ALLIED PAPER, INC./PORTAGE CREEK/KALAMAZOO RIVER
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The Allied Paper Inc./Portage Creek/Kalamazoo River Superfund Site is located in Allegan and Kalamazoo Counties, Michigan. The site includes soil and sediments contaminated by a group of chemicals called polychlorinated biphenyls (PCBs) in 80 miles of the Kalamazoo River (from Morrow Dam to Lake Michigan), paper mill properties, riverbanks and floodplains, and a 3-mile stretch of Portage Creek. EPA has broken down the site into six segments, or operable units (OUs), that require cleanup. The six OUs are as follows:
- 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;
- OU 5: Portage Creek and Kalamazoo River sediments; and
- OU 7: Plainwell Mill
Five of the OUs are considered source OUs, meaning they historically contributed to (i.e., were sources of), the river’s contamination. So far, cleanup has taken place at three of the five source OUs and EPA conducts maintenance activities and monitors underground water sources, or groundwater, at these locations. For the remaining OUs that were a source of contamination to the river, interim actions have been taken to stop contamination to the river and cleanup decisions have occurred to address what remains.
OU5 includes 80 miles of the Kalamazoo River and 3 miles of Portage Creek. Because OU5 is so large and complex, it has been divided into seven Areas. Each Area is separated by dams and requires its own cleanup. EPA has decided on cleanup plans for two of the seven Areas in addition to taking interim actions throughout Kalamazoo River and Portage Creek to protect human health and the environment.
What Has Been Done to Clean Up the Site?
Since 1998, EPA has removed nearly 450,000 cubic yards of contaminated material from the site, cleaned up and restored seven miles of the Kalamazoo River and banks, and capped 82 acres worth of contaminated material to lock it away.
EPA is working with its partners at the Michigan Department of Environmental Quality (MDEQ) and the potentially responsible parties (PRPs), or the parties responsible for the contamination, to clean up the site and eliminate PCBs, the chemicals of concern, from entering the Kalamazoo River. Under the law, EPA can require the PRPs to pay for the cleanup. EPA and the PRPs have entered into a number of legal agreements wherein the PRPs will either reimburse EPA for cleaning up the site, or conduct cleanup activities with EPA oversight. While work is being done, the State of Michigan has posted fish advisory signs along the Kalamazoo River warning people about the risks of eating fish from the river.
During the cleanup there are two EPA programs working in tandem: the Remedial Program and the Removal Program. The Remedial Program addresses contamination that does not pose an immediate threat to public health or the environment – the cleanups are very thorough, require lots of planning, and move from upstream to downstream. The Removal Program addresses contamination that poses an immediate threat to human or environmental health – removal actions target contamination “hot spots” throughout the site. Typically, removals are implemented based upon information obtained by the Remedial Program, and once the removal action is complete, the Remedial Program will address the remaining cleanup required in a particular section of the river.
The site is very large and complex, and thus has been broken down into smaller pieces called Operable Unit (OUs). EPA and MDEQ have cleaned up three of the six OUs so far (OU2: Willow Boulevard and A-Site Landfill; OU3: King Highway Landfill; OU4: 12th Street Landfill). The agencies monitor OUs 2, 3, and 4 to ensure the cleanups continue to protect human health and the environment.
EPA has decided on cleanup plans for OU1 (Allied Paper Landfill) and OU7 (Plainwell Mill) and has taken action to make sure the contamination in those locations do not move into the Kalamazoo River or Portage Creek.
OU5 is the largest of the operable units and consists of 80 miles of the Kalamazoo River. Because of its size and complexity, OU5 was subdivided into seven Areas – EPA has decided on cleanup plans for two of the seven Areas. The Agency has also taken interim actions, which are measures taken to reduce the release of contamination that threatens human and environmental health before EPA chooses the final cleanup plan.
EPA has conducted several five-year reviews of the for the three areas where remedial action has taken place. These reviews ensure that the cleanups put in place protect public health and the environment.
What Is the Current Site Status?
PCB Cleanup Completed at Otsego Dam
The U.S. Environmental Protection Agency completed the removal of PCB-contaminated sediment and soil along the Kalamazoo River near the Otsego Township Dam. Georgia-Pacific LLC, Weyerhaeuser Co., and International Paper Co. were required to carry out the cleanup activities. Throughout this project, EPA coordinated with the Michigan Department of Environmental Quality (MDEQ) and Michigan Department of Natural Resources (MDNR).
