-9) was
placed. The discontinuity apparent in the diagram occurred because a
wind shift allowed floating emulsion to begin flowing back into cleaned
areas after start of placement of the bale string.
Several ideas were tried in conjunction with breaking up and cir-
culating the emulsion into the north pond, and later flushing the
residues to the pump stands:
(1) A high pressure stream of water was used to partially break
up the emulsion mass just ahead of the weir. The stream by itself
proved ineffective in pushing the emulsion over the weir but, when used
with the hand pulled boom, speeded emulsion transfer to the north pond.
An attempt was made to operate the hose from the Phillips boat. The
effect of the stream on the emulsion mass was no better than that
achieved from the nearby bank. Hose handling problems, boat instability,
laborer's inexperience, and the threat of a possible fall into the acidic
liquids quickly terminated this operation.
(2) The use of helicopter downwash to assist in crowding the emul-
sion toward the skimming weir was tried briefly by a small Bell heli-
copter chartered for a photo reconnaissance flight. The method proved
effective where the thick emulsion mass had been partially broken up by
high pressure hose action. However, the operation was suspended after
only a brief trial because of high cost; the emulsion would not be
hurried. Use of an air cooled engine swamp boat appeared feasible from
experience with helicopter downwash and wind action. However, this idea
was never implemented.
(3) Low pressure, high volume flushing by copious amounts of the
aqueous liquids proved the most effective in herding the emulsion mass
and later the residues. As areas were flushed clean, the temporary dis-
charge point was moved by ditching, or use of hose or 5-inch irrigation
pipe (P3 and P4, Fig. A-9).
(4) As liquids were being drained, high pressure streams were once
again tried in order to bring emulsion residues to the pump stands.
Streams were tried from low level (hand held) and high level (hydroseeder).
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Both methods failed and low pressure, high volume flushing was continued.
Eight sheep had wandered into the lagoon sometime after February 18.
The bodies floated to the weir as the emulsion layer was transferred to
the north pond. These were pushed to the side until all eight were col-
lected. They were then removed and buried in the nearby Weber County
offal landfill.
Several test holes had been dug around the lagoon site to monitor
groundwater levels (Fig. A-4) . One hole (Testhole //1) , approximately 20
feet east of the lagoon, showed groundwater at 4 inches, or roughly at
the same level as the lagoon liquids. Over a period of 6 days, the
level in the test hole dropped approximately 5^ inches. After snow on
April 10, the hole had refilled to its original depth. By April 11, the
lagoon liquid level had risen 1 inch, corresponding to the addition of
about 300,000 gallons to the liquid volume.
By April 14 approximately 80 percent of the emulsion in the lagoon
had been transferred away from the weakened west dike and concentrated
in the north pond. Most of the remaining emulsion was concentrated and
isolated in the deep pools in the lagoon's southeast corner. Containment
and mitigation actions were nearing completion. The emergency contractor
then excavated a drainage ditch around the east and north sides of the
lagoon (Fig. A-12). This open ditch, 4 to 5 feet deep, 3 feet wide, and
1,200 feet long, was designed to intercept the ground and surface water
flow toward the lagoon, reduce the artesian pressure influencing the
lagoon liquid level, and channel collected water into the irrigation
return canal flowing east to west along the southern property boundary.
The entire Little Mountain Salvage Yard was under artesian influence.
Just behind the field headquarters, 500 feet north of the lagoon, was
an artesian well with a 6-foot head. Groundwater level before construc-
tion of the intercept ditch was 0 to 3 inches below grade on the north,
east, and south sides of the lagoon. The intercept ditch was completed
on April 23.
On April 22 and 23, the emergency contractor brought an 850 gallon
vacuum truck to the lagoon for emulsion pumping, hauling, and dumping
experiments. After eight loads were removed from the lagoon, it was
established that this vehicle would be inadequate for the job. Contracts
covering the balance of the work to be performed under Phase IV had been
signed with Miya Brothers Construction Company and Miya was now on the
job. Operations by the emergency contractor were completed on April 23.
Miya Brothers Construction Company began work on April 9. Preparing
the disposal site at Little Mountain was the first priority operation so
as to permit removal of the emulsion at the earliest date possible. Work
was immediately suspended for 5 days because of heavy snowfall, resuming
again on April 15.
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Miya was utilized at the lagoon site in completing Phase III
activities in support of Electric Sewer Service, and thus the two
contractor operations overlapped. Miya participated during this
period in the circulation and concentration of the emulsion into the
north pond, gaining pumping experience and establishing pumping
requirements.
In addition, Miya did the bulk of the necessary junk and debris
clearance from the lagoon and work area. Junk and debris were removed
by using combinations of hand labor, cable winching, and a 5-yard
front end loader. All was removed with the exception of several car
bodies that were deeply mired in the lagoon sludge. At least half of
the junk on the 15-acre tract was either in or adjacent to the lagoon.
The Little Mountain Salvage Yard owner arranged for clearing the entire
site of junk and this operation was completed by the time EPA opera-
tions were concluded for the summer.
B. LAGOON
After operational startup of Phase IV activities by Miya, the
search for an adequate pumping system to handle the lagoon liquids
intensified. Experience gained in the circulation effort had estab-
lished the pump operational requirements: high capacity, minimum trash
interference, and boosting to a 15-foot head for loading of tankers.
The systems available locally and tested or studied included:
(1) The USGS ADAPTS: This is a high capacity (2,000 gpm) hydrau-
lically driven system which can tolerate moderate trash interference.
This system would have been suitable, but somewhat oversized. It was
withdrawn from consideration because of concern about corrosion due to
the liquid acidity, and the need to return the pumping system to the
PST in case it would be required for emergency use by the Coast Guard.
(2) An 850-gallon vacuum truck had been brought to the site for
evaluation by members of the PST at the time of delivery of the ADAPTS
pump. This unit was retested during early removal of the liquid contents
from the deep pools in the southeast corner of the lagoon. The truck
was very slow in loading the emulsion, requiring approximately 25 minutes.
The only discharge port was through 4-inch rear piping. The rate of dis-
charge, the inability to achieve any wide distribution (splash), and the
slow turnaround for the volume hauled (in excess of 1 hour for 850 gal-
lons) caused this system to be withdrawn from consideration.
(3) A Groman-Rupp 4-inch, single diaphragm pump: This pump was
used at the site to aid in cleaning isolated pockets of liquid. It is
a low volume pump capable of pumping several gallons a minute against
a fairly low head. It would tolerate trash up to 4 inches in any dimen-
sion. However, the diaphragms were susceptible to puncture. Use of
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diaphragm pumps was ruled out due to capacity and head limitations and
possibility of puncture.
(4) The 3-inch Jagger centrifugal trash pump: This pump met the
operational requirements when pumping the aqueous liquids and was sub-
sequently used for aqueous liquid removal. However, it lugged down
when the emulsion layer was encountered.
(5) The 2-inch and 8-inch Crisifulli centrifugal irrigation
pumps: The 2-inch pump, as expected, proved to be grossly undersized
and inadequate. The 8-inch model, however, proved to be more than
adequate and thoroughly suited to the job. The pump unit is mounted
on an independent axle at the end of a 10-foot draw bar and driven by
tractor power takeoff. The intake is through a front and rear center
orifice with the discharge at an upper corner into an 8-inch rubberized
discharge hose. The no-head capacity of the pump is approximately
2,500 gpm when pumping water. Pumps were now available to do the work
and no further pump evaluations were made.
Two tankers, 4,350 and 2,800 gallons capacity, were equipped with
a 3-inch bottom loading port, a 24-inch top hatch, and a 12-inch bottom,
rear, air actuated, gravity feed discharge port. The only modification
needed was the attachment of a horizontal splash pan below the discharge
ports. The first attempt at discharging a load of emulsion failed due
to the high viscosity of the mass. The splash pan was lowered in an
attempt to improve the condition but this had little effect. By sub-
merging the Crisifulli pump to just above the emulsion/aqueous inter-
face, aqueous phase was mixed with the emulsion by centrifugal action,
altering the thixotropic properties and sufficiently decreasing the
viscosity to permit rapid discharge from the tank. When fully loaded,
a uniform splash pattern approximately 10 feet wide was achieved.
The contract called for separate removal of the emulsion and
aqueous layers, but it was agreed between the contractor and the OSC
that combined aqueous/emuIsion would be pumped in order to facilitate
tanker discharge. Removal from the lagoon of liquid volume over
750,000 gallons (60 percent emulsion) was paid for at the unit rate
bid for the aqueous portion. Some separation of the layers occurred
during transport and to allow proper application rates on the land
farm plots it was necessary to gauge the tank to measure emulsion and
aqueous volumes.
By April 18, most of the emulsion (estimated to be 600,000 to
700,000 gallons) was concentrated in the north pond and liquid removal
operations began in earnest. A 6-foot deep sump was dug (Pj, Fig. A-9)
for pump intakes. The 3-inch trash pump was used to pull the aqueous
liquids from beneath the concentrated emulsion. Loading was accomp-
lished through the bottom port in each of the tankers and a 50-pound
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bag of lime was added to the load through the top hatch for pH con-
trol. The pumping rate during this stage was approximately 500 gpm.
The 1^-mile trip to the farm took approximately 5 minutes, the dis-
charge (flushing onto plots 0, P, Q, R, Fig. A-14) another 5 minutes,
and the return trip and spotting accounted for a turnaround time of
approximately 30 minutes.
After 4 days of pumping, approximately 226,000 gallons of aqueous
had been removed by this method and the trash pump was starting to lug
down because of the partial intake of emulsion. By this time trials
with the 8-inch Crisifulli had been completed, the loading arm had been
fabricated, and the land farm was ready for receipt of the emulsion.
On April 23, the first loads of emulsion were removed. The increased
rate of pumping into the top tanker hatches (2,000 gpm) reduced the
turnaround time by 5 to 10 minutes. Liquid removal from the north pond
proceeded initially at the rate of 80,000 to 120,000 gallons per 8-hour
day. Later., daily volumes hauled fell off because of the work required
in bringing remaining liquid to the pumping station.
As the north pond liquids were evacuated, the skimming weir was
gradually lowered, allowing additional amounts of emulsion to be carried
to Pi. By May 8, the dike separating the north pond from the balance
of the lagoon was removed. All residual liquids found along the
western lagoon edge and within the north pond were either flushed to
Pi or crowded to Pj_ by tracked dozer (D-2 size) action for removal.
A pump stand (P2> Fig. A-9) was built to facilitate draining liquids
from the southeast lagoon corner. As liquids were drained, residuals
were flushed or crowded towards the pump stand. By May 9, all liquids
had been removed. On May 10, emulsion stained earth from areas of the
lagoon bottom and sides which were not contaminated with the acid sludge
was stripped and stockpiled. Six hundred and thirty yards of this
emulsion stained earth were later removed to Plot T at the land farm.
On May 10 - 11, initial backfilling of the cleaned shallow depres-
sions along the southern lagoon edge commenced. Repeated passes of
heavy equipment across the cut/fill area (A3, Fig. A-9) caused buried
sludge to extrude to the surface. The seep intensified and additional
seeps originated throughout this general area from ground vibration due
to movement of equipment and passing railroad trains.
