Subject: Ongoing, previously unidentified dioxin source from the Dow site?

Date: May 24, 2002

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Dow/2,4,6-Trichorophenol/Dioxin?

ONGOING PREVIOUSLY UNIDENTIFIED DIOXIN SOURCE FROM THE DOW SITE?

Both the EPA and state agencies have generally ignored the potential for
ongoing dioxin releases from the Dow facility in Midland and declared that
most of the dioxin found in the community is "Historical." No one disagrees
that Dow's hazardous waste incinerator was the major source of dioxin on
Midland, but there is evidence to suggest that other processes and products
may continue to add additional dioxin to the already high existing levels in
the community.
Dow has never been required to report all of the known or suspected dioxin
sources from their facility. None of the agencies have thoroughly investigated the
potential for ongoing dioxin emissions from Dow processess and products.

In 1999 Dow told local activists that they were collecting data on
Persistent, Bioaccumulative, Toxic (PBT)chemicals from their 15 business
leaders at the Midland facility (Greg Bond).
Each business leader was supposed to (1) identify any known PBT and (2)
develop a plan to reduce/eliminate the PBT from the process.
To date we have been unable to get any information on the status of Dow's
investigation or progress on reducing and eliminating PBT's from their
processess.
The state told me that they have no authority to request this information.

POTENTIAL DIOXIN SOURCE:

In May 2001 I contacted the MDEQ Waste Management Division regarding Midland
chemical releases of 2,4,6-Trichlorophenol from the Dow facility and
suggested this as a potential dioxin emission not previously identified.
Historical evidence I collected suggests that 2,4,6-Trichlorphenol contains
dioxins.
I also contacted Jeff Feerer from Dow to ask where these 2,4,6-T releases came from.

2,4,6-T is linked to Dow's Dichlorophenol Process.

Jeff Feerer responded on May 24, 2001 and told me that 2,4,6-Trichlorophenol
is a byproduct in a waste stream from the reactor that makes dichlorophenol.
He said it is made in the reactor and not used as a raw material.

November 3,2000: Dow reported an unknown quantity of 2,4,6-Trichorophenol
was released to the atmosphere in Midland for approx 4 hours.
I looked at some of the other reports and found others.

Feb 5, 2001: A combination chemical release to the atmosphere of
2,4,6-Trichrophenol, 2,4-D, Sulfur Dioxide, Hydrogen Chloride, and Phenol.

May 23, 2002: EPA released the TRI data and I noted that
2,4,6-Trichlorophenol was still being released from the Dow facility.

I jotted these numbers down quickly from the EPA TRI site last night.
Reported 2,4,6-Trichlrophenol releases in Midland for the year 2000: 104
pounds to the Air, 210 pounds to Surface Water, Total on and Offsite
releases were 371 pounds.

2,4,6-Trichlorophenol/2,4-D/Dioxin?

I have repeatedly tried to get both the state and federal agencies to look
at other potential dioxin sources from the Dow site.
Since 1999 I have requested that the DEQ look at Dow's 2,4-D process and
product because it contains dioxin and is widely spread throughout the
environment and has been released to the air in Midland on many occasions
(SARA Title III).
Several studies have linked exposure to 2,4-D with Non-Hodgkins lymphoma.
No one seems to be able to explain How 2,3,7-8-TCDD got into Dow's widely
used herbicide 2,4-D and no one has paid close attention to the
2,4,6-Trichorophenol linked to the process.

Of greater concern is the fact that the state refuses to fingerprint 2,4,D
and sample both the process and product to determine the levels of dioxin.
This product is spread all over lawns, parks, schools and used by farmers on
crops. It is also dumped in Michigan lakes for so-called "weed control."
Even if the levels of dioxin were found to be low the widespread usage would
be a concern.

For years, Dow denied that 2,4-D contained dioxin (2,3,7,8-TCDD).
In 1999, Dow's Greg Bond told me that there was 2,3,7,8-TCDD in 2,4-D, But
the levels were lower than they were in the past.

