First five-year review report for Tenth Street Superfund site, Oklahoma City, Oklahoma County, Oklahoma

              FIVE-YEAR REVIEW REPORT
FIRST FIVE-YEAR REVIEW REPORT
for
Tenth Street Superfund Site
Oklahoma City
Oklahoma County , Oklahoma
EPA ID# OKD980620967
September 2001
Prepared by:
U.S. Environmental Protection Agency, Region 6
Dallas, Texas
and the
Oklahoma Department of Environmental Quality
Oklahoma City, Oklahoma
\
Concurred by: A^L^LQ V^AVAViJct'
Stacey Bennei P.E., US EPA
Remedial Project Manager
Date
Concurred
Gus Chavama,US hrA
Chief, Texas/Arkansas Programs Section
Date
Concurred by: //.,.'-((i^^c^^ ^-Mr.j^.^A /..i -A
Tracy She^p^rd, U.S. EPA
Regional Counsel Superfund
Date
146341
Concurred by:
Chief, Texas/Arkansas Branch
Concurred byL J^>^<^^^ J^L,
Mark A. Peycke,p.sTEPA
Regional Counsel Superfund
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/Date-
Concurred by:G^ 1/L{D^4^-
JMne Buzzell, water Editor
Superfund Division
Date
•&
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
1445 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
MEMORANDUM
From: Stacey Bennett, P.E. . ^ l a ^(J
Remedial Project Manager (6SF-AP)
Through: William Honker, Chief ,c
TX/AR Branch (6SF-A^
To: Myron 0. Knudson, P.E., Director
Superfund Division (6SF)
RE: Approval of the First 5-year Review
Tenth Street Superfund Site
OKD980620967
This memorandum approves the 5-year review report dated September 2001, which was
prepared jointly by the U.S. Environmental Protection Agency Region 6 and the Oklahoma
Department of Environmental Quality. Based upon the 5-year review report, the Tenth Street
Superfund Site remedy is protective of human health and the environment.
The 5-year review was a statutory requirement as per the NCP part 300.430 (f)(4)(ii) of
the Code of Federal Regulations. The review was comprised of: 1) inspecting the areas
remediated, 2) conducting a review of ground water sampling data, 3) inspecting the River, and
4) interviewing a nearby business owner, a former member of a community advisory group, and a
city council member to determine whether there were additional concerns regarding the remedy
and its protectiveness.
Although the results of the review concluded that the overall remedy is protective of
human health and the environment, there were 3 minor issues that must be addressed to ensure
future protectiveness of the remedy. All issues will be followed up by the State before the end of
the calendar year.
Minor Issues
1. The current 0 & M plan (dated 1995) requires groundwater sampling annually and
mowing of the grass twice a year. The current frequency of mowing has been altered to
meet the seasonal needs.
Action: Because no PCBs have been detected in the groundwater for the last 5 years, it
Internet Address (URL) - http://www.epa.gov/earth1 r6/
Recycled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
is recommended that the sampling of the wells be reduced to once every other year instead of
every year. Mowing of the grass will continue twice a year, unless there is a fire danger from
letting the grass grow too tall in dry years. The 0& M plan should be revised to incorporate
these changes.
2. All monitoring wells are located outside of the Site fence and do not have locks to
prevent unauthorized access.
Action: The ODEQ will place locks on all monitoring wells before the end of the month.
3. There are no institutional controls in place to prevent future land uses or activities from
placing structures or digging into the cap.
Action: The EPA and State should meet with the City and appropriate owners to determine how
this issue can be addressed. One potential mechanism is the use of a deed notice.
Determinations
I have determined that the remedy for the Tenth Street Superfund Site is protective of
human health and the environment, and will remain so provided the minor concerns identified in
the Five-Year Review Report are addressed as described above.
^0^1 ,^ C
Myron 0. Knudson, P.E.
