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June 14, 2007

Mr. Joseph Haas, Senior Environmental Quality Analyst


MDEQ, Constitution Hall, 525 West Allegan Street
PO Box 30458
Lansing, MI 48909-7758

Re: Permit Modification Request for:


MDEQ Permit File No. 07-56-0005-P
Corps Permit File No. LRE-2007-586-23
Reach D Project on the Tittabawassee River
The Dow Chemical Company, Midland, Michigan

Dear Mr. Haas:


As agreed at our meeting of June 5, 2007, we are submitting drawings B2-001Y-984050 through
B2-008Y-984050 and the attached information to serve as Dow’s formal request for a
modification to the referenced MDEQ & Corps permits. This request covers only the work
proposed for 2007 and includes the items listed below. A detailed description of each item
follows the list.

Permit Modification Items


1. Increased scope of work and phased approach to the project
2. Raise the permitted top elevation of the temporary sheet piling from 598 to 600 USGS datum
3. New permanent sheet piling wall in the following areas:
• Upstream end of Reach D to downstream side of RR Bridge
• New temporary turbidity curtain for between the Pipe Bridge and RR Bridge
• Downstream side of RR Bridge to the Dow Dam
• At the existing 30 inch & 36 inch waterline crossings
4. Excavation and fill volumes changes
5. Turbidity monitoring equipment to be installed in the river channel

2007 Permit Modification Request Items

Increased scope of work


Based on the river bottom sampling data that was available when the project was originally
permitted in March, all of the contaminated sediments were thought to be between the river bank
and the 1940 (flume) sheet piling. Additional river bottom sampling was recently performed and
the limits of contamination were found to extend beyond (river side) the flume sheet piling. The
total volume of contaminated sediment to be removed for this project increased from the 4,000
cubic yards originally permitted to the current estimate of 14,000 cubic yards (inplace measure).
This change in scope, the need for a new permanent sheet piling wall for the full length of the
project to ensure RGIS sheet piling and bank stability, along with several other significant
construction issues have led Dow to determine that there is a very low probability of completing
the entire project in the 2007 construction season.

In an effort to move the project forward, Dow is requesting MDEQ & Corps approval to complete the
work in 2 phases. The first phase will be completed in 2007 and extends from the upstream end of
Reach D to the Pipe Bridge as shown on the drawings. The 2007 work includes installation of
temporary and permanent sheet piling, sediment removal and placement of new rip rap & fish gravel
in this area. Dow is also requesting approval to install the remainder of the new permanent sheet
piling from the Pipe Bridge to the Dow Dam. Installing the entire permanent sheet piling wall this
year will expedite the 2008 work by and estimated 6 to 7 weeks. It is Dow’s intent to remove all of
the temporary sheet piling in the fall of 2007 and then secure the site for winter. If this is not
possible due to river and weather conditions, sections of the sheet piling will be removed at the
upstream and downstream ends of the temporary wall to provide a flow path through this area. In
2008, the remainder of the Reach D Project will be completed
Raise temporary sheet piling top elevation to 600 USGS – The top of temporary sheet piling
elevation was originally permitted at 598 USGS datum which is approximately 1.6 feet above
ordinary high water mark (OHWM) of the river. Due to the normal changes in river elevation as a
result of the Sanford Dam operations and the fact that the project will run into the fall of this year,
we request that the permit be modified to allow the top of the temporary sheet piling be set at
elevation 600 USGS. This elevation will significantly reduce the potential for overtopping during
the typical river elevation fluctuations due to Sanford Dam operations and during the early fall
rains.

New Permanent Sheet Piling Wall


• Upstream end of Reach D to downstream side of RR Bridge – In 1985, RGIS sheet piling
was installed along the bank on this section of the river. An analysis of the RGIS sheet piling
indicates that it will become unstable due to the depth of contaminated sediment removal
required in this area. To insure RGIS sheet piling stability, Dow will install a new permanent
sheet piling wall immediately adjacent to and on the river side of the existing piling. The new
piling will be driven at least 10 feet deeper into the structurally stable till soil than the current
RGIS piling. The new piling will also have the same top elevation as the existing RGIS piling,
600 USGS.

