### HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD - REVIEW COVER SHEET

Name of Site: MacMillan Ring Free Oil

EPA ID No.: AR D008049207

Contact Persons

Site Investigation: Brenda Nixon Cook, NPL Coordinator, EPA Reg.6 (214) 665-7436 (Name) (Telephone)

Documentation Record: Brenda Nixon Cook, NPL Coordinator, EPA Reg.6 (214) 665-7436 (Name) (Telephone)

Pathways, Components, or Threats Not Scored

A lthough the surface water migration pathway score is sufficient to list the site, contamination in other media has been identified that may pose a threat to human health and the environment and may be evaluated in the future (Ref. 5)

. 1) Ground Water Pathway: The ground water migration pathway has not been scored because

, b ased on information available at this time, scoring of the ground water migration pathway would not significantly affect the listing decision ( Ref. 1, Sec. 2.2.3).

2) Soil Exposure Pathway: The soil exposure pathway has not been scored. Based on information available at this time, evaluation of the soil exposure pathway would not affect the listing decision (Ref. 1, Sec. 2.2.3).

3) Air Pathway: The air migration pat hway has not been scored. Based on information available at this time, evaluation of the air migration pathway would not affect the listing decision (Ref. 1, Sec. 2.2.3).

4) Surface Water Pathway: The Surface Water Pathway has been scored for the Human Food Chain Threat and Environmental Threat. The drinking water threat has not been scored. Based on information available at this time, evaluation of the drinking water threat would not affect the listing decision (Ref. 1, Sec. 2.2.3).

HRS Documentation Record MacMillan Ring Free Oil ARD008049207HRS Documentation Record 

### 1 MacMillan Ring Free Oil ARD008049207 

### HRS DOCUMENTATION RECORD

Name of Site: MacMillan Ring Free Oil

Site Spill Identifier No.: 063T

CERCLIS Site ID No.: ARD008049207

EPA Region: 6

Date Prepared: Dec ember 2013

Street Address of Site: MacMillan Road off Arkansas Highway 335*

City, County, and State: Norphlet, Union County, Arkansas 71759*

General Location within the State: The site is located in the City of Norphlet, Union County, Arkansas . Norphlet is located in south- central Arkansas (Ref. 3, p. 1).

Topographic Map(s): The following U.S. Geological Survey (USGS) 7.5

- minute topographic series map was used in locating the site: Smackover, Arkansas (19 62 ) (Ref. 3, p. 1).

Latitude/Longitude*: 33° 18’ 30.096 ” N, 92° 39 ’ 24.769 ” W

Latitude and Longitude coordinates were measured from the northern side of Source 2 where Ponds 705- 707 were histo rically located and were determined using a scaled topographic map and Geographic Information System ( GIS ) software (Ref. 4, pp. 1-2).

Scores

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 R ecord identify the general area the site is located. They repre sent 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. E PA lists national priorities among the known "releases or threatened releases" of hazard ous 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, disposed

, or placed, or has otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that a cer tain area may need to be addressed under CERCLA. Accordingly, EPA contemplates that the preliminary description of property boundaries at the time of scoring will be refined as more informa tion is developed as to where the contamination has come to be located.HRS Documentation Record 

### 2 MacMillan Ring Free Oil ARD008049207 

### NOTES TO THE READER

1. The following rule applies when citing references in this documentation record:

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 has a two

- digit number followed by the sequential number (e.g., Reference 4, page 1 is expressed as 040001 in Reference 4 ).

2. Hazardous substances are listed by the names used in the January 2004 (with March 2012 update) Superfund Chemical Data Matrix (SCDM) (Ref. 2).

3. Attachment A of this documentation record consists of the following figures:

• A-1 Site Location Map

• A-2 Property Layout Map

• A-3 Surface Water Pathway Map

• A-4 15- Mile Target Distance Limit

• A-5 Sample Location MapHRS Documentation Record 

### 3 MacMillan Ring Free Oil ARD008049207 

### REFERENCES CITED

1. 40 Code of Federal Regulations (CFR) Part 300, Hazard Ranking System; Final Rule. 14 December 1990. Volume 55, No. 241. Pages: 1. [A complete copy can be obtained from the Regional Docket upon request or found online at http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS Rule ].

2. U.S. Environmental Protection Agency (EPA). 2004. Superfund Chemical Data Matrix (SCDM) (excerpts). January 2004 with updated data factor values from March 2012. Pages: 20. [ A complete copy of SCDM is available at 

### http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm ].

3. U.S. Geological Survey (USGS) Topographic Maps. 19 62, S mackover

, Arkansas ; 19 62 (photorevised 1978)

, Calion , Arkansas ; 19 81, Harrell Brake, Arkansas (7.5- minute topographic series maps). Pages: 3.

4. Weston Solutions, Inc

. (WESTON ® 

### ). 2013. Project Note to File. Calculating the Latitude and Longitude coordinates of the Site . 24 July 2013 . Pages: 2.

5. WESTON. 2013. T rip Report for MacMillan Ring Free Oil Co. Inc. (excerpts) . Norphlet, Union County, Arkansas. ARD008049207. 28 May 2013. Pages: 147.

6. Arkansas Department of Environmental Quality ( ADEQ ) . 2011. Comprehensive Site Assessment. Norphlet Chemical ( MacMillan Ring Free Oil). Norphlet, Union County, AR. 25 April 2011. Pages: 584.

7. Arkansas Department of Pollution Control and Ecology ( ADPC&E )

. Facility Annual Hazardous Waste Report and correspondence between Macmillan Refinery and ADPC&E. MacMillan Ring- Free Oil Co. Inc. Norphlet, Arkansas. 31 D ecember 1983, 5 August 1985, and 30 October 1987. Pages: 5.

8. EPA. 1986- 2004. EPA Region 6 Correspondence. MacMillan Ring Free Oil. 29 July 1986 – 30 November 2004. Pages: 29.

9. ADPC&E. 1983-1994. ADPC&E Correspondence. MacMillan Ring Free Oil. N orphlet, Union County, Arkansas. 24 February 1983 – 17 October 1994. Pages: 43.

10. ADPC&E. 1990. R CRA Inspection. MacMillan Ring Free Oil. Norphlet, Union County, Arkansas. 29 May 1990 . Pag es: 74.

11. ADPC&E. 1991. C omprehensive Monitoring Evaluation. N or

- Ark Industrial Corp ( MacMillan Ring Free Oil Site). 24 July 1991. Pages: 116.

12. ADEQ. 2012. State Priority List Summary for NCI Facility. NCI Facility (formerly MacMillan Ring Free Oil). ARN000606985. October 2012. Pages: 6.

13. ADPC&E. 1987. NPDES Permit No. AR0000728. Nor

- Ark Industrial Corporation (formerly

### MacMillan Ring Free Oil) at 33 deg. 18’ 36” N, 92 deg. 39’ 15” W. Norphlet, Union County, Arkansas. 21 September 1987. Pag es: 1.

14. Hawkins and Metzger and Wright, Lindsey, & Jennings. 1989 and 1990. Correspondence to ADPC&E concerning ownership change. 13 April 1989 and 18 January 1990 . Pages: 2.

15. ADEQ . 201 2 . Official Photographic Log

. Evaluation for NPL Site Visit

. Norphlet Chemical Company, Norphlet, Union County, Arkansas. 27 January 2012 . Pages: 86.

16. WESTON. 2012. W etland s Evaluation. MacMillan Ring Free Oil Site. N orphlet, Union County, Arkansas. 16 August 2012. Pages: 13.

17. EPA . 2009. Pollution Repor t. Norphlet Chemical Inc. Norphlet, Union County, Arkansas. 29 September 2009 . Pages: 2.

18. National Drought Mitigation Center, United States Department of Agriculture (USDA) and the National Oceanic and Atmospheric Administration (NOAA). 2012. U.S. Drought Monitor

. 23 August 2012. Pages: 1.

19. Test America Laboratory, Inc . 201 2 . Test America Analytical Report. J ob ID 680 -82124-1. For Weston Solutions, Inc. 10 September 2012. Pages: 15.

20. ADPC&E. 199 2

. MacMillan Oil Refinery Final Pit Sludge Analysis

. Letter to Charles Fisher, EPA, Region 6. 8 September 1992 . Pages: 1 57.

21. WESTON. 2013. P roject Note to File. Pond Area Measurements. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 29 July 2013. Pages: 3.

22. WESTON. 2012. Norphlet Chemical Site Reassessment Photo Summary. 1 4

- 16 August 2012. Pages: 16.

23. Felton Environmental Services, Inc . 2005. Preliminary Site Assessment

. MacMillan Ring- Free Oil Company Site, Norphlet, Union County. Arkansas. 1 February 2005. Pages: 224.

24. Federal Emergency Management Agency (FEMA). 2007. Flood Insurance Rate Map. Union County, Arkansas, and Incorporated Areas. Map Number 05139C0145C. 28 September 2007. Pages 3.

25. WESTON. 2012. Q uality Assurance Sampling Plan for Site Reassessment. Norphlet Chemical, 600 MacMillan Road, Norphlet, Union County, Arkansas. August 2012. P ages: 228.

26. EPA Region 6 Laboratory. 201 3

. Final Analytical Reports

. Norphlet Chemical

. Project 12SF152. October - November 2012, February 2013 . Pages: 696.

27. MacMillan Petroleum. 1984

. Revised Closure Plan

. MacMillan Petroleum, Norphlet, Arkansas . June 1984 . Pages: 101.

HRS Documentation Record 

### 4 MacMillan Ring Free Oil ARD008049207

### 28. ADPC&E. 1995. Memorandum . Closeout of Outstanding Issues. MacMillan R ing Free Oil. Norphlet, Arkansas. 30 January 1995. Pages: 2.

29. EPA. F act Sheet. U sing Qualified Data to Document an Observed Release and Observed Contamination. EPA 540-F-94-028. November 1996. Pages: 18.

30. WESTON. Field Logbook s . WO# 20406.012.0 19 .0 718 .01. Field Logbook Notes for Norphlet Chemical . 06 June 2012 to 08 August 2012 . Pages: 27.

31. EPA. 1988. B est Demonstrated Available Technology (BDAT) Background Document for K048, K050, K051, K052 (excerpts). EPA/530- SW -88-031C. August 1988. Pages: 25.

32. Toxics Release Inventory Program. www.epa.gov/TRI/ . TRI Explorer search conducted for area code 7 1759. 2011 Data Update as of March 2013. Pages: 2.

33. EPA. 2013. Enviromapper for Envirofacts database. http://www.epa.gov/emefdata/em4ef.html?ve=16,33.29722213745117,- 92.66215515136719&pText=71759, AR . Accessed 18 July 2013. Pages: 20

.

34. WESTON. 201 3 . Project Note to File. Level II Wetland Perimeter Measurement. MacMillan Ring Free Oil , Norphlet, Union County, Arkansas

. 17 April 2013. Pages: 2.

35. Ecosystem Management and Restoration Research Program (EMRRP)

. 2001. Riparian Habitat Management for Reptiles and Amphibians on Corps of Engineers Projects. ERDC TN

EMRRP

- SI -22. August 2001. Pages 13.

36. WESTON . 201 3. Phone Conversation Record with Arkansas Game and Fish Commission South Central Regional Office. Fisheries in Hayes Creek, Flat Creek, Haynes Creek, Smackover Creek and the Ouachita River . 18 Jul 2013 . Pages: 1.

37. USGS. 2013. Surface-Water Annual Statistics for the Nation. USGS 07362100 Smackover Creek near Smackover, Arkansas. http://waterdata.usgs.gov/nwis/annual?referred_module=sw&search_site_no=07362100&f

. Accessed 22 April 2013. Pages: 1.

38. USGS. 2013. Surface- Water Annual Statistics for the Nation. USGS 0 7362000 Ouachita River at Camden, Arkansas. http://waterdata.usgs.gov/nwis/annual?referred_module=sw&search_site_no=07362000&f

. Accessed 22 April 2013. Pages: 1.

39. WESTON. 2013. Project Note to File. Calculating Overland Flow Distances

. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 9 May 2013. Pages: 3.

40. WESTON. 2013. Project Note to File. Slope Calculation

. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 24 April 2013. Pages: 1.

HRS Documentation Record 

### 5 MacMillan Ring Free Oil ARD008049207

### 41. WESTON. 2013. P roject Note to File. In

- Water Target Distance Limit Measurements

. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 28 May 2013. Pages: 2.

42. WESTON. 2013. P hone Conversation Record with ADEQ. Hayes Creek drainage ditches, Norph let , Union County, Arkansas. 10 May 2013. Pages: 1.

43. EPA. 1992. M emorandum. R equest for a Removal Action at MacMillan Ring Free Oil Company Site, Norphlet, Union County, Arkansas. 9 November 1992. Pages: 14.

44. EPA. 1997. R emov al Phase III Action Polreps . M acMillan Ring Free Oil Company Site, Norphlet, Union County, Arkansas. 17 March 1994 - 1 July 1997. Pages: 46.

45. Ecology and Environment, Inc. (E&E). 1998. CERCLA Biodegradation Project Removal Report for Macmillan Ring -F ree Oil Company, Norphlet, Union County, Arkansas. 13 M ay 1998. Pages: 512.

46. PDP Analytical Services. 1992. U.S. EPA CLP Form I Analyses Data Sheets. SDG P701. 23 June 1992. Pages: 65.

47. EPA. 1992. P olRep No. 4, M acMillan Oil Refinery, Norphlet, Union County, Arkansas. 22 June 1992. Pages: 3.

48. WESTON. 2013. Project Note to File. Sample Quant itation Limit (SQL) Calculation

. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 29 July 2013. Pages: 2.

49. WESTON. 2013. Project Note to File. Location of Site within Sub- Watershed Map

. MacMillan Ring Free Oil, Norphlet, Union County, Arkansas. 3 September 2013 . Pages: 3.

50. WESTON. 2013. Project Note to File. J Bias on Samples Analyzed Out of Hold Time. MacMillan Ring Free Oil, Norphlet, Un ion County, Arkansas. 5 September 2013 . Pages: 1.

HRS Documentation Record 

### 6 MacMillan Ring Free Oil ARD008049207HRS Documentation Record 

### 7 MacMillan Ring Free Oil ARD008049207 

### SITE SUMMARY

MacMillan Ring Free Oil (MacMillan) has also been referred to as Norphlet Chemical in several of the historical documents referenced. These two separate facilities have been located on the same property

, at different times, and operated by different owners, but the focus of this HRS Documentation Record is historical operations that occurred during ownership by MacMillan

. Norphlet Chemical did not use the sources identified in this HRS Documentation Record.

The former MacMillan Ring Free Oil s ite is located on MacMillan Road off Arkansas Highway 335

, Norphlet, Union County, Arkansas (Ref. 3, p. 1; Ref. 5, p. 2 ). The facility boundary is approximately 100 acres as depicted on Attachment A, Figure A -2. The facility is bordered by a r esidential subdivision and the Norphlet Public Schools complex (which includes kindergarten through 12th grade) on the west, a city park and baseball fields to the northwest and Hayes Creek to the north and

e ast

. In addition, railroad tracks run east of the facility with railroad spur s on the eastern portion of the property . To the south are undeveloped woods, the City of Norphlet Wastewater Treatments Ponds, and Massey Creek ( Attachment A, Figure A-1 ; Ref. 5, p. 2; Ref. 6, p. 10 ).

During MacMillan’s operation there were numerous tanks located throughout the property as seen in a plant layout map included in the MacMillan Closure Report (Ref. 27, p . 11). D uring a 1980 E PA Preliminary Assessment of the facili ty , 167 tanks with a total capacity of 510,000 barrels of refined products were identified (Ref. 20, pg. 21). In addition, a 50,000

- barrel bulk crude AST was still on

facility in January 2012, but had been removed when a site visit from EPA contractors oc curred in August 2012 (Ref. 6, p,. 21; Ref. 15, p. 72; Ref. 30, p. 3). To the north of the facility was a group of ASTs that were used for asphalt storage. In January 2012, t hese tanks were in various stages of disrepair, and several tanks had been removed (Ref. 15, pp. 80

- 86). During a June 2012 site visit by EPA contractors, these tanks were observed to have been removed (Ref. 30, p. 3).

The former Boiler House, located west of Source 4, i s still located on the property, with the boiler equipment stil l in place. The building is currently locked with asbestos hazard warning signs (Ref. 6, p. 21). The former canning building and drum storage building are still currently located on

- property , with chemicals observed throughout both areas (Ref. 6, p. 23). Several 55

- gallon metal and plastic drums were observed throughout the western and northern portions of the canning building. Some drums were physically damaged, dented, and or leaking. Additionally several bags of chemicals were located within the buildings, with physical conditions of the storage bags ranging from well wrapped with plastic to ripped and torn. The southwestern portion of the canning building contained n umerous 5- gallon buckets and 1

- liter containers of named and un

- named chemicals. At least three unlabeled 1,000 gallon plastic storage tanks enclosed by metal frames were observed and contained a brown liquid. Concrete flooring throughout the building had observable staining (Ref. 6, pp. 24, 146-162).

The area west of the canning and drum storage building is gravel covered with a number of metal pipe racks with process piping still in place. West of the piping racks is the area used by Norphlet Chemical for their manufacturing operation. All of the storage tanks, tower, and process vessels and piping are still in place from the Norphlet Chemical operation. Storm water from this area of the facility drains westward to a n ew small wastewater treatment system which is located on the eastern edge of the form er wastewater treatment plant. A water leak was discovered from a system of sumps from theHRS Documentation Record 

### 8 MacMillan Ring Free Oil ARD008049207 

### Norphlet Chemical process area. The runoff from the leak was flowing towards the Fire Water Pond located to the south (Ref. 6, p. 24).

The MacMillan facility is cur rently partially fenced along the west side of the property, but there is no fence along the railroad tracks to the east. Debris piles consisting of piping, empty drums, and used equipment and parts are located throughout the property. T hese piles are no t located on plastic or covered (Ref. 6, p p . 11, 133, 137) . E leven large surface impoundments (referred to in historical documents as ponds) were previously located on the south side of the facility and the east side of the railroad tracks (Ref. 20, pp. 2 2- 32; Ref. 23, pp. 38, 40). These ponds have been backfilled, and are marked by open areas covered by sparse vegetation ; these open areas are also visible in Attachment A, Figure A -2.

For HRS scoring purposes, the site consists of two sources which consi st of buried/backfilled surface impoundments, along with a release of hazardous substances to nearby surface water bodies.

The facility has a long history of industrial operations that are summarized as follows:

• As early as 1929, t he facility and surrounding property operated as a crude oil refinery and manufacturer of lubrication oil and asphalt products. During this time, the facility was called MacMillan Ring Free Oil Company, Inc. (Ref. 6, p. 34 ; Ref. 12, p p . 2 , 4 )

. In 1987, operations ceased due to an involuntary bankruptcy (Ref. 7, p. 5 ).

