FAQ — Background

What is the Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund Site?
What is Superfund?
What is the KRSG?
What are the roles/responsibilities of the United States Environmental Protection Agency and Michigan Department of Natural Resources and Environment?
What are the AOCs and how are they used to guide work at the Site?
What are PCBs?
Why are people concerned about PCBs in the Kalamazoo River? Which activities are safe?
What are "bioavailable" PCBs?

What is the Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund Site?

The Allied Paper, Inc./Portage Creek/Kalamazoo River Superfund Site is located in southwest Michigan and includes the lower 3 miles of Portage Creek, 80 miles of the Kalamazoo River between Morrow Lake and Lake Michigan, and four former disposal areas and associated mill properties. The total geographic scope of the area studied for the Remedial Investigation/Feasibility Study stretches across 90 miles of river from Battle Creek to Saugatuck.

The Kalamazoo River was declared a Superfund Site because of the presence of PCBs (polychlorinated biphenyls) in the river's fish, sediment, and surface water. For more than half of the 20th century, PCBs were legally used by many industries in the manufacture of electrical components and other products that benefited from their fire retardant and other chemical properties. Between 1957 and 1971, PCBs were also used to make carbonless copy paper. Carbonless copy paper was often mixed in with the used office paper that came to the Kalamazoo area paper mills between the late 1950s and the early 1970s to be recycled into new paper products. During the recycling process, PCBs were released to the Kalamazoo River through the mills' waste streams.

Since the Site covers such a large geographical area, it is divided into several operable units, or OUs. Work at each OU can proceed on separate schedules, and as a result, extensive cleanup work has already taken place at three locations that were used as disposal sites for paper-making residuals and wastes. The status of work at these three areas is described in the FAQ for the Landfill Operable Units.

OUs at the Superfund Site include:

• OU1 — Allied Paper, Inc. Operable Unit
• OU2 — Willow Boulevard/A-Site Operable Unit
• OU3 — King Highway Landfill Operable Unit
• OU4 — 12th Street Landfill Operable Unit
• OU5 — 80 miles of the Kalamazoo River, including a stretch of Portage Creek

New investigations in a portion of OU5 (referred to as Area 1 – an 80-mile stretch of the Kalamazoo River and a stretch of Portage Creek downstream of Alcott Street) started in the summer of 2007. This work is designed to build upon the extensive information gathered at the Site between 1993 and 2006. In August 2008, USEPA set the schedule for the new investigations of the rest of OU5 (Areas 2 through 7). This information is presented on the Supplemental Investigations page.

What is Superfund?

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980. Among other things, this law provides broad federal authority to address releases or threatened releases of hazardous substances that may endanger public health or the environment. A major component of Superfund is a process for cleaning up abandoned or uncontrolled hazardous waste sites. The law provides for liability of persons responsible for releases of hazardous waste at these sites and establishes a trust fund to provide for cleanup when no responsible party can be identified.

Superfund authorizes two kinds of response actions:

• Short-term removals, where actions may be taken to address releases or threatened releases requiring prompt response. The Time-Critical Removal Action (TCRA) at the former Plainwell Impoundment is this type of response. Read more on the TCRA.
• Long-term remedial response actions, that significantly and permanently reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life threatening. These actions can be conducted only at sites listed on the USEPA's National Priorities List (NPL). Sites on the NPL are areas where clean up of known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States has been designated a priority.

What is the KRSG?

The Kalamazoo River Study Group (KRSG) was a group of companies that were current or former owners of paper recycling facilities that existed along the Kalamazoo River near Kalamazoo. From the time work started at the Superfund Site in the early 1990s until January 2009, the KRSG companies were jointly responsible for investigation and cleanup activities along the river and at the various Operable Units. Membership in the KRSG changed over the years and at one time included Plainwell, Inc., Fort James Corporation, and Millennium Holdings, LLC. With the bankruptcy of Millennium Holdings, LLC in January 2009, the KRSG is no longer in existence.

What are the roles/responsibilities of the United States Environmental Protection Agency and Michigan Department of Natural Resources and Environment?