Director
Superfund Division
U.S. Environmental Protection Agency
Region 6
Date
Five-Year Review Report
First Five-Year Review Report
For
The Tenth Street Superfund Site
Oklahoma City
Oklahoma, Oklahoma
OKD980620967
September 2001
PREPARED BY:
U.S. Environmental Protection Agency, Region 6
Dallas, Texas
and the
Oklahoma Department of Environmental Quality
Oklahoma City, Oklahoma
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Table of Contents
List of Acronyms..................................................................... 3
Executive Summary.................................................................. 4
Five Year Review Summary Form ................................................ 5
I. Introduction................................................................... 7
II. Site Chronology............................................................... 8
III. Background.................................................................... 9
Site Characteristics...............................9
Land and Resource Use..........................9
History of Contamination........................9
Initial Response Actions.........................9
Contaminants and Media Impacted............ 10
Tinman Health and Environmental Impacts... 10
Feasibility Study.................................. 11
IV. Remedial Actions............................................................. 11
Remedial Action Objectives....................11
Remedy Selection................................ 11
ROD Amendment................................12
Remedy Implementation........................ 13
Operation and Maintenance.....................14
V. Five-Year Review Progress................................................... 15
VI. Five-Year Review Process.................................................... 15
Community Involvement......................... 15
Documents Review............................... 15
Data Review....................................... 16
Site Inspection..................................... 16
Interviews.......................................... 16
VII. Assessment...................................................................... 17
VIIL Issues...........................................................................18
IX. Recommendations and Follow-up Actions................................18
X. Protectiveness Statements................................................... 18
XI. Next Review...................................................................19
Tables
Table 1: Chronology of Site Events...................................... 7
Table 2: Feasibility Study Alternatives Summary..................... 11
Table 3: Initial PCB Results for Groundwater Monitoring, 1996 ..... 12
Table 4: Annual System Operations/O&M Costs....................... 13
Table 5: Annual PCB Results for Groundwater Monitoring........... 14
Figures
Figure 1: Site Map ...................................................... Appendix
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List of Acronyms
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 also known as Superfund: Amended in 1986 by the Superfund
Amendments and Reauthorization Act (SARA).
CFR Code of Federal Regulations
DEQ Oklahoma Department Of Environmental Quality
EPA United States Environmental Protection Agency
FS Feasibility study
FR Federal Register
IAG Interagency Agreement
NCP National Oil and Hazardous Substances Contingency Plan
NPL National Priorities List: A list of sites identified for remediation under
CERCLA.
O&M 'Operation and maintenance
OSWER Office of Solid Waste and Emergency Response
PCBs Polychlorinated biphenyls
RCRA Resource Conservation and Recovery Act
RA Remedial action
RD Remedial design
RI/FS Remedial investigation/ feasibility study
ROD Record of Decision: Documents the selection of cost-effective Superfund
Financed remedy.
SARA Superfund Amendments and Reauthorization Act of 1986. (See
CERCLA.)
SWDA Solid Waste Disposal Act
TSCA Toxic Substances Control Act
USACE United States Army Corps of Engineers
WasteLAN The Regional database related to CERCLIS
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- 3
Executive Summary
The Tenth Street Superfund Site is located in Oklahoma City, Oklahoma. The
Site was used as a municipal landfill from 1951 to 1954. The Site was then used as a
salvage yard from 1959 to 1985, accepting materials such as tires, solvents, and
transformers.
The initial Record of Decision (ROD) selected a remedial alternative to excavate
and chemically treat contaminated soils onsite. After technical problems arose during the
implementation of the remedy, an amended ROD was signed in September 1993, which
provided for the construction of a permanent cap to cover the additional consolidated
soils contaminated with PCBs. Construction activities were initiated August 28, 1995
and completed January 4, 1996. The EPA issued the Final Close Out Report for the Site
on July 3, 1997. The trigger for this five-year review was the actual start of construction
on August 28, 1995.
The assessment of this five-year review found that the remedy was constructed in
accordance with the requirements of the ROD and that the remedy is functioning as
designed.
Although no major deficiencies were found during the review, three minor
concerns were discovered and will be addressed to ensure the future protectiveness of the
remedy. These three minor concerns are: 1) updating the 0 & M plan to incorporate the
current grass mowing schedule and proposed ground water sampling frequency; 2)
placing locks on the ground water monitoring wells; and, 3) determining adequate
institutional controls to ensure that future land activities or uses do not compromise the
cap's integrity.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name (from WasteLan): Tenth Street Superfund Site
EPA ID (from WasteLan): OKD980620967
City/County: Oklahoma
NPL status: Final
Remediation Status:
Under Construction
Operating
XX Complete
Multiple OUs: NO Construction Completion Date: January 7,1997
Has Site been put into Reuse: NO
REVIEW STATUS
Lead Agency: EPAandODEQ
Author name: Stacey Bennett (EPA) and Dennis Datin (ODEQ)
Author title: Remedial Project Manager
Review period: August 2000 through September 2001
Date(s) of Site Inspection: May 9, 2000
Type of Review: Post-SARA
Review number: 1 (first)
Triggering Action: Actual RA On-Site Construction
Triggering Action Date (from WasteLAN): August 28, 1995
Due Date (five years after triggering action date): August 28, 2000
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Five-Year Review Summary Form, continued
Issues:
No major issues were identified. Three minor issues were identified.
1. The current 0 & M plan (dated 1995) requires ground water
sampling annually and mowing of the grass twice a year. The
current frequency of mowing has been altered to meet the seasonal
needs.
2. All monitoring wells are located outside of the site fence and do
not have locks.
