Clean Watershed Campaign

Dear Administrator Jackson

Lone Tree Council joining a chorus of environmental and public health advocates calling on Administrator Jackson to finally release the EPA’s long delayed dioxin reassessment.

Jan. 2012 EPA Jackson dioxin reassessment.

Lone Tree videotaping the CAG meetings

Since EPA’s take over of Dow’s contamination along the rivers, public participation and attendance at meetings has hit an all time low. The CAG has had its fits and starts and is still grappling with the science and charge before them. Few attend the CAG meetings.

Last month Lone Tree Council began videotaping the CAG meetings and the League of Women Voters of Flint are giving us space on their site to make the meetings available to the public. The first is the December 12th 2001 meeting of the EPA’s Community Advisory Group.

Its been and will remain an exasperating ordeal to garner a good cleanup but to that end, public scrutiny is important.

Practice collides with rhetoric

Ringing in the New Year, EPA announced this past week that Dow Chemical is second among toxic chemical emitters.

And then there’s the rhetoric.

Sustainability begins at home, but its destiny is to engage the problems of the world. We will build on our company’s rich legacy of leadership in solving the world’s most pressing problems with a spirit of fearless accountability, not just for our own footprint on the planet, but the collective footprint we make as part of the human family. —Andrew Liveris, CEO Dow Corporation

26 days and counting

Back in September, Lisa Jackson’s EPA, after missing a previous deadline to release the dioxin reassessment, said the agency would divide its long-awaited final dioxin reassessment into two parts: cancer and non-cancer endpoints with plans to release the non-cancer numbers for dioxin in soil by the end of this month, January 2012.

Applying a tried and true decades old tactic, it should come as no surprise that Dow’s lobbyists at the American Chemistry Council are once again calling on EPA to delay the release of the non cancer numbers past the end of this month, insisting on more information and investigation by EPA in light of a new appropriations bill passed in December.

Administration after administration for decades has promised the release of this much needed guidance. Each and every time they have caved, placing corporate and monied interests above public health.

High hopes for 2012?

You can follow the recent development at this Center for Health, Environment & Justice (CHEJ) link.

EPA Settles on Plan for Segment 1

November 2011

EPA and Dow Chemical Co. signed a legal agreement on November 2, 2011 requiring Dow to clean up sediment in Segment 1, a three-mile stretch of the Tittabawassee River next to Dow’s Midland Plant. There are six Sediment Management Areas or SMAs identified within Segment 1 where chemical pollutants are targeted for cleanup. Most of the pollution in Segment 1 is from chlorobenzenes and other chemicals rather than dioxin. A form of the contamination, dense non-aqueous phase liquid (DNAPL), a heavy liquid made up of materials that do not mix with water and sinks to the bottom of the river, is targeted for cleanup in three of the SMAs. EPA selected its plan after carefully considering public comments.

MDEQ also declining to use Dow funded UM Dioxin Study

For the first time an agency stated in plain language their rationale for declining the use of a study funded by Dow Chemical. Below is MDEQ’s written and succinct comments to the EPA’s Community Advisory Group (CAG) who invited Dr Garabrant to speak to them about the findings in his Dow funded study.

DEQstatementfor10-17-2011CAG

EPA will not use Dow funded UM Dioxin Study

As reported by the Saginaw News, EPA and MDEQ are again declining to use the Dow Chemical funded U of M Dioxin Exposure Study for protection of public health and response activities along the river.

Good for EPA and MDEQ. While acknowledging the study has some valuable information, the agencies remain firm in the belief that the study as limitations.

Dr. Garabrant, the lead researcher said it was ‘logical nonsense’ that EPA declined to use the Dow funded study. No sir it is not. Read more »

Where is the outrage?

Here is an outrageous video of contaminated sediments being pumped into the Army Corp of Engineers/Saginaw County dredge site. Currently, there is no coordination on this site among the agencies who have all expressed concern about the site integrity, wildlife contamination, lack of permits or long term implications of this dump site.

Dow Chemical is (should be?) responsible, cradle to grave, for their dioxin contamination. However, EPA has made an exception in this case to take a hands off position for the time being on Dow’s responsibility and obligations on the Saginaw River and to people that live and play on and in it. A delay is always a win for Dow and their shareholders, yet is once again a loss for the people that live in their spoils.

Region V taking their sweet time

In an e-mail the end of June, EPA Region V said recent sampling showed sediments migrating toward Lake Huron were not highly contaminated. Lone Tree Council has requested the data twice and have yet to receive the information even though EPA’s Superfund Director said it would be forthcoming in two weeks (August 5th e-mail)

EPA responded to our second request for the data with a detailed account of EPA activities in the region since 2007 - but no data or acknowledgment that we even asked for the data.

We hold EPA to its word and again today sent an e-mail requesting for the third time the data referenced in their June 26th e-mail to Lone Tree Council.

There is a hesitation on the part of Superfund to require sediment traps to stop the migration of Dow’s dioxin to Lake Huron. Not sure if it’s based in science or the omnipresent politics which has engulfed this contamination for decades.

EPA to Lone Tree Council 6-26

Cleanup near the Dow Plant Site

EPA will be accepting public comment on a number of alternatives for several areas desperately in need of cleanup near the Dow Chemical plant site. Unlike most of the river system the chemical drivers are not dioxins and furans but a whole host of other toxins like arsenic, ethyl parathion, chlorobenzenes and PAH’s (polycyclic aromatic hydrocarbons) to name a few.

Presenting the biggest challenge for cleanup is a toxic DNAPL (a ‘dense non-aqueous phase liquid’: a thick gooey, heavier than water concoction that sinks below the water level) found in the river. A number of questions and concerns prevail around the DNAPL issue. It appears there is no definitive answer as to how the DNAPL arrived in the river or how much is there, plus the ability of a DNAPL to migrate makes it difficult to locate and remove.

EPA and MDEQ are advocating Alternative 2.