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FOURTH FIVE-YEAR REVIEW REPORT FOR

OKLAHOMA REFINING COMPANY SUPERFUND SITE

CADDO COUNTY, CYRIL, OKLAHOMA

May 12, 2017

2011/2016

Prepared by

U.S. Environmental Protection Agency

Region 6

Dallas, Texas

FOURTH FIVE-YEAR REVIEW REPORT OKLAHOMA REFINING COMP ANY SUPERFUND SITE

EPA ID#: OKD091598870 CADDO COUNTY, CYRIL, OKLAHOMA

This memorandum documents the U.S. Environmental Protection Agency's performance, determinations, and approval of the Oklahoma Refining Company Superfund Site fourth five-year review, under Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S. Code Section 962l(c), as provided in the attached fourth Five-Year Review Report.

Summary of the fourth Five-Year Review Report

The OUl remedy is performing in accordance with its remedial design. The landfills and capped areas are in good condition and require no major repairs to remain protective. Small soil repairs will be necessary to mitigate damage to capped soil areas and landfill caps caused by burrowing animals and possibly storm water erosion. Site fencing is generally in good condition but will require small patches to prevent trespassing. Future remedial actions planned to be implemented through OU2 and OU3 are expected to further reduce or eliminate entirely any remaining exposure of human health and the environment to contaminants of concern. Community involvement revealed concerns related to wildfire and storm water drainage deficiencies.

Environmental Indicators

Human Exposure Status: Under Control Contaminated Groundwater Status: Insufficient Data Site-Wide Ready for Reuse: No

Actions Needed

The following actions must be taken for the remedy to be protective in the long term:

• Repair erosion identified at the edge of the acid flow capped area, which could impact capped

contaminated material if it continues.

Determination

I have determined that the remedy for the Oklahoma Refining Company Superfund Site OUl is protective. This five-year review report specifies the actions that need to be taken for the remedy to remain protective.

Date

2

Michael Hebert

CONCURRENCES

FOURTH FIVE-YEAR REVIEW REPORT OKLAHOMA REFINING COMP ANY SUPERFUND SITE

EPA ID#: OKD091598870 CADDO COUNTY, CYRIL, OKLAHOMA

• Date Remedial Project Manager

Blake Atkins Date Chief, Louisiana/New Mexico/Oklahoma Section

..s /~ /1 1 Date '

Attorney, Office of Regional Counsel

Mar . Peyck Date ,

Chief, Superfund Branch, Office of Regional Counsel

Date

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ISSUES/RECOMMENDATIONS

FOURTH FIVE-YEAR REVIEW REPORT

OKLAHOMA REFINING COMPANY SUPERFUND SITE

EPA ID#: OKD091598870

CADDO COUNTY, CYRIL, OKLAHOMA

Issues/Recommendations

OU(s) with Issues/Recommendations Identified in the Five-Year Review:

OU1

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1 Issue Category: Operations and Maintenance

Issue: Repair erosion identified at the edge of the acid flow capped area,

which could impact capped contaminated material if it continues.

Recommendation: Fill area to grade with clean soil and revegetate as

necessary

Affect Current

Protectiveness

Affect Future

Protectiveness

Party

Responsible

Oversight Party Milestone Date

No Yes State EPA/State 8/17/2018

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Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ......................................................................................... 6

I. EXECUTIVE SUMMARY ..................................................................................................................... 7 II. INTRODUCTION .................................................................................................................................. 7

FIVE-YEAR REVIEW SUMMARY FORM ......................................................................................... 8 III. RESPONSE ACTION SUMMARY ..................................................................................................... 9

Basis for Taking Action .......................................................................................................................... 9

Response Actions .................................................................................................................................... 9 Status of Implementation ...................................................................................................................... 10 IC Summary Table ................................................................................................................................ 11 Systems Operations/Operation & Maintenance .................................................................................... 11

IV. PROGRESS SINCE THE LAST REVIEW ....................................................................................... 12

V. FIVE-YEAR REVIEW PROCESS ...................................................................................................... 13 Community Notification, Involvement & Site Interviews .................................................................... 13

Data Review .......................................................................................................................................... 14 Site Inspection ....................................................................................................................................... 14

VI. TECHNICAL ASSESSMENT ........................................................................................................... 15 QUESTION A: Is the remedy functioning as intended by the decision documents? .......................... 15

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of the remedy selection still valid? .............................................. 15

QUESTION C: Has any other information come to light that could call into question the

protectiveness of the remedy? ............................................................................................................... 16 VII. ISSUES/RECOMMENDATIONS .................................................................................................... 16

OTHER FINDINGS.............................................................................................................................. 17 VIII. PROTECTIVENESS STATEMENT ............................................................................................... 17

IX. NEXT REVIEW ............................................................................................................................ 17 APPENDIX A – REFERENCE LIST....................................................................................................... 18

APPENDIX B – ORC NORTH AND SOUTH BOUNDARY MAP ....................................................... 19 APPENDIX C – COC CLEANUP GOALS ............................................................................................. 20 APPENDIX D – 5 YEAR REVIEW PUBLIC NOTICE .......................................................................... 22

APPENDIX E – INTERVIEWS ............................................................................................................... 23 APPENDIX F – SAMPLE O&M REPORT ............................................................................................. 32

APPENDIX G – GLADYS CREEK BANK SLOPE FAILURE PHOTOGRAPHS ............................... 34 APPENDIX H – CAPPED AREAS MAP ................................................................................................ 36 APPENDIX I – FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST .......................................... 37

APPENDIX J – CAPPED ACID FLOW AREA ...................................................................................... 51

APPENDIX K – ARARs FROM OU1 ROD ............................................................................................ 52

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LIST OF ABBREVIATIONS & ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CPC Cyril Petrochemical Corporation

EPA United States Environmental Protection Agency

ESD Explanation of Significant Difference

FS Feasibility Study

FYR Five-Year Review

ICs Institutional Controls

IDW Investigation Derived Waste

LNAPL Light Non-Aqueous Phase Liquid

NCP National Contingency Plan

NPL National Priorities List

O&M Operation and Maintenance

ODEQ Oklahoma Department of Environmental Quality

ORC Oklahoma Refining Company

OSDH Oklahoma State Department of Health

OU1 Operable Unit 1

OU2 Operable Unit 2

PRP Potentially Responsible Party

RA Remedial Action

RAO Remedial Action Objectives

RCRA Resource Conservation and Recovery Act

RD Remedial Design

RI Remedial Investigation

ROD Record of Decision

RPM Remedial Project Manager

TCLP Toxicity Characteristic Leaching Procedure

UAO Unilateral Administrative Order

UU/UE Unlimited Use and Unrestricted Exposure

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I. EXECUTIVE SUMMARY

The Operable Unit 1 (OU1) portion of this 5-Year Review focuses on the implemented portions of the original

remedy performed according to the 1992 Record of Decision (ROD). The implemented portion of the 1992 ROD

consists of the work done on the southern portion of the site, such as soil excavations, capping of contaminated

areas, and the construction and maintenance of two on-site landfills. Other site contamination that was not addressed

by the 1992 ROD is the subject of on-going remedial activities under Operable Unit 2 (OU2) and Operable Unit 3

(OU3). OU2 addresses the soil and Light Non-Aqueous Phase Liquid (LNAPL) issues present on Oklahoma

Refining Company (ORC) North, as well as sediment removal from the caustic and acid seeps located on ORC

South. OU2 is currently in Remedial Design (RD) and is being carried out in accordance with its ROD dated June

17, 2013. OU3 is currently in the Remedial Investigation (RI) stage and will address issues with ground water,

Gladys Creek surface water, and North Gladys Creek sediments.

The OU2 RD currently being conducted will utilize the Hazardous Waste Landfill constructed under the OU1

remedy for disposal of contaminated media. Investigation Derived Waste (IDW) from OU2 RI sampling activities

is currently being stored on ORC South, on an appropriate IDW pad and will be removed once the drums are full,

or once the OU2 remedial design work has been completed. Significant work within OU2 was also performed on

the ORC North drainage ditch to improve storm water flow on-site and off. Preliminary work on OU3 began in

October 2016 and consisted of a meeting between the Environmental Protection Agency (EPA), Oklahoma

Department of Environmental Quality (ODEQ), and Burns and McDonnell at ODEQ headquarters, as well as an

on-site inspection of ORC South landfills and related areas. OU3 sampling activities began in February 2017 and

will be focused on the evaluation of ground water, Gladys Creek surface water, and North Gladys Creek sediments.

