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What's being done about the dioxin contamination?

bulletTittabawassee River Cleanup activity  New!
bulletMichigan Republican Dow puppets attempt to hijack the MDEQ to stop enforcement
bulletTwo Paths to resolution
bulletCleanup Methods 
bulletFormer Governor Engler corrupt DEQ administration background
bulletHighlights of Dow/MDEQ / EPA Activity
bulletEPA Activity Details







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Tittabawassee River Cleanup Activity

11/7/08 Riverside Boulevard Cleanup status
bullet The MDEQ meeting 11/7/08 revealed that Riverside Boulevard residents are satisfied with cleanup so far.  This neighborhood is located near the spot where the initial dioxin contamination was revealed to the public back in 2002 after a Lone Tree Council FOIA demonstrated that the former MDEQ administration was covering up the discovery.  View the "Long Shadow" documentary for a close-up of the early days in this saga including interviews with a Riverside resident who regularly consumed contaminated eggs from his free range chickens.
bulletRecent testing evidently confirmed previously reported high levels in the yards, roads, and homes of residents.  In July 2008, the EPA stepped in forced Dow to initiate an immediate cleanup.  River Boulevard is one of the last dirt roads in Saginaw County and provides the only access to the residents homes.  According to the MDEQ, dioxin levels of 10,000 ppt where discovered in the dusty and often muddy road.  The EPA has since paved it as part of the remediation.  This area is prone to repeated flooding, it will be interesting to see how future contamination is handled.
bullet Riverside Neighborhood EPA Pollution Status Report

EU001 is a residential cleanup of dioxin contamination located in Saginaw, Saginaw County, Michigan.  See Polrep 1 for more details.

Set up for the soil removal activities began in August and consisted of: building a staging area for personnel and equipment, road building within staging area and creation of access points through pre-existing berm to staging area, the placement of landscape fabric and stone under crawlspaces and decks to minimize human exposure to contaminants, and creating permanent floors in outdoor sheds.

Removal activities of contaminated soil began on September 2, 2008.  Pre-excavation activities on these properties include moving of outdoor personal property to the staging area and the removal of trees and brush.  During removal activities, crews removed 2 feet of contaminated soil in residential areas and 1 foot of soil from the “transition zones” (non-residential).  After the removal of soil was complete, crews placed landscape fabric as a demarcation layer, backfilled with clean fill and topsoil and prepared the area for landscaping and sod placement.   All removal activities of contaminated soil were completed on October 8, 2008.  

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Highlights of Dow/MDEQ/EPA Activity

Below are a few media articles on the various activities undertaken by Dow , EPA, & the State to address the contamination.  See our Newspaper/Media page for much more.  For a comprehensive list of meetings related to the issues, see our Meetings page.

bulletNo deal yet on dioxin cleanup 1/13/05
bulletDow releases plan to clean up dioxin 1/20/05
bulletDioxin deal done: Dow, DEQ agree 1/20/05
bulletGood news? Too soon to tell  1/20/05
bulletDioxin plan details given 1/21/05
bulletEnvironmentalists skeptical, public officials encouraged 1/21/05
bulletEnvironmentalists upset with DEQ-Dow pact 1/25/05
bulletDow to argue for reduced cleanup 1/27/05
bulletDioxin Cleanup 1/29/05
bulletResidents will have options to limit dioxin exposure 1/30/05
bulletDioxin deal still needs some meat on its bones 2/8/05
bulletDow to notify property owners of cleanup plans, meetings 2/24/05
bulletDow talks to residents at properties with high dioxin levels 2/25/05
bulletCleanup called 'Band-Aid' 3/3/05
bulletDow meetings offer answers 3/3/5
bulletDow, DEQ goal: Communicate openly 4/7/05
bulletDow meeting features incident with TV-5 reporter 4/7/05
bulletDow pays for Freeland park upgrades 4/13/05
bulletInterim dioxin cleanup under way 5/8/05
bulletHydraulic dredge is doubtful here  6/23/05
bulletEPA talks about Fox River dredging project 6/23/05
bulletMany refusing dioxin cleanup 7/3/05
bulletResidents' dioxin levels higher near Dow, study shows  7/14/05
bulletDEQ tries to clarify polluted property criteria 7/20/05
bulletResearcher: Dioxin risk exists 8/4/05
bulletPollution cleanup bill getting messy  8/9/05
bulletPollutants leave scared landscape 8/14/05
bulletDow to post fish and soil advisories along Saginaw and Tittabawassee rivers 8/20/05
bulletCommunication plan might change 8/26/05
bulletPark design goes deep 9/6/05
bulletState warns of high dioxin levels in some Tittabawassee River Fish 9/8/05
bulletNew warning signs at local launch 11/10/05

