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B ,. _, Ur_IKIS_ Officeof EPNR(X__ _- E_!aJ Prolec_ion Emergencyand Sepl_nl_' 1990 Agency Remed_ Rede '1 &_ Superfund Recordof Decision: t,. Tenth Street Dump/Junkyard, OK _cy I
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,. _, Ur_IKIS_ Officeof EPNR(X___- E_!aJ Prolec_ion Emergencyand Sepl_nl_' 1990

Agency Remed_Rede

'1&_ Superfund

Record of Decision:t,.

TenthStreetDump/Junkyard,OK

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I · PAGE I EPA/ROD/R06-90/059l__ L_

/__ SUPERFUND RECORD OF DECISION 09/27/90-- Tenth Street Dump/Junkyard, OK

First Remedial Action - Final &

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U.S. Environmental Protection Agency 800/000401 M Street, s.w.

Washington, D.C. 20460

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The 3.5-acre Tenth Street Dump/Junkyard site is an inactive landfill in Oklahoma City,

Oklahoma, within the North Canadian River's 100-year floodplain. There are two

residences and a salvage yard within 100 yards of the site. From 1951 to 1979, the

site was used, in succession, as a municipal landfill, a privately owned and operated

salvage yard, and an automobile salvage yard. Waste materials accepted by the first

_"salvage yard included paint thinners, old transformers, and tires. Dielectric fluid

that contained PCBs was drained from old transformers, stored in barrels, and sold.

During this PCB recovery process, substantial quantities of PCB-contan_Lnated oil were

spilled onto the ground at the site. In 1983, EPA site inspections located 20 drums,

some of which were corroded and leaking contaminated material into the soil. Soil

samples, taken on and around the site, showed contamination by hazardous materials,

particularly, high levels of PCBs. In 1985, EPA completed removal actions, which

included disposal of drums containing hazardous waste, decontamination and relocation

of Junk automobiles, consolidation of contaminated soil to the center of the site,

installation of a plastic liner and a clay cap, and installation of security fencing.

This Record of Decision addresses soil contamination at the site. It is estimated

(See Attached Page)

l_Docmumt&u'ldo&boMplmRecord of Decision - Tenth Street Dump/Junkyard, OKFirst Remedial Action - Final

Contaminated Medium: soil

Key Contaminants: organics (PCBs)

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EPA/ROD/R06-90/059

' f"_ Tenth Street Dump/Junkyard, OK{ First Remedial Action - Final

Abstract (Continued)

that 8,500 cubic yards of soil are contaminated by PCBs, with 7,500 cubic yards of this

total having PCBs levels above the TSCA PCB spill cleanup policy level of 25 mg/kg. The

primary contaminants of concern affecting the soil are organics including PCBs.

The selected remedial action for this site includes removing the red clay cover andplastic liner_ excavating an estimated 7,500 cubic yards of PCB-contaminated soil with

concentrations of 25 mg/kg and higher, followed by treatment of the excavated soil by

chemical dechlorination and carbon adsorption to control air emissions_ and backfillingand regrading the excavated area with clean and treated soil. The estimated presentworth cost for this remedial action is $4,044,000. There are no O&M costs associatedwith this remedial action.

PERFORMANCE STANDARDS OR GOAL_: Contaminated soil with greater than 300 mg/kg PCB (an

order of magnitude higher than the health-based goal) is considered the principal

threat. However, the soil excavation goal is PCB 25 mg/kg (TSCA), due to the costeffectiveness of treating soil with iow levels of PCBs along with the highlycontaminated soil, and is based on a 10-6 excess cancer risk level. Soil residuals will

contain less than 2 mg/kg PCBs.

f--_ DECLARATIONTENTH STREET DUMPRECORD OF DECISION

SEPTEMBER 1990

Statutory Preference for Treatment as aPrincipal Element is Met

and a Five-Year Review is not Required

SITE NAME AND LOCATION

Tenth Street Superfund Site3200 NE Tenth StreetOklahoma C_ty, Oklahoma

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for theTenth StreetSite _n OklahomaCity,Oklahoma,which was chosen in accordance

with the ComprehensiveEnvironmentalResponse,Compensationand LiabilityiAct of 1980 (CERCLA), as amended by the Superfund Amendments andReautnorlzation Act of 1986 (SARA), and, to the extent practicable, !

_ the NationalOil and HazardousSubstancesPollutionContingencyPlan(NCP). This decision _s based on the administrative record for thissite.

The State of Oklahoma does not support the selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, ifnot addressedby implementingthe responseactionselected_n the Recordof Decision (ROD), may present a potential endangerment to public health,welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

Tne selected remedy addresses the principal threat posed by the sitethrough chemical treatment of PCB contamnated soil at the site. Treatedso_l w_ll be d_sposed on site to backfill the excavated area.

The major components of the selected remedy include:

· Remove the ex_stlng red clay cover and the visqueen plasticliner.

· Excavate an estimated 7,500 cu. yd. of PCB contaminated soil withconcentrations of 25 ppm and higher.

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e Chemically treat the excavated contaminated soil by a chemicaldechlo_ination process meeting the Toxic Substance Control Act (TSCA)PCB alternative treatment requirements.

· Backfill the treated soil in the excavated area.

· Grade the site for effective drainage and establish vegetative cover.

-STATUTORY DETERMINATIONS

The selected remedy is protective o¢ human health and the environment,compiles with federal and state requirements that are legally applicabiPor relevant ano appropriate to the remedial action, and is cost effective.This remedy utilizes permanent solutions and an alternative treatmenttechnology to the maximum extent practicable and satisfies the statutorypreference for remedies that employ treatment that reduces toxicity,mobility, or volume as a principal element.

Because this remedy wilt not result in hazardous substances remainingonsite above health-based levels, the five-year review witl not apply :

to this action, i

Robert E. Layton_r.,_.E. Date '_Regional _dministrator

2

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I) I. LOCATIONANDDESCRIPTION

The Tenth Street STte (the "sTte") Ts located at 3200 NE Tenth Street, Tnthe far eastern boundary of Oklahoma City, Oklahoma (Section 31, Township12 North, Range 2 West, of Oklahoma County). The site is approximately3.5 acres in sTze. It is situated TmmedTately south of NE Tenth Streetand 1Tes between Bryant Avenue and the North Canadian River. StandishAvenue, a STde street east of Bryant, is the North-South street closestto the western boundary of the site (see Figures 1 & 2). The site isalso situated in the 1OD-year flood plain of the North Canadian River.The area Tn the vlcTnity of the STte iS used primarily for lndustrTalpurposes.

VegetatTon _n the area Ts d_rectly related to the North CanadTan RTverand to the degree of urbanization. It consists of marsh grass and willowand cottonwood trees alongthe rTver banks. Grasscovered f_elds and lotsaway from the river are punctuated by varieties of elm, backjack, postoak and other decTduous trees. Around the site are primarily short grasseswhTle the sTte itself is covered by a tall grass.

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WTtnin 100 yards of the western sTte boundary _s a resTdence. East of ithe site about 75 yards _s a residence and a salvage yard (Figure 2).Two Tndlv_duals live at the residence adjacent to the salvage yard and !one _nd_vldual I_ves at the residence west of the s_te. There are about

30 visitors per day at the salvage yards and about 4 vis,tots per day at/f-' the nome west of the site.

According to a 1985 traffTc count, approximately 16,000 cars per day passthe site on the NE Tenth Street. The closest population centers areOklahoma CTty (446,120, 1986 census records) and Del CTty (28,523, 1980census records).

The Oklahoma C_ty publTc water supply source is Draper Lake. Del Cityuses surface water from Thunderbird Lake and ground water for Tis sourcesof drinking water. Both Draper Lake and Thunderbird Lake are outsTde ofa three-mle radTus of the site. Water supply for about 29,218 peoplewlthTn a three-m_le radius of the sTte ts provided by ground water fromthe Gather-Wellington formation.

The nearest major surface water body Ts the North Canadian River, whichl_es south and east of the site. RegTonal dra4nage ts toward the riverbut local topography Causes some varlatlons tn this patteen. Two southeasttrending trTbutarles about 200 to 400 yards west of the site become confluentand join the North Canadian RTver about ¢00 yards south of the site.About 0.25 m_le tO the northeast of the s_te are two large ponds whichwere previously quarrying pits for sand and gravel.

The site rests on unconsolidated Quarternary alluvium deposits of theNorth CanadT_n River (Figure 3); its thTckness ranges from a few inches

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The site rests on unconsolidated Quarternary alluvium deposits of theNorth Canadian R_ver (F_gure 3); its thickness ranges from a few inches

/--'x up to 100 feet. Beneaththe s_te, the alluviumis about 30 feetthick.t ?i The Garber-WellingtonFormationunderliesthe alluviumwith the Hennessey

shale strat_graphically positioned _n between. However, the Hennesseyshale _s not present underneath the site.

The Garber-Welllngton is the most Important source of ground water in theOklahoma City-Del City-M_dwest City area. In the vicinity of the site,the base of fresh water is sloped from 600 to 300 feet above sea level.The Hennessey shale is not a s_gnlf_cant aquifer but the water _s ofsufficientyield and qualityto providewater suppliesfor domesticandagricultural use (ground water classification 2B).

Ground water beneath the site is present _n at least two distinct zonesas _nd_cateday f_eld investigationsand water qualitydata. A shallowwater-Deamng zone exists from 6 feet to at least 30 feet below groundsurface (BGS). The water table ranges from 6 to 10 feet BGS and slopesgently to the south-southeast, towards the North Canadian River (Figure4). Another zone }s present at about 160 feet BGS. The upper and lo_erbounds of this deeper zone are not known. Nor is it known if other waterbearing units ex,st between these shallow and deep zones.

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II. SITEHISTORYANDENFORCEMENTACTIVITIES [

!Evidencefromaerialphotographsindicatethat the area was operatedas a

municipallandfillbetween 1951 and 1954. From about 1959 to 1979Mr. RaymondCobb leasedthis s_teand operated1C as a salvageyarduntil his death in 1979. During his operation, materials such as paintthinners, tires, and old transformers were accepted in the salvage yard.Dielectricfluid that conta_neapolychlorinatedbiphenyls(PCBs)wasdrained from old transformers, stored iA barrels, and sold. During therecovery process, substantial quantities of oil were spilled onto theground. After Mr. Cobb's death,Mr. RollingFu!lbrightoperatedthe siteas an automobile salvage yard called Deadeye's Salvage Yard.

In 1983, the Field Investigation Team of the Environmental ProtectionAgency (EPA) _nspected the site and observed about 20 drums, some ofwhich were corroded, leaking, or bulging. LiquiOs contained _n the drumsand so_ls from the surrounding area were sampled by FIT. High concent-ationsof volatile organic compounds, benzene, polynuclear aromatics, methylenechloride, methylene phenol, ethanol, tetrachloroethane, acetone, andCetracnloroethylene were detected in soil. Subsequent sampling in 1984and 1985 by the the Technical Assistant Team (TAT) of EPA detected highconcentrations of PCBs _n the so_l on and around the site.

In August 1985, the EPA Region 6 Regional Administrator approved anemergency response action to remove and dispose of electrical equipmentand drums containing hazardous substances. Th_s authority also includedactions to decontaminate and relocate junk automobiles, consolidatecontaminated so_ls to the center of the site, grade the site for effec-tive drainage, _nstall a synthetic l_ner and clay cap, and erect a

7

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OROUNOWA'III_ I_'VAIlONI

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Igp _ELD INVESTIOATION ,j . FIGURE4 _)___

a security fence around the site.

F'_'_ After completion of the removal action the site was evaluated under thecriteria fo_determining priorities amonQ releases or threatened releasesthroughout the Uniteo States for the_purpose of taking remedial action.In January !987, the site was proposed For inclusion on the NationalPriorities List (NPL) due to the potential for ground water contamination.The site was placed on the NPL in July !987.

A remedial investigation and feasibility study (RI/FS) was conducted byEPA Reoion 6 in Spring 1989 to identify the types, quantities and locationsof contaminants, to identify the risk from these contaminants and toaddress the contamination problems. The RI consisted of a comprehensivefield sampling and analysis program Followed by validation and evaluationof the data collected. The RI report was _inalized and released to thepublic in March !990.

The results of the RI identify that:

o PCBs are the contaminants of concern at the site, based on concentrationand risk; the predominant PCB species present is Aroclor 1260;

o Contaminationis limitedto soil at the site; and i

o Groundwater or surfacewater contaminationwas notdetected.

Fr_, The Feasibility Study Report and Risk Assessment Report for this sitewere completed in July 1990. In August 1990, the FS report and the RiskAssessment report were released to the public along with the ProposedPlan. A 30-day public comment period was provided, ending onSeptember 8, 1990.

Searches %r potentially responsible parties (PRPs) have been conductedand two possible PRPs, Mr. Sullivan Scott and Mr. Elmer Cobb, were identified.Upon further investigation, other PRPs may be identified. The known PRPswere notified in w_iting on March 23, 1989 via a general notice letterand given the oDportunity to conduct the RI/FS under the supervision ofEPA. However, neither has elected to undertake these activities.

III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

A Community Relations Plan for the site was developed and finalized inJune 1989. This document lists contacts and interested parties throughoutgovernment and the local community, and locations for information repositories.It also establishes communication pathways to ensure timely disseminationof pertinent information. Fact sheets outlining the RI and its orogresswere distributed. An open house to provide information on the RI activitieswas held in September 1989. The RI report was released to the public inMarch 1990. The FS Report, Risk Assessment Report, and the Proposed _lanwere released to the public in August 1990. An open house to provideinformation on the FS and the Proposed Plan was held on August 7, 1990.Ail of these documents were made available in the administrative record and

9

information repositories maintained at' the Oklahoma City Public Works_epartment, Oklahoma State Department of Health, and the Ralph Eilison _ 'Library. _ public comment period was held ¢rom August 9, 1990 toSeptember 7, 1990. & public meeting was held on August 14, 1990 to presentthe results of the RI/FS and the preferred alternative as presented inthe proposed plan for the site. Ail comments which were received by EPAwithin the comment period, including those expressed verbally at thepublic meeting, are addressed in the responsiveness summary section ofthe Record of Decision.

IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY

As characterized by the RI, the problems at the Tenth Street SuperfundSite are limited to soil contamination. The site was determined to posea principal threat because of the potential for direct contact with thecontaminated soil and the soil's potential impact on ground water. Thescope of the response action is to address the principal threat at thesite by preventing current or future exposure to the contaminated soilthrough treatment and/or containment, and reducing or controlling thepotential migration of contaminants from the soil to ground water.

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V. SUMMARYOFSITECHARACTERISTICS i

!Analyses of soil, ground water, and surface water from the site and

adjacent areas indicate contaminants at the site are primarily related toPCBs. Other contaminants do not pose a health risk, based on the riskassessment. Contamination is limited to soil at the site.

Soil

Soil samples were collected at selected intervals during the drilling offive ground water monitoring wells and 26 shallow boring; of these 31locations, two monitoring wells and 11 shallow borings are offsite (Figure5). A summary of the PCB soil sampling results is listed in Table 1.The concentrations of PCBs range from 41 ppm to as much as !700 ppm,while the average concentration is 110 ppm. Kigure 6 shows total Aroclorconcentrations without species differentiation.

