FIRST FIVE·YEAR REVIEW REPORT Imperial Refining Compao)' Superfund Site EPA ID No. OKOOO2024099 Ardmore, Carter County, Oklahoma
This memorandum documents the United States Environmental Protection Agency's (EPA) performance, detenninations, and approval ofthe Imperial Refining Company Superfund Site (Site) first five-year review under Section 121 (e) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 United States Code Section 962 1(c), as provided in the attached First Five-Year Review Report prepared by the Oklahoma Department of Environmental Quality on behalf of EPA.
Summary of Five-Year Review Findings
The first five-year review for the Site was performed through a review ofsite documents and site-specific requirements; a site inspection performed on June 5, 2012; interviews with personnel from the Oklahoma Department of Environmental Quality; interviews with stakeholders; and a review of data collected at the Site during the first five-year review period.
The Site remedy included: off-site disposal of principal threat wastes within the soil; reduction or elimination of soil direct conlact threats; and placement of institutional controls (in the form of conveyance notices) to inform the public of Site conditions.
The remedial action construction was initiated on February 13, 2008, and completed in February 2012. Operation and maintenance (O&M) activities will be on-going on an annual basis. The remedy should remain protective in the long-term.
During the first five-year review, there were no issues identified that prevent the remedy form being protective of human health and the environment.
Actions Recommended
Recommendations and follow-up actions associated with the Site that were identified during the five-year review include the following:
• Sediment Sampling of Ponds - Pond sediment sampling is recommended before the next five year review in order to document the continued protectiveness of the sediment overburden in the ponds. Erosion control measures seem to be working, but the site should be inspected at least annually (and after significant rainfall events) to check for erosion on or near the clay barrier where waste remains in-place.
• Enforcement of Institutional Controls - Institutional controls should remain in place and continue to be enforced.
• Site Maintenance - Erosion control measures seem to be working, but conditions need to be observed at least annually, and after rainfall events greater than a 2-year storm event. Maintenance to prevent erosion where waste remains in-place may include grading, seeding, or importing of backfill. Determinations
The selected remedy for the Site currently protects human health and the environment because the remedy is perfonning as intended and institutional controls are in place restricting land and groundwater use. The remedy will remain protective of human health and the environment in the long-tcnn provided O&M activities, continue, and the institutional controls remain in place. -,
Carl Edlund U.S. EPA Region 6 / Date Director, Superfund Division
2 CONCURRENCES:
FIRST FIVE-YEAR REVIEW REPORT IMPERIAL REFll'lNG COMPANY SUPERFUND SITE EPA ID No. OK0002024099
,-<-"'L!..C,---"-l'-'<"!7f--'<",- ,Date: 1 / J'4!r3 Brian W. Ytueller. U.. EPA Remedial Project Manager
-::-cC?,---,Cif:c:-f-t-+L7..L7t£::.=t=-:07-._<-__'Dale !E-S ! I ~ Cathy Gilmore. U.S. EPA Superfund LAfNM/OK Section Chief 6~2~4~~;~~;;~¥-Date:~ 3 Charles Faultry, U.S. EPA Associate Director, Superfund Re edial Branch
t;:::k~~r¢~~~__Date: f)~/t 1 Mark A. Peyck .5. EPA Chief, Superfund Branch, Office of Regional Counsel
C q ~ Date 2-1-2010 l'fung-Ehnillg. U.S. EPA_~ Atto } o~ee of Regional Counsel Date:;'j~
Pam hill ips, U.S. EPA Deputy Director. Superfund ivision
3
FIVE-YEAR REVIEW REPORT FOR IMPERIAL REFINING COMPANY SUPERFUND SITE CARTER COUNTY, OKLAHOMA
Prepared by
Aroo Samwel Oklahoma Department of Environmental Quality Oklahoma City, Oklahoma
JANUARY 2013 TABLE OF CONTENTS
List of Acronyms 4
Executive Summary 5
Five-Year Review Summary Form 7
1.0 lntroduction 9
2.0 Site Chronology 10
3.0 Backgronnd 12 3.1 Physical Characteristics 12 3.2 Land and Resource Use 13 3.3 History of Contamination 13 3.4 Initial Response 14 3.5 Basis for Taking Action 14
4.0 Remedial Actions 17 4.1 Remedy Selection 18 4.2 Remedy Implementation 18 4.3 System Operations/Operation and Maintenance (O&M) 2\
5.0 Five-Year Review Process 22 5.1 Administrative Components 22 5.2 Community Notification and Involvement 23 5.3 Document Review 23 5.4 Data Review 23 5.5 Site Inspection 24 5.6 Site Interviews 25
6.0 Tecbnical Assessment 26 6. t Question A: Is the remedy functioning as intended by the decision documents? , " ,.. ,.26 6.2 Question B: Are the exposure asswnptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?, 27 6.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 28 6.4 Technical Assessment Summary 28
2 7.0 Institutional Control 28 7.1 Types oflnstitutional Controls in Place at the Site 29 7.2 Effect of Future Land Use Plans on Institutional Controls 29 7.3 Plans for Changes to the Site Contamination 5tatus 29
8.0 Issues 29
9.0 Recommendations and Follow-up Actions 29
10.0 Protectiveness Statement 30
11.0 Next Review 30
Tables
Table I - Chronology of Site Events Table 2 - Current Hwnan Health Benchmarks Table 3 - Current Ecological Benchmarks Table 4 - Feasibility Study Alternatives Summary Table 5 - Annual O&M Cost Estimate Table 6 - Pond Sampling Results Table 7 - Recommendations and Follow-Up Actions
Attacbments I. Site Location Map 2. Site Map 3. Public otice 4. Documents Reviewed 5. Pond Sample Locations 6. Site Inspection Checklist 7. Interview Records 8. Photos Documenting Site Conditions 9. Deed Notices
3 LIST OF ACRONYMS
ARARs Applicable and Relevant and Appropriate RequiremenlS CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 also known as Superfund: Amended in 1986 by the Superfund Amendments and Reauthorization Act (SARA). DEQ Oklahoma Department of Environmental Quality EPA United States Environmental Protection Agency FT Feet FS Feasibility Study His Hazard Indices IC lnstiturional Control MGIKG Milligram /Kilogram NCP National Oil and Hazardous Substances Contingency Plan NPL National Priorities List: A list ofsites identified for remediation under CERCLA. ODOT Oklahoma Department ofTransportation O&M Operation and Maintenance PAHs Polynuclear Aromatic Hydrocarbons PCB Polychlorinated Biphenyl RA Remedial Action RAOs Remedial Action Objectives RD Remedial Design RI Remedial Investigation RlIFS RemediallnvestigationfFeasibility Study ROD Record of Decision: Documents selection ofcost-effective Superfund financed remedy. SARA Superfund Amendments am Reauthorization Act of 1986. (See CERCLA.) TCLP Toxicity Characteristic Leaching Procedure UST Underground Storage Tank
4 EXECUTIVE SI:MMARV
The Oklahoma Depanment of Environmental Quality (D£Q). the lead agency, and U.S. Environmental Protection Agency Region 6 (EPA), the support agency, conducted the first Five- Vear Review in accordance with Section 121(c) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 United Stales Code (USC) §9621(c). of the remedial action implemented at the Imperial Refining Company Superfund Site (Site) in Carter County, Oklahoma. The purpose of this Five-Year Review is to determine whether the selected remedy for the Site is currently protective of human health and the environment.
This is the firsl Five-Year Review for the Site. The triggering action for the Five-Year Review is the Remedial Action (RA) construction stan date on February 13.2008. The scheduled date for the Second Five-Year Review is February 2018; however, the final commitment date is five years from the signature date of this Five-Year Review Report. This Five-Year Review was conducted from May 2012 through December 2012, and its methods, findings. conclusions, and recommendations are documented in this report.
The Site was placed on the National Priorities List on May II, 2000. Based upon the concentrations and risk of arsenic and benzo(a)pyrene, the Site was determined to pose a principal threat because of the potential for direct contact through ingestion, dennal contact, inhalation and/or food-chain uptake with the contaminated surface soil, pond and creek sediment, and waste material. The original remedy in the Record of Decision (ROD) called for excavation and offsite disposal of all wastes found onsite. The EPA issued a ROD Amendmenl in February 2009 that stated in areas where excavation was impractical and potentially dangerous; the remedy amendment was to excavate and remove waste materials to the extent practicable and place a clay barrier over the non-hazardous wastes thaI remain in-place. The Remedial Action Objectives have been achieved. The assessment orthis Five-Year Review found that all threats at
the Site have been addressed, and the selected remedy is expected 10 remain protective of human health and the environment.
There are no issues that currently prevent the remedy from being protective of human health and the
environment. Erosion control measures seem to be working, but conditions need 10 be observed at least
annually, and after rainfall events greater than a 2·year storm event. ~aintenance to prevent erosion where waste remains in-place may include grading, seeding, or importing of backfill. The 2009 sampling of the pond sediment overburden revealed that contaminants arc below sediment cleanup levels. It is
5 recommended to resample the pond sediment in order to demonstrate the continued protectiveness of the remedy.
6 Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Imperial Refining Company
EPA 10: DK0002024099
NPL Status: Final
Remediation Status: Complete
Multiple DUs? Has the site achieved construction completion? No Yes, Preliminary Close Out Report 9/18/08
Has site been put into reuse? No
REVIEW STATUS
Lead agency: State
Author name (Federal or State Project Manager): Arcn Samwel
Author title: Environmental Programs Specialist
Author affiliation: Oklahoma Department of Environmental Quality
Review period: February 13, 2008 - February 13, 2013
Date of site inspection: June 15, 2012
Type of review: NPL State-lead Review number: 1
Triggering action date: February 13, 2008 Remedial Action Onsite Construction
Due date (five years after triggering action date): February 13, 2013
7 Five-Year Review Summary Form, cont'd.
Issues:
None.
Recommendations and Follow-up Actions:
Pond sediment sampling is recommended before the next five year review in order to document the continued protectiveness of the sediment overburden in the ponds. Erosion control measures seem to be working, but the site should be inspected at least annually (and after significant rainfall events) to check for erosion on or near the clay barrier where waste remains in-place.
Protectiveness Statement(s):
The remedy implemented at the Imperial Refining Company Superfund Site in Ardmore, Oklahoma is protective of human health and the environment.
8 1.0 INTRODUCTION
The Oklahoma Department of Environmental Quality (DEQ) conducted the first Five-Year Review of the Imperial Refining Company Superfund Site (Site). located in Ardmore, Carter County, Oklahoma. The purpose ofa Five-Year Review is to detennine whether the remedy at a site remains protective ofhuman health and the environment, and to document the methcx1s, findings, and conclusions in a Five-Year Review Report. Five-Year Review Reports identify issues found during the review, if any, and make recommendations to address the issues. This Five-Year Review Report documents the results ofthe review for the Site, conducted in accordance with the Environmental Protection Agency (EPA) guidance on Five-Year Reviews.
