federal mogul department for environmental protection kentucky division of waste management february...

Federal Mogul

Department for Environmental ProtectionKentucky Division of Waste Management

February 10, 2015Presented by Chris Jung

To Protect and Enhance Kentucky’s Environment

Division of Waste Management

Site Location


Federal Mogul


History of the Facility


HISTORY OF FACILITY

• In 1961, Scotscraft, a division of Kirsch, manufactured drapery and curtain rods (zinc plating line).

• Sometime after 1971, Scotscraft expanded operations to the former Wood Master building across the street that is currently occupied by Sumitomo.

• In 1981, Cooper Industries purchased Kirsch.

• In 1990, Cooper ceased all production at the Scottsville facility.

• In mid 1990s, Cooper Industries re-opened the Scottsville facility and began reconditioning and manufacturing brake pads as Wagner.

• In 1998, Federal Mogul acquired Cooper Industries and continued the brake pad manufacturing operation.

• In 2006, Federal Mogul closed the Scottsville facility.

• In 2013, Industrial Warehousing Inc. moved into the building and uses it as a warehouse.


PRIMARY WASTES GENERATED AT THE FACILITY

Metals: Zinc Cyanide Both were common ingredients in the plating process for the

manufacture of the curtain rods.

Volatile Organic Compounds (VOCs): Trichloroethylene (TCE) Dichloromethane Both are common ingredients in many degreasers.


Environmental Regulation• Cooper disposed of wastes in trenches until 1979.

• In mid 1970’s through 1980’s laws were passed that controlled how wastes were disposed.

• Inspections of the facility by the KY Division of Waste Management in the 1980s identified improper storage of hazardous wastes.

• A Notice of Violation was issued to the facility in 1982 for improper storage of drums of hazardous waste.


Drum Storage


Drum Storage and Site Investigation

• In 1991, Cooper entered into an Agreed Order with the Division that required the closure of the drum storage areas.

• The Agreed Order required Cooper to investigate whether there were releases at any other areas at the facility were solid or hazardous wastes were handled.


Facility Assessment• In July 1991, a RCRA Facility Assessment (RFA) was

completed that identified areas behind the facility that required additional investigation for possible releases.

• In 1993, the investigation of the area behind the facility was initiated.

• The investigation looked at contamination in four different areas:– Soil– Groundwater and Surface water– Air


Soil Investigation

• Multiple samplings events and investigations were conducted at the east side of the facility.

• The investigations included over 35 soil borings. Cyanide 370 ppm (Res. Limit = 1600 ppm) Arsenic 37 ppm (Res. Limit = .39 ppm) Trichloroethylene 2,779 ppm (Res. Limit = 2.8 ppm) Cis-1,2-Dichloroethylene 955.9 ppm (Res. Limit = 780ppm)


Boring Locations


Pit Excavation• Based on our data from the soil borings and

employee interviews, the disposal pits were excavated down to bedrock.

• Approximately 52 drums and 172 cubic yards of soils were removed and disposed of at an approved offsite location.


Pit Location


Excavation


Temporary Storage


Groundwater and Surface Water Investigation


Groundwater Investigation

• Between 1998 and 2010, a total of 18 monitoring wells were installed at the site.

• The highest recorded concentration was found in the MW-14B. Groundwater sample tested in 2005 at MW-14B had a TCE concentration of 334 ppm (MCL .005 ppm).


Investigation

•


Interim Measures• Based on the elevated sample results, Federal Mogul

submitted a plan to install extraction wells at the facility.

• In 2005, work began on converting monitoring wells MW-12B and MW-14B into extraction wells.

• Approximately 5000 gallons of water are pumped per day.

• The extracted water is treated onsite by an air stripper to remove contaminants.


Investigation

•


Surface Water Investigation In 2005, sample results from Ramble Creek had elevated

concentrations of trichloroethylene (TCE) and cis-1,2-dichloroethylene (DCE).

Highest recorded TCE concentration was 144 ppb (MCL 5 ppb) in 2006.

Last four monitoring events in 2014 of Ramble creek found the following results for TCE concentration:

•22 ppb

•6.1 ppb

•6.8 ppb

•7.2 ppb


Dye Trace

• A dye trace study was performed in 2006 to find any additional surface water that might be affected by the contamination at this site.

• Dye was injected into monitoring wells and one of the previously excavated pits located to the east of the Federal Mogul property.


Dye Trace Study Area


Confirmatory SamplingRamble Creek


Air Investigation


Air Monitoring

• In 2012, the Division requested offsite sub soil air monitoring to the west of the facility.

• Three outside locations were selected, and a 24-hour test was conducted.

• One sample result evidenced elevated concentrations of trichloroethylene (620 ppb).


Indoor Air Sampling


Trichloroethylene (TCE)• EPA Region 9 Interim TCE Indoor Air

Response Levels:

Residential 2 µg/m³

Commercial/Industrial 8 µg/m³

(8-hour workday)

Commercial/Industrial 7 µg/m³

(10-hour workday)


Indoor Air SamplingIn 2012, the Division requested that Federal Mogul take additional air samples including indoor the houses west of the facility.


Indoor Air Results


Outdoor Air Sampling


Next Phase of Investigation


Projected Work• Federal Mogul will continue to perform air

and groundwater monitoring.

• Federal Mogul is currently implementing a remediation pilot injection project in the former burial pits in the rear of the facility.

• Federal Mogul has recently submitted a plan to install additional on and offsite groundwater monitoring wells.


Geophysical Investigation

Several geophysical studies have been performed both on and offsite, to identify locations for sampling.


Proposed Monitoring Wells

Allen County Public Library

106 West Public Square

Scottsville, KY 42164


200 Fair Oaks

Frankfort, KY 40601 Point of contact: Tina Fisher

(502)564-6716 (fax) (502)564-9232

Email: [email protected]

File Copies

federal mogul department for environmental protection kentucky division of waste management february...

Documents

scottsville facility

division of kirsch

ppm trichloroethylene

cooper industries re

rcra facility assessment

drum storage areas

identified areas

ppm cis