I have repeatedly asked (1) what were the historical levels of dioxin foound
in 2,4,D? and (2) what are the current levels of dioxin?
Dow submitted some shaky information to the DEQ using detection limits that
were too high.

2,4,6-TRICHLOROPHENOL HISTORY AND DIOXIN CONCERNS

2,4,6-Trichlorophenol (CAS No. 88-06-02) First listed in the Third Annual
Report on Carcinogens.

CARCINOGENICITY:
THERE IS SUFFICIENT EVIDENCE FOR THE CARCINOGENICITY OF
2,4,6-TRICHLOROPHENOL IN EXPERIMENTAL ANIMALS (NCI 155, 1979; IARC V20,
1979;IARC S.4, 1982;IARC S7, 1987).
WHEN ADMINISTERED IN THE DIET, 2,4,6-TRICHLROPHENOL INCREASED THE INCIDENCE
OF LEUKEMIAS OR LYMPHOMAS IN MALE RATS AND HEPTOCELLULAR CARCONOMAS AND
ADENOMAS IN MICE OF BOTH SEXES (NCI 155, 1979)

An IARC Working Group concluded that there is limited evidence for the
carcinogenicity of chlorophenols, including 2,4,6-T in humans. Four coohort
studies of men involved in the manufacture of trichlrophenols indicated a
relationship between exposure to chlorophenols and the incidence of SOFT
TISSUE SARCOMAS AND LYMPHOMAS.
NONE OF THESE STUDIES DISTINGUISHED EXPOSURE TO 2,4,6-TRICHLOROPHENOL FROM
EXPOSURE TO TETRACHLORODIBENZO-P-DIOXIN (TCDD) OR OTHER CHEMICALS IN THE
WORKPLACE WITH ANY CERTAINTY. (see 2,3,7,8-tetrachlorodibenzo-p-dioxin,
Section III B, IARC S 4, 1982, IARC S7, 1987)

March 15, 1983: Internal EPA Chlorinated Dioxin Work Group;
Listing Background document.
Excerpts:
Summary; CDDS'S AND CDF'S ARE PRESENT IN WASTES RESULTING FROM THE
PRODUCTION OF MATERIALS ON EQUIPMENT PREVIOUSLY USED FOR THE PRODUCTION AND
MFG OF THE PRODUCTION OF USE OF THE FOLLOWING:

2,4,6-Trichlorphenol.

The EPA's Cancer Assessment Group determined that 2,4,6-Trichlorophenol was
a potent carcinogen. In addition, Chlorophenols may cause liver and kidney
damage; some chlorophenoxy compounds may have reproductive effects.
ALTHOUGH THESE COMPOUNDS MAY UNDERGO ENVIRONMENTAL DEGRADATION, THEY ARE
SUFFICIENTLY PERSISTENT AND UNDER SOME ENVIRONMENTAL CONDITIONS TO WARRANT
CONCERN FOR THEIR HUMAN HEALTH EFFECTS..

TWO OF THE TOXICANTS OF CONCERN IN THESE WASTES (CDD'S AND CDF'S) ARE
CAPABLE OF CAUSING OR SIGNIFICANTLY CONTRIBUTING TO SERIOUS IRREVERSIBLE
ILLNESS OR INCAPACITATING IRREVERSIBLE ILLNESS AT LOW DOSE LEVELS.
MOREOVER THESE TOXICANTS ARE PERSISTENT AND CAN MIGRATE FROM THESE WASTES IF
IMPROPERLY MANAGED. THE ADMINISTRATOR HAS THEREFORE DETERMINED THAT THESE
WASTES ARE ACUTELY HAZARDOUS.

EARLY EVIDENCE OF DIOXIN IN 2,4,6-T

In 1975, production of the compound was limited because of the high cost of
removing TOXIC CHLORINATED DIBENZO-P-DIOXINS OCCURRING AS IMPURITIES IN
SAMPLES OF 2,4,6-TRICHLROPHENOL. Commercial production of
2,4,6-Trichlrophenol was first reported in 1950.

