&EPA
United States
Environmental Protection
Agency
Share your opinion
EPA invites your comments on
the proposed cleanup plan for the
Tittabawassee River floodplain soil.
The public comment period is
Aug. 15 through Oct. 14.
There are several ways to comment:
•	Orally or in writing at the public
meeting.
•	Fill out and mail the form on
Page 5, or submit it at one of the
meetings.
•	Use the public comment form link
at www.epa.gov/region5/cleanup/
dowchemical.
EPA may modify the proposed cleanup
plan or select another option based on
new information or public comments,
so your opinion is important.
Public meeting
EPA will hold a public meeting,
Wednesday, Sept. 24, at 6:30 p.m., at
the Freeland High School Auditorium,
8250 Webster Road, Freeland,
where you can make oral or written
comments. There also will be a series
of informal floodplain property owner
meetings where owners can discuss
the proposed plan with EPA staff in
a small group or one-on-one. Call
EPA's Saginaw office at 989-401-5509
for details. EPA will accept written
comments at these sessions, but not
oral comments.
Contact EPA
If you need special accommodations
at the public meeting or have
questions, contact:
Diane Russell, Community
Involvement Coordinator
989-401-5507, russell.diane@epa.gov.
You may also call EPA's Chicago
office toll-free at 800-621-8431,
9:30 a.m -5:30 p.m. weekdays.
EPA Proposes Cleanup Plan for
Tittabawassee River Floodplain Soil
Tittabawassee River, Saginaw River & Bay Site
Midland, Saginaw and Bay City, Michigan	August 2014
The U.S. Environmental Protection Agency, working with the Michigan
Department of Environmental Quality, has proposed a plan to clean up dioxin-
contaminated soil in frequently flooded areas along the Tittabawassee River.
The floodplain includes about 4,500 acres and extends along 21 miles of the
river below the Dow Chemical Co. plant in Midland (see Page 2).
EPA's proposed cleanup will ensure that people are safe when they come
in contact with Tittabawassee River floodplain soil. Not all areas in the
floodplain will need a cleanup, and areas outside the floodplain are also not
expected to need a cleanup. Because floodplain land is used in different ways,
the proposed plan calls for a combination of steps:
•	Maintained Residential Areas are homeowners' yards that are clearly
maintained for typical backyard uses. If tests show a contamination
level greater than 250 parts of dioxin in a trillion parts of soil - a
measure known as "parts per trillion," or "ppt" - workers will dig up
and remove contaminated soil, replace it with clean soil and restore
grasses and plants.
•	Other Land Use Areas - such as farms, parks, commercial properties
and natural areas including unmaintained parts of properties and the
Shiawassee National Wildlife Refuge - are places where the soil will
either be dug up and trucked away for disposal or covered with clean
material if dioxin levels are greater than 2,000 ppt. EPA will work
with each property owner on the right approach. After the cleanup,
these areas will typically be replanted.
Your comments are needed
EPA will be accepting comments on the proposed floodplain cleanup plan
from Aug. 15 through Oct. 141 (see box, left). This fact sheet provides
background information, describes cleanup options and explains EPA's
recommendations. You can find more details in a document called the
Tittabawassee River Floodplain Response Proposal, available at www.epa.
gov/region5/cleanup/dowchemical and at the local information repositories
listed on Page 7. EPA wants your comments on the cleanup options and its
recommendations, as well as this technical report.
Before making its final decision on a cleanup plan, EPA will review all the
comments it receives during the public comment period. EPA will respond
to comments in a document called a "Responsiveness Summary/' This will
be part of another document called an "Action Memorandum" that describes
the final cleanup plan. The Agency will announce the final plan in local
newspapers and will place a copy of the plan in the information repositories
(see Page 7) and on the website.
1 Section 117(a) of the Comprehensive Environmental Response, Compensation and Liability*
Act (CERCL4, known as the Superfund law) requires EPA to provide an opportunity for public
input with a comment period. EPA expects that the public will want more than the normal
30-day public comment period and therefore is providing in advance a 30-day extension to
the public comment period pursuant to Section 300.415 (n)(4)(iii) of the National Oil and
Hazardous Substances Pollution Contingency Plan.