3. There are no institutional controls to prevent future owners from
placing structures or digging into the cap.
Recommendations and Follow-up Actions:
1. It is recommended that the sampling of the wells be reduced to once
every other year instead of every year. The results of the sampling
show that no PCBs are in the ground water. Mowing of the grass will
continue twice a year, unless there is a fire danger from letting the
grass grow too tall in dry years. The 0& M plan should be revised to
incorporate these changes.
2. All monitoring wells must have locks in order to prevent unauthorized
access.
3. The EPA and DEQ will need to investigate necessary measures to
ensure that future uses of the property will not compromise the cap's
integrity.
Protectiveness Statement
The remedy that was implemented for the Tenth Street Supermnd Site is protective of
human health and the environment, and will remain so provided the minor concerns listed
above are addressed.
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I. Introduction
The U.S. Environmental Protection Agency (EPA) and the Oklahoma Department of
Environmental Quality (DEQ) have jointly conducted a five-year review of the remedial
actions implemented at the Tenth Street Dump/Junkyard Superfand Site in Oklahoma
City, Oklahoma. The review was conducted from August 2000 through September 2001.
This report documents the results of the review.
The purpose of five-year reviews is to determine whether the remedy at a site is
protective of human health and the environment. The methods, findings, and conclusions
of reviews are documented in five-year review reports. In addition, five-year review
reports identify deficiencies found during the review, if any, and recommendations to
address them.
The EPA musfimplement five-year reviews consistent with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA § 121 ©, as
amended, states:
If the President selects a remedial action that results in
any hazardous substances, pollutants, or contaminants
remaining at the site, the President shall review such
remedial action no less often than each five years after
the initiation of such remedial action to assure that human
health and the environment are being protected by the
remedial action being implemented.
The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:
If a remedial action is selected that results in hazardous
substances, pollutants, or contaminants remaining at the
site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such
action no less often that every five years after the
initiation of the selected remedial action.
This is the first five-year review for the Tenth Street Superfand site. The triggering
action for this statutory review is the date of the start of the remedial action, which was
August 28, 1995. The five-year review is required due to the fact that hazardous
substances, pollutants, or contaminants remain at the site above levels that allow for
unlimited use and unrestricted exposure.
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II. Site Chronology
Table 1: Chronology of Site Events
EVENTS
North Canadian River channelized and levees built, removing the meander loop, which
crossed through the Site. Site was operated as a municipal landfill.
No activity noted at the Site.
Site was operated as a salvage yard.
EPA inspected the Site, finding drums, which were bulging, corroded and/or leaking.
Sampling of soils and drums by EPA and posting of warning signs at the Site.
EPA Region VI Regional Administrator approves a removal action to fence and cap
the Site.
Phase I removal action conducted by Region VI Emergency Response Clean Up
Service contractor to decontaminate and relocate automobiles, spare parts, the office
building and tire repair machine shop.
Phase II removal action conducted to level, place temporary cap, and seed Site; install
fencing; and dispose of 20 drums.
Site proposed for the National Priorities List (52 FR 2492).
Site added to the National Priorities List (52 FR 27620).
Field investigation conducted for Remedial Investigation Report.
Feasibility Study Report published.
Record of Decision (ROD) issued requiring chemical treatment of the PCB-contaminated
soil.
Feasibility Study Report Addendum published.
Public Notice announcing Amended Proposed Plan.
Amended ROD (including responses to comments from public) issued requiring
capping-of contaminated soil meeting technical requirements for caps under the Toxic
Substances Control Act (TSCA) 40 CFR 761.75 (b) (1) and (2).
EPA issues Interagency Agreement No. DW96950179-01-0 to the USCOE to perform
remedial design.
EPA issues Interagency Agreement No. DW96950200-01-0 to the USCOE to perform
remedial action.
Final Remedial Design completed.
0 & M Plan
Contract DACW56-95-C-0027 for construction of the remedial action awarded to
Abatement Systems, Inc.
Notice To Proceed issued.
Remediation activities at the Site began.
Pre-final inspection conducted which determined that the remedial action contractor
has substantially completed the construction activities, except turfing, in accordance
with the Remedial Design plans and specifications.
