Chemical Warfare Agents in Michigan

[asagady@sojourn.com]

>Date: Tue, 22 Oct 1996 18:10:48
>To: enviro-mich@igc.org
>From: asagady@sojourn.com
>Subject: Chemical Warfare Agents in Michigan
>
>FROM: 
>
>Sierra Club, Mackinac Chapter
>300 North Washington Square #411
>Lansing, MI  48933
>
>
>On Friday, the Sierra Club published an announcement appearing that
>morning in the Federal Register announcing that the "Chemical  Warfare
>Development Division" in Michigan was the site of known or suspected
>burial of chemical warfare materials.
>
>Today, the Sierra Club received a fax from the U. S. Department of 
>Defense Aberdeen Proving Ground indicating that  the the "Chemical
>Warfare Development Division" site is on the property of the Dow 
>Chemical Company, Midland MI  
>
>Information from the fax follows:
>
>During WWI, Dow manufactured mustard gas in Midland in Building 
>20A.   This site was first used to manufacture chloroform and was 
>converted to make mustard gas.
>
>The purpose of the Chemical Warfare Development Division was to 
>develop a process for the large scale production of mustard gas.  
>Experimental production of a thousand tons of mustard gas was completed
>prior to the shutdown of the plant at the end of the way.   The plant
>was then converted and used for the production of aspirin.
>
>According to the DOD fax  "Mustard agent and contaminated equipment
>from the Chemical Warfare Development Division was disposed of on Dow 
>Chemical property by burial."
>
>"No remediation actions are planned at this time"
>
>"It can not be determined whether the suspected original disposal site
>was completely decontaminated by Dow personnel at a later date.  If 
>Dow personnel did remove the mustard agent and contaminated 
>equipment, it could not be determined where the agent and equipment
>were moved to.  It can be stated with some certainty that
>the relocated agent and equipment probably stayed within the 
>Dow Chemical property boundary."
>
>The DOD notice describes the site as the "Dow Chemical Company, 
>centralized disposal pits."
>
>
>=====================================================
>
>The Sierra Club-Mackinac Chapter has the following questions for
>Dow Chemical, the U. S. Department of Defense, the U.S. Environmental
>Protection Agency and the Michigan Department of Environmental
>Quality:
>
>1.    Has Dow Chemical surveyed all such pre-RCRA "disposal 
>       pits" for evidence of disposal of mustard gas?
>
>2.      Has Dow Chemical surveyed soil gases at these sites with
>        low detection limit equipment to determine whether any 
>        mustard gas products or intermediates are detectable?
>        If so, what are the results?   And were any other toxic volatile 
>        organic compounds detected in any such sampling?
>
>3.      Has Dow Chemical used ground penetrating radar, magnetometers,
>         and other  remote sensing techniques to survey all known or suspected
>         sites of mustard gas disposal?   Have these same techniques been
>         used to assay any other sites of pre-RCRA toxic and hazardous waste
>         disposal sites at the Dow complex?
>
>4.      Has Dow Chemical identified all such primitive, pre-RCRA
>         disposal sites on its property?   
>
>5.      What is the nature of any toxic and hazardous materials that
>         have been disposed in pre-RCRA "disposal pits?"
>
>6.      Has Dow Chemical installed perimeter groundwater detection
>         wells at sites which are pre-RCRA "disposal pits?"  If so, what if
>         any evidence is available showing migration of toxicants from
>         the site of pre-RCRA "disposal pits?"
>
>7.      Has Dow Chemical been shielded from requirements to remove
>          and destroy (or otherwise properly dispose) toxicant materials that
>          may be present in pre-RCRA "disposal pits" by the early-1990's 
>          amendments  to Michigan's environmental response statutes
>          allowing risk-based, "in-place" "clean-ups"  where toxicants are
>          covered but not removed?
>
>
>Posted by Alex Sagady, Technical Consultant to the 
>Sierra Club, Mackinac Chapter
>asagady@sojourn.com     (517) 332-6971;  (517) 332-8987 (fax)
>
>

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Alex J. Sagady & Associates    		Email:  asagady@sojourn.com
Environmental Consulting and Database Systems
PO Box 39
East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)