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How will I know if my property needs a
cleanup?
After the cleanup plan is selected EPA will contact property
owners who might be affected to discuss their property.
Technical experts will review existing information and take
new samples, if needed. EPA, working with MDEQ, will
consider each property and determine if it should be cleaned
up, then present that decision to the owner. If cleanup is
needed, EPA officials will work closely with the owner on
specific plans and schedules. Once the cleanup is done, or if
no cleanup is needed, the owner will receive a confirmation
letter from EPA.
The Tittabawassee River cleanup has been divided into
seven segments ranging from three to four miles each.
Cleanup in the floodplain will be done in stages from
upstream to downstream, segment-by-segment. Year-by-
year, the cleanup will move downstream. Because the
floodplain is large, it will take several years to complete
the work (see map). EPA will update its website regularly,
allowing you to track the floodplain cleanup progress.
Segment 1 has no floodplain. EPA expects Dow to begin
Segment 2 floodplain cleanup work in 2015, with oversight
by EPA and MDEQ. The flow chart below shows what
property owners can expect when work begins in their
segment. You can contact EPA if you are not sure in which
segment your property is located.
Why is this cleanup important?
EPA has studied the Tittabawassee floodplain extensively.
Dioxins, primarily flirans, are the main contaminant in
floodplain soil. Some areas have high levels of dioxins,
while in other areas dioxins have not been found or the
levels are not as high.
The term "dioxins" refers to a large family of similar
chemicals, including flirans EPA has concluded that
dioxins may cause cancer or other health effects such as
thyroid or reproductive issues, depending on exposures.
Dioxins are not created intentionally but can be formed
by human activity or naturally, such as in fires. In the case
of the floodplain soil, dioxins formed as a byproduct of
Dow 's early manufacturing processes.
When people work or play outdoors, they can accidentally
eat a small amount of dirt or get dirt on their skin. When
die dirt is contaminated, people are being exposed to small
amounts of contamination. EPA's proposed cleanup will
limit people's exposure to dioxins in Tittabawassee River
floodplain soil.
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FreelarnS Rd
Tittabawassee River
Floodplain Work Schedule
Segment 2
Planning 2015
Work Start 2015
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Freeland
BAY COUNTY
Segment 3
Planning 2015
Work Start 2016
SAGtNAW COUNTY
X
Tittabawassee Rd.
Segment 4
Planning 2016
Work Start 2017 or 2018
/
Saginaw
Segments 5, 6 and 7
Planningand Work
Start after 2016
Gratiot Rd.
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A
Figure 1: Tittabawassee River floodplain location and
anticipated schedule.
What to expect when cleanup starts in your river segment
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Project
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Figure 2: What to expect when cleanup starts in your river segment.
2

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How were the cleanup numbers developed?
EPA and MDEQ have developed two dioxin cleanup
numbers for the Tittabawassee River floodplain: 250 ppt
for Maintained Residential Areas and 2,000 ppt for Other
Land Use Areas. These cleanup levels, reflecting the
unique characteristics of Tittabawassee floodplain soils,
are based on site-specific exposure factors. The cleanup
numbers are designed to protect all age groups - everyone
who lives, works or plays in the floodplain.
When EPA and MDEQ estimate potential risk from
environmental contaminants, they consider how much
exposure people might have. If a person is exposed to less
contamination then there is less potential risk. Exposure
refers to how often a person may come into contact with
floodplain soil, the dioxin levels in the soil and how
much of the dioxin might get into a person's body. People
use different parts of the floodplain in different ways -
therefore the exposures in each of those areas would be
different. In developing the cleanup numbers, EPA and
MDEQ considered factors such as local climate, where
people spend time and how they use the floodplain, the
amount of exposure that people get from house dust and
soil, and site-specific studies on the amount of dioxins in
Tittabawassee floodplain soil that are taken up into the
body.
A detailed description of how the numbers were
developed can be found at www.epa.gov/region5/cleanup/
dowchemical/floodplain.html and at the local information
repositories (see Page 7). The cleanup numbers are not
based on potential human exposures from eating livestock
or wildlife from the floodplain, or on potential ecological
risks. EPA and MDEQ will continue to evaluate these
potential exposures.
