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FOURTH FIVE-YEAR REVIEW REPORT FOR
HARDAGE-CRINER SUPERFUND SITE
MCCLAIN COUNTY, OKLAHOMA
MAY 4, 2017
Prepared by
Oklahoma Department of Environmental Quality
Oklahoma City, Oklahoma
Prepared for
U.S. Environmental Protection Agency
Region 6
Dallas, Texas
FOURTH FIVE-YEAR REVIEW REPORT HARDAGE-CRINER SUPERFUND SITE
EPA ID#: OKD0004000093 MCCLAIN COUNTY, OKLAHOMA
This memorandum documents the U.S. Environmental Protection Agency's performance, determinations, and approval of the Hardage-Criner Superfund Site (Site) Fourth Five Year Review, under Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S . Code Section 9621(c), as provided in the attached Fourth Five-Year Review Report.
Summary of the Fourth Five-Year Review Report This is. the Fourth Five-Year Review of the Hardage-Criner Superfund Site. The Hardage Site Remediation Corporation has continued the Operation and Maintenance in accordance with the 2016 Revised Performance Monitoring Plan, as required by the Court Order. Performance Monitoring Plan (PMP) components include monitoring the ground water quality and surface water quality on and near the site, monitor and operate the passive aeriation system (PAS), monitor the performance of the V-Trench, monitor the integrity of the cap, monitor liquid levels in the Barrel Mound and Main Pit wells, document the quantity of liquids extracted by the Permanent Mounds Liquid Recovery System (PLRS), maintain the institutional control boundary (ICB), prepare and submit quarterly and annual remediation status reports, and provide support to EPA' s Five-Year Review Process.
The site is not ready for reuse and is only used for remediation purposes. Currently, there are no reuse plans associated with the site proper, although an area south of the site boundary has been approved for the grazing of cattle, hay baling, and row crops. All issues and recommendations from the Third Five-Year Review have been addressed. This review found that there are neither issues nor recommendations for the site. The next Five-Year Review of the site will be required five years from the completion of this Five-Year Review.
Environmental Indicators Human Exposure Status: Under Control Contaminated Groundwater Status: Under Control Site-Wide Ready for Reuse: No
Actions Needed The following actions must be taken for the remedy to be protective in the long term: None.
Determination I have determined that the remedy for the Hardage-Criner Superfund Site is protective of human health and the environment.
s/ ~ /17 Date
Director, Superfund Division U.S. Environmental Protection Agency Region 6
2
Blake Atkins
CONCURRENCES
FOURTH FIVE-YEAR REVIEW REPORT HARDAGE-CRINER SUPERFUND SITE
EPA ID#: OKD0004000093 MCCLAIN COUNTY, OKLAHOMA
3-/£-/7 Date
Date Chief, Louisiana/New Mexico/Oklahoma Section
Date
/J~~ Ma ih Bento~ Zey, Offic:o;Regional Counsel
Date ranch, Office of Regional Counsel
l Pamela Phillips Date Deputy Director, Superfund Division
3
4
ISSUES/RECOMMENDATIONS
FOURTH FIVE-YEAR REVIEW REPORT
HARDAGE-CRINER SUPERFUND SITE
EPA ID#: OKD0004000093
MCCLAIN COUNTY, OKLAHOMA
Issues/Recommendations
OU(s) with Issues/Recommendations Identified in the Five-Year Review:
Sitewide: No issues were noted during this Five-Year Review.
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Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ......................................................................................... 6
I. INTRODUCTION ................................................................................................................................... 7 FIVE-YEAR REVIEW SUMMARY FORM ......................................................................................... 8
II. RESPONSE ACTION SUMMARY ...................................................................................................... 8 Basis for Taking Action .......................................................................................................................... 8 Response Actions .................................................................................................................................... 9
Status of Implementation ...................................................................................................................... 10 IC Summary Table ................................................................................................................................ 10 Systems Operations/Operation & Maintenance .................................................................................... 11
III. PROGRESS SINCE THE LAST REVIEW ....................................................................................... 12 IV. FIVE-YEAR REVIEW PROCESS .................................................................................................... 15
Community Notification, Involvement & Site Interviews .................................................................... 15 Data Review .......................................................................................................................................... 15
Permanent Mounds Liquids Recovery System (PLRS) .................................................................... 15 V-Trench Recovery System: ............................................................................................................. 16 Southwest Wells Recovery System (SWWRS): ............................................................................... 16 Passive Aeriation System (PAS):...................................................................................................... 17
Injection Well/Infiltration Gallery: ................................................................................................... 17 North Criner Creek Alluvium: .......................................................................................................... 17
North Criner Creek Surface Water: .................................................................................................. 18 Northwest Borrow Area…………………………………………………………………………….18
Air Monitoring: ................................................................................................................................. 19
Site Inspection ....................................................................................................................................... 19 V. TECHNICAL ASSESSMENT ............................................................................................................ 19
QUESTION A: Is the remedy functioning as intended by the decision documents? .......................... 19 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? .............................................. 19 QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? ............................................................................................................... 20
VI. ISSUES/RECOMMENDATIONS ..................................................................................................... 20 VII. PROTECTIVNESS STATEMENT .................................................................................................. 20
VIII. NEXT REVIEW .............................................................................................................................. 20 APPENDIX A – REFERENCE LIST....................................................................................................... 21 APPENDIX B – SITE BACKGROUND ................................................................................................. 22
APPENDIX C – SITE CHRONOLOGY .................................................................................................. 26 APPENDIX D – SITE MAPS................................................................................................................... 31 APPENDIX E – SITE INSPECTION CHECKLIST................................................................................ 33 APPENDIX F – SITE INTERVIEWS ...................................................................................................... 43
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LIST OF ABBREVIATIONS & ACRONYMS
AGV Active Gas Vent
ARAR Applicable or Relevant and Appropriate Requirement
CFR Code of Federal Regulations
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
Court U.S. District Court for the Western District of Oklahoma
Court Order U.S. v. Royal N. Hardage, et al, C.A. No. 86-1401-P (W.D.Okla.)
DOJ U.S. Department of Justice
EPA Environmental Protection Agency
FWA Flow-weighted Average
Gpm Gallons per minute
HSC Hardage Steering Committee
HSRC Hardage Site Remedy Corporation
ICB Institutional Control Boundary
NAPL Non-aqueous Phase Liquids
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NES National Environmental Services, Inc
NPL National Priorities List
NWBA Northwest Borrow Area
O&M Operations and Maintenance
OSDH Oklahoma State Department of Health
OSHA Occupational Safety and Health Administration
OU Operable Unit
PAS Passive Aeration System
PCOR Preliminary Close Out Report
PDB Passive Diffusion Bags
PLRS Permanent Mounds Liquid Recovery System
PMP Performance Monitoring Plan
ppb Parts Per Billion
PRP Potentially Responsible Party
PTP Phytoremediation Test Plot
RA Remedial Action
RCRA Resource Conservation and Recovery Act
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
Site Hardage-Criner Superfund Site
SWWRS Southwest Wells Recovery System
SVOC Semi-volatile Organic Compound
TOU Thermal Oxidation Unit
ug/l Micrograms Per Liter
U.S.C. United States Code
USGS U.S. Geological Survey
VOC Volatile Organic Compounds
V-Trench V-Trench Recovery System
WTP Water Treatment Plant
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy, in order to determine if the remedy is and will continue to be protective of human health and the
environment. The methods, findings, and conclusions of reviews are documented in five-year review
reports such as this one. In addition, FYR reports identify issues found during the review, if any, and
document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this five-year review pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,
consistent with the National Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)), and
considering EPA policy.
This is the fourth FYR for the Hardage Criner Superfund Site. The triggering action for this statutory
review is the signing of the third FYR on May 10, 2012. The FYR has been prepared, due to the fact that
hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited
use and unrestricted exposure (UU/UE).
The Hardage-Criner Superfund Site Five-Year Review was led by the Oklahoma Department of
Environmental Quality (DEQ). Participants included Chanh Le of the DEQ, Mike Hebert of EPA-
Region 6, and Brian LaFlamme of Nationwide Environmental Services, Inc. Documents reviewed as
part of this Five-Year Review is listed in Appendix A. The review began on July 11, 2016.
Site Background
The Hardage-Criner Superfund Site was an industrial hazardous waste land disposal facility and covers
approximately 160 acres. The site is located on old State Highway 122 near Criner, Oklahoma. The site
is bordered by open farmland with the North Criner Creek, located to the southwest of the site.
The site was active from 1972 to 1980 and accepted approximately 21 million gallons of waste,
including acids, caustics, lead, cyanide, arsenic, aromatic solvents, chlorinated solvents, pesticides,
polychlorinated biphenyls, oil recycling waste, and other hazardous substances. Initially, liquid and
sludge waste from drums or tank trucks was discharged into unlined pits. As the disposal pits filled,
drums were piled into a sludge mound. Eventually, the site contained waste impoundments, including a
large unlined main pit, a series of smaller pits, a sludge mound, and a barrel mound. Although the site
was initially permitted by the Oklahoma State Department of Health, its permit was later revoked when
the facility failed to meet newly imposed standards of the Resource Conservation and Recovery Act, 42
United States Code Section 6924.
