1. Introduction
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1.1 Background
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Site Number: |
059B |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
4/6/2016 |
Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
Response Lead: |
PRP |
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Incident Category: |
Removal Action |
NPL Status: |
NPL |
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Operable Unit: |
5 |
Mobilization Date: |
8/1/2016 |
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Start Date: |
8/1/2016 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
MID006007306 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
DEQ |
FPN#: |
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Reimbursable Account #: |
059B |
1.1.1 Incident Category
Time Critical Removal Action - PRP Oversight
1.1.2 Site Description
See PolRep #1
1.1.2.1 Location
See PolRep #1
1.1.2.2 Description of Threat
See PolRep #1
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
See PolRep #1
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Excavation of contaminated riverbank soils and in-stream sediments along with restoration are near completion in BRSA 4. The staging area is constructed and removal operations began in BRSA 6.
2.1.2 Response Actions During Reporting Period
BRSA 4 & 5
- Excavation of contaminated soils continues with excavation completed and confirmation results received in riverbank grids 39-43 and 47-51 (grids 44-46 are yet to be excavated). Due to field adjustments, there are now 51 total grids in BRSA 4, with each grid consisting of approximately 50 lineal feet of riverbank. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs;
- Completed removal of sheet piling in first 'stream tube'; and
- Completed excavation of contaminated in-stream sediments in the second 'stream tube' in BRSA 4, which is located within the river channel immediately adjacent to riverbank grids 47-50. The target clean-up goal for in-stream sediments is 1 mg/kg total PCBs.
- Due to field adjustments, in-stream sediments were excavated from a single stream tube in BRSA 5.
Estimated excavation depths and confirmation sampling results are found in the table below for riverbank grids (Table 1), 'stream tube' grids (Table 2), and a 'stream tube' grid in BRSA 5 (Table 3):
BRSA 4
RIVERBANK
GRID
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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39
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12
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<0.066
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40
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48
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<0.072
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41
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48
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0.08
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42
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48
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<0.058
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43
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48
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<0.072
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44
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to be excavated
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-
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45
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to be excavated
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-
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46
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to be excavated
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-
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47
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36
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<0.039
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48
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24
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0.091
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49
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12
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<0.034
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50
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12
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<0.036
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51
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12
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<0.042
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Table 1. BRSA 4 Riverbank
Grid Confirmatory Sampling Results
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BRSA 4
STREAM TUBE GRID*
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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47
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6
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0.72
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48
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6
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0.14
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49
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6
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0.066
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50
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6
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0.26
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Table 2. BRSA 4
Stream Tube Confirmatory Sampling Results
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BRSA 5
STREAM TUBE
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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1
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6
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0.14
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Table 3. BRSA 5 Stream
Tube Confirmatory Sampling Results
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Table Notes: Confirmatory sampling takes place immediately following excavation of contaminated soils and/or sediments in accordance with procedures outlined in the FSP and the TM for BRSAs 4, 5, 6 & 9. Both documents can be found in the ‘Documents' Section of the project website. Stream Tube grids are numbered consistent with the riverbank grid they are located adjacent to. A figure showing the location of both (preliminary) riverbank grids and stream tubes can be found on Figure 8 of the BRSA 4, 5, 6 & 9 TM.
- Transport/disposal of approximately 2486 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4).
BRSA 6
- Completed construction of staging area and stabilization pad (see aerial photo);
- Completed assembly and tested WWTP;
- Constructed coffer dam systems to facilitate removal of riverbank soils and in-stream sediments in grids 1-10; and
- Installed sheet pile coffer dam system in first 'stream tube'.
OVERALL SITE
- Daily particulate monitoring (PM10) around the site perimeter with no sustained exceedance off site of particulates above the action level of 1.5 mg/m3;
- Turbidity control measures and monitoring in Kalamazoo River around the BRSA 3 - 9 excavation area (1 upstream monitor and 2 downstream monitors), with no sustained exceedance of the action level of 50 NTUs above upstream levels;
- Treatment of approximately 265,264 gallons of contact water from contaminated grids and contaminated soils staging pads in the on-site WWTP located in BRSA 4 (see Section 2.1.4). Sampling results from the WWTP continues to confirm non-detect levels for total PCBs in treated water; and
- Monitoring of the temporary WCS.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
See PolRep #1
2.1.4 Progress Metrics
Both quantities during the reporting period ('Quantity' column) and totals to date ('Total' column) are included in the table.
