Five-Year Review Report · PDF fileof the Sand Springs Petrochemical Complex Five-Year Review Report prepared by ARCO on ... Super-fund Division ... iv EXECUTIVE SUMMARY

Five-Year Review Report

First Five Year Review Report

For

Sand Springs Petrochemical Complex

City of Sand Springs

Tulsa County, Oklahoma

September 2000

Prepared By

Region 6

United States Environmental Protection AgencyDallas, Texas

146437

FIVE-YEAR REVIEW

Sand Springs Petrochemical ComplexOKD980748446

Sand Springs, Oklahoma

This memorandum documents U.S. Environmental Protection Agency's (EPA) approvalof the Sand Springs Petrochemical Complex Five-Year Review Report prepared by ARCO onbehalf of EPA.

Summary of Five-Year Review Findings

Old petroleum refinery acidic sludges (Source Control Operable Unit) were treated byChemical Solidification/Stabilization process and placed in an on-site RCRA Subtitle C landfill.Glen Wynn lagoon sludges were incinerated at an off-site facility. The landfill has been effectivein preventing the infiltration of precipitation and direct contact with the treated wastes.The Main Site Operable Unit (groundwater) were impacted by unknown historical sourcesupgradient of the site. Since those sources no longer exist, the groundwater should attenuatenaturally over time. However, monitoring of groundwater will continue for 30 years.

Actions Needed

The landfill is protected by fencing and institutional control and should preventunauthorized entry or use of the landfill. The landfill should be inspected periodically to repairany erosion or stressed vegetation to maintain the integrity of the RCRA cap.

Determinations

I have determined that the remedy for the Sand Springs Petrochemical Complex isprotective of human health and the environment.

//yi^/wiL r^^yl̂ ^. f———9——————"T"""" Xf^ '"——7 ' "——TT—f——————•—————————

Myron 0. Knudson, P.EC}DirectorSuper-fund DivisionU.S. Environmental Protection AgencyRegion 6

^7^' D a t e

CONCURRENCES

FIVE-YEAR REVIEW

for the

Sand Springs Petrochemical Complex

ShawnGhoseM.S.,P.E.Remedial Project Manager

^L/7 /^}^^ ^ ̂ ̂aul W e n d e l TPaul Wendel

Staff Attorney

I „ Gus Chavarria•^ Chief, Project Management Section

Superfund Division

\^W^. Honker, P.E.& Chief, AR/OK/TX Branch

Superfund Division

Mark PeyckeChief, Superfund BranchOffice of Regional Counsel

Pamela PhillipsDeputy DirectorSuperfund Division

TABLE OF CONTENTS

LIST OFACRONYMS............................................................................................................ iv

EXECUTIVESUMMARY......................................................................................................... vFIVE-YEAR REVIEW SUMMARYFORM.............................................................................vii

I. INTRODUCTION......................................................................................................1

II. SITE CHRONOLOGY..............................................................................................2

III. BACKGROUND .......................................................................................................3A. LOCATION...............................................................................................................3B. HISTORY.................................................................................................................3

IV. REMEDIAL ACTIONS..............................................................................................4C. REMEDY SELECT10N................................................................................................4D. REMEDY IMPLEMENTATION.......................................................................................6

a. Source Control Operable Unit........................................................................6b. Main Site Operable Unit..................................................................................8

E. SYSTEM OPERAT10NS..............................................................................................8

V. FIVE-YEAR REVIEW PROCESS...........................................................................13

VI. FIVE-YEAR REVIEW FINDINGS ...........................................................................14F. INTERVIEWS..........................................................................................................14G. SITEINSPECTION...................................................................................................14H. RISK INFORMATION REVIEW...................................................................................15I. DATAREVIEW.......................................................................................................16

VII. ASSESSMENT ...................................................................................................16

VIII. DEF1CIENCIES...................................................................................................18

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS.......................................... 19

X. PROTECTIVENESS STATEMENTS ..................................................................... 20

XI. NEXT FIVE-YEAR REVIEW...................................................................................20

11

Tables

TABLE 1: Chronology of Site EventsTABLE 2: Summary of 1998 and 1999 Leachate Collection System Pumping DataTABLE 3: Leachate Collection System, 1998 and 1999 GPAD CalculationsTABLE 4: Water Level Data and Detected LNAPL Thickness

Attachments

Attachment 1: Documents ReviewedAttachment 2: Site Maps,Attachment 3: List of Constituents for Ground Water MonitoringAttachment 4: Summary of Laboratory Analytical Results

111

List of AcronymsARARs Applicable or Relevant and Appropriate RequirementsCA Cooperative AgreementCD Consent DecreeCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCERCLIS Comprehensive Environmental Response, Compensation, and Liability

Information SystemCFR Code of Federal RegulationsDoD Department of DefenseDOE Department of EnergyEO Executive OrderEPA United States Environmental Protection AgencyFCOR Final Close Out ReportFFA Federal Facility AgreementFFRRO Federal Facilities Restoration and Reuse OfficeFR Federal RegisterHASP Health and Safety PlanIAG Interagency AgreementIRIS Integrated Risk Information SystemMCLs Maximum Contaminant LevelsNCP National Oil and Hazardous Substances Pollution Contingency PlanNPL National Priorities ListO&M Operation and MaintenanceOERR Office of Emergency and Remedial ResponseOSHA Occupational Safety and Health AdministrationOSWER Office of Solid Waste and Emergency ResponseOU Operable UnitPRP Potentially Responsible PartyRA Remedial ActionRAGS Risk Assessment Guidance for SuperfundRCRA Resource Conservation and Recovery ActRD/RA Remedial Design/Remedial ActionRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionRPM Remedial Project ManagerSARA Superfund Amendments and Reauthorization Act of 1986SMOA Superfund Memorandum of AgreementSPIM Superfund Program Implementation ManualTBCs To Be ConsideredsUSACE United States Army Corps of Engineersu,g/l microgram per liter

IV

EXECUTIVE SUMMARY

This is the first five-year review for the Sand Springs Petrochemcial Complex located inTulsa County in Sand Springs, Oklahoma. The results of the five-year review indicatethat the remedy is protective of human health and the environment. The RCRA SubtitleC landfill and the ground water monitoring system are functioning as designed and arein good condition. Some minor deficiencies were noted that do not affect theprotectiveness of the remedy.

The remedies that were implemented for the Source Control Operable Unit and theMain Site Operable Unit continue to be protective of human health and theenvironment. Since the remedies for both operable units are protective of humanhealth and the environment, the remedy for the site is protective of human health andthe environment.

