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2.1.1 Narrative
This removal action will be conducted in accordance with Section 104(a)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and 40 C.F.R. § 300.415 (Removal action) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to abate or eliminate the immediate threats posed to public health and/or the environment. This action is anticipated to require from four to six months to implement.
2.1.2 Response Actions to Date
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.
On April 19, 2013, CRA Field Services loaded the first truck of PCB impacted soil destined for delivery to the Heritage Environmental Services, Roachdale, Indiana, Landfill. This landfill is permitted to accept PCB Mega-Rule managed waste streams.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
U.S DOJ, U.S. EPA and Phillips 66 negotiated a Consent Decree (CD)to govern the clean-up activities.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| PCB Impacted Soil and Debris |
Soil and debris |
8384.99 tons |
NA |
Land Disposal |
Clean Harbors, Lone Mountian, Oklahoma, LLC, Landfill |
| PCB Impacted Soil and Debris (PCB Mega Rule) |
Soil and debris |
119.69 |
NA |
Land Disposal |
Heritage Environmental Services, Roachdale, Indiana, Landfill |
| R5 Priorities Summary |
| This is an Integrated River Assessment. |
Miles of river systems cleaned and/or restored |
NA |
| Cubic yards of contaminated sediments removed and/or capped |
19,000 tons |
| Gallons of oil/water recovered |
NA |
| Acres of soil/sediment cleaned up in floodplains and riverbanks |
4.75 |
| Stand Alone Assessment |
Acres Protected |
22 |
| Number of contaminated residential yards cleaned up |
0 |
| Human Health Exposures Avoided |
3.14 |
| Number of workers on site |
30 |
| Contaminant(s) of Concern |
| Contaminant(s) of Concern |
Polychlorinated biphenyl (PCBs) |
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U.S. EPA Emergency Response and Removals Branch will perform oversight of the investigation and delineation of PCB impacts and oversight of the removal actions to take place in the Spring of 2013.
2.2.1 Anticipated 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.
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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
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