# Presentation: 750885

## EPA Update 

**Allied Paper/Portage Creek/Kalamazoo River Superfund Site**

**May 29, 2003**
**Kalamazoo River Protection Association **

## Tonight’s Topics

**  ****Cleanup Approach**
**  ****Schedule Update **

## Cleanup Approach

**1)  Eliminate PCB sources: **
**      ****-  Paper wastes on river banks**
**      ****-  Morrow Lake as potential source**
**      ****-  Existing landfills**
**   **
**      ****-  Paper mill properties**

**Notes:**
EPA’s plan is to First, eliminate on-going PCB sources by removing paper wastes on river banks and Then, address in-stream sediments.  Before addressing in-stream sediments, EPA will investigate PCB sources upstream of Morrow Lake. We will also make sure no PCB’s are entering river from existing landfills and paper mill properties.

## Cleanup Approach

**2)  Address in-stream sediments**
**3)  Begin upstream and move          downstream**** **

**Notes:**
EPA’s plan is to First, eliminate on-going PCB sources by removing paper wastes on river banks and Then, address in-stream sediments.  Before addressing in-stream sediments, EPA will investigate PCB sources upstream of Morrow Lake. We will also make sure no PCB’s are entering river from existing landfills and paper mill properties.

## Allied Paper/Portage Creek/

- Kalamazoo River Superfund Site

**Schedule **
**Update**** **

## On Schedule

**  ****Morrow Lake **
**  ****Plainwell/Otsego City**
**     ****impoundments**
** **
**  ****Downstream impoundments **
**     ****and Lake Allegan**

## On Schedule

- Allied Paper/Portage Creek/
- Kalamazoo River Superfund Site

**On Schedule**

**On Schedule**

**On Schedule**

**On Schedule**

## Morrow Lake

**Work on schedule:**
**  **Sent information request letters to
-      potential PRPs
-   Next Step:   Send notification to PRPs
-      to start RI/FS negotiations (Summer/Fall)

**Notes:**
These letters request information regarding the Superfund investigation and help EPA determine the extent of PRP liability for contamination in the river. 
 During the RI/FS negotiations, EPA and PRPs try to reach  an agreement to the terms of the RI/FS work and that the PRPs will pay for the RI/FS work.  Negoitation period is 60 days but may extend another 30 days.    

## Plainwell/Otsego City Impoundments

**Work on schedule:**
**  ****EPA completing remedial**
**     ****investigation and feasibility study **
** ****Next steps:**
**Summer – Issue Proposed Plan**
**Summer/Fall – Issue Record of Decision (ROD) **

## Downstream Impoundments and Lake Allegan

**Work on schedule:**
** ****Sent information request letters to potential  PRPs**** **
** ****Developed sampling plan**
**Want PRPs to implement**
**Still need to negotiate agreement to conduct sampling **
** ****Next step:  send notification to PRPs to start RI/FS negotiations (Summer/Fall)**

**Notes:**
These letters request information relevant to the Superfund investigation 
EPA developed sampling plan for Lake Allegan and is in the process of finalizing plan for the downstream impoundments.  Still need to negotiation agreement to conduct sampling that will be done after we send the notifications to the PRPs to start RI/FS negotions. 
Expect to send out letter this Summer/Fall
1400 samples proposed at Lake Allegan.  1000 samples collected at Plainwell/Otsego City at cost of 800K.

## Rescheduled

**  ****Allied Paper landfill**
**  ****Willow Boulevard/A-Site**
**  ****12****th****  Street landfill**

**Notes:**
Some of the projects dates that have been rescheduled since our August 2002 fact sheet are:

## Rescheduled

- Allied Paper/Portage Creek/
- Kalamazoo River Superfund Site

**Rescheduled**

**Rescheduled**

**Rescheduled**

## Allied Paper Landfill

**MDEQ remedial investigation (RI) completion rescheduled  from spring to fall 2003**
**                       ****EPA will complete FS **
**                            ****and proposed plan **
**                             ****(fall/winter 2004) **

