Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

1 Issued: June 1, 2009 

### OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
POST-CLOSURE AND CORR ECTIVE ACTION PERMIT
FOR A CLOSED HAZARDOUS WASTE MANAGEMENT FACILITY

EPA ID#: OKD058078775 Permit Number: OKD058078775-PC
Permittee: Sunoco, Inc. (R & M) Tulsa Refinery
1700 S. Union Effective Date: 6/1/2009 Tulsa, OK 74107-1734 Expiration Date: 6/1/2019

Mailing Address: Sunoco, Inc. (R & M) Tulsa Refinery
P.O. Box 2039 Tulsa, OK 74102-2039

Pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA) of 1976, including the H azardous and Solid Waste Amendments of 1984 (HSWA) at 42 U.S.C. § 6901 et seq ., and regulations promulgate d thereunder by the U.S. Environmental Protection Agency (EPA) codified in Title 40 of the Code of Federal Regulations, the Oklahoma Hazardous Waste Management Act (OHWMA) at 27A O.S. § 2-7-101, et seq ., as amended, and rules promulgated thereunder in the Oklahoma Administrative Code (OAC) 252:205, the Oklahoma Uniform Environmenta l Permitting Act at 27A O.S. § 2-14-101 et seq

., and rules promulgated thereunder in OAC 252:4- 7, a Permit to perform corrective action of a closed hazardous waste management facility is hereby issued by the Oklahoma Department of Environmental Quality (ODEQ) to Sunoco, Inc. (R & M) (hereafter called th e Permittee). The facility is located in the city of Tulsa, Oklahoma, at the st reet address shown above, at latitude N.

36 o 08' 025" and longitude W. 96 o 01' 015", summarily described as follows:

Legal Description of the Facility Boundary, which also constitutes the Permit Boundary:

AREA NO. 1 Beginning at the southwest corner of Section 9-T19N-R12E going 1,319.10' east along
the south line of Section 9 to the SW corn er of the SE/4, SW/4 ; thence north 1,319.99' to the Point of Beginning for Area No. 1; th ence N0°21'13"E a distance of 1,789.23' to the south Meander Line of the Arkansas River; thence N0o21'13” E a distance of 488.47' to the Thread of the Arkansas River; then ce N70o12'00"E a distance of 2,189.22'; thence N71o28'45"E a distance of 4,880.66' ; thence at an angle of 54o05,08" a distance (length) of 2,588.93' at a radius of 2,742.59' (also T=1,40 0.00'); thence S54o26'07"E a distance of 2,024.81'; thence S27o39'12"W a distance of 686.83' to the Meander Line of the Arkansas River; thence S27o39'12"W a distance of 254.9 9'; thence at an angle of S17o44'50" a distance (length) of 941.13' at a radius of 3,038.39' (also 424.38'); thence N89o11'33"W aSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

2 Issued: June 1, 2009 distance of 748.48'; thence S0o01'00"E a dist ance of 1,172.42'; thence at an angle of 13o5'14" a distance (length) of 204.40' at a radius of 894.88'; thence S78o46'27"W at a distance of 0.00'; thence N88o8'19"W a distance of 4,572.38'; thence N0o19'09"E a distance of 427.00' (M); thence S89o46' 32"W a distance of 522.13' (M); thence S0o19'09"W a distance of 407.99' (M); thence N88o08'19"W a distance of 3,958.37'to the Point of Beginning ending Area No.1 containing 703.86418 acres (M).

AREA NO. 2 Beginning at the southwest corner of S ection 11-T19N-R12E going 367.17' north along the west line of Section 11; thence N77o16'20"E a distance of (approx.) 25' to the Point of Beginning for Area No. 2; thence N0o 01'00"W a distance of 1,096.79'; thence S89o11'33"E a distance of 711.26'; thence S9o54'22"W a distance of 622.19'; thence S26o28'54"W a distance of 0.00'; thence at an angle of 50o47'26" a distance (length) of 793.28' at a radius of 894.88'; thence S77o16'20" W a distance of 0.00' to the Point of Beginning of Area No. 2 containing 13.64541 acres.

AREA NO. 3 Beginning at the SE corner of the SW/4 of the SE/4 of Section 10-T19N-R12E going north 50' (approx.) to the Point of Begi nning of Area No. 3; thence S85o57'55"W a distance of 300.92'; thence S89o46'32"W a dist ance of 2,348.95'; thence N0o14,06"E a, distance of 333.50'; thence S88o08'19"E a di stance of 2,093.62'; thence N1o51'41"E a distance of 25.00'; thence S88o08'19"E a di stance of 555.00'; thence S0o04'02"W a distance of 242.08' to the Point of Begi nning of Area No. 3 containing 17.59624 acres.

AREA NO. 4 Beginning at the SE corner of the SW/4 of the SE/4 of Section 9-T19N-R12E going north a distance of 50' (approx.) along the SW/4, SE/4 section line; thence N0o0'0"E a distance of 50' to the Point of Beginning of Area No. 4; thence N89o46' 36'W a distance of 1,319.10’ (M); thence N0o20'31"E a distan ce of 238.29' (M); thence N88o08'19"W a distance of 252.29' (M); thence N1o51'41"E a distance of 226.00'; thence S88o08'19"E a distance of 1,692.82'; thence S0o19'50"W a dist ance of 423.02' to the Point of Beginning of Area No. 4 containing 16.02264 acres.

(M) = Measured (D) = Deeded

The facility covered by this Permit cons ists of an integrated crude oil refinery, owned and operated by the Permittee, which ha s been in existence sinc e 1913. The refinery occupies approximately 800 acres, and is bordered by the Arkansas River on th e north. The Permittee has historically operated three (3) Land Treatment Units (LTUs) covering a total of 74.5 acres of the refinery property. These Units were operated under a previous RCRA Permit and are now closed. Due to past refinery operations, there are or have been a total of fifteen (15) non-permitted Solid Waste Management Units (SWMUs) in various locations over the site, consisting of landfills, ot her land treatment units, storage areas, and impoundments. As of the date of permit issuance, n one of these is actively operating. Some have been closed with waste in-place, while others were “clean-closed” and the
wastes have been re moved. Some of th e landfill SWMUs still require remedial actions to controlSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

3 Issued: June 1, 2009 and contain the wastes th ey hold. In add ition, portions of the groundwat er beneath the facility are contaminated with petroleum hydrocarbons, including a significant separate phase amount of Light Non-Aqueous Phase Liquids (LNAPL).

This Permit is issued to cover: the correctiv e action requirements for certain SWMUs and an Area of Concern identified herein, as well as recovery of the L NAPL beneath the facility. The post-closure care for the LTUs will be integrated into the corrective action requirements for the
SWMUs. This Permit does not authorize the co nstruction or operation of any active hazardous waste management units.

Prior to issuance of this Permit, several matters regarding co rrective action investigation, interim measures and remediation were being addressed under a 2002 Consent Order between Sunoco and ODEQ in Case No. 02-190. These matters have now been completed or are incorporated into the requirements of this Permit. In ac cordance with General Paragraph 11 of the Consent Order, the ODEQ will terminate this Consent Order upon the effective date of this Permit.

The Permittee must comply with a ll terms and conditions of this pe rmit. This permit consists of the conditions contained herein (i ncluding those in any attachments); the app licable regulations of OAC 252:205; and the applicable regulation s contained in 40 CFR Parts 124, 260 through 264, 266, 268, and 270, all as specified in the permit. Applicable regulations are those which are in effect on the date of issuance of the perm it, in accordance with 40 CFR 270.32(c). Primary responsibility for the enforcemen t under RCRA of the provisions of this permit shall lie with ODEQ.

This permit is based on the assumption that all the information submitted in the Part B permit application attached to the Permittee's letter date d October 31, 1998, as mo dified by subsequent submittals dated May (and received June 2), 19 99; December 17, 1999; October 1, 2001, April 15, 2002, May 5, 2002, May 24, 2002, July 17, 2002, August 1, 2002, Au gust 23, 2002, August 30, 2002, September 13, 2002, Septem ber 16, 2002, Septembe r 24, 2002, October 8, 2002, October 9, 2002, October 24, 2002, Nove mber 4, 2002, Novemb er 8, 2002, November 25, 2002, December 3, 2002, February 7, 2003, February 13, 2003, Febr uary 18, 2003, February 26, 2003, February 27, 2003, March 19, 2003, Ju ly 17, 2003, October 1 3, 2003, December 11, 200 3, February 6, 2004, March 5, 2004, March 1 1, 2004, March 26, 2004, May 14, 2004, Ma y 23, 2004, Augu st 13, 2004, November 13, 2004, Novemb er 24, 2004, July 19, 20 05, and January 30, 2007 (hereafter referred to as the application) was accurate when submi tted. Any inaccuracies fo und in the submitted information may be grounds for th e termination, revocation and reis suance, or modification of this permit in accordance with OAC 252:205 and 40 CFR 270.41, 270.42, an d 270.43, and for
enforcement action.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

4 Issued: June 1, 2009 This permit is effective as of June 1, 2009 and shall remain in effect until June 1, 2019 unless revoked and reissued under 40 CFR 270.41, term inated under 40 CFR 270.43, or continued in accordance with 40 CFR 270.51(a), OAC 252:205 and th e Oklahoma Administrative Procedures

Act.

Issued this 1st day of June, 2009.

Saba Tahmassebi, Ph.D., P.E. Date Chief Engineer
Land Protection Division Department of Environmental Quality

_______________________________ __________________ Scott Thompson, Director Date
Land Protection Division Department of Environmental QualitySunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

i Issued: June 1, 2009 TABLE OF CONTENTS

Page No.

SECTION I - GENERAL PERMIT CONDITIONS ............................................................. I-1
A. GENERAL ........................................................................................................... I-1
B. BASIS OF PERMIT ........................................................................................... I-1
C. INCORPORATION BY REFERENCE ........................................................... I-1
D. DEFINITIONS .................................................................................................... I-1
E. EFFECT OF PERMIT ....................................................................................... I-3
F. PERMIT ACTIONS ........................................................................................... I-4
G. SEVERABILITY ................................................................................................ I-5
H. DUTIES AND REQUIREMENTS .................................................................... I-5

I. SIGNATORY REQUIREMENT ..................................................................... I-10
J. REPORTS, NOTIFICATIONS, A ND SUBMISSIONS TO THE DEQ ...... I-10
K. CONFIDENTIAL INFORMATION ............................................................... I-10
L. DOCUMENTS TO BE MAINTAINED AT THE FACILITY ..................... I-10

SECTION II - GENERAL CONDITIONS .............................................................................II-1
A. DESIGN AND OPERATION ............................................................................II-1
B. WASTE DISPOSAL PROHIBITED .................................................................II-1
C. WASTE AND ENVIRONMENTA L MEDIA SAMPLING AND
ANALYSIS ..........................................................................................................II-1
D. SECURITY .........................................................................................................II-1
E. GENERAL INSPECTION REQUIREMENTS ...............................................II-1
F. PERSONNEL TRAINING ................................................................................II-1
G. PREPAREDNESS AND PREVENTION ........................................................II-2
H. CONTINGENCY PLAN ....................................................................................II-2

SECTION III - CORRECTIVE ACTION ............................................................................. III-1
A. SCOPE OF REQUIREMENTS ...................................................................... III-1
B. UNIT IDENTIFICATION .............................................................................. III-1
C. CORRECTIVE ACTION FOR LTUs ........................................................... III-4
D. INSPECTIONS AND MAINTENANCE ....................................................... III-6
E. SPECIFIC CONDITION – INVE STIGATION OF AREA OF
CONCERN ........................................................................................................ III-6
F. SPECIFIC CONDITION – CONTINUED REQUIREMENTS FOR
PREVIOUSLY IDENTI FIED SWMU AND AOC ......................................... III-7
G. FINANCIAL ASSURANCE ............................................................................ III-8

