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1. Introduction
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1.1 Background
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Site Number: |
059B05 |
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Contract Number: |
EP-S5-08-02 |
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D.O. Number: |
0087 |
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Action Memo Date: |
7/5/2011 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
NPL |
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Operable Unit: |
05 |
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Mobilization Date: |
9/26/2011 |
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Start Date: |
8/30/2011 |
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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: |
NA |
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ERNS No.: |
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State Notification: |
Yes |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Fund-lead removal action
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
Dredging operations in SA5D (Upjohn Park) continued during this reporting period. Contaminated sediment removal and backfilling was completed in grids SA5D-9 to SA5D-13 by September 14. Visible gross contamination and elevated PCB test results at target excavation depths (see Sections 2.1.2 and 2.2.2) required additional excavation to meet the clean-up performance standard. Preparations are underway to begin dredging operations in SA5C immediately following completion of dredging/backfilling operations in SA5D.
2.1.2 Response Actions to Date
From September 1 to September 14, EPA, START and ERRS contractors conducted the following activities:
Site Activities - SA5D & SA5C
- Excavated contaminated sediments from grids SA5D-9 to SA5D-13 (see table below for details) and placed backfill materials / coir logs according to the site restoration plan;
- Conducted pre-construction soil sampling in SA5C on east bank working area;
- Fenced in working area in SA5C;
- Installed wooden platform working surface in SA5C on east bank between Crosstown Parkway and Vine Street to support heavy equipment;
- Installed sediment controls in creek channel in SA5C; and
- Began installation of isolation groundwater de-watering system in SA5C.
| GRID |
TOTAL ESTIMATED EXCAVATION DEPTH (in) |
FINAL
CONFIRMATION PCB RESULT (mg/kg) |
| SA5D-9 |
60 |
0.13 |
| SA5D-10 |
60 |
0.045 |
| SA5D-11 |
60 |
ND |
| SA5D-12 |
50 |
0.14/
0.11 (dup) |
| SA5D-13 |
60 |
ND |
ND: non-detect dup: duplicate sample location
Site Activities - Axtell Creek
- Installed coir logs on creek banks.
Site Activities - Staging Pad
- Solidified and loaded out 1031.44 tons of TSCA (> 50ppm PCBs) contaminated sediments for disposal at Wayne Disposal landfill in Belleville, Michigan;
- Solidified and loaded out 685.91 tons of non-TSCA (< 50ppm PCBs) contaminated sediments for disposal at C&C Landfill in Marshall, Michigan; and
- Treated 7,190 gallons of potentially contaminated contact water in EPA's mobile wastewater treatment plant, with a total of 478,273 gallons treated to date.
Project Management Activities
- Continued weekly progress meetings with City of Kalamazoo;
- Conducted data validation for additional post-removal confirmation sediment samples collected from SA5D;
- Conducted site walks in SA5A & SA3A to plan for contaminated sediment removal operations in 2013;
- Requested site access from property owner of residences on west bank of SA5A;
- Solicited bids for clearing and grubbing in SA5A;
- Reviewed post-excavation structural assessment for SA6;
- Begin development of seasonal site shut-down / demobilization plan; and
- Began discussions with property owners in SA3A regarding site access, preparation and restoration.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The major PRP for this portion of the Allied Paper Inc./Portage Creek/Kalamazoo River Superfund site was dissolved through bankruptcy proceedings in April 2010. Other PRPs are being evaluated.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
TSCA contaminated
sediments |
solidified sediment |
1031.44 tons |
009077467JJK
to
009077487JJK |
disposal |
Wayne Disposal, Belleville, MI |
| Non-TSCA contaminated sediments |
solidified sediment |
685.91 tons |
NTSCA-145
to
NTSCA-158 |
disposal |
C&C Landfill, Marshall MI |
| Scrap metal |
solid |
480 lbs |
NA |
recycling |
Shupan Recycling |
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2.2 Planning Section
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A summary of removal activities that will take place from September 15 through September 28 include:
Site Activities - Staging Pad
- Continue de-watering and solidification of excavated sediments for transport;
- Continue transport of solidified sediments for disposal; and
- Continue treatment of contaminated water in EPA's mobile waste water treatment plant.
Site Activies - SA7 & SA6
- Conduct restoration work (seeding, fertilizing, tree & brush planting) according to Restoration Plan.
Site Activities - SA5D & SA5C
- Excavate, solidify and transport for disposal contaminated sediments from Portage Creek in grids SA5D-13 to SA5D-17 (between the Upjohn Park footbridge and Crosstown Parkway);
- Backfill and install coir logs in grids SA5D-13 to SA5D-17 according to Restoration Plan;
- Complete installation of isolation groundwater de-watering system in SA5C; and
- Excavate, solidfy and transport for disposal contaminated sediments from Portage Creek in grids SA5C-1 to SA5C-7 (between Crosstown Parkway and Vine Street).
Project Management Activities
- Continue weekly progress meetings with City of Kalamazoo;
- Conduct pre-construction samplinog and contaminated sediment confirmation sampling of SA5A & SA3A; and
- Obtain access agreements for properties on west creek banks in SA5A and SA3A.
