According to a
News report, The U of M is about to release new statistical
manipulations of their data. Some consider this just another payment to
Dow for the 15 million they spent on their dioxin exposure study.
IF they follow past practices, statistics will be used to
diverted attention from the real fact that 50% (472) of the people tested had
levels higher than the studies median (which is 28% higher than those in the
rest of the nation). In preparation, review the
MDCH Pilot Exposure Investigation results and
consider the following:
The recent U/M Dioxin Exposure Study did not
fully explain the significance of elevated dioxin blood serum levels found in
Michigan residents. In addition, the U/M did not discuss many of the significant
findings presented in the supplied data tables.
When compared on a year 2005 to year 2005
basis, Michigan median serum levels are 70% higher than the national levels.
This elevation is much greater than the 10% increase reported by the U/M.
When compared on a mean, 95th percentile and maximum level basis, Michigan serum levels are from 52% to 125% higher than US levels.
Dioxin serum levels in the Midland Dow Plume
are lower than other Michigan areas. The U/M has kept the specific locations
that were sampled confidential. However, based on data from previous soil
sampling programs, more than 70% of the locations sampled in Midland by the
U/M may have been two miles or more from the Dow incineration complex. Only
2 out of a total of 31 samples may have been taken in heavily contaminated
neighborhoods. Although Midland serum levels are low compared to other
Michigan study zones, average serum levels in Midland are still nearly
150% higher than the corresponding 2005 US level.
The U/M found very high dioxin blood serum
levels even in background areas believed to be regions of low dioxin
contamination. Every Michigan area studied by the U/M was found to have
dioxin serum levels significantly higher than 2005 US national levels. The study confirmed that dioxin contamination in Michigan is more
wide-spread than previously believed and not just confined to the
A comprehensive analysis of the U/M study,
including information not discussed in the U/M report, can be found on at
website will only carry information related to the U/M dioxin blood
serum report and is
produced by David Linhardt, a Chemical Engineer formerly employed by
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.
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
Dioxin on the move, 2 floods so far
The flood stage of the Tittabawassee River is
approximately 24 feet. As the images below show,
flooding occurs on many properties at lower levels.
Hard to imagine anyone thinking
they can predict where all the dioxin
laden soil lands after the flood, especially that
100,000 ppt "hot spot"
located a few miles upstream of where these photos were taken.
here to watch a short video of the river in action
MDCH Warning:, people should take precautions when entering the flood
plain: "There are some common sense steps you can take to limit your exposure to
the dioxins found in the flood plain. If you have been playing or working in
soil that could be contaminated, wash your skin to remove any dirt. Thorough
hand washing is especially important before eating. Children playing outside
should be prevented from putting toys or other dirty objects in their mouths.
Clean fill dirt can be added over contaminated dirt in gardens, on lawns, and in
play areas if dioxin contamination is known or suspected. However, if the
area is flooded after clean fill is added, the surface soil could be
re-contaminated. Care should be taken not to disturb the layer of clean soil
covering the contaminated soil. Because they may be especially sensitive to
dioxins, children should not play in soil or sediment that is known to contain
elevated levels of dioxins. "
For more information concerning flooding in previous years,
The Daubert Effect
discussing methods used by corporations such as Dow to twist our Judicial
system. Below are a few excerpts:
"In the past the courts asked scientists to play
gatekeeper by deciding what was good science--permissible in the
courtroom--and what wasn't. But 1993 brought a dramatic shift. The Supreme
Court ruled in Daubert v. Merrell Dow Pharmaceuticals that scientists should
not be the ultimate arbiters of the quality of science. That power should be
reserved for judges.
The decision brought the two disciplines into ugly conflict. Since Daubert,
respected researchers have seen their legitimacy questioned, even rejected,
by judges who may never have taken a college biology course. Cutting-edge
science has been banished from courthouses. And juries, a fundamental
element of the justice system, have been stripped of much of their power. "Daubert
lets judges have much too much leeway to follow their personal
inclinations," says Stanley Feldman, retired chief justice of the Arizona
Supreme Court. "It's an interference in the jury process and wholly
unneeded." Feldman says the 1993 ruling was written to address legitimate
concerns about how science is used in courtrooms. But "the remedy," he says,
"is worse than the problem." ...
