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
Removal operations in BRSAs 7 & 8 resumed on March 12 after record high water levels receded. Removal of the temporary WCS resumed from the south side of the river.

2.1.2 Response Actions During Reporting Period

BRSA 7
- Additional excavation of contaminated soils continued with confirmation results received in the riverbank grid shown in Table 1 below. There are 63 total river bank grids in BRSA 7, with each grid consisting of approximately 50 feet of riverbank. There are 3 stream tubes, with each varying in size. The target clean-up goal in riverbank soils is 5 mg/kg total PCBs and in-stream sediments is 1mg/kg total PCBs;
- Transportation and disposal of contaminated soils & sediments (utilizing the staging pad in BRSA 6); and
- Maintenance and repair of stream tube protection measures and access roads.

General 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 7 & 8. 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 1-7 of the BRSA 7 & 8 TM.

BRSA 8
- Excavation of contaminated soils and sediments continues, with confirmation results received in riverbank grids and stream tubes shown in Tables 2 & 3 below. There are 63 total river bank grids in BRSA 8, 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; 
- Transportation and disposal of contaminated soils & sediments (utilizing the staging pad in BRSA 9); and
- Maintenance and repair of stream tube protection measures and access roads.

General 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 7 & 8. 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 1-8 of the BRSA 7 & 8 TM.

OVERALL SITE
- Transport/disposal of approximately 2120 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4);
- Particulate monitoring (PM10) around the site perimeter (when feasible) with no sustained exceedance off site of particulates above the action level of 1.5 mg/m3;
- Turbidity monitoring utilizing a hand held monitoring instrument with no sustained exceedances;
- Treatment of approximately 13,280 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 both WWTPs continue to show non-detect levels for PCBs in the treated discharge; 
- Temporary WCS removal activities resumed on the south bank of the river as weather conditions improved and high water levels receded (see photo); and
- Bank re-grading and restoration continues on the north bank of the river at the temporary WCS (see photo). The temporary WCS corridor is being restored in consultation MDEQ & MDNR (see photo) pursuant to an approved 'Application/Permit to Use State Land.'

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.

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

BRSA 6
- Staging pad and WWTP operations to support removal operations in BRSA 7.

BRSA 7
- Access road construction along riverbanks;
- Continue excavation of contaminated riverbank soils and in-stream sediments;
- Treat contact water from contaminated grids, stream tubes and staging pad (located in BRSA 6); and
- Transport contaminated soils & sediments for disposal.

BRSA 8
- Continue excavation of contaminated riverbank soils and in-stream sediments;
- Treat contact water from contaminated grids, stream tubes and staging pad (located in BRSA 9); and
- Transport contaminated soils & sediments for disposal.

BRSA 9
- Staging pad and WWTP operations to support removal operations in BRSA 8.

SITEWIDE
- Operate dust and turbidity control/monitoring systems (as feasible & necessary);
- Repair and re-construction of riverbanks and restoration planting in all BRSAs impacted by record high water levels; and
- Continue removal of temporary WCS and restoration of surrounding area.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2

2.2.1.2 Administrative Activities / Next Steps
- MDNR issued an updated 'Application/Permit to Use State Land' for riverbank and channel restoration activities in the area surrounding the temporary WCS on March 15.

2.2.2 Issues

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

2.5.3 Information Officer
- Information on the status of the project was provided by CIC Diane Russell at community meeting held at the Otsego Public Library on March 10.

3.1 Unified Command

3.2 Cooperating Agencies

See PolRep #1

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

USEPA - 1
START - 1
MDNR - 1
MDEQ - 1
Envirocon - 42
Milbocker & Sons, Inc. - 4
Spicer Group, Inc. - 1
AMEC-FW - 2

TOTAL: 53

6.1 Internet location of additional information/report

https://response.epa.gov/otsegodam

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

6.2 Reporting Schedule
The next PolRep will be generated on March 30.