Subject: Environmental information and recommendations withheld from the public

Date: November 21, 1983

====================================================================

12/14/04

The 1980's EPA Dioxin Study is often tossed out there to suggest that the levels of dioxin found during the study were acceptable. These soundbites oversimplify the issue. Most Midland residents were not closely involved with this study, and were/are listening to Dow, Midland City officials and public statements made by some carefully selected EPA officials. Public relations. Critical public health, environmental information and recommendations were withheld from the public, and therefore to this day many remain confused about the dioxin issue.

Expensive public relations tactics by Dow and Midland City officials, recruiting favorite politicians (most funded by Dow) and pressure on the Governor (using the economic hammer) have all been used before. I've watched this performance in the past and feel like I'm watching a re-run today. Unfortunately, all of these games result in the continued poisoning of thousands of residents and our precious natural resources. I'm afraid that mistakes and oversights made by the EPA in this 1980's study are about to be repeated today. Openess, truth, active participation and transparency are critical components that must be part of this process if we are ever going to move forward.

The following is for your consideration, but it is only the tip of the iceberg.

Thanks,

Diane Hebert Midland, MI.

_____________________________________________________________________________

Excerpts:

Date: Nov.21, 1983 United States Environmental Protection Agency Region V

SUBJECT: Visit to Dow Chemical Company Midland Plant, November 15, 1983

From: Jon Barney, Permits Section

To: David Stringham, Chairman Dioxin task force

Participants in the discussions and plant tour, in addition to me, were:

U.S. EPA: Phil Gehring, Dave Barna

Dow: Vern May, Gary Veurink, Dave Wilson

We arrived at the 1710 Building at about 1:00 p.m and had a brief meeting before starting the plant tour. After an explanation by Barna of the information we needed on the desired sampling locations, we raised the issue of relating the block flow diagrams in the Form 2C permit application to the major sewers we planned to sample. At May's request I reviewed our reasons for wanting this information and how it would be used for developing the permit. All three Dow representatives discussed the problems with determining correct flows for these sewers.

- Sewers have been cross-tied at various points over the years, so they are no longer truly separate.

-Several years ago flow measurement equipment was installed in many of the internal sewers at a cost of about $350K, but continuing severe problems in maintaining the equipment together with flow interference problems caused by the equipment itself caused them to junk the whole system.

- Flows estimated for Effluent Guideline Development,e.g., have always been capacity (design) flows, but (they believe) flows provided under our 308 were estimates of actual flow for 1980-81.

- Significant reductions in flow due to increased recycle, decreased once-through cooling, process modifications, etc., have been occurring steadily over the years.

- Many processes have been shut down entirely.

They said they could not provide a boat for us to use on the Brine Pond and Tertiary Pond, due to their liability in case of mishap. They thought arranging a location for our trailer (probably outside plant fence) should not be a problem. We will send a map of Dow's brine system to Gary Amendola.

I asked about permission to conduct the in-plant soil sampling. May said AS LONG AS ONLY SURFACE SAMPLES (top one or two inches) ARE CONTEMPLATED, HE COULD GET QUICK APPROVAL. I said we probably would want 2 or 3 cores as well. HE SAID THIS WOULD CAUSE REAL PROBLEMS WITH MANAGEMENT. THEY BELIEVE THAT "GEOLOGICAL EXPLORATIONS SHOULD BE LEFT TO OUTSIDE OF THE PLANT." NO ONE KNOWS WHAT IS DOWN THERE FROM PAST OPERATIONS, AND THEY ARE NOT EAGER TO FIND OUT IN THE ABSENCE OF ANY KNOWN PROBLEM. MAY SAID HE PERSONALLY IS NOT AWARE OF ANY HIGH LEVELS OF DIOXIN BEING COVERED UP ANYWHERE IN THE PLANT.