October 2005 New warning signs posted in West Michigan and Imerman Parks

bullet Little new information at session 11/11/05
bulletDow fined for conducting unreported dioxin tests 01/06/06
bullet DEQ: More dioxins moving towards Bay City 02/10/06
bullet Dow still collecting information on dioxin 02/10/06
bullet DEQ Goal: Protect public and environment 02/19/06
bullet Dow expected to enter round 2 of cleanup 02/19/06
bullet EPA raps dioxin plan 02/22/06
bulletDEQ agrees with EPA dioxin plan concerns 02/24/06
bullet MDEQ: Dow has 2 months to resubmit dioxin plans 03/03/06
bullet Eating fish from river not healthy , DEQ says 03/10/06
bullet State announces 2004 emissions report, data includes increase for Dow 05/01/06
bullet Paralysis by Analysis: Dow wants to delay cleanup until the year 2017
bulletCommunity Meeting June 2006
bullet Michigan Department of Community Health will be hosting activities for the public to answer questions about safe fishing, fish consumption and the fish advisories on our local rivers and Bay. July 2006
bullet DEQ: Tittabawassee River Sampling Identifies Areas for Interim Clean-up Action 1/11/2007
bullet Final GeoMorph Upper Tittabawassee River dioxin tearc2007_1sting report available  2/11/07
bullet DEQ announces spot cleanup of Tittabawassee River 5/6/07
bulletDEQ announces Dow to begin cleanup work in Tittabawassee River 7/7/07
bulletEPA memo says river highly contaminated with chemicals other than dioxin 7/11/07
bullet DEQ responds to EPA criticism of Dow's RIWP 7/12/07
bulletMDCH releases  "Fish Consumption Survey of People Fishing and Harvesting Fish from the Saginaw Bay Watershed' Report
bulletEPA demands Midland dioxin sampling data 8/31/07
bulletFirst dioxin-contaminated soil removed from the Tittabawassee 9/9/07
bulletEPA pulls out of Dow/MDEQ mediation process 9/12/07
bulletEPA gives Dow 60 days to negotiate cleanup settlement of Rivers an Bay 10/10/07
bulletMDCH releases final Pilot Exposure report 11/5/07
bulletEPA notifies Dow of Clean Air and Hazardous Waste violations 11/9/07
bulletEPA orders emergency cleanup of 1,600,000 ppt hotspot found in Saginaw River 11/13/07
bulletEPA responds to Dow spokesman down playing of dioxin dangers 11/14/07
bulletMDCH issues fish consumption advisory for Saginaw River 11/15/07
bulletEPA and Dow sign consent order to begin emergency cleanup of dioxin hotspot 11/16/07

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 Dow "Legislators" repeatedly attempt to hijack states regulatory system.

A group of Michigan Republican Lawmakers from Midland & Saginaw (Stamas , Moolenaar, Goschka) have repeatedly filed bills in the Michigan Legislature to raise the States dioxin Residential Direct Contact Criteria (RDCC) to over 11 times the current standard, from 90 ppt to 1000 ppt.  In our opinion, this is a attempt to relieve Dow Chemical of it's clean up responsibilities under it's current operating license.    These individuals have shown their true colors: their allegiance to Dow Chemical company overrides their concern for public safety in City of Midland,   Tittabawassee River flood plain, the State of Michigan, and the United States of America.  A poll found 90%  of Michigan voters support a comprehensive policy to phase out persistent toxic chemicals (like dioxin).  Yet these "representatives" advance the cause of Dow over their citizens.  If passed, these bills may set a precedent that could affect dioxin standards across the entire United States.  Now is the time for concerned citizens from around the country to get involved in this debacle unless you want Dow Chemical interfering in your backyard. 

