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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 |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
NPL |
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Operable Unit: |
5 |
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Mobilization Date: |
8/1/2016 |
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Start Date: |
8/1/2016 |
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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 |
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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
Removal operations are near completion in BRSA 9. Construction of access roads in BRSA 8 is near completion. Sheet piling operations are complete in BRSA 7, with access road construction commencing.
2.1.2 Response Actions During Reporting Period
BRSA 6
- Restoration continues along riverbanks (see photo); and
- Continue transportation & disposal of contaminated soils and sediments.
BRSA 7
- Removed turbidity curtain downstream of temporary WCS and old auxiliary spillway; and
- Continued maintenance of stream tube protection measures to prevent erosion (see photo).
BRSA 8
- Continued construction of access roads along riverbanks; and
- Continued maintenance of stream tube protection measures to prevent erosion (see photo).
BRSA 9
- Excavation of contaminated soils continued with excavation continues with confirmation results received in riverbank grids and stream tube grids shown in the tables below. There are 38 total river bank grids in BRSA 9, with each grid consisting of approximately 50 lineal feet of riverbank. There are 3 stream tubes, with each stream tube varying in size. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs and in-stream sediments is 1mg/kg total PCBs; and
- Continued transportation and disposal of contaminated soils and sediments.
Estimated excavation depths and confirmation sampling results are found below for riverbank grids and stream tubes in BRSA 9 (Tables 1 & 2).
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BRSA 9
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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31
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12
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TBD
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32
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12
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TBD
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33
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12
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TBD
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34
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12
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0.26
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35
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12
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0.12
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Table 1. BRSA 9
Riverbank Grid Confirmatory Sampling Results
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BRSA 9
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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12A-31
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TBD
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TBD
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12A-32
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TBD
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TBD
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11A-33
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TBD
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TBD
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Table 2. BRSA 9
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.
OVERALL SITE
- Transport/disposal of approximately 301 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4).
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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 the Kalamazoo River downstream of project area (1 upstream monitor and 2 downstream monitors), with no sustained exceedance of the action level of 50 NTUs.
Turbidity control measures were removed downstream of the temporary WCS now that pilot channel construction operations are complete. Turbidity monitors are currently being relocated now that pilot channel construction activities are completed and turbidity control measures have been removed downstream of the temporary WCS;
- Treatment of approximately 63,890 gallons of contact water from contaminated grids and contaminated soils staging pads in on-site WWTPs located in BRSAs 6 & 9 (see Section 2.1.4). Sampling results from the WWTPs in BRSAs 6 & 9 continue to show non-detect levels for PCBs in the treated discharge. Both WWTPs are being winterized to allow for operation in freezing temperatures; and
- Monitoring of the temporary WCS. All stop logs remain removed from the structure.
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 |
20 lbs |
1100 lbs |
NA |
recycling |
Otsego Recycling Center
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| Plastic |
solid |
10 lbs |
485 lbs |
NA |
recycling |
Otsego Recycling Center |
| Steel |
solid |
0 lbs |
21,720 lbs |
various |
recycling |
Broken Arrow Recycling |
| Contaminated soil (< 50 ppm* PCBs) |
solid |
301 tons (est) |
30,752 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 |
63,890 gal |
1,696,016 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 6
- Continue backfilling & restoration of excavated riverbank grids;
- Treat contact water from contaminated grids & contaminated soils staging pad;
- Continue removal of sand bag and sheet pile coffer dams; and
- Continue transport contaminated soils & sediments for disposal.
BRSAs 7 & 8
- Continue access road construction along river banks; and
- Begin excavation of contaminated soils & sediments.
BRSA 9
- Complete excavation of remaining riverbank grids and stream tubes;
- Continue backfilling & restoration of excavated riverbank grids;
- Treat contact water from contaminated grids & contaminated soils staging pad; and
- Transport contaminated soils & sediments for disposal.
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
- Discussions continue on proposed plans to remove the temporary WCS and restore the area (see photo). It is expected that a draft proposal will be submitted to US EPA in mid-December for review.
- A monthly progress report for October was submitted by AMEC-FW. Detailed monthly activity reports are posted in the 'Documents' section of the website each month (see Section 6.1).
2.2.2 Issues
- Field sampling is being planned for several grids in BRSA 7 to confirm the need for remediation excavation in areas with high banks and coarse sediments.
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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 by on-site safety officer(s) from Envirocon & AMEC-FW.
2.5.2 Liaison Officer
A tour was provided to representatives of MDNR & MDEQ on November 16.
2.5.3 Information Officer
An article with an update on progress appeared in the local Otsego Union Enterprise newspaper on November 17.
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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
MDNR - 1
MDEQ - 1
Envirocon - 44
Milbocker & Sons, Inc. - 3
SWAT - 4
AMEC-FW
- 3
Spicer Group - 1
TOTAL: 59
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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
ND Non-Detect
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
UAO Unilateral Administrative Order
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 December 8.
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7. Situational Reference Materials
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No information available at this time.
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