Adminstrator Jackson: We are still waiting
Dear Administrator Jackson,
On behalf of the Lone Tree Council I would like to thank you for the EPA’s many efforts to address the myriad of issues associated with dioxin and its impacts on human health and quality of life. We understand that responding to the NAS, development of interim PRG’s and the cumbersome process of finalizing the Dioxin Reassessment are a monumental task. Those of us living in Dow Chemical’s horrific dioxin contamination here the Saginaw Bay Watershed of Michigan are hopeful the EPA remains steadfast in its resolve to address this pressing issue.
We have stated publicly, in press releases and in communications to your agency, that absent a final number for dioxin in soils our community will be left to struggle for a cleanup. Our communities become fatalities of Dow Chemical’s PR and spin about dioxin. The company continues to manufacture uncertainty about the toxicity of dioxin and persists in their campaign to convince the community that no one is in harm’s way. Residents are held hostage by decades of contamination and delays. Our communities, homes, wildlife and rivers become pawns in a political game that Dow is most deft at applying and playing to the detriment of public health and an already overdue cleanup. Dow Chemical will continue to do this because a clear, scientifically sound number for dioxin in soils has yet to be established authoritatively by the EPA.
Permit me to share an example with you. In 2005 it was decided in closed-door meetings between Dow Chemical and the state of Michigan that EPA’s outdated number of 1,000 ppt for dioxin in soil would be utilized while evaluating homes along the Tittabawassee River. To the best of my knowledge this number is still being used. Not only is this number scientifically indefensible but the decision to use the 90 ppt ignored EPA’s 1998 OSWER directive for dioxin in soils which said that on state led RCRA sites, soil criteria numbers established by the state would be recognized by EPA. At the time, this site was a state led RCRA corrective action. Not only was the state’s use of 90 ppt relevant under OSWER, but the number was and is much more scientifically current and defensible than EPA’s 1000 ppt. Local use of the outdated 1,000 ppt is illustrative of the inherent problems absent a current established number from EPA. Secondly, absent a current number, Dow was able to supplant the state’s 90 ppt for EPA’s old, less protective number of 1000 ppt because the latter was still on the books. No doubt the decision was political but had a different number, a more current number been in place, Dow Chemical would have been without this option.
The EPA’s next steps are of great interest to us. Along with many other organizations we have been watching and are concerned with the industry push back and efforts to further delay progress on this issue. The EPA’s failure to meet the June deadline for the final PRG’s is unsettling. Our fear is it does not bode well for communities such as ours. In June of 2009 EPA’s Mr. Stanislaus stated during a public meeting that Dow’s dioxin contamination was a public health threat. We appreciated that acknowledgment and remain hopeful that EPA will make this public health protection the driver in upcoming decisions. We would be most interested in knowing if a new timeline has been established for release of the PRG and how it will impact your commitment to our community to release the dioxin reassessment.
Regards,
Michelle Hurd Riddick
Lone Tree Council
989-799-3313
cell 989-327-0854
michdave@aol.com
www.cleanwatershedcampaign.org
Cc Terry Miller, Lone Tree Council
Tracey Easthope, Ecology Center
