EPA: Commentary on Dow Chemical and
other local issues
01/08/11 EPA testing of local drinking
water complete
EPA has completed its water sampling from
the drinking water systems for Midland, Saginaw and Bay City. Sampling was
done in response to some community concerns that U.S. Army Corps of
Engineers navigational dredging in the Saginaw River might stir up
contaminants that could move downstream and affect drinking water. EPA took
baseline samples in 2009 while no dredging was occurring, and again in 2010
while the Corps of Engineer’s dredging was underway. EPA tested for a wide
range of chemicals including dioxins, furans, volatile organics,
semi-volatile organics PCBs, pesticides and metals. A comparison of the
baseline sampling results to the sampling results for when dredging was
underway do not show a difference in water quality as a result of dredging.
The results from both years were below EPA and Michigan DNRE’s standards for
drinking water safety.
More than 180 compounds were analyzed for
in each sample. Most compounds were not detected in any sample.
Sample results were compared to the U.S.
EPA National Primary Drinking Water Regulations Maximum Contaminant
Levels (MCLs) established under the Safe Drinking Water Act. No
contaminants were detected at concentrations exceeding the MCLs.
A variety of other organic and inorganic
contaminants were detected in all samples at low levels. Because MCLs
are not established for all contaminants, sample results also were
compared to Michigan's Part 201 Residential and Commercial 1 Drinking
Water Criteria (Part 201 Criteria). Although the Part 201 Criteria are
applicable to groundwater, these benchmarks were evaluated. None of
these detected compounds exceeded the Part 201 Criteria.
11/19/09 EPA says public
drinking water does not have high levels dioxin
The EPA has announced that repeat testing found no dioxin or furan
contamination in the public drinking water taken from the Saginaw Bay. The
first round of testing for dioxin and furans had to be rejected because of
contaminated laboratory equipment. This initial sampling was conducted to
establish a baseline against which to compare data that will be collected at a
future date during dredging activities
in the Saginaw River. Residents requested the sampling because of
the chance that dioxin laden sediments from the dredging might be drawn into the
public water inlets.
Satellite
views of the bay show a large plume of what looks like river sediment extending
from Bay city and up to the area near Whitestone Point where Saginaw draws it's
water. The EPA intends to resume testing in 2010 once dredging on the Saginaw
River resumes. Note that the Saginaw Bay sediment has been found to
contain high levels of dioxin and furans and will be further investigated as
part of the
proposed EPA and Dow's cleanup settlement process.
Below is the original press release from July and a list of chemicals tested
(click on image):
In
July 2009, the United States Environmental Protection Agency (U.S. EPA) tasked
the Weston Solutions, Inc. (WESTON®), Superfund Technical Assessment and
Response Team (START) to conduct water sampling at three municipal water supply
facilities (Facilities) located in Arenac, Midland, Saginaw, and Bay Counties in
Michigan because of stakeholder concerns about potential re-suspension of
contaminants from navigational dredging into the public drinking water supply.
On July 28, and 29, 2009, WESTON START mobilized to the Facilities to conduct
baseline water sampling. This sampling was conducted to establish a baseline
against which to compare data that will be collected at a future date during
dredging activities in the Saginaw River. At the time of baseline sampling,
dredging activities had been suspended for over 2 weeks. Major findings from the
baseline water sampling include:
• More than 180 compounds were analyzed for in each sample. Most compounds
were not detected in any sample. • Sample results were compared to the U.S. EPA National Primary Drinking Water
Regulations Maximum Contaminant Levels (MCLs) established under the Safe Weston
Solutions of Michigan, Inc. • Furans were detected in all of the environmental samples, as well as in the
blank samples (not source water) at similar concentrations, indicating that the
furans are most likely from laboratory contamination. U.S. EPA has determined
that the furan data are not usable as a result of this laboratory contamination.
Therefore, U.S. EPA is arranging to resample the Facilities for furans. • A variety of other organic and inorganic contaminants were detected in all
samples at low levels. Because MCLs are not established for all contaminants,
sample results also were compared to Michigan’s Part 201 Residential and
Commercial 1 Drinking Water Criteria (Part 201 Criteria). Although the Part 201
Criteria are applicable to groundwater, these benchmarks were evaluated. None of
these detected compounds exceeded the Part 201 Criteria.
10/06/09 EPA water testing of municipal
water supply facilities for Furans must be repeated
In July 2009, the United States Environmental Protection Agency (U.S. EPA)
tasked the Weston Solutions, Inc. (WESTON®), Superfund Technical Assessment and
Response Team (START) to conduct water sampling at three municipal water supply
facilities (Facilities) located in Arenac, Midland, Saginaw, and Bay Counties in
Michigan because of stakeholder concerns about potential re-suspension of
contaminants from navigational dredging into the public drinking water supply.
On July 28, and 29, 2009, WESTON START mobilized to the Facilities to conduct
baseline water sampling. This sampling was conducted to establish a baseline
against which to compare data that will be collected at a future date during
dredging activities in the Saginaw River. At the time of baseline sampling,
dredging activities had been suspended for over 2 weeks. Major findings from the
baseline water sampling include:
• More than 180 compounds were analyzed for in each sample. Most compounds
were not detected in any sample. • Sample results were compared to the U.S. EPA National Primary Drinking Water
Regulations Maximum Contaminant Levels (MCLs) established under the Safe Weston
Solutions of Michigan, Inc. • Furans were detected in all of the environmental samples, as well as in the
blank samples (not source water) at similar concentrations, indicating that the
furans are most likely from laboratory contamination. U.S. EPA has determined
that the furan data are not usable as a result of this laboratory contamination.
Therefore, U.S. EPA is arranging to resample the Facilities for furans. • A variety of other organic and inorganic contaminants were detected in all
samples at low levels. Because MCLs are not established for all contaminants,
sample results also were compared to Michigan’s Part 201 Residential and
Commercial 1 Drinking Water Criteria (Part 201 Criteria). Although the Part 201
Criteria are applicable to groundwater, these benchmarks were evaluated. None of
these detected compounds exceeded the Part 201 Criteria.
(CHICAGO - Sept. 30, 2009) U.S. Environmental Protection Agency's Office of
Research and Development has completed its review of a dioxin exposure study
conducted by the University of Michigan in the Midland-Saginaw, Michigan
area. EPA found the study was conducted well and provided useful,
scientifically credible information. However, the study is of limited value
to help EPA fully evaluate human exposure to levels of dioxin in the
Tittabawassee River and Saginaw River and Bay.
EPA's
review was conducted under the dioxin science plan announced by
Administrator Lisa P. Jackson this past May. The University of Michigan
Dioxin Exposure Study (UMDES) was conducted in response to community
concerns that dioxin compounds from the Midland-based Dow Chemical Co. had
contaminated the city and surrounding areas. The University received
financial support for the UMDES from Dow through an unrestricted grant.
Primary data collection was completed in 2004-2005 and the analysis of study
results continues.
EPA's review identified several significant issues that limit the utility of
the UMDES results:
* The study did not include children, who tend to have higher exposures to
contaminants because they have more contact with, and ingestion, of soils
and dusts.
* It is unclear if the study included a sufficient number of properties with
highly-contaminated soils. Such properties can be found in the
Midland-Saginaw area.
* It is uncertain how well the study represented people who participate in
activities that could lead to elevated dioxin exposures, such as eating
local fish and game with elevated dioxin levels.
Additionally, the UMDES included no health status information on the people
surveyed. Thus, the UMDES data do not support analysis of the association
between dioxin blood levels and possible health effects. Understanding these
issues is critical when evaluating associations between exposure and blood
dioxin levels in sensitive populations, including children. Also, the site
specific data collected by the study will not be relevant as EPA revises its
national interim preliminary remediation goals for dioxin in soil.
The study included more than 900 participants and provided estimates of the
distributions of dioxin concentrations in blood, soil and dust in the
Midland-Saginaw area as well as a reference area for comparison 100 miles to
the south. EPA's review found that the UMDES was well-suited to identify
patterns of serum dioxin, furan and PCB levels among adults. Among the
study's other findings: people living the Midland-Saginaw area have higher
blood dioxin levels than those in the reference area and national averages,
and that properties in Midland-Saginaw tend to have higher soil dioxin
levels than in the reference area. As has been found in other studies, it
also found that higher blood dioxin levels were associated with demographic
factors such as increased age, dietary choices and being overweight.
Representatives from EPA's Office of Research and Development and Office of
Solid Waste and Emergency Response will hold a public meeting in the
Midland-Saginaw area in late October to discuss the UMDES review. More
information will be announced soon.
07/23/09 Recent EPA updates:
Municipal Water Sampling of areas drinking water sources
Municipal
Water Sampling
Community members have raised questions about U.S. Army Corps of Engineers
navigational dredging in the Saginaw River. The concern is whether sediments
re-suspended during the dredging will move downstream into Saginaw Bay and
affect drinking water intakes. In response to this concern EPA agreed to testing
at the water plants for Midland, Saginaw and Bay City. (Midland and Saginaw
share a water intake in Saginaw Bay, but have separate drinking water treatment
plants.)
EPA is planning two rounds of sampling. One round of sampling will be
collected during a period of no dredging activity and the second round will be
collected while dredging is underway. Samples will be collected of both the
water entering the municipal water treatment systems and of the treated water
sent to the communities. EPA plans to analyze the samples for a wide range of
chemicals including dioxins, furans, volatile organics, semi-volatile organics,
PCBs, pesticides and metals.
EPA is scheduled to collect the first round of samples the week of July 27,
2009. These samples will be collected during a period of no dredging activity
since the Corps of Engineers stopped dredging the week of July 6, 2009. EPA's
schedule for collecting samples while dredging is underway is dependent upon
when the dredging resumes. EPA will provide an update when the schedule for
collecting theses samples has been finalized.
TRW Note: It's not just for Dioxin.
Click on picture above for other
contaminants of concern
03/03/09 EPA to oversee Dow dioxin cleanup at
Saginaw Township's West Michigan Park
CONTACT:Mick Hans, 312-353-5050, <mailto:hans.mick@epa.gov>hans.mick@epa.gov
Anne Rowan, 312-353-9391, <mailto:rowan.anne@epa.gov>rowan.anne@epa.gov
(MDEQ) Robert McCann, 517-241-7397
FOR IMMEDIATE RELEASE
No. 09-OPA024
EPA to oversee Dow dioxin cleanup at Saginaw Township's West Michigan Park
CHICAGO (March 3, 2009) - U.S. Environmental Protection Agency Region 5 said
today that Dow Chemical Co. has agreed to conduct another Superfund removal
action to clean up dioxin contamination in the Tri-Cities area. The new
project, at Saginaw Township's West Michigan Park and nearby properties, is
set to begin in mid-April. The work is expected to be finished and the park
reopened by early June.
West Michigan Park is three miles upstream from the confluence of the
Tittabawassee and Shiawassee Rivers. Historically, the park and the
neighborhood around the park have flooded a number of times, resulting in
dioxin-contaminated river sediment being deposited in the area.
Dow will provide EPA with a detailed work plan for the cleanup by March 13.
If EPA approves the plan, it will oversee Dow's cleanup of the 5-acre park.
The cleanup includes excavation of soil in most areas and backfill with
clean soil, paving of the park's driveway and parking lot, and elevation of
playground equipment to avoid recontamination if the area floods again. The
work will also address contamination hot spots at a condominium complex to
the west and in several residential lots east of the park.
"The West Michigan Park cleanup marks the sixth Superfund removal of dioxin
contamination EPA has supervised in the Tri-Cities area since July 2007,"
said Acting Regional Administrator Bharat Mathur. "We'll be devoting extra
attention to the areas of the park where children play."
"Thanks to our combined efforts we continue to see progress made in moving
the overall cleanup efforts forward," said Michigan Department of
Environmental Quality Director Steven E. Chester. "The cleanup at West
Michigan Park is an important step in this process, and we are looking
forward to its reopening this summer once the work is complete."
Dow Midland facility is a 1,900-acre chemical manufacturing plant. Dioxins
and furans are byproducts from the manufacture of chlorine-based products.
Past waste disposal practices, emissions and incineration at Dow have
resulted in on- and off-site dioxin and furan contamination.
02/12/08 EPA's response to OIG's
evaluation of Superfund Alternative Site policy
EPA's response
to the Office of the Inspector General (OIG) report dated June 2007.
"Please be aware that based on EPA's attached response and on EPA's
"Evaluation of the Superfund Alternative Approach implementation", the OIG
closed their report on this matter."
11/7/08 Riverside Boulevard Cleanup status The MDEQ meeting 11/7/08 revealed that
Riverside Boulevard
residents are satisfied
with cleanup so far. This
neighborhoodis located near
the spot where
the initial dioxin contamination was
revealed to
the public back in 2002 after a Lone Tree Council FOIA demonstrated
that the former MDEQ administration was covering up the discovery.
