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How much dioxin has been found?

How much dioxin is there? "More than has ever been measured at a site in Michigan's history."  Since the initial discovery , various phases of sampling have been mandated by the MDEQ, each round tends to find more than any of the previous studies.  The latest testing in November 2007 reveals levels of 1,600,000 ppt, over 17,000 times the states clean up levels of 90 ppt. 

 

Of special note was the comment made by an Andrew Hogarth (Saginaw News, October 8, 2002), a MDEQ Assistant Division Chief " It was present at every depth we sampled, we didn't stop finding it".

This page contains summaries of the various studies:

bullet1,600,000 ppt found in Saginaw River next to Wickes Park 2007
bulletSoil Sampling Summary 2003
bulletPhase 1 Results 2001
bulletPhase 2 Results 2002
bulletPhase 3 Results 2004 
bulletDow Chemical secret soil testing 2005 
bulletDioxin levels in floodplain residents 2005
bulletMDEQ/GLNPO Study Update February 2006
bullet Dioxin levels of 87,000 ppt found in and around the Tittabawassee River, January 2007 new
bullet Dioxin levels of 100,000 ppt found in and around the Tittabawassee River, February 2007 new
bulletSaginaw River
bulletSaginaw Bay
bulletState of Michigan Dioxin background levels

Phase 1 Results 2001

In 2001 Phase 1, approximately 50 discrete and composite soil samples where taken in 9 areas.  In 2002 Phase 2, approximately 170 soil samples where taken in 12 locations from an estimated 16,000 acre flood plain During Phase 1 &2 of the MDEQ Tittabawassee/Saginaw River Flood Plain Environmental Assessment Initiative.   With a few exceptions, samples where taken from public property.  Does this represent a fair estimate of the extent of contamination?  Are there areas with much higher contamination levels?

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Phase 1 Sample Summary Table

All Phase 1 samples collected near confluence of Tittabawassee & Saginaw Rivers, area just south east of Phase 2 area indicated on map above and 22 miles downstream of the City of Midland (Dow).

Sample Site Name Lowest ppt TEQ found in soil Highest ppt TEQ found in soil
Farm Field 180 424
Golf Course 2529 2588
Forested area, Shiawassee National Wildlife Reserve 35 1055
Upland area, Shiawassee National Wildlife Reserve 58 765
Mitigation Site (22 miles downstream of Midland near confluence of Tittabawassee & Saginaw Rivers 338 7261

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Phase 2 Results 2002

Phase 2 Sample Summary Table (note that all "normal" values where obtained either upstream of Dow or taken from areas outside the rivers floodplain).  The tables below are a quick summary of the findings.  If you want to see all the details and are willing to wait a bit, click here: Summary of Phase 2 Tittabawassee River Flood Plain Sampling

bulletAll dioxin data is presented in parts per trillion (ppt) of total toxic equivalent (TEQ)
bulletSamples where collected from 3 soil layers at each sample location, 0-3 inches, 3-6 inches, and 12-15 inches.  At certain locations, based on property use, a surface soil sample was also collected from 0-1 inch.
bulletPolycholrinated biphenyl (PCB) compounds did not represent a significant contribution to the TEQ at any sample location.
bulletMaps may be found at MDEQ Dioxin Web site, they are pdf and VERY large
bulletNote: secret Dow Chemical studies detected Freeland Festival Park levels

Sample Site Name Abbreviation/Study Map number Lowest ppt TEQ found in soil Highest ppt TEQ found in soil Number samples over 90 ppt vs Total samples
Chippewa River CHW/Map #1/2 miles upstream of Midland 4 11 0/6
Pine River PINE/Map #1/upstream of Midland 3 11 0/6
Tittabawasse Sanford SFD/not on map/upstream of Midland 1 3 0/6
Emerson Park Midland EMP/Map #1/City of Midland 5 100 1/12
Caldwell Boat Launch CBL/Map #2/1 mile downstream of Midland 18 270 6/8
Freeland Festival Park FFP/Map #3/7 miles downstream of Midland 190 3400 12/12

Note: Testing in fall of 2002 indicates contamination goes as deep as 3 FEET

Note: Secret Dow Chemical studies published in March 2005 found levels as high as 8420

