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KALAMAZOO COUNTY
KALAMAZOO
Congressional District # 06
ALLIED PAPER, INC./PORTAGE CREEK/KALAMAZOO RIVER
EPA ID# MID006007306Last Updated: November, 2009
Site Description
The Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund site includes five disposal areas, five paper mill properties, an approximately 80-mile stretch of the Kalamazoo River from Morrow Dam to Lake Michigan, and a three-mile stretch of Portage Creek.
At this time, the site is divided into five cleanup projects known as operable units (OUs):
• OU #1, Allied Paper Property/Bryant Mill Pond Area;
• OU #2, Willow Boulevard and A-Site Landfill;
• OU #3, King Highway Landfill;
• OU #4, 12th Street Landfill; and
• OU #5, the Portage Creek and Kalamazoo River sediments.
The primary site contaminant is polychlorinated biphenyls (PCBs), a hazardous substance and probable human carcinogen. PCBs were introduced to Portage Creek and the Kalamazoo River through past discharges and disposal of PCB-contaminated paper residuals by the paper industry. The five disposal areas are situated on the river banks and contain millions of cubic yards of PCB-contaminated waste. It has been estimated that the river sediments contain more than 120,000 pounds of PCBs. The contaminated sediments have largely been deposited in four impoundment areas.
In February 2007 two Administrative Orders on Consent (AOCs) were signed by both the United States Environmental Protection Agency (EPA) and Millennium Holdings, LLC and Georgia-Pacific, LLC (collectively known as the Kalamazoo River Study Group (KRSG)). One AOC requires the KRSG to conduct a supplemental remedial investigation/feasibility study (RI/FS) for the Portage Creek and Kalamazoo River sediments, and the other called for a time-critical removal action (TCRA) of sediments in a portion of the Kalamazoo River near Plainwell, MI. (Additional information is provided below in the “Cleanup Progress” section.) EPA is currently the lead regulatory agency on this project and is working closely with the Michigan Department of Environmental Quality (MDEQ) to oversee the cleanup activities.
Site Responsibility
This site is being addressed through federal, state, and potentially responsible parties' actions.Threats and Contaminants
The site is contaminated with PCBs, a hazardous substance and probable human carcinogen. It has been estimated that the river sediments contain over 120,000 pounds of PCBs, and the five unconfined disposal areas situated on the river banks contain millions of cubic yards of PCB-contaminated waste.Cleanup Progress
EPA’s cleanup approach for the Kalamazoo River is to first eliminate ongoing sources of PCBs, which includes the exposed paper wastes along the river banks and flood plain soils (or impoundments), and then address in-stream sediments. The exposed paper wastes are located behind State-owned and privately-owned dams along the river. Before evaluating cleanup options for in-stream sediments, EPA will investigate upstream sources of PCBs and evaluate the existing landfill OUs and paper mill properties to ensure they are not a source of PCBs to the river. Generally, EPA's cleanup will begin upstream and work downstream on a reach-by-reach and dam-to-dam basis.
INTERIM ACTIONS
To date, a number of initial measures have been taken to reduce the release of PCBs from the disposal areas. In 1992, a fence was erected around the entire OU #1 Allied Paper property, including the Bryant Mill Pond area (approximately 70 acres on Portage Creek), to restrict access and thereby reduce the potential for exposure from direct contact with exposed sediments. Because of concern about the ongoing release of PCBs from the Bryant Mill Pond area to Portage Creek and the slow progress of actions under the state-lead RI/FS, EPA entered negotiations in 1997 with H.M. Holdings, Inc., to expedite an action to address the Bryant Mill Pond sediments. In November 1997, EPA and H.M. Holdings reached an agreement in principal for H.M. Holdings to fund, up to a certain monetary limit, an EPA-conducted removal and onsite containment action for the Bryant Mill Pond sediments. The Removal Action began in June 1998. Portage Creek was temporarily diverted from its normal streambed in order to conduct "dry" excavation of 150,000 cubic yards of the creek bed and floodplain soils. Excavation work was completed in May 1999. Excavated material was placed in the Historical Residual Dewatering Lagoon and the Bryant Former Residual Dewatering Lagoons. PCB concentrations remaining after the removal action were less than 1 part per million (ppm). The cost of the removal action was $7.5 million.
