HRS DOCUMENTATION RECORD

REVIEW COVER SHEET

Name of Site: Wilcox Oil Company

CONTACT PERSONS

Site Investigation: Brenda Nixon Cook, EPA Region 6 (214) 665-7436 

(Name) (Telephone) 

Documentation Record: Brenda Nixon Cook, EPA Region 6 (214) 665-7436 

(Name) (Telephone) 

Pathways, Components, or Threats Not Evaluated 

1) Ground Water Pathway: The ground water migration pathway was evaluated but has 

not been scored. Private water wells have shown elevated levels of metals (Ref. 5, p. 10). 

Based on information available at this time, further evaluation of the ground water 

migration pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3). 

2) Surface Water Pathway: Ground Water to Surface Water Migration Component: 

The Surface Water Pathway has been scored for the Human Food Chain Threat and 

Environmental Threat. The Ground Water to Surface Water Migration pathway has not 

been scored. Based on information available at this time, evaluation of this component 

would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

3) Air Migration Pathway: The air migration pathway has not been scored because an 

observed release to the air migration pathway has not been documented and there are no 

analytical data to support a release. Based on information available at this time, 

evaluation of the air migration pathway would not significantly affect the listing decision 

(Ref. 1, Sec. 2.2.3).

4) Soil Exposure Pathway: The soil exposure pathway has not been scored. Observed 

contamination has been documented on or within 200 feet of soil pathway targets, but 

based on information available at this time, further evaluation of the soil exposure 

pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3). 

These pathways and components are of concern to the U.S. Environmental Protection 

Agency (EPA) and may be considered during a future evaluation. 
1

HRS DOCUMENTATION RECORD

Name of Site: Wilcox Oil Company

CERCLIS Number: OK0001010917 

Site Spill Identifier Number (SSID): 06GG 

EPA Region: 6 Date Prepared: May 2013 

 

Street Address of Site*: West 221st Street South/Refinery Road, 0.35 mile east of 

U.S. Highway 66 (Ref. 5, p. 5, Fig.1 of this HRS 

documentation record) 

County and State: Creek County, OK, 74010 

General Location in the State: The site is located northeast of the City of Bristow in the 

central portion of the state (Fig. 1 of this HRS 

documentation record).

Topographic Map: Bristow Quadrangle, OK (Ref. 3) 

Latitude*: 35°50'26.8966” N Longitude*: 96°22'48.693" W (Ref. 5, p. 4) 

Air Pathway Not Scored

Ground Water Pathway Not Scored

Soil Exposure Pathway Not Scored

Surface Water Pathway 100.00 

HRS SITE SCORE 50.00 

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area 

the site is located. They represent one or more locations EPA considers to be part of the site based on the screening information 

EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known "releases or threatened releases" of 

hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a 

hazardous substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring and the 

subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under 

CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be 

refined as more information is developed as to where the contamination has come to be located. 
2

NOTES TO THE READER

Tracking numbers are assigned by the region to every page of every reference. The tracking 

number consists of the reference number followed by the page number within that reference. A 

tracking number will have a two-digit number followed by the sequential number (for example, 

05 001; 05 002). 

The following rules were used when citing references in the HRS (Hazard Ranking System) 

package.

1. The tracking numbers are cited for all references.

2. Hazardous substances are listed by how they appear in the Superfund Chemical Data 

Matrix (SCDM).

3. Significant figures: Calculations are reported to two significant figures to the right of the 

decimal place when the HRS does not specify rounding. 

4. Abbreviations/Conventions used to identify references and citations: 

Figure Fig. 

Number No.

Reference Ref. 

Section Sec.

Single Pages p. 

Multiple Pages pp. 

“.” Next Reference 

() Selected acronyms 

5. List of Figures

Figure 1 Facility Location Map

Figure 2 Facility Sketch 

Figure 3 Sample Location Map

Figure 4 Background, Source, and Contaminated Sample Location Map 

Figure 5 Probable Point of Entries (PPEs) for Surface Water Migration Pathway 

Figure 6 Surface Water Pathway Map 

6. Parent Site Wilcox Oil Company

7. Child Sites Lorraine Refinery, CERCLIS No. OKN000606909 
3

ACRONYMS

BGS Below Ground Surface

CERCLA Comprehensive Environmental Response, 

Compensation, and Liability Act

CFS Cubic Feet Per Second 

ESI Expanded Site Inspection 

HWD Hazardous Waste Division 

HRS Hazard Ranking System

mg/kg milligrams per kilogram

NPDES National Pollutant Discharge Elimination 

System

NGV National Geodetic Vertical Datum

NWI National Wetlands Inventory 

OFS Overland Flow Segment 

ODEQ Oklahoma Department of Environmental 

Quality

PAH Polynuclear Aromatic Hydrocarbon

PPE Probable Point of Entry 

RA Removal Assessment

RL Reporting Limit

RPB Response and Prevention Branch 

RCRA Resource Conservation and Recovery Act of 

1976 

RSD Remediation Services Division

START Superfund Technical Assessment and 

Response Team

SA Site Assessment

SI Site Inspection 

SCDM Superfund Chemical Data Matrix

SSID Site Spill Identifier Number

TAL Target Analyte List

TAT Technical Assistance Team

TCL Target Compound List

TDL Target Distance Limit

ug/kg Micrograms per kilogram 
!"#$

LWSS-9 LWGW-9

^

Figure 1. Facility Location Map, Wilcox Oil Company

Bristow, Oklahoma

0 1,250 2,500 5,000Feet

Oklahoma

± CERCLIS ID No. OK0001010917

44

Legend

Facility Boundary

Lorraine Refinery Boundary

Wilcox Oil Co. Refinery Process Area

Source: 2009 National Geographic Society; (topographic quadrangle: Bristow, 1973 and Slick, 1973, Oklahoma) Streams

Wilcox Oil Co. 

Oil Tank Storage Area

1:24,000
^ 0 250 500 1,000

Feet

Oklahoma ±

CERCLIS ID No. OK0001010917

1:5,500

Bing Maps Aerial Imagery, National Agriculture Imagery Program, and 1923 Certified Sanborn MapAnnotated by START

(((

(

( (

(

(

( (

( (

West 

Tr

i

butary

San

d

Creek

Wilcox O

Legend

Property BoundaLorraine Refinery Wilcox Oil Co. RProcess Area

Perennial StreaIntermittent Str

Source No. 8

Source No. 5

Central Tributary

Figure 2. Facility Sketch, Wilcox Oil Company

Bristow, Oklahoma

Source No. 1

Source No. 6

Source No. 4

Source No. 2

Source No. 9

Source No. 3 Source No. 7

Source No. 10
^

Figure 3. Sample Location Map

Wilcox Oil Company, Bristow, Oklahoma

0 5 250 00 1,000

Feet

Oklahoma

±

CERCLIS ID No. OK0001010917 1:5,500

West Tributary

Sand Creek

Source: Bing Maps Aerial Imagery, National Agriculture Imagery Program, and 1923 Certified Sanborn Map

Source No. 11

(

((

(

(

(

(

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(

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(

(

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*#

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!(

!(

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!(

!(

!(

*#

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!(

!(

!(

!(

*#

*#

*#

SED-2

LSS-4

W-9

W-8

W-7

W-4

W-2 W-3

W-1

LSD-5

LSD-2

LWW

LWW-5

LWW-1

SED-7

SED-3

LWSS-8

LWSS-6 LWSS-7

LWSS-5

LWSS-4

LWSS-3

SED-14

SED-13

SED-12

SED-11

W-5 (6)

LWW-3 (4)

SED-4 (5)

LWSS-1 (2)

West Tributary

Legend

Lorraine RefWilcox Oil Co

Former Cooling Pond

Sand Creek

*# Sediment

!( Waste

*# Surface Soil

( Former Tank 

Source No. 1

Central Tributary

Source No. 5

Source No. 4

Source No. 2

Source No. 8

Source No. 3 Source No. 7

Source No. 10

Source No. 6

Property Bou

PPE-1
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*# *#

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LWSS-9

LSD-5

SED-7

LSD-2

W-1

W-9

SED-14

W-7 W-5 (6)

W-4

W-2 W-3

SED-4 (5)

SED-13

SED-11

SED-3

SED-2

SED-12

LWSS-8

LWW-1

LWW-6

LWW-3 (4)

W-8

LWW-5

LWSS-3 LWSS-4

LWSS-1 (2)

LWSS-5

LWSS-6 LWSS-7

LSS-4

^

Figure 4. Background, Source, and 

Contaminated Sample Location Map

Wilcox Oil Company, Bristow, Oklahoma

Oklahoma

San

d

Creek

West Tributary

0 300 600 900 1,200 150

Feet

CERCLIS ID No. OK0001010917 1:9,000 ± Source: Bing Maps Aerial Imagery, National Agriculture 

Imagery Program, and 1923 Certified Sanborn Map

Source No. 8

Source No. 7

Source No. 3

Source No. 9

Source No. 4

Source No. 6 Source No. 5

Source No. 1

Source No. 2

Source No. 10

Legend

Perennial Stream

Intermittent Stream

Former Cooling Pond

( Former Tank Bottoms

*# Sediment

!( Waste

*# Surface Soil

Property Boundary

Lorraine Refinery

Wilcox Oil Co. 

Refinery Process Area

Sample locations from 

Ref. 5, pp. 25-26; 

Ref. 7, p. 8; Ref. 9, pp.24-26; 

and Ref. 16, p.22.

East Tributary

Background Surface Soil

Sample Location

Central 

Tributary

PPE-1
^

Figure 5. Probable Point of Entries (PPEs) for

Surface Water Migration Pathway

Wilcox Oil Company, Bristow, Oklahoma

0 250 500 1,000

Feet

Oklahoma

±

CERCLIS ID No. OK0001010917 1:5,500

(

((

(

(

(

(

(

(

(

(

(

(

(

(

*#

*#

*#

*#

*#

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!(

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PFO1A W-9

W-8

W-7

W-4

W-3 W-2

W-1

LSS-4

LSD-5

LSD-2

LWW

LWW-5

LWW-1

SED-7

SED-3

LWSS-8

LWSS-6 LWSS-7

LWSS-5

LWSS-4

LWSS-3

SED-14

SED-13

SED-12

SED-11

W-5 (6)

LWW-3 (4)

SED-4 (5)

LWSS-1 (2)

West Tributary

Sand Creek

Source: Bing Maps Aerial Imagery, National Agriculture Imagery Program,1923 Certified Sanborn Map, and U.S. Fish & Wildlife Service National Wetlands Inventory

Source No. 6

Legend

*# Sediment

!( Waste

*# Surface Soil

( For

Lorra

WilcoProc

Form

Property Boundary

Level II Segment

Source No. 1

Source No. 5

Source No. 4

Source No. 8

Source No. 2

S

Source No. 3 Source No. 7

Source No. 10

PPE No. 3

PPE No. 2

Central Tributary

Potential Contamination Segment Begins

PPE-1
^

Figure 6. Surface Water Pathway Map

Wilcox Oil Company

Bristow, Oklahoma

Oklahoma

0 0 0.25 .511.5 2

Miles

CERCLIS ID No. OK0001010917

±

1:60,000

Legend

Facility Boundary

15 Miles Downstream

Wetland

Source: Bing Maps Aerial Imagery, National Agriculture Imagery Program, 

1923 Certified Sanborn Map, and U.S. Fish & Wildlife Service National Wetlands Inventory

Segment Length (ft)

PPE-1 to PPE-2 1,629

PPE-2 to PPE-3 1,176

PPE-3 to PPE-4 2,048

PPE-4 to Little Deep Fork Creek 16,309

Little Deep Fork Creek to TDL-1 51,175

Total Distance 72,337

Little Deep Fork Creek Begins

Sand Creeek

Site Location

Level II Segment

PPE-1

PPE-3

PPE-2

PPE-4

Fishery

15-Mile TDL-3

15-Mile TDL-1

15-Mile TDL-2

15-Mile TDL-4

Potential Contamination

West Tributary

East Tributary

Central Tributary
10

WORKSHEET FOR COMPUTING HRS SITE SCORE

s s2

1. Ground Water Migration Pathway Score (S w) NS NS

 (from Table 3-11, line 13) 

2a. Surface Water Overland/Flood Migration Component 100 10,000 

 (from Table 4-11, line 30) 

2b. Ground Water to Surface Water Migration Component NS NS

 (from Table 4-25, line 28) 

2c. Surface Water Migration Pathway Score (ssw) 100 10,000 

 Enter the larger of the line 2a and 2b as the pathway score 

3. Soil Exposure Pathway Score (ss) NS NS

 (from Table 5-1, line 22) 

4. Air Migration Pathway Score (sa) NS NS

5. Total of S 2

gw +S 2 sw +S 2s +S 2a 10,000 

6. HRS Site Score: Divide the value on line 5 by 4 and take the 50.00 

square root. 

