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 continue in BRSA 7 and restoration operations continue in BRSAs 6, 8 & 9.

2.1.2 Response Actions During Reporting Period

BRSA 6
- Continued restoration of construction entrance & staging area; and
- Continue restoration (plantings) on river bank (see photo). All plastic pots from trees & shrubs are being recycled.

BRSA 7
- Excavation of contaminated soils and sediments continues (see photo) with confirmation results received in the riverbank grids and stream tube grids shown in Tables 1 & 2 below. There are 63 total river bank grids in BRSA 7, with each grid consisting of approximately 50 feet of riverbank. There are 3 stream tubes, with each varying in size. The target clean-up goal in riverbank soils is 5 mg/kg total PCBs and in-stream sediments is 1mg/kg total PCBs;
- Transportation and disposal of contaminated soils & sediments;
- Re-grading and restoration of excavated riverbanks; and
- Maintenance of stream tube protection measures.

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 1-7 of the BRSA 7 & 8 TM.

BRSA 8
- Continue re-grading and restoration of riverbanks.

BRSA 9
- Removal of entrance off Jefferson Road (see photo); and
- Restoration of staging area.

OVERALL SITE
- Transport/disposal of approximately 1132 tons of excavated soils to an approved landfill facility (see Section 2.1.4);
- Dust control measures and particulate monitoring (PM10) around site perimeter with no sustained exceedance of particulates above action level of 1.5 mg/m3;
- In-stream turbidity monitoring with no sustained exceedances observed;
- Shipment of approximately 13,813 gallons of contact water from contaminated grids and/or contaminated soils staging pad at BRSA 7 to an approved off-site treatment facility (see Section 2.1.4);
- Completed construction of an irrigation system in all completed BRSAs for planted native plants/grasses; and
- Continued restoration activities (grading, contouring) of area at former temporary WCS, including construction of a new entrance off River Road.

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
- Complete restoration of staging area; and
- Complete restoration of entrance to staging area off 19th Street.

BRSA 7
- Complete access road construction (using plastic mats) along riverbanks into remaining riverbank grids & stream tubes;
- Continue excavation of contaminated riverbank soils and in-stream sediments;
- Re-construct and restore riverbanks;
- Collect contact water from contaminated grids, stream tubes and staging pad in temporary storage tanks;
- Transport contact water from temporary storage tanks for treatment at off-site WWTP; and
- Transport contaminated soils & sediments for disposal.

BRSA 8
- Complete re-construction and restoration of riverbanks.

SITEWIDE
- Operate dust and turbidity control/monitoring systems;
- Continue irrigation of native trees/plants/grasses in restored areas;
- Commence river channel contouring with specialized excavator; and
- Continue restoration of area surrounding the former temporary WCS and auxiliary spillway and complete construction of public access / parking area off of River Road.

2.2.1.1 Planned Response Activities

See Sections 2.2.1 & 2.2.1.2

2.2.1.2 Administrative Activities / Next Steps
- A driveway permit was issued by Allegan County Roads Commission for a new entrance off of River Road into the BRSA 8 / former auxiliary spillway area on May 30 (see Section 2.2.1).
- AMEC-FW is addressing comments on the Post Removal Site Control Plan.

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. Site surveillance continues during weekends to discourage trespassing into work areas and restored river bank areas.

2.5.2 Liaison Officer

2.5.3 Information Officer

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 - 2
MDNR - 1
MDEQ - 1
Envirocon - 38
Grand Rapids Irrigation - 2
Milbocker & Sons, Inc. - 2
MJ VanDamme Inc. - 1
K & D Industries West Inc. - 1
Spicer Group, Inc. - 1
AMEC-FW - 2

TOTAL: 52

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 June 22.