Historical land use surrounding the Site is primarily rural agricultural. The institutional control
boundary (ICB) restricts the Site and some adjoining property surrounding the Site (USDC WD 1991,
USDC WD 2008a). In 2010, the EPA approved and the Court granted partial release and modification
of the restrictive covenants previously imposed upon the ICB. The following activities on designated
tracts shall be permitted, including the erection and maintenance of a fence separating tract 3 from tract
7, and tracts 2, 3 and 6 may be used for animal grazing, animal husbandry and seeding, sowing and
haying of grasses only for feeding grazing animals, provided that any tilling or plowing of soil shall not
exceed six inches in depth (EPA, 2010, USDC WD 2010).
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Additional information concerning the site background can be found in the Hardage-Criner Superfund
section of DEQ’s website as well as in Appendix B of this review.
FIVE-YEAR REVIEW SUMMARY FORM
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
During site operations, approximately 21 million gallons of industrial wastes including acidic, caustic
and corrosive wastes, many classified as carcinogenic, were disposed on the Site. The principal source
of contamination is estimated to be 278,000 cubic yards of sludges, waste drums, highly contaminated
soils, and waste liquids contained in three waste disposal areas near the center of the property.
Hazardous substances detected in the source area include: 1,2-dichloroethane, 1,1,2-trichloroethane, 1,1-
dichloroethene, tetrachloroethene, trichloroethene, lead, chromium, polychlorinated biphenyls, and
toxaphane.
Hazardous substances from the source area have contaminated the ground water present in Strata I, II,
and III. Ground water flows east toward the east farm ponds, and west-southwest toward the North
SITE IDENTIFICATION
Site Name: Hardage-Criner
EPA ID: OKD000400093
Region: 6 State: OK City/County: Criner/McClain
SITE STATUS
NPL Status: Final
Multiple OUs? No
Has the site achieved construction completion?
Yes
REVIEW STATUS
Lead agency: State
Author name (Federal or State Project Manager): Chanh Le
Author affiliation: Oklahoma Department of Environmental Quality
Review period: 7/11/2016 - 10/31/2016
Date of site inspection: 10/3/2016
Type of review: Statutory
Review number: 4
Triggering action date: 5/10/2012
Due date (five years after triggering action date): 5/10/2017
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Criner Creek alluvium. Strata IV and V consist of low permeability mudstones and silty mudstones that
separates the shallow ground water from saline water in Stratum VI.
Response Actions
In 1978, the State of Oklahoma filed complaints against the facility for suspected lead contamination of
the air around the Site. In 1979, the OSDH began proceedings to revoke the facility’s permit for
utilizing unpermitted pits, failure to seal permeable lenses beneath the pits, improper closure of pits,
failure to retain runoff, and improper storage of wastes at the Site. Subsequently, preliminary EPA
investigations and inspections indicated poor waste management practices that posed a potential threat
to public health and the environment. In September 1980, the U.S. Department of Justice (DOJ) filed
suit in United States v. Hardage against Mr. Royal Hardage on behalf of the EPA. The suit alleged
violations of Section 7003 of RCRA, 42 U.S.C. Section 6973 and sought injunctive relief for Site
cleanup and closure. The Site was closed in November 1980 and Royal Hardage filed bankruptcy in
1983. In 1984, potentially responsible parties (PRPs) were notified of potential EPA CERCLA liability
and the DOJ began legal action seeking to recover costs and impose an EPA CERCLA remedy. After a
trial, the EPA CERCLA remedy was determined de novo and the Judge ordered implementation of the
Hardage Steering Committee (HSC) remedy, thereby rejecting the 1989 EPA CERCLA remedy as
“arbitrary and capricious”. Therefore, the Site is under the jurisdiction of the U.S. District Court for the
Western District of Oklahoma (Court) and operates under a Court Ordered remedy, not an EPA
CERCLA Record of Decision (ROD).
The Court Order specified remedial objectives for the Site without specifying cleanup goals for
individual media. The objectives described in the 1990 Judgement and Order (USDC WD 1990)
included:
Control of the surface water pathway;
Preclusion of site access and direct contact with waste;
Control of air emissions from source areas;
Preclusion of the use of affected ground water; and
Provision for a contingent response to ensure continued maintenance of the quality of North
Criner Creek.
The remedy components described in the 1990 Judgement and Order form the basis of a waste
containment remedy at the site. Remedy components consisted of:
V-shaped, gravel-filled interceptor trench constructed at the base of Stratum III and top of
Stratum IV to provide hydraulic control of the source areas by capture and removal of affected
groundwater and non-aqueous phase liquids for subsequent treatment.
Composite Cap (CAP) over source areas to prevent direct contact with wastes, to control surface
water flow in source areas, to limit erosion of affected soils, to reduce infiltration of
precipitation, and to provide passive gas collection and treatment.
Permanent vertical liquid recovery wells in the Barrel Mound and the Main Pit to extract
pumpable liquids for off-site treatment by incineration and disposal in order to protect the
stability of the Barrel Mound and Main Pit and to reduce the volume of free liquids.
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Southwest Interceptor wells to prevent migration of affected ground water in the North Criner
Creek alluvium.
Water treatment system to treat ground water collected from the trench and wells to standards
applicable for discharge into North Criner Creek.
Natural attenuation and, if necessary, control of migration of constituents presently found in the
alluvial ground water to effect cleanup of alluvial ground water, and to prevent significant
expansion of the area of affected ground water.
Institutional controls to limit public access to affected areas, to prohibit future withdrawal of
affected ground water, and to continue the public water supply to area residents.
A ground water and surface water monitoring system to monitor groundwater and surface water
for continued effectiveness of the remedy.
Status of Implementation
The HSRC completed construction of the Court-Ordered Remedy in 1995.
In 2010, the EPA approved and the Court granted partial release and modification of the restrictive
covenants previously imposed upon the ICB. The following activities on designated tracts shall be
permitted, including the erection and maintenance of a fence separating tract 3 from tract 7, and tracts 2,
3 and 6 may be used for animal grazing, animal husbandry and seeding, sowing and haying of grasses
only for feeding grazing animals, provided that any tilling or plowing of soil shall not exceed six inches
in depth (EPA, 2010, USDC WD 2010).
IC Summary Table
Table 1: Summary of Planned and/or Implemented ICs Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instrument
Implemented and Date
(or planned)
Groundwater Yes Yes Sitewide
Restrict future
withdrawal of
groundwater not
relating to the
Remedy.
Supplemental
Judgement and Order –
Hardage Site (May
1991)
Sitewide fencing,
warning signs,
other forms of
security.
Yes Yes Sitewide Restrict access to
site.
Supplemental
Judgement and Order –
Hardage Site (May
1991)
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Systems Operations/Operation & Maintenance
In order to evaluate the effectiveness of the remedy and compliance with discharge limits, a
Performance Monitoring Plan (PMP) describes the monitoring and evaluation measures for operations
conducted on the site. The original PMP was in effect in 1996 then revised in 1998, 2005, 2008, and
2011. The most recent revision is the 2016 revision that supersedes all previous versions of the PMP.
The 2016 Revised PMP details the procedures and reporting required to:
Monitor liquid levels in the Barrel Mound and Main Pit wells and document quantities of liquid
extracted by the PLRS;
Monitor performance and verify hydraulic capture of the V-Trench Recovery System (V-
Trench);
Monitor water quality conditions of the SWWRS while on standby;
Monitor performance and verify hydraulic capture of the SWWRS if the HSRC is required to
begin pumping and treating ground water from the SWWRS;
Monitor operation and performance of the PAS and water quality of the effluent;
Monitor water levels and the natural attenuation of volatile organic compounds (VOCs) in North
Criner Creek (NCC) alluvial monitoring wells;
Monitor the surface water quality in NCC;
Monitor water quality in Northwest Borrow Area (NWBA) Seep-14;
Monitor water quality of the NWBA surface water County Road sampling location;
Monitor the integrity and performance of the Resource Conservation and Recovery Act
Composite Cap (RCRA Cap);
Monitor the Hardage Site Security Fence (Security Fence) to ensure it continues to meet the
design specifications;
Monitor the Institutional Control Boundary (ICB) fence to ensure it continues to meet the design
specifications;
Prepare and submit the quarterly and annual Remediation Status Reports (RSRs); and
Provide support to EPA’s 5-Year Review process by performing the cap subsidence survey, the
down-hole video logging of the SWWRS and V-Trench wells, and any additional work requested
by EPA.
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III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last five-year review, as
well as the recommendations from the last five-year review and the current status of those
recommendations.
Table 2: Protectiveness Determinations/Statements from the 2012 FYR
OU # Protectiveness
Determination Protectiveness Statement
Sitewide Protective All immediate threats at the Site have been
addressed, and the Court selected remedy
components are expected to remain protective of
human health and the environment. The Court Order
specified remedial objectives for the site, without
specifying cleanup goals for individual media. The
remedy components form the basis of a waste
containment remedy at the Site and must be
monitored in perpetuity. The V-Trench must be
maintained and operated indefinitely, but the HSRC
has received permission from the Court to cease
pumping the SWWRS and place it in a “stand-by
mode” (USDC WD 2005). The institutional controls
ordered by the Court dedicate the Site solely to the
remedial activities ordered by the Court and restrict
access and use of the Site and certain adjoining
properties.