Beginning May 13, the outer edges of the sludge mass were consoli-
dated by pushing (D-8 Dozer) the outlying material toward the center.
As the sludge was consolidated, clean earth was pushed against the peri-
meter to hold the sludge in place and to form a temporary dike for
ponded liquids.
The semiliquid sludge mass rose approximately 4 inches during this
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operation due to the burden placed around the outer edge. All- lagoon
liquids present initially were removed during the pumping/hauling
phase. However, subsequent rains, continuing groundwater seeps, and
partial deemulsification of the lagoon sludge due to the mechanical
action of the forces being applied around the edges caused free
liquids to once again appear on the surface of the sludge mass. These
liquids exhibited the same properties as the original lagoon liquids:
floating oil and strongly acidic aqueous phase.
During this operation, the weakened western dike was dissected
and used for temporary containment of the consolidated sludge mass.
A detailed inspection of the dike by the OSC, staff, and the dozer
operator showed that the dike was saturated with oil. This saturation
and channeling had allowed seepage of lagoon liquids through the dike
into ponds and then into the nearby irrigation return canal as seen in
February and March 1974 and in 1973.
During Spring the sludge mass exhibited varying ability to support
weight and tolerate disturbance. On cool or cloudy days (slow thermal
heating of the black surface) the sludge crust would support, for a
time, the small tracked dozer and personnel. The crust could be wind-
rowed to assist residue flushing or pushed from place to place. When
left undisturbed for a period of time the sludge would flow, loosing
all cohesive structural support. Berms for channeling flow would dis-
appear, items of equipment (irrigation pipe, hand tools) would sink,
the dozer if stationary for too long in one spot would gradually sink.
This phenomenon became more pronounced as the days and nights became
warmer and the overlying liquids were removed. Summer sun on black
heat absorptive surface caused the undisturbed mass to reach a sub-
surface (10 inches) temperature of 115 - 120 degrees Fahrenheit. With
the mass heated to this temperature, all structural support was lost
and the sludge assumed properties of a highly viscous liquid.
As liquids were drained from the north pond, approximately 500
yards of sludge were found in the northern half of the pond bottom.
Beginning May 13, an attempt was made to consolidate this sludge with
the main sludge mass. This sludge, as soon as it was disturbed, became
a semiliquid which could not be pushed in quantity for any appreciable
distance. The pond bottom was saturated with groundwater and would not
support a wheeled vehicle. The major bulk of the sludge was removed
by pushing quantities of the sludge onto the bank and into the bucket
of a 5-yard loader by dozer blade action. The loader then carried and
dumped it into the main sludge body (cell 1, Fig. A-ll). The soft pond
bottom caused frequent bogging of the D-8 cat. This operation was
augmented with a backhoe and dragline operation from the bank. Bottom
instability and high groundwater caused temporary suspension of this
operation on May 23 to permit drying of the bottom.
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The necessity for coordinating the actions of State and County
Highway Departments, permitting Miya Brothers to meet prior commitments
on two DDO projects, completing paperwork necessary to extend the EPA
contract with Miya, and determining and coordinating a final sludge
mixing and treating method resulted in a 2-week suspension of work
by Miya May 27 to June 9. In preparation for this, additional temporary
diking was done around the sludge mass to protect the site from any un-
expected precipitation and a catch basin was installed across the drain-
age along the west property line.
State and County Highway Departments and Miya Brothers began work
June 10 on the construction of a permanent perimeter dike to totally
contain the sludge mass. Five 10-wheel dump trucks, two D-8 cats, a
3-yard and a 5-yard wheeled loader, and a Heiner compactor placed
5,670 yards of fill into the perimeter dike during 4 10-hour days,
completing approximately 80 percent of the permanent dike (Fig. A-ll).
Thereafter, Miya using a 10-wheel dump and two 22-yard belly dumps
completed the exterior and interior dikes by June 29. A total of
14,500 yards of fill went into this dike construction. When completed
(Fig. A-10), the perimeter and interior dikes dividing the lagoon into
four compartments (cells 1-4) were 3 feet above the sludge level with
a 10-foot wide top forming a road and work platform. The dike around
cell 5 was 2 feet above the sludge surface and also 10 feet wide.
Great Basin Surveying and Engineering Company surveyed and briefly
advised on dike construction and fill properties until arrangements
were completed with the Bureau of Reclamation to act as inspector for
the diking and capping operations. An engineer inspected the progress
periodically and reported on the adequacy of the construction.
The interior area of cell 1 had originally contained most of the
car bodies, junk, and debris that were in the lagoon embedded in sludge
to a depth of 2 to 4 feet. Smaller pieces at or near the surface were
pulled loose by hand, winched out by cable from the bank or scooped
out with the small tracked dozer. Large items deeply mired were not
extracted. Items removed were stockpiled in a separate area to await
cleaning before salvage by the land owner.
Early plans for final sludge treatment revolved around the idea
of entombment. These plans anticipated the incorporation of rock and
rubble into the sludge mass, enough to supply sufficient void space to
interstitially contain the entire mass and serve as support for the
final cover. No concerted effort had been made to extract all mired
junk and debris from cell 1 as this material would add to that structural
support. Also, in order to save time and money, the heavily contaminated
junk and debris which had been initially removed to allow for equipment
passage was reintroduced into cell 1. Chunks of defective concrete block
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and pipe were brought to the site by a local plant to be used for
incorporating voids into the sludge.
By the time the final method of sludge mixing had been determined
(discussed below), all cracked pipe, broken block, and oil contaminated
junk available at the site had been placed into cell 1.
Mixing experiments at the site were conducted by Consolidated
Denver Corporation. Materials tried were alkaline salt cake and
anhydrous sodium sulfate, which were available in quantity from nearby
Great Salt Lake Minerals and Chemical Corporation, clay available
locally, lime, cement, and a proprietary gelling agent. Alkaline clay
soil from the site itself proved to be an acceptable mixing and treat-
ing agent at about 8:1 to 10:1 mix ratios of alkaline clay: oil and
grease content of the sludge.
Experience of Consolidated Denver Corporation as well as that of
other contractors contacted had included mixing operations in which
heavy sludges and oil were pumped from a lagoon or holding pond to a
blender or mixer, the material being returned to the lagoon or pond
after mixing. This procedure is slow and expensive and to save time
and money, the OSC and staff decided to conduct _in situ treatment and
mixing using locally available equipment.
Any disturbance of the sludge caused release of quantities of SC>2
and other gases, in addition to the ever present noxious odor (Table
B-8). This feature had become evident during the efforts to consolidate
sludge found in the north pond area into cell 1. However, at that time,
strong daily breezes dissipated the fumes and odor away from the opera-
tional area. Later, as mixing/treating operations began, summer calms
beset us and the fumes and rank odors permeated the entire site. Ele-
vated levels of SO2, measured by OSHA, EPA, and Utah State Health,
created an unhealthy working environment. Equipment operators and
personnel closely monitoring the operation used bottled air for sustained
operations. Self contained packs for rescue were available in case of
accident. This requirement made the sludge operation very difficult for
the equipment operators during the hot weather, and was a primary factor
in not moving the sludge from the lagoon for off site disposal.
The only means of standoff mixing was to use a small dragline oper-
ating from the dikes. The mixing/treatment began by stirring the sludge
in cell 2 with the dragline bucket, increasing the overall temperature
of the sludge by distributing the solar heated surface throughout the
mass and by heat produced by air oxidation of previously anaerobic
materials. This stirring served to reduce the sludge viscosity, to
dry the sludge to some extent, and to release some of the SO2 and gases
that were present in the sludge mass, reducing these concentrations
during subsequent mixing stages. A load of dry clay soil was brought
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to and dumped along the edge of a cell by either dump truck or the
5-yard loader. The dragline operator would then scoop a mixture of
sludge and clay soil from one spot and dump the load, scattering it
as much as possible in another area of the cell being worked. More
soil was added and the operation repeated as the dragline worked
around each cell and from cell to cell. This work produced a cavity
on one side. The natural flow of the semiliquid mass from mound to
pit also helped to a minor extent to distribute and mix the soil into
the sludge. A thorough intimate mix could not be achieved by this
method. However, the partially mixed mass became stable enough to
support the weight of the D-8 cat most of the time.
Although often plagued by bogging, the cat was able to achieve
additional mixing by blade and track action. More dry clay soil was
added and the new mixture windrowed back and forth with the blade.
Mix temperature during this time, because of radiant heating and
chemical reaction, reached 150 degrees Fahrenheit and this heat was
hard on equipment and tiring to personnel. A thorough mix was still
not achieved, as witnessed by the fact that unmixed sludge continued
to extrude to the surface of the mixed cells. As soil was added and
mixed with the sludge, mix levels approached the top of the dike in
cell 4. Five hundred to seven hundred cubic yards of partially
mixed sludge was transferred from cell 4 to cell 5 to gain additional
cell 4 freeboard. The cut/fill area in cell 5 was dug with a backhoe
and all exposed sludge in cell 5 was mixed with alkaline clay.
A Raygo Gator rototiller, capable of thorough mixing to a depth
of 20 inches, was rented from the Great Salt Lake Minerals Company
and utilized to achieve the final complete intimate mix. Additional
clay soil was brought to the lagoon, placed on the partially mixed
sludge and tilled by the Gator into the sludge. As a layer of sludge
was suitably mixed with the Gator, it was pushed aside to allow access
to and working of the next lower layer. This process was repeated
until the bottom of the sludge was reached in each cell. The depths
ranged from 18 to 20 inches in cell 1 to approximately 5 feet in cell
4. The excavated mix was then replaced in the cell. The Gator ex-
hibited surprising ability in attacking the rock, rubble, and debris
strewn sludge in cell 1. Fortunately, the only large items found in
this area that the Gator was unable to handle were half a dozen car
bodies. Sludge adjacent and within these car bodies was mixed by use
of a backhoe and dozer. The Gator was able to negotiate the remainder
of the cell with little trouble so that an acceptable mix was achieved.
At this point, the interior dikes were shaved down to the level of the
treated sludge and entire area graded so that the surface had a 2-foot
fall " from north to south and an 8-inch fall from east to west. The
Gator then was able to make full length passes from cell 1 to cell 4,
blending the mix into a homogeneous surface. During the 32 hours of
Raygo Gator use the acids of the sludge corroded the teeth from an
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original length of 12 inches down to 4 to 6 inches. Approximately
30,000 cubic yards of dry alkaline clay soil were required for the
sludge mixing/treating operation.
A 12- to 18-inch thick clay cap was placed and compacted on top
of the mixed and treated sludge to provide for surface water drainage,
a permanent seal against water infiltration, and a support for vegeta-
tion. The perimeter dike top and exterior dike slopes were graded to
prevent surface ponding and retard erosion and the finished clay cap
had the same fall as the mixed and treated sludge. The surrounding
area was graded to allow for site surface drainage away from the dikes.
