&EPA
United States
Environmental Protectior
Agency
You are invited
EPA invites you to discuss the proposed
cleanup plan for the Allied Paper
Landfill site.
EPA will hold a public meeting,
Thursday, Nov. 19, at 6 p.m., at the
Washington Writers" Academy
cafeteria, 1919 Portage St. EPA
representatives will present details of
the plan, and oral comments will be
accepted and recorded by a court
reporter.
Also come to a community roundtable
event: Thursday, October 15, 6 p.m.
at the Washington Writers" Academy
cafeteria, 1919 Portage St. or
Thursday, October 22, 6 p.m. at the
Hispanic American Council, St. Joseph
Parish Gymnasium, 930 Lake St.
EPA representatives will be available
to answer questions and participate in a
discussion with the community about
the plan.
Read the proposed plan
The detailed plan is available for
review in the information repositories
and on the Web (see box, Page 4).
Public comment period
You may comment on the proposed
plan from Sept. 30 through Dec. 1.
There are several ways to offer
comments:
• Fill out and mail the enclosed
comment form, or submit it at the
public meeting.
• Orally or in writing at the public
meeting.
• Goto:
www.epa.gov/region5/cleanup/alliedpa
per/pubcomment.html.
• Send a fax to 989-401-5508.
EPA may modify the plan or select
another solution based on new
information or public comments, so
your opinion is important.
EPA Proposes Cleanup Plan
for Allied Paper Landfill
Allied Paper/Portage Creek/Kalamazoo River Site
Kalamazoo, Michigan September 2015
The U.S. Environmental Protection Agency, with the Michigan Department of
Environmental Quality, plans to clean up contaminated material at Allied
Paper Landfill, a former landfill in part of the Allied Paper/Portage
Creek/Kalamazoo River Superflind Site called Operable Unit 1. The cleanup
plan includes consolidating and capping material containing PCBs and other
contaminants, and installing a groundwater monitoring network. Areas of the
former landfill would be available for future reuse and redevelopment.
Your comments are needed
EPA will accept comments on the proposed cleanup plan from Sept. 30
through Dec. 1 (see box, left). Tins fact sheet provides background
information, describes cleanup options and explains EPA"s
recommendations1. You can find more details in a document called Allied
Paper/Portage Creek/Kalamazoo River Superfund Site Proposed Plan for
Operable Unit 1 - Allied Paper Landfill, at
www.epa.gov/region5/cleanup/alliedpaper and at the local information
repositories listed on Page 4.
EPA will review all comments before making a final decision on a cleanup
plan, and will respond to comments in a document called a "responsiveness
summary." This will be part of the final cleanup plan called the "record of
decision."'
Kalamazoo River Superfund Site, Michigan
Douglas
ALLEGAN
COUNTY
' Otsego City Dan i
ainwell
Throwbridge Dam—
Otseflo Darn
BARRY
COUNTY
LAKE SUPERIOR
Font er Plainwell Dam-1
Plainwell No. 2
VAN BUREN
COUNTY
OU1
ALLIED
ALLEGAN COUNTY
KALAMAZOO COUNTY-
CALHOUN COUNTY
PAPER LANDFILL-"^"7*!
Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA known as the Superfund law) requires publication of a notice and a proposed plan. It also
requires a public comment period and the opportunity for a public meeting. This fact sheet summarizes the
technical written proposed plan and other site-related environmental reports that can be viewed at the
information repositories listed on Page 4.
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Background
Several paper mills along the Kalamazoo River and
Portage Creek recycled various types of paper stock
starting in the 1950s. This included carbonless copy
paper containing PCBs that were released into the mills"
waste streams and eventually into Portage Creek and the
Kalamazoo River.
hi 1990, the site was added to the National Priorities List
because of PCBs in the sediment, fish and surface water
of the Kalamazoo River. The site consists of 77 miles of
the Kalamazoo River and a 3-mile stretch of Portage
Creek, and is in both Allegan and Kalamazoo counties in
southwest Michigan (see map, Page 1).
This plan is for Allied Landfill, between Cork Street
and Alcott Street in Kalamazoo (see map, below). The
landfill site includes areas that are zoned for residential,
commercial and manufacturing uses, and Portage Creek
rans through the property.
Why is a cleanup needed?
There have been several cleanups at Allied Landfill since
the early 1990s to minimize exposure to PCBs and to stop
the release of contamination to Portage Creek and the
Kalamazoo River. Those actions included the removal of
146,000 cubic yards of PCB-contaminated material from
the Bryant Mill Pond (the Portage Creek floodplain within
the site boundaries) and consolidating and capping that
material on-site. This work has decreased PCB levels
significantly in Portage Creek itself and in fish.
