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How Dow is Regulated Under Environmental Regulations
The Dow Chemical Company (Dow), Michigan Operations, Midland Plant is a chemical manufacturing complex located at 1790 Building, Washington Street in Midland, Michigan, and the Dow, Michigan Operations, Salzburg Road Landfill is a hazardous waste landfill located at 2314 West Salzburg Road, in Midland, Michigan. The combined Midland Plant and Salzburg Road Landfill complex is comprised of approximately 2,052 acres. Dow manufactures a variety of chemical products using a variety of process equipment including reactors, distillation/fractionation columns, separators, storage tanks/silos, boilers, condensers, thermal heat recovery, oxidation units, scrubbers, etc. at various locations within the Dow Chemical complex. Many locations across the complex generate hazardous waste which Dow is licensed to store, treat, and dispose of under the hazardous waste license issued by the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Materials Management Division (MMD). Dow's license also cover the Salzburg Landfill located southwest of the intersection of Waldo and Salzburg Roads.
Dow is subject to multiple environmental regulatory programs, carried out by multiple government agencies. Each agency issues separate permits or licenses under the authority they are assigned under the regulations. The permit or license issued by each agency identifies what Dow must do to operate properly, to prevent the release of contaminants to the environment, and to limit any allowed discharge of contaminants to levels determined to be protective of human health and the environment. Each agency requires monitoring and performs independent oversight to ensure the facility is operated in a protective manner that meets the permits and license requirements. The agencies also share information to ensure compliance.
EGLE, MMD licenses and inspects Dow's hazardous waste and solid waste operations separately. MMD inspects Dow's hazardous waste operations at least four times per year and solid waste operations at least once per year. Before the pandemic, these inspections were typically unannounced. During the pandemic, short advance notice is provided before an inspection. The inspections are performed to verify the operations meet the license requirements. MMD evaluates Dow's hazardous waste storage, treatment, and disposal areas, emergency planning, employee training, recordkeeping, and corrective action (clean-up) information.
EGLE, Air Quality Division issues the permit for air emissions from the facility. Air Quality Division inspects the facility to evaluate compliance with the air quality requirements and reviews the facility's monitoring data.
EGLE, Water Resources Division (WRD) issues the permit for the discharge of treated wastewater into the Tittabawassee River. The WRD inspects the facility, reviews monitoring data, and conducts sampling of the facility's discharge.
The Michigan Department of Agriculture and Rural Development is involved for agriculturally zoned properties in the floodplain areas and is available to answer questions regarding cleanup activities and the raising of chicken and livestock within areas of dioxin and furan contamination.
Finally, the Michigan Department of Health and Human Services is available to answer questions regarding any health concerns regarding dioxins and furans.
Although the U.S. Environmental Protection Agency (EPA) does not permit or license the facility, they may also conduct inspections to verify compliance with air, water, and hazardous waste regulations. Dow, EGLE, and EPA have entered into an Administrative Settlement Agreement and Order on Consent for the cleanup of dioxins and furans released from legacy operations at Dow to the Tittabawassee and Saginaw Rivers and Floodplains and Saginaw Bay Superfund Site. EPA is the lead agency for the Superfund site cleanup. Additional information on the cleanup is available on EPA's website here.
The U.S. Fish and Wildlife Service is also coordinating response activities for the facility associated with a settlement for a Natural Resources Damage Assessment (NRDA). Additional information regarding the NRDA settlement activities is available on the USFWS website here.
Subscribe to the Site mailing list to receive updates from EGLE related to the Dow license and corrective action activities. You are the eyes and ears of your community. Through your observations and reporting of activities of concern, you play a valuable role in helping the EGLE protect human health and the environment. To file a complaint or share details about improper waste handling or disposal, contact EGLE through the Pollution Emergency Alerting System (PEAS) Hotline at 800-292-4706.