II. INTRODUCTION

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order

to determine if the remedy is and will continue to be protective of human health and the environment. The methods,

findings, and conclusions of reviews are documented in five-year review reports, such as this one. In addition, FYR

reports identify issues found during the review, if any, and document recommendations to address them.

The U.S. EPA is preparing this five-year review pursuant to the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP)(40

CFR Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fourth FYR for the ORC Superfund Site. The triggering action for this statutory review is the completion

date of the previous FYR. The FYR has been prepared, due to the fact that hazardous substances, pollutants, or

contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of three OUs. OU1 addresses the implemented remedy from the 1992 ROD which includes

primarily ORC South soil excavation, capping of subsurface contamination, and the maintenance of the hazardous

and non-hazardous landfills. OU2 addresses soil remediation and LNAPL recovery on ORC North, while OU3

addresses the groundwater and surface water interactions of the surrounding water features such as Gladys Creek

and its associated structures.

The Oklahoma Refining Company Superfund Site Five-Year Review was led by Kyle Gregory at ODEQ, for EPA.

Participants included Amy Brittain, Christopher Orlik, and Kyle Gregory of ODEQ and Michael Hebert of EPA

Region 6. Amy Brittain manages the Oklahoma ODEQ’s Superfund section, while Christopher Orlik acts as State

Project Manager. Michael Hebert represents EPA as ORC’s Remedial Project Manager. Kyle Gregory provides

engineering and project management support for ORC at ODEQ. Documents reviewed as part of this Five-Year

Review are listed in Appendix A. The review began on August 1, 2016. 8/1/2016

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Site Background

The ORC site is an approximately 200-acre, abandoned, former crude oil refinery, located in Cyril, Caddo County,

Oklahoma, approximately 75 miles southwest of Oklahoma City. The refinery at the ORC site operated from 1920

to 1984, when it declared bankruptcy and ceased operations. In 1987, Cyril Petrochemical Corporation (CPC)

purchased the northern portion of the property, which consisted of the process areas and tank farm, with the intention

of reactivating the refinery. The refinery was never reactivated, and all process equipment was removed in August

2003. The site is informally divided into two parts, as follows:

• ORC South – ORC South includes the “abandoned” southern portions of the site that formerly consisted of

grasslands and approximately 40 randomly-sized pits and wastewater ponds.

• ORC North (CPC property) – ORC North includes the northwest portion of the site that formerly consisted

of the refinery process areas and a tank farm.

A map of ORC is available in Appendix B. Remediation activities began pursuant to the 1992 ROD. The 1992 ROD

addressed the southern “abandoned” portion of the site which contained pits and wastewater ponds. The waste from

this area was excavated and placed into hazardous and non-hazardous landfills, also located on ORC South.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Oklahoma Refining Company

EPA ID: OKD091598870

Region: 6 State: OK City/County: Cyril, Caddo

SITE STATUS

NPL Status: Final

Multiple OUs? Yes

Has the site achieved construction completion?

No

REVIEW STATUS

Lead agency: EPA

[If “Other Federal Agency”, enter Agency name]:

Author name (Federal or State Project Manager): Kyle Gregory

Author affiliation: Oklahoma Department of Environmental Quality

Review period: 8/17/2016 - 8/14/2017

Date of site inspection: 12/8/2016

Type of review: Statutory

Review number: 4

Triggering action date: 8/17/2012

Due date (five years after triggering action date): 8/17/2017

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III. RESPONSE ACTION SUMMARY

Basis for Taking Action

The purpose of the response actions conducted at the ORC site was to protect human health and the environment

from releases or threatened releases of hazardous substances from the ORC site. Contaminants of concern identified

in the ROD for the ORC site are presented in Appendix C. The major risks posed by the site were direct contact

with soils, waste sediments, surface water and ground water. Exposures to the affected soil, ground water, surface

water and sediment were determined to be associated with human health risks higher than the acceptable risk range

(between 1x10-4 and 1x10-6).

Response Actions

In 1984 the Oklahoma State Department of Health (OSDH) issued an order to ORC for corrective action of Resource

Conservation and Recovery Act (RCRA) violations, which included inadequate closure plans, failure to sample soil

in the land treatment area, and failure to adequately sample ground water in the land treatment area.

An action memorandum prepared pursuant to Section 104 of CERCLA, authorizing an EPA removal action at the

site, was signed on August 30, 1990. The scope of the removal action consisted of fencing the site, characterization

of the contents and removal of drums, plugging wells in the acid pit area, and placing netting over several

impoundments to protect wildlife. A Unilateral Administrative Order (UAO) was issued to CPC on January 25,

1991, ordering the company to perform the fencing on its portion of the property and the drum characterization.

CPC responded to the order to undertake the actions requested; however, the work plan submitted by CPC to

perform the work was not considered adequate for the drum characterization. CPC was allowed to proceed with the

fencing of its property and EPA proceeded with performance of the drum characterization, the well plugging, and

installing the impoundment netting. The removal action on CPC’s property and the abandoned property was

completed in August 1991.

The ORC site was added to the NPL in June 1988. The OSDH began a Remedial Investigation (RI) in 1989 and

completed the RI in 1991. The focus of this RI was the southern portion of the site. The Feasibility Study (FS) was

performed between 1989 and 1991. The FS identified soil, sediment, surface water and ground water that required

remediation and identified the cleanup levels to be achieved during remediation. The site’s original ROD was

developed and signed in 1992, and then later amended by two Explanations of Significant Difference (ESDs) in

1996 and 2003. After partially completing the remedy according to the 1992 ROD, the need for several alterations

became apparent. The groundwater remedy was delayed through the two ESDs and the OU2 ROD. Groundwater

is now being addressed in OU3. Tables of clean up goals for sediment, soils, and subsurface soils can be found in

Appendix C. The 1992 ROD consisted of the following components:

In-situ bioremediation of organic-contaminated sediments.

In-situ bioremediation of inorganic-contaminated sediments, followed by capping. Stabilized

sediments and surface soils shall be capped with 2.5 feet of clay followed by 1 foot of subsoil

followed by 0.5 feet of topsoil.

Removal of all onsite surface water from impoundments.

Treatment of all contaminated surface water taken from the surface impoundments in an onsite water treatment

facility.

Prepared-bed biotreatment of contaminated sediments and soil that could not be treated in situ, followed by

stabilization, if necessary, and containment of treated residuals. Stabilized soils shall be disposed in the same

onsite landfill used to dispose biotreatment residuals.

Excavation and containment of contaminated sediments and soil that exceeded health-based

levels.

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Excavation and neutralization of low pH sediment, followed by placement of treated material as fill, in area of

origin.

Excavation and recycling of asphaltic materials.

Removal and recycling of LNAPLs, primarily petroleum, floating on the ground water and commingled with

hazardous waste.

Containment of contaminated ground water using interceptor wells to prevent migration.

Treatment of all collected water in an onsite water treatment facility. Treated water was to be

injected into contaminated portions of the aquifer to enhance bioremediation of the contaminated ground water.

The 1996 ESD consisted of the following changes:

Stabilization and onsite capping of asphaltic materials, rather than recycling. Postponement of the ground water portion of the remedy to a second construction phase.

Construction of a temporary water treatment facility and discharge of treated water to Gladys Creek, instead of

to the aquifer.

The 2003 ESD consisted of the following changes:

The installation of the LNAPL trench was delayed until a decision regarding the LNAPL plume under the CPC

property was made.

The Remedial Action Objectives (RAOs) for the two railroad loading areas and the Tank 177 area were changed

from residential to industrial to reflect actual use.

The asphaltic waste and pitch waste remedy was changed from capping to disposal in a permitted landfill

facility.

The AP-1 waste material remedy was changed from stabilization to placement in the hazardous waste landfill.

The Toxicity Characteristic Leaching Procedure (TCLP) lead performance standard was increased from 1.5

mg/L to 5.0 mg/L to bring remediation requirements in line with regulatory limits.

Metals containing materials placed into the landfill would not be required to meet direct contact remediation

levels, but would be tested with TCLP procedures to determine the need for stabilization to meet groundwater

protection standards.

The RAO for beryllium was increased from 1.0 to 2.0 ppm, in order to reduce false positives and uncertain

quantifications.

The remediation of Tank #1 area was changed from excavation to cover, with eight to twelve inches of clean

soil.

