The MJ Daly Site is located at 101 Oak Street, Ludlow, Kentucky. One structure is currently standing on the site, a 10,000 square foot abandoned warehouse building. The surrounding area is residential, with a few small businesses.
Records indicate that M. J. Daly operated on the property from 1950s to the 1980s. The warehouse building was the former location of a specialty chemical manufacturing business operated by M. J. Daly Company. This business involved the mixing and packaging of organic chemicals including, but not limited to, aromatic solvents, acetates, alcohols, and ketones. As recently as 2004, Barker Fine Color leased the warehouse property to operate a pigment manufacturing facility.
On June 27, 2005, the United States District Court for the Eastern District of Kentucky issued a Warrant for Entry at the M.J. Daly Co., Inc. The Warrant authorized U.S. EPA access to perform a site investigation at the abandoned warehouse facility.
On July 25-28, 2005, EPA, Kentucky DEP, and START conducted a Removal Site Evaluation (RSE) at the Site. The RSE included tank, drum and waste sampling, subsurface soil sampling with a Geoprobe, trenching, and monitoring well sampling. During the RSE, the EPA On-Scene Coordinator (OSC) noted vandalized piping, liquid wastes leaking into floor drains, unrestricted access to tank areas, un-containerized waste on the building floor, and leaking drums. A total of 24 ASTs and 6 drums and containers were documented onsite. Three of the 24 ASTs contained solid dye pigment wastes including barium, chromium, lead, and mercury. Drums were documented to contain wastes including ethylbenzene, isopropyl benzene, toluene, and xylenes. The drums and tanks were noted to be in varying stages of deterioration with contents leaking onto the floor. Test trenching along the building foundation documented subsurface pipes draining liquid waste at the northwest corner of the site building to the surrounding soil. It is presumed that this release is migrating offsite. The analytical results documented that following hazardous substances were released to the environment: acetone, benzene, chloroethane, 1,1-dichloroethane, cis-1,2-dichloroethene, ethylbenzene, 1,1,1-trichloroethane, toluene, vinyl chloride, and xylenes.
Based on the sampling results, and due to deteriorating conditions, the OSC determined that a removal action was warranted and initiated response actions to mitigate the threats to human health.
On 8/26, the OSC met with the Region 4 ERRS contractor (CMC, Inc.) to go over the immediate actions required to stabilize site conditions. A security guard was hired and temporary fencing erected to keep out trespassers.
On 9/01, the United States District Court extended the initial Access Warrant for a period not to exceed one year to perform the removal action. Upon receipt of the warrant, ERRS & the Superfund Technical Assistance and Response Team (START) contractor re-mobilized to the Site. Current ERRS activities include partial building demolition, tank demolition, and arranging for offsite disposal/treatment of hazardous substances. START has been tasked with site documentation and air monitoring during demolition work.
The OSC has coordinated with state and local officials in preparation for removal activities at the Site. An Emergency Contingency Plan was developed with input from local responders, and EPA's Community Involvement Coordinator (CIC) outlined public outreach activities. On Sept. 9, the OSC conducted an on-site press conference with local media representatives, and the CIC distributed Fact Sheets to approximately 100 residences and businesses in the community.
During the next 2 weeks (through Oct. 7), the folllowing removal actions are planned for the Site:
Clean & grub vegetation within tank farm area
Finalize design of a recovery trench to intercept solvent-contaminated runoff
Continue demolition of ASTs
Haul scrap metal to a recycler
Finalize arrangements for disposal of tank and drum waste
The Action Memo for the Site calls for complete building demolition, in order to assess and mitigate the extent of solvent contamination in soils and shallow groundwater. While the project was funded incrementally to initiate emergency measures, completing the demolition of the warehouse building requires additional resources. A Ceiling Increase Action Memo will be required to authorize removal of the building down to the foundation, and to scope out the further assessment of environmental contamination at the Site.
EPA Region 5 is assisting EPA Region 4 by allowing an OSC stationed in Cincinnati, OH to provide oversight of field operations at the Site.
Due to the continuing response to the aftermath of Hurricane Katrina, EPA’s cleanup operations at the MJ Daly Site, may be affected.
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