The Five-Year Review process is required by federal statute. The EPA must implement Five-Year Reviews consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121(c), 42 V.S.C. § 9621 (c), as amended, states the following:
"If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the Site. the President shall review such remedial action no less often than each five years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104] or [106]. the President shall take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results of all such review, and any actions taken as a result of such reviews."
This requirement is interpreted further in the NCP Section 300.430(f) (4Xii), 40 CFR § 300.430(f)(4)(ii), states the following:
"Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation ofthe selected remedial action."
The EPA five-year review guidance further states that a five-year review should be conducted as a matter of policy for the following types ofactions:
• A pre-Superfund Amendments and Reauthorization Act (SARA) RA that leaves hazardous substances, pollutants, or contaminants on-site above levels that allow for unlimited use and unrestricted exposure
• A pre- or post-SARA RA that, once completed, will not leave hazardous substances, pollutants,
9 or contaminants on-site above levels that allow for unlimited use and unrestricted exposure but will require more than five years to complete • A removal-only site on the National Priorities List (NPL) where the removal action leaves hazardous substances, pollutants, or contaminants on-site above levels that allow for unlimited use and unrestricted exposure and no RA has or will be conducted.
Because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure, a Five- Year Review is required.
This is the first Five-Year Review forthe Site, which has a review period from February 13,2008, to February 13,2013. The triggering action was the Remedial Action Onsite Construction start date of February 13, 2008. The Five-Year Review was conducted from May 2012 through December 2012 and its methods, findings, conclusions, and recommendations are documented in this report. This report documents the Five-Year Review for the Site by providing the following infonnation: site chronology (Section 2.0), background infonnation (Section 3.0), an overview ofthe RAs (Section 4.0), the Five-Year Review process (Section 6.0), technical assessment ofthe site (Section 7.0), institutional controls (Section 8.0), issues (Section 9.0), recommendations and follow-up activities (Section 10.0), protectiveness statement (Section 11.0), and discussion of the next review (Section 12.0). Attachment I provides the site location map. Attachment 2 provides a site map. Attachment 3 provides a public notice. Attachment 4 provides a list of documents reviewed. Attachment 5 provides the pond sample locations. Attachment 6 provides the site inspection checklist. Attachment 7 provides the interview records. Attachment 8 provides the site inspection photographs. Attachment 9 provides the deed notices.
2.0 SITE CHRONOLOGY
A Site chronology is provided in Table 1. Additional Site infonnation is available at http;//\vww.deg.state.ok.usllpdnew/SF/Superfund%20ProjectlSF%20Site%20SummariesllmperialRefiner y.html and http://www.epa.gov/region6l6sflpdffiles/imperial-ok.pd[
10 TABLE I
CHRONOLOGY OF SITE EVENTS IMPERIAL REFINING COMPANY SUPERFUND SITE
Date Event 1917-1934 Imperial Refining Company in operation. 1934-1948 Tanks and most of the buildings dismantled. September 1997 DEQ conducted a Preliminary Assessment. July 1998 DEQ conducted a Site Inspection. 1998 & 1999 EPA conducted Removal Assessments. May 11,2000 Proposed to NPL. July 27,2000 Placed on NPL. 2004 EPA conducted a Removal Action to install perimeter fencing. 2005-2007 DEQ conducted a Remedial InvestigationIFeasibility Study. September 3, 2007- Proposed Plan Comment Period. October 12, 2007 September 20, 2007 Proposed Plan Public Meeting. December 26, 2007 Record of Decision signed. January 30, 2008 Remedial Design and Remedial Action Work Plan. February 13, 2008 Remedial Action construction began. March 2008 Remedial Design & Remedial Action Work Plan Addendum. July 17, 2008 Open House. August 6 & 13,20081 Site Pre-final and Final Inspections. Seotember 10, 2008 September 18, 2008 Preliminary Close Out Report. November 3, 2008- Record of Decision Amendment Proposed Plan Comment Period. December 3, 2008 November 18, 2008 Proposed Plan Amendment Public Meeting. February 20, 2009 Record of Decision Amendment signed. December 201 0 Draft Erosion Mitigation Evaluation Report submitted. April 2011 Draft Erosion Mitigation Design Report submitted. Team meeting between EPA, DEQ, ODOT, City of Ardmore, and Chickasaw July 14,2011 Teleohone Comoany. August 19,2011 Final Erosion Mitigation Design submitted. August 26, 20 II Final Erosion Mitigation Design report accepted. November 28,2011 Erosion Mitigation field work began. February 2012 Channel construction, erosion mitigation, and surface water drainage completed.
11 June 27,2012 Five-Year Review Inspection. October 18, 2012 Final Remedial Action Inspection. December 2012 Final Remedial Action Report.
Notes: NPL National Priorities List DEQ Oklahoma Depanment of Environmental Quality ODOT Oklahoma Department ofTransportation EPA U.S. Environmental Protection Agency Region 6
3.0 BACKGROUND
This section discusses the Site's physical characteristics, land and resource use near the Site, history of site contamination, initial response to the Site, and the basis for the response.
3.1 PHYSICAL CHARACTERISTICS
The Site is the location of a former petroleum refinery that operated from 1917 to 1934. The legal description for the property is SE v., NE v., Section 20, and SW v., NW v., Section 21, T4S, R2E. Indian Meridian, which is located within the northeastern portion of the City of Ardmore, Carter County, Oklahoma. The Site is divided into three parcels: the West (36.5 acres), East (14.5 acres) and East Railroad (21 acres). The Site covers approximately 72 acres and is bisected by U.S. Highway 142 and railroad tracks operated by the BNSF Railway Company. Numerous tanks and buildings were present on the Site during refinery operation, but all ofthe tanks and most ofthe buildings were dismantled sometime between 1934 and 1948 leaving the property in much the same condition as it is in today, mixed wooded areas and open fields. A site location map is provided in Attachment I, and a site map in provided in Attachment 2.
The overall slope of the Site is toward Sand Creek, an intennittent stream that flows south to north near the eastern boundary ofthe Site. The primary physical features on the Site include Sand Creek, two ponds, and a central ridge that trends northwest to southeast. The slope east of Sand Creek is generally west towards the creek. Surface elevations range from approximately 775 feet (ft) mean sea level along Sand Creek to 850 ft mean sea level on the west side ofthe Site.
12 3.2 LAND AND RESOURCE USE
The adjacent property to the north and east of Hwy 142 is occupied by a facility that manufactures roofing shingles. Waste-water processing lagoons operated by Valero Refining arc located west of the Site, and the rest ofthe immediately adjacent property is largely undeveloped. Several small businesses, Valero's active oil refinery, and a small residential area with about a dozen houses (along the streets of Brooks,
Akron, Commerce and Industrial) are located within ~ mile north of the Site. An estimated 23,000 people live within a 4-mile radius of the Site. Because waste remains in-place, the Site is restricted to industrial use. The Site is currently not being used. The site is owned by a private land owner. A Site location map is provided in Attachment I, and a site map in provided in Attachment 2.
The onsite ponds are identified by community members as fishing areas especially during the summer; however, evidence of this activity has not been found. Pond waters are not used for domestic, recreational, or agricultural purposes. Sand Creek has been identified as a Category 4a, impaired or threatened waterbody for one or more designated uses. Sand Creek is an intennittent stream; activities around Sand Creek are expected to be limited to wading. No drinking water intakes are present within 15 miles downstream of the Site; however, three irrigation intakes are identified within this segment.
No municipal wells are identified in the area. Ardmore's municipal water system supplies drinking water to people living in the residential area north ofthe Site. All ofthe City of Ardmore's municipal water is supplied by surface water resources. In 1969, Ardmore relied on two sources for its water supply, Ardmore City Lake located four miles north of Ardmore and Ardmore Mountain Lake, located approximately 21 miles northwest of the Site. After 1969, Lake Jean Neustadt, located six miles northwest of Ardmore, and Lake Scott King were constructed to supplement Ardmore's water supply. A new water treatment plant was constructed in 1979, and Lake of the Arbuckles, located approximately 15 miles north of the Site, was put on line to provide additional capacity and storage for the City of Ardmore. Currently, there are no identified future uses of groundwater within the vicinity ofthe Site.
3.3 HISTORY OF CONTAMINATION
The Imperial Refining Company began operations at the Site in 19 I7. The eastern portion ofthe property was purchased in April 1917, and the western portion was purchased three months later. Imperial Refining Company remained active for 17 years until it went bankrupt in 1934. Due to the absence of environmental regulations during the operational period, no pennits, violations, inspections, or facility
13 operation documentation have been identified, and no records have been found that describe the types of activities that took place on the Site. There were numerous pits, piles, and water impoundments contaminated with metals and polynuclear aromatic hydrocarbons (PAHs).
The waste material was found in 12 distinct piles across the Site, one vertical tank remnant, and one underground storage tank (UST). The average thickness ofthe waste piles was approximately I ft, and the benzo(a)pyrene concentrations range from 2.5 milligrams per kilogram (mg/kg) to 570 mg/kg. In addition to the waste material, surface soil [0-1 foot (ft) below ground surface] and sediment (0·1 ft below ground surface) had elevated concentrations ofbenzo(a)pyrene and arsenic. The soil concentrations ranged from I mg/kg to 90 mglkg for arsenic and 0.04 mg/kg to 10.2 mg/kg for benzo(a)pyrene. The exposure routes of concern were direct contact and ingestion. Sediments in onsite intermittent drainages were indistinguishable from Site soils except by their location within drainages; therefore, the drainage sediments were considered soils for the remedial action. The sediment concentrations range from 4.7 mglkg to 33.4 mglkg for arsenic and 0.062 mg/kg to 1.3 mg/kg for benzo(a)pyrene.
3.4 INITIAL RESPONSE
The DEQ conducted a Preliminary Assessment in September 1997 and a Site Inspection in July 1998. Based on the results, elevated levels of benzene, ethylbenzene, toluene, xylenes and polynuclear aromatic hydrocarbons (PAHs) were present. DEQ referred the property to the EPA for further action.
In 1998, EPA conducted a Removal Assessment to determine the absence or presence of hazardous materials and the types and concentrations of hazardous substances. A second Removal Assessment was conducted in 1999 to estimate waste pile volumes and evaluate disposal options.
In May 2000, the Site was proposed to the National Priorities List (NPL). In July 2000, the Site was placed on the NPL. In 2004, EPA conducted a Removal Action to install a perimeter fence. From 2005 to 2007, ODEQ, as the lead agency for the RemediallnvestigationlFeasibility Study (RIlFS), with the EPA as the support agency, conducted the RI/FS. The RlIFS identified the types, quantities, and locations of contaminants found and developed ways to address the contamination. Also, a Human Health Risk Assessment and an Ecological Risk Assessment were performed to determine the current and future effects of contaminants on human health and the environment.
