HomeMy WebLinkAbout1998-09-16 PACKET 02.B.FtEQUEST OF CITY COUtJGiL ACTIdN COUNCIL AGENDA
MEETING ITEtvt
DATE 9/16/98 a • +
PREPARED BY: Administration R_yan Schroeder
ORIGINATWG DEPARTMENT STAFF AUTHOR
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COUNCIL ACTION REQUEST
Presentation - PCA / Ashland Site Update.
SUPPORTING DOCUMENTS
� MEMO(LETTER:
❑ RESOLUTION:
❑ ORDINANCE:
❑ ENGINEERING RECOMMENDATION:
❑ LEGAL RECOMMENDATION:
� OTHER:
ADMINiSTRATORS COMMENTS
� q �e� C' .
"� City Administrator Date
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COUNCIL ACTION TAKEN: ❑ APPROVED ❑ DENIED ❑ OTHER
Memo To: Mayor and City Council
From: Ryan R. Schroeder
Subj.: PCA/Ashland Site Update
Date: September 1, 1998
As Council is aware Marathon Ashland Petroleum is the owner of a parcel of
property known as the Oakey farm or the Grey Cloud Dunes site. It is located
south of 100 Street and south and east of Hadley and 103� The Minnesota
DNR received state bonding funds from the 1998 �egislature to provide for
acquisition of a portion of the property. Their intent is preservation and
growth of the Grey Cloud Dunes Prairie.
Through the past coupie of years Council had been left with the impression
that this property was not of concern relative to possibie contaminants that
might be on site. According to PCA documentation on the site a notice of
violation of PCA rules had been issued on the site on February 2, 1981.
Elevated metal concentrations were found on the site in October 1982. Buried
hazardous wastes were identified in December 1984. Further analysis and
negotiations on remedies occurred between then and 1995 when a new
Remedial Action Plan was submitted by the property owner to the PCA.
Today, there are considered to be five disposal areas on the site. Area five, the
most significant area, was reportedly cleaned up by December 1997. This
action apparently opened the door to DNR acquisition efforts of the "Dunes"
area. Apparently, the owner and the PCA determined that additional
remediation activities should/could occur in addition to reclamation of area
five this past springlsummer.
The property owner applied for permits to extend cleanup activities on June 9,
1998. At that time remediation was underway on area one. Since that time
areas two and three have also been remediated. Apparently area four,
consisting of farm debris is remaining and is reportedly expected to be
cieaned up by the DNR over time after they take ownership of the property.
The PCA representative on the site, Mr. Frank Waliner, will be at the Council
meeting of September 16 to update you on past activities. While debris and
contaminants beyond those originally contemplated were found in the various
areas Mr. Wallner is not expected to have the final report from the owner in
hand by that date. Any information he does have wili be attached to the
materials within your packet or brought to the meeting.
Enclosed is the bulk of the file on remediation of this site.
SE°-08-1998 12�2'7 MN. PCR GWS� P.02/04
Ashlend/Cottage Grove Site Cleanup Surnmiary
The Ashland/Cottage Crrove site is an area of land located near Had2ey and 100 on which
Ashland's predecessor (Northwest Re&ning) dumped wastes in four azeas. The waste consisted
mainly of off-spec asphait material. tlshland (now named Marathon Ashland Petroteum) began
cleaning up the site in October of 1997 by removing attd thermally treatin� wastes from Area 5,
A pubiic meetin� was held at the Cottage Grove library on May 8, 1997 prior to the cleanup, In
add'ation, Marathon Ashland Petroleum (:1fAP) presented the plan for clea,ning up the Area to the
Commutnty Advisory Panel in September of 1997. An update to the public Was also issued via a
press release to the lacal news paper on September 18, 1997. Staff were also interviewed by the
local public access cable statipn (Scott Rose) for an update on the Cotta�e Grove site Cleanup.
After Area 5 was completed in becember, 1997, we inforrned MAP that additional excavation
was needed, and estunated that oniy about 1,000 additional cubic yards had to be removed. We
believed that this needed to 6e removed inord�r to limit the Department of Natural Rasourees'
(DNR) and MAP's future liability. This is a relativety small amount. However, to Marathon
Ashland Petroleum's credit, they made a decision to remove all the wastes fram areas l, 2 and 3.
The waste was hauled to a landffil The following is a summary of the cleanup activity at each
2rC8.
AMC$ i
Wastes encountered during tha 1987 Remedial Tnvestigation (R�) included asphatf waste, heavy
crude oil, empty drums, sample cans, and mi5callaneous solid waste. Some sur5cial asphalt
deposits were present in this area.
Actian Taken: Beginning on June ], 1998 MAP excavated alt wastes in this area. An MPCA
inspection confirmed thaY I�dAP dug down to clean sand. A total of 7,573.5 tons of waste was
removed.
Area 2
Area 2 consists of three separate sub-areas 2A, 2B, and 2C. Wastes encountered in Area 2A
during the KI included metal drums, mostIy empty but some containing tar, Wastes encountered
in Area 2B during the RI included drummed asphalt and sample cans, and areas of hard asphatt.
Test trenching ind'acated that depths to the botiom of the waste material was from six to ten feet,
A boring near the center of Area 2B showed soil contamination visibie to a depth af 15 feet.
