TRW Archives 2007 3rd quarter 07/01/07 - 09/30/07
09/28/07
Tittabawassee River EPA Dredging Pollution Reports
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 latest EPA "Pollution" reports which summarize the progress
made so far on reach D, J-K, and O:
 |
Reach D as
of September 28
 |
 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 |
|
| Reach
J-K as of September 28
|
 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.
Remedial action includes the planting of over 400 trees.
|
| 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. |
|
|
Reach O as of September 28
|
 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.
|
|
For additional information and
past progress reports, click here
09/27/07
Lone Tree
Council / TRW Dioxin Update
I
hesitated only briefly to use the Dioxin Update format to beg your attention
to a less obvious aspects of the budget battle and our local contamination.
Let me share some information with you prepared by people much smarter than
myself. It is my sheer love and appreciation of this state's natural
resources that I ask you to read on. Folks this is about our Great
Lakes........and I submit to you any legislator who thinks funding of Great
Lakes protection is not a priority deserves to be booted in the next
election.
Water quality is
a public health issue and it is a huge economic issue. Tourism is our third
leading industry, it is incumbent on clean water, beaches and fish. Look at
Saginaw Bay, muck, dioxin, sewage, phragmities, fecal
material.........monitoring, investigation, enforcement and cleanup are not
free. DNR and DEQ should not be on the chopping block. They have taken
enough hits.
Our legacy, like
our history, should be rich in stories and experiences with these
lakes. Report after report demonstrate declining water quality, closed
beaches, increasing issues with invasive species, toxic build
up,..............
Are the lakes a
priority for you? Click on the link below and then let the Governor and
your legislators know you stand with our great Great lakes.
Michigan's Great Outdoors suffering
from budget cuts
The following was pilfered from
Dave Dempsey's blog
http://daviddempsey.typepad.com/
The Department of Natural Resources and Department of
Environmental Quality have suffered a 62 percent decline in funding
since 2001. This decline is not at all proportionate to overall
declines in statewide funds: for the same period, total general
fund spending dropped only 6 percent. Please
go to the Michigan League of Conservation Voters and read more.
http://www.michiganlcvedfund.org/
snip:
In Saginaw, increased budget cuts
to the DEQ would have consequences for local citizens. "The most
pervasive toxic contamination in the state threatens Lake Huron. The DEQ
has worked five years to bring the responsible party, the Dow Chemical
Company, to a point where some dioxins and other toxics are being
removed. What happens if the DEQ's budget is cut again? What happens to
our rivers, our lakes, our drinking water, our fisheries, if our first
line of defense is hamstrung by budget cuts," said Lone Tree Council
Chairperson Terry Miller. "And the DEQ's Saginaw Bay Coastal
Initiative, an effort to deal with the shoreline muck, invasive species,
and sewer overflows -- do we just tell people to hold their noses and
hope?"
snip:
Howard Tanner, former Director of
the DNR expressed his concern over the report's conclusions. "Michigan
was once a leader on conservation and environmental protection of our
vast natural resources. Somehow that trend has been reversed and our
leadership in conservation has been tarnished. It is up to our leaders
in Lansing to work together to return to our once proud legacy of
environmental stewardship by properly funding the DNR and DEQ."
Michelle Hurd Riddick
Lone Tree Council
09/23/07
Tittabawassee River EPA Dredging Pollution Reports
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 latest EPA "Pollution" reports which summarize the progress
made so far on reach D, J-K, and O:
|
Reach D as
of September 20
|
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 |
|
| Reach
J-K as of September 21
|
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.
Remedial action includes the planting of over 400 trees.
|
| 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. |
|
|
Reach O as of September 21
|
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.
|
|
For additional information and
past progress reports, click here
09/15/07 Loss of Community Identity
Here we go again.
One of today's
headlines was the announcement that The Dow Chemical Company will now be the
major sponsor for The Bay City River Roar every summer. By doing so, the
event will now be called The Dow River Roar.
Huh?
It's fine and dandy if Dow wants to
contribute money to that event, but why must it now be named after the
company? For $35,000, it appears Bay City was willing to sell the name of
one of it's major summer events. It has been The Bay City River Roar for 20
years. That's pretty sad.
