quickly to reduce damage and stress to the organisms. and will be wrapped in foil, placed in plastic bags. and labeled for analysis. Because the levels of dioxin in the environment are so small, especially sensitive techniques have been developed for measuring it. The most common combines careful sample preparation with the use of gas chromatography and mass spectrometry. However, this technique is expensive; a single test of each sample costs about $l500. EPA is working to develop analytical methods which are more sensitive. more rapid, and less costly. How Long? The actual sampling takes very little time, but laboratory analysis may take as long as two to four months. EPA will notify property owners of the sampling results as soon as possible. In the Meantime.. EPA and other federal agencies have research underway to learn more about the extent of dioxin contamination and the risks of exposure. Because the movement and effects of dioxin in the environment are not fully understood at this point, EPA is acting conservatively on the basis of CUrrent data. The Agency is evaluating methods of disposing of or destroying contamined soils and wastes. Established technologies include incineration, chemical degradation. and biological treatment measures, but EPA is working to find other methods of disposal as well. One promising technique is to treat soil with a chemical compound and sunlight. This method holds promise for actually detoxifying the dioxin molecule. Some temporary methods to limit exposure include: excavating highly contaminated soil and removing it to a safe location: securing and capping the contaminated area; and using high efficiency vacuums and liquid dust suppressants. Because dioxin and other hazardous wastes generate intense public interest and concern, each of EPA's l0 regional offices has a dioxin information coordinator to answer your questions or provide the latest and most accurate information about dioxin studies in your community. Regional Community Involvement Contacts for Dioxin Debra Office of Public Affairs US. EPA Re ion 1 JFK Federal guilding Boston. MA 02203 Richard Cahill Office of Public Affairs U.S. EPA Region 2 26 Federal Plaza New York. NY Joe Donovan Office of Public Affairs US EPA Region 3 6th and Walnut Phila. PA l9 06 Hagan Thompson Office of Public Affairs US. EPA Region 4 345 Courtland St. NE Atlanta, GA 30308 Vanessa Musgrave Office of Public Affairs US. EPA Region 5 230 S. Dearborn Chicago. IL 60604 Betty'WilIiamSOn Office of Public Affairs US EPA Region 6 I201 Elm St. Dallas. TX 75270 Steven Wurtz Office of Public Affairs US. EPA Region 7 324 E. St. Kansas City. MO 64l06 Nola Cook Office of Public Affairs US EPA Region 8 Suite 900 l860 Lincoln St. Denver. CO 80295 Deanna Wieman Office of External Affairs US. EPA Region 9 215 Fremont St. San Francisco. CA 94l05 Bob Jacobson Office of Public Affairs US. EPA Region l0 1200 Sixth Ave. Seattle. WA 9810i (6l7) 223-4906 (2 2l 264~25l5 l2 5l 597-9370 (404) 88l?3004 l3l2] 886-6l28 l2l4l 7678986 (BIS) 374-5894 (303) 837-5927 l4 5l 974-8083 (206l 442?l203 Connecticut. Maine. Massachusetts. New Hampshire. Rhoda island. Vermont New Jersey, New York. Puerto Rico, Virgin Islands Delaware. Maryland. Virginia. West inia, District of Colum ia Alabama. Georgia. Florida, Mississippi. North Carolina. South Carolina, Tennessee. Kentucky illinOIs. Indiana. Ohio. Michigan. Minnesota Arkansas. Louisiana. Oklahoma. Texas. New MeXIco lowa. Kansas. Nebraska Colorado. Utah, Wyoming. Montana. North Dakota. South Dakota Arizona. California. Nevada. Hawaii. American Samoa. Guam Alaska. ldaho. Oregon. Washington Learning More About Dioxin In the past few years, you may have heard a lot about a substance called dioxin. Neither dioxin nor its associated problems are new. Questions about its effects have been raised since it first was in 1872, and many of those questions still need answers. Now new questions have been raised about dioxin. both as an environmental contaminant and a potential public health problem. The fact is that we still don't fully understand dioxin or how exposure to dioxin affects human health. We don't fully know how much dioxin is in the environment, or where it is. We aren't even sure how best to clean it up when we do find it. The only sure thing is that dioxin contamination has become an extremely complex and emotional issue. Because of concerns about dioxin, the United States Environmental Protection Agency (EPA) initiated a "national dioxin strategy? and will: 0 study the nature of dioxin contamination throughout the US. and the risks to people and the environment: a clean up dioxin?contaminated sites that threaten public health: 0 find ways to prevent future contamination; and 0. find ways to destroy or dispose of existing dioxin. As a first step, EPA will sample over 1,000 sites all over the country. These range from sites Where certain pesticides were produced and EPA "1081 expects to find dioxin. to places where EPA least expects to find dioxin. The places where EPA expects to find dioxin include private PropeI?W and citizens are being asked to cooperate in the study by allowing field teams to take small samples 01? soil from their propertY- This sampling is extremely important as it will help EPA to learn if there are "background" levels of dioxin in the environment. EPA has prepared this leaflet to explain this study more fully. What is Dioxin? The word dioxin is actually a generic term for a group of compounds known as dibenzo-p-dioxins but in popular use it usually refers to the most toxic and carefully studied of these compounds 2.3.7.8 tetra- chlorodibenzo-p-dioxin, or or simply TCDD. Whenever we discuss Dioxin in this leaflet. we are referring to 2.3.7.8-TCDD. Nobody produces dioxin on purpose. It is an unwanted but almost unavoidable by-product that comes from manufacturing several commercial substances, chiefly the pesticide 2,4,5 tri? chlorophenol. This pesticide is then used as a basic ingredient in the manufacture of several other pesticides. (Pesticide is a general term for chemical products used to destroy or control unwanted insects, plants, fungi, mites, rodents. bacteria, or other organisms). Where Does It Come From? TCDD enters the environment in several ways. For example, through dioxin- contaminated chemical products: as a component of the wastes that are produced in manufacturing these products: and through the widespread use of these contaminated products. Certain types of combustion are other possible sources of dioxin contamination. At What Level is Dioxin a Concern? In general, it is the potential for exposure, either through ingestion or contact with contaminated soil or through eating contaminated fish, that presents the greatest possibilities for health risks. The Centers for Disease Control (CDC) considers part per billion (ppb) of dioxin in soil to be a level of concern in residential areas. The Food and Drug Administration (FDA) recommends limiting consumption of fish with 25 parts per trillion (Opt) or greater of diOxin and not eating any fish with greater than 50 of dioxin. EPA, in conjunction with these other federal agencies and State and local health agencies, will alert you to any precautions you should take whenever dioxin is detected at levels that may adversely affect your health. These agencies will also decide what further actions are necessary. Why is EPA Concerned about Although scientists disagree on the long-term health effects of exposure to dioxin, tests on laboratory animals indicate that it is one of the most toxic man-made chemicals known. Because information on effects to humans has come mostly from accidental exposures, the data are not definitive. Scientists do agree, however, that exposure to TCDD can cause a persistent skin rash called chloracne, as experienced by some workers exposed to TCDD in the work place or through industrial accidents. Tests on laboratory animals also indicate that exposure may result in a rare form of cancer called soft tissue sarcoma, liver dysfunction, elevated blood cholesterol, nervousness, and other problems. How is EPA Studing In its study of dioxin. EPA will look at seven' categories, or ?tiers" of sites, ranging from those where no contamination is expected (Tier 7) to those sites most likely to be contaminated (Tiers ?l and 2). Tier 7 includes background sites where EPA does not expect to find dioxin. The purpose of sampling these sites is to determine whether dioxin contamination is widespread and, if so. at what levels. Tier 7 sampling consists of two phases. The first involves sampling soils from 300 urban and 200 rural locations across the country. Most of this sampling will take place on private property. No one whose property is selected is required to permit the sampling. Cooperation is encouraged but is strictly voluntary. The second phase involves sampling fish or shellfish taken from 420 locations, including streams throughout the US, waters of the Great Lakes, and estuarine and coastal waters. The sampling for this tier is a focus of EPA concern because dioxin in soil and in fish presents the greatest potential exposure to humans. Tiers 1 and 2 include facilities where pesticide products containing dioxin were manufactured or sites used to dispose of production wastes. EPA estimates that 80 percent of all dioxin contamination will be found in these two tiers. Sampling at these sites has already begun under EPA's Superfund program. Tier 3 includes facilities where pesticides that may be contaminated with dioxin were formulated and sites where these facilities disposed of their wastes. Tier 4 includes sources that may be emitting dioxin during the combustion process. Tier 5 includes sites where pesticides that may be contaminated with dioxin have been used or are being used. These include rice and sugar cane fields, rangelands, orchards, forest lands, rights of way, and possibly some wood products processing plants. Tier 6 includes facilities where improper quality controls during the production of certain chemicals and pesticides could have led to dioxin by-products. How Were Background Sites'Chosen? All 500 soil sampling sites in Tier 7 were randomly chosen by statistical methods from over l3,000 locations across the country. One hundred fish sampling sites, taken from the US. Geological Survey's National Stream Accounting Network (NASQAN), also were randomly selected. An additional 320 fish sampling sites were purposely chosen from locations of regional or national interest. These sites are of interest because they are near population centers or are in commercial or recreational fishing areas. Their selection does not mean that they are suspected of being contaminated by dioxin. How are-Samples Taken? Soil sampling is done very simply. From the middle of each site, field crews will take samples with a tulip bulb planter from a depth of about three inches. The sample is placed in a square mason jar, labeled, and sent to an EPA laboratory for analysis. Fish sampling is more complicated. At freshwater sites, crews will take samples both of bottom-feeding fish and' game fish; at coastal and estuarine sites, only mussels and oysters will be taken in most cases. Samples will be taken very FINAL COMMUNITY RELATIONS PLAN MIDLAND, MICHIGAN August 1984 07.5VG1.0 FINAL COMMUNIT RELATIONS PLAN STUDY OF DIOXIN AND THER TOXIC BOLLUTANTS MIDLAND MICHIGAN Augu 1984 i The Community Relations Plan (CRP) for the study of dioxia and other toxic pollutants in Michigan has been prepared in two sections. The first sect?'on contains the community re- lations assessment, which presents the site background and discusses the objectiVes and techniques of the Community Relations Plan. The second 5 ction outlines implementation activities, including a work plan, Staff allocation, budget and schedule. Primary responsibility for implementation of the CRP will rest with U.S. Region V. This Community Relations Pla is based upon information gained during a review of project files, discuSsions with Region personnel and onsite interviews. Interviews were held with a variety of local buSineSses, service organiza- tions, environmental groups, and elected officials. Table 1 lists the individuals who were interviewed for the prepara tion of this CRP. 1 COMMUNITY RELATIONS ASSESSMENT . COMMUNITY RELATIONS BACKGROUND - Over the past few years there have been several reports of diOXin found in fish from Michigan rivers. In June 1978, Dow Chemical Company reported!to the Michigan Department of Natural Resources that '2 3, 7, 8? was found in fish taken in 1976 from the Tittabawassee River of the Midland plant at levels ranging from 70- 230 parts per trillion (ppt). Various fish caught at Smith's Cressing ROad in 1977 had concentratio of 2, 3, 7 B-TCDD ranging from nondetectable to 170 ppt. Based on the information reported by Dow, the Michigan Department of Public Health (MDPH) immediately issued an adVisory against consuming fish caught in the Tittabawassee and Saginaw Rivers. The health i advisory is still in effect. 1 In addition, limited data published by Dow suggest that di- oxins are found in. soils in the City of Midland and outlying areas in the parts per trill?on range and somewhat higher within the Dow Chemical plant boundar.ies. Currently, not enough data are available to adequately assess whether the levels of dioxins reported by Dow represent typical levels of dioxin in Midland soils, or whether higher levels may be found in certain locations. EPA has developed a national strategy and is developing . national and regional field investigation plans for dioxins; I a The strategy and field programs will address broad issues such as the level and extent lf dioxin contamination nation? wide; the sources of_dioxin contamination- research; inter- agency issues concerning health effects# and intensive Studies at control sites and other locations where dioxin contamination is suspected. The U. S. EPA's nationwide strategy will include backgro nd sampling at several loca- tions throughout the country.ll As part of this effort, EPA is conducting a study 1n four midwestern locations including the City of Midland and the ow Chemical Company plant to determine whether or not dioxins and other toxic pollutants are present at levels of conc rn. Depending on the results obtained, more intensive inve tigations or remedial measures may be warranted. This CRP outlines the pub_lic participation activities that will occur during the above?outlined study for the Midland Michigan, area. COmmunity lations is a dynamic, ever- achanging_ precess. Therefore, this plan may require additions and changes to addr ss unforeseen conditions that may develop during the ooursq of the study. The U. S. EPA reserves the right to consider any and all suggeSted changes to this plan that equitably benefit the Community. Prior History of Federal/State-Activities The Michigan Department of Natural Resources first? became aware of the existence of dioxin contamination in Michigan i?n June 1978. At that time, Dow presented results of re? search studies on dioxins to the Department's staff. This information formed the basis for the MDPH health advisory referenced ab0ve. In October 1978, MDNR requested assistance from EPA to conduct in?plant sampling at the Dow facility. EPA and MDNR tested wastewater, river sedimentJ and treatment plant sediments. In 1979, EPA and the State 0 Michigan began review of an NPDES water diSCharge permit for the Dow-Midland plant. I Information on plant discharg was needed to develop a "best available technology analysis. EPA. issued an information request to Dow 0 January 20, 1981. Issues; surrounding the information request were reSolVed in the Spring of 1984. In September 1981, EPA and the State of Michigan conducted a caged fish study as part of a wastewater characterization .study at the Dow plant. Thelprocess wastewater effluent from the Dow plant was sampled and caged fish were placed in the Tittabawassee River in the plume of the discharge. The preliminary results from this _study were released in March 1983. These results describe the wastewater discharge from Dow Chemical's Midland plant of conventional pollutants, nonconventional pollutants, and toxics. addition, on i 1 Eforcement actions related to dioxin and furan pollution in 1 I 1+ March 1, Michigan State University released a graduate student's study which indicat that 2, 3, 7, 8- TCDD was widely distributed throughout southe lower Michigan rivers. This was the first report of poten ial widespread TCDD contamina? tion reported within the stat . On March 23, 1983, U. S. EPA eceived a request from the State of Michigan to begin rk on a study of the dioxin contamination in the Midland rea. Work began immediately to prepare a scope of work and budget package for such an effort. In September 1983, Congress appropriated funding for the National Di0xin Study. 