holly east tulsa refinery rcra part b post-closure and corrective ...

HOLLY REFINING & MARKETING ‐ TULSA LLC EAST TULSA REFINERY

RCRA PART B POST‐CLOSURE AND CORRECTIVE ACTION

PERMIT APPLICATION

902 WEST 25th STREET TULSA, OKLAHOMA 74107

OCTOBER 21, 2011

HOLLY EAST TULSA REFINERY

RCRA PART B POST‐CLOSURE AND CORRECTIVE ACTION

PERMIT APPLICATION

OCTOBER 21, 2011

Holly Refining & Marketing Tulsa LLC – East Tulsa Refinery RCRA Part B Post‐Closure and Corrective Action Permit

Permit No. 990750960–PC

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY RCRA POST‐CLOSURE CARE PERMIT FOR A ACTIVE HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID#: OKD990750960 Permit Number 990750960‐PC Permittee: Holly Refining & Marketing ‐ Tulsa LLC Effective Date: XX/XX/201X P. O. Box 970 Expiration Date: XX/XX/202X Tulsa, OK 74101 Pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA) of 1976, including the Hazardous and Solid Waste Amendments of 1984 (HSWA) at 42 U.S.C. § 6901 et seq., and regulations promulgated thereunder by the U.S. Environmental Protection Agency (EPA) codified in Title 40 of the Code of Federal Regulations, the Oklahoma Hazardous Waste Management Act (OHWMA) at 27A O.S. § 2‐7‐101, et seq., as amended, and rules promulgated thereunder in the Oklahoma Administrative Code (OAC) 252:205, the Oklahoma Uniform Environmental Permitting Act at 27A O.S. § 2‐14‐101 et seq., and rules promulgated thereunder in OAC 252:4‐7, a Permit to perform post‐closure care and corrective actions for a closed hazardous waste management facility is hereby issued by the Oklahoma Department of Environmental Quality (DEQ) to Holly Refining & Marketing – Tulsa LLC (hereafter called the Permittee). The Refinery is located within Township 19 North, Range 12 East, Sections 13, 14, 23 and 24, Tulsa County, Oklahoma, at 902 West 25th Street, City of Tulsa (Facility), summarily described as follows: The Permittee is a petroleum based refinery located on approximately four hundred seventy four (474) acres. The refinery has been in operation since approximately 1906 under several operators. The Refinery is one of the Permittee’s two (2) refineries operating in Tulsa, OK. These refineries include the Facility (Holly East Tulsa Refinery) formerly owned by Sinclair and the Holly West Tulsa Refinery formerly owned by Sunoco. The combined refining capacity of the Permittee’s East and West Tulsa Refineries is approximately 125,000 barrels of oil per day. The petroleum products normally produced at the Facility include the following: 1. Gasoline; 2. Diesel fuel; 3. Fuel oils; 4. Propane; 5. Butane; and 6. Commercial jet fuel.



The permit is a RCRA post‐closure and corrective action permit for two (2) closed hazardous waste treatment units and several other recognized solid waste management units (SWMUs) or areas of concern (AOCs) located on the Facility property. A Consent Order, Case No. 09‐319, was agreed to between the Permittee and the DEQ on November 30, 2009. The Consent Order mandated the inclusion of post‐closure care requirements for the Walnut Grove Land Treatment Unit (WGLTU) in the Flare Area post‐closure permit. It also required the inclusion of additional investigation activities in four of the SWMUs and AOCs. These include SWMU‐H (landscape area), AOC‐2 (former Union Pacific railroad property) and the light non‐aqueous phase liquid (LNAPL) and dissolved phase benzene and MTBE plumes underlying the Facility. The expansion of the stated boundaries of SWMU‐C and SWMU‐E were also to be included in the Flare Area post‐closure permit. The closed Land Treatment Units (LTUs) are areas of the Facility that were previously used for land farming operations since the early 1900’s. Historically applied wastes consisted of liquid, sludge and solid residues from various refinery operations. The most recent RCRA post‐closure permit for the Flare Area Land Treatment Unit (FALTU), Permit # 990750960‐PC, was renewed on July 2, 2008. The FALTU was officially closed and post‐closure care began on April 1, 1993. The WGLTU was issued a permit to operate as a hazardous waste LTU on December, 10, 1998, Permit # 990750960‐OP. The WGLTU operating permit expired on December 10, 2008. The WGLTU was officially closed on April 24, 2009 and post‐closure care began at that time. On March 8, 2010 the Permittee received notification from DEQ granting closure of the WGLTU effective November 4, 2009. In the interim, post‐closure activities at the WGLTU have been conducted based upon the Post‐Closure Plan contained in the expired WGLTU Operating Permit # 990750960‐OP. The Permittee submitted a draft RCRA Post‐Closure Care Permit Application for the FALTU and WGLTU to the DEQ on April 30, 2010, as required by the Consent Order in Case No. 09‐319. All tasks required by said Consent Order have since been fulfilled. In September 2010, the Permittee presented a preliminary conceptual site model (CSM) to the DEQ, including a review of current environmental subsurface conditions which suggest the LTUs do not appear to be a source of the LNAPL and dissolved phase plumes underlying the Facility. Additionally, no statistically significant soil or groundwater detections were exhibited over decades of compliance monitoring at the FALTU and WGLTU. As such, the Permittee proposed that a Facility‐wide permitting approach may be more appropriate for the Facility than the current LTU‐based permit(s). The DEQ agreed to this approach and a new Consent Order for the Facility (Case No. 11‐100) was filed on July 6, 2011, requiring submittal of a new RCRA Post‐Closure and Corrective Action Permit application for the Facility by October 21, 2011. The Permittee must conduct post‐closure maintenance activities, including groundwater monitoring, for a thirty (30) year period or until a demonstration of no endangerment to human health or the environment is approved by the DEQ in accordance with the terms of this permit. The Permittee must comply with all terms and conditions of this permit. This permit consists of the conditions contained herein (including those in any attachments), and the applicable



regulations contained in 40 CFR Parts 124, 260 through 264, 266, 268, and 270, as specified in the permit. Applicable regulations are those which are in effect on the date of issuance of the permit, in accordance with 40 CFR 270.32(c). Primary responsibility for the enforcement under RCRA and HSWA of the provisions of this permit shall lie with DEQ. This Permit is based on the assumption that all the information submitted in the Part B permit application attached to the Permittee's letter dated October 20, 2011, and additional information submitted on XXXX ,XX, 20XX (hereafter referred to as the application) is accurate and that the Facility will be operated pursuant to the conditions of this permit and as specified in the application. Any inaccuracies found in the submitted information may be grounds for the termination, revocation and reissuance, or modification of this permit in accordance with 40 CFR 270.41, 270.42, and 270.43 and for enforcement action. This permit is effective as of xx/xx/20XX and shall remain in effect until xx/xx/20XX unless revoked and reissued under 40 CFR 270.41, terminated under 40 CFR 270.43, or continued in accordance with 40 CFR 270.51(a), OAC 252:205, and the Oklahoma Administrative Procedures Act. Issued this XX day of XXXX, 20XX. ___________________________________________ Saba Tahmassebi, Ph.D., P.E., Chief Engineer Land Protection Division ___________________________________________ Scott Thompson, Division Director Land Protection Division



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TABLE OF CONTENTS

SECTION I ‐ GENERAL PERMIT CONDITIONS ........................................................................... I‐1

A. GENERAL ............................................................................................................................... I‐1 B. BASIS OF PERMIT .................................................................................................................... I‐1 C. INCORPORATION BY REFERENCE ............................................................................................ I‐1 D. DEFINITIONS .......................................................................................................................... I‐1 E. EFFECT OF PERMIT ................................................................................................................. I‐3 F. PERMIT ACTIONS ................................................................................................................... I‐4 G. SEVERABILITY ......................................................................................................................... I‐5 H. DUTIES AND REQUIREMENTS ................................................................................................. I‐5 I. SIGNATORY REQUIREMENT ................................................................................................. I‐10 J. REPORTS, NOTIFICATIONS, AND SUBMISSIONS TO THE ADMINISTRATIVE AUTHORITY ........ I‐11 K. CONFIDENTIAL INFORMATION ............................................................................................. I‐11 L. DOCUMENTS TO BE MAINTAINED AT THE FACILITY .............................................................. I‐11

SECTION II ‐ GENERAL FACILITY CONDITIONS ........................................................................ II‐1

A. DESIGN AND OPERATION OF FACILITY ................................................................................. II‐1 B. WASTE DISPOSAL PROHIBITED ............................................................................................. II‐1 C. WASTE AND ENVIRONMENTAL MEDIA SAMPLING AND ANALYSIS ...................................... II‐1 D. SECURITY .............................................................................................................................. II‐1 E. GENERAL INSPECTION REQUIREMENTS ............................................................................... II‐1 F. PERSONNEL TRAINING ......................................................................................................... II‐1 G. PREPAREDNESS AND PREVENTION ...................................................................................... II‐2 H. CONTINGENCY PLAN ............................................................................................................ II‐2 I. GENERAL POST‐CLOSURE REQUIREMENTS .......................................................................... II‐3 J. COST ESTIMATES FOR POST‐CLOSURE AND CORRECTIVE ACTION ...................................... II‐4 K. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION AND POST‐CLOSURE ............................ II‐4 L. LIABILITY REQUIREMENTS ................................................................................................... II‐5 M. INCAPACITY OF OWNERS OR OPERATORS, GUARANTORS, OR FINANCIAL INSTITUTIONS .. II‐5

SECTION III ‐ CORRECTIVE ACTION ....................................................................................... III‐1

A. SCOPE OF REQUIREMENTS .................................................................................................. III‐1 B. UNIT IDENTIFICATION ......................................................................................................... III‐2 C. CORRECTIVE ACTION FOR LTUs .......................................................................................... III‐9 D. INSPECTIONS AND MAINTENANCE ................................................................................... III‐10 E. FACILITY HYDROGEOLOGY AND CONCEPTUAL SITE MODEL (CSM) DEVELOPMENT ........ III‐11 F. SPECIFIC CONDITION ‐ INVESTIGATION OF AOC ‐ 2 ........................................................... III‐17 G. SPECIFIC CONDITION ‐ INVESTIGATION OF SWMU ‐ H ..................................................... III‐19 H. SPECIFIC CONDITION ‐ INVESTIGATION OF SWMU ‐ C ...................................................... III‐21 I. SPECIFIC CONDITION ‐ INVESTIGATION OF PREVIOUSLY IDENTIFIED SWMUS AND AOCS III‐22 J. SPECIFIC CONDITION ‐ INVESTIGATION OF LNAPL PLUME ............................................... III‐22



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K. SPECIFIC CONDITION ‐ INVESTIGATION OF DISSOLVED PHASE PLUME ........................... III‐27 L. SPECIFIC CONDITION ‐ LNAPL REMEDIATION PLAN ......................................................... III‐29 M. COMPLETED INTERIM MEASURES .................................................................................... III‐34

SECTION IV ‐ SPECIAL CONDITIONS PURSUANT TO THE 1984 HAZARDOUS AND SOLID WASTE AMENDMENTS (HSWA) ....................................................................................................... IV‐1

A. STANDARD CONDITIONS ..................................................................................................... IV‐1 B. SPECIFIC CONDITION ‐ INFORMATION REPOSITORY ........................................................... IV‐8 C. ADDITIONAL CORRECTIVE ACTION ..................................................................................... IV‐9 D. REPORTING REQUIREMENTS ............................................................................................ IV‐14 E. NOTIFICATION REQUIREMENTS FOR AND ASSESSMENT OF NEWLY‐IDENTIFIED SWMU(S)

AND POTENTIAL AOC(S) ..................................................................................................... IV‐15 F. NOTIFICATION REQUIREMENTS FOR NEWLY‐DISCOVERED RELEASES AT SWMU(S) AND

AOC(S) ................................................................................................................................ IV‐16 G. INTERIM MEASURES .......................................................................................................... IV‐16 H. RFI WORK PLAN ................................................................................................................. IV‐17 I. RFI IMPLEMENTATION ...................................................................................................... IV‐19 J. RFI FINAL REPORT AND SUMMARY ................................................................................... IV‐19 K. DETERMINATION OF NO FURTHER ACTION ...................................................................... IV‐20 L. CORRECTIVE MEASURES STUDY (CMS) PLAN ................................................................... IV‐21 M. CORRECTIVE MEASURES STUDY (CMS) ............................................................................. IV‐22 N. CMS FINAL REPORT AND SUMMARY ................................................................................. IV‐22 O. CORRECTIVE MEASURE (REMEDY) SELECTION AND IMPLEMENTATION .......................... IV‐23 P. RFI SCOPE OF WORK .......................................................................................................... IV‐23 Q. CMS SCOPE OF WORK ....................................................................................................... IV‐39

TABLES TABLE III.A AOII SCHEDULE FOR AOC‐2 AND SWMU‐H ....................................................... III‐19 TABLE III.B SUMMARY OF LNAPL RECOVERY SYSTEMS ....................................................... III‐32 TABLE III.C SWMU DESIGNATION AND STATUS; DEFINITION OF AREA OF CONCERN (AOC) ................................................................................................................. III‐35

TABLE 1 RFI/CMS & COMPLIANCE REPORT SUBMISSION SUMMARY



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FIGURES

FIGURE III‐A 100 YEAR FLOOD PLAIN FIGURE III‐B GROUNDWATER POTENTIOMETRIC SURFACE MAP (MAY 2011) FIGURE III‐C APPARENT LNAPL THICKNESS MAP (MAY 2011) FIGURE III‐D BENZENE CONCENTRATIONS IN GROUNDWATER (MAY 2011) FIGURE III‐E MTBE CONCENTRATIONS IN GROUNDWATER (MAY 2011) FIGURE III‐F BTEX AND MTBE CONCENTRATIONS IN GROUNDWATER (MAY 2011) PLATE III‐A 100 YEAR FLOOD PLAIN WITH TOPOGRAPHIC MAP PLATE III‐B 100 YEAR FLOOD PLAIN WITH TOPOGRAPHIC MAP, POINT OF COMPLIANCE WELLS

AND GROUNDWATER CONTOURS (MAY 2011)

PERMIT ATTACHMENTS ATTACHMENT 1 CONTINGENCY PLAN ATTACHMENT 2 POST‐CLOSURE PLAN ATTACHMENT 3 SAMPLING AND ANALYSIS PLAN ATTACHMENT 4 INSPECTION AND MAINTENANCE PLAN ATTACHMENT 5 CORRECTIVE ACTION AND POST‐CLOSURE COST ESTIMATES ATTACHMENT 6 CONSENT ORDER, CASE NO. 11‐100 (JULY 6, 2011)

Holly Refining & Marketing – Tulsa LLC, East Tulsa Refinery RCRA Post‐Closure and Corrective Action Permit


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SECTION I ‐ GENERAL PERMIT CONDITIONS

A. GENERAL The Permittee shall monitor and maintain the Facility in compliance with the provisions of the Oklahoma Hazardous Waste Management Act (OHWMA), 27A O.S. Sec. 2‐7‐101 et. seq., Oklahoma Administrative Code Title 252 Chapter 205 (OAC 252:205), the Federal Resource Conservation and Recovery Act (RCRA), including the 1984 Hazardous and Solid Waste Amendments to RCRA (HSWA), and the approved permit application as further modified through Permit Conditions set herein.

B. BASIS OF PERMIT This permit is granted based on the information submitted and the design criteria presented in the application. Any inaccuracies found in this information could provide cause for the termination or modification of this permit and for enforcement action. The Permittee is to inform the Land Protection Division of the Oklahoma Department of Environmental Quality (DEQ) of any deviation from or changes in the design or operation of the Facility which could affect the Permittee's ability to comply with the applicable regulations or permit Conditions. The term of this permit is ten (10) years. This permit shall be reviewed by the Department five (5) years after the date of permit issuance and shall be modified as necessary, as provided in 40 CFR 270.41 and 27A O. S. § 2‐7‐127(B). Except as provided in Permit Condition I.F.3. (40 CFR 270.51), the term of this permit shall not be extended by modification beyond the expiration date appearing on the face of this Permit [40 CFR 270.50(b)].

C. INCORPORATION BY REFERENCE All the referenced Code of Federal Regulations (40 CFR) Parts 124, 260 through 266, 268, and 270 as specified in the permit are, unless otherwise stated, incorporated in their entirety by OAC 252:205‐3‐1 through OAC 252:205‐3‐6, as of the date of this permit.

D. DEFINITIONS For purposes of this permit and the special conditions pursuant to HSWA, terms used herein shall have the same meaning as those in 40 CFR Parts 124, 260, 261, 264, 266, 268, and 270; and OAC 252:205‐1‐2 through OAC 252;205‐3‐6; unless this permit specifically provides otherwise. Where terms are not defined in the OAC, RCRA regulations, or the permit, a standard dictionary reference or the generally accepted scientific or industrial meaning of the term shall define the meaning associated with such terms.



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“Action Levels” means health and environmental‐based levels of constituent concentrations determined by the DEQ to be indicators for protection of human health and the environment. “Area of Concern” (AOC) means any discernable unit or area which, in the opinion of the DEQ, may have received solid or hazardous waste or waste containing hazardous constituents at any time. The DEQ may require investigation of the unit as if it were a Solid Waste Management Unit (SWMU). If shown to be a SWMU by the investigation, the AOC must be reported by the Permittee as a newly‐identified SWMU. If the AOC is shown not to be a SWMU by the investigation, the DEQ may determine that no further action is necessary and notify the Permittee in writing. “CMS” means Corrective Measures Study. “Corrective Action” means remediation as well as continued monitoring and long‐term maintenance of the SWMUs and LTUs. “DEQ” or “ODEQ” means the Oklahoma Department of Environmental Quality. “Director” means the Executive Director of the Oklahoma Department of Environmental Quality, or his/her designee or authorized representative. “Division Director” means the Director of the Land Protection Division of the Oklahoma Department of Environmental Quality, or his/her designee or authorized representative. “EPA” means the United States Environmental Protection Agency. "Facility" means all contiguous property under the control of the owner or operator seeking a Permit under Subtitle C of RCRA. “HSWA” means the 1984 Hazardous and Solid Waste Amendments to RCRA. “Hazardous constituent” means any constituent identified in Appendix VIII of 40 CFR Part 261, or any constituent identified in Appendix IX of 40 CFR Part 264. “Hazardous waste” means a solid waste that is listed or identified as a hazardous waste in 40 CFR Part 261. “Land Protection Division” (LPD) means the Land Protection Division of the DEQ. “NFA” or “No Further Action” means that no additional investigation or remediation is known to be required for a designated SWMU or AOC, or portion thereof. “NFA” status does not relieve the Permittee of continued monitoring and/or maintenance of the area or unit, as may be specified elsewhere in this permit.



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“Permit” means this permit as issued or modified, all attachments to this permit, and conditions and documents incorporated, including all state and federal rules and law referenced herein. “Permittee” means Holly Refining & Marketing, Inc. “RCRA” means the Resource Conservation and Recovery Act of 1976 as amended by HSWA in 1984. “RFA” means RCRA Facility Assessment. “RFI” means RCRA Facility Investigation. “Regional Administrator” means the Regional Administrator of EPA Region VI, or his/her designee or authorized representative. “Release” means any spilling, leaking, pouring, emitting, emptying, discharging, injecting, pumping, escaping, leaching, dumping, or disposing of hazardous wastes or hazardous constituents into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing hazardous wastes or hazardous constituents). “Solid Waste Management” means the systematic administration of activities which provide for the collection, source separation, storage, transportation, transfer, processing, treatment, and disposal of solid waste. “Solid Waste Management Unit” (SWMU) means any discernible unit at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste. Such units include any area at a facility at which solid wastes have been routinely and systematically released. The definition includes regulated units (i.e., landfills, surface impoundments, waste piles and land treatment units) but does not include passive leakage or one‐time spills from production areas and units in which wastes have not been managed (e.g., product storage areas). If, subsequent to the issuance of this permit, regulations are promulgated which redefine any of the above terms, the DEQ may, at its discretion, apply the new definition to this permit by modifying the permit in accordance with 40 CFR Section 270.41.

E. EFFECT OF PERMIT The Permittee is required to monitor and maintain the closed hazardous waste land treatment units (LTUs) in accordance with the conditions of this permit. Any storage, treatment, and/or disposal of hazardous waste not authorized in this permit is prohibited, unless exempted from permit requirements. The Permittee is also required to investigate, remediate as necessary,



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monitor, and maintain the Solid Waste Management Units, Areas of Concern, and hydrocarbon plumes identified within or subsequent to the issuance of this permit. Subject to 40 CFR 270.4, compliance with this permit generally constitutes compliance, for purposes of enforcement, with Subtitle C of RCRA. Issuance of this permit does not convey any property rights of any sort or any exclusive privilege, nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of state or local laws or regulations. Compliance with the terms of this permit does not constitute a defense to any order issued or any action brought under the OHWMA; Sections 3008(a), 3008(h), 3013, or 7003 of RCRA; Sections 104, 106(a) or 107 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9601 et seq., commonly known as CERCLA), or any other law providing for protection of public health or the environment from an imminent or substantial endangerment. [40 CFR 270.4, 270.30(g)].

F. PERMIT ACTIONS

1. Permit Modification, Revocation and Reissuance, and Termination

This permit may be modified, revoked and reissued, or terminated for cause, as specified in 40 CFR 270.41, 270.42, and 270.43. The filing of a request for a permit modification, revocation and reissuance, or termination, or the notification of planned changes or anticipated noncompliance on the part of the Permittee, does not stay the applicability or enforceability of any Permit Condition. [40 CFR 270.4(a), 270.30(f).

2. Permit Renewal

This permit may be renewed as specified in 40 CFR 270.30(b) and Permit Condition I.H.2. Review of any application for a permit renewal shall consider improvements in the state of control and measurement technology, as well as changes in applicable regulations.

3. Permit Expiration

Pursuant to 40 CFR 270.50, this permit shall be effective for a fixed term not to exceed ten

(10) years. This permit and all conditions herein will remain in effect beyond the permit's expiration date, if the Permittee has submitted a timely, complete application (see 40 CFR 270.10, 270.13 through 270.29) and, through no fault of the Permittee, the DEQ has not issued a new permit, as set forth in 40 CFR 270.51. Permits continued under this section remain fully effective and enforceable. When the Permittee is not in compliance with the conditions of the expiring or expired permit, the DEQ may choose to do any one or more of the following:

a) Initiate enforcement action based upon the permit which has been

continued;



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b) Issue a notice of intent to deny the new permit under 40 CFR 124.6. If the permit is denied, the owner or operator would then be required to cease the activities authorized by the continued permit or be subject to enforcement action for operating without a permit;

c) Issue a new permit under Part 124 with appropriate conditions; or

d) Take other actions authorized by these regulations.

4. Transfer of Permits

This permit is not transferable to any person, except after notice to the DEQ. The DEQ may require modification or revocation and reissuance of the permit pursuant to 40 CFR 270.40. Before transferring ownership or operation of the Facility during its operating life, the Permittee shall notify the new owner or operator in writing of the requirements of 27A O.S. Sec 2‐7‐109, 40 CFR Parts 264 and 270 and this permit. [40 CFR 270.30(l)(3), 264.12(c)]

G. SEVERABILITY

The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected thereby. [40 CFR 124.16(a)]

H. DUTIES AND REQUIREMENTS

1. Duty to Comply The Permittee shall comply with all conditions of this permit, except to the extent and

for the duration an emergency permit authorizes that noncompliance. Any permit noncompliance, other than noncompliance authorized by an emergency permit, constitutes a violation of OHWMA and RCRA and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. [40 CFR 270.30(a)]

2. Duty to Reapply

The Permittee shall submit a complete application for a new permit at least 180 days prior

to permit expiration. [40 CFR 270.10(h), 270.30(b)]



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3. Biennial Report

The Permittee shall comply with the biennial reporting requirements of OAC 252:205‐3‐2(d) and 40 CFR 262.41.

4. Need to Halt or Reduce Activity Not a Defense It shall not be a defense for the Permittee, in an enforcement action, that it would have

been necessary to halt or reduce the Permitted activity in order to maintain compliance with the conditions of this permit. [40 CFR 270.30(c)]

5. Duty to Mitigate

In the event of noncompliance with this permit, the Permittee shall take all reasonable

steps to minimize releases to the environment and shall carry out such measures as are reasonable to prevent significant adverse impacts on human health or the environment. [40 CFR 270.30(d) and OAC 252:205‐9‐1]

6. Proper Operation and Maintenance

The Permittee shall at all times properly operate and maintain all facilities and systems of

treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance/quality control procedures. This provision requires the operation of back‐up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this permit. [40 CFR 270.30(e)]

7. Duty to Provide Information

The Permittee shall furnish to the DEQ, within a reasonable time, any relevant

information which the DEQ may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The Permittee shall also furnish to the DEQ, upon request, copies of records required to be kept by this permit. [40 CFR 270.30(h)]

8. Inspection and Entry

Pursuant to 40 CFR 270.30(i), the Permittee shall allow the DEQ, or an authorized representative, upon the presentation of credentials and other documents, as may be required by law, to:



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a) Enter at reasonable times upon the Permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit;

b) Have access to and copy, at reasonable times, any records that

must be kept under the conditions of this permit;

c) Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and

d) Sample or monitor, at reasonable times, for the purposes of

assuring permit compliance or as otherwise authorized by RCRA, any substances or parameters at any location.

9. Monitoring and Records

Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. The method used to obtain a representative sample of the material to be analyzed must be the appropriate method from Appendix I of 40 CFR Part 261 or an equivalent method approved by the DEQ. Laboratory methods must be those specified in the most recent edition of Test Methods for Evaluating Solid Waste: Physical/Chemical Methods SW‐846, Standard Methods of Wastewater Analysis, or an equivalent method approved in writing by the DEQ. [40 CFR 270.30(j)(1)]

The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports and records required by this permit, the certification required by 40 CFR 264.73(b)(9), and records of all data used to complete the application for this permit for a period of at least three (3) years from the date of the sample, measurement, report, record, certification, or application. These periods may be extended by request of the DEQ at any time and are automatically extended during the course of any unresolved enforcement action regarding this Facility. The Permittee shall maintain records from all groundwater monitoring wells and associated groundwater surface elevations for the active life of the Facility and for disposal facilities for the post‐closure care period as well. [40 CFR 270.30(j)(2)]



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Pursuant to 40 CFR 270.30(j)(3), records of monitoring information shall specify:

i. The date(s), exact place, and times of sampling or measurements;

ii. The individual(s) who performed the sampling or measurements;

iii. The date(s) analyses were performed;

iv. The individual(s) who performed the analyses;

v. The analytical techniques or methods used; and

vi. The results of such analyses.

10. Reporting Planned Changes The Permittee shall give notice to the DEQ, as soon as possible, of any planned physical

alterations or additions to the LTUs or SWMUs that are subject to corrective action.[40 CFR 270.30(l)(1)]

11. Reporting Anticipated Noncompliance

The Permittee shall give advance notice to the DEQ of any planned changes to the LTUs

and SWMUs that are subject to further corrective action, or to activities regarding such units, which may result in a material noncompliance with permit requirements. [40 CFR 270.30(l)(2)]

12. Monitoring Reports [40 CFR 270.30 (l)(4)]

a) The Permittee shall conduct the sampling at the intervals specified

in this permit.

b) The Permittee shall submit Semi‐Annual Reports within or on forty five (45) days following the end of each sixth month period. The six month periods end on June 30 & December 31, where as, the Semi‐Annual Reports would be submitted by February 15th and August 15th, annually.



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13. Compliance Schedules Reports of compliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than fourteen (14) days following each schedule date. [40 CFR 270.30 (l)(5)]

14. Twenty‐Four Hour Reporting [40 CFR 270.30(l)(6) and OAC 252:205‐13‐1]

a) The Permittee shall report to the DEQ any noncompliance

which may endanger health or the environment. Any such information shall be reported orally within twenty‐four (24) hours from the time the Permittee becomes aware of the circumstances. The Permittee is not required to notify the DEQ of a release if it is completely contained within 24 hours, or is less than 25 gallons. The report shall include the following:

(1) Information concerning release of any hazardous

waste that may cause an endangerment to public drinking water supplies;

(2) Any information of a release or discharge of

hazardous waste, or of a fire or explosion at the hazardous waste management facility which could threaten the environment or human health outside the Facility.

b) The description of the occurrence and its cause shall include:

(1) Name, address, and telephone number of the owner

or operator;

(2) Name, address, and telephone number of the Facility;

(3) Date, time, and type of incident;

(4) Name and quantity of materials involved;

(5) The extent of injuries, if any;



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(6) An assessment of actual or potential hazards to the environment and human health outside the facility, where this is applicable; and

(7) Estimated quantity and disposition of recovered

material that resulted from the incident.

c) A written submission shall also be provided within five (5) days of the time the Permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance and its cause; the period(s) of noncompliance (including exact dates and times); whether the noncompliance has been corrected; and, if not, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. The DEQ may waive the five‐day written notice requirement in favor of a written report within fifteen (15) days.

15. Other Noncompliance

The Permittee shall report all other instances of noncompliance not otherwise required to

be reported under Permit Conditions (I.H.1 through 13), at the time monitoring reports are submitted. The reports shall contain the information listed in Permit Condition I.H.14. [40 CFR 270.30(l)(10)]

16. Other Information

Whenever the Permittee becomes aware that it failed to submit any relevant facts in the

permit application, or submitted incorrect information in a permit application or in any report to the DEQ, the Permittee shall promptly submit such facts or information. [40 CFR 270.30(l)(11)]

I. SIGNATORY REQUIREMENT

All applications, reports, or information submitted to or requested by the DEQ, his designee, or authorized representative, shall be signed and certified in accordance with 40 CFR 270.11 and 270.30(k).



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J. REPORTS, NOTIFICATIONS, AND SUBMISSIONS TO THE ADMINISTRATIVE AUTHORITY

All reports, notifications, or other submissions which are required by this permit to be sent or given to the DEQ should be sent by certified mail, overnight delivery, electronic mail or hand delivery to: Saba Tahmassebi, Ph.D., P.E., Chief Engineer Land Protection Division Oklahoma Department of Environmental Quality 707 N. Robinson, P.O. Box 1677 Oklahoma City, Oklahoma 73101‐1677 Phone Number (405) 702‐5100

K. CONFIDENTIAL INFORMATION In accordance with 40 CFR 270.12 and OAC 252: 4‐1‐5(d) and OAC 252:205‐1‐4, the Permittee may claim confidential any information required to be submitted by this permit. Any such claim must be asserted at the time of submission in the manner prescribed on the application form or instructions, or in the case of other submissions, by stamping the words “confidential business information” on each page containing such information. If no claim is made at the time of the submission, EPA and DEQ may make the information available to the public without further notice. If a claim is asserted, the information will be treated in accordance with the procedures in 40 CFR Part 2 (Public Information). Claims of confidentiality for the name and address of any permit applicant or Permittee will be denied.

L. DOCUMENTS TO BE MAINTAINED AT THE FACILITY The Permittee shall maintain at the Facility, until corrective action is completed and certified by an independent, registered professional engineer, the following documents and all amendments, revisions and modifications to these documents:

1. Contingency Plan, as required by 40 CFR 264.53(a) and this permit (See Permit Attachment 1); this Plan need only be maintained at the Facility until three (3) years after all SWMUs and/or regulated units are certified as closed or remediated, and such certifications are accepted by the DEQ.

2. Post‐Closure Plan, as required by 40 CFR 264.118(a) and this permit (See Permit Attachment 2);



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3. Sampling and Analysis Plan, as required by 40 CFR 264.97(d) and this permit (See Permit Attachment 3);

4. Inspection and Maintenance Plan, as required by 40 CFR 264.15(b)(2) and this permit (See Permit Attachment 4);

5. Annually‐adjusted cost estimate for corrective action measures and post‐

closure activities as required by 40 CFR 264.144(d) (See Permit Attachment 5);

6. Operating record, as required by 40CFR 264.73 and this permit; and

7. All other documents required by Section I, Permit Condition H.10.



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SECTION II ‐ GENERAL FACILITY CONDITIONS

A. DESIGN AND OPERATION OF FACILITY The Permittee shall maintain the LTUs, SWMUs and AOCs subject to this permit to minimize the possibility of a fire, explosion, or any unplanned, sudden or nonsudden release of hazardous waste constituents to air, soil, groundwater, or surface water which could threaten human health or the environment, as required by 40 CFR 264.31 and OAC 252:205‐9‐1.

B. WASTE DISPOSAL PROHIBITED

The Permittee shall not dispose of any hazardous waste on‐site. Hazardous wastes generated at the Facility may be temporarily stored on‐site as specified in 40 CFR 262.34.

C. WASTE AND ENVIRONMENTAL MEDIA SAMPLING AND ANALYSIS

The Permittee shall follow the sampling and analysis procedures as outlined in the Sampling and Analysis Plan (SAP) provided as Permit Attachment 3. The analysis of all samples (waste, water, soils, etc.) is to be conducted in accordance with Permit Attachment 3. At a minimum, the Permittee shall maintain proper functional instruments, use approved sampling and analytical methods, verify the validity of sampling and analytical procedures, and perform correct calculations. If the Permittee uses a contract laboratory to perform analyses, then the Permittee shall inform the laboratory in writing that it must operate under the sample analysis conditions set forth in this permit.

D. SECURITY The Permittee shall comply with the security provisions of 40 CFR 264.14(b) and (c) and Permit Attachment 1.

E. GENERAL INSPECTION REQUIREMENTS The Permittee shall follow the inspection schedule set out in Permit Attachment 4. The Permittee shall remedy any deterioration or malfunction discovered by an inspection, as required by 40 CFR 264.15(c). Records of inspections shall be kept, as required by 40 CFR 264.15(d).

F. PERSONNEL TRAINING The Permittee shall ensure that all personnel performing functions involving hazardous waste are properly trained for the duties performed in accordance with 40 CFR 264.16. A description of the required training for personnel, and documents and records listing all relevant training



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received, shall be maintained at the Facility as required by 40 CFR 264.16(d) and (e). These records shall be made available for inspection by DEQ personnel upon request.

G. PREPAREDNESS AND PREVENTION

1. Required Equipment At a minimum, the Permittee shall maintain at the Facility the equipment set forth in

Permit Attachment 1, as required by 40 CFR 264.32.

2. Testing and Maintenance of Equipment The Permittee shall test and maintain the equipment specified in Permit Condition

II.G.1, as necessary, to assure its proper operation in time of emergency, as required by 40 CFR 264.33.

3. Access to Communications or Alarm System

The Permittee shall maintain access to the communications or alarm system, as required

by 40 CFR 264.34.

4. Arrangements with Local Authorities The Permittee shall maintain arrangements with state and local authorities, as required

by 40 CFR 264.37. If state or local officials refuse to enter into preparedness and prevention arrangements with the Permittee, the Permittee must document this refusal in the operating record.

H. CONTINGENCY PLAN

1. Implementation of Plan

The Permittee shall immediately carry out the provisions of the Contingency Plan,

Permit Attachment 1, whenever there is a fire, explosion, or release of hazardous waste or constituents which could threaten human health or the environment.

2. Copies of Plan

The Permittee shall maintain and distribute copies of the Contingency Plan consistent

with the requirements of 40 CFR 264.53.



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3. Amendments to Plan The Permittee shall review and immediately amend, if necessary, the Contingency Plan,

as required by 40 CFR 264.54. Such amendment may require permit modification in accordance with 40 CFR 270.42.

4. Emergency Coordinator

A trained emergency coordinator/Qualified Individual shall be available at all times in case of an emergency, as required by 40 CFR 264.55. The primary Emergency Coordinator/Qualified Individual(s) for the Facility is as follows: Mr. Joe Bennett, Fire Chief (918)‐594‐6492 I. GENERAL POST‐CLOSURE REQUIREMENTS

1. Post‐Closure Care Period

The Permittee began post‐closure care for the FALTU on April 1, 1993 and for the

WGLTU on November 4, 2009 after completion of closure of the units. The Permittee shall maintain the Facility in accordance with 40 CFR 264.117 and Permit Attachment 2 until certification of completion of post‐closure.

2. Post‐Closure Security

The Permittee shall maintain security at the Facility during the post‐closure care period by posting a sign with the legend, “Danger ‐ Unauthorized Personnel Keep Out” or equivalent language at each entrance to the Facility. The legend must be written in English and must be legible from a distance of at least 25 feet. [40 CFR 264.14 (c)]

3. Amendment to Post‐Closure Plan The Permittee shall amend Permit Attachment 2 in accordance with 40 CFR 264.118(d),

whenever necessary.

4. Post‐Closure Notices

The Permittee shall request and obtain a permit modification prior to post‐closure removal of hazardous wastes, hazardous waste residues, liners, or contaminated soils, in accordance with 40 CFR 264.119(c).



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J. COST ESTIMATES FOR POST‐CLOSURE AND CORRECTIVE ACTION

1. The Permittee's most recent post‐closure cost estimate, prepared in accordance with 40 CFR 264.142, 264.144, 264.197(c)(3) and (5), 264.228(c)(2), and 264.258(c)(2), is specified in Permit Attachment 5.

2. The Permittee must revise the post‐closure cost estimate whenever there

is a change in the Facility's Post‐Closure Plan, as required by 40 CFR 264.144(c).

3. Within sixty (60) days of DEQ’s approval of any new corrective measure

for an LTU, SWMU, or AOC, the Permittee shall submit a cost estimate consistent with 40 CFR 264.145. Within sixty (60) days of DEQ approval of such cost estimate, the Permittee shall update the financial assurances to include the estimated costs.

4. The cost estimates shall be adjusted annually consistent with 40 CFR

264.144 and 264.145.

K. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION AND POST‐CLOSURE The Permittee shall demonstrate continuous compliance with 40 CFR 264.145 by providing documentation of financial assurance, as required by 40 CFR 264.151 or 264.149, in at least the amount of the cost estimates required by Permit Condition II.J. Changes in financial assurance mechanisms must be approved by the DEQ pursuant to 40 CFR 264.145 or 264.149. The Permittee shall maintain financial assurance for the well gauging network and point of compliance (POC) wells identified in the sampling and analysis plan (SAP) (Permit Attachment 3), for the LNAPL Containment Systems identified in Condition III.K.1.a, and the remedial measures that maintain the integrity and covers of the LTUs and SWMUs, all of which shall be collectively referred to as the “Current Corrective Measures.” The Permittee shall maintain financial assurance under this Condition II.K during the ten (10) year term of this permit and any period of continuance prior to re‐issuance. In all other respects, the financial assurance shall be consistent with all applicable requirements of 40 CFR Part 264 Subpart H [40 CFR 264.145], including the following:

1 . The Permittee has submitted updated cost estimates for the financial assurance required by Condition II.J., which, subject to any changes required by Conditions II.J.2, 3 or 4 and Condition II.K, shall be used as the basis of the financial assurance. Within one hundred and twenty (120) days of the effective date of this permit, the Permittee shall update the financial assurance to cover the updated cost estimates.



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2 . The DEQ may approve a decrease in the cost estimate for the financial

assurance mechanism if the owner or operator demonstrates to the DEQ that the amount of the cost estimate exceeds the remaining cost of the Current Corrective Measures or any new corrective measures [40 CFR 264.145(f)(9)].

3 . The owner or operator is no longer required to submit the specified items

[40 CFR 264.145(f)(3)] necessary to demonstrate he/she meets the financial test when the requirements of 40 CFR 264.145(f)(10) are met.

L. LIABILITY REQUIREMENTS Because all hazardous waste management units subject to permitting, i.e., the LTUs, have been certified as closed, and such certifications have been accepted by the DEQ, under 40 CFR 264.147(e), the Permittee is no longer required to maintain liability coverage for sudden and non sudden accidental occurrences.

M. INCAPACITY OF OWNERS OR OPERATORS, GUARANTORS, OR FINANCIAL INSTITUTIONS

The Permittee shall comply with 40 CFR 264.148, whenever necessary.



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SECTION III ‐ CORRECTIVE ACTION

A. SCOPE OF REQUIREMENTS This Section addresses the corrective action that is required for the closed Land Treatment Units (LTUs), an identified Solid Waste Management Unit (SWMU), an Area of Concern (AOC), and any newly‐identified SWMUs and potential AOCs. Additional investigation requirements for the dissolved phase plume(s) and the Light Non‐Aqueous Phase Liquids (LNAPL) plume beneath the Facility are also presented in this section. The corrective action requirements for the Holly Tulsa East Refinery include:

1. additional investigations of AOC‐2 and SWMU‐H;

2. additional investigation at SWMU‐C;

3. additional investigations to further characterize and define the Light Non‐Aqueous Phase Liquids (LNAPL) plume(s) beneath the Facility;

4. additional investigations to further characterize and define the dissolved phase plume(s) beneath the Facility;

5. groundwater permit compliance monitoring;

6. development of groundwater media protection standards;

7. development of an LNAPL Site Conceptual Model (LSCM);

8 . development and implementation of an appropriate LNAPL Remediation

Plan; and

9. financial assurance for corrective measures. An aerial map of the Facility showing the Facility property boundary in relation to the 100 year floodplain is provides as Figure III‐A at the end of Permit Section IV. A larger scale topographic map showing the locations of LTUs, pertinent Facility features and topographic features within a 1,000‐ft buffer surrounding the Facility property boundary is provided as Plate III‐A. The LTUs, SWMUs and AOCs are identified as described below.



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B. UNIT IDENTIFICATION

1 . Land Treatment Units (LTUs)

The Flare Area LTU (FALTU) and the Walnut Grove LTU (WGLTU) are closed hazardous waste LTUs located entirely within the secured boundaries of the Holly Tulsa East Refinery. The LTU areas have been the locations of land farming operations since the early 1900’s. Historically applied wastes consisted of liquid, sludge and solid residues from various refinery operations. The Permittee shall provide post‐closure care for the Flare Area and Walnut Grove LTUs in accordance with Attachment 2 of this permit.

a. The Flare Area LTU (FALTU) is located in the southeast corner of the

Refinery in Section 23 of T 19 N, R 12 E and is located entirely within the secured boundaries of the Holly Tulsa East Refinery. The historically active portion of the FALTU was approximately 29 acres in size. The area surrounding the FALTU is industrial to the north, east, and west, and residential to the south. The American Electric Power (AEP) property borders the FALTU on the east; railroad spurs border the LTU on the west with Refinery property further west of the tracks and north of the LTU.

b. The most recent RCRA Post‐Closure Permit for the FALTU, Permit #

990750960‐PC, was renewed on July 2, 2008. This permit was a renewal from a previous FALTU post‐closure permit which had an effective date of May 26, 1995. A Certificate of Closure for the FALTU was submitted by Sinclair on March 3, 1993 in accordance with 40 CFR 264.115 and the Closure Plan was implemented. The FALTU was officially closed and post‐closure care began on April 1, 1993, after submittal of the required Notice of Closure Report and fulfilling applicable regulatory requirements. A total of approximately eighteen (18) years of post‐closure monitoring activities have been completed at the FALTU. Copies of the Closure Documents for the FALTU are enclosed at the end of Permit Section IV.

c. The FALTU is divided into three (3) application plots, with separate

background area(s). The wastes that were historically disposed of at the FALTU were refinery wastes D001, D008, and K049 through K052. No wastes have been reportedly applied to the FALTU since February 1988.

d. The Walnut Grove LTU (WGLTU) is located in the northeast corner

of the Refinery in Section 14 of T 19 N, R 12 E and is located entirely within the secured boundaries of the Holly Tulsa East Refinery. The



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historically active portion of the WGLTU was approximately 20 acres in size. The area surrounding the WGLTU is industrial to the north, west and south, with Refinery property located to the west and south of the LTU. The Arkansas River levee and Arkansas River are located directly to the east of the LTU.

The WGLTU was issued a permit to operate (Permit # 990750960‐

OP) as a hazardous waste LTU on December 10, 1998; the WGLTU operating permit expired on December 10, 2008. A Certificate of Closure was approved by the DEQ on November 4, 2009 and post‐closure care began at this time. Post‐closure activities at the WGLTU have been conducted in accordance with the Post‐Closure Plan contained in the expired WGLTU Operating permit # 990750960‐OP. A total of approximately two (2) years of post‐closure monitoring activities have been completed for the WGLTU. Copies of the Closure Documents for the WGLTU are enclosed at the end of Permit Section IV.

The WGLTU is divided into four (4) application plots, with separate

background area(s). The disposal of some characteristic listed wastes was banned from land disposal at the WGLTU on November 8, 1990. Wastes that have been reportedly applied to the WGLTU since 1990 have been non‐hazardous wastes from various refinery sources that have been tested for ignitibility, corrosivity, reactivity, and toxicity characteristics and found to be characteristically non‐hazardous.

2 . The SWMUs are identified as:

a. SWMU A (Former Land Farm) was identified as a SWMU by the USEPA in 1984 as a result of a Facility Site Inspection. SWMU‐A reportedly was used for the disposal of rust scale from unleaded tank bottoms from 1947 – 1970. Lead (Pb) and chromium (Cr) have been identified in the subsurface soils at SWMU‐A. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.” The SWMU A status is closed as a result of this determination.



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b. SWMU B (Former Land Farm) was identified as a SWMU by the EPA in 1984 as a result of a Facility Site Inspection. SWMU‐B historically received oily tank bottom sludges until 1966 and was the reported location of a one time crude oil spill. Pb and Cr have been identified in the subsurface soils at the SWMU. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.” The SWMU B status is closed as a result of this determination.

c. SWMU C (Former Land Farm; Tetraethyl Lead (TEL) Area) was

identified as a SWMU by the EPA in 1984 as a result of a Facility Site Inspection. Originally described as a one‐acre size site, SWMU‐C historically received leaded tank bottom sludges in 1973. Pb has been identified in the subsurface soils at the SWMU. Although SWMU C had previously received closure status from the DEQ as a result of the Sinclair Phase 2 report, it was reopened and the boundaries of SWMU‐C were expanded by approximately 11.3 acres in August 2008. The SWMU‐C boundaries were expanded to incorporate additional areas impacted by elemental mercury (Hg), Pb, and petroleum hydrocarbons identified during a Sinclair geotechnical investigation in support of a new sulfur unit in July 2008. DEQ requested a work plan to address the elemental Hg. The work plan was submitted by Sinclair in June 2009 and approved by DEQ in October 2009. Holly conducted investigation activities and impacted soil removal actions in December 2009 and in February 2010. A summary report was submitted to DEQ on June 13, 2010. The report concluded that no visible elemental Hg remained in the investigation area, and the elemental Hg impact was localized and appeared to be of limited extent. However, soil sampling in the area post soil removal indicated that Hg impacted soils were still present above USEPA risk based industrial soil screening levels. The DEQ response letter dated August 15, 2011 (received by Holly on September 9, 2011) noted additional measures that Holly must take if follow‐up investigation and corrective actions were not performed. Holly plans for additional investigations to be performed for the applicable chemicals of concern (COCs). An investigative work plan will be submitted in the schedule outlined in



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Permit Condition III.H.2. (Specific Condition – SWMU‐C Investigation).

d. SWMU D (Former Landfill; Off‐Unit Storm Pond) was identified as a SWMU by the EPA in 1984 as a result of a Facility Site Inspection. Originally described as a five‐acre size site, SWMU‐D reportedly historically received oily tank bottoms and heat bundle cleaning sludges sometime prior to 1947 and until 1976. These wastes were reportedly excavated and land farmed at the FALTU. SWMU‐D is now occupied by an active storm water holding reservoir lined with a four‐inch thick clay layer. Pb and Cr had been identified in the groundwater adjacent to SWMU‐D. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.” The SWMU D status is closed as a result of this determination.

e. SWMU E (Former Landfill; current Waste Water Treatment Plant

(WWTP)) was identified as a SWMU by the EPA in 1984 as a result of a Facility Site Inspection. Originally described as a five‐acre size site, SWMU‐E reportedly was an active landfill where American Petroleum Institute (API) separator sludge was disposed of sometime prior to 1947 and ending in 1976. These wastes have been reportedly excavated and land farmed at the FALTU. Currently, SWMU‐E houses the Refinery WWTP including the On‐unit Storm Pond, two API separators and tanks 400 and 401 (designated as slop oil tanks). In July 2008, additional waste materials were reportedly encountered during the cleaning of the north storm water pond located at the WWTP. The boundaries of SWMU‐E were subsequently expanded to include the newly identified impacted areas. It is not feasible to perform current investigations at SWMU‐E due to on‐going refinery operations. Further investigation of SWMU‐E will be proposed when the Refinery ceases operations or the WWTP is taken out of permanent service.

f. SWMU F (Former Land Farm) was identified as a SWMU in October 2004 as a result of refinery construction activities related to the installation of new naphtha hydrotreater equipment. Solid waste



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material, identified as coke, was found approximately three feet below ground surface (bgs) inside an old concrete foundation. A total of approximately 3,875 cubic yards of waste material was reportedly excavated from SWMU‐F and disposed of off‐site. It is not feasible to perform current investigations at SWMU‐F due to on‐going refinery operations. Further investigation of SWMU‐F will be performed when the Refinery ceases operations or the naphtha hydrotreater and associated units are taken out of permanent service.

g. SWMU G (Former Land Farm; Alky Unit) was identified as a SWMU in August 2007 as a result of Refinery personnel evaluating the integrity of buried sections of the process wastewater sewer system located at the alky unit. Impacted soils were observed as a result of cracks and other openings in one of the drain lines connecting to the sewer. The main sewer is comprised of approximately 1,266 linear feet of pipe. The excavated drain and feeder lines were reported to be approximately 120 feet in length. It is not feasible to perform current investigations at SWMU‐G due to on‐going refinery operations. Further investigation of SWMU‐G will be proposed when the Refinery ceases operations or the Alky Unit is taken out of permanent service.

h. SWMU H (Former Waste Disposal Site) was identified as a SWMU in May 2008 when buried drums were discovered during Refinery landscaping and grading activities. An approximate 9.5 acre tract of land adjacent to the Arkansas River located between the east tank farm fence and the east property fence was slated for public access under the management of the River Parks Authority. Prior to opening the area to the public, landscaping activities encountered a patch of tar‐like material and debris. The waste materials were excavated to a depth of approximately three‐foot below the ground surface. Reportedly during excavation activities deteriorated drums, petroleum impacted soils and potential asbestos containing materials (ACM) were identified. Additionally, it was reported that the City of Tulsa encountered over 150 buried drums during the installation of a sewer line in the same approximate area in 1991. Employees from former Refinery operations indicated a portion of SWMU‐H was apparently used as a waste disposal site. Reportedly shallow pits approximately 18 to 20‐feet wide by approximately 20 to 25‐feet long and 8 to 12‐feet deep were dug and then filled with a variety of waste material (e.g., asbestos, wood scraps, glass, scrap metal, dirt, bricks, coke, gunite, spent catalyst, resid materials, and tank bottoms). The disposal area was apparently operational prior to 1951 and closed sometime prior to 1982.



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Sinclair notified DEQ on June 13, 2008 of encountering buried solid waste in this area and, on July 18, 2008, they received a request from DEQ to submit an investigation work plan. Sinclair submitted a preliminary investigative work plan to DEQ in August 2008. The initial two phases of the work plan proposed historical aerial photo review and a geophysics survey. The historical aerial photo and geophysics survey report for SWMU‐H was submitted to DEQ on February 25, 2010. The report detailed eleven geophysical anomalies in the southern portion of SWMU‐H including one anomaly that extended to the eastern fence line. The historical aerial photo review from 1958 depicts a disturbance in the northeastern portion of the SWMU that was outside the geophysical survey area. DEQ approved the preliminary assessment report on March 26, 2010. Holly discussed investigation approaches for SWMU‐H with the DEQ on February 15th, 2011. Holly also reviewed the current site knowledge and data gaps related to the Facility conceptual site model (CSM). DEQ then requested that Holly submit a formal work plan for phased investigations at SWMU‐H and AOC‐2. Holly submitted an Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H to the DEQ on May 15, 2011. DEQ approved the investigation work plan as submitted in correspondence dated June 28, 2011. Investigation activities are anticipated to begin at SWMU‐H in the fall of 2011.

