REVISED COMMUNITY RELATIONS PLAN C BASED OH ADDITIONAL COMMENTS from CLIFFS-DOW

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E r c REVISED COMMUNITY RELATIONS PLAN c BASED OH ADDITIONAL COMMENTS FROM CLIFFS-DOW

CLIFFS-DOW DISPOSAL AREA MARQOFTTE, MICHIGAN

EPA 10A.5L27.0

August 22, 1984

GLT469/16

L f CONTENTS Section Page 1 INTRODUCTION 1-1

2 COMMUNITY RELATIONS BACKGROUND Site Description 2-1 History of Community Relations 2-3 0 Activities Interested Parties and Key Concerns 2-4 Community Relations Objectives 2-7

COMMUNITY RELATIONS WOPK PLAN Community Relations Techniques and 3-1 [j Tasks Staffing Allocation 3-5 r— Budget 3-6

MAILING LIST Agencies 4-1 Interest Groups Elected Officials Media GLT469/29

L [- r Section 1 INTRODUCTION

The Superfund program encourages active dialogue between communities that may be affected by the releases of hazardous substances and the agencies responsible for administering remedial actions. Therefore, community relations is an impor- tant function in connection with Superfund sites. It begins with the preparation of a plan to guide community relations activities during the Remedial Investigation and Feasibility Study. The Community Relations Plan presented in this docu- ment has been tailored to the needs of the community sur- rounding the Cliffs-Dow disposal area and is designed to r keep the public informed of site developments, and to allow them to review and comment on decisions that would affect final action at the site. ^•—/ This Community Relations Plan has been prepared for Phase I, Remedial Investigation and Feasibility Study (RI/FS) , work f* at the Cliffs-Dow site in Marquette County, Michigan. The L. plan is divided into the following sections: { o Introduction | o Community Relations Background o Community Relations Work Plan o Mailing Lists 1 The Community Relations Background (Section 2) provides a site description, a history of community relations activ- j ities, and a discussion of the participants and issues sur- L rounding the site. This information was used to design community relations objectives appropriate to the site. This r section is based on discussions with agency staff, public officials and citizens familiar with the site. The names ^"^ and addresses of these individuals are included in Section D. j The Community Relations Work Plan (Section 3) designates i specific tasks to be completed during the RI/FS. These tasks are outlined in sequence and correspond to related technical j work activities. Staff allocations are shown by task, and j budget information is provided. The RI/FS and corresponding community relations activities are scheduled to continue for 17 months. * Section 4 includes the names of agencies; elected officials; and the media. j L This plan is a dynamic tool, its objective is to respond to site conditions as they occur. It will, therefore, be I reviewed periodically during the RI/FS and will be revised 1 to reflect schedule and activity changes, new technical findings and emerging public concerns and information needs.

1-1 r. f~ The U.S. EPA, in coordination with the Respondents, v/ill be responsible for implementing the Community Relations Plan. GLT469/24 r r r c c

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Section 2 COMMUNITY RELATIONS BACKGROUND

SITE DESCRIPTION The Cliffs-Dow plant disposal area is located in the City of Marquette, Michigan on 2 acres of wooded and shrub-covered land. The site is west of Dead River and north of County Road 550 (Figure 2-1) . The area around the site is largely undeveloped. The five nearest residences are about one-quarter mile to the west. The City of Marquette,a community of about 23,000 people, owns the site. In 1955, the city leased it to Cliffs-Dow Chemical Company. The Cleveland Cliffs Iron Company and the Dow Chemical Company were shareholders in this company. e The site was used by Cliffs-Dow for the disposal of wood tars from the manufacture of charcoal and chemicals. c The exact dates of when the area was used by Cliffs-Dow for disposal of wood tars cannot be determined. The available records suggest the dates from about 1955 to sometime in the i, 1960's. In 1968, Cleveland Cliffs Iron and the Dow Chemical Company sold their shares in Cliffs-Dow to Georgia-Pacific Corporation and to E.L. Bruce, after which operations con- tinued under the name of Royal Oak Charcoal Company. The most significant threat to public health and the environment posed by the Cliffs-Dow site is potential soil and groundwater contamination by leachate from the site. A 1981 study indicated probable soil and groundwater contamination. The soil was reported to contain concentrations of lead, nickel, selenium, silver, zinc, and two organic pollutants (chloroform L and ethyl benzene) . A wood tar sample contained six pollutants (chloroform, fluoranthene, napthalene, phenanthrene, 2-4 dimethylphenol, and phenol). Soil contamination appears to exist to a maximum depth of 17 feet below ground level. Since the contamination extends several feet beyond the fill, it appears, that the wood tar residue components have reached down to the underlying soils and groundwater. The greatest immediate threat posed by the soil contamination is through direct contact with the soil by site intruders. Waste materials protrude through the ground cover, which does not completely cover the disposal area. Groundwater samples taken immediately adjacent to the fill were analyzed in May 1982 by Environmental Control Technology Corporation (ENCOTEC) for the City of Marquette. Their results