'Final preparations for the Midland Study were complete? shortly thereafter. The Midland Study is part of the National Dioxin Study and is consistent with study efferts throughout the country. History of Community Relation: Activities On March 16,1983, a "Citizens Petition for an Investigation and Enforcement Action" was submitted to the U. S. Environ- mental Protection Agency by the Environmental Congress of Mid?Michigan (ECOMM) and the Foresight Society. Both of these groups are based in the central Michigan area. The petition requested that EPA begin investigations and en- central Michigan. The petition was submitted to EPA Head- quarters and was passed on to Region in early April. On April 18, 1983, ECOMM and the Foresight Society submitted a supplemental petition through the. Citizens' Clinic for Accountable Government of the Government Accountability Project, a group based in jWashington, D. C. This supplemental petition expanded on many of the issues included in the initial petit?on. The Administrator' 3 response to the Central Michigan Citizen' 5 Petition was issue on June 10,1983, and was reprinted in the Federal Register on July 25, 1983. The. response reviewed those actiVities which the EPA and the? State of Michigan were already undertaking to address the issues raised in the petitiontand outlined additional future activities which the agency proposed to undertake-. EPA conducted a meeting on June 10, 1983, in Midland, Michigan, to discuss the Administrator' 5 response to the petit1on. Approximately 70 people attended that meeting. ECOMM pre- sented a series of questionslat the ?eeting that were responded to in writing on August 9,1983. On August 10, 1983, EPA issued a draft study plan jointly With the State of Michigan ?01 public review and comment. The study plan included an 'bitial community relations schedule. A press release as issued announcing the availability of the study, co ies were made available at a 1 local information repository and ind-ividual copies were mailed to interested parties On August 12, 1983, public officials Were br_iefed on the content of. the draft studyi plan. A public meeting Was eld in Midland on August 1983, to discuss the draft an. Approximately 150 people attended the meeting, About '20 comments were rece1ved from the public. The _comments addressed several is ues including the need for and the scope of the study, anal tical leVels of detection, and possible effects on the Midl$nd area. After consideration of all comments received th ough September 21, numerousl 'revisions to the study plan ere made. A response summary was prepared and distributed bn September 26,1983, to about 500 people. A second public meeting was held on October 4, 1983, in Ingersoll Township 0 review responses to public comments and planned revisio to the soil study plan. About 190 people attended the meeting. An undated "Citizens' Participation Program for Central Michigan" was submitted by ECOMM in early September 1983. Since March 10, 1983, four Freedom of Information Act (FOIA) requests have been submitted on behalf of ECOMM and the Foresight Society. An FQIA request was also received from- the Midland Area Chamber of Commerce.. Responses to all FOIA requests have been completed.E Local p_ress coverage concern- ing the Midland Study and the activities of ECOMM has been substantial. National preSS coverage, through both newspapers and trade journalsL has also occurred. Community Relations Parti ipants The major participants foi Michigan Study have been the EPA, the State of MichigaJ, _Dow Chemical Company, the local Communities, the Congress ona1 delegation and two local en- Vironmental Organizations ?the Environmental Congress of Mid-Michigan (ECOMM) and he Foresight Society. A discusT sion of the role each of these groups has played and its: issues of concern are des ribrd below. 5 U. S. _Environmental Protection Agency. Since 1978, U. S. EPA Re_gion has assisted the _State of Michigan with sampling and wastewater permitting activities related to Dow Chemical ,Company' 5 Midland facility. 1Under the prOposed National Dioxin Strategy, EPA has lead responsibility for the conduct of the Michigan Study of Dioxin and Other Toxic Pollutants. \This study 18* an element of the Region's broader investigations of dioxin and other toxic,pollutants. The Centers for Disease COntrol (CDC) has assisted EPA in the design of the study. 1 1 State of Michigan. Three sta agencies have been involved in the ongoing study efforts in the Midland area: the Attorney General's Office (MAG) the Michigan Department of Natural Resources (MDNR), ani the Michigan Department ofi Public Health (MDPH). EPA be an work with the MDNR and the MDPH in April 1983, to prepare .a study plan for the Michigan study. In Ju-ne, Governor Blanchard assigned responsibility for coordinating the State' efforts to the Attorney Gen? 'eral' Office. Since that ti e, the Attorney General has been the primary contact fd Michigan. participation. William Cooper, the Chairman bf the Michigan Environmental Review"BOard (MERB), has also assisted the Attorney General's Office. The Michigan Department of Pu lic Health has been involved in the design of the soil sam ling study and discussion 0- health issues surrounding the Dow Chemical Plant. If study results indicate the potentia for health riSks, MDPH will assume a greater role in future site- related activities, as will CDC. City of Midland- The mayor, ?ity manager, and city attorney for Midland haVe all participated in .public meetings and discussions with EPA concerning the upcoming study. The City has also assisted EPA in setting up public meetings to discuss the study elements. During the public comment period on the_ study design, the City requested formal status during the course of the study. While EPA responded that _no formalized mechanism existed for such status, the agency is committed to provide the Citylwith full communications about the study through this Community Relations Plan. Other Local Government Units! The city of Saginaw has expressed interest in the study based on concern of movement of water contaminatiOn in the I Tittabawassee River. Several city council members have discussed their views with EPA and have participated in public meetings. Ingersoll and Williams ToWnships have also expressed inter? est in the upcoming study. Kurt Schaffner, the IngerSoll TownShip Supervisor, has been in contact with E-PA on several Occasions. While Ingersoll Township has been involved with Dow over past problems associated with brine spills, they do not anticipate an active roleiin this study. It was also suggested that Midland and Larkin Townships be regularly advised of study progress and findings- The Midland County Board Of Cdmmissioners has also expressed an interest in the study and has commented on draft study materials. Like the City of idland, the County has also requested. ongoing information. on study' progress. The Statement assessing the overall impact on public health, an county public health director, Dr. Winifred Oyen, has been the focal point for county involvement. Environmental Organizations. Two Michigan area environmental organizations have been heavily involved in! activities surrOunding the Do plant and the proposed study plan. These are the Environm ntal Congress of Mid-Michigan (ECOMM) and the Foresight Sobiety. ECOMM was organized around the specific issues absociated with the proposed study, while the Foresight Society was organized initially in 1982 to respond to a- discharge permit application pending for the Dow facility. The two groups have been represented in Washington, D. C., by the Government Account ability Project (GAP). On March 16, 1983, ECOMM and the Foresight Society filed a petition under TSCA requestin that EPA begin investigations and enforcemen-t actions related to pollution by toxic subm stances in central Michigan. In general, petitioners re- quested independent testing of contamination levels for all known and suspected pollutants and contaminants on Dow property and 'adjacent areas} an Environmental Impact epidemiological study on health problems in the central Michigan area,. and an eValuation of the danger of Contamination of drinking water aquifers. The Administrator's response to the petition was isSued on June 10, 1983. I In a "Citizens' Participation Program for Central Michigan" submitted by ECOMM, they expressed concern that citizen input into the study process had not been encouraged. The stated purpose of the ECOMM Citizen Participation Plan is to "improve Working relations between the environmental regulatory agencies and the petitioners, to establish a pro- tecol for the sharing of information and to ensure that the petitioners who requested the Full Field Investigation are included in the process." I A response to the proposed Citizen Participation Plan was included in the response to comments d_istributed by Region on September 26,1983, along with the revised soil study. Dow Chemical Company. Since the March announcement of previous dioxin study results, Dow has been invited to speak to over 60 groups throughout?Michigan to discuss past and upcoming studies. Dow has participated in the public meetings held by EPA and has met with both the State of Michigan and EPA. Dow has copperated with EPA in both the study design and sampling portions of the study. 'special appropriation of fu ds for the National Dioxin ?study activities. sanswer as soon as possible. I I I Congressional Delegation. ngressmen Albosta and Traxler have shown substantial inter st in the Midland question., They have participated in th public and small group meetings. Congressmen Albosta and Traxler were both instrumental in achieving Cohgressional approval cf the Study. Congressman AlboSta as organized meetings between EPA, the State of Michigan, nd local officials to discuss Community Relations Issues Numerous interviews were cond cted with local officials and area residents to determine he public issues surrounding the Michigan study. The fol owing summary of issues is based on the information gain from those discussions. As a result of interviews co ducted, it appears that the general public in Midland is not concerned about potential contamination, but many are ihterested in the outcome of the study. Midland residents be Ilieve that they live in a healthy environment and do net believe that they have been expOSed to unuSual health risks because of Dow's activities. Dow is widely accepted as a good corporate neighbor and a reSpOnsible, highly professional member of the community. Dow' 5 scientific expertise isihighly regarded and they have a credible public image in the local area. While most peOple are not individually concerned about health risks from potential cOntaminatiOn, now that the question has been raised they want a credible?, scientifically defensible Residents and members of the business community are con- cerned about the damage thebeelieve has been done to Midm land's public image. They have an intense pride in their community and believe tha-t media coverage or the study is ?creating the wrong impression of the area. They are fearful Ehat the study results will raise additiOnal questions and are hoping for an early resolution of the questions that: have been raised. Most individuals. interviewed during the preparation of this CRP indicated that they do not believe that a problem exists. HOwever, if toxic pollution problems are found, they want the problem addressed, solved and laid to rest. The general community is very well informed on the issues surrounding the study. Many citizens have technical back? grounds and are thus able to provide meaningful comment on technical aSpects of the studies. Numerous service clubs ?have sponsored programs to inform their members and the general level of public underFtanding i-s high. People are very interested in the technical issues and are conversant I I 'u I I ?warrants their active participation in the study process. in the issues surrounding testing levels part per 'trillion versus-part per billion, sampling protocol, etc. Some people interviewed expressed a concern that Midland has been singled out.and have re uested Comparative study re- sults that will show how ranks against other similar communities. Some residents have also requested a health risk analysis that will allo evaluation of the study re4 sults against health information so that the public health risk, if any, can be determinid. According to interviews, the members of ECOMM seem to represent a small number of residents of the Midland area. They have committed a substantial amOunt of personal time to research issues surrounding he Dow facility and believel that they have collected tech ical information that suggests a high level of tox1c contamrnation.- They believe that EPA and the State of Michigan have been slow to act and that substantial further investigaFion is required. ECOMM wants to educate the Midland publi about the potential health risks in the community and work with state and federal agencies to resolve the existing health problems ECOMM has identified. ECOMM believes that the research they have done on the issue They would like to serve asla formal participant and/or observer in important project meetings between EPA, the State of Michigan, and Dow. At a minimum, they believe that minutes of all project meetings should be provided to them. ECOMM members believe they Iare committed to a clean environment and want a partnership relationship with EPA. They believe that their recent efforts have provided good, investigative reSearch for EPA and that they would like to be reimbursed for their efforts. In summary, the City of Midland has been significantly im- pacted by the events during and following March 1983. While most local residents are not Eearful for their health, they do want the queStion of potential contamination in Midland laid to rest. They want a credible, defensible research study that will clear the air and allow them to move on to other matters. . COMMUNITY RELATIONS AND TECHNIQUES This community relations plan?focuses on effective, two-way communication between interested citizens, local officials, and the EPA. It is EPA's intent to provide an Opportunity for the public to participate in the study through review and comment on project docume ts. EPA also intends to pro? Vide significant information the public through. access to study results, public meetin and -project progress re- ports. Although EPA will ma every attempt to adhere to all project schedules, the pr vision of scientifically cor- rect information will be the ajor goal of the study effort. If project deadlines must -be lipped to ensure high quality results, the public will be tified in adVance. Community Relations Objectives 0 Establish open, effective, two-way communicatior: .among residents, interested parties, and the EPA and State of Michigan project team. 0 Allow. equal public access to all project infermation and participation in study activities. 0 Establish an effect?ve means of sharing technical among -he project team, residents, interested parties elected officials, and participating agencies including the City of Midland, County of Midland, Ingersoll Township, Williams Township, COMM, the Foresight Society, and any other identified groups. 0 Provide a central information source for interested parties and local officials to receive information on sitelactivities and study resultsJ 1 0 Provide all interested parties and media with accurate, timely information regarding the objectives, progress, and findings of the study. I ProVide summaries of technical study results in a form that is usefufl to residents, interested parties, and elected officials. ProVide an opportunity to review all study results and to comment on any specific recommendations that result from study activities. In general, a 21?day comment period (minimum) on any I recommendatiOns for further action will be :provided. Two-week advance notice of the public comment period will be provided as appropriate. 0- Identify interested. citizens in the City of Midland, and Ingersoll and Williams Townships and surrounding areas who ?wish to be routinely informed of study activities and results. 0 Remain sensitive td conununity concerns as the study progreSses. i ?clearinghouse to ensure that local concerns are addressed COmmunity Relations Techniques I The techniques listed below a _e suggested methods for meet- ing the commUnity relations 0 jectives. The recOmmendation of these techniques is based on the particular concerns of those.involVed with the Midla site. These techniques-reL sulted from review of Hater'als submitted by interested groups and discussions with Region project and public affairs staff. Central Information Contacts. EPA will establish a central information contact who inte ested parties can call for information. Technical quest'ons will be referred to Gary Amendola of the Eastern Dist ict Office, while other types of information will be provided by Vanessa Musgrave, Office of Public Affairs. The central contacts will serve as a and that requested informati is provided. Coordination with local officials and participating agencies will be necessary to assure that consistent informa-tion is provide to all interested residents, press, and agencies. Local Repositories. Local information repositories will be set up at the City of Midland Library, the Midland County Health Department, and the Township office (Table 2). A complete docket of project technical materials, reports, correspondence, comments, and reSponses to comments will be established and maintained at each site. These repositories will allowlresidents and local officials access to all project materials. Progress Reports and Briefings. Brief progress reports will be prepared approximately every three months to update information on upcoming activities, study results, meetings, schedule changes and other items of interest. These progress reports will be distributed to elected officials' an_d interested parties and will also -be available at the information repositories. Formal briefings will be cenducted with the City of Midland, the Midland County Board ?Of COmmissioners, Midland County Health Department, Inger? soll Township, Congressional[delegation, ECOMM and Dow. These individual briefings will provide a review of past and upcoming activities. Study Result Briefings. Prior to release of study results, EPA.?will. brief ?the Congressional delegation, property owners, State of Michigan officials, the City of Midland, Midland County Board of C0mmi$sion_ers, Midland County Health Department, Ingersoll Townsh1p, ECOMM and Dow. These ?briefings will be hel_d prior to the scheduled public meetings and will precede re?ease of the study results to: the press. Briefings will be scheduled in advance to ensure I r10 full participation by interested officials. CDC involvement will be scheduled as appropriate. I Public Comment on Study Plaxl Elements. The Community Relations Plan and study plans will be available for public review and comment prior to implementation. Public comment on both the substantive and precedural elements of these plans will be solicited. 