February 11, 2025
THIS MEETING HAS BEEN POSTPONED DUE TO WEATHER. WE WILL KEEP YOU ADVISED

February 1, 2025
UPCOMING PUBLIC MEETING 2.12.25 AND A SHORT HISTORY OF THE WEST REFINERY ON THE ARKANSAS RIVER

In response to the significant interest, ODEQ has scheduled a public hearing on the draft Resource Conservation and Recovery Act (RCRA) permit for HF Sinclair's West Tulsa Refinery.
After receiving comments between October 30, 2024 and December 16, 2024, ODEQ had to acknowledge the need for clarification and further public dialogue. READ ODEQ'S MEETING NOTICE.
As a result, the comment period for the public to register our comments, questions, and opposition to the proposed draft permit remains open. MAKE A PUBLIC COMMENT.
Tulsa Area Arkansas River Advocates (TAARA) has created an event page for folks who want to connect before the meeting. Arrive early (5:15-5:30 pm) to Show Your Love for the Arkansas River with TAARA!

PUBLIC MEETING DETAILS
WHEN: Wednesday, February 12, 2025 at 6:00 pm
WHERE: Aaronson Auditorium, Tulsa City-County Central Library, 400 Civic Center
If you are unable to attend the meeting in person, that's okay - LEAVE A COMMENT NOW - and leave more than one if you think of something you left out or if you want to ask another question.
The entire 348-page draft permit is not shown on ODEQ's Permits for Public Review webpage (apparently due to ODEQ file-size constraints) but does appear buried in dropdown menus on the Land Divisions Public Participation Process webpage.
To save you the trouble of hunting around and because TAARA knows how important it is for the public to be informed, we are linking the entire 348-page draft permit for you here.
Short History.
From Joshua Cosden’s original refinery there was a continuous line of companies spanning 96 years that ended with Sunoco. Holly, now known as HF Sinclair, purchased the refinery from Sunoco in 2009. In 2009, when the refinery was purchased, its new owners (Holly now HF Sinclair) took over the ODEQ-issued RCRA permit from Sunoco and agreed to assume all obligations under the existing RCRA permit including all financial assurance obligations. This RCRA permit was set to expire on June 1, 2019.
Prior to the expiration date, HF Sinclair made an application to renew the permit and it has taken 6 years to get to this point. The refinery owner has now had 16 years of RCRA permit experience.

Cosden Refinery. “The Cosden Refinery in West Tulsa (prior to being annexed by Tulsa). The cracking units heated oil at various temperatures, resulting in a variety of petroleum products.” The Beryl Ford Collection/Rotary Club of Tulsa, Tulsa City-County Library and Tulsa Historical Society. Accession # 0817. Accessed 2/18/22.

Mid Continent Petroleum fire, 1951. “Looking west across the Arkansas River. 01/06/1951.” The Beryl Ford Collection/Rotary Club of Tulsa, Tulsa City-County Library and Tulsa Historical Society. Accession #D2225. Accessed 2/18/22.

Sunray Mid-Continent refinery. “Looking east across the Arkansas River, circa 1950. The MidContinent Refinery and storage facilities in the west.” The Beryl Ford Collection/Rotary Club of Tulsa, Tulsa City-County Library and Tulsa Historical Society. Accession #A1085. Accessed 1/27/25.
The Permit.
Concerned citizens have identified problems with the draft permit and highlighted some of these issues.
LOCATING THE RCRA PERMIT DRAFT
The 348-page draft permit is not shown on ODEQ's Permits for Public Review webpage (apparently due to ODEQ file-size constraints) and instead shows a 72-page draft. The entire 348-page draft does appear on ODEQ's website although it is buried among dropdown menus on the Land Divisions Public Participation Process webpage. Because TAARA knows how important it is to be informed (and to spare you the trouble of hunting down the entire draft like we had to), we are linking the entire 348-page draft permit for you to read here.
CORRECTIVE ACTION PLAN MUST BE REQUIRED AND SUBJECT TO A DEADLINE
The draft permit application expresses the intention to continue the tasks defined in the permit for another 28 years, 44 years total, until 2053 without making a credible commitment to Corrective Action. It is time to move beyond an interim study-phase and commence corrective action.
Corrective Action requires a schedule, a plan and cost estimate to remove or fix in place the oil and chemicals of concern that have accumulated under the refinery since 1913. The draft permit “authorizes development of a Corrective Action Plan." We think that the permit should REQUIRE the submission of a Corrective Action Plan and post it for public comment and be subject to an explicitly stated deadline.
The West Refinery has used the Arkansas River as an oil-water separator for the last 6 years. Floating booms are not a “remediation system." ODEQ has the authority to require the Refinery to install emergency on shore measures to control LNAPL flowing to the river from Area C-5 and should do so.
Conclusions.
We are not okay with delay. We are not okay having our concerns dismissed. We know that this pollution is a today-problem and will not let ODEQ make it a tomorrow-problem for the grandchildren of our grandchildren to deal with.
Tell ODEQ:
It is time to move on from the study of the problem phase and take Corrective Action. EPA and DEQ should assemble the responsible parties and start this work.
Use of the river as an oil-water separator should end.
The Conceptual Site Model should be expedited.
MAKE A COMMENT TO ODEQ: link to Comment Form.
For more about hydrocarbon migration coming from the West Refinery into the Arkansas River see FOX23 Investigates: Tulsa fisherman shares concerns about Arkansas River (Janna Clark Jan 2, 2025).
See ARRC's Library of Documents for more information on the February 12, 2025 Meeting.
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A Bit More Insight.
WEST REFINERY MAP SHOWING AREAS OF CONCERN
The map below can be located on page 333 of the draft permit and identifies Areas of Concern (AOC) at the West Refinery Site where the migration of contaminated groundwater occurs.

Detail Figure 3.1 HF Sinclair Tulsa Refining LLC, Tulsa West Refinery Section 3 RCRA Permit Renewal Application.
Google Earth 8-11-22

WEST REFINERY AREA C-5
LNAPL (Light Non-Aqueous Phase Liquid - a type of groundwater contaminant that floats on top of water) has been flowing to the river from Area C-5 since August 2019.
Containment and Sorbent Booms are used to "recover" oil carried by groundwater to Zink Lake in the Arkansas River.
Private Drone 10-24

WEST REFINERY AREA C-5
The West Refinery has used the Arkansas River as an oil-water separator for the last 6 years.
Floating booms are not a “remediation system." ODEQ has the authority to require the Refinery to install emergency on shore measures to control LNAPL flowing to the river from Area C-5 and should do so.
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