f/EPA
United States
Environmental Protection
Agency
Share your opinion
EPA invites comments on its proposed
cleanup plan for an island located
in the Tittabawassee River. The
Agency encourages people to attend
the public meeting at 6:30 p.m.,
Thursday, April 28,2011, at Saginaw
Valley State University, Curtiss Hall,
Banquet Rooms B & C, 7400 Bay
Road, Saginaw. EPA and MDEQ
representatives will also be available
to talk to residents at an informal
session on April 28,2 - 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-
pubcommenthtm; and 4) fax to EPA's
Patricia Krause at 312-697-2568.
Contact EPA
If you need special
accommodations at either the
availability session or the public
meeting or have questions contact:
Patricia Krause
EPA Community Involvement
Coordinator
Superfund Division (SI-7J)
312-886-9506
krause.patricia@epa.gov
Don de Blasio
EPA Community Involvement
Coordinator
Superfund Division (SI-7J)
312-886-4360
deblasio.don@epa.gov
EPA toll-free: 800-621-8431,
9:30 a.m. - 5:30 p.m., weekdays
EPA Proposes Cleanup
Action for Small Island
Tittabawassee River, Saginaw River and Bay Site
Midland, Saginaw and Bay City, Michigan April 2011
The U.S. Environmental Protection Agency, working with the state of
Michigan, is proposing a cleanup action on a small island in the Tittabawassee
River to limit contaminated sediment (mud) from moving downstream.
The island is located in a stretch of river known as Reach MM in a section
of the site designated by EPA as Segment 5 (see Figure 1 on Page 2). The
island contains high levels of dioxins (primarily furans) and is eroding over
time. EPA's recommended plan to control dioxin movement from the island
is to remove the contaminated sediment located above the water surface,
combined with in-place containment of the remaining island sediment under
a cap designed to let the island restore itself naturally. Nearby underwater
sediment would also be capped as needed. This work would remove highly
contaminated sediment and isolate less polluted sediment and stop it from
moving downstream. The project would also promote natural restoration of
the area to an island habitat.
The measures described in this fact sheet are called "early actions." EPA is
proposing to perform these steps later this year, long before an extended,
comprehensive cleanup can be accomplished for floodplain soil and river
sediment in designated segments of the Tittabawassee and Saginaw rivers.
Public comment needed
The purpose of this proposed plan fact sheet is to give you background
information, describe the proposed options to control contaminant movement
from the Reach MM island, and explain EPA's recommendation1. You
are encouraged to comment on this proposed plan. More details can be
found in a document called the Reach MMIn-Channel Island Engineering
Evaluation/Cost Analysis (EE/CA). EPA is also seeking comments on this
technical report, which can be found on our website and at the local document
repositories listed on Page 7.
EPA will be accepting comments from April 22 - May 22, 2011, and holding a
public meeting on April 28. See the left-hand box for ways you can participate
in the decision-making process.
Background
The Dow Chemical Co. has been operating its Midland plant since the 1890s.
Dioxins including furans and other contaminants are found in and along
the Tittabawassee and Saginaw rivers and in Saginaw Bay from past waste
disposal practices at Dow's Midland plant. A January 2010 legal agreement
sets out requirements for Dow to perform investigations and develop and
design cleanup options selected by EPA, in consultation with the Michigan
Department of Environmental Quality, leading to protective cleanup of the
Tittabawassee River, Saginaw River and Bay site. For cleanup purposes,
EPA divided the Tittabawassee and upper Saginaw rivers into eight segments
Section 117 (a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA,
known as the Super/and law) requires EPA to provide an opportunity for public input with a 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 in the repositories listed on P. 7 and at the EPA Chicago Office.
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ranging from three to five miles long. Work will be
conducted in stages from upstream to downstream,
segment-by-segment, ensuring that each section is
cleaned up before moving on to the next. However, the
legal agreement also recognizes that movement of highly
contaminated sediment and riverbank soil to other areas of
the site is a concern that would be handled, as needed, on
an accelerated schedule.
A procedure was established to determine if these early
actions might be needed for certain sediment and riverbank
deposits. The evaluation considers the size of the deposit,
the level of dioxins and the likelihood the contaminants
could move. The evaluation also considers how far down
the river the deposit is located, because areas farther
downstream may need to be treated through early actions
before the final, long-term cleanup work reaches that
particular area. Federal and state environmental regulators
determined the island in Reach MM is one of these
locations needing early action.
It is likely the Reach MM island formed in the early
1900s because of changes in Tittabawassee River currents
after construction of a nearby bridge. At the same time,
very large amounts of sediment were washing into the
river because of logging and agricultural practices.
The sediment mixed with contaminants and built up in
certain areas like the Reach MM island. Overtime, less
contaminated sediment layers built up on the island over
the more polluted deposits. Sampling from Reach MM
island showed high levels of dioxins in the island sediment
and along the bank faces.