Flashback to about, what, 3 years
ago....
Yes, you all know what I'm talking
about. Even today when the subject is brought up, people from all walks of
life in Saginaw that I talk to roll their eyes in disgust at the mention of
The Saginaw Civic Center, now known as The Dow Event Center and referred to
as "The Dow".
Yes, Saginaw sold the name of our event
center to Dow Chemical as well for $250,000 a year. Just the name mind you,
not the building itself. But now, every event held in our event center has
Dow mentioned in the story or event. Not Saginaw. What ever happened to
Saginaw?
Pick up our local Saginaw newspaper on
any given day lately, and I swear some days there are more articles about
Midland than about Saginaw County. Midland has their own paper. If I want
to read about Midland, I can pick up one of their papers.
Has anyone also noticed that just about
every other event held in the Tri-cities lately has Dow as a sponsor as
well? Again, there is nothing at all wrong with the company's generosity in
wanting to contribute to local events, they have a lot of money to work
with.
But I want to know where Dow was for the
past 100 years they have been operating in Midland. Up until about 5 years
ago, most of us only knew Dow as that company up in the polluted city
of Midland that smells, and has all the buildings and events named after
them. So what happened 5 years ago to produce such a sudden interest in Bay
City and Saginaw after 100 years?
I think you know the answer.
I just hope that the struggling
communities of Bay City and Saginaw don't lose site of who we are. Stop
selling our names. As we all know, there is a price, a certain loyalty
expected from a company for such generosity. I for one, want no part of
becoming "Stepfordville" aka Midland.
Kathy Henry
09/14/07 Restoring Great Lakes would reap region $50 Billion windfall
A report published by the Brookings Institute September 5, 2007 titled "Great
Lakes cleanup could generate $50 billion windfall states "(Investing in
cleanup) makes tremendous sense in terms of the economic strategy for our region
and our country. These restoration activities aren't just nice things to
do for the environment".
The report concludes that increased residential property values are the
primary contributor to the windfall. An additional $30 billion would be
gained due to new job related activities.
Local officials are concentrating on scaring the public into stopping the
clean up. Why?
Click here for the
Detroit News coverage of the report or visit
http://www.healthylakes.org to
view the report.
09/14/07
Tittabawassee River EPA Dredging Pollution Reports
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 3 EPA "Pollution" reports which summarize the progress
made so far on reach D, J-K, and O:
|
Reach D as
of September 12
|
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 |
|
| Reach
J-K as of September 13
|
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. |
|
|
Reach O as of September 13
|
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.
|
|
For additional information and
past progress reports, click here
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."
 Citizens
were denied an open and transparent process back in 2005
when Lt. Governor John Cherry signed the infamous "framework" agreement.
What's next? Will
the EPA propose or mandate a new plan, sue Dow for
the missing information, or just walk away? We doubt it's the latter, stay
tuned.
Click here to view the
entire EPA press release.
09/06/07 First
dioxin-contaminated soil removed from Tittabawassee River !
Local TV station
WJRT TV
reports that the 1st load of an estimated 15,000 cubic yards of dioxin
contaminated soil has been removed from the
Reach D section
of river sediment located in the Dow Chemical plant. This is great news!
Reach D is a 1,200 foot section of river located entirely on Dow Chemical
property, only 114,000 feet remain to complete
the cleanup.
Click here for the latest EPA Reach D progress report
09/05/07
Tittabawassee River EPA Dredging Pollution Reports
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 2 EPA "Pollution" reports which summarize the progress
made so far on reach O and J-K:
08/31/07 EPA Issues Demand for Midland
Dioxin Data
THE TRUTH WILL SET YOU FREE
BELOW IS A PRESS RELEASE FROM EPA . THE AGENCY IS ASKING
THE CITY OF MIDLAND TO RELEASE SAMPLING DATA FOR THE PAST TWO YEARS WITHIN
THE CITY OF MIDLAND. THIS INFORMATION IS PUBLIC AND SHOULD NEVER HAVE BEEN
KEPT FROM THE PUBLIC.
