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Long Term Stewardship Plan Former TRW Facility Sullivan, Missouri

June 19, 2017

Attachment D to Corrective Action Abatement Order on Consent No. 17-HW-P001

Long Term Stewardship Plan Former TRW Facility

Prepared for:

TRW Automotive (U.S.) LLC

Prepared by:

ARCADIS U.S., Inc.

132 East Washington Street

Suite 600

Indianapolis

Indiana 46204

Tel 317 231 6500

Fax 317 231 6514

Our Ref.:

KC001689.0001

Date:

June 19, 2017

This document is intended only for the

use of the individual or entity for which it

was prepared and may contain

information that is privileged, confidential,

and exempt from disclosure under

applicable law. Any dissemination,

distribution, or copying of this document

is strictly prohibited.

Matt Johnston, LPG – IN #2259 Project Geologist

John P. Shonfelt, PG Principal/Certified Project Manager

SECTION 1 – INTRODUCTION 1

1.01 Purpose & Scope 1

SECTION 2 – CITY OF SULLIVAN WELL NO. 2 AND TREATMENT SYSTEM 3

2.01 COS-2 Treatment System 3

2.01.01 Operation 4

2.01.02 Maintenance 6

2.01.02 Record Keeping Procedures 6

SECTION 3 – GROUNDWATER MONITORING PLAN 7

SECTION 4 – INSTITUTIONAL CONTROLS 7

4.01 Water Well Installation Controls 7

4.02 Property Use Restrictions 7

SECTION 5 – CLOSED SURFACE IMPOUNDMENTS 8

SECTION 6 – CITY OF SULLIVAN AND OTHER THIRD PARTY NOTIFICATIONS 8

SECTION 7 – MEETINGS BETWEEN TRW AND CITY OF SULLIVAN 9

SECTION 8 – CONTACT LISTS 9

Tables Table 1 – LTSP Coordination Lists Table 2 – COS-2 Key Component List Table 3 – Standard Communication Log Table 4 – Contact List Figures Figure 1 – COS Organization and Decision Flow Chart

Appendices A. COS-2 Operating Records Checklist B. COS-2 Maintenance Record Checklist C. COS-2 Start Up Procedures D. COS-2 Normal Operation Instructions E. COS-2 Alarm Conditions F. COS-2 Emergency Actions

G. COS-2 Shutdown Procedures H. COS-2 Parts Replacement Information Sheet I. Draft Letter of Understanding Between TRW and COS

SECTION 1 – INTRODUCTION

1.01 Purpose & Scope

This Long Term Stewardship Plan (LTSP) is Attachment D to the Corrective

Abatement Order on Consent No. 17-HW-P001 (Order). In general, the LTSP describes

the routine and ongoing procedures required by the Order to document, track and verify the

arrangements and agreements that TRW Automotive U.S. LLC (TRW) will need to

implement in cooperation with the City of Sullivan (COS) and other third parties. Other

Attachments to the Order include the Groundwater Monitoring Plan (GMP), Drinking

Water Contingency Plan (DWCP), and the Corrective Measures Implementation Plan

(CMI), or collectively, the Work Plans.

Paragraphs 75, 76, and 77 of the Order lists specific items that must be covered in

the LTSP. Several of these required elements are contained in the other Attachments. The

list of specific items and where they can be found, either in this document or in the GMP,

DWCP, and/or CMI, follows:

Order Required Element Section and/or Document

Location

74 Sister Property, Inc. and Sullivan Warehousing, Inc. shall record an environmental covenant in the chain-of-title for the Facility property that includes appropriate property-specific use restrictions.

Stand-alone document contained in Attachment F to the Order

75.A Table 4 and Figure 1 of the LTSP include current contact information for TRW, the City of Sullivan and Ace Manufacturing and Parts Co;

LTSP – Table 4 and Figure

1

75.B A section discussing the property use restrictions outlined in Paragraph 74 of this Order

LTSP –Section 4.02

75.C A summary description of long-term final remedy operation, maintenance, security and monitoring

LTSP – Section 2

2

Long Term Stewardship Plan Former TRW Facility, Sullivan, Missouri

75.D Presentation and discussion of the final remedy objectives, including applicable media cleanup standards

CMI – Section 1.02;

GMP – Table 3

75.E Identification of equipment needed for long-term final remedy implementation, including that required for water supply treatment systems installed at the City of Sullivan’s municipal wells;

LTSP – Table 2;

CMI Table 1

75.F A description of the training requirements and procedures for all personnel involved in operation, maintenance and monitoring of the final remedy including any training provided to City of Sullivan employees for the operation and maintenance of water supply treatment systems installed at the City of Sullivan’s municipal wells

LTSP – Section 2.01.01;

CMI – Section 2.04.02

75.G A description of any start-up procedures for elements of the final remedy, including any operational testing;

LTSP – Appendix C;

CMI - Appendix E

75.H A description of normal operation and maintenance procedures related to the final remedy, including: 1) ongoing operational tasks; 2) ongoing maintenance tasks; 3) a description of applicable treatment or operational conditions; and 4) a schedule showing the frequency of each task;

LTSP – Appendix D;

CMI – Appendix F

75.I An inspection schedule for final remedy equipment and components for both on- and off-property groundwater treatment systems; and

LTSP – Appendix B;

CMI – Tables 3, 4 and 5

75.J A description of the procedures to address any breakdown or operational problems with the final remedy including a list of redundant and emergency back-up equipment and procedures.

LTSP – Appendix H;

CMI – Appendix J; On-Site

System Manuals

76 The LTSP includes all measures necessary for effective and efficient communication with third parties, specifically the City of Sullivan, Missouri, related to implementation of the final remedy for the Facility.

LTSP – Section 7

77 As part of the LTSP, TRW shall inspect the Facility to assess its condition at least once per year as part of annual coordination efforts with the City of Sullivan and the Facility property owners. If conditions at the Facility change such that previously inaccessible soils are now accessible,

Environmental Covenant

Paragraph 74 of the Order

3


TRW shall notify the Department within 15 days of becoming aware of the situation. All current and future landowners and operators shall be advised of this requirement by TRW and be instructed to notify TRW of any activities on the property that may uncover or disturb previously inaccessible soils.

The procedures as well as Responsible Party, Frequency, Recordkeeping, Location of

Records, and Reporting /Verification information are shown in Table 1. The key systems

that will be managed by the LTSP are:

City of Sullivan Well No. 2 and Treatment System

Groundwater Monitoring Plan

Institutional Controls

Closed Surface Impoundments

COS and Other Third Party Notifications

SECTION 2 – CITY OF SULLIVAN WELL NO. 2 AND TREATMENT SYSTEM

2.01 COS-2 Treatment System

The City of Sullivan has agreed to overall responsibility for the operation and

maintenance of COS-2 and the remediation system. The signed Agreement specifying the

City of Sullivan responsibility is provided as Appendix B in the CMI. Table 1 reflects the

conditions of the Agreement. Appendix A contains the COS-2 Operating Records Checklist

to be used by the City of Sullivan, while Appendix B contains the COS-2 Maintenance

Records Checklist and Schedule. The CMI provides additional information on the design

and operation of the system.

