The Natural Resource Damage Assessment and Restoration (NRDAR) process was created under the authorization of the Clean Water Act (33 USC 1251 et seq.) of 1977; Comprehensive Environmental Response, Compensation and Liability Act (42 USC 9601 et seq.) of 1980 as amended; Oil Pollution Act (33 USC 2701 et seq.) of 1990; Organic Act; State and Tribal Laws.

Such provisions authorize natural resource trustees to recover compensatory damages for injury to, destruction of, or loss of natural resources resulting from a discharge of oil into navigable waters (OPA) or a release of a hazardous substance (CERCLA).

Regulations provide an administrative process for conducting assessments as well as technical methods for the actual identification of injuries and calculation of damages.



NRDA Work Group Funded *

* Washington Work Group NRDA Allotted Funding Administered through the BIA:

For Calendar year, Jan. 1 through Dec. 31, 2017

2017~ NRDA and NRDAR (Assessment and Restoration) Activities

The Peoria Tribe of Indians of Oklahoma, as a Natural Resource Trustee of the Tri-State Mining District / Tar Creek Superfund Site, was for the year 2017, active and continues to be involved in Natural Resource Damage Assessment and Restoration activities impacting the Peoria Tribe.  The Peoria Tribe Trusteeship is represented in (1) the Tar Creek Trustee Council in Oklahoma; and (2) the Trustee Councils of The Tri-State Mining District, in Kansas, Missouri, and Oklahoma.  This has been accomplished through the participation of Environmental Specialist Larry Tippit of the Peoria Environmental Department.   His participation is described in the following narrative.  We anticipate that these same activities will continue through Calendar Year 2018.  Some tasks and responsibilities were completed but many remain the same, and new tasks and responsibilities may / will be added.

An extensive task undertaken by Larry Tippit of the Peoria Environmental Department, was the collecting of wildlife tissue samples, as natural resource subsistence resources, in connection with the EPA Region 6 Human Health Risk Assessment for Operable Unit 5.  OU5 consists of the entire Spring River Watershed and Neosho River watershed from the confluence of Elm Creek down to the Twin Bridges State Park.  Theses drainages include Shoal Creek, Center Creek, and Turkey Creek in Missouri; Beaver Creek, Tar Creek, Elm Creek, and Lost Creek in Oklahoma.  Mr. Tippit took “opportunistic” whitetail deer samples consisting of heart, liver, kidney, and muscle tissue.  Sets of sample tissues were donated from deer harvested in the Elm Creek watershed by other hunters.  Mr. Tippit provided one “control” set of tissue samples and one set of tissue samples from a deer harvested on the Central Mill chat piles.  Heart, liver, kidney and muscle tissues were taken from raccoon trapped on Spring River, Neosho River; Elm Creek, Five Mile Creek, Tar Creek, Beaver Creek, and Lost Creek.  Three animals were taken from different areas of each stream, for a total of twenty-one raccoons sampled. Also taken from these streams was the muscle tissue from Bullfrogs legs.  Instead of harvesting a certain number of these bullfrogs, an aggregate of sixteen ounces of hind leg muscle tissue was the goal.  An interesting conclusion was that adequate numbers of bullfrogs were harvested from Spring River, Elm Creek, Five Mile Creek, and Lost Creek, while only two small frogs were able to be taken from Tar Creek, and none from Beaver Creek.  Larry Tippit guided two EPA and USFWS biologists and took these bullfrogs with a pellet rifle. Duck tissue samples were to also be taken for analysis, but the Tribal representative who was to take them was unable to participate in the survey because of a health problem.

Larry Tippit of the Peoria Environmental Department also served as a guide and land-owner / GRDA liaison, working with the USFWS, Oklahoma Department of Wildlife Conservation, USGS, and two EPA biologist, in a Mussel Tissue / Mussel Habitat / Water Quality / Sediment Toxicity Study on both Spring and Neosho Rivers.  Twenty-four sites were investigated in Oklahoma, with a final selection of eight sites designated for intensive study. Again, this study was in line with the OU5 Human Health Risk Assessment.

It should be noted that all sampling of whitetail deer, raccoon, bullfrogs, and mussels was done under the written permission of the Oklahoma Department of Wildlife Conservation.

