Tittabawassee River Floodplain Soils Outreach Strategy
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TITTABAWASSEE RIVER FLOODPLAIN SOILS OUTREACH STRATEGY ADDENDUM #1 TO THE COMMUNITY INVOLVEMENT PLAN FOR THE TITTABAWASSEE RIVER, SAGINAW RIVER AND BAY SITE FEBRUARY 2013 OVERVIEW The Tittabawassee River, Saginaw River and Bay Site includes areas in and along a 24-mile stretch of the Tittabawassee River south of the confluence of the Chippewa River, the 22-mile Saginaw River and portions of the 1,143 square mile Saginaw Bay. The rivers and floodplains include residential, commercial, industrial, recreational and agricultural areas of Midland, Saginaw and Bay Counties in Michigan. The Saginaw Bay watershed is one of Michigan's most diverse areas – its rich resources support agriculture, tourism, manufacturing, outdoor recreation and a vast variety of wildlife. In the Tittabawassee River, dioxins and furans are the primary contaminants in sediment, riverbanks and floodplain soil. These contaminants came from historical releases from The Dow Chemical Company’s Midland Plant. EPA, in coordination with the Michigan Department of Environmental Quality, is requiring Dow to evaluate cleanup options at the Site under a legal agreement that was signed in 2010 between EPA, DEQ and Dow. Activities to be carried out under the agreement fall into three critical categories: Limiting contact with bare floodplain soil in areas frequently used by people Controlling movement of highly contaminated soil and sediment through early actions Developing comprehensive long-term cleanup options for the rivers and bay The current focus is on the Tittabawassee River because upstream cleanup is needed before EPA can move ahead with the Saginaw River and Bay. EPA’s initial strategy for comprehensive long-term cleanup was to divide the Tittabawassee River into seven segments for development of upstream-to- downstream cleanup options. The cleanup decisions for each segment would have addressed contaminated sediment, river banks and floodplain soils concurrently. As the cleanup has moved forward, EPA recognized that cleanup decisions for an upstream segment that represents a small fraction of the Tittabawassee River floodplain could establish precedents for downstream floodplain properties. Therefore, EPA has developed a refined approach that will allow the entire floodplain population to be engaged and participate in the decision-making process at the same time. The intention is to maximize input before the cleanups are proposed or selected. EPA believes that up-front community engagement will increase participation in selected cleanups while providing property owners with certainty about what cleanup will be offered, even if implementation is staggered over several years. Comprehensive decision-making for the floodplain soil at this time is likely to result in overall faster cleanup and risk reduction for the floodplain. EPA’s revised strategy for comprehensive cleanup includes the following elements: Continued selection and implementation of upstream-to-downstream cleanup for in-channel sediment and river banks for Segments 2 – 7 of the Tittabawassee River. (Segment 1 cleanup was selected in 2011, is under way and is expected to be complete in 2013.) Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Selection of the cleanup approach for floodplain soil for the entire Tittabawassee River floodplain at one time, with implementation in an upstream-to-downstream fashion, concurrent with completion of the adjacent segment sediment and river bank work. Figure 1 shows the Tittabawassee River segments including the floodplain shown in blue. There are about 4,500 acres in the frequently flooded areas of the Tittabawassee River floodplain. Focus is on the frequently flooded areas because that’s where significant levels of dioxins and furans have been deposited over time. The entire floodplain is not equally contaminated and some areas may not require cleanup. EPA is currently evaluating which floodplain areas may need work. Current estimated land use includes idle portions of residential property and other natural areas [~ means about]: ⋅ ~54% of the floodplain acreage ⋅ ~5 active residential ⋅ ~15% Shiawassee National Wildlife Refuge ⋅ ~18% active agriculture ⋅ ~5% commercial ⋅ ~3% public parks including Tittabawassee Township, Freeland Festival, Imerman and West Michigan About 73% of the floodplain (including portions of parks, the Refuge, natural areas, residential and commercial properties) is wetlands, forested or Figure 1: Tittabawassee River Segments and unmaintained and returning to the wild. Floodplain OUTREACH STRATEGY OVERALL GOALS – WHY EPA IS