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1
This Proposed Plan, part of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA) process (Figure 1), identifies
the preferred alternative for remediating the
contamination associated with the Tulsa Fuel and
Manufacturing Superfund Site (Site), Collinsville,
Oklahoma, and provides the rationale for this
preference. In addition, this Plan includes
summaries of other cleanup alternatives evaluated
for use at this Site. This document is issued by the
Oklahoma Department of Environmental Quality
(DEQ), the lead agency for Site activities, in
consultation with the United States Environmental
Protection Agency, Region VI (USEPA). The final
remedy will be selected for the Site after reviewing
and considering all information submitted during the
30-day public comment period on the Proposed Plan
(see right). Based on new information or public
comments, DEQ, in conjunction with the USEPA,
may modify the preferred alternative or select other
response actions. Therefore, the public is
encouraged to review and comment on the
alternatives presented in this Proposed Plan.
The DEQ is issuing this Proposed Plan as part of its
public participation responsibilities under Section
300.430(f)(2) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) and
the CERCLA of 1980 §117(a). This Proposed Plan
summarizes information that can be found in
greater detail in the Remedial Investigation (RI),
and the Feasibility Study (FS) Reports and other
documents contained in the Administrative Record
Dates to Remember:
Public Comment Period: July 1, 2008 to July
30, 2008
The DEQ will accept written comments on the
Proposed Plan during the public comment
period.
Public Meeting: July 24, 2008
The DEQ will hold a public meeting to explain
the Proposed Plan and all of the alternatives
presented in the Feasibility Study. Oral and
written comments will also be accepted at the
meeting. The meeting will be held at Collinsville
City Hall, 106 North 12th street, Collinsville,
Oklahoma at 6:00 to 7:30.
The Administrative Record including
copies of the RI and FS reports are
available for viewing at:
Collinsville Public Library
1223 W. Main, Collinsville, Oklahoma
918-596-2840
Hours: 12 pm to 8 pm Monday thru Thursday
12 pm to 5 pm Friday
10 am to 5 pm Saturday
Closed on Sunday
Proposed Plan
Tulsa Fuel and Manufacturing Superfund Site
Collinsville, Oklahoma
Oklahoma Department of Environmental Quality Announces Proposed Plan
Figure 1 - The CERCLA Process
2
Figure 2 - Site Location
for this site. The DEQ encourages the public to
review these documents to gain a more complete
understanding of the Site and investigation activities
that have been conducted at the Site.
SUMMARY OF
PERFERRED REMEDIAL
ALTERNATIVES
Soil and Waste Materials: On-Site Soil and Waste
Materials Areas
Consolidation and cap, of approximately 164,000
cubic yards of material
Estimated Capital Cost – $5,293,802
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
On-Site Fixation or Stabilization and On-Site
Disposal, of approximately 33,000 cubic yards of
material
Estimated Capital Cost - $1,183,928
Soil, Sediment, and Waste Materials: Off-Site
Locations
Excavation, Stabilization, and Disposal at TFM
Off-Site Estimated Total Capital Cost - $331,213
SITE HISTORY
The Tulsa Fuel and Manufacturing Superfund Site,
located in Collinsville, Oklahoma is an abandoned
zinc smelter and lead roaster that operated from
1914 through 1925 See Figure 2 (above). The
Tulsa Fuel and Manufacturing smelting operation
utilized nine furnaces, which were believed to be
fueled by nearby natural gas wells. Other main
structures of the smelter included a mechanical kiln
building, a condenser room, and a laboratory. A 2-
million gallon capacity surface reservoir was used in
conjunction with the condenser room during
smelting operations. Large amounts of ore were
stored on the Site in the area northeast of the
waste piles. The Site was abandoned in the 1920s.
The majority of the structures have been
demolished, but several foundations and building
footings remain.
A residence, which was occupied from 1935 through
February 2002, was located on the Site near the
former office building (paymaster hut). The on-Site
residence was destroyed by a fire and is currently
unoccupied. The residence has a water well that
was used in the past for drinking water but is no
longer in use. No other residential structures are
located on the site; however, a garage and a few
storage sheds remain in place adjacent to the
former residence.
After being identified in 1992, a Preliminary
Assessment (PA) of the Site was performed under
the direction of the USEPA, followed by a focused
Site Inspection (SI) in September 1994. A search
for potentially responsible parties (PRPs) was
conducted from August through September 1998.
The Hazard Ranking System (HRS) Documentation
Record was completed by USEPA, and the Site was
3
Figure 3 – Site Layout
proposed to the Superfund
National Priorities List (NPL)
in September 1998. Final
listing of the Site to the NPL
occurred on January 19,
1999. In May of 1999, the
USEPA completed a
Removal Assessment Report
for the Site. The
assessment found that
there was approximately
30,000 cubic yards of waste
materials present.
The Agency for Toxic
Substances and Disease
Registry (ATSDR) finalized
the Public Health
Assessment for the Site in
July 2000. A Special Notice
Letter, which notified the
PRP of potential liability for
Site response activity, was
issued to the identified PRP
in July 2000. The DEQ
assumed the lead role for the RI/FS, and USEPA
assumed the role of support agency after the PRP
declined to conduct the RI/FS. Access to the
property was granted in 2003, and USEPA partially
fenced the Site in 2004 under emergency response
authority to restrict public access.
From 2005 through 2006, DEQ conducted an RI/FS.
The RI was conducted from August 2005 through
October 2006 and identified the types, quantities,
and locations of contaminants. A summary of the
investigation was presented in the RI report in
August 2007 and at a public meeting held October
2007. The FS Report, which summarized and
evaluated remedial alternatives, was also finalized in
October 2007. Additionally, between November
2007 and January 2008, DEQ and EPA conducted a
supplemental RI to evaluate potential off-site
residential properties.
SITE CHARACTERISTICS
The approximately 61-acre Site is located 1 1/3
miles south of downtown Collinsville, Oklahoma.
The Site is bounded by “Old” U.S. Highway 169 and
the Atchison Topeka Santa Fe railroad tracks to the
east, a flooded strip mine pit (Strip Mine Pit) that
comprises the boundary of a former coal mining
operation to the south, and agricultural lots to the
north and west. Additionally, property owned by
the Faith Assembly Church bounds the Site to the
north. The Collinsville Smelter, which is another
former zinc smelter, is located approximately 1/4
mile to the east-northeast of the Site on 220 acres
of property formerly owned by the Bartlesville Zinc
Company. Currently the Site is unused, but due to
residential interest in the area it is reasonable that
future land use for the site may be zoned as
residential.
The majority of the facility structures have been
demolished. The northern portion of the Site (north
of the access road/driveway) is vegetated with
grasses. A large area located in the southern
portion of the Site (referred to as the “Waste Area”)
is covered with smelter waste consisting of broken
retorts and condensers, slag, building debris, ash,
bricks, and other materials from the former smelting
operations. The Waste Area covers approximately
25 acres and extends to the southern border of the
Site where it terminates at the Strip Mine Pit.
Waste materials in the Waste Area vary in thickness
from 2 feet to greater than 6 feet. Portions of the
Waste Area have sloughed into the Strip Mine Pit
(Figure 3).
4
Figure 4 - Contaminant Location and Movement
Topography of the Site is relatively flat, with a slight
slope downward to the southeast. Site drainage
and run-off are uncontrolled. The Strip Mine Pit
receives surface water runoff from the Site. In
addition, the Site is drained by an intermittent
stream that flows west to east and bisects the Site
(referred to as the Mid-Site Ravine). The Mid-Site
Ravine discharges to a low area located along the
east boundary of the Site (referred to as the Eastern
Wetlands). Surface water from the Strip Mine Pit
also discharges to the Eastern Wetlands. The
Eastern Wetlands drains to the east through a
culvert underneath the railroad on the eastern
border of the Site. Surface water exiting the Site
flows to the north and east in an intermittent
stream a distance of approximately 3/4 mile before
draining into Blackjack Creek. Three intermittent
ponds (Ponds 1, 2, and 3), which are thought to be
remnants of the 2-million gallon reservoir, are
located north of the former smelter operations area.
In addition, two smaller ephemeral ponds (Ponds 4
and 5) are located on the Site.
Soils at the Site consist primarily of silt, clay, silty
loam, and shale sediments. The soil layer is
relatively thin across the site, ranging in depth from
7.2 to 12.5 feet in thickness. The soil overlies initial
bedrock which was observed to consist of shale with
a few instances of sandstone and limestone.
No major bedrock or alluvial aquifers underlie the
Site. The upper bedrock aquifer yields small
amounts of fair to poor quality groundwater, and
has been designated as a minor use general basin.
The occurrence of groundwater beneath the Site is
limited; however, it does appear to be continuous
across the Site. Available data indicate that
groundwater flows in a south/southeasterly
direction. Groundwater depth fluctuates, dependant
upon precipitation. Depth to groundwater at the
Site is variable and ranged from less than 4 feet
below the ground surface to more than 15 feet
below the ground surface.
The major findings of the RI are listed below.
Figure 4 is a general model of the Site.
• Media impacted at the Site include surface and
subsurface soils, surface water, sediment,
groundwater, and vegetation. Sample results
were compared to background values and to
applicable screening levels. Region 6 screening
levels are values which were used to identify
areas that require further investigation.
• Review of the Site indicated a clear division into
two areas: 1) areas of the TFM site where waste
materials were not visually observed during
sampling (i.e., on-site non-waste areas); and, 2)
areas of the Site where waste materials were
visually observed during sampling (i.e., on-site
waste areas).
• One or more metals were detected at levels that
exceeded background and/or screening levels in
most of the on-site soils. The highest
concentrations of metals were observed in the
southern portion of the Site and were associated
with the former smelter operations area.
5
• For the majority of the off-site surface soil,
surface water, sediment, and/or vegetation
samples, one or more metals were detected at
levels that exceeded background and/or
screening levels.
• Groundwater samples were collected from nine
temporary piezometers and seven monitoring
wells at the Site. Arsenic, cadmium, lead, and
zinc were detected at levels that exceeded
background and/or screening levels.
• Surface water and sediment samples were
collected from on- and off-site surface water
drainages and/or impoundments. In the surface
water samples, cadmium, lead, and zinc were
detected at levels exceeding background and/or
screening levels. Sediment samples from the
on- and off-site surface water drainages and/or
impoundments should arsenic, cadmium, lead,
and zinc were detected at levels exceeding
background and/or screening levels.
• Samples collected from on-site blackberry
bushes contained higher concentrations of
metals than those collected from off-site bushes.
Washed berries and leaves had lower
concentrations of metals than unwashed samples.
• The results of the air samples collected from the
Site were similar to background levels
suggesting that the Site is not currently a source
of airborne contamination to off-site locations.
• Leaching from surface soil to subsurface soil is a
potential contaminant transport mechanism.
Storm water run-off to surface water bodies is
also a potential migration path. Leaching from
contaminated soil to groundwater is possible but
does not appear to be a major contaminant
pathway. Wind blown movement of dust
generated from contaminated surface soils is
another possible migration pathway.
• Some off-site properties are impacted. However,
at this time it is not possible to attribute the
material to TFM or the adjacent smelter.
The principal and low level threat wastes for the
Site consist of smelter operations debris, including:
broken retorts, condensers, ash, and slag. These
are considered “principal and low level threat
wastes” because the contaminants of concern are
found at concentrations that may pose a significant
risk and are considered to be source material.
What is a “Principle and Low Level
Threat Waste?”
Principal threat wastes are those source materials
considered to be highly toxic or highly mobile that
generally cannot be reliably contained, or would
present a significant risk to public health or the
environment should exposure occur. Low level
threat wastes are source materials that generally
can be reliably contained and would present only a
low risk in the event of a release. The decision to
treat low level threat wastes is made on a site-specific
basis through a detailed analysis of
remedial alternatives using the nine remedy
selection criteria specified in the National Oil
and Hazardous Substances
Pollution Contingency Plan (NCP) and
summarized in Table 3. This analysis provides the
basis for making a statutory finding that the
selected remedy uses a proven treatment
technology as a principal element.
The NCP establishes an expectation that EPA
will use treatment to address the principal threats
posed by a site wherever practicable, and
engineering controls such as containment for
wastes that pose a relatively low, long-term
threat or where treatment is impracticable (NCP
Section 300.430(a)(1)(iii)(A)). The “principal threat”
concept is applied to the characterization of “source
materials” at a Superfund site. Source material is
any material that includes or contains hazardous
substances, pollutants or contaminants that act as a
reservoir for migration of contamination to ground
water, surface water, air, or acts as a source for
direct exposure. Based on high levels of arsenic,
cadmium, and lead detected in soil, sediment, and
surface water samples, materials such as broken
retorts and condensers, slag, and other smelter-related
materials represent a primary source
material at the Site.
Although the contaminated soils present at the Site
represent a source material, they are not
characterized as a “principal threat waste”
because the resulting soil contamination associated
with this smelter materials can be reliably
contained. However, because current and future
public exposure to heavy metals present in soils at
the Site exceeds EPA’s risk management criteria,
treatment alternatives will be evaluated.
6
What is Risk and How is it Calculated?