Background
Dow has been operating at its Midland plant since the
Tittabawassee River is being done in stages from upstream
to downstream, segment-by-segment. Segment 1, a 3-mile
stretch next to Dow's Midland plant, was cleaned up in
2012 and 2013. Cleanup of sediment and riverbanks in
Segment 2 started this year and is expected to be done in
2015. Cleanup of the upstream sediment and banks will
help prevent recontamination of the floodplain.
There are about 4,500 acres in the frequently flooded areas
along the Tittabawassee River. Land use in the floodplain
is varied. Residents, farmers and businesses may be
affected along with the Shiawassee National Wildlife
Refuge and public parks. Large areas in the floodplain are
undeveloped and support natural ecosystems like mature
forests and wetlands. Some yards and West Michigan Park
have already been cleaned up; they will continue to be
evaluated after floods.
Summary of cleanup alternatives
There are two technologies to clean up the Tittabawassee
River floodplain soil. Briefly, they are:
•	Removal and Disposal - digging up contaminated
soil with heavy equipment and replacing it with
clean soil. The contaminated soil is hauled away
for disposal at an approved location. Most existing
vegetation must be removed, but the areas will be
replanted once clean soil is put down.
•	Clean Cover - placing a cover of clean material
over contaminated soil. Covers are usually a layer
of clean soil with grass or other plants on top, but
other materials could be used as appropriate. Clean
covers help keep people and animals from coming
into contact with the contamination. Most existing
vegetation must be removed, but is typically
replanted.
EPA considered three alternatives that use these
technologies (see Table 1 below).
from former
Table 1: Tittabawassee River floodplain cleanup alternatives

Alternative 1
Alternative 2
Alternative 3
EPA's Recommended
Alternative
Maintained
Residential Areas
Remove and
dispose of soil in
areas with dioxin
levels >250 ppt.
Remove and
dispose of soil in
areas with dioxin
levels >250 ppt.
Remove and dispose of
soil in areas with dioxin
levels >250 ppt.
Other Land Use
Areas
Remove and
dispose of soil in
areas with dioxin
levels >2,000 ppt.
Clean cover over
areas with dioxin
levels >2,000 ppt.
Either remove and
dispose of soil OR cover
areas with dioxin levels
>2,000 ppt, working
with property owners.
1890s. Dioxins are found in and ale
and Saginaw rivers and in Saginaw
waste management practices at
the Midland plant. In the past,
dioxins got into the Tittabawassee
River where they mixed with the
sediment and built up in some
riverbanks. Frequent flooding over
a long time moved contaminated
sediment into the floodplain.
Current waste management
practices now control contaminant
releases from Dow's facility.
EPA, working with MDEQ, is
directing Dow's investigation
and cleanup of the river and
floodplain. Cleanup in the
3

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Evaluation of alternatives
EPA is required to evaluate these options against the criteria
of effectiveness, implementability and cost (see box, right).
These three criteria help compare how the alternatives will
meet cleanup goals. EPA's main goal for this floodplain
cleanup is to ensure that people are safe when they contact
Tittabawassee floodplain soil. To meet this goal, EPA will
select a cleanup plan that reduces dioxin levels in surface
soil, ensuring safe exposures under different land uses.
Effectiveness: All alternatives are expected to help protect
human health and the environment, meet the cleanup goals,
and comply with laws and regulations.
•	All alternatives would have some short-term impacts
such as noise or air pollution that may be temporarily
disruptive during the cleanup. Short-term effects
would be managed by construction practices. It should
take less time to install clean covers than to dig up and
remove soil.
•	A clean cover may not be effective in all areas. For
example, active farming would disrupt a cover.
•	All alternatives would require most existing vegetation
to be cleared away in the work areas. Removing
trees, shrubs and plants can have short- and long-
term impacts on the ecosystem. Although areas will
typically be replanted, forests and mature wetlands
may require decades to return to their pre-construction
condition. Grassy areas will be easier to restore.
