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A. L. TAYLOR (VALLEY OF THE DRUMS) SUPERFUND SITE ... The owner operated an unpermitted waste disposal and drum storage facility at the Site ...
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Table of Contents LIST OF ABBREVIATIONS & ACRONYMS....................................................................... iv I. INTRODUCTION.................. 1 Site Background.......................................................................................................................... ^ FIVE-YEAR REVIEW SUMMARY FORM.................................... 2 II. RESPONSE ACTION SUMMARY .......................................................................................... 3 Basis for Taking Action .............................................................................................................. 2 Response Actions........................................................................................................................ 3 Status of Implementation............................................................................................................ ^ Systems Operations/Operation & Maintenance (O&M)............................. 7 III. PROGRESS SINCE THE LAST REVIEW............................................... .............................. 9 IV. FIVE-YEAR REVIEW PROCESS........................................................................................ 10 Community Notification, Involvement & Site Interviews........................................ 10 Data Review.............................................................................................................................. 11 Site Inspection........................................................................................................................... 12 V. TECHNICAL ASSESSMENT.......... .................................... ................................................. 14 QUESTION A: Is the remedy functioning as intended by the decision documents?....... ....... 14 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?....................... 15 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?................................................................................................... 13 VI. ISSUES/RECOMMENDATIONS .......................................................................................... OTHER FINDINGS.................................................................................................................. 17 VII. PROTECTIVENESS STATEMENT ..................................................................................... 18 VIII. NEXT REVIEW............................................................................................................. 18 APPENDIX A - REFERENCE LIST........................................... A- APPENDIX B - CURRENT SITE STATUS.................................................................................... B-I APPENDIX C - SITE CHRONOLOGY.......................................................................................... C- APPENDIX D - SITE BACKGROUND.......................................................................................... D- APPENDIX E - SITE MAPS.......................................................................................................... E- APPENDIX F - PRESS NOTICE.................................................................................................... F- APPENDIX G - APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) REVIEW....................................................................................................................... G’l APPENDIX H - DATA TABLES ........................................................ H- APPENDIX I - SITE INSPECTION CHECKLIST ............................................................ .............. I-l APPENDIX J - SITE INSPECTION PHOTOS.................................................................... J-
Tables Table I: Parameters for Groundwater and Surface Water Monitoring.................................. ......... 6 Table 2: Summary of Planned and/or Implemented Institutional Controls (ICs)............................ 8 Table 3: O&M Costs over the FYR Period................................................................................... 10 Table 4: Protectiveness Determinations/Statements from the 2013 FYR..................................... 10 Table 5; Status of Recommendations from the 2013 FYR............................................................ 11 Table 6: Site Deed Documents.................................................................................................... 13
LIST OF ABBREVIATIONS AND ACRONYMS
ARAR Applicable or Relevant and Appropriate Requirement ATV All-terrain Vehicle CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CD Consent Decree CFR Code of Federal Regulations CIC Community Involvement Coordinator COC Contaminant of Concern EPA United States Environmental Protection Agency FYR Five-Year Review ICs Institutional Controls KDEP Kentucky Department for Environmental Protection KNREPC Kentucky Natural Resources and Enviroiunental Protection Cabinet MCE Maximum Contaminant Level NA Not Applicable NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PCB Polychlorinated Biphenyls PAH Poly Aromatic Hydrocarbons PRP Potentially Responsible Party RAO Remedial Action Objectives RCRA Resource Conservation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager RSL Regional Screening Level SVOC Semi Volatile Organic Compounds TBC To Be Considered TCLP Toxicity Characteristic Leaching Procedure VOC Volatile Organic Compounds UU/UE Unlimited Use and Unrestricted Exposure
I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.
The United States Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy.
This is the sixth FYR for the A. L. Taylor Superfund site (the Site). The triggering action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).
The Site consists of one Operable Unit (OU), OU1, which is addressed in this FYR.