But now rigorous science also gets thrown out. "There have been numerous
examples where highly qualified scientists, sterling scientists, have been
Dauberted out," says David Ozonoff, chair emeritus of Boston University's
department of environmental health. That's because controversial lawsuits
often turn on groundbreaking science--the type that attracts the best
researchers and the type Daubert discourages.
In March 2006, for example, Dow Chemical persuaded a federal judge to
exclude the opinions of three scientists including renowned North Carolina
toxicologist Ken Rudo, who had concluded that groundwater contamination at a
Louisiana trailer park increased residents' risk of cancer. The case was
then dismissed. This wasn't unusual: The RAND Institute for Civil Justice,
in a 2002 analysis of 400 lawsuits, found a marked upswing in summary
judgments following Daubert. In 96 percent of those judgments, the defense
Until significant changes take place, say Daubert critics, the system will
continue to harm more than scientists' reputations--it will also harm ill
and injured Americans. "We do need tools to make sure that bad science
doesn't get to court," says David Michaels, a George Washington University
epidemiologist who served as an assistant energy secretary during the
Clinton Administration. "But Daubert is an imprecise tool, and its
application has resulted in miscarriages of justice." "
Daily News reports the Michigan Court of Appeals will hear oral
arguments for the Dow Class-Action certification on May 7, 2007.
I think the different branches of government in
Michigan have lost touch with what truth and justice is for "the people", from
past actions and decisions that have been made. Therefore, I have no
expectation one way or the other on what might happen. But it is good to know
that we finally do have an argument date that has been in the Court of appeals
for a year and a half, holding our case in limbo. No matter the outcome of
Dow's appeal for class certification, we look forward to moving on to the merits
of this case.
Kathy Henry, TRW
Click here for 4 years of details
concerning the case.
Washington State to dredge dioxin
"Olympia, WA. Marine sediments, low oxygen levels, over 100 years of industry
and other pollution, dioxins, and more - cleaning the southernmost tip of Puget
Sound, Washington will be quite a feat.
Dioxin levels in the lower Budd Inlet are too high to safely dredge excessive
sediment. Shellfish harvesting is off limits in the area due to safety concerns.
During the summer months oxygen sinks too low, dangerous to marine life. ...."
According to the articles author, Charlotte McNamara, "The dioxin contents
are high enough that soil to be dredged has to be properly disposed of (on land,
not deeper into the sound). The current study being done is to determine the
actual dioxin content, so sure facts are not yet available.
Sediment sampling in lower Budd Inlet last year revealed dioxin levels
ranging from 0.1 ppt to 52.7 ppt. The dioxin limit set by state and federal
agencies for disposing of marine sediments at a South Sound marine disposal site
near Ketron and Anderson islands is 3.8 ppt. In Washington, the state toxic
cleanup standard for dioxin found in residential soil is 6.67 ppt. "
The federal Clean Water Act requires states to clean up water bodies that
don't meet water quality standards.
In Michigan, the state toxic cleanup standard for dioxin in residential soil
(RDCC) is 90 ppt. The Tittabawassee River sediment has over 100,000 ppt
dioxin, flood plain soil sampling reveals
levels greater than 8,000 ppt in our parks and dioxin levels in
are elevated. State officials are still debating whether it is a problem.
What's wrong with this
It's Time to think ahead - A Planners
Developing a Regional Environmental
Enhancement Plan of Action
In view of the Dow Chemical Company’s
eventual decontamination of dioxin in Midland soils and in the Tittabawassee and
Saginaw rivers and Lake Huron’s Saginaw Bay, may I suggest that the Counties of
Midland, Saginaw and Bay and the State of Michigan collaborate in developing a
regional environmental enhancement plan of action for the Tittabawassee River
and Saginaw River corridors and the Saginaw Bay.
