Targeted brownfield assessment for Oklahoma Army National Guard, former Haskell armory, Haskell, Oklahoma.

              Phase I TBA 1 Haskell Armory
Haskell, Oklahoma
TARGETED BROWNFIELD ASSESSMENT
For
Oklahoma Army National Guard
Former Haskell Armory
Haskell, Oklahoma
ASTM E 1527-05
Phase I Environmental Site Assessment
All Appropriate Inquiry
Prepared by:
June 24, 2011
Phase I TBA 2 Haskell Armory
Haskell, Oklahoma
Prepared for:
The City of Haskell
P.O. Box 9
Haskell, Oklahoma 74436
Prepared by:
Oklahoma Department of Environmental Quality
Land Protection Division
707 N. Robinson
P.O. Box 1677
Oklahoma City, Oklahoma 73101-1677
I declare that to the best of my professional knowledge and belief, I meet the definition of
Environmental Professional as defined in Section 312.10 of this part. I have specific qualifications based
on education training, and experience to assess a property of the nature, history and setting of the
subject property. I have developed and performed the all appropriate inquiry in conformance with the
standards and practices set forth in 40 CFR Part 312.
Environmental Professionals in charge of the project:
_____________________________________
Rachel Francks
Environmental Programs Specialist I
_____________________________________
Heather Mallory
Environmental Programs Specialist III
Phase I TBA 3 Haskell Armory
Haskell, Oklahoma
Table of Contents
1.0 Executive Summary…………………………………………………………………………………………………….. 5
2.0 Introduction……………………………………………………………………………………………………………….. 6
2.1 Purpose …………………………………………………………………………………………….……..…………… 7
2.2 Detailed Scope-of-services ……………………………………………………………….…………………… 7
2.3 Significant Assumptions …………………………………………………………………….………………….. 7
2.4 Limitations and Exceptions ………………………………………………………………………….………… 8
2.5 Special Terms and Conditions ……………………………………………………………………………….. 8
3.0 Site Characterization and History ………………………………………………………………………………… 8
3.1 Location and Legal Description ……………………………………………………………………………… 8
3.2 Site and Vicinity Characterization ………………………………………………………………………….. 9
3.3 Descriptions of Structures, Roads and Other Improvements ……………………………….. 9
3.4 Owner, Property Manager, and Occupant Information ………………………………………… 10
3.5 Information Reported by User Regarding Environmental Lien or Specialized
Knowledge or Experience …………………………………………………………………………………….. 10
3.6 Commonly Known or Reasonable Ascertainable Information ………………………….……. 10
3.7 Valuation Reduction for Environmental Issues ………………………………………………………. 10
3.8 Current Use of Property ………………………………………………………………………………………… 10
3.9 Past Use of Property ……………………………………………………………………………………………… 11
3.9.1 Review of Aerial Photos ………………………………………………………………………………….. 11
3.9.2 Fire Insurance Maps ………………………………………………………………………………………… 12
3.10 Current and Past Use of Adjoining Properties ………………………………………………….……. 12
3.11 Environmental (Physical) Setting ……………………………….……………………..…………………… 12
3.11.1 Surface Water Characteristics …………………………………………………………………………. 13
3.11.2 Subsurface Geological Characteristics …………………………..………………………….…….. 13
3.11.3 Ground Water Characteristics …………………………………………………………………………. 13
3.11.4 Air Characteristics …………………………………………………………………………………………… 13
4.0 Records Review ………………………………………………………………………………………….………………. 14
4.1 Federal National Priorities List (NPL) …………………………………………………………………….. 14
4.2 Federal CERCLIS List ………………………………………………………………………………………………. 14
4.3 Federal RCRA CORRACTs List ………………………………………………………………………….……… 14
4.4 Federal RCRA non-CORRACTS TSD List …………………………………………………….…………….. 14
4.5 Federal RCRA Generators List …………………………………………………………���…………………... 14
4.6 Federal ERNS List …………………………………………………………………………………………………… 15
4.7 Federal Institutional Control/Engineering Control Registries ………………………………… 15
4.8 State-Equivalent NPL …………………………………………………………………………………………….. 15
4.9 State-Equivalent CERCLIS ……………………………………………………………………………………… 15
4.10 State Landfill and/or Solid Waste Disposal Sites …………………………………………………… 15
4.11 State Leaking UST List …………………………………………………………………………………………… 15
4.12 State Registered UST Sites ……………………………………………………………………………………. 15
4.13 State Institutional Control/Engineering Control Registries ……………………………………. 16
4.14 State Voluntary Cleanup Sites ………………………………………………………………………………. 16
4.15 State Brownfield Sites ……………………………………………………………………………………………. 16
4.16 Oil and Gas Records ………………………………………………………………………………………………. 16
Phase I TBA 4 Haskell Armory
Haskell, Oklahoma
5.0 Site Reconnaissance and Interviews ……………………………………………………………………………. 16
5.1 Methodology and Limiting Conditions ……………………………………….………………………….. 16
5.2 General Site Conditions ……………………………………………………………….………………………… 17
5.2.1 Above Ground Storage Tanks (ASTs) ………………………………………………………………… 17
5.2.2 Landfills and/or Dumping …………………….…………………………………………………………. 17
5.2.3 Impoundments ……………………………..………………………………………………………………… 17
5.2.4 Monitoring Wells …………………………………………………………………………………………….. 17
5.2.5 Disturbed and Stained Soil ………………………………………………………………………………. 17
5.2.6 Seeps ………………………………………………………………………………………………………………. 18
5.2.7 Chemical Spills …………………………….………………………………………………………………….. 18
5.2.8 Farm Waste ……………………………………………………………………………………………………… 18
5.2.9 Known Pesticide Misapplication ………………………………………………………��…………… 18
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site …………………… 18
5.2.11 Petroleum Products and Oil and Natural Gas Exploration ……………………………….. 18
5.2.12 Asbestos …………………………………………………………………………………………………………. 18
5.2.13 Lead ………………………………………………………………………………………………………………… 19
5.2.14 Transformers/PCB Equipment …………………………………………………………………………. 19
5.3 External Observations …………………………………………………………….…………………………….. 19
5.4 Internal Observations ………………………..………………………………………………………………….. 19
5.5 Interviews ……………………………………………………………………………………��……………………… 20
6.0 Findings ………………………………………………………………………………………………………………………. 20
7.0 Opinion and Recommendations ………………………………………………………………………………….. 21
8.0 Data Gaps …………………………………………………………………………………………………………………… 21
9.0 Conclusions …………………………………………………………………………………………………………………. 21
10.0 Additional Services ……………………………………………………………………………………………………… 22
11.0 Deviations …………………………………………………………………………………………………………………… 22
12.0 References …………………………………………………………………………………………………………………. 23
13.0 Appendices ………………………………………………………………………………………………………………… 24
A. Oklahoma Corporation Commission Oil and Gas Records
B. Oklahoma Corporation Commission UST records
C. Limited Environmental Baseline Assessment. Oklahoma Army National Guard
Highway 64 North, Haskell, OK. Oklahoma Military Department Environmental
Office.