H. CAPACITY OF OWNERS OR OPERATORS, GUARANTORS, OR
FINANCIAL INSTITUTIONS ....................................................................... III-8
I. FINANCIAL ASSURANCE FO R CORRECTIVE ACTION ....................... III-9
J. LIABILITY REQUIREMENTS ..................................................................... III-9
K. LNAPL REMEDIATION ............................................................................... III-9
L. GROUNDWATER MONITORING ............................................................ III-13
M. STANDARD CORRECTIVE ACTION CONDITIONS ........................... III-20Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

ii Issued: June 1, 2009 LIST OF ATTACHMENTS

#1. INTEGRATED CONTINGENCY PLAN

#2. INSPECTION AND MAINTENANCE PLAN

#3. FINANCIAL ASSURANCE COST ESTIMATE

#4. GROUNDWATER MO NITORING PLAN

APPENDIX A - E520 GROUNDWA TER MONITORING PROGRAM

APPENDIX B - E521 GROUND WATER MONITORING SAMPLE
COLLECTION

APPENDIX C - E522 GROUNDWATE R MONITORING SAMPLE LIST

APPENDIX D - E523 GROUND WATER MONITORING DATA
EVALUATION REPORTING & MODIFICATIONS

APPENDIX E - E524 GROUNDWA TER MONITORING LNAPL AND
GROUNDWATER ELEVATION WELLS NETWORK

APPENDIX F - E525 GROUNDWA TER MONITORING LIST OF
MONITORING WELLS AND FUNCTIONS

#5. LIGHT NON-AQUEOUS PHASE LIQU ID (LNAPL) RECOVERY PLANSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-1 Issued: June 1, 2009 

### SECTION I - GENERAL PERMIT CONDITIONS

A. GENERAL

The Permittee shall monito r and maintain the facility in comp liance with the pr ovisions of the Oklahoma Hazardous Waste Management Ac t (OHWMA), 27A O.S. Sec. 2-7-101 et. seq

., Oklahoma Administrative Code Title 252 Chapte r 205 (OAC 252:205), the Federal Resource Conservation and Recovery Act (RCRA), including the 1984 Hazardous and Solid Waste Amendments to RCRA (HSWA), an d the approved permit applicatio n as further modified through
Permit Conditions set herein.

B. BASIS OF PERMIT

This permit is granted based on the information submi tted and the design crite ria presented in the Application dated October 31, 1998 and revise d by submissions throu gh January 2007. Any inaccuracies found in this information could prov ide cause for the termina tion or modification of this permit, and for enfo rcement action. The Permitt ee is to inform the Land Protection Division of the Department of Environmenta l Quality of any deviation from or changes in the design or operation of the facility which coul d affect the Permittee's ability to comply with the applicable regulations or Permit Conditions.

The term of this pe rmit is ten (10) years. Th is permit shall be reviewed by the DEQ five (5) years after the date of permit issuance and shall be modi fied as necessary, as provided in 40 CFR 270.41 and 27A O.S. § 2-7-127(B). Ex cept as provided in Permit C ondition I.F.3. (40 CFR 270.51) the term of this permit shall not be extended by mo dification beyond the expiration date appearing on the face of this perm it [40 CFR 270.50(b)].

C. INCORPORATION BY REFERENCE

All the referenced Code of Federal Regulations (40 CFR) Parts 124, 260 th rough 266, 268, and 270 as specified in the permit are, unless otherwis e stated, incorporated in their entirety by OAC 252:205-3-1 through OAC 252:205-3-6, as of the date of this permit.

D. DEFINITIONS

For purposes of this permit and th e special conditions pur suant to HSWA, terms used herein shall have the same meaning as thos e in 40 CFR Parts 124, 260, 261 , 264, 266, 268, an d 270; and OAC 252:205-1-2 through OAC 2 52;205-3-6; unless this permit sp ecifically provides otherwise. Where terms are not defined in the OAC, RCRA regulations, or the permit, a standard dictionary reference or the generally accepted scientific or industria l meaning of the term sh all define the meaning
associated with such terms.

“Action Levels” means health and environmental-based levels of constitu ent concentrations determined by the DEQ to be indicators for pr otection of human health and the environment.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-2 Issued: June 1, 2009 “Area of Concern” (AOC) means any discernable unit or area wh ich, in the opinion of the DEQ, may have received solid or hazardous waste or waste containing hazardous constituents at any time. The DEQ may require investigation of the unit as if it were a Solid Waste Management Unit (SWMU). If shown to be a SW MU by the investigation, the AOC must be reported by the Permittee as a newly-identified SWMU. If the AOC is shown not to be a SWMU by the investigation, the DEQ may determin e that no further action is neces sary and notify the Permittee in writing.

“CMS” means Corrective Measures Study.

“Corrective Action” means remediation as well as continued monitoring and long-term
maintenance of the SWMUs and LTUs.

“DEQ” or “ODEQ” means the Oklahoma Departme nt of Environmental Quality.

“Director” means the Executive Director of the Okla homa Department of Environmental Quality, or his/her designee or au thorized representative.

“Division Director” means the Director of the Land Protection Division of the Oklahoma Department of Environmental Quality, or his/ her designee or authorized representative.

“EPA” means the United States Environmental Protection Agency.

“Facility” means all contiguous property under the c ontrol of the owner or operator seeking a permit under Subtitle C of RCRA.

“HSWA” means the 1984 Hazardous and Solid Waste Amendments to RCRA.

“Hazardous constituent” means any constituent identified in Appendix VIII of 40 CFR Part 261, or any constituent iden tified in Appendix IX of 40 CFR Part 264.

“Hazardous waste” means a solid waste that is listed or identified as a hazardous waste in 40 CFR

Part 261.

“Land Protection Division” (LPD) means the Land Protec tion Division of the DEQ.

“NFA” or “No Further Action” means that no additi onal investigation or re mediation is known to be required for a designated SWMU or AOC, or por tion thereof. “NFA” status does not relieve the Permittee of continued monitoring and/or maintena nce of the area or unit, as may be specified
elsewhere in this Permit.

“Permit” means this permit as issued or modified, all Attachments to this permit, and conditions and documents incorporated, including all state and federal rules and law referenced herein.

“Permittee” means Sunoco, Inc. (R&M), Tulsa Refinery, 1700 S. Union, Tulsa, Oklahoma 74107.
EPA ID No. OKD058078775.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-3 Issued: June 1, 2009 “RCRA” means the Resource Conservation and Recove ry Act of 1980 as amended by HSWA in
1984.

“RFA” means RCRA Facility Assessment.

“RFI” means RCRA Facility Investigation.

“Regional Administrator” means the Regional Administrator of EPA Region VI, or his/her designee or authorized representative.

“Release” means any spilling, le aking, pouring, em itting, emptying, disc harging, injecting, pumping, escaping, leaching, dumping, or disposing of hazardous wast es or hazardous constituents
into the environmen t (including the abandonment or discar ding of barrels, containers, and other closed receptacles contai ning hazardous wastes or hazardous constituents).

“Solid Waste Management” means the systematic administrati on of activities wh ich provide for the collection, source separation, storage, transp ortation, transfer, pro cessing, treatment, and disposal of solid waste.

“Solid Waste Management Unit” (SWMU) means any discernible unit at which solid wastes have been placed at any time , irrespective of whether the unit was in tended for the management of solid
or hazardous waste. Such units include any area at a facility at which solid wastes have been routinely and systematically releas ed. The definition incl udes regulated units (i .e., landfills, surface impoundments, waste piles and land treatment units ) but does not include passive leakage or onetime spills from production areas and units in wh ich wastes have not been managed (e .g., product storage areas).

If, subsequent to the issuance of this permit, regulations are promulgated which redefine any of the above terms, the DEQ may, at its discretion, apply the new definiti on to this permit by modifying the permit in accordance wi th 40 CFR Se ction 270.41.

E. EFFECT OF PERMIT

The Permittee is required to monitor and maintain the closed hazardous waste la nd treatment units (LTUs) in accordance with the cond itions of this permit. Any storage, treatment, and/or disposal of hazardous waste not authorized in this perm it is prohibited, unless exempted from permit requirements. The Permittee is also required to investigate, remediate as necessary, monitor, and maintain the Solid Waste Management Units, Areas of Concern, and hydrocarbon plumes identified within or subsequent to the issuan ce of this Permit. Subject to 40 CFR 270.4, comp liance with this permit generally constitutes compli ance, for purposes of enforcemen t, with Subtitle C of RCRA. Issuance of this permit does not convey any property rights of any sort or any exclusive privilege, nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of state or local laws or regulations. Compliance with the terms of this permit does not constitute a defense to any order issued or any action brought unde r the OHWMA; Sections 3008(a), 3008(h), 30 13, or 7003 of RCRA; Sections 104, 106(a) or 107 of the ComprehensiveSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-4 Issued: June 1, 2009 Environmental Response, Compensa tion, and Liability Act of 1980 (42 U.S.C. 9601 et seq., commonly known as CERCLA), or any other law providing for protec tion of public health or the
environment from an imminent or substan tial endangerment. [40 CFR 270.4, 270.30(g)]

F. PERMIT ACTIONS

1 . Permit Modification, Revocation and Reissuance, and Termination

This permit may be modified, revoked an d reissued, or terminated for cause, as specified in 40 CFR 270. 41, 270.42, and 270.43. The fili ng of a request for a permit modification, revocation and reissuance, or termination, or the notification of planned changes or an ticipated noncompliance on the part of the Pe rmittee, does not stay the applicability or en forceability of any Permit Co ndition. [40 CFR 270.4(a), 270.30(f)]

2 . Permit Renewal

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

3 . Permit Expiration

Pursuant to 40 CFR 270.50, this permit sh all be effective for a fixed term not to exceed ten (10) years. This permit and all conditions herein will remain in effect beyond the permit's expira tion date, provided the Perm ittee has submitted a timely, complete application, and th rough no fault of the Permitt ee, the DEQ ha s not issued a new permit, as set forth in 40 CFR 270. 51. Permits continued under this section remain fully effective and enforceable. When the Permittee is not in compliance
with the conditions of the e xpiring or expired permit, the DEQ may choose to do any one or more of the following:

a. Initiate enforcement action based upon the permit wh ich has been continued;

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

c. Issue a new permit under Part 12 4 with appropriate conditions; or

d. Take other actions au thorized by law.

4 . Transfer of PermitsSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-5 Issued: June 1, 2009 This permit is not transferable to any pe rson, except after notic e to the DEQ. The DEQ may require modification or revocation and reissuance of the permit pursuant

to 40 CFR 270.40. Be fore transferring ownership or operation of the facility during its operating life, the Permittee shall notif y the new owner or operator in writing of the requirements of 27A O.S. Sec 2-7- 109, 40 CFR Parts 264 and 270 and this permit. [40 CFR 270.30(l)(3), 264.12(c)]

G. SEVERABILITY

The provisions of this pe rmit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to
other circumstances and the remainder of th is permit shall not be affected thereby.

H. DUTIES AND REQUIREMENTS

1 . Duty to Comply

The Permittee shall comply w ith all conditions of this pe rmit, except to the extent and for the duration an emergency permit authorizes that non compliance. Any permit noncompliance, other than nonco mpliance authorized by an emergency permit, constitutes a violation of OHW MA and RCRA and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. [40 CFR 270.30(a)]

2 . Duty to Reapply

The Permittee shall submit a complete app lication for a new permit at least 180 days before the expiration date of the effect ive permit. [40 CFR 270.10(h), 270.30(b)]

3 . Biennial Report

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

4 . Permit Expiration

Refer to Permit Condition I.F.3.