•	All alternatives would result in truck traffic through
the communities. Clean covers would require trucks
to deliver the cover materials. Removal would
require trucks to take the contaminated soil to an
approved disposal site and more trucks to bring
in clean replacement soil. Plans will be developed
to ensure community safety and to minimize
disruption to local residents.
•	Worker safety concerns involve working around
and operating construction equipment, managing
large amounts of contaminated soil and clearing
vegetation. Extensive outdoor work may also
expose workers to allergens or irritants (for
example, poison ivy, bee stings), or extreme
weather conditions. These concerns would be
Explanation of evaluation criteria
For this type of action, EPA uses three criteria to
evaluate and compare cleanup options. Table 2 below
compares each alternative against these criteria.
^ Effectiveness evaluates the ability of an
alternative to meet project objectives, whether
it is protective and reliable, and if it complies
with all laws and regulations.
^ Implementability evaluates how difficult the
option will be to complete, whether materials
and services are available in the area, and
whether it is acceptable to the community.
^ Cost includes the estimated costs to construct
the option such as equipment, materials
and labor, as well as the long-term costs of
monitoring and maintaining the option.
and may need maintenance to make sure they
are reliable in the long term. Removal would be
effective in the long term because it permanently
removes contaminated soil from the floodplain.
Implementability: All of the alternatives can be carried
out. Similar actions have been done successfully at
other areas in the Tittabawassee River floodplain. All
equipment, personnel and material necessary to implement
the alternatives should be locally available. Community
acceptance will be evaluated after public comments are
received. MDEQ supports EPA's recommended alternative,
but will make a final recommendation after considering
public comments.
•	Implementing either soil removal or a clean cover
is expected to be easier in Maintained Residential
Areas because the existing vegetation will be
much easier to remove and replace.
•	There may be seasonal restrictions that limit when
and how work can be done. For example, trucks
may be restricted on certain roads at times, or work
may be limited by the breeding season of eagles.
•	Implementing a clean cover may be difficult on steep
slopes or in areas where it may cause excess flooding.
•	Agreements from owners will be obtained before
conducting work on their property.
Table 2: Comparison of how each alternative meets the evaluation criteria

Effectiveness
Implementability
Cost
Alternative 1
High
Moderate to High
Highest
Alternative 2
Low to High
Moderate to High
Lowest
Alternative 3
EPA's Recommended
Alternative
High
High
Intermediate
4
managed by appropriate
health and safety and
operational plans.
• All of the alternatives
are expected to be
effective in the long term.
Clean covers provide
an immediate benefit
by safely isolating the
contamination. Covers
must be monitored

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Use this space to write your comments
Your input on the alternatives being considered for the cleanup of the Tittabawassee River floodplain soil is important to
EPA. Comments provided by the public are valuable in helping EPA select a cleanup plan.
You may use the space below to write your comments, then detach, fold and mail. Comments must be postmarked no later
than Oct. 14. You may also hand this in or give your comments orally at the public meeting on Sept. 24. Comments can
also be submitted online at www.epa.gov/region5/cleanup/dowchemical. If you have any questions about the comment
period, please contact Diane Russell at 989-401-5507, or at russell.diane@epa.gov. You may also call EPA's Chicago
office toll-free at 800-621-8431, 9:30 a.m -5:30 p.m. weekdays.
Name	
Address	
City	State
Zip	
5

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Proposed Cleanup Plan for Tittabawassee River Floodplain Soil
Public Comment Sheet
Detach, fold, seal, apply postage and mail
Name	
Address	
City	State
Zip	
Diane Russell
Community Involvement Coordinator
U.S. EPA Region 5 Superfund Division
Saginaw Community Information Office
804 S. Hamilton St., Suite 111
Saginaw, MI 48602
Place
Stamp
Here

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Cost: Table 2, on Page 4, shows the relative cost for each
alternative. Placing a clean cover is estimated to cost
between $17,000 and $30,000 per acre. Removing and
disposing of soil is estimated to cost between $33,000 and
$49,000 per acre. The ranges are preliminary and reflect
different costs when working in areas with heavy forests
compared to grassy areas, different excavation and cover
thicknesses, and other factors. Alternative 2 is the least
costly and Alternative 1 is the most costly. Because more
than 700 property parcels will need evaluations to determine
if cleanup is needed, it is not possible to estimate the total
Tittabawassee River floodplain cleanup cost at this time.