Wastes in Area 2C were simiIar to those in sreas 2A and 2B,
Action Taken: MAP removed all wastes from areas 2A, ZB, and 2C. All asphatt waste,
including empty and partially fi12ed cans and drums were completely removed.
A total o£ 7,266.62 tons of waste was removed.
On July 1, 1998 MFCA staffmet with the Cottage Crrove City Adminisuator to give an update on
cleanup activity.
Area 3
Wastes found in Area 3 included off- spec asphalt, intact drums and miscellaneous solid waste.
Analyticat results oFsoil samples collected from test trenches indicated no evidence of
contaminant leaching to underlying soils. Drums partially filled with an oIly waste were also
found,
Action Taken: Wastes in Area 3 were completely removed. About 5 intact drums were found to
contain a hydraulic fluid (partially filled). Thus Par, 3 of the five drums contained hazarQous
waste, 7hese drums were only 20% to 30% futi, and were removed so that the contents wouid
not spill. Drums were placed in over-pack drums, and disposed o£ A totat of 4S0 tons of
contaminated soil was removed. 5ome of this contaminated soil failed hazardous Waste testing
and will be handled appropriatel,y. Area 3 contained the smallest volume of waste. The
excavation of Area 3 was completed on August 28, 1998 which is the completion date for the site
cleanup. Currendy there aze 5 roll offboxes on-aite which contain contaminated soils MAP will
dispose of these soils as soon as test results are in. The ro11-offboxes are covered.
Area 4
Wastes encountered in test trenches in Area 4 included solid debris and etnpty and crushed drums,
It is anticipated that once the D'_�R takes control of the property they will remove atl solid debris
such as tires, bed springs etc. No contaminauon has been detected in Area 4.
Area 5
Area 5 consisted of two asphalt waste disposal lagoons and was the largest waste area on the Sr:e.
Action Takea: Area 5 was remediated in late 1997 under the direCtion of MPCA Site Response
Section. The most highly concentrated wastes were excavated down to a depth of 10 feet, and
thermally treated on-site, Treated soll was placed back over ihe excavation. A 2ota1 of
10,961.39 tons of soil was thermally treated. Although some wastes remain 10 £eet below the
clean soil level, it will not poSe a human health risk. This project began on October 29, 1997 and
was completed on December 30, 1947.
Groundwater
Monitorir� in 1986 indicated very low levels of VOCs and matals but no PAHs in groundwater at
the Site. Over 10 years of mpnitoring has shown that there are no significant groundwater
impacts from the Site. Soil borings conducted in Areas 1, 2 and 5 in 1995 (about 10 years after
the first investigation was completed) show no 5ignificant leaching has occurred since 1985.
Since'_vlAp has completely rempved wastes from Areas 1, 2, and 3, and the most highly
concentrated wastes &om Area 5, future groundwater (mpacts are not expected.
Crro�mdwater flow direcUon is towaz•d Yhe river (see map} . Even if the groundwater was
contaminated there are np receptors between the site and the river.
SEP-88-1998 12�27 MN. PCA G�S�`
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Ciiy of
�Cottage Grove
in��
7516 801h Street Soufh / Coeoge Grove, Minnesota 55016
June 24, 1998
Mr. Frank Wallner, Project Manager
Ground Water and Solid Waster Division, MPCA
520 Lafayette Road North
St. Paul, MN 55155-4194
Dear Mr. Wallner:
612 •
This letter is in regard to the grading permit application for clean-up work associated
with the Marathon Ashland Petroleum site. The application was made by Edward Bacig
of Bay West. 1 have received a copy of the letter you sent to Representative Marko and
also the information from you regarding test trenching in areas 2B, 2C, and area 1. As
you are aware the City is very interested in the status of this property, due to the future
use and the status of the site contamination. it was disappointing to not be included in
the pianning for the 1998 site clean-up in light of the City's known concerns.
Review of the submitted materials does not depict any intent for revegetation of
disturbed areas. John Burbank had indicated that the contractor stated the DNR does
not want typicai reseeding to occur because they do not want to introduce non-native
vegetation. Due to site topography, the close proximity to the ridge, and the ecology of
the area, it wouid seem prudent to revegetate to maintain existing topography. Without
a specific plan as to how slope stabilization wiii be addressed, it is not possibie to issue
the grading permit at this time.
One issue which needs clarification is whether any additional site ciean-up will be
necessary. Previous discussions had led the City to believe no additional ciean-up was
necessary. However, your memo of Aprii 18, 1998, indicates that there was always an
intent to remove surface deposits of asphalt, which then prompted additional site
assessment. This expected ciean-up was never conveyed to the City. Frankly, the City
is concerned that aii information regarding lhe site and its contamination has not been
made available to the City. Please be aware that the City wiil continue to monitor this
issue and may request mitigative measures prioF to the sale of the property.
You should also be aware that the City is currently evaluating pavement reconstruction
of roadways within this general area. Given the amount of clean-up activity and the
i�umber of trucks hauling from the site, approximately 15 per day, the City is looking
toward the DNR, MPCA, and/or Marathon Ashland Petroleum to contribute to the road
EQUAL OPPORTUNITV EMPLOYER
Mr. Frank Wailner
June 24, 1998
Page 2
reconstruct on 110"' Street, ideal Avenue, 100th Street, and Jamaica Avenue. As our
analysis proceeds, we wili keep you informed as to the expected cost share.
