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. Based on the sampling results of the RSE, and due to deteriorating conditions, the OSC determined that a removal action was warranted and intitiated response actions to mitigate the threats to human health.
On 10/15/05, OSC Smith ordered a shutdown of work at the Site, due to lack of current funding. The following is an account of the work performed from 9/23 thru 10/19:
-On 9/30/05 the removal, dismantling, and shearing of the 9 ASTs in the northern tank farm was completed. All scrap metal was transported and disposed of at the River Steel Scrap yard in Newport, Kentucky. All building debris (concrete, wood, etc) was transported and disposed of at Epperson Landfill in Williamsburg, Kentucky.
-On 10/4/05 the removal, dismantling, and shearing of the 9 ASTs in the northern tank farm was initiated. As of 10/11/05, 3 of the ASTs have been removed, dismantled, and loaded out as scrap.
-On 10/11/05, the 6 ASTs containing residual wastes were emptied by Permafix using a vacuum truck. Five drums containing compatible wastes were also emptied. The wastes were transported to the Permafix facility in Dayton, Ohio for disposal.
-On 10/14/05 the removal and dismantling of ASTs was completed. The contents of two ASTs (pigments and sludge) were soldified and staged inside one the buildings onsite pending finalization of the disposal information.
Perimeter air monitoring continued on a daily basis for nuisance particulates and VOCs during removal activities. No VOCs have been detected to date. Particulate readings continue to remain below the action level for the site. On 10/12/05, perimeter air sampling for asbestos was initiated due to the presence of non-friable asbestos containing material in the roofing tar of buildings at the site. The sampling will continue, at a minimum, on a weekly basis for the duration of the removal. The results of the initial samples yielded non-detect values.
The following activities remaining under the removal action are:
1) Finalize design of a recovery trench to intercept solvent-contaminated runoff
2) Continue building demolition and slab removal
3) Continue hauling scrap metal to a recycler
4) Continue transporting construction debris to C & D landfill
5) Excavation and disposal of impacted soils under the site buildings
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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