EPA remedial project manager (RPM) Yvonne Jones led the FYR. Participants included EPA community involvement coordinator (CIC) Angela Miller, EPA site attorney Stedman Southall, EPA Hydrologist Noman Ahsanuzzaman, EPA toxicologist Kevin Koporec, EPA ecological risk assessor Brett Thomas, EPA IC Legal Coordinator Bilal Harris and the Kentucky Department for Environmental Protection (KDEP) Project Manager Shital Jiwane. KDEP conducted the FYR and prepared this report regarding the remedy implemented at the Site. The review began on November 13, 2017. A list of documents reviewed as part of this FYR is included in Appendix A. A summary of the current site status is included in Appendix B.
Site Background
The A.L. Taylor site is a 23-acre site located on Letts Road, directly off Highway 1020, in Brooks, Bullitt County, Kentucky just south of the Jefferson County line (Figure E-1). The Site has 17 acres of wooded, grassy areas and a 6-acre capped landfill enclosed by a security fence. Woods border the Site to the north and west. Several private rural residences and a golf course are located to the south and east of the Site. Wilson Creek is a small stream which runs along the eastern edge of the Site and flows northward into Pond Creek. Pond Creek eventually drains into the Salt River just before the Salt River's confluence with the Ohio River (Figure E-2).
The owner operated an unpermitted waste disposal and drum storage facility at the Site from 1967 until
industries of the Louisville area were the primary waste generators using the Site. Solvent waste from drums was dumped into excavated pits and burned off. The wastes were buried in trenches and thousands of drums were stored on the ground surface during later years of operation. These activities had greatly disturbed the surface features of the Site and resulted in substantial pollution of groundwater, surface water, soils and sediment. The Site caught attention of the KNREPC again in 1975. This was the first time state officials documented releases of hazardous substances from the Site into nearby Wilson Creek. From 1979 till 1981, the EPA and KNREPC conducted emergency removal actions to prevent further releases of oil and hazardous substances. However, a site inspection in 1981 revealed that deteriorating and leaking drums were still discharging contaminants into Wilson Creek. In 1982, erosion at the Site partially exposed a buried drum which indicated that contamination still existed in surface soils.
Between 1979 and 1984, numerous investigations were carried out and analytical data was collected to determine the extent of contamination. Over the course of these investigations, 140 contaminants were identified. The 1984 Feasibility Study Addendum and Endangerment Assessment identified the contaminants found most often and in highest concentrations. These contaminants included: xylene, phthalates, toluene, alkyl benzenes, methyl ethyl ketone, methylene chloride, acetone, anthracene, vinyl chloride, trans-1,2 dichloroethylene, fluoranthene and aliphatic acids. Polychlorinated Biphenyls (PCBs) were found in low concentrations in surface soils and sediments in Wilson Creek. Several metals, including barium, lead, zinc, copper, strontium, magnesium and chromium were detected in soils, surface water and groundwater in concentrations exceeding natural background levels for groundwater but were below National Drinking Water Standards.
The 1984 Feasibility Study Addendum and Endangerment Assessment also discussed human health risk scenarios and evaluated groundwater and surface water as potential routes of exposure to hazardous substances released from the Site. However, neither type of water source appeared to be a likely route of exposure to populations located downstream of surface water routes or downgradient of groundwater movement from the Site. There was little potential for exposure to contaminants in groundwater because most nearby properties were connected to the public water supply. Additionally, the aquifer produced low yields of poor water quality. Surface water, like groundwater was not considered a potential exposure route because it was not a source of drinking water for populations downstream of Wilson Creek. Recreational use of the streams leading from the Site was not documented. However, it was believed to be low or infrequent above the Ohio-Salt river confluence. Another factor limiting future human exposure risks was the limited population growth projected in the vicinity of the Site. Topographic features of the area surrounding the Site made it largely imsuitable for development. The principal environmental impact from the Site was considered to be the discharge of contaminated surface water runoff to Wilson Creek and subsequently downstream. However, the greatest risk of adverse health effects was present for persons entering the Site because of the ease of access to the Site and the high levels of organic chemicals and metals remaining in surface soil, runoff water and in burial pits. Therefore, an effective remedial plan was warranted to mitigate potential adverse impacts on human health, welfare and environment.