Source Control Operable Unit

The remedy that was implemented for the Source Control Operable Unit is protective ofhuman health and the environment. The RCRA Subtitle C landfill has been effective inpreventing the infiltration of precipitation and direct contact with treated wastes.Perimeter fencing and institutional controls at the landfill are in place and are effectivein preventing unauthorized entry or use of the landfill. The landfill is in good conditionand is inspected and maintained on a regular basis.

Main Site Operable Unit

The remedy that was implemented for the Main Site Operable Unit is protective ofhuman health and the environment. The ground water continues to be impactedupgradient of the site from unknown historical sources. Since those sources no longerexist, the ground water should continue to naturally attenuate over time.

v

Five Year Review Summary FormSITE IDENTIFICATION

Site Name: Sand Springs Petrochemical ComplexEPAID: OKD980748446Region: 6 | State: Oklahoma | City/County: Sands Springs

SITE STATUSNPL Status | 0 Final | ® Deleted | 0 Other (specify)Remediation Status(choose all that 0 Under 0 Operatingapply) ConstructionMultiple <S) YES 0 NO Construction Completion DaOUs?Has site been put into reuse? |0 YES 1 ® NO

REVIEW STATUSReviewing (g) EPA 0 State | 0 Tribe |0 Other FederalAgency: I [ AgencyAuthor Name: Shawn Ghose M.S., P.E.Author Title: Remedial Project Mgr Author Affiliation: EPAReview Period: 8/95 to 8/2000Date(s) of site inspection: 6/23/2000Type of Review: ® Statutory 0 Post-Sara 0 Pre-Sara 0 NPL-

0 Policy 0 Non-NPL Remedial Action Site0 NPL State/Tribe-lead0 Regional Discretion

Review (^1 (first) 0 2 (second) 0 3 (third) 0 Othernumber (specify)Triggering Action:® Actual RA Onsite Construction 0 Actual RA Start at OUOConstruction Completion 0 Previous Five-Year R0 Other (specifyTriggering action date: 9/04/1991Due date (five years after triggering action date): 9/04/1996

/Tulsa County

® Complete

te: 8/22/95

Removal only

1 #eview Report

VI

Five Year Review Summary formDeficiencies

The following general deficiencies were identified:• Three small patches of stressed vegetation on the landfill cap• Vent cover partially filled with dirt• Minor erosion on gravel side slope of perimeter road• Three patches of stressed vegetation outside of the landfill perimeter fence• Barren slope on Arkansas River Levee outside of the landfill perimeter fenceNone of these deficiencies currently cause the remedy not to be protective

Recommendations and Follow-up Actions

Two actions are required to correct the deficiencies and ensure that protectiveness ismaintained:• Landfill cover, perimeter road, and vent cover will be repaired as part of regular

landfill maintenance.• Areas outside of the landfill perimeter fence will be repaired.

Protectiveness Statements(s):

The remedial actions at the Source Control Operable Unit and the Main Site OperableUnit are protective of human health and the environment. Since both operable units areprotective, the remedy for the site is protective of human health and the environment.

Other Comments:

The landfill is in good condition and is inspected and maintained on a regular basis.Institutional controls are in place and no changes in land use are planned. Theperimeter fence has been effective in preventing unauthorized access to the landfill..

Vll

Sand Springs Petrochemical ComplexFirst Five-Year Review Report

I. Introduction

EPA Region 6 has conducted a first five-year review of the remedial actionsimplemented at the Sand Springs Petrochemical Complex located in Tulsa County,Oklahoma. The review was conducted from April 2000 through June 2000, and thisreport documents the results of the review. The purpose of five-year reviews is todetermine whether the remedy at a site is protective of human health and theenvironment. The methods, findings, and conclusions of reviews are documented infive-year review reports. In addition, five-year review reports identify deficiencies foundduring the review, if any, and identify recommendations to address them.

This review is required by statute. EPA must implement five-year reviews consistentwith the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan(NCP). CERCLA §121(c), as amended, which states:

If the President selects a remedial action that results in any hazardoussubstances, pollutants, or contaminants remaining at the site, the President shallreview such remedial action no less often than each 5 years after the initiation ofsuch remedial action to assure that human health and the environment are beingprotected by the remedial action being implemented.

NCP Section 300.430(f)(4)(ii). 40 CFR § 300.430(f)(4)(ii) states:

t If a remedial action is selected that results in hazardous substances, pollutants,or contaminants remaining at the site above levels that allow for unlimited useand unrestricted exposure, the lead agency shall review such action no lessoften than every five years after initiation of the selected remedial action.

This is the first five-year review for the Sand Springs Petrochemical Complex. Thetriggering action for this review was the start of the remedial action on September 4,1991. Due to the fact that stabilized waste, contained in a landfill, remains at the siteabove levels that allow for unrestricted use and unlimited exposure, five-year reviewsare required.

1 1 . Site Chronology

Table 1: Chronology of Site Events

Date

Early 1900's193019481953

19641969'12/809/83

3/84

6/86

5/87

6/87

9/876/889/917/929/9212/927/938/95

Event

Pierce Petroleum begins to refine oil on the site.Sinclair Oil purchases the Pierce Petroleum Refinery.Sinclair Oil Refinery is shut down and dismantling begins.Sinclair conveys property to the Sand Springs Home, but retains 38acres.Sand Springs Home leases 5.5 acres of its property to Glenn Wynn.Sinclair Oil merges with Atlantic Richfield Company (ARCO).EPA investigates ground water contamination on the site.U.S. Environmental Protection Agency (EPA) proposes Sand SpringsPetrochemical Complex for inclusion on the National Priorities List.EPA orders potentially responsible parties to conduct emergencyremoval of drums and tanks.U.S. Environmental Protection Agency (EPA) promulgates SandSprings Petrochemical Complex for inclusion on the NationalPriorities List.Oklahoma State Department of Health in cooperative agreement withthe EPA completes the RI/FS for the Source Control andGroundwater Operable Units.ARCO and citizens comment on the Source Control RI/FS; ARCObegins treatability studies pursuant to an Administrative Order onConsent with EPA.EPA issues Record of Decision for the Source Control Operable Unit.EPA issues Record of Decision for the Groundwater Operable Unit.Removal of Tank Bottom Pit sludge to the Small Acid Pit.ARCO completes treatability studies.Remedial Action on the Glenn Wynn portion of the site begins.Remedial Action on the Glenn Wynn portion of the site is completed.Remedial Action on the acid tar wastes begins.Remedial Action completed.