Other basic NRDAR responsibilities continue for the indefinite future until all remediation and restoration activities in connection with the Tri-State Mining District / Tar Creek Superfund Site are accomplished. When on-the-ground restoration projects are completed, Federal Regulation required monitoring of those completed tasks are projected to continue for 30 to 50 years.

Each Monday morning, scheduling permitting, the NRDA Peoria Representative (Larry Tippit) met with the Peoria Environmental Department Director to review the past week’s activities and accomplishments.  This included planning or outlining respecting activity for the current week. If possible, Mr. Tippit briefed the Environmental Director on all meetings, pertinent conference calls, and correspondence the day after.  Each Tuesday morning, the Peoria NRDA Representative met with Peoria Chief at a formal staff meeting for a brief outline of the coming week’s schedule or agenda, and if necessary, a discussion of the past week’s activities.  If more detailed discussion or direction was necessary, Mr. Tippit met with the Chief at the Chief’s convenience.  During these meetings, any future NRDA or NRDAR strategy was reviewed, discussed or planned.  Also, any pertinent documents, recommendations, and/or decisions were discussed and resolved.  Through the month, Mr. Tippit routinely prepared “Confidential” Business Committee reports on the same-said information for the Peoria Chief to discuss with the Tribal Business Committee during “closed session.”  These reports, after being reviewed with the Environmental Director were submitted to the Chief for review, approval, and organization into Business Committee Packets for the Business Committee meeting.  Mr. Tippit was then available to respond to any questions that might be forthcoming from the Tribal Business Committee.   In addition, Mr. Tippit corresponded regularly with Tribal NRDAR legal support, Attorneys Brian Cleary and Shannon Work of Coeur d ‘Alene, Idaho, regarding case strategy, review of legal documents, and tribal concerns, and/or comments on case assessment studies and documents, and upcoming Restoration activities.  With the inclusion of a NRD Mining Company bankruptcy claim, this correspondence had evolved into a twice a week conference calls with Misters Cleary and Work and the six other Tar Creek Trustee Council Indian Tribes.

The Peoria Environmental Department and Environmental Specialist Larry Tippit continued to be involved in the preparation of and participation in the following areas and ways (though not necessarily in this order):

