Tittabawassee
River Watch www.trwnews.net
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Note: the CAP described below is dead and gone. The state has capitulated to Dow and has not held a meeting in over 240 days (as of 1/21/05). The open and transparent process promised by Governor Granholm has evaporated.Citizen Advisory Panel (not official MDEQ page)
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 | 11/15/04 The Department of Environmental Quality regrets to inform you
that the Community Advisory Panel meeting scheduled for 6:30 p.m. on November 17 in
Freeland has been canceled. Dr. Linda S. Birnbaum, the scheduled speaker at the event, is
unfortunately in the hospital and will be unable to travel to Michigan in time for the
meeting. Dr. Birnbaum, Director of the U.S. Environmental Protection Agency's Experimental
Toxicology Division in the National Health and Environmental Effects Research Laboratory,
was to have provided information relating to dioxins and their health effects. The meeting will be rescheduled at a later date. Please contact DEQ Press Secretary Patricia Spitzley at 517-241-7397 for more information. |
| Canceled: 11/17/04 6:30-8:30 p.m. The Department of Environmental Quality announces a Community Advisory Panel meeting that will be open to the general public on November 17 in Freeland. Dr. Linda S. Birnbaum, Director of the U.S. Environmental Protection Agency's Experimental Toxicology Division in the National Health and Environmental Effects Research Laboratory, will be the featured speaker. Her presentation will be on dioxins and their health effects. The meeting will be held at the Freeland High School Auditorium, at 8250 Webster Road, Freeland, from 6:30 p.m. to 8:30 p.m. Please contact DEQ Press Secretary Patricia Spitzley at 517-241-7397 for more information. |
| August 2004 meeting cancelled due to MDEQ workload and behind closed door negotiations with Dow. |
| 05/26/04 4:00 pm - 6:00 pm, Note Time Change. James Twp Hall, 6060 Swan Creek Rd., Saginaw: At the last meeting on March 10, it was expected that the SOW review and approval would be completed in April prior to the DEQ CAP meeting scheduled to be held on May 5. Although DEQ staff have made a great deal of progress on the SOW review, they will not be able to complete the review and the SOW modifications for approval in time to meet with Dow prior to the May 5 DEQ CAP meeting and finalize the approval documents to share with the CAP members. The new date is May 26. |
| 03/10/04 4:30 pm - 7:00 pm, CAP meeting, Saginaw Township Firehall #1, 6171 Shattuck Rd., Saginaw (corner of Shattuck and Lawndale Rds., one mile east of Hospital Rd. and one mile west of Center Rd.). This meeting rescheduled by MDEQ on 1/22/04, had been scheduled for 2/4/04. Future meetings will be held on a bi-monthly basis. MDEQ says rescheduling is necessary due to current Dow related workload. |
| 01/07/04 4:30 pm - 7:00 pm, Green Point Nature Center |
| 12/03/03 4:30 pm - 7:00 pm, Tittabawassee Township Memorial Park Building |
| 10/08/03 4:30 pm - 7:00 pm, Midland's Strosacker Center in Conference Room 110. The address is 220 W. Main Street, Midland (right downtown) |
| 09/03/03 4:30 pm - 7:00 pm, Tittabawassee Township Memorial Park Building |
| 07/31/03 4:00 pm - 6:00 pm, Thomas Township Library, 8207 Shields Drive, Saginaw |
| The Science behind Michigans 90 ppt RDCC
for dioxin
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| EPA to demonstrate new dioxin detection technology at Greepoint Nature Center 4/28/04 | ||||||||||||||||||||||||
| MDEQ T.River/Saginaw River/MIdland Soils Information Bulletin #4 March 2004 | ||||||||||||||||||||||||
| Revised Dow SOW T.River sediment and floodplain 021704 - under MDEQ review | ||||||||||||||||||||||||
| Revised Dow SOW Midland Area Soils 021704 - under MDEQ review | ||||||||||||||||||||||||
| MDEQ grants Dow extension to respond to SOW Notice of deficiency (NOD) 1/26/04 | ||||||||||||||||||||||||
| MDCH Pilot Exposure Investigation Protocl Power Point Presentation 12/1/03 | ||||||||||||||||||||||||
| MDCH PEI protocol: Dioxin exposure in Adults living in the Tittabawassee River Flood Plain 12/1/03 | ||||||||||||||||||||||||