• In 1987, Nor

- Ark Industrial Corporation obtained a permit to discharge wastewater to nearby receiving waters at the property (Ref. 13, p.1) and eventually purchased the property in 1989 ( Ref. 10, p. 10 ; Ref. 14, p. 1 ). Nor

- Ark Industrial provided storage tank leasing for asphalt products until filing for bankruptcy in 1991 (Ref. 6, p. 10; Ref. 10, p. 10).

• In 1999, Norphlet Chemical Storage Inc. purchased the property at an auction. The property included appr oximately 106 acres that was part of the former MacMillan Ring Free Oil Refinery. The 106 acres that comprised MacMillan Refinery included a 94.8

- acre tract of land west of the railroad and the 10.7- acre tract of land east of the railroad (Ref. 6, p.34).

• In 2004, N orphlet Chemical Storage, Inc. sold the 94.8

- tract of land to Norphlet Chemical Properties, Inc. or Norphlet Chemicals, Inc. (NCI) (Ref. 6, p.34) . N CI planned to produce 1,1,2,2- tetrafluoroethane (Freon 134A) refrigerant from anhydrous hydrof luoric acid and trichloroethylene. The plant never operated as intended and filed for bankruptcy in 2008 (Ref. 12, p. 1).

Regulatory Enforcement History

Multiple phases of investigation have occurred at the property since 1980. These investigations and the regulatory history of the facility were obtained from the Arkansas Department of Environmental Quality (ADEQ) and are summarized in the following text.

During ownership of the facility

, MacMillan encountered both state and federal enforcement actions for multiple violations, including release of oilfield waste to Arkansas state waters, improper storage of hazardous waste, failure to perform required ground water monitoring and failure to implement approved closure plans for on-property impoundments (Ref. 9, pp. 1, 7, 10, 19 ).HRS Documentation Record 

### 9 MacMillan Ring Free Oil ARD008049207 

### In 1980, MacMillan Refinery filed a Notification of Hazardous Waste Activity Part A application with the United States Environmental Protection Agency ( EPA ) . D uring its opera tions, MacMillan used dissolved air flotation (DAF) systems as a part of their wastewater treatment process from 1975 until 1987. The DAF sludge located in three surface impoundments on the property (Ponds, 705, 706, and 707) contained petroleum waste products classified as hazardous waste (K048) under 40 C ode of Federal Regulations ( CFR ) §261.32 (Ref. 27, p.2). S ince the DAF impoundments contained a hazardous waste, a ground water monitoring system was required. For years, MacMillan communicated with EP A that they did not agree that the DAF should be regulated as hazardous waste and continued utiliz ing the impoundments without a ground water monitoring system (Ref. 9 , pp.2

- 3; Ref . 7, pp. 2

- 4; Ref. 27, p.2). D uring that time, several overflows to Hayes C reek from the DAF impoundments and other impoundments occur r ed (Ref. 8, pp. 5-6, 9; Ref. 9, p.1).

On 21 September 1984, the EPA issued a Compliance Order and Notice of Opportunity for Hearing against MacMillan Refinery charging the company with failure to install a ground water monitoring system (Ref. 8, pp. 1

- 2). In August 1985, Arkansas Department of Pollution Control and Ecology ( ADPC&E ) ordered MacMillan to either install the necessary controls for the impoundments containing hazardous waste to comply with its RCRA Part B Permit, or submit a closure plan (Ref. 7
, p. 1 ). The MacMillan facility did not comply with either order and

, in 1986, ADPC&E terminated MacMillan ’s status as a Treatment, Storage, Disposal (TSD) facility, and directed them to implement a closure plan for the on

- property surface impoundments (ponds) (Ref. 10 , p. 11). A closure plan was prepared by MacMillan and modified by ADEQ in May 1986, but the facility filed for bankruptcy before the plan wa s implemented (Ref . 7, p. 5).

Nor

- Ark purchased the property in 1989, assuming liability for all chemicals and contaminated media

on the property , but did not implement any ground water monitoring or the impoundment closure plan mandated by A D EQ ( Ref. 7, p p. 1 , 3 ) . Nor

- Ark also incurred several environmental violations during its ownership of the property . T hese violations ranged from failure to close the hazardous waste impoundments and monitor ground water ( Ref. 7, p. 1; Ref. 9, p. 6; Ref. 11, pp. 2, 5, 8 ), failure to maintain 12

- inch freeboard on t he impoundments (Ref. 9, p. 7), unpermitted discharges, improper storage of hazardous wastes, and failure to meet administrative and reporting requirements (Ref. 9, pp. 7- 21; Ref . 10 , pp. 2 -3, 21-22) , to violations of asbestos regulations (Ref. 8, pp. 8, 10

- 12). By 1990, Nor

- Ark had dismantled most of the facility and sold the majorit y of the equipment and fixtures (Ref. 14, p. 2 ). In March 1991, Nor-Ark filed for bankruptcy (Ref. 6, p. 10).

During its ownership under Nor

- Ark, and after the Nor

- Ark b ankruptcy, a number of facility visits by EPA, EPA contractors

, and ADPC&E documented evidence of overflow from the ponds and oily material released to the environment (Ref. 9, pp . 7

- 21, 2 3- 25, 27

- 28). A series of EPA Superfund removal actions were conducted from 1992 through 1997 to address the immediate issue of release to the environment (Ref. 9, pp. 28-30). These removal actions included the following:

• In 1992, a pproximately 31,500 g allons of free

- floating oil materials were recovered from impoundments, and oil and oil- contaminated vegetation along Hayes Creek and Massey Creek

were removed (Ref. 8, p. 11).

• In 1993, a pproximately 9,600 g allons of composite waste/flammable corrosive liquids and 50,080 gallons of waste oil were removed and tra nsported off -property . Asbestos on the facility (found in buildings and piping) was also abated and transported off

- property forHRS Documentation Record 

### 10 MacMillan Ring Free Oil ARD008049207 

### disposal. Removal activities of Comprehensive Environmental Response, Compensation, and Liabilit y Act ( CERCLA )- regulated wastes had ceased, and the remaining waste at the facility was slated for removal under the Oil Pollution Act ( OPA ) (Ref. 8, pp. 13, 22 -23).

• From 1994 through 1997, removal actions continued with pumping, treating, and discharging of OPA and CERCLA

- regulated wastes from the impoundments into the surrounding creeks and conducting on

- site bioremediation of approximately 43,000 cub ic yards of contaminated soil (Ref. 8, pp. 26-27 ; Ref. 9, pp. 40

- 41). The on

- site biodegradation of impou ndment sediments were treated on

- site within land treatment units (LTUs). OPA and CERCLA wastes were treated at the same time within 13 separate batches , and bioremediated soils from all impoundments (OPA and CERCLA) were used to backfill the impoundments ( Re f . 8, pp. 26

- 27; Ref. 45, pp. 5, 6).

EPA’s removal actions were conducted to mitigate the imminent threat to the public health and environment; however, these removal actions did not address environmental concerns of total petroleum hydrocarbon ( TPH )- contaminated soil and contaminated surface water runoff that existed at the facility (Ref. 6, p. 37; Ref. 9, pp. 41-43 ).

The facility historically has had a mix of OPA and CERCLA wastes. It was discovered near the end of the OPA response, from state recor ds and conversations with a former employee, that the impoundments (ponds) had been contaminated with the following listed Resource Conservation and Recovery Act (RCRA) hazardous wastes generated by petroleum refining operations: K048 - DAF, K049 – slop oil emulsion solids, K050 – heat exchanger bundle cleaning sludge, K051 - American Petroleum Institute ( API ) separator sludge, and K052 – tank bottoms. These RCRA hazardous wastes also constitute hazardous substances pursuant to Section 101(14) of the CERCLA

. These RCRA hazardous wastes have commingled with the contents of impoundments that had been considered OPA regulated (Ref. 43, p. 3).

In April 2009, an ADEQ inspection prompted the State to request an emergency removal action by EPA. ADEQ had reported corrosion on tank relief valves associated with tanks containing anhydrous hydrofluoric acid (AHF) and AHF mixtures. The tanks (associat ed with Norphlet Chemical operations and not MacMillan) were located approximately 500 feet from the Norphlet Public School complex. Initial emergency actions conducted by EPA included removal of the AHF and AHF mixtures, construction of a scrubber to neu tralize residual AHF remaining in tanks and flow lines, and decontamination of the associated tanks and piping (Ref. 17, pp. 1, 2 ).

Although EPA 

### Emergency Response and Removal Actions took place on the property from 1992- 1997, and in 2009, t he activities p erformed to date were conducted to stabilize the S ite

, and all source materials cited in this report currently remain on -site (Ref. 6, pp. 1-27 ; Ref. 28, pp. 1-2 ). In April 2010, the facility was placed on the State Priority List under the Arkansas Pollution Control and Ecology Commission’s Regulation No. 30. The facility was listed due to the potential for soil, surface water, and/or ground water contamination on - and off

- site and the need to remediate the s ite to protective levels (Ref. 12, p. 2).HRS Documentation Record 

### 11 MacMillan Ring Free Oil ARD008049207 

### Site Assessment History

The facility has undergone multiple assessments from 1981

- 2011 analyzing ground water, s urface water, surface soil, sub surface soil, and sediment. P ast investigations include a Site Assessment conducted by B&F for MacMillan Ring F ree Oil in 1987 ; EPA

- lead investigations in 1979, 1981, 1985, 1993, and ongoing from 1994

- 1997 (Ref. 6, p. 78 -81); and a Comprehensive Site Assessment (CSA) commissioned by ADEQ in 2011 (Ref. 6, pp. 1-584).

The 2011 CSA performed by ADEQ contractors FTN Associates, Ltd. and Center for Toxicology and Environmental Health (CTEH) was conducted to determine the nature and extent of hazardous substances released into the environment, the potential for additional releases of hazardous substances, and the current and possible future risks to human health and the environment from the s ite. Results indicated contamination of the surface and subsurface soil, ground water, and surface water/sediment (Ref. 6, pp.12

- 13, 77

- 105). C ontaminants of concern included polycyclic aromatic hydrocarbons (PAHs), TPH, and metals (Ref. 6, pp. 55, 91).

Many of the ground water samples collected during the CSA had hydrocarbon odors; some samples effervesced which indicated the presence of methane gas; and others were characterize d by oil sheens or contained wastes (Ref. 6, p. 12) . T he plume of ground water co ntamination exists beneath the property , and given the potentiometric surface, off -property migration west of the site is not expected

, and the southeast extent of the plume has not been defined (Ref. 6, p. 85).

The CSA noted extensive black hydrocarbon surface soil staining in the area of the former tan k farms and drainage ditches at the facility , oil sheens on the surface of former impoundments ( ponds) after rainfall events, and yellow and green stains on surface soil in the area of the former NCI plant (Ref. 6, pp. 12, 87). Surface soil sampling conducted during the CSA also identified TPH-contamination in the area of the former tank farm and the back filled former impoundments on the east and west sides of the railroad tracks (Ref. 6, pp. 12, 87, 99) , as well as one “hot spot” of PAH

- contaminated surface soil located within the surface water drainage pathway directly down gradient from Tank 514 (Ref. 6, pp

. 12, 99, 122). TPH was also detected in surface water samples taken from Hayes Creek, Massey Creek, the on -property firewater pond, and a drainage pathway on the east side of the facility that flows into Hayes C reek (Ref. 6, pp. 13, 91, 92, 99). Sediment samples collected from Hayes Creek indicated the presence of TPH, chromium, and lead (Ref. 6, pp. 13, 92) . D uring the sampling event, samplers observed a sheen along portions of Hayes Creek and in the drainage ditch on t he west side of the railroad tracks (Ref. 6, pp. 91, 99).

In August 2012, the EPA Region 6 Prevention and Response Branch (EPA

- PRB or EPA) performed supplemental sampling for Site Reassessment (SR) at MacMillan to determine whether the s ite
pre sents a threat to public health or welfare of the United States or the environment in accordance with 40 CFR 300.415. EPA collected surface water and sediment samples from locations within Hayes Creek; sediment, surface water, and soil samples from overland flow pathways ; soil waste samples from on

- site sources; passive soil gas samples between the historical ground water plume bo undary and the Norphlet School S ystem complex west of the facility ; and ground water samples from a background location and from monitoring wells at existing locations on the facility ( Ref. 5 , p p . 4 , 5 ; Ref. 25, pp. 5-6 ).HRS Documentation Record 

### 12 MacMillan Ring Free Oil ARD008049207 

### The EPA Team also conducted a wetland survey on 16 A ugust 2012 that identified that one of the former impoundments (Pond 713) east of the rail line on the property currently serves as a wetland habitat. Although the wetland evaluation was conducted under drought conditions, historically, this area has been inundated with water as observed during previous site visits and by historical aerials, and indicators of wetland hydrology were noted in the evaluation. T he wetland habitat is approximately 50 feet south of former Ponds 710 through 712 on the east side of the facility and abutting a loop of Hayes Creek

. ( Ref. 15, pp. 38, 41; Ref. 16, pp. 1 -13 ; Ref. 18, pp. 1; Ref. 24, pp. 1

- 2; Ref. 30, pp. 1 -2 ; Ref. 42 ). The wetland survey also identified that Hayes Creek is a sensitive riparian habitat (Ref. 16, pp.1, 3, 4).

Results from the EPA SR sampling event indicated an observed release to the surface water pathway from the s ite, with some samples containing Level II concentrations. Chemicals of concern released to the pathway include metals, and semivolatile organic compounds ( SVOCs ). The i nvestigation identified two sources and six probable points of entry where hazardous substances from the sources were entering the surface water pathway. The two sources identified are the three separate backfilled former surface impoundments ( ponds) on the east side of the railroad tracks ( Pond 710, Pond 711, and Pond 712), and the area of the backfilled former impoundments west of the firewater pond (Ponds 704- 707) ( Ref. 5, p. 13 ; Ref. 5 , pp. 14-18 ). Analytical results for samples collected at prob able points of entry to Hayes Creek, and from within Hayes Creek itself, indicated the presence of metals, and SVOCs. A nalytical results for samples collected at the probable point of entry to th e wetland contiguous to Hayes Creek (PPE

- 03) and the wetland itself also indicated the p resence of metals and SVOCs (Ref. 5, pp. 6, 13 ; Ref. 5 , pp. 26-31, 20; Ref. 19, pp. 6-12).HRS Documentation Record 

### 13 MacMillan Ring Free Oil ARD008049207 

### WORKSHEET FOR COMPUTING HRS SITE SCORE

S S 2



### 1. Ground Water Migration Pathway Score (S gw 

### ) NS NS (from Table 3 -1, line 13)

2a. Surface Water Overland/Flood Migration Component 100 10,000 (from Table 4 -1, line 30)

2b. Ground Water to Surface Water Migration Component NS NS (from Table 4 -25, line 28)

2c. Surface Water Migration Pathway Score (S sw 

### ) NS NS (Enter the larger of lines 2a and 2b as the pathway score)

3. Soil Exposure Pathway Score (S s 

### ) NS NS (from Table 5 -1, line 22)

4. Air Migration Pathway Score (S a 

### ) NS NS (from Table 6 -1, line 12)

5. Total of S gw 2 

### + S sw 2 

### + S s 2 

### + S a 2



### ---- 10,000

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

Notes :

S Score S 2 Score squared NS Not scored

Tables 3

- 1, 4

- 1, 4

- 25, 5

- 1, and 6

- 1 refer to score sheets presented in the HRS (Ref. 1). Table 4- 1 is reproduced in t he following pages of this HRS Documentation R ecord for the convenience of the reader.HRS Documentation Record 

### 14 MacMillan Ring Free Oil ARD008049207 DRINKING WATER THREAT - Not Scored (NS)



### Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

1. Observed Release 550 550 2. Potential to Release by Overland Flow: 2a. Containment 10 NS 2b. Runoff 25 NS 2c. Distance to Surface Water 25 NS 2d. Potential to Release by Overland Flow (lines 2a[2b + 2c]) 500 NS 3. Potential to Release by Flood: 3a. Containment (Flood) 10 NS 3b. Flood Frequency 50 NS 3c. Potential to Release Flood (lines 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

Waste Characteristics

6. Toxicity/Persistence a NS 7. Hazardous Waste Quantity a NS 8. Waste Characteristics (Toxicity/Persistence x Hazardous Waste Q uantity, then assign a value from Table 2

- 7) 100 NS Targets

9. Nearest Intake 50 NS 10. Population 10a. Level I Concentrations b NS 10b. Level II Concentrations b NS 10c. Potential Contamination b NS 10d. Population (lines 10a + 10b + 10c) b NS 11. Resources 5 NS 12. Targets (lines 9 + 10d +11) b 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 NSHRS Documentation Record 

### 15 MacMillan Ring Free Oil ARD008049207 HUMAN FOOD CHAIN THREAT



### Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

14. Likelihood of Release (Same value of line 5) 550 ___550

Waste Characteristics

15. Toxicity/Persistence/ Bioaccumulation a 5 x 10 8
16. Hazardous Waste Quantity a 1 0,000 17. Waste Characteristics (Toxicity/Persistence/Bioaccumulation x Hazardous Waste Q uantity, then assign a value from Table 2

- 7) 1,000 1,000

Targets

18. Food Chain Individual 50 20 19. Population 19a. Level I Concentrations b 0 19b. Level II Concentrations b 0 19c. Potential Human Food Chain Contamination b 0. 0 000006 19d. Population (lines 19a + 19b + 19c) b 0.000 0 00 6 20. Targets (lines 18 + 19d) b 20.000 0 00 6

Human Food Chain Threat Score

21. Human Food Chain Threat Score [(lines 14 x 17 x 20)/82,500 subject to a maximum of 100] 100 100.00HRS Documentation Record 

### 16 MacMillan Ring Free Oil ARD008049207 ENVIRONMENTAL THREAT



### Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

22. Likelihood of Release (Same value of line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence Bioaccumulation a 5x10 8
24. Hazardous Waste Quantity a 1 0,0 00 25. Waste Characteristics (Ecosystem Tox./Persistence x Bioaccumulation x Hazardous Waste Quantity, then assign a value from Table 2

- 7) 1,000 1,000

Targets

26. Sensitive Environments 26a. Level I Concentrations b 0 26b. Level II Concentrations b 25 26c. Potential Contamination 26c. Potential Contamination b 0 26d. Sensitive Environments (lines 26a + 26b + 26c) b 25 27. Targets (value from line 26d) b 25

Environmental Threat Score

28. Environmental Threat Score [(lines 22 x 25 x 27)/82,500 subject to a maximum of 60] 60

___ 100 .00

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 .00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE

30. Component Score (Highest score from Line 29 for all watersheds evaluated, subject to a maximum of 100) 100 100.00Source Characterization – Source 1

HRS Documentation Record 

### 17 MacMillan Ring Free Oil ARD008049207 

### SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 1 – Buried/Backfilled Surface Impoundment s (Pond s 710, 711, and 712)

Source Type

The area to the east of the former MacMillan Refinery and the railroad tracks contained three surface impoundments (ponds ) (Source 1) which had been historically used by MacMillan operations for storing crude oil. O ne of these ponds, historically referred to as Pond 712 as well as Pond 4 is approximately 61,000 s quare feet (ft 2 

### ) in area (Ref. 20, pp. 11, 20; Ref. 21). In 1980, du ring a Preliminary Assessment ( PA ) conducted by EPA contractors

, Pond 712/4 was found to contain a total volume of 450,000 gallons (Ref. 20, p . 25 ). The pond historically referred to as Pond 711 as well as Pond 6 is approximately 12,600 ft 2 

### in area (Ref. 20, pp. 11, 20; Ref. 21, pp. 1-3). In 1980, during a PA conducted by EPA contractors

, Pond 711/6 was found to contain a total volume of 225,000 gallons (Ref. 20, p . 27 ). The pond historically referred to as Pond 710 as well as Pond 7 is approximately 10,800 ft 2 

### in area (Ref. 20, pp. 11, 20; Ref. 21). In 1980, during a PA conducted by EPA contractors

, Pond 710/7 was found to contain a total volume of 240,000 gallons (Ref. 20, p. 28 ).