  • Assisted in developing a Grand Lake Restoration Compensation Development Plan (public comments have been received and are being incorporated into the document);
  • Develop a “Proof of Claim” for the Peoria Tribe for the Gold Fields / Peabody PRP Mining Company bankruptcy proceedings;
  • Developing a Peabody / Gold Fields / Blue Tee negotiation strategy;
  • Participate in developing a Tri-State Mining District / Tar Creek Superfund Site Damage claim against Peabody / Gold Fields / Blue Tee Mining Companies;
  • Assisted in developing Peoria Tribe Natural Resource Damage Assessment and Restoration Documents (ongoing development);
  • Worked to develop a natural resource damage assessment study on small mammals in riparian and terrestrial environments; a particular resource not previously investigated by USFW, USGS, or other tribal trustees, Taking and collecting soft tissue samples for heavy metal analysis of whitetail deer, ducks and raccoon for OU5 Human Health Risk Assessment;
  • Reviewed and commented on all proposed natural resource studies, such as; the USGS Spring River Overbank Study; USGS Spring River Sediments Study; US Fish and Wildlife Service Crayfish Study; Six Treaty Tribe Overbank / Floodplain Study; Six Treaty Tribe Cultural Resource Index Study; Six Treaty Tribe Plant Cultural Resource Index, Six Treaty Tribes Spring Study; Tri-State Transition Zone Study (ongoing activities);
  • Review, comment, and development of the Tar Creek Trustee Council Restoration Plan (final draft development ongoing to coordinate with Damage Assessment Claim against Peabody / Gold Field in bankruptcy proceedings);
  • Investment of Asarco Bankruptcy Settlement Restoration funds; to be able to have available dollars “project ready”, and to secure the safest investment (Federal Treasury Bonds) to be able to extend “dollars to put on the Ground”, those restoration dollars;
  • Attended and participated in USEPA OU4 Remediation meetings and conference calls as a stakeholder, as possible;
  • Provided letters of concern and comments on EPA remediation actions upcoming Region 6 and 7 –  OU5 Spring River / sediment loading and transportation;
  • Meet with /conference calls regularly with EPA Region 6 and 7 representatives for discussion of concerns and planning for the institution of Operable Unit 5, sediment loading and transport in the Spring River and Neosho River watersheds;
  • Assist in development of EPA Region 6 OU5 Human Health Risk Assessment Study;
  • Attended and participated in all Tar Creek Trustee Council meetings;
  • Attended and participated in all Trustee Councils of Tri-State meetings and conference calls;
  • Attended and participated in all Spring River Watershed meetings;
  • Attended and participated in Grand Lake Watershed Council meetings;
  • Attended Tar Creek Conference functions;
  • Participated (Planning Committee member) in developing a third “Tribal Only, NRDAR Workshop,” sponsored by EPA/DOI, in conjunction with the NRDA Work Group, Washington D.C., for Indian Tribes nationwide.  Worked to help sponsor and hold this workshop in Tulsa, Oklahoma;
  • Attended and participated in organizing the program, assisted in putting the conference on, and was a presenter at the five day Tribal Only, NRDAR Workshop in Tulsa, Oklahoma;
  • Provided and led a Tar Creek Superfund site tour for Washington, D.C. officials, biologists and staff that had never seen any part of the Tri-State Mining District / Tar Creek Superfund Site;
  • Worked with secured Tribal Legal Representation, (apart from U.S. D.O.I. and U.S. D.O.J.), concerning ongoing case strategy, individual and tribal comments on pertinent case documents, and currently developing future NRDAR actions.  This legal support has been secured through federal funding (BIA Tribal Attorney Support, Washington, D.C. Work Group) per U.S. Federal Regulations;
  • Worked with DOI in securing two-year extension on Grand Lake Tolling Agreement to further Tar Creek Trustee Council claim development.
  • Participated in monthly Tribal / DOI, NRDAR Concerns conference call (nation-wide call);
  • Participated in EPA, Washington, D.C. sponsored Tribal Superfund Working Group conference calls, meetings, and activities;
  • Was selected to serve as an Advisory Council member for the Tribal Superfund Working Group;
  • Worked to develop and position the Peoria Tribe Aquatic Facility, Endangered Fish and Mussel Species capabilities, for restoration activities and projects associated with the Tri-State Mining District / Tar Creek Superfund sites, and for production of a fish “Replacement Equivalency” species (in accord with the provisions of CERCLA) in lieu of the lost services of injured fish species.  Also, positioning the Peoria Facility for the restocking or enhancing of endangered or threatened fish and mussel species.
  • Served as a presenter at the Annual Tar Creek Conference organized and put on by the L.E.A.D. Agency.


Larry Tippit, Peoria Environmental Department received two awards in

September 2017 at the Annual Tar Creek L.E.A.D. Conference: (1)  A

“Certificate of Appreciation” from USEPA Region 6 for “Participation in Tar

Creek Superfund Site Data Collection” for the OU5 Human Health Risk

Assessment; and (2) “The Mike Synar Environmental Excellence Award.”  “For

    his tenacious spirit protecting our environment and uncanny ability to put

    authority to task.”


          NRDA and NRDAR are ongoing activities in the Tri-State Mining District, Tar Creek Superfund Site, Spring River Watershed, Neosho River Watershed, and the Grand Lake Basin.  Also, USEPA remediation activities are ongoing in these areas for the unforeseeable future, particularly in OU4 (Operable Unit 4 Superfund site) and upcoming OU5, (which will include all of Spring River Watershed and the Neosho River watershed from the confluence of Elm Creek down to Twin Bridges State Park).  Because restoration activities can only be undertaken as specific EPA remediation activities are affected, Peoria Tribal participation in NRDAR (Natural Resource Damage Assessment and Restoration) activities will continue for the year 2018 with the ongoing activities listed above, and several new, additional activities added.

In 2017 the Tar Creek Trustee Council continued work on an OU4 Terrestrial Claim and RCDP, with this work carrying over into 2018.  This will entail the addition of new or more delineated natural resource studies, and further study of culturally specific natural resources and injury determination there-of; specifically, a Spring River / Neosho River Watersheds Mussel Study; a Tribal Aquatic Study; and the OU5 Human Health Risk Assessment Study.

