Request for Emergency Removal Action at the Hudson Oil Refining Company Incorporated Superfund Site

Home , Asbestosis, Contingency plan, Emergency evacuation

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733

MAR 24 (999

MEMORANDUM SUBJECT: Request for Emergency Removal Action at the Hudson Oil Refinery Site, Gushing, Payne County, Oklahoma FROM: Myron O. Knudson, P.E., Direct Sui THROUGH: irector Office of ;ency and Remedial Response (5201G) TO: Timothy Fields. Jr., Acting Assistant Administrator Office of Solid Waste and Emergency Response (5101) I. PURPOSE This Memorandum requests approval of an emergency removal action in accordance with the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), 42 U.S.C. § 9604, at the Hudson Oil Refinery Site (the "Site") in Gushing, Payne County, Oklahoma. The removal action is to address loose and friable Asbestos Containing Material ("ACM"), two tetraethyl lead ("TEL") tanks, an anhydrous hydrofluoric acid ("HF") alkylation process unit, a variety of laboratory chemicals and miscellaneous chemicals stored on site. This Memorandum also confirms and documents the prior oral authorization of the removal action. On August 10, 1998, Myron O. Knudson, P.E., Superfund Division Director, orally approved the expenditure of up to $1 million to initiate a classic emergency removal action on the known existence of 23,000 square feet of loose and friable asbestos on the South Refinery. On November 12, 1998, Director Knudson orally approved an additional $750,000 to address the most immediate threats posed by the HF alkylation unit. The proposed plan of action meets the criteria for initiating a removal action under Section 300.415 of the National Contingency Plan (NCP), 40 C.F.R. § 300.415. An additional purpose of this Memorandum is to request and document approval of a removal action ceiling increase for the Site beyond the statutory $2 million and the twelve-month limit for removal actions. Based on a continuing Removal Site Evaluation, the On-Scene Coordinator ("OSC") has determined that conditions at the Site meet criteria based on the SG-%io emergency waiver in Section 104(c)(l) of CERCLA, 42 U.S.C. § 9604(c)(l). This exemption is O Recycled/Recyclabl~~—— '_-- ~_-~-~ -«:..-• e- ^ —— • Printed..-"" with _Vegetable " '--Oi" l •Based ^.' ~-~ -InksT ~E~~ o" n- 100%- ; . Recycled;p-- -"-Paper --^ (4O%r-__> -. Postconsumer)• £

021957 necessary to continue the decontamination of the Site. Approval of this request for a ceiling increase would raise the project ceiling to $6,282,500. The OSC is also aware of and is investigating other highly significant site features affecting the environment and/or public health, but in a less immediate manner than the threats described above. These include above ground storage tanks ("AST"); another large amount of ACM that is less deteriorated; piles of suspected tank bottoms and sludges, visibly stained soils, and large volumes of product in and associated with various refinery equipment (pipes and vessels), drums, and oil-water separators. These features pose clear threats to public health and/or the environment. However, the Region 6 Superfund program will determine whether the removal or remedial program should address these remaining features. These features are not included in the response action requested in this memorandum. They may be the subject of future removal and/or remedial actions, once overall program assessment is completed over the next few months. Additionally, petroleum wastes on site from tanks, drums and oil- contaminated soils may be addressed by a removal action pursuant to the Clean Water Act ("CWA"), 33 U.S.C. 1321, et seq., as amended by the Oil Pollution Act of 1990 ("OPA"), and qualify for Oil Pollution Act funding (FPN #088081). II. SITE CONDITIONS AND BACKGROUND CERCLISNo.: OKD082471988 Category of removal: Emergency Site ID #: EE A. Site Description 1. Removal site evaluation The Site is an inactive refinery that produced liquid propane gas, gasoline, aviation fuel, diesel fuel, and fuel oils from 1922 to 1982. The Site includes loose and friable ACM, an anhydrous HF alkylation process unit, two TEL tanks, thirty large ASTs, three large piles of suspected tank bottoms, visibly stained soils, partially razed and abandoned refinery equipment and structures with product (including over 200 small tanks and vessels), approximately 124 drums, ten API separators, and 18 buildings where various chemicals have been stored, including two lab buildings. Additionally, there are underground pipes and possibly underground storage tanks, six wastewater treatment impoundments, a coke pond, an aeration lagoon, a Land Treatment Unit ("LTU") of 11 acres, an LTU runoff collection pond, contaminated soils, and potentially contaminated wetlands and groundwater. Soil samples collected from the Site for a U.S. Environmental Protection Agency ("EPA") 1995 Site Inspection Prioritization Report contained inorganic constituents including lead, nickel, vanadium, and arsenic. Organic poly-aromatic hydrocarbons found at the Site included benzo(a)anthracene, chrysene, fluoranthene, benzo(a)pyrene, indeno(l,l,2,3-cd)pyrene and pyrene. This report also documented that there were 28,000 pounds of chemicals, including HF, solid chlorine, TEL, and ethylene dichloride, stored in buildings on site. A 1997 sampling

021958 effort by Asbestos Consulting Services, Inc., documented 23,000 ft2 of ACM on pipes and vessels on the portion of the refinery on the south side of State Highway 33 (the South Refinery). The OSC and the Oklahoma Department of Environmental Quality ("ODEQ") investigated the Site on August 4,1998. The ODEQ and the OSC saw friable ACM torn and hanging from refinery vessels and pipes, overflowing ASTs and separators, and numerous deteriorated leaking drums and smaller containers of unknown materials. The EPA determined that the Site presented an imminent and substantial threat to public health and the environment. On August 10,1998, the Superfund Division Director orally approved a $1 million ceiling to initiate a classic emergency removal action at the Site. Subsequently, upon discovery of a leaking HF storage tank, the Director orally approved an additional $750,000 on November 12, 1998. 2. Physical location The official Comprehensive Environmental Response, Compensation and Liability Information System ("CERCLIS") address for the Site is 401 West Maple Street, Gushing, Payne County, Oklahoma. When in operation, this was the main office for the Hudson Oil Refining Company, Inc. ("Hudson"). The Site is in Section 33, Township 18 North, Range 5 East with the approximate geographical coordinates of latitude 35°59'10" north and longitude 96°46'40" west. The Site is on the north west side of the town of Gushing and is bisected by State Highway 33 (Attachment 1). The Site is in a mixed residential-commercial suburban area in Gushing, Oklahoma. The population of Gushing is about 7,500. Eleven residences are within 200 feet of the Site, a Head Start day care facility is within one quarter of a mile, and 193 residences, a nursing home and a city power plant are within 1/3 of a mile of the Site. Runoff from the Site enters on site wetlands and then Skull Creek, a perennial stream which flows from the Site seven miles to the northeast and into the Cimarron River. The Site was not secure against entry by trespassers, as the surrounding fences were breached in various locations. According to the EPA Region 6 Environmental Justice Index Pilot, the square mile surrounding the site is about 26% minority and 58% economically stressed. For a 50 square mile area around the site, the population is about 12% minority and 46% economically stressed. On August 11,1998, the EPA photographed a Texas Horned Lizard (Phrynosoma cornutum), a "Category II Species of Special Concern" under Oklahoma law, at the Site. See Okla. Admin. Code 800:25-19-5, 800:25-19-6(f)(10). 3. Site characteristics The Site property consists of approximately 200 acres. State Highway 33, the main highway through Gushing, bisects the Site, establishing what are referred to as "North" and

