U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Otsego Township Dam Area - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #27
Progress
Otsego Township Dam Area
059B
Otsego Township, MI
Latitude: 42.4601694 Longitude: -85.7199333
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To:
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Douglas Ballotti, EPA
Samuel Borries, EPA
Mike Ribordy, EPA
Jim Saric, EPA
Mark Mills, MDNR
Polly Synk, MDAG
Cyndi Trobeck, City of Otsego
Valincia Darby, U.S. DOI
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From:
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Paul Ruesch, OSC
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Date:
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10/27/2017
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Reporting Period:
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10/14/2017 - 10/27/2017
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1. Introduction
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1.1 Background
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Site Number: |
059B |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
4/6/2016 |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
NPL |
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Operable Unit: |
5 |
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Mobilization Date: |
8/1/2016 |
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Start Date: |
8/1/2016 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
MID006007306 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
DEQ |
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FPN#: |
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Reimbursable Account #: |
059B |
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
See PolRep #1
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Restoration with native plantings continues in BRSAs 3 & 4. Removal operations are near completion in BRSAs 6 & 9. Hydraulic dredging of a pilot channel to support removal and restoration operations continues in BRSAs 7 & 8, with heavy rain and high water levels (see photos) preventing progress.
2.1.2 Response Actions During Reporting Period
BRSAs 3 & 4
- Completed planting native trees and shrubs along river banks, with the exception of live willow stakes.
BRSA 6
- Excavation of contaminated soils continues in Grid 54, which requires additional excavation to meet the target clean-up goal. There are 54 total grids in BRSA 6, with each grid consisting of approximately 50 lineal feet of riverbank. There were 4 stream tubes, with each stream tube varying in size. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs and in-stream sediments is 1mg/kg total PCBs;
- Restoration of riverbanks along excavated grids; and
- Continued transportation and disposal of contaminated soils and sediments.
BRSAs 7 & 8
- Hydraulic dredging continues to construct a 'pilot channel' in front of the temporary WCS;
- Removed or added stop logs at temporary WCS, with concurrence from MDEQ & MDNR, to lower or raise water levels, allowing better access for construction;
- Clearing of trees along access roads;
- Construction of access roads along riverbanks; and
- Maintenance and monitoring of turbidity curtain downstream of temporary WCS and old auxiliary spillway to control downstream turbidity (cloudiness in water caused by sand/dirt/clay particles) which may result from hydraulic dredging operations.
BRSA 9
- Excavation continues in remaining grids though progress was impeded by elevated water levels. (see photos). There are 38 total river bank grids in BRSA 9, with each grid consisting of approximately 50 lineal feet of riverbank; and
- Continued transportation and disposal of contaminated soils and sediments.
OVERALL SITE
- Transport/disposal of approximately 1131 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4).
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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 the Kalamazoo River downstream of project area (1 upstream monitor and 2 downstream monitors), with no sustained exceedance of the action level of 50 NTUs;
- Treatment of approximately 137,890 gallons of contact water from contaminated grids and contaminated soils staging pads in on-site WWTPs located in BRSAs 6 & 9 (see Section 2.1.4). Sampling results from the WWTP in BRSA 6 indicated an exceedance in the permissible discharge limit for PCBs (ND) of 0.29 ppm. The system was shut down for maintenance and change out of activated carbon vessel(s). Discharged water was being collected in storage tanks at the time and was not discharged to the Kalamazoo River. Sampling results from the WWTP in BRSA 9 continued to show non-detect levels for PCBs in the treated discharge; and
- Monitoring of the temporary WCS. Stop logs continue to be added or removed depending on the operational and navigational needs of the hydraulic dredging rig constructing the pilot channel.
