IMPERIAL REFINING COMPANY SUPERFUND SITE

COMMUNITY INVOLVEMENT PLAN

July 8, 2003 Revised: February 1, 2005

State of Oklahoma Department of Environmental Quality

Land Protection Division

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TABLE OF CONTENTS SECTION PAGE A. Overview of the Community Involvement Plan 1 B. Capsule Site Description 1 Site History 1 Site Description 1 Site Location 2 Site Inspections and Cleanup Activities 3 C. Community Background 3 Community Profile 3 History of Community Involvement 4 Key Community Concerns 5 Response to Community Concerns 5 D. Community Involvement Program 6 Appendices A. DEQ and EPA Contacts 7 B. Local Officials 8 C. Elected State and Federal Officials 9 D. Tribal Groups 9 E. Environmental and Active Citizen Groups 10 F. Media Contacts 10 G. Meeting Location 11 H. Repository Locations 11

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A. OVERVIEW OF COMMUNITY INVOLVMENT PLAN The purpose and goal of this Community Involvement Plan (CIP) is to provide residents near the Imperial Refining Company Superfund Site (IRC) and other interested parties timely and accurate information about the site and upcoming events. This allows all parties to maximize their participation in all phases of the cleanup, including the Remedial Investigation and Feasibility Study (RI/FS), Proposed Plan, Record of Decision (ROD), Remedial Design and Remedial Action, and the decision-making process. The community outreach is a cooperative effort of the United States Environmental Protection Agency (EPA) and the Oklahoma Department of Environmental Quality (DEQ). This plan outlines the general communications efforts for IRC and may be modified and updated as necessary. These efforts will be explained in-depth in the Section D of the CIP. B. CAPSULE SITE DESCRIPTION Site History The Imperial Refining Company (IRC) is an 80-acre abandoned former crude oil refinery located on both sides of State Highway 142 in northeast Ardmore, Carter County, Oklahoma. IRC operated from 1917 until 1924. All the tanks and process equipment were dismantled by 1948. The site is heavily vegetated and contains numerous pits, waste piles and water impoundments contaminated with metals and refining wastes. Waste areas are characterized as dry, asphalt-like tar mats that tend to flow during hot weather and are associated with oil-contaminated soil on top of an oil-stained clay. Other wastes include contaminated soils from tank bottoms, coke piles, reservoir sediments and rubble from buildings. One large waste area contains several abandoned, partially crushed 55-gallon drums. Chemicals found in various areas include benzene, toluene, ethylbenzene, and xylene (BTEX), polyaromatic hydrocarbons (PAHs), oil and grease, and heavy metals. More investigation is necessary to determine the chemical risks at the site but there are also numerous physical hazards at the site, such as rusted, partially crushed drums, large quantities of broken glass, and open pits. Site Description/Location The site is bounded by undeveloped property to the south and east. Several small businesses, an active refinery, and a small residential area with about a dozen houses are located north of the site, and west of the property are several active waste water treatment lagoons operated by the active refinery. Directly south is a closed City of Ardmore landfill dating from the early 1970’s. South and west of the site Unocal is performing a voluntary cleanup of the former Pure Oil Refinery that operated from 1916 to 1936.

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Site Inspections and Cleanup Activities In September 1998, DEQ referred the site to EPA because of the threat posed to human health through direct contact with waste. EPA inspected the site and wrote a Removal Assessment Report in May 1999 and then listed the site on the National Priorities List (NPL) in May 2000. In December 2001, the Agency for Toxic Substances and Disease Registry (ATSDR) prepared a Public Health Assessment as required by Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The state of Oklahoma, Department of Environmental Quality will function as the lead agency for the remedial and community involvement activities. EPA will work with the state, community, and the tribal entities in a cooperative manner to facilitate the planning and implementation of the work at the site. The property has changed ownership several times and is currently held in a family trust and there are no other potentially responsible parties (PRPs). C. COMMUNTIY BACKGROUND Community Profile The city of Ardmore is comprised of approximately 24,000 people. Ardmore has a Council/City Manager type of government. There is a comprehensive city plan and zoning. Ardmore is the county seat of Carter County. There is an estimated population of 2,250 living within a 1-mile radius of the site. By the early part of the 20th Century, Ardmore was well established, with the largest population in Indian Territory. Its economic base was cotton. It was the largest inland cotton market in the United States. As the prairie soil depleted and cotton was no longer raised, the Healdton Oil Field was discovered, and oil became the economic base for the community. Ardmore has a rich history and has seen the oil business “boom and bust”. In the early part of the 20th Century Ardmore was alive with several active refineries. These refineries came and went quickly, often leaving large quantities of waste products in their wake. Currently, Valero Energy Company operates the only active refinery in Ardmore. Ardmore prides itself for its historical, current, and future development. The community has an active refinery, a Michelin tire manufacturing plant, and numerous medium to small businesses. Ardmore aggressively recruits new businesses for the area. Ardmore is also very proud of the outdoor activities that are available throughout Carter County, including seven local lakes, numerous hiking and camping areas, as well as numerous fishing and hunting opportunities. Ardmore is also developing a City of Ardmore Trails Plan. They have picked several sites around the city to build twenty biking, jogging, and skating trails for public use. They have shown interest in building one near or through the site once it has been cleaned up.