Although historically, these ponds contained segregated wastes, during remediation activities conducted in 1995, OPA and CERCLA wastes were treated at the same time within 13 separate batches , and bioremediated soils from all impoundments (OPA and CERCLA) were used to backfill the impoundments ( Ref. 8, pp. 26 -27; Ref. 45, pp. 5, 6) . In November 1995, treated soil from the CERCLA regulated waste was placed back into Source 1 (Ref. 44, p. 22 ). According to ADPC&E, although Source 1 was ba ckfilled with soil t hat was bio remediate d, it is likely that there are a ffected soils left in place , as reportedly the financial resources were not available at the time to meet proposed cleanup criteria (Ref. 6, p. 81; Ref. 28, pp. 1

- 2). Sidewall contamination remained in p lace, as it was outside the scope of EPA Emergency Response Branch actions (Ref. 9, p. 42). The location of the backfilled Source 1 is still apparent due to lack of vegetation present (Ref. 6, p. 22; Ref. 22, pp. 10-12).

Ponds 710, 711, and 712 (Source 1) operated in the past without any freeboard, or liner and discharges to Hayes Creek were observed (Ref. 20, pp. 11, 25, 35; Ref. 23, p. 27 ). In 1994, Source 1 remained open and visual staining was observed on the earthen berms of the ponds (Ref . 23, p. 32) . Source 1 has a history of discharging to the adjacent Hayes Creek ( Re f . 20, p. 11; Ref. 23, pp. 40, 43). Historically

, Source 1 overflowed during floods that were documented in December 1982 and January 1983. T he oily material release cove red approximately 150 t o 200 a cres of Ouachita River bottom (Ref. 23, p. 157).

Source 1 is classified as the HRS source type “Buried/Backfilled Surface Impoundment” (Ref. 1, Table 2- 5).Source Characterization – Source 1

HRS Documentation Record 

### 18 MacMillan Ring Free Oil ARD008049207 

### Source Location

Source 1 is located approximately 1 50 feet east of the railroad tracks and is also located adjacent to, and abutting

, the west side of Hayes Creek (Ref. 6, pp. 30, 31). The location of the backfilled Ponds 712, 710, and 711, Source 1, is depicted on Attachment A, Figure A-2.

Source Containment

Release To Surface Water

During 2012 field activities, there was no evidence of a maintained engineered cover or any run

- off management system , and Source 1 functioned without a liner ( Ref. 20, p. 25; Ref. 22, pp. 10 -12)

. Although Source 1 ha s been backfilled, placement of an impermeable membrane was deemed too expensive during the closeout of the pond (Ref. 28, p. 2).

Containment Value: 10

2.4.1 Hazardous Substances

During a Sampling Inspection conducted in 1985 by EPA contractors, a sample was taken from Source 1. M ainly unknown organics were detected in the sample (Ref. 20, p. 1 1). Sampling conducted in 1992 on the sludge from Ponds 711 and 712 of Source 1, before removal activities were conducted, had the following chromium levels detected. Concentrations of chromium were at 24.9 mg/kg and 16.9 mg/kg respectively (Ref. 46, pp. 49, 50) . Chromium is not a hazardous constituent associated with OPA wastes, but is associated with DAF and has been an issue at the site for a long time ( Ref. 20, p. 4; Ref. 27, p. 3).

As part of SR sampling of the MacMillan facility from 13 through 17 August 2012, EPA contractors collected three solid waste sample s from Source 1 (Ref. 5, pp. 5; Ref. 22, pp. 10 -12; Ref. 25, p. 21). The sample s were analyzed for target compound list ( TCL ) volatile organic compounds ( VOCs ) , TCL SVOCs, pesticides, and polychlorinated biphenyls ( PCBs ) by the Contract Laboratory Program ( CLP ) Statement of Work ( SOW ) for Multi

- Media, Multi

- Concentration Organic Analysis, OLM04.2, and T AL metals with mercury by CLP SOW Multi

- Media, Multi

- Concentration Inorganics Analysis, ILM05 .3 (Ref. 25, p. 23)

. 

### TCL S VOCs were also analyzed by EPA SW 846 Method 8270 for low

level PAH s (Ref. 26, pp.431

- 432). The samples were submitted to the EPA Region 6 Environmental Services Branch Laboratory, located in Houston, Texas (Ref. 5, p. 5; Ref. 26, pp. 1, 309, 431).

Analytical evidence of the contamination in the waste source sample s associated with the backfilled Ponds 710-712 (Source 1) located o n the MacMillan s ite is summarized below.

Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg)

EPA SR Sampling Activities – August 2012

Anthracene PS

- 01

- 03

- 51 0.0183 J 0.0056 Ref. 26 , p p

. 431

- 433, 546; Ref. 30, p. 9Source Characterization – Source 1

HRS Documentation Record 

### 19 MacMillan Ring Free Oil ARD008049207 Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg)
Benzo(a)anthracene PS

- 01

- 03

- 51 0.0872 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9

Benzo(a)pyrene PS

- 01

- 03

- 51 0.0617 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Benzo(k)fluoranthene PS

- 01

- 03

- 51 0.163 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Benzo(g,h,i)perylene PS

- 01

- 03

- 51 0.040 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Chrysene PS

- 01

- 03

- 51 0.285 J 0.0224 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Dibenz(a,h)anthracene PS

- 01

- 03

- 51 0.011 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9

Fluoranthene PS

- 01

- 03

- 51 0.0832 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Indeno(1,2,3

- cd)pyrene PS

- 01

- 03

- 51 0.0224 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Naphthalene PS

- 01

- 03

- 51 0.0927 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9

2- Methylnaphthalene PS

- 01

- 03

- 51 0.159 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9

Phenanthrene PS

- 01

- 03

- 51 0.148 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9 Pyrene PS

- 01

- 03

- 51 0.149 J 0.0056 Ref. 26, pp. 431

- 433, 546; Ref. 30, p. 9

Arsenic PS

- 01

- 03

- 51 1.8 0.5 Ref. 26 , p p

. 1- 3, 125 ; Ref. 30, p. 9

Chromium PS

- 01

- 03

- 51 1,120 1.1 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9

Lead PS

- 01

- 03

- 51 26.0 0.5 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9 Manganese PS

- 01

- 03

- 51 113 0.5 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9

Mercury PS

- 01

- 03

- 51 0.223 0.074 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9

Vanadium PS

- 01

- 03

- 51 11.9 2.2 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9

Zinc PS

- 01

- 03

- 51 49.1 2.2 Ref. 26, pp. 1

- 3, 125; Ref. 30, p. 9 Acenaphthylene PS

- 02

- 03

- 51 0.0107 J 0.0044 Ref. 26, p p

. 431

- 433, 550 ;Ref. 30, pp. 9

- 10
Anthracene PS

- 02

- 03

- 51 0.0188 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Benzo(a)anthracene PS

- 02

- 03

- 51 0.0372 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Benzo(a)pyrene PS

- 02

- 03

- 51 0.0328 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Benzo(k)fluoranthene PS

- 02

- 03

- 51 0.0721 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Benzo(g,h,i)perylene PS

- 02

- 03

- 51 0.0373 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Chrysene PS

- 02

- 03

- 51 0.117 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Dibenz(a,h)anthracene PS

- 02

- 03

- 51 0.0067 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10
Fluoranthene PS

- 02

- 03

- 51 0.0378 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10
Fluorene PS

- 02

- 03

- 51 0.0378 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Indeno(1,2,3

- cd)pyrene PS

- 02

- 03

- 51 0.0157 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10Source Characterization – Source 1

HRS Documentation Record 

### 20 MacMillan Ring Free Oil ARD008049207 Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg)

2- Methylnaphthalene PS

- 02

- 03

- 51 0.122 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Naphthalene PS

- 02

- 03

- 51 0.0661 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10
Phenanthrene PS

- 02

- 03

- 51 0.116 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10 Pyrene PS

- 02

- 03

- 51 0.0817 J 0.0044 Ref. 26, pp. 431

- 433, 550;Ref. 30, pp. 9

- 10
Arsenic PS

- 02

- 03

- 51 1.2 0.5 Ref. 26, p p. 1

- 3, 129 ; Ref. 30, pp. 9

- 10

Chromium PS

- 02

- 03

- 51 3.5 1.0 Ref. 26, pp. 1

- 3, 129; Ref. 30, pp. 9

- 10 Chromium(VI) PS

- 02

- 03

- 51 2.9 0.51 Ref. 19 , p. 7
Lead PS

- 02

- 03

- 51 19.5 0.5 Ref. 26, pp. 1

- 3, 129; Ref. 30, pp. 9

- 10 Manganese PS

- 02

- 03

- 51 89.8 J * 0.5 Ref. 26, pp. 1

- 3, 129; Ref. 30, pp. 9

- 10

Mercury PS

- 02

- 03

- 51 0.114 0.067 Ref. 26, pp. 1

- 3, 1 30 ; Ref. 30, pp. 9

- 10

Vanadium PS

- 02

- 03

- 51 6.5 2.0 Ref. 26, pp. 1- 3, 129; Ref. 30, pp. 9

- 10
Zinc PS

- 02

- 03

- 51 27.3 2.0 Ref. 26, pp. 1

- 3, 129; Ref. 30, pp. 9

- 10

Anthracene PS

- 03

- 03

- 51 0.0117 J 0.0044 Ref. 26, p p. 431

- 433, 554 ; Ref. 30, p. 10 Benzo(a)anthracene PS

- 03

- 03

- 51 0.0236 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10

Benzo(a)pyrene PS

- 03

- 03

- 51 0.0238 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Benzo(k)fluoranthene PS

- 03

- 03

- 51 0.0591 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Benzo(g,h,i)perylene PS

- 03

- 03

- 51 0.0249 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Chrysene PS

- 03

- 03

- 51 0.0927 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Dibenz(a,h)anthracene PS

- 03

- 03

- 51 0.0048 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10

Fluoranthene PS

- 03

- 03

- 51 0.0267 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Indeno(1,2,3

- cd)pyrene PS

- 03

- 03

- 51 0.0105 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Naphthalene PS

- 03

- 03

- 51 0.0777 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10

Phenanthrene PS

- 03

- 03

- 51 0.0815 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10 Pyrene PS

- 03

- 03

- 51 0.0572 J 0.0044 Ref. 26, pp. 431

- 433, 554; Ref. 30, p. 10

Arsenic PS

- 03

- 03

- 51 13 0.5 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10

Chromium PS

- 03

- 03

- 51 3.1 1.0 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10

Lead PS

- 03

- 03

- 51 13.1 0.5 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10 Manganese PS

- 03

- 03

- 51 86.4 0.5 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10

Mercury PS

- 03

- 03

- 51 0.132 0.071 Ref. 26, pp. 1

- 3, 13 4 ; Ref. 30, p. 10

Vanadium PS

- 03

- 03

- 51 7.7 2.1 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10

Zinc PS

- 03

- 03

- 51 30.4 2.1 Ref. 26, pp. 1

- 3, 133; Ref. 30, p. 10

Notes: (mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg ) J I dentification of analyte s is acceptable; the reported value is an estimate because the samples were extracted past holding time. Concentrations should be considered minimum values ( Ref. 26 , p. 432). The estimated values are bias ed low (Ref. 26, p. 432; Ref

. 50, p. 1)

.Source Characterization – Source 1

HRS Documentation Record 

### 21 MacMillan Ring Free Oil ARD008049207 J* I dentification of analyte is acceptable; the reported value is an estimate due to outlying quality control parameters (Ref. 26 , pp. 3, 695). These estimated values are bias ed low as the samples were extracted out of the hold time (Ref. 26, p. 432; Ref. 50

, p. 1 ).
1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is adjusted for sample aliquot, sample volume, and dilutions for the analysis and meets the definition of Sample Quantitation Limit (SQL) as defined by the HRS (Ref. 1, Sect ion 1.1; Ref. 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2).


### Although low levels of PAHs are consistent with oil waste, these contaminants are also present within the CERCLA hazardous waste. In addition, elements such as chromium, mercury, and zinc are present withi n Source 1 and these contaminants are not associated with OPA wastes, but with the RCRA hazardous K048 through K052 wastes (Ref. 31, pp. 12-16, 18-23, 25).

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The hazardous constituent quantity for Source 1 could not be adequately determined according to HRS requirements; that is the total mass of all Comprehensive Environmental Response, Compensation, and Liab ility Act (CERCLA) hazardous substances in the source is not known and cannot be estimated with reasonable confidence (Ref. 1, S ection 2.4.2.1.1). T here are insufficient historical and current data (manifests, potentially responsible party (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 1 w ith reasonable confidence. S coring proceeds to the evaluation of Tier B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity- Not Evaluated (NE)

The hazardous wastestream quantity for Source 1 could not be adequately determined according to HRS requirements; that is the mass of the wastestream plus the mass of any additional CERCLA pollutants and contaminants that are allocated to the source is not known and cannot be estimated with reasonable confidence (Ref. 1, S ection 2.4.2.1.2). T here are insufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) available to adequately calculate the mass of the wastestream plus the mass of any additional CERCLA pollutants and contaminants in the source and the associated releases from the source. Therefore, there is insufficient information to e valuate the associated releases from the source to calculate the hazardous wastestream quantity for Source 1 w ith reasonable confidence. S coring proceeds to the evaluation of Tier C, volume (Ref. 1, Section 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

The dep th of the buried/backfilled ponds could not be accurately determined based on i nformation available. Therefore, information is not sufficient to evaluate Tier C and it is not possible to adequately determine a volume for Source 1 (Ref. 1, Section 2.4.2.1. 3 ). Source 1 has been assigned a val ue of 0 for the volume measure. Scoring proceeds to the evaluation of Tier D, area (Ref. 1, SectionSource Characterization – Source 1

HRS Documentation Record 

### 22 MacMillan Ring Free Oil ARD008049207 

### 2.4.2.1.4 ).

2.4.2.1.4 Tier D: Area

An approximate calculation for the area of Source 1 w as performed using GIS software. T he GIS software calculated the area of the polygon drawn over the footprint of the buried/backfilled ponds

, visible by sparse vegetation within a wooded area, as seen on aerial photographs (Ref. 21 ). Th e GIS software calculated the area of the buried/backfilled Ponds 710 through 712 to be 81,300 ft 2 

### (Ref. 21, pp. 1 -2) . T he Tier D equation for assigning a value for the area of a buried/backfilled surface impoundment is A/13 (Ref. 1, Table 2- 5). Calculati ons for Ponds 710 through 712 are as follows:

Ponds 710 - 712 : 81,300 square feet Area of Source 1 (ft 2 

### ): 81,300 Area Assigned Value = 81,300/13 Area Assigned Value = 6,253.846

2.4.2.1.5 Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous wastestream quantity (Tier B), Volume (Tier C), and Area (Tier D) should be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Ti er Evaluated Source 1 Values
A Not Evaluated
B Not Evaluated
C 0
D 6,253

. 846



### Source Hazardous Waste Quantity Value: 6,253.846Source Characterization - Source 2

HRS Documentation Record 

### 23 MacMillan Ring Free Oil ARD008049207 

### SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 2 – DAF Settling Unit (Ponds 704, 705, 706, and 707)

Source Type

The area to the southwest of the former MacMillan Refinery and west of the fire water pond contained four surface impoundments (ponds) (Source 5), covering an are a of approximately 193,660 ft 2 

### , which had historically been used by MacMillan operations to store DAF sludge (Ref. 21; Ref. 27, p. 3). DAF sludge is a listed hazardous waste due to the presence of hexavalent chromium and lead in the DAF float materials (Ref. 27, p. 3) . Therefore DAF sludge is considered a K048 through K052 listed hazardous waste that is CERCLA eligible (Ref. 20, pp. 1 -4; Ref. 45, p. 15 ). In historical reports, these surface impoundments are referred to as Ponds 704, 705, 706, and 707 (Ref. 23, p. 57, 163; Ref. 27, p. 2 ). These surface impoundments (ponds) were located in a series and were connected to each other by flow lines . The DAF float gravity flowed via a 6

- inch line to Pond 706 where the sludge settled to the bottom of the pond. Water from Pond 706 flowed via a flow line below the surface to Pond 705 and again via a flow line to Pond 707 (Ref. 27, pp. 2, 3). Po nd 704 (also called 5

- acre Pond) was utilized

as wastewater treatment pond that received runoff of the CERCLA wastes from Ponds 705 -707 when they were full and overflowing (Ref. 10, p. 28; Ref, 23, p p. 27 , 40 ). Pond 704 was believed to be connected to Ponds 705

- 707 via underground pipes and/or broken earthen levees (Ref. 43, p. 2). Together all these po nds operated as a DAF settling unit. EPA estimated that the total capacity of the ponds (Source 5) was approximately 30,000 cubic yards ( Ref. 23 , p. 27 ). In 1992, ADPC&E noted that Pond 705 contained evidence of oily staining and the berm had collapsed on the far south side allowing liquid to flow f r eely into Pond 707. Pond 706 had evidence of oily staining and dead vegetative growth around the pond. Pond 707’s berm had also collapsed on the southwest side allowing liquid to flow freely into Pond 704 (Ref. 9, p. 24 ). During a 1992 EPA assessment it was noted that Pond 704 was full and had recently overflowed to Massey Creek (Ref. 23, p. 40). The DAF settling units (ponds) operated in the past without any freeboard or liner and overtopping of dikes was observed (Ref. 20, pp. 49, 77, 78, 80, 82, 83, 156, 157; Ref. 23, p. 27).

