What's being done about the dioxin contamination?
Tittabawassee River Cleanup Activity
 |
2/9/08 State investigating dioxin cleanup options At Thursday nights
(2/7/08) MDEQ Community Dioxin Meeting, Art Ostaszewski of the MDEQ
gave a presentation on Dioxin Treatment Technologies currently under review by
the state.
 | Source of contamination to be cleaned is basically divided into 3
categories:
 | River Sediments such as sands, silts, bed load, buried, exposed, and
re-suspended |
| Eroding River Banks |
| Soils: those that are repeatedly flooded on agricultural,
recreational, and residential properties |
|
| MDEQ treatment approaches used to date
| Natural Attenuation: basically do nothing and monitor
|
| Excavation and hauling to Chemical Disposal Facility Landfill
|
| Interim Response Activities: see Biotech and Phase Separation
solutions below
| Less intrusive than Excavation/Hauling |
| Possibly less costly |
| New science at work, 2 new methods used in pilot study last year
with exciting results. |
|
|
| MDEQ requirements for testing new technology
| The technology must involve the destruction and extraction of the
contaminants |
| The technology must have been used previously in other full-scale
cleanups |
| The technology company must conduct a "Bench Scale" (i.e. trial) on
the Tittabawassee contamination at no cost to the state |
|
| Two companies participated in the trial (note the MDEQ does not endorse
either at this time)
| Biotech Restorations
www.geosolve-inc.com/biotech.html
| Trial on Tittabawassee removed 45% of dioxin and furans in 4
months
|
|
 Process
using existing bacteria in soil to breakdown the contaminants into
inert substances. |
| Process treats the soil in place, however it needs to be plowed
and watered |
| 39 other projects around the world |
|
| Phase Separation Solutions
www.phaseparation.com/soil/index.html
| Trial on Tittabawassee removed 99.8% of dioxins and furans |
|
 Process
uses a low temperature thermal desorption process where soils are
removed and fed into a portable "extraction chamber" located on or
near the treatment area. |
| Process requires soils to be temporarily removed and fed into
chamber. After treatment they can be returned to original
location. |
| 8+ projects worldwide including
potential residential areas near the Sydney Australia 2000
Olympics site |
|
|
| 4 steps will be used to assess treatment technologies
| Step 1: Bench Scale
| Michigan's cost: none |
| Initial review of technology |
| Conduct Bench-Scale test with Tittabawassee sedement and soil
| As of February 2007, both BioTech and Phase Separation have
completed this step. |
|
| Review results with MDEQ, Dow, EPA, and public |
|
| Step 2: Field Demonstration I
| Michigan's Cost: up to $200,000 |
| Conduct field demonstration on 1-5 acres |
| Review results with MDEQ, Dow, EPA, and public |
|
| Step 3: Process optimization - Feasibility studies |
| Step 4: Field Demonstration II
| Michigan's Cost: up to $500,000 |
| Conduct larger/better field demonstration |
| Review results with MDEQ, Dow, EPA, and public |
|
|
| Next Steps
| Final reports from Biotech and Phase Separation released to public
in May 2008 |
| Vendor presentation at MDEQ Community Dioxin meeting in May 2008 |
| Finding avenues to move to Field demonstration 1 |
| Identify additional mature technologies to provide bench-scale
trials |
| Establish whether there is public support for treatment technologies
such as these.
|
|
|
| 05/03/07 MDEQ announces spot cleanup of Tittabawassee River
| The MDEQ announced
at it's quarterly
Midland/Saginaw/Bay City (Tri-Cities) Dioxin Community Meeting that
two "hot spots" will be cleaned up this summer. Both areas are
located just downstream of the Dow Midland Headquarters with reported
levels ranging from 30,000 to 60,000 ppt TEQ dioxin. |
| A third spot with levels
as high as 87,000 was mentioned, however
cleanup may not begin until 2008. |
| Interesting, a 4th spot with a 100,000 ppt was not mentioned.