Livestock Farm River rd. LIVE/Map #3/9 miles downstream of Midland <1 33 0/18
Imerman Park IMP/Map #4/11.5 miles downstream of Midland 3 2400 32/44
West Michigan Park WMP/Map #5/18 miles downstream of Midland 140 970 12/12
Cropland West Mich Ave CROP/Map #5/20 miles downstream of Midland <1 49 0/15
Former National Plate Glass NPG/Map #5/20 miles downstream of Midland 1 1 0/3
Riverside Boulevard R19/Map #5/22 Miles downstream of Midland 46 1400 9/11
Eggs from Riverside Boulevard R19 egg/Map #5/22 miles downstream of Midland 16 48 0/2
Former National Plate Glass surface water runoff NPG GW/Map #5/22 miles downstream of Midland 0.015 .019 0/2

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Phase 3 Results 2004

Residents participating in the MDEQ Phase 3 dioxin sampling study recently received the "draft" results.  The study was conducted on 22 Saginaw County properties in the Tittabawassee River 100 year floodplain between June and December of 2003.  221 samples where taken.  To review the draft data, continue scrolling down or click here to jump to the official results available in the next section of this page.

The MDEQ has completed the total toxicity equivalent (TEQ) calculations of dioxin, so that the results can be compared to the 90 parts per trillion (ppt) dioxin criteria RDCC generated in   accordance with Part 201, Environmental Remediation, of the Natural Resource and environmental Protection Act, 1994,PA 451, as amended in the Part 201 Administrative Rules.

Of special note: The MDEQ sampling was taken randomly from within a property boundary.  From what we understand of the process, they picked sites that had characteristics suggesting contamination might be present.  However, they also picked sites where they expected to find low or "normal" levels.  This might explain why "only" 40% of samples exceeded 90 ppt TEQ.  Had they focused solely on suspected "hot spots", we suspect the percent of  contaminated samples would have been much higher.

The tables below summarizes the findings.  Tables created by TRW based on draft MDEQ results.
Note: on 2/23/03, the "Analysis by sample depth table" created by TRW reported in error 56 samples taken at the 3" depth.  The correct count is 55, the table has been updated with correct value of 55 samples as of 2/24/04.   The percentage of samples exceeding 90ppt at the 3" depth remains the same: 42% (rounded).

Analysis by sample depth
Sample Depth Total Samples # Samples higher than 90 ppt TEQ Percent exceeding 90 ppt TEQ Lowest TEQ value Highest TEQ value
1 inch 73 27 33% < 5 ppt TEQ 2,640 ppt TEQ
3 inches 55 23 42% < 5 ppt TEQ 2,270 ppt TEQ
6 inches 50 24 48% < 5 ppt TEQ 2,790 ppt TEQ
15 inches 43 14 33% < 5 ppt TEQ 5,660 ppt TEQ
Analysis by Street/Road

Road

Number Residences Tested

% Residences with > 90 ppt TEQ samples

Highest TEQ

Number Samples

# samples > 90 ppt TEQ

% > 90 ppt TEQ

Adams

1

100%

260

3

1

33%

Midland

8

50%

1,570

79

20

25%

Michigan

1

100%

3,140

15

11

73%

River

7

100%

5,660

73

38

52%

Strobel

3

66%

2,640

36

5

14%

St. Andrews

1

100%

1,340

6

4

67%

Wallace

1

100%

1,970

9

9

100%

Total

22

77%

221

88

40%

Analysis by Residence - sample aerial maps>click on address link.   See MDEQ web site for all of them
Street (Saginaw County)
Each row represents one residence/property
Lowest ppt TEQ found in soil Highest ppt TEQ found in soil.  RED indicates > 90 ppt TEQ Number samples over 90 ppt vs Total samples Ratio of Highest TEQ compared to 90 TEQ. 
90 TEQ=1.0
1