D. Caldwell Environmental Work Plan for Remediation of Lead Contamination,
Oklahoma Army National Guard, Haskell, OK.
E. Photographs from site visit April 22, 2011
F. FEMA Flood Zone Map
G.
Memorandum of Agreement between Oklahoma Department of Environmental
Quality and the Town of Haskell
H. Deeds
I. Qualifications of Environmental Professionals
J. USGS Topographical Map Muskogee County
K. Aerial Photographs
14.0 Background and Disclaimer ………………………………………………………………………………………….
Phase I TBA 5 Haskell Armory
Haskell, Oklahoma
Phase I Assessment
1.0 Executive Summary
On April 22, 2011, Rachel Francks, John Reid, and Savannah Smith of the DEQ performed site
reconnaissance of the Haskell National Guard Armory located at Township 16N, Range 15E, Section
26, NW¼, SE ¼ Muskogee County, Oklahoma, as part of a Targeted Brownfield Assessment (TBA).
The subject property is situated south of a tributary to Coal Creek and to the west of the Union
Pacific (UP) rail line. The purpose of the TBA was to identify potential environmental concerns by
reviewing historical data, regulatory information, and by performing a visual inspection of the site
and surrounding area. The following is an executive summary of the environmental site assessment
results:
Recognized environmental conditions (REC) include the indoor firing range and the vent from
the firing range on the roof of the armory. There are also some panels below the windows,
sound reducing panels in the firing range, floor tiles, black mastic and insulation around pipes
that may be asbestos containing materials (ACMs).
The Haskell National Guard Armory was built in 1982 and is currently on the National Register of
Historic Places. The property was managed and maintained by the Oklahoma Military
Department (on behalf of the State of Oklahoma). Ownership of the subject property has been
transferred to the City of Haskell as of the 13 September, 2010. The City Manager in agreement
with the City of Haskell is currently working on clean up and development as well as using the
building for city storage. Once clean up activities have occurred, the town hall will be moved
into the building.
There is one large building on the site that has a large garage and indoor firing range area. The
offices surround the garage and the indoor firing range (IFR). There is a kitchen to the north of
the garage that has grease traps still installed. All other appliances have been removed. There
are pipes in the kitchen and the rooms to the west of the garage area that are surrounded by
insulation that may be ACM. There is another small detached building made of corrugated
metal. It doesn’t appear to have any utilities hooked up to it and it doesn’t have a door. The
shed is in poor condition.
The property contains an IFR that was last serviced in 2005. During the service the sand from
the pit was piled outside the building before removal. There are no records of the exact location
of the sand pile but it is assumed the sand would have been piled on the east side of the
building near the door to the IFR. There was no sand found on any of the soil areas on the east
side of the building and there was no distressed vegetation in the area. There was no sand
present in the trap during the site visit and the backstop had also been removed. The IFR has a
vent fan attached to the roof of the building. Soil samples were collected from around the rain
gutter down spouts.
Phase I TBA 6 Haskell Armory
Haskell, Oklahoma
Adjoining properties consist of the UP train tracks, residential areas, undeveloped land and an
auto-body shop. Historical aerial photographs beginning in 1941 show the area as either
undeveloped or agricultural land. Aerial photos from 1995 – 2010 show the area around the
location to be occupied by agricultural fields to the west and residential housing to the north.
The 1995 map shows the area across the highway as undeveloped. After 2003 the aerial photos
show a church occupying the land across the highway and an auto-body shop approximately 800
ft to the SE.
The property is located in rural Haskell, so Sanborn Fire Insurance maps do not show the subject
property.
No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. There were no RCRA generators
listed within one mile of the subject property, and no archived Comprehensive Environmental
Response, Compensation, and Liability Information System (CERCLIS) site listings.
There was one underground storage tank on site. It had a 1,000 gallon capacity and was used to
store gasoline. The tank was removed in 1998 and the case was closed with the Oklahoma
Corporation Commission (OCC). At the time of removal the soil and the tank were tested with
an Organic Vapor Meter (OVM) Photoionization Detector (PID) and there were no fuel vapors
detected in the tank or in the soil. It is unknown how long the tank had been empty. When
pulled the tank was in good condition with no holes. The hole was filled with clean soil. There
was no sign of the UST or of soil staining, but the Haskell City Manager, Duane Points, told us
they had recently had the parking lot repaved with new gravel. The UST is considered a
historical recognized environmental condition (HREC).
Oil and gas exploration was found in the OCC oil and gas records on the adjoining properties, but
the holes drilled were dry. There was no record of oil and gas production on any adjoining sites.
No transformers were noted around the armory building. Fluorescent lighting ballasts are
located throughout the building. The lighting ballasts are all in good condition in most rooms.
The condition of the lights in the shower rooms is uncertain because the lights wouldn’t turn on
during the site visit. All fluorescent bulbs contain mercury and should be handled as Universal
Waste unless documentation and/or sampling demonstrate they are not hazardous.
