EPA - KALAMAZOO RIVER SUPERFUND SITE - ALLIED PAPER …

[Pages:4]us EPA RECORDS CENTER REGION 5

KALAMAZOO RIVER SUPERFUND SITE

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494691

ALLIED PAPER, INC. OPERABLE UNIT

FREQUENTLY ASKED QUESTIONS - REMEDIAL INVESTIGATION

REPORT

JULY 2009

What is the current status of work at the Allied Site? During the past decade or more, a variety of investigation and cleanup efforts have been completed at the Allied Paper, Inc. Operable Unit of the Kalamazoo River Superfund Site (Allied Site). These efforts have included extensive environmental sampling; a number of targeted environmental cleanup projects including the removal of sediments in the former Bryant Mill Pond Area of Portage Creek in 1998-1999; and operation and monitoring of a groundwater collection system installed along Portage Creek. The sediments excavated as part of the Bryant Mill Pond cleanup were placed, with other paper-making residuals previously deposited at the site, under a protective cap/cover system built according to specifications established by the State of Michigan.

Environmental investigation results and monitoring data associated with the various cleanup activities are summarized in the March 2008 Remedial Investigation Report (R1 Report), released by the Michigan Department of Environmental Quality (MDEQ). Read below for more information on the RI Report.

Is the situation at the Allied Site stable? Yes. Most of the paper wastes at the property that contain measureable levels of PCBs (or polychlorinated biphenyls), including those that were in the former Bryant Mill Pond, have been consolidated beneath a cover layer that is consistently monitored and maintained to verify it is functioning as expected. Further, the entire property is fenced in, and public access is restricted. Recent fish and water data from Portage Creek show PCB concentrations have improved substantiallyTollowing completion of the Bryant Mill Pond cleanup in 1998-99 and are continuing to decline.

What are the next steps in the cleanup process? With the completion of some recent groundwater assessment work, the "Feasibility Study" (FS) phase will begin shortly. At a Superfund Site, the FS work is carried out to develop and evaluate a range of options for a final cleanup plan. The results of the assessment are presented in an FS Report. The U.S. Environmental Protection Agency (USEPA - the lead regulatory agency for the Allied Site), will review and approve the FS Report, then develop a Record of Decision, or ROD, to formalize the final cleanup approach for the Allied Site. USEPA may be prepared to publish the ROD for public review and comment in 2010.

What is the RI Report? RI stands for Remedial Investigation. The RI Report is a summary of the investigations and cleanup work completed to date at the Allied Site. The key components of an RI Report are;

? A summary of environmental data collected during the remedial investigations ? An assessment of the nature and extent of environmental issues at the site ? ' An assessment of potential risks to public health and the environment ? A sununary of interim cleanup or response actions taken during the remedial investigation process ? A description of additional data that may be necessary to develop and evaluate cleanup options

Between 1993 and 2003 (the period covered in the RI Report), several phases of investigation were completed that included extensive sampling and analysis of groundwater, soils, sediment, surface water, fish, and air at the Allied Site.

Who produced and approved the RI Report? The MDEQ and the USEPA worked together during the past several years to finalize the RI Report At Superfund Sites where there is more than one regulatory agency involved, work is often carried out in this type of collaborative manner.

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Working Draft

KALAMAZOO RIVER SUPERFUND SITE

ALLIED PAPER, INC. OPERABLE UNIT

FREQUENTLY ASKED QUESTIONS - REMEDIAL INVESTIGATION

REPORT

JULY 2009

What infonnation in the RI Report is relevant to me?

The RI Report is indeed long -more than 700 pages. This type of extensive documentation is not unusual at a property like the Allied Site where work has been underway for more than a decade. To help sift through the volumes of material and highlight information that may be most important to our neighbors, we have prepared "Neighbor Packets" that contain:

? An individual property data sheet (for fence-line neighbors only) ? This list of frequently asked questions ? An overall summary of the RI Report ? A timeline for the Allied Site

The entire report is always available on USEPA's website ( scroll down to the "Technical Reports" section and look for the "Allied Paper, Inc. Operable Unit Remedial Investigation Report - March 2008"). You can also contart the project representatives listed below with questions regarding the Allied Site.

Why did it take so long to finalize the RI Report? It takes time to plan and carry out the variety of investigations that are needed to collect and analyze the data necessary to identify the nature and extent of environmental conditions, and then develop the reports documenting the findings. At the Allied Site, a variety of interim cleanup actions have also been completed during the RI process, and results of those actions also need to be considered before moving into the FS stage. It is often useful to collect samples over the course of several years at many different locations so that trends over time can be studied. For instance, in the case of the groundwater analysis. Millennium and MDEQ installed approximately 180 different monitoring and collection wells, obtaining numerous samples over the years.

Are there any risks to people who live near the Allied Site? As described above, the situation at the Allied Site is stable. Based on the samples of surface soils collected from residential properties near the Allied Site, PCBs are NOT present above the thresholds defined as safe by MDEQ for residential properties. The majority of PCBs that remain at the Allied Site are generally isolated under a cap / cover system, and access to the property is restricted at all times to prevent people from accidentally entering the area.

As part of the FS process, USEPA will continue to evaluate the data from the Allied Site and the range of cleanup options that will be developed and evaluated in the FS Report will be specifically designed to provide long-term protection for both human health and the environment.

What is the current state of the air, groundwater, surface water, and soil in and around the Allied Site?

