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 completed excavation of contaminated sediments & bank soils in BRSA 1, including two grids which contained levels of contamination exceeding 50 mg/kg PCBs, which were managed pursuant to TSCA regulations. Restoration activities continue throughout BRSA 1. Contaminated soils/sediments remaining on site are being loaded out for transport & disposal at EPA approved landfill facilities.  Decommissioning and demobilization of the WWTP, heavy equipment, and infrastructure/materials are underway in BRSA 1, with completion expected in the next few weeks.

 2.1.2 Response Actions to Date

The following activities took place during the reporting period:

- Excavation of contaminated sediments and bank soils in remaining grids of BRSA 1, including TSCA material (soils > 50 mg/kg total PCBs) from an area designated as 'T1' within grids 29 & 30.   A special work plan was developed, submitted and approved for this area. These contaminated sediments & soils are staged on site awaiting transport for disposal;

- All 58 grids of BRSA 1 have now been excavated to the target clean-up goal of 5 mg/kg total PCBs in riverbank soils (see below table). Note that previous POLREPs 4-6, which contained portions of the table below, have been corrected to show actual excavation depths in all grids;

- Transport/disposal of approximately 3212.90 tons of excavated sediments/soils to an EPA approved landfill facility. A total of 6186.14 tons of excavated sediments/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 55,970 gallons were treated during the reporting period. A total of approximately 263,726 gallons have been treated since the start of the project. Sampling results continue to confirm non-detect levels for total PCBs in treated water;

- Investigatory geotechnical borings to determine the stability of side slopes in BRSA 5 (see photograph);

- 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 with no sustained exceedances of the action level of 50 NTUs above upstream levels. As excavation activities have been completed, the turbidity monitors were removed from the river on November 8.

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. A new column has been added with project totals to date.

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

- Complete reconstruction & restoration of all excavated grids in BRSA 1;
- Complete load out & transport of all remaining contaminated sediments & soils for disposal, including those subject to TSCA regulations;
- Treatment of all remaining contact water in the on-site WWTP;
- Decommissioning & demobilization of the on-site WWTP;
- Complete investigatory geotechnical soil borings in BRSAs 5 & 7;  
- Operation of dust 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
- EPA provided comments to AMEC-FW on a draft Technical Memorandum outlining the approach for BRSAs 2 & 3 submitted on October 21. AMEC-FW is working to address the issues raised by EPA and other state/federal/local partners. AMEC-FW plans to submit a second draft Technical Memorandum for BRSAs 2&3 for approval by December 9. 

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

- A tour of the site was conducted for 22 representatives of the Michigan Statewide Public Advisory Group on October 27;
- A site update was provided at a meeting of the Kalamazoo River Cleanup Coalition on October 27; and
- A tour was provided for Michigan State Representative Mary Whiteford on November 2 (see attached photograph).

2.5.3 Information Officer

The OSC and CIC continue 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: 15
AMEC-FW: 3
Spicer Group: 1
TTL Associates, Inc. (geotechnical drilling contractor): 2

TOTAL: 27

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

ppm                   parts per million

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.