4


2.01.01 Operation

An organizational and decision-making flow chart that demonstrates the relationships

and responsibilities between TRW and the City of Sullivan regarding COS-2 is provided as

Figure 1. The City of Sullivan has overall responsibility for the operation and maintenance

of COS-2 and the treatment system. If an issue arises with the treatment system that the City

needs help in handling, the City shall contact the TRW Site Operator, who shall answer

questions and/or provide guidance. If a piece of equipment on the treatment system fails or

must otherwise be replaced, TRW and its Site Operator will effect repair/replacement, in

coordination with the City of Sullivan. Issues related to the system performance and

compliance with discharge standards (as related to the COCs only) are covered under the

DWCP.

A table identifying key components of the system, their designation, a description of

their operational purpose, operating range, records to be kept, and other relevant

information is provided as Table 2.

Operation of the treatment system can be divided into several scenarios, depending

on system status, water characteristics, water demand, and non-normal or emergency

situations. The following lists anticipated scenarios the operator will encounter. Step-by-

step methods to be used under each of these scenarios follow or are cross-referenced to

Appendices.

1. Startup. When the system is ready to become operational, the operator must go

through a specific, stepwise process to ensure the water is properly treated before

distribution, and that no equipment is damaged. The methodology to be used is

provided in Appendix C.

2. Normal Operation. Under normal operation, COS-2 is pumping from the well

through the air stripper and chlorination system, and then to the distribution system.

The operator is required to perform periodic checks to verify the system is

operating properly. The normal operations checklist is provided as Appendix D.

5


3. System Performance Monitoring. Periodic sampling and analysis of effluent from

the treatment system is required. With respect to monitoring of COCs, the

sampling and monitoring is described in the DWCP. Monitoring of other water

quality parameters required by the Public Drinking Water Program of the Missouri

Department of Natural Resources (MDNR) is performed by the City of Sullivan and

is outside the scope of this LTSP.

4. Alarm Condition. Alarm conditions are indicated by an annunciator or visual signal

(light) on the main control panel. Specific alarm conditions are listed in Appendix

E, but may include:

a. Chlorine weight. Indicates the chlorine supply tanks need to be changed

b. High/low water level in the chlorine contact chamber.

c. High air flow back pressure. Check blower operation, blockage in air line,

scale on trays, blockage in stack.

d. Low chlorine residual. Check chlorine feed line for blockage, low chlorine

weight.

Many of these alarms are simply issues that must be checked and require minor

adjustments. However, certain alarms require immediate response. These alarms

constitute emergency conditions.

5. Emergency. Emergency conditions require immediate response. Specific actions to

be taken are provided in Appendix F. Note that as a condition of its permit to

dispense water, the City is required to have an emergency operating plan. A copy

of this plan is maintained in the Water Department offices. Conditions that

constitute an emergency are:

a. Gaseous chlorine release

b. Well pump failure

c. Electrical outage

d. Contact tank high-high level alarm

6. Shutdown. As with Startup, the operator must go through a specified shutdown

sequence. These steps are provided in Appendix G.

6


According to Missouri regulations (10 CSR 60), the system must have a current valid

operating permit to dispense water, and be operated by a Class D Certified water operator.

Licenses must be maintained and visibly posted at the well. The City of Sullivan is

responsible for maintaining both the operating permit and providing licensed operators.

2.01.02 Maintenance

Maintenance of the system can be divided into two types: preventative (routine) and

responsive (repair). Preventative maintenance is typically performed on a schedule and is

done to prevent failure or damage from occurring. Typical preventative maintenance

activities are lubricating motors or other moving parts, changing oil, and cleaning the trays

on the air stripper. Preventative maintenance activities are identified in the system manuals

located in the COS-2 well house. The City of Sullivan is responsible for performing

preventative maintenance on the treatment system.

Responsive or repair maintenance is typically performed as a result of a failure of a piece of

equipment, or in response to an alarm condition. Again, the system manuals located at COS-

2 provide detailed information regarding procedures for troubleshooting specific pieces of

equipment. A contact information sheet for the ordering of replacement parts is provided in

Appendix H.

2.01.02 Record Keeping Procedures

All operating measurements and maintenance records shall be prepared and

maintained by the City of Sullivan, with the exception of the COC sampling and analytical

data, which will be done by TRW. These City of Sullivan records are kept at the COS 3 well

house office for a minimum of three years. An example operating records checklist is

provided as Appendix A. An example maintenance records checklist is provided as Appendix

B.

7


SECTION 3 – GROUNDWATER MONITORING PLAN

A network of 42 monitoring wells, nine municipal potable water supply wells, and six

private wells are periodically monitored under the criteria spelled out in the GMP. TRW

coordinates with the City on access to the municipal wells as well as traffic control while

sampling wells in road right-of-ways, and repair of well boxes. Sampling of the monitoring

wells and private wells are coordinated with the third party owners of the property where

those wells are located. Additional operation, maintenance, security, monitoring, and

notification criteria and procedures are detailed in Table 1.

SECTION 4 – INSTITUTIONAL CONTROLS

4.01 Water Well Installation Controls

Institutional controls will be reviewed annually with the City. Controls include

Sections 705.040 of the City of Sullivan Municipal Code which states no one “shall erect,

construct or drill a water well within the limits of the City of Sullivan, Missouri.”

4.02 Property Use Restrictions

Sister Property, Inc. and Sullivan Warehousing, Inc. shall record an environmental

covenant in the chain-of-title for the Facility property that includes appropriate property-

specific use restrictions. This environmental covenant shall incorporate by reference the

well installation prohibition contained in Article I, Section 705.040 of the Municipal Code

of the City of Sullivan, the existing property use restriction associated with closure of the

former surface impoundment, the “inaccessible soils” restriction, and any other current

property-specific use restriction(s) established pursuant to state law/regulation and/or the

Municipal Code of the City of Sullivan. This environmental covenant shall include

provisions requiring that Sister Properties, Inc. and/or Sullivan Warehousing, Inc. routinely

verify the status of Article I, Section 705.040 of the Municipal Code of the City of Sullivan

8


and notify the Department in a timely fashion of any proposed (or actual) changes to this

ordinance. Documentation verifying compliance with the environmental covenant for the

previous calendar year shall be submitted on an annual basis no later than January 31.