If you have any questions, feel free to contact me at 458-2824.
Sincer ly,
�Z-�f�✓/
Kim Lindquist, AICP
Community Development Director
Cc: Cottage Grove City Council
Ryan Schroeder, City Administrator
State Representative Sharon Marko
State Senator Len Price
Edward Bacig, Bay West
Jim Nelson, Marathon Ashland Petroleum
Bob Everett, Marathon Ashland Petroleum
Ron Nargang, ONR
Bob Djupstrom, DNR
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June 16, 1998
Minnesota Pollution Controi Agency
The Honorable Shazon Marko
Minnesota State Representative
439 State Office Building .
100 Constihztion Avenue � •
Saint Paul, Minnesota 55155 A
Dear Representative Narxo:
The purpose of this letter is to follow-up on your concems expressed to me yesterday
regarding Marathon Ashiand Petroleum's (MAP) most recent cleanup action at the
Cottage Grove site.
First, I want to apologi2e for not notifying you of this action, which is an extension of the
main cleanup work that MAP completed in December 1997. My understanding of your
concerns are that: l. The Depar[ment of Natural Resources (DNR) did not fully inform
legislators of the need for additional cleanup of waste left on site during budget hearings
at which they requested funds to acquire the property; 2. The State would be taking on
liability if it purchased the site; and 3. Truck traffic as a result of the cleanup.
With reQard to point #1, the MPCA did not make a determination that additional cleanup
was needed until Apri121, 1998. Prior to this date additional cleanup was not
anticipated. Also, MAP did not begin the additional work until June I, weli after the
legislative session. Please note that a summary of the Cottage Grove site, inciuding a
description of the waste that would remain was prepared at your request and was fa;ced on
March 4, 1998.
With regard to your concern about the State purchasing contaminated property it is
importanT to note that the additionai cleanup action was taken to further limit liability
since the State (DNR) was goin� to purchase the land. Prior to purchasing the property
the DNR conectly applied to our Voluntary Investigation and Compliance (VIC} unit for
what we call a No Association Determination letter. Essentially such a letter gives
assurances that purchasers of contaminated land wiil not be held liable in the future.
Marathon Ashland will always retain liability if an unforeseen contamination issue
shouid arise.
With regard to your concems about truck traffic, I called Ashland to make sure they were
taking all precautions possible. Marathon Ashland personnel have been eYtremely
proactive. First, even though the waste is non-hazardous (it is essentially an off-spec
asphalt) the trucks are covered. Secondly, MAP personnel specifically planned the truck
520 Lafayette Rd. N.; St. Paul, MN 55155-4194; (612) 296-6300 (Voice); (612) 282-5332 (TTY)
Regional Offices: Duluth • Brainerd • Detroit l.akes • Marshall • Rochester
Equai Opportunity Empioyer • Printetl on recycled paper containing at least 20% tibers tmm paFer recycletl by consumers.
The Honorable Sharon Marko
Page 2 •
June 16, 5998
route such that is would pass by the least number of homes; Third, Ashland personnei
have followed trucks (unbeknownst to the drivers) to make sure they make full stops and
aze obeying the speed limits. In addition, when I mentioned your concerns about truck
traffic to MAP personnel, they double checked the route within an hour of my call.
Enclosed is a map which shows the route used by the trucks. We aze confident that iVIAP
is doing all they can to eliminate any impacts to residents.
F
}
I hope that this letter helps answer youi concems. If you have any additional questions,
please feel free to call me at 296 7443.
Sincerely,
,,.,�,� ���/����
Frank X. Wallner
Project Manager
Response Unit II
Site Response Section
Ground Water and Solid Waste Division
FXW:Ima
cc: Bob Everett, MAP
Senator Leonazd Price
, �Ryan Schroeder, City of Cottage Grove
Ron Nazgan�, DNR
�EPARTMENr: POLLUTION CON'� _�L AGENCY
DATE: April 28, 1998
To: pshland/Cottage Grove File (Company now called
Marathon Ashland Petroleum)
FROM: Frank X. WallneF��t�.
Project Manager
Response Unit II
Site Response Section
Ground Water and Soiid Waste Division
oHONE: 296-7443
SuB.IECT: Test Trenchin� At Areas 2B 2C and Area 1.
BackgrounJ:
r.e� e�
sF�oaoo6�o5 N�as)
STATE OF MINNESOTA
Office Memorandum
Marathon/Ashland Petroteum (MAP) completed the mmoval and thermal desorption of Area 5 in
Decembet 1997. This action resulted in the removal and treatment of 10,961 cubic yards ofthe
most highty contaminated waste. Previous investigations show that wastes are also present in
other areas - primarily areas 1, and 2. The MPCA stafFs risk based decision concluded that
these areas do not have to be remediated. Tl�is decision is based on the following;
1. The tand use ofthe area wilt likely be for a Departrnent ofNatural Resources (DNR}
Scientific and
Natural Area, not residential.
2. Over 10 years of ground water monitoring shows that groundwater is not being impucted
downgradient.
3. Even if [here were groundwater impacts there are no private wells downgradient from
the deposiu of waste.
4. The waste present are comprised mainly of off-spec asphatt wastes. Latest see of data shows
that the waste is non-hazardous.