2

III. Background

A. Location

The Sand Springs Petrochemical Complex Superfund Site is located within the citylimits of Sand Springs, Oklahoma in Tulsa County. The site is located on the northbank of the Arkansas River (Attachment 2) and comprises approximately 235 acres.The area is designated as an industrial, area and the site is situated on the alluvial floodplain of the Arkansas River. Approximately 25 to 40 feet of alluvial deposits composethe alluvial aquifer, which overlies 205 feet of shale bedrock. In situ aquifer testsperformed at the site indicate the alluvial aquifer has a high hydraulic conductivity. Theaquifer tests and measured water levels in monitoring wells on the site indicate that theground water moves at a rapid rate (several hundred feet per year) and discharges tothe Arkansas River during most of the year (stable or falling river stages). Duringperiods of high river levels, a gradient reversal may occur causing river water torecharge the alluvial aquifer. However, gradient reversals have not been documentedthrough field measurements.

B. History

Beginning in the early 1900's, the site was occupied by the Pierce Petroleum Refinery.The refinery was subsequently acquired by the Sinclair Oil Corporation in the early1930's and continued to operate until 1948 when most of the refinery operations wereshut down. Dismantling of the refinery commenced shortly thereafter, and all remainingrefining operations ceased in 1952. Remaining on the site from refinery operationswere several acid petroleum waste pits and non-acid petroleum waste pits. By Octoberof 1953, Sinclair had conveyed all but approximately 38 acres of the refinery property tothe Sand Springs Home. Since 1953, a variety of industries leased or purchasedproperty from the Sand Springs Home, including chemical manufacturers, solvent andwaste oil recyclers, and scrap metal operations. In 1969, Sinclair merged with. theAtlantic Richfield Company (ARCO) and the 38-acre tract of land was absorbed in themerger.

From 1964 through 1983, several solvent and oil recycling facilities operated on a5.5-acre portion of the site. The area encompassing the recycling operations is nowreferred to as the Glenn Wynn portion of the site. Remaining on the site as a result ofrecycling operations were two unlined solvent pits, numerous tanks and drums, andcontaminated soils that were the result of accidental spillage.

In December 1980, state agencies and the EPA became concerned aboutcontamination at the site. Over the next three years, water and soil samples were

environment. Results of the tests indicated that contact with the sludge andcontaminated soils posed a human health risk, and the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA), commonly known as Superfund,would be utilized to address contamination at the site. The Sand SpringsPetrochemical Complex was proposed for inclusion on the Superfund NationalPriorities List (NPL) in September 1983, and the site was officially added to the NPL inJune 1986.

EPA ordered the owner and three lessees of the Glenn Wynn portion of the site toconduct an emergency removal of contaminated drums and tanks. Only the propertyowner complied with the order and the removal action was completed in 1987.

The EPA subsequently divided the site into two operable units, the Source ControlOperable Unit, which included all waste pits and contaminated soils, and the Main SiteUnit, which included ground water. Under a cooperative agreement with the EPA, theOklahoma State Department of Health began the Remedial Investigation and RemedialDesign for the operable units. The Remedial Investigation and Feasibility Study for theSource Control Operable Unit were completed in May 1987. The RemedialInvestigation and Feasibility Study for the Main Site Operable Unit were completed inMarch 1988.

IV. Remedial Actions

A. Remedy Selection


The EPA Regional Administrator for Region 6 signed the Record of Decision (ROD) onSeptember 29, 1987. The ROD stated that, in EPA's judgment Alternative 2 appearedto meet more statutory selection criteria than the other remedies evaluated, but hadserious implementation problems. During the comment period, the ARC 0 PetroleumProducts Company, a division of Atlantic Richfield Company (ARCO), one of thepotentially parties for the site, made written and oral proposals for a privately financedremedy for the site. The EPA concluded that the ARCO proposal provided a remedycomparable to Alternative 2. The EPA accepted this remedy provided that theeffectiveness of the proposal was adequately assured or that ARCO would undertakethe corrective actions deemed appropriate by the EPA if the ARCO proposed remedyfailed. The ROD listed the following in the description of the remedy:

1) The excavation and off-site thermal destruction of sludges, at least to thesludge/soil interface from the portion of the site identified as the North and SouthGlenn Wynn Lagoons

4

2) Solidification and/or stabilization of all remaining sludges and containment ofthe resulting matrix in a hazardous waste (RCRA) cell to be constructed on-site;this cell (or cells) had to meet the minimum technological requirements ofSubtitle C of the Solid Waste Disposal Act

3) As part of the remedial design, ARCO had to demonstrate that thesolidification technology met EPA approved criteria; the criteria included bothchemical and physical testing requirements; in the event that the solidificationtechnology failed these criteria, thermal destruction would have been the remedyfor the above-mentioned operable unit.

4) No liability release for the site or from future maintenance and monitoring.

5) Repair or restoration of the RCRA cell to ensure no migration from the unit ordestruction or treatment of all or a portion of its contents, as EPA shall deemappropriate, if the monitoring should show that the solidification and/orstabilization remedy has failed.


The EPA Regional Administrator for Region 6 signed the ROD on June 28, 1988. TheROD stated that in EPA's judgment Alternative 2, No Action (Monitoring following theSource Control Remedial Action) met the statutory selection criteria. Factors supportingthis decision included: after the Source Control Remedial Action, a natural flushingaction will have decreased the level of contamination over time; the ground water andArkansas River are not sources of drinking water; and there are no public healththreats from the minimally contaminated soil. The State of Oklahoma concurred withthis remedy. The ROD listed the following requirements in the description of theremedy:

1 . placing appropriate warning signs;

2. restricting access; and,

3. collecting and analyzing ground water and Arkansas River samples for aperiod of at least 30 years.

The EPA determined that this alternative is protective of human health and theenvironment, attains federal and state requirements that are applicable or relevant andappropriate, is cost-effective compared to equally environmentally protectivealternatives, and utilizes permanent solutions and alternative treatment technologies tothe maximum extent practicable.

B. Remedy Implementation

ARCO managed the full remediation activities. The Corps of Engineers, Tulsa District,provided oversight for the EPA during the Additional Site Characterization, RemedialDesign, and Remedial Action, and will continue in this function during the Operationsand Maintenance Phase. The Remediation Actions have been completed in phases.

a. Source Control Operable Unit

Glenn Wynn Site

Remedial activities for the Glenn Wynn portion of the Sand Springs PetrochemicalComplex commenced in August 1992. The remediation included the following six sub-sites: North Lagoon, South Lagoon, Drum Area, T-5 Area, L-Shaped Area and PumpHouse.,

Except for the Pump House, remediation of the sub-sites consisted of excavatingcontaminated material and transporting this material to off-site hazardous wasteincinerators. After excavated areas were completed, the excavations were backfilledand compacted with either stockpiled soil from the sub-site or with clean fill from off sitesources. Contaminated debris, generated during the remediation, were transported tothe Lone Mountain Hazardous Waste facility located in Major County, Oklahoma.