3 . The Areas of Concern (AOCs) are identified as:

a. AOC 1 (Former Landfill; Dredge Pond) was a naturally occurring pond used to dispose of spent catalyst from a fluid catalytic cracking unit. The AOC was designated a SWMU resulting from the disposal of spent catalyst and tank bottom wastes; associated impacts were Pb and hydrocarbons. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.” The AOC‐1 status is closed as a result of this determination.

b. AOC 2 (Former Union Pacific Railroad Property) was identified as a

SWMU in July 22, 2008 as a result of refinery construction activities



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and was described as an approximate 0.4 acre site. Solid waste was encountered in two excavations during the rerouting of an off‐unit storm water line. The buried waste was located in a triangular portion of property located south of the Refinery’s WWTP and northeast of the Refinery’s off‐unit storm water pond. Sinclair purchased the triangle piece of property from Union Pacific Railroad in 2008. The buried waste was encountered near the surface to depths ranging from approximately four to six feet bgs. The waste was comprised primarily of fire brick, scrap metal, construction debris, glassware, insulation and asbestos containing materials. Asbestos was subsequently removed from an excavation in AOC‐2 that was approximately 600 feet long by 30 feet wide by five to six feet deep; the ACM was reportedly properly disposed off‐site. Additional non‐ACM soil was removed from the subsurface in this area and is stockpiled within the boundaries of AOC‐2. Sinclair notified DEQ in July 2008 that they encountered buried solid waste in this area. In an October 2008 letter, DEQ requested that Sinclair submit an RCRA Facility Investigation (RFI) work plan. Sinclair submitted a preliminary investigative work plan to DEQ on April 6, 2009. The initial two phases of the work plan proposed historical aerial photo review and a geophysics survey. The historical aerial photo and geophysics survey report for AOC‐2 was submitted to DEQ on February 25, 2010. The report detailed several geophysical anomalies located inside the AOC‐2 area including an anomaly that extends outside the geophysical survey area along the northwestern portion of AOC‐2. DEQ approved the preliminary assessment report on March 26, 2010. Holly also identified an oil seep on the ground surface in a remote area of AOC‐2 during a pre‐investigation site inspection. The oil seep has been located on the Facility base map and will be further investigated as part of the future LNAPL investigation. Holly discussed investigation approaches for AOC‐2 with the DEQ on February 15th, 2011. Holly also reviewed the current site knowledge and data gaps related to the Facility CSM. DEQ then requested that Holly submit a formal work plan for a phased investigation at SWMU‐H and AOC‐2. Holly submitted an Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H to the DEQ on May 15, 2011. DEQ approved the investigation work plan as submitted in correspondence dated June 28, 2011. Investigation activities are anticipated to begin at AOC‐2 in the early fall of 2011.



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C. CORRECTIVE ACTION FOR LTUs

1. Pursuant to 40 CFR 264.90(f), 264.110(c), 264.118(b)(4) and (d)(2), and 264.140(d), which have been incorporated by reference at OAC 252:205‐3‐2(f), DEQ may replace all or part of the post‐closure requirements of 40 CFR 264.91 through 264.100 applying to the regulated LTUs with alternative requirements for groundwater monitoring and corrective action, including financial responsibility, where DEQ determines, as it has, that:

a. The regulated LTUs are situated among solid waste management

units (or areas of concern), a release has occurred, and both the regulated LTUs and one or more SWMUs or AOCs are likely to have contributed to the release; and

b. It is not necessary to apply the groundwater monitoring and

corrective action requirements of subsections 264.91 through 264.100 because alternative requirements will protect human health and the environment.

Accordingly, instead of the post‐closure care requirements at 40 CFR

264.91 through 264.100, the Permittee shall conduct groundwater monitoring and corrective action, including financial responsibility, for the LTUs in the same manner as for the SWMUs and AOCs as summarized in Table III.B. and as specified in this permit.

2. The Permittee shall implement the Post‐Closure Plan, Attachment 2. 3. The Permittee shall implement the Inspection and Maintenance Plan,

Attachment 4. 4. The Permittee shall not allow any use of the units designated in Permit

Condition III.B.1 which will disturb the integrity of the final cover, any components of the containment system, or the function of the Facility’s monitoring systems. [40 CFR 264.117(c)]

5. The Permittee shall comply with the requirements for land treatment

units as follows: [40 CFR 264.280(c)]

a. Continue any operations necessary to enhance degradation and transformation and sustain immobilization of hazardous constituents in the treatment zone to the extent that such measures are consistent with other corrective action activities;



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b. Maintain a vegetative cover over closed portions of the Facility [40 CFR 264.280(c)(2)];

c. Maintain the run‐on control system required under 40 CFR

264.273(c); d. Maintain the run‐off management system required under 40 CFR

264.273(d); e. Control wind dispersal of hazardous waste as required under

40 CFR 264.273(f); and f. Continue to comply with any prohibitions or conditions

concerning growth of food‐chain crops required under 40 CFR 264.276.

6. The Permittee shall inspect the LTUs on a semi‐annual basis and after all

significant storm events, as required in the Consent Order (Case No.11‐100 dated July 6, 2011), Item 14.

7. The Permittee may irrigate the LTUs as necessary to maintain the

appropriate vegetative cover including using treated effluent from the WWTP as an irrigation source. Additionally, non‐hazardous clarifier sludge (biosludge) may be applied to the vegetative cover as a nutrient source for fertilization and a supplemental supply of irrigation water. The following conditions will apply:

a. The Permittee shall evaluate the effects of the irrigation at least

annually and shall report this evaluation in the appropriate semi‐annual monitoring report; and

b. Parameters that will be evaluated include groundwater elevation,

flow, and quality and condition of the vegetative cover.

D. INSPECTIONS AND MAINTENANCE

1 . The Permittee shall inspect the components, structures, and equipment at the site in accordance with the Inspection Schedule, Permit Attachment 4. [40 CFR 264.117(a)(1)(ii)]

2 . The Permittee shall comply with the following requirements for all identified LTUs which have waste left in place:



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a. Maintain the integrity and effectiveness of the final cover, including making repairs to the cap, as necessary, to correct the effects of settling, subsidence, erosion, or other events;

b. Continue to operate the LNAPL recovery system(s) designated in the August 2011 semi‐annual monitoring report or equivalent systems at the discretion of the Permittee until the LNAPL investigation is completed, the LCSM has been developed, and DEQ has approved the Facility LNAPL remediation plan; and

c. Prevent run‐on and run‐off from eroding or otherwise damaging the final cover.

3 . The Permittee shall maintain the groundwater monitoring system

required in the Sampling and Analysis Plan (SAP), Attachment 3.

E. FACILITY HYDROGEOLOGY AND CONCEPTUAL SITE MODEL (CSM) DEVELOPMENT

1. As required by 40 CFR 270.14(c)(2), relevant hydrogeologic information for the Facility is provided herein, based upon work completed for the RCRA Hazardous Waste Facility Part B Permit Application, Sinclair Oil Corporation (1984). The information presented herein can also be found in the RCRA Facility Investigation Preliminary Report (RFI), Sinclair Oil Company 1988 as well as the RCRA Facility Assessment Preliminary Review/Visual Site Inspection (RFA), Sinclair Oil Company 1987 and represents data collected during field exercises in September of 1981. Additionally, data collected in support of the semi‐annual monitoring reports (SMR) throughout the years and new well installations are presented herein.

a. Hydrogeologic Characteristics The alluvial sandy material beneath the Facility is saturated at

depths of about 8 to 15 feet, forming the uppermost unconfined aquifer. The alluvium ranges in thickness from 18 to 34 feet and grades from finer sands near the ground surface to coarse sand near the bedrock interface. The upper most bedrock formation beneath the Facility is the Seminole Formation which consists of basal sandstone, a lower shale zone, middle sandstone, and upper shale containing one or more sandstone units. The LTUs are underlain by a sandstone unit of the Seminole Formation. According to permit language provided in Sinclair’s previous Hazardous Waste Facility Part B permit Applications, the uppermost aquifer is not hydraulically connected to the underlying aquifers. The principal source of groundwater recharge is rainfall. The water table tends to fluctuate in response to rainfall, evapotranspiration, and discharge



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to the Arkansas River. The annual cycle of water levels reflects the seasonal variation in precipitation and other climatic factors. Natural groundwater movement has been repeatedly measured from mapping the potentiometric surface of the groundwater. Groundwater generally flows to the east/southeast toward and discharges to the Arkansas River. The potentiometric map created for the August 2011 SMR is provided as Figure III‐B. The potentiometric surface map indicates a groundwater flow direction of east/southeast at a hydraulic gradient of approximately 0.003 ft/ft.

Transmissivity, hydraulic conductivity, and storage coefficients were

calculated based on drawdown observations from monitoring wells during historical pumping tests. Pumping tests were reportedly conducted at wells WTP‐1 and WTP‐4 in September 1981 that yielded transmissivities, hydraulic conductivities, and storage coefficients of 48,000 (gpd/ft), 4800 (gpd/ft2) and 0.07 for WTP‐1 and 70,000 (gpd/ft), 5400 (gpd/ft2) and 0.01 for WTP‐4, respectively. Additional tests were performed in October 1981 after it was determined that gravity drainage effects were observed. A 24‐hour pump test was performed at well WTP‐4 at a flow rate of 75 gpm and a drawdown of 2.7 feet was observed. Data collected for the 24‐hour test yielded an average hydraulic conductivity of 4,500 gpd/ft; transmissivity was calculated to range from 47,100 to 54,000 gpd/ft2 with an average storage coefficient of 0.1.

Groundwater travel time across the Facility was calculated to be

approximately 7.14 feet per day using the calculated hydraulic conductivity and a hydraulic gradient of 0.003 ft/ft and an assumed porosity of 25 percent. At this rate it would take approximately 700 days for the groundwater to move from the west edge of the Facility to the Arkansas River using data previously gathered data presented in the RFA and RFI Reports.

Groundwater flow velocity was calculated to be approximately 7.14

feet per day based upon an approximate hydraulic gradient of 0.003 ft/ft and an assumed porosity of 25%. Based on the Darcy flow concept the base flow contribution by the alluvial aquifer at the Facility to the Arkansas River was calculated. The cross‐sectional area was 81,000 ft2 so the base flow contribution, using the above numbers, was reportedly determined to be approximately 1,093,500 gpd.



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2. Conceptual Site Model (CSM) Development

a. Development of a CSM is essential to guide ongoing investigation and monitoring of the Facility toward complete characterization of chemicals of concern (COCs), evaluation of impacted media, determination of contaminant routes of transport, evaluation of applicable exposure pathways, and potential contaminant effects on human health and the environment. Once a basic understanding of the contaminant source, transport mechanisms, area(s) of impact and applicable exposure routes have been identified through development of a preliminary CSM, the CSM can be continually refined as investigation(s) progress and the nature and extent of COCs are more fully understood. The CSM is generally developed through (1) identification of COCs; (2) source characterization; (3) evaluation of COC transport mechanisms and migration pathways; and (4) identification of potential receptors.

i. Identification of contaminants of concern (COCs) The Facility has been in operation since 1906 by several

different operators including Texaco and Sinclair. Typical products produced at the Refinery include: gasoline; diesel fuel; fuel oils; fuel gases; asphalt and sulfur. The principal process units at the Facility consist of crude distillation, distillate hydrotreating, naphtha hydrodesulfurization, fluid catalytic cracking, isomerization, catalytic reforming, alkylation, diesel hydrodesulfurization and sulfur recovery.

Environmental investigations conducted at the Facility since

the mid‐1980’s have identified impacts to soil and groundwater resultant from historic Facility operations, maintenance activities, and spills and releases from Facility storage tanks, equipment, and process lines. COCs in soil and groundwater beneath the Facility, identified over the course of historic investigations, include:

a. COCs in Soil and Groundwater:

1. VOCs including BTEX and MTBE;

2. SVOCs including 1‐Methylnaphthalene, 2,4‐

Dimethylphenol, 2‐Methylnaphthalene, 2‐Methylphenol, Bis(2‐ethylhexyl)Phthalate and Naphthalene; and



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3. Inorganics including Arsenic, Barium, Chromium, Cobalt, Lead, Mercury (SWMU‐C), Nickel, Vanadium, Mercury, and Cyanide

b. LNAPL as described in Permit Condition III.J.

ii. Source characterization Evaluation of current and historic data for soil and

groundwater beneath the Facility generally indicate that most impacts are likely attributed to cumulative effects of historic operations and releases from Facility equipment, tanks and process lines over time, rather than from a specific event(s) and/or waste management practice(s) associated with individual LTU(s), SWMU(s) or AOC(s). As presented by Holly during a meeting with the DEQ on September 10, 2010, a review of current environmental subsurface conditions show that the LTUs do not appear to be sources for the Facility‐wide LNAPL and dissolved‐phase plumes that are present underlying portions of the Refinery. Also, no statistically significant soil or groundwater detections had been observed from decades of compliance monitoring at the Flare Area and Walnut Grove LTUs.

During the September 10, 2010 DEQ meeting, Holly

suggested that a Facility‐wide RCRA permitting approach would be better protective of human health and the environment than the current LTU based post‐closure permitting approach. DEQ subsequently agreed to the Facility‐wide approach; Consent Order Case No. 11‐100 was then executed on July 6, 2011, to transition the Facility from an LTU‐based RCRA Permit to a Facility‐wide RCRA Post‐closure and Corrective Action Permit.

The sources of contamination beneath the Facility include:

a. The dissolved phase BTEX and MTBE plume(s) as described in Permit Condition III.K;

b. The LNAPL plume(s) as described in Permit Condition III.J; and

c. Elemental Hg at SWMU‐C, as described in

Permit Condition III.H.1.



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Residual subsurface contamination is exhibited in locations within the dissolved phase and LNAPL plumes. While the general areas of impact and corresponding dissolved phase COC concentrations have been identified, further investigations of the dissolved phase and LNAPL plumes are necessary to fully delineate the chemical nature and extent of each and to identify the characteristics of each plume, including plume expansion and shrinkage, plume migration, natural attenuation tendencies, LNAPL mobility, and chemical makeup. The proposed additional investigations for the LNAPL plume and the dissolved phase plume are outlined in Permit Conditions III.J and III.K, respectively.

iii. Transport mechanisms and exposure pathway review and

evaluation Evaluation of transport mechanisms and exposure pathwaysshould be part of the CSM developmental process upon completion of the additional investigations required by Permit Conditions III.F, G, H, J and K, and periodically reviewed as site conditions change and additional investigations are completed.

Evaluation of potential exposure pathways and associated

transport mechanisms may include, but may not necessarily require, all of the following:

a. COC transport mechanisms associated with each

media (i.e., source) may include:

i. Soil: 1. Volatilization of COCs to indoor

and outdoor air; 2. Leaching of COCs from soil to

groundwater; and 3. Storm water runoff in areas

with surface soil contamination.

ii. Groundwater:

1. Volatilization of COCs from groundwater to indoor and outdoor air;



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2. Adsorption of COCs onto soil during periods of groundwater fluctuation (i.e., creation of a smear zone); and

3. Potential transport of COCs in groundwater to surface water body receptors.

b. Potential exposure pathways and associated

exposure routes may include the following:

i. Groundwater Exposure Pathway 1. Groundwater ingestion; 2. Inhalation of volatilized COCs; 3. Direct contact with

groundwater.

ii. Surface Water and Sediment Exposure Pathway

1. Surface water ingestion; 2. Inhalation of volatilized COCs; 3. Direct contact with surface

water and sediments.

iii. Soil Exposure Pathway 1. Direct contact; 2. Inhalation of volatilized COCs.

iv. Air Exposure Pathway

1. Inhalation of COCs; 2. Direct contact with

contaminated particulate matter;

3. Ingestion of contaminated particulate matter.

v. Biotic Exposure Pathway

1. Ingestion of food sources exposed to COCs in soil, groundwater, surface water and/or sediment.



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iv. Identification of potential receptors Potential current and future receptors affected by COCs in soil and groundwater beneath the Facility may include the following:

a. On‐Site and Off‐Site Industrial workers and visitors;

b. Off‐Site Residents; and

c. Ecological receptors associated with the Arkansas

River.

b. The following guidance documents may be used to aid in CSM development:

i. Standard Guide for Developing Conceptual Site Models for

Contaminated Sites, ASTM Designation E1689‐95.

The CSM will be continually revised and updated to represent current conditions as subsurface investigations, assessments and remedial measures are completed at the Facility. This data will be presented in the SMRs, as applicable.

F. SPECIFIC CONDITION – INVESTIGATION OF AOC‐2

1. In May 2011, Holly submitted an Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H to the DEQ to assess the current and potential releases of hazardous wastes and hazardous constituents from AOC‐2 and SWMU‐H, as defined in Table III.B. The DEQ approved the Work Plan as submitted in correspondence dated June 28, 2011.

2. The Permittee shall complete the following investigation phases at AOC‐2 in accordance with the approved May 2011 Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H: a. Completion of test pits to define the nature and extent of

anomalies identified during geophysical screening investigations; i. Approximately 44 test pits to be installed;

ii. Test pits are planned to define both the horizontal and

vertical extent of waste material and its chemical make‐up.



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b. Membrane interface probe (MIP) screening to further characterize portions of the investigation areas that were not screened during the geophysical survey;

i. Complete one MIP point for approximately every 100 ft x

100 ft area, with emphasis towards previously non‐screened areas, areas of data gaps, or approximately 50 MIP points total;

ii. Each MIP point to be completed to approximately 15 ft to 20 ft total depth.

c. Installation of soil confirmatory borings in each investigation area

to validate MIP findings; and

i. Install ten (10) soil confirmatory borings, or 20 percent of total MIP locations, to approximately 20 ft total depth.

d. Installation of piezometers to assess groundwater elevations and

general horizontal and vertical gradients beneath the investigation areas. i. Four (4) pairs of piezometers to be installed in AOC‐2,

consisting of one shallow piezometer and one deep piezometer;

ii. Shallow piezometers shall be installed to approximately 15 ft depth;

iii. Deep piezometers to be installed to approximately 25 ft depth;

iv. Each piezometer to be contained in its own borehole and to be constructed of 1.5‐inch diameter 5 ft long screen and PVC riser to surface.

The number, locations and construction specifications of test pits, MIP points, confirmatory soil borings and piezometers to be installed at AOC‐2 are detailed in the Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H. The amount, locations and construction specifications of proposed investigation activities may change based upon actual field conditions encountered and pending results of each investigation phase described above.



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3. The Permittee shall implement Permit Condition III.F.2 starting on September 19, 2011 in accordance with the following schedule:

TABLE III.A – AOII SCHEDULE FOR AOC‐2 AND SWMU‐H

EVENT TASK ESTIMATED DURATION

1 Test Pits at SWMU-H Test Pits at AOC-2

~8 days ~10 days

Data Evaluation

Period Data evaluation of test pit findings; refine MIP work scope as necessary.

2 MIP Screening at SWMU-H MIP Screening at AOC-2

~10 days ~9 days

Data Evaluation

Period

Data evaluation of MIP findings; refine confirmatory boring scope as necessary.

3

Confirmatory borings and piezometers at SWMU-H

Confirmatory borings and piezometers at

AOC-2

~6 days

~5 days

4. The Permittee shall conduct the investigation of AOC‐2 and submit a report to DEQ identifying and discussing the findings and any recommendations for further action, and proposing a schedule for implementation of any recommended further action. After DEQ’s review and approval or approval with modifications of the recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding AOC‐2.

G. SPECIFIC CONDITION – INVESTIGATION OF SWMU‐H

1. In May 2011, Holly submitted an Area of Interest – Investigation Work Plan

for AOC‐2 and SWMU‐H to the DEQ to assess the current and potential releases of hazardous wastes and hazardous constituents from AOC‐2 and SWMU‐H, as defined in Table III.B. The DEQ approved the Work Plan as submitted in correspondence dated June 28, 2011.

2. The Permittee shall complete the following investigation phases at SWMU‐

H in accordance with the approved May 2011 Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H:

a. Completion of test pits to define the nature and extent of

anomalies identified during geophysical screening investigations;

i. Approximately 31 test pits to be installed;



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ii. Test pits are planned to define both the horizontal and vertical extent of waste material and its chemical make‐up.

b. Membrane interface probe (MIP) screening to further characterize

portions of the investigation areas that were not screened during the geophysical survey;

i. Complete one MIP point for approximately every 100 ft x

100 ft area, with emphasis towards previously non‐screened areas, areas of data gaps, or approximately 50 MIP points total;

ii. Each MIP point to be completed to approximately 25 ft total

depth.

c. Installation of soil confirmatory borings in each investigation area to validate MIP findings; and

i. Install ten (10) soil confirmatory borings, or 20 percent of

total MIP locations, to approximately 20 ft total depth.

d. Installation of piezometers to assess groundwater elevations and vertical and horizontal gradients beneath the investigation areas.

i. Six (6) pairs of piezometers to be installed in AOC‐2,

consisting of one shallow piezometer and one deep piezometer;

ii. Shallow piezometers shall be installed to approximately 15

ft depth;

iii. Deep piezometers to be installed to approximately 25 ft depth;

iv. Each piezometer to be contained in its own borehole and to

be constructed of 1.5‐inch diameter 5 ft long screen and PVC riser to surface.

The number, locations and construction specifications of test pits, MIP points, confirmatory soil borings and piezometers to be installed at SWMU‐H are detailed in the Area of Interest – Investigation Work Plan for AOC‐2 and SWMU‐H. The amount, locations and construction specifications of proposed investigation activities may change based upon actual field



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conditions encountered and pending results of each investigation phase described above.

3. The Permittee shall implement Permit Condition III.G.2 starting on

September 19, 2011 in accordance with the schedule set forth in Permit Condition III.F.3.

4. The Permittee shall conduct the investigation of SWMU‐H and submit a

report to DEQ identifying and discussing the findings and any recommendations for further action, and proposing a schedule for implementation of any recommended further action. After DEQ’s review and approval or approval with modifications of the recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding SWMU‐H.

H. SPECIFIC CONDITION – INVESTIGATION OF SWMU‐C

1. On June 10, 2010, Holly submitted a Subsurface Investigation and Soil Removal Activities – Mercury Assessment Area within Expanded SWMU‐C Report. The report summarized the February 2010 excavation activities implemented to remove elemental Hg identified in the geotechnical boring B‐5 area. Two (2) confirmatory samples collected from the base (B5‐EX‐N.BOTTOM) and sidewall (B5‐EX‐S.SIDE) of the excavation exhibited total mercury concentrations (134 mg/kg and 74.5 mg/kg, respectively) exceeding the applicable USEPA Industrial Soil screening level of 43 mg/kg, indicating additional investigation/corrective may be necessary.

2. The DEQ response letter dated August 15, 2011 (received by Holly on September 9, 2011) noted additional measures that Holly must take if follow‐up investigation and corrective actions were not performed.

3. Within one hundred eighty (180) days of the DEQ receipt of the dissolved phase investigation report, the Permittee shall submit a Work Plan for further investigation of SWMU‐C to address relevant COCs within the expanded SWMU‐C area.

4. After DEQ’s written approval of the work plan, and in accordance with the approved schedule, the Permittee shall implement the work plan and submit a report to DEQ identifying and discussing the findings and any recommendations for further action, and proposing a schedule for implementation of any recommended further action. After DEQ’s review and approval or approval with modifications of the recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding SWMU‐C.



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I. SPECIFIC CONDITION – INVESTIGATION OF PREVIOUSLY IDENTIFIED SWMUs AND AOCs

1. Within one hundred eighty (180) days from the cessation of Facility

operations or the permanent closure of any process unit that has an associated SWMU which has an open status designation, the Permittee shall submit to DEQ a work plan, including a schedule, to assess the current and potential releases of hazardous wastes and hazardous constituents from the designated SWMU as defined in Table III.B.

2. After DEQ’s written approval of the work plan, and in accordance with the

approved schedule, the Permittee shall conduct the assessment and submit a report to DEQ identifying and discussing the findings and any recommendations for further action, and proposing a schedule for implementation of any recommended further action. After DEQ’s review and approval or approval with modifications of the recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding the designated SWMU.

J. SPECIFIC CONDITION – INVESTIGATION OF LNAPL PLUME

As required by 40 CFR 270.14(c)(4), the LNAPL plume is described herein based on findings from the May 2011 Facility‐well network gauging event. A figure included in the August 2011 SMR representing the observed apparent LNAPL thickness and distribution during this period is provided as Figure III‐C at the end of Permit Section IV. As seen on Figure III‐C, the thickest LNAPL observed underlying the Facility is located to the northeast of SWMU‐E (map grid G4) on the northern boundary of the AEP property, the maximum apparent thickness in this area at 4.97 feet of LNAPL. The LNAPL plume during the May 2011 event is observed to be divided into four distinct lobes with several wells outside the lobes containing LNAPL. The smallest footprint is located adjacent to the former Tank 100 area (grid A‐4). The LNAPL plume area to the south of SWMU‐A covers the largest footprint (map grids B5‐6, C5‐6, D4‐6, and E4‐6) and ranges in apparent thickness from 0.01 ft to 3.3 ft in TX‐059. The LNAPL plume lobe located in the central portion of Refinery has a maximum LNAPL apparent thickness of 3.41 ft in well SR‐23. This portion of the LNAPL plume extends into areas of AOC‐2 and loses definition on the western/northwestern edges of the plume. LNAPL was also observed at the eastern boundary of the Facility and into the AEP property. It should also be noted that the eastern portion of this LNAPL plume intersects a large engineered control barrier wall. The barrier extends for a few thousand feet and reportedly was installed by Texaco. A second western leg of the barrier was reportedly installed by the City of Tulsa in the 1990s to help in dewatering during the installation of a city sewer line in the area. The barrier was presumably installed to limit the migration of



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LNAPL to the Arkansas River from historical LNAPL releases. Holly has not been able to locate any construction drawings or records for this engineered control. However, additional evaluation and hydraulic study of this barrier is planned as part of both the future SWMU‐H investigation (Permit Condition III.G) and the Facility LNAPL investigation. It has been demonstrated throughout the documented literature that overall LNAPL thicknesses in an aquifer change significantly with the fluctuations in ground water levels (Holly Tulsa West Refinery). Typically, observed LNAPL levels will increase with decreasing water levels and decrease with rising water levels in an unconfined aquifer. The gauging data collected for the May 2011 monitoring event shows the LNAPL plume to have the approximately same total area footprint, although configured differently in some portions of the plume than that observed during the previous November 2010 semi‐annual gauging event. A current “snapshot” of the LNAPL plume is observed using the existing monitoring wells at the Facility; many of these wells however, are not screened across the water table. These wells will need to be replaced to gain a more accurate view of the extent of the LNAPL plume.

An investigation of the LNAPL plume(s) underlying the Facility is necessary to accurately define the extent and composition of the LNAPL layer(s) beneath the Facility. To further characterize the current condition of the LNAPL plume(s), and evaluate associated exposure risks and applicable remedial objectives, the Permittee shall conduct an LNAPL investigation in accordance with Permit Condition III.J.1 and submit a summary of findings report in accordance with Permit Condition III.J.1.c. Based on the results of the LNAPL investigation, the Permittee shall develop an LNAPL Conceptual Site Model (LCSM) in accordance with Permit Condition III.J.2. The LCSM will then be used to aid in development of a suitable LNAPL Remediation Plan for the Facility (Permit Condition III.L).

1. LNAPL Plume Investigation

a. Within one hundred and eighty (180) days from the submittal of the RCRA Post‐Closure and Corrective Action Permit application for the Facility (assumed to be October 21, 2011), the Permittee shall submit to DEQ a work plan, including a schedule, to further characterize the light non‐aqueous phase liquids (LNAPL) plume beneath the Facility.

b. The LNAPL Plume Investigation Work Plan shall include a sufficient

Scope of Work (SOW) to define the extent, composition and characteristics of the LNAPL plume(s) beneath the Facility. The Work Plan may include but not be limited to the following:

i. Evaluation of data gaps, well redundancy(ies) and incorrectly

screened wells requiring replacement to fully characterize the lateral and vertical extent of the LNAPL plume(s);



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ii. An SOW, including field methodologies and procedures, for horizontal and vertical delineation and profiling of the LNAPL plume(s), including LNAPL thickness, chemical composition and potential product variances with depth;

iii. A SOW, including field methodologies and procedures, for soil

sampling and field screening to be completed during investigations to assess soil saturation conditions;

iv. A SOW of work for installation, development and surveying of

newly‐installed LNAPL gauging wells;

v. A SOW, including field methodologies and procedures, to evaluate LNAPL transmissivities to understand LNAPL plume mobility and migration;

vi. A revised SOW for Facility‐wide LNAPL gauging; and

vii. Methodology for data evaluation and refinement of the current LNAPL monitoring network.

c. After DEQ’s written approval of the work plan, and in accordance

with the approved schedule, the Permittee shall conduct the investigation(s) and submit a report to DEQ identifying and discussing the findings and any recommendations for further action, and proposing a schedule for implementation of any recommended further action. The LNAPL Plume Investigation summary report may include the following, at a minimum:

i. Descriptions of field work completed in support of the

LNAPL plume investigation(s); ii. Tabulated results of any groundwater and LNAPL gauging

data; iii. Tabulated results of any soil, groundwater or LNAPL sample

data obtained from field tests or laboratory analysis; iv. Maps showing the locations of newly‐installed gauging

wells, sample locations, and current distributions of the LNAPL plume(s) beneath the Facility;



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v. Discussion of the current condition of the LNAPL plume(s), including descriptions of the lateral and vertical extent of the plumes and plume composition variations laterally and with depth;

vi. Evaluation of LNAPL plume stability, including plume

migration or shrinkage, plume mobility, and general plume trends in comparison to historical data;

vii. Recommendations for further investigation(s), if necessary;

and

viii. Recommendations for revisions to the Facility‐wide gauging well network, if necessary, based on findings of the LNAPL plume investigation(s).

After DEQ’s review and approval or approval with modifications of the recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding assessment and monitoring of the LNAPL plume.

2. LNAPL Conceptual Site Model (LCSM)

a. Upon completion of the LNAPL investigation, the Permittee shall

develop an LNAPL CSM summarizing the current conditions and characteristic of the LNAPL plume beneath the Facility, an evaluation of the applicable exposure pathways, remedial objectives, and recommended remedy(ies) to mitigate risks associated with identified complete exposure pathways.

b. The LCSM shall be developed in accordance with, but not limited to,

the following guidance documents: i. Interactive LNAPL Guidance, Version 2.0, American

Petroleum Institute (API), August 2004;

ii. LNAPL Distribution and Recovery Model (LDRM), Volume 1: Distribution and Recovery of Petroleum Hydrocarbon Liquids in Porous Media, API Publication 4760, January 2007;

iii. LNAPL Distribution and Recovery Model (LDRM), Volume 2: User and Parameter Selection Guide, API Publication 4760, January 2007;



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iv. A Decision‐Making Framework for Cleanup of Sites Impacted with Light Non‐Aqueous Phase Liquids (LNAPL), USEPA RTDF document 542‐R‐04‐011, March 2004; and

v. Standard Guide for Development of Conceptual Site Models

and Remediation Strategies for Light Non‐Aqueous Phase Liquids Released to the Subsurface, ASTM Designation E2531‐06.

c. The LCSM may include the following:

i. Description of the horizontal and vertical extent of the LNAPL

plume(s);

ii. Description of physical characteristics of the LNAPL plume(s), including estimated age, weathering, and chemical composition;

iii. An estimate of LNAPL volume;

iv. Evaluation of LNAPL mobility and stability, , based on the results of the LNAPL investigation described in Permit Condition III.J.1;

v. Evaluation of LNAPL transmissivity and recoverability;

vi. Evaluation of LNAPL potential and complete exposure pathways and receptors for the Holly Tulsa East Facility;

vii. Evaluation of LNAPL remedial objectives based on the identified exposure risks and with respect to LNAPL compositional (i.e., vapor intrusion, dissolved phase and direct contact) and saturation (i.e., mobility and visible LNAPL thickness) drivers;

viii. An outline of conceptual LNAPL remedial strategies to fulfill

identified remedial objectives; and

ix. A proposed schedule for development and implementation of an LNAPL Remediation Plan, required by Permit Condition III.L.



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d. Within ninety (90) days from DEQ’s receipt of the Dissolved Phase Plume Investigation Summary Report described in Permit Condition III.K.3, the Permittee shall meet with the DEQ to discuss the results of the LNAPL and Dissolved Phase investigations and the development of the LCSM.

e. Within ninety (90) days from the meeting described in Permit

Condition III.J.2.d, the Permittee shall submit a draft LNAPL Remediation Plan to the DEQ, in accordance with Permit Condition III.L.

K. SPECIFIC CONDITION – INVESTIGATION OF DISSOLVED PHASE PLUME Benzene, toluene, ethylbenzene and xylenes (BTEX) and methyl‐tert‐butyl‐ether (MTBE) are present in dissolved concentrations in the groundwater at the Facility. In addition, arsenic, barium, nickel and cyanide have been observed in several of the monitoring wells at the Facility. During the May 2011 sampling event, benzene was detected in 12 wells, toluene in 8 wells, ethylbenzene in 7 wells, xylenes in 14 wells and MTBE in 6 wells. Arsenic was observed in 16 wells, barium in all 41 wells, nickel in 3 wells and cyanide in 5 wells. Chromium, Cobalt, Lead and Vanadium were also detected in the wells at the Facility. Chromium was detected in 2 wells and Lead was detected in 1 well, respectively. Cobalt and Vanadium were both detected in 2 wells. Concentrations of benzene ranged from 0.0083 mg/L in MW‐280 to 0.443 mg/L in MWII‐A4. Interim POC wells with dissolved concentrations below method reporting limits include AEP‐1, AEP‐3, AEP‐7, AEP‐8, AEP‐9, SOC‐12, SX‐160, SX‐2, TX‐53, WTP‐5, MW‐265, MW‐266, MW‐267, MW‐268, MW‐269, MW‐270, MW‐271, MW‐272, MW‐274, MW‐275, MW‐277, MW‐278, MW‐279, MW‐F1, MWII‐B1, SOC‐5, SOC‐6, SOC‐016, SOC‐13 and MWII‐C7. A figure included in the August 2011 SMR representing the dissolved Benzene during this period is provided as Figure III‐D. Concentrations of MTBE ranged from 0.0067 mg/L in MW‐277 to 0.0678 mg/L in AEP‐8. The May 2011 distribution of MTBE is shown on Figure III‐E. The distributions of dissolved levels of both BTEX and MTBE can be observed on Figure III‐F. In general, as can be seen on Figure III‐F, the interim POC wells containing higher concentrations of BTEX and MTBE tend to be located on the east‐south east downgradient portion of the Facility. The exceptions are localized areas around interim POC well MWII‐A4 at the north central property boundary, interim POC well MW‐250 at the west central upgradient portion of the Facility and some occurrences along the west‐southwestern property boundary at interim POC wells MW‐271, MW‐273, and MW‐276, respectively. Inorganic compounds that were detected at the Facility include arsenic, barium, nickel, cyanide, chromium, cobalt, lead and vanadium. Arsenic was observed in 16 of the 41 compliance wells sampled ranging in concentrations from 0.011 mg/L in TX‐53 to 0.054 in MWII‐B1. The concentrations observed in these wells are generally consistent with the historical values from



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wells in this area and are likely the result of the natural mineralogy of the saturated zone. Several of these wells are located on the upgradient Facility property boundary. Based on monitoring well gauging conducted during the semi‐annual sampling events, several monitoring wells appeared to be screened inappropriately, flooded, damaged or can’t be located. To provide an accurate assessment of the dissolved phase plume(s), additional and replacement monitoring points are necessary. To further characterize the current condition of the dissolved phase plume(s) beneath the Facility, and evaluate associated exposure risks and applicable corrective actions, if necessary, the Permittee shall conduct an investigation of the dissolved phase plume(s) in accordance with this Permit Condition III.K and submit a summary of findings report in accordance with Permit Condition III.K.3.

1. Within one hundred twenty (120) days from DEQ’s receipt of the LNAPL investigation Report (Permit Condition III.J.1.c), the Permittee shall submit to DEQ a work plan, including a schedule, to further characterize the dissolved phase plume beneath the Facility.

2. The dissolved phase investigation Work Plan shall include a sufficient SOW to

characterize the lateral and vertical extent of on‐site and off‐site dissolved phase COCs emanating from beneath the Facility. The Work Plan may include but not be limited to the following:

a. Evaluation of data gaps, well redundancy(ies) and incorrectly

screened wells requiring replacement to develop a sufficient Facility‐wide monitoring network;

b. A SOW, including field methodologies and procedures, for horizontal and vertical delineation of the dissolved phase plume(s);

c. A SOW, including field methodologies and procedures, for soil sampling and field screening to be completed during investigations;

d. A SOW for installation, development, and surveying of newly‐installed monitoring wells and surveying of all wells that are part of the current Facility gauging well network and the POC wells network;

e. A SOW for Facility‐wide groundwater gauging and sampling; and

f. Methodology for data evaluation and refinement of the current Facility‐wide monitoring and point of compliance (POC) well network.

3. After DEQ’s written approval of the work plan, and in accordance with the

approved schedule, the Permittee shall conduct the assessment and submit a report to DEQ identifying and discussing the findings and any



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recommendations for further action, and proposing a schedule for implementation of any recommended further action. The dissolved phase plume investigation summary report shall include the following, at a minimum:

a. Descriptions of field work completed in support of the dissolved

phase plume investigation(s); b. Tabulated analytical results of any soil and groundwater samples

submitted for laboratory analysis; c. Maps showing the locations of newly‐installed monitoring points,

sample locations, and current distributions of dissolved phase constituents;

d. Discussion of the current condition of the dissolved phase plume(s),

including descriptions of the lateral and vertical extent of on‐site and off‐site dissolved phase VOCs;

e. Evaluation of plume stability, including plume migration or shrinkage,

plume mobility, and general plume trends in comparison to historical data;

f. Recommendations for further investigation(s), if necessary; and g. Recommendations for revisions to the Facility‐wide monitoring and

POC well network, if necessary, based on findings of the dissolved phase plume investigation(s).

After DEQ’s review and approval or approval with modifications of the

recommendations, the permit shall be modified in accordance with Section IV.A.3 to specify any further action that the Permittee shall undertake regarding assessment and monitoring of the dissolved phase plume.

L. SPECIFIC CONDITION ‐ LNAPL REMEDIATION PLAN Recent advances in the understanding of LNAPL plumes and their characteristics, exposure pathways, transport mechanisms, and limitations of LNAPL recovery operations provide a new more comprehensive basis for development of an effective Facility LNAPL management strategy. This relatively new understanding of LNAPL behavior focuses on understanding both “compositional” and “saturation” risk based drivers in the development of appropriate remediation strategies.



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Compositional drivers are key in assessing the source and concentration of the LNAPL plume, and generally include: a) vapor intrusion and explosion hazards; b) dissolved phase concentrations; and c) direct contact and ingestion. Saturation drivers are key in assessing LNAPL transport, plume expansion and stability, and generally include: a) mobility and b) visual presence of LNAPL in monitoring wells. The common historical approach that many regulatory bodies have utilized as an overall LNAPL strategy, or fallback position, when other statute language to deal with LNAPL does not exist, is the “recovery to the extent practical” approach. This approach has been demonstrated on many RCRA and other sites to no‐longer represent the most effective LNAPL management strategy and is often impractical. It is often not the best strategy to address actual exposure risks based upon actual site conditions. It can often eliminate or minimize the development of site specific remedial objectives for a “one size fits all strategy”. The Permittee shall develop an LCSM as discussed in Permit Condition III.J.2. The LCSM shall be used as a basis to form a conceptual LNAPL Remediation Plan, which shall be discussed with the DEQ as required by Permit Condition III.J.2.d., followed by preparation of a formal LNAPL Remediation Plan as required below.

1. Within ninety (90) days from the meeting described in Permit Condition

III.J.2.d, the Permittee shall submit a draft LNAPL Remediation Plan to the DEQ, in accordance with Permit Condition III.L.

2. The LNAPL Remediation Plan shall include the following:

a. A description of the LCSM;

b. A summary of the current LNAPL recovery systems, including

hydrocarbon recovery efforts to date and dates of operation;

c. The proposed LNAPL Remediation strategy for the Facility, including: i. An outline of the general LNAPL Remediation strategy for the

Site, based on the findings of the LCSM;

ii. A summary of the current LNAPL and dissolved phase plume conditions, including relevant findings of the LNAPL and dissolved phase plume investigations discussed in Permit Conditions III.J and III.K;

iii. General Requirements for continued LNAPL plume monitoring;



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iv. General Requirements for LNAPL plume assessment, including

methodology for continual monitoring and assessment of “compositional” and “saturation” drivers, as determined to be necessary based on the LCSM;

v. General Requirements for any proposed LNAPL recovery operation(s);

vi. General Requirements for management, maintenance, testing and upkeep of the existing LNAPL recovery systems;

vii. Any Interim LNAPL Remediation Goals;

viii. Recordkeeping and Reporting Requirements.

3. After DEQ’s review and approval or approval with modifications of the LNAPL Remediation Plan, the permit shall be modified in accordance with Section IV.A.3.

4. Until DEQ approves a formal LNAPL Remediation Plan, the Permittee shall

operate and maintain the ten (10) existing LNAPL recovery system or equivalent systems based upon the discretion of the Permittee, identified in this section, as required by the Consent Order provided as Attachment 6. LNAPL recovery systems will be added, modified, or eliminated at the discretion of the Permittee based upon changes in site conditions and/or the effectiveness of recovery operations. Any changes to the LNAPL recovery systems will be documented in the SMRs and will not require a permit modification. Additional LNAPL recovery wells may be installed to recover LNAPL at the discretion of the Permittee and the results of the LNAPL and dissolved plume investigations.

a. Existing remediation systems for the recovery and removal of LNAPL,

consisting of petroleum hydrocarbons and related materials, are designated as follows:

i. LNAPL recovery systems consisting of ten (10) nitrogen‐driven

recovery systems where each system can be connected to up to four recovery wells (except Battery #5). Modifications to these systems may be made at the discretion of the Permittee, provided the overall effectiveness of the system(s) is(are) not reduced. The recovery systems, identified by number, are currently configured as described in the below



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table. The locations of the LNAPL recovery systems are shown on Figure III‐C:

TABLE III.BSummary of LNAPL Recovery Systems

System #

General Location

Recovery System Installation

Month & Year

Associated Wells Grid

Locations 1 2 3 4

1 Ball

Tanks–North

March‐08 SR‐1 SR‐6 SR‐12 E‐3

2 Tank 123 September‐08 SR‐2 SR‐19 TX‐14 SR‐9 D‐5, C‐4,

C‐5 4 CDU‐NW March‐09 TX‐105 SR‐07 D‐3

5 FCCU‐west

July‐09 SR‐24 D‐2

7 Ball

Tanks‐South

November‐08 SR‐4 SR‐13 TX‐147 E‐2, E‐3

8 Tank 470 June‐08 SR‐26 SR‐27 SX‐154 H‐4

9 Flare Area‐West

September‐09 SR‐30 SR‐31 TX‐73 TX‐79

E‐2, F‐2

10 Tank 464 June‐08 SR‐28 SR‐32 SR‐8 F‐4, G‐4

11 Flare Area‐East

May‐08 MWD‐3 MWII‐D7R G‐2, G‐3

12 Former Tank 100

September‐10 MW‐259 A‐4

5. Additional Remedial Measures and Modification of Existing Measures

a. The DEQ may require the Permittee to implement additional remediation measures, on an emergency basis or otherwise, to address any LNAPL contamination deemed to present an on‐going, significant and/or immediate threat to human health or the environment. Such requirements may be imposed by a DEQ‐ordered Permit modification (40 CFR 270.41); Emergency Permit (40 CFR 270.61); Temporary Authorization of a Permit Modification (40 CFR 270.42(e)); Administrative Compliance Order (OAC 252:4‐9‐2); or such other means as are authorized by law. Such action may only be taken:

i. at the written request of the Permittee;



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ii. upon a determination by the DEQ that following normal permit processing procedures would unnecessarily exacerbate a significant threat to human health or the environment; and/or

iii. upon a determination by the DEQ that the Facility is not

meeting the Interim LNAPL Remediation Goals of Condition III.K.2.a, and the Permittee is not taking the proper and prompt actions necessary to return to compliance, regardless of a showing of intent or incapacity on the part of the Permittee.

6. Maintenance, Upkeep and Testing of Remediation Systems

The Permittee shall perform functions necessary to maintain the current performance of the Facility LNAPL remediation systems at existing operational conditions. Adjustments in recovery operations may be made based upon changes in site conditions and decreases in recovery volumes or LNAPL saturations values.

a. Holly shall maintain LNAPL recovery in at least 50% of the current

LNAPL systems identified in Permit Condition III.L.4 unless recovery volumes have decreased to the point of diminishing returns in more than 50% of the LNAPL recovery wells.

b. Temporary shutdown for routine maintenance shall not be deemed as an interruption of operation.

c. Shutdowns due to causes beyond the control of the Permittee, such as a tornado, flood, labor disruption, terrorist activity, electrical outages or the like, or to ensure safe working conditions shall not be considered a violation of this permit, but operations should resume as soon as practicable.

d. The Permittee may submit a request to the DEQ to cease to

operate any or all remediation systems for extended, but defined, periods in order to perform testing or system evaluations (e.g., to investigate contaminant level “rebound”). The DEQ will evaluate the request in light of the overall progress being made towards the requirements of this permit, and may approve the request if deemed appropriate. Such request and approval (or denial, if appropriate) shall not be deemed a Permit Modification.



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7 . Recordkeeping and Reporting

a. The Permittee shall record the volumes of LNAPL recovered from all Containment and Recovery Systems, and any relevant data. This data, along with all monitoring, testing, and maintenance records obtained pursuant to Permit Condition III.L, shall be entered in the operating record.

b. The Permittee shall prepare a report on the effectiveness of the Containment and Recovery Systems at least semi‐annually, until a new LNAPL Remediation Plan is implemented, and shall submit said Report concurrently with the groundwater analytical reports required in the SMR.

M. COMPLETED INTERIM MEASURES

1. Slurry Walls Proximate to Eastern Tank Farm and SWMU‐H Multiple slurry walls have been installed proximate to the southeast quadrant of the eastern tank farm and SWMU‐H, as shown on Figure III‐C. It is believed, the main slurry wall running as the southern boundary of the tank farm, then trending parallel and adjacent to the Arkansas River and SWMU‐H, was installed by Texaco. Details regarding the installation date and construction are presently unknown. It is assumed the slurry wall was installed by Texaco to limit the migration of LNAPL towards the Arkansas River. The smaller western portion of the slurry wall that runs north/south was reportedly installed by the City of Tulsa to facilitate a sewer line or utility installation project. The construction details are not known, however, it is reported that the wall was installed sometime in or prior to 1991. A monitoring well network is absent along the eastern portion of the Refinery near the slurry walls. Because there is no means to monitor and compare groundwater hydraulic head proximate to the slurry walls or significant local chemical data, there is uncertainty to the effectiveness and performance of the slurry walls. However, petroleum sheening, with the possible exception of one historical occurrence, has not been reported along the riverbank in the SWMU‐H area.



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Holly Tulsa East Refinery TABLE III.C. – SWMU DESIGNATION AND STATUS; DEFINITION OF AREA OF CONCERN

(AOC)

Solid Waste Management Units (SWMUs)

SWMU ID

Name

Original Permit Status WGLTU Operations

Permit No. 990750960‐OP

December 10, 1998

Permit Status1

(As of Effective Date of this Permit)

A Former Land Farm RFI completed November

1997; Closed, NFA Closed, NFA

B Former Land Farm RFI completed November

1997; Closed, NFA Closed, NFA

C Former Land Farm; Tetraethyl Lead (TEL)

Area

RFI completed November 1997; NFA

Expanded by 11.3 acres in August 2008; IM Completed for elemental Hg

in December 2009 and February 2010. Additional investigations to be performed for applicable COCs. A Work Plan will be submitted to DEQ within one hundred eighty (180) days of DEQ receipt of the dissolved phase

plume investigation report.

D

Former Landfill; Off‐Unit Storm Pond

RFI completed November 1997; NFA

Closed, NFA

E

Former Landfill; Current Waste Water

Treatment Plant (WWTP)

RFI completed November 1997; Additional Investigation

Required.

Open, Currently operated as the refinery WWTP and off‐unit storm pond, two API separators and tanks

400 and 401); Additional investigation required when Facility

ceases operation or the unit is permanently closed.



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Solid Waste Management Units (SWMUs)

SWMU ID

Name

Original Permit Status WGLTU Operations

Permit No. 990750960‐OP

December 10, 1998

Permit Status1

(As of Effective Date of this Permit)

F

Former Land Farm Not included in Permit

IM Completed, Additional investigation required when Facility

ceases operation or the unit is permanently closed.

G Former Land Farm;

Alky Unit Not included in Permit

Currently houses the alkylation unit and active process wastewater sewer

lines; Additional investigation required when Facility ceases

operation or the unit is permanently closed.

H Property leased to River Parks (Former Waste Disposal Site)

Not included in Permit

Initial investigations completed by Sinclair in 2010; Additional subsurface investigations to be performed by

Holly in September 2011.

I Unassigned

1. NFA Status, or “No Further Action”, indicates that the DEQ is not currently requiring any further action by the Permittee to remediate or close a particular SWMU. NFA Status does not relieve a Permittee from continued monitoring and maintenance of the unit.

Areas of Concern (AOCs)

Name Description/Location AOC 1

AOC 1 (Former Landfill; Dredge Pond) was a naturally occurring pond used to dispose of spent catalyst from a fluid catalytic cracking unit. The AOC was designated a SWMU resulting from the disposal of spent catalyst and tank bottom wastes; associated impacts were Pb and hydrocarbons. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.” The AOC‐1 status is closed as a result of this determination.



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Areas of Concern (AOCs) Name Description/Location AOC 2

AOC‐2 (Former Union Pacific Railroad Company) is a triangularly shaped parcel of land, consisting of approximately 9.48 acres located in the central portion of the Refinery. The area is bordered on the north by the Refinery WWTP (SWMU‐E). West of the subject property is the former gas plant and to the southeast rail lines are located immediately adjacent to the boundary with the off‐unit storm water pond (SWMU‐D) located beyond the rail lines. The property is encased in perimeter fencing and a security gate. Sinclair purchased this parcel from UPRR in 2008, following the completion of a Phase I Environmental Site Assessment (Phase I ESA). AOC 2 was identified as a SWMU in July 22, 2008 as a result of refinery construction activities. Solid waste was encountered in two excavations during the rerouting of an off‐unit storm water line. The buried waste was located in a triangular portion of property located south of the Refinery’s WWTP and northeast of the Refinery’s off‐unit storm water pond. The buried waste was encountered near the surface to depths ranging from approximately four to six feet below the ground surface, and was comprised primarily of fire brick, scrap metal, construction debris, glassware, insulation and asbestos containing materials, as described in Permit Condition III.B.3.b. Initial screening investigations were completed by Sinclair in 2010. Additional subsurface investigations to be performed by Holly in September 2011.