Table 3: Status of Recommendations from the 2012 FYR
Component Issue Recommendations Current
Status
Completion
Date (if
applicable)
Northwest
Borrow
Area
Phytoremediation
test plot (PTP)
does not appear to
be functioning as
intended.
Re-evaluate the PTP
remedy to determine if it is
functioning as intended.
Take the appropriate steps
to ensure a proper
functioning or develop an
alternative that would meet
the objectives of the PTP.
Considered
But Not
Implemented
12/2/2013
Composite
Cap
Small holes and
burrows persist on
surficial layer of
cap.
Continue monitoring of cap
with expedited actions if
liner material is found.
Completed 12/2/2013
Security
Fence
Depressions and
burrows present
underneath
security fence.
Continued monitoring and
to take appropriate actions
to prevent access from
humans or large animals.
Completed 12/2/2013
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Passive
Aeration
System
(PAS)
Detection of
112TCA in PAS
Effluent and
retention pond.
Control switches
on PAS are
exposed to the
elements.
Aggressive monitoring of
PAS effluent and retention
pond. Regular monitoring
and replacement of
switches as needed.
Completed 12/2/2013
Southwest
Wells
Recovery
System
(SWWRS)
Roots present in
SWWRS-6
preventing pump
removal.
Continue to work toward
efficient and effective
removal of roots.
Considered
But Not
Implemented
12/2/2013
Performance
Monitoring
Plan (PMP)
2008 PMP should
be updated to
include changes in
ICB, FWA
calculation,
permanent
implementation of
PAS.
Revise PMP to include
changes in the ICB, FWA
calculation, permanent
implementation of PAS.
Completed December
2011
Active Gas
Venting
Carbon Canisters
appeared rusty and
in need of
replacement.
Replace rusted and old
carbon canisters.
Considered
But Not
Implemented
12/2/2013
Toxicity
Criteria
Updates to RfD of
12 DCE and TCE
and updated
cancer oral slope
factors and
inhalation risk.
Make appropriate changes
to the PAS risk assessment
if recent changes
significantly affect risk.
Completed 12/2/2013
Recommendation 1
The Phytoremediation Test Plot (PTP) was a test to see if root growth from planted trees into Stratum I
would remove shallow ground water through root uptake and evapotranspiration. If successful, it would
affect the ephemeral flow of several small ground water seeps that appeared as a result of removing the
overburden soil in the Northwest Borrow Area, during the construction of the 14-acre RCRA Cap over
the mound source areas. In the previous 5 Year Review, it was determined that the remedy was not
functioning as intended, as only a fraction of the originally planted trees survived and the ones that did
were young, skinny, and appeared unhealthy.
In a response letter dated October 15, 2012, the HSRC believes that the recommendation in the 5 Year
Review to “take appropriate steps to ensure a properly functioning PTP” or “develop an alternative that
would meet the objectives of the PTP” are unnecessary, as the PTP was just a “test” and not a part of the
court-ordered remedy. Since the PTP has been problematic, the EPA agreed that it is practical not to try
to ensure the PTP properly functions or develop another alternative. However, since contaminants
found in the Northwest Borrow Area are directly attributable to the site and the PTP will not be
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maintained, sufficient sampling should be performed to ensure that contaminants are not migrating off-
site.
After correspondence between the HSRC and the EPA, the following actions will now occur in the
Northwest Borrow Area:
Semi-annual sampling at the Seep-14 and County Road locations;
Samples to be collected as soon as practical (e.g. within one business day) of significant
precipitation event (e.g. likely to produce seep flow);
Whenever possible, the semi-annual sampling would occur during March-April in the first half
of the calendar year and September-October in the second half of the calendar year;
During each semi-annual period, when sufficient water is present for sampling at Seep-14
location, one sample will be collected. When there is sufficient water present for sampling at the
County Road location, a sample will be collected contemporaneously with the Seep-14 sample;
During each semi-annual period, if contemporaneous samples from Seep-14 and County Road
have not been collected with the first Seep14 sample, the HSRC will continue to monitor the
County Road after precipitation events. If following a subsequent precipitation event, there is
sufficient water present for sampling at the County Road location, a sample will be collected at
the County Road location and the Seep-14 location.
All data collected will be reported in the next Remedial Status Report (RSR). If there are no data,
the HSRC will provide the reason(s) for no data in the next RSR.
The HSRC will collect the sample associated with the NWBA at the frequency proposed above,
at least through the scheduled September-October 2016 sample. After this sample, the HSRC, as
part of the next Five Year Review, which is due for completion by May 10, 2017, can submit a
request to change the sampling frequency for the NWBA. This request should include all the
sampling data from 2013 through 2016, as well as any other previous historical data for the
NWBA.
Recommendation 5
The FWA calculation for the SWWRS remains consistently well below the Court-mandated action
levels of 100 ppb and 150 ppb; therefore, there is no pressing reason to remove the roots from SWWR-
06. Attempts have been made, but resulted in the pump being irretrievably stuck. If reactivation of the
SWWR becomes necessary, the HSRC will ensure proper operation in accordance with the 1990 Court
Order and subsequent modifications, up to and including, over drilling and reinstalling SWWR-06.
Recommendation 7
The canisters are exposed to the elements and will tend to exhibit external weathering characteristics
such as rusting. However, inspections indicate the physical integrity of these “rusty” canisters has not
been compromised and there are not indications that vapors are being released to the atmosphere. As per
the Performance Monitoring Plan (PMP), the canisters are routinely observed and replacement is based
on the condition and/or analytical results of air samples from the effluent of the canisters.
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Recommendation 8
EPA acknowledges that Hardage has evaluated updates to the reference doses and cancer oral slope
factors for various hazardous substances used in the PAS Risk Assessment and that these changes do not
significantly alter the overall risk.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
A public notice was made available by newspaper in the Purcell Register, on August 18, 2016, stating
that there was a five-year review and inviting the public to submit any comments to the DEQ or U.S.
EPA. The results of the review and the report will be made available at the Site information repository,
located at the Oklahoma Department of Environmental Quality (707 N. Robinson, OKC, OK 73101), the
Environmental Protection Agency Region 6 (1445 Ross Ave, Dallas, TX 75202), and the Purcell Library
(919 N. 9th Ave, Purcell, OK 73080).
During the FYR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. The results of these interviews are summarized
below.
Brian LaFlamme (HSRC), Mike Hebert (EPA), Hal Cantwell (DEQ), and Dick Vinson (Local Citizen)
were contacted for interviews concerning the site. The overall impression of the site is that O&M of the
site has been performed routinely with no significant problems over the last five years. There have been
no complaints, violations, or incidents relating to the site other than HSRC no longer allows Mr. Vinson
to raise cattle on the Institutional Control property. The remedy continues to function as expected.
Several changes have occurred in the O&M, in order to optimize the O&M of the site. Changes made in
the last 5 years do not negatively affect the protectiveness of the remedy.
Data Review
In order to evaluate the effectiveness of the remedy, monitoring data is required and reported.
Permanent Mounds Liquids Recovery System (PLRS):
The approximate weight of liquids recovered from the PLRS recovery wells shall be documented during
the load-out events.
Table 4: Annual Production Totals
Year PLRS/MLRS (kilograms)
2012 6,800
2013 3,400
2014 4,200
2015 2,400
2016 2,930
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V-Trench Recovery System:
Performance of the V-Trench Recovery System is based on the requirement that water level within the
V-Trench must be a minimum of 1-foot lower than the simultaneous water level of the respective down
gradient piezometer. From 2012-2016 this criteria has been met annually.
Monitoring data is collected of the ground water retrieval:
Table 5: Annual Ground Water Retrieval
Year Ground Water (gallons)
2012 2,673,500
2013 2,467,200
2014 2,371,800
2015 2,914,500
2016 4,401,300
Annual affected ground water pumped via the V-Trench Recovery System decreased every year except
in 2015. This exception correlates with the higher than average precipitation the state of Oklahoma
experienced in 2015. Ground water recovered is received by the Passive Aeration System where
monitored natural attenuation is the chosen remedy method.
Water quality samples of the V-Trench influent into the PAS are also collected:
Table 6: V-Trench Effluent Analytical Results
Year Average Total VOC (µg/l)
2012 808
2013 900
2014 747
2015 636
2016 778
Water quality samples are to monitor the VOC concentrations being inputted into the PAS.
Southwest Wells Recovery System (SWWRS):
The SWWRS were not active in the years of interest of this 5-Year Review. The annual flow-weighted
average (FWA) of VOCs for the SWWRS are collected and if the action levels of 100-ppb or 150-ppb
are reached then the frequency of the ground water monitoring will change or the SWWRS will be
reactivated. The table below shows the annual FWA of the SWWRS.
Table 7: Total Annual FWA of Total VOC Concentration
Year FWA (ppb)
2012 25.1
2013 35.3
2014 26.3
2015 15.0
2016 19.1
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Passive Aeriation System (PAS):
The PAS basin is routinely sampled for VOCs, SVOCs, Pesticides/PCBs, metals and inorganics. Since
the PAS has been active, no VOCs, SVOCs, nor Pesticides/PCBs were detected for the years of interest
for this 5-Year Review. Metal and inorganic constituents found in the samples were found to be within
historical concentrations. Further, the concentrations were less than Oklahoma’s water quality standards
to which the PAS effluent is compared.