View the "Long Shadow" documentary for a close-up of the early days in
this saga including interviews with a Riverside resident who regularly
consumed contaminated eggs from his free range chickens.
Recent testing evidently confirmed
previously reported high levels in the yards, roads, and homes of
residents. In July 2008, the
EPA stepped in forced Dow to initiate an immediate cleanup. River Boulevard is
one of the last dirt roads in Saginaw County and provides the only access to
the residents homes. According to the MDEQ, dioxin levels of 10,000
ppt where discovered in the dusty and often muddy road. The EPA has
since paved it as part of the remediation. This area is prone to
repeated flooding, it will be interesting to see how future contamination is
handled.
07/23/08 New EPA Midwest regional
administrator appointed
The U.S. Environmental Protection
Agency has a new regional administrator. Federal administrator Stephen
L. Johnson announced Monday that he appointed Lynn Buhl, a deputy assistant
administrator in the Office of Enforcement and Compliance Assurance at EPA
headquarters, to the administrator position.
Buhl will replace Mary Gade, who resigned May 1 amid internal fights over
dioxin contamination near Dow Chemical Co.'s headquarters in Midland, Mich.
As a Bush political appointee Buhl's tenure may be limited to 6 months
depending upon the elections in November. Will recent progress on the
Tittabawassee River flood plain clean up come to a screeching halt?
Will Buhl develop a conscious as Mary Gady seemingly did so last year?
Will Dow have any influence on Buhl's actions? Only time will tell.
Click here for article from
Grist Magazine concerning Buhl and her past.
07/15/08 EPA says Dow agrees to clean up
dioxin contamination in Riverside neighborhood
Dow Chemical to clean up dioxin contamination in Saginaw's
Riverside Boulevard neighborhood
CHICAGO (July 15, 2008) - U.S. Environmental Protection Agency Region
5 today announced an agreement with Dow Chemical Co. that requires the
company to clean up dioxin contamination in the Riverside Boulevard
neighborhood of Saginaw, Mich. Construction work in this neighborhood
on the Lower Tittabawassee River is expected to begin in late July and
continue through the fall.
EPA's data shows unacceptably high levels of dioxin contamination in
yards, the unpaved Riverside Boulevard roadway and in the interior of
some homes.
Last April, EPA took soil samples at the residential properties
following discussions and consultation with Michigan Department of
Environmental Quality and Michigan Department of Community Health.
"We are pleased that Dow and EPA were able to reach agreement on the
terms of this cleanup," said EPA Region 5 Superfund Division Director
Richard Karl. "EPA will continue to oversee all aspects of the work
along Riverside Boulevard in close coordination with MDEQ and MDCH."
The agreement, called an administrative order on consent, includes:
* Excavation of residential yards, then backfilling with clean soil.
* Interior cleaning of homes.
* Remediation of unpaved surfaces on Riverside Boulevard.
Dow's Midland facility is a 1,900-acre chemical manufacturing plant.
Dioxins and furans are byproducts from the manufacture of chlorine-based
products. Past waste disposal practices, emissions and incineration at
Dow have resulted in on- and off-site dioxin and furan contamination. A
copy of the administrative order on consent and other documents are at
http://www.epa.gov/region5/sites/dowchemical.
Sent by the U.S. Environmental Protection Agency · 1200 Pennsylvania
Avenue NW · Washington DC 20460 · 202-564-4355
06/01/08 EPA
responds: Chamber of Commerce statements have little factual basis
As posted in the Saginaw News "My View" column Saturday June 1, 2008
Assumptions without research lead to misinformation
The U.S. Environmental Protection Agency shares the
view recently
expressed in these pages by Bob Van Deventer of the Saginaw County Chamber
of Commerce that protecting the health and safety of residents in the
Saginaw Valley environment is a top priority.
However, Van Deventer's presentation of the issues concerning dioxin
contamination in the Tittabawassee River system leaves out several important
details.
Van Deventer claims that "not one individual has ever been ill because of
the effects of furans/dioxins" in the river. This is a striking
oversimplification. To EPA's knowledge, no specific study has ever been
conducted that supports this statement.
Certainly, in the case of dioxin, delaying action until people actually
suffer clinical health effects would be irresponsible.
Considerable evidence shows that adverse health effects are possible and
may begin to occur when individuals are exposed at levels not much higher
than those expected for the general population. Also, available data show
elevated dioxin levels in soils near many private homes as well as in local
game and fish in the Saginaw Valley.
Another Van Deventer claim, that "wildlife along the Tittabawassee River
is flourishing," has little factual basis. The EPA has never received a work
plan for an ecological risk assessment by Dow or Michigan State University
researchers that meets the agency's baseline requirements. Furthermore, the
MSU wildlife studies to date have not undergone peer review.
Finally, in discussing the University of Michigan's preliminary results
from its dioxin exposure study, Van Deventer states that it "clearly showed
very little difference in dioxin blood levels" between Tittabawassee River
floodplain residents and a test group not living in the area. Again, the U-M
study has yet to be fully peer-reviewed.
To conclude anything definitive at this early date would seem to be an
attempt to limit further discussion. A final report is not expected until
late this year at the earliest.
The studies under way clearly demand the full scrutiny of the scientific
and academic communities. The agencies also fully support the concept of
new, additional studies of human and ecological health in the area by
qualified researchers. To do anything less is to short-change the residents
and the health of the Saginaw Valley.
Mario M. Mangino is a toxicologist with the U.S. Environmental
Agency's Region 5 in Chicago.
06/1/08 EPA: Agencies
consider downstream effect of river restoration
As posted in the Saginaw News "My View" column Saturday June 1, 2008, 2-3
months after it was submitted in response to Horn's My View article of 2/29/08
Agencies consider downstream effect of river restoration
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.
05/29/08 EPA to seek immediate
cleanup of dioxin in riverside residential neighborhood
CHICAGO (May 28, 2008) - Officials from U.S. Environmental Protection Agency
Region 5, Michigan Department of Environmental Quality and Michigan
Department of Community Health met with residents of the Riverside Boulevard
neighborhood in Saginaw last night to discuss results of recent sampling of
dioxin-contaminated soil in the area.
Soil from residential properties in an area along the Lower Tittabawassee
River was recently sampled and analyzed by EPA and evaluated in
collaboration with MDEQ and health officials. While final data is still
coming in, preliminary results show properties with unacceptably high levels
of dioxin contamination.
EPA has notified Dow Chemical Co. of the situation and will meet with the
company and MDEQ to discuss potential response actions. EPA and Dow
successfully negotiated the terms of four hot spot cleanup projects
implemented by Dow on the Tittabawassee and Saginaw Rivers downstream of its
Midland, Mich., facility last year.
"This cleanup is a high priority as this dioxin contamination is in a
residential neighborhood," said EPA Region 5 Superfund Division Director
Richard Karl. "We will continue to work with the state agencies to evaluate
results of sampling from other residential areas and consider appropriate
actions.
The recent sampling project was prompted by Dow's February 2008 disclosure
to the agencies of an elevated dioxin level found in a residential soil
sample collected by Dow in November 2007. Under the company's Michigan
operating license which requires Dow to conduct corrective action for
historic releases, MDEQ has been requiring Dow to conduct floodplain soil,
riverbank and sediment sampling in and along the Tittabawassee River
downstream of Midland.
Dow's Midland facility is a 1,900-acre chemical manufacturing plant. Dioxins
and furans are byproducts from the manufacture of chlorine-based products.
Past waste disposal practices, emissions and incineration at Dow have
resulted in on- and off-site dioxin and furan contamination.
# #
05/01/08 EPA top Midwest administrator
forced out by Bush because of enforcing Dow cleanup
Mary Gade, based
in Chicago, says Bush administration made her quit over Dow
Chemical case
By Michael Hawthorne Chicago Tribune reporter May 1,
2008
The Bush administration forced its top environmental regulator
in the Midwest to quit Thursday after months of internal
bickering about dioxin contamination downstream from Dow
Chemical's world headquarters in Michigan.
snip: For the past year, Gade has
been locked in a heated dispute with Dow about long-delayed
plans to clean up dioxin-saturated soil and sediment that
extends 50 miles beyond its Midland, Mich., plant into Saginaw
Bay and Lake Huron.
snip: Though regional EPA
administrators typically have wide latitude to enforce
environmental laws, Gade drew fire from officials in Washington
last month after she sent contractors to test soil in a Saginaw
neighborhood where Dow had found high dioxin levels.
snip:"There is no question this is
about Dow," Gade said. "I stand behind what I did and what my
staff did. I'm proud of what we did."
Harken
back to the 1980's and Dow interference with EPA. For months
now Dow has been reaching out to EPA headquarters shopping
around for a better deal, a quick-out or an opportunity to
skirt the law. Same thing they've been doing for thirty plus
years.
Looking forward to the
ongoing investigative
story by the Tribune. Go to the link and watch the video clip of
Joy and Lloyd Cooper who live on the Tittabawassee River in the
neighborhood that drew Mary Gade so much fire.
EPA, MDEQ to sample Saginaw residential area for
dioxin contamination
(Chicago- Apr. 2, 2008) U.S. Environmental Protection Agency
Region 5 and Michigan Department of Environmental Quality
have begun screening a residential neighborhood in Saginaw
Mich., for dioxin-contaminated soil.
An estimated 10 residential properties in an area along the
Tittabawassee River will be sampled. Small plugs from up to
36 inches below surface level will be sent for laboratory
analysis.
Analysis may take two to three weeks. Once the data is
returned, EPA and MDEQ, along with Michigan Department of
Community Health, will consider a range of options,
including more comprehensive sampling in the area and
possible cleanup actions.
"Residential soil contamination is a serious matter," said
Associate Superfund Director Ralph Dollhopf. "At this time
of year, children are playing outside again and families are
planning gardens. If action is needed, this project will
ramp up very quickly."
The investigation aims to determine the extent of dioxin
contamination present in the neighborhood. The project was
prompted by Dow Chemical Co.'s February 2008 disclosure to
the agencies of an elevated dioxin level found in a
residential soil sample collected by Dow in November 2007.
Under the company's Michigan operating license, MDEQ
required Dow to conduct certain soil and embankment sampling
along the Middle Branch of the Tittabawassee River.
Dow's Midland facility is a 1,900-acre chemical
manufacturing plant. Dioxins and furans are byproducts from
the manufacture of chlorine-based products. Past waste
disposal practices, emissions and incineration at Dow have
resulted in on and off-site dioxin and furan contamination.
01/04/08
EPA
Terminates negotiations with Dow on river cleanup
Maybe there is hope yet. In our
previous update (see 12/22/07 entry below) , the EPA negotiations with Dow
seemed to be following a familiar pattern with a predicted outcome.
Today's EPA Press Release (below) may indicate a fundamental shift in the
right direction.
Dow
influenced Local and State politiciansare preventing the
MDEQ and it's hard working staff from accomplishing much other
than a few public relations "hotspot" cleanup stunts in a long and
protracted process that would take decades to resolve the entire watershed.
In contrast, recent
EPA comments indicate they are ready to cut through all the bull
and prepared to force Dow to come up with a comprehensive plan that protects
human health and the environment. Only time will tell.
What we need is a cleanup plan that immediately addresses the
entire 50 mile river system and the floodplains that surround it.
What's next? Speculation ( that's all it is at this point since the
negotiations are closed to the public) is that the EPA may just hire
contractors to perform the necessary cleanup and send the bill to Dow.
We doubt Dow would just roll over and pay, a Federal lawsuit may be in the
works and Dow's operating license could be in jeopardy. We hope
it does not come to that, maybe Dow will decide to start to play ball in
earnest.
---------
(Chicago, Ill. - Jan. 4, 2008) U.S. Environmental Protection Agency
Region 5 today stopped its negotiations with Dow Chemical aimed at a
settlement to conduct a study and interim cleanup actions for dioxin
contamination in the Tittabawassee River system.
"EPA does not believe that the deal Dow is offering goes far
enough," said Ralph Dollhopf, Associate Director for the Superfund
Division of EPA's Regional Office in Chicago. "Key issues that are
paramount for protecting human health and the environment remain
unresolved. EPA simply will not accept any deal that is not
comprehensive."
Last October, EPA called for 60 days of negotiations under
provisions of the Comprehensive Environmental Response, Compensation
and Liability Act, or Superfund. Superfund specifies the process in
which a remedial investigation and feasibility study must be
conducted, as well as the design and execution of a cleanup plan.
Last month, EPA extended its Dec.10, 2007, deadline to resolve
remaining issues and reach a final agreement.
"I am extremely disappointed with this outcome," said Regional
Administrator Mary A. Gade. "EPA approached negotiations with high
hopes and realistic expectations. Our team put in many long hours of
good faith efforts that came to an unfortunate end today. EPA is now
reviewing its options for ensuring that dioxin contamination in the
river system and the Midland area can be fully addressed."
