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May 20,2007
This document represents the May 2007 Progress Report for the Reach D Pilot Correction
Project (PCAP).
During the period of April 20, 2007 through May 20, 2007, the following project activities have
taken place (item numbers refer to those outlined in the attached Gantt Chart):
Regulatory Submittals/Activities
ITEM 4: The geophysical contractor completed post-processing of data for the Reach D
Project site. A summary report provided by Tetra Tech is included as Attachment A.
ITEM 6/7: Results of chemistry testing on samples collected by ATS and their subcontractors
at several locations outside the flume sheet piling and from natural soils beneath the
anthropogenic Reach D deposit are included in Table 1.
MDEQ-WMD and URS staff discussed and came to an agreement on means to collect
additional data from natural soils beneath the Reach D anthropogenic deposit in the area
between the Railroad Bridge and the Dow Dam. These samples were obtained and results
are presented in Table 2. Data from original characterization work are included for reference
in Table 3. A description of results and a summary of findings are included as Attachment B.
ITEM 16: Pore water data collected from a temporary well screened within the impacted
sediment was summarized and submitted to the MDEQ-Water Bureau on April 30, 2007.
Initial dewatering pilot testing was completed. Laboratory testing was completed and results
were summarized and provided to the MDEQ-Water Bureau on May 8, 2007, for dewatering
pilot study water quality. These data are being used by the MDEQ-Water Bureau during its
review of the NPDES Permit modification request made by Dow.
ITEM 19: Development of the Semi-Permeable Membrane Device (SPMD) Study was
completed, with a summary of the proposed study included in this submittal;
ITEM 29: Dow submitted the Permit To Install to the MDEQ-Air Quality Division on May
3, 2007.
ITEM 32: The MDEQ approved the Permit To Install Construction Waiver on May 4, 2007.
ITEM 36: The Fugitive Dust Control Plan was submitted by Dow and approved by the
MDEQ during this reporting period.
ITEM 38: The Ambient Air Monitoring Program was near completion, due for submittal to
the MDEQ on May 21st.
ITEM 41: As part of mobilization activities, a Soil Erosion Permit for the project was
received from the City of Midland on April 26, 2007.
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Pre-Construction Activities
Activities conducted during this period included the following:
ITEM 18: Receipt and acceptance of the dredging contractors Health and Safety Plan
(HASP);
ITEM 41: Initial mobilization activities included Dow contractor safety training and
orientation; and the ordering and delivery of sheet piling and HDPE pipe
ITEM 42: Some site preparation activities began under the auspices of the Permit To Install
Construction Waiver. These activities included the initiation of HDPE dredge line fusion on
May 10, 2007.
Test piles were driven on May 3rd and 4th to support the final sheet piling design. It is
noteworthy that as part of this design process, two subsurface water pipelines (30” and 36”
diameter) were identified in Reach D. This discovery has instigated a substantial amount of
unforeseen work that will be necessary to properly design the sheet piling system. This work
includes additional excavations, underwater inspections by divers, pipeline isolation
requirements, and contingency plan development.
Final design of the Geotube containment facility was complete. Final drawings are included
in this submittal for MDEQ review.
Dow received approval from the MDEQ on May 7th to begin construction of the Geotube
Containment Facility. Mobilization by the construction contractor began shortly thereafter,
with construction due to begin before the end of this reporting period.
Equipment for installation of the temporary sheet piling also began during this reporting
period, with construction also projected to begin before the end of this reporting period. Site
preparation construction activities are contingent on weather and ground conditions.
2 of 3
The objective of this study is to examine the time-integrated presence of selected chlorinated
organic chemicals in the water of the Tittabawassee River as measured by uptake in SPMDs.
The specific Tittabawassee River site location targeted for this monitoring study will be
upstream and downstream of Reach D, located near the Dow Dam. A summary of the proposed
study is presented as Attachment D.
Because this monitoring project is focused on gathering background river data on selected
chemicals, and sediment dredging and removal is scheduled to begin in mid-July 2007, this study
must be initiated no later than early June, contingent on the issuance of all necessary permits.