4-Month Warranty Inspection
EPA Issued Preliminary Close-Out Report
8-month Warranty Inspection
Final Inspection
Operational and Functional Determination
Final Close-Out Report
The site was delisted from the NPL
DATES
1951 - 1954
1954-1959
1959-1985
1983
1984-1985
Aug 23, 1985
Sep 12-27, 1985
Dec 9, 1985-AprlO, 1987
January, 1987
July, 1987
April, 1989
July, 1990
Sep 27, 1990
April 1993
July 13, 1993
Sep 30, 1993
May 11, 1994
Sep 28,1994
January, 1995
May 1995
Apr26, 1995
May 31, 1995
Aug 28, 1995
Jan 4, 1996
Apr30,1996
Junll, 1996
Sep 18, 1996
January, 1997
January, 1997
July 3, 1997
November 21,2000
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III. Background
Site Characteristics
The Site is located in an industrial and residential area in northeast Oklahoma
City, Oklahoma (Section 31, Township 12 North, Range 2 West). The Site is located on
the south side of Tenth Street between Bryant Avenue and the North Canadian River and
covers approximately 3.5 acres (Figure 1). One residence is located adjacent to the west
side of the Site. Residential subdivisions are located approximately one block to the
north and approximately one block to the west of the Site.
Aerial photos show that in 1951 a meander loop of the North Canadian River cut
almost directly through the Site, making the Site subject to a 100-year flood. Between
1951 and 1954, the river was channelized and levees were constructed on both sides of
the river.
Land and Resource Use
The site is in an area of mixed residential and industrial land use, and is
surrounded on three sides by active automobile salvage yards. In the September 27, 1990
Record of Decision, EPA assigned an industrial land use to this site. The site is currently
not being used. The Oklahoma County owns the majority of the property and three
private landowners own other portions of the property. The area is not currently zoned.
Although insufficient information exists to classify the alluvial aquifer at the site,
EPA believes the appropriate classification is Class II, potential drinking water supply.
The aquifer is not contaminated with PCBs, meets primary drinking water standards, does
not exceed 10,000 ppm total dissolved solids, and probably yields more than 150 gallons
per day. No users of the alluvial aquifer have been identified; all known water supply
wells in the immediate area are probably completed in the Garber-Wellington.
History of Contamination
The Site, including the cutoff meander loop, was operated as a municipal landfill
between 1951 and 1954. No activity at the Site was noted between 1954 and 1959.
Beginning in 1959, Mr. Raymond Cobb leased the Site from Mr. Sullivan Scott and used
the Site as a salvage yard, accepting materials such as tires, solvents, and transformers.
The dielectric fluids from the transformers contained Polychlorinated Biphenyls (PCBs).
The fluids were drained from the transformers, then transferred to barrels and sold.
During the recovery process, substantial quantities of oil were spilled onto the ground.
Mr. Cobb continued this operation until his death in 1979, when Mr. Rolling Fulbright
began operating the Site as Deadeye's Salvage Yard, an automobile salvage yard.
Initial Response Actions
Sampling by the EPA in 1984 and 1985 identified PCB concentrations up to
39,000 parts per million (ppm) in the soil. After reviewing the data, EPA determined that
the contaminants posed a potential health threat.
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The Regional Administrator authorized a removal action in an Action
Memorandum dated August 23, 1985. The EPA began the removal action for the Site in
September 1985 to address direct human contact threats and the potential for offsite
migration of contaminants
The removal action was successfully completed in April 1987. The removal
action consisted of:
• Removing and disposing of the electrical equipment and drums containing
hazardous substances;
• Decontaminating and relocating of automobiles and other salvage material;
• Consolidation of contaminated soils to the center of the Site;
• Grading of the Site for effective drainage,
• Installation of a temporary synthetic liner and clay cap; and
• Erection of a security fence around the Site.
The Site was proposed for the National Priorities List (NPL) in January 1987 (52
FR 2492) and placed on the NPL in July 1987 (52 FR 27620).
Contaminants and Media Impacted
The EPA initiated a Remedial Investigation/Feasibility Study (RI/FS) in 1989.
The RI determined the types and amounts of contaminants present at the Site and
discovered the extent of contamination. The RI indicated that PCBs were the
contaminants of concern at the Site, and were limited to surface and subsurface soils at
the Site. The predominant PCB species present was Aroclor 1260.
The ground water table at the site ranged from about 1151.7 Mean Sea Level
(MSL) to about 1150.0 MSL. Contaminated soil at its deepest point onsite was
approximately 3 feet above the water table. No PCBs or other compounds were detected
in ground water samples taken during the RI. In addition, surface water samples were
collected during the RI and no contaminates attributable to the Site were detected.
Human Health and Environmental Impacts
The human health risk assessment conducted during the RI, indicated that
carcinogenic risks posed by the site were attributed to PCB contamination in the soil.
The average lifetime carcinogenic risk from direct contact with soil, based on the average
concentration of PCBs in soil was estimated to be 3.8 x 10 -5 excess cancer incident.
The environmental risks associated with contaminants at the site were reported
during the RI to be non-measurable or minimal. Surface waste samples collected showed
no organic chemicals related to the site. In addition, biota samples collected indicated
that the North Canadian River, downstream from the site, contained more individual
species than upstream.