As for example, in the 1970s the Erie and Niagara Counties Regional Planning
Board in Western New York oversaw an international study of the environmental
enhancement of the Niagara River Corridor through Western New York and Ontario,
Canada, from Lake Erie to Lake Ontario. The international environmental study
examined the environmental status of the Niagara River Corridor in relation to
pollution sources, geophysical features, land use and population concentrations,
historic features, prominent buildings, highways and entranceways, and tourist
activities concentrations. Possible conceptual solutions to environmental
problems were considered through preparation of alternative design concepts for
geographic areas within the river corridor and preparation of alternative river
corridor “themes” for river system management. A preferred “design” concept was
selected for each geographical area. Based on the improvement actions implied in
the selected area design concepts, a series of environmental action programs,
both short-range and long-range, were prepared for the entire Niagara River
Corridor. These actions involved natural resources maintenance and enhancement,
land use and transportation, aesthetics and prominent buildings, recreation,
tourism and historic features. Among these, first priority for implementation
was assigned to pollution abatement programs, particularly the need for
upgrading municipal and industrial wastewater treatment plants. The coordinated
management program involved actions at the local, county, regional, state,
federal and international levels to implement recommended action programs.
Later would come open space acquisition, housing development, urban
redevelopment, storm water drainage and flood control management, trafficways
planning, water quality management, toxic waste management, Love Canal Superfund
site remediation, air quality improvement strategies, and coastal zone
management planning programs pursuant to the U.S. Department of Housing and
Urban Development, U.S. Department of Transportation, U.S. Environmental
Protection Agency, National Oceanic and Atmospheric Administration, U.S. Army
Corps of Engineers, New York State Department of Environmental Conservation, and
the New York State Department of Health. In 2004, New York State Governor George
E. Pataki and the New York State Department of Environmental Conservation
promoted the creation of the Niagara River Greenway which will aid in the
planning and development of a greenway of interconnected parks, river access
points and waterfront trails along the Niagara River from Lake Ontario to Lake
Perhaps an environmental enhancement program such as the Niagara River Corridor
would be applicable to the Tittabawassee River and Saginaw River corridors here
in the Saginaw Valley. It’s time to plan ahead! x
Richard A. Maltby, AICP
TRW Note: Mr. Maltby is a retired professional urban and environmental resource
planner and is a member of the American Institute of Certified Planers (AICP)
and the American Planning Association. He has 38 years of experience in
Michigan, Illinois, and New York; the most recent as the Midland county planning
director from 1983-1998. He currently resides in the Midland area and was
a Freeland resident form 1942-1957.
03/08/07 Lone Tree
Council / TRW Dioxin Update
Saginaw News Editorial gets it wrong!
Editorial comments are opinion and everyone has
one and is entitled to one but they are not
entitled to their own facts. Editorial boards
must deliver accurate information when sounding
off atop their daily soapbox. Accuracy being a
core editorial value…so one would think.
Last week’s editorial by the Saginaw
News could not be more wrong in their opening
editorial statement: ...
Judge says Saginaw County
attorney's not allowed to keep secrets
Saginaw County attempted to keep confidential
the depositions of Saginaw County’s Jim Koski
and Jim Sygo of the Michigan Department of
Environmental Quality. Not sure what Saginaw
County’s attorneys were trying to hide and
nobody asked or if they did it was not reported
in the stories. ...
During the Feb 8th 2007
DEQ/Dow meeting at Horizons, DEQ stated there
were still a number of issues with Dow’s human
health risk assessment one year later. Dow sat
silent and said nothing. After three years it
is inconceivable that Dow cannot submit a plan
that adheres to EPA guidelines and policy. Delay
game by design? Probably. No less than 20 Dow
scientists or hired contractors are present for
the DEQ/Dow town hall meetings………..yet
collectively they cannot, in three years, come
up with a risk assessment that follows EPA
guidelines. Yeh, right!