 

NS = Not Scored 
Score Sheets

11

Table 4-1 Surface Water Overland/Flood Migration Component Score Sheet 

Factor Categories and Factors Maximum Value Value Assigned

DRINKING WATER THREAT

Likelihood of Release

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

2a. Containment 10

2b. Runoff 25

2c. Distance to Surface Water 25

2d. Potential to Release by Overland Flow

 (Lines 2a[2b+2c]) 500 NS

3 Potential to Release by Flood:

3a. Containment (Flood) 10

3b. Flood Frequency 50

3c. Potential to Release by Flood

 (Line 3a X 3b) 500 NS

4. Potential to Release

(Lines 2d + 3c, subject to a maximum of 

500) 500 NS

5. Likelihood of Release

(Higher of Lines 1 and 4) 550 550 

NS

Waste Characteristics

6. Toxicity/Persistence *

7. Hazardous Waste Quantity *

8. Waste Characteristics 100 NS

Targets

9. Nearest Intake 50 NS

10. Population:

10a. Level I Concentrations ** NS

10b. Level II Concentrations ** NS

10c. Potential Contamination ** NS
Score Sheets

12

Factor Categories and Factors Maximum Value Value Assigned

10d. Population (Lines 10a+10b+10c) ** NS

11. Resources 5 NS

12. Targets (Lines 9+10d+11) ** NS

Drinking Water Threat Score

13. Drinking Water Threat Score

([Lines 5 x 8 x 12]/82,500, 

subject to a maximum of 100) 100 NS

HUMAN FOOD CHAIN THREAT

Likelihood of Release

14. Likelihood of Release

(Same value as Line 5) 550 550

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation * 1x1012

16. Hazardous Waste Quantity * 10,000

17. Waste Characteristics 1,000 1,000

Targets

18. Food Chain Individual 50 20

19. Population:

19a. Level I Concentrations ** 0

19b. Level II Concentrations ** 0

19c. Potential Contamination ** 0.00003

19d. Population (Lines 19a+19b+19c) ** 0.00003

20. Targets ** 20.00003

(Value from Lines 18+19d)

Human Food Chain Threat Score

21. Human Food Chain Threat Score 100 100

([Lines 14 x 17 x 20]/82,500,

subject to a maximum of 100)

ENVIRONMENTAL THREAT

Likelihood of Release

22. Likelihood of Release

(Same value as Line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence/ 

Bioaccumulation * 1 x 1012

24. Hazardous Waste Quantity * 10,000
Score Sheets

13

Factor Categories and Factors Maximum Value Value Assigned

25. Waste Characteristics 1,000 1,000

Targets

26. Sensitive Environments:

26a. Level I Concentrations ** 0

26b. Level II Concentrations ** 25

26c. Potential Contamination ** 0

26d. Sensitive Environments 

(Lines 26a+26b+26c) ** 25 

27. Targets

(Value from Line 26d) ** 25

Environmental Threat Score

28. Environmental Threat Score

([Lines 22 x 25 x 27]/82,500subject to a 

maximum of 60) 

60 60

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A 

WATERSHED

29. WATERSHED SCORE***

(Lines 13 + 21 + 28, subject to a maximum 

of 100) 

100 100

30. Component Score (S of)***

(Highest score from Line 29 for all 

watersheds evaluated, subject to a 

maximum of 100) 

100 100

*Maximum value applies to waste characteristic category

**Maximum value applicable

***Do not round to the nearest integer
Reference Sheet

14

Reference 

Number Description of the Reference

1. U.S. EPA Hazard Ranking System (HRS); Final Rule. Code of Federal Regulations, Title 

40, Part 300, Appendix A. Washington, DC: U.S. Government Printing Office, 2000. A 

complete version of this document is available online at: 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm. Total Pages: 5

2. U.S. EPA. Superfund Chemical Data Matrix. Appendix B. December 2, 2011. A 

complete version of SCDM is available at: 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm . Excerpt Pages: 50 

3. U.S. Geological Survey (USGS). 15-Minute Series Topographic Map. Bristow, 

Oklahoma. 1973. Total Pages:1 

4. U.S. EPA, Office of Solid Waste. Associated Waste Report: Crude Oil Bottoms and Oily 

Debris. January 2000. Total Pages: 173 

5. Oklahoma Department of Environmental Quality (ODEQ), Site Assessment Unit. 

Expanded Site Inspection Report for Wilcox Refinery. September 30, 2011. Total Pages: 

55 

6. ODEQ, State Environmental Laboratory. Report of Analysis by Metal Laboratory. Report 

of Analysis by Gas Chromatograph with Mass Spectrometer Detection (GCMS) 

Laboratory. Analysis Date: June 2011. Document Date: September 2011. Total Pages: 

170 

7. ODEQ, Land Protection Division. Supplemental Sampling Report Expanded Site 

Inspection for Wilcox Refinery. Total Pages: 15 

8. ODEQ, State Environmental Laboratory. Data Package Wilcox. Report of Analysis by 

Metal Laboratory. Report of Analysis by Gas Chromatograph with Mass Spectrometer 

Detection (GCMS) Laboratory. Sample Date: December 2011. Document Date: March 

2012. Total Pages: 69

9. ODEQ, Site Assessment Unit. Expanded Site Inspection Report for Lorraine Refinery. 

September 29, 2010. Total Pages: 336 

10. ODEQ, State Environmental Laboratory. Data Package Lorraine. Report of Analysis by 

Metal Laboratory. Report of Analysis by Gas Chromatograph with Mass Spectrometer 

Detection (GCMS) Laboratory. Date: June-July 2010. Total Pages: 240 

11. Downham, T., ODEQ. Memorandum: Site Reconnaissance for the Former Wilcox 

Refinery in Bristow, Creek Co., Oklahoma. June 17, 2011. Total Pages: 2 
Reference Sheet

15

12. ODEQ. Preliminary Assessment of the Wilcox Refinery, Creek County, Oklahoma. 

December 15, 1994. Total Pages: 25 

13. Roy F. Weston, Inc. Prepared for U. S. Environmental Protection Agency. Expanded Site 

Inspection Report, Wilcox Oil Company, Bristow, Creek County, Oklahoma. March 

1997. Total Pages: 68

14. Ecology and Environment, Inc. Prepared for U. S. Environmental Protection Agency. Site 

Assessment Report, Wilcox Refinery, Bristow, Creek County, Oklahoma. March 1999. 

Total Pages: 150

15. ODEQ. Preliminary Assessment Report, Lorraine Refinery, Bristow, Creek County, 

Oklahoma. September 28, 2008. Total Pages: 32 

16. ODEQ. Site Inspection Report, Lorraine Refinery, Bristow, Creek County, Oklahoma. 

August 18, 2009. Total Pages: 278 

17. Reference number reserved.

18. Environmental Data Resources. Certified Sanborn® Map Report for Wilcox/Lorraine 

Refinery. May 1, 2012. Total Pages: 6

19. ODEQ. State Environmental Laboratory. Quality Assurance Plan. State Fiscal Year 2010. 

February 15, 2010. Total Pages: 9

20. ODEQ. Wilcox Refinery ESI, Site ESI Field Logbook. June 28- 29, 2011. Total Pages: 

14 

21. ODEQ. Site Inspection and Analysis Plan, Wilcox Refinery ESI, Creek County, 

Oklahoma. June 8, 2011. Total Pages: 45 

22. ODEQ. Site Inspection and Analysis Plan, Lorraine Refinery, Creek County, Oklahoma. 

May 31, 2010. Total Pages: 46 

23. ODEQ. Lorraine Refinery ESI, Site SI Field Logbook. June 8- 9, 2010. Total Pages: 2 

24. Downham, T., ODEQ. Memorandum: Changes from Wilcox ESI Sampling and Analysis 

Plan (SAP) during the Sampling Event. July 15, 2011. Total Pages: 1 

25. Dynamac Corporation. Record of Communication. From: START-3, To: Fish and Game 

Warden, Creek County, Oklahoma. Subject: Fisheries within 15-mile TDL of Wilcox 

Refinery. May 11, 2012. Total Pages: 1
Reference Sheet

16

26. USDA. Average Annual Precipitation for Oklahoma for 1961-1990. Available online at: 

http://www.wrcc.dri.edu/pcpn/ok.gif . Downloaded: January 24, 2013. Total Pages: 1 

27. Reference number reserved.

28. EPA Region 6, GIS Support. Historical Aerial Photographs Wilcox 1954, 1972, 1980, 

and 1995. Downloaded April 26, 2012. Total Pages: 8 

29. USGS. Water-Data Report 2010 for 07243500 Deep Fork Near Biggs Oklahoma. U.S. 

Geological Survey, 2012, Water-resources Data for the United States, Water Year 2011: 

U.S. Geological Survey Water-Data Report WDR-US-2011, Site 07243500. Available 

online at: http://wdr.water.usgs.gov/wy2011/pdfs/07243500.2011.pdf . Total Pages: 3 

30. United States Department of Interior. National Wetland Inventory Maps. Bristow, 

Oklahoma, Aerial Photography 1980 and Slick, Oklahoma, 1980. Total Pages: 2 

31. ODEQ. Sampling and Analysis Plan for Lorraine Sampling Inspection. March 24, 2009. 

Total pages: 39 

32. U.S. EPA. Memorandum. To: J. Winston Porter, EPA Assistant Administrator. From: 

Francis S. Blake, General Council. Subject: Scope of the CERCLA Petroleum Exclusion 

under Sections 101(14) and 104(a)(2). July 31, 1987. Total Pages: 11 

33. ODEQ. Memorandum. To: Lorraine PA File. From: Vanessa Peterson. Subject: Current 

Ownership of (Lorraine Refinery), Potentially Responsible Parties (PRPs) Search and 

Site Reconnaissance. September 12, 2008. Total Pages: 46 

34. ODEQ. Memorandum. To: Wilcox/Lorraine File. From: Todd Downham. Subject: 

Locations and Physical Descriptions of Soil and Sediment Sampling. September 24, 

2012. Total pages: 4 

35. ODEQ. Memorandum. To: Wilcox/Lorraine File. From: Todd Downham. Subject: 

Clarification of Waste Sampling. October 4, 2012. Total pages: 1

36. U.S. District Court. U.S. vs. Western Processing Co., Inc. 761 F. Supp. 713 (1991). 

Available online at: 

http://www.leagle.com/xmlResult.aspx?xmldoc=19911486761FSupp725_11354.xml&do

cbase=CSLWAR2-1986-2006 . Downloaded: August 27, 2012. Total pages: 10 

37. U.S. Court of Appeals for the Ninth Circuit. Cose vs. Getty Oil, 4 F. 3d 700. April 13, 

1993.Total pages: 9 

38. U.S. Fish and Wildlife Service. Wetlands and Deepwater Habitats Mapping Codes. Table 

Revised June 23, 2010. Downloaded from 
Reference Sheet

17

http://www.fws.gov/wetlands/Documents/Wetlands-and-Deepwater-HabitatsClassification-chart.pdf . Total pages: 2 

39. ODEQ, Land Protection Division. Quality Assurance Project Plan for Site Assessment 

Unit. Scope of Work FFY 2009 State of Oklahoma Department of Environmental Quality 

Land Protection Division Site Remediation Section Site Assessment Unit Quality 

Management Plan EPA QTRAK # 08-148. August 29, 2008. Total Pages: 125

40. ODEQ. Quality Management Plan for State FY 2010-2011. October 12, 2009. Total 

Pages: 155
18

Site Description and History:

Wilcox Oil Company is an inactive and abandoned oil refinery located in Creek County, 

Oklahoma. The site consists of contaminated areas and surface water bodies due to the release 

from the former Lorraine and former Wilcox Refineries. These refineries were located in the N 

1⁄2 of the NW 1/4 of S29 T16N R9E and the SW 1/4 of the SW 1⁄4 of S20 T16N R9E in Creek 

County, Oklahoma (Ref. 5, pp. 4, 5). The location of the releases from the two refineries are 

considered to be a single site composed of a commingled release from the combined refinery 

operations threatening the same targets. The release from the two refineries is comingled and /or 

the contamination is contiguous. The Wilcox Oil Company site is composed of a release from the 

combined facility operations. 