During 1987, the U. S. Fish and Wildlife Service of the Department of the Interior
conducted a Preliminary Natural Resource Survey and granted a release from natural
resource damages.
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Feasibility Study
The Feasibility Study (FS) developed and evaluated a range of alternatives to
remediate the soil contamination. A total of 5 alternatives were considered after a
screening process. Table 2 below lists the alternatives considered.
Table 2. Feasibility Study Alternatives Summary, Tenth Street Superfund Site,
Oklahoma City, Oklahoma
Alt.
Number
1
3
4
5
6
Alternative
Description 1
No Action
Excavation and
Off-site Disposal
Excavation,
Onsite-Chemical
Treatment and
Disposal Onsite
Excavation,
Onsite Thermal
Treatment, and
Disposal Onsite
Excavation and
Offsite Thermal
Treatment
Capital Cost
$ 2,500
$ 4,037,000
$ 4,044,000
$ 4,406,000
$17,829,000
Annual
O&Mcost
$ 11,800
$0
$0
$0
$0
Present
Worth Cost
$ 184,200
$ 4,037,000
$ 4,044,000
$ 4,406,000
$ 17,829,000
Implefflsent^itm
• - 'Ilriwh1':1^'
30 years for
O&M
3 months
6-9 months
6-9 months
3 months
Note: Alternative 2 was screened out prior to the detailed evaluation of alternatives because the site was in
a flood plain and because the alternative would not satisfy the preference for treatment expressed in SARA,
(ROD, September 27, 1990).
IV. Remedial Actions
Remedial Action Objectives
Based upon the concentration and risk ofPCBs, the Site was determined to pose a
principal threat because of the potential for direct contact with the contaminated soil and
the soil's potential impact on ground water. The scope of the response action was to
address the principal threat at the Site by preventing current or future exposure to the
contaminated soil through treatment and/or containment, and reducing or controlling the
potential migration of contaminants from the soil to ground water.
Remedy Selection
A proposed plan for the Site was issued in August 1990, presenting the preferred
alternative of chemical dechlorination of the contaminated soil. The EPA Regional
Administrator for Region 6 signed a Record of Decision (ROD) on September 27, 1990.
In the ROD, EPA selected Alternative 4 - Excavation, Onsite Chemical Treatment, as the
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remedy for the Tenth Street Superfund Site. As noted in the ROD in the "Statement of
Basis and Purpose," the State of Oklahoma (State) did not support the original remedy
selected in the ROD.
The major components of the Selected Remedy included:
• Removing the existing red clay cover and the visqueen plastic liner from the
removal action,
• Excavating an estimated 7,500 cubic yards ofPCB contaminated soil with
concentrations of 25 ppm and higher,
• Chemically treating the excavated contaminated soil by a chemical dechlorination
process meeting the Toxic Substances Control Act (TSCA) PCB alternative
treatment requirements,
• Backfilling the treated soil in the excavated area, and
• Grading the site for effective drainage and establish vegetative cover.
During the Remedial Design (RD) phase of the onsite chemical treatment remedy,
the EPA became aware of problems with the implementation of this process at other
Superfund sites. Problems that were experienced included: low production rates; severe
odor problems during the treatment process and persisting in the soil after treatment;
"soupy" (wet) physical condition of the treated soil and the ensuing need for stabilization
before placement back on the ground as backfill; soil volume increases of 100% during
treatment, causing space problems for backfilling on the site; and leaching of residual
reagent from the soil following treatment.
In addition to the technical problems related to chemical dechlorination
experienced at other Superfund sites, onsite treatment of the contaminated soil was
further complicated as the result of construction debris and other types of solid waste that
had been dumped at the Tenth Street Site previous to the PCB spills. The contaminated
soil from PCBs became mixed with the solid waste and the materials handling problems
resulting from such a mixture greatly complicated the treatment remedy. Projected
construction costs were also greatly increasing. As a result, EPA re-evaluated the
remedial alternatives at the Site.
ROD Amendment
On September 30, 1993, the EPA Regional Administrator for Region 6 signed an
Amended ROD, which was concurred upon by the State. The amended remedy addressed
approximately 9,800 cubic yards of soil contaminated with PCBs at or above 25 ppm.
The objective of the amended remedy was the same as the original ROD, which was to
protect human health and the environment by preventing current or future exposure to the
contaminated soil through treatment and/or containment, and reducing or controlling the
potential migration of contaminants from the soil to ground water. The major
components of the selected remedy-as reflected in the Amended ROD included:
• Excavation and placement of contaminated soil from the roadway right-of-way on
the south side ofN.E. Tenth Street onto the existing cap;
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• Allowing the Oklahoma Department of Transportation's widening of Tenth Street
to cover contaminated soil in the roadway right-of-way on the North side ofN.E.