Details of required language for the compliance document are provided in the

environmental covenant. The environmental covenant shall be in a form that complies

with §§ 260.1000-260.1039, RSMo. The Department will review, respond to and/or

approve the draft covenant language in accordance with Section VIII (Review and

Approval Procedures). The approved environmental covenant shall be recorded by Sister,

Properties, Inc. and Sullivan Warehousing, Inc. in the property chain-of-title at the Franklin

County Recorder’s Office within 30 days of final execution (signature by all parties). A

copy of the environmental covenant and proof of filing from the Franklin County

Recorder’s Office shall be provided to TRW and the Department within 30 days of

recording. The draft environmental covenant is been included as Attachment F to the

Order.

SECTION 5 – CLOSED SURFACE IMPOUNDMENTS

Annual inspection, maintenance, and financial assurance of the closed Ramsey

surface impoundments shall be submitted to both City of Sullivan and MDNR. Additional

detail is provided in Table 1.

SECTION 6 – CITY OF SULLIVAN AND OTHER THIRD PARTY

NOTIFICATIONS

TRW shall notify and/or consult as appropriate with the City of Sullivan and/or Ace

Manufacturing and Parts Co. et, al, on proposed activities and other project matters related to

their property and operations. Additional notification criteria and procedures are detailed in

Table 1.

9


SECTION 7 – MEETINGS BETWEEN TRW AND CITY OF SULLIVAN

TRW and City of Sullivan will attend an Annual Meeting to verify, discuss and

update mutual aspects of the LTSP. The 1st Annual Meeting will be held within 30 days of

the Order being signed and annually thereafter within 30 days of the anniversary date of the

signing of this Consent Order. TRW will coordinate with the City Administrator to establish

a date and time for the Annual Meeting. Following the Annual Meeting, a draft Letter of

Understanding (included as Appendix I to this LTSP) will be prepared by TRW for review

and approval by City of Sullivan. This letter will attest to the Annual Meeting taking place

and to both TRW and the City agreeing to perform the procedures and tasks described in the

LTSP. The mutually signed finalized letter will then be submitted to MDNR. Given the

dynamic nature of the LTSP, any updates or revisions to the LTSP will be made at the annual

meeting. The revised LTSP will then be attached to the subsequent Letter of Understanding.

When requested, TRW will also attend meetings of the City of Sullivan Board of

Aldermen to answer questions related to implementation of the Work Plans and the LTSP.

Communications between TRW and City of Sullivan will be tracked. Table 3 is the Standard

Log used by the TRW Facility Operator to track communication between TRW and City of

Sullivan.

SECTION 8 – CONTACT LISTS

Table 4 presents a list of contacts for both the City of Sullivan and TRW. The lines

of communication between the City and TRW are spelled out in the CMI, and are represented

by the attached Figure 1. This list will be updated at the Annual Meeting.

Table 1

Source Procedure Responsible Party Frequency Recordkeeping Location of Records Reporting and Verification

Operation - collection of operating records

COS Water Operator - Gary Hecht

Daily COS 2 Operating Records Checklist (Ref; CMI Table 2), attached as Appendix A to LTSP.

Operating Record Checklist will be kept by COS at COS-3 wellhouse for a minimum of 3 years.

Review at annual meeting.

Operation - assessment of whether pumped volume meets minimum guidelines

TRW Facility Operator - Roy Tiefenbrunn

Monthly Standard Log. Ramsey Treatment Building Notification by email to TRW management, review at annual meeting.

Operation - significant downtime COS Water Operator - Gary Hecht

COS will provide this information as soon as it is known.

COS Water Operator - Bob Hahn reports to TRW Facility Operator - Roy Tiefenbrunn. Roy Tiefenbrunn records in Standard Log.

Ramsey Treatment Building TRW Facility Operator - Roy Tiefenbrunn will submit email notification to ARCADIS-John Shonfelt of reason for downtime and expected duration. Roy also emails John with information on when COS-2 and/or treatment system comes back on line. Review at annual meeting.

Operation - Purchase of Gas Chlorine and payment of utilities

COS Water Operator - Gary Hecht, TRW Project Manager -Troy Sclafani

As needed Purchase Orders recorded in Operating Record Checklist- Notes. Payment records - in TRW internal accounting

Purchase Orders: COS-3. Payment records: TRW corporate headquarters.

TRW Project Manager -Troy Sclafani verifies payments monthly. Review at annual meeting.

Operation - Treatment system effluent analytical results


Monthly Transmittal letter with laboratory report.

Copy at Ramsey Treatment Building.

TRW Project Manager - Troy Sclafani receives copy of letter. Review at annual meeting.

Operation - Training TRW Consultant Engineering Manager -Bret Overholtzer

Annually, or as needed Training log COS-3 Letter to COS documenting persons trained, areas of training. Review at annual meeting.

Operation - Equipment Manuals COS Water Operator - Gary Hecht

As needed As received, or as changes made

COS-2 Review at annual meeting.

Maintenance - Modifications and repairs

COS Water Commisioner - Tom Harman

As event occurs COS 2 Maintenance Records Checklist (Ref; CMI Table 3), attached at Appendix B to LTSP.

Maintenance Records Checklist will be kept by COS at COS-3 wellhouse for a minimum of 3 years.

Review at annual meeting.

Groundwater Monitoring PlanNotification to COS of COS Well sampling and monitoring well sampling.


Seven days prior to planned sampling event.

Standard Log. Ramsey Treatment Building Review at annual meeting.

Monitoring Well Access - Notification to COS of damage to road/wellhead and repairs needed.


As neccesary Standard Log. Ramsey Treatment Building Review at annual meeting.

Private Well Access- Notification to Owners


As neccesary Standard Log. Ramsey Treatment Building Review at annual meeting.

Reporting of Results to COS TRW Consultant Project Manager - John Shonfelt

Quarterly as part of the groundwater monitoring report

Copies of transmittal letter ARCADIS-Indianapolis Review at annual meeting.

New Well Installation - Notification to COS

TRW Consultant Project Manager - John Shonfelt

30 days prior to installation Letter of Notification ARCADIS-Indianapolis Review at annual meeting.

Old Well Abandonment - Notification to COS

TRW Consultant Project Manager - John Shonfelt

30 days prior to abandonment Letter of Notification ARCADIS-Indianapolis Review at annual meeting.

Purge Water Disposal Request to COS


Quarterly Letter requesting permission to discharge

Ramsey Treatment Building Review at annual meeting.

Municipal Code 704.040 Compliance

COS Building Inspector - Dan King

As necessary City Public Records on variances and violations

COS City Hall. Review at annual meeting.

