U.S. E.P.A. Selects Consolidation and Capping Remedy for Allied Paper Site

The U.S. Environmental Protection Agency has selected a remedy for the 89-acre Allied Paper Landfill site located in the City of Kalamazoo. The remedy outlined in the formal Record of Decision, referred to as Alternative 2D, calls for the consolidation of contaminated material, the installation of an impermeable cap, ongoing monitoring to verify the remedy’s effectiveness, and new commercial development and recreational opportunities at the site.

Contaminated soils, sediments, and residuals from the site would be excavated and consolidated into the main body of the landfill area. The existing landfill area abutting Portage Creek would also be excavated and consolidated, reducing the footprint of the contamination from approximately 49 acres to 27 acres. After the material has been consolidated it will be covered with an impermeable cap and an active gas collection system will be installed. Excavated and backfilled areas that are not used for flood or water runoff could then become available for commercial redevelopment, and the capped area could potentially be reclaimed for light recreational use, including a planned recreational trail through the site along Portage Creek. Long-term groundwater monitoring to verify the effectiveness of the remedy, land and groundwater use restrictions, and long-term operation and maintenance are also included. Consolidation and capping remedies have been used successfully at numerous sites across the country, including three other landfills at this site in Kalamazoo. Containment remedies employ proven technologies that are protective over the long term.

The EPA considered several other remedies including the total removal of contaminated material, complete encapsulation of the contaminated material, no action, and several variations of consolidation and capping. In determining a remedy the EPA evaluates each alternative against nine criteria, noting how each compares to the other alternatives under consideration. Among the criteria are the overall protection of human health and the environment; the long-term effectiveness and permanence; the reduction of toxicity, mobility, or volume of contaminants; the short-term effectiveness; impermeability; and cost. Alternative 2D offered the best balance of these criteria. Total removal of the contaminated material would cost an estimated $238 million, without an identified funding source.  That remedy is over three times the cost of Alternative 2D, while offering only slightly greater protection.

The EPA developed Alternative 2D after extensive discussion with the City of Kalamazoo and the Michigan Department of Environmental Quality, the three having met in person more than 40 times since 2014. This option was judged to be more protective than the consolidation and capping options originally included in the 2013 Feasibility Study due to the stewardship of the land associated with redevelopment. The EPA also considered all public comments that were received during the process, and responses to each comment are included in the Record of Decision document.

Kalamazoo River Watershed Council and Kalamazoo River Cleanup Coalition have noted Alternative 2D is a reasonable compromise, and the Natural Resource Trustee Council (comprised of the Michigan Department of Environmental Quality, Michigan Department of Natural Resources, U.S. Fish and Wildlife Service, National Oceanic and Atmospheric Administration, and others) is supportive of the option. Mayor Bobby J. Hopewell offered his support of the plan to the EPA in a 2015 letter. 

Now that a decision has been made, the EPA will begin designing the selected remedy. Additional sampling will be conducted to determine the fine details of the contaminated material and the plans to actually build the remedy will be completed. This process is expected to take 18 to 24 months. After the plans have been finalized, implementation of the remedy is expected to take approximately two years to complete. At this point ongoing monitoring and maintenance would begin and the site could potentially be available for reuse.

The complete Record of Decision is available online here.

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