Response Actions
At the request of KNREPC, the EPA began the first emergency response action for the Site in 1979. Under the authority of Section 311 of the Clean Water Act, EPA prevented further releases of pollutants into nearby Wilson Creek by constructing interceptor trenches and a temporary water treatment system, securing leaking drums and segregating and organizing drums on site. Approximately 17,000 drums
were reportedly stored on the ground surface at the Site. In 1980, KNREPC contacted six responsible parties who identified and removed approximately 30 percent of the drums. In 1981, during a site inspection, it was discovered that the remaining drums were deteriorating and leaking contaminants. The EPA responded again under the emergency provisions of CERCLA. The existing treatment system was upgraded and the remaining 4,200 drums were removed. However, substantial amounts of waste remained buried on site. EPA added the Site to the Superfund Program’s NPL in 1983. In April 1986, the United States filed a cost recovery action pursuant to section 107 of CERCLA, Section 311 of the Clean Water Act and Section 7003 of the Resource Conservation and Recovery Act (RCRA) for emergency and other response costs incurred at the Site since 1979.
Between 1981 and 1986, a RI/FS was conducted to evaluate the possible remedial alternatives for the Site. The RI/FS phase included site sampling, hydrogeologic studies, human risk assessment, remedial design, cost analysis etc. During this period, public meetings were held to discuss alternatives. The alternatives were compared using evaluation criteria of reliability, implementability, RCRA conformance, environmental concern, and safety and O&M efforts. Following the RI/FS, EPA issued a Record of Decision (ROD) for the Site in 1986.
The remedial alternatives evaluated at the Site represented source control measures. The objectives of the remedial action broadly covered all routes of release, but focused on areas displaying the greatest potential for adverse effects on human health and the environment. The remedial action objectives (RAOs) discussed in the ROD include:
The ROD selected the onsite containment alternative as the final remedy for the Site. The selected remedy included:
six-foot-high chain link fence with appropriate gates.
Status of Implementation
Remedial design for the Site began in May 1986 and focused on designing components for the onsite containment remedy. The active contaminant migration pathway at the Site was determined to be by surface water runoff coming into contact with contaminated soils. A landfill cap was proposed as a method of containing waste materials and preventing contact between surface water and waste. Remedial action activities began at the Site on April 20, 1987. Remedial measures included installation of a clay cap, a perimeter drainage system, groundwater monitoring wells and security fence. Activities prior to the installation of the cap included clearing the vegetation and structures from the Site and draining the contents of a runoff control pond built by EPA in 1981 during the initial emergency response actions. Pond sediments were stabilized and the pond was refilled with water. Areas with suspected buried waste which were outside of the intended cap were excavated and any waste found was reburied in the cap area. Site borrow material was used in all depressions and low spots to prepare the Site for capping. The cap consisted of an impervious layer with a minimum of 36 inches of clay, an 18- inch pervious drainage layer (gravel), and a 12- inch topsoil layer with grass vegetative cover. Perimeter surface diversion ditches were constructed around the cap primarily to reduce erosion of the cap by runoff. The ditches were lined with riprap, seeded with a mixture of grasses and mulched with straw. Two culverts were installed at the northern and southern ends of the Site under the main access road. Construction of the cap and drainage ditches was completed in July 1987. A six-foot high chain link security fence with appropriate gates was installed outside the cap area in an effort to limit unauthorized entry onto the Site. The security fence encloses approximately six acres of the Site. The remaining 17 acres is a wooded and grassy area. Twelve groundwater monitoring wells were placed around the landfill to detect movement if any, of contaminants migrating off site towards Wilson Creek.
Reseeding and regrading was performed around the cap in the fall of 1988 due to erosion problems. Larger drainage ditches and culverts were constructed to withstand a 25-year/24-hour rainfall. Remedial construction was officially completed in March 1989 and a close out report was published on August 10,
The EPA performed O&M activities from September 1988 through February 1990. In July 1989, the EPA and KNREPC (now KDEP) signed the Superfuiid State Contract for O&M activities. The contract stated that KNREPC would perform the Site's O&M activities and identified the specific responsibilities of both agencies. The EPA and site PRPs signed a Consent Decree (CD) in October 1991. In the CD, the PRPs agreed to repay costs incurred by the EPA during the initial response actions to clean up the Site. The PRPs also agreed to provide funding to perform monitoring and O&M activities at the Site. The Superfimd State Contract required that EPA provide KNREPC with this funding from the PRPs to conduct O&M activities and repair on-site utility poles as needed. However, the contract required that KNREPC provide all necessary personnel, equipment and services to carry out required O&M activities. In May 1996, the EPA deleted the Site from the NPL. This deletion does not preclude future action under Superfimd.