CONDUCTING ENHANCED OUTREACH FOR THE TITTABAWASSEE RIVER FLOODPLAIN Because the cleanup decision will affect many properties and landowners, EPA wants to make sure that the entire Tittabawasee River floodplain community has the opportunity for early and continuing input during the decision process. EPA wants to understand the community’s values about the current state of the floodplain and their desires for future conditions and uses. EPA also wants to obtain feedback on possible approaches to the cleanup of floodplain soils and the trade-offs that come with each option. EPA is currently working with DEQ and Dow to develop cleanup approaches for the Tittabawasee River floodplain soil. The preliminary cleanup options and their tradeoffs are discussed in a document called February 2013 Page 2 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy the Tittabawassee River Floodplain Soil Alternatives Array (which can be found at www.epa.gov/region5/cleanup/dowchemical/floodplain). Early feedback on these preliminary options will allow the community’s concerns to be reflected in EPA’s final proposal. In addition to early, informal feedback, EPA will take formal public comment on its proposal before selecting the Tittabawassee River floodplain soil remedy. PARTICIPATION – HOW EPA WILL EXCHANGE/RECEIVE INFORMATION FROM THE PUBLIC In order to engage the Tittabawassee floodplain stakeholders to obtain feedback on possible approaches to the cleanup of floodplain soils, EPA will use elements from the Site Community Involvement Plan, which lays out many approaches to reach residents and owners affected by Site contaminants. Among the approaches suggested in the CIP, the following may be most useful for Tittabawasee River floodplain outreach: Informal Public Participation Description: Informal interactions with EPA staff are among ways the public and EPA can communicate about the project and a way for EPA to understand the public’s concerns. Goal: Give the public the opportunity to provide informal feedback early and throughout the process. This will allow EPA to recognize trends in issues of public concern and identify areas that need more information or clarification. Method: EPA will initiate a series of small group discussions with floodplain landowners at times and places convenient to them. EPA is likely to target groups by land use (e.g., homeowners, farmers, etc.). EPA may advertise these discussions by placing leaflets on doors, posting flyers at commonly visited locations and by other means. EPA may selectively invite target groups or individuals to meet informally. EPA may also consider knocking on doors to chat with landowners. EPA is also considering a moderated workshop to solicit input. Informal comments can be offered at any time, such as by calling or visiting the EPA Saginaw Community Information Office or during availability sessions, open houses and community events. Written comments may be sent by email or mail. Stakeholder Group Interaction Description: EPA will coordinate with stakeholder groups and actively seek to present information at their meetings. Goal: Ensure that members of these organizations receive the information they need and that EPA receives their comments and understands their concerns. Interaction with stakeholder groups can also extend EPA’s outreach by sharing EPA notices of events, site updates and other information with their members and constituents. Method: EPA coordinates with and will try to present information at meetings of targeted stakeholder groups. On request, EPA will try to attend meetings of stakeholder groups. EPA is also considering a moderated workshop to solicit input. February 2013 Page 3 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Formal Public Comment Description: Formal public comment is an opportunity for community members to review and contribute comments on various EPA documents or actions. Comment periods with set deadlines are required for certain actions such as Proposed Cleanup Plans or Engineering Evaluations/Cost Analysis documents. Goal: Comment periods give people the opportunity for formal participation in the process and give EPA valuable information for use in making decisions. Method: After considering feedback from the early, informal outreach, EPA will take formal public comment on the proposed cleanup plan for floodplain soils before selecting the final remedy. EPA announces comment periods with newspaper postings, listserv notifications and fact sheets. Public announcements are made to ensure the public understands what is being presented, when comments will be accepted, how long the comment period will be open and how to submit comments. After