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

2.1.1 Narrative

The GC continues excavating contaminated sediments and bank soils and restoring excavated grids in BRSA 1. Contaminated material is being loaded out from the staging pad for transport & disposal at an EPA approved landfill facility.

 2.1.2 Response Actions to Date

The following activities took place during the reporting period:

- Excavation of contaminated soils with confirmation sampling results received from grids 31-36, 38, 47-48, and 53-58 (see table below for results). Grids not included in this sequence were either still awaiting analytical results from the laboratory or required additional excavation to meet cleanup objectives. A total of 43 grids have now been excavated. There are 58 grids in BRSA 1. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs.

 ND = non-detect

- Reconstruction / restoration of excavated grids in BRSA 1 (see attached photo);

- Transport/disposal of approximately 1,402 tons of excavated soils to an EPA approved landfill facility. A total of 2,943 tons of excavated soils have been transported from BRSA 1 for disposal to date;

- Treatment of contact water from contaminated grids and the contaminated soils staging pad in the on site WWTP. Approximately 56,292 gallons were treated during the reporting period. A total of approximately 219,000 gallons have been treated since the start of the project. Sampling results continue to confirm non-detect levels for total PCBs in treated water;

- Daily particulate monitoring (PM10) around the perimeter of BRSA 1 with no detections off site of particulates above the action level of 1.5 mg/m3; and

- Turbidity control measures and monitoring in Kalamazoo River around the BRSA 1 (1 upstream monitor and 2 downstream monitors) with no sustained exceedances of the action level of 50 NTUs above upstream levels.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

See PolRep #1

2.1.4 Progress Metrics

The following materials were managed during the reporting period.

2.2.1 Anticipated Activities
During the next reporting period, the following activities are expected to occur:

- Excavation of contaminated sediments and bank soils in remaining grids of BRSA 1, including TSCA material (soils > 50 mg/kg total PCBs) from grid 29;

- Reconstruction & restoration of excavated grids in BRSA 1;

- Solidification/staging/transport of contaminated sediments & bank soils for disposal;

- Treatment of contact water in the on site WWTP;

- Operation of dust and turbidity control/monitoring systems; and

- Maintenance/monitoring of the temporary WCS.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2.

2.2.1.2 Next Steps
- A draft Technical Memorandum outlining the approach for BRSAs 2 & 3 was submitted on October 21.  EPA is currently coordinating review of the document with state, federal and local partners.

2.2.2 Issues

None

2.4.1 Narrative

See PolRep #3. US EPA (estimated) costs only include on site (personnel, travel, contractor) costs from the beginning of field work (August 1). 

* 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.

2.5.1 Safety Officer

See PolRep #1

2.5.2 Liaison Officer

The OSC and CIC are serving in this role.

2.5.3 Information Officer

The OSC and CIC are serving in this role.

3.1 Unified Command

3.2 Cooperating Agencies

See PolRep #1

On average, the following personnel were present on site during the reporting period: 

US EPA - 1

Michigan DEQ - 2

Michigan DNR - 1

START - 2

Envirocon: 20

AMEC-FW: 3

Spicer Group: 1

TOTAL: 30

AMEC-FW         AMEC Foster Wheeler

BRSA                Bank Removal and Stabilization Area

CIC                   Community Involvement Coordinator

in                       inches

mg/kg                milligrams per kilogram

mg/m3              milligrams per cubic meter

Michigan DEQ  Michigan Department of Environmental Quality

Michigan DNR  Michigan Department of Natural Resources

ND                    non-detect

NTU                  Nephelometric Turbidity Unit      

OSC                  On Scene Coordinator

PCBs                Poly-chlorinated biphenyls     

PM                    Particulate Matter

PolRep              Pollution Report

PRP                  Potentially Responsible Party 

TSCA                Toxic Substances Control Act     

US EPA             United States Environmental Protection Agency

WCS                  Water Control Structure

WWTP               Waste Water Treatment Plant

6.1 Internet location of additional information/report

http://www.epaosc.org/otsegodam

www.epa.gov/superfund/allied-paper-kalamazoo

6.2 Reporting Schedule

PolReps are generated every two weeks during active field activities.