A CERCLA baseline human health risk assessment estimates
the "baseline risk." This is an estimate of the likelihood of
health problems occurring if no cleanup action were taken
at a site. To estimate the baseline risk at a CERCLA site,
EPA identifies a four-step process:
Step 1: Identify Chemicals of Concern
Step 2: Estimate Exposure
Step 3: Assess Potential Health Effects
Step 4: Characterize Site Risk
In Step 1, the risk assessor compiles all the chemical data
for a site to identify what chemicals were detected in each
medium (i.e. soil and groundwater). Chemicals that are
detected frequently at high concentrations, or are
considered highly toxic, are considered “chemicals of
concern” and are evaluated in the risk assessment
In Step 2, the risk assessor considers the different ways
that people might be exposed to the contaminants
identified in Step 1, the concentrations that people might
be exposed to, and the potential frequency and duration of
exposure. Using this information, the risk assessor
calculates a "reasonable maximum exposure" (RME)
scenario, which portrays the highest level of human
exposure that could reasonably be expected to occur.
In Step 3, the risk assessor compiles toxicity information on
each chemical, including numeric values for assessing
cancer and noncancer adverse health affects. The EPA
identifies two types of risk: cancer risk and noncancer risk.
The likelihood of any kind of cancer resulting from a
CERCLA site is generally expressed as an upper bound
probability; for example, a "1 in 10,000 chance.” In other
words, for every 10,000 people that could be exposed, one
extra cancer may occur as a result of exposure to site
contaminants. An extra cancer case means that one more
person could get cancer than would normally be expected
to from all other causes. For noncancer health effects, the
risk assessor calculates a "hazard index." The key concept
here is that a "threshold level" (measured usually as a
hazard index of less than 1) exists below which noncancer
health effects are no longer predicted.
In Step 4, the risk assessor uses the exposure information
from Step 2 and toxicity information form Step 3 to
calculate potential cancer and noncancer health risks. The
results are compared to EPA acceptable levels of risk to
determine whether site conditions could potentially cause
health problems for populations at or near the CERCLA site.
The proposed remedial action would address
the principal and low level threat at the Site.
SCOPE AND ROLE OF THE ACTION
This action, referred to as the Tulsa Fuel and
Manufacturing Remedial Action, will be the final
action for the Site. The Remedial Action Objectives
(RAOs) for the Site are designed to prevent current
and future exposure to contaminated media.
SUMMARY OF SITE RISKS
As part of the RI/FS, the DEQ conducted a baseline
human health risk assessment (BHHRA) to
determine the possible effects of contaminants on
human health and the environment. The Site is
currently vacant, and the future land use has not
been decided; therefore, the site was evaluated as
though recreational or residential development
could occur in the future.
Human Health Risk
The human health risk assessment evaluated the
potential for on- and off-site residential, industrial,
and recreational populations to experience adverse
health effects as a result of exposure to
contaminants in soil, groundwater, surface water,
sediment, and air. It was assumed that people
could be exposed to site-related contaminants
through direct contact, accidental ingestion,
ingestion of blackberries or fish, and inhalation.
The populations characterized for the risk
assessment included adult and child residents,
trespassers, outdoor commercial/industrial workers,
construction/utility workers, and recreationists.
Chemicals of potential concern (COPCs) were
identified for each medium based upon comparison
to published screening levels from the USEPA.
Exposure to each COPC was evaluated for potential
noncancer health effects, and for those chemicals
that are potential carcinogens, the potential for
causing cancer.
Risk of noncancer health effects is determined by
calculating hazard indices. The key concept here is
that a "threshold level" exists below which
noncancer health effects are no longer predicted.
The USEPA level of concern for noncancer risk is a
hazard index greater than one. The following
populations had a calculated noncancer hazard
index greater than one:
7
What are the “Chemicals of Concern”?
The DEQ and EPA have identified 3 contaminants
in soil, surface water, and sediment that pose the
greatest potential risk to human health at this Site.
The occurrence of the adverse effects described
below depends on the chemical concentration and
level of exposure.
Metals are chemical elements that usually have
luster, conduct heat energy and electricity, and
bend without breaking. Metals found on the Site
are by-products of the zinc smelting and lead
roasting operations and consist of such things as
slag, retorts, and sands.
Arsenic: Arsenic is a naturally occurring element.
Arsenic compounds are used as pesticides and for
wood preservation. Arsenic is a Chemical of
Concern (COC) for the soil and sediment on- and
off-Site. The detected concentrations for arsenic
ranged from nondetect to 1,170 mg/kg for on-site
soil and from nondetect to 588 mg/kg for on-site
sediment. Off-site, the detected concentrations of
arsenic in soil ranged from nondetect to 538
mg/kg, and from nondetect to 341 mg/kg for
sediment
Cadmium: Cadmium is a naturally occurring
element. Cadmium compounds are used in the
production of batteries, plastics, and metal
coatings. Cadmium is a COC for the soil, sediment,
and surface water on- and off-site. The detected
concentrations for cadmium ranged from
nondetect to 1,620 mg/kg for on-site soil, from
nondetect to 1,400 mg/kg for on-site sediment,
and from nondetect to 184 μg/L for on-site surface
water. Off-site, the detected concentrations of
cadmium in soil ranged from nondetect to 193
mg/kg, from nondetect to 987 mg/kg for sediment,
and from nondetect to 810 μg/L for surface water.
Lead: Lead is a naturally occurring element. Lead
has many different uses, including the production
of batteries, ammunition, and metal products.
Lead is a COC for the soil and sediment on- and
off-Site. The detected concentrations for lead
ranged from nondetect to 71,700 mg/kg for on-site
soil and from 180 mg/kg to 8,150 mg/kg for on-site
sediment. Off-site, the detected
concentrations of lead in soil ranged from
nondetect to 15,900 mg/kg and from 119 mg/kg to
5,080 mg/kg for sediment.
• Future Adult and Child Residents – On-Site
Waste and Non-Waste Areas
• Future Outdoor Commercial/Industrial
Worker – On-Site Waste Area
• Future Construction/Utility Worker – On-Site
Waste Area
• Future Trespasser – On-Site Waste Area
• Current and Future Off-Site Trespasser
• Current Child Resident at Various Off-Site
Residences
• Current Adult and Child Residents at Various
Off-Site Residences
The USEPA’s target risk range for total excess
lifetime cancer risk is 1 in 10,000 to one in a million.
The total excess lifetime cancer risks for the
populations that exceeded that range were:
• Future Adult and Child Residents – On-Site
Waste and Non-Waste Areas
• Future Outdoor Commercial/Industrial
Worker – On-Site Waste Area
• Current Child and Adult Resident at Various
Off-Site Residences
Risk from exposure to lead is evaluated by modeling
the potential level of lead that could occur in blood.
Since children are the most sensitive to lead impacts,
residential exposures are focused on children.
Similarly, commercial/industrial exposures are
focused on the fetuses of pregnant adult workers.
Modeling results that show a greater than 5 percent
chance of a blood lead concentration greater than
10 micrograms of lead per deciliter of blood are
considered unacceptable. The predicted blood lead
levels for the site were unacceptable in the
following populations:
• Future Adult and Child Residents – On-Site
Waste and Non-Waste Areas
• Future Outdoor Commercial/Industrial
Worker – On-Site Waste Area
• Future Construction/Utility Worker – On-Site
Waste and Non-Waste Area
8
Figure 5 – Area of Concern for On-Site Soil
and Waste
• Current Child and Adult Resident at Various
Off-Site Residences
Ecological Risks
An ecological risk assessment was conducted at the
Site. The Site was evaluated for the presence of
ecological receptors (plants and animals) and
completed ecological exposure pathways to
contaminants in surface and subsurface soil, surface
water, sediment, and plant and fish tissue.
Potentially completed exposure pathways identified
at the Site included direct contact or ingestion of
surface soils by plants and wildlife, direct contact or
ingestion of surface water by plants and wildlife,
and direct contact or ingestion of surface water
sediments by wildlife. Additionally, area fish and
wildlife could be exposed through bioaccumulation
of Site related constituents in benthic invertebrates,
aquatic and terrestrial invertebrates, aquatic and
terrestrial plants, small mammal prey, and fish.
Indicator species were selected to model and
evaluate potential risk. These species were not
always identified at the Site but habitat at the Site is
suitable for these species.
Analysis of the potentially completed exposure
pathways from the Site shows that metals (arsenic,
cadmium, lead, and zinc) present the greatest
potential risk to plant and wildlife species. Of the
terrestrial receptor species chosen for evaluation,
the short-tailed shrew and the American Robin had
the highest amounts of risk. Of the species that
would have regular contact with surface water and
sediment, the mallard and the great blue heron had
the highest amount of risk. The areas and media
resulting in unacceptable levels of ecological risk
were analogous to areas and media with
unacceptable human health risk. Since addressing
human health risk will also address those areas
posing ecological risk, the remainder of this
Proposed Plan discusses Site cleanup in terms of the
human health.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are the cleanup
objectives for protection of human health and the
environment. Site-specific preliminary remediation
goals (PRGs) are the desired endpoint
concentrations for each exposure route that are
believed to provide adequate protection of human
health and the environment. In this case a Hazard
Index of 1 or in excess of 3 in every 100,000 excess
cancer risk. RAOs and PRGs were developed for the
Site by taking into account media, exposure
pathways, COCs, and PRGs. PRGs for each medium
(soil, sediment, and surface water) are summarized
in Table 1 above.
Areas of Concern (AOCs) are areas on the Site that
require remediation based upon the RAOs and PRGs.
The RAOs and AOCs for the Site by medium are:
Table 1
Site-Specific PRGs by Medium
COC Site-Specific PRG
Soil, Residential (mg/kg) or (ppm)
Arsenic 37
Cadmium 75
Lead 500
Soil, Nonresidential (mg/kg) or (ppm)
Arsenic 200
Cadmium 560
Lead 1,000
Sediment (mg/kg) or (ppm)
Arsenic 181
Cadmium 813
Lead 500
Surface Water (μg/L) or (ppm)
Cadmium 238
9
Figure 6 – Areas of Concern for Sediment and
Surface Water
Soil and Waste Materials
• Protect human health by preventing direct
contact, through the ingestion and inhalation
exposure pathways with arsenic, cadmium, and
lead contaminated on-site and off-site soil and
waste material by reducing arsenic, cadmium,
and lead concentrations to residential levels less
than 37 ppm, 75 ppm, and 500 ppm, or to
nonresidential levels less than 200 ppm, 560
ppm, and 1,000 ppm respectively. AOCs for soil
are shown on the previous page Figure 5.
Sediment
• Protect human health and the environment by
preventing direct contact, through the ingestion
pathway, with arsenic, cadmium, and lead
contaminated sediment by reducing arsenic,
cadmium, and lead concentrations to levels less
than 181 ppm, 813 ppm, and 500 ppm,
respectively. AOCs for sediment are shown on
Figure 6.
Surface Water
• Protect human health and the environment by
preventing direct contact, through the ingestion
pathway, with cadmium contaminated surface
water by reducing cadmium concentrations to
levels less than 238 ppm. AOCs for surface
water are shown on Figure 6.
SUMMARY OF REMEDIAL
ALTERNATIVES
Remedial alternatives for the Tulsa Fuel and
Manufacturing Site are presented in Table 2 (next
page) and discussed in the following paragraphs.
The alternatives are numbered to correspond with
the numbers in the FS Report.
These technologies were evaluated for practicality
(effectiveness and implement ability) and cost.
Technologies that were not practical or cost-effective
were removed from further consideration.
The remaining technologies were then reviewed to
identify combinations that would address all aspects
of each AOC’s contamination (Figures 5 and 6).
These combinations are referred to as remedial
alternatives. The following remedial alternatives
were developed for the AOCs at the Site.
Common Element
The following paragraph identifies the common
element of the alternatives except for Remedial
Alternative 1 - No Action and Alternative 3 –
Stabilization and Off-Site Disposal at a RCRA-Permitted
Facility. The Common Element will
achieve applicable RAOs. This element may be
compatible with residential land.
Institutional Controls (ICs) – The ODEQ will file a
recordable notice of remediation taken pursuant to
CERCLA in the land records of the county in which
the site is located. The notice will contain a legal
description of the affected property and will identify
all engineering controls used to ensure the
effectiveness of the remediation. Additionally, the
notice will contain a prohibition against engaging in
any activities that could cause damage to the
remedial action or to the engineering controls or
that could cause recontamination of the soil or
groundwater. The notice will contain appropriate
restrictions on land use or other activities that are
incompatible with the cleanup levels, including but
not limited to restrictions against using groundwater
for drinking or irrigation purposes or redeveloping
the land for residential use. The ODEQ has
authority to take administrative or civil action to
recover costs from or to compel compliance with
this notice against any person who damages or
interferes with the remediation, engineering controls
10
or continuing operation, maintenance or monitoring
of the site.
Alternative 1 – No Action
Estimated Capital Cost - $0
Estimated Annual O&M Cost - $0
Estimated Present Value Cost - $83,188
Estimated Construction Timeframe – None
Regulations governing the Superfund program
generally require that the “no action” alternative be
evaluated to establish a baseline for comparison.
Under this alternative, the DEQ and EPA would take
no action at the Site or at off-site properties to
prevent exposure to the soil, sediment, and other
Site-related contamination. All remedial alternatives,
except the “no action” alternative, are expected to
attain the RAOs and meet appropriate waste
disposal regulations. Selection of the “no action”
alternative would mean that the RAO’s would not be
met and possible exposure of COC could occur to
current and future human receptors and ecological
receptors.