21-Day Public COmment Period A 21?day public comment period has been provided for. review of the Community Relations Plan and study plan. At this time, EPA does not anticipate the recommendation of specific remedial actionsL If, however, it becomes clear that remedial actions are I warranted, a 30? ?day public co ent period will be provided before work is undertaken. Public Summaries of Technica Results. To provide local officials, interested parties? and residents with a clear understanding of the technic 1 infOrmation resulting from study activities, public summaries will be prepared to de- scribe the sampling results and study conclusions. These Summaries will be incorporated in progress reports and community meetings. These public summaries will be designed to .be clear, accurate descriptions of study results and pre? pared in a style and format at encourages public use and understanding. Comment Process for Draft Community Relations Plan. The draft Community Relations Plan was submitted to interested officials and groups for a 30-day review. Comments on the draft plan were accepted by mail. Based on comments received, a final Community Relations Plan was prepared and distributed. All individuals who submitted comments reCeived a letter outlining the response to their comments. Public Meetings. Public meetings may be held to review the study plans and the composite}s tudy findings.- A tentative schedule of public meetings is included in Section 2 of this Community Relations Plan. Meetings will be held in the City of Midland. Notice of upcoming meetings will be provided through preSs releases two weeks in advance, the quarterly progress reports, and speciallmeeting notices in newspapers of local distribution, if appropriate. Press Releases. Press releases will be issued at -appr0priate times throughout the study: To announce the staot?up of field activities To announce specific sampling results To announce upcomin public meetings To announce -the ava '1ability of'the final study' results. 0 0.0 .11 ?Press briefings will accompam I I 4 press releases when signifi- can?t issues are concerned or when highly technical data are presented. provided to local officials delegation. Press Briefings. A briefing held one to two days prior to Copies of the press releases will also be and the Congressional for the local press will be the release of specific study results (subsequent to briefings of public officials). The purpose of the briefing will data interpretation, sampling effects_ana1ysis and related formation will-provide a back so that the local press.is study results. Fact sheets LoCal Presentations. scheduled trips to Midland as COMMUNITY RELATIONS WORK PLAN Meeting A: ill also be provided. PreSentations to 10ca1 service groups and other interested organizations will be coordinated with be to provide information on and testing processes, health technical isSues. This in? ground on the technical issues etter prepared to report the time is available. The schedule outlined below i receipt of laboratory resultsL will be communicated to the major participants. ACTIVITY DESCRIPTION Community Meetings Octobe-r- 1' tentative and dependent upon Significant schedule changes 983. To discuss response tq public comments, soil sampling plan, and project schedule. Meeting B: Late Fal? 1984. results to date, (Held October 4.) 'To discuss sampling remainder of study' 'activities, and schedule. Meeting C: Early 198 5. To discuss study results and future recommendations, if any. . Press=Releases/Advisories Press Release A: September - I l1983- Issued September 13 to announce October 4 public meeting. Press Release B: October 19 83. To announce start-up of project activities- Press Release C: of draft relations comment. ,February 1984. To announce aVailability study elements and community plan for public review andI _12 PreSs Release D: Press Release E: Other press releases and/or advisories will be issued as appropriate throughout the study process. Progress Reports Progress Report A: Progress Report B: Progress Report C: Progress Report D: Public Summaries of Summary A: Summary B: Summary C: Information Briefings Briefings for local Late Fal 1984. To announce sediment and waste ater sampling results. To an- nounce blic Meeting B. To announce sampling results from waste systems, wells, 1 achate and air samples. soil sampling results and CDC and Michi gam Departmen of Public Health evaluation Early 1988. To announce availability of final study results and Public Meet- ing C. March 1984 August 1984 November 1984 March 1985 Technica1_Materia1 June/Julyl 1984. To describe? soil sampling results.and CDC MDPH findings. . October 1984. ?To describe sediment and .wastewater sampling results. To describe sampling results from waste systems, wells, leachate, and air samples. Spring 1985. To describe the final study results. officials and interested groups will be held approximately every four months. Briefing A: Briefing B: Briefing C: Briefing D: January 1984 March 1984 October/November 1984 January/February 1985 Response to Media and Citizen:Inquiries . 3 . . . . . Ongoing: RespOnd to questions and inquiries from media and concerned citizens. i 13 Other Activities Information February E984. Establish repositories repository: at City of Midland library, Midland County Health Department, and Ingersoll Township Office. Mailing list} September 1983. Prepare project mailing list. Update as appropriate. Talle INDIVIDUALS INFERVIEWED DURING COMMUNITY RELATIONS PLAN Mr. Ned S. Arbury 10 Snowfield Midland, Michigan 48640 Dow Chemical Company Michigan Division 47 Building Midland, Michigan 48640 Contacts: Ms. Sarah Rowley Mr. Vern May Ms. Sue Dupree Mr. Michael Rio Environmental Congress of Mid?Michigan 2505 East Sugnet Court Midland, Michigan 48640 Contacts: Ms; Diane Hebert Ms. Andrea Wilson Mr. Vincent Castellanos City of Midland City Hall 202 Ashman Street Midland, Michigan 4864q I Contacts: Mr. Joseph Mann, Mayor Mr. ClifflMiles, City Manager Mr. John Rae, City Attorney Midland County Board of Commissioners Courthouse Midland, Michigan 48640 Contacts: Mr. Scott McDonald, Chairman Ms. Laura:Brandes Ms. Mary Miller Midland County Health Debartment 125 West Main Street I Midland, Michigan 48640 Contact: Dr. Winifred Oyen, Director Ta le 1 INDIVIDUALS DURING COMMUNITY ELATIONS PLAN (Continued) 7. Mr. Curtis R. Shaffner, Ingersoll Township Supervisor 4400 Brooks Road, Rt. #10 Midland, Michigan 48640 8. Major Warren Yoder, Salvation Army 1517 Bayliss Midland, Michigan 48640 Ta le 2 MIDLAND INFORMATION Grace A. Dow Memorial Public 1710 W. St. Andrews Midland, Michigan 48640 (517) 835-7151 - Gale Burkhart, Supevisor of R-ferences Rosemary Byers, Director ibrary Midland County Health Department 125 W. Main Street Midland, Michigan 48640 (517) 832-6689 Dr. Winifred Oyen, Director Ingersoll Township 4400 E. Brooks Road Midland, Michigan 48640 (517) 835-5289 Curtis R. Shaffner, Supervisor i 1 i FINAL OMMUNITY RELATIONS PLAN MIDLAND, MICHIGAN August 1984 07.5VG1.0 FINAL COMMUNITY RELATIONS PLAN STUDY OF DIOXIN AND OTHER TOXIC POLLUTANTS MIDLAND, MICHIGAN August 1984 The Community Relations Plan (CRP) for the study of dioxin and other toxic pollutants in Michigan has been prepared in two sections. The first section contains the community re- lations assessment, which presents the site background and discusses the objectives and techniques of the Community Relations Plan. The second section outlines implementation activities, including a work plan, staff allocation, budget and schedule. Primary responsibility for implementation of the CRP will rest with U.S. EPA, Region V. This Community Relations Plan is based upon information gained during a review of project files, discussions with Region personnel and onsite interviews. Interviews were held with a variety of local businesses, service organiza- tions, environmental groups, and elected officials. Table 1 lists the individuals who were interviewed for the prepara- tion of this CRP. COMMUNITY RELATIONS ASSESSMENT COMMUNITY RELATIONS BACKGROUND Over the past few years there have been several reports of dioxin found in fish from Michigan rivers. In June 1978, Dow Chemical Company reported to the Michigan Department of Natural Resources (MDNR) that was found in fish taken in 1976 from the Tittabawassee River of the Midland plant at levels ranging from 70-230 parts per trillion (ppt). Various fish caught at Smith's Crossing Road in 1977 had concentrations of 2,3,7 ranging from nondetectable to 170 ppt. Based on the information reported by Dow, the Michigan Department of Public Health (MDPH) immediately issued an advisory against consuming fish caught in the Tittabawassee and Saginaw Rivers. The health advisory is still in effect. In addition, limited data published by Dow suggest that di? oxins are found in soils in the City of Midland and outlying areas in the parts per trillion range and somewhat higher within the Dow Chemical plant boundaries. Currently, not enough data are available to adequately assess whether the levels of dioxins reported by Dow represent typical levels of dioxin in Midland soils, or whether higher levels may be found in certain locations. EPA has developed a national strategy and is developing national and regional field investigation plans for dioxins. i The strategy-and field progr ms will address broad issues such as the level and extent-_f dioxin contamination nation? wide; the sources of dioxin ontaminatiOnu research; inter- ,agency issues concerning he 1th effe?ts: and intensive I studies at control_sites and other locations where dioxin contamination is suspected. The U. nationwide strategy will include background sampling at several loca? tiOns throughout the country. As part of this effort. EPA is conducting a study in four midwestern locations including the City of Midland and the _ow Chemical Company plant to determine whether or not dioxins and -other toxic pollutants are present at levels of concern. Depending on the results obtained, more intensive inve tigations or remedial measures may be warranted. This CRP outlines the public participation activities that will occur during the above-o tlined study for the Midland Michigan, area. Community relatiOns is a dynamic, ever- -Changing process. Therefore, this plan may require additions and changes to address unfOreseen conditions that may develop during the courSe of the study. The U. S. EPA reserves the right to consider any and all suggested changes to this plan that equitab'ly benefit the community. Prior History of Federal/State Activities The Michigan Department of Natural Resources first became aware of the existence of dioxin contamination in Michigan in June 1978. At that time, Dow presented results of reo? search studies on dioxins to 'the Department's staff. This information formed the basis?for the MDPH health advisory referenced above. In October 1978, MDNR requested assistance from EPA to conduct in-plant sampling at the Dow facility. EPA and MDNR tested wastewater, river sedimentL and treatment plant sedimentsL In 1979, EPA and the State of Michigan began review of an NPDES water discharge permitlfor the Dow-Midland plant. Information on plant discharge was needed to develop a "best ava_ilable technology 1analysis. EPA. issued. an information requeSt to Dow on January 20. 1981. Issues. surrounding the information request were resolved in the' Spring of 1984. In September 1981, EPA and the State of Michigan conducted a caged fish study as part of a wastewater characterization study at the Dow plant. Th? process wastewater effluent from the Dow plant was sampled and caged fish were placed in the TittabawaSsee River in the plume of the discharge. The preliminary results from this study were released in March 1983. These results describe the wastewater discharge from Dow Chemical' 5 Midland plant of conventi'onal pollutants,, nonconventional pollutants. and toxics. -In addition, on 1 1. .r 1 ?H?g upetition requested that EPA begin investigations and en? 'forcement actions related to dioxin and furan pollution in supplemental petition expanded on many of the issues I I I March 1, Michigan State University released a graduate student' 5 study which indicated that 2, 3, 7, 8? TCDD was widely d-istributed throughout southern lower MiChigan rivers'. This was the first report of potential wideSpread TCDD contamina- tiOn reported within the stat On March 23, 1983, U.S. EPA received a request from the 'State of Michigan to begin rk on a study of the dioxin cOntamination in the Midland area. work began immediately to prepare a scope of work and budget package for such an effort. In September 1983, Iongress appropriated funding for the National Dioxin Studl. Final preparations for the Midland Study were complete shortly thereafter. The Midland Study is part of the National Dioxin Study and is consistent with study efforts throughout the country. History of Community Relations Activities On March 16, 1983, a ?Citizens Petition for a-n Investigation and Enforcement Action" was submitted to the U. S. EnvironT mental Protection AgenCy by the Environmental Congress of; Mid-Michigan (ECOMM) and the Foresight Society. Both ofl these groups are based in the central Michigan area. The central Michigan. The petition was Submitted to EPA Headi quarters and was passed on to Region in early April. On April 18, 1983, ECOMM and the Foresight Society submitted a supplemental petition through the _Citizens' Clinic for Accountable Government of the Government Accountability Project, a group based in {Washington, D. C. This included in the initial petition. The ?Administrator' 5 responsei to the Central Michigan Citizen's Petition was issued on June 10, 1983, and was- reprinted in the Federal Register on July 25, 1983. The. response reviewed _those activities WhiCh the EPA and theI State of Michigan were already undertaking to address theI issues raised in the petition]and outlined additional future activities which the agency proposed to undertake. EPA conducted a meeting on June 10, 1983, in Midland, Michigan, to discuss the.Administrator's responSe to the petition._ ?Approximately 70 people attended that meeting. ECOMM pre4 sented a series of questions} at the meeting that were reSponded to in writing on August 9, 1983. On August 10, 1983, EPA issued a draft study plan jointly with the State of Michigan for public reView and comment. The study plan included an initial community relations schedule. A press release was issued announcing the availability of the study, co 1es were made available at a to 'Michigan" was submitted by ECOMM in early September 1983. 1 local information repository and individual copies were mailed to interested parties On August 12,1983, public Officials were briefed on the content of. the draft study plan. A public meeting Was held i?n Midland on August 18, 1983, to discuss the draft plan. Approximately 150 people attended the meeting. . I About '70 comments were rece1ved from the public. The I comments addressed several 1siues including the need for and the scope of the study, anal tical levels of detection, and possible effects on the Midl nd area. After consideration of all comments received through September 21, numerous! 'revisions to the study plan were made. A re5ponse summary was prepared and distributed September 26, 1983, to about 500 people. A second public meeting was held on OctOber 4, 1983, in Ingersoll Township 0 review resPonses to public comments and planned revisions to the soil study plan. About 190 people attended the meeting. An undated "Citizens' Participation Program for Central I Since March 10, 1983, four Freedom of Information Act (FOIA) requests have been Submitted on behalf of ECOMM and the Foresight Society. An FOIA 1equest was also received from the Mid1_and Area Chamber of Commerce. Responses to all FOIA requests have been completed. Local press coverage concern? ing the Midland Study and the activities of ECOMM has been- substantial. National press coverage, through both neWSpapers and trade jOurnalsL has also occurred. Community RelatiOns Participants The major participants for the Michigan Study have been the the State of Michigan, Dow Chemical Company, the local communities, the Congressiona?_ delegation and two local en? vironmental Env1ronmental Congress of Mid?Michigan (ECOMM) and theWForesight Society. A discus? sion of the role each of these groups has played and its issues of concern are described below. U. S. Environmental Protection Agency. Since 1978, U. S. EPA Region has assisted the State of Michigan with sampling and Wastewater permitting act vities related to Dow Chemical Company' 5 Midland facility. [Under the proposed National Dioxin Strategy, EPA has lead re3ponsibility for the conduct of the Michigan Study of Dioxin and Other Toxic Pollutants. This study is an element of the Region's broader investigations of dioxin andlother toxiC pollutants. The Centers for Disease Control (CDC) has assisted EPA in the design of the study. I I An. .4. I State of MiChigan- Three st te agencies have been involved in the ongoing study efforts in the Midland area: the Attorney General's Office G) the Michigan Department of Natural Resources (MDNR), an the Michigan Department of Public Health (MDPH). EPA began work with the MDNR and the MDPH in April 1983, to preparb a study plan for the Michigan study. In June, G0vernor aSsi_gned responsibility for coordinating the Sta-te' efforts to the Attorney Gen-i eral' 5 Office. Since that time, the Attorney General has been the primary contact fjr' Midhigan. participation. William Cooper, the Chairman of. the Michigan Environmental Reviewr Board. (MERE), has a so assisted the .Attorney General's Office. The Michigan Department of Public Health has been involved in the_ design of the soil sampling study and discussion of health issues surrounding th1 Dow Chemical Plant. If study results indicate the potenti for health risks, MDPH will assume a greater role in fut re site-related activities, as will CDC. City of Midland. The mayor, pity manager, and city attorney for Midland have all participated in public meetings and' discussions with EPA concerning the upcoming study. The City has also assisted EPA im s_etting up public meetings t-o discuss the study elements. During the .public comment period on the study design, City requested formal status during the course of the study. While EPA responded that no formalized mechanism existed for such status, the agency ?s Committed to provide the City' with full communications about the study through this Commun1ty Relations Plan. I . The city of Saginaw has expressed interest in the study based on concern of movement of water contamination in the ?Tittabawassee RiVer. Several city council members have discussed their views with EPA and -have participated in: public meetings. Ingersoll and Williams Townships have also expressed inter est in the upcoming study. Kurt Schaffner, the Ingersol? Township Supervisor, has been'in contact with EPA on several occasiOns. While Ingersoll Township has been involved with Dow over past problems associated with brine spills, they do not anticipate an active role in this study. It was also suggested that Midland and Larkin Townships be regularly advised of study progress and findings. The Midland County Board of Commissioners has also expressed an interest in the study and:has commented on draft study materials. Like the City oflMidland, the County has also requested. ongoing information. on study' progress. The county public health director, Dr. Winifrtd Oyen, has been the focal point for county involvement. 