&EPA

United States
Environmental Protection
Agency

We want to hear from you

EPA invites your comments on the
Agency's proposal to change the
cleanup plan at the Dana Corp.
facility in Roscoe. Your input is
important because it helps EPA
determine the best course of action.
Here is how you can submit written
statements during the public
comment period that runs until
midnight Sept. 30, 2010:

•	Fill out and mail the
enclosed comment form by
the deadline.

•	E-mail comments to EPA
Project Manager Christopher
Black at

black .christopher@epa. gov.

•	FAX to Christopher Black at
312-692-2062.

•	Attend the Sept. 15 public
meeting at North Suburban
Library, Roscoe Branch,
5562 Clayton Circle, 5:30-
7:30 p.m.

For general questions about the Dana
cleanup contact:

Rafael P. Gonzalez

EPA Public Affairs Specialist

312-886-0269

gonzalez.rafaelp@epa.gov

For technical questions:

Christopher Black

EPA Project Manager

312-886-1451

black.christopher@epa.gov

Region 5 toll-free: 800-621-8431,

8:30 a.m. - 4:30 p.m., weekdays.

EPA Proposes Changes
To Cleanup Plan	

Dana Corp. Facility (Warner Electric)

Roscoe, Illinois	September 2010

U.S. Environmental Protection Agency Region 5 is proposing several changes
to the long-standing cleanup plan for the Dana Corp. facility in Roscoe in
order to manage the remaining soil and underground water contamination in
and around the site. Proposed changes include phasing out a water treatment
system, installing new soil vapor extraction equipment and encouraging the
growth of pollution-eating microbes. The proposed actions at a cost of
$992,000 are part of a number of changes EPA wants to make to a 1991
cleanup plan for the Dana site, which was formerly known as Warner Electric
Brake and Clutch Co.

EPA conducts cleanup activities at the Dana site under the authority of the
federal Resource Conservation and Recovery Act (RCRA). This plain
language fact sheet summarizes technical information that can be found in a
document called the "statement of basis/'1 Another useful document
containing detailed information about the site is called "Revised Workplan to
Administrative Order on Consent - April 2009." EPA encourages the public
to review these documents in order to gain a better understanding of the
RCRA corrective action activities being conducted at the Dana facility.

The statement of basis proposes the pump-and-treat system that has been
cleaning underground water supplies since 1991 be phased out. Tests show
the underground water ("ground water" in environmental terms) is now
meeting drinking water standards and treatment is no longer needed.
Installation of a soil vapor extraction system at the former plant would reduce
the mass of chlorinated volatile organic compounds (CVOCs) still underneath
the facility and prevent gases from moving into indoor air or ground water.
And EPA also wants to use a cleanup technique called "enhanced
bioremediation" on the remaining pollution on and around the Dana site. In
enhanced bioremediation, living microbes already present are encouraged to
grow and digest the contaminants.

Site history

The Dana facility is located at 5253 McCurry Road in Roscoe and is bounded
by residential property to the north of McCurry Road, by a gravel pit and
agricultural land west of State Route 251, by a railroad to the east, and by
agricultural land and commercial property to the south. The Rock River flows
about 1 mile to the southwest.

The Dana facility began operations in 1957 when Warner Electric fabricated

'EPA may modify the proposed remedy or select another option based on new information
or public comments. All documents supporting the proposed changes are contained in the
administrative record located at the Roscoe Branch Library, 5562 Clayton Circle, Roscoe,
and EPA Region 5 Records Center (7th Floor), 77 W. Jackson Blvd., Chicago.


-------
metal parts for automotive brakes and clutches.

As part of the manufacturing process, metal parts were
machined and degreased using volatile organic
compounds such as trichloroethene (TCE), 1,1,1
trichloroethane (1,1,1TCA), and methylene chloride.
Some of these VOCs were released to the soil where they
seeped into the underground water supplies. The Dana
facility ceased operations in 2004.