Locations of SWMUs and AOCs can be viewed on the figures provided at the end of Permit Section IV.



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SECTION IV ‐ SPECIAL CONDITIONS PURSUANT TO THE 1984 HAZARDOUS AND SOLID

WASTE AMENDMENTS (HSWA)

This section shall apply to all current and newly‐identified SWMUs and AOCs.

A. STANDARD CONDITIONS

1. Waste Minimization

Annually, by December 1, for the previous year ending September 30, the Permittee shall enter into the operating record as required by 40 CFR 264.73(b)(9), a statement certified according to 40 CFR 270.11(d) specifying that the Permittee has a program in place to reduce the volume and toxicity of hazardous wastes generated by the Facility's operation to the degree determined by the Permittee to be economically practicable; and the proposed method of treatment, storage, or disposal that is the most practicable method currently available to the Permittee which minimizes the present and future threat to human health and the environment. A current description of the program shall be maintained in the operating record and a copy of the annual certified statement shall be submitted to the DEQ. The following are suggested criteria for the program:

a) Any written policy or statement that outlines goals, objectives,

and/or methods for source reduction and recycling of hazardous waste at the Facility;

b) Any employee training or incentive programs designed to identify

and implement source reduction and recycling opportunities;

c) Any source reduction and/or recycling measures implemented in the last five years or planned for the near future;

d) An itemized list of the dollar amounts of capital expenditures (plant

and equipment) and operating costs devoted to source reduction and recycling of hazardous waste;

e) Factors that have prevented implementation of source reduction

and/or recycling;

f) Sources of information on source reduction and/or recycling received at the Facility (e.g., local government, trade associations, suppliers, etc.);



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g) An investigation of additional waste minimization efforts which could be implemented at the Facility. This investigation would analyze the potential for reducing the quantity and toxicity of each waste stream through production reformulation, recycling, and all other appropriate means. The analysis would include an assessment of the technical feasibility, cost, and potential waste reduction for each option;

h) A flow chart or matrix detailing all hazardous wastes it produces by

quantity, type, and building/area;

i) A demonstration of the need to use those processes which produce a particular hazardous waste due to a lack of alternative processes or available technology that would produce less hazardous waste;

j) A description of the waste minimization methodology employed for

each related process at the Facility. The description should show whether source reduction or recycling is being employed; and

k) A description of the changes in volume and toxicity of waste actually

achieved during the year in comparison to previous years.

2. Dust Suppression

a) Pursuant to 40 CFR 266.23(b), and the Toxic Substances Control Act, the Permittee shall not use waste or used oil or any other material which is contaminated with dioxins, polychlorinated biphenyls (PCBs), or any other hazardous waste (other than a waste identified solely on the basis of ignitability), for dust suppression or road treatment.

3. Permit Modification

a) DEQ Initiated Modifications

If at any time for any of the reasons specified in 40 CFR 270.41, the DEQ determines that modification of this permit is necessary, the DEQ may initiate permit modification proceedings in accordance with the regulations set forth at 40 CFR 270.41.

b) Permittee Initiated Modifications

The Permittee may, where appropriate, initiate permit modifications in accordance with the regulations set forth at 40 CFR 270.42. All applicable requirements and procedures as specified in 40 CFR



IV‐3

270.42 shall be followed by the Permittee in initiating such proceedings.

c) Modification of Corrective Action Schedules of Compliance (CASC)

(1) The Permittee shall adhere to CASCs contained in the permit. If at any time the Permittee determines that such schedules cannot be met, the Permittee shall, within fifteen (15) days of such determination, notify the DEQ and submit a request for a permit modification under 40 CFR 270.42, with a justification as to why the current CASC cannot be met.

(2) If the DEQ determines that a modification of the CASC is

required, the procedure noted in Permit Condition IV.A.3 and IV.A.4 will apply. CASC modifications made under this procedure are not subject to administrative appeal.

(3) The DEQ will notify the Permittee in writing of the proposed

modification. Such notice will:

(a) Describe the exact changes to be made to the permit Conditions;

(b) Provide an explanation of why the modification is

needed;

(c) Provide notification of the date by which comments on the proposed modification must be received. Such date will not be less than twenty (20) days from the date the notice of proposed modification is received by the Permittee, or after the public notice is published;

(d) Provide notification that supporting documentation

or data may be available for inspection at the State or EPA Regional office; and

(e) Include the name and address of a representative of

the DEQ to whom comments may be sent.

(4) The DEQ shall:

(a) Publish a notice of the proposed modification in a newspaper distributed in the locality of the Facility,



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which includes notice of pertinent items in permit Condition IV.A.3.;

(b) Mail a notice of the proposed modification to all

persons on the Facility mailing list maintained according to 40 CFR 124.10(c)(1). Such notice will include items under Permit Condition IV.A.3, and shall be mailed concurrently with notice to the Permittee;

(c) For facilities which have established an information

repository pursuant to Permit Condition IV.B., the DEQ shall place a notification of the proposed modification, including items under Permit Condition IV.A.3.c.3(a) in the information repository concurrently with actions taken under those items.

(5) DEQ's Decision Regarding Modification

(a) If the DEQ receives no written comment on the

proposed modification, the modification shall become effective five (5) calendar days after the close of the comment period. The DEQ shall:

i. Notify the Permittee in writing of the final

decision; and

ii. Notify individuals on the Facility mailing list in writing that the modification has become effective and shall place a copy of the modified permit in the information repository.

(b) If the DEQ receives written comment on the

proposed modification, the DEQ shall make a final determination concerning the modification after the end of the comment period. The DEQ shall:

i. Notify the Permittee in writing of the final

decision; and

ii. Provide notice of the final modification decision in a locally distributed newspaper and place a copy of the modified permit in the information repository.



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4. Permit Review

This permit may be reviewed by the DEQ five (5) years after the date of permit issuance and may be modified as necessary as provided for in Permit Condition IV.A.3. Nothing in this section shall preclude the DEQ from reviewing and modifying the permit at any time during its term.

5. Compliance with Permit

Compliance with a RCRA Permit during its term constitutes compliance, for purposes of enforcement, with Subtitle C of RCRA except for those requirements not included in the permit which:

a) Become effective by statute;

b) Are promulgated under 40 CFR 268 restricting the placement of

hazardous wastes in or on the land; or

c) Are promulgated under 40 CFR 264 regarding leak detection systems for new and replacement surface impoundments, waste piles, and landfill units, and lateral expansions of surface impoundments, waste piles, and landfill units. The leak detection system requirements include double liners, CQA programs, monitoring action leakage rates, and response action plans, and will be implemented through the procedures of 40 CFR 270.42 Class 1 Permit Modifications.

6. Specific Waste Ban

a) The Permittee shall not place in any land disposal unit the wastes

specified in 40 CFR 268 after the effective date of the prohibition unless the DEQ has established disposal or treatment standards for the hazardous waste and the Permittee meets such standards and other applicable conditions of this permit.

b) The Permittee may store wastes restricted under 40 CFR 268 solely

for the purpose of accumulating quantities necessary to facilitate proper recovery, treatment, or disposal provided that it meets the requirements of 40 CFR 268.50(a)(2) including, but not limited to, clearly marking each tank or container.

c) The Permittee is required to comply with all requirements of 40 CFR

268.7 as amended. Changes to the waste analysis plan will be



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considered permit modifications at the request of the Permittee, pursuant to 40 CFR 270.42.

d) The Permittee shall perform a waste analysis at least annually or

when a process changes, to determine whether the waste meets applicable treatment standards. Results shall be maintained in the operating record.

e) The Permittee must comply with requirements restricting placement

of hazardous wastes in or on land which become effective by statute or promulgated under Part 268, regardless of requirements in the permit. Failure to comply with the regulations may subject the Permittee to enforcement action under Section 3008 of RCRA and under the Oklahoma Hazardous Waste Management Act (OHWMA).

f) The Permittee shall conduct post‐closure care in accordance with

Permit Attachment 2 for each LTU identified in the permit. Post‐ closure care began after completion of closure of the unit(s) and shall continue for thirty (30) years after that date. The 30‐year post‐closure care period may be shortened upon application and demonstration approved by the DEQ that the Facility is secure, or may be extended by the DEQ if necessary to protect human health and the environment. [40 CFR 264.117(a)]

g) The Permittee may irrigate the LTUs as necessary to maintain the

appropriate vegetative cover including using treated effluent from the WWTP as an irrigation source. Additionally, non‐hazardous clarifier sludge (biosludge) may be applied to the vegetative cover as a nutrient source for fertilization and a supplemental supply of irrigation water. The following conditions will apply:

1) The Permittee shall evaluate the effects of the irrigation at

least annually and shall report this evaluation in the appropriate semi‐annual monitoring report; and

2) Parameters that will be evaluated include groundwater

elevation, flow, and quality and condition of the vegetative cover.

7. Information Submittal

Failure to comply with any condition of the permit, including information submittal, constitutes a violation of the permit and is grounds for enforcement action, permit amendment, termination, revocation, suspension, or denial of permit renewal application.



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Falsification of any submitted information is grounds for termination of this Permit (40 CFR 270.43). The Permittee shall ensure that all plans, reports, notifications, and other submissions to the DEQ required in this permit are signed and certified in accordance with 40 CFR 270.11. A summary of the planned reporting requirements pursuant to this permit is found at the end of this section in Table 1. Two (2) copies of each of these plans, reports, notifications or other submissions shall be submitted to the DEQ by Certified Mail, hand delivered, electronic delivery, or overnight mail to:

Saba Tahmassebi, Ph.D., P.E. Chief Engineer Land Protection Division Oklahoma Department of Environmental Quality 707 North Robinson Avenue, P.O. Box 1677 Oklahoma City, Oklahoma 73101‐1677

8. Plans and Schedules Incorporated Into Permit

All plans and schedules required by this permit are, upon approval by the DEQ, incorporated into this permit by reference and become an enforceable part of this permit. Since required items are essential elements of this permit, failure to submit any of the required items or submission of inadequate or insufficient information may subject the Permittee to enforcement action under Section 3008 of RCRA and under the OHWMA which may include fines, suspension, or revocation of the permit.

Any noncompliance with approved plans and schedules shall be termed noncompliance with this permit. Written requests for extensions of due dates for submittals may be granted by the DEQ in accordance with Permit Condition IV.A.3. If the DEQ determines that actions beyond those provided for, or changes to what is stated herein, are warranted, the DEQ may modify this permit according to procedures in Permit Condition IV.A.3.

9. Data Retention

All raw data, such as laboratory reports, drilling logs, bench‐scale or pilot‐scale data, and other supporting information gathered or generated during activities undertaken pursuant to this permit shall be maintained at the Facility during the term of this permit, including any reissued permits. The Permittee may retain certain documents, including in electronic format and off‐site, provided such documents can be readily retrieved for review by DEQ.



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10. Management of Wastes

a) All solid wastes which are managed pursuant to a remedial measure taken under the corrective action process or as an interim measure addressing a release or the threat of a release from a LTU or SWMU shall be managed in a manner protective of human health and the environment and in compliance with all applicable Federal, State and local requirements. Until such time as final regulations are adopted, proposed regulations under Subpart S ‐ Corrective Action for Solid Waste Management Units ‐ 40 CFR 264.550, 264.551 and 264.552, Federal Register, Friday, July 27, 1990, pp 30798‐30884, shall be applicable as guidance for managing these wastes. Unless an exemption to permitting applies, approval of units for managing hazardous wastes and conditions for operating the units, if approved, shall be granted through the Permitting process.

B. SPECIFIC CONDITION ‐ INFORMATION REPOSITORY

1. Within thirty (30) days of the effective date of this permit, the Permittee

shall establish an information repository to provide the public an opportunity to review and comment on the corrective action activities specified in this permit. This repository shall be established at a local public library or similar facility which is easily accessible to the public during normal working hours.

2. Within thirty (30) days of the effective date of this permit, the Permittee

shall mail a notice to all individuals on the Facility‐specific mailing list maintained by the DEQ, including all individuals that submitted oral or written comments on the Permittee's draft permit during the public comment period. The Permittee shall amend this mailing list as necessary to include those individuals that submit a written request to the DEQ and the Permittee for inclusion in this list.

3. The notice shall state the location, purpose, and content of the repository.

A copy of the notice shall be provided to DEQ, for approval, prior to mailing to the public.

4. The Permittee shall state in the notice that written comments concerning

each submittal (excluding progress reports and correspondence) required by this permit shall be forwarded to the following representative of the DEQ within fifteen (15) calendar days of the date due to the DEQ:



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Saba Tahmassebi, Ph.D., P.E. Chief Engineer Land Protection Division Ohio Department of Environmental Quality 707 North Robinson Avenue, P.O. Box 1677 Oklahoma City, Oklahoma 73101‐1677

5. Once established, the Permittee shall place into the repository, on or before the date due to the DEQ, all submitted final work plans and reports as specified in this permit, and those documents deemed appropriate by the DEQ. The Permittee shall specify within the text or cover letter of each document the date each submittal was placed in the repository.

C. ADDITIONAL CORRECTIVE ACTION

1. Corrective Action for Releases: Section 3004(u) of RCRA, as amended by

HSWA, and 40 CFR 264.101, requires that permits issued after November 8, 1984, address corrective action for releases of hazardous waste or hazardous constituents from any SWMU at the Facility, regardless of when the waste was placed in the unit.

The Permittee is currently performing remedial measures on groundwater beneath the Facility, caused by the existence of a separate phase LNAPL plume(s) on the water table surface. Current remedial measures involve recovery of non residual LNAPL from approximately ten (10) LNAPL recovery systems. The Permittee shall operate and maintain the identified LNAPL recovery systems or equivalent systems (at the discretion of the Permittee based upon site conditions) until LNAPL remediation goals are developed in the future LNAPL Remediation Plan. The future LNAPL Remediation Plan and current LNAPL remediation activities are covered in Section III of the Permit by Permit Condition III.L.

2. Action Levels

a) Applicability ‐ The concept of action levels, described in the RFI

guidance document referenced in Permit Condition IV.H.1.c.1 shall be used by the Permittee to determine the need for further corrective actions under this permit. As specified in Permit Condition IV.L., the Permittee shall conduct a corrective measures study (CMS) whenever concentrations of hazardous constituents in groundwater, surface water, soils, or air exceed action levels for any environmental medium or when the DEQ determines that concentrations of contaminants, even if below action levels, present a threat to human health or the environment. The concept of action



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levels is not the same as cleanup levels, although in some cases a final cleanup level may be set to equal the action level

b) Calculation ‐ The Permittee shall adhere to RFI guidance in the calculation of action levels for all the environmental media. These action levels shall be updated as new toxicity data and promulgated standards (e.g., maximum contaminant levels) are derived. The most recent reference doses, reference concentrations, and cancer slope factors (e.g., data found in EPA's Integrated Risk Information System) shall be utilized in the calculation of action levels. The toxicity data available at the time that a determination for further action is made (i.e., requirement to conduct a CMS), including interim measures, shall be utilized in the calculations. If used as final cleanup levels, action levels shall be calculated using the most recent toxicity data and promulgated standards existing at the time of implementation of corrective measures.

3. Risk Assessment

a) The Permittee shall conduct human health and ecological risk

assessments as necessary for the protection of human health and the environment. These risk assessments shall be used to establish baseline risk at a site and/or to derive final or interim cleanup levels at the site. These risk assessments, if necessary, shall be performed concurrently with the corrective action activities specified in this permit, including any activities undertaken during implementation of the activities proposed in the RFI Work Plan. These risk assessments may also be performed concurrently with the RFI Final Report and Summary and the CMS Phase of this permit, as specified in Permit Condition IV.C.3 and P., respectively, but only after the Permittee has determined the full vertical and horizontal extent of contamination at each respective SWMU.

b) The Permittee shall utilize, but not be limited to, the following EPA documents and publications: "Compendium of ORD and OSWER Documents Relevant to RCRA Corrective Action" (EPA 530‐B‐92‐003, April 1992); "Ecological Assessments of Hazardous Waste Sites, A Field and Laboratory Reference Document" (EPA/600/3‐89/013, March 1989); "ECO Update, Ecological Assessment of Superfund Sites: An Overview" (Publication 9345.0‐05I, Vol. 1, No. 2, December 1991); and "ECO Update, Developing A Work Scope for Ecological Assessments" (Publication 9345.0‐05I, Vol. 1, No. 4, May 1992) including any subsequent revisions.



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(1) Baseline Risk Assessments ‐ Baseline risk assessments, if required, shall be used to evaluate the risks posed by contaminants at a site prior to the beginning of any corrective actions. This type of risk assessment shall be used in certain circumstances (specified in Permit Condition IV.C.3.b.2) instead of action levels (described in Permit Condition IV.C.2) to determine the need for remedial action.

(2) Although the action level concept shall serve as a trigger for a CMS (as specified in Permit Condition IV.P.) certain exceptions will apply, but not be limited to the following circumstances. In cases where the applicable action levels are not sufficiently protective of sensitive environmental systems such as wetlands, estuaries, and habitats of endangered or threatened species, the Permittee shall conduct a baseline environmental risk assessment. In cases where there are confirmed releases to groundwater, surface water, air, or sediments, a baseline risk assessment shall be required to determine the need for stabilization/interim measures, especially where health advisories have been issued by local/state governments. In addition, action levels may be inappropriate at a site where there are multiple contaminants or where leaching from contaminated soils into groundwater poses greater risk than ingestion of the soils.

(3) If an action level has been exceeded, for any of the environmental media of concern, at any time during the corrective action activities required by this permit, the Permittee may be required to conduct a risk assessment to determine risks to human health and the environment and the necessity to perform interim measures, as specified in Permit Condition IV.G. Risk assessments to determine final cleanup levels or to be used in justifying no further action determinations shall be conducted only after the Permittee has determined the full vertical and horizontal extent of contamination from each SWMU or groups of SWMU(s) specified in this permit.

c) Risk Assessments for Deriving Cleanup Levels ‐ Risk assessments, if

required, may also be used as a starting point for cleanup goals, in addition to the final cleanup level. Risk assessments may be required as specified in Permit Condition IV.C.3.b.2). In addition, where cleanup levels fail to incorporate significant routes of



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exposure at a particular site, or where remedies cannot meet the 10‐4 to 10‐6 risk range for carcinogens or meet action levels if chosen as final cleanup levels, a risk assessment may also be required.

The DEQ intends to review risk assessments as part of the CMS Phase of the corrective action activities specified in this permit in deriving final cleanup goals, but only after the Permittee has determined the full vertical and horizontal extent of contamination from each SWMU or groups of SWMU(s) specified in this permit.

d) Use of Risk Assessments in Justifying No Further Action ‐ The Permittee may submit a risk assessment(s) justifying no further action at a SWMU(s) concurrently with submittal of the RFI Final Report and Summary specified in Permit Condition IV.J., only if the Permittee has determined the full vertical and horizontal extent of contamination from each SWMU or group of SWMU(s) specified in this permit.

e) Corrective Action for Releases Beyond Facility Boundary ‐ Section

3004(v) of RCRA as amended by HSWA, and Federal regulations promulgated as 40 CFR 264.101(c), require corrective actions beyond the Facility property boundary, where necessary to protect human health and the environment, unless the Permittee demonstrates that, despite the Permittee's best efforts, the Permittee was unable to obtain the necessary permission to undertake such actions. The Permittee is not relieved of all responsibility to clean up a release that has migrated beyond the Facility boundary where offsite access is denied.

f) Financial Responsibility ‐ Assurances of financial responsibility for

corrective action shall be provided as specified in the permit following major modification for remedy selection.

4. Dispute Resolution

a) The parties shall use their best efforts to informally and in good faith

resolve all disputes or differences of opinion. If, however, disputes arise concerning the corrective action which the parties are unable to resolve informally, the following procedures shall apply. If Permittee's dispute concerns its inability to meet a specified deadline, then Permittee is obligated to advise the DEQ of the issue at least thirty (30) days in advance of the deadline.



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b) The DEQ shall provide Permittee written notice of its disapproval or modification of any interim submission under HSWA, including, but not limited to, implementation of work plans, approval of documents, scheduling of any work, or selection, performance, or completion of any corrective action. The written notice of disapproval or modification shall set forth the reasons for the disapproval or modification. If the Permittee disagrees, in whole or in part, with any such written notice, the Permittee shall notify the DEQ in writing, within ten (10) days of receipt of the written notice. The Permittee and the Land Protection Division’s RCRA Permits staff shall use their best efforts to informally and in good faith resolve the dispute. The Permittee is entitled to meet with Land Protection Division’s RCRA Permits staff in person at the DEQ's office or by teleconference, if it so desires, in order to resolve the dispute.

c) If Permittee and the Land Protection Division staff are unable to

resolve the dispute, the Permittee may request a final decision by the Division Director. Within thirty (30) days of receipt of the DEQ's written notice, the Permittee shall submit to the Division Director, a written statement of its arguments and explanations of its position. The written statement should include, at a minimum, the specific points of dispute, the position the Permittee maintains should be adopted as consistent with the Permit requirements and the basis therefore, any matters which it considers necessary for proper determination of the dispute, and whether the Permittee requests an informal conference in front of the Division Director. The Permittee's failure to follow the procedures set forth in this paragraph will constitute a waiver of its right to further consideration of the dispute.

d) The Division Director, at his/her discretion, will determine whether

an informal conference, if requested by the Permittee, will be held.

e) The DEQ shall consider the written position of the Permittee and the oral arguments, if an informal conference is convened, and shall provide a written statement of its decision based on the record. This statement shall be considered to be incorporated as an enforceable part of the permit. The written statement shall respond to the Permittee's arguments and shall set forth the reasons for the DEQ's final decision. Such decision shall be the final resolution of the dispute and shall be implemented immediately by the Permittee according to the schedule contained therein.



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f) Notwithstanding the invocation of this dispute resolution procedure, the Permittee shall proceed to take any action required by those portions of the submission and of the permit the DEQ determines are not substantially affected by the dispute.

g) The Permittee shall invoke the Dispute Resolution provisions of this

permit in good faith and not for purposes of delay.

D. REPORTING REQUIREMENTS

1. The Permittee shall submit, in accordance with Permit Condition IV.A.7, semi‐annual progress reports of all corrective measures activities (e.g., RFI, CMS) conducted pursuant to the provisions of this permit beginning no later than (45) forty five days from the end of each six‐month period (January 1 – June 30) and (July1 – December 31). These reports shall contain:

a) A description of the work completed and an estimate of the

percentage of work completed;

b) Summaries of all findings, including summaries of laboratory data;

c) Summaries of all problems or potential problems encountered during the reporting period and actions taken to rectify problems;

d) Projected work for the next reporting period;

e) Summaries of contacts pertaining to corrective action or

environmental matters with representatives of the local community, public interest groups or State government during the reporting period;

f) Changes in key project personnel during the reporting period; and

g) Summaries of all changes made in implementation during the

reporting period.

2. Copies of other reports relating to or having bearing upon the corrective action work, (e.g., inspection reports), drilling logs and laboratory data shall be made available to the DEQ upon request.



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E. NOTIFICATION REQUIREMENTS FOR AND ASSESSMENT OF NEWLY‐IDENTIFIED SWMU(s) AND POTENTIAL AOC(s)

1. The Permittee shall notify the DEQ, in writing, of any newly‐identified

SWMU(s) and potential AOC(s) (i.e., a unit or area not specifically identified during the RFA), discovered in the course of groundwater monitoring, field investigations, environmental audits, or other means, no later than thirty (30) calendar days after discovery. The Permittee shall also notify the DEQ of any newly‐constructed land‐based SWMU(s) (including but not limited to, surface impoundments, waste piles, landfills, land treatment units) and newly‐constructed SWMU(s) where any release of hazardous constituents may be difficult to identify (e.g., underground storage tanks) no later than thirty (30) days after construction. The notification shall include the following items, to the extent available:

a) The location of the newly‐identified SWMU or potential AOC on the

topographic map required under 40 CFR Section 270.14(b)(19). Indicate all existing units (in relation to other SWMU(s));

b) The type and function of the unit;

c) The general dimensions, capacities, and structural description of the

unit (supply any available drawings);

d) The period during which the unit was operated;

e) The specifics, to the extent available, on all wastes that have been or are being managed at the SWMU or potential AOC; and

f) Results of any sampling and analysis required for the purpose of

determining whether releases of hazardous waste including hazardous constituents have occurred, are occurring, or are likely to occur from the SWMU or whether the AOC should be considered a SWMU.

2. Based on the results of this Notification, the DEQ will designate the newly‐

identified SWMU(s) or AOC(s). Based on the results of this notification or investigation conducted according to Permit Conditions III.H, III.I or III.K, the DEQ will determine the need for further investigations or corrective measures at any newly‐identified SWMU(s) or AOC(s). If the DEQ determines that such investigations are needed, the DEQ may require the Permittee to prepare a plan for such investigations. The plan for investigation of SWMU(s) or AOC(s) will be reviewed for approval as part of the RFI Work Plan or a new RFI Work Plan under Permit Condition IV.K.3.



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The permit will be modified according to Permit Condition IV.A.3 to incorporate the investigation requirements for the newly‐identified AOC(s) identified pursuant to Permit Condition IV.J.1 or SWMU(s) identified pursuant to Permit Conditions III.E or III.G, if an investigation is required.

F. NOTIFICATION REQUIREMENTS FOR NEWLY‐DISCOVERED RELEASES AT SWMU(s)

AND AOC(s) The Permittee shall notify the DEQ in writing, no later than fifteen (15) calendar days after discovery, of any release(s) from a SWMU or AOC of hazardous waste or hazardous constituents discovered during the course of groundwater monitoring, field investigation, environmental auditing, or other means. Such newly‐discovered releases may be from newly‐identified SWMUs or AOCs, newly‐constructed SWMUs, or from SWMUs or AOCs for which, based on the findings of the RFA, completed RFI, or investigation of an AOC(s), the DEQ had previously determined no further investigation was necessary. The notification shall include information concerning actual and/or potential impacts beyond the Facility boundary and on human health and the environment, if available at the time of the notification. The DEQ may require further investigation and/or interim measures for the newly‐identified release(s), and may require the Permittee to prepare a plan for the investigation and/or interim measure. The plan will be reviewed for approval as part of the RFI Work Plan or a new RFI Work Plan under Permit Condition IV.H.3. The permit will be modified according to Permit Condition IV.A.3 to incorporate the investigation, if required.

G. INTERIM MEASURES If during the course of any activity initiated under this permit, the DEQ determines that a release or potential release of hazardous constituents from a SWMU or AOC poses a threat to human health and the environment, the DEQ may require interim measures. The DEQ shall determine the specific measure(s) or require the Permittee to propose a measure(s). The interim measure(s) may include a permit modification, a schedule for implementation, and a written plan. The DEQ shall notify the Permittee in writing of the requirement to perform interim measures. The DEQ may modify this permit according to Permit Condition IV.A.3 to incorporate interim measures into the permit.

1. The Permittee may propose interim measures at any time. The proposal

shall include a written plan and a schedule for implementation. Depending upon the nature of the interim measure, a permit modification may not be required.

2. The following factors will be considered by the DEQ in determining the

need for interim measures and the need for permit modification:

a) Time required to develop and implement a final remedy;



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b) Actual and potential exposure to human and environmental receptors;

c) Actual and potential contamination of drinking water supplies and

sensitive ecosystems;

d) The potential for further degradation of the medium in the absence of interim measures;

e) Presence of hazardous wastes in containers that may pose a threat

of release;

f) Presence and concentration of hazardous waste including hazardous constituents in soil that have the potential to migrate to groundwater or surface water;

g) Weather conditions that may affect the current levels of

contamination;

h) Risks of fire, explosion, or accident; and

i) Other situations that may pose threats to human health and the environment.

H. RFI WORK PLAN

1. The RFI Work Plan as specified in Permit Condition IV.H.1 shall be submitted

to the DEQ within one hundred eighty (180) days of the effective date of this permit. The RFI Work Plan must address releases of hazardous waste or hazardous constituents to all media, unless otherwise indicated in this permit.

a) The Work Plan shall describe the objectives of the investigation and

the overall technical and analytical approach to completing all actions necessary to characterize the direction, rate, movement, and concentration of releases of hazardous waste or hazardous constituents from specific units or groups of units, and their actual or potential receptors. The RFI Work Plan shall detail all proposed activities and procedures to be conducted at the Facility, the schedule for implementing and completing such investigations, the qualifications of personnel performing or directing the investigations, including contractor personnel, and the overall management of the RFI. The Scope of Work for a RCRA Facility Investigation (RFI) is in Permit Condition IV.P.



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b) The RFI Work Plan shall describe sampling, data collection quality

assurance, and data management procedures, including formats for documenting and tracking data and other results of investigations, and health and safety procedures.

c) Development of the RFI Work Plan and reporting of data shall be

consistent with the following EPA guidance documents or the equivalent thereof:

(1) RCRA Facility Investigation Guidance Document (EPA

530/SW‐89‐031, May 1989);

(2) RCRA Groundwater Monitoring: Draft Technical Guidance (EPA/530‐R‐93‐001, November 1992;

(3) RCRA Groundwater Monitoring Technical Enforcement

Guidance Document (OSWER 9950.1) September 1986; and

(4) Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW‐846, 3rd Edition, November 1992, with revisions.

2. After the Permittee submits the Work Plan, the DEQ will approve,

disapprove, or modify the Work Plan in writing.

If the DEQ approves the Work Plan, the Permittee shall begin implementation of the Plan within fourteen (14) days of receipt of approval, and implement it according to the schedule contained in the Plan. All approved work plans become incorporated into this permit pursuant to Permit Condition IV.A.8. In the event of disapproval (in whole or in part) of the Work Plan, the DEQ shall specify deficiencies in writing. The Permittee shall modify the Plan to correct these within the time frame specified in the notification of disapproval by the DEQ. The modified Work Plan shall be submitted in writing to the DEQ for review. Should the Permittee take exception to all or part of the disapproval, the Permittee shall submit a written statement of the grounds for the exception within ten (10) days of receipt of the disapproval pursuant to Permit Condition IV.C.4.

3. The DEQ shall review for approval as part of the RFI Work Plan, or as a new

Work Plan, any plans developed pursuant to Permit Condition IV.K addressing further investigations of newly‐identified SWMUs or AOCs, or



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Permit Condition IV.K addressing new releases from previously‐identified SWMUs or AOCs.

I. RFI IMPLEMENTATION

Upon receipt of written approval from the DEQ for the RFI Work Plan, the Permittee shall implement the RFI according to the schedules and in accordance with the approved RFI Work Plan and the following:

1. The Permittee shall notify DEQ at least ten (10) days prior to any field sampling, field testing, or field monitoring activity required by this permit to give DEQ personnel the opportunity to observe investigation procedures and/or split samples.

2. Deviations from the approved RFI Work Plan which are necessary during

implementation of the investigations must be approved by the DEQ and fully documented and described in the progress reports and in the RFI Final Report.

J. RFI FINAL REPORT AND SUMMARY

1. Within sixty (60) calendar days after the completion of the RFI, the Permittee shall submit an RFI Final Report and Summary. The RFI Final Report shall describe the procedures, methods, and results of all investigations as described in Permit Conditions IV.H, IV.I and IV.P. This includes SWMUs and AOCs and their releases, the type and extent of contamination at the Facility, sources and migration pathways, action levels, and actual or potential receptors. The RFI Final Report shall present all information gathered under the approved RFI Work Plan. The RFI Final Report must contain adequate information to support further corrective action decisions at the Facility. The Summary shall summarize the RFI Final Report.

2. After the Permittee submits the RFI Final Report and Summary, the DEQ

shall either approve or disapprove them in writing.

If the DEQ approves the RFI Final Report and Summary, the Permittee shall mail the approved Summary to all individuals on the Facility mailing list established pursuant to 40 CFR 124.10(c)(1)(ix), within fifteen (15) calendar days of receipt of approval. If the DEQ determines the RFI Final Report and Summary do not fully meet the objectives stated in Permit Condition IV.P, the DEQ may disapprove the RFI Final Report and Summary. If the DEQ disapproves the Report, the DEQ



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shall notify the Permittee in writing of the Report's deficiencies and specify a due date for submittal of a revised Final Report and Summary or the DEQ shall modify the report before approval. Once approved, the Summary shall be mailed to all individuals on the Facility mailing list as specified above, unless the Permittee takes exception to the conditions of the approved Report. If the Permittee takes exception to any portion of the Report approved by the DEQ, written notification of the exception(s) will be sent to the DEQ in accordance with dispute resolution provisions of Permit Condition IV.C.4.

3. Action levels, as discussed in Permit Condition IV.C.2, shall be used by the Permittee to determine the need for further corrective action under this permit. Action levels are one criterion which can be used to determine if a CMS is required. The concept of action levels is not the same as cleanup levels, although in some cases a final cleanup level may be set to equal the action level.

K. DETERMINATION OF NO FURTHER ACTION

1. Based on the results of the RFI and/or other relevant information, the

Permittee may submit an application to the DEQ for a Class III Permit modification under 40 CFR 270.42(c) to terminate the RFI/CMS process for a specific unit. This permit modification application must contain information demonstrating that there are no releases of hazardous waste including hazardous constituents from a particular SWMU at the Facility that pose threats to human health and/or the environment, as well as additional information required in 40 CFR 270.42(c).

If, based upon review of the Permittee's request for a permit modification, the results of the RFI, and other information, including comments received during the sixty (60) day public comment period required for Class III Permit modifications, the DEQ determines that releases or suspected releases which were investigated either are non‐existent or do not pose a threat to human health and/or the environment, the DEQ may grant the requested modification.

2. If necessary to protect human health or the environment, a determination

of no further action shall not preclude the DEQ from requiring continued or periodic monitoring of air, soil, groundwater, or surface water, when site‐specific circumstances indicate that releases of hazardous waste or hazardous constituents are likely to occur.

3. A determination of no further action shall not preclude the DEQ from

requiring further investigations, studies, or remediation at a later date, if



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new information or subsequent analysis indicates a release or likelihood of a release from a SWMU, or AOC at the Facility that is likely to pose a threat to human health or the environment. In such a case, the DEQ shall initiate a modification to the permit according to Permit Condition IV.A.3.

L. CORRECTIVE MEASURES STUDY (CMS) PLAN

1. If the DEQ has reason to believe that a SWMU or AOC has released

concentrations of hazardous constituents, or if the DEQ determines that contaminants present a threat to human health or the environment given action levels or site‐specific exposure conditions, the DEQ may require a CMS and shall notify the Permittee in writing. The notification may also specify remedial alternatives to be evaluated by the Permittee during the CMS.

2. The Permittee shall submit a CMS Plan to the DEQ within ninety (90)

calendar days from notification of the requirement to conduct a CMS. The Scope of Work for a CMS Plan is in Permit Condition IV.Q.

The CMS Plan shall provide the following information:

a) A description of the general approach to the investigation, and

potential remedies;

b) A definition of the overall objectives of the study;

c) Specific plans for evaluating remedies to ensure compliance with remedy standards;

d) Schedules for conducting the study; and

e) The proposed format for the presentation of information.

3. After the Permittee submits the CMS Plan, the DEQ will approve,

disapprove, or modify the Plan in writing.

If the DEQ approves the CMS Plan, the Permittee shall implement the Plan per Permit Condition IV.M. In the event of disapproval (in whole or in part) of the CMS Plan, the DEQ shall specify deficiencies in writing. The Permittee shall modify the Plan to correct these within the time frame specified in the notice of deficiency. The modified CMS Plan shall be submitted in writing to the DEQ for review. Should the Permittee take exception to the disapproval, decision, or



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directive, the Permittee shall submit a written statement of the grounds for the exception in accordance with dispute resolution provisions of Permit Condition IV.C.4.

M. CORRECTIVE MEASURES STUDY (CMS)

No later than fourteen (14) calendar days after the Permittee has received written approval from the DEQ for the CMS Plan, the Permittee shall begin implementation of the CMS and execute the Plan according to the schedules specified and in accordance with the approved CMS Plan. All approved plans become incorporated into this permit as per Permit Condition IV.A.8.

N. CMS FINAL REPORT AND SUMMARY

1. Within sixty (60) calendar days after the completion of the CMS, the Permittee shall submit a CMS Final Report and Summary. The Summary shall summarize the Final Report. The CMS Final Report shall discuss the results of investigations of each remedy studied and of any bench‐scale or pilot tests conducted. It must include an evaluation of each remedial alternative. The CMS Final Report shall present all information gathered during the CMS, and must contain adequate information to support the remedy selection process. In the CMS Final Report, the Permittee shall propose a corrective action program that shall:

a) attain compliance with corrective action objectives for hazardous

constituents in each medium, as established in Permit Condition III and IV.C;

b) control sources of releases;

c) meet acceptable waste management requirements; and

d) protect human health and the environment.

2. After the Permittee submits the CMS Final Report and Summary, the DEQ

will either approve or disapprove them in writing. Should the Permittee take exception to the disapproval, decision, or directive, the Permittee shall notify the DEQ according to Permit Condition IV.C.4.

If the DEQ approves the CMS Final Report and Summary, the Permittee shall mail the approved Summary to all individuals on the Facility mailing list established pursuant to 40 CFR 124.10(c)(1)(ix), within fifteen (15) calendar days of receipt of approval.



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If the DEQ determines the CMS Final Report and Summary do not fully meet the objectives stated in Permit Condition IV.Q, the DEQ may disapprove the CMS Final Report and Summary. If the DEQ disapproves the Report, the DEQ shall notify the Permittee in writing of the Report's deficiencies and specify a due date for submittal of a revised Final Report and Summary. Once approved, the Summary shall be mailed to all individuals on the Facility mailing list as specified above.

3. Based on preliminary results and the CMS Final Report, the DEQ may

require the Permittee to evaluate additional remedies or particular elements of one or more proposed remedies.

O. CORRECTIVE MEASURE (REMEDY) SELECTION AND IMPLEMENTATION

Within thirty (30) calendar days after approval of CMS Final Report and Summary, the DEQ shall initiate modification of the permit according to Permit Condition A.3, for corrective measure (remedy) selection, based on the approved CMS Final Report. The resultant modified permit will include schedules for remedy implementation.

P. RFI SCOPE OF WORK

1. Purpose

The purpose of the RFI is to determine the nature and extent of releases of hazardous wastes or hazardous constituents from SWMUs and AOCs. The required information shall include each item specified under Tasks I‐III. The Permittee shall furnish all personnel, materials, and services necessary for, or incidental to, performing the RFI. If the Permittee believes that certain requirements of the Scope of Work are not applicable, the specific requirements shall be identified and a detailed rationale for inapplicability shall be provided.

2. Scope

The RFI consists of three tasks:

Task I: RFI Work Plan

a. Introduction b. Environmental Setting c. Source Characterization



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d. Contamination Characterization e. Potential Receptor Identification f. Data Collection Quality Assurance Plan g. Data Management Plan h. Health and Safety Plan i. Community Information Repository

Task II: RCRA Facility Investigation Task III: RFI Final Report and Summary

3. Work Plan

The Permittee shall prepare a RFI Work Plan as specified in Permit Condition IV.H. and the following. The RFI Work Plan shall provide for and address the following information needs:

a) Introduction

(1) Facility Description

The introduction shall summarize the regional location, pertinent boundary features, general facility physiography, hydrogeology, and historical use of the Facility for the treatment, storage, or disposal of solid and hazardous waste. Information from existing reports and studies is acceptable, as long as the source of this information is documented, pertinent, and reflective of current conditions. This section shall include:

(a) Map(s) depicting the information specified below. All

maps shall be consistent with requirements set forth in 40 CFR 270.14 and shall be of sufficient detail and accuracy to locate all current and future work performed at the site.

i. general geographic location;



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ii. property lines, with the owners of all adjacent property clearly indicated, and all land previously owned and/or used by the Permittee around the Facility;

iii. topography, waterways, wetlands,

floodplains, water features, and drainage patterns;

iv. all tanks, buildings, utilities, paved areas, rights‐of‐way, and other features;

v. all SWMUs and AOCs;

vi. all known past solid or hazardous waste

treatment, storage and disposal areas or units regardless of whether they were active on or after November 19, 1980;

vii. surrounding land uses (residential,

commercial, agricultural, recreational); and

viii. the location of all production and groundwater monitoring wells. These wells shall be clearly labeled and ground and top of casing elevations included (these elevations may be included as an attachment).

(b) A history and description of ownership and operation,

solid and hazardous waste generation, treatment, storage and disposal activities at the Facility.

(c) A summary of approximate dates or periods of past

waste releases, identification of the materials released, the amount released, the location of the release, and a description of the response actions conducted (local, state, or federal response units, or private parties), including any inspection reports or technical reports generated as a result of the response.

(d) A reference to all environmental, geologic, and

hydrogeologic studies performed by all parties, at or near the Facility, with a short summary of the purpose, scope, and significant findings thereof.



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(e) A reference to all environmental Permits, applied for and/or received, the purpose thereof, and a short summary of requirements.

(2) Nature and Extent of Contamination

(a) The introduction shall summarize all possible source

areas of contamination. This, at a minimum, should include all SWMU(s) and AOC(s) requiring further investigation. For each area, the Permittee shall identify the following:

i. location of unit/area on a facility map;

ii. quantities of solid, hazardous, and

radiochemical wastes;

iii. quantities of radiochemical and hazardous constituents, to the extent known; and

iv. identification of areas where additional

information is necessary.

(b) The Permittee shall prepare an assessment and description of the existing degree and extent of contamination. This should include:

i. available monitoring data and qualitative

information on locations and levels of contamination at the Facility;

ii. all potential migration pathways including

information on geology, pedology, hydrogeology, physiography, hydrology, water quality, meteorology, and air quality; and

iii. the potential impact(s) on human health or

the environment, including demography, groundwater and surface water use, and land use.

(3) Implementation of Interim Measures

The Permittee shall document and report on all interim measures which have been or are being undertaken at the



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Facility, including under state or Federal compliance orders, other than those specified in the permit. The report shall include, as applicable:

(a) Objectives of the interim measures: how the measure

is mitigating a potential threat to human health or the environment and/or is consistent with and integrated into requirements for a long term solution;

(b) Schedules for design, construction and monitoring;

(c) Schedule for progress reports;

(d) Stabilization that has occurred at the site;

(e) Proposed further investigation and/or action; and

(f) Justification for limiting the scope of the RFI.

b) Environmental Setting

The Work Plan shall provide for collection of information to supplement and verify existing information on the environmental setting at the Facility. The Work Plan shall provide for characterization of the following:

(1) Hydrogeology

The Work Plan shall describe in detail a program to evaluate hydrogeologic conditions at the Facility. This program shall provide for at least the following information needs:

(a) A description of the regional, local, Facility‐wide, and

SWMU‐specific geologic and hydrogeologic characteristics affecting groundwater flow beneath the Facility;

(b) An analysis of any topographic features including

surface water bodies that might influence the groundwater flow system;

(c) A representative and accurate classification and

description of the hydrogeologic units which may be part of migration pathways at the Facility (i.e., the



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aquifers and any intervening saturated and unsaturated units) based on field data, tests (e.g., gamma and neutron logging of existing and new wells, piezometers and borings), and cores;

(d) The extent (depth, thickness, lateral extent) of

hydrogeologic units which may be part of migration pathways based on field studies and cores, structural geology, and hydrogeologic cross sections, including:

i. unconsolidated sand and gravel deposits;

ii. zones of fracturing or channeling in

consolidated or unconsolidated deposits; and

iii. zones of high permeability or low permeability that might direct and restrict the flow of contaminants.

(e) A description of representative water level or fluid

pressure based on data obtained from groundwater monitoring wells and piezometers installed upgradient and downgradient of the potential contaminant source. Information needs include: potentiometric surface maps; hydrologic cross sections showing vertical gradients; vertical and horizontal components of flow; temporal changes in hydraulic gradients; and flow nets;

(f) A description of man‐made influences that may affect

site hydrogeology such as active and inactive local water‐supply and production wells, pipelines, French drains, and ditches.

(2) Soils

The Permittee shall describe in detail a program designed to characterize soil and rock units above the water table. Such characterization shall include, but is not limited to, the following information: subsurface soil distribution; soil profile, including ASTM and USCS classifications of soils; transects of soil stratigraphy; saturated hydraulic conductivity; porosity; cat ion exchange capacity (CEC); soil pH; particle size distribution; depth to water table; moisture



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content; effect of stratification on unsaturated flow; infiltration; evapotranspiration; residual concentration of contaminants in soil; total natural organic carbon content; and mineral and metal content.

c) Source Characterization

The Permittee shall describe in detail a program designed to completely characterize the wastes and the areas where wastes have been placed, including: type, quantity, physical form, composition, disposition (containment and nature of wastes), and the facility characteristics affecting releases (e.g., facility security, engineered barriers). This shall include quantification of the following specific characteristics, at each source area:

(1) Unit/disposal area characteristics, including but not limited

to: location of unit/disposal area; type of unit/disposal area; design features; operating practices (past and present); period of operation; age of unit/disposal area; general physical conditions; and method used to close the unit/disposal area;

(2) Waste characteristics, including but not limited to: type of

waste placed in unit (hazardous classification, quantity, chemical composition); physical and chemical characteristics (physical form, physical description, temperature, pH, general chemical class, molecular weight, density, boiling point, viscosity, solubility in water, solubility in solvents, cohesiveness, vapor pressure); and migration and dispersal characteristics of the waste (sorption coefficients, biodegradability, photodegradation rates, hydrolysis rates, chemical transformations).

d) Contamination Characteristics

The Permittee shall describe in detail a program to collect analytical data on groundwater, soils, surface water, sediment, and subsurface gas contamination when necessary to characterize contamination from a SWMU. The data shall be sufficient to define the extent, origin, direction, and rate of movement of contaminant plumes. Data required shall include time and location of sampling, media sampled, concentrations found, conditions during sampling, and the identity of the individual(s) performing the sampling and analysis. All media (groundwater, surface water and sediments, soil, air, and



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gas) must be investigated. If the Permittee believes certain media could not be affected by a release from a specific unit, a detailed justification for not investigating those media must be provided. The Permittee shall address the following types of contamination at the Facility as appropriate:

(1) Groundwater Contamination

The Work Plan shall describe in detail a program of groundwater investigation to characterize any groundwater plumes of contamination at the Facility that are not subject to corrective action requirements of 40 CFR Section 264.100. The program shall at a minimum provide for the following information needs:

(a) a description of the horizontal and vertical extent of

any immiscible or dissolved plume(s) originating from the Facility;

(b) the horizontal and vertical direction of contamination

movement;

(c) the velocity of contaminant movement;

(d) an evaluation of factors influencing the plume movement; and

(e) an extrapolation of future contaminant movement.

(2) Soil Contamination

The Permittee shall describe in detail a program to characterize contamination of soil and rock units above the water table in the vicinity of the contaminant release. The program shall provide for the following information needs:

(a) a description of the vertical and horizontal extent of

contamination;

(b) a description of contaminant and soil chemical properties within the contaminant source area. This includes contaminant solubility, speciation, adsorption, leachability, exchange capacity, biodegradability, hydrolysis, photolysis, oxidation,



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natural total organic carbon content, and other factors that might affect contaminant migration and transformation;

(c) plume migration and transformation; specific

contaminant concentrations; the velocity and direction of contaminant movement; and an extrapolation to future contaminant movement.

(3) Surface Water and Sediment Contamination

The Permittee shall describe in detail a program to characterize contamination in surface water bodies and sediment resulting from contaminant releases at the Facility. The investigation shall at minimum include the following:

(a) a description of the surface water body including

location, elevation, flow, velocity, depth, width, seasonal fluctuations, flooding tendencies, drainage patterns, and evapotranspiration rates;

(b) a description of sediment characteristics including

depositional area, thickness, mineralogy, grain size, density, ion exchange capacity, and total natural organic carbon content;

(c) maps for all areas included in surface water and

sediment investigations which meet requirements in 40 CFR 270.14 and which are sufficiently detailed and accurate to depict all the information required;

(d) a description of the horizontal and vertical extent of

any immiscible or dissolved plumes originating from the Facility, and the extent of contamination in the underlying sediments;

(e) the horizontal and vertical direction and velocity of

contaminant movement;

(f) an evaluation of the physical, biological, chemical, and radiochemical factors influencing contaminant movement;



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(g) an extrapolation to future contaminant movement; and

(h) a description of the chemistry of the contaminated

surface waters and sediments. This includes pH, temperature, total dissolved solids, total suspended solids, biochemical oxygen demand, alkalinity, conductivity, dissolved oxygen profiles, nutrients, chemical oxygen demand, total organic carbon, and specific contaminant concentrations.

(4) Air Contamination

The Permittee shall describe in detail a program to characterize particulate and gaseous contaminants released into the atmosphere. This investigation shall provide the following information: a description of the horizontal and vertical direction and velocity of contaminant movement; the rate and amount of the release; and the chemical, radiochemical, and physical composition of the contaminants released, including horizontal and vertical concentration profiles.

(5) Subsurface Gas

The Permittee shall describe in detail a program to characterize the nature, rate and extent of releases of reactive gases from the units. Such a program shall include, but is not limited to provisions for monitoring subsurface gases released from the unit and an assessment of the potential for threat to human health and/or the environment.

e) Potential Receptors

The Permittee shall describe in detail a program to collect data to describe human populations and environmental systems that are susceptible to contaminant exposure from the Facility. Chemical and radiochemical analysis of biological samples may be needed. Data on observable effects in ecosystems may also be required. The following characteristics shall be identified:

(1) Local uses and possible future uses of groundwater

including:



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(a) type of use (i.e., potable, domestic, agricultural,

residential, industrial, municipal); and

(b) location of all groundwater wells, names of owners or tenants at those locations, USGS/DODT well designations, and current use of those wells within a 1 mile radius of facility.

(2) Local uses and possible future uses of surface waters within a

1.5 mile radius of the Facility, including domestic and municipal, recreational, agricultural, industrial, and environmental;

(3) Human use of or access to the Facility and adjacent lands,

including but not limited to recreation, hunting, residential, commercial, and industrial;

(4) A demographic profile of people who use or have access to

the Facility and adjacent land, including, but not limited to age, gender, and sensitive subgroups;

(5) A description of the local ecology, including biota in surface

water bodies on, adjacent to, or affected by the Facility, and a description of any endangered or threatened species near the Facility.

f) Data Collection Quality Assurance Plan

The Permittee shall prepare a plan to document all monitoring procedures sampling, field measurements, and sample analysis performed at the Facility during the investigation to characterize the environmental setting, source, and contamination, so as to ensure that all information, data, and resulting decisions are technically sound, statistically valid, and properly documented.

(1) The strategy section of the Data Collection Quality Assurance

Plan shall include but not be limited to the following:

(a) description of the intended uses for the data, and the necessary level of precision and accuracy for those intended uses;



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(b) description of methods and procedures to be used to assess the precision, accuracy and completeness of the measurement data; and

(c) schedule and information to be provided in quality

assurance reports, including at least:

i. periodic assessment of measurement data accuracy, precision, and completeness;

ii. results of performance audits;

iii. results of systems audits; and

iv. significant quality assurance problems and

resolutions.

(2) The Sampling and Field Measurements Section of the Data Collection Quality Assurance Plan shall at least discuss:

(a) selecting appropriate sampling and field

measurements locations, depths, etc.;

(b) providing a statistically sufficient number of sampling and field measurement sites;

(c) determining conditions under which sampling or field

measurements shall be conducted;

(d) determining which parameters are to be measured and where;

(e) selecting the frequency of sampling and length of

sampling period;

(f) selecting the types of sample (e.g., composites vs. grabs) and number of samples to be collected;

(g) delineating procedures designed to prevent

contamination of sampling or field measurements equipment and cross contamination between sampling points;



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(h) documenting field sampling operations and procedures;

(i) selecting appropriate sample containers;

(j) preserving samples;

(k) controlling chain‐of‐custody; and

(l) disposing of all contaminated materials generated by

activities in a manner compliant with all state and Federal regulations.