If in the future the land use changes, the MPCA would need to reevaluate the need for additional
remediation.
CurrenY Status:
Scattered throughout areas 1 and 2 are surface deposits of old asphalt. After the sale of the land
to the Department oFNatural Resources (DNR) the ptan was for the DNR to remove these
surface deppsits of asphalt. However, Voluntary Investigation and Compliance staff reviewed
the Cottage Grove site Remedial lnvestigation prior to issuing e no association letter to the
DepaRment of t�atural Resources. The review concluded that some depositt of tar below the
hard asphah surface remain. This raised a concem about what the DNR would do when the hard
surface laye� is remo�ed - thus exposing some tar. As a result of this concem Jim Lundy, Frank
Wallner, and Jeff Mayan from MAP met at the site on Apri1 15, 1998, and touk saveeal hand
au�er borings to determine if significant quantities of tar was present below hardened asphalt
deposits. This preliminary work did show some smal) deposiu of tar below t}�e surface in area
SUN-19-199B 11�34 MN. PCR G�SW
Ashland/Cottage Gro�c h�c (Company now called Marathon Ashlano r'etroleum)
Page 3
April 28, 1998
Below hard surtace asphaii was very ckan sand.
Test Trench 6- Area 2C
Length; Approximately 10 fcet. Dcpth 4 feet.
Below herd surface asphalt was ciean sand.
Test Trench �- Down the bluff from area 2B
Length; Approximately l0 feet. Depth: 5 feet.
Below deposits of broken up surface asphalt was clean sand.
Test Trench 8- Area 1
Length: Approximatety 1 S feet. Depth: Approximately 5 feet.
This vench was taken to determine the character of any waste below a surface deposit of soft
asphalt. !t was speculated that since the surface asphalt was sofrer it would extend down deep.
However, the trench revealed mainly dark stained soil with some runny tar. Clean sand below.
5ome extra tarry waste will have to be removed when the hard asphalt surface is removed,
Test Trench 9- Area 1
P.83i95
Length: Approximately 7 fcet. Depth: 4 feet.
Agai� a soft asphalt surface deposit was targeted for caca�ation. The trcnch revealed dark sandy
soil, with very little tarry materiai. Clean sand below.
!n addition to the test trenching staff used a hand auger to probe just wesVsouth west of srea 2.
Probing did not uncover any new sub surface deposiu. it atso helped confirm that much ofthe
hard, broken•up surface deposits aro surficial and eould easily be removed.
Conclusion
(n general the test v�nching wnfirmed the eartier Remdial Investigation conducted by Ashland
in l987. The only significant finding is that oftest trench 1 and 2 in area 2B which did show
some deposits of tarry materiai immediately below the Mard asphalt which witl have to be
removed once che asphalt is remo�ed. Ares l at test trenches 8 and 9 also showed signs of smail
amounts of tarry material which would also need to be removed. 7he quantiry is hard to judge
without all the asphalt removed although e rough estimate would be Iess than a 1,000 cubic
yards. The hard surface asphalt couid be takert to a landfill. !t is likely that the tarry material
can also bo Iandfi(lad, but to be sure Ashland eoilected a sample which will be tested for TCLP.
Past TCLP tcsu of matorial from area 5 showed it to be non-haurdous.
FXW:Ima
cc: Bob Djupstrom, DNR
Bob Everett, Marathon Ashiand Petroleum
JUN-19-199B 11�34 MN. PCR GWSW
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June 11, 1998
Mr. John M. Burbank
Associate Planner
City of Cottage Grove
7516 80`" Sueet South
Cottage Grove, Minnesota 55016
BAV WfSj INC.
FIVf fMPIRE DRIVf
SAINT PAUL, MN 55703-7867
6t2-297-0456 Y�800-279�0456
FAX fi12�297-0099
RE: Grading Permit Application for Oakey Farms Excavation Project, Cottage Grove,
Minnesota
Deaz Mr. Burbank:
Per our discussion on Tuesday, June 9, 1998, enclosed you will find an Application for Grading
Permit and a check for the sum of $229.95 for the Grading Plan Review Fees ($30.53) and the
Grading Pemvt Fees ($199.42).
The Oakey Fazms Excavation project involves the excavation of approximately 10, 350 tons of
soil from two azeas (see attached site location map). Approval for the start of the project was
received from Mr. Frank Wallner of the Minnesota Pollution Control Agency (MPCA) on June
l, 1998. The project is scheduled to run approximately 6 to 8 weeks and be completed by July
31, 1998. Copies of the Site Plan, Erosion Control Plan and Health and Safery Plan are attached.
The traffic plan for the site involves loading end-dumps starting at approximately 7:00 am and
continuing unti14:30 pm. The trucks will each weigh approximately 23 tons upon leaving the
site. The trucks wili be foilowing a course which runs east on 110`� Street South; north on Ideal
Avenue South; east on 100�' Street South; north on Jamaica Avenue; and north on Highway 61.
The finat destination of the trucks is Superior FCR Landfill in Buffalo, Minnesota.
Appro�cimately seven End-Dump trucks will be used every day, each making ttuee trips between
Oakey Farm and Superior FCR Landfiil.
