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 #28
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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11/10/2017
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Reporting Period:
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10/28/2017 - 11/10/2017
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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
Removal operations were completed in BRSA 6 and are near completion in BRSA 9. Hydraulic dredging of a pilot channel to support removal and restoration operations in BRSAs 7 & 8 was completed. Construction of access roads and sheet piling in BRSAs 7 & 8 continues. All stop logs were removed from the temporary WCS.
2.1.2 Response Actions During Reporting Period
BRSAs 3 & 4
- Re-planted trees and shrubs impacted by elevated water levels.
BRSA 6
- Excavation of contaminated soils was completed with confirmation results shown in Table 1. There were 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;
- Maintenance, cleaning and activated carbon change out in WWTP (see Section 2.2.1.2); and
- Continue transportation & disposal of contaminated soils and sediments.
The estimated excavation depth and confirmation sampling result is found below for the final riverbank grid (Table 1).
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BRSA 6
RIVERBANK GRID
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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54
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24
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1.1
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Table 1. BRSA 6 Riverbank
Grid Confirmatory Sampling Results
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Table Notes: Confirmatory sampling takes place immediately following excavation of contaminated soils and/or sediments in accordance with procedures outlined in the FSP and the TM for BRSAs 4, 5, 6 & 9. Both documents can be found in the ‘Documents' Section of the project website. Stream Tube grids are numbered consistent with the riverbank grid they are located adjacent to. A figure showing the location of both (preliminary) riverbank grids and stream tubes can be found on Figure 8 of the BRSA 4, 5, 6 & 9 TM.
BRSAs 7 & 8
- Hydraulic dredging was completed to construct a 'pilot channel' in front of the temporary WCS;
- Hydraulic dredging equipment was removed from the river and demobilized from the site;
- Completed construction of sheet pile coffer dam system along BRSA 7 riverbank (see photo);
- Completed drawdown of water levels by removing all stop logs from temporary WCS, with concurrence from MDEQ & MDNR, allowing better access for construction along the riverbanks;
- Continued construction of access roads along riverbanks; and
- Maintenance & monitoring of turbidity curtain downstream of temporary WCS and old auxiliary spillway to control downstream turbidity.
BRSA 9
- Excavation of contaminated soils continued with excavation completed and confirmation results received in riverbank grids and stream tube grids shown in the tables below. There are 38 total river bank grids in BRSA 9, with each grid consisting of approximately 50 lineal feet of riverbank. There are now 3 stream tubes, with each stream tube varying in size, as an extra stream tube was added adjacent to river bank grids 30-32. The target clean-up goal in the riverbank soils is 5 mg/kg total PCBs and in-stream sediments is 1mg/kg total PCBs; and
- Continued transportation and disposal of contaminated soils and sediments;
Estimated excavation depths and confirmation sampling results are found below for riverbank grids in BRSA 9 (Table 2), and stream tube grids (Table 3).
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BRSA 9
RIVERBANK GRID
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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30
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12
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< 0.031
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31
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12
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TBD
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32
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12
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TBD
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33
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12
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TBD
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34
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12
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TBD
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35
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12
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TBD
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36
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6
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0.76
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37
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6
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0.092
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38
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6
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0.064
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Table 2. BRSA 9
Riverbank Grid Confirmatory Sampling Results
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BRSA 9
STREAM TUBE
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TOTAL ESTIMATED EXCAVATION DEPTH (in)
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FINAL
CONFIRMATION TOTAL PCBs RESULT (mg/kg)
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12A-30
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12
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< 0.037
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12A-31
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TBD
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TBD
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12A-32
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TBD
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TBD
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11A-33
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TBD
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TBD
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11A-34
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12
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< 0.079
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11A-35
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12
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0.15
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11A-36
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12
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0.16
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11A-37
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12
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< 0.038
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Table 3. BRSA 9
Stream Tube Confirmatory Sampling Results
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Table Notes: Confirmatory sampling takes place immediately following excavation of contaminated soils and/or sediments in accordance with procedures outlined in the FSP and the TM for BRSAs 4, 5, 6 & 9. Both documents can be found in the ‘Documents' Section of the project website. Stream Tube grids are numbered consistent with the riverbank grid they are located adjacent to. A figure showing the location of both (preliminary) riverbank grids and stream tubes can be found on Figure 8 of the BRSA 4, 5, 6 & 9 TM.
OVERALL SITE
- Transport/disposal of approximately 168 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 111,450 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 WWTPs in BRSAs 6 & 9 continue to show non-detect levels for PCBs in the treated discharge; and
- Monitoring of the temporary WCS. All stop logs were removed to lower water levels.
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 |
20 lbs |
1080 lbs |
NA |
recycling |
Otsego Recycling Center
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| Plastic |
solid |
50 lbs |
475 lbs |
NA |
recycling |
Otsego Recycling Center |
| Steel |
solid |
9480 lbs |
21,720 lbs |
various |
recycling |
Broken Arrow Recycling |
| Contaminated soil (< 50 ppm* PCBs) |
solid |
168 tons (est) |
30,451 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 |
111,450 gal |
1,632,126 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:
BRSA 6
- Continue backfilling & restoration of excavated riverbank grids;
- Treat contact water from contaminated grids & contaminated soils staging pad;
- Remove sand bag and sheet pile coffer dams; and
- Continue transport contaminated soils & sediments for disposal.
BRSAs 7 & 8
- Continue access road construction along river banks;
- Complete construction of sheet pile coffer dams; and
- Begin excavation of contaminated soils & sediments.
BRSA 9
- Complete excavation of remaining riverbank grids and stream tubes;
- Continue backfilling & restoration of excavated riverbank grids;
- 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
- Discussions continue on proposed plans to remove the temporary WCS and restore the area.
- AMEC-FW submitted final draft TM for BRSAs 7 & 8 to US EPA for review on October 27. The document was approved on October 30.
- AMEC-FW submitted a letter to MDEQ on November 1 with formal notification of non-compliance and corrective action for the WWTP in BRSA 6. The document can be found in the 'Documents' section of the project website. An exceedance to the discharge limit of ND was previously reported incorrectly as 0.29 ppm total PCBs. The actual exceedance was detected at 0.29 ppb total PCBs. The activated carbon was replaced and WWTP operations have been returned to normal.
2.2.2 Issues
High water levels resulting from excessive rainfall events continues to slow progress as repairs & maintenance were needed along riverbanks 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 & AMEC-FW.
2.5.2 Liaison Officer
The Allegan County Sheriff's Office dive team conducted a training for all site personnel on proper planning, equipment and tactics for conducting a river rescue on November 2 (see photo).
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 - 1
START - 1
MDNR - 1
MDEQ - 1
Envirocon - 44
White Lake Dock & Dredge, Inc. - 3
Milbocker & Sons, Inc. - 4
SWAT - 2
AMEC-FW
- 3
Spicer Group - 1
TOTAL: 61
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5. Definition of Terms
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AMEC-FW AMEC Foster Wheeler
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
ppb parts per billion
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 24.
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7. Situational Reference Materials
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No information available at this time.
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