OPA and CERCLA wastes were treated at the same time within 13 separate batches , and bioremediated soils from all impoundments (OPA and CERCLA) were used to backfill the impoundments ( Ref. 8, pp. 26 -27; Ref. 45, pp. 5, 6). According to ADPC&E, a lthough Ponds 70 4-707 were backfilled with soil that was bioremediated, it is likel y that there are affected soils left in place, as reportedly the financial resources were not available at the time to meet proposed cleanup criteria (Ref. 6, p. 81; Ref. 28, pp. 1

- 2). Sidewall contamination remained in place, as it was outside the scope of EPA Emergency Response Branch actions (Ref. 9, p. 42). The location of the backfilled Ponds 70 4- 707 (Source 2 ) is still apparent due to lack of vegetation present; however, individual ponds are no longer discernible (Ref. 6, p. 22; Ref. 22, pp. 10- 12).

Source 2 is classified as the HRS source type “Buried/Backfilled Surface Impoundment” (Ref. 1, Table 2- 5).Source Characterization - Source 2

HRS Documentation Record 

### 24 MacMillan Ring Free Oil ARD008049207 

### Source Location

The backfilled Ponds 70 4-707 (Source 2) are located on the southwest side of the facility just west and southwest of the fire water pond (Attachment A Figure A -2; Ref. 6, p. 99 ).

Source Containment

Release To Surface Water

The backfilled Ponds 70 4-707 , Source 2, do not have a maintained engineered cover, no liner, and no functioning or maintained run

- on control system or runoff management system (Ref. 6, p. 81; Ref. 15, p. 65 ; Ref. 20, p. 38) . Although the ponds have been backfilled, placement of an impermeable membrane was deemed too expensive during the closeout of the ponds (Ref. 28, p. 2).

Containment Value: 10

2.4.1 Hazardous Substances

Sampling conducted in 1992 on the sludge from the pits before removal activities were conducted

, had the following chromium levels detected in them. Pond 704 contained 77.9 mg/kg of chromium, Pond 705 contained 183 mg/kg of chromium, Pond 706 contained 138 mg/kg of chromium, and Pond 707 contained 97.7 mg/kg of chromium (Ref. 46, pp. 44-47; Ref. 47, p. 2 ).

During previous investigations, liquid waste (MW

- 1 and MW

- 5) and soil (NCI

- 9) samples were collected from the area of Ponds 704, 705, 706, and 707 (Source 2 ). During ADPC&E sampling in 1990, elevated levels of PAHs and approximately 15 gallons of oil were found in MW -1 (Ref. 6, p . 79 ; Ref. 11, p. 9 )

. In 1992, EPA contractors found elevated concentrations of SVOCs naphthalene and phenol detected in samples from MW

- 5 (Ref. 6, p. 80). In 1996 and 1997, EPA contractors found 2 feet of waste in MW

- 1 and a number of PAHs, with benzo(a)pyrene detected abo ve the EPA maximum contaminant level (Ref. 6, p. 80). As part of the CSA in 2011, ADEQ contractor s fo u nd lead in liquid waste from MW -1 and hexavalent chromium in surface soil at a concentration of 1.7 mg/kg from NCI -9, above EPA Regional Screening Levels (Ref. 6, pp. 93 , 99).

As part of SR sampling of MacMillan from 13 through 17 August 2012, EPA contractors collected one liquid waste sample from the location of the former ponds, Source 2 (Ref. 5, pp. 5; Ref. 22, p. 16 ; Ref. 25, p. 21). The sample contained two layers, with liquid waste visible on water (Ref. 22, p. 16). The sample was analyzed for TCL VOCs, TCL SVOCs, pesticides, and PCBs by the CLP SOW for MultiMedia, Multi

- Concentration Organic Analysis, OLM04.2, and TAL metals with mercury by CLP S OW Multi

- Media, Multi

- Concentration Inorganics Analysis, ISM05.3 (Ref. 25, p. 23)

. 

### TCL SVOCs were also analyzed by EPA SW 846 Method 8270 for low

- level PAHs (Ref. 26, pp. 431- 432). T he sample was submitted to the EPA Region 6 E nvironmental Services Branch Laboratory, located in Houston, Texas (Ref. 5, p. 5; Ref. 26, pp. 1, 309, 431).

MW

- 1 was placed adjacent to and downgradient of Source 2 in 1987, as part of the closure of the impoundments and in order to monitor the contamination from the former hazardous waste management unit (Ref. 6, p. 79) . Therefore samples from MW

- 1 are indicative of the waste presentSource Characterization - Source 2

HRS Documentation Record 

### 25 MacMillan Ring Free Oil ARD008049207 

### within Source 2. Analytical evidence of the contamination associated with Source 2 located on the MacMillan s ite is summarized below.

Hazardous Substance Evidence References Sample ID Concentration (mg/ L) Reporting Limit 1 (mg/ L)

EPA SR Sampling Activities – August 2012

Chromium MW

- 1

- 120816

- 21 0.6 0.09 Ref. 26, p p

. 1- 3, 197 ; Ref. 30, p. 25
Lead MW

- 1

- 120816

- 21 0.6 0.09 Ref. 26, pp. 1

- 3, 197; Ref. 30, p. 25
Vanadium MW -1- 120816

- 21 1.6 0.2 Ref. 26, pp. 1

- 3, 197; Ref. 30, p. 25

2- Methylnaphthalene MW -1- 120816

- 21 3.49 J 2.29 Ref. 26, p p

. 431

- 433, 608 ; Ref. 30, p. 25 Acenaphthylene MW

- 1

- 120816

- 21 2.74 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25

Anthracene MW

- 1

- 120816

- 21 11.2 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25 Benzo(a)anthracene MW -1- 120816

- 21 9.48 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25

Benzo(a)pyrene MW -1- 120816

- 21 2.88 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25 Beno(k)fluoranthene MW

- 1

- 120816

- 21 2.42 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25 Chrysene MW

- 1

- 120816

- 21 14.7 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25
Fl uoranthene MW -1- 120816

- 21 4.11 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25

Fluorene MW

- 1

- 120816

- 21 6.16 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25 Naphthalene MW

- 1

- 120816

- 21 2.63 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25
Phenanthrene MW

- 1

- 120816

- 21 9.2 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25 Pyrene MW -1- 120816

- 21 32.8 J 2.29 Ref. 26, pp. 431

- 433, 608; Ref. 30, p. 25

Notes: mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg ) J I dentification of analyte s is acceptable; the reported value is an estimate because the samples were extracted past holding time. Concentrations should be considered minimum values ( Ref. 26, p. 432). These estimated values are bias ed low (Ref. 26, p. 432; Ref. 50 , p. 1 ).
1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is adjusted for sample aliquot, sample volume, and dilutions for the analysis and meets the definition of Sample Quantitation Limit (SQL) as defined by the HRS (Ref. 1, Section 1.1; R ef. 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2).



### 2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The hazardous constituent quantity for Source 2 could not be adequately determined according to HRS requirements; that is the total mass of all CERCLA hazardous substances in the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1). There are insufficient historical and current data (manifests, potentially responsible party (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 associate d 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 2 with reasonable confidence. Scoring proceeds to the evaluation of Tie r B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).Source Characterization - Source 2

HRS Documentation Record 

### 26 MacMillan Ring Free Oil ARD008049207 

### 2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The hazardous wastestream quantity for Source 2 could not be adequately determined according to HRS requirements; that is the mass of the wastestream plus the mass of any additional CERCLA pollutants and contaminants that are allocated to the source is not known and cannot be estimated with reasonable confidence (Ref. 1, S ection 2.4.2.1.2). T here are insufficient histori cal and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) available to adequately calculate the mass of the wastestream plus the mass of any additional CERCLA pollutants and contaminants in the source and the ass ociated releases from the source. Therefore, there is insufficient information to evaluate the associated releases from the source to calculate the hazardous wastestream quantity for Source 2 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, volume (Ref. 1, Sec. 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

The depth of the buried/backfilled ponds, Source 2 , could not be accurately determined based on information available. Therefore, information is not sufficient to evaluate Tier C and it is not possible to adequately determine a volume for Source 2

. Source 2 has been assigned a value of 0 for the volume measure (Ref. 1, Section 2.4.2.1. 3 ). Scoring proceeds to the evaluation of Tier D, area (Ref. 1, Section 2.4.2.1.4 ).

2.4.2.1.4 Tier D: Area

An approximate calculation for the area of Source 2 was performed using GIS software. T he GIS software calculated the area of the polygon drawn over the footprint of the buried/backfilled Ponds 704- 707, visible by sparse vegetation west and southwest of the fire water pond, a s seen on aerial photographs (Ref. 21). The GIS software calculated the area of the buried/backfilled Ponds 704-707 to be 193,660 ft 2 

### (Ref. 21, pp. 1, 3)

. T he Tier D equation for assigning a value for area of a buried/backfilled surface impoundment is A/13 (Ref. 1, Table 2- 5). Calculations are as follows:

Ponds 704-707 = 193,660 square feet Area of Source 2 (ft 2 

### ): 193,660 Area Assigned Value = 193,660/13 Area Assigned Value = 14,896.923

2.4.2.1.5 Source Hazardous Waste Quantity Value

According to the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).Source Characterization - Source 2

HRS Documentation Record 

### 27 MacMillan Ring Free Oil ARD008049207 Tier E valuated Source 2 Values
A Not Evaluated
B Not Evaluated
C 0
D 14,896.923



### Source Hazardous Waste Quantity Value 14,896.923Source Characterization

HRS Documentation Record 

### 28 MacMillan Ring Free Oil ARD008049207 

### Other Sources Not Scored

A set of five aboveground storage tanks (ASTs) used for the storage of oil are located east of the former refinery (Ref. 6, p. 22). While MacMillan was operating, there were six ASTs at this location that had a total capacity of 20,000 gallons each (Ref. 27, p. 11). In 1992, it was observed that one of these ASTs had leaked a hard asphalt substance, and it appeared that as weather temperatures rose , this substance would liquefy and start to flow from the ASTs (Ref. 23, p. 50). These tanks were insulated with an open cell foam insulation that was covered with a corrugated metal protective skin. The metal skin was missing from several large areas of the tanks and the foam insulation was observed falling to the ground during field activities conducted by ADEQ contractors in 2011 (Ref. 6, p. 22). Currently these ASTs ( tanks) are in various stages of disrepair, and some tanks have been completely or partially removed. S urface soil staining (black, petroleum hydrocarbon) is extensive in the area of the tank farm (Ref. 6, p. 87; Ref. 22, pp. 8

- 10). R unoff is visible through continuous staining along the drainage ditches leading off

- property (Ref. 6, p. 87, 133, 134, 140; Ref. 22, pp. 8-10).

As part of the CSA in 2011, ADEQ contractors collected surface soil samples in the vicinity of the tank farm. Diesel

- range organics were detected in the vicinity of the tank farm and to the southeast (Ref. 6, p. 87).

As part of SR sampling of MacMillan from 13 through 17 August 2012, EPA contractors collected two solid waste samples from around the tank farm ( Ref. 5, pp. 5; Ref. 22, pp. 10 -12; Ref. 25, p. 21). The samples were analyzed for TCL VOCs, TCL SVOCs, pesticides, and PCBs by the CLP SOW for Multi

- Media, Multi

- Concentration Organic Analysis, OLM04.2, and TAL metals with mercury by CLP SOW Multi

- Media, Multi

- Concentration Inorganics Analysis, IL M05.3 (Ref. 25, p. 23)

. 

### TCL SVOCs were also analyzed by EPA SW 846 Method 8270 for low

- level PAHs (Ref. 26, pp.431 -432). The samples were submitted to the EPA Region 6 Environmental Services Branch Laboratory, located in Houston, Texas (Ref. 5, p. 5; Ref. 26, pp. 1, 309, 431).

Analytical evidence of the contamination associated w ith the tanks located on the MacMillan site is summarized below.

Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg)

EPA SR Sampling Activities – August 2012 Benzo(a)anthracene TS

- 01

- 03

- 51 0.0205 J 0.0129 Ref. 26, p p. 431

- 433, 530 ; Ref. 30, p. 8

Benzo(a)pyrene TS

- 01

- 03

- 51 0.0251 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Benzo(k)fluoranthene TS

- 01

- 03

- 51 0.245 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Benzo(g,h,i)perylene TS

- 01

- 03

- 51 0.0703 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Chrysene TS

- 01

- 03

- 51 1.34 J 0.0517 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Dibenz(a,h)anthracene TS

- 01

- 03

- 51 0.0187 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Indeno(1,2,3

- cd)pyrene TS

- 01

- 03

- 51 0.0196 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8

Phenanthrene TS

- 01

- 03

- 51 0.0216 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8 Pyrene TS

- 01

- 03

- 51 0.205 J 0.0129 Ref. 26, pp. 431

- 433, 530; Ref. 30, p. 8Source Characterization

HRS Documentation Record 

### 29 MacMillan Ring Free Oil ARD008049207 Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg)

Arsenic TS

- 01

- 03

- 51 1.3 0.5 Ref. 26, p p

. 1- 3, 105 ; Ref. 30, p. 8

Chromium TS

- 01

- 03

- 51 1.3 1.0 Ref. 26, p p

. 1- 3, 109 ; Ref. 30, p. 8

Lead TS

- 01

- 03

- 51 10.0 0.5 Ref. 26, pp. 1

- 3, 109; Ref. 30, p. 8 Manganese TS

- 01

- 03

- 51 25.4 J * 0.5 Ref. 26, pp. 1

- 3, 109; Ref. 30, p. 8

Vanadium TS

- 01

- 03

- 51 3.0 2.1 Ref. 26, pp. 1

- 3, 109; Ref. 30, p. 8

Zinc TS

- 01

- 03

- 51 13.7 2.1 Ref. 26, pp. 1

- 3, 109; Ref. 30, p. 8 Benzo(a)anthracene TS

- 02

- 03

- 51 0.0791 J 0.0131 Ref. 26, p p. 431

- 433, 534 ; Ref. 30, p. 8

Benzo(a)pyrene TS

- 02

- 03

- 51 0.0729 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Benzo(k)fluoranthene TS

- 02

- 03

- 51 0.298 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Benzo(g,h,i)perylene TS

- 02

- 03

- 51 0.0957 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Chrysene TS

- 02

- 03

- 51 1.38 J 0.0523 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Dibenz(a,h)anthracene TS

- 02

- 03

- 51 0.0269 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Indeno(1,2,3

- cd)pyrene TS

- 02

- 03

- 51 0.0332 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8

2- Methylnaphthalene TS

- 02

- 03

- 51 0.0163 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Naphthalene TS

- 02

- 03

- 51 0.0141 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8

Phenanthrene TS

- 02

- 03

- 51 0.0304 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8 Pyrene TS

- 02

- 03

- 51 0.200 J 0.0131 Ref. 26, pp. 431

- 433, 534 ; Ref. 30, p. 8

Arsenic TS

- 02

- 03

- 51 1.8 0.5 Ref. 26, p p

. 1- 3, 113 ; Ref. 30, p. 8

Chromium TS

- 02

- 03

- 51 4.5 1.0 Ref. 26, pp. 1

- 3, 113; Ref. 30, p. 8

Lead TS

- 02

- 03

- 51 9.3 0.5 Ref. 26, pp. 1

- 3, 113; Ref. 30, p. 8 Manganese TS

- 02

- 03

- 51 12.9 0.5 Ref. 26, pp. 1

- 3, 113; Ref. 30, p. 8

Mercury TS

- 02

- 03

- 51 0.10 0.072 Ref. 26, pp. 1

- 3, 11 4 ; Ref. 30, p. 8

Vanadium TS

- 02

- 03

- 51 11.1 1.9 Ref. 26, pp. 1

- 3, 113; Ref. 30, p. 8

Zinc TS

- 02

- 03

- 51 8.3 1.9 Ref. 26, pp. 1

- 3, 113; Ref. 30, p. 8

Notes: mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μ g/kg) J I dentification of analyte s is acceptable; the reported value is an estimate because the samples were extracted past holding time. Concentrations should be considered minimum values (EPA Region 6 data, p. 432). These estimated values are bias ed low (Ref. 26, p. 432; Ref. 50 , p. 1 ). J* For I dentification of analyte is acceptable; the reported value is an estimate due to outlying quality control parameters (Ref. 26 , pp. 3, 695). These estimated values are bias ed low as the samples were extracted out of the hold time (Ref. 26, p. 432 ; Ref. 50 , p. 1 ).
1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is adjusted for sample aliquot, sample volume, and dilutions for the analysis and meets the definition of Sample Quantitation Limit (SQL) as defined by the HRS (Ref. 1, Section 1.1; Ref. 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2).Source Characterization

HRS Documentation Record 

### 30 MacMillan Ring Free Oil ARD008049207 

### SITE SUMMARY OF SOURCE DESCRIPTIONS

Source

No. Source Hazardous Waste Quantity Value Containment Factor Value

Ground Water Surface Water Gas Air Particulate
1 6,253.846 NE 10 NE NE
2 14,896.923 NE 10 NE NE
TOTAL 21,150.769

NE = Not EvaluatedGW Migration Pathway

HRS Documentation Record 

### 31 MacMillan Ring Free Oil ARD008049207 

### 3.0 GROUND WATER MIGRATION PATHWAY SCORE - NOT SCORED

The ground water migration pathway will not be scored because it is not expected to contribute significantly to the Site score. The Site score already exceeds 28.50 based only on the evaluation of the surface water pathway.

Ground water samples were collected during the sampling events conducted by ADEQ in 1987 and 1990; by EPA contractors in 1994, 1996, and 1997; by ADEQ contractors during the 2011 CSA conducted, and by EPA contractors during the 2012 SR. During these events, elevated levels of PAHs were detected in sev eral wells located throughout the facility (Ref. 6, pp. 79, 80, 94, 144). Total chromium was detected in monitoring wells located on the east side of the facility in 2011, as well as total lead in several locations throughout the facility (Ref. 6, p. 86). Hexavalent chromium and lead were also detected in a monitoring well (NCI -3) located on the east side of the Site in 2012 (Ref. 5, p. 14). During the 2012 EPA SR, passive soil gas (PSG) samples were collected at the leading edge of historical plume boundary which was identified during the 2011 CSA sampling event (Ref. 5, pp. 4; 20; Ref. 6, pp. 94-98). The samples were analyzed for VOCs. Only one TPH value, slightly above detection limits was detected (Ref. 5, p. 18). Results indicated that the plume’s predominant direction is away from the school.SW Pathway – Overland/Flood Migration

HRS Documentation Record 

### 32 MacMillan Ring Free Oil ARD008049207 

### 4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 General Considerations

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

The hazardous substance migration path includes both the overland and the in

- water segment that hazardous substances would take as they migrate away from sources at the s ite (Ref. 1, S ection 4.1.1.1). Hazardous substance migration path s overland and in

- water segments for Sources 1 through 5 are described in the following text. The surface water pathway is presented on Figures A-3 and A-4.

Overland Segments

Topography of the MacMillan Ring Free Oil property slopes to the east and to the south, as described in the paragraphs below . The eastern slope that guides source contamination to the probable points of entry on the eastern side of the property is 5%, or 11.28o (Ref. 3, p. 1; Ref. 40, p. 1 ).

