U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Rock-Tenn - Removal Polrep
Final Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #3
Removal Complete - Final POLREP
Rock-Tenn
C5A2
Otsego, MI
Latitude: 42.4647444 Longitude: -85.7043547
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To:
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From:
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Brian Kelly, OSC
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Date:
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4/2/2012
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Reporting Period:
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1. Introduction
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1.1 Background
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Site Number: |
C5A2 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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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: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
1/24/2012 |
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Start Date: |
1/24/2012 |
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Demob Date: |
3/28/2012 |
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Completion Date: |
4/2/2012 |
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CERCLIS ID: |
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RCRIS ID: |
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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
CERCLA Time-Critical Removal. PRP Voluntary Action.
1.1.2 Site Description
The site is comprised of a former paper mill in which representatives of Allegan County found abandoned drums, totes, and containers.
MacSimBar Paper Company began papermaking at the site in 1906. Paper and related products were produced at the site for 98 years during which time the facility was operated under several different names. In 2004, the Rock-Tenn mill closed. Cogswell Property LLC, of Redford Township, bought the mill site in 2006. The property entered foreclosure in 2011 after Cogswell failed to pay property taxes. Currently, Allegan County owns the property.
1.1.2.1 Location
431 Helen Ave, Otsego, Allegan County, Michigan 49078
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On November 16 and 17, 2011, and December 14, 2011, EPA conducted a site assessment that found drums and totes of corrosive hazardous waste. Sampling for polychlorinated biphenyls found only trace levels. (see the Site Assessment Report for more details).
After being notified of the site, Rock-Tenn volunteered to remove the containerized wastes. In January, Rock-Tenn distributed a site contingency plan to local agencies and submitted a work plan to EPA. The company's initial assessment found
50 1-Gallon Paint Cans
875 1-Gallon Roofing Patch w/asbestos
160 1-Gallon Flammable Paint
800 1-Pt Cans
3 30-Gallon Acid Drums
103 5-Gallon Pails
216 55-Gallon Drums
7 Batteries - Car Type
4 Empty Totes
6 Fire Extinguishers
18 Full Totes
20 Hydrated Lime Pallets
9 MT 55-Gallon Drums
4 Propane Tanks 100 lb
62 Propane Hi lo Tanks
30 Qt - Pints
2 Refrigeration Units
64 Spray Bombs - Most MT
1 Transformers
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
The Project Objectives included
1) Assure that all activities completed at the project site will be in compliance with State, Federal and local applicable rules and regulations;
2) Assure the safety of on-site personnel;
3) Assure the safety of the community;
4) Assure security of the project site during removal activities; and
5) Assure efficient and accurate characterization, consolidation and off-site disposal of all totes, drums, small containers and other identified chemical hazards at the project site.
2.1.2 Response Actions to Date, 2012
Between January and the end of March, Rock-Tenn (and Rock-Tenn's consultant Terra) and EPA completed three sweeps of the buildings finding 277 drums, 21 totes, 515 bags of lime, 1807 paint cans, and 576 misc containers. The wastes were transferred to the containment area in buildings 41 and 42. These buildings are separate from the main complex and located at the edge of the west parking lot. Samples were collected, and after laboratory results, the wastes were organized into like groups for disposal. Drums were kept in a heated tent during sampling to prevent the contents from freezing. Air monitoring was conducted both for worker safety and at the perimeter of the site. No elevated readings were found.
During the first week of March, Terra had completed sampling and consolidation of wastes, dismantled the staging tent and cleaned out and cut up the empty drums and totes. Paint drums and totes were prepared for off-site shipment and sent to Autumn Hills RDF in Zeeland, Michigan. A vac truck was used to pump out used oil and wash water from drums. A company called White Pigeon Paper picked up the bags of lime that were in good condition. Non-hazardous drums and scrap metal were loaded into separate roll-off boxes for disposal.
On March 20, EPA, City of Otsego, Allegan County, and Rock-Tenn meet on site to review the cleanup and discuss transfer of the site back to the County.
Between mid March and April 2, Terra loaded a dry van, demobilized all equipment, shipped scrap steel and construction and demolition debris, finalized disposal, and cleaned the staging areas.
The removal is complete.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Rock-Tenn Company performed a voluntary removal action.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Regulated Medical Waste (Urine Samples) |
Liquid |
30 lbs |
004045511 |
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| Drummed Latex Paint |
Liquid |
3025 G |
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| Used Oil and Wash Water |
Liquid |
3000 G |
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| Small Containers Latex Paint |
Liquid |
4 Tons |
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| Weak Acids |
Liquid |
340 G |
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| Liquid Dyes |
Liquid |
635 G |
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| PM-9906 |
Liquid |
600 G |
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| Caustic Cleaners |
Liquid |
750 G |
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| Wax/Grease/Tar |
Liquid |
510 G |
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| Neutral Solids |
Solid |
440 G |
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| Solid Powders and Dyes |
Solid |
4.75 Tons |
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| Non-Hazardous Powder |
Solid |
55 G |
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| AP-8020 |
Liquid |
1500 G |
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| Strong Acids |
Liquid |
220 G |
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| AF-4471 |
Liquid |
900 G |
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| PM-9001 |
Liquid |
1200 G |
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| Neutral Liquids |
Liquid |
880 G |
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| RCRA Empty Drums |
Solid |
1.22 Tons |
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| MT Drums, Lime, DE, & Hot Tar Pot combined |
Solid |
20 Yds |
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| General C&D |
Solid |
20 Yds |
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| Propane Containers |
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19 units |
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| Fire Extinguishers |
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46 |
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| Scrap Metal |
Solid |
5.97 Tons |
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| Hydrated Lime |
Solid |
515-50 Lbs bags |
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| Waste Flam. Liquid (LP) |
Liquid |
419 G |
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| Waste Paint (LP) |
Liquid |
70 G |
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| Waste Toxic, Corr. (LP) |
Liquid |
2 G |
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| Waste Corrosive (LP) |
Liquid |
8 G |
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| Waste Aerosols (LP) |
Liquid |
130 Lbs |
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| Waste Methylacetylene (LP) |
Liquid |
2 Lbs |
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| Waste Perto. Gas (LP) |
Liquid |
10 Lbs |
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| Waste Corr. Flam (LP) |
Liquid |
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| Non-Haz Liquids (LP) |
Liquid |
220 G |
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| Waste Comp. Gas (LP) |
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4 Lbs |
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| Env Haz Sub. (HG) |
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20 Lbs |
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| Env Haz Sub. (NiCd Battery) |
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7 Lbs |
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| Batteries- Lead Acid |
Solid |
300 Lbs |
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| This is an Integrated River Assessment. The numbers should overlap. |
Miles of river systems cleaned and/or restored |
0 |
| Cubic yards of contaminated sediments removed and/or capped |
0 |
| Gallons of oil/water recovered |
5000 |
| Acres of soil/sediment cleaned up in floodplains and riverbanks |
0 |
| Stand Alone Assessment |
Acres Protected |
10 |
| Number of contaminated residential yards cleaned up |
0 |
| Human Health Exposures Avoided |
30 |
| Number of workers on site |
15 |
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2.2 Planning Section
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No further removal work is planned. Allegan County plans to conduct a brownfields assessment of the property.
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2.3 Logistics Section
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No information available at this time.
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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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No information available at this time.
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3. Participating Entities
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3.1 Unified Command
EPA - Brian Kelly
City of Otsego - Dave Rayman and David Dutton
Allegan County - Kevin Ricco
Rock-Tenn - Steve Hamilton
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4. Personnel On Site
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No information available at this time.
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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