5 . Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee, in an enfo rcement action, that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the c onditions of this perm it. [40 CFR 270.30(c)]

6 . Duty to MitigateSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-6 Issued: June 1, 2009 In the event of noncomp liance with this permit, th e Permittee shall take all reasonable steps to minimize releases to the environment and shall carry out such
measures as are reasonable to prevent significant adverse impacts on human health or the environment. [40 CFR 27 0.30(d) and OAC 252:205-9-1]

7 . Proper Operation and Maintenance

The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and relate d appurtenances) which are installed or used by the Permittee to achie ve compliance with the cond itions of this permit. Proper operation and mainte nance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assu rance/quality control procedures. This provision requires the operati on of back-up or auxiliary f acilities or similar systems only when necessary to achieve compliance with the conditions of this permit. [40 CFR 270.30(e)]

8 . Duty to Provid e Information

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

9 . Inspection and Entry

Pursuant to 40 CFR 270.30(i), the Perm ittee shall allow the DEQ, or an authorized representative, upon the pr esentation of cred entials and other documents, as may be required by law, to:

a. Enter at reasonable times upon the Perm ittee's premises where a regulated facility or activity is located or cond ucted, or where reco rds must be kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipmen t (including monitoring and control equipment), practices, or operations regulat ed or required under this permit; and

d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance or as otherwise au thorized by RCRA, any substances or parameters at any location.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-7 Issued: June 1, 2009 10 . Monitoring and Records

Samples and measurements taken fo r the purpose of monitoring shall be representative of the monitore d activity. The method used to obtain a representative sample of the material to be analyz ed must be the appropriate method from Appendix I of 40 CFR Part 26 1 or an equivalent method approved by the DEQ. Laboratory methods must be those specified in the mo st recent edition of Test Methods for Evaluating Solid Waste: Physical/C hemical Methods SW-846

, Standard Methods of Wastewater Analysis , or an equivalent method approved in writing by the DEQ. [40 CFR 270.30(j)(1)]

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

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

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

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

3. The date(s) analyses were performed;

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

5. The analytical techniques or methods used; and

6. The results of such analyses.

11 . Reporting Planned Changes

The Permittee shall give notice to the DEQ, as soon as possibl e, of any planned material physical alterations or additions to the LTUs and SWMUs that are subject
to further corrective ac tion. [40 CFR 270.30(l)(1)]Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-8 Issued: June 1, 2009 12 . Reporting Anticipated Noncompliance

The Permittee shall give advance notice to the DEQ of any planned changes to the
LTUs and SWMUs that are s ubject to further corrective action, or to activities regarding such units, which may result in a material no ncompliance with permit requirements. [40 CFR 270.30(l)(2)]

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

a. The Permittee shall c onduct the sampling at the in tervals specified in this permit.

b. The Permittee must report th e results of all environm ental monitoring to the DEQ within thirty (30) days of receipt of the results of sample analyses from the analytical laboratory, or no later than seventy-five (75) days after the end of the sampling event, whichever comes first.

14 . Compliance Schedules

Reports of compliance or noncompliance w ith, or any progress reports on, interim and final requirements contained in any co mpliance schedule of this permit shall be
submitted no later th an fourteen (14) days following each scheduled date. [40 CFR 270.30 (l)(5)]

15 . Twenty-Four (24) Hour Reporting [40 CFR 270.30(1)(6) and OAC 252:205-13- 1]

a. The Permittee shall immediately re port to the DEQ any noncompliance, which may endanger human health or th e environment. If a release of
materials that are or become hazar dous waste occurs, and such release
could threaten human health and the environment, the Permittee shall take all necessary action to contain, remediate, and mitigate hazards from the release. Any such information shall be reported orally within twenty-for (24) hours from the time the Permittee becomes aware of the circumstances. The Permittee is not required to notify the DEQ of a release if it is completely contained in a secondary containment area, is remediated within 24 hours, or is less than 25 gallons. The report shall include the following:

1. Information concerning the release of any hazardous waste that may cause an endangerment to public drinking water supplies.

2. Any information of a release or di scharge of hazardous waste, or of a fire or explosion from the haza rdous waste management facility
which could threaten the environment or human health outside the facility.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-9 Issued: June 1, 2009 b. The description of the occurre nce and its cause shall include:

1. Name, address, and telephone number of the owner or operator;

2. Name, address, and telephone number of the facility;

3. Date, time, and type of incident;

4. Name and quantity of materials involved;

5. The extent of injuries, if any;

6. An assessment of actual or pot ential hazards to the environment
and human health outside the facil ity, where this is applicable; and

7. Estimated quantity and dispositio n of recovered material that
resulted from the incident.

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

16 . Other Noncompliance

The Permittee shall report all other in stances of noncompliance not otherwise required to be reported under Permit Conditio ns I.H.12 - 15, at the time monitoring reports are submitted. The reports shall contain the information required in Permit Condition I.H.15. [4 0 CFR 270.30(l)(10)]

17 . Other Information

Whenever the Permittee becomes aware that it failed to s ubmit any relevant facts in the permit application, or subm itted incorrect information in a permit application or in any report to the DEQ, the Permittee shall prompt ly submit such facts or information. [40 CFR 270.30(l)(11)]Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-10 Issued: June 1, 2009 I. SIGNATORY REQUIREMENT

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

J. REPORTS, NOTIFICATIONS, A ND SUBMISSIONS TO THE DEQ

All reports, notifications, or other submissions which ar e required by this permit to be sent or given to the DEQ should be sent by certified mail, overnight delivery, or hand delivery, to:

Saba Tahmassebi, Ph.D., P.E., Chief Engineer
Land Protection Division Oklahoma Department of Environmental Quality
707 N. Robins on, P.O. Box 1677 Oklahoma City, Oklahoma 73101-1677 Phone Number (405) 702-5100

K. CONFIDENTIAL INFORMATION

In accordance with 40 CFR 27 0.12 and OAC 252: 4-1-5(d) and OAC 252:205-1-4, the Permittee may claim confidential any informat ion required to be submitted by this permit. Any such claim
must be asserted at the time of submission in the manner prescr ibed on the application form or instructions, or in the case of other submission s, by stamping the words “confidential business information” on each page containing such informat ion. If no claim is ma de at the time of the submission, EPA and DEQ may make the information available to the public without fu rther notice. If a claim is asserted, the inform ation will be treated in accordanc e with the procedures in 40 CFR Part 2 (Public Information). Claims of confid entiality for the name and address of any permit applicant or Permittee will be denied.

L. DOCUMENTS TO BE MAINTAINED AT THE FACILITY

The Permittee shall ma intain at the facility, until corrective action is comple ted and certified by an independent, registered professional engineer, the following documents and all amendments,
revisions and modificati ons to these documents:

1. A list of the wastes that have been la nd treated or a list of hazardous constituents reasonably expected to be in or derived fro m the wastes that were land treated in the past in accordance with 40 CFR 270.14(b)(2).

2. Inspection schedules, as required by 40 CFR 264.15(b)(2) and this permit (See Permit Attachment 1).

3. Integrated Contingency Plan, as required by 40 CFR 264.53(a) and this permit (See Permit Attachment 1). This Plan need only be maintained at the facility until threeSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

I-11 Issued: June 1, 2009 (3) years after all SWMUs and/or regulat ed units are certified as closed or remediated, and such certificatio ns are accepted by the DEQ.

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

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

6. Annually-adjusted cost estimate for corre ctive measures (See Permit Attachment 3).

7. Groundwater Performance Monitoring Plan (See Permit Attachment 4).

8. LNAPL Recovery Plan (See Permit Attachment 5).Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

II-1 Issued: June 1, 2009 

### SECTION II - GENERAL CONDITIONS

A. DESIGN AND OPERATION

The Permittee shall maintain the LTUs and SWMUs that are subject to fu rther corrective action to minimize the possibility of a fire, explosi on, or any unplanned, sudden or non-sudden release of hazardous waste constituents to air, soil, gr oundwater, or surface water which could threaten human health or the environment, as required by 40 CFR 264 .31 and OAC 252:205-9-1.

B. WASTE DISPOSAL PROHIBITED

The Permittee shall not dispose of any hazardous wa ste on-site. Hazardous wastes generated at the facility may be temporarily stored on-site as specified in 40 CFR 262.34.

C. WASTE AND ENVIRONMENTAL ME DIA SAMPLING AND ANALYSIS

The Permittee shall follow the sampling and analys is procedures as detailed in the Groundwater Monitoring Plan, Permit Attachment 4. The analysis of all samples (waste, water, soils, etc.) is
to be conducted in accordance with the Groundwater Monitoring Plan.

At a minimum, the Permittee shall maintain proper functional instruments, use approved sampling and analytical methods, verify the valid ity of sampling and analytical procedures, and perform correct calculations. If the Permittee uses a contract laboratory to perform analyses, then the Permittee shall inform the laboratory in writing that it must operate under the sample analysis conditions set forth in this permit.

D. SECURITY

The Permittee shall comply with the securi ty provisions in Permit Attachment 1.

E. GENERAL INSPECTION REQUIREMENTS

The Permittee shall follow the inspection schedule s set out in Permit Attachments 2 and 4. The Permittee shall remedy any deterioration or malfun ction discovered by an inspection consistent with 40 CFR 264.15(c). Records of inspections sh all be kept consistent with 40 CFR 264.15(d).

F. PERSONNEL TRAINING

The Permittee shall ensure that all personnel pe rforming functions involvi ng hazardous waste are properly trained for the duties performed in accordance with 40 CFR 264.16. A description of the required training for personnel, and documents and records listing al l relevant training received, shall be maintained at the facility as required by 40 CFR 264.16(d) and (e). These
records shall be made available for inspection by DEQ personnel upon request.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

II-2 Issued: June 1, 2009 G. PREPAREDNESS AND PREVENTION

1 . Required Equipment

At a minimum, th e Permittee shall mainta in at the facility the equipment set forth in the Integrated Contingency Plan, Permit Attachment 1.

2 . Testing and Maintenance of Equipment

The Permittee shall test and maintain the equipment spec ified in Permit Condition II.G.1, as necessary, to assure its proper operation in time of emergency consistent
with 40 CFR 264.33.

3. Access to Communications or Alarm System

The Permittee shall maintain access to the communications or alarm system
consistent with 40 CFR 264.34.

4. Arrangements with Local Authorities

The Permittee shall maintain arrangements with state and local authoritie s consistent
with 40 CFR 264.37. If state or local officials refuse to enter into preparedness and prevention arrangements w ith the Permittee, the Pe rmittee must doc ument this refusal in the operating record.

H. CONTINGENCY PLAN

1 . Implementation of Plan

The Permittee shall immediately carry ou t the provisions of the Integrated Contingency Plan, Permit Attachment 1, whenever th ere is a fire, explosion, or
release of hazardous waste or constituents which could threaten human health or the
environment.

2 . Copies of Plan

The Permittee shall maintain and distribute copies of the Contingency Plan
consistent with 40 CFR 264.53.