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History of Community Involvement January 2001 IRC was originally identified during a record search for abandoned refineries that once operated in Oklahoma. IRC was listed on the National Priorities List in May 2000. At that time, a newspaper article was written in The Oklahoman newspaper about the listing and the site. The local paper, The Daily Ardmoreite, also carried an article about the site when the Agency for Toxic Substances and Disease Registry (ATSDR) held a Public Availability Session in Ardmore on January 24, 2001. During the session EPA, ATSDR and DEQ met with several local and area officials, and approximately five area residents. Most people at the meeting knew of the site and expressed enthusiasm that the site would be cleaned up. Several City of Ardmore officials were present. Their concerns ranged from the potential for the site to contaminate streams from runoff to concerns about public perception and how to best handle public concern and questions about the site. The area representative for the Oklahoma Department of Transportation (ODOT) had concerns about the site because it is transversed by Highway 142. A portion of Highway 142 was scheduled for a repaving project, and ODOT was concerned about the potential for exposure of unknown chemicals to the workers. After discussion with DEQ and further research, ODOT decided to perform the project in a way that would not expose the worker to the underlying soil of the highway. March 2001 EPA issued a public notice in the Daily Ardmoreite announcing the availability of a technical assistance grant. April 2001 A citizens group called the East Side Renaissance, Inc. held a meeting on April 16, 2001. Participants included the members of East Side Renaissance, Inc., Ardmore Beautification Council, Carter County Health Department, ATSDR, DEQ, and EPA. Topics included an update of the IRC site, Brownfields potential, revitalization/redevelopment potential, environmental justice issues, technical assistance grants, and the City of Ardmore Trails Plan. Sandy Butler of the Carter County Health Department facilitated the meeting. East Side Renaissance requested a technical assistance grant from EPA to monitor the progress at the site once remediation efforts start. The grant request was not awarded due to protest by another member of the group. The group was told they could reapply if they could come to an agreement about its leadership. The technical assistance grant is still available. April 2002 The DEQ and EPA held a Community Involvement Meeting April 23, 2002, at the Ardmore public library to discuss the site with interested community members and local officials. Prior to the meeting EPA set up interview times with local officials. An interview questionnaire was reviewed with the participants. Most were aware of the site by word-of-mouth or through the newspaper articles. Most wanted to be added to the mailing list for future information.