The geographical coordinates for the site are 35°50’26.8966” north latitude and 96°22’48.693” 

west longitude (Ref. 5, p. 4). The property covers approximately 125 acres (Ref. 3; Ref. 5, pp. 4, 

5, 23; Figure 1 of this HRS Documentation Record).

Two refinery process facilities and storage tank areas once operated at the two facilities. Recent 

investigations (2009-2011) indicate the site area contains elevated concentrations of metals and 

organic compounds in the former storage tank areas, surface soils, surface impoundment and 

sediments. Elevated levels of metals were also detected in three private residential wells on site, 

and from three wells adjacent to the property (Ref. 5, pp. 5 – 12, 17-22; Ref. 18).

Wilcox Oil Company (Wilcox) operated as a crude oil refinery from the 1920s until 1963. A 

skimming and cracking plant was constructed in 1929. The main components of the plant 

consisted of a skimming plant, cracking unit, and redistillation battery with a vapor recovery 

system and treatment equipment (Ref. 12, pp. 3, 5). 

The Wilcox Oil Company expanded when it acquired the Lorraine Refinery in 1937, which was 

located west of the railroad (Figure 1 of this HRS documentation record; Ref. 33, pp. 2, 3). Oil 

refining began in 1915 at the Lorraine Refinery (Ref. 33, p.2). Wilcox sold the property to a 

private individual in 1963 (Ref. 13, p. 3). Most of the equipment and storage tanks were 

auctioned or salvaged for scrap metal by the new property owners. Wilcox Oil Company no 

longer operates in Oklahoma. Based on information from the Oklahoma Secretary of States’ 

office, the company merged with Tenneco Oil Company in 1967 (Ref. 13, p. 15). 

A church and six residents are presently on the facility (Ref. 5, p. 13). 

A large volume of visible waste is present where refined product and crude oil storage tanks 

were once located (Ref. 15, pp. 3, 5, 6; Ref. 33, p. 5; Ref. 35). Approximately 4 inches of crude 

oil were discovered on a church property when a cap broke off an existing pipeline. Hydrocarbon 

sheen was visible when digging 2-3 feet below ground surface (Ref. 33, p. 4). Elevated levels of 

metals and semi-volatiles are present in waste samples collected (Tables 3 and 4 of this HRS 

documentation record). 
19

The site includes remnants of former oil refining operations and tank farms. The facility can be 

divided into three major former operational areas: two processing areas with surrounding refined 

product storage and a crude oil storage area. An active railroad divides the two former 

processing areas and product storage areas (Ref. 18, pp. 1-4). Most of the refinery structures and 

tanks have been removed or are in ruins. The northwestern portion of the property, west of the 

railroad and north of West 221st Street South/Refinery Road, was used as a refined product 

storage area but is now rural land no longer used for refinery storage purposes. There are

multiple areas of stressed vegetation, barren areas, and visible black tarry waste of a 

hydrocarbon nature (Ref. 11, pp. 1-2; Ref. 33, pp. 3, 4, 5).

The southwestern portion of the property, south of Refinery Road, west of the railroad had a 

processing area and refined product storage. The First Assembly of God Church, 

playground, and one residence are located where processing and storage occurred. There are 

multiple areas of stressed vegetation, barren areas, and visible black tarry waste (Ref. 11, pp. 

1, 2; Ref. 15, pp. 2, 3). 

East of the railroad was a processing area and refined product storage areas. Several refined 

product storage tanks, refinery-related debris, dilapidated buildings, and structures remain on 

the property. There is one residence in this portion of the property. An intermittent stream (West 

Tributary) marks the eastern extent of the processing and refined product storage area east of 

the railroad. This tributary runs north to south and flows into Sand Creek to the south. There are 

multiple areas of stressed vegetation, barren areas, and visible black tarry waste (Ref. 11, pp. 1, 

2).

To the east of the West Tributary is a former large crude oil storage area/tank farm. There are 

four residences located on top of or directly next to former tank locations. There are multiple 

areas of stressed vegetation, barren areas, and visible black tarry waste of a hydrocarbon nature. 

Waste was also observed in several drainage channels that empty into Sand Creek (Ref. 11, pp. 

1, 2). 

There are a total of six residences on the property, all of which are located on former tank or 

refinery operations locations. Three of the residences located on the eastern portion of the 

property are known to use water from domestic/private wells located on site. The drainage 

pattern of the property is primarily towards Sand Creek that follows the western and 

southwestern boundaries of the property. Two intermittent streams and several drainage 

channels cross the portion of the property east of the railroad, both of which flow into Sand 

Creek (Ref. 11, pp. 1, 2). 

A detailed title search in the Creek County Clerk office confirms that the property was used in 

oil refinery operations from 1915 until November 1963. Access to the property is not controlled

(Ref. 15, pp. 3, 4). Portions of the property are fenced (Ref. 12, p. 4). There are no schools or 

day care centers located within 200 feet of the site (Ref. 15, p. 3) . 

The Wilcox Oil site consists of a former cooling pond, former tank bottoms, and the associated 

releases of polynuclear aromatic hydrocarbons (PAHs) and metals to the nearby wetlands and 
20

Sand Creek (Ref. 18, pp. 3, 4; Table 9 of this HRS documentation record). 

Leaded tank bottoms are specifically listed as RCRA K052 waste and are CERCLA hazardous 

substances (Ref. 14, pp.1-8). In the definition of hazardous substances, Section101(14) of 

CERCLA provides that “[t]he term does not include petroleum, including crude oil or any 

fraction thereof which is not otherwise specifically listed or designated as hazardous substance 

under subparagraph (A) through (F) of this paragraph...”. This provision has been termed the 

“petroleum exclusion”. In the EPA General Counsel’s Opinion Scope of the CERCLA Petroleum 

Exclusion under Sections 101(14) and 104(a) (2) (July 31, 1987), the EPA interprets the 

petroleum exclusion to include hazardous substances such as benzene and toluene, which are 

“indigenous” to petroleum products. The petroleum exclusion also includes “refinery-added” 

hazardous substances that are normally mixed with or added to crude oil or crude oil fraction 

during the refining process. Conversely, “contaminants” found in petroleum or petroleum 

products do not fall within the petroleum exclusion. “Contaminants” include substances which 

are not indigenous to petroleum products or which are present at levels that exceed those 

normally found in petroleum products (Ref. 14, pp.1-8). 

In its decision in US v. Western Processing (1991), the federal district court concluded that “tank 

bottom sludge is a contaminated waste product, and not a petroleum fraction, as that term is used 

in [CERCLA].” In so ruling, the court focused in part on the tank bottom’s status as “waste” in 

contrast to a useful petroleum product, which would be considered a petroleum fraction under 

CERCLA (Ref. 36, pp. 1-10). In Cose v. Getty Oil (1993), the U.S. 9th Circuit of Appeals 

concluded “crude oil tank bottoms are never ‘subjected to various refining processes’; as 

required by our ‘petroleum’ definition. Moreover, such tank bottoms are not used ‘for producing 

useful products’...” and “crude oil tank bottoms do not fall within CERCLA’s exclusion of 

‘petroleum’, including crude oil or a fraction thereof” (Ref. 37, pp. 1-9). In addition, the circuit 

court of appeals also found it unnecessary to determine whether the level of lead in the refinery 

sludge exceeded levels indigenous to petroleum products such as leaded gasoline (Ref. 32, pp. 1-

11). 

A summary of sampling activities conducted at the facility is provided in Table 1:
21

Table 1- Summary of Investigations

Investigation Agency/Company Date Findings/Summary Ref. No.

Preliminary 

Assessment- Wilcox 

Oil Company

ODEQ for EPA Dec 1994 Oil waste and sludge observed on residential yards. 12, pp. 1, 4, 6, 7, 14, 22, 

25

Expanded Site 

Inspection – Wilcox Oil 

Company

Roy F. Weston, 

Inc. for EPA

Mar 1997 Oily, tarry, black-asphalt materials observed in the former bermed 

areas. Contaminated soil, and contaminated sediments detected in 

ponds. Copper and lead detected in Sand Creek sediments.

13, pp. 1, 28-32, 37, 40

Site Assessment -

Wilcox Refinery

Ecology & 

Environment, Inc. 

for EPA

Mar 1999 Approximately 73,000 cubic yards of oily waste and contaminated 

soil and 3,000 gallons of liquid waste identified.

14, pp. 1, 45

Preliminary Assessment 

– Lorraine Refinery

ODEQ for EPA Sept 2008 Church and residence located on former refinery operations. No 

sampling conducted.

15, pp. 1, 2, 3, 5, 14, 16, 

24, 26

Site Inspection –

Lorraine Refinery

ODEQ for EPA Aug 2009 LS series of soils (LSS) on Lorraine facility and sediments (LSD) 

from Sand Creek. Soil contamination and observed release in Sand 

Creek sediments documented.

16, pp. 1, 7, 12, 13

SAP/QAPP Data

31; 39; 40 16, pp. 

70 - 

258

Expanded Site 

Inspection – Lorraine 

Refinery

ODEQ for EPA Sept 2010 LW series of soil (LWSS) and waste (LWW) samples collected at 

Wilcox facility from tank farm and residential yards. Metals and 

SVOCs detected in waste and soil samples.

9, pp. 1, 6, 7, 11-12; 23

SAP/QAPP Data

19; 22 10

Expanded Site 

Inspection – Wilcox Oil 

Company

ODEQ for EPA Sept 2011 SS series of soil samples collected at Wilcox Refinery property and 

W series of waste samples collected from tank farm. SED series of 

sediment samples from tributaries and Sand Creek. Metals and 

SVOCs detected in waste and soil samples and metals detected in 

sediments.

5, pp. 1, 12, 15; 23

SAP/QAPP Data 

19; 21; 24 6

Supplemental ESI –

Wilcox Oil 

ODEQ for EPA Dec. 2011 SED series of samples collected from tributary and Sand Creek.

Metals detected in sediments.

7, pp. 1, 3, 5, 6

SAP/QAPP Data

19; 21 8

Key: ESI: Expanded Site Inspection; ODEQ-Oklahoma Department of Environmental Quality; SAP-Sampling and Analysis Plan; QAPP-Quality Assurance Project Plan
SO-Source Characterization

Source No.: 1 

22

SOURCE DESCRIPTION

2.2 SOURCE CHARACTERIZATION

Source characterization for the Wilcox Oil Company site includes identification of the sources, 

hazardous substances associated with the sources and pathways potentially threatened by the 

hazardous substances. There are 10 sources evaluated at the Wilcox Oil Company site, for HRS 

purposes: 

Source No. 1- Cooling Pond 

Source Nos. 2-10: Tank Bottoms 

The first source evaluated is: 

 

• Source No. 1: Cooling Pond 

2.2.1 Source 1 Identification

Number of the source: Source No. 1 

Name and description of the source: Cooling Pond (surface impoundment (buried/backfilled) 

Source No. 1, a surface impoundment, is located on the east side of the former process and 

refinery areas at the Lorraine Refinery (Ref. 18, pp. 1-6; Figs. 2 and 3 of this HRS 

documentation record). The area in the vicinity of the surface impoundment contained a cooling 

tower, stills and storage tanks (Ref. 18, pp. 1-6). A church and parking lot near the surface 

impoundment are now located where the former refinery operations were conducted (Ref. 16, pp. 

