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The B.F. 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. Based on public comment received on the 2017, Plan, EPA issued an amenment to the Propsoed Plan in June 2013. After a period of public comment, EPA issued a ROD on September 5, 2018.

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What Is the Current Site Status?

The September 2018, ROD is a major milestone in the cleanup of the BF Goodrich Superfund Site. The first ROD was issued in 1988 and addressed a small portion of the BF Goodrich facility. With the expansion of the scope of the Superfund work in 2009 to also address areas being managed by KDEP pursuant to the Resource Conservation and Recovery Act (RCRA), the September 2018, ROD now addresses all aspects of the Site with the exception of a RCRA landfill that will continue to be overseen by KDEP.

EPA will now begin working with KDEP and the former/current owners and operator to begin the process of implementing the remedy. The first steps will involve entering into an agreement with the owner/operators as potenitally responsible parties (PRPs) for the cleanup of the Site.

EPA expects to have this agreement in place by spring 2019 and begin the process of developing the design for construting the remedy. Much of the information that will be needed is available from the exsisting data, but some additional data collection will be needed. In particular, additional geotechnical data will need to be collected to determine the propert placement, depth, and construction material of the 3-mile long subsurface barrier wall. Data will also need to be collected to better determine location of the NAPL beneath 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 onshore area and the 50-acre offshore area that is referred to as the B.F. 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.

With the issueance of the 2018 ROD, these restricitons were expanded for the entire 250-acre site area. However, these restrictions will not be formalized until after the remedy design is complete and the remedy constructed.

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Sampling and Monitoring

Groundwater samples are collected on an annual basis to monitor the effectiveness of the RCRA 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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