3 of 3
Attachment A
By Tetra Tech
Upper Tittabawassee River
Hydrographic and Geophysical Survey
Reach D
Survey Report
May 7, 2007
Prepared by:
Tetra Tech EC, Inc.
19803 North Creek Parkway
Bothell, WA 98011
(425) 482 7600
1 Overview................................................................................................................................ 1-1
2 System Setup.......................................................................................................................... 2-1
2.1 Interconnections........................................................................................................... 2-1
2.2 Device Offsets.............................................................................................................. 2-3
2.2.1 Hypack/Hysweep Offsets.................................................................................. 2-3
2.3 Sonar Mount................................................................................................................. 2-3
2.4 Geodesy Settings.......................................................................................................... 2-5
2.5 GPS Reference Station................................................................................................. 2-6
3 Bathymetry Results................................................................................................................ 3-1
4 Sub-Bottom Profile Results ................................................................................................... 4-1
List of Figures
List of Tables
Data collection and navigation software, for the bathymetry and sidescan surveys, was
Hypack®/Hysweep®. The SBP data were collected using Edgetech 3100-P hardware and
Discover software v3.42.
Software settings for bathymetry data acquisition include the serial I/O configuration and sensor
offsets in Hypack, and Hypack Navigation device offsets in the HySweep hardware
configuration.
2.1 Interconnections
Figure 2-1 shows the data flow and communications setup for the devices which make up the
survey system. Table 2-2 lists the settings for each of the data communication links.
Device offsets are precisely defined for the multibeam sonar, attitude sensor and GPS antenna, so
that the Hypack/HySweep acquisition software can accurately convert the input sonar and
support sensor data into XYZ soundings on the earth.
The following offsets, in feet, were used for the Hypack and HySweep sensors:
The sonar head was mounted to the vessel using a side mount pole, as shown in Figure 2-2. The
mount is rigidly attached to the side of the vessel. The sidescan system was mounted on a bow
mount, shown in Figure 2-3. This figure also shows the subbottom profiler towfish, which was
suspended from a pole mounted on the port bow.
The geodesy settings shown in Table 2-4 were used for the project.
At the time of the mobilization, the only pre-defined high quality survey control point in the area
was the National Geodetic Survey (NGS) FREELAND (PID OK0006) Primary Airport Control
Station located at the Tri-City International Airport. The NGS Data Sheet for this control is
provided in Appendix A.
Since no national or state agency control points were available in locations suitable for setting up
a RTK base station, the NGS Online Positioning User Service (OPUS) was used to establish
geodetic control points. Wade-Trim, a local survey company, provided two locations where they
had previously determined coordinates using RTK GPS. An RTK capable GPS was set up over
the points for a period of approximately 2 hours, throughout this period data were recorded. The
data were then transferred to NGS OPUS via the internet for processing. Based on this data NGS
OPUS provided the reports included in Appendix A, which were used for Reach D control.
Additional OPUS points were established for quality control (QC) purposes.
Table 2-5 presents the NGS control and OPUS points that were utilized and established.
The 3100-P system consists of a towfish with in-water transducers and hydrophone receivers and
a shipboard processing system that received digital data from the towfish. For this project the
SB-424 towfish was suspended in a fixed position just forward of the bow along the port side of
the survey vessel (Figure 2-3) to enable data collection in very shallow water, as well as provide
the best possible positional data that fixed mounting offers. This same mount was adapted and
used for the SB-216 (Figure 4-1) during data collection on May 14. A small inflatable catamaran
was used to support the larger and heavier SB-216 towfish.
An acoustic pulse was generated by the transducers and acoustic reflections from the river sub-
bottom were received by the hydrophones. Data were transmitted via cable from the towfish to
the shipboard processing system workstation running Edgetech’s Discover software. The
processing system logged the return pulse signals and processed the data into time-based cross
sections of the acoustic response of the sub-bottom. By inputting the speed of sound measured at
the site (as determined with a Seabird SBE-19, 1427 ft/sec used) the time sections were
converted into pseudo-depth sections. Data were displayed as pseudo-depth cross sections of
acoustic response with time on a computer screen and logged to computer hard drive and then
transferred and archived to external data storage for permanent storage and later post-processing.