Aerial photo of Allied Landfill atid Portage Creek
However, 1.6 million cubic yards of PCB contaminated
material in the former disposal areas pose an
unacceptable risk to people and the environment. The
plan focuses on cleaning up these areas.
Cleanup alternatives
Based on site contaminants, characteristics, overall
objectives and technology, EPA identified seven cleanup
alternatives for the site (see table, Page 5). Each
alternative was evaluated against criteria established by
federal law (see box, Page 3). However, the last two
criteria, state and community acceptance, will not be
evaluated until after the comment period and public
meeting. Each cleanup alternative, except the no-action
alternative, reduces exposure to PCBs.
MONARCH
HRDL
BRYANT
HROL/FRDLs
(capped area)
FORMER
TYPE III
LANDFILL
— FORMER
FILTER PLANT
BRYANT MILL
PROPERTY
LBG£ND
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RotdTTnM
Property lro«n Count* Tu Map
* Property Boundary
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PROPERTY
This map shows details of the Allied Landfill site.
2
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Explanation of evaluation criteria
1. Overall protection of human health and
the environment. Examines whether an
option protects both human health and the
environment. This standard can be met by
reducing or removing pollution or by reducing
exposure to it.
2. Compliance with applicable or relevant
and appropriate requirements. Ensures
options comply with federal and state
environmental laws.
3. Long-term effectiveness and permanence.
Evaluates how well an option will work over
the long term, including how safely remaining
contamination can be managed.
4. Reduction of toxicity, mobility or volume
through treatment. Determines how well the
option reduces the toxicity, movement and
amount of pollution using treatment.
5. Short-term effectiveness. Compares how
quickly an option can help the situation and
how much risk exists while the option is under
construction.
6. Implementability. Evaluates how feasible
the option is and whether materials and
services are available in the area.
7. Cost. Includes not only buildings,
equipment, materials and labor, but also the
cost of maintaining the option for the life of
the cleanup.
8. State acceptance. Determines whether the
state environmental agency (in this case the
MDEQ) accepts the option. EPA evaluates this
criterion after receiving public comments.
9. Community acceptance. Considers the
opinions of the public about the proposed
cleanup plan. EPA evaluates this criterion after
a public hearing and comment period.
EPA's recommended alternative
Based on the criteria, EPA recommends Alternative 2D,
consolidating materials to a 27-acre area, and installing a
cap and a long-term groundwater monitoring network.
Areas outside the cap would be available for
commercial/industrial redevelopment, and the capped area
would be available for some recreational reuse. Alternative
2D is protective, complies with environmental laws, and
represents the best balance of long-term and short-term
effectiveness, implementability and cost.
Alternative 2D would meet the EPA's cleanup goals for
the site because it would:
• Significantly reduce the exposure of people and
animals to contamination;
• Comply with federal and state regulations;
• Provide a cost-effective way to manage PCB
contamination; and
• Complete activities within three years.
Next steps
Before making a final decision, EPA and MDEQ will
review all comments from the public. EPA will
respond to the comments and make those responses
available in the final decision document. EPA could
change the recommended cleanup plan based on public
comments.
EPA will announce its final cleanup plan in a local
newspaper advertisement. Copies of the final plan will
be available at the information repositories (see Page
4) and at www.epa.gov/region5/cleanup/alliedpaper.
For more information, contact:
Michael Berkoff
Remedial Project Manager
312-353-8983
berkoff.michael@epa.gov
Diane Russell
Community Involvement Coordinator
989-401-5507
russell.diane@epa.gov
3
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Former Western Disposal
Sub-Area
Former Type III
Landfill Sub-Area
Former
Bryant HRDUFRDLs
Sub-Area
Residential
Sub-Area
Monarch HRDL
Sub-Area
3-D Representation of Alternative 2D
For more information
You can read documents related to the Allied Paper Landfill site at www.epa.gov/region5/cleanup/alliedpaper, or at these
information repositories:
U.S. EPA Record Center
Allegan Public Library
Waldo Library
77 W. Jackson Blvd., 7th Floor
331 Hubbard St.
Western Michigan University
Chicago
Allegan
1903 W. Michigan Ave.
Kalamazoo
Charles Ransom Library
Otsego District Library
180 South Sherwood
219 South Farmer St.
Plainwell
Otsego
Kalamazoo Public Library
Saugatuck-Douglas Library
315 South Rose
10 Mixer St.
Kalamazoo
Douglas
4
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Cleanup Alternatives Comparison Table
Cleanup Alternatives
Description
Protective
Time to
Implement
Cleanup
Short-term Impacts
Cost
1- No Action
Required baseline to con pa re with other alcematives.