Since subsurface water flow through the site is from northeast to
southwest, a 6-inch perforated drainline in a 12- to 14-inch bed of
1%-inch gravel was laid in the open ditch along the north and east
sides of the lagoon to permanently intercept and divert groundwater
away from the lagoon into the irrigation return canal. The ditch was
then backfilled and the area graded to blend into surrounding contours.
Operations at the lagoon site were completed August 17, 1975 (Fig. A-12).
C. LAND FARM
The south end of Little Mountain was initially inspected and base-
line samples taken on March 26. After final approval of the use permit
had been given by Hill Air Force Base, the suitable areas were located,
divided into manageable increments, individually surveyed (Fig. A-13),
and coded with colored tape on corner stakes. The 18 initial plots
ranged in size from 0.73 to 10.97 acres. Field trials were made to test
liquid runoff characteristics on tilled ground. After determining
individual plot soil characteristics, Dr. Skujins supplied the OSC with
recommended oil, sludge, lime, and nutrient application rates (Table
B-4) .
Since the oil emulsion, aqueous phase and sludge were acidic, con-
tained high concentration of heavy metals (Cr, V, Ni, Cd, Pb, Zn) and
the soil and oil emulsion were low in phosphorous and nitrogen, the
plots intended for oil disposal were to be treated with several addi-
tives: Calcium hydroxide (lime) to increase the pH of the soil and
neutralize the acid, and to precipitate the heavy metals thereby pre-
venting migration or diffusion; phosphate fertilizer in a single addi-
tion to increase biologically available phosphorous; and urea (45 per-
cent nitrogen) in several increments to promote the biodegradation of
the nitrogen deficient hydrocarbons. The original operations plan
called for four steps in the overall land farm operation: (1) site
preparation including additive application, (2) application of the
lagoon aqueous layer, (3) application of the lagoon emulsion and sludge,
and (4) tilling. Plans included future reapplication of urea and fur-
ther tilling at intervals to be determined by Dr. Skujins. Steps 1 to
3 were conducted concurrently to permit removal of emulsion from the
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lagoon site as rapidly as possible.
Soil depth within the designated farm plots ranged from 6 to 20
inches, with several rock outcroppings occurring randomly through the
area. The entire farm was ripped using a D-8 Cat and C-12 Road Patrol.
Quantities of medium to large size rocks on the surface and unearthed
during this operation were removed by hand labor assisted by a 5 cubic
yard front loader. After ripping and rock picking had been completed,
the entire area was cultivated to a depth of approximately 5 inches by
disc or barber shank harrow action. Both the disc and harrow were
suspended by a three point hitch and worked effectively in the shallow
tilling operations required of them. However, the barber shank harrow
proved better when rocks were encountered due to its ability to pass
the rock between the teeth where the disc would have to step over.
Plans then called for complete application of lime and soil
nutrients to the individual farm plots before depositing lagoon
liquids. Lime and nutrients were applied to plots A-N using a standard
agricultural spreader. Rate of application was guaged by computing
quantity of material in the hopper versus width of coverage versus
length of run tailored to recommendations of Dr. Skujins. No additives
were applied directly to plots 0, P, Q, R (Fig. A-14). Due to delay at
the farm caused by precipitation of April 10, and the necessity for the
rock picking operation, the initial load of lagoon liquids arrived on
April 18, soon after the lime spreading operation began.
Initially, when lagoon liquid phase volumes were large, discrete
removal of the aqueous layer was accomplished. Using the Jagger trash
pump, aqueous liquids were bottom loaded into the transport tankers.
Removal of the aqueous layer permitted concentration of emulsion into
the north pond as rapidly as possible. One 50-pound bag of lime was
added through the top hatch and mixed with the aqueous layer by loading
agitation and motion of the tanker during the 1^-mile lagoon to farm
transit. Aqueous liquids were flushed onto the uphill side of plots
0, P, Q, R and allowed to wash down across the plowed field at a satur-
ation rate. The discharge point was moved, as needed, to prevent runoff
occurring on the opposite plot border. The lime added to the liquids
at the time of loading raised the pH to approximately 9 at the time of
discharge.
Emulsion liquids were top loaded into the transport tankers using
the Crisifulli pump and modified loading arm. Liquids were discharged
from the tankers onto prepared plots through a 12-inch rear, gravity
feed, exit port onto a horizontal splash pan suspended 10 inches below
the port. The emulsion liquids were spread uniformly on the designated
plots, A-N, by contour passes. The application rate was guaged by
calculating the tanker volume versus successive pass spacing versus
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width of splash versus length of run (speed of truck). The EPA
Operations Engineer exercised direct control of all truck movements
to ensure, as near as possible, conformity with the recommended
application rates.
Plans originally called for the emulsion to lay on the surface
after spreading to allow for short term weathering in the hot sun
before final cultivation. However, due to the mixing of the emulsion
and aqueous phases by the truck loading pump, the liquids discharged
from the truck were less viscous than that which was originally
planned for, accumulated in the tire depressions and tended to run.
This tendency to migrate and the threat of rain required that one of
the tractors in use at the farm follow the tanker with the disc or
harrow, partially mixing dirt with the emulsion to hold it in place.
As phase volumes decreased, a greater proportion of aqueous
layer was mixed with the oil emulsion layer. During transit the
tanker load became stratified. At the land farm the aqueous layer
was decanted onto plots 0, P, Q, R. After emulsion started to flow,
the air actuated valve was closed and the remainder of the emulsion
was spread on designated plots. During this stage, lime was added
to loads estimated to contain more than 50 percent aqueous. PST
personnel assisted the operations engineer by spotting trucks, count-
ing loads, controlling applications, estimating discrete volumes and
pulling samples of discharge liquids for on site gross analysis.
The total volume of lagoon liquids exceeded the original survey
(1,675,000 gallons vs. 1,170,000 gallons). A control plot S, 4.2
acres in area, was prepared. This plot and the four plots set aside
for farming a portion of the bottom acid sludge were utilized to
accept the overage. Final stripping of oil residues and oil satur-
ated earth at the lagoon site generated approximately 630 yards of
contaminated soil. Plot T, 0.99 acres, was prepared for this material.
It was hauled from the lagoon in a dump truck, spread with the Road
Patrol, and tilled under.
Eventually, 1,675,000 gallons of liquid was removed from the
lagoon (Table B-5). This included approximately 721,300 gallons of
emulsion and 242,180 gallons of aqueous phase which was spread on
40.46 acres, 663,520 gallons of aqueous phase which was spread on
4.4 acres, and 50,000 gallons of aqueous which was spread on farm
roads for dust suppression. After final liquid loads were placed and
nutrient spreading completed, all plots with the exception of 0, P,
Q, R were tilled to a depth of 5 inches with an agricultural rototiller.
Plots 0, P, Q, R were cultivated with the barber shank harrow.
Three small areas where off plot spillage had occurred were cleaned
by shallow Road Patrol blade stripping. The exposed ground was then
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scarified with the harrow and allowed to naturally reseed. These
runoffs resulted when the tank truck driver opened the rear discharge
port before the truck had moved onto the tilled/prepared surface.
A 12-inch dirt berm was placed around the farm perimeter to
prevent any farm runoff and/or inflow onto the farm area during periods
of precipitation. The initial farming operations were completed on
May 23 and some natural revegetation was apparent within four weeks.
The application rates for materials and nutrients spread are given in
Table B-5.
D. CONCLUDING
The Field Headquarters and operations were secured August 20, 1974.
The Phase IV work remaining was projected for the Spring or Fall of
1975 and Spring of 1976. Operations were to conclude with final evalua-
tion of the sludge mixing at the lagoon site, and return of the Little
Mountain land farm site to Hill Air Force Base after appropriate resto-
ration work.
1. Lagoon. The lagoon site was observed periodically to ensure
functioning of the permanent drainage system installed, and to detect
any extruded material surfacing from pockets of untreated sludge, dike
and cap erosion, and possible migration or diffusion of contaminants
from the site.
Immediately following the securing of the site in August 1974,
minimal extrusion of sludge through the cap was observed at two loca-
tions. These were located at the southwest corner of former cell 4.
These consisted of small pockets (estimated at less than 10 gallons)
that apparently had been left untreated and mixed at the interior of
the perimeter dike toe and represented entrainment of untreated sludge
during construction of this dike. During mixing and treatment of the
sludge, the backhoe had been used to examine several extrusions that
had taken place prior to completion of treatment and mixing. Excavation
of these areas had shown sludge arising from small unmixed pockets. The
overburden of mixed material forced the lighter sludge through chimneys
to the surface from as deep as 6 feet. The small extrusions through
the cap observed in the Fall of 1974 were minimal and constitute no
environmental threat after drying and weathering. Further minimal ex-
trusions in this same area have been observed during the Summer of 1975.
Coring of the cells on October 22, 1975 provided two cores for examina-
tion that verified absence of unmixed sludge in cell center. Further,
no evidence of layering or of separation of the mixed material was evi-
dent .
Observations made through the very wet Spring and Summer of 1975
showed that erosion at the site had been minimal with respect to the
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lagoon cap and perimeter dikes and no problems of this nature are
expected. Drainage of the site and cap are excellent and no standing
pools exist to create future problems on mitigation of the oily sludge.
Some native growth was observed during the Summer of 1975 and reseeding
of the site or cap appeared unnecessary.
The drainage intercept installation was observed to be functioning
very well. During the height of the wet Spring of 1975, an estimated
flow filling half the 6-inch drain was observed. Routine monitoring
of the drainage canal by the Utah Division of Environmental Health has
indicated no problems arising from migration or diffusion of contami-
nants from the site.
The Weber County Commission had agreed to do any additional drain-
age control, or to reseed if required for erosion control. It was also
agreed that any extrusion of sludge that could be an environmental
problem would be corrected by the County Road Department.
Miya Brothers Construction Company removed the T-siphons and
skimming pond on the Ogden Bay Migratory Bird Refuge in March 1975 as
no discharge of oil was taking place and no problems were foreseen.
Operations at the lagoon site have been completed and monitoring
by EPA and Utah State Health of the site itself will be continued in
the future to provide information in developing future guidelines for
similar operations. The property owner had expressed full cooperation
with these activities and is in agreement for protection of the cap for
a period of time to be agreed to at a later date.
2. Land Farm. Following the initial emulsion and aqueous phase
disposal operations, no further rainfall took place through the Summer
and early Fall of 1974. Dr. Skujins' analysis of data indicated an
increase of hydrocarbon (Fig. A-15) and lipolytic soil organisms (Fig.
A-16) and an increase in soil respiration (Fig. A-17) during 1974.
Also, the soil nitrogen (Fig. A-18) was not depleted sufficiently to
require further application of urea in the Fall of 1974.