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LEGEND

mmm CLIFFS-DOW DISPOSAL AREA SITE 4000

2000

SOURCE: USGS MARQUETTE QUADRANGLE SCALE IN FEET 7.5 MINUTE SERIES 1954 - PHOTO REVISED 1975

FIGURE 2-1 SITE LOCATION CLIFFS-DOW SITE

L- p indicated levels of chloroform and benzene in excess of the U.S. EPA water quality criteria. There is some indication that the chloroform and benzene may be do to laboratory or field collection continuation. The Dead River, situated south and east of the disposal site, flows to the northeast where it empties into Lake Superior about 1 mile downstream from the site. The direction of I groundwater flow across the site is generally to the east and slightly to the northeast away from the disposal site, towards the Dead River which is about 1/2 mile away. The potential of contaminated groundwater feeding into the Dead n River could create surface water contamination problems. The City of Marquette uses Lake Superior for its main source r of drinking water. Two residential wells west of the site were sampled by the Michigan Department of Public Health in April 1982. Accord- I; ing to the Department's analysis, no contamination was apparent. A site assessment prepared by Weston-Sper for the U.S. EPA in July 1983 recommended limiting access to the site to con- 0 trol unintentional access. To date, this has not been done. r HISTORY OF COMMUNITY RELATIONS ACTIVITIES The public is largely unaware of the Cliffs-Dow County Road 550 disposal area. Many citizens of the area are not aware of the potential hazards of the disposal area nor that it is on the Superfund National Priorities List (NPL). However, the public is aware of the former plant site. When the Cliffs-Dow site is mentioned, the public immediately focuses on the former plant site, and not on the County Road 550 disposal area. The County Road 550 disposal area is rather remote, little used, relatively small in size, and not an obvious or obtru- sive health threat, as perceived by the public; consequently, it has received scant attention, from the community or the media. The government and private industry, on a voluntary basis, have been and continue to be involved at the site. According to Mike Etelamaki, Public Works Director, City of Marquette, there is no evidence of public complaints about the'site between 1955 and 1981. In the Spring of 1981, two people reported that they had walked through the disposal area and soiled their clothing with tar residue. The city then began site investigations and placed the County Road 550 disposal area on the U.S. EPA inventory list. The disposal area was also included in the city's water filtration assessment to determine any possible impact the site may have on water quality.

2-3 F Continuing in 1981 through 1982, soil, surface water, and r residential well samples, as well as groundwater analysis, were performed by City of Marquette consultants, the Dow Chemical Company and the Michigan Department of Public Health. r This preliminary testing indicated soil and groundwater contamination. In December 1982, the County Road 550 disposal area was placed on the Superfund National Priorities List by r the U.S. EPA. At the annual meeting of the Upper Peninsula Environmental Coalition (UPEC) held April 1983 in Marquette, The Department r of Natural Resources included in its presentation a discussion of the Cliffs-Dow County Road 550 disposal area. The local daily, The Mining Journal, covered the meeting. In March 1984, the students at Northern Michigan University sponsored a public forum at which various environmental issues, including the Cliff-Dows site were discussed. Channel 6 covered the proceedings, as did the student newspaper, the Northwind. To date, the City of Marquette, as owner, has participated in several meetings with the other involved parties; namely, Cleveland Cliffs, Dow Chemical, and Georgia-Pacific in voluntary effort to define and resolve the disposal area problems. In addition, the tests and studies of the area undertaken by the city have either been in conjunction with Dow Chemical or have been reimbursed by Cleveland-Cliffs and Dow Chemical.