Adams #1

10

230

1/3 2.6
2

Michigan #1

10

3140

11/15 34.9
3

Midland Rd. #1

20

70

0/2 0.8
4

Midland Rd. #2

20

590

5/10 6.6
5

Midland Rd. #3

< 5 ppt

< 5 ppt

0/8 0
6

Midland Rd. #4

< 5 ppt

60

0/12 0.7
7

Midland Rd. #5

< 5 ppt

1570

8/14 17.4
8

Midland Rd. #6

< 5 ppt

1130

5/12 12.6
9

Midland Rd. #7

< 5 ppt

420

2/12 4.7
10

Midland Rd. #8

< 5 ppt

30

0/9 0.3
11

River Rd. #1

< 5 ppt

250

1/12 2.8
12

River Rd. #2

< 5 ppt

5660

12/16 62.9
13

River Rd. #3

20

240

3/9 2.7
14

River Rd. #4

< 5 ppt

1110

4/10 12.3
15

River Rd. #5

50

410

6/8 4.6
16

River Rd. #6

< 5 ppt

920

8/13 10.2
17

River Rd. #7

80

1130

4/5 12.6
18

St Andrews #1

< 5 ppt

1340

4/6 14.9
19

Stroebel Rd. #1

< 5 ppt

90

0/16 1.0
20

Stroebel Rd. #2

< 5 ppt

2640

4/13 29.3
21

Stroebel Rd. #3

< 5 ppt

260

1/7 2.9
22

Wallace #1

180

1970

9/9 21.9

An important footnote:  The MDEQ has performed a few random samplings from a few locations on a few properties due to the high cost of sampling.  Over time, flood plain soil  moves around due to floods, wind, erosion, etc..  A dioxin level posted for a residence does not indicate the lowest or the highest contamination that may be on a property, a sample taken a small distance away may be higher or lower.  Unless every square foot of the property is tested every year, we will never know the true extent.

 In TRW's opinion, the random sampling of 22 properties (out of ~2000) suggests the dioxin is everywhere in the flood plain at levels well beyond the States 90 ppt TEQ, including surface levels.  If you live in the 100 year flood plain, assume your property is contaminated, possibly with very high levels.  Take precautions immediately.

The MDEQ graph below summarizes the Dioxin & Furan contamination discovered in Phase 1 & 2 as well as additional data collected from the Saginaw River and Saginaw Bay.  Graph was presented a the MDEQ public meeting at Freeland High School 6/24/03.

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Summary Phase 1-3

Soil Sampling

How much dioxin is there? "More than has ever been measured at a site in Michigan's history." 

Of special note was the comment made by an Andrew Hogarth (Saginaw News, October 8, 2002), a MDEQ Assistant Division Chief " It was present at every depth we sampled, we didn't stop finding it".

Mr. Hogarth's comment was referring to the elevated dioxin levels found during Phase 2 of the Environmental Assessment conducted by the MDEQ.    The Phase 2 sample testing plan include surface measurements as well as a number of depths up to 15 inches.  Highest Levels (3,400 ppt TEQ) where found at the 12-15 inches level.  Highest surface level was 1,500 ppt TEQ.  Both measurements where found in the Freeland Festival Park. 

The sampling in Phase 1 found dioxin levels ranging from 35 ppt to 7,261 ppt, with an average level of 998 pptPhase 2 averaged 799 ppt with a max of 3,400 ppt in soils downstream of Dow and actually in the floodplain.  A floodplain residents yard averaged 529 ppt with a high of 1,400 ppt.  Eggs from freerange chickens on this residents property had dioxin levels of 16 - 48 ppt in each egg!  Phase 3 testing of 22 residences found 77% had levels greater than 90 ppt TEQ, averaging 309 ppt for all samples and depths.  The Phase 3 sample testing plan include surface measurements as well as a number of depths up to 15 inches.  Highest Levels (5,660 ppt TEQ) where found at the 12-15 inches level on River Road.  Highest surface level was 2,640 ppt TEQ on Stroebel Road. A value of 240 ppt TEQ was found at a Midland Road residence back door: Outside the 100 year flood plainSecret testing conducted by Dow in 2004/2005 found levels in Freeland Festival Park as high as 8,920 ppt TEQ and T.River sediments of 19,000 ppt TEQ.

The results of the 2004 Pilot Exposure Investigation found house dust in some peoples homes have dioxin levels as high as 268 ppt TEQ.  This is THREE times the 90 ppt TEQ RDCC the State allows in the dirt OUTSIDE homes.

The MDEQ residential direct contact criteria (RDCC) is 90 ppt TEQ or above.  State of Michigan average dioxin soil concentration is 6.3 TEQ

bullet Click here to view summary of dioxin soil concentrations in Michigan
bullet Click here to view MDEQ Michigan Soil Background Dioxin Data November 1999 (large pdf file)
bullet Click here to view a summary of Dioxin cleanup levels used in other States, most are MUCH lower than Michigan's.