5, 6; Figure 2 of this HRS documentation record). 

The contamination associated with Source No. 1 was based upon analytical results from the 

ODEQ Site Inspection (SI) (August 2009) (Ref. 16, pp. 6, 12, 13, and 25; Table 5 of this HRS 

documentation record). Sampling was conducted following the procedures set forth in the 

Quality Assurance Project Plan (QAPP) (Ref. 39) and the approved DEQ Quality Management 

Plan (QMP) for State fiscal year 2009-10, EPA QTRAK # 09-039 (Ref. 40). 
SO-Source Characterization

Source No.: 1 

23

•Location of the source, with reference to a map of the site: 

Source No. 1 is located on the eastern side of the former process and refinery areas of the 

Lorraine Refinery (Ref. 18, pp. 1-6) (Figs. 2 and 3 of this HRS documentation record). The 

sample that was used to define Source No. 1 is LSS-4 (Table 2 of this HRS documentation 

record).

•Source Type for HRS evaluation purposes: Surface Impoundment (buried/backfilled) 

•Containment 

Gas release to air: The air migration pathway was not scored; therefore, gas release to 

air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, 

particulate containment was not evaluated.

Release to ground water: The ground water migration pathway was not scored; 

therefore, ground water containment was not evaluated. 

Release via overland migration and/or flood: There is no documentation or evidence to 

indicate that Source No. 1 had a maintained run-on control system or runoff management 

system, or an engineered cover. There is also no evidence of any runoff treatment (Ref. 5, 

pp. 8, 31-54; Ref. 18, pp. 1-6). The containment factor value for Source No. 1 is 10 (Ref. 

1, Table 4-2).

2.2.2 Hazardous Substances Associated with a Source 

The substances listed in the following pages were present in the sample collected during the 

2009 Lorraine Site Inspection from the waste in the former cooling pond (Ref. 16). 

The sample contained arsenic, chromium, copper, lead, nickel, and zinc at concentrations equal 

to or greater than their corresponding reporting limits (RLs) and waste was evident during 

sample collection (Ref. 16, p. 17; Table 3 of this HRS documentation record). The sample was

analyzed for semivolatiles and metals ( Ref. 16, pp. 70, 125).
SO-Source Characterization

Source No.: 1 

24

Table 2 - Source Evidence Sample

Sample ID/SEL No. Depth

Soil 

Description Date Reference

LSS-4/ 462168 0 to 24 

inches

Light 

brown 

sandy

April 22, 

2009 

Ref. 16, pp. 17, 70, 125; 

Ref. 34; Figure 3 of this 

HRS documentation record 

Table 3- Source No. 1 Evidence 

Hazardous 

Substance 

Sample No. LSS-4 / 

SEL # 462168 

Collection date: 

4/22/2009

Conc.

(mg/kg) RL (mg/kg)

Arsenic 1.50 1 

Chromium 4.90 1 

Copper 7.80 1 

Lead 513 1

Nickel 6.70 1 

Zinc 16.7 1 

Chain of 

Custody Ref. 16, p. 70 

Laboratory 

Reports 

(including 

Form Is)

Ref. 16, p. 125 

Other 

Supporting 

References

Fig. 3 of this HRS 

documentation record

Key:

Bold- Sample Concentration is greater than RL

Conc.- Concentration

SEL – State Environmental Laboratory

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant 

concentration at which a laboratory can report the concentration with 

confidence; therefore, the RL is by definition at or above the detection limit.) 
SO-Source Characterization

Source No.: 1 

25

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity 

The hazardous constituent quantity for Source No. 1 could not be adequately determined 

according to the HRS requirements; that is the total mass of all Comprehensive Environmental 

Response, Compensation and Liability Act (CERCLA) hazardous substances in the source is not 

known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). There are 

insufficient historical and current data (manifests, PRP records, state records, permits, waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA 

hazardous substances in the source and the associated releases from the source. Therefore, there 

is insufficient information to evaluate the associated releases from the source to calculate the 

hazardous constituent quantity for Source No. 1with reasonable confidence. Scoring proceeds to 

the evaluation of Hazardous Wastestream Quantity (Surface Water Pathway) according to the 

HRS (Ref. 1, Sec. 2.4.2.1.1 and 2.4.2.1.2). 

Hazardous Constituent Quantity Value (S): Not Calculated 

Are the data complete for hazardous constituent quantity for this area? No 

2.4.2.1.2 Hazardous Wastestream Quantity

The hazardous wastestream quantity for Source No. 1 could not be adequately determined 

according to the HRS requirements; that is the mass of hazardous wastestreams plus the mass of 

any additional CERCLA pollutants is not known and cannot be estimated with reasonable 

confidence (Ref. 1, Sec. 2.4.2.1.2). There are insufficient historical and current data (manifests, 

PRP records, state records, and permits) available to adequately calculate the mass of the 

hazardous wastestream or the mass of any additional CERCLA hazardous substances in the 

source. Therefore, there is insufficient information to evaluate the associated releases from the 

source to calculate the hazardous wastestream quantity for Source No. 1with reasonable 

confidence. Scoring proceeds to an evaluation of volume according to the HRS (Ref. 1, Sec. 

2.4.2.1.2 and 2.4.2.1.3). 

Hazardous Wastestream Quantity Value (W): Not Calculated 

Are the data complete for hazardous wastestream quantity for this area? No 

2.4.2.1.3 Volume

The depth of the cooling pond is not known; therefore, volume of the area cannot be adequately 

determined. Volume is assigned a value of 0 and scoring will proceed to an evaluation of area 

according to the HRS (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).
SO-Source Characterization

Source No.: 1 

26

2.4.2.1.4 Area

According to the 1923 Sanborn Map, the Cooling Pond measured approximately 25 feet (ft.) by 

30 ft.; therefore, it occupied approximately 750 square feet (Ref. 18, p. 4). 

The hazardous waste quantity evaluation equation for a buried/backfilled surface impoundment 

is A/13 (Ref. 1, Table 2-5). The area source will be assigned an area hazardous waste quantity 

value of 57.69. 

750 sq. ft./13 = 57.69 

Area of source (ft2

): 750 

Area Assigned Value: 57.69 

References: Fig. 2 of this HRS documentation record; Ref. 1, Sec. 2.4.2.1.4; Ref. 18, p. 4 

2.4.2.1.5 Calculation of Source Hazardous Waste Quantity Value 

Source No. 1, Cooling Pond

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source 

No. 1 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The highest value assigned is 

Tier D.

Source No. 1 Hazardous Waste Quantity Value: 57.69 
SO-Source Characterization

Source Nos.: 2-10 

27

2.2 SOURCE CHARACTERIZATION

The sources evaluated at the Wilcox/Lorraine Refinery site, for HRS purposes include: 

 

• Source Nos. 2 - 10: Tank Bottoms (Pile- other) 

2.2.1 Sources 2- 10 Identification

The following information corresponds to sources 2 - 10 identified for this documentation 

record. 

Number of the source: Source No. 2 - 10 

Name and description of the source: Tank Bottom (Pile-other) 

Source No. 2 through Source No. 10 are former tank bottoms located in the central portion of the 

former process and refinery areas of the Lorraine and Wilcox Refinery. Tank bottoms are 

generally defined as the liquids and residue, such as heavy hydrocarbons, solids, sands and 

emulsions, which collect in the bottom of or remain in the bottom of storage tanks after a period 

of service (Ref. 4, p. 9). Previous investigations identified approximately 6.5 acres of tank 

bottom material within the storage tank berms in the tank farm area (Ref. 12, p. 6). Tank bottom 

sediment and oily sludge was also observed in a former remnant of a tank bottom (Ref. 5, pp. 47-

54). 

The area of each tank bottom was measured based upon the Sanborn and historical aerial 

photographs (Ref. 18, Ref. 28). Tank waste bottoms were located in the bermed area for each oil 

storage tank. 

Waste samples were collected during the ODEQ Site Inspection (SI) (August 2009) and 

Expanded Site Inspection (ESI) of the Lorraine Refinery (September 2010) and the ODEQ ESI 

of the Wilcox Refinery (September/December 2011) (Ref. 5, pp. 47-54; Ref. 21;Ref. 22; Ref. 

24). During sampling activities, these areas contained oil, tarry and black asphalt-like materials 

(Ref. 5, p. 5; Ref. 34, pp. 2, 3).

•Location of the source, with reference to a map of the site:

Source No. 2 through Source No. 10 are located in the central portion of the facility. Waste 

samples were collected from each source. Analytical results are summarized in Table 4 of this 

HRS documentation record (Figs. 2, 3 and 4 of this HRS documentation record). 

•Source Type for HRS evaluation purposes: Pile (other) 

•Containment 
SO-Source Characterization

Source Nos.: 2-10 

28

Gas release to air: The air migration pathway was not scored; therefore, gas release to 

air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, 

particulate containment was not evaluated.

Release to ground water: The ground water migration pathway was not scored; 

therefore, ground water containment was not evaluated. 

Release via overland migration and/or flood: There is no documentation or evidence to 

indicate that the tank bottoms had a maintained run-on control system or runoff 

management system (including treatment of diked liquids), liner, or an engineered cover 

(Ref. 5, pp. 8, 31-54). The containment factor value for Source Nos. 2-10 is 10 (Ref. 1, 

Table 4-2). 

2.2.2 Hazardous Substances Associated with a Source 

Table 4 shows the hazardous substances detected in the waste samples collected during the ESI 

sampling missions. The samples were analyzed for semivolatiles and metals (Ref. 6; Ref. 10; 

Table 4 of this HRS documentation record).
SO-Source Characterization

Source Nos.: 2-10 

29

Table 4-EVIDENCE for Source Nos. 2-10

WASTE SAMPLES

Hazardous Substance

Source No. 2 

Sample No. LWW-5 / SEL # 

485658 

Collection date: 6/9/2010

Source No. 2 

Sample No. W-8 / SEL # 

505872 

Collection date: 6/28/2011

Conc. RL Conc. RL

Metals (mg/kg)

Arsenic 11 10 <10 10 

Copper 8.2 5 <5 5 

Lead 164 10 <10 10 

Nickel 13.8 10 <10 10 

Semivolatiles (ug/kg)

Benzo(b)fluoranthene <190,000 190,000 1,100 1,100 

Benzo(a)pyrene <190,000 190,000 1,200 1,100 

Chrysene <190,000 190,000 2,500 1,100 

Fluoranthene <190,000 190,000 <1,100 1,100 

2-Methylnaphthalene 380,000 190,000 <1,100 1,100 

Phenanthrene 200,000 190,000 2,400 1,100 

Pyrene 200,000 190,000 2,600 1,100 

REFERENCES

Chain of Custody Ref. 10, p. 239 Ref 6, p.6 

Laboratory Reports 

(including Form Is) Ref. 10, pp. 116-119, 124 Ref 6, pp. 45-47, 50, 69-71 

Other Supporting 

References

Fig. 3 of this HRS 

documentation record

Ref. 5, p. 53; Ref 6, pp. 1, 9, 

40, 42; Fig. 3 of this HRS 

documentation record

 Key:

 Bold- conc. is greater than or equal to the RL 

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at 

which a laboratory can report the concentration with confidence; therefore, the RL is by definition 

at or above the detection limit.)