Injection Well/Infiltration Gallery:
This component was in temporary abandonment during the years of interest for this 5-Year Review. A
mechanical integrity test (MIT) continues to be performed every five years.
North Criner Creek Alluvium:
Monitoring wells for the North Criner Creek Alluvium are divided into three groups, with Group I being
the most up gradient and Group III being the most downgradient. The groups are monitored to prove that
monitored natural attenuation is occurring downgradient.
Group I Wells: MW-12S, MW-12M, MW-13S, MW-13M, MW-28, MW-29S, MW-29M, MW-30, AW-
S03, AW-A01
Ground water from these well locations flow toward North Criner Creek and is part of the monitored
natural attenuation remedy components. Monitoring for this group of wells include the sampling of
upgradient background well (MW-30) and sampling of MW-29S and MW-29M if MW-30 is confirmed
to have VOCs. For the years of interest for this 5-Year Review, VOCs were non-detect.
Group II Wells: MW-31, MW-32, MW-33, MW-34S, MW-34M
Historically these wells report no detections of VOCs, but in 2014 MW-34S was confirmed to have
detections of VOCs. In 2015 no VOCs were detected in the annual sampling of Group II Wells.
Table 8: Total VOC Detection in Group II Wells
Year Total VOC (µg/l)
2014 8.7
2015 nd
2016 nd
Confirmed detections of VOCs in Group II Wells trigger the requirement to sample Group III wells the
following year.
Group III Wells: MW-35, MW-36, MW-37, MW-38, MW-39
Group III Wells are sampled every five years, with the previous 5 year sampling event occurring in 2012
and the next scheduled sampling to occur in 2017. Due to detections of VOCs in a Group II Well in
2014, the Group III Wells were sampled in 2015. Group III Wells were reported as non-detects for
VOCs in the 2012 and 2015 sampling events. Since the Group II Wells reported non-detect in 2015, the
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Group III Wells will resume a five year sampling interval, with the next scheduled sampling event in
2020.
Table 9: Total VOCs in Group III Wells
Year Total VOC (µg/l)
2012 nd
2015 nd
North Criner Creek Surface Water:
Sampling locations for this monitoring include NCC-1, NCC-2, NCC-3, and NCC-4. All locations are
sampled annually, as long as sufficient flow is possible and is less than one cubic feet per second. NCC-
2 and NCC-4 are also sampled quarterly, as possible. No detections of VOCs were reported during the
years of interest for this 5-Year Review.
Northwest Borrow Area:
Surface runoff across the Northwest Borrow Area, including seeps within the area, is carried to a
singular discharge point that travels to the County Road sampling location and onward to North Criner
Creek. There is no action level associated with this location, and sampling occurs to ensure that
contaminants are not migrating off-site.
Per the 2016 Revised PMP, monitoring of the Northwest Borrow Area consists of semi-annual water
quality sampling of Seep-14 and the County Road location, if sufficient water is present.
Seep-14:
The table on the following page summarizes total VOC concentrations of Seep-14. Sampling occurred if
sufficient water was available.
Table 10: Total VOCs Concentration (µg/l) of Seep-14
Year 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter
2012 2814 - - -
2013 967 - - -
2014 - - - -
2015 - 552 424 968 “-“ Insufficient Water
Year 1st Half 2nd Half
2016 1989 - “-“ Insufficient Water
All concentrations are within the historical range of the location. The maximum total concentration
collected from Seep-14 was 5,340 µg/l, in 1995.
19
County Road:
This location was not sampled in 2012-2014, due to insufficient water. In 2015, sampling of this
location reported non-detect for VOCs. Therefore, there is not an indication that contaminants from the
Site are migrating off-site.
Air Monitoring:
Effluent air from the Permanent Liquid Recovery System (PLRS) and the Active Gas Vent (AGV)
system discharge is monitored using a PID. PID readings for the years of interest for this 5-Year Review
did not indicate any breakthroughs; therefore, no effluent air samples were collected from the PLRS and
AGV.
Site Inspection
The inspection of the Site was conducted on October 3, 2016. In attendance were Chanh Le, Hal
Cantwell, and Scott Thompson of the ODEQ, and Brian LaFlamme, Ben Costello, George Davis, and
Ryan Savage of Nationwide Environmental Services, acting on behalf of the HSRC. The purpose of the
inspection was to assess the protectiveness of the remedy.
Remedy components inspected include the V-Trench, the PLRS, the AGV, the Drying Shed, the
SWWRS, the Security Fence, and the Cap. All remedial components appeared to be in working
condition and no evidence of potential issues or failures were seen. The security fence appeared to be in
good condition for the purpose of restricting access and signs were visible to warn passersby. The cap
was found to be in good condition, with good vegetation and no indications of burrowing animals or
erosion concerns.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Yes, the remedy is currently functioning as intended, is in compliance with the Court-ordered remedy,
and continues to be protective of human health and the environment. The remedy is evaluated yearly and
an Annual Report is submitted to ODEQ and EPA. The effectiveness of the remedy is evaluated by
requirements laid out in the Performance Monitoring Plan (PMP). HSRC continually searches for
opportunities to improve the performance of the remedy. The 2016 Revised PMP details what activities
will be performed to maintain the remedy.
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?
Yes, the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the
time of the remedy selection are still valid.
The exposure assumptions and toxicity data for the contaminants of concern have not changed since the
previous Five Year Review.
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The Court Order specified remedial objectives for the Site, without specifying cleanup goals for
individual media. HSRC has implemented the remedy as described in the court order.
Institutional controls require the prevention of public access to the affected area, prohibition of
withdrawal of affected ground water, and supply of potable water to area residents. As such, there are no
current exposure pathways, except for the on-site workers and trespassers. For this five year review,
there are no changes to be made to the exposure pathway.
There have been slight modifications to the institutional control property land use in the last five years.
In addition to the previous modification that allowed a local land owner to run cattle on property south
of the Site Boundary, another modification has allowed for hay baling and row crops. The modifications
remain in compliance.
QUESTION C: Has any other information come to light that could call into question the protectiveness
of the remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) with Issues/Recommendations Identified in the Five-Year Review:
Sitewide - No issues were noted during this Five-Year Review.
VII. PROTECTIVNESS STATEMENT
Sitewide Protectiveness Statement
Protectiveness Determination:
Protective
Protectiveness Statement:
The remedy at the site is protective of human health and the environment. The Court Order
remedial objectives are being met and the Court selected remedy components are expected to
remain protective. Remedy components form the basis of waste containment at the Site, and
institutional controls ordered by the Court dedicate the Site solely to the remedial activities
ordered by the Court and restrict access and use of the Site and certain adjoining properties.
VIII. NEXT REVIEW
The next five-year review report for the Hardage-Criner Superfund Site is required five years from the
completion date of this review.
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APPENDIX A – REFERENCE LIST
EPA. 2001. “Comprehensive Five-Year Review Guidance.” EPA 540-R-01-007. June 2001.
EPA. 2002. “First Five-Year Review Report for the Hardage-Criner Superfund Site. McClain County,
Oklahoma. September.
EPA. 2007. “Second Five-Year Review Report for the Hardage-Criner Superfund Site. McClain County,
Oklahoma September.
EPA. 2012. “Third Five-Year Review Report for the Hardage-Criner Superfund Site. McClain County,
Oklahoma. May.
HSRC. 1996. Performance Monitoring Plan for Long-Term Operation and Remedy Implementation.
HSRC. 2012. Annual Remedial Site Report. January.
HSRC. 2013. Annual Remedial Site Report. January.
HSRC. 2014. Annual Remedial Site Report. January.
HSRC. 2015. Annual Remedial Site Report. January.
HSRC. 2016. Annual Remedial Site Report. January.
HSRC. 2016. Revised Performance Monitoring Plan for Long-Term Operation and Remedy
Implementation.
APPENDIX B – SITE BACKGROUND (Site background information is derived from the Third Five-Year Review of the Site)
22
3.0 BACKGROUND
This section discusses the Site’s physical characteristics, land and resource use near the Site, history of
site contamination, initial response to the Site, and the basis for the response.
3.1 PHYSICAL CHARACTERISTICS
The Site is located on old State Highway (SH) 122, 3/4 mile west of the intersection of old SH 122 and
SH 59 (Attachment 1). The Site is near Criner, McClain County, Oklahoma, approximately 30 miles
south-southwest of Oklahoma City. According to the 2010 census, the population within a one-mile
radius of the Site is approximately 48 persons.
The Site covers approximately 160 acres and is bordered by open farmland. The topography of the area is
flat to gently rolling hills. The principal disposal operations were conducted along a north-south trending
ridge at the center of the property. Relief is about 100 feet from the ridge to the adjacent stream valley.
The Site is bounded on the southwest by the North Criner Creek floodplain. North Criner Creek flows in
a southeasterly direction past the Site, eventually discharging to the Canadian River. Runoff from the
western side of the Site enters North Criner Creek and runoff from the eastern side drains into three small
farm ponds.