2.0 Introduction
The State of Oklahoma Department of Environmental Quality (DEQ) under a Brownfield
Assistance Agreement (No. RP96681001-0) (Ref. 2) with the U.S. Environmental Protection
Phase I TBA 7 Haskell Armory
Haskell, Oklahoma
Agency (EPA) conducted a Targeted Brownfield Assessment of a property located at Township
16N, Range 15E, Section 26, NW¼, SE ¼ Muskogee County, Oklahoma.
2.1 Purpose
The purpose of this assessment is to look at the environmental conditions within the target area
and provide this information to the City of Haskell as well as meet the All Appropriate Inquiry
requirement of the landowner liability protections under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA, better known as Superfund – Ref. 3), as
provided in the Small Business Relief and Brownfield’s Revitalization Act of 2002 (Public Law
107-118, Subtitle B – Ref. 5). The purpose of a Phase I Environmental Site Assessment is to
identify, to the extent feasible, recognized environmental conditions in connection with the
target property through a systematic review of readily available information sources and a site
reconnaissance.
DEQ is providing technical assistance to the project by evaluating the environmental condition
of the property prior to the City of Haskell converting the armory for use as a City Hall. Funding
for this assessment has been provided by the U.S. Environmental Protection Agency (EPA).
2.2 Detailed Scope-of-Services
DEQ examined the current use of the property and then identified the historical uses of the
property to determine if recognized environmental conditions exist. DEQ examined historical
documents, governmental databases, oil and gas records, aerial photographs, Sanborn Fire
Insurance Maps, and conducted interviews and a site reconnaissance of the area. A good faith
effort was made to identify possible environmental conditions that might affect the
development of the property.
2.3 Significant Assumptions
History and knowledge of the subject property shows that the building was used as a National
Guard Armory. Prior to armory construction in 1982, the property was undeveloped land.
There has been no oil and gas exploration on the property according to Oklahoma Corporation
Commission records.
Since the building was constructed in 1982, the building may contain ACM. The U.S. began
banning the use of asbestos in most building materials in the 1970s due to studies confirming
the harmful health effects caused by exposure to airborne asbestos. Suspect floor and wall tiles
with black mastic, as well as window panels and insulation were observed in the building during
the site reconnaissance conducted on 22 April 2011. The DEQ plans to have a lead dust, lead
paint and asbestos survey conducted on the property.
Phase I TBA 8 Haskell Armory
Haskell, Oklahoma
2.4 Limitations and Exceptions
The purpose of an environmental site assessment is to identify actual or potential “recognized
environmental conditions” that may result in liability, land use restrictions, or cause delays in
revitalization. The ASTM Phase I Environmental Site Assessment E 1527 – 05 (Ref. 4) is the
minimum standard for environmental due diligence in the real estate industry and meets the
standard for All Appropriate Inquiry under the Small Business Liability Relief and Brownfields
Revitalization Act of 2002. A diligent effort in accordance with generally accepted good
commercial and customary standards and practices was undertaken to identify the “recognized
environmental conditions” that might affect the revitalization project. However, the
identification of old hazardous waste sites is an evolving process; therefore, DEQ cannot state
with absolute certainty that no other potential hazardous waste sites are located in the area.
This assessment was conducted under constraints of time, cost, and scope and reflects a limited
investigation and evaluation. It reflects the normal degree of care and skill that is ordinarily
exercised by environmental professionals conducting business in this or similar localities. In no
event shall the DEQ or its employees be liable for any damages, injury, loss, cost or expense
whatsoever arising in connection with the use or reliance on the information contained in this
report, except as otherwise provided by law.
The information in this report is based on a review of governmental records, interviews with
knowledgeable representatives of the property, information provided by the City of Haskell, and
observations of the environmental professional. The result of this assessment, as written in this
report, is valid as of the date of report. The assessment does not include sampling of rock,
groundwater, surface water, or air. For qualifications of environmental professionals see
Appendix I.
2.5 Special Terms and Conditions
This assessment report has been prepared for the City of Haskell by the DEQ using EPA funding.
Information about this report will be provided to the EPA for its files. This report and the
working file are public record and subject to the Oklahoma Open Records Act and the federal
Freedom of Information Act.
3.0 Site Characterization and History
3.1 Location and Legal Description
The subject property is located in the NW quadrant 194th and Duncan St. NW of Haskell,
Oklahoma along highway 64 approximately 1 mile. This property consists of approximately
8 acres of land and contains the former National Guard Armory building. A site map and
topographical map depicting the property have been provided in Appendix A.
Phase I TBA 9 Haskell Armory
Haskell, Oklahoma
The subject property is located in Section 26, Township 16N, Range 15E, NW¼, SE ¼ of
Muskogee County, Oklahoma.
Records at the Muskogee County Courthouse were searched to determine ownership and
operational history of the subject property. It was determined that the property was
previously owned by the Town of Haskell and deeded to the Oklahoma Military for the State
of Oklahoma in 1978 for the purpose of building a National Guard Armory. Prior to 1978 the
property was unoccupied.
3.2 Site and Vicinity Characterization
The former Haskell Armory was built in 1982. According to Muskogee County land records,
the land for the building was deeded by the City of Haskell, on August 7, 1978, for benefit of
the Oklahoma National Guard (see Appendix J). The subject property is a tract of land about
eight acres in size. The subject property is located at 1600 Haskell Blvd, Haskell, Oklahoma
bound by Haskell Blvd. on the west, and UP train tracks on the east. The areas where the
subject property and adjacent properties are located are best characterized by rural
development and undeveloped land. Undeveloped land surrounds the property to the
south, agricultural fields are to the east and there are rural residential areas to the north
and west across the highway.
Asbestos may be present onsite due to the age of the building. Utilities that serve the
subject property are the City of Haskell for natural gas and OG&E for the electric, and the
City of Haskell provides water and sewer services to the armory according to Duane Points,
city manager for the City of Haskell.
