Allied Paper Landfill/Bryant Mill Pond Area
Community Involvement Coordinator
Diane Russell (firstname.lastname@example.org)
Remedial Project Manager
312-353-8983 or 800-621-8431, ext. 38983
Michigan Department of Environmental Quality
(where to view written records)
Kalamazoo Public Library
315 South Rose
Western Michigan University
1903 West Michigan Avenue
Charles Ransom Library
180 South Sherwood
Allegan Public Library
331 Hubbard Street
Otsego District Library
219 South Farmer Street
10 Mixer Street
The Allied Landfill is part of the Allied Paper/Portage Creek/Kalamazoo River Superfund site. The entire site is made up of five disposal areas, five paper mill properties, and an 80-mile stretch of the Kalamazoo River from Morrow Dam to Lake Michigan and a three-mile stretch of Portage Creek. Allied Landfill occupies 89 acres including Portage Creek between Cork and Alcott streets in the city of Kalamazoo.
A remedial investigation, a study of the nature and extent of contamination, was conducted by the Michigan Department of Environmental Quality and focused on polychlorinated biphenyls or PCBs.Various paper manufacturing and disposal operations were conducted on the site until all paper manufacturing operations stopped in the late 1970s and early 1980s. Paper-making residuals were a byproduct of the paper recycling process and are the primary waste at Allied Landfill. Carbonless copy paper was one type of paper recycled at Allied Landfill. The ink in recycled carbonless copy paper contained PCBs and was mixed into the residuals during the paper recycling process. These PCB-contaminated residuals were disposed of at Allied Landfill. The residuals are mostly a mixture of clay and wood fiber and appear at the site as gray clay. As with most clay, the paper residuals are difficult for water to penetrate, a condition called low permeability.
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EPA held an Open House on Feb. 19, 2014 to share information about past cleanup actions, groundwater at the Allied Landfill, the nature and extent of contamination, the Superfund process and potential cleanup options for the landfill. EPA and EPA contractors along with Michigan Department of Environmental Quality staff were available to talk one-on-one throughout the session.
The information shared can be found in the posters listed below.
- Feb. 19, 2014 Poster Session Part 1 (PDF) (7.9MB, 13 pp)
- Feb. 19, 2014 Poster Session Part 2 (PDF) (7.7MB, 14pp)
- Nature of Contamination
- Capping cleanup option
- Removal and Disposal cleanup option
- Paying for cleanup
EPA has concluded that the groundwater at Allied Landfill does not pose a risk outside of the landfill waste. The city of Kalamazoo has raised concerns that contamination from Allied Landfill could migrate to the city’s well field and affect drinking water. In 2009, a study done by Millennium Holdings (then the owner and a responsible party for the cleanup of Allied Landfill) evaluated whether a pathway existed where the groundwater could flow from the Allied Landfill to the city’s Central Well Field. The study concluded that the presence of a groundwater migration pathway from Allied Landfill to the city’s Central Well Field is highly unlikely. EPA and MDEQ have determined that groundwater at Allied Landfill flows east towards Portage Creek and not northwest towards the city of Kalamazoo’s Central Well Field. Additionally, the low levels of contamination observed in the groundwater within the landfill are not reaching Portage Creek, as indicated by the groundwater data. Some of the specific findings of the study are:
- Groundwater is not flowing towards the city’s Central Well Field.
- Shallow groundwater flow is to the east and not northwest towards the city wells. Shallow groundwater from adjacent properties flows to the east and west onto Allied Landfill.
- Portage Creek is the point of discharge for shallow groundwater from Allied Landfill, further directing ground water away from the Central Well Field.
- All available data suggests that a flow path from Allied Landfill towards the city’s Central Well Field is unlikely. The direction of groundwater flow in this area is from a deeper aquifer toward a shallow aquifer. A rock layer separates the two aquifers, limiting flow between them.
- Transport of PCBs in the groundwater is limited. PCBs were detected in only three of 56 monitoring well locations. The wells with detections were within or right next to the contaminated paper residuals.
- The land surface of Allied Landfill generally slopes toward Portage Creek, which is why water from the landfill discharges to Portage Creek.
Nature of Contamination at Allied Landfill
What are PCBs?
PCBs are a family of man-made chemicals that contain 209 individual compounds with different toxicity. PCBs were used widely as coolants and lubricants in transformers and other electrical equipment. Manufacturing of PCBs stopped in 1977 because of evidence that PCBs accumulate in the environment and may cause a health hazard.
The nature of PCBs is they are generally immobile, meaning they don’t move. PCBs are chemically and thermally stable so they will not change or decompose, have low solubility so they do not dissolve in water, and will strongly adhere to solids. Chemicals with low water solubility are more likely to be absorbed onto solids. In the case of Allied Landfill, PCBs stick to the paper residuals due to their high organic content. The PCBs are readily absorbed by organic materials such as sediment and soil. Because of these conditions, PCBs at Allied Landfill do not readily migrate out of the paper residuals. Currently the remaining potential sources of PCBs to Portage Creek from Allied Landfill are associated with erosion of contaminated soil and sediment along the edges of the landfill.
Early investigative efforts focused on PCBs because cleaning up that pollutant would also deal with other substances at the landfill. In addition to PCBs, inorganic materials and semi-volatile organic compounds were detected in soil, sediment and groundwater.
