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2.1.1 Narrative
The GC completed excavation of contaminated sediments & bank soils in BRSA 1, including two grids which contained levels of contamination exceeding 50 mg/kg PCBs, which were managed pursuant to TSCA regulations. Restoration activities continue throughout BRSA 1. Contaminated soils/sediments remaining on site are being loaded out for transport & disposal at EPA approved landfill facilities. Decommissioning and demobilization of the WWTP, heavy equipment, and infrastructure/materials are underway in BRSA 1, with completion expected in the next few weeks.
2.1.2 Response Actions to Date
The following activities took place during the reporting period:
- Excavation of contaminated sediments and bank soils in remaining grids of BRSA 1, including TSCA material (soils > 50 mg/kg total PCBs) from an area designated as 'T1' within grids 29 & 30. A special work plan was developed, submitted and approved for this area. These contaminated sediments & soils are staged on site awaiting transport for disposal;
- All 58 grids of BRSA 1 have now been excavated to the target clean-up goal of 5 mg/kg total PCBs in riverbank soils (see below table). Note that previous POLREPs 4-6, which contained portions of the table below, have been corrected to show actual excavation depths in all grids;
|
BRSA
1
GRID
|
TOTAL
EXCAVATION DEPTH (in)
|
FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
|
|
1
|
48
|
3.10
|
|
2
|
14
|
2.30
|
|
3
|
30
|
0.17
|
|
4
|
13
|
0.18
|
|
5
|
16
|
ND
|
|
6
|
21
|
0.49
|
|
7
|
21
|
0.34
|
|
8
|
12
|
0.51
|
|
9
|
13
|
0.14
|
|
10
|
12
|
0.24
|
|
11
|
8
|
0.064
|
|
12
|
11
|
0.032
|
|
13
|
19
|
ND
|
|
14
|
14
|
ND
|
|
15
|
18
|
ND
|
|
16
|
11
|
ND
|
|
17
|
9
|
0.22
|
|
18
|
17
|
0.27
|
|
19
|
36
|
ND
|
|
20
|
41
|
0.17
|
|
21
|
36
|
ND
|
|
22
|
36
|
0.5
|
|
23
|
37
|
0.15
|
|
24
|
37
|
0.17
|
|
25
|
35
|
ND
|
|
26
|
42
|
0.083
|
|
27
|
42
|
0.11
|
|
28
|
35
|
ND
|
|
29
|
40
|
ND
|
|
T1*
|
50
|
0.14
|
|
30
|
39
|
0.33
|
|
31
|
38
|
0.25
|
|
32
|
41
|
0.22
|
|
33
|
42
|
0.58
|
|
34
|
42
|
2.10
|
|
35
|
43
|
1.30
|
|
36
|
46
|
3.10
|
|
37
|
55
|
0.38
|
|
38
|
40
|
2.10
|
|
39
|
42
|
0.78
|
|
40
|
37
|
2.70
|
|
41
|
42
|
0.75
|
|
42
|
42
|
1.60
|
|
43
|
42
|
1.10
|
|
44
|
42
|
ND
|
|
45
|
39
|
ND
|
|
46
|
40
|
0.12
|
|
47
|
36
|
ND
|
|
48
|
38
|
ND
|
|
49
|
35
|
0.071
|
|
50
|
35
|
0.084
|
|
51
|
34
|
0.12
|
|
52
|
28
|
3.40
|
|
53
|
28
|
0.42
|
|
54
|
17
|
0.54
|
|
55
|
18
|
0.87
|
|
56
|
15
|
0.54
|
|
57
|
8
|
3.60
|
|
58
|
22
|
0.41
|
* Grid T1 was a polygon spanning Grids 29 & 30 that contained contaminated soils in excess of 50 mg/kg PCBs according to pre-design sampling. This area was managed in accordance with TSCA regulations, with excavated sediments/soils managed apart from other materials.
- Reconstruction / restoration / inspection of excavated grids in BRSA 1 (see attached photo);
- Transport/disposal of approximately 3212.90 tons of excavated sediments/soils to an EPA approved landfill facility. A total of 6186.14 tons of excavated sediments/soils have been transported from BRSA 1 for disposal to date;
- Treatment of contact water from contaminated grids and the contaminated soils staging pad in the on site WWTP. Approximately 55,970 gallons were treated during the reporting period. A total of approximately 263,726 gallons have been treated since the start of the project. Sampling results continue to confirm non-detect levels for total PCBs in treated water;
- Investigatory geotechnical borings to determine the stability of side slopes in BRSA 5 (see photograph);
- 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; and
- Turbidity control measures and monitoring in Kalamazoo River around the BRSA 1 with no sustained exceedances of the action level of 50 NTUs above upstream levels. As excavation activities have been completed, the turbidity monitors were removed from the river on November 8.
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. A new column has been added with project totals to date.
| Waste Stream |
Medium |
Quantity |
Total |
Manifest # |
Treatment |
Disposal |
| Cardboard |
solid |
100 lbs |
410 lbs |
NA |
recycling |
Otsego Recycling Center
|
| Plastic |
solid |
20 lbs |
120 lbs |
NA |
recycling |
Otsego Recycling Center |
| Steel |
solid |
4560 lbs |
4570 lbs |
various |
recycling |
Broken Arrow Recycling |
| Contaminated soil (< 50 ppm* PCBs) |
solid |
3212.90 tons |
6186.14 tons |
various |
disposal |
Republic Ottawa County Farms Landfill, Coopersville, MI |
Contaminated soil
(> 50 ppm* PCBs) |
solid |
tons |
tons |
|
disposal |
US Ecology Michigan,
Belleville, MI |
| Contact water |
liquid |
55,970 gal |
263,726 gal |
NA |
on-site WWTP |
On-site reuse/discharge to Kalamazoo River |
Note: 1 ppm = 1 mg/kg
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