By leaving the impacted soil and waste materials in-place,
a formal review of the Site will be required
every 5 years. Conducting remedy reviews is
assumed to include monitoring of all media and
wastes remaining on the Site. Costs associated with
this “no action” alternative include conducting five-year
reviews with associated groundwater
monitoring and a Site Closure Report.
Soil: On-Site Soil and Waste Materials Areas
(This is DEQ’s preferred remedial alternative
for on-site soil and waste material areas)
• Alternative 2 - Consolidation and Cap
Estimated Capital Cost – $5,293,802
Estimated Annual O&M Cost - $55,174 -
$69,556
Estimated Present Value Cost -
$3,130,145 – $5,724,924
Estimated Construction Timeframe – 20
weeks
Estimated Time to Achieve RAOs – 20
weeks
For this Alternative approximately 164,000 cubic
yards of soil and waste materials on the Site would
be capped. Several consolidation and capping
options were evaluated. Several consolidation and
capping options were evaluated and the specific
design and cost of will be determined during the
Remedial Design. Cost estimates for each option
are detailed in the FS; for estimating purposes, the
highest estimate is present here. Each of the
capping scenarios would minimize surface exposure,
prevent infiltration of water that could create
contaminated leachate, and prevent transport of
wastes by erosion. Periodic maintenance would be
required to maintain the integrity of the cap. ICs
for this preferred remedial alternative for soil and
waste material would include prohibition of
activities that would damage the cap such as
plowing, digging, drilling, trenching or other earth
movement. Shallow-root gardening for human
consumption would also be
prohibited. Groundwater use restrictions may
include but not be limited to restrictions against
using groundwater for drinking or irrigation
purposes. Other land use restrictions and
engineering controls may be developed as the work
on the site progresses. The DEQ will monitor and
maintain the vegetation and soil to prevent erosion
or movement of the cap to prevent exposure of
metals-contaminated soil to humans and the
TABLE 2
SUMMARY OF REMEDIAL
ALTERNATIVES TULSA FUEL AND
MANUFACTURING SITE
FS Designation Description
SOIL: On-Site Soil and Waste Materials Areas
1 No Action
2 Consolidation and Cap
3 Stabilization and Off-Site Disposal at a
RCRA-Permitted Facility
4 On-Site Fixation or Stabilization and
On-Site Disposal
SOIL, SEDIMENT, and WASTES: Off-Site Locations
1 No Action
2 Excavation, Stabilization (as needed)
and Disposal at TFM
3
Excavation, Stabilization (as needed)
and Off-Site Disposal at a RCRA-Permitted
Facility
SEDIMENT and SURFACE WATER: On-Site Ponds,
Mid-Site Ravine, and Strip Mine Pit
1 No Action
2 Stabilization and Off-Site Disposal at a
RCRA-Permitted Facility
3 On-Site Fixation or Stabilization and
On-Site Disposal
SURFACE WATER
1 No Action
11
environment. Also refer to Common Elements.
Post-closure groundwater monitoring would be
conducted to detect movement of contaminants
leaching from the capped area and to verify the cap
retains its integrity. Every 5 years a formal review
of the remedy will be required to ensure that it is
protective. This alternative will achieve applicable
RAOs and meet PRGs. The capping scenarios that
were evaluated include:
• Alternative 2 – Scenario 5-2, 25 Acre Cap
• Alternative 2 – Scenario 5-2a – 5-2d, 10 Acre
Cap
The above capping scenarios were evaluated to look
at the cost associated with various sizes, types, and
depths of caps and liners.
• Alternative 3 – Stabilization and Off-Site Disposal
at a RCRA-Permitted Facility
Estimated Capital Cost - $31,879,532
Estimated Annual O&M Cost - $52,500
Estimated Present Value Cost - $32,014,734
Estimated Construction Timeframe – 32 weeks
Estimated Time to Achieve RAOs – 32 weeks
For this Alternative, approximately 164,000 cubic
yards of contaminated soil and waste materials
would be excavated, stabilized, and loaded onto
trucks or railcars, and transported to an off-site
permitted waste landfill for disposal. The off-site
landfill would need to meet regulatory requirements
for this type of waste. This alternative would
permanently remove contaminated material from
the Site and is a proven and acceptable practice
that reduces the risk posed by hazardous
substances. This alternative will achieve applicable
RAOs and meet PRGs.
• Alternative 4 – On-Site Fixation or Stabilization
and On-Site Disposal
Estimated Capital Cost - $13,177,831
Estimated Annual O&M Cost - $49,174
Estimated Present Value Cost - $13,534,509
Estimated Construction Timeframe – 30 weeks
Estimated Time to Achieve RAOs – 30 weeks
Alternative 4 involves excavating approximately
164,000 cubic yards of contaminated soil and waste
materials for placement in an on-site disposal cell.
The excavated areas would be backfilled with clean
soil. The disposal cell would consist of a clay liner
and composite liner with leachate collection.
Contaminated soil that is determined to be
hazardous by characteristic or is wet would be
stabilized so the fill material would be acceptable for
placement in the cell. The cell would be capped
with compacted clay and topsoil. Capping would
minimize surface exposure, prevent infiltration of
water that could create contaminated leachate, and
prevent transportation of wastes by erosion.
Periodic maintenance would be conducted to
maintain the integrity of the cap. ICs for this
remedial alternative would include prohibition of
shallow-root gardening for human consumption and
all activities that would damage the cap such as
plowing, digging, drilling, trenching or other earth
movement. Prohibitions against using groundwater
for drinking or irrigation purposes may be
included. Vegetation and soil will be monitored and
maintained to prevent erosion or movement of the
cap. Also refer to Common Elements. Post-closure
groundwater monitoring would be conducted to
determine if the cell and its contents were impacting
the groundwater beneath the disposal cell and to
verify the cap retains its integrity. Every 5 years a
formal review of the remedy will be required to
ensure that it is protective. This alternative will
achieve applicable RAOs and meet PRGs.
Sediment and Surface Water: On-Site Ponds,
Mid-Site Ravine, and Strip Mine Pit
(This is DEQ’s preferred remedial alternative
for on-site ponds, mid-site ravine, and strip
mine pit)
• Alternative 2 – On-Site Fixation or
Stabilization and On-Site Disposal
Estimated Capital Cost - $1,183,928
Estimated Annual O&M Cost - $49,174
Estimated Present Value Cost -
$1,540,606
Estimated Construction Timeframe – 30
weeks
Estimated Time to Achieve RAOs – 30
weeks
Alternative 2 would remove approximately 33,000
cubic yards of metals impacted sediment in the on-site
surface water features. The surface water
features would be drained and treated if needed,
with measures taken to retain sediments within the
AOC. The sediment would be dewatered and
stabilized, and excavated for loading and transport
to the consolidation area or on-site disposal cell.
12
After sediment removal, the surface water features
would be backfilled with clean soil and regraded.
The consolidation area or on-site disposal cell would
be capped with compacted clay and topsoil.
Capping would minimize surface exposure, prevent
infiltration of water that could create contaminated
leachate, and prevent transportation of wastes by
erosion. Periodic maintenance would be conducted
to maintain the integrity of the cap. ICs for this
preferred remedial alternative for sediment and
surface water would include prohibition of all
activities that would damage the cap such as
plowing, digging, drilling, trenching or other earth
movement and shallow-root gardening for human
consumption. Prohibitions against using
groundwater for drinking or irrigation purposes are
possible. Other land use restrictions and
engineering controls may be developed as the work
on the site progresses The DEQ will monitor and
maintain vegetation and soil to prevent erosion or
movement of the cap. Also refer to Common
Elements. Post-closure groundwater monitoring
would be conducted. Every 5 years a formal review
of the remedy will be required to ensure that it is
protective. This alternative will achieve applicable
RAOs and meet PRGs. Surface water features not
requiring remediation would be left as is.
• Alternative 3 – Stabilization and Off-Site Disposal
at a RCRA-Permitted Facility
Estimated Capital Cost - $1,854,238
Estimated Annual O&M Cost - $52,500
Estimated Present Value Cost - $1,989,440
Estimated Construction Timeframe – 32 weeks
Estimated Time to Achieve RAOs – 32 weeks
Alternative 3 would remove approximately 33,000
cubic yards of metals impacted sediment in the on-site
surface water features. The surface water
features would be drained, with measures taken to
retain sediments within the AOC. The sediment
would be dewatered, excavated, and stabilized for
loading and transport to an off-site permitted waste
landfill for disposal. The off-site landfill would meet
regulatory requirements for this type of waste. This
alternative would permanently remove
contaminated material from the Site and is a proven
and acceptable practice that reduces the risk posed
by hazardous substances. This alternative will
achieve applicable RAOs and meet PRGs. Surface
water features not requiring remediation would be
left as is.
Soil, Sediment, and Wastes: Off-Site
Locations
Additional investigations may be conducted offsite
to determine nature and extent of contamination.
Currently, those efforts are not part of this remedial
action. Future investigation and remediation efforts
may remain separate and be conducted by an
interested third party and/or PRPs; or residential
contamination may be incorporated into this
remedial response through an amended ROD or an
Explanation of Significant Difference (ESD).
(This is DEQ’s preferred remedial alternative
for off-site areas)
• Alternative 2 – Excavation, Stabilization,
and Disposal at TFM
Estimated Capital Cost - $331,213
Estimated Annual O&M Cost - $0
Estimated Present Value Cost - $376,986
Estimated Construction Timeframe – 12
weeks
Estimated Time to Achieve RAOs – 12
weeks
For this Alternative, approximately 1,600 cubic
yards of contaminated soil and waste materials
would be excavated, stabilized (as needed), loaded
onto trucks, and transported to the Site for disposal
within a capped consolidation area or on-site
disposal cell. The excavated areas would be
backfilled with clean soil. This Alternative would
permanently remove contaminated material from
the off-site areas and is a proven and acceptable
practice that reduces the risk posed by hazardous
substances. This alternative will achieve applicable
RAOs and meet PRGs. ICs for this preferred
remedial alternative for off-site locations would
include prohibition of activities that would damage
the cap such as plowing, digging, drilling, trenching
or other earth movement. Shallow-root gardening
for human consumption would also be
prohibited. Groundwater use restrictions may
include but not be limited to restrictions against
using groundwater for drinking or irrigation
purposes. Other land use restrictions and
engineering controls may be developed as the work
on the site progresses. The DEQ will monitor and
maintain the vegetation and soil to prevent erosion
or movement of the cap to prevent exposure of
metals-contaminated soil to humans and the
environment. Also refer to Common Elements.
13
• Alternative 3 – Excavation, Stabilization, and Off-
Site Disposal at a RCRA-Permitted Facility
Estimated Capital Cost - $706,680
Estimated Annual O&M Cost - $0
Estimated Present Value Cost - $760,989
Estimated Construction Timeframe – 12 weeks
Estimated Time to Achieve RAOs – 12 weeks
With this Alternative, approximately 1,600 cubic
yards of contaminated soil and waste materials
would be excavated, stabilized (as needed), and
loaded onto trucks and transported to an off-site
permitted waste landfill for disposal. The off-site
landfill would meet regulatory requirements for this
type of waste. The excavated areas would be
backfilled with clean soil. This Alternative would
permanently remove contaminated material from
the off-site areas and is a proven and acceptable
practice that reduces the risk posed by hazardous
substances. This alternative will achieve applicable
RAOs and meet PRGs.
TABLE 3
Evaluation Criteria for CERCLA Remedial
Alternatives
Overall Protection of Human Health and
Environment determines whether an alternative
eliminates, reduces, or controls threats to public
health and the environment through institutional
controls, engineering controls, or treatment.
Compliance with ARARs evaluates whether the
alternative meets Federal and State environmental
statutes, regulations, and other requirements that
pertain to the site, or whether a waiver is justified.
Long-term Effectiveness and Permanence
considers the ability of an alternative to maintain
protection of human health and the environment
over time.
Reduction of Toxicity, Mobility, or Volume of
Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the
harmful effects of principal contaminants, their
ability to move in the environment, and the amount
of contamination present.
Short-term Effectiveness considers the length
of time needed to implement an alternative and the
risks the alternative poses to workers, residents,
and the environment during implementation.
Implementability considers the technical and
administrative feasibility of implementing the
alternative, including factors such as the relative
availability of goods and services.
Cost includes estimated capital, periodic, and
annual operations and maintenance (O&M) costs,
as well as present worth cost. Present worth cost
is the total cost of an alternative over time in terms
of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -
30 percent.
State/Support Agency Acceptance considers
whether the DEQ and USEPA agree with the
analyses and recommendations, as described in the
RIA/FSA and Proposed Plan.
Community Acceptance considers whether the
local community agrees with DEQ's analyses and
preferred alternative. Comments received on the
Proposed Plan are an important indicator of
community acceptance.
14
EVALUATION OF REMEDIAL
ALTERNATIVES
Nine criteria are used to evaluate remedial
alternatives individually and against each other in
order to select a remedy. This section of the
Proposed Plan profiles the relative performance of
each alternative against the nine criteria, noting
how is compares to the other options under
consideration. This nine evaluation criteria are
discussed below. The “Detailed Analysis of
Alternatives” can be found in the FS Report.