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Key Community Concerns Local officials were concerned about public perception of a Superfund site in the community. It was noted by some that the site is used for hunting. Currently, the site is not fenced and this allows for unrestricted access. The City of Ardmore Water Division has a permitted waste water discharge point downstream of the site and are required to meet strict discharge criteria. The Water Division is concerned that any new discharges to the creek may impact its permit limits. They are also interested in the future plans for the wetland area on both sides of Highway 142. EPA and DEQ who went door-to-door on April 24, 2002, to inform local residents and businesses of the community involvement actions. Many of those that were home or available to discuss the site seemed pleased that the site is being addressed. Several citizens had lived and raised children in the area and noted that the children would often play in the old refinery area. Often, the children would come home covered in refinery type wastes. Some residents stated that many people in the area had died of cancer and they wanted to know if it could be related to exposure from the site or the active refinery. The citizens were aware of hunting and fishing that occurs at the site. Illegal dumping was also a concern. Some complained of odors from the area, but it is believed that the odors originate from the active refinery wastewater ponds. Several people asked about how the area would be zoned after the clean up was complete. Zoning of the property will be a local issue. We informed them that we would assist the community with technical expertise during the zoning process, if requested. Response to Community Concerns Further site-specific education for the local community will greatly improve the perception about the future of the site. Many people interviewed showed interest in improving the area through the remediation efforts. In an effort to remain responsive to the community, the DEQ will use the following techniques. DEQ will conduct community outreach using both formal and informal means, which may include meetings with community leaders and elected/appointed officials at local, state, and federal levels, publications and newsletters, fact sheets, regular scheduled meetings with area residents, news releases to the media, and updating the information repository. Most meetings will be held at the Ardmore Public Library, which is also the location of the information repository. Should a technical assistance grant (TAG) be awarded and/or community advisory group (CAG) be formed the groups will disseminate information to the community and inform DEQ of any questions or concerns of the community. Notification of public meetings will be accomplished through announcements in the newspaper and potentially the water utility bill. Public notices will be placed in the local paper at least five days prior to the public meetings and will run daily up to the meeting. DEQ or EPA Region 6 personnel will handle informal inquiries from homeowners and other interested parties about the site.

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D. COMMUNITY INVOLVEMENT PROGRAM The overall goal of the community involvement program is to promote two-way communication between citizens and DEQ and to provide opportunities for meaningful and active involvement by the community in the cleanup process. The plan is designed to be flexible and responsive to changing community concerns. The following plan is based on the results of the prior community interviews. DEQ will implement the following community involvement activities.

1. Establish Community Involvement Contacts composed of DEQ personnel and EPA Community Relations personnel to act as points of contact for all information and activities related to this plan.

2. Provide Technical Assistance Grant (TAG) information to the community. Should EPA

award a TAG, the DEQ and EPA will provide site information and assistance as necessary.

3. Maintain open and ongoing communications with the community to provide information about plans, ongoing work, site developments, and remedial activities, as well as, to provide mechanisms for the public to voice their concerns to DEQ. This will be accomplished with newsletters, fact sheets, and open house informational meetings which will be scheduled when activity at the site changes and/or when the community has shown interest or concern in learning more about ongoing activities at the site. A public meeting is required during the Proposed Plan comment period.

4. Provide phone numbers of DEQ and EPA contacts so that information regarding ongoing

activities can be obtained, and concerns can be noted and addressed in a timely manner.

5. Provide opportunities for the community to learn about site developments, major project milestones, and maintain a local repository containing copies of site documents and other pertinent information about the site.

6. Review the Community Involvement Plan periodically and make revisions, as necessary.

7. Maintain a mailing list for the site. This will help facilitate the distribution of site-specific

information to everyone who needs or wants to be kept informed about the site.

8. A public notice announcing the public comment period will be published in the major local newspaper to solicit comments for the Proposed Plan. This required comment period will give community members an opportunity to review and comment on the Proposed Plan. This provides the citizens with meaningful involvement in the process and also provides DEQ and EPA valuable information for use in decision-making. A public meeting will be held in conjunction with the Proposed Plan submission.

9. Prepare and issue a Responsiveness Summary. This will summarize comments received

during the comment period, document how the agencies have considered those comments during the decision-making process, and provide responses to comments.

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Appendix A DEQ and EPA Contact

Angela Brunsman Tel: 405-702-5135 Project Manager Fax: 405-702-5101 Department of Environmental Quality P.O. Box 1677 Oklahoma City, Oklahoma 73101 Monty Elder Tel: 405-702-1017 Public Information Officer Fax: 405-702-1001 Department of Environmental Quality P.O. Box 1677 Oklahoma City, Oklahoma 73101 Katrina Coltrain Tel: 214-665-8143 Remedial Project Manager Fax: 214-665-6660 U.S. EPA, Region 6 Toll Free: 800-533-3508 1445 Ross Avenue Dallas, Texas 75202 David Birdsong Community Relations Tel: 214-665-2221 U.S. EPA, Region 6 Toll Free: 800-533-3508 1445 Ross Avenue Dallas, Texas 75202 Dawn O’Connor Tel: 888-422-8737 Community Involvement Specialist Community Involvement Branch Agency for Toxic Substances and Disease Registry