Laterally, PCBs are generally located more towards the central portion ofthe site. Vertically, PCBs are present from 1 ft to as much as 8 _tbelow the ground surface (including the thickness of the cap). Excludingthe cap, the maximum depth of contamination or thickness of contaminatedsoil below the protective cap is about 6.7 ft. In general, contaminatedsoil is about 1 foot thick at the cap periphery, while it is between 3 to6.7 ft thick towards the center of the cap. The increase in the thicknessof contaminated soil from 2 feet in 1985 to 6.7 feet in 1989 (Figure 7),is due to grading of soil towards the center of the site during constructionof the protective cap. Contamination greater than the 25 ppm PCB remedialgoat was not detected at depths greater than 6 feet. The deepest pointwhere contamination was detected is about 3 _t above the ground water

table.

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TENTHSTREETSUPERFIINDSITE

HAX, TOTAL RORF.CAP SAUPLE EXCESS tlAX, rlEPTH THICKNESS RURRLE HALF.

_;AtlPLE SAIIPLE THICKNESS I_EPTH PCBCONt, CANCER PCBCOtlTAtl. OF CONTAPI. THICKtlESS qEPTHLOCATION STATION tFT) . fFT) :(DOm) RISKL SqlL ?eFT1 SrlTL (FT) fl:T) JrT)

B-I SOl? 2.0 't.R 10.'t 1._-10'45013 6.n 16.0 1.R-10'4 6.0 4.0 7. :_ 7.9

fi-? S, 14 0.6 1._ _._. 1.4-10'_SOT5 R.11 BIlL 0.17 ?. 1-111'_ l.ci o.q ?.q _.11

B-1 c;1116 0.11 1.6 Rr)L 0.17 :).q-lO'_ 0.11 0.11S017 R.11 RDL 0. -7 ?.11-10'R 1.7 R.O

,-, B-4 50!8 0.0 1.R 0._ 3.1-10'_ 0.11r.o soIq 5.11 0.'_6 R._-IO'R 11.11 R.11 R.rl

B-5 SO20 0.11 1._ BDL O._. 't. 4-10'R 11.11SO_l 5.11 RDL 0._ ?.4-10'S 0.0 5.q "_,11

R-6 5073 0.11 1._ R[1L0.17 2. q-lO'S O.fi

S0_4 5.11 ROLO.:P ?. q-lO'_ 11'11 w 0.0 R.q

B-7 S1175 0.0 1.R BDL 0.17 !.4-lO-_ 11.115026 5.11 RI_LO. IR 2.2-10'R O.O q.n _.O

R-8 S027 I1.11 l._ RDL 0.17 1.q-10-_ 11.11S028 _.0 BDL O. 1R 6.4-10'_ 11.11 6.q _.q

B-9 SO_J 0.0 1.11 BOLO. 1R 1.fi-10'R 0.11SO10 _.0 RI)L 11.17 ?. 1-10'_ 0.0 q.O fi.O

B-lO SO?il 0.11 1._ BDL 0.19 1._-10'4 0.115032 R.O RDL 0._0 2._-10'R 0.11 _.fl R.O

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flAX. TOTAL RNRECAP _AtlPLE EXCESC; flAX. r}EPTH THICKNESS RIIRBLE tlOLE

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LnCATION STATINN lET) eFT) (Dom1 RISK SnlL (FT) SOIL (Fi,T) fFT) fFTI

R-11 S034 O.N 1.5 RDL 0.19 1._-ln-A 0.0 0.0

S015 1.N RDL 0.!9 7.4-10-_ :_.R ?.0

8-12 S0t6 1.; ?._ RO0 _. 1-10-3

S017 5.0 RnL fi.iR 1.q-10'5 2._ 1.0 1._ 5.0f

R-Il 5038 f}.R 1.R 700 :_.:_-10'1

SOl9 5.0 RDL fi. lq 1.7-10-_ 1.R 1.0 5.0 r_.o

R-14 S040 0.0 1.R N.R6 l._-lO-5

S041 5.0 RIlL 0.71 P.5-IO'R 1.5 I. _i 4._ R.n

11-15 S042 1.1 1.1 420 4.4-10'1

5043 R.O _60 ?.q-lO'_ 8.0 6.7 6.0 /1.0

R-16 S045 9.9 q.r} 0.5 ?.6-10'5

_, S046 4.5 nOL 0.17 ?.0-10'5 3.11 f}.R flOflE 4.R

R-17 S/147 1 ./I 7.0 190 2.P-10-1

SO4R 6.0 RflL 0.17 2._-1fi'5 _.11 1.11 1.0 6.0

B-18 S049 O. 7 1.7 106 .3.1-10'1

sor-,o 3.q 11DL11.71 9.1-10'5 1.? 1./1 2.? q.q

6-19 _051 O.R 1 .R 140 1.R-lO'3

5052 4.0 200 2.1-10-3 4.11 3.7 4.0 4.n

R-:_O 5053 l.n _./1 _07 2.1-10'3

S054 9./1 BDL 0.!9 ?.1-10'5 7.t 6.3 A.O q.11

8-21 S056 1.11 2._ AOL 0.90 7.6-1fi'5 0.0

S057 4.0 BDL 0.19 9.4-10'5 0.0 _.R _.0

R-22 S0r-,8 O.R !.R RDL 0.lq 4.0-1,9-5

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N.E. TENTH STREI:._

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<1 / !l_m som<l

residence0 I -- 1.3 I<1 sal_ge yard. · 0 B--_I ....

.vrJ-s o-2 I < I .....residence <l am4- z2 I _ ·

f016 < I · B--15 /· g) 1042- 420 PW-1

/ m-a .o43- = ' SITE BOUNDARY ) ._1_-I$0S3 - $07 m =

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.""010-17

TENTH STREET SUPERFUND SITE 'i=,< , ._'l_;,_ AROCLOR (PCB)O.

'-" .... '"" .... CONCENTRATIONS' (3 0

32o0N.E.TENTHSmEET -_<' <, _ <'...j ,-% IN SOILOKLAHOMA CITY: OKLAHOMA sm-. _o<I <1

o FIGURE 61989 FIELD INVESTIGATION e-4 .-3

_ _ mm mm m m m, .-m

rj i, [i

S I · · ·

T I CALCULATED INTERVAL OF CONTAMINATED-1 --_ SOIL WITH EXCESS CANCER RISK >5E-5. Im_l.

m.-s I _ N

_ e e-4 FENCE LINESL.:' z/'"

iL Ill ill

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I '?,Ill%"_-., __._' I 1' _"'" _" /'_l -_ [

: i '-"TENTHSTREETSUPERFUNDSITE.3200 N.E. TENTH STREET ' CONTAMINATED SOILOKLAHOMA CITY, OKLAHOMA . "1ffi1_s ·. I'°t' (BENEATH PROTECTIVE CLAY CAP)

" "mll_,mlml--

............... _,11 FIGURE .7

J

Durino preparation of the feasibility study report, review of the 1985Removal After-Action Report revealed that PCB contamination was detected

in the roao right-of-way at a depth approximately 4 ft. and the _rotectivecap was extended to the edge of the NE Tenth Street. This area ofcontamination is between the north fence line of the site and the edge ofthe NE Tenth Street. Additional sampling is planned and results will beusea to estimate the additional volume of contaminated soil to be addressedin the remedial action.

Only local concentrations of polyr,uclear aromatic hydrocarbons (PAHs)were detected (Tables 2 - 8). The levels are slightly elevated and areconsistently associated with burned rubble and landfill debris. Thesamples in which PAHs were detected contained burned wood, tires, andother debris typical of landfills.

Lead concentrations are slightly elevated in onsite areas but are withinnormal ranges in the offsite areas. The slightly elevated concentrationsof lead are typically associated with salvage activities. Lead at theTenth Street Site is most likely a result of automobile and other metalsalvage decomposition and corrosion.

Based on the results of soil sampling, it is estimated that approximately :

7,500 cu. yd. of soil contaminated with PCBs greater than 25 ppm are jpresent at the site. Of this volume, 6,500 cu. yds. are contaminatedwith greater than 300 _pm PCBs, representing the volume of material that Jposes the principal threat at this site. Principal threats are definedas soil contaminated an order of maQnitude or more above the health-based

coal set for the site. Soil contaminated between 25 ppm and 300 ppm!1,000 yds.) represents the low-level threat posed by the Tenth Streetsite.

Ground Water

Ground water samples were collected from the five monitoring wells fnstaiiedduring the RI and _rom one existing private well. Locations of groundwater samples are showr_in Figure B. PCBs or compounds that may act ascarriers for PCBs were not detected in ground water samples collected(Tables 9 and 10).

The ground water table at the site ranges from about 115!.7 MSL (Mean SeaLevel) to about 1150.0 MSL. Contaminated soil at its deepest point onsiteis approximately 3 Feet above the water table. The ground water wasmeasured in April 1989, a month in which ground water levels are consideredto be high in Oklahoma.

Surface Water

Surface water samples were collected from a tributary that runs by thewestern margin of the Site and from the North Canadian River (Figure 9).Contaminants attributable to the site were not detected in the surfacewater samples collected (Table 9 and !1). This conclusion is based onupstream samples beina equally or more contaminated than downstream samples.

17

I Table 2 Organicchemicalsaetecteain soil from theon-sitearea at the loth Streetsite _ '

. Range of

Upper Range of QuantitationCnemical Frequenc_ Average Bouna Detections Limits

Acenapntene 3/20 65 R 83 47-83 380-4300Acetone 15/20 13 35 5-47 12-13

Anthracene 7/20 160 R 260 48-260 380-4300

Aroclor1242 1/20 27,000 170,000 230,000 92-490,000

I Aroclor1254 4/20 40,000 100,000 290-100,000 180-970,000

i Aroclor 1260 16/20 180,000 940,000 270-1,700,000 180-200Benzene 3/20 3 3 0.2-3 6

i Benzo(a) 13/20 630 2200 110-2800 380-4300anthracene

Benzo(a) 16/20 580 1900 100-2500 380-4300 iI pyrene !

i Benzo{b) 17/20 750 2700 150-4300 380-850fluoranthene

Benzo(g,h,1) 11/20 510 1200 57-1200 380-4300

i perylene

Benzo(k) 12/20 850 3000 88-4300 380-4300

i fluoratheneB_s(2-etnylnexy])17/20 1200 5800 170-9900 380-420pnthalate

m carbon d_sulf_de 3/20 3 6 0.9-6 6

i Chloroform 7/20 0.6 R 2 0.2-2.0 6Chloromethane 3/20 2 2 0.6-0.9 11-13

m Chrysene 18/20 480 1500 15-2400 380-410

Dr-n-butyl- 5/20 410 460 49-460 380-4300

m phtnalate ,,'

I18

!

I T

Table 2 (continued)

A Range ofUpper Range of Quant_tationChf ',...'_, - [reque,ncy Averag e Bound - Oe,tection,s Limits

Oibenzo(a,n) 7/20 410 530 41-530 380-4300anthracene

DDT 3/20 100 162 44-162 19-49,000

Fluoranthene 17/20 650 2100 96-3000 380-440

Fluorene 3/20 50 68 _-68 380-4300

Indeno{1,2,3-cd) 12/20 490 1100 44-1100 400-4300pyrene

Phenanthrene 16/20 460 1400 90-1400 380-4300

Pyrene 16/20 620 1900 130-2200 380-4300

Tetrachloro- 3/20 3 5 3-7 6c

ethylene i

Toluene 6/20 2 3 0.2-3 6 !

1,2,4-Trichloro- 5/20 400 1400 52-1400 380-4100benzene

1,1,1-Trichloroetnane 3/20 3 3 0.3-0.4 6

Xylene 5/20 4 12 2-22 6

R - Recalculateausing only aetectedquantitiesof contaminant.

19

Table 3 ' Organic chemicals detectea in soit from the salvageyard area at the loth Street site

Range ofUpper Range of Quantitat_on

Chemical Frequency Average Bound D,etections Limits

Acenaphtene 1/4 43 43 43 340-380

Acetone 1/4 34 120 120' 10-12

Anthracene 3/4 120 200 66-200 370

Aroclor 1242 1/4 180 600 600 83-95

Benzo(a) 4/4 520 1200 210-1200 -anthracene

Benzo(a) 4/4 620 1500 210-1500 -pyrene

iBenzo(b) 4/4 1100 3000 350-3000 -fluoranthene !

Benzo(g,n,_) 4/4 290 640 100-640 -perylene

Benzo(k) 4/4 ggo 3000 260-3000 -fluorathene

Bis(2-ethylnexyl) 3/4 670 2100 150-2100 340

phtnalateChrysene 4/4 620 1500 220-1500 -

Dlbenzo(a,h) 3/4 120 190 49-190 370anthracene

Fluorancnene 4/4 1100 2500 380-2500 -

:ndeno(1,2,3-ca) 4/4 240 560 g1-560 -pyrene

Pnenanthrene 4/4 420 880 170-880 ' -

Pyrene 4/4 590 1300 230-1300 -

2O

!

JTable 4 Arganicchemicalsdetectedin soil from the off-site

area at the lothStreet Site I

. Range of 1UDDer Range of OuantttationKhem_cal ;requency Ave_aae Bound Detections Limits

Acenaohthene 1/7 41 41 41 _S0-390 I

Acetone 5/7 71 t6 1_-5g 11

Anthracene _/7 63 R 76 49:76 _0-490 I

Aroclor1260 1/7 110 lgg 220 170-lq0 IBenzo(a) 6/7 160 _60 43-260 t90anthracene

Benzo(a_ 5/7 160 _50 52-250 l?O-tgO Ioyrene

Benzo(b) 6/7 260 _20 _9-520 _gO IFluoranthene

Benzo (g,h,i) 4/7 140 170 94-170 _50-390 J Ioerylene !

Benzo (k) 617 _60 _2_ _8-520 _9_ I_'_" fluoranthene

Bis(_-ethylhexyl)6/? 290 1364 40-1600 _60 1ohthalate

£hrysene 617 200 q?O Bl-_70 tqO IFluoranthene _/? 560 _60 ?1-_60 _o-tqo

lndeno_l,_,t-cd_ 4/? qO R 1_0 46-1_0 t50-390 Ioyrene

Phenanthrene _/? 190 400 70-750 _gO Ipyrene _I? 110 ?2 70-7_0 _90

R = Recalcu3atedusing only detectedquantitiesof contaminant. I

I!

_- 21

IJ

I

Table 5 Comparison of _norganic cnemcals detected a',.

the loth Street s_teto backgroundlevels I

IChemical Rn-Slte SalvageYard Off-Site Loc j!._ Nationala

Aluminum 11000 10400 7170 <20000 66000 mAntimony 12 8 4.2 - -

Arsenic 13 15.9 2.6 - 6b IBarium 570 472 247 <300 554

Beryllium 0.29 0.22 0.32 >2 1 m

Cadmium 9.7 5.0 1.9 - 0.6 c

Calcium 27000 61000 15300 <30000 24000 I

Chromium 55.5 66.5 13 50 53 ICobalt 10.3 12.5 5.0 >15 10

Copper 708 400 50.6 20 25 i IIIron 57500 65100 10400 >30,000 25000

Lead 1100 769 289 >20 20 1

Magnesium 3450 3930 2430 <3000 9200 IManganese 480 581 219 >500 560

Mercury 0.22 0.67 0.071 - 0'3d I

Nickel 50.7 49.g 9.8 >20 20

Potassium 1990 1740 1160 <10000 23000 I

Selenium 0.47 nd nd o mSilver 1.7 nd n_ - 0.05e

Sodium 342 2530 80.1 <5000 12000 I

Thallium 0.28 nd nd - 5f

Vanadium 27.7 34.2 18.1 <50 76 I

Zinc 2170 1790 289 >,,00 " mCyanide 1.3 nd 0.8 - -

a

:2 I '

T

m

Table 6 Inorganic chemicals detected in soil from the on-site

area at the lothStreet site

Range ofUpper Range of Quant.