CONTACT: Karen
Thompson, 312-353-8547, thompson.karen@epa.gov
For Immediate Release
No. 07-OPA151
EPA ISSUES
DEMAND FOR MIDLAND DIOXIN SAMPLING DATA
(Chicago - 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.
# # #
08/27/07 Tittabawassee and Saginaw
river
fish consumption still a hazard
The Michigan Department of Community Health has released a report of its
"Fish Consumption Survey of People Fishing and Harvesting Fish from the Saginaw
Bay Watershed." The final report is available at
www.michigan.gov/mdch-toxics.
Funding from the Saginaw Bay Watershed Initiative Network made the survey
possible.
The department asked people fishing on the Tittabawassee, Saginaw and
Shiawassee rivers and Saginaw Bay if they were aware of and used the advisory.
The department also asked them what fish they were catching and eating and use
the information to improve the advisory and increase public awareness of safe
consumption of locally caught fish.
One troubling finding of the survey is that many people are eating carp,
catfish and white bass that contain high levels of dioxins and other
environmental contaminants. The department recommends against eating carp or
catfish from the Tittabawassee and Saginaw rivers, and to extremely limit
consumption of white bass. There are similar recommendations for eating fish
from the bay. Walleye are less contaminated. River sediments and eroding
floodplain soils have created dioxin and other contaminants in the fish.
These findings are a concern, considering that the University of Michigan
Dioxin Exposure Study has shown that eating fish from the rivers and bay is
linked to higher levels of dioxins in humans. The study shows some people may be
eating more fish than the people who were part of the study.
Until dioxins and other contaminants are removed from river sediments and
upland soils, eating certain fish from these waters will continue to pose a
hazard. The department is working with local community groups in Saginaw to
increase awareness of the advisory and safe consumption of locally caught fish.
The advisory is available at
www.michigan.gov/mdch or by calling (800) 648-6942.
T.J. Bucholz
Public Information Officer
Michigan Department of Public Health
Lansing
Click here
to view "Fish consumption survey of people fishing and harvesting fish from
Saginaw Bay Watershed 06/14/07"
08/25/07
Dow deletes agent orange details from
Wikipedia
Who do you trust?
Excerpt from Forbes 8/15/07 article
"... someone on a Dow Chemical computer deleted details of the
company's development of birth defect-inducing Agent Orange and the continuing
controversy around the Bhopal disaster, in which Union Carbide, a firm that Dow
later acquired, was responsible for the death of as many as 22,000 Indians. "
... "Wikipedia has always been a truth tool," says Michael Fertik, founder of
the online PR firm Reputation Defender. He argues that companies should have
known better than blatantly to skew information on a site that tracks IP
addresses and closely monitors articles for spin. ... "It's our
policy never to delete anything from Wikipedia," Fertik says. "People have been
aware for a long time about who's doing what on the site, and changes are
observed very closely. If you get in the business of deleting this or that, you
can easily get in a flame war with the whole community."
To read the entire article go to
http://www.forbes.com and search for "wikipeida"
08/22/07
Lone Tree
Council / TRW Dioxin Update
|
Petitioned Health Consultation on the Saginaw River
|
It's
been awhile but we did hear the our petitioned health consultation to
ATSDR ( Agency for Toxics Substance and Disease Registry) may be
completed by Michigan Department of Community Health and submitted to
the agency for their comments by summers end. The petitioners, 20 plus
residents, two physicians and several environmental groups petitioned
ATSDR and MDCH for a public health assessment for the following reasons
.... |
|
|
Summary of DEQ/DOW meeting August 9th
|
Hot Spot |
|
City of Midland
 |
is keeping secreted away with the law
firm of Miller Canfield data on soil sampling/locations in the
city. |
|
|
U of M Study
|
The regulatory agencies have yet to
receive the requested data from Dr. Garabrant's U of M Exposure
Investigation. This is the data requested 18 months ago....acknowledged
the study data has not gone through the rigors of peer reviewed
journals. (Which has not stopped Dow from marketing it to every
elected/public official who will listen to them)
|
|
|
Saginaw River New High
|
32,000 ppt was found in the 6th street
turning basin in a bed load sample- meaning the dioxin was at the
sediment surface and mobile. Concentrations varied between
non-detect and 32,000 ppt. |
|
|
Sediment Trap Studies
|
"The Saginaw
River is a significant source of dioxin to the Great Lakes. The
floodplain soils as well as the sediments within the watershed are
highly contaminated with dioxins and furans. Much, if not all of
this contamination is thought to have originated in Midland.
