- CERCLA-Tulsa Fuel and Manufacturing
Burns & McDonnell was selected by the Oklahoma Department of Environmental Quality (ODEQ) to conduct a remedial investigation and feasibility study (RI/FS) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP) at the Tulsa Fuel and Manufacturing (TFM) Superfund site near Collinsville, Okla.
TFM operated a lead smelter and zinc roaster at the site from 1914 to 1925. The operation consisted of nine furnaces, a kiln building, a condenser room, a large reservoir and a laboratory. Large amounts of ore were stored at the site and an estimated 30,000 cubic yards of broken retorts, slag and other materials for the smelting operation are present at the site. These waste piles are not covered and are uncontrolled with surface water and off-site drainage occurring at the site, resulting in metals contamination. Possible migration pathways included airborne transportation, leaching to soil and groundwater, groundwater migration, surface runoff and physical transport of slag off the site for residential use.
Determining the nature and extent of the contamination at the site presented a challenge due to an array of migration pathways and a limited budget; however, an approach that met the project objectives and budget through the use of innovative sampling and analytical techniques was implemented.
- Remedial investigation (RI) with baseline risk assessment (BLRA)
- Feasibility study (FS)
- Proposed plan
- Record of decision (ROD)
Remedial Investigation (RI)
The project scope started with the preparation of the RI work plan. The RI work plan included procedures for conducting field work, selecting of remedial alternatives, and preparing the feasibility study, proposed plan and record of decision. To meet the limited site budget, a phased approach for field activities was adopted. This approach entailed an initial investigation to determine which areas of concern/pathways were impacted, then focus was placed on those areas. For example, off-site surface sampling was initially on a wide-spaced grid using XRF on-site analyses. A second phase with laboratory samples was then used to define the extent. The approach for the site also considered the fact that future litigation with potentially responsible parties (PRPs) was a distinct possibility and the investigation must be conducted in a manner that conclusions reached could be supported during future litigation.
A wide variety of field techniques were used based on past experience at similar sites and included trenching, PM-10 air sampling, personal air monitoring, direct-push soil and water sampling, well installation, surface water sampling, subsurface water sampling, and sediment sampling. Burns & McDonnell is conducting the Phase 2 sampling to fill data gaps and preparing the RI report, which includes a human and ecological baseline risk assessment. The approach for the risk assessment was determined in the work plan with input from EPA personnel to reduce comments and associated delays later in the project.
Using the conclusions of the RI report and risk assessment, Burns & McDonnell will evaluate remedial alternatives to eliminate potential risks at the site and meet other remedial goals by completing a fasibility sudy. ote that selection of the remedial alternatives began during the RI by the selection of possible alternatives and collection of data to evaluate the remedial alternatives at the site.
Proposed Plan and Record of Decision
A poposed pan and record of decision will also be prepared to complete the RI/FS process under CERCLA. Investigation derived waste (IDW) was characterized and then disposed of as necessary. Some IDW was left at the site for incorporation into the final remedial alternative.
The project is located within the area of Oklahoma that is a possible location of the American burying beetle, which is on the endangered species list. The site is representative of the beetle’s preferred habitat in Oklahoma: the forest/pasture ecotone and open pastures. The U.S. Fish & Wildlife Service required a survey of the site for the presence/absence of the beetle before the initiation of field activities at the site. The project required a certified sampler, work plan and report before permission to conduct field work was obtained. The survey work plans were prepared on an accelerated schedule in order to be in the field during the temperature and precipitation window required.
The TFM site is at the edge of Collinsville and required interaction with the community. Burns & McDonnell, with ODEQ, sponsored two town hall meetings to allow the public to ask questions or voice concerns. Through our interaction with the citizens at the meeting, we learned that slag from the site was used extensively around Collinsville for road base and backfill. Based on this information, we obtained access and sampled a number of locations within Collinsville and identified other slag sites for remediation.
A project Web site was created to maintain the administrative record. The public has access to final documents and other correspondence that are part of required record are available to anyone that logs onto the site. The public can gain access at the public library if they do not have Internet access. Additional information for the project team and regulators is available on the Web site but not available to the public because of multi-level security.
Burns & McDonnell also coordinated sampling efforts and planning with the Inter-Tribal Environmental Council (ITEC) to ensure that off-site samples were collected at a number of Native American-owned properties.
Oversight/Performance of Chemical Analytical Services
The project involved sampling both the TFM site and properties in the surrounding community. The ODEQ State Environmental Laboratory (SEL) was used for analyses of all project samples. Because of the large sample load, Burns & McDonnell chemists carefully coordinated submission of samples to the lab, clarifying the identity of project quality control samples and anticipated deliverables. During the course of the RI, it was determined that the laboratory x-ray fluorescence (XRF) analysis of on-site samples was routinely yielding results in excess of the calibration range. In order to provide a sufficient data set for use in the risk assessment, key samples were identified and reanalyzed using inductively coupled plasma techniques to obtain results within the calibration range. Additionally, a hand-held XRF was used to assist in off-site characterization. Use of the field XRF expedited the sample collection process and allowed for quick determination of locations that required further characterization. Off-site samples were then collected and submitted to the laboratory for analysis to insure usable data, support conclusions regarding nature and extent of contamination, and provide a sufficient data set for use during the risk assessment.
GIS/Data Management/Graphics/Project Web Site
Burns & McDonnell is using its proven methodology for regulatory screening to produce figures and data tables. One notable project requirement is that the project management team relies on daily updates from analytical laboratories to determine where to next sample. To facilitate reporting-on-demand, Burns & McDonnell built a secure Web site using ESRI ArcIMS (Internet Mapping System), which makes analytical results and sampling status maps accessible from any Internet-connected workstation. The site is interactive, password protected and restricts use based on the password (i.e. project manager, team member, public). Draft documents were posted to the site for regulatory review and comment, monthly reports and invoices were posted for review and approval, and photos of field work were available for review by the public during the field investigation. The site decreased review times, accelerated the schedule and gave the public access to project status information. GIS figures were available during the field investigation. The figures tracked the progress of the field work and posted the field screening results as available. The site improved communication among the project team and was a valuable tool for quick decision making.
Burns & McDonnell prepared a data management plan that detailed data storage, handling, access and security between Burns & McDonnell, ODEQ, the U.S. Environmental Protection Agency and other participating parties. Data were stored in Microsoft Access using an ODEQ-approved delivery format contained ESRI Personal Geodatabase feature classes that supported its use with ArcGIS version 9.x. ArcCatalog was used to build and import data table structure, and the database was normalized to eliminate redundant data and create data dependencies. The database includes chemical data, borehole data and spatial data with naming conventions that allowed the entire project team to understand the data based on the naming conventions.
- Completed RI with no OSHA reportable accidents.
- Project Web site was utilized to facilitate communication with project team and public.
Multiple sample collection techniques employed to overcome difficult on-site conditions.
- Efficient mobilization for field work in Oklahoma.
- American burying beetle survey work plans and survey were prepared and implemented on an accelerated schedule in order to be in the field during the temperature and precipitation window required.