Status of Implementation

The final OU1 remedy has been completed. A final report documenting the performance and completion of the

remedial action (RA) at the ORC site was submitted by the contractors on March 21, 2003. From 2003 to 2006,

EPA conducted a removal action of the refinery superstructure, on the northern portion of the property.

Remedial activities continue under OU2 and OU3. A RD is currently being conducted, pursuant to the OU2 ROD

which was signed in June 2013. RI activities are currently being conducted for OU3, which addressed surface water

and groundwater at the site.

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IC Summary Table

Table 1: Summary of Planned and/or Implemented ICs Media, engineered

controls, and areas

that do not support

UU/UE based on

current conditions

ICs

Needed

ICs Called

for in the

Decision

Documents

Impacted

Parcel(s)

IC

Objective

Title of IC Instrument

Implemented and Date

(or planned)

Soil, landfills,

water wells,

groundwater,

fencing

Yes Yes ORC Site Land use restrictions

Notice of Remediation

or Related Action

January 3, 2006

Systems Operations/Operation & Maintenance

There have been no changes to the O&M plan since the last five-year review. The ODEQ currently performs O&M

of the implemented remedy according to the previously developed O&M plan. The O&M plan only addresses the

southern portion of the site and covers the following activities:

● Landfill monitoring and maintenance. ● Soil cover inspection and maintenance.

● Security fence inspection and maintenance.

● Photo documentation.

● Institutional controls maintenance.

The hazardous and non-hazardous landfills are inspected quarterly. Each inspection includes:

● Identification of areas with noticeable settlement and/or standing water.

● Identification of areas of erosion and/or animal burrowing.

● Identification of areas without vegetation.

● Identification of damage to protection posts, settlement monuments, and underlying cap liner.

● Check the condition of the let-down structures on the hazardous waste landfill.

● Check the condition of the sumps.

● Check the condition of the fence and gates.

● Mowing is done as required.

Several locations onsite have subsurface soil remaining with concentrations of contaminants above RAOs. These

areas are inspected to ensure the integrity of the soil cap has not been compromised.

EPA responded to flood conditions in Cyril in June 2016 by reworking areas of the on-site drainage ditch. This

reworking and removal of soil from around a silted-in tin-horn allowed the remaining storm water flow from the

west side of the drainage ditch to flow east through the channel. Further improvements to the on-site drainage ditch

were completed by ODEQ, in October 2016. These improvements further facilitated the ability of the ditch to

transmit storm water during heavy rainfall events. Final storm water drainage improvements for the north side of

the site are planned to be implemented through the future OU2 RA.

In response to a report of children trespassing and swimming in a contaminated pond, approximately 1,650 feet of

fence was added around a pond on ORC North, in November 2013. The cost of this addition was $44,000.

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O&M costs have remained on average below maintenance estimates, as seen in Table 2, when compared to the 2007

O&M plan estimate of $19,196.50.

Table 2: O&M Costs by Fiscal Year

O&M Fiscal Year O&M Cost

2011 $ 8435.33

2012 $ 7065.19

2013 $ 5172.14

2014 $ 2675.10

2015 $ 5622.62

2016 $ 3838.28

IV. PROGRESS SINCE THE LAST REVIEW This section includes the protectiveness determinations and statements from the last five-year review, as well as the

recommendations from the last five-year review, and the current status of those recommendations.

Table 3: Protectiveness Determinations/Statements from the 2012 FYR

OU # Protectiveness

Determination Protectiveness Statement

1 Short-term Protective The response implemented to-date at the ORC site is

considered to be protective of human health and the

environment in the short-term.

Table 4: Status of Recommendations from the 2012 FYR

OU

# Issue Recommendations

Current

Status

Current Implementation

Status Description

Completion Date

(if applicable)

1 ODEQ performed a

well survey in 2006

and identified well

maintenance needs.

This maintenance has

not been completed.

Implement

recommendations

of the ODEQ well

survey.

Completed See reference “Multi-Purpose

Well Completion & Plugging

Report for the ORC Site” for

a report on completed well

survey recommendations.

7/14/2014

1 The cut bank on the

east side of Gladys

Creek continues to

erode due to natural

flow in the creek.

Continue to

monitor Gladys

Creek cut bank and

consider options to

address the

erosion.

Ongoing The creek bank has collapsed

and has receded under the

fence. Further erosion may

damage the nearby road.

Creek bank stabilization is

being analyzed through OU2

Not Completed

1 There are

deteriorating drums

from two separate

investigations on

the South portion of

the site. These drums

could re-contaminate

the area if

deterioration

continues.

Remove the

deteriorating drums

from the site.

Completed These drums have been

removed.

7/8/2013

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1 The extent of LNAPL

observed in SBB-2 is

not currently being

monitored.

Determine

monitoring for

SBB-2 in the future

ROD

Amendment.

Completed LNAPL monitoring is being

conducted through OU2

6/17/2013

1 Arsenic exceedances

continue in Gladys

Creek.

Address arsenic

exceedances in the

future ROD

Amendment.

Completed Gladys Creek is being

addressed through OU3

6/17/2013

1 Long term ground

water monitoring and

surface water

monitoring

are not being

conducted as required

by the 1996 ESD and

2003 ESD.

Perform long term

ground water

monitoring and

surface water

monitoring as

required by the

1996 ESD and

2003 ESD.

Completed Ground water and surface

water issues are being

addressed through OU2 and

OU3

6/17/2013

1 A remedial approach

to contaminated soil

beneath the former

refinery in the

northern portion of

the site has not yet

been developed.

Use available

documents and

data collected to

develop an

appropriate course

of action for

remediation of soil

contamination.

Completed Soil contamination on ORC

North is being addressed

through OU2

6/17/2013

1 A comprehensive

site-wide remedial

approach to ground

water

contamination has not

yet been developed.

ODEQ and the

EPA are currently

coordinating

efforts to

develop a revised

feasibility study

regarding the

ground water

remedy.

Completed Groundwater contamination is

being addressed through OU2

(LNAPL removal, soil source

removal), and OU3

(groundwater-surface water

interactions)

6/17/2013

V. FIVE-YEAR REVIEW PROCESS

Community Notification, Involvement & Site Interviews

A public notice (Appendix D) was made available by newspaper, through the Lawton Constitution, on 10/16/2016,

stating that there was a five-year review and inviting the public to submit any comments to the U.S. EPA. The

results of the review and the report will be made available at the Site information repository, located at Anadarko

Community Library.

During the FYR process, interviews were conducted to document any perceived problems or successes with the

remedy that has been implemented to date. The results of these interviews are summarized below.

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Interview forms were sent to state and federal regulatory personnel, local municipal and tribal authorities, and

nearby land owners/citizens. No nearby land owners/citizens completed the interview form. In addition, a

community interview form was provided to Cyril Town Hall, for any community members who were interested in

participating. No community members responded to this general interview form, provided at the Cyril Town Hall.

The completed interview forms obtained during the FYR can be seen in Appendix E. The overall opinion of the

site’s past and current cleanup work is positive. Overall, the work at ORC has been considered beneficial by the

local community. Suggested areas for improvement were mostly centered on maintenance of the site’s boundary

fence, trespassing, as well as ODEQ and EPA community interaction. Other issues mentioned were related to

flooding conditions in Cyril, which are believed to be related to the on-site drainage ditch. Both formal interviews

and general discussion with community members mentioned overgrown vegetation as a wildfire concern.

Data Review

The data reviewed for this FYR focused on the condition of the landfills and capped areas, resulting from the

implementation of the OU1 remedy. Data collected regarding the condition of the landfills exists as quarterly O&M

reports. These reports have been generated by ODEQ and have suggested no current or future issues with landfill

integrity. A summary of these O&M reports is as follows:

Several reports noted signs of burrowing animals.

Minor fence repairs are noted in a report dated 12/22/2011.

Vegetation is well established.

A fire was noted on 2/13/2015 that occurred north of the Hazardous Waste landfill. No damage was

recorded and no repairs were required.

An example O&M report is attached in Appendix F.

Additional information is available on ORC South, in the form of site visits and photo documentation. A severe

creek bank failure was observed in a region near a capped area, referred to as the “Acid Flow Area”. Although this

collapse is in an area which contains contaminated groundwater seeps, the collapse has not yet affected any capped

soil or related contaminated material. Photos of this creek bank collapse are included in Appendix G. A map of

capped areas can also be seen in Appendix H.