5 Environmental Organizations. Two Michigan area environmental organizations have been heavily involved in: activities surrounding the Dow plant and the proposed study plan. These are the Environmental Congress of Mid-Michigan (ECOMM) and the Foresight Sobiety. ECOMM Was organized around the specific isSues associated with the proposed study, while the Foresight Society was organized initially in 1982 to respond -to a discharge permit application pending fOr the Dow facility. The?f twO groups have been represented in Washington,D . ., by the 60vernment Account ability Project (GAP). On March 16, 1983, ECOMM and the Foresight Society filed a petition under TSCA requesting that EPA begin investigations and enforcement actions related to pollution by toxic sub" s-tances in central Michigan. In general, petitioners re- quested independent testing of contamination levels for all known and suspected pollutants and contaminants on Dow property' and adjacent areas, an Environmental Impact I Statement assessing the overall impact on public health, an epidemiological study on hea1th problems in the central Michigan area, and. an evaluation of ?the danger of contamination of drinking water aquifers. The Administrator' response to the petition was issued on June 10, 1983. In a "Citizens' Participatioanrogram for Central Michigan" submitted by ECOMM, they expressed cOncern that citizen input into the study process had not been enCOuraged. The st-ated purpose of the ECOMM Citizen Participation Plan is to "improve working relations between the environmental regulatory agencies and the petitioners, to establish a pro? tocol for the sharing of information and to ensure that the petitioners who requested the' Full Field Investigation are included in the process." A response to the prOposed Citizen Participation Plan was included in the response to comments distributed by Region .V on September 26,1983, along with the revised soil study. Dow Chemical Company. Since the March announcement of previous dioxin study results, Dow has been invited to speak to oVer 60 groups throughout!Michigan to discuss past and upcoming studies. Dow has participated in the public meetings held by EPA and has met with both the State of Michigan and EPA. Dow has cooperated with EPA in both the study design and sampling pdrtions of theistudy. I Congressional Delegation. angressmen Albosta and Traxler "have shown subStantial interest 1n the Midland question. They have participated 1n th public and small group meetings. Congressmen .Albogla and Traxler ?were both . instrumental in achieving ngressional approval of the: Special appropriation of fuxids for the National Dioxin Study. Congressman Albosta has Organized meetings between EPA, the State of Michigan, end local Officials to discuss study activities. Community Relations Issues 'responsible, highly professional member of the community._ Numerous interviews were conducted with local officials and area residents to determine the public issues surrounding the Michigan study. The foldowing summary of issues is, based on the information gained from those discussions. As a result of_ interviews conducted, it appears that the general public in Midland. is not concerned about potential contamination, but many are interested in the outcome of the study. Midland residents bqlieve that they live in a.1 healthy environment and do not belieVe that they have been exposed to unusual health risks because of Dow' 5 activities. Dow is widely accepted as a good corporate neighbor and Dow' 3 scientific expertise islhighly regarded and they have a credible public image in the local area. While most pebple are not individually concerned about health risks from potential contamination, new that the question has been raised they want a credible, scientifically defensible answer as soon as possible. Residents and members of thelbusiness community are con? c_erned about the damage they believe has been done to Mid- land's public image. They have an intense pride in thei? community and believe that media coverage of the study is' creating the wrong impressionQOf the area. They are fearful that the study results will raise additional questions and are hoping fer an early resolution of the questions thatl have been raised. Most individuals interviewed during the preparatiOn of this CRP indicated that they do not believe that a problem exists. However, if toxic pollution problems are found, they want the problem addressed, solved and laid to rest. The general community is very well informed on the issues surrounding the study. Many'citizens have technical back? grounds and are thus able to,provide meaningful comment on technical asPects of the studies. NumerOus service clubs have sponsored programs to inform their members and the general level of public understanding. is high. People are very interested in the technihal issues and are conversant ?environment and want a partnership relationship with EPA. in the issues surrounding testing leveld part per trillion versus part per billion, sampling protocol, etc.). Some people interviewed expressed a concern that Midland has been singled out and have requested comparative study ruef sults that will show how Midland ranks against other similar communities. Some residents have also requested a health risk analysis that will_ allo evaluation of the study re- sults against health information so that the public health risk, if any, can be determiifd. I According to interviews, th1 members of ECOMM seem to represent a small number cf esidents of the Midland area. They have committed a substa ial amount of personal time to research issues surrounding the Dow facility and believd that they have collected technical information that suggests a high level of toxic contamination. They believe that A and the State of Michigan .haye been slow to act and that substantial further investigation is required. ECOMM wants to educate the Midland public about the potential health' risks in the community and work with state and federal agencies to resolve the eXisting health problems ECOMM has identified. ECOMM believes that the research they have done on the issue warrants their active participation in the study processJ They would like to serve asIa fermal participant and/or observer in important pro-ject meetings between EPA, the State of Michigan, and Dow. At a minimum, they believe that minutes of all project meetings should be provided to themL ECOMM members believe they are committed to a clean They believe that their recent efforts have provided good, investigative researCh for EPA and that they would like to be reimbursed for their efforts. In summary, the City of Midland has been significantly im- pacted by the events during and follOwing March 1983. While most local residents are notlfearful for their health, they do want the question of potential contamination in Midland laid to rest. They want a credible, defensible research study that will clear the air and allow them to move on to other matters. COMMUNITY RELATIONS OBJECTIVES AND TECHNIQUES This community relations plan .focuses on effective, two?way communicatiOn between interested citizensL local officials, and the EPA. It is intent to provide an opportunity for the public to participate in the study through review and comment On project documehts. EPA also intends to pro- vide significant information to the public through access to I I I Study results, public meetin's, -and project progress re- ports. Although EPA will ma eVery attempt to adhere to. all project Schedules, the pr vision of scientifically cor- rect information will be the major goal of the study effort. If projeCt deadlines must be lipped to ensure high quality results, the public will be tified in adVance. Community Relations ObjectiVe! I 0 Establish Open, ef?sctive, two-way communication among residents, in erested_parties, and the EPA and State of Michigan project team. 0 Allow equal publi access to all project information and par icipation in study activities. 0 Establish an effective means of sharing technical information among the project team, residents, interested partiesf elected officials, and .participating' agencies including' the City? of ?Midland, County ofIMidland, Ingersoll Township, Williams Township, ICOMM, the .Foresight Society, and any other identified groups. 0 Provide a central' informatiOn source for interested parties and local officials to receive information on site activities and study resultsJ c: Provide all interested parties and media with accurate, timely information regarding the objectives, progress, and findings of the study. 0 Provide summaries of technical study results in a form that is usefuIl to residents, interested parties, and elected officials. I 0 Provide an oppOrtunity to review all study results and to comment on any specific recommendationsI that result from study activities. In general, a 21-day comment period (minimum) on any recommendations for further action will be . provided. Two-week advance notice of the .public comment period willIbe provided as appropriate. I. 0 Identify interested: citizens in the City of Midland, and Ingersoll and Williams Townships and surrOunding areas who 'wish to be routinely informed of study activities and resu1ts. I Remain sensitive to community concerns as the study progresses. Community Relations_Techniques The techniques listed below are suggested methods for meet? ing the community relations otjectives. The recommendation of these techniques is based on the particular concerns of 'those involved with the Midla site. These techniques rd? sulted from review of Heter' als submitted by interestedi groups and discussions with egion project and publiCI affairs staff. Central Information Contacts. EPA will establish a central information contact who inte ested parties can call for information. .Technical quest' ons will be referred to Gary Amendola of the Eastern Dist ict Office, while Other types of information will be provided by Vanessa Musgrave, Office of Public Affairs. The cent a1 contacts will serve as a clearinghouse to ensure that local concerns are addressed and that requested informa-tion is prOvided. Coordination with local officials and participating agencies will be necesSary to assure that consistent information is provided to all interested residents, press, and agencies. 1 Local Repositories. Local information repdsitories will be set up at the City of Midland Library, the Midland County Health .Department, ?and the Ingersoll Township. office (Table 2). A complete docket of project technical ,materials, reports, correspondence, comments, and responses to comments will be established and maintained at each site. These repositories will a11bw residents and local officials access to all project materials. Progress Reports and Briefings. Brief progress reports will be prepared approximately every three months to update information on upcoming activ1ties, study reSults_, meetings, ?schedule changes and other items of. interest. These progress reports will be distributed to elected officials' and interested parties and w111 also be available at the information repositories. Formal briefings will be cOnducted with the City of Midland, the Midland County Board .of Commissioners, Midland County Health Department, Inger? soll Township, Congressiona 1 delegation, ECOMM .and Dow. These individual briefings will provide a review of past and upcOming activities. - Study Result Briefings. Prio1 to release of study results, EPA will brief the Congressional delegation, property owners, State Of Michigan- officials, the City of Midland, Midland Cohnty Board of CommiSsioners, Midland County Health Department, Ingersoll Township, ECOMM and Dow. These briefings will be held prio1 to the scheduled public meetings and will precede release of the?study results to} the press. Briefings will be scheduled inladvance to ensure 10 full participation by interested officials. CDC involvement will be scheduled as appropriate. Public Comment on Study Plan Elements. The Community Relations Plan and study plans will?be available for public review and comment prior to implementation. Public comment on both the substantive and procedural elements of these plans will be solicited. 21?Day Public Comment Period. A 21-day public comment period has been provided review of the Community Relations Plan and study plans. At this time, EPA does not anticipate the recommendation of specific remedial actions. If, however, it becomes clear that remedial actions are warranted, a 30?day public comment period will be provided before work is undertaken. Public Summaries of Technical Results. To provide local officials, interested parties, and residents with a clear understanding of the technical information resulting from study activities, public summaries will be prepared to de- scribe the sampling results and study conclusions. These summaries will be incorporated in progress reports and community meetings. These public summaries will be designed to be clear, accurate descriptions of study results and pre? pared in a style and format that encourages public use and understanding. Comment Process for Draft Community Relations Plan. The draft Community Relations Plan was submitted to interested officials and groups for a 30-day review. Comments on the draft plan were accepted by mail. Based on received, a final Community Relations Plan was prepared and distributed. All individuals who submitted comments received a letter outlining the response to their comments. Public Meetings. Public meetings may be held to review the study plans and the composite study findings. A tentative schedule of public meetings is included in Section 2 of this Community Relations Plan. Meetings will be held in the City of Midland. Notice of upcoming meetings will be provided through press releases two weeks in advance, the quarterly progress reports, and special meeting notices in newspapers of local distribution, if appropriate. Press Releases. Press releases will be issued at appropriate times throughout the study: To announce the start-up of field activities To announce specific sampling results To announce upcoming public meetings To announce the availability of the final study results. 0000 11 _Loca1 Presentations. Press briefings will accompan. cant issues are concerned or presented. 1 . . press releases when signifi? hen highly technical data are Copies of the press releases will also be provided to local officials and the Congressional delegation. Press Briefings. A briefing held one to two days prior to results (subsequent to briefia purpose of the briefing will data interpretation, sampling effects analysis and related for the local press will beI the release of specific study 195 of public officials). The be to provide information on and testing processes, health technical issues. This in- formation will provide a background on the technical issues so that the local press is b? Fact sheets W111 also be provided. study results. meeting A: tter prepared to report the' Present tions to local service groups and other interested organiza ions will be coordinated with scheduled trips to Midland as time is available. COMMUNITY RELATIONS WORK PLAN The schedule outlined below i receipt of laboratOry results. will be communicated to the major participants. ACTIVITY DESCRIPTION Community Meetings .Late Fall results 't Meeting B: activities, and schedule. Meeting C: October 1983. public comments, soil sampling plan, and project Schedule. Early 1985. tentative and dependent upon Significant schedule changes To discuss response to (Held October 4.) 1984. To discuss sampling 0 date, remainder of study To discuss study results and future recommendations, if any. . Press Releases/Advisories PreSs Release A: September 1983. Issued September 13 to announce October 4_public meeting. Press Release B: October 1983. To announce start-up of project activities. Press Release C: February of draft relations comment. 