As a matter of EPA’s policy, a review of the Site has been conducted at least every five years after the initiation of the remedial action at the Site to ensure that the remedy remains protective of human health and the environment. The First FYR report was published in 1992 and subsequent FYRs have been published since.
During a site inspection in 2007, the EPA found drum carcasses and hardened paint sludges resembling rocks at various locations near Wilson Creek. The investigations of the paint sludges began in 2010
continuing into 2011 which included identilying the areas containing paint waste, soil and sediment sampling and waste characterization. The paint waste was found to be non-hazardous and was cleaned up in March 2017.
Institutional Controls
The ROD did not call for ICs. There are no restrictions in place to protect the integrity of the remedy and prevent exposure to contaminated groundwater at the Site. According to the ROD, groundwater is not a source of drinking water near the Site because the aquifers produce low yields of poor quality. The residences and businesses near the Site obtain their drinking water from the public water supply. Options for ICs restricting groundwater and land use at the Site need to be evaluated to ensure that fiiture use will remain protective of human health and the environment.
Table 2 lists the potential ICs associated with the Site. Figure E-3 shows the location of the Site parcel requiring ICs.
Table 2: Summary of Planned and/or Implemented Institutional Controls (ICs)
Media, Engineered Controls, and Areas That Do Not Support UU/UE Based on Current Conditions
ICs Needed
ICs Called for in the Decision Documents
Impacted Parcel(s)
IC Objective
Title ofIC Instrument Implemented and Date (or planned)
Groundwater Yes No 034-000-00-011 Restrictgroundwater^ use^ of NA
Soil (^) Yes No 034-000-00-
Restrict inappropriate land use
NA
Systems Onerations/Operation & Maintenance (O&lVn
The final O&M plan for the Site was developed in May 1988 and revised in November 1989. The O&M plan provided the procedures to be followed during the closure and 30-year post closure period for maintaining the cap, drainage ditches, security fence, and the site access road and monitoring groundwater and surface water at the Site. The revised Final O&M plan estimated long-term O&M costs for a post-closure period of 30 years to be $998,875.
According to the revised Final O&M plan, regularly scheduled observation and maintenance activities at the Site include; ' • Performing field observations each year during January and during April through October.
installed berms, seeded with straw and mat and added class II riprap. This has temporarily reduced the flow of water but more permanent solution is needed. A professional engineer with KDEP evaluated the area and determined a swale should be installed along the eastern edge of the fence to allow for water to flow under the fence into Wilson Creek without disturbing the cap. The EPA and KDEP should evaluate options to resolve this issue.
Table 3 presents the annual O&M costs incurred during the current FYR period. These costs represent the total O&M funds used during a calendar year. The higher costs in 2016 and 2017 are associated with the topographic survey of the Site, grade and drainage improvement work in the southeastern portion of the Site and paint waste cleanup at Wilson Creek in addition to the routine O&M activities. As of January 2018, the current balance of the O&M fund is approximately $1.2 million. The SSC signed between EPA and KDEP for O&M activities is set to expire on December 18, 2020.
Table 3: O&M Costs over the FYR Period
Year Total O&M Cost (rounded to the nearest _____ hundred) 2013 $13, 2014 $7, 2015 $18, 2016 $23, 2017 $44,
III. PROGRESS SINCE THE LAST REVIEW
Table 4 summarizes the protectiveness determination and statement from the 2013 FYR Report. Table 5 summarizes the issues and recommendations from the 2013 FYR Report.
Table 4: Protectiveness Determinations/Statements from the 2013 FYR
ou#
Protectiveness Determination
Protectiveness Statement
Sitewide Short-Term Protective
The remedy at the Site currently protects human health and the environment in the short term. The landfill cap is effectively containing and preventing migration and contact with contaminants. For the remedy to be protective in the long term, the EPA and KDEP should take following actions:
Table 5: Status of Recommendations from the 2013 FYR
Sitewide
Issue
Required O&M activities have not taken place on a regular basis. Lack of required O&M activities has resulted in overgrowth of vegetation in the letdown channels on the cap. Overgrowth may impede water from moving off the cap as designed and may contribute to the ponding of water near the fence line on the southeast side of the Site.