The targeted area begins upstream of Dow's Midland, Mich., facility
and extends downstream to the Saginaw River, its floodplains and
Saginaw Bay in Lake Huron.
Under Superfund, an investigation and study are necessary to
evaluate the nature and extent of hazardous substances, pollutants
or contaminants from a site and assess the risks they present to
human health and the environment. It would also require that enough
data be developed to evaluate a range of cleanup options.
Dow's Midland facility is a 1,900-acre chemical manufacturing plant.
Dioxins and furans are byproducts from the manufacture of
chlorine-based products. Past waste disposal practices, fugitive
emissions and incineration at Dow have resulted in on- and off-site
dioxin and furan contamination.
What
should concern everyone is that on the surface, this process closely
resembles the pattern of the last "negotiation" in 2004 when the Governor
Granholm stopped the transparent public process and went behind closed doors
with Dow. Is this just another replay of 2004/2005? Should we substitute
the abbreviation "DEQ" with "EPA" in the
timeline below? Any one seen
Dave Camp
hanging around the EPA office lately? We hope not, however with negotiations behind closed doors
again, only time will tell.
May 26.
2004 -- A
community meeting sponsored by the City of Midland draws more than 1,500
to the Midland Center for the Arts to hear DEQ Director Steve Chester,
representatives from the city, Dow and the Midland County Health Department
talk about dioxin contamination. Emotions of residents and local
lawmakers are inflamed.
May 27.
2004 --A cleanup plan for the Tittabawassee River and Midland
isn't done yet, but state Department of Environmental Quality
officials vow to have it ready by mid-June.
May 27.
2004 --
Senate & House Bills are
introduced by Sen. Tony Stamas and Rep. John Moolenaar to give polluters
free ride
June 1.
2004 -- Congressman Dave Camp, state Sens. Mike Goschka and Tony
Stamas and state Reps. Jim Howell,
John Moolenaar and Sandy Caul
request
a meeting with Gov. Jennifer Granholm to talk about dioxin.
June 3.
2004 -- State Rep. John Moolenaar recommends cuts in the Department of
Environmental Quality budget, calling the move a
"message
of intent" for a department "out of control." Cuts suggested included a
15 percent reduction in director Steve Chester's salary and the abolishment
of the DEQ's hazardous waste program.
June 5.
2004 -- Congressman Dave Camp, state Sen. Tony Stamas and state Reps.
Mike Goschka and John Moolenaar and Sandy Caul, meet with Gov. Granholm at
Mackinaw Island.
Aug. 29. 2004 -- Residents of the Tittabawassee River flood plain
send a
letter to the governor, lieutenant governor and Chester saying they are
growing increasingly concerned about the inaction of officials and are
questioning their trust in the government.
Sept. 1,2004 -- John Moolenaar says that a meeting
among the concerned parties is planned for Sept. 15 at which he expects a
plan of action to be presented.
Sept. 16, 2004 -- The state Department of Environmental
Quality emerges from negotiations with Dow Chemical Co. not with
an agreement about how to proceed with dioxin cleanup, but with a date.
DEQ spokeswoman said the
parties
plan to reach agreement by Sunday, Oct. 31
January 21, 2005 -- Dow and
DEQ agree on "framework",
not cleanup
January 24, 2005 --
Leading citizens and environmental
groups today
sharply
criticized an agreement between Dow Chemical Company and the
Granholm Administration, saying it fails to deliver a cleanup of dioxin
contamination in the Saginaw Bay basin
Click hereto view the confidential EPA memo detailing Dow's deceptive tactics
accidentally released to the Lone Tree Council as part of a FOIA request.
See 12/7/07 Detroit Free
Press story for an interpretation. Note: there have been two
breaking stories in the last 24 hours, the
whistle blower lawsuit
filed yesterday about Dow submitting flawed data to the MDEQ is unrelated to the
leaked EPA memo above. However they both share a common theme: a sneaky and
unscrupulous Dow Chemical The Detroit Free Press reports (a few snippets)
EPA found state failed to stand up to chemical giant
With the state's complicity, Dow Chemical Co. has delayed cleanup
and misled the public about the dangers of dioxin it dumped decades
ago into rivers downstream of its Midland plant, Environmental
Protection Agency officials charged in a confidential August
internal report.
The memo, obtained by the Free Press, also said Dow impeded state
efforts to force a cleanup, concealed data and studies, tried to
keep documents confidential that should have been made public and
insisted on negotiating cleanup details with Gov. Jennifer
Granholm's office, rather than staff of the state Department of
Environmental Quality. ...
The situation has left people living along the
Tittabawassee and Saginaw rivers frustrated. Their yards
and homes are contaminated with dioxin that continues to
wash onto their land during flooding. ...
Separately from the EPA memo, a high-ranking Dow
employee, whose job was to oversee validation of test
results of soil samples tested for dioxin along the
river, filed a lawsuit in Saginaw County last month
claiming tests by Dow contractors were so flawed that
the laboratory doing the validation rejected them and
then quit, saying it didn't want to continue validation
work for Dow. ...
A revealing memo
The EPA memo accidentally was released within recent
weeks to the Lone Tree Council, an environmental group,
under a Freedom of Information Act request. ...
The memo said that Dow, unlike most companies, has
insisted on direct negotiations with the governor and
with Chester of the DEQ.
The EPA memo also said:
• Dow had done unapproved
studies and collected data without telling regulators.
The DEQ fined the firm $70,000 in January 2006 over
illegal sampling.
• Political figures, including legislators, have been
involved on Dow's behalf, trying to soften standards in
the company's favor.
• Dow tried to make dioxin seem less toxic. The EPA
issued a press release last month rebuking Dow for
statements downplaying the extremely high sample found
in the Saginaw River.
• Dow used a dispute process to make documents
confidential that should not be. The memo itself is one
of those documents. ...
• Under a
grant from Dow and pursuant to an unpublished contract
with Dow, the University of Michigan has conducting a
study of dioxin exposure in the Saginaw Bay watershed.
EPA does not consider the study to be particularly
relevant to the corrective action in this matter and
believes the study was initiated at the request of Dow
in order to downplay the risks of exposure to dioxin
contaminated soils.
Getting to the truth
In her suit, whistleblower Denney
said
the independent laboratory double-checking the dioxin results told
her in November 2006 that the data from Dow's contractor was badly
flawed. ...
Denney told her bosses. A week later, they ordered her to stop
doing any work relating to the data validation.
The lab rejected
the data in a letter Dec. 5, 2006, saying it couldn't validate it.
On Dec. 8, the lab sent Dow a letter terminating its contract,
citing a breakdown in procedures. Denney's suit said Dow submitted
the bad data to the DEQ in February.
"She's been shut out," said Victor Mastromarco Jr., Denney's
attorney.
Click hereto view the whistle blowers suit document
11/16/07
EPA: Dow to clean up dioxin hot spot in
the Saginaw River
CONTACT: Anne Rowan, 312-353-9391, rowan.anne@epa.gov Mick Hans,
312-353-5050, hans.mick@epa.gov
For Immediate Release No. 07-OPA227
EPA: DOW TO CLEAN UP DIOXIN HOT SPOT IN THE SAGINAW RIVER
CHICAGO (Nov.15, 2007) — U.S. Environmental Protection Agency Region 5 and Dow
Chemical Co. of Midland, Mich., today signed a consent order to begin an
emergency
cleanup of a previously unknown dioxin hot spot on the Saginaw River.
Under the order, Dow must dredge dioxin-contaminated sediments in the Saginaw.
Field work must begin immediately with the dredging to be completed by Dec. 15.
“The extremely high level of dioxin found in the Saginaw River and its possible
consequences warrant immediate action,” said Regional Administrator Mary A. Gade.
“Today’s Superfund emergency order requires action now to eliminate an imminent
and substantial threat to human health and the environment.
“ Friday evening, Nov. 9, Dow notified EPA and Michigan Department of
Environmental
Quality of preliminary results of over 1.6 million parts per
trillion (ppt) of dioxin in one
sample of sediment taken from the Saginaw River.
This dioxin concentration is probably
the highest ever found in the Great Lakes.
The sample came from a location a half-mile
below the confluence of the
Tittabawassee and Shiawassee Rivers, roughly adjacent to
Wickes Park in Saginaw.
On Sunday, EPA provided Dow legal notice of its potential liability and the
Agency’s intent
to immediately begin cleanup. Under the Superfund law, EPA gave
Dow the option to
perform the cleanup under EPA oversight. On Monday, EPA and
MDEQ technical experts
surveyed the site and met with Dow to discuss cleanup
alternatives. On Tuesday, Dow
notified EPA that it would agree to perform the
work under an EPA order. ....
Click here to read the "Administrative Settlement Agreement and
Order on
Consent for Removal Action" between DOW and the EPA
11/14/07 EPA responding to Dow's outrageous drops of ink in 55
gallon drum analogy
Would appear EPA did not take lightly Dow's PR spin to down play the
significance of 1.6 million
ppt hot spot in the Saginaw River or the company's
attempt to brush aside their dioxin contaminating
fish and then people who eat the fish:
CONTACT: Anne Rowan, 312-353-9391, <mailto:rowan.anne@epa.gov>rowan.anne@epa.gov
FOR IMMEDIATE RELEASE 07-OPA220
Note to correspondents: More information on new dioxin hot spot in the Saginaw
River
(Chicago, Ill. - Nov. 14, 2007) Recent published statements by a Dow Chemical
Co. spokesman
regarding the company's discovery of another dioxin hot spot in
the Saginaw River may leave the
public with mistaken impressions about the
health concerns related to this finding and exposure
pathways. Comparing a
highly toxic chemical such as dioxin to ink drops in a drum as Dow
recently did,
minimizes the real concern regarding dioxin's toxicity and the very high level
found. ...
(Chicago, Ill. - Nov. 13, 2007) Acting immediately on information
received from Dow Chemical Co. of Midland, Mich., U.S. Environmental
Protection Agency, Michigan Department of Environmental Quality and the
company have begun preliminary emergency removal activities at a
previously unknown dioxin hot spot on the Saginaw River.
Late Friday, Dow notified EPA and MDEQ of preliminary, unvalidated
results of over 1.6 million parts per trillion (ppt) of dioxin in one
sample of sediment taken from the Saginaw River. This concentration is
50 times higher than a 32,000 ppt level, previously the highest found in
the Saginaw River. It is 15 times higher than any dioxin levels found at
hot spots in the Tittabawassee River. This new Saginaw River sample came
from a location a half mile below the confluence of the Tittabawassee
and Shiawassee Rivers, roughly adjacent to Wickes Park in Saginaw.
"EPA has determined that this emergency work should be performed under
an EPA Superfund order," said Regional Administrator Mary A. Gade. "EPA
and MDEQ are working closely together on a thorough and appropriate plan
to remove this hot spot. Moreover, we must be very cautious to make
sure, through laboratory tests, that we determine the extent of this
high level of contamination. It may be only one additional hot spot or
it could cover a larger area."
Dow discovered the latest hot spot during sampling done according to its
own Sept. 14, 2007 work plan, which has not been approved by either EPA
or MDEQ.
As a result of EPA Superfund orders in June 2007, Dow is now wrapping up
the cleanup of three dioxin hot spots in the Tittabawassee River and
should be done by year's end. Those dioxin hot spots along the first six
miles of the Tittabawassee River were contaminated at levels up to
87,000 ppt, far above state and federal action levels. The area is prone
to flooding and erosion which can spread contamination.
Dioxins are highly toxic compounds that pose serious risks to human
health and the environment. EPA's reassessment of the most recent
scientific findings on dioxin indicates that it is a more potent
chemical than previously understood.
For more information about the health impacts of dioxin and eating fish
from the Saginaw River system, members of the public may call the
Michigan Dept. of Community Health at 800-648-6942 and the Agency for
Toxic Substances and Disease Registry at 312-886-0840.
Dow's Midland facility is a 1,900-acre chemical manufacturing plant.
Dioxins and furans come from the production of chlorine-based products.
Past waste disposal practices, fugitive emissions and incineration at
Dow resulted in dioxin and furan contamination both on- and off-site.
Click here for a biased
Dow media spin article released earlier today to preempt
the EPA report.
Local media bought it up hook, line, and sinker.
TV news had
the Dow spinmister John Musser comparing the find to 6 drop in a 55 gallon barrel
and
interviews with fishermen lowering their hook almost directly over the contaminated
area. Both articles are using the term "Dioxin-Like" (assume it was a
sound bite provided
by Dow) in an attempt to downplay the discovery.
Regardless of the "dow-ese" used by
the media, the samples taken near Wickes
park revel dioxin in unprecedented levels and it
is the same Dow DIOXIN found throughout the Saginaw Bay
watershed. Suffice it to say
that this is "sound science"
at it's finest.