A review of the topographical map indicated that the surface elevation of the site is
approximately 600 feet above mean sea level. The topographical gradient is to the
north/northwest, toward a tributary of Coal Creek. The Coal Creek tributary is located
approximately 0.12 miles north of the site. Coal Creek is located 0.7 miles north and east of
the subject property. The topographical map can be found in Appendix G.
3.3 Description of Structures, Roads, and Other Improvements
The structure of the armory is in fair condition. The roof of the building has holes in several
locations; the kitchen and scullery, the machine room, the drill floor, the garage, and some
of the classrooms. There are leaks in locations where pipes come down from the roof or
ceiling. The floor was damaged in several places and black mastic was visible in the areas
where the white tiles had been removed. In addition there was damage to the concrete
floor in the room with the vault door. Windows were in good condition at the Armory.
Roads surrounding the Armory and the parking lot are in good condition. According to
Duane Points, the city administrator for the City of Haskell, the parking lot around the
Phase I TBA 10 Haskell Armory
Haskell, Oklahoma
armory was recently regraveled. All roads are constructed of asphalt pavement. Adjacent
properties, which consist of a residential and undeveloped land, are in fair condition.
Throughout the facility, there are floor drains. Based on previous armories, it is thought that
these drains lead into the city sanitary sewage pipes, but at the time of this report that
could not be confirmed.
3.4 Owner, Property Manager, and Occupant Information
The subject property is owned by the City of Haskell and is currently unoccupied. The DEQ
Site Cleanup Assistance Program (SCAP) is in charge of identifying environmental hazards
and conducting the cleanup of the Armory. The Military department transferred ownership
of the armory to the City of Haskell prior to completion of remedial activities.
3.5 Information Reported by User Regarding Environmental Lien or Specialized Knowledge or
Experience
The property owner and/or representatives reported no environmental liens on the subject
property, and had no specialized knowledge or experience regarding recognized
environmental conditions. The DEQ conducted a search for environmental liens at the
Seminole County Courthouse. No environmental liens or use limitations were reported for
the subject property.
3.6 Commonly Known or Reasonably Ascertainable Information
Duane Points, city administrator for the City of Haskell, had no exceptional knowledge of
commonly known or reasonably ascertainable information within the local community
about possible environmental conditions on the property. It is known within the community
that the building functioned as a National Guard Armory.
3.7 Valuation Reduction for Environmental Issues
Valuation of the property is outside the scope of this assessment. A professional appraiser
should be consulted to place a value on the property.
3.8 Current Use of the Property
The property is currently being used to store some items for the city of Haskell, but is largely
unused.
Phase I TBA 11 Haskell Armory
Haskell, Oklahoma
3.9 Past Use of the Property
3.9.1 Review of Aerial Photographs
Historic aerial photographs were searched to view the changes to the property
over time. Aerial photographs were obtained from the Department of Libraries
and the DEQ database of archived and present-day photographs. Aerial
photographs from 1941, 1995, 2003, 2005, and 2010 were obtained. All these
photographs are located in Appendix B. The following represents a summary of
what was found at the subject property from each photograph.
1941 aerial photograph
The 1941 aerial photograph shows the subject property to be next to highway
64 to the west, and Texas and Pacific train tracks to the east. All the land
surrounding and on the site is agriculture use. There is a tributary to Coal Creek
going from the southwest to the northeast to the north of the property.
1995 aerial photograph
The 1995 aerial photograph shows the subject property to be near residential
development to the north, Texas and Pacific train tracks and agriculture
development to the east, and undeveloped land to the south and the west. The
property contains a driveway and parking lot and the building is visible but the
eastern portion of the property is otherwise undeveloped. Highway 64 is to the
southwest of the property. There is a tributary to Coal Creek going from the
southwest to the northeast to the north of the property.
2003 aerial photograph
The 2003 aerial photograph shows the subject property to be near residential
development to the north, Texas and Pacific train tracks and agriculture or
undeveloped land to the east, and commercial development to the south and
the west. The property to the south appears to be a church with a large parking
lot and the property to the west is some other commercial property. The land
to the southeast is undeveloped. The armory property contains a driveway and
parking lot and the building is visible but the eastern portion of the property is
otherwise undeveloped. Highway 64 is to the southwest of the property. There
is a tributary to Coal Creek going from the southwest to the northeast to the
north of the property.
Phase I TBA 12 Haskell Armory
Haskell, Oklahoma
2005 aerial photograph
The 2005 aerial photograph shows the subject property to be near residential
development to the north, Texas and Pacific train tracks and agriculture or
undeveloped land to the east, and commercial development to the south and
the west. The property to the south appears to be a church with a large parking
lot and the property to the west is some other commercial property. The land
to the southeast is undeveloped. The armory property contains a driveway and
parking lot and the building is visible but the eastern portion of the property is
otherwise undeveloped. Highway 64 is to the southwest of the property. There
is a tributary to Coal Creek going from the southwest to the northeast to the
north of the property.
2010 aerial photograph
The 2003 aerial photograph shows the subject property to be near residential
development to the north, Texas and Pacific train tracks and agriculture or
undeveloped land to the east, and commercial development to the south and
the west. The property to the south appears to be a church with a large parking
lot and the property to the west is some other commercial property. The land
to the southeast is undeveloped. The armory property contains a driveway and
parking lot and the building is visible but the eastern portion of the property is
otherwise undeveloped. Highway 64 is to the southwest of the property. There
is a tributary to Coal Creek going from the southwest to the northeast to the
north of the property.
3.9.2 Fire Insurance Maps
The location is outside of the area covered by Sanborn Maps.
3.10 Current and Past Uses of Adjoining Properties
The areas around the site are mostly residential or agriculture/unused fields. There is
an autobody shop to the south of the site, but it is not on the RCRA generator lists.
3.11 Environmental Setting
The DEQ reviewed several sources to obtain information on the physical setting of the
subject property and its surrounding areas. These sources include: The United States
Department of Agriculture Oklahoma County Soil Survey, Oklahoma Geological Survey,
and the Federal Emergency Management Association. Review of the physical setting of
the area is to evaluate the sensitivity of the hydrogeology to potential contamination
from sources either on or near the site.