1. Overall Protection of Human Health and
the Environment – All of the alternatives except
the “no action” alternative would provide adequate
protection of human health and the environment by
eliminating, reducing, or controlling risk through
treatment, containment, engineering controls,
and/or institutional controls. Because the “no
action” alternative is not protective of human health
and the environment, it was eliminated from
consideration under the remaining eight criteria.
An exception was made for the surface water
medium. “No action” was the only alternative
retained for surface water. Since on-site Ponds 1
through 5 would be removed from service and
would no longer exist, surface water remediation is
not needed for these ponds. In addition, dredging
and/or removal of waste materials and
contaminated sediment from the Strip Mine Pit and
other off-site drainages will remove materials that
could potentially impact surface water at these
locations.
2. Compliance with ARARs – All of the
alternatives would meet their respective ARARs
from Federal and State Laws. Transportation of
wastes under the alternatives with off-site disposal
will have to be conducted pursuant to Federal and
State transportation regulations. Facilities accepting
these wastes would have to be certified to accept
the respective wastes.
3. Long-term Effectiveness and Permanence
Soil: On-Site Soil and Waste Materials Areas
All of the considered alternatives provided similar
long-term effectiveness. Alternative 2 (capping)
and Alternative 4 (stabilization and on-site disposal
cell) would prevent direct contact exposure and
contaminant migration; however, monitoring and
maintenance would be necessary to ensure the
long-term effectiveness and permanence of these
alternatives. Alternative 3 (off-site disposal) would
prevent direct contact exposure, contaminant
migration, and reduce the inherent hazards posed
by the contaminants at the Site. Additionally,
Alternative 3 would maximize reuse of the Site.
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
Each of the considered alternatives provided similar
long-term effectiveness. Alternative 2 (excavation,
stabilization, and off-site disposal) permanently
removes contaminated sediments from the Site.
Alternative 3 (stabilization and on-site disposal)
would prevent direct contact exposure and
contaminant migration; however, monitoring and
maintenance would be necessary to ensure the
long-term effectiveness and permanence of
Alternative 3.
Soil, Sediment, and Wastes: Off-Site Locations
All of the considered alternatives provided similar
long-term effectiveness. Alternative 2 (excavation
and disposal at the TFM Site) and Alternative 3
(excavation and off-site disposal at a landfill)
removes contaminated materials from the off-site
properties and prevent direct contact exposure and
contaminant migration. Since contaminants are
removed, monitoring and maintenance would not be
required to ensure long-term effectiveness and
permanence of these alternatives.
4. Reduction of Toxicity, Mobility, or Volume
of Contaminants
Soil: On-Site Soil and Waste Materials Areas
Each of the alternatives provides reduction of the
mobility of the contaminants through the use of a
physical barrier to prevent contact of the
contaminants with the environment. Alternative 4
(stabilization and on-site disposal cell) and
Alternative 3 (off-site disposal) further reduce the
mobility and toxicity of the contaminants by
treatment of soil and wastes, as needed, so that
materials are no longer considered hazardous by
characteristic. Alternative 3 (off-site disposal) does
not reduce the toxicity and volume of the
contaminants; however, the volume of
contaminated materials on-site will be transferred to
a permitted off-site disposal facility. None of the
alternatives achieve a reduction or volume.
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
15
Each of the alternatives provides reduction of the
mobility of the contaminants through the use of a
physical barrier to prevent contact of the
contaminants with the environment. Alternative 2
(excavation, stabilization, and off-site disposal) and
Alternative 3 (stabilization and on-site disposal)
further reduce the mobility and toxicity of the
contaminants by treatment of soil and wastes, as
needed, so that materials are no longer considered
hazardous by characteristic. Neither of the
alternatives reduces toxicity and volume of the
contaminants; however, the volume of
contaminated sediment on-site would be transferred
to an off-site disposal facility as part of Alternative 2.
Neither of the alternatives achieves reduction of
volume.
Soil, Sediment, and Wastes: Off-Site Locations
Each of the alternatives provides reduction of the
mobility of the contaminants through the use of a
physical barrier to prevent contact of the
contaminants with the environment. Alternative 2
(excavation and disposal at the TFM Site) and
Alternative 3 (excavation and off-site disposal at a
landfill) further reduce the mobility and toxicity of
the contaminants by treatment of soil and wastes,
as needed, so that materials are no longer
considered hazardous by characteristic. Neither of
the alternatives reduces the volume of the
contaminants; however, the volume of
contaminated materials for the off-site locations
would be transferred either to the TFM Site
(Alternative 2) or an off-site disposal facility
(Alternative 3).
5. Short-Term Effectiveness
Soil: On-Site Soil and Waste Materials Areas
Alternative 2 (capping) would provide better short-term
effectiveness because the cap could be
constructed faster than excavating and stabilizing
material for movement to an on-site disposal cell
(Alternative 4) or off-site disposal facility
(Alternative 3). Alternative 2, Scenario 5-2 (capping
in place) does not present a short-term threat
except to the extent that the area presents direct
contact or migration potential during the time it
takes to fully implement the remedy. The
remaining alternatives involve the consolidation or
excavation of wastes and contaminated soils and
thus present a potential for short-term exposure.
Additionally, these alternatives pose potential risks
to construction workers and nearby residents during
excavation and handling of contaminated materials.
Control of dust and runoff during remedial activities
will limit the amount of materials that may migrate
to a potential receptor. In addition, workers would
be required to wear the appropriate level of
protection to avoid exposure during excavation and
treatment activities. Alternative 3 may pose a
higher short-term risk to the nearby residents
because of the potential for exposure to the
contaminated soils by trucking the material to an
off-site facility.
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
Both alternatives have similar short-term
effectiveness. Both alternatives involve the
excavation of contaminated sediments and thus
present a potential for short-term exposure as
previously described.
Soil, Sediment, and Wastes: Off-Site Locations
Both alternatives have similar short-term
effectiveness. Both alternatives involve the
excavation of wastes and contaminated soils and
thus present a potential for short-term exposure as
previously described.
6. Implementability
For all alternatives, administrative coordination,
labor, equipment, materials, and outside services
will be required. These alternatives utilize
conventional material and equipment which are
widely used and accepted in the construction
industry. Institutional controls such as deed notices
will be placed on land parcels that are contained in
the site boundary by DEQ under Oklahoma Statute
27A O.S. §2-7-123.
7. Cost
Soil: On-Site Soil and Waste Materials Areas
The estimated present worth cost for Alternative 2
(capping) is less than Alternative 3 (stabilization and
on-site disposal cell) for all capping scenarios that
were reviewed. Alternative 4 (off-site disposal) is
the most costly; however, the alternative requires
only minimal O&M costs. Alternatives 2 and 3 have
more expensive O&M required for 30 years.
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
The estimated present worth for Alternative 3
(stabilization and on-site disposal) is less than
Alternative 2 (excavation, stabilization, and off-site
disposal).
16
Soil, Sediment, and Wastes: Off-Site Locations
The estimated present worth cost for Alternative 2
(excavation and disposal at the TFM Site) is less
than Alternative 3 (excavation and off-site disposal
at a landfill). While Alternative 3 is the most
expensive, contaminated materials would not be
brought onto the Site.
8. State/Support Agency Acceptance
The State of Oklahoma supports the Preferred
Alternative. The EPA as the support Agency accepts
the Preferred Alternative, contingent upon the
Public Comment Period.
9. Community Acceptance
Community acceptance of the Preferred Alternative
will be evaluated after the public comment period
ends and will be described in the responsiveness
summary of the Site Record of Decision.
SUMMARY OF
PERFERRED REMEDIAL
ALTERNATIVES
Soil and Waste Materials: On-Site Soil and Waste
Materials Areas
Consolidation and cap, of approximately 164,000
cubic yards of material
Estimated Capital Cost – $5,293,802
Sediment and Surface Water: On-Site Ponds, Mid-
Site Ravine, and Strip Mine Pit
On-Site Fixation or Stabilization and On-Site
Disposal, of approximately 33,000 cubic yards of
material
Estimated Capital Cost - $1,183,928
Soil, Sediment, and Waste Materials: Off-Site
Locations
Excavation, Stabilization, and Disposal at TFM
Off-Site Estimated Total Capital Cost - $331,213
Based on the information available at this time, the
State of Oklahoma and the USEPA believe the
Preferred Alternative would be protective of human
health and the environment, would comply with
ARARs, and would utilize permanent solutions to the
maximum extent practicable. The Preferred
Alternative can change in response to public
comment or new information.
COMMUNITY PARTICIPATION
The DEQ and USEPA provide information regarding
the cleanup of the Tulsa Fuel and Manufacturing
Site to the public through public meetings, the
Administrative Record file for the Site, and
announcements published in the Collinsville News.
The DEQ and USEPA encourage the public to gain a
more comprehensive understanding of the Site and
the Superfund activities that have been conducted
at the Site.
The date, location, and time of the public meeting,
the dates for the public comment period, and the
locations of the Administrative Record file, are
provided on the front page of this Proposed Plan.
For further information on the Tulsa Fuel and Manufacturing
Superfund Site, please visit the locations identified on Page 1
to view various site documentation or contact:
Ms. Sara Downard Mr. Michael Torres
Project Manager Remedial Project Manager
Oklahoma DEQ EPA Region 6
707 N. Robinson, PO Box 1677 1445 Ross Avenue
Oklahoma City, OK 73101 Dallas Texas, 75202
(405) 702-5126 (214) 665-2108
Sara.Downard@deq.state.ok.us torres.michael@epa.gov
17
ACRONYMS
AOC Area of Concern
ARARs Applicable or Relevant and
Appropriate Requirements
ATSDR Agency for Toxic Substances and
Disease Registry
BHHRA Baseline Human Health Risk
Assessment
CERCLA Comprehensive Environmental
Response, Compensation, and
Liability Act
COPC Contaminants of Potential Concern
COC Contaminants of Concern
DEQ Oklahoma Department of
Environmental Quality
USEPA United States Environmental
Protection Agency, Region VI
FS Feasibility Study
HRS Hazard Ranking System
mg/kg Milligrams per kilogram
NCP National Oil and Hazardous
Substance Pollution Contingency
Plan
NPL National Priority List
PA Preliminary Assessment
PRGs Preliminary Remedial Goals
PRP Potentially Responsible Party
ROD Record of Decision
RAOs Remedial Action Objectives
RI Remedial Investigation
RCRA Resource Conservation and
Recovery Act
RME Reasonable Maximum Exposure
SI Site Inspection
Site Tulsa Fuel and Manufacturing
Superfund Site
μg/L Microgram per Liter
GLOSSARY OF TERMS
Specialized terms used in this Proposed Plan are
defined below:
Administrative Record – The body of documents
available to the public associated with
characterization and remedy selection at a site.
Applicable or Relevant and Appropriate
Requirements (ARARs) – The Federal and State
environmental laws that a selected remedies will
meet. These requirements may vary among sites
and alternatives.
Baseline Human Health Risk Assessment
(BHHRA) – An evaluation of the potential threat to
human health and the environment in the absence
of any remedial action.
Carcinogen – Capable of causing the cells of an
organism to react in a manner to produce cancer.
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) –
CERCLA was enacted by Congress on December 11,
1980. This law created a tax on the chemical and
petroleum industries and provided broad Federal
authority to respond directly to releases or
threatened releases of hazardous substances that
may endanger public health or the environment.
Ecological Risk Assessment – Study that
assesses risks to aquatic and terrestrial receptors
posed by contaminant releases from a site.
Excess Lifetime Cancer Risk - Cancer posed by a
contaminated site in excess of the lifetime
probability of developing cancer from other causes.
Feasibility Study (FS) – Identifies and evaluates
the appropriate technical approaches and treatment
technologies to address contamination at a site.
Groundwater – Underground water that fills pores
in soils or openings in rocks to the point of
saturation. Groundwater is often used as a source
of drinking water via municipal or domestic wells.
Groundwater Monitoring – Ongoing collection of
groundwater information about the environment
that helps gauge the effectiveness of a clean-up
action.
Human Health Risk Assessment – A study that
determines and evaluates risk that site
contamination poses to human health.
Institutional Controls – Actions taken to limit transporting, treating, storing, and disposing of
unauthorized access to the site, control the way in hazardous waste.
which an area of the site is used, and monitor
contamination migration.
Microgram per Liter (μg/L) - A unit of
measurement equivalent to one microgram of
contaminant per liter of water.
Milligram per Kilogram (mg/kg) - A unit of
measurement equivalent to one milligram of
contaminant per kilogram of solid (typically soil).
National Oil and Hazardous Substance
Pollution Contingency Plan (NCP) – Regulations
governing cleanups under USEPA’s Superfund
program.
Preferred Alternative – Final remedial alternative
that meets NCP evaluation criteria and is supported
by regulatory agencies.
Present Value Cost – A method of evaluation of
expenditures that occur over different time periods.
By discounting all costs to a common base year, the
costs for different remedial action alternatives can
be compared on the basis of a single figure for each
alternative. When calculating present worth cost for
Superfund sites, total operations & maintenance
costs are to be included.
Remedial Action – Action(s) taken to correct or
remediate contamination.
Remedial Action Objectives (RAOs) –
Remediation objectives for protection of human
health and the environment.
Record of Decision (ROD) – A formal document
that is a consolidated source of information about a
Superfund site, the remedy selection process, and
the selected remedy.
Receptor – An organism that receives, may receive,
or has received environmental exposure to a
chemical.