Environmental Covenant Sister Property and Sullivan Warehousing

one time City Public Records COS City Hall. Document to be recorded

Annual Coordination Meeting TRW Project Manager - Troy Sclafani

Annually, in May Meeting minutes ARCADIS-Indianapolis Letter of Understanding

Board of Aldermen Meeting TRW Project Manager - Troy Sclafani

Annually, in May Meeting minutes ARCADIS-Indianapolis Letter of Understanding

Contact Lists TRW Consultant Project Manager - John Shonfelt

Annually Meeting minutes ARCADIS-Indianapolis Letter of Understanding

Site Inspection and maintenance required to maintain integrity of cap


Monthly Facility Inspection Record and Checklist

Ramsey Treatment Building Review at time of annual meeting

Update Post Closure Cost Estimate

TRW Project Manager - Troy Sclafani

Annually in January Copy of Estimate Ramsey Treatment Building Confirm in attachment to Letter of Understanding

Satisfy financial assurance requirements in 40 CFR 265.145


Annually Copy of Paid Invoice for Surety Premium and copy of Standby Trust Agreement

Records kept by TRW at Corporate offices in Livonia, MI.

Confirm in attachment to Letter of Understanding

Closed Surface Impoundments (through 2023)

Institutional Controls

Coordination ListsFormer TRW FacilitySullivan, Missouri

City of Sullivan (COS) Well No. 2 and Treatment System

2016 LTSP Tables 1_3_4.xlsTable 1 Coordination List Page 1 of 2 3/17/2016

Table 1

Source Procedure Responsible Party Frequency Recordkeeping Location of Records Reporting and Verification

Coordination ListsFormer TRW FacilitySullivan, Missouri

Notify and/or consult with Ace Manufacturing and Parts Co. et a) on proposed activities and other project matters related to their property and operations.


As event occurs Direct contact by phone or email, or copied on other official correspondence

Records kept initially by the TRW PM then by TRW at Corporate offices in Livonia, MI.

Review at time of annual meeting

Notify and/or consult with City of Sullivan Officials on proposed activities and other project matters related to their property and operations.


As event occurs Direct contact by phone or email, or copied on other official correspondence

Records kept initially by the TRW PM then by TRW at Corporate offices in Livonia, MI.

Review at time of annual meeting

Meet with the owners of the former TRW Facility (Sister Property Group) to assess whether any physical changes have occurred to or within the on-site buildings (demolition, floor removal, excavation, etc.) that could result in access to subsurface soil.


Annually in May Meeting minutes Records kept initially by the TRW PM then by TRW at Corporate offices in Livonia, MI.

Confirm in attachment to Letter of Understanding

COS and Other Third Party Notifications

2016 LTSP Tables 1_3_4.xlsTable 1 Coordination List Page 2 of 2 3/17/2016

Table 2. COS-2 Groundwater Recovery and Treatment System Key Components List Former TRW, Inc. Facility300 Ramsey St., Sullivan, MO

Part Designation Description / Specifications Operation Information Maintenance InformationP-1 COS-2 Well Pump Running at ~280 gpm, Max. ~400 gpm None

Motor: Model # 2366186025 Intake set @ 483-feet bgsSerial # 03G19-08-0033Manufacturer: Franklin Discharge Piping:OD: 6-Inches 4-inch galvanized steel50 Hp, 480v 3-Phase at 3,450 RPMs Check Valves @ 231-feet & 462-feet bgsAmps: 66, 63, 66

Pump: 230S500-14Manufacturer: GrundfosStainless Steel Submersible - 14 Stage TurbineOD: 6-inches Owner's Manual located at COS-3 building14 Stage, 240 gpm @ 580 td/h @ 3,525 RPMs

ED-1 Eductor: Mixes ambient air with groundwater. Clean as needed.Manufacturer: MazzeiO.D. 4-inches

AS-1 Blower: Forces air through stripper. Lubricate motor as recommended by Manufacturer: American manufacturer, information provided by tag 1,800 cfm @ 18-inches water column Air Damper - Controls volume of air flow through the attached to motor. Otherwise - Annually.15 Hp, 460v 3-phase @ 3,450 RPM stripper. Should only be set with a recently cleaned Inlet: 8-inches air-stripper. Belts - If squealing at start-up belts need to be Outlet: 6-inches tightened. Belts showing signs of wear

should be replaced. When replacing belts all should be replaced simultaneously.

Owner's Manual located at COS-3 buildingAir- Stripper: Designed Flow Rate: 275 gpm with a Max of 300 gpm Pressure wash and clean on a monthly to as Manufacturer: NEEP Systems Maximum high water flow design of 425 gpm needed basis. Shallow Tray Air Stripper System Groundwater flows horizontally across while air is Serial #: 31231-04-5398 blown upward through the water thus aerating the Owner's Manual located at COS-3 building

water and stripping off VOCs.Air Pressure Gauge: Measures differential pressure between Keep clean and perform periodic opening andDwyer Magnahelic Series 200 atmospheric and air-stripper in inches of water. closing of the vent drain plug to dislodgeRange: 0-30-inches wc Remember to record pressure readings. any possible unwanted deposits.

Owner's Manual located at COS-3 buildingE1 Chlorination Injection System: Detects gas leaks as soon as they occur. Periodic Calibration per owners' manual

Chlorine/Sulphur Dioxide Gas Detector: Green or Yellow LED readings = No or Low CL GasManufacturer: Regal being below 1 ppm.Model: Series 3000 Amber LED = Warning Indicator with an audible Reads 0 - 10 ppm CL Gas alarm. Owner's Manual located at COS-3 buildingLED and Audible Alarms Red LED = Danger Indicator - CL Gas > 3 ppm.

Periodic Calibration per owners' manualChlorine Dual Cylinder Scale: For use with 150 lbs Chlorine gas Cylinders, Manufacturer: Regal that are equal to or less than 12" in diameter.Model: SC401 Weighs cylinders independently.Resolution of 1 lb.Capacity of 300 lbs with a safe overload Owner's Manual located at COS-3 buildingcapacity of 400 lbs.

Chlorine Injector: Injects chlorine into water for disinfection. Scheduled Maintenance every year or on an asManufacturer: Regal Automatically switches cylinders when empty. needed basis by system operator.Model: 216Vacuum type injectorRated up to 500 ppd maximum Owner's Manual located at COS-3 building

CB-1 Chlorination Contact Basin: Allows for required 15 minutes of water disinfection Pressure wash and clean on a monthly to as 2,500 gallon sub-grade chlorine contact basin time prior to introduction to first receptor. needed basis.

Page 1 of 2

Table 2. COS-2 Groundwater Recovery and Treatment System Key Components List Former TRW, Inc. Facility300 Ramsey St., Sullivan, MO

Part Designation Description / Specifications Operation Information Maintenance InformationP-2 Vertical Sump Pump: Pumps water from contact basin into distribution None

Motor: network.Manufacturer: US Motor25 Hp, 460v 3-phase @ 3,525 RPMs Discharge Piping:

6-inch galvanized steelPump Manufacturer: J-LineModel: 8LC2-StageInlet: 9.25" O.D. Bell SuctionOutlet: 6" O.D. Owner's Manual located at COS-3 buildingRated @ 275 gpm @ 95 psi @ 226 tdh

FL-1 Fluorine Injection Regulator Injects fluorine into water supply. Replace fluorine and clean on an as needed basis by system operator or coordinated with manufacturer.