Dioxin-Like refers to compounds
from a group of halogenated aromatic hydrocarbons that
have molecules shaped
like TCDD and produce similar toxic effects, such as certain other
chlorinated dibenzo-p-dioxins (CDDs) and certain chlorinated dibenzofurans (CDFs),
polychlorinated biphenyls (PCBs), polybrominated biphenyls (PBBs),
brominated
dibenzo-p-dioxins (BDDs), and brominated dibenzofurans (BDFs).
11/09/07 EPA notifies Dow of clean-air & hazardous waste violations
Chicago, Ill. - Nov. 9, 2007) U.S. Environmental Protection Agency Region 5
today notified
Dow Chemical Co. that it has found potential clean-air and
hazardous waste violations at
the company's Midland, Mich., facility.
EPA issued a finding of violation under the Clean Air Act and a notice of
violation under
the Resource Conservation and Recovery Act. It also issued
requests for information under
both acts.
"The issuance of these notices and requests for information shows that the
agency takes
seriously its responsibility of protecting human health and the
environment," said Regional
Administrator Mary A. Gade. "Our investigation of
this very large facility spanned eight
weeks over a two-year period and included
personnel from EPA's National Enforcement
Investigation Center. Today's actions
are a product of that investigation."
EPA alleges Dow violated the Clean Air Act by, among other things, failing to
follow
regulations aimed at detecting and repairing leaks, as well as failing to
conduct a required
stack test. Dow was also allegedly found to be in violation
of multiple Resource Conservation
and Recovery Act requirements for managing
hazardous waste.
These are preliminary findings of violations. To resolve them, EPA may issue a
compliance
order, assess an administrative penalty or bring suit against the
company. Dow has 30 days
from receipt of the notice to meet with EPA to discuss
resolving the allegations.
EPA said Dow's alleged clean-air violations may have increased public exposure
to organic
hazardous air pollutant emissions including, but not limited to,
ethyl chloride, toluene, ethylene,
perchloroethylene, methanol and hydrogen
chloride. Hazardous air pollutants may cause serious
health effects including
birth defects and cancer and may also cause harmful environmental
and ecological
effects. These pollutants are also volatile organic compounds and are major
precursors of ground-level ozone (smog).
Smog is formed when a mixture of pollutants react on warm, sunny days. Smog can
cause
respiratory problems, including coughing, wheezing, shortness of breath
and chest pain.
People with asthma, children and the elderly are especially at
risk, but these health
concerns are important to everyone.
Hazardous wastes have properties that make them dangerous or potentially harmful
to
human health and the environment. They exhibit at least one of four
characteristics - flammability,
corrosivity, reactivity or toxicity. They can be
liquids, solids, contained gases or sludges and
can be products of manufacturing
processes or simply discarded commercial products like
cleaning fluids or
pesticides.
Your editorial of Sept. 17th entitled "Our View: EPA should finish its work"
suggests that
because the agency's dioxin reassessment is not yet completed,
dioxin toxicity remains
open to serious scientific debate. This is simply not
true.
EPA has extensive scientific knowledge on the toxicity of dioxin. Thousands
of peer-reviewed
scientific studies have been published. No matter how you look
at dioxin, one fact remains indisputable:
dioxin is a highly toxic compound. In
fact, EPA's reassessment of the most recent science indicated
that dioxin is a
more potent toxic chemical than previously believed. A recent University of
Michigan
study funded by Dow Chemical revealed that people consuming fish from
the Tittabawassee River,
Saginaw River and Saginaw Bay have higher than average
levels of dioxin in their blood. Any increase
in the dioxin levels of fish
consumers is a health concern.
For more than 25 years, the State of Michigan has found it necessary to
issue consumption
advisories on fish from the Tittabawassee River, the Saginaw
River and the Saginaw Bay because
dioxin contamination extends over 50 miles.
EPA believes that the current science on dioxin is
sufficient to develop cleanup
criteria for the watershed. Even without a final dioxin reassessment,
EPA has
moved forward with dioxin cleanups across the nation to protect public health.
The Midland Daily News is right to urge EPA to continue its work on a final
dioxin reassessment
and take into consideration comments provided by the
National Academy of Science. And EPA is
right to urge Dow Chemical to continue
and accelerate its work to restore the Saginaw Bay watershed
so that fish
consumers will no longer need to be concerned about dioxin in the fish they eat.
Richard Karl, Director
Superfund Division
U.S. EPA Region 5
Midland
EPA to Dow Chemical: 60 day clock to
negotiate on Tittabawassee River system cleanup starts today
CHICAGO (Oct. 10, 2007) - At a meeting today in Chicago, U.S.
Environmental Protection Agency Region 5 formally notified Dow
Chemical that it has a limited opportunity to negotiate with the
Agency on a settlement to conduct an investigation, a study and
interim response actions for dioxin contamination in the
Tittabawassee River system. The Midland, Mich., company has until
Oct. 17 to decide whether it will negotiate.
The targeted area begins upstream of Dow's Midland Plant and may
extend downstream to the Saginaw River, its floodplains and portions
of Saginaw Bay in Lake Huron.
EPA has the authority to call for negotiations under the
Comprehensive Environmental Response, Compensation and Liability
Act, or Superfund. Superfund specifies the process in which a
remedial investigation/ feasibility study (RI/FS), cleanup removal
actions and remedy design must be conducted.
"The Superfund law provides a strong mechanism to continue
necessary actions to comprehensively and definitively address the
issue of dioxin contamination in the river system," said Ralph
Dollhopf, associate director of EPA's Regional Superfund Division.
"The work begun this summer to address three hot spots in the
Tittabawassee River is also being performed under Superfund
authority."
Dow's expected RI/FS effort must evaluate the nature and extent
of hazardous substances, pollutants or contaminants from the site
and assess the risks they present to human health and the
environment. It must also provide enough data to develop and
evaluate a range of cleanup options.
If the company agrees begin negotiations, Dow will have until Dec.
10 to present EPA with a good faith offer demonstrating its
willingness to conduct or finance an RI/FS and design a remedy. EPA
may choose to extend negotiations until Jan. 9, 2008, if
appropriate.
Top EPA and Michigan Department of Environmental Quality
officials are meeting today in Lansing to discuss their respective
roles throughout this process.
Dow's Midland facility is a 1,900-acre chemical manufacturing
plant. Dioxins and furans were byproducts from the manufacture of
chlorine-based products. Past waste disposal practices, fugitive
emissions and incineration at Dow have resulted in on- and off-site
dioxin and furan contamination.
09/12/07
EPA has had enough, pulling
out of current mediation process
The United States Region 5 Environmental Protection Agency has declared the
current mediation process between Dow Chemical and the State of Michigan broken and is pulling out of the
process.
"EPA believes a
more open and transparent process is the best way to make important decisions
that will affect the future health and vitality of the watershed for the people of Michigan and
the United States," said Regional Administrator Mary A. Gade. "Despite the best intentions of all involved, the
current process is not working as effectively as it should and it is time to consider a new approach."
EPA issues demand for
Midland dioxin sampling data
(Chicago, Ill. - Aug. 31,
2007) U.S. Environmental Protection Agency Region 5 today issued a request
for information to the city of Midland, Mich., for all dioxin sampling data
taken within the city in 2006 and 2007.
The city of Midland has
information that would give EPA a more complete picture of Dow Chemical
Co.'s dioxin contamination in that area. EPA has also sent information
requests to two other entities that hold relevant information.
"It appears that the data
is obscured by an unusual double blind system that EPA has been unable to
obtain voluntarily from the city of Midland," said EPA Region 5 Superfund
Division Director Richard Karl. "The city holds the key to the data and
we're requiring them to provide it."
Today's request is part of
a larger investigation of dioxin contamination in the Midland area. In
mid-August, EPA issued two requests to Dow asking for information on
off-site and on-site dioxin sampling conducted by Dow and more extensive
data on numerous other hazardous materials produced at the Dow Midland
plant.
Dow began a dioxin cleanup
in three hot spots of the Tittabawassee River as a result of EPA orders in
late June. Those cleanups are expected to be completed this year and set
the stage for additional work downriver.
The Dow facility is a
1,900-acre chemical manufacturing plant located in Midland, Mich. Dioxins
and furans were byproducts from the manufacture of chlorine-based products.
Past waste disposal practices, fugitive emissions and incineration at Dow
have resulted in on- and off-site dioxin and furan contamination.
07/11/07 READ THIS - Unbelievable, shocking, it isn't just dioxin
anymore!!
Speechless.....
A EPA document recently obtained by the Lone Tree
Council exposes the TRUE state of the Tittabawassee River and Dows attempts to
repeatedly delay addressing the problems. It's not just dioxin any more
folks.
It seems we are a true silicon valley now thanks to Dow Corning. Silicon has
been found in every soil sample taken. Not to mention another 29+
dangerous chemicals including Octachlorostyrene , Hexachlorobenzene, Aldrin,
Dieldrin, Fhloradane, DDT, Mirex, and Toxaphene.
But lets not forget about the unprecedented levels
of dioxin. The document offers valid scientific references which counter almost
every lie Dow has purported as "Sound Science" over the last 5 years.
The contents are mind blowing and the implications
staggering. This is a must read for everyone, please download it, print it and
pass around (it's 44 pages but everyone of them contains important myth busting
facts). Politicians should pay close attention, the cats out of
the bag.
Below are a few of the key points of the document, many more are contained in
the document with supporting evidence.
Most of Dow's proposed Scope of Work (SOW) and Remedial Investigation Work
Plans (RIWP) are deficient and should not be approved by the MDEQ.
Dow is not complying with it's RCRA license
Dow's deviation from the EPA's guidelines concerning Human Health Risk
Assessments are unacceptable.
Dow's deviation from the EPA's guidelines concerning Ecological Risk
Assessments are unacceptable.
Dow's lack of progress in completing their Immediate Response Actions
(IRA) is unacceptable.
Dow did not include any of the several hundred hazardous chemicals and
byproducts produced in it's plants history, the EPA wants a revised RIWP
which includes them.
Dow demonstrates a pattern of missed deadlines and incomplete corrective
action document submittals to the MDEQ, this is a violation of their RCRA
License.
Dow has failed to report all environmental monitoring data and has
inappropriately applied confidential status to much of the data.
The EPA has major concerns about the Geomorph studies which have many
deficiencies and feels the process has not been fully proven.
Silicon has been found present in all soil samples and could be an
explanation for the unusual distribution of dioxin and furans in the
environment.
EPA believes the 1986 flood caused a release of hazardous chemicals from
Dows waste water treatment facility.
EPA is very concerned with 29 chemicals that have been found in the
sediment and fish that have been produced by the Dow plant over the years.
Dow is manipulating chemical concentration data in it's studies.
Dow's Human Health Risk Assessment (HHRA) cite scientific literature in
a very selective manner, ignoring recent cancer and other studies which
offer contrary outcomes.
The Dow TCDD Worker study they cite so often is flawed and the outcome
meaningless
EPA considers Dow's selective citations to scientific literature
unacceptable.
EPA has significant concerns with human dioxin exposure through the food
chain pathway.
Because of the risk to human health, the EPA considers Dows plans to do
additional studies before taking remedial action unacceptable.
The University of Michigan needs to release the raw data from it's
Dioxin Exposure study to the EPA and MDEQ. This can be done without
revealing the identity of the participants.
The EPA believes the University of Michigan has not been
cooperating in producing information to the EPA and MDEQ and therefore wants
the MDEQ to investigate why.
Dow is not meetings it's time lines and needs to be held accountable in
order to keep its RCRA license.