• New temporary turbidity curtain between the Pipe Bridge and RR Bridge – A temporary
turbidity curtain will be installed between the Pipe Bridge and the RR Bridge prior to driving
the new permanent sheet piling wall in this area to ensure no sediment leaves the site. The
curtain will be located approximately 10 feet from shore and will have a top elevation of 600
USGS as shown on the drawings. The curtain will be connected to the temporary sheet
piling on the upstream end and be anchored to the river bank on the downstream end.
Design drawings for the curtain were not complete at the time of this submittal but will be
forwarded as soon as they are available. Upon completion of the permanent sheet piling
installation between the bridges, the turbidity curtain will be removed from the river.

• Downstream side of RR Bridge to the Dow Dam – A work plan for this section of the new
permanent sheet piling was originally submitted to the MDEQ via email on 4/11/07. That
data has been incorporated into the attached drawings. This section of new permanent sheet
piling is necessary to provide river bank stabilization when the contaminated sediments along
this portion of the project are removed in 2008. This section of new sheet piling wall will be
embedded in the existing river bank as shown on drawings. The new piling will also
transition into the existing sheet existing piling at the Dow Dam. The top of the new sheet
piling wall in this area will be driven to elevation 600 USGS which will make it flush with
surrounding ground.

• At the existing 30 inch and 36 inch waterline crossings – The new permanent sheet piling
immediately above and adjacent to the existing waterlines will be shortened and coped (cut)
to provide a minimum of 12 inches to 18 inches of clearance above and around the sides of
the pipe as shown on the drawings. This method will protect the existing waterlines from
damage during the installation of the new piling. In 2008, upon completion of the sediment
removal, the voids between the new sheet piling and the waterlines will be sealed using grout
bags such as Fabriform® or similar material.
Excavation & Fill Volumes
• Excavation – The volume of contaminated sediment to be removed in the 2007 work area is
approximately 6,800 cubic yards (inplace measure). This is approximately 49% of the
estimated total volume of contaminated sediment in the entire Reach D Project area. The 2007
work will also remove an estimated 85% to 90% of the contaminated sediments that found
outside (river side) of the 1940 flume sheet piling.

• Fill – Upon completion of the contaminated sediment removal in 2007 work area (upstream of
the Pipe Bridge), new rip rap and fish gravel will be installed on the river side of the new
permanent sheet piling as detailed on the drawings. The rip rap is required to prevent scouring
and destabilization of the sheet piling wall due to high river events and ice flows. An
approximately 6 inch thick layer of fish gravel will be installed over top of the new rip rap as
requested by the MDEQ. In the area from the Pipe Bridge to the Dow Dam, the new rip rap
and fish gravel will be installed in front of the new permanent sheet piling after the
contaminated sediments are removed in 2008. The estimated total volume of new rip rap and
fish gravel to installed in 2007 is approximately 1,800 cubic yards – 1,650 rip rap & 150 fish
gravel (inplace measure). When compared to the contaminated sediment excavation volume in
the 2007 work area, there is a net removal of approximately 5,000 cubic yards of material from
the river channel.

Turbidity monitoring equipment – Two turbidity monitors will be installed in the river channel for
the 2007 project as shown on the drawings. One monitor will be positioned upstream of the
project to measure normal turbidity levels in the river. The second monitor will be located just
downstream of the new temporary turbidity curtain between the bridges. Both of the monitors will
be mounted on a single piece of piling (sheet pile, H-pile or pipe pile) driven into the river bottom.
The support pile will be marked in accordance with all regulations to protect the public.

HEC RAS modeling – A new HEC RAS model has been developed for the 2007 work. The
model indicates that there could be an increase of 0.07 feet in the 100 year flood stage elevation
at the upstream Dow property line as a result of the proposed work. The new model includes the
following items:
• New temporary sheet piling from the upstream end of Reach D to the Pipe Bridge with a
top elevation of 600 USGS
• New permanent sheet piling from the upstream end of Reach D to the Dow Dam with a
top elevation of 600 USGS
• A new temporary turbidity curtain between the Pipe Bridge and RR Bridge with a top
elevation of 600 USGS – the curtain was modeled as a barrier in the river similar to a
sheet piling wall
• All of the contaminated sediments are inplace in this model represent the project site just
before dredging starts. We believe this is the “worst case” scenario because the volume
of contaminated sediment to be excavated from the river is over 3 ½ times larger than the
fill volume of new rip rap and fish gravel that will be placed in the river after sediment is
removed.