3 . Amendments to Plan

The Permittee shall review and immediately amend, if necessary, the Contingency
Plan consistent with 40 CFR 264.54. Such amendment may require permit
modification in accordan ce with 40 CFR 270.42.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

II-3 Issued: June 1, 2009 4 . Emergency Coordinator

A trained emergency coordinator shall be available at all times in case of an emergency consistent with 40 CFR 264.55.Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-1 Issued: June 1, 2009 

### SECTION III - CORRECTIVE ACTION

A. SCOPE OF REQUIREMENTS

This Section addresses the corrective action that is required for the closed Land Treatment Units (LTUs), the identified Solid Wast e Management Units (SWMUs), an Area of Concern (AOC), and any newly-identified SWMUs and potential AOCs. These requirements include groundwater monitoring, development of grou ndwater media protection standards, and financial assurance for
corrective measures. This Sec tion also addresses the recovery requirements fo r the Light NonAqueous Phase Liquids (LNAPL). The LTUs and SWMUs are identified as described below.

B. UNIT IDENTIFICATION

1 . Land Treatment Units (LTUs) (A lso referred to as SWMU 16)

The LTUs are composed of three designated plots consisting of approximately 74.5 total acres: 1) East Land Treatment Area (16.47 acres); 2) Central Land Treatment Area (27.34 acres); and 3) West (Allison) Land Treatment Area (30.69 acres). The LTU facility has been operated since the mid-1970’s , and managed un der permitted regulation status since 1988 . Wastes applied to the LTU consisted of liquid and solid residues from various on-site refinery operations. The listed hazardous wastes that were historically app lied (hazardous waste applicati on ceased in 1994) to the LTU included: Dissolved air floatation (D AF) float (K048), slop oil emulsion solids (K049), API separator sludge (K051), lead ed gasoline tank bottom sludge (K052), and oil/water/solids separation sludge (F 037). Although these were the primary waste streams applied, other hazardous and non-ha zardous wastes ha ve been treated
in the unit. The Closure Certification fo r these units was accep ted on August 22,

2003.

2 . The SWMUs are identified as:

a. SWMU 1 (Midco Landfill) is a closed landfill site of approximately 2.5 acres which originally received petroleum sludge s; the wastes were subsequently removed for disposal el sewhere and the area was backfilled
with soils and construction/demolition debris. The landfill was closed in 1982 and was not a regulated unit unde r the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in no further [corrective] action (NFA) status.

b. SWMU 2 (West Landfarm) use began in the mid to late 1970s. The unit is approximately 175 feet by 375 feet and is a former land treatment unit. It has not been utilized since 1980. The 1988 RCRA permit required a RFI for SWMU 2. The Permittee completed the RFI in accordance with an approved work plan. The Permittee concluded that there were no hazardous constituents above background and requested a determinationSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-2 Issued: June 1, 2009 for no further action. This SWMU has been deleted from the permit. (See Table III.B.)

c. SWMU 3 (Tetraethyl Lead (TEL) Weathering Area) has gone unused since before 1966. It is approximate ly 500 feet by 30 feet. The SWMU was a staging area for steel used in hydrofluoric acid a nd TEL service. The Permittee cleaned the unit during the winter of 1981. The July 21, 1986 RFA Report included a recommendation for no further action due to prior waste removal. The 1988 RCRA permit did not require a RFI for SWMU 3. This SWMU has been deleted from the permit. (See Table III.B.)

d. SWMU 4 (Asphalt Sludge Landfill) is a closed landfill which was used for the disposal of asphaltic sludges and re lated wastes. The landfill is on the northern edge of the refinery property, on the bank of the Arkansas River. Use of the landfill ceased before 1966, and a mixed cover of shale and native soils was placed on the area. S eepage was noted from the base of the fill, and in 2003 an interim re medial measure was implemented to place a collection and drainage trench on the downgradient edge of the landfill, and recap the fill. The area was also contoured for proper drainage, and erosion control. Th e closure of this SWMU was accepted on March 12, 2004. The SWMU is currently subject to continued monitoring and operation of the collection system.

e. SWMU 5 (North Petroleum Sludge Landfill) is located in the north-central portion of the Facility, north of the USACE levee. Historically, SWMU 5 was utilized for deposition of acid sludge and other petroleum sludges, coke fines, spent filter clays, cata lyst fines, and demolition waste. Deposition ceased prior to 1971. The Permittee has completed an interim remedial measure that involves re-g rading of the SWMU 5 area, erosion control measures, stabil ization of the riverbank, limited removal and conditioning of exposed surface waste, limited removal and conditioning
of waste material from the riverbank and the adjacent riverbed, and overall SWMU surface conditioning. The inte rim remedial measure was accepted by the DEQ in February 2007.

f. SWMU 6 (Northeast Landfill) is located in the extreme northeastern area of the refinery. It occupies an area of approximately 9 acres according to past documents. The unit received demolition debris, acidic petroleum sludges and clays (presumed to be filter clays), tank bottom sludge, refining residue from burn pits a nd trash from a period between 1949, or earlier, until some time between 1954 and 1961. The Permittee implemented an interim measure for SWMU 6 involving re-grading of the SWMU area, erosion control measur es, stabilization of the riverbank, limited removal and conditioning of exposed surface waste, limited
removal of waste material from the riverbank and the adjacent riverbed,Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-3 Issued: June 1, 2009 and overall SWMU surface conditioning. Remedial activities were completed in 2006.

g. SWMU 7 (East Landfill) is a closed landfill of approximately 6 acres which received spent filter clays, petroleum sludges, rock, gravel, and
trash. The landfill was closed no later than 1961 and a number of structures and refinery units have b een constructed above it; the unit was not a regulated unit under the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in "NFA" status. (See Table III.B.)

h. SWMU 8 (Scrap Metal Landfill) is a closed landfill of approximately 0.3 acres which received scrap metals fr om hydrofluoric acid service (and possibly from tetraethyl lead service). The landfill was closed prior to 1980 and was not a regulated unit unde r the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in "NFA" status. (See Table III.B.)

i. SWMU 9 (Concrete Sump) is a concrete pad used from 1973 to 1981 to collect petroleum sludge. During th e time of the RFA visual Facility inspection in 1986, the SWMU was in use to melt wax removed from tanks. The July 21, 1986 RFA Report included a recommendation for no further action except for inclusion in the facility -wide groundwater program. The 1988 RCRA permit did require a RFI for SWMU 9. The Permittee completed the RFI in accordance with an approved workplan. The Permittee found influence of a hydr ocarbon plume 12 to 13 feet below the ground surface. The Permittee id entified a clean zone below the SWMU and above the hydrocarbon plume. This information indicates the hydrocarbon plume found beneath the SW MU did not originate from this unit, but from historical petroleum l eaks and spills. Therefore, this SWMU has been deleted from the permit. (See Table III.B.)

j. SWMU 10 (Wastewater Treatment System) consists of a number of above-ground and in-ground tanks and vessels, and a ssociated piping and ancillary equipment, which treats all re finery wastewaters for discharge. The unit is an active operations unit as of the date of issuance of this
Permit.

k. SWMU 11 (Spray Pond) is a former cooling water pond now used to
collect storm water runoff. It was us ed for cooling water until circa 1960.
It was converted to a storm wa ter pond circa 1972. The July 21, 1986 RFA Report included a recommendation for no further action except for
inclusion in the faci lity-wide groundwater program. The 1988 RCRA permit did require a RFI for SWMU 11. The Permittee completed the RFI in accordance with an approved workplan. The Permittee concluded that the RFI results showed no significan t results greater than background, andSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-4 Issued: June 1, 2009 requested a determination for no furt her action. The Permittee collected storm water samples from the SWMU April 14, 1999. All results complied with NPDES permit limits. This SWMU has been deleted from the permit. (See Table III.B.)

l. SWMU 12 (Cat Cracker Landfill) is a closed landfill of approximately 3 acres which received cinders, coke fine s, railroad engines, rocks, scrap wood, scrap metal, and bricks. The landfill was closed prior to 1948, and a number of structures and refinery un its have been constructed above it; the unit was not a regulated unit under the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in "NFA" status. (See Table III.B.)

m. SWMU 13 (Scrap Metal Landfill) is a closed landfill of approximately
900 ft 2 which received steel parts remove d from hydrofluoric or tetraethyl lead service. The landfill was closed prior to the implementation of RCRA and a gas flare has been cons tructed above it; the unit was not a regulated unit under the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in "NFA" status. (See Table III.B.)

n. SWMU 14 (Allison Property Landf ill) is a closed landfill of approximately 2.5 to 3.0 acres wh ich received asphaltic sludges for disposal. The landfill is believed to have ceased operation before 1943, and has undergone Interim Measures which were approved by the U.S. EPA. These Interim Measures were completed in 1995. The unit was not a regulated unit under the initial RCRA operating Permit of October, 1988. As of the date of issuance of this Permit, the SWMU is in "NFA" status. (See Table III.B.)

o. SWMU 15 (Storm Water Impoundments) is composed of the East and West basins. They operate as surg e basins for nonhazardous stormwater and emergency process wastewater by-passes. These were RCRAregulated units from 1991 when they were managing hazardous wastewater. In 1994, they were cl ean closed and ceased being RCRAregulated. The basins are underlain by a liner system composed of two feet of compacted clay and an ei ghty-mil HDPE liner. This SWMU has been deleted from the permit. (See Table III.B.)

C. CORRECTIVE ACTION FOR LTUs

1. Pursuant to 40 CFR 264.90(f), 264.110( c), 264.118(b)(4) and (d)(2), and 264.140(d), which have been incorporated by reference at OAC 252:205-3-2(f), DEQ may replace all or part of the post-closure requirements of 40 CFR 264.91 through 264.100 applying to the regulated LTU s with alternative requirements forSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-5 Issued: June 1, 2009 groundwater monitoring and corrective action, including financial responsibility, where DEQ determines, as it has, that:

a. The regulated LTUs are situated among solid waste management units (or areas of concern), a release has occurred, and both the regulated LTUs and
one or more SWMUs or AOCs are like ly to have contributed to the release; and

b. It is not necessary to apply the groundwater monitoring and corrective action requirements of subsections 264.91 through 264.100 because alternative requirements will protect human health and the environment.

Accordingly, instead of the post-closu re care requirements at 40 CFR 264.91 through 264.100, the Permittee shall conduc t groundwater monitoring and corrective action, including financial resp onsibility, for the LTUs in th e same manner as for the
SWMUs as summarized in Tabl e III.B. and as specified in this permit. The LTUs
will be identifi ed as SWMU 16.

2. The Permittee shall implement the Inspection and Maintenance Plan, Attachment

2.

3. The Permittee shall not allow any use of the units designated in Permit Condition III.B.1 which will disturb the integrity of the final cover, any components of the containment system, or the function of th e facility’s monitoring systems. [40 CFR 264.117(c)].

4. The Permittee shall comply with the requirements for land treatment units as follows: [40 CFR 264.280(c)]

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

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

c. Maintain the run-on control syst em required under 40 CFR 264.273(c).

d. Maintain the run-off management system required under 40 CFR 264.273(d).

e. Control wind dispersal of hazardou s waste as required under 40 CFR 264.273(f).Sunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-6 Issued: June 1, 2009 f. Continue to comply with any proh ibitions or conditions concerning growth of food-chain cr ops required under 40 CFR 264.276.

5. The Permittee may irrigate the LTUs using treated wastewater as specified in
Permit Number OK0000876 issued under the Oklahoma Pollutant Discharge Elimination System. In addition to the re quirements of that Permit, the following will also apply:

a. Applications will be limited to a volume of water equivalent to 3⁄4" (0.75 inch) over the area irrigated during a twenty-four (24) hour period. The maximum volume of water applied annually to any LTU area shall be limited to six inches (6"), without prior written notice to the DEQ.

b. At least annually, the Permittee shall ev aluate the effects of the irrigation, if any, upon groundwater elevation, flow, and quality, and report the results of this evaluation to the DEQ.

