EPA Pressures Dow Chemical for Immediate Clean Up in Michigan

EPA Region 5 notified Dow Chemical Co. on July 3 that it must immediately start cleanup of three dioxin-contaminated hot spots downstream of its Midland, Mich., facility on the Tittabawassee River.

The action was taken using the Comprehensive Environmental Response, Compensation and Liability Act of 1980 and requires that Dow and EPA negotiate the final terms of three administrative consent orders for the cleanup within 15 days and start field work by August 15.

EPA has documented that dioxin contamination in soil poses risks to human health and the environment. Cleanup must take place in a significant portion of the Upper Tittabawassee River this construction season.

The Dow facility is a 1,900-acre chemical manufacturing plant located in Midland, Mich. Dioxins and furans were byproducts from the manufacture of chlorine-based products. Past waste disposal practices, fugitive emissions, and incineration at Dow have resulted in on- and off-site dioxin and furan contamination. Contamination of the Saginaw Bay Watershed extends over 50 miles into Saginaw Bay.

In late November 2006, Dow identified dioxin hot spots along the first six miles of the Tittabawassee River contaminated with levels up to 87,000 parts per trillion, far in excess of state and federal requirements. The areas of concern are subject to flooding and erosion that could spread the contamination.

Dow's corrective action work under its 2003 Michigan Resource Conservation and Recovery Act license has taken too long, prompting EPA to require the following actions.

  • Development of a removal plan, including field sampling.
  • Excavation and/or dredging of soil, bottom deposit, sediment, submerged sediment, riverbank and floodplain soil to an EPA-approved cleanup level.
  • Cut-back and stabilization of river bank.
  • Proper disposal of all dioxin-contaminated material, including water.
  • Re-vegetation of floodplain areas with native plants, backfilling and erosion control.
  • Sampling and chemical analysis as removal progresses.

Dow has five days to respond to EPA's notice letter.

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  • OHS Magazine Digital Edition - January 2019

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