Soil Replacement Frequently Asked Questions (FAQ)
Now that you have an overview of the work that Dow will undertake to resolve the soil contamination issue, you may have some questions about the implementation of the project. Below are some frequently asked questions.
Q: What is dioxin, and why is it in the soil on my property?
A: Dioxins are a family of chemicals comprising 75 different types of dioxin compounds and 135 related compounds called furans. They are unintended by-products of certain industrial processes and also occur due to activities such as backyard burning of household trash, and natural events such as forest fires.
Dioxin contamination in the City of Midland is the result of airborne emissions from past waste management practices at Dow. Emissions released into the air from incinerators used in the early days of Dow's manufacturing operations contained dioxins, which ended up in the soil downwind of the plant.
Dioxin emissions from Michigan Operations decreased dramatically over the years as processes were modernized. In 1995, Dow committed to reducing dioxin emissions by 90%, which had already been greatly reduced from past operations that contributed dioxin to Midland soil.
Dow's rotary kiln incinerator now enables 99.999% efficiency in eliminating chemical emissions.
Q: What if I do not want to take part in this project?
A: This process is entirely voluntary. Testing and remediation will only take place with the consent of property owners. Property owners will have the option to refuse access to their property. If property owners decide not to participate, funding will be set aside for Dow to complete the work at a later date.
Q: Will residential property owners incur any costs from this project?
A: No, all costs will be incurred by Dow.
Q: How did you determine which residential properties to test for dioxins in the soil?
A: Data previously collected in the Midland area was used to determine where sampling should be conducted. This initial area has been generally defined as the area closest to Dow's Michigan Operations site, north to Eastlawn Drive, west to Rodd Street and east to Waldo Avenue. A smaller area to the southeast of the intersection of Washington and Ashman Streets also will be sampled. The footprint of these areas will be refined as the program is implemented and more sampling information becomes available.
Q: How did you determine that 250 ppt is the appropriate action level?
A: MDEQ is responsible for determining appropriate clean-up levels where corrective action is required, as part of the State's authorization to implement the federal Resource Conservation and Recovery Act (RCRA). This clean up level was developed by MDEQ, in accordance with U.S. Environmental Protection Agency-approved risk assessment procedures, and with input from EPA. Sampling data and bioavailability soil studies conducted in the Midland area were factored into the calculations.
Q: Should I be concerned about my family living on our property before cleanup?
A: No. Risks to human health from dioxins are based on exposure. The action level is based on more exposure than most people will experience. The EPA has said that a small amount of an individual's exposure to dioxin comes from soils. If you are concerned, the MDEQ has recommendations on how to minimize your exposure to contaminated soil.
Q: What will happen to the trees and other features on my lawn if I allow Dow to clean up my property?
A: Dow will work to return lawns and yards to their pre-remedy state. The plan for each property will depend on property-specific circumstances, and will be reviewed with each owner. Dow will conduct cleanup work to remove 12 inches of soil and replace it with new soil in a manner that will preserve mature trees. Dow will also seek to protect unique or ornamental features, whenever possible. Vegetation and plants affected by the removal process will be replaced. The intent will be to make this as easy as possible for homeowners.
Q: Who will be responsible for the maintenance of my new lawn?
A: Dow will work with property owners to maintain new lawns and plants until they are re-established. This may include installing water delivery systems, restoring existing irrigation systems, and paying for watering the lawn and new plants until vegetation is re-established.
Q: Why are you removing only the top 12 inches of soil?
A: Based on studies conducted, the contamination was generally found only in the top 12 inches so that was established as the depth of soil required to be removed and replaced to address the contamination without the need for further sampling.
Q: Where will the contaminated soils go?
A: Since the soils meet nonresidential cleanup criterion, they will be reused on the Michigan Operations site.
Q: How is this project related to the dioxin contamination on the Tittabawassee River and floodplain?
A: These are two different situations requiring very different solutions. The river and floodplain are being addressed through an agreement with EPA that was signed in January 2010. Dow continues to follow the EPA's systematic process of characterization and remediation on the river, segment by segment, as required in the agreement.
Q: Will this resolve the dioxin issue in Midland once and for all? Will Dow have to come clean up my lawn ever again?
A: MDEQ and Dow understand that this plan will resolve the issue of soil contamination on residential properties in the final resolution area.
Q: Will the residents of Midland have a say in how this cleanup plan is implemented?
A: Public engagement is an important part of the process and there will be opportunities for people to comment at various stages. A public information meeting will be held on June 6, 2016.