D. INSPECTIONS AND MAINTENANCE

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

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

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

b. Continue to operate any hydrocarbon removal system(s) in accordance
with Section III.K.

c. Prevent run-on and run-off from erodi ng or otherwise damaging the final cover; and

3 . The Permittee shall maintain the groundw ater monitoring system required under
Section III.L.

E. SPECIFIC CONDITION – INVEST IGATION OF AREA OF CONCERN

1. Within ninety (90) days of issuance of th e permit, the Pe rmittee shall s ubmit to DEQ a work plan, including a schedule, to asse ss the current and pot ential releases of
hazardous wastes and hazardou s constituents from AOC 1 as defined in Table III.B.Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-7 Issued: June 1, 2009 2. After DEQ’s written approval of the work plan, and in acc ordance with the approved schedule, the Permittee shall conduct the assessment and submit a report to DEQ identifying and discussing the findings a nd any recommendations for further action, and proposing a schedule for implementation of any recommended further action. After DEQ’s review and approval or approval with modifications of the recommendations, the permit sh all be modified in accordan ce with Section III.M. to specify any further action that the Permittee shall und ertake regarding AOC 1.

F. SPECIFIC CONDITION – CONTINUED REQUIREMENTS FOR PREVIOUSLY
IDENTIFIED SWMU AND AOC

1. SWMU 10 – Wastewat er Treatment System

a. The Permittee shall provide written notice to the DEQ at least fifteen (15) calendar days prior to beginning any excavations, repairs, expansions or
other modifications of this SWMU wh ich would involve the exposure of
soils or other materials contaminated with haza rdous constituents. The notice shall include a description of the work anticipated, the extent of any excavations, the area of th e unit affected, and the prov isions to be used to evaluate any exposed mate rials for proper handling to prevent any release of
hazardous constituents whic h might affect human heal th or the environment.

i. In the event immediate repairs are needed to the unit to prevent or minimize a non-perm itted release to the enviro nment, or significant economic loss to the Permittee, or to respond to an emergency situation, the requirem ent for written prior no tification in Permit Condition III.F.1.a. is waived, provid ed that the alternate notification requirements of Perm it Condition III.F .1.a.ii. ar e followed.

ii. In the event immediate repairs to the unit are deemed necessary under Permit Condition III.F.1.a.i, the Permittee shall notify the DEQ by telephone or facsimile transmissi on as soon as possible (but no later than twenty-four (2 4) hours after the need for immediate repair is recognized), and shall submit the formal written notification
described under Permit Condition III. F.1.a. within 15 calendar days after repair work begins.

b. The Permittee shall provide written no tice and a plan to the DEQ at least sixty (60) calendar days prior to beginning the closure, replacement or reconstruction of any in-ground or be low-ground units within this SWMU. Said Plans are subject to revi ew and approval by the DEQ.

2. AOC 2 – Areas E, F, G Riverbank Containment System

a. The Permittee installed a system to contain L NAPL and prevent LNAPL
releases from the riverbank in Area s E, F and G. The system becameSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-8 Issued: June 1, 2009 operational on December 31, 2007. Construction drawings for installation of the system were s ubmitted to DEQ on April 28, 2008. The drawings were approved by DEQ on May 5, 2008.

G. FINANCIAL ASSURANCE

The Permittee shall maintain financial assuran ce for the LNAPL Containment Systems identified in Condition III.K.1.a, the groundwater monitoring system for the wells identified in Condition III.L.2.a.i., and the remedial measures that main tain the integrity and covers of the LTUs and SWMUs, all of which shall be collectively referre d to as the “Current Co rrective Measures.” The Permittee shall maintain financial assurance under this Condition III.G. during the ten year term of this Permit and any period of continuance prior to re-issuance. In all other respects, the
financial assurance shall be consistent with all applicable requireme nts of 40 CFR Part 264 Subpart H as if the costs were post-closure ca re costs [40 CFR 264.145], in cluding the following:

1 . The Permittee has submitted updated cost estimates for the financial assurance required by Condition III.G., which, subject to any changes required by Conditions III.G.2, 3 or 4 a nd Condition III.I, shall be used as the basis of the financial assurance. Within sixty (60) days of the effective date of this permit, the Permittee shall update the fina ncial assurance to cover th e updated cost estimates.

2 . Within sixty (60) days of DEQ’s approva l of any new corrective measure for an LTU, SWMU, or AOC, the Permittee shall subm it a cost estimate consistent with 40 CFR 264.145. Within sixty (60) days of DEQ approval of such cost estimate, the Permittee shall update the financial assu rances to include the estimated costs.

3 . The cost estimates shall be adjusted annually consistent with 40 CFR 264.144 and
264.145.

4 . The DEQ may approve a decrease in the co st estimate for the financial assurance
mechanism if the owner or operator demonstrates to the DEQ that the amount of the cost estimate exceeds the remaining co st of the Current Corrective Measures or any new corrective meas ures [40 CFR 264.145(f)(9)].

5 . The owner or operator is no longer require d to submit the specified items [40 CFR 264.145(f)(3)] necessary to demonstrate he/s he meets the financial test when the requirements of 40 CFR 264.145(f)(10) are met.

H. CAPACITY OF OWNERS OR OPERATOR S, GUARANTORS, OR FINANCIAL
INSTITUTIONS

The Permittee shall comply with 40 CFR 264.148, whenever necessary.Sunoco, Inc. R&M
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III-9 Issued: June 1, 2009 I. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION

The Permittee shall demonstrate c ontinuous compliance with its fi nancial assurance obligations in the permit by providing documentation of fina ncial assurance consis tent with 40 CFR 264.151 or 264.149, in at least the amount of the cost estimates required by Permit Condition III.G. Changes in financial assurance mechanisms must be approved by the DE Q consistent with 40
CFR 264.145 or 264.149.

J. LIABILITY REQUIREMENTS

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

K. LNAPL REMEDIATION

1 . General Requirements

The Permittee shall maintain an d continue to operate the LNAPL recovery and containment systems currently in place as described by A ttachment 5. In additi on, the Permittee shall install, maintain, and operate any additional re mediation systems deemed necessary by this
Section.

a. Existing remediation systems for the recovery and removal of Light NonAqueous Phase Liquids (LNAPL), c onsisting of petroleum hydrocarbons and related materials, are designated as follows:

i. Containment systems consisting of r ecovery wells, as described in
Attachment 5. These wells are lo cated primarily on the northern boundary of the refiner y, to prevent LNAPL from leaving the facility property and entering the Arkansas River. Modifications to these systems will require the written approval of the DEQ as specified in Attachment 5, but shall not be cons idered as Permit Modifications.

ii. LNAPL recovery systems consisting of recovery wells, as described
in Attachment 5. Thes e wells are located throu ghout the interior of the refinery to remove specific ar eas of LNAPL. Modifications to these systems may be made at th e discretion of the Permittee, provided the overall effectivenes s of the system(s) is(are) not
reduced.

2 . Interim LNAPL Remediation Goals

a. The interim goals of the LNAPL re mediation program are to recover LNAPL and prevent sheening in the Ri ver. To achieve these goals, inSunoco, Inc. R&M
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III-10 Issued: June 1, 2009 addition to continuation of the LNAPL Containment and Recovery Systems as described in Att achment 5, the Permittee shall:

i. Conduct bi-weekly inspections for sheening along the entire length of the facility to de tect the presence of hydrocarbon discharge to
the Arkansas River.

ii. If sheening in the same area is identified during four consecutive biweekly (fortnightly) inspections, wi thin fifteen (15) days of the fourth bi-weekly inspection, the Permittee shall notify the DEQ in writing. Such notification shall in clude a summary of relevant data or observations, a preliminary identification of the known or suspected source of and reasons for the sheening, and any other information deemed pert inent by the Pe rmittee. The Permittee shall request a conference with DEQ to ob tain its review and preliminary concurrence regarding the probable source of the sheening. After obtaining DEQ’s preliminary concurrence, the Permittee shall undertake the appropriate action as follows:

A. If the sheening is believed to be from the LNAPL plume which is present on the surfa ce of the water table beneath SWMUs 4, 5, 6 or 14, within ni nety (90) days of DEQ’s concurrence regarding the probable source, the Permittee shall submit a work plan to DEQ proposing further investigations, assessments, or containment measures that should be undertaken, and a schedule for all proposed work;

or

B. If the sheening is believed to be from releases of waste in the
surface or subsurface areas of SWMUs 4, 5, 6 or 14, within the later of ninety (90) days of DEQ’s concurrence regarding the probable source or three year s from the date in which the
installation of the re medial measures was completed at the probable source SWMU, the Pe rmittee shall submit a work plan to DEQ proposing further in vestigations, assessments, or
remedial measures that should be undertaken and a schedule for all proposed work; or

C. If the sheening is believed to be from the LNAPL plume which is present on the surfa ce of the water table beneath
AOC 1 as defined in Table III.B. or from releases of waste in
the surface or subsurface areas in AOC 1, the Permittee shall address the sheening in the AOC 1 Assessment required under Condition III.E., or if that AOC 1 Assessment has been completed, within 180 days of DEQ’s concurrence regarding the probable source, the Permitte e shall submit a work plan toSunoco, Inc. R&M
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III-11 Issued: June 1, 2009 DEQ proposing investigations, assessments, containment systems, or remedial measures that should be undertaken, and a schedule for all proposed work.

ii. After DEQ approves the propos ed work, the Permittee shall implement the approved work in accordance with the approved
schedules.

iii. In addition, the Permittee shall employ booms as necessary to control the migration of floating hydrocarbons in the River.

iv. The Permittee shall also continue to con duct the semi-annual
evaluations of the LNAPL Cont ainment Systems and the LNAPL Recovery Systems and provide DEQ with the semi-annual reports as required by Attachment 5.

3 . Additional Remedial Measures and Modification of Existing Measures

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

i. at the written reques t of the Permittee;

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

iii. upon a determination by th e DEQ that the facility is not meeting the
Interim LNAPL Remediation Goals of Condition III. K.2.a., and the Permittee is not taking the proper and prompt actions necessary to return to compliance, regardless of a showing of intent or incapacity on the part of the Permittee.Sunoco, Inc. R&M
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III-12 Issued: June 1, 2009 4 . Maintenance, Upkeep and Testing of Remediation Systems

The Permittee shall perform all functions nece ssary to maintain the performance of the LNAPL remediation systems at the facility at the levels specified by this Permit. Unless otherwise allowed by this Conditi on (III.K.4), all remediation systems are to be kept in continuous operation.

a. A “shutdown” is considered to be the complete cessation of activities by one (1) or more of the five (5) area containment systems. Intermittent operation which occurs on a scheduled basis (for example, to allow back flushing of filters, or water table stab ilization) shall not be considered as a
shutdown.

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

c. Temporary shutdowns for unschedul ed or unexpected maintenance purposes, including the replacement of equipment, caused by malfunctions in the remediation system shall not be deemed as an interruption of operation, provided the shutdown(s) are for no longer than a total period of seventy-two (72) hours from discove ry in any thirty (30) day period.

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

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

f. If the Permittee has reason to believe that a shutdown of a remediation system is of a duration to adversely impact the timely achievement of the requirements of this permit, prio r approval from the DEQ must be obtained. The request shall include:

i. The reason for the ex tended shutdown, and its expected duration;

ii. The anticipated effect of the shut down upon the achievement of the requirements of this permit.Sunoco, Inc. R&M
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III-13 Issued: June 1, 2009 iii. Alternative remediation approaches which may be considered if the
shutdown continues for mo re than one (1) year;

iv. Any other information the Permittee deems relevant.