...I grew up in Midland, Michigan with three parents...My father was and still is a
chemical engineer in the plant... my third parent's name was on
everything: There was the
Grace A. Dow Memorial Library and the
Dow Gardens...Even if the buildings didn't have
the Dow name on the sign out front, such as the
arts center and several prominent citizens' homes, they
had a suspicious look, since they were designed by
Alden B. Dow...Dow
not only dominates the cultural landscape of my hometown,
but the physical one...Through these
tubes flows the substances that make Midland bigger and more
important than the other dying auto towns in the area....Without these chemicals,
there would be no Midland...The benefits appeared to
outweigh this damage. How many kids had gone to college on
Dow money?...Besides, Dow had been pretty good about
cleaning up its mess. Or so I thought, before I heard about
the deer...As is inevitable in a company town, there are people who
are mad because Dow is being attacked....One valley resident calls the
environmentalists “terrorists” on her website...She notes that Dow has put in a nice park on the
river for area residents to enjoy, and that the
company brings good cookies to public meetings. How could
we, the ungrateful children concerned about a little mess in
a little floodplain, be so angry?...Everyone wants to defend
her family when it is attacked. ... No one wants to believe that
the provider that put food on their family’s table for the
last century might have done something wrong. If Dow is
responsible for the dioxin contamination, that means that
the environutz are right. It means that their neighbor’s
little boy’s birth defects might not be the act of God that
they had blamed it on all those years. It means that their
own risk of cancer is higher, and that they might have
unwittingly poisoned their children. ...My brother was diagnosed with a
rare form of
non-Hodgkins Lymphoma at 21 years old; we had blamed it
on genetics and bad luck. But his form of cancer is one of
those that has a
high correlation with dioxin exposure, ... I find myself hearing the voices of those
extremist environmentalists, and I start to think they might
be right: Dow might not be such a good parent after all.
Even worse, all those times that I supported my third
parent, I was wrong, too. Eating crow is hard, but it’s
something that we have to do. Midland residents just need to
make sure that they don’t get that crow downriver from the
TRW Note: The author did a excellent job with her review of the
situation; however a few points require corrections or
Their is no paradox, the
U of M Exposure
Study found increased dioxin levels in people as
PEI study, the U of M chose to present it's
findings based on statistical tools that down played
The Dow supporter blog site
mentioned represents the view of a few Tittabawassee
02/23/07 Lone Tree
Council / TRW Dioxin Update
PIT FIGHT CONTINUES IN LANSING COURT
Federation/Lone Tree Council Asks Ingham County Court to Review DEQ
Environmental groups continue to challenge the Corps of Engineers’ plan
to dump toxic pollutants into the Saginaw River.
real issue is the rush by which
the facility was sited,” said Lone Tree Council’s chairman, Terry
Miller. “It should never have been placed near residences, in a
floodplain, next to a State Game Area, in a wildfowl flyway, with no
public construction plans, operation and management plan or water
treatment. Now the State is closing ranks to defend its faulty
process, and we are hopeful the courts will intervene on the
02/14/07 Dow fined for bribing Indian
Dow Chemical Co. will pay a $325,000 civil penalty to settle charges that a
subsidiary made improper payments to Indian government officials who held sway
over regulatory approvals for the company's pesticides, the Securities and
Exchange Commission said.
Click here for the details
02/13/07 Lone Tree
Council / TRW Dioxin Update
Dow Community Meeting
One young mother from Midland stood up and
talked about her son’s cancer, Ewings Sarcoma.
Dow employees had higher
incidents of prostate and stomach cancer
DEQ responded ... residents living along
the floodplain did have higher levels of dioxin.
The Dow contractors gave a very detailed
analytical presentation of their GeoMorph sampling along the upper
T-river and floodplain.
02/11/07 City of Midland dioxin
results to be released next month
reported in the
Midland Daily News, results of
400+ samples in the plume of the Dow plant revel levels as high as 1,000 ppt TEQ
in the soil of residential neighborhoods. Michigan's background level is 6
ppt, the States cleanup standard Residential Direct Contact Criteria is a
maximum of 90 ppt TEQ.
DEQ officials say the Midland soil sample results will be posted on the DEQ
website around the beginning of March.
02/11/07 Final GeoMorph Upper
Tittabawassee River dioxin testing report available
2/1/07, Dow and Ann Arbor Technical Services submitted their GeoMorph Pilot Site
Characterization Report for the Upper Tittabawassee River (UTR) to
Michigan's Waste and Hazardous Materials Division. The report is composed
of many documents, each containing maps of the testing area and the results
obtained. Note that many of these files are very large pdf's and will
require a high speed internet connection to download.