bullet  Attempts to highjack State Regulatory System
bullet2006: Dow hacks try again with three new bills
bullet2005: Dow hacks introduce bills HB4617 and SB390, Governor vetoes
bullet2004: House Appropriations Sub-Committee – Votes to Slash DEQ Budget & Eliminate Entire Programs
bullet2002:  MDEQ attempts change states dioxin RDCC
bulletClick here for all the details

Currently, two paths to resolution of the contamination are being followed:

bulletRegulatory System as of 1/1/03  (for what happened before this date, click here)
bulletMDEQ / EPA regulatory approach:
bulletCreate and implement Dow Corrective Action as required by their Hazardous Waste Facility Operating License. issued  June 2003
bulletDow to create a Scope of Work (SOW) to define work plan on how they will address issues mandated in Operating License.
bulletMDEQ and area stake holders (Tri County Project Coordination Plan) attempt to work with Dow to create a credible SOW which includes remediation plans.  See Community Advisory Panel (CAP) page for details
bulletSo far, Dow is attempting to do as little as possible with the SOW.  Other than for putting a few hand washing stations in parks, remediation is not being addressed.   They are not responding to the immediate needs of those with known contamination nor are they implementing a method to break exposure pathways.  Dow's' plan of attack seems to be delay, delay, delay with more testing, testing, testing.  Citizens at CAP are saying CLEAN IT UP NOW! and take immediate steps to reduce/eliminate exposure pathways in known contaminated areas until a final solution is implemented.   Health Studies are NOT required before cleanup begins!
bulletThe MDEQ , EPA (Page 1 2 3 4), and CAP are finding many issues with the initial Dow SOW.  Dow understands what was required of them for this SOW, they choose to water it down and avoid any of the real issues.     
bulletUnless regulatory agencies take a strong position, we will still be talking & testing years from now. 
bulletLegal System:
bulletThe discovery of dioxin contamination was not made know to the public until January 2002 when the Lone Tree Council filed a Freedom of Information Act as the result of  whistle blowers in the States Government.
bulletFor the next 12 months, victims of the contamination where caught up in a corrupt & illegal political process where Dow and the  Engler administration tried to work behind closed doors to create and ram through regulations that would relieve Dow of any responsibility and raise Residential Human Contact Criteria levels from 90 ppt to 851 ppt. 
bulletDecember 27, 2002. illegal activities stopped in the 11th hour of the Engler administration by concerned citizens.
bulletJanuary 1/1/03, Governor Engler and his administration where shown the door when Michigan voters elected Jennifer Granholm as Governor.
bulletThe Dow "administration" did not change, residents expect more of the same from Dow.  
bulletBased on the prior years illegal activities & cover-up's,  Dow's worldwide history of avoiding responsibility,  and lack of visible action from the new   administration, contaminated residents hire lawyers and sue the Dow Chemical Company.
bulletSuit filed March of 2003 seeking damages for loss property values and future health monitoring, both issues that seemed to ignored by the regulatory approach.
bulletThe Health Monitoring aspect of the suit is basically a "Health Study" that is not under the control or influence of Dow Chemical.
bulletAs of February 2003,  over 300 residents have signed on prior to being certified as a Class Action (certification expected in February 2004).
bulletOnce certified, potential plaintiff's will expand to over 2000.
bulletIf not certified as a class action, our lawyers will sue all 300 as individual cases.
bulletFor details of the Law Suit and all the latest activities, click here

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Past, current,  and possible future cleanup methods


Can all the dioxin be cleaned up?

Many have asked this question and not one official at any of the public meetings (Dow, MDEQ, ATSDR, or EPA) could provide an concrete answer.   Current cleanup activity is limited to a few "hot spots", no one has yet to propose clean up methods for the rest of the 44 miles of Tittabawassee  river banks, 16,000 acres Tittabawassee floodplain soil, Saginaw River, and the Saginaw Bay.

