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The BF Goodrich Site is located in western Kentucky along the shore 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. The Remedial Investigation (RI) documented the presence of about 3,500,000 cubic yards of soil contaminated with non-aqueous phase liquid (NAPL) beneath multiple chemical plants and the Tennessee River. [Non-aqueous phase liquids or NAPLs are liquid solution contaminants that do not dissolve in or easily mix with water (hydrophobic), like oil, gasoline and petroleum products.]

The primary threat is to human and ecological receptors associate with the River. [Ecological receptors includes any living organisms other than humans, the habitat which supports such organisms, or natural resources which could be adversely affected by environmental contaminations resulting by a release at or migration from a site.]

Until 2009, much of the environmental response had been managed by the Kentucky Department of Environmental Protection (KDEP) under the Resource Conservation and Recovery Act (RCRA) because of the active chemical plants. The Superfund response had focused on a landfill and burn pit area. However, as EPA’s and KDEP’s understanding of the magnitude of contamination increased, and with the third-party litigation issues among the PRPs, KDEP requested that EPA expand the scope of the Superfund response to also include areas managed by KDEP pursuant to RCRA.

With concurrence from KDEP, EPA proposes to isolate the contamination underlying the site by installing a 3-mile long barrier wall around the facility, and excavating contamination from beneath a 5-acre portion of the river. The total cost of the remedy is estimated at $253M and would be paid by three potentially responsible parties (PRPs).

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What Is Being Done to Clean Up the Site?

  • The PRPs are leading investigative and cleanup activities at the B.F. Goodrich site, with oversight provided by EPA, in cooperation with KDEP. PolyOne, Goodrich and Westlake formed a PRP group and started a large-scale, multi-phase site investigation in August 2010. It included the installation of over 250 soil borings, and the collection and analysis of over 3,000 groundwater, surface water, soil, sediment and air samples.
  • While Superfund was working at the site during the 1980s and 1990s, the Kentucky Department for Environmental Protection (KDEP) led RCRA-related cleanup actions on most of the remainder of the site. Goodrich closed a series of disposal ponds, consolidated contaminated material into an on-site landfill (i.e., the RCRA Closure Cell), and implemented a multi-well groundwater collection and treatment system.
  • In the late 1980s, KDEP required Goodrich to start extracting and treating contaminated groundwater under the RCRA program. This process is called a pump-and-treat program. The goals of the pump-and-treat program are to stop contaminated groundwater before it discharges into the Tennessee River and to extract and treat concentrated areas of contaminated groundwater. KDEP also required Goodrich to obtain a RCRA Corrective Action Permit and conduct environmental studies to investigate the source of contamination and how far the contamination had spread on the RCRA site.
  • Goodrich was responsible for both the CERCLA- and RCRA-related cleanup work. As mentioned above, Goodrich installed a groundwater collection, treatment and disposal system for both areas. An eight-well groundwater collection and treatment system was initially installed in the mid-1980s, under the RCRA program. The system expanded in 1992, as required by the Superfund Record of Decision (ROD) and RCRA Corrective Action Permit. A final expansion of the well system under the RCRA Corrective Action Permit increased the total number to 51. The treatment system discharges the treated groundwater to the Tennessee River. Today, the PRPs monitor changes in groundwater quality and water levels through a 185-well groundwater monitoring system.
  • Later in 2006, a second Five-Year Review of the burn pit and landfill in the eastern portion of the site found that cleanup actions to date were protective of people and the environment in the short term. However, there was a need for additional work to improve cleanup progress in the long term. Groundwater contamination was not decreasing to levels anticipated by EPA. As a result, EPA concluded that the nature of the contamination, such as contamination in non-aqueous phase liquid (NAPL) form, may be impacting cleanup activities at the eastern burn pit and landfill. In 2007 and 2008, EPA determined there are areas of NAPL at and near the burn pit and landfill impacting cleanup progress. In addition, there is evidence of NAPL at the RCRA site. EPA and KDEP concluded that the most effective way to address contamination at the B.F. Goodrich site was to expand the scope of the Superfund response to include the entire site (with the exception of the RCRA closure cell).
  • In 2009, EPA and KDEP expanded the scope of the Superfund response to include the entire 200-acre area underlying the chemical plants and portions of the Tennessee River impacted by releases from the site. An investigation of the site was completed in 2015 and a cleanup decision for the entire site is planned for early 2018.

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What Is the Current Site Status?

Currently, EPA and KDEP are working to complete an evaluation of potential cleanup options and develop a cleanup plan. The results from this effort were summarized in a Proposed Plan and issued for public comment on November 30, 2017.  The public comments will be used by EPA, in conjunction with KDEP, to select a remedy for the cleanup of the site. A final cleanup decision will be documented in a Record of Decision, tentatively planned for mid-2018.

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EPA’s Involvement at the Site

EPA and KDEP have been working to address contamination related issues since the mid-1980's. Early accomplishments include EPA's closure of a former burn pit and landfill along with KDEP's closure of a series of unlined waste ponds and the installation of a colleciton and treatment system to protect the River.

Since the completion of these activities, EPA and KDEP have worked to document the full extent of contamination and potential threats posed by the site. This study was completed in 2015, and a final cleanup plan is anticipated for mid-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.

  • In 2008, B.F. Goodrich and the BOC Group entered into a legal agreement with EPA to conduct a focused remedial investigation and feasibility study for the landfill and burn pit area at the site.
  • In December 2009, after EPA and KDEP decided that the Superfund program would oversee cleanup work on those portions of the site previously regulated by the RCRA Corrective Action program.
  • The PRPs entered into a legal agreement with EPA to conduct an expanded remedial investigation and feasibility study that replaced the previous legal agreement.
  • 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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