By the Spring of 1975 the quantity of oil in the soil had decreased
significantly and a reapplication of urea to restore nitrogen levels
was required. Dr. Skujins advised application be made at two-thirds the
initial rate. Miya conducted this operation during April 1975 and tilled
all plots to which urea had been applied. These Spring operations were
conducted sufficiently early so that there were repeated rains and snows
at the site following the application and tilling. Extensive regrowth
took place on most plots in 1975. The plots used for aqueous disposal
(0, P, Q, R) were neither treated with urea nor tilled. They appeared
to have a normal regrowth of natural vegetation during 1975. Plots
that were fertilized and tilled, for the most part, had a regrowth con-
sisting primarily of sunflower with some June grass.
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At the fourth RRT meeting on October 20, 1975, Dr. Skujins
recommended initiation of the final steps necessary to bring the
disposal phase to completion. The OSC and RRT concurred and final
cultivation began. It was not necessary to reapply urea. The land
farm was tilled by Miya Brothers, all plot access roads and berms
restored to the natural contour by grading and tilling, and the area
seeded with crested wheatgrass at a rate of 10 pounds to the acre.
Inspection of the site by Hill Air Force Base and the OSC fol-
lowing completion of the work by Miya was made and a formal termina-
tion of the permit for use of the site by EPA was agreed upon for the
Spring of 1976.
Future reports on the oil disposal at the HAFB site will be pub-
lished as a result of an EPA-DOHM research contract with Dr. Skujins
and in an EPA-Edison Laboratory contract with SCS Engineers, Inc. on
practical recommendations for oil spill debris disposal. In addition,
installation of well points to provide for sampling and obtaining data
on migration of pollutants from the former lagoon site is planned by
EPA Hazardous Waste Management Division, Headquarters. Two papers on
aspects of the operations described in this OSC report have been pre-
sented and accepted for publication.
E. DISCUSSION
With the development of an operational Plan (subpart III-F) fol-
lowing the March 22 RRT meeting, individual work items were identified
on a GANTT chart. Forethought and computation used in developing
these work items allowed us to assign milestone dates and estimate
overall project costs. Table B-9 shows that the detailed prior plan-
ning paid off in that the majority of tasks were completed essentially
on schedule and that the liquid removal and disposal operation was
concluded one week ahead of the target date. As the reader is already
aware from preceeding sections, the sludge handling method eventually
adopted could not have been either planned for or targeted at the time
of operational plan development. Therefore, sludge associated mile-
stones anticipated in earlier versions of Table B-9 were deleted before
June 1. Thereafter, this phase became a play-by-ear operation carried
through to completion as quickly as possible. Following is a brief
discussion on how operations were conducted as opposed to the tentative
operational steps anticipated on March 29 (subpart III-F).
Task 1. Eventually, 43 acres were needed for lagoon liquid
disposal. The 1.2 million gallon liquid volume calculated in
early March was augmented by inflow from precipitation and ground-
water so that the final volume needing disposal was 1.65 million
gallons.
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Because of the necessity of utilizing one of the two tractors
in use at the farm to control oil migration immediately after dis-
charge from the tanker, chemical spreading took much longer than
originally anticipated. However, this increased time did not
delay project completion.
Task 2. This task was essentially completed as called for
in the original plan.
Tasks 3 and 4. These tasks were essentially completed as
called for. Some aqueous was withdrawn before emulsion removal
commenced because of the delay caused by the land farm rock pick-
ing operation.
Task 5. Experience showed that high pressure streams of
water had little effect when trying to move or herd contaminates.
Low pressure, high volume flushing and dozer blade stripping was
necessary to bring nonsludge contaminated liquids to the appropriate
collection points.
Task 6. The only change to this step was the addition of a
permanent drain tile in the ditch before backfilling. This drain
allows for a permanent lowering of the lagoon area water table.
Tasks 7 and 8. Response to these tasks (sludge disposal) is
addressed elsewhere in this report.
Task 9. This was completed as specified. The land owner
arranged for removal of all junk from the Salvage Yard. A recycl-
ing firm from Salt Lake City completed this removal by late June.
Task 10. The only portion of this task not completed was the
placing of straw bales across the farm drainage. Observations
showed this precaution to be unnecessary.
We were fortunate in being able to establish a fully equipped field
office within walking distance of the lagoon (Fig. A-2). The field
headquarters consisted of three individual offices, a central reception
area, and adjacent kitchen and toilet facilities. One end of the build-
ing was a partially equipped analytical lab and the other end used as
storage space.
The office was furnished with five desks, several tables and two
dozen assorted chairs. This allowed, among other things, the OSC to
have a private office, each onsite engineer to have a separate desk,
and each visitor a chair to sit in and a table to work on. Five 3-line
phones were strung to the office. This combination of headsets/lines
worked quite well in conducting the day to day operations.
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Headquarters operations were augmented by a standard/legal
copier, and a telecopier for transmitting written messages from
office to office. Daily pollution reports (POLREPS) were dispatched
from the field office via the DDO communications center to RRT
members and the National Response Center. Morning reports, out-
lining previous days operations and resultant planning, were dis-
patched via the telecopier to the Region VIII office. Lagoon and
land farm operations were monitored and controlled from the field
office by the use of PST supplied portable radios.
In addition to routine office matters, several additional records
and operational files were required or found to be necessary for sub-
sequent job accounting. These were, in part:
1. Daily Journal - showing items purchased, vendor sources,
control/PO numbers, and cost;
2. A complete list of vendors utilized;
3. Competitive price quotes from potential vendors (where more
than one supplier could be found);
4. Daily contractors' expenses (Miya //I and It 2 and Electrical
Sewer Service);
5. Headquarters duty roster and personnel assignment dates;
6. Daily event log (chronology - Annex C);
7. Daily phone log;
8. Daily visitors log.
In conformance with requests from EPA and DOJ lawyers, a profes-
sional photographer was retained to document, on 16mm film, all opera-
tions. After job completion, this film, along with some 2,000 still
shots by other personnel visiting or working at the site at various
times, will serve as a complete visual documentary.
Operational plans called for, at the end of every work day, a
review and accounting by the contractor, OSC and staff of:
1. Manpower and equipment utilization for that day, with associ-
ated hourly cost;
2. Problems encountered and solutions arrived at; and
3. Projected manpower and equipment needs for the following day.
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This review allowed total flow of information between headquarters and
operations and for immediate resolution of any discrepancies in time
accounting.
The acidic nature of the lagoon contents necessitated that all
personnel working at the site be protected. Protective clothing,
rubber boots and gloves, and goggles were furnished by the EPA or DDO.
Emergency eye wash kits were placed near the lagoon. Cleaning solvents
and a fresh water pond just north of the lagoon would provide relief
from gross contamination. Luckily, no accidents occurred necessitating
use of any of these emergency measures.
The PST personnel assigned to the operation provided the bulk of
the necessary leg work. A crew of three were assigned to the OSC at
any one time. One man was assigned to operations at the farm, one to
the lagoon and the third as administrative assistant at headquarters.
The field men assisted the operations engineer in directing contractor
activities, assisted the contractor in equipment operations and repairs
and provided on-the-spot solutions to occasional tight situations
(migrating oil threatening to overflow a farm plot berm, or enticing
nearby target shooters to relocate elsewhere). The administrative
assistant helped maintain office files, identify potential vendors,
transmit communications, pick up needed supplies and maintain or
change, as needed, government vehicles.
Along with operational difficulties discussed in other parts of
this report, events, unique in themselves, which served to disrupt any
semblance of daily routine were:
1. Deer flies - pesky little varmints found in abundance in the
area. Their bites drew blood and they kept the crew slapping
themselves all day long;
2. Temperature - during early stages, snow, drizzle and mud, on
occasion, kept the crew office bound. Later, consistent
temperatures near 100° had a tiring effect on all concerned.
Heat and dust, especially after June 11, were circumvented by
early starting times, frequent work breaks, and liberal use
of water sprays;
3. Odor - luckily, the prevailing wind in the area was southerly,
dispersing fumes from the lagoon and the nearby offal pit out
over the Great Salt Lake. However, during calm or wind shift,
SO2 and putrid odors from the lagoon and offal pit permeated
the general area making breathing uncomfortable;
4. Robberies - the field office was visited three times by unan-
nounced and unwelcome visitors. Approximately $800.00 worth
of equipment was lost; and
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5. Vandalism - on one occasion, nocturnal visitors operated the
contractors' equipment. Luckily, no equipment was damaged.
V. COSTS AND RECOVERY
Between 1967 and 1972, Western Petroleum Company processed
approximately 11 million gallons of waste oil through their recycling
plant in Ogden, Utah. A feed stock rate averaging 200,000 gallons/
month generated waste products amounting to 60,000 gallons/month (30
percent of feed). These wastes in the form of free, contaminated
liquids and impregnated filter media were disposed of at the Little
Mountain Salvage Yard oil lagoon.
The Federal cleanup of the lagoon cost approximately $260,000
(Table B-10). Of this amount, $210,600 represents direct payment from
the Federal Pollution Revolving Fund. The balance, or indirect cost,
represents involvement by participating Federal agencies on a fund
reimbursable basis although not all participating agencies sought full
reimbursement.
Cost of cleanup was approximately $0.155/gallon of liquid found
at the site in 1974. The cost of cleanup was approximately $0,025/
gallon of feed stock processed through the Western Petroleum facility
during active life of the lagoon, or $0.034/gallon of reclaimed
material for the same time interval. Had proper waste disposal been
an integral part of normal operations at the Western Petroleum facility,
it is likely that the resultant disposal cost would have been signifi-
cantly less that $0,034 or $0.025/gallon, depending on which base is to
be used. Further, the need for proper waste disposal could have led
to increased feed stock utilization and recovery over and above that
which was realized at the time. In any event, proper, timely disposal
would not have generated either the environmental threat found in the
Spring of 1974 or the long and costly legal proceedings conducted coin-
cident with the following the cleanup effort.
Extensive legal discussions during 1975 and 1976 led to an out of
court settlement. On January 25, 1977 a check for $125,000 was received
by EPA and forwarded to the U.S. Coast Guard for deposit in the Revolving
Fund.
Case closed.
VI. RECOMMENDATIONS
With the resources and personnel available to the OSC through the
National Oil and Hazardous Substances Pollution Contingency Plan, day-
to-day problems could be readily managed. The critical problems in
this incident were identifying an acceptable disposal method/site, and
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the lack of guidelines for mitigation of this large volume of acid
sludge at a reasonable cost. The following recommendations are pri-
marily concerned with problems of disposal:
1. Persistent effort by local, State and Federal agencies,
working with industry groups, is required for the development
of satisfactory disposal methods. Predesignation of approved
disposal sites should be an ongoing effort.
2. Lagooning or ponding of hazardous wastes, as in the present
case, rarely is a satisfactory or permanent method of disposal
and should be discouraged. Wastes generated by industry
should be recycled or disposed of as they are generated and
costs of these operations reflected in product pricing.
3. Individual States and Federal agencies, as well as industry
groups, have given much effort to the study of the recycling
or reuse of the valuable waste oils and in minimizing the
volume of wastes generated. These efforts should be intensi-
fied .