Throughout much of the twentieth century, hydraulic forces within
the watershed have dispersed these contaminants downstream
throughout the Tittabawassee and Saginaw River Watershed. Currently
dioxin and furan contaminated sediments can be found extending into
Lake Huron. " |
|
| Sampling of the middle
Tittabawassee River |
| Dow is gaining access |
| MDEQ use of 90 ppt is
supported by EPA
|
"In addition, U.S. EPA
believes that MDEQ’s default dioxin cleanup criteria of 90 ppt is
entirely consistent with U.S. EPA's residential cleanup level when
both levels are normalized to the same target risk goal. |
|
|
|
A Journal, TOXICOLOGY states
dioxins most potent in humans
|
Comparison of the
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)-induced CYP1A1 gene
expression profile in lymphocytes from mice, rats, and humans:
Most potent induction in humans. |
|
|
Dioxin in Georgetown MA being
cleaned
|
Georgetown Massachusetts has soil contaminated with
4 ppt to
100 ppt
of dioxin in a junkyard and the state’s DEP (Department of Environmental
Protection) and the Conservation Commission are insistent it be cleaned
up to protect the environment and water supply. Our concentrations
sediments and soils exceed
80,000
ppt
and have been flushed down river into yards, parks, farm fields and out
to Lake Huron for decades.
|
|
Click here to view
the entire update
08/15/07
Tittabawassee River EPA Dredging Pollution Reports
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 2 EPA "Pollution" reports which summarize the progress
made so far on reach D and J-K:
08/13/07 Thank you
I just wanted to take a quick moment to thank you for all
the time and energy you have put into your website. I live
in Cleveland and just wrote a paper titled Midland,
Michigan: Dow Chemical's Personal Waste Land. Your website
was a God send while doing research. It's hard to find
reliable sources on the internet and through links on your
site I was able to complete my research without having to
search web results.
I wish you all the best in your cause.
Thank you,
Tonya Moening
08/9/07 MDEQ Dioxin Meeting Tonight
The
Department of Environmental Quality and The Dow Chemical Company are
hosting the next quarterly Midland/Saginaw/Bay City (Tri-Cities) Dioxin
Community Meeting at 6:30 p.m. on Thursday, August 9, 2007, at the
Horizons Conference Center, 6200 State Street, Saginaw. This meeting is
open to the public. The press release and agenda for the meeting are
available at:
http://www.michigan.gov/deq/0,1607,7-135-3308-173383--,00.html and
http://www.michigan.gov/documents/deq/deq-whm-hwp-dow-commMeetingAgenda2-8-09-07_204971_7.pdf
Supporting materials are available at the following location:
http://www.michigan.gov/deq/0,1607,7-135-3312_4118_4240-53424--,00.html
Cheryl Howe
Environmental Engineering Specialist
Hazardous Waste Management Unit
Hazardous Waste Section
517-373-9881/517-373-4797 Fax
08/9/07 Comments on Dioxin
Exposure, Richard A. Maltby, AICP
DIOXIN
EXPOSURE by Richard A. Maltby, AICP August 3, 2007
While reading Midland County Environmental Health Services Director Chuck
Lichon’s article, “Dioxin: A
difficult-to-define molecule entangled in hypothetical fears” (The Bay City
Times, July 31, 2007), we should all be aware that the Michigan Department of
Community Health continues to recognize the danger of exposure to dioxins.
For example, the state Department of Community Health says: “Not all dioxins
have the same toxicity or ability to cause illness and adverse health effects.