Source 1 – Buried/Backfilled Ponds 710, 711, and 712 A Probable P oint of E ntry (PPE)

, referred to as PPE 1 (location DD -01) , exists downgradient and to the
east of the backfilled Pond 712 (Source 1) (Ref. 5, p. 13; Ref. 30, p. 9; Ref. 39, pp. 1-2 ). Surface water runoff emanating from the barren area of the former pond flows east , following the natural topography approximately 40 feet east toward Hayes Creek, entering the creek at DD

- 01 ( PPE 1) (Ref. 5, p. 13; Ref

. 30, p. 9 ; Ref. 39 , pp. 1 -2)

. On the southeast end of Source 1, surface water runoff flows east/southeast and flows through a pipe located at DD -05 which abuts the former pond (Ref. 22, p. 15). From the pipe, flow continue s south along a drainage ditch for approximately 95 feet before e ntering the loop to Hayes Creek at DD-02 (PPE2 ) ( Ref. 39, pp. 1, 2; Ref. 42, p. 1).

From Pond 711 of Source 1, drainage occurs to the southeast and enters the adjacent wetland

, contiguous to Hayes C reek, at PPE5 with a minimal (>0) overland flow distance (Ref. 5, p. 13; Ref. 22, p. 3; Ref. 30, p. 9; Ref. 39, pp. 1-2).

From Pond 710 of Source 1 , drainage occurs to the southeast and enters the adjacent wetland contiguous to Hayes Creek at PPE4 with a minimal (>0) overland flow distance ( Ref. 22, p. 3; Ref. 39, pp. 1- 2).

Source 2 – Buried/Backfilled Ponds 704-707 Runoff/overflow emanating from the backfilled Ponds 70 4- 707 historically and currently surface flow s south through drainage ditches approximately 2,500 feet to Massey Creek via PPE6 ( Ref. 3, p. 1; Ref. 6, p p . 26, 44 ; Ref. 15, p p . 64, 68; Ref. 39, pp. 1, 3). The majority of wastes emanating from Source 2 is subsurface as evident through the wastes found in MW -1 , and discharges through active seeps present throughout the property (Ref. 6, pp. 12, 22, 123; Ref. 15, pp. 14, 15, 17 -21 ; Ref. 22, p. 16). Overland flow from Source 2 also follows surface topography gradient to the north-northeast toward Hayes Creek for approximately 1,000 feet to an active seep (RD -02) (Ref. 6, pp. 13, 4 3). The active
seep was sampled during the 2012 SR activities (RD

- 02) (Ref. 22, p. 9). From this location overland flow continue s north approximately 175 feet along the drainage ditch located on the eastern side of the railroad spurs , until it in tercepts a corrugated culvert (located at OP

- 01). T he corrugated culvertSW Pathway – Overland/Flood Migration

HRS Documentation Record 

### 33 MacMillan Ring Free Oil ARD008049207 

### continues east under the railroad tracks and a dirt road another 105 f eet and discharges through a second outfall pipe (OP

- 02) (Ref. 5, p.13; Ref. 22, p. 12; Ref. 30, pp. 3, 10; Ref. 39, pp. 1- 2). From here, the overland flow travels through a ditch approximately 150 feet east and empties into a man

made pond, which currently serv es as wetland habitat, via PPE 3 (Ref. 5, p. 13; Ref. 16, pp. 1 -13 ; Ref. 22, p. 13; Ref. 30, p. 10; Ref. 39, pp. 1-2).

The outer banks of Hayes Creek are located in Federal Emergency Management Association ( FEMA ) Flood Zone A . Flood Zone A is subject to inundation by the 1% annual chance of flood (Ref. 24, p p

. 1-3). This increases the chances that chemicals emanating from the MacMillan Site will be carried downstream. In addition, the contiguous wetland and Hayes Creek constitutes the beginning of the in

water segment for the surface water pathway.

In

- Water Segment s

The in

- water segment begins at the PPE to an eligible surface water body as defined in the HRS (Ref. 1, Sec. 4.1.1). E ligible surface water bodies that have been determined to be part of the in

- water segment for the MacMillan Site include the wetland c ontiguous to Hayes Creek

, Hay es Creek, Massey Creek, Flat Creek, Haynes Creek, Smackover Creek, and the Ouachita River ( Attachment A , Figure A

4; Ref. 3, p p . 1 -3 ; Ref. 30, pp. 1, 2 ; Ref. 41, pp. 1 -2) . All of the surface water bodies within the in

water segment are perennial and, therefore, eligible for HRS scoring (Ref. 1, Sec. 4.0.2; Ref. 42, p. 1; Ref. 49, pp. 1- 3)

The Target Distance Limit ( TDL ) is defined as being 15 miles from the farthest do wnstream PPE in the in

- water segment section (Ref. 1, S ec. 4.1.1.2). T he TDL of the surface water flow path is presented in Attachment A, Figure A-4 and is described in the following paragraphs.

Drainage from Source 1 enters Hayes Creek at location s DD -01 (PPE1 ) and DD

- 02 (PPE 2). Drainage on the south end of Source 1 enters the wetland contiguous to Hayes Creek at PPE4 and PPE5

. Drainage from Source 2 enters Massey Creek from PPE6 (Attachment A, Figure A-3 ; Ref. 5, p. 13 ; Ref. 15, p. 68; Ref. 39, pp. 1, 2 ).

PPE 2 and PPE6 are the farthest downstream PPE s . From PPE 2 , Hayes Creek flows for 1. 07 miles before its confluence with Flat Creek. From PPE6, Massey Creek flows for 2.65 miles before its confluence with Flat Creek. Flat Creek flows eastward for 1.86 miles before flowing into Hay n es Creek. Haynes Creek meanders northeast for 5. 46 miles before joining Smackover Creek. Smackover Creek meanders 4.48 miles before flowing into the Ouachita River. T he i n-w ater segment of the surface water pathway continues for 0.15 miles from PPE6 and 2.13 miles from PPE2 in the Ouachita River until the pathway extent reaches 15 miles, just northwest of Babb Lake (Attachment A, Figure A-4 ; Ref . 3, p. 1-3 ; Ref. 41, pp. 1, 2 ).SW Pathway – Likelihood of Release

HRS Documentation Record 

### 34 MacMillan Ring Free Oil ARD008049207 

### 4.1.2.1 LIKELIHOOD OF RELEASE

4.1.2.1.1 Observed Release

Direct Observation

Observed Release is established by direct observation. E vidence of sources flooding with material containing hazardous substances in direct contact with the surface water exists. S everal overflows to Hayes Creek from the DAF impoundments and other impoundments have historically occurred ( Ref. 8, pp. 5

- 6, 9; Ref . 9, p p. 1- 2, 6 )

. During the 1980s, several overflows to Hayes Creek from the ponds

were documented (Ref. 8, pp. 5

- 6, 9). In December 1982 and January 1983, floods in the area caused oily materials containing hazardous substances to release from the ponds and cover approximately 150 to 200 acres of Ouachita River bottom between Calion and Campanolle Landing (Ref. 8, p. 14; Ref. 9, pp. 1-2, 6 ).

On 6 S eptember 1990, during an ADPC&E inspection of the facility , the inspector observed unpermitted discharge of pond fluids to an unnamed creek (Hayes Creek) (Ref. 9, p. 10).

Between 28 M ay and 20 June 1992, cleanup of affected vegetation along Hayes Creek took place. Cleanup involved placing numerous sections of sorbent boom in the creek to contain free float ing oil and the collection of oily contaminated materials from the creek banks. Due to the large amount of oily soaked vegetation along the creek bed, a controlled burn took place . The oily soaked materials that were not suitable for burning were placed in roll-off boxes for disposal (Ref. 8, p. 11).

On 13 July 1994, ADPC&E representatives found evidence of a release from the pond s located east of the railroad tracks

. V isual staining was observed on the berms of the ponds and along the banks of Hayes Creek (Ref. 9, p. 37).

Chemical Analysis

As well as an observed release by direct observation, an observed release by chemical analysis is established . In 1985, during an inspection, EPA contractors sampled the east side of the property (Ref. 2 0, pp. 11, 19, 20) . Analytical results detected elevated concentrations of organics (mainly unknown compounds) as well as lead from the Pond 712 bank, the pathway between the pond and Hayes Creek

, and from within Hayes Creek (Ref. 20, p. 11).

During the August 2012 SR sampling activities conducted by EPA contractors

, surface water and sediment samples collected from within the surface water pathway demonstrated elevated concentrations of hazardous substance s (Ref. 5

, p. 4). For the purpose of this report, only the sediment samples are being presented, as the sediment samples alone provide sufficient evidence to establish an observed release . Two sediment samples were collected from the wetland contiguous to Hayes Creek and twelve sediment samples were collected from within Hayes Creek (Ref. 5, p. 4). Sample locations are depicted in Figure A -5 of Attachment A.SW Pathway – Likelihood of Release

HRS Documentation Record 

### 35 MacMillan Ring Free Oil ARD008049207 

### Background Concentrations

A background sediment sample was collected from Hayes Creek (BG

- 01) approximately 1,000 feet upstream and upgradient of the s ite (Attachment A, Figure A

- 5; Ref. 25, p. 4) . The background sediment sample collected from Hayes Creek is compared to site

- related sediment samples collected from the wetland contiguous to Hayes Creek and Hayes Creek in order to illustrate an observed release from the site to the surface water pathway can be established (Ref. 5, p. 4; Ref. 25, pp. 13, 21 ).

The background sediment sample was collected on 16 August 2012 by EPA contractors. The sediment sample was collected from 0 to 2 inches below ground surface (bgs) with disposable plastic scoops then transferred directly to the appropriate sample containers. The sample was collected from within the creek where sediments had a ccumulated (Ref. 5, p. 4). Once collected, the sediment sample bottles were placed on ice until shipping (Ref. 5, p. 4; Ref. 25, p. 20). The background sample and the samples collected to demonstrate the presence of contamination in the overland flow path and to demonstrate an observed release were all collected during the same time frame during the same sampling event (Ref. 5, p. 4). The samples were collected by the same field team during the same sampling event, following the same sample collection protocols and methodologies. T he background sample was collected from a similar location (within Hayes Creek), was from similar media (the sediment/soil type at Hayes Creek is similar to the eastern end of the wetland) , same depth, used the same sampling meth ods, preservation, and handling and were all collected during the same weather conditions as the observed release samples (Ref. 5, p. 4; Ref. 16, pp. 2, 6; Ref. 30, pp. 4-13).

Sediment samples were shipped via Federal Express to the EPA Region 6 Laborat ory located in Houston, Texas, for VOCs, SVOCs, pesticides, PCBs, TAL metals and mercury analysis and to Test America Laboratories , Inc. located in Savannah, Georgia, for hexavalent chromium analysis. The samples were analyzed for VOCs , SVOCs, pesticides, and PCBs by CLP COW OLM04.2, for TAL metals and mercury by CLP SOW ISM05.3, and hexavalent chromium by EPA Method SW846 7196A (Ref. 5, p. 5; Ref. 25, p. 23; Ref. 26, pp. 279-306, 401-428, 667-694).

EPA SR Sampling Event - Background Sample Description August 2012

Station Location

(Sample ID ) Sample Location Sample Date (Military Time) Reference

Sediment

BG

- 01 (BG

- 01

- 03

- 51) Hayes Creek upstream of the MacMillan S ite sources. 08/16/2012 (0710) Ref. 25 , p. 21 ; Ref. 26 , p 299; Ref. 30 , p. 11; Attachment A, Figure A -5SW Pathway – Likelihood of Release

HRS Documentation Record 

### 36 MacMillan Ring Free Oil ARD008049207 

### EPA SR Sampling Event - Background Sample Concentrations August 2012

Summary of MacMillan Designated Background Levels

Hazardous Substance Evidence Reference

Station Location/ Sample ID Concentration mg/kg RL 1 mg/kg

Sediment

– Hayes Creek 2

- Meth yl naphthalene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569 Anthracene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569 Benzo(a)anthracene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569 Benzo(a)pyrene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569
Benzo(k)fluoranthene BG

- 01 / BG

- 01

- 03

- 51 0.0073 J 2 (0.073) 0.0058 Ref. 26 , p p

. 431

- 433, 569 Benz o (g,h,i)perylene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569
Chrysene BG

- 01 / BG

- 01

- 03

- 51 0.105 J 2 (1.05) 0.0058 Ref. 26 , p p

. 431

- 433, 569 Fluoranthene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569 Indeno(1,2,3

- cd)pyrene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569
Naphthalene BG

- 01 / BG

- 01

- 03

- 51 0.0073 J 2 (0.073) 0.0058 Ref. 26 , p p

. 431

- 433, 569 Phenanthrene BG

- 01 / BG

- 01

- 03

- 51 0.0058 U 0.0058 Ref. 26 , p p

. 431

- 433, 569

Pyrene BG

- 01 / BG

- 01

- 03

- 51 0.0081 J 2 (0.096066) 0.0058 Ref. 26 , p p

. 431

- 433, 569 Arsenic BG

- 01 / BG

- 01

- 03

- 51 0.5 U 0.6 Ref. 26 , p p

. 1

- 3, 153 Cadmium BG

- 01 / BG

- 01

- 03

- 51 1.6 0.6 Ref. 26 , p p

. 1

- 3, 153 Chromium BG

- 01 / BG

- 01

- 03

- 51 1.2 U 1.2 Ref. 26 , p p

. 1

- 3, 153 Chromium (VI) BG

- 01 / BG

- 01

- 03

- 51 1.5 U 1.5 Ref. 19 , p. 6 Lead BG

- 01 / BG

- 01

- 03

- 51 8.8 0.6 Ref. 26 , p p

. 1

- 3, 153 Manganese BG

- 01 / BG

- 01

- 03

- 51 2.5 0.6 Ref. 26 , p p

. 1

- 3, 153 Mercury BG

- 01 / BG

- 01

- 03

- 51 0.066 U 0.066 Ref. 26 , p p

. 1

- 3, 15 4 Vanadium BG

- 01 / BG

- 01

- 03

- 51 2.7 2.4 Ref. 26 , p p

. 1

- 3, 153 Zinc BG

- 01 / BG

- 01

- 03

- 51 10.5 2.4 Ref. 26

, p p

. 1

- 3, 153

Notes: mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg )

1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory are detection limits which have been adjusted for sa mple aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2

- 3; Ref. 24, p. 4; Ref. 26 , pp. 3, 433 ; Ref. 48, pp. 1 -2 ).

2 Values that have been adjusted according to the EPA Fact Sheet (Ref. 29) are listed in parenthe ses. U Not detected at reported quantitation limit ( Ref. 26 , p. 307). J I dentification of analyte is acceptable; the reported value is an estimate because the samples were extracted past holding tim e. Concentrations should be considered minimum va lues ( Ref. 26 , p. 432). These estimated values are bias ed low (Ref. 26, p. 432; Ref. 50, p. 1 ).SW Pathway – Likelihood of Release

HRS Documentation Record 

### 37 MacMillan Ring Free Oil ARD008049207 

### Observed Release Samples

Observed release criteria are met when the hazardous substance is attributable to a release from the S ite, its concentration exceeds the SQL (including the background SQL), and is at least three times greater than the background concentration when the background concentration equals or exceeds its SQL (Ref. 1, Table 2-3 ).

Sampling locations with hazardous substances meeting observed release criteria are presented below.

EPA SR Sampling Event – August 2012

Station Location

(Sample ID) Sample Location Sample Date (Military Time) Reference
Hayes Creek PPE

- 01 (PPE

- 01

- 03

- 51) W here loop of Hayes Creek enters main branch of Hayes Creek on the north. 08/14/2012 (1310) Ref. 25, p.21; Ref. 26 , pp. 285, 288 ; Ref. 30 , p.6

PPE

- 02 (PPE

- 02

- 03

- 51) W here loop of Hayes Creek enters main branch of Hayes Creek on the south

. 08/14/2012 (1320) Ref. 25 , p.21; Ref. 26 , pp. 292, 298 Ref. 30 , p. 7

PPE

- 04 (DD

- 01

- 03

- 51) Northern

- most PPE at Hayes Creek in a section that runs adjacent to former Pond 712

. 08/14/2012 (0830) Ref. 25, p.22; Ref. 26

, pp. 279,288 ; Ref. 30 , pp

. 9, 5

SW

- 01 (SED

- 01

- 03

- 51) Within Hayes Creek between north and southern sections of loop. 08/14/2012 (1050) Ref. 25, p.21; Ref. 26 , pp. 279, 288, 291 ; Ref. 30 , p. 6

SW

- 02 (SED

- 02

- 03

- 51) Within Hayes Creek approximately 250 feet downstream of PPE

- 02. 08/14/2012 (1340) Ref. 25 , p.21; Ref. 26 , pp. 674, 676 ; Ref. 30 , p. 6

SW

- 03 (SED

- 03

- 03

- 51) Within Hayes Creek approximately 100 feet downstream of SW

- 02. 08/14/2012 (1402) Ref. 25 , p.21; Ref. 26 , pp. 675, 676 ; Ref. 30 , p. 7

SW

- 04 (SED

- 04

- 03

- 51) Within Hayes Creek approximately 500 feet downstream of SW

- 03. 08/16/2012 (0820) Ref. 25 , p.21; Ref. 26 , pp. 688, 689 ; Ref. 30 , pp. 11, 12

SW

- 05 (SED

- 05

- 03

- 51) Within Hayes Creek approximately 100 feet downstream of SW

- 04. 08/16/2012 (0835) Ref. 25 , p.21; Ref. 26 , pp. 688, 690 ; Ref. 30 , pp. 11, 12

DD

- 02 (DD

- 03

- 03

- 51) Within loop of Hayes Creek, adjacent to wetland area and old weir system and the southernmost PPE of Source 1. 08/14/2012 (0900) Ref. 25 , p. 22; Ref. 30 , p. 5; Attachment A, Figure A -5

DD

- 03 (DD

- 04

- 03

- 51) Within loop of Hayes Creek, located just downstream of old weir system

. 08/14/2012 (0920) Ref. 25 , p. 22; Ref. 30 , p. 5; Attachment A, Figure A -5

DD

- 04 (DD

- 02

- 03

- 51) Field duplicate (DD

- 04

- 03

- 52) Within loop of Hayes Creek, located on south end before entering the main branch of Hayes Creek. 08/14/2012 (1030) Ref. 25 , p. 22; Ref. 30 , p. 6 ; Attachment A, Figure A -5

W etland Contiguous to Hayes Creek

PPE

- 03 (PPE

- 03

- 03

- 51) PPE 3 into wetland area

. 08/15/2012 (1245) Ref. 25 , p.21; Ref. 26 , pp. 294, 298; Ref. 30 , p. 10

WA

- 01 (WA

- 01

- 03

- 51) Within wetland area. 08/15/2012 (1255) Ref. 25 , p.21; Ref. 26 , pp. 294, 682, 686 ; Ref. 30 , p. 10



### The sediment samples were collected on 14 through 18 August 2012 by EPA contractors . The sediment samples were collected with disposable plastic scoops and transferred to an appropriate sample container. The samples were collected from 0 to 2 inches bgs from locations within the creekSW Pathway – Likelihood of Release

HRS Documentation Record 

### 38 MacMillan Ring Free Oil ARD008049207 

### where sediments had accumulated

, such as bends in the creek ( Ref. 5, p . 4; Ref. 25 , p . 16 ). Once collected, the sediment sample bottles wer e placed on ice until shipping ( Ref. 25, p. 18 ).