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Mr. Burbank
June I1, 1998
Page 2
Due to the limited slop of the site and the shallow nature of the excavation, an Erosion Control
Plan is not needed for the eastern portion of Area 1. Four copies of the Erosion Control Plan aze
attached for the westem end of the excavation at Area 1(within 30 feet of the crest of the hill)
and for Area 2.
Four copies of the "final grading plan" will be fonvazded to the City of Cottage Grove upon
completion of excavation activities and following consultation with the MPCA and the
Minnesota Department of Natural Resources (MDNR).
Bay West is looking forward to working with the City of Cottage Grove on the Oakey Farm
project. If you have any questions or concems regarding the excavation activities at Oakey
Fann, please contact me at 291-3414.
Very Truly Your �
Edward J. Baci
Project Manager, Hydrogeologist
encl.
06/SO/98 WED 12:40 FA% 612 458 2881 COTTAGE GROVE COM3i DEVLP (�0�2
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APPLICATION FOR GRADING PERM(T � � �g3•`�"
1, Grading Site:
Western end of IlOth Street South
�ne�s,
Oakev Farm
e...w„o.,� wm.
2. Project Owner/Representative:
Marathon Ashland Petroleum L L C
w.m.
103rd Street South and Aadlev Avenue, St. Paul Park. Miv'
" �,m.m
612) 458-2661
3. Frm preparing gradng and orosion control ptan:
Bay west, Inc.
«.�.
5 Empire Drive, St. Paul, MN 55103
�ae.m
(612) 291-0456 (612) 291-0099
llwr�Fu
4. Contractor performing groding work:
MANN Excavating, Inc.
r�.
300 Hastines,,Svenue. St. Pau] Park MN 55071
�wann
(612) 459-9987
rn�.,F..
Cetvge Gra+Comnnor'a Umw NunCr 6 Dah InuW
5. Describe wocic appiied for under tfiis pertnit:
Excavatine of netroleum contaminated �n;1a_
6. Estimate value of Grading work: S 27 900.00
la4or 4 Matriil
7. Cubic yaeda of materiaf to be moved on the site: 10.350 vd3.
Endose the fol(owing documents:
p A she plan showing the dimensions and acreages of Yhe site to be graded.
D Faur(4� eopies af the finei greding pinn showing origina� and final contours of the site.
� Pour(4j copies of the erosion caatrol plan showing all erosion controi faciliYies to be installed and mainiained during
and following grading operation.
The �ndersig�ed here6y agrees that all work wi(i be done in accordance with ordinances of the �ty af Cottage Grove
and the eequirements of the Engineering Department.
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HEALTH ANDSAFETY PLAN
for
MARATAON ASHLAND
PETROLEUM LLC
OKEY FARM SOIL REMOVAL
Prepared by
BAY WEST, INC.
�c� �.�--��
Steven M. Kett, CIH, CSP
Industrial Hygi�nist
May 1998
BW980231 D � � C �' `/_ �
I j .�'_' , I I '.
�
' 1� _._.
HEALTH ANDSAFETY PLAN
Okey Farna Soil Removal
TABLE OF CONTENTS
1 .0 INTRODU CTION .........................................................................................................................................1
1 .1 PURPOSE AND SCAPE ..................................................................................................................................... 1
1 .2 PROIECTOVERVIEW ........................................................................................:.....................:...................... I
2.0 PERSONNEL AND RESPONSIBILITIES .................................................................................................. 2
2.1 GENERAI.RESPONSIBILI'fY FORI AND SAFETY ..................................................................................... 2
2 .2 KEY PERSONNEL ........................................................................................................................................... 2
3 .0 TRAINING ....................................................................................................................................................3
3 .1 GENERALTRAIIJING ...................................................................................................................................... 3
3.2 PROJECT $PECIFIC `I`RASNING ......................................................................................................................... 3
3.3 MARATHON ASHLAND PETROLEUM LLC SAFETY ORIENTATTON ..................................................................... 3
4 .0 MEDICAL SURVEILLANCE ...................................................................................................................... 3
5 .0 Aa7.aRn ASSESSMENT ............................................................................................................................. 3
5 .1 Cxenucn[. HnznRns .................................................................................................................................... 3
5 .2 PttYS[cnr.FinznxDS ...................................................................................................................................... 4
5.3 HEAT SIRESS AND SEVERE WEATHER .........................................................................�................................... 5
6.0 HAZARD CONTROI .................................................................................................................................... 5
6 .1 INSPECTTONS ................................................................................................................................................ 5
6.2 Srt� Cox�rgoL ............................................................................................................................................. 5
6.3 DUSr Cor�rxoL ............................................................................................................................................ 6
6.4 HOUSEKEEPING AND HYGIENE ....................................................................................................................... 6
6 .5 $ITE COMMLiNICAT[ON .................................................................................................................................. 6
7.0 PERSONAL PROTECTIVE EQUIPMENT ................................................................................................ G
8.0 AII2 MONTTOItING .................................................................
8.1 CANFINEDSPACEMONITORING .................................................
$.2 DUST MONTTORING ..................................................................
9.0 DECONTAMINATION ...............................................»...........
9.1 PERSONNEL DECANTAMINATION ...............................................
9.2 EQUSPMENT DECANTAbtAIATION ...............................................
l0A CONTINGENCY PLAN .........................................................