Because of the EPA Optimization Review Committee report to EPA Region 6, some adjustment of focus in Remediation efforts toward ground and surface waters were instituted in 2015 with more adjustments taking place on through 2018.  These actions include damming, diking, and diverting leachate and run-off from chat piles to surface waters and preventing further contamination from entering streams and wetlands in the superfund area.  This is to precede the chat pile removal mandated by the OU4 Record of Decision (ROD).  With surface waters protected, then the slower process of removing the chat piles can continue. This has impacted certain NRDA activities of the Peoria Environmental Specialist.  Some associated legal activities did undergo changes, as recommended by the legal counsel employed by the Peoria Tribe. The Peoria NRDAR representative continues to work to see that these adjustments are followed and implemented.

Also, included in adjustments or changes to the above list are; negotiations, mediation or litigation activities with PRPs (Potentially Responsible Parties).  PRP’s have again extended the Grand Lake Tolling Agreement for two years, and though having met in 2014 with the Tar Creek Trustee Council for a preliminary discussion, have not met with the TCTC in 2015, 2016, or 2017.  Now, because of one Mining Company bankruptcy NRD claim settlement, another RP has initiated a settlement with their company  It is anticipated that the remaining PRPs will follow suit in negotiating settlements during 2018.

The TCTC Restoration Plan has been completed and was published in September 2017.  The TCTC is scheduling a “Restoration Next Step” meeting in February 2018 to discuss Restoration Project proposals. Specific restoration goals will be discussed, then we will begin accepting proposals, and consideration of proposals from within the TCTC Trustees, and the developing of a list of prospective restoration partners.  It has been decided that all proposals will be judged their own individual merits and not by the proposed Evaluation Matrix.   Approved “On the Ground” projects can begin with the Asarco restoration dollars from the previously negotiated Asarco settlement.

Many of the above-mentioned activities, actions, and documents fall under CERCLA, OPA, and other Federal Confidentiality Agreements, and cannot be elaborated on..

If there are any questions or any clarification is needed about anything in this report, please contact the Peoria NRDA Representative at your earliest possible convenience, which is Larry Tippit.

        Inland Oil Spill Response Training

The week of December 4th, Monday,  through Friday, December 8th  Larry Tippit of the Peoria Environmental Department attended an Inland Oil Spill Response Training in Tulsa, at the U.S, Fish and Wildlife Services offices.  This class was sponsored and put on by the Department of the Interior.  The purpose of the class was to train responders for inland oil spills.  Prior to the last few years, most oil spills were associated with oil tanker ships and of a coastal nature.  Presently there are more inland oil spills than coastal, with Oklahoma being second in number behind Texas.  This is because of the huge volume of oil being transported in pipelines, tanker trucks, and by rail in tanker cars.

Participation in the class was by invitation by the DOI.  The majority of attendees were DOI employees, USFWS, and BIA.  Tribal attendees consisted of Larry Tippit of the Peoria Tribe of Indians and four representatives of the Osage Tribe.  This was one of five trainings that are being conducted throughout the U.S.  Training sessions for the week were:   starting Monday at 1:00 p.m. until 5:00 p.m.; Tuesday, 8:00 a.m. through 5:00 p.m.; Wednesday, 8:00 a.m. through 5:00 p.m.; Thursday, 8:00 a.m. through 5:00 p.m.; and Friday, 8:00 a.m. through 12:00 noon.  There was a one-hour break Tuesday through Thursday for lunch “on your own.”

The course training, topics covered, and activities were as follows, with the exception of two outdoor exercises.  Some adjustments were made for the outside activities because of the weather.


We received an introduction to the textbooks we would be using in the class. (1) “Shoreline Assessment Manual “(provided because damage assessment is carried on in the same methods whether on coastal areas or on inland waterways.); (2) “Best Practices for Migratory Bird Care During Oil Spill Response”; (3) “Inland Oil Spill Response for the Department of the Interior”; (4) “Superfund Task Force Recommendations”.

Introductions were made all around of instructors and students.  The objectives and logistics of the course were discussed, including the watershed framework of the course.  With an inland oil spill the main or first objective is to prevent the spill from contaminating inland waters, whether impounded, flowing streams, or ground water.  Then, the roles and responsibilities of the Department of the Interior in their response to an inland spill were discussed.

