Late on Friday, November 9, 2007, Dow notified U.S. EPA that preliminary data for a sediment sample collected from within the channel of the Saginaw River was in excess of 1.6 parts per million (ppm) Dioxin TEQ. This is the highest TEQ analytical result recorded for either the Tittabawassee or Saginaw Rivers. On November 11, 2007, U.S. EPA issued a verbal General Notice Letter of Potential Liability to Dow.
On Monday, November 12, 2007, U.S. EPA, MDEQ and Dow representatives met at Wickes Park in the City of Saginaw to review site conditions and discuss U.S. EPA’s expectations for the conduct of an expedited time-critical removal action. An Administrative Order by Consent will be issued to Dow for the performance of the removal. Dow was in the process of collecting physical site data such as river depth and velocity measurements, collecting sediment samples for dewatering studies, and channel profile measurements.
On Monday November 12, 2007, a meeting was held at the Saginaw River Site with U.S. EPA, MDEQ, and Dow representatives. Attendees include: U.S. EPA OSC Jim Augustyn, U.S. EPA OSC Mark Durno, Mr. Al Taylor MDEQ, Mr. Todd Konechne Dow, Mr. Scott Madill URS, Mr. Robert Kaufman Environ. Mr. Steve Omara Fisher Construction, Inc., Mr. Dan Capone U.S. EPA START, and Ms. Katie Mooney U.S. EPA START.
Discussed initial activities being conducted by Dow. Dow currently conducting a river assessment using transect to measure the river flow and depth every 25 feet for 75 feet north and south of the elevated sample location then every 100 feet. In addition Dow will collect approximately six to eight bulk sediment samples from 0 to 8 inches deep in the area of the elevated dioxin concentrations to analyze for disposal characteristics.
U.S. EPA and MDEQ have requested additional information from Dow to better understand the conditions at the Site.
MDEQ has contacted the Michigan Department of Community Health and they have recommended additional public notice via advisory signage at the hot spot and the Rust Ave boat launch or request the gate house at the boat launch distribute a one page map/advisory requesting fishermen avoid the hot spot area.
Dow will conduct a removal of sediments with elevated dioxin levels in the area of the elevated sample location.
U.S. EPA and MDEQ will require the area to be fully bounded by sampling to include depth sampling to obtain natural background information.
Dow will provide copies of analytical results from the site, including dioxin and furan data and any follow up confirmation analyses and any other potential constituents of interest (PCOI) data that has been collected. This information is necessary to better understand the nature of this deposit and for the development of the health and safety plan and to determine ARARs for any water treatment/discharge.
Dow will provide copies of any other relevant site characterization data from the collection of the initial samples including boring logs, sample descriptions, bathymetry, velocity measurements, cross-sections, sample collection methodology, field notes from sample collection, etc.
Dow will provide an update on obtaining property access from the City of Saginaw and General Motors for conducting the removal action.
Dow will provide a list of removal and disposal options being considered based upon existing data and data that is being actively collected.
Dow will provide a schedule for the collection and analysis of additional extent of contamination sampling.
Dow will provide revised copies of the map showing existing sampling locations and concentrations.
MDEQ and MDCH will provide additional public notice via advisory signage at the hot spot and the Rust Ave boat launch or request the gate house at the boat launch distribute a one page map/advisory requesting fishermen to avoid the hot spot area.
Dow will subitt a work plan for removal action and will implement selected removal action as defined in the approved work plan.
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