Phase I TBA 13 Haskell Armory
Haskell, Oklahoma
3.11.1 Surface Water Characteristics
The topography of the area is relatively flat. The Haskell Armory is located at a
surface elevation of approximately 600 feet above mean sea level. The
topographical gradient is to the north-northwest, toward the Coal Creek
tributary. The Coal Creek tributary is located approximately 0.12 miles north of
the site. Coal Creek is located 0.7 miles north-northeast of the subject property.
No surface water bodies are on the subject property or the adjoining properties.
According to the Federal Emergency Association, the subject property is in an
area outside the 500 year flood plain. According to FEMA (Ref. 14), Zone X is
outside the flood plain. The structure lies outside of the flood boundary line. A
map of this information is located in Appendix F.
3.11.2 Subsurface Geological Characterization
According to the Soil Survey of Muskogee County, Oklahoma, the subject
property consists mainly of Verdigris silt loam. Verdigris soils comprise around
5% and are characterized by a slope of 0 to 1 percent, a water table depth of
more than 80 inches, and a moderately high to high water capacity. Dennis silt
loam comprises 95% of the subject property area of interest and is
characterized by a slope of 1 to 3 percent, a water table depth of 12 to 30
inches, and high water capacity (Ref. 16).
3.11.3 Ground Water Characteristics
The hydrogeology as reported by Oklahoma Water Resource Board indicates the
site isn’t on any major or minor groundwater source. Throughout most of the
area, the substrata are not favorable for the production of ground water. There
are no major groundwater aquifers in this area. Oklahoma Water resources
board states that the closest aquifer in this area is the Arkansas River Alluvium
and Terrace approximately 2.3 miles to the east. The site is outside of the
vulnerability area for the aquifers. The subject site obtains its drinking water
from the City of Haskell, which uses surface water as its water source.
3.11.4 Air Characteristics
No air emissions were noticed at the subject property or the adjoining
properties. The DEQ dataviewer database was searched for Air Quality
Permitted Facilities (AQPF). No AQPF were found within 1 mile radius from the
subject property. No odors were noticed outside of the subject property during
the site visit. There is a potential for lead dust and asbestos emissions from the
subject property.
Phase I TBA 14 Haskell Armory
Haskell, Oklahoma
4.0 Records Review
A regulatory database search was conducted by the DEQ. This search included, at a minimum, those
records and distances from the site dictated as appropriate in the ASTM standard. The DEQ
performed a review of available federal and state databases to assess whether the subject property
or proximate properties were listed as having environmental concerns, which could have an adverse
impact on the subject property. The following provides a summary of the databases reviewed.
4.1 Federal National Priorities List (NPL)
A search of the Environmental Protection Agency’s NPL database shows no current NPL sites
within a mile radius of the subject property (Ref 8). The subject property is not an NPL site.
The database also shows no delisted NPL sites within a half mile radius of the property.
4.2 Federal CERCLIS List
The EPA database for Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) Information Systems (CERCLIS) was searched for active and archived CERCLIS
sites on and near the subject property (Ref. 9). The ASTM’s recommended search radius for
the subject property for both active and archived CERCLIS sites is ½ mile. No CERCLIS sites
were found within a ½ mile radius of the site. The property is not listed as an active CERCLIS
site.
The subject property is also not listed in the archived CERCLIS site list. There are no archived
sites within a ½ mile of the subject property.
4.3 Federal RCRA CORRACTs List
A database search of RCRA CORRACTs List showed no RCRA locations on the property or
within a mile of the site.
4.4 Federal RCRA non-CORRACTS TSD List
A database search of RCRA CORRACTs List showed no RCRA non-CORRACTS locations on the
property or within a half mile of the site.
4.5 Federal RCRA Generators List
A database search of RCRA CORRACTs List showed no generator locations on the property or
on any adjacent properties.
Phase I TBA 15 Haskell Armory
Haskell, Oklahoma
4.6 Federal ERNS List
Emergency Response Notification system (ERNS) maintained by the National Response
Center was searched for any hazardous substance releases or spills within the subject
property (Ref. 11). ASTM requires a minimum search distance of property only when
identifying ERNS cases. No ERNS sites were reported within the property or the adjoining
properties.
4.7 Federal Institutional Control/Engineering Control Registries
There were no institutional controls reported by the Oklahoma Military Department. Duane
Points did not know of any institutional controls that had been put in place.
4.8 State-Equivalent NPL
The DEQ does not have a State-equivalent NPL database. Oklahoma does not have a State
Superfund law to establish a State-equivalent NPL database.
4.9 State-Equivalent CERCLIS
The DEQ does not have a State-equivalent CERCLIS database.
4.10 State Landfill and / or Solid Waste Disposal Sites
An online search of landfill resources showed no landfills on the property or within a
half mile of the site.
4.11 State Leaking UST List
The Oklahoma Corporation Commission UST Notification Database was searched to
locate any known leaking underground storage tanks (LUSTs) sites located within the
ASTM’s minimum search distance of a ½ mile of the subject property. No LUST sites
were found within the ½ mile radius.
4.12 State Registered UST Sites
The Oklahoma Corporation Commission UST Notification Database was searched to
locate registered underground storage tanks (UST) located within the ASTM’s minimum
search distance of the subject property and its adjoining properties. No registered USTs
were found on the adjoining properties. The subject property formerly contained a
1,000 gallon gasoline UST on the property. The UST was removed October 22, 1998 from
the subject property (Appendix L). No leaks were reported to the OCC for the UST.
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Haskell, Oklahoma
Following the tank removal the soil was sampled from seven feet below the surface five
feet from the south wall (down gradient) of the tank and the center of the tank pit. Soil
samples collected below the fuel island were below the OCC action levels for TPH and
BTEX. The site was closed within prescribed standards by OCC on November 10, 1998.
This is considered a historic REC due to the potential soil and groundwater impacts. For
a map of UST sites near the subject property, see Appendix B.