| Levels as high as
100,000 TEQ of dioxin (page 303)
are noted in a recent
Geomorph study document which summarizes dioxin levels in
samples collected in and around the first 6 miles of the river down
stream of Dow's Midland plant. |
|
| Hydraulic Dredging was specified as the
clean up method.
|
 Environmental
dredging is used to remove contamination from targeted areas. This
technology is very precise and is designed to minimize re-suspension
of small sediment particles that may be contaminated with PCBs,
heavy metals, or other toxic materials. This process is much more
controlled than navigational dredging, using technologies like the
hydraulic dredge, which functions like a large vacuum cleaner to
remove contaminated sediments with strong suction pumps.
Click here for additional details |
|
| The two sites account for 3,600 feet of the river sediment which is
3% of the 22 miles (116,00 feet) of
contamination. |
| While cleanup goes after a small portion of the dioxin source, it
does not directly address the estimated 16,000 acres of
contaminated properties in the rivers flood
plain.
| Flood events are constantly
re-distributing the contamination, cleaning up a few hot spots is a
start. However, until all the "hot spots" are identified and
cleaned, the river will never be "clean". Once the sediment is
removed, the contaminated floodplain soils will continue to move
around and redistribute it's poison. As part of the final
solution, flood plain soils must be remediated as well.. |
| The
current sampling and analysis is limited to the first 6 miles of
river downstream of Dow. Only 16 miles to go! |
|
| The most interesting development was the
announcement by the MDEQ
Deputy Director that Michigan's economic problems could slow down
efforts to clean up the three hot spots along the Tittabawassee River
due to cuts in his staff if the State reduces or eliminates his budget.
| Coincidence? We think not when you consider the ties that
some of our legislative puppets have to
Dow Chemical. |
| Dow has had every opportunity to resolve this issue on it's own.
Unfortunately, they have no intention of doing so unless forced to
by the State or EPA. |
| Our only hope is to let your legislators know you want a cleanup
to be a high priority; Call or email them today.
| Kenneth Horn (R), House district 94, 517-373-0834,
kennethhorn@house.mi.gov |
| Andy Coulouris (D), House district 95, 517-373-0152,
andycoulouris@house.mi.gov |
| John Moolenaar (R), House district 98, 517-373-1791,
johnmoolenaar@house.mi.gov |
| Roger Kahn (R), Senate district 32, 517-373-1760, fax
517-373-3487,
senrkahn@senate.michigan.gov |
|
|
|
| 6/27/07 EPA mandated spot cleanup on 3 Dow properties
| 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.
| Reach D
|
 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
|
 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
|
 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
progress reports,
click here |
|
Highlights of Dow/MDEQ/EPA Activity
Below are a few media articles on the various activities undertaken by Dow ,
EPA, &
the State to address the contamination. See our
Newspaper/Media page for much more. For a comprehensive list of
meetings related to the issues, see our Meetings
page.