984. To annpunce availability study elements and community, plan for public review and: 1 312 Press Release D: Press Release E: I 1 Late Fall 1984. ?To announce sediment and waSte?ater sampling results. To an- nounce Public Meeting B. To announce sampling results from waste systems, wells, 1 achate and air samples soil. sampling results and CDC and.Michigan Department of Public Health eValuationL Early 1985. To annOunce availability of final study results and Public Meet-i ing C. I Other press releases and/or advisories will be issued as appropriate throughout the study process. Progress Reports Progress Report A: Progress Report B: Progress Report C: Progress Report D: Public Summaries of Summary A: Summary B: Summary C: Information Briefings Briefings for local officials and interested groups will be March 1984 August 1984 November 1984 March 1985 . Technical Material June/July 1984. To describe? soil sampling results and CDC MDPH findings. October 1984. To describe sediment and wastewater sampling results. To describe sampling results from waste systems, uwells, leachate, and air samples. i Spring 1985. To describe the final study results. held approximately every four months. i Briefing.A: Briefing B: Briefing C: Briefing D: January 1984 March 1984 'October/November 1984 January/February 1985 Response to Media and Citizen Inquiries 1 Ongoing: Re5pond to questions and inquiries from media and concerned citizens. i 13 Other Activities Information February 1984. Establish repositories repository: at City of Midland library, Midland County alth Department, and Ingersoll 'Township Office. Mailing list} September 1983. Prepare project mailing list. Update as appropriate. - l4 'I'a 1e1 INDIVIDUALS INTERVIEWED DURING COMMUNITY RELATIONS PLAN Mr. Ned S. Arbury 10 Snowfield Midland, Michigan 48640 Dow Chemical Company Michigan Division 47 Building Midland, Michigan 48640 Contacts: Ms. Sarah Rowley Mr. Vern May Ms. Sue Dupree Mr. Micha?l Rio Environmental Congress of Mid-Michigan 2505 East Sugnet Court Midland, Michigan 48640 Contacts: Ms. Diane Hebert Ms. Andrea Wilson_ Mr. Vincent Castellanos City of Midland City Hall 202 Ashman Street Midland, Michigan 48640 Contacts: Mr. Joseph Mann, Mayor 'Mr. CliffiMiles, City Manager Mr. John Rae, City Attorney Midland County Board of Commissioners Courthouse Midland, Michigan 48640 Contacts: Mr. Scott McDonald, Chairman Ms. Laura Brandes Ms. Mary Miller Midland County Health Department 125 west Main Street Midland, Michigan 48640 Contact: Dr. Winifred Oyen, Director I I ble 1 I INDIVIDUALS I TERVIEWED DURING COMMUNITY RELATIONS PLAN (Continued) 7. Mr. Curtis R. Shaffner, Ingersoll Township Supervisor] 4400 Brooks Road, Rt. #10 i Midland, Michigan 48640 8; Major Warren Yoder, Salvation Army 1517 Bayliss Midland, Michigan 48640 Table 2 MIDLAND INFORMATION REPOSITORIES Grace A. Dow Memorial Public Library 1710 W. St. Andrews Midland, Michigan 48640 (517) 835-7151 Gale Burkhart, Supevisor of References Rosemary Byers, Director Midland County Health Department 125 W. Main Street Midland, Michigan 48640 (517) 832-6689 Dr. Winifred Oyen, Director Ingersoll Township 4400 E. Brooks Road Midland, Michigan 48640 (517) 835-5289 Curtis R. Shaffner, Supervisor l'ier 2 ?recursor Sites fier 3 -ormu ation Sites 'ier 4 Zombustion Sites 'ier 5 20mmerCIal Use iltes 'ier _6 )uallty Control 'roblem Sites 'ier 7 :ontrol Sites remedial actions are needed. EPA is still in the process of identifying locations where wastes from these production facilities might have been diSposed. Tier 2 includes nine sites where was used as a precursor to make other chemical products such as silvex, and hexachlorophene. Initial sampling has been completed at most sites. The waste disposal sites associated with these facilities will ultimately be included in this tier. Tier 3 consists of sites and associated waste diSposal sites where . and its derivatives were formulated into herbicide products. Approximately 60 to 70 sites will be sampled between October 1983 and October 1985. EPA also will be investigating the possibility that various combustion processes produce dioxin. Examples of combustion sources to be studied include hazardous and municipal waste incinerators, internal combustion engines, and accidental fires involving PCB-transformers. This tier includes sites where pesticides that may babontaminated with have been used or are being used on a commercial basis for a variety of agricultural and silvicultural activities. Examples of these uses include clearing power line rights-of-way of brush and vegetation, and as a pesticide for rice and sugar cane fields in the Southern United States and in forests of the Pacific Northwest. Approximately 20 to 30 sites are scheduled for testing. In this tier, EPA will test certain organic chemical and pesticide manufacturing facilities where improper quality controls may have resulted in the production of Approximately 20 sites will be investigated. These are sites where EPA least expects to find dioxin. They have been included as part of study as ?control" sites to determine if there are ?background" levels of dioxin in the environment and, if so, how widespread they are. Soils at 500 randomly selected sites across the country 200 in rural areas and 300 in urban areas will be sampled between July 1984 and July 1985. Fish will be sampled from over 400 locations, including streams throughout the US, the Great Lakes, and coastal and estuarine waters. (o [g Overview Dioxin Tier Production Sites United States Office of July l984 Environmental Protection Public Affairs (A407) Agency Washington DC 20460 Dioxin Facts Study Site Categories in National Dioxin Strategy In December 1983, the US. Environmental Protection Agency (EPA) announced a National Dioxin Strategy to determine the extent of dioxin contamination throughout the country. The strategy provides a systematic framework under which the Agency will: I. study the nature of dioxin contamination throughout the US. and the risks to people and the environment. 2. clean up dioxin-contaminated sites that threaten public health; 3. find ways to prevent future contamination; and 4. find ways to destroy or dispose of existing dioxin. To carry out its dioxin strategy, EPA established seven categories (tiers) of sites for investigation and study. These sites range from those that are most probably contaminated to those where there is no advance expectation of finding contamination. EPA believes over 80 percent of the dioxin will be found in the Tier 1 and 2 sites. The other study tiers, where EPA believes 10?20 percent of the dioxin. may be located, comprise a National Dioxin Study which begins in the summer of 1984 and will take from 12?15 months. The word dioxin is actually a generic term for a group of compounds known as dibenzo-p-dioxins but in popular use it usually refers to the most toxic and carefully studied of these compounds" or or TCDD. Whenever we discuss dioxin in this fact sheet, we are referring to 2,3,7,8 Nobody produces dioxin on purpose. It is an unwanted but almost unavoidable by-product that comes from manufacturing several commercial substances, chiefly the pesticide 2,4,5-trichlorophenol This pesticide is then used as a basic ingredient in the manufacture of several other pesticides. EPA has already investigated and confirmed dioxin contamination at most of the ten sites where was produced. At many of these locations, companies are undertaking cleanup or are engaged in negotiations with EPA. Additional investigations will be made where appropriate, and Superfund authority will be used to clean up these locations if removal or United States Environmental Protection Agency Office of Public Affairs (A-107i Washington DC 20460 July 1984 Dioxin Facts Answers to Commonly Asked Questions What is dioxin? The word dioxin is a generic term for a group of 75 related compounds known as poiychlorinated dibenzo-p-dioxins but in popular use it usually refers to the most tome and carefully studied of these compounds 2,31,8- tetrachlorodibenzo?p?dioxin, or or Simply TCDD. Where does dioxin come from? Nobody produces dioxin (TCDD) on purpose. it is an unwanted but almost unavoidable by-product that comes from manufacturing several commercial substances. chiefly the pesticide 2,4,5?trichlorophenol This pesticide is then used as a basic ingredient in the manufacture of several other pesticides, including the herbicides and silvex, and the bactericide hexachlorophene. (Pesticide is a general term for chemical products used to destroy or control unwanted insects. plants, fungi, mites, rodents, bacteria, or other organisms.) How does dioxin get into the environment? TCDD can enter the environment in several ways; through chemical products contaminated with dioxm; as a component of the wastes that are produced in manufacturing these products; and through the widespread use of contaminated products. Combustion is another possible source of dioxin contamination. Dioxin can enter waterways and soil in stormwater runoff, through industrial discharges. or by seeping from landfills that contain dioxin?contaminated wastes. Dioxin's solubility in water is quite low. but it attaches itself to soil particles. thus making it more likely to be found in the sediment than in the water itself. Once in the environment, dioxin can be very persistent. its half-life in soil is on the order of 5-10 years. Under Special circumstances, however, the ultraviolet radiation in sunlight can degrade it over a shorter amount of time. How does dioxin affect people? Although scientists disagree on the long-term health effects of exposure to 2.3.7.8-TCDD, tests on laboratory animals indicate that it is one of the most toxic man-made chemicals known. Because information on effects to humans has come mostly from accidental exposures. the data are not definitive. Scientists do agree, however, that exposure to TCDD can cause a persistent skin rash called chloracne. as experienced by some workers exposed to dioxin in the work place or through industrial accidents. Tests on laboratory animals also indicate that exposure may result in a rare form of cancer called soft tissue sarcoma, liver dysfunction, elevated blood cholesterol, nervousness. and other problems. Much controversy still exists over the use of Agent Orange, a dioxin?contaminated defoliant used during the Vietnam War, and whether some veterans and their children may be suffering from delayed effects of the chemical. How do people generally come in contact with dioxin? There are two exposure routes that present the greatest possibilities for health risks. One is through contact with dioxin-contaminated soil and the other is through eating contaminated fish. Dioxin-contaminated soil presents a particular risk to children who ingest it. At what levels is dioxin a danger to people? The Centers for Disease Control (CDC) considers 1 part per billion (ppb) of dioxin in soil to be a level of concern in residential areas. (CDC is the federal agency EPA relies on to conduct site-specific exposure and risk assessments whenever hazardous pollutants are found in soil at high levels.) The Food and Drug Administration recommends limiting consumption of fish with 25 parts per trillion (ppt) or greater of dioxin to no more than one meal per week and not eating any fish with greater than 50 of dioxin. EPA, in conjunction with these federal agencies and State and local health agencies, will issue health advisories and alert people to any precautions they need to take whenever dioxin is detected at these levels. They will also decide what further actions are necessary. Is it safe to swim or boat in water that contains dioxin? Local health agencies post signs to alert people when they should not be using a particular body of water for recreational purposes. Since dioxin does not readily dissolve in water, but instead attaches to particles and eventually settles to the bottom, it is not likely to pose a threat to human health unless you disturb any sediment in which dioxii' has settled. However. if you have any concerns whatsoever about the safety of the water, for any reason. ask advice of your local health officials before swimming 'Joating. Is it safe to drink water that contains dioxin? Any drinking water that is suspected of being contaminated with dioxin or any other hazardous chemical should not be consumed. You should contact your local health department to find out the facts, or heed any advice they have given you. They will also advise you on whether or not you should be using an alternative drinking water source. Most water treatment plants can eliminate dioxin during the water treatment process by removing the sediment in which it collects. Does dioxin affect animals? The only known incident in the US occurred in Missouri in 1971 when horse arenas were sprayed With high levels of dioxin~contaminated oil. Hundreds of horses became sick and 65 of them died. What federal agencies are involved in dioxin detection and cleanup? EPA regulates dioxin under the Toxic Substances Control Act and the Federal Insecticide. Fungicide. and Rodenticide Act and is developing regulations to control it in wastes under the Resource Conservation and Recovery Act. The Food and Drug Administration issues health advisories for dioxin in products for human consumption. The Occ'upational Safety and Health Adminisuation has iurisdiction over dioxin exposure in the workplace. Issues associated with dioxin in Agent Orange involving military personnel are handled by the Veterans Administration (VA) and the Department of Defense. although the VA has relinquished control of a project to investigate a link between dioxin and Vietnam veterans to the Centers for Disease Control. What has industry done about the dioxin problem? By 1965. some companies had changed their production processes and increased quality control practices in an attempt to reduce the levels of TCDD in the pesticide 2.4.5-T. As the controversy over dioxin increased. these companies instituted practices to further lower dioxin levels. and some companies ceased manufacturing the controversial product altogether. Today there is no domestic manufacturer of the pesticide What has the federal government done about the dioxin problem? In 1970. the Department of Health. Education. and Welfare (now the Department of Health and Human Services), the Department of Agriculture. and the Department of interior su5pended many uses of the herbicide as a result of a report by the National lnstitute for Environmental Health Services that is caused birth defects in laboratory mice. In 1970. the Department of Defense halted the spraying of Agent Orange in Vietnam and in 1978. the Veterans Administration created the Agent Orange Registry to identify veterans who are concerned about possible exposure to Agent Orange. In 1979. on the basis of controversial evidence that linked forest spraying of with an increase in miscarriages among some Oregon women. EPA suspended use of silvex and on forests. rights-of-way and pastures. but still allowed spraying on rice fields, fence rows, vacant lots and lumberyards. in 1981, the Centers for Disease Control began a study to determine if Vietnam veterans are at a greater risk of having Children with birth defects. In 1981. the Food and Drug Administration banned the use of hexachlorophene in nonprescription soaps and deodorants. In 1981. the Food and Drug Administration recommended that people not eat fish with dioxin levels greater than 50 ppt. and limit their consumption of fish with 25-50 of dioxin. Fish with dioxin below the 25 level are considered safe to eat. in 1982. EPA required some industries to certify that they were no longer using chlorophenoI-type compounds as slime control agents. In 1983. EPA proposed cancellation of all remaining 2.4.5-T and silvex products. This action was appeaied at a hearing by a number of pesticide registrants and users. Until the hearings are completed. as required by law. limited use of 2.4.5-T and silvex may continue. In 1983. EPA initiated a National Dioxin Strategy to look for areas throughout the country where may be present in the environment. The strategy provides a systematic framework under which the agency will study the nature of dioxin contamination throughout the US. and the risks to people and the environment; clean up dioxin- contaminated sites that threaten public health; find ways to prevent future contamination; and find ways to destroy or dispose of existing dioxin. A National Dioxin Study to investigate the nature and extent of dioxin contamination in the environment will begin this summer and take from 1245 months. Air. water, soil, and fish sampling will take place in over 1.000 locations across the country. In 1984. EPA issued a water quality criteria document for 2.3.7.8-TCDD. Are there ways to safely dispose of or destroy dioxin? EPA is currently evaluating methods of diaposing of or destroying dioxin?contaminated soils and wastes. Established technologies include incineration. chemical degradation. and biological treatment measures. but EPA rs working to find other methods of disposal as well. One promising technique is to treat soil with a chemical compound and sunlight. This method holds promise for actually detoxifying the dioxin molecule. Another alternative that is being investigated involves the use of solvents to change dioxin into a soluble form capable of destruction. Some temporary methods to limit exposure include: excavating highiy contaminated soil and removing it to a secure landfill or concrete vault; securing and capping the contaminated area; and using high efficiency vacuums and liquid dust suppressants. Who can I contact if I have more questions about dioxin? Each of EPA's 10 regional offices has a community involvement contact who can answer your questions about dioxin. Followrng are their names. addresses. and telephone numbers. Debra {8 7l 22341906 Connecticut. Maine, Office of Public Affairs Massachusetts. New US. EPA ion 1 Hampshire. Rhode JFK Federai uilding Island. Vermont Boston. MA 02203 Richard Cahill f2l2} 264?25l5 New Jersey. New York. Of?ce of Public Affairs Puerto Rico. Virgin US. EPA Region 2 Isfands 26 Federal Plaza New York. NY 0007 Joe Donovan l2l5l 597-9370 Delaware. Maryland. Office of Public Affairs Virginia. US. EPA Region 3 West Virginia. District 8th and Walnut Sts. of Columbia Phila.. PA 9 06 Hagan Thompson {4041 88l-3004 Alabama. Georgia. Office of' Public Affairs Florida. Mississi pi. US. EPA Region 4 North Carolina. outh 345 Courtland St, NE Carolina. Tennessee. Atlanta. GA 30308 Kentucky Vanessa Musgrave (3l2i 886-6l28 lilinois. Indiana. Ohio. Office of Public Affairs 5. EPA Region 5 230 S. Dearborn Chicago. IL 60604 Michigan, Wisconsin. Minnesota Betty Williamson 2I4l 767-9986 Arkansas. Louisiana. Office of Public Affairs Oklahoma. Texas. New U.S EPA Region 6 Mexico 20l Elm St. Dallas. TX 75270 Steven Wurtz (8 6l 374-5894 lowa. Kansas. Missouri. Office of Public Affairs Nebraska US. EPA Region 7 324 E. St. Kansas City. MO 64l06 Nola Cook Office of Public Affairs US. EPA Region 8 Surte 900 1860 Lincoln St. Denver. CO 80295 [303] 837-5927 Colorado, Utah. Wyoming. Montana. North Dakota. South Dakota Deanna Wreman [415) 974-8083 Arizona. California. Office of External Affairs Nevada. Hawaii. US. EPA Region 9 American Samoa. 