oEPA

United States
Environmental Protection
Agency

For more information...

on the Kalamazoo River dams,
contact:

Don de Blasio

Community Involvement

Coordinator

(312) 886-4360

(800) 621-8431 Ext. 64360

deblasio.don@epa.gov

Shari Kolak

Remedial Project Manager
(312) 886-6151
(800) 621-8431 Ext. 66151
kolak.shari@epa.gov

Site-related documents may
be reviewed at:

Kalamazoo Public Library
315 South Rose
Kalamazoo, Mich.

Waldo Library

Western Michigan University
1903 West Michigan Avenue
Kalamazoo, Mich.

Charles Ransom Library
180 South Sherwood
Plainwell, Mich.

Allegan Public Library
331 Hubbard Street
Allegan, Mich.

Otsego District Library
219 South Fanner Street
Otsego, Mich.

Saugatuck-Douglas Library
10 Mixer Street
Douglas, Mich.

When possible, site information is
also posted to:

http://www.epa.gov/region5/sites

The Kalamazoo River Dams:
Questions and Answers

Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund Site

Kalamazoo, Michigan	September 2003

U.S. Environmental Protection Agency has been recently involved in several
meetings sponsored by local environmental groups for the Allied Paper Inc./
Portage Creek/Kalamazoo River Superfund site. A concern frequently raised at
these meetings is the future of the six dams in the 80-mile stretch of the river.
Here are the answers to many of those questions.

Has EPA decided whether the dams should stay in place?

No, EPA has not made a decision about whether the dams should stay in place
or be removed. EPA recently sent Michigan Department of Environmental
Quality a draft Feasibility Study for the first two exposed sediment impound-
ments on the Kalamazoo River (Plainwell and Otsego City). MDEQ is in the
process of reviewing and commenting on this draft. The draft FS included a
draft "alternative array," which described seven remedial alternatives being con-
sidered for the first two impoundments. EPA will eventually select the remedy
for these impoundments from the alternative array after it is finalized. Because
the federal and state agencies are still deliberating about the draft FS (includ-
ing the alternative array), it is not yet available to the public. EPA can assure
you, however, that one of the alternatives the Agency is considering for these
impoundments involves the removal of the Plainwell and Otsego City dams.
After the alternative array is final, EPA will evaluate the alternatives accord-
ing to the Superfund remedy selection process provided in the National Oil and
Hazardous Substances Pollution Contingency Plan, referred to as the NCP

How does this issue (the dams) fit into Superfund's cleanup plan
selection process?

To fully understand the importance of this issue, let's first examine the process
EPA uses to choose a cleanup plan. The NCP provides nine criteria to evaluate
EPA's options in cleaning up a Superfund site. The first two criteria - called
"threshold criteria" - are the most important. Every alternative must meet them
in order to be eligible for selection. The first threshold criterion is overall pro-
tection of human health and the environment, and the second is compliance with
applicable or appropriate and relevant legal requirements. So the question is,
must be dams be removed to ensure adequate protection of people and the envi-
ronment? EPA is studying this question very carefully.

The next five NCP criteria in the cleanup decision process are the "primary bal-
ancing criteria." After the threshold criteria are met, these are the most impor-
tant in comparing alternatives. The five are:

•	0 long-term effectiveness and permanence

•	0 reduction of toxicity, mobility or volume through treatment

•	short-term effectiveness

•	implementability

•	cost


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The question of dams removal is relevant to all of these crite-
ria. EPA must now:

•	0 evaluate whether the dams must be removed to ensure

long-term effectiveness of the cleanup

•	0 evaluate the effects of dam and sediment removal on

people and the environment

•	0 assess the difficulty of removing the dams

•	0 determine the cost associated with dam removal.
CERCLA (the Superfund law) and the NCP require all clean-
ups to be "cost-effective," which means that costs must be
proportional to the plan's overall effectiveness. EPA is study-
ing this issue too. There is more discussion on this point in
other answers in this fact sheet.

The last two NCP criteria, called "modifying criteria," are
state acceptance and community acceptance. They're called
"modifying" because EPA can't thoroughly evaluate them
until a proposed plan is issued. In this case, for example, EPA
knows that the state and many people in the community favor
removing the dams on the Kalamazoo. But since no plan
has been proposed and no details on possible alternatives
released, EPA cannot know for sure how any of the options
will be received. EPA can't evaluate state or community
acceptance until these two important stakeholders have the
opportunity to consider all the relevant information.

What has EPA done about dams at other sediment
sites?

In some cases, EPA required the dams remain in place, while
at other sites, EPA has required the dams to be removed.
Every situation is different, and every decision is based pri-
marily on what's needed to protect people and the environ-
ment.

Can EPA implement a cleanup plan without state
approval?

EPA always prefers to work with its state partners, so EPA
strives to build consensus. But EPA doesn't necessarily need
state approval of a cleanup plan to issue a final decision.
There are a few things to remember:

•	0 If Superfund money is to be used to pay for a cleanup,

the state in which the site is located must provide
certain assurances about cost-sharing and long-term
operation and maintenance before work can begin.

•	0 If Superfund money is used, the state is usually

required to pay 10 percent of the cleanup costs, and
pay for long-term operation and maintenance.

•	0 If a Superfund facility was publicly operated at the

time of disposal, the state is potentially responsible for
half the cleanup costs.

•	0 If those responsible for the contamination conduct or

pay for the cleanup, then work can proceed without
state approval. State assurances on cost-sharing are not
necessary.

If EPA decides the dams should stay in place, is there
anything the state can do to change EPA's decision?