OCCUPATIONAL EXPOSURE: The primary routes of potential exposure to 2,4,6-T
are Inhalation and Dermal contact. The risk of potential occupational
exposure to 2,4,6-T is greatest for workers involved in wood preservative
and textile treatment.
The National Occupational Exposure Survey (1981-1988) indicated that 851
workers, including 187 women were potentially exposed to
2,4,6-Trichlorophenol in the workplace (NIOSH 1984).
The National Occupational Exposure Survey conducted by NIOSH from 1972-74
estimated that 110 workers were possibly exposed to 2,4,6-T in the
workplace. Worker exposure was primarily in HOSPITALS, AND IN THE LEATHER
TANNING AND FINISHING INDUSTRY.(NIOSH, 1976)

ENVIRONMENTAL CONTAMINATION

ACCORDING TO NCI, SUBSTANTIAL EXPOSURE OF THE POPULATION IS QUESTIONABLE;
HOWEVER RESIDUES MAY BE PRESENT THROUGHOUT THE ENVIRONMENT SINCE IT HAS BEEN
USED AS A PESTICIDE.
THE COMPOUND HAS BEEN DETECTED IN TROUT EXPOSED TO PESTICIDE RUN-OFF.

2,4,6-TRICHLOROPHENOL CAN FORM IF INDUSTRIAL WASTEWATER CONTAINING PHENOL OR
CERTAIN AROMATIC ACIDS IS TREATED WITH HYPOCHLORITE.
INVESTIGATORS HAVE DETECTED TRICHLROPHENOL IN RIVER WATER SAMPLES, LANDFILL
LEACHATE SAMPLES, CHEMICAL PLANT EFLLUENT SAMPLES, FINISHED DRINKING WATER
SAMPLES.

The Toxic Chemical Release Inventory listed THREE INDUSTRIAL FACILITIES that
processed, or otherwise used 2,4,6-Trichlorophenol in 1988 (TRI 1990).
In compliance with the Community Right-To-Know program, the facilities
reported releases of 2,4,6-Trichlorophenol to the environment which were
estimated to total 12,300 pounds.
Additional EXPOSURE INFORMATION may be found in in ATSDR Toxicological
profile.

I hope this is finally enough information and that someone will investigate
these additional potential dioxin sources from the Dow facility.
2,4,6-Trichlorophenol would clearly be expected to contain dioxin and the
fact that 2,4,6-T is linked to Dow's 2,4-D herbicide process is even more
interesting. This process and product needs to be investigated as a dioxin
source.

I've noticed that agencies have selectively ignored the potential exposure
from industrial products even though there is overwhelming evidence to
suggest that many of these products have contaminated the environment and
exposed the public, especially dioxin-contaminated herbicdes..

2,4,D is up for Re-Registration in 2003. The EPA has not been able to
provide any information on the dioxin in Dow's 2,4,-D.
The widespread use of this product could be a significant source of dioxin
in Midland, in Michigan and throughout the country.
The potential impact of this dioxin source needs to be addressed.
This is an additional dioxin risk in the Midland community and beyond.

This information needs to be investigated and considered as an additional
risk factor for Midland residents.
The releases of 2,4,6-Trichlorophenol from the Dow facility appear to be
another route of dioxin exposure not previously considered by the agencies.
The relationship between Dow's 2,4-D process and 2,4,6-Trichlorophenol
should raise some new questions and investigations by both state and federal
agencies..

Another route of exposure for Midland residents and suggestive evidence that
there are STILL ongoing sources of dioxin emissions from the Dow facility in
Midland not previously considered by the state and federal agencies.


Diane Hebert
Midland, Michigan


Source: Diane Hebert

For additional articles like this one, go to the Tittabawasse 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.