In July 2002, the USEPA officially assumed the lead regulatory agency role for the Kalamazoo River Superfund Site. Up until that point, the Michigan Department of Environmental Quality (MDEQ) had been the lead agency, but in July 2001 requested the USEPA assume that role. The USEPA is now responsible for selecting the final remedy for the Site, although the Michigan Department of Natural Resources and Environment (MDNRE – the result of a January 2010 merger of MDEQ and the Michigan Department of Natural Resources) will continue to play a supporting role and will have input in the decision-making process. Since taking over the Site, the USEPA has conducted additional sampling and analysis activities, and led the negotiations that resulted in the February 2007 signing of two Administrative Settlement Agreements and Orders on Consent.

What are the AOCs and how are they used to guide work at the Site?

On February 21, 2007 Georgia-Pacific LLC and Millennium Holdings, LLC voluntarily entered into two separate agreements with the USEPA that provide the overall framework for current work and future investigations at the Superfund Site. These agreements are referred to as AOCs, which means Administrative Settlement Agreement and Order on Consent, and they are filed with United States District Courts. You can read USEPA′s fact sheet on the two agreements.

The first agreement – referred to as the SRI/FS AOC – describes a series of supplemental remedial investigations and feasibility studies that will be carried out over the next several years. The work will proceed in phases across seven distinct Areas of the Site and four former paper mill properties. Field work for the new investigations in Area 1 – the stretch of the Kalamazoo River from Morrow Dam to the Plainwell Dam and Portage Creek from Alcott Street to its confluence with the Kalamazoo River – started in the summer of 2007, and included sampling of fish, sediment, floodplain soils, and surface water. Since the bankruptcy of Millennium Holdings in January 2009, Georgia-Pacific has continued the work described in the AOC. Read more about the supplemental investigations.

The second agreement – referred to as the TCRA AOC – describes the requirements for the Time-Critical Removal Action (TCRA) in the former Plainwell Impoundment. Work on the TCRA began in March 2007, and the majority of the construction work was completed by December 2008. Follow up planting and project cleanup activities were completed by June 2009. Monitoring of the area will continue through 2011. Read more on the TCRA.

In 2009 Georgia-Pacific entered into two additional agreements with USEPA – one is an AOC for a new TCRA in the Plainwell No. 2 Dam Area, and the second is a Consent Decree regarding the Willow Boulevard/A-Site Operable Unit.

What are PCBs?

PCBs are a group of 209 chemicals that were produced in the United States between 1929 and 1978 for use primarily as industrial coolants, insulators, and lubricants. PCBs were widely used because they were stable and resisted wear and chemical breakdown. The same chemical properties that made PCBs useful to industry are now responsible for persistent levels of PCBs remaining in the environment, including the Kalamazoo River. PCBs persist in the environment because they adhere readily to organic material in sediments and soils, and tend to bioaccumulate (build up) in the fatty tissue of fish and other animals. The potential adverse environmental and health effects of PCBs were not well understood until 1977, when the government banned most uses of PCBs.

Why are people concerned about PCBs in the Kalamazoo River? Which activities are safe?

Because fish are most likely to come into contact with bioavailable PCBs (see below), determining the level of PCBs in certain species of Kalamazoo River fish is a priority. The Michigan Department of Community Health (MDCH) currently maintains fish consumption advisories, as both a protective measure and to raise awareness about guidelines for eating Kalamazoo River fish.

The Public Advisory Council for the Kalamazoo River Area of Concern Remedial Action Plan asked the MDCH to evaluate the potential health hazards from the PCBs present in the water and sediment of the Kalamazoo River, and to address specific questions regarding risks associated with recreational use of the river.

In response to this request, in May 2002, the MDCH, under a Cooperative Agreement with the Agency for Toxic Substances and Disease Registry (part of the U.S. Department of Health and Human Services), issued a "Health Consultation" report in which they concluded that there is "no apparent health hazard associated with the Public Advisory Council′s specific concerns." Further, the MDCH stated that "there is no need to restrict access to the Kalamazoo River or Portage Creek" and that "no apparent public health hazard is posed by the contamination of the sediment."

The MDCH agrees that recreational activities such as boating, swimming, and wading in the Kalamazoo River are safe. Read MDCH′s "Health Consultation" report.

What are "bioavailable" PCBs?

PCBs that are located where they are readily available for biological uptake are considered "bioavailable." Bioavailable PCBs are those located in the water column or surface sediment. From there, PCBs can accumulate in fish and be passed to people or wildlife if those fish are eaten. However, natural attenuation processes ongoing in places like Lake Allegan can cover PCBs in the sediment bed where they become unavailable for exposure or transport.