Site Inspection

The inspection of the Site was conducted on 12/8/2016. In attendance were Michael Hebert of EPA, Christopher

Orlik, Amy Brittain, and Kyle Gregory of the ODEQ. Appendix I includes a complete site inspection checklist. The

5-Year Review site visit consisted of three primary inspection areas appropriate for the landfills, the capped areas,

and the site fencing. Each landfill was visually inspected around its perimeter, top, and all drainage structures. All

leak detection gauge ports and sumps were also inspected, along with any settlement monuments. Signs of animal

burrowing were apparent on both the hazardous waste and non-hazardous waste landfills, near settlement

monuments. The North Sump, atop the non-hazardous waste landfill, showed soil erosion at its base, but this erosion

is likely due to animal burrowing. The leak detection system pipe caps, located on the hazardous-waste landfill,

were found to be missing or blown from their intended position on the tubing. All drainage structures were in good

condition and showed no signs of erosion. Both hazardous and non-hazardous landfills showed no bulging,

depressions, or other indications of failure.

All capped soil areas on ORC South were inspected to ensure their continued integrity. These areas were located

south of the hazardous waste landfill, northeast of the hazardous waste landfill, and additional areas nearer to Gladys

Creek that were thought to be invaded by the Gladys Creek stream bank collapse. These soil covers appeared to be

intact with minimal slumping and a healthy grass cover. The edge of the acid flow capped area noted in

Appendix J was experiencing soil erosion, but this soil degradation does not appear to have invaded into the

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contaminated material. The soil in this capped area was originally set to 18 inches, and the erosion is no deeper than

10 inches.

An inspection of the fencing on ORC South showed all gates, locks, and fence sections to be intact, except for minor

washouts. The largest breach of the site fence occurred where Gladys Creek had eroded away the creek wall and

caused a severe bank collapse. This approximately 50 foot section of fence has had temporary repairs performed by

the site’s current lessee, to protect on-site grazing cattle. Other washout areas located near Gladys creek are either

minor, or have also had temporary repairs performed by the site’s lessee.

Drums are present on ORC South’s investigation derived waste (IDW) staging area. These drums are from recent

(mid-late 2016) actions performed on OU2, through well drilling and soil sampling.

VI. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary:

Yes - the OU1 remedy is functioning as specified in the decision documents. The capped areas are intact or have

experienced only minor surficial erosion. The hazardous and non-hazardous waste landfills are in excellent

condition, with only minor animal burrowing. The capped areas and hazardous waste landfills effectively prevent

exposure of people and the environment to the contaminated materials within. The last five years of O&M costs

have been below the anticipated amount in the O&M plan, showing that the remedy has been performing without

any substantial issues. Because of the 2016 Gladys Creek bank collapse near the former Acid Flow Area on ORC

South (see Appendix G), this section of the fence will require repair to discourage trespassing. The severe creek

bank failure observed in a region near the capped area, referred to as the “Acid Flow Area”, requires repair.

Although this collapse is in an area which contains contaminated groundwater seeps, the collapse has not yet

affected any capped soil or related contaminated material.

There have been various instances of trespassing on-site. In response to a report of children trespassing and

swimming in a contaminated pond, approximately 1,650 feet of fence was added around a pond on ORC North, in

November 2013. The cost of this addition was $44,000. Additional reports of trespassing arose on April 30, 2014.

A concerned citizen from Cyril, OK reported a “redneck run” event which occurred on the ORC site. The event

included an obstacle course race which encompassed portions of the site. The course consisted of travel through a

hole in the fence, pits dug by heavy equipment, the former drainage pond area and ditch, and areas with asphaltic

waste. ODEQ contacted the landowner and event planners as well as sent a letter dated May 5, 2014, notifying them

of the risks posed by contact with contaminated soil and sediments at the site. These notifications indicated that

such events should not take place on the site. Continued maintenance of the institutional controls and O&M by

ODEQ will help ensure trespassing is discouraged and land use remains consistent with risks associated with the

selected remedy.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives

(RAOs) used at the time of the remedy selection still valid?

Question B Summary:

Yes, the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives are still valid. EPA

began publishing revised health hazard assessments for Benzo[a]pyrene on January 19, 2017. Although the updated

values are not yet finalized, ODEQ recalculated the cleanup values with the updated reference doses. With these

new values, the current cleanup values for soil and sediment for the ORC site are still within the acceptable risk

range. The resulting 10-5 and 10-6 risk cleanup values of 17.8 mg/kg and 1.78 mg/kg, respectively, are higher than

16

the 0.33 mg/kg cleanup number in the OU1 ROD. The values used in these calculations are provided in Table 5

and Table 6.

Table 5: Health Hazard Assessment for Effects Other than Cancer Health Hazard Dosage

Reference Dose for Oral Exposure 3x10-4 mg/kg-day

Reference Concentration for Inhalation Exposure 2x10-6 mg/m3

Table 6: Cancer Assessment

Quantitative Estimates for: Quantitative Limit:

Carcinogenic Risk from Oral Exposure 1 per mg/kg-day

Carcinogenic Risk from Inhalation Exposure 6x10-4 per µg/m3

There have been no changes in human health exposure pathways for the site since completion of the third five-year

review. In addition, no new contaminants or routes of human exposure have been identified for the site as part of

this five-year review. Post-remediation site conditions have eliminated or reduced human health exposure pathways

present at the site. ARARs included in the 1992 ROD are included in Appendix K.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the

remedy?

No, no other information has come to light that could call into question the protectiveness of the OU1 remedy.

Additional concerns have been noted from the community about the site’s wildfire potential. Because the site

consists primarily of large swathes of unmaintained tall grasses and other vegetation, its close proximity to private

residences allows these homes to be susceptible to grass fires. Grass fires have been noted on-site in the past on

occasion, including one noted in an O&M report dated February 13, 2015, in Appendix E.

VII. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) with Issues/Recommendations Identified in the Five-Year Review:

OU1

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1 Issue Category: Operations and Maintenance

Issue: Repair erosion identified at the edge of the acid flow capped area,

which could impact capped contaminated material if it continues.

Recommendation: Fill area to grade with clean soil and revegetate as

necessary

Affect Current

Protectiveness

Affect Future

Protectiveness

Party

Responsible

Oversight Party Milestone Date

No Yes State EPA/State 8/17/2018

17

OTHER FINDINGS

In addition, the following are recommendations that were identified during the FYR and may improve performance

of the remedy, reduce costs, and improve management of O&M, but do not affect current and/or future

protectiveness:

The gate located on the south side of ORC North leading in from S. Baskett St. has been damaged by

vehicle impacts on multiple occasions. Installation of an appropriate reflector/warning apparatus may

reduce future O&M costs.

Repair damage to perimeter fencing, especially in the vicinity of the Gladys Creek bank collapse near the

former Acid Flow Area on ORC South (see Appendix G).

Monitor storm drainage for erosion or for impeded flow conditions.

Maintain vegetation on west side of site near private residences.

Replace/repair leak detection riser pipe caps.

Repair landfill cap damage from burrowing animals.

VIII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s)

Operable Unit:1

Protectiveness Determination:

Protective

Protectiveness Statement: The remedy implemented for ORC OU1 currently protects human health and

the environment because O&M is occurring to ensure the perimeter fencing and capped areas remain

intact. However, in order for the remedy to be protective in the long term, the erosion at the edge of the

acid flow capped area needs to be repaired to ensure the capped materials are not exposed.

IX. NEXT REVIEW

The next five-year review report for the Oklahoma Refining Company Superfund Site is required five years from

the completion date of this review.

18

APPENDIX A – REFERENCE LIST Benzo[a]pyrene (BaP) IRIS. Environmental Protection Agency (EPA). Accessed March 2nd, 2017.

https://cfpub.epa.gov/ncea/iris2/chemicalLanding.cfm?substance_nmbr=136

CERCLA Removal Assessment Report for Oklahoma Refining Company Cyril, Caddo County, Oklahoma. U. S.

Environmental Protection Agency (EPA), September 2005.

Comprehensive Five-Year Review Guidance. OSWER No. 9355.7-03B-P. U.S. Environmental Protection Agency

(EPA), June 2001.

Explanation of Significant Difference to the Record of Decision, Oklahoma Refining Company Superfund Site,

Cyril, Oklahoma. U.S. Environmental Protection Agency (EPA), March 27, 1996.

Explanation of Significant Difference to the Record of Decision Oklahoma Refining Company Superfund Site, Cyril,

Oklahoma. U.S. Environmental Protection Agency (EPA), October 2003.