14 3.5 BASIS FOR TAKING ACTION
The purpose of the response actions conducted at the Site was to protect public health and welfare and the environment from releases or threatened releases of hazardous substances from the site. From early 2005 through early 2007, DEQ conducted a RemediallnvestigationfFeasibility Study (RlIFS). The RI identified the types, quantities, and locations of contaminants, and the FS developed options to address the contamination. Waste piles found at the Site were characterized as dry, asphalt-like tar mats associated with oil-contaminated soil on top ofoil-stained clay. The contaminants of concern were mostly PAHs, specifically benzo(a)pyrene; and metals, primarily arsenic.
Human Health Impacts The human health risk assessment conducted during the R1 indicated that carcinogenic risks posed by the site were attributed to arsenic, benzo(a)pyrene, and dibenz(a,h)anthracene in the soil. These chemicals generated risks in excess of JE-05 (greater than1.4E-05) in site soil. Cancer risks associated with the sediment scenarios that generated risks in excess of 1E-05 (greater than I.4E-05) included arsenic and benzo(a)pyrene. The current human health benchmarks for arsenic and benzo(a)pyrene are shown in Table 2.
TABLE 2
CURRENT HUMAN HEALTH BENCHMARKS
ROD Current Basis for Risk at Cleanup Industrial Soil Cleanup Benchmark* Cleanup Level Level Level Arsenic 20 mg/kg 20 mg/kg Background 5.00E-05
Benzo(a)pyrene 5.27 mg/kg 5.27 mg/kg Human Health 2.50E-05 , ·EPA s Integrated Risk InformatiOn System
Non-carcinogenic health effects can range from rashes, eye irritation, and breathing difficulties to organ damage, birth defects, and death. Non-cancer hazard quotients associated with each individual chemical for each exposure route are less than 1. Non-cancer hazard indices (HIs) associated with each individual chemical for each exposure medium are less than 1. However, when a HI for all chemicals associated with an exposure route or exposure medium is calculated, the HIs are less than one except for exposure to soil through ingestion. The risk assessment identified a HI>l due to exposure to soil in the West Parcel (HI=J .90E+00) and East Parcel (HI=2.70E+00) for future child residents. Although several contaminants
15 contributed to the total non·cancer risk, many are co-located with arsenic, benzo(a)pyrene and the waste material.
Environmental Impacts The ecological risk assessment conducted during the RI demonstrated that certain chemicals associated with the Site (aluminum, arsenic, barium, copper, manganese, selenium, thallium, and vanadium) posed a significant and immediate risk within the upland habitat ofthe Site. Within the open water habitat, sediments found to significantly reduce survival and gro\\1h of amphipods; thereby deducing a significant and immediate risk to sediment·dwelling (i.e., benthic invertebrates) organisms in both the West and East Pond. Within the wet area habitat, several chemicals (antimony, arsenic, copper, lead, manganese, zinc, PCB, 4,4'-DDT, benzo(a)pyrene, chrysene, and pyrene pose a significant and immediate risk; while chromium, iron, nickel, benz(a)anthracene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)f1uoranthene, dibenz(a,h)anthracene, fluoranthene, and indeno(l ,2,3·cd)pyrene) posed a potential risk to wildlife receptors.
Benzo(a)pyrene and arsenic are the primary risk drivers. These risk drivers arc co-located with other metals and organics as well as areas of ecological risk associated with the upland habitat (soil) and wet areas (sediment not in the ponds or creek). The current ecological benchmarks for arsenic and benzo(a)pyrene arc shown in Table 3.
TABLE 3
CURRENT ECOLOGICAL BENCHMARKS
ROD Current Basis for Risk at Cleanup Industrial Sediment Cleanup Benchmark* Cleanup Level Level Level Arsenic 20 mg/kg 20 mg/kg Background 5.00E-05
Benzo(a)pyrene 0.782 mglkg 0.782 mg/kg Ecological not applicable *EPA's Integrated Risk InformatIOn System
Feasibility Study The FS developed and evaluated a range of alternatives to remediate the soil, sediment, and waste contamination. A total of20 alternatives were assembled and then screened out after being evaluated for effectiveness, implementability, and cost relative to Site conditions. Those alternatives not screened out are listed in Table 4.
16 TABLE 4
FEASIBILITY STUDY ALTERNATIVES SUMMARY
Medium RIlFS Alternative Description SS-I No Action Institutional Controls, Natural Attenuation, Engineering Controls, and 55-2 Lon~-term MonitorinR SS-J Cap in Place with Institutional Controls Surface Soil SS-4 Consolidate and Cap with Institutional Controls (55) & Intermittent 55-5 In situ Landfarming and Stabilization with Institutional Controls Drainage 55-6 Excavation, Landfarming, and Stabilization with Institutional Controls Sediments Excavation, Thermal Desorption, and Stabilization with Institutional 55-7 Controls 55-8 Excavation and Offsite Disposal 5S-9 Excavation and Consolidation in Pond(s) with Institutional Controls P-I No Action P-2 Sediment Capping with Institutional Controls East & West Pond P-J In situ Landfarming, Excavation, and Offsite Disposal Sediments (P) P-4 Excavation and Offsite Disposal P-S Dredging and Offsite Disposal SC-I No Action Sand Creek SC-2 Excavation and Offsite Disposal Sediments (SC) SC-J Excavation and Onsite Disposal with Institutional Controls WM-I No Action Waste Materials WM-2 Excavation and Offsite Disposal (WM) WM-J Excavation and Offsite Recycle
4.0 REMEDIAL ACTIONS
This section discusses the remedial action objectives, selected remedy, remedy implementation, and operation and maintenance (O&M) activities.
Remedial Action Objectives Remedial Action Objectives (RAOs) are the cleanup objectives for protection of human health and the environment. RAOs were developed for Site soil, sediment, and waste material. For surface soil the objective is to prevent exposure to current and future human and ecological receptors through ingestion,
17 dennal contact, and inhalation of contaminated soil containing arsenic and benzo(a)pyrene concentrations in excess of5E·05 and 2.5E·05 excess cancer risk respectively. For pond and creek sediment the objectives are to prevent exposure to current and future human receptors through ingestion, dennal contact, and inhalation of contaminated sediment containing arsenic concentrations in excess of 5E-05 excess cancer risk and to prevent exposure to current and future ecological receptors through direct contact, food-chain uptake, and incidental ingestion of contaminated sediment containing benzo(a)pyrene concentrations in excess of levels that are protective ofecological receptors. For waste material, the objectives are to prevent exposure to human and ecological receptors through ingestion and dennal contact and prevent further migration of waste material contamination to Site and/or offsite soil, sediment, groundwater, and surface water.
4.1 REMEDY SELECTION
A proposed plan for the Site was issued in September 2007, presenting the preferred alternative of excavation and offsite disposal for the waste, contaminated soil, and contaminated sediment at the Site. The EPA Regional Administrator for Region 6 signed the Record of Decision (ROD) on December 26, 2007. The remedy selected was excavation and offsite disposal of soil, sediment, and waste material. The soil cleanup levels were based on a residential scenario, 20 mglkg for arsenic and 1.55 mglkg for benzo(a)pyrene. The sediment cleanup levels were 20 mglkg for arsenic and 0.782 mglkg for benzo(a)pyrene. These cleanup levels are in line or below the latest toxicity toxicological benchmarks (see Tables 2 & 3). Two rounds of confinnation sampling results from the east and west ponds collected during the remedial action were reviewed. The results were all below sediment cleanup levels and show that the remedy remains protective.
4.2 REMEDY IMPLEMENTATION
The EPA began onsite Remedial Action construction on February 13,2008. During remedial action, a total of approximately 104,493.5 cubic yards of wasteIs oil and approximately 1699.5 cubic yards of sediment were removed from the Site and shipped to an offsite landfill. As excavation activities progressed, waste was found to exist in locations where removal would be both impracticable and dangerous. Excavated areas were backfilled, graded and seeded after confinnation sampling indicated that cleanup levels have been met.
18 ROD Amendment A ROD amendment proposed plan for the Site was issued in November 2008, presenting an additional containment component where excavation would be impracticable and potentially dangerous to the original excavation and offsite disposal remedy. On February 20. 2009, the EPA Superfund Division Director for Region 6 signed a ROD amendment.
During the remedial action, waste was found along the borders of the property, throughout the ponds, and surrounding a high pressure gas line. Excavation and removal of waste along the borders was not feasible, safe or practical due to its proximity to sloped areas supporting the highway, the rail line, and business propel1)', as well as its depth under significant volumes of uncontaminated overburden. Based on excavation activities and delineation pits throughout the east and west ponds, surface sediment exceeding the ecological cleanup numbers was completely removed. Due to the presence of 18 inches of uncontaminated overburden, the complete removal of surface sediment exceeding the ecological cleanup numbers, and the unknown locations at depth throughout the remaining areas oCthe ponds, no further excavation will occur in the ponds. Excavation in close proximity to the high pressure gas line was not recommended or considered safe; therefore, waste remains around the gas line within the easement boundaries.
Because waste remains in-place, cleanup levels for the Site were reevaluated and changed from residential to industrial land use. The soil cleanup level for benzo(a)pyrene changed to 5.27 mglkg. The soil cleanup level is still in line with the latest toxicity toxicological benchmarks (see Table 2). The soil cleanup level for arsenic did not change, and no change was made to sediment cleanup levels. The Site is restricted to industrial use through the enforcement of institutional controls (ICs). The vapor intrusion pathway is incomplete since there are no buildings at the Site. No human exposure under the indoor air pathway is expected. Jfreuse and construction is proposed, this pathway should be considered.
The remedy activities included in this ROD Amendment to supplement the 2007 ROD remedy of Excavation and Offsite Disposal included material being left in-place, the use of institutional controls, and the implementation of long-term monitoring are listed below.
Ponds: Due to the presence of uncontaminated overburden, the complete removal of surface sedimem exceeding the ecological cleanup numbers, and the unknown locations of waste at depth throughout the remaining areas of the ponds, no further excavation occurred. Excavated areas were backfilled with clean material, and an Ie was placed on the ponds. O&M activities will be conducted by DEQ and five year reviews will be conducted by EPA.
19 Northern Site Boundary with Atlas Roofing, Inc.: An engineering evaluation identified suitable slope stabilization and construction activities and an appropriate backfill material for placement on the waste. As backfill material was imported, a slope of no greater than 3 feet vertical to I foot horizontal was maintained along this border to minimize erosion and facilitate slope suppoI1, drainage control, and re-vegetation. Atlas Roofing, Inc. placed an IC on the property, O&M activities will be conducted by DEQ, and five year reviews will be conducted by EPA.