Below are a few snippets from the document:
Dow, however, is conducting its remedial investigation of the
Saginaw Bay watershed without approved or enforceable compliance schedules in
conflict with the terms and conditions of Dow’s RCRA Permit. ... U.S. EPA
believes that risks to human health and the environment posed by the
contamination of the Saginaw Bay watershed are so significant and widely
distributed, that a risk assessment will unlikely provide site specific clean-up
criteria that can be directly implemented at this site. ... U.S. EPA has
significant concerns with human health risks associated with dioxin exposure
through the food chain pathway, especially for at-risk populations such as
pregnant women, children, Native Americans, subsistence and sport hunters and
fishermen. At sites as large and complex as the subject site, corrective measure
technologies and their scope ... U.S. EPA is concerned that Dow’s ecological
risk assessment (ERA) is inconsistent with current Agency guidance and the
typically accepted methods for conducting such risk assessments. ... U.S. EPA
does not believe that ecological risk has been adequately addressed by Dow in
the revised RIWPs. ... This concerns U.S. EPA because it is known that
individuals within a population can be adversely impacted by contaminants
without observed population-level effects. ... levels of dioxin and furan
contamination in the Saginaw Bay watershed through the timely implementation of
Interim Response Actions (IRAs) as required by Dow’s RCRA Permit. ... U.S. EPA
believes that hazardous constituents are actively migrating downstream from
Dow’s facility into Lake Huron. ... U.S. EPA does not consider Dow’s
description to be complete given the scope of Dow's chemical operations in
Midland, Michigan. The limited information provided by Dow to MDEQ in the
revised RIWPs is problematic. ... U.S. EPA believes that the record in this
matter demonstrates a pattern by Dow of missed deadlines and the submittal of
incomplete corrective action documents to MDEQ (see Dow Off-Site Corrective
Action Activity Table below). U.S. EPA considers these actions by Dow to be
inconsistent with the requirements of Dow’s RCRA License. ... Failure to Report
all Environmental Monitoring Data and Improper Application of Confidential
Status to Data ... This ongoing failure to provide data within time frames
specified in Dow’s RCRA permit continues despite the fact that Dow was issued a
Notice of Violation (NOV) by MDEQ for a similar series of violations on
September 19, 2005. ... U.S. EPA also has significant concerns with the
agreement between the City of Midland and MDEQ to allow Dow to partially shield
corrective action data gathered within the City of Midland from public
disclosure. U.S. EPA considers the holding of what would normally be publicly
available corrective action data in a confidential manner by a third party not
subject to the terms and conditions of Dow’s RCRA License to be inconsistent
with the recordkeeping and reporting requirements of Dow’s RCRA License. ...
Nowhere within Section II.L (Recordkeeping and Reporting) does Dow’s RCRA
License provide for the selective or partial reporting of data by Dow. ...
A fundamental component of the GeoMorph process, as explained by ATS, is
real-time remediation. This component of GeoMorph is not being implemented and
calls into question the value of the GeoMorph approach when applied at this
site. ... U.S. EPA does not agree with the
assertion that the GeoMorph process has been fully proven at this site. ...
While Dow has provided a relatively detailed history of Dow's historic chlorine
production at Section 3.3.1.1 of the TR RIWP, Dow provides virtually no
additional specific information, other than a list of products organized by
decade(s), in the revised RIWPs concerning the many hazardous constituents
potentially released by Dow to the Saginaw Bay watershed. U.S. EPA does not
consider Dow’s description to be complete. ... constituents from the Dow
Corning facility may have potentially affected the distribution of contaminants
from Dow’s Midland facility within the Saginaw Bay watershed. ... Dow’s
characterization of the hazardous contamination in the Saginaw Bay watershed,
therefore, will not be complete without an understanding of the historic
operations and waste management practices of the Dow Corning facility whose
operations were, and are, intertwined with those of Dow’s Midland facility. ...
In 2004, the Superfund Innovative Technology Evaluation project conducted by the
Battelle Memorial Institute identified silicone compounds in all of the soil
samples taken from the TR. U.S. EPA believes the presence of silicones in the
soils and sediments of the Saginaw Bay watershed to be unique and, therefore,
could be an explanation for the unusual distribution of dioxins and furans in
the subject environment. ... Dow does not provide a detailed
discussion of the 1986 flood event on the Tittabawassee River and the potential
release of contaminants to the river during that event. U.S. EPA is concerned
with this event because U.S. EPA believes there may have been a release of
hazardous constituents from Dow’s wastewater treatment facilities during this
time period. If so, a detailed description of such events is warranted. ...
U.S. EPA is particularly concerned with the following PBTs, due to the fact that
these chemicals have either: 1) been identified in fish tissue in the Saginaw
Bay watershed; 2) are known by-products of one or more chemical production
processes identified by Dow in the revised RIWPs as having occurred at its
Midland, Michigan facility; and/or 3) U.S. EPA has reason to believe these PBTs
may have been produced and released by Dow from its Midland, Michigan facility.
... For example, Dow repeatedly emphasizes that humans are less sensitive than
rats to the effects of dioxin. Dow’s assertion ignores the recent paper by K.
Nohara et al. (Toxicology 225: 204-213; 2006) which clearly shows that humans
are the most sensitive species, as well as earlier work demonstrating that for
multiple endpoints, there was similar sensitivity between animals and people.
... Dow states that there are no studies of the reproductive effects of
the PCDFs, which ignores the work of Hamm et al. (Toxicol. Sci. 74:182-191;
2003) showing that the 1998 WHO TEFs did an excellent job (within 2X) of
predicting the reproductive effects. ... Dow ignores some of the recent
cancer studies showing that early life exposure may enhance the risk of cancer
both in animals and humans (C. LaMartinierre et al. in rats; M. Warner et al. in
the Seveso cohort). ... U.S. EPA is concerned that Dow may not be
using the most appropriate dose metrics, which are very dependent upon response
... The epidemiological studies of Dow "TCDD" workers used "controls" who
were highly exposed to PCDFs (Collins et al, 2005), so it is inappropriate to
say that Dow TCP and PCP workers had no increased cancer risk - their exposure
was similar to the "controls." ... Dow has proposed to conduct numerous
studies to support a HHRA which could result in a higher clean-up criteria for
dioxin than required by Part 201 of Michigan Act 451. U.S. EPA believes most if
not all of these studies are unnecessary and will only result in lengthening the
time frames for the completion of many of the components of the remedial
investigation. ... U.S. EPA also has significant concerns with human
health risks associated with dioxin exposure through the food chain pathway,
especially for at-risk populations such as pregnant women, children, subsistence
hunters and fishers, and Native Americans ... However, U.S. EPA has
never stated or agreed that the use of PRA methodology for selecting
chemical-specific dose-response factors is justified because ... U.S. EPA
does not believe that there is any need for Dow to conduct the extensive and
time intensive additional site-specific studies currently grouped under the
heading “Exposure Study Plans.” ... For example, a recent Michigan Department of
Community Health study has identified potentially at-risk segments of the
population in Saginaw and Bay City, Michigan which consume a significant amount
of highly contaminated river bottom feeding fish (catfish and carp). Given the
significant risks associated with exposure to dioxins, furans and other possible
hazardous constituents from eating such fish, Dow’s proposal to continue to
study such pathways before initiating any remedial actions is not acceptable.
... Dow’s proposal to undertake an extensive effort to re-evaluate the TEFs is
unlikely to have any significant effect on the HHRA. ... U.S. EPA
recommends that MDEQ seek the production of any and all relevant information
concerning the nature and extent of dioxin and furan contamination in the
Saginaw Bay watershed obtained during or related to the UMDES from the
University. ... U.S. EPA recommends that MDEQ
seek the production of information concerning Dow’s funding and contractual
control over the UMDES from the University. ... U.S. EPA recommends
that MDEQ incorporate the following compliance schedule into any approval of the
revised RIWPs, if Dow fails to timely provide a compliance schedule as required
by their RCRA License. ... U.S. EPA
recommends that MDEQ require Dow to provide a separate enforceable IRA
compliance schedule to be approved by MDEQ and incorporated into Dow’s RCRA
License for addressing the currently identified TR dioxin hot spots. ....
EPA's list of chemicals of concern:
Aldrin/dieldrin
Benzo(a)pyrene {B(a)P}
Chlordane (Dow-Klor and Dowchlor)
DDT (+DDD+DDE)
Hexachlorobenzene (HCB)
Alkyl-lead
Mercury and mercury compounds
Mirex(Hexachloropentadiene)
Octachlorostyrene
Toxaphene
Cadmium and cadmium compounds
1,4-dichlorobenzene
3,3'-dichlorobenzidine
Dinitropyrene
Endrin
Heptachlor (+Heptachlor epoxide)
Hexachlorobutadiene (+Hexachloro-1,3-butadiene)
Hexachlorocyclohexane
4,4'-methylenebis(2-chloroaniline)
Pentachlorobenzene
Pentachlorophenol
Tetrachlorobenzene (1,2,3,4- and 1,2,4,5-)
Tributyl tin
[Plus PAHs as a group, including but not limited to]:
06/27/07 EPA: Dow Chemical must clean up Tittabawassee Hot Spots
Immediately
CHICAGO, June 27 /PRNewswire-USNewswire/ -- U.S. Environmental Protection
Agency Region 5 today notified Dow Chemical Co. that it must immediately start
cleanup of three dioxin-contaminated hot spots downstream of its Midland, Mich.,
facility on the Tittabawassee River.
The action is being taken using the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 and requires that Dow and EPA negotiate
the final terms of three administrative consent orders for the cleanup within 15
days and start field work by August 15.
EPA has documented that dioxin contamination in soil poses risks to human
health and the environment. Cleanup must take place in a significant portion of
the Upper Tittabawassee River this construction season.
In late November 2006, Dow identified dioxin hot spots along the first six
miles of the Tittabawassee River contaminated with levels up to 87,000 parts per
trillion, far in excess of state and federal requirements. The areas of concern
are subject to flooding and erosion that could spread the contamination.
Dow's corrective action work under its 2003 Michigan Resource Conservation
and Recovery Act license has taken too long, prompting EPA to require the
following actions.
09/06/06 EPA questions applicability of key dioxin study to Michigan cleanup
Lone Tree Council / TRW Dioxin Update
Risk Policy Report
September 5, 2006
EPA Region V is questioning the applicability of a recent landmark dioxin
exposure study to a contentious dioxin cleanup near Dow Chemical Co.’s
headquarters in Michigan, saying the study did not thoroughly target susceptible
subpopulations and is not the type of information that forms the basis of
remediation decisions.
University of Michigan scientists released preliminary results from the
research, The University of Michigan Dioxin Exposure Study, last month, which
showed residents in a dioxin-contaminated area near the Dow facility have higher
levels of dioxin in their blood, but the study also found that age, weight and
gender more greatly influenced those levels rather than a person’s proximity to
the contaminated site.
While the researches did not draw any conclusions about health risks or cleanup
policies, one of the authors said the study—which found the highest dioxin blood
levels in older, heavier males—would provide “valuable data [to regulators and
the community] in determining how best to manage this problem.”
Dow officials, who have long fought both Michigan and EPA proposed cleanup
levels and efforts to demand extensive surveys of dioxin contamination stemming
from the facility, cited the study as important information to take into account
as EPA prepares a cleanup plan for the site. Dow’s Midland, MI, headquarters has
dioxin levels as high as 2,000 parts per trillion (ppt), with an average of
almost 1,000 ppt at the site. The site spread contamination to the Tittabawassee
River, which has deposited contaminated sediments on the shores of the river via
frequent flooding and continues to do so. The area along the river has farms and
residences, among other uses.
EPA Region V officials, however, are raising a number of questions about the
study, noting that its results are preliminary; that it did not specifically
target susceptible populations like children, hunters, fishermen and pregnant
and nursing women; and that it is not the type of health effects study that
could be used to determine health risks from exposure to the contamination.
Moreover, EPA says that because background levels of dioxin—a suspected
carcinogen—found in human blood are high enough to pose health risks, the
elevated levels found in the study are of concern, since residents near the Dow
site had 28 percent higher dioxin levels than the control group. “EPA is
concerned about the dioxin blood levels in some local residents,” one Region V
source says, since “a number of studies have confirmed a relationship between
background levels [of dioxin in humans] and adverse health effects” such as
diabetes, endometriosis, thyroid disorders, immune disorders and neurological
impairments.
The source also says EPA is concerned about highly exposed subpopulations, like
hunters and fishermen, who consume a significant amount of dioxin-contaminated
fish and game. “There wasn’t an attempt upfront to include highly exposed
groups,” one EPA source says. Another regional source notes that both
subsistence fishermen from environmental justice populations along with
recreational fishermen and hunters get a significant portion of their protein
intake from fish and game in the area, which are likely to be contaminated with
dioxin. The first EPA source also notes that the study only evaluated people
over age 18, excluding infants, children and pregnant or nursing women, who
would be considered at higher risk than the populations studied.
The second EPA source adds that the Michigan study would only be one of many
types of information the agency will consider as it develops its cleanup plan,
but it will not be a major factor because it does not draw any conclusions about
health. To do so, EPA will develop a risk assessment and combine that
information with data that are currently being collected and will be collected
over the next few years on levels of contamination in the flood plain near the
Dow facility.
Dow is currently collecting samples along the first six miles of the
Tittabawassee River and will do more sampling over the next several years based
on the results of the initial sampling. EPA says its remedial options include
removing contaminants if there are “hotspots,” but if contamination is spread
evenly, that would make cleanup more difficult.
Remember it is the responsibility of MDEQ and
MDCH to act or require interventions and cleanup before health effects occur.
That we should look for dead bodies or disease before we act is irresponsible.