Feasibility Study Report for the Oklahoma Refining Company Superfund Site Cyril, Caddo County, Oklahoma.

Bechtel Environmental Incorporated (BEI), December 1991.

Landfill O&M Inspection Reports. Oklahoma Department of Environmental Quality (ODEQ), 2011-2016.

ORC POLREP #6. U.S. Environmental Protection Agency (EPA). Accessed March 15th, 2017.

https://response.epa.gov/site/polrep_profile.aspx?site_id=OKD091598870&counter=20858

Operation and Maintenance Plan for the South Portion Source Remedy of the Oklahoma Refining Company

Superfund Site. Oklahoma Department of Environmental Quality (ODEQ), March 2007.

Quarterly Operation and Maintenance Inspection Report, Oklahoma Refining Company. Oklahoma Department of

Environmental Quality (ODEQ), May 2011.

Record of Decision, Oklahoma Refining Company Superfund Site, Caddo County, Oklahoma. U.S. Environmental

Protection Agency (EPA), June 1992.

Remedial Investigation/Feasibility Study Work Plan Operable Unit 3. Burns & McDonnell, December 2016.

Remedial Investigation Report for the Oklahoma Refining Company Superfund Site Cyril, Caddo County,

Oklahoma. Bechtel Environmental Incorporated (BEI), September 1991.

Record of Decision Oklahoma Refining Company Operable Unit 2. Oklahoma Department of Environmental

Quality (ODEQ), June 2013

Third Five-Year Review Report for Oklahoma Refining Company Superfund Site Caddo County, Oklahoma.

Oklahoma Department of Environmental Quality (ODEQ), August 2012

Multi-Purpose Well Completion & Plugging Report for the ORC Site. Davis Environmental Drilling, LLC, July

2014

19

APPENDIX B – ORC NORTH AND SOUTH BOUNDARY MAP

20

APPENDIX C – COC CLEANUP GOALS Table 1: Remedial Action Objectives for Sediments and Surface Soils

Chemical of Concern RAOs, mg/kg Basis

1 Arsenic 25 or 305 HBR or Groundwater

Protection

2 Barium 13,500 HBR

3 Beryllium 0.5 Detection Limit

4 Cadmium 135 HBR

5 Chromium 1,350 or 770 HBR or Groundwater

Protection

6 Copper 351,000 HBR

7 Lead 600 or 865 HBR or Groundwater

Protection

8 Mercury 81 HBR

9 Nickel 5,400 HBR

10 Zinc 54,000 HBR

11 Benzene 22 or 0.20 HBR or Groundwater

Protection

12 Ethylbenzene 27,000 or 191 HBR or Groundwater

Protection

13 Toluene 54,000 or 104 HBR or Groundwater

Protection

14 Xylenes 540,000 or 2828 HBR or Groundwater

Protection

15 Acenaphthene 16,000 or 4,424 HBR or Groundwater

Protection

16 Anthracene 81,000 or 55,752 HBR or Groundwater

Protection

17 Benzo(a)anthracene 4.1 HBR

18 Benzo(a)pyrene 0.33 Detection Limit

19 Benzo(b)fluoranthene 0.69 HBR

20 Benzo(g,h,i)perylene 13 HBR

21 Benzo(k)fluoranthene 13 HBR

22 Chrysene 46 HBR

23 Dibenzo(a,h)anthracene 0.33 Detection Limit

24 Fluoranthene 10,800 HBR

25 Fluorene 10,800 HBR or Groundwater

Protection

26 Indeno(123/c,d)pyrene 3.2 HBR

27 Napthalene 79 Groundwater Protection

21

28 Phenanthrene 1,080 HBR

29 Pyrene 8,100 HBR

30 2,4-Dimethylphenol 5,400 or 66 HBR or Groundwater

Protection

31 2-Methylnapthalene 1,080 or 510 HBR or Groundwater

Protection

32 2-Methylphenol 13,500 or 12 HBR or Groundwater

Protection

33 4-Methylphenol 13,500 or 14 HBR or Groundwater

Protection

34 Phenol 162,000 or 125 HBR or Groundwater

Protection

Table 2: Remedial Action Objectives for Subsurface Soils

Chemical of Concern RAOs, mg/kg Basis

1 Arsenic 305 Groundwater Protection

2 Chromium 770 Groundwater Protection

3 Lead 865 Groundwater Protection

4 Benzene 0.20 Groundwater Protection

5 Napthalene 79 Groundwater Protection

6 2,4-Dimethylphenol 66 Groundwater Protection

7 2-Methylnapthalene 510 Groundwater Protection

8 2-Methylphenol 12 Groundwater Protection

9 4-Methylphenol 14 Groundwater Protection

10 Phenol 125 Groundwater Protection

22

APPENDIX D – 5-YEAR REVIEW PUBLIC NOTICE

23

APPENDIX E – INTERVIEWS

INTERVIEW RECORD

Site Name: Oklahoma Refining Company (ORC) EPA ID No.: OKD091598870

Subject: Five Year Review Date: 12/9/2016

Type: Other

Contact Made By:

Name: Kyle Gregory Title: Engineer Intern II Organization: Oklahoma

Department of Environmental

Quality (ODEQ)

Individual Contacted:

Name: Michael Hebert Title: RPM Organization: EPA

Telephone No: 214-665-8315

Fax No: 214-665-6660

E-Mail Address: [email protected]

Street Address: 1445 Ross Avenue

City, State, Zip: Dallas, TX 75202

Summary of Conversation

1. What is your overall impression of the project? The project is on track to complete all necessary remedial activities at the site even though it will be

several years before these activities are completed.

2. Are you aware of any community concerns regarding the site or its operation and administration? The lead agency for the site, the Oklahoma Department of Environmental Quality (ODEQ), has

periodically informed EPA of various minor trespassing incidents at the site. However, there have not

been any significant concerns voiced by the community except for the drainage issues that are in

common with the City of Cyril on the western edge of the site.

3. Have there been any significant changes in the site status or maintenance requirements since completion of the last five year review? If so, do they affect the protectiveness or effectiveness of the remedy?

Please describe changes and impacts.

A significant issue that has been on-going since the last Five Year Review has been the drainage issues

that are in common with the City of Cyril on the western edge of the site. This drainage issue has not

necessarily affected the protectiveness or effectiveness of the remedy but will have to be ultimately

addressed since there is a significant amount of storm water runoff that drains from the City of Cyril

onto the site.

The most significant change since the last five year review was the settlement of the liability case

against the APCO Liquidating Trust which resulted in EPA receiving settlement funding that will be used

to complete the remaining remedial activities at the site.

24

INTERVIEW RECORD



Type: Other

Contact Made By:



Quality (ODEQ)


Name: Michael Hebert Title: RPM Organization: EPA


Fax No: 214-665-6660


Street Address: 1445 Ross Avenue

City, State, Zip: Dallas, TX 75202


4. Are you aware of any changes in land use at or near the site? Has your office had any inquiries regarding potential reuse of the property, and if so, what were they?

EPA is not aware of any land use changes at or near the site. EPA and ODEQ had a discussion with a

citizen on December 8, 2016, interested in purchasing some of the southern portion of the site.

5. Are you aware of any unanticipated events, incidents, or activities related to the site requiring a response from your office since the last five year review? If so, please give details of the events and results of the responses. The lead agency for the site, the Oklahoma Department of Environmental Quality (ODEQ), has

periodically informed me of various minor trespassing incidents at the site. The ODEQ has addressed

these incidences.

6. Do you have any comments, suggestions, or recommendations regarding the project? EPA and ODEQ should continue to explore ways to decrease costs concerning the performance of

remedial activities as well as decrease the time it takes to complete activities.

25

INTERVIEW RECORD



Type: Other

Contact Made By:



Quality (ODEQ)


Name: Amber Edwards Title: Env. Programs Manager Organization: ODEQ

Telephone No:

Fax No:

E-Mail Address:

Street Address: 707 N. Robinson

City, State, Zip: Oklahoma City, OK 73102


1. What is your overall impression of the project? My overall impression of the project is good. ODEQ and EPA are working together to ensure the project is progressing.

2. What effect has the project had on the surrounding community? Once the project is completed the site will be usable for the community.

3. Are you aware of any community concerns regarding the site or its operation and administration? No, I am not aware of any concerns.

