CONESTOGA-ROVERS & ASSOCIATES

261 Martindale Road, Unit #3, St Catharines, Ontario L2W1A2 Telephone: 905-682-0510 Facsimile: 905-682-8818 vwvw.CRAwor ld.com

May 13, 2002 169503

Reference No. 13151-06

Mr. Thonnas Cook On-Scene Coordinator U.S. EPA Region 5 n West Jackson Boulevard Mail Code SE-5J Chicago, Illinois 60604-3507

Dear Mr. Cook:

Re: Notification of Site Conditions UAO Removal Action Implementation Former Rockwell Intemational Corporation Site Allegan, Michigan

This letter has been prepared to formally notify the Uruted States Environmental Protection Agency (U.S. EPA) of certain Site conditions at the former RockweU International Corporation Facility in Allegan, Michigan (Site). On May 1, 2002 the City of Allegan notified ArvfriMeritor, through ArvinMeritor's Site representatives, Conestoga-Rovers and Associates (CRA), that there was a blockage of the sanitary sewer line which runs from the residential dwelling atNorth Street, beneath the western portion of the Coimty of Allegan Health Services parking lot, and cormects to the main sanitary line south of the County of Allegan building. The City of Allegan indicated that they would need to excavate the sanitary sewer line to find the blockage and conduct repairs as necessary. The location of the sanitary line is shown on the attached Drawing No. 1.

The City of Allegan indicated that they began the excavation activities on the morning of May 2, 2002, starting at the north end of the parking lot and proceeding south. Approximately 80 to 100 feet south of where the City of Allegan began excavating, they state that they encountered some stained material near the elevation of the sanitary sewer Line (See Drawing No. 1). The area where the stained material was encountered corresponds approximately to the area where the blockage to the sanitary sewer line was encountered. The City of Allegan continued to excavate material to remove the line to the main sanitary sewer connection. According to the City of Allegan representatives, stained material was encountered from aroimd the blockage south to the main sewer line connection.

During installation of the new sanitary sewer tine. City of Allegan personnel reported observing oil on the surface of the excavation water. At approximately 3:00 pm on May 2,2002, CRA's construction superintendent arrived at the Site with several CRA laborers at which time the

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City of Allegan informed CRA of what they encountered in the excavation. When CRA arrived on-Site the City of Allegan had begun backfilling the excavation.

On the morning of May 3, 2002, CRA's Project Manager was informed of the incident and two CRA representatives visited the Site to evaluate the situation further. CRA persormel observed some black stained material which had a petioleum odor. CRA also observed some standkig water in the southeast comer of the parking lot that contained a sUght oUy sheen. CRA collected two samples of stained soil material, one from the parking lot area (S-050302-WB-001) and one from the north of the parking lot in the backyard of North Street (S-050302-WB-002). In addition, CRA collected a sample of the standing water observed kv the south east corner of the parking lot (SW-050302-WB-003). The three samples were submitted to Severn Trent Laboratories (STL) for polychlorinated biphenyls (PCB) analysis. On the afternoon of May 3, 2002 CRA and ArvuiMeritor contacted tiie U.S. EPA On-Scene Coordinator (OSC), Mr. Thomas Cook and left a message regarduig the incident at the Site. Suice the OSC was not available the Regional Deputy Officer, Emergency Response Branch Region 5 (Mr. William Simes) was also informed of the incident.

The preliminary analytical results of the three soil samples collected on May 3,2002 are presented below. It should be noted that the results are preliminary and have not undergone quahty assurance/quality control reviews.