2l5 Fremont St. Guam San Francisco, CA 94l05 Bob Jacobson i206} 442-i203 Alaska, Idaho, Oregon. Office of Public Affairs US. EPA Region ID 1200 Sixth Ave Seattle. WA 98l0l Washington FINAL COMMUNITY RELATIONS PLAN MIDLAND, MICHIGAN August 1984 07.5VG1.0 DATE: SUBJECT: FROM: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION August 21, 1984 Additions to Information Repositories Vanessa Musgrave Community Relations Coordinator Gayle Burkhart, Dow Public Library Kurt Shaffner, Ingersoll Township Dr. N. Oyen, Midland Health Department Enclosed please find two new documents to be included in the information repositories on the investigation of potential contamination in Midland, Michigan. The final community relations plan should be added with its tabbed sheet. The new fact sheet should be filed behind the tab marked "Brochures". If you need additional copies of these documents please contact me at (312) 886r6128, or at the address above. Thank you again for your cooperation. .two sections. FINAL COMMUNIT RELATIONS PLAN STUDY OF DIOXIN AND THER TOXIC POLLUTANTS MIDLAND Augu. The Community Relations Plan and other toxic pollutants in MICHIGAN . 1984, I (CRP) for the study of dioxin Michigan has been prepared in The first section contains the community res lations assessment, which presents the site background and discusses the objectives and_ techniques of the Community .gained during a review of project files, discussions with ?Region personnel and onsite interviews. Relations Plan. 'The second section outlines implementation ?activities, including a work plan, staff allocation,.budget and schedule. Primary responsibility for implementation of the CRP will rest with U. S. EPA, Region V. This Community Relations Plan is based upon information Interviews were held with a variety of local 'businesses, service organiza+? tions, environmental groups, and elected _officials. Tablell lists the individuals who were interviewed for the prepara? tion of this CRP. COMMUNITY RELATIONS ASSESSMENT ?Dow Chemical Company reported COMMUNITY RELATIONS BACKGROUND :Over the past few years there have been several reports of dioxin _found 1n fish from Michigan rivers. In June 1978,? to the Michigan Department of Natural Resohrces (MDNR) thatl2, 3, 7, B-TCDD was found in fish taken in 1976 from the Tittabawassee River of the Midland p-lant at levels ranging from 70? 230 parts per trillion (ppt). Various fish caught at Smith's Crossing Road in 1977 had concentrations of 2, 3, 7 8- TCDD ranging fromr nondetectable to 170 ppt.. Based on the information reported by Dow, the Michigan Department of .Public Health immediately issued an adViSOry against consuming fish caught in the Tittabawassee and Saginaw Rivers. The health advisory is still in effect. In addition, limited data published by Dow suggest that di- 0xins are found in soils in_the City of Midland and outlying areas in the parts per trillion range and somewhat higher within the Dow Chemical pla-nt boundaries. Currently, not enough data are available to adequately assess_ whether the levels of dioxins reported by Dow represent typical .levels of dioxin in Midland soils, or whether higher levels may be found in certain locations. . . EPA has developed a national strategy and is developing national and regional field investigation'plans for dioxins. The strategy and field programs will address broad issues such as the level and extent of dioxin contamination nation- wide3 the sources of dioxin contamination; research3 inter? agency issues concerning health effect53 and intensive studies at control sites and other locations where dioxin contamination is suspected. The U.S. EPA's nationwide strategy will include backgro nd sampling at several loca- tions throughout the country. As part of this effort, EPA is conducting a study in four midwestern locations including the City of Midland and the Dow Chemical Company plant to determine whether or not dioxins and other toxic pollutants are present at levels of concern. Depending on the results obtained, more intensive investigations or remedial measures may be warranted. This CRP outlines the public participation activities that will occur during the above-outlined study for the Midland Michigan, area. Community relations is a dynamic, ever- -changing process. Therefore, this plan may require additions and changes to address unfereseen conditions that may develop during the course. of the study. The U. S. EPA reserves the right to consider any and all suggested changes to this plan that equitably benefit the community. Prior History of Federal/State Activities The Michigan Department of Natural Resources first became aware of the existence of dioxin contamination in Michigan in June 1978. At that time, Dow presented results of re?i search studies on dioxins to the Department's staff. This information formed the basis for the MDPH health advisory referenced above. In October 1978, MDNR requested assistance from EPA to conduct in-plant sampling at the Dow facility. EPA and MDNR tested wastewater, river sediment, and treatment plant sediments. In 1979, EPA and the State of Michigan began review of an. NPDES water discharge permit?for the Dow-Midland plant. Information On plant discharge was needed to develop a "best available technology analysis. EPA issued an information request to Dow on January 20, 1981. Issues surrounding the information request were resolved in the Spring of 1984. In September 1981, EPA and the State of Michigan conducted a caged fish study as part of a wastewater characterization study at the Dow plant. The process wastewater effluent from the Dow plant was sampled and caged fish were placed in the Tittabawassee River in the plume of the discharge. The preliminary results from this study were released in March 1983. These results describe. the wastewater discharge from Dow Chemical' 5 Midland plantlof conventional pollutants, nonconventional pollutants, and toxics. In addition, on March 1, Michigan State Uni Iersity released a graduate student's study which indicated that 2 3, 7, 8- TCDD was widely distributed throughout southern lower Michigan rivers. This was the first report of potential widespread TCDD contamina? tion reported within the state. On March 23, 1983, U.S. EPA received a request from the State of Michigan to begin work on a study of the dioxin contamination in the Midland brea. Work began immediately to prepare a scope of work and budget package for such an effort. In September 1983, Congress appropriated funding for the National Dioxin StudyL Final preparations for the Midland. Study' were completed shortly' thereafter. The Midland Study is part of the National Dioxin Study and is consistent with study efforts throughout the country. History of Community Relations Activities On March 16, 1983, a "Citizens Petition for an Investigation and Enforcement Action" was submitted to the U. S. Environ- mental Protection Agency by the Environmental Congress of Mid-Michigan (ECOMM) and the Foresight Society. Both of these groups are based in the central Michigan area. The petition requested that EPA begin investigations and en-' forcement actions related to dioxin and furan pollution in central Michigan. The petition was submitted to EPA Head? quarters and was passed on to Region in early April. On April 18, 1983, ECOMM and the Foresight Society submitted a supplemental petition through the Citizens' Clinic for Accountable Government of the Government Accountability Project, a group based in Washington, D.C. This supplemental petition expanded on many of the issues included in the initial petition. The Administrator's response to the Central Michigan Citizen' 5 Petition was issued on June 10, 1983, and wasi reprinted in the Federal R_gister on July 25, 1983. The response reviewed those activit1es which the EPA and the State of Michigan were already undertaking to address the issues raised inbthe petitionland outlined additional future activities which the agency proposed to undertake. EPA conducted a meeting on June 10, 1983, in Midland, Michigan, to discuss the Administrator's response to the petition. Approximately 70 people attended that meeting. ECOMM pre- sented a series of questions at the meeting that were responded to in writing on August 9, 1983. On August 10, 1983, EPA issued a draft study plan jointly with the State of Michigan for public review and comment. The study plan included an initial community relations schedule. A press release was issued announcing the availability of the study, copies were made available at a local information repository, and individual copies were mailed to interested partiesJ On August 12,1983, public officials were briefed on the content of the draft study plan. A public meeting was held in Midland on August 18 1983, to discuss the draft plan. Approximately 150 people attended the meeting. About 70 comments were received from the public. The comments addressed several 1ssues including the need for and the Scope of the study, analytical levels of detection, and possible effects on the Midland area. After consideration Of all comments received through September 21, numerous 'revisions to the study plan were made. A response summary was prep_ared and distributed on September 26, 1983, to about 1500 people. A second public meeting was held on October 4, 1983, in Ingersoll Township -to review responses to public comments and planned revisions to the soil study plan. About 190 people attended thelmeeting. i An undated "Citizens' Participation Program for Central Michigan" was submitted by ECOMM in early September 1983. I Since March 10, 1983, four Freedom of Information Act (FOIA) requests have been submitted on behalf of ECOMM and the Foresight Society. An FOIA request was also received from the Midland Area Chamber of Commerce. Responses to all FOIA requests have been completed. Local press coverage concern- ing the Midland Study and the activities of ECOMM has been substantial. National press coverage, through both neWSpapers and trade journals, has also occurred. Community Relations Participants The major participants for the Michigan Study have been the EPA, the State of Michigan, Dow Chemical Company, the local communities, the Congressional delegation and two local en- vironmental organizations??the Environmental Congress of Mid-Michigan (ECOMM) and the Foresight Society. A discus- sion of the role each of these groups has played and its issues of concern are described below. U.S. Environmental Protection Agency. Since 1978, U.S. EPA Region has assisted the State of Michigan with sampling and wastewater permitting activities related to Dow Chemical Company's Midland facility. Under the proposed National DioXin Strategy, EPA has lead reSponsibility for the conduct of the Michigan Study of Dioxin and Other Toxic Pollutants. This study is an element of the Region's broader investigations of dioxin and other toxic pollutants. The Centers for Disease Control (CDC) has assisted EPA in the design of the study. State of Michigan. Three sta agencies have been involved 1n the ongoing study efforts in the Midland area: the Attorney General' 5 Office (MAG) the Michigan Department of Natural Resources (MDNR), and the Michigan Department ofi ublic Health (MDPH). EPA began work with the MDNR and the MDPH in April 1983, to prepare a study plan for the Michigan study. In June, Governor Blanchard assigned responsibility for coordinating the State' 5 efforts to the Attorney Gen- eral's Office. Since that ti e, the Attorney General has: been the primary contact fdr?MiChigan. participation. William C00per, the Chairman of the Michigan Environmental Review' Board (MERB), has also assisted the .Attorney General's Office. The Michigan Department of Public Health has been involved in the design 0f the soil Sampling study and discussion of health issues surrounding the Dow Chem-ical Plant. If study results indicate the potential for health risks, MDPH will assume a greater role in future site-related activities, as will CDC. City of Midla?nd. The mayor, city manager, a-nd city attorney for Midland have all participated in public meetings and discussions with EPA concerning the upcoming study. The -City has also assisted EPA inlsett ing up public meetings to discuss the study elements. 'During the public comment period on the study design, the City requested formal status during the course of the study. While EPA responded that no formalized mechanism existed for such status, the agency is committed to prOvide the City with full communications about ?the study through this Community RelatiOns Plan. Other Local Government Units. The city of Saginaw has expressed interest in the study based on concern of movement of water contamination in the 'Tittabawassee River. Several city council members have discuSsed their views with EPA and have participated in public meetings. Ingersoll and Williams Townships have also expressed inter; ?est in the upcoming study. .Kurt Schaffner, the Ingersoll: Township Supervisor, has been in contact with EPA on several occasions. While Ingersoll TownShip has been involved with Dow over past.problems.associated with brine spills, they do not anticipate an active role in this study. It was also suggested that Midland and Larkin Townships be regularly advised of study progress and findings. The Midland County Beard of Commissionerthas also expressed an interest in the study and has commented 0n draft study. materials. Like the City of Midland, the County has also requested ongoing information on study progress. The - county public health directOr; Dr. Winifred Oyen, has been the focal point for county involvement. 4 1 Environmental Organizations. Two Michigan area _known and suspected pollLitants and Contaminants on Dow environmental organizations have been heavily involved in. activities surrounding the Do plant and the proposed study plan. .These are the Environmental Congress of Mid-Michigan (ECOMM) and the Foresight Soeiety. ECOMM was organized around the specific issues associated with the proposed study, while the Foresight Society was organized initially in 1982 to respond to a disch rge permit application pending for the Dow* facility. These two groups have been represented in Washington, D. C., by the Government Account? ability Project (GAP). On March 16, 1983, ECOMM and the Foresight Society filed a petition under TSCA requeSt-ing that EPA begin investigation-s and enforcement actions related to pollution by toxic sub- stances in central Michigan. [In general, petit1oners re- quested independent testing of contamination levels for all property and adjacent areas,! an Environmental Impact Statement assessing the Overall impact on public health, an epidemiological study on health problems in the central Michigan area, and an evaluation of the danger of contamination of drinking water aquifers. The Administrator's response to the petition was issued on June 10, 1983. In a "Citizens' Participation Program for Central Michigan? submitted by ECOMM, they expressed concern that citizen input into t-he study process had not been encouraged. The stated purpose of the ECOMM CitiZen Participation Plan is to "improve working relations between the environmental regulatory agencies and the petitioners, to establish a pro? tocol for the sharing of information and to ensure that the petitioners who requested the Full Field Investigation are included in the prOcess." A response to the proposed Citizen Participation Plan was i?ncluded in the response to comments distributed by Region on september 26, 1983, along with the revised soil study. Dow Chemical Company. Since the March announcement of previous dioxin study results, Dow has been invited to speak to over 60 groups throughout Michigan to discuSs past and upcoming studies. Dew has participated in the public meetings held by EPA and haslmet with both the State of Michigan and EPA. Dow has cooperated with EPA in both the study design and sampling por ions of the study. i 1 .1 Congressional Delegation. Congressmen Albosta and Traxler have shown substantial inter st in the Midland question. They have participated in th public and small group meetings. Congressmen .A_lbosta and Traxler' were both instrumental .in achieving Co gressional approval of the Special appropriation of funds for the National Dioxin Study. Congressman Albosta? as organized meetings between EPA, the State of Michigan, _nd local officials to discuss study activities. . Community Relations Issues Numerous interviews were cond cted with. local officials and area residents to determine the public issues surrounding? the Michigan study. The following summary of issues is based on the information gained from those discussions. As a reSult of interviews conducted, it appears that the general public in Midland isinot concerned about potential contaminatiOn, but many are interested in the outcome of the study. Midland residents bedieve that they live in a. *healthy environment and do not believe that they have been exposed to unusual health rishs because of 3 activities. Dow is widely accepted as a g_ood corporate neighbor and a responsible,_highly professional member of the community. Dow' scientific expertise islhighly regarded and they have a credible public image in the local area. While most peeple are not individually -concerned about health risks from potential contamination,:now that the question has been raised they want a credible, scientifically defensible answer as soon as possible. Residents and members of theibusiness community are con? cerned about the damage they believe has been done to Mid- land's public image. They have an intense pride in their community and believe that media coverage or. the study isl creating the wrong impression of the area. They are fearful that the study results will raise additional questions and 'are hoping for an early resolution of the questions that have been raised. Most individuals interviewed during the preparation of this CRP indicated that they do not believe that a problem exists. However_, if toxic pollution problems are found, they want the problem addressed, solved and laid to rest. i The general community is very'well informed on the issues surrounding the study. Many citizens have technical back? grounds and