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02/26/04  Official MDEQ Phase 3 results

February 2004 Preliminary Residential Dioxin/Furan Soil Sampling Results of 22 Residential properties in Saginaw County

bulletMDEQ Press Release
bulletMDEQ Residential Property Analytical Results

In addition to the above, the MDEQ has posted aerial maps of all 22 properties on it's web site, www.michigan.gov/tittabawassee .   The maps are very large pdf files, be prepared to wait a while for them to load.

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9/22/03  New dioxin test results indicate contamination lies OUTSIDE the flood plain!

Today, MDEQ released preliminary results of dioxin testing on a Tittabawasse River residents property located in Freeland.  The most frighting result was found literally at their back door.  242 ppt TEQ was measured at the surface.   This is almost 3 times the states maximum level Residential Direct Contact Criteria (RDCC) of 90 ppt TEQ.    THE HOME  IS AT LEAST 20 FEET ABOVE THE FLOOD PLAIN AND A 100 FEET FROM THE WATERS EDGE AT THE CREST OF THE 1986 FLOOD.

This development opens a 'floodgate' of questions and concerns.  How did it get there?  At this point, possible causes are speculative.  However, a former resident of the area states that many years ago, it was common practice to scrape up the flood plain soil and use as  back fill in the property lying above the flood plain to increase the size of a home's building site. 

If true, residents may find their "high ground" safe havens are polluted at levels greater than those found in the flood plain.

In addition, the former resident indicated it was common practice to mine the flood plain dirt and haul to building sites all over Saginaw County and as far away as Clare and Midland Counties.   Until now, people living out of sight of the river thought all of this was someone else's problem.  How many have been unknowingly living in a toxic environment and how many of those have had detrimental health effects because of it?

Another sample taken from the river bank of the Freeland property returned a value of 1,130 ppt TEQ. The area sampled lies directly under the feet of the people attending family gatherings shown on this web sites Picture Page.  A third sample from the flood plain was below 90 ppt, speculation could lead one to believe this depressed area at the base of the hill is actually where the dirt was excavated and hauled up to the house.  In other words, this location was "cleaned-up".    Further details of the testing will be released once the official MDEQ report is released.

The scope of the Dow's SOW currently under development MUST be expanded to include ALL property  adjacent to the Tittabawasse river, regardless of it's "flood plain" status.  The practice of backfilling building sites was probably not unique to this property.  Further more, Dow must take IMMEDIATE ACTION to protect residents identified with contamination within their immediate living space. 

DOW, NO MORE TALK, NO MORE DELAYS, STOP THE SPIN, DO THE RIGHT THING, TAKE ACTION, CLEAN IT UP NOW!

The above testing results where made know to Dow representatives at tonight's public SOW meeting

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Secret testing by Dow Chemical 2005 - see the results below

Excerpt from Detroit Free Press June 3, 2005 article:

"Dow Chemical Co. conducted secret dioxin studies in violation of their operating license, say state and federal regulators -- a blow to trust between the company and officials negotiating Dow's plan to clean up the pollutant.

Government scientists on an April field trip stumbled across a Dow contractor sampling Tittabawassee River sediment, said Greg Rudloff, corrective activities project manager with the federal Environmental Protection Agency. The state Department of Environmental Quality demanded information from Dow, which produced a dozen studies analysts are just starting to review. ...

We were told there was no sampling or analytical data going on, and there was," said Michelle Hurd-Riddick, an outspoken Dow critic from Saginaw. "Now they've given us this data, but you don't know if you have all of it. What if they only gave 75% of it? We just don't know. ...

