TITTABAWASSEE RIVER FLOODPLAIN SOILS OUTREACH STRATEGY ADDENDUM #1 TO THE COMMUNITY INVOLVEMENT PLAN FOR THE TITTABAWASSEE 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 . The rivers and floodplains include residential, commercial, industrial, recreational and agricultural areas of Midland, Saginaw and Bay Counties in . 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 ’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 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 the comment period closes, EPA produces a document responding to the comments.

CURRENT STRATEGY – HOW EPA WILL INTERACT WITH FLOODPLAIN STAKEHOLDERS

This strategy identifies the major Tittabawassee River floodplain stakeholders in the Bay City-Midland- Saginaw area, referred to here as tri-county area, with ways to reach out to them to provide an opportunity for meaningful input on the cleanup of floodplain soils. This strategy supplements but does not replace the CIP. This strategy will be adjusted, as needed, to meet EPA and stakeholder needs. Initially, EPA will focus its floodplain outreach around public participation and stakeholder group interaction. The level of this group interaction will be to inform, consult and involve. EPA will inform stakeholders by identifying potential cleanup options and what the possible trade-offs may be for each option. This interaction is an opportunity for involvement and providing EPA information about the community’s values regarding the floodplain and its future.

February 2013 Page 4 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Timeline

Figure 2 shows the project timeline including how the Tittabawassee River floodplain fits into the overall Site cleanup. Starting in 2013, EPA will conduct early informal outreach before any formal cleanup options are developed, proposed or finalized. EPA hopes to have a proposal for cleanup of floodplain soils to the public for formal comment in 2014. This schedule may be influenced by community feedback in 2013.

Figure 2: Project Timeline

February 2013 Page 5 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Outreach Groups and Delivery Methods

Following describes each category contained in the table below:

Audience: The targeted/selected group. The Tier indicates the outreach commitment for EPA based on how critical the group’s input is in achieving Agency goals and meeting its commitments to policies and Site cleanup.  Tier 1: The individuals and groups that will be most directly affected by EPA’s cleanup decision for Tittabawasee River floodplain soils. Their level of participation includes inform, consult and involve.  Tier 2: Groups that are important because of the nature of their impact on the community and concerns regarding EPA’s cleanup decisions. Their level of participation is to inform and consult.  Tier 3: Groups that are important in the community but may not be directly affected by EPA’s cleanup decision for Tittabawasee River floodplain soils. Their level of participation is to inform and consult, as needed. • Reason: Why the group was targeted or selected. • Method: How and where outreach will occur. • Start Time: Approximate timeframe when scheduling outreach presentations/meetings/ discussions will start. There will be ongoing outreach, as needed, throughout the decision- making process.

Audience Reason Method Start Time Tier 1 Tittabawassee River Floodplain Residents Tittabawassee River Residents’ property may Hold small meetings at March 2013 floodplain be directly affected by times and places residents/neighborhood cleanup decisions made convenient for residents associations for the Tittabawassee and associations. floodplain area. It is important EPA Try to schedule understands their presentations at venues concerns and values. close to major clusters of homes.

Try to get on agenda of neighborhood groups’ meetings.

Possible workshops.

Possible door knocks.

February 2013 Page 6 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Audience Reason Method Start Time Tier 1 Tittabawassee River Floodplain Agricultural Groups Tittabawasee River Owners of agricultural Invite farmers and February/March floodplain land may be affected by agricultural group 2013; ideally Farmers/Agricultural cleanup decisions made representatives to before planting Groups for the Tittabawassee meetings. season starts floodplain area. It is important EPA Hold meetings at venues understands their close to major clusters concerns and values. of farmers.

Try to get on agenda of groups' meetings.

Possible workshop.

Tittabawassee River Floodplain Businesses Tittabawassee River Outreach and feedback Try to schedule April 2013 floodplain Businesses from business owners presentations at groups’ within the Tittabawassee meeting sites. floodplain whose property and/or Hold meetings for them operations may be at CI office. affected by potential floodplain cleanup Possible workshop. activities.

Park and Recreation Departments Parks and recreation Feedback about impacts Meet with park April 2013 departments managing to park property and managers. parks along how users potentially are Tittabawassee River affected will be Try to get on agenda of important to developing groups’ meetings. long term cleanup plans.