4.13 State Institutional Control/Engineering Control Registries
A database search of the ODEQ’s Brownfields webpage showed no institutional controls
or engineering controls on the property or within a half mile of the site. Duane Points,
city administrator for the City of Haskell, did not know of any controls on site.
4.14 State Voluntary Cleanup Sites
A database search of Voluntary Clean Up sites showed no VC locations on the property
or within a half mile of the site.
4.15 State Brownfield Sites
An online search of Brownfield resources showed no Brownfield sites on the property or
within a half mile of the site.
4.16 Oil and Gas Records
The subject property is located in the NW ¼ SE ¼ SE ¼ of Section 26 T16N R15E. The
DEQ performed a search of oil and gas records from the Oklahoma Corporation
Commission’s (OCC) oil and gas records database. The subject property is in an area
where there is a history of oil and gas development. Oil and gas records were searched
to record the known history of well development on and near this site. A search area
consisted of the property as described from the legal location above and the quarter,
quarter, quarter sections directly above and up gradient of the site. No well records
were found on site or in adjacent or up gradient areas. Wells near the area are located
in Appendix H.
5.0 Site Reconnaissance and Interviews
5.1 Methodology and Limiting Conditions
A site reconnaissance of the subject property located at 1600 Haskell Blvd. was performed
on April 22, 2011. Rachel Francks, John Reid and Savannah Smith of the DEQ met the
caretaker of the property, Duane Points (City Administrator, Haskell) at the property. Mr.
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Haskell, Oklahoma
Points introduced Francks, Reid, and Smith to the site and answered questions to the best of
his knowledge on the site. Mr. Points lead DEQ inside the building and gave his knowledge
about what the building was used for and what kinds of activities occurred there in the past.
All areas of the building were observed noting any environmental conditions that might
need additional investigation. The entire outside area of the subject property was walked
through for observations that might need additional investigation as well.
5.2 General Site conditions
The former Haskell Armory Property is composed of a brick building of approximately
14,550 square feet that was built in 1982 and has an IFR. The building is currently occupied
by the City of Haskell. The property surrounding the building consists of a grassy residential
area to the north; a church and residential area to the west; a small gravel parking area, and
autobody shop to the south; and a gravel parking lot and grassy area to the east. The
subject property is outside of town and paved streets are located to the west of the subject
property. The following are general site conditions that were evaluated on the property and
adjacent properties.
5.2.1 Aboveground Storage Tanks (ASTs)
There were no ASTs at the site, nor was there any indication that there had
been at any point.
5.2.2 Landfills and/or Dumping
There was no indication that any part of the property had been used as a landfill
at any point.
5.2.3 Impoundments
There was no standing water on the property. There is a ditch between the
road and the parking lot for the armory. There was no water in it at the time of
the site visit.
5.2.4 Monitoring Wells
There were no wells noted during the site visit. The OWRB data viewer has no
record of wells being located on the property.
5.2.5 Disturbed and Stained Soils
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Haskell, Oklahoma
There were no disturbed soils during the site visit. The vegetation around the
armory appeared to be in good condition and did not appear distressed. There
were no stained soils visible, but Duane Points mentioned that the parking lot
around the armory had recently had new gravel laid on it.
5.2.6 Seeps
No seeps of any kind were observed at the subject property.
5.2.7 Chemical Spills
No evidence of possible chemical spills was observed on the subject property.
5.2.8 Farm Waste
No farm waste was observed at the subject property.
5.2.9 Known Pesticide Misapplication
No known pesticide misapplications were detected during the site visit or during
the supportive research.
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site
Rainwater runs off the east side of the subject property. DEQ observed pooled
water in the concrete floor of the Drill Hall that may be due to rain events and
the disrepair of the roof. No potential pollutants were observed on the
neighbor’s properties that may affect the armory.
5.2.11 Petroleum Products and Oil and Natural Gas Exploration
No petroleum products or oil and natural gas exploration was observed during
the site visit.
5.2.12 Asbestos
Since many of the State armories were built before the 1970s, there is a high
potential of finding asbestos containing material (ACM) in the armory buildings.
The U.S. began banning the use of asbestos in most building products in the
1970s due to studies confirming the harmful health effects caused by exposure
to airborne asbestos. ACM may be found in the insulation wrapping of the
heating pipes and/or heaters, roofing materials, ceiling tiles, window putty,
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Haskell, Oklahoma
mastic, and floor tiles. Floor tiles that are 9”x9” have been found to regularly
contain asbestos.
The building may contain ACM; however, DEQ’s contractor is in the process of
sampling and analyzing asbestos, lead dust and conducting a lead-based paint
assessment in the armory. 12”x12” inch tiles were found in most of the
classrooms and hallways. The some of the tiles appear to have been damaged
and removed. Black mastic is visible where tiles are missing. The window seal
putty throughout the facility may contain asbestos. This material is usually
suspect for ACM. Thermal system insulation was observed and could be present
on some of the utility pipes in the building. There are acoustic tiles in the IFR
and panels below the windows that may also contain asbestos.
5.2.13 Lead
The building most likely contains lead dust. Surveys for lead-based paint and
lead dust throughout the building will be conducted by a contractor for the
DEQ. The results have not been received by the DEQ. However, there is a
potential for lead based paint and lead dust in the building. There is an IFR in
this building, so any lead dust is most likely due to activities from the range or
gun cleaning activities. Samples collected by DEQ along downspouts from the
gutters attached to the roof near the IFR vent show lead levels are below
screening levels.
5.2.14 Transformers/PCB Equipment
There were no transformers observed around the subject property.
5.3 External Observations
The exterior of the building is in fair condition. Some of the holes that were noted inside
were visible from the outside. These are just below the roof line. There is some water
damage to panels that are below the windows (See Appendix E).
5.4 Internal Observations
The building is currently unoccupied and was last used by the Oklahoma Army National
Guard to support the military mission. The one story building was constructed from brick in
1982. Before construction of the armory building, the land was owned by the City of Haskell
and was vacant land. During the site visit on April 22, 2011, holes were observed in the roof.