"We know this company has a habit of selectively presenting data," said Tracey Easthope, director of the environmental health program at the Ecology Center in Ann Arbor. She referred to last summer when the company issued a press release implying its study of dioxin in Tittabawassee valley wildlife showed levels were safe. Weeks later, state health officials using the same data issued an unprecedented warning against eating some game meat. "

bulletThe state demanded the results of the studies, most of which are now posted on the MDEQ web site, click here.
bullet100% of the 16 samples from the Tittabawassee floodplain down stream of the Dow plant have dioxin levels exceeding the States 90 ppt Residential Direct Contact Criteria.
bullet75% of the 16 samples from the Tittabawassee floodplain down stream of the Dow plant have dioxin levels exceeding the ATSDR 1000 ppt  TEQ Action level
bulletA T.River sediment sample measured 19,000 ppt TEQ, click here, see page 12.
bulletA Freeland Festival Park sample of 8,920 ppt TEQ is almost 2.5 time higher than previous samples taken in 2003.  It's 99 times higher than the States 90 ppt TEQ RDCC and 8.9 times higher than the ATSDR action level. This park now has the dubious honor of having the highest level of soil dioxin (that have been released to the public) found in the flood plain since the problem was exposed.
bullet3,867 ppt at Tittabawassee Twp Park
bulletFour samples taken at Imerman Park ranged from 2,157 ppt to 4,230 ppt.
bullet Click here to view MDEQ letter to Dow requesting information after catching them in the act of secret sampling, a direct violation of Dow's Hazardous Waste Management License.
bulletComment from Michelle Hurd Riddick of the Lone Tree Council: These results are consistent with Phase 1, Phase 2, and Phase 3 of sampling done by DEQ over the past three years. The conclusion has not changed. Dioxin is pervasive at high levels the entire length of the river. Dioxin will continue to move and be redistributed along this dynamic mobile river system. As it moves it will continue to be deposited and re-deposited in peoples' yards, homes, public parks and communities. Dioxin will continue to find its way into wildlife, fish and peoples' bodies. It will continue to migrate to the Saginaw River and to Lake Huron.
bulletThe table below is an excerpt from the Dow Study: Ecological Risk Assessment Support Sampling.  Click here to view the entire 136 page report (pdf), the data appears in Table 1 on page 9.

Soil TEQ Results - ERA Support Report,  Dow Chemical Company, Michigan Operations
Sampling Location Location ID  
 
Sample Media Sample Depth (feet) TEQ (ng/kg)
  Plot 1 & 2 are reference areas upstream of the Dow Plant
Plot 1: Reference Site -
Sanford, MI
Gladwin Forest
TRU-02687 Soil 0.0-0.5 1.77
TRU-02688  Soil 0.0-0.5 0.28
TRU-02689 Soil 0.0-0.5 3.57
TRU-02690 Soil 0.0-0.5 0.42
Plot 2: Reference Site -
Chippewa Nature Preserve
CHR-02695 Soil 0.0-0.5 9.26
CHR-02696 Soil 0.0-0.5 13.90
CHR-02697 Soil 0.0-0.5 9.20
CHR-02698 Soil 0.0-0.5 16.98
Plot 3:
Smith's Crossing
(near Bailey Bridge Rd.)
 All samples below this point are downstream of the Dow Plant
MIC-02703 Soil 0.0-0.5 326.89
MIC-02704 Soil 0.0-0.5 3159.40
MIC-02705 Soil 0.0-0.5 2067.16
MIC-02706 Soil 0.0-0.5 451.22
Plot 4:
Tittabawassee Township Park
FRE-02711 Soil 0.0-0.5 1704.41
FRE-02712 Soil 0.0-0.5 1487.74
FRE-02713 Soil 0.0-0.5 3867.11
FRE-02714 Soil 0.0-0.5 1359.28
Plot 5:
Freeland Festival
Park.  Highest levels found in flood plain
FRE-02719 Soil 0.0-0.5 264.53
FRE-02720 Soil 0.0-0.5 8919.82
FRE-02721 Soil 0.0-0.5 164.21
FRE-02722 Soil 0.0-0.5 3141.30
Plot 6:
Imerman Park
THT-02727 Soil 0.0-0.5 4230.73
THT-02728 Soil 0.0-0.5 2157.02
THT-02729 Soil 0.0-0.5 2261.57
THT-02730 Soil 0.0-0.5 4082.15

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02/11/06 Great Lakes National Program Office Study Update: it's everywhere

Note, the height of the red >1000 ppt bars was capped at 5000 ppt for clarity.At the February 9, 2006 Tri-County Dioxin Community Meeting, the DEQ
 presented an update of the GLNPO study which presented a view of
 dioxin sampling activities of the entire Saginaw Bay watershed.  The
presentation made use of Google images superimposed with sampling
data comparing pre and post 2004 data.  Click on the image above to see a slide containing
all of the current data points.