The Pump House contained drums of drill cuttings, drums of monitor well purge water,and plastic bags of personal protective equipment. This material was generated fromprevious investigations at the Sand Springs site. All solid material was tested andeither incinerated with other site wastes, stockpiled for later treatment, or transported tothe Lone Mountain Hazardous Waste facility. All water was treated on-site at thetemporary wastewater treatment plant. Final site grading and seeding occurred inDecember 1992.

Waste Water Treatment

A waste water treatment plant was constructed on the site to treat water pumped fromthe retention pond and to treat surface runoff that contacted the sludge pits. Theretention pond was located between the large acid sludge pit and the small acid sludgepit. After completion of the remedial action, the waste water treatment plant wasdismantled.

6

Refinery Wastes

During the Remedial Investigation and subsequent additional site characterizationactivities, six petroleum waste pits were identified that required excavation, treatment,and placement into the on-site landfill. The six pits were: Large Acid Pit, Small AcidPit, Round River Pit, Levee Pit, Tank Bottom Pit, and Con-Rad Sludge Area.Excavated areas included the contaminated soils adjacent to these pits, and theSurface Impoundment between the Large and Small Acid Pits. Treatment consisted ofmixing neutralized waste with stabilizing additives in a Transportable Treatment Unit(TTU) to produce a stabilized material that could be secured in the on-site landfill.

Refinery Waste Remediation

The Tank Bottom Pit (TBP) remediation began on September 4, 1991. Approximately2,350 cubic yards of sludge and soil above the sludge soil interface were excavatedfrom the TBP. An additional one foot of soil as required by the work plan was excavatedfrom the TBP bottom and the pit edges resulting in an additional 1,300 cubic yards ofexcavated soil. The 3,650 cubic yards of excavated sludge and were placed in theSmall Acid Sludge Pit for later treatment.

After excavation of the TBP, the remaining sludge pits were excavated in phases andthe following operations were conducted as part of the remediation:

1. The neutralization of acid material in-place by mixing a lime slurry into the sludge2. The neutralized waste was excavated and hauled to a stock pile adjacent to the

Transportable Treatment Unit (TTU)3. Excavation continued to a depth of one foot below the sludge soil interface4. Treatment of stabilized waste in the TTU to achieve the physical and chemical

properties required by the ROD5. Placement of the neutralized treated waste into the landfill6. Construction of the landfill cover

The TTU consisted of an initial grinder to reduce the neutralized sludge to a friableconsistency, a large batch mixer to mix the stabilizing agents with the neutralizedsludge, and a covered walking floor to contain emissions from the stabilized material.

The Subtitle C landfill was constructed of eight separate cells. Each cell contained aseparate pipe system for leachate collection and leachate detection. A perimeter drainsurrounds the landfill and two gas vents were installed into the landfill cap. A securityfence was placed around the perimeter of the landfill and institutional controls wereimplemented by the landowner.

7

Approximately 206,500 cubic yards of solidified sludge and soil were excavated, treatedin the TTU, and placed in the landfill. All construction activities were completed onAugust 22,1995.

b. Main Site Operable Unit

Remediation Activities for the main site consisted of the installation of seven newmonitoring wells (MW-101 to MW-107) and the use of two existing wells (MW-14 andMW-15) installed during the Rl. The seven new wells are located around the landfilland consist of three normal upgradient and four normal downgradient. The two existingwells are located upgradient of the landfill. Two of the new wells (MW-106 and MW-107) were installed on the levee during the construction phase and were utilized fordown gradient pre-closure monitoring. The existing wells MW-14 and MW-15 wereutilized for upgradient pre-closure monitoring.

Monitoring of the ground water was divided into pre-closure and post-closuremonitoring. Pre-closure monitoring consisted of the collection of quarterly samples for aperiod of one year from MW-106, MW-107, MW-14, and MW-15. After closure of thelandfill, the remaining wells were installed (Attachment 2), and a 30 year post-closuremonitoring period began. Post-closure monitoring was established as one year ofquarterly sampling, one year of semi-annual sampling, and eight years of annualsampling followed by sampling on a 5 year cycle.

C. System Operations

The maintenance of the monitor wells and the landfill is being conducted in accordancewith the approved Landfill Groundwater Monitoring Plan and the Post-Closure Plan.The property owner is the Sand Springs Home. The Sand Springs Home has grantedthe Oklahoma Department of Environmental Quality (DEQ) access to the property formaintenance and inspection. Under this agreement, Atlantic Richfield will conduct themonitoring and maintenance. Systems operations include the following activities:

1. Inspection of the landfill cap and side slopes for physical deformities 'andvegetative cover

2. Inspection of perimeter roads, perimeter security fence, and perimeter drainsystem

3. Inspection of the landfill vents, monitor wells, and leachate collection system4. Sampling of the on-site monitor wells in accordance with the post-closure

monitoring schedule5. Measurement and removal of leachate from the leachate collection and leachate

detection system

Landfill Maintenance

The maintenance of the landfill has generally been limited to annual mowing, minorerosion repair of the perimeter road and side slopes, and maintenance of the perimeterfence. The top of the landfill cap between the vents had exhibited only sparsevegetation after closure. In the fall of 1998, it was suspected that a condition ofexcessive salt in the soil surface was inhibiting the growth of vegetation. This wasconfirmed in the spring of 1999, and the top six inches of soil in the problem areas wasremoved and replaced with new soil. The landfill cap is now vegetated with grass.

A similar condition is suspected for an area on the side slope of the Arkansas RiverLevee that is located approximately 100 feet outside of the landfill perimeter fence.From 1943 when it was installed until remedial action, the levee formed the south bermof two of the acid sludge pits. After the sludge was removed, the side of the levee wasgraded and seeded, but the area has never fully vegetated. Replacement of the soilcover on the side of the levee and the placement of sod on the side slope werecompleted in July 2000.