Tenth Street;
• Construction of a new cap meeting the technical requirements for caps under the
Toxic Substances Control Act (TSCA), 40 CFR Section 761.75 (b)(l) and (2);
and
• Maintenance of the cap and ground water monitoring.
The revised remedy of capping the waste does not satisfy the statutory preference for
treatment as a principal element of the remedy. But, the EPA, with concurrence from the
State of Oklahoma, determined that this alternative was protective of human health and
the environment, complied with Federal and State requirements that are applicable or
relevant and appropriate, was cost effective compared to equally protective alternatives
that utilized permanent solutions and alternative treatment technologies to the maximum
extent practicable. The estimated cost of this selected remedy was $648,000.
Remedy Implementation
The EPA entered into an Interagency Agreement (IAG) with the U.S. Army Corps
of Engineers (USACE-Tulsa District) to perform the remedial design and the remedial
action.
The US ACE initiated the remedial action contract on May 31, 1995, and the
actual remedial action construction activities at the Site began on August 28,1995. The
major components of the remedial action included:
* Drum sampling and disposal,
* Over-drilling and grouting of existing monitoring wells,
* Excavation and relocation ofPCB-contaminated soil from the perimeter of the
Site,
* Soil sampling of the walls and bottom of the excavated area for PCBs,
* Placement, grading and compaction of random fill to grade the Site at the required
foundation elevation,
* Installation and development of three down-gradient ground water monitoring
wells,
* Placement of 3-foot thick clay barrier layer,
* Placement ofgeomembrane, drainage net, and geotextile,
* Installation of perimeter drain system,
* Placement of cover soil and topsoil layers,
* Monitoring well sampling,
* Installation of a new fence around the Site, and
* Establishment of turf.
During the remedial action activities, 2 feet of additional excavation was needed
in an area which was determined to exceed the PCB cleanup standard after the initial
excavation sampling. This additional 275 cubic yards of excavation and the additional
testing required added an additional $17,825 to the original estimated costs.
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At the conclusion of the remedial action, approximately 4,655 cubic yards (cy3) of
soil with the concentrations ofPCBs greater than 25 ppm had been excavated from the
north and west perimeter and the south comer of the perimeter of the Site. These soils
were then spread in the area where the existing cap, along with the remainder of the
waste (from the Removal Action in 1987), was located. This area was then capped,
sprigged and fertilized. A new fence was also installed around the Site.
The remedial action contractor obtained samples from the 5 monitoring wells (3
new downgradient wells which are MW3A, MW 4A, and MW 5A and 2 existing
upgradient wells which are M-l and M-2) and had the samples analyzed for PCBs. All
analyses showed non-detectable levels of PCBs, indicating that no PCBs are leaching into
the groundwater and migrating offsite. The results of the analyses are shown in Table 3
below.
TABLE 3. INITIAL PCB RESULTS FOR GROUNDWATER MONITORING, 1996
(Hg/1)
Analyte
Arochlor 1016
Arochlor 1221
Arochlor 1232
Arochlor 1242
Arochlor 1248
Arochlor 1254
Arochlor 1260
M-l
<10.0
<10.0
<10.0
<10.0
<10.0
<20.0
<20.0
M-2
<10.0
<10.0
<10.0
<10.0
<10.0
<20.0
<20.0
MW3A
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
MW4A
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
MW5A
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
NOTE: The MCL for PCBs is 0.5 ug/1.
The remedial action was completed on January 4, 1996.
Operation and Maintenance
The initial Operations and Maintenance (0 & M) plan required that the cap be
inspected once a month or immediately following a heavy rainfall event for the first six
months and then every six months thereafter. Ground water monitoring would be
conducted once every year. An annual report was to be developed following receipt of
laboratory data from the monitoring well sampling.
In January 1997, the State of Oklahoma began inspection, maintenance, and
monitoring activities in accordance with the approved O&M Plan issued May 1995. The
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ground water monitoring wells at the Site are sampled annually. Monitoring consists of
sampling 5 monitoring wells, 2 up gradient and 3 down gradient, to verify that PCBs
from this Site are not contaminating the ground water. Additionally, the grass on the cap
was mowed three times the first year and twice the second year and third years and then
will be mowed only once a year for this year. The current mowing schedules are changes
to the original O&M plan. The cap is inspected for damage at least once a year. Repairs
from erosion or other damage will be made as necessary by the State. Table 4 below
summarizes the annual O&M costs since 1997.
Table 4: Annual System Operations/O&M Costs
Dates
From
July 1, 1997
July 1,1998
July 1, 1999
To
June 30, 1998
June 30, 1999
June 30, 2000
Total Cost rounded to nearest $1000
1800
1800
1600
V. Progress Since the Last Five-Year Review
This was the first five-year review for the Site.