are thus able to provide meaningful comment on technical aSpects of the studlies. Numerous service Clubs have sponsored programs to inform their members and the general level of public understanding is high. People are very interested in the technifal issues and are conversant in the issues surrounding testing levels part per trillion versus part per billion, sampling protocol, etc.). Some people interviewed expressed a concern that Midland has been singled out and have requested comparative study re- sults that will show how Midland ranks against other similar communities. Some residents have also requested a health risk analysis that will allow evaluation of the study re- sults against health information so that the public health risk, if any, can be determined. According to interviews, the members of ECOMM seem to represent a small number of residents of the Midland area. They have committed a substantial amount of personal time to research issues surrounding the Dow facility and believe that they have collected technical information that suggests a high level of tox1c contamination. They believe that EPA and the State of Michigan have been slow to act and that substantial further investigation is required. ECOMM wants to educate the Midland public about the potential health risks in the community and work with state and federal agencies to resolve the existing health problems ECOMM has identified. ECOMM believes that the research they have done on the issue warrants their active participation in the study process. They would like to serve as a formal participant and/or observer in important project meetings between EPA, the State of Michigan, and Dow. At a minimum, they believe that minutes of all project meetings should be provided to them. ECOMM members believe they are committed to a clean environment and want a partnership relationship with EPA. They believe that their recent efforts have provided good, investigative research for EPA and that they would like to be reimbursed for their efforts. In summary, the City of Midland has been significantly im- pacted by the events during and following March 1983. While most local residents are not fearful for their health, they do want the question of potential contamination in Midland laid to rest. They want a credible, defensible research study that will clear the air and allow them to move on to other matters. COMMUNITY RELATIONS OBJECTIVES AND TECHNIQUES This community relations plan focuses on effective, two-way communication between interested citizens, local officials, and the EPA. It is EPA's intent to provide an opportunity for the public to participate in the study through review and comment on project documents. EPA also intends to pro- vide significant information to the public through access to 1 study results, public meetin s, and project progress re- ports. Although EPA will ma every attempt to adhere to all project schedules, the privision of scientifically cor? rect information will be the ma] or goal of the study effort. If project deadlines must be lipped to ensure high quality results, the public will be tified in advance. Community Relations Objectives 0 participating' agencies including 'the City? of ?accurate, timely information regarding the "parties, and elected officials. . Establish open, eff lctive, two?Way communication among residents, nerested parties, and the EPA and State of Michiga project team. Allow equal publi access to all project information and participation in study activities. Establish an effective means of sharing technical information among Ehe project team, residents, interested parties} elected officials, and Midland, COunty of 'Midland, IngerSoll Township, Williams Township, ECOMM, the Foresight Society, and any other identified groups. Provide a central information source for interested parties and local officials- to receive information on sitegactivities and study results. Provide all interested parties and media with objectiVes, progress, and findings of the study. AProvide summaries of technical study results in a form that is useful to residents, interested Provide an opportunity to review all study results and to comment on any specific recommendations that result from study activities. In general, a 21?day comment period (minimum) on any recommendations for further a_ction will be provided. Two-week advance notice of the public comment period will be provided as appropriate. Identify interested: citizens in the City of Midland, and Ingersoll and Williams Townships and surrounding areas Who wish to be routinely informed of study activities and results. Remain sensitive to community concerns as the study progresses. I Community Relations Techniques The techniques listed below are suggested methods for meet- ing the community relations objectives. The recommendation of these techniques is based on the particular concerns of those involved with the Midland site. These techniques re- sulted from review of materials submitted by interested groups and discussions with Region project and public affairs staff. Central Information Contacts. EPA will establish a central information contact who interested parties can call for information. Technical questions will be referred to Gary Amendola of the Eastern District Office, while other types of information will be provided by Vanessa Musgrave, Office of Public Affairs. The central contacts will serve as a clearinghouse to ensure that local concerns are addressed and that requested information is provided. Coordination with local officials and participating agencies will be necessary to assure that consistent information is provided to all interested residents, press, and agencies. Local Repositories. Local information repositories will be set up at the City of Midland Library, the Midland County Health Department, and the Ingersoll Township office (Table 2). A complete docket of project technical materials, reports, correspondence, comments, and responses to comments will be established and maintained at each site. These repositories will allow residents and local officials access to all project materials. Progress Reports and Briefings. Brief progress reports will be prepared approximately every three months to update information on upcoming activities, study results, meetings, schedule changes and other items of interest. These progress reports will be distributed to elected officials and interested parties and will also be available at the information repositories. Formal briefings will be conducted with the City of Midland, the Midland County Board of Commissioners, Midland County Health Department, Inger- soll Township, Congressional delegation, ECOMM and Dow. These individual briefings will provide a review of past and upcoming activities. Study Result Briefings. Prior to release of study results, EPA. will brief the Congressional delegation, property owners, State of Michigan officials, the City of Midland County Board of Commissioners, Midland County Health Department, Ingersoll Township, ECOMM and Dow. These briefings will be held prior to the scheduled public meetings and will precede release of the study results to the press. Briefings will be scheduled in advance to ensure 10 full participation by interested officials. CDC involvement will be scheduled as appropriate. Public Comment on Study Plan Elements. The Community Relations Plan_and study plans will be available for public review and comment prior to i'plementation. Public comment on both the substantive and procedural elements of these plans will be solicited. 21?Day Public Comment Period. A 21?day public comment period has been provided fo' review of the Community Relations Plan and study plans. At this time, EPA does not anticipate the recommendation of specific remedial actions. If, however, it becomes clear that remedial actions are warranted, a 30- -day public comment period will be provided before work is undertaken. Public Summaries of Technical.Results. To provide local officials, interested parties, and residents with a clear understanding of the technical information reSulting from study activities, public summaries will be prepared to de- scribe the sampling results and study conclusions. These summaries will be incorporated in pmogress reports and Community meetings. These public summaries will be designed to be clear, accurate descript-ions of study results and pre? pared in a style and format that encourages public use andl understanding. Comment Process for Draft Community Relations Plan. The -draft Community Relations Plan was submitted to interested officials and groups for a 30-day review. Comments on the draft plan were accepted by mail. Based on comments received, a final Community Relations Plan was prepared and distributed. All individuals who submitted comments received a letter outlining the response to their comments. Public Mee_tings. Public meetings may be held to review the _study plans and the composite study findings. A tentative schedule of public meetings is included in Section 2 of this Community Relations Plan. Meetings will be held in the City of Midland. Notice of upcoming meetings will be provided through press releases two weeks in advance, the quarterly progress reports, and special meeting notices in newspapers of local distribution, if Press Releases. Press releases will be issued at appropriate times throughout the study: To announce the start-up of field activities To announce specific sampling results To announce upcomingipublic meetings To announce the availability of the final study results. 0000 ll Press briefings will accOmpan press releases when signifi- cant issues are concerned or when highly technical data are presented. Copies of the press releases will also be . provided to local officials and- the Congressional delegation. . Press Briefings. A briefing fer the local press will be held one to two days prior to the release of specific study results (subsequent to briefings of public officials). The purpose of the briefing will be to provide information on data'interpretation, sampling and testing processes, health effects analysis and related technical issues. This in- formation will provide a background on the technical issues so that the local press is better prepared to report the! study results. Fact sheets w?ll also be provided. Local Presentations. Presentations to local service groups and other interested organizations will be coordinated with scheduled trips to Midland as time is available. COMMUNITX RELATIONS WORK PLAN The schedule outlined below is tentative and dependent upon receipt of laboratory results. Significant schedule changes will be. communicated to the major participants. ACTIVITY DESCRIPTION Community Meetings Meeting A: October 1983. To discuss response to public comments, soil sampling plan, and project schedule. (Held October 4.) Meeting B: Late Fall 1984. To discuss sampling results to date, remainder of study activities} and schedule. Meeting C: Early 1985. To disCuss study results and future recommendations, if any. Press Releases/Advisories Press Release A: September 1983. Issued September 13 to announce October 4 public meeting. Press Release B: - October 1983. To announce start-up of project activities. Press Release C: February 1984 To announce availability of draft study elements and community' for public review and i comment. i 12 Press Release D: Press Release E: Late Fall 1984. To announce sediment and wastewater sampling results. To an? nounce Public Meeting B. To announce sampling :results from waste systems, wells, leachate and air samples soil sampling results and CDC and Michigan Department of Public Health evaluation. Early 1985. To announce availability of final study results and Public Meet- ing C. Other press releases and/or advisories will be issued as appropriate throughout the study process. Progress Progress Progress Progress Progress Public Summaries of Reports Report A: Report B: Report C: Report D: Summary A: Summary Summary C. I March 1984 August 1984 November 1984 March 1985 TechnicaliMaterial June/July 1984. To describe? soil I sampling results and CDC MDPH findings. October 1984. To describe sediment and wastewater sampling results. To describe sampling results from waste' systems, wells, leachate, and air samples. Spring 1985. To describe the final study results. Information Briefings Briefings for local officials'and interested groups will be held approximately every fourjmonths. Briefing A: Briefing B: Briefing C: Briefing D: Response to January 1984 March 1984 October/November 1984 January/February 1985 Media and Citizen Inguiries Ongoing: concerned citizens. Respond to questions and inquiries from media and 13 Other Activities Information February ?984. Establish repositories repository: at City ow Midland library, Midland County Health Department, and Ingersoll Township Office. Mailing list? September 1983. Prepare project mailing list. Update as appropriate. 14 Table 1 I INDIVIDUALS INTERVIEWED DURING COMMUNITY RELATIONS PLAN -l i Mr. Ned S. Arbury 10 Snowfield Midland, Michigan 48640 Dow Chemical Company Michigan Division 47 Building Midland, Michigan 48640 Contacts: Ms. Sarah Rowley Mr. Vern May Ms. Sue Dupree Mr. Michael Rio Environmental Congress of Mid?Michigan 2505 East Sugnet Court Midland, Michigan 48640 Contacts: Ms. Diane_Hebert Ms. Andrea Wilson Mr. Vincent Castellanos City of Midland City Hall i 202 Ashman Street Midland, Michigan 48640: Contacts: Mr. Joseph Mann, Mayor Mr. Cliff Miles, City Manager Mr. John R?ae,r City Attorney Midland County Board of Commissioners Courthouse Midland, Michigan 48640 1 . Contacts: Mr. Scott'McDonald, Chairman Ms. Laura,Brandes Ms. Mary Miller Midland County Health De?artment ?125_West Main Street Midland, Michigan 48640 Contact: Dr. Winifred Oyen, Director Table 1 - INDIVIDUALS INIERVIEWED DURING COMMUNITY RELATIONS PLAN (Con?inued) 7. Mr. Curtis R. Shaffner, lngersoll Township Supervisor. 4400 Brooks Road, Rt. #10 Midland, Michigan 48640 8. Major Warren Yoder, Salvation Army 1517 Bayliss Midland, Michigan 48640 Tab MIDLAND INFORMAT Grace A. Dow Memorial Public 1 1710 W. St. Andrews Midland, Michigan 48640 (517) 835-7151 Gale Burkhart, Supevisor of Re Rosemary Byers, Director Midland County Health Departme 125 W. Main Street Midland, Michigan 48640 (517) 832-6689 Dr. Winifred Oyen, Director Ingersoll Township 4400 E. Brooks Road Midland, Michigan 48640 (517) 835-5289 Curtis R. Shaffner, Supervisor . 1e 2 ION REPOSITORIES ibrary ferences nt September 25, 1984 r! - f. Environmental Action Foundation}: 724 Dupont Circle Building .iv' 'Washington, D.C. 20056 ?I've just finishedtreading your_article 0n chemical injection, in EXposure magazine. It'was great, and I can't wait"to get it out to everyone. Although chemical injection has been widely used as a method of disposal in Michigan, it is incredible how few people are aware of it. I believe that this article will serve as a useful tool for educating, and hopefully opposing this insane method of disposal. This information has never been pulled together in a way that the general public could understand before, and as a result there has been very little interest in the issue. I Will keep you informed of it's impact. Your organisation has been invaluable when it comes to providing inror? mation, resources, and updates on current legislation in Washington, that . . . . I will ultimately impact kichigan. I am very interested in your peermatch program. I am finding it very difficult to choose an area of need because we seem to have all of the problems listed on the application.!However, I will try to prioritize.- have recently turned over eight pages of known and supected contaminated sites in the Midland area, to The Michigan Department of Naturalikesources. .These sites were uncovered as a.result of.our.organieation's invastigation,. which included talking to former and current Dow workers, searching agency files, searching old news files, talking to City workers, and phySically examining the areas. Many of these Sites are along the banks of the Tittabawassee River, and some are popular recreation areas. .We have learned that these Sites were Lsed both by the City of Midland, and? The Dow Chemical Company. Most of them have not been tested, cleaned up, or turned over to the state. They have contributed to the pollution of the Tittabawassee River, and possibly been a health threat to those who use these areas for recreation. Although Dow and the city have been aware of these sites, apparently they feel no responSibility to alert people; to the possible health threats. Most people are not even aware that? these places are old dumps. believe that this is only the tip of the' iceberg, and feel that a "Community+Right To Knew Rule"_is a possible solution. have generated some interest in the ,Govenor's office, and the Department or Natural.Resources, but am simply not knowledgeable .4 fbeptember 25, 1984 Environmental Action Foundation enough in this area to carry it further.