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 continues excavating contaminated sediments and bank soils and restoring excavated grids in BRSA 1. Contaminated material is being loaded out from the staging pad for transport & disposal at an EPA approved landfill facility.

 2.1.2 Response Actions to Date

The following activities took place during the reporting period:

- Excavation of contaminated soils with confirmation sampling results received from grids 13 - 28 (see table below for results). A total of 58 grids have now been staked in BRSA 1, with each grid consisting of approximately 50 lineal feet of riverbank. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs.

 ND = non-detect

- Reconstruction / restoration of excavated grids in BRSA 1 (see attached photo);

- Transport/disposal of approximately 1,541.68 tons of excavated soils to an EPA approved landfill facility (see attached photo);

- Treatment of contact water from contaminated grids and the contaminated soils staging pad in the on site WWTP. Approximately 19,035 gallons were treated during the reporting period. A total of approximately 155,188 gallons have been treated since the start of the project. Sampling results continue to confirm non-detect levels for Total PCBs in treated water.

- 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;

- Turbidity control measures and monitoring in Kalamazoo River around the BRSA 1 excavation area (1 upstream monitor and 2 downstream monitors) with no sustained exceedances of the action level of 50 NTUs above upstream levels;

- Mussel survey/relocation efforts were completed on September 23 in BRSA 5 and most of BRSA 6 due to the seasonal limit on when this type of work can be conducted. All mussels were measured, tagged, and relocated to suitable habitat upstream of the M-89 bridge. Work will continue in Spring of 2017 to complete relocation in BRSAs 6 thru 9; and

- Maintenance (clearing debris) and removal of stop logs (see attached photo) in the temporary water control structure to lower Kalamazoo River water levels in the work area.

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.

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

- Excavation of contaminated sediments and bank soils in remaining grids of BRSA 1, including TSCA material (soils > 50 mg/kg total PCBs) from grid 29;

- Reconstruction & restoration of excavated grids in BRSA 1;

- Solidification/staging/transport of contaminated sediments & bank soils for disposal;

- Treatment of contact water in the on site WWTP;

- Operation of dust and turbidity 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
- Plans are under development for removal operations in BRSAs 2 & 3. A Technical Memorandum outlining the approach for BRSAs 2 & 3 will be submitted by October 21 (an extension from the original October 14 due date was requested and approved). Work in BRSAs 2 & 3 is expected to commence later this year.

2.2.2 Issues

None

2.5.1 Safety Officer

See PolRep #1

2.5.2 Liaison Officer

 A contractor to the PRPs visited BRSA 1 on October 6 to discuss planning for 'crisis communications' in the event of an accident or contingency at the site. 

Now that removal operations are underway, site visits/tours are being requested and scheduled for local elected officials, agencies and other organizations.

2.5.3 Information Officer

The OSC and CIC are 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 - 1

Michigan DNR - 1

START - 1

Envirocon: 20

AMEC-FW: 3

Spicer Group: 1

TOTAL: 28

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

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.