02/08/07 Tri-Cities Dioxin Community
The next quarterly Midland/Saginaw/Bay City (Tri-Cities) Dioxin
Community Meeting at 6:30 p.m. on Thursday, February 8, 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
02/06/07 New sampling data:
100,000 ppt TEQ dioxin found in T.River
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.
The report contains the results of what looks to be over 3,000 samples collected
from various depths and sites including wetlands, in channel, floodplain,
levees, and river bank terraces. Sample results seem to vary all over the place,
ranging from <10 to 100,000 ppt TEQ. Note numerous samples collected at
the surface contain levels ranging up to 30,000 ppt TEQ on the river banks (page
125) which is over 300 times the States
(Residential Direct Contact Criteria) of 90 ppt.
Furthermore, I would say any citizen confronted
with the history of Dow's pollution of the Saginaw Valley ought to feel
outraged, as I have expressed in many letters and in my book "The Pollution
Signature" and the four episodes of "The Dioxin Story." Copies of my books
have been given to the Dow Chemical Company, DEQ, EPA, and area libraries,
newspapers and nature centers.
I will continue to monitor Dow's involvement in
the cleanup of the community, the Tittabawassee and Saginaw rivers, and the
Saginaw Bay. And I will continue to register my criticism of the Dow
Chemical Company when I know it is justified. After all, that is my duty as
a professional environmental planner certified by the American Institute of
Also I am obligated to uphold the AICP Code of
Professional Conduct. Until the dioxin-contaminated areas in the Saginaw
Valley are restored to a clean and healthy environment, I must strive to
continue to protect the integrity of the natural environment and must follow
several other professional obligations to serve the public interest.
In view of my environmental management planning
work experience in Western New York, I would not want to see the Niagara
Falls Love Canal tregedy repeated here in the Saginaw Valley.
Richard A. Maltby
01/23/07 Dioxin's harm already done
Below is the Saginaw News editorial admonishing Dow and DEQ to move
cautiously with the cleanup of the Tittabawassee River. (After 30 years I didn't
think it could move any slower). DEQ and Dow have said they will address the
recently found hot spots in excess of 83,000ppt in sediments and 87,000ppt on
the banks. The SN suggests removing would only cause sediments to migrate
further down river.........this after 30 years of the Tittabawassee and Saginaw
Rivers depositing dioxin laden sediments to Lake Huron.
Below the editorial link is Dave Dempsey's commentary and link in response to
the Saginaw News.
the Saginaw County BOC essentially committed the taxpayers of Saginaw
County to liability for a project we have no control over? Did
Jim Koski tell the board they had no control over who could use the
Request for Operational Management Plan Denied
All of a sudden DEQ doesn't want to share the OMP. In a letter of denial
DEQ cited the following for their denial" a deliberative
process concerning enforcement action(s) related to the Saginaw River
Dredge Disposal Materials Facility". Won't speculate at
this point what that means but it can't be good. Would also think that
the county might want to ask what that enforcement action is since they
have committed the taxpayers.
Freedom of Information Act Document on the October 2006 Operational
As a result of a FOIA request by Bay City resident
John Witucki we do have a one page document of comments submitted by one
DEQ staff with regard to the October 2006 OMP. The one the DEQ will not
share. The one page document of comments are concerning. Dated November
3, 2006 one DEQ official comments:
In addition to the attached
comments in the attachment a number of other issues have arisen due to the
recent construction activities at the DMDF which include:
The text mentions
contamination with dioxins and furans (top of page 2). It should
also more accurately reflect the wide range of contamination of organics,
BCCs, heavy metals, and nutrients, as known to date, and put into context
that the highly contaminated sediments ought to be limited from
ecological exposures and cause chemical releases to the watershed by a
contained upland disposal facility.
There are no plans for
the design included in the submital.
should have at least 2 feet of freeboard above the current 100 yr flood
elevation, or they will be submerged by larger sized rain storms and
snowmelt events that also generate greater flows due to greater runoff rates
from the developing Saginaw River watershed. The predicted 100-yr
flood elevation has risen on tributaries and the S.R. over the past 30 yrs
and will continue to rise in the future."
