Clean Watershed Campaign

LTC Preliminary Comments Public Meeting

AOC CERCLA DOCKET No. V-W-10-C-942

January 19^th 2011

Comments of the Lone Tree Council

Good Evening. My name is Michelle Hurd Riddick I’m with the Bay City based Lone Tree Council. We appreciate the opportunity to comment tonight on Dow Chemical’s Task 1.4 Engineering Evaluation for Early Response Actions to Address Potential Acute or Near Term Exposure Risks.

Residents and interested parties are often at a disadvantage to understand technical documents so EPA efforts tonight to explain them in more detail are much appreciated. 

Tonight I would like to make a few comments and only a few suggestions. Last week, after meeting with Tittabawassee River residents, Lone Tree Council again retained the services of Dr. Peter deFur to assist us in navigating and commenting in detail on the technical aspects of this document. Our additional comments are forthcoming.

It would be comical if not such serious business that these activities are called Early Response Actions. This contamination is decade’s old. Dow Chemical is rewriting a plan and embarking on a project that they first undertook in January of 2005.— but never completed. There is nothing early about these response activities. They are late if anything and long overdue. I think it is safe to say that Dow did not make a best effort 6 years ago—had they done so, had the company kept their many commitments both verbal and contractual we would be light years ahead of the game. We are looking for assurances and strong enforcement language from EPA that this will be the last time these particular interim response actions will be resurrected and re-introduced as some new plan to the community. Read more »

Another effort at avoiding exposure

This past week, Region V EPA announced a 30-day public comment period on Interim Action Plans to limit human exposure to dioxins in parks and residences along the Tittabawassee River. These interim actions are in the form of work plans submitted by Dow Chemical commensurate with their obligations under the Administrative Order on Consent signed with EPA in January of 2010.

We agree that limiting human exposure to Dow’s dioxin is of paramount importance especially for families with children and for women of childbearing age…… Unfortunately EPA has denied relocation as an interim response or final remedy.

Not to be critical of efforts to mitigate exposures but it is exactly 6 years since this was originally designed and submitted by Dow during 8 months of closed door negotiations with MDEQ. Read more »

Times Square ball not the only one dropped in 2011

In a May 2009 letter to the community, via her emissaries at public meetings and in a phone conversation with Lone Tree Council and the Ecology Center, EPA administrator, Lisa Jackson, committed to an expeditious cleanup and stated she would make protection of public health her top priority.

To that end, EPA was committed to establishing an interim number for dioxin in soil pending the release of the dioxin reassessment, which she assured us, would be released by December 31 2010.

Happy New Year and welcome to 2011. Reporting on the failure of the EPA to meet the goals or deadlines laid out in May of 2009, Michigan Messenger is reports the EPA has removed Lisa Jackson May 2009 letter to the community. We are happy to post it here for you.

EPA’s failure to assign a number will continue to hold river residents captive to the arcane science of the 1980’s….playing into Dow’s hands. There can be no serious commitment to public health protection so long as the EPA allows Dow Chemical, their lobbyists including the Chamber of Commerce, the Chemical Industry and glad- handing legislators to throw up roadblocks. EPA needs to make a decision. The dioxin reassessment is 28 years old. So long as industry breathes they will continue to demand answers to create the delays they have always received.
President Obama, Administrator Jackson give us a number that protects the public health of residents in Mid-Michigan. No more delays. Please. No more delays.
Michigan Messenger article: EPA misses dioxin deadlines | Michigan Messenger