| MDEQ Notice of Deficiency to Dow concerning draft IRA's in T.RIver & Midland SOW's 12/12/03 | ||||||||||||||||||||||||
| Pilot Exposure Investigation participant selection process flowchart 120303 | ||||||||||||||||||||||||
| Pilot Exposure Investigation fact sheet 12/3/03, Page 1 Page 2 | ||||||||||||||||||||||||
| Status of Scope of Work (SOW) Related Reviews 12/3/03 | ||||||||||||||||||||||||
| MDEQ graph of Tittabawassee River flooding 1960 -1999 | ||||||||||||||||||||||||
| MDEQ releases public comment on Dow SOW 10/22/03 | ||||||||||||||||||||||||
| MDEQ approves ow WIld Game IRA scope with stipulations 10/22/03 | ||||||||||||||||||||||||
| Dr. Hector Galbraith MDEQ sponsored Aquatic ERA presentation & FInal Report 10/8/03 | ||||||||||||||||||||||||
| MDEQ Part 201 Rules and Regulations | ||||||||||||||||||||||||
| MDEQ follow-up info to Dow on issues raised in 9/3/03 CAP meeting | ||||||||||||||||||||||||
| CAP 9/3/03 flip chart record of brainstorming session | ||||||||||||||||||||||||
| EPA's response to Dow's 8/12/03 preliminary SOW | ||||||||||||||||||||||||
| MDEQ's response to Dow's 8/12/03 preliminary SOW | ||||||||||||||||||||||||
| Dow's preliminary Scope of Work for Tittabawassee River Flood Plain (08/12/03) | ||||||||||||||||||||||||
| Dow's preliminary Scope of Work for Midland Soils (08/12/03) | ||||||||||||||||||||||||
| MDEQ draft document describing CAP's place in Tri-County Project Coordination Plan (08/03) |
| The Great Divide 09/26/03 Saginaw News |
| Waves of Frustration & valuable public input 09/23/03 Midland Daily News |
| Public offers input on Dow's dioxin 09/04/03 Midland Daily News |
| Dow gets advice on cleanup 09/04/03 Saginaw News |
| Dow Chemical meets with public on dioxins 09/03/03 ABC WJRT-TV |
| Scope of work 08/23/03 Midland Daily News |
| State demands more from Dow 08/20/03 Saginaw News |
| Critics call Dow's dioxin plan a 'stall technique 08/13/03 Saginaw News |
| Dow outlines plans for dixoin in floodplain 08/12/03 Saginaw News |
| Dow submits dioxin study plans 08/12/03 Midland Daily News |
| Dow Chemical Releases Plans For Dioxin Issues 08/12/03 CBS WNEM-TV |
02/1/04 Corporate Science at work: Dow to fund dioxin testing.
On January 30, 2004, Dow published a press
release stating they will provide a grant to the University of Michigan to design a
study to determine the typical blood level of dioxin in residents of Saginaw and Midland
counties.
Dow states the test results will "compliment" the MDCH Pilot Exposure Study by developing " an understanding of whether residents who live along the
Tittabawassee River and in Midland have higher dioxin levels in their blood compared with
a similar group of residents living outside of those areas."
In our opinion, the word "compliment" suggests the Dow study will provide
control group data for the MDEQ PIE study. Unfortunately, this is not true.
The MDCH PIE protocol states:
"Another purpose of this Pilot Exposure Investigation is to test the sampling criteria, questionnaire, and blood and indoor dust sampling methods prior to the implementation of a larger investigation that will include residents from the city of Midland, the flood plain of the Tittabawassee River, Saginaw County, Michigan and a control community with no known exposure to polychlorinated dioxins, furans, and coplanar PCBs beyond background."
The problem is this: non-floodplain residents of Saginaw and Midland Counties may be contaminated as a result of dioxin exposure as well. For decades, Tittabawassee floodplain soils may have been used all over the area for fill dirt and landscaping. In addition, airborne contaminants and fish/wildgame consumption may increase local residents dioxin exposure. Saginaw and Midland counties are not a good choice for a "control community with no know exposure" to dioxins and furans.
Hopefully, the ATSDR and MDCH will review the Dow study protocol and clearly indicate what is or is not "complimenting" the MDCH PIE. Until more is know about the study and it's contractor, Dr. David Garabrant, we remain skeptical of Dow's motives in funding this "study". Why? Click here
8/14/03 MDEQ preliminary review of Dow's SOW - needs lot's of work.
A few excerpts appear below, click here for entire summary.