INTERESTED PARTIES AND KEY CONCERNS

INTERESTED PARTIES Local and state government, along with the former shareholders of Cliffs-Dow, and its successor, Royal Oak, have been the most active participants in the Cliffs-Dow County Road 550 disposal area. Some limited interest has been shown by local organizations and the media. City of Marquette Depending on the legal interpretation, the City of Marquette is either a responsible party or an interested party in site activities. The city has expressed a desire to do whatever is necessary to clean up any potential hazards. The city believes that their joint efforts with Cleveland Cliffs and Dow Chemical have been effective and beneficial thus far. Cleveland Cliffs and Dow Chemical have reimbursed L the city for site-related costs, and have supplied technical support and equipment for analyses and studies. The city is concerned that federal and state involvement may jeopardize their working relationships.

2-4 L n The city's community relations efforts have cpnsisted of r participating at the NMU environmental forum held in March 1984, at which Mike Etelamaki, Public Works Director, addres- sed the County Road 550 disposal area issue. t- In a telephone interview with Mr. Etelamaki on June 20, 1984, he stated that the city would like to secure the site and is hoping that funding from Superfund will be available. At E present, the site is only posted with "No Trespassing" signs, with a barrier placed across the site entrance. 0 The city would like to be informed prior to scheduling of public meetings. Mr. Etelamaki recommended issuing press releases to make the public aware of upcoming meetings, the issues involved, work to be accomplished, and the results of the private negotiations among the city, Dow Chemical, Cleveland- Cliffs and Georgia-Pacific. As a participant, the City will 0 be kept informed of findings throughout the RI/FS. Cliffs-Dow Chemical Company Although this company no longer exists, the former shareholders G of Cliffs-Dow and Royal Oak are involved with the City of Marquette in developing and implementing the Remedial Inves- tigations/Feasibility Studies for the County Road 550 disposal G area. Because the parties will develop and implement the RI/FS, they will be an integral part of the community relations activities, and will provide advice and assistance throughout the investigation. L State of Michigan Two state agencies have been involved in the Cliffs-Dow County Road 550 disposal area: 1) the Michigan Department of Natural Resources (MDNR), and 2) the Michigan Department of Public Health (MDPH). The MDPH collected residential well samples in April 1982 in the area. Results of that one sampling indicated no well contamination. In addition, the city has been working with MDPH on a water filtration program, the disposal area, and the plant site. The MDNR has been involved L in almost all aspects of the site work and actions to date, either in a leadership or oversight role. Interest Groups Because they believe that the more obvious and potential hazard and threat is the Cliffs-Dow former plant site, citi- L zens have not organized to voice their concerns about the County Road 550 disposal area. However, there is an organi- zation in the area formed for the purpose of maintaining and L improving the quality of the environment. The Dpper Peninsula

2-5 L r Environmental Coalition (UPEC) has been in existence since f 1976, and has a membership of 100 individuals and 10 businesses, industries, and other groups. r Bill Robinson, board member and professor in the Biology Department at NMU indicated that UPEC expects to become involved in the community relations activities at the disposal site. He requested meetings with the U.S. EPA to gain familiarity o with the issues, to gather information on health effects posed by potential groundwater and surface water contamination, and to discuss potential ways of stopping contaminated ground- '0 water flows. Professor Robinson stated that people in the area are more r concerned about the Cliffs-Dow plant site than they are about the County Road 550 disposal area, which has received very little publicity. It is his belief that citizens are not aware of the potential hazards associated with the disposal c site. Northern Michigan University Students Both Professor Robinson and Mr. Etelamaki from the City of Marquette mentioned that the NMU student body is active in environmental issues. The political science students sponsored an environmental conference in March 1984 at which the County Road 550 disposal site was discussed.