021959 "South" Refineries. The North and South Refinery properties respectively include approximately 165 and 35 acres (Attachments 2 and 3). The North and South Refineries have been inactive since 1982. The refineries produced liquid propane gas, gasoline, aviation fuel, diesel fuel, and fuel oils from 1922 to 1982. In 1994, a Final Consent Decree ("FCD") between the EPA and Hudson was terminated by the Court. This FCD had required Hudson to address some major environmental issues at the Site, including: 1) tank clean-out; 2) soil excavation; 3) biotreatment of contaminated soil; 4) removal of north oily water pond sludges and soils; 5) groundwater remediation; and, 6) groundwater monitoring at the LTU. Hudson only met a portion of the obligations identified in the FCD. It is evident that before shutdown in 1982, the North and South Refineries were not properly purged, and various chemicals were left on site. The EPA has contacted a former Alkylation Plant Operator who worked at the Site for 38 years and was the operator who performed the final plant shutdown in 1982. According to him, Hudson performed an "inadequate purge" of the North Refinery on the final shutdown. Instead of purging the liquid in the lines, he said, Hudson pumped natural gas through the system and the HF-rich natural gas purge vapors were diverted to a flare. Similarly, on the South Refinery, the EPA has found that product, including gasoline, diesel fuel, and crude oil, remains in all of the lines and vessels. Reportedly, several parties have salvaged equipment and materials from the Site since the plant's closure in 1982. 4. Release or threatened release into the environment of a hazardous substance, pollutant, or contaminant a. Primary Threats - to be addressed in this response action. There have been uncontrolled releases of friable asbestos, anhydrous HF vapors, and TEL vapors into the environment. Friable asbestos, HF and TEL are hazardous substances as defined in Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further defined in 40 C.F.R. § 302.4. The ACM on pipes and vessels on the South Refinery is exposed, torn, and hanging on process equipment. Windy conditions at the Site may result in a release of asbestos, affecting adjacent residents. A 1997 sampling effort by the Asbestos Consulting Services, Inc. documented 23,000 square feet of ACM (Chrysotile and Amosite) on the South Refinery. On October 24,1998, the EPA observed a small vapor release of HF from a valve on a 12,000 gallon tank on the North Refinery. Documentation recovered from on-site office buildings alerted the EPA that a portion of the North Refinery contained an HF alkylation process unit. Anhydrous HF was used as a alkylation catalyst in making high octane fuels (aviation fuel). On October 26,1998, the United States Coast Guard ("USCG") using an Infra- Red Camera determined that the leaking tank was a little more than half full (estimated 6,000 gallons). In addition to this tank, a thorough assessment identified approximately 99 vessels that are an integral part of the alkylation process. Only three of the vessels have been identified as having no significant potential to contain HF. These vessels include storage tanks, reactors,

021960 settling tanks, strippers, scrubbers, preheaters, condensers, pumps, columns, recirculators, liquid traps, regenerators, reboilers, dryers and coolers. Additionally, approximately 18,000 linear feet (3.4 miles) of pipeline may contain HF. The former plant operator reported that most of the HF vessels and pipelines would be expected to have HF liquid/vapor inside them, and said that, in his opinion, the "plant is a stick of dynamite wailing to go off." The EPA has observed a number of areas of heavy corrosion on the HF storage tank and pipes which could cause of the release of liquid HF. Anhydrous HF reportedly has a liquid to vapor ratio of about 1:400 (ambient temperature dependent). At this ratio, a liquid release of HF would produce a significant plume of hazardous vapors affecting public health and the environment. The disaster potential is high for any such HF vapor plume in the Gushing area. There is a threat of release of TEL from two tanks on site. Inspection revealed that while these tanks appear to be in fair condition, there is a strong odor downwind from them, indicating some leakage. TEL is extremely explosive. It presents a severe threat of lead release to the environment by explosion. Due to high lead concentration, TEL poses a significant poison threat. Petroleum industry statistics indicate that almost two dozen people have been killed world wide in explosions this year while handling/using TEL. This hazard has given rise to a petroleum industry TEL synonym of "tetraethyl death." Due to the proximity to the Gushing population, a TEL explosion poses extreme hazards. Additionally, two laboratories on site have been inventoried and approximately 1,000 small containers were staged into chemically compatible groups. Containers in labs were found to contain hazardous substances as defined at Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further defined at 40 C.F.R. § 302.4. Lab hazardous substances included hydrochloric acid, nitric acid, sulfuric acid, ammonium hydroxide, sodium hydroxide, 1-butanol, chloroform, toluene, and silver nitrate. Many of the containers were in poor condition, some were leaking, and numerous others were without labels. There was evidence that the labs had been broken into and vandalized in the past. Neighbors report numerous incidents of vandalism at the Site, including one occasion where juveniles broke bottles from the labs on tank exteriors. Despite 24-hour security measures since the EPA has been on site, there have been two break-ins with minor vandalism and theft resulting. These incidents were thought to involve local youths. Local law enforcement personnel believe that the youths may be attracted to the labs to obtain reagents for illegal drug manufacturing, and that the labs will remain an attractive nuisance until their contents are removed. There are also a variety of miscellaneous bulk chemicals on site. These are stored in sacks and piles, and all are in deteriorated condition. Long term exposure to the weather and periodically to vandals has resulted in these bulk materials being scattered and entering the storm water runoff patterns of the site. The chemicals include chlorine based materials and other oxidizers, strong acids, and strong bases, and ion exchange resins. Many of the bulk chemicals appear to have been used in the treatment of boiler feed water, and use for the others is unknown. The chemicals described as bulk were found in 16 separate buildings (other than the lab buildings) on site.

021961 In support of the asbestos abatement efforts on the South Refinery, the EPA has already recovered over 30,000 gallons (over 700 barrels) of material, including gasoline, crude oil, and butane from tanks, vessels, and pipes. In locations where the pipes have been previously damaged, visibly stained soils indicate that the material drained to the soil at the damaged location. Additional site features have been at least superficially investigated, but are not the subject of the current emergency response action to asbestos (South Refinery), HF, TEL, and miscellaneous chemicals. The present response action is addressing these additional matters only as necessary to handle or move material, and to address the asbestos, HF, and TEL. Oily sludges and stained soils are being moved from asbestos abatement workplaces and temporarily stored in an on-site holding cell area to prevent worker exposure/injury and to prevent "tracking" these wastes by personnel and equipment over a much larger area. Asbestos-wrapped pipe is being emptied of product before completion of the asbestos abatement and demolition action with the product being stored in temporary on site tanks. The response action has included emergency measures as necessary to stabilize some leaking vessels, but otherwise has not been directed at their contents. On November 14,1998, a 120 foot tall pressure vessel jacketed with ACM was determined to be leaking sodium hydroxide solution. This vessel was undergoing asbestos abatement preparation when its severely corroded base was discovered. The base corrosion was so severe that the structural integrity was compromised, and vessel was swaying in the wind and clearly in danger of falling. An emergency response effort to secure the vessel and safely lower it to the ground for product removal followed on November 14 and 15,1998. The operation required two cranes, temporarily diverting resources from the asbestos abatement support effort. The sodium hydroxide was safely removed and temporarily stored on site, and the asbestos abatement of this vessel followed. b. Remaining Threats ~ may be addressed in subsequent actions There is a threat of release of hazardous substances from over 200 tanks and vessels and over 10 miles of piping associated with the North and South Refineries. Product from refineries was not adequately purged when the plant shut down. There is threat of release of hazardous substances and/or oily waste from tanks, tank bottoms, drums and separators. Potential RCRA listed wastes associated with these sources of waste include: K049 (slop oil emulsions); KO51 (API separator sludge); K087 (decanter tank tar sludge from coking); K052 (leaded tank bottom); and K169 (crude oil storage tank sediments), as defined at 40 C.F.R. § 261.32. Tops of tanks had been cut off or torn open by previous owners/operators, allowing the release of contents. Releases of oily material are plainly visible around the Site. Sheens can be seen entering runoff to on site wetlands and off site drainage ditches. Drainage ditches eventually enter Skull Creek. On-site wetlands and Skull Creek are navigable waters of the United States. These conditions have required the construction of temporary dikes to retain ongoing spillage.

