United States Environmental Protection Agency
Region V
POLLUTION REPORT

Subject: 

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 Tittabawasse 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 is providing oversight with assistance from U.S. EPA’s START Contractor, Weston Solutions, Inc.

The following tasks are currently on going:

•    Installation of chain link security fence around the wooded area of JK-2.
•    The installation of rip rap along the shoreline at the northern and southern ends of the JK-1 area.
•    The installation of an irrigation system for dust suppression and also to water vegetation planted as part of the Site Restoration Activities.
•    Removal of the soil from the JK-1 Cut-2 excavation area, and relocating the soil to the JK-2 backfill area (on site).

To view a map that depicts current site progress, please visit the Document Section of this website and open the document titled "Site features map".

The following tasks have been completed by Dow’s contractor during the period from August 31 – September 12, 2007:

Friday, August 31: Dow’s contractor completed the excavation and off-site disposal of the impacted soil within the JK-1 Cut-1 area.  Additional excavation was conducted on the north end and south end of the JK-1 Cut-1 area. An additional 12 inches of surficial soil was removed from these two areas based on elevated laboratory analytical results. Upon completion of excavation activities, post-excavation surface soil samples were collected.  The post-excavation samples were collected to ensure elevated soils would not be excavated and placed over the JK-2 area as cap material.  Post-removal samples will be collected in JK-1 area after the final cut of soil is excavated and placed in JK-2.

Saturday - Monday, Sept 1st – 3rd: No site activities took place due to the Labor Day weekend break.

Tuesday, Sept 4th:  Site activities included; delivery of rip rap stone, the installation of the stone along the southern most portion of the JK-1 area, surveyors marking the lateral extent of the JK-2 non-wooded area, and the installation of an irrigation system.

Wednesday, Sept 5th & Thursday, Sept 6th: No site activities conducted. Awaiting post excavation laboratory analysis.

Friday, Sept 7th: Laboratory analytical results indicated elevated dioxin levels in the central portion of JK-1 Cut-1 area remained.  Additional excavation activities were conducted in order to remove soil with elevated concentrations of dioxin from this central area. Upon completion of the excavation activities, samples were collected in order to determine if any residual concentrations of dioxin remained.

Saturday, Sept 8th: Dow’s contractor continued the installation of the site irrigation system.

Sunday, Sept 9th: No site activities conducted.

Monday, Sept 10th: Dow’s contractor continued the installation of the irrigation system. Surveyors collected GPS coordinates and elevations of the JK-1 Cut-1 area.

Tuesday, Sept 11th: Surveyors completed the survey activities of the JK-1 Cut-1 area. Dow has received and reviewed the laboratory analytical data from the post excavation activities.  Concentrations of furan and dioxin are at or near 10 ppt.  Dow contractors continued working on the installation of the rip rap on the south end of the JK-1 area.

Wednesday, Sept 12th: Dow’s contractor began Cut-2 within the JK-1 area.  The excavated soil will be used to cap impacted surface soils in the JK-2 area.  Installation of rip rap in the northern area of JK-1 began. The southern rip rap area has been completed.

The following tasks will be implemented:

•    The collection and laboratory analysis of post removal soil samples from the JK-1 and JK-2 (non-wooded area) prior to the installation of top soil.
•    Importing and installation of topsoil as part of the site restoration activities.
•    Planting of over 200 trees as part of the site restoration activities.

Awaiting comments from the Trustees on the Restoration Work Plan to finalize seed slection for ground cover.

As of 9/12/07, Dow has removed and transported to the landfill approximately 23,562 in-place cubic yards of impacted soil from the Reach JK site. Approximately 24,000 in-place cubic yards of impacted soil was the estimated total volume to be removed. The following disposed waste was excavated from the JK-1 Cut #1 area:

8/17/2007    30 loads    540 in-place cubic yards
8/18/2007    64 loads    1,152 in-place cubic yards
8/21/2007    76 loads    1,368 in-place cubic yards
8/22/2007    93 loads    1,674 in-place cubic yards
8/23/2007    60 loads    1,080 in-place cubic yards
8/24/2007    103 loads    1,854 in-place cubic yards
8/25/2007    20 loads    360 in-place cubic yards
8/27/2007    178 loads    3,204 in-place cubic yards
8/28/2007    148 loads    2,664 in-place cubic yards
8/29/2007    180 loads    3,240 in-place cubic yards
8/30/2007    199 loads    3,582 in-place cubic yards
8/31/2007    127 loads    2,286 in-place cubic yards
9/7/2007    31 loads    558 in-place cubic yards