I told him we probably could begin soil sampling at the plant as early as next week, if they agreed to provide access. May said his quick review of the draft survey plan we provided indicated ONLY SURFACE SAMPLES WOULD BE COLLECTED. IF THIS WAS THE CASE, HE THOUGHT WE WOULD BE ABLE TO PROCEED. I said we would discuss this and get back to them.

Dave Wilson asked why the sampling of the incinerator wastewater and plant-site and landfill leachate was necessary for our BAT determination, since they understood BAT applied only to "processes." I explained that national effluent regulations were developed for industrial categories, generally looking at process wastewater only. However, in determining BAT permit limitations at a particular facility, all sources contributing toxic pollutants to the wastewater must be considered.

c.c. Dioxin Task Force Distribution Manzardo, Pratt

Following internal EPA discussion:

Gary Amendola (EPA Dioxin Project Mgr.) stated that we are now preparing to do the Dow in-plant soils sampling. DOW HAS GIVEN THE OK FOR US TO TAKE SURFACE SOIL SAMPLES BUT NO CORES. Gary Amedola said that we should go ahead and get the surface samples, and if we detect problems with these, we can then reopen the issue with Dow regarding core samples. Extensive discussion ensued on the merits of this scenario vs. trying to get core samples now. Milt Clark and Jon Dikinis feel we should be trying to get core samples now. Gary Amendola and Dave Stringham feel it is not presently worth getting into a confrontation on this. Gary Amendola will, however, revise the soil sampling schedule to reflect a phased "surfacecore" approach. The samples will be taken around the 2,4,5-T production areas and incinerator sites.

Midland Community Relations: David Stringham and Gary Amendola plan to meet with CH2M-Hill's Nancy Tuor on December 1, 1983 to further discuss the Community Relations plan for Midland. Nancy Tour's interviews went very well.

Note: Dow did a massive clean-up before the EPA arrived to take samples. I reported this to the EPA at the time and their response was that it was good that Dow was finally cleaning up. One worker told me they sandblasted the incinerator. I personally observed open truckloads of soils being hauled offsite, (most down Bay City Rd.) A crossing guard on Bay City Rd. told me she had never seen this many trucks. Shortly afterward, this woman had to take time off for a severe eye infection. I don't know where all of the 'dirt' went. I also received reports from other local residents in Larkin Township of direct dumpling in some of Dow's old brinewells in Mills Township. Many of the areas within Dow were paved. The EPA left these areas alone.

I took Dave Barna on a day long tour of community sites ( in the city and county) that a few of us thought should be sampled (after extensive research). Some of these suspect areas we submitted were Dow's problem-plagued chemical injection wells. Dow plugged these wells with cement before the EPA could sample them. There were/are many other similar troubling details surrounding the EPA Dioxin Study in Midland.

Because this study is often used by Dow and Midland City officials to suggest that Dow and Midland received a clean bill of health I thought it was important to correct this myth. The EPA left many unanswered questions and raised some new ones. This is only one example, there are more. The pressure placed on the EPA by Dow, Midland City officials and the politicians recruited by Dow was similar to what we are seeing today. The EPA wanted out. Dow still had friends in EPA Headquarters. The Multi-Media Risk Evaluation done by Milt Clark in Region V was sanitized by EPA Headquarters, even though it was scientifically sound. The politics overrode the science. Midland residents were never given the opportunity to view the 'real' Risk Assessment. An 'Acceptable Risk' label was slapped on Midland, and to this day it is used to say that Midland dioxin levels are 'acceptable.'

Milt Clark resigned from the Dioxin Task Force. EPA Headquarters would not allow Dr. Clark to present his detailed assessment publically. I believe that David Stringham was hired by Waste Management Co.

Years later the consequences of these actions are evident. If the EPA had continued their sampling program within Midland and downstream/downwind, we may not be facing this crisis today. There was sufficient evidence then, as there is now, to suggest that Dow's dioxin had moved offsite and downstream, and that the magnitude of the contamination was massive. Due to political pressures, like we're seeing now, they just quit looking. I hope these mistakes are not repeated by the DEQ today.

Diane Hebert


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.