United States Environmental Protection Agency
Region V
POLLUTION REPORT

Date:	Sunday, September 02, 2007
From:	James Augustyn/Brian Schlieger, On-Scene Coordinator

To:	Jason El-Zein, ERB 1/RS-1	David Chung, OSWER
	Al Taylor, MDEQ	NRC Duty Officer, National Response Center
	Cheryl Howe, MDEQ	Mark Johnson, U.S. EPA R5
	Bill Bolen, ERB 1	Todd Konechne, Dow Chemical Company
	Jeff Cahn, USEPA	Jim Sygo, MDEQ

Subject:

Tittabawassee River Reach J/K
Midland, MI
Latitude: 43.5719
Longitude: -84.2006

POLREP No.:	4	Site #:	B5KF
Reporting Period:	August 24 through August 30, 2007	D.O. #:
Start Date:	8/6/2007	Response Authority:	CERCLA
Mob Date:	8/6/2007	Response Type:	Time-Critical
Completion Date:		NPL Status:	NPL
CERCLIS ID #:	MID980994354	Incident Category:	Removal Action
RCRIS ID #:		Contract #

Site Description

On June 27, 2007, U.S. EPA ordered The Dow Chemical Company (Dow) to negotiate an Administrative Order on Consent, to address removal of extremely elevated levels of dioxin-contaminated soil from an eroding river bank within Reach JK of the Tittabawassee River near Midland, Michigan. Dow agreed to the terms of the Order and on July 12, 2007, the Order was signed by the Regional Administrator and Dow. For additional background information please see the site profile.

Reach JK will be divided into two areas. The area along the river bank where contaminated soil will be excavated will be designated JK-1, and an area further back from the river bank where clean soil will be used to cap contaminated soil will be designated JK-2.

On-Scene Coordinator (OSC) Jim Augustyn provided oversight with assistance from U.S. EPA’s START Contractor, Weston Solutions, Inc.

Current Activities

The following tasks have been completed by Dow’s contractor during the period from August 24 through August 30, 2007:

•    Collection and laboratory analysis of waste characterization samples for waste profiling from the soil being loaded into the trucks for disposal at Dow's Salzburg Road Landfill.

•    Collection and laboratory analysis of post removal soil samples from the JK-1 area after the impacted soils have been removed to the engineered depth.

•    The collection and laboratory analysis of soil samples from an off site source of topsoil which will be used to cap the removal areas of JK-1 and JK-2.

The following tasks are currently on going at the Site:

•    Excavation of the impacted soils at JK-1 continues. Excavation activities for the 1st cut on JK-1 started on August 17, 2007, and are expected to be completed by August 31, 2007.

•    Transportation and off site disposal of impacted soil from the JK-1 excavation area to the Salzburg Road Landfill.

•    Installation of an 8-foot high chain link fence around the wooded wetland area of JK-2.

Planned Removal Actions

•    Post removal sampling identified an area in JK-1 that Dow has elected to excavate and dispose an additional 12 inches of soil from the northern most portion of the JK-1 area.

•    The installation of river bank armoring, rip rap, along the shoreline at the northern and southern ends of the JK-1 area most susceptible to river currents.

•    Collection and laboratory analysis of post removal soil samples from the JK-1 area prior to placing top soil and fish gravel along the lower river shelf.

•    The removal of wood chip access haul roads and the truck decontamination pad within the JK-1 excavation area.

•    Installation of an irrigation system for dust suppression and to water vegetation planted as part of the Site Restoration Activities.

Next Steps

• Mobilization of additional heavy equipment to begin the JK-1 cut #2 excavation activities. Cut #2 will bring the site grade to engineered specifications to reduce river scouring action on this portion of the river bank. Excavated material from JK-1 will be used to cap impacted area in JK-2.

• Complete installation of an 8-foot high chain link fence around the wooded wetland area of JK-2.

Key Issues

• The Trustee partners are reviewing and will comment on the draft Site Restoration Plan. Restoration activities will start as soon as possible to establish ground cover to reduce erosion. Replacement of large trees and shrubs with native plants will begin as soon as plantings are available.

Estimated Costs *

	Budgeted	Total To Date	Remaining	% Remaining
Extramural Costs
RST/START	$100,000.00	$13,800.00	$86,200.00	86.20%
Intramural Costs

Total Site Costs	$100,000.00	$13,800.00	$86,200.00	86.20%

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

Disposition of Wastes

• As of August 29, 2007, Dow has removed and transported to the Salzburg Landfill approximately 17,136 in-place cubic yards of impacted soil from the Reach JK-1 area. Approximately 24,000 in-place cubic yards of impacted soil is the estimated total volume to be removed.