U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Black Leaf Chemical - Removal Polrep
Initial Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #1
Removal Site Evaluation Polrep
Black Leaf Chemical
B4L7
Louisville, KY
Latitude: 38.2318091 Longitude: -85.7827199
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To:
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From:
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Art Smith, On-Scene Coordinator
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Date:
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9/2/2011
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Reporting Period:
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August 1, 2011- August 31, 2011
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1. Introduction
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1.1 Background
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Site Number: |
B4L7 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
8/23/2011 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Assessment |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
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Start Date: |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
KYD980559250 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
08/29/2011 |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Inactive Production Facility
1.1.2 Site Description
1.1.2.1 Location
The Site is located on a portion of a 29-acre parcel of land in the Park Hill neighborhood of Louisville, and is bordered by a densely populated residential area to the north, a large rail yard to the south, and industrial/commercial areas to the east and west. Multiple brick structures occupy the Site, which was the location of pesticide formulating operation, a whiskey distillery, and several wood drying and lumber distribution companies in the past.
The Site is currently abandoned.
1.1.2.2 Description of Threat
Immediate threats are present in the form of potential direct contact with hazardous substances due to lack of controls on access to the Site.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On July 25, 2011, the Kentucky Department for Environmental Protection (KDEP) Superfund Branch requested that EPA Region 4 evaluate this Site for purposes of conducting a time-critical removal action. The request was based on the results of an October 2010 Site Investigation (SI) that revealed high concentrations of organochlorine pesticides in surface soil at an industrial park. Elevated levels of arsenic and polynuclear aromatic hydrocarbons (PAHs) were also discovered in surface soils. KDEP also cited the lack of controls on access to the Site and the inability to compel the current property owner to secure the Site as a basis for requesting EPA assistance.
On August 8, 2011, EPA On-Scene Coordinator (OSC) Art Smith and KDEP performed a site inspection. At that time, a gate at the 17th Street entrance to the Site was missing and evidence of trespassing was noted in areas of the Site where hazardous substance releases are present. Based on this information, the OSC completed the removal site evaluation under 40 CFR Section 300.410, and concluded that the site meets the following National Contingency Plan (NCP) criteria under 40 CFR Section 415(b)(2) for initiating a time-critical removal action:
Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human populations, or the food chain from hazardous substances pollutants or contaminants;
Sampling results from the October 2010 Site Investigation confirmed elevated levels of the following pesticides in surface soil:
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Hazardous Substance
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CAS Number
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Maximum Concentration (mg/kg)
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Alpha-BHC
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319-84-6
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1,400
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Gamma-BHC
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58-89-9
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180
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4,4’ DDT
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50-29-3
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270
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Dieldrin
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60-57-1
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18
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The graffiti observed in several buildings onsite documents the fact that trespassing is ongoing and these conditions represents an actual or potential exposure to hazardous substances.
Section 300.415 (b)(2)(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate;
Analytical results reveal that elevated pesticide and arsenic levels are present at or near the surface creating a potential for migration to off-site locations.
Section 300.415 (b)(2)(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released;
As stated earlier, pesticide and arsenic contamination is found at the surface If the contamination is not addressed with a removal action then this contamination could possibly migrate to off-site locations.
Section 300.415 (b)(2)(vii) The availability of other appropriate federal or state response mechanisms to respond to the release;
As stated previously, KDEP referred the Site to EPA for action, citing an inability to finance the work necessary to mitigate threats at this Site.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Current Situation
The Site is currently owned by Louisville Industrial Park, LLC and is in an abandoned state. It is fenced along it's entire perimeter, but there are several breaches in the fencing along the northern property boundary. The gate at the Dixie Highway entrance is secure, but the gate at the 17th Street entrance is missing entirely. This entrance is characterized by an accumulation of solid waste which has been dumped illegally.
The abandoned buildings are in a general state of disrepair, and graffiti is observed throughout. In addition, numerous open pits and drainage structures are present which could cause serious injury if one were to fall in unexpectedly. Further evidence of trespassing by "urban explorers" has been chronicled in the Louisville Eccentric Observer (LEO). (See http://leoweekly.com/news/meet-break for the June 1, 2011 LEO excerpt).
2.1.2 Response Actions to Date
KDEP removed approximately 90 drums of hazardous and solid wastes at this location in May and June 2009.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The current property owner is Louisville Industrial Park, LLC. Records indicate that previous owners and operators at the Site include Virginia-Carolina Chemical Corporation and Diamond Alkali Company Black Leaf Division. Both of these entities are believed to have been involved with organochlorine pesticide manufacturing, formulating and distibution at this location in the 1950s.
EPA has initiated the enforcement process and is currently engaged in the identification of PRPs for this Site.
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Louisville Industrial Park, LLC has informed EPA and KDEP that they do not have the resources to secure the Site.
The OSC approved an Action Memorandum on August 23, 2011 under his delegated authority in the amount of $50,000. A Task Order was issued to CMC Environmental Services, Inc. on September 2, 2011 for purposes of enhancing security at the Site.
2.2.1.2 Next Steps
The removal action will be limited to reparing and replacing fencing and gates to a degree sufficient to deter trespassers.
2.2.2 Issues
The Site will be posted to waren trespassers of hazardous conditions. This may generate interest in the Site, both at the neighborhood level and in the community at large.
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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No information available at this time.
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4. Personnel On Site
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No information available at this time.
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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