5 . Recordkeeping and Reporting

a. The Permittee shall record the volumes of LNAPL recovered from all Containment and Recovery Systems, a nd any relevant data. This data, along with all monitoring, testing, and maintenance records obtained pursuant to Permit Condition III.K.2., sh all be entered in the operating
record.

b. The Permittee shall prepare a repor t on the effectiveness of the Containment and Recovery Systems at least semi-annually, and shall submit said Report concurrently with the groundwater analytical reports required by Permit Conditions III.L.7.

L. GROUNDWATER MONITORING

1 . Highlights

The groundwater monitoring pr ogram is comprised of three major components: 1) facilitywide groundwater monitoring of the dissolve d phase petroleum hydrocarbons at the wells identified in Appendix F of Attachment 4, includ ing specific monitoring at the closed Land Treatment Units (LTUs); 2) a secondary monitoring program to map separate-phase LNAPLs which float atop the groundwater; and 3) development of interim goals for contaminated groundwater discharging to the Arkansas River.

Ordinarily, an LTU that receive d hazardous waste after July 26, 1982 must comply with the requirements of 40 CFR 264.91 through 264.100 for purposes of detecting, characterizing, and responding to releases to the uppermost aq uifer. The detection monitoring system is
utilized to determine whether h azardous contaminants have migr ated from the LTU into the uppermost aquifer. Solid Waste Management Units (SWMUs) which may also impact the groundwater are normally monitored separately under 40 CFR 264.101. However, because the LTUs are intimately situat ed with many of the SWMUs, under 40 CFR 264.90(f), a single, facility-wide ground water monitoring program is required for the facility.

The facility-wide Groundwater Monitoring Syst em has been and shall continue to be designed, constructed, operated, and maintain ed to enable evaluation of groundwater resources at the facility point-of-compliance (including interaction with surface water). The monitoring system will be maintained in accordance with the detailed plans and specifications presented in the Facility-Wid e Groundwater Performa nce Monitoring Plan (Permit Attachment 4) dated February 26, 2003, as modified by this Permit. The monitoring system consists of 38 wells (9 upgradient, 3 interior, and 26 downgradient or Point of Compliance wells).Sunoco, Inc. R&M
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III-14 Issued: June 1, 2009 The viscosity of the LNAPL vari es over the facility, and ranges from lighter distillates (e.g., kerosene) to heavier range hydrocarbons (e.g., lube and fuel oils). The LNAPL Monitoring Program is also described in A ttachment 4, and consists of mo re than 400 gauging wells as
of the initial date of th is permit. These are used to determ ine the presence of LNAPL, and its thickness, where possible. In some wells the LNAPL is too viscous to allo w an accurate
determination of its thic kness in relationship to the water table surface.

The Permittee is required to de termine the elevation of the gr oundwater beneath the facility, and LNAPL presence and thickness at the locations id entified in Appendix E of Attachment 4, at least semi-annually. Th ese values are regularly reporte d to the DEQ along with the analytical results from semi-annual samp ling of the elevat ion and quality of the groundwater at the monitoring wells identi fied in Appendix F of Attachment 4. Moni toring will continue until such time as the requireme nts of this Permit are met.

2 . Well Location, Installation and Construction

a . The Permittee shall maintain a gr oundwater monitoring system, as specified below:

i. The Permittee shall main tain groundwater moni toring wells at the locations specified on the map pres ented in Permit Attachment 4, and in conformance with Appendix F of Attachment 4. Well locations may be added as directed by the DE Q, or at the discretion of the Permittee, using installation methods and procedures approved by the DEQ. Wells may only be de leted or changed following the approval by DEQ.

ii. The Permittee shall main tain the monitoring wells identified in
Permit Condition III.L. 2.a.i, in accordance with the plans and specifications presented in Perm it Attachment 4, unless otherwise approved by DEQ.

iii. All wells deleted from the ground water monitoring system shall be plugged and abandoned in accordance with procedures approved by the Oklahoma Water Resources Board (OWRB), unless the well(s) is retained for use in the groundwate r elevation monitoring network. Well plugging and abandonment meth ods and certification shall be submitted to the DEQ within 90 da ys from the date the wells are removed from the monitoring program.

b . The Permittee shall maintain an LNAPL Monitoring System, as specified below. The LNAPL Monitoring System is divided into three (3) subsets; an LNAPL Containment subsystem, an LNAPL Recovery subsystem, and an LNAPL/Groundwater Elevation gauging subsystem. The Permittee shall maintain the LNAPL Monitoring System of wells at the locationsSunoco, Inc. R&M
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III-15 Issued: June 1, 2009 specified on the map presented in Permit Attachment 4, and in conformance with Appendix D and Appendix E of Attachment 4, and
Attachment 5.

i. Well locations may be added or delete d as directed by the DEQ, or at the discretion of the Permittee, using installation methods and procedures approved by the DEQ. Any additions or deletions shall be consistent with the objective to accurately indicate both LNAPL presence and thickness, and ground water elevation, over the facility, and shall be reported to the DEQ semi-annually.

ii. Except as provided in Condition II I.L.2.b.i., the Permittee shall maintain the wells identified in Permit Condition III.L.2.b., in accordance with the plans and spec ifications presented in Permit
Attachments 4 and 5.

iii. All wells deleted from the monitoring program shall be plugged and abandoned in accordance with proc edures specified by the Oklahoma Water Resources Board (OWRB). Well plugging and abandonment
methods and certification shall be submitted to the DEQ at least semi-annually, as appropriate.

3 . Sampling Parameters, Frequency and Location

a . The Permittee shall obtain and analyze samples from all groundwater wells listed in Appendix F of Att achment 4 as described in Permit Condition III.L.4. and as designated in Permit Attachment 5. Samples shall be obtained using the followi ng schedule, and analyzed for the parameters indicated:Sunoco, Inc. R&M
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III-16 Issued: June 1, 2009 Wells Designated As (see Appendix F of

Attachment 4): Sampling Frequency Sampling Month(s)* Parameters Analyzed**

Upgradient Annual April Appendix F in Attachment 4, All

Interior Annual April Appendix F in Attachment 4, Metals only

Downgradient Semi-Annual April, October Appendix F in Attachment 4, All
* The month of sampling may be altered a maximum of one (1) month with written permission of the DEQ, for good cause shown, on a case-by-case basis

. ** All wells shall be field analyzed for pH , Specific Conductivity, and Temperature, each time the wells are sampled.

4 . Sampling and Analysis Procedures

The Permittee shall us e the following techniques and pr ocedures when obtaining and analyzing samples from the groundwater monitoring wells described in Permit Condition

III.L.2:

a . Samples shall be collected using the techniques described in Permit Attachment 4. All groundwater monitoring wells shall be sampled in a single, contiguous time period unless otherwise approved by the DEQ.

b . Samples shall be preserved and shippe d in accordance with the procedures specified in Permit Attachment 4

.

c . Samples shall be analyzed in accordan ce with the procedures specified in
Permit Attachment 4. A ll analyses shall comp ly with the methods specified by EPA publication SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Third Edition including Updates I, II, IIA, IIB, III, and IIIA. The Permittee shall adopt any future updates or
modifications to these methods within two (2) years of their effective date(s).

d . Samples shall be tracked and contro lled using the chain-of-custody procedures specified in Permit Attachment 4.

5 . Elevation of the Groundwater Surface a nd Presence of Separate-Phase Liquids

a . The Permittee shall determine the LNAPL elevation and thickness, and the groundwater surface elevation at ea ch Groundwater Monitoring Well and at each LNAPL Gauging Well identifie d in Appendix E of Attachment 4 at least semi-annually, in conjunc tion with groundwater sampling in
accordance with Permit Condition III.L.7. Elevation determinations shall be made immediately prior to sampling events.Sunoco, Inc. R&M
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III-17 Issued: June 1, 2009 b . The Permittee shall record the surveyed elevation of all monitoring well(s) when installed (with as-built drawings). The total depth of wells and the elevations of the following should be recorded: top of casing, ground surface and/or apron elevation, and the top of the protective casing.

c . At least every three (3) years following issuance of this Permit, the Permittee shall re-survey the well locat ions and elevations of each well
identified as a “POC” well in Appendix E to Attachment 5.

d . At least every three (3) years following issuance of this Permit, the Permittee shall check the total depths of all groundwater monitoring and gauging wells for siltation or infiltra tion of solids. If siltation or infiltration has occurred such that the total effective depth of any well has been reduced by more than twelve (12) inches, the Permittee shall promptly redevelop all affected wells to remove the solids and re-establish well depth.

6 . Development of Interim Groundw ater Protection Standards

Permittee has demonstrated through rou tine groundwater and LNAPL sampling and gauging and through successive i nvestigations and re ports that groundwater exists within an overburden made of flood plain alluvium under unconfined conditions . As a result, all groundwater beneath the facility discharges to the Arkansas Ri ver. Groundwater is not a source of drinking water and the potential receptors of any contaminated groundwater would be in the River and sediment of the River. Permittee shall develop appropriate interim goals for contaminated groundwater discharging into the Arkansas River (“Interim Goals”). These Interim Goals will be based on protection of potential receptors in the River and sediment and may be qualitat ive and/or quantitative in nature. These Interim Goals may also become final goals for groundwater at the facility, through a process that confirms the beneficial use of groundwater, the technical impracticability of achieving media cleanup standards throughout th e facility and the effectiveness of groundwater remediation systems developed under this permit to meet existing standards.

a . Within 180 days of the date of issuan ce of this permit, the Permittee shall submit to the DEQ a proposed method to develop the Interim Goals for contaminated groundwater; i.e., disso lved phase petroleum hydrocarbons, discharging to the River. The method shall consider the factors identified in 40 CFR 264.94(b)(2) and all other rele vant factors. Upon approval of the method, the Permittee shall devel op the Interim Goals and within 180 days of the approval, submit same to the DEQ. Approval of the proposed interim goals shall constitute a Perm it Modification in accordance with 40

CFR 270.42.

b . Beginning with the approval of the Interim Goals under Condition III.L.6.a., above, the Permittee shall use the Interim Goals to evaluate the analytical results from all downgrad ient/Point of Compliance groundwaterSunoco, Inc. R&M
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III-18 Issued: June 1, 2009 monitoring wells in Appendix F in Attachment 4 after each sampling event, using the schedules shown in Condition III.L.8. and the approved
methods.

c . The goals may differentiate between c ontamination caused by activities of the Permittee, and contamination caused by others or occurring naturally.

7 . Monitoring Program and Data Evaluation

The Permittee shall de termine groundwater qua lity as follows:

a . The Permittee shall collect, preserve, and analyze groundwater samples from the wells in Appendix F in Attachment 4 pursuant to Permit
Condition III.L.4.

b . The Permittee shall determine the con centration of hazardous constituents (as specified in Permit Condition III.L.3.) in groundwater at each monitoring well identified in Appendix F in Attachment 4. These
determinations shall be made at le ast semi-annually, during the months specified in Condition III.L.3.a.

c . The Permittee shall determine the groundw ater flow rate and direction in the uppermost aquifer at least annually.

d . The Permittee shall perform the evaluation required by Permit Condition III.L.6. after each sampling event.