3.2 LAND AND RESOURCE USE
Historical land use surrounding the Site is primarily rural agricultural. The institutional control boundary
(ICB) restricts the Site and some adjoining property surrounding the Site (USDC WD 1991, USDC WD
2008a). In 2010, the EPA approved and the Court granted partial release and modification of the
restrictive covenants previously imposed upon the ICB. The following activities on designated tracts shall
be permitted including the erection and maintenance of a fence separating tract 3 from tract 7, and tracts
2, 3 and 6 may be used for animal grazing, animal husbandry and seeding, sowing and haying of grasses
only for feeding grazing animals, provided that any tilling or plowing of soil shall not exceed six inches in
depth (EPA, 2010, USDC WD 2010).
3.3 HISTORY OF CONTAMINATION
Royal N. Hardage owned and operated an industrial hazardous waste land disposal facility at the Site
from September 1972 to November 1980. Initially, the facility was permitted by the Oklahoma State
Department of Health (OSDH), but the permit was later revoked when the facility failed to meet newly
23
imposed standards of the Resource Conservation and Recovery Act (RCRA), 42 United States Code
(U.S.C.) Section 6973. During its operation, approximately 21 million gallons of waste were transported
to the Site for storage or disposal. Wastes included acids, caustics, lead, cyanide, arsenic, aromatic
solvents, chlorinated solvents, pesticides, polychlorinated biphenyls, oil recycling waste, and other
hazardous substances. Initially, liquid and sludge waste from drums or tank trucks was discharged into
unlined pits. As the disposal pits filled, drums were piled into a Sludge Mound. Eventually, the Site
contained waste impoundments, including a large unlined Main Pit, a series of smaller pits, a Sludge
Mound, and a Barrel Mound.
3.4 INITIAL RESPONSE
In 1978, the State of Oklahoma filed complaints against the facility for suspected lead contamination of
the air around the Site. In 1979, the OSDH began proceedings to revoke the facility’s permit for utilizing
unpermitted pits, failure to seal permeable lenses beneath the pits, improper closure of pits, failure to
retain runoff, and improper storage of wastes at the Site. Subsequently, preliminary EPA investigations
and inspections indicated poor waste management practices that posed a potential threat to public health
and the environment. In September 1980, the U.S. Department of Justice (DOJ) filed suit in United States
v. Hardage against Mr. Hardage on behalf of the EPA. The suit alleged violations of Section 7003 of
RCRA, 42 U.S.C. Section 6973 and sought injunctive relief for Site cleanup and closure. The Site was
closed in November 1980 and Royal Hardage filed bankruptcy in 1983. In 1984, potential responsible
parties (PRPs) were notified of potential EPA CERCLA liability and the DOJ began legal action seeking
to recover costs and impose an EPA CERCLA remedy. After a trial, the EPA CERCLA remedy was
determined de novo and the Judge ordered implementation of the Hardage Steering Committee (HSC)
remedy, thereby rejecting the 1989 EPA CERCLA remedy as “arbitrary and capricious”. Therefore, the
Site is under the jurisdiction of the U.S. District Court for the Western District of Oklahoma (Court) and
operates under a Court Ordered remedy, not an EPA CERCLA Record of Decision (ROD).
The Court Order specified remedial objectives for the Site without specifying cleanup goals for individual
media. The HSC completed construction of the court-ordered remedy in 1995. Periodic modifications
have been made (i.e. Southwest Wells Recovery System [SWWRS] and Passive Aeration System [PAS]).
The First Five-Year Review was completed on September 27, 2002. The Second Five-Year Review was
completed on September 24, 2007.
3.4 BASIS FOR TAKING ACTION
During site operations, approximately 21 million gallons of industrial wastes including acidic, caustic and
corrosive wastes, many classified as carcinogenic, were disposed on the Site. The principal source of
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contamination is estimated to be 278,000 cubic yards of sludges, waste drums, highly contaminated soils,
and waste liquids contained in three waste disposal areas near the center of the property. Hazardous
substances detected in the source area include: 1,2-dichloroethane, 1,1,2-trichloroethane, 1,1-
dichloroethene, tetrachloroethene, trichloroethene, lead, chromium, polychlorinated biphenyls, and
toxaphane.
Hazardous substances from the source area have contaminated the ground water present in Strata I, II, and
III. Ground water flows east toward the east farm ponds, and west-southwest toward the North Criner
Creek alluvium. Strata IV and V consist of low permeability mudstones and silty mudstones that
separates the shallow ground water from saline water in Stratum VI.
4.0 REMEDIAL ACTIONS
This section discusses the selected remedy, remedy implementation, operation and maintenance (O&M)
activities, and O&M costs.
4.1 SELECTED REMEDY
The Court selected remedial objectives for the Site, but did not select specific numerical cleanup
standards for attainment by the remedy. The remedial objectives described in the 1990 Judgment and
Order included (USDC WD 1990):
Control of the surface water pathway;
Preclusion of site access and direct contact with waste;
Control of air emissions from source areas;
Preclusion of the use of affected ground water; and
Provision for a contingent response to ensure continued maintenance of the quality of North Criner Creek.
The Court selected the following remedy components for the Site as described in the 1990 Judgment and
Order (see Section VIII, Finding No. 16, pages 56-58). The remedy components form the basis of a waste
containment remedy and must be monitored in perpetuity.
25
APPENDIX C – SITE CHRONOLOGY
26
CHRONOLOGY OF SITE EVENTS
HARDAGE-CRINER SUPERFUND SITE
Date Event
September 1972 - November 1980
Site operated as an Oklahoma Controlled Industrial Hazardous Waste Land Disposal Facility.
1978 State of Oklahoma filed complaints against the Site operator (i.e., Royal Hardage) for suspected lead contamination of the air around the Site.
September 1979
State of Oklahoma began proceedings to revoke the Site permit as a result of Royal Hardage's use of un-permitted pits, his failure to seal permeable lenses in the pits, his improper closure of pits, his failure to retain runoff, and his improper storage of wastes.
1979 Preliminary EPA investigations and inspections of the Site indicated poor waste management practices posing threats to public health and the environment.
September 1980
United States filed suit in United States v. Hardage (Hardage I) on behalf of the EPA against Royal Hardage seeking cleanup and closure of the Site. U.S. complaint alleged endangerment under Section 7003 of the RCRA, 42 U.S.C. Section 6973.
November 1980 Royal Hardage closed the Site prior to the effective date of the RCRA Subtitle C regulations.
1980 – 1986 EPA, RCRA, and CERCLA investigations and studies. Royal Hardage filed bankruptcy. Hardage I was dismissed in 1985 and U.S. filed CERCLA suit in Hardage II on June25, 1986.
1984 The EPA notified arranger and transporter companies that used the Site that they were CERCLA PRPs. The HSC was formed by the PRPs.
1986 – 1989
HSC site investigations and Hardage II case discovery. The EPA made second CERCLA remedy selection after 1986 remedy was not found compliant with RCRA land disposal restrictions. PRPs found liable in Hardage II, and the EPA entered $11 million de minimis settlement.
October 1989 HSC Recommended Comprehensive Site Remedy: Source Control and Management of Migration - Preliminary Design Report.
August 9, 1990 U.S. District Court rejected the EPA remedy and selected HSC Site remedy de novo in Hardage II.
September 1990 HSC Site Remedial Design /Remedial Actions began.
May 2, 1991 U.S. District Court Supplemental Judgment and Order.
May 1993 Site Remedial Design completed.
August 31, 1993 Modifications to the remedy were identified in the Order Modifying Remedy Implementation: Mounds Liquids Recovery System and On Site Class-1 Non-Hazardous Injection Well.
October 1993 Site remedial construction contract signed.
November 1993 Site remedial construction commenced started.
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Date Event
May 1994 Site V-Trench construction completed.
February 1995 Site Water Treatment Plant brought on-line.
September 1995 The Site remedial construction contractor finished its six-month shakedown and O&M started.
1995 HSRC contracted with Nationwide Environmental Services, Inc. for long-term O&M for the Site remedy.
September 1997 The EPA signed Hardage Site Preliminary Close Out Report.
September 2002 First Five Year Review Report for the Hardage-Criner Superfund Site completed.
January 2003 Hardage-Criner Superfund Site 2002 Annual Remedial Status Report completed.
January 2004 Hardage-Criner Superfund Site 2003 Annual Remedial Status Report completed.
January 2005 Hardage-Criner Superfund Site 2004 Annual Remedial Status Report completed.
March 9, 2005 U.S. District Court Joint Stipulation Agreement.
June 2005 Safety, Health, and Emergency Response Plan completed.
August 2005 Revised Performance Monitoring Plan for Long-Term Operation of the Remedy Implementation.
December 2005 Southwest Wells “Stand-by” Flow-Weighted Average Sampling Results finalized.
January 2006 Hardage-Criner Superfund Site 2005 Annual Remedial Status Report completed.
May 2006 O&M Manual (Revision 2) completed.
December 2006 Screening Level Health and Ecological Risk Assessment completed. Hardage-Criner Superfund Site Proposed V-Trench Passive Aeration System completed.
January 2007 Hardage-Criner Superfund Site 2006 Annual Remedial Status Report completed.