Leachate Collection System

The leachate collection system consists of a separate leachate collection and leachatedetection system. The system is being operated on an annual basis to removeleachate that accumulates in the leachate collection sumps. The system is functioningas designed, and no operational problems have been recorded for the leachatecollection and detection systems. The amount of leachate pumped is recorded duringremoval, and the data is presented in annual reports. Table 1 is a summary of 1998and 1999 leachate collection system pumping data. It is expected that the amount ofleachate removed wilt be significantly different for the cells. This is because the cellswere closed at different times, and some cells were subjected to large amounts ofrainfall prior to the cell being closed.

The Post Closure Plan specifies an Action Leakage Rate (ALR) of 560 gallons per acre,which is the maximum allowable amount of leachate that can be collected from theleachate detection sumps. Leachate from sumps that exceeds the ALR indicates thatthere are leaks in the system, and corrective action will be necessary to diminish theexcessive leachate.

The amount of leachate is calculated for all cells in gallons per acre per day (GPAD).The calculation of the GPAD is as follows:

GPAD = total gallons removed - acre values for each cell - total decimal days

9

Where: the total decimal days are the number of days that leachate wasaccumulated.

Table 1: Summary of 1998 and 1999 Leachate Collection System Pumping DataSand Springs Petrochemical Complex Site

Cell Number

11122334455667788

Total G

Type

CollectionCollectionDetectionCollectionDetectionCollectionDetectionCollectionDetectionCollectionDetectionCollectionDetectionCollectionDetectionCollectionDetection

iallons

19Leachate

EvDate

Serviced6/19/98

6/19/986/19/986/19/986/19/986/19/986/19/986/19/987/23/987/23/986/19/986/19/987/23/987/23/988/20/988/20/98

98Collectionent

Gallonsper Cell

1683

01515

01450

05770

4250

51812

8000

18020

8782

19Leachate

EvDate

Serviced6/21/996/22/996/22/996/22/996/22/996/21/996/21/996/22/996/22/996/22/996/22/996/22/996/22/996/21/996/21/996/21/996/21/99

99Collectionent

Gallonsper Cell

13925180

14590

11600

6600

1010

48313

4010

21200

8,307

The amount of leachate removed from the leachate detection system is extremelysmall. The amount of leachate was measured to be zero in all cells except cell number6. This cell recorded 12 gallons in 1998 and 13 gallons in 1999. No other cellscontained measurable amounts of leachate. The small amount of leachate detected in

10

cell number 6 was calculated to be 0.04 GPAD (Table 2). This amount was below theAction Leakage Rate of 560 GPAD that was established in the Post Closure Plan.

Table 2: Leachate Collection System, 1998 and 1999 GPAD Calculations

CellNumbe

r

CelMCell 2Cell 3Cell 4Cell5Cell6Cell 7Cell8

System

DetectionDetectionDetectionDetectionDetectionDetectionDetectionDetection

CellAcres

1.1351.1390.8900.8990.8690.8811 . 1 1 31.108

Gallons000001200

1998

Days472472472472506472506534

GPAD0.000.000.000.000.000.030.000.00

Gallons000001300

1999

Days368368367368334368333305

GPAD0.000.000.000.000.000.040.000.00

Notes:(1) GPAD = total gallons removed - acre values for each cell(2) Decimal days were rounded up to the nearest whole day

total decimal days

Sampling of Monitor Wells

Monitor wells are currently being sampled on an annual basis as specified by theLandfill Groundwater Monitoring Plan. The wells are sampled for the list of constituentsshown in Attachment 3. A review of the available sample analysis (Attachment 4:Summary of Laboratory Analytical Results) has not shown a degradation of the groundwater associated with the landfill that would require a further response action.However, an upgradient plume has been detected in samples collected from two of theground water monitoring wells.

The monitor wells MW-104 and MW-105 that are located on the east side of the landfillhave become contaminated with an Light Nonaqueous-Phase Liquid (LNAPL). TheLNAPL has a diesel odor, but appears to be a mixture of materials. In the 12-yearsampling and investigation history for this project, this type of LNAPL material hasnever been present on the site. The location of the affected wells and the direction of

11

the ground water flow indicates that the LNAPL is originating from an area north of thelandfill (Attachment 2: Site Maps).

The plume appears to have the greatest impact on the nearest downgradient well (MW-104). 1.62 feet of LNAPL was recorded in this well in 1998; 1.14 feet was recorded in1999 and 0.7 foot in 2000. The LNAPL thickness was removed from the well prior tosampling. A bail down test was not conducted because the thickness of LNAPL in thecasing is not a good measure of thickness in the aquifer. In MW-105 there was nomeasurable thickness of LNAPL in 1998, 1999, or 2000; however, a sheen, odor, andgreasy residue indicated that the plume was present in the well during the three years.(Table 3).

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Table 3: Water Level Data and Detected LNAPL Thickness

WellNumber

MW-101MW-102MW-103MW-104MW-105MW-106MW-107MW-14MW-15

WellDepth

33.228.527.736.534.436.236.726.927.6

V

199821.1919.9019.4425.8724.5130.9230.3517.4216.86

Vater Leve

199917.7917.0316.5621.6220.2726.2225.7114.9514.58

I

200022.0220.8720.3725.7025.0931.7331.1718.4617.92

LNAPL

1998

24.25sheen

. Level or IndicatedPresence

1999 2000

20.48 25.00sheen sheen

The ground water movement is rapid through the alluvial aquifer; 1987 slug testscalculated movement to be 350 feet per year. Permeabilities that were calculated in1987 were reported in the 2.0 X 10'2 range. Considering some retardation, it wouldtake at least two or more years for the LNAPL to travel from the perimeter of the landfillarea to the closest monitor well (MW-104). Projecting the direction of ground waterflow, there are no additional wells that would intercept the plume between MW 105 andthe Arkansas River.

Comparing the analytical results to previous years, there are several increases involatile organic parameters. The concentration of 2-methylnapthalene in MW-104changed from nondetect in 1996 to: 18 ug/l in 1997, 1 1 0 ug/l in 1998, 520.8 ug/l in 1999and back to nondetect in 2000. 1,1 dichloroethane was detected in three monitor wellsin 1998, six monitor wells in 1999, and two monitor wells in 2000. This reflectschanging amounts of dissolved constituents from the upgradient plume in the groundwater. A sample of the LNAPL was not collected.

V. Five Year Review Process

The Sand Springs Petrochemical Complex five-year review was led by Shawn Ghose,EPA Remedial Project Manager for the site. Others persons involved in the reviewincluded Mr. Richard Smith, USAGE Project Manager and Dr. Dennis Hrebec, O&Mcontractor.

The five-year review consisted of reviewing the data against the established critera andan inspection of the site.

