Tittabawassee River Watch Editorial
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07/25/07 DEQ Director responds to Saginaw News editorial
I was disappointed to read The Saginaw News editorial that criticized the
progress being made by the Department of Environmental Quality to move the
dioxin cleanup in the Midland and Saginaw areas forward. ("Finally, EPA is
flexing muscle," July 5)
Much of the work done over the past one to two years has focused on gathering an
immense amount of data, and while this work may not be noticeable to the public
on a daily basis, it is absolutely vital in helping our agency and Dow Chemical
Co. understand the scope of the contamination problem and how we can best
address it.
The U.S. Environmental Protection Agency recently did issue removal orders to
Dow, effectively telling the company that it needs to accelerate plans to remove
some of the most highly contaminated areas in the Tittabawassee River. What was
missed in the editorial, however, was that this would not have been possible
without the work already completed by the state.
In fact, the work that began this month to remove a section of that contaminated
sediment from the river already was scheduled to begin prior to EPA's orders.
As the editorial suggests, Dow did submit a cleanup plan Dec. 1, 2005, that was
intended to provide the next steps in the cleanup process. Despite the state DEQ
providing Dow with substantial detailed guidance on exactly what needed to be
addressed, its proposal was found to be so deficient by both the Department of
Environmental Quality and EPA that we simply had to request an entirely new
cleanup plan. Dow's plans lacked detail in determining the size and scope of the
contaminated area, the necessary follow-up investigations and did not even
address human health risk assessment studies. Furthermore, the company's plan
provided a schedule that would not have remediation begin until 2017 even under
the best case scenario. Clearly, this was unacceptable to both the DEQ and EPA,
and the major revisions that would be required were clearly detailed in the
DEQ's 43 pages of comments sent back to Dow.
Again, it was not a simple "no" as the editorial stated.
Rather than wait for a new work plan and miss the 2006 sampling season, the DEQ
required Dow to submit sampling plans for the Upper Tittabawassee and the city
of Midland. A process was approved quickly and generated 3,800 samples that were
analyzed for dioxins and furans within the floodplain and river sediments and
400 samples from the city of Midland. This is the process that ultimately led to
the cleanup actions that began this month, and the investigation of the next 11
miles of the Tittabawassee River and floodplain will continue this summer.
The DEQ and Dow have co-hosted quarterly community meetings where all of this
information has been presented to the public, and we would welcome your
assistance in sharing this information with those who cannot attend. The DEQ
intends to continue our work with the local community, Dow and the EPA as we
make meaningful progress on this complex issue. v
Steven E. Chester
Director, Michigan Department of Environmental Quality.