021962 5. NPL status Concurrent with the removal action, the EPA is conducting an Expanded Site Inspection for potential National Priorities List ("NPL") consideration. The Site is believed to have a strong probability of NPL listing based on the Hazard Ranking System (HRS). See 40 C.F.R. § 300.425(c)(l). The HRS package is expected to be completed in time for an April 1999 NPL update. 6. Maps, pictures, and other attachments 1. Maps - topography 2. Aerial - South Refinery 3. Aerial - North Refinery 4. Letter from ODEQ 5. Unilateral Administrative Order for access 6. Asbestos Project Design 7. Meditext - Asbestos 8. Allied Signal Chemicals - HF 9. Meditext-TEL 10. Desk Reference - TEL 11. Enforcement Attachment B. Other Actions to Date 1. Previous actions In 1987, as a part of Bankruptcy hearings, the District Court for the Western District of Oklahoma handed down a Partial Consent Decree. This decree led to a Final Consent Decree ("FCD") between the EPA and Hudson. The FCD required Hudson to set aside $1 million for proper closeout, including: 1) tank clean-out; 2) soil excavation; 3) biotreatment of contaminated soil; 4) removal of north oily water pond sludges and soils; 5) groundwater remediation; and 6) groundwater monitoring at the LTU. Reportedly, the north oily water pond, the LTU, the tank farm, and the separators were addressed. In 1994, the U.S. District Court issued an "Order for Closure" of the FCD. EPA records indicate that, although it did not so state in the Order for Closure, the Court recognized that the requirements of the FCD had not been completed, and that exhaustion of the available resources caused closure. In 1995, Roy F. Weston, Inc., prepared a Hazard Ranking System ("HRS'") Prescore Package for the EPA based on perimeter site inspection and file research. The preliminary HRS score was less than 28.5, due to limited targets and petroleum exclusion issues. Subsequently, the EPA classified the Hudson Oil Refinery Company as "No Further Remedial Action Planned" ("NFRAP"). In 1997, the current owner of the largest portion of the Site property reportedly hired a contractor to conduct an asbestos abatement action and remove tank contents in exchange for the

021963 right to salvage equipment and metal from the Site. The contractor hired a subcontractor to develop an Asbestos Abatement Project Design ("PD") to address ACM on the South Refinery. That PD was approved by the Oklahoma Department of Labor ("ODOL"). The PD was not followed, however, and the contractor never completed PD abatement efforts. Instead, it breached piping and tanks and cut off the tops of ASTs, presumably to salvage scrap metal. It also left behind ACM, torn and hanging from facility components, exacerbating the friable asbestos problem significantly. In November 1997 the ODEQ requested EPA assistance at the Site (Attachment 4). The Site was subsequently referred to the EPA. 2. Current actions The EPA is conducting an emergency removal action to address the imminent and substantial threats to public health and the environment. On August 10,1998, the Superfund Division Director orally approved a $1 million ceiling to initiate a classic emergency removal action on the South Refinery. This ceiling was specifically approved to address the known existence of 23,000 square feet of loose and friable asbestos on the South Refinery. The EPA's presence allowed for the investigation of other hazards at the Site to further define environmental cleanup needs at the Site. The owners of the Site granted access in accordance with a Unilateral Administrative Order ("UAO") which became effective on September 11,1998 (Attachment 5). The EPA Emergency Rapid Response Services ("ERRS") contractor was mobilized to the Site on September 16,1998 to conduct a classic emergency removal action on the South Refinery, and the EPA Superfund Technical Assessment and Response Team ("START") has concurrently been directed to investigate additional hazards/environmental problems at the Site. a) ACM Removal/Demolition The START contractor developed an Asbestos Abatement Project Design Addendum ("Addendum") to the 1997 Asbestos Abatement Project Design ("PD") developed by Diversified Environmental Technologies, Incorporated (Attachment 6). This addendum was developed to address South Refinery friable ACM, which is hanging from facility components and lying on the ground. The ERRS contractor awarded a subcontract to Basic Industries, Inc. ("BI") for the South refinery asbestos abatement work. This contract stipulated that abatement work, barring shut downs due to extreme weather conditions, must be complete by December 18,1998. The ODOL approved the Addendum on October 12,1998, and permitted the BI contractors to initiate abatement. ODOL inspections of BI's work continue to ensure compliance of all State asbestos abatement regulations. BI constructed a 124 ft. by 20 ft. negative pressure decontamination tent, decontamination facilities and windwalls on the Site. "Cut and Wrap" procedures are being used to address ACM on pipes and structures. "Cut and Wrap" procedures refer to wrapping ACM on pipes and structures in two layers of 6-mil polyethylene sheeting. The pipes are men cut into manageable sections and lowered to the ground by use of cranes. BI is wrapping pipes and using glove bags every 30 feet. Glove bags are used to abate ACM from short sections of the pipes. 8

