Work Plan

On February 16, 2012, the Michigan Department of Environment, Great Lakes, and Energy (EGLE, formerly MDEQ) announced an agreement with Dow on a proposed plan to resolve the long-standing dioxin issue in the city of Midland.

As part of the proposed resolution, Dow would sample residential properties near the manufacturing site for the presence of dioxins above a site-specific action level. EGLE proposed a level of 250 parts per trillion (ppt) for residential soils in the Midland Area. This level was developed by EGLE, in accordance with U.S. Environmental Protection Agency (EPA)-approved risk assessment procedures, and with input from EPA. Sampling data and bioavailability soil studies conducted in the Midland Area were factored into the calculations.

The exact area for remediation was determined by soil sampling results. The initial area for sampling has been generally defined as the area closest to Dow Michigan Operations Site, north to Eastlawn Drive, west to Rodd Street and east to Waldo Avenue. A smaller area to the southeast of the intersection of Washington and Ashman Streets was also sampled. The footprint of these areas were refined as the program was implemented and more sampling information become available.

Project Progress & History

To date Dow has requested access to over 1700 residential, residential like and non-residential properties. Once access was granted Dow sampled the property and tested the soil for dioxin TEQ. Results of the testing were communicated to property owners. If the soil tests were less than or equal to 250 ppt no additional work was required. If the soil tests were above 250 ppt TEQ Dow developed a soil monitoring plan or a plan with the property owner for removal of 12 inches of soil, replacement with clean soil and new landscaping. Upon agreement with the property owner Dow completed the work.

History of Dioxin Issue in Midland

1983 - 1988	Sampling of dioxin levels in Midland soils (EPA/1983, Dow/1984, 1988) concludes soils are below federal residential clean-up guidance of 1000 ppt.
1984	Dow releases a detailed peer reviewed study on the historic sources of dioxin entitled, "Point Sources and Environmental Levels of 2378-TCDD on the Midland Plant Site of the Dow Chemical Company and in the City of Midland, Michigan." The study included 240 samples of soil, water, airborne particles and other samples. None of the samples outside of the Michigan Operations fence line exceeded 1000 ppt. (Nov 5)
1988	EPA report recommends additional sampling of soil, sediment and water. Federal hazardous waste permit includes requirements for sampling plans.
1996	The state became authorized to implement corrective action in Michigan for facilities that manage hazardous waste. Sampling of dioxin levels in Midland Soils (MDEQ/1996, Dow/1998) concludes soils are above the 1995 state criterion of 90 ppt.
2002	The 90 ppt generic state clean-up level for dioxin for residential property is incorporated into regulations.
2003	Hazardous Waste Management Facility Operating License requires Dow to address elevated dioxin levels in city of Midland as well as the Dow plant site, Tittabawassee and Saginaw Rivers, and Saginaw Bay.
2004	Dow submits to MDEQ a proposed path forward on the development of site-specific criteria for Midland, which includes soil testing and bioavailability studies.
2006 - 2011	Additional studies conducted to evaluate Midland-specific dioxin and soil characteristics. The soil sampling that was conducted as part of these studies is the basis for the initial Resolution Area.
2010	Changes made to Michigan's clean-up law (Part 201) regarding the "facility" designation allow discussions to move forward.
2012	MDEQ, Dow reach agreement on a proposed plan to resolve dioxin situation for city of Midland Soils.
2012-2014	Dow implementing plan
2016	Dow submits Corrective Action Report to DEQ