The HEC RAS model is not attached to this electronic submittal because it is to large for our
email system to handle. Phil Vogelsang of URS performed the modeling work and will send a
complete electronic copy of the new HEC RAS model directly to Joy Brooks, as requested. If
there are any questions on the modeling or if you would like a copy, please feel free to contact
Phil directly at his office (616) 574-8479 or via cell (616) 901-7472.

We have also include Attachment A which indicates our best estimate of the overall project
schedule for 2007 and 2008. The 2007 portion of the schedule is based on receiving all MDEQ
and Corps permits by Friday, July 6th and starting the sheet piling work on Monday, July 9th, river
and weather conditions permitting. The 2008 schedule is preliminary and assumes river and
weather conditions will allow work to start by mid May, 2008.
Electronic copies of Attachment A and the drawings associated with this permit modification
request are attached. We will also follow-up with 11”x17” hard copies of the drawings for you and
all of the folks listed below. In addition, we will provide 3 full size copies of the drawings to
District for Joy & Brian. If there are any questions please contact me at @ 989-636-6085 or via
email at jjallen@dow.com.

Sincerely,

John Allen, P.E.

CC:
Joy Brooks, MDEQ
Cheryl Howe, MDEQ
Mark Lesinski, US Army Corps of Engineers
Trish Peters, MDEQ
Brian Rudolph, MDEQ
Al Taylor, MDEQ
Steve Lucas, Dow
Phil Vogelsang, URS
ATTACHMENT A

REACH D PROJECT
SCHEDULE

2007 Schedule:
• Joint Permit modification request submitted to MDEQ & Corps June 14th
• Joint Permit modification approved and issued by MDEQ & Corps on or before July 6th
• Start temporary sheet piling installation July 9th
• Complete temporary sheet piling installation August 3rd
• Start removal of existing rip rap by mechanical excavation August 6th
• Start permanent sheet piling installation within temporary sheet piling area August 6th
• Complete removal of existing rip rap August 10th
• Start dredging (sediment removal) operation August 13th
• Complete permanent sheet piling installation within temporary sheet piling area August 31st
• Install temporary turbidity curtain between Pipe Bridge & RR Bridge week of August 13th
• Start permanent sheet piling installation from Pipe Bridge to Dow Dam August 20th
• Complete permanent sheet piling installation from Pipe Bridge to Dow Dam September 28th
• Complete dredging September 28th
• Remove temporary turbidity curtain between Pipe Bridge & RR Bridge week of October 1st
• Install new rip rap + fish gravel week of October 1st
• Start removal of temporary sheet piling and site winterization October 8th
• Complete temporary sheet piling removal and site winterization November 9th
• Alternative schedule – remove sections of the sheet piling at the upstream and
downstream ends of the temporary wall to provide a flow path through this area

2008 Schedule (schedule assumes river & weather conditions allow work to start in mid May)
• 4th quarter of 2007 - Joint Permit application submitted to MDEQ & Corps for 2008 work
• Joint Permit issued by MDEQ & Corps in early May, 2008
• Mobilize and prepare to start work for the first half of May
• Start turbidity barrier (temporary sheet piling & turbidity curtains @ 30 inch & 36 inch
waterlines) installation from Pipe Bridge to Dow Dam during second half May
• Complete turbidity barrier installation by end of June
• Mechanical excavation of existing clay & gravel between RR Bridge and Dow Dam in
late June or early July – estimate one week duration
• Start dredging (sediment removal) operation in early July
• Complete dredging by late August or early September
• Install new rip rap + fish gravel in September
• Start removal of turbidity barrier by late September or early October
• Complete turbidity barrier removal and demobilization by late October or early November

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