Tag Archives: Tittabawassee

Soil tests to begin this summer; dioxin resolution planned for 2017

KATHIE MARCHLEWSKI, MIDLAND DAILY NEWS, MAY 11, 2006
DOW WANTS RESULTS DIOXIN SURVEY KEPT CONFIDENTIAL FOR HOUSEHOLDERS’ SAKES, DO NOT ENVISAGE REMEDIAL ACTION ANY TIME IN THE NEXT DECADE
The Midland residents whose properties have been chosen for the first phase of dioxin-related soil sampling are expected to be notified in June. A final resolution to the local contamination issue, however, could be much further off.
The Dow Chemical Co. and Michigan Department of Environmental Quality this week have been working on a plan to begin soil testing here, and have come up with a preliminary strategy including the identification of a sampling grid and the identification of a program that will keep test results private.
“In Midland, we have specific concerns relative to confidentiality agreements,” said Gary Dyke, Dow-contracted project manager with Midland-based CH2M Hill. “We feel like we’re all moving in the same direction.”
The program includes testing in 145 300-by-300-foot boxes. From those boxes, five soil samples would be taken. Only one would be analyzed for dioxins and furans. The boxes chosen are located in varying distances from the Dow plant, mostly to the north and northeast.
Residents who wish to know how much dioxin is in their individual properties will be able to request test results. “If people want their results, we want to make sure they get their results,” DEQ Geologist Al Taylor said.
Both Dow and the DEQ are sensitive to property owners’ privacy concerns, and want results to be kept confidential. As proposed, however, the sampling plan could jeopardize confidentiality. That’s because the potential exists for all five property owners within a sampling box to request results. If that happened, four would find out their soil was not analyzed. By process of elimination, the fifth property, the one that was analyzed, would be revealed.
“That’s a potential problem,” Taylor said of the plan. The two are continuing to work on a resolution to that issue.
Meanwhile, the DEQ also is reviewing Dow’s most recently submitted remedial investigation work plan. After issuing the company a notice of deficiency for the plans submitted earlier this year, the DEQ received revised plans May 1.
“It’s not quite yet where we want it to be,” Taylor said.
While Dow will be out conducting testing this spring, summer and fall, the sampling program is a preliminary one. Samples will be used for a bioavailability study Dow expects to complete in 2010. From 2009 to 2013, the company is proposing a human health risk assessment and from 2012 to 2014, another round of soil sampling. The work plans suggest that potential remedies would be explored and selected in 2015, with a two-year implementation ending in 2017.
Proposals for the Tittabawassee River and its flood plain are on a slightly speedier schedule, with completion set for 2012.
“It’s a proposed timeline with the understanding that there are a number of things that could change that,” said Dow spokesman John Musser. “The things we learn could shorten the cycle — or make it longer. Until we’ve got more data, it’s the best guess we’ve got.”
Environmental Protection Agency officials who first expressed concerns about Dow’s work plans said after an initial review of revisions, they have concerns about the schedule. So does the DEQ. The two agencies are working on a high-level review and comments.
“It looks like there are opportunities to expedite some things,” said Greg Rudloff of the EPA.
There also might be opportunities for interim response measures; such as ones already under way to protect people from exposure in areas of known contamination. “That might increase our comfort level with the time frame,” Rudloff said.

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Judge clears way for dredge basin