- I could use someone_w1th to see the rule further expanded. .1Bes1des an industrial survey to identify old dump sites, I would like see a plan that included informing reSidents when.accidental releases {of chemicals entered the environmend, either from roadside spraying, or equipment malfunctions. in Midland,fit is not uncommon to have accidental releases of such things as bromine,ichlorine, diphenyloxide, and who knows _what. We're never told, and bow isn't required to report releases under two hours. There is no chemical monitoring here, and no pollution index printed in the local news paper. A few weeks ago I received information that a decision was almost made to evacuate the city, due to one of these releases. That information was given to me by a very reliable source, yet I have no real way of confiming it.l The decision was in the hands or a few top level people, and the reSidents were never informed. All of us recall that there was a strong odor'that night and the following morning, but have no way of knowing what chemical was released. It's a little scary to know that these deciSions are left in the hands of a few top level people. I have to wonder if bad p.r. was a deciding factor. In the meantime, my children'are sleeping in their room, with the.windows open. I have no way of knowing what adverse impact on their health these releases might be having. I have no way of knowing if my son?s bloody noses might be related. Dow has total control over our lives. I,have no real way of knowing'What damage they might have done. ?Whil 'nurSing'my' son, I was exposed to unacceptable amounts or dioxin, through Dow's incinerator. I had no idea we wereibeing used as human guinea pigs. Dow, while d0ing their "Trace Chemistries of Fire" burn in 1978, reported finding 8200 parts per billion 2,5, 7?8 TODD in their rotary kiln incinerator. They didn't inform the state, or the the local reSidents that they were conducting a trial burn. We need a "Community?Right To Know Rule." The bottom line in all of this is health. We have already seen an excess1ve increase in soft tissue sarcoma, cleft palate, multiple myeloma; and cancer. We are_totally dependent on the agencies to recommend that health studies be conducted. Because we are not a superfund site, we must fight even harder for these studies, These recommendations will be very dependent on the SOll sampling resuits found by the EPA, in the Midland area. apage three September 25, 1984 F. _Environmental Action Foundation LDow1didragmassive_clean?up, on and ff-site before the EPA collected soil in the area. We tried to.gat EPA to stop them, as we felt that disturbing some of these soils could release some of these chemicals .i?tc'the environment. We were unsuccessful, and as a result, feel that we may again have been exposed to unacceptable levels of dioxin, and other particulate matter via the air and wind diSperSicn. There was an increase in asthma cases (many first admissions), and infections. We are Simply not capable of determining a connection. I have recently been in contact with Carol VanStrum, of Tidewater Oregon. Carol authored a book, entitled hitter Fog", A story or Herbicides and Human Rights. The interesting connection between Oregon, and Michigan is the fact that our dioxin sampling results taken by the EPA were mixed up. Dioxin which federal they found in Oregon in 1979 actually came from the Midland area in 1978. Dow Chemical is involved in both cases. Carol, and I have been,trying to piece this puzzle together. There are some very suspicious surrounding this incident. EPA will not give us information regarding the chain of custody for these samples. It was this very time period that the EPA decided to go behind closed doors with Dow for the 2,4, b?T hearings, and Freedom of Infor- .,mation requests made by to have miss1ng pieces. - Last week 1 was able to send Carol information from our reduest'that seemed to have been removed from their Freedom or Information Re?uest. This information was related to health problems in-their area. Carol, and her husband, Paul Merrell, feel that they have narrowed the problem down to a couple of people within the EPA. The most useful information Carol has offered has to do with health problems suspected to be related to the Spratdng of the herbicide This information regarding health effects related to these chemicals that were widely used in Midland and Oregon is critical. People in the Midland area are not generally aware of this inrormation. I believe that the . health study done in the Alsea, Oregon area; needs to be released in the Midland area. People need to be made aware that there are commonalities between the health problems observed in Oregon, and the health problemS? in Midland. i i I It September 25, 1984 Lu? . 1 Environmental Action Foundation I believe having Carol come to Midland, to discuss the health problems, birth defects, etc. they observed, alter the 2-4?b?T spraying would wake a few people up. This information has been played down in the area, if discussed at all. Our county health director used to work for Dow, and continues to work very closely with them. She spends the better part or her time trying to rationalize any unusual rise in illnesses. Although we had a dramatic.increase in cleft palate births in the early seventies, and the protocol for a study was set,it was never done. Nobody seems to be able to give a reasonable explanation for this. Additionally, the problem of the dioxin sampling result mix?up needsto be it _.is In by i'urther explored. As Carol and I continue to put the pieces together, is beginning to appear that an investigation into the entire situation lull" o. warranted. Perhaps? jointly we could ask for this investigation., I I . late November, of early December, where will be a public hearing, held the State, to determine if Dow, shhuld receive a renewal on their permit, to operate their 152 acre hazardous 1andfill(Salzburg). This landi?ill was shut down for quite- a while, due to leakage into the "clean zone." Although Dow had characterized this dump as "The Cadillac 91' Landfills" All or Dow's landfills have leaked I . didn't intend to write a bOok when started, but felt that these proolems deserved a detailed explanat? could use any and all information about alternatives to landfills." i on. I haven't even touched on the ongoing brinespills, that continue to threaten the groundwater, the incineration of chemicals with radioactive waste, and a host of other unresolved problems in the are Again, thank you for all you've done, and cbntinue to do. I'll.look forward to hearing from you sobn. "SincerelyDiane Hebert, director Environmental Congress of -Ern. 2505 East Sugnet Court . 1 .J ?fig?f: ?r?T Midland, Mi. 48640 EAE MICHAEL E. PICKER .5 2700 Street -at,w 5 inf. Sacramento, CA 95816 131? - (916) 446-7127 /'jy~f )3 .24 in" I . AREAS 9E EXPERTISE CO MMUNITY ORGANIZ ING Ten years of experience in building and working with community groups; conducting needs assessment, facilitation, training in organizational and political skills, leadership building, grass roots fundraising and coalition building. Some roles included strong advocacy components (as Sacramento President of CASE, acted as shop steward on clerical worker grievances, sat on Tri? Counties Central Labor Council). Role as Coordinator of Organizing included direction of other community organizers, as well as self-directed community groups. Indo?China Information Project (1971?72): Sacramento President, CASE, Local 909 of AFSCME (1975-77); United Farmworkers Union (1976); Sacramento CED (1978); Chemical Action Neighborhood Association (1980); McColl Dump Committee [1980); Coordinator of Organizing, CED Cancer Project (1980?81). MEDIA AND PUBLIC.RELATIONS Six years of experience in working with the press (electronic and print), drafting press releases and designing information packets, organizing press conferences and events. Experience includes radio talk shows and speaking live before television cameras. Written communication skills include technical writing, manuals for public interest groups, and articles for the press. Wrote successful grant requests for toxic substances education programs. Cowrote materials on community disclosure of toxic substances for regional workshop and followup. Sacramento President, CASE, LoCal 909 of AFSCME (1915-77); Organizer, Sacramento CED (1978); CED Stop Environmental Cancer roject (1980-81); Deputy Assistant to the Governor for Toxic Substances Control (1981-82). ADMINISTRATION Founded and administered not for profit charitable agency and succesfully obtained IRS letter of determination: ran staff of sixty (including some full time volunteers), worked on budgeting, grant writing. Have had full responsibility for personnel management, including hiring and firing staff. Coordinated statewide networks of community groups that included paid staff not directly under control of my agency or program. Valley Oak Institute (1978-79); Drown for President (1979-80); CED Cancer Project (1980-81). PLANNING - i . Brogram-- Worked with community and public interest groups to conduct needs assessment, produce materials (research and educational) and tools to reach group goals. Co?wrote model ordinance for use by local government concerning toxic substances disclosure . Participated in development of proposed budget item for Office of Public Education and Liaision and other sections of in Governor's 1983 Budget relating to toxic substances program. Clerical and Allied Services Employees (CASE) Local 909 of Sacramento Campaign for Economic Democracy CED Stop Environmental Cancer Coalition Toxics Cleanup Campaign 1981. Conference-- Designed plan and worked with volunteer team to hold? statewide,conference for victims of toxic substances exposure. Conference included nationally known speakers. Participatory workshOps developed a statement of interests and ongoing statewide network. Designed, planned and organized series of regional workshops for communities on information necessary to use local authority to control toxic substances and hazardous materials. Developed and implemented followup to workshOps to enable exchange of ideas between regions. CED Stop Environmental Cancer Project (1981); Governor's Office of Toxic Substances Control (1982). Campaign?- Devised and-implemented_campaign plans for candidate and issue elections, voter registration drives and Voter Rights Act compliance. Past work also includes issue and political . organizing campaigns (other than elections), including facilitation of planning teams working with research elements, and teams of field organizers. Peter McNamee for Yolo County Clerk (1978); Valley Oak Institute for Voter Participation (1978-79): John Means for City Council (1979); Brown for President Campaign (1979-80); Toxics Cleanup Campaign (1981): Governor's Office of Toxic Substances Control. CAMPAIGN ORGANIZATION AND MANAGEMENT Over five years of experience directing political campaigns, including candidate management and scheduling: voter behavior analysis, targetting and polling activities: volunteer recruitment and coordination; direct mail; canvass coordination, GOTV and field organization. Have'acted as consultant for many local campaigns, and developed and conducted training workshops. Brown for Governor (1973?74): Tom Hayden for US Senate, 2 Sacramento Coordinator (1975); Yes on 141 Campaign Staff {1976); Manager, Peter McNamee for Yolo County Clerk Campaign (1978); Manager, Jane Dolan for Butte County Supervisor (1978): Manager, Stop the Coal Power Plant, Butte County (1978); Manager, John Means for Bakersfield City Council (1979); area Coordinator and Staff Organizer, Brown for President (1979780). MICHAEL E. .3 2700 a Street 3 (up Sacramento, CA 95816 a .Qk: _ff?'i ,g (916) 446?7127 [ff asses or was 11va COMMUNITY ORGANIZ ING Ten years of experience in building and working with community groups; conducting needs assessment, facilitation, training in organizational and political skills, leadership building, grass roots fundraising and coalition building, Some roles included strong advocacy components (as Sacramento President of CASE, acted as shop steward on clerical worker grievances, sat on Tri- Counties Central Labor Council}. Role as Coordinator of Organizing included direction of other community organizers, as well as self-directed community groups. Indo-China Information Project (1971?72): Sacramento President, CASE, Local 909 of AFSCME (1975?77); United Farmworkers Union (1976); Sacramento CED (1978); Chemical Action Neighborhood Association (1980); McColl Dump Committee (1980); Coordinator of Organizing, CED Cancer Project (1980-81). MEDIA AND PUBLIC RELATIONS Six years of experience in working with the press (electronic and print), drafting press releases and designing information packets, organizing press conferences and events. Experience includes radio talk shows and speaking live before television cameras. Written communication skills include technical writing, manuals for public interest groups, and articles for the press. Wrote successful grant requests for toxic substances education programs. Cowrote materials on community disclosure of toxic substances for regional workshop and followup. Sacramento President, CASE, Local 909 of AFSCME (1975-77); Organizer, Sacramento CED (1978); CED Stop Environmental Cancer roject (1980-81); Deputy Assistant to the Governor for Toxic Substances Control (1981-82). ADMINISTRATION Pounded and administered not for profit charitable agency and succesfully obtained IRS letter of determination; ran staff of sixty (including some full time volunteers); worked on budgeting, grant writing. Have had full responsibility for personnel management, including hiring and firing staff. Coordinated statewide networks of community groups that included paid staff not directly under control of my agency or program. 1 Valley Oak Institute (1978-79); Brown for President (1979-80); CED Cancer Project (1980-81). PLANNING Worked with community and public interest groups to conduct needs assessment, produce materials (research and educational) and tools to reach group goals. Co-wrote model ordinance for use by local government concerning toxic substances disclosure . Participated in development of proposed budget item for Office of Public Education and Liaision and other sections of in Governor's 1983 Budget relating to toxic substances prOgram. Clerical and Allied Services Employees (CASE) Local 909 of Sacramento Campaign for Economic Democracy (CED) (1979); CED Stop Environmental Cancer Coalition Against'deTC?WEste Toxics Cleanup Campaign 1981. anferenge~- Designed plan and worked with volunteer team to hold statewide conference for victims of toxic substances exposure. Conference included nationally known speakers. Participatory workshops developed a statement of interests and ongoing statewide network. Designed, planned and organized series of regional workshops for communities on information necessary to use local authority to control toxic substances and hazardous materials. Developed and implemented followup to workshops to enable exchange of ideas between regions. CED Stop Environmental Cancer Project (1981); Governor's Office of Toxic Substances Control (1982). Campaign-- Devised and implemented campaign plans for candidate and issue elections, voter registration drives and Voter Rights Act compliance. Past work also includes issue and political organizing campaigns (other than elections), including facilitation of planning teams working with research elements, and teams of field organizers. Peter McNamee for Yolo County Clerk (1978); Valley Oak Institute for Voter Participation (1978-79); John Means for City Council (1979); Brown for President Campaign (1979?80); Toxics Cleanup Campaign (1981); Governor's Office of Toxic Substances Control. CAMPAIGN ORGANIZATION AND MANAGEMENT Over five years of experience directing political campaigns, including candidate management and scheduling; voter behavior analysis, targetting and polling activities; volunteer recruitment and coordination; direct mail; canvass coordination, GOTV and field organization. Have acted as consultant for many local campaigns, and developed and conducted training workshOps. Brown for Governor (1973-74); Tom Hayden for US Senate, Sacramento Coordinator (1975); Yes on 141 Campaign Staff (1976); Manager, Peter McNamee for Yolo County Clerk Campaign (1978): Manager, Jane Dolan for Butte County Supervisor (1978); Manager, Stop the Coal Power Plant, Butte County (1978); Manager, John Means for Bakersfield City Council (1979); Area Coordinator and Staff Organizer, Brown for President (1979-80). env?ironmentol OCTIOH foundation 72-1 Dupont Circle Washington. DC. 20036 Board at Directors Walter Buardman Former Nature ConservarIr-y Gall Harmon Hurrmm Ii Wows Karim-mu: Fummr Urraclor. Umv or Occupnrrowr Hearth Program Overrun Resedmh Drreclnr, for Southern Sgt)? SHar Pohrmat Drrecror Solar Lobby Jerry Powell Marmomg Partner Resource (arcing-want)? Advisory Board qunnm Dunn of Graduate Srudnes Urlw n! Hemrwr Boom State and or"! 1 adders-mp Prruecr Hams Arum-?cans for Han-I Henderson Author. Volume. of Me ?drlur full- i? ?Hulls-AH [Lu I..r 1. AthCIdqu) ?Hess-r; Vu'rr I'rrmn?hnrl? ?Nth-r} Arm: Workms ?rm. mm {mm In: Pumu Luums Policy Adwsm or Hie Emm Anthony Housman Urruclor In.? for Pubhc Proiects (202] 659?9682 Energy 120216594130 Waste and TOXIC Substances [90212964570 "Mr" June 17, 1983 Dear Diane: Thank you for your interest in our "peermatch" assistance program. Peermatching means taking a well? informed, eXperienced citizen activist from one group and sending him or her to consult with another group facing a problem familiar to that consultant. EAF has received funding to support a small number of peermatches in the area of waste and toxic substance issues. Specific areas in which assistance is available are listed on the enclosed application form. While EAF will subsidize travel and eXpenses, we ask that the requesting group donate something to offset costs. The peermatch consultant will receive no fee for his/her services. We have identified citizens eXperienced in each of the 13 areas to consult with groups chosen by EAF to receive peermatch assistance. Not all groups requesting a peermatch will receive one but for all requests, some kind of assistance will be offered, whether it be materials, resources, names of experts, or strategic advice. For the citizen peermatching program to be most effective, we need to have very specific infor? mation about your problem and/or what you wish to accomplish. The data you provide on the enclosed application form will help us determine whether we have a citizen consultant who can address your needs. If_you age chosen for a consultation, we will also ask that you complete a very brief evaluation form within the month following your consultant's visit. (Your consultant will also complete an evaluation.) You will hear from us within a week after we receive your application. If you are chosen for a peermatch, we will tell you about your citizen consultant and ask that you contact them directly to make arrangements. We will also be in touch with them to discuss your Situation. and to finalize details regarding reimbursement and evaluation. you out through this We look forward to I hope we can help rather unique program. hearing from you. Sincereiy, 1 . 4/ . Durso-Hughes