Figure 4-2 shows the only data collected behind the sheet pile wall to show any structure
(collected April 6th). Approximately three layers are discernable to a maximum depth of about
2.5 ft below the bottom. These layers were not compared to core data, but at 2.5 feet below the
bottom, it is not believed that the data extends to the ‘native’ material below the sediment
deposited in the flume. The bottom layer appears to have a gravel component while the
overlying sediment appears to be soft, fine grained material.
Data was collected with the more powerful, and lower frequency SB-216 on May 14th within the
flume area in Reach D. The results were no better than with the SB-424. The one file that spans
the largest area within the flume is presented in Figure 4-3. The May 14th SB-216 data were
colleted at approximately the same river stage as during the April 6th SB-424 data collection.
Figure 4-4 shows a representative sample of the SBP data collected during the survey outside of
the flume area. This survey line was in the main river channel and shows a clearly defined layer
below the existing river bottom. The blue surface is the under side of the digital terrain model
created from the bathymetry (within the IVS Fledermaus software). Data from within the water
intake basin does not show this layering.
The NGS Data Sheet. See file dsdata.txt for more information about the
datasheet. DATABASE = Sybase ,PROGRAM = datasheet, VERSION = 7.42
1 National Geodetic Survey, Retrieval Date = APRIL 5, 2007
OK0006
***********************************************************************
OK0006 FBN - This is a Federal Base Network Control Station.
OK0006 PACS - This is a Primary Airport Control Station.
OK0006 DESIGNATION - FREELAND
OK0006 PID - OK0006
OK0006 STATE/COUNTY- MI/SAGINAW
OK0006 USGS QUAD - AUBURN (1973)
OK0006
OK0006 *CURRENT SURVEY CONTROL
OK0006 ___________________________________________________________________
OK0006* NAD 83(1994)- 43 31 22.32418(N) 084 05 26.01391(W) ADJUSTED
OK0006* NAVD 88 - 203.553 (meters) 667.82 (feet) ADJUSTED
OK0006 ___________________________________________________________________
OK0006 X - 476,921.563 (meters) COMP
OK0006 Y - -4,607,649.372 (meters) COMP
OK0006 Z - 4,369,920.959 (meters) COMP
OK0006 LAPLACE CORR- -2.32 (seconds) DEFLEC99
OK0006 ELLIP HEIGHT- 169.32 (meters) (06/11/02) GPS OBS
OK0006 GEOID HEIGHT- -34.24 (meters) GEOID03
OK0006 DYNAMIC HT - 203.512 (meters) 667.69 (feet) COMP
OK0006 MODELED GRAV- 980,414.7 (mgal) NAVD 88
OK0006 OBS GRAVITY - 980,412.0 (mgal) GRAV_OBS
OK0006
OK0006 HORZ ORDER - A
OK0006 VERT ORDER - SECOND CLASS 0
OK0006 ELLP ORDER - FOURTH CLASS I
OK0006
OK0006.This mark is at Tri City Intl Airport (MBS)
OK0006
OK0006.The horizontal coordinates were established by GPS observations
OK0006.and adjusted by the National Geodetic Survey in July 1992..
OK0006
OK0006.The orthometric height was determined by differential leveling
OK0006.and adjusted by the National Geodetic Survey in June 1991..
OK0006
OK0006.The X, Y, and Z were computed from the position and the ellipsoidal
ht.
OK0006
OK0006.The Laplace correction was computed from DEFLEC99 derived
deflections.
OK0006
OK0006.The ellipsoidal height was determined by GPS observations
OK0006.and is referenced to NAD 83.
OK0006
This position and the above vector components were computed without any
knowledge by the National Geodetic Survey regarding the equipment or
field operating procedures used.
Background
River-based sampling was completed by ATS and their sub-contractors on April 10 and
11, 2007. These samples included sub-grade samples from beneath the anthropogenic
deposit between and south of the two bridges. A total of ten samples were able to be
tested for at least a partial list of the contaminants of concern. Results are summarized in
Table 1.