8 . Reporting and Recordkeeping

a . The Permittee shall enter all monito ring, testing, and analytical data obtained pursuant to Permit Condition III.L.7. in the operating record. The data must include all computati ons, calculated means, variances, and
results of statistical tests.

b . The Permittee shall submit the analytical, measurement, and evaluation results required by Permit Conditions III.L.4, III.L.5, and III.L.6, in accordance with the following schedule:

Results Submitted to DEQ Within 45 Days after Sampling Sampling Event is Comp leted, but No Later Than: April June 15
October December 15

c . For any compound found in the analysis from Permit Condition III.L.4. above, the Permittee may resample within one month and repeat theSunoco, Inc. R&M
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III-19 Issued: June 1, 2009 analysis for those compounds. If the results from this second analysis confirm the initial results, then these results will form the basis for future evaluations. If the Permittee does not resample for the compounds identified above, the hazardous cons tituents found during the initial analysis will form the basis for future evaluations.

d . The Permittee may make a demonstration that the results are due in whole or in part to sources other than thos e under the control of the Permittee, or errors in sampling, analysis or evaluation. For such demonstration:

i. The Permittee must noti fy the DEQ in writing, within seven (7) days
of the submission under Condition III.L.8.b. that a demonstration
will be made.

ii. The Permittee must submit a report to the DEQ, within 90 days, that
demonstrates that a source not u nder the control of the Permittee caused the result in whole or in pa rt, or that the apparent result
stemmed from an erro r in sampling, analysis or evaluation.

iii. Within 90 days, submit to the DE Q an application for a permit modification to make any appropria te changes to the monitoring program at the facility.

iv. Continue to monitor in accordanc e with the modi fied monitoring program at the facility.

v. If the DEQ does not approve the al ternative source demonstration,
the Permittee shall im plement the measures in Condition III.L.9.

9 . Additional Assessments and Remedial Measures

a . If, after applying the methods for co mparing the results under Condition III.L.6.a., the evaluation finds an exceed ance of the Interim Goals for two consecutive sampling periods, th e Permittee shall undertake an assessment, and within ninety (90) days after submittal of the second consecutive report of an exceedance, the Permittee shall submit a report identifying additional investigations that should be conducted, changes to the methods of comparison, validati on or confirmation that should be made, and/or remedial measures that should be undertaken.

b . The Permittee shall monitor the gr oundwater and report results as specified in this Section III.L. Af ter considering the results of such monitoring, and as necessary to protect human health and the environment, DEQ may require further assessment of the environmental
conditions or remedial measures. Such assessments and remedialSunoco, Inc. R&M
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III-20 Issued: June 1, 2009 measures shall be adopted as a pe rmit modification pursuant to a DEQ
initiated modification in accordance with 40 CFR 270.41 or a Permitteeinitiated modification in accordance with 40 CFR 270.42.

M. STANDARD CORRECTIVE ACTION CONDITIONS

1 . Permit Modification

a . DEQ Initiated Modifications

If at any time for any of the reasons specified in 40 CF R 270.41, the DEQ
determines that modification of th is Permit is necessary, the DEQ may initiate permit modification proceedings in accordan ce with the regulations
set forth at 40 CFR 270.41.

b . Permittee Initiated Modifications

The Permittee may, where appropriate, initiate permit modifications in accordance with the regulations set fo rth at 40 CFR 270.42. All applicable requirements and procedures as sp ecified in 40 CFR 270.42 shall be followed by Permittee in initiating such proceedings.

c . Modification of Corrective Action Schedules

i. The Permittee shall adhere to the due dates contai ned in this permit. If at any time the Permittee determin es that such schedules cannot be met, the Permittee shall, within fifteen (15) days of such determination, notify the DEQ an d submit a request for a permit
modification under 40 CF R 270.42, with a justification as to why the
due date cannot be met.

ii. If the DEQ determines th at a modification of a due date is required, the permit modification procedures of 40 CFR 270.42 will apply.

iii. The Permittee will submit the prop osed modification. Such proposed
modification will:

A. Describe the exact changes to be made to the permit conditions;

B. Provide an explanation of wh y the modification is needed.

d . Notwithstanding the foregoing Conditions , changes and extensions of the due date for any submittal under this Permit are Class 1 permit modifications with prior approval. Ex tensions to final compliance datesSunoco, Inc. R&M
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III-21 Issued: June 1, 2009 established by the permit fo r the entire faci lity should be considered as
Class 3 modifications.

2 . Permit Review

This Permit may be reviewed by the DEQ fi ve (5) years after th e date of permit issuance and may be modified as necessary as provided for in Permit Condition III.M.1.a. Nothing in this section shal l preclude the DEQ from reviewing and modifying the Permit at any time during its term.

3 . Compliance with Permit

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

a . Become effective by statute;

b . Are promulgated under 40 CFR 268 rest ricting the placement of hazardous wastes in or on the land; or

c . Are promulgated under 40 CFR 264 regard ing leak detection systems for new and replacement surface impoundme nt, waste pile, and landfill units, and lateral expansions of surface impoundment, waste pile, and landfill units. The leak detection system re quirements include double liners, CQA programs, monitoring action leakage ra tes, and response action plans, and will be implemented through the procedures of 40 CFR 270.42 Class 1 permit modifications.

4 . Information Submittal

Failure to comply with any condition of the Permit, including information submittal, constitutes a violation of the Permit and is grounds for enforcement action, permit amendment, termination, revocation, suspensi on, or denial of permit renewal application. Falsificati on of any submitted information is grounds for termination of this Permit (40 CFR 270.43).

The Permittee shall ensure that all plans, reports, and notifications required in this Permit to be submitted are signed and certified in accordance with 40 CFR 270.11. Two (2) copies and one (1) 3.5" 1.44 MB floppy disk or 5.25” CDROM, Windows® compatible, each of these plans, reports, notifications or other submissions shall be submitted to the DEQ by Certified Mail or hand delivered to:Sunoco, Inc. R&M
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III-22 Issued: June 1, 2009 Saba Tahmassebi, Ph.D., P.E. Chief Engineer
Land Protection Division Oklahoma Department of Environmental Quality

P.O. Box 1677
707 North Robinson Oklahoma City, Oklahoma 73101-1677 (405) 702-5100

5 . Plans and Schedules Inco rporation Into Permit

All plans and schedules re quired by this Permit are, upon approval by the DEQ, incorporated into this Permit by reference and become an enforceable part of this Permit. Since required items are essential elements of this Permit, failure to submit any of the required items or subm ission of inadequate or insufficient information may subject the Permittee to enforcement action under Section 3008 of RCRA, or 27A O.S. § 2-3-502, whic h may include fines, suspension, or
revocation of the Permit.

Any noncompliance with approved plan s and schedules shall be termed noncompliance with this Permit. Written requests for extensions of due dates for submittals may be granted by the DEQ in accordance with Permit Condition III.M.1.c. If the DEQ determines that actions beyond those provided for, or changes to what is stated herein, are warranted, the DE Q may modify this Permit according to procedures in Permit Condition III.M.1.c.

6 . Data Retention

All raw data, such as laboratory reports, dr illing logs, bench-scale or pilot-scale data, and other supporting information ga thered or generate d during activities undertaken pursuant to this Permit shall be maintained at the facility during the term of this Permit, including any reissued Permits. The Permittee may request the DEQ’s approval to retain such docume nts, including in electronic format and off-site, provided such documents can be readily retrieved for review by DEQ.

7 . Management of Wastes

All solid wastes which are managed pursu ant to a remedial measure taken under the corrective action process or as an in terim measure addressi ng a release or the
threat of a release from a solid waste management unit shall be managed in a manner protective of human health and th e environment and in compliance with all applicable Federal, State and local requirements. Unless an exemption to permitting applies, approval of units for managing hazardous wastes and conditions for operating the units, if approved, shall be granted through the permitting process.Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-23 Issued: June 1, 2009 8 . Specific Condition - Information Repository

a . Within thirty (30) days of the effective date of this Permit, the Permittee shall establish an information repository to provide the public an opportunity to review and comment on the corrective action activities specified in this Permit. This repos itory shall be established at a local public library or similar facility wh ich is easily accessible to the public during normal working hours.

b . Within thirty (30) days of the effective date of this Permit, the Permittee shall mail a notice to all individuals on the facility-specific mailing list maintained by the DEQ, including all individuals that submitted oral or
written comments on the Permittee's draft permit duri ng the public comment period. The Permittee shall amend this mailing list as necessary
to include those individuals that su bmit a written request to the DEQ and
the Permittee for inclusion in this list.

c . This notice shall state the location, pur pose, and content of the repository. A copy of this notice shall be provided to the DEQ, for approval, prior to mailing to the public.

d . The Permittee shall state in this noti ce that written comments concerning each submittal (excluding progress re ports and correspondence) required by this Permit shall be forwarded to the following representative of the DEQ within fifteen (15) calendar da ys of the date due to the DEQ:

Saba Tahmassebi, Ph.D., P.E. Chief Engineer
Land Protection Division Oklahoma Department of Environmental Quality

P.O. Box 1677
707 North Robinson Oklahoma City, Oklahoma 73101- 1677

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

9 . Additional Corrective Action

Corrective Action for Releases: Section 3004(u) of RCRA, as amended by HSWA, and 40 CFR 264.101, requires that permits issued after November 8, 1984, addressSunoco, Inc. R&M
OKD058078775-PC
Post-Closure and Corrective Action Permit

III-24 Issued: June 1, 2009 corrective action for releases of hazardous waste or hazard ous constituents from any SWMU at the Facility, rega rdless of when the waste was plac ed in the unit.

The Permittee originally identified SWMUs which were listed in the original Part B RCRA Operating Permit, issued November 1, 1988. Based on this information, the Permittee performed a RCRA Fa cility Investigat ion and subsequently performed remedial action on SWMU 14. SWMUs 4, 5, and 6 were further investigated during
corrective action activities auth orized initially in an Ad ministrative Consent Order entered into by the Permittee and DEQ on July 5, 2002.

The Permittee has completed interim remedial measures on SWMUs 4, 5 and 6.
These interim measures will be observed for the dura tion of this Permit, and if deemed satisfactory may be designated as permanent remedi es. The LTUs (SWMU 16) also are subject to corrective measur e requirements under th e permit, including groundwater monitoring and cover maintena nce. No additional SWMUs requiring corrective action have been identified for pur poses of this permit . In the event that
the Permittee discover s newly-identified SWMUs the Permittee shall notify the DEQ as provided herein. This Permit shall be modified to include the additional requirements for corrective action fo r any newly identified SWMUs.

The Permittee is concurrently performi ng remedial measures on groundwater beneath the facility, caused by the existence of a relativ ely large area of separatephase petroleum hydrocarbons. These se parate-phase hydrocarbons, or LNAPLs,
consist of both raw crude oils and refined products, and were released during operations over the life of the facility. The LNAP L remediation activities are covered by Permit Conditio n III.K, LNAPL Remediation.

10 . Reporting Requirements

a . The Permittee shall submit, in accord ance with Permit Condition III.L.4, signed semi-annual progress reports of all corrective action activities conducted pursuant to the provisions of this Permit beginning no later than ninety (90) calendar days from the effective date of this Permit. These reports shall contain:

i. A description of the work completed and an estimate of the percentage of work completed;

ii. Summaries of all findings, includ ing summaries of laboratory data;

iii. Summaries of all problems or potential problems encountered during the reporting period and actio ns taken to rectify problems;

iv. Projected work for the next reporting period;Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-25 Issued: June 1, 2009 v. Summaries of contacts pertai ning to corrective action or environmental matters with representatives of the local community, public interest groups or State government during the reporting period;

vi. Changes in key project personnel during the reporting period; and

vii. Summaries of all changes made in implementation during the reporting period.

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

c . In addition to the written reports as required in Permit Condition III.M.10.a. and b above, at the reque st of the DEQ, the Permittee shall provide status review through semi -annual briefings with the DEQ.