I Chemical Frequenc_ Average Bt'me Pletectlons LimitsAluminum 20/20 11000 180000 2990-19000 -

m Antimony 10/20 12 43 9.3-61.9 5.3-9.2

Arsenic 20/20 13 30 1.4-35.8 -

m Barium 20/20 570 1120 43.1-1120 -

I Beryllium 11/20 0.29 0.62 0.12-0.62 0.27-0.57Cadmium 18/20 9.7 24 0.9-27.5 0.72-0.88

I 20/20 27,000 44,200 2700-44,200 -Calcium

T

Chromium 20/20 55.5 120 4.7-120 - iII Cobalt 19/20 10.3 24.5 2.7-32.4 7.4 ! ,:

Copper 20/20 708 3190 12.6-5560 -

Iron 20/20 57500 155000 3740-223000 -

LeaU 20/20 1100 3610 4.1-5620 -

Magnesium 20/20 3450 5360 1760-5810 -

I Manganese 20/20 480 906 89-938 -

m Mercury 14/20 0.22 0.52 0.13-0.52 0.09-0.12Nickel 20/20 50.7 88.8 5.2-88.8 -

m Potassium 20/20 1990 3300 640-3300 -Selenium 7/20 0.47 0.59 0.35-0.59 0.3-4.2

m silver 6/20 1.7 6.5 1.4-9.9 0.9-1.0 _l,I i

Sodium 20/20 342 606 67.6-606 -

ITnallaum 2/20 0.28 0.46 0.4-0.65 0.03-0.59

m Vanadium 20/20 27.7 48.4 6.8-57.9 -Zinc 20/20 2Z70 5330 120-6730 -

I_cyaniue 8/20 1.3 3.1 0.64-4.3 1.1-3.9

m 23

Table 7 Inorganicchemicalsdetectedin soil from the salvageyardare_ at the lothStreet site

Range of- Upper Rangeof Quant.

Chemical Frequency Average Bound Detections Limits

Aluminum 4/4 10400 14900 6000-14900 -

Antimony 2/4 8.0 15.5 9.7-15.5 6.5-7,2

Arsenic 3/4 15.9 27 15.8-27 1,3

Barium 4/4 472 776 145-776 -

Beryllium 1/4 0.22 0.37 0.37 0.32-0.35

Cadmium 3/4 5.0 9.1 3.6-9,1 0.85

Calcium 4/4 61100 149000 5220-14900 -

Chromium 4/4 66.5 136 9-136 -

C

Cobalt 4/4 12.5 26,8 3-26.8 - i

Copper 4/4 400 893 9.3-893 - }

Iron 4/4 65100 165000 6580-165000 -

Lead 4/4 769 1250 2.6-1250 -

14agnesium 4/4 3930 6310 2040-6310 -

Manganese 4/4 581 994 162-994 -

Mercury 2/4 0.67 2 0.55-2.0 -

li_ckel 4/4 49.9 111 6.7-111 -

Potassium 4/4 1740 2410 1110-2410 -

Selenium 0/4 - - - 0.72-0.83

Silver 0/4 - - - 0.87-1,0

Sodium 3/4 Z530 9040 494-9040 39.8

Thallium 0/4 - - - 0.43-0.57

Vanadium 4/4 34.Z 56.4 14,1-56,4 -

Zinc 4/4 1790 3110 37.2-3110 -

Cyanide 0/4 - - - 1.1-1.2/

24

Table 8 Inorganicchemicalsdetecteain soil fromthe off-sitearea at the 10thStreet site

o

Range ofUpper Rangeof Quant.

Chemical Frequenc_ Average BounU Detections Limits

Aluminum 7/7 7170 16300 2880-18000 -

Antimony 1/7 4.2 7.4 8 6.6-7.5

Arsenic 6/7 2.6 5.4 1.4:5.8 2.7

Barium 7/7 247 402 53.1-402 -

Beryllium 2/7 0.32 .09 0.36-1.0 0.32-0.34

Cadmium 2/7 1.9 6.9 3.4-7.6 0.83-0.98

Calcium 7/7 15300 42200 6510-47200 -

Chromium 7/7 13 25.7 4.5-25.7 - :i

Cobalt 7/7 5.0 8.9 2.7-9.0 - !

Copper 7/7 50.6 207 3.1_219 -

'_ Iron 7/7 10400 17900 4620-17900 -Lead 7/7 289 g17 6._-g17 -

Magnesium 7/7 2430 5160 1250-5670 -

Manganese 7/7 219 332 105-332 -

Mercury 1/7 0.071 0.14 0.16 0.11-0.12

Nickel 7/7 9.8 18.1 5.3-18.1 -

Potassium 7/7 1160 2750 442-3040 -

S_lenium 0/7 - - - 0.73-0.83

Silver 0/7 - - - 0.89-1.0

Sodium 6/7 80.1 139 48.g-139 -

Ina11ium O/7 - - - O.43-0.49

._:adium 7/7 18.1 34.9 10.7-37.8 -

Zinc 7/7 289 741 21-741 -

Cyanide 1/7 0.8 2.0 2.2 1.1-1.2

25 j

i

I Lr-_1=50

I .,

_-" I INII e j FENCE LINES

...... N.E. TENTH STREET

/ residence' I salvage yordMV/2-S Iresidence

· / PW.-1

' SITE BOUNDARY

· /j! ·· ...?,/ (--'---

I .,,.-[I I! I GROUNDWATER

TENTHSTREETSUPERFUNDSITE · SAMPLINGLOCATIONS3200 N.E. TENTHSmEET L -_. -_;-o_L^.o.,c,_.o_,,o,^ .... , .

I J I m mil t m m)

WEI.Le.AHPLF' _£RFEfi PCR ANALYSI S PCB ANRLYSISLOCATInN 1NTFRVAL TRN UflFILTERFD F I LTERFD

GWO01 I1gl-S q.7-1q.6 FT FK6R_ .nS ul.lO u .OR u/.lO uFKfi}3q

FO_

GWO02 I_,IP-S q.R-lg.q FT FK6R4 .fl_ u/.lO u .(15 u/.!O uFK6qO ,

FO6

GWOn'l lIW3-5 9.s-lq.6 FT FK6q3 .05 ,/.lfi u .(1_ u/.lO uFKfq4

FOR

GWOOq II%.14-5 1(1._-20._FT FK6R?. .r}._u/.lO u .05 u/.lO uFK6R7

FO7

GWO05 fIW4-13 19.0-29.0 FT FK6R'_ .OR u/.lO u .05 u/.lO u, FK6/IR

FO9ro FK6_16 .q5 u/ 10 u-_ GWO06 Field blank

Fln

PWO01 Residential Well FK664 .05 u/.lO uFi!

SWO01 Trtbutary-uDstrPam surface FK614 .t)5u/.lfluFO?.

SWfi02 River-downstream surface FK61_ .05 u/.lO uFO3

_WO03 River-downstream surface FK636 .q_ u/.lO uFO4

CWOOI City Water FK637 .05 u/.lO uFOI

* Cnncentrattons in ua/1 or OOb. U . Below detection limit.*TRN Traffic Report Number.

qraantc or soectal analytical services numbersused to track samoles. Temoerature aooroxtmately

l_°C on all around water

.05 - .qetection limit for Aroclors 1(116 thru 1248. samoles from monttortn.a

.10 - Oetectton ltmit for Aroclors 17.54 and 17.60. wells.

!

Table lO Tnoraanicchemicalsdetectedin groundwater _'_"

. from the loth StreetSite. t I

Maximum IConcentration

Chemical PrivateWell UDaradea Oownaradeb ?mits

Aluminum _7.4 c g190 6630 50 ,, IArsenic (2._)d g.7 4_9 50 (30 P)

Barium 751 qgO 232 _000 P I

Beryllium (1._) 0._ O.t ...... IChromium (4.6) _.q lO.q 100 P

Cobalt (?.6_ ?'? ?'q ...... I

Coooer 89.7 7.1 5.4 1000 S

ILead (l._) q.q _._ qO (5 P) {

Manganese el.t) 924 !690 qO S

Nickel (17.91 12.R 7.o ...._- _1

Selenium r3.41 _1._) 1.0 50 P I

Vanadium 6.6 _0._ 17.1 ......

7inc 162 44.; tO._ 5000 S : I

a = Arithmaticaverageof monitoringwells t_-lS and t_-_S, ib = Arithmaticaverageof monitoringwells HW-tS.UW-4S and )_-40.c = All concentrationin ug/1.d = Detectionlimitwithin brackets.

o = Prooosed limit. Is = Secondarylimit fTasteand aestheticquality).

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mTable 11 Inorganicchemicalsdetectedin surfacewater

from the lornStreetSite.

_mI

Wat_, QualityCriteriaChemical Upstream Downstream Acute Chronic

IAluminum 1080 1630 ......

Arsenic {2.2) a 5.2 360 190 m

Barium 152 154 --- - ---I

Calcium 159000 99300 ...... mCopper (2.9) 29 18+ 12+ I

IIron 2250 7760 --- 1000

21.4 1.7 82+ 3.2+ ILead

Magnesium 30400 41000 ......

i IManganese 1280 141 ......l

Potasium 7160 5900 ...... ,-_mIm

Selenium {3.4) 3.7 280 35

Sodium 106000 151000 ...... I

Vanadium [¢.9) 9.3 ......m

Zinc 68.4 113 120+ 110+ ma = Detectionlimitwithin brackets. I

I+ = Hardnes$dependent(100mg/L assumed).

I

!i

_ mti

m

_o ii

I T

Migration Pathwaysr--

The contam_nan'csof concern at this s_te are PCBs. The migration ofPCBs _n the subsurface (tn soil, soil to ground water, and in groundwater) is controlled Dy several factors. These include the solubility ofPCBs, soil permeability, the presence or absence of transport-facilitatingsolvents, organic carbon content, and organic colloids. With the verylow solubility of PCBs, the presence of a protective cap, the absence oftransport-facilitating solvents, normal organic carbon content, no detectionof PCBs adhering to colloids, as well as the physical separation betweencontaminatedso_land the groundwater table,_t would take free productto be present at the site in order for subsurface m_gration to occur.PCBs are f_xea in the sol] matrix beneath the Tenth Street s_te and migrationis not occurring.

At present t_me, airborne migration of PCBs from the site is not iikely.With the protective soil cover and vegetation established, any migrationof contaminants by particulates generated from wind erosion is virtuallyeliminated. Tne potential for airborne migration of PCBs from the sitewould ex,st, only _f the so_] cover is destroyed by external forces suchas heavy erosion, flooding, or physical destruction. Likewise, the currentpotential for transport of PCBs from the site via surface water is minimaldueto theexistenceof theprotectivecover, j

If the PCB contaminated soil was exposed, the areas most likely to be Jimpacted by contaminant m_gration would be the nearby community and persons

who VlSltthe automobilejunk yard.q

VI. SUMMARY OF SITE RISKS

A baseliner_skassessmentwas conductedfor this site and is presentedina document entitled, Baseline Risk Assessment for the Tenth Street DumpSuperfundS_te,OklahomaC_ty, Oklahoma. The assessmentfollowsproceduresset in the EPA Risk Assessment Gu4dance for Superfund Sites, December 1989.

Identification of Contaminants of Concern

Chemcals whose analytical results are of acceptible quality for use inthe risk assessmentand relatedto the site were identifiedas contaminantsof concernfor this s_te. Concentrationsof site-relatedcontaminantsinwater and soil samplesare comparedto applicableor relevantand appropriaterequirements(ARARs). In addition,comparisonsare made to localandnationalbackgroundconditions. Chemicalswhose concentrationsare lessthan backgroundare eliminatedfromthe quantitativerisk assessment.Chemicalsdetectedat the site and their comparisonto ARARs and backgroundlevelsare also summamzed in Tables5, 10, and 11.

ExposureAssessment

In the risk assessment,EPA evaluatedthe current,or baseline,r_sktohealthposed by the contaminantsat the Tenth Streetsite. Since the siteis currentlyunoccupied,assumptionsregardingthe most probablefuture

land use for the sitewere made by EPA. Becausethe propertiessurroundingthe site are operating automobile salvage yards and inquiries have beenmade of EPA regarding the suitability of the s_te for future development,EPA considered the probable future land use to be commercial. The risk

31

i

]

assessment and the development of remedial goals focused on the effectsworkersexposedto thesitecontaminants.

The assumptions used for the ground water ingestion scenario are:

1. 70-year lifetime;2. 70 kg. (adult) and !0 kg. (child) body weight;3. ingestion rate of 2 liters per day for adults;4. ingestion rate of 1 liter per day for children.

The assumptions used for soil ingestion and dermal absorptionwere based on an industrial/ commercial exposure scenario:

1. ?O-year lifetime;_. 70 kg. body weight;3. ingestion rate of 0.1 grams per day;4. exposure duration of 9 years, 40 hours per day,

five days per week.

These assumptions are standardized in the risk assessment guidance.

Toxicit_ Assessment

Quantitative risk assessment requires contaminant-specific qualitativeand quantitative toxicity information. Contaminants are classified as !systemic toxicants, and/or as known or suspected human carcinogens. For

systemic toxicants, the EPA reference doses (RfDs) and, acceptable intakes _'_subchronic and chronic (AISs and AICs) are identified. For known orsuspected carcinogens, EPA weight-ofevidence classifications and upperbound cancer slope factors are identified. Included in the risk assessmentare pertinent Standards, criteria and guidelines developed for the protectionof human health and the environment. Dose-response parameters used inthe assessment are presented below.

Organic Chemicals

Acetone. The chronic oral RfD for acetone is 0.1 mg/kg/day (HealthEffects Assessment Summary Tables, Third Quarter FY 1989. (HEAST).

.Benzene_ The chronic oral RfD for benzene is 7E-4 mg/kg/day (0.0007)_ATSDR-1987). Benzene is classified as a human carcinoQen (Group A) andhas an oral and inhalation slope factor of _.9E-2 (mg/kg/day)-_ (IRISand HEAST). Some individuals exposed to benzene over a long period oftime have developed leukemia (cancer of the white-btood-cellforming tissue)(ATSDR 1987 }.

Bis (2-ethylhexyl) phthalate. The chronic oral RfD for bis (2ethyl hexyl)phthalate is 2E-2 mg/kg/day (Integrated Risk Information System (IRIS) 'and HEAST). It is classified as a probable human cQrcinogen (Group B2)and has an oral slope factor of 1.4E-2 (mg/kg/day)'_ {HEAST).

Carbon disulfide. The chronic oral RfD for carbon disulfide is 0.1 mg/kg/day

(IRIS). t_

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Chloroform. Tne subcnronic and chronic oral RfD for chloroform is 1E-2

mg/kg/day(HEASTand IRIS). Chloroformis classifiedas a probablehuman

carcinogen (GrOup B2), a_d has oral and inhalation slope factors of 6.1E-3and 8.1E-2 (mg/kg/day) , respectively(IRIS).

Chloromethane. Chloromethane is classified as a possible human carcinogen

(Group C), a_d has oral and inhalation slope factors of 1,3E-2 and 6.3E-3(mg/kg/day)',respectively(HEAST).

1,4 -Dichlorobenzene. The subchronlc and chronic inhalation RfD for 1,4-dlchlorobenzeneis 0.7 mg/cu.m(HEAST). 1,4 dichlorobenzeneis consideredas a probable human.carcinogen (Group B2) and has an oral slope factor of2.4E-2 (mg/kg/day)'l (HEAST).

