f/EPA
United States
Environmental Protection
Agency
Share your opinion
EPA invites comments on its interim
proposed plan for areas located
along the Tittabawassee River.
The Agency encourages people
to attend the public meeting on
Wednesday, Jan. 19, 6:30 p.m., at
Saginaw Valley State University,
Curtiss Hall, Seminar Rooms D - G,
7400 Bay Road, Saginaw.
EPA and MDNRE representatives will
also be available to talk to residents
at informal sessions on Tuesday,
Jan. 18,5 - 8 p.m., at the Freeland
Sportszone, 5690 Midland Road,
Freeland; and Wednesday, Jan. 19,
1-4 p.m., at the Thomas Township
Library, 8207 Shields Drive, Saginaw.
There are several ways to offer
comments on the proposed plan:
1) orally or in writing at the public
meeting; 2) fill out and mail the
enclosed comment form or submit
it at the meeting; 3) electronically
by Internet at epa.gov/region5/
publiccomment/dowchemical-
pubcomment.htm.; 4) fax to EPA's
Patricia Krause at 312-697-2568.
Contact EPA
If you need special accommodations
at either the availability sessions or
the public meeting or have questions
contact:
Patricia Krause
Community Involvement Coordinator
312-886-9506
krause.patricia@epa.gov
Don de Blasio
Community Involvement Coordinator
312-886-4360
deblasio.don@epa.gov
Region 5 toll-free: 800-621-8431,
9:30 a.m. - 5:30 p.m., weekdays
Interim Actions Proposed for
High-Use Floodplain Areas
Tittabawassee River, Saginaw River & Bay Site
Midland, Saginaw and Bay City, Michigan January 2011
U.S. Environmental Protection Agency, working with Michigan Department
of Natural Resources and Environment, is proposing an interim plan to
limit human exposure to dioxin and furan contamination in areas along the
Tittabawassee River. EPA's recommended plan includes placing a barrier such
as ground cover over bare floodplain soil to limit human contact, or moving
or raising land-use features such as gardens and recreation areas out of the
floodplain. The plan is aimed at areas that frequently flood and contain bare
soil. EPA is also recommending criteria that would make properties along the
Tittabawassee River eligible for these early actions. The measures described
in this fact sheet are interim exposure controls that EPA is proposing to take in
the short-term, until long-term solutions are implemented for floodplain soil.
Public comment needed
The purpose of this proposed plan fact sheet is to give you background
information, describe the proposed eligibility criteria and proposed interim
exposure control options and explain EPA's recommendations.1 You are
encouraged to comment on this proposed plan. More details can be found in a
document called the Task 1.4 Engineering Evaluation/Cost Analysis for Early
Response Action to Address Potential Acute or Near Term Exposure Risks.
EPA is also seeking comment on this technical report, which can be found on
our website and at the local document repositories listed on Page 4.
EPA will be accepting comments from Jan. 12 - Feb. 11, 2011. See the left-
hand box for ways you can participate in the decision-making process.
Managing high-use properties
EPA and MDNRE identified flood-prone properties along the Tittabawassee
and Saginaw rivers that may be frequently used by people. These areas are
called Exposure Units, or EUs. Properties within the EUs are being evaluated
to see if interim exposure controls would be useful before comprehensive
cleanup options are developed and implemented in future years. Work was
completed at EU 01 in 2008 and EU 02 in 2009. There are currently about 260
properties in 18 other EUs that will be evaluated (see Figure 1 on P. 2).
Dow Chemical Co., with oversight by EPA and MDNRE, has been evaluating
the EU properties in phases since the summer of 2010. Phase 1 includes EUs
10 and 11. Phase 2 includes EUs 04, 06, 07 and 08. The evaluation process
includes an appointment and interview with residents to see how they use
their property, and then conducting a survey to assess property conditions and
identify land-use features. Findings are compared with the proposed eligibility
criteria to see if an interim exposure control is recommended. Evaluations
are complete for properties in Phase 1. Evaluations for Phase 2 properties are
nearing completion. Phase 3 and 4 evaluations will take place in 2011 (see
Figure 2 Timeline on P. 7).
1 Section Il7(a) of the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA, known as the Superfund law) requires EPA to provide an opportunity for public input with
a meeting and comment period. It also requires a newspaper ad announcing the proposed plan with
a brief description. This fact sheet summarizes a document called the "engineering evaluation/cost
analysis " and other site-related reports. All official site documents can be found at the repositories
listed on P. 4 and at the EPA Region 5 office in Chicago.
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Tittabawassee &
Saginaw Rivers
• EU Locations
^] Counties
Dow Midland Plant
Figure 1 - Location of Exposure Units along the site.
Proposed eligibility criteria
Several thousand floodplain soil samples have been
analyzed at the site. Dioxins and furans have been found in
floodplain soils. As such, EPA is proposing that all of the
following criteria must be met for a residential property
in the Tittabawassee River EUs to qualify for interim
exposure controls:
• A portion of the property is located within a
frequently flooded area (generally, the 8-year
floodplain), or soil has been moved from
frequently flooded areas to other parts of the
property.