4. Have there been any complaints, violations, or other incidents related to the site requiring a response

by your office? If so, please give details of the events and results of your responses. There was grass fire at the site in February 2015 and the local fire department responded. ODEQ conducted a site visit to survey any damage.

5. Is the remedy functioning as expected? Yes, the remedy is functioning as expected.

6. Do you have any comments, suggestions, or recommendations regarding the project? No.

26

INTERVIEW RECORD



Type: Other

Contact Made By:



Quality (ODEQ)


Name: Amy Brittain Title: Env. Programs Manager Organization: ODEQ


Fax No: 405-702-5101





1. What is your overall impression of the project? The landfills are well vegetated. As community concerns are raised ODEQ and EPA work to try to

respond in a timely manner. Work continues to move forward in respect to final cleanup of the north

side and ground water.

2. What effect has the project had on the surrounding community? The south side of the site is used for cattle grazing. The community is waiting for the rest of the site to

have cleanup completed so that it can be safely used.

3. Are you aware of any community concerns regarding the site or its operation and administration? The community has raised concerns with flooding as surface water enters the north side of the site. The

community has also raised concerns about vegetation on the north side of the site.

27

INTERVIEW RECORD



Type: Other

Contact Made By:



Quality (ODEQ)


Name: Amy Brittain Title: Env. Programs Manager Organization: ODEQ


Fax No: 405-702-5101





4. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of your responses. A wild fire spread onto the site several years ago, ODEQ personnel responded to ensure no parts of the

remedy were impacted. The only impact identified was a gate that was damaged during the fire

departments response. ODEQ has since fixed the gate.

A large flooding event occurred in Spring of 2016 in the town. ODEQ personnel responded by

coordinating efforts with EPA Region 6 to clean out the drainage ditch that bisects the north side of the

site. ODEQ also removed vegetation and soil from the ditch to try to increase the drainage potential.

5. Is the remedy functioning as expected? Yes, the landfills continue to function properly.

6. Do you have any comments, suggestions, or recommendations regarding the project? ODEQ and EPA should continue to work on Operable Unit 2 and 3 so that a final cleanup strategy can be

implemented at the site.

28

INTERVIEW RECORD



Type: Other Incoming Outgoing

Contact Made By:

Name: Kyle Gregory Title: Engineer Intern II Organization: ODEQ


Name: Lynn Schonchin Title: Assistant Director Organization: Comanche Nation

Office of Environmental Programs

Telephone: 580-492-3754

Fax No:


Street Address:

City, State, Zip:

Summary Of Conversation

1. What is your overall impression of the work conducted at the ORC Site? As there are tribal members and our

non-tribal neighbors whom live next to the ORC site, I and my coworkers are pleased with the progress and

work being completed on the site.

2. How has the Comanche Nation Office of Environmental Programs been involved with the ORC site in the last

five years? The Comanche Nation Office of Environmental Programs has had little involvement with the ORC

site until the recent year when our office was asked to help make contact with area tribal members.

3. From your perspective, what effects have continued remedial operations at the site had on the surrounding

community? The work being done has eased the tension of all those whom live not only by the ORC site but

those whom live in the town of Cyril and all those downstream.

4. Are you aware of any ongoing community concerns regarding the site in regard to its operation and

maintenance or other issues? The one concern I hear still is when a flooding event does occur how much

contamination is released especially downstream and to what levels the ground water has been affected.

5. Do you feel well-informed about the site’s activities and progress? Our office, until very recently, has

received little to no information regarding the work on or data collected concerning the ORC site. As such

we do not feel well informed.

6. Do you have any comments, suggestions, or recommendations regarding the site? I would hope that more

information would be shared with the public thru news media, television or some source similar. I do

appreciate the personal visits to our office and the information shared to this point, thank you.

29

INTERVIEW RECORD



Type: Other Incoming Outgoing

Contact Made By:



Quality (ODEQ)


Name: Jason White Title: Environmental Programs

Manager

Organization: Inter-Tribal

Environmental Council

Telephone (918) 453-5110

Fax No: (918) 453-2904


Street Address: 206 East Allen Road

City, State, Zip: Tahlequah, Ok, 74464

Summary Of Conversation

7. What is your overall impression of the work conducted at the ORC Site? The overall impression has been

great. The ORC Site is safer for the community and the environment since remediation activities have taken

place on the site. There is still work to be done but overall the cleanup of the Superfund Site has been

beneficial to the community.

8. How has the Inter-Tribal Environmental Council been involved with the ORC site in the last five years? The

Inter-Tribal Environmental Council has been working with the Tribes impacted from the Superfund Site. We

have been corresponding with ODEQ and Tribes regarding updates for the clean up of the site. The Inter-

Tribal Environmental Council organized a meeting with the Tribes, ODEQ, and EPA.

9. From your perspective, what effects have continued remedial operations at the site had on the surrounding

community? Remedial operations have been positive for the community. Knowing that the site is getting

cleaned up helps make the community safer and their environment cleaner.

10. Are you aware of any ongoing community concerns regarding the site in regard to its operation and

maintenance or other issues? One issue that was been brought to our attention is the fencing. The fencing

has had issues or concerns about site restriction to the property. There has been holes or areas that

trespasser can access the site. We have also heard about people swimming in the pond on-site. The pond

may need to be drained to eliminate swimming and wildlife from being exposed to contaminants.

11. Do you feel well-informed about the site’s activities and progress? Yes, ODEQ has been very involved in

keeping everyone up to date on activities for the OKC Site.

12. Do you have any comments, suggestions, or recommendations regarding the site? Keep up the good work

and please check on maintaining the fencing and signage for the site.

30

INTERVIEW RECORD



Type: Phone

Contact Made By:



Quality (ODEQ)


Name: Brad Alexander Title: City Mayor Organization: Cyril City

Management

Telephone No: (405)222-8654

Fax No:


Street Address:

City, State, Zip:


1. What is your overall impression of the project? Brad suggested ODEQ begin quarterly meetings again

between Cyril, ODEQ, and EPA regarding ORC North and future remediation work. Brad expressed

concerns that there may have been funds mismanagement and over-spending occurring during the

original remediation on ORC South.

2. From your perspective, what effects have continued remedial operations at the site had on the

surrounding community? Brad believes the continued remediation work is benefitting the community.

3. Are you aware of any community concerns regarding the site or its operation and administration? Brad

suggests that the slow response to the on-site drainage ditch flooding issues may have exacerbated

flooding issues in Cyril. Brad would like to better understand the project timeline, how the work will

impact the community, and whether local resources will be utilized.

4. Are you aware of any unanticipated events, incidents, or activities that have occurred at the site,

such as dumping, vandalism, fire, or anything that required emergency response from local authorities? If

so, please give details. Brad mentioned the 2015 wildfire and how regular mowing of vegetation would

help protect homes near the ORC site.

5. Are you aware of any changes in land use at or near the site? Has your office had any inquiries

regarding potential reuse of the property, and if so, what were they? Brad would like to work with

Stillwater Central Railroad to help new industry enter Cyril. Brad hopes that the large number of railroad

spurs will be an excellent selling point for industry to ship product to a nearby port. There have been no

changes in actual land use near the site.

6. Do you have any comments, suggestions, or recommendations regarding the project? Brad expressed

appreciation that ODEQ and EPA are working on the site and that remediation work is benefitting the

community. Brad also suggests that remediation work should utilize Cyril local business and resources

whenever possible. Brad also urges the proper expenditure of funds on appropriate remediation efforts

without excessive spending in future remediation efforts.

31

INTERVIEW RECORD



Type: Other

Contact Made By:



Quality (ODEQ)


Name: Todd Downham Title: Env. Programs Specialist Organization: ODEQ

Telephone No: (405) 702-5136

Fax No: (405) 702-5101


Street Address: 707 N Robinson, P.O. Box 1677

City, State, Zip: Oklahoma City, OK. 73101-1677


1. What is your overall impression of the project? -Good

2. Is there a continuous on site O&M presence? If so, please describe staff activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities. -ODEQ personnel perform quarterly inspections to determine the condition of the cover (grass), fencing integrity, presence of erosion and animal burrowing.

3. Have there been any significant changes in the O&M requirements, maintenance schedules, or sampling routines in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy?

Please describe changes and impacts.

-No significant changes

4. Do you have any recommendations to improve landfill O&M? -Animal burrowing continues to be a minor issue. It could cause erosion issues in the future.

