U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Black Leaf Chemical - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #4
Progress 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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8/30/2013
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Reporting Period:
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08/26/2013 through 08/30/13
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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 Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
9/23/2011 |
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Start Date: |
9/23/2011 |
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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 at 1391 Dixie Highway in the Park Hill neighborhood of Louisville. The 29-acre parcel 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 a pesticide formulating operation, a whiskey distillery, and several wood drying and lumber distribution companies in the past. The Site is currently abandoned.
The Site comprises the areal extent of contamination, which includes the 29-acre industrial park, the public right of ways to the north of the facility and the following residential properties to the north of the facility:
1532 Wilson Avenue
1610 Wilson Avenue
1616 Wilson Avenue
1620 Wilson Avenue
1624 Wilson Avenue
1632 Wilson Avenue
1728 Wilson Avenue
1732 Wilson Avenue
1748 St. Louis Avenue
1752 St. Louis Avenue
1.1.2.2 Description of Threat
On July 25, 2011, the Kentucky Department for Environmental Protection (KDEP) Superfund Branch requested that the U.S. Environmental Protection Agency 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. 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.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On August 8, 2011, On-Scene Coordinator (OSC) 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 National Contingency Plan (NCP) criteria for a time-critical removal action. On September 13, 2011, the EPA initiated a time-critical removal action to repair the fence and secure the Site to protect the public from potential direct contact with hazardous substances.
In September and October 2011, the EPA collected soil samples on-site in a storm drain and at multiple locations just outside the fence along the perimeter of the Site to determine whether hazardous substances had migrated to off-site areas. Analytical results indicated that arsenic, lead, and organochlorine pesticides which were released at the Site have migrated off-site into the public sewer system and the public right of ways.
In February 2012, the EPA collected soil samples at 50 residential properties located in close proximity to the Site. In November 2012, both the EPA and the Kentucky Department for Environmental Protection collected soil samples at 19 additional residential properties. Analytical results indicated that arsenic, lead, organochlorine pesticides and polycyclic aromatic hydrocarbons (PAHs) which were released at the Site have migrated to nearby residential properties. In particular, arsenic, benzo(a)pyrene, and lead are at concentrations which exceed the EPA’s Removal Management Levels (RML) for residential areas.
In June 2013, an Action Memorandum was signed authorizing $312,600 in funding for EPA to conduct a time-critical removal action at the 10 residential lots where EPA's RMLs are exceeded.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
2.1.2 Response Actions to Date
During the week of August 26, no EPA lots were excavated.
Also during the week of August 26, the EPA START contractor OTIE continued with daily monitoring for airborne particulate matter potentially associated with soil excavation. The goal is to keep daily average readings to less than 125 micrograms of total particulate matter per cubic meter (ug/m3) of air. This action level correlates to an estimated fraction of total dust that are lead particles and is designed to comply with the National Ambient Air Quality Standard for lead dust = 0.15 ug/m3. This action level was derived and is based on a lead level in soil of 1200 milligrams per kilogram (mg/kg) or 0.12% of total particulate matter. The particulate action level of 150 ug/m3 is conservative as the assumed source soil lead concentration of 1200 mg/kg is the maximum value found in residential soil samples and was only detected in one lot. (The average lead concentration in soil is about 270 mg/kg).
The air monitoring results are obtained by a DataRAM 4000 particulate counting instrument. The results are viewed in real time using the VIPER wireless transmission system developed by EPA's Environmental Response Team (ERT). For more information on VIPER, please use the hyperlink: www.epaosc.org/viper.
The OSC tasked the START contractor to compare output from the VIPER server with the data logs on the DataRAM 4000 instruments. The particulate monitoring readings and the comparisons are in units of ug/m3, and are as documented in the table below:
| Time Weighted Average Comparison |
| Run Date |
VIPER Linc 202 |
Data Ram Linc 202 |
VIPER Linc 32 |
Data Ram Linc 32 |
| 8/20/2013 |
34.2 |
22.39 |
31.6 |
17.96 |
| 8/21/2013 |
27.3 |
27.28 |
32.11 |
32.69 |
| 8/22/2013 |
24.5 |
24.39 |
31.2 |
31.18 |
| 8/26/2013 |
38.1 |
38.19 |
57.6 |
57.6 |
| 8/27/2013 |
37.1 |
37.11 |
42.4 |
42.45 |
Except for the readings obtained on 08/20, the values are in agreement, and the VIPER system is producing reliable data for particulate measurements. Also of note, the total dust levels are estimated to be about 2 to 4 times lower than
the 125 ug/m3 action level for total dust in air. This documents that the dust suppression tactics to support soil excavation are effective.
On August 27, the OSC, KDEP, and the ERRS contractor CMC, Inc. met to discuss air sampling that would provide information on actual amounts of airborne arsenic and lead that may arise from excavation activities. Air sampling would be designed to validate the 125 ug/m3 average total dust action level detected Initiation of air sampling activities is pending the selection by ERRS of a qualified subcontractor to perform these services.
On August 30, the OSC met with the owner at 1748 St. Louis to confirm that a parked car and a dog had been re-located to facilitate soil excavation at this address.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Several PRPs for this Site have been identified, and the process of identifying PRPs for this Site is nearly complete. Of the viable PRPs identified for the Site thus far, there is no expressed commitment to undertaking the necessary response actions. Based on a lack of PRP participation, it is necessary to proceed with a fund-lead removal action.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Soil excavation on EPA lots are scheduled to resume on 09/09. The Region 4 CIC will be onsite during that week to assist with additional pre-construction surveys.
2.2.1.2 Next Steps
Prepare an Action Memorandum that will add funding to the project. The increase is necessary due to unforeseen START costs for continued air monitoring. The Action Memo will also request a change in the scope of the project due to additional source control measures required to address possible sediment contamination on the Black Leaf Site.
2.2.2 Issues
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2.3 Logistics Section
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NA
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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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3.1 Unified Command
3.2 Cooperating Agencies
Kentucky Department for Environmental Protection
Louisville Metro Public Works
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4. Personnel On Site
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EPA Region 4 - 1
START - 1
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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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6.1 Internet location of additional information/report
6.2 Reporting Schedule
Polreps will be submitted on a weekly basis
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7. Situational Reference Materials
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No information available at this time.
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