Site Boundaries with Hwy 142: An engineering evaluation identified suitable slope stabilization and construction activities and backfill material for placement on the waste. As backfill material was imported, a slope of no greater than 3 feet vertical to 1 foot horizontal was maintained along this border to minimize erosion and facilitate slope support., drainage control, and revegetation. The Oklahoma Department ofTransportation placed an IC on Hwy 142 and its associated utility easements. O&M activities will be conducted by DEQ in coordination with the Oklahoma Department ofTransportation, and five year reviews will be conducted by EPA.
Northern and Western Boundaries with Valero Refinery property: Backfill of the excavated areas and areas above the waste material provides for slope control, drainage control, and establishment of vegetation. As backfill was placed, the drainage along this boundary was re directed away from these waste areas in an effort to mitigate erosion, ensure drainage control, and facilitate revegetation. An IC was placed on the property. At this time, Valero is working with the DEQ's Brownfields program to develop plans related to the waste that remains on their property. O&M activities will be conducted by DEQ. and five year reviews will be conducted by EPA.
Oneok Gas Pipeline: Excavation in close proximity to the high-pressured gas line was unsafe so the waste was left around the gas pipeline. As backfill material was imported, a gentle slope was maintained along this border to minimize erosion and facilitate slope support, drainage control, and re-vegetation. The clay backfill was placed on either side of the pipeline and clay overburden, at a depth of approximately two feet, was placed along the top of the gas line to provide a barrier for the pipeline and promote surface water runoff. An IC was placed on the property, ODEQ will conduct O&M activities in coordination with Oneok, and five year reviews will be conducted by EPA.
Site Boundary with BNSF Railway: Excavation in close proximity to the rail line may have
20 altered the stability and integrity ofthe rail line so the waste was left in place. Backfill ofthe excavated areas and areas above the waste material provides for slope control, drainage control. and establishment of vegetation, BNSF placed an Ie on the railroad right-of-way. O&M activities will be conducted by ODEQ in coordination with BNSF, and five year reviews will be conducted by EPA to ensure protectiveness.
Erosion Mitigation The Site is monitored routinely for areas of erosion and lack ofvegctative gro\\1h. Actions that have been implemented to address identified erosion areas include seeding,. fertilization, silt fencing, area grading, wood mulching, rip-rap placement, and water discharge management control. In December 2010, a Draft Erosion Mitigation Evaluation report was submitted for Agency (EPA) review. A Draft Erosion Mitigation Design report with the selected alternative was submitted in April2011 for Agency (EPA) review. A team meeting was held at the Site on July 14, 20 I 1, between EPA, DEQ, the Oklahoma Department of Transportation, the City of Ardmore, and the Chickasaw Telephone Company to discuss the design in the field and provide additional comment and clarification. On August 19,20 II, a Final Erosion Mitigation Design Document was submitted and accepted as final by EPA on August 26, 2011. Erosion Mitigation field work began November 28, 2011. Field work related to channel construction, erosion mitigation, and surface water drainage was completed in February 2012. These elements are inspected to monitor and assess continued functionality.
4.3 SYSTEMS OPERATIONS/OPERATION AND MAITENANCE (O&M)
Site operational and functional activities were conducted by EPA until DEQ took over site Operation and Maintenance in December 20 12. An updated O&M Plan for the Site was submitted to EPA August 3, 2012. The scheduled tum-over of activities is December 2012. Because waste remains in-place on the Site, O&M activities will be conducted by DEQ no less often than once per year and will be required to ensure remedy protectiveness. O&M activities will include site inspections for erosion, property uses. and enforcement of the ICs. This activity may also include maintenance of the slopes through grading, seeding, or importing of backfill that may be needed. Maintenance of[hese slopes will provide continued slope support, continued drainage control, continued vegetation growth, and ensure that exposure and migration is not occurring. Areas of primary interest will include the slopes along Hwy 142, Atlas Roofing Inc., Oneok Gas Pipeline, BNSF Railway, and Valero Refining. Table 5 shows the estimated cost for O&M.
21 TABLE 5
ANNUAL O&M COST ESTIMATE
Description Quantity Units Cost per Total Estimated Unit Cost Soil for Erosion 75 Cubic Yard $23.00 $1,725.00 Seeding 2 Acre $\0.00 $20.00 Backfill Eauioment I Week $60.00 $2,500.00 Backfill Equipment Operator 10 Hour $100.00 $600.00 Field Staff for Seeding and Backfill $2,000.00 Site Inspection $800.00 Subtotal $7.645.00 Contingency 20% $1,529.00 SlIblOta! $9,174.00 Project Management 5% $458.70 TOTAL ANNUAL O&M COST S9,632.70
S.O FIVE-YEAR REVIEW PROCESS
This section presents the process and findings ofthe Five·Year Review. Specifically, this section presents the findings of administrative components, community notification and involvement, document review, data review, a site inspection, and interviews.
5.1 ADMINISTRATIVE COMPONENTS
The five-year review team consisted of Aron Samwel of the DEQ. The review was conducted from May 2012 through December 2012 and included a site inspection and document review. The tasks for the five year review included:
1. A press release stating thai a five-year review was underway, 2. Review of existing documents and data, 3. Inspection ofthe site, 4. Conducting site interviews, and 5. Preparation of the five-year review report (to be completed by February 2013).
22 5.2 COMMUNITY NOTIFICAnON AND INVOLVEMENT
A notice was published in the The Daily Ardmoreite on June 6, 2012 and provided in Attachment 3 informing the public orthe initiation of the Five·Year Review Process, a brief history or the Site, remedial goals and actions, and when and where the Five·Ycar Review Report may be found. Upon signature, the Five-Year Review Report will be placed in the infomlation repositories for the Site; the DEQ office in Oklahoma City, Oklahoma; the Ardmore Public Library in Ardmore, Oklahoma; and the EPA Region 6 office in Dallas, Texas. A notice will then be published in the local newspaper to summarize the findings of the review and announce the availability of the report at the information repositories.
5.3 DOCUMENT REVIEW
This Five·Year Review for the Site included a review ofrelevant site documents, including site assessment reports, removal assessment reports, RVFS, ROD proposed plans, RODs, and erosion reports. On June 15,2012, DEQ chei:ked the public record at the local site repository which was complete and accessible. The complete list of documents reviewed during this Five-Year Review is provided in Attachment 4.
5.4 DATA REVIEW
All backfill confinnation sample results met the established cleanup levels. All analytical data was independently validated, and the EPA and DEQ detennined that analytical results were accurate to the degree needed to assure satisfactory execution of the remedial action. The Site is restricted to industrial use through the enforcement of institutional controls (lCs). The vapor intrusion pathway is incomplete since there are no buildings at the Site. No human exposure under the indoor air pathway is expected. If reuse and construction is proposed, this pathway should be considered. The sediment cleanup levels were 20 mglkg for arsenic and 0.782 mglkg for benzo(a)pyrene. The current toxicological benchmarks remain 20 rng/kg for arsenic and 0.782 mglkg for benzo(a)pyrene. Two rounds ofconfinnation sampling results from the east and west ponds collected during the remedial action were reviewed. The results were all below sediment cleanup levels and show that the remedy remains protective. A map showing sample locations is provided in Attachment 5. Table 6 summarizes the results:
23 TABLE 6
POND SAMPLING RESULTS
Sample Location Date Arsenic Results Bcnzo(it)pyrcnc Results Sampled (mglkg) i~./k.) Current Toxicological Benchmark 20 0.782 (same as ROD Cleanup Level)
East Pond· I 04/14/09 16.3 0.130 J
East Pond - I 07/21/09 16.2 <0.489 U
East Pond· I - Duo 07/21/09 <7.3 U < 0.553 U
East Pond - 2 04114109 11.5 0.053 J
East Pond - 2 Dup 04114/09 11.1 0.039 J
East Pond - 2 07/21/09 <7.8 U <0.525 U
East Pond - 3 04/14/09 6.5 0.290 J
East Pond - 3 07121/09 < 6.0 U < 0.477 U
West Pond - I 04114/09 9.7 < 0.440 U
West Pond - 1 07/21/09 <9.9U < 0.528 U
West Pond - 2 04114109 9.4 0.059 J
West Pond - 2 07/21/09 < 10.3 U <0.544 U
West Pond - 3 04114/09 17.7 0.310 J
West Pond - 3 07121/09 9.7 < 0.522 U
5.5 SITE INSPECTION
A site inspection was conducted on June 15, 2012, to assess the condition of the Site and the measures employed to protect human health and the environment from the contaminants still present at the Site. Attendees included: (1) Aro" Samwei ofthe DEQ; (2) Dennis Datin ofthe DEQ; (3) Amy Brittain ofthe DEQ; (4) Liberty Galvin of the DEQ; (5) Blake Rudd of Ardmore Public Utilities; (6) Katrina Higgins Coltrain of the EPA; (7) and Brian Yost of EA Engineering. The site inspection checklist is included in
24 Attachment 6. Site interview records are provided in Attachment 7. A photographic log ofthe inspection is included in Attachment 8.
The inspection team investigated the Site within the Site boundary. The Site's general appearance was excellent and well maintained. No evidence of erosion or potential contaminant migration was seen on the Site. The team inspected all areas where waste remains in-place. The clay barrier was inspected for exposure of source materials. No evidence of erosion was seen on the clay overburden. The backfill material was well vegetated. The slopes were no greater than three feet to one foot horizontal. On the ponds, no erosion or scouring of the uncontaminated clay overburden was seen. No digging, excavating, or activities that would cause erosion were seen. No evidence of residential, recreational, or groundwater use was seen at the Site. The gates were secured, and no evidence of trespassing or vandalism was seen.
There was no evidence of contaminant migration from Valero to Imperial Refining Company property during the site inspection.
5.6 INTERVIEWS
[n accordance with the community involvement requirements ofthe Five-Year Review process, key individuals to be surveyed were identified by the DEQ. Completed survey forms for the following individuals are included in Attachment 7:
• Blake Rudd, Ardmore Public Utilities • Brian Yost, EA Engineering • Amy Brittain, DEQ • Dennis Datin, DEQ • Jeff Pearl, ODOT • Christopher Beck, Atlas Roofing • Katrina Higgins-Coltrain, EPA • Laura Schneider, owner • Chad Graves, Valero (declined) • W. T. and Betty Thomason, neighbors (not interviewed)
No continuing or unresolved issues were discovered during the interview process.
25 6.0 TECHNICAL ASSESSMENT
An overall assessment of the remedy implemented allhe Site was conducted 10 confinn thallhe selected remedy is operating according 10 the ROD expectations and is still protective of human health and the environment. The assessment was used to primarily answer the following questions, which determines the protectiveness finding of the remedy:
• Is the remedy functioning as intended by the decision documents? • Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? • Has any other information come into light that could call into question the protectiveness of the remedy?
