ALLIED PAPER, INC./PORTAGE CREEK/KALAMAZOO RIVER
On this page:
- What Is Being Done to Clean Up the Site?
- What Is the Current Site Status?
- EPA’s Involvement at the Site
- Operable Units (opens new page)
- Cleanup Progress (opens new page)
The Allied Paper Inc./Portage Creek/Kalamazoo River Superfund Site is located in Allegan and Kalamazoo Counties, Michigan. The site includes soil and sediment contamination in disposal areas, paper mill properties, about 80 miles of the Kalamazoo River (from Morrow Dam to Lake Michigan), adjacent riverbanks and contiguous floodplains, as well as a 3-mile stretch of Portage Creek. EPA has identified six areas, or operable units (OUs), requiring cleanup. Cleanup has taken place at three of the six areas; operation and maintenance activities and groundwater monitoring are ongoing at these locations. Final cleanup decisions have not been made at the remaining three OUs. However, several interim cleanup actions have been conducted.
At this time, the site is divided into six 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;
- OU #5, Portage Creek and Kalamazoo River sediments; and
- OU #7, Plainwell Mill
What Is Being Done to Clean Up the Site?
The site is being addressed through federal, state and potentially responsible party (PRP) actions. EPA has completed remedies for three of the six OUs and conducted several other interim actions to eliminate PCB sources from entering the Kalamazoo River.
EPA holds routine public meetings updating stakeholders on site activities.
The State of Michigan fish advisory signs are posted throughout the Kalamazoo River warning those who may desire to consume fish.
EPA has conducted several five-year reviews of the site’s remedy for the three areas where remedial action has taken place. These reviews ensure that the remedies put in place protect public health and the environment, and function as intended by site decision documents. The most recent review concluded that response actions at the site are in accordance with the remedy selected by EPA and that the remedy continues to be protective of human health and the environment in the short term. Continued protectiveness of the remedy requires implementation and maintenance of each component of the selected remedy, including any necessary institutional controls and proper maintenance of landfills at the site.
What Is the Current Site Status?
March 2017 Update
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 2-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 Work should start in 2018. On December 21, 2016 EPA issued a Unilateral Administrative Order to Georgia-Pacific, International Paper and Weyerhaeuser to conduct the work specified in the ROD.
In February 2016, EPA approved the Area 3 site investigation report. This report also shows high levels of PCB-contamination in soil and sediment. (Area 3 is the Kalamazoo River between the Otsego City Dam and the Otsego Township Dam.) In June 2016, Georgia-Pacific submitted the Alternative Screening Technical Memorandum, which evaluates various technologies that may be available to manage contamination in this area. In January 2017, EPA provided comments on the ASTM document, and the Area 2 Feasibility Study report, which evaluates cleanup alternatives, is due to EPA on October 2, 2017. In August 2016, work began on a Time-Critical Removal Action in the Kalamazoo River upstream of the Otsego Township dam and the M-89 bridge (see Otsego Township Dam - Time-Critical Removal update below).
Georgia-Pacific submitted the draft Area 4 site investigation report in September 2017. This document shows where and how soil and sediment sampling was conducted in Area 4 of the river. (Area 4 is the Kalamazoo River between the Otsego Township Dam and Trowbridge Dam.) This document is currently being reviewed by EPA.
In November 2016, Georgia-Pacific submitted the work plan for the investigation of Area 5 (Area 5 is the Kalamazoo River between the Trowbridge Dam and Allegan City Dam.) This officially started the Area 5 investigation. Field investigations will begin in 2017.
March 8, 2017 Public Meeting Presentation and Handout
- Area 2 Feasibility Study Meeting Presentation (PDF) (43pp, 17MB) March 8, 2017
- Kalamazoo River Area 2 Cleanup Alternatives (PDF) (2p, 3MB)
Allied Paper Landfill Update
EPA has been working with the bankruptcy Trustee for Allied Landfill to implement the remedial design for the remedy selected in the September 21, 2016 Record of Decision. The remedy includes consolidation and capping of the waste into a 27-acre area and long-term groundwater monitoring.
- Operable Unit 1 - Allied Landfill Record of Decision September 2016
Otsego Township Dam - Time-Critical Removal
Dredging work started in August 2016 in the first "Bank Removal and Stabilization Area" (BRSA) near the Pine Creek dam. Nearly 3000 feet of riverbank was cleaned up with the removal of over 7000 tons of PCB-contaminated soils and sediments. Over the winter months, land clearing and staging area and access road construction will occur to prepare for cleanup along three additional BRSAs to be addressed in early 2017. Planning for the remaining BRSAs and removal of the temporary water control structure is underway with the expected completion of the project by mid-2018.
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 Work Plan and Pre-Design Investigation Work Plan were finalized in September, and the Pre-Design Investigation Report is expected to be submitted to EPA in Spring 2017.
The site’s long-term remedy includes controlling and eliminating sources of PCB contamination into the River. Cleanup has taken place at three of the site’s six OUs (OU2: Willow Boulevard and A-Site landfill; OU3: King Highway Landfill: and OU4: 12th Street Landfill). Operation and maintenance activities and groundwater monitoring are ongoing at these locations.