CLA-1 Chlorine Analyzer Monitors Chlorine Concentrations in Discharge Periodic replacement of charts, cleaning

Page 2 of 2

Table 3Standard LogFormer TRW FacilitySullivan, Missouri

Date Initials Contacted By Subject Resolution

Page 1 of 1 3/25/2014

Table 4

Affiliation Name Project Title Position Address Phone Alternative phone fax emailTRW Robert Bleazard Program Manager Sr. HS&E Manager -

Environmental Remediation

11202 E Germann Rd Mesa, AZ 85212

(480) 722-4866 (480) 600-8036 (480) 722-4618 [email protected]

Troy Sclafani Project Manager Arcadis (248) 994-2288 (248) 672-7837 NA [email protected]

Roy Tiefenbrunn TRW Facility Operator RNJ, LLC (573) 468-6205 (314) 406-4923 NA [email protected]

Don Butler TRW Assistant Facility Operator

Self Employed

28550 Cabot Drive, Suite 500, Novi, MI 48377630 Grandview, Sullivan, MO 63080423 Windridge Estates Drive, Sullivan, MO 63080 (573) 468-5318 NA [email protected]

John Shonfelt TRW Consultant -Project Manager

ARCADIS /Principal/Certified Project Manager

ARCADIS, 8725 Rosehill, Suite 350 Lenexa, KS 66215

(913) 998-6911 (913) 522-7842 (913) 492-0902 [email protected]

Bret Overholtzer TRW Consultant -Engineering Manager

ARCADIS /Senior Engineer ARCADIS, 8725 Rosehill,

Suite 350 Lenexa, KS 66215

(913) 492-0900 (913) 488-9957 (913) 492-0902 [email protected]

Matt Johnston TRW Consultant -Project Geologist

ARCADIS/ Geologist

ARCADIS, 132 East Washington Street, Suite 600 Indianapolis, IN 46204

(317) 231-6500 (317)-409-8242 (317) 231-6514 [email protected]

Edward Mason TRW Consultant -Database Manager

ARCADIS/ Scientist ARCADIS, 6723 Towpath Road, Syracuse, NY 13214

(315) 671-9506 (315) 447-0223 (315) 446-9120 [email protected]

Jennifer Singer TRW Consultant - Data Validation

ARCADIS/ Chemist

ARCADIS, 50 Fountain Plaza, Suite 600, Buffalo, NY 14202

(716) 667-6664 (716) 667-0279 (716) 667-0279 [email protected]

Wes Kuhn TRW Consultant - Field Sampling

ARCADIS /Geologist

ARCADIS, 132 East Washington Street, Suite 600 Indianapolis, IN 46204

(317) 231-6500 (317) 372-4903 (317) 231-6514 [email protected]

Denise Pohl TRW Consultant - Laboratory Manager

Test America / Lab Manager

Test America North Canton,4101 Shuffel Drive, NW, North Canton, OH 44720

(330) 497-9396 (330)966-9789 (330) 497-0772 [email protected]

City of Sullivan Jim Schatz Mayor City of Sullivan 210 West Washington, Sullivan, MO 63080

(573) 468-4612 (573) 468-8207

J.T. Hardy City Administrator City of Sullivan 210 West Washington, Sullivan, MO 63080

(573) 468-4612 (573) 468-8207 [email protected]

Robert Schaffer City Engineer City of Sullivan 210 West Washington, Sullivan, MO 63080

(573) 468-8965 (573) 216-1527

Tom Harman Water Comissioner City of Sullivan 210 West Washington, Sullivan, MO 63080

(573) 468-4812 (314) 691-0248 (573) 860-3529

Gary Hecht Water Operator City of Sullivan 248 East Springfield Rd, Sullivan, MO 63080

(573) 468-4812 (573) 860-3529

Randy Counts Police Chief City of Sullivan 106 Progress Drive (573) 468-8001

Larry CuneioStreet Commissioner City of Sullivan 345 North Church Street,

Sullivan, MO (573) 468-4912

Dan King Building Commissioner City of Sullivan 210 West Washington, Sullivan, MO 63080

(573) 468-8965

Ace Manufacturing and Parts Co.

Kevin Ijames Project Contact Ace Manufacturing 300 Ramsey Street, Sullivan MO 63080

(573) 468-4181 [email protected]

Contact List

Sullivan, MissouriFormer TRW Facility

3/17/2016

Figure 1. COS-2 Organization and Decision Flow ChartFormer TRW Facility

Sullivan, Missouri

COS-2

Mr. J.T. Hardy

City Administrator

City of Sullivan, MO

Mr. Tom Harman

City Water Commissioner


Mr. Gary Hecht

Water Operator


Mr. Roy E. Tiefenbrunn

TRW Facility Operator

RNJ L.L.C.

Mr. Bret Overholtzer, P.E.

Engineering Manager

ARCADIS

Mr. Troy Sclafani

Project Manager

Arcadis

Mr. Robert Bleazard, P.E.

Program Manager

TRW Automotive, Inc.

Appendix A

COS-2 Operating Records Checklist

Appendix A OPERATING RECORDS CHECKLIST

City of Sullivan Well #2 (COS-2) Treatment System, Sullivan, Missouri Month: County: Franklin PWS ID#: 6010775 Date Time Operator

Initials Meter reading (1000 gal)

Water Treated (1000 gal)

Residual Chlorine, mg/l

Fluoride Dosage Test mg/l Air Pressure (psi)