2.2.1 Anticipated Activities
See POLREP #2
2.2.1.1 Planned Response Activities
See above
2.2.1.2 Next Steps
See above
2.2.2 Issues
- Excavation of grids to initial target depths revealed visual paper pulp material. Therefore, many grids were over-excavated until that material was no longer visible. Grids SA5D-9 & SA5D-12 were sampled at the initial target depths (see table below), to verify that the suspected paper pulp material exceeded project performance standards. All confirmatory sample results from over-excavation in grids SA5D-9 to SA5D-13 were under the performance standard of 10 mg/kg as well as the performance standard goal of 1 mg/kg as listed below (see table).
| GRID |
INITIAL TARGET DEPTH (in) |
INITIAL PCB RESULT(mg/kg) |
OVER
DIG
(in) |
TOTAL ESTIMATED DEPTH (in) |
FINAL DEPTH PCB RESULT (mg/kg) |
| SA5D-9 |
30 |
1.02 |
30 |
60 |
0.13 |
| SA5D-10 |
30 |
-- |
30 |
60 |
0.045 |
| SA5D-11 |
42 |
-- |
18 |
60 |
ND |
| SA5D-12 |
42 |
2.45 |
8 |
50 |
0.14/0.11 (dup) |
| SA5D-13 |
12 |
-- |
48 |
60 |
ND |
ND: Non-detect dup: duplicate sample location
- The additional over-excavation in grids SA5D-9 to SA5D-13 in Portage Creek resulted in increased costs
and added expenses for personnel, equipment, transportation, disposal, sampling and backfill material.
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2.3 Logistics Section
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The current resources present on site during this reporting period include:
- Office trailers
- Portable restrooms and hand-washing stations
- Portable generators
- Submersible pumps
- Equipment storage container
- ERRS work crews and subcontractor work crews
- START sampling contractor
- Heavy equipment
- Water truck
- Street sweeper
- Mixing boxes
- Frac (water) tank
- Pressure wash trailer
- Bypass pumps and piping
- Sheet piling and steel bridge personnel support structures
- Mobile wastewater treatment plant
- Temporary steel bridge
- Monitoring Equipment
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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
Craig Thomas and Paul Ruesch serve as safety officer(s). The HASP is reviewed and signed by all site personnel. All new personnel, including sub-contractors, are provided a site orientation and safety briefing. Safety meetings are held each morning with all site workers.
Minor issues identified in the August 30 safety audit by Federal Occupational Health were addressed during this reporting period.
2.6 Liaison Officer
Craig Thomas and Paul Ruesch serve as liaison(s) with local officials and interested parties.
2.7 Information Officer
A local freelance photographer took photos of the excavation, creek bypass pumping and contaminated sediment removal load out operations for a documentary on Osprey in the Kalamazoo River system.
2.7.1 Public Information Officer
See Section 2.6
2.7.2 Community Involvement Coordinator
Don DeBlasio - U.S. EPA
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3. Participating Entities
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3.1 Unified Command
N/A
3.2 Cooperating Agencies
U.S. Environmental Protection Agency
Michigan Department of Environmental Quality
Michigan Department of Agriculture and Rural Development
Michigan Department of Natural Resources
U.S. Fish and Wildlife Service
City of Kalamazoo:
Department of Public Services
Parks and Recreation Department
Economic Development Department
Community Planning & Development
Public Safety Department
Fire Department
Police Department
ReDevelopment Department
Bronson Methodist Hospital
Kalamazoo Nature Center
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4. Personnel On Site
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U.S. EPA - 2
ERRS contractor (Environmental Quality Management, Inc) - 13
START contractor (Dynamac/Weston) - 1
CMC Contractors (excavation subcontractor) - 1
Rain for Rent (groundwater extraction subcontractor) - 3
Farm & Garden (fencing subcontractor) - 3
TOTAL PERSONNEL = 20
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5. Definition of Terms
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C&D - Construction and Demolition (waste)
ERRS - Emergency and Rapid Response Services
FOSC - Federal On Scene Coordinator
U.S. FWS - United States Fish and Wildlife Service
HASP - Health and Safety Plan
HDPE - High density polyethylene (plastic)
mg/kg - milligrams per kilogram
mg/m3 - milligrams per cubic meter
MDARD - Michigan Department of Agriculture and Rural Development
MDEQ - Michigan Department of Environmental Quality
NA - Not Applicable
NOAA - National Oceanic and Atmospheric Administration
NPL - National Priorities List
NRDA - Natural Resource Damage Assessment
ntu - nephelometric turbidity units
PCB - polychlorinated biphenyl
ppm - parts per million
PRPs - Potentially Responsible Parties
RTK GPS - Real Time Kinematic Global Positioning System
SA - Slope Area
START - Superfund Technical Assessment and Response Team
U.S. EPA - United States Environmental Protection Agency
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6. Additional sources of information
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6.1 Internet location of additional information/report
See the project website at http://www.epaosc.org/portagecreekarea.
6.2 Reporting Schedule
The next POLREP will be generated in approximately 2 weeks.
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7. Situational Reference Materials
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See the project website at http://www.epaosc.org/portagecreekarea.
Additional information on the overall Kalamazoo River Project can be found at http://www.epa.gov/Region5/cleanup/kalproject/index.htm.
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