JEREMIAH STETTLER, THE SAGINAW NEWS, MAY 10, 2006
“TWO FOR THE GOOD GUYS!” EXCLAIMS MORONIC OFFICIAL KOSKI AS TOWNSFOLK FAIL IN THEIR BID TO KEEP TOXIC DIXOIN SLUDGE AWAY FROM THEIR HOMES
DETROIT — A U.S. District Court judge has refused to stop construction of a nearly 300-acre storage basin for dredge spoils along the Saginaw River.
Judge Bernard A. Friedman denied a temporary restraining order and preliminary injunction Tuesday that would have kept the U.S. Army Corps of Engineers from beginning work this week on a disposal site for river muck in Zilwaukee and Frankenlust townships.
The judge ruled that the project will not cause “irreparable harm” to human health or the environment, despite claims to the contrary by litigants Lone Tree Council and Environment Michigan.
The decision comes as the second victory in less than a month for Saginaw County, which owns the 281-acre property that someday could hold silt sucked from the Saginaw River. The county has faced rising litigation in the weeks before the Corps of Engineers starts construction on the property.
Bay County Circuit Judge Lawrence M. Bielawski denied an injunction sought last month by Frankenlust Township officials who claimed the county had trampled over their zoning laws.
Now comes Friedman’s decision.
“Two for the good guys!” exclaimed Saginaw County Public Works Commissioner James A. Koski after the ruling.
Koski said construction could begin as early as Thursday on a storage basin fashioned out of clay that could hold up to 3.1 million cubic yards of dredge spoils.
The project is a key component of the corps plan to dredge the upper Saginaw River. Without it, dock owners say commercial shipping could slow to a trickle and even stop, threatening up to 280 jobs tied directly to river commerce.
Environmentalists call it a faulty project that will endanger the lives of people and wildlife along the Saginaw River. What worries them is dioxin, a persistent byproduct of chemical manufacturing and other industrial processes that scientists have linked to birth defects, immunodeficiencies and some forms of cancer in laboratory animals.
The Corps of Engineers has found dioxin levels up to 11,812 parts per trillion in the river channel — 131 times higher than the state limit of 90 parts per trillion.
Environmentalists say those contaminants, if not handled properly, could have far-reaching implications on the people and animals that live around the proposed dredge disposal site.
“The dioxins in the Saginaw River are the same ones which in the Tittabawassee River triggered all kinds of public health and environmental interventions by regulatory agencies,” said Lone Tree Council spokeswoman Michelle Hurd Riddick.
Koski contends the site is safe.
“We are making it safer than the corps has built anywhere,” he said. “I am absolutely and totally confident that it was done right.”
Lone Tree filed suit in U.S. District Court last week to stop the project. The organization claims federal law requires the Corps of Engineers to conduct a rigorous environmental impact statement before using the site.
The corps disagrees, saying the site lacks the “significant” environmental impacts to warrant it.
Lone Tree still will get its chance to argue for a comprehensive environmental review. Friedman denied the injunction but said environmentalists may pursue their claims for an environmental impact statement before Judge David M. Lawson in Bay City.
Hurd Riddick said she is disappointed but not undeterred.
“It is one battle of many,” she said. “You win some, and you lose some. Our focus has always been getting the EIS done. That is where our focus will stay.” v
Jeremiah Stettler is a staff writer for The Saginaw News. You may reach him at 776-9685.

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Dow-funded study finds food downstream more toxic for Tittabawassee songbirds but makes light of it

Mónica Guzmán, Midland Daily News
It might look like the same trees and shrubs from a bird’s-eye view, but whether an eastern bluebird, tree swallow or house wren builds its nest upstream or downstream of The Dow Chemical Co. could mean the difference between everyday flies and earthworms and slightly more contaminated grub.
[Ed: 339 times more contaminated, see below! The Midland Daily News is Dow’s home town newspaper. For facts, visit http://www.trwnews.net/]
That’s the preliminary finding of a Dow-funded study on common songbirds living on the Tittabawassee River watershed.
The project, one of a group of contamination studies conducted by doctoral students at Michigan State University, is about one-third complete, said its lead researcher, Timothy B. Fredericks.
But there are still plenty of measurements left to take – including tissue and behavioral data – before anything can be said about what the difference in diet means for the birds.
“They are still here, so take that as you will,” said Fredericks, who presented his findings to the public at the Chippewa Nature Center Thursday. “It’s preliminary, but I’m going to say they’re OK.”
His was the last installment of a four-part weekly series at the nature center about chemical contamination and local wildlife.

Upstream of Dow, all is tickety-boo for the Eastern Bluebird As for its downstream cousin? Stop! Spit that out at once!

Songbirds living downstream from the Dow Chemical plant ate insects and worms with up to 55 times more toxins than birds nesting upstream, the study found.
Ninety percent of the toxins are difurans, a compound related to dioxins, Fredericks said.
Sneaking a peek at the birds’ meals was not easy. First, the researchers had to carefully extract food from wide-mouthed nestlings after mom or dad delivered the feast. Then, they had to sort out the menu of spiders, mayflies, moths and earthworms – in various stages of digestion – from more than 1,000 collected samples, and tally each item’s predetermined toxicity.
“You learn your bugs, that’s for sure,” Fredericks joked.
Earthworms living downstream picked up the most of the soil and sediment-bound toxins of all the critters in the birds’ diet. The worms – bluebirds’ favorite snack – showed 339 times more contaminants than those further upstream.

