The MJ Daly Site is located at 101 Oak Street, Ludlow, Kentucky. 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.
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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.
The EPA removal action was initiated on August 26, 2005 and continued through early January 2006. During this period, all above ground storage tanks were removed for proper disposal, the structure was demolished and the concrete slab taken up over a portion of the site. Site work was suspended and all personnel demobilized on 01/19/06, due to personnel scheduling issues prompted by EPA's continued response to Hurricane Katrina.
The EPA removal action was re-started on June 1, 2006. The scope of work for Phase 2 activities involves construction of a cap and a sheet pile wall to isolate an area of high VOC contamination in soil (total VOCs in soil > 10,000 ppm), and to cutoff the offsite migration of contaminants discharging into a nearby storm drain. Pile driving activities began on June 16, 2006 and were completed on September 11, 2006. The sheet pile cell is about 17,000 sq. feet in area and contains over 1000 cy of contaminated soil. These soils were excavated from areas where contact with subsurface runoff resulted in leachate generation and subsequent discharge to the municipal sewer system.
Construction of the perimeter drainage system was completed on August 31, 2006. Over 480 linear feet of drainage system was installed along the eastern (upgradient) perimeter of the Site to intercept and control subsurface water flow. Prior to construction, all visibly discolored soils were removed down to the top of a continuous clay layer found at an average depth of 3' below land surface. The system operates as a french drain, and consists of 4" diameter perforated pipe bedded in gravel. The drain was joined to a 6" diameter PVC pipe which passes through the sheet pile cell and is connected to the Sanitation District No. 1 sewer system.
Final placement of soils into the cell occurred on September 19, 2006, and capping of the cell and all other areas where visibly contaminated soils appear at the surface was completed on October 5, 2006. One final touchup of areas where minor erosion had occurred was performed on August 31, 2007, which marked the completion of the removal action.
The site is ready for reuse with some restrictions, notably that the cap be maintained in order to prevent a release of hazardous substances. The City of Ludlow, KY has expressed an interest in acquiring the site for use as a parking lot for the renovated City Hall located next door on Elm Street. EPA is preparing official correspondence to the City of Ludlow concerning the reuse of the site, including certain requirements to be met, so that subsequent potential liability for the existing contanmination may be avoided.