Distribution of Samples
-212 total samples from 116 stations
  Floodplain 115, Shiawassee-22%, Saginaw-68%, Bay-10%
  Sediment 97,     Shiawassee-33%, Saginaw-45%, Bay-22%

PRELIMINARY CONCLUSIONS
1) The Shiawassee River is not a significant contributor of Dioxin/Furans to Saginaw.
2) The Saginaw River Floodplain is not as contaminated as the Tittabawassee River Floodplain.
3) The highest TEQ concentrations, (up to 16,000 ppt TEQ) were found in the Upper Saginaw
     River Sediments (non-navigational).
4) High levels (> 1000 ppt TEQ) were found in the Lower Saginaw River and west portion
    of Saginaw Bay at depth.

NEXT STEPS
1) Report due to EPA-GLNPO -Spring 2006.
2) Incorporate Dow Studies and Agency Data into Google Earth.

Contact info: Allan Taylor taylorab@michigan.gov 1-517-335-4799

Click here to view the entire presentation which is also available at http://www.michigan.gov/deqdioxin

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01/11/07 Horrifying levels of dioxin found in and around the Tittabawassee River

 87,000 ppt  State Cleanup Level is 90 ppt

MDEQ mandated sampling of the Tittabawassee River and it's banks have discovered the highest levels of dioxin soil contamination ever found in a region surrounding a Michigan chemical plant.

"I think the numbers are horrifying," said Terry Miller of the Bay City-based Lone Tree Council, which has been pushing Dow and the state to clean up previously known hotspots, at least.

    "It confirms the need to address these things and address them upstream before they get downstream," he said. "The DEQ has got to stiffen its spine, and Dow's got to do the right thing."
 

DEQ Press Release

FOR IMMEDIATE RELEASE
January 11, 2007

DEQ Contact:  Robert McCann
                        (517) 241-7397

Dow Contact:  John Musser
                       (989) 636-5663


Tittabawassee River Sampling Identifies Areas for Interim Clean-up Action

Recently available results from sampling along and in the upper Tittabawassee River have identified several areas with elevated levels of dioxin and furan that require short term response activities.  The sampling results identified certain eroding river banks with concentrations up to 84,000 parts per trillion (ppt) TEQ, the combined toxicity of dioxins and furans, and certain in-channel deposits with concentrations up to 87,000 ppt TEQ.  The elevated sampling results are located within areas along and in the first six and one-half miles of the Tittabawassee River.

The sampling was taken as part of the ongoing study and investigation being conducted by the Department of Environmental Quality and The Dow Chemical Company.  In general, the chemical profile of the in-channel and eroded bank samples are largely consistent with earlier sampling results from the same general area showing a mixture consisting mainly of furans with a small percentage of dioxins.

Dow has proposed a conceptual approach and schedule for a focused pilot corrective action plan (PCAP) to address these areas.  The details of the PCAP will be developed jointly by DEQ and Dow with measures that will ensure a timely approach that will achieve the greatest protections for human health and minimizes harm to the environment and natural resources.  These initial corrective action activities are scheduled to begin this month and be completed as early as August 2007.

Preparation for implementing the interim actions is underway with Dow developing the final plan and initiating the permit application processes with state and federal agencies for the work to be done in and along the Tittabawassee River.  Dow has committed to working collaboratively and cooperatively with DEQ to further refine, design and implement the plan for addressing these areas as quickly and as safely as possible.

These findings were generated during the implementation of the DEQ-approved sampling plan that was developed and is being implemented by Dow and its contractor, Ann Arbor Technical Services, as part of the remedial investigation of the Tittabawassee River required by DEQ’s hazardous waste management facility operating license, issued to Dow on June 12, 2003.

The public will have an opportunity to ask questions about short and long-term actions that will be developed during the February 8, 2007 Tri-Cities Community Meeting at The Horizons Center in Saginaw Township from 7-9pm.

#####

Public Reaction

 In today's  DEQ Press Release it would appear Dow Chemical and DEQ have agreed that 83,000 ppt is just too high a sediment concentration for dioxin in the Tittabawassee River and therefore Dow will remove it by sometime in August at the latest.
 
