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Hudson Oil Refinery

CUSHING, PAYNE COUNTY, OKLAHOMA

EPA ID# OKD082471988

The site is an inactive refinery that operated from 1922 to 1982. Oklahoma State Highway 33 bisects the property, establishing areas known as the "North refinery," approximately 165 acres, and the "South refinery," approximately 35 acres. The refineries produced liquid propane gas, gasoline, aviation fuel, diesel fuel, and fuel oils from 1922 to 1982.

The Environmental Protection Agency (EPA) completed a classic emergency response action on the South refinery in 1999, to address the known existence of 23,000 square feet of loose and friable asbestos containing material (ACM), two lab buildings and 16 other buildings housing miscellaneous chemicals and drums. EPA also completed a classic emergency response on the North refinery in 1998, to address an anhydrous Hydrogen Fluoride ("HF") alkylation plant and an actively leaking 12,000 gallon HF storage tank and two tetraethyl lead (TEL) tanks. Additionally, EPA completed an Oil Pollution Act removal action to address nonhazardous oily waste, including oil-stained soils, tank bottoms, tank contents, etc.

In 2001, EPA completed an Engineering Evaluation/Cost Analysis (EE/CA) to investigate above-ground contamination remaining on the North Refinery. The EE/CA identified a potential exposure threat to human health from the North refinery through ingestion, dermal contact, or inhalation of over 70 hazardous chemicals potentially present at the site. These materials present both a cancer and non-cancer risk to human health. Toxic effects vary, ranging from minor skin and eye irritations to cancer, asphyxiation, and death. Some of the more toxic chemicals that may be present are tetra-ethyl lead (TEL), hydrogen sulfide (H2S), benzene, hydrochloric acid (HCL), hydrosulfuric acid, hydrofluoric acid (HF), mercury, arsenic, chromium, ammonia, and calcium hypochlorite. Also, the ACM associated with the piping and vessels at the facility is friable and has weathered and deteriorated over time posing an increasing risk of release to the air. Given the unstable physical and chemical conditions at the site, there is also an increasing threat to nearby residents and motorists on State Highway 33 of fire and explosion from improperly stored chemicals at the site.

An Action Memorandum for a Non-time Critical (NTC) removal action at the site was signed on September 25, 2001. The EPA has allocated the total project ceiling of $8,572,140 for this NTC removal, to address the refinery superstructure and miscellaneous items. The refinery superstructure includes 22 towers, 216 process vessels, and 8 buildings located within the project area, cooling towers, TEL buildings (North and South refineries), and associated aboveground piping. Miscellaneous items include contents of collection basins of the cooling towers and caustic sump, miscellaneous containers and drums, above-ground storage tanks (ASTs) outside the refinery superstructure, and structurally unsafe buildings. Because the North refinery was not properly purged at shutdown in 1982, chemicals remain in the lines and vessels. The contents of the process vessels and piping will be purged of chemicals and the remaining refinery superstructure will be dismantled. Concurrently, ACM from pipes and vessels will be abated. The dismantling of the superstructure may include the use of explosives to control the fall of the large towers and vessels.

The Hudson Oil Refinery site was proposed for placement on the NPL on April 23, 1999 [64 Fed. Reg. 19968 (1999)]and subsequently placed on the NPL on July 22, 1999 [64 Fed. Reg. 39878 (1999)]. The Oklahoma Department of Environmental Quality is currently preparing a work plan to conduct a Remedial Investigation/Feasibility Study (RI/FS) and baseline risk assessment to determine the extent of contamination in soil, surface water, and ground water. After completion of the RI/FS a Proposed Plan and a Record of Decision, followed by a Remedial Design and a Remedial Action will complete the remediation process.

On September 23, 2002, the EPA initiated work on the NTC removal action at the site. The EPA is conducting this work through an Interagency Agreement with the U.S. Corps of Engineers (USACE).