KEY CONCERNS Public Misconception Public confusion exists over the Cliffs-Dow former plant site and the Cliffs-Dow County Road 550 disposal area. The public is under the impression that the former is the target c of Superfund remedial activities. V7hen they are made aware that the County Road 550 disposal area is on the National Priorities List, they immediately question why the the former i: plant site is not on the NPL. Most people regard the former plant site, which had been a producer of charcoal from the early 1900's until 1969, poses the higher potential hazard L of the two sites. As a result, U.S. EPA must continue to make a distinction between the two sites, and to explain the method and process I: used in selecting sites for placement on the National Prior- ities List. L Public Information At present, interest and involvement in the County Road 550 L disposal area is limited to state and local government agencies I. 2-6 L r and the former shareholder of the Cliffs-Dow and Royal Oak f companies. Public Involvement Citi2en awareness and concern appears to be minimal, and may increase as site activities begin and more information is provided. Initially, the UPEC will probably express the highest interest. Many of their members are biologists and geologists who are expected to be interested in the technical C issues. Potential Health and Environment Hazards Of primary concern to the City of Marquette and the Michigan Department of Natural Resources is the potential contamination of groundwater and surface water at or near the site. 0 An immediate concern is presented by the potential for contamination through direct contact by intruders with onsite wastes. The City of Marquette believes an immediate remedial G measure should include fencing of the site. COMMUNITY RELATIONS OBJECTIVES 1. Inform the public of the need for the RI/FS at the County Road 550 disposal area, in view of citizen belief that the Cliffs-Dow plant site is the more hazardous and threatening to the public health. 2. Carefully distinguish and communicate the differences between the Superfund-related activities at the County L Road 550 disposal area and the plant site activities to be undertaken by the State of Michigan. *— 3. Define an integral role for the respondents as participants in community relations activities. L 4. Provide all interested parties an opportunity to review the FS and comment on remedial action alternatives. A 3-week public comment period will be provided upon com- pletion of the draft FS, with a 2-week notice prior to L the beginning of the comment period. 5. Provide citizens, involved agencies and organizations, elected officials, and the media with timely, and con- sistent information about the scope, progress, and findings of the RI/FS. L 6. Provide a means for interested parties to express concerns L and make inquiries to ensure effective two-way communication.

2-7 n F 7. Provide all information, especially technical findings, in language that is understandable to the general public. 8. Identify a central contact who is available to provide a quick, reliable response to any questions or concerns by the public or government officials. G GLT455/13 n c G [j i; L

2-8 r, Section 3 fr COMMUNITY RELATIONS WORK PLAN r COMMUNITY RELATIONS TECHNIQUES AND TASKS The following techniques and tasks are designed to meet the objectives outlined in the previous section. Figure 3-1, at c the end of this section summarizes the schedule of community relations activities during the RI/FS. At the Cliffs-Dew site, it is fully anticipated that the G Respondents will perform the Remedial Investigation and Feasibility Study. Although, EPA will maintain leadership - for implementing the community relations program during the 0 RI/FS the Respondents will have an integral role, defined as follows: G o Information inquiries from the media, individuals, - etc., and will be referred to the Respondents as necessary. o The Respondents will have an opportunity to review and comment on mail-out material prior to distribution . o Respondents will be present at EPA sponsored community meetings. The Respondents will be given the opportunity to discuss aspects of the technical studies designated by EPA. o The Respondents may conduct their own public relations efforts or respond to media inquiries, in addition to their responsibilities in this CRP. U.S. EPA will stay in contact with the Respondents and each will share and public relations materials that is sent out. o The Respondents will participate in the develop- ment of the responsiveness summary. Their involvement in the RI/FS makes their assistance imperative when responding to public comment.

MAILING LIST A mailing list will be developed for the Cliffs-Dow site including state and local agencies, elected officials, media, and residents. A preliminary list has been provided in Section 4. Because the level of public interest has been low, a detailed citizen list is not available.

3-1 p G CENTRAL INFORMATION CONTACT The U.S. EPA, Region V will designate Mr. John Perrecone (312/886-6685) as their community relations person responsible for providing information to citizens, agencies, elected officials, and the media. Mr. Perrecone will work closely with his Michigan Department of Natural Resource counterpart and a representative of the Respondents. The contact person's G name, address, and telephone number will be included for easy reference in fact sheets and press releases, and will be listed in the public information repositories.

LOCAL REPOSITORIES A public information file will be established at selected repositories (such as city and university libraries or munici- pal building). Copies of relevant site information will be available for public review.