The most toxic chemical in the group is 2,3,7,8-tetrachlorodibenzo-para-dioxin
(2,3,7,8-TCDD). Because it is the most toxic, 2,3,7,8-TCCD is the standard to
which other dioxins are compared. The levels of other dioxins measured in the
environment are converted to a ‘2,3,7,8-TCDD’ equivalent concentration based on
how toxic they are compared to 2,3,7,8-TCDD. These converted dioxin levels are
then added together to determine the total equivalent (TEQ) concentration of the
dioxins in a sample.”
The state Department of Community Health also reported that it is not known
whether people exposed to low levels of dioxins will experience the same health
effects as seen in animal studies.
However, based on the available information, dioxins are believed to have the
potential to cause a wide range of adverse effects in humans. The U.S.
Environmental Protection Agency has characterized the mixture of dioxins to
which people are usually exposed as “likely human carcinogens.” The EPA has also
characterized 2,3,7,8-TCDD as a “human carcinogen.” The U.S. Department of
Health and Human Services lists 2,3,7,8-TCDD as a substance “known to be a human
carcinogen.”
Furthermore, the National Research Council of the National Academy of Sciences
recently informed us that 2,3,7,8-TCDD is among the most toxic anthropogenic
substance ever identified. Animal studies have demonstrated potent effects of
TCDD, including tumor development, birth defects, reproductive abnormalities,
immune dysfunction, dermatological disorders, and plethora of other adverse
effects. Because of their persistence in the environment and their
bioaccumulative potential, TCDD and other dioxins, are now ubiquitous
environmental pollutants and are detected at low concentrations in virtually all
organisms at higher-trophic levels in the food chain, including humans.
Inadvertent exposures of humans through chemical waste byproducts, industrial
accidents, occupational exposures to commercial compounds (primarily phenoxyacid
herbicides), and through dietary pathways have led to a wide range of body
burdens of TCDD and other dioxins and numerous epidemiological studies to a
variety of adverse effects in humans. As a practicing professional urban and
regional environmental resources planner for 38 years, I am inclined to say it
would be wise to take precaution with exposure to dioxins and other
environmental pollutants than to be sorry.
08/09/07
Tittabawassee River EPA Dredging Pollution Reports
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 3 EPA "Pollution" reports which summarize the progress
made so far:
07/26/07
Lone Tree
Council / TRW Dioxin Update
|
Photos of
Reach D contamination |
|
DEQ Directors Chester's Comments |
|
Comments on Dow's Delayed,
Deficient Work |
|
Some Good News |
|
Dow/DEQ public meeting |
Click here to view
the entire update
07/25/07 DEQ Director responds
to Saginaw News editorial
I was disappointed to read The Saginaw News editorial that criticized the
progress being made by the Department of Environmental Quality to move the
dioxin cleanup in the Midland and Saginaw areas forward. ("Finally, EPA is
flexing muscle," July 5)
Much of the work done over the past one to two years has focused on gathering
an immense amount of data, and while this work may not be noticeable to the
public on a daily basis, it is absolutely vital in helping our agency and Dow
Chemical Co. understand the scope of the contamination problem and how we can
best address it.
The U.S. Environmental Protection Agency recently did
issue removal
orders to Dow, effectively telling the company that it needs to accelerate
plans to remove some of the most highly contaminated areas in the Tittabawassee
River. What was missed in the editorial, however, was that this would not have
been possible without the work already completed by the state.
In fact, the work that began this month to remove a section of that
contaminated sediment from the river already was scheduled to begin prior to
EPA's orders.
As the editorial suggests, Dow did submit a cleanup plan Dec. 1, 2005, that
was intended to provide the next steps in the cleanup process. Despite the state
DEQ providing Dow with substantial detailed guidance on exactly what needed to
be addressed, its proposal was found to be so deficient by both the
Department
of Environmental Quality and
EPA that we simply had to request an entirely new cleanup plan. Dow's plans
lacked detail in determining the size and scope of the contaminated area, the
necessary follow-up investigations and did not even address human health risk
assessment studies. Furthermore, the company's plan provided a schedule that
would not have remediation begin until 2017 even under the best case scenario.