The last topic covered Monday was Wildlife Operations; Oiled Wildlife Response, dealing with both wildlife rescue and rehabilitation.  It was stated that usually one-third or less of avian species survive after being contaminated with spilled oil.  After decontamination of bird species, 1 – 2 days, it usually requires ten days to two weeks of rehabilitation before release.   Contaminated mammals are harder to capture than oiled birds but much easier to clean and have a much greater survival rate.  Even turtles, frogs, salamanders, etc may be rescued and treated with some success.


The first training module focused on the EPA role as the “Federal On-Scene Coordinator” and their responsibilities in an inland oil spill response process.  EPA provides an On-Scene Coordinator responsible for the initial emergency actions and notifying all, Natural Resource Trustees impacted, including State, local, and Tribal Trustees.  They also monitor all actions taken to control and remediate the spill; and evaluate the spill reduction effectiveness.  All these activities take place under a “Unified Command, Incident Command System designed to address oil spills.

The second module addresses specific oil properties; the behavior, fate, and effects of spilled oil.  The class in teams, performed a lab exercise of sediment penetration for oils with different viscosities and sediments of different grain sizes.

The third module was a Safety Training for Small Boat Operations.  The instructor had brought safety equipment from the minimum floatation devises (Personal Flotation Devises) to Type V PFD Deck suits and Emergency kits.  It was stressed that the DOI regulations and Bureau Policies require boat operators to file a Float Plan prior to departure on any water oil assessment, recovery, or on the water activity, and must have an effective communications system.

The fourth module was on 2A Section 106 Consultations During Response — Cultural, Historic, and Archaeological Resources. This covered topics such as Wildlife Field Operations; from wildlife assessment through search and capture, cleaning and recovery.  It also touched on wildlife Deterrence Techniques, to prevent more or further wildlife contamination before the remediation of the original oil spill.   Ways and means to preserve Tribal, Cultural, Historic, and Archaeological resources were also discussed.

The Fifth module focused on the Chemical Analysis; Fingerprinting and Toxicity of spills.  Six types of oil classifications were discussed: (1) gasoline; (2) kerosene; (3) diesel; (4) heavy fuel oil; (5) lube oil; (6) asphalt.  Toxicity of each can range from Acute mortality; Chronic effects; to Delayed effects.  Toxicity was discussed concerning Human health, toxicity to fish avian species and mammals.

The sixth training module was an exercise in Personal Protective Equipment.  Each student was required to “suit up” in sealed Tybex Suits, double rubber gloves (possibly leather gloves over the double rubber gloves) and Tybex Booties over substantial work boots.

The last activity of the day was a team exercise (class divided into 4 teams) analyzing a supposed large spill in our area, identifying key issues: Type and kind of spill; Response; What resources you most want to protect in the response; and how and where you might fit into the Spill Response Incident Command Structure.


The first study module this day was on Aquatic Recourses at Risk to Oil Spills.  It covered Inland Aquatic Systems: (1) Flowing Freshwater Ecosystems; Streams, medium to large rivers, sediments/substrates, size and arrangement; transition zones; currents; and sand and gravel bars.  (2)  Still Freshwater Ecosystems: Lakes, Ponds, and other Impoundments.  The designation Ecosystems, in both flowing and still waters, include all biota impacted, plant and animal and their habitat.

The second module covered was On – Water Response Strategies: Mechanical Protection/Recovery and in Situ Burning.   This included dikes, damming, booming, for deflecting the flow of the contaminant, but also to provide or aid in recovery of the spill.  In areas where recovery is not possible, or prohibitive for some reason, burning in place may be the recommended course of action, depending on the size, scope, and the product spilled.

The next two modules were covered together: (SCAT Part 1 and SCAT Part 2) Shoreline Cleanup Assessment Technique.  This was directly from the NOAA Shoreline Assessment Manual.  It included from Start — agreeing to deploy to a spill; what equipment to pack; Day One, Site Arrival; early Response, organization into teams, gathering information; following days and activities, early response, Assessments and Reconnaissance, identifying stakeholders and concerns; developing Health and Safety Plans, mobilizing equipment; establishing a daily routine and a response organization.  Further activities include SCAT Team assessments, Shoreline Treatment and Endpoint Recommendations.  Finally, remediation activities, more inspections, monitoring collateral damages, and always “Keep Up and Current” with all Documentation and paperwork.