Remedial Investigation (RI) – A study
conducted to identify the types, amounts, and
locations of contamination at a site.
Resource Conservation and Recovery Act
(RCRA) – The Federal act that established a
regulatory system to track hazardous wastes from
the time they are generated to their final disposal.
RCRA also provides for safe hazardous waste
management practices and imposes standards for
18
Reasonable Maximum Exposure (RME) - The
highest level of human exposure that could
reasonably be expected to occur.
19
Name
Address___________________________
City______________________________
State___________Zip________________
USE THIS SPACE TO WRITE YOUR COMMENTS
Your input on the Proposed Plan for the Tulsa Fuel and Manufacturing Site is important to the DEQ and EPA.
Comments provided by the public are valuable in helping the DEQ and EPA select a final cleanup remedy for
the Site.
You may use the space below to write your comments, then fold and mail. Comments must be postmarked
by July 30, 2008. If you have any questions about the comment period, please contact Sara Downard at
(405) 702-5126, Michael Torres at (214) 665-2108, or through EPA’s toll-free number at 1-800-533-3508.
Those with electronic communications capabilities may submit their comments to the DEQ or EPA via
Internet at the following e-mail addresses: Sara.Downard@deq.state.ok.us or Torres.Michael@epa.gov.
Click tabs to swap between content that is broken into logical sections.
| Okla State Agency |
Environmental Quality, Oklahoma Department of |
| Title | Proposed plan, Tulsa Fuel and Manufacturing Superfund site, Collinsville, Oklahoma. |
| Alternative title | Remediation plan--weblink |
| Authors |
Oklahoma. Department of Environmental Quality. United States. Environmental Protection Agency. Region VI. |
| Publisher | Oklahoma Department of Environmental Quality |
| Publication Date | 2008 |
| Publication type |
Planning Document Technical Reports |
| Subject |
Hazardous waste site remediation--Oklahoma--Collinsville. Tulsa Fuel & Manufacturing Superfund Site (Okla.)(Okla.) |
| Purpose | This Proposed Plan, part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process, identifies the preferred alternative for remediating the contamination associated with the Tulsa Fuel and Manufacturing Superfund Site (Site), Collinsville, Oklahoma, and provides the rationale for this preference.; The Tulsa Fuel and Manufacturing Superfund Site, located in Collinsville, Oklahoma is an abandoned zinc smelter and lead roaster that operated from 1914 through 1925. |
| OkDocs Class# | E4850.3 T924f 2008 |
| Digital Format | PDF, Adobe Reader required |
| ODL electronic copy | Downloaded from agency website: |
| Rights and Permissions | This Oklahoma government publication is provided for educational purposes under U.S. copyright law. Other usage requires permission of copyrightholders. |
| Language | English |
| Full text | 1 This Proposed Plan, part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process (Figure 1), identifies the preferred alternative for remediating the contamination associated with the Tulsa Fuel and Manufacturing Superfund Site (Site), Collinsville, Oklahoma, and provides the rationale for this preference. In addition, this Plan includes summaries of other cleanup alternatives evaluated for use at this Site. This document is issued by the Oklahoma Department of Environmental Quality (DEQ), the lead agency for Site activities, in consultation with the United States Environmental Protection Agency, Region VI (USEPA). The final remedy will be selected for the Site after reviewing and considering all information submitted during the 30-day public comment period on the Proposed Plan (see right). Based on new information or public comments, DEQ, in conjunction with the USEPA, may modify the preferred alternative or select other response actions. Therefore, the public is encouraged to review and comment on the alternatives presented in this Proposed Plan. The DEQ is issuing this Proposed Plan as part of its public participation responsibilities under Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and the CERCLA of 1980 §117(a). This Proposed Plan summarizes information that can be found in greater detail in the Remedial Investigation (RI), and the Feasibility Study (FS) Reports and other documents contained in the Administrative Record Dates to Remember: Public Comment Period: July 1, 2008 to July 30, 2008 The DEQ will accept written comments on the Proposed Plan during the public comment period. Public Meeting: July 24, 2008 The DEQ will hold a public meeting to explain the Proposed Plan and all of the alternatives presented in the Feasibility Study. Oral and written comments will also be accepted at the meeting. The meeting will be held at Collinsville City Hall, 106 North 12th street, Collinsville, Oklahoma at 6:00 to 7:30. The Administrative Record including copies of the RI and FS reports are available for viewing at: Collinsville Public Library 1223 W. Main, Collinsville, Oklahoma 918-596-2840 Hours: 12 pm to 8 pm Monday thru Thursday 12 pm to 5 pm Friday 10 am to 5 pm Saturday Closed on Sunday Proposed Plan Tulsa Fuel and Manufacturing Superfund Site Collinsville, Oklahoma Oklahoma Department of Environmental Quality Announces Proposed Plan Figure 1 - The CERCLA Process 2 Figure 2 - Site Location for this site. The DEQ encourages the public to review these documents to gain a more complete understanding of the Site and investigation activities that have been conducted at the Site. SUMMARY OF PERFERRED REMEDIAL ALTERNATIVES Soil and Waste Materials: On-Site Soil and Waste Materials Areas Consolidation and cap, of approximately 164,000 cubic yards of material Estimated Capital Cost – $5,293,802 Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit On-Site Fixation or Stabilization and On-Site Disposal, of approximately 33,000 cubic yards of material Estimated Capital Cost - $1,183,928 Soil, Sediment, and Waste Materials: Off-Site Locations Excavation, Stabilization, and Disposal at TFM Off-Site Estimated Total Capital Cost - $331,213 SITE HISTORY The Tulsa Fuel and Manufacturing Superfund Site, located in Collinsville, Oklahoma is an abandoned zinc smelter and lead roaster that operated from 1914 through 1925 See Figure 2 (above). The Tulsa Fuel and Manufacturing smelting operation utilized nine furnaces, which were believed to be fueled by nearby natural gas wells. Other main structures of the smelter included a mechanical kiln building, a condenser room, and a laboratory. A 2- million gallon capacity surface reservoir was used in conjunction with the condenser room during smelting operations. Large amounts of ore were stored on the Site in the area northeast of the waste piles. The Site was abandoned in the 1920s. The majority of the structures have been demolished, but several foundations and building footings remain. A residence, which was occupied from 1935 through February 2002, was located on the Site near the former office building (paymaster hut). The on-Site residence was destroyed by a fire and is currently unoccupied. The residence has a water well that was used in the past for drinking water but is no longer in use. No other residential structures are located on the site; however, a garage and a few storage sheds remain in place adjacent to the former residence. After being identified in 1992, a Preliminary Assessment (PA) of the Site was performed under the direction of the USEPA, followed by a focused Site Inspection (SI) in September 1994. A search for potentially responsible parties (PRPs) was conducted from August through September 1998. The Hazard Ranking System (HRS) Documentation Record was completed by USEPA, and the Site was 3 Figure 3 – Site Layout proposed to the Superfund National Priorities List (NPL) in September 1998. Final listing of the Site to the NPL occurred on January 19, 1999. In May of 1999, the USEPA completed a Removal Assessment Report for the Site. The assessment found that there was approximately 30,000 cubic yards of waste materials present. The Agency for Toxic Substances and Disease Registry (ATSDR) finalized the Public Health Assessment for the Site in July 2000. A Special Notice Letter, which notified the PRP of potential liability for Site response activity, was issued to the identified PRP in July 2000. The DEQ assumed the lead role for the RI/FS, and USEPA assumed the role of support agency after the PRP declined to conduct the RI/FS. Access to the property was granted in 2003, and USEPA partially fenced the Site in 2004 under emergency response authority to restrict public access. From 2005 through 2006, DEQ conducted an RI/FS. The RI was conducted from August 2005 through October 2006 and identified the types, quantities, and locations of contaminants. A summary of the investigation was presented in the RI report in August 2007 and at a public meeting held October 2007. The FS Report, which summarized and evaluated remedial alternatives, was also finalized in October 2007. Additionally, between November 2007 and January 2008, DEQ and EPA conducted a supplemental RI to evaluate potential off-site residential properties. SITE CHARACTERISTICS The approximately 61-acre Site is located 1 1/3 miles south of downtown Collinsville, Oklahoma. The Site is bounded by “Old” U.S. Highway 169 and the Atchison Topeka Santa Fe railroad tracks to the east, a flooded strip mine pit (Strip Mine Pit) that comprises the boundary of a former coal mining operation to the south, and agricultural lots to the north and west. Additionally, property owned by the Faith Assembly Church bounds the Site to the north. The Collinsville Smelter, which is another former zinc smelter, is located approximately 1/4 mile to the east-northeast of the Site on 220 acres of property formerly owned by the Bartlesville Zinc Company. Currently the Site is unused, but due to residential interest in the area it is reasonable that future land use for the site may be zoned as residential. The majority of the facility structures have been demolished. The northern portion of the Site (north of the access road/driveway) is vegetated with grasses. A large area located in the southern portion of the Site (referred to as the “Waste Area”) is covered with smelter waste consisting of broken retorts and condensers, slag, building debris, ash, bricks, and other materials from the former smelting operations. The Waste Area covers approximately 25 acres and extends to the southern border of the Site where it terminates at the Strip Mine Pit. Waste materials in the Waste Area vary in thickness from 2 feet to greater than 6 feet. Portions of the Waste Area have sloughed into the Strip Mine Pit (Figure 3). 4 Figure 4 - Contaminant Location and Movement Topography of the Site is relatively flat, with a slight slope downward to the southeast. Site drainage and run-off are uncontrolled. The Strip Mine Pit receives surface water runoff from the Site. In addition, the Site is drained by an intermittent stream that flows west to east and bisects the Site (referred to as the Mid-Site Ravine). The Mid-Site Ravine discharges to a low area located along the east boundary of the Site (referred to as the Eastern Wetlands). Surface water from the Strip Mine Pit also discharges to the Eastern Wetlands. The Eastern Wetlands drains to the east through a culvert underneath the railroad on the eastern border of the Site. Surface water exiting the Site flows to the north and east in an intermittent stream a distance of approximately 3/4 mile before draining into Blackjack Creek. Three intermittent ponds (Ponds 1, 2, and 3), which are thought to be remnants of the 2-million gallon reservoir, are located north of the former smelter operations area. In addition, two smaller ephemeral ponds (Ponds 4 and 5) are located on the Site. Soils at the Site consist primarily of silt, clay, silty loam, and shale sediments. The soil layer is relatively thin across the site, ranging in depth from 7.2 to 12.5 feet in thickness. The soil overlies initial bedrock which was observed to consist of shale with a few instances of sandstone and limestone. No major bedrock or alluvial aquifers underlie the Site. The upper bedrock aquifer yields small amounts of fair to poor quality groundwater, and has been designated as a minor use general basin. The occurrence of groundwater beneath the Site is limited; however, it does appear to be continuous across the Site. Available data indicate that groundwater flows in a south/southeasterly direction. Groundwater depth fluctuates, dependant upon precipitation. Depth to groundwater at the Site is variable and ranged from less than 4 feet below the ground surface to more than 15 feet below the ground surface. The major findings of the RI are listed below. Figure 4 is a general model of the Site. • Media impacted at the Site include surface and subsurface soils, surface water, sediment, groundwater, and vegetation. Sample results were compared to background values and to applicable screening levels. Region 6 screening levels are values which were used to identify areas that require further investigation. • Review of the Site indicated a clear division into two areas: 1) areas of the TFM site where waste materials were not visually observed during sampling (i.e., on-site non-waste areas); and, 2) areas of the Site where waste materials were visually observed during sampling (i.e., on-site waste areas). • One or more metals were detected at levels that exceeded background and/or screening levels in most of the on-site soils. The highest concentrations of metals were observed in the southern portion of the Site and were associated with the former smelter operations area. 5 • For the majority of the off-site surface soil, surface water, sediment, and/or vegetation samples, one or more metals were detected at levels that exceeded background and/or screening levels. • Groundwater samples were collected from nine temporary piezometers and seven monitoring wells at the Site. Arsenic, cadmium, lead, and zinc were detected at levels that exceeded background and/or screening levels. • Surface water and sediment samples were collected from on- and off-site surface water drainages and/or impoundments. In the surface water samples, cadmium, lead, and zinc were detected at levels exceeding background and/or screening levels. Sediment samples from the on- and off-site surface water drainages and/or impoundments should arsenic, cadmium, lead, and zinc were detected at levels exceeding background and/or screening levels. • Samples collected from on-site blackberry bushes contained higher concentrations of metals than those collected from off-site bushes. Washed berries and leaves had lower concentrations of metals than unwashed samples. • The results of the air samples collected from the Site were similar to background levels suggesting that the Site is not currently a source of airborne contamination to off-site locations. • Leaching from surface soil to subsurface soil is a potential contaminant transport mechanism. Storm water run-off to surface water bodies is also a potential migration path. Leaching from contaminated soil to groundwater is possible but does not appear to be a major contaminant pathway. Wind blown movement of dust generated from contaminated surface soils is another possible migration pathway. • Some off-site properties are impacted. However, at this time it is not possible to attribute the material to TFM or the adjacent smelter. The principal and low level threat wastes for the Site consist of smelter operations debris, including: broken retorts, condensers, ash, and slag. These are considered “principal and low level threat wastes” because the contaminants of concern are found at concentrations that may pose a significant risk and are considered to be source material. What is a “Principle and Low Level Threat Waste?” Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained, or would present a significant risk to public health or the environment should exposure occur. Low level threat wastes are source materials that generally can be reliably contained and would present only a low risk in the event of a release. The decision to treat low level threat wastes is made on a site-specific basis through a detailed analysis of remedial alternatives using the nine remedy selection criteria specified in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and summarized in Table 3. This analysis provides the basis for making a statutory finding that the selected remedy uses a proven treatment technology as a principal element. The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by a site wherever practicable, and engineering controls such as containment for wastes that pose a relatively low, long-term threat or where treatment is impracticable (NCP Section 300.430(a)(1)(iii)(A)). The “principal threat” concept is applied to the characterization of “source materials” at a Superfund site. Source material is any material that includes or contains hazardous substances, pollutants or contaminants that act as a reservoir for migration of contamination to ground water, surface water, air, or acts as a source for direct exposure. Based on high levels of arsenic, cadmium, and lead detected in soil, sediment, and surface water samples, materials such as broken retorts and condensers, slag, and other smelter-related materials represent a primary source material at the Site. Although the contaminated soils present at the Site represent a source material, they are not characterized as a “principal threat waste” because the resulting soil contamination associated with this smelter materials can be reliably contained. However, because current and future public exposure to heavy metals present in soils at the Site exceeds EPA’s risk management criteria, treatment alternatives will be evaluated. 6 What is Risk and How is it Calculated? A CERCLA baseline human health risk assessment estimates the "baseline risk." This is an estimate of the likelihood of health problems occurring if no cleanup action were taken at a site. To estimate the baseline risk at a CERCLA site, EPA identifies a four-step process: Step 1: Identify Chemicals of Concern Step 2: Estimate Exposure Step 3: Assess Potential Health Effects Step 4: Characterize Site Risk In Step 1, the risk assessor compiles all the chemical data for a site to identify what chemicals were detected in each medium (i.e. soil and groundwater). Chemicals that are detected frequently at high concentrations, or are considered highly toxic, are considered “chemicals of concern” and are evaluated in the risk assessment In Step 2, the risk assessor considers the different ways that people might be exposed to the contaminants identified in Step 1, the concentrations that people might be exposed to, and the potential frequency and duration of exposure. Using this information, the risk assessor calculates a "reasonable maximum exposure" (RME) scenario, which portrays the highest level of human exposure that could reasonably be expected to occur. In Step 3, the risk assessor compiles toxicity information on each chemical, including numeric values for assessing cancer and noncancer adverse health affects. The EPA identifies two types of risk: cancer risk and noncancer risk. The likelihood of any kind of cancer resulting from a CERCLA site is generally expressed as an upper bound probability; for example, a "1 in 10,000 chance.” In other words, for every 10,000 people that could be exposed, one extra cancer may occur as a result of exposure to site contaminants. An extra cancer case means that one more person could get cancer than would normally be expected to from all other causes. For noncancer health effects, the risk assessor calculates a "hazard index." The key concept here is that a "threshold level" (measured usually as a hazard index of less than 1) exists below which noncancer health effects are no longer predicted. In Step 4, the risk assessor uses the exposure information from Step 2 and toxicity information form Step 3 to calculate potential cancer and noncancer health risks. The results are compared to EPA acceptable levels of risk to determine whether site conditions could potentially cause health problems for populations at or near the CERCLA site. The proposed remedial action would address the principal and low level threat at the Site. SCOPE AND ROLE OF THE ACTION This action, referred to as the Tulsa Fuel and Manufacturing Remedial Action, will be the final action for the Site. The Remedial Action Objectives (RAOs) for the Site are designed to prevent current and future exposure to contaminated media. SUMMARY OF SITE RISKS As part of the RI/FS, the DEQ conducted a baseline human health risk assessment (BHHRA) to determine the possible effects of contaminants on human health and the environment. The Site is currently vacant, and the future land use has not been decided; therefore, the site was evaluated as though recreational or residential development could occur in the future. Human Health Risk The human health risk assessment evaluated the potential for on- and off-site residential, industrial, and recreational populations to experience adverse health effects as a result of exposure to contaminants in soil, groundwater, surface water, sediment, and air. It was assumed that people could be exposed to site-related contaminants through direct contact, accidental ingestion, ingestion of blackberries or fish, and inhalation. The populations characterized for the risk assessment included adult and child residents, trespassers, outdoor commercial/industrial workers, construction/utility workers, and recreationists. Chemicals of potential concern (COPCs) were identified for each medium based upon comparison to published screening levels from the USEPA. Exposure to each COPC was evaluated for potential noncancer health effects, and for those chemicals that are potential carcinogens, the potential for causing cancer. Risk of noncancer health effects is determined by calculating hazard indices. The key concept here is that a "threshold level" exists below which noncancer health effects are no longer predicted. The USEPA level of concern for noncancer risk is a hazard index greater than one. The following populations had a calculated noncancer hazard index greater than one: 7 What are the “Chemicals of Concern”? The DEQ and EPA have identified 3 contaminants in soil, surface water, and sediment that pose the greatest potential risk to human health at this Site. The occurrence of the adverse effects described below depends on the chemical concentration and level of exposure. Metals are chemical elements that usually have luster, conduct heat energy and electricity, and bend without breaking. Metals found on the Site are by-products of the zinc smelting and lead roasting operations and consist of such things as slag, retorts, and sands. Arsenic: Arsenic is a naturally occurring element. Arsenic compounds are used as pesticides and for wood preservation. Arsenic is a Chemical of Concern (COC) for the soil and sediment on- and off-Site. The detected concentrations for arsenic ranged from nondetect to 1,170 mg/kg for on-site soil and from nondetect to 588 mg/kg for on-site sediment. Off-site, the detected concentrations of arsenic in soil ranged from nondetect to 538 mg/kg, and from nondetect to 341 mg/kg for sediment Cadmium: Cadmium is a naturally occurring element. Cadmium compounds are used in the production of batteries, plastics, and metal coatings. Cadmium is a COC for the soil, sediment, and surface water on- and off-site. The detected concentrations for cadmium ranged from nondetect to 1,620 mg/kg for on-site soil, from nondetect to 1,400 mg/kg for on-site sediment, and from nondetect to 184 μg/L for on-site surface water. Off-site, the detected concentrations of cadmium in soil ranged from nondetect to 193 mg/kg, from nondetect to 987 mg/kg for sediment, and from nondetect to 810 μg/L for surface water. Lead: Lead is a naturally occurring element. Lead has many different uses, including the production of batteries, ammunition, and metal products. Lead is a COC for the soil and sediment on- and off-Site. The detected concentrations for lead ranged from nondetect to 71,700 mg/kg for on-site soil and from 180 mg/kg to 8,150 mg/kg for on-site sediment. Off-site, the detected concentrations of lead in soil ranged from nondetect to 15,900 mg/kg and from 119 mg/kg to 5,080 mg/kg for sediment. • Future Adult and Child Residents – On-Site Waste and Non-Waste Areas • Future Outdoor Commercial/Industrial Worker – On-Site Waste Area • Future Construction/Utility Worker – On-Site Waste Area • Future Trespasser – On-Site Waste Area • Current and Future Off-Site Trespasser • Current Child Resident at Various Off-Site Residences • Current Adult and Child Residents at Various Off-Site Residences The USEPA’s target risk range for total excess lifetime cancer risk is 1 in 10,000 to one in a million. The total excess lifetime cancer risks for the populations that exceeded that range were: • Future Adult and Child Residents – On-Site Waste and Non-Waste Areas • Future Outdoor Commercial/Industrial Worker – On-Site Waste Area • Current Child and Adult Resident at Various Off-Site Residences Risk from exposure to lead is evaluated by modeling the potential level of lead that could occur in blood. Since children are the most sensitive to lead impacts, residential exposures are focused on children. Similarly, commercial/industrial exposures are focused on the fetuses of pregnant adult workers. Modeling results that show a greater than 5 percent chance of a blood lead concentration greater than 10 micrograms of lead per deciliter of blood are considered unacceptable. The predicted blood lead levels for the site were unacceptable in the following populations: • Future Adult and Child Residents – On-Site Waste and Non-Waste Areas • Future Outdoor Commercial/Industrial Worker – On-Site Waste Area • Future Construction/Utility Worker – On-Site Waste and Non-Waste Area 8 Figure 5 – Area of Concern for On-Site Soil and Waste • Current Child and Adult Resident at Various Off-Site Residences Ecological Risks An ecological risk assessment was conducted at the Site. The Site was evaluated for the presence of ecological receptors (plants and animals) and completed ecological exposure pathways to contaminants in surface and subsurface soil, surface water, sediment, and plant and fish tissue. Potentially completed exposure pathways identified at the Site included direct contact or ingestion of surface soils by plants and wildlife, direct contact or ingestion of surface water by plants and wildlife, and direct contact or ingestion of surface water sediments by wildlife. Additionally, area fish and wildlife could be exposed through bioaccumulation of Site related constituents in benthic invertebrates, aquatic and terrestrial invertebrates, aquatic and terrestrial plants, small mammal prey, and fish. Indicator species were selected to model and evaluate potential risk. These species were not always identified at the Site but habitat at the Site is suitable for these species. Analysis of the potentially completed exposure pathways from the Site shows that metals (arsenic, cadmium, lead, and zinc) present the greatest potential risk to plant and wildlife species. Of the terrestrial receptor species chosen for evaluation, the short-tailed shrew and the American Robin had the highest amounts of risk. Of the species that would have regular contact with surface water and sediment, the mallard and the great blue heron had the highest amount of risk. The areas and media resulting in unacceptable levels of ecological risk were analogous to areas and media with unacceptable human health risk. Since addressing human health risk will also address those areas posing ecological risk, the remainder of this Proposed Plan discusses Site cleanup in terms of the human health. REMEDIAL ACTION OBJECTIVES Remedial Action Objectives (RAOs) are the cleanup objectives for protection of human health and the environment. Site-specific preliminary remediation goals (PRGs) are the desired endpoint concentrations for each exposure route that are believed to provide adequate protection of human health and the environment. In this case a Hazard Index of 1 or in excess of 3 in every 100,000 excess cancer risk. RAOs and PRGs were developed for the Site by taking into account media, exposure pathways, COCs, and PRGs. PRGs for each medium (soil, sediment, and surface water) are summarized in Table 1 above. Areas of Concern (AOCs) are areas on the Site that require remediation based upon the RAOs and PRGs. The RAOs and AOCs for the Site by medium are: Table 1 Site-Specific PRGs by Medium COC Site-Specific PRG Soil, Residential (mg/kg) or (ppm) Arsenic 37 Cadmium 75 Lead 500 Soil, Nonresidential (mg/kg) or (ppm) Arsenic 200 Cadmium 560 Lead 1,000 Sediment (mg/kg) or (ppm) Arsenic 181 Cadmium 813 Lead 500 Surface Water (μg/L) or (ppm) Cadmium 238 9 Figure 6 – Areas of Concern for Sediment and Surface Water Soil and Waste Materials • Protect human health by preventing direct contact, through the ingestion and inhalation exposure pathways with arsenic, cadmium, and lead contaminated on-site and off-site soil and waste material by reducing arsenic, cadmium, and lead concentrations to residential levels less than 37 ppm, 75 ppm, and 500 ppm, or to nonresidential levels less than 200 ppm, 560 ppm, and 1,000 ppm respectively. AOCs for soil are shown on the previous page Figure 5. Sediment • Protect human health and the environment by preventing direct contact, through the ingestion pathway, with arsenic, cadmium, and lead contaminated sediment by reducing arsenic, cadmium, and lead concentrations to levels less than 181 ppm, 813 ppm, and 500 ppm, respectively. AOCs for sediment are shown on Figure 6. Surface Water • Protect human health and the environment by preventing direct contact, through the ingestion pathway, with cadmium contaminated surface water by reducing cadmium concentrations to levels less than 238 ppm. AOCs for surface water are shown on Figure 6. SUMMARY OF REMEDIAL ALTERNATIVES Remedial alternatives for the Tulsa Fuel and Manufacturing Site are presented in Table 2 (next page) and discussed in the following paragraphs. The alternatives are numbered to correspond with the numbers in the FS Report. These technologies were evaluated for practicality (effectiveness and implement ability) and cost. Technologies that were not practical or cost-effective were removed from further consideration. The remaining technologies were then reviewed to identify combinations that would address all aspects of each AOC’s contamination (Figures 5 and 6). These combinations are referred to as remedial alternatives. The following remedial alternatives were developed for the AOCs at the Site. Common Element The following paragraph identifies the common element of the alternatives except for Remedial Alternative 1 - No Action and Alternative 3 – Stabilization and Off-Site Disposal at a RCRA-Permitted Facility. The Common Element will achieve applicable RAOs. This element may be compatible with residential land. Institutional Controls (ICs) – The ODEQ will file a recordable notice of remediation taken pursuant to CERCLA in the land records of the county in which the site is located. The notice will contain a legal description of the affected property and will identify all engineering controls used to ensure the effectiveness of the remediation. Additionally, the notice will contain a prohibition against engaging in any activities that could cause damage to the remedial action or to the engineering controls or that could cause recontamination of the soil or groundwater. The notice will contain appropriate restrictions on land use or other activities that are incompatible with the cleanup levels, including but not limited to restrictions against using groundwater for drinking or irrigation purposes or redeveloping the land for residential use. The ODEQ has authority to take administrative or