Sample ID Location PCB Result

S-050302-WB-001 Parking Lot 50,000 Hg/kg S-050302-WB-002 Yard of North Street ND(400) ^g/kg SW-050302-WB-003 Water in SE Comer of Parkkig Lot 40 ng/L

ArvinMeritor immediately informed U.S. EPA verbally of the PCB analytical results upon receipt of the results and a security fence was installed around the parking lot to prevent contact by the public. CRA representatives, on behalf of ArvinMeritor, met with the OSC, Lori Hong of Weston, and Lisa Sutterfield of the City of Allegan at the Site to review the situation on May 10,2002. During the on-Site meeting, CRA indicated that ArvinMeritor would proceed with the following activities:

• Begin re-mobUizing the removal action contractor to the Site to begin setting up the facihties required to conduct further excavation activities, including Site trailers, a decontamination facility, soil staging faciUty, excavation equipment, additional fencing, frac tank for excavation water, and other required facihties on May 13, 2002;

• InstaU three temporary monitoring weUs approximately 10 to 20 feet west of the area where the stained material and oU was encountered by the City of AUegan to monitor for potential migration to the west of the area. The weUs wUl be instaUed to straddle the water table and

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two soU samples wUl be coUected from each soU boring and submitted for PCB analysis. One of the two samples wiU be coUected from the "smear zone." CRA wiU mobiUze a Geoprobe to the Site on May 15, 2002 to complete these activities;

• Remove, for off-Site disposal, approximately 1 foot of soU material from the area of the parking lot which has been impacted by soU material from the excavation or from discharge of oUy water;

• Excavate, for off-Site disposal, soil material from the area where the City of Allegan encountered the stained soU and oU material;

• Excavate for off-Site disposal additional material from the excavation, as necessary to remove stained or oUy material in accordance with the Unilateral Admirustrative Order (UAO) Removal Action Work Plan;

• Conduct verification sampling of the excavation in accordance with the UAO Removal Action Work Plan; and

• Conduct backfUling, restoration, and demobilization activities once the excavations have been verified to meet the cleanup objectives of the UAO Removed Action Work Plan.

The additional sampling, removal, staging, and backfiU activities wiU be conducted in accordance with the UAO Removal Action Work Plan, with the exception that the staging area, for characterization of excavated material, may be located on the City of AUegan footpath instead of on the former RockweU Site north of the former Manufacturing BuUding as was done during the initial removal action activities.

Should you have any questions on the above, please do not hesitate to contact us.

Yours truly,

CONESTOGA-ROVERS & ASSOCIATES

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GAC/sr/13 End.

c c : Kathleen Schnieders (U.S. EPA) Linda Furlough (ArvinMeritor) Robert Schroder (ArvinMeritor) David Tripp (Dykema Gossett) Glenn Turchan (CRA)

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10 20ft

LEGEND

™™™'-"^i'-"~'™™' EXISTING CONTOUR

-~"™™™' •'• ™—'•™~" FENCE

0 MW-12 MONITORING WELL LOCATION

O '^" MANHOLE

• ^-^ CATCH BASIN

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O SAMPLE LOCATION

STM CUY STORM SEWER PIPE

s CONCRETE STORM SEWER PIPE

SAN ESTIMATED SANITARY SEWER LOCATION ESTIMATED STORM SEWER ALIGNMENT

^ „ , ^ _ _ ~ ~ " EXCAVATION AREA

J g APPROXIMATE AREA OF STAINED l ^ ^ ^ _ _ J MATERIAL ENCOUNTED BY CITY OF ALLEGAN

SCALE VERIFICATION

THIS BAR MEASURES 1" ON ORIGINAL. ADJUST SCALE ACCORDINGLY.

DRAWING STATUS

FORMER ROCKWELL INTERNATIONAL SITE

UAO REMOVAL ACTION SITE AREA

CONESTOGA-ROVERS A ASSOCIATES

Source Reference:

SOURCE: ENVIRONMENTAL STRATEGIES CORP.; PITTSBURGH, PA; 12/3/97

Project Manager

G, CARLI

Reviewed By:

N. LEVESQUE

Project Nil:

13151-06 Report NH:

COOK013 Drawing N^:

1 13151-06(COOK013)GN-DE001 MAY 10/2002