VI. Five-Year Review Process
The five-year review team consisted of Dennis L. Datin of the DEQ, and Camille
Hueni, Noel Bennett, and Stacey Bennett with the EPA. The review was conducted from
August 2000 until September 2001. The tasks for the five-year review included:
1. Review of the existing sampling data up to September 1999,
2. Review of the MCL set for PCBs,
3. Interviews with a nearby business owner, former member of a citizen advisory
group, and a city council member,
4. Inspection of the site on May 9, 2000, and
5. Preparation of the five-year review report.
Community Involvement
The community was not notified that a five-year review has begun. Instead, a fact
sheet will be provided to the community stating the results of the five-year review.
Documents Review
The following documents were reviewed to complete this five-year review. These
documents included:
• Tenth Street Operation and Maintenance Plan, May 1995,
• 10th Street Dump Record of Decision, September 1990,
• Amended Record of Decision, September 1993,
• Preliminary Close-Out Report, Tenth Street Superfund Site, Feb 1997,
• Final Close-Out Report, Tenth Street Superfund Site, July 3, 1997,
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• Groundwater Assessment reports, 1996-2000,
• 10th Street Superfund Site Final Design Analysis, June 1995,
• Remedial Action Report, Tenth Street Superfund Site
Data Review
Prior to the completion of the remedial action, ground water sampling was
conducted as part of the confirmation sampling (See Table 3 in the Remedy
Implementation Section). The 0& M plan also required ground water sampling once a
year. Table 5 below summarizes the results of the annual ground water sampling. No
PCBs have been detected in the ground water through September 2000.
TABLE 5. ANNUAL PCB RESULTS FOR GROUNDWATER MONITORING, 1997-2000
(Hg/1)
ANALYTE
Total PCBs in Water
September 1997
Total PCBs in Water
September 1998
Total PCBs in Water
September 1999
Total PCBs in Water
September 2000
M-l
< 0.300
< 0.220
N 0.000
N 0.000
M-2
< 0.300
< 0.300
N 0.000
N 0.000
MW3A
< 0.300
< 0.300
N 0.000
N 0.000
MW4A
< 0.300
< 0.300
N 0.000
N 0.000
MW5A
< 0.300
< 0.300
N 0.000
N 0.000
NOTE I: N = No PCB common peaks detected and confirmed.
NOTE 2: The sampling method used is EPA Method 608.
Site Inspection
The EPA and DEQ conducted a site inspection on May 9, 2000. The visual
inspection revealed that the site cap cover is sound and that the vegetative cover is
adequate. The fence was in good condition at this time with the gates having adequate
locks on them. The monitoring wells are located outside of the fenced area. Although
the monitoring wells were in good condition, there were no locks on the wells.
Interviews
DEQ interviewed a nearby business owner, a former member of a citizen advisory
group, and a city council member. None of the interviewees expressed any concerns
regarding the remedy at the site. The city council member stated that the frequency of
grass mowing should be carefully monitored.
VII. Assessment
An overall assessment of the remedy implemented at the Site was conducted in
order to confirm that the selected remedy is operating according to the ROD expectations.
The assessment was primarily used to answer the following questions:
• Is the remedy functioning as intended by the decision documents?
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• Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?
• Has any other information come to light that could call into question the
protectiveness of the remedy?
Question A: Is the remedy functioning as intended by the decision documents?
All activities at the Site were consistent with the ROD, as amended, and with the RD and
RA statements of work issued to the USCOE for design and construction of the remedy.
All contaminated soil with more than 25 ppm PCBs was placed under a clay barrier layer
with a geo-membrane liner. Infiltration of precipitation is retarded because of this liner,
thereby reducing the possibility of leaching of the contaminants into the ground water.
The inspection and maintenance of the cap according with the 0 & M plan insures that
cap's integrity remains in place.
Annual sampling of the ground water has revealed that no PCBs are present, which
supports the successfulness of the remedy.
The health and safety plan for the site is adequate. Access control to the site is adequate
with the chain link fence in good condition and there are locks on the gate.
The operation and maintenance of the site is easily accomplished with mowing to control
the grass, which usually takes place in September of each year. The cost of mowing the
site is about $650 per year. The ground water sampling usually occurs in September of
each year. One issue that was discovered is that the monitoring wells do not have locks to
prevent unauthorized access. All of the monitoring wells are located outside of the Site
fence.
Since the site has been closed, there have been no changes in the effectiveness of the
remedy and the remedy is functioning adequately. There have been no changes in land
use of the surrounding areas since the remedy began.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and
remedial action objectives (RAOs) used at the time of the remedy selection still
valid?