Module 15 was next covered on “Inland Response Shoreline/Habitat Cleanup Methods” and an outdoors Field Exercise.  We car-pooled to a site; the J.D. Metcalfe Recreation Area – Mingo Creek and Retention Pond and flood plain. The group was broken up into four teams and provided a oil spill scenario.  It featured the spill, rising waters, Tribal cultural areas and resources, migratory waterfowl, wildlife and an endangered species.  Each team was responsible for assessing the spill, containing the spill, reducing or remediating the spill, and not only recovering and cleaning injured and contaminated biota, geese, turtles, mammals, but also preventing the contamination of other biota (birds, mammals, etc.) until the spill was completely reduced.


The first subject covered and the 16th module in our workbook was Inland Oil Cleanup Endpoints.  The objectives of this study were minimizing exposure hazards for human health; speedy recovery of the impacted area; and to reduce the threat of additional or prolonged natural resource impacts.  Two of the concerns addressed were to maintain clean pure water (drinking water standards) and to keep the spill away from human habitation and high use areas.  Although endpoints always involve tradeoffs, goals are oil removal and recovery without causing more harm to the natural environment; leaving no visible oil; no longer releasing an oil sheen; oil no longer rubs off on contact; and removal to where recovery can occur without causing more harm than leaving the oil in place.

Modules 17 and 18 featured “Wetlands: Oil Behavior and Cleanup” and “In-situ Burning: Inland and Upland Habitat. “Some of the topics discussed were being able to determine the dominant types of wetlands in inland regions; identifying factors that affects how oil impacts wetlands; and being able to recommend response options to speed recovery of oiled wetlands.  One must take into consideration the environmental tradeoffs, the effects of the oil spill vs. the effects of cleanup activities: Natural recovery of the wetland vs. trampling, mixing of soils, removing surface soils, and smothering effects of replacing uncontaminated soils and artificial packing of the wetland.

Videos, photos, and graphs were shown concerning burning in-situ.  Successful burning can depend the type of oil spilled, the habitat, the size, season, and weather conditions.  One example of an in-situ burn showed a spill of some 13 acres which ended with a total of 135 acres burned.  Another example showed good removal of surface oil but ineffective in removing subsurface oil, that which penetrated burrows, root cavities, etc.   Good judgment is a must for effective oil removal by burning.

The 19th module featured Natural Resource Damage Assessment and Restoration.  NRDAR is the natural conclusion after any oil spill.  Natural resources and the services they provide must always be considered.  Most attendees in this class were not familiar with NRDAR processes so the course of events was to clarify what NRDAR “IS”, and what it “IS NOT.”  Laws and regulations that legislate NRDA were briefly covered:  Clean Water Act; CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act); Oil Pollution Act; National Marine Sanctuaries Act; and applicable State and Tribal Laws.  The purpose of NRDAR is to arrive at monetary settlements with the Responsible Parties to restore, rehabilitate, replace or acquire the equivalent of injured natural resources and their services.  Other issues with NRDAR covered had to do with NRDAR Strategy, the Scope of Liability, Pre-assessment Phase, Cooperative Assessments, Restoration Planning Phase, and Restoration.

The next class session consisted of a class exercise: a scenario and Unit/Branch Assignments for an Incident Command System.  The class was again divided into four groups in different rooms, with each group given a different scenario.  But each group would have to correspond and rely on the other groups for pertinent information to develop a solution to their particular scenario.  For example: while one group identified natural resources at risk, another group had wildlife specialist whose expertise was in capture and cleaning of injured species; while a third group was made up of toxicology experts.  The fourth group was made up of spill containment and recovery specialist.  Each group then had to coordinate their recovery efforts to make one united team to contain, clean up and remediate the supposed oil spill.

At the end of this exercise all four groups met together again to discuss their different roles and perspectives, and to discuss how they could develop and implement a SCAT.