Institutional controls restricting groundwater use at the Site, land use on the landfill cap, and land use in other areas, as appropriate, are needed to ensure protectiveness, but are not required by the Site's decision documents. No institutional controls have been put in place.
The EPA has not tested to determine whether dioxin and PCB congeners are present at the Site. Further testing has not been conducted to determine whether historical burning of chlorinated contaminants on site has resulted in the creation of dioxin and weathered PCB congeners.
Recommendations
KDEP should conduct regular O&M and monitoring activities.
Select and implement institutional controls to restrict groundwater use at the Site, land use on the landfill cap, and land use in other areas, as appropriate.
Evaluate the need to conduct further investigations using updated sampling and analysis techniques in accordance with EPA standard operating procedures to evaluate if dioxin and PCB congeners are present on the Site.
Current Status
Ongoing
Under Discussion
Address in next FYR
Current Implementation Status Description KDEP has routinely conducted O&M and monitoring activities since the last FYR
None
None
Completion Date (if applicable) 3/23/
N/A
N/A
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
A public notice was made available by a newspaper posting in the Pioneer News newspaper, on 7/23/2018 (Appendix G). It stated that the FYR was underway and invited the public to submit any comments to the EPA. No one contacted the EPA as a result of the advertisement. The results of the review and the report will be made available at the Site ’s information repository, the Ridgway Memorial
In addition to KDEP’s annual sampling events, as a part of the dried paint waste investigation and characterization activities at Wilson Creek, a private contractor, Linebach Funkhouser Inc., performed soil, sediment and paint sludge sampling in 2010 and 2011. The sampling was performed to assess the impact of waste paint sludge and empty drums on underlying natural soil/sediments. During the investigation, the contractor collected and analyzed: 29 surficial soil and sediment samples (0 to 0.5 feet deep) including 20 sediment samples from Wilson Creek, 53 shallow subsurface soil samples (0.5 to 2 feet deep) and 90 deeper subsurface soil samples (2 to 10 feet deep). The results of the investigation were published in Areas of Concern Characterization Report submitted to KDEP dated August 5, 2011 and summarized below.
Soil and Sediments
The soil samples were collected immediately below the observed waste material from the southern portion near well ALT-6, northern portion outside the cap and adjacent to the bed of Wilson Creek. Sediment samples were collected directly from the bed of Wilson Creek. The samples were analyzed for RCRA Metals, VOCs, PAHs, and PCBs. Benzo(a) pyrene and arsenic were detected slightly in excess of its risk based screening level for residential soil in some samples in 2010 whereas Aroclor 1254 and/or 1260 were detected above risk based screening levels for non-restricted site use in some samples collected near Wilson Creek in both 2010 and 2011. The sediment sampling results were consistent with the soil sampling results. The sediments in Wilson Creek bed had been affected by the PCBs, Aroclor 1254 and 1260 at concentrations exceeding KDEP’s default risk-based screening levels for non- restricted use property. The levels of PCBs were significant and covered a stretch of Wilson Creek extending approximately 1,600 linear feet.
Waste Characterization/Paint Sludge Sampling
Five composite samples of hardened waste material were collected during the 2010/2011 investigation. The samples were collected again in 2016 and evaluated for the same parameters as soil and sediments but using the toxicity characteristic leaching procedure (TCLP). During both events, the analyses indicated that the material did not constitute a regulatory designation as a characteristic waste. Subsequently, the waste was cleaned up and disposed of as a special waste at a permitted Subtitle D landfill in 2017.
Overall, all the sampling events conducted over the FYR period indicate that apart from metals and VOCs, contamination has been minimal in groundwater and almost nonexistent in surface water. However, PCBs in Wilson Creek sediments are still a cause for concern. The PCBs were found in Wilson Creek at elevated concentrations even after the paint waste was cleaned up in early 2017. Therefore, a thorough investigation of the source of PCB contamination is warranted.