Cleanup methods mentioned by public officials (in no particular order):

bulletBurial with clean soil -  silly idea, might work until next flooding when
contaminated river sediment is spread over the formerly clean topsoil. 
How many dump trucks would it take to cover 16,000 acres?  What about
all the trees, how do you cover the dirt they grow in without killing them.
bulletDredging - dredge the entire river of sediment to prevent it from be
re-deposited on land during flooding.  Use some sort of mesh/filter to
prevent disrupted contaminated sediment
from flushing out to sea.  Where
has this been done and did it work? 
Can we ship all of the spoils to Midland
where they think this stuff is safe?

            As of May 3, 2007, Hydraulic dredging is being proposed for a spot clean up of the Tittabawassee just south of the Dow Plant.  Click here for an overview of the process as it was performed on the Hudson River, NY.   


As of July 2007, Hydraulic dredging is being used to clean up 3 sediment hotspots in the Tittabawassee River and flood plain soils are being excavated and trucked to Midland Dow's Salzburg dump.






bulletHeating -  Thermal Desorption: heat soil to a high temperature to drive
thermdesorp.jpg (7844 bytes)off contaminants.  All 16,000 acres?  Are you willing to watch all the plants
and trees die as the soil is treated. This process may or may not work,
depends upon many technical factors and probably is not appropriate for such
a large scale contamination. A report, Overview of Thermal Desorption Technology
by the Naval Facilities Engineering Service Center describes the various processes available.  Costs estimates range from $35 - $250 per ton of treated soil. How many tons of soil are found in 16,000 acres and how long would it take to roll off the little  conveyor belt ?

In February 2008, the MDEQ announced it conducted  a "Thermal Desorption" trial in 2007

bulletPhase Separation Solutions 
bulletTrial on Tittabawassee removed 99.8% of dioxins and furans
bullet Process uses a low temperature thermal desorption process where soils are removed and fed into a portable "extraction chamber" located on or near the treatment area.
bulletProcess requires soils to be temporarily removed and fed into chamber.  After treatment they can be returned to original location.
bullet8+ projects worldwide including potential residential areas near the Sydney Australia 2000 Olympics site
bulletIn February 2008, the MDEQ announced it conducted a biological trial in 2007
bulletBiotech Restorations
bulletTrial on Tittabawassee removed 45% of dioxin and furans in 4 months
bulletCompany thinks they can improve the performance with further enhancement of the process. Other sites treated have seen > 96% removal rates.
bullet Process using existing bacteria in soil to breakdown the contaminants into inert substances.
bulletProcess treats the soil in place, however it needs to be plowed and watered
bullet39 other projects around the world
bulletSolidification - EPA has proposed solidification at some sites, a process in which contaminated soil is mixed with cement-like material. The sludge eventually hardens
and is left on-site.   Everyone who wants a volcanic moonscape for your back yard should vote for this one.
bulletIncineration - The use of incineration as a remedy is perpetuated by an industry and government bias against innovative non-incineration technologies. This bias can be seen in engineering curricula, regulatory training, and research which focus on building better burners and landfills. Communities are often frustrated by the lack of alternatives to incineration. As it now stands, companies have no incentive to develop non-incineration technologies and EPA has no mandate to certify alternatives for use in the field.
bulletNatural attenuation - Another disturbing trend is leaving the contamination in place and relying on "natural attenuation" to take care of the problem. Natural attenuation essentially means performing no further treatment and waiting for dilution, dispersion, evaporation, and eventually degradation to deal with the contamination. - Nothing is being "attenuated" in the Tittabawassee or Saginaw River as indicated by the high levels being found
bulletRelocation & Fences - Sad, but this is probably the leading cleanup "technology" for the
16,000 acre Tittabawassee flood plain dioxin contamination.