10.1 MEDICALEMERGENCY ............................................................
10.2 Et.�RGENCY AND FIILST AID EQUIPA�NT .................................
103 INCIDEN'f/ACCIDENT REPORTW G ................................_ _ _ _. _..
n
.......................................... 7
.......:.................................. 7
........................................................ 7
........................................................ 7
........................................................ 7
........................................................ 7
................................................................. 7
................................................................. 8
................................................................. 8
HEALTH AND SAFETY PLAn'
Okev Farm Soi! Removal
1.0 INTRODUCTION
1.1 Purpose and Scope
This Health and Safety Plan (FiASP) provides the safety and health guidelines for the
excavation and removal of asphalt contaminated soil at the Marathon Ashland Petroleum
LLC Refinery's Cottage Grove Site in Cottage Grove, Mumesota, hereinafter refened to as
the `Okey Farm Site.' In addition to this HASP, all project-associated personnel working at
or visiting the site shall adhere to the safety and heaith requirements established by
Mazathon Ashland Petroleum LLC. Site activities fall under the scope of the OSHA
Hazwoper standazd (1910.120/1926.65).
This HASP has been developed based upon information provided by the Project Manager
and a review of 1987 Remedial Invesdgation Final Repart. It is subject to change based
upon actual and changing conditions encountered at the project site. The site supervisor has
the authority to modify the contents of this HASP as deemed necessary to adequately
protect the health and safety of the workers or the environment. All changes to this HASP
shall first be communicated to the Project Manager and the Health and Safety Manager. All
changes to this plan or relief from plan requirements for specific activities shall be properly
documented. Addenda may be added for changes to the scope o£work.
1.2 Project Overview
The Okey Farm Site contains several areas formerly used for disposal of solid waste, barrels
containing asphalt, oily emulsion, and calcium carbonate. Areas which are or may be
included within the scope ofthis project are labeled as Areas 1-3 on the attached site
diagram (Attachment I) and aze described below:
Area i: This azea contains approximately 3100 cubic yards of soil contaminated to a
depth of 10 feet with heavy crude oil fractions (asphalt waste), a few empty drums,
sample cans, and miscellaneous solid waste. Lead is present but in concentrations which
are nbt anticipated to present a worker exposure potential.
Area 2: This area contains three sub-areas, noted as 2A, 2B, and 2C. Area 2A contains
appro�mately 180 cubic yazds of contaminated soils containing deteriorated metal
drums of tar to an anticipated depth of 4 feet. Area 2B contains 1300 cubic yards of
contaminated soil containing heavy crude oil fractions, drummed asphalt and sample
cans to a depth of 6 feet. Area 2C is similar to 2A and 2B and is estimated to contain
120 cubic yazds of contaminated soil. A composite sample from Area 2 indicates a
relatively high concentration of lead (6500 mg/kg). However, due to the oily nature of
the contaminated soil and exposure control measured stated herein, airborne lead is not
anticipated to present a potential for exposure above the OSHA action limit (30 µg/m').
BW980231 Page I May 1998
HEALTH ANDSAFETY PLAN
Okey Farrn Soil Re�zoval
• Area 3: This area is less contamination than Areas 1 or 2. The area contains 410 cubic
yards of contaminated soil and approximately 150 - 200 drums, most of which are
empty.
The scope of work for this project includes the excavation and loading of contaminated soil
and solid waste into transport containers for off-site disposal. The transport of the
contaminated materials is not included under the scope of site operations and personnel
perfomung these activities must only receive site safety training.
Mann Excavating, Inc. has been contracted to perform site excavation activities. Muilin
Trucking, Inc. has been subcontracted to transport the contaminated soils between the site
and the disposal facility. This HASP only applies to the portion of work (soil loading)
perfonned by this subcontractor while on the site's premises.
The project is expected to commence in May 1998 and continue for approacimately four
weeks.
2.0 PERSONNEL AND RESPONSIBILITIES
2.1 General Responsibiiity for Health and Safety
The Bay West Site Supervisor is responsible for maintaining compliance of all on-site
project personnel and activities with this HASP. Any deviation frorn required safety and
health guidance outlined in this HASP must first be approved by the Bay West Project
Manager and the Health and Safety Manager.
2.2 Key Personnel
BW980231 Page 2 May 1998
A listing of key personnel involved in site activities is contained in the following table.
HEALTH AND SAFETY PLAN
Okey Farm Soil Removal
3.0 TRAINING
3.1 Generat Training
Personnel perfomung work on the site must be at least 24-hour trained per 29 CFR
1926.65, Hazardous WasYe OperationrandEmergencyResponse (HAZWOPER), and also
document the required "one day of supervised experience" stated in the regulation. Site
workers must also have completed an 8-hour refresher course within the previous 12
months.
3.2 Project Specific Training
All project personnel (including transportation employees} must receive site specific health
and safety training prior to commencing work at the project site. This trairung shall discuss
the contents of this pian, anticipated hazards at the site, means of controlling or reducing
risk to the hazards, and proper work methods. All site specific training will be documented
(See Attachment 2).
3.3 Marathon Ashland Petroleum LLC Safety Orientation
Prior to perfornung any on-site work at the Marathon Ashland Petroleum LLC refinery, Bay
West and subcontractor personnel must attend the Marathon Ashland Petroleum LLC safety
orientation. Contact Mike Boswell, Marathon Ashland Petroleum LLC Safery Supervisor, at
(Phone: 458-2666) to schedule tYsis trairring.
