-001G1 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 L_ L 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 com- munity 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 1-2 p 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 environ- ment posed by the Cliffs-Dow site is potential soil and ground- water 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 contamina- tion is through direct contact with the soil by site intru- ders. 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 2-1 p r r. o n o D 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 filtra- tion 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 con- tamination. 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 volu- ntary 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.