(3) The Sample Analysis shall include:

(a) Chain‐of‐custody procedures;

(b) sample storage procedures and holding times;

(c) sample preparation methods;

(d) analytical procedures;

(e) calibration procedures and frequency;

(f) data reduction, validation and reporting; and

(g) frequency of internal quality control checks and

laboratory performance audits.

g) Data Management Plan

The Permittee shall develop and initiate a Data Management Plan to document and track investigation data and results. This plan shall identify and set up data documentation materials and procedures (data record), project file requirements, and project‐related progress reporting procedures and documents.

(1) The data record shall include at least the following for all

sample and field measurements: unique measurement code; measurement location; measurement type; laboratory ID number; property or component analyzed; and results of analyses.



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(2) The Data Management Plan shall provide the format to be used to present the data and conclusions of the investigation, etc.

(a) The following shall be presented in tables: raw data;

data sorted by significant features such as location, media, constituent; data reduction for statistical analysis; and summary data.

(b) The following shall be presented in graphical formats

(e.g., bar graphs, line graphs, plan maps, isopleth plots, cross‐sections, three‐dimensional displays, etc.): sampling location and grid; levels of contamination at each sampling location; geographical extent of contamination; and changes in concentration relative to source, time, depth, and other parameters.

h) Health and Safety Plan

(1) The Permittee shall prepare a facility Health and Safety Plan,

which shall include:

(a) a description of the Facility including availability of resources such as roads, water supply, electricity and telephone service;

(b) a description of the known hazards and evaluation of

the risks associated with each activity conducted, including but not limited to on‐ and off‐site exposure to contaminants during implementation of interim measures;

(c) a list of key personnel and alternatives responsible

for site safety, response operations, and for protection of public health;

(d) a delineation of the work area;

(e) a description of levels of protection to be worn by

personnel in the work area;

(f) procedures established to control site access;



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(g) decontamination procedures for personnel and equipment;

(h) site emergency procedures;

(i) emergency medical care procedures for injuries and

toxicological problems;

(j) requirements for an environmental field monitoring program;

(k) routine and special training requirements for

responders; and

(l) procedures for protecting workers from weather‐related problems.

(2) The Facility Health and Safety Plan shall be consistent with:

(a) NIOSH Occupation Safety and Health Guidance

Manual for Hazardous Waste Site Activities (1985);

(b) EPA Order 1440.1 ‐ Respiratory Protection;

(c) EPA Order 1440.3 ‐ Health and Safety Requirements for Employees Engaged in Field Activities;

(d) Approved Facility Contingency Plan;

(e) EPA Operating Safety Guide (1984);

(f) OSHA regulations, particularly 29 CFR 1910 and 1926;

(g) State and local regulations; and

(h) Other EPA guidance as provided.

i) Community Information Repository

Information and reports related to permit required monitoring, investigations, corrective measures, if implemented, and permit related DEQ correspondence will be placed in the public information repository as it becomes available as well as in the Facility RCRA Permit document file room.



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4. Task II: RCRA Facility Investigation

The Facility investigation activities shall follow the RFI Work Plan. All sampling and analyses shall be conducted in accordance with the Data Collection Quality Assurance Plan. All sampling locations shall be documented in a log and identified on a detailed site map. During the RFI, it may be necessary to revise the RFI Work Plan to increase or decrease the detail of information collected to accommodate the facility specific situation. The Permittee shall conduct investigations of SWMU(s), and AOC(s) previously identified with known or suspected releases of contamination to characterize the Facility (Environmental Setting), define the source (Source Characterization), define the degree and extent of contamination (Contamination Characterization), and identify actual or potential receptors. The investigations should result in data of adequate technical quality to develop and evaluate corrective measures alternatives during the Corrective Measures Study, when necessary.

5. Task III: RFI Final Report and Summary

The Permittee shall analyze all Facility investigation data collected during the RFI process and prepare a detailed report on the type and extent of contamination at the Facility including sources and migration pathways. All information generated during the investigation shall be presented and analyzed. All evidence and procedures used for making any determinations (e.g., velocity of groundwater, extent of contamination) shall be fully documented. The report shall describe the extent of contamination (qualitative/quantitative) in relation to background levels indicative for the area. The report shall contain the results of all tests, calculations, inspections, record searches, and observations. It shall contain soil and groundwater contamination profiles, statistical comparisons, and the results of all sampling events conducted as part of the investigation. It shall display results in tables, graphs, maps, and cross sections as discussed in the Data Management Plan and Permit Condition IV.P.3.g.2. The Permittee shall identify all relevant and applicable standards for the protection of human health or the environment (e.g., National Ambient Air Quality Standards, Federally‐approved State water quality standards, groundwater protection standards, etc.). Data shall be evaluated to ensure it is sufficient in quality (e.g., quality assurance procedures have been followed) and quantity to describe the nature and extent of contamination, to evaluate the potential threat to human health or the environment, and to support a CMS, if required. The report shall present all data in an Appendix.



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6. General RFI Reporting Requirements

a) Two (2) hard copies and one electronic disk copy of all reports and data shall be submitted by the Permittee to the DEQ as specified in Permit Condition IV.A.7.

b) The RFI Work Plan shall be submitted by the Permittee to the DEQ

as described in Permit Condition IV.H.

c) The RFI Final Report and Summary shall be submitted by the Permittee to the DEQ as described in Permit Condition IV.J.

d) Within ninety (90) days of the effective date of this permit, the

Permittee shall provide the DEQ with signed, semi‐annual progress reports as specified in Permit Condition IV.D.1.

Q. CMS SCOPE OF WORK

1. Purpose

The purpose of the CMS is to develop and evaluate corrective measures alternatives and to recommend the corrective measure or measures to be taken. The required information shall include each item specified under CMS Tasks IV‐VI. The Permittee will furnish the personnel, materials, and services necessary to prepare the CMS, except as otherwise specified. If the Permittee believes that certain requirements of the Scope of Work are not applicable, the specific requirements shall be identified and the rationale for inapplicability shall be provided.

2. Scope

The CMS consists of three tasks:

Task IV: CMS Plan

a. Description of Current Situation b. Establishment of Corrective Action Objectives c. Description of Approach to CMS d. Schedule for CMS



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Task V: CMS

a. Identification of Corrective Measures Alternatives(s) b. Screening of Corrective Measures Alternatives(s) c. Development of Corrective Measures Alternative(s) d. Evaluation of Corrective Measures Alternative(s) e. Selection of Corrective Measures Alternative(s)

Task VI: CMS Final Report and Summary

3. Task IV: CMS Plan

a) Description of Current Conditions

The Permittee shall briefly describe current conditions at the Facility to update information provided in the RFI Final Report and Summary. This shall include previous and/or ongoing remedial activity or interim measures.

b) Establishment of Corrective Action Objectives

The Permittee shall propose to the DEQ for review and approval Facility specific objectives for the corrective action. These objectives shall be based on public health and environmental criteria, information gathered during the RFI, EPA guidance, and the requirements of any applicable Federal statutes and regulations.

c) Description of Approach to CMS

The Permittee shall describe the general approach to the corrective measures study. The approach shall include identification, development, screening, and evaluation of the corrective measures alternatives, as discussed in detail in Permit Condition IV.Q.4. The Permittee shall describe specific plans for laboratory and bench‐scale studies, or field studies, if needed. Specific plans for evaluating remedy effectiveness shall also be developed. The approach shall specify formats to be used for data presentation, including raw data, maps, charts, graphs, engineering schematics, construction design, etc.



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d) Schedule

The Permittee shall develop a schedule for implementing the corrective measures study, and a schedule for submitting quarterly progress reports on the study implementation.

4. Task V: CMS

The CMS consists of five parts: identification, screening, development, evaluation, and selection of the corrective measures alternative(s).

a) Identification of Preliminary Corrective Measures Alternative(s)

Based on the results of the RFI and the CMS Plan objectives, the Permittee shall identify all possible alternatives for removal, containment, treatment and/or other remediation of the contamination.

b) Screening of Preliminary Corrective Measures Alternatives

The Permittee shall screen the identified preliminary corrective measures alternatives to eliminate those that may not prove feasible to implement, that rely on technologies unlikely to perform satisfactorily or reliably, or that do not achieve the corrective action objective within a reasonable time period. This screening process focuses on eliminating those technologies which have severe limitations for a given set of waste and site‐specific conditions. The screening step may also eliminate technologies based on inherent technological limitations.

Site, waste, and technological characteristics which are used to screen inapplicable technologies are described in more detail below:

(1) Site Characteristics. Site data should be reviewed to

identify conditions which may limit or promote the use of certain technologies. Technologies which are clearly precluded by site characteristics should be eliminated from further consideration;

(2) Waste Characteristics. Identification of waste characteristics

that limit the effectiveness or feasibility of technologies is an important part of the screening process. Technologies clearly limited by waste characteristics should be eliminated from consideration;



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(3) Technological Limitations. The level of technology

development, performance record, and operation and maintenance problems shall be identified for each technology considered. Technologies that are unreliable, perform poorly, or are not fully demonstrated may be eliminated in the screening process.

c) Development of Corrective Measures Alternatives

The Permittee shall develop corrective measures alternatives based on corrective measures objectives, and identification and screening of preliminary alternatives. The Permittee shall rely on engineering practice to determine which of the previously identified and screened technologies appear most suitable for the site. Technologies can be combined to form the overall corrective measures alternatives. The alternatives developed should represent a workable number of options that each appears to adequately address all site problems and corrective action objectives. Each alternative may consist of an individual technology or a combination of technologies. The Permittee shall document the reasons for excluding technologies.

When a new technology is proposed or similar waste streams have not routinely been treated or disposed of using the technology, the Permittee shall conduct laboratory and/or bench‐scale studies to determine the applicability to Facility conditions. The Permittee shall analyze the technologies, based on literature review, vendor contracts, and past experience to determine the testing requirements.

(1) The Permittee shall develop a testing plan identifying the

type(s) and goal(s) of the study(ies), the level of effort needed, and the procedures to be used for data management and interpretation.

(2) Upon completion of testing, the Permittee shall evaluate the

testing results to assess the technology or technologies with respect to the site‐specific questions identified in the test plan.

(3) The Permittee shall prepare a report summarizing the testing

program and its results, both positive and negative.



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d) Evaluation of Corrective Measures Alternative(s)

The Permittee shall evaluate each corrective measures alternative developed in Permit Condition IV.Q.4.c. The evaluation shall be based on technical, environmental, human health and institutional concerns. The Permittee shall also develop cost estimates for each corrective measure.

(1) Technical, Environmental, Human Health, and Institutional

Concerns

The Permittee shall provide a description of each corrective measures alternative which includes but is not limited to the following: preliminary process flow sheets; preliminary sizing and type of construction for buildings and structures; and rough quantities of utilities required. The Permittee shall evaluate each alternative in the four following areas:

(a) Technical

The Permittee shall evaluate each corrective measure alternative based on performance, reliability, implementability and safety.

i. The Permittee shall evaluate performance

based on the effectiveness and useful life of the corrective measure:

(a) Effectiveness shall be evaluated in

terms of the ability to perform intended functions such as containment, diversion, removal, destruction, or treatment. The effectiveness of each corrective measure shall be determined either through design specifications or by performance evaluation. Any specific waste or site characteristics which could potentially impede effectiveness shall be considered. The evaluation should also consider the effectiveness of combinations of technologies.



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(b) Useful life is defined as the length of time the level of effectiveness can be maintained. Each corrective measure shall be evaluated in terms of the projected service lives of its component technologies. Resource availability in the future life of the technology, as well as appropriateness of the technologies, must be considered in estimating the useful life of the project.

ii. The Permittee shall provide information on

the reliability of each corrective measure including operation and maintenance requirements and demonstrated reliability:

(a) Operation and maintenance

requirements include the frequency and complexity of operation and maintenance. Technologies requiring frequent or complex operation and maintenance activities should be regarded as less reliable than technologies requiring little or straightforward operation and maintenance. The availability of labor and materials to meet these requirements shall also be considered;

(b) Demonstrated and expected reliability

is a way of measuring risk and effect of failure. The Permittee should evaluate whether technologies have been used effectively under analogous conditions; whether the combination of technologies have been used together effectively; whether failure of any one technology has an immediate impact on receptors; and whether the corrective measure has the flexibility to deal with uncontrollable changes at the site.



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iii. The Permittee shall describe the implementability of each corrective measure including relative ease of installation (constructability) and total time required to achieve a given level of response:

(a) Constructability is determined by

conditions both internal and external to Facility conditions and includes such items as location of underground utilities, depth to water table, heterogeneity of subsurface materials, and location of facility (i.e., remote location vs. congested urban area). The Permittee shall evaluate what measures can be taken to facilitate construction under site specific conditions. External factors which affect implementation include the need for special Permits or agreements, equipment availability, and the location of suitable off‐site treatment or disposal facilities;

(b) Time has two components to be

addressed: the time it takes to implement a corrective measure and the time it takes to see beneficial results. Beneficial results are defined as the reduction of contaminants to acceptable levels as established in the corrective measures objectives.

iv. The Permittee shall evaluate each corrective

measures alternative with regard to safety. This evaluation shall include threats to the safety of nearby communities and environments as well as those to workers during implementation. Factors to consider include fire, explosion, and exposure to hazardous substances.



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(b) Environmental

The Permittee shall perform an Environmental Assessment for each alternative. The assessment shall focus on Facility conditions and pathways of contamination actually addressed by each alternative. The Environmental Assessment for each alternative will include at a minimum, an evaluation of the short‐ and long‐term beneficial and adverse effects of the response alternative, evaluation of any adverse effects on environmentally‐sensitive areas, and an analysis of measures to mitigate adverse impacts.

(c) Human Health

The Permittee shall assess each alternative in terms of the extent to which it mitigates short‐ and long‐term potential exposure to any residual contamination and protects human health both during and after implementation of the corrective measure. The assessment will describe the levels and characterizations of contaminants on‐site, potential exposure routes, and potentially affected populations. Each alternative will be evaluated to determine the level of exposure to contaminants and the reduction over time. For management of mitigation measures, the relative reduction of impact will be determined by comparing residual levels of each alternative with existing criteria, standards, or regulations acceptable to the DEQ.

(d) Institutional

The Permittee shall assess relevant institutional needs for each alternative. Specifically, the effects of federal, state, and local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations on the design, operation, and timing of each alternative shall be considered.



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(2) Cost Estimate

The Permittee shall develop an estimate of the cost of each corrective measures alternative and for each phase or segment of the alternative. The cost estimate shall include capital, and operation and maintenance costs.

(a) Capital costs consist of direct and indirect costs.

i. Direct capital costs include:

(a) Construction costs: Cost of materials,

labor (including fringe benefits and workers’ compensation), and equipment required to install the corrective measures alternative;

(b) Equipment costs: Costs of treatment,

containment, disposal and/or servicing of equipment used to implement the action;

(c) Land and site development costs:

Expenses associated with purchase of land and development of existing property; and

(d) Building and services costs: Costs of

process and non‐process buildings, utility connections, purchased services, and disposal costs.

ii. Indirect capital costs include:

(a) Engineering expenses: Costs of

administration, design, construction, supervision, drafting, and testing of corrective measures alternatives;

(b) Legal fees and license or permit costs:

Administrative and technical costs necessary to obtain licenses and permits for installation and operation;



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(c) Start‐up and shakedown costs: Costs incurred during corrective measure start‐up; and

(d) Contingency allowances: Funds to

cover costs resulting from unforeseen circumstances such as adverse weather conditions, strikes, and inadequate facility characterization.

(b) Operation and maintenance costs are post‐

construction costs necessary to ensure continued effectiveness of a corrective measure. The Permittee shall consider the following operation and maintenance cost components:

i. Operating labor costs: Wages, salaries,

training, overhead, and fringe benefits associated with the labor needed for post‐construction operation;

ii. Maintenance materials and labor costs: Costs

for labor, parts, and other resources required for routine maintenance of facilities and equipment;

iii. Auxiliary materials and energy: Costs of such

items as chemicals and electricity for treatment plant operations, water and sewer service, and fuel;

iv. Purchased services: Sampling costs, laboratory

fees, and professional fees which can be predicted;

v. Disposal and treatment: Costs of

transporting, treating, and disposing of waste materials, such as treatment plant residues, generated during operation;

vi. Administrative costs: Costs associated with

administration of corrective measures operation and maintenance not included under other categories;



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vii. Insurance, taxes, and licensing costs: Costs of

such items as liability and accident insurance; real estate taxes on purchased land or rights‐of‐way; licensing fees for certain technologies; and permit renewal and reporting costs;

viii. Maintenance reserve and contingency funds:

Annual payments into escrow funds to cover costs of anticipated replacement or rebuilding of equipment, and any large unanticipated operation and maintenance costs; and

ix. Other costs: Items that do not fit any of the

above categories.

e) Selection of Corrective Measures Alternative(s)

The Permittee shall select a corrective measures alternative using technical, human health, and environmental criteria. At a minimum, the following criteria shall be used to select the final corrective measure or measures.

(1) Technical

(a) Performance. Corrective measure or measures which

are most effective at performing their intended functions and maintaining performance over extended periods of time will be given preference;

(b) Reliability. Corrective measure or measures which do

not require frequent or complex operation and maintenance activities and have proven effective under conditions similar to those anticipated will be given preference;

(c) Implementability. Corrective measures or measures

which can be constructed and operated to reduce levels of contamination to attain or exceed applicable standards in the shortest period of time will be preferred; and

(d) Safety. Corrective measure or measures which pose

the least threat to the safety of nearby residents and



IV‐50

environments as well as workers during implementation will be preferred.

(2) Human Health

The corrective measure or measures must comply with existing EPA criteria, standards, or regulations for the protection of human health. Corrective measures which provide the minimum level of exposure to contaminants and the maximum reduction in exposure with time are preferred.

(3) Environmental

The corrective measure or measures imposing the least adverse impact or greatest improvement on the environment over the shortest period of time will be preferred.

5. Task VI: CMS Final Report and Summary

The Permittee shall prepare a CMS Final Report and Summary presenting the results of the CMS and recommending a corrective action program. The Report shall at a minimum include:

a) A summary of all the corrective measures alternatives originally

identified, and the screening rationale employed. The results of development of each alternative shall be described, and the evaluation of those developed shall be presented in detail. The report will describe the rationale for selection of a corrective measures alternative, including performance expectations, preliminary design criteria and rationale, general operation and maintenance requirements, and long‐term monitoring requirements. The report shall include summary tables which allow the alternative or alternatives to be easily understood. Trade‐offs among health risks, environmental effects, and other pertinent factors shall be highlighted;

b) A proposed corrective action program that will attain compliance

with concentration level objectives, control sources of releases, meet acceptable waste management requirements, and protect human health and the environment;

c) Design and implementation precautions, including special technical

problems, additional engineering data required, permits and



IV‐51

regulatory requirements, access, easements, and rights‐of‐way, health and safety requirements, and community relations activities;

d) Cost estimates and schedules including capital cost estimate,

operation and maintenance cost estimate, and project schedule (design, construction, operation); and

e) A schedule for corrective measure (remedy) implementation.

6. General CMS Reporting Requirements

a) Two hard copies and one electronic disk copy of all reports shall be

submitted by the Permittee to the DEQ as specified in Permit Condition IV.A.7.

b) The CMS Plan shall be submitted by the Permittee to the DEQ as

described in Permit Condition IV.L.

c) The CMS Final Report and Summary shall be submitted by the Permittee to the DEQ as described in Permit Condition IV.N.

d) Within ninety (90) days of the date the Permittee is notified to begin

a CMS, the Permittee shall provide the DEQ with signed, semi‐annual progress reports as specified in Permit Condition IV.D.1.



IV‐52

Table 1: RFI/CMS & COMPLIANCE REPORT SUBMISSION SUMMARY Below is a summary of the planned reporting requirements pursuant to this Permit: Actions Due Date Progress reports on all activities Semi‐annually; within or on forty‐five (45)

calendar days following the end of each six month reporting period that ends on June 30 and December 31.

RFI Work Plan One hundred and eighty (180) calendar days after the effective date of the permit if required.

Revised RFI Work Plan As determined by DEQ, not less than thirty (30) calendar days of receipt of NOD

RFI Report and Summary Sixty (60) calendar days after completion of RFI

Revised RFI Report and Summary As determined by DEQ, not less than thirty (30) calendar days of receipt of NOD

Notification of newly identified SWMU(s) Thirty (30) calendar days after discovery

Notification of newly discovered releases Fifteen (15) calendar days after discovery

Interim Measures Plan As determined by DEQ

Revised Interim Measure Plan As determined by DEQ

CMS Plan Ninety (90) calendar days after notification of requirement to perform CMS

Revised CMS Plan As determined by DEQ, not less than thirty (30) calendar days of receipt of NOD

CMS Final Report and Summary

Sixty (60) calendar days after completion of CMS

Revised CMS Final Report As determined by the DEQ, not less than thirty (30) calendar days after receipt of NOD

Demonstration of Financial Assurance at Facility One hundred and twenty (120) calendar days modification to implement corrective measures after permit

FIGURES

Produced using ArcGIS 10.0 SP1

LegendRefinery Property Boundary100 Year Flood Plain

Figure

4770 Duke DriveSuite 300Mason, Ohio 45040

Phone: (513) 459-9677Fax: (513) 459-9869www.hullinc.com

© 2011, Hull & Associates, Inc.

File Name: HRM004_08_FigIII-A_Floodplain.mxdGeodatabase: HRM012.mdb

0 400 800200

Feet

1:9,600

Edited: 9/22/2011 By: jslifer

III-A100 YearFlood Plain

Holly Refining and Marketing - Tulsa, LLC (Tulsa East Refinery)

902 West 25th StreetTulsa, Tulsa County, Oklahoma

October 2011

Note:Flood plains downloaded from the FEMA Map ServiceCenter. Data last updated on 8/3/09.

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

MWDP-3MWDP-1

MWDP-2

MWII-E7

MWII-E8

MWII-E5

MWII-D4

MWII-D7

MWII-D8

MWII-SL3

MWII-SL2

MWII-SL1

MWII-API7

MWII-API6

WGPZ-8

WGPZ-5

WGPZ-6WGPZ-2

TP-8

TP-1TP-7 TP-4

E-27

MWC-2

MWC-1

SR-15

MWD-1SR-14

SR-17

MWE-2

MWE-1

SR-10

MWD-2

SR-22

SR-23

SR-05

MW-263

MW-262

MW-261

MW-260

MW-259

MW-257

MW-252

AEP-05

AEP-02

WTP-10

WTP-11

TX-110

TX-102

TX-033

TX-023

TX-031

TX-068

TX-101

WTP-14

WGL-15

TX-059

TX-067

TX-071

TX-103

TX-065

TX-077

TX-006

TX-047

TX-007

TX-010

TX-127

TX-004

TX-011

TX-140

WTP-13TX-040

TX-153

TX-150

WTP-08

WTP-09

TX-148

WTP-17

TX-080

TX-141

TX-082

TX-026

TX-092

TX-100

SX-156

TX-132

TX-063

MWDP-4

TX-064

TX-089

WTP-12

SX-162

SX-163

SX-164

SX-165

SOC-011

SOC-008

SOC-014

SOC-003SOC-020

SOC-002

MWAPI-2

MWII-B3

MWII-B2

MWII-A1

MWII-C5

MWII-D5

SOC-014B

MW-264

MW-258

MW-256MW-255MW-254

MW-253

MW-251

AEP-06

AEP-04

TX-002

TX-139

TX-066

TX-136

MWDP-3R

SOC-019SOC-018

SOC-017

MWAPI-1

MWAPI-3

MWAPI-5

MWAPI-4

MWII-C4

SR-26

SR-27

SR-28

SR-08

SR-31

SR-30

SR-07

SR-19

SR-02

SR-09

SR-01SR-12

SR-13

SR-06

MWD-3

SR-04

SR-24

TX-105

TX-073

TX-079

SX-154

TX-014

MWII-D7R

SR-32

SR-29

MW-F2

MWC-3

SR-21

SX-003

WTP-06

WTP-01

WTP-02

SX-155

SOC-015

SOC-009

SOC-004

SOC-001

MWII-B4

MWII-A2

MWII-A3

MWII-C8

A-2

A-1 SR-03

SR-20

WGPZ-1

WGL-16

WTP-04

TX-104

TX-137

SOC-007

MWII-A5

MWII-C6

MW-F1

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013

SOC-016

SOC-167

SOC-166

SOC-012MWII-B1

MWII-A4

MWII-D6

MWII-C7

MW-277MW-276

MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-278

MW-279

MW-280Slurry Wall

Arkansas River

AEPProperty

621

622

620

623

624

615

625

616

626

614

613

612

611

610

609

619

625

623

614

613

613

617

626

615

627

624

626

621

620

618

617

616615

619

614

613

617

619622

611

618

612

614

614

621.4

615.28

614.71

624.71

626.15

626.77

626.82

626.69

626.01

625.54

617.00

614.7

626.6

626.6

613.5

612.4

613.5

619.7

616.3

612.6

612.5

619.4

615.2

616.4

616.8

615.1

613.5

613.9

616.5

622.68

623.77

625.32

626.63

626.54

626.63

626.56

626.68

626.62

626.69

626.84626.89

626.94626.84

626.73

626.87

626.91

626.92

615.51

620.11

614.79

613.63

613.18

617.06

611.04

613.72

614.26616.08

615.86

613.33

615.41

617.82

616.16

620.42

616.58

619.34

619.15

618.23

619.45

617.35

617.49

620.51612.83

616.61

615.94

619.95

616.78

618.93

618.23

619.19

618.09

619.95

619.18

622.45

617.39

616.17

619.31

618.85

615.04619.67

616.47

616.56

616.81

616.51

616.82

621.27

625.42622.88627.45

612.25

620.51

616.74

617.73

617.88

613.73

619.74

619.36

621.11

613.77

612.89

616.56

613.68

612.75

620.56

618.08

619.06

618.49

619.65

618.25

616.56

616.56

616.03

619.91

619.13

616.46

620.27

617.46

612.78

616.48614.77

616.74

614.13613.66

612.45

612.94

613.65

613.39

613.25

613.08617.52

616.67616.93617.15

614.28

616.82

613.84

613.22

613.78

615.67

614.95

616.84

617.85

617.23

620.92

621.26

620.98

616.32

618.12

621.64

615.59

615.04

613.06613.02

612.97

615.05

615.77

614.18617.02

619.04

617.08

616.22

616.25

616.49

616.72

616.01

612.18

612.25

612.26

613.19

613.21

613.25

612.92

608.62610.48

611.66


LegendRefinery Property BoundaryProperty Leased to the City of TulsaLTUsSWMUsTanksSlurry WallRailroadFenceStream/PondRiverbankOutfallPotentiometric ContoursInferred ContoursFlow Direction

Sample LocationsDouble Cased Well With Screen Below TopGroundwater Level (Facility Gauging Network)

Facility Gauging Network PiezometerFacility Gauging Network WellLNAPL Recovery Tank Battery WellMonitoring Well

Interim Point of Compliance Wells

Destroyed Well

Groundwater Potentiometric SurfaceMap (Corrected Elevations) (May 2011)

Figure




File Name: HRM004_08_FigIII-B_PSMMay11.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200


III-B

October 2011

Notes:1. Contour Interval = 1.0 ft.2. Potentiometric surface generated using Surfer 8contouring software, modified by Hull where appropriate.3. Potentiometric elevations corrected for weight of LNAPLusing a specific gravity of 0.84 where specific data isunavailable.

Holly Refining and Marketing - Tulsa, LLC(Tulsa East Refinery)


6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

MWDP-3MWDP-1

MWDP-2

MWII-E7

MWII-E8

MWII-E5

MWII-D4

MWII-D7

MWII-D8

MWII-SL3

MWII-SL2

MWII-SL1

MWII-API7

MWII-API6

WGPZ-8

WGPZ-5

WGPZ-6WGPZ-2

TP-8

TP-1TP-7 TP-4

E-27

MWC-2

MWC-1

SR-15

MWD-1SR-14

SR-17

MWE-2

MWE-1

SR-10

MWD-2

SR-22

SR-23

SR-05

MW-263

MW-262

MW-261

MW-260

MW-259

MW-257

MW-252

AEP-05

AEP-02

WTP-10

WTP-11

TX-110

TX-102

TX-033

TX-023

TX-031

TX-068

TX-101

WTP-14

WGL-15

TX-059

TX-067

TX-071

TX-103

TX-065

TX-077

TX-006

TX-047

TX-007

TX-010

TX-127

TX-004

TX-011

TX-140

WTP-13TX-040

TX-153

TX-150

WTP-08

WTP-09

TX-148

WTP-17

TX-080

TX-141

TX-082

TX-026

TX-092

TX-100

SX-156

TX-132

TX-063

MWDP-4

TX-064

TX-089

WTP-12

SX-162

SX-163

SX-164

SX-165

SOC-011

SOC-008

SOC-014

SOC-003SOC-020

SOC-002

MWAPI-2

MWII-B3

MWII-B2

MWII-A1

MWII-C5

MWII-D5

SOC-014B

MW-264

MW-258

MW-256MW-255MW-254

MW-253

MW-251

AEP-06

AEP-04

TX-002

TX-139

TX-066

TX-136

MWDP-3R

SOC-019SOC-018

SOC-017

MWAPI-1

MWAPI-3

MWAPI-5

MWAPI-4

MWII-C4

SR-26

SR-27

SR-28

SR-08

SR-31

SR-30

SR-07

SR-19

SR-02

SR-09

SR-01SR-12

SR-13

SR-06

MWD-3

SR-04

SR-24

TX-105

TX-073

TX-079

SX-154

TX-014

MWII-D7R

SR-32

SR-29

MW-F2

MWC-3

SR-21

SX-003

WTP-06

WTP-01

WTP-02

SX-155

SOC-015

SOC-009

SOC-004

SOC-001

MWII-B4

MWII-A2

MWII-A3

MWII-C8

A-2

A-1 SR-03

SR-20

WGPZ-1

WGL-16

WTP-04

TX-104

TX-137

SOC-007

MWII-A5

MWII-C6

MW-F1

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013

SOC-016

SOC-167

SOC-166

SOC-012MWII-B1

MWII-A4

MWII-D6

MWII-C7

MW-277MW-276

MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-278

MW-279

MW-280Slurry Wall

Arkansas River

AEPProperty

1.10.1

0

0

0

0

0

0

0

0

0

0

0

0

0

0.4

3.3

0.2

0.85

1.44

0.04

0

0

0

0

0

0

0

0

0

0

0

0

0

0

00

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2.05

1.47

0.01

00

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0.01

1.79

1.29

0.51

1.95

2.27

1.87

0.75

1.92

0.78

2.67

0.67

1.51

1.25

0.42

0.78

0.382.62

0.22

0.12

0.12

0.88

0.13

0.52

0.12

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

00

0

0

0

0

0

0

00

0

0.57

0.14

1.36

0.58

0.010.75

0.58

4.97

0.05

2.29

2.81

1.73

0.33

3.41

1.97

2.76

0.48

2.57

1.37

0.22

0.22

1.94

1.26

0.25

0.99

0.15

1.01

0.03

1.28

0.12

0.42

0.07

2.94

0.56

0.85

0.31

0

0

0

00

0

0

00

0

0

0.5

1

0.01

21.5

2.5

3

1.5

0.5

0.01

0.5

2

0.5

1.5

2

2

2

0.01

0.01

1 1

1.5

1

0.01

1

1.5

1

1.5

0.01

0.01


LegendRefinery Property BoundaryProperty Leased to the City of TulsaLTUsSWMUsTanksSlurry WallRailroadFenceStream/PondRiverbankOutfallLNAPL Thickness ContoursInferred LNAPL Thickness Contours




Destroyed Well

LNAPL Thickness0.010.511.522.533.5



Figure




File Name: HRM004_08_FigIII-C_LNAPLMay11.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200


III-C

October 2011Holly Refining and Marketing - Tulsa, LLC

(Tulsa East Refinery)

Apparent LNAPL Thickness Map(May 2011)

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

Arkansas River

MW-2730.242

SX-1610.174

MW-2800.0083

MW-2760.0406

MW-2500.0486

AEP-090.0421

SOC-0100.105

SX-1680.0128

WTP-070.0522

MWII-A40.443

SOC-1670.0483

MWII-D60.0149

MW-F1<0.005

MW-279<0.005

MW-278<0.005

MW-277<0.005

MW-275<0.005MW-274

<0.005

MW-272<0.005

MW-271<0.005

MW-270<0.005

MW-269<0.005

MW-268<0.005

MW-267<0.005

MW-266<0.005

MW-265<0.005

AEP-07<0.005

AEP-08<0.005

AEP-01<0.005

AEP-03<0.005

SX-160<0.005

SX-002<0.005

WTP-05<0.005

TX-053<0.005

SOC-006<0.005

SOC-005<0.005

SOC-013<0.005

SOC-016<0.005

SOC-012<0.005MWII-B1

<0.005

MWII-C7<0.005

AEP-10

SX-158

SOC-166


LegendRefinery Property BoundaryProperty Leased to the City of TulsaLTUsSWMUsTanksSlurry WallRailroadFenceStream/PondRiverbankOutfall


Destroyed Well

Benzene Detects



Figure




File Name: HRM004_08_FigIII-D_BnznMay11.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200




Benzene Concentrations inGroundwater (May 2011) III-D

Note:1. SX-158 and AEP-10 were not sampled due to LNAPL.2. All units are mg/L.

(0.0421)

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

Arkansas River

SX-1610.06

MW-2500.011

MW-2770.0067

AEP-080.0678

AEP-090.0332

SX-1680.0118

MW-F1<0.005

MW-280<0.005

MW-279<0.005

MW-278<0.005

MW-276<0.005

MW-275<0.005MW-274

<0.005

MW-273<0.005

MW-272<0.005

MW-271<0.005

MW-270<0.005

MW-269<0.005

MW-268<0.005

MW-267<0.005

MW-266<0.005

MW-265<0.005

AEP-07<0.005

AEP-01<0.005

AEP-03<0.005

SX-160<0.005

SX-002<0.005

WTP-05<0.005

WTP-07<0.005

TX-053<0.005

SOC-010<0.005

SOC-006<0.005

SOC-005<0.005

SOC-013<0.005

SOC-016<0.005

SOC-167<0.005

SOC-012<0.005MWII-B1

<0.005

MWII-A4<0.005

MWII-C7<0.005

MWII-D6<0.005

AEP-10

SX-158

SOC-166




Destroyed Well

MTBE Detects



Figure




File Name: HRM004_08_FigIII-E_MTBEMay11.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200




MTBE Concentrations inGroundwater (May 2011) III-E


(0.0332)

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Arkansas R

iver

MW-F1

MW-280

MW-279

MW-278

MW-277MW-276MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013SOC-016

SOC-167

SOC-012MWII-B1

MWII-A4

MWII-C7

MWII-D6

SOC-166




Destroyed Well

BTEX and MTBE Concentrationsin Groundwater (May 2011)

Figure




File Name: HRM004_08_FigIII-F_BTEXMMay11.mxdGeodatabase: HRM012.mdb

0 400 800200

Feet

1:9,600


III-F

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-267

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-270

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SOC -13B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SOC -6

B 0.0083T <0.005E <0.005X 0.0096

M TBE <0.005

M W-280

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-268

B 0.242T 0.0082E 0.0103X 0.0173

M TBE <0.005

M W-273

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-265

B <0.005T <0.005E 0.0744X 0.0052

M TBE <0.005

M W-271

B 0.0483T 0.0084E <0.005X 0.0188

M TBE <0.005

SOC -167

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-278

B 0.0486T <0.005E 0.014X 0.0394

M TBE 0.011

M W-250

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-269

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-274

B 0.443T <0.005E 0.145X 0.238

M TBE <0.005

M WII-A 4B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SOC -016B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SOC -5

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-279

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-266

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-272B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-275

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W11-C 7

B 0.0522T 0.0087E <0.005X 0.0118

M TBE <0.005

WT P -7

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

A EP -7

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

A EP -3

B 0.0421T <0.005E <0.005X 0.0249

M TBE 0.0332

A EP -9

B 0.0406T <0.005E 0.0952X 0.327

M TBE <0.005

M W-276B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M WII-B 1

B 0.0128T 0.0056E 0.0056X 0.0132

M TBE 0.0118

SX-168

B <0.005T 0.0051E <0.005X 0.0071

M TBE <0.005

A EP -1

B <0.005T <0.005E <0.005X <0.005

M TBE 0.0678

A EP -8

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SOC -12

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

T X-53

B <0.005T <0.005E <0.005X <0.005

M TBE 0.0067

M W-277

B 0.0149T 0.0054E <0.005X 0.0104

M TBE <0.005

M WII-D 6

B 0.105T 0.0063E <0.005X 0.0068

M TBE <0.005

SOC -10

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SX-2B 0.174T 0.0089E 0.0099X 0.0182

M TBE 0.06

SX-161

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

SX-160B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

WT P -5

B <0.005T <0.005E <0.005X <0.005

M TBE <0.005

M W-F 1





PLATES


Flare Area LTU

Walnut Grove LTU


LegendRefinery Property Boundary1000' Buffer of Property BoundaryLTUs100 Year Flood Plain

Plate

File Name: HRM004_08_PltIII-A_FldTopo.mxd



0 400 800200Feet

1:4,800


Geodatabase:

100 Year Flood Plain withTopographic Map



III-AOctober 2011

HAIGIS.mdb

Note:Flood plains downloaded from the FEMA Map Service Center. Data last updated on 8/3/09.40 CFR 270.14(b)(19) requires the topographic map be presented as a 1”=200’ scale,however, in order to present the topographic map on a reasonably sized printout (D-size,plate) with the required 1,000 feet around the facility the scale of the topographic mapneeded to be adjusted.

Edited: 10/18/2011 By: jslifer621

622

620

623

624

615

625

616

626

614

613

612

611

610

609

619

625

623

614

613

613

617

626

615

627

624

626

621

620

618

617

616615

619

614

613

617

619622

611

618

612

614

614TP-8

TP-1TP-7 TP-4

E-27

MWC-2MWC-1

SR-15

MWD-1SR-14

SR-17

MWE-2MWE-1

SR-10

MWD-2

SR-22

SR-23

SR-05

MW-264

MW-263

MW-262

MW-261

MW-260MW-258MW-257MW-256

MW-255MW-254

MW-253MW-252MW-251

AEP-06

AEP-05

AEP-04

AEP-02

WTP-10

WTP-11

TX-110

TX-102

TX-033TX-023

TX-031

TX-068

TX-002

TX-101

WTP-14

TX-059

TX-067

TX-071

TX-103

TX-065

TX-077

TX-006

TX-047

TX-007

TX-010

TX-127

TX-139

TX-011

TX-140

WTP-13

TX-040

TX-153

TX-150

WTP-08

WTP-09

TX-148

WTP-17

TX-080

TX-141

TX-082

TX-026

TX-092

SX-156

TX-066

TX-132

TX-063

MWDP-4

TX-089

WTP-12

SX-162

SX-163 SX-164

TX-136

SX-165

SOC-011

SOC-008

SOC-014

SOC-003

MWDP-3R

SOC-020SOC-019

SOC-018SOC-017

SOC-002

MWAPI-1MWAPI-5

MWAPI-2

MWAPI-4

MWII-B3MWII-B2

MWII-A1

MWII-C4

MWII-C5

MWII-D5

SOC-014B

TX-004MWAPI-3

MW-F2

MWC-3

SX-003

MWII-A2 MWII-A5

MWII-C8

MW-F1

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013SOC-016

SOC-167

SOC-166

SOC-012MWII-B1

MWII-A4

MWII-C7

MWII-D6

MW-277MW-276MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-278

MW-279

MW-280

Arkansas River

Flare Area LTU

Walnut Grove LTU


LegendRefinery Property Boundary1000' Buffer of Property BoundaryLTUs100 Year Flood PlainFacility Gauging Network Well


Destroyed Well

Potentiometric ContoursInferred ContoursFlow Direction

Plate

File Name: HRM004_08_PltIII-B_POCPSM.mxd



0 400 800200Feet

1:4,800


Geodatabase:

100 Year Flood Plain with TopographicMap, Point of Compliance Wells andGroundwater Contours (May 2011)



III-BOctober 2011

HAIGIS.mdb

Note:Flood plains downloaded from the FEMA Map Service Center. Data last updated on 8/3/09.40 CFR 270.14(b)(19) requires the topographic map be presented as a 1”=200’ scale,however, in order to present the topographic map on a reasonably sized printout (D-size,plate) with the required 1,000 feet around the facility the scale of the topographic mapneeded to be adjusted.

LTU CLOSURE DOCUMENTS


Permit No. 990750960‐PC

HOLLY TULSA EAST REFINERY PART B RCRA PERMIT ATTACHMENT #1

CONTINGENCY PLAN




POST‐CLOSURE PLAN



i

POST‐CLOSURE PLAN TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................ 1

1.1 OBJECTIVES AND SCOPE .................................................................................................. 1 2.0 REGULATORY STATUS & HISTORY ................................................................................ 3 3.0 FACILITY DESCRIPTION .................................................................................................. 5

3.1 SITE DESCRIPTION ......................................................................................................... 5

3.1.1 General LTU Description ....................................................................................... 5 3.1.2 FALTU Description ................................................................................................. 6 3.1.3 WGLTU Description ............................................................................................... 6

4.0 GROUNDWATER MONITORING PROGRAM .................................................................. 8

4.1 OBJECTIVES AND SCOPE ................................................................................................. 8 4.2 SAMPLING AND ANALYSIS PLAN (SAP) .............................................................................. 9

5.0 POST‐CLOSURE CARE PROGRAM ................................................................................. 10

5.1 OBJECTIVES AND SCOPE ................................................................................................ 10 5.2 SITE INSPECTIONS ....................................................................................................... 10

5.2.1 Inspection Activities ........................................................................................... 10

5.3 MAINTENANCE ........................................................................................................... 11

5.3.1 Site Maintenance ............................................................................................... 11 5.3.2 Maintenance Corrective Actions ........................................................................ 12 5.3.3 Groundwater Monitoring Network Maintenance .............................................. 12 5.3.4 Corrective Actions .............................................................................................. 12 5.3.5 Security ............................................................................................................... 12 5.3.6 Record Keeping & Site Contact .......................................................................... 13



1

Holly Tulsa East Refinery

Attachment #2 Post‐Closure Plan October 2011

1.0 INTRODUCTION

Holly Refining and Marketing (Permittee) operates the Holly Tulsa East Refinery (Facility) which

has two (2) land treatment units (LTUs) where wastes remain in place after closure of the LTUs.

Accordingly, Resource Conservation and Recovery Act (RCRA) regulations state that a Post‐

Closure Plan must be included in the Facility RCRA Part B Permit. This Post‐Closure Plan

document has been prepared to meet the submittal requirements of a RCRA Part B Permit

pursuant to general post‐closure care regulations 40 CFR 264 & 265.118. The closed LTUs at

the Facility are known as the Flare Area LTU (FALTU) and the Walnut Grove LTU (WGLTU).

1.1 Objectives and Scope

This Post‐Closure Plan document has been submitted with the RCRA Part B Application 40 CFR

270.14(b)(13). The objective of the Post‐Closure Plan is to identify the activities that will be

continued after closure of each LTU and detail the frequency of those post‐closure activities which

include the operating, maintenance, and monitoring of the units. LTU specific requirements for

post‐closure care are detailed in 40 CFR 264 & 265 Subpart M for Land Treatment and 40 CFR

264.280(c) for post‐closure care.

The Post‐Closure Plan is required to provide procedural information with respect to the following:

• Groundwater monitoring activities and frequencies;

• Planned maintenance and inspection activities and the frequencies they will be

performed; and



2

• Facility contact information and Facility reporting over the duration of the post‐closure care period.

Activities outlined in the Post‐Closure Plan will be implemented for a period of thirty (30) years

from the date of certified closure of each specific LTU.

The LTUs contain hazardous waste constituents; therefore, any post‐closure use of the LTU

areas (land) which may disturb the integrity of the surface cap or functions of the monitoring

systems will be prohibited.



3

2.0 REGULATORY STATUS & HISTORY

Permit # 990750960‐PC, renewed on July 2, 2008, is the most recent RCRA post‐closure permit for

the FALTU. This permit was a renewal from a previous FALTU post‐closure permit which had an

effective date of May 26, 1995. A Certification of Closure for the FALTU was submitted on March

3, 1993 and the monitoring activities of the Closure Plan implemented at that time. The FALTU

was officially closed on April 1, 1993. Post‐closure care began on April 1, 1993 after submittal of

the required Notice of Closure Report and fulfilling applicable regulatory requirements. A total of

approximately eighteen (18) years of post‐closure monitoring activities have been completed at

the FALTU.

The WGLTU was issued a permit to operate as a hazardous waste LTU on the effective date of

December, 10, 1998, Permit # 990750960‐OP. The WGLTU operating permit expired on

December 10, 2008. Subsequently, Sinclair Oil Company (SOC) submitted a Certification of

Closure on April 24, 2009 in accordance with 40 CFR 264.115 and began implementation of the

Post‐Closure Plan contained within the expired WGLTU Operating Permit (Permit # 990750960‐

OP). In 2009, SOC submitted a request to the Oklahoma Department of Environmental Quality

(DEQ) for a RCRA post‐closure permit modification to add the WGLTU to the FALTU post‐closure

permit. The Permittee has continued to operate the post‐closure of the WGLTU under the

same Post‐Closure Plan until a new RCRA Part B Permit can be completed. Holly submitted a

draft RCRA Post‐Closure Care Permit for the FALTU and WGLTU to the DEQ on April 30, 2010, as

required by the Consent Order in Case No. 09‐319. All tasks required by said Consent Order have

since been fulfilled. In September 2010, Holly presented a preliminary conceptual site model

(CSM) to the DEQ, including a review of current environmental subsurface conditions which

suggest the LTUs do not appear to be a source of the LNAPL and dissolved phase plumes

underlying the Facility. Additionally, no statistically significant soil or groundwater detections were

exhibited over decades of compliance monitoring at the FALTU and WGLTU. As such, Holly

proposed that a Facility‐wide permitting approach may be more appropriate for the Facility than

the current LTU‐based permit(s). The DEQ agreed to this approach and a new Consent Order for



4

the Facility (Case No. 11‐100) was filed on July 6, 2011, requiring submittal of a new RCRA Post‐

Closure and Corrective Action Permit application for the Facility by October 21, 2011. A total of

approximately two (2) years of post‐closure monitoring activities have been completed at the

WGLTU.

The current Facility RCRA post‐closure permit requires the Permittee to monitor and maintain the

LTUs in accordance with requirements of the Oklahoma Waste Management Act (OWMA), 27 O.S.

1993, Sec. 2‐7‐101 et seq., as amended, the Oklahoma Administrative Code Title 252 Chapter 200

(Rule or Rules), the Federal Resource Conservation and Recovery Act (RCRA), Title 40 Code of

Federal Regulations (40 CFR) and the Hazardous and Solid Waste Amendments of 1984 (HSWA).



5

3.0 FACILITY DESCRIPTION

The Permittee is a petroleum based refinery located on approximately four hundred seventy four

(474) acres. The Refinery has been in operation since approximately 1906 under several

operators. The refinery is one of the Permittee’s two (2) refineries operating in Tulsa, OK. These

refineries include the Facility (Holly East Tulsa Refinery) formerly owned by Sinclair and the Holly

West Tulsa Refinery formerly owned by Sunoco. The combined refining capacity of the

Permittee’s East and West Tulsa Refineries is approximately 125,000 barrels of oil per day. The

petroleum products normally produced at the Facility include the following:

1. Gasoline;

2. Diesel fuel;

3. Fuel oils;

4. Propane;

5. Butane; and

6. Commercial jet fuel.

The refinery is located in Township 19 North and Range 12 East. The location of the refinery and

general location of the LTUs are shown on the topographic map of the Facility that is provided as

Figure 1 in the Sampling and Analysis Plan, Permit Attachment 3.

3.1 Site Description

3.1.1 General LTU Description

The FALTU and the WGLTU are closed hazardous waste LTUs located entirely within the secured

boundaries of the Facility. The LTU areas have been locations of land farming operations since the

early 1900’s. Historically applied wastes consisted of liquid, sludge and solid residues from various

refinery operations. The FALTU is located in the southeast portion of the refinery. The WGLTU is

located in the northeast corner of the refinery. The locations of the LTUs are shown on Figure 2 in

Permit Attachment 3.



6

3.1.2 FALTU Description

The FALTU is situated in the southeast corner of the refinery in Section 23 of T 19 N, R 12 E and

occupies an area of approximately twenty‐nine (29) acres in size. The area surrounding the

FALTU is industrial to the east and west and residential to the south. American Electric Power

(AEP) borders the FALTU on the east; railroad spurs boarder the LTU on the west with refinery

property further west of the tracks and north of the LTU. The Arkansas River is located farther to

the east beyond the AEP property. The wastes historically disposed at the FALTU were refinery

wastes D001, D008, and K049 through K052. No wastes have been applied to the FALTU since

February, 1988. The vegetative cover of the LTU continues to be maintained by Holly.

The FALTU is generally underlain by a silty or sandy loam followed by very fine sand ranging in

color from reddish brown to dark and light brown at approximately 5 feet. The fine sand generally

grades to a medium grain sand that is brown to light gray in color by 15 feet below ground surface.

The medium sand grades to a coarse sand which is generally encountered from 15 to 20 feet

below ground surface. Bedrock in this area was encountered at approximately 20 to 30 feet below

ground surface and consists of either a gray shale or gray‐green sandstone. Available boring/well

installation logs for the FALTU well network and from the most recent soil sampling event are

included for reference as Attachment A. Holly has not been able to locate any historical structural

diagrams or drawings of the FALTU in the historical record.

3.1.3 WGLTU Description

The WGLTU is situated in the northeast corner of the refinery in Section 14 of T 19 N, R 12 E and

occupies an area of approximately twenty (20) acres in size. The area surrounding the WGLTU is

industrial to the north, west and south with refinery property located to the west and south of

the LTU. The Arkansas River levee and River are present to the east. The disposal of some

characteristic listed wastes was banned from land disposal at the WGLTU on August 8, 1990. The

“K” listed wastes were banned from land disposal at the WGLTU on November 8, 1990. Wastes

applied to the WGLTU since 1990 have been non‐hazardous waste from various refinery sources;



7

the wastes were tested for ignitibility, corrosivity, reactivity and toxicity characteristics which

determined the non‐hazardous classification. The vegetative cover of the WGLTU continues to be

maintained by Holly.

The WGLTU is generally underlain by silty or sandy loam followed by very fine sand ranging in color

from reddish brown to dark and light brown at approximately 5 to 10 feet. The fine sand generally

grades to a medium grained sand that is brown to light gray in color by 15 feet below ground

surface. The medium sand grades to a coarse sand which is generally encountered from 15 to 20

feet below ground surface. Boring logs in the WGLTU did not indicate the presence of bedrock

within the depths that were drilled; therefore, depth to bedrock cannot be determined specifically

in the WGLTU area. However, throughout the Facility bedrock is generally encountered within 30

feet of the ground surface. It can be assumed that bedrock in the WGLTU would likely be

encountered within 30 feet of the ground surface. Available boring / well installation logs for the

WGLTU well network and from the most recent soil sampling event are included for reference as

Attachment A. Holly has not been able to locate any historical structural diagrams or drawings of

the FALTU in the historical record.



