Dioxin discharges data includes an increase for Dow – but really they're doing frightfully well

By Kathie Marchlewski
The Michigan Department of Environmental Quality has released its annual report on toxic chemicals released or managed by Michigan manufacturers, including The Dow Chemical Co. The 2004 data includes a statewide decline of discharges, though in Midland, Dow has reported slight increases, including in dioxin discharged into the Tittabawassee River.
Dow’s discharges — 564,000 pounds total, including trace amounts of dioxin measured in grams — account for only about half a percent of the 97 million pounds of chemicals disposed of or released in the state in 2004 — a seven percent decrease over 2003. Dow’s total was 537,000 pounds in 2003. The top producer is Wayne County-based U.S. Steel Corp.; Dow ranks No. 28 of 900 facilities reporting.
Dow is the only facility in Michigan which reported surface water discharges of dioxin and dioxin-like compounds, though it is not the only producer of the toxins — utilities and paper companies also typically produce the manufacturing byproduct.
“If you measure, you have to report,” said Paul Dean, of Dow Environmental Health and Safety. Reporting dioxin surface water discharge is a requirement of Dow’s operating license.
The state has required facilities to report dioxin releases since 2000. That year, Dow reported discharging 5.69 grams into the river. In 2001, it reported 2.565 grams; in 2002, 4.3 grams; in 2003, 0.894 grams, and in 2004, 1.57 grams.
While the amount of dioxin released appears to have increased over last year, Dean said — and DEQ officials agree — that the number is an estimate, not an absolute, and varies based on the amount of water being processed, rather than actual detection and measurement of dioxins.
“We haven’t really been seeing any detectable dioxins or furans in the effluent,” DEQ Geologist Allan Taylor said. “They have to report, and they have to base that report on what could be there. That number is a very conservative estimate of the most that could be there.”
The measurement of dioxin and dioxin-like compounds reported by Dow also is a total mass number — that is, it does not account for variations in toxicity. The amount of TCDD, the most toxic of the dioxins and dioxin-like compounds, is calculated at about a half a percent of the mixture. Another 16 types of dioxins are also included in emissions, each with lower levels of toxicity.
Taylor said the dioxin discharged into the Tittabawassee River today is different in makeup from historical discharges that contaminated river sediment, the flood plain, and stretched into the Saginaw River and Bay.
“It does look very different from the samples that we’ve taken,” Taylor said.
Dow also reported 0.22 of a gram of dioxin discharged into the air.
Other dioxin releases shown in the TRI for Dow include 27,231 grams disposed of — a large jump from what other industrial facilities reported. “The next closest is less than one gram,” said Ruth Borgelt, DEQ TRI data analyst. She attributes that increase to remediation activities. Even landfilled materials must be reported, even though disposal is being conducted properly without public impact.
The majority of the dioxin Dow reported comes from an ongoing project involving the dredging of its tertiary ponds to remove sediment and move it to its Salzburg Road landfill. The movement of that material had to be reported, even though it was landfilled and disposed of properly.
Dean said that project is expected to be completed this year.
Overall, the company has reported strong improvements in the amount of chemical emissions it has produced since 1994 — 2004 marked a 42 percent reduction. There has, however, been an increase in the number of release incidents it reported to governmental agencies. In 2004, the most recent report available, there were 29 incidents where Dow’s chemical releases exceeded permitted limits — a 10-year high. In 2003, there were 22, and in 2002, 16 incidents.
Reducing that number to zero is the goal of the site’s “Drive to Zero campaign launched in 2005 with a “vision of zero — zero injuries, zero incidents and zero environmental harm.”
“We will continue to build on the improvements we’ve made and address areas where our performance still needs to be stronger,” Dow spokeswoman Anne Ainsworth said.
Globally since 1996, Dow’s solid waste has been reduced by 1.6 billion pounds — enough to fill 415 athletic fields one meter deep — and waste water has been reduced by 183 billion pounds — equal to water usage for 170,000 U.S. homes for one year. Since 1995, Dow has invested more than $400 million in a variety of dioxin reduction projects, including improvements to treatment technology projects. The result has been an 80 percent reduction of dioxin emissions to air and water, and to air alone, a 95 percent reduction.
Dow’s 2005 public report for Michigan Operations is expected to be available in late May or early June.
Details about Michigan’s Toxic Release Inventory data are available on the Internet at www.michigan.gov/deqsara. Other information about the TRI is available at www.epa.gov. Dow’s public reports for Michigan Operations are available at www.dow.com.

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