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
Removal operations in BRSA 8 were completed. Removal operations in BRSA 7 continue along with removal of the temporary WCS.

2.1.2 Response Actions During Reporting Period

BRSA 7
- Transportation and disposal of contaminated soils & sediments (utilizing the staging pad in BRSA 6);
- Re-grading and restoration of riverbank grids;
- Tree clearing operations to facilitate access road construction to access remaining riverbank and stream tube grids; and
- Maintenance and repair of stream tube protection measures and access roads.

BRSA 8
- Excavation of contaminated soils and sediments was completed, with confirmation results received in riverbank grids and stream tubes shown in Tables 1 & 2 below. There were 63 total river bank grids in BRSA 8, with each grid consisting of approximately 50 lineal feet of riverbank. There were 3 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; 
- Transportation and disposal of contaminated soils & sediments (utilizing the staging pad in BRSA 9); and
- Re-grading and restoration of riverbank grids.

General 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 7 & 8. 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 1-8 of the BRSA 7 & 8 TM.

OVERALL SITE
- Transport/disposal of approximately 2,349 tons of excavated soils to an EPA-approved landfill facility (see Section 2.1.4);
- Particulate monitoring (PM10) around the site perimeter (when feasible) with no sustained exceedance off site of particulates above the action level of 1.5 mg/m3;
- Turbidity monitors were re-installed in the river. No sustained exceedances were observed;
- Treatment of approximately 70,710 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 both WWTPs continue to show non-detect levels for PCBs in the treated discharge; 
- Temporary WCS removal activities continue on the south bank of the river (see photo); and
- Bank re-grading and restoration continues on the north bank of the river at 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 6
- Staging pad and WWTP operations to support removal operations in BRSA 7.

BRSA 7
- Access road construction along riverbanks;
- Construction of a staging pad, load out area and temporary storage tanks for contact water adjacent to command post;
- Continue excavation of contaminated riverbank soils and in-stream sediments;
- Treat contact water from contaminated grids, stream tubes and staging pad (located in BRSA 6); and
- Transport contaminated soils & sediments for disposal.

BRSA 8
- Re-construction and restoration of riverbanks; and
- Transport contaminated soils & sediments for disposal.

BRSA 9
- Dismantlement, cleaning and removal of WWTP; and
- Staging pad operations to support restoration operations in BRSA 8.

SITEWIDE
- Operate dust and turbidity control/monitoring systems;
- Complete removal of temporary WCS; and 
- Continue restoration of surrounding area.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2

2.2.1.2 Administrative Activities / Next Steps
- The end date of the 'Application/Permit to Use State Land' (#ASGA-17-010) for activities at the command post area located at 2063 Covault Lane was extended until 9/30/2018. This area will be utilized as a staging area for BRSA 7 removal operations beginning in April 2018.

2.2.2 Issues

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

2.5.3 Information Officer
- Various press (television crews, photographers and reporters) visited the site on March 26, 28 & 29.
- A presentation was provided to seventh graders participating in the STREAM program at the Otsego Middle School on March 27. A site tour was provided immediately following the presentation (see photo). The presentation and field visit were part of a series of interactions between site personnel and students participating in the STREAM program.

3.1 Unified Command

3.2 Cooperating Agencies

See PolRep #1

On average, the following personnel were present on site during the reporting period: 

USEPA - 1
START - 1
MDNR - 1
MDEQ - 1
Envirocon - 39
Milbocker & Sons, Inc. - 3
Spicer Group, Inc. - 1
AMEC-FW - 2

TOTAL: 49

6.1 Internet location of additional information/report

https://response.epa.gov/otsegodam

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

6.2 Reporting Schedule
The next PolRep will be generated on April 13.