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 continue in BRSA 7 and restoration operations continue in BRSA 8.

2.1.2 Response Actions During Reporting Period

BRSA 6
- Commence removal of contaminated soil & sediment staging pad.

BRSA 7
- Excavation of contaminated soils and sediments continues (see photo) with confirmation results received in the riverbank grids and stream tube grids 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);
- Completed construction of contaminated soil staging pad;
- Completed construction of contact water storage tanks and secondary containment;
- Continued construction of access roads to provide access into remaining grids and stream tubes; and
- Maintenance of stream tube protection measures.

General Table Notes:
* Grid 51 needed to be split into 2 grids for access & construction purposes
- 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
- Continue re-grading and restoration of riverbanks.

OVERALL SITE
- Transport/disposal of approximately 1068 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4);
- Dust control measures and particulate monitoring (PM10) around the site perimeter with no sustained exceedance off-site of particulates above the action level of 1.5 mg/m3;
- No sustained exceedances observed in turbidity monitors;
- Treatment of approximately 27,600 gallons of contact water from contaminated grids and/or contaminated soils staging pad in the on-site WWTP located in BRSA 6 (see Section 2.1.4). Sampling results continue to show non-detect levels for PCBs in the treated discharge; and
- Continued restoration activities (grading, contouring) of area and river bed at former temporary WCS (see photo).

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
- Complete removal of staging pad and begin restoration of surrounding area;
- Remove remaining sheet pile and demobilize crane; and
- Dismantle and remove WWTP.

BRSA 7
- Continue access road construction along riverbanks into remaining riverbank grids and stream tubes;
- Continue excavation of contaminated riverbank soils and in-stream sediments;
- Re-construct and restore riverbanks;
- Collect contact water from contaminated grids, stream tubes and staging pad in temporary storage tanks;
- Transport contact water for treatment at off-site WWTP (see Section 2.2.1.2); and
- Transport contaminated soils & sediments for disposal.

BRSA 8
- Re-construction and restoration of riverbanks.

SITEWIDE
- Operate dust and turbidity control/monitoring systems;
- Commence river channel contouring with specialized excavator; and
- Continue restoration of area surrounding the former temporary WCS and auxiliary spillway.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2

2.2.1.2 Administrative Activities / Next Steps
- AMEC-FW requested approval to ship contact water for off-site treatment at Liquid Industrial Waste in Holland, MI (MID 006 546 121) on May 1. The facility is in compliance with the CERCLA Off-Site Rule and is acceptable for off-site treatment/disposal. Licensed hauler(s) will be used to transport contact water from on-site storage tanks to the facility.
- On May 9, comments were provided to AMEC-FW on a draft outline of the final report to be submitted at conclusion of project.

2.2.2 Issues
- Trespassing into work areas has increased with the Spring weather conditions. Site security was increased and personnel will be patrolling all construction areas during off hours and weekends.

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 site tour was provided to an interested neighbor on April 30.
- A presentation was made at the Otsego Historical Society on May 10.

2.5.3 Information Officer

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 - 40
Milbocker & Sons, Inc. - 3
Spicer Group, Inc. - 1
AMEC-FW - 2

TOTAL: 50

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 May 25.