**Notes:**
The completion date for the Allied Paper RI was rescheduled from Sring to Fall this year.  DEQ AND the PRPs agreed that it was necessary to install additional monitoring wells to more fully characterize groundwater at the site
After DEQ finishes the RI, EPA will take the lead by completing the Feasbility Study and issue the proposed  plan in fall/winter next year.
ROD to be issued Spring 2005

## Willow Blvd/A-Site

**MDEQ feasibility study (FS) completion rescheduled  from summer/fall 2002 to summer 2003**
**  ****EPA will  issue:**
**    ****- Proposed plan in summer       **
**    ****- ROD in fall/winter **

**Notes:**
The Feasiblity study for the Willow Boulvard/A-site landfill has been rescheduled.  DEQ expects to finalize the FS next month.  
After the FS is finalized, EPA will issue a proposed plan this summer and Record of Decision this fall/winter.

   MDEQ had to wait until the ecological risk assessment was completed.  EPA went thru peer review of a protion of the document took 7 months. 

## 12th Street Landfill

**Cleanup negotiations unsuccessful. PRPs would not do cleanup**
**Next step: Additional sampling in July to provide stronger basis for a legal action (Unilateral Administrative Order) **
**Remedial design in 2004**

**Notes:**
ROD already issued. EPA started negotiating the terms of the cleanup work last Summer.  However,the negoitations were unsuccessful.  PRPs didn’t feel we had a good idea of the volume and extent of material that would have to be consolidated into the landfill.  The PRPs we didn’t feel we have data to show erosion from the landfill.  
Because negotiations were unssecculf, EPA is considering issuing a legal action called a UAO.  EPA needs to collect addtiional samples to support the issuance of this legal action. Essentially, the UAO would force the PRPs to conduct cleanup
Typically, if cleanup negotiations are unsuccessful, then EPA has several choices;
  -  Issue UAO, if don’t comply:
     - Use trust fund monies to pay for cleanup 
      - Litigate in court
      - likely we could use money from settlement to do work ourselves.
      - renegotiate with the PRPs to voluntarily sign.  The CD which outlines the cleanup work to be performed.
3) EPA expects to start remedial design next year.  Remedial design phase is engineering phase of the project where technical drawings and specifications are developed for the remedy selected in the ROD.   

## Completed

**King Highway landfill **
**MDEQ will be overseeing long-term groundwater and surface water monitoring**** **

**Notes:**
1) King Highway landfill construction is complete and DEQ will be overseeing long term groundwater and surface water monitoring shortly.

## Completed 

- Allied Paper/Portage Creek/
- Kalamazoo River Superfund Site

**Completed **

## What’s Next

** ****Summer:  Proposed Plans**
**    ****-   Willow Blvd/A-site **
**    ****-   Plainwell/Otsego City **
**    ****-   Public meetings/comment periods**
** ****Fall/Winter:  Record of Decisions**
**    ****-  Willow Blvd/A-site  **
**    ****-  Plainwell/Otsego City**

**Notes:**
1) King Highway landfill construction is complete and DEQ will be overseeing long term groundwater and surface water monitoring shortly.

## What’s Next

** ****Summer/Fall negotiations:**
**   **
**     ****-  12****th**** Street landfill:  renegotiate        **
**        ****consent decree with PRPs or issue  **
**        ****legal order to conduct cleanup   **

**Notes:**
1) Renegotiate terms of consent decree or terms of cleanup with PRPs or issue legal order 

## What’s Next

** ****Summer/Fall negotiations (cont.)**
**  **
**   ****-  Downstream impoundments, Lake    **
**      ****Allegan, and River:  Start **
**      ****negotiations for RI/FS work**

**Notes:**
1) Renegotiate terms of consent decree or terms of cleanup with PRPs or issue legal order 

## Contacts

**Shari Kolak, EPA Project Manager**
**312-886-6151**
**(800) 621-8431 Ext. 66151**
**kolak.shari@epa.gov**
**Don de Blasio, Community Involvement Coordinator**
**312-886-4360**
**(800) 621-8431 Ext. 64360**
**deblasio.don@epa.gov**