hudson refinery


The Site is located in Payne County Oklahoma. The 200-acre site is located on the west side of the City of Cushing, Oklahoma. The Site is divided by State Highway (SH) 33 with 165 acres north of SH 33 (North Refinery) and 35 acres south of SH 33 (South Refinery). The Site is an abandoned refinery that operated from 1922 until ceasing operation in 1982. The Site historically included aboveground storage tanks, wastewater treatment impoundments, separators, stained soils, a land treatment unit, and loose and friable asbestos containing material. Surrounding the site are residential and agricultural lands to the north and commercial properties to the south. There are approximately 8,371 residents in the City of Cushing. Few structures currently remain on the site. Two removal actions took place at the Site. In 1999 emergency cleanup activities were initiated on both the North and South Refineries. The Removal Action Memorandum documented EPA’s determination that the Site presented an imminent and substantial threat to public health and the environment. Removal activities included investigation of radiation sources, demolition of structurally unsafe buildings, removal of tetra-ethyl lead (TEL), asbestos-containing material (ACM) abatement, disposal of waste containing hazardous substances. excavation of oil-contaminated soils; removal of product from above-ground storage tanks (ASTs), separators, and sumps; construction of a bioremediation land-treatment unit for biotreatment of Oil Pollution Act (OPA) wastes; dismantling of hydrofluoric acid alkylation unit with approximately 5,600 gallons of product, removal of all catwalks from the towers that were left standing, and the removal of TEL ASTs. From September 2002 through June 2003 EPA conducted a non-time-critical removal action. The areas addressed in this removal action included superstructures, refinery process units containing potential hazardous chemicals and substances, miscellaneous items, including unlined collection basins, a sump, and structurally unsafe buildings. Existing refinery process equipment and structures were dismantled and removed from the site. Friable ACM was removed from process equipment and piping in coordination with decontamination and removal activities. From 2004 through 2007, the Oklahoma Department of Environmental Quality conducted the Remedial Investigation and Feasibly Study. On November 23, 2007, EPA Region 6 selected the cleanup remedy for the Site and issued its Record of Decision (ROD). Cleanup construction for this site started in early 2010 and was completed in October 2010. A Unilateral Administrative Order (UAO), signed January 6, 2009, was sent to the company, Land O’Lakes, requiring it to implement the Site remedy outlined in the Record of Decision (ROD). It is EPA policy for parties that were responsible for site contamination to conduct and pay for the cleanup of Site contamination. Starting in May 2010, Land O’Lakes began cleanup of the wastewater ponds on the portion of the Site north of Highway 33. Clean-up steps included: removing water from the ponds, removing pond sediments that needed to be cleaned up, and filling in and grading the ponds so they would not hold water. Land O’Lakes discharged the pond water into Skull Creek at points along Depot Street north of Highway 33. The pond water was tested for pollutants. EPA and the Oklahoma Department of Environmental Quality (ODEQ) reviewed the results of the testing and determined that it was safe to discharge the water into Skull Creek. Land O’Lakes completed the construction for cleanup of contaminated soil, wastewater pond sediment, coke tar, asbestos containing debris, and tank and scrap metal from the Site as outlined in the ROD. Contaminated soil, wastewater pond sediment, and coke tar cleanup took place at various locations across the Site. Debris containing asbestos and two surface pipes wrapped with asbestos insulation were removed from the Site. The final excavation of waste and contaminated soil was completed in early October 2010. All waste and contaminated soil and sediment have been hauled off Site for disposal in an approved commercial landfill. Site excavations have been backfilled and graded. Two existing ponds have been modified to moderate the amount of storm water leaving the Site into Skull Creek. Need for Explanation of Significant Differences (ESD): On November 19, 2010, the EPA signed an ESD for the Site. The Superfund Program allows for changes in the remedy presented in the Record of Decision (ROD) if the remedial action taken differs significantly from the remedy selected in the ROD with respect to scope, performance, or cost. Significant Changes are those changes that generally involve a change to a component of the selected remedy, but do not fundamentally alter the overall cleanup approach. Work for some of the changes has already been completed. The ESD explains the differences between the cleanup action presented in the ROD and the cleanup action that has or will be completed onsite. The ESD outlined six significant changes from the ROD; it also documented minor changes. Brief descriptions of the six significant changes are included below: Wastewater Pond 6, Treatment Pond 8, and Runoff Pond 9 - Wastewater Pond 6, Treatment Pond 8, and Runoff Pond 9 will remain in service so that during a given precipitation event, storm water runoff from the Site will not be discharged to Skull Creek at higher flow rates than would currently occur for a like precipitation event. Ponds that required removal of contaminated sediment (Aeration Pond 7, Wastewater Ponds 1 through 3, and the Coke Pond) were not completely backfilled, but backfilled to provide a minimum of 2 ft. of clean cover soils, and then graded to promote runoff and prevent ponding of storm water runoff during precipitation events. Clean soils contained in the berms of Aeration Pond 7 and Wastewater Ponds 1-5 were utilized as borrow materials during Site backfilling and grading operations. Asbestos-Containing Material (ACM) – ACM volume addressed during remedy construction increased in volume from the ROD estimate. The ROD estimated the volume of ACM requiring removal as 10 cubic yards. Additional ACM was found during the RA. 460.82 cubic yards of ACM impacted soil/debris were removed from the Site and properly disposed. A total of 719 linear feet of ACM wrapped pipe was also removed; the piping weighed 1.7 tons. Scrap Metal – The volume/weight of tank and scrap metal debris, along with excavated piping, addressed during RA construction increased from the ROD estimate. The term “construction debris” was used by the landfill for general debris, building material, and contaminated soil mixed with concrete chunks, brick, and metal waste. The estimated volume of construction debris removed during the RA was 3,294 cubic yards calculated at 2.2 tons per cubic yard. Scrap metal, tank metal and piping weight hauled off-site for recycle or disposal was logged separately. The final weight for scrap metal, tank metal and piping was 242.62 tons. Ground Water Monitoring for Thallium – Thallium monitoring has been removed from ground water monitoring requirements. Thallium monitoring was conducted during the RD and during RA construction. Thallium was not detected in any of the ground water samples. Laboratory detection levels were well below the ROD cleanup level of 2.0 μg/L. Proper Plugging and Abandoning of Site Wells – Site wells which will not be part of operation and maintenance activities for ground water monitoring will be required to be properly plugged and abandoned. Institutional Controls – Site ownership has changed which affects filing of institutional controls required by the ROD.

Hazardous Ranking Score

29 / 100

A score of 28.5 or higher qualifies a site for the Superfund National Priority List.

Regional Contact

Region 6
Phone: (800) 887-6063

Contact Region



Site Inspection
Preliminary Assessment
Final Listing On NPL

Contaminants & Health Effects

      Endocrine Disrupter
      Reproductive Toxin
      Persistent, bioaccumulative and toxic


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        within a 1 mile radius


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