 < - Conc. is less than the RL 

 mg/kg – milligrams per kilogram

 ug/kg – micrograms per kilogram
SO-Source Characterization

Source Nos.: 2-10 

30

Table 4 - EVIDENCE for Source Nos. 2-10

WASTE SAMPLES

Hazardous Substance

Source No. 3 

Sample No. 

W-2 / SEL # 

505877 

Collection 

date: 

6/28/2011 

Source No. 4 

Sample No. W-4 / 

SEL # 505878

Collection date: 

6/28/2011 

Source No. 5 

Sample No. 

W-5 / SEL # 

505873 

Collection 

date: 

6/28/2011 

Source No. 5

Sample No. 

W-6 

(Duplicate of 

W-5) / SEL # 

505890 

Collection 

date: 

6/28/2011

Source No. 6 

Sample No. W7 / SEL # 

505992 

Collection 

date: 6/29/2011

Conc. RL Conc. RL Conc. RL Conc. RL Conc. RL

Metals (mg/kg)

Copper 5.60 5 7.4 5 7.9 5 6.70 5 6.10 5 

Lead 2,320 10 254 10 590 10 486 10 15.4 10 

Nickel 153 10 <10 10 <10 10 

7.20

10 6.50 10 

Semivolatiles (ug/kg)

Benzo(a)anthracene <350 350 1,800 J 1,700 <350 350 <350 350 <1,000 1,000 

Benzo(b)fluoranthene <350 350 <1,700 1,700 <350 350 <350 350 1,200 1,000 

Benzo(a)pyrene <350 350 <1,700 1,700 <350 350 <350 350 <1,000 1,000 

Chrysene <350 350 <1,700 1,700 <350 350 <350 350 <1,000 1,000 

Fluoranthene <350 350 <1,700 1,700 <350 350 <350 350 1,500 1,000 

Phenanthrene <350 350 <1,700 1,700 <350 350 <350 350 <1,000 1,000 

Pyrene <350 350 3,300 J 1,700 <350 350 <350 350 1,200 1,000 

REFERENCES

Chain of Custody Ref 6, p. 6 Ref 6, p. 6 Ref 6, p. 6 Ref 6, p. 7 Ref 6, p. 8 

Laboratory Reports 

(including Form Is) 

Ref 6, pp. 45-

47, 55, 85-87 

Ref 6, pp. 45-47, 56,

88-91 

Ref 6, pp. 45-

47, 51, 72-74 

Ref 6, pp. 45-

47, 68, 130-

132 

Ref 6, pp. 45-

47, 139,153-155 

Other Supporting 

References

Ref. 5, p. 48; 

Ref. 6, p.14; 

Fig. 3 of this 

HRS 

documentation 

record

Ref. 5, p. 50; Ref. 6,

p.15, 42; Fig. 3 of this 

HRS documentation 

record

Ref. 5, p. 51; 

Ref. 6, p.10; 

Fig. 3 of this 

HRS 

documentation 

record

Ref. 5, p. 51; 

Ref 6, pp. 1, 

27; Fig. 3 of 

this HRS 

documentation 

record

Ref. 5, p. 52; 

Ref 6, pp.1, 32, 

40, 42; Fig. 3 of 

this HRS 

documentation 

record

Key:

Bold- conc. is greater than or equal to the RL 

J – Concentration is an estimated quantity, but the identification of the hazardous substance is not in doubt.

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at which a laboratory can 

report the concentration with confidence; therefore, the RL is by definition at or above the detection limit.)

< - Conc. is less than the RL 

mg/kg – milligrams per kilogram

ug/kg – micrograms per kilogram 
SO-Source Characterization

Source Nos.: 2-10 

31

Table 4 - EVIDENCE for Source Nos. 2-10 

WASTE SAMPLES

Hazardous Substance

Source No. 7 

Sample No. W-1 

/ SEL # 505876 

Collection date: 

6/28/2011 

Source No. 8

Sample No. 

W-3 / SEL # 

505875 

Collection 

date: 

6/28/2011 

Source No. 9

Sample No. 

LWSS-4 / 

SEL # 485641 

/ 485656

Collection 

date: 6/9/2010

Source No. 10 

Sample No. W-9 / 

SEL # 505886 

Collection date: 

6/28/2011 

Conc. RL Conc. RL Conc. RL Conc. RL

Metals (mg/kg)

Arsenic <10 10 <10 10 19.8 10 <10 10 

Copper <5 5 <5.0 5 52.1 5 78.2 5 

Lead 122 10 <10 10 15.7 10 1,560 10 

Nickel <10 10 <10 10 23.6 10 22.6 10 

Semivolatiles (ug/kg)

Benzo(a)anthracene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Benzo(b)fluoranthene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Benzo(a)pyrene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Chrysene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Fluoranthene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Phenanthrene <1,000 1,000 <350 350 <360 360 <27,000 27,000 

Pyrene <1,000 1,000 490 350 <360 360 <27,000 27,000 

REFERENCES

Chain of Custody Ref 6, p. 6 Ref 6, p. 6 Ref 10, p. 239 Ref 6, p. 7 

Laboratory Reports 

(including Form Is) 

Ref 6, pp. 45-47, 

54, 82-84 

Ref 6, pp. 45-

47, 53, 78-81 

Ref 10, pp. 

139-141, 167-

169, 186

Ref 6, pp. 45-47, 

64,117-119 

Other Supporting 

References

Ref. 5, p. 47; 

Ref. 6, p.13; Fig. 

3 of this HRS 

documentation 

record

Ref. 5, p. 49; 

Ref. 6, p.12; 

Fig. 3 of this 

HRS 

documentation 

record

Ref. 9; Fig. 3 

of this HRS 

documentation 

record

Ref. 5, p. 54; Ref 6, 

pp.1, 23; Fig. 3 of 

this HRS 

documentation 

record

Key:

Bold- conc. is greater than or equal to the RL 

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at which a laboratory can 

report the concentration with confidence; therefore, the RL is by definition at or above the detection limit.)

< - Conc. is less than the RL 

mg/kg – milligrams per kilogram

ug/kg – micrograms per kilogram
SO-Source Characterization

Source Nos.: 2-10 

32

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity 

The hazardous constituent quantity for Source Nos. 2-10 could not be adequately determined 

according to the HRS requirements; that is the total mass of all Comprehensive Environmental 

Response, Compensation and Liability Act (CERCLA) hazardous substances in the sources is 

not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). There are 

insufficient historical and current data (manifests, PRP records, state records, permits, waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA 

hazardous substances in the sources and the associated releases from the sources. Therefore, 

there is insufficient information to evaluate the associated releases from the sources to calculate 

the hazardous constituent quantity for Source Nos. 2-10 with reasonable confidence. Scoring 

proceeds to the evaluation of Hazardous Wastestream Quantity (Surface Water Pathway) 

according to the HRS (Ref. 1, Sec. 2.4.2.1.1 and 2.4.2.1.2). 

Hazardous Constituent Quantity Value (S): Not Calculated 

Are the data complete for hazardous constituent quantity for this area? No 

2.4.2.1.2 Hazardous Wastestream Quantity 

The hazardous wastestream quantity for Source Nos. 2-10 could not be adequately determined 

according to the HRS requirements; that is the mass of hazardous wastestreams plus the mass of 

any additional CERCLA pollutants is not known and cannot be estimated with reasonable 

confidence (Ref. 1, Sec. 2.4.2.1.2). There are insufficient historical and current data (manifests, 

PRP records, state records, and permits) available to adequately calculate the mass of the 

hazardous wastestream or the mass of any additional CERCLA hazardous substances in the 

sources. Therefore, there is insufficient information to evaluate the associated releases from the 

sources to calculate the hazardous wastestream quantity for Source Nos. 2-10 with reasonable 

confidence. Scoring proceeds to an evaluation of volume according to the HRS (Ref. 1, Sec. 

2.4.2.1.2 and 2.4.2.1.3). 

Hazardous Wastestream Quantity Value (W): Not Calculated 

Are the data complete for hazardous wastestream quantity for this area? No 

2.4.2.1.3 Volume

The volume cannot be determined. Volume is assigned a value of 0 and scoring will proceed to 

an evaluation of area according to the HRS (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).
SO-Source Characterization

Source Nos.: 2-10 

33

2.4.2.1.4 Area

Using the historical aerial photographs and the Sanborn maps, by sample collection of waste 

samples and visual inspection within each bermed area, the diameter of each waste source 

measured approximately 200 feet (Ref. 18; Ref. 28). The area source was determined by 

calculating the area of a circle. (Area of a circle = Π r2).

100 ft. 2 x 3.14 = 31,400 ft. 2 

31,400 ft. 2 / 13 = 2,415.38 

Each area source for Source Nos. 2-10 will be assigned an area hazardous waste quantity value 

of 2,415.38. 

Area of source (ft2): 21,783.42 

Area Assigned Value: 2,415.38 

References: Figures 2 and 3 of this HRS documentation record; Ref. 1, Sec. 2.4.2.1.4; Ref. 18; 

Ref. 28 

Other Possible Sources Not Scored 

Other possible sources at Wilcox include: 

• four tank bottom areas located north and south of Source No. 1 (Ref. 18, p. 4; Figure 5 of 

this HRS documentation record); two of the tank bottoms are located within the wetlands 

(Figure 5 of this HRS documentation record); and

• three tank bottom areas in the former tank farm area (Ref. 18, pp. 2-6). 

The possible contaminants associated with the tank bottoms are most probably the same 

hazardous substances detected in the samples from Source Nos. 2 through 10. 
SO-Summary

34

2.4.2.2.5 Calculation of Hazardous Waste Quantity Factor Value 

SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment

Source 

No.

Source Hazardous Waste Quantity 

Value

Ground 

Water 

Surface 

Water 

Air

Surface Water 

Migration 

Pathway 

Soil Exposure 

Pathway Gas Air Particulate

1 57.69 NS NS 10 NS NS

2 2,415.38 NS NS 10 NS NS

3 2,415.38 NS NS 10 NS NS

4 2,415.38 NS NS 10 NS NS

5 2,415.38 NS NS 10 NS NS

6 2,415.38 NS NS 10 NS NS

7 2,415.38 NS NS 10 NS NS

8 2,415.38 NS NS 10 NS NS

9 2,415.38 NS NS 10 NS NS

10 2,415.38 NS NS 10 NS NS

Total 21,796.11

Key:

NS: Not Scored

The sum of the source hazardous waste quantity values is assigned as the Hazardous Waste 

Quantity Factor Value (Ref. 1, Sec. 2.4.2.2). The sum of the source hazardous waste quantity 

values for Surface Water Pathway is 21,796.11. For a Hazardous Waste Quantity range of 

greater than >10,000 to 1,000,000 a value of 10,000 is assigned for the migration pathway (Ref. 

1, Sec. 2.4.2.2, Table 2-6). 

Assigned Hazardous Waste Quantity Factor Value for Migration Pathways: 10,000 
SWOF-Surface Water Overland Flow/Flood Migration Component 

35

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood 

Component

General Considerations:

Four PPEs have been identified. While contamination could have entered the wetlands anywhere 

along the boundary of the wetlands and the surface impoundment, PPE-1 is the most upstream 

probable point of entry into the wetlands from the surface impoundment. PPE-1 is located on the 

western part of the former Lorraine refinery (Figure 5 of this HRS documentation record). PPE2 and PPE-3 are where on-site intermittent tributaries flow into Sand Creek (Figure 5 of this 

HRS documentation record). PPE-4 is located on the eastern side of the Wilcox facility where an 

eastern intermittent tributary also flows into Sand Creek (Figure 6 of this HRS documentation 

record). The 15 mile target distance limit is illustrated on Figure 6 of this HRS documentation 

record. 

Table 5 describes the overland flow pathway and PPE information for each source. 

 

Table 5 – Surface Water Pathway Description for Each Source

Source No Pathway Description PPE Ref. 