11 . Notification Requirements for and Asse ssment of Newly-Identified SWMUs and
Potential AOCs

a . The Permittee shall notify the DEQ, in writing, of any newly-identified SWMU(s) and potential AOCs (i.e., a unit or area not specifically identified during the RFA), discover ed in the course of groundwater monitoring, field investigations, envir onmental audits, or other means, no later than thirty (30) calendar days after discovery. The Permittee shall also notify the DEQ of any newl y-constructed land-based SWMUs (including but not limited to, surface im poundments, waste piles, landfills, land treatment units) and newly-constr ucted SWMUs where any release of hazardous constituents may be diffic ult to identify (e.g., underground storage tanks) no later than thirty (30) days after construction. The notification shall include the following items, to the extent available:

i. The location of the newly-identif ied SWMU or potential AOC on the topographic map required under 40 CFR Section 270.14(b)(19). Indicate all existi ng units (in relation to other SWMUs);

ii. The type and function of the unit;

iii. The general dimensions, capacities, and structural description of the unit (supply any av ailable drawings);

iv. The period during which the unit was operated;Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-26 Issued: June 1, 2009 v. The specifics, to the extent available, on all wastes that have been or are being managed at th e SWMU or potential AOC; and

vi. Results of any sampling and analys is required for the purpose of determining whether releases of hazardous waste including
hazardous constituents have occurr ed, are occurring, or are likely
to occur from the SWMU or whether the AOC should be
considered a SWMU.

b . Based on the results of this Notification the DEQ will designate the newlyidentified AOC(s). Based on the results of this notification or investigation conducted according to Permit Condition III.M.9., the DEQ will determine the need for further investigations or corrective measures at any newly-identified SWMU(s) or AOC(s ). If the DEQ determines that such investigations are needed, the DEQ may require the Permittee to prepare a plan for such investigati ons. The plan for investigation of SWMU(s) or AOC(s) will be reviewed for approval as part of the RFI
Work Plan or a new RFI Work Plan under Permit Condition III.M.15. The Permit will be modified according to Permit Condition III.M.1.c to incorporate the investigation requi rements for the newly-identified AOC(s) or SWMU(s).

12 . Notification Requirements for Newly-Di scovered Releases at SWMU(s) and AOC(s)

The Permittee shall notify the DEQ in writi ng, no later than fifteen (15) calendar days after discovery, of a ny release(s) from a SWMU or AOC of hazardous waste
or hazardous constituents discovered during the course of groundwater monitoring, field investigation, environmental auditing, or other means. Such newly-discovered releases may be fr om newly-identified SWMUs or AOCs, newly-constructed SWMUs, or from SWMUs or AOCs for which, based on the findings of the RFA, completed RFI, or investigation of an AOC(s), the DEQ had previously determined no further investigation was necessary. The notification shall include information concerning act ual and/or potential impacts beyond the facility boundary and on human health and the environment, if available at the time of the notification. The DEQ may require further investigation and/or interim measures for the newly-identified release(s), and may require the Permittee to prepare a plan for the investigation and/or interim measure. The plan will be reviewed for approval as part of the RFI Work Plan or a new RFI Work Plan under Permit Condition III.M.5. The Permit will be modified according to Permit Condition III.M.1 to incorporat e the investigation, if required.

13 . Interim Measures

a . If during the course of any activity initiated under this Permit, the DEQ determines that a release or potenti al release of hazardous constituentsSunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-27 Issued: June 1, 2009 from a SWMU poses a threat to human health and the environment, the DEQ may require interim measures . The DEQ shall determine the specific measure(s) or require the Pe rmittee to propose a measure(s). The interim measure(s) may include a permit modification, a schedule for implementation, and a written plan. The DEQ shall notify the Permittee in writing of the requirement to perfor m interim measures. The DEQ may modify this Permit according to Permit Condition III.M.18.a to incorporate interim measur es into the Permit. (27A O.S. §2-6-105; OAC 252:205-9-1 and 252:205-13-1)

b . The Permittee may propose interim measures at any time. The proposal shall include a written plan and a schedule for implementation. Depending upon the nature of the interim measure, a permit modification may not be required.

c . The following factors will be considered by the DEQ in determining the need for interim measures and the need for permit modification:

i. Time required to develop and implement a final remedy;

ii. Actual and potential exposure to human and environmental
receptors;

iii. Actual and potential contaminati on of drinking water supplies and sensitive ecosystems;

iv. The potential for further degradati on of the medium in the absence of interim measures;

v. Presence of hazardous wastes in c ontainers that may pose a threat of release;

vi. Presence and concentration of hazardous waste including
hazardous constituents in soil that ha ve the potential to migrate to groundwater or surface water;

vii. Weather conditions that may a ffect the current levels of contamination;

viii. Risks of fire, explos ion, or accident; and

ix. Other situations that may pose th reats to human health and the
environment.

14 . Current Interim MeasureSunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-28 Issued: June 1, 2009 Surficial soil areas with observable disc oloration due to petroleum contamination have been addressed by the Permittee by “discing” each area to aerate it and
stimulate volatilization and natural biodegradation. C onfirmatory TPH analysis has demonstrated the resulting levels of di esel range organics and gasoline range organics to be below levels that apply in ODEQ’s underground storage tank program. Permittee shall report on progre ss made regarding this interim measure in the semi-annual progress reports under Condition III.M.10.

15 . RFI Work Plan

In the event that the Permittee discovers SWMUs or AOCs that require investigation, this Permit shall be modified to includ e the requireme nts for a RFI Workplan in this section.

16 . RFI Implementation

The Permittee has implemented an RFI at the Facility. In the event that the
Permittee identifies additional SWMUs or AOC s, this Permit may be modified to include requirements for an a dditional RFI im plementation.

17 . RFI Final Report and Summary

The Permittee has impl emented an RFI at the Facility and subm itted an RFI Final Report and Summary. In th e event that the Permittee id entifies add itional SWMUs or AOCs, this Permit may be modified to include requirements for an RFI Report and Summary.

18 . Determination of No Further Action (NFA)

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

If, based upon review of the Permitt ee's request for a permit modification, the results of the RFI, and other in formation, including comments received during any public comment period required for Class III permit modifications, the DEQ determines that releases or suspected releases which were investigated either are non- existent or do not pose a threat to
human health and/or the environmen t, the DEQ may grant the requested
modification.Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-29 Issued: June 1, 2009 b . If necessary to protect human health or the environment, a determination of no further action shall not preclu de the DEQ from requiring continued or periodic monitoring of air, soil, groundwater, or surface water, when site-specific circumstances indicate th at releases of hazardous waste or hazardous constituents are likely to occur.

c . A determination of no further action shall not preclude the DEQ from requiring further investigati ons, studies, or remediat ion at a later date, if new information or subsequent analysis indicates a release or likelihood of a release from a SWMU at the Facility that is likely to pose a threat to human health or the environment. In such a case, the DEQ shall initiate a
modification to the Permit.

19 . Corrective Measures Study (CMS) Plan

The Permittee has effectively completed a CM S Plan for the Facili ty. In the event that additional CMS work is required, th is Permit shall be mo dified to include requirements for a new CMS Plan.

20 . CMS Implementation

As of the date of Perm it issuance, the Permittee is implementing Corrective
Measures at the Facilit y. In the event that an additi onal CMS is requir ed, this Permit
shall be modified to include requirem ents for CMS implementation.

21 . CMS Final Report And Summary

The Permittee is implem enting Corrective Measures at the Facility. In the event that
the Permittee identifi es additional SWMUs or AOCs, th is Permit may be modified to include requirements for an RFI Report and Summary.

22 . Corrective Measure (Remedy) Selection and Implementation

The Permittee has completed corrective me asures selection and implementation at the Facility for all known SW MUs. In the event that the Permittee is required to perform additional corrective measures, th is Permit may be modified to include
corrective measure selection and implementation requirements.

23 . RFI Scope of Work

The Permittee has impl emented an RFI at the Facility and subm itted an RFI Final Report and Summary. In th e event that the Permittee id entifies add itional SWMUs or AOCs, this Permit may be modified to include requirements for an RFI Scope of
Work.Sunoco, Inc. R&M
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III-30 Issued: June 1, 2009 24 . CMS Scope of Work

The Permittee has completed corrective measures selection and implementation at the Facility for all known SW MUs. In the event that the Permittee is required to perform additional corrective measures, th is Permit may be modified to include requirements for a CMS Scope of Work.Sunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-31 Issued: June 1, 2009 TABLES

Sunoco, Inc. (R & M) Tulsa Refinery TABLE III.B. – SWMU DESIGNATION AND STATUS;
DEFINITION OF AREA OF CONCERN

Solid Waste Management Units (SWMUs)

SWMU

No. Name Original Permit

Status November 1, 1988 Permit Status 1
(As of Effective Date of this Permit)

1 Midco Landfill RFI to be performed Closed, NFA 2 West Landfarm RFI to be performed Deleted From Permit 3 TEL Weathering Area Deleted from Permit Deleted From Permit

4 Asphalt Sludge Landfill RFI to be performed Interim Measures Completed, Maintenance and Monitoring
for Additional Action.

5 Area D Landfill (not including AOC 2) Omitted from Permit Interim Measures Completed, Maintenance and Monitoring
for Additional Action.

6 Northeast Landfill RFI to be performed Interim Measures Completed, Maintenance and Monitoring
for Additional Action. 7 East Landfill RFI to be performed Closed, NFA 8 Scrap Metal Landfill RFI to be performed Closed, NFA 9 Concrete Sump RFI to be performed Deleted From Permit

10 Wastewater Treatment System RFI to be performed RFI Completed, No Immediate Action Required 2
11 No. 2 Spray Pond RFI to be performed Deleted From Permit

12 Cat Cracker Landfill RFI to be performed Closed, NFA 13 Scrap Metal Landfill Deleted from Permit Closed, NFA

14 Allison Property Landfill RFI to be performed Remedial Measures Completed, NFA 15 Storm Impoundment Basins RFI to be performed Deleted From Permit

16 Land Treatment Areas Operational Units Closed, Inspection and
Maintenance 17 Oily Sludge Roads Deleted from Permit Deleted From Permit

18 Tank Diked Areas Deleted from Permit Deleted From Permit 19 Unassigned 20 Unassigned 21 UnassignedSunoco, Inc. R&M
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Post-Closure and Corrective Action Permit

III-32 Issued: June 1, 2009

1. NFA Status, or “No Further Action”, indicates that the DEQ is not currently requiring any further action by the Permittee to remedi ate or close a part icular SWMU. NFA
Status does not relieve a Permittee from con tinued monitoring and maintenance of the unit, however.

2. Soils in the vicinity of SWMU 10 remain contaminated. Any future construction activities in the area, includi ng construction, modification, or closure of an existing unit, or excavation of soils, may be cause for initiating additional remediation
activities. Areas of Concern (AOCs) Name Description/Location

AOC 1 The area of the Sunoco, Inc. (R&M) Tulsa Re finery lying to the North of the crest of the Corps of Engineers flood levee, ex tending to the Northern facility property line, and extending from the eastern e nd of SWMU 14 (approximate facility coordinate line E. 2547700) eastward to the easternmost facility property boundary (approximate coordinate line E. 2556800). Said AOC does not include the previously located and de scribed SWMUs 4, 5, and 6.

AOC 2 This AOC encompasses Areas E, F and G and is the area of the Sunoco, Inc. (R&M) Tulsa Refinery immediately adj acent to the Corps of Engineers flood levee, and extending from the eastern end of SWMU 5 (approximate facility coordinate line E. 2552000) eastward to the western boundary of SWMU 6 (approximate facility coordinate line E. 2554500). Said AOC does not include
AOC 1 or SWMUs 5 or 6.

Locations of SWMUs and AOCs can be viewed on the following illustrations.