PRESS RELEASES Press releases under this community relations plan will be issued to the local and regional media to provide information about the RI/FS. The Respondents and local and state agency personnel will be notified before a press release is issued so they are aware of the content and are prepared to respond to citizen inquiries. Task A Issue a press release to announce the first community meeting (A) for the purpose of describing the RI/FS, its scope and schedule. Task B Issue a press release to announce the second community meeting (B) explaining the results of the RI. Task C Issue a press release to announce the final community meeting (C) at which the alternatives in the draft FS report will be identi- fied, examined, and preferred alternatives explained. Announcement of the public comment period will be made at this time. Task D Issue a press release to announce the U.S. EPA's record of decision, and describe the 0 implementation schedule. COMMUNITY MEETINGS L Three community meetings have been planned: Task A Conduct a community meeting (A) at the beginning of the RI/FS as an initial contact with potentially interested parties to:

3-2 L r o Introduce the EPA onsite coordinator i: (OSC). o Introduce the Respondents and their role. f o Describe the Superfund program and EPA role. G o Define the scope of the project and the schedule. o Identify the appropriate places in the 0 process for citizen input. o Describe the information distribution n procedure for the RI/FS. c o Allow for public comment and questions. o Determine the community's information needs and concerns. 0 Task B Conduct a community meeting (B) to present the results of the RI and to describe the alternatives being considered in the FS. Task C Conduct a community meeting (C) following the release of the draft FS to discuss the evalua- tion and recommendation of remedial alternatives .

TECHNICAL SUMMARIES Technical summaries of the RI and FS report will be prepared and distributed to persons on the mailing list, at community meetings, and will be available at the information repositories. The summaries will be clear, accurate descriptions of study findings and alternatives, prepared in a style and format that will encourage public use and understanding. Task A Prepare a technical summary of the remedial investigation. Task B Prepare a technical cummary of the Feasibility Study.

PUBLIC COMMENT PERIOD I A 3-week public comment period will be provided after release u of the draft FS. Notice of the comment period and of the availability of the FS will be issued 2 weeks before the ! comment period begins. Comments will be accepted in writing L or orally at the community meeting held during this period.

3-3 L The FS and technical summary will be available for review at public information repositories and other locations as appro- G priate. 0 RESPONSIVENESS SUMMARY A responsiveness summary will be prepared after the public comment period to summarize the comments received and to present the agency response to them. The summary will be distributed to those on the mailing list and placed in the information repositories.

REVISION OF COMMUNITY RELATIONS PLAN Community concerns and information needs will be monitored throughout the RI/FS. Community relations staff will also regularly check with technical staff to monitor any changes in technical activities or scheduling. The community relations plan will be reviewed quarterly and revised as necessary. GLT455/14 .. . • -'.•:.. 0

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3-4 L Section 4 PRELIMINARY MAILING LIST n STATE AND LOCAL AGENCIES AND INTEREST GROUPS pe U.S. EPA - Region V ! -: Doug Yeskis 230 South Dearborn Chicago, Illinois 60604 P| (312) 886-9296 City of Marquette David Svanda, City Manager *Mike Etelamaki, Public Works Director G 300 West Baraga n Marquette, Michigan 49855 h v_, (906) 228-8200 Marquette County Health Department G Dr. Randy Johnson Is 184 U.S. 41 Highway Negaunee, Michigan 49866 r> (906) 475-9977 Michigan Department of Natural Resources *Bob Schmelling District Office L- 1990 U.S. 41 Highway South Marquette, Michigan 49855 f (906) 226-7505 L Upper Peninsula Environmental Coalition r *Bill Robinson \^/ P.O. Box 34 Houghton, Michigan 49931 Michigan Department of Public Health

ELECTED OFFICIALS City of Marquette Mayor: Robert Stow, Sr. Commissioners: Ling; Berubi; Johnson • Kulishek; Labrecque; and Coyne 300 West Baraga Marquette, Michigan 49855 L (906) 228-8200

*Persons interviewed during preparation of the community relations plan.

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Representative Dominic Jacabetti C House of Representatives State Capitol Lansing, Michigan 48909 (517) 373-0498 Senator Norman D. Shinkle State Senate G State Capitol Lansing, Michigan 48909 Representative Robert Davis U.S. House of Representatives 1124 Longworth Building Washington, D.C. 20515 (202) 225-4735 MEDIA

NEWSPAPER News Editor The Marquette Mining Journal Marquette, Michigan 49855 (906) 228-2500 News Editor Detroit Free Press Detroit, Michigan News Editor The Northwind L Northern Michigan University Marquette, Michigan 49855

G TV AND RADIO WLUC - Channel 6 P.O. Box 460 Marquette, Michigan 49855 (906) 475-4161 WNMU - Channel 13 Northern Michigan University Marquette, Michigan 49855 WDMJ - Radio 842 West Washington Street Marquette, Michigan 49855 WGLQ - Radio 100 North Front Street Marcuette, Michigan 49855 GLT4~55/19 L 4-2