4. Followup monitoring and applied research on disposal methods
and sites utilized in oil and hazardous materials spill cleanup,
or on disposal sites routinely utilized by industry, would pro-
vide data for establishing adequate guidelines for approved
and safe disposal practices. In this incident, two followup
contracts for research at the Little Mountain Land Farm dis-
posal site and a contract for monitoring of the acid sludge
fate at the original lagoon site have been established. These
studies will provide data and findings on which future recom-
mendations can be made.
VII. ACKNOWLEDGEMENT
The On Scene Coordinator would like to thank all individuals,
companies, contractors, and agencies who assisted in the successful
completion of this project. Although it would be unrealistic to recog-
nize each individual participant, special thanks are due Norm Chamberlain
of the Utah State Division of Health. Mr. Chamberlain was untiring in
his efforts to attain coordination and cooperation between the On Scene
Coordinator and the various State agencies, and in providing suggestions,
consultation, and evaluation at all times.
Special thanks go to the U.S. Coast Guard, partner agency to the
EPA in the United States Oil and Hazardous Materials Spill Program.
Although Ogden Bay is far removed from any seacoast, the USCG Pacific
Strike Team proved willing and able to respond effectively and rapidly.
The experience, knowledge and long days of willing effort by the Strike
-------
Force personnel contributed significantly to the overall work progress
and the smooth performance of daily activities.
The contractor who performed the bulk of the work in this cleanup
and disposal operation cannot be praised too highly. Sam Miya and the
men who worked for him on several occasions had good reason to walk off
the job because of adverse working conditions. It is doubtful another
contractor would have persevered. It was through their dedicated
efforts in assisting the OSC that the entire operation was completed
successfully.
-------
LOCATION MAP
LITTLE MOUNTAIN SALVAGE YARD LAGOON
AND
LAND FARM DISPOSAL SITE
Little Mountain
Weber River
900 South
Land Fan
Laqoon
Ogden Bay Migratory Bird Refuge
\
Ogden Bay - Great Salt Lake
\
1" = 2 miles
N
Brigham City
11
\
1-15
1200 South
Oaden
-------
-------
Figure A-J
1973 Lagoon Sampling
Scale 1" = 300'
0 -- Sanolinq Points
Fresh Water
Pond
Oil Pond
Oil Pond
Seep
Floating
Oil
Fmulsi fied
Oil
SIudqe
Floating
Oil
Emulsified
Oil
SIudqe
Previous Dike
F1 oati ng
Oil
+->
O.
QJ
C7>
D-
C
15
35*
370
CT
JD
Q.
290
1.4*
3800
6" 180 400
6" 630 66
1200 11000
6" 11 280
Emulsified 3V 2g 550
SIudqe
67 96
C
P-
Cr
cr
ro
ci
80 20
,048* .15*
CT
P-
CT
3.
CD
P.
o
Q_
CO
ro
210 1.1 26 405
,15* .19* 5*
+->
3:
•
4->
3.
JD
>s
S-
JD
o»
+->
SZ
ro
00
ro
in
cK
Q.
3
.1
5
100
1000
3000 13 16
29 22 71 1.3 7.7
56 28 74 .3 4.8
130 43 290 1.7 9.1
12 .08 5
75
17 20 54 .1 4.9 410 2 .02 5
36 28 58 .3 1.7
3200 9 3300 6.6 20
-------
-------
Figure A
Organization
-5
-------
SLUDGE DISPOSAL SITE
— - .TTI F MOUNTAIN
SOUTH TIP OF LITTLE
\lABOCH »r
mspos'L site
-------
Figure A-7
-------
Figure A-8
Lagoon Liquid Flow During Emulsion Concentration
1" = 110'
N
/
\
Irrigation Canal
-------
Is!an d
Irrigation Canal
-------
Figure A-10
US ENW?0NM£N7AL PROrec
topoo^a
| , ,r SEC 19,T6N,R3W,$L6
SctLf
\\vvi //:""
r
/ /•
\ \
-------
Figure A-ll
Original Lagoon Outline with Dike Overlay
-------
Figure A-l2
Final Placement
1" =
Irrigation Canal
-c —
-------
-------
-------
XI o6
320 .
Plot
A-N O
S ~
U a
Feb. June Oct
- 1974 -
Figure A-15
Number of Hydrocarbon-Uti1izing Organisms for
-------
Plot
A-N
S
U
o
~
A
\
\
A- -A
»
June
1974 -
/\
/
/
'/
•A
1 1
Oct.
A'1
I
Feb.
June
- 1975
7
Oct.
Figure A-16
Number of Aerobic Bacteria
-------
Plot
- 1974 - - 1975 -
Figure A-17
Soil Respiration Rate
-------
Plot
A-N O
S ~
U A
- 1974 - - 1975 -
Figure A-18
-------
Table B-l
Summary of Bids
nil Lagoon Clean-up at Little Mountain Salvage Yard
Bid Item #1 opened on April 3, 1974
$/Hour for Bidder"1", per hour cost
Equipment Item with Operator 1 2 3 5 6 7++
D-6 Dozer, or equivalent
35.00
51.00
35.00
29.55
39.00
26.00
Sludge hauling vehicle, 8 yd min.
25.00
34.50
25.00
29.44
23.50
16.50
10-wheeler dump
25.00
34.50
30.00
29.44
21.50
17.50
Dragl ine
40.00
55.00
35.00
30.78
41.00
24.00
Frontend loader, 3 yd min.
36.00
50.00
35.00
39.08
30.00
26.00
C-12 Road Patrol
36.00
36.00
30.00
33.74
29.00
24.00
Cultivator, disker, spreader
35.00
32.00
36.00
24.68
21.00
18.50
Laborer
14.75
10.00
8.50
7.42
9.25
7.50
+ Mo Bid from Bidder #4.
-------
Table B-2
Summary of Bids
Oil Lagoon Clean-up at Little Mountain Salvaqe Yard
Bid Item #2 opened on April 3, 1974
Bidder* Lump Sum"t"+++ Overage, per gallon
1 30,000 .04
2++ 16,000 .026
3 75,000 .10
4 45,000 .06
7+++ 3,000 .004
+ Bidder #5 submitted bid day followinq bid openina. Therefore
bid invalid. No Bid from Bidder #6.
++ Bid rejected for inadequate equipment after inspection by EPA
engi neer.
+++ Bidder #7 withdrew bid on Item #2 due to computation error.
++++ All bids rejected as being unresponsive, due to cost exceeding
-------
Table B-3
Summary of Bids
Oil Laqoon Clean-up at Little Mountain Salvage Yard
Bid Item #2 opened on April 12, 1974
Bidder Lump Sum Overage, per gallon
1 19,900 0.0275
2 25,000 0.04
3 17,875 0.021
4* 16,975 0.004
5 25,000
* Bidder #4, Miya Brothers Construction Company awarded contract
-------
Table B-4 Suggested Application Rates
Plot
Designation
Area Acres
Material
Meterial per
Plot
r
0
c
a
r+
O
Hi
f-*
c
H
n
0
CU
0
3!
to
C/N Ratio
1
Theoretical
N
|
c:
~1
re
ru
X-
Ln
»-S
P 2)
Theoretical
I
Application
Rate
A
6.9
emulsion
75.700
gal
1200
kg
20:1
5300
kg
12,600
kg
570
kg
10,800 pn1/6"/acrc
R
10.97
cmulsion
119,000
gal
1900
kg
50:1
3310
kg
7,370
kg
330
kg
"
C
8.04
emulsion
86,600
gal
1400
kg
50:1
2420
kg
5,360
kg
240
kg
11 ii m
D
. 73
emulsion
7, 884
gal
140
kg
50:1
220
kg
540
kg
24
kg
Mil II II
E
0.96
emuIslon
10,368
gal
140
kg
10:1
1455
kg
2,700
kg
120
kg
II II II
F
0.87
emuIsion
18,792
gal
250
kg
20:1
1320
kg
3,600
kg
160
kg
21,600 gal/6"/acre
C
0.91
emulsion
19,656
gal
250
kg
50:1
550
kg
1,340
kg
60
kg
II II II
H
1.08
sludge
160 cu.
, yd.
2200
kg
20:1
3890
kg
8,000
kg
360
kg
60 metric tons/C'/ncre
I
.96
sludge
160 cu.
. yd.
2200
kg
50:1
1400
kg
3,200
kg
144
kg
11 11 ti
J
1.2
sludge
190 cu,
. yd.
2200
kg
50:1
1730
kg
3,200
kg
144
kg
11 it ii
K
1.02
sludge
160 cu.
. yd.
2200
kg
10:1
7340
kg
16,000
kg
720
kg
i,
L
0.9/i
emulsion
20,302
gal
350
kg
20:1
14 70
kg
3,240
kg
145
kg
10,800 gal/fi'Vacre
M
0.84
emulsion
18,144
gal
300
kg
50:1
508
kg
1,200
kg
54
kg
ii 11 11
N
0. 84
emulsion
18,144
ga 1
300
kg
100:1
254
kg
600
kg
27
kg
•1 it n
0
app. 17
rJ udge
1000 metric tons
17,100
kg
20:1
30,000
kg
67,000
kg
3,000
kg
60 metric t/6'V^cre
1) Includes approx, 125 kg Ca(OH)2 per acre 6" to stabilize soil pit
2) Should be applied as conmterc la 1.1 y available potassium phosphate. Theoretical value should be multiplied by
10 to obtain approximate commercial weight of weight of fertilizer (0-10-0)
3) 1 cc pure oil per 30 cc soil
-------
Table B-5. Little Mountain Farm Plot Size and Application Rates.
Phosphate
Urea - '74
Urea - '75
Emulsi on
Aqueous
Lime
(20%)
(45% N)
(45% N)
PI ot
Acres
(gal/acre)
(gal/acre)
(1bs/acre)
(1bs/acre)
(1bs/acre)
(1bs/acre)
A
6.90
16,030
2,730
800
250
1 ,180
735
B
10.97
19,740
1 ,590
930
250
1 ,180
735
C
8.04
14,350
2,050
935
250
1 ,180
735
D
0.73
23,030
11 ,080
935
250
1 ,180
960
E
0.96
23,030
11 ,080
935
500
2,360
1 ,540
F
0.87
25,660
14,930
1 ,680
750
3,540
2,425
G
0.91
25,660
14,930
1 ,660
250
1 ,180
850
H
1.08
23,920
14,620
1 ,900
500
2,360
1 ,430
I
0.96
23,920
14,620
1 ,900
500
2,360
1 ,465
J
1 .20
23,920
14,620
1 ,900
750
3,540
2,700
K
1.02
23,920
14,620
1 ,900
750
3,540
2,345
L
0.94
19,520
13,520
1 ,670
750
3,540
2,095
M
0.84
19,520
13,510
1 ,670
500
2,360
1 ,675
N
0.84
19,520
13,510
1 ,670
250
1 ,180
840
S
4.20
9,780
11,020
-
-
-
-
J**
0.99
-
-
-
-
-
-
0-R
4.4
-
150,810*
-
-
-
-
Dust Control 47,825*
Total 45.85 721,320 935,335 - All plots tilled to a depth of five (5) inches.
* 50 lbs. of lime for pH control was added to each truck!oad of aqueous solution as it was pumped
from the lagoon.