021964 Pipes may then be cut into manageable lengths using metal shears at the short clean areas, and then placed onto trailers or into roll-off boxes for transport to an approved disposal facility. The larger vessels and structures are being wrapped on the ends where asbestos is exposed, and lowered by crane into a decontamination tent, where the asbestos is abated. Because the South Refinery was not properly purged at shutdown in 1982, product remains in the lines and vessels. The product in the lines presents a clear threat of fire and explosion during the ACM abatement and demolition activities (and afterward if not removed). Therefore, the ERRS contractor has implemented procedures to collect product from the pipes and vessels. Each pipe must be investigated by drilling a small hole using a pneumatic air drill to determine if product is present. If product is present, vacuum trucks are used to recover it. If product is not present, pipes are monitored with a Total Vapor Analyzer (TVA) to determine if explosive vapor conditions are present. In addition to using vacuum trucks, lines may require steam cleaning to remove product or vapors before being cut or lowered into the decontamination tent. To date, more than 30,000 gallons (more than 700 barrels) of products (i.e gasoline, diesel fuel, butane) have been collected from vessels, tanks and pipes and stored in temporary tanks on site. In addition to purging lines and lowering vessels and structures, the ERRS contractor has prepared the work area for abatement efforts. This includes: moving drums out of the way to a central staging area; removing unstable structures from areas where abatement contractors must work; constructing a temporary storage cell for contaminated sludges/soils found in the work area; collecting sludges expected to be released from the pipes and vessels as they are cut; setting up a decontamination area for metals derived from asbestos abatement work; clearing brush for abatement contractors; improving and making on-site roads to support the heavy equipment necessary for abatement work; and other similar physical assistance and support of asbestos abatement contractors' work. 2) Investigation . . ... On September 23, 1998, engineers from the EPA START contractor conducted a non- destructive/visual assessment of the structural integrity of buildings, catwalks and towers on site. They determined that all catwalks and towers were structurally unsound and should not be climbed. Nine buildings were determined to be structurally unsound (Attachment 7). The START documented 44 structures on site, including two lab buildings and two TEL tank storage buildings. Additionally, 16 buildings contain various chemicals and vessels, including drums, vats, powders, caustics, compressed gas cylinders, paints, unknown solid pellets, and acid tanks. During the week of October 5,1998, the EPA START conducted an inventory of tanks, drums and miscellaneous containers on site, and performed sampling and hazard categorization of unknown products from drums, tanks, API separators and suspected tank bottoms. The START collected samples from approximately 124 drums, 26 tanks, 8 API separators, and 3 piles of tank bottoms. All samples were hazard categorized by the START into seven separate waste streams: flammable, combustible, base, neutral, strong acid, weak acid, and chlorinated compounds. Samples from tanks, API separators and tank bottoms were sent to a lab for

021965 analysis. Two laboratories on site were inventoried and compatible groups from approximately 1,000 small containers were temporarily staged inside the labs. Nine yellow boxes, approximately 1ft. by 1 ft. in size, and marked "Danger Radioactive" were discovered on the North Refinery on October 15,1998. The area around the boxes was marked for personnel exclusion. The ODEQ assessed the boxes for radiation on October 16, 1998, using a Ludlum Model 19 to detect gamma rays, a Model 12-4 for neutrons, and a Model 44-9 probe to detect alpha, beta and gamma rays. The ODEQ did not detect any readings above background. The radioactive source in these boxes appears to have been removed. The boxes were apparently associated with storage of historical cesium gauges used to monitor tank levels. Ultimate disposition of these boxes is being discussed with State officials. The EPA has been evaluating the potential for bioremediation of soils, sludges, and tank and separator contents in the existing LTU. Bioremediation appears to be a viable and economical alternative to off-site disposal of the organic materials in that location. c) HF storage tank On October 24,1998, the EPA observed a small release of HF vapor from a valve on top of a 12,000 gallon tank located on the North Refinery. Documentation recovered from office buildings on site alerted the EPA that a portion of the North refinery was an HF alkylation process unit. Anhydrous HF was used as an alkylation catalyst in making high octane fuels. On October 26,1998, the USCG, using an infrared camera, determined that the leaking tank was a little more than half full (estimated 6,000 gallons). The OSC mobilized the EPA Emergency Response Team to the Site, along with experts obtained through the ERRS contractor with experience in performing transfers of highly corrosive material. The EPA has also consulted extensively with manufacturers of HF (Dupont and Allied Signal), the HF Institute, designers of HF alkylation units (Amoco), and previous employees of the plant. The EPA subsequently conducted a thorough engineering assessment of the HF unit that included the identification of all vessels and pipes which may contain HF. There are approximately 96 vessels and 3.4 miles of pipe that have been identified as integral parts of the alkylation process. The EPA determined that the 12,000 gallon HF storage tank, estimated to hold approximately 6,000 gallons of material, represented the greatest threat to public health and the environment. Analysis of this tank revealed that pipes and valves on it are corroded and in poor condition. If left alone, it could have released up to 6,000 gallons of liquid HF. Such a release could produce a very large cloud of hazardous vapors seriously threatening public health and the environment. Disaster potential associated with this vessel was very high. On December 13,1998, the EPA transferred the liquid contents of the tank to inter-modal containers. In these containers the material can be safely transported off site for disposal and/or treated on site. This transfer operation was carefully planned with the consultation of EPA and industry experts, and contingencies such as vapor suppression systems were installed before the transfer. Although no mishap was expected, expert analysis of the planned transfer operation revealed that if a leak had occurred, the probable maximum amount of liquid HF material that 10

021966 could have been released was approximately 50 gallons. This is twice the volume of the transfer line. Based on this worst-case scenario of release, the EPA reviewed computer air dispersion models (ALOHA) on the impact of such a release on the surrounding community. This model predicted that at 50° F, HF vapors immediately dangerous to life and health would reach as far as 1/3 of a mile. Additionally, a plume that would meet short term exposure limits set for 15 minutes of allowable exposure could reach as far as 3/4 of a mile. Although the EPA did not anticipate a release of HF, the EPA recommended to City officials that every precaution be taken to ensure the safety and health of the public. In accordance with the EPA's evaluation of air modeling data, City officials arranged for the voluntary evacuation of 435 citizens within a 1/3 mile radius around the HF tank for 9 hours on December 13,1998, with a contingency plan to increase the evacuation radius to 3/4 mile in the event of a release. Contingency plans included the staging of equipment and personnel from EPA, the USCG and the local fire and police departments throughout the area. Additionally, State Highway 33 remained closed in front of the Site for 11 hours, until the transfer of HF was complete. EPA completed the transfer of close to 5,600 gallons of HF from the corroding storage tank on December 13,1998. No serious problems developed during the 11-hour transfer. Liquid was transferred into two inter-modal containers that could hold up to 4,000 gallons each. d) Emergency stabilization actions The ERRS contractor has performed emergency stabilization efforts at the Site to prevent the further release of hazardous substance off-site. Specifically, they have constructed berms around some tanks and drainage ponds which would otherwise release oily waste from the Site to on-site wetlands and Skull Creek. There have been leaking and poor-condition drums which have been overpacked and temporarily stored in a secure location on site. Sludges and grossly contaminated soils have been moved from work areas to temporary storage. Leaking vessels (such as the sodium hydroxide leak described above) have been addressed on an "as needed" basis. C. State and Local Authorities' Roles 1. State and local actions to date The ODEQ and ODOL have actively participated in activities on site. The ODOL has provided oversight of asbestos abatement activities, and the ODEQ has provided leadership with community relations, sampling of suspected ACM, and investigation of hazards at the Site. Both the ODEQ and the State Highway Patrol provided assistance in evacuation efforts associated with the EPA's HF response action. However, the State does not have the resources to undertake a response action to address the emergency conditions and clean up the contamination. The ODEQ has agreed to enter into a Removal Action Contract with the EPA, whereby the ODEQ will partially fund the removal action costs pending NPL ranking of the Site.