Final cleanup decisions have not been made at the remaining three OUs. However, several interim cleanup actions have been conducted.
EPA’s general cleanup approach for the Kalamazoo River is to first eliminate ongoing sources of PCBs, which includes the existing landfill OUs and paper mill properties (to ensure they are not a source of PCBs to the river) as well as exposed paper wastes along the river banks and flood plain soils (or impoundments), and then to address in-stream sediments. The exposed paper wastes are located behind State-owned and privately-owned dams along the river. Generally, EPA's cleanup will begin upstream and work downstream on a reach-by-reach and dam-to-dam basis.
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 (at the time) of actions under the state-lead RI/FS, EPA entered into 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 on-site 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 within OU #1. PCB concentrations remaining in the Bryant Mill Pond and adjacent floodplain soils 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 were completed include:
• Sheet pile and temporary cap installation at the Willow Blvd/A-Site Landfill (OU #2) to prevent direct erosion into the river.
• Sheet pile installation at the Allied Paper Landfill (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, Michigan. 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 50 ppm, which are considered non-hazardous waste and which represented 80 percent of the waste material, were disposed at Allied Waste's C and C Landfill near Marshall, Michigan, and its Ottawa Farms Landfill near Coopersville, Michigan. 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, Michigan.
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. This removal action project began in August 2009 approximately three miles upstream of the earlier Plainwell Dam cleanup, and included a two-mile stretch of the Kalamazoo River. The project was completed in December 2010. Approximately 11,000 linear feet of riverbank was cleared, excavated and restored, with approximately 18,000 cubic yards of soil and debris disposed off-site at the Allied Waste C&C Landfill in Marshall, Michigan, and at Ottawa County Farms Landfill in Coopersville, Michigan. This action removed 90 percent of the PCB-contaminated soil from the area at a cost of about $10 million.
In July 2011, EPA signed an Action Memorandum to conduct a time-critical removal action along a 1.8-mile stretch of Portage Creek from Alcott Street to the confluence of the Kalamazoo River. EPA began implementing this PCB hot spot excavation project in September 2011. In 2012, EPA removed 13,000 cubic yards of PCB-contaminated sediment and soil from select areas within Portage Creek upstream of Stockbridge Avenue to Vine Street. This included the most contaminated areas of Portage Creek near Upjohn Park and Axtell Creek. EPA also conducted sampling in nearby Upjohn Park and determined no PCBs were present in park soil. In 2013, EPA continued excavation of the remaining downstream contaminated portions of Portage Creek. The cleanup work, which was originally expected to be completed during the summer of 2014, was completed ahead of schedule in November 2013, with final restoration activities completed in 2014. A total of 23,700 cubic yards of contaminated soil and sediment were removed at a cost of about $16 million.
OPERABLE UNIT 1: ALLIED LANDFILL
The Remedial Investigation Report developed for the site by MDEQ was finalized and approved by EPA in March 2008. A groundwater investigation to determine the impacts, if any, from the Allied Landfill (OU #1) was completed in the summer of 2009. The groundwater investigation confirmed the conclusions in the RI Report that groundwater from OU #1 is flowing toward Portage Creek. In October 2009, Millennium Holdings submitted the draft Feasibilty Study Report for OU #1 which examined a range of cleanup alternatives. As a result of the April 23, 2010, Lyondell bankruptcy settlement, Millennium Holdings ceased work at OU #1 and approximately $50 million was placed in a trust to pay for the remaining work at OU #1. EPA completed the Feasibility Study in January 2014. EPA held several public availability sessions and conducted site tours of the Allied Landfill, including discussing potential cleanup alternatives, in 2013 and 2014. EPA continues to engage the public and the City of Kalamazoo throughout the remedy selection process. A release date for a proposed cleanup plan for the Allied Landfill has not yet been determined, but it is anticipated in fall 2015. Read more at Allied Paper Landfill/Bryant Mill Pond Area Cleanup Website.
OPERABLE UNIT 2: WILLOW BOULEVARD AND A-SITE LANDFILL
The Willow Blvd/A-Site Landfill 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 implementation of the cleanup was approved by a federal District Court. Under the legal agreement, Georgia-Pacific agreed to consolidate waste materials, construct a permanent landfill cap, and install a groundwater monitoring system. The design work was completed in 2010 and construction activities began in April 2011. Capping activities at Willow Bouldevard and A-Site were completed in the fall of 2013. Long-term monitoring of groundwater will continue into the future.
OPERABLE UNIT 3: KING HIGHWAY LANDFILL
Cap construction at the King Highway Landfill was completed in the fall of 2001. During 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.
OPERABLE UNIT 4: 12th STREET LANDFILL
In September 2001, EPA signed the Record of Decision for the 12th Street Landfill. The remedy includes excavation of PCB residuals that have migrated from the landfill and consolidation of those residuals back into the landfill, stabilization of the side slopes of the landfill, installation of a cap, and long-term monitoring of groundwater. Weyerhaeuser conducted the cleanup, with oversight by EPA and MDEQ. Landfill consolidation and capping was completed in December 2010. Landfill cap maintenence activities were conducted in the summer of 2011 and long-term monitoring of groundwater will continue into the future.