| The preliminary review identified a number of key issues that must be resolved prior to approval of the SOWs. Many of these issues were discussed by WHMD and Remediation and Redevelopment Division staff at our August 5 meeting with Dow and in the follow-up e-mail on August 7. Our preliminary review included a side-by-side review of the SOWs in comparison to Condition XI.B. of the operating license. This review indicates that Dow did not adequately address all of the applicable elements that are required by the license to be included in the SOWs. |
| Specifically, Condition XI.B.3.(a) of the license requires the SOWs to identify and propose the implementation of specific interim response activities (IRAs) for the protection of public health for the areas identified in Condition XI.B.2. of the license that are known through prior environmental sampling to be impacted by releases from the facility. |
| Your proposal to conduct sampling and an exposure evaluation without controlling potential ongoing exposures is not acceptable as an IRA. As noted in the August 7 e-mail to you on this issue, consideration should be given to offering the residents in this area a range of alternatives to begin reducing the potential for exposure immediately - before the results of an exposure study are available. Sampling and exposure investigation can and should be a part of the IRA for this area, but direct mitigation is also required. |
| In addition, the Tittabawassee River Area SOW should propose to identify any other residential properties in the Tittabawassee River area of concern that are or could be contaminated so that immediate IRAs (sampling and exposure controls) may be implemented, if necessary. |
| The SOWs do not appropriately prioritize work in a schedule based on consideration of potential risks to human health and the environment in accordance with Condition XI.B.3.(b) of the license. |
| It is also not clear why a six-month period is necessary to prepare a current conditions report or why approval of that report is necessary to begin the development of a Remedial Investigation work plan. |
| Condition XI.B.3.(b)(i) of the license requires Dow to identify in the SOWs additional potential exposure pathways that do not have Part 201 of Act 451 generic criteria (e.g., food chain exposures, house dust, etc.). Currently the SOWs state that additional exposure pathways will be identified and evaluated and, therefore, do not address this requirement. |
| Condition XI.B.3.(b)(ii) of the license requires the SOWs to identify the specific areas proposed for investigation and the process proposed for selecting those areas. |
| The SOWs appear to only address dioxins and furans as the "contaminants of concern." It is not appropriate to narrow the SOWs to dioxins and furans at this point. |
| As we have discussed, Dow may begin to implement interim measures to begin reducing exposure immediately, without waiting for MDEQ approval. Timely resolution of these issues is necessary and prudent for the protection of public health and the environment. Meeting prior to the September 3 CAP meeting will afford Dow the opportunity to address the preliminary concerns and provide a meaningful basis for discussion at the September 3 meeting and subsequent public meetings as to how you intend to address concerns already identified. As mentioned previously, we will be meeting with the CAP on September 3 and will be hosting two public meetings later in September to solicit public comment on the SOWs. We have requested Dow participation in these meetings to present your SOWs. To date, we have not received confirmation that Dow intends to present the SOWs. Please let us know so that we can coordinate these efforts. George Bruchmann, Chief Waste & Hazardous Materials Division Michigan Department of Environmental Quality |
8/12/03 Dow releases SOW
Today, At the 11th hour, Dow submitted it's preliminary Scope of Work (SOW) to the MDEQ as mandated in it's new Hazardous Waste Site Operating License and Corrective Action Consent Order. This was not something Dow did on it's own recognizance to serve the public, rather, it was something the State of Michigan forced them to do after a long and drawn out battle. This is not an announcement of a solution to the problem.
Two SOW's where submitted, one for Tittabawassee River and flood plain, the other for soils outside Dow's facility in the Midland area. In summary, their purpose is as follows (links to actual document are at the end of this article):
Dow’s Hazardous Waste Site Operating License ("License"), Condition XI.B.2., issued on June 12, 2002, requires Dow to submit to the Michigan Department of Environmental Quality ("MDEQ") for review and approval a Scope of Work ("SOW") for conducting Remedial Investigation ("RI") of the Midland area soils and the Tittabawassee River Sediments and Floodplain. The SOW outlines the general steps involved in the implementation of a RI, which will be elaborated upon in the RI Workplan that will be submitted to MDEQ for review and approval following approval of the SOW. The License also requires Dow to propose Interim Remedial Activities and a Public Participation Plan along with the SOW. The SOW is intended to be a preliminary outline that provides an overview of the contents of the RI Workplan that Dow will prepare after approval of the SOW by MDEQ. The RI Workplan will be developed by Dow working with the MDEQ after Dow and MDEQ receive public input on the SOW. As it is developed, the RI Workplan may vary from the SOW in its organization, task, prioritization of activities, or other aspects, subject to MDEQ approval.
After a very brief review of the SOW's, a few opinions by TRW (more in-depth analysis will follow):
Some good things:
| Dow admits they are responsible for the dioxin (are we out of the denial stage?) |
| Parks will receive immediate attention to reduce exposure until a permanent solution is found. |
| Those most likely to be contaminated will be focused on first. |
Some bad things:
| Both SOW's state that Dow intends to use "Probabilistic Risk Assessment"
techniques to measure human health risks.
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| SOW's intend to focus on cancer health effects.
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| Dioxin testing: So far the MDEQ has done a lot of dioxin testing with the limited funds available. It can cost over $1200 per sample. Why does Dow want to perform it's own testing? A better solution would be for the MDEQ to continue testing using funds from Dow. Why let the fox into the chicken coop? Check with a lawyer before your let Dow on to your property to perform dioxin testing on your family or property. If you do not have a lawyer or want to talk with one that understands the issues, click here. |
Accompanying the SOW release was the usual Dow PR spin-masters media blitz, consider the source before you believe anything you hear.
| Dow's says emissions have decreased to nearly zero.
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| Dow stated the dioxin pollution occurred back in the early 1900's.
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