civil action to recover costs from or to compel compliance with this notice against any person who damages or interferes with the remediation, engineering controls 10 or continuing operation, maintenance or monitoring of the site. Alternative 1 – No Action Estimated Capital Cost - $0 Estimated Annual O&M Cost - $0 Estimated Present Value Cost - $83,188 Estimated Construction Timeframe – None Regulations governing the Superfund program generally require that the “no action” alternative be evaluated to establish a baseline for comparison. Under this alternative, the DEQ and EPA would take no action at the Site or at off-site properties to prevent exposure to the soil, sediment, and other Site-related contamination. All remedial alternatives, except the “no action” alternative, are expected to attain the RAOs and meet appropriate waste disposal regulations. Selection of the “no action” alternative would mean that the RAO’s would not be met and possible exposure of COC could occur to current and future human receptors and ecological receptors. By leaving the impacted soil and waste materials in-place, a formal review of the Site will be required every 5 years. Conducting remedy reviews is assumed to include monitoring of all media and wastes remaining on the Site. Costs associated with this “no action” alternative include conducting five-year reviews with associated groundwater monitoring and a Site Closure Report. Soil: On-Site Soil and Waste Materials Areas (This is DEQ’s preferred remedial alternative for on-site soil and waste material areas) • Alternative 2 - Consolidation and Cap Estimated Capital Cost – $5,293,802 Estimated Annual O&M Cost - $55,174 - $69,556 Estimated Present Value Cost - $3,130,145 – $5,724,924 Estimated Construction Timeframe – 20 weeks Estimated Time to Achieve RAOs – 20 weeks For this Alternative approximately 164,000 cubic yards of soil and waste materials on the Site would be capped. Several consolidation and capping options were evaluated. Several consolidation and capping options were evaluated and the specific design and cost of will be determined during the Remedial Design. Cost estimates for each option are detailed in the FS; for estimating purposes, the highest estimate is present here. Each of the capping scenarios would minimize surface exposure, prevent infiltration of water that could create contaminated leachate, and prevent transport of wastes by erosion. Periodic maintenance would be required to maintain the integrity of the cap. ICs for this preferred remedial alternative for soil and waste material would include prohibition of activities that would damage the cap such as plowing, digging, drilling, trenching or other earth movement. Shallow-root gardening for human consumption would also be prohibited. Groundwater use restrictions may include but not be limited to restrictions against using groundwater for drinking or irrigation purposes. Other land use restrictions and engineering controls may be developed as the work on the site progresses. The DEQ will monitor and maintain the vegetation and soil to prevent erosion or movement of the cap to prevent exposure of metals-contaminated soil to humans and the TABLE 2 SUMMARY OF REMEDIAL ALTERNATIVES TULSA FUEL AND MANUFACTURING SITE FS Designation Description SOIL: On-Site Soil and Waste Materials Areas 1 No Action 2 Consolidation and Cap 3 Stabilization and Off-Site Disposal at a RCRA-Permitted Facility 4 On-Site Fixation or Stabilization and On-Site Disposal SOIL, SEDIMENT, and WASTES: Off-Site Locations 1 No Action 2 Excavation, Stabilization (as needed) and Disposal at TFM 3 Excavation, Stabilization (as needed) and Off-Site Disposal at a RCRA-Permitted Facility SEDIMENT and SURFACE WATER: On-Site Ponds, Mid-Site Ravine, and Strip Mine Pit 1 No Action 2 Stabilization and Off-Site Disposal at a RCRA-Permitted Facility 3 On-Site Fixation or Stabilization and On-Site Disposal SURFACE WATER 1 No Action 11 environment. Also refer to Common Elements. Post-closure groundwater monitoring would be conducted to detect movement of contaminants leaching from the capped area and to verify the cap retains its integrity. Every 5 years a formal review of the remedy will be required to ensure that it is protective. This alternative will achieve applicable RAOs and meet PRGs. The capping scenarios that were evaluated include: • Alternative 2 – Scenario 5-2, 25 Acre Cap • Alternative 2 – Scenario 5-2a – 5-2d, 10 Acre Cap The above capping scenarios were evaluated to look at the cost associated with various sizes, types, and depths of caps and liners. • Alternative 3 – Stabilization and Off-Site Disposal at a RCRA-Permitted Facility Estimated Capital Cost - $31,879,532 Estimated Annual O&M Cost - $52,500 Estimated Present Value Cost - $32,014,734 Estimated Construction Timeframe – 32 weeks Estimated Time to Achieve RAOs – 32 weeks For this Alternative, approximately 164,000 cubic yards of contaminated soil and waste materials would be excavated, stabilized, and loaded onto trucks or railcars, and transported to an off-site permitted waste landfill for disposal. The off-site landfill would need to meet regulatory requirements for this type of waste. This alternative would permanently remove contaminated material from the Site and is a proven and acceptable practice that reduces the risk posed by hazardous substances. This alternative will achieve applicable RAOs and meet PRGs. • Alternative 4 – On-Site Fixation or Stabilization and On-Site Disposal Estimated Capital Cost - $13,177,831 Estimated Annual O&M Cost - $49,174 Estimated Present Value Cost - $13,534,509 Estimated Construction Timeframe – 30 weeks Estimated Time to Achieve RAOs – 30 weeks Alternative 4 involves excavating approximately 164,000 cubic yards of contaminated soil and waste materials for placement in an on-site disposal cell. The excavated areas would be backfilled with clean soil. The disposal cell would consist of a clay liner and composite liner with leachate collection. Contaminated soil that is determined to be hazardous by characteristic or is wet would be stabilized so the fill material would be acceptable for placement in the cell. The cell would be capped with compacted clay and topsoil. Capping would minimize surface exposure, prevent infiltration of water that could create contaminated leachate, and prevent transportation of wastes by erosion. Periodic maintenance would be conducted to maintain the integrity of the cap. ICs for this remedial alternative would include prohibition of shallow-root gardening for human consumption and all activities that would damage the cap such as plowing, digging, drilling, trenching or other earth movement. Prohibitions against using groundwater for drinking or irrigation purposes may be included. Vegetation and soil will be monitored and maintained to prevent erosion or movement of the cap. Also refer to Common Elements. Post-closure groundwater monitoring would be conducted to determine if the cell and its contents were impacting the groundwater beneath the disposal cell and to verify the cap retains its integrity. Every 5 years a formal review of the remedy will be required to ensure that it is protective. This alternative will achieve applicable RAOs and meet PRGs. Sediment and Surface Water: On-Site Ponds, Mid-Site Ravine, and Strip Mine Pit (This is DEQ’s preferred remedial alternative for on-site ponds, mid-site ravine, and strip mine pit) • Alternative 2 – On-Site Fixation or Stabilization and On-Site Disposal Estimated Capital Cost - $1,183,928 Estimated Annual O&M Cost - $49,174 Estimated Present Value Cost - $1,540,606 Estimated Construction Timeframe – 30 weeks Estimated Time to Achieve RAOs – 30 weeks Alternative 2 would remove approximately 33,000 cubic yards of metals impacted sediment in the on-site surface water features. The surface water features would be drained and treated if needed, with measures taken to retain sediments within the AOC. The sediment would be dewatered and stabilized, and excavated for loading and transport to the consolidation area or on-site disposal cell. 12 After sediment removal, the surface water features would be backfilled with clean soil and regraded. The consolidation area or on-site disposal cell would be capped with compacted clay and topsoil. Capping would minimize surface exposure, prevent infiltration of water that could create contaminated leachate, and prevent transportation of wastes by erosion. Periodic maintenance would be conducted to maintain the integrity of the cap. ICs for this preferred remedial alternative for sediment and surface water would include prohibition of all activities that would damage the cap such as plowing, digging, drilling, trenching or other earth movement and shallow-root gardening for human consumption. Prohibitions against using groundwater for drinking or irrigation purposes are possible. Other land use restrictions and engineering controls may be developed as the work on the site progresses The DEQ will monitor and maintain vegetation and soil to prevent erosion or movement of the cap. Also refer to Common Elements. Post-closure groundwater monitoring would be conducted. Every 5 years a formal review of the remedy will be required to ensure that it is protective. This alternative will achieve applicable RAOs and meet PRGs. Surface water features not requiring remediation would be left as is. • Alternative 3 – Stabilization and Off-Site Disposal at a RCRA-Permitted Facility Estimated Capital Cost - $1,854,238 Estimated Annual O&M Cost - $52,500 Estimated Present Value Cost - $1,989,440 Estimated Construction Timeframe – 32 weeks Estimated Time to Achieve RAOs – 32 weeks Alternative 3 would remove approximately 33,000 cubic yards of metals impacted sediment in the on-site surface water features. The surface water features would be drained, with measures taken to retain sediments within the AOC. The sediment would be dewatered, excavated, and stabilized for loading and transport to an off-site permitted waste landfill for disposal. The off-site landfill would meet regulatory requirements for this type of waste. This alternative would permanently remove contaminated material from the Site and is a proven and acceptable practice that reduces the risk posed by hazardous substances. This alternative will achieve applicable RAOs and meet PRGs. Surface water features not requiring remediation would be left as is. Soil, Sediment, and Wastes: Off-Site Locations Additional investigations may be conducted offsite to determine nature and extent of contamination. Currently, those efforts are not part of this remedial action. Future investigation and remediation efforts may remain separate and be conducted by an interested third party and/or PRPs; or residential contamination may be incorporated into this remedial response through an amended ROD or an Explanation of Significant Difference (ESD). (This is DEQ’s preferred remedial alternative for off-site areas) • Alternative 2 – Excavation, Stabilization, and Disposal at TFM Estimated Capital Cost - $331,213 Estimated Annual O&M Cost - $0 Estimated Present Value Cost - $376,986 Estimated Construction Timeframe – 12 weeks Estimated Time to Achieve RAOs – 12 weeks For this Alternative, approximately 1,600 cubic yards of contaminated soil and waste materials would be excavated, stabilized (as needed), loaded onto trucks, and transported to the Site for disposal within a capped consolidation area or on-site disposal cell. The excavated areas would be backfilled with clean soil. This Alternative would permanently remove contaminated material from the off-site areas and is a proven and acceptable practice that reduces the risk posed by hazardous substances. This alternative will achieve applicable RAOs and meet PRGs. ICs for this preferred remedial alternative for off-site locations would include prohibition of activities that would damage the cap such as plowing, digging, drilling, trenching or other earth movement. Shallow-root gardening for human consumption would also be prohibited. Groundwater use restrictions may include but not be limited to restrictions against using groundwater for drinking or irrigation purposes. Other land use restrictions and engineering controls may be developed as the work on the site progresses. The DEQ will monitor and maintain the vegetation and soil to prevent erosion or movement of the cap to prevent exposure of metals-contaminated soil to humans and the environment. Also refer to Common Elements. 13 • Alternative 3 – Excavation, Stabilization, and Off- Site Disposal at a RCRA-Permitted Facility Estimated Capital Cost - $706,680 Estimated Annual O&M Cost - $0 Estimated Present Value Cost - $760,989 Estimated Construction Timeframe – 12 weeks Estimated Time to Achieve RAOs – 12 weeks With this Alternative, approximately 1,600 cubic yards of contaminated soil and waste materials would be excavated, stabilized (as needed), and loaded onto trucks and transported to an off-site permitted waste landfill for disposal. The off-site landfill would meet regulatory requirements for this type of waste. The excavated areas would be backfilled with clean soil. This Alternative would permanently remove contaminated material from the off-site areas and is a proven and acceptable practice that reduces the risk posed by hazardous substances. This alternative will achieve applicable RAOs and meet PRGs. TABLE 3 Evaluation Criteria for CERCLA Remedial Alternatives Overall Protection of Human Health and Environment determines whether an alternative eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or treatment. Compliance with ARARs evaluates whether the alternative meets Federal and State environmental statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified. Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the environment over time. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the amount of contamination present. Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to workers, residents, and the environment during implementation. Implementability considers the technical and administrative feasibility of implementing the alternative, including factors such as the relative availability of goods and services. Cost includes estimated capital, periodic, and annual operations and maintenance (O&M) costs, as well as present worth cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are expected to be accurate within a range of +50 to - 30 percent. State/Support Agency Acceptance considers whether the DEQ and USEPA agree with the analyses and recommendations, as described in the RIA/FSA and Proposed Plan. Community Acceptance considers whether the local community agrees with DEQ's analyses and preferred alternative. Comments received on the Proposed Plan are an important indicator of community acceptance. 14 EVALUATION OF REMEDIAL ALTERNATIVES Nine criteria are used to evaluate remedial alternatives individually and against each other in order to select a remedy. This section of the Proposed Plan profiles the relative performance of each alternative against the nine criteria, noting how is compares to the other options under consideration. This nine evaluation criteria are discussed below. The “Detailed Analysis of Alternatives” can be found in the FS Report. 1. Overall Protection of Human Health and the Environment – All of the alternatives except the “no action” alternative would provide adequate protection of human health and the environment by eliminating, reducing, or controlling risk through treatment, containment, engineering controls, and/or institutional controls. Because the “no action” alternative is not protective of human health and the environment, it was eliminated from consideration under the remaining eight criteria. An exception was made for the surface water medium. “No action” was the only alternative retained for surface water. Since on-site Ponds 1 through 5 would be removed from service and would no longer exist, surface water remediation is not needed for these ponds. In addition, dredging and/or removal of waste materials and contaminated sediment from the Strip Mine Pit and other off-site drainages will remove materials that could potentially impact surface water at these locations. 