The project involved a 1.7-mile area of PCB-contaminated sediment and soil immediately upstream of the former Otsego Township Dam. This portion of the Kalamazoo River is in what EPA calls Area 3 of Operable Unit 5 of the Allied Paper Inc./Portage Creek/Kalamazoo River Superfund site.
Cleanup progress to date
Work began in August 2016. Workers dredged over 50,000 tons (33,000 cubic yards) of sediment and soil from this stretch of the river, stabilized riverbanks to prevent future contamination and erosion, and disposed of contaminated materials at an approved landfill. Once contaminated material was removed, workers tested and monitored the area to confirm cleanup goals were met, filled excavated areas with clean material, and restored the area with native plants.
A temporary water control structure that was built in 2015 to replace the dam was removed, and the river is now an open channel. The area around the former auxiliary spillway has been restored as a wetland area. There are two public parking areas built at former project staging areas. The river is now open, and there is access to the river at these areas for kayaks and canoes.
Kalamazoo River Cleanup Progress
In September 2015, EPA signed a document called the “Record of Decision” for Area 1 of the river. (Area 1 is the portion of the Kalamazoo River between Morrow Dam and the former Plainwell Dam, and includes Portage Creek between Cork Street and the Kalamazoo River.) The cleanup for Area 1 includes excavation of PCB-contaminated hot spots in a 3-mile section of the Kalamazoo River near the confluence of Portage Creek, and floodplain soil removal in the Plainwell Impoundment near the former Plainwell Dam.
In December 2016, EPA ordered Georgia-Pacific, International Paper, and Weyerhaeuser to conduct the Area 1 work by issuing a legal document called a “Unilateral Administrative Order.” Since then, sampling is ongoing to support the cleanup design, and cleanup work is anticipated to start in 2019.
In September 2017, EPA signed a Record of Decision for Area 2 of the river (Area 2 is the Kalamazoo River between the former Plainwell Dam and the Otsego City Dam). The remedy for Area 2 includes construction of a new river channel, excavation of PCB hot spots, capping of several side channel areas and removal of the Otsego City Dam.
In July 2018, Georgia Pacific submitted a revised version of a document called the “Feasibility Study Report” for Area 3 of the river (Area 3 is the Kalamazoo River between the Otsego City Dam and the former Otsego Township Dam). This report details various cleanup alternatives for this area. EPA anticipates announcing a proposed cleanup plan in 2019 for public comment.
In November 2017, Georgia-Pacific submitted a revised Supplemental Remedial Investigation Report for Area 4 of the river (Area 4 is the Kalamazoo River between the Otsego Township Dam and Trowbridge Dam). The final version of the report, which shows where the contamination in Area 4 is located, will be submitted for EPA review in August 2018.
In October 2017, sampling began to support the investigation of Area 5 of the river (Area 5 is the Kalamazoo River between the Trowbridge Dam and Allegan City Dam). Additional investigation sampling will occur throughout 2018 and 2019.
Plainwell Mill update
EPA signed a Record of Decision for the former Plainwell Paper Mill in September 2015. The selected cleanup plan requires the excavation and off-site disposal of contaminated soil from the former mill site. The Remedial Design was finalized in April 2018, and Weyerhaeuser has submitted the cleanup work plan.
Cleanup work will start once EPA approves the work plan, which is anticipated in 2018.
Allied Paper Landfill update
EPA’s selected remedy for Allied Landfill includes consolidation of existing waste materials to a 27-acre area, installation of a cap, and a long-term groundwater monitoring network. Areas outside of the cap would be available for commercial/industrial redevelopment, and the capped area would be available for some recreational reuse. EPA expects the city of Kalamazoo to facilitate any future redevelopment and act as the long-term steward of the property.
The project is currently in the design phase. EPA expects cleanup work to begin by 2020 and take up to three years to complete. EPA continues to gather input from the city of Kalamazoo on cleanup plans.
Operable Unit 1 - Allied Landfill Record of Decision (PDF) (138pp, 24.6MB) September 2016