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
Excavation of contaminated riverbank soils is complete in BRSA 3. Contaminated soils/sediments continue to be loaded out for transport & disposal. Preparation for excavation activities in BRSA 4 continues, with installation of coffer dams in the river to isolate in-stream sediments requiring removal.

2.1.2 Response Actions During Reporting Period
- Excavation of contaminated soils with confirmation sampling results received from remaining grids (10-18) in BRSA 3 (see table below for clearance sampling results). There were 18 total grids in BRSA 3, 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;

Note: Confirmatory sampling takes place immediately following excavation of contaminated soils in accordance with procedures outlined in the Field Sampling Plan and the Technical Memorandum for BRSA 3. Both documents can be found in the ‘Documents' Section of the project website.

- Transport/disposal of approximately 1847 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4);

- Treatment of approximately 39,000 gallons of contact water from contaminated grids and contaminated soils staging pad in the on site WWTP (see Section 2.1.4). Sampling results continue to confirm non-detect levels for total PCBs in treated water;

- Construction of both sand bag and steel sheet pile coffer dams in BRSA 4 to prepare for contaminated riverbank soil & in-stream sediment removal (see photo);

- Daily particulate monitoring (PM10) around the site perimeter with no sustained exceedance off site of particulates above the action level of 1.5 mg/m3;

- Turbidity control measures and monitoring in Kalamazoo River around the BRSA 3 - 9 excavation area (1 upstream monitor and 2 downstream monitors), with no sustained exceedance of the action level of 50 NTUs above upstream levels; and

- Monitoring & maintenance of the 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 3
- Reconstruct & restore riverbanks;
- Complete transport of contaminated sediments & bank soils for disposal; and
- Decommission and demobilize WWTP along with other equipment from staging area.

BRSA 4
- Complete construction of staging area, stabilization pad & on site WWTP; and
- Continue installation of sand bag and steel sheet pile coffer dams to prepare for excavation of contaminated sediments.

SITEWIDE
- Operate dust and turbidity control/monitoring systems; and
- Maintain/monitor temporary WCS.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2

2.2.1.2 Administrative Activities / Next Steps
- Planning discussions continue on a draft TM for BRSAs 7 & 8, which include plans for removal of the temporary WCS.
- On May 19, US EPA responded to a May 12 letter from MDEQ concerning the proposed approach in BRSAs 7 & 8 (see 'documents' section).
- US EPA met with representatives of Michigan Gas Utilities on May 16 to discuss a proposed natural gas line installation that may impact the area in the vicinity of the project command center located at 2063 Covault Lane.
- AMEC-FW submitted a revised draft TM for BRSAs 4, 5, 6 & 9 for review and approval on May 24. The TM components dealing with BRSA 4 were already conditionally approved on April 10, so review is only focused on the TM sections relating to BRSAs 5, 6 & 9.
- Draft restoration plan proposals for the spillway area adjacent to the temporary WCS (BRSA 8 entrance), and the end of 19th Street (BRSA 6 entrance) were prepared by START in coordination with Michigan DNR and Allegan County Road Commission for incorporation into draft TM documents.

2.2.2 Issues
Four representatives of a local labor union began sporadic demonstration activity at the entrances of BRSA 3 on May 16 and BRSA 4 on May 25. Though this activity has not impacted work progress, it has presented a safety hazard with respect to traffic both passing by and entering/exiting the staging area(s).

2.5.1 Safety Officer

A safety meeting is held prior to start of work each day. The meeting is led by on-site safety officer(s) representing both Envirocon and AMEC-FW.

2.5.2 Liaison Officer

OSC Ruesch met with union business representative Joseph Schippa on May 16 to inform him of current site activities and relay concerns about traffic safety in the vicinity of staging area entrances as well as for traffic along Lincoln Road (M-89). US EPA notified Michigan DNR, Michigan DEQ, Allegan County Sheriff, Otsego City Police, Michigan DOT, Allegan County Road Commission, property owners, and neighboring residents of the union activity on May 16-17.

2.5.3 Information Officer
A flyer was distributed door to door to neighbors in the vicinity of BRSA 4 notifying them of the possibility of increased noise from steel sheet pile installation.

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
START - 1
Michigan DNR - 1
Michigan DEQ - 1
Envirocon: 24
AMEC-FW: 2
Spicer Group: 1

TOTAL: 31

6.1 Internet location of additional information/report

http://www.epaosc.org/otsegodam

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

6.2 Reporting Schedule
The next PolRep will be generated on June 9.