32

APPENDIX F – SAMPLE O&M REPORT

34

APPENDIX G – GLADYS CREEK BANK SLOPE FAILURE PHOTOGRAPHS

36

APPENDIX H – CAPPED AREAS MAP

37

APPENDIX I – FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site name: Oklahoma Refining Co. (ORC) Date of inspection: 12/8/2016

Location and Region: Cyril, Oklahoma R6 EPA ID: OKD091598870

Agency, office, or company leading the five-year

review: ODEQ

Weather/temperature: Scattered clouds, windy,

high of 33

Remedy Includes: (Check all that apply)

x Landfill cover/containment □ Monitored natural attenuation

x Access controls □ Groundwater containment

x Institutional controls □ Vertical barrier walls

□ Groundwater pump and treatment

□ Surface water collection and treatment

□ Other______________________________________________________________________

_____________________________________________________________________________

Attachments: □ Inspection team roster attached □ Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager _____Todd Downham________ __________EPS_____ _______12/29/2016_____

Name Title Date

Interviewed □ at site X at office □ by phone Phone no. ______________

Problems, suggestions; x Report attached ________________________________________________

__________________________________________________________________________________

2. O&M staff ____________________________ ______________________ ____________

Name Title Date

Interviewed □ at site □ at office □ by phone Phone no. ______________

Problems, suggestions; □ Report attached _______________________________________________

__________________________________________________________________________________

38

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 of

deeds, or other city and county offices, etc.) Fill in all that apply.

Agency ____________________________

Contact ____________________________ __________________ ________ ____________

Name Title Date Phone no.

Problems; suggestions; □ Report attached _______________________________________________

__________________________________________________________________________________

Agency ____________________________

Contact ____________________________ __________________ ________ ____________



__________________________________________________________________________________

Agency ____________________________

Contact ____________________________ __________________ ________ ____________



__________________________________________________________________________________

Agency ____________________________

Contact ____________________________ __________________ ________ ____________



__________________________________________________________________________________

4. Other interviews (optional) □ Report attached.

Amy Brittain – Environmental Programs Manager, ODEQ

39

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents

□ O&M manual □ Readily available □ Up to date X N/A

□ As-built drawings □ Readily available □ Up to date □ N/A

□ Maintenance logs □ Readily available □ Up to date □ N/A

Remarks__________________________________________________________________________

____________________________________________________________________

2. Site-Specific Health and Safety Plan □ Readily available □ Up to date X N/A

□ Contingency plan/emergency response plan □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. O&M and OSHA Training Records □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Permits and Service Agreements

□ Air discharge permit □ Readily available □ Up to date X N/A

□ Effluent discharge □ Readily available □ Up to date X N/A

□ Waste disposal, POTW □ Readily available □ Up to date X N/A

□ Other permits_____________________ □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Gas Generation Records □ Readily available □ Up to date □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Settlement Monument Records □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

7. Groundwater Monitoring Records □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

8. Leachate Extraction Records □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

9. Discharge Compliance Records

□ Air □ Readily available □ Up to date X N/A

□ Water (effluent) □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

10. Daily Access/Security Logs □ Readily available □ Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

40

IV. O&M COSTS

1. O&M Organization

X State in-house □ Contractor for State

□ PRP in-house □ Contractor for PRP

□ Federal Facility in-house □ Contractor for Federal Facility

□ Other__________________________________________________________________________

_________________________________________________________________________________

2. O&M Cost Records

X Readily available X Up to date

□ Funding mechanism/agreement in place

Original O&M cost estimate___19,196.50_____ X Breakdown attached

Total annual cost by year for review period if available

From__________ To__________ __________________ X Breakdown attached

Date Date Total cost









3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons: __________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

V. ACCESS AND INSTITUTIONAL CONTROLS X Applicable □ N/A

A. Fencing

1. Fencing damaged □ Location shown on site map □ Gates secured □ N/A

Remarks___Site fence was damaged and repaired in several areas by site lessee_________________

_________________________________________________________________________________

B. Other Access Restrictions

1. Signs and other security measures □ Location shown on site map □ N/A

Remarks_____Signs in place__________________________________________________

_________________________________________________________________________________

41

C. Institutional Controls (ICs)

1. Implementation and enforcement

Site conditions imply ICs not properly implemented □ Yes X No □ N/A

Site conditions imply ICs not being fully enforced □ Yes X No □ N/A

Type of monitoring (e.g., self-reporting, drive by) _________________________________________

Frequency ________________________________________________________________________

Responsible party/agency ____________________________________________________________

Contact ____________________________ __________________ ________ ____________


Reporting is up-to-date □ Yes □ No X N/A

Reports are verified by the lead agency □ Yes □ No X N/A

Specific requirements in deed or decision documents have been met X Yes □ No □ N/A

Violations have been reported □ Yes □ No X N/A

Other problems or suggestions: □ Report attached

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

2. Adequacy X ICs are adequate □ ICs are inadequate □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

D. General

1. Vandalism/trespassing □ Location shown on site map X No vandalism evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Land use changes on site X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Land use changes off site X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

VI. GENERAL SITE CONDITIONS

A. Roads □ Applicable □ N/A

1. Roads damaged □ Location shown on site map X Roads adequate □ N/A

Remarks____The road by the creek bank collapse may be damaged if erosion continues__________

_________________________________________________________________________________

42

B. Other Site Conditions

Remarks _The stream bank is collapsing in areas and is causing damage to the perimeter

fence._____________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________

____________________________________________________________________

VII. LANDFILL COVERS X Applicable □ N/A

A. Landfill Surface

1. Settlement (Low spots) □ Location shown on site map X Settlement not evident

Areal extent______________ Depth____________

Remarks____________________________________________________________

__________________________________________________________________

2. Cracks □ Location shown on site map X Cracking not evident

Lengths____________ Widths___________ Depths__________

Remarks____________________________________________________________

__________________________________________________________________

3. Erosion □ Location shown on site map X Erosion not evident


Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Holes □ Location shown on site map □ Holes not evident

Areal extent_minimal_____ Depth__less than one foot___

Remarks_Signs of burrowing animals______________________________________________

_________________________________________________________________________________

5. Vegetative Cover X Grass X Cover properly established X No signs of stress

□ Trees/Shrubs (indicate size and locations on a diagram)

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Alternative Cover (armored rock, concrete, etc.) □ N/A

Remarks_Rock armor on let-down structures in place and intact.__________

_________________________________________________________________________________

7. Bulges □ Location shown on site map X Bulges not evident

Areal extent______________ Height____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

8. Wet Areas/Water Damage □ Wet areas/water damage not evident

□ Wet areas □ Location shown on site map Areal extent______________

□ Ponding □ Location shown on site map Areal extent______________

□ Seeps □ Location shown on site map Areal extent______________

□ Soft subgrade □ Location shown on site map Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________

43

9. Slope Instability □ Slides □ Location shown on site map X No evidence of slope instability

Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________

B. Benches □ Applicable X N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope

in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

channel.)

1. Flows Bypass Bench □ Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Bench Breached □ Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Bench Overtopped □ Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

C. Letdown Channels X Applicable □ N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

cover without creating erosion gullies.)

1. Settlement □ Location shown on site map X No evidence of settlement


Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Material Degradation □ Location shown on site map X No evidence of degradation

Material type_______________ Areal extent_____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Erosion □ Location shown on site map X No evidence of erosion


Remarks__________________________________________________________________________

_________________________________________________________________________________

44

4. Undercutting □ Location shown on site map X No evidence of undercutting


Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Obstructions Type_____________________ X No obstructions

□ Location shown on site map Areal extent______________

Size____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Excessive Vegetative Growth Type____________________

□ No evidence of excessive growth

X Vegetation in channels does not obstruct flow

□ Location shown on site map Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________

D. Cover Penetrations X Applicable □ N/A

1. Gas Vents □ Active □ Passive

□ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition

□ Evidence of leakage at penetration □ Needs Maintenance

X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Gas Monitoring Probes


□ Evidence of leakage at penetration □ Needs Maintenance X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Monitoring Wells (within surface area of landfill)


□ Evidence of leakage at penetration □ Needs Maintenance X N/A

Remarks___________________________________________________________

_________________________________________________________________

4. Leachate Extraction Wells

□ Properly secured/locked □ Functioning □ Routinely sampled X Good condition

□ Evidence of leakage at penetration X Needs Maintenance □ N/A

Remarks__The leachate collection and monitoring system is experiencing issues with the PVC caps

blowing off. A new cap design should be implemented to prevent rainwater from invading the leachate

system.__________________________________________

5. Settlement Monuments X Located □ Routinely surveyed □ N/A

Remarks_Signs of burrowing animals near settlement monument____________________________