1 Source No. 1 transects the PPE-1: Palustrine forested 9, p. 23; Figs. 

wetlands located on the west wetlands contiguous with Sand 5 and 6 of this 

side of the facility Creek HRS 

documentation 

record

2 Intermittent rills and sheet PPE-4: Confluence of the eastern 13, pp. 24, 46; 

flow southeast to the East tributary into Sand Creek Figs. 5 and 6 

Tributary of this HRS 

documentation 

record

3 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow south to an intermittent tributary into Sand Creek Figs. 5 and 6 

central tributary of this HRS 

documentation 

record

4 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow south to an intermittent tributary into Sand Creek Figs. 5 and 6 

central tributary of this HRS 

documentation 

record

5 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow south to an intermittent tributary into Sand Creek Figs. 5 and 6 
SWOF-Surface Water Overland Flow/Flood Migration Component 

36

Table 5 – Surface Water Pathway Description for Each Source

central tributary of this HRS 

documentation 

record

6 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow south to an intermittent tributary into Sand Creek Figs. 5 and 6 

central tributary of this HRS 

documentation 

record

7 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow south to an intermittent tributary into Sand Creek Figs. 5 and 6 

central tributary of this HRS 

documentation 

record

8 Intermittent rills and sheet PPE-3: Confluence of the central 13, pp. 24, 46; 

flow southwest to an tributary into Sand Creek Figs. 5 and 6 

intermittent central tributary of this HRS 

documentation 

record

9 Intermittent rills and sheet PPE-4: Confluence of the eastern 13, pp. 24, 46; 

flow south to the east tributary into Sand Creek Figs. 5 and 6 

tributary of this HRS 

documentation 

record

10 Intermittent rills and sheet PPE-2: Confluence of the western 13, pp. 24, 46; 

flow south to the west tributary into Sand Creek Figs. 5 and 6 

tributary of this HRS 

documentation 

record

Definition of In-Water Segments

The drainage pattern for the site is generally to the south (Ref. 3; Ref. 9, p. 23; Ref. 13, pp. 23, 

46; Ref. 30. pp. 1-2). There are four locations where overland flow of surface waters across the 

site enters perennial waters (Sand Creek) (Ref. 9, p. 23; Ref. 13, pp. 3, 23, 46). Sand Creek 

meanders approximately 3.5 miles east until it merges with Little Deep Fork Creek. Little Deep 

Fork Creek begins approximately 3.1 miles southeast of PPE No. 4 (Figures 5 and 6 of this HRS 

documentation record). 

Sand Creek

Sand Creek, a perennial stream, is located on the west side of the facility (Ref. 3; Figure 5 of this 

HRS documentation record). Sand Creek flows southward approximately 3.5 miles until it 

empties into the Little Deep Fork Creek (Ref. 3; Figure 6 of this HRS documentation record). 
SWOF-Surface Water Overland Flow/Flood Migration Component 

37

Little Deep Fork Creek

The Little Deep Fork Creek is joined by Sand Creek approximately 3.1 miles from the farthest

downstream PPE (PPE 4). The remaining 8.9 miles of the 15-mile target distance limit (TDL) is 

contained within the Little Deep Fork Creek, which is a fishery (Ref. 5, pp. 1-4; Ref. 9, p. 1; Ref. 

25, p.1).

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release 

Chemical Analyses:

Field sampling procedures used for the samples collected followed the procedures set forth in the 

EPA Guidance for Performing Site Inspections under CERCLA, Interim Final, EPA 540-R-92-

021(Ref. 5, pp. 4, 55; Ref. 16, pp. 4, 34; Ref. 31, pp. 6, 20). The sampling followed the 

procedures set forth in ODEQ’s Site Assessment Quality Assurance Project Plan (QAPP) and the 

approved DEQ Quality Management Plan (QMP) (Ref. 39; Ref. 40). The samples were analyzed 

for total metals, including mercury, volatile and semivolatile organics using Oklahoma State 

Environmental Laboratory (SEL) methods and procedures (Ref. 16, pp. 59-68; Ref. 19). 

Release sediment samples were compared to the background sediment samples to support an 

observed release to the surface water migration pathway. In addition to the chemical analyses, 

waste was also observed deposited into the stream bank during field activities by ODEQ 

personnel (Ref. 20, pp. 11, 12). 

Soil types on the facility and surrounding area contain several soil series: the Stephenville and 

Darnell fins sandy loams, sloping and gently sloping, the Verdigris silt loam; and Oil-waste 

Land. Soils are described by the Creek County Soil Survey as follows (Ref. 16, pp. 7-9):

• The Stephenville and Darnell fine sandy loams cover most of the facility. These soils 

consist of shallow to moderately deep upland soils developed over reddish-yellow to red 

sandstone or interbedded sandstone and sandy shale (Ref. 16, p. 7). 

• The Verdigris silt loam is located in the southwestern portion of the property, along Sand 

Creek. These soils occupy the flood plans of streams and are moderately well drained; 

however, they are flood occasionally to frequently. Parent material consists of slightly 

acid to weekly alkaline alluvial sediments washed from soils of the prairies (Ref. 16, p. 

8). 

• Oil-waste Land has been mapped in areas through the property, occurring in tanks farm 

and refinery areas. The areas mapped in this soil type have been practically ruined for 

agricultural use by oil and salt-water waste from oil wells. They are more or less gullied 

and eroded and are almost barren of vegetation (Ref. 16, p. 7). 

• Background Concentration – 
SWOF-Surface Water Overland Flow/Flood Migration Component 

38

Table 6- Sediment Background Samples- Sand Creek

Sample ID Depth Sediment Description Date Reference

LSD-5 

0 to 24

inches Dark brown sandy clay April 22, 2009

Ref. 16, pp. 20, 277; 

Ref. 34, pp. 1, 2 

SED-7

0 to 24

inches Brown silty sediment June 25, 2011

Ref. 20, p. 13; Ref. 34, 

pp. 1, 2
SWOF-Surface Water Overland Flow/Flood Migration Component 

39

The background sediment samples, LSD-5 and SED-7 were collected upstream in Sand Creek 

(Figure 4 and Figure 5 of this HRS documentation record). The samples were grab samples 

collected from an area with similar flora and sediments (Figure 5 of this HRS documentation 

record; Ref. 5, p. 29; Ref. 16, p. 25, Ref. 30, p. 1; Ref. 34). The sediment samples were analyzed 

for semivolatiles by EPA Method 8270D and metals by EPA Methods 6010 or 6020 by the 

ODEQ SEL (Ref. 6, p. 2).

Table 7 – Background Sediment Concentrations for Sand Creek

Sample No. SED-7 / 

SEL # 505996

Collection date: 6/25/2011

Sample No. LSD-5 /

SEL # 462188

Collection date: 4/22/2009

% moisture 19.2 27

Hazardous Substance Conc. (mg/kg) RL (mg/kg) Conc. (mg/kg) RL (mg/kg)

Metals (mg/kg)

Chromium <5 5 4.90 1 

Copper <5 5 <1 1 

Lead <10 10 2.50 1 

Nickel <10 10 2.20 1 

Zinc 8.60 5 6.40 1 

Semivolatiles (ug/kg)

Benzo(a)anthracene <430 430 <400 400

Benzo(b)fluoranthene <430 430 <400 400

Benzo(a)pyrene <430 430 <400 400

Chrysene <430 430 <400 400

Pyrene <430 430 <400 400

Fluoranthene <430 430 <400 400

Chain of Custody Ref 6, p. 8 Ref. 16, p. 71 

Laboratory Reports (including Form 

Is) Ref 6, pp. 45-47, 143, 165 to 167 Ref. 16, pp. 120, 250-253

Other Supporting References Fig. 4 of this HRS documentation 

record; Ref. 6, p.36

Fig. 4 of this HRS documentation 

record; Ref. 16 

Key:

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at which a laboratory 

can report the concentration with confidence; therefore, the RL is by definition at or above the detection limit.)

< - concentration was detected below the RL 

 
SWOF-Observed Release

40

Table 8- Sediment Samples- Sand Creek

Sample 

ID Depth Sediment Description % Moisture Date Reference

LSD-2 

0 to 24 

inches

Brown sandy clay 18.4 April 22, 2009

Ref. 16, pp. 18, 

117, 277; Ref. 34, 

pp. 1, 4 

SED-12

0 to 24 

inches

Sandy Dark Grey sediment 24.2 December 6, 2011

Ref. 7, p. 3; Ref. 

8, p. 28; Ref. 34, 

pp. 1, 2 

SED-13

0 to 24 

inches

Reddish brown sediment 22.9 December 6, 2011

Ref. 7, p. 3; Ref. 

8, p. 34; Ref. 34, 

pp. 1, 2 

SED-14

0 to 24 

inches

Brown sandy sediment, strong 

hydrocarbon and observance 

seep and sheen

6.9 December 6, 2011

Ref. 7, p. 3; Ref. 

8, p. 40; Ref. 34, 

pp. 1, 3 

Sediment sample LSD-2 was compared to background sample LSD-5 and sediment samples 

SED-12, SED-13, and SED-14 were compared to SED-7.
SWOF-Observed Release

41

Table 9 – EVIDENCE

SEDIMENT SAMPLESSand Creek

Hazardous 

Substance

Established 

Background Level

Sample No. LSD-2 

SEL No. 462185

Collection date: 

4/22/2009

Sample No. SED12

SEL No. 512702

Collection date: 

12/6/2011

Sample No. SED-13

SEL No. 512703

Collection date: 

12/6/2011

Sample No. SED-14

SEL No. 512704

Collection date: 

12/6/2011

2009 2011

Conc. RL Conc. RL Conc. RL Conc. RL 

Metals (mg/kg)

Lead 2.50 <10 9.60 1 17.0 10 <10 10 145 10 

Semivolatiles (ug/kg)

Benzo(a)anthracene <400 <430 <390 390 <450 450 <410 410 2,400 580

Chrysene <400 <430 <390 390 <450 450 <410 410 4,100 580

Pyrene <400 <430 <390 390 <450 450 <410 410 4,500 580

Fluoranthene <400 <430 <390 390 <450 450 <410 410 1,600 580

REFERENCES

Chain of Custody

Table 7 

of this HRS 

documentation 

record

Ref. 16, p. 71 Ref. 8, p. 6 Ref. 8, p. 6 Ref. 8, p. 6 

Laboratory Reports 

(including Form Is)

Ref 16, pp.117, 241-

243

Ref 8, pp. 23-25, 

27-32

Ref 8, pp. 23-25, 

33-38

Ref 8, pp. 23-25, 39-

45

Other Supporting 

References

Fig. 4 of this 

HRS documentation 

record; Ref. 16, p. 

277

Fig. 4 of this 

HRS 

documentation 

record; 

Ref 8, pp. 1, 8, 19

Fig. 4 of this 

HRS documentation 

record; 

Ref 8, pp. 1, 9, 19

Fig. 4 of this 

HRS documentation 

record; 

Ref 8, pp. 1, 10, 19

Key: 

Conc: Concentration

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at which a laboratory can report the 

concentration with confidence; therefore, the RL is by definition at or above the detection limit.)

BOLD – Concentration meets observed release criteria (Ref. 1, Table 2-3).
SWOF-Observed Release

42

Attribution:

The Wilcox facility is an inactive and abandoned oil refinery (Ref. 12, p. 3). The facility was active from 

1915 until 1960s (Ref. 12, p. 3; Ref. 15, p. 4; Ref. 18, pp. 1-4).

The hazardous substances used to establish an observed release were associated with the site sources and 

the site contributed at least in part to the significant increase in the concentration of the hazardous 

substances in the observed release. Furthermore, the hazardous substances were detected at elevated

levels in intermittent streams on the property that leads to Sand Creek (see Table 10 of this HRS 

documentation record).

