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 is nearing completion of restoration activities in BRSA 1. Contaminated soils/sediments remaining on site were loaded out for transport & disposal at EPA approved landfill facilities. Decommissioning and demobilization of heavy equipment, supplies and materials continue in BRSA 1, with completion expected in the next few weeks.

 2.1.2 Response Actions During Reporting Period

The following activities took place during the reporting period:

- Reconstruction / restoration / inspection of excavated grids in BRSA 1, including plantings (see attached photos);

- Transport / disposal of approximately 945.8 tons of excavated sediments/soils with PCB levels less than 50 ppm to an EPA-approved landfill facility. A total of 7120.64 tons of excavated sediments/soils have been transported from BRSA 1 for disposal to date;

- Transport / disposal of approximately 103.91 tons on excavated sediments/soils with PCB levels exceeding 50 ppm to an EPA-approved landfill facility;

- Treatment of contact water from contaminated grids and contaminated soils staging pad in the on site WWTP. Approximately 39,349 gallons were treated during the reporting period. A total of approximately 303,075 gallons have been treated since the start of the project. Sampling results confirmed non-detect levels for total PCBs in treated water;

- Dismantlement and demobilization of the WWTP from the BRSA 1 staging area. This unit will not be utilized over the winter due to weather considerations;

- Completion of investigatory geotechnical borings to determine the stability of slopes in BRSA 7 (see attached photo);

- Surveying / staking of potential support / staging areas for BRSAs 3-9; and

- 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.

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. Totals to date are also included in the table below.

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

- Complete restoration of all grids in BRSA 1;
- Restoration of the BRSA 1 staging and support areas in coordination with Michigan DNR;
- Operation of dust control/monitoring systems;
- Continued surveying / staking of potential support / staging areas to support BRSAs 3-9;
- Commencement of construction activities in support / staging area in BRSA 3; 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
- Permits will be obtained for anticipated work in the right of way along M-89 for BRSAs 3 & 4;
- AMEC-FW will submit a second draft Technical Memorandum for BRSAs 2 & 3 by December 9 for review;
- AMEC-FW will present the general approach to field work in remaining BRSAs at a meeting on December 16; and
- Consent to Access agreements will be developed and presented to land owners in BRSAs to be addressed in 2017.

2.2.2 Issues

None

2.4.1 Narrative

See PolRep #3 and #7.

* 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 site walk around the M-89 bridge was conducted with MDOT representatives on November 14 to discuss precautions and permitting requirements for conducting removal operations in proximity to the structure; and
- A site tour was conducted for representatives of the Otsego Township Board of Trustees on November 17.

2.5.3 Information Officer

- A site tour was provided to a reporter and photographer from the Kalamazoo Gazette on November 15; and
- A fact sheet is under development for door to door distribution to neighbors explaining work to be conducted over the winter months.

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 - 1
Michigan DNR - 1
START - 1
Envirocon: 12
AMEC-FW: 2
Spicer Group: 1
TTL Associates, Inc. (geotechnical drilling contractor): 2

TOTAL: 21

AMEC-FW         AMEC Foster Wheeler

BRSA                Bank Removal and Stabilization Area

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     

OSC                  On Scene Coordinator

PCBs                Poly-chlorinated biphenyls     

PM                    Particulate Matter

PolRep              Pollution Report

ppm                   parts per million

PRP                  Potentially Responsible Party     

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

As field activities are for the most part completed for 2016, the nest PolRep will be generated at the end of December.