6.1 QUESTION A, IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS?
The decision document for the Site is the February 20, 2009 amended ROD. All activities at the Site were consistent with the ROD, as amended, with the January 2008 Remedial Design and Remedial Action Work Plan, with the March 2008 Remedial Design & Remedial Action Work Plan Addendum, and with the December 2010-August 2011 Erosion Mitigation Evaluation & Design Reports. A lOtal of approximately 104,493.5 cubic yards of waste/soil and approximately 1699.5 cubic yards of sediment were removed from the Site and shipped to an offsite landfill. In areas where excavation was impractical and potentially dangerous; the remedy was a clay barrier over the waste that remains in-place. An waste material that remains in-place has minimum two feet cover of uncontaminated backfill on top to fonn a barrier. Exposure and migration is prevented because of this barrier. Because the clay barrier/uncontaminated overburden is functioning and pond sediment data was below sediment cleanup levels, no risk recalculation/assessment was necessal)' for this Site. Infiltration of precipitation is retarded, thereby reducing the possibility of leaching, and all toxicity characteristic leaching procedure (TCLP) data indicate that the leaching potential of this material is low as all results have been below regulatory limits for characteristic hazardous waste categories and land disposal restrictions. The inspection and maintenance of the barrier according to the O&M plan insures the barrier's integrity remains in-place.
All RAOs have been met, and cleanup levels were attained and confirmed by soil and sediment confinnation sampling. The backfill met site cleanup levels and standards. Erosion mitigation actions are working as intended, and erosion issues have been corrected. Erosion caused by large storms that moved
26 through the area after construction has not been seen. The vegetation is thick, and well seeded; providing for soil stability and reducing the potential for erosion.
Sampling of the pond sediment has revealed that contaminants are below sediment cleanup levels, which supports the protectiveness ofthe remedy. Sediment sampling is recommended in the next live years in order to evaluate the continued protectiveness ofthe sediment overburden in the ponds. Access control to the site is adequate with the chain link fence in good condition and locks are on the gates. DEQ has completed and filed all ofthe necessary ICs restricting site use. O&M ofthe Site began in December 2012, and will easily be accomplished with annual site inspections for erosion, property uses, and enforcements of the ICs. Maintenance of the slopes may include grading, seeding, or importing backfill to provide continued slope support, drainage control, and vegetation growth to ensure protectiveness. Since O&M activities have just begun, opportunities for optimization will be considered in the next five year review.
6.2 QUESTION B: ARE THE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT TIlE TIME OF REMEDY SELECTION STILL VALID?
On February 20, 2009, the amended ROD restricted the Site to industrial land use. The human heallh risk assessment evaluated risk for the industrial worker and shows that the excess lifetime cancer risk for an industrial worker fell within the risk range of IE-04 to IE-06 and the non..carcinogenic risk is less than I. The excess lifetime cancer risk is primarily associated with the ingestion and dennal contact pathways related to arsenic and benzo(a)pyrene in the soil and sediment. Using the assumptions and calculations presented in the human health risk assessment. the cleanup level for benzo(a)pyrene (2.5E-OS excess lifetime cancer risk) under an industrial reuse scenario is 5.27 mglkg, which is within EPA's cancer risk range of IE-06 to IE-04 and is considered protective ofhuman health and the environment. There have been no changes in the exposure assumptions or physical conditions of the Site that would affect the protectiveness ofthe remedy. The remedial action complies with all applicable and relevant and appropriate requirements (MARs). There were no newly promulgated ARARs during this five-year review. The ARARS for the remedial action, including the Endangered Species Act, the Executive Order on Floodplain Management, the National Emission Standards for Hazardous Air Pollutants, the Oklahoma Clean Air Act, and ODEQ's Air Pollution Control rules were met. The contaminants left onsite were compliant with the Oklahoma Solid Waste Management Act, 27 A.O.S. § 2-10-101 et seg. and ODEQ's Solid Waste Management rules, OAC 2S2:S IS. Current and future zoning maps produced by the City of Ardmore depict portions ofthe Site west ofHwy 142 and east of the railroad tracks as light
27 industrial and the portion of the Site east ofHw), 142 and west ofthe railroad tracks as heavy industrial. There have been no changes in land use of the surrounding areas.
ICs restrict the Site to industrial use only. They prohibit digging below five feet, excavation, and any activi£y that cause erosion. Two ofthe deed notices prohibit withdrawal ofgroundwater. The vapor intrusion pathway is incomplete since there are no buildings at the Site. No human exposure under the indoor air pathway is expected. If reuse and construction is proposed, this pathway should be considered. There are also no changes in exposure pathways for the industrial worker or trespasser. There have been no changes to toxici£y criteria or contaminant characteristics or standards for arsenic and benzo(a)pyrene (no revisions have been made to EPA's Integrated Risk Infonnation System for these chemicals). There have been no new contaminants or contaminant sources identified at the Site. Because there is no change to the exposure pathways or contaminants ofconcern the remedial action is perfonning as expected and RAOs are currently being achieved.
6.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?
At this time, there is no other infonnation that calls into question the current protectiveness of the Site remedy.
6.4 TECHNICAL ASSESSMENT SUMMARY
A review of the documents, sampling data, interviews, and the results from the site inspection indicates that the remedy selected in the amended ROD is functioning as intended. There have been no changes in the exposure assumptions or physical conditions of the site that would affect the protectiveness of the remedy. There have been no changes in the toxicity factors during the five-year review period, and there has been no change to the standardized risk assessment methodology that would affect the protectiveness of the remedy. The ICs will help further protect human health and the environment. There is no other inronnation that calls into question the protectiveness of the remedy. The remedy implemented at the Site is currently protective ofhuman health and the environment, and the long-term protectiveness of the remedial action will be verified by annually inspections and pond sediment sampling before the next five year review to document continued protectiveness of the remedy.
28 year review to document cominued protectiveness of the remedy.
7.0 INSTITUTIONAL CONTROLS
ICs are generally defined as non-engineered instruments such as administrative and legal tools that do not involve construction or physically changing the site and that help minimize the potential for human exposure to contamination and/or protect the integrity of a remedy by limiting land and/or resource use. ICs can be used for many reasons including restriction of site use, modifying behavior, and providing infonnation to people. rcs may include deed notices, easements, covenants, restrictions, or other conditions on deeds, and/or groundwater and/or land use restriction documents. The following paragraphs describe the ICs implemented at the site, the potential effect of future land use plans on ICs, and any plans for changes to site contamination status. The following sections describe the institutional controls implemented at the Site, the potential effect of future land use plans on institutional controls, and any plans for changes to site contamination status.
7.1 TYPES OF INSTITUTIONAL CONTROLS IN PLACE AT THE SITE
Seven ICs restricting site reuse to non residential are in place for the Site and were filed with the Carter County Clerk. They prohibit digging below five feet, excavating, or any activity that cause erosion. Two of the deed notices prohibit withdrawal of groundwater. They also prohibit residential, recreationar, or child-care usc at the Site. The notices will run with the land, and no change of ownership will change the land use restrictions. Copies of these notices are provided in Attachment 9. On June 25, 2012, the DEQ checked the Oklahoma Public land Records website at okcountyrecords.com for Carter County and found the deed notices were readily available to the public. No activities were observed on the inspection that would have violated the ICs.
7.2 EFFECT OF FUTURE LAND USE PLANS ON INSTITUTIONAL CONTOLS
No future land uses have been established or are anticipated for the Site that would require an adjustment to the institutional controls currently being implemented.
29 7.3 PLANS FOR CHANGES TO SITE CONTAMINAnON STATUS
No changes to the status ofcontamination at the Site are anticipated.
8.0 ISSUES
There are no issues that currently prevent the remedy from being protective of human health and the environment.
9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS
This section describes the recommendations and follow 6 up actions associated with the Site that were identified during the Five-Year Review:
• Ponds- 2009 sampling of the pond sediment overburden revealed that contaminants are below sediment cleanup levels. It is recommended to resample the pond sediment in order to demonstrate the continued protectiveness ofthe remedy.
• Enforcement of Institutional Controls -Institutional controls should remain in place and continue to be enforced.
O&M- Erosion control measures seem to be working, but conditions need to be observed at least annually, and after rainfall events greater than a 2-year storm event. Maintenance to prevent erosion where waste remains in·place may include grading, seeding, or importing of backfill.
30 TABLE 7
RECOMMENDATIONS AND FOLLOW-UP ACTIONS
Affects Recommendations and Party Oversight Milestone Protectiveness Issue Follow-Un Actions Resoonsible Al!eocv Date IYeslNol Sediment sampling is Before Next recommended in order to re Five Year evaluate the continued . Pond Review protectiveness (sediments not DEQ EPA No sediment (preferably above cleanup levels) orthe in the next sediment overburden in the I-2 years) I DOnds. Follow O&M plan, Within I conditions should be year of O&M observed at least annually and DEQ EPA completion No after rainfall events greater of the RA than 3.8 inches in 24 hours. Report
10.0 PROTECTIVENESS STATEMENT
Most orthe waste was excavated and disposed of offsite, but in areas where excavation was impractical and potentially dangerous, the remedy was a clay barrier over the waste that remains in-place. Based on the information available during the first five-year review, the remedy implemented at the Imperial Refining Company Superfund Site in Ardmore, Oklahoma is protective of human health and the environment.
11.0 NEXT REVIEW
The Site requires ongoing Five-Year Reviews. The next review will be conducted within the next five years, but no later than February 13, 2018.
31 Attachment t Site Location Map
32 /j N
LOCATION MAP OF THE IMPERIAL REFINERY SUPERFUND SITE ARDMORE, CARTER COUNTY, OKLAHOMA
33 Attachment 2 Site Map
34 VVaste Len in Place at the Imperial Refinery Superfund Site, Ardmore, OK
o 100 200 400 I I I Feet
Map created by Aron Samwlli 01 October 4, 2012,
35 Attachment 3 Public Notice
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38 Attachment 4 Documents Reviewed
39 Documents Re\'iewed
Oklahoma Department of Environmental Quality (DEQ). Preliminary Assessmem Imperial Refining Company. Carter County: Ardmore. Oklahoma. September 24, 1997.
Oklahoma Department of Environmental Quality. Imperial Refining Company Sile Inspeclion. Carter COUIlIY, Oklahoma. CERCUS Id NUII/ber OK000202-1099. July 31,1998.
Ecology and Environment, Inc. (prepared for EPA). Removal Assessmem ReporJ for Imperial Refining Company. Ardmore. Carter County, Oklahoma. May 28, 1999.
U.S. Environmental Protection Agency. Comprehensive Five-Year Review Guidance. EPA 540 R-01-007. June 2001.