Dlchlorodiphenyltrichloroetnane (DDT). The subchronic and chronic RfDfor DDT is 5E-4mg/kg/day(HEAST). DDT is classifiedas a probablehumancarcinogen (Group,B2), and nas an oral and _nhalation slope factor of0.34 (mg/kg/aay)-_ (HEAST).

Df-n-butyl phthalate. Subchronic and chronic RfDs for di-nbutyl phthalateare 1.0 and 0.1 mg/kg/day,respectively(HEAST).

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olychlorlnated Biphenyls (PCBs)? PCBs are a complex mixture of polychlorinJtedOmpoundS whfcn includes _ro_lors 1242, 1254 and 1260. The chronic oral JRfD for PCBs is based on a study using Aroclor 1016 (no data on noncarcinogieffectsof Aroclor1260)and is 1E-4mg/kg/day(ATSDR). PCBs are classifiedas a probablehumancarcinogenwith a slope factorof 7.7 (mg/kg/day)-_.

PolynculearAromaticHydrocarbons(PAHs). PAHs are a complexclass ofcompoundswhich _nclu_es:acenaphthene,anthracene,benzo (al anthracene,benzo (al pyrene,benzo (b) fluoranthene,benzo (g,h,1)perylene,benzo-(k) fluoranthene,chrysene,dibenz (a,h)anthracene,fluorene,fluoranthene,indeno (1,2,3cd) pyrene,phenantnreneand pyrene. The subchronicandchronicoral RfD for PAHs is based on the toxicityof naphthaleneand is0.4 mg/kg/day. PAHs are classifiedas probablehuman carcinogens(GroupB2), _nd have oral and inhalationslope factorsof 11.5and 6.1 (mg/kgday)-_, respectively(EPA 1986). PAH slope factorsare based on benzo-(a)pyrenecarcinogenic_ty.The followingPAHs are consideredto becarcinogenic:benzo(a)anthracene,benzo(a)pyrene,benzo(b)fluoranthene,benzo(g,h,1)perylene,benzo(k)fluoranthene,chrysene,dibenzo(a,h)perylene,benzo(k)fluoranthene,dibenzo(a,h)anthraceneand indeno (1,2,3,cd)pyrene.

Tetrachloroethylene(Perchloroethylene).The subchronicand chronicRfDsfor tetrachloroethyleneare 0.1 and 0.01 mg/kg/day,respectively(HEAST).Tetracnloroethylene_s classifiedas a probablehuman carcinogen(B2),and has an oral and inhalationslope factorsof 5.1E-2and 3.3E-3(mg/kg/day)-l,respectively(HEAST). ........

Toluene. The subchronic and chronic oral RfDs for toluene are 4E-1and 3E-1mg/kg/day,respectively(IRIS and HEAST). Subchronicand chronicinhalationRfD for tolueneis 2 mg/cu.m(HEAST). TheEPA determinationof toluene carcinogenicityis pending (IRIS).

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1,2,4-Trichlorobenzene.The subcnronicand chronicoral RfDs for 1,2,4-trlcn]oroben'zeneare 2E-1 and 2E-2 mg/kg/day,respectively;subcnronlcand chronicInhalationRfDs are 3E-2 and 3E-3 mg/kg/day,respectively(HEAST).

1,1,1-Trichloroethane.The subchronicand chronicoral RfDs for 1,1,1-trichloroethaneare 9E-1 and gE-2 mg/kg/day,respective]y;and the subchronlcand chronicInhalationRfDs are 10 and i mg/cu.m (IRISand HEAST). TheEPA determinationof its carcinogenlcityis pending(IRIS).

Xylene. For mixed xylenes, subchronic and chrontc oral RfDs are 4E+O and2.0 mg/kg/day,respectively;and the chronicinhalationRfD is 3E-1 mg/cu.m.(HEAST).

Inor_antc Chemicals

Alumlnium. The data on aluminiumis inadequatefor quantitativeriskassessment (HEAST).

Antimony. The subchronicand chronicoral RfO for antimonyis 4E-4

(mg/kg/day)(IRISand HEAST). iArsenic. The subchronicand chronicoral RfD for arsenicis 1E-3 mg/kg/da,y(HEAST). Arsenic is classifiedas a human carcinogen (Group A), and hasoral and Inhalationslope factorsof 1.8 and 1.5E+1 (mg/kg/day)-I(IRIS).

Barium. For bartum,thesubchronic and chronicoral RfD is 5E-2 mg/kg/day(IRISand HEAST);subchronicand chronictnhalationRfDs are 5E-3 and 5E-4mg/kg/day,respecttvely(HEAST).

Beryllium. The subchronTcand chronicoral RfD for berylliumis 5E-3(mg/kg/day)-1 (HEAST).

Cadmium. The chronicRfDs for cadmiumare 1E-3mg/kg/day(food)and 5E-4mg/kg/day(water)(HEAST). Cadmiumis consideredas a probablehumancarcinogenby inhalgt_on(GroupB1) and has an inhalationslope factorof6.1E+0 (mg/kg/day)-_ (IRISand HEAST).

Chromium. The chronicRfD for chromiumis 5E-3 mg/kg/day(IRIS). Chromiumts consideredas a human carcinogenby tnhalatton(GroupA) and has aninhalationslope factorof 4.1E+1(mg/kg/day)'' (IRIS).

Cobalt. Quantitativerisk assessmentinformationon cobaltts not available.

Copper. For copper,the oral AIS and AIC ts 3.7E-2mg/kg/dayand theinhalationAIC is 1E-2 mg/kg/day(EPA 1986). Copper is not classifiedasto human carc_nogeniclty (Group D) (IRIS).

Cyanide. The subchron_cand chronicoral RfD for cyanideis 2E-2mg/kg/day(HEAST).

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Lead. Lead can have profoundadverseeffectson certainbloodenzymes

(_ and on aspectsof children'sneurobehavioraldevelopment. These adverseeffectsmay occur at bloodlead levelsso Iow as t_ be essentiallywithouta thresholdFIRIS). For lead,oral AIC is 1.4E-3mg/kg/dayand inhalationAIC is 4.3E-4mg/kg/day(EPA 1986). Lead is classifiedas a probablehuman carcinogen {Group B2) (IRIS and HEAST).

Manganese. For managanese,the subchronicand chronicoral RfDs are 5E-1and 2E-I mg/kg/day,respectively;and the subchronicand chronicinhalationRfD is 3E-4 (HEAST). Manganeseis not classifiedas to human carcinogenicity(GroupD) (IRIS).

Mercury. The subchronicand chronicoral RfD alkyt and inorganicmercuryis 3E-4mg/kg/day{HEAST).

Nickel. The subchronicand chronicoral RfD for nickelis 2E-2mg/kg/day(HEAST). Nickelis classifiedas a humancarcinogenby inhalation(GroupA) and has an inhalationslope factorof 8.4E-1{mg/kg/day)-1 (IRIS).

Selenium. For selenium,the subchronicand chronicoral RfDsare 4E-3and 3E-3 mg/kg/day,respectively;and the subchronica_d chronicinhalatio_

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RfD is lE-3mg/kg/day(HEAST). i

Silver. The oral AIC for silveris 3E-3mg/ko/day{EPA 1986). !

Vanadium. The subchronicand chronicRfD for vanadiumis 7E-3 mg/kg/day(HEAST).

Zinc. The subchronicand chronicRfD for zinc is 0._ mg/ko/day(HEAST).

Risk Characterization

The first step in the risk characterizationis to calculatethe intakeofspecificsite-relatedcontaminants_bsorbedfrom the affectedmedia.Intakesby exposedpopulationswil_ be calculatedfor the selectedpathwaysof exposure,and convertedto daily doses (in mo/kg bodyweight/day)bycorrectingfor absorptionefficiencyacrossgastrointestinal,pulmonary,or dermalboundaries. These doses are denotedby EPA as the chronicdaily intake(CDI). The CDIs for systemic(noncarcinogenic)and carcinogenichealtheffectsare calculatedseparatelyto accountfor differencesin,the averagingtime.

The potentialeffectsof contaminantson human health have been evaluatedfor their noncarcinogenicand carcinogeniceffects. For noncarcinogeniceffects,a chronicHazard Index (HI)is calculatedby summingthe quotientsof the contaminant-specificCDIs by the contaminantspecificRfDs orAICs. A total (i.e, accountingfor all media) HI greaterthan 1 suggestsa potentialhuman healthconcern. For groundwater exposure,theevaluationof noncarcinogeniceffectswill focuson 1 to 6 year oldchildren,who are the most sensitiveto contaminantexposures.

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For carcinogenic effects, the potential upper-bound lifetime excess cancerrisk (accounting for all contaminated media) is estimated by summing theproducts of t_e contaminant-specific CDIs and the contaminant-specificslope _actors. EPA considers a lifetime upper bound of risk range of 10-4to 10-v as the target range for remedial action goals at Superfund sites.EPA also considers the 1E-6 risk level as the "point of departure" forremedial goals. This is the level that the agency expects to achievewhere practicable.

The dermal absorption route lacks the toxicity reference values of theother exposure routes (e.g., oral and inhalation), Oral values were usedto assess risks from dermal exposure.

The results of the risk assessment indicate that no adverse health effects

would be expected from ingestion of the ground water near the site. PCBswere not detected in any ground water samples taken, gata presented inTable 2 indicates that the maximum concentration limits for metals werenot exceeded in any samples taken.

The risk assessment also indicated that non-carcinogenic risks from _CBs,metals, polynuclear aromatic hydrocarbons, and solvents are not presentat this site. The combined hazard index, the measure of non-carcinogeni-city, for direct contact with the contaminated soil was calculated to be i

0.55. A hazard index of 1.0 or greater is considered by EPA to representa non-carcinogenic risk.

Carcinogenic risks posed by the site are attributed to the PCB contamina-tion in the soil. The average lifetime carcinogenic risk from directcontact with the soil, based on th_ averaqe concentration of PCBs in thesoil, is estimated to be 3.8 x 10'_ excess cancer incidents. Under the

"worst case" c_nditions, the estimated risk is 9.6 x 10-_, or approxi-mately 1 x 10' . Potynuclear aromatic hydrocarbons, metals_ and sovlentsdid not contribute to the carcinogenic risks (tess than 10' risk).

Environmental Assessment

The environmental risks associated with contaminants at the site appearto be non-measurable or minimal. Surface water samples collected show no

organic chemicals related to the site and similar concentrations of inorganicchemicals. Biota samples collected indicate that the North Canadian 'River, downstream from the site contain more individuals and species thanupstream. The vegetation in the vicinity of the site and cottonwoodtrees along the intermittent stream west of the site did not appear to bestressed. During !g87, the U.S. Fish and Wildlife Service of the Departmentof the Interior conducted a Preliminary Natural Resource Survey a_d granteda release from natural resource damages.

VII. DESCRIPTION OF ALTERNATIVES

As discussed earlier, PCBs are the contaminants of concern and arelimited to surface and subsurface soils at the site. Remedialalternatives for the Tenth Street site have been evaluated with respect to

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nine evaluationcriteriaset in the NationalContinoencyPlan, the ToxicSubstance Control Act (TSCA), PCB regulations; the Resource Conservationand RecoveryAct (RCRA), land disposalrestrictions;the OklahomaSolidWaste )lanagenmnt Act, Regulations Governing Solid _aste and Sludge Management.The PCB Spill Cleanup Policy, which is not an ARAR but is codified in theFederal Register, has also been considered. The TSCA PCB regulations ofimportance to Superfund sites are found in 40 CFR Part 761, Subpart D:Storage and Disposal (761.60 - 761.79}. These regulations specify thetreatmentand disposalrequirementsfor PCBs.

RCRA land disposal restrictions do not specifically apply to PCBcontamination, as PCBs alone are not a RCRA waste. However, if thePCBs are mixed with other hazardous waste(s), they may be subject to landdisposal restrictions. The Oklahoma Regulations Governing Solid Wasteand SludgeManagementspecifylandfilllocationstandards,and the finalcover requirement. Under EPA Guidance on Remedial Actions for SuperfundSites with PCB Contamination(Augustlggo),land use (residential,industrial, or rural) is a p_imary consideration in determining cleanuplevel. The concentration of PCBs that can be left i_ the soil on sitedependsprimarilyon the expectedexposurescenario(i.e. directcontact_limited contact, or restricted contact through capping and access control,)and the achievement of adequate risk protection.

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Remedialaction is clearlywarrantedat Tenth Streetbased on the August i

1990 EPA guidancefor PCB-contaminatedSuperfundsites. Section3.1.2 o¢this guidancediscussesremedialgoals for industrialor remoteareaswith PCB contamination.A range of 10 ppm to 25 ppm is consideredappropriate

_-,) for a remedialgoal in an industrialarea. This goal is consistentwiththe goals set in the TSCA Spill CleanupPolicy.

The remedialgoal for the Tenth Street sitewas set based on futureindustrialland use and is 25 ppm PCBs in the soil onsite. This goalwasselectedto be consistentwith the Toxic SubstancesControlAct SpillCleanupPolicycriteriafor commercial/industrialareas and goals set atother Superfundsites nationwidewhere commercialexposureswere considered.This concentrationalso representsa maximumresidualexcesscancer riskof 1 x !0'_. This risk is based on a futurecommercial/industriallanduse. An estimated7,500 cubicyards of soil to a depth of about 6 feetare contaminatedwith greaterthan 25 ppm of PCBs and will be addressedby the remedial action.

Alternatives Evaluation

To achievethe remedialgoal, technologiesand processoptionsapplicableto this site were identifiedand analyzed. After the screeningprocess,a totalof six alternativeswere formulated. These alternativeswerefurtherevaluatedin terms of effectiveness,implementability,and cost.Five alternativeswere analyzedin detail in the FS. These five alternativesare listedbelow and numberedto correspondwith the alternativesin theFS report. ,,.

o Alternative 1: No Action

/_--_ o Alternative3: Excavationand OffsiteDisposal

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o Alternative 4: Excavation, Ons_te Chemical Treatment. andDisposa]Onslte

o Alternative 5: Excavation, Onslte Thermal Treatment, anaD_sposal Onsite

o Alternative6: Excavationand OffslteThermalTreatment

Alternative 2, _n place capping was screened out prior to the detailed eval-uationof alternativesbecausethe site Ts in a flood plain and becausecappingwould not satisfythe preferencefor treatmentexpressedin SARA.

Except for the "no action"alternative,all of the alternativesconsideredfor the site _ncluaea commoncomponent,the removaland/ortreatmentofPCB contamnated soil. An air monitoringprogramand dust controlmeasureswould be _mplementedto reduce/m_n_mizeany potentialadversesnort-termhealtheffectsduring excavationand treatmentactivities. Institutionalcontrolswould not be requiredfor any of the alternatives,exceptthe"No Action" alternative.

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Descriptionsof each of the alternativesare as follows: i

Alternative1: NoAction j

EstimatedCapitalCost: $2,500

Estimated Annual O&M Costs: $11,800

Estimated Total Present Worth Costs: $184,200

Estimated Implementation Timeframe: 30 years for O&M

The Superfuna regulations (National Contingency Plan) requires that the"no action" alternative be evaluated at every site to establish a baselinefor comparison. No constructionactivitieswould occur at the site; anestimated 7,500 cu. yd. of PCB contaminated soil at concentrations of 25ppm and above would remain at the site.

Under this alternative, deed restrictions to prohibit soil excavationand construction activities woulO be imposed on the site, and regularmaintenance _ncluaing vegetation mowing, reseeding, and fence andcover surfacerepairwould be performed. The two downgradientgroundwa_er monitoringwells would be sampled and analyzed for PCBs annuallyto ensure that no migration of PCBs to ground water underneath the siteoccurs. This alternative would meet neither the Toxic Substances ControlAct (TSCA) PCB o_sposal requirements, PCB Spill Cleanup Policy, nor theOklahoma Solid Waste Regulations. This alternative would not mitigatethe long-term risks identified w_tn the contaminants at the site.