Notes

Previous Reading

Free Total Reading Amt Used: lbs

Calculated mg/L

P.O.E Dist.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Appendix B

COS-2 Maintenance Record Checklist

Appendix B

MAINTENANCE RECORD CHECKLIST City of Sullivan Well #2 (COS-2) Treatment System

Sullivan, Missouri

Date of Inspection: __________/___________/_____________ Operator Name: ____________________________________________________________ 1.0 Building (as needed) ______1. Outside air vent blower operating properly. Notes: ________________________ ______2. Remediation Building condition (lights, roof, exterior) Notes: ______________________ If not, what needs repaired ____________________________________________________ ______3. Heater operating properly? Notes: __________________________________ 2.0 Air Stripping Trays (once per year or as needed) ______1. Did you inspect the Air Stripper Trays? Notes: _______ _____ ____ ______2. Do all pressure/vacuum and temperature gauges appear to be registering properly? ______3. Was demister cleaned (subcontractor)? Notes: ______________________________ 3.0 Chlorine Contact Tank (once per year or as needed) ______1. Did you inspect/clean the Equalization Tank? Notes: _______________________ 4.0 Blower (see below) ______1. General blower condition – excessive noise, vibration, overheating (daily) Notes: ________ ______2. Percentage is the blower damper open? _______%. Notes: _____________________ ______3. Lubrication Notes: _ ________ Fan Bearings (grease as needed) Notes:____________________________________ Motor Bearings (annual)Notes: _________________________________________ Pillow Blocks? Notes: ________________________________________________ ______4. V-Belt (as needed) Notes: _ _______________ 5.0 Chlorine Injector System Injector (annual) ______1. Check Valve Clean/repair Notes: ________________ ______2. Ejector nozzle cleaning/inspection Notes: ________________ ______3. Manual rate adjustment valve cleaning Notes: ________________ ______4. Safety shutoff valve plug and seat cleaning Notes: ________________ Analyzer ______1. Reagent replenishment (as needed) Notes: ________________ ______2. Pump tubing (6 months) Notes: ________________ ______3. Fuse replacement (as needed) Notes: ________________ ______4. Clorimeter cleaning (as needed) Notes: ________________ ______5. Sample conditioning Filter (as needed) Notes: ________________ Page 1 of 2

6.0 Pumps Well Pump None normally Discharge pump ______1. Lubrication (as needed) Notes: ________________ ______2. Tighten/Repair Packing (as needed) Notes: ________________ 7.0 Instrumentation Influent Flowmeter ______1. Calibration (as needed) Notes: _____________________________________ Gas Cylinder Scale ______1. Calibration (as needed) Notes: _____________________________________ Residual Chlorine Analyzer ______1. Service/Calibration (1/year) Notes: _____________________________________ ______2. Ink and chart replacement (as needed) Notes: ______________________ Effluent Flowmeter ______1. Calibration (1/year) Notes: _____________________________________ 8.0 Alarms System Alarm Check OK chlorine gas detector Contact basin low level alarm Contact basin high level alarm Contact Basin high-high alarm 9.0 Health and Safety ______1. Is fire extinguisher properly mounted in the equipment shelter?________ ______2. Does the extinguisher need charged or serviced?___________ ______3. When does the extinguisher certification expire?______________ (If removing extinguisher for

service or recertification, make sure another charged, certified unit is left in its place.) ______4. Are the following documents displayed and easily accessible? _____Material Safety Data Sheets _____Hazardous Communication Program Manual ______5. Is the First Aid Kit available, either in well house or in truck?_______ ______6. Is the First Aid Kit properly stocked?_________ List any items that need replenished ______7. Is the SCBA complete?_________ List any items that need replenished Air pressure (psi) reading on tank: Miscellaneous Inspection and O&M Notes: ______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________ Page 2 of 2

Appendix C

COS-2 Start Up Procedures

COS-2 Remediation System Start-Up Procedures City of Sullivan, Missouri, Municipal Well #2 (COS-2)

A. Empty Contact Basin Start Up Procedures

1. Refer to turbidity meter section prior to start up (Section C). 2. Connect water supply from the city water hose bib to the hose connection at the

chlorine gas chlorinator with a water hose. Turn on the city water. Open valve # 35.

3. Turn on the electricity at the air-stripper electrical panel and set it on automatic.

4. Turn the well pump to manual mode and turn on the electricity. Verify the

municipal well and air stripper start automatically.

5. Turn on the electricity to ABB liquid level controller and Toshiba variable frequency drive units. Set the ABB control switch to automatic mode and the set point (contact basin level) at 6.5 feet.

6. On the exit piping from the air- stripper, open butterfly valve # 37. This will

allow water to flow into the contact basin. Be sure to check that the bypass valve #36 to the floor drain is closed.

7. Open the butterfly valve #29 in the discharge piping in line from the pump. This

allows water to be pumped into the city distribution system. Be sure to check that the bypass valve #30 to the drain is closed. Butterfly valve #29 will require some adjustment once the system has been on line long enough for the contact basin to fill. The proper adjustment is necessary so that water is being removed from the contact basin at the same rate that it is being discharged into it. This will allow the pump to operate at a constant speed rather than varying the rate in an effort to maintain a consistent level in the contact basin.

8. When the contact basin reaches its operating level, the contact basin pump will be

energized and water will be discharged into the city distribution system. When the pump starts, disconnect the hose from valve #35 and then close the valve. Immediately open valves #31 and #34 in the pump discharge line which supplies water to the chlorinator. This will maintain the vacuum required to inject chlorine gas into the system.

9. Open valve #42 in the treated water discharge line to supply a water sample to the

Hach chlorine analyzer.

B. Start-up Procedures when the Contact Basin Level is Adequate for discharge pump to automatically energize

1. Refer to turbidity meter section prior to start up (Section C).

2. Set the chlorine feed rate valve at the desired rate at 2 1/2 to 3 lbs per 24 hours.

3. Turn on the electricity at the air-stripper electrical panel and set it on automatic.

4. Turn the well pump to manual mode and turn on the electricity. Verify the municipal well and air stripper start automatically.

5. Turn on the electricity to ABB liquid level controller and Toshiba variable

frequency drive units, if necessary. Set the ABB control switch to automatic mode and the set point (contact basin level) at 6.5 feet.

6. On the exit piping from the air-stripper, open butterfly valve # 37. This will allow

water to flow into the contact basin. Be sure to check that the bypass valve #36 to the floor drain is closed.

7. If necessary, open the butterfly valve #29 in the discharge piping in line from the

pump. This allows water to be pumped into the city distribution system. Be sure to check that the bypass valve #30 to the drain is closed.

8. Immediately open valves #31 and #34 in the pump discharge line which supplies

water to the chlorinator. This will maintain the vacuum required to inject chlorine gas into the system.

9. Open valve #42 in the treated water discharge line to supply a water sample to the

Hach chlorine analyzer.

C. Turbidity Meter Flushing Procedures These steps are to be followed following a high turbidity shutdown. They may also need to be used during normal start up procedures.

1. While system is shutdown, clean the turbidity meter chamber and eyes to eliminate having an unnecessary system shutdown because of dirt in the chamber.

2. Close valves #8 and #13. Then open valve #14.

3. Hard flush the meter with valve #19 through the turbidity meter to clear any

residual turbidity being measured by the meter.

4. Start the well and allow it to run for approximately one hour.

5. Open valve #13.

6. Open the well side of the faucet to flush the lines with a high flow rate.

7. Open valve #8 and allow for two minutes of flush time.

8. Close valve #14.

9. Observe the turbidity level readings, if it reaches a high enough level to shut off the well, open valve #14 immediately and close valve #13.

10. The well should restart in three to four minutes. When the turbidity stabilizes

repeat steps 2 through 9 until the turbidity level is low enough to continually operate the well.