Clearly, this was unacceptable to both the DEQ and EPA, and the major revisions
that would be required were clearly detailed in the DEQ's 43 pages of comments
sent back to Dow.
Again, it was not a simple "no" as the editorial stated.
Rather than wait for a new work plan and miss the 2006 sampling season, the
DEQ required Dow to submit sampling plans for the Upper Tittabawassee and the
city of Midland. A process was approved quickly and generated 3,800 samples that
were analyzed for dioxins and furans within the floodplain and river sediments
and 400 samples from the city of Midland. This is the process that ultimately
led to the cleanup actions that began this month, and the investigation of the
next 11 miles of the Tittabawassee River and floodplain will continue this
summer.
The DEQ and Dow have co-hosted quarterly community meetings where all of this
information has been presented to the public, and we would welcome your
assistance in sharing this information with those who cannot attend. The DEQ
intends to continue our work with the local community, Dow and the EPA as we
make meaningful progress on this complex issue.
Steven E. Chester
Director, Michigan Department of Environmental Quality.
07/24/07 EPA website describes
1200 foot cleanup site- only 114,900 ft to go
https://www.epaosc.net/tittabawasseeDioxinReachD
  
 
 
   
07/12/07 MDEQ responds to EPA
criticism of Dow's RIWP
The MDEQ and the EPA are in disagreement over some
of the
EPA's critique (see next story for details) of Dow's
Remedial Investigation Work Plans (RIWP) Tittabawassee
River cleanup process:
Many of the issues raised concern the
GeoMorph process which attempts to predict contaminated areas.
Both the MDEQ and the EPA expect Dow to conduct additional sampling in the areas
identified by the process as priority cleanup areas to validate the the plan.
So far, this has not happened. In our opinion, the disagreement hinges on
the attitudes of the players:
| Delay: Dow is reluctant to
perform additional sampling and dragging it's feet whenever possible |
| Pretty Please: The MDEQ is asking
for samples under the conditions of their
"Framework" agreement with Dow |
| Do it: The EPA is mandating them
to comply. |
Not mentioned in the MDEQ response is any reference
to all of the other toxic chemicals discovered and mentioned in the EPA
document. What are the plans of the MDEQ to address the silicon, Octachlorostyrene , Hexachlorobenzene, Aldrin,
Dieldrin, Fhloradane, DDT, Mirex, and Toxaphene?
As residents who live in Dow's toxic soup, we
really don't care which organization makes Dow accountable so long as it happens
soon. We appreciate the efforts of most of the MDEQ's staff, they are
dedicated professionals who are being prevented from doing their job by
backroom politics and are fighting with both
hands tied behind their back. Anything the EPA can do to move this process
along is a good thing.
Click here to read the MDEQ's response in detail
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]:
Anthracene
Benzo(a)anthracene
Benzo(g,h,i)perylene
Perylene
Phenanthrene
Click here to view the entire document
07/09/07
Lone Tree Council / TRW Dioxin Update
Removal of dioxin hotspots- AMEN!
| It's taken five years but
the removal of these sediments in Reach D is reason to celebrate. It is
however only the first step, one of many, many steps needed to restore
the river system in the Saginaw Bay Watershed. Savor the moment.
|
About the EPA
Press Release
Ripping into DEQ
unwarranted
| The
Saginaw
News editorial comment from Thursday July 5th was
outrageous. Totally at a loss to explain where the SN editorial
board gets their information. While I respect their right to editorial
license and commentary the Saginaw News has a responsibility to its
readers to speak with some semblance of accuracy. Below are two of many
outrageous comments from the editorial followed by some information and
perspective in bold print: |
1"
Apparently there has been no real sense of urgency here. Does it
take four years for Dow to acquire all the various state permits and
wrap up the required paperwork to close this deal, especially if the
company has worked on it like the DEQ's Siamese Twin. The
delays are NOT due to four years of failure by the state to issue
permits
and
wrapping up the required paperwork requires Dow Chemical to submit
acceptable work plans to the state. Section
XI of Dow's license lays out clearly and concisely what is
expected of Dow Chemical. If fact the license was hammered out with Dow
Chemical over a number years.