June 8, 2007 5 year down-hole video survey of V-trench and Southwest Wells Recovery System. Unable to obtain video logs from four wells blocked with root mats.
June 16, 2007 5 year RCRA Composite Cap subsidence survey completed. Nine locations showed subsidence of at least 0.5 ft or greater. Locations inspected by HSRC with no slope subsidence indicated.
July 2007 Court grants temporary modification to remedy for construction and operation of Passive Aeration System to treat ground water collected in V-Trench.
September 24, 2007 Second Five Year Review Report for the Hardage-Criner Superfund Site completed.
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Date Event
November 2007 V-Trench Passive Aeration System Pilot Study implemented.
April, 14 2008 A Court order was issued on April 14, 2008, to amend the Hardage Site and Institutional Control Boundary (ICB) lines.
April 2008
Revised pages to the 2005 PMP were approved by EPA and DEQ documenting the O&M changes during the operation of the PAS pilot test, the change in measuring the PLRS levels, the removal of pumps from the SWWRs wells, and the use of PDBs for sampling.
November 2008 The Annual FWA report was provided to EPA and DEQ in November 2008. Roots obstructed sample collection in SWWRS-6.
January 2009 Hardage-Criner Superfund Site 2008 Annual Remedial Status Report completed.
May 2009 Mechanical Integrity Test of Injection Well No. 1. Satisfies 5-year requirement.
July 13, 2009 HSRC notified the Court of the EPA approved modification of annual sampling event, replacing SWWRS-6 with a nearby piezometer for calculation of 2009 FWA.
January 2010 Hardage-Criner Superfund Site 2009 Annual Remedial Status Report completed.
March 24, 2010 Hardage Site Passive Aeration System 2-Year Full-Scale Pilot Test submitted.
June 15, 2010 A Court order was filed to allow the HSC to continue to operate the PAS as a temporary modification to the remedy during the HSRC’s evaluation.
May-June 2010 The HSC filed a Notice of Partial Release and Modification of Restrictive Covenants which only pertains to the ICB south of 180th Street to allow grazing and animal husbandry on the subject property.
August 2, 2011 Court approves implementation of Passive Aeration System as part of permanent remedy.
October 7, 2011 Court approves modification to SWWRS sampling protocol and the temporary replacement of SWWRS-6 with nearby piezometer (SWPZ-9) becomes part of permanent remedy.
January 25, 2012 2011 Revised Performance Monitoring Plan
June 8, 2012 5Year Down Hole Video
July 24, 2012 5 Year RCRA Composite Cap Topographic Survey
May 10, 2012 3rd Five-Year Review Signed
2014 Water Treatment Plant Decomissioning
29
Date Event
October 21, 2014 New carbon canisters installed in AGV and PLRS
October 12, 2016 Revised Performance Monitoring Plan
30
APPENDIX D – SITE MAPS
31
32
APPENDIX E – SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE VISIT CHECKLIST
I. SITE INFORMATION
Site Name: Hardage-Criner Superfund Site Date of Inspection: 10/3/2016
Location and Region: McClain County, Oklahoma EPA ID: OKD000400093
Agency leading the five-year review: DEQ Weather/temperature: Sunny/ Cool temperature
Remedy Includes: (Check all that apply)
Landfill cover/containment Groundwater pump-and-treatment
Access controls Surface water collection and treatment
Institutional controls Other-Leachate collection and treatment
Attachments: Inspection team roster attached Site map attached to report
II. INTERVIEWS (Check all that apply)
1. O&M Site Manager Brian LaFlamme Project Manager/NES 10/9/16 Name Title Date
Interviewed: by mail at site by phone Phone no. 303-232-2134
Problems, suggestions: Report attached Survey form attached to report
2. O&M Staff n/a_______________________________________________
Name Title Date
Interviewed: by mail at office by phone Phone no.
Problems, suggestions: Report attached
3. Local regulatory authorities and response agencies (i.e.; State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.). Fill in all that apply.
Agency ODEQ
Contact Hal Cantwell Project Manager 10/6/16 405-702-5139
Name Title Date Phone no.
Problems, suggestions: Report attached Survey form attached to report
Agency EPA
Contact Michael Hebert RPM 10/6/16
Name Title Date Phone no.
Problems, suggestions: Report attached Survey form attached to report
4. Other interviews (optional): Report attached
33
III. ONSITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents
O&M manual (long term monitoring plan) Readily available Up to date N/A
As-built drawings Readily available Up to date N/A
Maintenance logs (current and cumulative monitoring reports) Readily available Up to date N/A
Remarks:
2. Site-Specific Health and Safety Plan Readily available Up to date N/A
Contingency plan/emergency response plan Readily available Up to date N/A
Remarks:
3. O&M and OSHA Training Records Readily available Up to date N/A
Remarks:
4. Permits and Service Agreements
Air discharge permit Readily available Up to date N/A
Effluent discharge Readily available Up to date N/A
Waste disposal, POTW Readily available Up to date N/A
Other permits Readily available Up to date N/A
Remarks:
5. Gas Generation Records Readily available Up to date N/A
6. Settlement Monument Records Readily available Up to date N/A
7. Groundwater Monitoring Records Readily available Up to date N/A
8. Leachate Extraction Records Readily available Up to date N/A
9. Discharge Compliance Records
Air Readily available Up to date N/A
Water (effluent) Readily available Up to date N/A
Remarks:
10. Daily Access/Security Logs Readily available Up to date N/A
Remarks:
34
IV. O&M COSTS
1. O&M Organization
State in-house Contractor for State PRP in-house
Contractor for PRP Other
2. O&M Cost Records
Readily available Up to date Funding mechanism/agreement in place
Original O&M cost estimate Breakdown attached
Total annual cost by year for review period, if available
Date Date Total Cost
From 2012 to 2012 $387, 000 - Breakdown attached
From 2013 to 2013 $378,000 - Breakdown attached
From 2014 to 2014 $894,000 - Breakdown attached
From 2015 to 2015 $384,000 - Breakdown attached
From 2016 to 2016 $294,000* - Breakdown attached
*Costs are to date 10/20/16
3. Unanticipated or Unusually High O&M Costs During Review Period
Water Treatment Plant Decommissioning
V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A
A. Fencing
1. Fencing damaged Location shown on site map Gates secured N/A
Remarks: The security fence is 9-feet high and consists of an 8-foot high chain-link fabric and three strands of barbed-wire supported by 45-degree extensions. The fence restricts access of both unauthorized persons and animals. A motorized gate at the main entrance prevents unauthorized entrance; it is operated by an intercom and keypad system. This allows ready access by the Site workers, while restricting access by others. The security fence surrounds approximately 160 acres of land. In addition, surrounding the security fence, perimeter fencing runs along the border of approximately 333 acres of land within the institutional control boundary.
B. Other Access Restrictions
1. Signs and other security measures Location shown on site map N/A
Remarks: Signs are posted at regular intervals along the security fence identifying the site as a
hazardous waste site and warning against unauthorized entry. Site lighting is provided by
floodlights that are operated by photocell detectors and hand switches.
35
C. Institutional Controls
1. Implementation and enforcement
Site conditions imply institutional controls not properly implemented Yes No N/A
Site conditions imply institutional controls not being fully enforced Yes No N/A
Type of monitoring (e.g., self-reporting, drive by) Onsite personnel enforce the institutional controls during normal work hours.
Frequency Daily
Responsible party/agency HSRC/NES
Contact Brian LaFlamme Project Manager/NES 10/6/16 918-746-7977 Name Title Date Phone no.
Reporting is up-to-date Yes No N/A
Reports are verified by the lead agency Yes No N/A
Specific requirements in deed or decision documents have been met Yes No N/A
Violations have been reported Yes No N/A
Other problems or suggestions: Report attached
2. Adequacy Institutional controls are adequate Institutional controls are inadequate N/A
Remarks:
D. General
1. Vandalism/trespassing Location shown on site map No vandalism evident
Remarks:
2. Land use changes onsite N/A
Remarks: The Court Order precludes the change of future land use.
3. Land use changes offsite N/A
Remarks: Hay baling and row crops now allowed
VI. GENERAL SITE CONDITIONS
A. Roads Applicable N/A
Remarks: The roads were in excellent condition.
B. Other Site Conditions Applicable N/A
Remarks:
VII. LANDFILL COVERS Applicable N/A
A. Landfill Surface
1. Settlement (Low spots) Location shown on site map Settlement not evident
Areal extent Depth
Remarks:
36
2. Cracks Location shown on site map Cracking not evident
Lengths Widths Depths
Remarks:
3. Erosion Location shown on site map erosion not evident
Areal extent Depth
Remarks:
4. Holes Holes evident Holes not evident
Areal extent Depth
Remarks:
5. Vegetative Cover Grass Cover properly established No signs of stress
Trees/Shrubs (indicate size and locations on a diagram) (None)
Remarks:
6. Alternative Cover (armored rock, concrete, etc.) N/A
Remarks: Surface water relief channels were noted with rip-rap and armored as necessary.