| No deal yet on dioxin
cleanup 1/13/05 |
| Dow releases plan to clean up
dioxin 1/20/05 |
| Dioxin deal done: Dow, DEQ
agree 1/20/05 |
| Good news? Too soon to
tell 1/20/05 |
| Dioxin plan details given
1/21/05 |
| Environmentalists skeptical,
public officials encouraged 1/21/05 |
| Environmentalists upset with
DEQ-Dow pact 1/25/05 |
| Dow to argue for reduced
cleanup 1/27/05 |
| Dioxin Cleanup 1/29/05 |
| Residents will have options
to limit dioxin exposure 1/30/05 |
| Dioxin deal still needs some
meat on its bones 2/8/05 |
| Dow to notify property
owners of cleanup plans, meetings 2/24/05 |
| Dow talks to residents at
properties with high dioxin levels 2/25/05 |
| Cleanup called 'Band-Aid'
3/3/05 |
| Dow meetings offer answers
3/3/5 |
| Dow, DEQ goal: Communicate
openly 4/7/05 |
| Dow meeting features
incident with TV-5 reporter 4/7/05 |
| Dow pays for Freeland park
upgrades 4/13/05 |
| Interim dioxin cleanup under
way 5/8/05 |
| Hydraulic dredge is doubtful
here 6/23/05 |
| EPA talks about Fox River
dredging project 6/23/05 |
| Many refusing dioxin cleanup
7/3/05 |
| Residents' dioxin levels
higher near Dow, study shows 7/14/05 |
| DEQ tries to clarify polluted
property criteria 7/20/05 |
| Researcher: Dioxin risk
exists 8/4/05 |
| Pollution cleanup bill
getting messy 8/9/05 |
| Pollutants leave scared
landscape 8/14/05 |
| Dow to post fish and soil
advisories along Saginaw and Tittabawassee rivers 8/20/05 |
| Communication plan might
change 8/26/05 |
| Park design goes deep 9/6/05 |
| State warns of high dioxin
levels in some Tittabawassee River Fish 9/8/05 |
| New warning signs at local
launch 11/10/05
    
October 2005 New warning signs posted
in West Michigan and Imerman Parks
|
|
Little new information at session 11/11/05 |
| Dow
fined for conducting unreported dioxin tests 01/06/06 |
|
DEQ: More
dioxins moving towards Bay City 02/10/06 |
|
Dow
still collecting information on dioxin 02/10/06 |
|
DEQ
Goal: Protect public and environment 02/19/06 |
|
Dow
expected to enter round 2 of cleanup 02/19/06 |
|
EPA raps
dioxin plan 02/22/06 |
| DEQ agrees with EPA dioxin plan
concerns 02/24/06 |
|
MDEQ: Dow
has 2 months to resubmit dioxin plans 03/03/06 |
|
Eating
fish from river not healthy , DEQ says 03/10/06 |
|
State
announces 2004 emissions report, data includes increase for Dow 05/01/06 |
|
Paralysis by Analysis: Dow wants to delay cleanup until the year 2017 |
| Community Meeting June 2006 |
|
Michigan Department of Community Health
will be hosting activities for the public to answer questions about safe
fishing, fish consumption and the fish advisories on our local rivers
and Bay. July 2006 |
|
DEQ: Tittabawassee River Sampling
Identifies Areas for Interim Clean-up Action 1/11/2007 |
|
Final GeoMorph Upper
Tittabawassee River dioxin tearc2007_1sting report available
2/11/07 |
|
DEQ announces spot cleanup of
Tittabawassee River 5/6/07 |
| DEQ
announces
Dow to begin cleanup work in
Tittabawassee River 7/7/07 |
| EPA
memo says river highly contaminated with chemicals other than dioxin
7/11/07 |
|
DEQ responds to EPA criticism of Dow's
RIWP 7/12/07 |
| MDCH
releases "Fish Consumption Survey of People Fishing and Harvesting
Fish from the Saginaw Bay Watershed' Report |
| EPA
demands Midland dioxin sampling data 8/31/07 |
| First
dioxin-contaminated soil removed from the Tittabawassee 9/9/07 |
| EPA pulls
out of Dow/MDEQ mediation process 9/12/07 |
| EPA gives Dow
60 days to negotiate cleanup settlement of Rivers an Bay 10/10/07 |
| MDCH releases
final Pilot Exposure report 11/5/07 |
| EPA notifies
Dow of Clean Air and Hazardous Waste violations 11/9/07 |
| EPA orders
emergency cleanup of 1,600,000 ppt hotspot found in Saginaw River
11/13/07 |
| EPA responds
to Dow spokesman down playing of dioxin dangers 11/14/07 |
| MDCH issues fish
consumption advisory for Saginaw River 11/15/07 |
| EPA and Dow sign
consent order to begin emergency cleanup of dioxin hotspot 11/16/07 |
Dow "Legislators" repeatedly attempt to hijack
states regulatory system.
