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
- Completed removal of staging pad and began restoration of surrounding area; and
- Dismantled and removed WWTP.

BRSA 7
- Transportation and disposal of contaminated soils & sediments;
- Continue re-grading and restoration of riverbanks; and
- Maintenance of stream tube protection measures.

BRSA 8
- Continue re-grading and restoration of riverbanks (see photo).

OVERALL SITE
- Transport/disposal of approximately 364 tons of excavated soils to an approved landfill facility (see Section 2.1.4);
- Dust control measures and particulate monitoring (PM10) around site perimeter with no sustained exceedance of particulates above action level of 1.5 mg/m3;
- In-stream turbidity monitoring with no sustained exceedances observed;
- Shipment of approximately 16,945 gallons of contact water from contaminated grids and/or contaminated soils staging pad at BRSA 7 to an approved off-site treatment facility (see photo & Section 2.1.4);
- Spraying for invasive plants in all BRSAs (see photo);
- Commenced construction of an irrigation system in all completed BRSAs for planted native plants/grasses; and
- Continued restoration activities (grading, contouring) of area at former temporary WCS.

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
- Continue restoration of staging area.

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 from temporary storage tanks for treatment at off-site WWTP; and
- Transport contaminated soils & sediments for disposal.

BRSA 8
- Continue 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
- A driveway permit application was submitted to Allegan County Roads Commission for a new entrance off of River Road into the BRSA 8 / former auxiliary spillway area on May 24;
- AMEC-FW submitted final draft restoration figures for construction entrances at BRSA 3, 6, 7, 8, 9, the former auxiliary spillway area, and the Command Center on May 22. The plans were approved with comments by US EPA on May 23.
- US EPA provided comments on a draft Post-Removal Site Control Plan to AMEC-FW on May 25. This plan provides plans for monitoring and maintenance of restored areas once work is completed to ensure riverbanks are stable and native plantings survive.

2.2.2 Issues
Excessive rainfall and corresponding elevated river levels delayed work for several days.

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. Site surveillance is being conducted during weekends to discourage trespassing into work areas and restored river bank areas. A 'man down' drill was held on May 22 in BRSA 8, with Otsego Fire Department and Emergency Medical Services responding. The exercise was a drill only and no one was actually hurt.

2.5.2 Liaison Officer
A site tour was provided to 15 members of the Kalamazoo River Watershed Coalition on May 21.

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 - 36
ProAct Services - 2
Grand Rapids Irrigation - 2
Milbocker & Sons, Inc. - 2
Cardno - 2
K & D Industries West Inc. - 2
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 June 8.