13

VI. Five Year-Review Findings

A. Interviews

The following individuals were contacted by telephone as part of the five-year review:

Loy Calhoun, City Manager of the City of Sand Springs (Interviewed 6/12/2000)Dennis Datin, Project Manager, Oklahoma Department of Environmental Quality(Interviewed 6/16/2000)Dennis Hrebec, D & B Construction. Operation and Maintenance (Interviewed5/25/2000)Penny Walker, Tulsa Corp of Engineers, EPA oversight agency (Interviewed 6/1/2000)Joe Williams, Trustee, Sand Springs Home (Interviewed 5/28/2000)

Mr. Calhoun stated that the City of Sand Springs had not received any inquiriesregarding the site, and the Sand Springs community is apparently not concerned aboutthe site. He was complimentary of the remedial action and has no concerns regardingcontinued effectiveness.

Dr, Datin stated that he has received only one inquiry concerning site monitor wells, andthat inquiry was found to be unrelated to the site. He was not aware of any problemsthat might affect the permanence of the remedial action.

Dr. Hrebec stated that the landfill is in good condition, and there are no knownproblems that might affect the effectiveness of the remedy.

Ms. Walker stated that there is only one problem at the landfill site. and it concernssparse vegetation. However, the sparse area is outside of the landfill perimeter fence,and is associated with a former excavation area where contaminated material wasexcavated from a sludge pit and backfilled with clean soil.

Mr. Williams stated that there have been no complaints or inquiries concerning the site.

B. Site Inspection

Representatives of the Tulsa Corp of Engineers (EPA oversight contractor), OklahomaDepartment of Environmental Duality and D & B Construction conducted a siteinspection of the landfill on June 21, 2000. Conditions during the inspection weretemperatures of 74 degrees, light winds and overcast skies. Rain had fallen during the

14

late morning and had ceased approximately one hour prior to the inspection. Within theperimeter of the landfill fence, the inspection included an evaluation of the cap and sideslopes, vegetation, drainage system, gas vents, monitor wells, perimeter fence, andgates. Outside of the perimeter fence, former areas that contained petroleum pits wereevaluated for vegetation.

The landfill was found to be in good condition, the vegetation on the landfill cap andside slopes was complete except for three areas approximately 4 feet in diameter thatexhibited stressed vegetation. Some evidence of moles was noted, and one of the ventcovers was partially filled with dirt from mole activity. There was no evidence ofslumping, cracks, or deformation of the landfill cap or side slopes.

The perimeter road was in good condition except on the west slope of the landfill wheresurface water crossing the perimeter road has cut a small erosion gully in the gravelside slope. Perimeter drains were in good condition, and perimeter fencing and gateswere in good condition. There was no evidence of unauthorized access to the landfill.

Monitor wells had the caps and locks installed and were in good condition. Earnerposts for above-surface monitor wells were intact, and below surface well enclosuresand cover plates were intact for surface mount wells. Annual sampling was conductedon June 27, 2000, and all monitor wells were operational.

Outside the landfill perimeter fence are three former petroleum pit areas that wereexcavated and backfilled during the remedial action. These areas were inspected forvegetative cover, and two of the areas were observed to have patches of bare soil. Onthe area of the former River Acid Sludge Pit, an erosional ditch was present wheresurface water runoff drains into the Arkansas River. On the area of the former LeveePit, two areas approximately six feet in diameter exhibited stressed vegetation. TheArkansas River Levee, which is located approximately 100 feet south of the landfillperimeter fence, was a former berm for two of the acid sludge pits. The north slope ofthe levee was observed to be partially barren of vegetation. Repair of all barren orstressed vegetation areas has been scheduled as part of regular landfill maintenance.

C. Risk Information Review

The following standards were identified as applicable or relevant and appropriaterequirements (ARARS) in the Record of Decision. The standards were reviewed forchanges that could affect the protectiveness of the remedy.

FederalResource Conservation and Recovery ActComprehensive Environmental Response, Compensation, and Liability ActSuperfund Amendments and Reauthorization Act

15

Clean Air ActClean Water ActExecutive Orders for Flood PlainsFish and Wildlife Coordination Act

StateOklahoma Water Quality StandardsOklahoma Solid Waste RegulationsOklahoma Clean Air Act

Although there have been several changes in Federal and State ARARS, such as alowered action level for lead and Land Disposal Restrictions, none of the regulatorychanges affect the remedy at the Sand Springs Petrochemical Complex. This isbecause the remedy does not have an ongoing remediation activity, such as a groundwater pump and treat operation, and is not attempting to attain a cleanup standard.The remedial action excavated and transported listed hazardous wastes to an offsiteincinerator, treated all characteristic hazardous waste to nonhazardous, and placed thetreated nonhazardous waste in an onsite RCRA Subtitle C landfill. Ground water isslightly contaminated upgradient of the site from unknown sources and flows beneaththe site to discharge into the adjacent Arkansas River.

D. Data Review

A review of records and monitoring reports through June 2000 indicates thatapproximately 8,000 gallons of leachate are removed from the leachate collectionsystem annually. This amount is expected to decrease over time. The analyticalresults of monitor welt samples have indicated a slight general decrease in contaminantlevels over the last three years, except for the two wells that are being inpacted by anupgradient offsite plume; those two wells have shown an increase in 2-methylnapthalene.

VII. Assessment

The following conclusions support the determination that the implemented remedy atthe Sand Springs Petrochemical Complex is continuing to be protective of humanhealth and the environment.

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

Institutional Controls and Other Measures: Institutional controls are in placeand there are no changes or planned changes in land use. Fences and gates are

16

maintained and provide an adequate means to restrict access. There is noobservable evidence of unauthorized access to the landfill.

Remedial Action Performance: The onsite RCRA Subtitle C landfill has beeneffective in isolating the treated waste. Only one minor erosion gully and threesmall barren soil areas on the cap were observed during the inspection. The cap,side slopes, and perimeter road are repaired on a regular basis, and the minordeficiencies listed have been scheduled for repair. None of the minor deficienciesthat were observed affect the performance or integrity of the landfill system.

System Operations/0 & M: System operations consist of repair andmaintenance of the landfill cap, perimeter road, perimeter fence, removal ofleachate from the leachate collection system, and sampling of the monitor wells.Systems operations are completed as required on a regular basis.

Early Indicators of Potential Remedy Failure: There is no indication of remedyfailure. The landfill is inspected on a regular basis and operation and maintenanceactivities are performed on the landfill as required.

Question B: Are the assumptions used at the time of remedy selection still valid?

Changes in Standards To Be Considered: This five-year review did not identifyany changes in Federal or State standards that impact the Source ControlOperable Unit remedy remedy or the Main Site Operable Unit remedy.

