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 #8
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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10/8/2013
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Reporting Period:
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9/30/2013 through 10/7/2013
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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
1612 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.
In September 2013, a Ceiling Increase Action Memorandum was signed authorizing an additional $396,150 in funding in order to complete the removal action.
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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 September 30, work focused on the soil removal at the following properties:
1632 Wilson Avenue
1728 Wilson Avenue
1732 Wilson Avenue
1752 St. Louis Avenue
At 1632 Wilson, sod was placed on October 2 marking completion of restoration at this property.
At 1728 Wilson, the lot was seeded and covered with straw on September 30, marking completion of restoration at this property.
At 1732 Wilson, clearing and grubbing began on September 30, and excavation and backfilling were completed on October 2. Approximately 110 cubic yards (cy) of soil was removed from the back yard of this property.
At 1752 St. Louis Avenue, excavation began on October 3, and was completed on October 4. Approximately 198 cy of soil were removed from the back yard at this property.
On October 4, all open excavations were backfilled, with the exception of 1752 St. Louis. That lot had an area that could not be backfilled before crews left for the weekend. All bare lots were prepared with straw in advance of a cold front expected to move into the area.
Approximately 115 tons of non-hazardous soils were shipped offsite during the week of September 30.
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 |
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Quantity |
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Disposal |
| Soil contaminated with lead, organochlorine pesticides and PAHs |
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671 tons |
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Outer Loop Landfill, Louisville, KY |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Complete final grading and seeding at 1752 St. Louis
Clear debris and begin excavation at 1748 St. Louis
2.2.1.2 Next Steps
2.2.2 Issues
On October 2, the results for the air samples which were collected on September 24 were reported by ERRS subcontractor Air Source Technology, Inc. Arsenic, lead, and total nuisance dust were below detection limits for all samples. This confirmed the results collected on September 10, and documents the OSC's decision that particulate monitoring activities are no longer necessary while excavation is occurring.
During the weekend of October 5-6, approximately 7.5 inches of rain fell at the Site, as measured by a rain gauge. On October 7, the OSC inspected the conditions of the back yards of residences adjoining the Black Leaf Site. No visible signs of siltation or other debris were observed in yards which had been remediated as part of this removal action.
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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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