** Contains approximately 630 cubic yards of oil-stained soil stripped from exposed surfaces of
-------
Core Segment
Depth, inches
Oil and Grease
API, %
pH
5% slurry
0-6
49.0
2.20
6-12
69.3
2.15
12-18
58.7
2.10
18-24
55-9
1.90
24-30
54.4
2.10
30-36
33-9'
1.95
36-42
3-5
3-95
42-48
3-3
4.25
Table B-6. Analysis of 6-inch Segments of a 4-foot Coring
-------
Analysis
Acid
Sludge 1
Acid
Sludge 2
Aqueous
Layer
Oil Emulsion
Layer
Pb, ppm
6596
953
1.18
258
Cd, ppm
8.3
1.2
0.01
35.9
Ni, ppm
5.8
0.1
0.19
3.2
V, ppm
55.9
6.7
1.50
0.35
Ba, ppm
2560
111
no anal.
2080
Zn, ppm
1450
185
8.30
4.6
Fe, ppm
548
15
71.5
125
pH
5% slurry
2.2
1.9
3.5
2.7
Oil-Grease
(API),%
75.5
48.6
(65 ppm)
45.7
Table B-7. Analysis of Little Mountain Salvage Yard Acid Sludge
-------
HYDROCARBON
Iso-butane
Methane
Ethane
1-Butene
trans-2-Butene
ci s-2-Butene
CONCENTRATION, ppm
129.2
37.5
13.4
2.1
5.0
8.5
Table B-8. Volatile Hydrocarbon Concentrations above Disturbed
-------
June
o
<;
T
Preoaration
Soread Chemicals-
Spread Emulsion
Spread Aqueous
Spread Residue
Spread Contain. Soil
**
Tillinq
General Site Work——
Circulate Emulsion
>*«
General Site Work
Junk Removal
Pump Emulsion
Pump Aqueous
Site Drainaqe
Flush Resid. liquids-
Sludge Consolidation-
Site Dress And Secure-
Snow, Rain, Mud-
w
:kxxxxx
X' 1
(X' !
I
1
1
1
1
,
l
i
v^xx1
4cnhi xx
¦| 1
\
i|'
1XXX
jAk1 1
i
i |
r 1
X
X
XX'
'' X 1
1
1
1
1. 1.1 '
, ¦ |: i
I i 1
,
¦¦ p
X
X XXI 1 1
; |
X
I
1
Xk: r
| June
July
August
o
o
a
<
Perimeter Dike Const.-
Internal Dike Const.—
Site Drainage
Dragl ine M1xi ng—
Dozer fiixinq
RototlIIing
Cappi na
' 1 1 Ixxx 1
1
1
1
1
I
11
1
i
1
1
>
WIVIV^
iwbM
, v
1
:«
i ¦
1
1
1
.
i
i
1
1 '
XJQXI XXtCXMX
< 1
I
1
1'
i
' 1
i
1
1
,
Ixx 1 XXH
XXX |
i
vv I
r .
1
, j.
1
1
'
1
X 1 xx>
xx taxx
xxxx
X! XXKI
¦
1 I
' 1 !¦
1
LL'
1 .d
XX X XXX
xxx:
x x;
:K
X
¦1-
i
1
1
1
|
1
)
1
1 X! X
KXXXII
i '
1
i
t
1
j
'
1
i
i
¦ !
i
1
i
i
1 XXXX
July
1 August
* Urea application, April 1975
** Restoration, tilling, and reseedicg, October 1975
*** T-siphons removed from refuge, March 1975
Table B-9
Chart of Daily Operations (X - day of operation,
-------
TABLE B-10
COST SUMMARY
A. DIRECT COSTS TO FEDERAL POLLUTION REVOLVING FUND
1. Consultant & Contracts, FY-74, 75
2. Supplies & Equipment, FY-74, 75, 76
3. Payroll, FY-74, 75
4. Paid to other Federal Agencies
5. Region VIII Travel
6. Headquarters Travel
B. INDIRECT COSTS - NORMAL AGENCY OPERATING ACCOUNTS
$124,690.86
59,438.73
7,779.09
2,075.68
11 ,473.43
5,134.58
210,592.37
1. Supplies & Equipment, before 3/20/74
2. Payroll
3. Region VIII Travel, before 3/20/74
4. Headquarters Travel, before 3/20/74
5. NERC - Las Vegas
4,214.00
37 ,771.26
2,156.70
2,065.31
2,986.00
49,193.27
$259,785.64
COST BY WORK CATEGORY (Approx)
A. EMERGENCY AND PROTECTIVE MEASURES
B. LAGOON SITE
$ 4,200
1. Preparation & Emulsion Concentration 22,800
2. Liquid Pumping, Hauling & Spreading 21,700
3. Sludge Consolidation & Perimeter Diking 19,900
4. Internal Diking - Sludge Treating & Mixing 32,900
5. Capping & Contouring 8,100
C. LAND FARM SITE
1. Site Preparation 7,000
2. Chemicals (lime, phosphate, urea) 13,600
3. Tilling & Seeding (1974/1975) 19,300
4. Consultant & Laboratory Support 25,600
D. OPERATIONS
105,400
65 ,500
1. Sampling
2. Supplies
3. Overhead
4. Other Federal
& Analysis
& Documentation
Agencies (DOHM, PST)
2,600
12,500
29,100
12,500
56 ,700
E. INDIRECT COSTS (Federal Employee Salaries)
28,000
-------
ANNEX C
CHRONOLOGICAL LIST OF EVENTS
Little Mountain Salvage Yard Oil Lagoon
2/14 George Rice, OSC, arrived on scene.
2/13 Initial situation analysis and arrangements for equipment
2/21 and personnel to be on standby alert for action in case of
major dike failure and/or significant discharge.
2/21 Skimming baffles across canal inside Refuge.
2/22 Start construction of catch basin in canal inside Refuge.
2/23 Installation of two 18-inch T-siphons at catch basin.
2/25 Finish construction of catch basin.
2/27 One hundred twenty-five sandbags filled and sent to lagoon
site (stockpile).
2/28 (a) Additional dike added to and around catch basin.
(b) Arrival of USCG Pacific Strike Team member with ADAPTS
pumping equipment.
3/1 (a) One hundred twenty-five sandbags filled and sent to
lagoon site.
(b) Sandbags placed on top and face of lagoon dike (west
face) .
3/2 (a) One hundred twenty-five sandbags filled and sent to
lagoon site.
(b) Sandbags placed on top and face of lagoon dike (west
face).
3/3 Heavy snow.
3/4 Sandbags placed on top and face of lagoon dike (west face).
3/5 One hundred twenty-five sandbags filled and sent to lagoon
site.
3/19 (a) Moving junk on southwest corner to provide access to
lagoon site.
(b) Removal of pools of oil below dike.
3/20 (a) Moving junk on southwest corner to provide access to
lagoon site.
-------
(b) Removal of pools of oil below dike.
3/21
3/22
3/23
3/25
3/26
3/27
3/28
3/29
4/1
4/2
4/3
4/4
4/5
(a) Building berm along west property line to control runoff
through depression onto adjoining property.
(b) Removal of oil from pools below eastern dike.
Removal of oil from pools below western dike.
Removal of oil from pools below western dike.
Fabricate four and install three 24-inch T's at catch basin
on canal.
Construction (fill) of roadway for access to lagoon center
island.
Construction (fill) of roadway for access to lagoon center
island.
Construction (fill) of roadway for access to lagoon center
island.
Construction (fill) of roadway for access to lagoon center
is
(a
(b
(c
(a
(b
(a
(b
(a
(b
(a
(b
and.
Construction (fill) of roadway for access to lagoon
center island.
Weber County crews upgrading roadway from County highway
to lagoon site.
Permit from Hill Air Force Base to use south end of
Little Mountain for land farm operations.
Establish EPA Field Headquarters on site.
Additional fill on roadway for access to lagoon center
island.
Additional fill on roadway for access to lagoon center
island.
Rain, snow.
Additional fill on roadway for access to lagoon center
island.
Opening of bids at Great Basin Engineering.
Additional fill on roadway for access to lagoon center
island.
Placement of end braces for skimming wier used to circu-
late emulsion into North Pond.
-------
4/7 Transferring aqueous solution from bottom of North Pond,
discharging across access road to area on east side of
lagoon center island.
4/8 (a) Transferring aqueous solution form North Pond.
(b) Carbide cannon placed on island and activated for bird
scare tactics.
4/9 (a) Land Farm Site:
(1) Ripping, ground breaking, road construction.
(2) Installation of gate through fence row on eastern
edge of Hill AFB property.
(b) Lagoon Site:
(1) Transferring aqueous solution from North Pond.
(2) Flasher barricades erected around lagoon for bird
scare tactics.
4/10 Lagoon Site: Received 4 to 6 inches snow.
(a) Multicolor banners strung for bird scare tactics.
(b) Transferring aqueous solution from North Pond.
4/11 Lagoon Site: Muddy. Transferring aqueous solution from
North Pond.
4/12 Lagoon Site: Muddy.
(a) Transferring aqueous solution from North Pond.
(b) Completed installation of skimming wier for return flow
of emulsion into North Pond.
4/13 Lagoon Site:
(a) Skimming wier opened.
(b) Circulating emulsion around island, across skimming wier
into the North Pond by continuous flushing action of
aqueous solution pumped from the bottom of the North
Pond.
4/14 Lagoon Site: Circulating emulsion into North Pond.
4/15 (a) Land Farm Site: Ripping, ground breaking and road con-
struction.
(b) Lagoon Site:
(1) Circulating emulsion into North Pond.
(2) Removal of junk and debris from the area around the
lagoon so that work could proceed.
4/16 (a) Land Farm Site: Ripping, ground breaking.
(b) Lagoon Site:
(1) Circulating emulsion into North Pond.
(2) Removal of junk and debris from work area.
-------
4/17 (a) Land Farm Site:
(1) Ripping and ground breaking.
(2) Removing larger rocks from tilled farming area.
(3) Initiate spreading of lime for pH control,
(b) Lagoon Site:
(1) Circulating emulsion into North Pond.
(2) First string of straw/hay bales placed in a line
from eastern lagoon border to center of island to
isolate areas of lagoon surface which had been
either flushed or wind-blown clean of floating
emulsion layer.
4/18 (a) Land Farm Site:
(1) Spreading first loads of treated aqueous solution.
(2) Ripping and ground breaking.
(3) Removing larger rocks from farming area.
(4) Lime spreading.
(b) Lagoon Site:
(1) Pumping aqueous solution from bottom of North Pond
into tanker to which has been added one 50-pound
bag of lime for pH control.
(2) Circulating emulsion into North Pond.
4/19 (a) Land Farm Site:
(1) Spreading treated aqueous solution.
(2) Removing larger rocks.
(3) Spreading lime and urea.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Circulating emulsion into North Pond.
(3) Pumping aqueous solution.
4/20 (a) Land Farm Site:
(1) Spreading treated aqueous solution.
(2) Removing larger rocks.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Circulating emulsion into North Pond.