Changes in Exposure Pathways: This five-year review did not identify anychanges in exposure pathways since the completion of the Source Control andMain Site remedies. Institutional controls have been effective in preventing anycurrent or planned changes in land use. There is no indication that the treatedwastes were not properly characterized, removed and treated during the SourceControl remedy. There is no indication that the ground water hydrology was notadequately characterized prior to the implementation of the Main Site remedy.

•

Changes in Toxicity and Contaminant Characteristics: Toxicity or othercharacteristics have not changed for the contaminants of concern.

Question C: Has any other information come to light that could call into questionthe protectiveness of the remedy?

No additional information has been identified that questions the protectiveness ofthe remedy.

17

VIII. Deficiencies

Deficiencies discovered during the five-year review are as follow:

Area within the landfill perimeter fence.(1) Three small areas of stressed vegetation on the landfill cap(2) One vent cover partially filled with dirt from mole activity(3) One small erosion gully that has been cut in the gravel side slope of theperimeter road

Area outside the landfill perimeter fence.(1) An erosional ditch was present on a former excavated area, where surface

water runoff drains into the Arkansas River(2) Two areas approximately six feet in diameter exhibited stressed vegetation on a

former excavated area(3) The north slope of the Arkansas River Levee, which is located approximately

100 feet south of the landfill perimeter fence, was observed to be partiallybarren of vegetation

None of the deficiencies are sufficient to warrant a finding of not protective as long ascorrective actions are undertaken.

18

IX. Recommendations and Follow-up Actions

At the time of the inspection, it was recommended that Atlantic Richfield Companyrepair the stressed vegetation areas, and erosion gullies, and remove the dirt from thegas vent cover. The recommendations and follow-up actions are outlined below:

Deficiencies

Within theperimeter fence:Small areas of

stressedvegetation on

landfill cap, Dirtin vent cover.Small erosiongullies on side

slope of perimeterroad

Outside theperimeter fence:

Stressedvegetation on

former excavationareas

Outside theperimeter fence:

Stressedvegetation/

barren area anderosion gulley onthe north side ofArkansas River

Levee

Recommendationsand

Follow-up Actions

Repair stressedvegetation areas,remove dirt from

vent, repair erosiongullies on side slopeof perimeter road.

Repair stressedvegetation areas.

Repair stressedvegetation/barrenareas and repairerosion gulley.

PartyResponsible

AtlanticRichfield Co.



OversightAgency

EPA/COE

EPA/COE

EPA/COE

MilestoneDate

NextQuarterlyInspection

Before thenext annual

report(6/01)

Before thenext annual

report(6/01)

Follow-upActions: AffectsProtectiveness

(Y/N)

N

N

N•

19

X. Protectiveness Statements

The remedies that were implemented for the Source Control Operable Unit and theMain Site Operable Unit continue to be protective of human health and theenvironment. Since the remedies for both operable units are protective of humanhealth and the environment, the remedy for the site is protective of human health andthe environment.


The remedy that was implemented for the Source Control Operable Unit is protective ofhuman health and the environment. The RCRA Subtitle C landfill has been effective inpreventing the infiltration of precipitation and direct contact with treated wastes.Perimeter fencing and institutional controls at the landfill are in place and are effectivein preventing unauthorized entry or use of the landfill. The landfill is in good conditionand is inspected and maintained on a regular basis.


The remedy that was implemented for the Main Site Operable Unit is protective ofhuman health and the environment. The ground water continues to be impactedupgradient of the site from unknown historical sources. Since those sources no longerexist, the ground water should continue to attenuate naturally over time.

XI. Next Five-Year Review

The next five-year review will be conducted in 2005. The scope of the next review maybe limited to an inspection of the RCRA Landfill System and the appurtenant structuresto ascertain that they are not being damaged by animals or the elements and thatunauthorized entry to the site is controlled.

20

Attachment 1Documents Reviewed

DOCUMENTS REVIEWED

Annual Inspection Report for the Sand Springs Petrochemical Complex Landfill. Prepared forARCO Petroleum Products by Caldwell Environmental Associates Inc., November 1998.

Annual Inspection Report for the Sand Springs Petrochemical Complex Landfill. Prepared forARCO Petroleum Products by Caldwell Environmental Associates Inc., August 1999.

Evaluation of Technologies Available to Treat Acid Sludges from Lubricating Oil Plants.Prepared for ARCO Petroleum Products by Mittelhauser Corporation, November 1986.

Feasibility Study Report for the Main Site Operable Unit of the Sand Springs PetrochemicalComplex Superfund Site. Tulsa County. Oklahoma. Prepared for the Oklahoma StateDepartment of Health by John Mathes & Associates, Inc., March 1988.

Feasibility Study Report for the Operable Unit of the Sand Springs Petrochemical ComplexSuperfund Site. Tulsa County. Oklahoma. Prepared for the Oklahoma State Department ofHealth by John Mathes & Associates, Inc., May 1, 1987.

Final Close Out Report. Sand Springs Petrochemical Complex Superfund Site. EnvironmentalProtection Agency Region 6, December 1997.

Remedial Design/Remedial Action. Source Control Operable Unit. Sand Springs PetrochemicalComplex. Additional Site Characterization Final. Prepared for ARCO Petroleum Products byMorrison-Knudsen Engineers Inc., September 1988.

Remedial Design/Remedial Action. Source Control Operable Unit, Sand Springs PetrochemicalComplex, Chemical Solidification and Stabilization Final. Prepared for ARCO PetroleumProducts by Morrison-Knudsen Engineers Inc., September 5, 1988.

Remedial Design/Remedial Action. Source Control Operable Unit. Sand Springs PetrochemicalComplex. Consolidated Final Design Report Volume 1. Executive Summary. Prepared for ARCOPetroleum Products by Morrison-Knudsen Engineers Inc., May 1993.

Remedial Design/Remedial Action. Source Control Operable Unit. Sand Springs PetrochemicalComplex. Glenn Wynn Sludge Removal Final. Prepared for ARCO Petroleum Products byMorrison-Knudsen Engineers Inc., November 1988.

Remedial Design/Remedial Action. Source Control Operable Unit. Sand Springs PetrochemicalComplex. Landfill Final. Prepared for ARCO Petroleum Products by Morrison-KnudsenEngineers Inc., September 1988.

Sand Springs Petrochemical Complex Tulsa County. Oklahoma. Sludge and SurfaceImpoundment Sampling Remedial Investigation Report. Prepared for the Oklahoma StateDepartment of Health by John Mathes & Associates, Inc., May 1,1987.