4A MEDICAL SURVEILLAi\'CE
All project site personnel exposed to hazardous materials must participate in a medical
surveillance program meeting the requirements of 29 CFR Parts 1926.65. These
requ'uements include pre-employment and routine medical exanunations.
Marathon Ashland Petroleum LLC Refinery requires all subcontractor personnel to
participate in their drug test progam.
5.0 HAZARD ASSESSMENT
5.1 Chemical Hazards
The primary substance to which site workers may be exposed is heavy petroleum
compounds (asphalt) and other low-volatility petroleum substances. Lead is present in the
soils in Area 2, but in concentrations which are not anticipated to present an exposure
potential. The hazazds of these materials are presented below:
Asphalt and low-volatilittipetroleum substances: These substances will most likely pose an
exposure potential through inhalation of dust cantaminated with the materials; however,
B W 98023 I
Page 3
May 1998
HEALTH ANDSAFETY PLAN
Okey Farm Soil Re»ioval
exposure is not anticipated to exceed current exposure lirnits. The threshold limit value for
asphalt fume is 5 mg/m Exposure may lead to respiratory imtation.
Lead: As stated, exposure to lead above the OSHA pernussible exposure limit (50 µg/m or
action limit (30 µglm is not anticipated due to the concentration of lead in the soil, the
condition of the soil (oily, non-dusty), and protective measures to be implemented to reduce
the amount of airborne dust generated by site activities (e.g., watering). For information
purposes, lead is a toxic metal which affects the central nervous system, gastrointestinal
system, and kidneys. Symptoms of exposure include weakness, insomnia, anorexia,
abdominal pain, and anemia, among others.
5.2 Physical Hazards
A variety of physical hazazds may be encountered at the project site:
Excavation: Notify the Marathon Ashland Petroleum LLC representative at least 48 hours
before commencing excauationJtrenching activities in order to have underground utilities located
and marked. Excavations greater than five feet in depth shall not be entered until protective
measures such as sloping, benching, or sidewall support systems aze implemented. These
protective measures must meet the specifications, and be unpiemented by a"competent person,"
as defined in 29 CFR 1926.650. An excavatian less than five feet in depth may only be entered
after the ground is examined by a"competent person," and that person does not find a potential
for cave-in. The boundary of the excavation shall be mazked, fenced, or othetwise controlled to
prevent entry into the excavation by unauthorized persons. A daily inspection shall be performed
by the site supervisor/excavation competent person. An inspection checklist is contained in the
Bay West Excavation and Trenching SOP (Attachment 3).
Confined snace entry: Excavations exceeding four feet in depth (below natural grade) are
considered to be confined spaces by Marathon Ashland Petroleum LLC. Entry by personnel
into such spaces requires implementation of the Marathon Ashland Petroleum LLC standazd
operating procedure for confined space entry (Attachment 3). Excavations meeting this
requirement will most likely be considered to be Class I confined spaces which require a confined
space permit and continuous monitoring for oaygen concentration during the entry.
Heavy Equipment: Work in or around heavy equipment presents several hazards including
the potential for being caught in or crushed by moving equipment, being struck by falling
materials, and exposure to noise (addressed separately). The risk of these injuries can be
reduced by staying clear of operating heavy equipment, being observant of work activities,
wearing appropriate PPE including hard hats and safety boots, and making the equipment
operator aware of your presence - always approach operating equipment in a direction
which is visible to the operator. Alt ground crew employees sha[i wear high visibility
vests when working around heavy equipment
Noi,se: Exposure to continuous loud noise or short-duration, impact type noise can lead to
temporary or permanent hearing loss. Effects of noise can be minimized by staying away
BW980231
Page 4
May 1998
HEALTH AND SAFETY PLAN
Okey Farm Soil Removal
from noise sources and wearing proper hearing protection including ear inserts and muffs.
All work near heavy equipment operation requires the use of hearing protection.
5.3 Heat Stress and Severe Weather
The potential for heat stress and severe weather may e�cist depending upon the weather
conditions encountered during site work.
Heat stress includes heat rash, cramps, fainting, heat exhaustion, and heat stroke, in order of
severity. Personnel suffering from any af these ilinesses must be given immediate treatment
to include removal from warm work areas to a cool rest area, administration of water or
other fluids, and medical attention (for fainting or heat stroke). Heat stress can be prevented
by having site workers take frequent rest breaks and drink plenty of fluids.
In the event of the potential for severe weather, the site supervisor shall monitor weather
conditions and severe weather watches/wamings established by the National Weather
Service. In the event of a severe weather warning or if lightning is observed in the vicinity
of the site, ail site work will be terminated and shelter wiii be sought by all site workers.
6.0 HAZARD CONTROL
6.1 Inspections
Pre-Consiruction Inspecfion/Review. Prior to initiation of site work, a preyob safety
review shall be performed by the Marathon Ashland Petroleum LLC representative(s) and
the Bay West project manager and/or site supervisor.
Periodic Inspections: The Site Supervisor shall perfbrm a safety/health audit each week while
work is being perfonned at the site. Results ofthe audit wii be documented on the Mazathon
Ashland Petroleum LLC Contractor SafetyAudit Repon form and provided to the Site Contact.
