On July 25, 2011, the Kentucky Department for Environmental Protection (KDEP) Superfund Branch requested that EPA 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.
On August 8, 2011, 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 onsite 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 off-site areas. Analytical results indicated that arsenic, lead, and organochlorine pesticides which were released at the Site have migrated offsite 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 indicate 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 EPA’s Removal Management Levels (RMLs) for 10 residential properties.
In June 2013, an Action Memorandum was signed authorizing $312,600 in funding to conduct a time-critical removal action at the 10 residential lots where EPA's RMLs are exceeded. The plans are to excavate soil to a one foot depth at the rear of the impacted properties, backfill with clean topsoil, and then lay sod as a ground cover. In addition, soils in the unpaved areas of the alley behind Wilson Avenue will be excavated to an approximate depth of one foot below land surface to cut off migration of contaminants to residential areas.
In September 2013, a Ceiling Increase Action Memorandum was signed authorizing an additional $396,150 in funding in order to complete the removal action.