(3) Pump aqueous liquid.
(4) Second string of bales to isolate area cleaned of
floating emulsion.
4/22 (a) Land Farm Site:
(1) Spreading treated aqueous solution and emulsion.
(2) Spreading lime and urea.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
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(2) Circulating emulsion into North Pond.
(3) Pumping aqueous liquid and emulsion.
(4) Dig drainage ditch.
4/23 (a) Land Farm Site:
(1) Spreading lime and urea.
(2) Spreading emulsion and treated aqueous solution,
(b) Lagoon Site:
(1) Pumping emulsion and aqueous solution.
(2) Removal of junk and debris from work area.
(3) Circulating emulsion into North Pond.
(4) Dig drainage ditch.
4/24 (a) Land Farm Site:
(1) Spreading emulsion.
(2) Spreading lime.
(b) Lagoon Site:
(1) Pumping emulsion.
(2) Removal of junk and debris from work area.
(3) Circulating emulsion.
4/25 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading lime.
(b) Lagoon Site:
(1) Removal of junk and debis from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing residual emulsion into pumping area using
aqueous solution and some fresh water from ponded
area just north of lagoon.
4/26 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading lime.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing of residual emulsion.
4/27 (a) Land Farm Site: Spreading lime.
(b) Lagoon Site: Flushing residual emulsion.
4/29 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading lime.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
-------
4/30 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading phosphate.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing residual emulsion.
5/1 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading phosphate.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing residual emulsion.
5/2 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading phosphate.
(3) Constructing berms around land farm plots to control
drainage into and from farm area.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing residual emulsion.
5/3 Rain.
(a) Land Farm Site:
(1) Spreading treated aqueous solution.
(2) Spreading phosphate.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping aqueous solution.
(3) Flushing residual emulsion.
5/4 Muddy.
(a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading phosphate.
(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion.
(3) Flushing residual emulsion.
5/6 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading lime.
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(b) Lagoon Site:
(1) Removal of junk and debris from work area.
(2) Pumping emulsion and aqueous solution.
(3) Flushing residual emulsion.
5/7 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading urea.
(b) Lagoon Site:
(1) Pumping emulsion and aqueous solution.
(2) Flushing residual emulsion.
5/8 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading urea.
(b) Lagoon Site:
(1) Pumping emulsion and aqueous solution.
(2) Draining remaining liquids.
5/9 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading urea.
(b) Lagoon Site:
(1) Pumping emulsion and aqueous solution.
(2) Draining remaining liquids.
5/10 (a) Land Farm Site:
(1) Spreading emulsion and treated aqueous solution.
(2) Spreading urea.
(b) Lagoon Site:
(1) Pumping remaining liquids.
(2) Stripping and stockpiling oil stained earth and
backfilling cleaned areas.
5/13 (a) Land Farm Site:
(1) Tilling land farm plots with rotovater to thoroughly
mix top 5 inches of soil and emulsion.
(2) Spreading urea.
(3) Cleanup of areas where small amounts of emulsion and
treated aqueous solution were dumped outside of or
ran from land farm plots.
(4) Reestablish berms around land farm plots for surface
drainage control.
(b) Lagoon Site:
(1) Consolidating sludge from lagoon edges and North
Pond area to reduce overall surface area.
(2) Stripping and stockpiling of oil stained earth.
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5/14 (a) Land Farm Site:
(1) Tilling with rotovater.
(2) Spreading urea.
(b) Lagoon Site:
(1) Consolidation of sludge.
(2) Moving old saturated dike into edge of remaining
sludge and backing up with clean fill to provide
stability to periphery of sludge pond.
(3) Hauling oil stained earth to newly prepared land
farm plot.
5/15 (a) Land Farm Site:
(1) Tilling with rotovater.
(2) Spreading urea.
(b) Lagoon Site:
(1) Consolidation of sludge.
(2) Hauling oil stained earth.
5/16 (a) Land Farm Site:
(1) Tilling with rotovater.
(2) Spreading urea.
(b) Lagoon Site: Consolidation of sludge from North Pond.
5/17 (a) Land Farm Site:
(1) Tilling with rotovater.
(2) Spreading urea.
(3) Spreading of oil stained earth in uniform layer,
(b) Lagoon Site:
(1) Consolidation of sludge from North Pond.
(2) Establishing positive site open air surface drainage
away from sludge pond.
(3) Construction of berm around eastern edge of sludge
pond to protect against outflow caused by rising
sludge level.
5/20 Rain
5/21 Muddy
5/22 (a) Land Farm Site:
(1) Tilling with rotovater.
(2) Reestablishing and adding to land farm site berms
to control surface drainage.
(3) Removal of junk and debris inadvertently transported
to land farm site along with oil stained earth.
(b) Lagoon Site:
(1) Consolidation of sludge from North Pond.
-------
(2) Open air site drainage.
5/23 (a) Land Farm Site:
(1) Tilling with rotovater
(2) Junk and debris removal.
(b) Lagoon Site:
(1) Consolidation of sludge from North Pond.
(2) Construction of catch basin on western property
line to prevent any discharge of oil which may
surface in the future because of high ground water
levels or precipitation runoff.
5/24 Lagoon Site: Consolidation of sludge from North Pond.
6/11 Lagoon Site: Construction of perimeter dike around sludge
pond for permanent containment.
6/12 Lagoon Site: Perimeter dike construction.
6/13 Lagoon Site: Perimeter dike construction.
6/14 Lagoon Site: Perimeter dike construction.
6/17 Lagoon Site: Perimeter dike construction.
6/19 Lagoon Site: Perimeter dike construction.
6/20 Lagoon Site:
(a) Perimeter dike construction.
(b) First internal dike construction initiated.
6/21 Lagoon Site: Perimeter and internal dike construction.
6/22 Lagoon Site: Perimeter and internal dike construction.
6/24 Lagoon Site: Perimeter and internal dike construction.
6/25 Lagoon Site: Perimeter and internal dike construction.
6/26 Lagoon Site: Perimeter and internal dike construction.
6/27 Lagoon Site: Perimeter and internal dike construction.
6/28 Lagoon Site: All diking completed.
7/1 Lagoon Site:
(a) Consolidation of sludge from old North Pond area.
-------
(b) Grade for overall site drainage removing old, northern
lagoon dike.
7/8 Lagoon Site:
(a) Mixing Cell #2 sludge with earth utilizing dragline.
(b) Contouring old North Pond area for site drainage.
7/9 Lagoon Site:
(a) Mixing Cell it2 sludge with earth.
(b) Installing subsurface drain around eastern lagoon boundary.
(c) Hauling l1^ inches of crushed rock for drain.
(d) Contouring North Pond area for drainage.
7/10 Lagoon Site:
(a) Mixing Cell //2 sludge with earth.
(b) Installing subsurface drain.
(c) Hauling 1^ inches of crushed rock for drain.
7/11 Lagoon Site:
(a) Mixing Cell #2 sludge with earth.
(b) Operators wearing breathing masks.
(c) Waste concrete pipe and block dumped into Cell #1.
(d) Complete installation of subsurface drain.
(e) Hauling l1^ inches of crushed rock for drain.
7/12 Lagoon Site:
(a) Mixing Cell it2 sludge with earth.
(b) Waste concrete pipe and block into Cell //l.
7/15 Lagoon Site:
(a) Complete mixing of Cell //2 sludge.
(b) Started mixing sludge in Cell #3 and cut/fill area.
(c) Residual junk from salvage yard added to Cell #1 for fill.
7/16 Lagoon Site:
(a) State Health Department measurement of SO2 levels
(140 ppm).
(b) Mixing Cell #3 sludge.
(c) Mixing cut/fill sludge.
7/17 Lagoon Site:
(a) Mixing Cell #3 sludge.
(b) Reworking (1 hour) Cell it2 mixture with track dozer (D-8) .
7/18 Lagoon Site:
(a) Mixing Cell it2 sludge.
(b) Cell #3 temperature survey.
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7/19 Lagoon Site: Mixing Cell #3 sludge.
7/20 Lagoon Site:
(a) Mixing Cell it3 sludge.
(b) Backhoe survey of Cell //2.
7/22 Lagoon Site:
(a) Mixing Cell //3 sludge.
(b) Importation and stockpiling fill.
7/23 Lagoon Site:
(a) Mixing Cells #1 and //3 sludge.
(b) Replowing Cell //2 with dozer.
(c) Importation and stockpiling fill.
7/24 Lagoon Site:
(a) Mixing Cells //I and //4 sludge.
(b) Importation and stockpiling fill.
7/25 Lagoon Site:
(a) Mixing Cells #1 and //4 sludge.
(b) Importation and stockpiling fill.
7/26 Lagoon Site:
(a) Mixing Cells til, #3, //4, and #5 sludge.
(b) Importation and stockpiling fill.
7/29 Lagoon Site:
(a) Mixing Cells #3, //4, and #5 sludge.
(b) Importation and stockpiling fill.
7/30 Lagoon Site:
(a) Mixing Cells //4 and #5 sludge.
(b) Importation and stockpiling fill.
7/31 Lagoon Site: Mixing Cell #4 sludge.
8/1 Lagoon Site:
(a) Initial sludge/clay mixing completed.
(b) Reworking all cells with dozer.
(c) Partial contents Cell //4 transferred to Cell //5.
(d) Removal of larger junk and rock fragments from Cell #1
preparatory to mixing with Raygo Gator.
8/2 Lagoon Site:
(a) Reworking all cells with dozer.
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(b) Finish moving one-half of the contents Cell //4 into
Cell 95.
(c) Rock and junk removal.
(d) Gator used in Cells //3 and //4.
8/3 Lagoon Site:
(a) Gator operating in Cells #1, #3, //4, and //5.
(b) Dozers stripping mixed and treated sludge to get at
lower strata.
8/6 Lagoon Site:
(a) Gator operating across all cells.
(b) Dozer stripping mixed and treated sludge.
8/7 Lagoon Site: Cells //l, #2, #3, and //4 completed and sloped
for finished contour.
8/8 Lagoon Site:
(a) Meeting with County to discuss Fall work.
(b) Raygo in Cell //5.
8/9 Lagoon Site:
(a) Cell #5 completed and sloped for drainage.
(b) T-siphon removed.
8/12 Lagoon Site: Cap placement.
8/13 Lagoon Site: Cap placement.
8/14 Lagoon Site: Cap placement.
8/15 Lagoon Site: Cap placement.
8/16 Lagoon Site: Shave dike top and contour all slopes for
drainage and erosion control.
8/17 Lagoon Site:
(a) Shave dike top and contour all slopes for drainage and
erosion control.
(b) Survey site to check slopes.
(c) Close Field Headquarters.
8/21 Lagoon Site: U.S. Coast Guard Pacific Strike Team vacated
site.