• The property is actively used.
• There is bare soil located within the actively used
floodplain.
Properties that do not meet the eligibility criteria now will
be re-evaluated periodically to determine if conditions
have changed. Residents with properties that were
previously designated "Priority 1" or "Priority 2" by
MDNRE may have undergone some interim response
activities. Maintenance of those actions will continue, and
the scope of the work may be expanded.
In the future after evaluations are conducted in these areas,
EPA may develop other eligibility criteria or options for
properties in the Saginaw River EUs and nonresidential
properties.
Summary of proposed options
EPA considered three alternatives for interim exposure
controls at eligible residential properties in the
Tittabawassee River EUs.
Option 1 - No Action: No actions or controls would be
implemented. The soil areas will remain "as is." Education
for reducing contact with potentially contaminated soil
may be part of this option. Estimated cost: Minimal
Option 2 - Control Barrier: A barrier such as ground
cover would be placed over the floodplain soil to limit
contact with underlying soil. Ground cover could include
clean reseeded soil, gravel, mulch or other appropriate
materials. Maintenance would be conducted as needed
to make sure the barriers remain effective. Education
for reducing contact with soil and for recognizing when
maintenance work is needed may be part of this option.
Estimated cost: Unit costs are based on type of material
used, labor and equipment and can range from $2 to
$3.50 per square yard.
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Option 3 - Moving or Raising Land-Use Features:
A land-use feature would be raised or moved out of the
floodplain to reduce or eliminate exposure to floods, which
can deposit contaminated mud (sediment). Examples
include raising a garden or relocating a fire pit or swing
(see photos P. 7). Bare soil would be covered after the
land-use feature is relocated under this option. Education
for reducing contact with soil and for recognizing
when maintenance work is needed may be part of this
alternative. Estimated cost: Unit costs including labor,
equipment and materials range from about $1 per
square foot to raise a garden to $800 to $900 to relocate
a land-use feature.
Evaluation of options
EPA is required by law to evaluate these options against
the criteria of effectiveness, implementability and cost (see
box below). Table 1 compares each alternative with the
criteria.
Effectiveness: Options 2 and 3 will be effective because
the actions will reduce contact with potentially affected
soil by providing an exposure barrier or by relocating a
land-use feature. Monitoring and maintenance as needed
will ensure effectiveness until long-term solutions are
implemented, and these actions are easy to do. Because
Options 2 and 3 are small in scope, there will not be
dramatic changes to the landscape. For example, we
anticipate that trees will not be taken down during this
phase. Option 1 would not be effective since it would not
prevent contact with potentially contaminated soil.
Explanation of evaluation criteria
For this type of interim action, EPA uses three criteria
to evaluate and compare cleanup options.
Effectiveness evaluates the ability of an option to
meet objectives. It also considers protectiveness and
whether the option will be reliable until long-term
solutions are implemented. Protectiveness can be
assessed in terms of how well the option protects
public health and the community, protects workers
during implementation, and protects the environment.
Implementability evaluates how difficult the option
will be to construct and whether materials and services
are available in the area.
Cost includes not only equipment, materials and labor
but also the cost of maintaining the option until long-
term solutions are implemented.
Implementability: Because Option 1 requires no action
it can be easily implemented. Based on successful
experience at other EUs and the ready availability of labor,
equipment and materials, both Options 2 and 3 can also
be implemented easily provided property owners provide
legal access.
Cost: The cost for Option 1 is minimal and the costs for
Options 2 and 3 are generally low. Total costs are difficult
to estimate because the size of areas to be addressed and
numbers and types of the land-use features varies by
property. EPA estimates that costs for the proposed interim
exposure controls for the potentially eligible Phase 1
properties would be less than $200,000.
Phase 2 evaluations will be completed soon. Any Phase
2 properties that meet the final eligibility criteria will be
offered interim exposure controls. Since the number of
properties evaluated in Phase 2 is similar to the number
of properties in Phase 1, EPA anticipates the cost to
implement interim exposure controls at potentially eligible
Phase 2 properties will be similar to Phase 1 costs.
Table 1 - Comparing the alternatives
Evaluation
Criteria
Effectiveness
Implementability
Cost
Option 1
No Action
Low
High
Minimal
Option 2
Control
Barrier
High
High
Low
Option 3
Movement
of Land-
Use
Feature
High
High
Low
EPA's recommendations
Both Options 2 and 3 are recommended for interim
exposure controls at eligible properties. The final option
will be developed on a property-by-property basis,
depending on conditions at that specific location. EPA will
work with each property owner or resident to design and
install one or a combination of these acceptable options.
Option 1, no action, is not recommended as an alternative
for eligible properties.
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Why are these control measures important?
Dioxins (including furans) are the primary contaminant found
at the site. The term "dioxins" refers to a large family of similar
chemicals. EPA has concluded that some dioxins may cause
cancer or other health effects such as skin problems, liver
damage and reproductive issues.