7. Bulges Location shown on site map Bulges not evident
Areal extent Depth
Remarks:
8. Wet Areas/Water Damage Wet areas/water damage not evident
Wet areas Location shown on site map Areal extent
Ponding Location shown on site map Areal extent
Seeps Location shown on site map Areal extent
Soft subgrade Location shown on site map Areal extent
Remarks:
9. Slope Instability Slides Location shown on site map
No evidence of slope instability Areal extent
Remarks:
B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow
down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1. Flows Bypass Bench Location shown on site map N/A or okay
Remarks:
2. Bench Breached Location shown on site map N/A or okay
Remarks:
3. Bench Overtopped Location shown on site map N/A or okay
Remarks:
C. Letdown Channels Applicable N/A
1. Settlement Location shown on site map No evidence of settlement
Areal extent Depth
Remarks:
2. Material Degradation Location shown on site map No evidence of degradation
Material type Areal extent
Remarks:
37
3. Erosion Location shown on site map No evidence of erosion
Areal extent Depth
Remarks:
4. Undercutting Location shown on site map No evidence of undercutting
Areal extent Depth
Remarks:
5. Obstructions Type
No obstructions Location shown on site map
Areal extent Size
Remarks:
6. Excessive Vegetative Growth Type
No evidence of excessive growth Vegetation in channels does not obstruct flow
Location shown on site map Areal extent
Remarks:
D. Cover Penetrations Applicable N/A
1. Gas Vents Active Passive
Properly secured/locked Functioning Routinely sampled Good condition
Evidence of leakage at penetration Needs O&M N/A
Remarks: monitored monthly
2. Gas Monitoring Probes
Properly secured/locked Functioning Routinely sampled Good condition
Evidence of leakage at penetration Needs O&M N/A
Remarks:
3. Monitoring Wells (within surface area of landfill)
Evidence of leakage at penetration Needs O&M N/A
Remarks:
4. Leachate Extraction Wells
Properly secured/locked Functioning Routinely sampled Good condition
Evidence of leakage at penetration Needs O&M N/A
Remarks:
5. Settlement Monuments Located Routinely surveyed N/A
Remarks: 2012 Survey (surveyed every 5 years)
E. Gas Collection and Treatment Applicable N/A
1. Gas Treatment Facilities
Flaring Thermal destruction Collection for reuse
Good condition Needs O&M
Remarks:
2. Gas Collection Wells, Manifolds, and Piping Good condition Needs O&M
Remarks:
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
Good condition Needs O&M N/A
Remarks:
F. Cover Drainage Layer Applicable N/A
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1. Outlet Pipes Inspected Functioning N/A
Remarks:
2. Outlet Rock Inspected Functioning N/A
Remarks:
G. Detention/Sedimentation Ponds Applicable N/A
1. Siltation Areal extent Size
N/A Siltation not evident
Remarks:
2. Erosion Areal extent Depth
Erosion not evident
Remarks:
3. Outlet Works Functioning N/A
Remarks:
4. Dam Functioning N/A
Remarks:
H. Retaining Walls Applicable N/A
1. Deformations Location shown on site map Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks:
2. Degradation Location shown on site map Degradation not evident
Remarks:
I. Perimeter Ditches/Off-Site Discharge Applicable N/A
1. Siltation Location shown on site map Siltation not evident
Areal extent Depth
Remarks:
2. Vegetative Growth Location shown on site map N/A
Vegetation does not impede flow
Areal extent Type
Remarks:
3. Erosion Location shown on site map Erosion not evident
Areal extent Depth
Remarks:
4. Discharge Structure Functioning N/A
Remarks:
VIII. VERTICAL BARRIER WALLS Applicable N/A
1. Settlement Location shown on site map Settlement not evident
Areal extent Depth
Remarks:
2. Performance Monitoring Type of monitoring
Performance not monitored Frequency Evidence of breaching
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Head differential
Remarks:
IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A
A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A
1. Pumps, Wellhead Plumbing, and Electrical
Good condition All required wells located Needs O&M N/A
Remarks: SWWRS continues to be on Standby
2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs O&M
Remarks:
3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A
1. Collection Structures, Pumps, and Electrical
Good condition Needs O&M
Remarks:
2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs O&M
Remarks:
3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks:
40
C. Treatment System Applicable N/A
1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon absorbers Filters Additive (e.g., chelation agent, flocculent) pH management Others Passive Aeration System Good condition Needs O&M Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually (See below. Quantities in Gallons) Quantity of surface water treated annually
Remarks: 2012 – 2,673,500; 2013- 2,467,200; 2014 – 2,371,800; 2015 – 2,914,500
2. Electrical Enclosures and Panels (Properly rated and functional)
N/A Good condition Needs O&M
Remarks:
3. Tanks, Vaults, Storage Vessels
N/A Good condition Proper secondary containment Needs O&M
Remarks:
4. Discharge Structure and Appurtenances
N/A Good condition Needs O&M
Remarks:
5. Treatment Building(s)
N/A Good condition (esp. roof and doorways) Needs repair
Chemicals and equipment properly stored
Remarks:
6. Monitoring Wells (Pump-and-treatment remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs O&M N/A
Remarks:
D. Monitored Natural Attenuation Applicable N/A
1. Monitoring Wells (Natural attenuation remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs O&M N/A
Remarks:
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X. OTHER REMEDIES
If there are remedies applied at the site that are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).
The Court selected remedial objectives for the Site, but did not select specific numerical cleanup standards for attainment by the remedy. The remedial objectives included control of the surface water pathway, air emissions, and affected ground water, as well as preclusion from site access and exposure to waste. The current implementation of the remedy is effective and is functioning as planned.
B. Adequacy of O&M
Current O&M activities are adequate.
C. Early Indicators of Potential Remedy Failure
There are no early indicators of potential remedy failure.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
The HSRC continues to look for optimization opportunities. Evidence is shown in the continual update to the performance monitoring plan. An example is the removal of the water treatment plant and full use of the passive aeration system.
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APPENDIX F – SITE INTERVIEWS
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INTERVIEW RECORD
Site Name: Hardage-Criner Superfund Site EPA ID No.: OKD000400093
Location: Criner, McClain County, Oklahoma Date:
Contact Made By:
Name: Chanh Le Title: Environmental Programs Specialist
Organization: DEQ
Individual Contacted:
Name: Hal Cantwell Title: Project Manager Organization: DEQ
Telephone No: (405) 702-5139
E-Mail Address: [email protected] Street Address: 707 North Robinson
City, State, Zip: Oklahoma City, OK 73102
1. What is your overall impression of the project? (general sentiment)
Very Positive – a very well managed and operated endeavor.
2. What effects have site operations had on the surrounding community?
The rural community in proximity to the Site have been minimally impacted. Several immediately neighboring landowner’s properties were obtained at fair market value by the HSRC to institute the stipulated Site Land Use restrictions. The site contamination is all encompassed within these properties owned by the HSRC.
3. Are you aware of any community concerns regarding the site or its operation and administration? If so,
please give details.
Occasionally, I receive inquiries regarding real estate transactions in the Sections near the Site but when the details of the history and cleanup activities of the site are known the parties do not express negative concerns.
4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details.
I do not know of any incidents of types listed that have occurred recently at the Site.
5. Do you feel well informed about the site’s activities and progress? I feel Very well informed concerning all aspects of the Site.
6. Do you have any comments, suggestions, or recommendations regarding the site’s management or
operation?
I do not.
7. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.)
conducted by your office regarding the site? If so, please give purpose and results.
There has been and continue to be frequent communications and activities related to the DEQ’s responsibilities in the role of representing the State of Oklahoma regarding the environmental remediation of the Site. The activities and results are too numerous and voluminous to list but can be obtained by visiting DEQ’s website or a submitting formal request to the DEQ Central Records.
8. Have there been any complaints, violations, or other incidents related to the site requiring a response by
your office? If so, please give details of the events and results of the responses.
There have there been no complaints, violations, or other incidents related to the Site requiring a response by our office.
44
INTERVIEW RECORD
Site Name: Hardage-Criner Superfund Site EPA ID No.: OKD000400093
Location: Criner, McClain County, Oklahoma Date:
Contact Made By:
Name: Chanh Le Title: Environmental Programs
Specialist
Organization: DEQ
Telephone No: (405) 702-5102
E-Mail Address: [email protected]
Street Address: 707 North Robinson
City, State, Zip: Oklahoma City, OK 73101
Individual Contacted:
Name: Brian LaFlamme Title: HSRC Facility Manager Organization: NES
Telephone No: (303) 232-2134
E-Mail Address: [email protected]
Street Address: 14818 6th Ave. West, Suite 5A
City, State, Zip: Golden, CO 80401
45
Summary Of Conversation
1. What is your overall impression of the project? (general sentiment)
Operation and maintenance (O&M) of the remedial action at the Hardage Site has been conducted in accordance with
the approved plan in an efficient manner and all required reports have been filed in a timely manner. Ongoing
collaboration with the ODEQ and EPA ensures continued efficiency and protection of human health and the
environment.
During the last 5-year interval, Site-related VOC concentrations in the Stratum III groundwater (previously captured
by the Southwest Wells Recovery System [SWWRS] remedy component) continue to be below the flow-weighted average
(FWA) VOC concentration limits of 100 (parts per billion) ppb and 150 ppb. This meets the natural attenuation
requirements, allowing this remedy component to remain idle.