Because this alternative would result _n contaminants remaining at

the site, CERCLArequiresthat the site be reviewedevery f_veyears. _

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? Alternative 3: EXCAVATION AND OFFSITE DISPOSAL

EstimatedCapital Costs: $4,037,000

EstimatedAnnual O&M Costs: $0.00

Estimated Total Present Worth Costs: $4,037,000

Estimated Implementation Timeframe: 3 months

This alternative consists of the removal of the existing temporary redclay cover and excavation and disposal of the PCB-contaminated soil in aTSCA-permitted chemical landfill. The red clay removed could be retainedto supplement the clean soil required to backfill the excavated area.

The contaminated soil would be excavated and temporarily stored in wastepiles. The contaminated soil would then be loaded onto 20 cu. yd. dumptrucks for transport to a TSCA-permitted landfill. Prior to leaving thesite, the trucks would be inspected to ensure hazardous substancetransportation requirements are met. Manifests would also be preparedand signed as required. The excavated area would be backfilted withclean soil. The final surface would be graded and seeded to blend with i

the surrounding area. !

Under this alternative, an estimated 7,500 cu. yd. of PCB contaminated

/-. soil at concentrations of 25 ppm and above would be removed from the site.During implementation of this alternative, measures to supress dustgenerated during excavation will be used to mitigate any potential riskto the nearby community may be expected due to fugitive dusts in theambient air. After completion of this alternative, no long-term monitoringand_maintenance would be required and the site risk would be reduced to10-6. This alternative would meet the TSCA PCB disposal requirements andthe PCB SDill Cleanup Policy.

Alternative 4: EXCAVATION, ONSITE CHEMICAL TREATMENT, AND DISPOSALQNSITE

Estimated Capital Costs: $4,044,000

Estimated Annual O&M Costs: $0.00

Estimated Total Present Worth Costs: $4,044,000

Estimated Implementation Timeframe: 6-9 months

This alternative consists of removino the existing red claycover and treating the PCB contaminated soil on-site by a chemicalprocess to destroy chlorinated biphenyls.

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After treatment, the treated soil (less than ? ppm PCB) would be put backinto the excavated area. The clay cover could be retained and used asclean backfill material. If needed, additional clean soil would be broughtto the site f_r final grading.

The basics of the chemical dechlorination process are straight forward.Contaminated soil is mixed with an alkaline reagent consisting of potassiumor sodium hydroxide in a solution of mixed polyethylene glycol and dimethylsulfoxide. The reagent mixture dechlorinates the aryl halide to form aPEG ether and a totally dechlorinated species.

In soil processing, the soil/reagent mixture is heated to 30 - 150°C withmixing until the reaction has been completed. At the end of the reaction,reagent is recovered by decantation and washing the soil with severalvolumes of water. The decontaminated soil is then discharged, with thereagent recycled for reuse. Water vapor and volatiles generated duringthe process will pass through a condensor equipped with a carbon adsorptionfilter before discharging to a waste treatment unit. Any volatiles thatare not condensed will be trapped by the filter. Spent carbon filterswilt be handled in accordance with the waste classification. Chemicalanalysis will be performed to ensure that discharged soil is clean.

A treatability study conducted during the RI indicated the !(PEGtreatment _process to be a feasible and effective technology for decontaminating PCB i

contaminated soil at this site. This study demonstrated that this technologycan destroy PCB contamination at this site to below 1 ppm in the soil.

An estimated ?,500 cu. yd. of PCB contaminated soil with concentrationsof 25 ppm and above would be treated. The concentrations of the treatedresidual would be reduced to less than 2 ppm. During implementation ofthis alternatve, dust suppression and monitoring will be done to mitigateany risk from fugitive dusts that may be generated. Emissions from thetreatment process would be minimal, water vapor and volatiles generatedwhich are not removed by the condensor unit would unit would be trapped

by carbon adsorp}ion. Completion of this alternative would reduce thesite risk to 10_u and no long-term monitoring and maintenance would berequired. This alternative would meet the TSCA PCB alternative treatmentrequirements (2.0 ppm) and the PCB Spill Cleanup Policy.

Alternative 5: EXCAVATION, ONSITE THERMAL TREA_4ENT, AND DISPOSALONSITE

Estimated Capital Cost: $4,406,000

EstimatedAnnual O&M Costs: $0.00

Estimated Total Present Worth Costs: $4,406,000

Estimated Implementation Timeframe: ,6_9 months

This alternative consists of removing the existing red clay cover andtreating the PCB contaminated soil on-site by an incinerator meetingthe

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incineration destruction removal efficiency (DRE) of 99.9999 percent setfor PCBs by _egulatlon. After treatment, the treated soil would put backinto the excavated area. The clay cover could be retained and used asclean backfill material. Additional clean so_l, if needed, would beplaced on top of the s_te for f_nal grading,

Priorto incineration,contaminatedsoilwould be excavatedand storedtemporarily in waste piles. The contaminated soil would be fed into theonsite incinerator equipped with emission controls and ash handling equipment.The exhaust gases resulting from Incineration would be scrubbed beforeventing to the atmosphere.

The scrubberwaterwould be incineratedor treatedby passingthroughserial activated carbon columns. The spent carbon would be incinerated.The ash would be testedprior to backfillingthe excavatedarea to ensurePCBs are destroyed. A shredderwould be used to reducelumpsof clay,rocks, and other large debris to an acceptable size for incineration.Large p_ecesof debris,suc_ as bricks,rocks,or concretefoundduringthe excavationthat can not be shreddedwould be assumedPCB wastesanddisposed of _n an approved landf311.

An estimated 7,500 cu. yd. of PCB contaminated soil at concentrations of i25 ppm and abovewould be treatedby the mobileincineratorbroughtons_te.

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After incineration,the site riskwould be reducedto 1E-6. No long-termmonitoringand maintenancewould be required. Any increasein riskbyinhalationdue to :he 3ntroductionof fugitivedusts in atmosphereby

_-'- soil excavation would be similar to Alternative 3. A potential increasein r_sk by inhalationto the nearbycommunitywould alsoexist, if emissioncontrol system of she Incinerator were to fail. This alternative wouldmeet the TSCA PCB incineration requirements (40 CFR 761), the PCB SpillCleanupPolicy,and the OklahomaCleanA_r Act.

Alternative 6: EXCAVATION AND OFFSITE THERMAL TREATMENT

EstimatedCapitalCosts: $17_82g,000

EstimatedAnnualO&M Costs: $0.00

Estimated Total Present Worth Costs: $17,829,000

Estimated Implementation Timeframe: 3 months

This alternative consists of removing tme existing red clay cover andtransporting the PCB contaminated soil to a permitted incineration facilityoff-site. The PCB would be thermally destroyed at the off-site facility.The cover soil removed could be retained to supplement the clean soilrequired to backfill the excavated area and for final gra_ing.

The contaminated soil would be excavated and temporarily stored _n wastepiles ready for loading and transporation. The contaminated soil wouldthen be loaded onto 20 cu. yd. dump trucks. Prior to leaving the site,

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the truckswould De _nspecteoto ensurehazardoussubstancetransportationrequirements-are met. Manifests would also De prepared and signed asrequired. The excavated area would be backfilled with clean soil. Thefinal surface would De graded and seeded to blend with the surroundingarea.

Implementation of this alternative would remove an estimated 7,500 cu.yd, of PCB contaminated soil at concentrations of 25 ppm and above fromthe site and reduce the site risk to 1E-6. No long-term monitoring andmaintenancewould be required. Duringsoil excavation,stockpiling,andloading, this alternative would have a potential for temporary increasesin risk by Inhalation to the nearby community similar to Alternative 3.This alternative would meet the TSCA PCB incineration requirements andthe PCB Spill Cleanup Policy.

VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Overall Protection of Human Health and the Environment

All of the alternatives, with the exception of the "no action" alternative,_would be comparablein terms of providingadequateprotectionof human

healthand the environment. They achieveprotectionby eliminating,reducing, or controlling risks through source removal and treatment. Atthe cleanup level of 25 ppm, risks through direct_contact and ingestionare reducedto a.cancerriskmaximumlevelof 10-_. The overallaverage _'"'site riskof 10-b is achievedby treatmentor removalof the contaminatedsoil and the placementof treatedsoil on the site. Alternative4, 5,and 6 achieveprotectionby reducingexposurethroughtreatment. Alternative3 reducesrisksby source removal. Under the "no action"alternative,aslongas the integrityof the existingsoil cover is maintained,no _mminentand substantialendangermentto public health,welfare,or the environmentwould be expected. However,contaminationwill remainat the site andpotentialfor contaminantmigrationwill alwaysexist. Also, site accesswould be restrictedand no excavationsor constructionactivitieswouldbe permittedat the site.

Compliance w_tn ARAR_

All of the alternatives, with the exception of the "No Action" alternative,will achievethe 25 ppm remedialgoal set in the TSCA Spill CleanupPolicy.The use of a fully compliantlanddisposalfacilitypermittedto acceptPCB-contaminatedmaterialswill ensurethat Alternative2, offsitelanddisposal,meets the TSCA disposalregulations(40CFR 761.75). Chemicaldechlorination will achieve the 2.0 ppm concentration set in the TSCAAlternateTechnologyregulations.Both onsiteand offsitethermaldestructionalternativeswould complywitn the incineratorregulationsgoverning PCB disposl (40 CFR 761.70).

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f_.. Long-termEffectivenessand Permanence

Alternative4,§, and 6 affordthe nighestdegreesof long-termeffectivenessand permanence as they use treatment tecnnologies to reduce hazardousposed by contamination at this site. Alternative 4 uses a chemical treatmenttecnnologywhile Alternatives5 and 6 use thermaldestruction. Bothchemical decnlor_nation and incineration are irreversible processes.

Alternative 3 would provide the similar level of protection for this sitethrough source removal. However, the waste would not De destroyed, it

would s_mply be relocated to another _lte. At 25 ppm, the average risksfrom the site would be reduced to 10' by Alternatives 3, 4, 5, and 6.

Alternative 1 leaves all of the contaminated soil at the site and reliesentirely upon the existing soil cover. As the existing soil cover wasnot constructedto meet the RCRA cap requirements,nor to meet the OklahomaSolid Waste Regulations final cover requirements, long-term effectivenessand permanence of the existing soil cover iS questionable.

Reduction of Toxicit_t Mobility_ or Volume

Alternatives 4, 5, and 6 would treat the contaminated soil to reduce the itoxicity, mobility and volume of contamination at the site. At a cleanup ilevelof 25 ppm, approximately7,500 cu. yd. of PCB contaminatedsoilwould be treated. About 1,000 cu.yds, of soil with PCB concentrations of25 ppm and below woulO remain at the site. Alternative 4 would treat the

f" contaminatedsot1 chemicallyand reducethe concentrationsof contaminantto less than 2 ppm. Alternatives5 and 6 would involveincinerationprocesses that would have a DRE of 99.9999 percent.

Alternative3, removalof the sourceof contaminantionand disposalin a chemicalwaste landfil),would simplytransferthe contamnationfrom one site to anotherand would not reducethe toxicityor volumeof the contamination.AlternativeI will not reducetoxicity,mobility, "or volume of the contamination.

Short-term Effectiveness

Alternative 3, 4, 5, and 6 are anticipated to pose similar levels ofshort-term risks. However, Alternative 4 would provide the greatestshort-termeffectivenessand presentthe least amountof riskto workers,the community, and the environment.

Particulate emissions resulting from excavation and stockpiling of contaminatedsoil would be expected during implementation of Alternative 4. Emissionsgenerated from KPEG treatment process would be kept at minimum. Watervapor and volatiles generated in the reactor will go through a condensor 'equipped with a carbon adsorption filter before discharging into a wastetreatment unit. Any volatiles that are not condensed will be trapped bythe filter. Spent carbon will be handled in accordance with the wasteclassification.

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The reagentsand byproductsused in the chemicaldechlorinationprocesswill not pose any short term risks. Data generated in laboratory testsusing rats indicatestnat ethyleneglycolate-400is 27 times lesstoxicthan PCBs; dimethyl sulfoxide is 17 times less toxic than PCBs. Thesereagents are also 9 and 6 t_mes, respectively, less toxic than table salt.The results of Ames toxicity tests indicates that the byproducts of thedechlorination process do not exhibit any carcinogenic potential.

Alternatives 3 and 6 are very similar with respect to short-term effectiveness.In addition to particulate emissions resulting from excavation of contaminatedsoil, potential release of contaminants along the route of transportationwould exist, if an accident were to occur.

Alternatives 4 and 5 can be implemented in approximately 6 to 9 months.Alternatives 3 and 6 can be completed in approximately 3 months.

Implementabilit_

Alternatives1, 3, and 6 would be the simplestto conductand operate.No special techniques, materials, permits, or labor would be required forimplementation of these alternatives; they are readily available in thelocal area. Permitted PCB landfills and offsite PCB incinerators are

commerciallyavailable, i

Alternative4, the KPEGtreatmentprocess,is more complexthan Alternatives)3 and 6. It would requirespecialiststo constructand operatethe system.Pilot testingwould be requiredto determineoperatingparametersand _fine tune the operation. Duringoperation,this treatmentprocesswouldrequireconstantattentionand periodicadjustment.

Alternative5 4s probablythe most complexalternativeto operate. Despiteanticipateddowntime due to mechanicalcomplexity, incinerationcouldreliablymeet the DRE. A mobile _ncineratorwould have to be broughtonsite. This alternativewould requirethe most attentionas incinerationrequiresperiodicsamplingof the residueand modificationof operatingparameters. A test burnwould be requiredto determi_etheoperatingparameters. Mobile incineratorsare commerciallyavailablefrom numerousvendors.

Cost

AlternativeI has t_e lowestestimatedpresentwort_ cost, $184,200. Thecost for Alternative3 is estimatedat $4,037,000. Alternative4 has anestimatedcost similarto Alternative3, $4,044,000.The estimatedcostfor Alternative5 is $4,0406,000,which is about 10% highert_an Alternative4. Alternative6 has the highestestimatedcost, $17,829,000.00,whic_is about 4.5 times higher than Alternative 4.

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State Acceptance

The State of Oklahoma currently prefers the "No Action" alternative. TheState believes that because the baseline risk (10-_) is within.the remedialtarget rangeestablishedin the NationalContingencyPlan (10'4 to 10-b)

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that furtheraction is not warrantedat the site. The State also believes

_---. that the short-term risks of implementation of a remedy are greater thanthe long-term_iskscurrentlyoosed by the site,althoughthe State did notoffer any quantitative evidence to substantiate the belief.

Community Acceptance

Community response to the alternatives is discussed in the responsivenesssummary, which addresses comments received during the public commentperiod. Citizens raised questions about exposure to fugitive dust fromexcavation, other locations where the technology has been used, and thepossibility of local contractors implementing the remedy.

IX. THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA, the detailedanalysis of the alternatives, and public comments, the U.S. EPA has selectedAlternative 4 - Excavation, Onsite Chemical Teatment, and Disposal Onsiteas the remedy for the Tenth Street Superfund site.