Other interim actions that have been completed include:
• Sheet pile and temporary cap installation at the Willow Blvd/A-site (OU #2) to prevent direct erosion into the river
• Sheet pile installation at the Allied Paper site (OU #1) along with a cap
In June 2009, the KRSG completed a time-critical removal action to remove PCB-contaminated sediment from the Kalamazoo River's Plainwell Impoundment near Plainwell, MI. The KRSG conducted the TCRA under a February 2007 AOC, with EPA oversight. Work began in March 2007. A total of 130,000 cubic yards of contaminated in-stream and bank sediment were removed by this action. Consistent with the federal Toxic Substances Control Act, sediments containing PCB concentrations greater than 50 ppm were disposed at Environmental Quality Co.'s Wayne Disposal Landfill in Belleville, Michigan. Sediments with concentrations less than this, which are considered non-hazardous waste and represent 80 percent of the waste material, were disposed at Allied Waste's C and C Landfill near Marshall, MI, and its Ottawa Farms Landfill near Coopersville, MI. The estimated cost of this project was $30 million. This project also rerouted the Kalamazoo River to its original channel and removed the dam near Plainwell. The Kalamazoo River is now free-flowing from Kalamazoo to Otsego City, MI.
In June 2009, Georgia-Pacific LLC (GP) and EPA entered into a legal agreement committing GP to conduct a time-critical removal action in the Plainwell #2 Dam area. The cleanup began in August 2009 approximately three miles upstream of the recently-completed Plainwell Dam cleanup. This Plainwell #2 removal project includes a two-mile stretch of the Kalamazoo River. During the 2009 construction season, GP removed contaminated soil along the north side of the Kalamazoo River. Approximately 4,900 linear feet of riverbank was cleared, excavated and restored, with approximately 4,725 cubic yards of soil and debris disposed off-site at the Allied Waste C&C Landfill in Marshall, MI, and at Ottawa County Farms Landfill in Coopersville, MI. All planned excavation activities were completed on the north side of the river in 2009. Depending on weather conditions, clearing and access road construction may occur on the south side of the Kalamazoo River during the winter months in preparation for cleanup activities in 2010. Cleanup activities in the Plainwell #2 Dam area are anticipated to be completed in 2010 and will remove 90 percent of the PCB-contaminated soil from the area at a cost of about $10 million.
OPERABLE UNIT 1: ALLIED LANDFILL
The Remedial Investigation Report for the Allied Site developed by MDEQ was finalized and approved by EPA in March 2008. A groundwater investigation to determine the impacts, if any, from OU #1 was completed in the summer of 2009. The groundwater investigation confirmed the conclusions in the RI report that groundwater from the Alllied Site is flowing toward Portage Creek. In October 2009, Millennium Holdings submitted to EPA the draft Feasibilty Study Report which examines a range of cleanup alternatives. EPA anticipates presenting to the public a proposed cleanup plan for the Allied Site in summer 2010.
OPERABLE UNIT 2: WILLOW BOULEVARD AND A-SITE LANDFILL
The Willow Blvd/A-Site Landfill OU #2 was under MDEQ control through completion of the RI/FS Report in 2006. EPA completed a Record of Decision for the closure of the landfill in 2006. In September 2009, the legal settlement between EPA and Georgia Pacific for design and cleanup at the Willow Boulevard/A-Site Landfill was approved by a federal District Court. Georgia-Pacific will consolidate waste materials, construct a permanent landfill cap and install a ground water monitoring system. The company will complete design work in 2010 and construct the landfill cap and ground water system in 2011.
OPERABLE UNIT 3: KING HIGHWAY LANDFILL
Cap construction at the King Highway Landfill (OU #3) was completed in fall 2001. In summer 2002, the cap was seeded for vegetative growth. In the fall of 2007, a gas collection trench was constructed at the landfill. The King Highway Landfill remains under MDEQ control and the remedy is currently near completion.
