Dioxin Update
Lone Tree Council and TRW
December 9th  2007 # 109
Needless to say it's been a busy couple of weeks with regard to Dow Chemical's dioxin contamination in our watershed. Please go to the TRW website to find a copy of the EPA memo and a copy of the complaint filed by Dr. Priscilla Denny seeking whistle blower protection from Dow Chemical. You can also link to the various news stories over the past few weeks.
There were a  few e-mails looking for clarification after reading Friday's Saginaw News which implied  DEQ was reviewing sampling data based on the EPA memo. Not the case. Flawed sampling data is being brought into question by Dr. Denny of Dow Chemical. The EPA memo doesn't speak to this issue at all. Two entirely separate issues.
Please read the EPA memo. It documents, in many cases, what others already knew: Dow's penchant for closed doors, confidentiality, leveraging politicians, resisting any other entities science on dioxin and insisting on studies not needed to carry out their legal obligations. Dow's John Musser debunked the memo as did many of Dow's supporters in the business community. None of them challenged any specifics in the document-- their arguments did not challenge the accuracy of the EPA statements but instead focused on defending Dow and calling into question how  Lone Tree secured the document-- Let me answer that-- we filed a FOIA and the document was released. It's a bit disturbing to me that there are community leaders who think this information should be private. Perhaps for some people Dow's image is more important than transparency and community right to know. 
What is all this feigned surprise about EPA's statements anyway? Since 2004, EPA has leveled numerous formal written complaints about Dow's shoddy work plans and lack compliance with the company's obligations under RCRA. EPA commented in June 2006 and again this past June EPA issued a 44 page document severely critical of Dow. Then in a July 13th 2007 Dow Activity Report EPA states: " Major deficiencies include: lack of implementation schedules, human health and ecological risk assessments that are inconsistent with U.S. EPA guidance, lack of progress in addressing dioxin hot spots, and an inadequate description of Dow's historic plant operations for use in developing a target analyte list.
Would appear the discomfort over the release of this memo is because Dow is being called out for their bad behavior.
So while Dow and their apologist say Dow is making progress they are doing so in part with an EPA gun to their head and sampling data that is off the map.The real question is what is being delayed because of  Dow's failure to follow the law under RCRA. The document speaks for itself. Please read it.
Progress has been made.  The DEQ pushing for sampling is what is driving the discovery of these hot spots and EPA issuing the CERCLA orders has forced Dow to move on these issues.
Human Element lost locally but recognized in Michigan's leading newspapers
We've all seen Dow's Human Element commercials--- infusing humans into  the Element Table and drawing humans into the chemistry equations of life while the New Harmony Waltz ( beautiful piece of music) plays in the background.
Both the Detroit News and Detroit Free Press carried stories in recent days looking at the people who live on the dioxin contaminated floodplain of the Tittabawassee River. People whose homes and yards have been contaminated and their lives forever changed because of the presence of dioxin.
The most significant issue raised at the  November DEQ meeting was a group of residents asking EPA to place them in the SUPERFUND RELOCATION PLAN. 
The Dow Human Element ad says,   ďAnd in the dazzling brilliance of this knowledge, we may overlook the element not listed on the chart. Itís importance so obvious, itís presence is simply understood. The missing element is the human element.Ē----
Tugs at the ole heart strings-  Almost moved to tears until you read and watch how people, their homes and yards, resources and public process- all those things that identify them as part of a community- are dismissed, denied or downplayed as just not important in Dow's quest to avoid responsibility and protect its bottom line. These people on the floodplain matter as do the people who consume the fish and utilize the land and waters resources in this region. People asking to be moved out of their homes because they don't want to live on contaminated property is a very big deal. TV-5 and TV 12 covered the story at 11 pm but nothing in the print media. Detroit Free Press covered the meeting and reported on the request to EPA for relocation.
EPA said they will get back with residents soon about their request for relocation.  Here are the links to the stories in the Detroit News and Free Press.


Dow Employee files for Whistle Blower protection

Dr. Priscilla Denny, a Dow Engineer brought to Michigan from Texas to oversee sampling alleges she was demoted for questioning dioxin level sampling data submitted to MDEQ.  Dr. Denny has filed  for protection from Dow Chemical for revealing that Project Enhancement Corp., the Germantown, Md., company hired to validate data from samples collected in August 2006, rejected the data because of "major technical non-compliance," according to Dr. Denny's complaint. She states she reported the flaws to her Dow supervisors, but Dow "submitted said bad data to the state on or about February 1, 2007.

This could be one ugly Pandora's box.................

Dow Deadline is tomorrow
Dow is suppose to submit plans for cleanup to EPA tomorrow. We can always hope the third time is  charm. This being the third time Dow has gone behind closed doors to negotiate a cleanup. 
About that 1.6 million ppt in the Saginaw River
One can only hope that the 1.6 million ppt find would be the one and only. However, the suggestion  was posed to a citizen at the DEQ quarterly meeting that there are likely others. Why? Think about it. What are the odds in 52 miles of river that this one nugget ( Dow word not mine) was found. More likely there are others in that region.
No less than 300 newspapers, magazines and media outlets carried the news of Michigan's largest watershed, our own Saginaw River  being home to the nations highest level of dioxin.
The MSU Wildlife Study
Please go to the TRW web site to read Gary Henry's comments:
The Michigan State University "Tittabawassee River Ecological Studies " presentation at the 11/28/07 quarterly dioxin meeting was intended to "convince" the attendees that even though wildlife in the contaminated floodplain are assimilating dioxin at a rapid pace, they are not exhibiting any ill effects. The study protocol includes the tagging/banding of the test subjects at the time of tissue and blood sampling. Depending upon the species tested, only 3% to 27% of the 3200+ subjects tagged where re-captured for subsequent re-testing. In other words, up to 97% of a particular species samples where taken from animals whose prior whereabouts are unknown.
This plan was not approved by DEQ or EPA  because it fails to follow established guidelines. It begs asking why Dow is being permitted to take up meeting time with unapproved studies that do not meet scientific guidelines. We did ask and are waiting for an answer.
Links to the stories
Here are the links to recent stories. Please take a moment to also read the comments posted online by readers. Most interesting.
FreePress Dioxin Deception  12/07/07
FreePress Fed up with dioxin: 12/09/07
SN 12/07/07
SN 12/08/07
Detroit News 11/23/07
Best Regards,
Michelle Hurd Riddick
Lone Tree Council

Source:  Lone Tree Council / TRW

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.