Weston Solutions, Inc. (prepared for DEQ). Final Remedial Investigation Report, Imperial Refining Company. November 14,2006.
Weston Solutions, Inc. (prepared for DEQ and EPA). FeasibililY Sll/dy for Ihe Former Imperial Refining Company Sile. Ardmore. Oklahoma. April 2007.
Oklahoma Department of Environmental Quality. Record ofDecision Proposed Plan. Imperial Refining Company Superfund Sile, Ardmore, Oklahoma. September 2007.
U.S. Environmental Protection Agency. Record of Decision SummOlY. Imperial Refining Company Superfllnd Sile. Ardmore, Carter County, Oklahoma. OK0002024099. December 2007.
Oklahoma Department of Environmental Quality and U.S. Environmental Protection Agency. Imperial Refining Company Supel:fimd Sile, Community Involvemenl Plan. July 8, 2003. Revised: February 1,2005. Revised: January 8, 2008.
Weston Solutions, Inc. (prepared for EPA). Remedial Design and Remedial Action Work Plan for Imperial Re.{tning Company. March 2008.
U.S. Environmental Protection Agency. Preliminwy Close QUI Repor!. Imperial Refining Superfund Site. Ardmore. Carter Counly. Oklahoma. CERCUS ID OK0002024099. September 18, 2008.
Oklahoma Department of Environmental Quality. Record of Decision Amendmem Proposed Plan. Imperial Refining Company Superfund Site. Ardmore, Oklahoma. November 2008.
U.S. Environmen(al Protection Agency. Record of Decision Amendmenl Summmy. Imperial Refining Company Superfund Site. Ardmore. Carter COIlI1ly. Oklahoma. OK0002024099. February 2009.
40 EA Engineering, Science, and Technology, Inc. (prepared for EPA). Final Erosion Mitigation Design Report, Operational & Functional Activities. Imperial Refining Superfimd Sire. August 2011.
41 Attachment 5 Pond Sample Locations
42 SedIlTl4lnI Sampling .YJ21.2Ol» --- "-'" Aof'*'ll ~ so.
43 (Close-up View of Pond Sample Locations)
44 Attachment 6 Site Inspection Checklist
45 FIVE-YEAR REVIEW SITE VISIT CHECKLIST
I. SITE INFORMAnON
Site Name: Imperial Refining Company Date of Inspection: Junc 15.2012 Location and Region: Ardmore. Oklahoma (Region EPA 10: OKDOO02024099 6) Agency leading the five-year review: Oklahoma Weather/temperature: Cloudy, 70°F Department of Environmental Quality
Remedy Indudes: (Check all that apply) ~ Landfill cover/containment (Clay Barrier) D Groundwater pwnp-and-treatment D Access controls D Surface water collection and treatment ~ Institutional controls D Other-Leachate collection and treatment Attachments: ~ Inspection team roster attached [gJ Site map attached to report
II. INTERVIEWS (Check all that apply) I. Site Manager Katrina Higgins-Coltrain Remedial Project ManagerlEPA 7/3/2012 Name Title Date Interviewed: l:8J bye-mail 0 at site D by phone E-mai I CoItrain.Katrina1v,epamai I.epa.gOY Problems, suggestions: ~ Report attached Survey fonn attached to report
2. Staff Brian Yost Project ManagerlEA 6/15/2012 Name Title Date Interviewed: D by e-mail ~ at sitc D by phone E-mail BYost(a)eaesLcom Problems, suggestions: ~ Report attachcd Survey fonn attached to report
3. Local regulatory authorities and response agencies (i.e.; State and Tribal offices, emergency response office. police department, office of public health or environmental health, zoning office, recorder ofdeeds, or other city and county offices, etc.). FiJI in aU that apply.
Agency City ofArdmore Contact Blake Rudd Utilities Director 6/1512012 (580) 221-5401 Name Title Date Phone no. Problems, suggestions: ~ Report attached Survey form attached to report Agency DEQ Contact Amv Brittain Environmental Programs Manager 6/15/2012 (405) 702-5157 Name Title Date Phone no. Problems, suggestions: ~ Report attached Survey fonn anaehed to report
46 Agency DEQ Contact Dennis Datin Professional Engineer 6/15/2012 (405)702-5125 Name Title Date Phone no. Problems, suggestions: ~ Report attached Survey form anached to report Agency ODOT Contact Jeff Pearl Environmental Programs Manager 6/27/2012 (405) 522-5193 Name Title Date Phone no. Problems, suggestions: ~ Report attached Survey form attached to report
4. Other interviews (optional): Christopher Beck ~Report attached Christopher Beck works for Atlas Roofing which borders the site to the north. Laura Schneider t8JReport attached Laura Schneider is co-manager of Hogan Family LLC. owner of the site. Ill. ONSITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) I. O&M Documents o O&M manual (long (enn monitoring plan) o Readily available o Up to date ~ N/A o As·built drawings o Readily available o Up to date ~ N/A o Maintenance logs o Readily available o Up to date ~N/A Remarks: 2. Site-Specific Health and Safety Plan o Readily available o Up to date ~ N/A o Contingency plan/emergency response plan 0 Readily available o Up to date ~ N/A Remarks: Will be UPdating the Safety, Health, and Emergency Response plan in 2012 3. O&M and OSHA Training Records o Readily available o Up to date ~ N/A Remarks: 4. Permits and Service Agreements 0 Air discharge pennit o Readily available o Up to date ~ N/A 0 Effluent discharge o Readily available o Up to dale ~ N/A 0 Waste disposal, POTW o Readily available o Up to date ~N/A 0 Other pennits o Readily available o Up to date ~N/A Remarks: 5. Gas Generation Records o Readily available o Up to date ~ N/A 6_ Settlement Monument Records o Readily available o Up to date ~N/A 7. Groundwater Monitoring Records o Readily available o Up to date ~ ':-
47 0 Water (emuent) o Readily available o Up to date [gJ N/A Remarks:
10. Daily Access/Security Logs o Readily available o Up (0 date [gJ N/A Remarks:
IV. O&M COSTS
I. O&M Organization [gJ State in·house o Contractor for State 0 PRP in-house 0 Contractor for PRP o Other 2. O&M Cost Records [gJ Readily available [gJ Up to date 0 Funding mechanism/agreement in place [gJ Original O&M cost estimate $9.632.70 0 Breakdown attached Total annual cost by year for review period, if available Date Date Total Cost From to -0 Breakdown attached From to -0 Breakdo\\'ll attached From to -0 Breakdown attached From to -0 Breakdown attached From (0 -0 Breakdown attached 3. Unanticipated or Unusually High O&M Costs During Review Period No V. ACCESS AND INSTITUTIONAL CONTROLS N/A 0 Applicable [gJ
A. Fencing I. Fencing damaged D Location shown on site map I:8J Gates secured 0 N/A Remarks: During the site insoeclion the fence and gates were in good coodilion. Contractor staled that in the past during deer hunting season; arrows. sholgun shells. and tire marks have been seen al the sile.
B. Other Access Restrictions I. Signs and other security measures o Location shown on site map I8J N/A Remarks:
48 C. Institutional Controls I. Implementation and enforcement Site conditions imply institutional controls not properly implemented DYes ~No ON/A Site conditions imply institutional controls not being fully enforced DYes ~No ON/A Type of monitoring (e.g., self-reporting, drive by) site inspections Frequency Annually Responsible party/agency DEQ Contact Aron Samwei Environmental Programs Specialist 6/15/2012 (405) 702-5123 Name Title Date Phone no.
Reporting is up-la-date ~ Yes ONo ON/A Reports are verified by the lead agency ~ Yes ONo ON/A Specific requirements in deed or decision documents have been met ~Yes ONo ON/A Violations have been reported DYes ~No ON/A Other problems or suggestions: o Report attached
2. Adequacy [8J Institutional controls are adequate 0 Institutional controls are inadequate 0 NJA Remarks: No digging. excavating. or activities that would cause erosion were seen. No residential. recreational, or groundwater use. D. General I. Vandalism/trespassing o Location shown on site map l'8J No vandalism evident Remarks:
2. Land use changes onsiteD N/A Remarks: No
3. Land use changes offsite ON/A Remarks: No
VI. GENERAL SITE CONDITIONS A. Roads 0 Applicable ~ N/A Roads damaged o Location shown on site map o Roads adequate 181 NIA Remarks
B. Other Site Conditions ~ Applicable 0 N/A Remarks: The site general appearance was excellent. Erosion mitigation work has been successful.