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Appendix B Local Officials

Mayor Sheryl Ellis 580-223-3055 1003 6th N.E. Ardmore, OK 73401 Vice-Mayor Martin Dyer 580-223-1656 P.O. Box 546 Ardmore, OK 73401 Ardmore City Commission Martin Dyer 580-223-1656 P.O. Box 546 Ardmore, OK 73402 Bob Geurin 909 Rockford Place 580-226-2465 Ardmore, OK 73401 David Mordy 580-226-3311 P.O. Box 457 Ardmore, OK 73402 John Moore 580-223-4347 1003 6th NE Ardmore, OK 73401 City Manager Dan Parrott 580-221-2561 P.O. Box 249 Ardmore, OK 73402 Local Health Officials Mindy Spohn 580-223-9705 Carter County Health Department 101 1st Street Ardmore, OK 73401 Fire Department J.D. Spohn – Fire Chief 580-221-2550 115 North Rockford Road Ardmore, Oklahoma 73401 Police Department Jim Hughes – Police Chief 580-223-1212 23 South Washington Ardmore, Oklahoma 73401

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Appendix C Elected State and Federal Officials

Senator Don Nickles (Republican – OK) Tel: 202-224-5754 United States Senate Fax: 202-224-6008 Washington, DC 20510-0001 Senator James Inhofe (Republican – OK) Tel: 202-224-4721 United States Senate Fax: 202-228-0380 Washington, DC 20510-0001 Representative Tom Cole (Republican – Congressional District 04) Tel: 202-225-6165 United States House of Representatives Fax: 202-225-3512 Washington, DC 20515 Senator Johnnie Crutchfield (Democrat – State District 014) Tel: 405-521-5607 2300 North Lincoln Boulevard, Room 416 Fax: 405-521-5507 Oklahoma City, Oklahoma 73105 Representative Greg Piatt (Republican – House District 048) Tel: 405-557-7326 2300 North Lincoln Boulevard, Room 300-B Fax: 405-557-7351 Oklahoma City, Oklahoma 73105-4805

Appendix D Tribal Groups

Chickasaw Nation Kyle Walls Tel: 580-332-8759 P. O. Box 1548 Ada, Oklahoma 74820

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Appendix E Environmental and Active Citizens Groups

Ardmore Beautification Council Tel: 580-223-2230 333 West Main, Suite 340 Fax: 580-223-2285 P.O. Box 1744 Ardmore, Oklahoma 73401-1744 Ardmore Trails Commission Sandy Butler Tel: 580-490-6174 1909 Harmony Ardmore, Oklahoma 73401 Eastside Renaissance, Inc. Tel: 580-223-6367 Garry Raymond 702 East Main Ardmore, Oklahoma 73401 Earthday Coalition Tel: 580-223-4597 Maria Wilkinson 412 I SW Ardmore, Oklahoma 73401

Appendix F Media Contacts

Channel 12 KXII-TV CBS Affiliate Tel: 580-223-0946 2624 South Commerace Fax: 580-226-8884 Ardmore, Oklahoma 73401 The Daily Ardmoreite Tel: 580-223-2200 117 West Broadway Fax: 580-226-0050 Ardmore, Oklahoma 73401 KCCU Radio Tel: 580-581-2472 2800 West Gore Boulevard Fax: 580-581-5571 Lawton, Oklahoma 73505 The Daily Oklahoman Tel: 405- 475-3311 P.O. Box 25125 Oklahoma City, Oklahoma 73125-5125

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Appendix G Meeting Location

Ardmore Library Tel: 580-223-8290 320 E Street NW Fax: 580-223-2033 Ardmore, Oklahoma 73401

Appendix H Repository Location

Ardmore Library Tel: 580-223-8290 320 E Street NW Fax: 580-223-2033 Ardmore, Oklahoma 73401 Department of Environmental Quality Tel: 405-702-5100 Land Protection Division Fax: 405-702-5101 707 North Robinson Oklahoma City, Oklahoma 73101 U.S. Environmental Protection Agency Tel: 214-665-6548 Region 6 Library - 7th Floor Toll Free: 800-533-3508 1445 Ross Avenue, Ste. 1200 Dallas, Texas 75202

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