 

Alternative sites that may be contributing releases of hazardous substances to those found at the Wilcox 

facility were identified. Former refineries were located north of the site. Little information is known 

about the dates of operation at these facilities. Sanborn maps from 1915 and 1920 indicate that the 

property west of the Wilcox Oil facility was occupied by Continental Refining Company (Ref. 18). 

Indiahoma Refining Company was located north of the facility (Ref. 18). 

The background sediment samples (SED-7, LSD-5, and SED-9) were collected between any up gradient 

influences from former refinery activities and the site sources, which indicates that the significant 

increase in the concentration of the hazardous substances in the observed release is not due to other sites. 

The sources contained the same constituents in the observed release and in the drainage pathway to Sand 

Creek (see Tables 3, 4, 7 and 10 of this HRS documentation record).
SWOF-Observed Release

43

Table 10- ATTRIBUTION 

SAMPLES- Overland flow into Sand Creek

ODEQ Sampling, June 2011

Hazardous Substance

Background Sample

SED-9 /

SEL No. 505888

Collection date: 

6/28/2011

Sample No. SED-2 

SEL No. 505990

Collection date: 6/29/2011

Sample No. SED-3 

SEL No. 505991

Collection date: 6/29/2011

Sample No. SED-4 

SEL No. 505993

Collection date: 

6/29/2011

Sample No. SED- 5 

SEL No. 505994

Collection date: 

6/29/2011

Sample No. SED-11

SEL No. 505874

Collection date: 

6/28/2011

Conc. 

(mg/kg)

 RL 

(mg/kg)

Conc. 

(mg/kg)

RL 

(mg/kg)

Conc. 

(mg/kg)

RL 

(mg/kg)

Conc. 

(mg/kg)

RL 

(mg/kg)

Conc. 

(mg/kg)

RL 

(mg/kg)

Conc. 

(mg/kg)

RL 

(mg/kg)

Copper <5 5 9.90 5 12.3 5 <5 5 5.70 5 8.70 5 

Nickel <10 10 18.4 10 17.9 10 <10 10 12.8 10 <10 10

REFERENCES

Chain of Custody Ref. 6, p. 7 Ref 6, p. 8 Ref 6, p. 8 Ref. 6, p. 8 Ref 6, p. 8 Ref 6, p. 6 

Laboratory Reports 

(including Form Is) Ref. 6, pp. 43-48, 66 Ref 6, pp. 45-47, 137 Ref 6, pp. 45-47, 138 Ref. 6, pp. 45-47, 140 Ref 6, pp. 45-47, 141 Ref 6, pp. 47, 52

Other Supporting 

References

Fig. 4 of this 

HRS documentation 

record; Ref. 6, p. 25

Fig. 4 of this 

HRS documentation 

record; Ref. 6, pp. 30, 39-

41

Fig. 4 of this 

HRS documentation 

record; Ref. 6, pp. 31, 39-

41

Fig. 4 of this 

HRS documentation 

record; Ref. 6, p. 33

Fig. 4 of this 

HRS documentation 

record; Ref. 6, p. 34

Fig. 4 of this 

HRS documentation 

record; Ref. 6, p.11

Key:

BOLD: concentration is greater than the RL

Conc: Concentration

RL – Reporting Limit (The RL is commonly defined as the lowest contaminant concentration at which a laboratory can report the concentration with confidence; 

therefore, the RL is by definition at or above the detection limit.)

<: concentration was not detected above RL
SWOF-Observed Release

44

The hazardous substances found on site may be directly related to crude oil or petroleum products. 

Waste petroleum products that contain higher concentrations of hazardous substances than the original 

product are CERCLA-eligible and are not subject to the petroleum exclusion provisions (Ref. 32, pp. 2-

4). 

Observed Release Factor Value: 550
SWOF/

Food Chain-Toxicity/Persistence/Bioaccumulation

45

4.1.3.2 HUMAN FOOD CHAIN THREAT - WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The human food chain waste characteristics section provides the toxicity, persistence and 

bioaccumulation factor values for hazardous substances that are available to migrate from sources at the 

site to surface water in the watershed via the overland/flood hazardous substances migration path for the 

watershed (Ref. 1, Section 4.1.3.2.1), the hazardous waste quantity value for the watershed (Ref. 1, 

Section 4.1.3.2.2), and the calculation of the human food chain threat-waste characteristics factor 

category value (Ref. 1, Section 4.1.3.2.3). The highest combined toxicity, persistence and 

bioaccumulation factor is used to determine the waste characteristics factor value for the human food 

chain threat of the surface water migration pathway (Ref. 1, Section 4.1.3.2.1.4). 

Hazardous substances that meet the criteria for an observed release to surface water and all hazardous 

substances associated with the sources that have a surface water containment factor value greater than 0 

for the watershed are presented in Table 11 below. Each hazardous substance eligible to be evaluated is 

assigned a toxicity/persistence/bioaccumulation factor value. The hazardous substance with the highest 

toxicity/persistence/bioaccumulation factor value for the watershed is used to assign the value to this 

factor (Ref. 1, Section 4.1.3.2.1.4). 

Table 11 – Human Food Chain Threat - Toxicity/Persistence/Bioaccumulation Summary 

Hazardous 

Substance

Source 

No. 

Toxicity 

Factor 

Value

Persistence 

Factor 

Value*

Toxicity/Persistence 

Factor Value 

(Table 4-12)

Bioaccumulation 

Factor Value **

Toxicity/

Persistence/

Bioaccumulation 

Factor Value 

(Table 4-16) Reference 

Metals

Arsenic 1, 2, 9 10,000 1.0 10,000 5.0 50,000

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p .1

Chromium 1 10,000 1.0 10,000 500 5,000,000 

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p .3 

Copper 1, 2, 3, 4, 

5, 6, 9, 10 - 1.0 - 500 - 

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 3

Lead

1, 2, 3, 4, 

5, 6, 7, 9, 

10 

10,000 1.0 10,000 5 50,000

Ref. 1, Table 

4-20, 4-21; 

Ref. 2, p.8 

Nickel 1, 2, 3, 5, 

9, 10 10,000 1.0 10,000 0.5 5,000

Ref. 1, Table 

4-20, 4-21; 

Ref. 2, p .9 

Zinc 1 10 1.0 10 5.0 50

Ref. 1, Table 

4-20, 4-21; 

Ref. 2, p .12
SWOF/

Food Chain-Toxicity/Persistence/Bioaccumulation

46

Table 11 – Human Food Chain Threat - Toxicity/Persistence/Bioaccumulation Summary 

Semivolatiles

Benzo(a)anthracene 4 1,000 1.0 1,000 50,000 50,000,000

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 2

Benzo(a)pyrene 2 10,000 1.0 10,000 50,000 500,000,000

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 2

Benzo(b)fluoranthe

ne 6 - - - - - - 

Chrysene 2 10 1.0 10 5 50

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 3

Fluoranthene 6 100 1.0 100 500 50,000

Ref. 1, Table 

4-20, 4-21; 

Ref. 2, p. 2

2-

methylnaphthalene 2 1,000 0.4 400 50,000 20,000,000

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 9

Phenanthrene 2 - 0.4 - 5,000 - 

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 9

Pyrene 2, 3, 4, 6, 

8 100 1.0 100 50,000 5,000,000

Ref. 1, Table 

4-12, 4-16; 

Ref. 2, p. 10

Key:

* Persistence values assigned are based on Sand Creek, which is a perennially flowing water classified as a River.

**Bioaccumulation values are assigned based on the surface category of fresh water

- No value in SCDM

The hazardous substance with the highest Toxicity/Persistence/Bioaccumulation Factor Value is 

benzo(a)pyrene.

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000 
SWOF/

Food Chain-Hazardous Waste Quantity 

47

4.1.3.2.2 Hazardous Waste Quantity 

Table 12- Hazardous Waste Quantity Summary

Source Number

Source Hazardous Waste 

Quantity Value (Section 

2.4.2.1.5)

Is Source Hazardous 

Constituent Quantity Data 

Complete? (yes/no)

1 57.69 No

2 2,415.38 No

3 2,415.38 No

4 2,415.38 No

5 2,415.38 No

6 2,415.38 No

7 2,415.38 No

8 2,415.38 No

9 2,415.38 No

10 2,415.38 No

TOTAL 21,796.11

The sum of the source hazardous waste quantity values is assigned as the Hazardous Waste 

Quantity Factor Value (Ref.1, Sec. 2.4.2.2 and Table 2-6). The sum of the source hazardous 

waste quantity values for Surface Water Pathway, rounded to the nearest integer, is 21,796. 

Sum of Values: 21,796 

Hazardous Waste Quantity Assigned: 10,000 (Ref. 1 Table 2-6) 
SWOF/

Food Chain-Hazardous Waste Quantity 

48

4.1.3.2.3 Waste Characteristics Factor Category Value 

The waste characteristics factor category value is assigned based on the Waste Characteristics 

Product. The Waste Characteristics Product is the product of the Toxicity/Persistence Factor 

Value and the Hazardous Waste Quantity Factor Value subject to a maximum of 1 x 108. This 

product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value 

of 1 x 1012. The hazardous substance with the highest Toxicity/Persistence/Bioaccumulation 

factor value for the watershed is benzo(a)pyrene (Ref. 1, Section 4.1.3.2.3). 

Toxicity/Persistence Factor Value: 10,000 

x Hazardous Waste Quantity Factor Value: 10,000 

(Toxicity/Persistence x Hazardous Waste Quantity):

10,000 x 10,000 = 1 x 108

(Subject to a maximum product of 1 x 108

) 

Bioaccumulation Potential Factor Value: 50,000 

(Toxicity/Persistence x Hazardous Waste Quantity) x 

Bioaccumulation Potential Factor Value:

 

(1 x 108) x (50,000) = 5 x 1012

(Subject to a maximum product of 1 x 1012) 

A Waste Characteristics Product value of 1 x 1012 receives a waste characteristics factor 

value of 1,000 (Ref. 1, Table 2-7).

Hazardous Waste Quantity Assigned Value: 10,000 

Waste Characteristics Factor Category Value: 1,000
SWOF/

Food Chain-Hazardous Waste Quantity 

49

4.1.3.3 HUMAN FOOD CHAIN THREAT-TARGETS

Little Deep Fork Creek, which is located in the 15-mile TDL is a fishery and fish collected are 

for human consumption (Ref. 25, p. 1). Little Deep Fork Creek is located approximately 3.7 

miles downstream of PPE-2, where Sample No. SED-14 was collected (see Figures 5 and 6 and 

Table 9 of this HRS Documentation Record). 

4.1.3.3.1 Food Chain Individual 

A food chain individual factor value of 20 is assigned based on an observed release by chemical 

analyses of fluoranthene and pyrene with a Bioaccumulation Factor Value of 500 or greater to 

sediments within the surface water target distance limit, and due to the fishery present in Little 

Deep Fork Creek (Sec. 4.1.2.1.1 of this HRS documentation record; Ref.1, Sec. 4.1.3.3.1; Ref. 2, 

pp. 2, 3, and 10; Ref. 25, p.1; Figure 6 and Table 9 of this HRS Documentation Record).

Food Chain Individual Factor Value: 20 (Ref. 1, Section 4.1.3.3.1) 
SWOF/

Food Chain-Hazardous Waste Quantity 

50

4.1.3.3.2 Population 

The Population Factor for the watershed is based on three factors: Level I concentrations, Level 

II concentrations, and potential human food chain contamination. 

4.1.3.3.2.1 Level I Concentrations

There are no Level I concentrations established because there were no tissue samples collected 

(Ref. 1, Sec. 4.1.3.3.2.1). 

4.1.3.3.2.2 Level II Concentrations 

No Level II concentrations have been established within a fishery.

4.1.3.3.2.3 Potential Human Food Chain Contamination 

Fishing is documented in Little Deep Fork Creek. Fish are consumed from Little Deep Creek, 

but the exact pounds consumed are not known (Ref. 25, p. 1). Although the annual pounds of 

fish consumed are unknown, since some fish are consumed, the annual pounds consumed are 

greater than zero. A human food chain population value of 0.03 is assigned for production 

greater than zero (>0) and less than 100 (<100) pounds per year of annual human consumption 

(Ref. 1, Table 4-18). 

