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Re: E-M:/ FW: State, Dow commit to expedite resolution of dioxin situation

------------------------------------------------------------------------- Enviro-Mich message from MICHDAVE@aol.com -------------------------------------------------------------------------
Sorry more comments. Below are the final comments from Lone Tree Council to the DEQ regarding Dow Chemical's work plans. Our frustration goes without saying.
Michelle HR
Lone Tree Council


We believe the sampling conducted by the U.S. Army Corps of Engineers (ACOE), the Michigan Department of Environmental Quality (MDEQ), and Dow consultants, have all supported the position that elevated levels of dioxins and furans, higher than any area in the state, are present in the sediment of the Tittabawassee River, the Saginaw River and bay, as well as the floodplain of the Tittabawassee River.  The highest levels are near the river and diminish with distance from the river consistent with periodic flooding.  The sediment contaminants are being regularly washed downstream from their source in the Tittabawassee to the confluence of the Saginaw River, down the Saginaw River and into the bay.


 The preliminary ecological studies demonstrate bio accumulation in deer, wild turkeys, squirrels, mergansers’ eggs and earthworms.  The Michigan Department of Community Health (MDCH) has issued only the second wildlife consumption advisory in its history for turkeys, deer and squirrels in the Tittabawassee floodplain.  MDCH has also issued fish consumption advisories on several species of fish in the Tittabawassee and Saginaw Rivers.  The Michigan Department of Agriculture (MDA) has issued food, farming and garden advisories for the Tittabawassee River floodplain based on dioxin/furan contamination.  Moreover, the twenty-five participants in the Pilot EI conducted by MDCH showed dioxin body burdens at levels above or at high end of normal range.


LTC believes that this information, collected in the four years since the discovery of elevated dioxin/furan levels in the watershed is sufficient to invoke the precautionary principle, and require of the responsible party, the Dow Chemical Company, to begin remediation.  We believe that all sampling must be directed towards, not only determining the geographical boundaries in all impacted areas, but the removal and disposal of high levels when they are discovered.  We believe that the delays caused by the responsible party’s inadequate Scopes of Work and now, responses to the Framework and license requirements, have exacerbated the problem.  All delay places a greater burden on the downstream ecology, flooding Inner Saginaw Bay with irretrievable contaminants; contaminants that have already impacted lake trout populations in Lake Huron, and would threaten recreational and commercial fisheries, as well as tourism in Lake Huron.  But the greater responsibility lies with addressing the human families that live, work and play in some of the highest concentrations of dioxins and furans in the state.


The state knows enough to act.   The willingness of the State of Michigan to tolerate these delays by Dow Chemical is a failure of will, and a violation of its obligations to protect the public and the publics’ resources.  For Dow Chemical to continue to obfuscate, delay and deny, is to violate its charter as a corporate entity, and make contemptible, its recent history of philanthropy.  LTC insists immediate efforts be directed to developing a comprehensive plan to fully characterize the extent of the contamination, develop a plan for remediation and restoration, including but not limited to, riverbank stabilization, removal and disposal of contaminated river sediment and floodplain soils, and complete restoration of the ecology of the floodplain and properties of those that reside in the floodplain.



Terry Miller

Michelle Hurd Riddick

Lone Tree Council


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