_________________________________________________________________________________

45

E. Gas Collection and Treatment □ Applicable X N/A

1. Gas Treatment Facilities

□ Flaring □ Thermal destruction □ Collection for reuse

□ Good condition □ Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Gas Collection Wells, Manifolds and Piping


Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

□ Good condition □ Needs Maintenance □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

F. Cover Drainage Layer □ Applicable X N/A

1. Outlet Pipes Inspected □ Functioning □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Outlet Rock Inspected □ Functioning □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

G. Detention/Sedimentation Ponds □ Applicable X N/A

1. Siltation Areal extent______________ Depth____________ □ N/A

□ Siltation not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Erosion Areal extent______________ Depth____________

□ Erosion not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Outlet Works □ Functioning □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Dam □ Functioning □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

46

H. Retaining Walls □ Applicable X N/A

1. Deformations □ Location shown on site map □ Deformation not evident

Horizontal displacement____________ Vertical displacement_______________

Rotational displacement____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Degradation □ Location shown on site map □ Degradation not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

I. Perimeter Ditches/Off-Site Discharge X Applicable □ N/A

1. Siltation □ Location shown on site map □ Siltation not evident


Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Vegetative Growth □ Location shown on site map □ N/A

□ Vegetation does not impede flow

Areal extent______________ Type____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Erosion □ Location shown on site map □ Erosion not evident

Areal extent_Approx. 50 linear feet Depth____________

Remarks_Nearby Gladys creek is experiencing bank collapse which is invading into ORC South.____

_________________________________________________________________________________

4. Discharge Structure □ Functioning X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

VIII. VERTICAL BARRIER WALLS □ Applicable X N/A

1. Settlement □ Location shown on site map □ Settlement not evident


Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Performance Monitoring Type of monitoring__________________________

□ Performance not monitored

Frequency_______________________________ □ Evidence of breaching

Head differential__________________________

Remarks__________________________________________________________________________

_________________________________________________________________________________

47

IX. GROUNDWATER/SURFACE WATER REMEDIES □ Applicable X N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines □ Applicable □ N/A

1. Pumps, Wellhead Plumbing, and Electrical

□ Good condition □ All required wells properly operating □ Needs Maintenance □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances


Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Spare Parts and Equipment

□ Readily available □ Good condition □ Requires upgrade □ Needs to be provided

Remarks__________________________________________________________________________

_________________________________________________________________________________

B. Surface Water Collection Structures, Pumps, and Pipelines □ Applicable □ N/A

1. Collection Structures, Pumps, and Electrical


Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances


Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Spare Parts and Equipment

□ Readily available □ Good condition □ Requires upgrade □ Needs to be provided

Remarks__________________________________________________________________________

_________________________________________________________________________________

48

C. Treatment System □ Applicable X N/A

1. Treatment Train (Check components that apply)

□ Metals removal □ Oil/water separation □ Bioremediation

□ Air stripping □ Carbon adsorbers

□ Filters_________________________________________________________________________

□ Additive (e.g., chelation agent, flocculent)_____________________________________________

□ Others_________________________________________________________________________


□ Sampling ports properly marked and functional

□ Sampling/maintenance log displayed and up to date

□ Equipment properly identified

□ Quantity of groundwater treated annually________________________

□ Quantity of surface water treated annually________________________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Electrical Enclosures and Panels (properly rated and functional)

□ N/A □ Good condition □ Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Tanks, Vaults, Storage Vessels

□ N/A □ Good condition □ Proper secondary containment □ Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Discharge Structure and Appurtenances

□ N/A □ Good condition □ Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Treatment Building(s)

□ N/A □ Good condition (esp. roof and doorways) □ Needs repair

□ Chemicals and equipment properly stored

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Monitoring Wells (pump and treatment remedy)


□ All required wells located □ Needs Maintenance □ N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

D. Monitoring Data

1. Monitoring Data

□ Is routinely submitted on time □ Is of acceptable quality

2. Monitoring data suggests:

□ Groundwater plume is effectively contained □ Contaminant concentrations are declining

49

D. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy)


□ All required wells located □ Needs Maintenance X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

X. OTHER REMEDIES

If there are remedies applied at the site which 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 OBSERVATIONS

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., to contain contaminant plume,

minimize infiltration and gas emission, etc.).

_The purpose of the landfill remedy is to prevent human and environmental exposure

to hazardous and other materials. The intact landfill cover and capped soil areas

currently prevent exposure to contaminated materials. Although the Glady creek bank

collapse is not currently invading the nearby capped areas, it has created an area where

the fence may continue to collapse. This fence must be repaired to prevent additional

long-term issues on the ORC site._________________________________________

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In

particular, discuss their relationship to the current and long-term protectiveness of the remedy.

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

50

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high

frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be

compromised in the future.

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

51

APPENDIX J – CAPPED ACID FLOW AREA

NOTE: The green star denotes erosion.

52

APPENDIX K – ARARS FROM OU1 ROD The ARARs identified by the ROD for the ORC site include chemical- and action-specific ARARs for soil and

sediment, and chemical- and action-specific ARARs for ground water. The ROD identified the following ARARs

as having an impact on the proposed remedy:

Chemical-Specific ARARs for Soil and Sediment

1. Identification and Listing of Hazardous Waste (40 CFR Part 261), Subpart C - Characteristics of Hazardous

Waste, and Subpart D - Lists of Hazardous Waste.

2. Land Disposal Restrictions (40 CFR Part 268), Subpart A (268.4) - Treatment Surface Impoundment

Exemption, and Subpart D - Treatment Standards.

3. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61).

4. Air Pollution Permits (Oklahoma Air Pollution Control Rules, OAC 310:200-7).

5. Control of Emissions of Organic Materials (Oklahoma Air Pollution Control rules, OAC

310:200-37).

6. Control of Emissions of Hazardous and Toxic Air Contaminants (Oklahoma Air Pollution Control Rules, OAC

310:200-41).

Action-Specific ARARs for Soil and Sediment

1. Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities (40 CFR

Part 264).

2. Treatment Surface Impoundment Exemption (40 CFR 268.4).

Chemical-Specific ARARs for Ground Water

1. Identification and Listing of Hazardous Waste (40 CFR Part 262), Subpart C - Characteristics of Hazardous

Waste.

2. National Primary Drinking Water Regulations (40 CFR Part 141).

3. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61).

4. Control of Emissions of Organic Materials (Oklahoma Air Pollution control Rules, OAC

310:200-37).

5. Control of Emissions of Hazardous and Toxic Air Contaminants (Oklahoma Air Pollution Control Rules,

OAC 310:200-41).

Action-Specific ARARs for Ground Water

1. Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities (40

CFR Part 264)

2. Standards Applicable to Transporter of Hazardous Waste (40 CFR Part 263).

The Oklahoma Air Pollution Control Rules cited above under the chemical-specific ARARs for soil were revised

and codified during the 2001 legislative session. The regulations that are relevant to activities conducted at the ORC

site are now found as:

• Control of Emission of Volatile Organic Compounds (VOCs) (Oklahoma Air Pollution Control Rules, OAC

252:100-37).

• Control of Emissions of Hazardous Air Pollutants and Toxic Air Contaminants (Oklahoma Air Pollution

Control Rules, OAC 252:100-41).

53

Activities relating to source remediation for the north side of the property not addressed under removal authority

have not yet started, The National Emissions Standards for Hazardous Air Pollutants, Air Pollution Permits,

Control of Emissions of Organic Materials, and Control of Emissions of Hazardous and Toxic Air Contaminants

regulations will apply for soil once remediation of the north refinery area begins.

The ROD specified that ground water and surface water RAOs were to be set at levels which would allow use of

the water as a primary drinking water source. The MCL for arsenic, beryllium and copper have changed since the

ROD was signed. The MCLs for the arsenic was revised as of January 23, 2006, from 50 μg/L to 10 μg/L. For

beryllium and copper, the MCLs were set higher at 4 μg/L and 1300 μg/L, respectively. To ensure protectiveness

of the remedy relative to the site ground water, the ground water RAOs should be set at the current MCL for each

contaminant. No significant changes have occurred to the remaining ARARs that would call into question the

effectiveness of the remedy.

Regulations for worker health and safety have been promulgated at 29 CFR Part 1910. These regulatory

requirements are specifically addressed in the ORC site-specific health and safety plan.