Methods
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The Dow Chemical Company Reach D Project
Michigan Operations
the future. Summary Tables present the results of leach testing, a full listing of leach
testing is provided as Attachment C to the May 2007 Reach D Monthly Progress Report.
Discussion
River-based Sampling
River-based sampling efforts inside of the flume were able to collect samples of the
natural clay soil layer just beneath the anthropogenic Reach D deposit. Samples RD-
51+00-IC-40, RD-51+50-IC-33, and RD-52+50-IC-20 (shown on Figure 1) are samples
of silty clay found beneath the anthropogenic deposit. Total soil concentrations from
these samples are all well below the MDEQ Generic Residential Groundwater Surface
Water Interface Criterion (GSI) for soil. Conservative leach testing showed leaching
under extreme conditions only in one sample. Detection limits for tetrachloroethene and
chlorobenzene were elevated too high in the samples to determine if the soils would leach
under these extreme conditions. Although no site-specific criterion for surface water
sediments has been specified under R 299.5730, these are soils beneath the river and
samples were well below the Generic soil GSI criterion, the data support completing the
removal action of the anthropogenic deposit, down to the elevation of the natural soils.
River-based sampling efforts were limited in the amount of information that could be
obtained. The presence of gravel and stiff clays minimized the ability to collect sufficient
samples to allow analysis in several locations. Several samples were attempted outside
the flume sheet piling, but were unable to obtain sufficient quantities of sediment for
testing. Samples from coring location RD-49+75-IC-45 (shown on Figure 1) from depths
ranging from 0.8 to 4.0 feet were not able to recover sufficient sample to allow testing for
volatile or semi-volatile compounds. A maximum estimated TEQ of 4,300 ppt was
detected from this set of samples. This coring was taken prior to results of high-resolution
bathymetry survey and it appears that this sample may have been obtained inside the
1939 flume sheet piling.
Samples from coring location RD-51+25-IC-50 were made down to a depth of 1.5 feet
using hand sampling tools from a floating platform by the River-based sampling crew.
Evidence of contamination from these samples was not identified.
Additional sampling is planned to occur at the time of this submittal in this are to confirm
the findings in samples from coring location RD-49+75-IC-45, and provide additional
data to evaluate the preliminary conclusion that contamination does not extend beyond
the 1939 flume sheet piling wall.
The shore-based sampling results indicate that the constituents of concern are present at
vastly lower concentrations than in the anthropogenic deposit above them. In addition,
although no site-specific criterion for surface water sediments has been specified under R
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The Dow Chemical Company Reach D Project
Michigan Operations
299.5730, none of the natural soil samples (in Tables 2 and 3) contained concentrations
of the constituents of concern above MDEQ Generic Residential soil GSI criterion.
Three of the fifteen additional soil samples were able to be leached at levels above the
Generic GSI groundwater criterion using the conservative leach testing. Because these
soil samples were well below the Generic soil GSI criterion, the data support completing
the removal action of the anthropogenic deposit down to the elevation of the natural soils.
Conclusion
Removal of the natural sub-grade soils is not necessary, as the soil data are not above
MDEQ Part 201 Generic Residential Groundwater Surface Water Interface Criterion.
Leach testing, as allowed (but not specifically required) by R 299.5722 and RRD
Operational Memorandum No. 2 – Attachment 2 (Soil Leaching Methods) results
conservatively show that risk of discharge from the natural soils beneath the
anthropogenic Reach D deposit (after its removal) will be below allowable levels.
River-based sampling completed thus far has been problematic in that an insufficient
number of samples have been able to be tested for the constituents of concern. As stated
above, additional sampling is planned to occur at the time of this submittal to confirm the
findings in samples from coring location RD-49+75-IC-45, and provide additional data to
evaluate the preliminary conclusion that contamination does not extend beyond the 1939
flume sheet piling wall.
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Attachment C
INTRODUCTION
OBJECTIVE
Deployment or protection devices may also be used, if necessary, to ensure the integrity
of the SPMDs during study conduct. Each deployment device will contain one or more
SPMD, as needed, to obtain the desired or target chemical quantitation levels detailed in
Table 1. Each individual SPMD weighs approximately 4.58 g and contains 20% lipid, or
~0.915 g (1 mL) of triolein; two SPMDs constitute approximately 9.2 g total weight and
will be used as a single SPMD sample, as this mass is roughly equivalent to the mass of
fish tissue (10 g) generally analyzed in fish studies conducted on the Tittabawassee River.