2. Compliance with ARARs – All of the alternatives would meet their respective ARARs from Federal and State Laws. Transportation of wastes under the alternatives with off-site disposal will have to be conducted pursuant to Federal and State transportation regulations. Facilities accepting these wastes would have to be certified to accept the respective wastes. 3. Long-term Effectiveness and Permanence Soil: On-Site Soil and Waste Materials Areas All of the considered alternatives provided similar long-term effectiveness. Alternative 2 (capping) and Alternative 4 (stabilization and on-site disposal cell) would prevent direct contact exposure and contaminant migration; however, monitoring and maintenance would be necessary to ensure the long-term effectiveness and permanence of these alternatives. Alternative 3 (off-site disposal) would prevent direct contact exposure, contaminant migration, and reduce the inherent hazards posed by the contaminants at the Site. Additionally, Alternative 3 would maximize reuse of the Site. Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit Each of the considered alternatives provided similar long-term effectiveness. Alternative 2 (excavation, stabilization, and off-site disposal) permanently removes contaminated sediments from the Site. Alternative 3 (stabilization and on-site disposal) would prevent direct contact exposure and contaminant migration; however, monitoring and maintenance would be necessary to ensure the long-term effectiveness and permanence of Alternative 3. Soil, Sediment, and Wastes: Off-Site Locations All of the considered alternatives provided similar long-term effectiveness. Alternative 2 (excavation and disposal at the TFM Site) and Alternative 3 (excavation and off-site disposal at a landfill) removes contaminated materials from the off-site properties and prevent direct contact exposure and contaminant migration. Since contaminants are removed, monitoring and maintenance would not be required to ensure long-term effectiveness and permanence of these alternatives. 4. Reduction of Toxicity, Mobility, or Volume of Contaminants Soil: On-Site Soil and Waste Materials Areas Each of the alternatives provides reduction of the mobility of the contaminants through the use of a physical barrier to prevent contact of the contaminants with the environment. Alternative 4 (stabilization and on-site disposal cell) and Alternative 3 (off-site disposal) further reduce the mobility and toxicity of the contaminants by treatment of soil and wastes, as needed, so that materials are no longer considered hazardous by characteristic. Alternative 3 (off-site disposal) does not reduce the toxicity and volume of the contaminants; however, the volume of contaminated materials on-site will be transferred to a permitted off-site disposal facility. None of the alternatives achieve a reduction or volume. Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit 15 Each of the alternatives provides reduction of the mobility of the contaminants through the use of a physical barrier to prevent contact of the contaminants with the environment. Alternative 2 (excavation, stabilization, and off-site disposal) and Alternative 3 (stabilization and on-site disposal) further reduce the mobility and toxicity of the contaminants by treatment of soil and wastes, as needed, so that materials are no longer considered hazardous by characteristic. Neither of the alternatives reduces toxicity and volume of the contaminants; however, the volume of contaminated sediment on-site would be transferred to an off-site disposal facility as part of Alternative 2. Neither of the alternatives achieves reduction of volume. Soil, Sediment, and Wastes: Off-Site Locations Each of the alternatives provides reduction of the mobility of the contaminants through the use of a physical barrier to prevent contact of the contaminants with the environment. Alternative 2 (excavation and disposal at the TFM Site) and Alternative 3 (excavation and off-site disposal at a landfill) further reduce the mobility and toxicity of the contaminants by treatment of soil and wastes, as needed, so that materials are no longer considered hazardous by characteristic. Neither of the alternatives reduces the volume of the contaminants; however, the volume of contaminated materials for the off-site locations would be transferred either to the TFM Site (Alternative 2) or an off-site disposal facility (Alternative 3). 5. Short-Term Effectiveness Soil: On-Site Soil and Waste Materials Areas Alternative 2 (capping) would provide better short-term effectiveness because the cap could be constructed faster than excavating and stabilizing material for movement to an on-site disposal cell (Alternative 4) or off-site disposal facility (Alternative 3). Alternative 2, Scenario 5-2 (capping in place) does not present a short-term threat except to the extent that the area presents direct contact or migration potential during the time it takes to fully implement the remedy. The remaining alternatives involve the consolidation or excavation of wastes and contaminated soils and thus present a potential for short-term exposure. Additionally, these alternatives pose potential risks to construction workers and nearby residents during excavation and handling of contaminated materials. Control of dust and runoff during remedial activities will limit the amount of materials that may migrate to a potential receptor. In addition, workers would be required to wear the appropriate level of protection to avoid exposure during excavation and treatment activities. Alternative 3 may pose a higher short-term risk to the nearby residents because of the potential for exposure to the contaminated soils by trucking the material to an off-site facility. Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit Both alternatives have similar short-term effectiveness. Both alternatives involve the excavation of contaminated sediments and thus present a potential for short-term exposure as previously described. Soil, Sediment, and Wastes: Off-Site Locations Both alternatives have similar short-term effectiveness. Both alternatives involve the excavation of wastes and contaminated soils and thus present a potential for short-term exposure as previously described. 6. Implementability For all alternatives, administrative coordination, labor, equipment, materials, and outside services will be required. These alternatives utilize conventional material and equipment which are widely used and accepted in the construction industry. Institutional controls such as deed notices will be placed on land parcels that are contained in the site boundary by DEQ under Oklahoma Statute 27A O.S. §2-7-123. 7. Cost Soil: On-Site Soil and Waste Materials Areas The estimated present worth cost for Alternative 2 (capping) is less than Alternative 3 (stabilization and on-site disposal cell) for all capping scenarios that were reviewed. Alternative 4 (off-site disposal) is the most costly; however, the alternative requires only minimal O&M costs. Alternatives 2 and 3 have more expensive O&M required for 30 years. Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit The estimated present worth for Alternative 3 (stabilization and on-site disposal) is less than Alternative 2 (excavation, stabilization, and off-site disposal). 16 Soil, Sediment, and Wastes: Off-Site Locations The estimated present worth cost for Alternative 2 (excavation and disposal at the TFM Site) is less than Alternative 3 (excavation and off-site disposal at a landfill). While Alternative 3 is the most expensive, contaminated materials would not be brought onto the Site. 8. State/Support Agency Acceptance The State of Oklahoma supports the Preferred Alternative. The EPA as the support Agency accepts the Preferred Alternative, contingent upon the Public Comment Period. 9. Community Acceptance Community acceptance of the Preferred Alternative will be evaluated after the public comment period ends and will be described in the responsiveness summary of the Site Record of Decision. SUMMARY OF PERFERRED REMEDIAL ALTERNATIVES Soil and Waste Materials: On-Site Soil and Waste Materials Areas Consolidation and cap, of approximately 164,000 cubic yards of material Estimated Capital Cost – $5,293,802 Sediment and Surface Water: On-Site Ponds, Mid- Site Ravine, and Strip Mine Pit On-Site Fixation or Stabilization and On-Site Disposal, of approximately 33,000 cubic yards of material Estimated Capital Cost - $1,183,928 Soil, Sediment, and Waste Materials: Off-Site Locations Excavation, Stabilization, and Disposal at TFM Off-Site Estimated Total Capital Cost - $331,213 Based on the information available at this time, the State of Oklahoma and the USEPA believe the Preferred Alternative would be protective of human health and the environment, would comply with ARARs, and would utilize permanent solutions to the maximum extent practicable. The Preferred Alternative can change in response to public comment or new information. COMMUNITY PARTICIPATION The DEQ and USEPA provide information regarding the cleanup of the Tulsa Fuel and Manufacturing Site to the public through public meetings, the Administrative Record file for the Site, and announcements published in the Collinsville News. The DEQ and USEPA encourage the public to gain a more comprehensive understanding of the Site and the Superfund activities that have been conducted at the Site. The date, location, and time of the public meeting, the dates for the public comment period, and the locations of the Administrative Record file, are provided on the front page of this Proposed Plan. For further information on the Tulsa Fuel and Manufacturing Superfund Site, please visit the locations identified on Page 1 to view various site documentation or contact: Ms. Sara Downard Mr. Michael Torres Project Manager Remedial Project Manager Oklahoma DEQ EPA Region 6 707 N. Robinson, PO Box 1677 1445 Ross Avenue Oklahoma City, OK 73101 Dallas Texas, 75202 (405) 702-5126 (214) 665-2108 Sara.Downard@deq.state.ok.us torres.michael@epa.gov 17 ACRONYMS AOC Area of Concern ARARs Applicable or Relevant and Appropriate Requirements ATSDR Agency for Toxic Substances and Disease Registry BHHRA Baseline Human Health Risk Assessment CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COPC Contaminants of Potential Concern COC Contaminants of Concern DEQ Oklahoma Department of Environmental Quality USEPA United States Environmental Protection Agency, Region VI FS Feasibility Study HRS Hazard Ranking System mg/kg Milligrams per kilogram NCP National Oil and Hazardous Substance Pollution Contingency Plan NPL National Priority List PA Preliminary Assessment PRGs Preliminary Remedial Goals PRP Potentially Responsible Party ROD Record of Decision RAOs Remedial Action Objectives RI Remedial Investigation RCRA Resource Conservation and Recovery Act RME Reasonable Maximum Exposure SI Site Inspection Site Tulsa Fuel and Manufacturing Superfund Site μg/L Microgram per Liter GLOSSARY OF TERMS Specialized terms used in this Proposed Plan are defined below: Administrative Record – The body of documents available to the public associated with characterization and remedy selection at a site. Applicable or Relevant and Appropriate Requirements (ARARs) – The Federal and State environmental laws that a selected remedies will meet. These requirements may vary among sites and alternatives. Baseline Human Health Risk Assessment (BHHRA) – An evaluation of the potential threat to human health and the environment in the absence of any remedial action. Carcinogen – Capable of causing the cells of an organism to react in a manner to produce cancer. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) – CERCLA was enacted by Congress on December 11, 1980. This law created a tax on the chemical and petroleum industries and provided broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. Ecological Risk Assessment – Study that assesses risks to aquatic and terrestrial receptors posed by contaminant releases from a site. Excess Lifetime Cancer Risk - Cancer posed by a contaminated site in excess of the lifetime probability of developing cancer from other causes. Feasibility Study (FS) – Identifies and evaluates the appropriate technical approaches and treatment technologies to address contamination at a site. Groundwater – Underground water that fills pores in soils or openings in rocks to the point of saturation. Groundwater is often used as a source of drinking water via municipal or domestic wells. Groundwater Monitoring – Ongoing collection of groundwater information about the environment that helps gauge the effectiveness of a clean-up action. Human Health Risk Assessment – A study that determines and evaluates risk that site contamination poses to human health. Institutional Controls – Actions taken to limit transporting, treating, storing, and disposing of unauthorized access to the site, control the way in hazardous waste. which an area of the site is used, and monitor contamination migration. Microgram per Liter (μg/L) - A unit of measurement equivalent to one microgram of contaminant per liter of water. Milligram per Kilogram (mg/kg) - A unit of measurement equivalent to one milligram of contaminant per kilogram of solid (typically soil). National Oil and Hazardous Substance Pollution Contingency Plan (NCP) – Regulations governing cleanups under USEPA’s Superfund program. Preferred Alternative – Final remedial alternative that meets NCP evaluation criteria and is supported by regulatory agencies. Present Value Cost – A method of evaluation of expenditures that occur over different time periods. By discounting all costs to a common base year, the costs for different remedial action alternatives can be compared on the basis of a single figure for each alternative. When calculating present worth cost for Superfund sites, total operations & maintenance costs are to be included. Remedial Action – Action(s) taken to correct or remediate contamination. Remedial Action Objectives (RAOs) – Remediation objectives for protection of human health and the environment. Record of Decision (ROD) – A formal document that is a consolidated source of information about a Superfund site, the remedy selection process, and the selected remedy. Receptor – An organism that receives, may receive, or has received environmental exposure to a chemical. Remedial Investigation (RI) – A study conducted to identify the types, amounts, and locations of contamination at a site. Resource Conservation and Recovery Act (RCRA) – The Federal act that established a regulatory system to track hazardous wastes from the time they are generated to their final disposal. RCRA also provides for safe hazardous waste management practices and imposes standards for 18 Reasonable Maximum Exposure (RME) - The highest level of human exposure that could reasonably be expected to occur. 19 Name Address___________________________ City______________________________ State___________Zip________________ USE THIS SPACE TO WRITE YOUR COMMENTS Your input on the Proposed Plan for the Tulsa Fuel and Manufacturing Site is important to the DEQ and EPA. Comments provided by the public are valuable in helping the DEQ and EPA select a final cleanup remedy for the Site. You may use the space below to write your comments, then fold and mail. Comments must be postmarked by July 30, 2008. If you have any questions about the comment period, please contact Sara Downard at (405) 702-5126, Michael Torres at (214) 665-2108, or through EPA’s toll-free number at 1-800-533-3508. Those with electronic communications capabilities may submit their comments to the DEQ or EPA via Internet at the following e-mail addresses: Sara.Downard@deq.state.ok.us or Torres.Michael@epa.gov. |
| Date created | 2012-01-30 |
| Date modified | 2012-01-30 |
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