49 VII. LANDFILL COVERS [gJApplicable DN/A A. Landfill Surface I. Settlement (Low spots) o Location shown on site map ~ Settlement nOl evident Areal extent Deptb Remarks: None noted. 2. Cracks o Location shown on site map r8I Cracking not evident Lengths Widths Depths Remarks: None noted. 3. Erosion o Location shown on site map rgj Erosion not evident Areal extent Depth Remarks: Erosion construction activities are in place and functioning. 4. Holes o Holes evident r8J Holes not evident Areal extent Depth Remarks: 5. Vegetative Cover [gJ Grass r8J Cover properly established o No signs ofstress o Trees/Shrubs (indicate size and locations on a diagram) Remarks: 6. Alternative Cover (annored rock. concrete, etc.) (8J N/A Remarks: 7. Bulges o Location shown on site map I8J Bulges not evident Areal extent Depth Remarks: 8. Wet AreaslWater Damage [gI Wet areas/water damage not evident o Wet areas o Location shown on site map o Areal extent o Ponding o Location shown on site map o Areal extent o Seeps o Location shown on site map o Areal extent o Soft subgrade o Location shown on site map o Areal extent Remarks: 9. Slope Instability o Slides o Location shown on site map IZI No evidence ofslope instability Areal extent Remarks: B. Benches o Applicable [gJ N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order 10 slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) I. Flows Bypass Bench o Location shown on site map [gJ NIA or okay Remarks: 2. Bench Breached o Location shown on site map [gJ N/A or okay Remarks: 3. Bench Overtopped o Location shown on site map [gJ N/A or okay Remarks:
50 C. Letdown Channels o Applicable ~N/A l. Settlement o Location shown on site map o No evidence of settlement Remarks: 2. Material Degradation o Location shown on site map o No evidence ofdegradation Material type Areal extent Remarks: 3. Erosion o Location shown on site map o No evidence of erosion Areal extent Depth Remarks: 4. Undercutting o Location shown on site map o No evidence of undercutting Areal extent Depth Remarks: 5. Obstructions Type o No obstructions o Location shown on site map Areal extent Size Remarks: 6. Excessh'c Vegetative Growth Type o No evidence of excessive growth o Vegetation in channels does nOl obstruct flow o Location shown on site map Areal extent Remarks: D. Cover Penetrations LJ Applicable ~N/A I. Gas Vents o Active bJ Passive o Properly secured/locked o Functioning o Routinely sampled o Good condition o Evidence of leakage at penetration o NeedsO&M ~ N/A Remarks: 2. Gas Monitoring Probes o Properly secured/locked o Functioning o Routinely sampled o Good condition o Evidence of leakage at penetration o NeedsO&M ~ N/A Remarks: 3. Monitoring Wells (within surface area of landfill) o Evidence of leakage at penetration o NeedsO&M ~N'A Remarks: 4. Leachate Extraction Wells o Properly secured/locked o Functioning o Routinely sampled o Good condition o Evidence of leakage at penetration o NeedsO&M ~ N/A Remarks: S. Settlement Monuments o Located o Routinely surveyed ~N/A Remarks: E. Gas Collection and Treatment LJ Applicable ~N/A I. Gas Treatment Facilities o Flaring o Thermal destruction o Collection for reuse
51 o Good condition o NeedsO&M Remarks: 2. Gas Collection Wells, Manifolds, and Piping o Good condition o NeedsO&M Remarks: 3. Gas Monitoring Facilities (e.g.. gas monitoring ofadjacent homes or buildings) o Good condition 0 eeds O&M I:8J N/A Remarks: F. Cover Drainage Layer o Applicable I:8J N/A I. Outlet Pipes Inspected o Functioning I:8J N/A Remarks: 2. Outlet Rock Inspected o Functioning ~ N/A Remarks: G. Detention/Sedimentation Ponds o Applicable I:8J N/A I. Siltation Areal extent Size I:8J N/A o Siltation not evident Remarks: 2. Erosion Areal extent Depth o Erosion not evident Remarks: 3. Outlet \Vorks o Functioning I:8J N/A Remarks: 4. Dam o Functioning I:8J N/A Remarks: H. Retaining Walls o Applicable I:8J N/A I. Deformations o Location sho\VJ1 on site map o Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks: 2. Degradation o Location shown on site map o Degradation not evident Remarks: [. Perimeter Ditches/Off-Site Discharge o Applicable I:8J N/A I. Siltation o Location shown on site map o Siltation not evident Areal extent Depth Remarks: 2. Vegetative Growth o Location shO\VJ1 on site map I:8J N/A o Vegetation does not impede flow Areal extent Type Remarks: 3. Erosion o Location shO\VJ1 on site map DErosion not evident
52 Areal extent Depth Remarks: 4. Discharge Structure o Functioning ~ N/A Remarks: VIII. VERTICAL BARRIER WALLS 0 Applicable ~N/A I. Settlement o Location shO\\TI on site map o Settlement not evident Areal extent Depth Remarks: 2. Performance Monitoring Type of monitoring o Performance not monitored Frequency o Evidence of breaching Head differential Remarks: IX. GROUNDWATER/SURFACE WATER REMEDIES o Applicable ~ N/A A. Groundwater Extraction \Vells, Pumps. and Pipelines o Applicable ~ N/A I. Pumps, \Vellhead Plumbing, and Electrical o Good condition o All required wells located o NeedsO&M ~N/A Remarks: 2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances o Good condition o NeedsO&M Remarks: 3. Spare Parts and Equipment o Readily available o Good condition o Requires upgrade o Needs to be provided Remarks: B. Surface Water Collection Structures, Pumps, and Pipelines o Applicable ~N/A I. Collection Structures, Pumps, and Electrical o Good condition o NeedsO&M Remarks: 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Otber Appurtenances o Good condition o NeedsO&M Remarks: 3. Spare Parts and Equipment o Readily available o Good condition o Requires upgrade o Needs to be provided Remarks:
C. Treatment S~'stem 0 Applicable ~ N/A 1. Treatment Train (Check components that apply) o ;vtetals removal 0 Oil/water separation 0 Bioremediation o Air stripping 0 Carbon absorbers o Filters _,-_-,---,.---, --,-_--,--_---, _ o Additive (e.g., chelation agent, flocculent) pH management o Others 53 WGood condition ~ Needs O&M o Sampling ports properly marked and functional o Sampling/maintenance log displayed and up to date o Equipment properly identified o Quantity of groundwater treated annually o Quantity of surface water treated annually Remarks: 2. Electrical Enclosures and Panels (Properly rated and functional) ~ N/A o Good condition o NeedsO&M Remarks:
3. Tanks, Vaults, Storage Vessels ~ N/A o Good condition o Proper secondary containment o NeedsO&M Remarks: 4. Discharge Structure and Appurtenances ~ N/A o Good condition 0 Needs O&M Remarks: 5. Treatment Building(s) ~ N/A o Good condition (esp. roof and doorways) o Needs repair o Chemicals and equipment properly stored Remarks:
6. Monitoring Wells (Pump-and-treatment remedy) o Properly secured/locked o Functioning o Routinely sampled o Good condition o All required wells located 0 Needs O&M ~N/A Remarks:
D. Monitored Natural Attenuation o Applicable ~ N/A I. Monitoring Wells (Natural attenuation remedy) o Properly secured/locked o Functioning o Routinely sampled o Good condition o All required wells located 0 Needs O&M ~N/A Remarks:
54 X. OTHER REMEDIES Jf there are remedies applied at the site that are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVAnONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., 10 contain contaminant plume, minim ize infiltration and gas emission, Ctc.). Most of the waste was excavated and disposed of offsite, but in areas where excavation was impractical and potentiallv dangerous. the remedy was a clav barrier over the waste that remains in place. The current implementation of the remedy is effective and is functioning as designed.
B. Adequacy of O&M Describe issues and observations relating to the implementation and scope ofO&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. O&M for the site has not started yet.
C. Early Indicators of Potential Remedy Failure Describe issues and observations such as unexpected changes in the cost or scope ofO&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be comprised in the future. There are no earlY indicators of potential remedy failure.
D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy,
55 INSPECTION TEAM ROSTER
Name Organization Title Katrina Higgins·Coltrain EPA Remedial Project Manager Brian Yost EA Engineering Project Manager Blake Rudd Ardmore Public Utilities Assistant Director Amy Brittain DEQ Environmental Programs Manager Dennis Datin DEQ Professional Engineer Aron Samwel DEQ Environmental Programs Specialist Liberty Galvin DEQ Technical Intern
56 Attachment 7 Site Interviews
57 INTERVIEW RECORD Sile Name: Imperial Refining Company EPA ID No.: OKDOOO2024099 Location: Ardmore, Carter County. Oklahoma Dale: 6115/12 Contact Made By: Name: Aron Samwel Tille: Environmental Programs Organization: DEQ Specialist Telephone No: (405) 702·5123 Street Addrt'Ss: 707 North Robinson E·~1ail Address: aron.samwel:gdeq.ok.gov City, Slate, Zip: Oklahoma City. OK 73101 Indh'idual Contacted: Name: Blake Rudd Title: AssiSlant Director Organization: Ardmore Public Utilities Telephone No: (580) 221-540 1 Street Address: P.O. Box 249 [-Mail Address: [email protected] City, State, Zip: Ardmore, OK 73402
Summary Of Convenation t. What is your overall impression or the project? Good
2. What effects have site operations bad on the surrounding community? Minimal
3. Are )'ou aware of any community concerns regarding the site or its operation and administration? Is so, please give details. Some concerns ahoul rhe wasTe Ilia/was left.
4. Are you aware ofany events, incidenls, or activities at Ihe site sucb as vandalism, trespassing, or emergency responses from local authorities? Ifso, please give details. No
5. Do you feel well informed aboul the sile's activities and progress? res
6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? No
58 INTERVIEW RECORD Site Name: Imperial Refining Company EPA ID No.: OKDOO02024099 Location: Ardmore, Carter County, Oklahoma Date: 6115/12
Contact Made By: Name: Aron Samwel Title: Environmental Programs Organization: DEQ Specialist Telephone No: (405) 702-5123 Street Address: 707 North Robinson E-Mail Address: [email protected] City, State, Zip: Oklahoma City. OK 7310 I Individual Contacted: Name: Brian Yost Title: Project Manager Organization: EA Engineering, Science & Technology, Inc. Telephone No: (972) 315-3922 Street Address: 405 S. Hwy 121 Bypass Bldg. C-100 E-Mail Address: [email protected] City, State, Zip: Lewisville, TX 75067
Summary Of Conversation I. What is your overall impression of the project? Very good
2. What is the current status of construction (e.g., budget and schedule)? On-budget on-schedule
3. ]s the remedy functioning as expected? How well is the remedy performing? Yes the remedy isjuncfioning and performing very well.
4. Have an}' problems been encountered which required, or will require, changes to this remedial design or this ROD? IVa
5. Have any problems or difficulties been encountered which have impacted construction progress or implementabilit)'? 2\'0
6. Do )'ou have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, cODstructabiliry, management, contractor, etc.)? No
59 INTERVIEW RECORD Site Name: Imperial Refining Company EPA ID No.: OKDOOO2024099 Location: Ardmore, Carter County, Oklahoma Date: 6/15/12 Contact Made By: Name: Aron Samwel Title: Environmental Programs Organization: DEQ Specialist
Telephone No: (405) 702-5 123 Street Address: 707 North Robinson E-Mail Address: [email protected] City, State, Zip: Oklahoma City, OK 73101 Individual Contacted: f'liame: Amy Brittain Title: Environmental Programs Organization: Department Manager Environmental Quality Telephone No: (405) 702·5157 Stl'"eet Address: 707 North Robinson E-Mail Address: [email protected] Cit}" State, Zip: Oklahoma City, OK 73101
Summary Of Conversation I. What is your overall impression of the project? Very good. as ;sslies have cOllie lip we have worked them out with EPA.
2. Han there been routinc communications or activities (site visits, inspections, reporting activities, etc.) conducted b)' your office regarding the site? U so, please give purpose and results. DEQ has performed site visits to meet with EPA alld inspect erosion areas.
3. Have there been any complaints, violations, or otber incidents related to the site requiring a response by your office? Uso, please give details of the events and results oftbe responses. No
4. Do you feel well informed about tbe site's activities and progress? Yes
5. Do you ban an}' comments, suggestions, or recommendations regarding the site's management or operation? No. site looks much better since lost round ofsite work.
60 INTERVIEW RECORD Site Name: Imperial Refining Company EPA ID No.: OKDOOO2024Q99 Location: Ardmore, Carter County. Oklahoma Date: 6/15/12 Contact Made By: Name: Arcn Samwel Title: Environmental Programs Organization: DEQ Specialist
Telephone No: (405) 702·5123 Street Address: 707 North Robinson E-Mail Address: [email protected] Cit)', State, Zip: Oklahoma City, OK 73101 Individual Contacted: Name: Dennis Datin Title: Professional Engineer Organization: Department Environmental Quality Telephone No: (405) 702·5125 Street Address: 707 North Robinson [-Mail Address: [email protected] Cil)', State, Zip: Oklahoma Cit). OK 73101
Summary Of Conversation I. What is your overall impression of the proj«t? The site looks good. Vegetation is good.