Unbelievable that one year later some of the key issues not addressed
include : ANNUAL REPORTING, PERIODI INSPECTIONS, DISPOSAL OF PRIVATE
DREDGING , PERPETUAL CARE AND INITIAL SITE DESIGN
01/17/07 Former Saginaw Resident publishes song about Tittabawassee Dioxin
Tag Team Productions releases Johnny
Coldheart's "Requiem For A River" as free internet download.
"Although I no longer live in Saginaw, I have been closely following the
developments in the situation regarding Dow Chemical's pollution of the
Tittabawassee River with Dioxin.
Today I am releasing a new CD single entitled "Requiem For A River". It is a
tribute to those who have been affected and/or exposed to one of the most toxic
substances ever devised. The poisoning of this beautiful river and it's
inhabitants (human and animals) saddens and sickens me to such a degree that I
can no longer stand by idly and watch - It's time for action." Jonny
TRW Note: The
artists web site contains obscenity and foul language and the song itself
contains strong lyrics, viewer/listener discretion advised. The
artists web site content and the songs lyrics represents his personal interpretation of the issue,
TRW and The Lone Tree Council did not contribute to either.
01/11/07 Horrifying levels of dioxin found in and around the Tittabawassee River
ppt State Cleanup Level
is 90 ppt
MDEQ mandated sampling of the Tittabawassee River and it's banks have
discovered the highest levels of dioxin soil contamination ever found in a
region surrounding a Michigan chemical plant.
"I think the numbers are horrifying," said Terry Miller of the
Bay City-based Lone Tree Council, which has been pushing Dow and the
state to clean up previously known hotspots, at least.
"It confirms the need to address these things and address them
upstream before they get downstream," he said. "The DEQ has got to
stiffen its spine, and Dow's got to do the right thing."
DEQ Press Release
FOR IMMEDIATE RELEASE
January 11, 2007
DEQ Contact: Robert McCann
Dow Contact: John Musser
Tittabawassee River Sampling Identifies Areas for Interim Clean-up Action
Recently available results from sampling along and in the upper Tittabawassee
River have identified several areas with elevated levels of dioxin and furan
that require short term response activities. The sampling results identified
certain eroding river banks with concentrations up to 84,000 parts per trillion
(ppt) TEQ, the combined toxicity of dioxins and furans, and certain in-channel
deposits with concentrations up to 87,000 ppt TEQ. The elevated sampling
results are located within areas along and in the first six and one-half miles
of the Tittabawassee River.
The sampling was taken as part of the ongoing study and investigation being
conducted by the Department of Environmental Quality and The Dow Chemical
Company. In general, the chemical profile of the in-channel and eroded bank
samples are largely consistent with earlier sampling results from the same
general area showing a mixture consisting mainly of furans with a small
percentage of dioxins.
Dow has proposed a conceptual approach and schedule for a focused pilot
corrective action plan (PCAP) to address these areas. The details of the PCAP
will be developed jointly by DEQ and Dow with measures that will ensure a timely
approach that will achieve the greatest protections for human health and
minimizes harm to the environment and natural resources. These initial
corrective action activities are scheduled to begin this month and be completed
as early as August 2007.
Preparation for implementing the interim actions is underway with Dow developing
the final plan and initiating the permit application processes with state and
federal agencies for the work to be done in and along the Tittabawassee River.
Dow has committed to working collaboratively and cooperatively with DEQ to
further refine, design and implement the plan for addressing these areas as
quickly and as safely as possible.
These findings were generated during the implementation of the DEQ-approved
sampling plan that was developed and is being implemented by Dow and its
contractor, Ann Arbor Technical Services, as part of the remedial investigation
of the Tittabawassee River required by DEQ’s hazardous waste management facility
operating license, issued to Dow on June 12, 2003.
The public will have an opportunity to ask questions about short and long-term
actions that will be developed during the February 8, 2007 Tri-Cities Community
Meeting at The Horizons Center in Saginaw Township from 7-9pm.
In today's DEQ Press Release it would appear Dow Chemical and DEQ
have agreed that 83,000 ppt is just too high a sediment
concentration for dioxin in the Tittabawassee River and therefore
Dow will remove it by sometime in August at the latest.