February 2013 Page 7 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Audience Reason Method Start Time Tier 1 U.S. Fish and Wildlife Service/Shiawassee NWR Users or Partners U.S. Fish and Wildlife FWS manages the Meet with the Refuge April 2013 Service/ Shiawassee Shiawassee National Manager. NWR users or partners Wildlife Refuge. Portions of the Refuge are located Meet with the FWS Site within the floodplain and coordinator. may be affected by long term cleanup plans. Meet with groups that have a particular interest in the Refuge.

Tier 2 Elected Officials/Local Government Bodies Federal/State Elected Elected officials Individual or group February/March Officials represent a broad range meetings at CI office, 2013 of constituents. It is offices of the officials, or important for them to be small neutral space advised early on about venue. activities in their communities so that they Telephone contact, as can discuss them with appropriate. their constituents.

Local Government Elected officials Individual or group February/March Bodies represent a broad range meetings at CI office, 2013 of constituents. It is offices of the officials, or important for them to be try to get on agenda for advised early on about regularly scheduled activities in their meeting. communities so that they can discuss them with Telephone contact, as their constituents. Local appropriate. Government bodies represent residents on a local level.

February 2013 Page 8 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Audience Reason Method Start Time Tier 2 Tribe Tribe There is one federally EPA will follow its March 2013 recognized tribe within government-to- 50 miles of the Site – the government Saginaw Chippewa Indian consultation Tribe of Michigan. Their procedures. input on EPA activities could help guide decisions.

Tittabawassee-Saginaw Rivers Contamination Community Advisory Group Tittabawassee-Saginaw This group represent a EPA will present March & May Rivers Contamination broad range of interests information at the 2013 Community Advisory in the community. regularly scheduled CAG Group meetings.

Environmental Groups Environmental Groups There are a few groups in Hold meetings for them June 2013 the tri-county area that at CI office or another identify themselves as location. environmental groups. They are concerned Try to get on agenda of about EPA decisions for groups’ meetings. the Site.

Chamber of Commerce/Better Business Bureau Chamber of Commerce/ These organizations Try to get on agenda of June 2013 Better Business Bureau represent additional groups’ meetings. stakeholders in the community. Tier 3 Sportsmen Organizations Sportsmen organizations This category is intended Try to get on agenda of On invitation and to reach out to hunters groups’ meetings. if time permits and anglers in the tri- county area who may use the Tittabawassee floodplain.

February 2013 Page 9 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy

Audience Reason Method Start Time Tier 3 Civic Organizations Civic organizations Civic organizations cover Try to get on agenda of On invitation and a wide variety of groups’ meetings. if time permits interests and groups ranging from those aimed at youth to senior citizens. Because they are so ubiquitous, informed groups can be useful allies in sharing EPA messages in the community.

Non-Governmental Organizations Non-Governmental Like civic organizations, Try to get on agenda of On invitation and Organizations NGOs cover a wide groups’ meetings. if time permits variety of interests and groups. Because they also are ubiquitous, informed NGOs can be useful allies.

Real Estate Agents [Realtors] Real Estate Agents Real estate agents have Try to get on agenda of On invitation and [Realtors] commercial interests groups’ meetings. if time permits similar to Chamber of Commerce, et al., but Hold meetings at CI more specific products. office. Student Groups Student Groups Students (high school, Hold informal meetings On invitation and college) may have a at campuses. if time permits unique perspective on their community and can offer useful input on EPA cleanup activities. They can also serve as surrogate educators to family, friends, and others.

February 2013 Page 10 Community Involvement Plan for Tittabawassee River, Saginaw River and Bay Site Addendum #1: Tittabawassee River Floodplain Soils Outreach Strategy Audience Reason Method Start Time Tier 3 Unions Unions Meetings with union Try to get on agenda of On invitation and groups can provide groups’ meetings. if time permits information about EPA proposed activities and Hold meetings at CI discuss the costs and office. benefits of cleanup activities.

Environmental Justice Groups Environmental Justice This is a category to Try to get on agenda of On invitation and groups address the needs of groups’ meetings. if time permits those who EPA has identified as meeting EJ Hold meetings at CI criteria. office.

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