8

4.0 GROUNDWATER MONITORING PROGRAM


The objective of the Facility‐wide groundwater monitoring program is to provide chemical data on

the nature and extent of the dissolved phase and LNAPL plumes underlying the Facility as well as

the LTUs and assess any remedial progress or corrective action measures that have been

implemented. While the groundwater monitoring program specified in Permit Attachment 3 is

intended primarily to demonstrate groundwater compliance with applicable protection standards

at the Facility point of compliance (POC), semi‐annual monitoring of Interim POC well network

located upgradient and downgradient of the LTUs is included as part of the overall groundwater

sampling compliance program. The LTU based POC wells included in the Facility Sampling and

Analysis Plan (SAP) will monitor groundwater concentration trends across each LTU area to

determine if there are any impacts from the LTUs on the groundwater beneath the Facility.

Facility Interim POC network wells serving as FALTU compliance monitoring points include:

FALTU upgradient/background (frequency):

• SOC‐010 (semi‐annual)

Dual purpose Facility Perimeter POC and FALTU downgradient/POC:

• SX‐160 (semi‐annual)


• WTP‐05 (semi‐annual)

• WTP‐07 (semi‐annual)

Facility Interim POC network wells serving as WGLTU compliance monitoring points include:

WGLTU upgradient/background (frequency):

• MWII‐C7 (semi‐annual)



9

Dual purpose Facility Perimeter POC and WGLTU downgradient/POC:





Copies of the boring / monitoring well construction logs for each of the Interim POC network wells

listed above are provided as Attachment A.

4.2 Sampling and Analysis Plan (SAP)

The groundwater monitoring for the Facility, including monitoring at Interim POC well network

locations upgradient and downgradient of each LTU, will be performed according to the

detailed procedures outlined in the Permit Attachment 3 (Facility SAP).



10

5.0 POST‐CLOSURE CARE PROGRAM


This Post‐Closure Plan outlines the necessary steps in providing post‐closure care of the FALTU

and the WGLTU. Post‐closure care outlines the necessary maintenance and monitoring

activities as well as their associated frequencies to be completed at each LTU. Specific

requirements for the post‐closure care of the LTUs include the following:

1. Continue all operations (including pH control) necessary to enhance degradation and transformation and sustain immobilization of hazardous constituents in the treatment zone to the extent that such measures are consistent with other post‐closure activities;

2. Maintain vegetative cover over the LTUs; 3. Maintain the surface water run‐on/run‐off control and management systems; 4. Control wind dispersion of hazardous waste; 5. Continue to comply with prohibitions on the growth of food chain crops; and 6. Continue applicable groundwater monitoring.

5.2 Site Inspections

5.2.1 Inspection Activities

Semi‐annual inspections will be performed (including but not limited to) at the general Facility

perimeter surrounding each LTU, along each LTUs cap, and at the associated groundwater

monitoring networks for each LTU and the Facility. Perimeter inspections will include

observation and documentation of the integrity of the perimeter fences, gates and locks.

Signage, as well as ingress and egress into the LTUs will also be reviewed during these

inspections. LTU maintenance inspections will involve visually inspecting the integrity of each

LTU cap for vegetation, animal burrows, erosion, settlement, subsidence, and plant growth.

The surrounding engineered dike systems will be also be inspected. The groundwater



11

monitoring network will be visually inspected for damage to the monitoring wells and pads

during the inspection process.

The full detailed inspection program and schedules for the LTU inspections are outlined in the

Inspection and Maintenance Plan, Permit Attachment 4. LTU inspections will be performed on

a semi‐annual or on an as‐needed basis contingent on weather conditions. Inspection forms

will be completed for each post‐closure inspection. An example inspection form can be found

in Permit Attachment 4.

Any changes, concerns or sub‐standard conditions observed during the inspections will be

brought to the attention of the Facility Environmental Coordinator. The Environmental

Coordinator will arrange to have any deficiencies corrected as soon as practical by the Facility

maintenance staff.

5.3 Maintenance

5.3.1 Site Maintenance

Site maintenance activities will be performed with the primary goal of maintaining the integrity

of the vegetative cover. Activities which could disturb the integrity of the final cover will be

prohibited.

Routine maintenance practices to preserve the integrity of the cap include the following:

• Localized reseeding and fertilization will be performed as necessary to maintain appropriate vegetative ground cover;

• Application of non‐hazardous clarifier sludge (biosludge) to the vegetative cover

as a nutrient and irrigation source as needed; • Irrigation will be performed as necessary to maintain the appropriate vegetative

cover of the LTUs, including the application of treated effluent from the waste



12

water treatment plant (WWTP) as a supplemental irrigation source for vegetation;

• Mowing of the grass will be performed as necessary; and

• Routine repairs to the caps and engineered dike systems will be made as necessary to correct and control the effects of settling, subsidence, erosion, etc.

5.3.2 Maintenance Corrective Actions

Any changes, concerns or substandard conditions observed during the maintenance inspections

will be brought to the attention of the Environmental Coordinator. The Environmental

Coordinator will arrange to have any maintenance deficiencies corrected as soon as practical by

the Facility maintenance staff.

5.3.3 Groundwater Monitoring Network Maintenance

The groundwater monitoring network will be inspected semi‐annually. The condition of all

monitoring wells, locks, protective concrete pads etc. will be noted.

5.3.4 Corrective Actions

Any changes, concerns or substandard conditions observed during the groundwater monitoring

well network inspections will be brought to the attention of the Environmental Coordinator.

The Environmental Coordinator will arrange to have any groundwater monitoring well network

deficiencies corrected as soon as practical by the Facility maintenance staff.

5.3.5 Security

All existing refinery security features will remain in place during the post‐closure period and will

be maintained as required to prevent unauthorized entry. The security system will consist of a

metal wire fence in good repair with locked gated entrances with warning signs. Routine

surveillance will be provided by Permittee’s security personnel. Each LTU is surrounded by

perimeter security fencing with a locked gate. Access into the LTU must be approved by



13

designated area supervisors and/or security. Signage at the entrance gates is visible from at

least twenty‐five (25) feet and indicates “Danger—Unauthorized Personnel Keep Out” or

equivalent language.

Any changes or concerns that are observed during the perimeter and security inspections will

be brought immediately to the attention of the Environmental Coordinator and the refinery

security manager. They will arrange to have any security concerns resolved immediately.

5.3.6 Record Keeping & Site Contact

Permittee will continue post‐closure care for a period of at least thirty (30) years after the

certified closure of each LTU.

During the post‐closure period, Permittee will designate a person to serve as the Facility’s post‐

closure care contact. Ms. Jaime Rountree has been designated as the post‐closure contact

person for this Facility. The contact information for Ms. Rountree is provided below:

Ms. Jaime Rountree

Remediation Program Manager

Holly Refining & Marketing

PO Box 21001

Tulsa, OK 74101‐1001

918‐594‐3210

E‐mail [email protected]

A copy of the Post‐Closure Plan for this Facility will be maintained in the Environmental File

Records Room located in the environmental department at the Facility.



14

This Post‐Closure Plan will be amended subject to the approval of the DEQ when operating

plans or Facility design changes affect the Post‐Closure Plan. Copies of all amendments will be

kept with the Post‐Closure Plan located in the Environmental File Records Room located in the

environmental department at the Facility.

ATTACHMENT A

Copies of Boring / Monitoring Well Construction Logs

for LTU POC Wells




SAMPLING AND ANALYSIS PLAN



i

TABLE OF CONTENTS

PAGE

1.0 PROJECT MANAGEMENT .............................................................................................. 1 1.1 Project Organization and Responsibilities ............................................................. 1

1.1.1 Management Responsibilities .................................................................... 1 1.1.2 Quality Assurance Responsibilities ............................................................ 3 1.1.3 Field Responsibilities ................................................................................. 3 1.1.4 Laboratory Responsibilities ........................................................................ 4 1.1.5 Special Training Requirements / Certifications .......................................... 4

1.1.5.1 Field Personnel ........................................................................ 5 1.1.5.2 Laboratory Personnel ............................................................... 5

1.2 Facility History/ Background Information ............................................................... 5 1.3 Project Description and Schedule ......................................................................... 8 1.4 Data Quality Objectives ......................................................................................... 9

1.4.1 Project Quality Objectives .......................................................................... 9

1.4.1.1 Stating the Problem ............................................................... 10 1.4.1.2 Identifying the Decision .......................................................... 10 1.4.1.3 Identifying Inputs to the Decision ........................................... 11 1.4.1.4 Defining the Boundaries of the Study .................................... 12 1.4.1.5 Developing a Decision Rule ................................................... 12 1.4.1.6 Specifying Limits on Decision Errors ..................................... 13 1.4.1.7 Optimizing the Design ............................................................ 13

1.5 Quality Assurance Objectives for Measurement Data ......................................... 14 1.5.1 PARCC Element - Precision .................................................................... 14

1.5.1.1 Definition ................................................................................ 14 1.5.1.2 Field Precision Objectives ...................................................... 14 1.5.1.3 Laboratory Precision Objectives ............................................ 14

1.5.2 PARCC Element - Accuracy .................................................................... 15

1.5.2.1 Definition ................................................................................ 15 1.5.2.2 Field Accuracy Objectives ...................................................... 15 1.5.2.3 Laboratory Accuracy Objectives ............................................ 16

1.5.3 PARCC Element - Completeness ............................................................ 17

1.5.3.1 Definition ................................................................................ 17 1.5.3.2 Field Completeness Objectives ............................................. 17 1.5.3.3 Laboratory Completeness Objectives .................................... 17



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TABLE OF CONTENTS (cont.)

PAGE

1.5.4 PARCC Element - Representativeness ................................................... 17

1.5.4.1 Definition ................................................................................ 17 1.5.4.2 Measures to Ensure Representativeness of Field Data ......... 18 1.5.4.3 Measures to Ensure Representativeness of Laboratory

Data ....................................................................................... 18

1.5.5 PARCC Element - Comparability ............................................................. 18

1.5.5.1 Definition ................................................................................ 18 1.5.5.2 Measures to Ensure Comparability of Field Data ................... 18 1.5.5.3 Measures to Ensure Comparability of Laboratory Data ......... 18

1.6 Documentation and Records ............................................................................... 19 2.0 FIELD SAMPLING AND ANALYSIS PLAN .................................................................. 20 2.1 Sampling Process and Design ............................................................................ 20 2.2 Task 1 – Groundwater and LNAPL Gauging ....................................................... 20 2.2.1 Water Level and LNAPL Measurements ................................................. 20

2.2.1.1 Measurement Locations and Frequency ................................ 21 2.2.1.2 Equipment and Procedures ................................................... 21 2.2.1.3 Documentation ....................................................................... 22 2.2.1.4 Decontamination .................................................................... 22 2.2.1.5 Investigative Derived Waste .................................................. 22 2.3 Task 2 - Groundwater Sampling .......................................................................... 22 2.3.1 General Sampling Requirements ............................................................. 22 2.3.2 Monitoring Wells Requiring Groundwater Sampling ................................ 23 2.3.3 Laboratory Analysis ................................................................................. 23 2.3.4 Sampling Equipment Preparation and Decontamination ......................... 24 2.3.5 Groundwater Sampling Methodology ...................................................... 24

2.3.5.1 Low-Flow Sampling ................................................................ 24

2.3.6 Sample Containers and Preservatives .................................................... 26 2.3.7 Sample Storage and Transportation ........................................................ 26



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TABLE OF CONTENTS (cont.)

PAGE

2.3.8 Sample Handling and Custody Requirements ......................................... 26

2.3.8.1 Chain of Custody Procedures ................................................ 27 2.3.8.2 Field Custody Procedures ...................................................... 27 2.3.8.3 Sample Collection .................................................................. 28 2.3.8.4 Sample Labeling .................................................................... 28 2.3.8.5 Sample Identification Numbers .............................................. 28 2.3.8.6 Field Sampling Data Sheets .................................................. 29 2.3.8.7 Laboratory Documentation ..................................................... 30 2.3.8.8 Final Evidence Files ............................................................... 31 2.3.9 Investigative Derived Waste .................................................................... 31 2.4 Quality Control Requirements ............................................................................. 32 2.4.1 Level of Quality Control Effort .................................................................. 32 2.4.2 Internal Quality Control ............................................................................ 33 2.4.2.1 Blank Samples ....................................................................... 33 2.4.2.2 Analytical Spikes .................................................................... 34 2.4.2.3 Reference Standards ............................................................. 35 2.4.2.4 Replicate Analysis .................................................................. 35

2.4.2.5 Calibration Check Standards ................................................. 35 2.4.2.6 Internal Standards .................................................................. 36

2.4.3 Sampling Quality Control ......................................................................... 36 2.5 Instrument Calibration and Maintenance Requirements ..................................... 37 2.5.1 Field Instrument Calibration and Preventative Maintenance ................... 37 2.5.2 Laboratory Instrument Preventative Maintenance ................................... 37 2.5.3 Laboratory Instrumentation Calibration Procedures ................................ 37 2.5.4 Field and Laboratory Consumables ......................................................... 38

2.6 Data Management ............................................................................................... 38 2.6.1 Sample Documentation ........................................................................... 38 2.6.2 Field Data Sheets .................................................................................... 38



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TABLE OF CONTENTS (cont.) PAGE 2.6.3 Laboratory Data Reduction, Review and Reporting ................................ 39 2.6.3.1 Data Reduction ...................................................................... 39 2.6.3.2 Data Review ........................................................................... 39 2.6.3.3 Date Reporting ....................................................................... 40 2.6.4 Corrective Action ..................................................................................... 40 2.6.4.1 Laboratory Corrective Action ................................................ 40 2.6.4.2 Bench Level ........................................................................... 41 2.6.4.3 Management Level ................................................................ 41 2.6.4.4 Receiving Level ...................................................................... 41 2.6.4.5 Field Corrective Action ........................................................... 41 2.6.5 Quality Assurance Reports to Management ............................................ 42 2.6.5.1 Laboratory Internal Reporting ................................................ 42 2.6.5.2 Additional Reporting ............................................................... 42 2.6.6 Data Management ................................................................................... 42 3.0 ASSESSMENT AND OVERSIGHT ................................................................................ 44 3.1 Performance and System Audits ......................................................................... 44 3.1.1 Performance Audits ................................................................................. 44 3.1.2 System Audits .......................................................................................... 44 3.1.3 Field Audits .............................................................................................. 45 3.2 Reports ................................................................................................................ 45 3.2.1 Internal Reporting .................................................................................... 45 3.2.2 Additional Reporting ................................................................................ 46 4.0 DATA REDUCTION, VERIFICATION, VALIDATION AND REPORTING ..................... 47 4.1 Review of Field Data ........................................................................................... 47 4.2 Data Validation .................................................................................................... 47

4.2.1 Procedures Used to Verify and Validate Field Data ................................ 47



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TABLE OF CONTENTS

(cont.) PAGE 4.2.2 Procedures Used to Verify and Validate Laboratory Data ....................... 48 4.2.2.1 Primary Review ...................................................................... 48 4.2.2.2 Secondary Review ................................................................ 49

4.2.2.3 Final Review .......................................................................... 49 4.2.3 Laboratory Data Reporting ...................................................................... 49 4.3 Reconciliation with User Requirements ............................................................... 50 5.0 REFERENCES ................................................................................................................ 51

TABLES Table 1: Summary of Facility-wide Monitoring Well Networks to be Gauged Semi-Annually Table 2: Summary of Point of Compliance Wells, Functions and Sampling Schedule Table 3: Summary of Analytical Methods and Chemicals of Concern for Semi-Annual

Groundwater Sampling Events (Region 5 Skinner List) Table 4: Summary of Analytes and Practical Quantitation Limits for Groundwater Samples Table 5: Field and Laboratory Quality Control Frequencies Table 6: Summary of Sample Containers, Preservation Methods and Holding Times Table 7: Preventative Maintenance for Field Instruments Table 8: QA Objectives for Field Measurements Table 9: Preventative Maintenance for Analytical Instruments

FIGURES Figure 1: Site Location and Topographic Features Figure 2: Facility Base Map Figure 3: LNAPL Recovery Systems

LIST OF APPENDICIES Appendix A Consultant Standard Operating Procedures Appendix B Field Data Sheets and QC Forms



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LIST OF ACRONYMS

AOII Areas of Interest Investigation bgs Below Ground Surface CLP Contract Laboratory Program COC Chemical of Concern or Chain-of-Custody (context specific) CSM Conceptual Site Model DO Dissolved Oxygen DOT Department of Transportation DQO Data Quality Objectives FID Flame Ionization Detector FOC Field Operations Coordinator GC Gas Chromatograph GC/MS Gas Chromatograph/ Mass Spectrometer GFAA Graphite Furnace Atomic Absorption HASP Health and Safety Plan HAZWOPER Hazardous Waste Operations and Emergency Response HRS Hazardous Ranking System HPDE High Density Poly Ethylene HSA Hollow Stem Auger Holly Holly Refining & Marketing – Tulsa, LLC. ICP Inductively Coupled Plasma ICPMS Inductively Coupled Plasma Mass Spectrometry LCS Laboratory Control Sample LIMS Laboratory Information Management System MCL Maximum Contaminant Level mgd Million Gallons per Day MS/MSD Matrix Spike/ Matrix Spike Duplicate NIST National Institute of Standards and Technology NPL National Priorities List NTU Nephelometric Turbidity Units OWCB Oklahoma Water Control Board DEQ Oklahoma Department of Environmental Quality OSHA Occupational Safety and Health Administration ORP Oxidation Reduction Potential (Redox Potential) OVA Organic Vapor Analyzer OV-PID Organic Vapor Photoionization Detector PARCC Precision, Accuracy, Representativeness, Comparability, Completeness PCB Polychlorinated Biphenyls PID Photoionization Detector PM Project Manager ppb Parts Per Billion ppm Parts Per Million Work Plan AOII Work Plan QA Quality Assurance QAM Quality Assurance Manual QAO Quality Assurance Officer QAP Quality Assurance Plan



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LIST OF ACRONYMS

(cont.) QAPP Quality Assurance Project Plan QC Quality Control QCI Quality Control Indicators RCRA Resource Conservation and Recovery Act RPD Relative Percent Difference RSD Relative Standard Deviations SIN Sample Identification Number SAP Sampling and Analysis Plan SAPQAPP Combined Sampling and Analysis Plan and Quality Assurance Project PlanSOP Standard Operating Procedure SVOC Semi-volatile Organic Compound TAL Target Analyte List U.S. EPA United States Environmental Protection Agency VOC Volatile Organic Compound WWTP Waste Water Treatment Plant



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1.0 PROJECT MANAGEMENT

1.1 Project Organization and Responsibilities This SAPQAPP has been prepared to identify the scope, procedures and quality

assurance/quality control (QA/QC) protocols for the collection of supporting data for the semi-

annual groundwater sampling and monitoring program occurring at the Holly Tulsa East

Refinery (Facility) in Tulsa, Oklahoma. The semi-annual sampling activities include collection of

groundwater samples from a select list of point of compliance (POC) wells and the collection of

water levels from the gauging monitoring well network on-site. The semi-annual groundwater

sampling activities described herein are being conducted in accordance with the Consent Order

(Case No. 11-100) dated July 6, 2011 (received by Holly on July 26, 2011) and will replace the

Facility monitoring requirements of the Flare Area Land Treatment Unit (FALTU) permit and the

expired permit for the Walnut Grove LTU (WGLTU), until the new Facility-wide RCRA Post-

Closure and Corrective Action Permit for the Facility becomes effective, as discussed in Section

1.2. The location of the Facility is shown on Figure 1.

Holly’s environmental consultant will be responsible for performing, or providing oversight of

subcontractors completing, the field investigations, preparing required reports, and performing

any subsequent work required to complete the semi-annual groundwater sampling. The

Oklahoma Department of Environmental Quality (DEQ) is responsible for review and approval of

this combined Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP)

(hereafter referenced as SAPQAPP). The various quality assurance and management

responsibilities of key project personnel are defined below.

1.1.1 Management Responsibilities RCRA Permit & Project Manager, Oklahoma Department of Environmental Quality The DEQ appointed RCRA Permit and Project Manager is responsible for oversight of Facility

RCRA permitting and compliance. The DEQ will provide review and approval of RCRA permit

related Facility reports and other relevant documents.

Andrew Haar, Holly Environmental Manager Mr. Haar has final responsibility for environmental related issues at the Facility. Mr. Haar

provides overall direction for this project to his environmental remediation staff, including Jaime



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Rountree. Mr. Haar serves as one of the primary communication links between DEQ and Holly

for this project.

Jaime Rountree, Holly Remediation Manager Ms. Rountree is responsible for overseeing the administrative requirements and day to day

management of RCRA Permit related work including implementation of the semi-annual

groundwater monitoring and sampling programs. Ms. Rountree is the primary contact between

the Facility, the Environmental Consultant, and any work crews responsible for completing the

field work. Ms. Rountree will work with the project management team to plan and develop

project strategies and will review project deliverables prior to submittal to the DEQ. Ms.

Rountree serves as one of the primary communication links between DEQ and Holly for this

project.

Environmental Consultant Project Manager The Environmental Consultant Project Manager (PM) (or equivalent staff) will be involved in the

planning and implementation of the semi-annual sampling events, and the evaluation of the

resultant data. The Environmental Consultant PM is responsible for meeting technical, financial,

and scheduling objectives for the project and is the primary communication link between Holly,

any subcontractors, and the laboratory. The Consultant PM will be involved in planning

meetings and project update meetings and will provide senior technical quality control and

project oversight. Duties and responsibilities of the PM include the following:

1. administrate and supervise all phases of the project;

2. ensure project objectives are met within financial and time constraints;

3. provide technical support to project team;

4. work with the quality assurance officer (QAO) and field personnel to plan and

conduct project operations, progress meetings, etc.;

5. review reports and other work products prior to their issuance; and

6. participate in project meetings held with Holly and the DEQ.



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1.1.2 Quality Assurance Responsibilities Environmental Consultant Quality Assurance Officer

The Consultant QAO will be responsible for enforcing the provisions of the SAPQAPP and will

remain independent of direct job involvement and day-to-day operations. Specific functions and

duties will be to:

1. establish Quality Assurance/Quality Control (QA/QC) procedures for the project; 2. evaluate data quality and maintain QC records; 3. provide the initial quality control review of analytical data; 4. provide a communication link between project personnel and the laboratory; and 5. revise work practices or identified procedural deviations to align work with

approved SAPQAPP procedures and guidelines.

1.1.3 Field Responsibilities Environmental Consultant Field Operations Coordinator

The Consultant Field Operations Coordinator (FOC) will be responsible for overseeing the day-

to-day conduct of project activities. Duties and responsibilities of the FOC will be to:

1. ensure the sampling activities are conducted in a manner that follows the procedures outlined in this plan;

2. coordinate the sampling activities with the QAO and field personnel; 3. oversee the use, maintenance and operation of sampling equipment; and 4. report daily activities, problems, etc. to the QAO.

The FOC will be in daily communication with field support personnel and may conduct field

audits over the duration of the project.

Field personnel from the Environmental Consultant and/or subcontracted services and labor will

be used to complete the semi-annual groundwater sampling events.



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1.1.4 Laboratory Responsibilities The laboratory will have its own project organization with responsibilities similar to that of the

field operations personnel. A Holly contracted laboratory will be used to support the semi-

annual groundwater sampling and analysis work.

Copies of applicable laboratory standard operating procedures (SOPs) for semi-annual

groundwater sampling at the Facility will be supplied by the contracted lab selected to perform

the work.

Laboratory Director The Laboratory Director will be primarily responsible for the overall operation of the laboratory

including all samples analyzed and data reported. The Laboratory Director will provide final

review of all data packages before reporting results and will be responsible for initiating

corrective action measures when analytical data do not meet the requirements of this plan or

the laboratory’s Quality Assurance Plan (QAP).

Laboratory Project Manager The Laboratory Project Manager will be the primary communications link between the laboratory

and the Environmental Consultant’s QAO/PM. The Laboratory Project Manager will be

responsible for relating any special needs of the field operations personnel to the laboratory.

The Laboratory Project Manager will also provide the final review of all data packages before

reporting results.

Laboratory Quality Assurance Officer The Laboratory QAO will be primarily responsible for implementing the laboratory’s QAP within

the laboratory, and monitoring compliance with the laboratory’s QAP. The Laboratory QAO’s

duties will also include: conducting laboratory audits, reviewing all QC data, and reporting

problems to the Laboratory Director for corrective action.

1.1.5 Special Training Requirements / Certifications All project personnel must be qualified and trained in the project tasks for which they are

responsible.



5

1.1.5.1 Field Personnel It is not anticipated that the completion of this project will require any uniquely trained

personnel. However, all field personnel must complete a site specific safety class

offered by Holly. If specialized training is required for any portions of the project, training

will be provided by a qualified trainer and the date and type of training will be

documented. The Site Health & Safety Plan (HASP) specifies the training necessary for

compliance with the Occupational Safety and Heath Administration (OSHA)

requirements. All field personnel will have completed OSHA 40-hour and annual 8-hour

refresher Hazardous Waste Operations and Emergency Response (HAZWOPER)

standard training, as required for personnel potentially exposed to hazardous

substances, as specified by 29 CFR 1910.120. If hazardous materials are moved off-

Site, compliance with the Department of Transportation (DOT) training requirements for

shipping hazardous materials may be required.

1.1.5.2 Laboratory Personnel Every employee has direct access to the Quality Assurance Manual (QAM) and training

is provided in order to help each employee apply the QAM to his or her specific

responsibilities. Records of relevant qualifications, training, skills and experience of the

technical personnel are maintained by the laboratory.

Analysts that operate Graphite Furnace Atomic Absorption (GFAA), Inductively Coupled

Plasma (ICP), Inductively Coupled Plasma Mass Spectrometry (ICPMS), Gas

Chromatography (GC), or Gas Chromatography Mass Spectrometry (GC/MS) equipment

must satisfactorily complete a short course offered by an equipment manufacturer,

professional organization, university, or other qualified training facility (formal in-house

training is acceptable). A minimum experience requirement for the operation of GFAA,

ICP, ICPMS, GC, and GCMS equipment is one year.

1.2 Facility History/ Background Information The Facility is located at 902 West 25th Street, Tulsa, Tulsa County, Oklahoma as shown on

Figure 1. The Facility occupies approximately 474 acres of land and has been in operation

since 1906 by several different operators including Texaco and the Sinclair Tulsa Refining

Company (Sinclair). Typical products produced at the refinery include: gasoline; diesel fuel; fuel



6

oils; fuel gases; asphalt and sulfur. The principal process units at the Facility consist of crude

distillation, distillate hydrotreating, naphtha hydrodesulfurization, fluid catalytic cracking,

isomerization, catalytic reforming, alkylation, diesel hydrodesulfurization and sulfur recovery. A

Facility Base Map showing pertinent Facility features including the land treatment units (LTUs),

Interim point of compliance (POC) wells, and the Facility-wide monitoring well gauging network

is included as Figure 2.

The Facility currently holds a Resource Conservation & Recovery Act (RCRA) post-closure

permit for the Flare Area LTU, Permit #990750960-PC. The Facility previously held an

additional permit #990750960-OP for operation of the Walnut Grove LTU. This permit expired

on December 10, 2008, prior to Holly taking ownership of the Facility. As part of the RCRA

permit, Holly is required to submit Semi-annual Monitoring Reports (SMRs) of the results from

monitoring of the LTUs. Holly has also previously submitted the results of the LNAPL

monitoring and recovery efforts to the DEQ annually.

On November 30, 2009 Holly entered into Consent Order (Case No. 09 —319) with the DEQ to

resolve certain hazardous waste permit related compliance issues in anticipation of Holly’s

purchase of the Facility from Sinclair on December 1, 2009. The Consent Order mandated the

inclusion of the Walnut Grove LTU (WGLTU) post-closure care requirements into the Flare Area

LTU (FALTU) post-closure permit. Holly was required to submit a RCRA Part B permit

modification application to the DEQ no later than 150 days from the date of change in ownership

of the Facility.

The Consent Order also required the inclusion of other Solid Waste Management Units

(SWMUs) and Areas of Concern (AOCs) into the Flare Area post-closure permit application

along with schedules for investigation of the LNAPL and dissolved-phase plumes underling the

Facility. On April 30, 2010 Holly submitted a draft RCRA LTU post-closure care permit

application to the DEQ for the Facility. The DEQ, per a new Facility Consent Order (Case No.

11-100), effective date of July 6, 2011 (received by Holly on July 26, 2011), indicated that all

tasks have been completed and Holly has satisfied all provisions related to the November 2009

Consent Order.



7

On September 1, 2010 Holly met with the DEQ to present and discuss current environmental

conditions at the site and to confer on deficiencies with Holly’s RCRA post-closure care and

corrective action permit application (Permit). A preliminary conceptual site model (CSM) for the

Facility was reviewed. During the meeting, Holly suggested that a Facility-wide RCRA

permitting approach would be better protective of human health and the environment than the

current LTU based post-closure permitting approach. Evidence to support this conclusion was

presented by Holly. A review of current environmental subsurface conditions showed that the

LTUs do not appear to be sources for the Facility-wide LNAPL and dissolved-phase plumes that

are present underlying portions of the refinery. Also, no statistically significant soil or

groundwater detections had been observed from decades of compliance monitoring at the Flare

Area and Walnut Grove LTUs. Holly also proposed that the annual LNAPL report be combined

with the SMR and be submitted two times per year instead of annually.

The DEQ subsequently agreed that a Facility-wide post-closure and corrective action permit

would be better protective of human heath and the environment for this Facility. The DEQ

indicated that Holly would need to enter into a Consent Order to transition the Facility from an

LTU-based to a Facility-wide based RCRA Permit. In correspondence dated November 12,

2010, Holly proposed specific Facility-wide modifications to the FALTU Permit monitoring

program. The proposed modifications expanded the number and size of the area monitored by

POC wells and increased the chemical parameters required to be analyzed in groundwater.

LTU-focused monitoring, including soil monitoring of the LTUs, was eliminated. Groundwater

sampling would only be conducted at the newly designated interim Facility-wide POC wells.

Statistical analysis of LTU-focused samples would no longer be required on soil or groundwater

laboratory analytical results.

Holly was notified by the DEQ on November 15, 2010 that the proposed modifications to the

monitoring program were conditionally approved provided that Holly add additional interim

Facility-wide POC wells in locations specified by the DEQ prior to the May 2011 sampling event,

and that Holly designate at least 150 monitoring wells to become the new Facility-wide

monitoring well gauging network. The additional POC wells were installed between April 11

and April 19, 2011. The wells were developed and surveyed upon completion. The wells were

sampled during the May 2011 sampling and gauging event as part of the new Interim POC

monitoring well network.



8

The Consent Order to transition the refinery into a Facility-wide post-closure and corrective

action permit was executed on July 6, 2011. This Consent Order also requires Holly to submit a

new RCRA Part B Permit Application for Post-Closure and Corrective Action to the DEQ on or

prior to October 21, 2011. The Consent Order additionally requires Holly to continue to recover

LNAPL from the subsurface and submit a sampling and analysis plan for the transition period.

This SAPQAPP is intended to fulfill the latter requirement and serve as the Facility SAPQAPP

until the new RCRA Permit becomes effective.

1.3 Project Description and Schedule This SAPQAPP specifies the new Facility monitoring requirements developed to transition the

Facility from the LTU-focused monitoring approach of the former WGLTU and current FALTU

permits to a Facility-wide approach as approved by the DEQ and as detailed in Section 1.2,

above. The new Facility-wide groundwater monitoring program has been designed to include at

least two downgradient and one upgradient POC monitoring wells from both the Flare Area and

Walnut Grove LTUs. To establish a more comprehensive analytical baseline for the Facility-

wide groundwater monitoring program, the new POC wells are now analyzed for the modified

Skinner’s List (MSL) analytes instead of the previous limited analyte list. All POC wells will be

sampled on a semi-annual basis.

As approved by the DEQ in the July 2011 Consent Order, Holly will inspect the LTUs semi-

annually, after significant storm events or at other times inspections may be warranted. The

SMR reports will now cover a six-month period ending in June and December each year and will

be submitted to the DEQ within 45 days after these periods end. The SMR reports will be

expanded to include all Interim Facility-wide POC groundwater analytical results, Facility-wide

LNAPL gauging results, apparent LNAPL thickness contour maps, dissolved-phase

concentration maps, and groundwater elevation contour maps as well as information required

by the current FALTU post-closure permit until the new RCRA Part B Post-Closure and

Corrective Action Permit becomes effective. The semi-annual groundwater sampling schedule

is provided below. A Facility Base Map showing the locations of POC monitoring wells, Facility-

wide gauging well network, LTUs and other pertinent Facility features is provided as Figure 2.

The locations of the current LNAPL recovery systems are shown on Figure 3. Task details are

provided in Section 2.0.



9

Task Purpose Frequency Schedule Compliance Deadline

Facility-wide monitoring well

gauging

Evaluate LNAPL apparent thickness,

groundwater elevations and flow patterns

Semi-Annually During May and November sampling events, annually

June 30th and December 31st, annually; results

reported in SMRs due 45 days following each

monitoring period. POC well sampling Evaluate dissolved

phase plume condition, stability; identify

potential off-site/upgradient sources

impacting Facility (or LTU)

Semi-Annually May and November, each year



monitoring period.

LTU inspections and maintenance

Post-closure care, maintain integrity of

closed LTUs to mitigate environmental impacts

Semi-Annually; after significant storm events;

and as warranted by

Facility conditions

In conjunction with May and

November sampling

events, each year



monitoring period.

1.4 Data Quality Objectives 1.4.1 Project Quality Objectives The Data Quality Objectives (DQO) process is a mechanism to translate general project goals

into specific tasks, which are conducted to produce data needed to support decision making for

the project. The DQO process typically comprises a seven-step process. The first step is to

develop a CSM to provide an understanding of the Site based on available data, such as

analytical results, historic use, exposure pathways, cleanup concerns, and future land use. The

model is refined as additional data are added. With a well-defined CSM, the goals of the

investigation are translated into qualitative and quantitative statements that define the type of

data needed. These data needs include the number and type of samples to be collected,

analytical detection limits, and certainty. Based on the outputs of the DQO process, a detailed

work plan can be prepared.

The following provides the general DQO steps that will be involved for the collection of semi-

annual monitoring data at the Holly Tulsa East Refinery.



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1.4.1.1 Stating the Problem Routine groundwater sampling is required to monitor the conditions of the dissolved

phase and LNAPL plumes beneath the Facility, and the potential effects of such

conditions on human health and the environment, as set forth in the effective RCRA

permit(s) for the Facility.

The purpose of this SAPQAPP is to document groundwater sample collection

methodologies, laboratory analytical methods, data evaluation methodologies and

procedures, and resultant changes in sampling protocol for the semi-annual groundwater

sampling events at the Holly Tulsa East Refinery. These data will be used to evaluate

current conditions of groundwater and LNAPL beneath the Facility in support of remedial

strategy development, evaluation of remedial progress, and compliance with post-

closure care and corrective action requirements set forth in the effective RCRA permit(s)

for the Facility.

1.4.1.2 Identifying the Decision

Data collected during routine groundwater monitoring will be used to determine the

following:

1. What is the current groundwater table elevation, flow direction and estimated hydraulic gradient beneath the Facility? Is this consistent with historical groundwater flow patterns?

2. Have the chemicals of concern (COC) concentrations increased or

decreased along the POC well network since the last monitoring period(s)?

3. Area COCs migrating across the Facility property?

4. Are the vertical and lateral extents of the dissolved phase and LNAPL

plumes defined?

5. Do the dissolved phase benzene and MTBE plumes appear to be migrating, expanding or shrinking?

6. Are any new Skinner List compounds exhibited in groundwater analytical

results not generally detected in historic data?

7. What is the current estimated LNAPL footprint(s) and thickness(es)?



11

8. Do(es) the LNAPL plume(s) appear to be expanding, shrinking or stable compared to the previous reporting period(s)?

9. What are the groundwater quality trends across the Facility (based on

field parameters)?

10. Do groundwater quality parameters suggest an environment conducive to natural attenuation of persistent COCs beneath the Facility?

11. Are changes to the Interim POC monitoring network and/or the Facility-

wide gauging network warranted to fill data gaps or eliminate redundancies?

12. Are additional groundwater quality, chemical or geochemical parameters

necessary to further evaluate plume effects, natural attenuation characteristics, and/or potential remedies?

13. Do the results of the groundwater sampling event validate the current

Conceptual Site Model?

14. Is the Facility in compliance with the effective RCRA Permit(s)?

15. Are additional investigations or actions warranted based on the findings to the above items 1 through 14?

1.4.1.3 Identifying Inputs to the Decision Groundwater samples will be collected and analyzed throughout the duration of the

project in order to support the decision and answer the questions posed in DQO

STEP 2. The decision inputs include:

1. spatial variation in groundwater COC data under current conditions; 2. spatial variation of LNAPL beneath the Facility;

3. spatial and temporal variation in water level data;

4. spatial variation in groundwater gradients;

5. spatial variation in water quality parameter data, including pH,

temperature, specific conductivity, dissolved oxygen, redox potential and turbidity.



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1.4.1.4 Defining the Boundaries of the Study The boundary of the study refers to both the spatial and temporal boundaries. The

boundaries are defined to ensure that samples are representative of the area for which

decisions will be made. Practical constraints on data collection need to be recognized.

These constraints include meteorological conditions that would preclude sampling;

inability to secure necessary access agreements; or the unavailability of personnel, time,

or equipment.

The groundwater monitoring protocol includes wells located on the Facility property, as

well as off-property wells located east of the Facility. Wells located east of Facility

include the American Electric Power property and the property leased to the River Parks

Authority along the river bank.

1.4.1.5 Developing a Decision Rule A decision rule usually compares an output parameter to an action level, which then is

used to determine course of action for the Site. A series of “if…then” statements has

been developed to define the conditions that assist in choosing courses of action for the

Site.

Based on analytical results obtained from previous groundwater samples, the following

“if…then” statement will be applied to the data obtained during each groundwater

sampling event:

If analytical results demonstrate COC concentrations greater than applicable groundwater screening levels at POC wells, select wells may be re-sampled and/or additional remedial measures may be implemented.

If analytical results demonstrate increasing COC concentrations in upgradient

POC wells, additional investigations may be implemented to assess potential new release(s) from on- or off-site sources.

If data gaps or redundancies are identified, additional monitoring wells may be

installed and sampled, or select wells may be recommended to be eliminated from the monitoring or sampling plans.



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If evaluations of the dissolved phase and/or LNAPL plume(s) indicate plume expansion, mobility or migration, additional remedial measures or modifications to any existing corrective action may be implemented.

1.4.1.6 Specifying Limits on Decision Errors The well spacing and placement of the monitoring wells for Facility-wide permit

compliance have been developed, in part, from current groundwater COC

concentrations and predominant groundwater flow directions. The number of POC and

gauging network wells were also determined with respect to the DEQ requirements for

the new Facility-wide RCRA permit.

Sampling may not capture all of the variations in concentrations and analyses can only

estimate the “true” value. Sampling “error” occurs when the sampling scheme does not

adequately detect the variability in the amount of contaminant in the environmental

matrix from point to point across the Site. The potential for these errors may be reduced

by implementing the DQO process when developing the monitoring plan.

The true value of an environmental measurement can be in question due to sampling

error. Sampling errors can occur when sampling is unable to capture the complete

scope of natural variability that exists in the environment. Data may also be

questionable due to measurement errors. Measurement errors can happen during

sample collection, handling, preparation, analysis, data reduction, or data handling.

There may be corrective steps that can be taken or additional qualifying information that

can be collected that will allow for the full or limited use of the data. Corrective actions

are discussed in Section 2.8.6 of this document.

1.4.1.7 Optimizing the Design The purpose of this step is to identify the most resource-effective sampling design that

generates data to satisfy the DQOs specified in the preceding steps. The sampling and

analysis program designed for this project was developed by considering overall cost

and ability to meet the previously defined DQOs.



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1.5 Quality Assurance Objectives for Measurement Data The overall QA objective for each project is to develop and implement procedures for field

sampling, chain-of-custody, laboratory analysis, and reporting that will provide legally defensible

results. Specific procedures for sampling, chain-of-custody, laboratory instrument calibration,

laboratory analysis, reporting of data, internal quality control, audits, preventive maintenance of

field equipment, and corrective action are described in other sections of this SAPQAPP.

Data quality objectives for measurements collected during the semi-annual sampling events will

be addressed in terms of precision, accuracy, representativeness, completeness, and

comparability (PARCC parameters). The collection of data used in this project will require that

the sampling and testing be performed using standard methods, with properly operated and

calibrated equipment, and conducted by trained personnel.

The following sections provide detailed discussion of PARCC elements.

1.5.1 PARCC Element – Precision

1.5.1.1 Definition Precision is a measure of the degree to which two or more measurements agree.

1.5.1.2 Field Precision Objectives Field precision will be assessed through the collection and measurement of field

duplicates for groundwater samples. Field duplicate samples will be collected at a rate

of one duplicate per 20 samples or a minimum of one per day of sampling.

1.5.1.3 Laboratory Precision Objectives Precision in the laboratory is assessed through the calculation of relative percent

difference (RPD) and relative standard deviations (RSD) for three or more replicate

samples. Precision control limits for the subcontracted analytical laboratory will be

provided in laboratory SOPs to be supplied by the contracted laboratory selected to

perform the work.

Laboratory precision shall be assessed by the preparation and analysis of method blank

analysis and blank spike analysis also know as Laboratory Control Samples (LCS) for



15

each analytical sequence. The analyte spiking list will be in accordance the standard

methods for the outlined in “Standard Methods for the Examination of Water and

Wastewater” or as appropriate as deemed by the sampling method.

Spiked samples are prepared by choosing a sample at random from each sample

shipment received at the laboratory, dividing the sample into equal aliquots, and then

spiking each of the aliquots with a known amount of analyte. The duplicate samples will

then be included in the analytical sample set. Splitting of the sample allows the analyst

to determine the precision of the preparation and analytical techniques associated with

the duplicate sample. The relative percent difference (RPD) between the spike and

duplicate spike will be calculated and plotted. The RPD is calculated according to the

following formula:

( )Spike 1 conc. - Spike 2 conc.RPD = x 100

0.5 Spike 1 conc. + Spike 2 conc.

1.5.2 PARCC Element - Accuracy 1.5.2.1 Definition Accuracy is the degree of agreement between an observed value and an accepted

reference or true value.

1.5.2.2 Field Accuracy Objectives Accuracy in the field is assessed using field and trip blanks and through the adherence

to all sample handling, preservation, and holding times. A trip blank will consist of a

laboratory-prepared sample of reagent grade water. Trip blanks will accompany sample

shipments which contain samples requiring volatile organic compound (VOC) analysis

and be subjected to the same procedures as the investigative samples. Trip blanks are

only required when VOCs will be analyzed. Trip blanks will be submitted for analysis at

the rate of one trip blank per shipping container containing samples for VOC analyses.

Field blanks (equipment blanks) will be collected by pouring laboratory-prepared water

or distilled water over or through the sampling equipment and collecting the rinseate in



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the proper analytical containers. Field blanks are required at a rate of one per 20

investigative samples or a minimum of one per day of sampling when non-dedicated

equipment is used in sampling procedures.

1.5.2.3 Laboratory Accuracy Objectives Laboratory accuracy is assessed through the analysis of Matrix Spike/Matrix Spike

Duplicate (MS/MSD) samples, laboratory control samples (LCSs) and surrogate

compounds, and the determination of percent recoveries. Accuracy control limits will be

provided in laboratory SOPs to be supplied by the contracted laboratory selected to

perform the work.

In order to assure the accuracy of the analytical procedures, an environmental sample

will be randomly selected from each sample shipment received at the analytical

subcontractor’s laboratory, and spiked with a known amount of the analyte. At a

minimum, a sample spike will be included in every set of twenty samples tested, or at

least once daily, on each instrument for each sample matrix to be tested. The increase

in concentration of the analyte will be observed in the spiked sample, due to the addition

of a known quantity of the analyte, compared to the reported value of the same analyte

in the unspiked sample to determine the percent recovery. Daily control charts will be

plotted for each commonly analyzed compound and maintained on instrument-specific,

matrix-specific, and analyte-specific bases.

Percent recovery for MS/MSD results is determined according to the following equation:

(Spiked Sample Conc. - Sample Conc.)%R = x 100

Known Conc. Added

Percent recovery for LCS and surrogate compound results is determined according to

the following equation:

Experimental Conc.%R = x 100Known Amount Added



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Additional information on laboratory accuracy will be provided in the method specific

SOPs to be supplied by the contracted laboratory selected to perform the work.

1.5.3 PARCC Element - Completeness 1.5.3.1 Definition Completeness is a measure of the amount of valid data obtained from a measurement

system compared to the amount expected under normal conditions.

1.5.3.2 Field Completeness Objectives Field completeness is a measure of the amount of valid measurements obtained from all

the measurements taken during the project. Field completeness objective for this project

will be greater than ninety percent.

1.5.3.3 Laboratory Completeness Objectives Laboratory completeness is a measure of the amount of valid measurements obtained

from all the measurements taken during the project. Laboratory completeness for this

project will be greater than ninety-five percent.

Completeness is the ratio of the number of valid sample results to the total number of

samples analyzed with a specific matrix and/or analysis. Following completion of the

analytical testing, the percent completeness will be calculated by the following equation:

Number of Valid MeasurementsCompleteness = x 100

Number of Measurements Planned

1.5.4 PARCC Element - Representativeness

1.5.4.1 Definition Representativeness expresses the degree to which data accurately and precisely

represents a characteristic of a population, parameter variations at a sampling point, a

process condition, or an environmental condition within a defined spatial and/or temporal

boundary.



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1.5.4.2 Measures to Ensure Representativeness of Field Data Representativeness will be achieved by insuring that sampling locations are properly

selected and that a sufficient number of samples are collected. Representativeness is

dependent upon the proper design of the sampling program and will be accomplished by

ensuring that this SAPQAPP and all relevant SOPs are followed. The QA goal will be to

have samples and measurements representative of the media sampled. Field testing for

pH, temperature, conductivity, dissolved oxygen, redox potential, and turbidity

stabilization prior to groundwater sampling will help ensure that representative samples

are collected.

1.5.4.3 Measures to Ensure Representativeness of Laboratory Data Using the proper analytical procedures, appropriate methods, meeting sample holding

times and analyzing and assessing field duplicate samples, ensures representativeness

in the laboratory.

1.5.5 PARCC Element - Comparability 1.5.5.1 Definition Comparability is an expression of the confidence with which one data set can be

compared with another. Comparability is also dependent on similar QA objectives.

1.5.5.2 Measures to Ensure Comparability of Field Data Comparability is dependent upon the proper design of the sampling program and will be

satisfied by ensuring that this SAPQAPP is followed and that proper sampling

techniques are used.

1.5.5.3 Measures to Ensure Comparability of Laboratory Data Planned analytical data will be comparable when similar sampling and analytical

methods are used and documented in the SAPQAPP. Comparability is also dependent

on similar QA objectives.



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1.6 Documentation and Records Data collected in support of on-going dissolved phase plume assessment and LNAPL

containment evaluation will be submitted semi-annually and will, at a minimum, include:

1. text describing rationale for sampling and analysis activities, sample collection and analysis activities, data analysis, and exposure evaluation and applicable standards;

2. figures showing property location, property boundaries, and sampling locations;

3. a table summarizing water level data;

4. potentiometric surface maps based on the gauging event data;

5. tables summarizing analytical results;

6. parameter isoconcentration maps (as warranted);

7. tables summarizing hydrocarbon (LNAPL) recovery system performance;

8. a summary of findings and recommendations for future activities;

9. complete laboratory data reports;

10. other relevant materials required to support the DQO objectives; and

11. a bibliography of references and appendices of supporting documents.

All records generated during these investigations will be kept on file by the Environmental

Consultant. These records will be considered part of the final evidence files and will at a

minimum include: field logbooks; field data and data deliverables; photographs; drawings; soil

boring logs; laboratory data deliverables; data validation reports; data assessment reports;

progress reports, QA reports; interim project reports, etc.; and all custody documentation (tags,

forms, airbills, etc.). Final Evidence files are discussed in detail in Section 2.4.5.9 of this

SAPQAPP.



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2.0 FIELD SAMPLING AND ANALYSIS PLAN 2.1 Sampling Process and Design The purpose of this section is to describe the general sampling procedures that will be used

during this project. The current Environmental Consultant’s Standard Operating Procedures

(SOPs) that are likely to be employed in the course of this project have been included in

Appendix A. Additional SOPs will be included in the groundwater monitoring work plan, as

necessary. Sampling efforts will be uniform and follow the QAPP and SOPs to ensure the

quality of the data collected.

The groundwater sampling plan for the Holly Tulsa East Refinery consists of the following tasks:

1. Semi-annual gauging of Facility-wide monitoring well network and POC wells;

2. Semi-annual sampling of all POC wells;

3. Semi-annual Monitoring Reports (SMRs) summarizing groundwater monitoring results and LNAPL recovery system operations, including modifications to the SAPQAPP or LNAPL system operations.

Primary constituents of concern at the Site include petroleum related VOCs and semi-volatile

organic compounds (SVOCs). QA/QC samples will be submitted in accordance with the

protocols presented in the following sections of this QAPP. Requirements for QA/QC samples

are identified in Sections 2.3 and 2.4.

2.2 Task 1 – Groundwater and LNAPL Gauging The purpose of this section is to describe the methods and procedures that will be used during

semi-annual groundwater and LNAPL gauging events. Water levels and LNAPL thickness

measurements will be collected as described in Section 2.2.1. The purpose of the semi-annual

gauging event is to assess current horizontal groundwater flow and LNAPL plume

characteristics.

2.2.1 Water Level and LNAPL Measurements Water level and LNAPL thickness measurements will be collected using manual methods.



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2.2.1.1 Measurement Locations and Frequency

Groundwater level and LNAPL thickness measurements will be collected from the

Facility-wide gauging network and POC wells on a semi-annual basis. The complete list

of wells to be gauged during each semi-annual event is presented in Table 1.

2.2.1.2 Equipment and Procedures In general, manual water level and LNAPL thickness measurements will be collected

using an electronic water level indicator. Each measurement shall be taken to the

nearest 0.01 of one foot from the reference point of each well. The reference point,

unless otherwise marked, shall be the north side of the top of casing (i.e., riser). A

detailed description of the procedures for water level measurements is included in

groundwater sampling SOP No. F3008-07rev.

For wells in which LNAPL is detected, measured LNAPL thickness (LT) will be recorded

via measurements of product depth (PD) and groundwater depth (GD); LT will then be

calculated as:

LT (measured) = GD - PD

To correct groundwater elevations for wells in which LNAPL is detected, the following

formula shall be used:

CPE = Well Datum – GD + (LT x SG)

Where:

CPE = Corrected Potentiometric Elevation

GD = Groundwater Depth

LT = LNAPL Thickness (measured)

SG = Specific Gravity of the LNAPL

Specific gravities of product observed at select monitoring locations have been identified

by Sinclair in previous SMRs as follows:



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Well ID SG (gm/cm3)

SR-27, TX-065 0.79

TX-077 0.80

TX-004, TX-040, TX-101, WTP-11, WTP-13 0.81

TX-006, TX066, TX-139 0.82

TX-007 0.83

TX-063, TX-073, TX-080, TX-105 0.85

TX-010, TX-011 0.86

TX-089, TX-102, TX-110, TX-150 0.87

TX-059, TX-082, TX-136 0.88

TP-1, TP-4, TP-7 0.92

For all other wells, where Specific Gravity data is unavailable, an average specific

gravity of 0.84 shall be used until new data is generated

2.2.1.3 Documentation Water level and LNAPL measurements will be recorded on the appropriate task-specific

forms, where appropriate. These forms include site water level measurement forms and

groundwater sampling data sheets. Water level and LNAPL data may also be recorded

in the field notebooks.