S ediment samples were delivered via Federal Express to the EPA Region 6 Environmental Services Branch Laboratory for analysis of VOCs, SVOCs , Pesticides, PCBs, and metals with mercury

. S ediment samples for analysis of hexavalent chromium were shipped via Federal Express to Test America Laboratories, Inc. l ocated in Savannah

, Georgia

. The samples were ana lyzed for VOCs, SVOCs , pesticides

, and PCBs by CLP OLM04.2, for TAL metals and mercury by CLP ILM01.2 , and for hexavalent chromium by EPA SW846 Method 7196A ( Ref. 5, p. 5; Ref. 25 , p. 23 ; Ref. 26 , pp. 279-306, 401-428, 667-694).

EPA SR Sampling Event – August 2012 Sediment Samples – Hayes Creek

Station Location

(Sample ID) Hazardous Substance Concentration mg/kg RL 1 mg/kg Reference

PPE

- 01 (PPE

- 01

- 03

- 51) Arsenic 0.80 0.50 Ref. 5 , p. 26 ; Ref. 26 , p p. 1- 3, 57 Chromium 3.4 1.10 Ref. 5, p.26; Ref. 26, pp. 1

- 3, 57 Chromium (VI) 2.3 1.3 Ref. 5 , p. 26 ; Ref. 19 , p. 6

Manganese 122 0.50 Ref. 5 , p. 26 ; Ref. 26, p p

. 1

- 3, 57 Vanadium 12.0 2.1 Ref. 5, p.26; Ref. 26, pp. 1

- 3, 57

PPE

- 02 (PPE

- 02

- 03

- 51) Anthracene 0.0249 J 0.0244 Ref. 5 , p. 27 ; Ref. 26 , p p. 431

- 433, 510 Benzo(a)anthracene 0.0975 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510

Benzo(a)pyrene 0.044 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510 Benz o (g,h,i)perylene 0.0417 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510 Fluoranthene 0.0381 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510 2

- Methylnaphthalene 0.0319 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510 Phenanthrene 0.0402 J 0.0244 Ref. 5, p.27; Ref. 26, pp. 431

- 433, 510 Arsenic 0.90 0.6 Ref. 5 , p. 27 ; Ref. 26 , p p

. 1

- 3, 90 Chromium 2.6 1.2 Ref. 5, p.27; Ref. 26, pp. 1- 3, 89 Manganese 48.7 0.6 Ref. 5, p.27; Ref. 26, pp. 1

- 3, 89 Vanadium 10.4 2.4 Ref. 5, p.27; Ref. 26, pp. 1

- 3, 89

PPE

- 04 (DD

- 01

- 03

- 51) Benzo(a)anthracene 0.0116 J 0.0097 Ref. 5 , p. 29 ; Ref. 26 , p p

. 431

- 433, 440 Benzo(a)pyrene 0.0114 J 0.0097 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 440 Benz o (g,h,i)perylene 0.0146 J 0.0097 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 440 Arsenic 1.1 1.1 Ref. 5 , p. 28 ; Ref. 26 , p p

. 1

- 3, 13 Chromium 3.4 2.1 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 13 Lead 128 1.1 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 13 Manganese 80.9 1.1 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 13 Vanadium 8.6 4.2 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 13
Zinc 59.0 4.2 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 13

SW

- 01 (SED

- 01

- 03

- 51) Chromium 3.1 1.2 Ref. 5 , p. 28 ; Ref. 26, p p

. 1

- 3, 85 Manganese 55.1 0.6 Ref. 5, p.28 ; Ref. 26, pp. 1

- 3, 85

SW

- 02 (SED

- 02

- 03

- 51) Anthracene 0.530 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Benzo(a)anthracene 1.01 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490

Benzo( a )pyrene 0.433 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Benzo(k)fluoranthene 0.422 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Benzo(g,h,i)perylene 0.368 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Chrysene 1.80 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490SW Pathway – Likelihood of Release

HRS Documentation Record 

### 39 MacMillan Ring Free Oil ARD008049207 Station Location

(Sample ID) Hazardous Substance Concentration mg/kg RL 1 mg/kg Reference

Fluoranthene 0.567 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Indeno(1,2,3

- c,d)pyrene 0.134 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490

2- Methylnaphthalene 0.215 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490
Phenanthrene 1.53 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490 Pyrene 2.02 J 0.134 Ref. 5, p.30; Ref. 26, pp. 431

- 433, 490
Arsenic 0.800 0.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 61
Chromium 3.20 1.3 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 61 Manganese 23.3 0.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 61

Mercury 0.132 0.059 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 62
Vanadium 8.80 2.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 61
Zinc 42.8 2.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 61

SW

- 03 (SED

- 03

- 03

- 51) Anthracene 0.0264 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Benzo(a)anthracene 0.110 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497

Benzo(a)pyrene 0.0901 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Benzo(k)fluoranthene 0.147 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Benzo(g,h,i)perylene 0.104 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Chrysene 0.476 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497
Fluoranthene 0.0231 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Indeno(1,2,3

- c,d)pyrene 0.0325 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497

2- Methylnaphthalene 0.0528 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Naphthalene 0.0489 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497
Phenanthrene 0.0489 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497 Pyrene 0.283 J 0.0157 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 497
Arsenic 0.700 0.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 69
Chromium 2.30 1.3 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 69
Lead 37.8 0.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 69 Manganese 24.4 0.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 69

Mercury 0.083 0.06 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 70

Zinc 42.8 2.7 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 69

SW

- 04 (SED

- 04

- 03

- 51) Arsenic 1.10 0.6 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 157
Chromium 2.50 1.2 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 157

SW

- 04 (SED

- 04

- 03

- 51) Manganese 32.3 0.6 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 157
Vanadium 11.8 2.4 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 157

SW

- 05 (SED

- 05

- 03

- 51) Anthracene 0.00605 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Benzo(a)anthracene 0.0286 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580

Benzo(a)pyrene 0.0256 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Benzo(k)fluoranthene 0.0329 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Benzo(g,h,i)perylene 0.0145 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Chrysene 0.0905 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580

2- Methylnaphthalene 0.0128 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Naphthalene 0.0153 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580
Phenanthrene 0.0118 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580 Pyrene 0.0761 J 0.0055 Ref. 5, p.31; Ref. 26, pp. 431

- 433, 580SW Pathway – Likelihood of Release

HRS Documentation Record 

### 40 MacMillan Ring Free Oil ARD008049207 Station Location

(Sample ID) Hazardous Substance Concentration mg/kg RL 1 mg/kg Reference
Manganese 12.6 0.6 Ref. 5, p.30; Ref. 26, pp. 1

- 3, 165

DD

- 02 (DD

- 02

- 03

- 51) Arsenic 4.5 1.1 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33
Chromium 13.6 2.3 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33 Manganese 90.0 1.1 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33

Mercury 0.224 0.099 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33
Vanadium 33.9 4.6 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33
Zinc 100 4.6 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 33
2- Methylnaphthalene 0.014 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466 Benzo(a)anthracene 0.0312 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466

Benzo(a)pyrene 0.0357 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466 Benzo(g,h,i)perylene 0.0232 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466
Fluoranthene 0.0215 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466 Indeno(1,2,3

- c,d)pyrene 0.0141 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466
Phenanthrene 0.0162 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 466

DD

- 03 (DD

- 03

- 03

- 51) Arsenic 2.8 1.5 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 41
Chromium 7.3 3.1 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 41 Manganese 121 1.5 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 41

Mercury 0.160 0.141 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 42
Vanadium 19.3 6.1 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 41
Zinc 148 6.1 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 41 Benzo(a)anthracene 0.0362 J 0.0348 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 473 Benzo(g,h,i)perylene 0.0430 J 0.0348 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 473

DD

- 04 (DD

- 04

- 03

- 51) Chromium 1.7 1.2 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 49 Manganese 14.9 0.6 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 49

Mercury 0.076 0.058 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 50 Benzo(a)anthracene 0.0259 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 480

Benzo(a)pyrene 0.0352 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 480 Benzo(g,h,i)perylene 0.0456 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 480
Fluoranthene 0.0386 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 480
Phenanthrene 0.0391 J 0.0135 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 480

DD

- 04 (DD

- 04

- 03

- 52) Arsenic 0.7 0.6 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 21
Chromium 2.2 1.2 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 21 Manganese 23.4 0.6 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 21
Zinc 48.6 2.4 Ref. 5, p. 19; Ref. 26, pp. 1

- 3, 21 Benzo(a)anthracene 0.0198 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453

Benzo(a)pyrene 0.0284 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453 Benzo(g,h,i)perylene 0.0343 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453
Fluoranthene 0.0124 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453 Indeno(1,2,3

- cd)pyrene 0.0095 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453

2

- Methylnaphthalene 0.0117 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453
Phenanthrene 0.0143 J 0.0056 Ref. 5, p. 19; Ref. 26, pp. 431

- 433, 453

Notes: mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg )SW Pathway – Likelihood of Release

HRS Documentation Record 

### 41 MacMillan Ring Free Oil ARD008049207 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory are detection limits which have been adjusted for sa mple aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2

- 3; Ref. 24, p. 4; Ref. 26

, pp. 3, 311 ; Ref. 48, pp. 1 -2 ). J I dentification of analyte is acceptable; the reported value is an estimate because the samples were extracted past holding tim e. Concentrations should be considered minimum values ( Ref. 26 , p. 432). The estimated values are bias ed low (Ref. 26, p. 432; Ref. 50, p. 1 ).SW Pathway – Likelihood of Release

HRS Documentation Record 

### 42 MacMillan Ring Free Oil ARD008049207 

### EPA SR Sampling Event – August 2012 Sediment Samples – W etland Contiguous to Hayes Creek

Station Location

(Sample ID) Hazardous Substance Concentration mg/kg RL 1 mg/kg Reference

PPE

- 03 (PPE

- 03

- 03

- 51) Benzo(a)anthracene 0.0229 J 0.0075 Ref. 5

, p.29 ; Ref. 26 , p p

. 431

- 433, 542 Benzo(a)pyrene 0.022 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542 Benz o (g,h,i)perylene 0.0141 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542 Fluoranthene 0.016 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542 Indeno(1,2,3

- cd)pyrene 0.00991 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542

2

- Methylnaphthalene 0.00828 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542 Phenanthrene 0.0214 J 0.0075 Ref. 5, p.29; Ref. 26, pp. 431

- 433, 542 Arsenic 1.6 0.6 Ref. 5 , p. 28 ; Ref. 26 , p p

. 1

- 3, 121 Chromium 4.2 1.1 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 121 Manganese 36.2 0.6 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 121

Mercury 0.087 0.054 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 121 Vanadium 11.0 2.2 Ref. 5, p.28; Ref. 26, pp. 1

- 3, 121

WA

- 01 (WA

- 01

- 03

- 51) Arsenic 1.3 0.5 Ref. 5 , p. 32 ; Ref. 26 , p p

. 1

- 3, 137 Chromium 3.9 1.0 Ref. 5, p.32; Ref. 26, pp.1

- 3, 137 Manganese 47.9 15.6 Ref. 5, p.32; Ref. 26, pp.1

- 3, 137

Notes: mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg )

1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory are detection limits which have been adjusted for sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2

- 3; Ref. 24, p. 4; Ref. 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2 ). J For semivolatile compounds

, identification of analyte is acceptable; the reported value is an estimate because the samples were extracted past holding time. Concentrations should be considered minimum values ( Ref. 26 , p. 432). The estimated values are biased low (Ref. 26, p. 432; Re f. 50, p. 1 ). For all other compounds, identification of analyte is acceptable; the reported value is an estimate due to outlying quality contr ol parameters (Ref. 26 , pp. 3, 695).SW Pathway – Likelihood of Release

HRS Documentation Record 

### 43 MacMillan Ring Free Oil ARD008049207 

### Attribution

Association with Sources

Sources containing hazardous substances and releases of hazardous substances from these sources have been documented at this s ite, as discussed in Section 2.2 S ource Characterization and Section 4.1.2.1. 1 Observed Release of this HRS D ocumentation Record. Samples collected from overland drainage routes document hazardous substance migration from s ite sources to the surface water pathway (Ref. 25 , pp. 1 6, 21, 22). T he following soil/sediment samples are included to support migration of site

- related contami nation along the overland flow segments from the sources to the probable points of entry to the contiguous wetland and Hayes Creek.

Station Location (CLP Sample No.) Sampling Location Sample Date (Military Time) Reference

EPA SR Sampling Event – August 2012
RD

- 02 (RD

- 02

- 03

- 51) Field D uplicate (RD

- 02

- 03

- 52) At an active seep on t he southern end of the railroad ditch located on east side of the rail spurs and west of the railroad tracks. 08/15/2012 (0905) Ref. 25 , p. 21; Ref. 30

, p. 9; Attachment A, Figure A -5

OP

- 01 (OP

- 01

- 03

- 51) Outfall pipe located on east side of RD

- 01 and the rail spurs

. 08/15/2012 (0855) Ref. 25 , p. 22; Ref. 30 , p. 8; Attachment A, Figure A -5

OP

- 02 (OP

- 02

- 03

- 51) Outfall pipe located on west side of Ponds 710

- 712 and wetland area. 08/15/2012 ( 1230 ) Ref. 25 , p. 22; Ref. 3 0, p. 10 ; Attachment A, Figure A -5
DD

- 05 (DD

- 05

- 03

- 51) Field D uplicate (DD

- 05

- 03

- 52) Located where pipe from weir system enters the drainage ditch at southern end of Pond 712

. 08/16/2012 (0920) Ref. 25 , p. 12; Ref. 30, p. 12; Attachment A, Figure A -5



### Analytical results from soil/sediment samples collected from overland flow pathways are included to support migration of site

- related contamination along the overland flow segment from s ite sources to the PPEs only. The analytical results from these samples were not used to score the site, but to support attribution.

Station Location

(CLP Sample No.) Hazardous Substance Concentration 2 mg/kg RL 1 mg/kg Reference

EPA SR Sampling Event – August 2012

RD

- 02 (RD

- 02

- 03

- 51) Arsenic 1.5 0.5 Ref. 5 , p. 23 ; Ref. 26 , p p

. 1

- 3, 101
Chromium 3.8 1.0 Ref. 5 , p. 23 ; Ref. 26 , p p

. 1- 3, 101 Manganese 23.6 0.5 Ref. 5 , p. 23 ; Ref. 26 , p p

. 1- 3, 101

Mercury 0.186 0.054 Ref. 5 , p. 23 ; Ref. 26 , p p

. 1

- 3, 102
2

- Methylnaphthalene 0.0949 J 0.0516 Ref. 5 , p. 23 ; Ref. 26 , p p

. 431

- 433, 522 Benzo(a)anthracene 0.383 J 0.0516 Ref. 5 , p. 23 ; Ref. 26 , p p

. 431

- 433, 522

Benzo(a)pyrene 0.201 J 0.0516 Ref. 5 , p. 23 ; Ref. 26 , p p

. 431

- 433, 522 Benzo(g,h,i)perylene 0.123 J 0.0516 Ref. 5 , p. 2 4 ; Ref. 26 , p p

. 431

- 433, 522
Fluoranthene 0.0754 J 0.0516 Ref. 5 , p. 2 4 ; Ref. 26 , p p

. 431

- 433, 522 Indeno(1,2,3

- cd)pyrene 0.0646 J 0.0516 Ref. 5 , p. 24 ; Ref. 26 , p p

. 431

- 433, 522SW Pathway – Likelihood of Release

HRS Documentation Record 

### 44 MacMillan Ring Free Oil ARD008049207 Station Location

(CLP Sample No.) Hazardous Substance Concentration 2 mg/kg RL 1 mg/kg Reference

RD

- 02 (RD

- 02

- 03

- 52) Arsenic 1.4 0.5 Ref. 5 , p. 23 ; Ref. 26

, p p. 1

- 3, 105
Chromium 2.9 1.0 Ref. 5 , p. 23 ; Ref. 26

, p p. 1- 3, 105 Manganese 28.3 0.5 Ref. 5 , p. 23 ; Ref. 26

, p p. 1- 3, 105

Mercury 0.143 0.067 Ref. 5 , p. 23 ; Ref. 26

, p p. 1

- 3, 106
2

- Methylnaphthalene 0.244 J 0.0502 Ref. 5 , p. 23 ; Ref. 26 , p p

. 431

- 433, 526 Benzo(a)anthracene 0.276 J 0.0502 Ref. 5, p. 23 ; Ref. 26 , p p

. 431

- 433, 526

Benzo(a)pyrene 0.117 J 0.0502 Ref. 5, p. 2 4 ; Ref. 26 , p p

. 431

- 433, 526 Benzo(g,h,i)perylene 0.102 J 0.0502 Ref. 5, p. 2 4 ; Ref. 26 , p p

. 431

- 433, 526 Indeno(1,2,3

- cd)pyrene 0.0518 J 0.0502 Ref. 5, p. 2 4 ; Ref. 26 , p p

. 431

- 433, 526

OP

- 01 (OP

- 01

- 03

- 51) Arsenic 1.9 0.6 Ref. 5 , p. 21 ; Ref. 26

, p p

. 1

- 3, 93
Chromium 3.9 1.1 Ref. 5, p. 21 ; Ref. 26 , p p

. 1

- 3, 93 Manganese 34.4 0.6 Ref. 5, p. 21 ; Ref. 26 , p p

. 1- 3, 93

Mercury 0.089 0.056 Ref. 5, p. 21 ; Ref. 26 , p p

. 1- 3, 94 Benzo(a)anthracene 0.0194 J 0.0122 Ref. 5 , p. 21 ; Ref. 26

, p p

. 431

- 433, 514

Benzo(a)pyrene 0.0261 J 0.0122 Ref. 5, p. 21 ; Ref. 26 , p p

. 431

- 433, 514 Benzo(g,h,i ) perylene 0.0253 J 0.0122 Ref. 5, p. 2 2 ; Ref. 26 , p p. 431