Dioxins are not created intentionally but can be formed
by human activity or naturally, for example, by fires. At
the site dioxins were formed as byproducts of Dow's early
manufacturing processes at its plant in Midland. In the past
the chemicals were released to the Tittabawassee River
where they washed up onto the floodplains during high river
flows. It is believed that current waste management practices
now control contaminant releases from Dow's facility.
Several thousand floodplain soil samples have been
analyzed. Dioxins have been found in floodplain soils at
locations within the Phase 1 and Phase 2 EUs. Generally,
higher levels of dioxins are found closer to the Tittabawassee
River in areas that flood frequently. Sometimes the dioxins
are found at or close to the surface, where people could be
exposed to them, or where the dioxins could move during
flooding.
Addressing current or potential high-use properties along
the river through temporary control measures is important.
Additional evaluation of floodplain soil cleanup will occur
as our work moves segment-by-segment down the rivers.
However, it will be several years before long-term solutions
are implemented for all of the floodplain soil. EPA's
proposed short-term actions are intended to limit people's
contact with potentially affected soil while the final cleanup
is being developed.
Next steps
Before it makes a final decision, EPA will review
comments received during the public comment period and
at the public meeting. Based on the comments, EPA, in
consultation with MDNRE, may modify its recommended
interim action plan or the proposed eligibility criteria so
your opinion is important.
More details are available in the official documents on file
at the information repositories and on EPA's website listed
below. EPA will respond to the comments in a document
called a "responsiveness summary." The Agency will
announce the final plan in local newspapers and will place
a copy in the information repositories and the website.
Once the plan is finalized, EPA expects Dow to implement
the interim exposure controls at eligible properties after
consultation with the property owners. Dow's work will
be done with oversight by EPA and MDNRE. The work
should be completed quickly, depending on conditions at
each property. To try to avoid bad weather and potential
flooding, the work would be completed during the typical
construction season, expected to begin in late spring and
end in the fall. It is anticipated the Phase 1 properties will
be completed in 2011.
Phase 2 evaluations will be completed soon. Any Phase
2 properties that meet the final eligibility criteria will be
offered interim exposure controls. Dow, with EPA and
MDNRE oversight, will conduct evaluations at the Phase 3
and 4 EUs in 2011. Once the Phase 3 and 4 evaluations are
complete, EPA and Michigan will consider whether other
eligibility criteria or options are needed for properties in those
EUs.
For more information
EPA Field Office
EPA has opened an information office in the Saginaw County Courthouse, 111 S. Michigan Ave., Saginaw.
Telephone: 989-790-5215.
View Site Documents
You can view documents related to the Tittabawassee River, Saginaw River & Bay site on the Web or at
information repositories:
• At www.epa.gov/region5/sites/dowchemical.
• Grace A. Dow Memorial Library, 1710 W. Saint Andrews St., Midland.
• Hoyt Main Library, 505 Janes Ave., Saginaw.
• Alice and Jack Wirt Public Library, 500 Center Ave., Bay City.
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Use This Space to Write Your Comments
EPA is interested in your comments on the proposed plan for interim exposure controls at the Tittabawassee River,
Saginaw River & Bay site. You may use the space below to write your comments. Submit them at the Jan. 19 public
meeting, or detach, fold, stamp and mail to EPA Community Involvement Coordinator Patricia Krause. Comments
must be postmarked by Feb. 11, 2011. If you have any questions, please contact Patricia directly at 312-886-9506,
or toll free at 800-621-8431, 9:30 a.m. - 5:30 p.m., weekdays. Comments may also be faxed to Patricia Krause at
312-697-2568 or sent via the Web at epa.gov/region5/publiccomment/dowchemical-pubcomment.htm
Name
Affiliation
Address
City State Zip
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River, Saginaw River & Site - Comment Sheet
fold
fold
Patricia Krause
Community Involvement Coordinator
Superfund Division (SI-7J)
EPA Region 5
77 W. Jackson Blvd.
Chicago, IL 60604-3590
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Divide EUs into
phases & planning
Phase 1
Phase 2
Phases 3 & 4
2010
Develop options
as needed
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2011
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Start in 2011
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Figure 2 - Timeline to address high-use properties along the Tittabawassee and Saginaw rivers.
As we work on these proposed interim exposure controls, EPA is also developing cleanup options for addressing
movement of highly contaminated soil and sediment and for the first segment of the Tittabawassee River. Please see
the fact sheet at http://www.epa.gov/region5/sites/dowchemical/pdfs/dowchemical_fs_201007_timeline.pdf for more
information about the other ongoing projects.
Figure 3 - Example of a raised garden bed.
Figure 4 - Example of ground cover around afire pit.
1
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EPA
For
& Bay Site
Midland, Saginaw, City, Michigan
Public Comment Period: Jan. 12™ Feb. 11, 2011
Public Jan. 19, 2011
Availability Jan. 18-19, 2011
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