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Ralph Dollhopf, EPA, 05/31/08, Letter to the editor, Saginaw News

My View: Agencies consider downstream effect of river restoration

by Ralph Dollhopf

Saturday May 31, 2008, 10:00 PM, Saginaw News

The U.S. Environmental Protection Agency agrees with state Rep. Kenneth B. Horn that all parties with a vested interest in cleaning up the pervasive, long-standing dioxin and furan contamination in the Tittabawassee and Saginaw rivers should work together to resolve this complex problem.

The residents who live along these valuable natural resources have been waiting for decades and deserve to finally see real action.

The EPA is working closely with the Michigan Department of Environmental Quality to accelerate the process and help bolster the state's efforts to compel Dow Chemical Co. to clean up the Tittabawassee River.

To be accountable to the public we serve, the EPA must also provide clarity, context and, in a few instances, corrections regarding some issues that were recently raised by Horn in these pages.

In 2006, Dow assured the DEQ that it would clean up three highly contaminated sections of the Tittabawassee River, but in 2007 the company indicated it would not finish by the end of the year. When Dow proposed two more years to finish work on the section near its Midland facility and made no plan to clean up the section six miles downriver, the EPA exercised its authority under Superfund and ordered Dow to complete all three cleanups simultaneously in 2007.

It is important to note that the DEQ and Dow were already planning to remove dioxin-contaminated soil along the 1,600-foot section three miles downriver from Dow's plant before the EPA got involved.

The plan called for Dow to engineer the riverbank to minimize future erosion. The goal was to allow the river to expand up the bank and reduce its energy during high flow periods.

The U.S. Fish and Wildlife Service also provided expert opinion, and its recommendations were incorporated into the work plan. The EPA's order ensured that the work got done.

Horn made the point that "lots of rip-rap" should be used to keep the banks from eroding.

While the EPA agrees that using some rip-rap is warranted, overuse may concentrate the river's energy and cause problems for communities downriver.
The EPA and the DEQ recognize that extensive work needs to be done to stabilize rapidly eroding riverbanks. However, neither agency considers lining the river with rip-rap an acceptable solution.

It is also necessary to clarify that as a matter of fact, 300 majestic, 100-year-old oak trees were not ripped from the ground during the cleanup.

According to Dow's tree inventory, only three of the 419 trees cut down were oaks. The rest were fast-growing and short-lived cottonwoods and ashes, generally considered to be less desirable. It is highly unlikely that many of them were 100 years old since most were small in diameter indicating relatively young ages.

Certainly, the EPA realizes it is unfortunate that even one tree was cut down, and that is why Dow was required to plant 430 new trees.

The Fish and Wildlife Service recommended that Dow replace the trees with a greater variety of native species because diversity makes the area less susceptible to blight or infestation.

Dow also replaced groundcover in the area with native grasses, an improvement requested by the Natural Resource Trustees.

The EPA could not agree more with Horn that future work should be accomplished in a way that does the least damage possible to the natural beauty of the rivers. The EPA and the DEQ are working together to make sure that even greater care is taken in the future to protect existing vegetation and, when possible, enhance the habitat with natural bank stabilization methods.

Ralph Dollhopf is associate director of the U.S. Environmental Protection Agency's Region 5 Superfund Division in Chicago.

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