Waste Stream |
Medium |
Quantity |
Total |
Manifest # |
Treatment |
Disposal |
Cardboard |
solid |
50 lbs |
850 lbs |
NA |
recycling |
Otsego Recycling Center
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Plastic |
solid |
30 lbs |
315 lbs |
NA |
recycling |
Otsego Recycling Center |
Steel |
solid |
20 lbs |
9270 lbs |
various |
recycling |
Broken Arrow Recycling |
Contaminated soil (< 50 ppm* PCBs) |
solid |
2486 tons (est) |
16,299 tons (est) |
various |
disposal |
Republic Ottawa County Farms Landfill, Coopersville, MI |
Contaminated soil
(> 50 ppm* PCBs) |
solid |
0 tons |
103.91 tons |
various |
disposal |
US Ecology Michigan,
Belleville, MI |
Contact water |
liquid |
265,264 gal |
860,194 gal |
NA |
on-site WWTP |
On-site reuse/discharge to Kalamazoo River |
*Note: 1 ppm = 1 mg/kg
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2.2 Planning Section
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2.2.1 Anticipated Activities
During the next reporting period, the following activities are expected to occur:
BRSA 4
- Complete excavation of contaminated riverbank soils (grids 44-46);
- Continue restoration of all excavated river bank and in-stream sediment areas;
- Treat contact water from contaminated grids and contaminated soils staging pad; and
- Transport contaminated soils and sediments for disposal.
BRSA 6
- Excavation of contaminated riverbank soils and in-stream sediments;
- Installation of sand bag and sheet pile coffer dam systems;
- Apply treatment to control invasive plants;
- Treat contact water from contaminated grids and contaminated soils staging pad; and
- Transport contaminated soils and sediments for disposal.
BRSA 9
- Commence construction of staging area;
- Apply treatment to control invasive plants; and
- Begin transport of equipment, supplies and materials to staging area.
SITEWIDE
- Operate
dust and turbidity control/monitoring systems; and
- Maintain/monitor temporary WCS.
2.2.1.1 Planned Response Activities
See Sections 2.2.1 & 2.2.1.2
2.2.1.2 Administrative Activities / Next Steps
- AMEC-FW is preparing responses to agency comments and will hold meetings to resolve outstanding issues and concerns on the draft TM for BRSAs 7 & 8.
2.2.2 Issues
None
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2.3 Logistics Section
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See PolRep #1
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
A safety meeting is held prior to work start each day. The meeting is led by on-site safety officer(s) from Envirocon & AMEC-FW.
2.5.2 Liaison Officer
- A site tour was held on July 26 for management representatives from MDEQ, MDNR and US EPA; and
- A site tour was held on July 27 for students from Michigan State University and Western Michigan University.
2.5.3 Information Officer
A neighbors meeting was held on July 26 at the Otsego City Hall. A project update along with plans for the rest of the 2017 construction season were presented.
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3. Participating Entities
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3.1 Unified Command
3.2 Cooperating Agencies
See PolRep #1
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4. Personnel On Site
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On average, the following personnel were present on site during the reporting period:
US EPA - 1
START - 1
Michigan DNR - 1
Michigan DEQ - 1
Envirocon: 35
Milbocker & Sons, Inc.: 4
AMEC-FW: 3
Spicer Group: 2
TOTAL: 48
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5. Definition of Terms
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AMEC-FW AMEC Foster Wheeler
BRSA Bank Removal and Stabilization Area
FSP Field Sampling Plan
mg/kg milligrams per kilogram
MDEQ Michigan Department of Environmental Quality
MDNR Michigan Department of Natural Resources
OSC On Scene Coordinator
PCBs Poly-chlorinated biphenyls
PolRep Pollution Report
ppm parts per million
PRP Potentially Responsible Party
START Superfund Technical Assessment & Response Team (US EPA contractor)
TM Technical Memorandum
US EPA United States Environmental Protection Agency
WCS Water Control Structure
WWTP Waste Water Treatment Plant
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6. Additional sources of information
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6.1 Internet location of additional information/report
http://www.epaosc.org/otsegodam
www.epa.gov/superfund/allied-paper-kalamazoo
6.2 Reporting Schedule
The next PolRep will be generated on August 18.
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7. Situational Reference Materials
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No information available at this time.
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