&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. ------- 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. z Z> Midland 8 » % FreelarnS Rd Tittabawassee River Floodplain Work Schedule Segment 2 Planning 2015 Work Start 2015 / 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. / A Figure 1: Tittabawassee River floodplain location and anticipated schedule. What to expect when cleanup starts in your river segment o Project team meets with you to f discuss property- specific details Project team takes samples (if needed) k EPA determines \ If work ) if work on property is I needed ' needed o Owner input Project tearm develops work plans and schedules work / o 1 EPA sends Project team \ you a letter conducts \ stating cleanup on /cleanup is property / / complete J Hi If no work is needed Figure 2: What to expect when cleanup starts in your river segment. 2 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. uddvj pdpfod}[ uo pdonpoudd^ ^ i;os ujeidpoou jaAjy easseMeqewil joj uey dnueap sasodojd Vd3 :3±IS AVa S d3Ald MVNI9VS 'd3AIU 33SSV/\AVaVllil SS-0 on l!LUJ0d Vd3 P!Bd S09j puB sBeisod ||B|/\| SSBIO }SJIJ S098fr I1AI 'MBinees 1.1.1. 31! "S "is uojIIlUbh S t>08 90IJJO uoueoijojui Ajmniuiuoo mbu|6bs uojSjAia punjjadns S uoi69y vd3 STI Aoua6\/ uoijoeiojd iBjuaLuuojjAug sa)B}s psjiun Vd3'cv ------- |