Risks Posed by Allied Landfill
Allied Landfill poses a risk to people’s health and the environment through exposure to the PCB-contaminated material at the landfill. People and animals can be exposed through direct contact with or through consuming the exposed PCB-contaminated material. Exposure could also occur if the contaminated residuals erode and move off-site.
If the contaminated residuals erode into Portage Creek, the fish can become contaminated and local anglers eating those fish would also become exposed. A prior cleanup action at the Bryant Mill Pond, which is located on the site, significantly reduced the PCB levels in fish at the Allied Landfill property by removing 150,000 cubic yards of waste from Portage Creek. PCB levels in the carp in Portage Creek have dropped since the removal action.
Erosion can be from natural or manmade causes. During any excavation work, there is a risk that the newly exposed contaminated paper residuals could travel off-site as dust emissions or from surface water runoff during rainstorms. A limited number of nearby commercial/industrial and residential properties contain contaminated paper residuals from the operations at Allied Landfill. Though there is a risk of direct contact exposure at these properties, PCB contamination is currently under clean soil or parking lots, which are barriers that prevent exposure.
Capping involves placing a protective cover over contaminated material such as landfill waste or contaminated soil. Caps do not destroy or remove contaminants. Instead, they isolate the contaminants to keep them in place, preventing the spread of contamination from erosion. Caps prevent wind from blowing contaminated material off-site. Caps also prevent people and wildlife from coming into direct contact with contamination. An important function of caps is that they help stop contamination from leaking into groundwater. They do this by stopping rain and snow from seeping through the material and carrying contaminants to the groundwater. The design of the cap for a site depends on several factors – the types and concentrations of contaminants, size of the site, amount of rainfall the area receives, and future use of the property. Groundwater monitoring wells placed around the capped area would be sampled routinely to make sure the contamination is contained.
The Superfund law and the National Contingency Plan, the federal government’s plan for responding to hazardous substance releases, as well as EPA guidance, state that EPA expects to use engineered barriers like caps for wastes that pose a relatively low long-term threat. Caps prevent exposure to large volumes of waste that can reliably be contained in place and have been selected for use at many Superfund sites across the country. Capping with groundwater monitoring is the remedy at Michigan Disposal Landfill, King Highway Landfill, 12th Street Landfill and the Willow Boulevard/A-Site Landfills, all in Michigan. These landfills have PCB-contaminated residuals, and the cleanups are operating successfully.
- A Citizen's Guide to Capping (PDF) (2 pp, 930 K) October 2012
Excavation and Off-site Disposal
The first step in total removal would be to identify the exact limits of the contaminated areas at the site. To conduct the excavation, standard construction equipment like backhoes would be used. Equipment would be chosen based on how large and deep the contaminated area is and whether access is limited because of the presence of buildings or other structures. Excavated soil would be transported off-site to a licensed landfill that can accept the waste. Excavation would be complete when the remaining soil around the excavated area meets established cleanup levels. Clean soil from other locations outside of the landfill would be needed to fill in the excavated area. Any excavation would require extensive safety precautions to prevent a release of contamination to Portage Creek through erosion or to the air as dust emissions. Excavation around buildings would be a bit more involved and precautions would be needed so that no foundations are damaged.Excavating contaminated soil may take several years and depends on several factors like the size and depth of the contaminated area and the funding available for the cleanup. Since EPA estimates there are about 1.5 million cubic yards of contaminated material at Allied Landfill, total removal could take about five years if 100 percent funding of the cleanup were available. This activity would require local traffic safety precautions as well as cause a greater amount of community disruption. In that scenario, there would be an average of 115 truck trips per day, year round, for five years. If 100 percent funding were not available, the cleanup would extend over a longer period of time.
Cost for Cleanup Options
The estimated cost for the consolidation, capping and monitoring option at Allied Paper Landfill is around $41 million. EPA estimated the option for total removal of waste would cost $189 million.
Paying for CleanupAllied Landfill’s former owner, Millenium Holdings, established a $50.5 million trust for cleanup of Allied Landfill as a part of a bankruptcy settlement in 2010. If funding were required beyond that trust account, a potential source would be EPA’s Superfund remedial budget, which provides funding to a wide variety of Superfund cleanup projects across the country. Nationwide, EPA’s remedial budget has been significantly reduced over the last five years and future years point to continued constrained budgets. The Allied Paper Landfill project would have to compete with other sites across the country for funding.
- Polychlorinated Biphenyls Agency for Toxic Substances and Disease Registry (PDF) (1p) Feb 2001
- EPA Releases Report on Landfill Cleanup Options – Public Availability Sessions to Follow (PDF) (6 pp, 419 K) January 2014
- A Citizen's Guide to Capping (PDF) (2 pp, 930 K) October 2012
- Feasibility Study Report (PDF) (271 pp, 30 MB)- November 2013
- Community Involvement Plan (PDF) (29pp, 1.0 MB) March 2008
- Allied Paper, Inc. Operable Unit Remedial Investigation Report - March 2008 - report text only (PDF) (175pp, 3.0 MB) March 2008
Note: The full report is 403pp and 121MB and is available at the repositories listed on this page. You can also request the full report on CD from Michael Berkoff (Berkoff.email@example.com), 312-353-8983.
- Allied Paper Operable Unit 1 Remedial Investigation Report - March 2008
Note: The full report is 403pp and 121MB and is available at the repositories listed on this page. You can also request the full report on CD from Michael Berkoff (Berkoff.firstname.lastname@example.org) , 312-353-8983.