Site Inspection
The FYR inspection of the Site was conducted on November 29, 2017. In attendance were EPA RPM, Yvonne Jones, KDEP representatives Christoph Uhlenbruch, Frank Whitney and Shital Jiwane, and KDEP’s site maintenance contractor, Eddie Taylor (no relation to A.L. Taylor). The purpose of the inspection was to assess the protectiveness of the remedy. The participants walked the Site, assessed the condition of the landfill cap, inspected the groundwater monitoring wells, drainage ditches and Wilson creek and met with a neighboring property owner.
During previous site virits, KDEP had noticed signs of ATV traffic around the Site. KDEP informed Ms. Jones that the fence was extended by about 10 feet in 2015 to deter ATV traffic and trespassing. No signs of ATV traffic were visible during this site visit. There was no “No Trespassing” sign at the front gate.
Ms. Jones noted that the routine monitoring seemed adequate and the Site looked in good shape. The cap looked regularly mowed and well maintained. There were no signs of erosion. The riprap slopes of the letdown channels were intact and the channels were free of vegetation. However, Mr. Taylor stated that he had observed the cap settling at few places. He showed the areas where it had started to settle. He mentioned that he had fixed an area of minor settlement around 3 years ago. The group noticed that the cap had started to settle in the central portion near the utility poles and access road leading to the back gate.
The fence around the cap was in good condition overall, although it was slightly broken near the vicinity of well ALT-10. The fence was extended in the eastern portion of the Site starting near well ALT-4 and all the way till well ALT-8. The riprap in this area was still at the same location where the original fence had been and the drainage ditch seemed to lose its boundary and direction near the fence extension. Ponding was observed near the area and berms were seen to control the runoff from the drainage ditch. Mr. Taylor indicated the area is prone to flooding during heavy rains as the area gets water from both the drainage ditch as well as overflow from the pond. Mr. Taylor shared a photograph taken during heavy rains in 2015 which showed the area under water due to nmoff. Ms. Jones was concerned about the issue and noted that she did not observe such level of ponded water during previous site visits.
The drainage ditch was mostly clear of excessive vegetation except in the northern portion outside the cap, trees and shrubs had started to grow. All the groundwater monitoring wells were clearly marked and locked. Some of the locks were rusty and could not be opened. The padding around the wells was good except ALT-1 where the padding was buried under a soil layer. Casing had become loose on ALT-4. One of the wells had marks of being hit by a mower or a similar object. There was an unmarked pipe near ALT- 10 and unlocked wells named ALT-DW along the northern portion of the Site which were not in use.
KDEP informed Ms. Jones that the paint waste and drum carcasses in Wilson creek were removed earlier in 2017. Ms. Jones wanted to confirm whether the paint waste removal was done satisfactorily or not. The creek was mostly clear and no waste was observed in the creek except at few places small remnants of paint waste were still noticeable.
The EPA and KDEP representatives also met with the neighboring property owner. He reiterated his concern, which he had also stated to KDEP during a site inspection in August 2017, that the routing of the drainage ditch towards the pond is the source for overloading the pond with sediment. This issue was also mentioned in the previous FYR interview when he claimed that the structural integrity of the pond had been affected. Ms. Jones informed him that EPA was doing a title search for the A. L. Taylor property to confirm the property boundaries. Depending on the outcome of the title search, EPA will take steps to resolve the issue.
On December 7, 2017, KDEP ’s Shital Jiwane and Daniel Phelps, Geologist, visited the designated site repository, Ridgway Memorial Library, located at 127 Walnut Street, Shepherdsville, Kentucky 40165. ( The library only had paper records for the Site. Cheryl Harris, KDEP, delivered a compact disc containing current site records to the library on February 7, 2018.
significantly. However, the levels of PCBs in the Creek remain elevated. Dried paint waste and drum carcasses were found in Wilson Creek in 2007. PCBs were found to be a component of the paint waste samples. It was assumed that the paint waste could be a potential source of PCB contamination in the Creek. The waste was cleaned up in January 2017 but the sediment samples collected during an annual sampling event in December 2017 indicated that PCBs are still present above regulatory limits in Wilson Creek. This has raised concerns as to the source of contamination in Wilson Creek.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?