According to gauging station #07243500 located in the NW 1⁄4 of the SW 1⁄4 of S20 T14N R12E 

in Okmulgee County, approximately 25 miles southeast from the site, the average annual flow 

rate of the Deep Fork River as measured for water year 1939 through 2011 is 932 cfs (Ref. 29, 

pp.1-2). No gauging stations are located on Sand Creek or the Little Deep Fork Creek. The flow 

rate at the target locations (wetlands, Sand Creek, and Little Deep Fork Creek) was extrapolated 

using the flow data from Deep Fork River, therefore these segments will be set to equal the 

flow at the downstream gauging station and will be considered to be a moderate to large stream 

and will be assigned a dilution value of 0.01 (Ref. 1, Table 4-13). 

Table 13- Fishery Identification Summary 

Identity 

of 

Fishery

Annual 

Production 

(pounds)

Type of 

Surface 

Water 

Body

Average 

Annual 

Flow

Population 

Value (Pi) 

Dilution 

Weight 

(Di) 

PixDi Reference

Little 

Deep 

Creek

>0 moderate 

to large

>100 to 

1,000 cfs 0.03 0.01 0.0003 

Ref. 1, Tables 

4-13, 4-18; 

Ref. 25, p. 1; 

Ref. 29, pp. 1-

2 

Sum: 0.0003 
SWOF/

Food Chain-Hazardous Waste Quantity 

51

(Sum of Pi x Di)/10: 0.00003 

Potential Human Food Chain Contamination 

Factor Value: 3.0 x 10-5
SWOF/Environment Toxicity/Persistence/Bioaccumulation

52

4.1.3.3.2.4 Calculation of Population Factor Value 

The population factor value is equal to: 

Level I Concentrations (0) + Level II Concentrations (0) + Potential Human Food Chain 

Contamination (0.00003) = 0.00003. 

A value of 3.0 x 10-5 is assigned as the Population Factor Value.

Population Factor Value: 3.0 x 10-5 

4.1.3.3.3 Calculation of Human Food Chain Threat- Targets Factor Category Value

The Human Food Chain Threat - Targets Factor Category value is calculated by summing the 

food chain individual and population factor values for the watershed: 

Food Chain Individual + Population Factor= 20 + 0.00003 = 20.00003 

Target Factor Category Value: 20.00003 

4.1.3.4 Calculation of Human Food Chain Threat Score for a Watershed

The Human Food Chain Threat score is calculated by multiplying the human food chain threat 

factor category values for likelihood of release, waste characteristics, and targets for the 

watershed (Ref. 1, Section 4.1.3.4). 

Likelihood of Release (550) x Waste Characteristics (1000) x Targets (20.00003) = 11,000,016 

(rounded to the nearest integer). 

This product is then divided by 82,500: 

11,000,016 ÷ 82,500 = 133.33 

The resulting value, subject to a maximum of 100, is assigned as the Human Food 

Chain Threat Score.

Human Food Chain Threat Score= 100 
SWOF/Environment Toxicity/Persistence/Bioaccumulation

53

4.1.4.2 ENVIRONMENTAL THREAT- WASTE CHARACTERISTICS

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation 

The environmental threat waste characteristics section provides the ecosystem toxicity, 

persistence and bioaccumulation factor values for hazardous substances that are available to 

migrate from sources at the site to surface water in the watershed via the overland/flood 

hazardous substances migration path for the watershed (Ref. 1, Section 4.1.4.2.1), the hazardous 

waste quantity value for the watershed (Ref. 1, Section 4.1.4.2.2), and the calculation of the 

environmental threat-waste characteristics factor category value. The highest combined 

ecosystem toxicity, persistence and bioaccumulation factor is used to determine the waste 

characteristics factor value for the environmental threat of the surface water migration pathway 

(Ref. 1, Section 4.1.4.2.3). 

Hazardous substances that meet the criteria for an observed release to surface water and all 

hazardous substances associated with the sources that have a surface water containment factor 

value greater than 0 for the watershed are presented in Table 14 below. Each hazardous 

substance eligible to be evaluated is assigned an ecosystem toxicity/persistence/bioaccumulation 

factor value. The hazardous substance with the highest ecosystem 

toxicity/persistence/bioaccumulation factor value for the watershed is used to assign the value to 

this factor (Ref. 1, Section 4.1.4.2.1.4). 

Table 14- Ecosystem Toxicity/Persistence/Bioaccumulation Factor Summary

Hazardous Substance Source 

No.

Ecosystem 

Toxicity 

Factor 

Value**

Persistence 

Factor Value*

Ecosystem 

Bioaccumulation 

Value**

Ecosystem 

Toxicity/

Persistence 

Factor Value

(Table 4-20)

Ecosystem 

Toxicity/

Persistence/

Bioaccumulation 

Factor Value

(Table 4-21)

Reference

Metals

Arsenic 1, 2, 9 10 1.0 5,000 10 50,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 1

Chromium 1 10,000 1.0 500 10,000 5,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 3

Copper

1, 2, 3, 

4, 5, 6, 

9, 10 1,000 1.0 5,000 1,000 5,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 3

Lead

1, 2, 3, 

4, 5, 6, 

7, 9, 10 1,000 1.0 50,000 1,000 50,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 8
SWOF/Environment Toxicity/Persistence/Bioaccumulation

54

Table 14- Ecosystem Toxicity/Persistence/Bioaccumulation Factor Summary

Nickel

1, 2, 3, 

5, 9, 10 100 1.0 500 100 50,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 9

Zinc 1 10 1.0 50,000 10 500,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p.12

Semivolatiles

Benzo(a)anthracene 4 10,000 1.0 50,000 10,000 500,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 2

Benzo(a)pyrene 2 10,000 1.0 50,000 10,000 500,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 2 

Benzo(b)fluoranthene 6 - - - - - -

Chrysene 2 1,000 1.0 5,000 1,000 5,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 3

Fluoranthene 6 10,000 1.0 5,000 10,000 50,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 2

2-methylnaphthalene 2 100 0.4 50,000 40 2,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 9

Phenanthrene 2 10,000 0.4 50,000 4,000 200,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 9

Pyrene

2, 3, 4, 

6, 8 10,000 1.0 50,000 10,000 500,000,000

Ref. 1, 

Table 4-20, 

4-21; Ref. 

2, p. 10

Key:

* Persistence values assigned are based on Sand Creek, which is a river.

**Ecosystem Toxicity and Ecosystem Bioaccumulation values are assigned based on the surface category of fresh water. 

- No value in SCDM

The contaminants with the highest Ecosystem Toxicity/Persistence/Bioaccumulation Factor 

Value are benzo(a)anthracene, benzo(a)pyrene and pyrene (Ref. 1, Table 4-21; Ref. 2, pp. 1-13). 

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000
SWOF/Environment Hazardous Waste Quantity 

55

4.1.4.2.2 Hazardous Waste Quantity 

Source Number

Source Hazardous Waste 

Quantity Value (Section 

2.4.2.1.5)

Is Source Hazardous 

Constituent Quantity Data 

Complete? (yes/no)

1 57.69 No

2-10 21,738.42 No

TOTAL 21,796.11 No

The sum of the source hazardous waste quantity values is assigned as the Hazardous Waste 

Quantity Factor Value (Ref. 1, Sec. 2.4.2.2 and Table 2-6). The sum of the source hazardous 

waste quantity values for Surface Water Pathway, rounded to the nearest integer, is 21,796. 

Sum of Values: 21,796 

Hazardous Waste Quantity Factor Value: 10,000 (Ref. 1 Table 2-6)
SWOF/Environment Hazardous Waste Quantity 

56

4.1.4.2.3 Waste Characteristics Factor Category Value 

A Waste Characteristics Factor Category Value is assigned based on the Waste Characteristic 

Product. The hazardous substances with the highest ecosystem 

toxicity/persistence/bioaccumulation factor value for the watershed are benzo(a)pyrene, 

benzo(a)anthracene, and pyrene (Ref. 1, Section 4.1.4.2.3). These values are used to determine 

the water characteristic product. The Waste Characteristic Product is the product of the 

Ecosystem Toxicity/Persistence/ Factor Value and the Hazardous Waste Quantity Factor Value 

subject to a maximum product of 1 x 108

. This product is multiplied by the Ecosystem 

Bioaccumulation Potential Factor Value Subject to a maximum product of 1 x 1012. 

Using HRS Table 4-20 and Table 15 of this HRS documentation record, the Ecosystem 

Toxicity/Persistence value for benzo(a)pyrene, benzo(a)anthracene, and pyrene is 10,000. 

A Hazardous Waste Quantity Factor Value of 10,000 is assigned from the sum of Source 

Hazardous Waste Quantity Values for all the sources (Ref. 1, Section 2.4.2.2, Table 2-6). 

Ecosystem Toxicity/Persistence Factor Value = 10,000 

Hazardous Waste Quantity Factor Value = 10,000 

10,000 x 10,000 = 1 x 108

(Subject to a maximum product of 1 x 108

The Ecosystem Bioaccumulation Value for benzo(a)anthracene, benzo(a)pyrene and pyrene is 

50,000 (Ref. 2, p. 8). 

Ecosystem Bioaccumulation Value = 50,000 

(Ecosystem Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Factor Value: 

(1 X 108) x (50,000) = 5 x 1012

 

(Subject to a maximum product of 1 x 1012) 

A Waste Characteristics Product Value of 1 x 1012 receives a Waste Characteristic Factor Value 

of 1,000 (Ref. 1, Table 2-7).

(Ecosystem Toxicity/Persistence Factor Value

x Hazardous Waste Quantity Factor Value) x Bioaccumulation Factor Value: 1 x 1012

Waste Characteristics Factor Value: 1,000 
SWOF/-Environment Targets 

57

4.1.4.3 ENVIRONMENTAL THREAT- TARGETS

4.1.4.3.1 Sensitive Environments 

4.1.4.3.1.1 Level I Concentrations

No water, benthic, or tissue samples have been collected within the Surface Water

Pathway; therefore, Level l concentrations are not being scored (Ref. 1, Sec. 4.1.4.3.1.1). 

Level I Concentrations Factor Value: 0
SWOF/Environment-Level II Concentrations

58

4.1.4.3.1.2 Level II Concentrations

Wetlands, as identified on National Wetland Inventory maps as a PFO1A designation, which 

meets the 40 CFR 230.3 definition of a wetland, are located on the southwest corner of the site 

and are contiguous with Sand Creek (Ref. 30, pp. 1-2; Ref. 38). 

Level II concentrations have been established in the wetlands at PPE No. 1 to PPE No. 3 in Sand 

Creek (Figure 5 of this HRS documentation record). Chemical analyses of samples meet 

observed release criteria (Tables 7 and 9 of this HRS documentation record). 

The wetted perimeter of the wetlands subject to Level II contamination (Ref. 1, p. 51625) 

measures 2,510 feet (Figures 5 and 6 of this HRS documentation record; Ref. 30, p. 1). A value 

of 25 is assigned from Table 4-24 of the HRS for length of wetlands from >0.1 to 1 mile (Ref. 1, 

Sec. 4.1.4.3.1.2). 

Other listed sensitive environments will not be scored. The Level II concentration factor value is 

the sum of the wetlands value (25) and listed sensitive environments value (0): 

25 + 0 = 25 

Level II Concentrations Factor Value: 25
SWOF/Environment-Factor Category Value

59

4.1.4.3.1.3 Potential Contamination 

Wetlands

There is potential wetland frontage along Little Deep Fork River (Ref. 30, pp. 1 - 2). The 

potential contamination to the wetlands will not be scored at this time. 

Sum of Sensitive Environments Value + Wetland Value: 0

Potential Contamination Factor Value: 0