11. When the well is operating satisfactorily be certain all valves are in normal

operating positions for well operation. Note: the above information is to serve as routine start-up procedures only. For trouble-shooting, refer to the system manuals.

Appendix D

COS-2 Normal Operation Instructions

Normal Operation Instructions City of Sullivan, Missouri, Municipal Well #2 (COS-2)

Remediation System The purpose of this manual is to provide routine O&M guidelines for the system operator of the Former COS-2 (Air-Stripper). This information is to serve as a summary to the O&M information provided by the manufactures recommended O&M activities for the components used in the system. A. Procedures when the Contact Basin Level is Adequate for discharge pump to

automatically energize.

1. Refer to turbidity meter section prior to start up (Section B). 2. Set the chlorine feed rate valve at the desired rate at 2 1/2 to 3 lbs per 24 hours. 3. Turn on the electricity at the air-stripper electrical panel and set it on automatic. 4. Turn the well pump to manual mode and turn on the electricity. Verify the

municipal well and air stripper start automatically. 5. Turn on the electricity to ABB liquid level controller and Toshiba variable

frequency drive units, if necessary. Set the ABB control switch to automatic mode and the set point (contact basin level) at 6.5 feet.

6. On the exit piping from the air- stripper, open butterfly valve # 37. This will allow water to flow into the contact basin. Be sure to check that the bypass valve #36 to the floor drain is closed.

7. If necessary, open the butterfly valve #29 in the discharge piping in line from the pump. This allows water to be pumped into the city distribution system. Be sure to check that the bypass valve #30 to the drain is closed.

8. Immediately open valves #31 and #34 in the pump discharge line which supplies water to the chlorinator. This will maintain the vacuum required to inject chlorine gas into the system.

9. Open valve #42 in the treated water discharge line to supply a water sample to the Hach chlorine analyzer.

B. Turbidity Meter Flushing Procedures These steps are to be followed as needed during normal operation procedures.

1. While system is shutdown, clean the turbidity meter chamber and eyes to eliminate having an unnecessary system shutdown because of dirt in the chamber.

2. Close valves #8 and #13.

3. Open valve #14.

4. Hard flush the meter with valve #19 through the turbidity meter to clear any residual turbidity being measured by the meter.

5. Start the well and allow it to run for approximately one hour.

6. Open valve #13.

7. Open the well side of the faucet to flush the lines with a high flow rate.

8. Open valve #8 and allow for two minutes of flush time.

9. Close valve #14.

10. Observe the turbidity level readings, if it reaches a high enough level to shut off

the well, open valve #14 immediately and close valve #13.

11. The well should restart in three to four minutes. When the turbidity stabilizes repeat steps 2 through 9 until the turbidity level is low enough to continually operate the well.

12. When the well is operating satisfactorily be certain all valves are in normal

operating positions for well operation.

A. Routine Operation & Maintenance

1. Air-stripper pressure washing - removal of CaCO3 and iron deposit build up - As Needed.

2. Changing of chlorine gas cylinders - When empty - As Needed. 3. Lubrication of motors, pillow blocks, and miscellaneous moving parts - Monthly

or on an As Needed basis. 4. Cleaning the analyzer and replenishing of its reagents - As Needed. 5. Equipment Inspection - Replace on an as needed basis.

Normal Valve Settings

Valve # Description Normal Operating Position

1 Main butterfly valve - to air- stripper (6”) Open 2 Main gate valve - to system (6”) Closed 3 Corp stop - supply to lube line, drinking fountain, hose

bibs & eyewash ¾” Open

4 Ball valve - to lube line (½”) Open 5 Electric solenoid valve - on lube line (½”) Automatic 6 Ball valve - to lube line (½”) Open 7 Ball valve - to lube line by-pass (½”) Closed

8 Ball valve - on main well pipe (½”) Open 9 Ball valve - supply to turbidity meter – well side (½”) Open 10 Ball valve - supply to well side of sink (½”) Open 11 Ball valve - supply from site to sink (¾”) Open 12 Corp stop - supply from system side of well (¾”) Open 13 Ball valve – well side to turbidity meter by – pass loop

(½”) Open

14 Ball valve – system side of turbidity meter by – pass loop (½”)

Closed

15 Ball valve – turbidity feed (½”) Open 16 Electric solenoid – valve to turbidity meter feed (½”) Open 17 Double disk check valve – main pipe (6”) Closed 18 Ball valve – feed at birthday meter (½”) Open 19 Globe valve – throttle (½” ) Open 20 Ball valve – dump from turbidity chamber (½”) Closed 21 Ball valve – discharge from turbidity meter (½") Open 22 Ball valve – supply for chlorine analyzer (½”) Adjustable 23 Ball valve – also supply to analyzer (½”) Open 24 Corp stop – fluoride injection tube (¾”) Open 25 Eye wash station (½”) Closed 26 Ball valve – supply to hose bib & eye wash well house

side (½”) Open

27 Ball valve – supply to hose bib, stripper end (½”) Open 28 Ball valve – to hose bib at system side of well piping (¾”) Open 29 Butterfly valve – air stripper to system discharge (6”) can

also be used as throttle valve Open

30 Gate valve – discharge to daylight (6”) Closed 31 Ball valve – feed for chlorine (¾”) Open 32 Ball valve – not in use (¾”) Closed 33 Ball valve – sample station and gauge (½”) Open 34 Ball valve – chlorine injector (3/4”) Open 35 Ball valve – air stripper discharge to site tube (½”) Closed 36 Ball valve – chlorine feed during startup with hose Closed 37 Butterfly valve – air stripper drain Open 38 Butterfly valve – air stripper discharge to contact basin Open 39 Cone valve – air stripper pressure gauge (1/8”) Open 40 Ball valve – air stripper bottom drain (2”) Closed 41 Blade valve (damper) – air intake to blower Adjustable 42 Ball valve – supply to chlorine analyzer (½”) Open 43 Inlet valve – to electrical solenoid valve (¾”) Open 44 Electrical solenoid valve (¾”) Closed

45 Outlet valve – to electrical solenoid valve (¾”) Open 46 Bypass valve – around solenoid valve (¾”) Closed

Notes: The above information is to serve as routine O&M criteria. The O&M schedule can be modified for better operation of the system but should not be performed less often than recommended by each components O&M manual. Operation times, flow rates and volumes, maintenance descriptions (cleaning, repair, replacement), and samples collection logs will be maintained to track the performance of the system.

Appendix E

COS-2 Alarm Conditions

ALARM CONDITIONSCity of Sullivan Well #2 Treatment System (COS-2)

TRW – Former Ramsey SiteSullivan, Missouri

Alarm Check Alarm Course of Action1. Chlorine gas detector

A. Power LED Solid Green None - Operating NormallyB. Power LED Flashing Unit powered by back-up battery - Reconnect Power source.