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ANNEX D
PARTICIPANTS
U.S. EPA
1860 Lincoln Street
Denver, Colorado 80295
George B. Rice, On Scene Coordinator (OSC)
*
Floyd D. Nichols, Deputy OSC and Operations Engineer
*
John A. Green, Chairman, Region VIII RRT
3/1 - Project evaluation
Dean Norris, Intergovernmental Relations
3/1 - Project evaluation
Don Dubois, Deputy Regional Administrator
4/2 - Project evaluation andapress conference
Donald Henderson, NOAA Meteorologist assigned to A&HM Division
2/14-15 - Coordinate NWS with RRT
Peter Larsen, Chemical Engineer
2/14-15 - RRT briefing
C. Alvin Yorke, Chief, Emergency Planning and Response Branch
3/1 - Site and work progress evaluation
3/19_2i - " " " " "
3/25 — M 11 11 11 M
f 3—5 — " n 11 M "
4/23 — 1' 11 M 11 "
4/24-25
1 j 22 — " " " " "
Charla Stewart, Clerk-Typist, Management Division
3/6-8 - Temporary Office Secretary
Rich Lathrop, Public Information Specialist, Public Affairs Division
3/2 - Public information dissemination
3/29-30
-------
Richard M. Jones, Chemist, S&A Division
3/16-17 - Operational plan development
5/7 - Site evaluation and monitor
Larry P. Gazda, Regional Solid Waste Representative, A&HM Division
3/18-19 - Disposal site selection
4/16-19 - Disposal Site Engineer
4/30 - Disposal evaluation
Max Orem, Sanitary Engineer, Water Division
3/25-26 - Disposal method consultation
Alan B. Lewis, Chief, Financial Management Branch
4/3-4 - Contracts and procurement methodology
Doug Skie, Civil Engineer, S&A Division
4/22-25 - Disposal Site Engineer
Keith Schwab, Director, S&A Division
5/24-25 - Site and work progress evaluation
Owen Boe, Sanitary Engineer, Water Division
5/29-5/3 - Disposal Site Engineer
Bill Tabor, Mechanical Engineer, S&A Division
5/6-9 - Disposal Site Engineer
Sam Landis, Federal Regional Council Liaison Officer
4/3-4 - Project Contracting Officer for oil removal contract
5/12 — " " " " " "
U.S. EPA
Spill Prevention Control Branch, WH-548
401 M Street S.W.
Washington, D.C. 20460
Hal Snyder, Sanitary Engineer
* - Site and work evaluation and Operations Engineer
Thomas Charlton, Mechanical Engineer
3/1-15 - Project evaluation and equipment selection
Ken Adams, Biologist
4/3-12 - Equipment selection and treatment methods
-------
Doug Heath, Visual Information Specialist
4/9-12 - Headquarters documentation
4/26-27
7/16-19
Hans Crump-Weisner, Chemist
4/19-25 - Analysis
Larry London, Chemical Engineer formerly with S&A Division
c/o 220 Las Vegas Trail North
Fort Worth, Texas 76108
3/2-3 - Sampling and site monitoring
Debbie Alder, Clerk-Typist, formerly with Management Division
U.S. EPA
Public Affairs
1200 Sixth Avenue
Seattle, Washington 98101
3/15-18 - Temporary Secretary
Tom Rogers, Lawyer, formerly with Enforcement Division
P.O. Box 2147
Aspen, Colorado 81611
3/6-7 - 0SC Counsel
3/11-13
3/15-20 - "
5/10
5/15 - "
Dave Goode, Clerk, formerly with Management Division
1673 Clinton Street
Aurora, Colorado 80010
3/21-22 - Procurement
4/1-2
Diane L. Spangler
Rt. 2, Box 235
Brigham City, Utah 84302
* - Secretary
Jim Walpole, Lawyer
Current address unknown, formerly with U.S. DOJ, Washington, D.C. 20530
3/10-17 - Case documentation and preparation
-------
Mike Roulier, Physical Chemist
U.S. EPA, NERC
5555 Ridge Avenue
Cincinnati, Ohio 45268
4/3-4 - Treatment methods
5/15
Leo McCarthy, Chemist
Industrial and Environmental Research Laboratory
Edison, New Jersey 08817
4/3-4 - Treatment methods
A1 Pressman
U.S. EPA, NERC
P.O. Box 15027
Las Vegas, Nevada 89114
2/18 - Site photo recon. flight (not in direct attendance)
U.S. Coast Guard
Pacific Strike Team
c/o Coast Guard
Yerba Buena Island
San Francisco, California 94130
Jim O'Brien
2/27-28 - Site evaluation, emergency actions and preparation
Roland Miller
2/27-28 - Site evaluation, emergency actions and preparation
Max Folkerts
2/28-3/10 - ADAPTS staging and lagoon monitor
4/3-5/5 - Lagoon operations monitor
Ron Utzig
4/18-5/5 - Administrative Assistant
Jerry Sanders
4/18-5/5 - Land farm operations monitor
John Griffen
3/10-4/3 - Lagoon operations monitor
5/6-6/2 - Administrative Assistant
-------
Mike Patterson
5/6-5/24 - Land farm operations monitor
A1 Veltri
5/6-5/24 - Lagoon operations monitor
Bob Miscovich
6/2-8/21 - Administrative Assistant
Cmdr. John Wiechert
2/14-15 - Operation Advisor - RRT member
o /o 1 o *5 _ " ii n ii
5/23-24
10/20/75 -
U.S. Coast Guard
12th Coast Guard District
630 Sansome Street
San Francisco, California 84126
Cmdr. Win Risinger
2/14-15 - Operations evaluation - RRT member
3/21-23
Cmdr. Gordon Dickman
5/23-24 - Operations evaluation - RRT member
Earl Downend
4/3-4 - Contracts and Revolving Fund usage
U.S. Army
Corps of Engineers
135 South State, Room 342
Salt Lake City, Utah 84111
Kell Cloward, Civil Engineer
2/20, 5/17, 5/24 - Dike evaluation
Stuart Bonnemort, Civil Engineer
5/21 - Dike evaluation
Jim Rubl, Civil Engineer
5/21 - Dike evaluation
-------
U.S. Air Force
Hill Air Force Base, Utah
Col. Hall, Rase Commander
Various times - Disposal site usage and USCG equipment transfer
Col. Porter, Facilities Section
Various times - Land farm site usage
Occupational Safety and Health Administration
Utah State Division of Health
44 Medical Drive
Salt Lake City, Utah
Jeff Throchmorton
6/18 - Personnel safety
7/16
Howard Schultz
6/18 - Personnel safety
7/16
Ray Handie, Civil Engineer
DOI - Bureau of Reclamation
125 South State
Salt Lake City, Utah 84111
6/6 - Dike evaluation
7/19
8/15
Jerry Hillier, Salt Lake District Manager
DOI - Bureau of Land Management
125 South State Street
Salt Lake City, Utah 84111
4/23 - Disposal site selection
Ernest Bertagnolli
DSA - Defense Depot, Ogden, Utah
Various time - Contracts, bid package, equipment and material storag
-------
U.S. Fish and Wildlife Service
Room 2215, Federal Office Building
Salt Lake City, Utah 84138
Bill Ritter, Wildlife Specialist
5/24 - Wildlife impact
Chuck Heumier, Wildlife Specialist
4/5 - Bird rehabilitation
4/8 - Bird scare tactics
Utah State Division of Health
44 Medical Drive
Salt Lake City, Utah 84110
Norm Chamberlin (deceased), Water Quality Division
Various times - Methodology, disposal site selection,
site monitoring, and Utah liaison to RRT
Russel Hinshaw, Water Quality Division
Various times - As above
Dennis Downs, Solid Waste Division
Various times - Disposal
Marvin Reid, Solid Waste Division
Various times - Disposal
Marv Maxell, formerly with Wildlife Resources
Various times - Methodology and wildlife impact
Utah Division of Wildlife Resources
1596 West North Temple
Salt Lake City, Utah
Noland Nelson
Various times - Disposal site selection, refuge catch
basin installation, and wildlife impact
Larry Dalton
Various times - Wildlife impact
-------
Weber County
City and County Building
Ogden, Utah
Boyd Storey, County Commissioner
Various times - Methodology, past history of site
and use of County resources
Keith Jensen, County Commissioner
Various times - See above
Monte Baily, County Commissioner
Various times - See above
Richard Schwartz, Health Department
Various times - Coordination with County Commission
Bill Kessler, Health Department
Various times - See above
Rip Skeen, Road Department
Various times - Use of County equipment
Bill Borin
Western Petroleum Distributors, Inc.
1460 Lake
Ogden, Utah
Various times - Site history and sludge handling experience
Electric Sewer Service
3212 Stephens Avenue
Ogden, Utah
2/21-4/29 - Emergency contractor
Miya Brothers Construction Company
3505 Grant Avenue
Ogden, Utah
4/9/74 to 10/29/75 - Prime contractor
John Shupe
3620 Gramercy Avenue
Ogden, Utah
4/1/74 to 10/26/75 - Photographic documentation
-------
Dr. John J. Skujins, Soil Microbiologist
Ecology Center, USU
Logan, Utah
4/1/74 to 10/31/75 - Disposal Consultant
Great Basin Engineering and Surveying
84 West 500 South
Bountiful, Utah
Various times - Site surveys and bid package development
Consolidated Denver Corporation
3100 Brighton Blvd.
Denver, Colorado 80216
Jim Butler
4/9
6/19
Prebid conference
Sludge treatment
Ulf Riser
4/9
6/19
Prebid conference
- Sludge treatment
* For specific dates, refer to Headquarters log.
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REFERENCES
1. Association of Petroleum Rerefiners. "Proceedings of the Second
International Conference of Waste Oil Recovery and Reuse." February
1975. Association of Petroleum Rerefiners, Washington, D.C.
2. Chansky, S., et al. "Waste Automotive Lubricating Oil as a Municipal
Incinerator Fuel." U.S. EPA Report Number EPA-R2-73-293. September
1973.
3. Department of Agriculture. "Soil Survey, Davis-Weber Area, Utah."
Soil Conservation Service, July 1968.
4. Environmental Protection Agency. "Report to Congress Waste Oil
Study." April 1974.
5. Environmental Protection Agency. "Runoff of Oils from Rural Roads
Treated to Suppress Dust." U.S. EPA Report Number EPA-R2-72-054.
October 1972.
6. Kincannon, C. B. "Oily Waste Disposal by Soil Cultivation Process."
U.S. EPA Report Number EPA-R2-72-110. December 1972.
7. Leonard, R. P. "Brief Investigation on the Treatment and Recovery of
Resources from Waste Oil Sludges." Calspan Number VT-3044-M-1.
January 1973. Calspan Corporation, Buffalo, N.Y.
8. Martin, E. J. and Gumtz, G. D. "State of Maryland Waste Oil Recovery
and Reuse Program." U.S. EPA Report Number EPA-670/2-74-013.
January 1974.
9. Page, A. L. "Fate and Effects of Trace Elements in Sewage Sludge
When Applied to Agricultural Lands - A Literature Review Study."
U.S. EPA Report Number EPA-670/2-74-005, January 1974.
10. Weinstein, N. J. "Waste Oil Recycling and Disposal." U.S. EPA
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