Past environmental actions

In 1983 the Illinois State Water Survey and Illinois
Environmental Protection Agency conducted a study of
nitrate levels in Winnebago County. The agencies tested
well water in the Hononegah Estates and Moore Haven
subdivisions in Roscoe and discovered excessive levels
of VOCs, which were traced to the Warner facility. In
1984 Warner Electric agreed to a legal order with the
State of Illinois where it extended municipal water to
Honenegah Country Estates and Moore Haven
subdivisions, cleaned on-site waste lagoons and closed
wastewater ponds.

In 1989, EPA and Dana entered into a RCRA
administrative order on consent where the company
agreed to install a deep water supply well that offers
clean drinking water to residents affected by site
contamination. In addition, a pump-and-treat system for
contaminated ground water was installed in 1991 in the
south end of the Moore Haven subdivision, and the
system has been successful in reducing underground
water contaminants.

Other environmental investigations were conducted on
and around the Dana site in 1992, 2002, 2003, 2005,
2006 and 2008. Besides the ground water and soil
contamination, investigators have been concerned about
the potential for a problem called "vapor intrusion."

Read the documents

Detailed reports and documents supporting
EPA's proposed amended cleanup plan can be
found in the administrative record for the Dana
site available at:

North Suburban Library District
Roscoe Branch
5562 Clayton Circle
Roscoe

VOCs that sit in soil or dissolve in underground water
tend to release hazardous vapors that rise through the soil
to the surface or seep through basement cracks and
contaminate indoor air. To protect residents from vapor
intrusion, soil gas and indoor air sampling were part of
some of the past environmental investigations. Results
indicated vapor intrusion had not become a serious health
concern in and around the Dana facility. Some of the
proposed cleanup changes are to keep the soil gas issue at
the facility under control.

Health risks from the site

Thanks to past cleanup and containment practices,
pollution from the Dana site does not pose an imminent
threat to people's health.

Ground water that starts in the site and flows underneath
residential areas on its way to the Rock River remains
contaminated with volatile organic chemicals. But
residents of Hononegah and Moorehaven subdivisions
and businesses in the area get their drinking water from
the North Park Public Water District, which is not
affected by the Dana pollutants, so people are not
exposed to excessive health risks. Some residents use
their private wells for watering lawns and swimming
pools, but environmental experts say VOC concentrations
are low enough that people will not face adverse health
effects if they have incidental contact with the tainted
ground water.

Health risks from on-site soil contamination and escaping
gas are also low because no one currently works on the
property. The potential for vapor intrusion exists at the
facility. Part of the changes proposed by EPA will
specifically tackle this issue. A 2003 vapor intrusion
study where indoor air samples were taken at several
homes near the Dana facility found no health concerns.

Cleanup changes and options

While considering how to manage remaining
contamination on and around the Dana site, EPA looked
at three cleanup options before picking a preferred route.
The alternatives considered were:

•	No further action. No cost.

•	Continuing the pump-and-treat system and not
addressing the mass of VOCs on the Dana
property. No cost.

•	Installing the soil vapor extraction system/using
enhanced bioremediation/allowing natural
processes to eliminate ground water
pollutants/monitoring the Rock River/imposing
institutional controls on the Dana property/and


-------
requiring financial assurances from Dana to do
the cleanup work. Cost - $992,000

All of the alternatives were compared to nine evaluation
criteria. Cleanup options selected must meet the first four
minimum criteria to be considered further:

1)	Protect human health and the environment.

2)	Attain soil and water contamination levels
that protect human health and the
environment.

3)	Control the sources of hazardous waste.

4)	Comply with applicable standards for waste
management in meeting Safe Drinking Water
Act standards.

Cleanup options that survive the first four criteria
were then checked against five balancing criteria:

1)	Long-term reliability and effectiveness.

2)	Reduction of toxicity, mobility, or volume of
waste.

3)	Short-term effectiveness

4)	Implementability (how easy is it to actually
install the cleanup option).

5)	Cost

The first two options - no action and continued operation
of the pump-and-treat system - failed to meet the four
base criteria so were eliminated from further
consideration. That left Alternative 3.