021967 The Local Emergency Planning Committee (LEPC) and the local police and fire departments set up an Incident Command System to work with the EPA on the HF response action and associated recommended evacuation. Additionally, the local fire department and hospital have provided on-scene fire trucks and ambulances during some dangerous response actions (i.e. sodium hydroxide vessels and work on the HF storage tank valves). The local "in- kind" services have been very substantial, and the work could not have readily proceeded without this cooperative effort. 2. Potential for continued State/local response The ODEQ and ODOL are expected to continue to participate substantially. In addition, the ODEQ, City of Gushing officials, the LEPC, local police and fire departments, local Red Cross and hospitals have assisted the EPA's efforts to safely transfer contents of the HF storage tanks on site. These groups worked closely with the EPA to evacuate nearby residents during the "high risk" HF transfer operations and to develop contingency plans in the event of an HF liquid release. A variety of community centers were used to temporarily house and feed those in need of these services. EPA was in constant radio contact with the local fire and police departments in case of emergency. A contingency plan for accidental releases of material from the site was developed in conjunction with the LEPC and local fire department. Parts of the plan, specifically communication links between the site and the fire department and sounding of the fire department's emergency evacuation alarm, were periodically rehearsed. III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT; STATUTORY AND REGULATORY AUTHORITIES Section 300.415 of the NCP lists the factors to be considered in determining the appropriateness of a removal action. Paragraphs (b)(2)(i), (ii),(iii), (v), and (vii) directly apply to the conditions at the Site. Any one of these factors may be sufficient to determine whether a removal action is appropriate. A. Threats to Public Health or Welfare 1. Exposure to human populations, animals or the food chain, NCP Section 300.415(b)(2)(i) a) ACM Residents living, working, and playing in and near the Site may be affected by the release of friable asbestos, which is a hazardous substance as defined at Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further defined at 40 C.F.R. § 302.42 . A 1997 sampling effort by Asbestos Consulting Services, Inc. documented 23,000 ft of ACM on refinery equipment on the South Refinery, and specifically identified Chrysotile and Amosite asbestos. This ACM had been torn and left hanging on facility components and on the ground before the EPA's arrival. There is a significant potential for continued exposure of residents living in close proximity to 12

021968 the Site. Winds or disturbance of the Site by owners of the Site or trespassers could result in a release of asbestos affecting nearby residents. Asbestos fiber inhalation has been linked to several diseases and conditions. These include asbestosis, lung cancer, mesothelioma, gastrointestinal cancers, and other abnormalities. Asbestosis is a disease characterized by fibrotic scarring of the lung. It reduces lung capacity and one's ability to resist respiratory infections. Common symptoms include shortness of breath, rales (a dry, crackling sound in the lungs during inhalation) and clubbing of fingers. Extreme cases of asbestosis will be fatal, usually due to cardiac arrest. The typical latency period for this disease is 15 to 30 years. There are an estimated 4,000 deaths per year associated with asbestosis. Mesothelioma is a cancer of the mesothelium, a thin tissue layer which contains and protects the internal organs of the body. It is the asbestos-associated disease of greatest concern because it is not associated with cumulative exposure. Cases of exposure have been recorded where the person's asbestos exposure has been quite limited. If it occurs in the chest cavity, it is called pleura! mesothelioma. If it occurs in the abdominal cavity, it is called peritoneal mesothelioma. Both types of cancer spread rapidly and are always fatal, usually within a year of diagnosis. The latency period for mesothelioma is 30 to 40 years after initial exposure. There are an estimated 1,000-1,500 deaths per year associated with mesothelioma. b) Anhydrous HF Residents living, working, and playing in and near the Site may be affected by the release of HF, which is a hazardous substance as defined in Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further defined in 40 C.F.R. § 302.4. Additionally, motorists on Highway 33 could be affected by the release of HF. A vapor release of HF has been observed by the EPA from a valve on a 12,000 gallon tank of HF on the North refinery of the site. Analysis of the tank revealed that pipes, valves and sight glasses on and attached to it are corroded and in poor condition. According to Mr. Glenn Wright, the previous manager of the Site, the valve was not leaking during his last visit to the Site, approximately two years ago. Additionally, it has been reported to the EPA that cedar trees are often planted at facilities which use HF as bio-indicators of low level releases because of then- high susceptibility to HF. Cedar trees a short distance downwind of the vapor release turned brown on the side facing the tank within two weeks of first observing the HF release. These factors indicate that the release is relatively recent. According to experts, such a release will inevitably cause the valve, followed by the tank, to corrode and release HF because HF becomes extremely corrosive when mixed with water as is happening with the caking valve. Failure of the tank containing approximately 6,000 gallons of anhydrous HF would result in a large liquid release and associated catastrophic vapor plume. In addition to this HF storage tank, the EPA has identified approximately 99 vessels that are an integral part of the alkylation process. Only three of these vessels have no significant potential to contain HF. These vessels include storage tanks, reactors, settling tanks, strippers, scrubbers, preheaters, condensers, pumps, columns, recirculators, liquid traps, regenerators, reboilers, dryers and coolers. Approximately 18,000 linear feet (3.4 miles) of pipeline are 13

021969 suspected of containing HF. Tanks and process equipment in the HF unit are in poor condition with visible signs of rust and corrosion. Additionally, the EPA has witnessed several places where it appears that HF has corroded through pipes. All vessels and pipes, if left alone, present a clear and imminent threat to the public should they fail and release liquid HF. According to Allied Signal personnel, HF has a liquid to vapor ratio of about 1:400, although this ratio is temperature dependent. Therefore, a relatively small liquid release will result in a large plume of vapor. Such a threat would increase significantly next spring and summer when temperatures are substantially over 67 °F (HF boiling point). Hydrofluoric acid is a clear, colorless liquid which when exposed to air produces pungent and especially dangerous fumes. HF is acutely toxic by the following routes of exposure: SKIN CONTACT: HF can cause serious, painful burns of the skin. HF is highly corrosive acid which means it can severely burn the skin, eyes and mucous membranes. The vapors from HF can also burn these tissues. The usual signs of an HF burn are redness, edema, a whitish discoloration of the skin and blistering. In contrast to the potential effects of HF liquid, burns from HF vapors are generally delayed from one to eight hours and are less severe. • EYE CONTACT: HF vapors can cause severe eye burns with destruction of the cornea. Blindness may result from severe or untreated exposure. • INHALATION: Because of the strong irritant nature of HF, an individual inhaling HF vapors of fumes will usually experience upper respiratory injury, with mucous membrane irritation and inflamation as well as cough. HF fumes may cause laryngospasm, laryngeal edema, bronchospasm and/or acute pulmonary edema. Acute symptoms include coughing, choking, chest tightness, chills, fever and cyanosis. Many reported fatalities have been due to severe pulmonary edema (coupled with systemic toxicity). Symptoms can often be delayed for several hours or even up to two days. • SYSTEMIC TOXICITY: One of the most serious consequences of severe exposure to HF by any route is the marked lowering of serum calcium (hypocalcemia) and other metabolic changes which may result in a fatal outcome if not recognized and treated. Hypocalcemia should be considered a possible risk in all instances of inhalation and whenever skin burns exceed 25 square inches. (See Attachment 8, Recommended Medical Treatment for Hydrofluoric Acid Exposure) c) TEL There are two 5,000 gallon tanks containing TEL on site. TEL vapors are poisonous if inhaled or skin is exposed. TEL is flammable when exposed to heat, flame or oxidizers. Vapors may form explosive mixtures with air. Containers may explode when heated. Like most volatile organic materials, the tendency to form explosive mixtures with air increases significantly with 14