Yes. Under the NCP, the state can ask EPA to amend its
"record of decision," which is a public document that details
the cleanup plan for the site. If EPA agrees that the changes
requested by the state are necessary to provide adequate
protection of human health and the environment, then EPA
will amend its record of decision. If EPA concludes that the
state's requested changes are an "enhancement," that is, they
go beyond what the NCP requires, then EPA may amend the
record of decision if the state agrees to pay all additional
costs for the changes the state wants.

Is there any way the state can get the dams removed,
other than through the Superfund cleanup process?

Yes. The state and other "Natural Resource Trustees," such
as U.S. Department of the Interior, can make a claim for
damages to the state's natural resources as a result of the
PCB contamination in the Kalamazoo River. The trustees are
assessing those potential damages now. A successful claim
can mean substantial payments to the trustees. The money is
usually used for restoration projects, and removing dams on
the Kalamazoo could be one of those projects.

What is EPA doing to evaluate the dam issue?

EPA is doing a thorough internal evaluation. EPA is also pay-
ing for a study by U.S. Geological Survey to determine what
would happen to the sediment behind the three state-owned
dams if the dams were removed. USGS is trying to deter-
mine where the sediment would erode and aggrade within
the current channel if the dams were to catastrophically fail,
and how much sediment would become mobile if this were
to happen. USGS is also studying other effects of removing
the dams, and they are collecting data on the sediment and on
discharges into the river at two points in the study area.

What questions will the USGS study not resolve?

•	0 What would happen to Allegan Dam if the three state-

owned dams are removed?

•	0 What would happen to Lake Allegan, which already

has sedimentation issues, if upstream dams are
removed?

•	0 Where could EPA dispose of significant quantities of

contaminated sediment removed from the river? How
much would that cost?

2


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• 0 How long would the dredging, excavation and disposal
of floodplain soil and sediment take before the dams
could be removed? EPA believes that such dredging
and excavation could take several years.

When is the USGS study due to be completed?

EPA expects an initial draft in September 2003. The final
USGS report is not due until September 2004.

What if EPA issues a proposed plan or record of
decision before September 2004 that does not
involve dam removal, but the USGS study shows
that removing the dams would improve long-term
effectiveness of the river cleanup, and not cost
significantly more than leaving the dams in place?

If EPA issues a proposed plan or record of decision that does
not involve dam removal before all USGS studies are com-
pleted, but the USGS studies contain information that makes
EPA believe that it needs to reconsider its cleanup plan in any
way (including dam removal), then EPA will re-evaluate it.
Under the NCP, EPA can always revise a proposed plan and
amend a record of decision based on important new informa-
tion.

Can EPA require that the dams stay in place? Can
EPA leave contaminated sediment in place if the state,
which owns the property, wants it all removed?

EPA hasn't decided whether the dams should stay or be
removed. But legally, EPA can require - as part of its pro-
posed cleanup plan - that waste stays on-site. Again, the
effect on people and the environment is a key issue. EPA
policy is against moving wastes from a contaminated area
to a clean area. The NCP process actually favors leaving
untreated waste at the site, because moving waste from one
site to another is not always the right thing to do. EPA can
also require - as part of the cleanup plan - that the dams be
repaired and maintained to keep the river in its present chan-
nel and prevent erosion of soil with high levels of PCBs.

If EPA requires the dams to remain in place, who will
pay for the necessary repairs and long-term operation
and maintenance of the dams?

The potentially responsible parties.

If EPA requires the dams to remain in place, does
that mean PCB-contaminated soil and sediment will
remain forever?

The risk to people and the environment will determine
whether contaminated soil and sediment remain in place. Any
decision on removing the dams will ensure that floodplain

soil and sediment with PCBs above the ecological risk value
and the human health risk value will either be removed or
treated on-site. The ecological risk range for floodplain soil
is 6 to 8 parts per million and for in-stream sediment is 0.5
to 0.6 ppm. The human health risk value for floodplain soil
is 23 ppm. An example of an on-site solution is a cap, or an
impenetrable barrier over the contaminated material.

What happens if the state decides to just take down
these dams?

The state can't legally do that because of provisions of the
Superfund law. The state is an owner of part of a Superfund
site, and property owners need EPA's approval to do any
cleanup work if EPA has already started a process called a
"remedial investigation and feasibility study." Removing
the dams would fall into the category of cleanup work. See
Section 122(e)(6) for the relevant legal citation.

What is EPA considering when looking at the cost of
removing the dams?

Because the state-owned dams are already partly dismantled,
the major cost of removing them is the cost of transport-
ing and disposing of contaminated sediment and soil.
Transportation and disposal costs are estimated to range
from 1 to 3 times the cost of dredging, depending upon the
location of the final disposal site. A key problem at all sedi-
ment sites is how to dispose of the contaminated materials.
At some sites - such as the Fox River in Wisconsin, where
the disposal area is quite close to the site - sediment will
be pumped through a temporary pipeline directly from the
river to the disposal site. This results in a significant cost
savings, especially if there's a large amount of sediment. At
other sites, there's no proper disposal area nearby. So after
the water is drained and treated, the sediment must be hauled
- usually by truck - to a distant location. The cost of haul-
ing sediment to a remote location can be quite high. To date,
EPA does not have a nearby disposal area for the contami-
nated sediment and soil that would need to come out of the
Kalamazoo in the event of dam removal.

3


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oEPA

United States
Environmental Protection
Agency

Region 5

Office of Public Affairs (P-19J)	CI DOT ^^1 AOO

77 W. Jackson Blvd.	NKol ULAOO

Chicago, IL 60604

RETURN SERVICE REQUESTED

ALLIED PAPER, INC./PORTAGE CREEK/KALAMAZOO RIVER
SUPERFUND SITE: The Kalamazoo River Dams: Questions and Answers

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