Why is this early action important?
Dioxins are the main contaminants found at the site. The
term "dioxins" refers to a large family of similar chemicals
including the closely related furans. 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 deposited in some sediment, like at
the Reach MM island. It is believed that current waste
Figure 1
mi\ island
Location Map
Segments
| | Counties
Dow Midland Plant
Segment 5
Saginaw Co.
L Saginaw
- Segment 6 EJegment 8
Shields*
Figure 1 - The Reach MM island is located in Segment 5 of the site near the intersection ofM-47 and Weiss Street
about 17 miles downstream from the confluence of the Chippewa and Tittabawassee rivers and about seven miles
upstream from the Shiawassee River.
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management practices now control contaminant releases
from Dow's facility.
The Reach MM island is subject to erosion that may be
spreading dioxins to downstream locations within the
floodplain and river channel where people or wildlife could
come into contact with the pollution. Once they erode from
the island, contaminants may build up in the food chain
or be distributed in sensitive ecosystems. Historical aerial
photographs show the Reach MM island has dwindled in
size over time (see Figures 2 and 3 on Page 7).
Addressing the Reach MM island through an early action
is important. It will be several years before the long-term,
comprehensive cleanup can be executed for Segment
5. By taking these cleanup steps now, the potential for
contamination from the Reach MM island to move
downstream will be diminished.
Summary of proposed alternatives
EPA considered three alternatives to control contaminant
movement from the Reach MM island:
Alternative 1 - Stabilization: This alternative would
protect the Reach MM island from further erosion by
placing material such as large woody debris or armor
stone over existing sediment on the island surface and
banks. The materials would be designed and placed on
the island to prevent sediment movement. Monitoring
would be conducted to make sure stabilization is effective.
Estimated Cost: $250,000
Alternative 2 - Above-Water Sediment Removal and
In-Place Containment (this is EPA's recommended
alternative): This alternative would include removal of
sediment located above the water line, combined with in-
place containment of the remaining sediment under a cap
designed to promote natural restoration of island habitat.
Excavation of the visible island would be done under dry
conditions. Removed sediment would be transported for
disposal at a licensed landfill. A containment cap made
of clean material would be placed over the exposed areas
created by the removal. Nearby underwater areas might be
capped as well depending on what conditions additional
investigations find. The cap would stabilize the remaining
sediment making it less mobile and reduce the potential for
human or wildlife exposure on the island. After the work is
completed, the area would remain an island during typical
water flow conditions and over time the island should
redevelop naturally. The cap would be monitored for
continued effectiveness. Estimated Cost: $500,000
Alternative 3 - Removal of All Targeted Sediment:
This alternative would include the removal of all targeted
sediment from above the water surface at the island
and underwater in this area as well. The exact zone to
be removed would be determined based on additional
investigations. Best management practices would be used
to minimize sediment movement during construction.
Water would need to be removed from the sediment by
"dewatering" - either near the removal area or the sediment
would be loaded onto trucks and taken to a staging facility.
After dewatering, dredged sediment would be transported
off-site and disposed of in a licensed landfill. Estimated
Cost: $1.1 million - $2 million
Common elements to all alternatives
Some features are common to all of the cleanup options.
Additional sampling will be needed to understand existing
conditions and identify the final size of the work area.
Each alternative would require an assessment of water
flow to make sure the sediment is stable and other nearby
deposits do not erode. Access to the island is likely to
be on temporary roads from an adjacent shoreline. Each
alternative would require clean material to be shipped into
the work area. Alternatives 2 and 3 would also require
contaminated sediment be removed from the location
and transported to a landfill for disposal. Because of the
increased truck volume, traffic controls will be put in place
as a safety measure. Work is expected to be completed
this year in one construction season. A health and safety
plan will be required for the project to protect workers and
residents.
Evaluation of alternatives
EPA is required by law to evaluate these options against
the criteria of effectiveness, implementability and cost (see
box on Page 4 for an explanation of the criteria). Table 1
compares each alternative against these criteria.
Effectiveness: All three options are expected to
protect human health and the environment and will
limit downstream contaminant movement. Alternative
1 protects the Reach MM island from further erosion
and immediately reduces downstream movement of
contaminants by stabilizing the existing island sediment.
However, nearby underwater areas would not be handled.
Alternative 2 offers long-term protection by removing
the contaminated sediment most likely to erode - the
sediment at and above the water line - and isolates and
safely contains the remaining deposit with a clean cap.
Alternative 3 would be effective in the long-term because
it removes contaminated sediment from the river system,
preventing downstream movement.