There was no standing water in the building at that time, though Duane Points said that
some areas had some and there were signs of water damage to insulation and on the floor.
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No chemicals or military equipment were observed on site. Photographs of the internal
view of the site can be found in Appendix F.
5.5 Interviews
Duane Points was listed as the point of contact for the armory. He has limited knowledge of
the site and was listed as the point of contact because of his position as city administrator of
the City of Haskell. Therefore interviews were not utilized in determining the operational
history of the site.
6.0 Findings
Summarized below are the major findings from this Targeted Brownfield Assessment and DEQ’s
recommendations. The major findings of the highest environmental concern are presented first.
• The former Haskell Armory was built in 1982. The land for the building was deeded by the City
of Haskell to the Oklahoma Military for the State of Oklahoma, for benefit of the Oklahoma
National Guard. The armory is currently owned by the City of Haskell and will be conveyed to
the city prior to cleanup activities. A Memorandum of Agreement (MOA) will be set in place
between the OMD and the DEQ. Once cleanup activities have occurred, a notice of remediation
and easement will be filed in the Muskogee County Courthouse.
• The building is probably contaminated with lead dust, lead-based paint, and asbestos. The
Oklahoma Department of Environmental Quality Site Cleanup Assistance Program plans to
remediate any lead and asbestos contamination on the subject property and properly dispose of
all associated waste. The possible lead and asbestos contamination in the building may
constitute a recognized environmental condition (REC).
• OCC records show the property formerly contained a 1,000 gallon underground storage tank
(UST) that was removed October 22, 1998. Soil samples collected below the fuel island were
below the OCC action levels and the tank itself was in good condition. The former UST is
considered a HREC.
• Adjoining properties consist of residential houses, an autobody shop and undeveloped land.
Historical aerial photographs show undeveloped land surrounding the subject property.
Autobody shops are often RCRA generators, but the autobody shop next to the armory wasn’t
listed on the RCRA generator list.
• No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
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or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. The subject property is on the
DEQ Site Cleanup Assistance Program (SCAP) list for cleanup of lead and asbestos
contamination. There were seven RCRA generators listed within one mile of the subject
property, and two archived Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) site listings.
• No underground storage tank sites were found within a ½ mile radius of the subject property.
• Oil and gas development was found in the OCC oil and gas records for the quarter, quarter,
quarter sections directly above and upgradient of the site. All wells drilled in the ½ mile area of
the site were dry. No development occurred at the wells near the site. There is no record of oil
and gas development onsite.
• No transformers were noted at the site. Fluorescent lighting ballasts are located throughout the
building. The lighting ballasts are all in good condition. The lighting ballasts may be a source of
mercury.
7.0 Opinion and Recommendations
Due to the past use of the property and contamination found on the subject property, the
environmental professionals working on this site believe that cleanup of lead and asbestos will be
necessary.
8.0 Data Gaps
No tribal information was obtained for this assessment. No tax records, city directories, or zoning
records were reviewed for this report. No interviews of the operational history of the building were
conducted. However, this did not affect the ability of the DEQ to make a recommendation on the
subject property
9.0 Conclusions
DEQ has performed a Phase I Environmental Site Assessment in conformance with the scope and
limitations of ASTM Practice E 1527-05 of the former Haskell armory located at 1600 Haskell Blvd.
Haskell, Oklahoma. Any exceptions to, or deletions from, this standard are described in Section
[10.0] of this report. Recognized environmental conditions on this property include lead dust, lead-based
paint, and asbestos contamination throughout the building. The former UST is also
considered and HREC.
The information provided in this assessment is to assist the City of Haskell in its revitalization
planning as well as meet the All Appropriate Inquiry requirement of the landowner liability
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protections under the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA, better known as Superfund – Ref. 3), as provided in the Small Business Relief and
Brownfields Revitalization Act of 2002 (Public Law 107-118, Subtitle B – Ref. 2).
10.0 Additional Services
In addition to this Phase I Targeted Brownfield Assessment, DEQ will provide sampling analysis
of potential asbestos, lead-based paint, and lead dust sources including the remediation of the
building. Soil sampling was conducted outside of the armory to check for lead contamination in
the soil.
11.0 Deviations
The following deviations from ASTM Practice E 1527-05 occur in this Phase I Targeted
Brownfield Assessment. No tax records, city directories, or zoning records were reviewed for
this report. Soil sampling was conducted only in areas considered likely to be contaminated by
lead from the IFR vent.
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Haskell, Oklahoma
12.0 References
1. Bridgewater, J. Oklahoma Department of Transportation, Rail Programs Division. (2011). Oklahoma freight
& passenger rail plan Oklahoma City: Retrieved from http://www.okladot.state.ok.us/rail/rail-plan/
pdfs/open_house_boards.pdf
2. U.S. Environmental Protection Agency. (2008). Oklahoma Brownfields Assistance Agreement (No
#RP96681001-0). Unpublished Document. State of Oklahoma: Oklahoma City, Oklahoma.
3. U.S. Environmental Protection Agency. (1980). Comprehensive Environmental Response, Compensation,
and Liability Act. (Public Law 96-510). Washington, DC: U.S. Government Printing Office.
4. U.S. Environmental Protection Agency. (2002). Small Business Liability Relief and Brownfields Revitalization
Act. (Public Law 107-118, Subtitle B). Washington, DC: U.S. Government Printing Office
5. ASTM International. (2005). Water and Environmental Technology: Phase I Environmental Site Assessment
E 1527 – 05. Baltimore, Maryland.
6. Rachel Francks, Oklahoma Department of Environmental Quality, interview notes with former Haskell City
Administrator Duane Points, April 22, 2011, Haskell Armory.