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.
| Waste Stream |
Medium |
Quantity |
Total |
Manifest # |
Treatment |
Disposal |
| Cardboard |
solid |
0 lbs |
1060 lbs |
NA |
recycling |
Otsego Recycling Center
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| Plastic |
solid |
0 lbs |
425 lbs |
NA |
recycling |
Otsego Recycling Center |
| Steel |
solid |
0 lbs |
12,240 lbs |
various |
recycling |
Broken Arrow Recycling |
| Contaminated soil (< 50 ppm* PCBs) |
solid |
1131 tons (est) |
30,283 tons est) |
various |
disposal |
Republic Ottawa County Farms Landfill, Coopersville, MI |
Contaminated soil
(> 50 ppm* PCBs) |
solid |
0 tons |
103.91 tons |
various |
disposal |
US Ecology Michigan,
Belleville, MI |
| Contact water |
liquid |
137,890 gal |
1,520,676 gal |
NA |
on-site WWTP |
On-site reuse/discharge to Kalamazoo River |
*Note: 1 ppm = 1 mg/kg
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2.2 Planning Section
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2.2.1 Anticipated Activities
During the next reporting period, the following activities are expected to occur:
BRSAs 3 & 4
- Re-plant native plantings impacted by elevated water levels.
BRSA 6
- Continue backfilling & restoration of excavated riverbank grids;
- Treat contact water from contaminated grids & contaminated soils staging pad;
- Perform maintenance, cleaning and activated carbon change out in WWTP;
- Begin removal of sheet pile coffer dams; and
- Complete transport contaminated soils & sediments for disposal.
BRSAs 7 & 8
- Continue hydraulic dredging of pilot channel;
- Continue tree-clearing as needed for access to river banks;
- Continue drawdown of water levels by adding or removing stop logs from temporary WCS;
- Continue monitoring & maintenance of dredging spoils fill area; and
- Continue access road construction along river banks.
BRSA 9
- Continue backfilling & restoration of excavated riverbank grids;
- Complete excavation of contaminated soils & sediments;
- Treat contact water from contaminated grids & contaminated soils staging pad; and
- Transport contaminated soils & sediments for disposal.
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
- US EPA will discuss proposed plans to remove of the temporary WCS and restore the area with the PRPs and agencies on November 7.
- Wood Group submitted final draft TM for BRSAs 7 & 8 to US EPA for final review on October 27.
2.2.2 Issues
Excessive rainfall events resulted in high water levels which inundated all work areas (see photos), slowing or completely stopping work progress for several days during the operational period. Repairs and maintenance will need to be performed along river banks prior to re-starting work.
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2.3 Logistics Section
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See PolRep #1
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
A safety meeting is held prior to work start each day by on-site safety officer(s) from Envirocon & Wood Group.
2.5.2 Liaison Officer
2.5.3 Information Officer
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3. Participating Entities
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3.1 Unified Command
3.2 Cooperating Agencies
See PolRep #1
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4. Personnel On Site
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On average, the following personnel were present on site during the reporting period:
US EPA - 0
START - 1
MDNR - 1
MDEQ - 1
Envirocon - 44
White Lake Dock & Dredge, Inc. - 3
Milbocker & Sons Construction, Inc. - 0
SWAT - 2
Toads Tree Service - 2
Wood Group
- 3
Spicer Group - 1
TOTAL: 58
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5. Definition of Terms
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BRSA Bank Removal and Stabilization Area
FSP Field Sampling Plan
mg/kg milligrams per kilogram
MDEQ Michigan Department of Environmental Quality
MDNR Michigan Department of Natural Resources
ND Non-Detect
OSC On Scene Coordinator
PCBs Poly-chlorinated biphenyls
PolRep Pollution Report
ppm parts per million
PRP Potentially Responsible Party
START Superfund Technical Assessment & Response Team (US EPA contractor)
TM Technical Memorandum
US EPA United States Environmental Protection Agency
WCS Water Control Structure
WWTP Waste Water Treatment Plant
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6. Additional sources of information
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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 November 10.
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7. Situational Reference Materials
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No information available at this time.
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