The standard SPMDs are 2.5 cm wide x 90 cm long low density polyethylene tubes (70-
95 µm wall thickness), for a total surface area of ~450 cm2 or approximately 100 cm2/g-
SPMD. High purity (>95%) triolein will be used in the SPMDs from EST. SPMD
calibration data are generally based on the weight of the standard SPMD [9].
At the termination of exposure, the SPMDs will be shipped to EST in St. Joseph, MO for
extraction. One or more background or control SPMDs will be handled and analyzed at
study initiation to identify any background chemical residues that may be present during
the handling process. We will also have one or more newly-opened SPMDs extracted by
EST at the termination of the exposure period. This allows Dow to monitor any chemical
residues introduced into SPMDs by the overall EST-extraction process. All extracts will
be returned to Dow for chemical residue analysis.
Except for Location B, where eight SPMDs will be used, twelve SPMDs will be placed at
each sampling location to help quantify the variability of accumulated residues; a total of
44 samples (with two SPMDs/sample or ~9.2 g/sample) will be needed for all sites. The
SPMDs will be placed in deployment cages for protection and attached to anchored poles
in the river to allow for a constant exposure location. The anchoring sites will be
approximately one foot (12”) or more off the bottom of the river.
At each location, on the terminal day of exposure, Tittabawassee River water samples
will be taken to analyze for constituents with water detection levels noted in Table 1;
specifically, the water samples will be analyzed for chlorobenzene, 1,2-dichlorobenzene,
1,4-dichlorobenzene, 1,2,4-trichlorobenzene, and hexachlorobutadiene. The water
sampling volume will be a minimum of 1-L for analytes analyzed as semi-volatile
compounds and 40-mL for analytes analyzed as volatile compounds. The sampling will
be in done in triplicate at each of the four locations for a total of 12 water samples. The
water samples will be taken in general accordance with a standard operating procedure
(SOP) regarding the collection of depth-integrated, aqueous samples from streams and
rivers not more than 15 feet in depth [11].
Chemical Analyses
SPMDs will be extracted by EST and returned to Dow for final analysis. The analytical
method for PCDD/PCDF analysis will be based on the U.S. EPA Method 1613B [12],
which involves isotope dilution methodology, purification by classical liquid
chromatography, and final analysis by high-resolution gas chromatography/high
resolution mass spectrometry (HRGC–HRMS). The remaining analytes in the SPMDs
will be determined by other methods, such as isotope dilution methodology, and some
purification prior to gas chromatography/mass spectrometry (GC/MS) analysis or other
appropriate analytical methods. Details of all analytical techniques will be provided in
the final study report.
River Conditions
Tittabawassee River water flow conditions, such as water flow and river gage height, will
be obtained from the United States Geological Survey (USGS) web page, available at:
http://waterdata.usgs.gov/mi/nwis/uv/?site_no=04156000&PARAmeter_cd=00065,00060 . Data on
Tittabawassee River gage height (feet) and streamflow (ft3/second or cfs) will be
collected daily over the exposure period. The USGS monitoring station on the
Tittabawassee River is located at Lat 43°35'43", Long 84°14'08", in NW1/4 NE1/4
sec.28, T.14 N., R.2 E., Midland County, Hydrologic Unit 04080201, on right bank 2,000
ft downstream from dam at Dow Chemical Co. in Midland, 0.7 mi upstream from
Bullock Creek, 1.4 mi downstream from Chippewa River, and 23 mi upstream from river
mouth.
USGS data on Tittabawassee River mean water flow per day are presented in Figure 2.
Average peak flow is generally in late March, while minimum flow is in mid-August; the
average flow for June is approximately 1,000 to 2,000 cfs. Collectively, the USGS data
may be used to characterize river conditions during the study and to allow for any follow-
up monitoring study to be evaluated against the river conditions at the time of the SPMD
exposures. Other water quality parameters, such as temperature, pH, alkalinity, etc., may
be available from the Dow Wastewater Treatment Plant and recorded in the data file for
the exposure dates.