MHR
02/21/06EPA finds Dow IR Workplans
"Critically Deficient"
In a recent memo to the MDEQ states:"...the United States
Environmental Protection Agency, Region 5 (EPA or the Agency) has conducted a
preliminary review of the
Tittabawassee River and Floodplain Remedial
Investigation Work Plan (T-RIWP) and the Midland Area Soils Remedial
Investigation Work Plan (M-RIWP) submitted to Michigan Department of
Environmental Quality (MDEQ) by the Dow Chemical Company, Midland, Michigan
(Dow) on December 29, 2005. As detailed in the attached comments,the Agency has
determined that the T-RIWP and M-RIWP (RIWPs) are critically deficient".
A few excerpts:
The RIWP deficiencies set forth in EPA’s comments
need to be addressed by Dow prior to initiation of a more comprehensive
review of these documents.
Dow’s Human Health Risk Assessment Work Plans are fundamentally flawed, and it would not be a wise or efficient use of
either agency’s resources to attempt to approve them with modifications in
their current form.
EPA requests that MDEQ require Dow to promptly address the
deficiencies detailed in the attached comments and then require Dow to
resubmit amended RIWPs to the State of Michigan no later than sixty (60)
days from the date that Dow is provided written notice of the subject
deficiencies.
EPA also requests that MDEQ not approve either RIWP, in full
or in part, until all of the requested changes are made by Dow and such
changes have been reviewed and approved by MDEQ.
The sampling protocol set forth in the T-RIWP by Dow to
determine the nature and extent of hazardous constituent contamination in
the Tittabawassee River (TR) sediments is severely inadequate.
Existing data is insufficient to support Dow’s
conclusion that sediment contaminant concentrations in the TR are random and
that no consistently elevated areas of contamination exist within the TR
sediments. Dow’s proposal of one sediment sampling location per mile is very
likely to be orders-of magnitude greater than the actual distance of spatial
correlation. Consequently, analytical
results obtained from sampling locations with a separation of one mile would
have a strong tendency to exhibit the unpredictability postulated by Dow.
EPA does not consider geospatial modeling as an acceptable
substitute to an empirical characterization of the nature and extent of
contamination. ... EPA recommends that MDEQ require Dow to implement a significantly more comprehensive and intensive
sampling
program that will establish the nature and extent of the PCOIs within the TR
floodplain.
Dow’s proposal for three surface water sample locations in
the TR to be sampled during a base flow and flood event is inadequate.
EPA requests that MDEQ require Dow to undertake the
following four sequential steps in order to properly characterize the TR and
Floodplain:
Completion of a thorough PCOI study (Principle
Contaminants of Interest)
Completion of a thorough geochemical study on all of the
identified PCOIs (or all PCOI chemical groupings)
of interest
Completion of a pilot characterization study to
determine horizontal sampling grid interval for both the River
sediments and the floodplain soils
Sampling for both PCOIs and geochemistry should be
performed on transects across the river at a minimum of 1/4 mile
intervals (approximately 100 transects).
EPA recommends that the sampling locations be
gridded on a one hundred (100) foot interval throughout both the
floodplain and the River, extending from one side of the one hundred
(100) year floodplain to the other.
Completion of a full characterization study including
the preparation of depth-based contaminant-concentration contour maps
for all identified PCOIs
EPA recommends that, at a minimum, the final work products
of the T-RIWP characterization process include the following:
90 ppt TEQ boundary line map (vertical and horizontal).
Depth based concentration
contour maps with a 100 ppt TEQ contour line.
0-6 inch surface TEQ
concentration contour map.
TEQ concentration contour
maps for all underlying 1-foot vertical compositing intervals
Comparable boundary lines and
maps should be produced for all other PCOIs.
Dow’s proposal in the M-RIWP to delay Phase II sampling
until 2008 is not acceptable to EPA.
... this multi-year process of developing, reviewing and
approving these risk-based and/or area-wide criteria will preclude a
thorough evaluation of the extent and intensity of the D/F contamination
within the City of Midland. Such a delay is not acceptable or appropriate
in light of the significant potential risks posed by the known
hazardous constituent contamination in the City of Midland.
EPA requests that MDEQ require Dow to include in the M-RIWP’s
proposed Phase II sampling plan, soil sampling at the Dow Midland facility.
The Human Health Risk Assessment Work Plans (HHRAWPs),
as proposed by Dow in the RIWPs, do not comply with EPA risk
assessment policy and guidance and, therefore, cannot be approved by EPA.
EPA requests that MDEQ require Dow to identify in the
RIWPs the likely and potential specific pathways of human exposure to
PCOIs in the Midland soils and TR soils and sediments. Such exposure
pathways will likely include direct contact to PCOIs and indirect
exposure to PCOIs after fate and transport processes have occurred, e.g.
consumption of contaminated fish and/or wildlife. In addition, Dow must
identify appropriate high-end receptor populations, such as subsistence
fish and wildlife consumers and native American populations.
Dow should be required to identify the specific data
which will be collected and used to support the exposure assessment
portion of the HHRAWPs. In addition, Dow should be required to explain
how the PCOI concentrations will be incorporated into the HHRAWPs to
determine levels of risk and used for comparison to Cleanup Criteria.
Dow's proposal, in the HHRAWPs, to use probabilistic
methods for deriving dose-response parameters for the PCOIs is unacceptable.
Dow implies that the methodology for applying
probabilistic risk assessment (PRA) to dose-response data in HHRAWPs
would be straightforward, but this is far from the case.
For example, Dow does not explain whether the
PRA analysis will use human studies in addition to animal
bioassay studies. If data from one animal species were to show a
clearly defined (and human related) dose-response effect
(positive), but the data from another species did not
(negative), it is not clear in the HHRAWPs whether Dow would
give the data from the positive species more weight than the
data from the negative species, in accordance with EPA policy
and guidance.
EPA does not believe that Dow has proposed an adequate or
widely accepted methodology for constructing Probability Distribution
Functions (PDFs) for dose-response data. Because the establishment of
dose-response data and toxicity factors for chemicals has national
implications, EPA cannot approve requested deviations on a site-specific
basis. National standards are based upon scientific consensus and are
established by EPA Headquarters in Washington, D.C. Recognition and use of
these standards are a necessary prerequisite to national consistency. As a
result, EPA, Region 5 cannot approve a PRA which includes probabilistic
methods for deriving dose-response parameters.
8/10/04 EPA
stepping in? New documents indicate unacceptable public health & ecological
risks.
A recent EPA memo (7/30/04) to the MDEQ indicates the results of
the Dow Wild Game study in the Tittabawassee River Flood plain are much more serious than
the Dow Press release indicates. The
EPA goes on to state that they may need "to become engaged in the dioxin
contamination problem and to re-enforce existing risks to public health and
wildlife". A summary of the memo was published today in the
Midland Daily News. Highlights of the
memo:
The contamination has similar characteristics regarding levels of risk and area affected
as the
Kalamazoo
and Fox Rivers, which are currently a focus of
the US EPA remediation plans.
It is clear than a persistent, un-addressed dioxin problem exists.
Unacceptable, elevated cancer risk's to public health to frequent consumers of fish.
Potential health risks to persons consuming game.
Dioxin contamination of game indicate contamination of the terrestrial food chain
Unacceptable, serious aquatic ecological risks to fish, fish eating birds, and mammals.
Strong consideration should be given to removal of dioxin contaminated sediments
and flood plain soil.
There is particular concern regarding
distortions
of risk information which are causing inaccurate risk messages to the public.
Dr. Linda Birnbaum’s presentation
to the locals on April 13, 2005 was enlightening to many of 150-200
attendees on both sides of the issue. Overall, the presentation was very useful
and we appreciate her efforts to update our community on the latest in dioxin
science. However, a portion of the presentation deviated from science and moved
into the realm of speculation, adding more questions than answers to an
extremely complicated contamination issue.
She confirmed that epidemiological studies of numerous human populations
provide
the evidence of adverse human effects of dioxin. These effects have been
documented in groups (cohorts) ranging from the general population to highly
exposed and everywhere in between. Health effects include, but are not limited
to cardiovascular disease, diabetes, glucose intolerance, hyperinsulinemaia,
hormone disruption, cancer, immune suppression. endometriosis, decreased
testosterone, chloracne. Prenatal exposure can lead to developmental problems
with the thyroid status, immune status, neurobehavior, cognition, dentition,
reproductive effects, altered sex ration and delayed breast development. In
other words, the toxicity of dioxin is not in question, it’s a fact based on
peer reviewed scientific studies from around the world.
For the most part, Dr. Birnbaum was extremely careful to limit her discussion to
her area of expertise as a toxicologist. When asked to provide guidance in areas
outside her expertise related to regulation, cleanup, and/or exposure pathways,
she did what a good scientist should, cite facts or decline to comment.
However, a major discrepancy developed soon after stating “Dioxin is well
absorbed by the GI tract and lungs”. When pressed to comment on whether soil
levels of dioxin in our area contribute to our dioxin body burdens, Dr. Birnbaum
responded by saying she was not an expert in that field but proceeded to
speculate “If I had to put money on it, it’s probably unlikely that your are
much more highly exposed than your neighbors who aren’t living in the flood
plain.” She followed this statement with the caveat that future studies may
prove her wrong.
Unfortunately for the general public, the news media & Dow supporters picked
this tidbit of conjecture as the main topic of their coverage, doing the
community a further disservice. Perhaps they should give the concept of “Sound
Science” something more than lip service.
From the layman’s perspective, ”absorbed by the GI tract and lungs” means that
if you breathe or eat it, you absorb it. Flood plain residents are breathing the
dust of the contaminated soil and tracking it into our homes 24x7. Has she seen
the freshly deposited soil in our yards & vegetation after every flood? Has she
driven a lawnmower in the flood plain? Has she seen the dust clouds blowing
around after a dry spell? Has she seen our Fish and Wild Game advisories? Why
are we told to wear face dust masks when working in our yards, avoid having
children play in the soils, and leave clothing worn when working in the yard
outside the house? How are we to believe that our soil, flora, and fauna do not
contribute to our dioxin body burden beyond that of the general population?
Dr. Birnbaum was unaware of last years MDCH PEI study whose unofficial,
preliminary results indicate a large portion of residents tested are
accumulating dioxin blood levels much higher than nation averages. In fact, over
60% of the results shared with TRW exceed the 75th percentile and over 60%
exceed the top end of the range for people 40-59 years old shown on Dr.
Birnbaum’s slide titled “Mean and Range of TEQ’s by Age Group”. Note we are
still waiting for the official PEI’s final report. If it should ever be
published, these values may change, either up or down.
Dr. Birnbaum stated she is a member of the scientific advisory board for the
University of Missouri bioavailabilty study being conducted by Dow. She stated
past studies have shown dioxin bioavailablity from soil ranging from 1% to 100%
depending upon the makeup of the soil. 100%??? And yet she speculates we do not
have any additional exposure from living in the flood plain.
She also stated her concern that the bioavailability study may not be using the
right types of soils to represent those found in the Tittabawassee Flood plain.
Suggestion: If she is on the advisory board, why not demand the study protocol
be adjusted accordingly? Her tone of voice indicated to me that she is
dismissing the value of the bioavailabilty study because of it’s design, not the
value of the data.
In my opinion, neither the bioavailabiltiy or the U of M Exposure Pathway
studies are necessary. They are just another example of paralysis by analysis.
We know dioxin is hazardous to humans, that they accumulate in the body, that
they take a very long time to dissipate from the body or the soil, the clinical
and subclinical effects of dixoin are being detected in the general population
of non-contaminated areas, and flood plain residents live every day in close
proximity with high levels of dioxin in and about our homes. It does not take a
rocket scientist to see that even a little bit extra dioxin in your body is not
a good thing in this situation. The reasonable course of action: take
precautions now until the source of the contamination is removed.
So what is the source of the extra dioxin that seems to be prevalent in flood
plain resident’s blood? If we get 95% of our dioxin from food like everyone else
as Dr. Birnbaum suggests, the remaining 5% could not account for the abnormally
high levels in our blood. Where did the rest come from? How did the
Tittabawassee fish and floodplain squirrels, turkeys, and deer acquire such
elevated dioxin levels? Where did the chicken eggs consumed by river resident’s
children acquire the 40 ppt TEQ per egg? The last time I checked, wildlife where
not shopping in our local food markets.
How can she speculate that living in areas of highly contaminated soils will
have an insignificant effect on our body burdens and also say the Public Health
position is: 1) “Current levels in the environment are associated with body
burdens in the general population which are at or near the point where effects
may be occurring”? and 2) “Continue to reduce sources and Environmental levels”
of dioxin. How can she speculate that living in highly contaminated soils
provides an insignificant source of dioxin when the Margin of Exposure for
"clearly adverse non-cancer responses" is less than 10?
Public Health should be paramount in this issue in the Tittabawassee watershed. Speculation and gambling belong
in the Mt. Pleasant casino.
Having said all this, we would still like to thank the Lone Tree Council for
bringing respected scientist such as Dr. Birnbaum to town. While we did not
agree with every thing she said, the vast majority of the information was
valuable and the communities understanding of the issues will only improve as
they bring in additional speakers in the future.