A group of Michigan Republican Lawmakers from Midland & Saginaw (Stamas , Moolenaar,
Goschka) have repeatedly filed bills in the Michigan Legislature to raise the States dioxin
Residential Direct Contact Criteria (RDCC) to over 11 times the
current standard, from 90 ppt to 1000 ppt. In our opinion, this is a attempt to
relieve Dow Chemical of it's clean up responsibilities under it's current operating
license. These individuals have shown their true colors: their allegiance to
Dow Chemical company overrides their concern for public safety in City of Midland,
Tittabawassee River flood plain, the State of Michigan, and the United States of
America. A poll found 90% of
Michigan voters support a comprehensive policy to phase out persistent toxic chemicals
(like dioxin). Yet these "representatives" advance the cause of Dow over
their citizens. If passed, these bills may set a precedent that could affect dioxin
standards across the entire United States. Now is the time for concerned citizens
from around the country to get involved in this debacle unless you want Dow Chemical
interfering in your backyard.
|
Attempts
to highjack State Regulatory System
| 2006: Dow hacks try again with three new bills |
| 2005: Dow hacks introduce bills HB4617 and SB390, Governor vetoes |
| 2004:
House Appropriations
Sub-Committee – Votes to Slash DEQ Budget & Eliminate Entire Programs |
| 2002: MDEQ attempts change
states dioxin RDCC |
| Click here for all the details |
|
Currently, two paths to resolution of the contamination are being
followed:
| Regulatory System as of 1/1/03 (for what happened before this date, click here)
| MDEQ / EPA regulatory
approach:
| Create and implement
Dow Corrective Action as required by their Hazardous Waste Facility
Operating License. issued June 2003 |
| Dow to create a Scope of Work (SOW) to define work plan on how they
will address issues mandated in Operating License. |
| MDEQ and area stake
holders (Tri County Project Coordination Plan) attempt to work with Dow to create a
credible SOW which includes remediation plans. See Community
Advisory Panel (CAP) page for details |
| So far, Dow is attempting to do as little as possible with the SOW. Other than for
putting a few hand washing stations in parks, remediation is not being addressed.
They are not responding to the immediate needs of those with known contamination nor are
they implementing a method to break exposure pathways. Dow's' plan of attack seems
to be delay, delay, delay with more testing, testing, testing. Citizens at CAP are
saying CLEAN IT UP NOW! and take immediate steps to reduce/eliminate exposure pathways in
known contaminated areas until a final solution is implemented. Health Studies
are NOT required before cleanup begins! |
| The MDEQ , EPA
(Page 1 2
3 4),
and CAP
are finding many issues with the initial Dow SOW. Dow understands what was required
of them for this SOW, they choose to water it down and avoid any of the real issues.
|
|
| Unless regulatory agencies take a strong position, we will still be talking &
testing years from now. |
|
| Legal System:
| The discovery of dioxin contamination was not made know to the public
until January 2002 when the Lone Tree Council filed a Freedom of Information Act as the
result of whistle blowers in the States Government. |
| For the next 12
months, victims of the contamination where caught up in a corrupt & illegal
political process where Dow and the Engler administration tried to work behind
closed doors to create and ram through regulations that would relieve Dow of any
responsibility and raise Residential Human Contact Criteria levels from 90 ppt to 851
ppt. |
| December 27, 2002. illegal activities stopped in the 11th hour of the
Engler administration by concerned citizens. |
| January 1/1/03,
Governor Engler and his administration where shown the door when Michigan voters elected
Jennifer Granholm as Governor. |
| The Dow
"administration" did not change, residents expect more of the same from Dow.
|
| Based on the prior
years illegal activities & cover-up's, Dow's worldwide history
of avoiding responsibility, and lack of visible action from the new
administration, contaminated residents hire lawyers and sue the Dow Chemical Company.
| Suit filed March of
2003 seeking damages for loss property values and future health monitoring, both issues
that seemed to ignored by the regulatory approach. |
| The Health Monitoring
aspect of the suit is basically a "Health Study" that is not under the control
or influence of Dow Chemical. |
| As of February 2003,
over 300 residents have signed on prior to being certified as a Class Action
(certification expected in February 2004).
| Once certified,
potential plaintiff's will expand to over 2000. |
|
| If not certified as a
class action, our lawyers will sue all 300 as individual cases. |
| For details of the Law
Suit and all the latest activities, click here |
|
|
Past, current, and possible future cleanup methods
| Can all the dioxin be cleaned up?