The first thing discussed Friday morning was Emerging Risks: Shale oils.  Shale oil (Bakken Crude) is the lightest oil, always a liquid and spreads quickly, vaporizes readily, and is highly volatile.  Recovery of a spill depends on the size of the spill and is critical with a recovery time of only 4 – 8 hours.  The Transportation Safety Board has measured the flash point for Bakken and found it to be comparable to unleaded gasoline.  With a Bakken spill, air monitoring is a must for safety.  In spills impacting waterways, it quickly adheres to suspended solids in the water column and forms unstable emulsions. Bakken is transported by pipeline tanker Truck and railroad tankers.

Another form of crude oil discussed was Diluted Bitumen.  It is an engineered Crude Oil produced from Tar Sands and liquefied by dissolving it with other lighter crudes or naphtha-based oils at 30 – 50%.  This allows it to be transported by pipeline.  In a Diluted Bitumen spill the diluents will evaporate quickly (an inhalation hazard) and the remaining tars will become highly adhesive.  In water bodies it adheres to suspended solids in the water column and sinks to the bottom.  The sunken dilbit can be a source of chronic sheening and may require extensive dredging for removal.

The last module consisted of Local Case Studies:  Osage County and the Deep Fork National Wildlife Reserve.   Both cases are chronic/ongoing /continuing because of the number of old oil wells still producing (sometimes as little as a barrel of oil per day) with unmaintained piping, storage tanks, and other support systems.   A leak in one of these systems may go days or weeks before the leak is discovered.

The last class discussion revolved around local risks.  In Ottawa County/Miami, Oklahoma, a spill of crude oils is a constant and ongoing threat.  Crude oil passes through Miami and Ottawa County on three major highways by tanker truck, in numerous railroad tanker cars, and several pipelines.

This session was followed by a brief wrap up and a post-course evaluation.  The class ended at 12:00 noon Friday, December 8.  Each class participant received a HAZWOPER Recertification and a Department of the Interior “Certificate of Completion” of the Inland Oil Spill Response Training with recognition of 36 hours of Instructional Training.


On May 10, 2017 all Solid Waste Rural Collection related equipment was officially donated to the Ottawa County Commissioners for their operation of the Rural Solid Waste Collection Sites.  This consisted of one 2000 Mack Roll-Off truck and four thirty yard roll-off bins, and six 20-yard roll-off bins. The Collection site located on East 90 Road is being operated by Ottawa County Commissioners through a yearly lease from  the Peoria Tribe.

The two rural collection sites had remained closed from September 2016 through the third week of January 2017.  In mid-January 2017 the Peoria Accounting Department received the third and final draw of funds from the Indian Health Service and could reconcile all past costs and be back within budget and close out the program.   At that time, County Commissioner John Clark came to the Environmental Department office and discussed the reopening of both sites.  He said that it was found that the collection sites had reduced the amount of illegal dumping in two County Districts.  He and another Commissioner had applied to the Oklahoma Department of Environmental Quality for funding to reopen the sites.  That funding was in line with the funding Ottawa County had initially received to build and help maintain the sites when partnering with the Peoria Environmental Department.  The County Commissioners then reopened the two sites and assumed responsible for all operation and maintenance.

The conclusion of this Peoria Solid Waste Project, “Rural Solid Waste Collection to Eliminate or Reduce Open Illegal Dumps Within the Peoria Jurisdictional Boundaries,” is that while it began with great difficulty and seemingly inefficient, it has proved to be very effective.  It has provided an alternative to the illegal open dumping issue within Peoria jurisdiction.  The proposal and objective at the beginning of this project was for the Peoria Environmental Department to turn the collection sites and equipment over to the Ottawa County Commissioners as a County function and responsibility.  This has proved to be successful and has done much to reduce the illegal, unsightly, and unhealthy trashing of the Peoria Tribe jurisdiction.

While Ottawa County Commissioners were and are working to make the Rural Collection sites operate effectively, the sites continue to be abused.  People continue to dump illegal wastes in the bins, leave waste materials on the ground not in the bins, and have on occasion blocked the site gates with solid waste materials. This resulted in the shutdown of the collection site in Commissioner John Clark’s District for an extended period.  Commissioner Clark has reopened the site in January 2018, but only with the caveat that users of this site comply with all posted regulations.

This report has been prepared and provided by Larry Tippit, Peoria Tribal Environmental  Department.