Lone Tree Council and TRW

Dioxin Update

March 6th 2006 #64

www.trwnews.net

NOTICE OF DEFICIENCY

 

On March 2, 2006, the MDEQ issued Dow Chemical its official Notice of Deficiency concerning Dow's proposed Remedial Investigation Work Plans (RIWP) for the Tittabawassee River and Midland.  Dow has 60 days to resubmit work plans to correct the 26 deficiencies noted.  Many of the MDEQ demands parallel the EPA's objections and are intended to force Dow to use principals and scientific methodologies acceptable to the EPA and other regulatory agencies rather than working so hard to develop the science that would benefit Dow. You can view the comments at the TRW news web site by clicking on current news. THESE PLANS ARE IMPORTANT BECAUSE THEY DETERMINE HOW TO PROCEED WITH RESPECT TO ALL AREAS OF CLEANUP. 

 

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Midland Daily News Editorial Page

March 1st 2006

Our View:  Compromise would be in order

 

 The government seems to be asking The Dow Chemical Co. if it is serious about addressing local dioxin contamination.
 At least, that seems to be at the heart of recent criticism of the work plan the company proposed, something it must do to comply with its operating license.

 

Snip

The EPA says the proposed testing plan is too sparse to produce technically supportable information about the nature and extent of contamination, and that the timeline is too long. It also says the human health risk assessment as designed fails to comply with federal and state risk assessment policies.

 

http://www.ourmidland.com/site/news.cfm?newsid=16218879&BRD=2289&PAG=461&dept_id=472539&rfi=6

 

 

Shame on you Mr. Musser.

Folks, Dow’s John Musser argues that Dow Chemical is not responsible to EPA. This is a bare faced lie and a deliberate attempt by Mr. Musser to deflect criticism of Dow pathetic work plans. The Midland Daily News is to be commended for pointing out the obvious. Dow’s license- permit to operate is a federal license. Oversight for Dow’s obligations to address the dioxin contamination and cleanup are granted to the state by the US Environmental Protection Agency which has final authority. Mr. Musser just doesn't like this inconvenient fact so he thought he would lie. --MHR

 

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Dow Remedial Investigation Work Plans for Saginaw River NOT SUBMITTED

 

Dow was to submit work plans for the upper Saginaw River by March 1 2006. It didn’t happen.  Lone Tree Council, using the Freedom of Information Act, requested a copy of the work plans. DEQ responded with the following statement.  “The State of Michigan DEQ & Dow Chemical Company have mutually agreed to defer submission of the Conceptual Work Plan for the Upper Saginaw River”.

 

Putting on a happy face? Once again, these two entities, DEQ and Dow, are making agreements outside the public view and without explanation. Usually when it's " mutual" but the public isn't offered an explanation we should anticipate some hard ball being played between the two parties. We are obviously not partners in their plans to cleanup our rivers or protect our resources.  We will keep asking and inquiring as to the details.  --MHR

 

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Dow Blow’s their own horn

 

Global Charter Reaffirms Dow Support Feb. 20^th 2006

Dow Chemical Press Release

 

http://biz.yahoo.com/prnews/060220/cgm021.html?.v=41

 

 

The Dow Chemical Company recently recommitted its support to Responsible Care® when Dow President, CEO and Chairman-Elect Andrew Liveris signed the Responsible Care Global Charter, a document that goes beyond the original elements of Responsible Care to consider evolving challenges for the chemical industry.

Dow participated in the development of the Responsible Care Global Charter under the auspices of the International Council of Chemical Associations (ICCA). In signing the Global Charter, Liveris joins a growing number of other chemical industry CEOs who have reaffirmed their support of the vision and ethics of Responsible Care on a global scale.

 

Snip

Responsible Care is the global chemical industry’s environmental, health and safety (EH&S) initiative to drive continuous improvement in performance. It achieves this objective by meeting and going beyond legislative and regulatory compliance, and by adopting cooperative and voluntary initiatives with government and other stakeholders.

 

We can't hear you Mr. Liveris

Dow is making unprecedented profits and is financially structured to meet their environmental responsibilities. They choose not to because they can. The big mistake we make is assigning any sense of ethic or social responsibility to this particular corporation.  Face it, the whole Responsible Care initiative was the public relations response to the Bhopal disaster. The Chemical industry knew they needed to get out ahead of their bad practices. Twenty years later, Dow’s signing of the Responsible Care Global Charter is just more public relations. Perhaps the new and improved version of the same old BS.   Even with their unprecedented quarterly profits this Fortune 50 Company in Midland has managed to avoid responsibility for using our rivers as their corporate sewers.

 

Dow with all their expertise and PhD’s should be on the cutting edge of environmental science, cleanup and restoration endeavors. But they choose to be divorced from the natural world in which they do business because it costs money. This separation is most pronounced in Dow’s absolute arrogance and indifference to their dioxin contaminating our rivers, parks, yards, bodies, wildlife and fish. It’s apparent in Dow’s resistance to submit substantive plans in accordance with their license. It is apparent in Dow’s failure to meet regulatory deadlines and resist cooperating with state.

 

There is nothing voluntary or cooperative about Dow’s activity. Dow has NEVER gone beyond legislative or regulatory compliance with regard to this local contamination. Abroad, in third world countries, Dow continues to market chemical banned in the US. When Dow took up the Responsible Care banner, they made ethics and responsibility an issue…………yet they have failed to demonstrate that they are either. --MHR

  

March 15^th deadline for public comment on Dow RIWP

 

 

Lone Tree is preparing comments on the Dow’s work plans and we will send them out soon. We did ask DEQ for a public Technical Information Meeting ( TIM)  sometime after the deadline to discuss the Notice of Deficiency and how they will be remedied. It is imperative the sampling season and data collection not be delayed because of Dow’s refusal to submit adequate work plans. We remain optimistic that the DEQ will agree to hold a TIM. --MHR

 

 

Think Spring………………………

 

Michelle Hurd Riddick

Lone Tree Council