The Court approved Passive Aeration System (PAS) continues to operate efficiently as a permanent remedy component
for the treatment of groundwater extracted from the V-Trench. The substitution of the PAS for the water treatment
plant has greatly decreased the site-wide energy usage and, therefore, the carbon footprint of the remedy. This has
allowed the decommissioning/dismantling of the water treatment plant in 2014.
A mechanical integrity test of the non-hazardous injection well in 2014 indicates the well is intact and has not been
compromised. The well remains in temporary abandonment and will be monitored and tested as the regulations require
until a final decision is made to permanently abandon it.
As anticipated, each year the permanent mound liquids recovery system (PLRS) recovers fewer liquids than the year
before. The HSRC continues to conduct load outs of the recovered mounds liquids consistent with RCRA.
The phytoremediation test plot was discontinued in 2013, with approval by EPA & ODEQ. The Site related VOC
concentrations in water quality samples from Seep 14 are decreasing.
2. Is the remedy functioning as expected? How well is the remedy performing?
The remedy is functioning as expected, performing efficiently and continuing to be protective of the human health and
the environment as well as the surrounding community.
The HSRC has been very proactive in their communications with their neighbors to ensure that ongoing Site operations
have no negative effects on the adjacent property owners. The HSRC has been working diligently with the various first
responders near the Hardage Site that might be called upon to enter the Site in case of a Site-related emergency. The
HSRC has voluntarily prepared first responder information notebooks and distributed them to each local fire
department and police force and installed first responder information boxes at each entrance to the Site. The first
responder information boxes are equipped with all relevant Site-related maps and annotated photographs, health and
safety information and HSRC emergency contact information.
The HSRC is currently seeking to enter into a lease agreement with a local farmer to allow growing/cutting of hay on
land south of the Hardage Site proper. The growing/cutting of hay would allow continued support for the local
community and provides a maintained landscape for unencumbered access to monitoring wells and creek locations that
also serves as a wildfire control.
3. What does the monitoring data show? Are there any trends that show contaminant levels are decreasing?
The O&M monitoring data indicate that overall VOC concentrations in Stratum III groundwater down gradient of the
V-Trench Remedy component are decreasing and the volume of mounds liquids (able to be pumped) recovered from
underneath the Cap are decreasing. This is an indication of the continuing integrity of the RCRA cap.
46
4. Is there a continuous on-site O&M presence? If so, please describe staff and activities.
There is an O&M presence onsite during normal working days, i.e., Monday through Friday from approximately 7:00
AM to 3:30 PM and on call during the weekends. The presence consists of two onsite technicians. The technicians
perform routine maintenance of equipment, sampling, and monitoring activities, and maintain the grounds.
Maintenance of the grounds includes providing a firebreak along all of the fence lines of the owned property. In
addition, the Hardage Site is equipped with emergency call-out capabilities that notify the onsite technician of any site
related emergency, e.g., break-in, fire, leaks, etc., after normal working hours. The onsite technicians assess the
situation and call the first responders if the situation requires their presence at the Hardage Site.
5. Have there been any significant changes in the O&M requirements, maintenance schedules, or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the
remedy?
Any changes to the O&M requirements are the result of improving sampling activities (i.e., from bailing to the use of
passive diffusion bags), monitoring activities (i.e., measuring liquid levels in the mounds only during load outs), and
treatment processes (i.e., replacing the water treatment plant with the PAS). The changes continue to maintain the
remedy’s overall protectiveness relative to treating groundwater and provide additional protectiveness for workers
during hands on O&M activities.
6. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years?
Not over the last five years. However, in 1996, shortly after start-up, seeps in the Northwest Borrow Area (as described
earlier) were observed and, following testing and coordination with EPA and ODEQ a plan to monitor the water quality
in the Northwest Borrow Area was implemented.
7. Have there been opportunities to optimize O&M, or sampling efforts? Please describe changes and resultant or
desired cost savings or improved efficiency.
As previously mentioned, the opportunity to include the PAS as a permanent remedy component has been realized.
This system provides all the protectiveness of the original water treatment plant while increasing the efficiency with
which groundwater is treated, reducing the overall carbon footprint of the remedy, reducing energy consumption, and
eliminating the need for expensive water treatment chemicals. The HSRC continues to evaluate opportunities to
optimize O&M activities and sampling efforts without compromising the protectiveness of the remedy. During the last
5-year interval, the Site-related VOC concentrations in the Stratum III groundwater (previously captured by the
SWWRS remedy component) continue to be below the flow-weighted average (FWA) VOC concentration limits of 100
ppb and 150 ppb. This meets the natural attenuation requirements, allowing this remedy component to remain idle.
8. Do you have any comments, suggestions, or recommendations regarding the project?
The Hardage Site Remedy Corp (HSRC), the organization implementing the remedy at the Hardage Site, appreciates
the proactive, cooperative teamwork and insights that Mike Hebert, EPA RPM, and Hal Cantwell, ODEQ RPM, have
provided over the years to streamline operational aspects of the remedy. This has allowed a significant reduction in
the site-wide energy consumption and carbon footprint and has made the remedy more cost-effective, all without
compromising the protectiveness of the remedy. The HSRC will continue its conscientious operation, maintenance, and
performance monitoring of the remedy at the Hardage Site.
47
INTERVIEW RECORD
Site Name: Hardage-Criner Superfund Site EPA ID No.: OKD000400093
Location: Criner, McClain County, Oklahoma Date: 10/05/2016
Contact Made By:
Name: Chanh Le Title: Environmental Programs Specialist
Organization: DEQ
Individual Contacted:
Name: Michael Hebert Title: Remedial Project Manager Organization: EPA
Telephone No: (214) 665-8315
E-Mail Address: [email protected] Street Address: 1445 Ross Ave, Suite 1200
City, State, Zip: Dallas, TX 75202
48
Summary Of Conversation
1. What is your overall impression of the project? (general sentiment)
Operation and Maintenance activities have been performed routinely over the past 5 years with no significant problems.
2. Is the remedy functioning as expected? How well is the remedy performing?
The Court ordered remedy has functioned as expected in the last 5 years. The V-Trench Recovery System and the Mounds Liquid Recovery System continue to recover contamination from the composite cap area. Consistent with the Monitored Natural Attenuation component of the Court-Ordered Remedy, the analytical results indicate total VOCs in the NCC alluvial system have decreased in the last 5 year period.
3. What does the monitoring data show? Are there any trends that show
contaminant levels are decreasing?
V-Trench Influent VOC concentrations have varied with no real discernable trend as in the last 5 year period. Consistent with the Monitored Natural Attenuation component of the Court-Ordered Remedy, the analytical results indicate total VOCs in the NCC alluvial system have decreased in the last 5 year period.
4. Is there a continuous on-site O&M presence? If so, please describe staff and
activities. If there is not a continuous on-site presence, describe staff and
frequency of site inspections and activities.
The Hardage Steering Committee and the Hardage Site Remediation Corp. have consultants that maintain a continuous on-site presence during regular working hours. The Programmable Logic Controller which monitors the site’s remedial systems has a
remote notification system to alert staff to upsets in the system operations when staff is not on-site.
5. Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines since start-up or in the last five years? If so, do
they affect the protectiveness or effectiveness of the remedy? Please describe
changes and impacts.
None of the following O&M changes affect the protectiveness of the remedy:
March 2013 – Samples were discontinued from the phytoremediation area
2014 – The PLC system was upgraded
2014 – The Water Treatment Plant was decommissioned
2014 – A mechanical integrity test was performed on the injection well
2014 – Maintenance was performed on the PLRS pumps – some pumps were replaced
2014 – New carbon canisters were installed on the PLRS air treatment systems 49
INTERVIEW RECORD
Site Name: Hardage-Criner Superfund Site EPA ID No.: OKD000400093
Location: Criner, McClain County, Oklahoma Date: March 31, 2017
Contact Made By:
Name: Chanh Le Title: Environmental Programs
Specialist
Organization: DEQ
Individual Contacted:
Name: Dick E. Vinson Title: citizen Organization: n/a
Telephone No: -
E-Mail Address: -
Street Address: -
City, State, Zip: -
1. What is your overall impression of the project? (general sentiment) A lot better.
2. What effects have site operations had on the surrounding community?
At first every one was pretty happy because I was helping with the trees around the area.
3. Are you aware of any community concerns regarding the site or its operation and
administration? If so, please give details. None
4. Are you aware of any events, incidents, or activities at the site such as vandalism,
trespassing, or emergency responses from local authorities? If so, please give details.
None 5. Do you feel well informed about the site’s activities and progress? Yes. I get a letter every November concerning the wells on my property.
6. Do you have any comments, suggestions, or recommendations regarding the site’s
management or operation? They do not let anybody on the tree area in front of the site. It’s a fire hazard right now without someone taking care of the area or raising cattle on it.
Originally I had it on record about what I could and could not do on the land that I was
originally working on when I agreed to clean it up. I helped keep trespassers out. I was okayed
to lay wheat and fertilize the ground. I was told that as long as I took care of the land I could
raise cattle on it. I was using a certain spray on the land and everybody knew about it, but one
day they came out and told me I couldn’t use it and kicked me off the land.
50