Below are Lone Tree Councils comments on EPA’s proposal to allow families to live on 250 ppt of dioxin contaminated soil. The major issues:
The PRGs are not protective of human health and certainly not protective of ecological receptors.
The assumptions regarding the relative bioavailability are not appropriate
At least one assumption is illogical to the point of being arbitrary and not based on any empirical data.
The data that EPA and state agencies have used in setting a 100% availability remain valid and not refuted, hence must be used in setting PRGs.
So the power trio of EPA, MDEQ and Dow are proposing a cleanup number for residential properties along the Tittabawassee River of 250 ppt. If the land is agriculture, farm or non residential the grotesque use of 2,000 ppt will be used.
This is not acceptable and Lone Tree Council has again retained the services of Dr. Peter deFur of Environmental Stewardship Concepts, LLC to sift through the rationale of the power trio.
Terry Miller, Lone Tree Council chairman makes a great point. He suggested if EPA is really concerned about public health, they should defer to a family specific model vs. the agencies catch all site specific model. It is not rocket science to figure out that a middle age couple living on 250 ppt is at a lot less risk than the family with a toddler, infant and or women of child bearing age.
Farm land and acreage not deemed residential use will be have to suffer 2,000 ppt. So for those who want to raise beef, chickens, goats or secure your own milk, eggs or meat… you’re SOL because what the trio agreed to does not make it safe for you to eat what you raise.
Trust me they said, I’m from the EPA. No way! Phone ringing off the wall today from reporters over the latest greatest plan from the EPA to NOT protect public health along the Tittabawassee River. If 250 ppt is good enough for Midland it’s good enough for the down river people too. Stay tuned.
West Michigan Park is a popular kids spot in the summer months. Nestled along the Tittabawassee River in Saginaw Twp, the park continues to be indundaed by the dioxin contaminated flood waters courtesy of Dow Chemical.
Will be posting additional pictures this weekend. We are into the 12th year of this contamination. Additional pictures are also available at www.trwnews.net.
Because if the environment is lost, America will just be a lot of ruined land and a lot of sick people.
Yesterday after decades of delays MDEQ agreed (EPA has been silent) with Dow Chemical and settled on 250 ppt for dioxin in Midland soils. This web site is dedicated to EPA activities along the river system but we cannot ignore the major deviation from the state’s standard of 90 ppt being used in Midland.
Lone Tree Council acknowledges the progress–hell, even talking about remediation in Midland has been taboo for decades. Concerns and comments were submitted to MDEQ in April from the Ecology Center and Lone Tree Council. Skepticism is warranted given the 250 ppt settled on is based on a cancer potency value that is half as protective as the number used at the national level.
In addition, just one day after the announcement of the 250 ppt use for dioxin in soils, EPA released their reference dose for dioxin in soils and the reference dose translates to 50 ppt for non cancer effects. Given EPA active involvement and oversight for decades in Midland, Dow Chemical’s backyard, the agency’s public absence on the 250 ppt did not go unnoticed. More on this in the near future.
Below is EPA’s presentation on dioxin, risk and how the agency arrived at the dioxin reference dose that translates to 50 ppt in soil.
The following link will connect viewers with the March CAG meeting. http://lwvflintarea.org/environmental.html
None of it was edited which will hopefully put to rest the concerns of CAG members who thought the worst when confronted with a public meeting being recorded. See the December CAG meeting at the same link.
Again, it is Lone Tree Council’s pleasure to provide this public service along with Tune Productions and the Flint League of Women Voters.
This week at the Detroit Economic Club, Dow Chemical announced yet another philanthropic partnership, this time with the University of Michigan to develop a sustainability program to the tune of 10 million dollars.
A press release issued by the Ecology Center of Ann Arbor highlights some of the skepticism over this partnership. The details of the program and Dow’s influence and control over it, if any, have not been released. Continue Reading »