- 433, 514
Fluoranthene 0.0151 J 0.0122 Ref. 5, p. 2 2 ; Ref. 26 , p p. 431

- 433, 514 Indeno(1,2,3

- cd)pyrene 0.0148 J 0.0122 Ref. 5, p. 2 2 ; Ref. 26 , p p

. 431

- 433, 514
Phenanthrene 0.0242 J 0.0122 Ref. 5, p. 2 2 ; Ref. 26 , p p

. 431

- 433, 514

OP

- 02 (OP

- 02

- 03

- 51) Arsenic 1.3 0.6 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 117
Chromium 3.0 1.2 Ref. 5, p. 21 ; Ref. 26 , p p

. 1

- 3, 117 Manganese 24.1 0.6 Ref. 5, p. 21 ; Ref. 26 , p p

. 1- 3, 117

Mercury 0.078 0.065 Ref. 5, p. 21 ; Ref. 26 , p p

. 1- 3, 118 Benzo(a)anthracene 0.412 J 0.027 Ref. 5 , p. 21 ; Ref. 26

, p p

. 431

- 433, 538

Benzo(a)pyrene 0.135 J 0.027 Ref. 5, p. 21 ; Ref. 26

, p p

. 431

- 433, 538 Benzo(g,h,i) perylene 0.0751 J 0.027 Ref. 5 , p. 22 ; Ref. 26 , p p

. 431

- 433, 538
Fluoranthene 0.289 J 0.027 Ref. 5 , p. 22 ; Ref. 26, pp. 431

- 433, 538 Indeno(1,2,3

- cd)pyrene 0.0315 J 0.027 Ref. 5 , p. 22 ; Ref. 26, pp. 431

- 433, 538
Phenanthrene 0.0376 J 0.027 Ref. 5 , p. 22 ; Ref. 26, pp. 431

- 433, 538

DD

- 05 (DD

- 05

- 03

- 51) Arsenic 2.1 0.8 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 173
Chromium 7.2 1.6 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 173 Manganese 83.8 0.8 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1- 3, 173

Mercury 0.170 0.094 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1- 3, 174

Zinc 201 3.2 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 173

DD

- 05 (DD

- 05

- 03

- 52) Arsenic 1.5 0.6 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1- 3, 181
Chromium 5.6 1.2 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 181 Manganese 61.9 0.6 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1

- 3, 181

Mercury 0.078 0.071 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1- 3, 182

Zinc 84.2 2.5 Ref. 5 , p. 21 ; Ref. 26 , p p

. 1- 3, 181 Benzo(a)pyrene 0.0184 J 0.0089 Ref. 5 , p. 22 ; Ref. 26 , p p

. 431

- 433, 594 Benzo(g,h,i)perylene 0.0158 J 0.0089 Ref. 5 , p. 22 ; Ref. 26 , p p

. 431

- 433, 594
2

- Methylnaphthalene 0.0327 J 0.0089 Ref. 5 , p. 22 ; Ref. 26 , p p

. 431

- 433, 594
Phenanthrene 0.0336 J 0.0089 Ref. 5 , p. 22 ; Ref. 26 , p p

. 431

- 433, 594

Notes:SW Pathway – Likelihood of Release

HRS Documentation Record 

### 45 MacMillan Ring Free Oil ARD008049207 mg/kg = milligrams per kilogram = 1,000 micrograms per kilogram ( μg/kg )

1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory are detection limits which have been adjusted for sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2

- 3; Ref. 24, p. 4; Ref. 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2 ). J I de ntification of analyte is acceptable; the reported value is an estimate because the samples were extracted past holding time. Concentrat ions should be considered minimum values ( Ref. 26 , p. 432). The estimated values are bias ed low (Ref. 26, p. 432; Re f. 50, p. 1 ). 

### The ground water plume under the property also shows migration of contamination from the property During sampling conducted in 2011 by ADEQ contractors, concentrations of benzene and naphthalene were detected (Ref. 6, pp. 97, 98). Ground water at the property is shallow at approximately 8 ft. bgs (Ref. 6, p. 84). With the property at 50 feet above Hayes Creek, the ground water at the property is at a higher elevation than the adjacent surface water at Hayes Creek (Ref. 40, p. 1).

Active seeps, which contain waste, are visible throughout the property. The waste follows the ground water gradient to the north

- northeast toward Hayes Creek, south

- southeast toward Massey Creek and south towards the convergence of the two creeks and em erges through the seeps, several of which are located adjacent to the railroad tracks. One such seep, RD -02, was sampled during the 2012 EPA SR. RD

- 02 contained arsenic, chromium, manganese, mercury, 2-methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(g,h,i)perylene, and indeno(1,2,3

- cd)pyrene ( Ref. 5, p p. 23 , 24; Ref. 26, p p

. 105 , 106, 526) . T he waste in the seeps is then carried through overland flow, discharging through piping located on the east side of the property . These pipes actively discharge waste into the wetland area (Ref. 6, pp. 12, 13, 43, 90, 123, 134, 140; Ref. 15, pp. 14, 15, 17 - 22, 25,

- 31, 33

- 41; Ref. 22, pp. 9, 12). Sample OP

- 02 was collected at an outfall pipe location just west of the wetland during the 2012 EPA SR and contained a rsenic , c hromium , m anganese , m ercury , b enzo(a)anthracene, b enzo(a)pyrene , b enzo(g,h,i) perylene , f luoranthene , i ndeno(1,2,3- cd)pyrene , and p henanthrene ( Ref. 5, pp. 13, 21, 22 ; Ref. 22, p. 12; Ref. 26, p. 117, 118, 538; Ref. 30, pp. 3, 10; Ref. 39, pp. 1- 2).

During the 2012 S R, two ground water samples were collected. O ne sample was designated as background and collected upgradient of the property , while the other (NCI

- 3) was collected on the east side of the property along the railroad spurs (Ref. 5, p. 4; Ref. 30, pp.24, 25). The following ground water sample is included to support migration of site-related contamination from the sources.SW Pathway – Likelihood of Release

HRS Documentation Record 

### 46 MacMillan Ring Free Oil ARD008049207 Station Location (CLP Sample No.) Hazardous Substance Concentration mg/L RL 1 mg/L Reference

EPA SR Sampling Event

– August 2012

NCI -3 (NCI -3- 120815

- 21) Zinc 2.05 0.02 Ref. 5 , p.3 8 ; Ref. 26, p p

. 1

- 3, 193

2- Methylnaphthalene 8.6 1.9 Ref. 5 , p. 8 3; Ref. 26, p p

. 431

- 433, 603
Naphthalene 19.6 1.9 Ref. 5 , p.3 8 ; Ref. 26, p p

. 431

- 433, 603

Notes: mg/L = milligram per liter for aqueous liquid = 1,000 microgram per liter (ug/L).

1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory are detection limits which have been adjusted for sa mple aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2

- 3; Ref. 24, p. 4; Ref . 26 , pp. 3, 311 ; Ref. 48, pp. 1 -2 ).


### Results of attribution soil/sediment and ground water samples revealed detects of several metals and PAHs as shown above. Of the metals and PAHs detected above in attribution soil/sediment samples, arsenic, chromium, manganese, vanadium, 2

- methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(g,h,i)perylene, and indeno(1,2,3-cd)pyrene were also detected within Hayes Creek at concentrations meeting observed release criteria (Ref. 1, Table 2 -3). Although low levels of PAHs are consistent with oil waste, these contaminants are also present within the CERCLA eligible wastes. In addition, elements such as chromium, hexavalent chromium, mercury, and zinc are present within the sources and these contaminants are not associated with OPA wastes , but with the RCRA hazardous K048 through K052 wastes (Ref. 31, pp. 12-16, 18-23, 25 ).

The facility historically has had a mix of OPA and CERCLA

- eligible wastes. It was discovered near the end of the OPA response, from state records and conversations with a former employee, that the impoundments (ponds) had been contaminated with the following listed RCRA hazardous wastes
gen erated by petroleum refining operations: K048 - DAF, K049 – slop oil emulsion solids, K050 – heat exchanger bundle cleaning sludge, K051 - API separator sludge, and K052 – tank bottoms. T hese RCRA hazardous wastes also constitute CERCLA eligible wastes and have commingled with the contents of OPA regulated wastes (Ref. 43, p. 3).

H istorical operations at the facility have been demonstrated to cause , among others, arsenic, chromium, manganese, vanadium, 2

- methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene

, benzo(g,h,i)perylene, and Indeno(1,2,3- cd)pyrene contamination based on sampling results of sources

. The presence of these substances in sources at the s ite

, combined with the overall lack of containment of the sources

, and the fact that contaminated so il/sediment samples of overland flow pathways and ground water samples are present , support contamination migration of these same compounds from sources at the s ite into the surface water pathway . T he contamination of, among others, arsenic, chromium, mang anese, vanadium, 2

- methylnaphthalene, benzo(a)anthracene, benzo(a )pyrene, benzo(g,h,i)perylene, and indeno(1,2,3- cd)pyrene in sediments can be attributed (wholly or, at least, in part) to the MacMillan operations.

Consideration of Other Possible Off- Site Sources

S earches of the Toxic Release Inventory (TRI) and EPA EnviroMapper for Envi r ofacts databases were performed within the zip code of the s ite location. Three facilities were identified upgradient along Hayes Creek (Ref. 33, pp. 1

- 2). R olling Frito Lay Sales, Welsco Inc., and Cross Oil Refining and Marketing, Inc. Rolling Frito Lay is a local trucking facility; Welsco is an industrial gas facility; andSW Pathway – Likelihood of Release

HRS Documentation Record 

### 47 MacMillan Ring Free Oil ARD008049207 

### Cross Oil Refining and Marketing, Inc. is a petroleum refining facility (Ref. 33, p p

. 3- 20). No nearby facilities along the surface water pathway are reported to have had a release of arsenic, chromium, manganese, vanadium, 2

- methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(g,h,i)perylene, and indeno(1,2,3- cd)pyrene according to the TRI database (Ref. 32, pp. 1- 2).

Although MacMillan is located in an area with other petroleum and oil industries, t he closest such

, facility is Cross Oil Refining, located approximately 5

- miles upstream along Hayes Creek (Ref. 33, p. 1). The bac kground sample collected for the s ite is deemed an appropriate background sample for the purposes of evaluating the s ite under the EPA’s HRS as the analytical results from the background sample is indicative of the highly petroleum industrialized area. Samples meeting observed release criteria, or displaying concentrations that are three times greater than the highest ba ckground concentration of a p articular analyte were collected at the s ite and from within the surface water pathway. Further, analytical results from samples collected from the sources at the s ite displayed the presence of the same contaminants as the samp les collected from the surface water pathway meeting observed release criteria.

Observed Release Factor

Based on the analytical data and attr ibution components listed above, a rsenic, chromium, chromium (VI), lead, manganese, mercury, vanadium, zinc, a nthracene, 2-methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, benzo(g,h,i)perylene, chrysene, fluoranthene, dibenz(a,h)anthracene, indeno(1,2,3

- cd)pyrene, naphthalene, phenanthrene, and pyrene have been documented as the hazardous substances in the observed release to the wetland contiguous to Hayes Creek and Hayes Creek. Therefore, the observed release factor value of 550 was assigned (Ref. 1, Section 4.1.2.1.1).

Observed Release Factor Value: 550SW Pathway – Potential to Release

HRS Documentation Record 

### 48 MacMillan Ring Free Oil ARD008049207 

### 4.1.2.1.2 POTENTIAL TO RELEASE

4.1.2.1.2.1 Potential to Release by Overland Flow

Potential to release was not evaluated because an observed release to the su rface water pathway was established by direct observation and chemical analysis (see Section 4.1.2.1.1 of this HRS Documentation R ecord).SW Pathway – Human Food Chain Threat/Waste Characteristics

HRS Documentation Record 

### 49 MacMillan Ring Free Oil ARD008049207 

### 4.1.3 HUMAN FOOD CHAIN THREAT

4.1.3.2 WASTE CHARACTERISTICS

Evidence of contamination associated with Source 1 a nd Source 2 have been established based on chemical analyses of samples collected from the sources (refer to the Attribution section and Section 2.2). A rsenic, chromium, lead, manganese, mercury, vanadium, zinc, anthracene, 2- methylnaphthalene, benzo(a)anthracene, be nzo(a)pyrene, benzo(k)fluoranthene, benzo(g,h,i)perylene, chrysene, indeno(1,2,3-cd)pyrene , naphthalene, phenanthrene, and pyrene were detected in sediment samples collected in the surface water pathway, thus establishing an observed release (see Section 4.1.2.1.1 of this HRS Documentation Record ).

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

Hazardous Substance Source Number Toxicity Factor Value Persistence Factor Value 1 Food Chain Bioaccumulation Value
Fresh Water 2 Toxicity/ Persistence/ Bioaccumulation

Factor Value Reference

Arsenic 1, OR 10,000 1 5 5 x 10 4 Ref. 2, p. 6 Acenaphthylene 1,2 0 0.4 500 0 Ref. 2, p. 6

Anthracene 1,2, OR 10 0.4 50,000 2 x 10 5 Ref. 2, p. 6 Benzo(a)anthrac e ne 1,2, OR 1,000 1 50,000 5 x 10 7 Ref. 2, p. 7 Benzo(a)pyrene 1,2

, OR 10,000 1 50,000 5 x 10 8 Ref. 2, p. 7 Benzo(k)fluoranthene 1, OR 100 1 50,000 5 x 10 6 Ref. 2, p. 7 Benzo(g,h,i)perylene 1, OR 0 1 50,000 0 Ref. 2, p. 7

Chromium 1,2,OR 10,000 1 500 5 x 10 6 Ref. 2, p. 8 Chromium(IV) 1 ,OR 10,000 1 5 5 x 10 4 Ref. 2, p. 8 Chrysene 1,2,OR 10 1 5 5 x 10 1 Ref. 2, p. 8 Dibenz(a,h)anthracene 1 10,000 1 50,000 5 x 10 8 Ref. 2, p. 9 Indeno(1,2,3

- cd)pyrene 1, OR 1,000 1 50,000 5 x 10 7 Ref. 2, p. 13

Lead 1,2,OR 10,000 1 5 5 x 10 4 Ref. 2, p. 13 Manganese 1,OR 10,000 1 50,000 5 x 10 8 Ref. 2, p. 13 Mercury 1

, OR 10,000 0.4 50,000 2 x 10 8 Ref. 2, p. 13

2- Methylnaphthalene 1,2

, OR 1,000 0.4 50,000 2 x 10 7 Ref. 2, p. 1 4 Naphthalene 1,2, OR 1,000 0.4 50,000 2 x 10 7 Ref. 2, p. 14

Phenanthrene 1, 2, OR 0 0.4 5,000 0 Ref. 2, p. 14 Pyrene 1,2, OR 100 1 50,000 5 x 10 6 Ref. 2, p. 15

Vanadium 1,2, OR 100 1 500 5 x 10 4 Ref. 2, p. 16

Zinc 1, OR 10 1 5 5 x 10 1 Ref. 2, p. 17

Notes: OR – Observed Release 1 The surface water category that includes rivers, oceans, coastal tidal waters, and great lakes was utilized to assign the hazardous substances persistence factor value (Ref. 1, Sec. 4.1.2.2.1.2). The persistence values for river s were assigned according to the Superfund Chemical Data Matrix (SCDM) T able (Ref. 2). 2 Bioaccumulation factor values are assigned from the SCDM (Ref. 2), for "Fresh Water" in which the fishery is located (Ref. 1, Sect. 4.1.3.2.1.3).SW Pathway – Human Food Chain Threat/Waste Characteristics

HRS Documentation Record 

### 50 MacMillan Ring Free Oil ARD008049207 

### Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8



### 4.1.3.2.2 Hazardous Waste Quantity

Source

No. Source Hazardous Waste Quantity Value Containment Factor Value

Ground Water Surface Water Gas Air Particulate
1 6,253.846 NE 10 NE NE
2 14,896.923 NE 10 NE NE
TOTAL 21,150.769

NE = Not Evaluated



### A hazardous waste quantity of 21,150.769 is estimated for sources at the MacMillan s ite

, which when applied in HRS Table 2-6, yields a pathway hazardous waste quantity of 10,000.

Hazardous Waste Quantity Factor Value = 1 0,000

4.1.4.2.3 Waste Characteristics Factor Category Value

T oxicity/P ersistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10,000 Bioaccumulation Potential Factor Value: 50,000

(T oxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 x 10 8 

### (T oxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potential Factor Value) = 5 x 10 12 

### (Ref. 1, Section 4.1.3.2.3).

A hazardous waste quantity factor of 10,000 is assigned according to HRS Section 2.4.2.2. F rom R eference 2 and Table 4

- 12 of the HRS, benzo(a)pyrene and manganese have a toxicity/persistence value of 10,000 and a bioaccumulation potential factor of 50,000. T he waste characteristics factor category value from Reference 1, Table 2

- 7 for a waste charac teristics product of 5 x 10 12 

### is 1,000.

Hazardous Waste Quantity Assigned Value: 10,000

Waste Characteristics Factor Category Value: 1,000SW Pathway – Human Food Chain T h reat/Targets

HRS Documentation Record 

### 51 MacMillan Ring Free Oil ARD008049207 

### 4.1.3.3 TARGETS



### 4.1.3.3.1 Food Chain Individual

Fishing is documented within the TDL and occurs within Smackover Creek and the Ouachita River (Ref. 36, p. 1). Fishermen along Smackover Creek and the Ouachita River catch bass, bream (sunfish), crappie, and catfish. These fish are used for personal consumption (Ref. 36, p. 1).

Fishery Type of Surface Water Body Reference(s) Smackover Creek Large River Ref. 37 Ouachita River Large River Ref. 38



### An observed release by chemical analysis and an observed release by direct observation are established to the surface water migration pathway (See Section 4.1.2.1.1 of this HRS Do cumentation R ecord). Since this information documents an observed release of a hazardous substance having a bioaccumulation factor of 500 or greater to surface water (Hayes Creek) in the watershed and there is a fishery present within the TDL, a food chain individual value of 20 w as assigned (Ref. 1, S ection 4.1.3.3.1; Ref. 36, p. 1).

Food Chain Individual Factor Value: 20

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations

Level I concentration s have not been established as fish tissue samples have not been collected; therefore, the Level I concentrations factor value receives an assigned value of 0.

Level I Concentration Factor Value: 0

4.1.3.3.2.2 Level II Concentrations

Level II concentrations have not been established within the fishery ; therefore, the Level II concentrations factor value receives an assigned value of 0.

Level II Concentration Factor Value: 0SW Pathway – Human Food Chain T h reat/Targets

HRS Documentation Record 

### 52 MacMillan Ring Free Oil ARD008049207 

### 4.1.3.3.2.3 Potential Human Food Chain Contamination

Identity of

Fishery Annual Production

(pounds) Type of Surface Water Body Average Annual

Flow Reference Population Value (P i ) Dilution Weight (D i ) P i x D i

Smackover Creek >0, but unknown Large River 18,770 cfs Ref. 1, Tables 4

- 13, 4- 18; Ref. 37 , p. 1 0.03 0.00 0 1 0.000 0 0 3

Ouachita River >0, but unknown Large River 30,350 cfs Ref. 1, Tables 4

- 13, 4- 18; Ref. 38, p. 1 0.03 0.0001 0.0000 0 3

Notes: cfs = cubic feet per second.