2.2.1.4 Decontamination The water level indicator will be decontaminated in accordance with SOP No. F1000.

2.2.1.5 Investigative Derived Waste All decontamination fluids will be processed through the Facility on-site Waste Water

Treatment Plant (WWTP).

2.3 Task 2 – Groundwater Sampling 2.3.1 General Sampling Requirements The purpose of this section is to describe the general sampling procedures to be employed

during semi-annual groundwater monitoring events. Contained in Appendix A are the current

Environmental Consultant’s SOPs relevant to the field activities described herein. Sampling



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efforts will be uniform and follow the QAPP and SOPs to ensure the quality of the data

collected. Routine groundwater monitoring includes lab analysis for Region 5 Skinner List and

field data acquisition of pH, specific conductivity, temperature and total dissolved solids.

2.3.2 Monitoring Wells Requiring Groundwater Sampling During each semi-annual groundwater sampling event, all Interim POC network wells and the

gauging network wells listed in Table 1 will be gauged to evaluate groundwater elevations and

apparent LNAPL thickness beneath the Facility, as described in Section 2.2. All POC wells will

then be sampled for Region 5 Skinner List parameters including VOCs, SVOCs and inorganics.

The Facility Interim POC wells, including location, designation and sampling frequency, are

listed on Table 2.

Low flow sampling techniques, as discussed in Section 2.3.3, will be used to collect the

groundwater samples during each semi-annual sampling event. The groundwater sampling

results will be used to evaluate current conditions of the dissolved phase and LNAPL plumes,

maintain compliance with the RCRA permit(s) for the Facility and to evaluate the need for

modifications to any Facility corrective actions and/or the Facility-wide sampling protocol.

2.3.3 Laboratory Analysis Environmental samples and QA/QC samples will be collected and submitted for laboratory

analysis of:

• Region 5 Skinner List VOCs by USEPA Method 8260

• Region 5 Skinner List SVOCs by USEPA Method 8720 • Region 5 Skinner List Inorganics by USEPA Methods 6010, 7040/4041 and SM

4500-CN-E, as applicable

The Region 5 Skinner List is summarized in Table 3, including a list of target analytes and their

associated sample methods. Table 4 provides a summary of practical quantitation limits and

performance criteria for proposed analytes. The laboratory SOPs, referenced on Table 4, are to

be supplied by the contracted laboratory selected to perform the work. Information regarding

the project target compounds, quantitation limits, and applicable standards is provided and will

be in accordance with the Method. Sample QA/QC requirements are listed in Table 5.



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Samples will be analyzed at standard turn around times.

2.3.4 Sampling Equipment Preparation and Decontamination

Sampling equipment that is to be reused (i.e. submersible pumps) will be thoroughly

decontaminated between sampling locations and at the beginning and end of each day.

Decontamination will consist of washing equipment with mild, non-phosphate soap such as

Liquinox, and thoroughly rinsing with distilled water. If complete cleaning of any piece of

sampling equipment is not possible, then it will be discarded and a clean article substituted. For

electronic well purging equipment, non-phosphate soapy water will be run through the pump

and hose followed by a thorough rinsing with distilled water. For a more detailed explanation of

decontamination procedures see SOP No. F1000-99rev (Appendix A).

2.3.5 Groundwater Sampling Methodology Groundwater samples obtained during the semi-annual sampling events will be collected using

low-flow sampling techniques in accordance with SOP F3008-10rev.

2.3.5.1 Low-Flow Sampling A low flow submersible pump (or equivalent) will be used for the performance of low-flow

groundwater sampling for wells. The sampling tubing will be lowered into the wells

placing the tubing at the mid-point of the well screen or saturated screen interval. Actual

pumping rates will vary based on the Site geology; however typical pumping rates are

anticipated at less than 1L/minute. Drawdown during purging activities will be monitored

with an electronic water level indicator or interface probe. Purging will take place at

pumping rates which produce maximum targeted drawdowns of less than 0.3 feet.

Groundwater indicator parameters will be collected at 3 minute or greater intervals

during low-flow purging to determine water quality stabilization. The pump’s flow rate

must “turn over” at least one flow-through cell volume between measurements.

Dedicated or single use polyethylene or similar tubing will be used at each sample

location and will be properly disposed of after use. Sampling personnel will wear clean

nitrile gloves while handling sampling equipment or collecting samples. The following

steps will be conducted during sampling:



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1. The pump intake or tubing will be placed at the mid-point of the screened interval.

2. Groundwater will be extracted at a rate not to exceed 1 liter per minute or at a rate not to induce greater than 0.3 feet of drawdown, or have the water level drop below the top of the screen (if static water levels is above the top of the screen).

3. Field groundwater indicator parameters (temperature, pH, specific conductance, and dissolved oxygen,) will be recorded during purging using a multi-parameter water quality meter such as YSI 6820 or 600XL or equivalent, equipped with a flow-through cell until stabilization has occurred as described in SOP F3008-01rev.

4. Upon groundwater stabilization a groundwater sample will be collected by transferring water directly from the discharge line (i.e., pump tubing) into laboratory supplied sample container in a manner which will minimize agitation and aeration.

Stabilization is achieved when three consecutive readings for the groundwater quality

parameters are within the following criteria:

Dissolved Oxygen 10% for values greater than 0.5 mg/L

(3 consecutive reading of < 0.5 mg/L)

Specific conductivity 3%

Temperature 3%

pH +- 0.1 unit

Redox Potential +- 10 millivolts

Turbidity 10% for values greater than 5 NTU

(3 consecutive reading of values <5 NTU)

Upon stabilization of field parameters the groundwater sample will be collected. The

groundwater sample will be collected from the pump discharge line (i.e. pump tubing) upon

disconnection of the flow through cell. The samples will be collected directly from the discharge

line of the pump, avoiding the possibility for cross contamination from water or sediment

contained in the flow through cell.

If a gas generator or vehicle battery is used to power the pump, the generator/vehicle will we

located at least 30 feet from the monitoring well. This will help prevent the exhaust from

interfering with the sample collection process.



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2.3.6 Sample Containers and Preservatives

Sample containers for environmental analysis will consist of certified lab supplied glass and

plastic bottles. Table 6 lists the sample containers, preservatives, and holding times for

analyses to be completed for the semi-annual sampling event. The subcontracted analytical

laboratory will supply unpreserved, pre-preserved and VOC trip blanks as needed to complete

the scope.

2.3.7 Sample Storage and Transportation

Field samples will be packaged and shipped according to SOP No. F1013-01REV (Appendix A).

Coolers are the most common package or containment device used to ship samples. Coolers

are also used during sampling efforts to store and transport samples prior to shipping. Samples

will be placed in an iced cooler immediately after collection. Any samples not placed on ice

immediately upon collection will be discarded and a new sample will be collected.

2.3.8 Sample Handling and Custody Requirements Custody is one of several factors that are necessary for the admissibility of environmental data

as evidence in a court of law. Custody procedures help to satisfy the two major requirements

for admissibility: relevance and authenticity. Sample custody is addressed in three parts: field

sample collection, laboratory analysis, and final evidence files. Final Evidence files, including

originals of all laboratory reports and purge files, are maintained under document control in a

secure area.

A sample or evidence file is under your custody if:

1. the item is in actual possession of a person;

2. the item is in view of the person after being in actual possession of the person;

3. the item was in actual physical possession but is locked up to prevent tampering;

and/or,

4. the item is in a designated and identified secure area.

Field custody procedures are outlined in Section 2.3.6.1.



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2.3.8.1 Chain of Custody Procedures The Chain-of-Custody document records the history of the samples custody from

acquisition to ultimate disposal. Samples collected may be used as legal evidence. As

such, the hand-to-hand custody from the point of collection to delivery at the laboratory

must be clearly documented.

2.3.8.2 Field Custody Procedures The sample packaging and shipment procedures summarized below will ensure that the

samples will arrive at the laboratory with the chain-of-custody intact. The protocol for

specific sample numbering and other sample designations are included in Section

2.3.6.5 of this SAPQAPP. Examples of field custody documents are presented in SOP

No. F3014-02rev, Appendix A of this SAPQAPP.

1. The field sampler is personally responsible for the care and custody of the samples until they are transferred or properly dispatched. Field procedures have been designed to limit the handling of the samples to as few people as possible.

2. All bottles will be identified by the use of sample labels with sample numbers, sampling locations, date/time of collection, and type of analysis. The sample numbering system is presented in Section 2.3.6.5 of this SAPQAPP.

3. Sample labels will be completed for each sample using waterproof ink

unless prohibited by weather conditions. For example, a logbook notation would explain that a pencil was used to fill out the sample label because the ballpoint pen may not function appropriately under certain freezing weather.

4. A properly completed chain-of-custody form will accompany all samples.

The sample numbers and locations will be listed on the chain-of-custody form. When transferring the possession of samples, the individuals relinquishing and receiving will sign, date, and note the time on the record. This record documents transfer of custody of samples from the sampler to another person, to a mobile laboratory, to the permanent laboratory, or to/from a secure storage area.

5. Samples will be properly packaged and shipped according to procedures

found in SOP No. F1013-01rev.



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2.3.8.3 Sample Collection Samples will be collected following the SOPs documented in Appendix A of this

SAPQAPP. The equipment used to collect samples will be noted, along with the time of

sampling, sample description, depth at which the sample was collected, volume and

number of containers.

2.3.8.4 Sample Labeling

All sample containers will be labeled at the time of sampling. Each label will be

completed with the required information and then secured to the container with

transparent packing tape to prevent accidental loss or damage from water or

mishandling. Required information on the sample label includes: sample identification

number, date, time, and requested analyses. Additionally, any preservatives or special

handling instructions will be clearly displayed on the label and the Chain-of-Custody.

2.3.8.5 Sample Identification Numbers

A unique sample identification number (SIN) will identify each sample collected for

chemical analyses. These SINs include several key pieces of information such as the

sample location, sample type/matrix, and the sampled depth interval or date sampled.

Groundwater Samples

Some examples of nomenclature for water samples follow:

MW-267

Monitoring Well MW-267



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MW-267A

FB-1

Trip Blank

2.3.8.6 Field Sampling Data Sheets All field notes will be recorded on the appropriate sampling sheets. The appropriate field

data sheets must also be completed for each sampling location. As weather conditions

often prohibit the completion of data sheets in the field, data may be recorded in

waterproof field notebooks and then transferred to data sheets at the end of the day.

Field data sheets for various types of sampling are contained in Appendix B of this

SAPQAPP. The following field data sheets shall be completed for the following tasks:

Duplicate sample from Monitoring Well MW-267

Field blank number 1 (QA/QC sample)

Trip Blank (QA/QC sample)



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1. Daily Field Report will be completed for each day summarizing that day's activities and observations;

2. Water Level and Interface Measurement Sheets will be completed for

each well gauged; and 3. Groundwater Sampling Sheets will be completed for each monitoring well

sampled.

A copy of all field data sheets, daily reports, and field notes will be given to the PM after

returning from the property, while the originals will be maintained in the job file or project

notebook for that property. No one shall, at any time, remove information from job files,

QA files, or the project notebook for field use or other use. If copies of previous work are

required, then arrangements will be made with the Project Manager or QAO to copy a

portion of the file.

Field notebooks, field data sheets, or daily field reports will not be obscured, destroyed,

or discarded, even if they contain errors or are illegible. Entries will be described in as

much detail as possible so that persons going to the facility could reconstruct a particular

situation without reliance on memory. All entries will be made in permanent ink, signed,

and dated and no erasures will be made. Corrections will be made by drawing a single

line through the error and writing in correct information. The use of white-out,

obliterating, or writing directly over the erroneous entry will be prohibited. All corrections

will be dated and initialed by the person making the correction.

2.3.8.7 Laboratory Documentation Workbooks, bench sheets, instrument logbooks, and instrument printouts are used to

trace the history of samples through the analytical process and to document and relate

important aspects of the work, including the associated quality controls. All logbooks,

bench sheets, instrument logs, and instrument printouts are part of the permanent record

of the laboratory. The Laboratory Section Heads will periodically review laboratory

notebooks for accuracy, completeness, and compliance with the Laboratory QAP.

Completed workbooks and instrument logbooks will be submitted to the QA Officer(s) for

storage.



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In general, good laboratory practices require that the following (or equivalent)

procedures be used. Each page, or as required, each entry, will be dated and initialed

by the analyst when the record is made. Errors in entry will be crossed out in indelible

ink with a single stroke. The use of white-out, obliterating, or writing directly over the

erroneous entry will be prohibited. The individual making the correction will initial all

corrections.

2.3.8.8 Final Evidence Files The final evidence file will be the central repository for all documents, which constitute

evidence relevant to sampling and analysis activities as described in this SAPQAPP.

The Environmental Consultant is the custodian of the evidence file and maintains the

contents of evidence files for the investigation, including all relevant records, reports,

logs, field notebooks, pictures, subcontractor reports and data reviews in a secured,

limited access area.

The final evidence file may include:

1. field logbooks; 2. field data and data deliverables;

3. photographs;

4. drawings;

5. soil boring logs;

6. laboratory data deliverables;

7. data validation reports;

8. data assessment reports;

9. progress reports, QA reports, interim project reports, etc.; and

10. all custody documentation (tags, forms, airbills, etc.).

2.3.9 Investigative Derived Waste Purged water will be collected and processed through the Facility WWTP.



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2.4 Quality Control Requirements 2.4.1 Level of Quality Control Effort Field blanks (if applicable), trip blanks, method blanks, field duplicates, laboratory duplicates,

laboratory control, and matrix spike samples will be analyzed to assess the quality of the data

resulting from the field sampling and analytical programs.

Field (equipment rinseate) and trip blanks consisting of distilled water will be submitted to the

analytical laboratories to provide the means to assess the quality of the data resulting from the

field sampling program. Field blank samples are analyzed to check for procedural

contamination at the Site that may cause sample contamination; field blanks will be collected if

non-dedicated equipment is used for sampling. Trip blanks are used to assess the potential for

contamination of samples due to contaminant migration during sample shipment and storage.

Trip blanks pertain to volatile organic samples only. Trip blanks are prepared prior to the

sampling event in the actual sample containers and are kept with the investigative samples

throughout the sampling event. They are then packaged for shipment with other samples and

sent for analysis. There should be one trip blank included in each sample shipping container,

containing bottles for VOC. At no time after their preparation will the sample containers be

opened before they reach laboratory.

Method blank samples are generated within the laboratory and used to assess contamination

resulting from laboratory procedures. Duplicate samples are analyzed to check for sampling

and analytical reproducibility. Matrix spikes provide information about the effect of the sample

matrix on the digestion and measurement methodology. All matrix spikes are performed in

duplicate and are hereinafter referred to as MS/MSD samples. MS/MSD analyses will be

performed as part of the batch QC for each group of samples analyzed by the laboratory.

Where possible, the laboratory will attempt to have the MS/MSD be performed on samples

submitted for this project. Additionally, MS/MSD aliquots will be collected in the field to be

included as part of the QC program for the Site data.

All samples will be sent to the designated approved laboratory for analysis. All analyses will be

completed in accordance with the specified methods. The level of laboratory QC effort for this



33

project and quantitation limits will be in accordance with the laboratory’s SOPs, to be supplied

by the contracted laboratory selected to perform the work.

2.4.2 Internal Quality Control The purpose of internal quality control measures is to document the validity of analytical data

generated by the laboratory. Laboratory internal quality control may include, but is not limited

to, the analysis of method blanks, reference standards, analytical spikes, and surrogate spikes.

Every analytical series will include some of these controls depending on the analytical methods

used. The internal quality controls used by the laboratory will be combined so they are

completely representative of every aspect of the analytical task from sample preparation to

sample analysis.

The following sections present a summary of, and suggested frequencies for, various quality

control measures that may be used dependent upon the analytical method(s) selected.

2.4.2.1 Blank Samples

Blanks are used to assess contamination introduced in transit, storage, or in the

laboratory. The types and frequencies of laboratory blank samples are specified by the

U.S.EPA methods used for analysis.

Method Blanks

Method blanks identify sources of contamination throughout the analytical process,

whether a contribution of specific analytes or a source of interference, which will need to

be identified, isolated, and corrected. To accomplish this, the method blank must be

initiated at the beginning of the analytical process and include all aspects of the

analytical work. This includes glassware, reagents, and instrumentation, as well as any

other possible source of contamination. Minimum method blank analyses will be one

method blank per analytical series at a frequency of one per 20 samples. Method blanks

will meet the criteria specified in the subcontracted laboratory’s SOPs or the Method.

Instrument Blank

Instrument blanks are analyzed after a sample or dilution has run which contains a target

compound at a concentration greater than 25 ug/l, a non-target compound at a



34

concentration greater than 100 ug/l or saturated ions from a compound (excluding

compound peaks in the solvent front). The results of the instrument blank analysis

indicate whether there is residual contamination in the instrument from a previous

sample.

Storage Blanks

Another type of method blank is storage blank. Storage blanks are associated with

volatile organic analyses and indicates possible cross-contamination among samples

while stored at the laboratory. At least one storage blank, per each group of samples,

will be generated and analyzed with the samples.

2.4.2.2 Analytical Spikes

The purpose of an analytical spike is to assess the efficiency and proficiency of an

analytical series. This includes quantitation standards, sample preparation, instrument

set-up, and the premises inherent in quantitation. This control reflects the competency

of sample analysis within an analytical series while it is less sensitive in reflecting the

conditions that are within the control of the analyst. The types and frequencies of

analytical spikes are specified by the U.S. EPA methods used for analysis.

Matrix Spike

Within an analytical series, a representative sample portion is designated as a separate

sample and spiked with known concentrations of the analytes under consideration.

Advantages of spikes are that the spiked portion is handled and prepared in exactly the

same way as the samples. Sample related interference affecting analysis would be

reflected in the results from the spiked sample. Results of spikes exceeding tolerances

specified by the methods need to be evaluated thoroughly in conjunction with other

measures of control.

Surrogate Spike

Surrogates, which have properties similar to the analytes of interest, are compounds

unlikely to be found in nature. The intent of a surrogate spike is to provide broader

insight to the proficiency and efficiency of an analytical method on a sample specific

basis. This control reflects analytical conditions, which may not be attributable to the



35

sample matrix. If results of a surrogate spike analysis exceed method-specified

tolerances, then the analytical results need to be evaluated thoroughly in conjunction

with other control measures. Re-analysis of the sample with additional controls, or

different analytical methodologies, will be necessary.

2.4.2.3 Reference Standards

Reference standards are standards of known concentration and independent in origin

from the calibration standards. These reference standards are generally available

through the U.S. EPA, the National Bureau of Standards, or are specified by analytical

methodologies. The purpose of a reference standard is to assess analytical proficiency

within an analytical series including the preparation of calibration standards, the validity

of calibration, sample preparation, instrument set-up, and the premises inherent in

quantification. Reference standards will be used in every analytical series except gas

chromatography/mass spectrometry (GC/MS) and specific GC analyses, for which there

are no reference standards.

A control chart will be maintained for analytes in which reference standards are used in

their analyses. When a reference standard value exceeds the established warning limits,

careful scrutiny will be given to the operations system, standards preparation, and

procedures that were used in obtaining the result. If the value of the reference standard

exceeds the established control limits, then the sample analysis will be stopped and

corrective action will be initiated. Samples analyzed since the last passing reference

standard will be re-analyzed following instrument recalibration.

2.4.2.4 Replicate Analysis

Replicate analysis is a measure of analytical precision and can be limited in its scope. If

used in conjunction with reference standards or analytical spikes, it can measure the

reliability of the analytical systems. Replicate analyses can be significant in the

interpretation of analytical results for samples with complex matrices.

2.4.2.5 Calibration Check Standards

The purpose of a calibration check standard is to assess an instrument's stability. A

calibration check standard will be analyzed at the beginning and end of an analytical



36

series or periodically throughout large series of samples. Calibration check standard will

be run after every twelve hours. In analyses where internal standards are used, a

calibration check standard need only be run at the beginning of an analytical series. If

results of the calibration check standard exceed method specified tolerances, then

samples analyzed since the last acceptable calibration check standard will be re-

analyzed.

2.4.2.6 Internal Standards

Internal standards will be monitored when required by the Method (e.g., U.S. EPA SW-

846 Method 8260C). The internal standard is present in all acquisitions with the

exception of performance standards. The standard response must be +/- 50% of the

initial calibration response and +/- 30% seconds of the initial calibration retention time. If

internal standard areas in one or more samples exceed the specified tolerances, then

the instrument will be recalibrated and all affected samples re-analyzed.

2.4.3 Sampling Quality Control Several sampling quality control measures will be necessary to assess the integrity of samples

collected and determine if the QA objectives discussed in this SAPQAPP are being met. These

measures include the use of duplicate samples and field blanks to locate possible sources of

sample contamination. Table 5 provides a summary of field quality control frequencies.

Groundwater and other aqueous samples will be analyzed at a frequency of approximately five

percent of the investigative samples. Field blanks will be collected by running laboratory

prepared water or distilled water through or over the parts of the sampling devices that contact

the samples. The rinseate will be transferred directly to the appropriate laboratory supplied

analytical containers. Field blanks will be analyzed for the same parameters as the field

samples. It is the sampler’s responsibility to collect the appropriate number of field blanks for

each sampling activity.

Field duplicate samples will be collected at a minimum frequency of one per every twenty

investigative samples.



37

2.5 Instrument Calibration and Maintenance Requirements 2.5.1 Field Instrument Calibration and Preventative Maintenance The field equipment for this project may include such items as thermometers, pH meters,

conductivity meters, Flame Ionization Detector (FID), or Photoionization Detector (PID), multi-

parameter water quality meters and other monitoring equipment as needed. Specific

preventative maintenance procedures to be followed for field equipment are those

recommended by the manufacturer. Field instruments will be calibrated daily before use,

following manufacturer’s procedures, and checked as field conditions necessitate through the

day. Initial calibration and calibration checks will be documented on the Field Instrument

Calibration Log (Appendix B). The maintenance schedule for field instruments is indicated in

Table 7. Critical spare parts such as tape and batteries will be stored on-site to reduce

downtime. Backup instruments and equipment will be available on-site or within one-day

shipment to avoid delays in the field schedule.

The data quality objectives for field instrumentation are summarized in Table 8.

2.5.2 Laboratory Instrument Preventative Maintenance As part of the QA Program Plan, a routine preventative maintenance program is conducted by

the analytical subcontractor to minimize the occurrence of instrument failure and other system

malfunctions. Designated laboratory employees regularly perform routine scheduled

maintenance and repair of (or coordinate with the vendor for the repair of) all instruments. All

maintenance that is performed is documented in the laboratory's operating record. All

laboratory instruments are maintained in accordance with manufacturer's specifications and the

requirements of the specific method employed. This maintenance is carried out on a regular,

scheduled basis, and is documented in the laboratory instrument service logbook for each

instrument. Emergency repair or scheduled manufacturer’s maintenance is provided under a

repair and maintenance contract with factory representatives. Table 9 provides an example of a

preventive maintenance schedule for laboratory equipment. The laboratory will maintain an

adequate supply of all necessary spare parts.

2.5.3 Laboratory Instrumentation Calibration Procedures Calibration procedures for a specific laboratory instrument will consist of initial five-point

calibration, initial calibration verification and continuing calibration verification. The selected



38

analytical subcontractor will provide SOPs describing the calibration procedures for each

specific laboratory instrument, including their frequency, acceptance criteria, and the conditions

that will require recalibration. Laboratory instrumentation calibration procedures will meet the

requirements of the appropriate Method.

2.5.4 Field and Laboratory Consumables An adequate supply of all supplies and consumables will be available for field and laboratory

work. All supplies used in the field and laboratory will be inspected prior to use to ensure that

they are free from visible defects. Sampling equipment and analytical supplies will be subject to

the various QC measures (i.e., equipment blanks and method blanks) previously discussed.

Any unacceptable supplies or consumables will be discarded and replaced with an acceptable

item.

2.6 Data Management 2.6.1 Sample Documentation All sample documents will always be legibly written in ink. Any corrections or revisions to

sample documentation shall be made by drawing a single line through the error, writing in the

correct information, and initialing any changes. The following sections are provided to outline

sample documentation procedures that will be employed when conducting the semi-annual

groundwater sampling activities.

2.6.2 Field Data Sheets General field notes will be recorded on field data sheets using indelible ink. Examples of the

field data sheets anticipated to be used during the semi-annual sampling events have been

included in Appendix B. When weather conditions prohibit the completion of data sheets in the

field, data may be recorded in field notebooks and then transferred to data sheets at the end of

the day.

Additionally, a Daily Field Report or equivalent document may be completed at the end of the

day summarizing the day's activities and observations. Copies of the documentation will be

provided to the PM as necessary. If copies of previous work are required, arrangements will be

made with the PM.



39

Field notebooks, field data sheets, or daily field reports will not be obscured, destroyed, or

discarded, even if it contains errors or is illegible. Corrections will be made by drawing a single

line through the error, writing in the correct information, and initialing any changes. Corrections

will be dated and initialed by the person making the correction.

2.6.3 Laboratory Data Reduction, Review and Reporting 2.6.3.1 Data Reduction

Analytical results will be reduced to the concentration units using the equations specified

in the analytical procedure. Appropriate blank corrections will be applied in all cases.

Senior laboratory staff will check the calculations.

2.6.3.2 Data Review

Each laboratory section will provide extensive data review prior to reporting results. In

general, there are three levels of data review.

The analyst will be responsible for primary review of data generated from sample

analysis. If recoveries of the quality control samples are within the method specified

tolerances then the data will be presented to data review groups for secondary review. If

recoveries of any quality control samples exceed specified tolerances, affected samples

will be re-analyzed.

Data review groups will conduct secondary review to determine if the analytical results

are acceptable. If recoveries of the quality control samples are within the method

specified tolerances then the data will be presented to laboratory project managers for

final review. If recoveries of quality control samples exceed the specified tolerances,

affected samples will be submitted for re-analysis.

Final review of analytical results will consist of the Laboratory Project Director’s

determination that the analytical results of a sample(s) are consistent. If so, the data will

be presented in a final report. If discrepancies or deficiencies exist in the analytical

results, corrective action will be taken. Audits of final reports by the Laboratory Quality

Assurance Officer may be conducted to determine the precision, accuracy,

completeness, and representativeness of sample analyses.



40

2.6.3.3 Data Reporting

Data reporting will be in accordance with the appropriate U.S. EPA method used for

analysis and will be prepared in a standard deliverable. Laboratory reports shall, at a

minimum, include the following:

1. narrative including statement of samples received, description and rationale for any deviations from approved methods/SOPs, summary of data quality, and documentation of any significant problems encountered during analysis;

2. documentation of laboratory events including dates of sample receipt,

sample extraction, and sample analysis;

3. analytical data including results, detection limits, dilutions, etc.;

4. a summary of QA/QC results and supporting documentation; and

5. a copy of the signed COC for samples submitted for analysis.

The laboratory’s QAO and/or the laboratory director should sign the laboratory reports

prior to issue. Reports will be issued to the Environmental Consultant’s QAO and PM.

Any draft reports should be clearly identified.

2.6.4 Corrective Action Corrective actions may be required for either analytical and equipment problems or

noncompliance problems. Analytical and equipment problems may occur during sampling and

sample handling, sample preparation, laboratory analysis, and data review. Noncompliance

problems are often associated with nonconformance to this plan or the U.S. EPA methods being

used.

2.6.4.1 Laboratory Corrective Action When deficiencies or "out-of-control" situations exist, the laboratory will provide a means

of detecting and correcting these situations. An "out-of-control" situation is defined as

data exceeding control limits. Samples analyzed during "out-of-control" situations will be

re-analyzed prior to reporting results. The laboratory's corrective action procedures are

documented in their QAP and method specific SOPs. In general, there are several

levels of "out-of-control" situations that may occur in the laboratory during analysis.



41

2.6.4.2 Bench Level Corrective action procedures will often be handled at the bench level. If an analyst finds

a non-linear response during calibration of an instrument, then the instrument will be

recalibrated before sample analysis. The problem may be corrected by a careful

examination of the preparation or extraction procedure, spike and calibration mixes, or

instrument sensitivity. If the problem persists, it will be brought to the management level.

2.6.4.3 Management Level If resolution at the bench level was not achieved, or a deficiency is detected after the

data has left the bench level, then corrective action becomes the responsibility of the

Laboratory Manager or Director. Unacceptable matrix or surrogate spike recoveries

detected by data review will be reported to the Laboratory Manager. A decision to re-

analyze the sample or report results will be made depending on the circumstance.

2.6.4.4 Receiving Level If discrepancies exist in either the documentation of a sample or its container, a decision

will be made after consulting with the appropriate management personnel. Decisions

will be fully documented. Some examples of container discrepancies are broken

samples, inappropriate containers, or improper preservation. In these cases, corrective

action will involve the Laboratory Project Manager contacting the Environmental

Consultant's QAO or PM.

2.6.4.5 Field Corrective Action

Corrective actions for field equipment problems will consist of reporting the problem to

the PM and/or the QAO so that maintenance can be performed or new equipment can

be acquired. Noncompliance problems will be reported immediately to the QAO. The

QAO will consult with the PM and corrective actions will be initiated. Corrective actions

may include resampling when necessary to meet the data objectives defined in the Work

Plan. The nature, extent, and corrective action for all noncompliances will be

documented.



42

2.6.5 Quality Assurance Reports to Management 2.6.5.1 Laboratory Internal Reporting

The Laboratory Quality Assurance Officer will report the status of the laboratory QA/QC

program to the laboratory management. Each report should include:

1. periodic assessment of measurement data accuracy, precision, and completeness;

2. results of audits; 3. significant QA/QC problems and recommended solutions; and 4. resolutions of previously stated problems.

The laboratory will determine the content and frequency of these reports in accordance

with its QAM or SOPs. The laboratory will report to the Environmental Consultant's QAO

or PM if the laboratory’s internal quality control issues have affected the results of the

samples.

2.6.5.2 Additional Reporting

Laboratory analytical reports will include a summary of the quality assurance activities

and quality control data for the project as related to sample analysis. The Laboratory

Project Manager will report suspected field QA/QC problems to the Environmental

Consultant's QAO. The Consultant's QAO will report to the Consultant PM when

appropriate. These reports may be either oral or written depending upon the nature and

complexity of the issues in the report.

The Consultant’s QAO will report any known issues potentially affecting the quality of the

analytical or field data to the PM. The PM is responsible for further dissemination of

these reports.

2.6.6 Data Management The raw data obtained during field activities will be recorded on the appropriate field forms or in

dedicated field notebooks. This data will become part of the project files to be maintained as

previously described in this SAPQAPP. The analytical subcontractor will maintain all raw data

for a minimum of 10 years. The analytical subcontractor will not destroy any data or records



43

without the consent of the Environmental Consultant. The procedures to be employed for data

verification, reduction, validation, and reporting are provided in Section 4 of the SAPQAPP.



44

3.0 ASSESSMENT AND OVERSIGHT

3.1 Performance and System Audits Performance and system audits of both field and laboratory activities may be conducted to verify

that sampling and analysis are performed within the constraints of this plan. These audits can

either be conducted internally by field or laboratory staff or externally by state or federal

agencies. The laboratory will participate in any performance or system audit conducted or

requested by the Environmental Consultant or the DEQ.

3.1.1 Performance Audits Performance audits may be conducted periodically to determine the accuracy of the total

measurement system(s) or components. In this program, blind performance evaluation

samples, submitted by state agencies, are analyzed and evaluated throughout the year as part

of an on-going participation in their certification programs. Any deficiencies in the results of

these analyses are reported to the laboratory and corrective action is initiated.

In addition to blind sample analyses, the laboratory will also participate in any audits from state

and federal agencies. These agencies submit a report noting any deficiencies and necessary

corrective action. The laboratory will respond with evidence of compliance within a limited time.

The laboratory also maintains a schedule of internal audits whereby the Laboratory Quality

Assurance Officer audits each section of the laboratory. When the audit is completed, a formal

report will be issued to the Laboratory Director. This report shall note any deficiencies and a

follow-up date to confirm corrective action.

3.1.2 System Audits A system audit is an evaluation of the various components of the measurement system to

assess their proper selection and use. This includes a careful evaluation of all laboratory quality

control measures. System audits will be conducted internally by the laboratory.



45

3.1.3 Field Audits The Environmental Consultant may conduct internal audits of field activities involving sampling

and measurements. These audits will include a thorough examination of field sampling records,

field instrument operating records, sample collection, shipping and handling, COC, etc. These

audits may occur at the discretion of the Project Manager, the beginning of the project, or when

new or modified sampling procedures are introduced to verify that the established procedures

are followed. Follow-up audits will be conducted to correct deficiencies, and to verify the

QA/QC procedures are being maintained throughout the project. Additionally, audits will occur

periodically throughout the monitoring period, especially when changes to sampling teams or

subcontractors are implemented. When an audit is completed a written report will be submitted

to the PM.

Consultant personnel will participate in any external audit requested by regulatory agencies.

The results and recommendations or any external audit should be reported to the Consultant's

QAO and/or PM in a timely manner so that corrective actions may be initiated.

3.2 Reports 3.2.1 Internal Reporting

Written reports of field audits will be issued to the Consultant PM. The PM is responsible for

further dissemination of these reports.

The Laboratory Quality Assurance Officer (or designees) will report the status of the laboratory

QA/QC program to the laboratory management. Each report should include:

1. periodic assessment of measurement data accuracy, precision, and completeness;

2. results of audits; 3. significant QA/QC problems and recommended solutions; and 4. resolutions of previously stated problems.

The laboratory will determine the content and frequency of these reports in accordance with its

QAP and its SOPs. The laboratory will report to the Consultant's QAO or PM if the laboratory’s

internal quality control issues have affected the results of the Consultant’s samples.



46

3.2.2 Additional Reporting

Laboratory analytical reports will include a summary of the quality assurance activities and

quality control data for the project as related to sample analysis. The Laboratory Project

Manager will report suspected field QA/QC problems to the Environmental Consultant's QAO or

PM.



47

4.0 DATA REDUCTION, VERIFICATION, VALIDATION, AND REPORTING The quality of field and analytical data must be assessed to ensure that these data are being

properly used. In order to support the conclusions of the assessment, all data must meet the

DQOs identified in Section 1.4. All data generated through field activities or by the laboratory

operation shall be reduced, verified, and validated prior to reporting. Data shall not be

disseminated until it has been subjected to these procedures, which are summarized in

subsections below.

4.1 Review of Field Data Field data reduction procedures will be minimal in scope compared to those implemented in the

laboratory setting. Only direct-read instrumentation will be employed in the field. All field data

will be written onto the field data sheets immediately after measurements are taken. If

corrections are required, the error will be legibly crossed out with a single line and the correction

will be made in a space adjacent to the original. All corrections will be initialed and dated by the

individual making the correction. Later, when the results calculation forms required for the

Semi-Annual sampling events are being filled out (i.e., corrected LNAPL thicknesses,

groundwater elevations, etc), the Field Operations Coordinator will review the forms to

determine whether any errors have been made by the field crew.

4.2 Data Validation Data verification is the process of checking the completeness, correctness, and compliance of

data with the field and analytical methods, SOPs, and this SAPQAPP. Data validation is the

process of assessing overall data quality with respect to the PARCC parameters. Data

verification and validation procedures shall be performed for both field and laboratory operations

as described below.

4.2.1 Procedures Used to Verify and Validate Field Data The PM or designee will verify all data generated during field activities. Data verification will

consist of reviewing all field data and documentation for transcription errors. Any data that is

entered into project databases, spreadsheets, drawings, etc. will be checked against the original

field measurements. Field custody records will be checked against the work plan to determine

that the appropriate samples were collected. Similarly, the custody records will be checked



48

against the analytical data generated by the laboratory to determine that all requested analyses

were complete.

Field measurements will be validated under the direction of the QAO according to the PARCC

parameters. Additionally, the analytical results of field QC samples will be evaluated to

determine that the field investigation and sampling methods employed meet the PARCC

requirements. Any identified non-compliant data will be evaluated to determine the potential

effect on overall validity and usability of the data generated. If the data is determined not

suitable for its intended purpose it will not be used and new data may be collected.

4.2.2 Procedures Used to Verify and Validate Laboratory Data The analytical subcontractor generating the data will perform initial data verification and

validation prior to reporting any analytical results. Data verification on the final analytical data

reported by the analytical subcontractor will be performed in accordance with individual methods

and the laboratory’s QA/QC program. Data verification will be performed by either the QAO,

project manager or their designee (project or senior level scientist).

Data verification and validation is the process through which proper quantification, recording,

transcription, and calculations are confirmed. It also confirms that the data is reasonable and

complete. The process should be such that errors are minimized and that corrective action

steps are taken when errors are detected. The laboratory’s data verification and validation

process includes three steps: primary, secondary, and final review.

4.2.2.1 Primary Review The analyst performs the initial review of the data. The analyst is responsible for

verifying the correctness of the data entered into the Laboratory Information

Management System (LIMS). This review includes, but is not limited to, verifying that

the quality control indicators (QCI) meet protocol criteria, calibration criteria are met,

appropriate detection limits were used, and data was reduced correctly and that any

corrective action was documented properly. The primary reviewer is responsible for

verifying any documentation associated with the data, completing review records

associated with the process, and compiling QC Reports. The analyst must perform

primary review on 100% of the data generated.



49

4.2.2.2 Secondary Review The Department Supervisor or second analyst can be responsible for a secondary

review of the data. This step is intended as a validation of the primary review.

Secondary review focuses on the calibration criteria, QCIs, compound identification,

results expression, reporting limits, and level of documentation. Approximately 10% of

the data are validated. If problems exist during this review, the data is returned, a 100%

review is done, and corrective action is performed as appropriate.

4.2.2.3 Final Review The Project Management Group prior to releasing the final report must perform final

review of the completed project. This review ensures that the client requirements have

been met and that the final report has been properly completed. The process includes,

but is not limited to, verifying that chemical relationships are evaluated, Chain-of-

Custody is completed, cover letters/ narratives are present, flags are appropriate, and

project specific requirements are met.

4.2.3 Laboratory Data Reporting After the laboratory has verified and validated the analytical data it will be reported to the

Consultant’s QAO. The laboratory reports will consist of:

1. A summary page referencing the laboratories sample number, client sample number, date collected and date received for each sample submitted.

2. Analytical results for each sample documenting the results, QC flags, units,

chronology of analytical events, reporting limits, analyst, and method references. Surrogate recoveries and other QC data (as appropriate) are also reported.

3. Definitions of quality control flags used in report. 4. Notes and comments of any identified QC problems or concerns that potentially

affect the quality of the data generated. 5. Copy of the completed chain-of-custody record.

Data will also be received electronically from the laboratory and uploaded to our database.

These data will be double checked against the hardcopy reports for accuracy. After being



50

double checked, the data will be tabulated for subsequent presentation for reporting purposes.

All finalized tables will be logged and entered into the Consultant’s database, which only

Consultant employees will have access.

The original laboratory data received by QAO will be maintained in the QA files after the review

process is completed. The QAO will give a copy of all laboratory data to the Consultant Project

Manager after review. No one shall, at any time, remove information from job files, QA files, or

the project notebook for field use or other use. If additional copies of laboratory data are

required, then arrangements will be made with the Consultant’s QAO to copy a portion of the

file. Job files, QA files, and project notebooks will be kept at the Consultant’s office for a period

of 10 years, after that they will be moved to a secure, fireproof storage facility.

4.3 Reconciliation with User Requirements Data collected during the semi-annual sampling events will be used to evaluate the current

conditions of the dissolved phase and LNAPL plumes beneath the Facility. These data will be

reconciled with the DQOs and PARCC parameters presented in Sections 1.5 of the SAPQAPP.

Specifically, these data will be qualitatively and quantitatively assessed to determine that

appropriate sample collection and analytical procedures were used. These assessments will

include:

1. determination of adherence to applicable SOPs; 2. determination that samples were collected from the proposed sample locations; 3. evaluation of detection limits, matrix interferences, and other factors potentially

biasing data; 4. evaluation of the data verification results; 5. evaluation of qualified data for environmental assessment purposes; 7. determination that the DQO procedures followed and/or refined during the

investigation; and 8 determination if there are any data gaps identified that need further evaluation.



51

5.0 REFERENCES

A variety of technical manuals, administrative documents, and publications were referred to in

preparing this document. Some of the references consulted are presented below. Referenced

documents and publications may or may not have been reviewed in their entirety. The

guidelines and procedures presented in the documents and publications referenced have not

been strictly adhered to unless stated otherwise.

U.S. EPA. Interim Guidelines and Specifications for Preparing Quality Assurance Project

Plans. EPA/600/4-83-004. February 1983.

U.S. EPA. Methods for Chemical Analysis of Water and Wastes. EPA/600/4-79-020. March 1983.

U.S. EPA. Data Quality Objectives for Remedial Response Activities: Development

Process. EPA/540/6-87/003. March 1987. U.S. EPA. Data Quality Objectives for Remedial Response Activities: Example Scenario.

EPA/540/6-87/004. March 1987. U.S. EPA. A Compendium of Superfund Field Operations Methods. EPA/540/P-87/001.

December 1987.

U.S. EPA. Quality Assurance/ Quality Control Guidance for Removal Activities. EPA/540/G-90/004. April 1990.

U.S. EPA. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846, 3rd

Edition. Updates II and III, 1998.

U.S. EPA. Quality Assurance Guidance for Conducting Brownfields Site Assessments. EPA 540-R-98-038. September 1998.

U.S. EPA. Requirements for Quality Assurance Project Plans. EPA/240/B-01/003. March 2001. U.S. EPA. Guidance for Quality Assurance Project Plans. EPA/240/R-02/009. December 2002. U.S. EPA New England Quantity Assurance Project Plan Program Guidance, April 2005.

TABLES

No. Well ID Grid Location

Primary Well Purpose No. Well ID Grid

LocationPrimary Well

Purpose1 AEP-01 H-2 POC Compliance 50 MWII-D7 G-3 Gauging Network2 AEP-03 H-1 POC Compliance 51 MWII-D7R G-3 Gauging Network3 AEP-07 G-3 POC Compliance 52 MWII-D8 F-2 Gauging Network4 AEP-08 H-3 POC Compliance 53 MWII-E5 E-4 Gauging Network5 AEP-09 H-3 POC Compliance 54 MWII-E7 G-4 Gauging Network6 AEP-10 H-2 POC Compliance 55 MWII-E8 F-4 Gauging Network7 MW-250 A-4 POC Compliance 56 MWII-SL1 E-4 Gauging Network8 MW-265 A-6 POC Compliance 57 MWII-SL2 F-4 Gauging Network9 MW-266 A-6 POC Compliance 58 MWII-SL3 F-4 Gauging Network

10 MW-267 A-5 POC Compliance 59 SOC-002 E-6 Gauging Network11 MW-268 A-4 POC Compliance 60 SOC-003 E-6 Gauging Network12 MW-269 A-3 POC Compliance 61 SOC-008 E-1 Gauging Network13 MW-270 A-2 POC Compliance 62 SOC-011 F-2 Gauging Network14 MW-271 A-2 POC Compliance 63 SOC-014 H-6 Gauging Network15 MW-272 A-1 POC Compliance 64 SOC-014 H-6 Gauging Network16 MW-273 A-1 POC Compliance 65 SOC-017 F-6 Gauging Network17 MW-274 A-1 POC Compliance 66 SOC-018 F-6 Gauging Network18 MW-275 B-1 POC Compliance 67 SOC-019 F-6 Gauging Network19 MW-276 C-1 POC Compliance 68 SOC-020 F-6 Gauging Network20 MW-277 D-1 POC Compliance 69 SR-04 E-2 Gauging Network21 MW-278 H-5 POC Compliance 70 SR-05 C-4 Gauging Network22 MW-279 H-5 POC Compliance 71 SR-06 E-3 Gauging Network23 MW-280 H-5 POC Compliance 72 SR-07 D-3 Gauging Network24 MWII-C7 F-6 POC Compliance 73 SR-08 F-4 Gauging Network25 MWII-D6 G-3 POC Compliance 74 SR-09 C-4 Gauging Network26 SOC-005 H-6 POC Compliance 75 SR-10 F-3 Gauging Network27 SOC-006 H-6 POC Compliance 76 SR-12 E-3 Gauging Network28 SOC-010 F-2 POC Compliance 77 SR-13 E-3 Gauging Network29 SOC-012 H-1 POC Compliance 78 SR-14 D-3 Gauging Network30 SOC-013 H-6 POC Compliance 79 SR-15 D-4 Gauging Network31 SOC-016 G-6 POC Compliance 80 SR-17 E-5 Gauging Network32 SOC-166a H-4 POC Compliance 81 SR-19 D-5 Gauging Network33 SOC-167 H-4 POC Compliance 82 SR-22 D-2 Gauging Network34 SX-002 B-6 POC Compliance 83 SR-23 D-2 Gauging Network35 SX-160 F-1 POC Compliance 84 SR-24 D-2 Gauging Network36 SX-161 H-4 POC Compliance 85 SR-26 H-4 Gauging Network37 SX-168 H-4 POC Compliance 86 SR-27 H-4 Gauging Network38 WTP-05 H-1 POC Compliance 87 SR-28 G-4 Gauging Network39 WTP-07 H-2 POC Compliance 88 SR-30 E-2 Gauging Network40 MWII-A4 E-6 POC Compliance 89 SR-31 E-2 Gauging Network41 MWII-A5 E-6 Gauging Network 90 SR-32 G-4 Gauging Network42 MWII-API7 F-4 Gauging Network 91 SX-003 B-6 Gauging Network43 MWII-B1 B-1 Gauging Network 92 SX-156 D-1 Gauging Network44 MWII-B2 B-2 Gauging Network 93 SX-158 D-1 Gauging Network45 MWII-B3 C-2 Gauging Network 94 SX-162 D-6 Gauging Network46 MWII-C4 E-6 Gauging Network 95 SX-163 D-6 Gauging Network47 MWII-C5 E-5 Gauging Network 96 SX-164 E-6 Gauging Network48 MWII-D4 F-3 Gauging Network 97 SX-165 C-1 Gauging Network49 MWII-D5 F-3 Gauging Network 98 TP-1 A-4 Gauging Network

a. POC well SOC-166 was identified as being destroyed during the date of SAPQAPP preparation, but will be replaced.

Summary of Facility-wide Monitoring Well Networks to be Gauged Semi-Annually

Table Continues

Holly Refining & MarketingTulsa East Refinery

SAP/QAPP

Table 1

Page 1 of 2

Summary of Facility-wide Monitoring Well Networks to be Gauged Semi-Annually


SAP/QAPP

Table 1

No. Well ID Grid Location

Primary Well Purpose No. Well ID Grid

LocationPrimary Well

Purpose99 TP-4 A-4 Gauging Network 147 TX-011 F-3 Gauging Network

100 TP-7 A-4 Gauging Network 148 TX-014 C-5 Gauging Network101 TX-002 F-4 Gauging Network 149 TX-023 E-5 Gauging Network102 TX-004 F-4 Gauging Network 150 TX-026 F-5 Gauging Network103 TX-006 E-4 Gauging Network 151 TX-031 E-4 Gauging Network104 AEP-02 H-1 Gauging Network 152 TX-033 D-5 Gauging Network105 AEP-04 G-2 Gauging Network 153 TX-040 F-4 Gauging Network106 AEP-05 G-3 Gauging Network 154 TX-047 E-2 Gauging Network107 AEP-06 G-3 Gauging Network 155 TX-053 A-3 Gauging Network108 E-27 F-4 Gauging Network 156 TX-059 D-5 Gauging Network109 MW-251 A-4 Gauging Network 157 TX-063 C-3 Gauging Network110 MW-252 A-4 Gauging Network 158 TX-065 E-3 Gauging Network111 MW-253 A-4 Gauging Network 159 TX-066 C-3 Gauging Network112 MW-254 A-4 Gauging Network 160 TX-068 E-4 Gauging Network113 MW-255 A-4 Gauging Network 161 TX-071 D-4 Gauging Network114 MW-256 A-4 Gauging Network 162 TX-073 E-2 Gauging Network115 MW-257 A-4 Gauging Network 163 TX-077 E-3 Gauging Network116 MW-258 A-4 Gauging Network 164 TX-079 F-2 Gauging Network117 MW-259 A-4 Gauging Network 165 TX-080 F-3 Gauging Network118 MW-260 A-4 Gauging Network 166 TX-082 H-4 Gauging Network119 MW-261 A-4 Gauging Network 167 TX-089 C-4 Gauging Network120 MW-262 A-4 Gauging Network 168 TX-092 E-3 Gauging Network121 MW-263 A-4 Gauging Network 169 TX-101 E-3 Gauging Network122 MW-264 A-4 Gauging Network 170 TX-102 D-5 Gauging Network123 MWAPI-1 F-4 Gauging Network 171 TX-103 E-4 Gauging Network124 MWAPI-2 F-4 Gauging Network 172 TX-105 D-3 Gauging Network125 MWAPI-3 F-4 Gauging Network 173 TX-110 D-4 Gauging Network126 MWAPI-4 F-4 Gauging Network 174 TX-127 E-3 Gauging Network127 MWAPI-5 F-4 Gauging Network 175 TX-132 C-3 Gauging Network128 MWC-1 E-6 Gauging Network 176 TX-136 C-4 Gauging Network129 MWC-2 E-6 Gauging Network 177 TX-139 F-3 Gauging Network130 MWC-3 E-6 Gauging Network 178 TX-140 F-3 Gauging Network131 MWD-1 E-3 Gauging Network 179 TX-141 F-3 Gauging Network132 MWD-2 G-3 Gauging Network 180 TX-148 F-1 Gauging Network133 MWD-3 G-2 Gauging Network 181 TX-150 F-1 Gauging Network134 MWDP-1 F-2 Gauging Network 182 TX-153 G-4 Gauging Network135 MWDP-2 F-2 Gauging Network 183 WGPZ-2 F-6 Gauging Network136 MWDP-3 G-2 Gauging Network 184 WGPZ-6 G-6 Gauging Network137 MWDP-3R G-2 Gauging Network 185 WGPZ-8 H-6 Gauging Network138 MWDP-4 G-2 Gauging Network 186 WTP-08 E-1 Gauging Network139 MWE-1 F-4 Gauging Network 187 WTP-09 F-1 Gauging Network140 MWE-2 F-4 Gauging Network 188 WTP-10 G-4 Gauging Network141 MW-F1 A-4 Gauging Network 189 WTP-11 F-4 Gauging Network142 MW-F2 A-4 Gauging Network 190 WTP-12 C-4 Gauging Network143 MWII-A1 D-6 Gauging Network 191 WTP-13 F-4 Gauging Network144 MWII-A2 D-6 Gauging Network 192 WTP-14 F-6 Gauging Network145 TX-007 E-3 Gauging Network 193 WTP-17 G-2 Gauging Network146 TX-010 E-3 Gauging Network 194 MWII-C6 F-5 Gauging Network

Page 2 of 2

No. Well ID Function Grid Location Sampling Frequency No. Well ID Function Grid Location Sampling

Frequency1 AEP-01 Downgradient H-2 Semi-Annual 1 MW-250 Upgradient A-4 Semi-Annual2 AEP-03 Downgradient H-1 Semi-Annual 2 MW-265 Upgradient A-6 Semi-Annual3 AEP-07 Downgradient G-3 Semi-Annual 3 MW-266 Upgradient A-6 Semi-Annual4 AEP-08 Downgradient H-3 Semi-Annual 4 MW-267 Upgradient A-5 Semi-Annual5 AEP-09 Downgradient H-3 Semi-Annual 5 MW-268 Upgradient A-4 Semi-Annual6 AEP-10 Downgradient H-2 Semi-Annual 6 MW-269 Upgradient A-3 Semi-Annual7 MW-250 Upgradient A-4 Semi-Annual 7 MW-270 Upgradient A-2 Semi-Annual8 MW-265 Upgradient A-6 Semi-Annual 8 MW-271 Upgradient A-2 Semi-Annual9 MW-266 Upgradient A-6 Semi-Annual 9 MW-272 Upgradient A-1 Semi-Annual

10 MW-267 Upgradient A-5 Semi-Annual 10 MW-273 Upgradient A-1 Semi-Annual11 MW-268 Upgradient A-4 Semi-Annual 11 MW-274 Upgradient A-1 Semi-Annual12 MW-269 Upgradient A-3 Semi-Annual 12 SX-002 Upgradient B-6 Semi-Annual13 MW-270 Upgradient A-2 Semi-Annual 13 MWII-C7 Interior / WGLTU Upgradient F-6 Semi-Annual14 MW-271 Upgradient A-2 Semi-Annual 14 SOC-010 Interior / FALTU Upgradient F-2 Semi-Annual15 MW-272 Upgradient A-1 Semi-Annual 15 AEP-01 Downgradient H-2 Semi-Annual16 MW-273 Upgradient A-1 Semi-Annual 16 AEP-03 Downgradient H-1 Semi-Annual17 MW-274 Upgradient A-1 Semi-Annual 17 AEP-07 Downgradient G-3 Semi-Annual18 MW-275 Crossgradient B-1 Semi-Annual 18 AEP-08 Downgradient H-3 Semi-Annual19 MW-276 Crossgradient C-1 Semi-Annual 19 AEP-09 Downgradient H-3 Semi-Annual20 MW-277 Crossgradient D-1 Semi-Annual 20 AEP-10 Downgradient H-2 Semi-Annual21 MW-278 Downgradient H-5 Semi-Annual 21 MW-278 Downgradient H-5 Semi-Annual22 MW-279 Downgradient H-5 Semi-Annual 22 MW-279 Downgradient H-5 Semi-Annual23 MW-280 Downgradient H-5 Semi-Annual 23 MW-280 Downgradient H-5 Semi-Annual24 MWII-A4 Crossgradient E-6 Semi-Annual 24 MWII-D6 Downgradient G-3 Semi-Annual25 MWII-C7 Interior / WGLTU Upgradient F-6 Semi-Annual 25 SOC-005 WGLTU Downgradient H-6 Semi-Annual26 MWII-D6 Downgradient G-3 Semi-Annual 26 SOC-006 Downgradient H-6 Semi-Annual27 SOC-005 WGLTU Downgradient H-6 Semi-Annual 27 SOC-012 Downgradient H-1 Semi-Annual28 SOC-006 Downgradient H-6 Semi-Annual 28 SOC-013 WGLTU Downgradient H-6 Semi-Annual29 SOC-010 Interior / FALTU Upgradient F-2 Semi-Annual 29 SOC-016 Downgradient G-6 Semi-Annual30 SOC-012 Downgradient H-1 Semi-Annual 30 SOC-167 Downgradient H-4 Semi-Annual31 SOC-013 WGLTU Downgradient H-6 Semi-Annual 31 SX-160 Downgradient F-1 Semi-Annual32 SOC-016 Downgradient G-6 Semi-Annual 32 SX-161 Downgradient H-4 Semi-Annual33 SOC-166a Downgradient H-4 Semi-Annual 33 SX-168 Downgradient H-4 Semi-Annual34 SOC-167 Downgradient H-4 Semi-Annual 34 WTP-05 FALTU Downgradient H-1 Semi-Annual35 SX-002 Upgradient B-6 Semi-Annual 35 WTP-07 FALTU Downgradient H-2 Semi-Annual36 SX-160 Downgradient F-1 Semi-Annual 36 SOC-166a Downgradient H-4 Semi-Annual37 SX-161 Downgradient H-4 Semi-Annual 37 MW-275 Crossgradient B-1 Semi-Annual38 SX-168 Downgradient H-4 Semi-Annual 38 MW-276 Crossgradient C-1 Semi-Annual39 WTP-05 FALTU Downgradient H-1 Semi-Annual 39 MW-277 Crossgradient D-1 Semi-Annual40 WTP-07 FALTU Downgradient H-2 Semi-Annual 40 MWII-A4 Crossgradient E-6 Semi-Annual

a. POC well SOC-166 was identified as being destroyed during the date of SAPQAPP preparation, but will be replaced.