Click here to download Dr.
Birnbaum's power point presentation used at the meeting.
EPA Pollution Progress Reports on Tittabawassee River
Cleanup - What's actually been done
11/06/11 EPA and Dow sign agreement to
start sediment clean up by Dow Midland Plant
November
2011
EPA and Dow Chemical Co. signed a legal agreement on November 2, 2011 requiring
Dow to clean up sediment in Segment 1, a three-mile stretch of the Tittabawassee
River next to Dow’s Midland Plant. There are six Sediment Management Areas or
SMAs identified within Segment 1 where chemical pollutants are targeted for
cleanup. Most of the pollution in Segment 1 is from chlorobenzenes and other
chemicals rather than dioxin. A form of the contamination, dense non-aqueous
phase liquid (DNAPL), a heavy liquid made up of materials that do not mix with
water and sinks to the bottom of the river, is targeted for cleanup in three of
the SMAs. EPA selected its plan after carefully considering public comments.
EPA’s cleanup plan for each is as follows.
SMA
1 – Place a clean cap over contaminated sediment to isolate and stabilize the
sediment. SMAs 2 and 3 – Remove and treat DNAPL, isolate contaminated sediment
with sheet pile and a cap, and capture water within the sediment and treat it.
SMAs 4 and 5 – Place a clean cap over contaminated sediment. SMA 6 – Dredge and
dispose of sediment contaminated by ethyl parathion; remove and treat DNAPL;
isolate remaining contaminated sediment with sheet pile and a cap; and capture
water within the sediment and treat it. Materials will be treated and disposed
at approved locations, sites will be monitored during and after the cleanup and
the cleanup systems will operate and be maintained.
Legal Agreement Signed for Early Action at Small Island in the Tittabawassee
River
EPA
and Dow Chemical Co. signed a legal agreement July 8, 2011, requiring Dow to
take early action to limit contaminated sediment from moving downstream from a
small island in the Tittabawassee River, known as Island MM. EPA's selected
action to control dioxin movement from the island is to remove contaminated
sediment, at a minimum that is located above the water surface. The remaining
island sediment and nearby underwater areas will be capped. The cap will be
designed to let the island restore itself naturally. The work will remove highly
contaminated sediment and stop it from moving downstream. Based on public
comment, EPA modified its proposed remedy to include a contingency that allows
EPA to adjust the amount of sediment removed and the areas capped, based on
studies of current conditions. EPA's responses to public comments can be found
in the Responsiveness Summary, which is Appendix C to the below document called
the Enforcement Action Memorandum.
07/21/09 Recent EPA updates:
West Michigan Park Cleanup done until next flood?
West Michigan Park cleanup completed
EPA
has finished work at Saginaw Township's West Michigan Park. The cleanup got
underway on April 27 and included the removal of more than 17,000 tons of
dioxin-contaminated soil. Last week contractors finished up by installing
guardrails and paving the parking lot and by planting 5,000 native plants along
the shoreline. The park will be reopened after the new grass and plants have had
time to get reestablished -- likely by mid-August.
11/7/08 Riverside Boulevard Cleanup status The MDEQ meeting 11/7/08 revealed that
Riverside Boulevard
residents are satisfied
with cleanup so far. This
neighborhoodis located near
the spot where
the initial dioxin contamination was
revealed to
the public back in 2002 after a Lone Tree Council FOIA demonstrated
that the former MDEQ administration was covering up the discovery.
View the "Long Shadow" documentary for a close-up of the early days in
this saga including interviews with a Riverside resident who regularly
consumed contaminated eggs from his free range chickens.
Recent testing evidently confirmed
previously reported high levels in the yards, roads, and homes of
residents. In July 2008, the
EPA stepped in forced Dow to initiate an immediate cleanup. River Boulevard is
one of the last dirt roads in Saginaw County and provides the only access to
the residents homes. According to the MDEQ, dioxin levels of 10,000
ppt where discovered in the dusty and often muddy road. The EPA has
since paved it as part of the remediation. This area is prone to
repeated flooding, it will be interesting to see how future contamination is
handled.
EPA "Pollution" Progress Reports - status updates of cleanup
process
On June 27, 2007, U.S. EPA ordered The Dow Chemical Company (Dow) to
negotiate an Administrative Order on Consent, to address removal of extremely
elevated levels of dioxin-contaminated sediment within Reach D of the
Tittabawassee River near Midland, Michigan. Dow contractors mobilized to the
site on July 9, 2007. Dow agreed to the terms of the Order and on July 12,
2007, the Order was signed by the Regional Administrator and Dow.
Below are the links to EPA "Pollution" reports which summarize the progress
made so far on reach:
The
Site covers the area in the vicinity of, an historic, 1,200 foot-long, water
discharge flume containing approximately 15,000 cubic yards of
dioxin-contaminated sediment and bottom deposits. The site is generally
bounded by the Dow Revetment Groundwater Interception System (RGIS) sheet
piling along the northeast bank of the Tittabawassee River and a line of old
sheet piling constructed in the 1930s-1940s and varying from 5 to 40 feet
distant from the bank. The entire removal area is located upstream of the
Dow Dam. The historic water discharge flume was, at one time, connected to
an outfall at the Midland Plant
The
Site is located in over-bank areas on the northeast side of the
Tittabawassee River, approximately 3.6 miles downstream of the confluence of
the Chippewa and Tittabawassee Rivers and located within The Dow property
bounded to the northeast by a wetland with Saginaw Road to the northeast
beyond the wetland, the Caldwell boat launch to the South, and to the west
by the east channel bank of the Tittabawassee River, in Midland County,
Michigan.
The Site includes two areas of focus. The first consists of buried,
post-industrial deposits immediately adjacent to the River and extending at
least 75 feet inland, near the southern end of Reach J and extending through
the southern end of Reach K (the “Levee Area”). The second area consists of
high and low terraces, and includes wetlands, that occupy most of the Reach
J/K over-bank area and are subject to sediment deposition during flood
conditions.
The
Site known as “Reach O of the Tittabawassee River Superfund Site,” is an
approximately 1,300 foot-long point bar extending approximately 50 to 100
feet into the Tittabawassee River and situated parallel to the northeast
bank of the Tittabawassee River, approximately 6.1 miles downstream of the
confluence of the Chippewa and Tittabawassee Rivers and located within, or
immediately adjacent to, the Dow Chemical Company property located to the
south of North Saginaw Road and to the west of North Orr Road, in Midland
County, Michigan.
EU001
is a residential cleanup of dioxin contamination
located in Saginaw,
Saginaw County, Michigan. See Polrep 1 for more details.
Set up for the soil removal activities began in August and consisted of:
building a staging area for personnel and equipment, road building within
staging area and creation of access points through pre-existing berm to
staging area, the placement of landscape fabric and stone under crawlspaces
and decks to minimize human exposure to contaminants, and creating permanent
floors in outdoor sheds.
Removal activities of contaminated soil began on September 2,
2008. Pre-excavation activities on these properties include moving of
outdoor personal property to the staging area and the removal of trees and
brush. During removal activities, crews removed 2 feet of contaminated soil
in residential areas and 1 foot of soil from the “transition zones”
(non-residential). After the removal of soil was complete, crews placed
landscape fabric as a demarcation layer, backfilled with clean fill and
topsoil and prepared the area for landscaping and sod placement. All
removal activities of contaminated soil were completed on October 8, 2008.
EPA Pollution Progress Reports on
Saginaw River Dredging
EPA "Pollution" Progress Reports - status updates of cleanup
process
Late on Friday, November 9, 2007, Dow notified U.S. EPA that preliminary data
for a sediment sample collected from within the channel of the Saginaw River was
in excess of 1.6 parts per million
(ppm) Dioxin TEQ. This is the highest TEQ analytical result recorded for
either the Tittabawassee or Saginaw Rivers. On November 11, 2007, U.S. EPA
issued a verbal General Notice Letter of Potential Liability to Dow.
Below are the links to EPA "Pollution" reports which summarize the progress
made so far :
Status: 02/01/12 EPA fails to meet Dioxin Reassessment deadline
again after 27 years of Dow influence
Lone Tree Council
P.O. 1251, Bay City, Michigan 48706
(Fighting for environmental justice since 1978)
February 1, 2012
For Immediate Release
Contact: Michelle Hurd Riddick - Lone Tree
Council 989-327-0854
Terry Miller - Lone Tree Council Chair
989-450-8097
Tracey Easthope MPH - Ecology Center
734-369-9268
Toxic Dioxin – Public Health Advocates,
Environmentalists Condemn Failure to Release Dioxin Health Report
Michigan Left in the Dark about Dioxin’s
Toxicity as EPA’s Voice Remains Silent
Advocates Urge EPA to Immediately Release
Dioxin Health Report, Decry 27 Years of Delays Due to Dow Chemical’s
Influence
(Mid Michigan) For twenty-seven years
dioxin impacted communities, like Saginaw, Bay City and Midland have
waited for EPA to articulate the science findings on the toxicity of
dioxin. Today, Lone Tree Council and the Ecology Center denounce the US
Environmental Protection Agency’s failure to once again release their
report on the non-cancer impacts of dioxin. In August of 2011 EPA
committed to a January 31st deadline.
The failure to finalize any portion of the
report represents a political, moral and ethical failure. Dioxin has
become the textbook example of how industry can successfully delay
science-based progress on toxic chemicals in this country.
“Since the mid 1980’s when the Reagan
administration permitted Dow Chemical to rewrite the EPA report on
dioxin, administration after administration in the White House has cowed
to this company and their lobbyists”, said Michelle Hurd Riddick of the
Lone Tree Council. “Public health is being sacrificed, our water
resources disregarded and science is being ignored once again in an
effort to placate the moneyed interest. It is indefensible that this
administration capitulated to industry, reaffirming the belief of most
Americans that corporations have greater influence and more control and
rights than people”, says Hurd Riddick.
In recent months, consistent with history,
the chemical industry has been working behind closed doors to conceal
hide and distort the truth about the dangers of dioxin. At the same
time, Vietnam Veterans, breast cancer advocates, public health
organizations, and environmental justice leaders have stood shoulder to
shoulder and urged EPA to do what’s right for the health of American
children and families.
Over the past three weeks a broad coalition
of organizations have written to EPA.
Cancer, diabetes, infertility, learning
disabilities and other chronic diseases linked to dioxin exposure are
extremely costly to American taxpayers in terms of health, quality of
life and regional economic development. EPA missed yet another deadline
to release their report on dioxin, one of the most toxic chemicals on
the planet.
Tracey Easthope MPH, "Finalizing this
study matters to people in Michigan. We are home to one of the largest
dioxin contamination sites in the country. People have been living with
this chemical in their bodies, in their food supply, and in their homes
for decades.”
“This report is a great example of why
people are so angry and frustrated by the influence of powerful
interests that trample the public interest. How is it possible for
industry to delay the release of a report for 27 years? How can a
system become this dysfunctional”?said Ms Easthope of the Ann
Arbor based Ecology Center.
According to EPA, dioxin releases
increased by 18% from 2009-2010 nationally. Dioxin air releases
increased by 10%. Dioxin’s effects on the immune system of the
developing organism appear to be among the most sensitive endpoints
studied.
Terry Miller, Lone Tree Council chairman
is calling on the administration to support EPA’s scientific findings
and release the non-cancer portion of the report as promised. “The
failure of EPA to publicly affirm their science, to find their voice on
the toxicity of dioxin, is an abysmal failure of public health policy “,
said Miller.” How many more years will Dow Chemical and industry
lobbyists be permitted to frame the issue and science on dioxin”?
Joining the Dow Chemical lobby, in
anticipation of the release by EPA, the corporate agriculture industry
circled their wagons, creating the Food Industry Dioxin Working Group (FIDWG)
to lobby against the EPA release. The FIWG member organizations:
American Farm Bureau Federation
American Feed Industry Association
American Frozen Food Institute
American Meat Institute
Corn Refiners Association
International Dairy Foods Association
National Chicken Council
National Grain & Feed Association
National Meat Association
National Milk Producers Federation
National Oilseed Processors Association
National Pork Producers Council
National Renderers Association
National Turkey Federation
Pet Food Institute
United Egg Producers
WASHINGTON - The US Environmental Protection Agency (EPA) announced
today that it plans to complete the non-cancer portion of
EPA’s Reanalysis of Key Issues Related to Dioxin Toxicity and Response to
NAS Comments, and post the final non-cancer assessment to the
Integrated Risk Information System (IRIS) by the end of January 2012.
After completing the non-cancer portion, EPA will finalize the cancer
portion of the dioxin reanalysis as quickly as possible.