Many have asked this question and not one official at
any of the public meetings (Dow, MDEQ, ATSDR, or EPA) could provide an concrete answer.
Current cleanup activity is limited to a few "hot spots", no one
has yet to propose clean up methods for the rest of the 44 miles of
Tittabawassee river banks, 16,000 acres Tittabawassee floodplain
soil, Saginaw River, and the Saginaw Bay.
Cleanup methods mentioned by public officials (in no
particular order):
| Burial with clean soil - silly
idea, might work until next flooding when
contaminated river sediment is spread over the formerly clean topsoil.
How many dump trucks would it take to cover 16,000 acres? What about
all the trees, how do you cover the dirt they grow in without killing them. |
| Dredging - dredge the entire river of
sediment to prevent it from be
re-deposited on land during flooding.
 Use some sort of mesh/filter to
prevent disrupted contaminated sediment
from flushing out to sea. Where
has this been done and did it work?
Can we ship all of the spoils to Midland
where they think this stuff is safe? |
As of May 3, 2007, Hydraulic
dredging is being proposed for a spot clean up of the Tittabawassee
just south of the Dow Plant.
Click here for an overview of the process as it was
performed on the Hudson River, NY. |
As of July 2007,
Hydraulic dredging is being used to clean up 3 sediment hotspots in
the Tittabawassee River and flood plain soils are being excavated and
trucked to Midland Dow's Salzburg dump.
| Biological
| In February 2008, the MDEQ
announced it conducted a biological trial in 2007 |
| Biotech Restorations
www.geosolve-inc.com/biotech.html
| Trial on Tittabawassee removed 45% of dioxin and furans in 4
months
|
|
Process
using existing bacteria in soil to breakdown the contaminants into
inert substances. |
| Process treats the soil in place, however it needs to be plowed
and watered |
| 39 other projects around the world |
|
|
| Solidification - EPA has proposed solidification at some sites, a
process in which contaminated soil is mixed with cement-like material. The sludge
eventually hardens
and is left on-site. Everyone who wants a volcanic
moonscape for your back yard should vote for this one. |
| Incineration - The use of
incineration as a remedy is perpetuated by an industry and government bias against
innovative non-incineration technologies. This bias can be seen in engineering curricula,
regulatory training, and research which focus on building better burners and landfills.
Communities are often frustrated by the lack of alternatives to incineration. As it now
stands, companies have no incentive to develop non-incineration technologies and EPA has
no mandate to certify alternatives for use in the field. |
| Natural attenuation - Another disturbing trend is leaving the
contamination in place and relying on "natural attenuation" to take care of the
problem. Natural attenuation essentially means performing no further treatment and waiting
for dilution, dispersion, evaporation, and eventually degradation to deal with the
contamination. - Nothing is being "attenuated" in the Tittabawassee or
Saginaw River as indicated by the high levels being
found |
| Relocation & Fences - Sad, but this is probably the leading cleanup
"technology" for the
16,000 acre Tittabawassee flood plain dioxin contamination.
|
| Other disturbing trends
The Center For Health, Environment
and Justice article:
Back to Where We Started: Trends in
Cleaning up Contaminated Sites summarizes the following:
In summary, there is less on-site treatment of the source of the
contamination, more frequent use of on-site containment, primarily clay
caps, and more frequent selection of natural attenuation to address both on-site soil and
groundwater contamination happening at Superfund sites. These decisions result in less
cleanup at these sites and less protection of the environment and public health of
surrounding communities and those of neighboring areas where "naturally
attenuated" contamination could spread. By leaving more contamination in
communities for longer periods of time, EPA is letting industry off the hook for the true
costs of cleaning up these sites. And at the same time, the people living in the areas
impacted by these sites continue to face health risks that could be reduced, if not
eliminated, with proper cleanup.