DEQ hit the ground
running in 2003 with a sense of urgency. When Dow realized in 2004 that
DEQ was going to enforce the license ( including soil testing in
Midland) you remember what happened? Dow called out their legislators
who threatened to gut
DEQ's budget, eliminate the Hazardous Waste Division overseeing
the cleanup and they went to the Michigan Economic Development
Corporation to threaten Governor Granholm with jobs. Like Blanchard and
Engler, Dow also got what they wanted from Granholm…….to
go behind closed doors for 8 months and derail the established
process and timeline for sampling, interim response activities and work
plans. HUGE DELAY- that had nothing to do with permits.
In 2003, 2004, 2005,
2006 and 2007 Dow Chemical submitted numerous plans to the DEQ which
have been rejected by DEQ and EPA as
“deficient”, “incomplete” or “ critically deficient”. Memos
and documents reveal Dow’s failure to follow the "corrective action
process" , failure to follow established "scientific guidelines" and
"regulatory guidelines" as well as their (Dow) failure to submit to
timelines, details, and public scrutiny. Again, nothing at all to do
with permits. Other memos detail Dow’s failure to send decision makers
to meetings so that activities could advance. Others detail identify Dow
not sharing information with the regulatory agencies.
A June 14th 2006 EPA
document addressing Dow' penchant for studies states:
"The scientific basis for the proposed extensive (and
time intensive) exposure studies, and bioavailability study does not
appear to be legitimate. Rather, these studies appear to be
intended to delay the remediation process."
How about this
August 2005 memo from EPA:
"EPA and MDEQ have concerns with the manner in
which Dow is conducting corrective action. Concerns include:
apparently concealed data which was produced by unapproved studies
conducted over the last 2 years (License violation); unrealistically
short time frames for MDEQ to review work plans (Framework
Violation); performing corrective action studies without approved
work plans; and Dow’s unwillingness to meet with MDEQ to discuss
work plans. "
2 " We're
no apologists for Dow, which certainly isn't blameless in this matter.
But in its defense it has done what DEQ has asked with no guidance from
the state agency". Over
the past few years Lone Tree Council has amassed thousands of pages of
documents, emails, letters, memos and CD's giving detailed responses and
guidance from DEQ to Dow Chemical. Many of these in response to Dow's
chronically deficient work plans ........plans required by law in the
corrective action license Dow signed in 2003.
These documents, many obtained using the Freedom of Information Act
clearly show DEQ and Dow have met over 150 times in the past three years
in-group meetings or phone conferences. From detailed handwritten
notes, lengthy e-mails with attachments, to Power Points and algorithms,
DEQ could not have given more guidance to Dow. Dow's repeated failure
to address their legal obligations is by design.
This corrective action
is resource intensive. Dow is unnecessarily monopolizing DEQ's
staff
time and taxpayers dollars with their deficient work plans, delays and
public manipulation of the cleanup process. If DEQ is guilty of
anything it is the failure of the agency to right out the entire plan
for Dow and then enforce it. Leveling unfounded accusations at DEQ, as
the Saginaw News did, is being an apologist for Dow Chemical. " No
guidance from the state agency" is just an unfounded, baseless, untruth
which plays well to the anti-regulatory, DEQ bashing faction in this
community........and that's the only thing it plays to.
Click here
to view the entire update
07/07/07
Lone Tree Council / TRW Dioxin Update
Dow to begin cleanup work in
Tittabawassee River
MDEQ Press Release 07/06/07
Contact:
Robert McCann
(517) 241-7397
Agency:
Environmental Quality
The Dow Chemical Company will begin work next week to remove a historic deposit
of contaminated sediments in the Tittabawassee River, just upstream of the Dow
Dam in Midland. The sediments are contaminated with high levels of dioxins and
furans, chlorobenzenes, metals, and other materials.
A coffer dam will be constructed in the river to contain the materials and
facilitate its removal, and boaters and fishermen are advised to maintain a safe
distance from construction activities.
The Department of Environmental Quality and the U.S. Army Corps of Engineers
issued a revised permit for Dow to construct the steel dam structure as a
component of an Interi |