Sand Springs Petrochemical Complex Source Control Operable Unit. Alternative Selection.Record of Decision. Environmental Protection Agency Region 6, September 1987.

Sand Springs Petrochemical Complex Main Site Operable Unit. Alternative Selection. Record nfDecision. Environmental Protection Agency Region 6, June 1988.

Sand Springs Petrochemical Complex Superfimd Site. Tulsa County. Oklahoma Main SiteOperable Unit. Remedial Investigation Report. Prepared for the Oklahoma State Department ofHealth by John Mathes & Associates, Inc., March 1988.

Sand Springs Superfund Site Study. Prepared by National Strategies Inc. for AmericanInternational Group Inc., Fireman's Fund Insurance Co. and Crum & Foster Insurance Co.November 1,1992.

Attachment 2Site Maps

Attachment 3List of Constitutents for Ground Water Monitoring

List of Constituents for Ground Water MonitoringSand Springs Petrochemical Complex

Metals Volatile OrganicCompounds

Base-NeutralExtractable Organic

Compounds

Acid ExtractableOrganic Compounds

ArsenicAntimonyBariumBerylliumCadmiumChromiumChromium VICopperLeadMercuryNickelCobaltSeleniumSilverZinc

1,2-DichloropropaneAcetoneBenzeneChloroethaneChloroformCnloromethane1,1-Dicnloroethane1.1-Dichloroetnene1.2-Dichloroethane1,2-TransDichloroetheneEthylbenzeneMethylene ChlorideTetrachloroethylene1.1.1-Trichloroethane1.1.2-TrichloroethaneTrichloroetheneTolueneVinyl chlorideXylenes

AnthraceneBenzo(a)anthraceneBenzo(a)pyreneBenzo(b)fluorantheneBenzo(k)fluorantheneBis(2-ethylhexyl)phthalateCnryseneDibenzofuranDimethyl phthatateDi-n-butylphthalateFluorene2-MethylnaphthaleneNaphthalenePhenanthrenePyrene

Benzoic acidP-Chloro-m-cresol2,4-Dinitrophenol4,6-Dinitro-o-cresolPhenol

Indicator ParameterTotal Organic CarbonTotal dissolved Solid

Field ParameterspHSpecific ConductanceTemperature

Attachment 3Summary of Laboratory Analytical Results

SUMMARY OF LABORATORY ANALYTICAL RESULTS (UNITS : UG/L)

Analyte

Arsenic

Barium

Beryllium

Cadmium

Chromium

HexavalentChromium

Dates

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/988/986/996/00

MW14----9

439232283224696

----

5.91.16

117

1012-942

---

MW-K--

MW15-----

228182179131179

----

-----

--8-5

---

05 resarr--

MW1017----

8011871491 1 4113

----

-----

15----

--

• -npled for

--

MW102

---

47-

1431 1 7214726147

----

-----

---

24-

---

•hexava

—

MW1035

1226326

843298509540502

----

-----

18--

1 110

---

lent chrc

-

MW10416-877

3680763822730756

----

13----

47----

---

amium, r--

MW1053610302517

166078303260328

-,---

1.20.6---

75-

18--

--

16esults w

--

MW106

-----

652912840135

----

2.426-4

----6

---

ere non---

MW1075--6

25

137785133

260

---5

1.20.7---

----8

---

detect--

Table 5: Summary of Laboratory Analytical Results (units : ug/L) (continued)Analyte

Copper

Lead

Mercury

Nickel

Selenium

Zinc

Dates

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/988/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

MW1410---

1710111469

---

M--

46-

2219

---812

66455891

MW15--

-

288744

--

0.61W-15W

--

----

----6

37222835

MW10114---

333---

---

as resan--

25--

18-

----7

8542204

-

MW102

----

--410-

---

npled fo-

---

27-

----9

--

1645

MW10316---

12-

0.96-

---

r mercur--

32--

14-

-----

60--

29

MW10467---

47----

---

•y, result--

47----

-----

159---

MW10536-

10-

43-

0.5--

---

s were n--

515033--

-----

2229615267

MW106

----

2-3-4

---

on-detec--

5327196103

----6

475366445232

MW107

----

3----

---

ct--

75357977

----9

764556133


Benzene

Chloro-ethane

Chloro-methane

1,1-Dichloro-ethane

1,2-Dichloro-ethane

1,1-Dichloro-ethene

Dates

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/996/00

MW14-----

-----

-----

-----

-----

-----

MW15-----

-- •---

-----

-----

-----

-----

MW101-----

-----

-----

-----

-----

-----

MW102-----

-----

-----

---

15.6-

-----

-----

MW103-----

-160

64(H)-

31.7

220----

--

3917.814.5

-----

-76---

MW10418--

2.9-

1600310400230252

-----

30--

10.5-

5---•

-----

MW105----

11 .5

----

442

-----

47-

2219.732.5

10--3-

-----

MW106-----

•----

-----

9-

1 110.1

-

-----

7----

MW107

-----

-----

-----

14--

2.2-

-----

-----


MethyleneChloride

2-Methyl-napthalene

--—--———--—

Tetrachloro-ethene (PCE)

Toluene

1,1,1,-Trichloro-ethane(TCA)

1,1,2-Trichloro-ethane

Dates

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/986/99

'"6/00"

3/966/976/986/996/00

3/966/976/986/996/00

3/966/976/98

"6/99""6/00

MW14-----

--

———

-

-----

-----

-----

-----

MW15-----

--

-

-----

-----

----

3.6

-----

MW101

-----

--™

-

-----

-----

-----

-----

MW102

-----

--*

-

---

10.5-

-----

-----

-----

MW103

-----

--™

-

---

11.7-

7----

-----

-----

MW10413----

-18

1 1 0520.8

-

-----

-----

-17---

-----

MW105-----

--™

-

96176

12.9-

-----

-28---

1 1--

4.8-

MW106-----

--

————

-

-----

-----

514-

2.2-

-----

MW107

-----

--*

-

-----

-----

-----

-----


Trichloro-ethene (TCE)

VinylChloride

Dates

3/966/976/986/996/00

3/966/976/986/996/00

MW14-----

-----

MW15-----

-----

MW101

-----

-----

MW102

--9--

--

24.6--

MW103

-86

9.9-

--

14--

MW104

-----

---

3.1-

MW1051 1 0443571-

721935

40.7-

MW10666-

27-

-----

MW107

-----

-----

Notes:

(1) If no value is indicated, the analyte was non-detect.