Summary of Point of Compliance Wells, Functions and Sampling Schedule

Sorted by Well Name Sorted by Function / Sampling Frequency


SAP/QAPP

Table 2

Page 1 of 1

Summary of Analytical Methods and Chemicals of Concern

Region 5 Waste Management Branch "Skinner List"

Antimony Cadmium Lead SilverArsenic Chromium Mercury VanadiumBarium Cobalt Nickel ZincBeryllium Cyanide Selenium

Volatile Organics EPA Method 8260BBenzene 1,2-Dichloroethane Ethylene dibromide (EDB) 1,1,1-TrichloroethaneCarbon disulfide 1,1-Dichloroethane Methyl ethyl ketone (MEK) TrichloroetheneChlorobenzene 1,4-Dioxane Styrene TetrachloroethyleneChloroform Ethylbenzene Toluene Xylenes (total)

Semivolatile Organics EPA Method 8270CAcenaphthene o-Cresol Diethyl phthalate NaphthaleneAnthracene m-Cresol 2,4 Dimethylphenol 4-NitrophenolBenzo(a)anthracene p-Cresol Dimethyl phthalate PhenanthreneBenzo(b)fluroranthene Dibenz(a,h)anthracene 2,4 Dinitrophenol PhenolBenzo(k)fluoranthene Di-n-butyl phthalate Fluoranthene PyreneBenzo(a)pyrene 1,2-Dichlorobenzene* Fluorene PyridineBis(2-ethylhexyl)phthalate 1,3-Dichlorobenzene* Indeno(1,2,3-cd)pyrene QuinolineChyrysene 1,4-Dichlorobenzene* Methyl tertiary butyl ether (MTBE) *can be tested as a volatile

Optional Semivolatile Organics EPA Method 8270C1-Methylnaphthalene 2-Methylnaphthalene Indene BenzenethiolDibenz(a,h)acridine

Groundwater Quality ParametersA. EPA Method 160.1pH Temperature Specific Conductance Total Dissolved Solids

Notes:a. pH, specific conductance/conductivity, and temperature are field parameters.

Inorganics EPA Methods 6010C, 7470A and SM 4500-CN-E


SAP/QAPP

Constiuents of Concern for Wastes from Petroleum Processes

for Semi-Annual Groundwater Sampling Events

Table 3

Page 1 of 1

Inorganics U.S. EPA Method 6010BAnalyte CAS MDL PQL UnitsAluminum 7429-90-5 32.0 75 ug/LAntimony 7440-36-0 5.63 10 ug/LArsenic 7440-38-2 4.85 10 ug/LBarium 7440-39-3 1.88 10 ug/LBeryllium 7440-41-7 0.40 1.0 ug/LCadmium 7440-43-9 0.33 5.0 ug/LCalcium 7440-70-2 5.10 100 ug/LChromium 7440-47-3 0.51 5.0 ug/LCobalt 7440-48-4 0.82 5.0 ug/LCopper 7440-50-8 0.55 10 ug/LIron 7439-89-6 24.3 50 ug/LLead 7439-92-1 1.97 5.0 ug/LMagnesium 7439-95-4 8.39 50 ug/LManganese 7439-96-5 0.75 5.0 ug/LNickel 7440-02-0 1.45 5.0 ug/LPotassium 7440-09-7 88.2 500 ug/LSelenium 7782-49-2 3.84 15 ug/LSilver 7440-22-4 0.60 7.0 ug/LSodium 7440-23-5 28.0 500 ug/LThallium 7440-28-0 6.17 20 ug/LZinc 7440-66-6 1.97 50 ug/L

Inorganics U.S. EPA Method 7470Analyte CAS MDL PQL UnitsMercury 7439-97-6 0.049 0.2 ug/L

Analyte CAS MDL PQL UnitsCyanide 12408-02-5 0.1 0.1 S.U.

Inorganics Method SM 4500-CN-E Water

Summary of Analytes and Practical Quantitation Limits for Groundwater Samplesa


SAP/QAPP

Table 4

Water

Water (7470B)

Page 1 of 5



SAP/QAPP

Table 4

VOCs U.S. EPA Method 8260BAnalyte CAS MDL PQL Units1,1,1,2-Tetrachloroethane 630-20-6 0.079 1.0 ug/L1,1,1-Trichloroethane 71-55-6 0.066 1.0 ug/L1,1,2,2-Tetrachloroethane 79-34-5 0.100 1.0 ug/L1,1,2-Trichloroethane 79-00-5 0.100 1.0 ug/L1,1-Dichloroethane 75-34-3 0.076 1.0 ug/L1,1-Dichloroethene 75-35-4 0.084 1.0 ug/L1,1-Dichloropropene 563-58-6 0.052 1.0 ug/L1,2,3-Trichlorobenzene 87-61-6 0.082 1.0 ug/L1,2,3-Trichloropropane 96-18-4 0.240 2.5 ug/L1,2,4-Trichlorobenzene 120-82-1 0.130 1.0 ug/L1,2,4-Trimethylbenzene 95-63-6 0.040 1.0 ug/L1,2-Dibromo-3-chloropropane 96-12-8 0.390 2.5 ug/L1,2-Dibromoethane (EDB) 106-93-4 0.055 1.0 ug/L1,2-Dichlorobenzene 95-50-1 0.150 1.0 ug/L1,2-Dichloroethane 107-06-2 0.060 1.0 ug/L1,2-Dichloroethene (Total) 540-59-0 0.080 1.0 ug/L1,2-Dichloropropane 78-87-5 0.042 1.0 ug/L1,3,5-Trimethylbenzene 108-67-8 0.062 1.0 ug/L1,3-Dichlorobenzene 541-73-1 0.088 1.0 ug/L1,3-Dichloropropane 142-28-9 0.075 1.0 ug/L1,4-Dichlorobenzene 106-46-7 0.064 1.0 ug/L2,2-Dichloropropane 594-20-7 0.078 1.0 ug/L2-Butanone (MEK) 78-93-3 0.370 10 ug/L2-Chlorotoluene 95-49-8 0.068 1.0 ug/L2-Hexanone 591-78-6 0.230 10 ug/L4-Chlorotoluene 106-43-4 0.079 1.0 ug/L4-Methyl-2-pentanone (MIBK) 108-10-1 0.240 10 ug/LAcetone 67-64-1 1.800 10 ug/LBenzene 71-43-2 0.055 1.0 ug/LBromobenzene 108-86-1 0.066 1.0 ug/LBromochloromethane 74-97-5 0.190 1.0 ug/LBromodichloromethane 75-27-4 0.051 1.0 ug/LBromoform 75-25-2 0.250 1.0 ug/LBromomethane 74-83-9 0.130 1.0 ug/LCarbon disulfide 75-15-0 0.060 1.0 ug/L

Water

Page 2 of 5



SAP/QAPP

Table 4

VOCs U.S. EPA Method 8260B (cont'd)Analyte CAS MDL PQL UnitsCarbon tetrachloride 56-23-5 0.057 1.0 ug/LChlorobenzene 108-90-7 0.063 1.0 ug/LChloroethane 75-00-3 0.404 1.0 ug/LChloroform 67-66-3 0.150 1.0 ug/LChloromethane 74-87-3 0.130 1.0 ug/Lcis-1,2-Dichloroethene 156-59-2 0.049 1.0 ug/Lcis-1,3-Dichloropropene 10061-01-5 0.049 1.0 ug/LDibromochloromethane 124-48-1 0.056 1.0 ug/LDibromomethane 74-95-3 0.170 1.0 ug/LDichlorodifluoromethane 75-71-8 0.057 1.0 ug/LEthylbenzene 100-41-4 0.056 1.0 ug/LHexachloro-1,3-butadiene 87-68-3 0.110 1.0 ug/LIsopropylbenzene (Cumene) 98-82-8 0.051 1.0 ug/LMethylene chloride 75-09-2 0.220 1.0 ug/LMethyl-tert-butyl ether 1634-04-4 0.063 1.0 ug/LNaphthalene 91-20-3 0.081 10 ug/Ln-Butylbenzene 104-51-8 0.067 1.0 ug/Ln-Propylbenzene 103-65-1 0.150 1.0 ug/Lp-Isopropyltoluene 99-87-6 0.071 1.0 ug/Lsec-Butylbenzene 135-98-8 0.053 1.0 ug/LStyrene 100-42-5 0.050 1.0 ug/Ltert-Butylbenzene 98-06-6 0.130 1.0 ug/LTetrachloroethene 127-18-4 0.050 1.0 ug/LToluene 108-88-3 0.066 1.0 ug/Ltrans-1,2-Dichloroethene 156-60-5 0.045 1.0 ug/Ltrans-1,3-Dichloropropene 10061-02-6 0.062 1.0 ug/LTrichloroethene 79-01-6 0.073 1.0 ug/LTrichlorofluoromethane 75-69-4 0.063 1.0 ug/LVinyl chloride 75-01-4 0.099 1.0 ug/LXylene (Total) 1330-20-7 0.120 3.0 ug/L

Water

Page 3 of 5



SAP/QAPP

Table 4

SVOCs U.S. EPA Method 8270CAnalyte CAS MDL PQL Units1,2,4-Trichlorobenzene 120-82-1 0.50 10 ug/L1,2-Dichlorobenzene 95-50-1 0.50 10 ug/L1,3-Dichlorobenzene 541-73-1 0.60 10 ug/L1,4-Dichlorobenzene 106-46-7 0.40 10 ug/L2,4,5-Trichlorophenol 95-95-4 0.40 50 ug/L2,4,6-Trichlorophenol 88-06-2 5.00 10 ug/L2,4-Dichlorophenol 120-83-2 0.40 10 ug/L2,4-Dimethylphenol 105-67-9 0.40 10 ug/L2,4-Dinitrophenol 51-28-5 25.00 50 ug/L2,4-Dinitrotoluene 121-14-2 0.30 10 ug/L2,6-Dinitrotoluene 606-20-2 0.30 10 ug/L2-Chloronaphthalene 91-58-7 0.30 10 ug/L2-Chlorophenol 95-57-8 0.30 10 ug/L2-Methylnaphthalene 91-57-6 0.40 10 ug/L2-Methylphenol(o-Cresol) 95-48-7 0.30 10 ug/L2-Nitroaniline 88-74-4 0.20 50 ug/L2-Nitrophenol 88-75-5 0.20 10 ug/L3,4-Methylphenol multiple 0.50 10 ug/L3,3'-Dichlorobenzidine 91-94-1 0.60 20 ug/L3-Nitroaniline 99-09-2 0.30 50 ug/L4,6-Dinitro-2-methylphenol 534-52-1 25.00 50 ug/L4-Bromophenylphenyl ether 101-55-3 0.40 10 ug/L4-Chloro-3-methylphenol 59-50-7 0.40 20 ug/L4-Chloroaniline 106-47-8 1.90 20 ug/L4-Chlorophenylphenyl ether 7005-72-3 0.40 10 ug/L4-Nitroaniline 100-01-6 25.0 50 ug/L4-Nitrophenol 100-02-7 0.90 50 ug/LAcenaphthene 83-32-9 0.40 10 ug/LAcenaphthylene 208-96-8 0.30 10 ug/LAnthracene 120-12-7 0.30 10 ug/LBenzo(a)anthracene 56-55-3 5.00 10 ug/LBenzo(a)pyrene 50-32-8 5.00 10 ug/LBenzo(b)fluoranthene 205-99-2 0.50 10 ug/LBenzo(g,h,i)perylene 191-24-2 5.00 10 ug/L

Water

Page 4 of 5



SAP/QAPP

Table 4

SVOCs U.S. EPA Method 8270C (cont'd)Analyte CAS MDL PQL UnitsBenzo(k)fluoranthene 207-08-9 5.00 10 ug/LBenzoic acid 65-85-0 25.0 50 ug/LBenzyl alcohol 100-51-6 1.10 20 ug/Lbis(2-Chloroethoxy)methane 111-91-1 0.30 10 ug/Lbis(2-Chloroethyl) ether 111-44-4 0.30 10 ug/Lbis(2-Chloroisopropyl) ether 39638-32-9 0.40 10 ug/Lbis(2-Ethylhexyl)phthalate 117-81-7 1.00 10 ug/LButylbenzylphthalate 85-68-7 5.00 10 ug/LChrysene 218-01-9 0.30 10 ug/LDibenz(a,h)anthracene 53-70-3 5.00 10 ug/LDibenzofuran 132-64-9 0.40 10 ug/LDiethylphthalate 84-66-2 5.00 10 ug/LDimethylphthalate 131-11-3 5.00 10 ug/LDi-n-butylphthalate 84-74-2 5.00 10 ug/LDi-n-octylphthalate 117-84-0 5.00 10 ug/LFluoranthene 206-44-0 5.00 10 ug/LFluorene 86-73-7 0.20 10 ug/LHexachloro-1,3-butadiene 87-68-3 0.60 10 ug/LHexachlorobenzene 118-74-1 0.20 10 ug/LHexachlorocyclopentadiene 77-47-4 0.30 10 ug/LHexachloroethane 67-72-1 0.60 10 ug/LIndeno(1,2,3-cd)pyrene 193-39-5 5.00 10 ug/LIsophorone 78-59-1 0.20 10 ug/LNaphthalene 91-20-3 0.40 10 ug/LNitrobenzene 98-95-3 0.40 10 ug/LN-Nitrosodimethylamine 62-75-9 0.50 10 ug/LN-Nitroso-di-n-propylamine 621-64-7 0.30 10 ug/LN-Nitrosodiphenylamine 86-30-6 0.30 10 ug/LPentachlorophenol 87-86-5 25.0 50 ug/LPhenanthrene 85-01-8 0.30 10 ug/LPhenol 108-95-2 0.30 10 ug/LPyrene 129-00-0 0.30 10 ug/L

a. Please refer to laboratory SOPs for additional information.b. Groundwater samples collected from wells with high concentrations of target COCs will have elevated reporting limits due to sample dilution. The reporting limits for samples requiring dilutions will be dependent upon analyte concentrations within the samples.

Water

Page 5 of 5

QUALITY CONTROL SAMPLES FREQUENCY OF SAMPLES

Field Sample DuplicatesTypically one duplicate sample for every 20 or fewer investigative samples, with at least one duplicate per day of sampling.

Matrix Spike/Matrix Spike DuplicateTypically one MS/MSD for every 20 or fewer groundwater samples, with at least one MS/MSD per day of sampling.

Field (Equipment Rinsate) Blank

Typically one field blank for every 20 or fewer investigative samples, with at least one field blank per day of sampling. Field blanks will only be collected when non-dedicated equipment is used.

Trip Blanks One blank per sample shipment of VOC sample vials (i.e. one blank per cooler).

Initial Calibration Sample analysis cannot proceed without a valid initial calibration.

Continued Calibration ChecksEvery 12 hours or 20 samples, which ever is sooner.Recalibrate as required by the method.

Laboratory Control Samples including Method Blanks and Blank Spikes

Every 12 hours or 20 samples, which ever is sooner.Recalibrate as required by the method.

Tune Standard One per batch.

Laboratory Control Spikes/Spike Duplicates Every 20 samples.

Surrogates A minimum of three surrogates at retention times across the GC run.

Internal Standards A minimum of three standards at retention times across the GC run.

Laboratory Samples


SAP/QAPP

Table 5

Field and Laboratory Quality Control Frequencies

Field Samples

Page 1 of 1

Parameter Analytical Method Bottle Type Preservation Holding Time2

Region 5 Skinner ListVolatile Organics (VOCs)

U.S. EPA Method 8260 (3) 40 ml glass vials HCL to pH<2Cool to 4oC

14 days

Region 5 Skinner ListSemivolatile Organics (SVOCs)

U.S. EPA Method 8270 (2) 1000 ml glass bottle (amber) Cool to 4oC 7 days Pre-Extraction40 days Post-Extraction

Region 5 Skinner List Inorganics (Metals3)

U.S. EPA Method 6010

Mercury U.S. EPA Method 7470

Cyanide Method SM 4500-CN-E (1) 500 ml plastic bottle NaOH to pH>12Cool to 4oC

14 days

Notes:1. These are typical containers; containers may vary, and containers may be combined during the sampling process.2. All holding times are measured from date of collection.3. Metals for POC wells include: antimony, arsenic, barium, beryllium,cadmuim, chromium, cobalt, copper, lead, mercury, nickel, selenium, silver, thallium, vanadium, and zinc.4. Holding time for Mercury is 28 days. Holding time for hexavalent chromium is 24 hours for water samples.


SAP/QAPP

(1) 500 ml plastic bottle (one bottle for both analyses 6010 and 7470)

HNO3 to pH<2Cool to 4oC 180 days4

Table 6

Summary of Sample Containers, Preservation Methods and Holding Times1.

WATER

Page 1 of 1

INSTRUMENTS.MAINTENANCE

PROCEDURES/SCHEDULE SPARE PARTS IN STOCK

MiniRae 2000 1. Calibrate beginning and end of each day andas necessary during use.

1. Battery charger

Photoionization Detector (or similar)

2. Check battery, and recharge when low. 2. Spare filter cartridges

3. Clean lamp window every 24 hours ofoperation.

3. Calibration Gas

4. Replace water traps if they become wet.

Thermo Environmental Model 580B

1. Calibrate beginning and end of each day, andas necessary during use.

1. Battery Charger

Photoionization Detector2. Check battery, and recharge when low. 2. Spare dust filters.

3. Clean lamp and dust filter as needed. 3. Calibration Gas


Vrae or MSA 4 gas monitors


1. Battery Charger

(or similar)2. Check battery, and recharge when low. 2. Spare Batteries

3. Clean lamp and dust filter as needed. 3. Spare moisture filters.


YSI 6-Seires Sonde or Equivalent


1. Battery charger

with flow through cell

2. Check probes/membranes daily for wear ordamage.

2. Calibration Solutions

3. Replace probes/membranes as needed. 3. Clean flow through cell as needed.

3. Replace batteries as needed.

LaMotte, 1. Calibrate beginning and end of each day, andas necessary during use.

1. Spare Batteries

Aqualitic, 2. Clean/wipe optics chamber with optical lenscleaning cloths

2. Calibration Standards

Hach Turbidimeters 3. Spare Test Vial

or similarSolinist or Heron 1. Check probe function before use. 1. Spare Batteries.

Water Level Indicators and Interface Probes

2. Service as needed. 2. Calibration Solutions

Table 7

Preventative Maintenance for Field Instruments


SAP/QAPP

Page 1 of 1

PARAMETER INSTRUMENTS PRECISION a. ACCURACY b. COMPLETENESS

Immiscible Layer Detection and Measurement

Heron or Solinist Interface Probe (or similar)

+/- 0.01 ft. +/- 0.005 ft. 95%

Standing Water LevelsHeron or Solinist Water Level

Indicator (or similar)

+/- 0.01 ft. +/- 0.005 ft. 95%

Temperature

Multi-parameter water quality sonde such as YSI, In-situ or

QED

+/- 0.5o C. +/- 0.15o C. 95%

Conductivity


QED

+ 0.001 to 0.1 mS/cm (range dependent)

+ 0.5% of reading+0.0001 mS/cm

95%

pH


QED

+/- 0.2 pH units +/- 0.2 pH units 95%

Redox Potential


QED

+/- 10 mV +/-20 mV 95%

Dissolved Oxygen


QED

+/- 0.01 mg/L +/- 2% of readings for 0.2 mg/L which ever is greater

for 0-20 mg/L range

/ 6% f di f 20 50

95%

TurbidityLaMotte, Aqualitic or Hach Field

Turbidimeter

+ 1% of reading or 0.01 ntu, which ever is greater

+ 2% of readings plus any stray light from 0-1000 ntu

95%

NOTES: a. Expressed as the acceptable deviation from the Scale.b. Expected based on equipment manufacturer specifications.

QA Objectives for Field Measurements


SAP/QAPP

Table 8

Page 1 of 1

INSTRUMENT ACTIVITY FREQUENCY

Gas Chromatograph/Mass Spectrometer Replace pump oil Monthly/as needed

Change septa As needed Change gas line dryers When pressure reaches 100 psiClean source Semi-annually/as needed Replace electron multiplier As needed/poor sensitivity Injector port cleaning As needed/poor sensitivity Leak check septum As needed/when leak suspectedCheck gas flow As needed Clean VOA purge glassware As needed Cut capillary column As needed Replace liner As needed/contamination suspected

Gas Chromatograph Change septa As neededClean gas line dryers As neededChange syringes on autosamplers As neededLeak check When installing columnsInjection port cleaning As neededCheck inlet system for buildup Periodically

Purge and Trap Sample Replace trap As neededConcentrator Decontaminate system As required by blank analysis

Check system for leaks As needed

Graphite Furnace Atomic Adsorption Spectrometer Change graphite contact rings As needed

Clean quartz windows As neededChange tubes As needed

Inductively Coupled Plasma Spectrometer Change sample rinse lines As needed

Clean nebulizer components As neededClean torch assembly As neededClean filters As neededClean Mirrors As needed

Inductively Coupled Mass Spectrometer Change pump tubing As needed

Clean nebulizer components As neededClean torch assembly As neededClean sampler and skimmer cones As neededChange roughing pump oil As needed

pH/Conductivity Meter Clean electrodes As neededFill electrodes As needed

Preventative Maintenance for Analytical Instruments


SAP/QAPP

Table 9

Page 1 of 1

FIGURES

HRM004_07_Fig01_SiteLocMap.mxd


Holly TulsaEast Refinery



0 1,000 2,000500Feet



Oklahoma1:24,000

Site Location and Topographic Features


SAP/QAPP for Semi-Annual Groundwater Sampling


October 2011

1Figure

Date:

File Name:

Source: The topographic map was acquired through the USGSTopographic Map web service. Topo quadrangle date not provided.

The aerial photo in the inset was acquired from the Indian Nations Councilof Governments (INCOG). Aerial photography dated March 2008.

LegendApproximate Site Boundaries

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

MWDP-3MWDP-1

MWDP-2

MWII-E7

MWII-E8

MWII-E5

MWII-D4

MWII-D7

MWII-D8

MWII-SL3

MWII-SL2

MWII-SL1

MWII-API7

MWII-API6

WGPZ-8

WGPZ-5

WGPZ-6WGPZ-2

TP-8

TP-1TP-7 TP-4

E-27

MWC-2

MWC-1

SR-15

MWD-1SR-14

SR-17

MWE-2

MWE-1

SR-10

MWD-2

SR-22

SR-23

SR-05

MW-263

MW-262

MW-261

MW-260

MW-259

MW-257

MW-252

AEP-05

AEP-02

WTP-10

WTP-11

TX-110

TX-102

TX-033

TX-023

TX-031

TX-068

TX-101

WTP-14

WGL-15

TX-059

TX-067

TX-071

TX-103

TX-065

TX-077

TX-006

TX-047

TX-007

TX-010

TX-127

TX-004

TX-011

TX-140

WTP-13TX-040

TX-153

TX-150

WTP-08

WTP-09

TX-148

WTP-17

TX-080

TX-141

TX-082

TX-026

TX-092

TX-100

SX-156

TX-132

TX-063

MWDP-4

TX-064

TX-089

WTP-12

SX-162

SX-163

SX-164

SX-165

SOC-011

SOC-008

SOC-014

SOC-003SOC-020

SOC-002

MWAPI-2

MWII-B3

MWII-B2

MWII-A1

MWII-C5

MWII-D5

SOC-014B

MW-264

MW-258

MW-256

MW-255MW-254

MW-253

MW-251

AEP-06

AEP-04

TX-002

TX-139

TX-066

TX-136

MWDP-3R

SOC-019SOC-018

SOC-017

MWAPI-1

MWAPI-3

MWAPI-5

MWAPI-4

MWII-C4

SR-26

SR-27

SR-28

SR-08

SR-31

SR-30

SR-07

SR-19

SR-02

SR-09

SR-01SR-12

SR-13

SR-06

MWD-3

SR-04

SR-24

TX-105

TX-073

TX-079

SX-154

TX-014

MWII-D7R

SR-32

SR-29

MW-F2

MWC-3

SR-21

SX-003

WTP-06

WTP-01

WTP-02

SX-155

SOC-015

SOC-009

SOC-004

SOC-001

MWII-B4

MWII-A2

MWII-A3

MWII-C8

A-2

A-1 SR-03

SR-20

WGPZ-1

WGL-16

WTP-04

TX-104

TX-137

SOC-007

MWII-A5

MWII-C6

MW-F1

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013

SOC-016

SOC-167

SOC-166

SOC-012MWII-B1

MWII-A4

MWII-D6

MWII-C7

MW-277MW-276

MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-278

MW-279

MW-280Slurry Wall

Arkansas R

iver

AEPProperty





Point of Compliance Wells

Destroyed Well



Figure




File Name: HRM004_07_Fig02_FacilityMap.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200


2


(Tulsa East Refinery)SAP/QAPP for Semi-Annual Groundwater Sampling

FacilityBase Map

6

5

4

3

2

1 1

2

3

4

5

6

A B C D E F G H

A B C D E F G H

Flare Area LTU

Walnut Grove LTU

SWMU-C

AOC2

SWMU-D

SWMU-G

SWMU-H

SWMU-B

SWMU-E

SWMU-A

AOC1

SWMU-E

SWMU-F

SWMU-ESWMU-E

Slurry Wall

Arkansas R

iver

AEPProperty

MWDP-3MWDP-1

MWDP-2

MWII-E7

MWII-E8

MWII-E5

MWII-D4

MWII-D7

MWII-D8

MWII-SL3

MWII-SL2

MWII-SL1

MWII-API7

MWII-API6

WGPZ-8

WGPZ-5

WGPZ-6WGPZ-2

TP-8

TP-1TP-7 TP-4

E-27

MWC-2MWC-1

SR-15

MWD-1SR-14

SR-17

MWE-2

MWE-1

SR-10

MWD-2

SR-22

SR-23

SR-05

MW-263

MW-262

MW-261

MW-260

MW-259

MW-257

MW-252

AEP-05

AEP-02

WTP-10

WTP-11

TX-110

TX-102

TX-033

TX-023

TX-031

TX-068

TX-101

WTP-14

WGL-15

TX-059

TX-067

TX-071

TX-103

TX-065

TX-077

TX-006

TX-047

TX-007

TX-010

TX-127

TX-004

TX-011

TX-140

WTP-13TX-040

TX-153

TX-150

WTP-08

WTP-09

TX-148

WTP-17

TX-080

TX-141

TX-082

TX-026

TX-092

TX-100

SX-156

TX-132

TX-063

MWDP-4

TX-064

TX-089

WTP-12

SX-162

SX-163

SX-164

SX-165

SOC-011

SOC-008

SOC-014

SOC-003SOC-020

SOC-002

MWAPI-2

MWII-B3

MWII-B2

MWII-A1

MWII-C5

MWII-D5

SOC-014B

MW-264

MW-258

MW-256MW-255MW-254

MW-253

MW-251

AEP-06

AEP-04

TX-002

TX-139

TX-066

TX-136

MWDP-3R

SOC-019SOC-018

SOC-017

MWAPI-1

MWAPI-3

MWAPI-5

MWAPI-4

MWII-C4

SR-29

MW-F2

MWC-3

SR-21

SX-003

WTP-06

WTP-01

WTP-02

SX-155

SOC-015

SOC-009

SOC-004

SOC-001

MWII-B4

MWII-A2

MWII-A3

MWII-C8

A-2

A-1 SR-03

SR-20

WGPZ-1

WGL-16

WTP-04

TX-104

TX-137

SOC-007

MWII-A5

MWII-C6

MW-F1

MW-250

AEP-07

AEP-08

AEP-10

AEP-09

AEP-01

AEP-03

SX-160

SX-161

SX-168

SX-002

WTP-05

WTP-07

SX-158

TX-053

SOC-010

SOC-006

SOC-005

SOC-013

SOC-016

SOC-167

SOC-166

SOC-012MWII-B1

MWII-A4

MWII-D6

MWII-C7

MW-277MW-276

MW-275MW-274

MW-273

MW-272

MW-271

MW-270

MW-269

MW-268

MW-267

MW-266

MW-265

MW-278

MW-279

MW-280

SR-26

SR-27

SR-28

SR-08

SR-31

SR-30

SR-07

SR-19

SR-02

SR-09

SR-01SR-12

SR-13

SR-06

MWD-3

SR-04

SR-24

TX-105

TX-073

TX-079

SX-154

TX-014

MWII-D7R

SR-32





Point of Compliance Wells

Destroyed Well



Figure




File Name: HRM004_07_Fig03_LNAPLRec.mxdGeodatabase: HRM012.mdb

0 300 600150

Feet

1:7,200


3


(Tulsa East Refinery)SAP/QAPP for Semi-Annual Groundwater Sampling

LNAPL RecoverySystems

APPENDIX A

Consultant Standard Operating Procedures

SOP INDEX F1000-99rev Decontamination of Field Equipment F1013-01rev Packaging and Shipping of Non-Hazardous Samples F2024-99rev Procedures for Proper Containment/Storage of Used Drilling Fluids, and

Purged Groundwater Investigative - Derived Solid and Selected Excavated Materials

F3008-07rev Groundwater Sample Collection F3014-02rev Chain-of-Custody Procedures F3028-11 Procedure for the Sampling of Investigative Derived Wastes for Waste Characterization

HULL & ASSOCIATES, INC. F1000-99REV.SOPSTANDARD OPERATING PROCEDURE PAGE 1 OF 4

This document is property of Hull & Associates, Inc. and is intended solely for internal use by Hull & Associates, Inc.employees or their agents. Any dissemination, distribution or unauthorized use of this SOP is strictly prohibited.

SOP No. F1000 (1999rev)DECONTAMINATION OF FIELD EQUIPMENT

1.0 Purpose

This SOP describes the minimum procedures that will be followed when decontaminating fieldequipment. The equipment may include split spoon soil samplers, bailers, trowels, shovels, hand augers,drilling rigs, or any other type of reusable equipment used during field investigations.

Decontamination will be performed as a both a quality assurance measure and as a safety precaution.Specifically, the purpose for these decontamination procedures is to minimize the potential for crosscontamination between sampling locations and prevent potentially contaminated materials from beingtransported off-site.

2.0 Equipment and Materials

Equipment and materials required for decontamination of field equipment may include, but will notnecessarily be limited to:

- high-pressure steam cleaner;- cleaning fluids: non-phosphatic soap and/or detergents, potable water, distilled/deionized water;- shovels and brushes;- paper towels;- disposable gloves;- waste storage containers: plastic bags, drums, boxes;- cleaning containers: plastic buckets, etc.;- plastic sheeting; and- personal protective equipment.

3.0 General

A. All decontamination will be performed under the assumption that the equipment is contaminated. At a minimum, clean, unused vinyl or latex gloves will be worn during all decontaminationactivities. Additional personal protective equipment will be worn as required.

B. An adequate supply of all decontamination equipment and materials will be available on site.

C. All equipment will be decontaminated before leaving the site.

D. Decontamination of vehicles or large equipment will generally be conducted in a designated area. Smaller equipment may be decontaminated at the sampling location.

E. All decontamination materials that cannot be re-used will be properly packaged for disposal basedon the nature of contamination.

4.0 Procedures



The following sections present the minimum procedures that will be used to decontaminate fieldequipment If different or more extensive procedures are required, they will be pre-approved by theProject Manager and Quality Assurance Officer.

4.1 Drilling Rig and Associated Equipment

A. All equipment coming in contact with potential contamination, both as part ofsubsurface equipment advancement and aboveground contact with drilling fluids,extracted soils, ground water, drill rig lubricants and fuels, etc., will be decontaminatedprior to use. At the discretion of the Project Manager, decontamination of the entiredrilling rig may be required due to the adherence of foreign substances as a result ofoperations, transportation from off-site, or travel between soil boring locations.

B. A high-pressure steam cleaner will be used to clean the inside and outside of drillingequipment that will not come into contact with test samples. Decontamination ofsampling equipment (e.g., split-spoon samplers) is described in section 4.2.

C. All liquid and solid material produced from this operation will be collected and properlycontained until such time as it can be properly disposed of.

D. The date, time, and decontamination procedure used will be recorded on the boring log,daily field report or in a field notebook.

4.2 Sampling Equipment (split spoons, trowels, etc.)

Sampling equipment will be decontaminated between sample locations and sample intervals tominimize the potential for cross-contamination.

A. The sampler will be completely disassembled and any adhered soil will be removed.

B. The sampler will be placed in a bucket containing a non-phosphatic soap and water (e.g., Liquinox™) and scrubbed until visibly clean. The soap and water will bechanged as necessary.

C. The sampler will then be thoroughly rinsed with potable water until all soap solution isremoved. All rinse water will be collected and containerized.

D. The sampler will be reassembled and given a final rinse with distilled/deionized water.

E. If the sampler is not to be used immediately it must be stored in a location or mannerthat will prevent it from becoming re-contaminated.

4.3 Ground-water Pumps

This procedure will be employed to decontaminate the non-dedicated pumps that are used duringwell purging, development, and sampling operations.

A. Any dedicated tubing that was used with the pump will be removed and properlydiscarded.



B. All exterior surfaces will be wiped with clean paper towels and any extraneous materialswill be removed using a stiff brush.

C. The pump and all associated downhole equipment will be placed in a suitably sizedcontainer of non-phosphatic soap (e.g., Liquinox™) and potable water. If the tubingon the pump is to be re-used, the pump will be turned on to circulate the solutionthrough the pump and tubing.

D. The pump will then be thoroughly rinsed with potable water. If the tubing on the pumpis to be reused then the pump will be turned on until the internal portions of the pumpand tubing are free of cleaning solution. The last rinse applied to the pump system willalways be distilled water.

F. The pump and associated downhole equipment will be properly stored to ensure thatthe system remains clean during transportation to other well heads. The pump will notbe allowed to come in contact with the ground at any time during handling andtransportation. If this occurs, the pump and associated downhole equipment will be re-cleaned.

G. All liquids and waste materials produced during this operation will be properly storedand disposed of as determined by the Project Manager.

4.4 Bailers

This section documents the procedures that will be followed to decontaminate non-dedicatedbailers used for purging or sampling ground water.

A. The bailer will be scrubbed with non-phosphatic soap and water solution. The insideof the bailer will be scrubbed with a cylinder brush to ensure that interior walls arethoroughly cleaned.

B. The bailer will be rinsed with potable water until it is free of the soap solution. A finalrinse of distilled water will then be applied.

C. The bailer will be properly stored if it is not to be immediately used. To properly storethe bailer, the entire bailer will be placed in its dedicated storage tube or wrapped ininert material (e.g., Saran wrap, aluminum foil, etc.).

D. All liquids and waste materials produced during this operation will be properly storedand disposed of as determined by the Project Manager

4.5 Well Casing and Screen Pre-Installation Decontamination Procedures

This section documents the procedures that will be followed to decontaminate well constructionmaterials prior to installation. The following procedures apply to both PVC and Type 304stainless steel casing and screen materials.

A. All personnel handling the well materials must wear clean and unused vinyl or latexgloves.



B. The well casing and screen will be removed from the packaging. The well materialswill be placed on clean sawhorses or equivalent support device. The well materials will be washed with a clean stiff brush and a non-phosphatic soap and water solution (e.g.,Liquinox™).

C. The well materials will then be rinsed with potable water.

D. A high pressure steam cleaner may then be used to thoroughly remove any remainingsoap or soiled areas.

E. The final step will be to rinse the well materials with distilled water. The well materialswill remain on the saw horses until well construction commences.

4.6 Interface Probe and Water Level Indicator

The entire length of the probe and tape that was inserted into the well will be decontaminatedby washing with a non-phosphate detergent (e.g., Liquinox™) and then rinsing with distilledwater.

5.0 Documentation

The procedure(s) employed, date(s), and time(s) will be recorded on the appropriate documentation (e.g.,daily field reports, field notebooks, boring logs, etc.). Any deviation from these procedures must benoted. Deviations must be approved by the Project Manager and Quality Assurance Officer.

6.0 Special Notes

None


This document is property of Hull & Associates, Inc. and is intended solely for internal use by Hull &Associates, Inc. employees or their agents. Any dissemination, distribution or unauthorized use ofthis SOP is strictly prohibited.

SOP No. F1013 (2001-REV)PACKAGING AND SHIPPING OF NON-HAZARDOUS SAMPLES

1.0 Purpose

The purpose of this SOP is to describe the procedures that shall be used to package andship all non-hazardous samples. These procedures are the recommended handlingprocedures for all sample shipments to minimize the loss of samples associated withbreakage and/or being received above the method required temperature. Theserequirements are mandatory for all samples being transported by non-project personnel.Project personnel include all HAI employees as well as personnel directly employed bythe analytical subcontractor. Third-party courier services, regardless of whethercontracted internally or by the analytical laboratory, are always considered non-projectpersonnel. Strict adherence to these procedures shall help ensure sample integrity even ifdelivery is delayed.


- duct tape- clear packing tape- custody seals- zip-loc (or equivalent) bags, various sizes- packing material (styrofoam peanuts, bubble wrap, etc.)- mailing label (in addition to any shipping papers)

3.0 Procedures

The following procedures shall be adhered to for packaging and shipping of all non-hazardous samples. If any materials are known or suspected to be hazardous, they shallbe packaged and shipped in accordance HAI SOP No. F1014.

A. Coolers

Coolers are the most common package or containment device used to ship samples.Coolers are also used during sampling efforts to store and transport samples prior toshipping. It is very important that samples be placed in an iced cooler immediatelyafter collection. The ice in the cooler used for shipping will last much longer if thesample containers placed into it have been pre-chilled. The following procedures shallbe used when packing the cooler for shipment:

1. Secure the drain on the cooler with packing tape or duct tape to preventaccidental opening.

2. Place each individual sample (soil and/or groundwater) in a Ziploc bag. VOAvials that are aliquots from the same sample can be placed in the same bag. It isrecommended that the VOA vials be wrapped with bubble wrap or paper towel toprevent excessive contact during shipping.



3. Place the samples into the cooler. Situate the sample containers so that they donot touch each other. This is very important for aqueous samples in glasscontainers as they are more prone to break.

4. Use plastic bubble wrap or styrofoam peanuts as packing or filler material toprevent the samples from colliding and breaking during transportation. Do notuse shredded paper because if the paper becomes wet it will no longer be usefulto prevent samples from colliding. Only a minimum amount of packing materialshould be used as these materials insulate the samples and prevent them frombeing properly chilled. Plastic sample containers can be placed between glasscontainers. Bags of ice may be also be used as packaging material betweensamples. Sample containers should be snug and not easily moved with in thecooler.

5. Fill the cooler with ice. Ice must be double-bagged in Ziploc bags. Forty to fiftypercent of the cooler capacity should contain ice in order to keep the samplescold during transport. If a commercial carrier such as FedEx or UPS is shippingthe samples it is best to use more ice in case delivery is delayed. Less ice may beused if the samples will be delivered by hand. As a rule of thumb, an averagecooler with a capacity of approximately 48 quarts will require two to three - eightpound bags of ice.

6. Temperature blanks shall be placed at the top of the cooler directly under the ice.

7. Place the chain-of-custody (COC) record in a Ziploc bag and tape it to theunderside of lid of the cooler. If samples are packed in multiple coolers, thenumber of coolers should be marked on the COC record and a photocopy of theCOC shall be placed in each cooler.

8. Tape the cooler shut to prevent accidental opening or potential leakage. Tapeshall be placed around the entire perimeter of the lid and then around the body ofcooler in two or three places. Do not tape down or otherwise restrict access tothe cooler handles. Coolers used for shipping should not have any broken ormissing handles.

9. Custody seals shall then be placed on the cooler to document the integrity of theshipping container. A minimum of two custody seals shall be placed on eachcooler in a manner that the cooler cannot be opened with out breaking the seal.Each custody seal shall be signed and dated by the person packing the cooler andthe seals shall covered by clear packing tape to prevent accidental loss or damageduring shipping.

10. Affix a mailing label with the laboratory’s address on the cooler. Apply cleartape over the address label to prevent accidental loss or damage during shipping.This label is required in addition to any shipping papers required by carriers.



B. BoxesSome samples do not require temperature control and may be shipped in boxes. Theboxes should be sturdy enough to withstand rough handling. No liquids shall ever beshipped by box. Materials suitable to be shipped by box include:

1. Air samples in summa canisters or airtight gas sampling bags or other non-pressurized sample containers.

2. Bulk asbestos samples.

3. Soil samples for geotechnical analyses.

These materials may be securely packed in a suitable box. The box shall be sealed withpacking tape and affixed with address labels and custody seals as described above.

4.0 Documentation

A copy of any applicable shipping papers shall be retained for future reference. Anypertinent shipping information should be recorded on the Daily Field Report or in thefield notebook for the project.

5.0 Special Notes

None

6.0 References

None

HULL & ASSOCIATES, INC. F2024-11REV.SOP STANDARD OPERATING PROCEDURE PAGE 1 OF 5 This document is property of Hull & Associates, Inc. and is intended solely for internal use by Hull & Associates, Inc. employees or their agents. Any dissemination, distribution or unauthorized use of this SOP is strictly prohibited.

SOP No. F2024 (2011rev) PROCEDURE FOR PROPER CONTAINMENT/STORAGE OF USED DRILLING FLUIDS, DECON. FLUIDS, PURGED GROUND WATER, INVESTIGATION-DERIVED

SOLIDS, AND SELECTED EXCAVATED MATERIALS 1.0 Purpose

This SOP documents the procedures to properly contain or store drilling fluids that are recirculated from a borehole, extracted from a monitoring well, or generated during decontamination activities. Also, this SOP documents the procedures to be followed to properly contain auger cuttings, unused soil samples or soils excavated in areas of known or suspected contamination.


- Five-gallon buckets - Thirty-gallon trash can - Portable water tank (of appropriate size) - DOT- approved, closed-top, 55-gallon steel drum, Type 17E - DOT-approved 55-gallon steel drums with locking open-top lids, Type 17H - Roll-off Box - Paint pen or permanent marker (indelible) - Shovel - Hand tools including hammer, bung wrench and ratchet equipped wth15/16” socket - Visqueen - Straw bales - Stakes or concrete blocks - Drum funnel

3.0 General

A. Management of Purge Water, Drilling Fluids, and Decontamination Fluids

1.0 Monitoring Wells/Extraction Wells Purge Water -Groundwater extracted from a monitoring well/extraction well and not used for laboratory analysis must be temporarily stored in a DOT-approved fifty-five gallon steel drum with a closed top unless otherwise directed by the Project Manager. As directed by the Project Manager, drums containing volatile free products should be fitted with bung caps capable of venting the vapors and grounded (if necessary). The drum shall be marked with the date of generation, the identification of the well the water was purged from, and the words "Purge Water." Purge water shall never be disposed of on the ground, into a sewer, or into a nearby stream unless permission has been granted from the appropriate regulatory agency. Purged groundwater may be processed on-Site if a groundwater treatment system is present.

2.0 Drilling Fluids - Water that is introduced to a boring by the drill rig to aid in

the drilling procedure shall not be recirculated back through the boring


unless approved by the Project Manager. If water must be contained for disposal, the fluids shall be directed from the augers, casing or rods into a portable storage tank or tub via an overflow adapter. The contents of the portable tank shall be disposed as directed by the Project Manager.

3.0 Aquifer Test Purge Water - Water that is removed from the aquifer during a

long duration pumping or step-drawdown aquifer test shall be disposed of as directed by the Project Manager.

Water extracted from a monitoring well to determine in-situ aquifer characteristics shall be stored in a portable container, or DOT approved drums near the well and disposed as directed by the Project Manager. The portable container shall be marked with the date of generation and the identification of the test well that water was extracted from.

4.0 Decontamination Fluids - Any fluids generated from decontamination

procedures shall be stored in DOT-approved fifty-five gallon steel drums with a closed top, unless a Site-specific decontamination plan has other directives. The date of generation and the words "Decon Fluids" will be clearly marked on the drum.

B. Management of Drill Cuttings and Excavated Materials

1.0 Auger Cuttings - Soil produced from drilling operations (e.g., auger cuttings,

unused samples) that is not saved for physical or chemical analysis shall be containerized on-site in DOT approved 55-gallon drums, containerized in lined roll-off boxes or stockpiled on and covered with Visqueen, that is secured to keep the cover in-place, consistent with the procedures described in Section 4.0.

Excavated Soils – On-Site management of soil excavated from areas of known or suspected contamination will be stockpiled on and covered with visqueen that is secured to keep the cover in-place or containerized in lined roll-off boxes, consistent with the procedures described in Section 4.0

4.0 Procedures

A. Drum Storage - Drums used to containerize auger cuttings, drilling fluids, purge water, decontamination water, etc. shall be clean DOT-approved 55-gallon steel drums with closed tops or locking open-top lids.

Auger cuttings and fluids, etc. shall be placed in drums as soon as possible to avoid contaminating the ground surface near the boring. Each drum shall be clearly labeled to identify the date of generation and the boring or well the material originated. If multiple drums are needed for a particular boring, they shall be consecutively numbered as they are generated. An example of proper drum labeling is as follows:


8/6/11 8/6/11 SB5-001 MW5-001 (Soil Boring 5 - Drum No. 001) Monitoring Well 5 – Drum No.001

Project Number Project Number Auger Cuttings Purge Water

Drums may also be labeled with a self-adhesive label, which may include the following information:

Generator's Name and Address Site Number Date Soil Boring/Monitoring Well Number(s) Contents

Soil from different soil boring locations shall not be mixed unless otherwise directed by the Project Manager. After the drums of soil are properly labeled and secured with a tight fitting lid, drums will be moved to a drum staging area. The location of the drum staging area shall be coordinated with the site owner/operator and Project Manager. The location selected should be away from traffic patterns, but accessible for future pick-up.

B. Stockpiling - Excavated soils shall be stockpiled consistent with Figure F2024-1.

Mixing auger cuttings from different locations shall be verified with the Project Manager and the location of the stockpile shall be coordinated with the site owner/operator. Prior to selecting a location, the volume of soil to be stockpiled will be estimated to determine the space requirements for stockpiling. The location selected should be away from traffic patterns, but accessible for future pick-up. It may be appropriate to form separate stockpiles for soils generated from different sources.

C. Roll-off box - Excavated soils or auger cuttings shall be placed in lined roll-off boxes.

The mixing of auger cuttings or excavated soils from different locations shall be verified with the Project Manager. Roll-off boxes shall be equipped with a lid or a good quality tarp for covering. All locking devices on lids and strapping devices on tarps shall be in good working condition. Tarps showing signs of wear, holes, tears or degradation shall be repaired or replaced. Strapping devices showing signs of damage or degradation shall be disposed and replaced. Following filling activities covers on roll-off boxes shall be closed and secured. The roll-off box storage location shall be coordinated with the site owner/operator. The location selected should be away from traffic patterns, but accessible for future pick-up. Records shall be kept of contents in each box. These records may include the following information:

Roll-off box identification number Generator's Name and Address Site Number


Date Soil Boring Number(s) Excavation location Contents

C. Soil Disposal - Prior to beginning the project, if possible, the Project Manager shall determine the soil disposal alternatives. If required, sampling for the purposes of waste profiling and disposal facility approval shall be completed following drilling and/or excavation, providing data consistent with the needs and requirements of the selected disposal facility(ies). Waste characterization sampling procedures are outlined in SOP F3028.