Soil sample analyses obtained during RI indicate that the estimatedvolume of PCB contaminated soil at the site is apDroximately 8,500 cu.

t'

yd. Based on the future industrial land use and compliance with the TSCA iSpill CleanupPolicy,the remedialgoal is set at 25 ppm. At this cleanup

target,the increasedcancer risk posed by the sitewould be reducedto tlO-J.

f'_ An estimated7,500 cu. yd. of soil contaminatedwith greaterthan 25 ppmPCBs would be excavatedand treatedonsite by chemicaldechlorinationtreatmentunit. The treatedsoil would containless than 2 ppm of PCB.A treatabilitystudy conductedduringRI has demonstratedthat the KPEGtreatmentprocessis capableof destroyingPCB contaminationat this siteto below 1 ppm.

X. STATUTORYDETERMINATIONS

Under its legal authorities,EPA's primaryresponsibilityat SuperfundSites is to under take remedialactionsthat achieveadequateprotectionof human healthand the environment. In addition,Section121 of CER£LAestablishedseveralother statutoryrequirementsand preferences. Thesespecifythat when complete,the selectedremedyfor this sitemust complywith applicableor relevantand appropriateenvironmentalstandardsestablisheounder Federaland State environmentallaws unlessa statutorywaiver isjustified.

The selectedremedyalso must be cost effectiveand utilizepermanentsolutionsand alternativetreatmenttechnologiesor resourcerecoverytechnologiesto the maximumextent practicable. ),

Finally,the statuteincludesa preferencefor remediesthat use technologiesthat permanentlyand significantlyreducethe volume,toxicity,or mobilityof hazardouswastes as their principalelement. The followingsectionsdiscusshow the selectedremedymeets these statutoryrequirements.

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Protectionof HumanHealthandtheEnvironment

The selected _emedy protects human health and the environment throughtreatmentof the PCB contaminatedsoil. The contaminantwill be permanentlyremovedfrom the so_l by glycolatedehalogenationprocess. The treatmentprocesswill degradethe PCBs into less toxic,water solublecompounds(glycol-ethersand chloridesalts),which furtherdegradeto form a totallydechlor3nated species.

Destructionof PCBs from the soil and backfillingthe treatedSoil, inthe excavatedarea would reducethe excesscancerrisk posed by the siteto 10'_. Becuasethe chemicaldechlorinationprocessequipmentiscompletelyenclosed,there are no short-termthreatsassociatedwithmaterialshandlingwith the selectedremedy.

Compliancewith Applicableor Relevantand AppropriateRequirements

Tne selectedremedyof excavation,onsitechemicaltreatment,and disposalof treatedsoil will complywith all applicableorrelevantand appropriaterequirements(ARARs). The ARARs arepresentedbelow.

Action-specificARARs: J!o PCB AlternativeTreatmentRequirements(< 2 ppm PC6s)PCBs, using total waste analysis(40 CFR Part 761,Subpart D)

Other Crlteria_ Advisories or Guidance To Be Considered:

o TSCA PCB Spill Cleanup Policy (Federal Register, April 2, 1990}

o EPA Guidanceon SelectingRemediesfor SuperfundSites with PCBContaminationCAugust1990)

Land D_sposalRestrict)ohsunder RCRA are not ARAbs for the PCB-contaminatedsoils at this site.

Cost - Effectiveness

The selectedremeay is cost-effective,as it has been determinedto providea high degreeof effectivenessproportionalto its cost. The estimatedtotal presentworth value is $4,044,000. The selectedremedyis theleast costly of the Alternatives 4, 5, and 6 which are equally protectiveof human healthand the environment.

Utilization of Permanent Solutions and Alternative Teatment Technologiesor Resource Recovery Technologies to the Maxi.mumExtent Practicabl e

U.S. EPA nas determinedthat the selectedremedy representsthe maximumextent to which permanent solutions and treatment technologies can be

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[

utilizedin a cost-effectivemanner for the final remedyat the Tenth_-_ Street Super_und site. Of those alternativesthat are protectiveof

human health and the environment and comply with ARARs, EPA has determinedthat the selected remedy provides the best balance of tradeoffs in termsof long-term effectiveness and permanence; reduction in toxicity, mobility,or volume achieved through treatment, short-term effectiveness,implementabitity, costs, also considering the statutory preferencefor treatment as a principal element and considering State and communityinput. Alternative 1 would not reduce the toxicity, mobility or volumeof the contamination; would not comply with ARARs; would not providereliable long-term effectiveness; would provide short-term effectiveness;would take 30 years to implement. Contamination will remain at the siteand potential for contaminant migration will always exist.

Alternative 3 would protect human health and the environment for thissite about equally as well as the selected remedy. It would also havesimilar long-term effectiveness, and short-term effectiveness. However,Alternative 3 would not reduce the toxicity or volume of the contaminant, ,,it would simply relocate the contamination to another site. Alternatives5 and 6 would provideequal protectionof human healthand the environment , _and long-term effectiveness as the selected remedy. They would also have

the same level of reductionin toxicity,mobility,and volumeas the tselected remedy. However, Alternatives 5 and 6 would have higher costs

and less short-termeffectiveness. )

Principalthreatsat Tenth Streetare definedas those soils contaminate_f"_ with greaterthan 300 ppm PCBs, an order of magnitudehigher than the

healthbased remedial goal. Low level threats are those soils with lessthan 300 ppm PCBs. The NCP expects that principal threats will be treated;iow level threats will also be treated where cost-effective.

Containment of the iow level threats was not considered because the costof treating alt soils above the health-based remedial goal is _niyapproximately 10 percent of the cost of treating the high leve) threats.Therefore, EPA considers treatment of all soil contaminated with greaterthan 25 ppm PCBs to be cost-effective.

Preference for Treatment as a Principal Element

By treating the PCB contaminated soil at the site and disposing the trea_edsoil onsite, the selected remedy addresses the principal threat of futuredirectcontact/ingestionof contaminatedsoil posed by the site throughthe use of treatment technologies. Therefore, the statutory preferencefor remediesthat employtreatmentas a principalelementis satisfied. _,.,

Documentation of No Significant Changes

The Proposed Plan for the Tenth Street site was released for publiccomment in August 1990. The Proposed Plan identified Alternative 4,chemical dechlorination of contaminated soil, as the preferred alternative.

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EPA reviewed al1 written and verbal comments submitted during the publiccomment period, Upon review of these comments,it was determined that nosignificantchangesto the remedy,as it was originallyidentifiedin theProposed Plan, were necessary.

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f'_ Tenth Street Site- CommunityRelationsResponsivenessSummary

The CommunityRelationsResponsivenessSummaryhas been preparedtoprovidewrittenresponsesto commentssubmittedregardingthe ProposedPlan at the Tenth Streethazardouswaste site. The summaryis dividedinto two sections.

SectionI:Backgroundof CommunityInvolvementand Concerns. Thissectionprovidesa brief historyof communityinterestand concernsraisedduringthe remedialplanningactivitiesat the Tenth Street site.

SectionII:Summaryof Major CommentsReceived: The comments(bothoraland written)are summarizedand EPA's responsesare provided.

I: Backgroundof Communit_Involvementand Concerns

The involvementin environmentalissues,includinghazardouswastemanagementis growing. Local chaptersof nationalenviornmentalorganizationsand a varietyof governmentalgroupsare involvedineffortsto safeguardsurfaceand groundwaterresources. Community tconcernsare that the contaminantsfrom the site have leachedinto the !area'sgroundwater. In additionto concernsabout grounwaterquality, f

membersof the communityfear that beforethe site was cappedrainfallcould have washedhazardouswaste from the surfaceof the landfill,spreadingcontaminantsbeyond the boundaryof the siteto affect offsitesurfacesoil and water thus making the area unsafefor recreation.

II. Summaryof Major CommentsReceived

Publicnoticeannouncingthe publiccommentperiodand opportunityfor apublicmeetingwas printedin the Daily Oklahomanon SundayAugust 5,1990. The proposedplan fact sheet was distributedto the sitemailinglist on August 3, 1990. The commentperiodbegan on August 9, 1990 andended September7, 1990. A publicmeetingwas held on August 14, 1990,at the James Stewartbuildingin OklahomaCity, Oklahoma. The purposeofthis meetingwas to explainthe contaminationproblemsat the site anddiscussthe proposedand preferredalternatives.

Approximately20 peoplewere in attendanceand 11 peopleasked questionsor made comments. One letterwas receivedwith comments.

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The comments/questions received durinQ the public comment period concernthe following:

1. Comment: Could the chemicals used in the chemical dechlorination

process be conducted with the soil in place, instead of excavatingthe soil?

EPA response: No, in place dechlorination would not work at the TenthStreet site. The clay soils on the site are too impermeable to allowthe chemicals to mix properly unless excavation is done, Withoutproper mixing, the chemicals would not come in contact with the conta-minated soils and proper decontamination could not occur. Researchconducted by EPA in 1987 also indicated that soils contaminated atdepths of greater than 2 feet were not adequately decontaminated byapplying the chemicals directly to the soil. Treatment of the deepercontaminated soils at Tenth Street would not be effective unlessexcavated.

2. Comment: What is the depth of contamination at the Tenth Street site?

EPA response: The soils at Tenth Street are contaminated with poly-chlorinated biphenyls (PCBs) to a depth of 6 feet. These soils arecontaminated with PCBs at concentrations greater than 25 ppm, the !

remedialactiongoalsetforthissite. lf

3. Comment: Does EPA currently have specifications for the chemical ,_dechlorination equipment to be used at Tenth Street?

EPA response: No, the specifications for this equipment have not beenwritten. Writing the specifications for remedial actions at Superfundsites is done as part of the design. However, the development of thetechnology in the feasibility study was done, in part, based on thespecifications of equipment currently available from vendors.

4. Comment: Wilt vendors who currently own the chemical dechlorinationequipment be the only companies allowed to supply the equipment for theremedy?

EPA response: No. Any vendor who has the equipment, or access to theequipment that can im_ement the remedy will be allowed to bid on theproject. EPA, by regulation (Federal Aquisition Regulations), mustprovide for fair and open competition among vendors when contractingfor Superfund work. Bidders must be able to demonstrate the capabilityto perform the specified work during the bidding process with whateverequipment they have available.

5. Comment: Where has chemical dechlorination been used on a Pull scale?

EPA response: Full-scale chemical dechlorination has been used tosuccessfully treat PCB and dioxin-contaminated materials at the Niagara-Mohawk Power Company in New York, the Western Processing Company in

Washington, and the Montana Pole Treating Company in Montana.

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6. Comment: How much dust wilt be releasedinto the air duringremediationand what precautions will be taken to protect the community fromwindblowndust?o

EPA response: During excavation, water sprays will be used to keepthe soil wet, minimizing the potential for dust to be generated.The rate of soil excavation will also be correlated with the rate oftreatment to minimize the area of soil exposed to the wind at any giventime. Also, air monitorswill be placedaroundthe parimeterof thesite. These monitors will allow the EPA to determine if wind conditionswarrant a slower operation or temporarily ceasing operations due to_ugitive dust emissions.

7. Comment: Will there be an emergency evacuation plan for an event whereexcessivedust is blowr,offsite?

EPA response: No. In the event that high winds generate excessivedust, as measured by the ambient air monitoring, excavation willbe postponeduntil the wind conditionsimproveand fugitiveemissions _':can be controlled.

' y . .

8. Comment: How many Technical Assistance Grants {TAGs) have been awarde__ '_in Region6? '_!'

EPA response: EPA Region6 awardeda TAG to a communitygroup in )Aibequerque,New Mexico for the South ValleySuperfundsite. Thisgrantwas awardedon February23, 1990. Three other grantswere awarded

f-_ by EPA to a group in Jacksonville,Arkansas. However,competinglocalgroupshave challengedthe grantsand finalaward is pendingthe reso-lution of appeals.

9. Comment: One commentorrequesteda postponementof the publiccommentperioduntil a local communitygroup has beenawardeda TAG and receivedthe assistancenecessaryto evaluateEPA's ProposedPlan for the TenthStreet site.

EPA response: In a letterdated September7, 1990, this requestwasdeniedby EPA. In arrivingat this decision,EPA consideredthetime requiredby the group to procurethe servicesof an advisorwerethe grant to be awardedin October1990. EPA believesthat, since thegrantmay be used by the communitygroup to reviewthe desigr_andoperationof the remedy,a delay in the selectionof a remedialtechnologyis not warranted. '

10. Comment: One commentor believed that a TAG would give local citizensthe opportunityto hire a consultantto conducta remedialinvestigationand feasibilitystudy at Tenth Street.

EPA response: A TAG is not availablefor this purpose. This grantare availablefor local citizen'sgroupsto reviewand interpretEPA'sstudiesduringall phasesof a Superfundproject. Grantsare notavailablefor independentinvestigationsconductedby local groups.

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11. Comment: A TAG would not be helpful to the local community after theRecordof Decisionis signedfor the TenthStreetproject.

EPA response': This is not true. TAGs may be used by the communitygroup to hire an advisor to review and interpret both the remedialdesign and construction activities conducted at Tenth Street.

12. Comment: At what stage is application for the TAG and when might itbe awarded?

EPA response: A magnafax copy of the grant appliacation is beingreviewed by the EPA Regional office in Dallas. The grant may beawarded in October 1990, provided that an original, signed copy ofthe application is received by the Regional office by September 30, 1990,and the application complies with Federal grant regulations.

13. Comment: EPA appears to be delaying the award of a TAG until theremedial action is completed.

EPA response: This is not true. Previous draft applications submittedby the local citizen's group since March 1990 have been incom_ete orincorrect. EPA cannot, by grant regulations, award a TAG unless theapplicationis completeand correct. Representativesfrom EPA have iassisted the group on numerous occasions in correcting the application.

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In some cases,commentson draft applicationswere not addressedin )subsequent submittals.

14. Comment: Why was Alternative #2, Capping in Place, not considered atTenth Street?

EPA Response: Construction of a cap on the Tenth Street site would notsatisfy the preference for treatment to reduce mobility, toxicity, orvolume stated in the Superfundlaw. EPA also expects,as outlinedinthe National Contingency Ptan (NCP), to treat wastes that constitutea principal threat at a site. Soils contaminated with greater than300 ppm PCBs are considered the principal threat at Tenth Street andby regulation should be treated. Also, capping was not consideredan appropriate remedy because the site is in the lO0-year floodplain of the North Canadian River and would require perpetual maintenanceto preventfutureexposureto contaminatedsoil.

15. Comment: How was the selectionof the ProposedPlan among Alternatives3, 4, and 5 made?

EPA response: These alternatives were compared against nine criteriaoutlinedin the NCP and the statutorypreferencesin the Superfundlaw.Alternative 3, offsite land disposal, does not meet the statutorypreference for treatment as a principal element of the remedy. Offsitedisposalwithouttreatmentis also the least preferredalte,nativeforSuperfundsites. Alternative5, onsitethermaldestruction,was notproposedin favor of an innovativetechnology. The Superfundprogramexpectsto select innovativetechnologiesat siteswhere such atechnologyispracticeable.

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16. Comment: Why is EPA selecting a technology rather than writing performancespecifications for cleaning up the site and taking bids on acceptibtesolutions for addressing the contaminants at Tenth Street?

EPA response: The process by which EPA selects remedies at Superfundsites is set forth in the National Contingency Plan (NCP). The NCP isthe regulation that governs the Superfund program. This process allowsEPA to screen out those technologies that are clearly inappropriatefor the Tenth Street site. As part of the design phase of this project,performance specifications will be written, These specificationswill include the required level of treatment and length of time requiredto complete the treatment process.

17. Comment: Has a health and safety plan for the construction at thissite been written?

EPA response: No. However, a health and sdfety plan, outliningcommunity and worker safety procedures, must be written and in placeprior to the start of construction activities at the site.

