On January 22, 2013, U.S. EPA mobilized START contractors to perform oversight of PCB sampling for additional delineation of PCB impacted soils.  These sample results will support the removal of impacted soils related to the former tanker truck cleaning operations at the former Rogers Cartage Site.  Approximately 122 samples were taken ranging in depth from 2 inches to 14 feet below ground surface.  All samples were collected by Conestoga-Rovers & Associates (CRA), on behalf of Phillips 66 Pipeline LLC (Phillips 66).

On February 15, 2013, CRA completed the PCB sampling activities. 

On February 18, 2013, CRA submitted the Removal Action Work Plan (RAWP), Field Sampling Plan (FSP), Quality Assurance Project Plan (QAPP), Health and Safety Plan (HASP), and Contingency and Emergency Response Plan (CERP) to the USEPA.

On February 27, 2013CRA submitted the supplemental Excavation Plan to the USEPA.  The Excavation Plan was based upon the results of the soil sampling performed at the Site in accordance with the Sampling Delineation Plan.

On March 4, 2013, the Agency approved the RAWP, FSP, QAPP, CERP, and the Excavation Plan.

During the period of March 13 through March 31, 2013, CRA mobilized crews, equipment, and materials to the Site.  CRA also prepared and improved Site roads leading to the excavation area.  Temporary roads and mats were placed in the excavation area.  These improvements extended the site preparation time, pushing back the excavation start date. 

On April 4, 2013, CRA Field Services initiated the PCB soil excavation and truck delivery to the leased Front Street railcar siding location for trans-loading of gondolas operated by Clean Harbors.  Clean Harbors can load up to six railcars per day.  Railcar gondolas will then be shipped to the Clean Harbors PCB Permitted Landfill in Lone Mountain, Oklahoma. 

U.S DOJ, U.S. EPA and Phillips 66 negotiated a Consent Decree (CD)to govern the clean-up activities. 

1.   Removal of PCB Impacted Soils – Conduct oversight for the removal of PCB impacted soils in a manner such to control, contain, and remove PCB contaminated soils at the Site, which should include, at a minimum:

a.   Installing/maintaining excavation-related access roads (Dura-Mat) and other haul roads located inside the Phillips 66 Terminal Property;

b.   Excavating Site soils at a depth range of between 2 to approximately 14 feet below ground surface (BGS) as specified in the Excavation Work Plan Supplement;

c.   Removing approximately 16,575 tons or more of Site soils;

d.   Loading excavated material into over-the-road (OTR) trucks for transport to an off-site rail loading facility, where the excavated materials will be direct transferred into rail cars; and

e.   Loading excavated material into over-the-road (OTR) trucks for transport to an off-site PCB permitted landfill.

f.    Transporting the loaded rail cars and/or trucks to an approved TSCA/PCB Mega-Rule facility in accordance with EPA's Off-Site Rule (40 CFR § 300.440).

g.   Control access to the contaminated areas to prevent further migration of contamination, by fencing or other applicable means;
Restore excavated areas to pre-existing conditions to the extent practicable.


2.2.1.1 Planned Response Activities

Remove all PCB impacted soils for appropriate off-site disposal requirements.

2.2.1.2 Next Steps

Conduct oversight to the removal, transportation and disposal of PCB impacted soils.

2.2.2 Issues

None at this time.  However, inclement weather may create weather delays to the project schedule. 

Also, railcar transportation arrangements have a limited window of time available due to other obligations.  The rapidly rising Mississippi River Stage could create a sharp rise in the localized groundwater within the site excavation. 

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

US EPA – 1

START – 1

Phillips 66 – 2

RP Contractors 

  Operators – 3

  Laborers – 4

  Field Team Leader – 1

ATSDR – Agency for Toxic Substances and Disease Registry

CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act

CERP – Contingency and Emergency Response Plan

CD – Consent Decree

CRA – Conestoga-Rovers & Associates

FPN – Federal Project Number

FSP – Field Sampling Plan

HASP – Health and Safety Plan

IEPA – Illinois Environmental Protection Agency

NA – Not Applicable/Available

NCP – National Oil and Hazardous Substances Pollution Contingency Plan

OSC – On-Scene Coordinator

PCBs – Polychlorinated biphenyl(s)

Phillips 66 – Philips 66 Pipeline LLC, aka: ConocoPhillips

POLREP – Pollution Report

QAPP – Quality Assurance Project Plan

PRP – Potentially Responsible Party

QAPP – Quality Assurance Project Plan

RP – Responsible Party

RAWP – Removal Action Work Plan

START – Superfund Technical Assessment and Response Team