Other disturbing trends

The Center For Health, Environment and Justice article:

Back to Where We Started:  Trends in Cleaning up Contaminated Sites   summarizes the following:

In summary, there is less on-site treatment of the source of the contamination, more frequent use of on-site containment, primarily clay caps, and more frequent selection of natural attenuation to address both on-site soil and groundwater contamination happening at Superfund sites. These decisions result in less cleanup at these sites and less protection of the environment and public health of surrounding communities and those of neighboring areas where "naturally attenuated" contamination could spread. By leaving more contamination in communities for longer periods of time, EPA is letting industry off the hook for the true costs of cleaning up these sites. And at the same time, the people living in the areas impacted by these sites continue to face health risks that could be reduced, if not eliminated, with proper cleanup.

These trends represent a failure of the Superfund program to fulfill its mission of cleaning up contaminated sites. Instead of giving companies responsible for the pollution a free hand to decide how to clean up a site, the people directly affected by these sites need to be able to decide how much cleanup is needed. These companies should be held accountable for what they did to the sites and to the people who live there. It is clear, however, from this picture of trends in cleanup remedies that we cannot rely on EPA to do this. We must do it ourselves with stronger local organizing and coordinated national efforts. We must work together to force EPA to be the agency we want it to be and to replace the agency that it has become, one that protects industry instead of the public.

Note: on January 1, 2003, Jennifer Granholm replaced John Engler as governor of Michigan. 
Many of the political appointees that drove the campaign to cover-up the dioxin contamination
left with Engler.  It's to early to tell if the new administration will take the citizens side in these
matters, however, recent news out of the  MDEQ indicate a change may be coming.  We will wait and see...

The content of this site referring to all of the deceit and collusion  between Dow and the MDEQ will remain for a  historical perspective. Future developments will hopefully be in stark contrast to the past.


MDEQ is pushing a Corrective Action Consent Order considered by AG to be illegal

The contents of the CACO will raise acceptable dioxin levels from 90 ppt TEQ to 831 ppt TEQ.  90 ppt TEQ is the current MDEQ limit for residential contact in the rest of Michigan.  Michigan's attorney general office commented that draft versions of this document where illegal.  Is the proposed version any better?  We better find out before 12/10/02 when the order could be signed the the departing MDEQ officials of the Engler administration.


Anything else?

  Not much other than talk and illegal backroom negotiations to relieve Dow of responsibility

Dow or MDEQ have no plans to start a cleanup, they intend for the citizens of the Tittabawassee flood plain to stew in this toxic mess until they can relieve Dow of responsibility for the cleanup.  The only existing DEQ Part 201 cleanup standard for dioxin in residential soils is 90 parts per trillion (ppt).    We have measured values of over 7000 ppt. Why are they ignoring this?   Because they need time to get the illegal version of the CACO approved before Engler leaves office.

Dow and MDEQ are trying to raise cleanup standards from 90 parts per trillion TEQ to over 831parts per trillion TEQ.  Why?   Because it gets Dow off the hook to clean it up. Many of the contaminated areas are in the range of 100-830 ppt.  Funny thing happened back in February 2002, the MDEQ tried to raise the limit from 90 ppt to 150 ppt.  Public outcry stopped them.  Once they completed the Phase 2 study, the new "scientific" cleanup level promoted by Dow was 1000+ ppt.  Now it's 831 ppt based on the most recent draft of the CACO.  There is no legal or scientific basis to do this and Michigan's Attorney General has told them to STOP trying to get this CACO approved.  However, they are still trying to do so before Engler leaves office.  Below is an internal email leaked to the public.  Outrageous

NOTE: The CACO was defeated in December 2002 because of the actions of concerned citizens.

    Michigan Attorney General office email to Art Nash of MDEQ

Dow & MDEQ are trying to divert attention away from a cleanup by proposing Health Study to be funded by Dow.  A Health Study is NOT required before a cleanup begins.  

The next time you hear about a Health Study being proposed by ANYONE, read this editorial and then read the proposal again. There are many design criteria which can included that make the studies outcome inconclusive before it even starts.

Dow & MDEQ are trying to push through an illegal CACO which will relieve Dow of any responsibility for the contamination.  Michigan's Attorney General office has reviewed the document and deemed it ILLEGAL and to STOP trying to get it passed.  NOTE: The CACO was defeated in December 2002 because of the actions of concerned citizens.

                    Attorney General letter to MDEQ telling them to STOP illegal activities

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