History of the Dioxin Emissions from the Dow Chemical Incinerator

In 1978, Dow Chemical reported results of a chlorinated dioxin and dibenzofuran

monitoring program to the Michigan Department of Natural Resources and U.S. EPA
Office of Toxic Substances (Blumb, R.R. et al, “Trace Chemistries of Fire: A Source of
Chlorinated Dioxins,”Science, 210, 385, 1980). U.S. EPA reviewed air and scrubber
water data from Dow Chemical’s rotary kiln incinerator, which revealed high levels of
dioxin and furan contamination. In field evaluations concluded by U.S. EPA Region 5 in
early 1980s, it was determined that the Dow incinerator, which had burned chlorinated
wastes for many years, was likely the primary historical source of dioxins and
dibenzofurans found in residential soils.

The link between the emissions from the incinerator and contamination found in
residential soils was based upon (1) similar dioxin/dibenzofuran profiles in air emissions
and soils as well as (2) dispersion modeling. Based upon a series of stack emissions tests
conducted in 1984 by U.S. EPA Region 5 and Dow Chemical data reviewed in 1987,
U.S. EPA concluded that dioxin and dibenzofuran levels had greatly reduced by
optimization of combustion conditions, so as to not significantly contribute to additional
soil contamination downwind of the facility.

Recommendations were made for a series of additional incinerator stack tests and
ambient air monitoring in the late 1980s. A comprehensive risk evaluation of soils, air,
water and fish in Midland conducted in 1988, concluded that significant health risks did
not exist for persons exposed to dioxins in soils, except for children with pica who would
have higher soil ingestion rates. Public health recommendations (e.g., washing hands
before eating) were made to reduce exposures to dioxins and dibenzofurans found in
soils. In contrast, highly significant health risks (cancer risks as great as one in a 100;
unacceptable non-cancer) were found for fish consumers eating fish from the
Tittabawassee River. With the exception of residential properties along the flood plain
which are of concern, more recent soil data in the Midland area indicates average cancer
risk levels in the one in a hundred thousand range with no residential properties being
above U.S. EPA’s action level of one part per billion. (Michigan Dioxin Studies, Dow
Chemical Building 703 Incinerator Exhaust and Ambient Air Study; EPA-905/4-88-04,
U.S. EPA, 1988; Dioxin Risk Assessment for Dioxin Contamination Midland Michigan,
EPA-905/4-88-005, U.S. EPA, 1988. Risk Management Recommendations for Dioxin
Contamination at Midland Michigan: Final Report; EPA-905/4-88-008, U.S. EPA, 1988).

According to RCRA personnel, this older incinerator was ultimately closed (date
unknown) and about ten years ago a second one was constructed having higher
efficiencies for destroying organic compounds. Dow has since then built a third
incinerator, theoretically even more advanced, and was planning to shut down the second
incinerator.