None - Operating NormallyAmber LED lights on and Alarm sounding

Indicates a [Cl] between 1 ppm and 2 ppm. Vent room & Locate leak and repair.

2. Chlorine Scale Chlorine supply tank empty Replace container - be sure to shut down regulator for that tank prior to unscrewing.

3. Chlorine Residual - <0.5 or >1.0 ppm Too little or too much chlorine being injected

Check chlorine feed line for blockage, low chlorine weight. Adjust injection rate accordingly.

4. High Air-Stripper Back Pressure Stripper pressure too high - compare to previous readings

Check blower operation, blockage in air line, scale on trays, blockage in stack, and damper setting.

5. Contact BasinA. Contact basin low level alarm Contact basin water level too low Check pumps and valve settings.B. Contact basin high level alarm Contact basin water level getting too high Check basin discharge pumping rate, check pump for blockages

(influent and effluent), and check piping out of basin for blockages.

C. Gas Level Bargraph and Digital Display

Green or Yellow bars & <1.0 displayed

3/17/2016

Appendix F

COS-2 Emergency Actions

EMERGENCY ACTIONSCity of Sullivan Well #2 Treatment System (COS-2)


Alarm Check Alarm Course of Action1. Chlorine gas detector

Indicates a [Cl] above 3 ppm. Evacuate area. Only re-enter with supplied air and ventilation. Locate Leak and repair.

None - Operating Normally

2. Pump Operation Submersible Pump Failure or Contact Basin Pump Failure

Shut system down. Notify the City of Sullivan system operator. Pump repair or replacement.

3. Electrical Power Outage Electrical Power Outage Shut down all system controls. Notify the City of Sullivan system operator. Determine time frame for outage. If outage is expected to last an extended period of time, then portable power should be brought in and the system re-started.

4. High Air-Stripper Back Pressure Stripper pressure too high - compare to previous readings

Check blower operation, blockage in air line, scale on trays, blockage in stack, and damper setting.

5. Contact Basin Contact Basin high-high alarm Contact basin water level too high Check basin discharge pumping rate, check

pump for blockages (influent and effluent), and check piping out of basin for blockages.

Gas Level Bargraph and Digital Display

Red LED lights on and Alarm sounding

3/17/2016

Appendix G

COS-2 Shutdown Procedures

COS-2 Remediation System Shutdown Procedures City of Sullivan, Missouri, Municipal Well #2 (COS-2)

System Shutdown Procedures

1. Turn off electrical controls to the municipal well. The air stripper will automatically shut down after it times out.

2. The power to the liquid level control and variable frequency drive units may be

turned off but is not required. Notes: The above information is to serve as routine shut down procedures only. For trouble shooting, refer to the system manuals.

Appendix H

COS-2 Parts Replacement Information Sheet

Parts Replacement Information SheetCity of Sullivan Well #2 Treatment System (COS-2) and Former Ramsey Remediation System


Repair and Parts Ordering Contact Information:Well

Flynn Drilling Company, Inc.

16705 Doolittle Outer Rd

Rolla, MO 65401

573 341-8444 - Mr. Arphey Lewis

www.flynndrilling.com

Chlorine AnalyzerHach CompanyP.O. Box 389Loveland, Colorado 80539-03891-800-227-4224 970 669-2932 fax - Reggie Harden Ext. 2127www.hach.com

Air StripperNorth East Environmental Products, Inc. (NEEP)7 Commerce AvenueWest Lebanon, NH 03784603-298-7061 603-298-7063 [email protected]

PumpsGrundfos Pumps Corporation U.S.A. 17100 W. 118th Terrace, Olathe, KS 66061913 227-3400 913 227-3500 faxwww.grundfos.com/web/homeus.nsf

ElectricalFranklin Electric Co., Inc. 400 E. Spring St.Bluffton, IN, 46714260.824.2900 260.824.2909 [email protected]

PipingWater Sewer Supply Company2612 Paris RoadColumbia, MO 65202573 474-8473

InstrumentsDwyer Instruments Inc.P.O. Box 373, 102 Indiana Hwy. 212Michigan City, IN 46361 USA219 879-8000 219 872-9057 faxwww.dwyer-inst.com/

Motors, Starters, ControlsSprecher + Schuh North America15910 International Plaza DriveHouston, TX 77032281 442-9000 281 442-1570 faxwww.ssusa.cc/pages/mainpg/contctmainall.html

Appendix I

Draft Letter of Understanding Between TRW and COS

<Date> Mr. Richard Nussbaum, P.E., R.G. Chief, Permits Section Hazardous Waste Program Division of Environmental Quality Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Re: Former TRW Facility, Sullivan, Missouri

EPA ID#MOD094390416 Letter of Understanding between TRW and City of Sullivan Dear Mr. Nussbaum: Pursuant to our meetings and further discussion with MDNR, this letter documents the City of Sullivan’s (COS’s) agreement to certain provisions of the Groundwater Monitoring Plan (GMP), Drinking Water Contingency Plan (DWCP), Corrective Measures Implementation Plan (CMI), and Long Term Stewardship Plan (LTSP) submitted by TRW on August 24, 2006 pursuant to development of a Corrective Action Abatement Order on Consent (Consent Order).

1. In Section 3.03 of the GMP, TRW has proposed the following procedure if a municipal well quarterly sample exceeds 4.0 ppb:

An evaluation to determine whether TRW is the source of the TCE If the evaluation shows TRW is responsible, monitoring will increase to a

monthly frequency. If the evaluation shows TRW is not responsible, monitoring will continue

to be performed per the normal GMP schedule. Until the evaluation is completed, monitoring will be performed per the

normal GMP schedule.

COS agrees that this is an acceptable approach. 2. Attachment A, Supplement C, (Municipal Well Sampling Protocol) of the GMP

requires municipal wells that have been inactive for a period of time to be purged (pumped) for 30 minutes prior to sampling.

COS agrees that this is an acceptable approach.

3. Section 2.05 of the DWCP describes implementation, timing of implementation,

further sampling and analysis, and decision points for when a municipal well exceeds the Groundwater Protection Standards (GPS). It includes provisions for three confirmation samples when the GPS is exceeded, and also calls for Long-

Term Persistence sampling if historical analytical results indicates a short term anomaly or that levels may not be expected to persist above the GPS level.

COS agrees that the procedures described in Section 2.05 are an acceptable approach.

4. Regarding Section 3.03 of the DWCP, TRW will use 1.0 ppb TCE as a design

effluent goal from a treatment system, and will undertake efforts to address a result greater than this goal in coordination with the City of Sullivan within seven days.

COS agrees that this is an acceptable approach

For TRW Automotive (US) LLC. For City of Sullivan, Missouri

Name Name Printed Name Printed Name Title Title Date Date

long term stewardship plan former trw facility sullivan, missouri … · long term stewardship plan...

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