The baseline risk assessment conducted during the 1990 RI/FS and a second risk
assessment conducted in March 1993 for the amended ROD was based on an exposure
scenario for an industrial worker.
Current and future land uses are expected to remain industrial onsite and
residential offsite. Although no formal land use plan was obtained from the City of
Oklahoma Planning Department, land use patterns in the immediate vicinity of the site
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are consistent with these designations, and consequently are consistent with the
assumptions in the ROD.
The MCL for PCBs in the groundwater is 0.5 ug/1. The remedial action complies with all
applicable and relevant and appropriate requirements (ARARs). These include the EPA
and DEQ rules and regulations.
Because the cap is functional and no PCBs were found in the ground water, no
risk recalculation/assessment was necessary for this site.
Question C: Has any other information come into light that could call into question
the protectiveness of the remedy?
There is no additional information which calls into question the protectiveness of
the remedy. Although the site is in the 100-year flood plain, the USACE has confirmed
that current controls, such as the levees, are still protective. This demonstrates that the
cap will not be impacted from a 100-year flood.
VIII. Issues
An inspection of the site revealed no deficiencies in the remedy. At the current
time there are no institutional controls for the site if the property is sold. This is a minor
deficiency that will need to be monitored. Additionally, locks need to be maintained on
the monitoring wells to prevent unauthorized access.
IX. Recommendations and Follow-up Actions
The current 0 & M plan requires ground water sampling annually and mowing of
the grass twice a year. It is recommended that the sampling of the wells be reduced to
once every other year instead of every year. The results of the sampling show that no
PCBs are in the ground water. Mowing of the grass will continue twice a year, unless
there is a fire danger from letting the grass grow too tall in dry years.
There are no institutional controls to prevent future owners from placing
structures or digging into the cap. The EPA and DEQ will need to investigate necessary
measures to ensure that the cap's integrity is not compromised. In addition, locks need to
be placed on all monitoring wells to prevent unauthorized access.
The five-year reviews will continue as required.
X. Protectiveness Statements
Four years after completion of the remedial action, the remedy at the Tenth Street
Superfund Site in Oklahoma City, Oklahoma, is protective of human health and the
environment.
All contaminated soil with more than 25 ppm PCBs was placed under a clay
barrier layer with a gee-membrane liner. This liner, reducing possible leaching of the
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contaminants into the ground water, retards infiltration of precipitation. Protection of the
ground water has been verified by the yearly ground water sampling of the five
monitoring wells, in which this sampling has revealed that there are no detectable levels
ofPCBs in the ground water.
XI. Next Review
The next five-year review will be due in September 2006, which is 5 years from
the date of this report.
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BIBLIOGRAPHY
U. S. Environmental Protection Agency, Tenth Street Superfund Site Remedial
Investigation Report, 2 Volumes, EPA Region 6, Undated.
U. S. Environmental Protection Agency, Tenth Street Superfund Site Feasibility Study
Report, EPA Region 6, July 1990.
U. S. Environmental Protection Agency, Tenth Street Superfund Site Feasibility Study
Report Addendum, EPA Region 6, April 1993.
U. S. Environmental Protection Agency, Tenth Street Dump, Record of Decision, EPA
Region 6, September 1990.
U. S. Environmental Protection Agency, Tenth Street Site, Amended Record of Decision,
EPA Region 6, September 1993.
U.S. Army Corps of Engineers, Tulsa District, 10th Street Superfund Site Final Design
Analysis, June 1995.
U.S. Army Corps of Engineers, Tulsa District, 10th Street Superfund Site Construction
Specifications and Plans, January 1995.
U.S. Army Corps of Engineers, Tulsa District, Tenth Street Superfund Site Preliminary
Close Out Report -Draft, February 1996.
U.S. Army Corps of Engineers, Southwestern Division Laboratory, Results of Chemical
Analyses of Soil Samples 10th Street (sic) Superfund Site, SWDED-GL Report No.
16402, October, 1995.
U.S. Army Corps of Engineers, Southwestern Division Laboratory, Results of Borrow
Material for Clay Cap Tenth Street, OK, SWDED-GL Report No. 16402-1, January,
1995.
U. S. Environmental Protection Agency, Close Out Procedures for National Priority List
Sites - Interim Final, (U. S. EPA Office of Solid Waste and Emergency Response
Directive 9320.2-09), August 1995.
U. S. Environmental Protection Agency, Structure and Components ofFive-Year
Reviews, (U. S. EPA Office of Solid Waste and Emergency Response Directive 9355.7-
02), May 1991
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APPENDIX
VICINITY MAP
10th STREET SUPERFUND SITE
OKLAHOMA CITY,OKLAHOMA
Figure 1
2