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The BF Goodrich site (the Site) is located in western Kentucky along the south bank  of the Tennessee River. Chemical manufacturing began in the mid-1950s and continues today. The primary product is ethylene dichloride (EDC), a feedstock for the production of polyvinyl chloride (PVC). Until the 1980s, chemical wastes were discharged to a series of unlined ponds in the floodplain where contaminants migrated into the soil, groundwater, and the Tennessee River A Remedial Investigation (RI), completed in 2015,  documented the presence of about 3,500,000 cubic yards of soil beneath multiple chemical plants and the Tennessee River that are contaminated with non-aqueous phase liquid (NAPL). Non-aqueous phase liquids, or NAPLs, are liquid solution contaminants like oil, gasoline and petroleum products that do not dissolve in or easily mix with water.

In the late 1980s, KDEP required Goodrich to  pump and treat contaminated groundwater to prevent its discharge to the river.  Currently,   parties responsible for the cleanup of the site sample 185 wells annually to monitor changes in groundwater quality. 

Because of the active operational status of the plants, until 2009 much of the environmental response for the Site had been managed by the Kentucky Department of Environmental Protection (KDEP) under regulations required by the Resource Conservation and Recovery Act (RCRA).  The Superfund response focused on a landfill and burn pit area. However, as EPA’s and KDEP’s understanding of the magnitude of contamination increased, KDEP requested that EPA expand the scope of the Superfund response to also include areas managed by KDEP pursuant to RCRA.

From 2010 through 2017, EPA and KDEP worked with the parties responsible for the cleanup of the site to determine the nature and extent of contamination and the potential risks. These results led to the development of the cleanup alternative in the November 2017, Proposed Plan.

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What Is the Current Site Status?

EPA is working with KDEP to complete a review of public comment regarding the proposed excavation of source material from beneath the Tennessee River. Depending on the results from this review, EPA may issue an amendment to the Proposed Plan or may issue a Record of Decision (ROD). The public will be notified of EPA’s decision.  

EPA anticipates that this review will be completed and ROD issued by the end of 2018.

Since the 1980’s, much work has been done by the current and former owner/operators of the BF Goodrich facility to address site-related contamination. Most notably, under the supervision of KDEP, two waste management ponds adjacent to the river were closed. Contaminated material was removed from the ponds and placed in a 240,000 cubic yard landfill with a top liner, bottom liner, and leachate collection system. In an effort to further protect the Tennessee River, 54 wells were installed to collect and treat contaminated groundwater prior to its discharge to the river.

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Activity and Use Limitations

At this site, activity and use limitations that EPA calls institutional controls are in place. Institutional controls play an important role in site remedies because they reduce exposure to contamination by limiting land or resource use. They also guide human behavior. For instance, zoning restrictions prevent land uses – such as residential uses – that are not consistent with the level of cleanup.

For more background, see Institutional Controls.

Multiple active chemical plants currently occupy the 200-acre area that is referred to as the BF Goodrich Superfund site. As a result, access to contaminated areas is controlled by the chemical plant operators. 

Some areas of contamination could be exposed along the river bank adjacent to the site when river levels are low. However, the property is owned by the chemical plants and access would need to occur from the river, by boat.

Prior to the expansion of EPA’s role in the management of the site in 2009, EPA conducted a cleanup on a small landfill and burn pit area on the east site of the BF Goodrich site. As part of this, institutional controls were placed on this area preventing the installation of wells for drinking water or use of the property for residential purposes.

These restrictions will likely be expanded throughout the entire 200-acre site with the final ROD planned for late-2018.

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Sampling and Monitoring

Groundwater samples are collected on an annual basis to monitor the effectiveness of the RCAR groundwater collection and treatment system.

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Enforcement Information

EPA negotiated legal agreements with the site PRPs to investigate and clean up the site.  The PRPs continue to fund site cleanup, monitoring and oversight activities.  EPA anticipates that these parties will also enter into an agreement with EPA to fund and conduct the final cleanup of the site.

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