5.0 Documentation A. For Drilling Fluids, Purge and Decontamination Water

1.0 The volume of water extracted from a well from developing or purging

activities shall be recorded on the Groundwater Data Sheet or in the field notebook.

2.0 The volume of water that is extracted from a monitoring well/extraction well

shall be recorded on the Aquifer Test Data Sheet or in the field notebook.

3.0 The volume of water collected from a boring during drilling procedures shall be recorded on the Soil Boring Log or in the field notebook.

4.0 The volume of decontamination fluids shall be recorded in a field notebook,

Soil Boring Log, or Groundwater Data Sheet.

B. For Drill Cuttings and Excavated Material

1.0 If auger cuttings are placed in drums, the following information shall be included on the soil boring log, field notebook, or in the daily field report:

- the number of drums generated - labeling procedures - the type of drums used

2.0 If auger cuttings or excavated soils are stockpiled, this information shall be

noted on the soil boring log, field notebook, or the daily field report. The estimated volume of soil produced from each source shall also be noted.

3.0 If auger cuttings or excavated soils are placed in roll-off boxes, this information shall be noted on the soil boring log, field notebook, or the daily field report. The estimated volume of soil produced from each source shall also be noted.


4.0 Photographs can be taken of the drum staging area, the soil stockpile or the roll-off box staging area to document that proper handling procedures were followed.

6.0 Special Notes

Investigative derived wastes shall be disposed of in an expeditious manner in accordance with local laws and regulations and not stored on-site for more than 90 days to avoid potential RCRA TSD reporting obligations. Waste staging shall be coordinated with facility personnel so these areas remain accessible and located in a safe, secure location. Drum labels shall be filled out legibly with a ball point pen, permanent marker or paint pen. If drums are exposed to the weather labeling can fade from sun exposure.

7.0 Applicable Standards and References

None


SOP No. F3008 (2010rev) GROUNDWATER SAMPLE COLLECTION 1.0 Purpose

This SOP describes the procedures that will be followed during the collection of representative groundwater samples from monitoring wells/piezometers.

2.0 Equipment and Materials (as Required)

- flow-through cell capable of continuously monitoring field indicator parameters during purging and sampling;

- turbidity meter (optional); - a graduated cylinder; - interface probe or water level indicator with a tape graduated to 0.01 ft; - submersible pump, bladder pump, peristaltic pump, foot-valve lift pump, or positive

displacement piston pump; - power source (e.g., generator), if an electric pump is used; - dedicated or reusable bailer constructed of Teflon, stainless steel, disposable

polyethylene, or other acceptable material; - tubing constructed of polyvinyl chloride, polypropylene, polyethylene, stainless steel

or other suitable materials sized appropriate for the pump discharge; - polypropylene rope/ or other suitable bailer cord; - pH/temperature meter; - conductivity meter; - dissolved oxygen meter; - ORP/eh meter: - storage container for purge water; - calibrated container with a capacity of at least five gallons; and - vinyl/nitrile sample gloves.

3.0 Procedures

A. As the monitoring well/piezometer is approached, a visual inspection of the condition

will be completed and documented. If warranted in the site-specific Health & Safety Plan (HASP), the ambient air conditions in the vicinity of the wellhead will be documented prior to its opening in accordance with the procedures described in the HASP.

B. Measurements will be taken from the survey mark indicated on the top of the well casing. If a mark is not already indicated, the north position of the casing should be used as the measurement point. This point should then be marked for future reference.

D. The monitoring well will be allowed to stabilize prior to collecting water level

measurements using a water level meter or, if warranted, an interface probe. The interface probe or water level indicator will be decontaminated in accordance with Hull SOP No. F1000 prior to collecting water level measurements.

E. If warranted (i.e., if there is the potential for the presence of nonaqueous-phase


liquid [NAPL] in the well), a determination of immiscible layer(s) will be conducted in accordance with the probe manufacturer’s instructions. Measurements will be recorded in the field notebook or on the appropriate field data sheet. After the immiscible layer procedure is complete, the probe and all measuring tape lowered into the well will be thoroughly decontaminated in accordance with Hull SOP No. F1000.

F. If a water level probe is used to measure water levels, the probe will be slowly and

carefully lowered into the well column until the water level is encountered. The water level indicator will emit an audible signal when it makes contact with water. The tape will be slowly raised and lowered to obtain an exact measurement from the top of well casing, to within 0.01 feet. The measurement will be recorded in the field notebook or on the appropriate field data sheet. After the water level measurement procedure is complete, the probe and all measuring tape lowered into the well will be thoroughly decontaminated in accordance with HAP SOP No. F1000.

G. Well Purging

The purpose of purging is to evacuate stagnant water that may be present in the well column and filter pack and introduce representative formation water into the well casing. Purging is completed using a variety of pumps and bailers, which are described below; however all purging will be conducted via low flow methods unless determined otherwise by the Practice Leader. The device selected to purge the well is dependent upon the well construction and hydraulic conditions of the screened interval. The selected purging device will provide an adequate discharge rate without producing a deleterious effect on groundwater quality.

Low-flow water extraction will be the primary method of purging and sampling. The pump will be carefully lowered in the well to avoid disturbing sediment that may have settled in the bottom of the well. The pump’s intake will be situated within the screened interval – by convention, halfway between the top and bottom of the screen; however, site-specific conditions may warrant setting the intake above or below the halfway point. Pumping will then be initiated, with the flow adjusted such that little or no water level drawdown is measured within the well – U.S. EPA generally recommends keeping the flow rate below 200 ml/min. to avoid aeration of the water. Indicator field parameters will be measured and recorded until stabilization occurs. EPA recommends that the basis for stabilization is three consecutive readings, taken within three to five minute intervals, which fall within the following limits: - turbidity (+/- 10% for values greater than 10 NTU) (if applicable); - DO (+/- 10%) (if applicable); - Specific conductance (+/- 3%); - temperature (+/- 0.5 degrees Celsius) - pH (+/- 0.2 unit); and - ORP/Eh (+/- 20 millivolts) (if applicable).

For volumetric purging, a bailer or one of various types of pumps may be used. If use of a bailer is the appropriate method for purging and sampling, the U.S. EPA indicates that three to five well volumes be purged from a well in order to obtain a representative groundwater sample using non-low flow purging/sampling. Typically,


indicator field parameters (pH, temperature and conductivity) stabilize within the period that monitoring wells are purged of three well volumes. In some cases, dissolved oxygen and ORP/eh readings may also be required to document stabilization. Occasionally, it is advisable to purge less than three well volumes (e.g., in conditions where excessive purging may cause contaminant migration or if minimal purge volume technology such as low flow sampling is employed). Furthermore, more than three well volumes will be purged in cases where indicator field parameters have not stabilized. Under these conditions, the well will be purged until the temperature, conductivity and pH of the purge water have stabilized, or up to five well volumes (unless the FSAP or Project Manager specifies that more than five well volumes will be purged). The temperature, pH, and conductivity will be measured initially, as well as after one to 1.5 well volumes, then after purging each subsequent one-half well volume until the following are observed: - turbidity (+/- 10% for values greater than 10 NTU) (if applicable); - DO (+/- 10%) (if applicable); - Specific conductance (+/- 3%); - temperature (+/- 0.5 degrees Celsius) - pH (+/- 0.2 unit); and - ORP/Eh (+/- 20 millivolts) (if applicable). The values will be recorded in the field logbook or on the appropriate field data sheet. Where required, these meters will be calibrated and operated in accordance with the manufacturer’s specifications or other Hull SOPs for equipment calibration/operation. Calibration procedures and readings will be recorded in the field notebook or on the appropriate field data sheet. To reduce the possibility of error, purge and well volumes will be calculated in the field based on a conversion factor that represents the gallons of water in the well per foot of standing water. Typical conversion factors used are listed in the table below:

VOLUME PER LINEAR FOOT OF STANDING WATER

Well Diameter Cubic Feet Gallons 2.0 0.022 0.16 4.0 0.087 0.65 6.0 0.196 1.47 8.0 0.349 2.61

The following formula was used to determine the conversion factors:

Gallons/feet of water = C x (π x d2/4 x 1 feet)

Where: π=3.1416

d = Diameter of Well Casing (feet) C = 7.48 (constant for converting feet3 to gallons)

Then the volume to be purged will be:


V = (gallons/ft. of water) x L x n

Where: V = Volume to be purged (gallons)

L = Column of standing water in well (feet) n = Number of well volumes to be removed (typically three to five)

Depending on the hydraulic characteristics, depth, and recharge rate of an individual well, bailing may be an applicable method for well purging. Bailers used during this operation will be constructed of PVC, stainless steel, Teflon, or other acceptable materials. The selection of the type of material will be determined by the Practice Leader based on known geochemical conditions at the site and regional regulatory variances. If dedicated bailers are installed in the wells, they will be used for both purging and sampling, unless otherwise authorized by the Project Manager.

When using this purging technique, a new rope will be attached to the bailer when purging each well, unless the rope is dedicated with the dedicated bailer. The bailer will be slowly lowered into the water column to prevent excessive agitation of fines and to prevent aeration of the ground water. The well will be bailed from the top of the water column to the bottom. When the bailer is full, it will be retrieved and the contents carefully transferred into a holding container of known volume to determine the purge volume (e.g., five-gallon bucket). All water removed during purging will be assumed contaminated unless analytical data have been obtained that indicate otherwise. Purge water will be stored on-site and properly disposed of as directed by the Project Manager and Hull SOP No. F2024.

In some cases, a disposable polyethylene bailer sized for two-inch inside-diameter wells will be used when sampling each well. Acceptable sampling collection equipment includes a disposable bailer, dedicated bailer, or properly-decontaminated Teflon, stainless steel, or other acceptable bailer. A spool of unused nylon, polypropylene, or other acceptable rope will be used as the bailer cord. If a Teflon or stainless steel bailer will be reused, it will be properly decontaminated in accordance with Hull SOP No. F1000 prior to use in each well. The bailer cord will then be attached to the bailer and the bailer knot tested to ensure that the knot and all parts of the bailer are securely intact prior to lowering into the well.

It should be noted that the bailer cord should never touch the ground surface or the

protective well casing at any time during the sample collection process. If conditions at the wellhead are such that the bailer cord cannot be prevented from touching the ground, protective plastic sheeting will be placed around the well area to prevent rope from contacting the ground. In general, the upgradient monitoring wells will be sampled first, followed by the downgradient well expected to be the least contaminated and continuing until the last downgradient monitor well expected to be the most contaminated is sampled. If, from the historical database of groundwater monitoring data, it is apparent that no contamination is known to be present, the upgradient monitoring well(s) will be sampled first, followed by the downgradient monitoring wells.


Very low yielding wells, from which at least three well volumes cannot be removed or stabilization criteria cannot be met, will be completely evacuated before sampling. All wells will be sampled upon sufficient recovery and within 24 hours of purging. If a sample cannot be obtained after the initial purging, multiple trips to the well with less than 24 hours between trips will be made in accordance with applicable regulations. In some cases, greater than 24 hours will be required for recovery. This will be determined on a project-specific basis. Efforts will be made to maintain consistency in purging and sampling methodology for long-term monitoring programs at specific sites.

H. Sample Collection When using the low-flow technique, samples should be collected from a bypass

assembly prior to water entering the flow-through cell or, alternatively, the flow-through cell can be disconnected. To the extent possible, the tubing should remain water-filled while directing water into sample containers. Care will be taken so that minimal turbulence/aeration occurs during transfer of water from the tubing into sample containers.

When collecting samples with a bailer, the bailer will be slowly lowered into the well

to prevent agitation of the water to minimize the volatilization of any VOCs. The bailer will then be slowly and smoothly raised to the surface in a manner that will not agitate the sample. If a bailer is used, the contents will be transferred into the appropriate containers using the bottom valve and preserved in accordance with the specified analytical method. If preservative is not used in certain containers, the inside of sample container should be rinsed with sample water prior to being filled. Samples will be collected in order of decreasing volatility (i.e., volatiles, semi-volatiles, metals, etc.). Sample bottles will be properly labeled in accordance with the relevant plans for the project.

When using other groundwater pumps for purging and sampling, factors such as

depth to water, total depth of the well, and/or well diameter make the use of a bailer inefficient. In these instances, the use of pumps will be employed to maximize the efficiency of purging. Any pump used will be properly decontaminated prior to purging, in accordance with Hull SOP No. F1000. The use of any pump to purge a well will be carried out in accordance with the manufacturer's instructions. Potential types of pumps used for well purging include: submersible pumps, foot-valve pumps (e.g., Waterra™), peristaltic pumps, and positive displacement piston pumps, and low volume dedicated purge pumps. These pumps will only be used with approval of the Practice Leader for purging and sampling operations.

I. Field filtering may be necessary for metals analyses of samples where turbidity

stabilized above 5 NTUs and screened formation would suggest low particle mobility, such as sand and finer material. In this case, in-line filtering is preferred; however, open system techniques are acceptable. The sample should be pressurized through the filter media using a syringe immediately upon collection and prior to being preserved. Typically, a 5 micron filter is used; however, a finer filter may be used if justified based on site-specific conditions.

J. Samples placed in 40 ml glass vials for analysis of VOCs should be filled to zero


headspace. After filling and capping tightly, the vial will be inverted and tapped to inspect for bubbles. If bubbles are present, the vial will be discarded and a new sample taken. The container should not be topped off to fill the remaining headspace. If a sample without bubbles is not possible due to offgassing, the presence of bubbles should be noted on the field data sheet.

K. If duplicate groundwater samples are collected, the sample containers for both the

well sample and the duplicate sample will be filled on a "one-to-one" basis. For example, the sample container for VOCs for a specific well will be filled and then the container for VOCs for the duplicate sample will be filled from the same bailer.

L. All sample containers will be placed on ice as soon as possible after collection.

Samples should remain at 4°C until analysis. M. Finally, materials for sample collection will be either properly disposed of, or in the

case of reusable equipment, will be properly decontaminated per with Hull SOP No. F1000.

4.0 Documentation

A number of documents may be completed and maintained as part of the groundwater sampling effort. The documents should provide a summary of the sample collection procedures and conditions, shipment method, analyses requested and the custody history. Below is a list of the items and documents that should be completed:

- Field notebook

- Groundwater Monitoring Well Field Data Sheets - Sample labels - Chain-of-Custody records - Daily Field Reports - Request for analysis sheets All pertinent data including, but not limited to, the type of purging device, the volume purged, pH, conductivity, temperature, and any other relevant information will be recorded on in the field notebook or on the appropriate data sheet. Any deviation from the above-described procedures will be performed only with prior approval of the Practice Leader and documented in the field logbook or in the “notes” section of the field data sheet.

5.0 Special Notes

See manufacturer’s instructions for specific notes on various equipment and materials used in the collection of groundwater samples from monitoring wells/piezometers.

HULL & ASSOCIATES, INC. F3014-02REV.SOP STANDARD OPERATING PROCEDURE PAGE 1 OF 4

This document is property of Hull & Associates, Inc. and is intended solely for internal use by Hull & Associates, Inc. employees or their agents. Any dissemination, distribution or unauthorized use of this SOP is strictly prohibited.

SOP No. F3014 (2002rev) CHAIN-OF-CUSTODY PROCEDURES

1.0 Purpose

This SOP documents the chain-of-custody (COC) procedures that will be employed during all sampling activities.


- Indelible ink ball-point pens - Chain-of-custody records - One-gallon size Zip-Loc (or equivalent) storage bags

3.0 General

A completed COC record must accompany every sample from the point of collection to delivery to the laboratory. A single COC record may accompany several samples as long as all the samples are contained in a single unit (e.g., cooler, box, etc.). If a single COC is to be used for multiple samples in multiple coolers then a photocopy of the original COC must be placed in each cooler. All COCs will be kept in one-gallon Zip-Loc bags to prevent damage from melting ice, broken samples, and bad weather. A copy of every completed COC record will be retained in the project files.

4.0 Procedures

4.1 Completion of COC Record

A. The COC record is initiated in the field by the sampler(s) immediately after a sample is collected. Figure F3014-1 illustrates a properly completed COC.

B. The sample identification number will be recorded on the COC. Each sample number

consists of three distinct data fields. A space for each data field is provided on the COC. These data fields include; Project Number, Sample Location, and Sample Type & ID.

C. The number of containers that makes a complete sample will be recorded in the box

labeled "No. of Cont.". A sample may consist of multiple containers depending upon the analytical procedures requested.

D. If the sample is to be analyzed for metals, the box labeled "Metals" shall be completed to

indicate whether the sample fractions for metals have been filtered. A "F" will be used to indicate that the metals were filtered and a "N" will indicate that they were not filtered. Occasionally, some samples may require metal fractions to be filtered and not filtered (e.g., analyses for dissolved and total metals). In this case a "B" will be used to indicate that the sample contains both filtered and non-filtered fractions. If the sample does not require analyses for metals or is not applicable to filtering (i.e., solid sample) a single line will be drawn through this box.



E. The date and time (military) of sample collection will be recorded in the box labeled "Sampling Date/Time". It is very important to note the exact time each sample was collected.

F. The requested analytical methods will be recorded in the diagonal spaces provided under

the box labeled "Analyses". The analytical method should always be referenced. Generalized descriptions such as “Metals” are not acceptable unless they reference a specific list (i.e., RCRA metals, Priority Pollutant List metals, etc).

G. Any preservatives added to the containers for each analytical method will be indicated by

recording the letter in the box labeled "Preservatives" that corresponds to the preservative added. The preservatives and corresponding letters are listed near the top of the COC record.

H. A check mark or an “X” will be made under each fraction for which a particular sample will

be analyzed. Drawing a line down the column or using quotes is not acceptable.

I. Any comments relating to the collected sample(s) can be recorded in the box labeled "Comments". These comments may indicate special handling or analytical instructions for the laboratory (e.g., compositing instructions, confirm MTBE, etc.) or may be used to indicate the location of sample collection.

J. Additional information required on the COC record includes the person the analytical

reports should be sent to, client, site, project description, project number and phase, names of all samplers involved in sample collection, where the samples are to be delivered, method of delivery, and airbill number (if applicable).

4.2 Transfer of Custody

A. The COC record must document the transfer of custody each time the sample(s) changes

hands. The National Enforcement Investigations Center (NEIC) of the EPA defines custody as:

1. the sample is in your physical possession;

2. the sample is within view after being in your physical possession;

3. the sample was in your possession and then you locked it or sealed it to

prevent tampering; and/or

4. the sample is placed in a designated secure place with limited access to authorized personnel only.

B. When transferring custody of samples, the person in custody (e.g., the sampler) must sign

the box labeled "Relinquished By" and fill in the date and time (military time) the custody of the samples was relinquished. The person accepting custody of the samples must then sign the box labeled "Received By" and complete the date and time (military time) the custody of the samples was accepted.



C. The above procedures must be followed until the samples are delivered to the laboratory. Both internal (within the same organization) and external (between different organizations) transfers need to be documented. In cases where a commercial courier (e.g., Federal Express) is used to deliver the samples, the person relinquishing custody to the courier should put the name of the courier in the "Received By" box and seal the COC inside the cooler. Most couriers have a policy against signing for custody of samples.

D. The pink copy (bottom) of the COC will be retained by the sampler before the samples

are shipped and the remaining copies (white and yellow) of the COC are delivered to the laboratory. The pink copy will then be immediately given to the QAO. The white copy will be returned by the laboratory with the final report.

5.0 Documentation

Chain-of-custody record 6.0 Special Notes If samples are shipped via commercial courier on Friday the air bill needs to be checked for Saturday delivery. Sample cooler packing instructions are documented in Hull’s SOP F1013. If samples are known to contain flammable or hazardous materials they need to be shipped accordingly. Check with the courier for specific shipping, labeling and packing requirements. 7.0 Applicable Standards and References

U.S. Environmental Protection Agency. NEIC Policies and Procedures. EPA-330/9-78-001- R. May 1978. (Revised February 1983.)

U.S. Environmental Protection Agency. User's Guide to the Contract Laboratory Program.

Office of Emergency and Remedial Response. December 1986.

U.S. Environmental Protection Agency. A Compendium of Superfund Field Operations Methods. EPA/540/P-87/001, December 1987.

Fig

ure

3014-1

HULL & ASSOCIATES, INC. F3028.SOP STANDARD OPERATING PROCEDURE PAGE 1 OF 5 This document is property of Hull & Associates, Inc. and is intended solely for internal use by Hull & Associates, Inc. employees or their agents. Any dissemination, distribution or unauthorized use of this SOP is strictly prohibited.

SOP No. F3028 (2011) PROCEDURE FOR THE SAMPLING OF INVESTIGATION DERIVED WASTES FOR WASTE

CHARACTERIZATION

1.0 Purpose These procedures shall be followed when collecting samples of used drilling fluids, decon fluids, purged groundwater, investigation-derived solids, and excavated materials for the purpose of waste characterization. The procedure describes recovery of samples collected from material containerized in drums, barrels, tanks, roll-off boxes, and stockpiles. 2.0 Equipment and Materials In general, sampling equipment should be constructed of inert materials such as stainless steel or Teflon. Reusable equipment shall be decontaminated in accordance with SOP No. F1000 prior to use. Additionally, single-use, disposable, sampling equipment may be used if specifically permitted by the work plans or the Project Manager. For sampling soil, sludge or sediment

- sampling spoon, trowel, shovel or scoop Encore sampler for VOCs (refer to SOP No. F3022 for this sampling device)

- stainless steel mixing bowl, Teflon tray, or clean and unused plastic bag (as required for compositing samples)

- hand tools including hammer, bung wrench and ratchet equipped wth15/16” socket - sampling gloves - laboratory sample containers - decontamination supplies

For sampling fluids

- dedicated or reusable bailer constructed of Teflon, stainless steel, disposable polyethylene, or other acceptable material

- single –use disposable composite liquid waste sampler or equivalent device - laboratory sample containers - sampling gloves - decontamination supplies

3.0 Procedures The sampling procedure varies depending upon whether the material to be sampled is soil, sludge, sediment or liquid, and how the material is stored.


3.1 Sampling soil, sludge or sediment from a drum Discrete Samples

A. All sampling equipment shall be either single-use disposable equipment or be decontaminated prior to use in accordance with the procedures specified in SOP No. F1000.

B. Remove the lid from the drum. C. Collect the sample using a sampling device (e.g., spoon, scoop, shovel, etc.)

from the material containerized in the drum. The sample shall be representative of the materials contained within the entire drum.

D. Place the sample into a laboratory-supplied container. Samples collected for

volatile organic analysis should be relatively undisturbed and collected directly into the Encore (or equivalent) sampling device.

E. Label the sample container with the appropriate information. Complete all chain-

of-custody documents and record the appropriate information in the field log book or report form.

F. Place the labeled sample container immediately in an appropriate transport

container with ice (if required).

G. Close the drum following sample collection, and return it to the staging area Composite Samples Composite samples are derived from multiple discrete samples collected as described above. The number of discrete samples to be included in a composite sample shall be specified by the Project Manager and is usually dictated by the requirements of the disposal facility. Composite samples may be formed from multiple discrete samples from a single drum or they may be formed from discrete samples collected from multiple drums. The compositing scheme shall be specified in the work plans or by the Project Manager. In general a composite sample is prepared by combining several discrete samples into a stainless steel mixing bowl, Teflon tray or Ziploc-type bag where the soil is mixed together. An aliquot of the mixed sample shall be placed into laboratory-supplied sample containers. 3.2 Sampling dry or saturated soil, sludge or sediment from a roll-box. Discrete Samples



B. Remove the lid or tarp from the roll-off box. C. Collect the sample using a sampling device (e.g., spoon, scoop, shovel, etc.)

from a least one foot beneath the surface of the material in the roll-off box. Samples collected for volatile organic analysis should be relatively undisturbed and collected directly into the Encore (or equivalent) sampling device.

D. Place the sample into a laboratory-supplied container.

E. Label the sample container with the appropriate information. Complete all chain-




G. Secure the roll-off box following sample collection. Composite Samples Composite samples are derived from multiple discrete samples collected as described above. The sampling requirements will vary and will be dictated by the requirements of the disposal facility and the applicable regulatory program. The compositing scheme shall be specified in the work plans or by the Project Manager. Typically, the roll off container shall be divided in quarters and a discrete sample collected from each quarter, a minimum of one foot below the surface of the material within the container. To prepare the composite, several discrete samples shall be placed into a stainless steel mixing bowl, Teflon tray, 5 gallon bucket or Ziploc-type bag where the soil is mixed together. An aliquot of the mixed sample shall be placed into laboratory-supplied sample containers. 3.3 Composite sampling of soil, sludge or sediment from a stockpile. Discrete Samples


B. Uncover the stockpile to allow access to the stockpiled material. C. Partition the stockpile into segments as specified in the work plans or by the

Project Manager to get representative samples. Certain regulatory programs will specify the number of discrete samples based on the volume of the stockpile.

D. Collect the sample using a sampling device (e.g., spoon, scoop, shovel, etc.)

from a least one foot beneath the surface of the soil in the roll-off box. Samples collected for volatile organic analysis should be relatively undisturbed and collected directly into the Encore (or equivalent) sampling device.


E. Place the sample into a laboratory-supplied container.

F. Label the sample container with the appropriate information. Complete all chain-


G. Place the labeled sample container immediately in an appropriate transport


H. Re-cover the stockpile following sample collection.

Composite Samples Composite samples are derived from multiple discrete samples collected as described above. The sampling requirements will vary and will be dictated by the requirements of the disposal facility and the applicable regulatory program. The compositing scheme shall be specified in the work plans or by the Project Manager. Typically, the stockpile shall be divided in quarters and a discrete sample collected from each quarter, a minimum of 1 foot below the surface of the soil within the container. The discrete samples shall be placed into a stainless steel mixing bowl, Teflon tray, 5 gallon bucket or Ziploc-type bag where the soil is mixed together. An aliquot of the mixed sample shall be placed into laboratory-supplied sample containers. 3.4 Sampling liquids stored in a 55-gal drum, barrel or tank. Discrete Samples

A. All sampling equipment shall either be single-use disposable equipment or be decontaminated prior to use in accordance with the procedures specified in SOP No. F1000.

B. Open the drum, barrel or tank. C. Collect a sample of the liquid using a sampling device (e.g., bailer or composite

liquid waste sampler).

D. Place the sample into an appropriate laboratory-supplied container.

E. Label the sample container with the appropriate information. Complete all chain-of-custody documents and record the appropriate information in the field log book or report form.



G. Close the drum, barrel or tank following sample collection,


Composite Samples Unless specifically required by the work plans, liquid wastes shall not be composited in the field. Composite samples for liquid wastes shall be formed in the laboratory from multiple discrete samples. The discrete samples of liquid waste shall be collected using the procedures described above. The discrete samples shall be submitted to the analytical laboratory with specific instructions on how to composite the samples.

4.0 Documentation

Each sample container will be labeled as directed by the Project Work Plan, Quality Assurance Project Plan or by the Project Manager. Chain-of-custody documentation will be completed for all samples collected for laboratory analysis. A field log book or other Field Data Sheet will be maintained describing the sampling procedures, the sample locations, all sample identification numbers, and any deviations from this SOP. A map or site sketch may be prepared to document staging areas; sketches will be contained in the field notes.

5.0 Special Notes

The decontamination process will be repeated after each use and between all discrete sample locations. If compositing strategies are used, decontamination may only be required between composite samples (i.e., not between discrete samples that form a single composite). Sample gloves shall be changed in between each location. Project Managers are responsible for determining the appropriate sampling protocols depending on the regulatory requirements. Some regulators may require the analyses of discrete samples for waste characterization as opposed to composites, etc. Review the Health and Safety Plan to assure that sampling activities consider the potential hazards associated with this activity.

6.0 Applicable Standards and References

U.S. EPA. Characterization of Hazardous Waste Sites, A Methods Manual - Vol. II, Available Sampling Methods. 2nd Ed. 12/84. EPA/600/4-84/076.

APPENDIX B

Field Data Sheets and QC Forms

FIELD DATA SHEET AND QC FORM INDEX Daily Field Report Groundwater Sampling Checklist Field Instrument Calibration Log Groundwater Monitoring Well Field Data Sheet (or Low-Flow example below) Low-Flow Groundwater Monitoring Well Field Data Sheet Holly East Refinery Groundwater Gauging Sheet (for Water Level and Interface

Measurements) Chain of Custody

Holly Refining & Marketing – Tulsa LLC, East Tulsa Refinery RCRA Post‐Closure & Corrective Action Permit



INSPECTION AND MAINTENANCE PLAN



i

INSPECTION AND MAINTENANCE PLAN TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................ 1

1.1 Objectives and Scope ...................................................................................................... 1 2.0 GENERAL INSPECTION & MAINTENANCE PLAN INSPECTION SCHEDULES ...................... 2

2.1 Inspection Details ............................................................................................................ 2 2.2 Frequency of Inspections ............................................................................................... 2

2.2.1 Corrective Actions .............................................................................................. 3

2.3 Record Keeping ............................................................................................................... 3

3.0 REGULATED AREAS OF THE INSPECTION & MAINTENANCE PLAN ................................. 4

3.1 Regulated Land Treatment Units (LTUs) ........................................................................ 4 3.2 Solid Waste Management Units (SWMUs) ................................................................... 5

3.2.1 SWMU‐ A: Former Land Farm .......................................................................... 5 3.2.2 SWMU‐B: Former Land Farm ........................................................................... 6 3.2.3 SWMU‐ C: Former Land Farm (Tetraethyl Lead Area) ........................................ 7 3.2.4 SWMU‐D: Former Landfill (Off Unit Storm Pond) ........................................... 8 3.2.5 SWMU‐E: Former Landfill (Current WWTP) ..................................................... 8 3.2.6 SWMU‐ F: Former Land Farm ............................................................................ 9 3.2.7 SWMU‐ G: Former Land Farm (Alky Unit) ....................................................... 10 3.2.8 SWMU‐ H: Landscaped Area ........................................................................... 11 3.2.9 AOC‐1: Former Landfill (Dredge Pond) ........................................................... 12 3.2.10 AOC‐2: Former Union Pacific Rail Road Property ........................................... 12

Figure

Figure 1 Inspection Form



1

Holly Tulsa East Refinery Attachment #4

Inspection and Maintenance Plan October 2011

1.0 INTRODUCTION

Holly Refining and Marketing (Permittee) operates the Holly Tulsa East Refinery (Facility) which

has two (2) land treatment units (LTUs) where wastes remain in place after closure of the

hazardous waste management units. The two (2) closed LTUs are known as the Flare Area LTU

(FALTU) and the Walnut Grove LTU (WGLTU). The FALTU is approximately twenty‐nine (29)

acres; the WGLTU is approximately twenty (20) acres in size.

The refinery has developed a comprehensive Inspection and Maintenance Plan (IMP) for the

Resource Conservation and Recovery Act (RCRA) regulated LTUs located at the Facility. The IMP

also applies to the solid waste management units (SWMUs) located at the Facility. This IMP has

been prepared to meet the submittal requirements of a RCRA Part B Permit.


The objective of the IMP is to detail the inspection and maintenance activities and the frequency

of those activities that will be carried out during the post‐closure period for each LTU, SWMU, and

area of concern (AOC). The IMP meets the general inspection requirements of 40 CFR Part

264.15 and the post‐closure requirements found in Part 264.273 (g).

The Post‐Closure Plan time frame is for a period of thirty (30) years from the date of final closure

of each LTU.



2

2.0 GENERAL INSPECTION & MAINTENANCE PLAN INSPECTION SCHEDULES

Inspections at the Holly Tulsa East Refinery will generally consist of the following activities for

the LTUs and the SWMUs/AOCs.

2.1 Inspection Details

The inspections cover the major features of the LTUs & SWMUs including:

• Deterioration, malfunctions, or improper operation of LTU run‐on and run‐off control systems including any potentially detrimental changes in the existing system of dikes and levees surrounding the LTUs;

• Integrity of the monitoring well networks;

• Security features including integrity of all fences, gates, locks, and appropriate signage;

• Conditions of paved, gravel and concrete surfaces;

• Condition of vegetative cover including soil erosion, subsidence and animal burrows; and

• Wind dispersion.

Conditions that require attention during the inspections (such as fence integrity, vegetative cap

condition, well condition, etc.) are outlined on the inspection log. A sample of the inspection log

for the IMP is provided as Figure 1.

2.2 Frequency of Inspections

Area Frequency

FALTU Semi‐annual, or as needed

WGLTU Semi‐annual, or as needed

SWMUs & AOCs Semi‐annual

Monitoring Well Network Semi‐annual



3

Note: LTU Inspections may be performed more frequently than semi‐annually if significant

weather events occur.

2.2.1 Corrective Actions

Any problems, deficiencies or issues detected by inspection or at any other time will

immediately brought to the attention of the appropriate supervisor, Security and the

Environmental Remediation Program Manager and noted in the inspection log. Repairs and/or

any corrective action will be taken as soon as possible to remedy the issue. A description of any

repairs or remedial actions will be recorded in the inspection log.

2.3 Record Keeping

The inspection logs will be kept for a minimum of three (3) years from the date of inspection,

and will be placed in the RCRA File and Records Room in the environmental department of the

Facility.

Corrective actions made in response to noted deficiencies or issues identified during any

inspection will also be included in the semi‐annual monitoring report (SMR) prepared for the

Oklahoma Department of Environmental Quality (DEQ).



4

3.0 REGULATED AREAS OF THE INSPECTION & MAINTENANCE PLAN

All closed LTUs, where wastes have been left in place, and the SWMUs/AOCs areas will be

inspected as part of this IMP. Descriptions and brief histories of the SWMUs are provided in more

detail under the SWMU/AOC section of this IMP. The following twelve (12) areas include LTUs and

SWMUs which require routine inspections and maintenance activities in accordance with the

protocols outlined in this IMP:

1. The Flare Area LTU

2. The Walnut Grove LTU

3. SWMU A – Former Land Farm

4. SWMU B ‐ Former Land Farm

5. SWMU C – Former Land Farm (Tetraethyl Lead Area)

6. SWMU D – Former Landfill (Off Unit Storm Pond)

7. SWMU E – Former Landfill (Current WWTP)

8. SWMU F – Former Land Farm

9. SWMU G – Former Land Farm (Alky Unit)

10. SWMU H – Landscaped Area

11. AOC 1 – Former Landfill (Dredge Pond)

12. AOC 2 – Former Union Pacific Rail Road Property

3.1 Regulated Land Treatment Units (LTUs)

Two RCRA regulated LTUs have historically operated at the Facility. Solid wastes were reportedly

placed in the LTUs sometime prior to 1947. The last waste application was in February 1988 for

the FALTU. Only non hazardous wastes were applied to the WGLTU since 1990. The FALTU was

certified closed in April 1, 1993. The WGLTU was certified closed April 24, 2009. In total, the two

(2) LTUs occupy approximately forty‐nine (49) acres. As part of the LTU closures, all areas were



5

either seeded or had previously established vegetative covers. Both LTUs are currently under

post‐closure care.

The Permittee proposes to inspect, maintain and monitor the LTUs during the post‐closure period by

performing the following activities:

1. Inspect and maintain a vegetative cover, including fertilization, watering, mowing and reseeding as needed;

2. Inspect to preserve adequate security requirements by checking Facility

fencing, locks and proper warning signs;

3. Inspect run‐on controls to maintain minimal run‐on to LTUs;

4. Inspect run‐off controls to maintain adequate drainage from LTUs; and

5. Perform required post‐closure semi‐annual water level gauging of Facility network gauging wells and semi‐annual groundwater monitoring of Facility POC wells. The groundwater monitoring protocol for the Facility is detailed in the Sampling and Analysis Plan (SAP) provided as Permit Attachment 3.

3.2 Solid Waste Management Units (SWMUs)

3.2.1 SWMU‐A: Former Land Farm

SWMU‐A was originally identified as a SWMU by the Environmental Protection Agency (EPA) in

1984 as a result of a refinery Site Inspection as part of Sinclair Oil Company’s (SOC) hazardous

waste management permit. SWMU‐A reportedly was used for the disposal of rust scale from

unleaded tank bottoms from 1947 – 1970. Lead (Pb) and Chromium (Cr) were reportedly

historically identified in the subsurface soils at the SWMU. In Section VI, page 1 of the

December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s

completed RFI Phase 2 report which presented the results of field sampling and analysis around

the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D,

and the Dredge Pond Area of Concern (AOC‐1), the DEQ determined that no further



6

remediation or corrective action is required.” The SWMU A status is closed as a result of this

determination.

Permittee proposes to:

• Inspect and maintain a vegetative cover, including fertilization, watering,

mowing and reseeding; and

• Inspect to preserve adequate security requirements by checking adjacent Facility fencing.

3.2.2 SWMU‐B: Former Land Farm

SWMU‐B was originally identified as a SWMU by the EPA in 1984 as a result of a refinery Site

Inspection as part of SOC hazardous waste management permit. It was reported that SWMU‐B

historically received oily tank bottom sludge’s up to 1966 and was the reported location of a

one time crude oil spill. Pb and Cr have historically been identified in the subsurface soils at the

SWMU. In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ

states that they “received Sinclair’s completed RFI Phase 2 report which presented the results

of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that

“with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the DEQ

determined that no further remediation or corrective action is required.” The SWMU B status

is closed as a result of this determination.


• Inspect and maintain a vegetative cover, including fertilization, watering, mowing and reseeding; and




7

3.2.3 SWMU‐C: Former Land Farm (Tetraethyl Lead Area)

SWMU‐C was originally identified as a SWMU by the EPA in 1984 as a result of a refinery Site

Inspection as part of SOC’s hazardous waste management permit. Originally described as a one

(1) acre size site, SWMU‐C historically received leaded tank bottom sludges in 1973. Pb has

historically been identified in the subsurface soils at the SWMU. Elemental mercury (Hg), Pb

and petroleum hydrocarbons were discovered during soil pre‐characterization activities as part

of a geotechnical investigation performed by SOC during construction of a new sulfur unit on

July 1, 2008. The boundaries of SWMU‐C were expanded in August 2008 to incorporate these

additional impacted areas.

The DEQ requested an investigative work plan to address the elemental Hg. The work plan was

submitted by SOC in June 2009 and approved by DEQ in October 2009. Holly conducted

investigation activities and impacted soil removal actions in December 2009 and in February

2010. A summary report was submitted to DEQ in June 2010. The report concluded that no

visible elemental Hg remained in the investigation target area, and the elemental Hg impact

was localized and appeared to be of limited extent. However, soil sampling in the area, post

soil removal, indicated that Hg impacted soils were still present above EPA risk based industrial

soil screening levels. The DEQ response letter dated August 15, 2011 (received by Holly on

September 9, 2011) noted additional measures that Holly must take if follow‐up investigation

and corrective actions were not performed. Holly plans for additional investigations to be

performed for the applicable chemicals of concern (COCs) in SWMU‐C. An investigative work

plan will be submitted in the schedule outlined in Permit Condition III.H.2.


• Inspect and maintain a vegetative cover, including fertilization, watering, mowing and reseeding; repairing concrete cracks; and adding gravel to fill in depressions in gravel areas; and



8


3.2.4 SWMU‐D: Former Landfill (Off Unit Storm Pond)

SWMU‐D was originally identified as a SWMU by the EPA in 1984 as a result of a refinery Site

Inspection as part of SOC’s hazardous waste management permit. Originally described as a five

acre size site, SWMU‐D reportedly historically received oily tank bottom and heat bundle cleaning

sludges sometime prior to 1947 and until 1976. These wastes were reportedly excavated and

land farmed at the FALTU. SWMU‐D is currently occupied by an active storm water holding

reservoir lined with a four‐inch thick clay layer. Pb and Cr have historically been identified in the

groundwater adjacent to SWMU‐D. In Section VI, page 1 of the December 10, 1998 Walnut Grove

Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which

presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ

further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1),

the DEQ determined that no further remediation or corrective action is required.” The SWMU D

status is closed as a result of this determination.


• Inspect to preserve adequate security requirements by checking adjacent Facility

fencing.

3.2.5 SWMU‐E: Former Landfill (Current WWTP)

SWMU‐E was originally identified as a SWMU by the EPA in 1984 as a result of a refinery Site

Inspection as part of SOC’s hazardous waste management permit. Originally described as a five

(5) acre size site, SWMU‐E reportedly was an active landfill where API separator sludge was

disposed of sometime prior to 1947 and ending in 1976. These wastes were reported to have been

excavated and land farmed at the FALTU. Currently, SWMU‐E houses the refinery waste water



9

treatment plant (WWTP) including the On‐unit Storm Pond, the two API separators and tanks 400

and 401 (slop oil tanks).

In July 2008 additional waste materials were encountered during the cleaning of the north storm

water pond located at the WWTP. The boundaries of SWMU‐E were subsequently expanded to

include the newly identified impacted areas. The dimension of the bottom of the north storm

pond is reportedly approximately one hundred eighteen (118) feet by two hundred twenty‐four

(224) feet. The dimension of the top of the north storm pond is approximately one hundred

seventy‐five (175) feet by two hundred eighty‐two (282) feet. The depth of the pond is

approximately eleven and one half (11.5) feet. The overall holding capacity of the pond is

estimated at 2.8 million gallons. It is not feasible to perform current investigations at SWMU‐E

due to on‐going refinery operations. Further investigation of SWMU‐E will be proposed when the

refinery ceases operations or the WWTP is taken out of permanent service.


• Inspect and maintain an adequate cover by repairing concrete cracks and re‐grading gravel or backfilling gravel areas as needed; and


3.2.6 SWMU‐F: Former Land Farm

SWMU‐F was identified as a SWMU in October 2004 as a result of refinery construction activities.

Refinery personnel were installing new naphtha hydrotreater equipment when solid waste material

identified as coke was found approximately three (3) feet below ground surface inside an old

concrete foundation. The dimensions of the foundation were approximately one hundred sixty

(160) feet long x fifty (50) feet wide x twelve (12) feet deep. SWMU F was estimated to have a

capacity of around 3,600 cubic yards based on the aforementioned dimensions. A total of

approximately 3,875 cubic yards of waste material was reportedly excavated from SWMU‐F and



10

disposed of off‐site. It is not feasible to perform current investigations at SWMU‐F due to on‐going

refinery operations. Further investigation of SWMU‐F will be performed when the refinery ceases

operations or the naphtha hydrotreater and associated units are taken out of permanent service.


• Inspect and maintain an adequate cover by repairing concrete cracks; and re‐grading gravel areas as necessary. Concrete‐floored units will be inspected only during routine maintenance turnaround of the units; and


3.2.7 SWMU‐G: Former Land Farm (Alky Unit)

SWMU‐G was identified as a SWMU in August 2007 as a result of refinery personnel evaluating

the integrity of buried sections of the process wastewater sewer system located at the alkalization

(alky) unit. It was determined that a release through cracks or other openings in one of the drain

lines that discharges oily water to the sewer system had occurred, impacting soils adjacent to the

line. The main sewer system is comprised of approximately 1,266 linear feet of pipe. The

excavated drain line was approximately one hundred (100) feet in length and the associated feed

lines totaled approximately one hundred twenty (120) linear feet. Based upon the dimensions of

the Alky Unit and assuming an area of impact to a maximum depth of five (5) feet, the unit is

estimated to have a 19,450 cubic yard capacity. The Alky Unit is located near the center of the

process area of the refinery. It is not feasible to perform current investigations at SWMU‐G due to

on‐going refinery operations. Further investigation of SWMU‐G will be proposed when the

refinery ceases operations or the Alky Unit is taken out of permanent service.


• Inspect and maintain an adequate cover by repairing concrete cracks and re‐grading gravel areas as necessary. Concrete‐floored units will be inspected only during routine maintenance turnaround of the units; and



11


3.2.8 SWMU‐H: Landscaped Area

SWMU‐H was identified as a SWMU in May 2008 when buried drums were discovered during

refinery landscaping and grading. An approximate nine and one half (9.5) acre size tract of land

adjacent to the Arkansas River located between the east tank farm fence and the east property

fence was slated for public access under the management of the River Parks Authority. Prior to

opening the area to the public, a patch of tar‐like material and debris were reportedly

encountered during landscaping activities. The waste materials were excavated to a depth of

approximately three (3) feet below ground surface. Reportedly during excavation activities

deteriorated drums, petroleum impacted soils and potential asbestos containing materials

(ACM) were identified. Additionally, the City of Tulsa reported encountering over one hundred

fifty (150) buried drums during the installation of the sewer line in the same approximate area

in 1991. Employees from former refinery operations indicated a portion of SWMU‐H was

apparently used as a waste disposal site. Reportedly shallow pits approximately eighteen (18)

to twenty (20) feet wide by approximately twenty (20) to twenty‐five (25) feet long and eight

(8) to twelve (12) feet deep were dug and then filled with a variety of waste material (e.g.,

asbestos, wood scraps, glass, scrap metal, dirt, bricks, coke, gunite, spent catalyst, residue

materials, and tank bottoms). The disposal area was apparently operational prior to 1951 and

closed sometime prior to 1982. Holly intends to perform additional investigations at SWMU‐H

as specified in Permit Condition III.G.


• Inspect and maintain an adequate vegetative cover by fertilizing, mowing, reseeding and watering; and




12

3.2.9 AOC‐1: Former Landfill (Dredge Pond)

Reportedly, the AOC‐1 Area was a naturally occurring pond that was used for disposal of spent

catalyst from the fluid catalytic cracking unit. The AOC‐1 Area was reportedly designated as a

SWMU resulting from the disposal of spent catalyst and tank bottom wastes. Reported impacts

were Pb and hydrocarbons. In Section VI, page 1 of the December 10, 1998 Walnut Grove

Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which

presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ

further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern

(AOC‐1), the DEQ determined that no further remediation or corrective action is required.” The

AOC‐1 status is closed as a result of this determination.


• Inspect and maintain a vegetative cover, including fertilization, watering, mowing and reseeding; and


3.2.10 AOC‐2: Former Union Pacific Rail Road Property

The AOC‐2 Area was identified as a SWMU in July 22, 2008 as a result of refinery construction

activities. Solid waste was encountered in two (2) excavations during the rerouting of an off‐unit

storm water line. The buried solid waste was located in a triangular portion of property located

south of the refinery’s WWTP and northeast of the refinery’s off‐unit storm water pond. SOC

purchased the triangle piece of property from Union Pacific Railroad in 2008. The buried waste

was encountered near the surface to depths ranging from approximately 4 to 6 feet below the

ground surface. The waste was comprised primarily of fire brick, scrap metal, construction debris,

glassware, insulation and ACM. Asbestos was reportedly then removed from an excavation in

AOC‐2 that was approximately six hundred (600) feet long x thirty (30) feet wide x five (5) to six

(6) feet deep in size. The ACM were reportedly disposed off‐site at an appropriate disposal



13

facility. Holly intends to perform additional investigations at AOC‐2 as specified in Permit

Condition III.F.


• Inspect and maintain an adequate cover by repairing concrete cracks, re‐grading gravel areas, fertilizing, watering, mowing and reseeding; and


HOLLY TULSA EAST REFINERY INSPECTION & MAINTENANCE PLAN

INSPECTION LOG Inspection Date: Inspected By: Inspection Time:

LTU OR SWMU AREA

VEGETATIVE COVER

GRAVEL PAVEMENT CONCRETE SURFACE

RUN‐ON/RUN‐

OFF

EROSION DUST

PONDED WATER etc.

SIGNAGE GATE FENCE OTHER/COMMENTS

FALTU

WGLTU

SWMU ‐ A

SWMU ‐ B

SWMU ‐ C

SWMU ‐ D

SWMU ‐ E

SWMU ‐ F

SWMU ‐ G

SWMU ‐ H

AOC‐1

AOC‐2 POC Monitoring Well Network

ISSUES/DEFICIENCIES NOTED

CORRECTION ACTIONS TAKEN

HTE - Figure 1 Inspection Form (Revised 09-21-11)




CORRECTIVE ACTION AND POST‐CLOSURE COST ESTIMATES

2010 $11,069,552.00 West$11,893,900.00 East

2011 $6,914,774.00 West$8,684,815.00 East

Projects Deleted from FA in 2011 2010 Estimated Cost JustificationWest

AOC 1 Investigation $100,000.00 Investigation Completed in 2010Area D Sheening Investigation $75,000.00 No sheening since permit effectiveAlternative Insitu pilot tests (i.e. air sparging, etc.) $60,000.00 Based on IGPG Sampling, this work is likely unnecessaryArea B RB Stabilization $300,000.00 Reduced by $50,000 ‐ IM Cost Estimate only $250,000 (includes $100,000 for POC Replacement)Area B Sheen Mitigation (pump and treat) $300,000.00 Additional Pump and Treat no longer being consideredArea B Sheen Mitigation (slurry wall option) $2,000,000.00 Slurry Wall no longer being consideredArea H Interim Measure $300,000.00 Reduced by $200,000 ‐ IM Cost Estimate only $100,000Area D Interim Measure $500,000.00 No sheening since permit effectiveAlternative Insitu ‐ Dissolved Phase Containment at RB $600,000.00 Based on IGPG Sampling, this work is likely unnecessaryMonitor well flooding resolution $100,000.00 Flooded Well Replacement Completed in 2010

$3,985,000.00 Total

EastGroundwater Standards Development & Risk Assessment $125,000.00 Not anticipated to be completed in the next 5+ yearsSWMU ‐ A (former land farm) $110,300.00 *No further action SWMU ‐ B (former land farm) $173,300.00 *No further action

SWMU ‐ C (former land farm) $437,300.00

SWMU ‐ D (former landfill) $61,000.00 *No further action

SWMU ‐ E (former landfill & current WWTP) $330,000.00

SWMU ‐ F (former land farm) $222,000.00

SWMU ‐ G (former land farm) $258,300.00

AOC ‐ Dredge Pond (former landfill) $147,000.00 *No further action Walnut Grove LTU (post closure) $1,110,000.00 No longer required (per CO 11‐100) as we move to facility‐wide permit Flare Area LTU (post closure) $750,000.00 No longer required (per CO 11‐100) as we move to facility‐wide permit

$3,724,200.00 Total

Notes: 1. General plant wide O&M was reduced from $9,900,000 to $5,835,000. LTU maintenance is now included in general plant wide O&M.

Justification of Reduction of 2011 Financial Assurance

2. 2010 East FA costs were calculated at the time of the purchase of the refinery. The status of many areas were unknown at that time. The costs were adjusted in 2011 based on the new facility‐wide permit approach and the SWMUs and AOC that had NFA status.

*In Section VI, page 1 of the December 10, 1998 Walnut Grove Operations Permit, DEQ states that they “received Sinclair’s completed RFI Phase 2 report which presented the results of field sampling and analysis around the identified SWMUs and AOC.” DEQ further stated that “with respect to SWMUs A, B, C, D, and the Dredge Pond Area of Concern (AOC‐1), the Oklahoma DEQ determined that no further remediation or corrective action is required.”

Holly has decided to include this investigation in the new Permit and will assure for the costs beginning in 2012

Unable to be investigated until the Waste Water Treatment Plant is taken out of permanent service or the refinery ceases operationInvestigation of SWMU‐F unable to be performed unless the refinery ceases operation or the naphtha hydrotreater and associated units are taken out of permanent service

Investigation of SWMU‐G unable to be performed unless the refinery ceases operation or the Alky Unit is taken out of permanent service




JULY 2011 CONSENT ORDER