The groundwater and surface water were evaluated as the potential routes of exposure to hazardous substances from the Site in the 1984 Feasibility study addendum and endangerment assessment. The major exposure pathway was runoff of contaminated surface water into Wilson Creek. The landfill cap and public water supply for nearby residents have significantly reduced the direct exposure to surface water runoff and groundwater respectively in the vicinity of the Site. However, in the absence of groundwater and land use restrictions, the risk of contamination is not completely eliminated. There have been no changes in site conditions that would suggest new exposure pathways.
The ROD did not establish any COCs,or any action levels associated with the COCs. However, the ROD provided the list of contaminants detected at highest concentrations or above background levels at the Site. The 1989 revised Final O&M plan established a list of contaminants including VOCs, other organic compounds and PCBs for analysis during groundwater and surface water monitoring. There are not any new or additional contaminant sources at the Site. ARARs were not defined for the Site in the ROD. Therefore, contaminant concentrations in groundwater monitoring wells and surface waters of Wilson Creek are compared to the current Federal Drinking Water standards (MCLs) and, in the absence of MCLs, to EPA Region 3 Regional Screening Levels (RSLs) for Tap Water. Sediment samples are compared to Regional Screening Levels for Residential and Industrial Soils and the Region 4 Ecological Screening levels for Sediments.
The comparison of surface water samples to regulatory standards since the previous FYR and current FYR period indicate that surface water samples in Wilson Creek did not have any exceedances since 2007 which proves that the remedy has been effective in preventing migration of contaminants by rrmoff. Groundwater contamination has been persistent during the last 10 years and still shows some metals and VOCs slightly above regulatory limits. Groundwater is not used as a drinking water source in the vicinity of the Site. Similarly, sediment samples continue to show elevated concentrations for the same PCB constituents namely Aroclor 1254 and 1260. Although these PCB constituents are not volatile and have very low solubility, direct contact with soil and sediments in Wilson Creek are a potential risk factor.
The RAOs in place at the time of remedy selection and described in the decision document remain valid. The remedy continues to work towards meeting RAOs. The objective of preventing direct contact or ingestion of contaminated soils and groundwater is achieved by a well maintained and secured landfill cap. The annual groundwater monitoring serves to indicate groundwater contaminant concentrations in the landfill and provides an early warning of potential releases to surface water in the Wilson Creek.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?
As has been noted in the previous FYRs, the southeastern portion of the cap near the fence line has been vulnerable to ponding but it has become worse in recent times. The natural topography of the area is such that the surface water/runoff flows eastward in this direction and moves towards Wilson Creek. During the current FYR site inspection in November 2017, it was observed that the area had a substantial amount of standing water. KDEP had installed berms to improve surface drainage and contain the runoff but they were not sufficient to stop the ponding of water. The drainage ditch does not have enough riprap to reduce the flow rate of water. This area including the fence were under water due to flooding in 2015. The water overflowed near the fence line due to flooding of the drainage ditch as well as overflow from the pond before moving toward Wilson Creek. If corrective measures are not taken, the integrity of the southeastern portion of the cap may be compromised. Therefore, EPA and KDEP should initiate steps to avoid ponding in the future.
I Issues and Recommendations Identified in the Five-Year Review:
OU(s): Sitewide Issue Category: Changed Site Conditions Issue: The ponding of water in the southeastern portion of the cap has reached problematic levels. It was noted that the area became flooded during heavy rains. The drainage ditch does not have enough riprap to manage the runoff. Recommendation: Implement proper measures to address ponding. Affect Current Protectiveness
Affect Future Protectiveness
Party Responsible
Oversight Party Milestone Date
No Yes EPA/State State/EPA 8/30/
OU(s): Sitewide Issue Category: Monitoring Issue: The dried paint waste and drum carcasses along the banks of Wilson Creek were cleaned up in January 2017, but the sediment samples collected in December 2017 showed that PCBs continue to exist in the creek. Recommendation: Investigate the source of PCB contamination in Wilson Creek. Affect Current Protectiveness
Affect Future Protectiveness
Party Responsible
Oversight Party Milestone Date
No Yes EPA/State EPA/State 3/31/2020 ,