Statistics
The stated objective of the study is to determine the time-integrated residues of certain
bioaccumulative chemicals in the Tittabawassee River over a several week timeframe.
As noted previously, the SPMD is not an accurate representation of a fish, but is a useful
tool to determine the environmental presence of aqueous hydrophobic chemicals.
Consequently, accumulated residues of compounds in SPMDs can not be compared to
accumulated fish chemical residues observed in previous Dow biouptake studies.
Individual chemical residue values, averages, standard deviations, and 95% confidence
limits will be reported for each sampling site location.
REFERENCES
2. Huckins JN, Petty JD, Lebo JA, Orazio CE, Prest HF, Tillitt DE, Ellis GS,
Johnson BT, Manuweera GK. 1996. Semipermeable membrane devices (SPMDs)
for the concentration and assessment of bioavailable organic contaminants in
aquatic environments. In Ostrander GK, ed, Techniques in Aquatic Toxicology.
Lewis, Boca Raton, FL, USA, pp 625–655.
5. Petty JD, Huckins JN, Zajicek JL. 1993. Application of semipermeable membrane
devices (SPMDs) as passive air samplers. Chemosphere 27:1609–1624.
6. Prest HF, Huckins JN, Petty JD, Herve S, Paasivirta J, Heinonen P. 1995. A
survey of recent results in passive sampling of water and air by semipermeable
membrane devices. Mar Pollut Bull. 31:306–312.
9. SPMD Technology tutorial (3rd edition). 2002. Prepared by James Huckins et al.
Available at: http://wwwaux.cerc.cr.usgs.gov/spmd/SPMD-Tech_Tutorial.htm.
10. Gale, RW, Huckins, JN, Petty, JD, Peterman, PH, Williams, LL, Morse, D,
Schwartz, TR, and Tillitt, DE. 1997. Comparison of the uptake of dioxin-like
compounds by caged channel catfish and Semipermeable membrane devices in
the Saginaw River, Michigan. Environ. Sci. Technol. 31: 178-187.
11. LimnoTech. 2006. Depth integrated water sampling standard operating procedure
(SOP).
12. U.S. EPA Method 1613B, Chlorinated Dioxins by Isotope Dilution High
Resolution Gas Chromatography/High Resolution Mass Spectrometry. Report
821/B-94-005.
Table 1. List of chemicals of interest and maximum limits of detection (MLOD) for
SPMDs.
MLOD
Chemical SPMD Water Units
chlorobenzene TBD 5 ng/g (wet wt) or ng/mL (ppb)
12-dichlorobenzene TBD 5
14-dichlorobenzene TBD 5
124-trichlorobenzene TBD 5
1245-tetrachlorobenzene 1
1234-tetrachlorobenzene 1
Hexachlorobutadiene TBD
Pentachlorobenzene 10
Hexachlorobenzene 1
2378-TCDD 1 pg/g (wet wt) or ng/L (ppt)
12378-PeCDD 5
123478-HxCDD 5
123678-HxCDD 5
123789-HxCDD 5
1234678-HpCDD 5
OCDD 10
2378-TCDF 1
12378-PeCDF 5
23478-PeCDF 5
123478-HxCDF 5
123678-HxCDF 5
234678-HxCDF 5
123789-HxCDF 5
1234678-HpCDF 5
1234789-HpCDF 5
OCDF 10
TBD = To be determined
Figure 1. Map of the planned sampling sites on the Tittabawassee River.
Figure 2. Mean river flow (ft3/sec) as a function of Julian Day for the Tittabawassee
River. Source: U.S. Geological Service.
US Geological Survey: Tittabawassee River Mean Flow Rate (cfs) versus Julian
Day (Data: 1937 to 2006)
6,000
Tittabawassee River Mean Flow (ft3/sec)
5,000 29 March
4,000
3,000
2,000
1,000
15 August
0
0 50 100 150 200 250 300 350 400
Julian Day #
Attachment D