 For the first time in the history of this contamination DEQ is going to require removal of contaminated sediments but  it took an alarming number of 83,000 ppt to get any action. Not acceptable!
 
These latest numbers are astounding and far exceed anything to date found in the Tittabawassee River or floodplain. We have repeatedly asked DEQ what's the threshold for dioxin cleanup? What number ( ppt) would require sediment removal from the river? We have yet to get an answer.  Surely it isn't as high as 83,000 ppt! Last we were told, Dow Chemical and DEQ could not agree upon a number. Interesting that the regulator needs the agreement of the polluter in order to settle on  a number protective of public health and natural resources. Just last year in Jeb Bush's Florida a community cleaned up dioxin to a state standard of 30 ppt. In Michigan, however, everything is negotiable with Dow Chemical.........
 
In the past few years DEQ commissioned a number of studies by Galbraith Environmental Services to ascertain the ecological thresholds.  Dr. Galbraith's findings for impairment? 50 ppt ( dioixin/furan) for mammalian populations and 10 ppt to 200ppt for avian species. State residential contract criteria is 90 ppt............Arriving at cleanup number may not be  politically comfortable but it is certainly scientifically defensible.
 
Today's press release states future activities with regard to these high dioxin numbers will include:
"...................measures that will ensure a timely approach that will achieve the greatest protections for human health and minimizes harm to the environment and natural resources". Would have to assume that in an effort to achieve the greatest protections for the inhabitants, DEQ would need an identifiable number to clean up to that they consider protective. What is that number?
 
Dow stated that the 83,000ppt is not a public health threat. Surely DEQ will not hold their breath waiting for Dow to acquiesce to defining a cleanup level.
 
As DEQ oversees Dow's next phase of mapping and sampling it is imperative that DEQ establish the number for cleanup/removal/ interim response along the Tittabawassee River. 
 
Michelle Hurd Riddick
Lone Tree Council

Related stories

 Saginaw News  Midland Daily News  API

 

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02/06/07 New sampling data:   100,000 ppt TEQ dioxin found in T.River

Levels as high as 100,000 TEQ of dioxin (page 303) are noted in a recent Geomorph study document which summarizes dioxin levels in samples collected in and around the first 6 miles of the river down stream of Dow's Midland plant.  The report contains the results of what looks to be over 3,000 samples collected from various depths and sites including wetlands, in channel, floodplain, levees, and river bank terraces. Sample results seem to vary all over the place, ranging from <10 to 100,000 ppt TEQ.  Note numerous samples collected at the surface contain levels ranging up to 30,000 ppt TEQ on the river banks (page 125) which is over 300 times the States RDCC (Residential Direct Contact Criteria) of 90 ppt.

Attachment R, Site Characterization Data Summary Report of Upper Tittabawassee River

Another document seems to be focused on erosion areas.  This report indicates levels as high as 9,700 ppt TEQ found in exposed soil, over 100 times the RDCC

Attachment S, Site Characterization Data Summary Report: Erosion Scar Sampling

We assume the State & Dow will now try to put all of this in perspective for us, the spin machine is ramping up to full speed.

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The Saginaw River

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11/13/07 EPA orders emergency cleanup, 1,600,000 ppt dioxin found next to park

Highest dioxin level found in Saginaw River: EPA, MDEQ and Dow at work on emergency cleanup

Release date: 11/13/2007

Contact Information: Anne Rowan, 312 353-9391, rowan.anne@epa.gov
 

FOR IMMEDIATE RELEASE
07-OPA217

(Chicago, Ill. - Nov. 13, 2007) Acting immediately on information received from Dow Chemical Co. of Midland, Mich., U.S. Environmental Protection Agency, Michigan Department of Environmental Quality and the company have begun preliminary emergency removal activities at a previously unknown dioxin hot spot on the Saginaw River.

Late Friday, Dow notified EPA and MDEQ of preliminary, unvalidated results of over 1.6 million parts per trillion (ppt) of dioxin in one sample of sediment taken from the Saginaw River. This concentration is 50 times higher than a 32,000 ppt level, previously the highest found in the Saginaw River. It is 15 times higher than any dioxin levels found at hot spots in the Tittabawassee River. This new Saginaw River sample came from a location a half mile below the confluence of the Tittabawassee and Shiawassee Rivers, roughly adjacent to Wickes Park in Saginaw.