All three alternatives will have short-term effects that will
temporarily disrupt areas in and along the river during
construction. The construction period for Alternative 1 is
the shortest and Alternative 3 is the longest. Alternative 2
could have limited short-term effects of water cloudiness
because of sediment removal, although this work will be
done under dry conditions so the effects will be minimal.
Alternative 3 could have short-term effects because
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underwater sediment removal may result in the release
of contaminants to surface water, cause cloudiness, and
move contaminants downstream during construction. In
addition, after removal under Alternative 3, contamination
may remain on the sediment surface and could later move
downstream.
Alternative 1 will cause the least changes to existing river
conditions, and Alternative 3 will cause the most. Under
Alternative 1 the island habitat will remain, although the
materials needed to prevent erosion may change the look
of the bank faces and surfaces. The flows will remain
similar, minimizing concerns about erosion in other areas.
Under Alternative 2 the cap will create a low island that is
expected to redevelop naturally over time. The flows will
remain similar, also minimizing concerns about erosion
in other areas. Under Alternative 3, no island habitat will
remain. The flows will change in this part of the river and
potential erosion of other areas must be considered.
Implementability: Actions similar to Alternatives 1, 2,
and 3 have been done successfully at other areas along
the Tittabawassee River. Stabilization under Alternative 1
may require a more refined approach compared to previous
projects because of specific conditions at the Reach MM
island. The river flow and the shape and steepness of the
island are conditions that may be challenging. Targeted
removal similar to Alternative 3 has been done, but past
experience shows that underwater sediment removal in the
Tittabawassee River is likely to have potential difficulties.
Managing river flow conditions to perform underwater
work, maintaining water quality during a removal, and
managing water from the dewatering process are all
challenges with Alternative 3. In addition, buried logs and
other debris pose obstacles to the sediment cleanup process
in Alternative 3. Partial removal and capping similar to
Alternative 2 has been successful at other locations without
major implementation issues. For Alternatives 2 and 3 a
local licensed landfill would be the location for permanent
disposal of removed sediments. Necessary personnel and
equipment are available for all options.
Cost: The costs for stabilization and a monitoring program
under Alternative 1, at $250,000, are comparatively low.
The costs for above-water sediment removal, in-place
containment and a monitoring program under Alternative 2,
at $500,000, are moderate. The costs for targeted sediment
removal under Alternative 3 would be high, with an
estimated price tag between $1.1 million and $2 million,
which includes anticipated construction monitoring but no
long-term monitoring. The range of costs for Alternative 3
is large because of uncertainties around the final volume of
sediment that needs to be removed.
EPA's recommendation
EPA, in consultation with MDEQ, recommends
Alternative 2 - Above-Water Sediment Removal and In-
Place Containment. The environmental agencies believe
this option provides the best balance of effectiveness,
implementability, and cost. Alternative 2 protects human
health and the environment long-term. It also provides
permanence by removing the most highly contaminated
sediment that is the most vulnerable to erosion, while
stabilizing and isolating remaining sediment. Alternative
2 will cause minimal short-term disruptions. Alternative 2
also is doable since the technology, materials and services
are available.
Explanation of evaluation criteria
For this type of action, EPA uses three criteria to
evaluate and compare cleanup options.
Effectiveness evaluates the ability of an option to
meet cleanup objectives. It also considers whether the
option protects human health and the environment, and
whether the option will be reliable.
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 long-term expenses of maintaining the option.
Table 1 - Compares how each alternative meets the evaluation criteria, relative to other alternatives.
Evaluation
Criteria
Effectiveness
Implementability
Estimated Cost
Alternative 1
Stabilization
Moderate
High
$250,000
Alternative 2
Above-water sediment
removal and in-place
containment
High
High
$500,000
Alternative 3
Removal of all
targeted sediment
Moderate to High
Moderate
$1.1 million -
$2 million
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Use This Space to Write Your Comments
EPA is interested in your comments on the proposed cleanup plan for an island located in the Tittabawassee
River. You may use the space below to write your comments. Submit them at the April 28 public meeting, or
detach, fold, stamp and mail to EPA Community Involvement Coordinator Patricia Krause. Comments must be
postmarked by May 22, 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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Tittabawassee River, Saginaw River - Comment
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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Figure 2 - Historical aerial photograph of the Reach MM island, 1963-65 time period.
Figure 3 -Aerial photograph of the Reach MM island, 2007.
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 MDEQ, may modify its recommended
plan, 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
in the right-hand box. 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
on the website.
Once the plan is finalized, EPA expects Dow to implement
the work at the Reach MM island. Dow's work will be
done with oversight by EPA and MDEQ. To try to avoid
bad weather and potential high-water levels, the work is
expected to be completed during late summer and early
fall 2011.
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 and 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.
7
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EPA
for
and Bay
Midland, Bay City, Michigan
Public Comment Period: April 22 - 22, 2011
Public April 28, 2011
Availability April 28, 2011
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