OPERABLE UNIT 4: 12th STREET LANDFILL
In September 2001, EPA signed the Record of Decision for the 12th St. Landfill. The remedy includes excavation of PCB residuals that have migrated from the landfill and will be placed back in the landfill. The side slopes of the landfill will be stabilized and a cap will be installed. Monitoring wells for long-term monitoring will be installed. To accommodate the channel diversion as part of the TCRA near the Plainwell Dam, the slope of the 12th street landfill adjacent to the Kalamazoo River was reshaped, upgraded, stabilized and restored in 2007. Contamination adjacent to the river has been removed in the vicinity of the 12th Street Landfill and remedial design work for the remaining portion of the 12th St. Landfill is being developed. This work is being conducted by Weyerhaeuser with oversight of EPA and MDEQ. As part of the landfill design, Weyerhaeuser will consolidate waste material, construct a landfill cap and install a groundwater monitoring system in 2010.
OPERABLE UNIT 5: PORTAGE CREEK AND KALAMAZOO RIVER SEDIMENTS
On February 21, 2007, EPA reached two settlement agreements with Georgia-Pacific Corporation and Millennium Holdings LLC, two of the Potentially Responsible Parties (PRPs) collectively known as the Kalamazoo River Study Group. The agreements were a result of 2 years of mediated negotiations between the PRPs and EPA, MDEQ and the Natural Resource Trustees (including the Michigan Department of Natural Resources, MDEQ, Michigan Department of Attorney General, National Oceanic and Atmospheric Administration, and the U.S. Fish and Wildlife Service).
Under one agreement, KRSG agreed to perform the TCRA sediment excavation in the Kalamazoo River near Plainwell, MI (as described above under “Interim Actions”). Under the other agreement, KRSG agreed to conduct a Supplemental RI/FS on the 80-mile stretch of the Kalamazoo River from Morrow Dam to Lake Michigan and Portage Creek from Cork Street to the confluence with the Kalamazoo River. Although large amounts of data have been obtained throughout the river, numerous areas were identified where further investigation is required. The Kalamazoo River was divided into seven areas. Currently, supplemental RI/FS work is underway in Area 1 which includes a 21-mile stretch of the Kalamazoo River from Morrow Dam to the Plainwell Dam and 3 miles of Portage Creek. Phases 1 and 2 of the sampling efforts in Area 1 have been completed and it is anticipated that Phase 3 sampling work in Area 1 will be completed in December 2009.
MILL PROPERTIES
Several old paper mills exist along the Kalamazoo River. EPA is investigating these areas to determine if the mill properties, although inactive, are a source of PCB contamination to the river.
Work at the Georgia-Pacific Kalamazoo Mill and former Hawthorne Mills (consisting of removal of buildings, removal of contaminated soil and site stabilization) was completed in July 2007. In December 2008, Georgia-Pacific submitted a report to EPA asserting its position that the two properties no longer contribute PCBs to the Kalamazoo River. In July 2009, EPA concurred with this report and no further work on these mill properties is anticipated at this time.
Preliminary work to remove PCB-contaminated sediment from the banks of the Plainwell Mill began in the fall of 2007 and was completed in March 2008. Approximately 5,000 cubic yards of material was removed. The first phase of the Remedial Investigation, a cursory groundwater investigation, was completed in December 2008. Currently, Weyerhaeuser is conducting Phase 2 of the site investigation at the Plainwell Mill. Soil and groundwater samples are being collected during December 2009 and January 2010, and the results are expected in spring 2010.
MILLENNIUM BANKRUPTCY
On January 6, 2009, Lyondell Chemical Company and 79 affiliated debtors filed for bankruptcy under Chapter 11 reorganization. One of the debtors is Millennium Holdings, LLC, one of the PRPs at the Kalamazoo River site. Bankruptcy reorganization is typically a lengthy process that could take a couple years to complete. Millennium Holdings is continuing to work on OU #1 (Allied Site) but has ceased work on other areas of the project; Georgia-Pacific is addressing those obligations. All work on the project under the two 2007 AOCs wth EPA is proceeding according to schedule. EPA is currently evaluating options under bankruptcy and environmental law to ensure that the cleanup of the Kalamazoo River site continues.
Contacts
Remedial Project Manager, U.S. EPAjim saric (saric.james@epa.gov)
(312) 886-0992
Community Involvement Coordinator, U.S. EPA
Don De Blasio
(312) 886-9749
Aliases
ALLIED CORP KALAMAZOO PLTALLIED PAPER/PORTAGE CREEK/KALAMAZOO RIV
PORTAGE CREEK
ALLIED PAPER
ALLIED PAPER/PORTAGE CK/KALAMAZOO RIVER