18. Comment: What is the currentprojectschedule? i!

EPA response: EPA will select the remedy for Tenth Street in iSeptember lggo. The design of the selected remedy is scheduled to !begin in March 1991, after a statutorily required moratorium periodto allow potentially responsible parties, if any, to take over theproject. The design will be completed in March I992, with aninvitation for bids being released by EPA shortly thereafter. EPAexpects field work to be begin in Summer 1992 and end in Summer 1993.

lg. Comment: EPA had already selected the remedy at the time of thepublic meeting.

EPA response: This is not true. EPA had proposed a remedialtechnology for the Tenth Street site at the public meeting.. Theplan was proposed as the best technical solution for the site, based _on the criteria outlined in the NCP. EPA does not select the remedyfor a site until alt of the comments made during the public commentperiod have been considered.

20. Comment: What was the predominant species of PCBs found at TenthStreet?

EPA response: The predominant species of PCBs found at Tenth Streetwas Aroclor 1260.

21. Comment: What are the toxicity and persistance of PCBs?

EPA response: EPA currently classifies PCBs as a Class B carcinogen,or a probable carcinogen. The EPA Cancer Assessment Group has

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estimated the cancer potency factor to be 4.0 (mg/kg/day)'1 andhas used this factor in health advisories issued by EPA. Based onlaboratory animal data, there is a potential for reproductive effects,developmental toxicity in humans exposed to PCBs. PCBs are alsoextremely persistant in the environment and can bioaccumulate in

the fatty tissues of exposed organisms (Federal Register ,July 10, 1986).

22. Comment: Does the cap that is currently on the site provide adequateprotection of human health and the environment form the contaminationat Tenth Street?

EPA response: No, it does not. The cap that was installed on the sitein 1985 by EPA was intended to temporarily prevent direct contact andmigration of contaminated soil. Stabilization of the site allowedEPA to evaluate more permanent solutions to the problems at TenthStreet. As seen by the current deterioration, the temporary capdoes not provide adequate long-term protection. As stated previously,the degree of protection afforded by any cap is questionable becausethe site is located in a lO0-year flood plain.

23. Comment: To what extenthave PCBsmigratedoffsite? i

EPA response: Samples taken during the 1985 removal action indicatesthat the only offsite PCB contamination exists in the right-of-waybetween the north site boundary and Tenth Street at a depth of 3 to 4feet below the surface. Surface soils are clean along the right-of-wayand do not pose a threat to pedestrians.

24. Comment: How deep were soil borings drilled during the remedial inves-tigation?

EPA Response: Soil borings were drilled to a depth of six feet. Soilsamples taken at this depth were not contaminated aboye the remedialgoals, indicating that deeper borings were not necessarY.

25. Comment: Can EPA promote the use of local firms for the remedialwork at Tenth Street?

(

EPA Response: EPA cannot give preference to local contractors becauseof their location. However, local companies can have a competitiveadvantage due to lower transportation costs. By the Federal AcquisitionRegulations, the selection of a contractor to implement the selectedremedy must be done through an open and competitive bidding process.EPA's prime contractor must also select subcontractors in _his manner.

26. Comment: What will the consultant hired to design the remedy actuallydo?

EPA response: The remedial design consultant wilt develop the contractsand bid documents necessary to procure a contractor to implement theremedy selected in the Record of Decision. The consultant wilt not be

6

directed to select a remedy for Tenth Street. The consultant willalso develop the specifications and blueprints for the remedy and

{_ methods of.verifyingthe performanceof the contractor.

27. Comment: Shouldn't a consultant be hired to recommend a remedy forTenth Street?

EPA response: Consultants may be hired to develop and evaluatepotential remedial alternatives for consideration by EPA. Theresponsibility to recommend and select remedies at Superfund sitesis solely EPA's by law.

_8. Comment: Is the equipment necessary for chemical dechlorinationcommercially available?

EPA response: Yes, one manufacturer, Galson Inc., of Syracuse, NewYork, has built a full-scale unit for use with contaminated soils.Other full-scale units have been used at the sites discussed in theresponse to comment #6.

_9. Comment: How much time will be required to treat each batch ofcontaminatedsoil in the chemicaldechlorinationunit? _

iEPA response: Experiencesat other sites and the treatability )study conducted on the Tenth Street soil indicate that each batch )of soil can be treated to less than _.0 ppm PCBs in approximately4 hours. At this rate, the 7,500 cubic yards of soil at Tenth Streetcan be treated in approximately g months.

30. Comment: What volumes of soil and reagent are mixed together in thechemical dechlorination process?

EPA response: Approximately 2 tons of soil are treated by 1 ton ofreagent (potassium or sodium hydroxide, polyethylene glycolate 400,and dimethyl sulfoxide) in each batch treatment process. The reagentsare recovered for reuse in subsequent batches.

31. Comment: How large will the excavation area onsite be during im_e-mentation of the remedy?

EPA response: The excavated area will be approximately equal tothe rate of treatment. Pot exam_e, EPA assumed in the feasibilitystudy that 30 cubic yards of soil would be treated per day. Excavationwould be done at the same rate with some material being stockpiledprior to treatment.

32. Comment: Did the remedialinvestigationindicatethe extentof theoriginal landfill at the site?

EPA response: No, it did not. EPA was primarily interested in PCBcontaminationat the site. However,samplestaken from boringsandmonitoring wells indicated that no remnants from the original landfillexist at the site.

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33. Comment: Will the material under the PCB-contaminated soil supportheavy equipment that may be needed to Implement the selected remedy?

i

EPA response: Yes. Soil logs taken from borings during the remedialinvestigation indicate Chat the deeper soil is solid and will supportheavy equipment.

34. Comment: W_ll the selected remedy be sufficient to address any addi-tional contamination that may be found after excavation begins?

EPA response: Yes, _t will be able to handle any additional soil found·at the site. Howe_er, the length of time required to complete theremedial action will increase.

35. Comment: Will there be any reason to close off parts of Tenth Streetto traffic during remediation?

EPA response: No, there won't be any reason to close of the street totraffic. W_ndblown dust will be controlled by sprays and keeping thearea of excavation to a minimum. Chemical dechlorination will be donein a completely enclosed unit, including reagent mixing, eliminatingair emissions from the process. Should weather conditions innibit iexcavation, operations would be postponed as a precaution. I

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36. Comment: Why was Tenth Street selected for cleanup as opposed to !

other sloes _n the area?

EPA response: Leaking drums discovered on the site in 1985 were removedby EPA to prevent any exposure to local populations or the environment.Because of the presence of PCBs in the soil and the potential for futureexposure, the site was placed on the National Priorities List, becomingeligible for funding for investigations and permanent remedial action.

37. Comment: Does the Tenth Street site have the highest Hazard RankingSystem score of any NPL site in the Oklahoma City area?

EPA response: No. Two other NPL sites, Tinker Air Force Base andthe Mosley Road Landfill have higher scores. It should be noted thatrelative scores are not used to set remedial priorities among Superfunasites and represents only a conservative rating of potential threatsbefore any intensive studies are conducted.

38. Comment: W_I! further treatment of residuals be required afterchemical decnlorinat_on is completed?

EPA response: Yes. Approximately 10 tons of solid residue from thetreatment process w_ll require offsite disposal as a PCB waste.Reagents are recovered and the treated soil will be used as backfillonsite.

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39. Comment: Is the chemical dechlorination process a patented process?

EPA response: The general process is not patented. However, the useof proorie_cary chemicals or specialized equipment has ted to patentson those variations by vendors. Contractors would have to negotiatefor patent rights or leases with vendors to use specific equipment.

40. Comment: PCBs at Tenth Street do not currently pose a threat to thesurrounding community; such a threat may potentially result only if thesite was disturbed.

EPA response: EPA never indicated that the site posed a current threatto the community, The need to take remedial action is based on thereasonable maximum exposure expected under future commercial land use.The consideration of future land use in setting remedial action goalsis consistent with the National'Contingency Plan and the Risk AssessmentGuidance for Superfund, Volume 1, December 1989. EPA considers futureland use to be reasonable at Tenth Street based on the current surround-ing land use (commercial) and inquiries that have been made to EPAby parties interested in commercial development of the property.

41. Comment: Remedial action at Tenth Street is contrary to national

policy because the baseline (current) risk at the site is already t

withintheremedialtargetrangesetby EPA. t!

EPA response: The National Contingency Plan (NCP) and nationalpolicy dictate that remedial action be taken at the site. The NCP

/_ 10'v (i.e., 1 in 1,000,000) risk level as the "point of departure" fordetermining remedial action goals when other standards are not available.EPA expects to achieve this level of protection when practicable.

The tlCPalso dictates that remedial actions comply with Applicableand Relevant and Appropriate Regulations and other policies andguidelines. These are listed in the preamble to the NCP and includethe Toxic Substances Control Act PCB Spill Cleanlp Policy (FederalRegister, April 2, 1987). As a matter of policy, EPA commies withthe cleanup levels set in the Spill Cleanup Policy. For commercialareas, this level is set at 25 ppm PCBs in soil. Of the 32 Recordsof Decision signed since the passage of SARA, for sites where PCBsare the contaminant o_ concern, 5 have selected cleanup levels ofppm PCBs. More stringent cleanup levels (10 ppm or less) have beenset at sites where residential exposures were considered.

42. Comment: Physical and legal restrictions could provide a level ofprotection comparable to any remedial action taken at the site.

EPA response: Section 300.430 (a}(iii) of the NCP states thatinstitutional controls shall not substitute for active response actionsas the sole remedy unless such active measures are impracticable. Asthis is not the case at Tenth Street. SARA expects to use treatment,not physical restrictions, as the principal element of remedial actionsat Superfund sites.

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43. Comment: The risk associatedwith the operationof the chemicalaechlorlnation process should be compared to the long-term risksposed by the-existing s_te.

EPA response: EPA does not measure short-term risks l_ the same mannerthat long-term r_sks are measured. However, the toxicities of thereagents and byproducts of the process can be compared to the toxicityof PCBs as a measure of the relative risks. A comparison of the reagents,the byproducts, PCBs, and other reference materials _s presented below:

MATERIAL LD50,ORAL-RATS

Polyethyleneglycol-400 27,500mg/kgDlmetnylsulfoxide 17,500mg/kgPCBs 1,010 mg/kg

Th_s data indicates that PCBs, the contaminants of concern at TenthStreet, are 27 times more toxic than polyethylene glycolate and 17times more toxic than dimethyl sulfoxide, the reagents in the chemicaldecnlorlnat_onprocess. Ethyleneglycol-400is also approvedby the _Food and Drug Administrationfor use in food and cosmetics. The jLD50 is the dose that causesmortalityin 50 percentof the test iorganisms. These tests were conducted on laboratory rats, considering t

oral ingestion. EPA researchalso indicatesthat dechlorinatedmixturesof 2,3,7,8-tetradioxln are 350 times less toxic than 2,3,7,8-tetraaioxinitself. The treatment byproducts ad not demonstrate any carcinogenicpotential based on the results of Ames tests conducted by EPA.

Materials handling w_ll not pose any short term risk during implementationof the remedy. Ex_sting chemical decnlorinat_on equipment is completelyautomated. Reagents, byproducts, and soils are handled in completelyenclosed systems using pumps and conveyor Pelts for materials handling.The system also addresses air emissions through condensors for watervapor and carbon filters for volatile organics. No contaminantsare released to the atmosphere during the treatment process.

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" ]31TRODUGTZON

Section ll3(J)(1) of the Comprehensive Environmental Response,Compensation, and Liability Act (C]flICXA) provides that Judicialreview of any issues concez_ing the adequacy of any response actionshall be limited to the adainistrative record which has beencompiled for the site at issue.

Section ll3(k)(l) of CBIICLI, requires that the United StatesEnvironmental Protection Agency (Agency) establish administrativerecords for the selection of CBRCLI response actions. Theadministrative record is the body of documents upon which theAgency based its selection of a response action. The Agency,s.decision on selection of a response action must be documentedthoroughly in the administrative record. The Agency must ensurethat the record is a compilation of documents leading up to and

reflecting the Agency,s response decision, i

In accordance with U.S. EPA Headquarters SEWER Directive 9833.3v

Section lZ3(k) of the Comprehensive Environmental Response,Compensation and Liability Act (C_RCLA), as amended in L986by the Superfund Anendments and Reauthorisation Act (Sm)the U.S. EPA is required to compile and make available to thepublic Administrative records containing documents used tosupport response actions authorized under _ and sm.The Administrative Records are to be maintained at the relevantU.S. EPA Regional Offices as Well as 'eat or near the facility atiSaUetU.

This Administrative Record File Index has been compiled inaccordance with OSWER Directive l_,mher 9833.18 Interim Guidanceon Administrative Records for Decisions on Selection of CBRCLAResponse Actions. This guidance reflects, to the extent practicable,revisions being made to the National Contingency Plan (ICCP).

This Administrative Record File Index consists of informationupon which the Agency based its decision on selection of responseactions. It is a subset of information included in the sitefiles. The records in this Administrative Record File Indexhave been arranged in chronological order (from the earliestdate to the most recent date), based on the date of the corres-ponding document. Each document contained in the AdministrativeRecord File has been stamped with a unique Document _,mher, to

/-_ assist in the location of the document within the Record File.

i I

09tZ8/89 AdministrativeRecord- CategoryNu_erOrder Page: ITenth Street

OocumentNu_er: I1-0001 Oate:02/07/83

OocumentTitle: PotentialHazaarousWasteSite- SiteInspectionReport'FrazierPit[lOthStreetSite),N.E.lothStreet,OklahoCity,Oklahou

Type:Report/StudyDocumentQualifiers(s): Original/Ouplicate of Original,

Author:PhilpE.Sumner,Jr.,FITCivilEngineerEcologyt Environment,Inc.

Recipient: StaffUSEPARegionS

TotalPages:15

DocumentNu_er: 11-0002 Date: 09121/84 i

DocumentTitle: AmemoranOueprovi_liq informationas requestedby USEPAreprding loth Street Site.

Type:Memorandum 'DocumentQualifiers(s): Original/Ouplicate of Original,

Author: WibTrubyOklahomaState Oepartmentof Itealth

_ecipient:FentonRo_Ok_ahumaStateDepartmento¢Health

'31 Pages: 2

OocumentNumber:il-DOD3 Date: 10101/84

DocumentTitle: ASection 104(e) letter requestinginformationrelated to activities at the loth Street Site.

Type: LetterDocumentQualifiers(s): Original/Ouplicate of Original,

Author: Allyn _. Davis, Director *'USEPARegion6,Air& WasteHanagementDivision

_ecipient:WilliamSpain,President _'"SouthwestElectric Co.

:otal Pages: 3

09/28/89 A_inistrativeRecord- Category_u_erOrder Page: 2Tenth Street

--ment Number:)]-0004 . Oate:10/01/84

_ocumentTitle: S_ling reportfortheN.E.lothStreetSite.

Type:Report/StuUy_ocumentQualifiers(s): Origi_l/Dupiicateof Origi_l,

Author:FrankE.Onellion,TATWeston-Sper

_ecipient:CharlesA.Gazda,ChiefUS[PARegionG,EmergencyResponseBranch

;otalPages:23

bocumentNumber:11-0005 Bate:10102/84I

OocumentTitle:Siteinspectiontodelinatetheareathatcoataineddrumsof suspectedhazardouswaste. I

_j]_[Report/StudyF_ent Qualifiers(s): Original/Ouplicate of Original,

Author:FrankE.Onellion,TATWeston-Sper

aecipient:CharlesA.GazUa,ChiefUS[PARegionG,Emer_ncyResmnseBranch

Fotal Pages: 24

)ocumentNumber:li-0006 Bate:lO/iT/B4

]ocumentTitle:A responsetotheSection[g4(e)requestletter,fromSouthwestElectricCo.

