07/11/07 READ THIS - Unbelievable, shocking, it isn't just dioxin anymore!!
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
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.
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 188.8.131.52 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:
Chlordane (Dow-Klor and Dowchlor)
Mercury and mercury compounds
Cadmium and cadmium compounds
Heptachlor (+Heptachlor epoxide)
Tetrachlorobenzene (1,2,3,4- and 1,2,4,5-)
[Plus PAHs as a group, including but not limited to]:
Click here to view the entire document
For additional articles like this one, go to the Tittabawassee River Watch web site www.trwnews.net. for complete coverage of the Tittabawassee River Dow Chemical dioxin contamination saga.. The source organization's web site link is listed above. The Newspaper / Media page of our site contains an extensive archive of media articles dating back to January 2002. The Newspaper / Media page may be accessed by scrolling down to the bottom of the CONTENTS section and clicking on the Newspaper/Media link.