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#2: Initial Actions to Address Dioxin Concerns
Open Letter to the Community from Susan Carrington

Midland, MI - November 17, 2003

As noted in my last letter to the community, Dow is committed to keeping you informed about our plans, our actions and our views on the local dioxin situation. I’d like to update you on some of the many actions underway.

First, let me address the belief held by some that Dow should “just clean it up.” It’s not that simple. Any remedial actions must be very carefully evaluated to ensure that they are necessary and effective, that they will not have a negative impact on the environment, and that they are acceptable to those who own or use the land where the actions would take place. These principles are guiding Dow’s actions, which now include:

Neighborhood Discussions. Dow wants to develop ongoing dialogue with residents of the Tittabawassee River area, the majority of who have not participated in the large public meetings held by MDEQ. These are the people who will be most affected by whatever decisions are made regarding the dioxin situation, and we believe they should be heard.

For that reason, this week we began a series of small, informal neighborhood discussions with local residents to provide them an opportunity to candidly discuss their specific ideas and concerns, and to help us in developing effective, acceptable options for addressing those concerns.

Let me emphasize that these meetings will not be used in the lawsuit pending against Dow. The neighborhood meetings are designed solely for Dow representatives to listen and learn. The meetings are not recorded, and no one is asked to sign or approve anything. In fact, in the spirit of openness, we have invited the media and public officials to attend the meetings as “observers,” with the understanding that they will keep participants’ comments confidential.

The first of these meetings was completed this week and I am pleased to report that attendance was good and people felt the discussions were candid and productive.

Wild Game Sampling. In response to a community request, and under a plan approved by MDEQ last Monday, professional hunters with the USDA’s Wildlife Services Division have begun collecting deer, turkeys and rabbits from two locations within the Tittabawassee River floodplain below Midland, and from one location within the floodplain upstream of Midland.

Tissue samples will be analyzed for dioxins and furans, and the data will be used to determine whether there is a difference between the animals taken from different points along the river. The results will also be compared with dioxin and furan levels found in the national food supply for the same or similar species, such as beef and chicken. Results will be available early next year.

This testing will provide actual data about the levels of dioxin in local wildlife. A recent preliminary assessment of possible dioxin levels in local wildlife, performed by a consultant for MDEQ, relied heavily on extreme assumptions and extrapolations rather than on actual data. We believe the actual data will be much more useful in answering people’s questions about the condition of local wild game and whether further action is needed.

Reducing soil exposure in public areas. Dow has submitted to MDEQ a series of actions designed to reduce the potential for exposure to soil in Freeland Festival Park, Imerman Park, West Michigan Park and the Center Road Boat Launch. Proposed actions include: building walkways and walls to cover exposed soil and reduce erosion; covering exposed soils with crushed rock, riprap, wood chips and vegetation to reduce contact; and installing additional hand-washing stations so people can wash off soil.

These interim actions are part of the proposed Scopes of Work (SOW) that Dow originally submitted to MDEQ for review in August, and has subsequently modified in response to public comments we’ve received. We expect to receive MDEQ’s comments on the overall SOW soon, and will continue working with the agency to refine and approve final work plans.

In the coming months, we will provide information on additional programs, including local soil sampling, river flow and sediment sampling and establishing public information centers.

As the process continues, we encourage you to work with us, and the regulatory authorities, toward resolving these issues. You may reach us at 636-9323, or via e-mail at www.dowmidmichigan.com/contact.

Sincerely,

Susan Carrington
Vice President and Director
Michigan Dioxin Initiative
 


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