021970 increasing ambient temperature. Symptoms of acute exposure may occur within a few hours or be delayed for weeks or even months. They include headache, irritability, reduced memory, tiredness, tremors, hallucinations, convulsions and death. Symptoms of chronic exposure can occur at some time after exposure to TEL and can last for months or years. Repeated exposure to TEL can cause lead to accumulate in the body. It can take years for the body to get rid of excess lead. Since TEL is changed into lead in the body, TEL may cause kidney and brain damage, and damage to blood cells causing anemia. (See Attachment 9, TEL New Jersey Hazardous Substance Fact Sheet. Micromedex, Inc.) d) Labs Laboratory chemicals on site are a significant threat since there are a large variety of materials and many of them are incompatible. These chemicals have been the clear target of two recent break-ins and vandalism despite EPA security measures. Approximately 1,000 small containers (5 gallon and less) from lab buildings on site were staged by compatibility category and inventoried. Hazardous substances documented included hydrochloric acid, nitric acid, sulfuric acid, ammonium hydroxide, sodium hydroxide, 1-butanol, chloroform, toluene, and silver nitrate. Many of the containers were in poor condition, leaking, and without labels. 2. Contamination of Drinking Water Supplies or Sensitive Ecosystems, NCP Section 300.415(b)(2)(ii); Runoff from the Site enters on-site wetlands and Skull Creek, a perennial stream which flows from the Site seven miles toward the northeast and into the Cimarron River. Vegetation in wetlands receiving runoff from tanks and separators appears stressed. 3. Hazardous Substance in Drums or Tanks, NCP Section 300.415(b)(2)(iii) Two 5,000 gallon tanks on site contain TEL. Level B entries into buildings housing these tanks revealed that the tanks were in visibly fair condition. A strong odor can be observed downwind, thus indicating some leakage. TEL is highly explosive and presents a severe threat of release to the environment by explosion. Other hazardous substances in tanks include the HF storage tank, as described elsewhere. 4. Weather conditions that may cause the release or migration of hazardous substances, NCP Section 300.415(b)(2)(v); Gushing, Oklahoma is subject to several types of extreme weather conditions that could cause the release of hazardous substances, such as high winds, tornadoes and flash floods. High wind and occasional tornadoes could damage tanks and structures on site, potentially releasing liquids onto the soil and asbestos fibers into the air. Storm water could entrain the surface sludges and contaminated soil and contaminate a larger area beyond the Site's boundary. 5. Threat of fire or explosion, NCP Section 300.415 (b)(2)(vi);

021971 Hazardous substances at the Site present a severe threat of fire or explosion. Tetraethyl lead is highly explosive and presents a severe threat of release to the environment by explosion. It is flammable when exposed to heat, flame or oxidizers. Exposure to air for several days may cause explosive decomposition. (See Attachment 10, Hazardous Chemicals Desk Reference) Like most organic materials that may form explosive vapors when mixed with ah-, this explosive potential of TEL increases significantly with increasing ambient temperatures. While technical information on HF defines it as a non-flammable material, conditions at the Site related to long-term storage of HF and the process of alkylation raise the potential for encountering a flammable atmosphere. Long-term storage of HF results in a reaction between the HF and the metal storage tank that can produce hydrogen gas. In addition, the alkylation process involves gases such as propane, butane, and iso-butane and alkylate products such as high octane aviation fuel that could be present in vessels and pipelines. Since the refineries were never purged, these as well as other flammable products (gasoline, diesel fuel, etc.) are expected to be found in the product lines and vessels. Also, hydrocarbons located around the site on soils or in leaking tanks and drums would provide fuel to sustain a fire on the Site. Evidence of historical vandalism at the Site raises concerns that juveniles smoking on site could start a fire that may become uncontrollable, considering substances documented at the Site. A smoke plume from a fire at the Site would affect motorists on Highway 33, as well as people living and working in Gushing. 6. Availability of other response mechanisms, NCP Section 300.415(b)(2)(vii) Assistance will not otherwise be provided on a timely basis because neither the State of Oklahoma nor local governments have the resources to deal with a site of this complexity or magnitude. B. Threats to the Environment Wildlife may be exposed to and harmed by contaminants at the Site. Wildlife at the Site includes horned lizards, bobcat, deer, roadrunners, migrating waterfowl and recreational fish species. Runoff from the Site enters Skull Creek, a tributary of the Cimarron River, which is a recreational fishery. Most refinery wastes that might enter the drainage basin have direct toxic effects on the aquatic biota. These wastes often float on the surface of the receiving stream, and inhibit natural gas exchange between the water body and the atmosphere. This can quickly result in depressed oxygen and high mortality to most forms of stream life. This oxygen deprivation effect is often one of the most significant adverse environmental affects of oily wastes entering water bodies. IV. EMERGENCY EXEMPTION FROM STATUTORY LIMITS

021972 The total projected cost ceiling will exceed the statutory $2 million limit and the twelve month statutory limit for removal actions. Accordingly, I recommend authorization of an exemption from the statutory limit of $2 million and the 12 months. Section 104 of CERCLA, 42 U.S.C. § 9604, vests the authority to conduct the removal action described in this memorandum, and the authority to make the findings necessary to obtain the relevant statutory exemptions, in the President of the United States. The authority to authorize the relevant CERCLA Section 104 exemptions for a removal action was delegated to the EPA Administrator by Executive Order Number 12580, January 23,1987, 52 Fed. Reg. 2923, and was redelegated to the Regional Administrator, EPA Region 6, by EPA Delegation Numbers 14-2-A (April 15,1994) and 14-3 (September 13,1987), That authority was in turn redelegated to the Director, Superfund Division, EPA Region 6, by EPA Region 6 Delegation Numbers R6-14-2-A (October 8,1996) and R6-14-3 (August 4,1995). Accordingly, I recommend that you find, based on the administrative record and the documentation provided in this memorandum, that the removal action at the Site may continue after $2 million has been obligated and after 12 months because (i) continued response actions are immediately required to prevent, limit, or mitigate an emergency; (ii) there is an immediate risk to public health or welfare or the environment; and (iii) assistance will not otherwise be provided on a timely basis. See Guidance on Implementation of the Revised Statutory Limits on Removal Actions, OSWER 9360.0-12 (April 6,1987). The following information, along with the administrative record, supports the findings recommended above: A. Continued response actions immediately required to prevent, limit, or mitigate emergency. Section 104(c)(l)(I) of CERCLA, 42 U.S.C. § 9604(c)(l)(I). No other agency is capable of the expeditious action necessary to address the releases or the threats of releases of hazardous substances at the Site. The inadequately purged HF Alkylation unit on the North refinery was highly susceptible to a failure of corroded equipment and a subsequent catastrophic release of liquid anhydrous HF. This danger was evidenced by the vapor release witnessed by the EPA on a 12,000 gallon HF storage tank. Experts warned that as the weather warms and moisture was pulled into the tank, the HF could become highly corrosive and valve and the tank could have broken apart. Such a release could have resulted in a catastrophic vapor cloud affecting the residents and workers in Gushing. Immediate and continued actions were necessary to address and render inert this threat. Similarly, the integrity of all other valves, vessels and piping containing HF is in question. Loose and friable asbestos is hanging and torn from facility components on the North and South Refineries. The release of asbestos fibers on the ground around the Site is plainly visible.