To accommodate the channel diversion as part of the TCRA near the Plainwell Dam (discussed above under "Interim Actions"), the slope of the 12th Street Landfill adjacent to the Kalamazoo River was reshaped, upgraded, stabilized and restored in 2007. As a result of this work, contamination adjacent to the river along the 12th Street Landfill was removed.
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, Michigan (as described above under “Interim Actions”).
Under the second 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 on Portage Creek from Cork Street to the confluence with the Kalamazoo River. Although large amounts of data had been obtained throughout the river, numerous areas needing further investigation were identified. The Kalamazoo River was divided into seven areas. The status of work in the various areas of the river is as follows:
- 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. Sampling has been completed, and EPA approved the supplemental Remedial Investigation (SRI) Report for Area 1 in June 2012. EPA subsequently approved the final Feasibility Study (FS) Report in November 2014. The FS evaluates potential cleanup alternatives. EPA proposed a remedy for Area 1 in May 2015 and anticipates a final remedy decision in fall 2015.
- The draft SRI Report for Area 2, which includes a 1.8-mile stretch of the Kalamazoo River from the former Plainwell dam to the Otsego City dam, was submitted to EPA for review in December 2012. EPA disapproved the draft SRI Report in April 2013, a revised SRI Report in February 2014, and a newly-revised SRI Report in July 2014. The latest version of the revised SRI Report was submitted to EPA for review in May 2015.
- Initial sampling for the supplemental RI in Area 3, which includes a 3.4-mile stretch of the Kalamazoo River from the Otsego City dam to the Otsego dam, was completed in October 2012. Additional sampling in Area 3 was completed in the summer of 2013. The Area 3 draft SRI Report was submitted to EPA for review in March 2014. EPA submitted preliminary comments on the draft report in August 2014 and a revised report is expected in July 2015.
- Planning for the supplemental RI/FS in Area 4, which includes a 4.7-mile stretch of the Kalamazoo River from the Otsego City dam to the Trowbridge dam, known as the Trowbridge Impoundment, began in December 2012. A work plan to conduct field investigations was approved by EPA in June 2013. It is anticipated, given the large size of this impoundment, that the field investigation will take 3 years to complete. In 2014, Georgia Pacific, with oversight from MDEQ and EPA, conducted field reconaissance work and conducted the first phase of sampling. Phase 2 sampling will occur in the summer/fall of 2015 and the RI report will be submitted to EPA in spring 2016.
Several old paper mills exist along the Kalamazoo River. EPA is investigating these areas to determine whether the mill properties, although inactive, are a source of PCB contamination to the river.
Operable Unit 7: Plainwell Mill
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 were removed. The first phase of the Remedial Investigation, a cursory groundwater investigation, was completed in December 2008. Weyerhaeuser subsequently conducted Phase 2 of the RI at the Plainwell Mill in the summer of 2011, and submitted the draft RI Report to EPA in August 2011. Additional soil and groundwater sampling as part of Phase 2 of the RI was completed during the summer of 2012. The revised RI Report for the Plainwell Mill was submitted to EPA for review in November 2012 and approved in the summer of 2013. EPA subsequently approved the FS Report, which evaluates various cleanup alternatives, in May 2015. 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. Weyerhaeuser Paper submitted to EPA the Remedial Design Work Plan in March 2016. EPA has provided comments to Weyerhaeuser on the plan. A Pre-Design Investigation is expected to be conducted this fall.
Other Mill Properties
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.
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. On April 23, 2010, the US Bankruptcy Court approved Lyondell's reorganization plan. Millennium Holdings ceased all work at the site. Part of the settlement included a $50 million trust being established for cleanup of OU #1 and a $50 million cash settlement to be used for cleanup of the entire site. Georgia-Pacific is addressing its obligations to complete the supplemental RI/FS according to the 2007 AOC. All work on the project under the two AOCs signed with EPA in 2007 is proceeding according to schedule. EPA is currently working with Georgia-Pacific, MDEQ, and other stakeholders to ensure that the cleanup of the Kalamazoo River site continues.
EPA’s Involvement at the Site
EPA proposed the site to the National Priorities List (NPL) in May 1989 and finalized the site on the NPL in August 1990.
In February 2007 two Administrative Orders on Consent (AOCs) were signed by both the U.S. 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, Michigan. (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.
This site is being addressed through federal, state, and potentially responsible parties' actions. Currently EPA is the lead Agency for OUs 1, 2, 4, 5 and 7. MDEQ is the lead Agency for OU 3: King Highway Landfill.
During cleanup, a site can be divided into a number of distinct areas depending on its complexity. These areas, called operable units (OUs), may address geographic areas, specific problems, or areas where a specific action is required. Examples of typical operable units include construction of a groundwater pump and treatment system or construction of a cap over a landfill.