"EPA has determined that this emergency work should be performed under an EPA Superfund order," said Regional Administrator Mary A. Gade. "EPA and MDEQ are working closely together on a thorough and appropriate plan to remove this hot spot. Moreover, we must be very cautious to make sure, through laboratory tests, that we determine the extent of this high level of contamination. It may be only one additional hot spot or it could cover a larger area."

Dow discovered the latest hot spot during sampling done according to its own Sept. 14, 2007 work plan, which has not been approved by either EPA or MDEQ.

As a result of EPA Superfund orders in June 2007, Dow is now wrapping up the cleanup of three dioxin hot spots in the Tittabawassee River and should be done by year's end. Those dioxin hot spots along the first six miles of the Tittabawassee River were contaminated at levels up to 87,000 ppt, far above state and federal action levels. The area is prone to flooding and erosion which can spread contamination.

Dioxins are highly toxic compounds that pose serious risks to human health and the environment. EPA's reassessment of the most recent scientific findings on dioxin indicates that it is a more potent chemical than previously understood.

For more information about the health impacts of dioxin and eating fish from the Saginaw River system, members of the public may call the Michigan Dept. of Community Health at 800-648-6942 and the Agency for Toxic Substances and Disease Registry at 312-886-0840.

Dow's Midland facility is a 1,900-acre chemical manufacturing plant. Dioxins and furans come from the production of chlorine-based products. Past waste disposal practices, fugitive emissions and incineration at Dow resulted in dioxin and furan contamination both on- and off-site.

In separate legal actions last week, EPA cited Dow for air and hazardous waste violations at its Midland facility. These involve preliminary findings of violations and Dow has 30 days to discuss resolution of the allegations.

Fact sheets on dioxins from Agency for Toxic Substances and Disease Registry (ATSDR) ToxFAQ http://www.atsdr.cdc.gov/tfacts104.html

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bullet Click here for map of 1,600,000 ppt contamination 
bullet Click here for EPA pollution report on the site

Click here for a biased Dow media spin article released earlier today to preempt
 the EPA report.  Local media bought it up hook, line, and sinker.  TV news had
the Dow spinmister John Musser comparing the find to 6 drop in a 55 gallon barrel
and interviews with fishermen lowering their hook almost directly over the contaminated
 area.  Both articles are using the term "Dioxin-Like" (assume it was a sound bite provided
by Dow) in an attempt to downplay the discovery.  Regardless of the "dow-ese" used by
the media, the samples taken near Wickes park revel dioxin in unprecedented levels and it
is the same Dow DIOXIN found throughout the Saginaw Bay watershed.  Suffice it to say
that this is  "sound science" at it's finest.

Dioxin-Like refers to compounds from a group of halogenated aromatic hydrocarbons that
have molecules shaped like TCDD and produce similar toxic effects, such as certain other
chlorinated dibenzo-p-dioxins (CDDs) and certain chlorinated dibenzofurans (CDFs),
polychlorinated biphenyls (PCBs), polybrominated biphenyls (PBBs),
brominated dibenzo-p-dioxins (BDDs), and brominated dibenzofurans (BDFs).

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Freedom of Information Act reveals extremely high levels of dioxin in Saginaw River

bulletACE Saginaw River sediment dioxin testing draft data and additional graphs
bulletSee GLNPO Study update above.
bulletFOR IMMEDIATE RELEASE

December 6, 2004

UPPER SAGINAW RIVER DIOXIN SAMPLING RESULTS RAISE TROUBLING QUESTIONS

High Numbers Prompt Groups to Ask County and Corps to Rethink Dredging Project

Through the Freedom of Information Act, Lone Tree Council and Citizens Against Toxic Substances (CATS) has learned sediment sampling for dioxin in the Upper Saginaw River, conducted by the US Army Corp of Engineers (USACOE), far exceeds any samples identified along the Tittabawassee River. A total of 50 samples revealed concentrations as high as
 11, 812 ppt (TEQ) in the Saginaw River.

Click here for the entire Lone Tree Council Press release

bulletDow Sediment evaluation report-Upper Saginaw River May 2005 (pdf)

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The Saginaw Bay

bulletMDEQ Baseline Chemical Characterization of Saginaw Bay Watershed Sediments 2002 (huge pdf)
bulletSee GLNPO Study update above.

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