7. EPA NPL list: http://www.epa.gov/superfund/sites/npl/status.htm.
8. Deleted NPL sites database: http://www.epa.gov/superfund/sites/query/queryhtm/npldel.htm
9. CERCLIS current and archived sites: http://cfpub.epa.gov/supercpad/cursites/srchsites.cfm.
10. RCRA database: http://www.epa.gov/enviro/html/rcris/rcris_query_java.html.
11. Emergency Response Notification System: http://www.nrc.uscg.mil/foia.html.
12. State Landfill site list: http://www.deq.state.ok.us/LpDnew/swindex.html.
13. Oklahoma Department of Environmental Quality online data viewer. www.deq.state.ok.us
14. Federal Emergency Management Association (FEMA). https://msc.fema.gov.
15. RCRA NOTIFIERS sorted by county and then city:
http://www.deq.state.ok.us/LPDnew/HW/Notifiers/notifiersbycountycity.pdf.
16. United States Department of Agriculture, Natural Resources Conservation Service. (n.d.). Web soil survey
Retrieved from http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx
17. “OWRB Custom Map Viewer." Data Driven Map Viewers. Web. 14 Mar 2011.
http://www.owrb.ok.gov/maps/server/wims.php.
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13.0 Appendices
A. Oklahoma Corporation Commission Oil and Gas Records
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B. Oklahoma Corporation Commission UST records
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C. Limited Environmental Baseline Assessment. Oklahoma Army National Guard Highway 64
North, Haskell, OK. Oklahoma Military Department Environmental Office.
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D. Caldwell Environmental Work Plan for Remediation of Lead Contamination, Oklahoma Army
National Guard, Haskell, OK.
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E. Photographs from site visit April 22, 2011
Figure 1 Classroom ceiling damaged
Figure 2 Classroom mastic exposed
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Figure 3 Classroom painting
Figure 4 Drill Floor
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Figure 5 Drill Floor Ceiling Damage
Figure 6 Drill Floor Wall Paint Peeling
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Figure 7 Firing Range Acoustic Tiles
Figure 8 Firing range ceiling damage
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Figure 9 Firing range ceiling vent
Figure 10 Firing range close up acoustic tiles
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Figure 11 Firing range sand pit
Figure 12 Firing range backstop
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Figure 13 front hall damaged wall tile
Figure 14 front hall exposed mastic
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Figure 15 kitchen grease trap
Figure 16 kitchen pipes thermal insulation
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Figure 17 kitchen stove vent
Figure 18 kitchen thermal insulation
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Figure 19 locker room breaker box
Figure 20 locker room floor
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Figure 21 machine room ceiling
Figure 22 machine room ceiling damage
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Figure 23 machine room electronics
Figure 24 machine room pipe insulation
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Figure 25 machine room pipe insulation 2
Figure 26 machine room wall damage
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Figure 27 maintenance room pipe insulation 1
Figure 28 maintenance room pipe insulation 2
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Figure 29 maintenance room wall damage
Figure 30 to the south autobody shop neighbor
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Figure 31 outside damage in roof
Figure 32 outside damaged panel beneath window
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Figure 33 outside example sample location
Figure 34 outside firing range door
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Figure 35 outside firing range vent
Figure 36 outside front of building
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Figure 37 outside firing range vent from front
Figure 38 outside drill floor door
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Figure 39 outside gutters
Figure 40 outside rear parking lot
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Figure 41 outside sampling area
Figure 42 outside service bay
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Figure 43 outside shed
Figure 44 outside wall
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Figure 45 pantry ceiling damage
Figure 46 pantry damaged wall tile
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Figure 47 scullery grease trap
Figure 48 shower room 1
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Figure 49 shower room 2
Figure 50 shower room 3
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Figure 51 shower room floor tile
Figure 52 vault room ceiling damage
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Figure 53 vault room floor damage
Figure 54 vault room wall damage 1
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Figure 55 vault room wall damage 2
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F. FEMA Flood Zone Map
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Haskell, Oklahoma
G. Memorandum of Agreement between Oklahoma Department of Environmental Quality and
the Town of Haskell
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H. Deeds
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I. Qualifications of Environmental professionals
1. Heather Mallory - Heather Mallory holds a Bachelors and Masters Degree in
Environmental Science from the University of Oklahoma. Mrs. Mallory has nine years
experience in environmental sampling and remediation. She is an Environmental Programs
Specialist with the Land Protection Division of the Oklahoma Department of Environmental
Quality. Her responsibilities include: project management of various Voluntary Cleanup
sites across the state, NEPA coordinator for the Tar Creek voluntary buyout of residents,
conducting and reviewing Targeted Brownfield Assessments, serving on agency-wide GIS
policy making committee, and training DEQ Land Protection Division staff on GPS receivers.
2. Rachel Francks – Rachel Francks holds a Bachelors Degree in Geography from the
University of Oklahoma. Ms. Francks has 6 months of experience in environmental sampling
and remediation. She is an Environmental Programs Specialist with the Land Protection
Division of the Oklahoma Department of Environmental Quality. Her responsibilities include:
project management of various Brownfields and Voluntary Cleanup site across the state,
QAPP reviewer, and conducting and reviewing Targeted Brownfield Assessments.
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J. USGS Topographical Map Muskogee County
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K. Aerial Photographs
Figure 56 Haskell Armory 1941 Aerial Photo
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Figure 57 Haskell Armory 1995 Google Earth Image
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Figure 58 Haskell Armory 2003 Google Earth Image
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Figure 59 Haskell Armory 2010 Google Earth Image
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Background and Disclaimer
The purpose of an environmental site assessment is to identify actual or potential “recognized
environmental conditions” that may result in liability or land use restrictions. The ASTM Phase I
Environmental Site Assessment E 1527 – 05 is the minimum standard for environmental due
diligence in the commercial real estate industry and meets the standard for All Appropriate
Inquiry under the Small Business Liability Relief and Brownfields Revitalization Act of 2002. A
diligent effort in accordance with generally accepted good commercial and customary standards
and practices was undertaken to identify the “recognized environmental conditions” that might
affect the redevelopment project. However, the identification of old hazardous waste sites is an
evolving process; therefore, DEQ cannot state with absolute certainty that no other potential
hazardous waste sites are located in the area. In no event shall the DEQ or its employees be
liable for any damages, injury, loss, cost or expense whatsoever arising in connection with the
use or reliance on the information contained in this report, except as otherwise provided by law.