These trends represent a failure of the Superfund program to fulfill its
mission of cleaning up contaminated sites. Instead of giving companies responsible for the
pollution a free hand to decide how to clean up a site, the people directly affected by
these sites need to be able to decide how much cleanup is needed. These companies should
be held accountable for what they did to the sites and to the people who live there. It
is clear, however, from this picture of trends in cleanup remedies that we cannot rely on
EPA to do this. We must do it ourselves with stronger local organizing and
coordinated national efforts. We must work together to force EPA to be the agency
we want it to be and to replace the agency that it has become, one that protects industry
instead of the public.
|
Note: on January 1, 2003, Jennifer Granholm replaced John Engler as governor
of Michigan.
Many of the political appointees that drove the campaign to cover-up the dioxin
contamination
left with Engler. It's to early to tell if the new administration will take the
citizens side in these
matters, however, recent news out of the MDEQ indicate a change may be coming.
We will wait and see...
The content of this site referring to all of the deceit and
collusion between Dow and the MDEQ will remain for a historical perspective.
Future developments will hopefully be in stark contrast to the past.
| MDEQ is pushing a Corrective Action Consent Order
considered by AG to be illegal
|
The contents of the CACO will raise
acceptable dioxin levels from 90 ppt TEQ to 831 ppt TEQ. 90 ppt TEQ is the current
MDEQ limit for residential contact in the rest of Michigan. Michigan's attorney
general office commented that draft versions of this document where illegal. Is the
proposed version any better? We better find out before 12/10/02 when the order could
be signed the the departing MDEQ officials of the Engler administration.
| Anything else?
|
Not much other than talk and illegal backroom
negotiations to relieve Dow of responsibility
Dow or MDEQ have no plans to start a cleanup,
they intend for the citizens of the Tittabawassee flood plain to stew in this toxic mess
until they can relieve Dow of responsibility for the cleanup. The only existing DEQ
Part 201 cleanup standard for dioxin in residential soils is 90 parts per trillion (ppt).
We have measured values of over 7000 ppt. Why are they ignoring this?
Because they need time to get the illegal version of the CACO approved before Engler
leaves office.
Dow and MDEQ are trying to raise cleanup standards from
90 parts per trillion TEQ to over 831parts per trillion TEQ. Why?
Because it gets Dow off the hook to clean it up. Many of the contaminated areas are
in the range of 100-830 ppt. Funny thing happened back in February 2002, the MDEQ
tried to raise the limit from 90 ppt to 150 ppt. Public outcry stopped them.
Once they completed the Phase 2 study, the new "scientific" cleanup level
promoted by Dow was 1000+ ppt. Now it's 831 ppt based on the most recent draft of
the CACO. There is no legal or scientific basis to do this and Michigan's Attorney
General has told them to STOP trying to get this CACO approved. However, they are
still trying to do so before Engler leaves office. Below is an internal email leaked
to the public. Outrageous
NOTE: The CACO was defeated in
December 2002 because of the actions of concerned citizens.
Michigan Attorney
General office email to Art Nash of MDEQ
Dow & MDEQ are trying to divert attention away from a
cleanup by proposing Health Study to be funded by Dow. A
Health Study is NOT required before a cleanup begins.
The next time you hear about a Health Study being proposed by ANYONE, read
this editorial and then read the proposal again. There are many design criteria which
can included that make the studies outcome inconclusive before it even starts.
Dow & MDEQ are trying to push through an illegal CACO
which will relieve Dow of any responsibility for the contamination. Michigan's
Attorney General office has reviewed the document and deemed it ILLEGAL
and to STOP trying to get it passed. NOTE: The CACO was defeated in December 2002 because of the
actions of concerned citizens.
Attorney General letter to
MDEQ telling them to STOP illegal activities
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Tittabawassee
River Watch www.trwnews.net
off contaminants. All 16,000 acres? Are you willing to watch all the plants