021973 Strong winds, common in Oklahoma, present a clear threat of carrying asbestos fibers off-site to nearby residents and children playing outside. TEL tanks present an imminent threat of fire and explosion. TEL is flammable when exposed to heat, flame or oxidizers. Vapors may form explosive mixtures with air. Containers may explode when heated. TEL odors have been noted downwind of existing storage tanks. This suggests venting or leaking. A TEL explosion on site is one of many ways a fire could start at the Site. Tanks and separators overflowing with oily sludge, refinery equipment left with gasoline and butane, soils contaminated with hydrocarbons and numerous buildings with improperly stored chemicals, present a significant threat of fire at the Site. Such a fire could easily become uncontrollable and a significant threat to the residents and workers in Gushing. B. Immediate risk to public health and welfare or the environment. Section 104(c)(l)(ii) of CERCLA, 42 U.S.C. § 9604(c)(l)(ii). There are ongoing releases at the Site of friable asbestos, HF and TEL. Sixteen buildings and two labs contain unsecured and improperly stored chemicals. There is rusting and deteriorating refinery equipment, including vessels and pipes that were inadequately purged, containing propane, butane, and iso-butane, high octane aviation fuel, gasoline and other flammable materials. Also, long term storage of HF in metal tanks is likely to result in the formulation of flammable hydrogen gas. Overflow from tanks and separators enters runoff at the Site, which enters on-site wetlands and Skull Creek. These threats require immediate attention at the Site. Delay of response could result in a severe release from deterioration, fire, wind, trespassers or rain. C. Assistance will not otherwise be provided on a timely basis. Section 104(c)(l)(iii) of CERCLA, 42 U.S.C. § 9604(c)(l)(iii). State, county, and local governments do not have the resources required to undertake a cleanup action of the magnitude required at the Site. V. ENDANGERMENT DETERMINATION Actual or threatened releases of the hazardous substance from this site, if not addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment. VI. PROPOSED ACTIONS AND ESTIMATED COSTS A. Proposed Actions The purpose of this removal action is to mitigate the most imminent threats to human health and the environment posed by the site conditions described above. Proposed actions include the removal of hazardous substances including friable ACM on outdoor pipes and 18

021974 equipment in the South Refinery only, addressing all of the anhydrous HF problems on site, addressing the TEL, removing the hazardous substances from labs, and the bulk and miscellaneous chemicals on site. The hazardous substances in tanks, separators, piles of tank bottoms and sludges, visibly stained soils, and product from refinery equipment may be considered in future actions at the site. 1. Proposed action description A. South Refinery i. ACM: The EPA will continue the ongoing emergency asbestos abatement removal action on the South Refinery. A large subcontract was secured to abate the asbestos threats and the abatement on the South Refinery is now more than 70% complete; most of the cost of this action is also already incurred. This action includes removal of outdoor friable ACM on pipes, vessels and structures, removal of product within pipes and vessels and concurrent demolition of the South Refinery. Additionally, the EPA will demolish and remove any on-site buildings determined to pose a risk of release of asbestos or other hazardous materials to the environment or a risk of injury to cleanup workers as a result of structural instability. Deteriorated buildings posing a threat of release of asbestos will be demolished using ODOL-approved wet methods, and appropriate disposal of contaminated material. Concurrent abatement and demolition actions are considerably more economical than sequential actions. ii. TEL: Because of the extremely explosive nature of TEL and the level A Personal Protective Equipment ("PPE") requirements, the EPA will develop a specific work plan to address the two 15,000 gallon TEL tanks. The first step will be to remove the buildings from around the tanks to gain access to the tanks. The second step will be to accurately quantify the amount of TEL remaining in each tank. This work plan will include close coordination with fire and hazardous materials personnel before efforts to open containers and collect material for disposal. Addressing this material during the lower ambient temperatures of the winter season will reduce the explosion hazards, since vaporization and tendency to form explosive mixtures with air will be depressed. iii. Miscellaneous chemicals and on-site labs: These materials will be addressed in the proposed removal action. Each of these sources will be tested to determine general waste characteristics, and where possible the material will be combined (bulked) into appropriate common waste streams for ease of handling and economy. Transportation to off-site disposal will be the clear choice for most materials. B. North Refinery i. Anhydrous HF Alkylation Plant: The EPA will collect liquid HF from vessels and pipes and dispose of it off-site. There are approximately 99 vessels that are an integral part of the alkylation process, and only three of them have no significant potential to contain HF. These vessels include storage tanks, reactors, settling tanks, strippers, scrubbers, preheaters, condensers, pumps, columns, recirculators, liquid traps, regenerators, reboilers, dryers and coolers. 19

021975 Additionally, approximately 18,000 linear feet (3.4 miles) of pipeline will require purging. The piping contains approximately 1,500 valves and 1,300 flanges. Research performed to date indicates that the primary HF hazards are in the tanks, vessels and reactors rather than the pipelines. Certainly the greatest threat is in the storage tank containing approximately 6,000 gallons of liquid HF. A work plan to address the plant will involve isolating each tank and vessel by closing valves, installing blind flanges and "hot tapping" to add new valving as required. Vessels containing HF may then be dealt with according to the magnitude of danger. Five vessels have been identified as the greatest health and environmental hazards: 1) HF storage tank; 2) HF Settling Tank; 3) Alkylation Reactor; 4) Polymer Storage Tank; and 5) HF Stripper. The EPA will work to address these five vessels first, followed by the other 94 vessels that have a significant potential to contain HF, and then the 3.4 miles of pipeline. Each of the five prioritized vessels will be isolated from all pipelines before attempting to access the vessel. Provided the vessels do not have excessive internal pressure, they will be opened at two top-located access points. If there are not two top-located access points available, entry will be made through access points located at the most elevated positions available. Selecting elevated access points will reduce or eliminate the risk of a liquid HF release. However, bottom-located valving may be used if a new valve can be connected without opening existing valves or removing flanges. This is a precaution taken in the event an existing valve is opened and an HF leak occurs, and then the valve fails to close. Nitrogen will be used to gently push (low pressure) HF vapors to an efficient vapor- scrubber system. The ERRS will initiate the purge with nitrogen gas at ambient temperatures, gradually increasing the temperature of the nitrogen until reaching the HF boiling point of 67 degrees Fahrenheit. A vapor sample port where vapors entering the scrubber will be monitored for HF vapor. The purging process will continue until HF is not detectable. In addition to HF liquid and vapors, the EPA has been advised that vessels and piping will contain scale with high concentrations of HF on most internal parts that were exposed to HF. Recommended Practices for the Hydrogen Fluoride Industry, a publication of the Hydrogen Fluoride Industry Practices Institute, advises: Most metals react with anhydrous HF ("AHF") to form metal fluorides and hydrogen... the fluoride scales can also cause burns, if handled improperly, even when they appear dry .... Clearly, great care must be taken in handling any material that has been exposed to AHF. This advice has proven correct. Acting in an abundance of caution, EPA placed dry flange bolts found loose on the floor of the alkylation unit into caustic solution. A vigorous exothermic boiling of the solution followed, indicating that the bolts were being neutralized from previous HF exposure. Handling or contact with these materials would have resulted in burns. A work plan to address the HF liquids and vapors will also include recommendations for managing