### S mackover Creek and Ouachita River are fished for bass, bream (sunfish), crappie, and catfish according to the Arkansas Game and Fish Commission; these fish are caught for human consumption (Ref. 36 ). Data to estimate pounds of fish caught annually for Sma ckover Creek and Ouachita River are not available; however, because these water bodies are fished, the annual production is known to be greater than zero. As such, a human food chain population value of 0.03 is assigned from Table 4

- 18 of the HRS Rule (Ref. 1, T able 4

- 18). For Smackover Creek and Ouachita River , the dilution weight was based on the average annual flow data collected by the United States Geological Survey ( USGS ) at a gauging station s located upstream of the TDL (Ref. 37; Ref. 38 ). Based on the stream flow, Smackover Creek and Ouachit a River, according to Table 4-13 of the HRS Rule, are classified as large river s and receive an assigned dilution weight of 0.0001 (Ref. 1, Table 4-13).

Smackover Creek and Ouachita River - Product of P i 

### x D i 

### = 0.06 x 0.0001

Product of P i 

### x D i 

### : 0.000006

(Sum of Products of P i 

### x D i 

### )/10: 0.0000006SW Pathway – Environmental Threat/Waste Characteristics

HRS Documentation Record 

### 53 MacMillan Ring Free Oil ARD008049207 

### 4.1.4 ENVIRONMENTAL THREAT

4.1.4.2 WASTE CHARACTERISTICS

Evidence of contamination associated with Sources 1 and 2 have been established based on chemical analyses of samples collected from these sou rces (refer to the Attribution S ection and Section 2.2 of this HRS Documentation Record ). Arsenic, chromium, chromium (VI) lead, manganese, mercury, vanadium, zinc, anthra cene, 2- methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, benzo(g,h,i)perylene, chrysene, indeno(1,2,3

- cd)pyrene, naphthalene, phenanthrene, and pyrene were detected in sediment samples collected within the contiguous wetland and Hayes Creek, establishing an observed release (see Section 4.1.2.1.1).

4.1.4.2.1 Ecot oxicity/Persistence/Bioaccumulation

Hazardous Substance Source Number Ecotoxicity Factor Value
Fresh 2 Persistence 1
Factor Value Ecosystem Bioaccumulation Potential Factor Value
Fresh Water 2 Ecotoxicity/ Persistence/ Bioaccumulation

Factor Value Reference

Arsenic 1, OR 10 1 5,000 5 x 10 4 Ref. 2, p. 6

Anthracene 1,2, OR 10,000 0.4 50,000 2 x 10 8 Ref. 2, p. 6 Benzo(a)anthrac e ne 1,2, OR 10,000 1 50,000 5 x 10 8 Ref. 2, p. 7 Benzo(a)pyrene 1,OR 10,000 1 50,000 5 x 10 8 Ref. 2, p. 7 Benzo(k)fluoranthene 1, R 0 1 50,000 0 Ref. 2, p. 7 Benzo(g,h,i)perylene 1,OR 0 1 50,000 0 Ref. 2, p. 7

Chromium 1,2,OR 10,000 1 500 5 x 10 6 Ref. 2, p. 8 Chromium(IV) 1 ,OR 100 1 5 5 x 10 2 Ref. 2, p. 8 Chrysene 1,2,OR 1,000 1 5,000 5 x 10 6 Ref. 2, p. 8 Dibenz(a,h)anthracene 1 0 1 50,000 0 Ref. 2, p. 9 Indeno(1,2,3

- cd)pyrene 1, OR 0 1 50,000 0 Ref. 2, p. 1 3

Lead 1,2,OR 1,000 1 50,000 5 x 10 7 Ref. 2, p. 13 Manganese 1,OR 0 1 50,000 0 Ref. 2, p. 1 3 Mercury 1,OR 10,000 0.4 50,000 2 x 10 8 Ref. 2, p. 13

2- Methylnaphthalene 1,2,OR 100 0.4 50,000 2 x 10 6 Ref. 2, p. 1 4 Naphthalene 1,2,OR 1,000 0.4 50,000 2 x 10 7 Ref. 2, p. 14

Phenanthrene 1,2,OR 10,000 0.4 50,000 2 x 10 8 Ref. 2, p. 14 Pyrene 1,2,OR 10,000 1 50,000 5 x 10 8 Ref. 2, p. 15

Vanadium 1,2,OR 0 1 500 0 Ref. 2, p. 1 6

Zinc 1,OR 10 1 50,000 5 x 10 5 Ref. 2, p. 17

Notes: OR – Observed Release 1 The surface water category that includes rivers, oceans, coastal tidal waters, and great lakes was utilized to assign the haz ardous substances persistence factor value (Ref. 1, Sec. 4.1.2.2.1.2). The persistence values for all the compounds listed were fo r river sSW Pathway – Environmental Threat/Waste Characteristics

HRS Documentation Record 

### 54 MacMillan Ring Free Oil ARD008049207 which includes the contiguous wetland and Hayes Creek according to the Superfund Chemical Data Matrix (SCDM) table (Ref. 2). 2 Bioaccumulation factor values are assigned from the SCDM (Ref. 2), for "Fresh Water" in which the wetland contiguous to Hayes Creek and sensitive environment are located (Ref. 1, Sect. 4.1.3.2.1.3).



### Ecot oxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8



### 4.1.4.2.2 Hazardous Waste Quantity

Source

No. Source Hazardous Waste Quantity Value Containment Factor Value

Ground Water Surface Water Gas Air Particulate
1 6,253.846 NE 10 NE NE
2 14,896.923 NE 10 NE NE
TOTAL 21,150.769

NE = Not Evaluated



### A hazardous waste quantity of 21,150.769 is estimated for sources at the MacMillan s ite

, which when applied in HRS Table 2 -6, yields a pathway hazardous waste quantity of 10,000 . Also, as documented in Sections 4.1.2.1.1 and 4.1.4.3.1.2 of this HRS Documentation R ecord, a wetland is subject to Level II concentrations; therefore, a minimum value of 100 can be assigned for the hazardous waste quantity factor value (Ref. 1, Section 2.4.2.2).

Hazardous Waste Quantity Factor Value = 10,000

4.1.4.2.3 Waste Characteristics Factor Category Value

Ecotoxicity/Persistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10,000 Bioaccumulation Potential Factor Value: 50,000

(Ecotoxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 x 10 8 

### (Ecotoxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potential Factor Value) = 5 x 10 12 

### (Ref. 1, Section 4.1.3.2.3).

A hazardous waste quantity factor of 10,000 is assigned according to HRS Section 2.4.2.2. F rom Reference 2 and Table 4

- 12 of the HRS, benzo(a)anthracene and benzo(a)pyrene have an ecotoxicity/persistence value of 10,000 and a bioaccumulation potential factor of 50,000. T he waste characteristics factor category value from Reference 1, Table 2 -7 for a waste characteristics product of 5 x 10 12 

### is 1,000.

Hazardous Waste Quantity Assigned Value: 10,000

Waste Characteristics Factor Category Value: 1,000SW Pathway – Environmental Threat/Targets

HRS Documentation Record 

### 55 MacMillan Ring Free Oil ARD008049207 

### 4.1.4.3.1 SENSITIVE ENVIRONMENTS

4.1.4.3.1.1 Level I Concentrations

No Level I concentrations have been documented; therefore, Level I concentrations were not evaluated. Level I concentrations factor value receives an assigned value of 0.

Level I Concentration Factor Value: 0

4.1.4.3.1.2 Level II Concentrations

Wetlands

The area of Level II contamination includes the perimeter of the wetlands where observed release concentrations of contaminants were detected (Ref. 1, Section 4.1.2.1.1). The perimeter of the wetland contiguous to Hayes Creek determined to be affected by Level II concentrations was approximately 980 linear feet (Ref. 16, pp. 1 -13 ; Ref. 34, pp. 1

- 2). The total length of the wetland contiguous to Hayes Creek was determined in accordance with Sections 4.1.4.3.1.1 and 4.1.4.3.1.2 of the HRS (Ref. 1) and was calculated by measuring the perimeter of the wetland contiguous to Hayes Creek subject to Level II concentrations as the length ( Ref. 1, Sections 4.1.4.3.1.1 and 4.1.4.3.1.2; Ref. 24, pp. 1- 2).

According to a wetlands evaluation conducted by an environmental scientist trained in wetland delineation, the area, wh ich used to be a m an

- made storm wat er retention pond, e ast of the facility

, meets the 40 CFR 230.3 d efinition of a wetland . A lthough the wetland evaluation was conducted under dr o ught conditions, historically, this area has been inundated with water as observed during previous site visits and by historical aerial photographs , and indicators of wetland h ydrology , soils and vegetation were noted in the evaluation (Ref. 15, pp. 38, 41 ; Ref. 16, pp. 1-13; Ref. 18, pp. 1 ).

Total Level II Wetland Perimeter = 980 feet (0.186 miles)

Wetland Value (Ref. 1, Table 4 -24): 25

Level II Concentrations Factor Value: 25

4.1.4.3.1.3 Potential Contamination

Sensitive Environments

Although wetland characteristics were not present between the farthest upstream PPE (DD

- 01) and farthest downstream sample (SW

- 05), this area is representative of a riparian habitat (Ref. 16, pp. 1

- 4). Riparian habitat and its diverse species represent an important component within ecosystem management. The majority of North American herpetofauna (reptiles and amphibians) inhabit wetlandSW Pathway – Environmental Threat/Targets

HRS Documentation Record 

### 56 MacMillan Ring Free Oil ARD008049207 

### habitats, including riparian areas. Reptiles and amphibians are functionally tie d to riparian habitats as they provide the essential habitat for their reproductive patterns (Ref. 35, pp. 1, 11). These particular
areas, re latively small in size, are important to the maintenance of unique biotic communities. This area of potential contamination within the TDL is considered a poor quality habitat due to industrial operations in the area. Therefore, this area is not included in the scoring of the s ite, but is presented here to illustrate a potentially affected sensitive environment.SW Pathway – Ground Water to Surface Water Migr ation

HRS Documentation Record 

### 57 MacMillan Ring Free Oil ARD008049207 

### 4.2 GROUND WATER TO SURFACE WATER MIGRATION COMPONENT - NOT SCORED

Section 4.2 of the HRS states that the ground water to surface water component can be used to evaluate surface water threats that result from migration of hazardous substances from a source at the facility to surface water (Ref. 1). Although the ground w ater to surface water component is possible as is evidence by the active seeps on the property, the surface water likelihood of release is scored based on the overland/flood migration component as shown in Section 4.1 of this report. Since the threat of r elease by overland flow or flood is more than minimal for this facility and the component score sufficient to score the overall site, the ground water to surface water migration component has not been scored.

### ! ( SITE LOCATION

FIGURE A-1 FACILITY LOCATION MAP MACMILLAN RING FREE OIL CO. INC. 600 MACMILLAN RD NORPHLET, UNION COUNTY, ARKANSAS 

# $ 0 2,000 4,000

Feet

LEGEND



### ! ( SITE LOCATION

20406.012.019.0718.01 AS SHOWN TDD NO: TO-0019-12-03-01 CERCLIS NO: ARD008049207

SOURCE: ESRI StreetMap and Data Partners
FILE: L:\20406_START3_R6\NORPHLET_CHEMICAL\GIS\FIGURE_A-1_SITE_LOCATION_MAP-TOPO.mxd 9:59:49 AM 9/6/2013 bondp SEPTEMBER, 2013 DATE PROJECT NO SCALE 

## US EPA REGION 6

" ) Arkansas REF. 3, P.1Massey Creek Hayes Creek MacMillan

MacMillan Holloway E. Front St.

LEVEL II WETLAND AREA SOURCE 1

SOURCE 2 Canning Building

Drum Storage

Norphlet Wastewater Treatment Ponds Residence Norphlet Public Schools Ballpark

Boiler Building

NCI Plant

Fire Water Pond 712 711

710

705-707

704

FIGURE A-2 PROPERTY LAYOUT MAP MACMILLAN RING FREE OIL CO. INC. 600 MACMILLAN RD NORPHLET, UNION COUNTY, ARKANSAS 

# $ 0 550 1,100

Feet LEGEND

FORMER PONDS

PROPERTY BOUNDARY

LEVEL II WETLAND AREA

20406.012.019.0718.01 AS SHOWN TDD NO: TO-0019-12-03-01 CERCLIS NO: ARD008049207

SOURCE: (c) 2010 Microsoft Corporation and its data suppliers
FILE: L:\20406_START3_R6\NORPHLET_CHEMICAL\GIS\FIGURE_A-2_PROPERTY_LAYOUT_MAP.mxd 9:57:41 AM 9/6/2013 bondp SEPTEMBER, 2013 DATE PROJECT NO SCALE 

## US EPA REGION 6

" ) Arkansas REF. 6, PP.33, 34 E Padgett Rd! ( ! ( ! ( ! ( ! ( ! ( ! ( ! (

!

( ! (

! ( " )

" )

" )

! (

! ( ! ( ! ( " ) " )

! ( ! ( ! (

! (

! ( ! (

! ( " )

" )

" ) 

### k j k j k j 

### AST's

MacMillan E. Front St

E. Front St

SOURCE 2 SOURCE 1

Massey Creek Hayes Creek

Massey Creek BG-01

SW-05 SW-04 SW-03 SW-02 PPE-02 SW-01 PPE-01 DD-03

DD-04

WA-01 DD-01 (PPE1)

DD-02 (PPE2)

PPE-03(PPE3) PPE4 PPE5

PPE6 RD-02 RD-01 OP-02

OP-01 DD-05 PS-01

PS-02 TS-02 TS-01

PS-03 NCI-1

NCI-3

MW-1 712

711

710

705-707

704

FIGURE A-3 SURFACE WATER PATHWAY MAP MACMILLAN RING FREE OIL CO. INC. 600 MACMILLAN RD NORPHLET, UNION COUNTY, ARKANSAS 

# $

0 320 640

Feet

TDD NO: TO-0019-12-03-01 CERCLIS NO: ARD008049207

SOURCE: (c) 2010 Microsoft Corporation and its data suppliers LEGEND

SURFACE WATER FLOW DIRECTION
OVERLAND FLOW 

### k j OUTFALL PIPE
" ) BACKGROUND GROUNDWATER SAMPLE
! ( BACKGROUND SEDIMENT SAMPLE
! ( LEVEL II SEDIMENT SAMPLE
! ( PROBABLE POINT OF ENTRY
! ( SEDIMENT CHARACTERIZATION SAMPLE
" ) SOURCE CLASSIFICATION SAMPLE

LEVEL II WETLAND AREA
PROPERTY BOUNDARY
FORMER PONDS

20406.012.019.0718.01 AS SHOWN

1:19:42 PM 9/6/2013 FILE: L:\20406_START3_R6\NORPHLET_CHEMICAL\GIS\FIGURE_A-3_SURFACE WATER PATHWAY MAP.mxd 1:19:42 PM 9/6/2013 bondp SEPTEMBER, 2013 SCALE PROJECT NO DATE 

## US EPA REGION 6

REF. 5, P. 10; REF. 6, PP. 30, 3

### ! (

! (

PPE6 DD-02 (PPE2) Probable Point of Entry

M

a

s

s

e

y C

r e e

k H

a y

e

s C

r e e

k 1

. 0

7

m

i l e

s F l a t C r e

e

k

1

. 8

6 m i l e s O u a

c h

i t a R i v

e r

2

. 1 3 m i l e

s S

m a c k

o

v

e r C r e e k 4

. 4

8

m

i l e

s

H

a y n

e s C r e e k

5 .

4 6

m

i l e

s

FIGURE A-4 15-MILE TARGET DISTANCE LIMIT MACMILLAN RING FREE OIL CO. INC. 600 MACMILLAN RD NORPHLET, UNION COUNTY, ARKANSAS 

# $

0 0.5 1

Miles

TDD NO: TO-0019-12-03-01 CERCLIS NO: ARD008049207

SOURCE: © 2011 National Geographic Society, i-cubed LEGEND

15-MILE TARGET DISTANCE LIMIT 

### ! ( UPSTREAM PROBABLE POINT OF ENTRY
PROPERTY BOUNDARY

20406.012.019.0718.01 AS SHOWN

10:21:11 AM 9/6/2013 FILE: L:\20406_START3_R6\NORPHLET_CHEMICAL\GIS\FIGURE_A-4_15-MILE TARGET DISTANCE LIMIT.mxd 10:21:11 AM 9/6/2013 bondp SEPTEMBER, 2013 SCALE PROJECT NO DATE 

## US EPA REGION 6 15-mile TDL2 15-mileTDL1

REF. 3, PP. 1-3; REF. 6, PP. 30, 33

### ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! (

! ( ! (

! ( " )

"

)

" )

! (

! ( ! ( ! ( " ) " )

! ( ! ( ! (

! ( " )

" )

" ) Hayes Creek

SOURCE 2 SOURCE 1 PS-01

PS-02

PS-03 TS-02 TS-01

RD-02 RD-01 OP-02
OP-01 DD-05 DD-01 (PPE1)

DD-02 (PPE2)

PPE-03(PPE3)

SW-05 SW-04 SW-03 SW-02 PPE-02 SW-01 PPE-01 DD-03

DD-04

WA-01 BG-01

NCI-1

712

711

710

705-707

704 NCI-3

MW-1

FIGURE A-5 SAMPLE LOCATION MAP MACMILLAN RING FREE OIL CO. INC. 600 MACMILLAN RD NORPHLET, UNION COUNTY, ARKANSAS 

# $

0 250 500

Feet

TDD NO: TO-0019-12-03-01 CERCLIS NO: ARD008049207

SOURCE: (c) 2010 Microsoft Corporation and its data suppliers LEGEND 

### " ) BACKGROUND GROUNDWATER SAMPLE 

### ! ( BACKGROUND SEDIMENT SAMPLE 

### ! ( LEVEL II SEDIMENT SAMPLE 

### ! ( PROBABLE POINT OF ENTRY 

### ! ( SEDIMENT CHARACTERIZATION SAMPLE 

### " ) SOURCE CLASSIFICATION SAMPLE

SURFACE WATER FLOW DIRECTION

LEVEL II WETLAND AREA
PROPERTY BOUNDARY
FORMER PONDS

20406.012.019.0718.01 AS SHOWN

5:50:25 PM 7/30/2013 FILE: L:\20406_START3_R6\NORPHLET_CHEMICAL\GIS\FIGURE_A-5_SAMPLE LOCATION MAP.mxd 5:50:25 PM 7/30/2013 bondp JULY, 2013 SCALE PROJECT NO DATE 

## US EPA REGION 6 MacMillan E. Front St E. Front St 

### Holloway

REF. 5, P. 10; REF. 6, PP. 30, 34