_ype: Letter _)ocumentOua)ifiers(s): Ortginai/Ouplicate of Original,

_uthor: William L. Spain,PresidentSouthwestElectric Co.

_ecipient: Allyn _. Oavis,OirectorUS[PARegion6,Airt Waste_anagementOivision

'o_,, _ages: 3

ienth Street

DocumentNum_r: ll-O00T Date: IZ/IZ/84

DocumentTitle: Awritten r_cordof Testimonybefore the Subcommitteeon Environment,£nergyandNatural Resourcesconcerninggeohydrologyof the areaof Tinker AFD.

Type: Report/StudyDocumentQualifiers(s): Original/Duplicate of Original,

Author: Dr. CharlesJ. Hankin,DirectorOklahoMGeologicalSurvey

Recipient: SuUcommitteeon Envirorment,Energy& HtRUnitedStates Congress

TotalPages:12

DocumentNumber:IleO008 Date: 04/17/85t

DocumentTitle: CDCreviewof loth Street Site data.r

Type:_emorandum "_'OocumentQualifiers(s}: Original/Duplicate of Original,

Author: GeorgiA. Jones,Chief, Superfu_i ImplementationGroupUSHHS,Public HealthService, CDC

Recipient: GeorgeC. 8uynoski,PublicHealthAdvisorUSEPARegion6

Total Pages: l

DocumentNumber:11-0009 Date: 05/15/85

DocumentTitle: Soil Salpling: Samplingof the loth Street Site by the TechnicalAssistanceTeam.

Type: Report/StudyDocumentqualifiers(si: Original/Duplicateof Original,

Author:Dennis_.Howard,TATHemmer : "'Weston-Sper

Recipient: GeraldFontenot,DeputyProject OfficerUSEPARegion6, EmergencyResponseBranch

Total Pages: 12

09/28/89 AdministrativeRecord- CategoryNumberOrder Page= 4. TenthStreet

_ent Number:11-00]0 Date:05/23/85fi

OocumentTitle: A letterdescripingthefindingsandpossiblehealtheffectsatthelothStreetSite,andrequestingassistanceinthelimitingofaccesstothesite.

Type:LetterwithAttachments

OocumentQualifiers(s): Original/Ouplicate of Original,

Author: FreOP. Walker,PhD,,Environmental[pidemiologistOklahomaStateDepartmentofHealth

Recipient:RollinFullbrightDeadeye'sSalvageYard

TotalPages: 4

Oocu_entNumber:[1-0011 Date:06/0SI85

OoculentTitle:A SectionIO4(e)letterrequestinginfor_tionrelatedtoactivitiesat thelothStreetSite. If

Type:Letter

Ooc_p_ Qualifiers(s): Original/DuplicateofOriginal,

Author:Allyn_.Davis,DirectorUSEPARegion_,Air& WasteManagementDivision

_ecipient: OklahomaGas&ElectricOklaho_ City, OklahoM

Total Pages: 3

/

)ocumentNumber:ll-OOl2 Oate: 06121185i

)oc_ent litle: I Section iO4(e) letter requesting i_orution related to activities at the loth Street Site.

ype: LetterocumentQualifiers(s}: Original/Duplicate of Original,

_thor: Allyn _. Oavis, Director "USEPARegion6, Air &WasteManagementDivision ,,

.cipient: Cecil JoeJesus is LordSalvageYard

tal f_: 3

I

Og/28/Sg Administrative Record- Category#umberOrder Page: 5TenthStreet

DocumentNumber:11-0013 - Date: 06/28/85

OocumentTitle: Responsefrol OklahoMGasi Electric to Section 104(e)request letter.

Type:LetterOocumontqualifiers(s): Original/Duplicate of Original,

Author: C.L. Tyree, Chief, EnvironmentalAffairsOklahomaGas& Electric

Recipient: Nartl__. RcKeeUSEPARegion6

TotalPages: 2

OocumentNumber:11-0014 Date: 07/10/85 i

letterrequestinginformationrelatedtoactivityatthelothStreetSite.[Sec_Requ+t]Oocu_entTitle A SectionIO4(e)

Type:LetterDocumentqualifiers(s): Original/Duplicate of Original,

Author: RobertHannesschlager,Acting ChiefUSEPARegion_, SuperfundBra_ch

_ecipient: SuJiivanScottOklahomaCity,Ok)ahoma

TotalPages: 2

OocumentNu_er: iI-OOIS Oate:OT/I!/8S

OocuMntTitle:A Section104(e)letterrequestinginformationrelatingtoactivitiesatthelothStreetSite.

Type:Letter]ocumentqualifiers(s): Original/Duplicate of Original,

_uthor:WiLliamB.Hathaway,ActingDirectorUSEPARegionS,Airt WasteIlanHementDivision

_ecipient: GeneralElectric CmmpanyOklahomaCity, Oklahoma

_otal Pages: 3

'i

09/28/89 AdministrativeRecord- CategoryNuler Order Page: 6TenthStreet

/_nt Number:ll-O016 - Date: 07/11/85

OocumentTitle: I Section104(e)letterrequestinginforMtionrelatedtoactivityat thelothStreetSite.

Type: LetterDocumentQualifiers(si: Original/Duplicate of Original,

Author:WilliamB.Hathaway,ActingDirectorUSEPARegion6,Air& WasteManagementDivision

Recipient: ElmerCobbOklahomaCity, OklahoM

TotalPages: 3

DocumentNumber:i1-0017 Date:OT/IS/85 i

OocamentTitle: A responsefromJoeCecil to the Section i04(e) letter of JuneZI,!g85, I

Typa,_LetterDdt Qualifiers(s): Orfginal/Oupllcateof Original,

Author: JoeCecilJesusis LordSalvageYard

Recipient: StaffUSEPARegion6

Total Pages: I

DocumentNumber:11-0018 Date: 08107/85

DocumentTitle: Responseby the GeneralElectric Companyto the Section 104(e)request letter.

Type: LetterOocumentQualifiers(s): Original/Duplicate of Original,

Author: EugeneR. Baker,CounselGeneralElectric Company,EngineerredRaterials Group

aecipient: RarthaMcKee

USEPARegion

Total rages: I

1

09/28/89 AMinistrativeRecord- CategoryNumberOrder Page: 7Tenth Street

Ooc_entNumber:]l-OOI9 . Oate:08/23/8S

OocumentTitle: ACTION_E_RANOUN- immediateRemovalRequestForthelothStreetSite,OklahoMCity,Okla..

Type: _emorandumDocumentQualifiers(s): Original/Ouplicate of OrigiMI,

Author: KarenSolari, OSCUSEPARegion6, Field ResponseSection

Recipient: Dick Whittington,P.E.,Reg.A_lministratorUSEPARegion6

TotalPages: S

lmmemll*eleelmlmll*lmemleilme_eeleelle--Imimllllmlemmmmelllllelimmmmle.ele!immm

OocumentNumber: II-OOZO Oate: 08/Zg/B5

OocumentTitle: AONINISTRATIVEORDERdirecting _at certain rmedial activities be undertakenat the loth Street Site.f

Type: ffiscellaneousDocumentQualifiers(s]: Original/Duplic_e of Original,

Author: FrancesE. Phillips for RegionalAdministratorUSEPARegion6

Recipient: Sullivan Scott/ElmerC_OklahomaCity, Oklahuma

Total Pages: IZ

OocueentNu_er: II-OOZI Date: 6_/24/8S

OocumentTitle: Final Report:Off-site s_ling at the loth Street Site [08185][Includes S_ling Data]

Type: _emorandumDocument_ualifiers(s): Original/Duplicate of Original,

Author: ThomasA. Walzer,FIT ChemicalEngineerEcology&Environment,Inc.

_ecipient:KeithBradley,R_ RegionViUSEPARegion

otalPages:_3

l

09/28/89 AdministrativeRecord- CategoryNumberOrder Page: 8TenthStreet

_-"ument Number: 11-0022 . 9ate: 10/Z9/85

DocumentTitle: HRSPackage:Includessamplingdata for preliminaryassessmentwith suanaries.[Locateclin site file, USEPARegion6,Oallas]

Type: MiscellaneousOocumentQualifiers(s): Original/Duplicateof Original,

Author: Referenceas to location

_ecJpient:

TotalPages:478

OocuaentNumber:I1-0023 9ate: 10130/85 i

DocumentTitle: Sampling9amaResults, Chainof CustodyRecordsfor Sept. 1985[Available in ERVol.4, USEPARegio_&, Oa)las]

Type: Sampling/Analyses/gata

O_',nt Qualifiers(s): Original/Duplicate of OrigiMi,

Author: Referenceas to location

_ecipient:

[oral Pages: O

*om_mmmmlmmfm_mlm.memmm_lem_mmm_mmme.m_mmm.mm_e._mm--me__mememmlmm_l.mlm.mmmomf

_ocumentNumber:II-OOZ4 Date: Ol/lS/86

_ocuaentTitle: A aemodescribing different areasand locations of hazardousvas(esat the loth Street Site, vith a nap.

Type: Memorandum3ocuaentQualifiers(s): Original/Duplicate of Original,

_uthor:StaffSunbelt[nviro_entalManagement,Inc.

_ecipient:SiteFileUSEPARegion

IT

)

09128189 AdministrativeRecord- CategoryHumberOrder Page: 9TenthStreet

OocumentNumber:!i-002S - Oate: OS/OS/B6

OocumentTitle: ACTIONFIENORANDUN- Six NonthTime[xelption to Allow Continuationof RemovalActivities at the loth Street Site.

'Type: ffelorandulOocuaentQualifiers(s): Original/Duplicate of OrigiMI,

Author:KarenSolari,OSCUSEPARegion6,FieldResponseSection

Recipient:DickWhittington,P.[.,Rq.AdministratorUS[PARegion6

TotalPages: 2

_)ocuaentN_er: 11-0026 Date:01/Z3/87 i

DocumentTitle: 'SalvageYardItakesEPAList' Anevsarticle on the addition of the Illth Street Site to the NPL.

Type'Newsier/JournalArticleOocummntOualifiers(s): Original/Ouplicate of Original,

Author:WayneSingleterryTheDaily Oklaholmn

Recipient: Site FileUSEPARegion6

TotalPages: I

_,'

OocumentN_er: 11-0027 Date:09/ZA/B7, )

OocuBentTitle: AfterActionReportforthelothStreetRemovalAction.

Type:Ilemorandua_ocumentqualifiers(s): Original/Duplicate of Original,

_uthor: CharlesA. Gazcla,Chief ":**"USEPARegion6, EmergencyResponseBranch

!ecipient:RobertE.Nannesschlager,Chief =US[PARegion6,SuperfunclBranch /

oralPages:33

; 09/28/89 AdministrativeRecord- CategorxN_er Order Page: lOTenth Street

_entNmm_er:I1-0028 - Date: 04/01/8g

OoculentTitle:Workplan;SiteS_ling & QualityAssurance/QualityControlPlan;Site_fety planforthelothStreetS_erfu_-Site,Olaho_City,Oklah_

Type: _iscellaneousOocmmentQualifiers{s): Original/Ouplicate of Original,

Author: StaffUSEPARegionG,HazardousWasteNgatDivision

Recipient:SitefileUS[PARegion

Total Pages:119

DocumentNumber:lJ-OOZ9 Date:091&5/89 !

DocumentTitle: CommunityRelationsPlan

Ty_--.Comunity RelationsPlanOo_.t Qualifiers(s): Original/Duplicate of Original,

Author: StaffUSEPARegion6,HazardousWasteDivision

Recipient:SiteFileUS[PARegion6

Total Pages: 2_

DocumentNumber:II-OO30 Date:09/26/69

OocumentTitle: RISamplingData[Resultscurrentlyinreviewandinterpertation](_mtactRPM,USEPARegion6)

Type:Sampling/Analyses/DataOocumentQualifiers(s): Original/Duplicate of Original,

Author:Referencesasto location _ ,,,

Recipient:

Total_ages: 0

I

ADMINISTRATIVE RECORD INDEX

ADDENDI_

t'

SITENAME: TENTHSTREETDUMPSITE t

SITE NUMBER: OKD 980620967 w-_

INDEX DATE: 08/02/90

ADMINISTRATIVE RECORDII_F._

ADDENDUM

SITE NAME: TENTH STREET DUMP SITESITE NUMBER: OKI)980620967

DOCUMENT NUMBER: 31·DOCUMENT DATE: 05/31/89

NUMBEROF PAGES: 026AUTMOR: Office fo Waste Pro&rams EnforcementCOMPANY/AGENCY: U.S. EPA HQRECIPIENT: U.S. EPA Region 6 Site FilesDOCUMENTTYPE: Compendium and Users ManualDOCUHENTTITLE: 'Compendium of CERCLA Response Selection Guidance Documents -

Users Manual'

DOCUMENTNUMBER: 32DOCUMENTDATE: 03/31/90NUMBEROF PAGES: OgOAUTHOR: EPA StaffCOMPANY/AGENCY: U.S. EPA Region 6RECIPIENT: U.S. EPA Re&ion 6 &ice Files iDOGUFW/rfTYPE: Report

DOCUMENTTITLE: Remedial Investi&ation Report - Volume 1 !

DOCUNENTNUMBER: 33DOCUNENTDATE: 03/31/90

_-_ NUMBER OF PAGES: 386[

AUTHOR: EPA StaffCOMPANY/AGENCY: U.S. EPA Region 6RECIPIENT: U.S. EPA Re&ion 6 Site FilesDOCUMENTTYPE: ReportDOCUMENTTITLE: Remedial Investisation Report - Volume 2

DOCUMENT NUMBER: 34DOCUMENT DATE: 05/31/90NUMBER OF PAGES: 004AUTHOR: EPA Staff

COMPANY/AGENCY: U.S. EPA Region 6RECIPIENT: U.S. EPA Region 6 Site FilesDOCUMENTTYPE: Site UpdateDOCUMENT TITLE: "Tenth Street Site Update"

A-1

ADMINISTRATIVE RECORD INDEX

ADDENDUH

SITE NAME: TENTH STREET DUMP SITESITE NUMBER: OKD 980620967

DOGUYtEI_NUI_ER: 35· DOCUHENTDATE: 06/30/90NUMBEROF PACES: 068AUTHOR: EPA StaffCOMPANY/AGENCY: U.S. EPA Region 6RECIPIENT: U.S. EPA Region 6 Site FilesDOCq/HENTTYPE: Assessment

DOCUMENTTITLE: 'Baseline Risk Assessment for =he Ten=h Street Dump SuperfundSite, Oklahoma City, OK'

DO_ NU_ER: 36

DOCUMENTDATE: 07/02/90 ,-'NU_ER OF PAGES: 017AUTHOR: EPA Staff

COMPANY/AGENCY: U.S. EPA Region 6RECIPIENT: U.S. EPA ReBion 6 Site FilesDOCUMENT TYPE: Plan !DOCUMENT TITLE: 'Proposed Plan - Tenth Street Superfund Site, Oklahoma City,t

OK' !

DOCUHENTNUKBER: 37IX)CUHE_ DATE: 07/31/90NUNBEROF PAGES: 138AUTHOR: EPA StaffCOMPANY/AGENCY: U.S. EFAKegion 6RECIPIENT: U.S. EPA ltegion 6 Site FilesDOCUMENTTYPE: ReportDOCUMENTTITLE: FeasibiLL=y Study Report for Tenth Street Superfund Site -

Oklahoma CitT, OK

A-2 I

r ,


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