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E-M:/ Dow Chemicals Scope of Work

                                     Lone Tree Council

P.O. 1251, Bay City, Michigan 48706

(Fighting for environmental justice since 1978)

For Immediate Release                              

Contact: Michelle Hurd Riddick 989-799-3313

Terry Miller 989-686-6386

Tuesday September 9, 2003                                     



Dow Chemical Scope of Work Woefully Inadequate

                              Activists and Citizens Propose More Aggressive Cleanup


Gathered in Immerman Park, one of the most contaminated parks in Saginaw County, environmental activists and citizens criticized Dow Chemical Company’s recent response to dioxin contamination in the Tittabawassee River, and proposed actions they said would be more protective of human health.


The activists noted that the Scope of Work (SOW) Plan submitted by Dow Chemical to  address its dioxin contamination of the Tittabawassee River Floodplain was delaying clean-up by continuing calls for more sampling and ignoring the immediate exposure of people in the floodplain.  


“The SOW  not only fails to address the immediate pathways of exposure but delays, the necessary cleanup,” said Lone Tree Council’s Michelle Hurd-Riddick.  “Dow should be doing a range of things from relocating families in heavily contaminated areas to dredging  to shore stabilization.”


Lone Tree Council, the Saginaw Bay Watershed  environmental group that disclosed the contamination in the Tittabawassee River after a Freedom of Information Act request, is calling on Dow Chemical of Midland Michigan to drop its pursuit of more testing and take six immediate steps to protect public health down stream in the Tittabawassee River floodplain.


“For decades, Dow has been able to stall cleanup in Midland by influence peddling and by calling for more studies. This cannot be permitted to happen here on the Tittabawassee River Floodplain, ” said Sandy Mannion, long time Midland County activist.


This summer the state of  Michigan listed the entire Tittabawassee River Floodplain as a Hazardous Waste Facility of the Dow Chemical Company.  Long-term remedy of this situation is incumbent on Dow initiating cleanup of identified hot spots like areas  at Immerman Park; areas where soil concentration far exceed the 90 ppt set by the State of Michigan.


 “Exposing children and the general public to these high concentrations while Dow gathers more data and community input is nothing short of irresponsible”, said Lone Tree Chairman Terry Miller.  “They need to dig in and get the job done.”


Though additional soil sampling is important, much of the activity that Lone Tree feels is imperative is not contingent on further sampling or date collection. All of the parks downstream from Midland are contaminated  as are the sediments in the Tittabawassee River. Lone Tree council believes Dow should immediately focus on these most obvious sites

Lone Tree Council

P.O. 1251, Bay City, Michigan 48706

(Fighting for environmental justice since 1978)



                                LONE TREE COUNCIL’S RESPONSE TO





   It is Lone Tree Council position that  an adequate Scope of Work must immediately address  Dow Chemical Company’s  contamination in the following ways:


  1. Remove Severe River Contaminants.  a) Steps must be taken immediately to remove the areas presently identified as of heaviest dioxin contamination (hot spots) in the Tittabawassee River.  This should include dredging  using a sealed clamshell, no overflow process, that would  not resuspend contaminants; approved and under the supervision of the Department of Environmental Quality and appropriate federal agencies.   b) In addition, the identification of locations, establishment and regular disposal of sediment through traps within the Tittabawassee River should be established to begin the cleaning of the river.
  2. Eliminate Park Exposure. Initiate actions to eliminate human exposure at public parks.  This may include but not be limited to capping, removal of soils, closure, and/or eliminating use of high human use, high contamination, areas through coverage with non-permeable material.
  3. Relocate Families.  In areas of heaviest contamination, Dow Chemical Company should offer families buy-outs at a price acceptable to the families.
  4. Respond to Floodplain Agriculture.  a) Dow must immediately remove any of its agriculture properties within the floodplain from cultivation.  Because of the risks posed by blowing dust during cultivation,  the risk of bio-uptake, and other ecological exposures, Dow should immediate suspend those leases.  b) In addition, Dow should aggressively provide monetary support and staff to either enroll (through the Michigan Department of Agriculture) existing private agriculture within the floodplain in the Conservation Reserve Enhancement Program (CREP) program or make outright purchase at a price acceptable to the owners.
  5. Conduct Floodplain Erosion Control.   Eroding banks continue the cycle of contamination.  Dow must identify areas where the Tittabawassee River shoreline is unstable and take steps necessary to stabilize.  This may include but not be limited to rip/rap or plantings.
  6. Continued Sampling.  All the above are not contingent on sampling, and should be expedited to prevent human exposure.  The State, however, has not been as comprehensive as necessary to determine the full extent of soil contamination.  Dow Chemical should initiate soil sampling in areas identified by the State including, but not limited to the Center Road Boat Launch, Green Point Nature Center, the Germania Golf Course, and a nearby driving range within the floodplain. Sampling should be split with the State, reported in a timely manner, and Interim Responses taken immediately upon finding elevated dioxin levels.


   It is critical that all six of these Interim Responses be implemented as soon as possible, delay and debate continue a process of denial and avoidance that has allowed human exposure to continue for decades -- that is simply unacceptable.   Dow Chemical Company seems committed to a health study or future ecological study before taking action -- that too is unacceptable.  We know where the hot spots are in the river,  we know the yards and the parks that are contaminated, the shoreline areas that need stabilization, to delay responding to these continuing sources of contamination is unconscionable.

   Also, these six responses do not preclude actions taken in the future relative to Remedial Investigations and Responses.   We believe that the Dow Chemical Company should conduct a comprehensive evaluation of continuing sources of dioxin releases to the Tittabawassee River, including but not limited to existing processes, historical sources, Dow owned agricultural properties, accidental releases, as well as permitted sources. 

   We also believe that the contamination was not the public’s responsibility, and those public funds that have been used to discover and evaluate the extent of the contamination, should be reimbursed to the State.  Moreover, we believe that the integrity of the process requires continued supervision by the Department of Environmental Quality, and that the Dow Chemical Company should reimburse all future staff time, and split sampling costs to the State. 

    We also believe that despite Dow Chemical’s denial, the company has played a significant if not exclusive role in the dioxin contamination in the Saginaw River sediment.  In a proactive action that would assume responsibility and actively pursue remediation before legal requirements, we would urge that Dow cooperate with, and support financially and with staff time, the legal and environmental requirements necessary to create a suitable dredge spoils site at the General Motors facility on the upper Saginaw River.

   Finally, Dow Chemical Company has resurrected its flawed approach to Risk Assessment in its Scope of Work. Dow has a responsibility , before once more taxing the time and energy of citizens, to respond to the highly critical comments of the U.S. Environmental Protection Agency, (U.S.EPA), Agency for Toxic Substances and Disease Registry (ATSDR) and State of Michigan toxicologist, who submitted  pages of criticism  last year.  And Dow should identify in its Scope of Work (SOW) what will be done with the results of its proposed health study data.