6.2 Site Control
The boundary of the site shall be identified with yellow and/or red baaicade tape; the
exclusion wne shall be mazked with hazard fencing. These materiais shall be used to
demazcate the support zone, contamination controi zones (decon trailer and equipment load-
out area), and exclusion zone.
All employees and visitors must sign in and out when arriving/leaving the projeci site. A
register shall be kept by the Site Supervisor. All site visitors must be escoeted at all times by
the Bay West Site Supervisor (or his designee) when on the premises of the project site. All
personnel entering the exclusion zone must also sign in and out.
BW980231 Page 5 May 1998
,
HEALTH AND SAFETY PLAlV�
Okey Farin Soil Removal
No cameras or other recording devices are allowed on the project site unless authorized by
the site supervisor or Marathon Ashland Petroleum LLC Company.
6.3 Dust Control
Dust generation will be controlled when working in Atea 2 to prevent the potential for
exposure to airbome lead. If visible dust generation is observed, dust suppression
techniques shall be implemented to include watering of the soil during excavation.
Monitoring of dust concentrations shall be periodically performed at the discretion of the
Site Supervisor to verify that dust control techniques are adequate.
6.4 Housekeeping and Hygiene
HousekeeDinQ: The worksite shall be maintained in a condition which minimizes litter and
clutter, slipping or tripping hazazds, and presents an orderly appearance.
Scmitation: Portable toilets shall be supplied at the project site and shall be routinely
serviced throughout the duration ofthe project
Smokin�Eating Drinkinn: No smoking or use of tobacco products, eating, or drinking
shall be allowed in the exclusion zone of the site. Smoking is not allowed orily in designated
areas. Drinking water will be supplied at the project site for use by all workers.
6.5 Site Communication
Hand radios will be available for site communication between the site supervisor and work
crews at the site if necessitated. A fixed or cellular phone will be available for off-site
communication.
Phone numbers for emergency services (fire, police, medical assistance) will be posted near
all telephones.
7.0 PERSONAL PROTECTIVE EQUIPMENT
All site workers must use the following PPE at ail times when within the boundaries of the
project site (this equipment constitutes Levei D protection):
• Hard hat
• Steel-toed safety boots
• Safety glasses with side shields or goggles
• Hearing protection (as needed)
BW980231 Page 6 May 1998
HEALTH AND SAFETY PLAN
Okey Farm Soil Rensova/
Personnel working in Area 2, shail wear the following protective equipment in addition to
the items listed above when working in excavation areas to reduce the potential for off-site
removai of lead contamination:
. Tyvek suit
• Boot covers
. Disposable rubber gloves
8.0 AIR MONITORING
8.1 Confined Space Monitoring
Monitoring during confined space entry into excavations will be performed using a PID
(with a 10.2 eV lamp) to assess exposure to organic vapors and a combustible gas indicator
to detennine oxygen concentration. Monitoring will be performed in the breathing zone of
employees. Confined spaces will not be entered if the o�cygen concentration is below 14.5%
or if the PID indicates organic vapor concentrations exceeding 5 ppm above the background
concentration for the area.
8.2 Dust Monitoring
Monitoring for dust concentration shall be performed by the Site Supervisor using a direct
reading aerosol monitor when visible emission of dust is observed. Additional dust
suppression actions must be taken if dust concentrations continuously exceed 2 mg/m
9.0 DECONTAMINATION
9.1 Personnel Decontamination
Personnel wearing contaminated, disposable PPE shall discard the PPE when leaving the
exclusion zones. The PPE will be stored and appropriately disposed.
9.2 Equipment Decontamination
Equipment will be decontaminated when leaving the exclusion zone. Equipment
contaminated with lead-contaminated soils will be washed/sprayed until no visible
contamination is observed.
10.0 CONTINGENCY PLAN
10.1 Medical Emergency
In the event of a medical emergency, immediately contact the site supervisor. If necessary,
decontaminate the victim to the extent possibie and administer first aid. Contact emergency
services by dialing 911.
BW980231
Page 7
May 1998
HEALTH AND SAFETY PLAl�i
Oke Farm Soil Renioval
If non-emergency medical aid is required, transport the victim to the following location:
Regina Medical Center
1175 Nininger road
Hastings, MN
480-4100
A map from the project location to the hospital is contained in Attachment 1.
10.2 Emergency and First Aid Equipment
The following emergency and first-aid equipment is required to be on-site at all times:
• first aid kit capable of accommodating the expected types of injuries and the quantity
of employees at the site
- fire extinguishers (adequate quantity to provide access to all areas where workers are
located)
10.3 IncidenUAccident Reporting
The Site Supervisor must complete a Contractor Supervisors Incident Report form for any
incident that involves a near miss situation or when an injury occurs on the jobsite.
BW980231 Page 8 May 1998
—, a
Attachment 1
Site Diagram
and
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Attachment 2
Training Documentation Form
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COA4PLIANCE AGREEMENT
The undersigned attest that they have read or have received training on the contents of this Health
and Safety Plan and agree to abide by the provisions contained in the plan. The undersigned also
agree to: assist in the imp(ementation and enforcement of the plan; be aware of site security and
safety conditions at all times; and, to perform site operations in a safe manner.
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