EPA's preliminary cost estimate for the recommended
alternative is $10 million, and likely more. Project costs will
be refined as property-specific cleanup plans are developed.
Common elements to all alternatives
Some features are common to each alternative:
•	Property-specific evaluations will be needed to better
understand specific floodplain areas requiring cleanup.
•	Access to the work areas may require temporary
roads across properties into the floodplain and
temporary staging areas for equipment and materials.
•	Excavated soil may be disposed of at a local landfill
or an approved area at Dow 's Midland plant.
•	Land in the floodplain would be managed to help
keep human exposure low.
•	EPA and MDEQ would monitor the cleanups.
•	A health and safety plan will ensure worker and
community safety while the work is underway.
•	A monitoring and maintenance plan will be required
to ensure long-term effectiveness for areas where a
cover is placed.
EPA calls land management tools "institutional controls,"
which are non-engineered instruments such as legal or
adminstrative controls. An example would be keeping land
undeveloped and natural through conservation easements or
other agreements. Land use within the floodplain is already
controlled under existing laws and regulations that restrict
construction, soil movement and development within the
floodplain. Additional long-term agreements would be
requested of property owners regarding the use of particular
floodplain areas in the future. Monitoring helps confirm that
future land uses are consistent with the land management
agreements and desired end use. More than one type of
institutional control may be applied to increase reliability.
EPA's recommended alternative
EPA, in consultation with MDEQ, recommends
Alternative 3 because it provides the best balance of
effectiveness, implementability and cost. Alternative 3
involves (1) the removal and disposal of surface soil in
Maintained Residential Areas where dioxin levels exceed
250 ppt, and (2) either removal and disposal of soil, or clean
River
Figure 3: Some typical floodplain properties
Zone A: Outside the floodplain, where levels are safe
and no cleanup is expected.
Zone B: Maintained Residential Areas in the floodplain
where the cleanup number of250 ppt would apply.
Zone C: Other Land Use Areas in the floodplain where
the cleanup number of2,000 ppt would apply.
cover, in Other Land Use Areas where dioxin levels exceed
2,000 ppt. The picture above shows some typical floodplain
properties and illustrates where the different cleanup goals
would apply.
Most of the floodplain is in a natural condition.
Alternative 3 helps preserve, protect or improve the
floodplain ecosystem by concentrating work in the most
contaminated or highly used areas. This alternative
permanently removes contaminated soil from the most
highly used areas - Maintained Residential Areas. The
environmental effects would be less in these areas since
lawns and similar areas are easier to reestablish. During
design, the team would work with homeowners to see if
specific trees could be retained. For Other Land Use Areas,
the final solution will be developed on a case-by-case basis,
depending on conditions and desired future land use at that
specific location. EPA will work with each property owner
to design and implement an acceptable solution.
For more information
You can read documents related to the Tittabawassee
River, Saginaw River and Bay site at
www.epa.gov/region5/sites/dowchemical, or at these
information repositories:
•	EPA Community Information Office,
804 Hamilton St., Suite 111, Saginaw.
•	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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EPA Proposes Cleanup Plan for Tittabawassee River Floodplain Soil
Tittabawassee River, Saginaw River & Bay Site
Midland, Saginaw and Bay City, Michigan
Opportunities to Learn More
Small, informal meetings
with floodplain property
owners
August & September
Various dates/times/places
Details to be mailed separately
to property owners
Formal public meeting
Freeland High School
Auditorium
8250 Webster Road, Freeland
Wednesday, Sept. 24
6:30 PM
60-Day Public Comment Period
Aug. 15 - Oct. 14, 2014
How to submit your
comments
In-Person
•	Submit written
comments at
informal and formal
public meetings.
•	Record verbal
comments for the
record at formal
public meeting.
k.
Online
• Go to EPA's website
and link to the
public comment
form
www.epa.gov/
region 5/
cleanup/
dowchemical
1 Mail in comment
form included in
fact sheet.
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