Details of proposed cleanup changes

Soil Vapor Extraction

Soil Vapor Extraction (SVE) is the removal of soil vapor
from below the surface. A pilot test was conducted on a
SVE system in 2008, and the test showed SVE works
well in extracting TCE and chlorinated compounds from
below the concrete slab at the facility. The SVE system
provides a vacuum on individual extraction points
through the facility floor. The system will be installed in
areas where solvents were used. The SVE will continue
to operate until the remaining soil vapor does not pose an
unacceptable risk to indoor air intrusion, or represent a
source for ground water contamination. It is anticipated it
will take three to five years to reach that soil vapor
cleanup goal.

Enhanced Bioremediation

Enhanced bioremediation means feeding the microbes
that are already degrading the contaminants in the ground
water to enhance their number and effectiveness. The
source of the microbial food is a sugar along with iron,
yeast extract and sodium sulfite. The injections will focus
on the affected ground water near the TCE storage area
on-site as well as other affected areas near the western
end of the facility. Pilot tests of the injections confirm its

effectiveness. Four ground water monitoring wells
downhill from the TCE storage area will be sampled to
insure the effectiveness of this technique. Enhanced
bioremediation will assist Dana in meeting the
intermediate cleanup criteria for ground water that is used
for watering lawns or in swimming pools.

Monitored Natural Attenuation
MNA includes a variety of physical, chemical or
biological processes such as evaporation, dilution and
decay that lower pollution levels. Eleven monitoring
wells will keep track of the natural attenuation process. It
is anticipated with the current contaminant levels and the
water flow rate that in 10 to 20 years drinking water
standards will be reached.

Seep Sampling along the Rock River
The treatment system currently collects and treats the
affected ground water prior to its discharge to the Rock
River. The proposed cleanup changes call for phasing out
the pump and treat system. The ground water enters the
Rock River at several points called "seeps." The seeps
will be sampled for two years during low river levels to
ensure the ground water is meeting cleanup standards.
Institutional Control

An environmental covenant will be implemented on the
Dana facility to restrict on-site ground water use, limit
site use to industrial/commercial activities, and impose
controls on excavation procedures for construction
workers and redevelopment workers in areas posing the
most health risk.

Financial Assurance

Dana will be required to provide financial assurance to
ensure the option can be implemented over its lifetime of
about 20 years. As mentioned above, the estimated cost
of preferred Alternative 3 is $992,000.

Next steps

EPA encourages the public to comment on this proposal
for the Dana Corp. facility. The comment period runs
through Sept. 30.

After reviewing all the comments, EPA will decide
whether Alternative 3 is appropriate and will release a
document called a "Final Decision Response to
Comments." The Final Decision Response to Comments
will be available in the administrative record for the site
kept at the Roscoe Branch Library. A summary of all the
comments received and EPA's responses will be
contained in the Final Decision Response to Comments.


-------
EPA Wants to Make
Changes to the Cleanup Plan

Dana Corp. Facility (formerly Warner Electric)
Roscoe, Illinois

Public Comment Period: Until Sept. 30, 2010

(details inside)

aBueiio dnueeio sesodojd Vd3 = 01*110313 ilSNHVM/AllHOVd VNVQ

06SE-W909 II 'oSbdimd
¦pA|g UOSJper M LL

(rsi-d) sjibjjv aiiqnd jo 33UJQ

S uoiDay

Aou&Bv

uoiios^oJd |e;uauJUOJ!AU3
S3iei$ psiiun

Vd3'os


-------
Use This Space to Write Your Comments

EPA is interested in your comments on the proposed changes to the cleanup plan for the Dana Corp. Facility in
Roscoe, 111. You may use the space below to write your comments and then detach, fold, stamp and mail to EPA
Project Manager Christopher Black. Statements may also be faxed to Chris at 312-692-2062. Comments must be
postmarked by midnight Sept. 30, 2010.

Name	

Affiliation if any
Address	

City

State

ZIP


-------
Dana Corp. Facility (Warner Electric)

fold

fold

Place
First
Class
Postage
Here

Christopher Black

EPA Project Manager

Land and Chemicals Division (LU-9J)

EPA Region 5

77 W. Jackson Blvd.

Chicago, IL 60604-3590


-------