The detailed results of years of sampling efforts are described in the RI Report and smnmarized in a Neighbor Packet (for fenceline neighbors). Overall results from more than a decade of sampling and analysis show:

? None of the 72 air samples taken have exceeded relevant screening levels for PCBs. Based on the air sampling data and other information,USEPA concluded that inhalation of PCB is not an exposure pathway of concern at the Allied Site (USEPA 2009).

? PCBs, where detected in surface water (Portage Creek) and groundwater, are at relatively low concentrations; and groundwater concentrations from the most recent sampling events were generally below relevant standards set by USEPA and MDEQ. The Michigan Department of Community Health concluded that surface waters of the nearby Kalamazoo River containing similarly low PCB concentrations were safe for swimming and recreational use pl.html#conc

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KALAMAZOO RIVER SUPERFUND SITE ALLIED PAPER, INC. OPERABLE UNIT FREQUENTLY ASKED QUESTIONS - REMEDIAL INVESTIGATION

REPORT JULY 2009

? Cleanup steps taken to date have largely addressed the presence of uncontrolled PCBs in soils at the site. The Bryant Mill Pond remedial action and disposal area capping activity cleaned up Portage Creek and secured the majority of PCB-impacted soil and paper residuals at the site from a risk exposure perspective.

? In most other areas where paper-making materials are present, there is extensive vegetation and soil cover. These areas remain undisturbed due to controlled access to the site, while remedial alternatives are being evaluated in the Feasibility Study.

? Regular monitoring and maintenance of the capped areas is ongoing

Is my drinking water safe from PCBs?

Yes. In 2008, the City of Kalamazoo shared their test data with Millennium and USEPA. These test results confirmed that over the past 50 years, there has been no record of PCBs ever being detected in the City's drinking water supply or in the city well fields. This is consistent with historical data collected at the Allied Site, showing that the groundwater flows to Portage Creek and not to the City's wellfield. Historical data from the City of Kalamazoo show that during the past 50 years, there has been no record of PCBs ever being detected in the City's drinking water supply or in the city well fields. This is consistent with historical data collected at the Allied Site, showing that the groundwater discharges to Portage Creek and not to the City's wellfield. A recent investigation, done with oversight by USEPA and MDEQ, that reinforces the groundwater "pathway" is to Portage Creek and shows that PCBs are unlikely to migrate to the deeper groundwater, where the City draws its water supply.

Are there plans to dispose of additional materials in the Allied Site? No. While the final cleanup plan for the Allied Site is yet to be developed and finalized, there are no plans to dispose of any additional materials at the Allied Site.

What is the potential for future redevelopment of the Allied Site? Evaluating potential future land uses is part of the FS process that is expected to unfold over the next several months. USEPA will have the lead role in this effort, and there will be opportunities for public input. The City of Kalamazoo recently completed its own planning process for the Portage Creek corridoran area that includes the Allied Site and surrounding areas. Information about that process and the City's future reuse plan is available at

Will the FS look at complete removal of all material from the Allied Site? The first step in the FS process is the"screening" or selecting of various remedial altematives to be evaluated in the FS. It is that process that will determine what remedial options will be further examined in theFS.

What are PCBs?

PCBs are the primary chemicals of concern at the Allied Site. PCBs are a group of chemicals produced in the United States from 1929 to 1978 for use primarily as industrial coolants, insulators and lubricants. Between 1957 and 1971, PCBs were also used in the manufacture of carbonless copy paper. While carbonless copy paper was not made in the Kalamazoo River valley, a number of local paper mills did recycle waste paper from govermnent offices, schools, and businesses that included PCB-containing carbonless copy paper. When paper waste containing the carbonless copy paper was recycled, PCBs were inadvertently released to the environment.

Chemically, PCBs are very stable, and this stability was a critical component in their wide-ranging commercial applications. This stability is also the reason why PCBs are relatively persistent in the environment PCBs tend to bind tightly to organic material such as soil and sediment, and they accumulate

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KALAMAZOO RIVER SUPERFUND SITE ALLIED PAPER, INC. OPERABLE UNIT FREQUENTLY ASKED QUESTIONS - REMEDIAL INVESTIGATION

REPORT JULY 2009

in the fatty tissue of fish and other animals. The potential adverse environmental and health effects of PCBs were not well imderstood until 1977, when the government banned most uses of PCBs. PCBs are classified as probable human carcinogens.

Who owns the Allied Site? The Allied Site is owned by LeMean Property Holdings Corporation, a subsidiary of Millennium Holdings, LLC (Millennium). Millennium and its subsidiaries are debtors in Chapter 11 bankruptcy proceedings.

What can I do to find out more? Visit USEPA's website (region5/kaIproject) to read technical reports on the Allied Site and stay up to date on the Superfund Site. USEPA also maintains collections of documents related to the Kalamazoo River Superfund Site at two area libraries: Waldo Library (903 W. Michigan Ave) and Kalamazoo Public Library (315S. Rose St). You can also contact the project representatives listed below.

Allied Paper, Inc. Operable Unit Project Representatives:

Michael Berkoff Remedial Project Manager USEPA Region 5 Superfimd Division Remedial Response Section #2 77 West Jackson Boulevard (SRF-6J) Chicago, IL 60604-3507 Tel. 312.353.8983 Berkoff.Michael@

Paul Bucholtz Project Manager Michigan Department of Environmental Quality 525 West Allegan Street P.O. Box 30473 Lansing, MI 48909-7973Tel: 517.373.6808 Bucholtzp@

Stephen Weishar Manager, Retained Liabilities & Remediation Millermium Holdings, LLC One Houston Center, Suite 700 1221 McKiimey Street Houston, TX 77010 Tel. 713.309.7431 Stq3henWdshar@

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