 
Earthworms collected upstream of Dow were taken as a control sample to compare toxic loads   Downstream of Dow earthworms contained 339 times more toxins, including dioxins and furans

Flies were 32 times more toxic downstream, and downstream moths – the house wren’s preferred prey – had 20 times more contaminants.
Still, the actual toxic content is at most a few hundred parts per billion, he said, and to what extent the birds are what they eat is a question that warrants more research.
“It will be interesting to see if the tissue concentrations match up with the dietary concentrations,” Fredericks said.
Testing the birds’ bodies for the presence of toxins and looking for any changes in nesting and growth are the next steps in what might be a three- or four-year project.
A similar Michigan State study presented last week found that owls are exposed to 100 times more contamination when they feed downstream of the company as when they feed upstream.

Wise old owls stay well upstream of Dow Chemical Owls downstream of Dow eat 10,000% more toxins

On Thursday, Fredericks said he had no expectations coming into the study, which kept him in the field as much as 18 hours a day while he gathered data between April and August last year, tagging nearly 900 birds for future observation in the process.
“I’ve always been attracted to birds, because they’re everywhere,” said Fredericks, who is preparing for another summer of intense research. “No matter where you go, anywhere you go, you see a bird.”

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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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Dow Chemical's work plans "fundamentally flawed" and "critically deficient" says EPA

The recent work plans submitted by Dow Chemical to MDEQ which were at the center of the recent DEQ- Dow meeting on Feb. 9th, have been reviewed by EPA Region V and the review is highly critical of Dow’s plans. The work plans are of highest priority because they determine how the state proceeds with cleanup.
Failing to pass scientific scrutiny within EPA Dow once again submits plans so deficient as to be transparent. No company with the resources that Dow has can consistently submit plans so inadequate and so lacking unless it is by design. Like the Consent Order in 2002, the Risk Assessment in 2002, the Scopes of Work in 2003 and the IRA’s, Dow’s intentions are to deliberately:

Ignore compliance with their license
Delay defining the extent of their contamination
Deny the toxicity of dioxin
Rewrite the science to benefit them
Rewrite the laws that govern them
Delay Cleanup

It’s a legitimate question to ask if “voluntary corrective action” really works or if it’s just a burden on the taxpayers as it drains resources and tax dollars within our budget strapped DEQ. Not to mention the natural resource and public health implications associated with deliberate delays created by a corporation that has no interest in being responsible. Under the provisions of voluntary corrective action the State of Michigan has spent years working with Dow to bring them into compliance. Folks it’s not working!
Some snippets of EPA’s comments to MDEQ,
“The Human Health Risk Assessment Work Plans (HHRAWPs), as proposed by Dow in the RIWPs, do not comply with EPA risk assessment policy and guidance and, therefore, cannot be approved by EPA” —–What are the odds Dow doesn’t know what the EPA policy is? Dow just chose to ignore the policy because it doesn’t fit their agenda.
“Dow’s current proposal to use approximately one sample to characterize each mile of river (25 samples per 22 miles of river) is unacceptable”. —-Dow has argued that no actions toward final remediation can take place until such time as we understand what properties are contaminated and how much contamination there is. Yet Dow repeatedly puts up every road block possible to delay information gathering.
“Dow’s proposal in the M-RIWP to delay Phase II sampling until 2008 is not acceptable to EPA. Rather, to avoid this unnecessary delay in the remedial investigation and to minimize any ongoing exposure and associated risks, EPA requests that MDEQ require Dow to initiate the Phase II sampling, described within the M-RIWP, no later than Spring of 2006”——–How Dow Chemical loves those delays.
You can read all of EPA’s comments on the TRW web site. www.trwnews.net or e-mail me and I will send them to you.
Much of what Dow is attempting to do with a rewrite of the science and the law is in an attempt to get out ahead of the release of Dioxin Reassessment at EPA. Again, Dow Chemical is the only entity that continues to deny, at the expense of public health, the toxicity of dioxin.
Through sheer political force, lobbying and local philanthropy Dow has been able to outflank regulatory agencies, rules, laws or anything else that constrains their profitability. Dow has been able to ruin the commons and trespass onto personal property and properties owned by the people of the State of Michigan almost with impunity and Dow’s dioxin will migrate to Lake Huron poisoning another entire eco-system and economic resource for decades.
While Dow is busy hanging their diamonds all over Saginaw County and ingratiating themselves with all the movers, shakers and policy makers, please, see it for what it is, a public relations campaign to avoid being responsible. The very thing we demand of government and individuals we should expect from Dow. There are responsible corporations – Dow just isn’t one of them.
Best regards,
Michelle Hurd Riddick
Lone Tree Council

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