For the first time in the history of this contamination DEQ
is going to require removal of contaminated sediments
but it took an alarming number of 83,000 ppt to get any
action. Not acceptable!
These latest numbers are astounding and far exceed anything to date
found in the Tittabawassee River or floodplain. We have repeatedly
asked DEQ what's the threshold for dioxin cleanup? What number ( ppt)
would require sediment removal from the river? We have yet to get an
answer. Surely it isn't as high as 83,000 ppt! Last we were told,
Dow Chemical and DEQ could not agree upon a number. Interesting that
the regulator needs the agreement of the polluter in order to settle
on a number protective of public health and natural resources. Just
last year in Jeb Bush's Florida a community cleaned up dioxin to a
state standard of 30 ppt. In Michigan, however, everything is
negotiable with Dow Chemical.........
In the past few years DEQ commissioned a number of studies by
Galbraith Environmental Services to ascertain the ecological
thresholds. Dr. Galbraith's findings for impairment? 50 ppt (
dioixin/furan) for mammalian populations and 10 ppt to 200ppt for
avian species. State residential contract criteria is 90 ppt............Arriving
at cleanup number may not be politically comfortable but it is
certainly scientifically defensible.
Today's press release states future activities with regard to these
high dioxin numbers will include:
"...................measures that will ensure a timely
approach that will achieve the greatest protections for human health
and minimizes harm to the environment and natural resources".
Would have to assume that in an effort to achieve the greatest
protections for the inhabitants, DEQ would need an identifiable
number to clean up to that they consider
protective. What is that number?
Dow stated that the 83,000ppt is not a public health threat. Surely
DEQ will not hold their breath waiting for Dow to acquiesce
to defining a cleanup level.
As DEQ oversees Dow's next phase of mapping and sampling it is
imperative that DEQ establish the number for cleanup/removal/
interim response along the Tittabawassee River.
01/02/07 ATSDR revises guidelines for dioxin in residential soil, deletes 1000
ATSDR is seeking public comment on the draft revision of its 1998 Policy
Guideline for Dioxins and Dioxin-Like Compounds in Residential Soil.
The 1998 policy established a screening level of 0.05 ppb TEQ (50 ppt), an
evaluation level (>0.05 ppb TEQ, <1 ppb), and an action level of 1 ppb TEQ
(1,000 ppt) for dioxins in residential soil.
ATSDR revised the 1998 policy because
it has been used inconsistently over the past eight years.
The ATSDR "action'' level has been misinterpreted by health assessors
and others as ...
(1) a soil concentration that defines a public health hazard
(2) an ATSDR clean-up level which implies the need for site
(3) an initial screening level that defines a safe level of
exposure, below which there is no public health concern.
However, ATSDR believes that these actions could be considered in some
circumstances when the 1 ppb level in soil is not exceeded. In response to
these concerns ATSDR has updated its Policy Guideline for Dioxins and
Dioxin-Like Compounds in Residential Soil.
Deletion of the 1 ppb action level as the criteria for taking
specific public health actions.
The 1-ppb dioxin soil concentration should not be used as a
comparison value for defining public health hazards in public health
assessments and consultations.
The 1-ppb action level can be cited by health assessors as the
Superfund Dioxin Cleanup policy criteria (EPA 1989,1998).
Retention of the 0.05 ppb Screening Level The minimal risk level (MRL)-based
environmental media evaluation guide (EMEG) of 0.05 ppb for dioxin TEQ
in soil is retained as the basis for screening soil concentrations.
Levels exceeding this screening level should be evaluated as
described in the ATSDR Public Health Assessment Guidance Manual (PHAGM)
DATES: Comments concerning this document must be received by February
ADDRESSES: Public comments should be forwarded to Ms. Athena Gemella,
ATSDR, Office of Science, 1600 Clifton Road, N.E., Mail stop E-28.
Atlanta, GA. 30333, or
FOR FURTHER INFORMATION CONTACT: Ms. Athena Gemella, Office of Science,
telephone (404) 498-0621.
Dated: December 22, 2006.
Kenneth Rose, Acting Director, Office of Policy, Planning and
Evaluation, National Center for Environmental Health/Agency for Toxic
Substances and Disease