The decision to split the dioxin assessment into two
portions, one being the cancer assessment and the other being the non-cancer
assessment, follows the release by the Science Advisory Board (SAB) of its
final review report of EPA’s Reanalysis of Key Issues Related to Dioxin
Toxicity and Response to NAS Comments on August 26, 2011. This
reanalysis report responded to the recommendations and comments included in
the National Academy of Sciences' (NAS) 2006 review of EPA's 2003 draft
dioxin assessment.
The SAB report indicates that EPA selected the most
appropriate scientific studies to support the non-cancer health assessment
and the oral reference dose derived in the draft assessment. The SAB also
commended EPA for a clear and logical reanalysis document that responded to
many of the recommendations offered previously by the NAS. Specifically, the
SAB acknowledged that the process the agency used to identify, review and
evaluate the scientific literature was both comprehensive and rigorous, and
the SAB report noted that "the criteria for study selection have been
clearly articulated, well justified, and applied in a scientifically sound
manner."
Dioxins are toxic chemicals that share a similar chemical
structure and act through a similar mechanism. While dioxin levels in the
environment have been declining since the early seventies, dioxins remain a
concern because they will continue to enter the food chain through releases
from soils and sediments, and they have been the subject of a number of
federal and state regulations and cleanup actions.
EPA is urging a Science Advisory Board (SAB) panel reviewing
the agency's re-assessment of dioxin to focus on the core
risk assessment document, not related risk and regulatory
documents, saying the agency has been working on the measure
for decades and is “really unlikely” to meet Administrator
Lisa Jackson's December 2010 deadline for completing the
measure.
Peter Preuss, director of EPA's National Center for
Environmental Assessment, urged the panel in July 13
comments to help agency staff quickly complete the
long-delayed assessment, by focusing on recommendations the
agency could complete in a reasonable amount of time.
“Our goal is simple. We’d like to finish this document,”
Preuss said. “Twenty-one years ought to be enough gestation
time to finish just about anything.”
But a speedy panel review may be unlikely as the agency's
draft document is already drawing significant concerns from
industry and others (see
related story).
The SAB panel is meeting July 13-15 to review EPA’s response
to the National Academy of Sciences (NAS) review of its 2003
draft assessment of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD) -- the most toxic form of the ubiquitous class of
chemicals and the basis for estimating risks of mixtures of
dioxins and related compounds at contaminated sites. The NAS
in 2006 suggested several changes EPA needed to make to its
2003 assessment.
The SAB panel meeting is the first of two meetings the panel
will hold as it conducts its review of the document, which
includes newly calculated cancer and non-cancer risk
estimates for TCDD, released in May.
Jackson in a
May 2009 letter to
community activists said the agency’s “goal is to issue a
final dioxin assessment by the end of 2010." But Preuss, who
oversees the center that crafts assessments for the agency’s
key Integrated Risk Information System (IRIS) database, told
the SAB panel that the agency “is really unlikely” to meet
Jackson's goal “unless SAB sends a one-page letter” saying
that the dioxin document does not require any changes.
Dioxin is a ubiquitous contaminant produced from combustion
and other industrial processes. It is persistant and exists
in fatty foods, such as meat and dairy products. The agency
published its current IRIS assessment of dioxin in 1985, and
began reassessing the risks of TCDD in 1990. But the
reassessment has faced numerous delays and reviews.
In his remarks, Preuss urged the panel to separate any
long-term recommendations from those short-term suggestions
needed to finalize the document, noting that that “many
things” are awaiting the outcome of the assessment,
including regulations and site cleanup decisions.
Jackson’s broader dioxin plan includes two other related
documents: a set of cleanup targets, known as preliminary
remediation goals (PRGs), which were to be published before
the agency finalizes the TCDD assessment, and used until
that time. The agency has yet to finalize those preliminary
numbers, with industry complaining bitterly about the
confusion that interim numbers could present.
EPA also released last fall a document adopting a set of
World Health Organization factors, known as toxicity
equivalency factors, or TEFs, which are used to estimate the
potency of mixtures of dioxins and dioxin-like compounds
relative to TCDD.
But Preuss urged the panel to focus its energy on the TCDD
assessment itself, and not get bogged down in discussions of
the related documents. “You’re likely to hear about TEFs and
PRGs [in the public comments],” Preuss said, “but they are
not part of our document.”
Industry toxicologists and consultants, disagreed, however,
arguing that many of the studies on which EPA based its
assessment include exposures to mixtures of dioxins -- not
TCDD alone. As a result, the board needs to consider the
effects of these confounding exposures on the data, they
argued.
Status May 21, 2010
EPA Dioxin Reassessment moving
forward after decades of delay?
WASHINGTON - The U.S. Environmental
Protection Agency (EPA) has reached a significant milestone toward the
completion of the agency’s dioxin reassessment with the public release
of its draft scientific report, EPA’s Reanalysis of Key Issues Related
to Dioxin Toxicity and Response to NAS Comments.The draft dioxin report is EPA’s response
to key comments and recommendations made by the National Academy of
Sciences on the agency’s draft dioxin reassessment.EPA is moving forward with Administrator
Lisa P. Jackson’s commitment to complete the long-awaited dioxin
reassessment. This comprehensive human health and exposure risk
assessment on dioxin, one of the most toxic environmental contaminants,
aims to protect the health of the American public. The draft report will
now undergo scientific peer review by independent, external experts as
well as public review and comment.
Oct 2004 EPA released the NAS
External Review Draft of the Dioxin Assessment, in
preparation for the first NAS panel meeting (held 11/22
-23/2004), in Wash., DC. This is still the most current
version of the EPA Dioxin Assessment.
STATUS March 11, 2009. Environmental Protection Agency said this week that it will try to speed the
release of its reassessment of dioxin, a chemical that has contaminated
Michigan’s largest watershed. “The new administration is familiar with the
history of this issue and will be focusing on expediting the study,” EPA
spokeswoman Suzanne Ackerman said this week.
“We’re pleased to hear EPA plans to expedite the study,” said Mike Schrade of
the Virginia-based Center for Health, Environment and Justice, which together
with 100 other groups sent a letter to the Obama administration in late January
asking that the dioxin reassessment be released.
STATUS October 5, 2007. EPA is poised
to issue a plan detailing how the agency will address recommendations from
the National Academy of Sciences (NAS) for improving its risk assessment of
dioxin, a move that will provide a long-awaited guide on the agency's future
efforts but could prolong uncertainty over how to regulate the ubiquitous
contaminant. Although the plan for responding to NAS will be released
in approximately a month, an agency source says EPA may not have a revised
risk assessment available for peer review for up to two years, and may not
ultimately develop a full toxicological profile for dioxin because the
agency's current responsibility "is to respond to NAS." The source
says developing a profile for the Integrated Risk Information System (IRIS)
-- which contains agency risk data used by state and federal officials to
set health and cleanup standards -- would be the "logical next step" after
preparing the response, but internal discussions of the agency's long-term
dioxin efforts remain unsettled. In July 2006 NAS released its highly
critical report -- Health Risks from Dioxin and Related Compounds:
Evaluation of the EPA Reassessment -- finding among other things that EPA's
2003 draft risk assessment did not adequately characterize the uncertainties
associated with different approaches to dioxin's cancer risks..snip..
Activists and public health advocates have long been critical of the pace of
EPA's dioxin efforts, which began in 1991 with an agency announcement that
it would proceed with an initial draft reassessment. In the intervening
years the substance has generated significant controversy, including an
industry push earlier this year for the Supreme Court to review whether EPA
cleanup orders at an Arkansas site contaminated with dioxin were unlawful
because of the lack of clarity over the substance's risk level. The delay on
dioxin has meant significant uncertainty for cleanup officials, including at
sites such as the Dow Chemical Company headquarters in Midland, MI, where
activists for a number of years have demanded action. Nevertheless, EPA is
only now coming around to responding to the NAS critique, the agency source
says, adding that limited resources may have contributed to the delay.
"There have been all these big IRIS assessments" -- such as
trichloroethylene and perchlorate, in addition to dioxin -- "and for all
these highly visible chemicals, there's just a finite number of people to
work on them," the source says..snip.. The source adds that the response may
be made available for peer review only in pieces and will likely not be
available in any form for at least a year. "Some NAS questions will be
pretty hard to answer," the source says, because the critique "was a
prescription for a lot more work." The source says EPA is now looking for
individuals within and especially outside the agency who can assist with
different parts of the response because of their expertise in a given field.
"We're sitting down and deciding what parts to bite off and deal with," the
source says, adding that the work plan is "a month away." Gathering needed
outside expert assistance will likely prolong the effort, the source says,
because of the time involved with going through the grant-making and
contracting process. -- Adam Sarvana. Source
InsideEPA.com, visit for all the details.
STATUS: November 2004. A White House science official
in a surprise move announced plans to release a report on dioxin in an apparent attempt to
show administration progress on monitoring and controlling for the highly controversial
pollutant. But the move has already drawn protests from environmentalists who say
development of the report will likely further delay release of EPA’s dioxin risk
review, which has been 13 years in the making. ... But an environmentalist at the meeting
dismisses the value of the new report in assessing public health risks from dioxin.
"This [progress report] is largely a public relations exercise that mirrors the
industry line about declining industrial emissions" even though EPA’s own
findings show that current body burdens may pose public health risks that require more
immediate action, the source says. ... The environmentalist says EPA’s inability to
release its dioxin risk review, which has undergone numerous scientific peer reviews, has
prevented a host of state and local governments from taking action on contamination that
continues to pose threats to their residents. "Local governments lack the resources
to carry out this kind of risk assessment and are waiting for this to be completed before
they can start cleanups. But now it looks like it will be at least another two years
before it is finalized," the source says
STATUS: October 2004 Dioxin Reassessment report. The
USEPA has updated the dioxin reassessment report and sent its most recent draft to the
National Academy of Sciences for their review. This draft is dated December 2003 and
was sent to the NAS in October 2004. The entire report has been updated including
the sources section (Part I), the health effects section (Part II) and the risk
characterization (Part III). The complete updated draft report can be found at:
http://www.epa.gov/ncea/pdfs/dioxin/nas-review/
. Source: www.chej.org
STATUS: July 2004 Dioxin Reassessment report. The
release of the U.S. EPA’s Dioxin Reassessment Report, a study on the sources and
health risks of our exposure to dioxin that has been 16 years in the making, continues to
be delayed for an indefinite period of time.An
Interagency Working Group (IWG) reviewed the dioxin reassessment report in 2003,
communicating a level of concern to EPA that triggered a request for the National Academy
of Sciences to conduct another review of the science.The IWG is co-chaired by the Department of Health and Human
Services (HHS) and the Department of Agriculture (USDA), agencies that have an overriding
interest in minimizing the economic impact of dioxin regulation on the cattle, dairy and
other food industries.Inside sources have
revealed to CHEJ that although the funding has not yet been given to the National Academy
for its review, HHS and USDA have finally settled on their charge to the committee:to find anything that is not perfect about the
draft reassessment!This fishing expedition
is just one more piece of evidence that the Administration’s over-riding concern is
to keep this potentially explosive report sitting safely on a shelf until well after the
November elections – in fact, for as long after that as possible. Source:
www.chej.org
STATUS: On October 29,
2003, the Interagency Working Group on Dioxin (IWG) officially requested that the National
Academy of Sciences (NAS) review EPA’s draft dioxin reassessment. The statement of
work to the NAS was also transmitted on October 29th. The review by the NAS is expected to take
approximately 15 months. At the time that the NAS review of the draft
dioxin reassessment commences, EPA plans to
make available on this website the version of the dioxin reassessment that is
undergoing NAS review.
EPA
has completed revision of the draft reassessment in response to SAB and public
comments.The draft reassessment has also completed final internal EPA review. The next
step for the draft reassessments a review by the Interagency Working Group on Dioxin
(IWG). The Dioxin IWG is convened under the auspices of the White House Office of Science
and Technology Policy, and is made up of federal agencies that address issues related to
health, food, and the environment. These agencies are working together to ensure an
integrated federal approach to dioxin related issues.
Because the Agency is committed to ensuring that the reassessment has a
strong scientific foundation, EPA will seek the recommendation of the IWG regarding the
need and benefit of further review of the reassessment by the National Academy of Sciences
(NAS). EPA recognizes that in situations such as this, where our own SAB was unable to
reach consensus on key scientific issues of importance to other federal agencies, it is
often appropriate for the NAS to provide additional review of those issues. Therefore, if
recommended by the IWG, the Agency will send the draft reassessment to the NAS for further
review and analysis.
The MDEQ meeting 11/7/08 revealed that
Riverside Boulevard
Dr. Linda Birnbaum’s presentation
to the locals on April 13, 2005 was enlightening to many of 150-200
attendees on both sides of the issue. Overall, the presentation was very useful
and we appreciate her efforts to update our community on the latest in dioxin
science. However, a portion of the presentation deviated from science and moved
into the realm of speculation, adding more questions than answers to an
extremely complicated contamination issue.