021976 the HF-contaminate scale problem. The EPA is considering methods for neutralizing the surficial scale and certain hardware. It is prudent to perform all HF work (storage tank, vessels and pipelines) this winter season, when ambient temperatures will keep HF below its 67 degree boiling point and minimize the liquid to vapor ratios. ii. ACM in the North Refinery will not be addressed as part of the proposed action, but will be considered for future EPA work. iii. TEL: As with the South Refinery, the EPA will develop a work plan to address the TEL tank on the North Refinery. c. North and South Refineries i. Tanks, separators and suspected tank bottom piles will not be addressed as part of the proposed action, but will be considered for future EPA work. Betwee3 n both the North and South Refineries, the EPA estimates that there are approximately 6,000 yd of tank and separator sludges and suspected tank bottom piles. Much of this waste has the potential to be biologically treated in the existing LTU. ii. Soils collected from work areas will not be addressed as part of the proposed action, but will be considered for future EPA work. Between3 both the North and South Refineries, the EPA estimates that there are approximately 5,000 yd of grossly contaminated soil that will have to be removed from work areas to provide for worker safety. All off-site transportation and disposal will be done in accordance with applicable U.S. Department of Transportation ("USDOT") requirements and in compliance with Ihe EPA's Off- Site Rule. See Section VI(A)(5). All requirements under the Occupational Safety and Health Act (OSHA) of 1970,29 U.S.C. § 651 et seq.. and under the laws of the State, approved under Section 18 of the Federal OSHA laws, as well as other applicable safety and heallh requirements, will be followed. Federal OSHA requirements include Hazardous Materials Operation, 20 C.F.R. Part 1910, as amended by 54 Fed. Reg. 9317 (March, 1989), all OSHA General Industry (29 C.F.R. Part 1910) and Construction (29 C.F.R. Part 1926) standards wherever they are applicable, as well as OSHA record keeping and reporting regulations, and the EPA regulations set forth in 40 C.F.R. Part 300, relating to the conduct of work at Superfund sites. 2. Contribution to remedial performance The selected response will contribute to any conceivable future remedial action, since control of the sources of pollution will be practiced. The removal action will eliminate the immediate threats identified hi Section III of this Memorandum. The removal action, to the extent practicable, will contribute to the efficient performance of any anticipated long-term remedial action. NPL listing is anticipated.

021977 3. Description of alternative technologies The proposed actions include only the highest risk public health threat portions of the site. These actions involve removal and off-site disposal of the chemical wastes that pose the public health threats. No alternatives technologies can be applied to these portions of the cleanup. 4. Engineering Evaluation/Cost Analysis (EE/CA) An EE/CA is not applicable to this project because of its emergency nature. 5. Applicable or Relevant and Appropriate Requirements This removal action will be conducted to eliminate the actual or potential exposure to hazardous substances, pollutants or contaminants pursuant to CERCLA, 42 U.S.C. § 9601 et seq.. and in a manner consistent with the NCP, 40 C.F.R. Part 300, as required at 33 U.S.C. § 1321(c)(2) and 42 U.S.C. § 9605. According to 40 C.F.R. Part 300.415Q), fund-financed removal actions and removal actions pursuant to CERCLA § 106 shall, to the extent practicable considering the exigencies of the situation, attain the Applicable or Relevant and Appropriate Requirements (ARARs) under Federal environmental law, including the Toxic Substances Control Act (TSCA), 15 U.S.C. § 2601 et sefl., the Safe Drinking Water Act (SDWA), 42 U.S.C. § 300 et seq.. the Clean Air Act (CAA), 42 U.S.C. § 7401 et seq.. the Clean Water Act (CWA), 33 U.S. § 1251 et seq.. the RCRA, 42 U.S.C. § 6901 et seq.. or any promulgated standard, applicable or relevant and appropriate requirements, criteria, or limitation under a State environmental or facility citing law that is more stringent than any Federal standard, requirements, criteria, or limitation contained in a program approved, authorized or delegated by the Administrator and identified to the President by the State in a timely manner. Off-site disposal will be necessary. Therefore, RCRA waste analysis requirements found at 40 C.F.R. §§ 261.20 and 261.30, RCRA manifesting requirements found at 40 C.F.R. § 262.20, and RCRA packaging and labeling requirements found at 40 C.F.R. § 262.30 are appropriate requirements for this removal action. Because on-site storage of hazardous wastes is not expected to exceed ninety days, specific storage requirements found at 40 C.F.R. Part 265 are not applicable, relevant, or appropriate. See 40 C.F.R. § 262.34. All hazardous substances, pollutants, or contaminants removed off-site for treatment, storage, or disposal shall be treated, stored, or disposed of at a facility in compliance, as determined by the EPA, pursuant to CERCLA Section 121(d)(3), 42 U.S.C. Section 9621(d)(3), and the following rule: "Amendment to the National Oil and Hazardous Substances Pollution Contingency Plan; Procedures for Planning and Implementing Off-Site Response Action: Final Rule." 58 FR 49200 (September 22,1993), and codified at 40 C.F.R: § 300.440. All off-site transportation of hazardous waste will be performed in conformity with RCRA and US Department of Transportation (USDOT) requirements. See generally 40 C.F.R. 263.

021978 The OSC has requested that the ODOL and the ODEQ provide state ARARs, and will to the extent practicable comply with any provided.

021979 B. Estimated Costs Extramural Costs: ERRS $ 5,250,000 Other Extramural Costs; START $ 60,000 USCG $ 150,000 $ 210,000 TOTAL EXTRAMURAL COSTS $ 5,460,000

Contingency $ 732,500 Intramural Costs; . ._. . _.. . EPA Direct Costs $ 60,000 EPA Indirect Costs $ 30,000 .1 TOTAL INTRAMURAL COSTS $ 90,000

TOTAL REMOVAL PROJECT CEILING $ 6,282,500 VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN If action is not taken at the Site, contamination from source materials will spread, and the residents — particularly the children playing in adjacent yards — will continue to be in danger of being exposed to the friable asbestos, HF, TEL and other hazardous substances that may be released. As cited above, such exposure could possibly lead to adverse health effects including death. VIII. OUTSTANDING POLICY ISSUES There are no outstanding policy issues associated with this action. I.. ENFORCEMENT See Attachment 11.

021980 X. RECOMMENDATION This decision document contains the recommended and amended removal action for the Hudson Oil Refinery in Gushing, Oklahoma, developed in accordance with CERCLA, 42 U.S.C. § 9601 et seq., and is not inconsistent with the NCP, 40 C.F.R. Part 300. This decision is based on the administrative record for the site. Because conditions at the site continue to meet the criteria defined in Section 300.415 of the NCP and meet the statutory criteria for an emergency waiver, I recommend your approval of this ceiling increase and exemption from the $2 million and 12 month statutory limits on removal actions. The total project ceiling is $6,282,500, of which an estimated $ 5,250,000 comes from the removal allowance.

APPROVED

Attachments (See II.A.6.)

021981