Site would be revisited ever,15 years accountng 'or
minimal cost-
NO
N/A
No worker risk, but
offsite migration
rema ins.
5110.D00
2-Corsolidaton and
Capping
All Group 2 Alternatives have the 'allowing
common elements:
» Excavate contaminated materials along lagoons,
disposal areas.
• Consolidate contaminated material and backfill
with clean material.
• install a cap over consolidated areas.
» Install a long-term groundwater monitoring system.
• install site restrictions to lim it com mercia! and
residential use.
» Restore wetlands.
• Monitor underlying groundwater.
Altemacve 2A:
conso;idate and cap
two areas [Monarch
and Operaronal
areas)
nstall two separate caps over Monarch area and
Operaronal areas.
res
2 years
Least impacts from
construcTon, truck
traffic, noise, dust.
544 million
Alternative 26:
consolidate and
cap one area
(Operational area)
Remove material in Monarch area and consolidate
under one cap in Qperaronal area.
yes
2 years
Some impacts due to
moving of Monarch
material.
$43 million
Altemacve 2C:
excavation and
consolidation of
contaminated
3reas a nd offsite
incineration of
excavated material
For excavated material: consolidate contaminated
material with PCB contamination levels below 500
mg/kg. and transport PCB-contaminated materia
with contamination levels above 500 mg/kg to an
offeite locaton for incineration. Remove materiai
at Monarch and consolidate under one cap in
Operational area.
yes
2 years
Some impacts due to
potent a 1 exposure
during construction and
transport offsite.
570 million
Altemafve 2D:
consolidation of
contaminated
areas into red jced
area (EPA's
reconnended
optson)
Consolidate contaminated material into a smalser
sized a res set back from Portage Creek to create an
a'ea avaiab e *or reoevelopmenta-d community
use in the future. Remove material at Monarch and
consolidate under one cap in operational area-
yes
3 years
Some impacts due to
increased excavation,
backfill volumes
and slightly longer
timeframe.
563 million
3- Removal and off-site
disposa 1 o* contami rated
material
Excavate contaminated areas and transport the
mate-ial offsite for disposal. Backfill with clean
material and install srte restrictions to limit
commercial use.
yes
5 years
Higher impacts due to
volume o£ material; high
risk of excavated material
impacting Portage Creek
and greatest amount of
truck travel for disposal
and brining backfill
material on-site.
5233 million
4- Encapsulation
containment system
» Excavate contaminated areas and consolidate the
excavated materia 1.
• Line the landfill bottom with compacted day and a
flexible synthetic material.
• Piece contaminated material in the lined area.
• Install cap over material.
• install site restrictions So limit commercial use.
• Restore wetlands and monitor groundwater.
yes
10 years
Highest impacts due
to volume of material
potentially impacting
Portage Creek and
duration, not ss many
transportation impacts
as Alternative 3 since
material is managed
at site.
5159 million
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EPA Proposes Cleanup Plan, Seeks Public Comments
Public Meeting
Thursday, Nov. 19
6 p.m.
Washington Writers' Academy
Cafeteria
1919 Portage St.
If you will need special accommodations at the meeting, contact:
Diane Russell, Community Involvement Coordinator, 989-401-5507, russell.diane@epa.gov
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Use This Space to Write Your Comments
EPA is interested in your comments on the proposed cleanup plan for the Allied Paper Landfill. You may use the space below to
write your comments. You may submit this sheet at the Nov. 19 public meeting, or detach, fold, stamp and mail. Comments must be
postmarked by Dec. 1. If you have any questions, please contact Diane Russell at 989-401-5507, weekdays 9:30 a.m. - 5:30 p.m.
Comments may also be faxed to 989-401-5508 or sent via the Web at www.epa.gov/region5/cleanup/alliedpaper and link to the
public comment form.
Name
Affiliation
Address
City
State
ZIP
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Allied Paper Landfill Comment Sheet
fold
fold
Place
First
Class
Postage
Here
Diane Russell
Community Involvement Coordinator
U.S. EPA, Region 5
Saginaw Community Information Office
804 S. Hamilton St., Suite 111
Saginaw, MI 48602
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