2. Haye there been routine communications or activities (site Yisits, inspections, reporting activities, etc.) conducled by your office regarding the site? Ifso, please give purpose and results. Only communications related to doing 'he erosion control work in the spring.
3. Have there been an)' complaints, violations, or other incidents related to the site requiring a response b)' )'our office? Ifso, please give details of the eyents and results oftbe responses. No
4. Do you feel well informed aboulthe site's activities and progress? res
5. Do you han any comments, suggestions, or recommendations regarding the site's management or operation? No
61 INTERVIEW RECORD Site Name: Imperial Refining Campan) EPA JD No.: QKOOOO2024099 Location: Ardmore, Caner Count), Oklahoma Date: 627 12 Contact Made B)':
Name: ATOll SamweJ Title: Environmental Programs Organization: DEQ Specialist Telephone No: (405) 702-5123 Street Address: 707 North Robinson [-Mail Address: [email protected] City, State, Zip: Oklahoma City, OK 73101 Individual Contacted: Name: Jeff Pearl Title: Environmental Programs Organization: Oklahoma Manager Department of Transportation Telephone No: (405) 522-5193 Sireet Address: 200 N.E. 21" St. Room 32A E-Mail Address: [email protected] City, Scale. Zip: Oklahoma Ciry, OK 73105
Summary OfCom'ersation 1. What is your overall impression of the project? Good
2. Wbat effects have sile operations bad on the surrounding communil)'? Perceived to be positive
3. Are you aware of any community concerns regarding the site or its operation and administration? Ifso, please give details. No
4. Are you aware of an)' events, incidents, or activities at the site such as \'andalism, trespassing, or emergency responses from local authorities? If so, please give details. No
5. Do you feel well informed about the site's activities and progress? Not really but maybe local ODOT is: we should col1tac( Bob Rose ill thefllIure. (*Bob '$ name has been added to the contact list.)
6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? No
62 INTERVIEW RECORD Site Name: Imperial Refining Company EPA to No.: OKDOOO2024099 Location: Ardmore, Caner Counr)', Oklahoma Date: 6/29/12 Contact Made By: Name: Aron Saln\\'el Title: Environmental Programs Organization: DEQ Specialist Telephone No: (405) 702-5123 Street Address: 707 North Robinson E-Mail Address: [email protected] City, State, Zip: Oklahoma City, OK 73101 Individual Contacted: Name: Christopher Beck ITitle: Senior Accountant IOrganization: Atlas Roofing Telephone No: (580) 223-3760 x 112 Street Address: 2300 Hwy 142 E. [·Mail Address: [email protected] Cily, Siale, Zip: Ardmore, OK 73401
Summary Of Conversation I. What is your overall impression oftbe project? It appears the project so far is improving the sire.
2. What effe£ts have site operations had on the surrounding (ommunit),? Site operations how left a sellse thai a part ofthe community is being brought back to 1I0rmal.
3. Are )'ou aware of an)' community concerns regarding the site or its operation and administration? If so, please give details, Not aware ofallY at this time.
4. Are you aware ofan)' events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? Ifso, please give details. Not aware ofany stich activities within the time J have been around this area.
5. Do you feel well informed about the site's activities and progress? Not really. At my Jerel nOI milch has been said abour the site next door.
6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation?
No. J do 1101 hcr.'e allY at this time.
63 INTERVIEW RECORD Site Name: Imperial Refining Company EPA ID No.: OKDOOO2024099 Location: Ardmore. Carter County, Oklahoma Date: 7/3/12 Contact Made By: Name: Arao Sam\\el Tille: Em ironmenlal Programs Organization: DEQ Speciali!>1
Telephone No: (405) 702-5123 Street Address: 707 North Robinson E·Mail Address: [email protected] City, State, Zip: Oklahoma City, OK 73101 Individual Contacted: Name: Katrina Higgins-Coltrain Title: Remedial Project Manager Organization: EPA Telephone No: (214) 665-8143 Street Address: 1445 Ross Avenue, Suite 1200 E-Mail Address: [email protected] City, State, Zip: Dallas, TX 75202
Summary Of Conversation I. What is )'our overall impression of the projcl.'t? This project has been a difficult and challenging project. During remedial action additional waste volumes were identified and sollllions were developed as the project field activi(;es continued. The EPA and ODEQ were able 10 work together effectively and efficiently tofind solutions to problems as-Ihey emerged durillgfield activities limiting delays in the schedule and unnecessary increases in cost.
Despite the challenges wilh waSle excavation field activity, management ofadditional waste volumes. implemelllatioll ofinstilutional cOlllrols, and implemelllatioll oja site Record ofDecision Amendmelll. Ihe project was completed 011 schedule and within budget. Post-remedial action erosion issues were also addressed as a team effort with the City ojArdmore. rhe Department ojTrclI/sportation. the Chickasaw Telephone Company. and the Property Owner.
2. What is the current status of construction (e.g. budget and schedule)? The project remedial action has- been completed al/({ post-remedial action operalional and jrmctiolljield activities have bee" completed. The site is all schedulejor turnover /0 Ihe State jor Operation and Maintenance in December 10/2.
3. Is the remedy functioning as expected? How well is the remed)' performing? During remedial action confirmation samples were collected to verify thai the soil cleanup levels had bee" met. All excavated areas were confirmed /0 meet these cleanup levels prior to backfilling. grading and seeding. All areas where waste was left-in-place was covered with a mi"imum Ojfwofeet ofsoil and seeded. Post-remedial actionfield activities were necessary to address erosion issues along surface drainage ways fa protect areas where waste was left-in-place. These activities were completed in FehmalY 20/1. and site inspections since completion indicate erosion miligation efforts are working CiS designed.
64 Summary Of Conversation Continued
4. Have any problems been encountered which required, or will require, changes to this remedial design or this ROD? The site ROD was signed on December 26.2007, and included excavation alld offsite disposal ofall COn/aminated media abo ....e cleanup levels. However, during remedial action. the idemificalion ofadditional wrote areas and waSle "ollimes required a ROD Amendmem. The ROD Amendmen/ \ms signed 0" February 20.2009. All waste Ihal could be excavated was remOl:ed and disposed oifsite: howerer.for Ihose areas where waste could 1101 be removed, il remained in-place (Ind was covered. Ilf.'ifirutio/101 controls restricting access and lISe oflhese areas were placed on the site deed as well as on any right-of-way where constructioll main/enal1ce may OCCllr. These areas will a/~'o require continued maintenance into thefuture l/nder Ihe ol'ersight ofthe ODEQ.
At this lime, 110 additional changes 10 the current remedial aclion are anticipated.
5. Have any problems or difficulties been encountered which have impacted construction progress or implementability? Do you have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, constructability, management, contractor, etc.)? This project is currently constrllction complete. Post-remedial actiOIl construction is also complete. AI this time, site inspections indicate thai the remedy isjlmctioning as designed. The S!art ofOperation and Maintenance is expected 10 begin in December 20/2 with the tUn/over ofthe site to the ODEQ.
65 INTERVIEW RECORD Site Name: Imperial Refining Company EPA ID No.: OKDOOO2024099 Location: Ardmore, Carter County, Oklahoma Date: 7/5/12 Contact Made By: Name': Arcn Samwe[ Title: Environmental Programs Organization: DEQ Specialist
Telephone No: (405) 702-5113 Street Address: 707 North Robinson E-Mail Address: [email protected] Cit)', State, Zip: Oklahoma City, OK 73101 Individual Contacted: Name: Laura Schneider Title: Owner IOrganization: Hogan LLC Telephone No: (512) 396-0468 SCreee Address: 803 Mustang Lane [-Mail Address: [email protected] City, State, Zip: San Marcos, TX 78666
Summary Of Conversation I. What is your o\'erall impression of the project? J don 'rfeelthe land on/he East ofHwy /42 was restored 10 irs previous slate. Land left with deep depressions notfilled. (*Laura has nol beel/lo the site since the erosion work has been completed.) 2. In what capacity are you associated witb the Site? Co-manager a/Hogan Family LLC, owner a/the site. 3. Are you familiar with activities at the Site? Mostly informed to activities the same as general public. Was askedfor input for drainage work because I voiced a concern about poor qllality ofstabilization techniqlles. 4. How have your interactions with the Site been? Interaction has been Vel)! limited, bllt were cordial. During most ofsile work I was never contacted, except to notify about public meetings. 5. A..e you awa..e ofany events, incidenls, or activilies allhe sile such as vandalism, trespassing, or emergenc)' responses from local authorities? If so, please give details. No 6. Do you feel well informed about Ihe site's activilies and progress? No 7. Do you have any comments, suggestions, or recommendations regarding the site's management or operation?
Question, Who is 110W managing the site? As owner: Hogan-Family LLC. /leeds to be il1formed abOUI future managemenl procedures. We need to know who does what and when (*DEQ called and talked to Lallra to €.tplain Ihal EPA is managing Ihe site lImil the site is fUmed over to DEQfor O&M: turnover scheduledfor December 2012.)
66 Attachment 8 Photos Documenting Site Conditions
67 Photo: I Takeo b)': Arcn Samwel Looking: West Comments: Oneok Gas Pipeline ~ .
68 Photo: 2 Taken by: Aron Sarnwel Looking: East Comments: West Pond
69 Photo: 3 Taken by: Aron Sanm'el Looking: North Comments: Western Site Boundary with Valero
I
70 Photo: 4 Taken by: Aron Samwel Looking: Down Comments: West Pond
71 Pboto: 5 Taken by: Arcn Samwel Looking: East Comments: West Pond
72 Photo: 6 Taken hy: Aron Sarnwel Looking: East Comments: Northern Site Boundary with Valero
73 Photo: 7 Taken by: Aron Samwel Looking: Northwest Comments: HI'. ' 142
74 Photo: 8 Taken hy: Aron Sarnwel Looking: East Comments: Culvert Drainage East of Hwy 142
75 Photo: 9 Taken by: Arcn Samwel Looking: Snuth Comments: East Pond
76 Photo: 10 Taken by: Non Samwel Looking: West Comments: East Pond
77 Photo: 11 Taken by: Aron Samwel Looking: Northeast Comments: Northern Site Boundary with Atlas Roofing
78 Photo: 12 Taken by: Aron Samwel Looking: North Comments: Northern Site Boundary with Atlas Roofing
79 Photo: 13 Taken by: Aron Samwel Looking: East Comments: BNSF Railway
80 Photo: 14 Taken by: Aron Samwel Looking: Southeast Comments: BNSF Railway
81 Attachment 9 Deed Notices
82